OP2655-02 i Date of Decision: 04/29/08 

Effective Date: 05/30/08 

 

State of Montana 

Department of Environmental Quality 

Helena, Montana 59620 

AIR QUALITY OPERATING PERMIT NUMBER OP2655-02 

Renewal Application Received: February 16, 2006

Application Deemed Administratively Complete: March 14, 2006

Application Deemed Technically Complete: March 14, 2006

AFS Number: 030-029-0012A

Draft Issue Date: January 23, 2008

Proposed Issue Date: March 10, 2008

End of EPA 45-day Review: April 28, 2008

Date of Decision: April 29, 2008

Effective Date: May 30, 2008

Expiration Date: May 30, 2013

In accordance with the Montana Code Annotated (MCA) sections 75-2-217 and 218, and Administrative 

Rules of Montana (ARM), Title 17, Chapter 8, Subchapter 12, Operating Permit Program, ARM 

17.8.1201, et seq., 

Columbia Falls Aluminum Company, LLC 

NE 1⁄4, SE 1⁄4, Section 3, Township 30 North, Range 20 West, Flathead County, Montana 

2000 Aluminum Drive 

Columbia Falls, MT 59912 

hereinafter referred to as "CFAC," is authorized to operate a stationary source of air contaminants 

consisting of the emissions units described in this permit. Until this permit expires, is modified, or 

revoked, the permittee is allowed to discharge air pollutants in accordance with the conditions of this 

permit. All conditions in this permit are federally and state enforceable, unless otherwise specified. 

Requirements that are only state enforceable are identified in the permit. A copy of this permit must be 

kept on-site at the above-named facility. 

Issued by the Department of Environmental Quality 

 / / .

 Signature Date 

Permit Issuance and Appeal Process: In accordance with Section 75-2-218, MCA, the Department of 

Environmental Quality’s (Department) decision regarding issuance of an operating permit is not effective 

until 30 days have elapsed from the date of the decision issued April 29, 2008. The decision may be 

appealed to the Board of Environmental Review (Board) by filing a request for a hearing within 30 days 

after the date of decision. The filing of a request for hearing does not stay the Department’s decision, 

unless the Board orders a stay upon receipt of a petition and a finding that a stay is appropriate under 

Section 75-2-218(6)(b), MCA. If no stay is ordered, the Department’s decision on the application is final 

30 days after the decision is made and the Department will send notification and a final permit cover page 

to be attached to this document stating that the permit is final. In addition, ARM 17.8.1233 allows for 

any person to petition the Environmental Protection Agency (EPA) within 60 days after the expiration of 

EPA’s 45-day review period to object to issuance of this operating permit. If EPA objects to the 

operating permit as a result of a petition prior to the Department’s notification of a final permit, May 30 

and all affected parties will be informed of the stay of a final permit. If the Department has already 

notified CFAC and all affected parties, the Department shall issue a revised permit according to ARM 

17.8.1231. Questions regarding the final issuance date and status of appeals should be directed to the 

Department at (406) 444-3490. 
OP2655-02 ii Date of Decision: 04/29/08 

Effective Date: 05/30/08 

 

Montana Air Quality Operating Permit 

Department of Environmental Quality 

SECTION I. GENERAL INFORMATION.........................................................................................................1

SECTION II. SUMMARY OF EMISSION UNITS..............................................................................................2

A. FACILITY-WIDE............................................................................................................................4

B. EU001 – EU007 MATERIAL HANDLING EMITTING UNITS WITH BAGHOUSES.............7

C. EU008 – EU014 EU’S WITH BAGHOUSES & GRAIN LOADING RESTRICTIONS...............8

D. EU015 – EU017 PASTE PLANT EMITTING UNITS WITH BAGHOUSES............................10

E. EU018 – PITCH STORAGE TANKS - PP04 ...............................................................................12

F. EU019 – PASTE PLANT OIL HEATING SYSTEM - PP05 .......................................................13

G. EU020 – EU023 PRIMARY SCRUBBER SYSTEM ALUMINA TRANSFER EU’S................14

H. EU024 – EU033 PRIMARY GAS COLLECTION SYSTEM EMITTING UNITS.....................15

I. EU034 – EU038 POTLINE ROOF VENT EMITTING UNITS...................................................18

J. EU039 – EU043 CASTING FURNACE EMITTING UNITS......................................................20

K. EU044 – EU048 CASTING PIT EMITTING UNITS...................................................................21

L. EU049 – EU050 ALUMINUM SAW EMITTING UNITS...........................................................22

M. EU051 – SANDBLASTING ACTIVITIES - CR01 ......................................................................23

N. EU052 – LECTROMELT FURNACE EMITTING UNIT - CR03...............................................24

O. EU053 – ROD MILL/MATERIAL STORAGE/BATH CRUSHING EMITTING UNIT-CR04 .25

P. EU054 – EU062 NATURAL GAS BOILER EMITTING UNITS ..............................................26

Q. EU063 – TRUCK, EQUIPMENT, AND HAUL ROAD EMISSIONS – MP05...........................27

R. EU064 – GASOLINE STORAGE (TANK) EMITTING UNIT – MP04......................................28

S. EU065 – SOW CASTING LINE...................................................................................................29

SECTION IV NON-APPLICABLE REQUIREMENTS................................................................................31

A. FACILITY-WIDE..........................................................................................................................31

B. EMISSION UNITS........................................................................................................................31

SECTION V – GENERAL PERMIT CONDITIONS ............................................................................................32

A. COMPLIANCE REQUIREMENTS..............................................................................................32

B. CERTIFICATION REQUIREMENTS .........................................................................................32

C. PERMIT SHIELD..........................................................................................................................33

D. MONITORING, RECORD KEEPING, AND REPORTING REQUIREMENTS........................34

E. PROMPT DEVIATION REPORTING .........................................................................................35

F. EMERGENCY PROVISIONS ......................................................................................................35

G. INSPECTION AND ENTRY ........................................................................................................36

H. FEE PAYMENT............................................................................................................................36

I. MINOR PERMIT MODIFICATIONS ..........................................................................................36

J. CHANGES NOT REQUIRING PERMIT REVISION .................................................................37

K. SIGNIFICANT PERMIT MODIFICATIONS ..............................................................................38

L. REOPENING FOR CAUSE..........................................................................................................38

M. PERMIT EXPIRATION AND RENEWAL..................................................................................38

N. SEVERABILITY CLAUSE ..........................................................................................................39

O. TRANSFER OR ASSIGNMENT OF OWNERSHIP ...................................................................39

P. EMISSIONS TRADING, MARKETABLE PERMITS, ECONOMIC INCENTIVES.................39

Q. NO PROPERTY RIGHTS CONVEYED......................................................................................39

R. TESTING REQUIREMENTS.......................................................................................................40

S. SOURCE TESTING PROTOCOL................................................................................................40

T. MALFUNCTIONS ........................................................................................................................40

U. CIRCUMVENTION......................................................................................................................40

V. MOTOR VEHICLES.....................................................................................................................40

W. ANNUAL EMISSIONS INVENTORY ........................................................................................40

X. OPEN BURNING..........................................................................................................................40

Y. PRECONSTRUCTION PERMITS ...............................................................................................40

Z. NATIONAL EMISSION STANDARD FOR ASBESTOS...........................................................41
OP2655-02 iii Date of Decision: 04/29/08 

Effective Date: 05/30/08 

 

AA. ASBESTOS ...................................................................................................................................41

BB. STRATOSPHERIC OZONE PROTECTION – SERVICING OF MOTOR VEHICLE AIR 

CONDITIONERS..........................................................................................................................41

CC. STRATOSPHERIC OZONE PROTECTION – RECYCLING AND EMISSION REDUCTIONS

 41

DD. EMERGENCY EPISODE PLAN..................................................................................................42

EE. DEFINITIONS...............................................................................................................................42

APPENDIX A - INSIGNIFICANT EMISSION UNITS ..................................................................................... A-1

APPENDIX B - DEFINITIONS AND ABBREVIATIONS .................................................................................B-1

APPENDIX C - NOTIFICATION ADDRESSES................................................................................................ C-1

APPENDIX D - AIR QUALITY INSPECTOR INFORMATION..................................................................... D-1

APPENDIX E - CFAC MACT IMPLEMENTATION PLAN.............................................................................E-1

APPENDIX F - CFAC MACT QUICK REFERENCE GUIDE..........................................................................F-1

APPENDIX G - STARTUP, SHUTDOWN AND MALFUNCTION PLAN (SSM) ......................................... G-1

APPENDIX H - POTLINE ROOF VENT OPACITY COMPLIANCE DEMONSTRATION....................... H-1

APPENDIX I - POLLUTION CONTROL DEVICE INSPECTION AND MAINTENANCE PLAN..............I-1

APPENDIX J - 62 FR 52383................................................................................................................................... J-1

APPENDIX K – AMBIENT MONITORING PLAN .......................................................................................... K-1
OP2655-02 1 Date of Decision: 04/29/08 

Effective Date: 05/30/08 

 

Terms not otherwise defined in this permit or in the Definitions and Abbreviations Appendix of this permit 

have the meaning assigned to them in the referenced regulations. 

SECTION I. GENERAL INFORMATION 

The following general information is provided pursuant to ARM 17.8.1210(1). 

Company Name: Columbia Falls Aluminum Company LLC 

Mailing Address: 2000 Aluminum Drive 

City: Columbia Falls State: MT Zip: 59912 

Plant Location: Columbia Falls; NE 1⁄4, SE 1⁄4, Section 3, Township 30 North, Range 20 West 

Responsible Official: Charles D. Reali Phone: 406-892-8225 

Facility Contact Person(s): Steve Wright Phone: 406-892-8211 

Primary SIC Code: 3334 

Nature of Business: Primary Aluminum Production 

Description of Process: 

CFAC operates five Vertical Stud Soderberg potlines at the Columbia Falls plant. Each potline has 120 

individual cells that produce aluminum by the Hall-Heroult process. Annual operating capacity is 

approximately 185,000 tons of Aluminum, based on an average current efficiency of 90.5%. 

The Hall-Heroult process consists of passing an electric current through aluminum oxide ore, or alumina 

(Al2O3), dissolved in molten cryolite. The reduction process is accomplished in a Vertical Stud Soderberg 

style pot. Soderberg technology describes the type of consumable carbon anode used in the process. 

The cells or “pots” are housed in buildings called potrooms; two potrooms are connected electrically in series 

to form one potline. CFAC currently has 10 potrooms that comprise the five potlines. Emissions from each 

pot are divided into two categories: primary emissions and secondary emissions. Primary emissions are 

captured at the pots and routed to the primary air pollution control system, the A398 dry alumina scrubbers. 

Secondary emissions are fugitive emissions from the pots that are vented out the roofline of the potrooms. 

Alumina is fed into a molten bath of cryolite, and heated to about 950°C (1740°F). Through the 

electrochemical process, electricity passes from the anode to the cathode, causing the aluminum to be reduced. 

The aluminum metal sinks below the cryolite bath to form a molten aluminum “pad.” The evolved oxygen 

atoms bond with the carbon in the anode of the cell to form carbon monoxide and carbon dioxide. Other 

emissions from the process include both particulate fluoride and gaseous hydrogen fluoride as well as 

hydrocarbon emissions containing polycyclic organic matter. The aluminum metal is siphoned from the pot 

every 48 hours and transported to the Casting Department, where it is cast into ingots of various sizes, shapes, 

and alloys. Typically each pot produces approximately 1700 pounds of aluminum per day.
OP2655-02 2 Date of Decision: 04/29/08 

Effective Date: 05/30/08 

 

SECTION II. SUMMARY OF EMISSION UNITS 

The emission units regulated by this permit are the following (ARM 17.8.1211): 

Emission Unit ID Emission Unit 

Description 

Pollution Control Device 

or Practice 

EU001 Ball Mill North - MH01 Baghouse 

EU002 Ball Mill South - MH02 Baghouse 

EU003 Coke Silo - MH04 Baghouse 

EU004 East Alumina Elevator - MH06 Baghouse 

EU005 East Alumina Unloading - MH07 Baghouse 

EU006 East Conveyor Storage - MH08 Baghouse 

EU007 West Alumina Unloading - MH09 Baghouse 

EU008 Anode Dust Control System MH03(1) & MH03(2) Baghouse 

EU009 Coke Unloading - MH05 Baghouse 

EU010 West Conveyor Storage - MH10 Baghouse 

EU011 Potline Sweeping - AR04 Baghouse 

EU012 Treatment of Aluminum Crucibles (TAC) 

Operations - CO10 

Baghouse 

EU013 Pin Cleaning - West Plant - CR07 Baghouse 

EU014 Pin Cleaning - East Plant - CR07a Baghouse 

EU015 Paste Plant Extruder - PP01 Procedair Dry Coke Scrubber (Baghouse) 

EU016 Paste Plant Mixer - PP02 Procedair Dry Coke Scrubber (Baghouse) 

EU017 Pinhole Past Drying - PP03 Baghouse 

EU018 Pitch Storage Tank Vents - PP04 Condensation Tower/Vent 

EU019 Paste Plant Oil Heating System - PP05 None 

EU020 East Plant Dry Scrubber Alumina Transfer (North) 

- AR01 

Baghouse 

EU021 East Plant Dry Scrubber Alumina Transfer (South) 

- AR02 

Baghouse 

EU022 West Plant Dry Scrubber Alumina Transfer 

(North) - AR06 

Baghouse 

EU023 West Plant Dry Scrubber Alumina Transfer 

(South) - AR07 

Baghouse 

EU024 Primary Gas Collection System - West Plant 

(Potlines 1 & 2) - AR05 

Alcoa A398 Dry Alumina Scrubber #1 

(Reactor #1 & Baghouse) 

EU025 Primary Gas Collection System - West Plant 

(Potlines 1 & 2) - AR05 

Alcoa A398 Dry Alumina Scrubber #2 

(Reactor #2 & Baghouse) 

EU026 Primary Gas Collection System - West Plant 

(Potlines 1 & 2) - AR05 

Alcoa A398 Dry Alumina Scrubber #3 

(Reactor #3 & Baghouse) 

EU027 Primary Gas Collection System - West Plant 

(Potlines 1 & 2) - AR05 

Alcoa A398 Dry Alumina Scrubber #4 

(Reactor #4 & Baghouse) 

EU028 Primary Gas Collection System - East Plant 

(Potlines 3, 4, & 5) - AR05 

Alcoa A398 Dry Alumina Scrubber #5 

(Reactor #5 & Baghouse) 

EU029 Primary Gas Collection System - East Plant 

(Potlines 3, 4, & 5) - AR05 

Alcoa A398 Dry Alumina Scrubber #6 

(Reactor #6 & Baghouse) 

EU030 Primary Gas Collection System - East Plant 

(Potlines 3, 4, & 5) - AR05 

Alcoa A398 Dry Alumina Scrubber #7 

(Reactor #7 & Baghouse) 

EU031 Primary Gas Collection System - East Plant 

(Potlines 3, 4, & 5) - AR05 

Alcoa A398 Dry Alumina Scrubber #8 

(Reactor #8 & Baghouse) 

EU032 Primary Gas Collection System - East Plant 

(Potlines 3, 4, & 5) - AR05 

Alcoa A398 Dry Alumina Scrubber #9 

(Reactor #9 & Baghouse) 

EU033 Primary Gas Collection System - East Plant 

(Potlines 3, 4, & 5) - AR05 

Alcoa A398 Dry Alumina Scrubber #10 

(Reactor #10 & Baghouse) 
OP2655-02 3 Date of Decision: 04/29/08 

Effective Date: 05/30/08 

 

EU034 Potline #1 Roof Vent, West Plant - AR03 None 

EU035 Potline #2 Roof Vent, West Plant - AR03 None 

EU036 Potline #3 Roof Vent, East Plant - AR03 None 

EU037 Potline #4 Roof Vent, East Plant - AR03 None 

EU038 Potline #5 Roof Vent, East Plant - AR03 None 

EU039 Casting Furnace #3 - CO01 None 

EU040 Casting Furnace #4 - CO02 None 

EU041 Casting Furnace #6 - CO03 None 

EU042 Casting Furnace #7 - CO04 None 

EU043 Casting Furnace #8 & #9 - CO05 None 

EU044 Casting Pit #3 - CO06 None 

EU045 Casting Pit #4 - CO06 None 

EU046 Casting Pit #6 & #7 - CO06 None 

EU047 Casting Pit #8 & #9 - CO06 None 

EU048 Dross Handling - CO07 None 

EU049 Sheet Ingot Saw – CO08 Target Box and Cyclone 

EU050 T-Ingot Saw – CO09 Target Box and Filter or Cyclone 

EU051 Sandblasting Activities - CR01 None 

EU052 Lectromelt Furnace - CR03 Baghouse 

EU053 Rod Mill/Material Storage/Bath Crushing - CR04 Baghouse 

EU054 Change House Boiler #1 - MP01 None 

EU055 Change House Boiler #2 - MP02 None 

EU056 Lab Boiler #1 - MP07 None 

EU057 Machine Shop Boiler #1 - MP08 None 

EU058 Machine Shop Boiler #2 - MP09 None 

EU059 Paste Plant Boiler #1 - MP11 None 

EU060 Paste Plant Boiler #2 - MP12 None 

EU061 Warehouse Boiler #1 - MP16 None 

EU062 Warehouse Boiler #2 - MP17 None 

EU063 Haul Road Emissions - MP05 None 

EU064 Gasoline Storage Tank - MP04 None 

EU065 Sow Casting Line None 
OP2655-02 4 Date of Decision: 04/29/08 

Effective Date: 05/30/08 

 

Section III Permit Conditions 

The following requirements and conditions are applicable to the facility or to specific emission units located at 

the facility (ARM 17.8.1211, 1212, and 1213). 

