\ ,-c osrq T 

### UNITED STATES ENVIRONMENTAL PROTECTION AGENCY FS7J 

### REGION 10

Z 

### 1200 Sixth Avenue, Suite 

### 900 

## zy , r Seattle, WA 98101-3140



### November 16, 2012

MEMORANDUM

SUBJECT: Intalco BART Technical Review Memo OFFICE OF ENVIRONMENTAL ASSESSMENT



### FROM:

TO: Steve Body, Environmental Scientist

State and Tribal Air Programs Unit, OAWT

This technical memo summarizes my review and technical analysis regarding the application of Best Available Retrofit Technology (BART) at the Alcoa Intalco Works primary aluminum smelter in Ferndale, Washington. As described below, my review focused primarily on BART for sulfur dioxide [SO 2 ] emitted from the potlines.

Due to the length and complexity of this technical memo, I have structured the document as a technical report, including a table of contents, list of attachments, and references.

If you have any questions about this memo, please call me at 3-1217.

C: Mark Filippini, Unit Manager, ESU, OEA Debra Suzuki, Unit Manager, STAPU, OAWT Juliane Matthews, ORC Dave Bray, OAWT

### 2 

# Table of Contents

1. Documents Reviewed

.................................................. ................................................... ....... 4

2. Scope of Review

.................................................. ................................................... ................ 5

3. Anode Bake Oven

.................................................. ................................................... .............. 5

4. Review of SO 2 

### Control Technologies for the Potlines

.................................................. ....... 6

4.1. Dry Sorbent Injection (DSI) or Dry Scrubbing

.................................................. ............... 6

4.2. Semi-Dry FGD or Spray Drying

.................................................. ....................................... 7

4.3. Seawater Scrubbing

.................................................. ................................................... ...... 8

4.4. Sodium Scrubbing

.................................................. ................................................... ......... 8

5. Review of Limestone Slurry Forced Oxidation (LSFO) Wet Scrubbing ............................. 9

5.1. Technical Feasibility

.................................................. ................................................... ..... 9

5.2. Cost Effectiveness

.................................................. ................................................... ........ 10

5.2.1. Low Bid

.................................................. ................................................... ..................... 10

5.2.2. Single Scrubbing Tower

.................................................. ............................................. 11

5.2.3. Equipment Life

.................................................. ................................................... ......... 12

5.2.4. Gypsum Reuse

.................................................. ................................................... .......... 13

5.2.5. Erection Cost

.................................................. ................................................... ............ 14

5.2.6. Summary of Cost Effectiveness

.................................................. ................................. 14

5.3. Environmental Impacts of LSFO

.................................................. ................................... 15

5.3.1. Wastewater

.................................................. ................................................... .............. 15

5.3.2. Water

.................................................. ................................................... ........................ 16

5.3.3. Air Quality

.................................................. ................................................... ................ 16

5.3.4. Energy

.................................................. ................................................... ....................... 17

5.3.5. Solid Waste

.................................................. ................................................... ............... 17

### 3 

# Attachments

Ecology BART Analysis for Intalco .................

................................................... ............. Attachment 1 Environ BART Analysis for Intalco .................

................................................... ............. Attachment 2 Hatch Pre-Feasibility Report ......................

................................................... ................... Attachment 3 40 CFR 51 Appendix Y ..............................

................................................... ........................ Attachment 4 Intalco Primary Call Log – Zach Hedgpeth ..........

................................................... ..... Attachment 5 NY SPDES Permit Form NY-2C for Massena-East Smelter .................................... Attachment 6 Email from Robert Jacobs, NYDEC dated 1/10/12 ..... ............................................. Attac hment 7 NY SPDES Number NY0000132 – Massena-East Smelter .. ................................... Attachment 8 Intalco Wastewater Flow Schematic, June 2011 ...... ................................................. A ttachment 9 Intalco NPDES Fact Sheet 2007 .....................

................................................... .............Attachment 10 EPA Region 10 LSFO Cost Effectiveness Analysis .... ...............................................Atta chment 11 EPA Region 10 LSFO Capital Cost Scaling Summary Tab le .................................Attachment 12 EPA Region 10 Market Review for Intalco-Produced Gy psum .........................Attachment 13 Intalco LSFO Cost Elements Comparison .............

................................................... ...Attachment 14 EPA Region 10 Intalco Water Demand Memo to File ... .........................................Attachment 15

### 4

1. Documents Reviewed This memo describes my technical review of BART as it applies to the Intalco primary aluminum smelter. My review necessarily began with the BART analysis for Intalco submitted to EPA by the Washington State Department of Ecology 1 

### . This document was submitted to EPA within Appendix L of the Washingto n Regional Haze State Implementation Plan (SIP), and is available along w ith supporting information on Ecology’s BART website 2 

### . This document is also included as Attachment 1 t o this memo, and is referred to as the “Ecology BART analysis” througho ut this memo.

However, research identified four additional primar y technical documents on which Ecology’s analysis relied substantially, either dir ectly or indirectly.

Ecology’s BART analysis was developed primarily bas ed on a BART analysis for Intalco prepared by Environ Corporation under contract with the company 3 

### . This document is included as Attachment 2 to this memo, and is refer red to as the “Environ BART analysis” throughout this memo.

The Environ BART analysis contains the BART analyse s for the potlines and other emission units subject to BART at Intalco. Environ’s techni cal feasibility and cost evaluation of limestone slurry forced oxidation (LSFO) scrubbing for SO 2 

### removal are based in part on a pre-feasibility report 4 

### prepared by Hatch under contract with Intalco’s pa rent company Alcoa Corporation. This document is included as At tachment 3 to this memo, and is referred to as the “Hatch pre-feasibility report” t hroughout this memo.

The Hatch and Environ analyses in turn utilized equ ipment capital cost quotes from two vendor reports commissioned by Alcoa for their smel ter in Alcoa, Tennessee. These capital cost quote documents are described as the Vendor #1 quote and the Vendor #2 quote in this document. I obtained these two vendor documen ts in order to perform a thorough review of the cost analysis. Alcoa submitted these two documents to EPA accompanied by a claim that they contained confidential business i nformation (CBI).

In the Regional Haze SIP, Washington requires all s ources subject to BART to follow EPA’s BART Guidelines of 40 CFR 51 Appendix Y; see Sectio n 1.1 of the Ecology BART analysis. Likewise, I used Appendix Y as the basis for this t echnical review. A copy of Appendix Y is included as Attachment 4 to this document.

1 

### Washington State Department of Ecology, “BART Determination Support Document for Alcoa Inta lco Works, Ferndale, Washington”, dated August 2009, revised F ebruary 4, 2010.

2 

### http://www.ecy.wa.gov/programs/air/globalwarm_RegHa ze/BART/BARTInformation.html#Intalco

3 

### Environ Corporation, “BART Determination for Alcoa Intalco Works, Ferndale, Washington”, dated November 2007.

4 

### Hatch, “Alcoa Primary Metals USA, Pre-Feasibility R eport, SO 2 

### Scrubbing for the Intalco Primary Aluminum Smelter”, dated November 5, 2007.

### 5

2. Scope of Review I reviewed Ecology’s BART analysis for Intalco in i ts entirety, but address most components in an abbreviated manner or only via summary commen t. My review focused on the BART determination for sulfur dioxide (SO 2 

### ) from the potlines for the following reasons:

1. The pollutants of interest with respect to visibili ty impacts are particulate matter (PM), nitrogen oxides (NO X 

### ), and sulfur dioxide (SO 2 

### ). 2. SO 2 

### emissions from Intalco significantly impact visibi lity at Olympic National Park and up to six other Class I areas in Washington. 3. According to the Ecology BART analysis, the potline s are permitted to emit 37,780 pounds of SO 2 

### per day (6,895 tons per year). 4. The primary air pollution control system employed b y Intalco for control of potline emissions consists of dry alumina injection followe d by fabric filtration. This level of control appears consistent with BART for PM. 5. As described in the Ecology BART analysis, emission s of NO X 

### from the potlines are insignificant since the potlines are electrically h eated (versus combustion of fossil fuels) and none of the raw materials contain signif icant quantities of nitrogen. 6. The potlines are the primary industrial process at the facility and are not equipped with active control technology for SO 2 

### . Currently the sole air pollution control strategy in place to reduce emissions of SO 2 

### from the potlines consists of limits on sulfur content in the petroleum coke (3.0 %) and pi tch (0.6 %) used in the manufacture of the pre-baked anodes. The anodes ar e consumed in the production of aluminum, thereby directly emitting SO 2



### .

Other than limited discussion of the anode bake ove n, the bulk of this memo delineates the areas and portions of the BART technical analysis f or SO 2 

### emissions from the potlines at the Intalco smelter where I disagree with the state and facility analyses. The memo also presents my revised cost effectiveness analysis for SO 2 

### from the potlines. I generally agree with the Environ and Ecology BART analyses with res pect to other pollutants and emission units at Intalco.

3. Anode Bake Oven The anode bake oven is the next largest air polluta nt emitting process after the potlines. The oven has uncontrolled emissions of 181 tons of SO 2 

### per year according to the Environ BART analysis. According to the Ecology BART analy sis, the oven also emits PM, NO X 

### , hydrocarbons, and fluoride, and has a total maximum visibility impact of approximately 0.053 deciview at Olympic National Park. Environ, in their BART analysis, estimates that approximately 40% of this visibility impact is due to SO 2 

### emissions. The oven is fired on natural gas and emissions are controlled with a dry alumina scrubber and baghouse similar to the potlines. The existing dry scrubber system provides high efficiency emission control for PM. In their BART analysis, Ecology rejected l ow efficiency (~20% reduction) controls for NO X 

### based on negligible visibility improvement.

Analyses examining control of SO 2 

### from the anode bake oven assumed that the exhaust gas stream would require a separate scrubber from the o ne controlling the potlines. Based on

### 6

a scaling approach described in the Hatch pre-feasi bility report, the Environ BART analysis includes estimated cost effectiveness values for a dedicated scrubber to control emissions from the anode bake oven. These estimates are base d on the vendor quotes for the potline LSFO scrubber, and resulted in a cost estimate of $ 36,400/ton of SO 2 

### removed.

None of the vendor quotes or subsequent cost analys es estimated the cost of routing the anode bake oven exhaust gas stream to a scrubber wh ose primary purpose was controlling SO 2 

### emissions from the potlines. Because of the small visibility impact of SO 2 

### emissions from the anode bake oven, I did not pursue further research into this potential control option.

4. Review of SO 2 

### Control Technologies for the Potlines The Environ BART analysis examined a total of eight control technologies with respect to SO 2 

### emissions from the potlines. Two of these control technologies are dry or semi-dry scrubbing technologies while the remaining six are wet scrubbing technologies. These control technologies are listed below:

Dry or Semi-Dry Technologies 1. Dry Sorbent Injection (DSI) or Dry Scrubbing 2. Semi-Dry Scrubbing or Spray Drying

Wet Technologies 3. Limestone Slurry Natural Oxidation (LSNO) Scrubbing 4. Conventional Wet Lime Scrubbing 5. Dual Alkali Sodium/Lime Scrubbing (dilute mode) 6. Seawater Scrubbing 7. Conventional Sodium Scrubbing 8. Limestone Slurry Forced Oxidation (LSFO) Scrubbing

Based on the Hatch, Environ, and Ecology documents, I focused my review on LSFO. This technology was selected by Environ and Ecology as t he best option among the technically feasible wet scrubbing technologies, and vendor cos t quotes were available. I agree that LSFO is the best option based on my independent res earch and analysis discussed below regarding the other technologies, and based on the considerations discussed in the Environ and Ecology BART analyses. I did not conduct furth er analyses regarding LSNO, Conventional Wet Lime Scrubbing, and Dual Alkali So dium/Lime Scrubbing because I agree with Ecology’s determination that these technologie s either have clear disadvantages or are likely to be more costly than LSFO. I conducte d targeted research and analysis on the remaining control technologies as described below.

4.1. Dry Sorbent Injection (DSI) or Dry Scrubbing Dry Sorbent Injection (DSI) can be used to remove S O 2 

### from an exhaust stream by contacting the exhaust gas with a dry powder alkali ne reagent, which is usually calcium or sodium based. Under appropriate conditions, SO 2 

### and other acid gasses are adsorbed onto the dry reagent particles and react with the reagen t to form a solid salt. The particulate matter must be removed downstream, usually via a ba ghouse or electrostatic precipitator.

### 7

Dry scrubbing can achieve between 50-90% SO 2 

### removal depending on the reagent used and other design factors (EPA, 2003).

The Ecology BART analysis discusses dry scrubbing o n page L-68, and rejects the technology as technically infeasible due to the low temperature of the exhaust gas downstream of the existing baghouses (≤ 205° F) and the low SO 2 

### concentration (≤ 105 parts per million by volume, ppmv) in the exhaust g as. Ecology based this determination on the Environ BART analysis, which in turn appears to be based on an EPA Fact Sheet, establishing 300° F as the minimum required tempera ture for dry sorbent injection (EPA, 2003). In addition to literature review which gene rally supports this finding (EPA, 2000 and NCSU, 1998), I contacted a vendor of dry scrubb ing technology 5 

### who confirmed the importance of exhaust gas stream temperature, and s tated that their dry scrubbing technology could successfully control SO 2 

### emissions for gas stream temperatures down to approximately 250-260° F.

Potential approaches to increasing the gas stream t emperature such as fixing duct leaks which introduce cold ambient air and/or direct heat ing of the exhaust stream were not discussed in the Environ BART analysis. Using stra tegies such as these, it may be possible to raise the gas stream temperature a sufficient am ount (on the order of 50-100° F) to make dry scrubbing technically feasible. However, direct heating is likely to require significant fuel usage since the volumetric flow ra te of exhaust gas from the potlines is on the order of 2 million actual cubic feet per minute (acfm).

Upstream of the existing baghouses, the exhaust gas temperature may be in the temperature range that is technically feasible for DSI. However, injection of the alkaline reagent would be likely to render the baghouse catc h unsuitable for recycling to the potlines as is the current practice for reclamation of the alumina and collected fluorides.

Based on these considerations, I agree with Ecology ’s determination that with a flue gas temperature of ~205° F, dry scrubbing is technicall y infeasible for control of SO 2 

### emissions from the potlines at Intalco.

4.2. Semi-Dry FGD or Spray Drying Spray drying is similar to dry scrubbing except tha t the alkaline reagent is sprayed in slurry form into the exhaust gas (usually within an absorb er chamber) upstream of a particulate matter removal device. Spray drying is generally a ble to achieve higher rates of SO 2 

### removal than dry scrubbing because the moisture on the particles enhances SO 2 

### removal (EPA, 2003). The quantity of water that is injecte d is carefully controlled in order to ensure that the exhaust gas stream is dry by the time it r eaches the particulate matter control device. Because of the need to evaporate the moist ure introduced into the exhaust gas, spray drying generally requires temperatures higher than those needed for dry scrubbing. Based on the temperature requirements, I agree that spray drying is technically infeasible for control of SO 2 

### from the potlines at Intalco.

5 

### See Attachment 5. September 7, 2011 phone convers ation with Don Hug of Allied Environmental.

### 8

4.3. Seawater Scrubbing Seawater scrubbing is used in Europe for control of SO 2 

### emissions from primary aluminum smelters similar to Intalco (Exponent, 2005). As w ith other wet scrubbing technologies, an alkaline solution (in this case seawater) is spraye d into the exhaust gas stream within one or more vertical towers. By encouraging contact be tween the SO 2 

### -containing gas stream and the slightly alkaline seawater, SO 2 

### is removed from the gas stream via absorption. Unlike LSFO and certain other wet scrubbing technol ogies, seawater scrubbing is a “once through” technology where the entire scrubber flow rate must be disposed of as

wastewater.

As described on pages L-81 to L-83 in their BART an alysis, although technically feasible, Ecology eliminates seawater scrubbing from consider ation as BART due to water quality discharge concerns. Unlike aluminum plants in Euro pe, wastewater discharge from primary aluminum smelters in the U.S. must comply w ith specific limits on fluorides among other pollutants (see 40 CFR 421, Subpart B). The Ecology BART analysis reiterates the argument developed in the Environ BART analysis sta ting that the necessary wastewater treatment facilities would not be cost-effective, a nd would produce a large amount of wastewater treatment sludge. Treatment of seawater would produce significantly more sludge than freshwater since precipitation of the n atural salts would be necessary in order to remove target pollutants.

Besides the concerns noted by Ecology the offshore aquatic area immediately surrounding the Intalco smelter has been designated as an envir onmental aquatic reserve for the protection of herring. New saltwater intake struct ures, which would be necessary for seawater scrubbing, are explicitly prohibited on pa ge 54 of the Cherry Point Environmental Aquatic Reserve Management Plan (DNR, 2010).

No cost analysis was conducted for seawater scrubbi ng. It is likely that the costs associated with extending saltwater intake and outfall infrast ructure beyond the aquatic reserve and associated wastewater treatment and sludge disposal costs would result in the technology being deemed cost-prohibitive, but these analyses w ere not included in either the Ecology nor Environ BART analyses. Based on these consider ations, I agree that although seawater scrubbing is technically feasible, it cannot be con sidered BART for control of SO 2 

### emissions from the potlines at Intalco.

4.4. Sodium Scrubbing Sodium scrubbing is a wet scrubbing technology usin g scrubber liquor containing a sodium reagent. The infrastructure and associated capital costs for a sodium scrubber would be similar to that of LSFO, although sodium-based reag ents are generally more expensive than limestone or lime (NCSU, 1998). Furthermore, based on the wastewater issues experienced at the Alcoa Massena-East smelter in Ne w York, a new sodium scrubber for the potlines at Intalco may require significant upgrade s to the wastewater treatment plant at Intalco in order to comply with water quality stand ards and protect the Cherry Point Aquatic Reserve. Accordingly, research suggests th at sodium scrubbing would be more costly than LSFO.

### 9

Research indicates that the Massena-East plant is t he only primary aluminum plant in the United States that currently operates a sodium scru bber for control of SO 2 

### from potlines. The sodium scrubber wastewater bleed stream requiri ng treatment at Massena-East is approximately 32 gallons per minute (gpm) 6 

### . This facility has had difficulty meeting its wastewater discharge permit limits 7 

### despite having more advanced wastewater treatment infrastructure than is currently in place at Intalc o 8



### .
Currently, emissions from the roof vents at Intalco are controlled by a series of small, dilute sodium scrubbers using soda ash 9 

### . The wastewater bleed stream from the roofline scrubbers which requires secondary treatment prior to discharge is approximately 48 gallons per minute (gpm) 10 

### . Secondary treatment at Intalco consists of an eq ualization tank followed by two parallel treatment trains, eac h including reaction and flocculation vessels for chemical treatment. Solids are removed using a clarifier and dewatered before disposal at the facility’s onsite landfill 11



### .
The experience at the Massena-East plant is consist ent with information available in the literature suggesting that treatment of process was tewater from sodium scrubbers can be more difficult due to the high solubility of sodium compounds (APTI, 1998). This characteristic of sodium scrubbers is also noted on page 17 of the Environ BART analysis. Based on these considerations, although sodium scru bbing is technically feasible for control of SO 2 

### emissions from the potlines at Intalco, I consider it likely to be more expensive than LSFO.

5. Review of Limestone Slurry Forced Oxidation (LSFO) Wet Scrubbing

5.1. Technical Feasibility On pages 5-5 and 5-17 of their BART analysis, Envir on identifies LSFO as the best choice among technically feasible control technologies for SO 2 

### emissions from the potlines. I agree with this determination based on evaluation o f the Environ BART analysis, as well as the Hatch pre-feasibility report and the two quotes from Vendors #1 and #2 cited above. All of these consultant reports agree that LSFO ach ieving an SO 2 

### removal efficiency of 95% is technically feasible for the Intalco potlines. Ecology also confirms the determination that LSFO is technically feasible on page L-68 of their BART analysis.

6 

### See Attachment 6. New York State Pollutant Dischar ge Elimination System (SPDES) Number NY0000132. Industrial Application Form NY-2C, Section II Outfa ll Information. Massena-East Facility, Outfall 01A . Process wastewater flow rate = 0.046 million gallons per da y (~32 gallons per minute).

7 

### See Attachment 7. January 10, 2012 email from Robe rt Jacobs, New York State Department of Environmental Conservation.

8 

### See Attachment 8. New York SPDES Number NY0000132 for the Massena-East Smelter. Carbon treatment is cited for Outfall O1A on page 24 of 28.

9 

### See Attachment 5. December 2, 2011 phone conversat ion with Kathryn Mitchell, Environmental Manager – Alcoa Intalco Works.

10 

### See Attachment 9. Process and Storm Water Flow Sch ematic, Intalco Aluminum Corporation, June 2011. Flow rate to secondary treatment = 0.07 million gal lons per day (~48 gallons per minute).

11 

### See Attachment 10. Intalco Fact Sheet for NPDES Permit WA-000295-0, Ma rch 15, 2007, page 8.

### 10

Ecology eliminated LSFO from consideration as BART based on cost-effectiveness as well as secondary environmental impacts, which are detailed below.

5.2. Cost Effectiveness As discussed above, all capital cost estimates for LSFO are based on two site-specific vendor quotes for the primary aluminum smelter loca ted in Alcoa, Tennessee. In the Hatch pre-feasibility report and the Environ BART analysi s, the two capital equipment quotes were averaged and scaled from the Tennessee facilit y to the Intalco operations based on differences in limestone consumption, gypsum produc tion, and exhaust gas flow rate. These calculations are summarized in Appendix D of the Environ BART analysis. Environ’s BART analysis for LSFO to control SO 2 

### emissions from the potlines resulted in a cost effectiveness value of $7,500/ton of SO 2 

### removed.

Ecology made several revisions to the Environ cost effectiveness analysis for LSFO for the potlines in their BART analysis, reducing the cost effectiveness value to $6,145/ton. The most significant change Ecology discusses is to eli minate the second spray tower which was included in the Hatch and Environ documents. T his second spray tower provided 100% scrubbing redundancy.

As described in this memo and attachments, I am fur ther revising the BART cost effectiveness analysis for LSFO to control SO 2 

### emissions from the potlines at Intalco. I agree with Ecology that the redundant scrubbing tow er is not necessary for the purposes of Regional Haze, and I also make several other change s to the analysis, further improving the cost effectiveness to an estimated range of $3,875 – $4,363/ton. My detailed cost effectiveness analysis is included as Attachment 11 to this memo. In addition to eliminating the cost for the redundant absorber, th e primary changes made to the analysis

are:

• The lower of the two vendor quotes is used rather t han the average,

• The scrubber equipment life is assumed to be 30 yea rs rather than 15,

• I assume the gypsum by-product is re-used rather th an sent to a landfill, and

• I evaluated the cost using a 40% erection cost fact or (per the EPA Control Cost Manual), and alternatively an 80% erection cost fac tor (as used by Environ).

The following sections include my rationale and bas is for the primary changes to the Environ cost effectiveness analysis for LSFO on the potlines.

5.2.1. Low Bid As discussed, I obtained copies of the capital equi pment quotes from Vendor #1 and Vendor #2 for LSFO to be installed on the potlines at the Tennessee smelter. The Environ BART analysis averaged these two quotes in applying these capital costs to the Intalco potlines. This approach is unacceptable based on t he EPA Air Pollution Control Cost Manual (EPA, 2002), and is not in accordance with s tandard contracting procedures.

### 11

The Control Cost Manual clearly supports the use of the low bid. Specifically, the manual states that “[s]ignificant savings can be had by so liciting multiple quotes” 12 

### and discusses the ability to “compare to other bids” 13



### .
This is in accordance with the standard contracting procedure of selection of the lowest responsive bid for equipment or services. The qual ifier “responsive” generally serves to allow exclusion of bids which are deemed inadequate to satisfy the requirements of the project. In this case, both bids were submitted by experienced, reliable equipment suppliers and were obviously considered responsive by Hatch and Environ since both quotes were utilized in both the Environ BART analy sis and the Hatch pre-feasibility report for Intalco.

My cost effectiveness analysis uses the lower of th e two capital equipment quotes, scaled from the Tennessee smelter to Intalco using the met hod described in the Hatch prefeasibility report. The specific method used to sc ale the capital quotes developed for the Tennessee smelter to the Intalco smelter is describ ed in section 5 of the Hatch report. This scaling approach can be summarized as follows.

The total capital cost of the LSFO system is broken down into specific components of the air pollution control system. For example, the reagent feed system is assumed to account for 10% of the total capital cost. Each specific compo nent of the capital cost is then scaled based on the most relevant operational parameter us ing a general formula for cost scaling. For example, the reagent feed system cost is scaled based on estimated limestone consumption.

In calculating my scaled capital cost, I followed t he method described in the Hatch prefeasibility report with the exception that I used t he lower of the two bids rather than the average. The EPA Region 10 and Environ capital cos t scaling calculations are summarized in Attachment 12. Scaling the capital costs based on the lower bid rather than the average reduced the Intalco capital cost from $80,445,682 t o $71,142,440.

5.2.2. Single Scrubbing Tower The Environ BART analysis is based on the assumptio n of a two absorber (spray tower) system, providing 100% redundancy. This approach w as taken in order to provide the same level of emissions control all the time, inclu ding during routine shutdown and maintenance of the primary spray tower. Primary al uminum facilities such as Intalco do not typically shut down operations periodically (as is usual across industry) since a potline is in continuous operation once started-up.

The Ecology BART analysis reduces the costs signifi cantly by assuming that the LSFO system required to be installed on the potlines wil l have only a single absorber tower. One of the vendors provided quotes for both dual tower and single tower LSFO systems, with

12 

### EPA, 2002. Page 3-38; Chapter 3 – Electrostatic Precipitators; Section 6 – Particulate Matter Controls.

13 

### EPA, 2002. Page 1-29; Chapter 1 – Selective Non-catalytic Reductio n (SNCR); Section 4.2 – NO X 

### Post Combustion.

### 12

the single tower system capital costs being about 2 8% lower than the dual tower system. Installation of LSFO with a single absorber tower w ould result in some amount of scrubber down time during which emissions from the existing dry scrubbers/fabric filters would be released uncontrolled for SO 2 

### emissions (as is currently the case all the time).

I agree that this change made by Ecology is appropr iate, and consider that the significant additional cost incurred by a two tower design to p rovide 100% redundancy is not an appropriate basis for rejecting LSFO as too costly as BART. A single scrubbing tower designed to treat the entire potline exhaust gas st ream can be expected to achieve significant SO 2 

### reductions at a reduced cost. I consider this typ e of system modification to be appropriate in order to develop a cost effective BART control option to protect visibility under the Regional Haze Program.

My analysis incorporates this reduced capital equip ment cost as well as reduced SO 2 

### removal based on an estimated two week annual shutd own of the scrubber for necessary
maintenance.

5.2.3. Equipment Life The Environ BART analysis uses an expected equipmen t lifetime of 15 years for the LSFO system. No basis for the 15 year lifetime is given ; the number is listed only as an assumption. I disagree that 15 years is an appropr iate length of time to use as the equipment life 14 

### for LSFO. My cost analysis uses a 30 year lifetim e. My basis and rationale are described below.

The expected service life of wet flue gas desulfuri zation (FGD) systems such as LSFO is cited as 30 years in the literature. Specifically, the air pollution control textbook

“ Estimating Costs for Air Pollution Control ” 15 

### cites 30 years as the typical lifetime for FGD systems (Vatavuk, 1990). Additionally, an equipmen t life of 30 years is cited in published papers, including a 2002 article in Chemical Engine ering & Technology magazine (Warych, 2002) 16 

### and a published EPA report (Kaplan, 1990).

The actual life of wet FGD scrubbers installed at c oal fired power plants has been demonstrated to be 30 years or more for many plants . Industry reports establish scrubber longevity near or exceeding 30 years. For example, I examined a public report by the Electric Power Research Institute (EPRI) which revi ewed the operations of a large number of coal fired power plants (EPRI, 2005). Of the pl ants reviewed in this report, roughly a dozen plants which are currently in operation have wet limestone FGD systems that were installed in the 1970’s and 1980’s. Examination of the record of FGD systems on coal fired power plants is useful due to the established natur e of this control device in industry, and because the large exhaust gas flow rates from utili ty boilers are generally comparable to those produced by primary aluminum smelters such as Intalco. In fact, the less

14 

### EPA, 2002. See Chapter 2 – Cost Estimation: Concep ts and Methodology; Section 1 – Introduction, specifically pages 2-19 through 2-21 for discussion of equipment life.

15 

### Vatavuk, 1990. See page 198.

16 

### Warych, 2002. See pages 427-432.

### 13

concentrated pollutant gas stream from an aluminum smelter suggests that the FGD system longevity may be enhanced when compared to an FGD s crubber controlling emissions from a coal fired boiler due to reduced wear and tear on the scrubber components.

Based on the literature citations of 30 years as a typical expected FGD life and the actual longevity of FGD equipment in industry I consider 3 0 years to be a reasonable timeframe for use as the actual equipment life for LSFO at In talco. The use of a 30 year life is also consistent with other BART determinations made by E PA. See for example the Oklahoma BART Federal Implementation Plan (FIP) final rule i ssued by Region 6 17



### .

5.2.4. Gypsum Reuse The Environ BART analysis assumes the gypsum produc ed as a by-product from LSFO at Intalco would be disposed of in a landfill at a cos t of $145/ton (about $4 million per year). Yet the Environ BART analysis as well as LSFO desig n information contained within the vendor cost quotes indicates that the gypsum produc ed as a by-product of LSFO would be suitable for re-use.

Region 10 conducted an internal economic analysis t o evaluate the potential for beneficial reuse of the gypsum by-product from LSFO (Attachmen t 13). This analysis identified several applications for FGD gypsum in addition to market factors which suggest the likely presence of a market for the gypsum produced by Int alco. Specifically, the analysis found that a significant price differential exists betwee n FGD gypsum and natural (mined) gypsum favoring the former. Also, the quantity of FGD gypsum produced by Intalco would constitute a very small percentage of the market an d is comparable to the quantity likely used by area cement plants 18 

### . Also, anecdotal evidence indicates that syntheti c gypsum produced by the LSFO scrubber at the TransAlta coal -fired power plant in Centralia, WA is a highly sought after “green” product 19 

### . Additionally, with the recently imposed requirement that the TransAlta plant cease burning coal in their two boilers in 2020 and 2025 20 

### , this local source of synthetic gypsum will no lon ger be available. This would reasonably be expected to positively impact demand for other regional sources of synthetic gypsum such as Intalco.

Furthermore, a cost study for the LSFO scrubber at the Centralia power plant which was conducted by Sargent & Lundy (Sargent, 1996) prior to scrubber construction took re-use of the gypsum by-product into account and applied a credit of $5/ton to the cost analysis.

17 

### 76 FR 81728, December 28, 2011.

18 

### For example, the Ash Grove Cement Plant in Seattle has a maximum production capacity of approximately 750,000 tons of cement clinker per year (PSCAA, 200 4). Gypsum is generally used as an additive to cli nker at approximately 4-5% by weight (Shreve’s, 1984). At the 5% rate, the Ash Grove Cement Plant in Seattle would use about 37,500 tons of gypsum annually when opera ting at full load. According to Environ, a LSFO sc rubber at Intalco would produce approximately 27,130 tons of gypsum when operating at full capacity.

19 

### “ TransAlta and George Pacific Share Win-Win Situatio n ”. Daniel Brunell. Association of Washington Business online article. July-August 2004. http://www.awb.org/articles/environment/transalta_a nd_georgia_pacific_share_win_win_situation.htm

20 

### See Ecology Order No. 6426, 1 st 

### Revision, Issued December 13, 2011. Available on Ecology’s website at http://www.ecy.wa.gov/programs/air/TransAlta/TransA lta_Revised_BART_CO_12-13-2011.pdf

### 14

Sargent & Lundy also estimate that disposal of the FGD gypsum would cost only $6/ton. Although these costs are presented in 1996 dollars, a large discrepancy exists between the Sargent & Lundy analysis and the $145/ton disposal cost used in the Environ BART analysis.

Based on the design specification establishing that the gypsum by-product would be suitable for commercial reuse, the evidence suggest ing a likely market for the gypsum, and the considerable financial incentive that would exi st for Intalco to sell or even give away the FGD gypsum rather than landfill it, I do not ag ree that it is reasonable to assume that the gypsum from the LSFO process will be disposed o f in a landfill. Furthermore, it appears that the $145/ton disposal cost used in the Environ BART analysis likely overstates the disposal costs.

My cost effectiveness analysis therefore eliminates the gypsum disposal costs and assumes that Intalco gives the gypsum away free on board 21 

### at the facility in Ferndale. Any proceeds from the sale of the gypsum would further improve t he LSFO scrubber cost effectiveness.

5.2.5. Erection Cost The Environ BART analysis doubles the cost factor u sed in the EPA Control Cost Manual to estimate the costs of erecting the control equipmen t. Specifically, the EPA Control Cost Manual estimates the erection cost as 40% of the pu rchased equipment cost (PEC). Environ’s BART analysis doubles this factor to 80% of the PEC. The Environ BART analysis justifies this increase only by referring to “retro fit of the existing plant and onsite fabrication”. In my opinion, inadequate basis is p rovided in the Environ BART analysis for this cost increase.

As discussed in the EPA Control Cost Manual, it is reasonable to consider additional costs which are determined to be necessary for retrofit p rojects. However, since no basis for the doubled erection cost was provided, my cost effecti veness analysis presents costs with and without this additional cost in order to illustrate the impact this apparently arbitrary and unsupported additional cost has on cost effectivene ss. If the EPA Control Cost methodology is used, my estimate of the cost effectiveness of L SFO falls from $4,363/ton to $3,875/ton.

5.2.6. Summary of Cost Effectiveness A table describing the differences between the Envi ron and the EPA Region 10 LSFO cost analyses in more detail is included as Attachment 1 4. The following summarizes the Environ and EPA LSFO cost analyses.

Environ EPA Region 10 Low EPA Region 10 High Capital Cost (millions) $235 $128 $152 Annual O&M Costs (millions) $21 $14 $14 Cost Effectiveness ($/ton) $7,500 $3,875 $4,363

21 

### Free on Board, defined here where the buyer pays fo r all loading, transportation, and unloading costs.

### 15

5.3. Environmental Impacts of LSFO Although operation of an LSFO scrubber on the Intal co potlines has the potential to reduce SO 2 

### emissions by over 6,000 tons per year, the scrubbe r would result in collateral energy and environmental impacts. A summarized discussion of these impacts is included below.

5.3.1. Wastewater According to the Environ BART analysis, “only a ver y small purge or blowdown stream is required” 22 

### for the LSFO system contemplated for control of SO 2 

### from the Intalco potlines. Review of the vendor reports obtained by Region 10 from Alcoa corroborates this statement, indicating that preliminary design of th e LSFO system included either a wastewater purge flow rate of a few gallons per min ute, or no purge flow rate at all. Further, Section 3.2 of the Hatch pre-feasibility r eport includes a detailed description of the liquid stream dispositions, and states that "the gy psum is left with 15 percent moisture which prevents the need for a liquid purge stream o therwise needed to purge impurities from the process".

I also conducted additional investigations to furth er examine whether LSFO is likely to result in significant negative water quality impact s. My additional work on this subject included research to: 1. Better understand the ability of Intalco’s existing wastewater treatment infrastructure to handle the projected additional w astewater flow rate (if any) from a new LSFO scrubber, and 2. Explore the implications of the Washington Departme nt of Natural Resources (DNR) Cherry Point Aquatic Reserve Management Plan (DNR, 2010).

In order to adequately understand the potential wat er quality implications of a new LSFO scrubber on the potlines at Intalco, I consulted wi th wastewater engineering staff within EPA Region 10. I provided our wastewater engineer with the specific information on the projected LSFO wastewater purge stream contained in the CBI vendor documents in addition to publicly available information on Intal co’s current wastewater effluent streams and treatment infrastructure. Specifically, this i nformation included the preliminary design purge flow rate of not more than a few gallons per minute (or no flow at all), and the detailed information regarding the existing wastewa ter quantity and quality as well as existing treatment infrastructure at the Intalco sm elter. The detailed information regarding the current wastewater streams and treatm ent infrastructure is contained in the NPDES materials included as Attachments 9 and 10. This internal review resulted in the opinion that the very small projected new wastewate r purge stream from LSFO is unlikely to require significant upgrades to the existing was tewater treatment infrastructure at Intalco. However, it is likely that modification t o the facility NPDES 23 

### permit would be required if the scrubber did produce a new, small w astewater purge stream.

The majority of the near shore aquatic lands adjace nt to the Intalco smelter are included in an aquatic lands reserve established by the State o f Washington (DNR, 2010). This aquatic

22 

### See Attachment 2, page 5-5.

23 

### National Pollutant Discharge Elimination System

### 16

land is protected by a management plan which would likely subject modified NPDES permit approvals to requirements beyond those otherwise ap plicable such as compliance with water quality standards. Review of the management plan as well as discussions with staff at the Washington DNR 24 

### and Ecology 25 

### who implement the plan indicate that the most likely additional requirements would consist of a s eries of scientific studies described in the management plan. According to DNR and Ecology staff familiar with the topic, an initial round of these studies has been completed at a cost of approximately $235,000. This cost included method development work so that future ite rations of the studies may cost substantially less. State staff estimated that if a second round of these studies were required for a revised NPDES permit at Intalco, the y could be completed in about one year.

Based on the above information, my cost analysis fo r LSFO includes an additional $235,000 in first year costs to cover these scientific studi es.

5.3.2. Water According to the Environ BART analysis, a new LSFO scrubber on the Intalco potlines would use an estimated 182.5 million gallons of fre sh water per year or approximately 0.5 million gallons per day (MGD). In their BART analy sis, Environ states that this 9% increase over current usage would “significantly impact the community infrastructure” 26 

### . On page L-79 of their BART analysis, Ecology discusses comm ents received from Intalco explaining that Intalco has relinquished a portion of their hi storic water rights, making it difficult to obtain the water rights for an LSFO scrubber.

In order to verify the facility and consultant clai ms regarding the difficulty of obtaining water for an LSFO scrubber, I contacted the Whatcom County Public Utility District (PUD), which supplies water to Intalco. Contrary to claim s by Environ and Intalco, the PUD General Manager Stephan Jilk stated that Whatcom Co unty PUD would have no difficulty supplying the necessary additional 0.5 MGD of fresh water required by an LSFO scrubber. Mr. Jilk also provided more accurate cost informati on based on the current fee schedule used by the PUD. I have included these revised cos t figures in my cost effectiveness analysis (see Attachment 11).

My conversation with the General Manager of the Wha tcom County PUD is documented in a memo to the project file and is included as Attachm ent 15.

5.3.3. Air Quality Operation of LSFO would increase particulate matter emissions by an estimated 200-300 tons per year due to solids in the mist droplets th at are not removed by the scrubber mist eliminators. The precise additional PM emissions w ill depend on the efficiency of the mist eliminators on the scrubber at removing entrained d roplets from the exhaust stream.

24 

### See Attachment 5. November 16, 18, and 22, 2011 phone conversations w ith Kyle Murphy, Cherry Point Aquatic Reserve staff contact – Washington State De partment of Natural Resources.

25 

### See Attachment 5. November 22, 2011 phone conversation with Randy Marshall, Washington State Department of Ecology.

26 

### See Attachment 2, page 5-22.

### 17

Operation of the scrubber would also increase emiss ions of greenhouse gases from the plant by an estimated 17,597 tons/year carbon dioxi de equivalent (CO 2 

### e), according to the Environ BART analysis.

5.3.4. Energy The project would require approximately 68,824,000 kW-hr of electricity per year, or 7.4 MW. This equates to an increase of about 1.6% from plant maximum power usage of 450 megawatts 27 

### (Herald, 2011).

5.3.5. Solid Waste The project is projected to produce approximately 2 7,130 tons of commercial grade gypsum annually, which would require disposal if no t re-used. As discussed above, I consider it reasonable to assume this commercial gr ade by-product would be reused.

27 

### 365 MW consumption at 80% capacity  ~450 MW at 100% capacity.

### 18

References

APTI, 1998. Scrubber Systems Operation Review Self Instructional Manual, Air Pollution Training Institute (APTI) Course SI:412C, Second Ed ition – Lesson 9: Flue Gas Desulfurization (Acid Gas Removal) Systems. Gerald T. Joseph, et al. Industrial Extension Se rvice, College of Engineering, North Carolina State University. 1998 . Developed under EPA Cooperative Agreement CT-902765.

DNR, 2010. Cherry Point Environmental Aquatic Reserve Manageme nt Plan. Washington Department of Natural Resources. November 2010. http://www.dnr.wa.gov/Publications/aqr_cp_mgmt_plan _2010.pdf

EPA, 2000. Srivistava Ravi K. Controlling SO 2 

### Emissions: A Review of Technologies . US Environmental Protection Agency, Office of Research and Development. EPA/600/R00/093.

EPA, 2002. EPA Air Pollution Control Cost Manual, Sixth Editio n. US Environmental Protection Agency, Office of Air Quality Planning a nd Standards. EPA/452/B-02-001. http://www.epa.gov/ttn/catc/dir1/c_allchs.pdf

EPA, 2003. Air Pollution Control Technology Fact Sheet: Flue G as Desulfurization – Wet, Spray-Dry and Dry Scrubbers . US Environmental Protection Agency, CICA. EPA-4 52/F-03- 034. http://www.epa.gov/ttn/catc/dir1/ffdg.pdf

EPRI, 2005. Flue Gas Desulfurization Systems: Component Materi al Performance & Welding

. Electric Power Research Institute (EPRI), December 2005.

Exponent, 2005. Ecological Risk Assessment for Use of Wet Scrubbers a t Alcoa Fjarðaál Aluminum Plant in Reyðarfjörður, Fjarðabyggð, Icela nd. Exponent. September 2005.

Herald, 2011. Stark, John. Intalco adding 60 jobs, restarting idled smelting c apacity. Bellingham Herald. January 8, 2011. http://www.bellinghamherald.com/2011/01/07/1804810/ alcoa-to-restart-intalco-2- other.html

Kaplan, 1990. Retrofit Costs of SO 2 

### and NO X 

### Control at 200 U.S. Coal-Fired Power Plants. Kaplan, et al. Presented at the 1990 Pittsburgh Co al Conference, September 11, 1990.

NCSU, 1998. Scrubber Systems Operation Review: Self Instructiona l Manual, APTI Course SI:412C, Second Edition. Gerald T. Joseph and David S. Beachler. Industri al Extension Service, College of Engineering, North Carolina Sta te University. 1998.

### 19

PSCAA, 2004. Air Operating Permit and Statement of Basis for Ash Grove Cement Company, Inc. – Seattle, WA. Puget Sound Clean Air Agency. Air Operating Perm it Issued May 15, 2004. Air Operating Permit http://www.pscleanair.org/announce/permits/issued/1 1339-faop.pdf Statement of Basis http://www.pscleanair.org/announce/permits/issued/1 1339-fsob.pdf

Sargent, 1996. Cost Study for a 1,400 MW Flue Gas Desulfurization Unit, Centralia Units 1 & 2 . Sargent & Lundy for Pacificorp. October, 1996.

Shreve’s, 1984. Shreve’s Chemical Process Industries, 5 th 

### Edition. George T. Austin. McGraw-Hill. 1984. ISBN 0-07-066167-7.

Vatavuk, 1990. Estimating Costs for Air Pollution Control . William M. Vatavuk. Lewis Publishers. 1990. ISBN 0-87371-142-4.

Warych, 2002. Optimum Values of Process Parameters of the 'Wet Li mestone Flue Gas Desulfurization System'. J. Warych and M. Szymanowski. Chemical Engineering & Technology, v. 25, 2002.

## BART DETERMINATION SUPPORT DOCUMENT FOR ALCOA INTALCO WORKS FERNDALE, WASHINGTON

Prepared by

Washington State Department of Ecology Air Quality Program

August 2009 Revised February 4, 2010

### TABLE OF CONTENTS

EXECUTIVE SUMMARY ........................................................................................................... iii

1. INTRODUCTION ................................................................................................................... 1

1.1 The BART Program and Analysis Process ...................................................................... 1

1.2 The Alcoa Intalco Plant .................................................................................................... 2

1.3 BART-Eligible Units at Intalco ........................................................................................ 2

1.3.1 Existing Potline Emissions Control .......................................................................... 3

1.3.2 Existing Anode Bake Furnace Emissions Control .................................................... 3

1.3.3 Existing Aluminum Holding Furnace Emissions Control ........................................ 4

1.3.4 Existing Controls for Material Handling and Transfer Operations, Other Natural Gas Combustion, and Other Small Miscellaneous Sources ...................................... 4

2. BART TECHNOLOGY ANALYSIS ..................................................................................... 4

2.1 Potline Control Options .................................................................................................... 4

2.1.1 SO 2 

### Control Options ................................................................................................. 4

2.1.2 PM Control Options .................................................................................................. 8

2.1.3 NO X 

### Control Options ................................................................................................ 9

2.1.4 Intalco’s BART Proposal for the Potlines ................................................................ 9

2.2 Anode Bake Furnace Control Options ........................................................................... 10

2.2.1 SO 2 

### Control Options ............................................................................................... 10

2.2.2 PM Control Options ................................................................................................ 10

2.2.3 NO X 

### Control Options .............................................................................................. 11

2.2.4 Intalco’s BART Proposal for the Anode Bake Furnace .......................................... 12

2.3 Aluminum Holding Furnaces ......................................................................................... 12

2.3.1 Aluminum Holding Furnaces Control Options ....................................................... 12

2.3.2 Intalco’s BART Proposal for the Aluminum Holding Furnaces ............................ 12

2.4 Material Handling and Transfer Operations ................................................................... 13

2.4.1 Material Handling and Transfer Operati ons and Other Miscel laneous Operations Control Options ....................................................................................................... 13

2.4.2 Intalco’s BART Proposal for the Materi al Handling and Transfer Operations ...... 13

3. VISIBILITY IMPACTS AN D DEGREE OF IMPROVEMENT ......................................... 13

4. ECOLOGY’S BART DETERMINATION ........................................................................... 14 Appendix A. Description of Available SO 2 

### Potline Control Options .......................................... 18 Appendix B. LSFO Scrubber Contro l Scenarios–Emissions and Impacts .................................. 22 Appendix C. Acronyms/Abbreviations ........................................................................................ 24

### EXECUTIVE SUMMARY

The Best Available Retrofit Technology (BART) progr am is part of the larger effort under the federal Clean Air Act Amendments of 1977 to elim inate human-caused visibility impairment in all mandatory federal Class I areas. Sources that are required to comply with the BART requirements are those sources that:

1. Fall within 26 specified i ndustrial source categories. 2. Commenced operation or completed permitting between August 7, 1962 and August 7, 1977. 3. Have the potential to emit more than 250 tons/y ear of one or more visibility impairing compounds. 4. Cause or contribute to visibility impairment within at least one mandatory federal Class I

area.

The Alcoa Intalco Works (Intalco) is a primary al uminum smelter facility utilizing the prebake process. The smelter is located on Cherry Po int near Ferndale, Washington. The aluminum smelting process produces emissions of particul ate matter (PM), fluorides, sulfur dioxide (SO 2 

### ), carbon monoxide (CO), nitrogen oxides (NO X 

### ), and hydrocarbons. The pollutants considered to be visibility impairing are PM, SO 2 

### , and NO X


### .
Aluminum smelters such as the Intalco facility are one of the 26 listed BART source categories. The Intalco plant was constructe d in 1965 and has the potential to emit more than 250 tons/year of PM and SO 2 

### . Most of the plant’s emission units are BART-eligible. Intalco’s major sources of visibility impairing pollutants are thr ee potlines and an an ode bake furnace.

Modeling of visibility impairment was done following the Oregon/Idaho/Washington/EPARegion 10 BART modeling protocol. 1 

### Modeled visibility impacts of baseline emissions show impacts on the 8 th 

### highest day in any year (the 98 th 

### percentile value) to be greater than 0.5 deciviews (dv) at seven Class 1 areas. Th e highest impact was 2.36 dv on Olympic National Park. Modeling showed that SO 2 

### emissions from the existing dry alumina/baghouse potline emission control system created 94 percent of the facility’s total visibility impact.

Intalco prepared a BART technical analys is using Washington State’s BART Guidance. 2



### The Washington State Department of Ecology (Eco logy) determined that the current level of emissions control is BART for the applicable units at the Alcoa Intalco Works primary aluminum smelter facility. The potlines and anode bake furnace are currently well controlled for particulate emissions. A wet scrubber on each source would be required to control SO 2 

### emissions. Modeling indicated that addition of a wet scrubbe r system on the potlines could reduce the visibility impact on Olympic National Park by over a deciview. However, the potline scrubber system’s estimated $7,500 cost per ton of SO 2 

### removed was determined to be excessive.

1 

### Modeling protocol available at http://www.deq.state.or.us/a q/haze/docs/bart protocol.pdf

. 2 

### “Best Available Retrofit Technology Determinations Unde r the Federal Regional Haze Rule,” Washington State Department of Ecology, June 12, 2007.

### iv Ecology also determined that the wet scrubber would have an excessive capital cost of $234.5 million and unacceptable impacts on solid waste ge neration, electrical power use, and water consumption. Ecology determined that a scrubb er on the anode bake furnace would have an excessive $36,400 cost per ton of SO 2 

### removed.

### March 3, 2009, Revised February 4, 2010

1. I NTRODUCTION

1. 1 The BART Program and Analysis Process

The federal Clean Air Act Amendments of 1977 (CAA) established a national goal of eliminating man-made visibility impairment in all mandatory federal Class I areas. The Act requires certain sources to utilize Best Av ailable Retrofit Technology (BART) to reduce visibility impairment as part of the overall plan to achieve that goal.

Requirements for the BART program and analysis process are given in 40 CFR 51, Subpart P and Appendix Y to Part 51. 3 

### Sources are “BART-eligible” if they:

1. Fall within 26 specified i ndustrial source categories. 2. Commenced operation or completed permitting between August 7, 1962 and August 7, 1977.
3. H ave the potential to emit more than 250 tons/y ear of one or more visibility impairing compounds including su lfur dioxide (SO 2 

### ), nitrogen oxides (NO X 

### ), particulate matter (PM), and volatile organic compounds (VOCs).

Emission units that meet the source category, age, and potential to emit criteria must also make the facility “cause or contribut e” to visibility impairment within at least one mandatory federal Class I area for a “BART-eligible facility” to be “subject to BART.” Ecology has adopted the “cause and contribute” criteria th at the United States Environmental Protection Agency (EPA) suggested in its guideline. BART -eligible units at a source cause visibility impairment if their modeled visibility impairment is at least 1.0 deciview (dv). Simila rly the criterion for contributing to impairment means that the source causes a modeled visibility change of 0.5 dv or

more.

The BART analysis protocol in Appendix Y to Pa rt 51, Sections III–V uses a 5-step analysis to determine BART for SO 2 

### , NO X 

### , and PM. The five steps are:

Step 1 – Identify all available retrofit contro l technologies. Step 2 – Eliminate technically in feasible control technologies. Step 3 – Evaluate the control effectiven ess of remaining control technologies. Step 4 – Evaluate impacts and document the results. Step 5 – Evaluate visibility impacts.

Ecology requires a facility that is “subject to BART” to prep are a BART technical analysis report and submit it to Ecology. Ecology then evaluates the report and makes a BART determination decision. This decision is then issued to the source ow ner as an enforceable Order, and included in the state’s Regiona l Haze State Implementation Plan (SIP).

3 

### Appendix Y to 40 CFR 51–Guidelines for BART Determinations Under the Regional Haze Rule.

### March 3, 2009, Revised February 4, 2010

As allowed by the EPA BART guidance, Ecology has chosen to consider all five factors in its BART determinations. To be selected as BART , a control has to be available, technically feasible, cost effective, provide a visibility be nefit, and have a minimal potential for adverse nonair quality impacts. Normally, the potential visibility improvement from a particular control technology is only one of the f actors weighed for determining whether a control constitutes BART. However, if two availabl e and feasible controls are e ssentially equivalent in cost effectiveness and non-air quality impacts, visibility improvement becomes the deciding factor for the determination of BART.

1.2 The Alcoa Intalco Plant

Alcoa Intalco Works (Intalco) is a primary alum inum smelter facility located in Ferndale, Washington, near Cherry Point along the Strait of Georgia. The facili ty produces primary aluminum metal by the Hall-Heroult reduction pro cess. It was original ly constructed in 1965, and began operation in 1966. Intalco is a Ti tle V source operating unde r Air Operating Permit No. 000295-0. Primary aluminum ore reduction plan ts are one of the 26 BART-eligible source categories. Intalco submitted a BART Determination Report to the Washington State Department of Ecology (Ecology) on December 4, 2007 as required by Order #5070.

1. 3 BART-Eligible Units at Intalco

A review of the Intalco emission sources found that:

1. All of the plant’s individual emission un its except for one remelt furnace are BARTeligible by construction date.
2. The individual emission units in total have a potential to emit greater than or equal to 250 tons/year of both sulfur dioxide (SO 2 

### ) and particulate matter (PM).
3. A baseline Class I area visibility impact analysis of 2003-2005 emissions using the CALPUFF model indicated impacts for the entire facility exceeded the 0.5 deciview (dv) contribution threshold in at least one Class I area. This confirmed that Intalco was subject to BART, and was required to prepare a BART Determination.

Intalco’s primary aluminum reduction operati ons include three potlines, an electrode manufacturing operation consisting of a past e production operation a nd a green anode baking furnace, and miscellaneous material handling oper ations. These units were placed into six
groups:

1. Potlines (3) 2. Anode bake furnace (1) 3. Aluminum holding furnaces (12) 4. Various material handling and transfer operations 5. Combustion sources (natural gas, diesel, propane) 6. Oth er small miscellaneous sources

### March 3, 2009, Revised February 4, 2010

1.3.1 Existing Potline Emissions Control

The potline operation manufactures metallic alumin um by the electrolytic reduction of alumina in the side-worked prebake cells. Direct elect rical current passes between the anodes and the carbon cathode that lines the cell walls. This current electroly tically reduces the alumina to metallic aluminum and oxygen. Molten aluminum is deposited and accumulates over time at the cathode beneath a layer of molte n cryolite bath. Periodically the molten aluminum is siphoned from beneath the cryolite bath and processed to ach ieve specific metal properties or is retained as pure aluminum. The produced aluminum is solidif ied into intermediate or final products. The major pollutants emitted from the cells are PM, hydrogen fluoride, SO 2 

### , and carbon monoxide. PM includes particul ate fluoride and alumina. SO 2 

### comes from the sulfur in the petroleum coke and pitch components used to make the anodes that are cons umed by the process. NO X 

### emissions are minimal since there is no extern al fuel or combustion zone and there are no large sources of nitrogen in the raw materials.

The potlines at Intalco consist of six potroom gr oups of electrolytic reduction cells connected in series that produce molten aluminum. There are two potroom groups per potline. Each potroom is comprised of 120 reduction cells (or pots) with 18 anodes per cell. All pots at Intalco are hooded to control emissions. Emissions capture d by the hoods are drawn through one of six primary control systems. Each primary control sy stem consists of a dry alumina injection system followed by a baghouse for the control of PM and fluoride emissions. The six primary control systems are located in the courtyards between th e potrooms. The system at Intalco is large, treating approximately 1,815,000 acfm of 180°F exhaust gases. This primary PM control system has an efficiency of about 97.7 percent.

A small fraction of the pot emissions escape capt ure by the hoods and are released inside the potrooms. These secondary emissions are dr awn through a secondary control system which consists of a series of 159 wet roof scrubbers that control PM and fluoride emissions. PM control efficiency for this secondary system is approximately 82 percent.

1.3.2 Existing Anode Bake Furnace Emissions Control

Anodes are manufactured in an an cillary on-site anode plant. Pu rchased calcined petroleum coke and anode butt material is crushed and sized, mixe d together with pitch, and formed into blocks called “green anodes.” The green anodes are then cooled prior to being baked in the anode bake furnace. Only after the anodes have been ba ked can they be used in the potlines.

The anode bake furnace structure is a series of interconnected refractory flues connected to side main exhaust manifolds. The furnace is fueled with natural gas. Exhaust gases are routed so that flue gases preheat the next sec tion of the furnace to be fired. Flue gases from the anode bake furnace contain PM, hydrogen fluoride, SO 2 

### , NO X 

### , carbon monoxide, and hydrocarbons.

The bake furnace emissions are controlled by an alumina dry scrubber which is similar to the ones used for the potline primary control system. The bake oven gas stream is cooled by a water

### March 3, 2009, Revised February 4, 2010

spray to reduce the inlet temperature before it en ters the scrubber. Fresh and recycled alumina are injected into the gas stream, gaseous fl uoride and polycyclic organic matter (POM) are adsorbed onto the alumina surface, and fabric f ilters on top of the reactor compartments collect entrained particulate matter present in the gas stream. The control system for the anode bake furnace treats approximately 216,000 acfm of 205°F e xhaust gases. The fabric filters reduce PM emissions by as much as 99 percent.

1.3.3 Existing Aluminum Holding Furnace Emissions Control

The 12 holding furnaces at Intalco vary in size. They are heated by natural gas burners. The largest of these furnaces has a natural gas rate d burner rated at 22 MMBtu/hr. There are no emission controls associated with the aluminum furnaces at Intalco. Emissions come from combustion of natural gas in the burners and the activities associated with treating molten metal while being processed in the furnaces.

1. 3.4 Existing Controls for Material Handling and Transfer Operations, Other Natural Gas Combustion, and Oth er Small Miscellaneous Sources

The remaining emission units are various material handling and transfer op erations, natural gas, diesel, and propane combustion, and other small mi scellaneous sources that support the potlines, anode bake furnace and holding furnace operations. Aside from the natural gas combustion products, emissions from most of the support operations consist of relatively small amounts of PM that are controlled by fabric filter-type control devices. Fa bric filters effectively remove about 99 percent of particulate emissions.

Natural gas consumption is mostly in the previo usly discussed anode bake furnace and aluminum holding furnaces. The balance comes from burners in the paste plant. Propane is used in forklifts. There are five sma ll auxiliary diesel generators.

2. B ART TECHNOLOGY ANALYSIS

The Intalco BART technology analysis was base d on the 5-step process defined in BART guidance and listed in Section 1.1 of this report. In talco’s analysis included a review of available and technically feasible retrofit technologies (Steps 1 and 2), dete rmination of control effectiveness for feasible options (Step 3), evalua tion of cost and secondar y impacts for feasible alternatives (Step 4), and analysis of impacts and visibility impr ovements (Step 5). The analysis looked at controls for SO 2 

### , PM, and NO X 

### from each category of emission units: the potlines, anode bake furnace, aluminum holding furnaces, handling and transfer operations, combustion sources, and other small sources.

2.1 Po tline Control Options

2 .1.1 SO 2 

### Control Options

### March 3, 2009, Revised February 4, 2010

Alcoa evaluated eight different SO 2 

### add-on control options along with pollution prevention as having potential application for potline SO 2 

### emission control. Six of the control options use wet scrubbing and two use dry scrubbing technology. A description of each technology is found in Appendix A.

Wet Scrubbing Technologies

• Limestone slurry scrubbing with forced oxidation (LSFO)

• Limestone slurry scrubbing with natural oxidation (LSNO)

• Conventional lime wet scrubbing

• Seawater scrubbing

• Dual alkali sodium/lime scrubbing (dilute mode)

• Conventional sodium scrubbing

Dry Scrubbing Technologies

• Dry sorbent injection

• Semi-dry scrubbing (spray dryer)

Limestone Slurry Forced Oxidation (LSFO) was de termined to be a technically feasible wet scrubbing retrofit control option for the potroom r eactors even though it is not ideally suited for scrubbing SO 2 

### concentrations that are less than or equal to 105 ppm. LSFO was also selected to be the best choice of the we t scrubbing technologies.

Dry sorbent injection downstream of the potline react or fabric filters is not technically feasible because of the low temperatures (less than or equal to 205°F) and low SO 2 

### concentrations (less than or equal to 105 ppm). Spray dry scrubbing do wnstream of the potline r eactors fabric filters is not technically feasible because of the low te mperatures (less than or equal to 205°F) and low SO 2 

### concentrations (less than or equal to 105 ppm).

Pollution Prevention

The guidelines for BART determinations under the Regional Haze Rule recommend consideration of pollution preven tion options in addition to add-on controls. The primary opportunity for pollution prevention in the smelting process to minimize SO 2 

### emissions is through controlling the sulfur cont ent in the incoming petroleum coke used to make the anodes.

Intalco’s Title V operating permit currently has a nu mber of operational limits that cap allowable emissions of SO 2 

### from the facility, including a net potline aluminum production limit of 307,000 tons/year; a daily potline SO 2 

### limit of 37,780 lb/day; limits on sulfur in coke and pitch at 3.0 percent and 0.6 percent, resp ectively; and a carbon consumption limit of 0.425 pounds of carbon per pound of aluminum produced.

The current levels of sulfur in petroleum coke used by other aluminum smelters was evaluated to determine whether a pollution prevention option us ing lower sulfur content coke would be a

### March 3, 2009, Revised February 4, 2010

feasible BART option for Intalco. This analysis indicated that some smelters currently utilize coke with sulfur contents as low as two percent. An analysis wa s also done to determine whether coke with sulfur levels below three percent can be anticipated to be available into the future. The primary conclusions from this analysis indicate that:

• There will be a continuing increase in the su lfur content of available coke. Low sulfur crude oil supplies are becoming less availa ble and more expensive for petroleum refineries. In the future, refineries with coking capacity are expected to minimize their raw material costs by using more of the higher sulfur crude oils and oil sands that are less costly.

• As oil fields age, the sulfur content of the crude oil is known to increase and the crude oil in the fields becomes more viscous and harder to extract. This effect is expected to increase the sulfur content of the petroleu m materials available to produce anode grade coke.

• Coke is a relatively small, low revenue compone nt of a refinery’s pr oduct profile. It is a low value product made from the thick, tar-like refinery wastes left over after all of the more valuable components have been removed from the petroleum crude. The aluminum industry has little influence in controlling th e quantity, quality, and price of the coke produced by refineries.

• Global primary aluminum production is expect ed to grow, resulting in a commensurate growth in demand for anode grade coke. Gr owth in aluminum production will continue to outpace the growth in coke production.

• Coke providers are blending imported, high cost , lower sulfur coke with domestically sourced coke in attempts to meet the curre nt specification requirements for coke.

• Remo val or reduction of the sulfur content of the coke once it has been received is not feasible.

Feasible SO 2 

### Control Options from RBLC Database

The data in the USEPA’s RACT/BACT/LAER ( RBLC) database supports the approach of limiting raw material sulfur content as a control option for the potlines and the anode bake furnace. Many facilities have limited sulfur content in coke to limit SO 2 

### emissions. Two facilities have limits of three pe rcent sulfur content in coke and one has a 2.95 percent sulfur content limit. One facility is shown in th e RBLC to have a wet scrubber to control SO 2 

### emissions; 4 

### however, an investigation revealed that th e wet scrubber was not required as part of a best available control technology (BACT) determination and that the facility cu rrently does not operate a wet scrubber to control SO 2 

### emissions. That facility’s current Title V permit for “Potline 5” limits coke sulfur content to three pe rcent, coal tar pitch sulfur to 0.8 percent, potline SO 2 

### emissions to 364.52 lb/hr from the primary emi ssions control unit, 7.44 lb/hr from the roof

4 

### RBLC ID ky-0070 for NSA–A division of Southwire Company on Potline 5 now Century Aluminum of Kentucky, LLC, Kentucky Title V Permit #V-01-019.

### March 3, 2009, Revised February 4, 2010

scrubbers, and 49.356 lb/ton of aluminum produced. Alcoa Intalco has a current limit of 44.8 lb SO 2 

### emitted per ton of aluminum produced.

Cost and Other Impacts of Feasible SO 2 

### Potline Controls

Wet scrubber costs for Intalco were estimated ba sed on cost quotes received by Alcoa from two flue gas desulphurization equipment vendors. The cost quotes were originally provided as part of the BART analysis for Alcoa’s Tennessee Oper ations in Alcoa, TN. Both vendors provided cost proposals for wet scrubbing systems based on LSFO scrubbers. Lime or sodium based scrubbers could also be used for potlines, but lime and sodium are less desirable reagents considering that these reagents are much more e xpensive. An advantage of the limestone forced oxidation process is that the spen t slurry is oxidized to gypsum, which dewaters more efficiently, resulting in less waste materials requiring disposal. An LFSO sc rubber was determined to be the most appropriate control devi ce for the cost analysis.

Neither of the two vendors provided a comprehensiv e installed cost estimate. Both preliminary designs were based on a central scrubbing center as the least cost approa ch, where exhaust from all dry scrubbing systems would be ducted to a centralized scrubbing system. Both design estimates were based on systems that would prov ide 100 percent availability of emissions control on each day of the year, given that potlines canno t be easily shutdown and restarted for control system outages. To achieve this 100 percent availability, the proposed designs includes two scrubber towers, one to be active, an d one to be held in reserve.

The capital and total an nualized costs for a potline wet scrubber system as proposed was $234.5 million and 46.8 million per year, respectively. The wet scrubber cost effectiveness was $7,500 per ton of SO 2 

### removed. A lower cost option base d on a single absorber tower based on information supplied by Intalco was analyzed by Ecology. A discussion of this option is included in Section 4 , Ecology’s BART determination.

The LSFO scrubber process oxidizes the spent slurry to gypsum sludge. The sludge volume would be 27,130 tons annually from the potline wet scrubber. It was not known at the time of the BART report preparation whether the gypsum would have commercial value or whether there would be any demand for it. If not sold, the sludges must be land filled.

It is estimated that 182.5 million gallons of water will be required annually to operate the potline wet scrubber at a cost of approximately $97,000. This would increase Intalco’s daily water demand by approximately nine percent.

A total of approximately 64.8 million kWh would be needed to operate the potline scrubber annually. This is equivalent to adding over 6,000 new households to the community. 5 

### Table B-2 in Appendix B summarizes the impacts analysis.

5 

### Calculated based on 2001 average energy usage per hou sehold for the U.S. as reported by the Department of

Energy. See http://www.eia.doe.gov/emeu/reps/enduse/er01_us_tab1.html

.

### March 3, 2009, Revised February 4, 2010

Cost of anode grade coke is predicted to conti nue to rise in the future, as discussed in the previous pollution prevention section. Both increasing demand by the aluminum industry and the need of refineries to move toward using higher sulfur containing crude oil stocks drive Intalco’s prediction. US Gulf calcined a node grade coke increased from $118.50/mt to $244.75/mt between 1994 and 2006. The future rate of cost increase is anticip ated to be greater due to the reasons discussed in the pollution pr evention section.

2.1.2 PM Control Options

Fabric Filters

Fabric filters generally provide high collection efficiencies for bot h coarse and fine (submicron) particles. They are relatively in sensitive to fluctuations in gas stream conditions. Efficiency is relatively unaffected by large changes in inlet dust loadings. Filter out let air is very clean. 6 

### Collected material is dry, which usually simplifie s processing or disposal . Fabric filters are currently applied for controlling PM em issions from the potrooms at Intalco.

Electrostatic Precipitators

Electrostatic Precipitators (ESPs) are capable of very high removal efficiencies for large and small particles. 7 

### They offer control efficiencies that are comparable to fabric filters. Because of their modular design, ESPs, like fabric filters, can be applied to a wide range of system sizes. The operating parameters that influence ESP performance include particulate mass loading, particle size distribution, particul ate electrical resistivity, space ve locity, and precipitator voltage and current.

Dusts with high resistivities are not well-suited for collection in dry ESPs because the particles are not easily charged. An ESP is technically feasible for contro l of PM from the potrooms at Intalco.

Fabric filtration with dry alumina scrubbing has been widely used in the primary aluminum industry. Most smelters constructed within th e past 20 years have used dry alumina scrubbing (either alumina injection or fluidi zed bed) with fabric filters to control particulate and fluoride emissions from potlines. A few plants use control systems consisting of ESPs to collect PM followed by spray towers to scrub gaseous fluor ide. Wet systems have many disadvantages, such as corrosion by hydrofluoric acid, scaling, and acidic wastew ater. ESPs and wet systems are no longer installed on new smelters in the U.S.

6 

### EPA 2003, “Air Pollution Control Technology Fact Sheet–Fabric Filter,” EPA-452 /F-03-025, August 7.

7 

### EPA 2003, “Air Pollution Control Technology Fact Sheet–Dry Electrostatic Precipitator,” EPA-452/F-03-028,

August 7.

### March 3, 2009, Revised February 4, 2010

Cyclones, Inertial Separators, and Wet Scrubbers

Cyclones and inertial separators are used for coll ection of medium-sized and coarse particles. Wet scrubbers generally remove large particles a nd can remove small particles with the use of high-pressure drops. However, none of these de vices are as effective at removing small and submicron particles as fabric filters and ESPs. 8



### Cost and Other Impacts of Feasible Particulate Potline Controls

Fabric filters are currently used on Intalco’s po tlines. Since fabric f ilters have high control effectiveness similar to ESPs, are widely used for potline particulate c ontrol in the aluminum industry, and have process advantag es relative to ESPs, no benefit wa s seen to switch from fabric filters to ESPs for PM control. Because no benefit was seen, no cost analysis of switching to an ESP-based particulate control was done.

2.1.3 NO X 

### Control Options

Potentially applicable NO X 

### emission controls include combus tion controls and post-combustion controls. The pots are heat ed solely through the action of the elec tric reduction process. There is no combustion of fuel. There are also no large s ources of nitrogen in the raw materials. This makes use of traditional combustion cont rols like staged combustion or low NO X 

### burners not applicable to the potlines. The temperature of the potroom exhaust is approximately 180°F and the NO X 

### concentration is less than one parts per million (ppm).

Possible post combustion controls include Se lective Non-Catalytic Reduction (SNCR) and Selective Catalytic Redu ction (SCR). Both involve injec ting ammonia or urea into the gas stream to react with NO X 

### to produce nitrogen and wate r. SNCR requires an operating temperature of 1,600°F to 2,100°F and inlet NO X 

### concentrations typically from 200 to 400 ppm to be about 30-50 percent effec tive. SCR uses a catalyst to reduce the operating temperature requirement to between 500°F to 800°F, and can achieve up to 90 percent reduction of inlet NO X 

### concentrations to as low as 20 ppm.

Since there is no external fuel or combustion zo ne in the smelting cells, there are no technically feasible pre-combustion NO X 

### controls. Low temperature and NO X 

### concentration make both SNCR and SCR post process NO X 

### controls technically infeasible.

2.1 .4 Intalco’s BART Propos al for the Potlines

For potline SO 2 

### emissions, Intalco proposed BART to be the current level of control, which includes a maximum of three percent sulfur in th e coke used to manufacture anodes. Use of wet scrubbing technology to reduce potline SO 2 

### emissions was rejected as BART due to excessive costs: total cost effec tiveness of $7,500 per ton of SO 2 

### removed and capital and total annualized

8 

### AWMA 2000, “Air Pollution Engineering Manual,” Second Edition.

### March 3, 2009, Revised February 4, 2010

costs of $234.5 million. A potline wet scrubber w ould also have substantial non air quality impacts, including increased energy usage, added water consumption, and solid waste generation.

For PM emissions, Intalco proposed BART to be the current level of control, which is the use of baghouses to control PM emissions from the alum ina dry scrubbers, and wet roof scrubbers to control secondary PM emissions from the potroom roofs.

For NO X 

### emissions, Intalco proposed BART to be no controls.

2.2 An ode Bake Furnace Control Options

The anode bake furnace process is discussed in Section 1.3.2 of this report. Emissions due to anode coke and pitch are similar to those from the potlines, so the same BART control options considered for the potlines are applicable to the bake furnace emissions exhaust. It is smaller, with only about 12 percent of the airflow volume of the combined potlines emission scrubber. It is natural gas fired rather than electrically h eated, so it has products of combustion including NO X


### .

2.2.1 SO 2 

### Control Options

A wet scrubber was identified as a technically feasible add-on pollution control option for the anode bake furnace. The anode bake furnace is a smaller source than the potlines and has a lower exhaust gas flow rate. A separate vendo r cost proposal was not obtained for the anode bake furnace, but an SO 2 

### removal efficiency of 95 percent is assumed to be feasible. Wet scrubber costs for the anode bake furnace were scaled from the LSFO potline wet scrubber vendor quotes.

The estimated installed capital cost to add a wet scrubber to remove 95 percent of the SO 2 

### from the anode bake furnace exhaust would be approxi mately $29.5 million with an annualized cost of $6.3 million per year. The wet scrubber co st effectiveness is $36,400 per ton of SO 2 

### removed. The wet scrubber also has an energy impact of 6,570,000 kW-hr/yr as well as solid waste impacts associated with dispos al of gypsum sludge from the scrubber and water use impacts from scrubber operation. The impacts are summarized in Table B-2 of Appendix B.

The pollution prevention option of reducing the sulf ur content of the anode coke is available for the anode bake oven as well as the potlines. See the potline pollution prevention discussion in Section 2.1.1

.

2.2.2 PM Control Options

Dry alumina injection with fabric filtration is currently used for PM control on the anode bake furnace. An ESP is also a technically feasible co ntrol, with a similar fine particulate PM capture

### March 3, 2009, Revised February 4, 2010

efficiency. As described in Section 2.1.2 , cyclones, inertial separato rs, and wet scrubbers are not as effective at removing small and submicr on particles as fabric filters and ESPs.

2.2.3 NO X 

### Control Options

Advanced firing system: NO X 

### emissions from anode baking depend on operating practices and burner controls. The traditional methods of preventing NO X 

### formation using staged combustion or low NO X 

### burners are not applicable because of th e unique configuration of an anode baking ring furnace, with fuel injected at several poin ts in narrow flues. However, advanced firing systems that measure and regulate fuel flow preci sely using a computerized control system can reduce total fuel usage. This will also reduce NO X 

### emissions. Prevention of NO X 

### formation using a more efficient advanced firing control system is technically feasib le for the anode bake furnace at Intalco. Total gas usage is projected to be reduced by 20 percent, which would result in a corresponding 20 percent reduction in NO X 

### emissions, or approximately 27 tons/year.

The LoTO X 

### TM system is the patented technology of BOC Gases. In this NO X 

### removal system, ozone is injected into the exhaust gas stream in order to oxidize insoluble NO X 

### to soluble nitrogen compounds, including N 2 

### O 5 

### . N 2 

### O 5 

### is highly soluble and reacts with moisture in the gas stream to form nitric acid. A scrubber is re quired downstream of the LoTOxTM system to remove the nitric acid formed by the reaction of N 2 

### O 5 

### and moisture in the gas stream. The ozone is typically generated on site and on demand. Sin ce LoTOxTM is a low temperature system, it does not require heat input and the low operating temperature ( 150 to 250°F) allows for stable and consistent control even with va riations in flow, load, and NO X 

### concentrations. 9



### Use of the LoTOxTM system has not been demonstrated at an aluminum plant. Research indicates that application of the LoTOxTM tec hnology has been limited to a sulfuric acid regeneration plant, a lead smelting reverbatory furnace, a stainless steel plant, a coal-fired electric generation unit, and tw o fluidized-bed catalytic cracking units (FCCU) at refineries. 10 11 

### Reported NO X 

### removal efficiencies for the LoTOxTM syst em are on the order of 90 to 95 percent.

The temperature of the anode baking emission exhaust (approximately 200°F) is within the temperature range where LoTOxTM could be us ed. Although this technology has not been demonstrated on an anode bake furnace, low-temperature oxidation technology may be technically feasible for reducing anode bake furnace NO X 

### emissions. At a control efficiency of 90 percent for NO X 

### emissions when combined with we t scrubbing, the resulting reduction in NO X 

### emissions would be 122 tons/year.

Intalco made the case that cost data for the LoTOx TM 

### system was not readily available. To show some cost estimation, Intalco noted that the LoTOx TM 

### system would also require a scrubber

9 

### BOC Process Gas Solutions, 2001, Lo w Temperature Oxidation System Demonstration at RSR Quemetco, Inc.,

City of Industry, California, June 28. See www.arb.ca.gov/research/i cat/projects/boc.pdf

. 10 

### EPA, February 2005, “Using Non-Thermal Plasma to Control Air Pollutants,” EPA-456/R-05-001. See

www.epa.gov/ttn/catc/dir1/fnonthrm.pdf.

11 

### EPA RACT/BACT/LAER Clearin ghouse (RBLC) database.

### March 3, 2009, Revised February 4, 2010

similar to the one de scribed earlier for SO 2 

### control. That would make the cost of the entire LoTOx TM 

### system installation more than the previously estimated SO 2 

### scrubber cost of $29.5 million. NO X 

### emissions are lower than SO 2 

### emissions for the anode bake furnace, so the cost per ton values for NO X 

### would be higher than the $36,400 estimated for SO 2 

### . Since cost for the LoTOx TM 

### system itself was not available, it is not po ssible to calculate a cost per ton for the total system based on both NO X 

### and SO 2 

### . To give a sense of the possible minimum cost, if the LoTOx TM 

### system were free, the cost would be gr eater than $18,000 per ton of total pollutants removed.

2.2 .4 Intalco’s BART Proposal fo r the Anode Bake Furnace

Intalco proposed that the existing potline SO 2 

### control pollution prevention limit of three percent sulfur in the coke to be BART for anode bake furnace SO 2 

### emissions. The cost effectiveness of wet scrubbing to reduce SO 2 

### emissions was determined to be excessive at $36,400 per ton of SO 2 

### removed. As discussed below in Section 3, additi on of a wet scrubber to the anode bake furnace would reduce the visibility impact on Olympic National Park by only 0.024 dv.

The existing level of control (based on baghous es on the alumina dry scrubbers) was proposed to be BART for PM emissions.

BART for anode bake furnace NO X 

### emissions was proposed to be no additional controls. The use of an advanced firing system for reduced energy use was rejected as BART because the 20 percent reduction in NO X 

### emissions would result in a negligible 27 ton per year NO X 

### reduction and visibility improvement. Em issions of all pollutants (SO 2 

### and NO X 

### ) from the anode bake furnace are responsible for only about one percent of the visibility impact on Olympic National Park; the most impacted Class I Area (s ee Section 3 below). The use of LoTOx TM 

### was rejected as BART because the technology is not availabl e or demonstrated in practice for aluminum anode bake furnace exhausts.

2.3 Al uminum Holding Furnaces

2.3.1 Aluminum Holding Furnaces Control Options

The 12 holding furnaces at Intalco ar e heated by natural gas burners, and vary in size, with the largest of these furnaces having a natural gas ra ted burner capacity of 22 MMBtu/hr. Emissions come from combustion of natural gas in the burn ers. There is currently no emission controls associated with the aluminum furnaces at Intalco.

2.3 .2 Intalco’s BART Proposal for th e Aluminum Holding Furnaces

Intalco proposed that BART fo r the aluminum holding furnaces was no controls. The proposal rejected additional controls as BART because the modeling analysis discussed in Section 3 below showed that any visibility improvement w ould be negligible because the existing burners have a negligible contribution to visibility impacts.

### March 3, 2009, Revised February 4, 2010

2.4 Ma terial Handling and Transfer Operations

2.4.1 Material Handling and Transfer Operations and Other Miscellaneous Operations Control Options

The remaining emission units are various material handling and transfer op erations, natural gas, diesel, and propane combustion, and other small miscellaneous sources that support the potlines and anode bake furnace. Aside from emissions from natural gas combustion, emissions from most of the support operations consist of relativ ely small amounts of PM that are controlled by fabric filter control devices.

2. 4.2 Intalco’s BART Proposal for th e Material Handling and Transfer Operations

Intalco showed that PM emissions from the BART-eligible material handling and transfer operations were all controlled us ing fabric filter technology. Th is existing level of emissions control was proposed to be BART for these material handling and transfer operations.

3. VISIBILITY IMPACTS AND DEGREE OF IMPROVEMENT

A baseline Class I area vi sibility impact analysis was performed on the BART-eligible emission units at Intalco usi ng the CALPUFF model with four kilometer grid spacing as recommended by the Oregon/Idaho/Washington/EP A-Region 10 BART modeling protocol. The modeled or projected 98 th 

### percentile visibility impacts fo r the entire facility exceed the 0.5 deciview (dv) contribution threshold in se ven Class I areas as shown in Table 3-1.

Table 3-1. BASELINE VISIBIITY MODELING RESULTS

Class I Area 2003 2004 2005

Modeled

98 th
Percentile (deciview) Number of Days Exceeding

0.5 dv Modeled 98 th
Percentile (deciview) Number of Days Exceeding

0.5 dv Modeled 98 th
Percentile (deciview) Number of Days Exceeding

0.5 dv
Alpine Lakes Wilderness Area 1.244 36 0.965 37 0.881 23

Goat Rocks Wilderness Area 0.500 8 0.579 10 0.317 3

Glacier Peak Wilderness Area 1.161 37 1.156 38 0.736 23

Mount Adams Wilderness Area 0.456 7 0.472 6 0.357 2

Mount Rainier National Park 0.843 22 1.052 26 0.629 15

North Cascades National Park 1.376 65 1.395 56 1.138 32
Olympic National Park 2.363 59 1.858 53 2.136 45
Pasayten Wilderness Area 0.866 30 0.871 33 0.659 13



### Intalco’s modeling consultant evaluated the eff ects of the different emission sources at the Intalco facility to determine which operations resu lted in the greatest visibility impacts. This

### March 3, 2009, Revised February 4, 2010

analysis indicated that the potli nes are responsible for 98 percent of the visibility impact on the most impacted Class I area, and 96 percent of that impact is from the SO 2 

### emissions. Of the remaining two percent of the visibility impact, th e anode bake furnace is the next largest source at about one percent of the impact. The other so urces in total are the sources of the remaining one percent of the impact.

