### CommonwealthofKentucky Energy and Environment Cabinet Departmentfor Environmental Protection Division for Air Quality 200 Fair Oaks Lane, 15tFloor

Frankfort, Kentucky 40601 (502) 564-3999 

### AIR QUALITY PERMIT Issued under401 KAR 52:020 

# Final

Version 06/26/09 Permittee Name: Mailing Address: Source Name: Mailing Address: Source Location: Permit: Agency Interest: Activity: Review Type: Source ID: Regional Office:
County: Application Complete Date: Issuance Date: Revision Date: Expiration Date: Rio Tinto Alcan-Sebree Works 9404 Highway 2096 Robards, KY 42452-9735 Same as above Same as above Same as above V-05-088 R2 1788 APE20090001 Title V/PSD 21-101-00029 Owensboro Regional Office 3032 Alvery Parkdrive W., suite 700 Owensboro, KY 42303-2191 (270) 687-7304 Henderson December7, 2005 April 3, 2007 October4, 2010 April 3, 2012

### TABLE CONTENTS
SECTION DATE OF ISSUANCE PAGE A. PERMITAUTHORIZATION Initial I B. EMISSION POINTS, EMISSION UNITS, Revision 2 2 APPLICABLE REGULATIONS, AND OPERATING CONDITIONS C. INSIGNIFICANT ACTIVITIES Initial 39 D. SOURCE EMISSION LIMITATIONS AND Revision 2 40 TESTING REQUIREMENTS E. SOURCE CONTROL EQUIPMENT Initial 41 OPERATION REQUIREMENTS F. MONITORING, RECORDKEEPING, AND Initial 42 REPORTING REQUIREMENTS G. GENERAL PROVISIONS Revision 2 45 H. ALTERNATE OPERATING SCENARIOS Initial 52 1. COMPLIANCE SCHEDULE Initial 52 Permit Type APE# Complete Issuance Summary of Date Date Action Initial Issuance 20050007 12/07/05 04/3/07 Permitissuance Administrative 20060003 8121106 1. Site-specific OM&M Amendment plan for group 1 and group 2 furnaces was incorporated to the section Din the permit. 2. Typo error was corrected. A7(90) was changed to A6(90). V-05-088 Significant Refurbishment ofthe existing RI Revision 20070002 9/12/2007 3/2612008 261 Anode Bake Furnace at the facility. V-05-088 Significant PSD review/Increase in R2 Revision 20090001 9/29/2009 production VersIOn 11-19-2009PermitNumber: V-05-088 R2 

### SECTION A - PERMIT AUTHORIZATION Page: 1 of52

BACT CB CO Division DC HAP NAAQS NESHAP NOx PM PM2.5 PM 10 PMACT Pursuant to a duly submitted application the Kentucky Division for Air Quality (Division) hereby authorizes the operation ofthe equipment described herein in accordance with the terms and conditions ofthis permit. This permit has been issued under the provisions ofKentucky Revised Statutes (KRS) Chapter 224 and regulations promulgatedpursuantthereto. The permittee shall not construct, reconstruct, or modif'y any affected facilities without first submitting a complete application and receiving a permit for the planned activity from the permitting authority, except as providedin this permitorin 401 KAR 52:020, TitleV Permits. Issuance ofthis permit does not relieve the permittee from the responsibility ofobtaining any other permits, licenses, or approvals required by the Kentucky Energy and Environment Cabinet (Cabinet) orany other federal, state, orlocal agency.
Definitions: The following definitions apply to all abbreviations and variables used in this permit:

- Best available control technology

- Carbonbake

- Carbon monoxide

- Kentucky Division for Air Quality

- DustCo

### 11ector

- Hazardous AirPollutant

- National Ambient Air Quality Standards

- National Emissions Standards for Hazardous Air Pollutants

- Nitrogen Oxides

- Particulate Matter

- particulatematter equal to or smaller than 2.5 micrometers

- ParticulateMatter equal to or smallerthan 10 micrometers

- NESHAP for Primary Aluminum Reduction Plants, also referred to as "PMACT' (40 CFR 63, Subpart LL) PSD