A. FACILITY-WIDE 

Conditions Rule Citation Rule Description Pollutant/Parameter Limit 

A.1 ARM 17.8.105 Testing Requirements Testing Requirements ----- 

A.2 ARM 17.8.230 Ambient Air Monitoring Fluoride in Forage See Appendix K 

A.3 ARM 17.8.304(1) Visible Air Contaminants Opacity 40% 

A.4 ARM 17.8.304(2) Visible Air Contaminants Opacity 20% 

A.5 ARM 17.8.308(1) Particulate Matter, Airborne Fugitive Opacity 20% 

A.6 ARM 17.8.308(2) Particulate Matter, Airborne Reasonable Precautions ------- 

A.7 ARM 17.8.308(3) Particulate Matter, Airborne Reasonable Precaution, 

Construction 

20% 

A.8 ARM 17.8.309 Particulate Matter, Fuel Burning 

Equipment 

Particulate Matter E = 0.882 * H-0.1664

Or 

E = 1.026 * H-0.233

A.9 ARM 17.8.310 Particulate Matter, Industrial Processes Particulate Matter E = 4.10 * P0.67 Or 

E = 55 * P0.11- 40 

A.10 ARM 17.8.322(4) Sulfur Oxide Emissions, Sulfur in Fuel Sulfur in Fuel (liquid or solid 

fuels) 

1 lb/MMBtu Fired 

A.11 ARM 17.8.322(5) Sulfur Oxide Emissions, Sulfur in Fuel Sulfur in Fuel (gaseous) 50 gr/100 CF 

A.12 ARM 17.8.324(3) Hydrocarbon Emissions, Petroleum 

Products 

Gasoline Storage Tanks ------- 

A.13 ARM 17.8.324 Hydrocarbon Emissions, Petroleum 

Products 

65,000-Gallon Capacity ------- 

A.14 ARM 17.8.324 Hydrocarbon Emissions, Petroleum 

Products 

Oil-effluent Water Separator ------- 

A.15 ARM 17.8.342 NESHAPs General Provisions SSM Plans Submittal 

A.16 ARM 17.74.336 Asbestos Asbestos ------- 

A.17 40 CFR Part 63, 

Subpart LL 

Aluminum MACT Fluoride, 

Polycyclic Organic Matter 

See Appendix F 

A.18 ARM 17.8.1212 Reporting Requirements Compliance Monitoring ------- 

A.19 ARM 17.8.1207 Reporting Requirements Annual Certification ------- 

Conditions

A.1. Pursuant to ARM 17.8.105, any person or persons responsible for the emission of any air contaminant into 

the outdoor atmosphere shall, upon written request of the Department, provide the facilities and necessary 

equipment (including instruments and sensing devices) and shall conduct test, emission or ambient, for such 

periods of time as may be necessary using methods approved by the Department. 

Compliance demonstration frequencies that list “as required by the Department” refer to ARM 17.8.105. In 

addition, for such sources, compliance with limits and conditions listing “as required by the Department” as 

the frequency, is verified annually using emission factors and engineering calculations by the Department’s 

compliance inspectors during the annual emission inventory review; in the case of Method 9 tests, 

compliance is monitored during the regular inspection by the compliance inspector. 

A.2. Pursuant to ARM 17.8.230 and Appendix K of this permit, CFAC shall conduct ambient monitoring. 

A.3. Pursuant to ARM 17.8.304(1), CFAC shall not cause or authorize emissions to be discharged into the 

outdoor atmosphere from any source installed on or before November 23, 1968, that exhibit an opacity of 

40% or greater averaged over 6 consecutive minutes, unless otherwise specified by rule or in this permit. 
OP2655-02 5 Date of Decision: 04/29/08 

Effective Date: 05/30/08 

 

A.4. Pursuant to ARM 17.8.304(2), CFAC shall not cause or authorize emissions to be discharged into the 

outdoor atmosphere from any source installed after November 23, 1968, that exhibit an opacity of 20% 

or greater averaged over 6 consecutive minutes, unless otherwise specified by rule or in this permit. 

A.5. Pursuant to ARM 17.8.308(1), CFAC shall not cause or authorize the production, handling, transportation, 

or storage of any material unless reasonable precautions to control emissions of particulate matter are taken. 

Such emissions of airborne particulate matter from any stationary source shall not exhibit an opacity of 20% 

or greater averaged over 6 consecutive minutes, unless otherwise specified by rule or in this permit. 

A.6. Pursuant to ARM 17.8.308(2), CFAC shall not cause or authorize the use of any street, road, or parking 

lot without taking reasonable precautions to control emissions of airborne particulate matter, unless 

otherwise specified by rule or in this permit. 

A.7. Pursuant to ARM 17.8.308(3), CFAC shall not operate a construction-site or demolition project unless 

reasonable precautions are taken to control emissions of airborne particulate matter. Such emissions of 

airborne particulate matter from any stationary source shall not exhibit an opacity of 20% or greater 

averaged over 6 consecutive minutes, unless otherwise specified by rule or in this permit. 

A.8. Pursuant to ARM 17.8.309, unless otherwise specified by rule or in this permit, CFAC shall not cause 

or authorize particulate matter caused by the combustion of fuel to be discharged from any stack or 

chimney into the outdoor atmosphere in excess of the maximum allowable emissions of particulate 

matter for existing fuel burning equipment and new fuel burning equipment, calculated using the 

following equations: 

For existing fuel burning equipment (installed before November 23, 1968): E = 0.882 * H-0.1664

For new fuel burning equipment (installed on or after November 23, 1968): E = 1.026 * H-0.233

Where H is the heat input capacity in million BTU (MMBtu) per hour and E is the maximum allowable 

particulate emission rate in pounds per MMBtu. 

A.9. Pursuant to ARM 17.8.310, unless otherwise specified by rule or in this permit, CFAC shall not cause 

or authorize particulate matter to be discharged from any operation, process, or activity into the 

outdoor atmosphere in excess of the maximum hourly allowable emissions of particulate matter, 

calculated using the following equations: 

For process weight rates up to 30 tons per hour: E = 4.10 * P0.67

For process weight rates in excess of 30 tons per hour: E = 55.0 * P0.11 – 40 

Where E is the rate of emissions in pounds per hour and P is the process weight rate in tons per hour. 

ARM 17.8.310(3)(a) states that this rule does not apply to particulate matter emitted from the reduction 

cells of a primary aluminum reduction plant; therefore, ARM 17.8.310 does not apply to particulate 

emissions from the roof monitors of the potline buildings, nor does it apply to particulate emissions 

from the primary control system (Alcoa A398 Dry Alumina Scrubbers). However, ARM 17.8.310 is 

applicable to all other (non combustion) processes at CFAC. 

A.10. Pursuant to ARM 17.8.322(4), CFAC shall not burn liquid or solid fuels containing sulfur in excess of 

one pound per million BTU fired, unless otherwise specified by rule or in this permit. 

A.11. Pursuant to ARM 17.8.322(5), CFAC shall not burn any gaseous fuel containing sulfur compounds in 

excess of 50 grains per 100 cubic feet of gaseous fuel, calculated as hydrogen sulfide at standard 

conditions, unless otherwise specified by rule or in this permit. 

A.12. Pursuant to ARM 17.8.324(3), CFAC shall not load or permit the loading of gasoline into any 

stationary tank with a capacity of 250 gallons or more from any tank truck or trailer, except through a 

permanent submerged fill pipe, unless such tank is equipped with a vapor loss control device or is a 

pressure tank as described in ARM 17.8.324(1), unless otherwise specified by rule or in this permit. 
OP2655-02 6 Date of Decision: 04/29/08 

Effective Date: 05/30/08 

 

A.13. Pursuant to ARM 17.8.324, unless otherwise specified by rule or in this permit, CFAC shall not place, 

store or hold in any stationary tank, reservoir, or other container with more than a 65,000-gallon 

capacity any crude oil, gasoline, or petroleum distillate having a vapor pressure of 2.5 pounds per 

square inch absolute or greater under actual storage conditions, unless such tank, reservoir, or other 

container is a pressure tank maintaining working pressure sufficient at all times to prevent hydrocarbon 

vapor or gas loss to the atmosphere, or is designed and equipped with a vapor loss control device, 

properly installed, in good working order and in operation. 

A.14. Pursuant to ARM 17.8.324, unless otherwise specified by rule or in this permit, CFAC shall not use 

any compartment of any single or multiple-compartment oil-effluent water separator which 

compartment receives effluent water containing 200 gallons a day or more of any petroleum product 

from any equipment processing, refining, treating, storing, or handling kerosene or other petroleum 

product of equal or greater volatility than kerosene, unless such compartment is equipped with a vapor 

loss control device, constructed so as to prevent emission of hydrocarbon vapors to the atmosphere, 

properly installed, in good working order and in operation. 

A.15. Pursuant to ARM 17.8.342 and 40 CFR 63.6, CFAC shall submit to the Department a copy of any 

startup, shutdown, and malfunction (SSM) plan required under 40 CFR 63.6(e)(3) within 30 days of 

the effective date of this operating permit (if not previously submitted), within 30 days of the 

compliance date of any new National Emission Standard for Hazardous Air Pollutants (NESHAPs) or 

Maximum Achievable Control Technology (MACT) standard, and within 30 days of the revision of 

any such SSM plan, when applicable. The Department requests submittal of such plans in electronic 

form, when possible. 

A.16. Pursuant to ARM 17.74.336, CFAC shall comply with all the limitations and requirements of their 

Asbestos Abatement Annual Permit #MTF0007. 

A.17. Pursuant to ARM 17.8.342, CFAC shall satisfy all of the applicable requirements, including emission 

limitations, testing, monitoring, record keeping, and reporting, of 40 CFR 63, Subpart LL, National 

Emission Standards for Hazardous Air Pollutants for Primary Aluminum Reduction Plants (Aluminum 

MACT). CFAC shall also satisfy the requirements of the Compliance Schedule contained in Appendix 

H of this permit. 

A.18. On or before February 15 and August 15 of each year, CFAC shall submit to the Department the 

compliance monitoring reports required by Section V.D. These reports must contain all 

information required by Section V.D, as well as the information required by each individual 

emissions unit. For the reports due by February 15 of each year, CFAC may submit a single 

report, provided that it contains all the information required by Section V.B & V.D. Per ARM 

17.8.1207, 

any application form, report, or compliance certification submitted pursuant to 

ARM Title 17, Chapter 8, Subchapter 12 (including semi-annual monitoring 

reports), shall contain certification by a responsible official of truth, accuracy 

and completeness. This certification and any other certification required under 

ARM Title 17, Chapter 8, Subchapter 12, shall state that, “based on information 

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

the document are true, accurate and complete.” 

A.19. By February 15 of each year, CFAC shall submit to the Department the compliance certification 

report required by Section V.B. The annual certification report required by Section V.B must 

include a statement of compliance based on the information available, which identifies any 

observed, documented or otherwise known instance of noncompliance for each applicable 

requirement. Per ARM 17.8.1207, 
OP2655-02 7 Date of Decision: 04/29/08 

Effective Date: 05/30/08 

 

any application form, report, or compliance certification submitted pursuant to 

ARM Title 17, Chapter 8, Subchapter 12 (including annual certifications), shall 

contain certification by a responsible official of truth, accuracy and 

completeness. This certification and any other certification required under ARM 

Title 17, Chapter 8, Subchapter 12, shall state that, “based on information and 

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

document are true, accurate and complete.” 

B. EU001 – EU007 MATERIAL HANDLING EMITTING UNITS WITH BAGHOUSES 

EU001 - Ball Mill North - MH01 

EU002 - Ball Mill South - MH02 

EU003 - Coke Silo - MH04 

Condition(s) Pollutant/ Compliance Demonstration 

Parameter 

Permit Limit 

Method Frequency 

Reporting 

Requirements 

Method 9 As Required by the 

Department and Section 

III.A.1 

B.1, B.4, B.5, Semi-annual 

B.7, B.8, B.9, 

B.10, B.11 

Opacity 20% 

Operate and Maintain 

Baghouse I & M 

(Appendix I) 

Ongoing Semi-annual 

B.3, B.6, B.8, 

B.9, B.10, 

B.11 

Particulate 

Matter 

E = 55*P0.11 – 40 Method 5 As Required by the 

Department and Section 

III.A.1 

Semi-annual 

EU004 - East Alumina Elevator - MH06 

EU005 - East Alumina Unloading - MH07 

EU006 - East Conveyor Storage - MH08 

EU007 - West Alumina Unloading - MH09 

Condition(s) Pollutant/ Compliance Demonstration 

Parameter 

Permit Limit 

Method Frequency 

Reporting 

Requirements 

Method 9 As Required by the 

Department and 

Section III.A.1 

B.2, B.4, B.5, Semi-annual 

B.7, B.8, B.9, 

B.10, B.11 

Opacity 40% 

Operate and Maintain 

Baghouse I & M 

(Appendix I) 

Ongoing Semi-annual 

B.3, B.6, B.8, 

B.9, B.10, B.11 

Particulate Matter E = 55*P0.11 – 40 Method 5 As Required by the 

Department and 

Section III.A.1 

Semi-annual 

Conditions

B.1. CFAC shall not cause or authorize emissions to be discharged to the atmosphere from the Ball 

Mill North-MH01, Ball Mill South-MH02, and Coke Silo-MH04, that exhibit an opacity of 

20% or greater averaged over 6 consecutive minutes (ARM 17.8.304(2)). 

B.2. CFAC shall not cause or authorize emissions to be discharged to the atmosphere from the East 

Alumina Elevator-MH06, East Alumina Unloading-MH07, East Conveyor Storage-MH08, and 

West Alumina Unloading-MH09, that exhibit an opacity of 40% or greater averaged over 6 

consecutive minutes (ARM 17.8.304(1)). 

B.3. The particulate emissions from process weight shall not exceed the value calculated by E = 

55.0*P0.11-40, where E is the rate of emissions in pounds per hour and P is the process weight 

rate in tons per hour (ARM 17.8.310). 
OP2655-02 8 Date of Decision: 04/29/08 

Effective Date: 05/30/08 

 

Compliance Demonstration 

B.4. As required by the Department and Section III.A.1, CFAC shall perform a Method 9 test in 

accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106). Each 

observation period shall be a minimum of 6 minutes, unless any one reading is greater than the 

relevant opacity limit (20% or 40%); then the observation period shall be a minimum of 20 minutes or 

until a violation of the standard has been documented, whichever is a shorter period of time (ARM 

17.8.1213). 

B.5. CFAC shall operate and maintain the baghouse for EU001 through EU007 in accordance with the 

Pollution Control Device Inspection & Maintenance Plan (Appendix I) to monitor compliance with 

condition III.B.1, and III.B.2 (ARM 17.8.1213). 

B.6. As required by the Department and Section III.A.1, CFAC shall perform a Method 5 test in 

accordance with the Montana Source Test Protocol and Procedures Manual (ARM 

17.8.1213). 

Record keeping 

B.7. CFAC shall maintain on-site records of all inspection and maintenance activities performed 

on the baghouses in accordance with the Pollution Control Device Inspection & Maintenance 

Plan (Appendix I) and submit records to the Department upon request (ARM 17.8.1212). 

B.8. Method 5 and Method 9 test reports must be maintained on-site and must be submitted to the 

Department, upon request, in accordance with the Montana Source Protocol and Procedures 

Manual (ARM 17.8.106). 

Reporting 

B.9. Any compliance source test reports must be submitted in accordance with the Montana 

Source Test Protocol and Procedures manual (ARM 17.8.106 and ARM 17.8.1212). 

B.10. The annual compliance certification report required by Section V.B must contain a 

certification statement for the above applicable requirements (ARM 17.8.1212). 

B.11. The semi-annual compliance monitoring reports shall include a summary of (ARM 

17.8.1212): 

 a. The results of any source test conducted during the reporting period; and 

 b. Any corrective actions taken as a result of the inspections and maintenance as 

required by the Pollution Control Device Inspection & Maintenance Plan (Appendix 

I). 

C. EU008 – EU014 EU’S WITH BAGHOUSES & GRAIN LOADING RESTRICTIONS 

EU008 - Anode Dust Control System - MH03(1) 

and MH03(2) 

EU012 - Treatment of Aluminum Crucibles - CO10 

EU009 - Coke Unloading - MH05 EU013 - Pin Cleaning - West Plant - CR07 

EU010 - West Conveyor Storage - MH10 EU014 - Pin Cleaning - East Plant - CR07a 

EU011 - Potline Sweeping AR04 
OP2655-02 9 Date of Decision: 04/29/08 

Effective Date: 05/30/08 

 

Condition(s) Pollutant/ Compliance Demonstration 

Parameter 

Permit Limit 

Method Frequency 

Reporting 

Requirements 

Method 9 As Required by the 

Department and 

Section III.A.1 

C.1, C.4, C.5, Semi-annual 

C.7, C.8, C.9, 

C.10, C.11 

Opacity 20% 

Operate and Maintain 

Baghouse I & M 

(Appendix I) 

Ongoing Semi-annual 

C.2, C.6, C.8, 

C.9, C.10, C.11 

Particulate Matter E = 55*P0.11 – 40 Method 5 As Required by the 

Department and 

Section III.A.1 

Semi-annual 

C.3, C.6, C.8. 

C.9, C.10, C.11 

Particulate Matter 0.02 gr/dscf Method 5 As Required by the 

Department and 

Section III.A.1 

Semi-annual 

Conditions 

C.1. CFAC shall not cause or authorize emissions to be discharged to the atmosphere from the 

Anode Dust Control System-MH03(1), Anode Dust Control System-MH03(2), Coke 

Unloading-MH05, West Conveyor Storage-MH10, Potline Sweeping-AR04, Treatment of 

Aluminum Crucibles-CO10, Pin Cleaning West Plant-CR07, and Pin Cleaning East PlantCR07a, that exhibit an opacity of 20% or greater averaged over 6 consecutive minutes (ARM 

17.8.304(2)). As a result of venting indoors, EU013 and EU014 are not currently subject to 

this (C.1) requirement. 

C.2. The particulate emissions from process weight shall not exceed the value calculated by E = 

55.0*P0.11- 40, where E is the rate of emissions in pounds per hour and P is the process weight 

rate in tons per hour (ARM 17.8.310). 

C.3. Particulate emissions shall not exceed the 0.02 gr/dscf (ARM 17.8.752). 

Compliance Demonstration

C.4. As required by the Department and Section III.A.1, CFAC shall perform a Method 9 test in 

accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106). Each 

observation period shall be a minimum of 6 minutes, unless any one reading is greater than 20%; then 

the observation period shall be a minimum of 20 minutes or until a violation of the standard has been 

documented, whichever is a shorter period of time (ARM 17.8.1213). 

C.5. CFAC shall operate and maintain the baghouse for EU008 through EU014 in accordance with the 

Pollution Control Device Inspection & Maintenance Plan (Appendix I) of this permit (ARM 

17.8.1213). 

C.6. As required by the Department and Section III.A.1, CFAC shall perform a Method 5 test in 

accordance with the Montana Source Test Protocol and Procedures Manual (ARM 

17.8.1213). 

Record keeping

C.7. CFAC shall maintain on-site records of all inspection and maintenance activities performed on the 

baghouses in accordance with Appendix I and submit the records to the Department upon request 

(ARM 17.8.1212). 

C.8. Method 5 and Method 9 test reports must be maintained on-site and must be submitted to the 

Department, upon request, in accordance with the Montana Source Test Protocol and 

Procedures Manual (ARM 17.8.106 and ARM 17.8.1212). 
OP2655-02 10 Date of Decision: 04/29/08 

Effective Date: 05/30/08 

 

Reporting 

C.9. Any compliance source test reports must be submitted in accordance with the Montana 

Source Test Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212). 

C.10. The annual compliance certification report required by Section V.B must contain a 

certification statement for the above applicable requirements (ARM 17.8.1212). 

C.11. The semi-annual compliance monitoring reports shall include a summary of (ARM 

17.8.1212): 

a. The results of any source test conducted during the reporting period; and 

b. Any corrective actions taken as a result of the inspections and maintenance as 

required by the Pollution Control Device Inspection & Maintenance Plan (Appendix 

I). 