An evaluation of the potent ial improvement in visibility that would result from application of feasible pollution preventi on/add-on control options was done. CALPUFF modeling was performed for two control scenarios: one with wet SO 2 

### scrubbing applied to the potline and one with wet SO 2 

### scrubbing applied to the anode bake furnace. In general, this modeling was the same as the baseline modeling except stack da ta and emission data associated with the application of the feasib le add-on controls were used as mo del inputs. Emission information for both baseline and control scenario modeling is found in Appendix B.

The addition of a potline wet scr ubber reduced modeled visibility im pacts in all Class I areas. For example, the baseline modeling re sults indicate that the highest 98 th 

### percentile visibility impact from Intalco’s BART-eligible sources at Olympic National Park estimated that wet scrubbers installed on the potlines would provide up to 1.172 dv of visibility improvement. The modeled visibility improvements from adding a wet scrubber at the anode bake furnace only are much smaller. The post-control modeling results for the anode bake furnace indicate visibility might be improved by up to 0.024 dv at Olympic National Park.

4. ECOLOGY’S BART DETERMINATION

Ecology’s BART determination for Intalco is given in Table 4-1. A more detailed description of each decision follows.

Table 4-1. BART DETERMINATION FOR INTALCO

Pollutant BART Determination Potlines

SO 2 

### Use of the current level of control, wh ich is a pollution prevention limit of 3% sulfur in the coke used to manufacture anodes.

PM Use of the current level of control, wh ich is the use of baghouses to control PM emissions from the alumina dry scrubbers, and wet roof scrubbers to control secondary PM emissions from the potroom roofs. NO X 

### No control Anode Bake Furnace

SO 2 

### Use of the current level of control, wh ich is a pollution prevention limit of 3% sulfur in the coke used to manufacture anodes.
PM Use of the current level of cont rol, which is the use of a baghouse.
NO X 

### No control Aluminum Holding Furnaces
SO 2 

### No control

### March 3, 2009, Revised February 4, 2010

Pollutant BART Determination
PM No control
NO X 

### No control Material Handling and Transfer Operations
SO 2 

### No control
PM Use of the current level of control, which is use of fabric filters.
NO X 

### No control

Aluminum Potlines

Ecology determined that for SO 2 

### emissions from the potlines, BART is the current level of control, which is a pollution prevention limit of three percent sulfur in the coke used to manufacture anodes.

Ecology agrees with Intalco that a pollution prevention limit based on coke sulfur content below three percent is infeasible as BART based on an ev aluation of the future av ailability of petroleum coke with lower sulfur content.

Ecology rejected the use of wet scrubbing technology as BART to reduce potline SO 2 

### emissions because of its excessive costs. Ecology has evaluated the cost estimate provided by Alcoa for this plant including adjusting Alcoa’s cost es timates for various items like operational and maintenance labor. For the proposed two absorp tion tower design, our revised annualized cost was $6,574 per ton of SO 2 

### removed. The capital and total an nualized costs were estimated to be $208.5 million and $40.9 million per year, respectively.

A single absorption tower design option was included in one of the two original Tennessee plant scrubber system proposals (by Babcock), but no t evaluated by Intalc o’s within its BART proposal for Intalco This design would cost le ss, principally by eliminating the second, backup scrubber tower. With the single absorber tower configuration, if the scrubber tower needed to be taken down for maintenance, the primary contro l system emissions would need to bypass the absorber tower while maintenance occurs, result ing in SO2 emissions identical to the current rates during the bypassing. Unlik e an electrical power plan t where routine and planned shutdowns occur during which maintenance can be carried out, an aluminum smelter does not normally stop operating once it has started. Ba bcock estimated that the single tower design reduced the Total Capital Investment Costs (TCI C) by 28.1 percent, or to 71.9 percent of their two scrubber system proposal. Ecology scaled this cost reduction to the Intalco cost estimate, and included additional cost reductions in annua l operating labor and maintenance labor as much as practical. The resultin g capital and total annualized costs were $185.1 million and $38.7 million respectively. This gave a cost effectiveness of $6,145 per ton of SO 2 

### removed assuming an identical SO 2 

### removal rate. Any direct venting of the emission gasses during maintenance of the absorber tower would lower the SO 2 

### tons removed and increase this dollars/ton cost effectiveness estimate. Ecology finds the single absorber option to not be cost effective.

### March 3, 2009, Revised February 4, 2010

Any potline wet scrubber system would also have substantial energy and non air quality impacts, including electricity, water, and waste disposal . Specifically for the limestone control option, Intalco has estimated that there would be an increased energy usage of 64,824,000 kWh of electricity per year, added water consumpti on of 183 million gallons per year, a need to discharge wastewater from the sc rubber system, and solid waste ge neration of 27,000 tons/year.

In response to comments by Ecology on the wet scrubber option, Intalco identified additional impediments to utilizing a wet scrubbing system . The most important for implementing a wet scrubbing system is that they currently purchas e potable water for indus trial purposes and have turned over water rights previously i ssued to Intalco to the water district. The result of this water transfer is the plant would have difficulty in acquiring water rights for this consumptive industrial purpose.

Based on the cost effectiveness and the non ai r quality impacts of a wet scrubbing system, Ecology determined BART for SO 2 

### is the current level of emissions control.

Ecology determined that for PM emissions from the potlines, BART is the current level of control, which is the use of baghouses to contro l PM emissions from the alumina dry scrubbers, and wet roof scrubbers to control secondary PM emissions from the potroom roofs.

Ecology determined that there are no feas ible technologies for the control of NO X 

### from the potlines. BART for NO X 

### is determined to be no controls.

Anode Bake Furnace

Ecology determined that the petroleum coke sulf ur limit accepted as BART for the potlines is also BART for anode bake furnace SO 2 

### emissions. The cost of wet scrubbing to reduce SO 2 

### emissions would be excessive at $36,400 per ton of SO 2 

### removed while providing minimal visibility improvement.

Ecology determined that the existing level of control (based on baghouses on the alumina dry scrubbers) is BART for PM emissions.

Ecology determined that BART for anode bake furnace NO X 

### emissions is no controls. The use of an advanced firing system for reduced en ergy use was rejected as BART because the technology would result in a negligible emissi on reduction and visibility improvement. Similarly, the use of LoTOx TM 

### was rejected as BART because the cost of the technology would be excessive and it has not been demonstrated in practice on aluminum plant anode bake furnaces.

Aluminum Holding Furnaces

### March 3, 2009, Revised February 4, 2010

Ecology determined that BART for the aluminum holding furnaces is no controls. The use of additional controls was reject ed as BART because any visibility improvement would be negligible due to the low level of emissions from the natural gas-fired burners.

Material Handling and Transfer Operations

Ecology determined that since PM emissions fr om the BART-eligible material handling and transfer operations are all cont rolled using fabric filter technolo gy, the existing level of emissions control is BART for these material handling and transfer operations.

Ecology determined that BART for NO X 

### and SO 2 

### emissions from material handling and transfer operations is no controls. Materi al handling and transfer operati ons are a negligible source of NO X 

### and SO 2 

### emissions. Additional control of these pollutants would provide negligible visibility improvement.

### March 3, 2009, Revised February 4, 2010

APPENDIX A

DESCRIPTION OF AVAILABLE SO 2 

### POTLINE CONTROL OPTIONS

Technology Description

Limestone Slurry Forced Oxidation (LSFO) Limestone slurry forced oxidation (L SFO) is used extensively in the utility flue gas desulphurization (FGD ) market. It has not been used on an aluminum smelter. The raw mate rial is finely ground limestone. The most commonly used equipment is an open, multi-level, countercurrent spray tower scrubber equipped with spra y nozzles to inject the limestone slurry droplets into the gas stream. Liquor is collected at the bottom of the tower and sparged with air to oxi dize the calcium sulfite to calcium sulfate to enhance the settling prope rties of the calcium sulfate. Recirculation pumps circulate the sc rubbing liquor to the spray nozzles. SO 2 

### removal efficiencies of 90% have been achieved. The bleed from the scrubber is sent to a dewatering system to remove excess moisture. For an aluminum smelter, the process will produce either solid gypsum waste or commercial-grade gypsum suitable for reuse as a cement additive if a cement production facility is available and willing to accept the material. Only a very small purge or blowdown stream is required.

Limestone Slurry Natural Oxidation (LSNO) Limestone slurry natural oxidation (LSNO) is very similar to LSFO. The major difference is the absence of an oxidation stage. The gypsum/calcium sulfite product is essentially a waste product with limited possibilities of use for agricultural purposes.

Conventional Lime Wet Scrubbing Conventional lime wet scrubbing is also similar to LSFO except that the raw material is hydrated lime or quick lime that is either slaked on-site or purchased in the slaked form. The system typically uses forced oxidation, although natural oxidation is possible. The process will produce either solid gypsum wast e or commercial-grade gypsum suitable for reuse as a cement additive if a cement production facility is available and willing to accept the material.

Seawater Scrubbing Seawater scrubbing is a method for controlling SO 2 

### emissions in which seawater is used to absorb SO 2 

### in exhaust gases. Seawater is slightly alkaline (with a pH of approximately 8). SO 2 

### has a high solubility in seawater. Absorbed SO 2 

### is subsequently oxidized to sulfates by the use of aeration and the pH is adjusted by the addition of additional seawater.
There are three main steps in this process: absorption, oxidation, and neutralization. Seawater is passed countercurre nt through the gaseous exhaust stream, typically using a spray column in the aluminum industry. SO 2 

### preferentially dissolves in the seawater. Removal efficiencies of 85 to 95% have been measured in practice. The clean

### March 3, 2009, Revised February 4, 2010

Technology Description exhaust gas is de-misted prior to release to the atmosphere. The acidified seawater is then passed to an oxidation basin in which air is blown through the effluent. The additional oxygen en sures that the dissolved SO 2 

### is converted to sulfates. Fi nally, additional fresh seawater is added to raise the pH to neutral (o r slightly alkaline) and the seawater is discharged back into the ocean.
The effluent from this process will typically have a temperature increase of about 1°C and will have a chan ge in sulfate concentration of approximately 2 to 5% above background. 12 13 

### Scrubbing of the potline emissions also adds fluoride and tr ace amounts of polycyclic aromatic hydrocarbons (PAHs) to the effluent s eawater. The volume of seawater required varies with exhaust flow rate and SO 2 

### loading in the gaseous exhaust stream. At Intalco, the volumetric flow rate needed was estimated to be approximately 2.2 million gallons per hour.
A global review of feasible contro l technologies identified seawater scrubbing as having been installed at seven aluminum smelters, none of which are in the U.S. Even though this technology has been identified as a control technology in operati on at six primary aluminum ore reduction plants in Norway and one primary aluminum ore reduction plant in Sweden, there are two r easons why this technology is not feasible at Intalco:

1. Federal Clean Water Act Secti on 304(b) effluent limitations guidelines would not allow discharg e of the scrubber solutions to the nearby salt water without extensive treatment to remove the sulfides, fluorides, and other pollutants. Removal of potline fluoride from the seawater scrubbe r effluent may be feasible, but would also require precipitation of many other naturally occurring salts in the seawater (chlorides, sulfates, other fluorides, etc.), resulting in the unnecessary generation of large amounts of sludge for land dis posal. Seawater scrubbing is, therefore, not a viable alternative for smelters in the U.S., especially when compared with other scrubbing technologies that use fresh water and require tr eatment/disposal for only those salts present in the potline exhaust.

2

. The portion of Puget Sound where seawater would be withdrawn and discharged has been included as part of the Cherry Point

12 

### Information from the ALSTOM Seawater FGD–Environmental Impact website at

www.environment.power.alstom.com/home/powe r/seawater_fgd/environmental_impact.htm.

13 

### Kwawaji, Akili D., et al. 2005. “Seawater Scrubbing for the Removal of Sulfur Dioxide in a Steam Turbine

Power Plant.” Proceeding of the PWR2005 ASME Power Co nference. April 5-7. Chicago, IL.

### March 3, 2009, Revised February 4, 2010

Technology Description Aquatic Reserve that was established in 2000. The construction of intake and/or discharge stru ctures within the Cherry Point Aquatic Reserve would require an impact analysis, assessment, and DNR authorization of any environmental impacts associated with a seawater scrubbing system. Since more than seven years have passed since Cherry Point was designated as an aquatic reserve and the initial SEPA eval uation has yet to be completed, the time required to complete an analysis of the environmental impacts associated with a seaw ater scrubbing system and obtain the requisite authorizations for a system that withdraws seawater from and discharges scrubber liquor into the Cherry Point Aquatic Reserve would make th is technology infeasible for BART compliance.

Dual Alkali Sodium/Lime Scrubbing (dilute mode) Dual alkali sodium/lime scrubbing (dilute mode) uses a caustic sodium solution in the scrubber tower. A portion of the scrubbing liquid is discharged to a neutralization stag e where lime slurry is used to regenerate the caustic, which is return ed to the scrubber. The bleed from the scrubber is sent to a dewa tering system to produce a gypsum byproduct. The process will produce either solid gypsum waste or commercial-grade gypsum suitable for reuse as a cement additive. Dual alkali sodium/lime scrubbing (dilute mode) is not currently marketed by major FGD vendors because the system is too complicated and expensive. Because of lack of av ailability and anticipated excessive cost, dual alkali sodium/lime scrubbing is determined to be not technically feasible.

Conventional Sodium Scrubbing Conventional sodium scrubbing has b een installed in at least 12 aluminum smelters around the world. An alkaline solution of either soda ash or sodium hydroxide is pu mped into the scrubbing tower and recirculated through a network of spray nozzles. Atomized droplets contact the up-flowing gas containing SO 2 

### . Where this technology has been deployed, the liquid effluent containing dissolved salts, including sodium and fluorides, has been discha rged into a large receiving stream or an open body of water without trea tment. As discussed earlier in conjunction with seawater scrubbing, untreated discharge is not feasible for Intalco. As a result of the inabi lity to discharge effluent, treated or otherwise, into a receiving water, Alcoa determined conventional sodium scrubbing to not be technically feasible.

Dry Injection In dry injection, a reactive alkaline po wder is injected into a furnace, ductwork, or a dry reactor. Typical removal efficiencies with calcium adsorbents are 50 to 60% and up to 80% with sodium base adsorbents. However, as with wet scrubbing, disposal of waste using sodium

### BART Support Document Page 21 of 23 Alcoa Intalco Works March 3, 2009, Revised February 4, 2010

Technology Description adsorbents must consider their high solubility in water compared to those from calcium adsorbents. The temperature range over which scrubbing has been used is 300 to 1, 800°F; the minimum temperature is 300 to 350°F. Dry systems are rarely used and according to EPA, only 3% of FGD systems installed in the U.S. are dry systems. 14 

### The dry waste material is removed using partic ulate control devices such a fabric filter or an electrostatic precipitator (ESP).

Semi-Dry Scrubbing Semi-dry scrubbing is more commonly referred to as spray drying. Calcium hydroxide slurry (lime mixe d with water) is introduced into a spray dryer tower. Sodium compounds can be used, but as with the dry scrubber, the high solub ility of the sodium-based waste products in water complicates disposal of the waste. The slurry is atomized and injected into a reactor with the exhaust gases, where droplets react with SO 2 

### as the liquid evaporates.
This system is categorized as a se mi-dry system because the end product of the SO 2 

### conversion reaction is a dry ma terial. The dry waste product is collected in the bottom of the spray dryer reactor and a fabric filter or ESP downstream of the spray dryer removes the CaSO 3 

### , CaSO 4 

### , and unreacted lime. This air pollution control system uses water for evaporative cooling and for the SO 2 

### reaction. It operates in a temperature range of 300 to 350°F because the temperature of the gases must be high enough to evaporate th e water portion of the slurry.Approximately 12% of the FGD systems installed in the U.S. are spraydry systems 15 

### with typical SO 2 

### removal efficiencies in the range of 80 to 90 percent. Unlike a wet scrubbing system, there is no liquid blowdownstream from the dry system and the collected solids are typically land filled.

14 

### EPA 2003, “Air Pollution Control Technology Fact Sheet–Flue Gas Desulfurization,” EPA-452/F-03-034.

15 

### Ibid.February 3, 2009APPENDIX B. LSFO SCRUBBER CONTROL SCENARIOS–EMISSIONS AND IMPACTSTable B-1. EMISSION RATES FOR SO2CONTROL SCENARIOS1ControlScenarioSO2ControlTechnologyEvaluatedSO2NO2PM2.5PM10Emissions(tons/yr)% Reduction(increase)2Emissions(tons/yr)% Reduction(increase)2Emissions(tons/yr)% Reduction(increase)2Emissions(tons/yr)% Reduction(increase)2CurrentAllowableEmissionsOperatingLimit of 3%Sulfur in Coke7,076136693869Scenario 1Plus LSFOScrubber Onlyfor Potlines854881360984(42)1,113(28)Scenario 2Plus LSFOScrubber Onlyfor AnodeBake Furnace6,90421360747(8)921(6)1. Total emission rate for the potline primary control system, the potline secondary control system emissions, and the anode bake furnace.2. Compared with current potential emissions. Intalco’s BARTtechnical analysis provides information on increases in emissions of particulatesdue to LSFO scrubbers. Because sulfate dominates visibility impacts on Class I areas, these small increases in particulates were not a factor inthe BART determination.BART Support Document Page 23 of 23Alcoa Intalco WorksFebruary 3, 2009Table B-2. SUMMARY OF THE IMPACTS ANALYSIS FOR SO2CONTROL SCENARIOSControlScenarioSO2ControlTechnologyEvaluatedSO2EmissionRate1(tons/yr)SO2EmissionReductions2(tons/yr)InstalledCapital CostTotalAnnualizedControlCostsCostEffectiveness(per ton SO2removed)EnergyImpact(kW-hr/yr)Non-Air QualityEnvironmental ImpactsCurrentAllowableEmissionsOperatingLimit of 3%Sulfur in Coke7,076Scenario 1Plus LSFOScrubber Onlyfor Potlines8546,223$234,531,049$46,820,000$7,50064,824,00027,130 tons/yr of solid wastedisposal182.5 million gallons/yrmakeup waterScenario 2Plus LSFOScrubber Onlyfor AnodeBake Furnace6,904172$29,482,194$6,227,000$36,4006,570,000639.5 tons/yr of solid wastedisposal12.8 million gallons/yrmakeup water1. Total emission rate for the potline primary control system,the potline secondary control system, and the anode bake furnace.2. Compared with current potential emissions.

### February 3, 2009

APPENDIX C. ACRONYMS/ABBREVIATIONS

BACT Best Availabl e Control Technology BART Best Availabl e Retrofit Technology dv Deciview(s) CO Carbon Monoxide Ecology Washington State Department of Ecology EPA United States Environmental Protection Agency ESPs Electrostatic Precipitators Intalco Alcoa Intalco Works LSFO Limestone Slurry Forced Oxidation LSNO Limestone Slurry Natural Oxidation mt Metric Ton NO X 

### Nitrogen Oxides PM Particulate Matter PM 10 

### Particulate Matter (with a m ean diameter less than 10 microns) ppm Parts per Million PSCAA Puget Sound Clean Air Agency SIP Regional Haze State Implementation Plan SO 2 

### Sulfur Dioxide VOC Volatile Organic Compound

## BART DETERMINATION FO R ALCOA INTALCO WORKS FERNDALE, WASHINGTON

Prepared for:

Alcoa Intalco Works Ferndale, Washington

Prepared by:

ENVIRON Corporation 6001 Shellmound Street, Suite 700 Emeryville, California 94608

November 2007

Contract Number 03-8979CIntalco BART Determination FINAL.doc
- 

### i

- 

## TABLE OF CONTENTS

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

2.0 IDENTIFICATION OF BART-ELIGI BLE UNITS AT INTALCO ........................ 2-1

3.0 BART-ELIGIBLE EMISSION UNIT GROUP DESCRIPTION ............................. 3-1 3.1 P RIMARY 

### A LUMINUM 

### R EDUCTION 

### P ROCESS 

### D ESCRIPTION 

### ........................................ 3-1 3.1.1 E XISTING 

### P OTLINE 

### E MISSIONS 

### C ONTROL 

### ......................................................... 3-2 3.1.2 A NODE 

### B AKE 

### F URNACE 

### E MISSIONS 

### C ONTROL 

### ................................................. 3-2 3.1.3 A LUMINUM 

### H OLDING 

### F URNACE 

### E MISSIONS 

### C ONTROL 

### .................................... 3-3

4.0 BASELINE CONDITIONS AND VISIBILI TY IMPACTS FOR BART-ELIGIBLE UNITS .......................................................................................................................... ... 4-1 4.1 CALPUFF M ODEL AND 

### B ASELINE 

### E MISSION 

### I NPUTS 

### ............................................... 4-1 4.2 S CREENING 

### -L EVEL 

### M ODELING 

### A NALYSIS 

### ................................................................. 4-1 4.3 R EFINED 

### M ODELING 

### A NALYSIS 

### ................................................................................. 4-2

5.0 BART ANALYSIS FOR BART-ELIGIBLE EMISSION UNITS ............................ 5-1 5.1 A VAILABLE AND 

### T ECHNICALLY 

### F EASIBLE 

### E MISSION 

### C ONTROL 

### O PTIONS 

### ................. 5-1 5.1.1 P OTLINE 

### E MISSIONS AND 

### E XISTING 

### C ONTROLS 

### ............................................... 5-1 5.1.2 A NODE 

### B AKE 

### F URNACE 

### E MISSIONS AND 

### E XISTING 

### C ONTROLS 

### ....................... 5-1 5.1.3 P OTENTIALLY 

### A PPLICABLE 

### BART C ONTROL 

### O PTIONS FOR 

### SO 2 

### ..................... 5-2 5.1.4 P OTENTIALLY 

### A PPLICABLE 

### BART C ONTROL 

### O PTIONS FOR 

### PM.................... 5-12 5.1.5 P OTENTIALLY 

### A PPLICABLE 

### BART C ONTROL 

### O PTIONS FOR 

### NO X 

### .................. 5-13 5.1.6 S UMMARY OF 

### T ECHNICALLY 

### F EASIBLE 

### BART C ONTROL 

### O PTIONS 

### ............... 5-15 5.2 C ONTROL 

### E FFECTIVENESS OF 

### F EASIBLE 

### O PTIONS 

### ................................................... 5-17

5.2.1 SO 2 

### W ET 

### S CRUBBING 

### .................................................................................... 5-17 5.2.2 SO 2 

### P OLLUTION 

### P REVENTION 

### ........................................................................ 5-18 5.2.3 A NODE 

### B AKE 

### F URNACE 

### A DVANCED 

### F IRING 

### S YSTEM 

### .................................... 5-18 5.2.4 A NODE 

### B AKE 

### F URNACE 

### L O 

### TO X TM 

### S YSTEM 

### .................................................. 5-18 5.3 E VALUATION OF 

### C OSTS AND 

### O THER 

### I MPACTS 

### ......................................................... 5-18 5.3.1 C OST 

### I MPACTS FOR 

### F EASIBLE 

### C ONTROLS 

### ...................................................... 5-18 5.3.2 E NERGY 

### I MPACTS 

### ........................................................................................... 5-21 5.3.3 G REENHOUSE 

### G AS 

### G ENERATION 

### ................................................................... 5-21 5.3.4 N ON 

### -A IR 

### Q UALITY 

### E NVIRONMENTAL 

### I MPACTS 

### ............................................. 5-21 5.3.5 R EMAINING 

### U SEFUL 

### L IFE 

### ............................................................................... 5-22 5.4 E VALUATE 

### V ISIBILITY 

### I MPACTS 

### .............................................................................. 5-22

6.0 DETERMINATION OF BART.................................................................................... 6-1 6.1 A LUMINUM 

### P OTLINES 

### ................................................................................................ 6-1 6.2 A NODE 

### B AKE 

### F URNACE 

### ............................................................................................. 6-1 6.3 A LUMINUM 

### H OLDING 

### F URNACES 

### .............................................................................. 6-2 6.4 M ATERIAL 

### H ANDLING AND 

### T RANSFER 

### O PERATIONS 

### ................................................. 6-2Intalco BART Determination FINAL.doc
- 

### ii

- 

## TABLES

3-1 Primary Aluminum Reduction Emission Units
4-1 Source Input Data for Baseline Modeling – Point Sources
4-2 Source Input Data for Ba seline Modeling – Line Sources
4-3 Source Input Data for Baseline Modeling – Area Sources
4-4 Source Input Data for Ba seline Modeling – Volume Sources
4-5 Screening Baseline Visibility Modeling Results
4-6 Refined Baseline Visibility Modeling Results
4-7 Culpability Analysis for Refined Ba seline Visibility Modeling Results in Olympic National Park

5-1 RBLC Database Search Resu lts for Primary Aluminum Facilities

5-2 Post Control SO 2 

### Emission Rates
5-3 Summary of Impacts Analysis for SO 2 

### Control Scenarios
5-4 Source Input Data for Post Control SO 2 

### Modeling

5-5 Post Control SO 2 

### Visibility Modeling Results



## FIGURES

5-1 Wet Scrubber Process Flow Diagram



## APPENDICES

A BART Modeling Results

B Business Confidential Information
C Pre-Feasibility Report
D Wet Scrubber Economic and Energy Impact

E Greenhouse Gas Emission CalculationsIntalco BART Determination FINAL.doc
- 

### iii

- 

## ACRONYMS

acfm actual cubic feet per minute AWMA Air and Waste Management Association BACT Best Availa ble Control Technology BART Best Available Retrofit Technology CAA Clean Air Act CFR Code of Federal Regulations DNR Department of Natural Resources dv deciview ELG Effluent Limitations Guidelines ESP Electrostatic Precipitator FGD Flue Gas Desulfurization Intalco Alcoa Intalco Works LAER Lowest Achievable Emissions Rate lb/day pounds per day LSFO Limestone Slurry Forced Oxidation LSNO Limestone Slurry Natural Oxidation MW Megawatt NESHAP National Emission Standard s for Hazardous Air Pollutants NO x 

### Nitrogen Oxides PAH Polycyclic Aromatic Hydrocarbons PM Particulate Matter PM 2.5 

### Particulate Matter less th an 2.5 micrometers in diameter PM 10 

### Particulate Matter less th an 10 micrometers in diameter ppm parts per million ppmv parts per million by volume RACT Reasonably Av ailable Control Technology RBLC RACT/BACT/LAER Clearinghouse SCR Selective Catalytic Reduction SEPA State Environmental Protection Act SNCR Selective Non-Catalytic Reduction SO 2 

### Sulfur Dioxide USEPA United States Envi ronmental Protection AgencyIntalco BART Determination FINAL.doc
- 

### ES-1

- 

## EXECUTIVE SUMMARY

The Clean Air Act (CAA) requires the protection of visi bility in 156 scenic areas across the United States. Under CAA Section 169A(b)(2)(A), st ates must require cert ain existing stationary
sources to install Best Available Retrofit T echnology (BART). Alcoa, Inc. – Intalco Works (Intalco) is a “BART-eligible” source. A BART determination is required because Intalco emits air pollutants that may reasonably be anticipated to contribute to impairment of visibility in a
Class I area.

The BART analysis contained herein lists the individual BART-eligible emission units and evaluates visibility impacts, control option f easibility, cost effectiveness and visibility improvement. The BART evaluation was comple ted according to guidance provided in 40 Code of Federal Regulations (CFR) 51, Appendix Y and the Washington, Oregon, and Idaho BART modeling protocol 1



### .

A baseline Class I area visibili ty impact analysis was perfor med on 100 BART-eligible emission units at Intalco using the CA LPUFF model as recommended by the modeling protocol. These sources include three potlines, the anode bake furnace, 12 aluminum holding furnaces, various material handling and transfer operations, natura l gas, diesel and propane combustion sources,
and other small miscellaneous sources.

The modeled or projected 98 th 

### percentile visibility impacts for the entire facility exceed the 0.5 deciview (dv) contribution threshold in five Class I areas: Alpine Lakes Wilderness Area, Glacier Peak Wilderness Area, Mount Rainier Na tional Park, North Cascades National Park, and Olympic National Park. The highest modeled faci lity-wide impact is 1.527 deciviews (dv) in the Olympic National Park (ONP). The modeled visi bility impacts are primarily from the potlines,
with a small amount from the anode bake furnac e. Other sources contribute negligible amounts
to the total as described further below.

The highest modeled or projected 98 th 

### percentile visibility impact of the potlines is approximately 1.44 dv in the ONP. The projected im pacts in the other, more distant, Class I areas are lower. More than 98% of the projecte d impact from the potlines is attributable to emissions from the potroom primary control de vices, with the remainder from the existing potroom roof scrubbers. More than 96% of the potroom primary control device impact is from emissions of sulfur dioxide (SO 2 

### ).

1 

### Modeling Protocol for Washington, Oregon, and Idaho: Protocol for the Application of the CALPUFF Modeling System Pursuant to the Best Availabl e Retrofit Technology (BART) Regulation. www.deq.state.or.us/aq /haze/docs/bartprotocol . October 11, 2006.Intalco BART Determination FINAL.doc
- 

### ES-2

- 

### Results from the BART analysis for potroom em issions determined that BART for potline SO 2 

### emissions is a pollution prevention limit of 3% su lfur in the calcined petroleum coke used to manufacture anodes (i.e., coke ). BART for other pollutants emitted from the potlines [particulate matter (PM) and nitrogen oxides (NO x 

### )] was determined to be the existing level of
emission control.

The highest modeled or projected 98 th 

### percentile visibility impact from the anode bake furnace is approximately 0.053 dv in ONP, with lower projected impacts in other Class I areas. More than 40% of the anode bake furnace impact (0.02 dv) is from SO 2 

### emissions and 55% of the impact (0.03 dv) is from NO x 

### . The analysis of control options for the anode bake furnace determined
that BART for bake furnace SO 2 

### emissions is a pollution preventi on limit of 3% sulfur in the coke. BART for other pollutants em itted from the anode bake furnace (NO x 

### and PM) was
determined to be the existi ng level of emission control.

Additional BART-eligible emission units at th e Intalco facility include aluminum holding furnaces, various material handling and transfer operations, natural gas, diesel, and propane combustion, and other small miscellaneous sour ces that support the primary aluminum ore reduction process. The combined projected imp acts from all remaining BART-eligible emission units (sources other than the potlines and anode bake furnace) are less than 0.05 dv in ONP, with lower projected impacts in other Class I areas. C onsidering the minimal cont ribution to visibility impairment (less than 0.05 dv) and the existing le vel of emissions control, these emission sources
were excluded from further e ngineering analysis and BART wa s determined to be no further
emissions control for these sources.Intalco BART Determination FINAL.doc 

### 1-1 

## 1.0 INTRODUCTION

The Clean Air Act (CAA) requires the protection of visi bility in 156 scenic areas across the United States. Under CAA Section 169A(b)(2)(A), st ates must require cert ain existing stationary
sources to install Best Available Retrofit Tec hnology (BART). A “BART- eligible” s ource is one
that is contained in the 26 identified source cate gories that has the potential to emit greater than or equal to 250 tons per year of any air polluta nt and was put in place during the 15-year interval between August 7, 1962, and August 7, 1977. BART is required when any source meeting this definition emits any air pollutant that may reasonably be anticipate d to cause or contribute to any impairment of visibility in any Class I area.Intalco BART Determination FINAL.doc 

### 2-1 

## 2.0 IDENTIFICATION OF BART-ELI GIBLE UNITS AT INTALCO

Alcoa, Inc. – Intalco Works (Intalco) operates em ission units that fall within the categories of primary aluminum ore reduction plants, one of the 26 identified source categories to which BART is applicable. The Intalco facility was originally constructed in 1965, and began operation in 1966. Therefore, the facility’s em ission units were in existence on August 7, 1977, but were not in operation before August 7, 1962. The facility has the potential to emit greater than or equal to 250 tons/year of sulfur dioxide (SO 2 

### ), nitrogen oxides (NO x 

### ), and particulate matter (PM), all of which have been classified as visibility impairing pollutants. As such, the Intalco facility is defined as a BART-eligible source. All emission units at Intalco, with the exception of one remelt furnace, were constructed between August 7, 1962 and August 7, 1977 and are, therefore, BART-eligible.Intalco BART Determination FINAL.doc 

### 3-1 

## 3.0 BART-ELIGIBLE EMISSION UNIT GROUP DE SCRIPTION

3.1 P RIMARY 

### A LUMINUM 

### R EDUCTION 

### P ROCESS 

### D ESCRIPTION 

### Intalco’s primary aluminum reduction operations include three potlines, an electrode manufacturing operation, consisting of a paste production ope ration and a green anode baking furnace, and miscellaneous material handling operations.

The potline operation manufactures metallic aluminum by the electrolytic reduction of alumina in side-worked prebake cells. Di rect electrical current, passing between anodes and the cathode, electrolytically reduces the al umina to metallic aluminum a nd oxygen. Molten aluminum is deposited and accumulates over time at the cathode beneath a layer of molten cryolite bath. Periodically the molten aluminum is siphoned from beneath the cryolite ba th and processed to achieve specific metal properties or is retained as pure aluminum. The produced aluminum is solidified into intermediate or final products.

Anodes are manufactured in an ancillary on-site paste producti on plant. Calcined petroleum
coke used to manufacture anodes (i.e., coke) is crushed and sized, anode butt material is crushed and sized, and both are mixed toge ther with pitch and formed into self-supporting carbonaceous blocks called “green anodes.” The green anodes are then cured and baked in furnaces before being used in the side-worked pr ebake aluminum reduction process.

Table 3-1 presents the individu al emission units that are incl uded in the primary aluminum reduction emission unit group and that were identifie d as BART-eligible emission units. Potlines A, B, and C emit SO 2 

### and PM, and the anode bake furnace emits lesser amounts of SO 2 

### , NO x 

### , and PM. These emission units are already e quipped with sophisticated emission control equipment for PM, so the BART determination for these emission units focuses primarily on potential reductions for SO 2 

### and NO x 

### .
The remaining emission units identified in Table 3-1 include aluminum holding furnaces, various material handling and transfer operations, natura l gas, diesel, and propa ne combustion, and other small miscellaneous sources that support the potlin es and anode bake furnace. Aside from the natural gas combustion products, emissions from most of the support operations consist of relatively small amounts of PM that are controlled by fabric filter type control devices. Fabric filters effectively remove more than 99% of particulate emissions and, based on the control technology review, represent the best available c ontrol for these types of material handling and transfer operations. The natural-gas fired units at Intalco emit very little PM. Given the relatively low level of emissions, the fact that fabr ic filters represent the best available control, and the minimal impacts of these sources on visi bility, these emission units were excluded fromIntalco BART Determination FINAL.doc 

### 3-2 

### further BART engineering analysis. BART for these support operations was determined to be the existing level of control.

3.1.1 Existing Potline Emissions Control The potlines at Intalco consist of six potroom groups [i.e., “... a group of potroom segments ducted to a common control system” (40 Code of Federal Regulations 60.191)] of electrolytic reduction cells connected in series that pr oduce molten aluminum. There are two potroom groups per potline. Each potroom is comprised of 120 reduction cells (or pots) with 18 anodes per cell. All pots at Intalco are hooded to control emissions. Emissions captured by the hoods are drawn through primary control systems, which consist of dry alumina injection systems with baghouses for the control of PM and fluoride emi ssions. A small fraction of the pot emissions escape capture by the hoods and ar e released inside the potrooms. These secondary emissions are drawn through a secondary control system which consists of wet roof scrubbers that control
PM and fluoride emissions.

Each of Intalco’s primary control system cente rs consists of multi-compartment baghouse cells. Either reverse pulse or reverse flow is used in cleaning the fabric filters of the baghouse cells. The multiple compartment design allows for maintenance and troubleshooting of individual cells while the baghouse center is still operating. The PM control efficiency of the primary control system is estimated to be 97.7% based on measured emissions.

Fugitive potroom emissions from primary alumin um smelters are typically not controlled. However, Intalco operates a sec ondary pollution control system on each of its potlines to abate fugitive emissions. The secondary control system consists of 159 wet roof scrubbers for the three potlines. Each wet roof scrubber treats approximately 10,000 actual cubic feet per minute (acfm) of potroom air. The wet roof scrubbers become inoperable and must be shutdown during any sustained periods of below-freezing temperatur es in order to avoid permanent damage from freezing. These shutdowns occur only in the winter months, and occur infrequently. For the last four operating years, shutdowns due to cold temperatures have averaged less than six or seven days per year. The PM control efficiency of th e secondary control system is estimated to be approximately 82%.

3.1.2 Anode Bake Furnace Emissions Control Products of natural gas combustion, products of combustion from volatiles liberated during the baking of green anodes, and other emissions typically associated with anode baking are exhausted to a dry alumina scrubbing system. The baking furnace emission control equipment conditions the exhaust gases prior to alumina bei ng injected. Fabric fi ltration modules located downstream of the alumina injection re duce PM emissions by as much as 99%.Intalco BART Determination FINAL.doc 

### 3-3 

### 3.1.3 Aluminum Holding Furnace Emissions Control The 12 holding furnaces at Intalco vary in size. The largest of these furnaces has a natural gas rated burner capacity of 22 MMBtu/hr. There are no emissi on controls associated with the
aluminum furnaces at Intalco.Intalco BART Determination FINAL.doc 

### 4-1 

## 4.0 BASELINE CONDITIONS AND VI SIBILITY IMPACTS FOR BARTELIGIBLE UNITS

CALPUFF modeling was performed to evaluate the cumulative visibility impacts of BARTeligible emission units at Intalco, and to compare the relative contribution of individual emission units to the total visibility impact. All mode ling performed in association with this BART determination was done by TRC Environmental Corporation following the WDOE’s BART modeling protocol 2 

### . The complete Intalco BART modeling report is contained in Appendix A

.

4.1 CALPUFF M ODEL AND 

### B ASELINE 

### E MISSION 

### I NPUTS 

### CALPUFF and its meteorological model CALM ET are designed to handle the complexities posed by complex terrain, long source recepto r distances, chemical transformation and deposition, and other issues related to Class I impacts. The USEPA adopted the CALPUFF modeling system as a guideline model for source- receptor distances greater than 50 km and for use on a case-by-case basis in complex flow situat ions for shorter distances (Federal Register, April 15, 2003). CALPUFF was recommended for Class I impact assessments by the Federal Land Managers Workgroup in 2000 and the Intera gency Workgroup on Air Quality Modeling in 1998. CALPUFF is recommended by USEPA (Federal Register, July 6, 2005) and the State of Washington 3 

### for BART analyses.

Tables 4-1, 4-2, 4-3, and 4-4 pr esent the baseline modeling source input data for point sources, line sources, area sources, and volume sources, re spectively, that were used in the CALPUFF model to forecast the visibility impacts. In accordance with Section IV of 40 CFR 51 Appendix Y and the BART modeling protoc ol for Washington, Oregon, and Idaho, baseline emission rates used in the model were based on 24-hour average actual emissions from the highest emitting day.

4.2 S CREENING 

### -L EVEL 

### M ODELING 

### A NALYSIS 

### Screening runs were performed for 2003 th rough 2005 using the 4-km resolution CALMET meteorological data set prepared by Geomatrix for Washington, Oregon, and Idaho. Eight Class I areas (Mount Adams Wilderness Area, North Ca scades National Park, Goat Rock Wilderness Area, Pasayten Wilderness Area, Glacier Peak National Park, Alpine Lakes Wilderness Area, Olympic National Park, and Mount Rainier National Park) were included in the screening level visibility modeling.

2 

### Modeling Protocol for Washington, Oregon, and Idaho: Protocol for the Application of the CALPUFF Modeling System Pursuant to the Best Availabl e Retrofit Technology (BART) Regulation. www.deq.state.or.us/aq/h aze/docs/bartprotocol.pdf . October 11, 2006.

3 

### Ibid.Intalco BART Determination FINAL.doc 

### 4-2 

### The screening level analysis results are presented in Table 4-5. These resu lts project visibility impacts within Mount Adams Wilderness Area of less than 0.5 dv, indicat ing that Intalco does not contribute to visibility impairment in the Mount Adams Wilderness Area. A refined, 1-km visibility impact analysis was subsequently performed on the remaining seven Class I areas.

4.3 R EFINED 

### M ODELING 

### A NALYSIS 

### Table 4-6 presents the modeled 98 th 

### percentile total source visibility impacts (reported as deciviews) for 2003, 2004, and 2005 in the seven Class I areas identified in the screening modeling analysis as having visi bility impacts greater than 0.5 dv. Refined modeled visibility impacts exceed the contribution threshold lim it of 0.5 dv at Alpine Lakes Wilderness Area, Glacier Peak Wilderness Area, Mount Rainier Na tional Park, North Cascades National Park, and Olympic National Park. Refined modeled visibility impacts at the Goat Rock and Pasayten
Wilderness Areas were below the 0.5 dv contribution threshold. The highest predicted visibility impacts were in Olympic National Park.

Table 4-7 presents a culpability analysis for Olympic National Park. Individual emission unit visibility impacts in Olympic National Park were used to identify which emission units were forecasted to have the most impact on visibil ity impairment. The modeled or projected 98 th 

### percentile visibility impact from the combin ed potline emissions for the maximum year is approximately 1.44 dv in Olympic National Park. Mo re than 98% of this projected impact from the potlines is attributable to emissions from the potroom primary control devices, with the remainder from the potroom wet roof scrubbers. More than 96% of the potroom primary control device impact is from emissions of SO 2 

### . The modeled or projected 98 th 

### percentile visibility impact for the maximum year from the anode bake furnace was 0.053 dv in Olympic National Park. More than 40% of the anode bake furnace impact is attributable to SO 2 

### emissions and approximately 55% of the impact is from NO x 

### emissions. The total projected impacts from the remainder of the facility’s BART-eligible sources for the maximum year are 0.049 dv in Olympic National Park.

For all emission units other than the potlines and anode bake furnace, the refined modeling
results in Table 4-7 show a combined total visi bility impact that is less than 0.05 dv. The combined impact of these emission units is less than 10% of the facility-wide contribution
threshold level of 0.5 dv for BART a pplicability established for Washington 4 

### . Reduction in
emissions from these units would not result in significant visibility impr ovement in any of the Class I areas. For example, the modeled visibil ity impact from all 12 aluminum holding furnaces (casthouse stacks in Table 4- 7) was 0.004 dv at ONP. The use of added controls for these

4 

### Modeling Protocol for Washington, Oregon, and Idaho: Protocol for the Application of the CALPUFF Modeling System Pursuant to the Best Available Retrofit Technology (BART) Regulation. October 11, 2006. www.deq.state.or.us/aq/h aze/docs/bartprotocol.pdfIntalco BART Determination FINAL.doc 

### 4-3 

### furnaces would provide a negligible visibility im provement at ONP, as well as the other Class I

areas.

Based on results from the baseline modeling, th e scope of the BART control analysis and engineering cost calculations were focuse d on the potlines and anode bake furnace.Intalco BART Determination FINAL.doc 

### 5-1 

## 5.0 BART ANALYSIS FOR BART-E LIGIBLE EMISSION UNITS

The results of the refined CALPUFF modeling s how that Intalco’s potline reactors and anode bake furnace contribute to visibility impairment in five Class I areas. The BART analysis completed for these emission sources is described in this section. The anal ysis included a review of available and technically feasible retrofit technologies (Steps 1 an d 2), determination of
control effectiveness for feasible options (Step 3), evaluation of cost and secondary impacts for feasible alternatives (Step 4), and analysis of impacts and vi sibility improvements (Step 5).

5.1 A VAILABLE AND 

### T ECHNICALLY 

### F EASIBLE 

### E MISSION 

### C ONTROL 

### O PTIONS 

### Steps 1 and 2 of the BART analysis are to id entify available emission control options and to evaluate the technical feasibility of these cont rol technologies. Contro l options for the potline
reactors and anode bake furnace are descri bed separately in the following sections.

5.1.1 Potline Emissions and Existing Controls Aluminum is manufactured in large electrolytic reduction cells called pots. Aluminum is produced from alumina in the pot as current is passed from a carbon anode to carbon blocks on the pot wall, which serve as the cathode. The anodes are made from pitch and coke. The major pollutants emitted from the cells are PM, hydrogen fluoride, SO 2 

### , and carbon monoxide. PM includes particulate fluoride, ca rbon dust, and alumina. SO 2 

### comes from the sulfur in the components used to make the anodes. NO x 

### emissions are minimal since there is no external fuel or combustion zone and there are no large so urces of nitrogen in the raw materials.

Emissions from the pots are coll ected by close capture hoods over each pot. The hoods enclose the pot as tightly as possible to collect off-gases, but sections ma y be removed to allow anodes to be changed. The off-gases are collected into manifolds that combine the gases from the individual pots. The temperature of the exhaust gases entering the control equipment is typically
150 to 300°F 5 

### . The combined gases are routed to a dr y alumina scrubber. The potline primary control systems for Intalco's three potlines consist of dry scrubbers using alumina injection with
fabric filtration for PM control. The system at Intalco is large, treating approximately 1,815,000 acfm of 180°F exhaust gases.

5.1.2 Anode Bake Furnace Emissions and Existing Controls

The anode bake furnace structure is a series of interconnected refr actory flues connected to side
main exhaust manifolds. The furnace is fueled with natural gas. Exhaust gases are routed so that

5 

### Air and Waste Management Association (AWMA). 2000. Air Pollution Engineering Manual , Second Edition.Intalco BART Determination FINAL.doc 

### 5-2 

### flue gases preheat the next section to be fired. Flue gases from the anode bake furnace contain PM, hydrogen fluoride, SO 2 

### , carbon monoxide, and hydrocarbons.

The bake furnace control device us ed at Intalco is similar to th e potline primary control system, consisting of dry alumina injection with fabr ic filtration. The bake oven gas stream is conditioned by a water spray to reduce the inlet temp erature before it enters the scrubber. Fresh and recycled alumina are injected into the gas stream, gaseous fluoride and POM are adsorbed onto the alumina surface, and fabric filters on to p of the reactor compartments collect entrained particulate matter present in the gas stream. The system at Intalco treats approximately 216,000 acfm of 205°F exhaust gases.

5.1.3 Potentially Applicable BART Control Options for SO 2 

### Sulfur in the anodes is oxidized, releasing SO 2 

### from the potlines as the anodes are consumed.
SO 2 

### is also released from the anode bake furn ace as pitch used to help form the anodes is oxidized during the baking process. Options for controlling SO 2 

### include both add-on controls and pollution prevention.

5.1.3.1 Add-on Emission Controls Absorption and adsorption have been used for the control of SO 2 

### emissions from numerous power utility and i ndustrial processes. As a result many commercialized control technologies have been used for SO 2 

### control. However, the practical application of these controls systems to the potline reac tors and anode bake furnace is limited by the very low inlet SO 2 

### levels, in the range of 100 parts per million by volume (ppmv), and the expected range of gas conditions, incl uding temperature, oxygen content, humidity,
SO 2 

### /O 2 

### ratio, and gas impurities.

Eight different SO 2 

### control options were consider ed as having pot ential practical application as part of the BA RT analysis. Two of these technologies have been applied
to the control of SO 2 

### emissions at aluminum smelters. Six of the control options use wet scrubbing and two use dry scrubbi ng technology. The eight po tentially applicable control options are:

• 

### Limestone slurry scrubbing with forced oxidation

• 

### Limestone slurry scrubbing with natural oxidation

• 

### Conventional lime wet scrubbing

• 

### Seawater scrubbing

• 

### Dual alkali sodium/lime scrubbing (dilute mode)

• 

### Conventional sodium scrubbingIntalco BART Determination FINAL.doc 

### 5-3 • 

### Dry injection

• 

### Semi-dry scrubbing

5.1.3.1.1 Wet Scrubbing The primary development of SO 2 

### control technol ogy occurred because of the need to
control emissions from the coal-fir ed, electric utility power industry 6 

### . The large volumetric size of the potroom exha ust (approximately 1,815,000 acfm) would require a system similar to those used in the electric utility power industry.

The typical temperature range for wet scrubbers is 300 to 700°F. For utility combustion units, wet scrubbing systems have been installed on systems as large as 1,500 megawatts (MW). Sodium compounds, lime, or limestone can be used. However, the high solubility of sodium complicates disposal of waste and wastewater. The typical sorbent material is lime or limestone. Lime is generally easier to manage on-site but is significantly more costly. Wet limestone scrubbing has a high capital and operating cost due to the handling of liqui d reagent and waste, but is the preferred process for coal-fired ut ility power plants due to the low cost of limestone and high removal efficiencies. Typical removal efficiencies for wet
scrubbers are between 80 and 95%. A pproximately 85% of the flue gas desulfurization (FGD) systems installed in the United States are wet scrubber
systems 7



### .
In wet scrubbers, the waste gas enters a larg e vessel (spray tower or absorber), where it is sprayed with water slurry. The calcium in the slurry reacts with SO 2 

### to form
CaSO 3 

### . A portion of the slurry from the react ion tank is pumped into the thickener, where the solids settle before going to a filter for final dewatering to about 50% solids. Figure 5-1 is a simplified pro cess flow diagram of a conventional wet
scrubber.

6 

### AWMA. 2000. Air Pollution Engineering Manual , Second Edition.

7 

### USEPA. 2003. “Air Pollution Control Technology Fact Sheet – Flue Gas Desulfurization.” EPA-452/F-03-034. August 8.Intalco BART Determination FINAL.doc 

### 5-4 Figure 5-1. Wet scrubber process flow diagram

Inlet Gas Particulate Control Clean gas out Spray tower/absorber

Fly Ash Lime (stone) and Water Reaction Tank Calcium-based sorbent spray

Thickener

Filter

Solids

Stabilized Waste Lime

Blending Pugmill Reagent Supply Liquid Waste Stream



### In the utility industry, the CaSO 3 

### waste product is usually mixed with fly ash (approximately 1:1) and fixative lime (appr oximately 5%) and typi cally disposed of in landfills. Alternately, the forced oxidation process oxidizes the spent slurry to gypsum. Gypsum crystals dewater more e fficiently and reduce the size of waste handling equipment. Depending on qua lity and demand, the gypsum may be commercially sold, eliminating the n eed for landfilling the waste product.

“Mist eliminators” installed at the spray tower outlet or downstream ductwork remove droplets from the gas. In some pow er plant installations, the gas is reheated to avoid corrosion downstream. Many scrubbers have gas bypassing capability, which can be used for gas reheating. Ifthe wet scrubber is downstream of a highefficiency particulate removal device [fabric filter or electrostatic precipitator (ESP)], the particulate concentration may be higher leaving the scrubber than entering due to the solids in mist droplets that are carried out of the scrubber.Intalco BART Determination FINAL.doc 

### 5-5 

### Some disadvantages of using wet scrubbing techniques in many a pplications are the requirement to treat wastewater, the need to construct compone nts from expensive alloys to resist corrosion, a nd much higher energy usage. A practical issue associated with a wet scrubber system is the complexity of the system. The space required for a wet system is substantial (i.e., large foot print), the systems requi re more maintenance due to their complexity, and more pe rsonnel are required for their operation.

5.1.3.1.1.1 Limestone Slurry Forced Oxidation Limestone slurry forced oxidation (LSFO) is used extensively in the utility FGD market. The raw material is finely ground limestone. Ther e are a number of suppliers of LSFO technology. The most commonly used equipment is an open, multi-level, countercurrent spray tower sc rubber equipped with spray nozzles to inject the limestone slurry droplets into th e gas stream. Liquor is collected at the bottom of the tower and sparged with air to oxidize the calcium sulfite to calcium sulfate to enhance the settling properties of the calcium sulfate. Recirculation pumps circulate the scrubbing li quor to the spray nozzles. SO 2 

### removal
efficiencies of 90% have been achieved. Th e bleed from the scrubber is sent to a dewatering system to remove excess mois ture. For an aluminum smelter, the process will produce either solid gypsum waste or commercial-grade gypsum
suitable for reuse as a cement additive if a cement production facility is available and willing to accept the material. Only a very small purge or blowdown stream is required.

LSFO was determined to be a technically f easible retrofit control option for the potroom reactor and the anode baking exhausts even though it is not ideally suited for scrubbing SO 2 

### concentrations that are less than or equal to 105 ppm.

5.1.3.1.1.2 Limestone Slurry Natural Oxidation Limestone slurry natural oxidation (LSNO) is very similar to LSFO. The major difference is the absence of an oxidation stage. The gypsum/calcium sulfite product is essentially a waste product with limited possibilities of use for agricultural purposes.

5.1.3.1.1.3 Conventional Lime Wet Scrubbing Conventional lime wet scrubbing is also similar to LSFO ex cept that the raw material is hydrated lime or quick lime that is either slaked on- site or purchased in the slaked form. The system typically uses forced oxidation, although natural oxidation is possible. The process will produce either solid gypsum waste orIntalco BART Determination FINAL.doc 

### 5-6 

### commercial-grade gypsum suitable for reuse as a cement additive if a cement production facility is available and w illing to accept the material.

5.1.3.1.1.4 Seawater Scrubbing Seawater scrubbing is a method for controlling SO 2 

### emissions in which seawater
is used to absorb SO 2 

### in exhaust gases. Seawater is slightly alkalin e (with a pH of approximately 8). SO 2 

### has a high solubility in seawater. Absorbed SO 2 

### is subsequently oxidized to sulfates by the use of aeration and the pH is adjusted by
the addition of additional seawater.

There are three main steps in this process: absorption, oxidation, and
neutralization. Seawater is passed countercurrent through the gaseous exhaust stream, typically using a spray column in the aluminum industry. SO 2 

### preferentially dissolves in the seawater . Removal efficiencies of 85% to 95% have been measured in practice. The clean exhaust gas is de-misted prior to release to the atmosphere. The acidified seawater is then pa ssed to an oxidation basin in which air is blown through the effluent. The additional oxygen ensures
that the dissolved SO 2 

### is converted to sulfates. Finally, additional fresh seawater is added to adjust the pH back up to neut ral (or slightly alkali ne) and the seawater is discharged back into the ocean.

The effluent from this process will typical ly have a temperature increase of about 1°C and will have a change in sulfate c oncentration of approximately 2-5% above background 8,9 

### . Scrubbing of the potline emissions also adds fluoride and trace amounts of polycyclic aromatic hydrocarbons (PAHs) to the effluent seawater. No additional chemicals are required and there is normally no solid waste generated for disposal as the effluent is typically discharg ed directly to the sea. The pH of the effluent can be adjusted to within the original range in the neutralization step of the process.

The volume of seawater required vari es with exhaust flowrate and SO 2 

### loading in the gaseous exhaust stream. Based on a review of specifications for existing potline seawater scrubbing systems, the volumetric flowrate of seawater needed for proper operation of a seawater scrubber at Intalco would be approximately 2.2 million gallons of seawater per hour.

8 

### Information from the ALSTOM Seawater FGD – Environmental Impact website (www.environment.power.alstom.com/home/powe r/seawater_fgd/environmental_impact.htm)

9 

### Kwawaji, Akili D., et. al. 2005. “Seawater Scrubbing for the Removal of Sulfur Dioxide in a Steam Turbine Power Plant”. Proceeding of th e PWR2005 ASME Power Conference. April 5-7. Chicago, IL.Intalco BART Determination FINAL.doc 

### 5-7 

### A global review of feasible control tec hnologies identified s eawater scrubbing as having been installed at seven aluminum smelters, none of which are in the
United States 10 

### . Even though this technology has been identified as a control technology in operation at six primary al uminum ore reduction plants in Norway and one primary aluminum ore reduction plant in Sweden 11 

### , there are two reasons why this technology is not feasible at Intalco.

1) The Administrator of USEPA has issued environmental regulations establishing effluent limita tions guidelines (ELGs) pur suant to section 304(b) of the Clean Water Act for facilities producing primary metals from ore concentrates and recovering secondary metals from recycled wastes. The ELGs are for facilities that discharge or may discharge po llutants to waters of the United States or which introduce or may introduce pollu tants into a publicly owned treatment
works. Seawater scrubbers installed to abate SO 2 

### and other visibility impairing pollutants from the Intalco’s BART eligible potline emission units would be subject to the ELGs for “Potline SO 2 

### Emissions Wet Air Pollution Control.” 12 

### A
seawater scrubber installed downstream of the alumina dry scrubbers at Intalco
would remove both fluoride and SO 2 

### from the dry scrubber exhaust. The amount
of fluoride absorbed into the seawater would exceed the ELG, requiring treatment
of the seawater to remove fluoride before it could be discharged back into the sea. For example with three potlines operational, approximately 159 lb/day of fluoride would be absorbed by the s eawater and the applicable ELG would be 59.5 lb/day (monthly average). Removal of potline fluoride from the seawater scrubber effluent may be feasible, but would al so require precipitation of many other naturally occurring salts in the seawater (c hlorides, sulfates, ot her fluorides, etc.), resulting in the unnecessary generati on of large amounts of sludge for land disposal. Seawater scrubbing is, therefore, not a viable alternative for smelters in the United States, especially when comp ared with other scrubbing technologies that use fresh water and require treatmen t/disposal for only those salts present in the potline exhaust.

2) In addition to the regulatory restri ctions and economic viability issues discussed above, a seawater scrubber is infeasible for BART compliance due to permitting obstacles. The Washington State Environmental Policy Act (SEPA), Chapter 43.21C RCW was enacted in 1971, and it provides the framework for agencies to consider the environmental c onsequences of a proposal before taking

10 

### The HATCH Group. 2006. “ Analysis of Options for BART Compliance” . April 18. Page 4.

11 

### Ibid. Page 9.

12 

### 40 CFR 421.23(n)Intalco BART Determination FINAL.doc 

### 5-8 

### action. It also gives agencies the ability to condition or deny proposals due to adverse impacts identified as likely to occur as a result of a proposal. The portion of Puget Sound where seawater would be w ithdrawn and discharged for an Intalco seawater scrubber has been included as pa rt of the Cherry Point Aquatic Reserve
that was established in 2000. The Aquatic Reserves Program is part of the Washington Department of Natural Resources (DNR) efforts to promote preservation, restoration, and enhancemen t of state-owned aquatic sites that
benefit the health of native aquatic habitat and species in the state. The aquatic reserves established by DNR ar e aquatic lands of special educational or scientific interest, or lands of special environmenta l importance. The construction of intake and/or discharge structures within th e Cherry Point Aquatic Reserve would require an impact analysis, assessment, and DNR authorization of any environmental impacts associated with a seawater scrubbing sy stem. Since seven years have already passed since Cherry Point was designated as an aquatic reserve and the initial SEPA evaluation has yet to be completed, the time required to complete an analysis of the environmen tal impacts associated with a seawater scrubbing system and obtain the requisite authorizations for a system that withdraws seawater from and discharges scrubber liquor into the Cherry Point Aquatic Reserve would render this tec hnology infeasible for BART compliance.

5.1.3.1.1.5 Dual Alkali Sodium/Lime Scrubbing (Dilute Mode) Dual alkali sodium/lime scrubbing (dilute mode) uses a caustic sodium solution in the scrubber tower. A por tion of the scrubbing liqui d is discharged to a neutralization stage where lime slurry is used to regenerate the caustic, which is
returned to the scrubber. The bleed fr om the scrubber is se nt to a dewatering system to produce a gypsum byproduct. The process will produce either solid gypsum waste or commercial-grade gypsum suitable for reuse as a cement additive. It should be noted, however , that dual alkali sodium/lime scrubbing (dilute mode) is not currently marketed by major FGD vendors because the system is too complicated and expensive.

5.1.3.1.1.6 Conventional Sodium Scrubbing Globally, conventional sodium scrubbing has been installed in at least 12
aluminum smelters. An alkaline solution of either soda ash or sodium hydroxide is pumped into the scrubbing tower and r ecirculated through a network of spray nozzles. Atomized droplets cont act the up-flowing gas containing SO 2 

### . Where this technology has been deployed, the li quid effluent containi ng dissolved salts, including sodium and fluorides, has been di scharged into a large receiving stream or an open body of water without treatment.Intalco BART Determination FINAL.doc 

### 5-9 

### 5.1.3.1.2 Dry Scrubbing

5.1.3.1.2.1 Dry Injection In dry injection, a reactive alkaline powder is injected into a furnace, ductwork, or a dry reactor. Typical removal efficien cies with calcium adsorbents are 50 to 60% and up to 80% with sodium base adsorbents. However, as with wet scrubbing, disposal of waste using sodium adsorbents must consider their high solubility in water compared to those from calcium adsorbents. The temperature range over which scrubbing has been used is 300 to 1,800°F; the minimum temperature is 300 to 350°F. Dry syst ems are rarely used and according to USEPA only 3% of FGD systems installed in the United States are dry systems 13



### . The dry waste material is removed using pa rticulate control devices such a fabric
filter or an ESP.

Dry scrubbing downstream of the potline reactors and anode bake furnace fabric filters is not technically feasible because of the low temperatures (less than or equal to 205°F) and low SO 2 

### concentrations (less than or equal to 105 ppm).

5.1.3.1.2.2 Semi-Dry Scrubbing (Spray Dryer) Semi-dry scrubbing is more commonly re ferred to as spray drying. Calcium hydroxide slurry (lime mixed with water) is introduced into a spray dryer tower. Sodium compounds can be used, but as with the dry scrubber, th e high solubility of the sodium-based waste products in wate r complicates disposal of the waste. The slurry is atomized and injected into a reactor with the exhaust gases, where droplets react with SO 2 

### as the liquid evaporates. This system is categorized as a semi-dry system because the end product of the SO 2 

### conversion reaction is a dry material. The dry waste product is colle cted in the bottom of the spray dryer
reactor and a fabric filter or ESP dow nstream of the spray dryer removes the
CaSO 3 

### , CaSO 4 

### , and unreacted lime. This air pollution control system uses water for evaporative cooling and for the SO 2 

### reaction. It operates in a temperature range of 300 to 350°F because the temper ature of the gases must be high enough to evaporate the water portion of the slurry. Approximately 12% of the FGD systems installed in the United States are spray dry systems 14 

### with typical SO 2 

### removal efficiencies in the range of 80 to 90%. Unlike a we t scrubbing system there is no liquid blow-down stream from the dry system and the collected solids are typically landfilled.

13 

### USEPA. 2003. “Air Pollution Control Technology Fact Sheet – Flue Gas Desulfurization.” EPA-452/F-03-034. August 8.

14 

### Ibid.Intalco BART Determination FINAL.doc 

### 5-10 

### Spray dry scrubbing downstream of the pot line reactors and anode bake furnace fabric filters is not technically feasible because of the low temperatures (less than or equal to 205°F) and low SO 2 

### concentrations (less than or equal to 105 ppm).

5.1.3.2 Pollution Prevention The guidelines for BART determinations under the Regional Haze Rule recommend consideration of pollution prevention options in addition to add-on controls. The primary opportunity for pollution prevention in the smelting process to minimize SO 2 

### emissions is through limitations on the sulfur content in the incoming coke. Coke is a major raw material used in the manufacture of green a nodes. Green anodes are subsequently baked in a furnace prior to their use in the smelting process.

Intalco’s Title V operating permit currently ha s a number of operational limits that cap
allowable emissions of SO 2 

### from the facility, including: a net potline aluminum production limit of 307,000 t on/yr; a daily potline SO 2 

### limit of 37,780 pounds per day (lb/day); limits on sulfur in coke and pitc h at 3.0% and 0.6%, respectively; and a carbon consumption limit of 0.425 pounds of carbon per pound of aluminum produced.

During the BART process, Intalco evaluated the current levels of sulfur in coke used by
other aluminum smelters to determine whet her a pollution preventi on option using lower
sulfur content coke would be a feasible BA RT option. This analysis indicated that certain smelters currently utilize coke with sulfur contents as low as 2%. Given that
sulfur contents lower than the current Inta lco specification are uti lized, Intalco undertook a low sulfur coke availability analysis to determine whether coke at levels below 3% would be available beyond 2013 when BART controls requirements are anticipated. Confidential research information belonging to the market analysts assisting with the coke availability analysis is included in Appendix B . The primary conclusions from this analysis indicate that:

• 

### Coke is a byproduct of the oil refining pro cess. The sulfur content of the world’s crude oil supply has been and will continue increasing in sulfur content. Those refiners with coking capacity are mi nimizing their raw material costs by maximizing use of high sulfur crude oils and oil sands to the optimal extent for their overall refinery design. The result will be a continuing increase in the sulfur
content of available coke.

• 

### Coke is a relatively small, low revenue component of the refinery’s product profile. As such, the aluminum industry has little influence in controlling the quantity, quality, and price of th e coke produced by refineries.Intalco BART Determination FINAL.doc 

### 5-11 • 

### Anode grade (or anode quality) coke is a small subset of the total coke produced
world-wide. Growth in the aluminum industry has increased the demand for the limited quantities of anode grade coke and has driven prices for coke to unprecedented levels. Refining higher sulf ur crude oils and oil sands further shrinks this small subset of anode grade coke.

• 

### Prices for coke nearly doubled from 1994 to 2006.

• 

### The increased global growth in aluminum production will continue to outpace the production of coke.

• 

### Primary aluminum production is expected to grow at the rate of 3 to 4% annually, resulting in a commensurate growth in demand for anode grade coke.

• 

### Coke providers are blending imported, high cost, lower sulfur coke with domestically sourced coke in attempts to meet the current specification requirements for coke.

• 

### Removal or reduction of the sulfur content of the coke once it has been received is
not feasible.

• 

### Aluminum smelters are experimenting w ith alternative coke s and technologies that are outside of the traditional specifi cations to ensure continued aluminum production in the face of the changing char acteristics of this key raw material.

• 

### The deterioration in coke quality and the tightness of supply is expected to
continue for the foreseeable future.

• 

### The increased demand for coke will for ce the aluminum industry to accept lower quality coke with hi gher sulfur contents.

Based on the market and availability anal ysis of the future coke supply, Intalco
determined that it is infeasible to consider coke at sulfur contents below 3% as a BART pollution prevention option because a supply of coke with sulfur contents below 3% cannot be ensured beyond 2013 when BART cont rol requirements are anticipated. These same market pressures are expected to force facilities currently us ing coke with sulfur contents below 3% to begin using higher sulf ur content coke in the future. Although
coke at sulfur contents below 3% is considered infeasible due to availability concerns, a pollution prevention option that maintains Intalco’s current sulfur in coke limit of 3% is considered technically viable or feasible, assuming that sufficient imported lower sulfur
coke remains available to allow blen ding to 3% sulfur content beyond 2013.Intalco BART Determination FINAL.doc 

### 5-12 

### 5.1.3.3 Feasible Control Options from RBLC Database

A review of USEPA’s RACT/BACT/LAER Clearinghouse (RBLC) da tabase was also completed to determine which control technol ogies or techniques ha ve been utilized by primary aluminum ore reduction plants. The results from the RBLC database search are
summarized in Table 5-1.

The data in the RBLC database support the approach of limiting ra w material sulfur content as a control option for the potlines and the anode bake furnace. Many facilities
have limited sulfur content in coke to limit SO 2 

### emissions. Two facilities have limits of
3% sulfur content in coke and one has a 2.95% sulfur content limit. One facility is shown
in the RBLC to have a wet scrubber to control SO 2 

### emissions; however, an investigation revealed that the wet scrubber was not requi red as part of a be st available control technology (BACT) determination and that th e facility currently does not operate a wet
scrubber to control SO 2 

### emissions. That facility’s current Title V permit for “Potline 5” simply limits coke sulfur content to 3% and coal tar pitch sulfur to 0.8%.

Dry alumina scrubbers (with fabric filters) ar e the controls that have been considered
BACT for PM.

5.1.4 Potentially Applicable BART Control Options for PM Potentially applicable PM em ission controls are discusse d in the following sections.

5.1.4.1 Fabric Filters Fabric filters generally prov ide high collection efficiencies for both coarse and fine (submicron) particles. They are relatively insensitive to fluctuations in gas stream conditions. Efficiency is relatively unaffected by large changes in inlet dust loadings. Filter outlet air is very clean 15 

### . Collected material is dry, whic h usually simplifies processing or disposal. Fabric filters ar e currently applied for controlling PM em issions from the potrooms and the anode bake furnace at Intalco.

5.1.4.2 Electrostatic Precipitators ESPs are capable of very high removal e fficiencies for large and small particles 16 

### . They offer control efficiencies that are comparable to fabric filters. B ecause of their modular design, ESPs, like fabric filters, can be applied to a wide range of system sizes. The operating parameters that influence ESP performance include fly ash mass loading, particle size distribution, fly as h electrical resistivity, and preci pitator voltage and current.

15 

### USEPA. 2003. “Air Pollution Control Technology Fact Sheet – Fabric Filter.” EPA-452/F-03-025. August 7.

16 

### USEPA. 2003. “Air Pollution Control Technology Fact Sheet – Dry Electrostatic Pr ecipitator.” EPA-452/F-03- 028. August 7.Intalco BART Determination FINAL.doc 

### 5-13 

### Dusts with high resistivities are not well-su ited for collection in dry ESPs because the particles are not easily charged. This also affects the ash layers on the collecting
electrodes. An ESP is techni cally feasible for control of PM from the potrooms and the
anode bake furnace at Intalco.

5.1.4.3 Cyclones, Inertial Separators, and Wet Scrubbers Cyclones and inertial separators are used for collection of medium-sized and coarse particles. Wet scrubbers generally remove la rge particles but can remove small particles with the use of high pressure drops. However, none of these devices are as effective at removing small and submicron particles as fabric filters and ESPs 17



### .

5.1.5 Potentially Applicable BA RT Control Options for NO x 

### Potentially applicable NO x 

### emission controls in clude combustion controls and post-combustion
controls.

5.1.5.1 Combustion Controls

The concentration of NO x 

### in the potroom reactor exhaust is extremely low (less than 1 ppm) because there is no external fuel or combustion zone and there are no large sources of nitrogen in the raw materials. Traditional methods of preventing NO x 

### formation using staged combustion or low NO x 

### burners are not applicable to the potlines at Intalco.

NO x 

### emissions from anode baking depend on operating practices and burner controls. The traditional methods of preventing NO x 

### formation using staged combustion or low
NO x 

### burners are not appli cable because of the unique conf iguration of an anode baking ring furnace, with fuel injected at several points in narrow flues. However, advanced firing systems that measure and regulate fuel flow precisely using a computerized control system may reduce NO x 

### emissions by reducing total fuel usage. Prevention of NO x 

### formation using advanced firing control is tech nically feasible for the anode bake furnace
at Intalco.

5.1.5.2 Post-Combustion Controls Selective non-catalytic reduction (SNCR), se lective catalytic reduction (SCR), and low temperature oxidation (LoTOx) controls are discussed in this section.

5.1.5.2.1 Selective Non-Catalytic Reduction SNCR is an add-on technique that involves injecting ammonia or urea into a specific temperature zone in a furnace or boiler. The ammonia or urea reacts with NO x 

### in the gas to produce nitrogen and water. SNCR typically provides a NO x 

### reduction of 30 to 50%.Intalco BART Determination FINAL.doc 

### 5-14 

### The effectiveness of SNCR depends on the te mperature where reagents are injected, mixing of the reagent in the gas, residence time of the reagent within the required temperature window, and the ratio of reagent to NO x 

### . The required temperature window is 1,600 to 2,100°F. Typical uncontrolled NO x 

### levels where this technology has been applied vary from 200 to 400 ppm. SNCR is less effective at lower levels of uncontrolled
NO x 18



### .
The temperature (approximately 200°F) and NO x 

### concentration (less than 1 ppm) of the potroom emission exhaust are outside the le vels where SNCR could be used. Thus, SNCR is not technically feasible for the potlines at Intalco.

The temperature of the anode baking emi ssion exhaust (300 to 450°F) is below the temperature where SNCR could be used. Down stream of the reactor where tar vapors are removed, the temperature is approximately 200° F, which is also below the appropriate range. In addition, the NO x 

### concentration (less than 20 ppm) is below the level where SNCR could be used. Thus, SN CR is not technically feasible for the anode bake furnace
at Intalco.

5.1.5.2.2 Selective Catalytic Reduction SCR is an add-on technique similar to SNCR that involves injecting ammonia into flue gas in the presence of a meta l-based catalyst to convert NO x 

### emissions to elemental nitrogen and water. The catalyst allows SCR systems to operate at much lower temperatures than SNCR; typical temperatur es for SCR are 500 to 800°F, compared with 1,600 to 2,100°F for SNCR. The optimum temperature range is 700 to 750°F 19 

### . SCR is capable of NO x 

### reduction efficiencies in the range of 70 to 90% and can be used with
NO x 

### concentrations as low as 20 ppm. However, higher NO x 

### levels result in increased performance 20



### .
The temperature of the potroom emissi on exhaust (approximately 200°F) and NO x 

### concentration (less than 1 ppm ) of the potroom emission exhaust are outside the levels where SCR could be used. Thus, SCR is no t technically feasible for the potlines at
Intalco.

The temperature of the anode baking emi ssion exhaust (300 to 450°F) is below the temperature where SCR could be used. Downst ream of the reactor where tar vapors are

17 

### AWMA. 2000. Air Pollution Engineering Manual , Second Edition.

18 

### USEPA. 2003. “Air Pollution Control Technology F act Sheet – Selective Non-Ca talytic Reduction.” EPA452/F-03-031. August 8.

19 

### USEPA. 2002. EPA Air Pollution Control Cost Manual , Sixth Edition. EPA/452/B-02-001. January.

20 

### USEPA. 2003. “Air Pollution Control Technology F act Sheet – Selective Catalytic Reduction.” EPA-452/F-03- 032. August 8.Intalco BART Determination FINAL.doc 

### 5-15 

### removed, the temperature is approximately 200° F, which is also below the appropriate range. In addition, the NO x 

### concentration (less than 20 ppm) is below the level where SCR could be used. Thus, SCR is not technica lly feasible for the anode bake furnace at
Intalco.

5.1.5.2.3 Low-temperature Oxidation Technology (LoTOxTM) The LoTOxTM system is the patented t echnology of BOC Gases. In this NO x 

### removal system, ozone is injected into the exhaust gas stream in order to oxidize insoluble NO x 

### to soluble nitrogen compounds, including N 2 

### O 5 

### . N 2 

### O 5 

### is highly soluble and reacts with moisture in the gas stream to form nitric ac id. A scrubber is required downstream of the LoTOxTM system to remove the nitric acid formed by the reaction of N 2 

### O 5 

### and moisture in the gas stream. The ozone is typically generated on site and on demand. Since LoTOxTM is a low temperature system it does no t require heat input and the low operating temperature (150 to 250°F) allows for stable an d consistent control ev en with variations in flow, load, and NO x 

### concentrations 21



### .
Use of the LoTOxTM system has not been demons trated at an aluminum plant. Research indicates that application of the LoTOxTM t echnology has been limite d to a sulfuric acid regeneration plant, a lead smelting reverbatory furnace, a stainless steel plant, a coal-fired electric generation unit, a nd two fluidized-bed catalytic cracking units (FCCU) at
refineries 22,23 

### . Reported NO x 

### removal efficiencies for the LoTOxTM system are on the
order of 90% to 95%.

The temperature of the anode baking emissi on exhaust (approximately 200°F) is within the temperature range where LoTOxTM could be used. Although th is technology has not
been demonstrated on an anode bake furn ace, low-temperature oxidation technology may be technically feasible for reducing anode bake furnace NO x 

### emissions.

5.1.6 Summary of Technically Feas ible BART Control Options

5.1.6.1 Feasible BART Control Options for SO 2 

### Two technically feasible options were identified for controlling SO 2 

### emissions from the potlines and anode bake furnace:

• 

### Adding a wet scrubber to th e potline and/or anode bake furnace exhausts, and

21 

### BOC Process Gas Solutions. 2001. Low Temperature Oxidation System Demonstration at RSR Quemetco, Inc., City of Industry, California. June 28. (www.arb.ca.gov/ research/icat/pro jects/boc.pdf)

22 

### USEPA. 2005. “Using Non-Thermal Plasma to Control Air Pollutants”. EPA-456/R-05-001. February. www.epa.gov/ttn/catc/dir1/fnonthrm.pdf

, 23 

### USEPA RACT/BACT/LAER Clearinghouse (RBLC) database.Intalco BART Determination FINAL.doc 

### 5-16 • 

### A pollution prevention option limiting the su lfur content in the coke used to produce anodes to 3.0%.

These two options were evaluated further as part of the BART determination analysis.

5.1.6.2 Feasible BART Control Options for PM Cyclones, inertial separators, wet scrubbers, ESPs, and fabric filters are all technically feasible for controlling potroom PM emissions. However, ESPs and fabric filters are superior devices for controlling fine PM.

Fabric filtration with dry alumina scrubbi ng has been widely used in the primary aluminum industry. Most smelters constructe d within the past 20 years have used dry alumina scrubbing with fabric filters to contro l emissions from potlines. A few plants use control systems consisting of ESPs to coll ect PM followed by spray towers to scrub gaseous fluoride. Wet systems have ma ny disadvantages, such as corrosion by hydrofluoric acid, scaling, and the requirement to treat wastewater. ESPs and wet systems are no longer installed on new smelters 24



### .
Dry scrubbers are widely used on anode bake furnaces because they provide effective removal of hydrocarbons, fluorides, and PM. Wet systems have the same disadvantages for anode bake furnaces as for potlines: corrosion by hydrofluoric acid, scaling, and the requirement to treat wastewater. Dry scrubbers with fabric filters are a superior choice
for anode bake furnaces.

Given that fabric filters are already used for PM control a nd that these high-efficiency devices are superior or equal to other feasible c ontrol options, no further analysis of PM controls was performed.

5.1.6.3 Feasible BART Control Options for NO x 

### Since there is no external fuel or combus tion zone in the smelting cells, there are no technically feasible pre-combustion NO x 

### controls. Likewise, there are no technically feasible add-on controls because of the temperature of the potroom exhaust (approximately 200°F) and low NO x 

### concentration (less than 1 ppm).

Advanced firing systems may prevent NO x 

### formation by reducing natural gas usage and are technically feasible for the anode bake furnace. Add-on SCR and SNCR controls are
not feasible at the furnace exhaust because of the temperature (less than 450°F) and presence of tar vapor. SCR and SNCR ar e not feasible downstream of the reactor because of the temperature (a pproximately 200°F) and low NO x 

### concentration (less than

24 

### Air and Waste Management Association (AWMA). 2000. Air Pollution Engineering Manual , Second Edition.Intalco BART Determination FINAL.doc 

### 5-17 

### 20 ppm). The use of low temperature oxidati on (LoTOxTM) may be a viable option for reducing NO x 

### emissions if a wet scrubber were installed on the bake furnace for SO 2 

### control.

The option for reducing NO x 

### formation through advanced firing systems for the anode bake furnace was evaluated further as part of the BART determination analysis. Further consideration was also give n to the potential use of low temperature oxidation (LoTOxTM).

5.2 C ONTROL 

### E FFECTIVENESS OF 

### F EASIBLE 

### O PTIONS 

### Step 3 of the BART analysis is to evaluate the control effectiveness of the technically feasible control technologies.

5.2.1 SO 2 

### Wet Scrubbing A wet scrubber was identified as a technically feasible add-on pollution control option to
reduce SO 2 

### from the potline reactors. Typical removal efficiencies are 80 to 95%. Capital cost estimates and control efficien cies for wet scrubbers at Intalco were developed by scaling costs fr om two vendor quotes obtained for the in stallation of LSFO scrubbing technology at Alcoa’s fa cility in Alcoa, Tennessee. Each of the vendors that provided proposals for the Tennessee f acility indicated that a 95% SO 2 

### removal was technically feasible. Accordingly, an SO 2 

### removal efficiency of 95% was used in the Intalco BART analysis for the wet scrubber control option.

Mist droplets will be a compone nt of the gas stream emitted from the scrubber. Solids in the droplets will become airborne PM when th e water in the droplets evaporates. The PM
concentration in the outlet of the wet scrubber was predicted to be 20 mg/Nm 3 

### by one of the vendors. This compares to a concentration of 10 mg/Nm 3 

### currently emitted from the existing potline control system. Conseque ntly, the wet scrubber option would cause a collateral increase in PM from the potlines.

A wet scrubber was also identified as a te chnically feasible a dd-on pollution control option for the anode bake furnace since it has an SO 2 

### concentration and a temperature similar to the potline reactor exhaust. However, the anode bake furnace is a smaller source than the potlines because of the lower exhaust gas flow rate (1,950,000 acfm versus 202,500 acfm). A separate vendor cost proposal was not obta ined for the anode bake furnace, but an SO 2 

### removal efficiency of 95% is assumed to be feasible. Wet
scrubber costs for the anode bake furnace we re also scaled from the LSFO potline wet scrubber vendor quotes.Intalco BART Determination FINAL.doc 

### 5-18 

### Table 5-2 summarizes the SO 2 

### , NO x 

### , and PM emission levels under the control scenarios considered for BART. The emissions represent the combined total emissions from the primary and secondary potline control syst ems and the anode bake furnace for each scenario. Control scenario #1 is the addition of a wet scrubber to the potline reactors.
Control scenario #2 is the addition of a we t scrubber to the anode bake furnace. The current potential emissions with 3.0% sulf ur coke are also listed. The emissions
reductions achievable for each of the scenar ios were compared to current potential
emissions.

5.2.2 SO 2 

### Pollution Prevention The pollution prevention option re presents a 3.0% sulf ur limit in the coke used to produce anodes. This option reflects the current sulfur limit in Intalco’s Title V operating permit.