- Prevention ofSignificant Deterioration ofairquality S02

- Sulfurdioxide TF

- Total Fluoride POM .- polycyclic organic matter PMIO / PM25 - PMIO and PM25 standards are the same except as noted PM/ PM IO - PM and PMIO standards are the same except as notedPermitNumber: V-05-088 R2 Page: 20f52 

### SECTION B - AFFECTED FACILITIES, APPLICABLE REGULATIONS, AND OPERATING CONDITIONS SUBJECT ITEM 1 REQUIREMENTS: Existing Process Sources Unit# UnitName Material Rate Construction Date (tons Iyear) AI (Tl-D) Barge Unloading Raw Material 585,562 August4, 1972 total B4 (S7, S8) Reacted Alumina Storage (2) Reacted Alumina 140,160 August4, 1972 each G8 (19) Ingot Casting Dross Loading Dross 5,820 August4, 1972 M1(E9) Anode Mix Hopper Anode Raw 127,020 December 12,1972 Materials (No POM) Q4 (EG) Anode Rod Cleaning Shot Blast 29,143 December31, 1972 Material K1 (P1(23)) Bath Crushing/Crucible Anode Cover 54,137 1972 Cleaning U1 (5P) Bath Transferto Storage Anode Cover 54,137 January 1, 1972 Processing Q1 (EF) Electric Arc Furnace ( 1) Charge Materials 168 December31, 1972 TPY Backup A8 (T4) Material Transfer Alumina/Coke 585,562 August4, 1972 A2 (Sl, S2, Alumina Storage Alumina 417,064 August4, 1972 S3) total B6 (S4, S5) Ore Storage Unreacted 140,160 August4, 1972 

### I Alumina each C1 (T5) Material TransferRail Car Alumina, 193,970 August 4, 1972

""- Fluoride, Coke "-- C2 (T6, 2S) Aluminum Fluoride A1F3 3,800 August4, 1972 f--" Total
_.

C4 (T7, T8, Coke Handling Petroleum Coke 193,970 August 4, 1972 T2)

....__... total C6 (3S, 4S) Coke Handling Petroleum Coke 96,985 August 4, 1972 each J] (E1) Butt SurgeTank Anode Butts 70,000 August 4, 1972 K7 (E6) Coke Crushing Petroleum Coke 193,970 December31, 1972 L1 (E7) Coke Ball Mill Petroleum Coke 193,970 December 31, 1972 L3 (E8) Coke Fines Handling Petroleum Coke 193,970 December31, 1972 U2 (Cl?) Green Anode Dust Collector Intermediate 17,000 December31, 1972 CokePermit Number: V-05-088 R2 Page: 3 of52 

### SECTION B - AFFECTED FACILITIES, APPLICABLE REGULATIONS, AND OPERATING CONDITIONS (CONTINUED) Unit# UnitName Material Rate ConstructionDate (tons /year) K5 (E5) Butt Impactor Anode Butts 70,000 December 31, 1972 J2 (E2) Anode ButtCleaning ShotBlast 10,744 Aug 4, 1972 Material 

## *EmISSIOns from all umts controlled bybaghouses. APPLICABLE REGULATIONS: 401 KAR 61:020 Existing process operations is applicable to units which were constructed before July 2, 1975 1. OperatingLimitations:
a. See SECTION D 1 below. b. The associated control device(s) shall be operated all the time when the units are operating. Compliance Demonstration: Records shall bekept ofthe times when the units are operatingbutthe control devices are not. Records shall also bekept ofthe maintenance activities. 2. Emission Limitations:
a. 

### Opacity Standard: Visible emISSIOns from each stack or vent associated with the emission units listed above shall not equal or exceed 40%opacity. Compliance Demonstration: Compliance with the opacity limits described above shall be determined through monitoring, maintenance of the records and annual Method 9 readings. b. 