D. EU015 - EU017 PASTE PLANT EMITTING UNITS WITH BAGHOUSES 

EU015 - Paste Plant Extruder - PP01 EU016 - Paste Plant Mixer - PP02 

Condition(s) Pollutant/ Compliance Demonstration 

Parameter 

Permit Limit 

Method Frequency 

Reporting 

Requirements 

Method 9 As Required by the 

Department and Section 

III.A.1 

D.2, D.5, D.6, Semi-annual 

D.11, D.13, 

D.15, D.16, 

D.17 

Opacity 40% 

Visual Survey Daily Semi-annual 

D.3, D.8, D.10, 

D.12, D.13, 

D.15, D.16, 

D.17 

Particulate 

Matter 

E = 55*P0.11 – 40 Method 5 As Required by the 

Department and Section 

III.A.1 

Semi-annual 

Operation of Dry Coke 

Scrubber: CFAC MACT 

Implementation Plan 

(Appendix E) 

Ongoing Annual 

Certification 

D.4, D.9, D.10, 

D.13, D.15, 

D.16, D.17 

Polycyclic 

Organic 

Matter (POM) 

None 

Visual Survey Daily Semi-annual 

 EU017- Pinhole Paste Drying - PP03 

Condition(s) Pollutant/ Compliance Demonstration 

Parameter 

Permit Limit 

Method Frequency 

Reporting 

Requirements 

Method 9 As Required by the 

Department and Section 

III.A.1 

D.1, D.5, D.7, Semi-annual 

D.11, D.14, D.15, 

D.16, D.17 

Opacity 20% 

Baghouse I & M 

(Appendix I) 

Ongoing Semi-annual 

D.3, D.7, D.8, 

D.12, D.14, D.15, 

D.16, D.17 

Particulate 

Matter 

E = 55*P0.11 – 40 Method 5 As Required by the 

Department and Section 

III.A.1 

Semi-annual 

Conditions

D.1. CFAC shall not cause or authorize emissions to be discharged to the atmosphere from Pinhole Paste 

Drying-PP03 that exhibit an opacity of 20% or greater averaged over 6 consecutive minutes (ARM 

17.8.304(2)). 
OP2655-02 11 Date of Decision: 04/29/08 

Effective Date: 05/30/08 

 

D.2. CFAC shall not cause or authorize emissions to be discharged to the atmosphere from the Paste Plant 

Extruder-PP01 and the Paste Plant Mixer-PP02, that exhibit an opacity of 40% or greater averaged 

over 6 consecutive minutes (ARM 17.8.304(1)). 

D.3. The particulate emissions from process weight shall not exceed the value calculated by E = 55.0*P0.11-

40, where E is the rate of emissions in pounds per hour and P is the process weight rate in tons per hour 

(ARM 17.8.310). 

D.4. Polycyclic Organic Matter (POM) emissions from the paste plant shall be controlled by the operation 

of a Dry Coke Scrubber (ARM 17.8.302(i), ARM 17.8.342, ARM 17.8.749, and 40 CFR Part 63, 

Subpart LL). 

Compliance Demonstration

D.5. As required by the Department and Section III.A.1, CFAC shall perform a Method 9 test in accordance 

with the Montana Source Test Protocol and Procedures Manual. Each observation period shall be a 

minimum of 6 minutes, unless any one reading is greater than the relevant opacity limit (20% or 40%); 

then the observation period shall be a minimum of 20 minutes or until a violation of the standard has 

been documented, whichever is a shorter period of time (ARM 17.8.1213). 

D.6. Daily, CFAC shall visually survey the Paste Plant Dry Coke Scrubber for any sources of excessive 

emissions. For the purpose of this survey, excessive emissions are considered to be any visible 

emissions, which meet or exceed 30% opacity. The person conducting the survey does not have to be 

an EPA Method 9 certified observer. However the individual must have been certified as a Method 9 

observer within the previous two years of the visual survey being performed. If sources of excessive 

emissions are identified, CFAC shall immediately conduct a Method 9 or take corrective action to 

contain or minimize the source of emissions. If corrective actions are taken, then CFAC shall 

immediately conduct a subsequent visual survey to monitor compliance. The person conducting the 

visual survey shall record the results of the survey in a log, including any corrective action taken. 

Conducting a visual survey does not relieve CFAC of a liability for a violation determined using 

Method 9 (ARM 17.8.1213). 

D.7. CFAC shall operate and maintain the baghouse (EU017) in accordance with the Pollution Control 

Device Inspection & Maintenance Plan (Appendix I) of this permit (ARM 17.8.1213). 

D.8. As required by the Department and Section III.A.1, CFAC shall perform a Method 5 test in accordance 

with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.1213). 

D.9. The Dry Coke Scrubber shall be operated when either EU015 or EU016 are operating, in accordance 

with the CFAC’s MACT Implementation Plan (Appendix E) of this permit, to control Polycyclic 

Organic Matter (POM) emissions from the Paste Plant. The parameter monitoring system must be 

operated, calibrated, and maintained for the Paste Plant Dry Coke Scrubber (40 CFR 63.848(f)). 

D.10. Daily, CFAC must inspect the Paste Plant Dry Coke Scrubber to ensure that the control device is 

operating properly. If a monitoring device measures an operating parameter outside of the limits 

established in CFAC's MACT Implementation Plan (Appendix E), then CFAC shall initiate corrective 

action procedures identified in the Startup, Shutdown, and Malfunction Plan (Appendix G of this 

permit) within one hour (ARM 17.8.1213). 

Record keeping

D.11. Method 9 tests shall be conducted in accordance with the Montana Source Test Protocol and 

Procedures Manual. Method 9 reports must be maintained on-site and must be submitted to the 

Department upon request (ARM 17.8.106). 

D.12. Method 5 test reports must be maintained on -site and must be submitted to the Department in 

accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106). 
OP2655-02 12 Date of Decision: 04/29/08 

Effective Date: 05/30/08 

 

D.13. CFAC shall maintain, on-site, a log including all visual observations monitoring compliance with 

the visual survey requirement. The log shall include the required information, the date, the time, 

and the initials of the documenting personnel (ARM 17.8.1212). 

D.14. CFAC shall maintain on-site records of all inspection and maintenance activities performed on the 

baghouses in accordance with the Pollution control Device Inspection & Maintenance Plan (Appendix 

I) and submit such records to the Department upon request (ARM 17.8.1212). 

Reporting 

D.15. All compliance source test reports must be submitted in accordance with the Montana Source Test 

Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212). 

D.16. The annual compliance certification report required by Section V.B must contain a certification 

statement for the above applicable requirements (ARM 17.8.1212). 

D.17. The semi-annual compliance monitoring reports shall include a summary of (ARM 17.8.1212): 

a. The results of any source test conducted during the last reporting period; 

b. Summary of corrective actions taken as a result of visual surveys; 

c. For EU015 & EU016 only, the number of operating parameter exceedances, including visible 

emissions, occurring during the semi-annual reporting period (one exceedance per 24-hr period – 

40 CFR 63.848(i)); 

d. For EU015 & EU016 only, any corrective actions taken as a result of the daily visual surveys of 

visible emissions and operating parameters (Startup, Shutdown and Malfunction Plan (Appendix 

G)); and 

e. For EU017 only, a summary of any corrective actions taken as a result of the inspections and 

maintenance as required by the Pollution Control Device Inspection & Maintenance Plan 

(Appendix I). 

E. EU018 – PITCH STORAGE TANKS - PP04 

Condition(s) Pollutant/ Compliance Demonstration 

Parameter 

Permit Limit 

Method Frequency 

Reporting 

Requirements 

E.1, E.2, E.3, E.4, 

E.5, E.6 

Opacity 20% Method 9 As Required by the 

Department and Section 

III.A.1. 

Semi-annual 

Conditions

E.1. CFAC shall not cause or authorize emissions to be discharged to the atmosphere from the Pitch 

Storage Tanks-PP04 that exhibit an opacity of 20% or greater averaged over 6 consecutive minutes 

(ARM 17.8.304(2)). 

Compliance Demonstration

E.2. As required by the Department and Section III.A.1, CFAC shall perform a Method 9 test in 

accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106). Each 

observation period shall be a minimum of 6 minutes, unless any one reading is 20% or greater, at 

which point the observation period shall be a minimum of 20 minutes or until a violation of the 

standard has been documented, whichever is the shorter period of time (Arm 17.8.1213). 
OP2655-02 13 Date of Decision: 04/29/08 

Effective Date: 05/30/08 

 

Record keeping

E.3. Method 9 tests shall be conducted in accordance with the Montana source Test Protocol and 

Procedures Manual. Method 9 reports must be maintained on-site and must be submitted to the 

Department upon request (ARM 17.8.106). 

Reporting 

E.4. Any compliance source test reports must be submitted in accordance with the Montana Source Test 

Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212). 

E.5. The annual compliance certification report required by Section V.B must contain a certification 

statement for the above applicable requirement(s) (ARM 17.8.1212). 

E.6. The semi-annual reporting shall provide a summary of the results of any source testing that was 

performed (ARM 17.8.1212). 

F. EU019 – PASTE PLANT OIL HEATING SYSTEM - PP05 

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration 

Method Frequency 

Reporting 

Requirements 

F.1, F.2, F.3, 

F.4, F.5 

Opacity 40% Method 9 As Required by the 

Department and Section 

III.A.1 

Semi-annual 

Conditions

F.1. CFAC shall not cause or authorize emissions to be discharged to the atmosphere from the Paste Plant 

Oil Heating System-PP05 that exhibit an opacity of 40% or greater averaged over 6 consecutive 

minutes (ARM 17.8.304(1)). 

Compliance Demonstration

F.2. As required by the Department and Section III.A.1, CFAC shall perform a Method 9 test in 

accordance with the Montana Source Test Protocol and Procedures Manual. Each observation period 

shall be a minimum of 6 minutes, unless any one reading is 40% or greater, at which point the 

observation period shall be a minimum of 20 minutes or until a violation of the standard has been 

documented, whichever is the shorter period of time (ARM 17.8.1213). 

Record keeping

F.3. Method 9 tests shall be conducted in accordance with the Montana Source Test Protocol and 

Procedures Manual. Method 9 reports must be maintained on-site and must be submitted to the 

Department upon request (ARM 17.8.106). 

Reporting 

F.4. The annual compliance certification report required by Section V.B must contain a certification 

statement for the above applicable requirements (ARM 17.8.1212). 

F.5. The semi-annual reporting shall provide a summary of any source testing that was performed (ARM 

17.8.1212). 
OP2655-02 14 Date of Decision: 04/29/08 

Effective Date: 05/30/08 

 

G. EU020 - EU023 PRIMARY SCRUBBER SYSTEM ALUMINA TRANSFER EU’S 

EU020 - East Plant Dry Scrubber Alumina 

Transfer (North) - AR01 

EU022 - West Plant Dry Scrubber Alumina 

Transfer (North) - AR06 

EU021 - East Plant Dry Scrubber Alumina 

Transfer (South) - AR02 

EU023 - West Plant Dry Scrubber Alumina 

Transfer (South) - AR07 

Conditions Pollutant/ Compliance Demonstration 

Parameter 

Permit Limit 

Method Frequency 

Reporting 

Requirements 

Method 9 As Required by the 

Department and Section 

III.A.1 

G.1, G.3, G.4, G.6, Semi-annual 

G.8, G.9, G.10 

Opacity 20% 

Operations & 

Maintenance 

Baghouse I & M 

(Appendix I) 

Ongoing Semi-annual 

G.2, G.5, G.7, G.8, 

G.9, G.10 

Particulate Matter E = 55*P0.11 – 40 Method 5 As Required by the 

Department and Section 

III.A.1 

Semi-annual 

Conditions 

G.1. CFAC shall not cause or authorize emissions to be discharged to the atmosphere from the East Plant 

Dry Scrubber Alumina Transfer (North)-AR01, the East Plant Dry Scrubber Alumina Transfer 

(South)-AR02, the West Plant Dry Scrubber Alumina Transfer (North)-AR06, and the West Plant Dry 

Scrubber Alumina Transfer (South)-AR07, that exhibit an opacity of 20% or greater averaged over 6 

consecutive minutes (ARM 17.8.304(2)). 

G.2. The particulate emissions from process weight shall not exceed the value calculated by E = 55.0*P0.11-

40, where E is the rate of emissions in pounds per hour and P is the process weight rate in tons per 

hour (ARM 17.8.310). 

Compliance Demonstration

G.3. CFAC shall operate and maintain the baghouse for EU020 through EU023 in accordance with the 

Pollution Control Device Inspection & Maintenance Plan (Appendix I) (ARM 17.8.1213). 

G.4. As required by the Department and Section III.A.1, CFAC shall perform a Method 9 test in 

accordance with the Montana Source Test Protocol and Procedures Manual. Each observation period 

shall be a minimum of 6 minutes, unless any one reading is greater than 20%; then the observation 

period shall be a minimum of 20 minutes or until a violation of the standard has been documented, 

whichever is a shorter period of time (ARM 17.8.1213). 

G.5. As required by the Department and Section III.A.1, CFAC shall perform a Method 5 test in 

accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.1213). 

Record keeping

G.6. CFAC shall maintain on-site records of all inspection and maintenance activities performed on the 

baghouses in accordance with the Pollution Control Device Inspection & Maintenance Plan 

(Appendix I) and submit the records to the Department upon request (ARM 17.8.1212). 

G.7. Method 5 and Method 9 test reports shall be maintained on-site and shall be submitted to the 

Department in accordance with the Montana Source Protocol and Procedures Manual (ARM 

17.8.106). 
OP2655-02 15 Date of Decision: 04/29/08 

Effective Date: 05/30/08 

 

Reporting 

G.8. Any compliance source test reports must be submitted in accordance with the Montana Source Test 

Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212). 

G.9. The annual compliance certification report required by Section V.B must contain a certification statement 

for the above applicable requirements (ARM 17.8.1212). 

G.10. The semi-annual compliance monitoring reports shall include (ARM 17.8.1212): 

 a. The results of any source test conducted during the last reporting period; and 

b. Any corrective actions taken as a result of the inspections and maintenance as required by the 

Pollution Control Device Inspection & Maintenance Plan (Appendix I). 

H. EU024 - EU033 PRIMARY GAS COLLECTION SYSTEM EMITTING UNITS 

EU024 - Primary Gas Collection System - West 

Plant - Scrubber #1 - AR05 

EU029 - Primary Gas Collection System - East 

Plant - Scrubber #6 - AR05 

EU025 - Primary Gas Collection System - West 

Plant - Scrubber #2- AR05 

EU030 - Primary Gas Collection System - East 

Plant - Scrubber #7 - AR05 

EU026 - Primary Gas Collection System - West 

Plant - Scrubber #3 - AR05 

EU031 - Primary Gas Collection System - East 

Plant - Scrubber #8 - AR05 

EU027 - Primary Gas Collection System - West 

Plant - Scrubber #4 - AR05 

EU032 - Primary Gas Collection System - East 

Plant - Scrubber #9 - AR05 

EU028 - Primary Gas Collection System - East 

Plant - Scrubber #5 - AR05 

EU033 - Primary Gas Collection System - East 

Plant - Scrubber #10 - AR05 

Condition(s) Pollutant/ Compliance Demonstration 

Parameter 

Permit Limit 

Method Frequency 

Reporting 

Requirements 

Method 9 As Required by the 

Department and Section 

III.A.1 

H.1, H.4, H.5, 

H.6, H.10, H.13, 

H.14, H.15, H.16 

Opacity 20% 

Visual Survey Daily 

Semi-annual 

H.2, H.4, H.7, 

H.11, H.13, H.14, 

H.15, H.16, H.17 

Total Fluoride 

(TF) 

1.3 kg / Mg (per Month) or 

Table C of Appendix F 

Method 13B or 

CFAC MACT 

Implementation 

Plan (Appendix 

E) 

Annual Quarterly 

H.3, H.4, H.8, 

H.9, H.12, H.13, 

H.14, H.15, H.16, 

H.17 

Polycyclic 

Organic 

Matter (POM) 

2.85 kg / Mg (per Quarter) 

or Table C of Appendix F 

Method 315 or 

CFAC MACT 

Implementation 

Plan 

(Appendix E) 

Annual Quarterly 

Conditions

H.1. CFAC shall not cause or authorize emissions to be discharged to the atmosphere from West Plant 

Primary Gas Collection System, Scrubbers 1 through 4 (AR05), and the East Plant Primary Gas 

Collection System, Scrubbers 5 through 10 (AR05), that exhibit an opacity of 20% or greater averaged 

over 6 consecutive minutes (ARM 17.8.304(2)). 

H.2. CFAC shall not cause or authorize Total Fluoride (TF) emissions that exceed 1.3 kg of TF per 

milligrams (Mg) of aluminum produced (2.6 lb TF per ton of aluminum produced) from any single 

potline; or if CFAC is averaging the TF emissions from two or more potlines, the emission limit for 

the averaging scheme is prescribed in Appendix F, Table C, of this permit (ARM 17.8.331 and ARM 

17.8.342). 
OP2655-02 16 Date of Decision: 04/29/08 

Effective Date: 05/30/08 

 

H.3. CFAC shall not cause or authorize POM emissions that exceed 2.85 kilograms (kg) of POM per Mg of 

aluminum produced (5.7 lb POM per ton of aluminum produced) from any single potline; or if CFAC 

is averaging the POM emissions from two or more potlines, the emission limit for the averaging 

scheme is prescribed in Appendix F, Table C, of this permit (ARM 17.8.331 and ARM 17.8.342). 

Compliance Demonstration

H.4. Unless otherwise specified by rule, CFAC shall operate the Scrubbers on the Primary Gas Collection 

System at all times to demonstrate compliance with conditions III.H.1, III.H.2, and III.H.3 (ARM 

17.8.749). 

H.5. As required by the Department, CFAC shall perform a Method 9 test in accordance with the Montana 

Source Test Protocol and Procedures Manual. Each observation period shall be a minimum of 6 

minutes, unless any one reading is greater than 20%; then the observation period shall be a minimum 

of 20 minutes or until a violation of the standard has been documented, whichever is a shorter period 

of time (ARM 17.8.1213). 

H.6. Daily, CFAC shall visually survey the Primary Gas Collection System for any sources of excessive 

emissions. For the purpose of this survey, excessive emissions are considered to be any visible 

emissions, which meet or exceed 15% opacity. The person conducting the survey does not have to be 

an EPA Method 9 certified observer. However, the individual must have been certified as a Method 9 

observer within the previous two years of the visual survey being performed. If sources of excessive 

emissions are identified, CFAC shall immediately conduct a Method 9 or take corrective action to 

contain or minimize the source of emissions. If corrective actions are taken, then CFAC shall 

immediately conduct a subsequent visual survey to monitor compliance. The person conducting the 

visual survey shall record the results of the survey in a log, including any corrective action taken. 

Conducting a visual survey does not relieve CFAC of a liability for a violation determined using 

Method 9 (ARM 17.8.1213). 