5.2.3 Anode Bake Furnace Advanced Firing System

NO x 

### emissions from the anode bake furnace could be reduced by incorporating an advanced firing system. Total gas usage is projected to be reduced by 20%, which would result in a corresponding 20% reduction in NO x 

### emissions, or approximately 27 tons/year.

5.2.4 Anode Bake Furnace LoTOx TM 

### System

NO x 

### emissions from the anode bake furnace coul d potentially be reduced by using the LoTOx TM 

### system for post-combustion contro l. This technology has a cont rol efficiency of 90% for NO x 

### emissions when combined with wet scrubbi ng, resulting in a potential reduction in NO x 

### emissions of approximately 122 tons/year.

5.3 E VALUATION OF 

### C OSTS AND 

### O THER 

### I MPACTS 

### Step 4 of the BART analysis involves evaluati on of cost and other impacts, including energy impacts, greenhouse gas generation, non-air quality environmental impacts, and remaining useful life. Costs of control, energy impacts, greenhouse gas generation impacts, non-air quality environmental impacts, and remaining usef ul life are evaluated in this section.

5.3.1 Cost Impacts for Feasible Controls

5.3.1.1 Wet Scrubbers The exhaust gases from each potline are routed to dry alumina reactors. Potline gases currently exhaust to atmosphere from stacks above the fabric filters in each of the six baghouse scrubbing centers, which are located in courtyards between the potrooms.

Wet scrubber costs for Intalco were estimated based on cost quotes received by Alcoa from two flue gas desulphurization equipmen t vendors. The cost quotes were originally provided as part of the BART analysis for Alcoa’s Tennessee Operations in Alcoa, TN.Intalco BART Determination FINAL.doc 

### 5-19 

### Both vendors provided cost proposals for wet scrubbing systems based on limestone forced oxidation (LSFO) SO 2 

### scrubbers. Lime- or sodium-b ased scrubbers could also be used for potlines, but lime and sodium are less desirable reagents considering that these reagents are much more expensive. An advantage of the limestone forced oxidation process is that the spent slurry is oxidized to gypsum, which dewaters more efficiently, resulting in less waste materials requiring disposal. Thus, an LFSO scrubber was determined to be the most appropriate cont rol device for the cost analysis. The vendor proposals are provided in Appendix B. These proposals contain confidential business information and are, therefore, labeled as confidential.

Neither of the two vendors provided a compre hensive installed cost estimate. Both preliminary designs were based on a central scrubbing center as the least cost approach, where exhaust from all dry scrubbing systems would be ducted to a centralized scrubbing system. Both design estimates were ba sed on systems that would provide 100% availability of emissions control on each day of the year, given that potlines cannot be easily shutdown and restarted for control system outages.

One vendor provided an estimate of the scrubbe r equipment only. The other provided an “indicative price,” with an inst alled cost assumed equal to th e equipment cost. Important retrofit considerations for installing a potlin e wet scrubbing system include: (1) that gases must be collected from multiple indivi dual baghouse stacks, (2) the system must simultaneously maintain balanced flow from multiple potline control devices, and (3) the system installation would require transpor t of new components through narrow passages in the existing potline. Coordination of the equipment delivery and the daily work schedule of the potline operation would also a ffect the control system installation. One of the vendors recognized the co mplexity of this project, poi nting out in their proposal that an extensive engineering effort was needed because of space limitations, access limitations, uncertainty as to laydown areas, and uncertainty of ductwork and supports. These retrofit issues would apply equally to both the Alcoa, TN facility and Intalco.

The vendor cost proposals for the Tennessee fa cility were based on a total scrubber exit gas volume of approximately 1,580,000 acfm at 101 o 

### F compared to a design exit gas volume of approximately 1,950,000 acfm at 98 o 

### F for Intalco. Vendor equipment cost proposals for the Alcoa, TN facility ther efore had to be adju sted to account for differences in exhaust gas volume and other design parameters.

Hatch, an engineering firm contracted by Alco a, prepared a pre-feasibility report for Intalco in which equipment costs provided by one of the vendors for the Alcoa, TN facility were scaled or adjusted to estim ate LSFO equipment costs for Intalco. The procedure used by Hatch adjusted equipment cost estimates using appropriate exponentialIntalco BART Determination FINAL.doc 

### 5-20 

### factors for equipment type (reagent feed, SO 2 

### removal, gas handling, etc.), along withdifferences in system exhaust gas volume, limestone consumption, and gypsum byproduct generation. ENVIRON used the cost adjustment approach developed by Hatch to prepare an average equipment cost ba sed on both vendor quotations. The equipment cost scaling procedures are out lined in the Hatch report in Appendix C and ENVIRON’s parallel calculations based on the average of the two vendor quotes are provided in Appendix D

.
The average scrubber equipment cost was used with factors from the EPA Air Pollution
Cost Control Manual 25 

### to determine installation costs and total capital costs. Operating costs were calculated based on utility and raw material requirements provided by Hatch, along with unit cost information provided by In talco and other cost assumptions from the
EPA Air Pollution Cost Control Manual . Complete cost calcul ations and assumptions are provided in Appendix D

.
Separate vendor cost quotes were not obtained for installing a wet SO 2 

### scrubbing system on the anode bake furnace. Instead, the potline SO 2 

### scrubber equipment costs were
scaled to estimate Intalco anode bake cont rol equipment costs usi ng the same approach discussed above for the potlines. The anode bake wet scrubber de sign was based on a scrubber exhaust gas volume of 202,500 acfm at 98 o 

### F. The vendor equipment costs were adjusted using exponential factors that acc ount for differences in exhaust gas volume, limestone consumption, and gypsum by-product generation.

Table 5-3 summarizes the cost of installi ng and operating an LSFO wet scrubber on the Intalco potlines and anode bake furnace to remove 95% of the SO 2 

### . The capital and total annualized costs for a potline wet scrubber are high at approximately $234.5 million and $46.8 million per year, respectively. The wet scr ubber cost effectiveness is also high at $7,500 per ton of SO 2 

### removed.

The estimated installed capital cost to a dd a wet scrubber to remove 95% of the SO 2 

### from
the anode bake furnace exhaus t would be approximately $29.5 million with an annualized cost of $6.3 million per year. The wet scrubber cost effectiveness is also high at $36,400 per ton of SO 2 

### removed.

5.3.1.2 Coke Sulfur Limit Intalco is currently able to obt ain coke with 3.0% sulfur without incurring significant additional cost. However, as low sulfur coke becomes more difficult to pr ocure, the cost will increase. Additional information regarding low sulf ur coke availability is included in Appendix B

.

25 

### USEPA. 2000. EPA Air Pollution Cost Control Manual , Sixth Edition. EPA-452/B-02-001. January 2002 (and updates).Intalco BART Determination FINAL.doc 

### 5-21 

### 5.3.1.3 Anode Bake Furnace LoTOx TM 

### System

Cost data for the LoTOx TM 

### system is not readily available. However, as demonstrated above for
the control of SO 2 

### emissions from the anode bake furnace, the cost of the downstream scrubber required for the use of the LoTOx TM 

### system would make this option cost prohibitive. NO x 

### emissions are lower than SO 2 

### emissions for the anode bake furnace, so the cost per ton values for
NO x 

### would be even higher than for SO 2


### .

5.3.2 Energy Impacts

A wet scrubber removes SO 2 

### by forcing the exhaust gas through a spray tower or absorber where it contacts water droplets that contain the unre acted lime or limestone. Energy is required to overcome the resistance of the scrubber compone nts as well as falling water droplets. A substantial amount of energy would be associated with fans to move the potline and anode bake furnace exhaust streams through scrubbers. Othe r energy is required for the slurry pumps, instrumentation, and miscellaneous items (e .g., lighting). The total energy required 26 

### would be approximately 7,400 kilowatt-hours (kWh)/hr for the potline scrubber and 750 kWh/hr for the anode bake furnace scrubber. As listed in Table 5-3, this is equivalent to 64,824,000 kWh of electricity per year for the potline scrubber. A wet scrubber on the anode bake furnace would add 6,570,000 kWh per year.

5.3.3 Greenhouse Gas Generation Greenhouse gases (GHGs) are gaseous compounds that are known to provide a warming effect to the atmosphere. The predominant GHG is carbon dioxide (CO 2 

### ). Other GHGs include nitrous oxide and methane. The proposed SO 2 

### control devices will increas e overall emissions of GHGs via three mechanisms: (1) as a byproduct of the reaction chemistry in the scrubbers, (2) as indirect emissions from the generation of electri city required to power the scrubbing systems, and (3) as direct emissions from vehicle travel for the additional personnel that will be required at the facility to maintain and operate the scrubbing systems. The details of the GHG emission calculations for each of these mechanisms are presented in the Appendix E

.

The total GHGs (in carbon dioxide equivalents) generated by th e implementation of the proposed scrubbing system for the potline fumes was estimated to be 96,441 pounds per day, or 17,597 tons per year. The total GHGs (in carbon dioxide equivalents) generated by the implementation of the proposed scrubbing system for the anode baking furnace was estimated to be 7,298 pounds per day, or 1,330 tons per year.

5.3.4 Non-Air Quality Environmental Impacts Both of the wet scrubber proposals were based on the LSFO process. This process oxidizes the spent slurry to gypsum, which may be landfilled or commercially sold. There is no way to knowIntalco BART Determination FINAL.doc 

### 5-22 

### at this time whether the gypsum would have commercial value or whether there would be any demand for it. Therefore, it must be assumed that 27,130 tons of waste from a potline wet
scrubber and 639.5 tons of waste from an anode bake furnace wet scrubbe r would be landfilled each year.

It is estimated that 182.5 million gallons of water will be required annually to operate the potline wet scrubber at a cost of approximately $97,000. This will significantly impact the community infrastructure in that this will increase Intalco’s daily water demand by approximately 9% 27



### .
It is also estimated that a total of approxima tely 71.4 million kWh would be needed to operate the potline and anode bake furnace scrubbers annua lly. This would impact power demand in the community and would also have an environmenta l impact due to power production equivalent to adding approximately 6,700 new households in the community 28



### .

5.3.5 Remaining Useful Life The Intalco smelter has been in operation si nce 1966 and remains a cr itical component of Alcoa’s aluminum production in th e United States. The facility intends to be in operation throughout the period of the Regional Haze Program.

5.4 E VALUATE 

### V ISIBILITY 

### I MPACTS 

### Step 5 of the BART analysis involve s evaluation of visibility impact s. More specifically, this is an evaluation of the potential improvement in vi sibility resulting from application of feasible pollution prevention/add-on control options. Refined CALPUFF modeling was performed for
two control scenario s: one with wet SO 2 

### scrubbing applied to the potline and one with wet SO 2 

### scrubbing applied to the anode bake furnace. This modeling was accomplished according to State of Washington’s BART modeling protocol 29 

### . In general, this modeling was the same as the baseline modeling except stack data and emission data associated with the application of the
feasible add-on controls were used as model inputs. Table 5-4 presents the post-control modeling source input data that we re used in the CALPUFF model to forecast visibility impacts for the two control options.

Table 5-5 presents the results of modeling with the two scrubber SO 2 

### control scenarios along with baseline impacts. As shown in Table 5-5, the addition of a potline wet scrubber reduced

26 

### Hatch. 2007. SO 2 

### Scrubbing for the INTALCO Primary Alum inum Smelter: Pre-Feasibility Report. July 26.

27 

### Based on average facility incoming water flow rates for 1998 through 2000, the th ree most recent years the facility was at full production.

28 

### Calculated based on 2001 average energy usage per hou sehold for the United States as reported by the Department of Energy ( http://www.eia.doe.gov/emeu/reps/enduse/er01_us_tab1.html ).

29 

### Modeling Protocol for Washington, Oregon, and Idaho: Protocol for the Application of the CALPUFF Modeling System Pursuant to the Best Available Retrofit Technology (BART) Regulation. October 11, 2006. www.deq.state.or.us/aq/h aze/docs/bartprotocol.pdfIntalco BART Determination FINAL.doc 

### 5-23 

### modeled visibility impacts in all five Class I areas to between approximately 0.1 and 0.35 dv for the three years modeled. For example, the baselin e modeling results indicate that the highest 98 th 

### percentile visibility imp act from Intalco’s BART-eligible sour ces at Olympic National Park with
3% sulfur in the coke was 1.527 dv. The post-control modeling resu lts indicate that the highest
98 th 

### percentile visibility impact from Intalco’s BART-eligible sources at Olympic National Park with wet scrubbers installed on the potlines was 0.355 dv in 2003. This represents a 1.17 dv reduction in total facility visibility impacts at Olympic National Park with the addition of wet scrubbers on the potlines.

The modeled visibility improvements shown in Table 5-5 from adding a wet scrubber at the anode bake furnace are minimal, with impr ovements ranging from approximately 0.004 to 0.024 dv compared to the baseline conditions. For exam ple, the post-control modeling results for the anode bake furnace indicate a highest 98 th 

### percentile visibility impact of 1.503 dv compared to the baseline value of 1.527 dv in 2003. This represen ts less than a 2% reduction in total facility visibility impacts at Olympic Na tional Park with the addition of wet scrubbers on the anode bake
furnace.

For NO x 

### , the use of an advanced firing system or LoTOx TM 

### technology for the anode bake furnace would also result in minimal improvements in visibility. The baseline visibility modeling indicated th at the highest 98 th 

### percentile visibility impact due to anode bake furnace
NO x 

### emissions was approximately 0.03 dv (55% of 0.053 dv). Therefore, a 20% reduction in
NO x 

### emissions from the anode bake furnace with th e use of an advanced firing system would reduce Intalco’s total visibility impacts by a pproximately 0.006 dv and a 90% reduction with the
use of LoTOx TM 

### would reduce the impacts by approximately 0.027 dv. Based on the minimal change in visibility forecast resulting from the in stallation of an advanced firing system or use of
LoTOx TM 

### , it was determined that neither of these t echnologies represents reasonably effective BART control technologies for the anode bake furnace.Intalco BART Determination FINAL.doc 

### 6-1 

## 6.0 DETERMINATION OF BART

6.1 A LUMINUM 

### P OTLINES 

### For potline SO 2 

### emissions, BART was determined to be the current level of control, which is a pollution prevention limit of 3% sulfur in the coke used to manufacture anodes. A pollution prevention limit based on coke sulfur contents below 3% was determined by Intalco to be infeasible as BART for 2013 and beyond based on a ma rket and availability analysis for future coke supply. Use of wet scr ubbing technology to reduce potline SO 2 

### emissions was rejected as
BART due to excessive costs: total co st effectiveness of $7,500 per ton of SO 2 

### removed and capital and total annualized costs of $234.5 m illion and $46.8 million per year, respectively. A potline wet scrubber would also have substantial secondary impacts, including increased energy usage of 64,824,000 kWh of electricity per year , added water consumption of 183 million gallons per year, and solid waste generation of 27,000 tons per year.

For PM emissions, BART was determined to be the current level of control, which is the use of baghouses to control PM emissions from the alum ina dry scrubbers and wet roof scrubbers to control secondary PM emissions from the potroom roofs.

There are no feasible technologies for control of NO x 

### from the potlines; thus, BART for NO x 

### was determined to be no controls.

6.2 A NODE 

### B AKE 

### F URNACE 

### A pollution prevention limit of 3% sulfur in the c oke was also determined to be BART for anode
bake furnace SO 2 

### emissions. The cost of wet scrubbing to reduce SO 2 

### emissions would be excessive at $36,400 per ton of SO 2 

### removed while providing minimal visibility improvement.

The existing level of control (based on baghouses on the alumina dry scrubbers) was determined
to be BART for PM emissions.

BART for anode bake furnace NO x 

### emissions was determined to be no controls. The use of an advanced firing system for reduced energy use was rejected as BART because the technology would result in negligible visibility imp rovement. Similarly, the use of LoTOx TM 

### was rejected as BART because the cost of the technology would be excessive and result in negligible visibility improvement.Intalco BART Determination FINAL.doc 

### 6-2 

### 6.3 A LUMINUM 

### H OLDING 

### F URNACES 

### BART for the aluminum holding furnaces was dete rmined to be no controls. The use of additional controls was rejected as BART because any visibility improvement would be negligible.

6.4 M ATERIAL 

### H ANDLING AND 

### T RANSFER 

### O PERATIONS 

### PM emissions from the BART-eligible materi al handling and transfer operations are all controlled using fabric filter tec hnology. This existing level of em issions control was determined
to be BART for these material ha ndling and transfer operations.

# TABLESProcess
Number Emission Unit
ID Emission Unit Description Visibility Impairing
Pollutants Existing
Pollution Controls Modeling Source Type

5 181-186 Potline primary emission control system stacks PM, SO
x Reactor/
Fabric Filter Point

5 22-180 Potline secondary emission control system stacks PM, SO
x Roof Water
Scrubbers Line

3 187 Anode bake furnace PM, SO
x , NO
x Reactor/
Fabric Filter Point

6 4, 5, 7, 8, 10, 11, 13, 14, 16-19 Aluminum holding furnaces PM Fabric Filter Point

2 188 Paste plant baghouse stack PM Fabric Filter Point 2 189 Phase A ball mill baghouse stack PM Fabric Filter Point 2 191 Phase B ball mill baghouse stack PM Fabric Filter Point

7 195 Primary WTP kiln wet scrubber PM Wet Scrubber Point

4 198 Rod shop (west) baghouse stack PM Fabric Filter Point 4 199 Rod shop (east) baghouse stack PM Fabric Filter Point 7 208 Ladle cleaning baghouse stack PM Fabric Filter Point 7 209 Autogenous mill baghouse stack PM Fabric Filter Point 7 210 TAC station baghouse stack PM Fabric Filter Point
6 217 Remelt furnace stack PM Point 2 232 Butts baghouse stack PM Fabric Filter Point 4 260 Aluminum spray cyclone stack PM Point 4 312 Rod shop induction furnace (east) stack PM Point 4 313 Rod shop induction furnace (west) stack PM Point 2 316 Pitch fume treatment system PM Point 3 251 Anode bake building monitor roof PM Volume
3 252 Anode block hole blower PM Volume 4 257A Rod shop crust recovery discharge to trucks from bins #1 and #2 PM Volume 4 257B Rod shop crust recovery discharge to trucks from bins #1 and #2 PM Volume 4 259A Rod shop carbon recovery discharge to trucks from bins #1 and #2 PM Volume 4 259B Rod shop carbon recovery discharge to trucks from bins #1 and #2 PM Volume 7 280 Annex cathode assembly area roof vents PM Volume 7 282 Annex ramming paste area roof vents PM Volume
1 239 Paved road vehicle dust emissions PM Area 1 241 Facility-wide natural gas combustion PM, SO
x , NO
x Area 7 273 Alumina ore handling fugitive dust PM Area

1 233 General welding PM Volume (combined)

1 240 Fugitive dust from loading and dumping waste PM Volume (combined)

1 242 Plant-wide propane combustion emissions PM, SO
x , NO
x Volume (combined)

2 190 Phase "A" mixer fugitives PM Volume (combined)

2 192 Phase "B" mixer fugitives PM Volume (combined)

2 193 KVS ball mill baghouse stack PM Fabric Filter Volume (combined)

2 194 Pet coke baghouse stack PM Fabric Filter Volume (combined)

2 243 Paste plant roof vents PM, SO
x , NO
x Volume (combined)

2 244 Phase "A" paste cooling conveyor fugitives PM Volume (combined)

2 245 Phase "B" paste cooling conveyor fugitives PM Volume (combined)

2 248 Scrap paste storage bins PM Volume (combined)

2 249 Paste plant vacuum system baghouse stack PM Fabric Filter Volume (combined)

3 250 Packing coke silo vent PM Volume (combined)

4 253 Rod shop roof vents (north) PM Volume (combined)

4 254 Rod shop roof vents (south) PM Volume (combined)

4 255 Hot anode butts transport PM Volume (combined)

4 256A,B Rod shop crust recovery discharge to storage bins #1 and #2 PM Volume (combined)

4 258A,B Rod shop carbon recovery discharge to storage bins #1 and #2 PM Volume (combined)

4 263 Cooling of cast iron dross sows outside rod shop PM Volume (combined) Table 3-1 Primary Aluminum Reduction Emission Units
Alcoa Intalco Works Ferndale, WashingtonProcess
Number Emission Unit
ID Emission Unit Description Visibility Impairing
Pollutants Existing
Pollution Controls Modeling Source Type Table 3-1 Primary Aluminum Reduction Emission Units
Alcoa Intalco Works Ferndale, Washington

5 238 Auxiliary diesel generators PM, SO
x , NO
x Volume (combined)

6 3, 6, 9, 12, 15 Casting pit steam exhaust stacks PM Volume (combined)

6 21 Pigger cooling conveyor exhaust stack PM Volume (combined)

6 220a, 220b, 221a, 221b MHD holding furnaces PM Volume (combined)

6 266 Casthouse monitor roof PM Volume (combined)

6 269 Pigger aluminum furnace door exhaust hood PM Volume (combined)

6 315 Dross/silicon storage baghouse PM Fabric Filter Volume (combined)

7 196 Primary WTP reclaimed storage silo baghouse stack PM Fabric Filter Volume (combined)

7 206 Pangborn baghouse stack PM Fabric Filter Volume (combined)

7 207 Annex paste plant baghouse stack PM Fabric Filter Volume (combined)

7 211 Alumina ore silo #1 baghouse stack PM Fabric Filter Volume (combined)

7 212 Alumina ore silo #2 baghouse stack PM Fabric Filter Volume (combined)

7 213 Alumina ore silo #3 baghouse stack PM Fabric Filter Volume (combined)

7 214 Alumina ore silo #4 railcar unloader baghouse stack PM Fabric Filter Volume (combined)

7 215 Alumina ore pier-head transfer point baghouse stack PM Fabric Filter Volume (combined)

7 216 Alumina ore ship unloading baghouse stack PM Fabric Filter Volume (combined)

7 226 Aluminum fluoride silo baghouse stack PM Fabric Filter Volume (combined)

7 228 Covered annex bunkers for crust and digout PM Volume (combined)

7 229 Brick crushing facility baghouse stack PM Fabric Filter Volume (combined)

7 274 Alumina silo #4 truck loader baghouse stack PM Fabric Filter Volume (combined)

7 275 Aluminum fluoride/anthracite railcar unloading fugitive dust PM Volume (combined)

7 276 Coke unloading and transfer fugitive dust PM Volume (combined)

7 281 Annex ramming paste area roof vents PM Volume (combined)

7 284 Annex west pitch melter stack PM Volume (combined)

7 285 Annex east pitch melter stack PM Volume (combined)

7 286 Annex ramming paste mixer stack PM Volume (combined)

7 287 Autogenous mill silo baghouse stack PM Fabric Filter Volume (combined)

7 293 Baghouse hopper unloading PM Volume (combined)

7 295 Landfill - solid waste PM Volume (combined)

7 296 Landfill - RCRA waste PM Volume (combined)

7 306 Alumina ore ship unloader clamshell PM Volume (combined)

8 222 Paint shop shot blaster baghouse stack PM Fabric Filter Volume (combined)LCCCoordinateXLCCCoordinateYStackHeightBaseElevationEffectiveStackDiameterExitVelocityFlowRateExitTemperaturePM10EmissionRateFilterablePM2.5EmissionRateCondensablePM2.5EmissionRateSO2EmissionRateNOxEmissionRate(km) (km) (m) (m) (m) (m/s)(m3/s)(°K) (g/s) (g/s) (g/s) (g/s) (g/s)DSA1 -120.536 -14.914 19.8 65.4 3.733 12.98 142.1 363.7 1.81 0.097 1.48 37.41DSA2 -120.466 -15.150 19.8 63.9 3.733 13.05 142.8 363.7 1.81 0.097 1.48 37.41DSB3 -120.691 -14.958 17.9 62.2 5.957 5.17 144.1 353.1 1.81 0.097 1.48 37.41DSB4 -120.621 -15.195 17.9 61.4 5.957 5.17 144.1 353.1 1.81 0.097 1.48 37.41DSC5 -120.840 -15.000 17.9 59.7 5.723 4.90 126.0 355.1 1.81 0.097 1.48 37.41DSC6 -120.770 -15.238 17.9 59.0 5.723 4.79 123.2 355.1 1.81 0.097 1.48 37.41BAKEOVEN -121.011 -15.391 25.5 57.5 2.129 12.98 46.2 369.4 0.35 0.15 0.15 5.22 3.91CAST1-6 -120.392 -15.061 26.9 66.1 2.365 5.69 25.0 433.0 0.33 0.079 0.13CAST7-8 -120.415 -14.965 23.2 66.1 1.365 5.69 8.3 433.0 0.11 0.026 0.045CAST9-10 -120.422 -14.960 18.4 66.1 1.365 5.69 8.3 433.0 0.11 0.026 0.045CAST11-12 -120.433 -14.922 23.2 66.1 1.365 5.69 8.3 433.0 0.11 0.026 0.045188 -120.933 -15.393 36.1 58.5 1.462 5.34 9.0 Ambient 0.010 0.010189 -120.919 -15.088 36.1 58.5 1.287 3.63 4.7 Ambient 0.090 0.090191 -120.940 -15.395 36.1 58.5 1.287 3.63 4.7 Ambient 0.090 0.090195 -120.553 -15.394 17.7 63.1 0.61 4.29 1.3 343.0 0.080 0.080198 -120.957 -15.122 13.3 58.5 1.219 20.23 23.6 Ambient 0.24 0.24199 -120.953 -15.121 13.3 58.5 1.219 20.23 23.6 Ambient 0.24 0.24208 -121.006 -15.002 5.0 58.5 1.828 2.53 6.6 Ambient 0.076 0.076209 -121.095 -14.985 15.7 74.4 0.914 36.19 23.7 Ambient 0.43 0.43210 -120.400 -15.282 9.4 65.2 0.762 3.11 1.4 395.0 0.00018 0.00018217 -120.360 -15.210 23.2 77 1.365 5.69 8.3 433.0 0.026 0.0035 0.0070232 -120.931 -15.423 6.6 58.2 0.61 29.12 8.5 Ambient 0.097 0.097260 -120.925 -15.134 11 59.1 0.26 1.46 0.08 Ambient 0.025 0.025312 -120.922 -15.099 13.7 58.5 0.49 1.59 0.30 370.0 0.11 0.11313 -120.941 -15.104 13.7 58.5 0.49 1.59 0.30 370.0 0.11 0.11316 -120.858 -15.400 22.86 57.96 1.372 15.9 23.5 302.9 0.30 0.30SourceDescriptionTable 4-1Source Input Data for Baseline Modeling - Point SourcesAlcoa Intalco WorksFerndale, WashingtonRoof Scrubber Water On ConditionsLCCCoordinateBegin XLCCCoordinateBegin YLCCCoordinateEnd XLCCCoordinateEnd YReleaseHeightBaseElevationLineSourceWidthExitVelocityFlowRateBuoyancyParameterPM10EmissionRateFilterablePM2.5EmissionRateCondensablePM2.5EmissionRateSO2EmissionRateNOxEmissionRate(km) (km) (km) (km) (m) (m) (m) (m/s)(m3/s) (m4/s3)(g/s) (g/s) (g/s) (g/s) (g/s)WSLINEA1 -120.532 -14.845 -120.422 -15.219 16.40 65.4 4.24 3.920 55.32 410.22 2.30 0.87 0.83 1.97 0.00WSLINEA2 -120.606 -14.867 -120.496 -15.241 16.40 64.1 4.24 3.920 55.32 410.22 2.30 0.87 0.83 1.97 0.00WSLINEB1 -120.681 -14.892 -120.571 -15.266 16.40 62.9 4.24 3.990 56.30 417.52 2.30 0.87 0.83 1.97 0.00WSLINEB2 -120.755 -14.914 -120.645 -15.288 16.40 61.7 4.24 3.990 56.30 417.52 2.30 0.87 0.83 1.97 0.00WSLINEC1 -120.828 -14.936 -120.719 -15.309 16.40 60.5 4.24 3.904 55.08 408.49 2.30 0.87 0.83 1.97 0.00WSLINEC2 -120.903 -14.958 -120.793 -15.332 16.40 59.3 4.24 3.904 55.08 408.49 2.30 0.87 0.83 1.97 0.00Roof Scrubber Water Off ConditionsLCCCoordinateBegin XLCCCoordinateBegin YLCCCoordinateEnd XLCCCoordinateEnd YReleaseHeightBaseElevationLineSourceWidthExitVelocityFlowRateBuoyancyParameterPM10EmissionRateFilterablePM2.5EmissionRateCondensablePM2.5EmissionRateSO2EmissionRateNOxEmissionRate(km) (km) (km) (km) (m) (m) (m) (m/s)(m3/s) (m4/s3)(g/s) (g/s) (g/s) (g/s) (g/s)WSLINEA1 -120.532 -14.845 -120.422 -15.219 16.40 65.4 4.24 3.920 55.32 860.33 11.94 4.48 4.29 1.97 0.00WSLINEA2 -120.606 -14.867 -120.496 -15.241 16.40 64.1 4.24 3.920 55.32 860.33 11.94 4.48 4.29 1.97 0.00WSLINEB1 -120.681 -14.892 -120.571 -15.266 16.40 62.9 4.24 3.990 56.30 875.62 11.94 4.48 4.29 1.97 0.00WSLINEB2 -120.755 -14.914 -120.645 -15.288 16.40 61.7 4.24 3.990 56.30 875.62 11.94 4.48 4.29 1.97 0.00WSLINEC1 -120.828 -14.936 -120.719 -15.309 16.40 60.5 4.24 3.904 55.08 856.70 11.94 4.48 4.29 1.97 0.00WSLINEC2 -120.903 -14.958 -120.793 -15.332 16.40 59.3 4.24 3.904 55.08 856.70 11.94 4.48 4.29 1.97 0.00SourceDescriptionSourceDescriptionTable 4-2Source Input Data for Baseline Modeling - Line SourcesAlcoa Intalco WorksFerndale, WashingtonSouthwestCorner LCCCoordinate XSouthwestCorner LCCCoordinate YReleaseHeightInitialσzBaseElevationTotalAreaPM10EmissionRateFilterablePM2.5EmissionRateCondensablePM2.5EmissionRateSO2EmissionRateNOxEmissionRate(km) (km) (m) (m) (m)(m2) (g/s/m2) (g/s/m2) (g/s/m2) (g/s/m2) (g/s/m2)239 Fugitive dust from vehicle travel on paved roads -120.536 -14.914 5 10 60 720,000 0.00000040 0.000000059 0 0 0241 Facility-wide natural gas combustion (fugitive) -120.466 -15.150 15 15 60 720,000 0.00000022 0.00000022 0 0.000000042 0.0000030273 Alumina ore handling fugitive dust -120.691 -14.958 15 15 60 720,000 0.000000053 0.0000000080 0 0 0SourceIDSource DescriptionTable 4-3Source Input Data for Baseline Modeling - Area SourcesAlcoa Intalco WorksFerndale, WashingtonReferenceLCCCoordinateXReferenceLCCCoordinateYReleaseHeightInitialσyInitialσzBaseElevationPM10EmissionRateFilterablePM2.5EmissionRateCondensablePM2.5EmissionRateSO2EmissionRateNOxEmissionRate(km) (km) (m) (m) (m) (m) (g/s) (g/s) (g/s) (g/s) (g/s)251 Anode bake building monitor roof -120.982 -15.242 22 33.7 10.2 58.7 0.13 0.13 0.00 0.00 0.00252 Anode block hole blower -120.982 -14.242 22 33.7 10.2 58.7 0.12 0.12 0.00 0.00 0.00257A Rod shop crust recovery discharge to trucks from bins #1 and #2 -120.948 -15.123 4.6 1.07 1.07 58.5 0.0021 0.00032 0.00 0.00 0.00257B Rod shop crust recovery discharge to trucks from bins #1 and #2 -120.906 -15.112 4.6 1.07 1.07 58.5 0.0021 0.00032 0.00 0.00 0.00259A Rod shop carbon recovery discharge to trucks from bins #1 and #2 -120.948 -15.123 4.6 1.07 1.07 58.5 0.0030 0.00046 0.00 0.00 0.00259B Rod shop carbon recovery discharge to trucks from bins #1 and #2 -120.906 -15.112 4.6 1.07 1.07 58.5 0.0030 0.00046 0.00 0.00 0.00280 Annex cathode assembly area roof vent -120.983 -15.013 18.3 8.97 8.51 58.5 0.054 0.054 0.00 0.00 0.00282 Annex ladle rebuild area rood vents -120.952 -14.99 18.3 8.97 8.51 58.5 0.38 0.38 0.00 0.00 0.00Others1Other sources smaller than 0.1 g/s, combined (no SOxor NOx)-120.665 -15.076 4.6 1.07 1.07 62.0 0.358 0.307 0.00 0.00 0.00Others2Other sources greater than 0.1 g/s, combined (no SOxor NOx)-120.665 -15.076 4.6 1.07 1.07 62.0 0.849 0.7414 0.00 0.00 0.00Others3Other sources, combined (with SOxor NOxemissions)-120.665 -15.076 4.6 1.07 1.07 62.0 0.1722 0.1676 0.00 0.1574 2.348SourceIDSource DescriptionTable 4-4Source Input Data for Baseline Modeling - Volume SourcesAlcoa Intalco WorksFerndale, Washington

### Modeled 98th Percentile Modeled 98th Percentile Modeled 98th Percentile

(deciview) (deciview) (deciview)

Alpine Lakes Wilderness Area 1.244 36 0.965 37 0.881 23
Goat Rock Wilderness Area 0.500 8 0.579 10 0.317 3
Glacier Peak Wilderness Area 1.161 37 1.156 38 0.736 23
Mount Adams Wilderness Area 0.456 7 0.472 6 0.357 2
Mount Rainier National Park 0.843 22 1.052 26 0.629 15
North Cascades National Park 1.376 65 1.395 56 1.138 32 Olympic National Park 2.363 59 1.858 53 2.136 45 Pasayten Wilderness Area 0.866 30 0.871 33 0.659 13

Note: 2003

Number of Days Exceeding

0.5 dv 2004

Number of Days Exceeding

0.5 dv

Modeled visibility impacts that exceed the 0.5 dv contribution threshold are presented in bold in this table. Table 4-5 Screening Baseline Visibility Modeling Results Alcoa Intalco Works Ferndale, Washington

Class I Area 2005

Number of Days Exceeding

0.5 dv

### Modeled 98th Percentile Modeled 98th Percentile Modeled 98th Percentile

(deciview) (deciview) (deciview)

Alpine Lakes Wilderness Area 0.738 24 0.742 18 0.632 9
Goat Rock Wilderness Area 0.332 4 0.287 5 0.194 0
Glacier Peak Wilderness Area 0.916 24 0.769 25 0.552 10
Mount Rainier National Park 0.660 11 0.574 9 0.414 3
North Cascades National Park 0.936 36 0.986 35 0.693 14 Olympic National Park 1.527 41 1.369 37 1.225 34 Pasayten Wilderness Area 0.448 6 0.469 6 0.412 2

Note: Table 4-6 Refined Baseline Visibility Modeling Results Alcoa Intalco Works Ferndale, Washington

Modeled visibility impacts that exceed the 0.5 dv contribution threshold are presented in bold in this table. Class I Area 2005

Number of Days Exceeding

0.5 dv 2003

Number of Days Exceeding

0.5 dv 2004

Number of Days Exceeding

0.5 dvModeled 98thPercentile(deciview)SO4NO3FilterablePM2.5Coarse PMCondensablePMTotal of all sources1.527 92.5% 3.0% 0.5% 0.5% 3.4%Potline primary emission controls1.414 96.6%0% 0.05% 0.3% 3.2%Potline secondary emission controls 0.026 67.6% 0% 5% 5.4% 21.6%Anode bake furnace0.048 59.4% 39.1%0% 0% 1.4%Casthouse stacks 0.002 0% 0% 0% 0% 66.7%All other stacks 0.003 0% 0% 80.0% 20.0% 0%All volume sources 0.022 6.3% 75.0% 12.5% 6.3% 0%All area sources 0.011 0% 93.8% 0% 0% 0%Total of all sources1.369 80.8% 4.4% 1.7% 2.4% 10.6%Potline primary emission controls1.142 90.6%0% 0.12% 1.1% 8.2%Potline secondary emission controls 0.124 40.4% 0% 10.1% 11.8% 37.6%Anode bake furnace0.053 40.8% 55.3%1.3% 1.3% 2.6%Casthouse stacks 0.004 0% 0% 16.7% 16.7% 66.7%All other stacks 0.006 0% 0% 66.7% 33.3% 0%All volume sources 0.025 2.8% 69.4% 16.7% 11.1% 0%All area sources 0.014 0% 95.0% 5.0% 5.0% 0%Total of all sources1.225 90.3% 2.5% 0.95% 0.89% 5.3%Potline primary emission controls1.080 95.7%0% 0% 0% 3.9%Potline secondary emission controls 0.079 61.5% 0% 7.3% 5.5% 26.6%Anode bake furnace0.039 62.3% 34.0%0% 0% 1.9%Casthouse stacks 0.001 0% 0% 0% 0% 100.0%All other stacks 0.003 0% 0% 75.0% 25.0% 0%All volume sources 0.016 4.5% 68.2% 13.6% 9.1% 0%All area sources 0.007 0% 90.0% 0% 0% 0%200320042005Year Source GroupPercentage of Species ContributionTable 4-7Culpability Analysis for Refined Baseline Visibility Modeling Results in Olympic National ParkAlcoa Intalco WorksFerndale, WashingtonRBLC ID FacilityLastUpdateProcess Pollutant Control OptionPercentEfficiencyEmission LimitKY-0070NSA - A Division ofSouthwire Company03/02/2004 Potline 5SO2Wet scrubber193% 25.51 lb/hrSC-0037 Alumax of South Carolina 09/17/2002 Potroom Groups (4) PM Existing dry alumina scrubbers (fabric filter) 5.9 lb/hrSC-0037 Alumax of South Carolina 09/17/2002 Potroom Groups (4)SO2Limit maximum % sulfur of anode coke to 2.95%;limit maximum % sulfur of anode pitch to 1.2%271 lb/hrSC-0037 Alumax of South Carolina 09/17/2002 Anode Bake PlantSO2No upgrade; limit maximum % sulfur of anodecoke to 2.95%; limit maximum % sulfur of anodepitch to 1.2%85.5 lb/hrSC-0037 Alumax of South Carolina 09/17/2002 Anode Bake Plant PM No upgrade; limit sulfur content of raw materials 4.8 lb/hrSC-0037 Alumax of South Carolina 09/17/2002 Anode Bake PlantNOxNo upgrade; limit sulfur content of raw materials 9 lb/hrKY-0041 Arco Metals Co. 12/18/2001Primary AluminumReduction PotlinePM Baghouse, hooding for raw material handling 98% 0.02 gr/dscfKY-0041 Arco Metals Co. 12/18/2001Primary AluminumReduction PotlineSO2Fuel spec: low sulfur coke and pitch (calc. 3%sulfur)388 lb/hrOR-0002 Alumax Pacific Corp. 12/18/2001 Entire Plant PM Baghouse5.4 lb/t (monthly ave.);5.0 lb/ton (annual ave.)OR-0002 Alumax Pacific Corp. 12/18/2001 Anode CokeSO2Fuel spec: sulfur limit in coke 3% S in cokeWA-0003 Alcoa 12/18/2001 Potlines 1, 2, and 3SO2Fuel spec: limit S content in coke, raw 3% S in cokeNC-0003 Alcoa 01/28/2002 Potline 3 PM Fabric filter 26 lb/hrNC-0003 Alcoa 01/28/2002 Potline 3SO2321 lb/hrNC-0003 Alcoa 01/28/2002 Anode ProductionSO213 lb/hrNC-0003 Alcoa 01/28/2002 Anode Production PM 9 lb/hrMO-0036 Noranda Aluminum, Inc. 05/09/2006Carbon BakingFurnace for Potline 3PM1098.6 tons/yrMO-0036 Noranda Aluminum, Inc. 05/09/2006 Potline 1PM10Coated filter dry scrubber 56.76 tons/yrMO-0036 Noranda Aluminum, Inc. 05/09/2006 Potline 3PM10Coated filter dry scrubber 68.8 tons/yrNote:1This wet scrubber is not actually used or required by permit.Table 5-1RBLC Database Search Results for Primary Aluminum FacilitiesAlcoa Intalco WorksFerndale, WashingtonEmissions Emissions Emissions Emissions(tons/yr) (tons/yr) (tons/yr) (tons/yr)1LSFO Scrubber forPotlines854 88 136 0 984 (42) 1,113 (28)2LSFO Scrubber forAnode Bake Furnace6,904 2 136 0 747 (8) 921 (6)CurrentAllowableEmissionsOperating Limit of3% Sulfur in Coke7,076 136 693 869Notes:NOxSO2Table 5-2Post Control Emission Rates1Alcoa Intalco WorksFerndale, Washington% Reduction(Increase)21Emission rates include the potline primary control system, the potline secondary control system emissions, and the anode bakefurnaceemissions.2Compared with current potential emissions.PM2.5PM10% Reduction(Increase)2% Reduction(Increase)2% Reduction(Increase)2ControlScenarioSO2ControlTechnologyControlScenarioControlTechnologyEvaluatedControlledSO2EmissionRate1(tons/year)SO2EmissionReductions2(tons/year)InstalledCapital CostTotalAnnualizedControlCostsCostEffectiveness(per ton SO2removed)EnergyImpact(kW-hr/yr)291tons/yr PM2.527,130 tons/year of solid waste disposal243tons/yr PM10182.5 million gallons/year makeup water17,597tons/yr GHG354tons/yr PM2.5639.5 tons/year of solid waste disposal52tons/yr PM2.512.8 million gallons/year makeup water1,330tons/yr GHG3CurrentAllowableEmissionsOperating Limitof 3% Sulfur inCoke7,076Notes:3Greenhouse gas (GHG) emissions are presented as CO2equivalent emissions. The GHG emission calculations are presented in Appendix E.Non-Air Quality EnvironmentalImpactsTable 5-3Summaryof the Impacts Analysis for SO2Control ScenariosAlcoa Intalco WorksFerndale, WashingtonCollateral Increasein Other Pollutants1Emission rates include the potline primary control system, the potline secondary control system emissions, and the anode bakefurnace emissions.2Compared with current potential emissions.12LSFO Scrubberfor PotlinesLSFO Scrubberfor Anode BakeFurnace8546,9046,223172 $29,482,194$234,531,0496,570,00064,824,000$46,820,000$6,277,000$7,500$36,400LCCCoordinateXLCCCoordinateYStackHeightBaseElevationEffectiveStackDiameterExitVelocityExitTemperaturePM10EmissionRateFilterablePM2.5EmissionRateCondensablePM2.5EmissionRateSO2EmissionRateNOxEmissionRate(km) (km) (m) (m) (m) (m/s) (°K) (g/s) (g/s) (g/s) (g/s) (g/s)1LSFO Scrubber forPotlinesPotline WetScrubber2-120.425 -15.316 38.1 59.0 8.1 18.3 310 0.00 17.8 0.00 11.22 0.002LSFO Scrubber forAnode Bake FurnaceAnode Bake FurnaceWet Scrubber3-121.018 -15.614 30.5 57.5 2.6 18.3 336 0.00 1.70 0.15 0.26 3.91Notes:1Source input data for all other sources are the same as listed in Table 4-1 through 4-4 for the baseline modeling.2Potline wet scrubber source replaces sources DSA1, DSA2, DSB3, DSB4, DSC5, and DSC6 in Table 4-1 from the baseline modeling.3Anode bake oven wet scrubber source replaces source BAKEOVEN in Table 4-1 from the baseline modeling.ControlScenarioSO2ControlTechnologySource DescriptionTable 5-4Source Input Data for Post Control SO2Modeling1Alcoa Intalco WorksFerndale, WashingtonModeled98thPercentileModeled98thPercentileModeled98thPercentile(deciview) (deciview) (deciview)Alpine Lakes Wilderness Area 0.158 0 0.147 0 0.129 0Glacier Peak Wilderness Area 0.190 0 0.163 0 0.125 0Mount Rainier National Park 0.108 0 0.107 0 0.085 0North Cascades National Park 0.198 0 0.212 0 0.174 0Olympic National Park 0.355 2 0.303 1 0.325 1Alpine Lakes Wilderness Area0.723220.729180.6219Glacier Peak Wilderness Area0.901240.752230.54610Mount Rainier National Park0.648110.5659 0.410 3North Cascades National Park0.921360.974340.68414Olympic National Park1.503411.348371.20633Alpine Lakes Wilderness Area0.738240.742180.6329Glacier Peak Wilderness Area0.916240.769250.55210Mount Rainier National Park0.660110.5749 0.414 3North Cascades National Park0.936360.986350.69314Olympic National Park1.527411.369371.22534Note:Table 5-5SO2Post Control VisibilityModelingResultsAlcoa Intalco WorksFerndale, WashingtonControlScenarioSO2ControlTechnologyEvaluatedClass I Area2005Number ofDaysExceeding0.5 dv2003Number ofDaysExceeding0.5 dv2004Number ofDaysExceeding0.5 dvCurrentAllowableEmissionsOperating Limit of3% Sulfur in CokeModeled visibility impacts that exceed the 0.5 dv contribution threshold are presented in bold in this table.LSFO Scrubber forPotlines12LSFO Scrubber forAnode Bake Furnace

# APPENDICES

# A PPENDIX 

# A:

BART M ODELING 

# R ESULTS

# A PPENDIX 

# B:

B USINESS 

# C ONFIDENTIAL 

# I NFORMATION

# A PPENDIX 

# C:

P RE 

# -F EASIBILITY 

# R EPORT

# A PPENDIX 

# D:

W ET 

# S CRUBBER 

# E CONOMIC AND 

# E NERGY 

# I MPACTPotlinesAnode BakeFurnaceVendor Quote#1Vendor Quote#2Average PotlinesAnode BakeFurnaceReagent feed system 10% 0.33 0.80 $6,500,000 $8,200,000 $7,350,000 $7,894,009 $404,491SO2removal system35% 0.50 0.80 $22,750,000 $28,700,000 $25,725,000 $28,543,995 $4,666,407Flue gas system 30% 0.50 0.80 $19,500,000 $24,600,000 $22,050,000 $24,466,281 $3,999,778By-product handling system 10% 0.40 0.80 $6,500,000 $8,200,000 $7,350,000 $8,104,759 $403,121General support equipment 15% 0.15 0.80 $9,750,000 $12,300,000 $11,025,000 $11,436,638 $568,845TOTAL $65,000,000 $82,000,000 $73,500,000 $80,445,682 $10,042,642Scaling of Capital Equipment Costs Based on Vendor ProposalsIntalco WorksFerndale, WashingtonIntalco Scrubber EquipmentCost EstimatesFraction ofTotalEquipmentCostScrubber ComponentScaling EquationExponentTennessee Potline Scrubber Equipment CostsBART cost calculations 110607.xls-Capital equipment costsE N V I R O NPotlines

Intalco Works Ferndale, Washington

Value Notes/References Capital Investment Costs

Direct Capital Costs (DCC)

Purchased Equipment Costs (PEC)

Adsorber vessels with internals $80,445,682 Based on vendor quotations for Tennessee Alcoa smelter, adjusted for scrubber exhaust gas flow rate, limestone consumption, and gypsum generation per Pre-feasability Report (Hatch 2007)

Pumps Included Limestone prep Included Dewatering systems Included
Fans Included
Inlet ductwork Included
Stacks Included Continuous Emission Monitoring system (2 stacks) $80,000 Subtotal (EC) $80,525,682

Instrumentation $4,026,284 USEPA 2002, Section 5.2, Chapter 1, Table 1.3 (5% of EC; adjusted from 10% since basic instrumentation is included in proposal)

Sales tax $5,234,169 State sales tax rate for Washington is 6.5% Freight $4,026,284 USEPA 2002, Section 5.2, Chapter 1, Table 1.3 (5% of EC)
Total Purchased Equipment Costs (PEC) $93,812,419

Direct Installation Costs (DIC)

Foundations and supports $11,257,490 USEPA 2002, Section 5.2, Chapter 1, Table 1.3 (12% of PEC) Handling and erection $75,049,936 USEPA 2002, Section 5.2, Chapter 1, Table 1.3 (80% of PEC; adjusted from 40% to account for retrofit of existing plant and onsite fabrication)

Electrical $938,124 USEPA 2002, Section 5.2, Chapter 1, Table 1.3 (1% of PEC) Piping $28,143,726 USEPA 2002, Section 5.2, Chapter 1, Table 1.3 (30% of PEC) Insulation $938,124 USEPA 2002, Section 5.2, Chapter 1, Table 1.3 (1% of PEC) Painting $938,124 USEPA 2002, Section 5.2, Chapter 1, Table 1.3 (1% of PEC)

Total Direct Installation Costs (DIC) $117,265,524
Total Direct Capital Costs $211,077,944 Sum of PEC and DIC

Indirect Capital Costs (ICC)
Engineering $4,690,621 USEPA 2002, Section 5.2, Chapter 1, Table 1.3 (5% of PEC; adjusted from 10% since vendor proposal includes an allowance for engineering)

Construction and field expenses $9,381,242 USEPA 2002, Section 5.2, Chapter 1, Table 1.3 (10% of PEC) Contractor fees $4,690,621 USEPA 2002, Section 5.2, Chapter 1, Table 1.3 (5% of PEC; adjusted from 10% based on assumption that vendor will oversee scrubber installation) Start-up $938,124 USEPA 2002, Section 5.2, Chapter 1, Table 1.3 (1% of PEC) Performance test $938,124 USEPA 2002, Section 5.2, Chapter 1, Table 1.3 (1% of PEC) Contingencies $2,814,373 USEPA 2002, Section 5.2, Chapter 1, Table 1.3 (3% of PEC)

Total Indirect Capital Costs $23,453,105

Total Capital Investment Costs (TCIC) $234,531,049 Sum of DCC and ICC

References:
Hatch. 2007. SO 2 Scrubbing for the INTALCO Primary Aluminum Smelter: Pre-Feasibility Report . July 26.
USEPA. 2002. EPA Air Pollution Control Cost Manual , Sixth Edition. EPA/452/B-02-001. January. Captial Investment Cost Analysis for SO 2 Control Using a Wet Scrubber

BART cost calculations 110607.xls-Capital cost calcs (potlines) E N V I R O NPotlines

Intalco Works Ferndale, Washington

Value Units Notes/References Annual Operation and Maintenance Costs

Direct Annual Costs (DAC)

Operating labor Operator $324,120 Assumes $37 per hour with one full-time operator, 3 shifts per day Supervisor $48,618 USEPA 2002, Section 5.2, Chapter 1, Table 1.4 (15% of operator costs)

Water $96,725 Water usage 500,000 gal/day Pre-feasability Report (Hatch 2007) Cost of water $0.00053 $/gal Intalco controller

Limestone $470,052 Limestone usage 14,244 tons/yr Pre-feasability Report (Hatch 2007) Cost of limestone $33 $/ton Assumes $28/ton for 8 mesh size limestone plus $5/ton for shipping by barge

Compressed air $18,922 Compressed air usage 150 scfm Pre-feasability Report (Hatch 2007) Cost of compressed air $0.24 $/1000 scf Average compressed air generation cost for industrial facilities (http://www1.eere.energy.gov/industry/bestpractices/pdfs/com pressed_air1.pdf)

Gypsum disposal $3,933,809 Gypsum generation rate 6,194 lb/hr Pre-feasability Report (Hatch 2007) Cost of gypsum disposal $145 $/ton Non-hazardous waste disposal and transportation costs

Maintenance Labor $673,920 Assumes $45 per hour with 4 full-time maintenance personnel, one shift per day, 5 days per week and 1 maintenance personnel for all other shifts Material $1,303,000 Cost for low sulfur boiler system with 1.7 macfm inlet/1.5 macfm outlet, which is smaller than the potline system with 2.2 macfm inlet/2.0 macfm outlet (Sargent & Lundy LLC 2003)

Electricity $3,409,742 Electricity usage 7,400 kWh/hr Pre-feasability Report (Hatch 2007) Electricity cost $0.0526 $/kWh Facility average power rate for 2007 (Intalco controller)

Total Direct Annual Costs $10,278,908

Indirect Annual Costs (IAC)
Overhead $1,409,795 USEPA 2002, Section 5.2, Chapter 1, Table 1.4 (60% of total labor and maintenance material costs)

General and administrative costs $4,690,621 USEPA 2002, Section 5.2, Chapter 1, Table 1.4 (2% of TCIC)

Property tax $2,345,310 USEPA 2002, Section 5.2, Chapter 1, Table 1.4 (1% of TCIC)

Insurance $2,345,310 USEPA 2002, Section 5.2, Chapter 1, Table 1.4 (1% of TCIC)

Total Indirect Annual Costs $10,791,037 Sum of PEC and DIC

Total Annual Operating and Maintenance Costs $21,069,945 Sum of DAC and IAC

References:
Hatch. 2007. SO 2 Scrubbing for the INTALCO Primary Aluminum Smelter: Pre-Feasibility Report . July 26. Sargent & Lundy LLC. 2003. Wet Flue Gas Desulfurization Technology Evaluation . Prepared for National Lime Association. January.
USEPA. 2002. EPA Air Pollution Control Cost Manual , Sixth Edition. EPA/452/B-02-001. January. Operation and Maintenance Cost Analysis for SO 2 Control Using a Wet Scrubber

BART cost calculations 110607.xls-O&M cost calcs (potlines) E N V I R O NInstallation of Wet Scrubber on Potline ExhaustReferencePotline hooding capture efficiency 95%Total potline uncontrolled SOxemission rate37,780 lb/dayTotal potline SOxemission limitPrimary potline control system uncontrolled SOxemission rate35,891 lb/day Calculated based on potline hooding capture efficiencySOxcontrol efficiency95%Controlled SOxemission rate1,795 lb/dayUncontrolled annual SOxemissions6,550 tpyControlled annual SOxemissions328 tpySOxreduction6,223 tpyDirect capital costs (DCC) 211,077,944$Indirect capital costs (ICC) 23,453,105$Total capital costs 234,531,049$Interest rate 7% USEPA 2002, Section 1, Chapter 2.4.2Period of annualization 15 years AssumptionCapital recovery discount factor 0.11 USEPA 2002, Section 1, Chapter 2.4.4.4, Equation 2.8aAnnualized capital cost 25,750,000$USEPA 2002, Section 1, Chapter 2.4.4.4, Equation 2.8Operating labor costs 324,120$Supervisory labor costs 48,618$Maintenance labor costs 673,920$Maintenance material costs 1,303,000$Electricity costs 3,409,742$Water costs 96,725$Limestone costs 470,052$Compressed air costs 18,922$Gypsum disposal costs 3,933,809$Overhead 1,409,795$Property tax 2,345,310$Insurance 2,345,310$General and administrative costs 4,690,621$Total annual cost estimate 46,820,000$Cost of option per ton SOxreduced7,500$BART cost calculations 110607.xls-Potline scrubber cost summaryE N V I R O NCaptial Investment Cost Analysis for SO 2 Control Using a Wet Scrubber

Anode Bake Furnace

Intalco Works Ferndale, Washington

Value Notes/References Capital Investment Costs

Direct Capital Costs (DCC)

Purchased Equipment Costs (PEC)

Adsorber vessels with internals $10,042,642 Based on vendor quotations for Tennessee Alcoa smelter, adjusted for exhaust gas flow rate per Pre-feasability Report (Hatch 2007)

Pumps Included Limestone prep Included Dewatering systems Included
Fans Included
Inlet ductwork Included
Stacks Included Continuous Emission Monitoring system (2 stacks) $80,000 Subtotal (EC) $10,122,642

Instrumentation $506,132 USEPA 2002, Section 5.2, Chapter 1, Table 1.3 (5% of EC; adjusted from 10% since basic instrumentation is included in proposal)

Sales tax $657,972 State sales tax rate for Washington is 6.5% Freight $506,132 USEPA 2002, Section 5.2, Chapter 1, Table 1.3 (5% of EC)
Total Purchased Equipment Costs (PEC) $11,792,878

Direct Installation Costs (DIC)

Foundations and supports $1,415,145 USEPA 2002, Section 5.2, Chapter 1, Table 1.3 (12% of PEC) Handling and erection $9,434,302 USEPA 2002, Section 5.2, Chapter 1, Table 1.3 (80% of PEC; adjusted from 40% to account for retrofit of existing plant and onsite fabrication)

Electrical $117,929 USEPA 2002, Section 5.2, Chapter 1, Table 1.3 (1% of PEC) Piping $3,537,863 USEPA 2002, Section 5.2, Chapter 1, Table 1.3 (30% of PEC) Insulation $117,929 USEPA 2002, Section 5.2, Chapter 1, Table 1.3 (1% of PEC) Painting $117,929 USEPA 2002, Section 5.2, Chapter 1, Table 1.3 (1% of PEC)

Total Direct Installation Costs (DIC) $14,741,097
Total Direct Capital Costs $26,533,975 Sum of PEC and DIC

Indirect Capital Costs (ICC)
Engineering $589,644 USEPA 2002, Section 5.2, Chapter 1, Table 1.3 (5% of PEC; adjusted from 10% since vendor proposal includes an allowance for engineering)

Construction and field expenses $1,179,288 USEPA 2002, Section 5.2, Chapter 1, Table 1.3 (10% of PEC) Contractor fees $589,644 USEPA 2002, Section 5.2, Chapter 1, Table 1.3 (5% of PEC; adjusted from 10% based on assumption that vendor will oversee scrubber installation) Start-up $117,929 USEPA 2002, Section 5.2, Chapter 1, Table 1.3 (1% of PEC) Performance test $117,929 USEPA 2002, Section 5.2, Chapter 1, Table 1.3 (1% of PEC) Contingencies $353,786 USEPA 2002, Section 5.2, Chapter 1, Table 1.3 (3% of PEC)

Total Indirect Capital Costs $2,948,219

Total Capital Investment Costs (TCIC) $29,482,194 Sum of DCC and ICC

References:
Hatch. 2007. SO 2 Scrubbing for the INTALCO Primary Aluminum Smelter: Pre-Feasibility Report . July 26.
USEPA. 2002. EPA Air Pollution Control Cost Manual , Sixth Edition. EPA/452/B-02-001. January.

BART cost calculations 110607.xls-Capital cost calcs (ABF) E N V I R O NOperation and Maintenance Cost Analysis for SO 2 Control Using a Wet Scrubber

Anode Bake Furnace

Intalco Works Ferndale, Washington

Value Units Notes/References Annual Operation and Maintenance Costs

Direct Annual Costs (DAC)

Operating labor Operator $324,120 Assumes $37 per hour with one full-time operator, 3 shifts per day Supervisor $48,618 USEPA 2002, Section 5.2, Chapter 1, Table 1.4 (15% of operator costs)

Water $6,771 Water usage 35,000 gal/day Pre-feasability Report (Hatch 2007) Cost of water $0.00053 $/gal Intalco controller

Limestone $11,286 Limestone usage 342 tons/yr Pre-feasability Report (Hatch 2007) Cost of limestone $33 $/ton Assumes $28/ton for 8 mesh size limestone plus $5/ton for shipping by barge

Compressed air $6,307 Compressed air usage 50 scfm Pre-feasability Report (Hatch 2007) Cost of compressed air $0.24 $/1000 scf Average compressed air generation cost for industrial facilities (http://www1.eere.energy.gov/industry/bestpractices/pdfs/com pressed_air1.pdf)

Gypsum disposal $92,725 Gypsum generation rate 146 lb/hr Pre-feasability Report (Hatch 2007) Cost of gypsum disposal $145 $/ton Non-hazardous waste disposal and transportation costs

Maintenance Labor $336,960 Assumes $45 per hour with 2 full-time maintenance personnel, one shift per day, 5 days per week and a half-time maintenance personnel equivalent for all other shifts

Material $163,796 Calculated based on estimated maintenance material costs for

p otline scrubber and ratio of purchased equipment costs for the anode bake furnace and potline scrubbers

Electricity $345,582 Electricity usage 750 kWh/hr Pre-feasability Report (Hatch 2007) Electricity cost $0.0526 $/kWh Facility average power rate for 2007 (Intalco controller)

Total Direct Annual Costs $1,336,165

Indirect Annual Costs (IAC)
Overhead $524,097 USEPA 2002, Section 5.2, Chapter 1, Table 1.4 (60% of total labor and maintenance material costs)

General and administrative costs $589,644 USEPA 2002, Section 5.2, Chapter 1, Table 1.4 (2% of TCIC)

Property tax $294,822 USEPA 2002, Section 5.2, Chapter 1, Table 1.4 (1% of TCIC)

Insurance $294,822 USEPA 2002, Section 5.2, Chapter 1, Table 1.4 (1% of TCIC)

Total Indirect Annual Costs $1,703,384 Sum of PEC and DIC

Total Annual Operating and Maintenance Costs $3,039,549 Sum of DAC and IAC

References:
Hatch. 2007. SO 2 Scrubbing for the INTALCO Primary Aluminum Smelter: Pre-Feasibility Report . July 26.
USEPA. 2002. EPA Air Pollution Control Cost Manual , Sixth Edition. EPA/452/B-02-001. January.

BART cost calculations 110607.xls-O&M cost calcs (ABF) E N V I R O NInstallation of Wet Scrubber on Anode Bake Furnace ExhaustReferenceUncontrolled SOxemission rate994 lb/daySOxcontrol efficiency95%Controlled SOxemission rate50 lb/dayUncontrolled annual SOxemissions181 tpyControlled annual SOxemissions9 tpySOxreduction172 tpyDirect capital costs (DCC) 26,533,975$Indirect capital costs (ICC) 2,948,219$Total capital costs 29,482,194$Interest rate 7% USEPA 2002, Section 1, Chapter 2.4.2Period of annualization 15 years AssumptionCapital recovery discount factor 0.11 USEPA 2002, Section 1, Chapter 2.4.4.4, Equation 2.8aAnnualized capital cost 3,237,000$USEPA 2002, Section 1, Chapter 2.4.4.4, Equation 2.8Operating labor costs 324,120$Supervisory labor costs 48,618$Maintenance labor costs 336,960$Maintenance material costs 163,796$Electricity costs 345,582$Water costs 6,771$Limestone costs 11,286$Compressed air costs 6,307$Gypsum disposal costs 92,725$Overhead 524,097$Property tax 294,822$Insurance 294,822$General and administrative costs 589,644$Total annual cost estimate 6,277,000$Cost of option per ton SOxreduced36,400$BART cost calculations 110607.xls-Furnace scrubber cost summaryE N V I R O N

# A PPENDIX 

# E:

G REENHOUSE 

# G AS 

# E MISSION 

# C ALCULATIONS

### E-1 BART Determination Alcoa Intalco Works Ferndale, Washington Greenhouse Gas Emission Calculations

Greenhouse gases (GHGs) are gaseous compounds that are consider ed to act as heat trapping constituents of the atmosphere. Although there are many gases that may trap heat in the atmosphere, there are six GHGs recognized by inte rnational and domestic regulations on climate change: carbon dioxide (CO 2 

### ), nitrous oxide (N 2 

### O), methane, hydrofluorocarbons (HFCs), chlorinated fluorocarbons (CFCs), and sulfur hexa fluoride. More than 80% of the global warming potential results from CO 2 

### emissions.

The proposed sulfur dioxide (SO 2 

### ) control devices will contribute to the facility’s overall emissions of GHGs via three mechanisms: (1) as a byproduct of the reaction chemistry in the scrubbers, (2) as indirect emissions from the gene ration of electricity required to power the scrubbing systems, and (3) as direct emissions from vehicle travel for th e additional personnel that will be required at the facility to maintain and operate the scrubbing systems.

The estimate of carbon dioxide emissions resulting fr om the reaction of limes tone with the sulfur dioxide in the exhaust streams is based on the theoretical reaction chemistry, assuming no other byproducts resulting from incomple te reaction. Consistent with the BART analysis, we assumed that 95% of the incoming sulfur dioxide reacts w ith the limestone, and hence is removed from the exhaust stream. There are three r eactions taking place in the scrubber:

1) Dissolution of the limestone in the scrubbing water:

CaCO 3 

### + H 2 

### O Æ Ca +2 

### + HCO 3 - 

### + OH 

### 2) Dissolution of the sulfur di oxide in the scrubbing water:

SO 2 

### + H 2 

### O Æ 2H + 

### + SO 3 -2



### 3) Oxidation of the sulfite ions to sulfate ions (a nd hence, formation of gypsum or calcium sulfate):

Ca +2 

### + HCO 3 - 

### + OH - 

### + 2H + 

### + SO 3 -2 

### + 1⁄2 O 2 

### Æ CaSO 4 

### + CO 2 

### +2 H 2 

### O

Consistent with the chemical balan ce shown above, for every mole of SO 2 

### reacted, a mole of carbon dioxide is formed.

The inlet sulfur dioxide molar flowrate was es timated based on design parameters provided by Hatch Associates 1 

### . Assuming a minimum 95% sulfur dioxide control efficiency (that is, assuming that 95% of the sulfur dioxide reacts with the limestone), the mass of carbon dioxide evolved was calculated based on the reaction chemistry presented above.

1 

### Hatch Associates. 2007. Pre-Feasibility Report – SO 2 

### Scrubbing for the INTALCO Primary Aluminum Smelter

. November 5. Tables 3 and 6 (potline exhaust an d anode baking furnace exhaust, respectively).

### E-2 The implementation of the proposed scrubbing systems would also generate GHGs indirectly, as a result of consuming electricity. The generation of electricity at some off-site location would produce GHGs. The methodology described in the California Climate Action Registry General Reporting Protocol (CCARGRP) 2 

### , for estimating indirect emissions of GHGs from electricity use was followed. Based on design specifi cations provided by Hatch Associates 3 

### , the daily electricity usage of each scrubber (potline fumes scrubber and the anode bake furnace scrubber) were multiplied by a state-specific carbon dioxide emi ssion factor. The state-specific emission factor was found in the USEPA Emissions and Generation Resource Integrated Database for 2006 (eGrid2006) 4 

### for Washington state. To estimate the em issions of nitrous oxide and methane (two minor GHG components from combustion sources), the default emission f actors provided in the CCARGRP 5 

### were used. To convert the estimated nitr ous oxide and methane emissions to carbon dioxide equivalents, the CCARG RP provides an estimate of each compound’s global warming potential (GWP) 6 

### . For example, methane has a GWP of 21 times that of carbon dioxide; therefore, to convert the methane emission rate to carbon dioxide equivalents, we multiply the methane emission rate by its GWP.

The last potential source of GHGs resulting fr om the implementation of the proposed scrubbing systems is from vehicle travel to and from th e facility by additional pe rsonnel necessary for the operation and maintenance of the scrubbing systems. Based on facility estimates, the potline fumes scrubbing system would require nine additional em ployees per day on weekdays and six additional personnel per day on weekends. Similarly, the anode baking furnace scrubbing system would require six additional employees per day on wee kdays and 4.5 additional personnel equivalents per day on weekends. It was assumed that each pers on would drive a roundtri p distance of 20 miles per day. This is approximately the roundtrip distance between the facility and downtown Bellingham, Washington. The emission estimate s of carbon monoxide, nitrous oxide, and methane in the vehicle exhaust were based on assuming an average fuel economy. The fleet average (1988 to 2007) fuel economy from the USEPA 7 

### was used. The emission f actor for carbon dioxide was provided in the CCARGRP for non-California gasoline 8 

### . The emission factors for nitrous oxide and methane from vehicles were based on the average of the 1988 to present emission factors provided in the CCARGRP 9 

### . To convert the nitrous oxide a nd methane emission rates to carbon dioxide equivalents, the GWP for each co mpound was applied as discussed above.

2 

### California Climate Action Registry. 2007. California Climate Action Registry General Reporting Protocol (CCARGRP): Reporting Entity-Wide Greenhouse Gas Emissions . Version 2.2. March. Chapter 6.

3 

### Hatch Associates. 2007. Pre-Feasibility Report – SO 2 

### Scrubbing for the INTALCO Primary Aluminum Smelter

. November 5. Tables 5 and 8 (po tline fumes scrubbing and anode baking furnace scrubbing, respectively).

4 

### United States Environmental Protection Agency (USEPA). 2007. Emissions and Generation Resource Integrated Database for 2006 (eGrid2006). Version 2.1. April. Year 2004 summary tables.

5 

### California Climate Action Registry. 2007. California Climate Action Registry General Reporting Protocol (CCARGRP): Reporting Entity-Wide Greenhouse Gas Emissions . Version 2.2. March. Table C-2

6 

### Ibid. Table III.6-1.

7 

### United States Environmental Protection Agency (USEPA). 2007. Light-Duty Automotive Technology and Fuel Economy Trends: 1975 to 2007 (Table 1 – Cars and Trucks).

8 

### California Climate Action Registry. 2007. California Climate Action Registry General Reporting Protocol (CCARGRP): Reporting Entity-Wide Greenhouse Gas Emissions . Version 2.2. March. Table C-3.

9 

### Ibid. Table C-4 (used weighted average of the factors provided for various spans of model years).

### E-3 The GHG emission calculations descri bed above are presented in the attached tables. The total GHGs (in carbon dioxide equivalents) generated by the implementation of the proposed scrubbing system for the potline fumes was estimated to be 96,441 pounds per day, or 17,598 tons per year. The total GHGs (in carbon dioxide equivalents) ge nerated by the implementation of the proposed scrubbing system for the anode baking furnace was estimated to be 7,298 pounds per day, or 1,330 tons per year.

### Greenhouse Gases Emissions Intalco (Ferndale, WA)

Scope :

Assumptions :

Sources of Greenhouse Gases :

Summary of Potline Wet Scrubber GHG Emission Estimates :

Mass of CO 2 

### evolved from scrubbing potroom emissions 31,969 lb/day Mass of GHGs (in CO 2 

### equivalents) evolved from electricity production for scrubbing system 64,294 lb/day Mass of GHGs (in CO 2 

### equivalents) evolved from vehicle travel for additional personnel 177.9 lb/day 96,441 lb/day 17,597 tons/yr

Summary of Anode Bake Furnace Wet Scrubber GHG Emission Estimates :

Mass of CO 2 

### evolved from scrubbing anode bake furnace emissions 663 lb/day Mass of GHGs (in CO 2 

### equivalents) evolved from electricity production for scrubbing system 6,516 lb/day Mass of GHGs (in CO 2 

### equivalents) evolved from vehicle travel for additional personnel 118.6 lb/day 7,298 lb/day 1,330 tons/yr TOTAL GHGs (CO 2 

### equivalents)

TOTAL GHGs (CO 2 

### equivalents)

- The addition of personnel as a result of the operation of the scrubbing systems (vehicle travel) Calculation of greenhouse gases from the implementation of a flue gas desulfurization system. There will be one scrubbing system for the potrooms and one for the anode baking furnace. The scrubbing system consists of a limestone-gypsum forced oxidation (LSFO) process.

CO 2 

### is the primary greenhouse gas evolved. Other components, such as methane or nitrous oxide are in de minimus quantities. These will be included where there is sufficient information for their estimate.

- Reaction chemistry of the limestone and sulfur dioxide (LSFO) - Energy consumption of the scrubbing systemsGHG Emissions from Scrubbing Potline EmissionsScrubbing Reaction Chemistry:1) CaCO3+ H2O ------> Ca+2+ HCO3-+ OH2) SO2+ H2O -----------> 2H++ SO3-23) Ca+2+ HCO3-+ OH-+ SO3-2+ 2H++ 1/2 O2----------------> CaSO4+ CO2+ 2H2OSo, for every one mole of SO2(64 grams) removed, one mole of CO2(44 grams) is evolved.Based on the final Hatch pre-feasibility report (dated November 5, 2007):Parameter ReferenceSO2concentration300mg/Nm3Hatch, Table 3Flowrate 1,814,880 scfm Hatch, Table 351,394 m3/minSO2at inlet of FGD system257.0 grams/second Calculated, based on FGD inlet flow characteristics presented in Hatch, Table 34.02moles SO2/second Based on molar mass of SO2of 64 grams/moleRemoval efficiency 95% minimum Hatch, Table 4Moles of SO2reacted3.81moles SO2/secondMoles of CO2evolved3.81moles CO2/secondMass of CO2evolved167.8grams CO2/second Based on molar mass of CO2of 44 grams/mole14,500,691grams CO2/day31,969lb CO2/dayValue

### GHG Emissions from Scrubbing Anode Baking Furnace Emissions

Scrubbing Reaction Chemistry:

1) CaCO 3 

### + H 2 

### O ------> Ca +2 

### + HCO 3 - 

### + OH -



### 2) SO 2 

### + H 2 

### O -----------> 2H + 

### + SO 3 -2



### 3) Ca +2 

### + HCO 3 - 

### + OH - 

### + SO 3 -2 

### + 2H + 

### + 1/2 O 2 

### ----------------> CaSO 4 

### + CO 2 

### + 2H 2 

### O

So, for every one mole of SO 2 

### (64 grams) removed, one mole of CO 2 

### (48 grams) is evolved.

Based on the final Hatch pre-feasibility report (dated November 5, 2007):

Parameter Reference
SO 2 

### at inlet of FGD system 5.33 grams/second Hatch, Table 6

0.083 moles SO 2 

### /second Based on molar mass of SO 2 

### of 64 grams/mole Removal efficiency 95% minimum Hatch, Table 7
Moles of SO 2 

### reacted 0.079 moles SO 2 

### /second
Moles of CO 2 

### evolved 0.079 moles CO 2 

### /second
Mass of CO 2 

### evolved 3.5 grams CO 2 

### /second Based on molar mass of CO 2 

### of 44 grams/mole 300,772 grams CO 2 

### /day

663 lb CO 2 

### /day ValueGHGs resulting from electricity generation associated with potline scrubber system1ParametersReferenceElectricity usage for potline wet scrubber 7,400 kWh/h Hatch, Table 5Electricity usage for potline wet scrubber 177,600 kWh/day Assumes continuous operation of wet scrubberN2O global warming potential (GWP) 310 Table III.6.1 - CCARGRPMethane GWP 21 Table III.6.1 - CCARGRPEmission FactorsReferenceCO2360 lb/MWh Emission factors for Washington state (eGrid 2006 Version 2.1, April 2007)CO20.36 lb/kWhN2O 0.004 lb/MWh Default emission factors for N2O and methane for Washington state (Table C.2, CCARGRP)Methane 0.037 lb/MWh Default emission factors for N2O and methane for Washington state (Table C.2, CCARGRP)Emission EstimatesCO263,936 lb/dayN2O 0.71 lb/dayMethane 6.57 lb/dayConversion of non-CO2GHGs to CO2equivalentsCO263,936 lb/dayN2O - CO2equivalents 220 lb/dayMethane - CO2equivalents 138 lb/dayTotal CO2equivalents 64,294 lb/dayNotes:1Based on methodology described in theCalifornia Climate Action Registry General Reporting Protocol (CCARGRP)(March 2007) and the data in the USEPAEmissions & Generation Resource Integrated Database(eGrid2006).GHGs resulting from electricity generation associated with anode bake furnace scrubber system1ParametersReferenceElectricity usage for anode bake furnace wet scrubber 750 kWh/h Hatch, Table 8Electricity usage for anode bake furnace wet scrubber 18,000 kWh/day Assumes continuous operation of wet scrubberN2O global warming potential (GWP) 310 Table III.6.1 - CCARGRPMethane GWP 21 Table III.6.1 - CCARGRPEmission FactorsReferenceCO2360 lb/MWh Emission factors for Washington state (eGrid 2006 Version 2.1, April 2007)CO20.36 lb/kWhN2O 0.004 lb/MWh Default emission factors for N2O and methane for Washington state (Table C.2, CCARGRP)Methane 0.037 lb/MWh Default emission factors for N2O and methane for Washington state (Table C.2, CCARGRP)Emission EstimatesCO26,480 lb/dayN2O 0.07 lb/dayMethane 0.67 lb/dayConversion of non-CO2GHGs to CO2equivalentsCO26,480 lb/dayN2O - CO2equivalents 22 lb/dayMethane - CO2equivalents 14 lb/dayTotal CO2equivalents 6,516 lb/dayNotes:1Based on methodology described in theCalifornia Climate Action Registry General Reporting Protocol (CCARGRP)(March 2007) and the data in the USEPAEmissions & Generation Resource Integrated Database(eGrid2006).GHGs resulting from vehicle travel for additional personnel associated with potline scrubber system1ParametersReferenceAdditional operating personnel 3 One additional full-time operator per shift, three shifts per day (assumption)Additional maintenance personnel (weekdays) 6 Four additional full-time maintenance personnel, one shift per day, plus one additional fulltime maintenancepersonnel for off-shifts(assumption)Additional maintenance personnel (weekends) 3 One additional full-time maintenance personnel for off-shifts (assumption)Total additional personnel (weekdays) 9Total additional personnel (weekends) 6Daily round trip distance 20 miles/trip Assumption (distance from plant to downtown Bellingham, WA is approximately 10 miles)Total daily mileage (weekdays) 180 miles/dayTotal daily mileage (weekends) 120 miles/dayAverage fuel economy 20.3 miles/gallon Fleet average (1988 to 2007 model years); USEPA, Light-Duty Automotive Technologyand Fuel EconomyTrends: 1975 to 2007, Table 1(Cars and Trucks)N2O global warming potential (GWP) 310 Table III.6.1 - CCARGRPMethane GWP 21 Table III.6.1 - CCARGRPEmission FactorsReferenceCO2emission factor 8.78 kg/gallon Non-CA gasoline; Table C.3, CCARGRPN2O emission factor 0.050 grams/mile Weighted average of 1988 to present automobile model years; Table C.4, CCARGRPMethane emission factor 0.049 grams/mile Weighted average of 1988 to present automobile model years; Table C.4, CCARGRPEmission EstimatesCO2(weekdays) 171.4 lb/dayN2O (weekdays) 0.020 lb/dayMethane (weekdays) 0.019 lb/dayCO2(weekends) 114.3 lb/dayN2O (weekends) 0.013 lb/dayMethane (weekends) 0.013 lb/dayConversion of non-CO2GHGs to CO2equivalentsCO2(weekdays) 171.4 lb/dayN2O - CO2equivalents (weekdays) 6.2 lb/dayMethane - CO2equivalents (weekdays) 0.4 lb/dayTotal CO2equivalents (weekdays) 177.9 lb/dayCO2(weekends) 114.3 lb/dayN2O - CO2equivalents (weekends) 4.1 lb/dayMethane - CO2equivalents (weekends) 0.3 lb/dayTotal CO2equivalents (weekends) 118.6 lb/dayCO2(annual) 28.2 tons/yrN2O - CO2equivalents (annual) 1.0 tons/yrMethane - CO2equivalents (annual) 0.1 tons/yrTotal CO2equivalents (annual) 29.3 tons/yrNotes:1Based on methodology described in theCalifornia Climate Action Registry General Reporting Protocol (CCARGRP)(March 2007).GHGs resulting from vehicle travel for additional personnel associated with anode bake furnace scrubber system1ParametersReferenceAdditional operating personnel 3 One additional full-time operator per shift, three shifts per day (assumption)Additional maintenance personnel (weekdays) 3 Two additional full-time maintenance personnel, one shift per day, plus one additional halftime equivalent maintenancepersonnel for off-shifts(assumption)Additional maintenance personnel (weekends) 1.5 One additional half-time equivalent maintenance personnel for off-shifts (assumption)Total additional personnel (weekdays) 6Total additional personnel (weekends) 4.5Daily round trip distance 20 miles/trip Assumption (distance from plant to downtown Bellingham, WA is approximately 10 miles)Total daily mileage (weekdays) 120 miles/dayTotal daily mileage (weekends) 90 miles/dayAverage fuel economy 20.3 miles/gallon Fleet average (1988 to 2007 model years); USEPA, Light-Duty Automotive Technologyand Fuel EconomyTrends: 1975 to 2007, Table 1(Cars and Trucks)N2O global warming potential (GWP) 310 Table III.6.1 - CCARGRPMethane GWP 21 Table III.6.1 - CCARGRPEmission FactorsReferenceCO2emission factor 8.78 kg/gallon Non-CA gasoline; Table C.3, CCARGRPN2O emission factor 0.050 grams/mile Weighted average of 1988 to present automobile model years; Table C.4, CCARGRPMethane emission factor 0.049 grams/mile Weighted average of 1988 to present automobile model years; Table C.4, CCARGRPEmission EstimatesCO2(weekdays) 114.3 lb/dayN2O (weekdays) 0.013 lb/dayMethane (weekdays) 0.013 lb/dayCO2(weekends) 85.7 lb/dayN2O (weekends) 0.0099 lb/dayMethane (weekends) 0.0096 lb/dayConversion of non-CO2GHGs to CO2equivalentsCO2(weekdays) 114.3 lb/dayN2O - CO2equivalents (weekdays) 4.1 lb/dayMethane - CO2equivalents (weekdays) 0.3 lb/dayTotal CO2equivalents (weekdays) 118.6 lb/dayCO2(weekends) 85.7 lb/dayN2O - CO2equivalents (weekends) 3.1 lb/dayMethane - CO2equivalents (weekends) 0.2 lb/dayTotal CO2equivalents (weekends) 89.0 lb/dayCO2(annual) 19.3 tons/yrN2O - CO2equivalents (annual) 0.7 tons/yrMethane - CO2equivalents (annual) 0.05 tons/yrTotal CO2equivalents (annual) 20.0 tons/yrNotes:1Based on methodology described in theCalifornia Climate Action Registry General Reporting Protocol (CCARGRP)(March 2007).