### PMStandards: I. For emissionunits K1 and UI, particulate emissions shall not exceed a maximum exit particulate emission concentration of0.02 grains per standard cubic foot. Addition ofdilution air shall not constitute compliance. Compliance Demonstration: Compliance with the limits described above shall be determined by annual testing ofthe particulate emissions from the K1 and U1 stacks. Annual testing must be completed within the first 12 months following issuance of this permit. 11. Except for emission units KI and U1, hourly particulate emissions shall not exceed the following limits:

• Forprocess weights < 0.5 tons/hour: 2.58 Ibs/hour

• Forprocess weight < 30 tonslhour: E'PM, 

### = 4.lOP/67

• Forprocess weights? 30 tonslhour: E'PM, = (55.0p/I' )- 40PermitNumber: V-OS-088 R2 Page: 40f52 

### SECTION B - AFFECTED FACILITIES, APPLICABLE REGULATIONS, AND OPERATING CONDITIONS (CONTINUED) Where j is the unit, E'PMj is the allowable particulate emISSiOn rate for unit j (poundslhour) and Pj is the averageprocess weightforunitj (tonslhour). Compliance Demonstration: Compliance with the hourly particulate emission limits described above shall be determined by comparing the allowable rate to the actual rate as calculated below: 

### E =

## Pij'E~M"(l_CEj)

PM" 

### hij 100 Where i is the month, j is the unit, EpMij is the actual average hourly particulate emission rate from unit j during month i (pounds/hour), Pij is the actual specific operating parameter for month i (units/month), EFpMj is the overall uncontrolled KYEIS particulate emission factor for unit j (pounds/unit), hij is the actual total hours of operation for unit j during month i (hours/month) and CEj is the overall control efficiency (%) ofany air pollution control equipment associated with unitj. 3. Testing Requirements:
a. For emission points Kl and Ul, the permittee shall measure particulate concentrations at both the inlet and outlet ofthe control device during the annual Method 5 test in order to determine both the emission rate and the actual control efficiency of the associated baghouse. Annual testing must be completed within the first 12 months following issuance ofthis permit. b. To determine compliance with visible emission limits, the permittee shall perform annual Method 9 readings on each stack, vent or control device associated with the units listed above. 4. Specific Monitoring Requirements: For each emission unit listed above, the permittee shall monitorthe following parameters:
a. Monthly total hours ofoperation. b. Monthly total material processed (except for Kl and Ul).
c. Hourlypollutant emission rates. d. Flow rate-based pollutant emission rates.
e. For each stack, vent orcontrol system: i. Monthly observations ofvisible emissions during operation ofassociated equipment. ii. Observations of visible emissions during all periods of control equipment malfunction. If visible emissions are seen during the observation, Method 9 shall be used to determine the opacity.PermitNumber: V-05-088 R2 Page: 50f52 

### SECTION B - AFFECTED FACILITIES, APPLICABLE REGULATIONS, AND OPERATING CONDITIONS (CONTINUED) iii. Annual Method 9 readings during operationofassociated equipment. 5. Specific Recordkeeping Requirements: For each emission unit listed above, the permittee shall maintainrecords ofthe following information:
a. Monthlytotal hours ofoperation. b. Monthlytotal material processed.
c. Hourlypollutantemission rates. d. Flow rate-based pollutantemissionrates.
e. Foreach stack, vent or control system, alog ofall visibleemission observations. If visible emissions are observed, the log shall indicate: i. Method 9readings ifany visible emissions are seen. ii. The cause ofthe abnormal visible emissions. iii. Any corrective actions taken. f. Foreach stack, vent orcontrol system, records ofthe annual Method 9 readings. 6. Specific Reporting Requirements:
a. If any operating or emission limit on a specific unit or operational group is exceeded morethan 6times in a specified semi-annual reporting period (as defined in SECTION F 6. below), the permittee shall submit a cOITective action plan to the Owensboro Regional Office for the Division's approval no later than 30 days from the due date ofthe semiannual report. b. With the exception ofspecific reporting requirements outlined above, the permittee shall report exceedances of any operating or emission limit specified in this permit to the Division's Owensboro Regional Office as described in SECTION F 8 below. 7. Specific Control Equipment Conditions:
a. For emission units KI and UI, the associated control equipment must achieve at least 97% actual control efficiency. b. See SECTION D 2below. 8. Compliance Certification: See SECTION D 3 below.PermitNumber: V-OS-088 R2 Page: 60f52 