H.7. CFAC shall annually perform at least one emission measurement test (three runs) for TF on each 

Primary Control System (West Plant and East Plant). That is, annually, CFAC will perform one 

emission measurement test run for TF on three of the four dry alumina scrubbers that comprise the 

Primary Control System of the West Plant; and annually CFAC will perform one emission measurement 

test run for TF on three of the six dry alumina scrubbers that comprise the Primary Control System of the 

East Plant. Also, CFAC will develop a testing schedule such that all dry aluminum scrubbers shall be 

tested for TF at least once (one test run) every 2 years. CFAC shall maintain a 12-month rolling average 

of TF emissions from the Primary Control Systems using the testing results of this requirement. All 

valid test runs must be used. TF Emissions determined by this requirement are combined with 

(measured) TF secondary emissions, and divided by the total aluminum production, to monitor 

compliance with TF emission limits (40 CFR Part 63, Subpart LL and ARM 17.8.1213). 

H.8. CFAC shall annually perform at least one emission measurement test (three runs) for POM on each 

Primary Control System (West Plant and East Plant). That is, annually, CFAC will perform one emission 

measurement test run for POM on three of the four dry alumina scrubbers that comprise the Primary 

Control System of the West Plant; and annually, CFAC will perform one emission measurement test run 

for POM on three of the six dry alumina scrubbers that comprise the Primary Control System of the East 

Plant. Also, CFAC will develop a testing schedule such that all dry aluminum scrubbers shall be tested for 

POM at least once (one test run) every 2 years. CFAC shall maintain a 12-month rolling average of POM 

emissions from the Primary Control Systems using the testing results of this requirement. All valid test 

runs must be used. POM Emissions determined by this requirement are combined with measured POM 

secondary emissions, and divided by the total aluminum production, to demonstrate compliance with POM 

emission limits (as prescribed in 40 CFR Part 63, Subpart LL and ARM 17.8.1213). 

H.9. Daily, CFAC must inspect the dry alumina scrubbers of the Primary Control Systems to ensure that the 

control devices are operating properly. If a monitoring device measures an operating parameter outside 

of the limits established in CFAC's Implementation Plan (Appendix E), then CFAC shall initiate 

corrective action procedures as identified in the Startup, Shutdown, and Malfunction Plan within one 
OP2655-02 17 Date of Decision: 04/29/08 

Effective Date: 05/30/08 

 

hour. If an operating parameter is exceeded six times in any (semi-annual) reporting period, then any 

subsequent exceedance in that reporting period is a violation. For the purpose of determining the 

number of exceedances, no more than one exceedance shall be attributed in any given 24-hour period 

(ARM 17.8.1213). 

Record keeping

H.10. Method 9 tests shall be conducted in accordance with the Montana Source Test Protocol and 

Procedures Manual. Method 9 test reports shall be maintained on-site and must be submitted to the 

Department upon request (ARM 17.8.106). 

H.11. CFAC shall maintain a record of the results from all valid TF emission measurement runs performed 

on the dry alumina scrubbers of the West and East Primary Control Systems. CFAC must calculate 

the rolling monthly average of TF emissions exhausted from the dry alumina scrubbers. The TF 

emissions from the Primary Control Systems will be calculated based upon the testing required in 

III.H.6 (ARM 17.8.1212). 

H.12. CFAC shall maintain a record of the results from all valid POM emission measurement runs 

performed on the dry alumina scrubbers of the West and East Primary Control Systems. CFAC must 

calculate the rolling monthly average of POM emissions exhausted from the dry alumina scrubbers. 

The POM emissions from the Primary Control Systems will be calculated based upon the testing 

required in III.H.7 (ARM 17.8.1212). 

H.13. CFAC shall maintain, on-site, a log including all visual observations monitoring compliance with 

the visual survey requirement. The log shall include the required information, the date, the time, 

and the initials of the documenting personnel (ARM 17.8.1212).

Reporting 

H.14. Any compliance source test reports must be submitted in accordance with the Montana Source Test 

Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212). 

H.15. The annual compliance certification report required by Section V.B shall contain a certification 

statement for the above applicable requirements (ARM 17.8.1212). 

H.16. The semi-annual compliance monitoring reports shall include a summary of the number of operating 

parameter exceedances, including visible emissions, occurring during the reporting period (ARM 

17.8.1212): 

H.17. The quarterly compliance monitoring reports shall include a summary of (ARM 17.8.1212): 

a. The results of all source testing that was performed during the quarter; 

b. The calculated TF and POM emissions from the Primary Control Systems (TF-Monthly and 

POM-Quarterly); 

c. The combined TF emissions from the Primary Control System and the secondary emissions from 

the potline roof monitors; 

d. The combined POM emissions from the Primary Control System and the secondary emissions 

from the potline roof monitors; 

e. The tons of aluminum produced (TAP) for each potline per month and quarter; 

f. The pound (lb) of TF emitted per TAP for each potline, and each emission averaging group, per 

month; 
OP2655-02 18 Date of Decision: 04/29/08 

Effective Date: 05/30/08 

 

g. The lb of POM emitted per TAP for each potline, and each emission averaging group, per quarter; 

and 

h. A summary of any corrective actions taken as a result of the daily visual surveys of visible 

emissions and operating parameters. 

Requirements III.H.13(c)-(h) above are the same as those specified in III.I.12(c)-(h). When CFAC 

complies with the requirements of c through h above, it is also satisfying the reporting requirements of 

III.I.12(c)-(h). 

I. EU034 - EU038 POTLINE ROOF VENT EMITTING UNITS 

EU034 - Potline #1 Roof Vent-West Plant - AR03 EU037 - Potline #4 Roof Vent- East Plant - AR03 

EU035 - Potline #2 Roof Vent-West Plant - AR03 EU038 - Potline #5 Roof Vent- East Plant - AR03 

EU036 - Potline #3 Roof Vent- East Plant - AR03 

Condition(s) Pollutant/ Compliance Demonstration 

Parameter 

Permit Limit 

Method Frequency 

Reporting 

Requirements 

I.1, I.4, I.5, Method 9 (Appendix H) Quarterly 

I.8, I.9, I.12, 

I.13, I.14 

Opacity 10% 

Visual Surveys 

(Appendix H) 

Daily 

Quarterly 

I.2, I.6, I.10, 

I.12, I.13, 

I.14 

Total Fluoride 

(TF) 

1.3 kg / Mg (per Month) 

or Table C of Appendix F 

Method 13B & Method 14 

(Appendix E) 

Three Test Runs 

per Month 

Quarterly 

I.3, I.7, I.11, 

I.12, I.13, 

I.14 

Polycyclic 

Organic Matter 

(POM) 

2.85 kg / Mg (per Quarter) 

or Table C of Appendix F 

Method 315 & Method 14 

(Appendix E) 

One Test Run per 

Month 

Quarterly 

Conditions

I.1. CFAC shall not cause or authorize emissions to be discharged to the atmosphere from the Roof Vents 

of Potlines 1 through 5 (AR03) that exhibit an opacity of 10% or greater averaged over 6 consecutive 

minutes (ARM 17.8.332). 

I.2. CFAC shall not cause or authorize TF emissions that exceed 1.3 kg of TF per Mg of aluminum 

produced (2.6-lb TF per ton of aluminum produced) from any single potline; or if CFAC is averaging 

the TF emissions from two or more potlines, the emission limit for the averaging scheme is prescribed 

in Appendix F, Table C (ARM 17.8.331 and ARM 17.8.342). 

I.3. CFAC shall not cause or authorize POM emissions that exceed 2.85kg of POM per Mg of aluminum 

produced (5.7-lb POM per ton of aluminum produced) from any single potline; or if CFAC is 

averaging the POM emissions from two or more potlines, the emission limit for the averaging scheme 

is prescribed in Appendix F, Table C (ARM 17.8.331 and ARM 17.8.342). 

Compliance Demonstration

I.4. A quarterly Method 9 test, performed in accordance with the procedures described in Appendix H of 

this permit, must be performed in accordance with the Montana Source Test Protocol and Procedures 

Manual. The Method 9 test shall be used to determine compliance with the 10% opacity limit. Each 

observation period shall be a minimum of 6 minutes, unless any one reading is greater than 10%; then 

the observation period shall be a minimum of 20 minutes or until a violation of the standard has been 

documented, whichever is a shorter period of time (ARM 17.8.1213). 

I.5. Daily, CFAC shall visually survey the Potline Roof Vent for any sources of excessive emissions. For 

the purpose of this survey, excessive emissions are considered to be any visible emissions, which meet 

or exceed 5% opacity. The person conducting the survey does not have to be an EPA Method 9 

certified observer. However, the individual must have been certified as a Method 9 observer within 

the previous two years of the visual survey being performed. If sources of excessive emissions are 
OP2655-02 19 Date of Decision: 04/29/08 

Effective Date: 05/30/08 

 

identified, CFAC shall immediately conduct a Method 9 or take corrective action to contain or 

minimize the source of emissions. If corrective actions are taken, then CFAC shall immediately 

conduct a subsequent visual survey to monitor compliance. The person conducting the visual survey 

shall record the results of the survey in a log, including any corrective action taken. Conducting a 

visual survey does not relieve CFAC of a liability for a violation determined using Method 9 (ARM 

17.8.1213). 

I.6. Monthly, CFAC shall perform at least three emission measurement test runs for TF on each potline (each 

Method 14 manifold system). Test runs must be the same duration as a pot cycle, or 48 hours. The 

minimum TF secondary emission testing schedule (three times per month) must adhere to the schedule 

defined in 40 CFR 63.847(b)(8); that is, at least one test run must be performed before the 15th of each 

month, one test run must be performed after the 15th of each month, and the remaining test run can occur 

at any time during the month, except that there must be at least 6 days between two of the runs. All valid 

test runs must be used when determining the secondary TF emissions. TF Emissions determined by this 

requirement are combined with the TF Primary Control System emissions (rolling monthly average), and 

divided by the total aluminum production, to monitor compliance with potline TF emission limits (as 

prescribed in 40 CFR 63, Subpart LL and ARM 17.8.1213). 

I.7. CFAC shall perform at least one emission measurement test run for POM each month on each potline 

(each Method 14 manifold system). Test runs must be the same duration as a pot cycle, or 48 hours. 

All valid test runs must be used when determining the secondary POM emissions. POM emissions 

determined by this requirement are combined with measured POM emissions from the Primary 

Control Systems, and divided by the total aluminum production, to monitor compliance with POM 

emission limits (as prescribed in 40 CFR Part 63, Subpart LL and ARM 17.8.1213). 

Record keeping

I.8. Method 9 tests shall be conducted in accordance to the Montana Source Test Protocol and Procedures 

Manual. The test reports shall be maintained on-site and must be submitted to the Department upon 

request (ARM 17.8.106). 

I.9. CFAC shall maintain on-site records of the daily visible emissions observed from the potline roofs, 

any exceedances above the 10% opacity requirement of III.I.1, and any maintenance or repair initiated 

as a result of excessive visible emissions from the potline roof monitors (ARM 17.8.1212). 

I.10. CFAC shall maintain a record of the results from all valid TF emission measurement runs performed 

on the Method 14 Manifolds for all potlines. The potline secondary TF emissions will be calculated 

based upon the testing required in III.I.6 (ARM 17.8.1212). 

I.11. CFAC shall maintain a record of the results from all valid POM emission measurement runs 

performed on the Method 14 Manifolds for all potlines. The potline secondary POM emissions will 

be calculated based upon the testing required in III.I.7 (ARM 17.8.1212). 

Reporting 

I.12. Any compliance source test reports must be submitted in accordance with the Montana Source Test 

Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212). 

I.13. The annual compliance certification report required by Section V.B must contain a certification 

statement for the above applicable requirements (ARM 17.8.1212). 

I.14. The quarterly reporting shall provide (ARM 17.8.1212): 

a. The results of all source testing that was performed during the quarter; 

b. The calculated secondary TF and POM emissions from the potline roofs (TF-Monthly and POMQuarterly); 
OP2655-02 20 Date of Decision: 04/29/08 

Effective Date: 05/30/08 

 

c. The combined TF emissions from the Primary Control System and the secondary emissions from 

the potline roof monitors; 

d. The combined POM emissions from the Primary Control System and the secondary emissions 

from the potline roof monitors; 

e. The TAP for each potline per month and quarter; 

f. The lb of TF emitted per TAP for each potline, and each emission averaging group, per month; 

g. The lb of POM emitted per TAP for each potline, and each emission averaging group, per quarter; 

h. The number of visible emission exceedances occurring during the quarter; and 

i. A summary of any corrective actions taken as a result of the daily visual surveys of visible 

emissions. 

Requirements III.I.12(c)-(h) above are the same as those specified in III.H.13(c)-(h). When CFAC 

complies with the requirements of c through h above, it is also satisfying the reporting requirements of 

III.H.13(c)-(h). 

J. EU039 - EU043 CASTING FURNACE EMITTING UNITS 

EU039 - Casting Furnace #3 - CO01 EU042 - Casting Furnace #7 - CO04 

EU040 - Casting Furnace #4 - CO02 EU043 - Casting Furnace #8 & #9 - CO05 

EU041 - Casting Furnace #6 - CO03 

Condition(s) Pollutant/ Compliance Demonstration 

Parameter 

Permit Limit 

Method Frequency 

Reporting 

Requirements 

J.1, J.4, J.5, J.6, 

J.7 

Opacity 40% Natural Gas or Liquid 

Petroleum Gas Combustion 

Ongoing Semi-annual 

Certification 

J.2, J.4, J.5, J.6, 

J.7 

Particulate Matter E = 0.882xH-0.1664 Natural Gas or Liquid 

Petroleum Gas Combustion 

Ongoing Semi-annual 

Certification 

J.3, J.4, J.5, J.6, 

J.7 

Sulfur in Fuel 50 gr/100 cu ft Natural Gas or Liquid 

Petroleum Gas Combustion 

Ongoing Semi-annual 

Certification 

Conditions

J.1. CFAC shall not cause or authorize emissions to be discharged to the atmosphere from Casting Furnace 

#3-CO01, Casting Furnace #4-CO02, Casing Furnace #6-CO03, Casting Furnace #7-CO04, and 

Casting Furnaces #8 & #9-CO05, that exhibit an opacity of 40% or greater averaged over 6 

consecutive minutes (ARM 17.8.304(1)). 

J.2. CFAC shall not cause or authorize particulate matter caused by combustion, from fuel burning 

equipment installed before November 23, 1968, to be discharged from any outdoor stack or chimney 

in excess of the value calculated by E = 0.882xH-0.1664, where H is the heat input capacity in MMBtu 

per hour and E is the maximum allowable particulate emissions rate in lb/MMBtu (ARM 17.8.309). 

J.3. CFAC shall not burn any gaseous fuel containing sulfur compounds in excess of 50 grains per 100 

cubic feet of gaseous fuel, calculated as hydrogen sulfide at standard conditions (ARM 17.8.322(5)). 

Compliance Demonstration

J.4. CFAC shall monitor compliance for the conditions in Section III.J.1, Section III.J.2, and Section III.J.3, 

pertaining to the facility’s natural gas casting furnaces by burning only natural gas or liquid petroleum 

gas. This does not preclude the Department from initiating an enforcement action if a Reference Method 

test indicates one of the limits is being violated (ARM 17.8.1213). 
OP2655-02 21 Date of Decision: 04/29/08 

Effective Date: 05/30/08 

 

Record keeping

J.5. CFAC shall maintain on-site a casting furnace operations log documenting any casting furnace 

stack specifications which deviate from normal operations as specified in Section III.J.1, III.J.2, 

and III.J.3. At a minimum, the furnace operations log shall include the required information, the 

date, and the initials of the documenting personnel (ARM 17.8.1212). 

Reporting 

J.6. The annual compliance certification report required by Section V.B shall contain a certification 

statement for the above applicable requirements, and that only natural gas or liquid petroleum gases 

were combusted (ARM 17.8.1212). 

J.7. The semi-annual compliance certification report shall summarize any deviations from normal 

operations as described in III.J.5 (ARM 17.8.1212). 

K. EU044 - EU048 CASTING PIT EMITTING UNITS 

EU044 - Casting Pit #3 - CO06 EU047 - Casting Pit #8 & #9 - CO06 

EU045 - Casting Pit #4 - CO06 EU048 – Dross Handling - CO07 

EU046 - Casting Pit #6 & #7 - CO06 

Condition(s) Pollutant/ Compliance Demonstration 

Parameter 

Permit Limit 

Method Frequency 

Reporting 

Requirements 

K.1, K.3, K.5, K.7 Opacity 40% Method 9 As Required by the 

Department and 

Section III.A.1 

Semi-annual 

K.2, K.4, K.6, K.7 Particulate Matter E = 4.10 x P 0.67 Normal Operations Ongoing Semi-annual 

Conditions

K.1. CFAC shall not cause or authorize emissions to be discharged to the atmosphere from Casting Pits #3, 

#4, #6, #7, #8, #9, (CO06), and Dross Handling-CO07, that exhibit an opacity of 40% or greater 

averaged over 6 consecutive minutes (ARM 17.8.304(1)). 

K.2. The particulate emissions from process weight shall not exceed the value calculated by E = 4.10 x P

0.67, where E is the rate of emissions in pounds per hour and P is the process weight rate in tons per 

hour (ARM 17.8.310). 

Compliance Demonstration

K.3. As required by the Department and Section III.A.1, CFAC shall perform a Method 9 test in 

accordance with the Montana Source Test Protocol and Procedures Manual. The Method 9 test shall 

be used to monitor compliance with the 40% opacity limit. Because all casting activities are 

conducted indoors, Method 9 testing will only focus on the visible emissions exiting from the 

openings of the casting buildings (ARM 17.8.1213). 

K.4. CFAC is required to maintain normal operations to monitor compliance with section III.K.2 (ARM 

17.8.1213). 

Record keeping

K.5. All test reports shall be maintained on-site and submitted to the Department in accordance with the 

Montana Source Test Protocol and Procedures Manual (ARM 17.8.106). 
OP2655-02 22 Date of Decision: 04/29/08 

Effective Date: 05/30/08 

 

K.6. CFAC shall maintain on-site a casting pit operations log documenting any casting pit vent 

specifications which deviate from normal operations as specified in Section III.K.1 and III.K.2. 

At a minimum, the casting pit operations log shall include the required information, the date, and 

the initials of the documenting personnel (ARM 17.8.1212). 

Reporting 

K.7. Any compliance source test reports must be submitted in accordance with the Montana Source Test 

Protocol and procedures manual (ARM 17.8.106 and ARM 17.8.1212). 

K.8. The annual compliance certification report required by Section V.B shall contain a certification statement 

for the above applicable requirements (ARM 17.8.1212). 

K.9. The semi-annual compliance monitoring reports shall contain a summary of (ARM 17.8.1212) 

a. Any source tests conducted during the period; and 

b. Any deviations from normal operations as described in III.K.6. 