# Alcoa Primary Metals

USA



# Pre-Feasibility Report

SO2 Scrubbing for the INTALCO Primary Aluminum Smelter

H-325640 2 November 5, 2007Alcoa Primary Metals - SO2 Scrubbing fo r the INTALCO Primary Aluminum Smelter Pre-Feasibility Report

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### Project Report
PR325640.10001 Rev. 2, Page 1



### November 5, 2007


## Alcoa Primary Metals SO2 Scrubbing for the INTALCO Primary Aluminum Smelter

DISTRIBUTION
Alcoa Hatch Michael Palazzolo Martin Desmeules James Schon Don Wilson Stephan Broek



## Pre-Feasibility Report

Table of Contents

1. Summary ........................................................................................................................ ......................... 2

2. Introduction ................................................................................................................... ......................... 4

2.1 Process Selection .............................................................................................................. ............. 4
2.2 FGD System Configuration....................................................................................................... ...... 4

3. FGD System for the Potrooms.................................................................................................... ............. 6

3.1 Design Basis................................................................................................................... ................ 6
3.2 Process description ............................................................................................................ ............ 7
3.3 Mass balance of an FGD system treating the fumes from the potrooms........................................... 8

3.4 Consumables .................................................................................................................... ........... 10
3.5 Scope of work.................................................................................................................. ............ 10

4. FGD System for the Baking Furnace.............................................................................................. ........ 12

4.1 Design basis................................................................................................................... .............. 12
4.2 Process description ............................................................................................................ .......... 13
4.3 Mass balance for an FGD system to treat the fumes from the baking furnace................................ 14

4.4 Consumables .................................................................................................................... ........... 15

4.5 Scope of work.................................................................................................................. ............ 15

5. Capital cost estimates......................................................................................................... ................... 18

5.1 Methodology .................................................................................................................... ........... 18
5.2 Cost estimate for the potline FGD system..................................................................................... 20

5.3 Cost estimate for the baking furnace FGD system......................................................................... 20Alcoa Primary Metals - SO2 Scrubbing fo r the INTALCO Primary Aluminum Smelter Pre-Feasibility Report

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## 1. Summary

This report is a pre-feasibility study for the implementation of flue gas desulphurisation (FGD) systems at the primary aluminum smelter of Intalco Works in Ferndale, Washington. The study focus is on controlling the SO 2 

### emissions from the potrooms and from the baking furnace. The target
removal is set for 95% of the released SO 2 

### at the emissions sources.

For both solutions the well known Limestone/Gypsum Forced Oxidation (LSFO) process is applied. This widely used process uses limestone as a re agent and produces gypsum as a by-product. This product can either be reused or safely stored in a landfill.

Potlines

For the potlines the selected configuration is a gas collection system that connects to each dry scrubbing system and redirects all fumes to a central FGD system. The FGD system comprises of two large open spray tower type absorbers in whic h the fumes are washed and cleaned. One such unit is operating while the second is on standby. The limestone handling as well as the gypsum recovery is done in a single plant serving both absorbers. Appropriate redundancy is built-in to ensure the 100% availability that is required in a smelter that operates 24 hrs a day, every day of the

year.
The FGD system is designed to handle 1,814,880 SCFM of fumes from the potrooms. This equates to an annual SO2 emission reduction of 7,875 tpa. The associated limestone consumption is 14,244 tpa while the water intake is 500,000 US Gallons per day. The annual gypsum production is 27,130 ton.

The cost estimate is a factored cost estimate using information derived from previous studies and cost databases. The following table presents the results for the potline FGD system.

Table 1: Capital cost estimate for the potline FGD system

All values in million USD Equipment Installation Subtotal Reagent feed system $6.98 $6.98 $13.96 SO2 removal system $25.24 $25.24 $50.49 Flue gas system $21.64 $21.64 $43.27 Byproduct handling $7.17 $7.17 $14.33 General support equipment $10.11 $10.11 $20.23

TOTAL PROCESS CAPITAL $71.14 $71.14 $142.28 POTLINE FGD



### Anode Baking Furnace

A smaller source of SO 2 

### emissions are the fumes from the anode baking furnace. In this case a single collector duct is tied into the existing dry scrubbing system to connect to the FGD system. This FGD system is much smaller but has the same configuration as the potline FGD system. It provides for 100% available scrubbing.Alcoa Primary Metals - SO2 Scrubbing fo r the INTALCO Primary Aluminum Smelter Pre-Feasibility Report

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### The FGD system is designed to handle 172,510 SCFM of fumes from the potrooms. This equates to
an annual SO 2 

### emission reduction of 175 tpa. The asso ciated limestone consumption is 342 tpa while the water intake is 35,000 US Gallons per day. The annual gypsum production is 640 ton.

The cost estimate is a factored cost estimate using information derived from previous studies and cost databases. The following table presents the results for the potline FGD system.

Table 2: Capital cost estimate for the baking furnace FGD system

All values in million USD Equipment Installation Subtotal Reagent feed system $0.36 $0.36 $0.72 SO2 removal system $4.13 $4.13 $8.25 Flue gas system $3.54 $3.54 $7.07 Byproduct handling $0.36 $0.36 $0.71 General support equipment $0.50 $0.50 $1.01

TOTAL PROCESS CAPITAL $8.88 $8.88 $17.76 BAKING FURNACE FGDAlcoa Primary Metals - SO2 Scrubbing fo r the INTALCO Primary Aluminum Smelter Pre-Feasibility Report

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## 2. Introduction

This report presents a pre-feasibility study on the implementation of FGD systems at the Intalco primary aluminum smelter in Ferndale, Washington.

The aluminum smelter has two prim ary sources of sulphur emissions, one is the pot rooms and the second is the anode baking furnace. This report includes the design and cost information on a dedicated FGD system for each of these main sources.



### 2.1 Process Selection In previous studies Best Available Technologies were identified. For studies at the Alcoa Tennessee smelter the limestone-gypsum forced oxidation (LSFO ) process was selected for further evaluation .



### 2.2 FGD System Configuration

2.2.1 Pot room system The FGD system is designed to capture fumes fr om the potrooms under fully operational conditions.

A comprehensive evaluation was done to see what configuration would be more effective: a set of scrubbing towers per potline (equal to two potrooms) or one central system with long collector ducts feeding into the central system.

Two main criteria were used to decide what configuration to apply: 1) The sum of all fumes must be treated in one scrubbing tower and 2) maintenance must be minimized.

The first criteria was met after calculations show ed that the sum of all flows would result in a scrubbing tower with a diameter of 60 feet. A large diameter tower is not uncommon and several FGD wet scrubbing towers with diameters of this size have been constructed world-wide. Having many smaller scrubbing towers versus one large tower design combined with collector ducts made of regular gauge steel is considered to be less cost effective than the latter case.

The second criteria concerns maintenance. The LSFO process basically is the circulation of a slurry of water, limestone and gypsum. It is abrasive and to a certain extent corrosive. Therefore, a lot of maintenance activity is associated with the circulation pumps and the scrubbing tower. Based on the design criteria of minimized maintenance, the selected system configuration was based on a single large scrubbing tower that would treat all of the pot room ventilation flows. Potroom flow would be combined into a single stream by a network of ducts, collecting fume from the current dry gas cleaning systems. .

An additional consideration was the continuous operation of a smelter. A single scrubbing tower must be taken down for service five to ten days per year (conservatively). This means that during periods of maintenance, there would be no scrubbing of SO 2 

### if a single scrubbing tower were installed. To provide 100 percent scrubbing availability during maintenance periods, a second scrubbing tower of the same size would be added to the design to ensure continuous SO 2 

### treatment during periods when the first scrubbing tower is taken out of service.Alcoa Primary Metals - SO2 Scrubbing fo r the INTALCO Primary Aluminum Smelter Pre-Feasibility Report

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### 2.2.2 Baking furnace system The FGD system for the baking furnace is of a simpler concept. The baking furnace is currently operated with an evaporative cooling tower followed by a dry gas cleaning system. The new FGD system will be connected downstream to the dry gas cleaning unit.

Anode Baking Furnace Evaporative gas cooler

Dry gas cleaning (New) SO 2 Control system



### Figure 1: Overall gas cleaning concept for the anode baking furnace.Alcoa Primary Metals - SO2 Scrubbing fo r the INTALCO Primary Aluminum Smelter Pre-Feasibility Report

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## 3. FGD System for the Potrooms

3.1 Design Basis The design basis for both scrubbing systems has been based on technical process information provided by Alcoa. The information is ba sed on actual operating conditions and operating
information for Intalco Works.

The following table presents the design basis for the FGD system serving the potlines.

Table 3: Design basis for the potline FGD system at Intalco Works

Design parameter Unit Value Number of potrooms in service - 6 Number of GTCs per potroom - 1

Total number of GTCs connected - 6 No. of reduction cells per potroom - 120 Ventilation flow for one reduction cell ACFM 3,000 (@212 °F)
SCFM (70 °F) 2,354 Air addition in each dry gas clea ning unit SCFM 20,000 (Estimate) Total flow of fumes to the FGD system SCFM 1,814,880 Nominal fume temperature °F 180

Composition of the fumes at the inlet of the FGD system Sulphur dioxide (SO 2 ) ppmv 105 (300 mg/Nm 3 ) Hydrogen fluoride (HF g ) mg/Nm 3 5 Water vapour (H 2 O) vol% 3 Particulates mg/Nm 3 10



### In addition, the following system requirements are applied in the design of the system.

Table 4: Design requirements

Aspect Unit Requirement

Desulphurization efficiency % Min. 95

Removal efficiency of particulates and
fluorides - No increment

Residual droplets mg/Nm 3 

### Max. 100Alcoa Primary Metals - SO2 Scrubbing fo r the INTALCO Primary Aluminum Smelter Pre-Feasibility Report

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### Spare scrubbing capacity % 100(1 full scrubbing tower standby/no spare spray layers inside one scrubbing tower)



### Limestone properties:

- CaCO3 content

- Reactivity

- Particle size distribution %

Microns Min. 85

Must comply with vendor specification.

96% < 75 microns (To be verified with vendor)

Gypsum by-product:

- Application

- Sulfate / Sulfite ratio

- Residual moisture -

-

% Disposal

99 / 1 (Full oxidation)

15

Chloride concentration in the slurry ppm 5,500

Waste water requirements - None.



### 3.2 Process description The fumes from the potrooms are extracted from th e stack of the existing dry gas cleaning systems (GTCs). Each stack will be provided with an adaptor and a valve that connects to the collector duct for the FGD system. This design allows for the GTCs to continue operation as it is today. The goal is that the GTCs do not “see” the additional FGD system . To achieve this, pressure control is applied in the collector duct whereby the pressure at the GTCs is maintained constant by a dedicated fan in the
collector duct.

The collector ducts go over the potrooms and come together at the central FGD system. In each collector duct a damper is added in order to isolate an individual duct.

The combined fumes are blown into the scrubbing tower. The tower is an open spray design and has two spray layers installed. Each layer has a dedicated recycle pump. Because there is a second scrubbing tower in standby there is no need to have additional spray layers installed.

Above the spray layers are two chevron type horizontal mist eliminators. Below the lower mist eliminator is the main wash system and between the two mist eliminators is a second wash system. There is no need for a third wash system at the top of the stack as this can be washed manually once

a year.
The two scrubbing towers vent to a combined stack that emits cleaned gases at a level approximately 150 feet above the ground.Alcoa Primary Metals - SO2 Scrubbing fo r the INTALCO Primary Aluminum Smelter Pre-Feasibility Report

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### Two slurry pumps recycle the slurry through the spray levels with the appropriate nozzles. These
can be either hollow cone or full cone nozzles. The slurry is semi-atomized into a spray of droplets that mix with the incoming fumes.

The bottom of the scrubbing tower fulfills several functions. It has to provide enough liquid head for the pumps, it provides for enough retention time for the gypsum to grow into a desirable particle size distribution so that is can be dewatered properly, it is used for pH control, and it provides for the means to oxidize all the sulphite into sulphate.

The fumes from the potroom contain close to 20 vo lume percent of oxygen. Experience with similar scrubbing systems of this type shows that 20 volume percent of oxygen is enough to provide full oxidation of sulphite into sulphate. However, for safety reasons (one wants to have the slurry fully oxidized at all times), a small amount of comp ressed air is introduced by a small blower.

A bleed system withdraws slurry from the scrubbing tower. A loop is used to measure the pH while the rest is fed to a hydroclone battery. This is the first stage of solids dewatering. The overflow of the hydroclones is returned to the scrubbing tower while the underflow is collected and fed to a vacuum filter. The system is engineered such that the underflow can be fed directly onto the filter.

The thickened slurry is dewatered on the vacuum filter to about 85 percent dry solids. The filtrate and wash/rinse water is collected and returned to the scrubbing tower. The gypsum is left with 15 percent moisture which prevents the need for a liquid purge stream otherwise needed to purge impurities from the process. The gypsum is moist e nough to be stored in semi open warehouse and can be loaded into dump trucks and taken to a third party.

Limestone is delivered in powder form and added to the process water and fed from the slurry tank to the scrubbing tower via a pH control system.



### 3.3 Mass balance of an FGD system tr eating the fumes from the potrooms

Limestone slurry storage tank Limestone silo Make-up
water

Wash & rinse wate r

Gypsum product Filtrate tank Vacuum Belt filte r Hydroclones

Belt filter feed tank Scrubbe r

Oxidation
air Gas outletAlcoa Primary Metals - SO2 Scrubbing fo r the INTALCO Primary Aluminum Smelter Pre-Feasibility Report

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N2 1,025,647 6,153,884 4,514 6,158,398 O2 285,454 1,712,725 1,368 1,713,645 CO2 413 2,479 3 3,751 H2O 25,375 152,251 82 324,134 H20 ( l )

- - - 653 SO2 316 1,893 - 95 SO3 - - - - HCl - - - - HF 5 32 - 1 Particulate 5 32 - 11 Mass flow ( lb/hr ) 1,337,216 8,023,295 5,967 8,200,687 Volume flow ( ACFM ) 369,114 2,214,685 1,365 1,984,246 Volume flow ( SCFM ) 302,481 1,814,887 1,343 1,877,773 Temperature ( °F ) 189 189 77 98 Pressure ( Inch WG ) 407.7 407.7 405.3 405.3

LIQUID / SOLIDS (lb/hr) Absorber recycle Absorber bleed pH loop Hydroclone overflow Hydroclone underflow

Liquid 30,849,560 78,847 25,708 46,671 6,467 Solids 5,444,040 13,914 4,537 4,086 5,291 Total 36,293,600 92,761 30,245 50,757 11,759 Solids concentration 15 15 15 8 45 Densit y ( SG ) 1.10 1.10 1.10 1.05 1.34 Flow ( GPM ) 66,050 169 55 96 18

LIQUID / SOLIDS (lb/hr) Vacuum filter feed Filter wash
water Rinse water Filtrate Gypsum

Liquid 6,467 - 10,530 16,068 929 Solids 5,291 - - 26 5,265 Total 11,759 - 10,530 16,095 6,194 Solids concentration 45 - - 0.2 85 Densit y ( SG ) 1.34 1.00 1.00 1.01 1.50 Flow ( GPM ) 18 - 21 32 -

LIQUID / SOLIDS (lb/hr) Limestone Process water Limestone slurry to
absorber

Liquid - 9,757 9,757 Solids 3,252 - 3,252 Total 3,252 9,757 13,009 Solids concentration 100 - 25 Densit y ( SG ) 2.80 1.00 1.19 Flow ( GPM )

- - -

LIQUID / SOLIDS (lb/hr) Process water
intake Water to
absorber Water to
limestone preparation Water to
gypsum dewatering Water for
oxidation air

cooling

Liquid 174,362 152,973 9,757 10,530 1,102 Solids - - - - - Total 174,362 152,973 9,757 10,530 1,102 Solids concentration - - - - - Densit y ( SG ) 1.00 1.00 1.00 1.00 1.00 Flow ( GPM ) 348 306 19 21 2Alcoa Primary Metals - SO2 Scrubbing fo r the INTALCO Primary Aluminum Smelter Pre-Feasibility Report

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### 3.4 Consumables The following list presents the main consumables for the FGD system treating the fumes from the
potrooms.

Table 5: Consumables

Consumable Unit Value

Process water US Gallons per day 500,000

Limestone Short tons per day 39

Compressed air SCFM 150

Electric power kWh/h 7,400



### 3.5 Scope of work The following is the scope of work used to develop the cost estimates. The overall basis is a lump sum contract with a single vendor/contractor.

GTC connections

All GTC stacks will be equipped with an adaptor that connect them to common scrubber ducts. The adaptors fit on the stacks and a valve is included.

Collector ducts

Each GTC will be connected to a collector duct and fan system. There are six collector ducts and fan systems, including isolation valves. The work includes structural steel work needed to position the collector ducts over the potrooms and to the central FGD system.

Scrubbing tower

Two scrubbing towers are included and they both are identical in size and have the same equipment and controls so that they can be operated independently from each other.

On the bottom, two 48-inch diameter pipes are connected to the tower and the suction of the recycle pumps. Each suction pipe has included a butterfly type valve to isolate a pump. Each recycle pump operates at 33,000 GPM. The discharge is also 48 inches in diameter and goes up the spray levels. Inside the scrubbing tower two spray levels are installed that form a network of smaller diameter pipes in order to provide equal distribution of the slurry over the cross section of the tower.

A common water supply system (tank and pumps) ser ves both scrubbing towers. It will connect to
the three wash levels above the mist eliminators.

A common air compressor is included for the supply of oxidation air. To prevent clogging of the line where air is injected, water is injected to saturate the air before it hits the slurry in the scrubbing

tower.Alcoa Primary Metals - SO2 Scrubbing fo r the INTALCO Primary Aluminum Smelter Pre-Feasibility Report

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### Primary dewatering

A first dewatering step is needed to create the right slurry density for final dewatering. A set of hydroclones is included to thicken the slurry from 15 percent solids to about 45 percent. The hydroclone set has included a chute to intercept the thickened slurry in case of a line blockage. In that case all slurry is returned.

Secondary dewatering

A vacuum belt filter is included for the dewatering of the gypsum slurry. This has included a vacuum system, wash & rinse system and discharge chute. In order to provide limited redundancy, two 75 percent capacity filters are included.

A filtrate collection system is incorporated to return any liquids to the scrubbing tower.

The vacuum filters are elevated in a building and the lower section has a dump & storage area for the gypsum. A front loader picks up the gypsum and dumps it into a dump truck for disposal.

Limestone system

The scope of work also includes an integrated silo and slurry preparation tank. Trucks are equipped with unloading equipment to deliver the limestone powder into the tank. The tank is provided with an agitator and pump set. The pumps are connected to a loop that passes both scrubbing towers. Slurry is drawn from the loop based on pH control. Dosing valves are included.

General systems and facilities

To prevent any uncontrolled releases into the environm ent, a slurry collection system is included in and around the central system to collect spills and overflows. A sump with a submerged pump is included and all slurry is transferred to the operating scrubbing tower.

The vendor will provide all automation and control systems to minimize manual intervention required from operating personnel.

Chemical sampling and analysis is added to the current work load of the laboratory staff. Some new equipment like slurry analysers will be provided.Alcoa Primary Metals - SO2 Scrubbing fo r the INTALCO Primary Aluminum Smelter Pre-Feasibility Report

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## 4. FGD System for the Baking Furnace

4.1 Design basis The following table presents the design basis for the FGD system serving the baking furnace.

Table 6: Design basis for the baking furnace FGD system – Intalco Works

Design parameter Unit Value

Number of fires in service - All Total flow of fumes in the existing stack ACFM 216,000 Nominal fume temperature °F 205

Composition of the baking furnace fumes at the inlet of the FGD system Sulphur dioxide (SO 2 ) ppmv 25 (5.33 grams/sec) Hydrogen fluoride (HF g ) mg/Nm 3 5 Water vapour (H 2 O) vol% 20.7 Particulates mg/Nm 3 <5 (0.35 grams/sec)



### In addition, the following system requirements are applied in the design of the system.

Table 7: Design requirements for the baking furnace FGD system

Aspect Unit Requirement

Desulphurization efficiency % Min. 95

Removal efficiency of particulates and
fluorides - No increment

Residual droplets mg/Nm 3 

### Max. 100

Spare scrubbing capacity % 100(1 full scrubbing tower standby/no spare spray layers inside one scrubbing tower)



### Limestone properties:

- CaCO3 content

- Reactivity

- Particle size distribution %

Microns Min. 85

Must comply with vendor specification.

96% < 75 microns (To be verified with vendor)Alcoa Primary Metals - SO2 Scrubbing fo r the INTALCO Primary Aluminum Smelter Pre-Feasibility Report

ISO 9001 PR325640.10001 , Rev. 2

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### Gypsum by-product:

- Application

- Sulfate / Sulfite ratio

- Residual moisture -

-

% Disposal

99 / 1 (Full oxidation)

15

Chloride concentration in the slurry ppm 7,500

Waste water requirements - None.



### 4.2 Process description The fumes from the ring duct are passed on to the evaporative cooling tower to cool the fumes and to precipitate some of the tars. The fumes are led into the dry gas cleaning system in which alumina is injected for particulate, tar, and fluoride removal. The fumes pass the bag filters and enter the plenum outlet.

The combined fumes are blown into the scrubbing tower. The tower is an open spray design and has two spray layers. Each layer has a dedicated recycle pump. Because there is a second scrubbing tower in standby there is no need to have additional spray layers.

Above the spray layers are two chevron type horizontal mist eliminators. Below the lower mist eliminator is the main wash system and between the two mist eliminators is a second wash system. There is no need for a third wash system at the top of the stack as this can be washed manually once

a year.
The scrubbing tower has an integrated stack that emits the clean gases at a level approximately 150 feet above the ground.

Two slurry pumps recycle the slurry through the spray levels with the appropriate nozzles. These
can be either hollow cone or full cone nozzles. The slurry is semi-atomized into a spray of droplets and washes the incoming fumes.

The bottom of the scrubbing tower fulfills several functions. It has to provide enough liquid head for the pumps, it provides for enough retention time for the gypsum to grow into a desirable particle size distribution so that is can be dewatered properly, it is used for pH control, and it provides for the means to oxidize all the sulphite into sulphate . All this is incorporated within the design.

Air is injected under the liquid level of the scrubber tower bottom to provide for the required oxidation sulphites into sulphates. A small blower is used to inject the air.

A bleed system withdraws slurry from the scrubbing tower. A loop is used to measure the pH while the rest is fed to a hydroclone battery. This is the first stage of solids dewatering. The overflow of the hydroclones is returned to the scrubbing tower while the underflow is collected and fed to a vacuum filter. The system is engineered such that the underflow can be fed directly onto the filter.

The thickened slurry is dewatered on the vacuum filter to about 85 percent dry solids. The filtrate and wash/rinse water is collected and returned to the scrubbing tower. The gypsum is left with 15 percent moisture which will prevents the need fo r a liquid purge stream othe rwise needed to purgeAlcoa Primary Metals - SO2 Scrubbing fo r the INTALCO Primary Aluminum Smelter Pre-Feasibility Report

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### impurities from the process. The gypsum is moist e nough to be stored in semi open warehouse and can be loaded into dump trucks and taken to a third party.

Limestone is delivered in powder form and added to the process water and fed from the slurry tank to the scrubbing tower via a pH control system.



### 4.3 Mass balance for an FGD system to treat the fumes from th e baking furnace

GAS (lb/hr) Fumes from dry gas cleaning

system Oxidation air Clean gases

N2 516,752 224 516,977 O2 24,683 68 24,741 CO2 88,656 0 88,687 H2O 99,881 4 111,652 H20 ( l )

- - 61 SO2 42 - 2 SO3 - - - HCl - - - HF 3 - 0 Particulate 3 - 1 Mass flow ( lb/hr ) 730,020 297 742,121 Volume flow ( ACFM ) 218,111 68 202,525 Volume flow ( SCFM ) 172,510 67 176,787 Temperature ( °F ) 212 77 145 Pressure ( Inch WG ) 407.7 405.3 405.3

LIQUID / SOLIDS (lb/hr) Absorber recycle Absorber bleed pH loop Hydroclone overflow Hydroclone underflow

Liquid 1,616,844 26,676 25,427 1,097 152 Solids 285,325 4,707 4,487 96 124 Total 1,902,170 31,383 29,914 1,193 276 Solids concentration 15 15 15 8.05 45 Densit y ( SG ) 1.09 1.09 1.09 1.02 1.31 Flow ( GPM ) 3,500 58 55 2.3 0.4 Limestone slurry storage tank Limestone silo Make-up
water

Wash & rinse wate r

Gypsum product Filtrate tank Vacuum Belt filte r Hydroclones

Belt filter feed tank Scrubbe r

Oxidation air Gas outletAlcoa Primary Metals - SO2 Scrubbing fo r the INTALCO Primary Aluminum Smelter Pre-Feasibility Report

ISO 9001 PR325640.10001 , Rev. 2

325640-RPT-CA01-10001.Doc © Hatch 2006/03 a LIQUID / SOLIDS (lb/hr) Vacuum filter
feed Filter wash
water Rinse water Filtrate Gypsum

Liquid 152 - 247 378 22 Solids 124 - - 1 124 Total 276 - 247 378 146 Solids concentration 45 - - 0 85 Densit y ( SG ) 1.33 1.00 1.00 1.00 1.50 Flow ( GPM ) 0.4 - 0.5 0.8 -

LIQUID / SOLIDS (lb/hr) Limestone Process water Limestone slurry to
absorber

Li q uid - 235 235 Solids 78 - 78 Total 78 235 314 Solids concentration 100 - 25 Densit y ( SG ) 2.80 1.19 1.00 Flow ( GPM )

- 0.5 0.5

LIQUID / SOLIDS (lb/hr) Process water
intake Water to
absorber Water to
limestone preparation Water to
gypsum dewatering Water for
oxidation air

cooling

Liquid 11,865 10,279 235 247 1,102 Solids - - - - - Total 11,865 10,279 235 247 1,102 Solids concentration - - - - - Densit y ( SG ) 1.00 1.00 1.00 1.00 1.00 Flow ( GPM ) 24 21 0.5 0.5 2.2



### 4.4 Consumables The following list presents the main consumables for the control system.

Table 8: Baking furnace FGD consumables

Consumable Unit Value

Process water US Gallons per day 35,000

Limestone Short tons per day 1.0

Compressed air SCFM 50

Electric power kWh/h 750



### 4.5 Scope of work The following is the scope of work used to develop the cost estimates. The overall basis is a lump sum contract with a single vendor/contractor.Alcoa Primary Metals - SO2 Scrubbing fo r the INTALCO Primary Aluminum Smelter Pre-Feasibility Report

ISO 9001 PR325640.10001 , Rev. 2

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### GTC connection

New fans will be installed to replace the existing fans downstream of the dry gas cleaning system. The fans are provided with an inlet manifold that connects to the scrubbing towers. Isolation dampers are included to separate one scrubbing tower from operation.

Scrubbing tower

Two scrubbing towers are included and they both are identical in size and have the same equipment and controls so that they can operate independently from each other.

The bottom two 4 inch diameter pipes are connected to the tower and the suction of the recycle pumps. Each suction pipe has included a butterfly type valve to isolate the pump. Each recycle pump operates at 1,750 GPM. The discharge is also 4 inches in diameter and goes to the spray levels. Inside the scrubbing tower two spray levels are installed and form a network of smaller diameter pipes in order to provide equal distribution of the slurry over the cross section of the tower.

A common water supply system (tank and pumps) ser ves both scrubbing towers. It will connect to
the three wash levels around the mist eliminators.

A common air compressor is included for the supply of oxidation air. To prevent clogging of the line where air is injected, water is injected to saturate the air before it hits the slurry in the scrubbing

tower.

Primary dewatering

A first dewatering step is needed to create the right slurry density for final dewatering. A set of hydroclones is included to thicken the slurry from 15 percent solids to about 45 percent. The hydroclone set has included a chute to intercept the thickened slurry in case nothing can go to the filter. In that case all slurry is returned.

Secondary dewatering

A vacuum belt filter is included for the dewatering of the gypsum slurry. This has included a vacuum system, wash & rinse system and discharge chute. In order to provide limited redundancy two 75 percent capacity filters are included.

A filtrate collection system is incorporated to return any liquids to the scrubbing tower.

The vacuum filters are elevated in a building and the lower section has a dump & storage area for the gypsum. A front loader picks up the gypsum and dumps it into a dump truck for disposal.

Limestone system

The scope of work also includes an integrated silo and slurry preparation tank. Trucks are equipped with unloading equipment to deliver the limestone powder into the tank. The tank is provided with an agitator and pump set. The pumps are connected to a loop that passes both scrubbing towers. Slurry is drawn from the loop based on pH control. Dosing valves are included.Alcoa Primary Metals - SO2 Scrubbing fo r the INTALCO Primary Aluminum Smelter Pre-Feasibility Report

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### General systems and facilities

To prevent any uncontrolled releases into the environm ent, a slurry collection system is included in and around the central system to collect spills and overflows. A sump with a submerged pump is included and all slurry is transferred to the operating scrubbing tower.

The vendor will provide all automation and control systems to minimize manual intervention required from operating personnel.

Chemical sampling and analysis is added to the current work load of the laboratory staff. Some new equipment like slurry analysers will be provided.Alcoa Primary Metals - SO2 Scrubbing fo r the INTALCO Primary Aluminum Smelter Pre-Feasibility Report

ISO 9001 PR325640.10001 , Rev. 2

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## 5. Capital cost estimates

In this section are provided all capital cost estimates for both the potroom FGD system and the baking furnace FGD system.

All equipment cost estimates are based on cost proposals provided by Alstom Power and Babcock Power for Alcoa’s smelter in Alcoa, TN and a pre-feasibility study prepared by Hatch for the Alcoa TN smelter, entitled “SO 2 

### Scrubber for Alcoa Tennessee” (June 7, 2007 (Hatch report number PRH322820.0001).



### 5.1 Methodology For this high level study, costs have been scaled based on specific design and operational aspects of FGD systems. The key three scaling parameters are the volume of gases going through, the amount of limestone consumed and the amount of gypsum by-p roduct produced. These three parameters help scale certain parts of the FGD system scale properly; however, to apply such method a break down is required for the cost provided in the study for Alcoa Tennessee works. This was not presented in the previous study and as such it has been included here.

Based on Hatch’ experience with cost analysis of FGD systems the following break down is derived and applied in this study:

Table 9: Break down of FGD sub system costs

Sub system Fraction of cost of the total

Reagent feed system 10% of TPC

SO 2 

### removal system 35% of TPC

Flue gas system 30% of TPC

By-product handling 10% of TPC

General support equipment 15% of TPC

TOTAL PROCESS CAPITAL (TPC) 100%Alcoa Primary Metals - SO2 Scrubbing fo r the INTALCO Primary Aluminum Smelter Pre-Feasibility Report

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### Table 10: Cost break down of the Alcoa Tennessee works FGD system.

All values in million USD Equipment Installation Subtotal Reagent feed system $6.50 $6.50 $13.00 SO2 removal system $22.75 $22.75 $45.50 Flue gas system $19.50 $19.50 $39.00 Byproduct handling $6.50 $6.50 $13.00 General support equipment $9.75 $9.75 $19.50

TOTAL PROCESS CAPITAL $65.00 $65.00 $130.00 TENNESSEE POTLINE FGD



### This table is used as a basis for the tables that fo llow and represent the results for the Intalco smelter.

Next step in the methodology is to convert the sub system costs from one case to another. For this the general formula of cost scaling is applied:

n


### Q Q P P        

× =

1 2 1 2



### From the Hatch database of cost information related to large FGD systems is further derived:

Table 11: Exponent n for scaled cost estimation.

Sub system Exponent n

Reagent feed system 0.33

SO 2 

### removal system 0.50

Flue gas system 0.50

By-product handling 0.40

General support equipment 0.15

These exponents apply to large scale FGD units. For the baking furnace, which is much smaller, in the report is applied an exponent of 0.8 for all s ub systems. This is consistent with earlier work prepared by the Alcoa team.

In order to scale costs between the different case s the following scaling factors have been applied:Alcoa Primary Metals - SO2 Scrubbing fo r the INTALCO Primary Aluminum Smelter Pre-Feasibility Report

ISO 9001 PR325640.10001 , Rev. 2

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### Table 12: Scaling parameters.

Scaling value

Parameter Tennessee (Q 1 

### ) Intalco Potline (Q 2 

### ) Intalco Baking Furnace (Q 2 

### )

Clean flue gas flow (ACFM) 1,582,432 1,948,246 202,525

Limestone consumption (tpa) 10,407 12,921 315

Gypsum production (tpa) 19,272 24,607 578

Example:



### 59

. 9 407

, 10 921

, 12 93

. 8 33

. 0

2 

### =      

= x P

This example shows that for Intalco the estimate cost s for the reagent (limestone) feed system is 9.59
million USD.



### 5.2 Cost estimate for the potline FGD system The following table presents the results from the cost estimation for the FGD system, servicing the potline ventilation fumes at Intalco.

Table 13: Cost estimate for the Intalco Works potline FGD system

All values in million USD Equipment Installation Subtotal Reagent feed system $6.98 $6.98 $13.96 SO2 removal system $25.24 $25.24 $50.49 Flue gas system $21.64 $21.64 $43.27 Byproduct handling $7.17 $7.17 $14.33 General support equipment $10.11 $10.11 $20.23

TOTAL PROCESS CAPITAL $71.14 $71.14 $142.28 POTLINE FGD



### 5.3 Cost estimate for the b aking furnace FGD system The following table presents the results from the cost estimation for the FGD system, servicing the potline ventilation fumes at Intalco.Alcoa Primary Metals - SO2 Scrubbing fo r the INTALCO Primary Aluminum Smelter Pre-Feasibility Report

ISO 9001 PR325640.10001 , Rev. 2

325640-RPT-CA01-10001.Doc © Hatch 2006/03 a 

### Table 14: Cost estimate for the Intalco Works baking furnace FGD system.

All values in million USD Equipment Installation Subtotal Reagent feed system $0.36 $0.36 $0.72 SO2 removal system $4.13 $4.13 $8.25 Flue gas system $3.54 $3.54 $7.07 Byproduct handling $0.36 $0.36 $0.71 General support equipment $0.50 $0.50 $1.01

TOTAL PROCESS CAPITAL $8.88 $8.88 $17.76 BAKING FURNACE FGD



### S. Broek

### Sheridan Science and Technology Park, 2800 Speakman Drive Mississauga, Ontario, Canada L5K 2R7 Tel 905 855 7600  Fax 905 855 8270

### 39156 Federal Register / Vol. 70, No. 128 / Wednesday, July 6, 2005 / Rules and Regulations

requirements, Sulfur oxides, Volatile organic compounds.

Dated: June 15, 2005. Stephen L. Johnson, Administrator.

■ For the reasons set forth in the preamble, part 51 of chapter I of title 40 of the Code of Federal Regulations is amended as follows:

**PART 51**

**— REQUIREMENTS FOR**  **PREPARATION, ADOPTION, AND SUBMITTAL OF IMPLEMENTATION**  **PLANS**

■ 1. The authority citation for part 51 continues to read as follows:

Authority: 23 U.S.C. 101; 42 U.S.C. 7410

– 7671q.

■ 2. Section 51.302 is amended by revising paragraph (c)(4)(iii) to read as follows:

**§ 51.302 Implementation control strategies**  **for reasonably attributable visibility impairment.** 
* * * * *

(c) * * * (4) * * * (iii) BART must be determined for fossil-fuel fired generating plants having a total generating capacity in excess of 750 megawatts pursuant to ‘‘ Guidelines for Determining Best Available Retrofit Technology for Coal-fired Power Plants and Other Existing Stationary Facilities ’’ (1980), which is incorporated by reference, exclusive of appendix E to the Guidelines, except that options more stringent than NSPS must be considered. Establishing a BART emission limitation equivalent to the NSPS level of control is not a sufficient basis to avoid the analysis of control options required by the guidelines. This document is EPA publication No. 450/
3

– 80

– 009b and has been approved for incorporation by reference by the Director of the Federal Register in accordance with 5 U.S.C. 552(a) and 1 CFR part 51. It is for sale from the U.S. Department of Commerce, National Technical Information Service, 5285 Port Royal Road, Springfield, Virginia 22161. It is also available for inspection from the National Archives and Records Administration (NARA). For information on the availability of this material at NARA, call 202

– 741

– 6030, or go to: http://www.archives.gov/ federal

_ register/index.html.
* * * * *

■ 3. Section 51.308 is amended by revising paragraph (b), removing and reserving paragraph (c), revising paragraphs (e)(1)(ii), (e)(3), and (e)(4), and adding paragaphs (e)(5) and (6) to read as follows: **§ 51.308 Regional haze program**  **requirements.**
* * * * *

(b) When are the first implementation plans due under the regional haze program? Except as provided in § 51.309(c), each State identified in § 51.300(b)(3) must submit, for the entire State, an implementation plan for regional haze meeting the requirements of paragraphs (d) and (e) of this section no later than December 17, 2007.

(c) [Reserved]
* * * * *

(e) * * * (1) * * * (ii) A determination of BART for each BART-eligible source in the State that emits any air pollutant which may reasonably be anticipated to cause or contribute to any impairment of visibility in any mandatory Class I Federal area. All such sources are subject to BART.

(A) The determination of BART must be based on an analysis of the best system of continuous emission control technology available and associated emission reductions achievable for each BART-eligible source that is subject to BART within the State. In this analysis, the State must take into consideration the technology available, the costs of compliance, the energy and nonair quality environmental impacts of compliance, any pollution control equipment in use at the source, the remaining useful life of the source, and the degree of improvement in visibility which may reasonably be anticipated to result from the use of such technology.

(B) The determination of BART for fossil-fuel fired power plants having a total generating capacity greater than 750 megawatts must be made pursuant to the guidelines in appendix Y of this part (Guidelines for BART Determinations Under the Regional Haze Rule).

(C) Exception. A State is not required to make a determination of BART for SO 2 or for NO X if a BART-eligible source has the potential to emit less than 40 tons per year of such pollutant(s), or for PM 10 if a BARTeligible source emits less than 15 tons per year of such pollutant.
* * * * *

(3) A State which opts under 40 CFR 51.308(e)(2) to implement an emissions trading program or other alternative measure rather than to require sources subject to BART to install, operate, and maintain BART may satisfy the final step of the demonstration required by that section as follows: If the distribution of emissions is not substantially different than under BART, and the alternative measure results in greater emission reductions, then the alternative measure may be deemed to achieve greater reasonable progress. If the distribution of emissions is significantly different, the State must conduct dispersion modeling to determine differences in visibility between BART and the trading program for each impacted Class I area, for the worst and best 20 percent of days. The modeling would demonstrate ‘‘ greater reasonable progress ’’ if both of the following two criteria are met:

(i) Visibility does not decline in any Class I area, and

(ii) There is an overall improvement in visibility, determined by comparing the average differences between BART and the alternative over all affected Class I areas.

(4) A State that opts to participate inthe Clean Air Interstate Rule cap-andtrade and trade program under part 96 AAA

– EEE need not require affected BART-eligible EGU ’ s to install, operate, and maintain BART. A State that chooses this option may also include provisions for a geographic enhancement to the program to address the requirement under § 51.302(c) related to BART for reasonably attributable impairment from thepollutants covered by the CAIR cap-andtrade program.

(5) After a State has met the requirements for BART or implemented emissions trading program or other alternative measure that achieves more reasonable progress than the installation and operation of BART, BART-eligible sources will be subject to the requirements of paragraph (d) of this section in the same manner as other

sources.

(6) Any BART-eligible facility subject to the requirement under paragraph (e) of this section to install, operate, and maintain BART may apply to the Administrator for an exemption from that requirement. An application for an exemption will be subject to the requirements of § 51.303(a)(2)

– (h).
* * * * *

■ 4. Appendix Y to Part 51 is added to read as follows: Appendix Y to Part 51

— Guidelines for BART Determinations Under the Regional Haze Rule

Table of Contents
I. Introduction and Overview

A. What is the purpose of the guidelines? B. What does the CAA require generally for

improving visibility? C. What is the BART requirement in the

CAA? D. What types of visibility problems does

EPA address in its regulations?


### 39157 Federal Register / Vol. 70, No. 128 / Wednesday, July 6, 2005 / Rules and Regulations

E. What are the BART requirements in

EPA ’ s regional haze regulations? F. What is included in the guidelines? G. Who is the target audience for the

guidelines? H. Do EPA regulations require the use of

these guidelines? II. How to Identify BART-eligible Sources

A. What are the steps in identifying BARTeligible sources? 1. Step 1: Identify emission units in the

BART categories 2. Step 2: Identify the start-up dates of the

emission units 3. Step 3: Compare the potential emissions

to the 250 ton/yr cutoff 4. Final step: Identify the emission units

and pollutants that constitute the BARTeligible source. III. How to Identify Sources ‘‘ Subject to BART ’’ IV. The BART Determination: Analysis of BART Options A. What factors must I address in the

BART Analysis? B. What is the scope of the BART review? C. How does a BART review relate to

maximum achievable control technology (MACT) standards under CAA section 112?D. What are the five basic steps of a caseby-case BART analysis? 1. Step 1: How do I identify all available

retrofit emission control techniques? 2. Step 2: How do I determine whether the

options identified in Step 1 are technically feasible? 3. Step 3: How do I evaluate technically

feasible alternatives? 4. Step 4: For a BART review, what

impacts am I expected to calculate and report? What methods does EPA recommend for the impacts analyses? a. Impact analysis part 1: how do I estimate

the costs of control? b. What do we mean by cost effectiveness? c. How do I calculate average cost

effectiveness? d. How do I calculate baseline emissions? e. How do I calculate incremental cost

effectiveness? f. What other information should I provide

in the cost impacts analysis? g. What other things are important to

consider in the cost impacts analysis? h. Impact analysis part 2: How should I

analyze and report energy impacts? i. Impact analysis part 3: How do I analyze

‘‘ non-air quality environmental impacts? ’’ j. Impact analysis part 4: What are

examples of non-air quality environmental impacts? k. How do I take into account a project ’ s

‘‘ remaining useful life ’’ in calculating control costs? 5. Step 5: How should I determine

visibility impacts in the BART determination? E. How do I select the ‘‘ best ’’ alternative,

using the results of Steps 1 through 5? 1. Summary of the impacts analysis 2. Selecting a ‘‘ best ’’ alternative 3. In selecting a ‘‘ best ’’ alternative, should

I consider the affordability of controls? 4. SO 2 limits for utility boilers 5. NO X limits for utility boilers V. Enforceable Limits/Compliance Date

I. Introduction and Overview A. What is the purpose of the guidelines?

The Clean Air Act (CAA), in sections 169A and 169B, contains requirements for the protection of visibility in 156 scenic areas across the United States. To meet the CAA ’ s requirements, we published regulations to protect against a particular type of visibility impairment known as ‘‘ regional haze. ’’ The regional haze rule is found in this part at 40 CFR 51.300 through 51.309. These regulations require, in 40 CFR 51.308(e), that certain types of existing stationary sources of air pollutants install best available retrofit technology (BART). The guidelines are designed to help States and others (1) identify those sources that must comply with the BART requirement, and (2) determine the level of control technology that represents BART for each source. B. What does the CAA require generally for improving visibility?

Section 169A of the CAA, added to the CAA by the 1977 amendments, requires States to protect and improve visibility in certain scenic areas of national importance. The scenic areas protected by section 169A

are ‘‘ the mandatory Class I Federal Areas * * * where visibility is an important value. ’’ In these guidelines, we refer to these

as ‘‘ Class I areas. ’’ There are 156 Class I areas, including 47 national parks (under the jurisdiction of the Department of Interior

— National Park Service), 108 wilderness areas (under the jurisdiction of the Department of the Interior

— Fish and Wildlife Service or the Department of Agriculture

— U.S. Forest Service), and one International Park (under the jurisdiction of the Roosevelt-Campobello International Commission). The Federal Agency with jurisdiction over a particular Class I area is referred to in the CAA as the Federal Land Manager. A complete list of the Class I areas is contained in 40 CFR 81.401 through 81.437, and you can find a map of the Class I areas at the following Internet site: http://www.epa.gov/ttn/oarpg/t1/fr

_ notices/ classimp.gif.

The CAA establishes a national goal of eliminating man-made visibility impairment from all Class I areas. As part of the plan for achieving this goal, the visibility protection provisions in the CAA mandate that EPA issue regulations requiring that States adopt measures in their State implementation plans (SIPs), including long-term strategies, to provide for reasonable progress towards this national goal. The CAA also requires States to coordinate with the Federal Land Managers as they develop their strategies for addressing visibility. C. What is the BART requirement in the CAA?

1. Under section 169A(b)(2)(A) of the CAA, States must require certain existing stationary sources to install BART. The BART provision applies to ‘‘ major stationary sources ’’ from 26 identified source categories which have the potential to emit 250 tons per year or more of any air pollutant. The CAA requires only sources which were put in place during a specific 15-year time interval to be subject to BART. The BART provision applies to sources that existed as of the date of the 1977 CAA amendments (that is, August 7, 1977) but which had not been in operation for more than 15 years (that is, not in operation as of August 7, 1962).

2. The CAA requires BART review when any source meeting the above description

‘‘ emits any air pollutant which may reasonably be anticipated to cause or contribute to any impairment of visibility ’’ in any Class I area. In identifying a level of control as BART, States are required by section 169A(g) of the CAA to consider:

(a) The costs of compliance, (b) The energy and non-air quality environmental impacts of compliance,

(c) Any existing pollution control technology in use at the source,

(d) The remaining useful life of the source, and

(e) The degree of visibility improvement which may reasonably be anticipated from the use of BART.

3. The CAA further requires States to make BART emission limitations part of their SIPs. As with any SIP revision, States must provide an opportunity for public comment on the BART determinations, and EPA ’ s action on any SIP revision will be subject to judicial review. D. What types of visibility problems does EPA address in its regulations?

1. We addressed the problem of visibility in two phases. In 1980, we published regulations addressing what we termed

‘‘ reasonably attributable ’’ visibility impairment. Reasonably attributable visibility impairment is the result of emissions from one or a few sources that are generally located in close proximity to a specific Class I area. The regulations addressing reasonably attributable visibility impairment are published in 40 CFR 51.300 through 51.307.

2. On July 1, 1999, we amended these regulations to address the second, more common, type of visibility impairment known as ‘‘ regional haze. ’’ Regional haze is the result of the collective contribution of many sources over a broad region. The regional haze rule slightly modified 40 CFR 51.300 through 51.307, including the addition of a few definitions in § 51.301, and added new §§ 51.308 and 51.309. E. What are the BART requirements in EPA ’ s regional haze regulations?

1. In the July 1, 1999 rulemaking, we added a BART requirement for regional haze. We amended the BART requirements in 2005. You will find the BART requirements in 40 CFR 51.308(e). Definitions of terms used in 40 CFR 51.308(e)(1) are found in 40 CFR
51.301.

2. As we discuss in detail in these guidelines, the regional haze rule codifies and clarifies the BART provisions in the CAA. The rule requires that States identify and list ‘‘ BART-eligible sources, ’’ that is, that States identify and list those sources that fall within the 26 source categories, were put in place during the 15-year window of time from 1962 to 1977, and have potential


### 39158 Federal Register / Vol. 70, No. 128 / Wednesday, July 6, 2005 / Rules and Regulations

emissions greater than 250 tons per year.Once the State has identified the BARTeligible sources, the next step is to identify those BART-eligible sources that may ‘‘ emit any air pollutant which may reasonably be anticipated to cause or contribute to any impairment of visibility. ’’ Under the rule, a source which fits this description is ‘‘ subject to BART. ’’ For each source subject to BART, 40 CFR 51.308(e)(1)(ii)(A) requires that States identify the level of control representing BART after considering the factors set out in CAA section 169A(g), as follows:

— States must identify the best system of

continuous emission control technology for each source subject to BART taking into account the technology available, the costs of compliance, the energy and non-air quality environmental impacts of compliance, any pollution control equipment in use at the source, the remaining useful life of the source, and the degree of visibility improvement that may be expected from available control technology.
3. After a State has identified the level of control representing BART (if any), it must establish an emission limit representing BART and must ensure compliance with that requirement no later than 5 years after EPA approves the SIP. States may establish design, equipment, work practice or other operational standards when limitations on measurement technologies make emission standards infeasible. F. What is included in the guidelines?

1. The guidelines provide a process for making BART determinations that States can use in implementing the regional haze BART requirements on a source-by-source basis, as provided in 40 CFR 51.308(e)(1). States must follow the guidelines in making BART determinations on a source-by-source basis for 750 megawatt (MW) power plants but are not required to use the process in the guidelines when making BART determinations for other types of sources.

2. The BART analysis process, and the contents of these guidelines, are as follows:

(a) Identification of all BART-eligible

sources. Section II of these guidelines outlines a step-by-step process for identifying BART-eligible sources.

(b) Identification of sources subject to BART. As noted above, sources ‘‘ subject to BART ’’ are those BART-eligible sources which ‘‘ emit a pollutant which may reasonably be anticipated to cause or contribute to any impairment of visibility in any Class I area. ’’ We discuss considerations for identifying sources subject to BART in section III of the guidance.

(c) The BART determination process. For each source subject to BART, the next step is to conduct an analysis of emissions control alternatives. This step includes the identification of available, technically feasible retrofit technologies, and for each technology identified, an analysis of the cost of compliance, the energy and non-air quality environmental impacts, and the degree of visibility improvement in affected Class I areas resulting from the use of the control technology. As part of the BART analysis, the State should also take into account the remaining useful life of the source and any existing control technology present at the source. For each source, the State will determine a ‘‘ best system of continuous emission reduction ’’ based upon its evaluation of these factors. Procedures for the BART determination step are described in section IV of these guidelines.

(d) Emissions limits. States must establish emission limits, including a deadline for compliance, consistent with the BART determination process for each source subject to BART. Considerations related to these limits are discussed in section V of these guidelines. G. Who is the target audience for the guidelines?

1. The guidelines are written primarily for the benefit of State, local and Tribal agencies, and describe a process for making the BART determinations and establishing the emission limitations that must be included in their SIPs or Tribal implementation plans (TIPs). Throughout the guidelines, which are written in a question and answer format, we ask questions ‘‘ How do I * * *? ’’ and answer with phrases ‘‘ you should * * *, you must

*** ’’ The ‘‘ you ’’ means a State, local or Tribal agency conducting the analysis. We have used this format to make the guidelines simpler to understand, but we recognize that States have the authority to require source owners to assume part of the analytical burden, and that there will be differences in how the supporting information is collected and documented. We also recognize that data collection, analysis, and rule development may be performed by Regional Planning Organizations, for adoption within each SIP or TIP.

2. The preamble to the 1999 regional haze rule discussed at length the issue of Tribal implementation of the requirements to submit a plan to address visibility. As explained there, requirements related to visibility are among the programs for which Tribes may be determined eligible and receive authorization to implement under the

‘‘ Tribal Authority Rule ’’ ( ‘‘ TAR ’’ ) (40 CFR 49.1 through 49.11). Tribes are not subject to the deadlines for submitting visibility implementation plans and may use a modular approach to CAA implementation. We believe there are very few BART-eligible sources located on Tribal lands. Where such sources exist, the affected Tribe may apply for delegation of implementation authority for this rule, following the process set forth in the TAR. H. Do EPA regulations require the use of these guidelines?

Section 169A(b) requires us to issue guidelines for States to follow in establishing BART emission limitations for fossil-fuel fired power plants having a capacity in excess of 750 megawatts. This document fulfills that requirement, which is codified in 40 CFR 51.308(e)(1)(ii)(B). The guidelines establish an approach to implementing the requirements of the BART provisions of the regional haze rule; we believe that these procedures and the discussion of the requirements of the regional haze rule and the CAA should be useful to the States. For sources other than 750 MW power plants, however, States retain the discretion to adopt approaches that differ from the guidelines. II. How to Identify BART-Eligible Sources

This section provides guidelines on how toidentify BART-eligible sources. A BARTeligible source is an existing stationary source in any of 26 listed categories which meets criteria for startup dates and potential emissions.A. What are the steps in identifying BARTeligible sources?

Figure 1 shows the steps for identifying whether the source is a ‘‘ BART-eligible

source: ’’

Step 1: Identify the emission units in the BART categories,

Step 2: Identify the start-up dates of those emission units, and

Step 3: Compare the potential emissions to the 250 ton/yr cutoff.

Figure 1. How to determine whether a source is BART-eligible:

Step 1: Identify emission units in the BART categories Does the plant contain emissions units in one or more of the 26 source categories?
➜ No ➜ Stop
➜ Yes ➜ Proceed to Step 2 Step 2: Identify the start-up dates of these emission units Do any of these emissions units meet the following two tests? In existence on August 7, 1977 AND Began operation after August 7, 1962

➜ No ➜ Stop
➜ Yes ➜ Proceed to Step 3 Step 3: Compare the potential emissions from these emission units to the 250 ton/yr cutoff

Identify the ‘‘ stationary source ’’ that

includes the emission units you identified in Step 2. Add the current potential emissions from

all the emission units identified in Steps 1 and 2 that are included within the

‘‘ stationary source ’’ boundary. Are the potential emissions from these

units 250 tons per year or more for any visibility-impairing pollutant?
➜ No ➜ Stop
➜ Yes ➜ These emissions units comprise the ‘‘ BART-eligible source. ’’ 1. Step 1: Identify Emission Units in the BART Categories

1. The BART requirement only applies to sources in specific categories listed in the CAA. The BART requirement does not apply to sources in other source categories, regardless of their emissions. The listed categories are:

(1) Fossil-fuel fired steam electric plants of more than 250 million British thermal units (BTU) per hour heat input,

(2) Coal cleaning plants (thermal dryers), (3) Kraft pulp mills, (4) Portland cement plants, (5) Primary zinc smelters, (6) Iron and steel mill plants, (7) Primary aluminum ore reduction plants,


### 39159 Federal Register / Vol. 70, No. 128 / Wednesday, July 6, 2005 / Rules and Regulations

(8) Primary copper smelters, (9) Municipal incinerators capable of charging more than 250 tons of refuse per day,

(10) Hydrofluoric, sulfuric, and nitric acid plants,

(11) Petroleum refineries, (12) Lime plants, (13) Phosphate rock processing plants, (14) Coke oven batteries, (15) Sulfur recovery plants, (16) Carbon black plants (furnace process), (17) Primary lead smelters, (18) Fuel conversion plants, (19) Sintering plants, (20) Secondary metal production facilities, (21) Chemical process plants, (22) Fossil-fuel boilers of more than 250 million BTUs per hour heat input,

(23) Petroleum storage and transfer facilities with a capacity exceeding 300,000 barrels,

(24) Taconite ore processing facilities, (25) Glass fiber processing plants, and (26) Charcoal production facilities. 2. Some plants may have emission units from more than one category, and some emitting equipment may fit into more than one category. Examples of this situation are sulfur recovery plants at petroleum refineries, coke oven batteries and sintering plants at steel mills, and chemical process plants at refineries. For Step 1, you identify all of the emissions units at the plant that fit into one or more of the listed categories. You do not identify emission units in other categories.

Example: A mine is collocated with an electric steam generating plant and a coal cleaning plant. You would identify emission units associated with the electric steam generating plant and the coal cleaning plant, because they are listed categories, but not the mine, because coal mining is not a listed category.

3. The category titles are generally clear in describing the types of equipment to be listed. Most of the category titles are very broad descriptions that encompass all emission units associated with a plant site (for example, ‘‘ petroleum refining ’’ and ‘‘ kraft pulp mills ’’ ). This same list of categories appears in the PSD regulations. States and source owners need not revisit any interpretations of the list made previously for purposes of the PSD program. We provide the following clarifications for a few of the category titles:

(1) ‘‘ Steam electric plants of more than 250 million BTU/hr heat input. ’’ Because the category refers to ‘‘ plants, ’’ we interpret this category title to mean that boiler capacities should be aggregated to determine whether the 250 million BTU/hr threshold is reached. This definition includes only those plants that generate electricity for sale. Plants that cogenerate steam and electricity also fall within the definition of ‘‘ steam electric plants ’’ . Similarly, combined cycle turbines are also considered ‘‘ steam electric plants ’’ because such facilities incorporate heat recovery steam generators. Simple cycle turbines, in contrast, are not ‘‘ steam electric plants ’’ because these turbines typically do not generate steam. Example: A stationary source includes a steam electric plant with three 100 million BTU/hr boilers. Because the aggregate capacity exceeds 250 million BTU/hr for the

‘‘ plant, ’’ these boilers would be identified in Step 2.

(2) ‘‘ Fossil-fuel boilers of more than 250 million BTU/hr heat input. ’’ We interpret this category title to cover only those boilers that are individually greater than 250 million BTU/hr. However, an individual boiler smaller than 250 million BTU/hr should be subject to BART if it is an integral part of a process description at a plant that is in a different BART category

— for example, a boiler at a Kraft pulp mill that, in addition to providing steam or mechanical power, uses the waste liquor from the process as afuel. In general, if the process uses any byproduct of the boiler and the boiler ’ s function is to serve the process, then the boiler is integral to the process and should be considered to be part of the process description.

Also, you should consider a multi-fuel boiler to be a ‘‘ fossil-fuel boiler ’’ if it burns any amount of fossil fuel. You may take federally and State enforceable operational limits into account in determining whether a multi-fuel boiler ’ s fossil fuel capacity exceeds 250 million Btu/hr.

(3) ‘‘ Petroleum storage and transfer facilities with a capacity exceeding 300,000 barrels. ’’ The 300,000 barrel cutoff refers to total facility-wide tank capacity for tanks that were put in place within the 1962

– 1977 time period, and includes gasoline and other petroleum-derived liquids.

(4) ‘‘ Phosphate rock processing plants. ’’ This category descriptor is broad, and includes all types of phosphate rock processing facilities, including elemental phosphorous plants as well as fertilizer production plants.

(5) ‘‘ Charcoal production facilities. ’’ We interpret this category to include charcoal briquet manufacturing and activated carbon production.

(6) ‘‘ Chemical process plants. ’’ and pharmaceutical manufacturing. Consistent with past policy, we interpret the category

‘‘ chemical process plants ’’ to include those facilities within the 2-digit Standard Industrial Classification (SIC) code 28. Accordingly, we interpret the term ‘‘ chemical process plants ’’ to include pharmaceutical manufacturing facilities.

(7) ‘‘ Secondary metal production. ’’ We interpret this category to include nonferrous metal facilities included within SIC code 3341, and secondary ferrous metal facilities that we also consider to be included within the category ‘‘ iron and steel mill plants. ’’

(8) ‘‘ Primary aluminum ore reduction. ’’ We interpret this category to include those facilities covered by 40 CFR 60.190, the new source performance standard (NSPS) for primary aluminum ore reduction plants. This definition is also consistent with the definition at 40 CFR 63.840. 2. Step 2: Identify the Start-Up Dates of the Emission Units

1. Emissions units listed under Step 1 are BART-eligible only if they were ‘‘ in existence ’’ on August 7, 1977 but were not

‘‘ in operation ’’ before August 7, 1962. What does ‘‘ in existence on August 7, 1977 ’’ mean?

2. The regional haze rule defines ‘‘ in existence ’’ to mean that:

‘‘ the owner or operator has obtained all necessary preconstruction approvals or permits required by Federal, State, or local air pollution emissions and air quality laws or regulations and either has (1) begun, or caused to begin, a continuous program of physical on-site construction of the facility or (2) entered into binding agreements or contractual obligations, which cannot be canceled or modified without substantial loss to the owner or operator, to undertake a program of construction of the facility to be completed in a reasonable time. ’’ 40 CFR
51.301.

As this definition is essentially identical to the definition of ‘‘ commence construction ’’ as that term is used in the PSD regulations, the two terms mean the same thing. See 40 CFR 51.165(a)(1)(xvi) and 40 CFR 52.21(b)(9). Under this definition, an emissions unit could be ‘‘ in existence ’’ even if it did not begin operating until several years after 1977.

Example: The owner of a source obtained all necessary permits in early 1977 and entered into binding construction agreements in June 1977. Actual on-site construction began in late 1978, and construction was completed in mid-1979. The source began operating in September 1979. The emissions unit was ‘‘ in existence ’’ as of August 7, 1977.

Major stationary sources which commenced construction AFTER August 7, 1977 ( i.e. , major stationary sources which
were not ‘‘ in existence ’’ on August 7, 1977) were subject to new source review (NSR) under the PSD program. Thus, the August 7,
1977 ‘‘ in existence ’’ test is essentially the same thing as the identification of emissions units that were grandfathered from the NSR review requirements of the 1977 CAA amendments.

3. Sources are not BART-eligible if the only change at the plant during the relevant time period was the addition of pollution controls. For example, if the only change at a copper smelter during the 1962 through 1977 time period was the addition of acid plants for the reduction of SO 2 emissions, these emission controls would not by themselves trigger a BART review.
What does ‘‘ in operation before August 7,
1962 ’’ mean?

An emissions unit that meets the August 7,
1977 ‘‘ in existence ’’ test is not BART-eligible if it was in operation before August 7, 1962.

‘‘ In operation ’’ is defined as ‘‘ engaged in activity related to the primary design function of the source. ’’ This means that a source must have begun actual operations by August 7, 1962 to satisfy this test.

Example: The owner or operator enteredinto binding agreements in 1960. Actual onsite construction began in 1961, and construction was complete in mid-1962. The source began operating in September 1962. The emissions unit was not ‘‘ in operation ’’ before August 7, 1962 and is therefore subject to BART.
What is a ‘‘ reconstructed source? ’

1. Under a number of CAA programs, an existing source which is completely or


### 39160 Federal Register / Vol. 70, No. 128 / Wednesday, July 6, 2005 / Rules and Regulations

1 Fine particles: Overview of Atmospheric Chemistry, Sources of Emissions, and Ambient Monitoring Data, Memorandum to Docket OAR
2002

– 006, April 1, 2005.

2 Note: Most of these terms and definitions are the same for regional haze and the 1980 visibility regulations. For the regional haze rule we use the
term ‘‘ BART-eligible source ’’ rather than ‘‘ existing stationary facility ’’ to clarify that only a limited subset of existing stationary sources are subject to BART. substantially rebuilt is treated as a new source. Such ‘‘ reconstructed ’’ sources are treated as new sources as of the time of the reconstruction. Consistent with this overall approach to reconstructions, the definition of BART-eligible facility (reflected in detail in the definition of ‘‘ existing stationary facility ’’ ) includes consideration of sources that were in operation before August 7, 1962, but were reconstructed during the August 7, 1962 to August 7, 1977 time period.

2. Under the regional haze regulations at 40 CFR 51.301, a reconstruction has taken place if ‘‘ the fixed capital cost of the new component exceeds 50 percent of the fixed capital cost of a comparable entirely new

source. ’’ The rule also states that ‘‘ [a]ny final decision as to whether reconstruction has occurred must be made in accordance with the provisions of §§ 60.15 (f)(1) through (3) of this title. ’’ ‘‘ [T]he provisions of §§ 60.15(f)(1) through (3) ’’ refers to the general provisions for New Source Performance Standards (NSPS). Thus, the same policies and procedures for identifying reconstructed

‘‘ affected facilities ’’ under the NSPS program must also be used to identify reconstructed

‘‘ stationary sources ’’ for purposes of the BART requirement.

3. You should identify reconstructions on an emissions unit basis, rather than on a plantwide basis. That is, you need to identify only the reconstructed emission units meeting the 50 percent cost criterion. You should include reconstructed emission units in the list of emission units you identified in Step 1. You need consider as possible reconstructions only those emissions units with the potential to emit more than 250 tons per year of any visibility-impairing pollutant.

4. The ‘‘ in operation ’’ and ‘‘ in existence ’’ tests apply to reconstructed sources. If an emissions unit was reconstructed and began actual operation before August 7, 1962, it is not BART-eligible. Similarly, any emissions unit for which a reconstruction

‘‘ commenced ’’ after August 7, 1977, is not BART-eligible.
How are modifications treated under the BART provision?

1. The NSPS program and the major source NSR program both contain the concept of modifications. In general, the term

‘‘ modification ’’ refers to any physical change or change in the method of operation of an emissions unit that results in an increase in emissions.

2. The BART provision in the regional haze rule contains no explicit treatment of modifications or how modified emissions units, previously subject to the requirement to install best available control technology (BACT), lowest achievable emission rate (LAER) controls, and/or NSPS are treated under the rule. As the BART requirements in the CAA do not appear to provide any exemption for sources which have been modified since 1977, the best interpretation of the CAA visibility provisions is that a subsequent modification does not change a unit ’ s construction date for the purpose of BART applicability. Accordingly, if an emissions unit began operation before 1962, it is not BART-eligible if it was modified between 1962 and 1977, so long as the modification is not also a ‘‘ reconstruction. ’’ On the other hand, an emissions unit which began operation within the 1962

– 1977 time window, but was modified after August 7, 1977, is BART-eligible. We note, however, that if such a modification was a major modification that resulted in the installation of controls, the State will take this into account during the review process and may find that the level of controls already in place are consistent with BART. 3. Step 3: Compare the Potential Emissions to the 250 Ton/Yr Cutoff

The result of Steps 1 and 2 will be a list of emissions units at a given plant site, including reconstructed emissions units, that are within one or more of the BART categories and that were placed into operation within the 1962

– 1977 time window. The third step is to determine whether the total emissions represent a current potential to emit that is greater than 250 tons per year of any single visibility impairing pollutant. Fugitive emissions, to the extent quantifiable, must be counted. In most cases, you will add the potential emissions from all emission units on the list resulting from Steps 1 and 2. In a few cases, you may need to determine whether the plant contains more than one ‘‘ stationary source ’’ as the regional haze rule defines that term, and as we explain further below. What pollutants should I address?

Visibility-impairing pollutants include the following:

(1) Sulfur dioxide (SO 2 ), (2) Nitrogen oxides (NO X ), and (3) Particulate matter. You may use PM 10 as an indicator for particulate matter in this intial step. [Note that we do not recommend use of total suspended particulates (TSP) as in indicator for particulate matter.] As emissions of PM 10 include the components of PM 2.5 as a subset, there is no need to have separate 250 ton thresholds for PM 10 and PM 2.5 ; 250 tons of PM 10 represents at most 250 tons of PM 2.5 , and at most 250 tons of any individual particulate species such as elemental carbon, crustal material, etc.

However, if you determine that a source of particulate matter is BART-eligible, it will be important to distinguish between the fine and coarse particle components of direct particulate emissions in the remainder of the BART analysis, including for the purpose of modeling the source ’ s impact on visibility. This is because although both fine and coarse particulate matter contribute to visibility impairment, the long-range transport of fine particles is of particular concern in the formation of regional haze. Thus, for example, air quality modeling results used in the BART determination will provide a more accurate prediction of a source ’ s impact on visibility if the inputs into the model account for the relative particle size of any directly emitted particulate matter ( i.e. PM 10 vs. PM 2.5 ).

You should exercise judgment in deciding whether the following pollutants impair visibility in an area:

(4) Volatile organic compounds (VOC), and (5) Ammonia and ammonia compounds. You should use your best judgment in deciding whether VOC or ammonia emissions from a source are likely to have an impact on visibility in an area. Certain types of VOC emissions, for example, are more likely to form secondary organic aerosols than others. 1 Similarly, controlling ammonia emissions in some areas may not have a significant impact on visibility. You need not provide a formal showing of an individual decision that a source of VOC or ammonia emissions is not subject to BART review. Because air quality modeling may not be feasible for individual sources of VOC or ammonia, you should also exercise your judgement in assessing the degree of visibility impacts due to emissions of VOC and emissions of ammonia or ammonia compounds. You should fully document the basis for judging that a VOC or ammonia source merits BART review, including your assessment of the source ’ s contribution to visibility impairment.
What does the term ‘‘ potential ’’ emissions mean?

The regional haze rule defines potential to emit as follows:

‘‘ Potential to emit ’’ means the maximum capacity of a stationary source to emit a pollutant under its physical and operational design. Any physical or operational limitation on the capacity of the source to emit a pollutant including air pollution control equipment and restrictions on hours of operation or on the type or amount of material combusted, stored, or processed, shall be treated as part of its design if the limitation or the effect it would have on emissions is federally enforceable. Secondary emissions do not count in determining the potential to emit of a stationary source. The definition of ‘‘ potential to emit ’’ means that a source which actually emits less than 250 tons per year of a visibility-impairing pollutant is BART-eligible if its emissions would exceed 250 tons per year when operating at its maximum capacity given its physical and operational design (and considering all federally enforceable and State enforceable permit limits.)

Example: A source, while operating at onefourth of its capacity, emits 75 tons per year of SO 2 . If it were operating at 100 percent of its maximum capacity, the source would emit 300 tons per year. Because under the above definition such a source would have

‘‘ potential ’’ emissions that exceed 250 tons per year, the source (if in a listed category and built during the 1962

– 1977 time window) would be BART-eligible. How do I identify whether a plant has more than one ‘‘ stationary source? ’’

1. The regional haze rule, in 40 CFR 51.301, defines a stationary source as a

‘‘ building, structure, facility or installation which emits or may emit any air pollutant. ’’ 2


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3 We recognize that we are in a transition period from the use of the SIC system to a new system called the North American Industry ClassificationSystem (NAICS). For purposes of identifying BARTeligible sources, you may use either 2-digit SICS or the equivalent in the NAICS system.

4 Note: The concept of support facility used for the NSR program applies here as well. Support facilities, that is facilities that convey, store or otherwise assist in the production of the principal product, must be grouped with primary facilities even when the facilities fall wihin separate SIC codes. For purposes of BART reviews, however, such support facilities (a) must be within one of the 26 listed source categories and (b) must have been in existence as of August 7, 1977, and (c) must not have been in operation as of August 7, 1962. 5 We expect that regional planning organizations will have modeling information that identifies sources affecting visibility in individual class I

areas. The rule further defines ‘‘ building, structure or facility ’’ as: all of the pollutant-emitting activities which belong to the same industrial grouping, are located on one or more contiguous or adjacent properties, and are under the control of the same person (or persons under common control). Pollutant-emitting activities must be considered as part of the same industrial grouping if they belong to the same Major Group ( i.e. , which have the same two-digit code) as described in the Standard Industrial Classification Manual, 1972 as amended by the 1977 Supplement (U.S. Government Printing Office stock numbers
4101

– 0066 and 003

– 005

– 00176

– 0, respectively).

2. In applying this definition, it is necessary to determine which facilities are located on ‘‘ contiguous or adjacent properties. ’’ Within this contiguous and adjacent area, it is also necessary to group those emission units that are under ‘‘ common control. ’’ We note that these plant boundary issues and ‘‘ common control ’’ issues are very similar to those already addressed in implementation of the title V operating permits program and in NSR.

3. For emission units within the

‘‘ contiguous or adjacent ’’ boundary and under common control, you must group emission units that are within the same industrial grouping (that is, associated with the same 2-digit SIC code) in order to define the stationary source. 3 For most plants on the BART source category list, there will only be one 2-digit SIC that applies to the entire plant. For example, all emission units associated with kraft pulp mills are within SIC code 26, and chemical process plants will generally include emission units that are all within SIC code 28. The ‘‘ 2-digit SIC test ’’ applies in the same way as the test is applied in the major source NSR programs. 4

4. For purposes of the regional haze rule, you must group emissions from all emission units put in place within the 1962

– 1977 time period that are within the 2-digit SIC code, even if those emission units are in different categories on the BART category list.

Examples: A chemical plant which started operations within the 1962 to 1977 time period manufactures hydrochloric acid (within the category title ‘‘ Hydrochloric, sulfuric, and nitric acid plants ’’ ) and various organic chemicals (within the category title

‘‘ chemical process plants ’’ ). All of the emission units are within SIC code 28 and, therefore, all the emission units are considered in determining BART eligibility of the plant. You sum the emissions over all of these emission units to see whether there are more than 250 tons per year of potential emissions.

A steel mill which started operations within the 1962 to 1977 time period includes a sintering plant, a coke oven battery, and various other emission units. All of the emission units are within SIC code 33. You sum the emissions over all of these emission units to see whether there are more than 250 tons per year of potential emissions. 4. Final Step: Identify the Emissions Unitsand Pollutants That Constitute the BARTEligible Source

If the emissions from the list of emissions units at a stationary source exceed a potentialto emit of 250 tons per year for any visibilityimpairing pollutant, then that collection of emissions units is a BART-eligible source.

Example: A stationary source comprises the following two emissions units, with the following potential emissions: Emissions unit A

200 tons/yr SO 2 150 tons/yr NO X 25 tons/yr PM Emissions unit B

100 tons/yr SO 2 75 tons/yr NO X 10 tons/yr PM For this example, potential emissions of SO 2 are 300 tons/yr, which exceeds the 250 tons/ yr threshold. Accordingly, the entire

‘‘ stationary source ’’ , that is, emissions units A and B, may be subject to a BART review for SO 2 , NO X , and PM, even though the potential emissions of PM and NO X at each emissions unit are less than 250 tons/yr each.

Example: The total potential emissions, obtained by adding the potential emissions of all emission units in a listed category at a plant site, are as follows: 200 tons/yr SO 2 150 tons/yr NO X 25 tons/yr PM

Even though total emissions exceed 250 tons/yr, no individual regulated pollutant exceeds 250 tons/yr and this source is not BART-eligible.
Can States establish de minimis levels of emissions for pollutants at BART-eligible sources?

In order to simplify BART determinations, States may choose to identify de minimis levels of pollutants at BART-eligible sources (but are not required to do so). De minimis values should be identified with the purpose of excluding only those emissions so minimal that they are unlikely to contribute to regional haze. Any de minimis values that you adopt must not be higher than the PSD applicability levels: 40 tons/yr for SO 2 and NO X and 15 tons/yr for PM 10 . These de minimis levels may only be applied on a plant-wide basis. III. How to Identify Sources ‘‘ Subject to BART ’’

Once you have compiled your list of BART-eligible sources, you need to determine whether (1) to make BART determinations for all of them or (2) to consider exempting some of them from BART because they may not reasonably be anticipated to cause or contribute to any visibility impairment in a Class I area. If you decide to make BART determinations for all the BART-eligible sources on your list, you should work with your regional planning organization (RPO) to show that, collectively, they cause or contribute to visibility impairment in at least one Class I area. You should then make individual BART determinations by applying the five statutory factors discussed in Section IV below.

On the other hand, you also may choose to perform an initial examination to determine whether a particular BART-eligible source or group of sources causes or contributes to visibility impairment in nearby Class I areas. If your analysis, or information submitted by the source, shows that an individual source or group of sources (or certain pollutants from those sources) is not reasonably anticipated to cause or contribute to any visibility impairment in a Class I area, then you do not need to make BART determinations for that source or group of sources (or for certain pollutants from those sources). In such a case, the source is not

‘‘ subject to BART ’’ and you do not need to apply the five statutory factors to make a BART determination. This section of the Guideline discusses several approaches that you can use to exempt sources from the BART determination process. A. What Steps Do I Follow To Determine Whether a Source or Group of Sources Cause or Contribute to Visibility Impairment for Purposes of BART?
1. How Do I Establish a Threshold?

One of the first steps in determining whether sources cause or contribute to visibility impairment for purposes of BART is to establish a threshold (measured in deciviews) against which to measure the visibility impact of one or more sources. A single source that is responsible for a 1.0 deciview change or more should be considered to ‘‘ cause ’’ visibility impairment; a source that causes less than a 1.0 deciview change may still contribute to visibility impairment and thus be subject to BART.

Because of varying circumstances affecting different Class I areas, the appropriate threshold for determining whether a source

‘‘ contributes to any visibility impairment ’’ for the purposes of BART may reasonably differ across States. As a general matter, any threshold that you use for determining whether a source ‘‘ contributes ’’ to visibility impairment should not be higher than 0.5 deciviews.

In setting a threshold for ‘‘ contribution, ’’ you should consider the number of emissions sources affecting the Class I areas at issue and the magnitude of the individual sources ’ impacts. 5 In general, a larger number of sources causing impacts in a Class I area may warrant a lower contribution threshold. States remain free to use a threshold lower than 0.5 deciviews if they conclude that the


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6 Note that the contribution threshold should be used to determine whether an individual source is reasonably anticipated to contribute to visibility impairment. You should not aggregate the visibility effects of multiple sources and compare their collective effects against your contribution threshold because this would inappropriately create

a ‘‘ contribute to contribution ’’ test. 7 The model code and its documentation are available at no cost for download from http:// www.epa.gov/scram001/tt22.htm#calpuff.

8 The Guideline on Air Quality Models, 40 CFR part 51, appendix W, addresses the regulatory application of air quality models for assessing criteria pollutants under the CAA, and describes further the procedures for using the CALPUFF model, as well as for obtaining approval for the use of other, nonguideline models.

9 Interagency Workgroup on Air Quality Modeling (IWAQM) Phase 2 Summary Report and Recommendations for Modeling Long Range Transport Impacts, U.S. Environmental Protection Agency, EPA

– 454/R

– 98

– 019, December 1998. location of a large number of BART-eligible sources within the State and in proximity to a Class I area justify this approach. 6
2. What Pollutants Do I Need to Consider?

You must look at SO 2 , NO X , and direct particulate matter (PM) emissions in determining whether sources cause or contribute to visibility impairment, including both PM 10 and PM 2.5 . Consistent with the approach for identifying your BART-eligible sources, you do not need to consider less than de minimis emissions of these pollutants from a source.

As explained in section II, you must use your best judgement to determine whether VOC or ammonia emissions are likely to have an impact on visibility in an area. In addition, although as explained in Section II, you may use PM 10 an indicator for particulate matter in determining whether a source is BART-eligible, in determining whether a source contributes to visibility impairment, you should distinguish between the fine and coarse particle components of direct particulate emissions. Although both fine and coarse particulate matter contribute to visibility impairment, the long-range transport of fine particles is of particular concern in the formation of regional haze. Air quality modeling results used in the BART determination will provide a more accurate prediction of a source ’ s impact on visibility if the inputs into the model account for the relative particle size of any directly emitted particulate matter (i.e. PM 10 vs. PM 2.5 ). 3. What Kind of Modeling Should I Use To Determine Which Sources and Pollutants Need Not Be Subject to BART?

This section presents several options for determining that certain sources need not be subject to BART. These options rely on different modeling and/or emissions analysis approaches. They are provided for your guidance. You may also use other reasonable approaches for analyzing the visibility impacts of an individual source or group of

sources. Option 1: Individual Source Attribution Approach (Dispersion Modeling)

You can use dispersion modeling to determine that an individual source cannot reasonably be anticipated to cause or contribute to visibility impairment in a Class I area and thus is not subject to BART. Under this option, you can analyze an individual

source ’ s impact on visibility as a result of its emissions of SO 2 , NO X and direct PM emissions. Dispersion modeling cannot currently be used to estimate the predicted impacts on visibility from an individual

source ’ s emissions of VOC or ammonia. You may use a more qualitative assessment to determine on a case-by-case basis which sources of VOC or ammonia emissions may be likely to impair visibility and should therefore be subject to BART review, as explained in section II.A.3. above.

You can use CALPUFF 7 or other appropriate model to predict the visibility impacts from a single source at a Class I area. CALPUFF is the best regulatory modeling application currently available for predicting a single source ’ s contribution to visibilityimpairment and is currently the only EPAapproved model for use in estimating single source pollutant concentrations resulting from the long range transport of primary pollutants. 8 It can also be used for some other purposes, such as the visibility assessments addressed in today ’ s rule, to account for the chemical transformation of SO 2 and NO X .

There are several steps for making an individual source attribution using a dispersion model:

1. Develop a modeling protocol. Some critical items to include in the protocol are the meteorological and terrain data that will be used, as well as the source-specific information (stack height, temperature, exit velocity, elevation, and emission rates of applicable pollutants) and receptor data from appropriate Class I areas. We recommend following EPA ’ s Interagency Workgroup on Air Quality Modeling (IWAQM) Phase 2 Summary Report and Recommendations for Modeling Long Range Transport Impacts 9 for parameter settings and meteorological data inputs. You may use other settings from those in IWAQM, but you should identify these settings and explain your selection of these settings.

One important element of the protocol is in establishing the receptors that will be used in the model. The receptors that you use should be located in the nearest Class I area with sufficient density to identify the likely visibility effects of the source. For other Class I areas in relatively close proximity to a BART-eligible source, you may model a few strategic receptors to determine whether effects at those areas may be greater than at the nearest Class I area. For example, you might chose to locate receptors at these areas at the closest point to the source, at the highest and lowest elevation in the Class I area, at the IMPROVE monitor, and at the approximate expected plume release height. If the highest modeled effects are observed at the nearest Class I area, you may choose not to analyze the other Class I areas any further as additional analyses might be unwarranted.

You should bear in mind that some receptors within the relevant Class I area may be less than 50 km from the source while other receptors within that same Class I area may be greater than 50 km from the same source. As indicated by the Guideline on Air Quality Models, 40 CFR part 51, appendix W, this situation may call for the use of two different modeling approaches for the same Class I area and source, depending upon the State ’ s chosen method for modeling sources less than 50 km. In situations where you areassessing visibility impacts for sourcereceptor distances less than 50 km, you should use expert modeling judgment in determining visibility impacts, giving consideration to both CALPUFF and other appropriate methods.

In developing your modeling protocol, you may want to consult with EPA and yourregional planning organization (RPO). Upfront consultation will ensure that key technical issues are addressed before you conduct your modeling.