### SECTION B - AFFECTED FACILITIES, APPLICABLE REGULATIONS, AND OPERATING CONDITIONS (CONTINUED) SUBJECT ITEM 2 REOUIREMENTS: New Process Sources Unit# UnitName Material Rate Construction Date (tons /year) Q2 (EF) Electric Induction Furnaces Cast Iron 9,360 Dec 6, 1989 (No. I (3) (see operating limitation) and No.2), Jan 2006 (No.3) A6 (89) Re-Melt Furnace Aluminum 54,750 Julv 29, 1999 B5 (S9) Reacted Alumina Storage Alumina 140,160 August 4, 1979 U3 (EJ) Central Anode Butts Anode Butts 80,000 December31, 1990 Cleaning B7 (S6) Ore Storage Unreacted 140,160 July28, 1977 Alumina 13 (E3) Butt Stripping/Crushing Anode Butts 70,000 July 28, 1977 K3 (E4) Butt Crushing Anode Butts 70,000 June 19, 1979 E6 (EL) Transloading Spent Potliner Spent Potliner 180,136 October I, 1995 and Sandblasting Operations E8 (EM) Building (138) Vacuum PotlinerProcess 229 June 17, 1995 System Area U4 (EQI) Anode Saw Dust Collector Anode 120,888 2004 U5 (EO 72, Pitch StorageTanks Coal Tar 19,000 1977 73)
¥ EmISSIOns from all umts controlled bybaghouse(s). APPLICABLE REGULATIONS: 401 KAR 59:010 New process operations (on or after July 2, 1975) 40 CFR 63 Subpart RRR Secondary aluminum production NESHAP applies to the Re-Melt Furnace. The Re-Melt furnace is classified as a Group 2 furnace pursuant to Subpart RRR. 1. OperatingLimitations: See SECTION D 1below.

a. Thepermittee shall not operatemore than two eleCtric induction furnaces atonetime. [Synthetic Minor Limit] b. The permittee shall not exceed a total annual induction furnace process rate of9,360 tons ofcast ironproduction per year. [Synthetic Minor]

c. The associated control device(s) shall be operated all the time when the units are in operation. Compliance Demonstration: Records shall be kept ofthe times when the units are operating butthe control devices are not. Records shall also be kept ofthe maintenance activities.PermitNumber: V-05-088 R2 Page: 7 of52 d. The associated control device(s) must achieve atleast 99% actual overall control efficiency. 

### SECTION B - AFFECTED FACILITIES, APPLICABLE REGULATIONS, AND OPERATING CONDITIONS (CONTINUED) Compliance Demonstration: SeeRecord Keeping Requirementbelow.

e. Melt furnace: Pursuant to Table 2 to 40 CFR 63 Subpart RRR, the permittee shall post identification, operating parameter ranges and operating requirements at affected source and emission unites). 2. Emission Limitations:
a. 

### Opacity Standard: Visible emISSIOns from each stack or vent associated with the emission units listed above shall not equal or exceed 20% opacity. Compliance Demonstration: Compliance with the opacity limits described above shall be determined through monitoring, maintenance of the records and annual Method 9 readings. 

### PM Standard: For emission unit listed above hourly particulate emissions shall not exceed the following limits: i. Forprocess weights < 0.5 tons/hour: 2.34lbslhour 0.62 ii. Forprocess weight < 30 tonslhour: iii. Forprocess weights :2: 30 tonslhour: E'PM; 

### =**3.59~** E'PMj 

## =**(17.3I~o16)** Where j is the unit, E'PMj is the allowable particulate emISSIOn rate for unit j (poundslhour) and Pj is the averageprocess weight forunitj (tonslhour). b. Compliance Demonstration: Compliance with the hourly particulate emission limits described above shall be determined by comparing the allowable rate to the actual rate as calculated below: E