L. EU049 - EU050 ALUMINUM SAW EMITTING UNITS 

EU049 – Sheet Ingot Saw - CO08 EU050 – T- Ingot Saw - CO09 

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration 

Method Frequency 

Reporting 

Requirements 

L.1, L.3, L.5, L.6, 

L.7, L.8 

Opacity 20% Method 9 As Required by the 

Department and Section 

III.A.1 

Semi-annual 

L.2, L.4, L.5, L.6, 

L.7, L.8 

Particulate Matter E = 4.10*P0.67 Method 5 As Required by the 

Department and Section 

III.A.1 

Semi-annual 

Conditions

L.1. CFAC shall not cause or authorize emissions from the Sheet Ingot Saw-CO08 that exhibit an opacity 

of 20% or greater averaged over 6 consecutive minutes (ARM 17.8.304(2)). As a result of venting 

indoors, EU050 (the T-Ingot Saw) is not currently subject to this requirement. 

L.2. The particulate emissions from process weight shall not exceed the value calculated by E = 4.10 x 

P0.67, where E is the rate of emissions in pounds per hour and P is the process weight rate in tons per 

hour (ARM 17.8.310). 

Compliance Demonstration

L.3. As required by the Department and Section III.A.1, CFAC shall perform a Method 9 test in 

accordance with the Montana Source Test Protocol and Procedures Manual. Each observation period 

shall be a minimum of 6 minutes, unless any one reading is 20% or greater, at which point the 

observation period shall be a minimum of 20 minutes or until a violation of the standard has been 

documented, whichever is the shorter period of time (ARM 17.8.1213). 

L.4. As required by the Department and Section III.A.1, CFAC shall test the above sources for particulate 

matter in accordance with Reference Method 5 to monitor compliance with the limitation contained in 

Section III.L.2. The source test must be performed as specified in the Montana Source Testing 

Protocol and Procedures Manual (ARM 17.8.106). 
OP2655-02 23 Date of Decision: 04/29/08 

Effective Date: 05/30/08 

 

Record keeping

L.5. All test reports shall be maintained on-site and submitted to the Department in accordance with the 

Montana Source Test Protocol and Procedures Manual (ARM 17.8.106). 

Reporting 

L.6. Any compliance source test reports must be submitted in accordance with the Montana Source Test 

Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212). 

L.7. The annual compliance certification report required by Section V.B must contain a certification 

statement for the above applicable requirements (ARM 17.8.1212). 

L.8. The semi-annual reporting shall provide a summary of any source testing conducted during the period 

(ARM 17.8.1212). 

M. EU051 – SANDBLASTING ACTIVITIES - CR01 

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration 

Method Frequency 

Reporting 

Requirements 

M.1, M.4, M.7, 

M.9, M.10, 

M.11 

Opacity 20% Method 9 As Required by 

the Department 

and Section 

III.A.1 

Semi-annual 

M.2, M.5, M.7, 

M.9, M.10, 

M.11 

Opacity Reasonable 

Precautions 

Visual Surveys Weekly Semi-annual 

M.3, M.6, M.7, 

M.8, M.9, 

M.10, M.11 

Particulate Matter E = 4.10*P0.67 Normal 

Operations 

Ongoing Semi-annual 

Conditions

M.1. CFAC shall not cause or authorize emissions to be discharged to the atmosphere from Sandblasting 

Activities-CR01 that exhibit an opacity of 20% or greater averaged over 6 consecutive minutes (ARM 

17.8.304(2)). 

M.2. CFAC shall not cause or authorize the production, handling, transportation, or storage of any material 

unless reasonable precautions to control emissions of particulate matter are taken. Such emission of 

airborne particulate matter from any stationary source shall not exhibit an opacity of 20% or greater 

averaged over 6 consecutive minutes, unless otherwise specified by rule or in this permit (ARM 

17.8.308(1)). 

M.3. CFAC shall not cause or authorize particulate matter to be discharged from any operation, process, or 

activity into the atmosphere in excess of the value calculated by E = 4.10x P0.67, where E is the 

emission rate in pounds per hour and P is the process weight rate in tons per hour (ARM 17.8.310). 

Compliance Demonstration

M.4. As required by the Department and Section III.A.1, CFAC shall perform a Method 9 test in 

accordance with the Montana Source Test Protocol and Procedures Manual. Each observation period 

shall be a minimum of 6 minutes, unless any one reading is 20% or greater, at which point the 

observation period shall be a minimum of 20 minutes or until a violation of the standard has been 

documented, whichever is the shorter period of time (ARM 17.8.1213). 
OP2655-02 24 Date of Decision: 04/29/08 

Effective Date: 05/30/08 

 

M.5. Once per calendar week during daylight hours, CFAC shall visually survey the Sandblasting units for 

any sources of excessive emissions. For the purpose of this survey, excessive emissions are 

considered to be any visible emissions, which meet or exceed 15% opacity. The person conducting 

the survey does not have to be an EPA Method 9 certified observer. However, the individual must 

have been certified as a Method 9 observer within the previous two years of the visual survey being 

performed. If sources of excessive emissions are identified, CFAC shall immediately conduct a 

Method 9 or take corrective action to contain or minimize the source of emissions. If corrective 

actions are taken, then CFAC shall immediately conduct a subsequent visual survey to monitor 

compliance. The person conducting the visual survey shall record the results of the survey in a log, 

including any corrective action taken. Conducting a visual survey does not relieve CFAC of a liability 

for a violation determined using Method 9 (ARM 17.8.1213). 

M.6. CFAC is required to maintain normal operations to monitor compliance with section III.M.3 (ARM 

17.8.1212) 

Record keeping

M.7. All test reports shall be maintained on-site and submitted to the Department in accordance with the 

Montana Source Test Protocol and Procedures Manual (ARM 17.8.106). 

M.8. The log of weekly visual survey results shall be maintained on-site and submitted to the Department 

upon request. The log shall include the required information, the date, the time, and the initials of 

the documenting personnel (ARM 17.8.1212).

M.9. CFAC shall maintain on-site a sandblasting operations log documenting any sandblasting 

emissions which deviate from normal operations as specified in Sections III.M.1, III.M.2, and 

III.M.3. At a minimum, the sandblasting operations log shall include the required information, 

the date, and the initials of the documenting personnel (ARM 17.8.1212). 

Reporting 

M.10. Any compliance source test reports must be submitted in accordance with the Montana Source Test 

Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212). 

M.11. The annual compliance certification report required by Section V.B shall contain a certification statement 

for the above applicable requirements (ARM 17.8.1212). 

M.12. The semi-annual reporting shall provide a summary of (ARM 17.8.1212): 

a. Any Method 9 tests that were performed; 

b. All visual surveys that were conducted; and 

c. Any instances of excessive emissions and any corrective actions taken as a result of excessive 

emissions. 

N. EU052 – LECTROMELT FURNACE EMITTING UNIT - CR03 

Condition(s) Pollutant/ Compliance Demonstration 

Parameter 

Permit Limit 

Method Frequency 

Reporting 

Requirements 

Method 9 As Required by the 

Department and Section 

III.A.1 

N.1, N.3, N.4, N.6, Semi-annual 

N.7, N.8, N.9, N.10 

Opacity 20% 

Baghouse I & M 

(Appendix I) 

Ongoing Semi-annual 

N.2, N.4, N.5, N.7, 

N.8, N.9, N.10 

Particulate Matter E = 4.10*P0.67 Method 5 As Required by the 

Department and Section 

III.A.1 

Semi-annual 
OP2655-02 25 Date of Decision: 04/29/08 

Effective Date: 05/30/08 

 

Conditions

N.1. CFAC shall not cause or authorize emissions to be discharged to the atmosphere from the Lectromelt 

Furnace-CR03 that exhibit an opacity of 20% or greater averaged over 6 consecutive minutes (ARM 

17.8.304(2)). 

N.2. The particulate emissions from process weight shall not exceed the value calculated by E = 4.10*P0.67, 

where E is the rate of emissions in pounds per hour and P is the process weight rate in tons per hour 

(ARM 17.8.310). 

Compliance Demonstration

N.3. As required by the Department and Section III.A.1, CFAC shall perform a Method 9 test in 

accordance with the Montana Source Test Protocol and Procedures Manual. The Method 9 test shall 

be used to determine compliance with the 20% opacity limit (ARM 17.8.1213). 

N.4. CFAC shall operate and maintain the baghouse in accordance with the Pollution Control Device Inspection 

& Maintenance Plan (Appendix I) (ARM 17.8.1213). 

N.5. As required by the Department and Section III.A.1, CFAC shall perform a Method 5 test in 

accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.1213). 

Record keeping 

N.6. CFAC shall maintain on-site records of all inspection and maintenance activities performed on the 

baghouses in accordance with the Pollution Control Device Inspection and Maintenance Plan 

(Appendix I) and submit such records to the Department upon request (ARM 17.8.1212). 

N.7. Method 5 and Method 9 test reports shall be maintained on-site and shall be submitted to the 

Department, upon request, in accordance with the Montana Source Protocol and Procedures Manual 

(ARM 17.8.106). 

Reporting 

N.8. Any compliance source test reports must be submitted in accordance with the Montana Source Test 

Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212). 

N.9. The annual compliance certification report required by Section V.B must contain a certification 

statement for the above applicable requirements (ARM 17.8.1212). 

N.10. The semi-annual compliance monitoring reports shall include a summary of (ARM 17.8.1212): 

 a. The results of any test conducted during the reporting period; and 

b. Any corrective actions taken as a result of the inspections and maintenance as required by the 

Pollution Control Device Inspection & Maintenance Plan (Appendix I). 

O. EU053–ROD MILL/MATERIAL STORAGE/BATH CRUSHING EMITTING UNIT-CR04 

Condition(s) Pollutant / Compliance Demonstration 

Parameter 

Permit Limit 

Method Frequency 

Reporting 

Requirements 

Method 9 As Required by the 

Department and Section 

III.A.1 

O.1, O.3, O.4, Semi-annual 

O.5, O.6, O.7, 

O.8, O.9 

Opacity 20% 

Operations & 

Maintenance Baghouse 

I & M (Appendix I) 

Ongoing Semi-annual 

O.2, O.3, O.4, 

O.5, O.6,O.7, 

O.8, O.9 

Particulate Matter E = 55*P0.11- 40 Method 5 As Required by the 

Department and Section 

III.A.1 

Semi-annual 
OP2655-02 26 Date of Decision: 04/29/08 

Effective Date: 05/30/08 

 

Conditions

O.1. CFAC shall not cause or authorize emissions to be discharged to the atmosphere from the Rod 

Mill/Material Storage/Bath Crushing Unit-CR04 that exhibit an opacity of 20% or greater averaged 

over 6 consecutive minutes (ARM 17.8.304(2)). 

O.2. The particulate emissions from process weight shall not exceed the value calculated by E = 55.0 x 

P0.11- 40, where E is the rate of emissions in pounds per hour and P is the process weight rate in tons 

per hour (ARM 17.8.310). 

Compliance Demonstration

O.3. CFAC shall operate and maintain the rod mill baghouse in accordance with the Pollution Control 

Device Inspection & Maintenance Plan (Appendix I) (Arm 17.8.1213). 

O.4. As required by the Department and Section III.A.1, CFAC shall perform Method 5 and Method 9 tests 

in accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.1213). 

Record keeping

O.5. CFAC shall maintain on-site records of all inspection and maintenance activities performed on the 

baghouses in accordance with the Pollution Control Device Inspection & Maintenance Plan 

(Appendix I) and submit such records to the Department upon request (ARM 17.8.1212). 

O.6. Method 5 and Method 9 test reports must be maintained on-site and must be submitted to the 

Department in accordance with the Montana Source Testing Protocol and Procedures Manual (ARM 

17.8.106). 

Reporting 

O.7. Any compliance source test reports must be submitted in accordance with the Montana Source Test 

Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212). 

O.8. The annual compliance certification report required by Section V.B shall contain a certification statement 

for the above applicable requirements (ARM 17.8.1212). 

O.9. The semi-annual compliance monitoring reports shall include (ARM 17.8.1212): 

 a. The results of any Method 5 or Method 9 tests conducted during the last reporting period; and 

 b. A summary of any corrective actions taken as a result of the inspections and maintenance as 

required by the Pollution Control Device Inspection & Maintenance Plan (Appendix I). 

P. EU054 – EU062 NATURAL GAS BOILER EMITTING UNITS 

EU054 - Change House Boiler #1 - MP01 EU059 - Paste Plant Boiler #1 - MP11 

EU055 - Change House Boiler #2 - MP02 EU060 - Paste Plant Boiler #2 - MP12 

EU056 - Lab Boiler #1 - MP07 EU061 - Warehouse Boiler #1 - MP16 

EU057 - Machine Shop Boiler #1 - MP08 EU062 - Warehouse Boiler #2 - MP17 

EU058 - Machine Shop Boiler #2 - MP09 

Condition(s) Pollutant/ Compliance Demonstration 

Parameter 

Permit Limit 

Method Frequency 

Reporting 

Requirements 

P.1, P.4, P.5, P.6, P.7 Opacity 20% Natural Gas Combustion Ongoing Semi-annual 

P.2, P.4, P.5, P.6, P.7 Particulate 

Matter 

E = 1.026*H-0.233 Natural Gas Combustion Ongoing Semi-annual 

P.3, P.4, P.5, P.6, P.7 Sulfur in Fuel 50 gr/100 cu ft Natural Gas Combustion Ongoing Semi-annual 
OP2655-02 27 Date of Decision: 04/29/08 

Effective Date: 05/30/08 

 

Conditions

P.1. CFAC shall not cause or authorize emissions to be discharged to the atmosphere from the Change 

House Boilers #1-MP01, Change House Boiler #2-MP02, the Lab Boiler #1-MP07, Machine Shop 

Boiler #1-MP08, Machine Shop Boiler #2-MP09, Paste Plant Boiler #1-MP11, Paste Plant Boiler #2-

MP12, Warehouse Boiler #1-MP16, and Warehouse Boiler #2-MP17, that exhibit an opacity of 20% 

or greater averaged over 6 consecutive minutes (ARM 17.8.304(2)). 

P.2. CFAC shall not cause or authorize particulate matter caused by combustion, from fuel burning 

equipment installed after November 23, 1968, to be discharged from any outdoor stack or chimney in 

excess of the value calculated by E = 1.026 x H-0.233, where H is the heat input capacity in MMBtu per 

hour and E is the maximum allowable particulate emissions rate in lb/MMBtu (ARM 17.8.309). 

P.3. CFAC shall not burn any gaseous fuel containing sulfur compounds in excess of 50 grains per 100 

cubic feet of gaseous fuel, calculated as hydrogen sulfide at standard conditions (ARM 17.8.322(5)). 

Compliance Demonstration

P.4. Monitoring compliance for Section III.P.1, III.P.2, and III.P.3 may be satisfied for their natural gas 

boilers by burning only natural gas. This does not preclude the Department from initiating an 

enforcement action if a Reference Method test indicates one of the limits is being violated (ARM 

17.8.1213). 

Record keeping

P.5. CFAC shall maintain on-site a boiler operations log documenting any boiler stack specifications 

which deviate from normal operations as specified in Sections III.P.1, III.P.2, and III.P.3. At a 

minimum, the boiler operations log shall include the required information, the date, and the 

initials of the documenting personnel (ARM 17.8.1212). 

Reporting 

P.6. The annual compliance certification report required by Section V.B must contain a certification 

statement for the above applicable requirements, and that only natural gas was combusted (ARM 

17.8.1212). 

P.7. The semi-annual compliance certification report shall summarize any deviations from normal 

operations as indicated in P.5 (ARM 17.8.1212). 

Q. EU063 – TRUCK, EQUIPMENT, AND HAUL ROAD EMISSIONS – MP05 

Condition(s) Pollutant/ Compliance Demonstration 

Parameter 

Permit Limit 

Method Frequency 

Reporting 

Requirements 

Q.1, Q.3, Q.4, 

Q.5, Q.6, Q.7 

Opacity 20% Method 9 As Required by the 

Department and Section 

III.A.1 

Semi-annual 

Method 9 As Required by the 

Department and Section 

III.A.1 

Q.2, Q.3, Q.4, Semi-annual 

Q.5, Q.6, Q.7 

Opacity Reasonable 

Precautions 

Maintenance, 

Treatment, and Speed 

As Needed Semi-annual 

Conditions

Q.1. CFAC shall not cause or authorize the production, handling, transportation, or storage of any material, 

unless reasonable precautions to control emissions of particulate matter are taken. Such emissions of 

airborne particulate matter from any stationary source shall not exhibit an opacity of 20% or greater 

averaged over 6 consecutive minutes, unless otherwise specified by rule or in this permit (ARM 

17.8.308(1)). 
OP2655-02 28 Date of Decision: 04/29/08 

Effective Date: 05/30/08 

 

Q.2. CFAC shall maintain all portions of the haul roads, access roads, parking lots, and general plant area 

as necessary to maintain compliance with the reasonable precautions limit in Section III.Q.1. CFAC 

shall treat all unpaved portions of the haul roads, access roads, parking lots, or the general plant 

area with water and/or chemical dust suppressant, as necessary, to maintain compliance with the 

reasonable precautions limitation in Section III.Q.1 (ARM 17.8.749).

Compliance Demonstration

Q.3. As required by the Department and Section III.A.1, CFAC shall perform a Method 9 test in 

accordance with the Montana Source Test Protocol and Procedures Manual. Each observation period 

shall be a minimum of 6 minutes, unless any one reading is 20% or greater, at which point the 

observation period shall be a minimum of 20 minutes or until a violation of the standard has been 

documented, whichever is the shorter period of time (ARM 17.8.1213). 

Record keeping

Q.4. All test reports shall be maintained on-site and submitted to the Department in accordance with the 

Montana Source Test Protocol and Procedures Manual (ARM 17.8.106). 

Reporting 

Q.5. Any compliance source test reports must be submitted in accordance with the Montana Source Test 

Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212). 

Q.6. The annual compliance certification report required by Section V.B must contain a certification stating 

whether CFAC is in compliance with the above applicable requirements (ARM 17.8.1212). 

Q.7. The semi-annual compliance reporting shall include the results of any Method 9 testing conducted 

during the period (ARM 17.8.1212). 

R. EU064 – GASOLINE STORAGE (TANK) EMITTING UNIT – MP04 

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration 

Method Frequency 

Reporting 

Requirements 

R.1, R.3, R.5, 

R.6, R.7, R.8 

Opacity 20% Method 9 As Required by 

the Department 

and Section 

III.A.1 

Semi-annual 

R.2, R.4, R.6, 

R.7, R.8 

Tanks Submerged Fill Log Ongoing Semi-annual 

Conditions

R.1. CFAC shall not cause or authorize emissions to be discharged to the atmosphere from any Gasoline 

Storage-MP04 that exhibit an opacity of 20% or greater averaged over 6 consecutive minutes (ARM 

17.8.304(2)). 

R.2. CFAC shall load (fill) the gasoline storage tank only through a permanent submerged fill pipe, or shall 

equip the tank with a vapor loss control device (ARM 17.8.324(3)). 