2. With the accepted protocol and compare the predicted visibility impacts with your threshold for ‘‘ contribution. ’’ You should calculate daily visibility values for each receptor as the change in deciviews compared against natural visibility conditions. You can use EPA ’ s ‘‘ Guidance for Estimating Natural Visibility Conditions Under the Regional Haze Rule, ’’ EPA

– 454/B

– 03

– 005 (September 2003) in making this calculation. To determine whether a source may reasonably be anticipated to cause or contribute to visibility impairment at Class I area, you then compare the impacts predicted by the model against the threshold that you have selected.

The emissions estimates used in the models are intended to reflect steady-state operating conditions during periods of high capacity utilization. We do not generally recommend that emissions reflecting periods of start-up, shutdown, and malfunction be used, as such emission rates could produce higher than normal effects than would be typical of most facilities. We recommend that States use the 24 hour average actual emission rate from the highest emitting day of the meteorological period modeled, unless this rate reflects periods start-up, shutdown, or malfunction. In addition, the monthly average relative humidity is used, rather than the daily average humidity

— an approach that effectively lowers the peak values in daily model averages.

For these reasons, if you use the modeling approach we recommend, you should
compare your ‘‘ contribution ’’ threshold against the 98th percentile of values. If the 98th percentile value from your modeling is less than your contribution threshold, then you may conclude that the source does not contribute to visibility impairment and is not subject to BART. Option 2: Use of Model Plants To Exempt Individual Sources With Common Characteristics

Under this option, analyses of model plants could be used to exempt certain BART-eligible sources that share specific characteristics. It may be most useful to use this type of analysis to identify the types of small sources that do not cause or contribute to visibility impairment for purposes of BART, and thus should not be subject to a BART review. Different Class I areas may have different characteristics, however, so


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10 CALPUFF Analysis in Support of the June 2005 Changes to the Regional Haze Rule, U.S. Environmental Protection Agency, June 15, 2005, Docket No. OAR

– 2002

– 0076. 11 That is, emission units that were in existence on August 7, 1977 and which began actual operation on or after August 7, 1962. you should use care to ensure that the criteria you develop are appropriate for the applicable cases.

In carrying out this approach, you could use modeling analyses of representative plants to reflect groupings of specific sources with important common characteristics. Based on these analyses, you may find that certain types of sources are clearly anticipated to cause or contribute to visibility impairment. You could then choose to categorically require those types of sources to undergo a BART determination. Conversely, you may find based on representative plant analyses that certain types of sources are not reasonably anticipated to cause or contribute to visibility impairment. To do this, you may conduct your own modeling to establish emission levels and distances from Class I areas on which you can rely to exempt sources with those characteristics. For example, based on your modeling you might choose to exempt all NO X -only sources that emit less than a certain amount per year and are located a certain distance from a Class I area. You could then choose to categorically exempt such sources from the BART determination process.

Our analyses of visibility impacts from model plants provide a useful example of the type of analyses that can be used to exempt categories of sources from BART. 10 In our analyses, we developed model plants (EGUs and non-EGUs), with representative plume and stack characteristics, for use in considering the visibility impact from emission sources of different sizes and compositions at distances of 50, 100 and 200 kilometers from two hypothetical Class I areas (one in the East and one in the West). As the plume and stack characteristics of these model plants were developed considering the broad range of sources within the EGU and non-EGU categories, they do not necessarily represent any specific plant. However, the results of these analyses are instructive in the development of an exemption process for any Class I area.

In preparing our analyses, we have made a number of assumptions and exercised certain modeling choices; some of these have a tendency to lend conservatism to the results, overstating the likely effects, while others may understate the likely effects. On balance, when all of these factors are considered, we believe that our examples reflect realistic treatments of the situations being modeled. Based on our analyses, we believe that a State that has established 0.5 deciviews as a contribution threshold could reasonably exempt from the BART review process sources that emit less than 500 tons per year of NO X or SO 2 (or combined NO X and SO 2 ), as long as these sources are located more than 50 kilometers from any Class I area; and sources that emit less than 1000 tons per year of NO X or SO 2 (or combined NO X and SO 2 ) that are located more than 100 kilometers from any Class I area. You do, however, have the option of showing other thresholds might also be appropriate given your specific circumstances. Option 3: Cumulative Modeling To Show That No Sources in a State Are Subject to BART

You may also submit to EPA a demonstration based on an analysis of overallvisibility impacts that emissions from BARTeligible sources in your State, considered together, are not reasonably anticipated to cause or contribute to any visibility impairment in a Class I area, and thus no source should be subject to BART. You may do this on a pollutant by pollutant basis or for all visibility-impairing pollutants to determine if emissions from these sources contribute to visibility impairment.

For example, emissions of SO 2 from your BART-eligible sources may clearly cause or contribute to visibility impairment while direct emissions of PM 2.5 from these sources may not contribute to impairment. If you can make such a demonstration, then you mayreasonably conclude that none of your BARTeligible sources are subject to BART for a particular pollutant or pollutants. As noted above, your demonstration should take into account the interactions among pollutants and their resulting impacts on visibility before making any pollutant-specific determinations.

Analyses may be conducted using several alternative modeling approaches. First, you may use the CALPUFF or other appropriate model as described in Option 1 to evaluate the impacts of individual sources on downwind Class I areas, aggregating those impacts to determine the collective contribution of all BART-eligible sources to visibility impairment. You may also use a photochemical grid model. As a general matter, the larger the number of sources being modeled, the more appropriate it may be to use a photochemical grid model. However, because such models are significantly less sensitive than dispersion models to the contributions of one or a few sources, as well as to the interactions among sources that are widely distributed geographically, if you wish to use a grid model, you should consult with the appropriate EPA Regional Office to develop an appropriate modeling protocol. IV. The BART Determination: Analysis of BART Options

This section describes the process for the analysis of control options for sources subject to BART. A. What factors must I address in the BART review?

The visibility regulations define BART as follows:

Best Available Retrofit Technology (BART) means an emission limitation based on the degree of reduction achievable through the application of the best system of continuous emission reduction for each pollutant which is emitted by . . . [a BART-eligible source]. The emission limitation must be established, on a case-by-case basis, taking into consideration the technology available, the costs of compliance, the energy and non-air quality environmental impacts of compliance, any pollution control equipment in use or in existence at the source, the remaining useful life of the source, and the degree of improvement in visibility which may reasonably be anticipated to result from the use of such technology.

The BART analysis identifies the best system of continuous emission reduction taking into account:

(1) The available retrofit control options, (2) Any pollution control equipment in use at the source (which affects the availability of options and their impacts),

(3) The costs of compliance with control options,

(4) The remaining useful life of the facility, (5) The energy and non-air quality environmental impacts of control options

(6) The visibility impacts analysis. B. What is the scope of the BART review?

Once you determine that a source is subject to BART for a particular pollutant, then for each affected emission unit, you must establish BART for that pollutant. The BART determination must address air pollution control measures for each emissions unit or pollutant emitting activity subject to review.

Example: Plantwide emissions from emission units within the listed categories that began operation within the ‘‘ time window ’’ for BART 11 are 300 tons/yr of NO X , 200 tons/yr of SO 2 , and 150 tons/yr of primary particulate. Emissions unit A emits 200 tons/yr of NO X , 100 tons/yr of SO 2 , and 100 tons/yr of primary particulate. Other emission units, units B through H, which began operating in 1966, contribute lesser amounts of each pollutant. For this example, a BART review is required for NO X , SO 2 , and primary particulate, and control options must be analyzed for units B through H as well as unit A.

C. How does a BART review relate to Maximum Achievable Control Technology (MACT) Standards under CAA section 112, or to other emission limitations required under the CAA?

For VOC and PM sources subject to MACT standards, States may streamline the analysis by including a discussion of the MACT controls and whether any major new technologies have been developed subsequent to the MACT standards. We believe that there are many VOC and PM sources that are well controlled because they are regulated by the MACT standards, which EPA developed under CAA section 112. For a few MACT standards, this may also be true for SO 2 . Any source subject to MACT standards must meet a level that is as stringent as the best-controlled 12 percent of sources in the industry. Examples of these hazardous air pollutant sources which effectively control VOC and PM emissions include (among others) secondary lead facilities, organic chemical plants subject to the hazardous organic NESHAP (HON), pharmaceutical production facilities, and equipment leaks and wastewater operations at petroleum refineries. We believe that, in many cases, it will be unlikely that States will identify emission controls more stringent than the MACT standards without


### 39164 Federal Register / Vol. 70, No. 128 / Wednesday, July 6, 2005 / Rules and Regulations

12 In identifying ‘‘ all ’’ options, you must identify the most stringent option and a reasonable set of options for analysis that reflects a comprehensive list of available technologies. It is not necessary to list all permutations of available control levels that exist for a given technology

— the list is complete if it includes the maximum level of control each technology is capable of achieving. 13 In EPA ’ s 1980 BART guidelines for reasonably attributable visibility impairment, we concluded that NSPS standards generally, at that time, represented the best level sources could install as BART. In the 20 year period since this guidance was developed, there have been advances in SO 2 control technologies as well as technologies for the control of other pollutants, confirmed by a number of recent retrofits at Western power plants. Accordingly, EPA no longer concludes that the NSPS level of controls automatically represents

‘‘ the best these sources can install. ’’ Analysis of the BART factors could result in the selection of a NSPS level of control, but you should reach this conclusion only after considering the full range of control options. identifying control options that would cost many thousands of dollars per ton. Unless there are new technologies subsequent to theMACT standards which would lead to costeffective increases in the level of control, you may rely on the MACT standards for purposes of BART.

We believe that the same rationale also holds true for emissions standards developed for municipal waste incinerators under CAA section 111(d), and for many NSR/PSD determinations and NSR/PSD settlement agreements. However, we do not believe that technology determinations from the 1970s or early 1980s, including new source performance standards (NSPS), should be considered to represent best control for existing sources, as best control levels for recent plant retrofits are more stringent than these older levels.

Where you are relying on these standards to represent a BART level of control, you should provide the public with a discussion of whether any new technologies have subsequently become available.D. What Are the Five Basic Steps of a Caseby-Case BART Analysis?

The five steps are: STEP 1

— Identify All 12 Available Retrofit Control Technologies,

STEP 2

—Eliminate Technically Infeasible Options,

STEP 3

—Evaluate Control Effectiveness of Remaining Control Technologies,

STEP 4

—Evaluate Impacts and Document the Results, and

STEP 5

— Evaluate Visibility Impacts. 1. STEP 1: How do I identify all available retrofit emission control techniques?

1. Available retrofit control options are those air pollution control technologies with a practical potential for application to the emissions unit and the regulated pollutant under evaluation. Air pollution control technologies can include a wide variety of available methods, systems, and techniques for control of the affected pollutant. Technologies required as BACT or LAER are available for BART purposes and must be included as control alternatives. The control alternatives can include not only existing controls for the source category in question but also take into account technology transfer of controls that have been applied to similar source categories and gas streams. Technologies which have not yet been applied to (or permitted for) full scale operations need not be considered as available; we do not expect the source owner to purchase or construct a process or control device that has not already been demonstrated in practice.

2. Where a NSPS exists for a source category (which is the case for most of the categories affected by BART), you should include a level of control equivalent to the NSPS as one of the control options. 13 The NSPS standards are codified in 40 CFR part 60. We note that there are situations where NSPS standards do not require the most stringent level of available control for allsources within a category. For example, postcombustion NO X controls (the most stringent controls for stationary gas turbines) are not required under subpart GG of the NSPS for Stationary Gas Turbines. However, such controls must still be considered available technologies for the BART selection process.

3. Potentially applicable retrofit control alternatives can be categorized in three ways.

• Pollution prevention: use of inherently lower-emitting processes/practices, including the use of control techniques ( e.g. low-NO X burners) and work practices that prevent emissions and result in lower ‘‘ productionspecific ’’ emissions (note that it is not our intent to direct States to switch fuel forms,
e.g. from coal to gas),

• Use of (and where already in place, improvement in the performance of) add-on controls, such as scrubbers, fabric filters, thermal oxidizers and other devices that control and reduce emissions after they are produced, and

• Combinations of inherently loweremitting processes and add-on controls.

4. In the course of the BART review, one or more of the available control options may be eliminated from consideration because they are demonstrated to be technically infeasible or to have unacceptable energy, cost, or non-air quality environmental impacts on a case-by-case (or site-specific) basis. However, at the outset, you should initially identify all control options with potential application to the emissions unit under review.

5. We do not consider BART as a requirement to redesign the source when considering available control alternatives. For example, where the source subject to BART is a coal-fired electric generator, we do not require the BART analysis to consider building a natural gas-fired electric turbine although the turbine may be inherently less polluting on a per unit basis.

6. For emission units subject to a BART review, there will often be control measures or devices already in place. For such emission units, it is important to include control options that involve improvements to existing controls and not to limit the control options only to those measures that involve a complete replacement of control devices.

Example: For a power plant with an existing wet scrubber, the current control efficiency is 66 percent. Part of the reason for the relatively low control efficiency is that 22 percent of the gas stream bypasses the scrubber. A BART review identifies options for improving the performance of the wet scrubber by redesigning the internal components of the scrubber and by eliminating or reducing the percentage of the gas stream that bypasses the scrubber. Four control options are identified: (1) 78 percent control based upon improved scrubber performance while maintaining the 22 percent bypass, (2) 83 percent control based upon improved scrubber performance while reducing the bypass to 15 percent, (3) 93 percent control based upon improving the scrubber performance while eliminating the bypass entirely, (this option results in a ‘‘ wet stack ’’ operation in which the gas leaving the stack is saturated with water) and (4) 93 percent as in option 3, with the addition of an indirect reheat system to reheat the stack gas above the saturation temperature. You must consider each of these four options in a BART analysis for this source.

7. You are expected to identify potentially applicable retrofit control technologies that represent the full range of demonstrated alternatives. Examples of general information sources to consider include:

• The EPA ’ s Clean Air Technology Center, which includes the RACT/BACT/LAER Clearinghouse (RBLC);

• State and Local Best Available Control Technology Guidelines

— many agencies have online information

— for example South Coast Air Quality Management District, Bay Area Air Quality Management District, and Texas Natural Resources Conservation Commission;

• Control technology vendors;

• Federal/State/Local NSR permits and associated inspection/performance test reports;

• Environmental consultants;

• Technical journals, reports and newsletters, air pollution control seminars; and

• The EPA ’ s NSR bulletin board

— http:// www.epa.gov/ttn/nsr;

• Department of Energy ’ s Clean Coal Program

— technical reports;

• The NO X Control Technology ‘‘ Cost Tool ’’— Clean Air Markets Division Web
page

— http://www.epa.gov/airmarkets/arp/ nox/controltech.html;

• Performance of selective catalytic reduction on coal-fired steam generating units

— final report. OAR/ARD, June 1997 (also available at http://www.epa.gov/ airmarkets/arp/nox/controltech.html );

• Cost estimates for selected applications of NO X control technologies on stationary combustion boilers. OAR/ARD June 1997. (Docket for NO X SIP Call, A

– 96

– 56, item II

– A

– 03);

• Investigation of performance and cost of NO X controls as applied to group 2 boilers. OAR/ARD, August 1996. (Docket for Phase II NO X rule, A

– 95

– 28, item IV

– A

– 4);

• Controlling SO 2 Emissions: A Review of Technologies. EPA

– 600/R

– 00

– 093, USEPA/ ORD/NRMRL, October 2000; and

• The OAQPS Control Cost Manual. You are expected to compile appropriate information from these information sources.

8. There may be situations where a specific set of units within a fenceline constitutes the


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logical set to which controls would apply and that set of units may or may not all be BART-eligible. (For example, some units in that set may not have been constructed between 1962 and 1977.)

9. If you find that a BART source has controls already in place which are the most stringent controls available (note that this means that all possible improvements to any control devices have been made), then it is not necessary to comprehensively complete each following step of the BART analysis in this section. As long these most stringent controls available are made federally enforceable for the purpose of implementing BART for that source, you may skip the remaining analyses in this section, including the visibility analysis in step 5. Likewise, if a source commits to a BART determination that consists of the most stringent controls available, then there is no need to complete the remaining analyses in this section.
2. STEP 2: How do I determine whether the options identified in Step 1 are technically feasible?

In Step 2, you evaluate the technical feasibility of the control options you identified in Step 1. You should document a demonstration of technical infeasibility and should explain, based on physical, chemical, or engineering principles, why technical difficulties would preclude the successful use of the control option on the emissions unit under review. You may then eliminate such technically infeasible control options from further consideration in the BART analysis. In general, what do we mean by technical feasibility?

Control technologies are technically feasible if either (1) they have been installed and operated successfully for the type of source under review under similar conditions, or (2) the technology could be applied to the source under review. Two key concepts are important in determining whether a technology could be applied:

‘‘ availability ’’ and ‘‘ applicability. ’’ As explained in more detail below, a technology is considered ‘‘ available ’’ if the source owner may obtain it through commercial channels, or it is otherwise available within the common sense meaning of the term. An available technology is ‘‘ applicable ’’ if it can reasonably be installed and operated on the source type under consideration. A technology that is available and applicable is technically feasible. What do we mean by ‘‘ available ’’ technology?

1. The typical stages for bringing a control technology concept to reality as a commercial product are:

• Concept stage;

• Research and patenting;

• Bench scale or laboratory testing;

• Pilot scale testing;

• Licensing and commercial demonstration; and

• Commercial sales. 2. A control technique is considered available, within the context presented above, if it has reached the stage of licensing and commercial availability. Similarly, we do not expect a source owner to conduct extended trials to learn how to apply a technology on a totally new and dissimilar source type. Consequently, you would not consider technologies in the pilot scale testing stages of development as ‘‘ available ’’ for purposes of BART review.

3. Commercial availability by itself, however, is not necessarily a sufficient basis for concluding a technology to be applicable and therefore technically feasible. Technical feasibility, as determined in Step 2, also means a control option may reasonably be deployed on or ‘‘ applicable ’’ to the source type under consideration.

Because a new technology may become available at various points in time during the BART analysis process, we believe that guidelines are needed on when a technology must be considered. For example, a technology may become available during the public comment period on the State ’ s rule development process. Likewise, it is possible that new technologies may become available after the close of the State ’ s public comment period and before submittal of the SIP to EPA, or during EPA ’ s review process on the SIP submittal. In order to provide certainty in the process, all technologies should be considered if available before the close of the State ’ s public comment period. You need not consider technologies that become available after this date. As part of your analysis, you should consider any technologies brought to your attention in public comments. If you disagree with public comments asserting that the technology is available, you should provide an explanation for the public record as to the basis for your conclusion. What do we mean by ‘‘ applicable ’’ technology?

You need to exercise technical judgment in determining whether a control alternative is applicable to the source type under consideration. In general, a commercially available control option will be presumed applicable if it has been used on the same or a similar source type. Absent a showing of this type, you evaluate technical feasibility by examining the physical and chemical characteristics of the pollutant-bearing gas stream, and comparing them to the gas stream characteristics of the source types to which the technology had been applied previously. Deployment of the control technology on a new or existing source with similar gas stream characteristics is generally a sufficient basis for concluding the technology is technically feasible barring a demonstration to the contrary as described below. What type of demonstration is required if I conclude that an option is not technically feasible?

1. Where you conclude that a control option identified in Step 1 is technically infeasible, you should demonstrate that the option is either commercially unavailable, or that specific circumstances preclude its application to a particular emission unit. Generally, such a demonstration involves an evaluation of the characteristics of the pollutant-bearing gas stream and the capabilities of the technology. Alternatively, a demonstration of technical infeasibility may involve a showing that there are unresolvable technical difficulties with applying the control to the source ( e.g. , size of the unit, location of the proposed site, operating problems related to specific circumstances of the source, space constraints, reliability, and adverse side effects on the rest of the facility). Where the resolution of technical difficulties is merely a matter of increased cost, you should consider the technology to be technically feasible. The cost of a control alternative is considered later in the process.

2. The determination of technical feasibility is sometimes influenced by recent air quality permits. In some cases, an air quality permit may require a certain level of control, but the level of control in a permit is not expected to be achieved in practice ( e.g. , a source has received a permit but the project was canceled, or every operating source at that permitted level has been physically unable to achieve compliance with the limit). Where this is the case, you should provide supporting documentation showing why such limits are not technically feasible, and, therefore, why the level of control (but not necessarily the technology) may be eliminated from further consideration. However, if there is a permit requiring the application of a certain technology or emission limit to be achieved for such technology, this usually is sufficient justification for you to assume the technical feasibility of that technology or emission limit.

3. Physical modifications needed to resolve technical obstacles do not, in and of themselves, provide a justification for eliminating the control technique on the basis of technical infeasibility. However, you may consider the cost of such modifications in estimating costs. This, in turn, may form the basis for eliminating a control technology (see later discussion).

4. Vendor guarantees may provide an indication of commercial availability and the technical feasibility of a control technique and could contribute to a determination of technical feasibility or technical infeasibility, depending on circumstances. However, we do not consider a vendor guarantee alone to be sufficient justification that a control option will work. Conversely, lack of a vendor guarantee by itself does not present sufficient justification that a control option or an emissions limit is technically infeasible. Generally, you should make decisions about technical feasibility based on chemical, and engineering analyses (as discussed above), in conjunction with information about vendor guarantees.

5. A possible outcome of the BART procedures discussed in these guidelines is the evaluation of multiple control technology alternatives which result in essentially equivalent emissions. It is not our intent to encourage evaluation of unnecessarily large numbers of control alternatives for every emissions unit. Consequently, you should use judgment in deciding on those alternatives for which you will conduct the detailed impacts analysis (Step 4 below). For example, if two or more control techniques result in control levels that are essentially identical, considering the uncertainties of emissions factors and other parameters


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14 The OAQPS Control Cost Manual is updated periodically. While this citation refers to the latest version at the time this guidance was written, you should use the version that is current as of when you conduct your impact analysis. This document is available at the following Web site: http:// www.epa.gov/ttn/catc/dir1/cs1ch2.pdf.

15 You should include documentation for any additional information you used for the cost calculations, including any information supplied by vendors that affects your assumptions regarding purchased equipment costs, equipment life, replacement of major components, and any other element of the calculation that differs from the Control Cost Manual. pertinent to estimating performance, you may evaluate only the less costly of these options. You should narrow the scope of the BART analysis in this way only if there is a negligible difference in emissions and energy and non-air quality environmental impacts between control alternatives. 3. STEP 3: How do I evaluate technically feasible alternatives?

Step 3 involves evaluating the control effectiveness of all the technically feasible control alternatives identified in Step 2 for the pollutant and emissions unit under review.

Two key issues in this process include: (1) Making sure that you express the degree of control using a metric that ensures an

‘‘ apples to apples ’’ comparison of emissions performance levels among options, and

(2) Giving appropriate treatment and consideration of control techniques that can operate over a wide range of emission performance levels. What are the appropriate metrics for comparison?

This issue is especially important when you compare inherently lower-polluting processes to one another or to add-on controls. In such cases, it is generally most effective to express emissions performance as an average steady state emissions level per unit of product produced or processed.

Examples of common metrics:

• Pounds of SO 2 emissions per million Btu heat input, and

• Pounds of NO X emissions per ton of cement produced. How do I evaluate control techniques with a wide range of emission performance levels?

1. Many control techniques, including both add-on controls and inherently lower polluting processes, can perform at a wide range of levels. Scrubbers and high and low efficiency electrostatic precipitators (ESPs) are two of the many examples of such control techniques that can perform at a wide range of levels. It is not our intent to require analysis of each possible level of efficiency for a control technique as such an analysis would result in a large number of options. It is important, however, that in analyzing the technology you take into account the most stringent emission control level that the technology is capable of achieving. You should consider recent regulatory decisions and performance data ( e.g. , manufacturer ’ s data, engineering estimates and the experience of other sources) when identifying an emissions performance level or levels to evaluate.

2. In assessing the capability of the control alternative, latitude exists to consider special circumstances pertinent to the specific source under review, or regarding the prior application of the control alternative. However, you should explain the basis for choosing the alternate level (or range) of control in the BART analysis. Without a showing of differences between the source and other sources that have achieved more stringent emissions limits, you should conclude that the level being achieved by those other sources is representative of the achievable level for the source being analyzed. 3. You may encounter cases where you may wish to evaluate other levels of control in addition to the most stringent level for a given device. While you must consider the most stringent level as one of the control options, you may consider less stringent levels of control as additional options. This would be useful, particularly in cases where the selection of additional options would have widely varying costs and other impacts.

4. Finally, we note that for retrofitting existing sources in addressing BART, you should consider ways to improve the performance of existing control devices, particularly when a control device is not achieving the level of control that other similar sources are achieving in practice with the same device. For example, you should consider requiring those sources with electrostatic precipitators (ESPs) performing below currently achievable levels to improve their performance. 4. STEP 4: For a BART review, what impacts am I expected to calculate and report? What methods does EPA recommend for the impacts analysis?

After you identify the available and technically feasible control technology options, you are expected to conduct the following analyses when you make a BART determination:

Impact analysis part 1: Costs of compliance,

Impact analysis part 2: Energy impacts, and Impact analysis part 3: Non-air quality environmental impacts.

Impact analysis part 4: Remaining useful life. In this section, we describe how to conduct each of these three analyses. You are responsible for presenting an evaluation of each impact along with appropriate supporting information. You should discuss and, where possible, quantify both beneficial and adverse impacts. In general, the analysis should focus on the direct impact of the control alternative. a. Impact analysis part 1: how do I estimate the costs of control?

1. To conduct a cost analysis, you: (1) Identify the emissions units being controlled,

(2) Identify design parameters for emission controls, and

(3) Develop cost estimates based upon those design parameters.

2. It is important to identify clearly the emission units being controlled, that is, to specify a well-defined area or process segment within the plant. In some cases, multiple emission units can be controlled jointly. However, in other cases, it may be appropriate in the cost analysis to consider whether multiple units will be required to install separate and/or different control devices. The analysis should provide a clear summary list of equipment and the associated control costs. Inadequate documentation of the equipment whose emissions are being controlled is a potential cause for confusion in comparison of costs of the same controls applied to similar sources.

3. You then specify the control system design parameters. Potential sources of these design parameters include equipment vendors, background information documents used to support NSPS development, control technique guidelines documents, cost manuals developed by EPA, control data in trade publications, and engineering and performance test data. The following are a few examples of design parameters for two example control measures:

Control device Examples of design parameters

Wet Scrubbers .. Type of sorbent used (lime, limestone, etc.). Gas pressure drop. Liquid/gas ratio.Selective Catalytic Reduction. Ammonia to NO X molar ratio. Pressure drop. Catalyst life.

4. The value selected for the design parameter should ensure that the control option will achieve the level of emission control being evaluated. You should include in your analysis documentation of your assumptions regarding design parameters. Examples of supporting references would include the EPA OAQPS Control Cost Manual (see below) and background information documents used for NSPS and hazardous pollutant emission standards. If the design parameters you specified differ from typical designs, you should document the difference by supplying performance test data for the control technology in question applied to the same source or a similar

source.

5. Once the control technology alternatives and achievable emissions performance levels have been identified, you then develop estimates of capital and annual costs. The basis for equipment cost estimates also should be documented, either with data supplied by an equipment vendor ( i.e.

, budget estimates or bids) or by a referenced source (such as the OAQPS Control Cost Manual, Fifth Edition, February 1996, EPA 453/B

– 96

– 001). 14 In order to maintain and improve consistency, cost estimates should be based on the OAQPS Control Cost Manual, where possible. 15 The Control Cost Manual addresses most control technologies in sufficient detail for a BART analysis. The cost analysis should also take into account any site-specific design or other conditions identified above that affect the cost of a particular BART technology option.


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16 Whenever you calculate or report annual costs, you should indicate the year for which the costs are estimated. For example, if you use the year 2000 as the basis for cost comparisons, you would report that an annualized cost of $20 million would be: $20 million (year 2000 dollars). b. What do we mean by cost effectiveness?

Cost effectiveness, in general, is a criterion used to assess the potential for achieving an objective in the most economical way. For purposes of air pollutant analysis,

‘‘ effectiveness ’’ is measured in terms of tons of pollutant emissions removed, and ‘‘ cost ’’ is measured in terms of annualized controlcosts. We recommend two types of costeffectiveness calculations

— average cost effectiveness, and incremental cost effectiveness. c. How do I calculate average cost effectiveness?

Average cost effectiveness means the total annualized costs of control divided by annual emissions reductions (the difference between baseline annual emissions and the estimate of emissions after controls), using the following formula: Average cost effectiveness (dollars per ton removed) = Control option annualized
cost 16 Baseline annual emissions

— Annual emissions with Control option Because you calculate costs in (annualized) dollars per year ($/yr) and because you calculate emissions rates in tons per year(tons/yr), the result is an average costeffectiveness number in (annualized) dollars per ton ($/ton) of pollutant removed.
d. How do I calculate baseline emissions?

1. The baseline emissions rate should represent a realistic depiction of anticipated annual emissions for the source. In general, for the existing sources subject to BART, you will estimate the anticipated annual emissions based upon actual emissions from a baseline period.

2. When you project that future operating parameters ( e.g. , limited hours of operation or capacity utilization, type of fuel, raw materials or product mix or type) will differ from past practice, and if this projection has a deciding effect in the BART determination, then you must make these parameters or assumptions into enforceable limitations. In the absence of enforceable limitations, you calculate baseline emissions based upon continuation of past practice.

3. For example, the baseline emissions calculation for an emergency standby generator may consider the fact that the source owner would not operate more than past practice of 2 weeks a year. On the other hand, baseline emissions associated with a base-loaded turbine should be based on its past practice which would indicate a large number of hours of operation. This produces a significantly higher level of baseline emissions than in the case of the emergency/standby unit and results in more costeffective controls. As a consequence of the dissimilar baseline emissions, BART for the two cases could be very different.
e. How do I calculate incremental cost effectiveness?

1. In addition to the average cost effectiveness of a control option, you should also calculate incremental cost effectiveness. You should consider the incremental cost effectiveness in combination with the average cost effectiveness when considering whether to eliminate a control option. The incremental cost effectiveness calculation compares the costs and performance level of a control option to those of the next most stringent option, as shown in the following formula (with respect to cost per emissions reduction): Incremental Cost Effectiveness (dollars per incremental ton removed) = (Total annualized costs of control option)

¥ (Total annualized costs of next control option) ÷ (Control option annual emissions) ¥ (Next control option annual emissions) Example 1: Assume that Option F on Figure 2 has total annualized costs of $1 million to reduce 2000 tons of a pollutant, and that Option D on Figure 2 has total annualized costs of $500,000 to reduce 1000 tons of the same pollutant. The incremental cost effectiveness of Option F relative to Option D is ($1 million ¥ $500,000) divided by (2000 tons ¥ 1000 tons), or $500,000 divided by 1000 tons, which is $500/ton.

Example 2: Assume that two control options exist: Option 1 and Option 2. Option 1 achieves a 1,000 ton/yr reduction at an annualized cost of $1,900,000. This represents an average cost of ($1,900,000/ 1,000 tons) = $1,900/ton. Option 2 achieves a 980 tons/yr reduction at an annualized cost of $1,500,000. This represents an average cost of ($1,500,000/980 tons) = $1,531/ton. The incremental cost effectiveness of Option 1 relative to Option 2 is ($1,900,000

¥ $1,500,000) divided by (1,000 tons ¥ 980 tons). The adoption of Option 1 instead of Option 2 results in an incremental emission reduction of 20 tons per year at an additional cost of $400,000 per year. The incremental cost of Option 1, then, is $20,000 per ton

¥ 11 times the average cost of $1,900 per ton. While $1,900 per ton may still be deemed reasonable, it is useful to consider both the average and incremental cost in making an overall cost-effectiveness finding. Of course, there may be other differences between theseoptions, such as, energy or water use, or nonair environmental effects, which also should be considered in selecting a BART technology.

2. You should exercise care in deriving incremental costs of candidate control options. Incremental cost-effectiveness comparisons should focus on annualized cost and emission reduction differences between

‘‘ dominant ’’ alternatives. To identify dominant alternatives, you generate a graphical plot of total annualized costs for total emissions reductions for all control alternatives identified in the BART analysis, and by identifying a ‘‘ least-cost envelope ’’ as shown in Figure 2. (A ‘‘ least-cost envelope ’’ represents the set of options that should be dominant in the choice of a specific option.)


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Example: Eight technically feasible control options for analysis are listed. These are represented as A through H in Figure 2. The dominant set of control options, B, D, F, G, and H, represent the least-cost envelope, as we depict by the cost curve connecting them. Points A, C and E are inferior options, and you should not use them in calculating incremental cost effectiveness. Points A, C and E represent inferior controls because B will buy more emissions reductions for less money than A; and similarly, D and F will buy more reductions for less money than C and E, respectively.

3. In calculating incremental costs, you: (1) Array the control options in ascending order of annualized total costs,

(2) Develop a graph of the most reasonable smooth curve of the control options, as shown in Figure 2. This is to show the ‘‘ leastcost envelope ’’ discussed above; and

(3) Calculate the incremental cost effectiveness for each dominant option, which is the difference in total annual costs between that option and the next most stringent option, divided by the difference in emissions, after controls have been applied, between those two control options. For example, using Figure 2, you would calculate incremental cost effectiveness for the difference between options B and D, options D and F, options F and G, and options G and H.

4. A comparison of incremental costs can also be useful in evaluating the viability of a specific control option over a range of efficiencies. For example, depending on the capital and operational cost of a control device, total and incremental cost may vary significantly (either increasing or decreasing) over the operational range of a control device. Also, the greater the number of possible control options that exist, the more weight should be given to the incremental costs vs. average costs. It should be noted that average and incremental cost effectiveness are identical when only one candidate control option is known to exist.

5. You should exercise caution not to misuse these techniques. For example, you may be faced with a choice between two available control devices at a source, control A and control B, where control B achieves slightly greater emission reductions. The average cost (total annual cost/total annual emission reductions) for each may be deemed to be reasonable. However, the incremental cost (total annual cost A

– B /total annual emission reductions A

– B ) of the additional emission reductions to be achieved by control B may be very great. In such an instance, it may be inappropriate to choose control B, based on its high incremental costs, even though its average cost may be considered reasonable.

6. In addition, when you evaluate the average or incremental cost effectiveness of a control alternative, you should make reasonable and supportable assumptions regarding control efficiencies. An unrealistically low assessment of the emission reduction potential of a certaintechnology could result in inflated costeffectiveness figures. f. What other information should I provide in the cost impacts analysis?

You should provide documentation of any unusual circumstances that exist for the source that would lead to cost-effectiveness estimates that would exceed that for recent retrofits. This is especially important in cases where recent retrofits have cost-effectiveness values that are within what has been considered a reasonable range, but your analysis concludes that costs for the source being analyzed are not considered reasonable. (A reasonable range would be a range that is consistent with the range of cost effectiveness values used in other similar permit decisions over a period of time.)

Example: In an arid region, large amounts of water are needed for a scrubbing system. Acquiring water from a distant location could greatly increase the cost per ton of emissions reduced of wet scrubbing as a control option. g. What other things are important to consider in the cost impacts analysis?

In the cost analysis, you should take care not to focus on incomplete results or partial calculations. For example, large capital costs for a control option alone would not preclude selection of a control measure if large emissions reductions are projected. In such a case, low or reasonable cost effectiveness numbers may validate the option as an appropriate BART alternative irrespective of the large capital costs. Similarly, projects with relatively low capital costs may not be cost effective if there are few emissions reduced. h. Impact analysis part 2: How should I analyze and report energy impacts?

1. You should examine the energy requirements of the control technology and determine whether the use of that technology results in energy penalties or benefits. A source owner may, for example, benefit from the combustion of a concentrated gas stream rich in volatile organic compounds; on the other hand, more often extra fuel or electricity is required to power a control


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device or incinerate a dilute gas stream. If such benefits or penalties exist, they should be quantified to the extent practicable. Because energy penalties or benefits can usually be quantified in terms of additional cost or income to the source, the energy impacts analysis can, in most cases, simply be factored into the cost impacts analysis. The fact of energy use in and of itself does not disqualify a technology.

2. Your energy impact analysis should consider only direct energy consumption and not indirect energy impacts. For example, you could estimate the direct energy impacts of the control alternative in units of energy consumption at the source ( e.g. , BTU, kWh, barrels of oil, tons of coal). The energy requirements of the control options should be shown in terms of total (and in certain cases, also incremental) energy costs per ton of pollutant removed. You can then convert these units into dollar costs and, where appropriate, factor these costs into the control cost analysis.

3. You generally do not consider indirect energy impacts (such as energy to produce raw materials for construction of control equipment). However, if you determine, either independently or based on a showing by the source owner, that the indirect energy impact is unusual or significant and that the impact can be well quantified, you may consider the indirect impact.

4. The energy impact analysis may also address concerns over the use of locally scarce fuels. The designation of a scarce fuel may vary from region to region. However, in general, a scarce fuel is one which is in short supply locally and can be better used for alternative purposes, or one which may not be reasonably available to the source either at the present time or in the near future.

5. Finally, the energy impacts analysis may consider whether there are relative differences between alternatives regarding the use of locally or regionally available coal, and whether a given alternative would result in significant economic disruption or unemployment. For example, where two options are equally cost effective and achieve equivalent or similar emissions reductions, one option may be preferred if the other alternative results in significant disruption or unemployment. i. Impact analysis part 3: How do I analyze

‘‘ non-air quality environmental impacts? ’’

1. In the non-air quality related environmental impacts portion of the BART analysis, you address environmental impacts other than air quality due to emissions of the pollutant in question. Such environmental impacts include solid or hazardous waste generation and discharges of polluted water from a control device.

2. You should identify any significant or unusual environmental impacts associated with a control alternative that have the potential to affect the selection or elimination of a control alternative. Some control technologies may have potentially significant secondary environmental impacts. Scrubber effluent, for example, may affect water quality and land use. Alternatively, water availability may affect the feasibility and costs of wet scrubbers. Other examples of secondary environmental impacts could include hazardous waste discharges, such as spent catalysts or contaminated carbon. Generally, these types of environmental concerns become important when sensitive site-specific receptors exist or when the incremental emissions reductions potential of the more stringent control is onlymarginally greater than the next mosteffective option. However, the fact that a control device creates liquid and solid waste that must be disposed of does not necessarily argue against selection of that technology as BART, particularly if the control device has been applied to similar facilities elsewhere and the solid or liquid waste is similar to those other applications. On the other hand, where you or the source owner can show that unusual circumstances at the proposed facility create greater problems than experienced elsewhere, this may provide a basis for the elimination of that control alternative as BART.

3. The procedure for conducting an analysis of non-air quality environmental impacts should be made based on a consideration of site-specific circumstances. If you propose to adopt the most stringent alternative, then it is not necessary to perform this analysis of environmental impacts for the entire list of technologies you ranked in Step 3. In general, the analysis need only address those control alternatives with any significant or unusual environmental impacts that have the potential to affect the selection of a control alternative, or elimination of a more stringent control alternative. Thus, any important relative environmental impacts (both positive and negative) of alternatives can be compared with each other.

4. In general, the analysis of impacts starts with the identification and quantification of the solid, liquid, and gaseous discharges from the control device or devices under review. Initially, you should perform a qualitative or semi-quantitative screening to narrow the analysis to discharges with potential for causing adverse environmental effects. Next, you should assess the mass and composition of any such discharges and quantify them to the extent possible, based on readily available information. You should also assemble pertinent information about the public or environmental consequences of releasing these materials. j. Impact analysis part 4: What are examples of non-air quality environmental impacts?

The following are examples of how to conduct non-air quality environmental impacts:

(1) Water Impact You should identify the relative quantities of water used and water pollutants produced and discharged as a result of the use of each alternative emission control system. Where possible, you should assess the effect on ground water and such local surface water quality parameters as ph, turbidity, dissolved oxygen, salinity, toxic chemical levels, temperature, and any other important considerations. The analysis could consider whether applicable water quality standards will be met and the availability and effectiveness of various techniques to reduce potential adverse effects.

(2) Solid Waste Disposal Impact You could also compare the quality and quantity of solid waste ( e.g. , sludges, solids) that must be stored and disposed of or recycled as a result of the application of each alternative emission control system. You should consider the composition and various other characteristics of the solid waste (such as permeability, water retention, rewatering of dried material, compression strength, leachability of dissolved ions, bulk density, ability to support vegetation growth and hazardous characteristics) which are significant with regard to potential surface water pollution or transport into and contamination of subsurface waters or aquifers.

(3) Irreversible or Irretrievable Commitment of Resources

You may consider the extent to which the alternative emission control systems may involve a trade-off between short-termenvironmental gains at the expense of longterm environmental losses and the extent to which the alternative systems may result in irreversible or irretrievable commitment of resources (for example, use of scarce water resources).

(4) Other Adverse Environmental Impacts You may consider significant differences in noise levels, radiant heat, or dissipated static electrical energy of pollution control alternatives. Other examples of non-air quality environmental impacts would include hazardous waste discharges such as spent catalysts or contaminated carbon. k. How do I take into account a project ’ s

‘‘ remaining useful life ’’ in calculating control costs?

1. You may decide to treat the requirement to consider the source ’ s ‘‘ remaining useful life ’’ of the source for BART determinations as one element of the overall cost analysis. The ‘‘ remaining useful life ’’ of a source, if it represents a relatively short time period, may affect the annualized costs of retrofit controls. For example, the methods for calculating annualized costs in EPA ’ s OAQPS Control Cost Manual require the use of a specified time period for amortization that varies based upon the type of control. If the remaining useful life will clearly exceed this time period, the remaining useful life has essentially no effect on control costs and on the BART determination process. Where the remaining useful life is less than the time period for amortizing costs, you should use this shorter time period in your cost calculations.

2. For purposes of these guidelines, the remaining useful life is the difference between:

(1) The date that controls will be put in place (capital and other construction costs incurred before controls are put in place can be rolled into the first year, as suggested in EPA ’ s OAQPS Control Cost Manual ); you are conducting the BART analysis; and

(2) The date the facility permanently stops operations. Where this affects the BART determination, this date should be assured by a federally- or State-enforceable restriction preventing further operation.

3. We recognize that there may be situations where a source operator intends to shut down a source by a given date, but wishes to retain the flexibility to continue


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17 The model code and its documentation are available at no cost for download from http:// www.epa.gov/scram001/tt22.htm#calpuff. 18 Interagency Workgroup on Air Quality Modeling (IWAQM) Phase 2 Summary Report and Recommendations for Modeling Long Range Transport Impacts, U.S. Environmental Protection Agency, EPA

– 454/R

– 98

– 019, December 1998. operating beyond that date in the event, for example, that market conditions change. Where this is the case, your BART analysis may account for this, but it must maintain consistency with the statutory requirement to install BART within 5 years. Where the source chooses not to accept a federally enforceable condition requiring the source to shut down by a given date, it is necessary to determine whether a reduced time period for the remaining useful life changes the level of controls that would have been required as BART.

If the reduced time period does change the level of BART controls, you may identify, and include as part of the BART emission limitation, the more stringent level of control that would be required as BART if there were no assumption that reduced the remaining useful life. You may incorporate into the BART emission limit this more stringent level, which would serve as a contingency should the source continue operating more than 5 years after the date EPA approves the relevant SIP. The source would not be allowed to operate after the 5-year mark without such controls. If a source does operate after the 5-year mark without BART in place, the source is considered to be in violation of the BART emissions limit for each day of operation. 5. Step 5: How should I determine visibility impacts in the BART determination?

The following is an approach you may use to determine visibility impacts (the degree of visibility improvement for each source subject to BART) for the BART determination. Once you have determined that your source or sources are subject to BART, you must conduct a visibility improvement determination for the source(s) as part of the BART determination. When making this determination, we believe you have flexibility in setting absolute thresholds, target levels of improvement, or de minimis levels since the deciview improvement must be weighed among the five factors, and you are free to determine the weight and significance to be assigned to each factor. For example, a 0.3 deciview improvement may merit a stronger weighting in one case versus another, so one ‘‘ bright line ’’ may not be appropriate. [Note that if sources have elected to apply the most stringent controls available, consistent with the discussion in section E. step 1. below, you need not conduct, or require the source to conduct, an air quality modeling analysis for the purpose of determining its visibility impacts.]

Use CALPUFF, 17 or other appropriate dispersion model to determine the visibility improvement expected at a Class I area from the potential BART control technology applied to the source. Modeling should be conducted for SO 2 , NO X , and direct PM emissions (PM 2.5 and/or PM 10 ). If the source is making the visibility determination, you should review and approve or disapprove of the source ’ s analysis before making the expected improvement determination. There are several steps for determining the visibility impacts from an individual source using a dispersion model:

• Develop a modeling protocol. Some critical items to include in a modeling protocol are meteorological and terrain data, as well as source-specific information (stack height, temperature, exit velocity, elevation, and allowable and actual emission rates of applicable pollutants), and receptor data from appropriate Class I areas. We recommend following EPA ’ s Interagency Workgroup on Air Quality Modeling (IWAQM) Phase 2 Summary Report and Recommendations for Modeling Long Range Transport Impacts 18 for parameter settings and meteorological data inputs; the use of other settings from those in IWAQM should be identified and explained in the protocol.

One important element of the protocol is in establishing the receptors that will be used in the model. The receptors that you use should be located in the nearest Class I area with sufficient density to identify the likely visibility effects of the source. For other Class I areas in relatively close proximity to a BART-eligible source, you may model a few strategic receptors to determine whether effects at those areas may be greater than at the nearest Class I area. For example, you might chose to locate receptors at these areas at the closest point to the source, at the highest and lowest elevation in the Class I area, at the IMPROVE monitor, and at the approximate expected plume release height. If the highest modeled effects are observed at the nearest Class I area, you may choose not to analyze the other Class I areas any further as additional analyses might be unwarranted.

You should bear in mind that some receptors within the relevant Class I area may be less than 50 km from the source while other receptors within that same Class I area may be greater than 50 km from the same source. As indicated by the Guideline on Air Quality Models, this situation may call for the use of two different modeling approaches for the same Class I area and source, depending upon the State ’ s chosen method for modeling sources less than 50 km. In situations where you are assessing visibility impacts for source-receptor distances less than 50 km, you should use expert modeling judgment in determining visibility impacts, giving consideration to both CALPUFF and other EPA-approved methods.

In developing your modeling protocol, you may want to consult with EPA and yourregional planning organization (RPO). Upfront consultation will ensure that key technical issues are addressed before you conduct your modeling.

• For each source, run the model, at precontrol and post-control emission rates according to the accepted methodology in the protocol.

Use the 24-hour average actual emission rate from the highest emitting day of themeteorological period modeled (for the precontrol scenario). Calculate the model results for each receptor as the change in deciviews compared against natural visibility conditions. Post-control emission rates are calculated as a percentage of pre-controlemission rates. For example, if the 24-hr precontrol emission rate is 100 lb/hr of SO 2 , then the post control rate is 5 lb/hr if the control efficiency being evaluated is 95 percent.

• Make the net visibility improvement determination.

Assess the visibility improvement based on the modeled change in visibility impacts for the pre-control and post-control emission scenarios. You have flexibility to assess visibility improvements due to BART controls by one or more methods. You may consider the frequency, magnitude, and duration components of impairment. Suggestions for making the determination

are:

• Use of a comparison threshold, as is done for determining if BART-eligible sources should be subject to a BART determination. Comparison thresholds can be used in a number of ways in evaluating visibility improvement ( e.g. the number of days or hours that the threshold was exceeded, a single threshold for determining whether a change in impacts is significant, or a threshold representing an x percent change in improvement).

• Compare the 98th percent days for the pre- and post-control runs.

Note that each of the modeling options may be supplemented with source apportionment data or source apportionment modeling.

E. How do I select the ‘‘ best ’’ alternative, using the results of Steps 1 through 5? 1. Summary of the Impacts Analysis

From the alternatives you evaluated in Step 3, we recommend you develop a chart (or charts) displaying for each of the alternatives:

(1) Expected emission rate (tons per year, pounds per hour);

(2) Emissions performance level ( e.g. , percent pollutant removed, emissions per unit product, lb/MMBtu, ppm);

(3) Expected emissions reductions (tons per year);

(4) Costs of compliance

— total annualized costs ($), cost effectiveness ($/ton), and incremental cost effectiveness ($/ton), and/or any other cost-effectiveness measures (such as $/deciview);

(5) Energy impacts; (6) Non-air quality environmental impacts; and

(7) Modeled visibility impacts. 2. Selecting a ‘‘ best ’’ alternative

1. You have discretion to determine the order in which you should evaluate control options for BART. Whatever the order in which you choose to evaluate options, you should always (1) display the options evaluated; (2) identify the average and incremental costs of each option; (3) consider the energy and non-air quality environmental impacts of each option; (4) consider the remaining useful life; and (5) consider the modeled visibility impacts. You should provide a justification for adopting the technology that you select as the ‘‘ best ’’ level of control, including an explanation of the


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CAA factors that led you to choose that option over other control levels.

2. In the case where you are conducting a BART determination for two regulated pollutants on the same source, if the result is two different BART technologies that do not work well together, you could then substitute a different technology or combination of technologies. 3. In selecting a ‘‘ best ’’ alternative, should I consider the affordability of controls?

1. Even if the control technology is cost effective, there may be cases where the installation of controls would affect the viability of continued plant operations.

2. There may be unusual circumstances that justify taking into consideration the conditions of the plant and the economic effects of requiring the use of a given control technology. These effects would include effects on product prices, the market share, and profitability of the source. Where there are such unusual circumstances that are judged to affect plant operations, you may take into consideration the conditions of the plant and the economic effects of requiring the use of a control technology. Where these effects are judged to have a severe impact on plant operations you may consider them in the selection process, but you may wish to provide an economic analysis that demonstrates, in sufficient detail for public review, the specific economic effects, parameters, and reasoning. (We recognize that this review process must preserve the confidentiality of sensitive business information). Any analysis may also consider whether other competing plants in the same industry have been required to install BART controls if this information is available. 4. Sulfur dioxide limits for utility boilers

You must require 750 MW power plants to meet specific control levels for SO 2 of either 95 percent control or 0.15 lbs/MMBtu, for each EGU greater than 200 MW that is currently uncontrolled unless you determine that an alternative control level is justified based on a careful consideration of the statutory factors. Thus, for example, if the source demonstrates circumstances affecting its ability to cost-effectively reduce its emissions, you should take that into account in determining whether the presumptive levels of control are appropriate for that facility. For a currently uncontrolled EGU greater than 200 MW in size, but located at a power plant smaller than 750 MW in size, such controls are generally cost-effective and could be used in your BART determination considering the five factors specified in CAA section 169A(g)(2). While these levels may represent current control capabilities, we expect that scrubber technology will continue to improve and control costs continue to decline. You should be sure to consider the level of control that is currently best achievable at the time that you are conducting your BART analysis.

For coal-fired EGUs with existing postcombustion SO 2 controls achieving less than 50 percent removal efficiencies, we recommend that you evaluate constructing a new FGD system to meet the same emission limits as above (95 percent removal or 0.15 lb/mmBtu), in addition to the evaluation ofscrubber upgrades discussed below. For oilfired units, regardless of size, you should evaluate limiting the sulfur content of the fuel oil burned to 1 percent or less by weight.

For those BART-eligible EGUs with preexisting post-combustion SO 2 controls achieving removal efficiencies of at least 50 percent, your BART determination should consider cost effective scrubber upgrades designed to improve the system ’ s overall SO 2 removal efficiency. There are numerous scrubber enhancements available to upgrade the average removal efficiencies of all types of existing scrubber systems. We recommend that as you evaluate the definition of

‘‘ upgrade, ’’ you evaluate options that not only improve the design removal efficiency of the scrubber vessel itself, but also consider upgrades that can improve the overall SO 2 removal efficiency of the scrubber system. Increasing a scrubber system ’ s reliability, and conversely decreasing its downtime, by way of optimizing operation procedures, improving maintenance practices, adjusting scrubber chemistry, and increasing auxiliary equipment redundancy, are all ways to improve average SO 2 removal efficiencies.

We recommend that as you evaluate the performance of existing wet scrubber systems, you consider some of the following upgrades, in no particular order, as potential scrubber upgrades that have been proven in the industry as cost effective means to increase overall SO 2 removal of wet systems:

(a) Elimination of Bypass Reheat; (b) Installation of Liquid Distribution Rings;

(c) Installation of Perforated Trays; (d) Use of Organic Acid Additives; (e) Improve or Upgrade Scrubber Auxiliary System Equipment; (f) Redesign Spray Header or Nozzle Configuration.

We recommend that as you evaluate upgrade options for dry scrubber systems, you should consider the following cost effective upgrades, in no particular order:

(a) Use of Performance Additives; (b) Use of more Reactive Sorbent; (c) Increase the Pulverization Level of Sorbent;

(d) Engineering redesign of atomizer or slurry injection system.

You should evaluate scrubber upgrade options based on the 5 step BART analysis
process. 5. Nitrogen oxide limits for utility boilers

You should establish specific numerical limits for NO X control for each BART determination. For power plants with a generating capacity in excess of 750 MW currently using selective catalytic reduction (SCR) or selective non-catalytic reduction (SNCR) for part of the year, you shouldpresume that use of those same controls yearround is BART. For other sources currently using SCR or SNCR to reduce NO X emissions during part of the year, you should carefully consider requiring the use of these controls year-round as the additional costs of operating the equipment throughout the year would be relatively modest.

For coal-fired EGUs greater than 200 MW located at greater than 750 MW power plants and operating without post-combustion controls ( i.e. SCR or SNCR), we have provided presumptive NO X limits, differentiated by boiler design and type of coal burned. You may determine that an alternative control level is appropriate based on a careful consideration of the statutory factors. For coal-fired EGUs greater than 200 MW located at power plants 750 MW or lessin size and operating without postcombustion controls, you should likewisepresume that these same levels are costeffective. You should require such utility boilers to meet the following NO X emission limits, unless you determine that an alternative control level is justified based on consideration of the statutory factors. The following NO X emission rates were determined based on a number of assumptions, including that the EGU boiler has enough volume to allow for installation and effective operation of separated overfire air ports. For boilers where these assumptions are incorrect, these emission limits may not be cost-effective.


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19 No Cell burners, dry-turbo-fired units, nor wetbottom tangential-fired units burning lignite were identified as BART-eligible, thus no presumptive limit was determined. Similarly, no wet-bottom tangential-fired units burning sub-bituminous were identified as BART-eligible.

20 These limits reflect the design and technological assumptions discussed in the technical support document for NO X limits for these guidelines. See Technical Support Document for BART NO X Limits for Electric Generating Units and Technical Support Document for BART NO X Limits for Electric Generating Units Excel Spreadsheet, Memorandum to Docket OAR 2002

– 0076, April 15, 2005. 21 See Technical Support Document for BART NO X Limits for Electric Generating Units and Technical Support Document for BART NO X Limits for Electric Generating Units Excel Spreadsheet, Memorandum to Docket OAR 2002

– 0076, April 15,
2005. 22 70 FR 9705, February 28, 2005. 

### T ABLE 

### 1.

— P RESUMPTIVE 

### NO X 

### E MISSION 

### L IMITS FOR 

### BART-E LIGIBLE 

### C OAL 

### -F IRED 

### U NITS



### . 19

Unit type Coal type NO X presumptive limit (lb/mmbtu) 20

Dry-bottom wall-fired ................................................................. Bituminous ............................... ................................................. 0.39 Sub-bituminous ........................................................................ 0.23 Lignite ....................................................................................... 0.29 Tangential-fired ......................................................................... Bituminous ............................ .................................................... 0.28 Sub-bituminous ........................................................................ 0.15 Lignite ....................................................................................... 0.17 Cell Burners .............................................................................. Bituminous ........................... ..................................................... 0.40 Sub-bituminous ........................................................................ 0.45 Dry-turbo-fired ........................................................................... Bituminous ........................... ..................................................... 0.32 Sub-bituminous ........................................................................ 0.23 Wet-bottom tangential-fired ...................................................... Bituminous .................................... ............................................ 0.62

MostEGUs can meet these presumptive NO X limits through the use of current combustion control technology, i.e. thecareful control of combustion air and lowNO X burners. For units that cannot meet these limits using such technologies, you should consider whether advanced combustion control technologies such as rotating opposed fire air should be used to meet these limits.

Because of the relatively high NO X emission rates of cyclone units, SCR is more cost-effective than the use of current combustion control technology for these units. The use of SCRs at cyclone units burning bituminous coal, sub-bituminous coal, and lignite should enable the units to cost-effectively meet NO X rates of 0.10 lbs/ mmbtu. As a result, we are establishing a presumptive NO X limit of 0.10 lbs/mmbtu based on the use of SCR for coal-fired cyclone units greater than 200 MW located at 750 MW power plants. As with the other presumptive limits established in this guideline, you may determine that an alternative level of control is appropriate based on your consideration of the relevant statutory factors. For other cyclone units, you should review the use of SCR and consider whether these post-combustion controls should be required as BART.

For oil-fired and gas-fired EGUs larger than 200MW, we believe that installation of current combustion control technology to control NO X is generally highly cost-effective and should be considered in your determination of BART for these sources. Many such units can make significant reductions in NO X emissions which are highly cost-effective through the application of current combustion control technology. 21 V. Enforceable Limits/Compliance Date

To complete the BART process, you must establish enforceable emission limits that reflect the BART requirements and require compliance within a given period of time. In particular, you must establish an enforceable emission limit for each subject emission unit at the source and for each pollutant subject to review that is emitted from the source. In addition, you must require compliance with the BART emission limitations no later than 5 years after EPA approves your regional haze SIP. If technological or economic limitations in the application of a measurement methodology to a particular emission unit make a conventional emissions limit infeasible, you may instead prescribe a design, equipment, work practice, operation standard, or combination of these types of standards. You should consider allowing
sources to ‘‘ average ’’ emissions across any set of BART-eligible emission units within a fenceline, so long as the emission reductions from each pollutant being controlled for BART would be equal to those reductions that would be obtained by simply controlling each of the BART-eligible units that constitute BART-eligible source.

You should ensure that any BART requirements are written in a way that clearly specifies the individual emission unit(s) subject to BART regulation. Because the BART requirements themselves are

‘‘ applicable ’’ requirements of the CAA, they must be included as title V permit conditions according to the procedures established in 40 CFR part 70 or 40 CFR part 71.

Section 302(k) of the CAA requires emissions limits such as BART to be met on a continuous basis. Although this provision does not necessarily require the use of continuous emissions monitoring (CEMs), it is important that sources employ techniques that ensure compliance on a continuous basis. Monitoring requirements generally applicable to sources, including those that are subject to BART, are governed by other regulations. See, e.g. , 40 CFR part 64 (compliance assurance monitoring); 40 CFR 70.6(a)(3) (periodic monitoring); 40 CFR 70.6(c)(1) (sufficiency monitoring). Note also that while we do not believe that CEMs would necessarily be required for all BART sources, the vast majority of electric generating units potentially subject to BART already employ CEM technology for other programs, such as the acid rain program. In addition, emissions limits must be enforceable as a practical matter (contain appropriate averaging times, compliance verification procedures and recordkeeping requirements). In light of the above, the permit must:

• Be sufficient to show compliance or noncompliance ( i.e. , through monitoring times of operation, fuel input, or other indices of operating conditions and practices); and

• Specify a reasonable averaging time consistent with established reference methods, contain reference methods for determining compliance, and provide for adequate reporting and recordkeeping so that air quality agency personnel can determine the compliance status of the source; and

• For EGUS, specify an averaging time of a 30-day rolling average, and contain a definition of ‘‘ boiler operating day ’’ that is consistent with the definition in the proposed revisions to the NSPS for utility boilers in 40 CFR Part 60, subpart Da. 22 You should consider a boiler operating day to be any 24-hour period between 12:00 midnight and the following midnight during which any fuel is combusted at any time at the steam generating unit. This would allow 30- day rolling average emission rates to be calculated consistently across sources. [FR Doc. 05

– 12526 Filed 7

– 5

– 05; 8:45 am]

**BILLING CODE 6560**

**– 50** 

**– P** 


### Attachment	5

Intalco	Primary	Phone	Log	–	Zach	Hedgpeth

Date Person Topic 9/7/11	 Don	Hug,	Allied	Env.	 Dry scrubbing	temp	requirements. 9/7/11	 Kathryn	Mitchell,	Intalco Jimmy	Jones,	Alcoa Obtaining	Alstom	&	Babcock	quote	docs.

9/20/11	 Kathryn	Mitchell,	Intalco	 Existing	wastewater	treatment facilities	for roofline	scrubbers. 11/16/11	 Kyle	Murphy,	WA	DNR	 Stud ies	required	under	Cherry	Pt	P lan. Discussion	of	DNR	aquatic	leases	in	general. 11/18/11	 Kyle	Murphy,	WA	DNR	 Curre nt	Intalco	aquatic	lease	docu ments. Outfall	location.		Gener al	lease	requirements. 11/22/11	 Randy	Marshall,	Ecology Studies	required	under	Cherry Pt	Plan. 11/22/11	 Kyle	Murphy,	WA	DNR	 Stud ies	required	under	Cherry	Pt	P lan. 11/28/11	 Linda	Martin,	KYDEP	 Rio Tinto	Alcan	plant	wet	scrubbin g	cost analysis. 12/2/11	 Ben	Girtain‐Plowe,	NYDEC	 West	Massena	plant	documents. 12/2/11	 Kathryn	Mitchell,	Intalco Jimmy	Jones,	Alcoa Alstom	&	Babcock	quotes.		Wastewater stream	expected	from	LSFO	per	quote	docs. Current	mini‐scrubbers	on	roofline. 12/8/11	 Stephen	Jilk,	Whatcom PUD	 PUD	ability	to	provide	500k	g pd	increased supply	to	Intalco,	and	related	fees. 12/9/11	 Judy	Schweiters,	Ecology	 Intalco	BART	in	general. 1/6/12	 Judy	Schweiters,	Ecology	 Existing	wastewater	infrastruct ure. 1/10/12	 Randy	Hamilton,	TCEQ	 Perm it	for	Oak	Grove	boiler	with	L SFO. 3/20/12	 Clint	Lamoreaux,	SWCAA	 LS FO	costs	at	TransAlta.		Contac t	with TransAlta. 6/20/12	 Jimmy	Jones,	Alcoa	 EPA	co st	analysis	and	technical	basi s. 7/19/12	 Jimmy	Jones,	Alcoa	 Alcoa	cost	scaling	approach	for	part ial scrubbing.

### Re: Zach's contact info -- Massena East permit Zach Hedgpeth to: Robert Jacobs 01/10/2012 11:26 AM



### Bob,

Thanks for your thoughts and the wastewater update. I'd enjoy talking this aspect over further with you, since our potential project has some noteworthy differences from Massena.

Give me a call sometime if this interests you, Zach

------------------------------------------------------------- Zach Hedgpeth, PE EPA Region 10 Office of Environmental Assessment (206) 553-1217 hedgpeth.zach@epa.gov

"Robert Jacobs" 01/10/2012 10:58:55 AM Not a problem. On a side note, the scrubber in u...

From: "Robert Jacobs" <rxjacobs@gw.dec.state.ny.us> To: Zach Hedgpeth/R10/USEPA/US@EPA Cc: "Steve Botsford" <srbotsfo@gw.dec.state.ny.us>, "Thomas Morgan" <tfmorgan@gw.dec.state.ny.us> Date: 01/10/2012 10:58 AM Subject: Re: Zach's contact info -- Massena East permit



### Not a problem.

On a side note, the scrubber in use in Massena is not without it's problems. The unit is fine for removing the sulfur, but it also picks up some of the fluorides. I don't know the details because this falls under our water resources division, but with the EPA Water Quality regulations, the facility is having problems meeting the water quality standards for fluorides. My understanding is once it's in the water, there's no efficient way of removing. So, it could be a matter of trading one problem for another if a facility were made to install a scrubber.

Something to consider.

Thanks.

Bob

>>> Zach Hedgpeth <Hedgpeth.Zach@epamail.epa .gov> 1/10/2012 1:34 PM >>> I really appreciate the fast action Bob, Zach

### From: "Robert Jacobs" <rxjacobs @ g w

. d ec

. s tate

. n y

. u s > To: Zach Hedgpeth/R10/USEPA/US@EPA Date: 01/10/2012 10:27 AM Subject: Re: Zach's contact info -- Massena East permit

Zach,

Attached is the Title V permit issued for the construction and operation of the Alcoa owned Reynolds Plant in Massena NY.

Let me know if you need anything else.

Bob Jacobs 315-785-6457 NYS DEC Region 6 Watertown, NY

>>> Zach Hedgpeth <Hedgpeth.Zach@epamail.epa .gov> 1/10/2012 1:11 PM >>> Here you are....thanks again Bob. Zach

------------------------------------------------------------- Zach Hedgpeth, PE EPA Region 10 Office of Environmental Assessment (206) 553-1217 hedgpeth.zach@epa.gov

[attachment "Reynolds Metals Massena NY Facility Title V permit 1999.pdf" deleted by Zach Hedgpeth/R10/USEPA/US]

## New York State Department of Environmental Conservation
Division of Environmental Permits, Region 6

• Dulles State Office Building, 317 Washington Street, Watertown, New York 13601-3787 Phone: (315) 785-2245 • FAX: (315) 785-2242**~,.,-..~ ~)**  f:,-'1 ;,'• 

### Website: 

## www .dec.state.ny. us

. \ Alexander B. Grannis Commissioner


### CERTIFIED MAIL • RETURN RECEIPT REQUESTED September 18, 2007

REYNOLDS METALS COMPANY ALCOA-EAST Attn: Mr. Wesley N. Oberholzer, Location Manager P. 

### 0. Box 500 Massena, NY 13662 BUREAU OF WATER PERMITS**o;cc".'~n**



# SEP 2 0 

# 2007

RE: MODIFICATION TO SPDES PERMIT #NY0000132; DEC #6-4058-00024/00001 ALCOA-EAST. (T) MASSENA. ST. LAWRENCE COUNTY.

Dear Mr. Oberholzer:

This is to inform you that pursuant to Article 17, Title 8 of the Environmental Conservation Law and 6NYCRR Part 757, the Department has made a determination to modify the permit referenced above as indicated in the following enclosed revised permit (pages 1-28). This revised permit supersedes the previous corresponding permit. This modification will be come effe1ctive October 1 , 2007.

The permit is being modified to revise the Outfall 002 construction compliance dates; correct the WTC page relative to current usage; and to reference the correct name of the current Environmental Manager (revisions to pages 1, 15, 23, and 26).

If you have any questions, you may contact me at 315-785-2245 or Ann Rice at 315-785-2513.

## S~n,rely, i /) /_ u

# ~nM-tetU~ Lawrence R. Ambeau Regional Permit Administrator Region 6

LRA:ACR:sgs Enclosure

cc: Charles Dobbs, ALCOA, w/enc. T.-homas Lightfoot, ALCOA, w/enc. vAian Fuchs, BWP, Albany, w/enc.

Shayne Mitchell, BWP, w/enc. NYSDOH, Canton, w/enc. USEPA, Region II, w/enc. Ann Rice/SPDES File, w/enc.Industrial Code: Discharge Class (CL): Toxic Class (TX): Major Drainage Basin: Sub Drainage Basin:
Water Index Number: Compact Area: NEW YORK STATE DEPARTMENT OF ENVIRONMENTAL CONSERVATION 

### State Pollutant Discharge Elimination System (SPDES) DISCHARGE PERMIT

3334 03 

### T 09 01,03 SL, SL-1 

### Special Conditions (Part 1)

SPDES Number: DEC Number: Effective Date (EDP): Expiration Date (ExDP): Modification Dates: NY- 0000132 6-4058-00024/00001 06/01/04 06/01/09 10/01107 first3.00

This SPDES permit is issued in compliance with Title 8 of Article 17 of the Environmental Conservation Law of New York State and in compliance with the Clean Water Act, as amended, (33 U.S.C. §1251 et.seq.)(hereinafter referred to as "the Act").

PERMITTEE NAME AND ADDRESS 

### j) 0

Name: Reynolds Metals

# Compan~'+**~"** '

Street: 201 Isabella Street ' 

# l ,p & Attention: Smelting Operations Manager

City: Pittsburgh State: PA Zip Code: ·15212-5858:

is authorized to discharge from the facility described below:

FACILITY NAME AND ADDRESS

Name:
Location (C,T,V): Facility Address: City:

NYTM-E: Alcoa -East

Massena (T)

194 County Route 45

Massena

From Outfall No.: 001 at Latitude: 44 o into receiving waters known as: St. Lawrence River and; (list other Outfalls, Receiving Waters & Water Classifications)

002, 003, 005, & 008 010 

### & 011 St. Lawrence River Raquette River 59 I County:

State: NY

NYTM-N: St. Lawrence

Zip Code: 13662

10 " & Longitude: 74 o 44

,

Class A Class B Class: A 50 If

in accordance with: effluent limitations; monitoring and reporting requirements; other provisions and conditions set forth this permit; and 6 NYCRR Part 750-1.2(a) and 750-2.

DISCHARGE MONITORING REPORT (DMR) MAILING ADDRESS

Mailing Name: Alcoa, Inc.
Street: P.O. Box 150 City: Massena State: NY Zip Code: 13662 Responsible Official or Agent: Charles Dobbs, Environmental Manager Phone: 315-764-4642

This permit and the authorization to discharge shall expire on midnight of the expiration date shown above and the permittee shall
not discharge after the expiration date unless this permit has been renewed, or extended pursuant to law. To be authorized to discharge beyond the expiration date, the permittee shall apply for permit renewal not less than 180 days prior to the expiration date shown above.

DISTRJBUTION:

Bureau of Water Permits NYSDOH, Canton USEP A Region II SPDES File Permit Administrator: Lawrence R. Ambeau, Region 6

Address: 317 Washington Street Watertwon, New York 13601

### SPDES PERMIT NUMBER NY0000132 

### Part I, Page 2 of 28



## PERMIT LIMITS, LEVELS AND MONITORING DEFINITIONS

C:\MvFiles\0000132o.07m()(I.$1Y1.wnd

OUTFALL WASTEWATER TYPE RECEIVING WATER EFFECTIVE EXPIRING

This cell describes the type of wastewater authorized This cell lists classified The date this page The date this page for discharge. Examples include process or sanitary waters of the state to which starts in effect. (e.g. is no longer in
wastewater, storm water, non-contact cooling water. the listed outfall discharges. EDPorEDPM) effect. (e.g. ExDP)

!PARAMETER MINIMUM MAXIMUM UNITS SAMPLE FREQ. SAMPLE TYPE

e.g. pH, TRC, The minimum level that must be The maximum level that may not SU, °F,**~emperature,** D.O. maintained at all instants in time. be exceeded at any instant in time. mg/1, etc.

PARA- EFFLUENT LIMIT PRACTICAL QUANTITA TION ACTION UNITS SAMPLE SAMPLE [METER LIMIT(PQL) LEVEL FREQUENCY TYPE

Limit types are defined below in For the purposes of compliance Type I or This can Examples Exarnples
Note I. The effluent limit is assessment, the analytical method Type II include units include Daily, include developed based on the more specified in the permit shall be used Action Levels of flow, pH, 3/week, grab, 24 stringent oftechnology-based limits, to monitor the amount of the are mass, weekly, hour required under the Clean Water Act, pollutant in the outfall to this level, monitoring Temperature, 2/month, composite

or New York State water quality provided that the labpratory analyst requirements, concentration. monthly, and 3 grab standards. The limit has been has complied with the specified as defined Examples quarterly, 2/yr samples derived based on existing quality assurance/quality control below in Note include !J.g/1, and yearly. collected assumptions and rules. These procedures in the relevant method. 2, that trigger lbs/d, etc. over a 6 assumptions include receiving water Monitoring results that are lower additional hour hardness, pH and temperature; rates than this level must be reported, but monitoring period. of this and other discharges to the shall not be used to determine and permit receiving stream; etc. If assumptions compliance with the calculated limit. review when

or rules change the limit may, after This PQL can be neither lowered exceeded.
due process and modification of this nor raised without a modification of I permit, change. this permit.

Note 1: DAILY DISCHARGE.: The discharge of a pollutant measured during a calendar day or any 24-hour period that reasonably represents the calendar day for the purposes of sampling. For pollutants expressed in units of mass, the 'daily discharge' is calculated as the total mass of the pollutant discharged

over the day. For pollutants with limitations expressed in other units of measurement, the 'daily discharge' is calculated as the average measurement of the pollutant over the day.

DAILY MAX.: The highest allowable daily discharge. DAILY MIN.: The lowest allowable daily discharge.

MONTHLY A VG: The highest allowable average of daily discharges over a calendar month, calculated as the sum of each of the daily discharges measured during a calendar month divided by the number of daily discharges measured during that month.

7 DAY ARITHMETIC MEAN (7 day average): The highest allowable average of daily discharges over a calendar week.

30 DAY GEOMETRIC MEAN: The highest allowable geometric mean of daily discharges over a calendar month, calculated as the antilog of: the sum of the log of each of the daily discharges measured during a calendar month divided by the number of daily discharges measured during that montl}.

7 DAY GEOMETRIC MEAN: The highest allowable geometric mean of daily discharges over a calendar week.

RANGE: The minimum and maximum instantaneous measurements for the reporting period must remain between the two values shown.

Note 2: ACTION LEVELS: Routine Action Level monitoring results, if not provided for on the Discharge Monitoring Report (DMR) form, shall be appended to the DMR for the period during which the sampling was conducted. If the additional monitoring requirement is triggered as noted below, the permittee shall undertake a short-term, high-intensity monitoring program for the parameter(s). Samples identical to those required for routine monitoring purposes shall be taken on each of at least three consecutive operating and discharging days and analyzed. Results shall be expressed in terms of both concentration and mass, and shall be submitted no later than the end of the third month following the month when the additional monitoring requirement was triggered. Results may be appended to the DMR or transmitted under separate cover to the same address. Iflevels higher than the Action Levels are confirmed, the permit may be reopened by the Department for consideration of revised Action Levels or effluent limits. The permittee is not authorized to discharge any of the listed parameters at levels which may cause or contribute to a violation of water quality standards. TYPE I : The additional monitoring requirement is triggered upon receipt by the permittee of any monitoring results in excess of the stated Action LeveL TYPE II: The additional monitoring requirement is triggered upon receipt by the permittee of any monitoring**res~lts** that show the stated action level exceeded for four of six consecutive samples, or for two of six consecutive samples by 20 % or more, or for any one sample by 50 % or more.

### SPDES PERMIT NUMBER NY0000132 

### Part I, Page 3 of 28



## · PERMIT LIMITS, LEVELS AND MONITORING

C:\MvF11esl0000132o.07mod.sm.wod

OUTFALL NUMBER WASTEWATER TYPE RECEIVING WATER EFFECTIVE EXPIRING 

# II

001 Noncontact cooling water (electrical system), St. Lawrence River 06/01104 05/31109

stormwater runoff, mechanical pump gland
seal water, and outfall 01A.

ETER MINIMUM MAXIMUM UNITS SAMPLE FREQUENCY SAMPLE TYPE FOOTNOTES (FN)

pH 6.0 9.0 

## su Weekly Grab

Temperature Monitor A 90 oF Weekly Grab

EFFLUENT LIMIT PQL MONITORING
PARAMETER ACTION LEVEL SAMPLE SAMPLE FN
UNITS FREQUENCY TYPE Monthly Avg. Daily Max. Daily Max. TYPE I TYPE II

'Flow Monitor Monitor MGD Conti Recorder

Total Dissolved Solids Monitor Monitor mg/1 Weekly 24hr.comp.

Total Suspended Solids Monitor 20 mg/1 Weekly 24hr.comp.

Oil & Grease Monitor 10 

# g Once/2 weeks Grab

Foam (visible) None None Weekly Grab 1

Aluminum, Total 4.6 i 7.5 lbs/day Weekly 24hr.comp. 2

Arsenic, Total

. . 0.30 lbs/day Quarterly 24hr.comp.

Chlorine, Total Residual Monitor 1000 ug/1 Monthly Grab

Copper, Total

- 

## - 0.35 lbs/day Quarterly 24hr.comp. 3

Cyanide, Total 0.57 1.2 lbs/day Once/2 weeks 24hr.comp. 2 80 200 ug/1

Fluoride, Total 140 210 lbs/day Weekly 24hr.comp. 2 20,000 30,000 ug/1

Nickel, Total 0.38 0.56 lbs/day Monthly 24hr.comp. 

## II

Phosphorus, Total Monitor I Monitor lbs/day Quarterly 24hr.comp.

Selenium, Total



### . 0.20 lbs/day Quarterly 24hr.comp.

Tin, Total 0.25 0.43 lbs/day Quarterly 24hr.comp.

Zinc, Total Monitor 1.1 lbs/day Monthly 24hr.comp.

P AHs, Individual Monitor 10 ug/1 Once/2 weeks 24hr.comp. 4

Aroclor 1242 Monitor 0.001 300 ng/1 Weekly Grab 

# HAroclor 1248 Monitor 0.001 300 ng/1 Weekly Grab

Aroclor 1254 Monitor 0.001 300 ng/1 Weekly Grab 5

Aroclor 1260 Monitor 0.001 300 ngll Weekly Grab 5

### SPDES PERMIT NUMBER NY0000132 

### Part I, Page 4 of 28



## PERMIT LIMITS, LEVELS AND MONITORING

C:IMyFI!es\0000132p.07mod.sm.wpd

OUTFALL WASTEWATER TYPE RECEIVING EFFECTIVE EXPIRING
NUMBER WATER

OIA Potline S02 W APC bleed stream, contaminated gw from North Yard, 001 06/01/04 05/31109

stormwater runoff, water intake filter backwash, dewatering bed filtrate, direct

steam sparging, washdown waters, pitch pump house sump & steam condensate,

No. 6 fuel oil & pitch secondary containment area stormwater, misc. process wastewaters, and outfalls 0 I B & 01 C.

PARAMETER 

# T
MINIMUM MAXIMUM UNITS SAMPLE FREQUENCY SAMPLE TYPE FOOTNOTES

pH 

# I 6.0 9.0 

## su 2/Week Grab

EFFLUENT LIMIT PQL MONITORING
PARAMETER ACTION LEVEL SAMPLE SAMPLE FN UNITS FREQUENCY TYPE Monthly A vg. Daily Max. Daily Max. TYPE I TYPE II

Flow Monitor 220,000 GPD Continuous Recorder

WAPCFiow Monitor Monitor GPD Daily Totalizer

CBOD5



## - - 20 mg/1 Monthly 24hr.comp.

jTKN Monitor 20 mg/1 Monthly 24hr.comp.

Total Dissolved Solids Monitor Monitor mg/1 Once/2 weeks 24hr.cornp.

Total Suspended Solids Monitor 20 mg/1 Once/2 weeks 24hr.cornp.

Oil & Grease Monitor 10 mg/1 Mon

# G~ Foam (visible) None visible Weekly



## - 

## - Grab 6

Aluminum, Total 2.8 6.3 lbs/day Once/2 weeks 24hr.comp.

Antimony, Total 0.85 1.9 lbs/day Quarterly 24hr.comp.

Fluoride, Total 29 63 lbs/day Once/2 weeks 24hr.comp.

Benzo(a)pyrene 0.016 0.033 lbs/day Once/2 weeks 24hr.comp.

P AHs, Individual 1 Monitor 10 ug/1 Once/2 weeks 24hr.cornp. 4

Phenols, Total



# - - 50 ug/1 Monthly 24hr.comp.

Aroclor 1242 Monitor 0.001 300 ng/1 1 Weekly Grab 5

Aroclor 1248 Monitor 0.001 300 1 ng/1 Weekly Grab 5

Aroclor 1254 Monitor 0.001 300 ng/1 Weekly Grab 5

Aroclor 1260 Monitor 0.001 300 ng/1 Weekly Grab 5

Production Rate (Potroom) Monitor



## - M#/d Monthly Calculated

### SPDES PERMIT 

## NUMBER NY0000132 

### Part I, Page 5 

### of 28

C:\MyFIIes\0000132p.07rnod.sm.wpd 

## PERMIT LIMITS, LEVELS AND MONITORING

OUTFALL No. WASTEWATER TYPE RECEIVING WATER EFFECTIVE EXPIRING

018 Black Mud Pond groundwater. Outfall OIA 06/01104 05/31109

PARAMETER MINIMUM MAXIMUM UNITS SAMPLE FREQUENCY SAMPLE TYPE FOOTNOTES

pH Monitor Monitor 

## su Monthly Grab

ENFORCEABLE LIMIT MONITORING
PARAMETER ACTION LEVEL SAMPLE SAMPLE FN UNITS FREQUENCY TYPE Monthly Avg. Daily Max. TYPE I TYPE II I

Flow Monitor 13,000 GPD Continuous Recorder

TKN Monitor 20 mg/1 Monthly 4 hr.comp. II
Cyanide, Total Monitor 1100 ug/1 Once/2 weeks 4hr.comp. 

## I

I

OUTFALL No. WASTEWATER TYPE RECEIVING WATER EFFECTIVE EXPIRING

OIC Landfill groundwater. Outfall OIA 06/01/04 05/31/09

ENFORCEABLE LIMIT MONITORING
PARAMETER ACTION LEVEL SAMPLE SAMPLE FN UNITS FREQUENCY TYPE Monthly Avg. Daily Max. TYPE I TYPE II

Flow Monitor Monitor GPD Weekly Totalizer 7

TKN " 

## - 40 mg/1 Monthly Grab 7

Cyanide, Total



## - " 2200 ug!l Once/2 weeks Grab 7

### SPDES PERMIT NUMBER NY0000132 

### Part I, Page 6 of 28



## · PERMIT LIMITS, LEVELS AND MONITORING

002

PARAMETER

pH

Temperature

PARAMETER

Flow

Total Dissolved Solids

Total Suspended Solids

Oil & Grease

Foam (visible)

Aluminum, Total

Antimony, Total

Chlorine, Total Residual

Fluoride, Total

Nickel, Total

Phosphorus, Total

Zinc, Total

P AHs, Individual

Phenols, Total

Aroclor 1242

Aroclor 1248

Aroclor 1254

Aroclor 1260

Production Rate (DCC) WASTEWATER TYPE

Direct chill contact cooling water, noncontact cooling water (compressors and air conditioning), stormwater runoff, boiler blowdown, steam condensate, and water tower overflow.