## PM" =

# Ij~~:PMj 

# -(1-**~:;-)** Where i is the month, j is the unit, EpMij is the actual average hourly particulate emission rate from unit j during month i (pounds/hour), Pij is the actual specific operating parameter for month i (units/month), EFpMj is the overall uncontrolled KYEIS particulate emission factor for unit j (pounds/unit), hij is the actual total hours of operation for unit j during month i (hours/month) and CEj is the overall control efficiency (%) ofany air pollution control equipment associated with unitj.
c. To preclude the applicability ofPSD, PM-I0 emissions must be less than 15 tons per rolling twelve month period for induction furnace #3. 3. Testing Requirements: To determine compliance with visible emission limits, thepermittee shall perform annual Method 9readings on each stack, vent or control device associated with theunits listed above.PermitNumber: V-05-088 R2 Page: 80f52 

### SECTION B - AFFECTED FACILITIES, APPLICABLE REGULATIONS, AND OPERATING CONDITIONS (CONTINUED) 4. Specific Monitoring Requirements: For each emission unit listed above, the permittee shall monitorthe following parameters:
a. Monthlytotal hours ofoperation. b. Monthlytotal material processed.

c. Hourlypollutantemission rates. d. Foreach stack, ventorcontrol system: i. Monthly observations ofvisible emissions during operationofassociated equipment. ii. Observations of visible emissions during all periods of control equipment malfunction. If visible emissions are seen during the observation, Method 9 shall be used to determine the opacity. iii. Annual Method 9readings during operation ofassociated equipment. 5. Specific Recordkeeping Requirements: For each emission unit listed above, the permittee shall maintain records ofthe following information:
a. Monthlytotal hours ofoperation. b. Monthlytotal material processed.
c. Hourlypollutantemission rates. d. For each stack, vent or control system, a log of all visible emission observations. If visible emissions are observed, the log shall indicate: i. Method 9 readings ifany visible emissions are seen. ii. The cause ofthe abnormal visible emissions. iii. Any corrective actions taken.
e. For each stack, vent or control system, records ofthe annual Method 9 readings. f. Re-Melt furnace: Pursuant to 40 CFR 63.l510(r)(l), the permittee shall record a description of the materials charged to each furnace, including any nonreactive, nonHAP-containing/non-HAP-generating fluxing materials or agents. 6. Specific Reporting Requirements:
a. If any operating or emission limit on a specific unit or operational group is exceeded morethan 6times in aspecified semi-annual reporting period (as defined in SECTION F 6. below), thepermittee shall submit a corrective actionplan to the Owensboro RegionalPermitNumber: V-OS-088 R2 Page: 90f52 

### SECTION B - AFFECTED FACILITIES, APPLICABLE REGULATIONS, AND OPERATING CONDITIONS (CONTINUED) b. Office for the Division's approval no later than 30 days from the due date ofthe semiannualreport.
c. With the exception ofspecific reporting requirements outlined above, the pennittee shall report exceedances of any operating or emission limit specified in this pennit to the Division's Owensboro Regional Office as described in SECTION F 8 below. d. Re-Me1t furnace: Pursuant to 40 CFR 63.151 0(r)(2), submit a certification ofcompliance with the applicable operational standard for charge materials in 40 CFR 63.1506(0) for each 6-month reporting period. Each certification must contain the infonnation in 40 CFR 63.1516(b)(2)(v). 7. Specific Control Equipment Conditions: SeeSECTION D 2below. 8. Compliance Certification: See SECTION D 3 below.PermitNumber: V-05-088 R2 Page: 100f52 

### SECTION B - AFFECTED FACILITIES, APPLICABLE REGULATIONS, AND OPERATING CONDITIONS (CONTINUED) SUBJECT ITEM 3 REQUIREMENTS: Heat Exchangers Unit# UnitName Fuel Rate Construction Date (MMBTU/hour) 

### S5 (EI) IndirectHeat Exchanger

- Natnral 12.5 December31, 1972 (Electrode Boiler) Gas 

### S6 (EI) Indirect Heat Exchanger Natnral 12.5 December31, 1972 Gas APPLICABLE REGULATIONS: 401 KAR 59:015 New indirectheat exchangers (on orafterApril 9, 1972) 40 CFR 63 Subpart DDDDD

- National Emission Standards for Hazardous Air Pollutants for 1ndustrial/Commercial/lnstitntional Boilers and Process Heaters 1. Operating Limitations: See SECTION D 1 below. 2. Emission Limitations:


### a. OpacityStandard: i. Visible emissions from each stack or vent associated with the emission units listed above during normal operations shall not exceed 20% opacity (based on a six minute average). ii. A maximum of40% opacity (based on a six minute average) shall be permissible for not more than 6 consecutive minutes in any consecutive 60 minutes during fire-box

. cleaning or while blowing soot.