Compliance Demonstration

R.3. As required by the Department and Section III. A.1, CFAC shall perform a Method 9 test in 

accordance with the Montana Source Test Protocol and Procedures Manual. Each observation period 

shall be a minimum of 6 minutes, unless any one reading is 20% or greater, at which point the 

observation period shall be a minimum of 20 minutes or until a violation of the standard has been 

documented, whichever is the shorter period of time (ARM 17.8.1213). 
OP2655-02 29 Date of Decision: 04/29/08 

Effective Date: 05/30/08 

 

R.4. CFAC shall maintain of log of any instances in which the submerged fill pipe was not used (ARM 

17.8.1213). 

Record keeping

R.5. All test reports shall be maintained on-site and submitted to the Department in accordance with the 

Montana Source Test Protocol and Procedures Manual (ARM 17.8.106). 

R.6. CFAC shall maintain of log as required in Section III.R.4. The log shall include the circumstance, 

date, and initials of documenting personnel (ARM 17.8.1213). 

Reporting 

R.7. Any compliance source test reports must be submitted in accordance with the Montana Source Test 

Protocol and Procedures Manual (ARM 17.8.106 and ARM 17.8.1212). 

R.8. The annual compliance certification report required by Section V.B must contain a certification 

statement for the above applicable requirements (ARM 17.8.1212). 

R.9. The semi-annual reporting shall provide (ARM 17.8.1212): 

a. A summary of the results from any source testing that was performed; and 

b. A summary of any instances when the submerged pipe was not used during loading operations. 

S. EU065 – SOW CASTING LINE 

EU065 – Sow Casting Line 

Condition(s) Pollutant/ Compliance Demonstration 

Parameter 

Permit Limit 

Method Frequency 

Reporting 

Requirements 

S.1, S.3, S.5, S.7, 

S.8, S.9 

Opacity 40% Method 9 As Required by the 

Department and 

Section III.A.1 

Semi-annual 

S.2, S.4, S.6, S.7, 

S.8, S.9 

Particulate Matter E = 4.10 x P 0.67 Normal Operations Ongoing Semi-annual 

Conditions

S.1. CFAC shall not cause or authorize emissions to be discharged to the atmosphere from the Sow 

Casting Line that exhibit an opacity of 40% or greater averaged over 6 consecutive minutes (ARM 

17.8.304(1)). 

S.2. The particulate emissions from process weight shall not exceed the value calculated by E = 4.10 x P

0.67, where E is the rate of emissions in pounds per hour and P is the process weight rate in tons per 

hour (ARM 17.8.310). 

Compliance Demonstration

S.3. As required by the Department and Section III.A.1, CFAC shall perform a Method 9 test in 

accordance with the Montana Source Test Protocol and Procedures Manual. The Method 9 test shall 

be used to monitor compliance with the 40% opacity limit. Because all casting activities are 

conducted indoors, Method 9 testing will only focus on the visible emissions exiting from the 

openings of the casting buildings (ARM 17.8.1213). 
OP2655-02 30 Date of Decision: 04/29/08 

Effective Date: 05/30/08 

 

S.4. CFAC is required to maintain normal operations to monitor compliance with section III.S.2 (ARM 

17.8.1213). 

Record keeping

S.5. All test reports shall be maintained on-site and submitted to the Department in accordance with the 

Montana Source Test Protocol and Procedures Manual (ARM 17.8.106). 

S.6. CFAC shall maintain on-site a sow casting operations log documenting any casting pit vent 

specifications which deviate from normal operations as specified in Section III.S.1 and III.S.2. 

At a minimum, the sow casting operations log shall include the required information, the date, 

and the initials of the documenting personnel (ARM 17.8.1212). 

Reporting 

S.7. Any compliance source test reports must be submitted in accordance with the Montana Source Test 

Protocol and procedures manual (ARM 17.8.106 and ARM 17.8.1212). 

S.8. The annual compliance certification report required by Section V.B shall contain a certification statement 

for the above applicable requirements (ARM 17.8.1212). 

S.9. The semi-annual compliance monitoring reports shall contain (ARM 17.8.1212): 

a. A summary of the results of any source tests that were performed; and 

b. Any deviations from normal operations as described in Section III.S.6. 
OP2655-02 31 Date of Decision: 04/29/08 

Effective Date: 05/30/08 

 

SECTION IV NON-APPLICABLE REQUIREMENTS 

Air Quality Administrative Rules of Montana (ARM) and Federal Regulations identified as not applicable to 

the facility or to a specific emission unit at the time of the permit issuance are listed below (ARM 17.8.1214). 

The following list does not preclude the need to comply with any new requirements that may become 

applicable during the permit term. 

A. FACILITY-WIDE 

The following table contains non-applicable requirements that are administrated by the Air Resources 

Management Bureau of the Department of Environmental Quality. 

Rule Citation 

State Federal 

Reason 

ARM 17.8.321, 

ARM 17.8.323, and 

ARM 17.8.610 

These rules are not applicable because the facility is not listed in 

the source category cited in the rules. 

ARM 17.8 316 

ARM 17.8.320, 

ARM 17.8.324(4)-(6) 

These rules are not applicable because the facility does not have 

the specific emission unit cited in the rules. 

40 CFR 60, Subparts C, Ca, Cb 

40 CFR 60, Subparts D, Da, Db, Dc 

40 CFR 60, Subparts E-J 

40 CFR 60, Subparts K, Ka, Kb 

40 CFR 60, Subparts L-Z 

40 CFR 60, Subparts AA-EE 

40 CFR 60, Subparts GG-HH 

40 CFR 60, Subparts KK-NN 

40 CFR 60, Subparts PP-XX 

40 CFR 60, Subparts AAA-BBB 

40 CFR 60, Subparts DDD 

40 CFR 60, Subparts FFF-LLL 

40 CFR 60, Subparts NNN-VVV 

40 CFR 61, Subparts B-F 

40 CFR 61, Subparts H-L 

40 CFR 61, Subparts N-R 

40 CFR 61, Subparts V-W 

40 CFR 61, Subpart Y 

40 CFR 61, Subpart BB 

40 CFR 61, Subpart FF 

These requirements are not applicable because the facility is not 

an affected source as defined in these regulations. 

40 CFR 63, Subpart B 

40 CFR 63, Subparts F-I 

40 CFR 63, Subparts L-M 

40 CFR 63, Subpart Q 

40 CFR 82, Subparts A-E 

40 CFR 82, Subparts G-H 

These requirements are not applicable because the facility is not 

an affected source as defined in these regulations. 

40 CFR 72 through 

40 CFR 78. 

These requirements are not applicable because the facility is not 

an affected source as defined by the acid rain regulations. 

40 CFR 68 This rule is not applicable because the facility does not meet the 

threshold quantity for any regulated substance. 

B. EMISSION UNITS 

The permit application identified applicable requirements: non-applicable requirements for individual or 

specific emission units were not listed. The Department has listed all non-applicable requirements in 

Section IV.A; these requirements relate to each specific unit as well as facility wide. 
OP2655-02 32 Date of Decision: 04/29/08 

Effective Date: 05/30/08 

 

SECTION V – GENERAL PERMIT CONDITIONS 

A. Compliance Requirements 

ARM 17.8, Subchapter 12, Operating Permit Program §1210(2)(a)-(c)&(e), §1206(6)(c)&(b)

1. The permittee must comply with all conditions of the permit. Any noncompliance with the 

terms or conditions of the permit constitutes a violation of the Montana Clean Air Act, and may 

result in enforcement action, permit modification, revocation and reissuance, or termination, or 

denial of a permit renewal application under ARM Title 17, Chapter 8, Subchapter 12. 

2. The filing of a request by the permittee for a permit modification, revocation and reissuance, or 

termination, or of a notification of planned changes or anticipated noncompliance does not stay 

any permit condition. 

3. It shall not be a defense for a permittee in an enforcement action that it would have been 

necessary to halt or reduce the permitted activity in order to maintain compliance with the 

conditions of the permit. If appropriate, this factor may be considered as a mitigating factor in 

assessing a penalty for noncompliance with an applicable requirement if the source 

demonstrates that both the health, safety, or environmental impacts of halting or reducing 

operations would be more serious than the impacts of continuing operations, and that such 

health, safety, or environmental impacts were unforeseeable and could not have otherwise been 

avoided. 

4. The permittee shall furnish to the Department, within a reasonable time set by the Department 

(not to be less than 15 days), any information that the Department may request in writing to 

determine whether cause exists for modifying, revoking and reissuing, or terminating the 

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

furnish to the Department copies of those records that are required to be kept pursuant to the 

terms of the permit. This subsection does not impair or otherwise limit the right of the 

permittee to assert the confidentiality of the information requested by the Department, as 

provided in 75-2-105, MCA. 

5. Any schedule of compliance for applicable requirements with which the source is not in 

compliance with at the time of permit issuance shall be supplemental to, and shall not sanction 

noncompliance with, the applicable requirements on which it was based. 

6. For applicable requirements that will become effective during the permit term, the source shall 

meet such requirements on a timely basis unless a more detailed plan or schedule is required by 

the applicable requirement or the Department. 

B. Certification Requirements 

ARM 17.8, Subchapter 12, Operating Permit Program §1207 and §1213(7)(a)&(c)-(d)

1. Any application form, report, or compliance certification submitted pursuant to ARM Title 17, 

Chapter 8, Subchapter 12, shall contain certification by a responsible official of truth, accuracy, 

and completeness. This certification and any other certification required under ARM Title 17, 

Chapter 8, Subchapter 12, shall state that, based on information and belief formed after 

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

complete. 

2. Compliance certifications shall be submitted by February 15 of each year, or more frequently if 

otherwise specified in an applicable requirement or elsewhere in the permit. Each certification 

must include the required information for the previous calendar year (i.e., January 1 – 

December 31). 
OP2655-02 33 Date of Decision: 04/29/08 

Effective Date: 05/30/08 

 

3. Compliance certifications shall include the following: 

a. The identification of each term or condition of the permit that is the basis of the 

certification; 

b. The identification of the method(s) or other means used by the owner or operator for 

determining the status of compliance with each term or condition during the certification 

period, consistent with ARM 17.8.1212; 

c. The status of compliance with the terms and conditions of the permit for the period covered 

by the certification, including whether compliance during the period was continuous or 

intermittent (based on the method or means identified in ARM 17.8.1213(7)(c)(ii), as 

described above); and 

d. Such other facts as the Department may require to determine the compliance status of the 

source. 

4. All compliance certifications must be submitted to the EPA, as well as to the Department, at the 

addresses listed in the Notification Addresses Appendix of this permit. 

C. Permit Shield 

ARM 17.8, Subchapter 12, Operating Permit Program §1214(1)-(4)

1. The applicable requirements and non-federally enforceable requirements are included and 

specifically identified in this permit and the permit includes a precise summary of the 

requirements not applicable to the source. Compliance with the conditions of the permit shall 

be deemed compliance with any applicable requirements and any non-federally enforceable 

requirements as of the date of permit issuance. 

2. The permit shield described in one above shall remain in effect during the appeal of any permit 

action (renewal, revision, reopening, or revocation and reissuance) to the Board, until such time 

as the Board renders its final decision. 

3. Nothing in this permit alters or affects the following: 

a. The provisions of Sec. 7603 of the Federal Clean Air Act (FCAA), including the authority 

of the administrator under that section. 

b. The liability of an owner or operator of a source for any violation of applicable 

requirements prior to or at the time of permit issuance. 

c. The applicable requirements of the Acid Rain Program, consistent with Sec. 7651g(a) of 

the FCAA. 

d. The ability of the administrator to obtain information from a source pursuant to Sec. 7414 

of the FCAA. 

e. The ability of the Department to obtain information from a source pursuant to the Montana 

Clean Air Act, Title 75, Chapter 2, MCA. 

f. The emergency powers of the Department under the Montana Clean Air Act, Title 75, 

Chapter 2, MCA. 
OP2655-02 34 Date of Decision: 04/29/08 

Effective Date: 05/30/08 

 

g. The ability of the Department to establish or revise requirements for the use of Reasonably 

Available Control Technology (RACT) as defined in ARM Title 17, Chapter 8. However, 

if the inclusion of a RACT into the permit pursuant to ARM Title 17, Chapter 8, 

Subchapter 12, is appealed to the Board, the permit shield, as it applies to the source’s 

existing permit, shall remain in effect until such time as the Board has rendered its final 

decision. 

4. Nothing in this permit alters or affects the ability of the Department to take enforcement action 

for a violation of an applicable requirement or permit term demonstrated pursuant to ARM 

17.8.106, Source Testing Protocol. 

5. Pursuant to ARM 17.8.132, for the purpose of submitting a compliance certification, nothing in 

these rules shall preclude the use, including the exclusive use, of any credible evidence or 

information relevant to whether a source would have been in compliance. However, when 

compliance or noncompliance is demonstrated by a test or procedure provided by permit or 

other applicable requirements, the source shall then be presumed to be in compliance or 

noncompliance unless that presumption is overcome by other relevant credible evidence. 

6. The permit shield will not extend to minor permit modifications or changes not requiring a 

permit revision (see Sections I & J). 

7. The permit shield will extend to significant permit modifications and transfer or assignment of 

ownership (see Sections K & N). 

D. Monitoring, Record keeping, and Reporting Requirements 

ARM 17.8, Subchapter 12, operating Permit Program §1212(2)&(3)

1. Unless otherwise provided in this permit, the permittee shall maintain compliance monitoring 

records that include the following information. 

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

b. The date(s) analyses were performed; 

c. The company or entity that performed the analyses; 

d. The analytical techniques or methods used; 

e. The results of such analyses; and 

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

2. The permittee shall retain records of all required monitoring data and support information for a 

period of at least five years from the date of the monitoring sample, measurement, report, or 

application. Support information includes all calibration and maintenance records and all 

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

reports required by the permit. All monitoring data, support information, and required reports 

and summaries may be maintained in computerized form at the plant site if the information is 

made available to Department personnel upon request, which may be for either hard copies or 

computerized format. Strip-charts must be maintained in their original form at the plant site and 

shall be made available to Department personnel upon request. 
OP2655-02 35 Date of Decision: 04/29/08 

Effective Date: 05/30/08 

 

3. The permittee shall submit to the Department, at the addresses located in the Notification 

Addresses Appendix of this permit, reports of any required monitoring by February 15 and 

August 15 of each year, or more frequently if otherwise specified in an applicable requirement 

or elsewhere in the permit. The monitoring report submitted on February 15 of each year must 

include the required monitoring information for the period of July 1 through December 31 of 

the previous year. The monitoring report submitted on August 15 of each year must include the 

required monitoring information for the period of January 1 through June 30 of the current year. 

All instances of deviations from the permit requirements must be clearly identified in such 

reports. All required reports must be certified by a responsible official, consistent with ARM 

17.8.1207. 

E. Prompt Deviation Reporting 

ARM 17.8, Subchapter 12, Operating Permit Program §1212(3)(c)

The permittee shall promptly report deviations from permit requirements, including those 

attributable to upset conditions as defined in the permit, the probable cause of such deviations, and 

any corrective actions or preventive measures taken. To be considered prompt, deviations shall be 

reported as part of the routine reporting requirements under ARM 17.8.1212(3)(b) and, if applicable, 

in accordance with the malfunction reporting requirements under ARM 17.8.110, unless otherwise 

specified in an applicable requirement. 

F. Emergency Provisions 

ARM 17.8, Subchapter 12, Operating Permit Program §1201(13) and §1214(5), (6)&(8)

1. An “emergency” means any situation arising from sudden and reasonably unforeseeable events 

beyond the control of the source, including acts of God, which situation requires immediate 

corrective action to restore normal operation and causes the source to exceed a technologybased emission limitation under this permit due to the unavoidable increases in emissions 

attributable to the emergency. An emergency shall not include noncompliance to the extent 

caused by improperly designed equipment, lack of reasonable preventive maintenance, careless 

or improper operation, or operator error. 

2. An emergency constitutes an affirmative defense to an action brought for noncompliance with a 

technology-based emission limitation if the permittee demonstrates through properly signed, 

contemporaneous logs, or other relevant evidence, that: 

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

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

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

levels of emissions that exceeded the emission standards or other requirements in the 

permit. 

d. The permittee submitted notice of the emergency to the Department within two working 

days of the time when emission limitations were exceeded due to the emergency. This 

notice fulfills the requirements of ARM 17.8.1212(3)(c). This notice must contain a 

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

taken. 

3. These emergency provisions are in addition to any emergency, malfunction, or upset provision 

contained in any applicable requirement. 
OP2655-02 36 Date of Decision: 04/29/08 

Effective Date: 05/30/08 

 

G. Inspection and Entry 

ARM 17.8, Subchapter 12, Operating Permit Program §1213(3)&(4)

1. Upon presentation of credentials and other requirements as may be required by law, the 

permittee shall allow the Department, the administrator, or an authorized representative 

(including an authorized contractor acting as a representative of the Department or the 

administrator) to perform the following: 

a. Enter the premises where a source required to obtain a permit is located, or emissionsrelated activity is conducted, or where records must be kept under the conditions of the 

permit. 

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

conditions of the permit. 

c. Inspect at reasonable times any facilities, emission units, equipment (including monitoring 

and air pollution control equipment), practices, or operations regulated or required under 

the permit. 

d. As authorized by the Montana Clean Air Act and rules promulgated thereunder sample or 

monitor, at reasonable times, any substances or parameters at any location for the purpose 

of assuring compliance with the permit or applicable requirements. 

2. The permittee shall inform the inspector of all workplace safety rules or requirements at the 

time of inspection. This section shall not limit in any manner the Department’s statutory right 

of entry and inspection as provided for in 75-2-403, MCA. 

H. Fee Payment 

ARM 17.8, Subchapter 12, Operating Permit Program §1210(2)(f) and ARM 17.8, Subchapter 5, Air 

Quality Permit Application, Operation, and Open Burning Fees §505(3)-(5) (STATE ONLY)

1. The permittee must pay application and operating fees, pursuant to ARM Title 17, Chapter 8, 

Subchapter 5. 

2. Annually, the Department shall provide the permittee with written notice of the amount of the 

fee and the basis for the fee assessment. The air quality operation fee is due 30 days after 

receipt of the notice, unless the fee assessment is appealed pursuant to ARM 17.8.511. If any 

portion of the fee is not appealed, that portion of the fee that is not appealed is due 30 days after 

receipt of the notice. Any remaining fee, which may be due after the completion of an appeal, 

is due immediately upon issuance of the Board’s decision or upon completion of any judicial 

review of the Board’s decision. 

3. If the permittee fails to pay the required fee (or any required portion of an appealed fee) within 

90 days of the due date of the fee, the Department may impose an additional assessment of 15% 

of the fee (or any required portion of an appealed fee) or $100, whichever is greater, plus 

interest on the fee (or any required portion of an appealed fee), computed at the interest rate 

established under 15-31-510(3), MCA. 