MINIMUM MAXIMUM UNITS

6.0 9.0 

## su

Monitor Average 90 oF

EFFLUENT UMIT PQL

Monthly Avg. Daily Max. Daily Max.

Monitor Monitor

Monitor Monitor

Monitor 20

Monitor 1 14

None None

Monitor 6.0

0.60 1.3

Monitor 1000

18 42

0.25 0.38

Monitor Monitor

Monitor 1.0

Monitor 6.0

.

Monitor 0.001 300

Monitor 0.001 300

Monitor 0.001 300

Monitor 0.001 300

Monitor

- RECEIVING WATER EFFECTIVE EXPIRING

St. Lawrence River 06/01104 05/31/09

SAMPLE FREQUENCY SAMPLE TYPE FOOTNOTES (FN)

Weekly Grab

Weekly Grab

MONITORING
ACTION LEVEL SAMPLE SAMPLE FN
UNITS FREQUENCY TYPE TYPE I TYPE II

MGD Continuous Recorder

mg/1 Weekly Grab

lbs/day Weekly Grab 12

lbs/day Weekly Grab 12

visible Weekly Grab I

lbs/day Weekly 24hr.comp. 12

lbs/day Quarterly 24hr.comp.

ug/1 Once/2 weeks Grab

lbs/day Monthly 24hr.comp.

lbs/day Quarterly 24hr.comp.

lbs/day Quarterly 24hr.comp.

lbs/day Monthly 24hr.comp.

ug/1 I Monthly 24hr.c

50 ug/1 Monthly 24hr.comp

.
ng/1 Weekly Grab 5

ng/1 Weekly Grab 5

ng/1 Weekly Grab 5

ng/1 Weekly Grab 5

M#/d Monthly Calculated

### SPDES PERMIT NUMBER NY0000132 

### Part I, Page 7 of 28



## · PERMIT LIMITS, LEVELS AND MONITORING

C:\MvFiles\0000132o.07mcd.sm.wPd

OUTFALL NUMBER WASTEWATER TYPE RECEIVING WATER EFFECTIVE EXPIRING

003 Sewage, oil/water separator effluent (steam St. Lawrence River 06/01/04 05/31/09 cleaning wastewaters), laboratory floor

drains, east sump groundwater, and miscellaneous process wastewaters.

PARAMETER MINIMUM MAXIMUM UNITS SAMPLE FREQUENCY SAMPLE TYPE FOOTNOTES (FN)

IPH 6.0 9.0 

## su 2/Week Grab

EFFLUENT LIMIT PQL MONITORING
PARAMETER ACTION LEVEL SAMPLE SAMPLE FN UNITS FREQUENCY TYPE Monthly Avg. Daily Max. Daily Max. TYPE I TYPE II

Flow Monitor 0.22 MGD Continuous Recorder

CBOD5 25 40 mg/1 Monthly 24hr.comp.

TKN Monitor 20 mg/1 Monthly 24hr.comp.

Total Dissolved Solids 

### I Monitor Monitor

1 mg/1 Once/2 weeks 24hr.comp.

Total Suspended Solids Monitor 20 I mg/1 Once/2 weeks 24hr.comp.

Oil & Grease Monitor 10 mg/1 Monthly Grab

Foam (visible) None None visible Weekly Grab 1

Fecal Coliform 200 (30 day geometric mean) MPN/100 m1 Monthly Grab 400 ( 7 day geometric mean)

Aluminum, Total 2000 4000 ug/1 Once/2 weeks 24hr.comp.

Chlorine, Total Residual Monitor 2000 ug/1 2/week Grab

Cyanide, Total 80 200 ug/1 Once/2 weeks 24hr.comp.

Fluoride, Total 20,000 30,000 ug/1 Once/2 weeks 24hr.comp.

Phosphorus, Total Monitor Monitor ug/1 Quarterly 24hr.comp.

Zinc, Total

- 

# - 200 ug/1 Quarterly 24hr.comp.

P AHs, Individual Monitor 10 ug/1 Monthly 24hr.comp. 4

Phenols, Total



## - - 50 ug/1 Once/2 weeks 24hr.comp. 8

Aroclor 1242 Monitor 0.001 300 ng/1 Weekly Grab 5

Aroclor 1248 Monitor 0.001 300 ng/1 Weekly Grab 5

Aroclor 1254 Monitor 0.001 300 ng/l Weekly Grab 5

Aroclor 1260 Monitor 0.001 300 ng/1 Weekly Grab 5

### SPDES PERMIT NUMBER NY0000132 

### Part I, Page 8 of 28



## - PERMIT LIMITS, LEVELS AND MONITORING

OUTFALL NUMBER WASTEWATER TYPE EXPIRING

005 Stormwater runoff and vehicle rinse 05/31/09

PARAMETER MINIMUM MAXIMUM UNITS SAMPLE FREQUENCY SAMPLE TYPE FOOTNOTES (FN)

pH 6.0 9.0 

## su Weekly Grab

Settleable Solids Monitor Average 0.1 mVI

EFFLUENT LIMIT PQL MONITORING
PARAMETER ACTION LEVEL SAMPLE SAMPLE FN UNITS FREQUENCY TYPE Monthly Avg. Daily Max. Daily Max. TYPE I TYPE II

Flow Monitor Monitor GPD Weekly Instantane:ous

Total Dissolved Solids Monitor Monitor

j mg/1 Monthly Grab

Total Suspended Solids " " 40 mg/1 Monthly Grab

Oil &Grease Monitor 10 mg/1 Monthly Grab

..

- 

## - None visible Weekly Grab 6

# I~**~** 2000 4000 ug/1 Quarterly Grab

Fluoride, Total 20,000 30,000 ug/1 Quarterly Grab

P AHs, Individual Monitor 10 ug/1 Quarterly Grab 4

Aroclor 1242 Monitor 0.001 300 ng/1 Once/2 weeks Grab 5

Aroclor 1248 Monitor 0.001 300 ng/1 Once/2 weeks Grab 5

Aroclor 1254 Monitor 0.001 300 ng/1 eks Grab

# ~ Aroclor 1260 Monitor 0.001 300 ng/1 Once/2 weeks Grab

### SPDES PERMIT NUMBER NY0000132 

### Part I, Page 9 of 28



## · PERMIT LIMITS, LEVELS AND MONITORING

C:IMyFiles\0000132o.07mod.sm.wod

OUTFALL NUMBER WASTEWATER TYPE RECEIVING WATER EFFECTIVE EXPIRING

008 Stormwater runoff. St. Lawrence River 06/01/04 05/31/09

PARAMETER MINIMUM MAXIMUM UNITS SAMPLE FREQUENCY SAMPLE TYPE FOOTNOTES (FN)

pH 6.0 9.0 

## su Weekly Grab

Settleable Solids Monitor Average 0.1 mill Weekly Grab

EFFLUENT LIMIT QL MONITORING
PARAMETER ACTION LEVEL SAMPLE SAMPLE FN UNITS FREQUENCY TYPE Monthly A vg. Daily Max. Daily Max. TYPE I TYPE II

# I~ Monitor Monitor GPD Weekly Instantaneous

Grab 

# I

Total Dissolved Solids Monitor Monitor mg/1 Monthly

Total Suspended Solids



## - - 40 mg/1 Monthly Grab

Oil & Grease Monitor 10 mg/1 ly Grab

Foam (visible)



## - 

# - N visible Weekly Grab 6

Aluminum, Total 2000 4000 ug/1 Quarterly Grab

Cyanide, Total 80 200 ug/1 Once/2 weeks Grab 9

Fluoride, Total 20,000 30,000 ug/1 Once/2 weeks Grab 9

P AHs, Individual Monitor 10 ug/1 Quarterly Grab 4

Aroclor 1242 Monitor 0.001 300 ng/1 Monthly Grab 5

Aroclor 1248 Monitor 0.001 300 ng/1 Monthly Grab

# ~I Aroclor 1254 Monitor 0.001 300

. ng/1 Monthly Grab

Aroclor 1260 Monitor 0.001 300 ng/1 Monthly Grab

### SPDES PERMIT NUMBER NY0000132 Part I, Page 10 of 28



## · PERMIT LIMITS, LEVELS AND MONITORING

C:\Myfiles\0000132p,07mod.sm,wp<l 

# II OUTFALL NUMBER WASTEWATER TYPE RECEIVING WATER EFFECTIVE EXPIRING


# II 010 Stormwater runoff, vehicle rinse water, and Raquette River 06/01/04 05131109

noncontact cooling water (rectifier yard).

PARAMETER MINIMUM MAXIMUM UNITS SAMPLE FREQUENCY SAMPLE TYPE FOOTNOTES (FN)

pH 6.0 9.0 

## su Weekly Grab

Settleable Solids Monitor Average 0.1 ml/1 Weekly Grab

EFFLUENT LIMIT PQL MONITORING
PARAMETER ACTION LEVEL SAMPLE SAMPLE FN UNITS FREQUENCY TYPE Monthly Avg. Daily Max. Daily Max. TYPE I TYPE II.

Flow Monitor Monitor GPD Weekly Instantaneous

Total Dissolved Solids Monitor Monitor mg/l Monthly Grab

Total Suspended Solids



# - 40 mgll Monthly Grab

Oil & Grease Monitor 10 mgll Monthly Grab

Foam (visible)



## - None visible Weekly Grab 6

Aluminum, Total 2000 4000 ugll Monthly Grab

Cyanide, Total 80 200 ugll Once/2 weeks Grab 10

Fluoride, Total Monthly 10,000 ug/1 Quarterly Grab

PARs, Individual Monitor 10 ugll Quarterly Grab 4

Aroclor 1242 Monitor 0.001 300 ng/1 Monthly Grab 5

Aroclor 1248 Monitor 0.001 300 ng/1 Monthly Grab 5

Aroclor 1254 Monitor 0.001 300 ngll Monthly Grab 5

Aroclor 1260 Monitor 0.001 300 ng/1 Monthly Grab 5

### SPDES PERMIT NUMBER NY0000132 

## Part I, Page 11 of 28



## PERMIT LIMITS, LEVELS AND MONITORING

C:\MvFiles\0000132p.07mod.sm.wpd

OUTFALL NUMBER WASTEWATER TYPE RECEIVING WATER EFFECTIVE EXPIRIN

011 Stormwater runoff and groundwater. R;aguette River 06/01104 05/31/09

PARAMETER MINIMUM MAXIMUM UNITS SAMPLE FREQUENCY SAMPLE TYPE FOOTNOTES (FN)

pH 6.0 9.0 

## su Quarterly Grab

Settleable Solids Monitor Average 0.1 ml/1 Quarterly Grab

EFFLUENT LIMIT PQL MONITORING
PARAMETER ACTION LEVEL SAMPLE SAMPLE FN UNITS FREQUENCY TYPE Monthly Avg. Daily Max. Dai1yMax. TYPE I TYPE II

Flow Monitor Monitor GPD Quarterly Instantaneous

Total Dissolved Solids Monitor Monitor mg/1 Quarterly Grab

Total Suspended Solids



## - - 40 mg/1 Quarterly Grab

Oil & Grease Monitor 10 mg/1 Quarterly Grab

Foam (visible)

- 

## - None visible Quarterly Grab 6

Aluminum, Total 2000 4000

. ug/1 Quarterly Grab

Cyanide, Total Monitor 60 ug/1 Quarterly Grab

Fluoride, Total Monitor 10,000 ug/1 Quarterly Grab

Iron, Total Monitor Monitor ug/1 Quarterly Grab

P AHs, Individual Monitor 10 ug/1 Quarterly Grab 4

Aroclor 1242 Monitor 0.001 300 ng/1 Quarterly Grab 5

Aroclor 1248 Monitor 0.001 300 ng/1 Quarterly Grab 5

Aroclor 1254 Monitor 0.001 300 ng/1 Quarterly Grab 5

Aroclor 1260 Monitor 0.001 300 ng/1 Quarterly Grab 5

## SPDES PERMIT NUMBER NYOOOOI32 Part I, Page 12 of 28

C:\MyFiles\0000132p.07mod.sm.wpd 

## PERMIT LIMITS, LEVELS AND MONITORING

OUTFALL NUMBER RECEIVING WATER EFFECfiVE EXP1RING

Sum ofOutfalls 001, 002, 003, 005, 008, 010, and/or 01 L St. Lawrence River 06/01/04 05/31/09

ENFORCEABLE LIMIT MONITORING
PARAMETER ACTION LEVEL SAMPLE SAMPLE FN UNITS FREQUENCY TYPE Monthly Avg. Daily Max. TYPE I TYPE II

Benzo( a )anthracene 33 Monitor grams/d Monthly Calculated 11

Benzo( a )pyrene 20 Monitor grams/d Monthly Calculated 11

Benzo(b )fluoranthene 33 Monitor grarns/d Monthly Calculated 11

Benzo(k)fluoranthene 33 Monitor grams/d Monthly Calculated

"""''· 33 Monitor grams/d Monthly Calculated
IL 3-cd)pyrene 33 Monitor grams/d Monthly

# Calc~GJ

OUTFALL NUMBER RECEIVING WATER EFFECTIVE EXPIRING

Sum of Outfalls 0 10 and 011. Raquette River 06/01/04 05/31109

ENFORCEABLE LIMIT MONITORING PARAMETER ACTION LEVEL SAMPLE SAMPLE FN UNITS FREQUENCY TYPE Monthly A vg.

### Daily~ TYPE II

Benzo(a)pyrene 1.5 M' Calculated IISPECIAL CONDITIONS and DEFINITIONS: 

### SPDES PERMIT NUMBER NY0000132
Part I, Page 13 of 28

The following special conditions and definitions apply to all activities regulated by this permit

..

A. Reporting Mass and Concentration- The permittee must report both concentration (in mg/1 for conventionals; in ug/1 for metals, inorganics, and organics; in ng/1 for PCBs and specific P AHs) and mass loading (in lbs/day for all but PCBs and P AHs which shall
be in grams/day) on the DMRs for all parameters except flow, pH, temperature, settleable solids, foam, and fecal coliform.

B. Composite Samples

- All 24 hour composite samples ml!st be flow proportional. All 4 hour composite samples must be time proportional.

C. Analytical Methods- Use of the following analytical methods, or other approved analytical methods that are equally or more sensitive, is required. This is necessary in order to ensure adequate detection limits and compliance with permit limits. Less sensitive analytical methods may be utilized, and the results compared to permit limits to make compliance determinations. However, these less sensitive methods may not be substituted to satisfy routine of other permit-specified monitoring requirements.

• Cyanide, Total- EPA method 335.2, PQL 60 ug/1 or less.

• Antimony, Arsenic, Nickel, and Tin

- GFAA, PQL 10, 4, 4, and 20 ug/1 or less, respectively.

• Selenium- GFAA or FAA, PQL 8 ug/1 or less.

• Zinc- GFAA or ICP, PQL 8 ug/1 or less.

• PAHs- EPA method 610 (GCIHPLC).

• Phenols, Total- EPA method 420.2, PQL 8 ug/1 or less.

• PCB Aroclors- EPA method 608 (GCIECD). The laboratory must make all reasonable attempts to achieve a MDL of
65 ng/1 or less per Aroclor. Monitoring requirements may be modified in the future, in accordance with 6NYCRR Part 621, if the Department approves a method different from 608. See footnote 5.

• Visible Foam 1) Fill one (1) 500 mL narrow mouth bottle (glass or plastic) with effluent water to be tested. 2) Upon return to the lab, fill alOOO mL Wheaton narrow mouth glass sample bottle to the 200 mL mark with
effluent from the 500 mL bottle. 3) Place the bottle with 200 mL of sample in a constant-temperature bath for a minimum of 1 hour and a rna:runum of 2 hours at 25 ± 1 °C (77 ± 1.8°F). 4) Measure the temperature of the sample and adjust to 25 

### ± 1 °C (77 

### ± 1.8°F) if necessary. 5) Remove the sample from the constant-temperature bath. 6) Vigorously shake the sample bottle using a minimum of an 8-inch stroke and 40 shakes in less than l 0 seconds. 7) After completing 40 shakes, start a timer and allow the bottle to stand undisturbed. 8) If any foam remains after 60 seconds, the sample will be noted as containing visible foam. If no foam remains
after 60 seconds the sample will be noted as not containing visible foam.

D. Flow Monitoring:
Continuous Recorder - A flow measurement system that continuously measures and displays the instantaneous flow rate, and cumulative discharge volume, versus time on paper and/or electronically.
Totalizer A flow measurement system that contiuuously measures and displays the instantaneous flow rate and records the cumulative discharge volume on a mechanical meter.

E. Approvable is defmed as that which can be approved by the Department with only minimal revision. Minimal revision shall mean revised and resubmitted to the Department within 30 days of notification by the Department of revisions that are necessary. All approvable engineering submissions must include the seal and signature of an engineer licensed to practice in New York State.

F. Electronic Reporting Within 90 days following the end of each calendar year, the permittee shall submit, to the Regional Water Engineer, and the Bureau of Water Permits, accurate summary table(s) including each analytical result for samples collected during the previous year. The table shall include daily flow rates (if required by the permit) and the individual sample results in
both concentration and mass where appropriate. The tables shall be submitted on a personal computer diskette in a spreadsheet
format acceptable to the Department. This reporting is for informational purposes only and will not be used to determine compliance with permit requirements.SPECIAL CONDITIONS and DEFINITIONS {continued): 

### SPDES PERMIT NUMBER NY0000132 

### Part I, Page 14 of 28

G. Miscellaneous Wastewater Treatment

- The Miscellaneous Wastewater Treatment Plan, when approved, shall become an enforceable compliance requirement of this SPDES permit.

H. Stormwater Only Outfalls Monitoring Threshold- Monitoring ofoutfalls 005,008,010, and 011 is not required if the outfall's flow rate is less than 5 gpm. However, any monitoring performed at flow rates less than 5 gpm will be used to determine permit compliance and must be reported on the DMR.

F001NOTES: The following footnotes apply to certain activities as noted on the previous permit pages.

1. If foam is observed in accordance with Special Condition C then the permit limit has been exceeded.

2. Interim requirements are in effect at outfall 001 until December 31, 2005, as follows: aluminum limits of 4.6/22 #I d, cyanide limits ofO. 5 7/1.2 lbs/ day and no concentration limits; fluoride limits of140/360 lbs/ day and no concentration limits; and, tin mon:itoring with no limits.

3. Copper monitoring at outfall 001 shall be daily during the first two discharge days following algaecide application.

4. Each individual Polynuclear Aromatic Hydrocarbon (P AH) detected by EPA method 610 shall be at or below 10 ug/1 ( 6.0 ug/1

at outfall 002) in order to demonstrate compliance with this limitation. P AHs specifically identified for limitation at the outfall

are excepted from this requirement. Analytical results shall be summarized and appended to the DMR. For compliance pmposes, if one or more P AHs exceed the permitted level for a sampling event it will constitute one permit limit exceedance.

5 .a. lfPCBs are detected above the Minimum Detection Level (MDL), the permittee shall provide a written detection report attached

to the DMR. The written detection report shall contain a description of the detection and its known or probable cause; including

exact dates and if the detection has not been corrected, the anticipated time it is expected to continue; and short term steps taken

or planned to reduce

, eliminate and prevent the detection and its reoccurrence.

5.b. Non-detect at the MDL or lower is the discharge goal. As outlined in 5a, the permittee shall report all values above the MDL. If the level of any aroclor is above 65 ng/1, the permittee must evaluate the treatment system and/or the wastewater source to identify the cause of the detectable level ofPCBs in the discharge. Following three consecutive months that include analytical results above 65 ng/1, the permittee shall prepare an approvable report identifying the long term measures undertaken to reduce, eliminate and prevent the detections and proposed additional steps, if necessary and feasible (both technically and economically),

to be taken to reduce, eliminate or prevent the recurrence of such detections. This report shall be submitted to the Department within 60 days following receipt of sampling results from the third detection monitoring period.

5.c. If the Department determines that effluent monitoring results above the MDL can be reduced, eliminated or prevented by implementation of additional technically and economically feasible measures as proposed by the permittee in 5b, the permittee shall implement such additional measures.

S.d. As treatment technology improvements become available, the permittee shall, at its own initiative or the Department's**n~quest,** review the available technology and submit for Department approval, plans to improve the treatment technology and/or Best Management Practices employed to remove the maximum feasible amount of PCBs from the wastewater discharge.

5.e. This limit is a phased Total Maximum Daily Load limit, prepared in accordance with 6 NYCRR Part 702.16(b).

5.f. Modification of requirements for use of analytical procedures (Special Condition C) and requirements for use of improved

treatment technologies as such improved technologies become available (5d) will be implemented as a permit modification in accordance with 6 NYCRR Part 621.FOOTNOTES (continued): 

### SPDES PERMIT NUMBER NY0000132 

## Part I, Page 15 of 28

6. If foam is observed the action level has been exceeded and one duplicate sample must then be analyzed for MBAS. Performance of the three day monitoring program is only required if the MBAS result exceeds 400 ug/1.

7. Outfall 01 C requirements will remain in effect until ExDP. However, there is a treatability threshold. For the purposesof this permit, exceedance of the treatability threshold is defmed as either of the following events

- three consecutive sample results exceed the action level for a parameter or five of the last eight sample results exceed the action level for a parameter.

If the treatability threshold is exceeded, within 30 days following such exceedance the permittee shall connect up to 10,000 gpd of landfill wastewater to the OlB treatment system or send this volume off-site for treatment. If the quantity of wastewater requiring treatment exceeds the capacity of the 0 lB treatment system the system shall be expanded as necessary to treat the remainder of this wastewater or this excess volume must be sent off-site for treatment. If off-site treatment of this excess volume is selected, this opemtion must commence within 60 days. If on-site treatment of this excess volume is selected, the permittee has 9 months to propose, receive Department approval of, and construct a system which will achieve fmallimits.

Once treatment is started, if three consecutive sample results do not exceed the outfall 0 lB pollutant limits or five of the last eight sample results do not exceed the outfall 0 lB pollutant limits, then the water may be returned to its originally permitted flow path.

8. Interim requirements are in effect at outfall 003 until 06/01/2007, as follows: phenols monitoring with no limits.

9. Interim requirements are in effect at outfall 008 until 06/01/07, as follows: cyanide limits of 1300/2700 ug/1 avg/max, and a fluoride limit of 60,000 ug/1 daily average.

10. Interim requirements are in effect at outfall 010 until 06/01/07, as follows: cyanide limits of350/1100 ug/1 avg/max.

11. Each month, the P AH results shall be averaged for each outfall. These average outfall values must then be summed and compared

to the "sum of outfalls" limits to determine compliance. During months when an outfall does not discharge or monitoring is not performed, that outfall does not contribute anything to the sum.

12. Interim requirements are in effect at outfall 002 until 06/01/10, as follows: TSS limits of20/40 mg/1 avg/max, a oil & grease limit of 15 mg/1, and an aluminum limit of 12lbs/day.

### SPDES PERMIT NUMBER NY0000132 

### Part I, Page 16 of 28



## TOXICITY TESTING PROGRAM, TIER 1 -ACUTE TEST

The Department has dete:rrn:ined that an acute effluent toxicity monitoring program is required. The permittee shall implement the

program as follows: Effluent Toxicity Monitoring Requirements

Outfall Effluent Reason for Testing Requirement Sample Frequency Sample
No. Parameters Type (Unitsl

Sum of Toxicity The presence of substances for which ambient Quarterly Flow001, 002, (% water quality criteria do not exist. Uncertainties in weighted 003,005, Effluent) the development ofTMDLs, WLAs, WQBELs, During calendar years ending in composite 008,010, etc. The presence of substances for which [6] and 

### [1] of outfalls*
&011 WQBELs are below analytical detectability. The possibility of complex or synergistic
interactions of chemicals.



### .. A The effluent toxicity monitoring program shall begm m January of the years noted m the table above. Subsequent modif1cat10n

or renewal of this permit does not reset or revise the deadline(s)set forth in the preceding sentence unless a new deadline is set explicitly by such modification or renewal.

B. The results of each toxicity test shall be submitted no later than 60 days following the end of each test period. These reports shall be submitted to the NYS DEC Regional Water Engineer at Region 6, State Office Building, 317 Washington Street, W ate:rtown, NY 13 601-3 787; and to the Toxicity Testing Unit, Bureau of Watershed Assessment and Research, 625 Broadway, Albany, NY
12233-3502.

C. Effluent Toxicity shall mean the toxicity of the effluent in acute static renewal tests specified as Tier 1 testing in 

### Methods for Measuring the Acute Toxicity of Effluents and Receiving Waters to Freshwater and Marine Organisms, Fourth Edition, EPA/600/4-90/027F (1993) or most recent edition (herein referred to as the EPA Acute Manual). Both a vertebrate and invertebrate species shall be used for the tests. Where the outfall being tested discharges to estuarine or ocean waters, the marine organisms shall be tested. Where the outfall being tested discharges to fresh waters, freshwater organisms shall be tested. Dilution

water shall be collected according to the EPA Acute Manual. Receiving water shall be used as dilution water unless the Department approves a different source. Effluent sampling and holding shall be done as outlined in the EPA Acute Manual, and
should also be consistent with outfall-specific requirements. Any deviation from procedures in the EPA Acute Manual**r<~quires** prior written approval by the Department.

D. The· 48-hour EC 50 and 48-hour LC 50 in % Effluent for both a vertebrate and an invertebrate species shall be dete:rrn:ined and reported in accordance with the specified frequency. The 48-hour EC 50 and 48-hour LC 50 in% Effluent shall be compared to the
Instream Waste Concentration (IWC) of the effluent calculated based on the daily average effluent flow at the time of the test and
the critical flow in the St. Lawrence River of 38300 MGD.

E. Where practicable, monitoring of chemical and physical parameters limited in this permit shall be coordinated so that the re:sulting analysis is also representative of the sample used for toxicity testing.

F. Discharges which use chlorination as part of the waste treatment process for disinfection should be dechlorinated prior to toxicity testing or samples shall be taken immediately prior to the chlorination system

G. In accordance with NYSDEC guidance, the Department may require the permittee to conduct additional toxicity testing. If such additional testing is necessary, the permittee shall be notified in writing by the NYS DEC Regional Water Engineer. The written notification shall include the reason(s) why such testing is required.



## * -The flow-weighted composite shall be based on 24 hour composite samples taken from outfalls 001, 002, and 003, and, grab samples taken from outfalls 005, 008, 010, and 011.Outfall
No.

Sum of 001,002, 003,005, 008,010, & 011 

### SPDES PERMIT NUMBER NY0000132 

### Part I, Page 17 of 28



## TOXICITY TESTING PROGRAM, TIER 2 -CHRONIC TEST

Effluent Toxicity Monitoring Requirements

Effluent Reason for Testing Requirement Sample Frequency Sample
Parameters Type (Units)

Toxicity The presence of substances for which ambient As directed by the Regional Water Flow- (% water quality criteria do not exist. Uncertainties in Engineer weighted Effluent) the development ofTMDLs, WLAs, WQBELs, composite

etc. The presence of substances for which of outfalls* WQBELs are below analytical detectability.
The possibility of complex or synergistic interactions of chemicals.

A. The permittee shall implement this effluent toxicity monitoring program beginning in the first month of the first full calendar quarter, i.e. January, April, July, or October, that is within 3 months of written notification from the NYSDEC Regional Water Engineer that chronic toxicity testing is necessary. The written notification will include the reasons why the chronic toxicity testing

program is necessary and the sample frequency.

B. The results of each toxicity test shall be submitted no later than 60 days following the end of each test period. These reports shall
be submitted to the NYS DEC Regional Water Engineer at Region 6, State Office Building, 317 Washington Street, Watertown,
NY 13601-3787; and to the Toxicity Testing Unit, Bureau ofWatershedAssessment and Research, 625 Broadway, Albany, NY
12233-3502.

C. Effluent toxicity shall mean the toxicity of the effluent in chronic static renewal tests as specified in Short- Term Methods for Estimating the Chronic Toxicity of Effluents and Receiving Waters to Freshwater Organisms, Third Edition, EP A/600/4-91/002 (1994), the EPA Chronic Manual for Marine Organisms (EPA/600/4-91/003(1994), or the most recent editions (herein referred

to as the EPA Chronic Manuals). Both a vertebrate and invertebrate species shall be used for the tests. Where the outfaH being
tested discharges to estuarine or ocean waters, marine organisms shall be tested. Where the outfall being tested discharges to fresh
waters, freshwater organisms shall be tested. Each test run shall be 'bracketed' with a test of pure effluent and a test of effluent diluted sufficiently such that at least one diluted sample shows no toxic effects. Appropriate dilutions between the endpoints shall
be tested to allow calculation of the Maximum Allowable Waste Concentration. Dilution water shall be collected according to the EPA Chronic Manuals. Receiving water shall be used as dilution water unless the Department approves a different source. Effluent sampling and holding shall be done as outlined in of the EPA Chronic Manuals. Any deviation from procedures in the
EPA Chronic Manuals requires prior written approval by the Department.

D. The Maximum Allowable Waste Concentration (MA WC) in% Effluent, for both a vertebrate and an invertebrate species, shall be determined and reported. The MA WC in% Effluent shall be compared to the calculated Instream Waste Concentration (IWC) of the effluent. The IWC in % Effluent shall be determined using the daily average effluent flow at the time of sampling and a critical receiving water flow in the St. Lawrence River of 38300 MGD.

E. Where practicable, monitoring of chemical and physical parameters limited in this permit shall be coordinated so that the resulting analysis is also representative ofthe samples used for toxicity testing.

F. Discharges which use chlorination as part of the waste treatment process for disinfection should be dechlorinated prior to toxicity testing or samples shall be taken immediately prior to the chlorination system.

G. In accordance with NYSDEC guidance, the Department may require the permittee to conduct additional toxicity testing. If such additional testing is necessary, the permittee shall be notified in writing by the NYS DEC Regional Water Engineer. The written notification shall include the reason( s) why such testing is required.

*-The flow-weighted composite shall be based on 24 hour composite samples taken from outfalls 001, 002, and 003, and, grab samples taken from outfalls 005, 008, 010, and 011.

### SPDES PERMIT NUMBER NY0000132 

### Part I, Page 18 of 28



## TOXICITY REDUCTION EVALUATION COMPLIANCE SCHEDULE

(a) In accordance with Department guidance on whole effluent toxicity monitoring and control, the Department will evaluate the results of acute and/or chronic toxicity testing of discharges authorized by this permit. Based on this evaluation, the Department

may require the permittee to perform a Toxicity Reduction Evaluation (TRE). Should a TRE be required, the permittee shall be notified in writing by the NYS DEC Regional Water Engineer. The written notification shall include the reasons why the TRE is required.

(b) Within 60 days of the date of the written notification from the NYS DEC Regional Water Engineer in (a), the permittee shall submit an approvable proposal for Toxicity Reduction Evaluation to the Bureau of Watershed Assessment and Research, 625 Broadway

, Albany, NY 12233-3502. The TRE proposal shall be directed towards identifying the source of the toxicity, describing procedures to reduce the toxicity to an acceptable level, identifying monitoring parameters suitable for insuring control of the toxicity, and proposing a schedule for completing the TRE.

(c) Within 14 days of receipt of written approval of the TRE proposal from the DEC Regional Water Engineer, the permittee shall implement the approved TRE proposal in accordance with the approved schedule.

(d) The completed TRE, including data fmdings and recommendations for corrective action, permit limits, and proposed**self~** monitoring requirements shall be submitted to the Bureau ofWatershed Assessment and Research at the address noted in (b) on this page. The Department will review the TRE and may modify the permit, in accordance with applicable law & regulation, to incorporate one or more of the following: substance specific numerical limits, toxicity limits, monitoring requirements, and/or

a schedule of compliance that will ensure acceptable toxicity levels of the effluent.

### SPDES PERMIT NUMBER NY0000132 

### Part I, Page 19 of 28

C:\MyFiles\0000132p.07mod.sm.wpd 

## SPECIAL CONDITIONS- BEST MANAGEMENT PRACTICES

1. The permittee shall develop a Best Management Practices (BMP) plan to prevent, or minimize the potential for, release of significant amounts of toxic or hazardous pollutants to the waters of the State through plant site runoff; spillage and leaks; sludge

or waste disposal; and storm water discharges including, but not limited to, drainage from raw material storage. Completed BMP plans shall be submitted by March 01, 2005 to the Regional Water Engineer at the address shown on the Recording, Reporting and Additional Monitoring Requirements page. The BMP plan shall be implemented within 6 months of submission, unless a different time frame is approved by this Department.

2. Subsequent modifications to or renewal of this permit does not reset or revise the deadline set forth in (1) above, unless a new deadline is set explicitly by such permit modification or renewal.

3. The permittee shall review all facility components or systems (including material storage areas; in-plant transfer,**proc(~ss** and material handling areas; loading and unloading operations; storm water, erosion, and sediment control measures; process emergency control systems; and sludge and waste disposal areas) where toxic or hazardous pollutants are used, manufactured, stored or handled to evaluate the potential for the release of significant amounts of such pollutants to the waters of the State. In performing such an evaluation, the permittee shall consider such factors as the probability of equipment failure or improper operation; cross-contamination of storm water by process materials, settlement of facility air emissions, the effects of natural phenomena such as freezing temperatures and precipitation, fires, and the facility's )listory of spills and leaks. For hazardous pollutants, the list of reportable quantities as defined in 40 CFR, Part 117 may be used as a guide in determining siglrificant

amounts of releases. For toxic pollutants, the relative toxicity of the pollutant shall be considered in determining the significance of potential releases. ·

The review shall address all substances present at the facility that are listed as toxic pollutants under Section 307 (a )(1) of**th•~** Clean Water Act or as hazardous pollutants under Section 311 ofthe Act or that are identified as Chemicals of Concern by the Industrial Chemical Survey. Of particular concern are Aluminum, Cyanide, Fluoride, PAHs, and PCBs.

4. Whenever the potential for a significant release oftoxic or hazardous pollutants to State waters is determined to be present, the permittee shall identify BMPs that have been established to minimize such potential releases. Where BMPs are inadequate or absent, appropriate BMPs shall be established. In selecting appropriate BMPs, the permittee shall consider typical industry practices such as spill reporting procedures, risk identification and assessment, employee training, inspections and records, preventive maintenance, good housekeeping, materials compatibility and security. In addition, the permittee may consider structural measures (such as secondary containment and erosion/sediment control devices and practices) where appropriate.

5. Development of the BMP plan shall include sampling of waste stream segments for the purpose of toxic "hot spot" identification. The economic achievability of effluent limits will not be considered until plant site "hot spot" sources have been identified, contained, removed or minimized through the imposition of site specific BMPs or application of internal facility treatment technology. For the purposes of this permit condition a "hot spot" is a segment of an industrial facility; including but not limited

to soil, equipment, material storage areas, sewer lines etc.; which contributes elevated levels of problem pollutants to the

wastewater and/or storm water collection system of that facility. For the purposes of this definition, problem pollutants are substances for which treatment to meet a water quality or technology requirement may, considering the results of waste stream segment sampling, be deemed unreasonable. For the purposes of this defmition, an elevated level is a concentration or mass loading of the pollutant in question which is sufficiently higher than the concentration of that same pollutant at the compliance monitoring location so as to allow for an economically justifiable removal and/or isolation ofthe segment and/or B.A.T. treatment of wastewaters emanating from the segment.

6. The BMP plan shall be documented in narrative form and shall include any necessary plot plans, drawings or maps. Other documents already prepared for the facility such as a Safety Manual or a Spill Prevention, Control and Countermeasure (SPCC) plan may be used as part of the plan and may be incorporated by reference. USEPA guidance for development of stonn water elements of the BMP is available in the September 1992 manual "Storm Water Management for Industrial Activities," USEPA Office of Water Publication EPA 832-R-92-006 (available from NTIS, (703)487-4650, order number PB 92235969). A copy of the BMP plan shall be maintained at the facility and shall be available to authorized Department representatives upon request. As a minimum, the plan shall include the following BMP's:

a. BMP Committee e. Inspections and Records i. Securityb. Reporting ofBMP Incidents f. Preventive Maintenance

c. Risk Identification & Assessment g. Good Housekeeping

d. Employee Training h. Materials Compatibility 

### SPDES PERMIT NUMBER NY0000132
Part I, Page 20 of 28

j. Spill prevention & response

k. Erosion & sediment control



### 1. Management of runoff

7. The BMP plan shall be reviewed annually and shall be modified whenever: (a) changes at the facility materially increase the potential for significant releases of toxic or hazardous pollutants, (b) actual releases indicate the plan is inadequate or (c) a letter · from the Regional Water Engineer highlights inadequacies in the plan.



### H. Facilities with 

### Petroleum and/or Chemical Bulk Storage (PBS and CBS) Areas: Compliance must be maintained with all applicable regulations including those involving releases, registration, handling and storage (6NYCRR 595-599) and (6NYCRR 612-614). Stormwater discharges from handling and storage areas should be
eliminated where practical.

A. Spill Cleanup -All spilled or leaked substances must be removed from secondary containment systems as quickly as practical
and in all cases within 24 hours. The containment system must be thoroughly cleaned to remove any residual contamination which could cause contamination ofstormwater and the resulting discharge of pollutants to waters of the State. Following spill cleanup the affected area must be completely flushed with clean water three times and the water removed after each flushing for proper disposal in an on-site or off-site wastewater treatment plant designed to treat and perinitted to discharge such wastewater. Alternatively, the permittee may test the first batch of stormwater following the spill cleanup to determine discharge acceptability. If the water contains no pollutants it may be discharged. Otherwise it must be disposed of as noted above. See Discharge Monitoring below for the list of parameters to be sampled for.

B. Discharge Operation- Stormwater must be removed before it compromises the required containment system capacity. Each discharge may only proceed with the prior approval of the permittee staff person responsible for ensuring SPDES permit compliance. Bulk storage secondary containment drainage systems must be locked in a closed position except when the operator is in the process of draining accumulated stormwater. Transfer area secondary containment drainage systems must be locked in

a closed position during all transfers and must not be reopened unless the transfer area is clean of contaminants. Stormwater discharges from secondary containment systems should be avoided during periods of precipitation. A logbook shall be maintained
on-site noting the date, time and personnel supervising each discharge.

C. Discharge Screening

- . Prior to each discharge from a secondary containment system the stormwater must be screened for contamination·. All stormwater must be inspected for visible evidence of contamination. Additional screening methods shall be developed by the permittee as part ofthe overall BMP Plan, e.g. the use of volatile gas meters to detect the presence of gross levels
of gasoline or volatile organic compounds. If the screening indicates contamination, the permittee must collect and analyze a representative sample •• of the stormwater. If the water contains no pollutants it may be discharged. Otherwise it must either be disposed of in an on-site or off-site wastewater treatment plant designed to treat and permitted to discharge such wastewater or the Regional Water Engineer can be contacted to determine if it may be discharged without treatment.

D. Discharge Monitoring- Unless the discharge from any bulk storage containment system outlet is identified in the SPDES permit as an outfall with explicit effluent and monitoring requirements, or the water is properly transferred to a treatment system in accordance with the approved Miscellaneous Wastewater Treatment Plan or DEC authorization, the permittee shall monitor the outlet as follows: (i) Bulk Storage Secondary Containment Systems: (a) The volume of each discharge from each outlet must be monitored. A representative sample shall be collected of the first discharge • following any cleaned up spill or leak. The sample must be analyzed for pH, the substance( s) stored within the containment area and any other pollutants the permittee knows or has reason to believe are present

... (b) Every fourth discharge • from each outlet must be sampled for pH, the substance( s) stored within the containment area and any other pollutants the permittee knows or has reason to believe are presen(•. (ii) Transfer Area Secondary Containment Systems: The first discharge • following any spill or leak must be sampled for flow, pH, the substance( s) transferred in that area and any other pollutants the permittee knows or has reason to believe are present

...

E. Discharge Reporting Any results of monitoring required above must be submitted to the Department by appending lhem to the corresponding discharge monitoring report (DMR). Failure to perform the required discharge monitoring and reporting shall

### SPDES PERMIT NUMBER NY0000132 

### Part I, Page 21 of 28

constitute a violation of the tenns of the SPDES permit.

F. Prohibited Discharges- In all cases, any discharge which contains a visible sheen, foam, or odor, or may cause or contribute to a violation of water quality is prohibited. The following discharges are prohibited unless specifically authorized elsewhere in this SPDES permit: spills or leaks, tank bottoms, maintenance wastewaters, wash waters where detergents or other chemicals have been used, tank hydrotest and ballast waters, contained fire fighting runoff, frre training water contaminated by

contact with pollutants or containing foam or frre retardant additives, and, unnecessary discharges of water or wastewater into secondary containment systems. An example of a necessary discharge could be the addition of steam to prevent bulk storage containment area sump pumps from freezing during cold weather.



### *

** Discharge includes storm water discharges and snow and ice removal. If applicable, a representative sample of snow and/or ice should be collected
and allowed to melt prior to assessment.

If the stored substance is gasoline or aviation fuel then sampled for oil & grease, benzene, ethylbenzene, naphthalene, toluene and total xylenes (EPA method 602). lf the stored substance is kerosene, diesel fuel, fuel oil or lubricating oil gasoline or aviation fuel then sampled for oil & grease and polynuclear aromatic hydrocarbons (EPA method 61 0). If the substance(s) are listed in Tables 6-8 of application form NY-2C sampling is required. lfthe substance(s) are listed in NY-2C Tables 9-10 sampling for appropriate indicator parameters may be required, e.g., substituting BODS for methanol, substituting toxicity testing for demeton. Discharge volume may be calculated by measuring the depth of water within the containment

area times the wetted area converted to gallons or by other suitable methods. Form NY -2C is available on the NYSDEC web site. Contact the facility inspector for further guidance. In all cases flow and pH monitoring is required.

### SPDES PERMIT NUMBER NY0000132 Part I, Page 22 of 28

C:\Myfilesl0000132p.07mod.sm.wpd



## · DISCHARGE NOTIFICATION REQUIREMENTS

a) The permittee shall, except as set forth in (c) below, maintain the existing identification signs at all outfalls to surface waters, which have not been waived by the Department in accordance with 17 -0815-a. The sign( s) shall be conspicuous, legible and in

as close proximity to the point of discharge as is reasonably possible while ensuring the maximum visibility from the surface water and shore. The signs shall be installed in such a manner to pose minimal hazard to navigation, bathing or other water related activities. If the public has access to the water from the land in the vicinity of the outfall, an identical sign shall be posted to be visible from the direction approaching the surface water.

b) The signs shall have minimum dimensions of eighteen inches by twenty four inches (18" x 24") and shall have white letters on

a green background and contain the following information:

N.Y.S. PERMITTED DISCHARGE POINT

SPDES PERMIT No.: NY

___ _

OUTFALL No. :

__



### For information about this permitted discharge contact:

Permittee Name:-----------------------------------

Permittee Contact:-----------------------------------'--

Permittee Phone: 

### )

- ### -####

OR:

NYSDEC Division of Water Regional Office Address :

NYSDEC Division of Water Regional Phone: { 

### )

- ### -####

For each discharge required to have a sign in accordance with a), the permittee shall provide for public review at a repository accessible to the public, copies ofthe Discharge Monitoring Reports (DMRs) as required by the RECORDING, REPORTING
AND ADDITIONAL MONITORING REQIDREMENTS page of this permit. This repository shall be open to the public, at

a minimum, during normal daytime business hours. The repository may be at the business office repository of the permittee or
at an off-premises location of its choice (such location shall be the village, town, city or county clerk's office, the local library

or other location as approved by the Department). In accordance with the RECORDING, REPORTING AND ADDITIONAL MONITORING REQIDREMENTS page of your permit, each DMR shall be maintained on record for a period of three years.

c) If, upon November 1, 1997, the permittee has installed signs that include the information required by 17 -0815-a(2)( a), but do not
meet the specifications listed above, the permittee may continue to use the existing signs for a period of up to five years, after which the signs shall comply with the specifications listed above. ·

d) The permittee shall periodically inspect the outfall identification signs in order to ensure that they are maintained, are still visible and contain information that is current and factually correct.

### SPDES PERMIT NUMBER NY0000132
Part I, Page 23 of 28



## WATER TREATMENT CHEMICAL (WTC) REQIDREMENTS (9199) New or increased use of a WTC requires prior DEC review and authorization. At a minimum, the permittee must notifY the DEC in writing
of its intent to change WTC use by submitting a completed WTCFX Form for each WTC. The DEC will review that submittal and
determine if a SPDES permit modification is necessary or whether WTC review and authorization may proceed outside of the formal permit
administrative process. The majority of WTC authorizations do not require formal SPDES permit modification. WTCs which are used in closed systems and cannot be discharged or those which are discharged to municipal STP do not require DEC review. WTC use and discharge questions or requests for forms should be directed to the DEC staff person who developed your SPDES permit. If you

are not sure who that is, contact the DEC staff person who last inspected your facility.

Examples ofWTCs include, biocides, coagulants, conditioners, corrosion inhibitors, defoamers, flocculants, scale inhibitors, sequestrants, and settling aids. DEC staff may also direct you to use the WTCFX Form for review and authorization of substances other than WTCs,

e.g. process chemicals. Generic WTC Usage Requirements
l. WTC usage shall not exceed the usage rate reported by the permittee or authorized below, whichever is less.

2. The discharge shall not cause or contribute to a violation of water quality or an exceedance of AWQC.

3. The permittee must maintain a logbook of all WTC use, noting for each WTC the date, time, exact location, and amount of each dosage, and, the name of the· individual applying or measuring the chemical. The logbook must also document that adequate

process controls are in place to ensure that excessive levels ofWTCs are not used and subsequently discharged through outfalls.
The permittee shall retain the logbook data for a period of at least 

### 3 years. This period may be extended by request of the OEC.

4. The permittee shall provide an annual report, attached to the December DMR, containing the following information fpr each
outfall: the current list ofWTCs authorized for use and discharge by the DEC, for each WTC the amount in pounds used during
the year, identification of authorized WTCs the permittee no longer uses, and any other pertinent information.

IS 0 s u onze or L" t fWTC A th . d fi U dD' h sean 1sc arge

Affected Outfall(s) Dosage (lbs/day) WTC Manufacturer and Product Name WTC Function Avg Max

002 10 20 BetzDearbom Cortrol IS l 050 Oxygen scavenger

001, 002,003 150 175 BetzDearborn Flowgard POT6103 Corrosion inhibitor

001 via OIA 270 306 GE Betz Klaraid CDP450 Coagulant

002 0.8 2.0 GE Betz Optisperse ADJI 030 Anti foam

. 002 15 20 GE Betz Optisperse AP0520 Dispersant

001 via OIA 3.0 5.4 GE Betz Polyfloc APII20 Flocculant

002 10 40 BetzDearborn Stearnate NA0660 Neutralizing agent

002 20 40 BetzDearbom Stearnate NF5000 Corrosion inhibitor

001 via O!A 7800/17300 gal Calcium chloride Fluoride capture

001, OJA, 002,003,005, & 010 max 50,+ 1.2@ 003 Chlorine Disinfection

001 4.73 lbs/acre ft Copper sulfate Algaecide

001 via OlA/OIB Hydrochloric acid pH adjust. & 0 lB de-scaling

001 via OlA/OlB Sodium hydroxide pH adjustment 

### • -AuthoriZed WTCs must e1ther be bsted above or Identified m a letter sent to the pernnttee by the DEC subsequent to Issuance of this permit page. In cases where a WTC is listed above and in a letter from the DEC, the more recent document will control.

### SPDES PERMIT NUMBER NY0000132 

### Part I, Page 24 of 28

C:\MyFlles\0000132p,07mod.sm.wpd 

## MONITORING LOCATIONS

The permittee shall take samples and measurements, to comply with the monitoring requirements specified in this permit, at the location(s) specified below:

Outfall 001 the effluent from the final treatment unit.

Outfall 0 1A the effluent from the fmal carbon unit at the weir box, flow monitoring may be performed on the equalization tank effluent.

Outfall 01B- the effluent from the fmal breakpoint chlorination unit.

Outfall 01 C - the landfill leachate prior to admixture with other wastewaters.

Outfall 002

- the effluent from the fmal treatment unit

Outfall 003

- the effluent from the fmal carbon unit

Outfall 005

- at the existing pipe invert where the pipe discharges to the St. Lawrence River.

Outfall 008- at the existing flow measurement weir.

Outfall 01 0

- at the existing flow measurement weir.

Outfall 011 -at the sheetpile dam flow measurement weir.

### SPDES PERMIT NUMBER NY0000132 

### Part I, Page 25 of 28

C:\MyFiles\0000132p.07mO<l.sm.wpd 

## MONITORING LOCATIONS

The permittee shall take samples and measurements, to comply with the monitoring requirements specified in this permit, at the location(s) specified below:



### RMC

- Simplified Outfall Diagram

No Scale, 11103

008



## s

R,P,S,N 

# R---__,.

Route 37 N,S----1>1

01C**.~·-L-...._** ( \ 

### l APC System I 

### '-_

_______ j



### Ra uette River

= Treatment System 

## • = Monitoring Location 

## s

011

Wastewaters: P 

## = Process/Sewage R 

# = Remediation N 

## = Noncontact S = Storm Water S,P

010

### SPDES PERMIT NUMBER NY0000132 

### Part I, Page 26 of 28

C:\MyFiles\0000132p.07mod.sm.wpd 

## SCHEDULE OF COMPLIANCE

a) The pennittee shall comply with the following schedule.

Action
Code

23099

01299

59499

25099

25099

05699 Outfall Number(s)

east sump, 001,002, 003, & 008 Compliance Action

A short term monitoring program shall be performed to determine the presence of
the following substances:

East Sump contaminated groundwater- priority pollutant metals, total aluminum,
total cyanide, total fluoride, P AHs, total phenols, and PCB aroclors. Outfall 001 -total boron, total lead, total mercury, and total vanadium.
Outfall 002

- total mercury, total tin, and total vanadium. Outfall 003

- total boron, total mercury, total thallium, and total vanadium.
Outfall 008 -total tin.

This program shall include the collection and analysis of one 24 hour composite sample per week for three consecutive discharge weeks, except only one sample is · required for mercury, and mercury and outfall 008 samples must be grabs. Mercury analysis must be performed using EPA method 1631. Analytical detection limits shall be adequately sensitive to provide meaningful data. Results of sampling, together with daily flow measurements, must be summarized and submitted.

OlA and 003 Submit an approvable Miscellaneous Wastewater Plan which identifies miscellaneous contaminated wastewaters and identifies an acceptable procedure for handling, treatment, and discharge.

Implement plan in accordance with the Department's approval. Due Date

12/0112004

12/0112004

Upon approval

002 Submit an approvable outfall VOC trackdown and elimination report. The source 06/0112005 of the benzene and toluene reported in the 8/17/01 pennit application must be identified through waste segment sampling and other means of investigation. These
substances must either be eliminated from the discharge or the pennittee must submit a permit modification request to authorize the routine discharge of these
substances.

002 Submit an approvable engineering report detailing measures which are proposed to 06/0112007 achieve final effluent limitations.

Commence construction.

Complete activities in accordance with the Department's approval and comply with final effluent limitations. 06/01/09

06/01110



### The above compliance actions are one time requirements. The permittee shall comply with the above compliance actions to the Department's satisfaction once. When this permit is administratively renewed by NYSDEC letter entitled "SPDES NOTICE/RENEW AI.. 

### APPLICATION/PERMIT", the permittee is not required to repeat the submission. The above due dates

are independent from the effective date of the permit stated in the letter of "SPDES NOTICE/RENEW AI.. 

### APPLICATION/PERMIT."

b) The pennittee shall submit a written notice of compliance or non-compliance with each of the above schedule dates no later than
14 days following each elapsed date, unless conditions require more immediate notice as prescribed in 6 NYCRR Part 7 50-1.2( a)
and 7 50-2. All such compliance or non-compliance notification shall be sent to the locations listed under the section of this permit entitled RECORDING, REPORTING AND ADDITIONAL MONITORING REQUIREMENTS. Each notice ofnon-corr!Qliance shall include the following information:

### Original Fact Sheet (submitted for public review May 11-July 22, 2005)
Revised Fact Sheet (issued with permit on March 15, 2007)



## FACT SHEET FOR NPDES PE RMIT WA-000295-0

FACILITY NAME INTALCO ALUM INUM CORPORATION

SUMMARY

Fact Sheet Page 1 of 68 Revised at Permit Issuance 03/15/07 Intalco NPDES Permit (WA-000295-0)

### TABLE OF CONTENTS

BACKGROUND INFORMATION ................................................................................................7 DESCRIPTION OF THE FACILITY .............................................................................7 History .....................................................................................................................7 Industrial Process ...................................................................................................7 Discharge Locations ...............................................................................................7 Discharge Descriptions ..........................................................................................8 Diverting Water to the BP Cogeneration Facility .............................................11 PERMIT STATUS ...........................................................................................................11 SUMMARY OF COMPLIANCE WI TH THE PREVIOUS PERMIT ......................13 WASTEWATER CHARACTERIZATION ..................................................................15 SEPA COMPLIANCE .....................................................................................................17

PERMIT LIMITATIONS ..............................................................................................................17 DESIGN CRITERIA .......................................................................................................18 TECHNOLOGY-BASED EFFLUENT LIMITATIONS .............................................18 ELIMINATING THE TOTAL SU SPENDED SOLIDS (TSS) CONCENTRATION LIMIT FOR OUTFALL 001 ..........................................23 REDUCED MONITORING FOR ANTIMO NY, NICKEL, B(a)P, COPPER, CYANIDE, AND OIL AND GREASE ...............................................................24 SURFACE WATER QUALITY-BASED EFFLUENT LIMITATIONS ...................27 Numerical Criteria for the Protection of Aquatic Life .....................................27 Numerical Criteria for the Protection of Human Health .................................27 Narrative Criteria ................................................................................................28 Antidegradation ...................................................................................................28 Effluent Quality ....................................................................................................28 Description of the Receiving Water ....................................................................28 Surface Water Quality Criteria ..........................................................................29 Mixing Zones ........................................................................................................30 Mixing Zone Determinations For Outfalls 001 And 002 ..................................30 Diffuser Information ............................................................................................34 Chronic Mixing Zones .........................................................................................35 Acute Mixing Zones .............................................................................................35 Consideration of Surface Water Qua lity-Based Limits for Numeric Criteria ..................................................................................................................37 Whole Effluent Toxicity ......................................................................................41 Toxicity Identification/reduction (TI/RE) .........................................................42 Cherry Point Herring ..........................................................................................43 Human Health ......................................................................................................45 Sediment Quality ..................................................................................................46 Fugitive Alumina Impact Study .........................................................................47 Ground Water Quality Limitations ...................................................................48 COMPARISON OF EFFLUENT LIMITS WITH THE EXISTING PERMIT ISSUED ON SEPTEMBER 1, 1998 ...................................................................49

Fact Sheet Page 2 of 68 Revised at Permit Issuance 03/15/07 Intalco NPDES Permit (WA-000295-0)

### MONITORING REQUIREMENTS..............................................................................................50 PERFORMANCE-BASED REDU CTION OF MONITORING FREQUENCIES ...................................................................................................51 ACTION LEVELS FOR POLLUTANT S DISCHARGED FROM THE STORMWATER POND AND THE SECONDARY WASTEWATER TREATMENT SYSTEM ....................................................................................53 LANDFILL MONITORING ..........................................................................................53 STORMWATER POND MONITORING .....................................................................54 EFFLUENT LIMITS BELOW QUANTITATION ......................................................54 EFFLUENT LIMITS BELOW DETECTION ..............................................................54 LAB ACCREDITATION ................................................................................................55

OTHER PERMIT CONDITIONS .................................................................................................55 OUTFALL 002 DIVERSION ..........................................................................................55 TEMPORARY CURTAILMENT ..................................................................................56 REPORTING AND RECORDKEEPING .....................................................................56 OPERATION AND MAINTENANCE MANUAL .......................................................57 SOLID WASTE PLAN ....................................................................................................57 NON-ROUTINE AND UNANT ICIPATED DISCHARGES .......................................57 SPILL PLAN ....................................................................................................................58 TREATMENT EFFICIENCY STUDIES ......................................................................58 Primary Wastewater Treatment Sy stem (PWTS) And Secondary Wastewater Treatment System (SWTS) ............................................................58 Anode Cooling Water ..........................................................................................58 OUTFALL EVALUATION ............................................................................................58 BEST MANAGEMENT PRACTICES A ND STORMWATER POLLUTION PREVENTION PLAN .........................................................................................59 GENERAL CONDITIONS .............................................................................................59

PERMIT ISSUANCE PROCEDURES .........................................................................................59 PERMIT MODIFICATIONS .........................................................................................59 RECOMMENDATION FOR PERMIT ISSUANCE ...................................................60

REFERENCES FOR TEXT AND APPENDICES........................................................................61

APPENDIX A--PUBLIC INVOLVEMENT INFORMATION....................................................62

APPENDIX B--GLOSSARY ........................................................................................................63

APPENDIX C--TECHNICAL CALCULATIONS .......................................................................67

APPENDIX D--RESPONSE TO COMMENTS

APPENDIX E—MAP OF DISCHARGE LOCATIONS

APPENDIX F—SUMMARY OF NONCOMPLIANCE

APPENDIX G—DISCHARGE MONITORING SUMMARY

Fact Sheet Page 3 of 68 Revised at Permit Issuance 03/15/07 Intalco NPDES Permit (WA-000295-0)

### APPENDIX H—WASTEWATER CHARACTERIZATION

APPENDIX I—COPPER MONITORING RESULTS

APPENDIX J—MIXING ZONE ANALYSES

APPENDIX K—TEMPERATURE ANALYSIS

APPENDIX L—REASONABLE POTENTIAL TO EXCEED (AQUATIC LIFE CRITERIA AND HUMAN HEALTH) ANALYSES FOR OUTFALL 001

APPENDIX L—REASONABLE POTENTIAL TO EXCEED (AQUATIC LIFE CRITERIA AND HUMAN HEALTH) ANALYSES FOR OUTFALL 002

APPENDIX M—ACUTE AND CHRONIC WET TEST RESULTS FOR OUTFALLS 001 &002

APPENDIX N—LANDFILL MONITORING RESULTS

APPENDIX O—PERFORMANCE BASED REDUCTION OF MONITORING FREQUENCIES

Fact Sheet Page 4 of 68 Revised at Permit Issuance 03/15/07 Intalco NPDES Permit (WA-000295-0)

### INTRODUCTION

The Federal Clean Water Act (FCWA, 1972, and later modifications, 1977, 1981, and 1987) established water quality goals for the navigable (surface) waters of the United States. One of the mechanisms for achieving the goals of th e Clean Water Act is the National Pollutant Discharge Elimination System of permits (NPDES permits), which is administered by the Environmental Protection Agency (EPA). The EP A has authorized the State of Washington to administer the NPDES permit program. Chapter 90.48 RCW defines the Department of Ecology's (Ecology) authority and obligations in administering th e wastewater discharge permit
program.
The regulations adopted by the St ate include procedures for is suing permits (Chapter 173-220 WAC), water quality criteria for surface and ground waters (Chapters 173-201A and 200 WAC), and sediment management standards (Chapter 17 3-204 WAC). These regulations require that a permit be issued before discharge of wastewat er to waters of the state is allowed. The regulations also establish the basi s for effluent limitations and ot her requirements which are to be included in the permit. One of the require ments (WAC 173-220-060) for issuing a permit under the NPDES permit program is the preparation of a draft permit and an accompanying fact sheet. Public notice of the availability of the draft perm it is required at least thirty days before the permit is issued (WAC 173-220-050). The fact sheet and draft permit are available for review (see Appendix A--Public Involvement of the fact sheet for more detail on the Public Notice procedures). Appendices B and C include a glossary of the terms used in this fact sheet and a reference to access the spreadshee t tools commonly used by Ecology.

The fact sheet and draft permit were reviewed by the Permittee. Errors and omissions identified in that review were corrected before going to public notice. After th e public comment period closed, Ecology summarized the substantive comments and the responses to each comment. The summary and response to comments is included in Appendix D of this fact sheet. Parties who submitted comments will receive a copy of Ecology's responses. The fact sheet was revised after the public comment period (which ended on July 22, 2005) to correct errors, to expand on explanations for conditions in the permit, and to explain changes that were made to the permit in response to public comment and other policy updates.

Fact Sheet Page 5 of 68 Revised at Permit Issuance 03/15/07 Intalco NPDES Permit (WA-000295-0)

### GENERAL INFORMATION Applicant Intalco Aluminum Corporation Facility Name and Address In talco Aluminum Corporation
4050 Mountain View Road
P.O. Box 937 Ferndale, Washington 98248 Type of Facility: Primary Aluminum Smelting
SIC Code 3334 Discharge Locations
Outfall 001
Outfall 002
Outfall 003
Outfall 004
Outfall 005
Outfall 011
Outfall 012 Strait of Georgia Latitude: 48° 50' 26.8" N Longitude: 122° 43' 13.6" W
Latitude: 48o 50’ 22” N Longitude: 122o 42’ 56.1” W
Latitude: 48o 50’ 49” N Longitude: 122o 42’ 56.1” W
Latitude: 48o 50’ 13” N Longitude: 122o 42’ 52” W
Latitude: 48o 50’ 31” N Longitude: 122o 42’ 49” W
Latitude: 48o 50’ 33” N Longitude: 122o 42’ 53” W
Latitude: 48o 50’ 25” N Longitude: 122o 42’ 53” W Water Body ID Number WA-01-0030 Receiving Water Strait of Georgia

Fact Sheet Page 6 of 68 Revised at Permit Issuance 03/15/07 Intalco NPDES Permit (WA-000295-0)

### BACKGROUND INFORMATION

DESCRIPTION OF THE FACILITY

H ISTORY


### The Intalco Aluminum Corporation (Intalco) began the operations of a primary aluminum smelter near Ferndale, Washington in 1966. At full production the facility employs approximately 800 people. The smelter is curr ently operating at approx imately 40% capacity with a workforce of 400 people.

I NDUSTRIAL 

### P ROCESS


### The Ferndale facility produces primary aluminum metal by the Hall-Heroult reduction process. The facility operates three pot lines, which contain a total of 720 side worked, pre-bake anode reduction cells. The smelter, in the past, ha s been capable of producing approximately 307,000 tons of aluminum metal per year at full produ ction. All metal produced is cast on-site into various sizes and forms: sows, t ees, slabs, billets, and ingots.

Potline A was shutdown in June of 2001. Intalco has been operating Potlines B and C at a reduced production level since the n. Intalco signed a 5-year pow er contract with Bonneville Power Association on August 01, 2006. Intalco proposes to operate two fully operational potlines (a total of 480 pots operating in Potlines A and C) by mid-2007. They propose to do this by migrating pots from Potline B to Potline C and starting up Potline A.

D ISCHARGE 

### L OCATIONS


### The facility is located near Ch erry Point along the Strait of Georgia. The process wastewater outfall line (001) is suspende d from the shipping pier and ex tends approximately 1100 feet from the edge of the shoreline. The stormwater outfall line (0 02) is approxima tely 800 feet south of the process outfall li ne and extends approximately 250 feet from the shoreline in a westerly direction. The approximate lo cations of Outfalls 001, 002, 003, 004, 005, 011, and 012 are as follows. The locations of these disc harges are also shown on the map in Appendix E

.



### Outfall Latitude Lon g itude

001 48o 50’ 2 6.8” N 122o 43 ’ 13.6” W

002 48o 50’ 22” N 122o 42’ 56.1” W

003 48o 50’ 49” N 122o 42’ 56.1” W

004 48o 50’ 13” N 122o 42’ 52” W

005 48o 50’ 31” N 122o 42’ 49” W

011 48o 50’ 33” N 122o 42’ 53” W

012 48o 50’ 25” N 122o 42’ 53” W

Fact Sheet Page 7 of 68 Revised at Permit Issuance 03/15/07 Intalco NPDES Permit (WA-000295-0)

### D ISCHARGE 

### D ESCRIPTIONS



### Intalco maintains a total of seven outfalls (001, 002, 003, 004, 005, 011, and 012). The discharge from each of the outfalls is described below.

Outfall 001 :
Non-contact cooling water from Intalco’s air compre ssors is the larges t component of the discharge at Outfall 001. Treated wastewaters from Intalco’s primary a nd secondary wastewater treatment systems, sanitary lagoon, anode contact cooling water from the carbon plant, and water heater/steam cleaner systems are commingled with the non-contact cooling water before discharge at Outfall 001. Major pollutants includ e total suspended solids (TSS), fluoride, and aluminum. Other possible pollu tants include cyanide, benzo(a) pyrene, and oil and grease.

The effluent to Outfall 001 is conveyed through a 24-inch diameter fiberglass reinforced plastic pipe and discharged through a 24-inch diameter , 120-foot long diffuser. The discharge is continuous and in the past has averaged 3.0 m illion gallons per day (MGD), with a maximum of 5.0 MGD. The Permittee is supplied with treated (coagulated) water from the Nooksack River by the Whatcom Public Utility Dist rict #1 (PUD). The plant’s air compressors are water-cooled by the PUD water. That cooling water const itutes approximately 80- 90% of the volume of discharge at Outfall 001.

Intalco’s Primary Wastewater Treatment System (P WTS) treats wastewater from the potline’s air pollution control system (wet scrubb ers). The PWTS consists of two clarifiers (the older clarifier is only used when the other clar ifier is shut down for maintenance). The clarifier provides treatment in the form of precipitation and sedi mentation to remove so lids and to reduce the turbidity in the wet scrubber wastewater. Coolin g water from the cast h ouse is used as makeup water in the PWTS. A small st ream of blowdown from the boil er used to heat the caustic storage tank (part of the Secondary Wastewater Treatment System described below) is also treated in the PWTS. Most of the treated effluent from the clarifier is recy cled back into the wet scrubbers. The remainder of the effluent is routed to the Secondary Wastewater Treatment System (SWTS) for removal of dissolved fluoride.

The SWTP is comprised of an equalization ta nk (ET) and two treatment trains running in parallel. Each treatment train consists of a reaction tank and a flocculation tank. Additional tanks supporting the treatment process are those used for storage of the treatment chemicals (calcium chloride, sulfuric aci d, and coagulant). Wastewater routed from the PWTS to the SWTS for fluoride treatment is pumped into the ET where it is combined with leachate from the on-site landfill leachate collection system. Pollutants in the PWTS effluent include high concentrations of particulate and fluoride. The landfill leachate contains high concentrations of fluoride and occasional high concentrations of cyanide. Wastewater in the equalization tank is pumped to the treatment train in the SWTS . Chemical treatment is followed by further treatment of the effluent in the form of sediment ation of solids in the clarifier. Some of the solids that settle out in the clar ifier are recycled back into the clarifier. The remainder of the solids (sludge) are dewatered in a rotary vacuum drum filter. The dewatered sludge is disposed of in the Permittee’s on-site RCRA landfill.

Fact Sheet Page 8 of 68 Revised at Permit Issuance 03/15/07 Intalco NPDES Permit (WA-000295-0)

### Intalco’s domestic wastewater is discharged to the plant’s aerate d sanitary lagoon. Effluent from the lagoon is treated by ultr aviolet (UV) disinfection before being discharged into a pipeline to Outfall 001. Total discharge volume is continuo us and in the past has averaged 0.035 MGD. The flow rate is expected to go down with the reduction in workforce to less than 400 employees. The permit allows for a reduction in removal efficiency when the average number of employees in a month is below 400. The permitted pollutants in the discharge are biochemical oxygen demand (BOD), total suspended so lids (TSS), and fecal coliforms.

Anode contact cooling water is generated during the anode production process. Intalco’s anodes are made from petroleum coke and coal tar pitc h. The coke and pitch are mixed together and then shaped into an anode with a mechanical press under high temperature and pressure. To facilitate maintaining the shape of the anode, th e anodes are cooled with a strong spray of cold water after removal from the press. During the spraying process, the contact water is contaminated with coke and pitch containi ng Polycyclic Aromatic Hydrocarbons (PAHs) [including benzo(a)pyrene (B(a)P)] . This wastewater is filtere d through a screen (to remove solids with adsorbed PAHs). The filtered wastewater is then discharged to the process sewer system without any additional treatment before it is discharged at Outfall 001. The permit requires the Permittee to conduct a treatment effici ency study of the anode contact cooling water filtration system to determine if it meets a ll known available and reasonable methods of treatment (AKART) standards. The treatment effici ency study is discussed in more detail later on in this document.

Intalco operates a steam-cleaning station in each of three maintenance shops (Automotive, Central, and Annex). These statio ns are used to clean various pi eces of plant equipment prior to maintenance activities. The wastewater from th ese stations is treated with sand filtration to remove suspended solids and with a coalescing fi lter to remove oil and grease. The filtered wastewater is then discharged to the proce ss sewer system without any additional treatment before it is discharg ed at Outfall 001.

Outfall 002 :

Due to the nature of the aluminum smelting proce ss, there is potential fo r stormwater to contact raw materials, byproduct, or waste materials that could contaminate the stormwater. To mitigate the discharge of any suspended solid material, all stormwater collected from the industrial portion of the plant site is rout ed through a stormwater settling pond in the s outhwest corner of the plant. The stormwater pond provides approximately 1.7 million gallons of capacity. The pond (built in 1992) is a flow-through system de signed to allow solids to settle from the stormwater. The stormwater pond is designed to treat maximum st ormwater flow rates up to 30 cubic feet per second (cfs). The pond was conservatively sized (1.9 million gallons) based on the 6-month, 24-hour design storm volume of 1.5 mi llion gallons. The hydraulic capacity of the stormwater system (including diversion struct ures) was designed for a 100-year, 24-hour (4.0 inches of rain) storm. All flow in excess of 28 cfs is diverted around th e pond via a series of three overflow structures.

Stormwater from outside the industrially developed plant site flows through tw o separate ditches. The two separate ditches combine with the stormwater pond effluent at the Outfall 002 monitoring and compliance point (D- 10). At this point, the water is further treated to remove oil

Fact Sheet Page 9 of 68 Revised at Permit Issuance 03/15/07 Intalco NPDES Permit (WA-000295-0)

### and other floating materials with a continuously operated mechanical oil skimmer. Absorbent materials (e.g. socks) are located immediately prio r to the location where the effluent enters the discharge pipe.

The discharge to Outfall 002 is conveyed through a 30-inch diameter fibergla ss reinforced plastic pipe and has no diffuser. This discharge, in the past, has been continuous and has averaged 0.6 MGD, with a typical range of 0.1 to 2.4 MGD for a monthly average. During storm events the flow may reach levels as high as 12.5 MGD. Th e primary sources of water for this discharge include stormwater runoff from th e 320 acres in-plant area and also the off-plant area of Intalco. Major pollutants discharged from Outfall 002 in clude total suspended solids, fluoride, and aluminum.

Periods of zero discharge occur at Outfall 002 during dry summer weather.

Outfalls 003, 004, and 005 :

Outfall 003 discharges stormwater runoff and leach ate from industrial solid waste in a historic landfill known as the Beach I Landfill. This la ndfill was operated from 1966 to 1978 by Intalco and is located northwest of the main plant site along a bluff overlooking the Strait of Georgia.

Outfall 004 discharges stormwater runoff and leach ate from industrial solid waste in a historic landfill known as Beach II Landfill. This landf ill was operated from 1971 to 1984 by Intalco and is located southwest of the main plant site al ong a bluff overlooking the Strait of Georgia.

Outfall 005 discharges stormwater runoff and leach ate from industrial solid waste in a historic landfill known as the Construction Debris Landf ill. This landfill was operated from 1966 to 1973 by Intalco and is located due west of the ma in plant site along a bluff overlooking the Strait of Georgia.

The control and elimination of these discharges is discussed in more detail in the Landfill Monitoring section later on in this document.

Outfalls 011 and 012 :

The silo storage area at the entrance to the pier contains three 100-foot diameter alumina storage silos. The drainage area of the alumina silo storage area is about 550 f eet by 200 feet (2.5 acres) and is divided into two watersheds.

The northern portion of the silo storage area drains to a single catch basin and discharges to Outfall 011. This outfall is embedded deep in th e riprap shoreline along the northern edge of the silo storage area. Drainage fr om the stormwater collection ditch on the north side of the road enters a catch basin at the south east corner of the truck escape ramp and is also discharged at Outfall 011. Additional drainage fr om the terraces on the hillside east of the road is conveyed through a series of catch basins and drains to the same catch ba sin at southeast corner of the truck escape ramp and is discharged at Outfall 011. Major pollutants incl ude TSS, fluoride, and aluminum. Intalco is required to reduce the TSS concentration in the discharge at Outfall 011 by implementing the BMPs in Condition S14.A. of the permit.

Fact Sheet Page 10 of 68 Revised at Permit Issuance 03/15/07 Intalco NPDES Permit (WA-000295-0)

### The middle and southern portion of the silo storag e area drain to three catc h basins arranged in a north-south alignment and connected in series in a single pipe. These three southern most catch basins discharge to Outfall 012. This outfall is embedded deep in the ri prap shoreline along the southern edge of the silo storage area. Outfall 0 12 is located in an area that is difficult to access due to vegetation and is only acce ssible on foot. Major pollutants include total suspended solids (TSS), fecal coliform, fluoride, and aluminum. The results of an analysis of the Outfall 012 discharge showed that the TSS concentra tion was higher than th e Ecology stormwater benchmark and the fecal coliform results were equal to the commonly used monthly average fecal coliform permit limit. On May 12, 2004 Ecology inspected Outfall 012 and noticed that there was a lot of animal waste in the vicinity of the outfall. Th e drainage area to Outfall 012 is localized and there are no sources of human waste in this area. Therefore, Ecology believes that animal waste, not human waste, contributed to th e high fecal coliform levels observed at Outfall 012. Intalco is required to reduce the TSS c oncentration in the disc harge at Outfall 012 by implementing the BMPs in Condition S14.A. of the permit.

The Permittee will be required to collect monthly grab samples from the catch basin sumps for Outfalls 011 and 012 when flow is available. The samples will be analyzed for TSS, aluminum, and fluoride. After one year of testing at Outfalls 011 and 012, the Permittee will have the option to petition Ecology in writing to reduce or eliminate this monitoring.

D IVERTING 

### W ATER TO THE 

### BP C OGENERATION 

### F ACILITY



### Whatcom County Public Utility Di strict No. 1 (PUD) owns the water rights for water in the Ferndale area and Intalco and the BP Cherry Poin t refinery contract for water through the PUD. The PUD withdraws water from the Nooksack Ri ver. Intalco has recently completed an agreement with the PUD and BP for a water reus e project. Under the agreement, Intalco will provide the water needed to operate the proposed BP cogeneration facility. Intalco will divert up to 4.5 MGD of non-contact, once-through cooli ng water normally discharged through Outfall 001, to the cogeneration facili ty for use in their evapor ative cooling system.

Implementation of this system is expected a bout six months prior to the start-up of the cogeneration facility. This proj ect will allow for the reuse of i ndustrial wastewater rather than consuming new water resources from the Nooksack River.

PERMIT STATUS

The previous permit for this facility was issu ed on September 1, 1998 and modified on June 1, 2000 and January 4, 2002. The effluent limitations for Outfall 001, Outfall 002, and the Sanitary Lagoon were as shown in the following tables:

Fact Sheet Page 11 of 68 Revised at Permit Issuance 03/15/07 Intalco NPDES Permit (WA-000295-0)

### Effluent Limitations: Outfall # 001

Parameter Units Monthly Average Daily Maximum

Total Suspended Solids lbs/day

mg/l 150

10 185

--

Fluoride lbs/day 68 296

Aluminum lbs/day 10.3 30

Free Cyanide mg/l <0.012 0.012

Benzo(a)Pyrene mg/l <0.01 0.01

Oil and Grease mg/l 5 10

pH Within the range of 6.0 - 9.0

Effluent Limitations: Outfall # 002

Units Monthly Average Daily Maximum Parameter

Total Suspended Solids mg/l 35 75

Fluoride mg/l 35 50

Aluminum mg/l 10 15

Benzo(a)Pyrene mg/l -- <0.01

Oil and Grease mg/l 5 10

pH Within the range of 6.0 - 9.0

Fact Sheet Page 12 of 68 Revised at Permit Issuance 03/15/07 Intalco NPDES Permit (WA-000295-0)

### Effluent Limitations: Sa nitary Lagoon Discharge

Parameter Units 30-Day Average 7-Day Average

Biochemical Oxygen Demand mg/l lbs/day 45.0
22.4 65.0
32.4

Total Suspended Solids mg/l lbs/day 45.0
22.4 65.0
32.4
Fecal Coliform Colonies/100 ml 200 400

Chlorine mg/l Minimum - 0.1 Maximum - 1.5

pH Within the range of 6.0 - 9.0

An application for permit renewal was submitted to Ecology on March 5, 2003 and accepted by on June 24, 2003. Additional 2F forms for Outfalls 003, 004, and 005 were submitted to and accepted by Ecology.

SUMMARY OF COMPLIANCE WITH THE PREVIOUS PERMIT

The facility last received an unannounced Class II inspection on May 23-24, 2006. The facility was found to be in compliance with the permit lim its at the time of the inspection. The last nonsampling inspection was completed on May 03, 2006.

In general, the Permittee has remained in compliance with effluent limits and other permit requirements during the previous permit term, based on monthly Discharge Monitoring Reports (DMRs) and inspections conducted by Ecology. Appendix F summarizes the incidents of noncompliance.

The previous permit required a number of special studies to be completed during the term of the permit. Studies of the effluent included annual priority pollutant te sting, acute and chronic toxicity testing, a stormwater characterization study, and stormwater sampling. Other studies or requirements included an outfall evaluation, pr eparation of stormwat er pollution prevention plans, a sediment study, an engineering study for chlorination, preparation of a stormwater pond operational plan and engineering report, develo pment of a potline ditch cleaning schedule, an aluminum and fluoride source study, and a potroom roof run-off study. All of the studies were completed as required by the NPDES permit and ar e discussed in the next section and later in this document.

REVIEW OF PREVIOUS PERMIT REQUIREMENTS

1. Primary Wastewater Treatment System Operational Plan :

Intalco is required to oper ate process wastewater treatment systems according to procedures and criteria described in an ope rating plan. Condition S.7 of the previous

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### permit requires Intalco to update and maintain operational plans on site for the process wastewater treatment systems. Intalco ha s not updated the operational plan for the primary treatment system. Condition S10.A of the permit requires In talco to update their O&M Manual to include the PWTS.

2. Secondary Wastewater Treatme nt System Operational Plan :

Intalco submitted a copy of the updated operational plan for the secondary treatment system in March 2004. The operational plan for the SWTS fulfills the requirements of the previous permit.

3. Sanitary Wastewater Treatment System Operational Plan :

Intalco submitted a copy of the “Sanitary Water Treatment Facility Operations and Maintenance Manual” in March 2004. This manual fulfills the requirements of previous permit.

4. Stormwater Pond Operational Plan :

Condition S7. of the previous permit required Intalco to develop and maintain a Stormwater Pond Operational Plan. In order to meet the requirements for the operational plan, Intalco conducted site hydrologic and rainfall characterizations and developed a stormwater model. Intalco was also requi red to submit an as-built engineering report which included design criteria for TSS rem oval efficiencies at the stormwater pond. Intalco submitted the operating plan and the as -built engineering report as sections of the Stormwater Runoff Study Final Report date d July 27, 2001 (final report). Ecology reviewed the final report and determined that Intalco had fulfilled the requirements of the previous permit. The stormwater pond’s influe nt flow design criteria (in Condition S4. of the permit) is taken from Intalco’s report titled “Proposed Stormwater Pond Outfall Changes” (dated October 14, 2003). Intalc o made recommendations regarding the maintenance of the stormwater pond in the fi nal report that have been included as requirements in Condition S14.A. of the permit.

5. Stormwater Pollution Prevention Plan :

Condition S.9. of the previous permit require d Intalco to submit a Stormwater Pollution Prevention Plan (SWPPP). Intalco was requi red to implement the operational and source control BMPs outlined in the SWPPP, submit a schedule for cleaning alumina and other debris from the potline ditche s, and conduct a study to dete rmine the contributions of aluminum and fluoride to the stormwater sy stem from runoff from the roofs of the potroom buildings.

Intalco submitted the SWPPP on August 27, 1999, additional information for the SWPPP in January 2000, the schedule for cleaning the potline ditches in January of 2000, and the final potroom roof runoff study results in July of 2001. Intalco leased a new more effective sweeper and began implementing the potline ditch cleaning schedule in

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### September 2000. Based on a review of these documents, Ecology determined that Intalco has fulfilled the requirements of the previous permit. Intalco recommended BMPs and other action items in the SWPPP and also in the Stormwater Runoff Study Final Report. Condition S14.A. of the permit requires Intalco to implement the BMPs and other action items and to update the SWPPP.

6. Stormwater Characterization Study : Condition S11. of the previous permit require d Intalco to submit a stormwater sampling and analysis plan to Ecology for review and a pproval within the first year of the permit. The purpose of the Plan was to characte rize the stormwater pond performance to determine the stormwater pond’s pollutant co ntribution to Outfall 002 versus off-site contributions. Intalco submitted a final stormwater sampling and analysis plan in March 2000. Intalco conducted the stormwater char acterization study from April 2000 through March 2001. The results of the study are compiled in a document entitled “Stormwater Runoff Study Final Report” dated July 27, 2001. Ecology reviewed the results of the study and determined that the submittal met the requirements of the previous permit. The final report included BMPs that Intalco recommended. Ecology requires Intalco to implement and follow these BMPs in Condition S14.A. of the permit.

WASTEWATER CHARACTERIZATION

The proposed wastewater discharges were char acterized by Intalco in the permit application process for conventional pollutants, metals , cyanide, volatile organic compounds, acid compounds, base neutral compounds, and pesticides . Long term average values reported below for Outfalls 001 and 002 and the sanitary lagoon effluent are based on extensive (daily to weekly) monitoring completed during the term of the permit. The table below also includes long term averages for pollutants with significant concentrations and/or of interest; the metals and organics listed include all of those that were quantified at greater than detection limits. These long term averages were calcula ted from six years of annual pr iority pollutant testing (1999- 2004). Additional information is included in Appendices G and H.

Fact Sheet Page 15 of 68 Revised at Permit Issuance 03/15/07 Intalco NPDES Permit (WA-000295-0)

### Wastewater Characterization (Long Term Average Value)

Parameter Concentration Mass

OUTFALL 001

TSS 4.20 mg/L 106 lbs/day

Fluoride 0.883 mg/L 23.4 lbs/day

Aluminum 0.57 mg/L 15.82 lbs/day
Free Cyanide <0.005 mg/L 0.0025 lbs/day
B(a)P <0.0001 mg/L 0 lbs/day

Oil & Grease 0.40 mg/L 10.4 lbs/day
Temperature 13.12°C
pH 6.3-8.3

Ammonia 0.105 mg/L

Chlorine 0.025 mg/L

Nitrate-Nitrite 0.644 mg/L

Nickel 0.008 mg/L

Zinc 0.012 mg/L

Phenols 0.068 mg/L
Total Organic Carbon 1.9 mg/L

OUTFALL 002

TSS 7.72 mg/L 52.6 lbs/day

Fluoride 16.1 mg/L 68.5 lbs/day

Aluminum 0.57 mg/L 17.96 lbs/day
Free Cyanide <0.005 mg/L -- B(a)P <0.0001 mg/L --
Oil & Grease 0.47 mg/L 2.41 lbs/day
Temperature 13.12°C
pH 6.3-8.2

Ammonia 0.077 mg/L

Nitrate-Nitrite 0.088 mg/L

Arsenic 0.0004 mg/L

Chromium 0.0006 mg/L

Fact Sheet Page 16 of 68 Revised at Permit Issuance 03/15/07 Intalco NPDES Permit (WA-000295-0)

### Wastewater Characterization (Long Term Average Value) – Continued

Parameter Concentration Mass

OUTFALL 002 (continued)

Nickel 0.015 mg/L

Zinc 0.045 mg/L

SANITARY LAGOON EFFLUENT

BOD 13.35 mg/L 4.34 lbs/day

TSS 9.55 mg/L 3.08 lbs/day

Fecal Coliform 1.7 cfu/100mL
pH 6.3-8.2

SEPA COMPLIANCE

This permit renewal has no SEPA compliance issues.

PERMIT LIMITATIONS

Federal and State regulations requ ire that effluent limitations set forth in a NPDES permit must be either technology- or wate r quality-based. Technology-based limitations are based upon the treatment methods available to treat specific pollutants. Tec hnology-based limitations are set by regulation or developed on a case-by-case basis (40 CFR 125 .3, and Chapter 173-220 WAC). Water quality-based limitations are based upon compliance with the Surface Water Quality Standards (Chapter 173-201A WAC), Ground Water Standards (Chapter 173-200 WAC), Sediment Quality Standards (Chapter 173-204 WA C) or the National Toxics Rule (Federal Register, Volume 57, No. 246, Tuesday, December 22, 1992). The more stringent of these two limits must be chosen for each of the parameters of concern. Each of th ese types of limits is described in more detail below.

The limits in this permit are based in part on information received in the application. The effluent constituents in the application were ev aluated on a technology- and water quality-basis. The limits necessary to meet the rules and re gulations of the State of Washington were determined and included in this permit. Ec ology does not develop effluent limits for all pollutants that may be reported on the a pplication as presen t in the effluent

. Some pollutants are not treatable at the conc entrations reported, are not controllab le at the source, are not listed in regulation, or do not have a reasonable poten tial to cause a wate r quality violation

. Effluent limits are not always developed for pollutants that may be in the discharge are not reported as present in the applicatio n. In those circumstances the permit does not authorize discharge of the non-reported pollutants. Effluent discharge cond itions may change from the conditions reported in the permit application. If si gnificant changes occur in any cons tituent, as described in 40 CFR 122.42(a), the Permittee is required to notify Ecol ogy. The Permittee may be in violation of the permit until the permit is modified to reflect additional discharge of pollutants.

Fact Sheet Page 17 of 68 Revised at Permit Issuance 03/15/07 Intalco NPDES Permit (WA-000295-0)

### DESIGN CRITERIA

Intalco conducted a study to de termine current capacities and tr eatment efficiencies of their wastewater treatment systems. Intalco subm itted the results of that study to Ecology in a document titled “Primary Water Treatment Plan t, Secondary Water Treatment Plant, and Sanitary Water Treatment Facility Capacities and Efficiencies” dated June 2004. These reports provide preliminary information. The permit will require treatment efficiency studies, when warranted, to determine the criteria necessary to monitor the efficiency of these systems.

TECHNOLOGY-BASED EF FLUENT LIMITATIONS

Ecology reviewed the applicant's Form R (Toxic Release Inventory Reporting Form), list of Superfund Amendments and Reauthorization Act of 1986 (SARA) Title III hazardous substances, and Form 2C of the NPDES Permit Application. also reviewed the discharge monitoring reports (DMRs), study results, and wastewater inspection re sults generated during the term of the previous permit.

After reviewing this data, Ecology determined that, in general, the effluent limits from the previous permit will remain the same. Thes e limits are believed to be ef fective regulatory controls.

Technology-based limitations are se t by regulations or developed on a case-by-case basis. EPA periodically evaluates specific industries, such as primary aluminum smelting, and publishes federal effluent guidelines which represent technology-based efflue nt limitations. In Washington, state law imposes a requirement to provide all known available and reasonable methods of treatment (AKART), and this requireme nt is functionally an overlay on the federal requirements. AKART may dictat e more stringent technology-bas ed limits than the federal effluent guidelines.

The applicable federal effluent guidelines for the primary aluminum smelting subcategory were promulgated by EPA on July 7, 1987 and ar e published in 40 CFR 421 Subpart B. EPA periodically reviews its effl uent guidelines and determines when guidelines for specific industries need to be updated. In EPA’s Technical Support Document for the 2004 Effluent Guidelines Program Plan EPA reviewed the primary aluminum smelting subcategory and determined that “reduction in pollu tant loadings from raw wastewat er to discharges indicate that the current treatment in the industry should be resulting in 99+ percent reductions for those pollutants regulated in the 1990 ru le” and that concentrations of benzo(a)pyrene “are generally below treatable concentrations and additional reductions of this pollutant may not be possible.” EPA determined in 2004 that the effluent guidelines for the entire Nonferrous Metals Manufacturing Point Source Category (of which pr imary aluminum smelting is a subcategory) did not need to be revised

The effluent limitations for toxic, non-conventio nal, and conventional pollutants at Outfalls 001 and 002 in the previous permit were establishe d using Best Professional Judgment (BPJ). Although the applicant has discharges that are ap plicable subcategories in the federal effluent guidelines in 40 CFR Part 421 - S ubpart B, these guidelines were not used to develop the limits. The limits for Outfall 001 are performance base d and were developed by running a statistical

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### analysis on two years of represen tative monitoring data using a me thod consistent with EPA and Ecology effluent limit setting guidelines.

The performance-based limits are more stringent than the federal efflue nt guidelines. Ecology has determined that the limits for Outfall 001 are based on AKART but is also requiring treatment efficiency studies in this permit. A possible outcome of these studies would be a refinement of AKART for this facility.

The concentration limits for the sa nitary lagoon are taken directly from the discharge standards and effluent limitations for domestic wastewater f acilities, Chapter 173-221 WAC. On January 21, 2004, Intalco submitted a request for an alternativ e percent removal effluent limitation at the sanitary lagoon during periods of reduced operations or temporary curtailment. Ecology reviewed the Permittee’s request and determined that the Permittee meets the criteri a required in Chapter 173-221-050 WAC and Chapter V, Section 3.5.1 of Permit Write r’s Manual. Therefore, the removal efficiency for BOD and TSS in the sa nitary lagoon discharge was reduced from a minimum of 65% to 55% when a monthly average of < 400 persons are employed onsite. The Permittee is required to report the number of pers onnel onsite to Ecology in the monthly discharge monitoring report. Upon an increase in personnel to > 400 persons monthly average, the removal efficiency for BOD and TS S is required to revert to a minimum of 65%.

Mass-based limits for B(a)P, antimony, and nickel were removed from the 1991 and 1998 NPDES permits for undefined reasons. Pe r 40 CFR 122.44(a)(1) and 122.44(1)(2)(ii), Ecology is reinstating these limits. Ecol ogy used representative production rates and the federal effluent guidelines for the primary aluminum smelting subcategories in 40 CFR 421 to derive the respective production-based effluent limits summariz ed in the table below (see the footnote for a discussion of the derivation of the limits).

PRODUCTION-BASED EFFLUENT LIMITS

Effluent Limitation Guideline Production-Based Effluent Limit

Production Rate million pounds (MMlb) Maximum Day (lb/MMlb) Maximum Monthly Average (lb/MMlb) Daily Maximum 

## B(a)P (lbs/day) Maximum Monthly Average (lbs/day) Anode Contact Cooling and Briquette Quenching (40 CFR 421.23(b)) 

### 1.8 0.007 0.003 0.013 0.005 Potroom Wet Air Pollution Control (40 CFR 421.23(m)) 

### 2.1 0.056 0.026 0.118 0.055
Direct Chill Contact Cooling (40 CFR 421.23(q)) 

### 2.1 NA NA NA NA B(a)P Permit Limits when aluminum production is greater than 15,614 tons per month 0.13 0.06 B(a)P Permit Limits when aluminum producti on is less than or equal to 15,614 tons per month 0.065 0.03



### Fact Sheet Page 19 of 68 Revised at Permit Issuance 03/15/07 Intalco NPDES Permit (WA-000295-0)

### PRODUCTION-BASED EFFLUENT LIMITS (CONTINUED)

Effluent Limitation Guideline Production-Based Effluent Limit



## Antimony Production Rate million pounds (MMlb) Maximum Day (lb/MMlb) Maximum Monthly Average (lb/MMlb) Daily Maximum (lbs/day) Maximum Monthly Average (lbs/day) Anode Contact Cooling and Briquette Quenching 

### 1.8 0.403 0.18 0.725 0.324

Potroom Wet Air Pollution Control 

### 2.1 3.204 1.428 6.728 2.999
Direct Chill Contact Cooling 

### 2.1 2.565 1.143 5.387 2.400 Antimony Permit Limits when aluminum production is greater than 15,614 tons per month 12.8 5.7 Antimony Permit Limits when aluminum production is less than or equal to 15,614 tons per month 6.4 2.85

Effluent Limitation Guideline Production-Based Effluent Limit



## Nickel Production Rate million pounds (MMlb) Maximum Day (lb/MMlb) Maximum Monthly Average (lb/MMlb) Daily Maximum (lbs/day) Maximum Monthly Average (lbs/day) Anode Contact Cooling and Briquette Quenching 

### 1.8 0.115 0.077 0.207 0.139

Potroom Wet Air Pollution Control 

### 2.1 0.913 0.614 1.917 1.289
Direct Chill Contact Cooling 

### 2.1 0.731 0.492 1.535 1.033 Nickel Permit Limits when aluminum pr oduction is greater than 15,614 tons per month 3.7 2.5 Nickel Permit Limits when aluminum producti on is less than or equal to 15,614 tons per month 1.85 1.25


### Ecology used monthly average production data from 1999 and 2000 to determine the production rates used to derive the monthly average limits for each of the processes. The monthly average production rates were also used to derive the maximum daily limits because the Permittee had no daily production data available. Ecology used the respective actual maximum monthly average production rates (converted to a daily maximum production rate assuming 24 hours of operation for 30 days each month) to derive the daily maximu m production-ba sed limit.

Because the Permittee has not operate d at full production in recent years, Ecology has established tiered production limits with the higher tier ap plicable when production exceeds 15,614 tons per month, and the lower tier applicable when producti on is less than or equal to 15,614 tons per month. 15,614 tons per month aluminum production is half the actual maximum monthly average production rate that occurred between 1999 and 2000 when the Permittee operated at full production.

The Permittee’s actual maxi mum monthly average pr oduction data for the Anode Contact Cooling and Briquette Quenching process was based on 16 hours of production per day. The Permittee plans to operate this process 24 hours a day duri ng the next permit cycle. Ecology converted the

Fact Sheet Page 20 of 68 Revised at Permit Issuance 03/15/07 Intalco NPDES Permit (WA-000295-0)

### maximum monthly average productio n rate into a maxi mum daily production rate based on 24 hour per day operation for a 30 day month per the calculations below. Ecology used the new maximum daily production rate to derive the maximum daily limits for the Anode Contact Cooling and Briquette Quenching process.

Calculations: Maximum monthly averag e production rate = 17668 tons per month (17668 tons/month)x(month/30 days)= 589 tons/day (589 tons/day)/(16 hours/day)= 37 tons/hour (37 tons/hour)x(24 hours/day)=888 tons/24 hour day (888 tons/day)x(2000lb/ton)x(MM lb/1.0x10 6 

### lb)= 1.8 MM lb/day = Maximum Daily Production

With the netting out allowance for TSS and alu minum at Outfall 001, th e intake water (PUD) levels were often higher than effluent levels. Th is resulted in a large numbe r of zeros in the data set. After evaluating several different ways to set limits for TSS and al uminum at Outfall 001 under the “netting out” provision, the permit writer decided to assign limits from the previous permit (issued February 14, 1992) . The limits for daily maximu m and monthly av erage TSS and daily maximum aluminum were determined by multiplying EPA Best Available Technology Economically Achievable (BAT) treatability leve ls by production normalized flows from process and non-process wastewater sources.

The effluent pH limitation in the permit will conti nue to be 6.0 to 9.0. This limitation is based on Best Practicable Control Technology (BPT) from guidelines in 40 CFR Part 421.22. This range (6.0 to 9.0) will not result in water quality violations.

Stormwater discharged at Outfall 002 is ma naged by a combination of best management practices and treatment by a stormwater detention pond, which Ecology has determined constitutes AKART for this faci lity. Because the monitoring da ta from Outfall 002 are highly auto correlated they do not meet the requi rements for normal stat istical distribution, a requirement for proper use of guidelines for estab lishing performance-based effluent limits. For this reason, limits for Outfall 002 are base d on Best Professional Judgement (BPJ).

NETTING OUT

The industrial water supplied to Intalco by Wh atcom County PUD No. 1 is treated Nooksack River water. The treatment pr ocess consists of coagulation/ flocculation followed by gravity separation. The treated water is not filtered and contains con centrations of TSS, aluminum, antimony, and nickel. About 80-90% of Intalco’s process water discharge is non-contact cooling water. The concentration of these constituents in the PUD supply water is neither increased nor decreased by use of once-through non-contact c ooling. The TSS and aluminum levels in the incoming source water do not meet the technolo gy-based limits for primary aluminum smelters that are based upon the amount of product produced.

Since the TSS, aluminum, antimony and nickel levels in the effluent at Outfall 001 are not fully representative of the impacts from the smelter, the NPDES permit allows Intalco to “net out” incoming pollutants in the intake water. Netti ng out allows Intalco to subtract the amount of

Fact Sheet Page 21 of 68 Revised at Permit Issuance 03/15/07 Intalco NPDES Permit (WA-000295-0)

### TSS, aluminum, antimony and nickel in the intake water from the values in the effluent to determine compliance with effluent limits. The e ffluent limits established for Outfall 001 are for the net discharge of TSS, aluminum, antimony and nickel.

Netting out is allowed in federal regulation, 40 CFR 122.45(g). There is a restriction that the discharge is to the same water body as the intake water unless th ere is a finding of no environmental degradation. Ecology policy uses the results of whole e ffluent toxicity (WET) tests as the criteria for dete rmining environmental degradati on. WET tests for Outfall 001 indicate that no reasonable poten tial exists for acute or chronic receiving water toxicity.

The permit will be reopened and the netting out provision for TSS, aluminum, antimony and nickel will be removed if any new information, su ch as the results of herring bioassay testing, shows that the receiving water environment is adversely affected by these constituents.

STORMWATER ALLOCATION AT OUTFALL 001

Condition S1.D of the permit requires Intalco to divert Outfall 002 stormwater to Outfall 001, pursuant to a specific time schedule.

After completing the diversion of stormwater from Outfall 002 to Outfall 001, the effluent limits for Outfall 001 will be adjusted to allow an allocation for the following parameters in the additional flow: TSS, B(a)P, aluminum, and fluor ide. The stormwater allocation for each of these parameters will be determined by convert ing the concentration-ba sed limit for Outfall 002 from the previous permit (1998) to a mass-based increment and adding it to the baseline effluent limit for Outfall 001. The additional stormwater flow from Outfall 002 entering Outfall 001 will be determined by continuous flow monitoring at D-10.

The maximum daily stormwater allocation for fluoride was calculated as follows:

Fa = Fc x flow x (3,785,000 l/million gallons)/(454,000 mg/lb)

Fa = 416.9 x flow

Where:

Fa = Stormwater allocation for fluoride (lb/million gallons) Fc = Maximum daily concentration limit for fluoride in 1998 permit (50 mg/l) flow = Stormwater flow from Outfall 002 (millions of gallons/day)

The same formula was used to calculate the average monthly stormwater allocation for fluoride and the stormwater allocations for TSS and aluminum. The stormwater allocation for B(a)P is based on the maximum stormwater B(a)P concentration measured in 20 months of Outfall 002 sampling. The allocations are tabulated below:

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### Stormwater Allocation (lbs/million gallons)

Parameter Monthly Average Daily Maximum
Total Suspended Solids 292 625

Fluoride 292 417

Aluminum 83 125

B(a)P 0.0017 0.0017

ELIMINATING THE TOTAL SUSPENDED SO LIDS (TSS) CONCENTRATION LIMIT FOR OUTFALL 001

The previous permit contained two separate monthly average discharge limits for Total Suspended Solids (TSS) from Outfall 001:

• 150 pounds/day (mass limit)

• 10 milligrams/liter (concentration limit)

During the permit renewal process, Intalco request ed that the TSS concentration limit (10 mg/l) be eliminated from the new permit. Intalco beli eved that the mass limit was more stringent and thus protective of the receiving water.

Over the term of the current permit (Septemb er 1998 through the present), Intalco has exceeded the daily maximum TSS limit on two occasions. The assignable causes for both of these exceedances were related to upsets in the opera tion of the facility’s secondary wastewater treatment plant. Intalco has never exceeded the monthly average TSS concentration limit or the monthly average TSS mass limit.

At Ecology’s request, Intalco an alyzed a database of over 1200 daily TSS measurements from the discharge. Intalco was ab le to show a correlation betwee n TSS concentration and TSS mass discharges at Outfall 001. A monthly average di scharge of TSS at a conc entration of 10 mg/l is predicted to represent a mass disc harge of 193 lb/day. Therefore, the 10 mg/l TSS concentration limit established in the current permit is less stri ngent than the 150 lb/day TSS mass limit. After reviewing Intalco’s analysis, Ecol ogy agreed that the concentrati on limit is less stringent than the mass-based limit and eliminated it in the permit.

Fact Sheet Page 23 of 68 Revised at Permit Issuance 03/15/07 Intalco NPDES Permit (WA-000295-0)

### REDUCED MONITORING FOR ANTIMONY, NICKE L, B(a)P, COPPER, CYANIDE, AND OIL AND GREASE

According to 40 CFR 122.44(a)(2)(i), any limit that is based on federal e ffluent guidelines may not be removed from a permit unless the source of the pollutant has been completely eliminated and not just controlled. This rule allows a reduction in monitoring at appropriate levels. If the Permittee has demonstrated with ad equate historic data that they can meet the permit limit then monitoring may be reduced to once per year (t he minimum required und er federal rules – 40 CFR 122.44(i)(2). If the permit limit was based on BPJ and Ecology is convinced that the pollutant has no potential to cause environmental harm, the limit can be removed from the permit and replaced by reduced mon itoring of the pollutant.

In the permit, monitoring for B(a)P, antimony, ni ckel, copper, cyanide, and oil and grease at Outfall 001 and for copper, cyanide, B(a)P, and o il and grease at Outfall 002 have been reduced from the previous permit. See the discussi on of production-based limits for B(a)P, antimony, and nickel in “ TECHNOLOGY-BASED EFFLUENT LIMITATIONS” earlier in this document. See the discussion of the reduced m onitoring for B(a)P, and antimony and nickel in

“ PERFORMANCE-BASED REDUCTION OF MONITORING FREQUENCIES ” later in this document. The Permittee is required to mon itor for copper as part of the annual priority pollutant scan (PPS) at both outfalls (Condition S 1.I) and is required to monitor for cyanide as part of the annual PPS at Outfall 002. The monitoring frequency for O&G was reduced to monthly for both outfalls. These monitoring change s were made based on reviews of historical monitoring data and the fact that the sources of the respective polluta nts have either been eliminated or are being controlled. The follo wing paragraphs provide information about the Permittee’s management of the sources of B(a) P, copper, cyanide, and oil and grease. The limits for copper, cyanide, a nd oil and grease from the prev ious permit were not changed

B(a)P

Benzo-a-pyrene (B(a)P) is pres ent in very small amounts in th e coal tar pitch used in the manufacture of anodes for the reduction process. Several improvements in handling practices and treatment of wastewater have reduced the likelihood of B(a)P and other related polycyclic aromatic hydrocarbons (PAH) being released to the process or st ormwater outfalls. The most significant source of B(a)P discharg e to the process outfall is from anode contact cooling water. To mitigate this potential, a filtration system has been installed to augment the existing API separator. See the discussions of the anode contact cooling water under Outfall 001 in “Discharge Descriptions” above a nd in “Treatment Efficiency Studi es” later in this document.

In the past, there was a potential for contamin ation of stormwater with B(a)P because offspecification materials containing B(a)P were stored out side. These off-specification materials were diverted from the anode forming process when process upsets occurred and stored until they could be reused in the process. Recently, the areas where this temp orary storage occurred have been covered and bermed to prevent stor mwater from contacting this material and to prevent stormwater inside the be rm from being released to the surrounding area. These materials are therefore no longer contributing to stormwater contamination.

Fact Sheet Page 24 of 68 Revised at Permit Issuance 03/15/07 Intalco NPDES Permit (WA-000295-0)

### Over the last permit term, 100% and 99% of th e samples collected to monitor B(a)P in the discharges from Outfalls 001 a nd 002 respectively have been be low the detection limit of 0.001 mg/l.

Copper

The source of copper in Intalco’s wa stewater is believed to be from PUD intake water. Since the copper monitoring requirement was established in Intalco’s 1998 NPDE S permit, 85% of the samples collected to monitor copper have had co pper concentrations below the detection limit of 6 micrograms/liter. To date, with the exception of 7 samples, all of the copper values for the 591 other samples collected were less than 15 micrograms/liter. A summary of the copper monitoring data collected over the term of the previous NPDES permit (September 1998- October 2004) is provided in Appendix I

.
In October 2003, 5 samples from monitored discharges were found to contain copper concentrations above 250 micrograms/liter which were apparently false positives due to laboratory reagent water contamination. Mon itoring results in December 2003 also indicated higher than normal copper concentr ations. Intalco conduc ted an investigation of the root cause of these high copper concentratio ns. Intalco sampled several pot ential sources of contamination and analyzed them for traces of copper. The sources included the laboratory de-ionized water system, the acid supplies used for both preservati on and digestion, and a re presentative sampling of volumetric glassware, and di gestion vessels. Although the inve stigation did not conclusively find the source of the contamina tion, all of the aforementioned except the de-ionized water system were ruled out as potential sources of copper contamination.

The samples collected from the de-ionized water system did not indicate copper contamination. However, inspection of the de-ionized water dist ribution discovered one faucet with a significant leak. When the valve system was removed a nd examined for damage, a badly corroded brass screw was found holding the washer onto the body of the valve stem. The screw was removed and replaced with a polypropylene screw. Subse quent analyses of the discharge samples for January through October 2004 show that the copper va lues have returned to the very low levels considered normal.

Cyanide

The Permittee maintains a triple-lined landfill on site which is used for the disposal of spent potliner (SPL). This landfill has a leachate collec tion system and a containment berm in place. Cyanide is a component of the SPL in the landfill. A break in the triple liner or a breech in the containment berm could result in a potential di scharge of cyanide to the stormwater system.

A review of monthly discharge monitoring repor ts (DMR) back through January 1994 indicated that 100% of the stormwater samples collected at Outfall 002 and analyzed for cyanide were below the method detection limit of 0.005 mg/l. Give n 10 years of data indicating that there has been no cyanide detected in the Outfall 002 di scharge, Ecology deci ded to reduce cyanide monitoring from weekly to annually.

Fact Sheet Page 25 of 68 Revised at Permit Issuance 03/15/07 Intalco NPDES Permit (WA-000295-0)

### Oil and Grease

Intalco has made significant advances in source reduction or treatment of organic materials over the last ten years. The largest potential for oil contamination occurs in the cooling water used in the “Direct chill” or DC casting process. This water has the potential to become contaminated with oils used in the hydraulics of this process. All of the wate r used in the DC casting process is pumped to a cooling tower equipp ed with an oil flocculation and flotation process. The oil, if present, is then removed and disposed as a solid waste in an approved landfill.

Additional measures have been ta ken to reduce oil and grease cont amination from the facility. These measures include the installation of sm all treatment systems to serve steam-cleaning operations at the automotive, central maintenan ce, and annex maintenance shops. The treatment systems consist of a coalescing filter and sand f ilter to remove both oil and grease and suspended solids. The waste materials from theses filters are disposed as solid waste.

Frequency distributions of the Permittee’s oil and grease (O&G) monitoring data collected from 1991 through 2004 for Outfalls 001 and 002 are pr esented in Tables 1 and 2 below. The Practical Quantitation Limit (PQL) and the Me thod Detection Limit (MDL) for O&G were 3.0 mg/L and 1.0 mg/L respectively. Ba sed on a review of this data, Ecology reduced the monitoring frequency from daily to monthly for both Outfalls.

Table 1 – Oil & Grease Monito ring Data for Outfall 001

Concentration (mg/L) Range (Maximum Daily Permit Limit = 10 mg/L) Frequency of Occurrence % of Total Data in Concentration Range

0-1 2995 60.29%
1-2 1417 28.52%
2-3 382 7.69%
3-4 122 2.46%
4-5 29 0.58%
5-6 14 0.28%
6-7 6 0.12%
7-8 2 0.04%
8-9 0 0.00%
9-10 0 0.00%
>10 (1) 

### 1 0.02%

1 Occurred on July 20, 1991



### Fact Sheet Page 26 of 68 Revised at Permit Issuance 03/15/07 Intalco NPDES Permit (WA-000295-0)

### Table 2 – Oil & Grease Monito ring Data for Outfall 002

Concentration (mg/L) Range (Maximum Daily Permit Limit = 10 mg/L) Frequency of Occurrence % of Total Data in Concentration Range

0-1 2275 46.33%
1-2 1613 32.85%
2-3 625 12.73%
3-4 250 5.09%
4-5 89 1.81%
5-6 28 0.57%
6-7 14 0.29%
7-8 14 0.29%
8-9 2 0.04%
9-10 0 0.00%
>10 0 0.00%



### SURFACE WATER QUALITY-BASED EFFLUENT LIMITATIONS

In order to protect existing water quality and preserve the designated beneficial uses of Washington's surface waters, WAC 173-201A-060 stat es that waste discharge permits shall be conditioned such that the discharge will meet es tablished Surface Water Quality Standards. The Washington State Surface Water Quality Sta ndards (Chapter 173-201A WAC) is a state regulation designed to protect the beneficial uses of the surface waters of the state. Surface water quality-based effluent limitations may be based on an individual waste load allocation (WLA) or on a WLA developed during a basin wide total maximum daily loading study (TMDL).

N UMERICAL 

### C RITERIA FOR THE 

### P ROTECTION OF 

### A QUATIC 

### L IFE


### "Numerical" water quality criteria are numerical values set forth in th e State of Washington's Water Quality Standards for Surface Waters (Chapt er 173-201A WAC). They specify the levels of pollutants allowed in receiving water while re maining protective of aquatic life. Numerical criteria set forth in the Water Quality Standards are used along with chemical and physical data for the wastewater and receiving water to derive the effluent limits in the discharge permit. When surface water quality-based limits are more stringent or potentially more stringent than technology-based limitations, they must be used in a permit.

N UMERICAL 

### C RITERIA FOR THE 

### P ROTECTION OF 

### H UMAN 

### H EALTH


### The U.S. EPA has promulgated 91 numeric water quality criteria for th e protection of human health that are applicable to Washington State (EPA 1992). These criteria are designed to protect humans from cancer and other disease and are primarily applicable to fish and shellfish consumption and drinking water from surface waters.

Fact Sheet Page 27 of 68 Revised at Permit Issuance 03/15/07 Intalco NPDES Permit (WA-000295-0)

### N ARRATIVE 

### C RITERIA



### In addition to numerical criter ia, "narrative" water quality criteria (WAC 173-201A-030) limit toxic, radioactive, or deleterious material concentrations below t hose which have the potential to adversely affect characteristic water uses, cause acute or chronic toxici ty to biota, impair aesthetic values, or adversely affect human heal th. Narrative criteria protect the specific beneficial uses of all fresh (WAC 173-201A- 130) and marine (WAC 173-201A-140) waters in the State of Washington.

A NTIDEGRADATION


### The State of Washington's Antidegradation Policy requires that discharges into a receiving water shall not further degrade the ex isting water quality of the water body. In cases where the natural conditions of a receiving water are of lower qua lity than the criteria assigned, the natural conditions shall constitute the wa ter quality criteria. Similarly, when the natural conditions of a receiving water are of higher qual ity than the criteria assigned, the natural conditions shall be protected. More information on the State Antideg radation Policy can be obtained by referring to WAC 173-201A-070.

Ecology has reviewed existing water quality data from Ecology’s long-term monitoring station GRG002 and from Eric Crecelius (2000). The data show that the ambient water meets the temperature, dissolved oxygen, pH, turbidity, a mmonia, cyanide and metals standards for the designated Class AA marine waters given in Chapter 173-201A WA C. Therefore, will use the designated classification criteria for this water body in the permit. The discharges authorized by this permit should not cause a loss of beneficial uses.

E FFLUENT 

### Q UALITY



### Pollutant concentrations of chlo rine, copper, cyanide, and nickel in the proposed discharge from Outfall 001 exceed aquatic life wate r quality criteria at the poin t of discharge with technologybased controls that Ecology has determined to be AKART. Similarly, PAHs in the proposed discharge from Outfall 001 exceed the human health water quality criteria. Therefore, Ecology considered whether the discha rge from Outfall 001 qualifies for a mixing zone in accordance with WAC 173-201A-400.

Pollutant concentrations of copper, and nickel in the proposed discharge from Outfall 002 exceed aquatic life water quality criteria at the point of discharg e with BMPs and technology-based controls that Ecology has determined to be AKAR T. Similarly, PAHs in the proposed discharge from Outfall 002 exceed the human h ealth water quality cr iteria. Therefore, considered whether the discharge from 002 qualifies for a mixing zone in accordance with WAC 173-201A-400.

D ESCRIPTION OF THE 

### R ECEIVING 

### W ATER


### The Permittee discharges to marine waters in the Strait of Georgia and these waters are designated waters of ex traordinary quality in the vicin ity of Outfalls 001, 002, 003-005, 011, and 012. Characteristic uses include the followi ng: fish migration; fish and shellfish rearing,

Fact Sheet Page 28 of 68 Revised at Permit Issuance 03/15/07 Intalco NPDES Permit (WA-000295-0)

### spawning and harvesting; wildlife habitat; primary contact recreati on; sport fishing; boating and aesthetic enjoyment; commerce and navigation. Water quality of this class shall markedly and uniformly exceed the requirements for all or substantially all uses.

The closest Ecology long-term core monitoring station, GRG002, is located in the Strait of Georgia near Patos Island. It is far enough away from the Cherry Point industries to prevent their discharges from influencing readings taken there. There is also substantial data for this station. The station at Bellingham Bay, BLL009, is also very close but is influenced by activity in Bellingham and is not suitable for a backgroun d data station. The cl osest long-term rotating station is LOP001 in Lopez Sound.

S URFACE 

### W ATER 

### Q UALITY 

### C RITERIA


### Applicable criteria are defined in Chapter 173-20 1A WAC for aquatic biot a. In addition, U.S. EPA has promulgated human health criteria for toxic pollutants (EPA 1992). Criteria for this discharge are summarized below:

Fecal Coliforms 14 organisms/100 mL maximum geometric mean
Dissolved Oxygen 7.0 mg/L minimum
Temperature 13 degrees Celsius maximu m or incremental increases above background
pH 7.0 to 8.5 standard units
Turbidity less than 5 NTU above background
No toxics in toxic amounts (see Appendix L for numeric criteria for toxics of concern for this discharge) Toxics

The Strait of Georgia is listed on the 2003/2004 Clean Water Act 303(d) list. It is listed for a variety of pollutants found in the sediments near Outfall 001. The following pollutants were found in the sediments around th e Intalco discharge outfalls: hexachlorobenzene, bis(2- ethylhexylphthalate), dibenz ofuran, phenol, PCBs, and PAHs . 1,2,4-trichlorobenzene and 1,2- dichlorobenzene were not detected but the detection limits for these parameters exceeded the Sediment Quality Standards . Stations near the Intalco discharge that have exceeded numeric sediment quality standards have passed confirma tory bioassay testing in accordance with the Sediment Management Standards (SMS) rule (Chapter 173-204 WAC). Under the SMS rule, sediments that pass confirmatory bioassays meet the sediment quality standards regardless of the numeric sediment chemistry results.

Intalco is required to submit a Sediment Sampling and Analys is Plan in Condition S11.A. of the permit. The additional monitoring to recharacteri ze the sediment in the vi cinity of Outfalls 001 and 002 will be conducted during the be ginning of the next permit cycle.

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### M IXING 

### Z ONES



### The Water Quality Standards allow Ecology to authorize mixing zones around a point of discharge. Both "acute" and "chronic" mixing z ones may be authorized for pollutants that can have a toxic effect on the aquatic environment near the point of discharge. The concentration of pollutants at the boundary of these mixing zones ma y not exceed the numerical criteria for that type of zone. Mixing zones for toxicants can only be authorized for disc harges that are receiving all known, available, and reasonable methods of prevention, control and treatment (AKART) and in accordance with other mixing zone requirements of WAC 173-201A-400.

The National Toxics Rule (EPA, 1992) allows mixi ng zones to be used to meet human health criteria. Ecology has decided to use the chro nic mixing zone for hu man health criteria.

Ecology has established a compliance schedule in the permit to divert stormwater from the present discharge at Outfall 002 to Outfall 001. After the diversion is complete, Ecology will allow some stormwater to be discharged from Outfall 002 at times when the hydraulic capacity of Outfall 001 would be exceeded, a condition that is expected to occur very infrequently. The following discussion regarding Outfall 002 pertai ns to the mixing zone for stormwater both before and after the diversion.

M IXING 

### Z ONE 

### D ETERMINATIONS 

### F OR 

### O UTFALLS 

### 001 A ND 

### 002

1. WAC 173-201A-400(1) requires th at the allowable size and location of a mixing zone and associated effluent limits be established in a permit.

This permit specifies the size and location of the allowable mixing zones for Outfalls 001 and 002 and the associated effluent limits.

2. WAC 173-201A-400(2) requires a discharger to fully apply AKART prior to being authorized a mixing zone.

Ecology has determined that the treatment provi ded for the discharges at Outfalls 001 and 002 and the pollution prevention activities practi ced at Intalco meet the requirements of AKART.

3. WAC 173-201A-400(3) requires mixi ng zone determinations to c onsider critical discharge conditions.

Critical discharge conditions ar e those conditions that result in reduced dilution. Factors affecting dilution include the depth of water, the density stratification in the water column, the density of the effluent, the curren ts and the rate of di scharge. The Permit Writer’s Manual provides guidance on how to de rive the critical conditions for evaluating

Fact Sheet Page 30 of 68 Revised at Permit Issuance 03/15/07 Intalco NPDES Permit (WA-000295-0)

### dilution from an outfall. Ecology followed that guidance in determining the acute, chronic, and human health cr iteria dilution factors.

Critical flow conditions for Outfall 001 were re -evaluated for this permit to consider four different flow conditions, which the discharge could experience during the term of the permit. The conditions are:

• Flows based on full production and non-cont act cooling water (This is the existing condition)

• Flows based on the addition of Outfall 002 stormwater to full production and noncontact cooling water.

• Flows based on full production only with the non-contact cooling water removed (there are plans for a co-generation facility to be built by the BP refinery, which will use the non-contact cooling water).

• Flows based on full production, no non-contact cooling water, and the addition of Outfall 002 stormwater.

4. WAC 173-201A-400(4) states th at no mixing zone shall be granted unless supporting information clearly indicates that the mixing z one would not have a reasonable potential to cause a loss of sensitive or important habitat, substantially interfere with the existing or characteristic uses of the water body, result in damage to the ecosystem, or adversely affect public health as determined by the department.

The wastewater discharges at Outfalls 001 and 002 have been evaluated to determine if there is a reasonable potential to exceed water quality standards. Water quality standards are based on EPA criteria. EPA’s criteria were developed from toxicity tests with numerous organisms. Water quality standard s include relevant dura tions of exposure and are not based on instantaneous exposures.

Acute standards generally are based on a 1-hour exposure at th e criteria level and chronic standards generally are based on a 4-day expos ure at the cr iteria level. The dilution modeling under critical conditions showed th at the acute diluti on at Outfall 001 was attained in less than 1 minute and the chr onic dilution in less than 9 minutes. The dilution modeling under critical conditions showed that the acute dilution at Outfall 002 was attained in less than 3 minutes and th e chronic dilution in less than 9 minutes. Drifting and non-strong swimming organisms in the water colu mn would not be affected by Intalco’s discharge because they cannot physically stay in the plume close to the outfall long enough to be affected. Strong swimming fish could maintain a position within the plume, but they can also avoid it.

Benthic organisms are not affected by the mixing zone because the plume is buoyant and rises in the water column. The diffuser for Ou tfall 001 itself is attached to pier pilings above the bottom which further prevents exposures to benthic organisms.

Whole effluent toxicity (WET) testing pr ovides a means of evaluating the cumulative toxicity of an effluent. WET testing perfor med by Intalco for Outfa ll 001 indicates that there is no reasonable potential for acute or ch ronic receiving water toxicity. During this

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### permit term, stormwater from Outfall 002 will be diverted to Outfall 001 and non-contact cooling water from the smelter is scheduled to be routed to the BP cogeneration facility for reuse. Non-contact cooling water will no longer be discharged via Outfall 001 if the BP cogeneration project is implemented. Consequently, Outfall 001 discharges will require additional WET characteriza tion following these changes.

Stormwater at Outfall 002 has occasionally s hown toxicity at dilutions less than the chronic critical effluent concentration. Ongoing implementation and refinement of stormwater best management practices (B MPs) is effectively reducing stormwater toxicity. WET limits are set based on dilution factors. When stormwater is re-routed to Outfall 001, the increased mixing allowance w ill further reduce the potential for the stormwater to actually have toxic e ffects in the receiving water.

The mixing zone for Outfall 001 is small and is centered at a dist ance of 1,100 feet from shore. The mixing zone does not overlap the herring spawning areas, which are closer to shore. The mixing zone for Outfall 002 is sma ll and is centered at a distance of 250 feet from shore. When the stormwater is re-ro uted to Outfall 001, then the mixing zone for Outfall 002 will essentially be unused except fo r when the hydraulic capacity of Outfall 001 is reached. This is likely to be a very rare occurrence and it is unlikely that these events would occur during the herring spawning season.

There is no documented linkage between Intalc o’s treated process water and stormwater effluents and the reduction in the local herr ing population. Intalco will use the recently developed herring bioassay test s to evaluate the possible e ffects of their effluents on herring and to compare the herring bioassay results with other EPA approved bioassay

tests.
When considering all of the above, Ecology has determined that the mixing zones for Outfalls 001 and 002 do not have a reasonable potential to cause a loss of sensitive or important habitat, substantially interfere with the existing or charac teristic uses of the water body, result in damage to the ecosyst em, or adversely affect public health. However, Ecology has determined that movi ng the stormwater discharge from Outfall 002 to Outfall 001 is a reasonabl e, available, and prudent measure that will provide further protection for nearshore habitat. The very infrequent use of Outfall 002 after the diversion is complete should not result in harmful effects.

5. WAC 173-201A-400(5) requires that water quality criteria shall not be violat ed outside of the boundary of a mixing zone.

Ecology conducted a reasonable potential to exceed analysis for Outfalls 001 and 002 (see Appendix L ), using procedures established by EPA and Ecology, for each pollutant to assure that there will be no violations of the water quality criteria outside the boundary of the mixing zones. The RPTE analysis us ed the lowest dilution ratios from all of the mixing scenarios that were modeled. Mode ling studies by ENSR in 2001 also evaluated the aggregate impact of the different industr ial discharges in the Cherry Point area and documented that the combined discharges do not result in exceedances of water quality criteria. Whole effluent toxicity test re sults at Outfall 002 have also shown much improvement as adjustments and additions have been made to BMPs implemented by Intalco.

Fact Sheet Page 32 of 68 Revised at Permit Issuance 03/15/07 Intalco NPDES Permit (WA-000295-0)

### 6. WAC 173-201A-400(6) requires that the size of a mixing zone and the concentrations of pollutants present shall be minimized.

The mixing zone size constraints provid ed in WAC 173-201A-400(7) and (8) are among the most limiting in the country. At any given time, the effluent plume actually utilizes only a portion of the acute and chronic mixi ng zone, which effectively minimizes the volume of water actually involve d in mixing. Because tidal currents change direction, the entire volume of the zone is needed to accommodate changes in plume orientation. The plume rises through the wate r column as it mixes and consequently most of the water volume in the mixing zone below the depth at which the mixed effluent traps, is not involved. Similarly, because the effluent will trap at some depth when density stratification is sufficient, waters above the tr apping depth will also not be involved in the mixing.

In the case of stormwater, much of the time the rate of discharge is much less than the rate that the allowed dilution is based on. That means that much of the time, the actual dilution will be greater, or that the allowed d ilution will be realized closer to the outfall, in less time than under the critical conditions.

It is impractical to attempt to specify in the permit the actual, more limited volume in which the dilution occurs as the plume rises, traps and moves with the current. However, the conservative modeled dilution factors imp licitly reduce the mixing zone volume from the volume described in the permit to just th e volume actually utilized by the plume.

The size of the mixing zone (in the form of the dilution factor) has been minimized by the use of design criteria with low probability of occurrence. For example, the reasonable potential to exceed analysis used the expected 95th percentile pollu tant concentration, the 90 th 

### percentile background concentration, the fl ux average dilution factor, and the most restrictive ambient current relevant to the acu te and chronic aquatic life and human health criteria.

The chronic mixing zones for Outfalls 001 a nd 002 are small, extending 217 feet and 209 feet, respectively, in all horizontal directions from the discharge points. The acute mixing zones are much smaller, extending 22 feet and 21 feet, respectively in all horizontal directions. When stormwater is re-routed to Outfall 001, the mixing zone for Outfall 002 will only be used during extreme stor m events, and that is expected to be a

rare occurrence.
For all of the above reasons, the size of the mixing zones for Outfalls 001 and 002 and the concentrations of the pollutants present are appropriately and effectively minimized.

7. WAC 173-201A-400(7)(b) and (8)(b) specify th e sizing requirements for mixing zones in estuarine waters.

The boundaries of the mixing zones were si zed in accordance with the regulatory requirements. The chronic mixing zone for Outfall 001 extends 217 feet in all horizontal directions from the diffuser. The acute mi xing zone for Outfall 001 extends 22 feet in any spatial direction from the diffuser. Th e chronic mixing zone extends 209 feet in all horizontal directions from Outfall 002. The acute mixing zone extends 21 feet in any

Fact Sheet Page 33 of 68 Revised at Permit Issuance 03/15/07 Intalco NPDES Permit (WA-000295-0)

### spatial direction from Outfall 002. The ch ronic mixing zones for each outfall extend from the seabed to the water surface. The human health mixing zones for each outfall are the same size as the chronic mixing zones.

8. WAC 173-201A-400(8) requires that a zone where acute criteria may be exceeded is allowed only if it can be demonstrated to the department 's satisfaction that th e concentration of, and duration and frequency of exposure to the discharg e, will not create a ba rrier to the migration or translocation of indigenous organisms to a de gree that has the potential to cause damage to the ecosystem.

The limited acute mixing zones authorized for Outfalls 001 and 002 will assure that they will not create a barrier to migration. The e ffluents from the two discharges will rise as they enter the receiving water assuring th at they will not cause translocation of indigenous organisms. Dilution modeling ha s demonstrated that mixing in the acute zones occurs very rapidly as the less dense e ffluent rises through the water column due to both the diffuser design and the buoyancy of th e effluent. Acute mixing occurs in less than a minute for Outfall 001 and in less than 3 minutes for Outfall 002 and the duration and frequency of exposure to elevated c oncentrations by any dr ifting or non-strong swimming organisms is minimized because the organisms simply cannot stay in one place while the plume moves past them. B ecause the mixing zone poses no barrier to organisms, strong swimming species are able to avoid the plume. Exposure to elevated concentrations in the effluents by benthic orga nisms is avoided because the plumes rise in the water column.

The acute mixing zones are sized at 10% of th e distance of the chronic mixing zones.

Because the requirements of WAC 173-201A- 400 have been satisfied, mixing zones are authorized in accordance with the following geom etric configurations and dilution factors.

9. WAC 173-201A-400(9) specifies conditions for allowing the overlap of mixing zones.

The mixing zones for Outfalls 001 and 002 do not overlap with each other or with another mixing zone.

D IFFUSER 

### I NFORMATION



### The diffuser at Outfall 001 is approximately 120 feet long with a diameter of 24 inches. There are 12 ports on each side (north and south faces) of the diffuser. Each port is 6 inches in diameter. The average distance between each of th e ports is 8 feet, 8 inches. The end of the diffuser has a blind flange with a 6 inch port in the center. The mean lower low water (MLLW) depth at the diffuser is 16 feet.

Outfall 002 extends 250 feet from th e shoreline. The open-ended pipe is 30 inches in diameter. The MLLW depth at the di scharge point is 9 feet.

This information and additional information is av ailable in the report entitled “Outfalls 001 and 002 Dilution Ratio Study” submitted to Ecology on December 1, 2006 (Cosmopolitan Engineering Group, 2006).

Fact Sheet Page 34 of 68 Revised at Permit Issuance 03/15/07 Intalco NPDES Permit (WA-000295-0)

### C HRONIC 

### M IXING 

### Z ONES


### WAC 173-201A-400(7)(b) specifies that mixing zones shall not extend in any horizontal direction from the discharge ports for a distance greater than 200 feet pl us the depth of water over the discharge ports as measured during ML LW. Given a MLLW depth of 16 feet for the diffuser at Outfall 001, the horizon tal distance is 216 feet. The mixing zone extends from the seabed to the top of the water surface. The horizontal distance of the chronic mixing zone at Outfall 002 is 209 feet.

A CUTE 

### M IXING 

### Z ONES


### WAC 173-201A-400(8)(b) specifies that in estuarine waters a zone where acute criteria may be exceeded shall not extend beyond 10% of the dist ance established for the chronic zone. The acute mixing zone for Outfall 001 extends 22 feet in any spatial direction from any discharge port. The acute mixing zone for Outfall 002 exte nds 21 feet in any spatial direction from the discharge pipe.

The dilution factors of effluent to receiving water that occur within these zones have been determined by the use of a dye study and modeling. The 1991 dye study, the 2002 and 2004 modeling were re-analyzed in August 2006 and revi sed in November 2006. The report entitled “Outfalls 001 and 002 Dilution Ratio Study” wa s prepared by Cosmopo litan Engineering Group for Intalco. The models used for near field effects were the EPA dilution models DKHW and UM3. Far field effects were predicted using th e EPA dilution model UM3. The dilution factors determined from this analysis are as follows:

Full Production plus non-contact c ooling water and separate stormwater outfall (current condition)
Acute Chronic Aquatic Life Outfall 001 27 41
Outfall 002 5 33 Human Health, Carcinogen
Outfall 001 NA 56
Outfall 002 NA 38 Human Health, Non-carcinogen
Outfall 001 NA 53
Outfall 002 NA 38

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### Full Production plus non-contact cooling water plus stormwater (diverting Outfall 002 to Outfall 001)
Acute Chronic Aquatic Life Outfall 001 26 40 Human Health, Carcinogen
Outfall 001 NA 54 Human Health, Non-carcinogen
Outfall 001 NA 52

Full production minus non-contac t cooling water and separate stormwater outfall (sending coolin g water to BP Cogen before the diversion is complete)

Acute Chronic Aquatic Life Outfall 001 40 66
Outfall 002 5 33 Human Health, Carcinogen
Outfall 001 NA 87
Outfall 002 NA 38 Human Health, Non-carcinogen
Outfall 001 NA 87
Outfall 002 NA 38

Full Production minus non-contac t cooling water plus stormwater (diverting Outfall 002 to Outfall 001 and sending cooling water to BP Cogen)

Acute Chronic Aquatic Life Outfall 001 28 61 Human Health, Carcinogen
Outfall 001 NA 83 Human Health, Non-carcinogen
Outfall 001 NA 83

Additional information regarding the update d mixing zone analysis is shown in Appendix J . A complete record of the dilution analysis for the Intalco aluminum smelter is available in Ecology’s files.

Fact Sheet Page 36 of 68 Revised at Permit Issuance 03/15/07 Intalco NPDES Permit (WA-000295-0)

### C ONSIDERATION OF 

### S URFACE 

### W ATER 

### Q UALITY 

### -B ASED 

### L IMITS FOR 

### N UMERIC 

### C RITERIA


### Pollutant concentrations in the proposed disc harges exceed water quality criteria with technology-based controls, which Ecology has de termined to be AKART. A mixing zone is authorized for each discharge in accordance with the geometric configuration, flow restriction, and other restrictions for mixing zones in Chapter 173-201A WAC as described above.

Pollutants in an effluent may affect the aquati c environment near the poi nt of discharge (near field) or at a considerable dist ance from the point of discharge (far field). Toxic pollutants, for example, are near-field pollutants--their advers e effects diminish rapidly with mixing in the receiving water. Conversely, a pollutant such as BOD is a fa r-field pollutant whose adverse effect occurs away from the discharge even af ter dilution has occurred. Thus, the method of calculating surface water quality-based effluent limits varies with the point at which the pollutant has its maximum effect.

The derivation of surface water qual ity-based limits also takes into account the variability of the pollutant concentrations in both the effluent and the receiving water.

Surface water quality-based limits are derived for the water body's critical condition, which represents the receiving water and waste discharge condition with the highest potential for adverse impact on the aquatic bi ota, human health, and existi ng or characteristic water body

uses.

The critical condition for the Geor gia Strait at Outfalls 001 and 002 occurs during the neap tide at MLLW and with 90 th 

### percentile background pollutant concentr ations. Ambient data at critical conditions in the vicinity of the two outfalls wa s taken from both histor ical data at Ecology’s Ambient Monitoring Station GRG002 and an in tensive monitoring study conducted in JulySeptember 1999 entitled “Concentrati on of Metals in Marine Wate r and Effluent of the Alcoa Intalco Works,” prepared by Eric Crecelius, Batt elle Marine Sciences Laboratory, April 2000):

Parameter Value Used
Temperature 19.3 o 

### C
pH (high) 7.9
Dissolved Oxygen 8.0 mg/l

Ammonia-N, total 0.45 mg/l
Cyanide, total <0.01 mg/l

Fluoride 1.27 mg/l

Aluminum, dissolved 11.4 μg/l

Cadmium, dissolved 0.11 μg/l
Copper, dissolved 0.93 μg/l

Lead, dissolved 0.02 μg/L
Mercury 0.0012 μg/L

Zinc, dissolved 2.90 μg/L

Other Metals Below detection limits



### Fact Sheet Page 37 of 68 Revised at Permit Issuance 03/15/07 Intalco NPDES Permit (WA-000295-0)

### The impacts of dissolved oxygen deficiency, temp erature, pH, turbidity, ammonia, metals, and other toxics were determined as shown below, using the dilution factors at critical conditions described above.

BOD 5 

### This discharge results in a sma ll amount of BOD loading relative to the large amount of dilution occurring in the receiving wate r at critical conditions. Technology-based limitations will be protective of dissolved oxygen crit eria in the r eceiving water.

Temperature

The impact of the discharges from Outfalls 001 and 002 on the temperature of the receiving water was analyzed using the guidance for th e State’s new temperature standards, WAC 173- 201A-210. To determine the reasonable potenti al to exceed temperature standards, Ecology evaluated the following criteria:

1. Annual Summer Maximum Criteria – Each water body has an annual maximum temperature criterion. These threshold criteri a protect specific categories of aquatic life by controlling the effect of human actions on summer temperatures. The reasonable potential to exceed the annual summer maximum criteria for Outfalls 001 and 002 was determined by using the following equation:

T chronic 

### = T ambient90 

### + (T effluent95 

### - T ambient90 

### )/DF

Where:

• T chronic 

### = Receiving water temperat ure at the chronic mixing zone boundary

• T ambient90 

### = 90 th 

### percentile of background temperatures at Station GRG002 from January 1999 through June 2005

• T effluent95 

### = 95 th 

### percentile of daily maximum e ffluent temperatures from January 1999 through October 2006.

• DF = Chronic d ilution factor at the critical condition

If T chronic 

### is greater than the criterion of 13 oC for extraordinary qual ity receiving waters, an effluent limit is needed.

Table 1 in Appendix K shows that the T chronic 

### in all cases for both Outfalls 001 and 002 is less than the temperature criterion of 13 oC. Therefore, there is no predicted violation of Water Quality Standards and an effluent limit is not required.

2. Incremental Warming Criteria – Where background temperatures are cooler than criterion - At locations and times when background temperat ures are cooler than the assigned threshold criterion, point sources are permitted to warm the water at the edge of the mixing zone by only a defined increment t . The reasonable potential to ex ceed incremental warming criteria for Outfalls 001 and 002 was determined using the equations below:

• T chronic 

### = T ambient 

### + (T effluent95 

### - T ambient 

### )/DF

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### • t = 12/(T ambient 

### – 2)

Where:

• T chronic 

### = Receiving water temperat ure at the chronic mixing zone boundary

• T ambient 

### = Instantaneous maximum b ackground temperature during critical time period at Station GRG002 fr om January 1999 through June 2005

• T effluent95 

### = 95 th 

### percentile of daily maximum effluent temperatures from January 1999 through October 2006

• DF = Chronic d ilution factor at the critical condition

If the ambient background temperature ( T ambient 

### ) is cooler than the th reshold criterion, and if T

chronic 

### is greater than (T ambient 

### + t ), an effluent limit is needed.

Tables 2 and 3 in Appendix K show the reasonable potential to exceed evaluation for several ambient temperatures selected from the sp ring months (March-June) of 1999 through 2005. Outfalls 001 and 002 discharge into the Cherry Point area where the he rring spawn during the spring season. Therefore, spring temperatures were chosen as th e critical time period for this evaluation.

In all cases, the T chronic 

### for Outfalls 001 and 002 in Tables 2 and 3 is less than (T ambient 

### + t)

. Therefore, there is no predicted violation of Wate r Quality Standards and an effluent limit is not required.

3. Incremental Warming Criteria – When the cr iterion is exceeded due to natural conditions – At locations and times when a threshold criterion is being exceeded due to natural conditions, all human sources, considered cumulatively, must not warm the waterbody more than 0.3oC above the naturally warm condition. If the am bient temperature (expressed as the 90 th 

### percentile of background temperatures, T ambient90 

### ) is warmer than the threshold criterion, then an incremental warming analysis must be performed.

The T ambient90 

### for the Strait of Georgia in the vicinity of Outfalls 001 and 002 is 11.8 oC, which is less than the threshold temperature criteri on of 13 oC. Therefore, the incremental warming criteria is not applicable.

pH

Because of the high buffering capacity of marine water, compliance with the technology-based effluent limits of 6.0 to 9.0 will assure complian ce with the Water Quality Standards for Surface Waters.

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### Turbidity

The impact of turbidity was evaluated based on the range of turbidity in the effluent and turbidity of the receiving water. Due to the large degree of dilution, it was determ ined that the turbidity criteria would not be violated outside the designated mixing zone.

Toxic Pollutants

Federal regulations (40 CFR 122.44) require NPDES permits to contain effluent limits for toxic chemicals in an effluent whenever there is a reasonable potential for those chemicals to exceed the surface water quality criteria. This process occurs concurrently with the derivation of technology-based effluent limits. Facilities w ith technology-based effluent limits defined in regulation are not exempted from meeting the Water Quality Standards for Surface Waters or from having surface water quality-based effluent limits.

The following toxics were determined to be pres ent in the discharge: ammonia, heavy metals, cyanide, phenols, and trace PAHs. A reasonable potential analysis ( Appendix L) was conducted on these parameters to determine whether or not effluent limitations would be required in this permit.

Valid ambient background data was available for ammonia, total cyanide, fluoride, aluminum, dissolved cadmium, dissolved coppe r, dissolved lead, mercury, and dissolved zinc. Calculations using all applicable data resulted in a determinat ion that there is no reasonable potential for this discharge to cause a violation of water quality standards ( See Appendix L ). This determination assumes that the Permittee meets the other effluent limits of this permit.

Water quality criteria for metals in Chapter 173-201A WAC are based on the dissolved fraction of the metal, except for arsenic and mercury.

Metal criteria may also be adjusted using the wa ter effects ratio approach established by USEPA, as generally guided by the procedures in USEPA Water Quality Standards Handbook , December 1983, as supplemented or replaced.

Ammonia

Ammonia is considered to be a toxic pollutant and was evaluated for reasonable potential to exceed water quality standards. Determining th e site-specific acute a nd chronic criteria for ammonia is slightly more complicated than simp ly obtaining the criteria from the regulations and comparing them to the effluent data. Ammonia's toxicity is dependent on that portion which is available in the unionized form. The amount of unionized ammonia is dependent on the pH, salinity, and temperature of the receiving water in the marine environment. In order to evaluate ammonia toxicity, receiving water information must be used.

One ambient receiving water station was evalua ted to determine the site-specific acute and chronic criteria and to obta in background ammonia data. The Ecology ambient monitoring station GRG002 was used in this analysis. Acut e and chronic ammonia criteria were calculated using Hampson's model in a spreadsheet form. Fr om those criteria, the 90t h percentile value was chosen to represent the critical condition as recommended by the Ecology Permit Writer's Manual. The values for the ambient station and the 90th percentile valu es for background total

Fact Sheet Page 40 of 68 Revised at Permit Issuance 03/15/07 Intalco NPDES Permit (WA-000295-0)

### ammonia concentrations were used in the reasonable potential calculation shown in Appendix L

. With the available dilution, it was determined that there is no reasonable potential for Intalco to exceed water quality standards for ammoni a at the edge of the dilution zone.

W HOLE 

### E FFLUENT 

### T OXICITY


### The Water Quality Standards for Surface Waters requi re that the effluent not cause toxic effects in the receiving waters. Ma ny toxic pollutants cannot be de tected by commonly available detection methods. However, toxicity can be m easured directly by exposing living organisms to the wastewater in laboratory te sts and measuring the response of the organisms. Toxicity tests measure the aggregate toxicity of the whole efflue nt, and therefore this approach is called whole effluent toxicity (WET) testing. Some WET te sts measure acute toxicity and other WET tests measure chronic toxicity.

Acute toxicity tests measure mortality as the signif icant response to the toxi city of the effluent. Dischargers who monitor their wast ewater with acute toxicity test s are providing an indication of the potential lethal effect of the effluent to organisms in the receiving environment.

Chronic toxicity tests measure va rious sublethal toxic responses such as retarded growth or reduced reproduction. Chronic toxici ty tests often involve either a complete life cycle test of an organism with an extremely short life cycle or a pa rtial life cycle test on a cr itical stage of one of a test organism's life cycles. Orga nism survival is also measured in some chronic toxicity tests.

Accredited WET testing laboratories have the pr oper WET testing protocols, data requirements, and reporting format. Accredite d laboratories are know ledgeable about WET testing and capable of calculating an NOEC, LC 50 

### , EC 50 

### , IC 25 

### , etc. All accredited labs have been provided the most recent version of Ecology’s Publication # WQ-R-95-80, Laboratory Guidance and Whole Effluent Toxicity Test Review Criteria which is referenced in the permit. Any Permittee interested in receivi ng a copy of this publication may call the Ecology Publications Distribution Center 360-407-7472 for a copy. Ecology recommends that Permittees send a copy of the acute and chronic toxicity secti ons of their permits to th eir laboratory of choice.

The WET tests for Outfall 001 during effluent ch aracterization indicate that no reasonable potential exists to cause receiving water acute or chronic toxicity (See Appendix M) . The Permittee will not be given an acute or chronic limit for the current discharge configuration at Outfall 001. The permit requires In talco to conduct new characteri zation testing of the combined effluent at Outfall 001 following th e diversion of Outfall 002 and to retest the effluent again prior to application for permit renewal. This additional testing is to de monstrate that acute or chronic toxicity has not increased in the effluent.

If the Permittee makes process or material cha nges which, in Ecology’s opinion, results in an increased potential for effluent toxicity, th en Ecology may require additional effluent characterization in a regulatory or der, by permit modification, or in the permit renewal. Toxicity is assumed to have increased if WET testing c onducted for submission wi th a permit application fails to meet the performance standards in WAC 173-205-020, "whole effluent toxicity performance standard". The Permittee may de monstrate to Ecology that changes have not increased effluent toxicity by performing additi onal WET testing after the time the process or material changes have been made.

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### Acute toxicity of Outfall 002 wa s measured during compliance mon itoring in the previous permit term (See Appendix M) . On five occasions the acute toxicity was found to be at levels that, in accordance with WAC 173-205-050(2)(a), have a r easonable potential to cause receiving water toxicity. An acute toxicity limi t is therefore required. The acute toxicity limit is no statistically significant difference in test organism survival between the acute critical effluent concentration (ACEC), 16.7% of th e effluent, and the control.

The acute toxicity limit is set relative to the zo ne of acute criteria exceedance (acute mixing zone) established in accordance with WAC 173- 201A-400. The ACEC is the concentration of effluent existing at the boundary of the acute mixing zone during critical conditions.

Monitoring for compliance with an acute toxici ty limit is accomplished by conducting an acute toxicity test using a sample of effluent diluted to equal the AC EC and comparing test organism survival in the ACEC to survival in nontoxic cont rol water. The Permittee is in compliance with the acute toxicity limit if there is no statistically significant difference in test organism survival between the ACEC and the control.

Chronic toxicity of Outfall 002 was also measur ed during compliance monitoring in the previous permit term (See Appendix M) . On ten occasions the chronic toxicity was found to be at levels that, in accordance with WAC 173-205-050(2)(a), ha ve a reasonable potentia l to cause receiving water toxicity. A chronic toxicity limi t is therefore required. The chronic toxicity limit is no statistically significant difference in test organism response between the chronic critical effluent concentration (CCEC), 3.0% of the effluent, and the control.

The chronic toxicity limit is se t relative to the mixing zone es tablished in accordance with WAC 173-201A-400. The CCEC is the concentration of effluent existing at the boundary of the mixing zone during critical conditions.

Monitoring for compliance with a chronic toxicity limit is accomplished by conducting a chronic toxicity test using a sample of effluent diluted to equal the CCEC and comparing test organism response in the CCEC to organism response in nontoxic control water. The Permittee is in compliance with the chronic toxicity limit if there is no statistically significant difference in test organism response between the CCEC and the control.

T OXICITY 

### I DENTIFICATION 

### / REDUCTION 

### (TI/RE)

In May 1999, the stormwater discharge from Ou tfall 002 failed the chro nic toxicity testing (WET) required in Condition S3. of the previous pe rmit. Intalco began additional chronic testing in June 1999 per the requirements of WAC 173- 205. The additional chronic testing exhibited toxicity failures. The toxicity failures tri ggered Intalco’s permit requirement to submit a Toxicity Identification/Reduction Evaluation (TI/RE) Plan to Ecol ogy for review and approval. The purpose of the TI/RE Plan was to evaluate a nd determine the source of the toxicity and to identify measures to elimin ate or reduce the toxicity.

The results of Intalco’s Toxicity Identificati on Evaluation (TIE) identif ied aluminum as the source of toxicity with compli cating factors resulting from th e presence of fluoride.

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### Intalco conducted an Initial S ource Assessment Study in response to the TI/RE from January through March 2000. The objectives of the study were to: 1) measure the concentrations of total and soluble aluminum, fluoride, a nd total suspended solids (TSS) in stormwater runoff at various locations, 2) identify the areas that contain pr ocesses which are significant source contributors, 3) determine which areas would benefit from source reduction strategies and/or stormwater treatment, and 4) identify additional sampling studies to better quantify specific source contributions. Intalco conducted a Refined Source Assessment from March 2000 through June 2001 in response to the findings of the Initial Source Assessment.

In response to the TI/RE, Inta lco reviewed and revised their housekeeping best management practices (BMPs) starting in June 2000. The BMPs included incr eased routine sweeping, covering the dross and collector bar storage areas, and instituting annual wet and dry season inspections as described in Section 10 of In talco’s Stormwater Pollution Prevention Plan.

The final report submitted by Intalco in response to the TI/RE is titled “Proposed Stormwater Pond Outfall Changes”, dated October 14, 2003. In this report, Intalco proposed modifying the stormwater discharge outlet to divert stormwat er through Outfall 001. Stormwater flows that exceed the hydraulic capacity of Outfall 001 w ould be discharged through Outfall 002. The Outfall 002 diversion is discussed in mo re detail later in this document.

Ecology has reviewed and approved all of the docu ments related to the TI /RE. Condition S.9 of the previous permit required In talco to implement the BMPs and source reduction methods that were proposed as a result of the TI/RE. The draft permit requires a number of new BMPs to further reduce pollutant loading in the stormwater . Ecology has determined that in addition to stormwater treatment, source control/source reduc tion through BMPs, the diversion of Outfall 002 to Outfall 001 is AKART for the Intalco faci lity. Condition S.1.D of the permit requires Intalco to complete the diversion within two years of the effective date of the permit. Conditions S8. and S9. of the permit require Intalco to recharacterize the effl uent from Outfall 001 for acute and chronic toxicity. These st udies are scheduled to occur af ter the Outfall 002 diversion has been completed and is operationa l to evaluate the impacts of mi xing the effluent from Outfall 002 with effluent from Outfall 001.

C HERRY 

### P OINT 

### H ERRING



### Background Information

Ecology has been working with several stakeholders including other state agencies, area industries, and the tribes (the Cherry Point Technical Workgroup) to investigate the Cherry Point herring decline. Over the past six years, Ecology has worked with Western Washington University’s Shannon Point Marine Center (SPMC) to develop herring tests to evaluate effluent toxicity as a source of the d ecline in the Cherry Point herring and to evaluate risks from industrial discharges to other herring stocks. As a result of these efforts, SPMC developed three herring tests. These three tests are a 96-hour larval acute survival test, a 10-day embryo survival and normal development test, and a 10-day larval survival and growth test. SPMC and a commercial lab, Nautilus Environmental, conducted validation studies of the three herring tests

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### during the 2005 herring spawning se ason. A validation study dete rmines if a lab can get a reasonably consistent answer each time a te st is performed using the same toxicant.

Both labs successfully validated the 96-hour larval acu te survival test and the 10-day embryo survival and normal development test. In N ovember 2005, Ecology approved the regulatory use of these tests. The labs could not completely va lidate the 10-day larval su rvival and growth test, but its partial success and the knowledge gained promise better performance next time.

Ecology has identified a number of other herri ng studies that are impor tant in building on the success of the herring test development. Thes e studies included comparing the herring embryo and larval survival and growth tests with E nvironmental Protection Agency (EPA) tests, an ambient toxicity study, and a temperature tole rance study. These studies and a request for funding were proposed to the Cherry Point Technical Workgroup and several other parties in 2004. No support was offered at that time.

Following the announcement regarding the validati on of the two herring te sts and after review and comment on the permit requirements in Teso ro’s and Intalco’s proposed NPDES permits, several industries approached Ec ology to discuss alternatives to including the validated herring tests in the NPDES permits.

Ecology and the industries discussed further refinement of the larval survival and growth test, validation of this test, and comparisons of the su rvival and growth test and the embryo test to EPA tests. In order to provide an assessment on Cherry Point herring while perfecting the larval survival and growth test and conducting the EPA comparisons, Ecology proposed an ambient toxicity study and temperature to lerance study. Industry agreed to support these studies in lieu of herring studies being included in this NPDES permit term.

Agreed Order Ecology has issued an agreed order with the BP Ch erry Point Refinery, C onocoPhillips Ferndale Refinery, Shell Puget Sound Refinery, Tesoro An acortes Refinery, and th e Alcoa-Intalco Works Aluminum Smelter (Industries) to conduct a dditional herring research and studies.

The Agreed Order (No. 3192) require s the five industries to conduct larval acute su rvival tests twice annually at each of thei r process wastewater and stormw ater outfalls and to provide $227,000 in funding toward: 1) further refinement and validation of the larval survival and growth test, 2) comparisons of herring test sensitivity to surrogate EPA test s, 3) an evaluation of ambient water toxicity at Cherry Point, 4) a temperature tolerance study of embryo s from Cherry Point and two other regional herring stocks, and 5) to ensu re a supply of herring gonads for use in these studies.

The Order also includes a requirement to follo w up on adverse effects f ound during the course of these studies with additional testing and/or inve stigation. Ecology will review the results of the studies required under the Order a nd include validated herring or equivalent EPA surrogate test requirements in the industry Na tional Pollutant Discharge Elimin ation System (NPDES) permits during the next permit cycle.

Fact Sheet Page 44 of 68 Revised at Permit Issuance 03/15/07 Intalco NPDES Permit (WA-000295-0)

### Additional Benefits After further refinement, the larval survival and growth test may be validated and approved for regulatory use. This will provi de another tool for evaluating chronic effects on herring from effluent toxicity and expand the number of availabl e commercial labs that can perform the test. Assuming that the EPA tests are equally or more sensitive than the herring tests, the EPA tests are better for monitoring effluents. The species used in the EPA tests are available year round, the tests can be performed more easil y, and they are more economical.

The ambient toxicity test will help Ecology to eval uate the combined effects of industry effluent plumes on herring embryos. Herring embryos are sensitive to high water temperatures. The temperature tolerance study will help Ecology to determine if water temperatures measured at Cherry Point are high enough to cause a dverse effects on herring embryos.

Herring Toxicity Testing Requirements for Intalco

Under the Agreed Order, Intalco will conduct herring larv al toxicity testing on the final effluent from Outfall 001 twice a year beginning in Ja nuary 2007. Intalco shall also conduct herring larval toxicity testing on the e ffluent from their stormwater ou tfall (002) twice a year beginning in January 2009, if the diversion to Outfall 001 has not occurred.

H UMAN 

### H EALTH


### Washington’s water quality standards now include 91 numeric health-based criteria that must be considered in NPDES permits. These criteria were promulgated for the state by the U.S. EPA in its National Toxics Rule (Federal Regist er, Volume 57, No. 246, Tuesday, December 22, 1992).

Ecology has determined that the Permittee’s effluent is likely to have chemicals of concern for human health. The Permittee's high priority status is based on its status as a major discharger and knowledge of data or process information in dicating that regulated chemicals occur in the discharges from the facility.

A determination of the discharge's potential to cause an exceedance of the water quality standards was conducted as required by 40 CFR 122.44(d) for Outfalls 001 and 002. The reasonable potential determination was evaluate d following procedures in the Technical Support Document for Water Quality-Based Toxics C ontrol (EPA/505/2-90-001 ) and Ecology’s Permit Writer's Manual (Ecology Publication 92-109, July, 1994). The determinati on indicated that the discharges from Outfalls 001 a nd 002 have no reasonable potential to cause a violation of water quality standards, thus an efflue nt limit is not warranted. See Appendix L.

Arsenic

In 1992 the USEPA adopted risk-based arsenic criter ia for the protection of human health for the State of Washington. The criter ion for marine waters is 0.14 μ g/L inorganic arsenic, and is based on exposure from fish and shellfish tissue ingestion. The freshwater criterion is 0.018

μ g/L, and is based on exposure from fish and shel lfish tissue and water ingestion. These criteria have caused confusion in implementation becaus e they differ from the drinking water maximum contaminant level (MCL) of 10 μ g/L, which is not risk-based, and because the human health

Fact Sheet Page 45 of 68 Revised at Permit Issuance 03/15/07 Intalco NPDES Permit (WA-000295-0)

### criteria are sometimes exceeded by natural backgr ound concentrations of arsenic in surface water and ground water.

In Washington, when a natural background concentration exceeds the criterion, the natural background concentration becomes the criterion, a nd no dilution zone is allowed. This could result in a situation where natural groundwater or surface water used as a municipal or industrial source-water would need additiona l treatment to meet numeric effluent limits even though no arsenic was added as waste. Alt hough this is not the case for all dischargers, we do not have data at this time to quantify the extent of the problem.

A regulatory mechanism to deal with the issues associated with natural background concentrations of arsenic in groundwater-deriv ed drinking waters is currently lacking. Consequently, the Water Quality Program, at this time, has decided to use a three-pronged strategy to address the issues associated with th e arsenic criteria. The three strategy elements

are:

1. Pursue, at the national level, a solution to the regulatory issue of groundwater sources with high arsenic concentrations causing m unicipal treatment plant effluent to exceed criteria. The revision of the drinking water MCL for arsenic offered a national opportunity to discuss how drinking water source s can affect NPDES wastewater dischargers, however Ecology was unsuccessful in focusing the discussion on developing a national policy for arsenic regulation that acknowledges the risks and costs associated with management of the public exposure to natural background c oncentrations of arsenic through water sources. The current arsenic MCL of 10 μ g/L could also result in municipal treatment plants being unable to meet criteria-based effluent limits. Ecology will conti nue to pursue this issue as opportunities arise.

2. Additional and more focused data collection . The Water Quality Program will in some cases require additional and more focused arsenic data collecti on, will encourage or require dischargers to test for source water arsenic c oncentrations, and will pursue development of a proposal to have Ecology's E nvironmental Assessment Program conduct drinking water source monitoring as well as some additional ambient monitoring data. At this time, Washington NPDES permits will contain numeric effluent limits for arsenic based only on treatment technology and aquatic life protection as appropriate.

3. Data sharing . Ecology will share data with USEPA as they work to develop new risk-based criteria for arsenic and as they deve lop a strategy to regulate arsenic.

S EDIMENT 

### Q UALITY


### Ecology has promulgated aquatic sediment standa rds (Chapter 173-204 WAC) to protect aquatic biota and human health. These standards state that Ecology may require Permittees to evaluate the potential for the discharge to cause a violation of applicab le standards (WAC 173-204-400).

In September 1999, Intalco conducted a marine se diment sampling and analysis study. The purpose of the Fall 1999 study was to 1) comply with the current NP DES permit sediment monitoring requirements, 2) determine if sedime nt remedial actions were necessary, and 3) evaluate sediment quality concerns related to th e Department of Natural Resources (DNR) lease

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### requirements. To meet these objectives, the study focused on: characterizing chemicals of potential concern (COC), concentrations and biological effects within and adjacent to the NPDES outfall mixing zones, analyzing facility pr ocess indicator chemicals including aluminum, fluoride, and cyanide, and analyzing select samp les for the full suite of Sediment Management Standard (SMS) chemicals.

Sediment was collected and analyzed from depths of 2 cm and 10 cm in order to assess sediment quality in the areas of ongoing disc harge and in the biologically active zone, respectively. COCs were determined to be LPAHs, HPAHs, PCBs, and various semi-volatile organic compounds. The full suite of SMS chemicals were analyzed at stations in areas that had not been previously characterized.

The sediment sampling found Sediment Quality Standard (SQS) and cleanup screening level (CSL) exceedances of both PCBs and PAHs in th e upper 2 cm and the upper 10 cm of sediment. Other chemical exceedances included bis(2-et hylhexylphthalate), di benzofuran, and phenol.

The aluminum, fluoride, and phenol concentrations in the sediment were found to be equivalent to those found in reference samples collected in the Carr Inlet. The levels of phenols are believed to be due to the decomposition of conife rous wastes. Cyanide was not detected in any of the sediments collected during the investigat ion. The detection of chemicals that exceeded SQS chemical criteria was consistent with historical sampling data.

Confirmatory bioassays were performed on the upper 10 cm of samples that exceeded the SQS chemical criteria. No adverse biological effects were found in any of the sediment samples indicating that elevated chemical concentrations in sediments adjacen t to the Intalco facility were not associated with adverse ecological effect s. Under WAC 173-204-310(2), sediment samples that pass all of the confirmatory biological tests are considered to pass sediment quality standards despite any exceedances of chemical standards.

After a review of the chemistry and bioassa y data collected duri ng the 1999 study, Ecology agreed that remedial cleanup action of the sedi ments adjacent to Intalco is not necessary. However, chemical exceedances in surface sedi ments remain a concern. Chemical exceedances in the upper 10 cm near the process and stormw ater outfalls may represent effects from the current discharges or another continuing source and need further investigation. Condition S11. of the permit includes a requirement to submit a Sediment Sampling and Analyses plan to conduct additional sediment sampling and analysis for PAHs, PCBs, aluminum, fluoride, and cyanide. The sediment recharacterization will be required early in the next permit term to evaluate sediment condition following the clean -up and closure of the Beach and Construction Landfills as discussed later in this document.

F UGITIVE 

### A LUMINA 

### I MPACT 

### S TUDY



### Concerns have been raised about the spillage of alumina or e during ship unloading and its possible accumulation in sedime nts around Intalco’s marine terminal. In December 1999, Intalco submitted a notice of construction appli cation requesting approval to upgrade their alumina ore unloading air pollution control system. Ecology reviewed the applicatio n and issued an order of approval to upgrade the control system. After the a pproval order was issued, Intalco

Fact Sheet Page 47 of 68 Revised at Permit Issuance 03/15/07 Intalco NPDES Permit (WA-000295-0)

### determined that their pier was not structura lly able to accommodate the proposed upgrades and the upgrades were not installed.

Since Intalco determined that the control system could not be upgraded, Intalco has made a considerable investment of resources into upgrad ing and maintaining the in tegrity of the seal on the clamshell and into operating the clamshell to minimize fugitive emissions. Intalco has also implemented a number of BMPs to minimize the fugitive emissions. Currently most of the alumina ore fugitive emissions are generated as the clamshell is lifted out of the ships hold. Based on the evaluations that have been made and the results of the BMPs that have been implemented, it is not likely that Intalco will be able to further reduce or eliminate alumina ore fugitive emissions.

Ecology is planning to issue an order by mid-2007 under their air and water quality authorities that will require Intalco to evaluate the potenti al impact of fugitive emissions from alumina ore unloading on sediments near the Intalco pier. If the evaluation determines that there is a significant impact to sediments, Ecology will requ ire Intalco to propose a method(s) to mitigate that impact.

G ROUND 

### W ATER 

### Q UALITY 

### L IMITATIONS


### Ecology has promulgated Ground Water Quality Standards (Chapter 173-200 WAC) to protect beneficial uses of ground water. Permits i ssued by Ecology shall be conditioned in such a manner so as not to allow violations of those standards (WAC 173-200-100).

The stormwater pond is lined with a PVC liner. The sanitary lagoon in Intalco’s wastewater treatment system consists of an unlined native clay bottom that could potentially discharge to ground water.

There is no data available to determine if ther e is a potential for an impact to ground water beneath the sanitary lagoon. As a result Intalc o will be required to submit a ground water impact study plan to be implemented in the third and fourth year of the permit. The plan must include sampling and testing schedules for the sanitary lagoon for all of the para meters included in the groundwater quality standards (GWQ S) (except pesticides, radionuc lides, PBBs and dioxin), and a hydrogeologic investigation to estimate the impact to ground water. If this study determines that there is a potential for th e wastewater in the sanitary la goon to cause an exceedance of the GWQS, Intalco will be required to install monito ring wells to investigat e any actual effects on the ground water.