I. Minor Permit Modifications 

ARM 17.8, Subchapter 12, Operating Permit Program §1226(3)&(11)

1. An application for a minor permit modification need only address in detail those portions of the 

permit application that require revision, updating, supplementation, or deletion, and may 

reference any required information that has been previously submitted. 
OP2655-02 37 Date of Decision: 04/29/08 

Effective Date: 05/30/08 

 

2. The permit shield under ARM 17.8.1214 will not extend to any minor modifications processed 

pursuant to ARM 17.8.1226. 

J. Changes Not Requiring Permit Revision 

ARM 17.8, Subchapter 12, Operating Permit Program §1224(1)-(3), (5)&(6)

1. The permittee is authorized to make changes within the facility as described below, provided 

the following conditions are met. 

a. The proposed changes do not require the permittee to obtain an air quality preconstruction 

permit under ARM Title 17, Chapter 8, Subchapter7. 

b. The proposed changes are not modifications under Title I of the FCAA, or as defined in 

ARM Title 17, Chapter 8, Subchapters 8, 9, or 10. 

c. The emissions resulting from the proposed changes do not exceed the emissions allowable 

under this permit, whether expressed as a rate of emissions or in total emissions. 

d. The proposed changes do not alter permit terms that are necessary to enforce applicable 

emission limitations on emission units covered by the permit. 

e. The facility provides the administrator and the Department with written notification at least 

7 days prior to making the proposed changes. 

2. The permittee and the Department shall attach each notice provided pursuant to 1.e above to 

their respective copies of this permit. 

3. Pursuant to the conditions above, the permittee is authorized to make Section 502(b)(10) 

changes, as defined in ARM 17.8.1201(30), without a permit revision. For each such change, 

the written notification required under 1.e above shall include a description of the change within 

the source, the date on which the change will occur, any change in emissions, and any permit 

term or condition that is no longer applicable as a result of the change. 

4. The permittee may make a change not specifically addressed or prohibited by the permit terms 

and conditions without requiring a permit revision, provided the following conditions are met. 

a. Each proposed change does not weaken the enforceability of any existing permit 

conditions. 

b. The Department has not objected to such change. 

c. Each proposed change meets all applicable requirements and does not violate any existing 

permit term or condition. 

d. The permittee provides contemporaneous written notice to the Department and the 

administrator of each change that is above the level for insignificant emission units as 

defined in ARM 17.8.1201(22) and 17.8.1206(3), and the written notice describes each 

such change, including the date of the change, any change in emissions, pollutants emitted, 

and any applicable requirement that would apply as a result of the change. 

5. The permit shield authorized by ARM 17.8.1214 shall not apply to changes made pursuant to 

ARM 17.8.1224(3) and (5), but is applicable to terms and conditions that allow for increases 

and decreases in emissions pursuant to ARM 17.8.1224(4). 
OP2655-02 38 Date of Decision: 04/29/08 

Effective Date: 05/30/08 

 

K. Significant Permit Modifications 

ARM 17.8, Subchapter 12, Operating Permit Program §1227(1), (3)&(4)

1. The modification procedures set forth in 2 below must be used for any application requesting a 

significant modification of this permit. Significant modifications include the following: 

a. Any permit modification that does not qualify as either a minor modification or as an 

administrative permit amendment; 

b. Every significant change in existing permit monitoring terms or conditions; 

c. Every relaxation of permit reporting or record keeping terms or conditions that limit the 

Department’s ability to determine compliance with any applicable rule, consistent with the 

requirements of the rule; or 

d. Any other change determined by the Department to be significant. 

2. Significant modifications shall meet all requirements of ARM Title 17, Chapter 8, including 

those for applications, public participation, and review by affected states and the administrator, 

as they apply to permit issuance and renewal, except that an application for a significant permit 

modification need only address in detail those portions of the permit application that require 

revision, updating, supplementation or deletion. 

3. The permit shield provided for in ARM 17.8.1214 shall extend to significant modifications. 

L. Reopening for Cause 

ARM 17.8, Subchapter 12, Operating Permit Program §1228(1)&(2)

This permit may be reopened and revised under the following circumstances. 

1. Additional applicable requirements under the FCAA become applicable to the facility when 

the permit has a remaining term of three or more years. Reopening and revision of the 

permit shall be completed not later than 18 months after promulgation of the applicable 

requirement. No reopening is required under ARM 17.8.1228(1)(a) if the effective date of 

the applicable requirement is later than the date on which the permit is due to expire, unless 

the original permit or any of its terms or conditions have been extended pursuant to ARM 

17.8.1220(12) or 17.8.1221(2). 

2. Additional requirements (including excess emission requirements) become applicable to an 

affected source under the Acid Rain Program. Upon approval by the administrator, excess 

emission offset plans shall be deemed incorporated into the permit. 

3. The Department or the administrator determines that the permit contains a material mistake 

or that inaccurate statements were made in establishing the emission standards or other 

terms or conditions of the permit. 

4. The administrator or the Department determines that the permit must be revised or revoked 

and reissued to ensure compliance with the applicable requirements. 

M. Permit Expiration and Renewal 

ARM 17.8, Subchapter 12, Operating Permit Program §1210(2)(g), §1220(11)&(12), and §1205(2)(d)

1. This permit is issued for a fixed term of five years. 
OP2655-02 39 Date of Decision: 04/29/08 

Effective Date: 05/30/08 

 

2. Renewal of this permit is subject to the same procedural requirements that apply to permit 

issuance, including those for application, content, public participation, and affected state and 

administrator review.

3. Expiration of this permit terminates the permittee’s right to operate unless a timely and 

administratively complete renewal application has been submitted consistent with ARM 

17.8.1221 and 17.8.1205(2)(d). If a timely and administratively complete application has been 

submitted, all terms and conditions of the permit, including the application shield, remain in 

effect after the permit expires until the permit renewal has been issued or denied. 

4. For renewal, the permittee shall submit a complete air quality operating permit application to 

the Department not later than 6 months prior to the expiration of this permit, unless otherwise 

specified. If necessary to ensure that the terms of the existing permit will not lapse before 

renewal, the Department may specify, in writing to the permittee, a longer time period for 

submission of the renewal application. Such written notification must be provided at least one 

year before the renewal application due date established in the existing permit. 

N. Severability Clause 

ARM 17.8, Subchapter 12, Operating Permit Program §1210(2)(i)&(l)

1. The administrative appeal or subsequent judicial review of the issuance by the Department of an 

initial permit under this subchapter shall not impair in any manner the underlying applicability 

of all applicable requirements, and such requirements continue to apply as if a final permit 

decision had not been reached by the Department. 

2. If any provision of a permit is found to be invalid, all valid parts that are severable from the 

invalid part remain in effect. If a provision of a permit is invalid in one or more of its 

applications, the provision remains in effect in all valid applications that are severable from the 

invalid applications. 

O. Transfer or Assignment of Ownership 

ARM 17.8, Subchapter 12, Operating Permit Program §1225(2)&(4)

1. If an administrative permit amendment involves a change in ownership or operational control, 

the applicant must include in its request to the Department a written agreement containing a 

specific date for the transfer of permit responsibility, coverage and liability between the current 

and new permittee. 

2. The permit shield provided for in ARM17.8.1214 shall not extend to administrative permit 

amendments. 

P. Emissions Trading, Marketable Permits, Economic Incentives 

ARM 17.8, Subchapter 12, Operating Permit Program §1226(2)

Notwithstanding ARM 17.8.1226(1) and (7), minor air quality operating permit modification 

procedures may be used for permit modifications involving the use of economic incentives, 

marketable permits, emissions trading, and other similar approaches, to the extent that such minor 

permit modification procedures are explicitly provided for in the Montana State Implementation Plan 

(SIP) or in applicable requirements promulgated by the administrator. 

Q. No Property Rights Conveyed 

ARM 17.8, Subchapter 12, Operating Permit Program §1210(2)(d)

This permit does not convey any property rights of any sort, or any exclusive privilege. 
OP2655-02 40 Date of Decision: 04/29/08 

Effective Date: 05/30/08 

 

R. Testing Requirements 

ARM 17.8, Subchapter 1, General Provisions §105

The permittee shall comply with ARM 17.8.105. 

S. Source Testing Protocol 

ARM 17.8, Subchapter 1, General Provisions §106

The permittee shall comply with ARM 17.8.106. 

T. Malfunctions 

ARM 17.8, Subchapter 1, General Provisions §110

The permittee shall comply with ARM 17.8.110. 

U. Circumvention 

ARM 17.8, Subchapter 1, General Provisions §111

The permittee shall comply with ARM 17.8.111. 

V. Motor Vehicles 

ARM 17.8, Subchapter 3, Emission Standards §325

The permittee shall comply with ARM 17.8.325. 

W. Annual Emissions Inventory 

ARM 17.8, Subchapter 5, Air Quality Permit Application, Operation and Open Burning Fees §505 

(STATE ONLY)

The permittee shall supply the Department with annual production and other information for all 

emission units necessary to calculate actual or estimated actual amount of air pollutants emitted 

during each calendar year. Information shall be gathered on a calendar-year basis and submitted to 

the Department by the date required in the emission inventory request, unless otherwise specified in 

this permit. Information shall be in the units required by the Department. 

X. Open Burning 

ARM 17.8, Subchapter 6, Open Burning §604, 605 and 606

The permittee shall comply with ARM 17.8.604, 605 and 606. 

Y. Preconstruction Permits 

ARM 17.8, Subchapter 7, Permit, Construction and Operation of Air Contaminant Sources §743, 

744, 745 and 764 (ARM 17.8.745(1), and 764(1)(b) are STATE ENFORCEABLE ONLY until 

approval by the EPA as part of the SIP) 

1. Except as specified, no person shall construct, install, alter, or use any air contaminant source or 

stack associated with any source without first obtaining a permit from the Department or Board. 

A permit is not required for those sources or stacks as specified by ARM 17.8.745(1). 

2. The permittee shall comply with ARM 17.8.743, 744, 745, 748 and 764. 

3. ARM 17.8.745(1) specifies de minimis changes as construction or changed conditions of 

operation at a facility holding an air quality preconstruction permit issued under Chapter 8 that 

does not increase the facility’s potential to emit by more than 15 tons per year of any pollutant, 

except (STATE ENFORCEABLE ONLY until approved by the EPA as part of the SIP): 
OP2655-02 41 Date of Decision: 04/29/08 

Effective Date: 05/30/08 

 

a. Any construction or changed condition that would violate any condition in the facility’s 

existing air quality preconstruction permit or any applicable rule contained in Chapter 8 is 

prohibited, except as provided in ARM 17.8.745(2). 

b. Any construction or changed conditions of operation that would qualify as a major 

modification under Subchapters 8, 9, or 10 of Chapter 8. 

c. Any construction or changed condition of operation that would affect the plume rise or 

dispersion characteristic of emissions that would cause or contribute to a violation of an 

ambient air quality standard or ambient air increment as defined in ARM 17.8.804. 

d. Any construction or improvement project with a potential to emit more than 15 tons per 

year may not be artificially split into smaller projects to avoid air quality preconstruction 

permitting. 

e. Emission reductions obtained through offsetting within a facility are not included when 

determining the potential emission increase from construction or changed conditions of 

operation, unless such reductions are made federally enforceable. 

4. Any facility making a de minimis change pursuant to ARM 17.8.745(1) shall notify the 

Department if the change would include a change in control equipment, stack height, stack 

diameter, stack gas temperature, source location or fuel specifications, or would result in an 

increase in source capacity above its permitted operation or the addition of a new emission unit. 

The notice must be submitted, in writing, 10 days prior to start up or use of the proposed de 

minimis change, or as soon as reasonably practicable in the event of an unanticipated 

circumstance causing the de minimis change, and must include the information requested in 

ARM 17.8.745(1). (STATE ENFORCEABLE ONLY until approval by the EPA as part of the 

SIP) 

Z. National Emission Standard for Asbestos 

40 CFR, Part 61, Subpart M

The permittee shall not conduct any asbestos abatement activities except in accordance with 40 

CFR 61, Subpart M (National Emission Standard for Hazardous Air Pollutants for Asbestos). 

AA. Asbestos 

ARM 17.74, Subchapter 3, General Provisions and Subchapter 4, Fees

The permittee shall comply with ARM 17.74.301, et seq., and ARM 17.74.401, et seq. (State only) 

BB. Stratospheric Ozone Protection – Servicing of Motor Vehicle Air Conditioners 

40 CFR, Part 82, Subpart B

If the permittee performs a service on motor vehicles and this service involves ozone-depleting 

substance/refrigerant in the motor vehicle air conditioner (MVAC), the permittee is subject to all 

the applicable requirements as specified in 40 CFR 82, Subpart B. 

CC. Stratospheric Ozone Protection – Recycling and Emission Reductions 

40 CFR, Part 82, Subpart F

The permittee shall comply with the standards for recycling and emission reductions in 40 CFR 

82, Subpart F, except as provided for Motor Vehicle Air Conditioner (MVACs) in Subpart B. 
OP2655-02 42 Date of Decision: 04/29/08 

Effective Date: 05/30/08 

 

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

required practices pursuant to §82.156. 

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

with the standards for recycling and recovery equipment pursuant to §82.158. 

3. Persons performing maintenance, service, repair, or disposal of appliances must be certified by 

an approved technical certification program pursuant to §82.161. 

4. Persons disposing of small appliances, MVACs, and MVAC-like (as defined at §82.152) 

appliances must comply with record keeping requirements pursuant to §82.166. 

5. Persons owning commercial or industrial process refrigeration equipment must comply with the 

leak repair requirements pursuant to §82.156. 

6. Owners/operators of appliances normally containing 50 or more pounds of refrigerant must 

keep records of refrigerant purchased and added to such appliances pursuant to §82.166. 

DD. Emergency Episode Plan 

The permittee shall comply with the requirements contained in Chapter 9.7 of the State of 

Montana Air Quality Control Implementation Plan. 

Each major source emitting 100 tons per year located in a Priority I Air Quality Control Region, 

shall submit to the Department a legally enforceable Emergency Episode Action Plan (EEAP) that 

details how the source will curtail emissions during an air pollutant emergency episode. The 

industrial EEAP shall be in accordance with the Department’s EEAP and shall be submitted 

according to a timetable developed by the Department, following Priority I reclassification 

EE. Definitions 

Terms not otherwise defined in this permit or in the Definitions and Abbreviations Appendix of 

this permit, shall have the meaning assigned to them in the referenced regulations. 
Permit Number: OP2655-02 43 Date of Decision: 04/29/08 

Effective Date: 05/30/08 

 

APPENDICES 
OP2655-02 A-1 Date of Decision: 04/29/08 

Effective Date: 05/30/08 

 

Appendix A - INSIGNIFICANT EMISSION UNITS 

Disclaimer: The information in this Appendix Hs not State or Federally enforceable, but is presented to assist 

CFAC, the permitting authority, inspectors, and the public. 

Pursuant to ARM 17.8.1201(22)(a), an insignificant emission unit means any activity or emission unit located 

within a source that: (i) has a potential to emit less than five tons per year of any regulated pollutant; (ii) has a 

potential to emit less than 500 pounds per year of lead; (iii) has a potential to emit less than 500 pounds per 

year of hazardous air pollutants listed pursuant to section 7412 (b) of the FCAA; and (iv) is not regulated by an 

applicable requirement, other than a generally applicable requirement that applies to all emission units subject 

to Subchapter 12. 

List of Insignificant Activities:

The following table of insignificant sources and/or activities was provided by CFAC. Because there are no 

requirements to update such a list, the emission units and/or activities may change from those specified in the 

table. 

Emission Unit ID Description 

IEU03 Collector Bar Shotblasting - CR02 

IEU04 Anode Debris Storage - CR05 

IEU05 Anode Abrader - CR06 

IEU06 Shed 11 Pot Rebuild / Masonry Mixer - CR08 

IEU07 Diesel Storage Tanks - MP03 

IEU08 Natural Gas Space Heaters - MP06 

IEU09 Open Burning - MP10 

IEU10 Plant Site Sanitary Landfill - MP13 

IEU11 Propane Storage - MP14 

IEU12 Waste Oil Heat Recovery - MP18 

IEU13 MSDS Chemicals / Plant-wide Usage - MP19 

IEU14 Carpenter Shop Cyclone 
OP2655-02 B-1 Date of Decision: 04/29/08 

Effective Date: 05/30/08 

 

Appendix B - DEFINITIONS and ABBREVIATIONS 

"Act" means the Clean Air Act, as amended, 42 U.S. 7401, et seq. 

"Administrative permit amendment" means an air quality operating permit revision that: 

(a) Corrects typographical errors; 

(b) Identifies a change in the name, address, or phone number of any person identified in the air 

quality operating permit, or identifies a similar minor administrative change at the source; 

(c) Requires more frequent monitoring or reporting by CFAC; 

(d) Requires changes in monitoring or reporting requirements that the Department deems to be no 

less stringent than current monitoring or reporting requirements; 

(e) Allows for a change in ownership or operational control of a source if the Department has 

determined that no other change in the air quality operating permit is necessary, consistent with 

ARM 17.8.1225; or 

(f) Incorporates any other type of change that the Department has determined to be similar to those 

revisions set forth in (a)-(e), above. 

"Applicable requirement" means all of the following as they apply to emission units in a source requiring an 

air quality operating permit (including requirements that have been promulgated or approved by the 

Department or the administrator through rule making at the time of issuance of the air quality operating permit, 

but have future-effective compliance dates, provided that such requirements apply to sources covered under the 

operating permit). 

(a) Any standard, rule, or other requirement, including any requirement contained in a consent decree 

or judicial or administrative order entered into or issued by the Department, that is contained in 

the Montana State Implementation Plan approved or promulgated by the administrator through 

rule making under Title I of the Federal Clean Air Act (FCAA); 

(b) Any federally enforceable term, condition or other requirement of any air quality preconstruction 

permit issued by the Department under subchapters 7, 8, 9 and 10 of this chapter, or pursuant to 

regulations approved or promulgated through rule making under Title I of the FCAA, including 

parts C and D; 

(c) Any standard or other requirement under sec. 7411 of the FCAA, including sec. 7411(d); 

(d) Any standard or other requirement under sec. 7412 of the FCAA, including any requirement 

concerning accident prevention under sec. 7412(r)(7), but excluding the contents of any risk 

management plan required under sec. 7412(r); 

(e) Any standard or other requirement of the acid rain program under Title IV of the FCAA or 

regulations promulgated thereunder; 

(f) Any requirements established pursuant to sec. 7661c(b) or sec. 7414(a)(3) of the FCAA; 

(g) Any standard or other requirement governing solid waste incineration, under sec. 7429 of the 

FCAA; 

(h) Any standard or other requirement for consumer and commercial products, under sec. 7511b(e) of 

the FCAA; 
OP2655-02 B-2 Date of Decision: 04/29/08 

Effective Date: 05/30/08 

 

(i) Any standard or other requirement for tank vessels, under sec. 7511b(f) of the FCAA; 

(j) Any standard or other requirement of the regulations promulgated to protect stratospheric ozone 

under Title VI of the FCAA, unless the administrator determines that such requirements need not 

be contained in an air quality operating permit; 

(k) Any national ambient air quality standard or increment or visibility requirement under part C of 

Title I of the FCAA, but only as it would apply to temporary sources permitted pursuant to sec. 

7661c(e) of the FCAA; or 

(l) Any federally enforceable term or condition of any air quality open burning permit issued by the 

Department under subchapter 6. 

"Department" means the Montana Department of Environmental Quality. 

"Emission unit" means any part or activity of a stationary source that emits or has the potential to emit any 

regulated air pollutant or any pollutant listed under sec. 7412(b) of the FCAA. This term is not meant to alter 

or affect the definition of the term "unit" for purposes of Title IV of the FCAA. 

“Excess emissions” means any visible emissions from a stack or source, viewed during the visual surveys, 

believed to exceed the visible emissions during normal operating conditions. 

“Excess fugitive emissions” means any visible emissions that leave the plant site boundaries. 

"FCAA" means the Federal Clean Air Act, as amended. 

"Federally enforceable" means all limitations and conditions which are enforceable by the administrator, 

including those requirements developed pursuant to 40 CFR Parts 60 and 61, requirements within the Montana 

State Implementation Plan, and any permit requirement established pursuant to 40 CFR 52.21 or under 

regulations approved pursuant to 40 CFR Part 51, Subpart I, including operating permits issued under an EPAapproved program that is incorporated into the Montana State Implementation Plan and expressly requires 

adherence to any permit issued under such program. 

"Fugitive emissions" means those emissions that could not reasonably pass through a stack, chimney, vent, or 

other functionally equivalent opening. 

"General air quality operating permit" or "general permit" means an air quality operating permit that 

meets the requirements of ARM 17.8.1222, covers multiple sources in a source category, and is issued in lieu 

of individual permits being issued to each source. 

"Hazardous air pollutant" means any air pollutant listed as a hazardous air pollutant pursuant to section 

112(b) of the FCAA. 

"Non-federally enforceable requirement" means the following as they apply to emission units in a source 

requiring an air quality operating permit. 

(a) Any standard, rule, or other requirement, including any requirement contained in a consent 

decree, or judicial or administrative order entered into or issued by the Department, that is not 

contained in the Montana State Implementation Plan, approved or promulgated by the 

administrator through rule making under Title I of the FCAA; 

(b) Any term, condition, or other requirement contained in any air quality preconstruction permit 

issued by the Department under subchapters 7, 8, 9, and 10 of this chapter that is not federally 

enforceable; 
OP2655-02 B-3 Date of Decision: 04/29/08 

Effective Date: 05/30/08 

 

(c) Does not include any Montana ambient air quality standard contained in Subchapter 2 of this 

chapter. 

"Permittee" means the owner or operator of any source subject to the permitting requirements of this 

subchapter, as provided in ARM 17.8.1204, that holds a valid air quality operating permit or has submitted a 

timely and complete permit application for issuance, renewal, amendment, or modification pursuant to this 

subchapter. 

"Regulated air pollutant" means the following: 

(a) Nitrogen oxides or any volatile organic compounds. 

(b) Any pollutant for which a national ambient air quality standard has been promulgated. 

(c) Any pollutant that is subject to any standard promulgated under sec. 7411 of the FCAA. 

(d) Any Class I or II substance subject to a standard promulgated under or established by Title VI of 

the FCAA. 

(e) Any pollutant subject to a standard or other requirement established or promulgated under sec. 

7412 of the FCAA, including but not limited to the following: 

(i) Any pollutant subject to requirements under sec. 7412(j) of the FCAA. If the administrator 

fails to promulgate a standard by the date established in section 7412(e) of the FCAA, any 

pollutant for which a subject source would be major shall be considered to be regulated on the 

date 18 months after the applicable date established in section 7412(e) of the FCAA. 

(ii) Any pollutant for which the requirements of section 7412(g)(2) of the FCAA have been met 

but only with respect to the individual source subject to sec. 7412(g)(2) requirement. 

"Responsible official" means one of the following: 

(a) For a corporation: a president, secretary, treasurer, or vice-president of the corporation in charge 

of a principal business function, or any other person who performs similar policy or decisionmaking functions for the corporation, or a duly authorized representative of such person if the 

representative is responsible for the overall operation of one or more manufacturing, production, 

or operating facilities applying for or subject to a permit and either: 

(i) The facilities employ more than 250 persons or have gross annual sales or expenditures 

exceeding $25 million (in second quarter 1980 dollars); or 

(ii) The delegation of authority to such representative is approved in advance by the Department. 

(b) For a partnership or sole proprietorship: a general partner or the proprietor; respectively. 

(c) For a municipality, state, federal, or other public agency: either a principal executive officer or 

ranking elected official. For the purposes of this part, a principal executive officer of a federal 

agency includes the chief executive officer having responsibility for the overall operations of a 

principal geographic unit of the agency (e.g., a regional administrator of the environmental 

protection agency). 

(d) For affected sources: the designated representative in so far as actions, standards, requirements, 

or prohibitions under Title IV of the FCAA or the regulations promulgated thereunder are 

concerned, and the designated representative for any other purposes under this subchapter. 
OP2655-02 B-4 Date of Decision: 04/29/08 

Effective Date: 05/30/08 

 

Abbreviations:

ARM Administrative Rules of Montana 

ASTM American Society of Testing Materials 

BACT Best Available Control Technology 

BDT bone dry tons 

BTU British Thermal Unit 

CFR Code of Federal Regulations 

CO carbon monoxide 

DEQ Department of Environmental Quality 

dscf dry standard cubic foot 

dscfm dry standard cubic foot per minute 

EEAP Emergency Episode Action Plan 

EPA U.S. Environmental Protection Agency 

EPA Method Test methods contained in 40 CFR 60, Appendix A 

EU emission unit 

FCAA Federal Clean Air Act 

gr grains 

HAP hazardous air pollutant 

IEU insignificant emission unit 

Mbdft thousand board feet 

Method 5 40 CFR 60, Appendix A, Method 5 

Method 9 40 CFR 60, Appendix A, Method 9 

MMbdft million board feet 

MMBTU million British Thermal Units 

NOx oxides of nitrogen 

NO2 nitrogen dioxide 

O2 oxygen 

Pb lead 

PM particulate matter 

PM10 particulate matter less than 10 microns in size 

psi pounds per square inch 

scf standard cubic feet 

SIC Source Industrial Classification 

SO2 sulfur dioxide 

SOx oxides of sulfur 

tpy tons per year 

U.S.C. United States Code 

VE visible emissions 

VOC volatile organic compound 
OP2655-02 C-1 Date of Decision: 04/29/08 

Effective Date: 05/30/08 

 

Appendix C - NOTIFICATION ADDRESSES 

Compliance Notifications: 

Montana Department of Environmental Quality 

Permitting and Compliance Division 

Air Resources Management Bureau 

P.O. Box 200901 

Helena, MT 59620-0901 

United States EPA 

Air Program Coordinator 

Region VIII, Montana Office 

10 W. 15th Suite 3200 

Helena, MT 59626 

Permit Modifications: 

Montana Department of Environmental Quality 

Permitting and Compliance Division 

Air Resources Management Bureau 

P.O. Box 200901 

Helena, MT 59620-0901 

Office of Partnerships and Regulatory Assistance 

Air and Radiation Program 

US EPA Region VIII 8P-AR 

1595 Wynkoop Street 

Denver, CO 80202-1129 
OP2655-02 D-1 Date of Decision: 04/29/08 

Effective Date: 05/30/08 

 

Appendix D - AIR QUALITY INSPECTOR INFORMATION 

Disclaimer: The information in this Appendix Hs not State or Federally enforceable but is presented to 

assist CFAC, permitting authority, inspectors, and the public. 

1. Direction to Plant: 

 CFAC is adjacent to the community of Columbia Falls, Montana, with a physical address of 2000 

Aluminum Drive. 

2. Safety Equipment Required:

Safety Equipment required to enter the facility are: hard hat, protective eyewear, and safety shoes or 

boots. Additional personal protective equipment may be necessary in certain areas, such as respiratory 

protection. 

3. Facility Plot Plan:

 A copy of the facility plot plan was submitted with the operating permit application on June 12, 1996. 
OP2655-02 E-1 Date of Decision: 04/29/08 

Effective Date: 05/30/08 

 

Appendix E - CFAC MACT IMPLEMENTATION PLAN 

Although the hard copy of Appendix E has been removed from the permit, the contents of Appendix E, CFAC 

MACT Implementation Plan remain as applicable requirements as stated in the Title V Operating Permit 

#OP2655-02. To receive a hard copy of this appendix, please contact one of the following: 

The Department of Environmental Quality 

Permitting and Compliance Division 

Air Resources Management Bureau 

1520 E. Sixth Ave. 

P.O. Box 200901 

Helena, Montana 59620-0901 

Bureau Phone #: (406) 444-3490 

OR 

Columbia Falls Aluminum Company, LLC 

2000 Aluminum Drive 

Columbia Falls, Montana 59912 

Phone #: (406) 892-8211 
OP2655-02 F-1 Date of Decision: 04/29/08 

Effective Date: 05/30/08 

Appendix F - CFAC MACT QUICK REFERENCE GUIDE 

Although the hard copy of Appendix F has been removed from the permit, the contents of Appendix F, CFAC 

MACT Quick Reference Guide remain as applicable requirements as stated in the Title V Operating Permit 

#OP2655-02. To receive a hard copy of this appendix, please contact one of the following: 

The Department of Environmental Quality 

Permitting and Compliance Division 

Air Resources Management Bureau 

1520 E. Sixth Ave. 

P.O. Box 200901 

Helena, Montana 59620-0901 

Bureau Phone #: (406) 444-3490 

OR 

Columbia Falls Aluminum Company, LLC 

2000 Aluminum Drive 

Columbia Falls, Montana 59912 

Phone #: (406) 892-8211 
OP2655-02 G-1 Date of Decision: 04/29/08 

Effective Date: 05/30/08 

Appendix G - STARTUP, SHUTDOWN AND MALFUNCTION PLAN (SSM) 

Although the hard copy of Appendix G has been removed from the permit, the contents of Appendix G, 

Startup, Shutdown and Malfunction Plan (SSM) remain as applicable requirements as stated in the Title V 

Operating Permit #OP2655-02. To receive a hard copy of this appendix, please contact one of the following: 

The Department of Environmental Quality 

Permitting and Compliance Division 

Air Resources Management Bureau 

1520 E. Sixth Ave. 

P.O. Box 200901 

Helena, Montana 59620-0901 

Bureau Phone #: (406) 444-3490 

OR 

Columbia Falls Aluminum Company, LLC 

2000 Aluminum Drive 

Columbia Falls, Montana 59912 

Phone #: (406) 892-8211 
OP2655-02 H-1 Date of Decision: 04/29/08 

Effective Date: 05/30/08 

 

Appendix H - POTLINE ROOF VENT OPACITY COMPLIANCE DEMONSTRATION 

Proposal to Perform Method 9 Visual Observations on Potroom Roofs 

CFAC proposes to perform Method 9 visual observations on portions of each potline’s roof in order to 

demonstrate compliance with ARM 17.8.332. This is similar in concept to EPA Method 14 where a manifold 

extracts emissions from either a 35-meter (115 feet) length of a roofline, or from 8% length of the roofline to 

determine compliance with emission standards for the entire potline. CFAC proposes to perform Method 9 

observations on the following roofs: 

Approximately 50% of Room 1 length (457 ft, representing potline 1) 

Approximately 35% of Room 3 length (321 ft, representing potline 2) 

Approximately 35% of Room 6 length (321 ft, representing potline 3) 

Approximately 35% of Room 7 length (321 ft, representing potline 4) 

Approximately 35% of Room 10 length (321 ft, representing potline 5) 

Specifically, CFAC proposes to demonstrate compliance with ARM 17.8.332 by performing quarterly Method 

9 visual observations as described below. Each Method 9 observation period will be a minimum of 6 minutes 

unless any one reading is greater than 10%; then the observation period will be a minimum of 20 minutes. 

Room 1 (potline 1): Method 9 observations will be taken by an observer located on the Room 2 roof, 

looking westward. Method 9 observations will be taken at more than one location along the north 

50% of Room 1. The Method 9 observation results will be averaged to produce a final result. 

Room 3 (potline 2): Method 9 observations will be taken by an observer located on the staircase to 

the Room 4 roof. The west plant ore silos will serve as a backdrop for the Method 9 observations. 

The ore silos provide a backdrop, which is approximately 321 feet, or approximately 35% of the total 

length of the Room 3 roof. Method 9 observations will be taken at more than one location along the 

north 35% of Room 3. The Method 9 observation results will be averaged to produce a final result. 

Room 6 (potline 3): Method 9 observations will be taken by an observer located on the staircase to 

the Room 5 roof. The east plant ore silos will serve as a backdrop for the Method 9 observations. The 

ore silos provide a backdrop, which is approximately 321 feet, or approximately 35% of the total 

length of the Room 6 roof. Method 9 observations will be taken at more than one location along the 

north 35% of Room 3. The Method 9 observation results will be averaged to produce a final result. 

Room 7 (potline 4): Method 9 observations will be taken by an observer located on the staircase to 

the Room 8 roof. The east plant ore silos will serve as a backdrop for the Method 9 observations. The 

ore silos provide a backdrop, which is approximately 321 feet, or approximately 35% of the total 

length of the Room 7 roof. Method 9 observations will be taken at more than one location along the 

north 35% of Room 7. The Method 9 observation results will be averaged to produce a final result. 

Room 10 (potline 5): Method 9 observations will be taken by an observer located on the staircase to 

the Room 9 roof, looking eastward. Method 9 observations will be taken at more than one location 

along the north 35% of Room 10. The Method 9 observation results will be averaged to produce a 

final result. 

CFAC shall perform daily visual surveys in a manner similar to the Method 9 procedures outlined 

above and it is understood by all parties that these daily visual observations are not Method 9 

observations. 
OP2655-02 I-1 Date of Decision: 04/29/08 

Effective Date: 05/30/08 

 

Appendix I - Pollution Control Device Inspection and Maintenance Plan 

Although the hard copy of Appendix I has been removed from the permit, the contents of Appendix I Pollution 

Control Device Inspection and Maintenance Plan remain as applicable requirements as stated in the Title V 

Operating Permit #OP2655-02. To receive a hard copy of this appendix, please contact one of the following: 

The Department of Environmental Quality 

Permitting and Compliance Division 

Air Resources Management Bureau 

1520 E. Sixth Ave. 

P.O. Box 200901 

Helena, Montana 59620-0901 

Bureau Phone #: (406) 444-3490 

OR 

Columbia Falls Aluminum Company, LLC 

2000 Aluminum Drive 

Columbia Falls, Montana 59912 

Phone #: (406) 892-8211 
OP2655-02 K-1 Date of Decision: 04/29/08 

Effective Date: 05/30/08 

 

Appendix J - 62 FR 52383 

http://www.epa.gov/EPA-AIR/1997/October/Day-07/a25882.htm 
OP2655-02 K-1 Date of Decision: 04/29/08 

Effective Date: 05/30/08 

 

Appendix K – Ambient Monitoring Plan

AMBIENT AIR MONITORING PLAN 

 COLUMBIA FALLS ALUMINUM COMPANY LLC 

 

1. This ambient air monitoring plan is required by Montana Air Quality Permit (MAQP) #2655 and 

Title V Operating Permit #OP2655 which applies to the Columbia Falls Aluminum Company 

(CFAC) primary aluminum reduction plant near Columbia Falls. This monitoring plan may be 

modified by the Department. All requirements of this plan are considered conditions of the 

permit. 

2. CFAC shall collect vegetation samples for fluoride-in-forage analysis at three air monitoring sites 

in the vicinity of their plant and facilities. The exact locations of the monitoring sites must be 

approved by the Department and meet all the siting requirements contained in the Montana 

Quality Assurance Manual, including revisions; the EPA Quality Assurance Manual, including 

revisions; Parts 53 and 58 of the Code of Federal Regulations; and ARM 17.8.230, or any other 

requirements specified by the Department. 

3. CFAC shall continue vegetation sampling for at least one year following issuance of this permit 

or as determined by the Department. The air monitoring data will be reviewed by the 

Department and the Department will determine if continued monitoring or additional monitoring 

is warranted. The Department may require continued vegetation sampling to track long-term 

impacts of emissions from the facility or require additional vegetation sampling, ambient air 

monitoring or analyses if any changes take place in regard to quality and/or quantity of emissions 

or the area of impact from the emissions. 

4. CFAC shall monitor the following parameters at the sites and frequencies described below: 

AIRS # and Site Name UTM1

 Coordinates Parameter Frequency 

30-029-0707 

Doane 

Zone 12 

N 5365419 

E 710886 

Fluoride in Vegetation As required by ARM 

17.8.230 

30-029-0708 

Hoffman 

Zone 12 

N 5362152 

E 713305 

Fluoride in Vegetation As required by ARM 

17.8.230 

30-029-0710 

New Liddle 

Zone 12 

N 5360573 

E 711411 

Fluoride in Vegetation As required by ARM 

17.8.230 

1

UTM = Universal Transverse Mercator 

5. Data recovery for all parameters shall be at least 80 percent computed on a quarterly and annual 

basis. The Department may require continued monitoring if this condition is not met. 

6. Any vegetation sampling or ambient air monitoring changes proposed by CFAC must be 

approved in writing by the Department. 

7. CFAC shall utilize air monitoring and quality assurance procedures which are equal to or exceed 

the requirements described in the Montana Quality Assurance Manual, including revisions; the 

EPA Quality Assurance Manual, including revisions; 40 CFR Parts 53 and 58 of the Code of 

Federal Regulations; and ARM 17.8.230, or any other requirements specified by the Department. 
OP2655-02 K-2 Date of Decision: 04/29/08 

Effective Date: 05/30/08 

 

8. CFAC shall submit an annual data report by March 15 of each year. The annual report shall 

consist of a narrative data summary and a data submittal of all data points on AIRS formatted 

paper input forms, disks or magnetic tapes which are compatible with the Department's computer 

system. The narrative data summary shall include: 

a. A topographic map of appropriate scale with UTM coordinates and a true north arrow 

showing the vegetation sampling and air monitoring site locations in relation to the plant 

and the general area; 

b. A hard copy of the individual data points; 

c. A summary of the data collection efficiency; 

d. A summary of the reasons for missing data; and 

e. A summary of any fluoride-in-forage standard exceedances. 

9. The Department may audit, or may require CFAC to contract with an independent firm to audit, 

the vegetation sampling network, the laboratory performing associated analyses, and any data 

handling procedures at unspecified times. On the basis of the audits and subsequent reports, the 

Department may recommend or require changes in the vegetation sampling network and 

associated activities in order to improve precision, accuracy and data completeness.