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### COMPARISON OF EFFLUENT LIMITS WIT H THE EXISTING PERMIT ISSUED ON SEPTEMBER 1, 1998



## Effluent Limitations: Outfall # 001

Existing Permit New Permit Parameter Units

Monthly Average Daily Maximum Monthly Average Daily Maximum

Total Suspended Solids lbs/day

mg/l 150

10 185

-- 150

-- 185

--

Fluoride lbs/day 68 296 68 296

Aluminum lbs/day 10.3 30 10.3 30

Free Cyanide mg/l <0.012 0.012 <0.012 0.012

Benzo(a)Pyrene mg/l <0.01 0.01 0.03 a 

### /0.06 b



### (lb/day) 0.065 a 

### /0.13 b



### (lb/day)

Antimony mg/l NL c 

### NL c 

### 2.85 a 

### /5.7 b 

### (lb/day) 6.4 a 

### /12.8 b 

### (lb/day)

Nickel mg/l NL c 

### NL c 

### 1.25 a 

### /2.5 b 

### (lb/day) 1.85 a 

### /3.7 b 

### (lb/day)

Oil and Grease mg/l 5 10 5 10

pH Within the range of 6.0 - 9.0 Within the range of 6.0 - 9.0

a 

### Permit Limit when aluminum production is less than or equal to 15,614 tons per month
b 

### Permit Limit when aluminum production is greater than 15,614 tons per month

c 

### NL= No Limit



## Effluent Limitations: Outfall # 002

Existing Permit New permit Parameter Units

Monthly Average Daily Maximum Monthly Average Daily Maximum

Total Suspended Solids mg/l 35 75 35 75

Fluoride mg/l 35 50 35 50

Aluminum mg/l 10 15 10 15

Fact Sheet Page 49 of 68 Revised at Permit Issuance 03/15/07 Intalco NPDES Permit (WA-000295-0)

## Effluent Limitations: Outfall # 002

Free Cyanide mg/l -- -- -- -- Benzo(a)Pyrene mg/l -- <0.01 -- <0.01

Oil and Grease mg/l 5 10 5 10

pH Within the range of 6.0 - 9.0 Within the range of 6.0 - 9.0



## Effluent Limitations: Sanitary Lagoon

Existing Permit New permit

Parameter Units 30-Day Average 7-Day Average 30-Day Average 7-Day Average

Biochemical Oxygen Demand mg/l lbs/day 45.0
22.4 65.0
32.4 45.0
22.4 65.0
32.4

Total Suspended Solids mg/l lbs/day 45.0
22.4 65.0
32.4 45.0
22.4 65.0
32.4

Fecal Coliform Colonies/100 ml 200 400 200 400

Chlorine mg/l <0.012 0.012 -- --

Minimum Number of Operating Tubes -- 12

pH Within the range of 6.0 - 9.0 Within the range of 6.0 - 9.0

MONITORING REQUIREMENTS

Monitoring, recording, and reporting are re quired (WAC 173-220-210 and 40 CFR 122.41) to verify that the treatment process is functioning correctly and the effluent limitations are being achieved.

The monitoring schedule is detailed in the permit under Condition S1. Specified monitoring frequencies take into account the quantity and vari ability of the discharge, the treatment method, past compliance, signif icance of pollutants, and cost of monitoring.

Fact Sheet Page 50 of 68 Revised at Permit Issuance 03/15/07 Intalco NPDES Permit (WA-000295-0)

### PERFORMANCE-BASED REDUCTION OF MONITORING FREQUENCIES

EPA published guidance in April of 1996 entitle d, “Interim Guidance for Performance-Based Reduction of NPDES Permit Monitoring Frequencie s”. EPA’s goal is to reduce the regulatory burden associated with reporting and monitoring on the basis of excellent performance. The guidance recommends looking at an d comparing long term average values to permit limits to evaluate a facility’s performance.

Several parameters in Intalco’s treated effluent were evaluated using this guidance. In addition to using the approach recommended in the guidan ce, daily maximum values were also compared with permit limits. Appendix O summarizes the current and pr oposed monitoring frequencies based on two years of representative monitoring data (January 2000 – December 2002).

For the parameters evaluated, Intalco’s monitoring history has demonstrated an ability to consistently meet regulatory limits and knowle dge of the treatment system operation. The proposed monitoring frequencies are based on the guidance recommendations and best professional judgment.

Ecology deviated from the policy recommendations for fluoride and cyanide at Outfall 001 and fluoride and aluminum at Outfall 002 by increa sing monitoring upstream at the secondary treatment plant and the stormwater pond. The monitoring frequencies for antimony and nickel, copper, and oil and grease at Outfall 001 and c opper, cyanide, B(a)P, and oil and grease at Outfall 002 were further reduced because years of monitoring data and other plant knowledge have shown that the sources of these pollutants ei ther no longer exist or have been controlled. More detailed information about these specific po llutants is discussed earlier in this document.

B(a)P Intalco conducted weekly B(a)P monitoring of Outfall 001 from April 1991 through September 1998 and monthly monitoring since October 1998. The Outfall 001 data indicates that B(a)P concentrations have not been above the detec tion limit (0.001 mg/L) since February 1996. Prior to that, there were 10 occasions (between June 1995 and February 1996) when B(a)P was above the detection level (the highest level of B(a)P of those 10 occasi ons was 0.016 lb/day). Using the maximum water flow at Outfall 001 (3.5 million ga llons per day), the 0.001 mg/L concentration translates to a long term aver age (LTA) of 0.03 lb/day, which is 100% of the proposed monthly average permit limit (0.03 lb/day when production is less than or equal to 15,614 tons per month) and 50% of the proposed monthly average permit limit (0.06 lb/day when production is greater than 15,614 tons per month). The highest level (0.016 lb/day) reported is 25% of the proposed daily maximum permit limit (0.065 lb/day when pr oduction is less than or equal to 15,614 tons per month) and 12% of the proposed daily ma ximum permit limit (0.13 lb/day when production is greater than 15,614 tons per month).

Ecology determined a monitoring frequency of on ce per month and once per quarter at Outfall 001 for B(a)P based on the previous monitoring fre quency (once per month) and the ratio of the LTA to the proposed monthly average permit limits for both tiers as outlin ed in EPA's "Interim Guidance for Performance-Based Reduction of NP DES Permit Monitoring Frequencies" dated April 1996 (EPA’s Guidance). In EPA’s Guidan ce, the 100% ratio of LTA to the proposed monthly average limit for B(a)P when production is less than or equal to 15,614 tons per month requires monitoring once per month. The 50% ratio of LTA to the proposed monthly average

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### limit for B(a)P when production is greater than 15,614 tons per month requires monitoring once per quarter. Because there have been no incident s of B(a)P reported above the detection level of 0.0001 mg/l since March 2005, Ecology determined th at requiring monitoring once per quarter is appropriate.

Antimony and Nickel As discussed earlier in “ TECHNOLOGY-BASED EFFLUENT LIMITATIONS”, Ecology added mass-based limits (at Outfall 001) for antimony and nickel to this permit. Ecology reviewed the historical antim ony and nickel data collected from 1988-1998 at Outfall 001. The table below provides a frequency dist ribution of that data. The data indicates that a significant amount of the total nickel and antimony in the effl uent comes into the plan t in the water supplied by the Public Utility District. The LTA of antimony (0.206 lb/day) is 7% of the proposed monthly average permit limit (2.85 lb/day when pr oduction is less than or equal to 15,614 tons per month) and 4% of the proposed monthly av erage permit limit (5.7 lb/day when production is greater than 15,614 tons per mont h). The highest level reported (0.375 lb/day) is 6% of the proposed daily maximum permit limit (6.4 lb/day wh en production is less th an or equal to 15,614 tons per month) and 3% of the proposed daily maximum permit limit (12.8 lb/day when production is greater than 15,614 tons per month).

The LTA of nickel (0.198 lb/d ay) is 16% of the proposed m onthly average permit limit (1.25 lb/day when production is less than or equal to 15,614 tons per month) and 8% of the proposed monthly average permit limit (2.5 lb/day when production is greater than 15,614 tons per month). The highest level reported (0.646 lb/day ) is 35% of the proposed daily maximum permit limit (1.85 lb/day when production is less than or equal to 15,614 tons per month) and 17% of the proposed daily maximum permit limit (3.7 lb /day when production is greater than 15,614 tons per month). In the last 2 years of data collection ( 1997 and 1998), the highest level of nickel reported (0.256 lb/day ) is 14% of the proposed daily maximum permit limit.

Ecology determined a monitoring frequency of once every 6 months for antimony and nickel based on the previous monitoring frequency (onc e per month in the permit cycles during 1988- 1998 - summarized in the table below) and the ra tio of the LTAs to the monthly average permit limits (<25%) as outlined in EPA's Guidance.

Frequency Distribution of Antimony and Nickel Daily Mass Discharge Data (1988-1998)
Metal Concentration Range Effluent Nickel Influent Nickel Effluent Antimony Influent Antimony
0.0-0.2 lb/day 174 195 121 50 0.2-0.4 lb/day 88 87 159 236
0.4-0.6 lb/day 14 4 0 0
0.6-0.8 lb/day 4 0 0 0
0.8-1.0 lb/day 0 0 0 0



### Fact Sheet Page 52 of 68 Revised at Permit Issuance 03/15/07 Intalco NPDES Permit (WA-000295-0)

### ACTION LEVELS FOR POLLUTANTS DI SCHARGED FROM THE STORMWATER POND AND THE SECONDARY WAST EWATER TREATMENT SYSTEM

Ecology established “action levels” in the permit fo r TSS, fluoride, and aluminum discharged in the stormwater pond (SWP) effluent and for T SS and fluoride discharged in the Secondary Wastewater Treatment System effl uent. These action levels were placed in the permit to ensure that the Permittee is consistently implementi ng the required BMPs designed to reduce or eliminate the respective pollutants, evaluating the cause of any upward trends in pollutant discharges, and taking corrective action to reverse those trends. Ecology determined the action levels for the SWP and the SWTS based on an analysis of the 2003 and 2004 monthly monitoring data submitted by the Permittee in their discharge monitoring reports (DMRs).

When action levels are exceeded at the SWP, the Permittee must review BMPs, check for spills to the stormwater system, and check ditches an d weir integrity and placement. When action levels are exceeded at the SWTS, the Permittee must review BMPs, check addition rates of treatment chemicals, and influent flows and loading.

LANDFILL MONITORING

Intalco signed an Agreed Order with Ecology for the remedial investigation and feasibility study of three historic landfills on its property in Ferndale, Washington under the Model Toxics Control Act (MTCA). The three landfills -- known as Beach One, Beach Two, and the Construction Debris Landfill -- were used fr om 1965 until the 1970s and early 1980s to dispose of industrial solid waste generate d at the Intalco plant. The landfills are located on bluffs above the Straight of Georgia.

The Agreed Order required Intalco to determine the volume and type of material found in each landfill and to characterize any su rface or ground water contamination from the landfills. This information was used as the basis for evaluating the different cleanup methods that were most appropriate for the site. The cleanup plan for th e site was to remove the debris from the two Beach Landfills on the bluffs and place it in th e permitted hazardous and solid waste landfill (Spent Potliner (SPL) Landfill) on the Intalco property and to close and cap the Construction Debris Landfill in place. The landfills were cl eaned up and closed in the summer and fall of 2006 under a Consent Decree issued by Ecology.

Intalco stopped using the landfil ls in 1984 and closed them by placing soil covers over the debris. Intalco has been monitoring seeps located in the hillside below the closed landfills since 1985. While there has been no dete rmination of an immediate thre at to human health or the environment from contaminants leaving the site, in November 1999, tests at three landfill monitoring stations (Outfalls 003, 004, and 005) i ndicated contaminants from the landfills may be leaching into surface water runoff.

The results of the November 1999 monitoring as co mpared to current stormwater limits and the marine water quality standards are shown in Appendix N . The majority of the results exceed both stormwater limits and surface water quality standards.

Fact Sheet Page 53 of 68 Revised at Permit Issuance 03/15/07 Intalco NPDES Permit (WA-000295-0)

### Intalco excavated and rem oved all waste materials and contaminated native soils from the Beach I and Beach II Landfills and inst alled an impermeable cap on the Closed Construction Debris Landfill. Ecology determined that this aggressi ve source control is AKAR T for the discharges from Outfalls 003, 004, and 005. Additional monitoring of these discharges will be conducted in accordance with the Consent Decree issued by Ecology.

The NPDES permit includes new monitoring requir ements at the Secondary Treatment Plant to test for PCBs and priority pollutant metals in the leachate from the SPL Landfill. Groundwater monitoring is required in the cons ent decree as part of the MTCA cleanup to evaluate impacts to groundwater from the closed landfills.

STORMWATER POND MONITORING

Condition S1.C of the permit requi res Intalco to monitor the stormwater pond effluent whenever the average 2-hour flow from the stormwater pond is > 3.7cfs (with a maximum required frequency of 3 days per week). Intalco determ ined, based on the result s of their Stormwater Pond Characterization Study, that the minimum rain fall that occurs befo re significant flow begins at compliance point D-10 is about 0.05 inches of rainfall or 0.20 million gallons, which is one-tenth of the design storm volume. A volum e of 0.20 million gallons is equal to a 3.7 cfs flow rate over a two hour time in terval. After evaluati ng Intalco’s precipitation data for January 2002 through September 2004, Ecology determined that a stormwater pond monitoring frequency based on the threshold volume of 3.7 cfs would be sufficient.

Intalco will be expected to maintain historic performance levels to c ontinue to receive the reduced monitoring. If the performance levels of the facility deteriorate, monitoring frequencies will revert to the frequencies in the current permit.

EFFLUENT LIMITS BELOW QUANTITATION

The water quality-based effluent limits for cyanide in the wastewater are be low the capability of current analytical technology to quantify. The Quantitation Level is the level at which concentrations can be reliably reported with a specified level of error. For maximum daily effluent limits, if the measured effluent concentration is below the Quantitation Level, the Permittee reports NQ for non-quantifiable. For av erage monthly effluent limits, all effluent concentrations below the Quantitation Level but above the Method Detection Level are used as reported for calculating the average monthly value.

EFFLUENT LIMITS BELOW DETECTION

The Method Detection Level (MDL) is the minimu m concentration of an analyte that can be measured and reported with a 99 pe rcent confidence that its concentr ation is greater than zero as determined by a specific laboratory method. For ma ximum daily limits, if the concentrations are below the MDL the Permittee reports ND for non-detectable. For averag e monthly limits, all values above the MDL are used as reported and a ll values below the MDL ar e calculated as zero.

Fact Sheet Page 54 of 68 Revised at Permit Issuance 03/15/07 Intalco NPDES Permit (WA-000295-0)

### LAB ACCREDITATION

With the exception of certain parameters the permit requires all monitoring data to be prepared by a laboratory registered or accredited under the provisions of Chapter 173-50 WAC, Accreditation of Environmental Laboratories. The Intalco laboratory is currently accredited for:

Chloride SM4500-Cl E

Chlorine Residual, Total SM4500-Cl G

Cyanide, Total EPA335.3

Cyanide, Weak Acid Dissociable SM4500-CN I

Fluoride SM4500-F E

Hexane Extractable Material EPA1664

pH SM4500-H

Solids, Total Suspended SM2540 D

Specific Conductance EPA120.1

Sulfate SM4500-SO4 F

Aluminum EPA200.7, EPA6010

Calcium EPA200.7, EPA6010

Copper EPA200.7, EPA6010

Potassium SM3500-K B

Sodium EPA200.7, EPA6010

OTHER PERMIT CONDITIONS

OUTFALL 002 DIVERSION

Permit Condition S1.D requires Intalco to construc t a diversion structure so that nearly all stormwater would discharge through Outfall 001 (process water outfall) rather than Outfall 002 (the existing stormwater outfall). Only stormwat er flows in excess of the hydraulic capacity of Outfall 001 would be discharged through Outfall 002. It is pr edicted that a discharge of stormwater through Outfall 002 would occur very infrequently, approximately once every five years or less. This discharge would take plac e during a high volume short duration rain event, typically during winter or spring months.

Fact Sheet Page 55 of 68 Revised at Permit Issuance 03/15/07 Intalco NPDES Permit (WA-000295-0)

### As discussed elsewhere in the fact sheet, Intalco has a histor y of toxicity problems in the discharge from Outfall 002. The sources of many of these problems have been corrected and will continue to be addressed by implementing and following BMPs at the smelter. However, the location of the Outfall 002 structure is an ong oing concern; it currently discharges to fairly shallow water and is not equipped with a diffuse r. Stormwater discharged through Outfall 002 has the potential to cause toxicity and temperature impacts in the receiving water despite Intalco’s ability to comply w ith permit limits and water quality standards at the edge of the mixing zone.

Receiving water temperature and toxicity are of particular concern because of the presence of Cherry Point herring. Cherry Poin t herring have historically spawned in the vicinity of and at the depth of the discharge of Outf all 002. The Cherry Point herr ing’s rate of development is temperature dependent and there has been a demonstrated increase in receiving water temperature in their spawning areas.

Cherry Point herring populations are currently rebounding after bei ng severely depressed to near extinction. The receiving water en vironment needs to be properly managed so that the herring stock continue to increas e their numbers and have every chance to rebuild.

Ecology has determined that the best way to mini mize potential toxicity and temperature impacts in the receiving water is to require Intalco to implement additional BMPs and to divert the Outfall 002 discharge through Outf all 001. Outfall 001 is in d eeper water and discharges through a diffuser away from the herring spawning habitat. It has better dilution within the mixing zone so discharging stormwater from Outfall 002 to Outfall 001 will provide greater water quality protection.

Following the diversion, monitoring will continue at the outlet of the stormwater pond to ensure the effectiveness of upstream treatment. The pe rmit specifies action levels for the stormwater discharge at which Intalco will be required to investigate potential problems and take corrective action as necessary. The permit also requires m onitoring for any discharges at Outfall 002 after the diversion.

TEMPORARY CURTAILMENT

A condition is included in the permit allowing th e Permittee to petition for reduced monitoring and the suspension of studies and certain permit requirements during temporary curtailment of smelter operations.

REPORTING AND RECORDKEEPING

The conditions in S2. of the permit are based on the authority to specify any appropriate monitoring, reporting and recordkeeping requiremen ts to prevent and control waste discharges (WAC 173-220-210).

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### OPERATION AND MAINTENANCE MANUAL

In accordance with state and federal regulations, the Permittee is required to take all reasonable steps to properly operate and maintain their wastewater treatment sy stems (40 CFR 122.41(e)) and WAC 173-220-150 (1)(g). An operation and maintenance (O & M) manual was submitted as required by state regulation fo r the construction of wastewater treatment facilities (WAC 173- 240-150). Intalco is required to update the O&M manual (per Condi tion S3 of the permit) to include changes made to the PWTS, the SWTS, a nd the anode cooling water treatment system as described in Condition S10 of the permit. It has been determined that the implementation of the procedures in the O & M manual and Treatment Sy stem Operating Plan is a reasonable measure to ensure compliance with the te rms and limitations in the permit.

SOLID WASTE PLAN

Ecology has determined that the Permittee has a poten tial to cause pollution of the waters of the state from leachate of solid waste.

This permit requires, under the authority of RCW 90.48.080, that the Permittee update the solid waste plan designed to prevent solid waste from cau sing pollution of the wate rs of the state. The plan must be submitted to the local permitting ag ency for approval, if necessary, and to Ecology.

The Permittee shall not allow leachate from its solid waste material to ente r state waters without providing all known, available, and reasonable met hods of treatment, nor allow such leachate to cause violations of the State Surface Water Qual ity Standards, Chapter 173-201A WAC, or the State Ground Water Quality Standards, Chapte r 173-200 WAC. The Permittee shall apply for a permit or permit modification as may be required for such discharges to state ground or surface

waters.
The Permittee shall manage the pile of furnace bric k from the anode plant located adjacent to the solid waste landfill in accordan ce with the management plan required by the Whatcom County Health Department. The management plan sha ll emphasize recycling as much of the brick as possible and disposing of the remai nder in the on-site landfill.

NON-ROUTINE AND UNANTICIPATED DISCHARGES

Occasionally, this facility may ge nerate wastewater which is not characterized in their permit application because it is not a routine discha rge and was not anticip ated at the time of application. This wastewater is typically water used to pressure test storage tanks or fire water systems or leaks from drinking water systems. It is typically clean but may be contaminated with pollutants. The permit contains an au thorization for non-rout ine and unanticipated discharges. The authorization re quires prior characterization of these wastewaters for pollutants and examination of the opportunitie s for reuse. Depending on the na ture and extent of pollutants in this wastewater and opportunities for reuse, Ecology may authorize a direct discharge via the process wastewater outfall or through a stormwater outfall for clean water, require the wastewater to be placed through th e facilities wastewater treatment process, or require the water to be reused.

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### SPILL PLAN

Ecology has determined that the Permittee stores a quantity of chemicals th at have the potential to cause water pollution if accide ntally released. Ecology has the authority to require the Permittee to develop best management plans to prevent this accidental release under section 402(a)(1) of the Federal Water Polluti on Control Act (FWPCA) and RCW 90.48.080.

The Permittee has developed a plan for preventing the accidental release of pollutants to state waters and for minimizing damages if such a spill occurs. The permit requires the Permittee to update this plan and submit it to Ecology.

TREATMENT EFFICIENCY STUDIES

P RIMARY 

### W ASTEWATER 

### T REATMENT 

### S YSTEM 

### (PWTS) A ND 

### S ECONDARY 

### W ASTEWATER 

### T REATMENT 

### S YSTEM 

### (SWTS)

Intalco is required to operate pr ocess wastewater treatment systems according to procedures and criteria described in an operating plan. Th e previous permit required Intalco to update and maintain operational plans onsite for the process wa stewater treatment systems. Intalco’s PWTS is a clarifier that is used to treat the wastewat er from the wet air polluti on control system (wet scrubbers). The Secondary Wastewater Treatme nt System (SWTS) is comprised of several treatment tanks and a clarifier. The wastewater from the PWTS and landfill leachate is treated through chemical precipitation a nd sedimentation in the SWTS.

Condition S10.A. of the permit re quires Intalco to update thei r O&M Plan to include their operational plan for the PWTS. Condition S10.B . requires Intalco to conduct a treatment efficiency study on the SWTS to determine if it meeting the design criteri a and to propose and implement any changes needed to upgrade the system.

A NODE 

### C OOLING 

### W ATER



### Anode contact water is generated during the anod e production process. This wastewater is filtered through a screen before it is commingled with other treated wastewaters and discharged through Outfall 001.

Ecology is requiring Intalco (Condition S10.C of th e permit) to complete a study of the anode contact cooling water filtration system to determin e if it meets AKART standards. If the system does not meet AKART, Intalco will be required to upgrade the system to AKART standards.

OUTFALL EVALUATION

In accordance with Condition S.6 of the previous permit, Intalco conducted an underwater inspection of Outfalls 001 and 002 in June 1999. Overall, both outfalls were in good condition. No significant damage or deterioration to th e pipes was found. At Outfall 001, the clamp bolts located at Bent 64 were loose and the vertical support rod on Bent 65 was malfunctioning due to a failed weld at the pipe clamp connection. Inta lco replaced the bolts on the pipe clamp at Bent

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### 64 and the support rod at Bent 65 and removed ma rine organisms fouling the diffuser openings during the scheduled pier maintenance program in 2000.

Condition S12. in the permit requires the Permittee to conduct an outfall inspection once per permit cycle and submit a report detailing the findings of that inspection. The purpose of the inspection is to determine the c ondition of the discharge pipe and diffusers and to evaluate the extent of sediment accumulations in the vicinity of the outfall.

BEST MANAGEMENT PRACTICES AND ST ORMWATER POLLUTI ON PREVENTION PLAN

Condition S14.A. of the permit lists BMPs that will help to furthe r reduce or eliminate pollutants in the process and stormwater that is discha rged to Outfalls 001 and 002, respectively. Permit Condition S14.B., requires Intalco to dem onstrate compliance with these BMPs or submit a compliance schedule to implement these BMPs in the Stormwater Pollution Prevention Plan. Intalco identified the listed BMPs in their Stor mwater Pollution Prevention Plan and in their Stormwater Runoff Study Final Report (in th e sections titled “As-Built Pond Engineering Report”, “Site Hydrologic Characterization”, Ra infall Characterization”, “Stormwater Model”, and “Stormwater Pond Characterization”) submitte d in compliance with Conditions S.9 and S.11 of the previous permit.

The stormwater BMPs required in the permit gene rally fall into two categories, non-capital and capital improvements. Non-capital improvements are BMPs that eliminate or minimize exposure of stormwater runoff to pollutants. Th ese BMPs include good housekeeping, preventive maintenance, inspections, sediment/erosion control, employee training, spill prevention and cleanup measures. Capital improvements are BMPs which prevent runoff from contacting storm water or which contain/divert/tre at contaminated stormwater di scharges so that they do not impact surface waters. These BMPs require capital expenditures and include detention/retention ponds, berms, treatment systems, covering sy stems, and stormwater diversions.

GENERAL CONDITIONS

General Conditions are based directly on state an d federal law and regulations and have been standardized for all individual industr ial NPDES permits issued by Ecology.

PERMIT ISSUANCE PROCEDURES

PERMIT MODIFICATIONS

Ecology may modify this permit to impose numeri cal limitations, if neces sary to meet Water Quality Standards for Surface Waters, Sediment Qu ality Standards, or Water Quality Standards for Ground Waters, based on new information obt ained from sources such as inspections, effluent monitoring, outfall studie s, and effluent mixing studies.

Ecology may also modify this permit as a result of new or amended state or federal regulations.

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### RECOMMENDATION FOR PERMIT ISSUANCE

This permit meets all statutory requirements for authorizing a wastewater discharge, including those limitations and conditions believed necessa ry to control toxics, protect human health, aquatic life, and the beneficial uses of waters of the St ate of Washington. Ecology is recommending that this permit be issued for (5) years.

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### REFERENCES FOR TEXT AND APPENDICES Cosmopolitan Engineering Group. 2006. Intalco Aluminum Corporat ion - Outfalls 001 and 002 Dilution Ratio Study , revised November 2006.

Crecelius, E. 2000. Concentration of Metals in Marine Wa ter and Effluent of the Alcoa Intalco Works

. Battelle Marine Scie nces Laboratory, April 2000.

Environmental Protection Agency (EPA)

1992. National Toxics Rule. Federal Register, V. 57, No. 246, Tuesday, December 22, 1992.

1991. Technical Support Document for Wa ter Quality-based Toxics Control . EPA/505/2- 90-001.

1985. Water Quality Assessment: A Screening Procedure for Toxic and Conventional Pollutants in Surface and Ground Water . EPA/600/6-85/002a.

1983. Water Quality Standards Handbook. USEPA Office of Water, Washington, D.C.

Tsivoglou, E.C., and J.R. Wallace.

Washington State Department of Ecology.

1994. Permit Writer’s Manual . Publication Number 92-109

Washington State Department of Ecology.

Laws and Regulations( http://www.ecy.wa.gov/laws-rules/index.html )

Permit and Wastewater Related Information ( http://www.ecy.wa.gov/program s/wq/wastewater/index.html

Wright, R.M., and A.J. McDonnell.

Fishcher, H.B., E.F. List, R.C.Y. Koh, J. Im berger, and N.H. Brooks, 1979. Mixing in Inland and Coastal Waters, Academic Press, Inc., Ha rcourt Brace Jovanovich Publishers, New York NW, pp. 126-127.

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### APPENDIX A--PUBLIC INVOLVEMENT INFORMATION

The Department has tentatively determined to reissue a permit to the Intalco Aluminum Corporation. The permit contains conditions and effluent limitations that are described in this fact sheet.

The Department will publish a Public Notice of Draft (PNOD) on May 11, 2005 in the Bellingham Herald and the Ferndale Westside Record Journal to inform the public that a draft permit and fact sheet are available for review. Interested persons are invited to submit written comments regarding the draft permit. The draft permit, fact sheet, and related documents are available for inspection and copying between th e hours of 8:00 a.m. and 5:00 p.m. weekdays, by appointment, at the Ecology office listed below. Written comments should be mailed to:

Judy Schwieters Department of Ecology Industrial Section P.O. Box 47706 Olympia, WA 98504-7706

Any interested party may comment on the draft pe rmit or request a public hearing on this draft permit within the sixty (60) day comment period. All comments and requests for a hearing must be submitted in writing to the address above by the 5:00 p.m.on Monday July 11, 2005. The request for a hearing shall indi cate the interest of the party and reasons why the hearing is warranted. The Department will hold a hearing if it determines there is a significant public interest in the draft permit (WAC 173-220-090). Public notice regardi ng any hearing will be circulated at least thirty (30) da ys in advance of the hearing. Peopl e expressing an interest in this permit will be mailed an individual notice of hearing (WAC 173-220-100).

Comments should reference specific text follo wed by proposed modification or concern when possible. Comments may address technical i ssues, accuracy and completeness of information, the scope of the facil ity’s proposed coverage, adequacy of environm ental protection, permit conditions, or any other concern that woul d result from issuance of this permit.

The Department will consider all comments received within thirty (30) days from the date of public notice of draft indicated above, in formulating a fina l determination to issue, revise, or deny the permit. The Department's response to all significant comme nts is available upon request and will be mailed directly to peopl e expressing an interest in this permit.

Further information may be obtained from th e Department by telephone, (360) 407-6955, or by writing to the address listed above.

This permit and fact sheet were written by Liem Nguyen and Judy Schwieters.
Update : Public Notice Published: May 11, 2005
Public Comment Period: May11, 2005 through July22, 2005

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### APPENDIX B--GLOSSARY

Acute Toxicity --The lethal effect of a compound on an or ganism that occurs in a short period of time, usually 48 to 96 hours.

AKART -- An acronym for “all known, available, and reasonable methods of treatment”.
Ambient Water Quality --The existing environmental conditi on of the water in a receiving water body.

Ammonia --Ammonia is produced by the breakdown of nitrogenous materials in wastewater. Ammonia is toxic to aquatic organisms, exerts an oxygen demand, and contributes to eutrophication. It also increases the amount of chlorine needed to disinfect wastewater.
Average Monthly Discharge Limitation --The average of the measured values obtained over a calendar month's time.
Best Management Practices (BMPs) --Schedules of activities, prohibitions of practices, maintenance procedures, and other physical, struct ural and/or managerial practices to prevent or reduce the pollution of waters of the State. BMPs include treatment systems, operating procedures, and practices to control: plant s ite runoff, spillage or leaks, sludge or waste disposal, or drainage from ra w material storage. BMPs ma y be further categorized as operational, source control, erosion and sediment control, and treatment BMPs.

BOD 5 

### --Determining the Biochemical Oxygen Demand of an effluent is an indirect way of measuring the quantity of organic ma terial present in an effluent that is utilized by bacteria. The BOD 5 

### is used in modeling to measure the reduction of dissolved oxygen in a receiving water after effluent is discharged. Stress cau sed by reduced dissolved oxygen levels makes organisms less competitive and less able to sustai n their species in the aquatic environment. Although BOD is not a specific compound, it is defi ned as a conventional pollutant under the federal Clean Water Act.
Bypass --The intentional diversion of waste stream s from any portion of a treatment facility.

Chlorine --Chlorine is used to disinfect wastewaters of pathogens harmful to human health. It is also extremely toxic to aquatic life.

Chronic Toxicity --The effect of a compound on an orga nism over a relatively long time, often 1/10 of an organism's lifespan or more. Chr onic toxicity can measure survival, reproduction or growth rates, or other parameters to measure the toxic effects of a compound or combination of compounds.
Clean Water Act (CWA) --The Federal Water Pollution Control Act enacted by Public Law 92- 500, as amended by Public Laws 95-217, 95-576, 96-483, 97-117; USC 1251 et seq.
Compliance Inspection - Without Sampling --A site visit for the purpose of determining the compliance of a facility with the terms and conditi ons of its permit or with applicable statutes and regulations.

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### APPENDIX B—GLOSSARY (CONTINUED)

Compliance Inspection - With Sampling --A site visit to accomplish the purpose of a Compliance Inspection - Without Sampling and as a minimum, sampling and analysis for all parameters with limits in the permit to asce rtain compliance with those limits; and, for municipal facilities, sampling of influent to ascertain compliance with the 85 percent removal requirement. Additional sampling may be conducted.
Composite Sample --A mixture of grab samples collected at the same sampling point at different times, formed either by continuous sampling or by mixing discrete samples. May be "timecomposite"(collected at constant time intervals) or "flow-proportional" (collected either as a constant sample volume at time intervals pr oportional to stream fl ow, or collected by increasing the volume of each aliquot as the flow increased while maintaining a constant time interval between the aliquots.
Construction Activity --Clearing, grading, excava tion and any other activity which disturbs the surface of the land. Such activities may include road building, constr uction of residential houses, office buildings, or industria l buildings, and demolition activity.

Continuous Monitoring –Uninterrupted, unless otherw ise noted in the permit.

Critical Condition --The time during which the combination of receiving water and waste discharge conditions have the highest potential for causing toxicity in the receiving water environment. This situation usually occurs wh en the flow within a water body is low, thus, its ability to dilute effluent is reduced.

Dilution Factor --A measure of the amount of mixing of e ffluent and receiving water that occurs at the boundary of the mixing zone. Expressed as the inverse of the percent effluent fraction e.g., a dilution factor of 10 m eans the effluent comprises 10 % by volume and the receiving water 90%.
Engineering Report --A document which thoroughly ex amines the engineering and administrative aspects of a particular domestic or industrial wastewater facility. The report shall contain the appropriate informati on required in WAC 173-240-060 or 173-240-130.

Fecal Coliform Bacteria --Fecal coliform bacteria are used as indicators of pathogenic bacteria in the effluent that are harmful to humans. Pa thogenic bacteria in wast ewater discharges are controlled by disinfecting the wastewater. Th e presence of high numbers of fecal coliform bacteria in a water body can indicate the recent release of untreated wastewater and/or the presence of animal feces.
Grab Sample --A single sample or measurement taken at a specific time or over as short period of time as is feasible.

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### APPENDIX B—GLOSSARY (CONTINUED)

Industrial Wastewater --Water or liquid-carried waste from industrial or commercial processes, as distinct from domestic wastewater. These wastes may result from any process or activity of industry, manufacture, trade or business, from the developmen t of any natura l resource, or from animal operations such as feed lots, poultry houses, or dairies. The term includes contaminated storm water and, also, l eachate from solid waste facilities.
Major Facility-- A facility discharging to surface water w ith an EPA rating score of > 80 points based on such factors as flow volume, toxic pollutant potential, and public health impact.
Maximum Daily Discharge Limitation --The highest allowable dail y discharge of a pollutant measured during a calendar day or any 24-hour period that reas onably represents the calendar day for purposes of sampling. The daily discharg e is calculated as the average measurement of the pollutant over the day.
Method Detection Level (MDL)-- The minimum concentration of a substance that can be measured and reported with 99% confidence that the analyte concentration is above zero and is determined from analysis of a sample in a given matrix containing the analyte.
Minor Facility-- A facility discharging to surface water with an EPA rating score of < 80 points based on such factors as flow volume, toxic pollutant potential, and public health impact.
Mixing Zone --An area that surrounds an effluent disc harge within which wa ter quality criteria may be exceeded. The area of the authorized mi xing zone is specified in a facility's permit and follows procedures outlined in st ate regulations (Cha pter 173-201A WAC).
National Pollutant Discharge Elimination System (NPDES) --The NPDES (Section 402 of the Clean Water Act) is the Federal wastewater pe rmitting system for discharges to navigable waters of the United States. Many states, in cluding the State of Washington, have been delegated the authority to issue these permits . NPDES permits issued by Washington State permit writers are joint NPDES/ State permits issued under both State and Federal laws.
pH --The pH of a liquid measures its acidity or alkalinity. A pH of 7 is defined as neutral, and large variations above or below this value ar e considered harmful to most aquatic life.
Quantitation Level (QL)-- A calculated value five times the MDL (method detection level).

Practical Quantitation Limit (PQL) -- is the lowest level that can be reliably achieved within sp ecified limits of precision and accuracy during routine laboratory operating conditions. The PDL is a calculated value that is five times the MDL (method detection level).
Responsible Corporate Officer -- A president, secretary, treasure r, or vice-president of the corporation in charge of a principal busine ss function, or any other person who performs similar policy- or decision-mak ing functions for the corporati on, or the manager of one or more manufacturing, production, or operating facilities employing more than 250 persons or have gross annual sales or expenditures ex ceeding $25 million (in second quarter 1980 dollars), if authority to sign documents has b een assigned or delegated to the manager in accordance with corporate procedures (40 CFR 122.22).

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### APPENDIX B—GLOSSARY (CONTINUED)

Technology-based Effluent Limit --A permit limit that is based on the ability of a treatment method to reduce the pollutant.
Total Suspended Solids (TSS) --Total suspended solids is the particulate materi al in an effluent. Large quantities of TSS discharged to a receiv ing water may result in solids accumulation. Apart from any toxic effects attr ibutable to substances leached out by water, suspended solids may kill fish, shellfish, and other aquatic organisms by causing abrasive injuries and by clogging the gills and respiratory passages of various aquatic fauna. Indirectly, suspended solids can screen out light and can promote and maintain the development of noxious conditions through oxygen depletion.

State Waters --Lakes, rivers, ponds, streams, inland wate rs, underground waters, salt waters, and all other surface waters and watercourses within the jurisdiction of the state of Washington.

Stormwater --That portion of precipitation that does not naturally percolate into the ground or evaporate, but flows via overland flow, interflow, pipes, and other features of a storm water drainage system into a defined surface water body, or a constructed infiltration facility.
Upset --An exceptional incident in which there is unintentional and temporary noncompliance with technology-based permit effluent limitati ons because of factors beyond the reasonable control of the Permittee. An upset does not include noncompliance to the extent caused by operational error, improperly designed treatment f acilities, lack of preventative maintenance, or careless or improper operation.
Water Quality-based Effluent Limit --A limit on the concentration of an effluent parameter that is intended to prevent the concentration of th at parameter from exceeding its water quality criterion after it is discharged into a receiving water.

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### APPENDIX C--TECHNICAL CALCULATIONS

Several of the Excel ® 

### spreadsheet tools used to evaluate a discharger’s ability to meet Washington State water quality standards can be found on the Department’s homepage at http://www.ecy.wa.gov/programs/wq/wastewater/index.html.

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### APPENDIX D—RESPONSE TO COMMENTS

APPENDIX E—MAP OF DISCHARGE LOCATIONS

APPENDIX F—SUMMARY OF NONCOMPLIANCE

APPENDIX G—DISCHARGE MONITORING SUMMARY

APPENDIX H—WASTEWATER CHARACTERIZATION

APPENDIX I—COPPER MONITORING RESULTS

APPENDIX J—MIXING ZONE ANALYSES

APPENDIX K—TEMPERATURE ANALYSIS

APPENDIX L—REASONABLE POTENTIAL TO EXCEED (AQUATIC LIFE CRITERIA AND HUMAN HEALTH) ANALYSES FOR OUTFALL 001

APPENDIX L—REASONABLE POTENTIAL TO EXCEED (AQUATIC LIFE CRITERIA AND HUMAN HEALTH) ANALYSES FOR OUTFALL 002

APPENDIX M—ACUTE AND CHRONIC WET TEST RESULTS FOR OUTFALLS 001 &002

APPENDIX N—LANDFILL MONITORING RESULTS

APPENDIX O—PERFORMANCE BASED REDUCTION OF MONITORING FREQUENCIES

Fact Sheet Page 68 of 68 Revised at Permit Issuance 03/15/07 Intalco NPDES Permit (WA-000295-0)% multiplier Cost Note

Capital Costs Purchased Equipment Costs

capital costs 51,187,853 $

CEMS 40,000 $ one SO2 CEM system
instrumentation 5% 2,561,393 $ scaled back from 10% CC Manual since basic inst is include d in proposal
sales tax 8.20% 4,200,684 $ State 6.5% plus local 1.7% freight 5% 2,561,393 $ CC Manual

PEC 60,551,322 $

Installation Costs
foundations 12% 7,266,159 $

erection 80% 48,441,058 $ Cost manual default is 40%.
electical 1% 605,513 $ piping 30% 18,165,397 $
inslulation 1% 605,513 $ field painting 1% 605,513 $

TIC 75,689,153 $

Indirect Costs engineering 5% 3,027,566 $ Cost manual 10%, but bid includes some engineering expe nses construction 10% 6,055,132 $ EPA Region 10 - High

Vendor #1 dual-absorber capital cost, scaled to single absorb er cost based on
Vendor #2

construction 10% 6,055,132 $
contractor fees 5% 3,027,566 $

start-up 1% 605,513 $ performance test 1% 605,513 $ contingencies 3% 1,816,540 $ aquatic studies 235,000 $ Nov 16, 18, and 22 conversations with Kyle Murphy, WA DN R
PUD water connection fee 300,000 $ 12/8/11 conversation with Stephan Jilk, Whatcom PUD

Total Indirect Cost 15,672,831 $

Total Capital Investment Cost (TCIC) 151,913,306 $

Capital Recovery

Interest rate 7% Equipment lifetime 30 Capital cost recovery factor 0.0806 Calculated via Equation 1.34 in the EPA CC Manual Annual Capital cost 12,242,147 $

Annual Costs

Direct Annual Costs Operating labor Operator 37.00 $ 324,120

$ Supervisor 15% 48,618 $ one full time operator, 3 shifts/day

Cost manual 10%, but assumes scrubber vendor will overse e scrubber installation and include in capital of equipment

Supervisor 15% 48,618 $

Water
Cost 0.00070 $ $/gal 12/8/11 conversation with Stephan Jilk, Whatcom PUD Quantity 500,000 Gal/day Pre Feasibility
Annual cost 127,750 $

Limestone usage, tons/yr 14,244.00 Limestone cost/ton 33.00 $
Annual Limestone cost 470,052 $

Compressed air
Plant cost 0.24 $ $/1000 scfm Quantity 150.00 scfm
Annual cost 18,922 $

Gypsum disposal
Generation rate 6,194.00 lb/hr 27,130 ton/yr Cost disposal $/ton nonhazardous solid waste, including transportation
Annual cost

- $

Maintenance Labor 45.00 $ 673,920

$

Materials 1,303,000 $

Elctricity 4 full time maintenance personnel, one shift/day, 5 days/w eek and 1 maintenance personnel for all other shifts

Required 7,400.00 KWh/hr Pre Feasibility report

Cost 0.05

$ $/kWh 2007 cost per Intalco
Total Cost 3,409,742

$

Total Direct Annual costs 6,376,124 $

Indirect Annual Costs
Overhead 60% 1,409,795 $ CC Manual, section 2.5.5.7
General and Administrative 2% 3,038,266 $ CC Manual, section 2.5.5.7 Property Tax 1% 1,519,133 $ CC Manual, section 2.5.5.7

Insurance 1% 1,519,133 $ CC Manual, section 2.5.5.7

Total Indirect Annual Costs 7,486,327 $

Total Annual O&M Costs 13,862,451 $

Total Annual Costs 26,104,598 $

SO X Reduction 5983 Assuming 2 week annual shutdown and bypass emissions $/ton of SO X 4,363 $% multiplierCostNoteCapital CostsPurchased Equipment Costscapital costs51,187,853$CEMS40,000$one SO2 CEM systeminstrumentation5%2,561,393$scaled back from 10% CC Manual since basic inst is included in proposalsales tax8.20%4,200,684$State 6.5% plus local 1.7%freight5%2,561,393$CC ManualPEC60,551,322$Installation Costsfoundations12%7,266,159$erection40%24,220,529$Cost manual default is 40%.electical1%605,513$piping30%18,165,397$inslulation1%605,513$field painting1%605,513$TIC51,468,624$Indirect Costsengineering5%3,027,566$Cost manual 10%, but bid includes some engineering expensesconstruction10%6,055,132$EPA Region 10 - LowVendor #1 dual-absorber capital cost, scaled to single absorber cost based on Vendor #2construction10%6,055,132$contractor fees5%3,027,566$start-up1%605,513$performance test1%605,513$contingencies3%1,816,540$aquatic studies235,000$Nov 16, 18, and 22 conversations with Kyle Murphy, WA DNRPUD water connection fee300,000$12/8/11 conversation with Stephan Jilk, Whatcom PUDTotal Indirect Cost15,672,831$Total Capital Investment Cost (TCIC)127,692,777$Capital RecoveryInterest rate7%Equipment lifetime30Capital cost recovery factor0.0806Calculated via Equation 1.34 in the EPA CC ManualAnnual Capital cost10,290,302$Annual CostsDirect Annual CostsOperating laborOperator37.00$324,120$Supervisor15%48,618$Cost manual 10%, but assumes scrubber vendor will oversee scrubber installation andinclude in capital of equipmentone full time operator, 3 shifts/daySupervisor15%48,618$WaterCost0.00070$$/gal12/8/11 conversation with Stephan Jilk, Whatcom PUDQuantity500,000Gal/dayPre FeasibilityAnnual cost127,750$Limestone usage, tons/yr14,244.00Limestone cost/ton33.00$Annual Limestone cost470,052$Compressed airPlant cost0.24$$/1000 scfmQuantity150.00scfmAnnual cost18,922$Gypsum disposalGeneration rate6,194.00lb/hr27,130ton/yrCost disposal$/tonnonhazardous solid waste, including transportationAnnual cost-$MaintenanceLabor45.00$673,920$Materials1,303,000$Elctricity4 full time maintenance personnel, one shift/day, 5 days/week and 1 maintenancepersonnel for all other shiftsRequired7,400.00KWh/hrPre Feasibility reportCost0.05$$/kWh2007 cost per IntalcoTotal Cost3,409,742$Total Direct Annual costs6,376,124$Indirect Annual CostsOverhead60%1,409,795$CC Manual, section 2.5.5.7General and Administrative2%2,553,856$CC Manual, section 2.5.5.7Property Tax1%1,276,928$CC Manual, section 2.5.5.7Insurance1%1,276,928$CC Manual, section 2.5.5.7Total Indirect Annual Costs6,517,506$Total Annual O&M Costs12,893,630$Total Annual Costs23,183,932$SOXReduction5983 Assuming 2 week annual shutdown and bypass emissions$/ton of SOX3,875$Attachment 12 - EPA Region 10 LSFO Capital Cost Scaling Summary TableReagent FeedSystem10% 0.33 $6,500,000 $8,200,000 $7,350,000 $7,894,009 $6,981,097SO2 RemovalSystem35% 0.5 $22,750,000 $28,700,000 $25,725,000 $28,543,995 $25,242,988Flue Gas System 30% 0.5 $19,500,000 $24,600,000 $22,050,000 $24,466,281 $21,636,847By-productHandling System10% 0.4 $6,500,000 $8,200,000 $7,350,000 $8,104,759 $7,167,474General SupportEquipment15% 0.15 $9,750,000 $12,300,000 $11,025,000 $11,436,638 $10,114,034$65,000,000 $82,000,000 $73,500,000 $80,445,682 $71,142,440Clean flue gas flow(acfm)Gypsum production(tpa)Gypsum production(tpa)ScrubberComponentFraction ofTotalEquipmentCostScalingEquationExponentLimestoneconsumption (tpa)Clean flue gas flow(acfm)Scaling ParameterScaled Average ofVendor #1 andVendor #2 Quotes(Environ)Scaled Vendor #1Quote (EPARegion 10)Tennessee Potline Scrubber Equipment CostsVendor #1QuoteVendor #2QuoteAverage

### INTALCO FGD GYPSUM MARKET REVIEW ‐ FINAL

1 

# MARKET REVIEW
FOR 

# INTALCO PRODUCED FGD GYPSUM

Elliot Rosenberg, Senior Economist March 23, 2012

### INTALCO FGD GYPSUM MARKET REVIEW ‐ FINAL

2 

### Premise: Starting about 2017 the proposed installation of scrubbers at Alcoa’s Intalco aluminum smelting fa cility at Ferndale Washington would become operational. A by-pro duct of the scrubbers’ operation at full capacity would be an esti mated 27,000 tons of FGD gypsum annually. The estimated cost for the disp osal of this FGD gypsum at a permitted
landfill is estimated to be $145 per ton (equal to $3.915 million annually).

Task: As a possible lower cost alternative to landfill disposal -
A. Determine if there wo uld be a market for Intalco’s FGD

gypsum. If there is a market - B. Can this FGD gypsum be sold at a lower cost than would be incurred for landfill disposal?

SUMMARY

As a result of continuing disc ussions with EPA Region 10 concer ning the treatment of sulfur dioxide (SO 2 

### ) being emitted from Intalco’s Ferndale Washington aluminum smelting facility (“Intalco”, “the Ferndale fac ility”) through the inst allation of scrubbers, gypsum would be produced as a by-product through a process known as Flu Gas Desulfurization (FGD). Gypsum produced through this process is referred to as FGD gypsum, s ynthetic gypsum, or syn-gyp. FGD gypsum is one of two primary sources of gypsum; the other gypsum source is from mining and is referred to as mined gypsum, crude gypsum or ra w gypsum. Intalco’s consu ltant estimates that when the Ferndale facility is operating at full capacity approximately 27,000 tons of FGD gypsum would be produced a nnually, starting about 2017.

Since disposal of this Intalco’s FGD gypsum at a permitted landfill is relatively costly, and these landfill disposal costs significantly impact the standard air quality cost effectiveness for the proposed scrubbers 1 

### , the issue for this review was to determ ine if a market could potentially exist for this FGD gypsum. In their cost effectivene ss analysis for the proposed scrubber Intalco’s consultant assumed disposal costs of $145 per to n including transportation (Environ 2007), equal to more than $3.9 million annually operating at full capacity. For this review from a cost effectiveness perspective a viable market alte rnative to landfill disposal means Intalco’s alternative ‘disposal’ cost should be less than $145 per t on, i.e., less than the disposal cost at a landfill. Ideally this mean s Intalco would be able to sell its FGD gypsum for a net profit or at least break-even. The price Intalco offers for its FGD gypsum, i.e., the company’s sale price,

1 

### In determining the cost effectiveness of this project proposal, the analysis uses annualized capital costs, and the project’s annual O&M (operating and maintenance) costs.

### INTALCO FGD GYPSUM MARKET REVIEW ‐ FINAL

3 

### would be FOB the Ferndale facility 2 

### . The final price would be ne gotiated between Intalco and the buyer.

Indentifying a prospective mark et (or markets) for Intalco’ s FGD gypsum starting about 2017 infers several conditions, e.g.,
- there would exist one or more co mmercial applications for FGD gypsum - the end-user for this FGD gypsum would likely exist within a r easonable distance of the Ferndale facility, implying transportation co sts could be an important consideration for the sale of Intalco’s FGD gypsum
- Intalco is able to attract a buyer (or buyers) at its FOB price, and - Intalco would be able to secure a long -term contract (e.g., 10 years or more duration)

Within the confines of this review a pros pective market for Intalco’s FGD gypsum was determined by identifying current uses for FG D gypsum, relevant supply and demand issues, relevant prices, and some market trends. While there are numerous commercial uses for FGD gypsum, a large percentage of current FGD gypsum is used in the production of wallboard, and the next largest use thou gh a distant second is in the production of cement.

One fundamental issue is whether Intalco can sell into the FGD gypsum market. This means identifying supply side issues that can impact a buyer’s decision to purchase Intalco’s FGD gypsum. Assuming that all FGD gypsum is of equa l or very similar quality, and prospective buyers are free to purchase FGD gypsum without any constraints 3 

### , it is necessary to determine the size of the FGD gypsum market (production a nd use), preferably a geographically relevant market, and understanding Intalco’ s annual production of FGD gypsum as a percentage of total FGD gypsum production and use, again preferably within our geographic region. One problem is that relevant geographic data can be difficult or impossible to obtain. This means that a geographically broader perspective w ould be the only option available, 4 

### but the resulting data could be less relevant for identifying the pr ospective market for Intalco’s FGD gypsum. Based on broader geographic data, the most current da ta (for 2011) indicates that Intalco’s annual estimated annual production of 27,000 tons of FGD gypsum would equal about 0.000084% of total annual U.S. production (oth er things held constant).

Using the available though limited information, and in consideration of: th e current overall U.S. gypsum market; the potentially increasing dema nd for FGD gypsum for wallboard production, cement and agricultural markets; th e potential for Intalco’s FGD gypsum to be sold as either as a non-calcined or calcined product – where the latter produc t sells at a significantly higher price

2 

### FOB = Free on Board. Defined here where the buyer pays for the FGD gypsum and loading at the Ferndale facility. The buyer is then responsible for transportation to the buyer’s site, and unloading costs. If Intalco pays the loading
cost, then this cost could be reflected in Intalco’s FOB price.

3 

### That is, buyers are not locked into long

‐ term agreements, or there is excess demand amongst buyers who are already locked into contracts for the supply of FGD gypsum.
4 

### For government reported statistics, where only one or several entities exist and could therefore be easily identified with the disclosure of their respective data, then by necessity that data then has to be aggregated to a larger geographic region (i.e., the inclusion of additional data), thereby obviating the possibility of identification of the source or sources of this data.

### INTALCO FGD GYPSUM MARKET REVIEW ‐ FINAL

4 

### compared to the former; the considerable pr ice differential between crude gypsum and FGD gypsum, the latter selling at a significant disc ount to crude gypsum; and the relatively small though consistent (prospective) s upply of Intalco FGD gypsum as a share of the total market -
leads me to conclude there coul d be a prospective market or markets for Intalco’s FGD gypsum. Even at an FOB price of $0.00 – in effect the FGD gypsum was free and the buyer only paid for loading 5 

### (and transportation) - Inta lco would still realize considerable savings compared to incurring the landfill disposal related costs.

MARKET REVIEW

This review relied on readily available informati on from several sources in order to determine if there is a prospective market for Intalco’s FGD gypsum, starting about 2017. An important consideration to keep in mind is that this mark et determination is forecasted for a period starting about five years out and car ries with it typical cav eats, primarily the issue of forecast reliability. Any forecast at this time is base d on best professional judgment.

Primary Reliance on Two Analytical Approaches The review primarily re lied on two approaches: - fundamental analysis : defined here as the study of ba sic, underlying factors that will affect the supply and dema nd of the commodity (CFTC 2011) - trend analysis : the study of the general direction of commodity pr ices, quantities, and other relevant commodity and market statistics over time – used as a method for generally forecasting those relevant elements

Fundamental Analysis of the FGD Synthetic Gypsum Market

The Market

The FGD Gypsum Market by Use FGD gypsum has many diverse appl ications in the U.S. market (FGDProducts.org), for example in:

 

### Wallboard

o 

### Regular

o 

### Sheathing

o 

### Soffit board

 

### Water resistant gypsum

 

### Cement

 

### Lath

 

### Wood chip boards

 

### Structural Fill

 

### Mining Applications

5 

### Or if Intalco paid for loading, then the FOB price would be: FOB = loading cost per ton

### INTALCO FGD GYPSUM MARKET REVIEW ‐ FINAL

5 o 

### Neutralization or encapsulation of acid-producing materials

o 

### Barrier to acid mine drainage formation

o 

### Alkaline amendment to neutra lize acid-producing rock

o 

### Subsidence control in underground mines

 

### Soil amendment

 

### Synthetic soil component

 

### Set retarder in portland cement

 

### Plaster

 

### Agriculture

o 

### Acid soil amelioration

o 

### Sodic soil reclamation

o 

### Surface crust reduction

o 

### Runoff and erosion reduction

o 

### Feedlot surface st abilization

o 

### Fertilizer

 

### Glass Making

 

### Pigments and/or Fillers

Examples of more esoteric applic ations for gypsum include its use in:

 Tofu

 Home brew

 Foot creams, shampoos, and other hair products

 Shi Gao 6



### Identifying Realistic Markets for Intalco’s FGD Gypsum One consideration in determining a realistic market for Intalco’s FGD gypsum is the ability
of that market to absorb Intalco’s entire annual pr oduction of FGD gypsum on an ongoing and consistent periodic basis . Maximum annual FGD gypsum production was estimated by Intalco’s consultant at 27,000 tons per ye ar (EPA 2012), or 2,250 tons per month. This annual production estimate is based on all three potlines at the Ferndale facility being in operation, starting about 2017. 7 

### Other assumptions include: - electric power costs remain relatively constant 8 

### - there will be limited (though unknown at this time) storage ca pacity at the Ferndale facility for the FGD gypsum produced. This will determine the minimum frequency for shipping out the FGD gypsum, and - FGD gypsum will be produced by the Ferndale facility at a uniform rate throughout the

year.

6 

### Certain gypsum used as a component in traditional Chinese medicine.

7 

### Of course if operating at less than full capacity, then annual FGD gypsum would be less than the 27,000 tons per
year. This factor would have to be taken into consideration with any contractual obligation.

8 

### Electric power accounts for approximately 27% of Alcoa’s primary aluminum production costs, of which Alcoa generates approximately 23% of the power used at its smelters worldwide.(Alcoa 2010, p.15) With respect to the Intalco smelter, Alcoa and BPA signed a contract providing for the sale of power that ended May 26, 2011, with a provision for a 5

‐ year extension if certain financial tests can be met. If this renewal was taken up then it provides the Intelco facility with power price stability at least up to about the time syn

‐ gyp would start being produced.(Alcoa 2010, p.16)

### INTALCO FGD GYPSUM MARKET REVIEW ‐ FINAL

6 

### Therefore, under these assumptions th e market must be able to absorb all of the Ferndale facility’s FGD gypsum production.

So while FGD gypsum has many applications, it re mains to identify a market or markets that can (prospectively) readily absorb all of In talco’s annual production of FGD gypsum. This means understanding certain market conditions, e.g.: - who are the ‘players’ in the FGD gypsum market, i.e., producers and buyers - overall future FGD gypsum pr oduction vis-à-vis future demand - Intalco’s annual FGD gypsum production vis-à-vis total national annual FGD gypsum

use - at a minimum there is no substantive quality difference in FGD gypsum produced by Intalco and other FGD gypsum producers, and perhaps Intalco’s FGD gypsum is of a higher quality – and is that relevant - to what extent, if any, does the market address any differences between FGD gypsum (calcined and non-calcined) and crud e gypsum – by price, by application? - there should be no barriers to market entry for Intalco’s FGD gypsum - recognizing the role transportation costs c ould play in determining the competitiveness of Intalco produced FGD gypsum. 9



### - to what extent can relevant market cond itions be identified with respect to Intalco’s geographic preferences

Gypsum Produced Production statistics developed by the U.S. G.S. do not actually reflect total U.S. production, since the synthetic gypsum (i.e., F GD gypsum) statistic for production is defined as ‘sold or used - not produced’. As s hown in Table 1 estimat ed 2011 annual use of synthetic gypsum (FGD gypsum) was 12,125,300 short tons. 10 

### . Assuming the same annual use for 2017, Intalco’s annual production of 27,000 tons would equal 0.22% of estimated total annual use of FGD gypsum in the U.S.! The American Coal Ash Association’s (ACAA) conservative estimate for 2010 F GD gypsum production is 22,000,000 short tons (ACAA 2010). 11 

### Assuming this figure remains constant through 2017, Intalco’s annual production would amount to no more than 0.12% of total annual U.S. production of FGD gypsum !

Another factor to be consid ered is the location of gypsum production. As shown in the U.S.G.S. section, while it appears no substantia l amount of gypsum is produced in the greater Pacific Northwest region (e.g. Washington, Idaho, and Oregon, Montana), FGD gypsum is produced at the Trans Alta power generation plant in Centralia. The company’s website says that it sold 89,100 metric tons of FGD gypsum in 2002 (T rans Alta 2012). Though the

9 

### One factor In Intalco’s favor is that one or more railroad sidings already exist at the Ferndale facility, thereby facilitating facility access for railroad bulk carriers.

10 

### Converted from 11,000 metric tons as shown in Table 1.

11 

### The actual annual coal derived FGD gypsum production is actually much greater since ACAA indicates that its

survey data represent about 67% of the coal

‐ fueled electric generation as reported to the EIA (Energy Information Agency).

### INTALCO FGD GYPSUM MARKET REVIEW ‐ FINAL

7 

### company will shut down one boiler by December 2020 and its se cond boiler by December 2025 (EPA 2012b), this factor would not appear to have any positive impact for Intalco’s market entry around 2017, though it could possibly have a meaningful positive impact subsequent to the boiler shutdowns.

Price Table 1 shows f.o.b. price estimates for gypsym . These price estimates indicate important
differentials between non-cal cined crude, non-calcined synt hetic, and calcined crude and synthetic. Note there is a substantial pr ice differential between non-calcined crude (i.e., mined) and non-calcined synthetic, estimat ed to be between $3.63 to $5.44 per short ton. 12 

### (Table 1) The primary reason is in produc tion costs between crude and FGD gypsum. The former requires a considerable investment and ongoing expense for the specific purpose of mining gypsum, while the latter is produced as a by-product from a process used to improve air quality from certain sources . Hence, there is no direct cost incurred for the production of FGD gypsum (other than storage and handlin g). If this spread between FGD gypsum and crude gypsum prices remains about the same by 2017, this means that FGD gypsum, including Intalco’s FGD gypsum, would have a real competitive advantage over crude gypsum based on f.o.b. prices. Another signif icant cost for a buyer of gypsum f.o.b. the gypsum producing facility is the shipping cost . So if a buyer of FGD gypsum can obtain its gypsum from Ferndale as a sour ce that is closer than any ot her FGD gypsum source, then the prospective buyer would presumably pay less for transportation. Sin ce Intalco would be looking to move its FGD gypsum in the market place, it would be looking at minimizing its FOB price in order to encourage a buyer to purchase its FGD gypsum, which concurrently minimizes Intalco’s ‘dispos al’ cost below $145 per ton.

Demand Also notice in Table 1 the price different ial between non-calcined gypsum (synthetic and crude), and calcined gypsum. The FOB 13 

### plant price for calcined gypsum is estimated at $27.22 per short ton in 2011, compared to an es timated FOB plant price for non-calcined of $0.91 to $2.72 per short ton; a price differe ntial of $24.50 to $26.31 pe r short ton. Because calcined gypsum contains about one-quarter the moisture of non-calcined gypsum, shipping costs are lower. Also, (certain) buyers may pref er calcined gypsum as a more usable product. Calcined gypsum could be used directly as is, or water can always be added back in to meet that user’s requirements. Should the propos ed Intalco scrubber project proceed, whether
Intalco sells non-calcined or calcined FGD gypsum would depend on the buyer’s requirement and whether producing calcined gypsum makes business sense.

12 

### It is my understanding (at this time) that there are no material differences between crude gypsum and syn

‐ gyp.
13 

### There are a number of ways to abbreviate Free on Board: FOB, F.O.B., f.o.b., etc. U.S.G.S. prefers f.o.b.

### INTALCO FGD GYPSUM MARKET REVIEW ‐ FINAL

8 

### Wallboard Market Based on the ACAA data, gypsum panel product s (e.g., wallboard, etc.) consume about 72% of (coal based) FGD gypsum; cement related uses about 11%; and agri culture about 4.5% (ACAA 2010). 14 

### These three markets are the focus of this review.

The U.S.G.S. expert indicated that though there was a decline in wallboard production starting about 2008 (Table 1), subsequently th ere has been a somewh at slow increase in wallboard production primarily tied to the hous ing market (ACAA 2010). At this time it is not known if there are any wallboard producers in the greater Pacific Northwest region. If there are, then their proximity to the Ferndale facility could indicate a prospective market for Intalco’s FGD gypsum.

Local Cement Market With respect to prospective users of syn-gyp in the region, there are at least four and possibly more cement kilns in the region (EPA, 2012): est. gypsum use*

 Ash Grove Seattle, WA: 750,000 tons c linker per year 37,500 tons/yr



###  LaFarge Seattle, WA: 425,000 tons clinker per year 21,250 tons/yr



###  Ash Grove Durkee, OR: 940,000 tons clin ker per year 47,000 tons/yr



###  Vancouver BC: there may be several cement kilns in the BC area



### __________ * For Portland cement production, the ratio is 95% clinker, 5% gypsum (EPA 2012; Taylor et al 2006).



### Any of these cement kiln operators could be prospective sources for Intalco’s FGD

gypsum. 15



### Agriculture Markets Gypsum is used as an agricultural amendm ent (Chen and Dick 2011). Gypsum application on a variety of crops has demonstr ated increased crop yield with no tillage when compared to crops grown without gypsum using conve ntional tillage.(Chen and Dick 2011, p.24) Increased crop yield where other farm costs re main constant or are reduced means increased crop revenue, i.e., more income for the farmer. Chen and Dick indicate that “ The costs associated with using gypsum, including F GD gypsum, includes the costs of purchasing the material, transporting it from the site of generation to the site of use, and spreading it on the land. The benefits are most often associated with increased crop yields.(p.24) 

### Gypsum as an agricultural amendment is most applicable to more arid lands, for example East ern Washington, Eastern Oregon, and parts of Idaho.(EPA 2012c) Given their relative proximity to the Ferndale facility; (perhaps) relatively low transportation costs from the Ferndale facility to a primary farm production facility such as a farmers’ cooperative depot 16 

### in these geographic areas; and the prospect of (relatively) low or lower cost gypsum from Intalco, agricultura l applications

14 

### Mining Applications account for 7.8% of FGD Gypsum production. This was not followed for this review as a prospective market for Intalco’s syn

‐ gyp.
15 

### Again assuming these facilities are not locked into marketing agreements that would preclude purchases of

gypsum from other sources.
16 

### A quick look at BNSF’s website indicates that the company is able to ship bulk fertilizer. It appears the Ferndale facility already has one or more rail sidings.

### INTALCO FGD GYPSUM MARKET REVIEW ‐ FINAL

9 

### in these areas could provide a prospective market for Intalco’s FGD gypsum. Since Intalco must dispose of its FGD gypsum on a consta nt amount schedule throughout the year and crops are cyclical, identifying an agricultural market or markets is an issue further study. Intalco’s relatively small annual production may also make it easier for the company to sell to a niche geographic agricultural market.

U.S.G.S. Derived Statistics The following was modified from the U.S.G. S. Gypsum Mineral Commodity Summaries for 2012, except where noted.

Domestic Production and Use: In 2011, domestic production of crude gypsum was estimated to be 9.4 million metric tons ( 10,361.6 short tons), with a value of about $65.9 million. The leading crude gypsum-producing Stat es were, in descending order, Oklahoma, Texas, Iowa, Nevada, and California, whic h together accounted for 58% of total output. Overall, 47 companies produced gypsum in the United States at 54 mines and plants in 34 States. Approximately 90% of domestic consumption, which totaled approximately 23 million metric tons (25.4 short tons) was accounted for by manufacturers of wallboard and plaster products; approximately 1.3 million me tric tons (1.4 million short tons) for cement production and agricultural ap plications, and small amounts of high-purity gypsum for a wide range of industrial pro cesses accounted for the remaini ng tonnage. At the beginning of 2011, the production capacity of operating wallboard plants in the United States was about 27 billion square feet1 per year.

Table 1 Gypsum Production, Consumption and Prices (1 metric ton = 1.1023 short tons) source: U.S.G.S.



### Salient Statistics—United States: 2007 2008 2009 2010 2011e Production (million metric tons ): Crude 15,700 12,300 10,400 8,840 9,400 Synthetic 2 

### 8,370 9,660 8,120 10,700 11,000 Calcined 3 

### 21,700 17,900 13,800 12,100 12,100 Wallboard products sold (million s.f 1 

### ) 27,800 20,700 18,300 17,200 16,900 Imports, crude, including anhydrite 9,390 7,330 4,220 3,330 3,300 Consumption, apparent 4 

### 33,300 29,100 22,600 22,500 23,400 Price: Average crude, FOB mine, dollars/mt 7.50 8.70 8.50 6.90 7.00 FOB mine, dollars/st 6.35 Average calcined 5 

### , FOB plant, dollars/mt 38.30 42.60 35.00 29.70 30.00 FOB plant, dollars/st 34.75 38.65 31.75 26.94 27.22 Non-calcined synthetic, FOB plant 6 

### , dollars/mt 1 – 3 FOB plant, dollars/st 0.91 – 2.72



### __________ e = Estimated. 1. The standard unit used in the U.S. wallboard industry is square feet. Multiply square feet by 9.29 x 10-2 to convert to square meters. 2. Data refer to the amount sold or used, not produced. 3. From domestic crude and synthetic. 4. Defined as crude production + total synthetic reported used + imports – exports. 5. Calcined gypsum contains about 1⁄2 molecule of water; non-calcined about 2 molecules of water. 6. Estimate provided by U.S.G.S. expert.

### INTALCO FGD GYPSUM MARKET REVIEW ‐ FINAL

10 

### Intalco’s Cost and In come from FGD Gypsum Disposal or Sale Assuming Intalco is able to sell its FGD gypsum into the marketpla ce, and based on the 2011 FOB prices paid for FGD gypsum in short tons (Tab le 1), the financial return to Intalco would be
as follows:

Table 2 Cost/Income from the Disposal a nd Sale of Inta lco FGD Gypsum

- Does not include storage and related handling costs - (see Table 1 for prices) Total Annual Syn-gyp cost = - $
Annual Production income = +$

Landfill Disposal, dollars per short ton 145 27,000 - $3,915,000 Sale of Intalco FGD gypsum: FOB Ferndale facility, dollars per short ton 0.00 27,000 $ 0 FOB Ferndale facility, dollars per short ton 0.91 27,000 + $24,570 FOB Ferndale facility, dollars per short ton 2.72 27,000 + $73,440 FOB Ferndale facility, dollars per short ton 27.22 27,000 + $734,940 17



### Table 2 clearly shows that selli ng its FGD gypsum at any price, even at zero dollars, is preferable to the $3.915 million annual cost In talco would incur for landfill disposal. 18 

### The 27,000 tons per year annual production of syn-gyp reflects the Ferndale facility operating all three of its potlines at full capacity 19



### .

Conclusion

This conclusion is based on the best information available at this time. Additional information that could have proved useful includes: regiona l/local gypsum related market costs and prices [e.g., transportation costs for shipping Intalco’ s FGD gypsum by bulk carrier (rail and road) to some representative locations (e.g., Tacoma, Portland, Eastern Washi ngton, Eastern Oregon, Idaho, etc.); regional use (consumption) of gyps um; regional market prices for FGD gypsum; and a more detailed study of the regional gypsum market related issues (e.g., the type of gypsum

17 

### Actual income would be less since the costs associated with treating the syn

‐ gyp to produce calcined syn

‐ gyp would have to be taken into consideration.

18 

### It is recognized that whether Intalco disposes of the syn

‐ gyp at a landfill or by selling it FOB Ferndale facility, adequate storage must be available to allow for shipment of the syn

‐ gyp on a regular schedule. Presumably that storage cost and the associated costs for loading equipment was included in the consultant’s $145/ton estimate for disposal, and would be similar when selling the FGD gypsum. These costs are not including in the Table 2
income calculations when the FGD gypsum is sold.

19 

### It should be noted that aluminum smelting capacity at the Ferndale facility could be reduced, concurrently reducing the quantity of syn

‐ gyp produced and Intalco’s disposal costs or sales income

– though capital costs would remain constant.

### INTALCO FGD GYPSUM MARKET REVIEW ‐ FINAL

11 

### preferred by potential buyers). That stated, at this time there appear to be a number of issues that point positively to a prospective market for Intalco’s FGD gypsum:

 Intalco’s estimated annual FGD gypsum produc tion is extremely small compared to the overall domestic gypsum market (though it is not known what the total gypsum use is within this region, a mo re realistic indicator). This means Intalco does not have to locate buyers who only require suppliers who can provide huge quantities of

gypsum.

 Intalco would not necessarily have to sell its FGD gypsum at the general market price because Intalco, at a minimum, would be able to sell its syn-gyp at a cost that allows it to only cover its on-site handling and stor age (i.e., break-even) – or perhaps even at a cost lower than $145 per ton.

 The general market price for FGD gypsum is considerably lower than that for crude gypsum, thereby giving FGD gypsum, Intalc o’s product, a competitive advantage when selling into the market.

 Calcined gypsum commands significantly more than non-calcined gypsum. This could prospectively provide a considerably greater return for Intalco (though it is not known at this time if there is a regional market for calcined gypsum, and whether the seller or buyer performs the calcination process).

 The wallboard market is gradually recove ring as reflected in the improving housing
market.

 Agriculture could provide a real market for Intalco’s FGD gypsum, where that agriculture market’s proximity to Ferndale translates into lower transportation costs, and Intalco’s ability to provide low priced FGD gypsum could translate into a further incentive for farmers to purcha se the company’s FGD gypsum.

 The Ferndale facility already has a railro ad siding, i.e., access to the BNSF mainline
and routes north/south and east.

 The Ferndale facility is relatively close to I5, facilitating easy road transport as a possible shipping method.

 Other than TransAlta, Intalco appears to be the only prospective supplier of FGD gypsum in this region.

Keeping in mind the caveats previously mentioned, particularly the issues with forecasting and the limited local market information, it appears th ere could be a market or markets for Intalco’s FGD gypsum starting about 2017, and that any pri ce Intalco receives from a buyer or buyers, even if that buyer only pays for loading and transportation, and maybe not even for loading, would substantially reduce the financial burden for Intalco compared to paying for landfill disposal costs at or near $145 per ton.



# * * * * *

### INTALCO FGD GYPSUM MARKET REVIEW ‐ FINAL

12 

### References

ACAA – American Coal Ash Association. 2010. ACAA CCP Survey Results. Annual surveys available from 2000 through 2010. http://acaa.affiniscape.com/displa ycommon.cfm?an=1&subarticlenbr=3

ALCOA. 2010. 2010 Annual Report and Form 10-K.

CFTC – Commodity Futures Tr ading Commission. 2011. Glossary. http://www.cftc.gov/ConsumerProtection/E ducationCenter/CFTCGlossary/index.htm

Chen, Liming and Warren A. Dick. 2011. “Gypsum as an Agricultural Amendment: General Use
Guidelines”. The Ohio Stat e University. Bulletin 945.

Environ. 2007. Bart Determination for Alcoa Inta lco Works, Ferndale, Washington . ENVIRON Corporation, Emeryville, California. November 2007. http://www.ecy.wa.gov/programs/ air/globalwarm_RegHaze/BART/ IntalcoBARTDeterminationFINAL.pdf

EPA. 2008. Agricultural Uses for Flue Gas De sulfurization (FGD) Gypsum. EPA530-F-08-009.
March 2008.

EPA, 2012a. Email from Zach Hedgpeth to Elliot Rosenberg. 1/23/12, and subsequent
conversation.

EPA. 2012b. Email from Zach Hedgpeth to Elliot Rosenberg. 2/09/12.

EPA. 2012c. Discussion with Karla Anderson.

FGDProducts. Org. Developed by the ACAA Educational Foundation and its Partner organizations, this website has been desi gned to provide produc tion, technical and environmental information about the use of FGD Gypsum http://www.fgdproducts.org

Taylor, Michael et al. 20 06. Energy Efficiency and CO 2 

### Emissions from the Global Cement Industry. IEA, Paris, 4-5 September 2006 http://www.iea.org/work/ 2006/cement/taylor_background.pdf

Transalta. 2012. http://suppliers.transalta.com/sd2002/e nviro_performance/land_use/waste.shtml

USA Gypsum. 2012. Agricultural Gypsum Uses.

### INTALCO FGD GYPSUM MARKET REVIEW ‐ FINAL

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### U.S.G.S. 2012a. Gypsum Statistics and Information. http://minerals.usgs.gov/miner als/pubs/commodity/gypsum/

U.S.G.S. 2012b. Other estimates and gypsum market information per phone calls with Robert D. Crangle, Jr., Gypsum Commodity Specialist.Attachment14–IntalcoLSFOCostElementsComparisonCostElementEnvironAssumptionEPARegion10AssumptionImpacttoCostEffectiveness1Scrubber	redundancyTwo	scrubber	towers,	each	capable	of	treating	100%	of	theexhaust	gas	stream;	i.e.	full	redundancy	during	scrubber	towermaintenance.A	single	tower	capable	of	treating	100%	of	theexhaust	gas	stream2.↓$1,347/tonEquipment	lifetime15	years30	years3↓$823/tonGypsum	disposal/reuseLandfilled.Given	away	FOB	at	Intalco.4↓$657/tonCapital	equipment	quoteAverage	of	two	quotes,	scaled	from	TN	smelter.Lower	of	two	quotes,	scaled	from	TN	smelter5.↓$393/tonSales	Tax6.5%8.2%↑$44/tonWater	cost/usage$0.00053/gal$0.0007/galPUD	connection	fee	$300k6↑$11/tonAquatic	studies	(DNR)Not	included.$235k7↑$5/tonCost	Effectiveness$7,500/ton$4,366/ton1Arrows	and	dollar	amounts	indicate	the	approximate	impact	of	each	EPA	assumption	to	increase	ordecrease	cost/ton	vs.	the	corresponding	Environ	assumption.2A	single	tower	LSFO	system	willmean	that	emissions	are	bypassed	during	any	time	the	scrubber	is	offline	for	maintenance.		Assuming	two	weeks	of	scrubberdowntime	annually	results	in	approximately	240	tons	less	SO2removed	by	the	scrubber.3The	EPA	Air	Pollution	Control	Cost	Manual	procedures	require	using	the	actual	expected	life	ofthe	control	equipment.		Specific	references	include	the	following	fromSection	1	–	Introduction;	Chapter	2	–	Cost	Estimation:	Conceptsand	Methodology:“For	each	alternative,	calculatea	discounting	factor	each	yearover	the	life	of	the	equipment...”	(Page	2‐19,	emphasis	added).“...sufficient	to	finance	the	investment	over	its	entire	life,	using	the	formula...[CRF]...wherePMT	is	the	equivalent	uniform	payment	over	the	life	of	the	control,	n,at	an	interest	rate,	i...”	(Page	2‐21,	emphasis	added).Wet	flue	gas	desulfurization	(FGD)	scrubbers	can	reasonably	beexpected	to	last	30	years	based	on	the	following:"...costofaprojectoveritslifetime‐typically30yearsforaFGDsystem."‐‐‐	"Estimating	Costs	of	Air	Pollution	Control",	William	M.	Vatavuk,	Lewis	Publishers,1990,	Page	198.“Booklife–30years”	‐‐‐	"Optimum	Values	of	ProcessParameters	of	the	'Wet	Limestone	Flue	Gas	Desulfurization	System'",	J.	Warych	and	M.	Szymanowski,Chemical	Engineering	&	Technology,	v.	25,	2002.	Pages	427‐432.Footnote	to	cost	calculation	table	for	FGD	systems:"Booklife‐30years;Taxlife‐20years"‐‐‐	"Retrofit	Costs	of	SO2and	NOx	Control	at	200U.S.	Coal‐Fired	PowerPlants",	Kaplan,	et	al.,	presented	at	the	1990	Pittsburgh	CoalConference,	September	11,	1990.The	following	document	contains	information	on	over	a	dozen	coal	fired	boilers	installed	with	wet	limestone	FGD	in	the	1970s	and	1980s.		Web	research	was	ableto	confirm	that	the	vast	majority	of	these	plants	are	still	operating.		"Flue	Gas	Desulfurization	Systems:		Component	MaterialPerformance	&	Welding",	ElectricPower	Research	Institute(EPRI),	December	2005.4“Market	Review	for	Intalco	Produced	FGD	Gypsum.”		Elliot	Rosenberg,	Senior	Economist.		EPA	Region	10.		March	23,	2012.5Using	the	lowest	responsive	bid	is	based	on:Standard	contracting	practice.Both	quotes	were	from	reputable,experienced	equipment	suppliers.EPA	Air	Pollution	Control	Cost	Manual	supports	using	the	lowestresponsive	bid,		specifically	themanual	states	that	“[s]ignificant	savings	can	be	had	by	solicitingmultiple	quotes”	(Page	3‐38;	Chapter	3	–	Electrostatic	Precipitators;	Section	6	–	Particulate	Matter	Controls)	and	discusses	the	ability	to	“compare	to	other	bids”(Page	1‐29;	Chapter	1	–	Selective	Non‐catalytic	Reduction	(SNCR);	Section	4.2	–	NOXPost	Combustion).6Conversation	with	Stephan	Jilk,General	Manager	of	Whatcom	PUD,	fresh	water	supplier	to	Intalco.7Conversations	with	Kyle	Murphy,	Washington	DNR	project	managerfor	Cherry	Point	Aquatic	Reserve	Management	Plan.UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 10 1200 Sixth Avenue Seattle, WA 98101



### December 9, 2011

Reply to Attn Of: OEA-095

MEMORANDUM

SUBJECT: Intalco Ferndale Smelter BART Review - Scrubber Water Demand

FROM: Zach Hedg kth,



### Environmental Engineer, ESU, OEA

TO: File

On the morning of December 8, 201.1, l called Mr. Stephan !ilk, General Manager of the Whatcom County Public Utility District, which supplies fresh water to the Intalco smelter. l explained that the EPA (Region 10 in Seattle) is conducting a review of a Washington State analysis regarding a potential wet scrubbing air pollution control system at the Ferndale smelter, I explained that in my technical services role within Region 10, I was calling to verify the availability of additional freshwater supplies which would be required by a new scrubbing system, or the lack thflreof.

I explained that the initial designs for the scrubber identify a freshwater requirement of approximately 0.5 million gallons per day (MGD), and that various reports had claimed that this additional water would be difficult for Intalco to obtain. I asked Mr. f 

### ilk if he could verify this scarcity of available water.

Mr. !ilk stated that increasing supply to Intalco by 0.5 MGD would not be a problem for Whatcom PUD in terms of water availability. Mr. I 

### ilk further explained that provision of this increased supply would entail the following approximate fees:

• One time "connection charge" to increase the amount of water the PUD delivers to Intalco of approximately $300,000 based on current charge rates, and
® Ongoing water cost of around $700 per million gallons or approximately $350 per day at 0.5 MGD.