Compliance Demonstration: Whileburning natural gas, this unit is considered to be in compliance with opacity standards. b. PMStandards: Particulate emissions shall not exceed the following limits: Unit# Unit Name P'hri (Ibs/MMBTU) 

### S5 (EI) Indirect Heat Exchanger

- (ElectrodeBoiler) 0.531 

### S6 (EI) IndirectHeat Exchanger 0.531 Compliance DemonstratIOn: Whileburnmg natural gas, thiS umt IS considered to bein compliance particulate standards.
c. S02 Standards: Sulfur dioxide emissions shall not exceed the following limits: Unit# UnitName P'hri (lbs/MMBTUl 

### S5 (EI) Indirect Heat Exchanger

- (ElectrodeBoiler) 2.74PermitNumber: V-05-088 R2 S6 (EI) IndirectHeatExchanger Pa e: 11 of52 2.74 

### SECTION B - AFFECTED FACILITIES, APPLICABLE REGULATIONS, AND OPERATING CONDITIONS (CONTINUED) Compliance Demonstration: While burningnatural gas, this unit is consideredto be in compliance sulfurdioxide standards. 3. Testing Requirements: N/A 4. SpecificMonitoring Requirements: N/A 5. Specific Record keeping Requirements: N/A 6. Specific Reporting Requirements: a. The permittee shall comply with the reporting requirements of 40 CFR 63 Subpart DDDDD. 7. Specific Control Equipment Conditions: SeeSECTION D 2 below.PermitNumber: V-05-088 R2 Page: 12 of52 

### SECTION B - AFFECTED FACILITIES, APPLICABLE REGULATIONS, AND OPERATING CONDITIONS (CONTINUED) SUBJECT ITEM 4 REQUIREMENTS: Potlines (3) Unit# UnitName Control Construction Date EI-2 Potline 1 Dry alumina August 1972 E3-2 Potline 2 scrubber/baghousefor August 1972 E5-2 Potline 3 reactors August 1979 Control Efficiency: 99% EI-1 Potline 1roof None

- Vents to Atmosphere August 1972 monitor E3-1 Potline 2roof August 1972 monitor E5-1 Potline 3 roof August 1979 monitor APPLICABLE REGULATIONS: 401 KAR 51 :017 Prevention ofsignificant deterioration ofair quality (S02, CO, PMIO, PM2 .5 and Fluorides) 401 KAR 61:165 Existingprimary aluminum reduction plants (potlines I & 2) 40 CFR 63 Subpart LL Primary Aluminum ProductionNESHAP (potlines 1,2 and 3) 40 CFR 63 Subpart LL and 401 KAR 61:165 supersede the mass emissions standards prescribedby 401 KAR 59:010 and 401 KAR 61:020 (see Section 2. Emission Limitations) 1. OperatingLimitations:
a. 12-month rolling total aluminum production shall not exceed 253,531 cumulative tons from potlines 1-3. b. Pursuant to 40 CFR 63.848(j), the permittee shall install, operate, and maintain a monitoring device to determinethe daily weight ofaluminum produced.
c. Pursuant to 40 CFR 63.848(f), the permittee shall install, operate, calibrate, and maintain a continuous parameter monitoring system for each emission control device. The permittee shallsllbmit for approval by the regulatory authority aaescription of the parameter(s) to be monitored, the operating limits, and the monitoring frequency to ensure that the control device is being properly operated and maintained. An explanation of the criteria used for selection of the parameter(s), the operating limits, and the monitoring frequency, induding how these relate to emission control also shall be submitted to the regulatory authority. Except as provided in paragraph 63.848(1) Alternative operatingparameters, the following monitoring devices shall beinstalled: (I) Fordry alumina scrubbers, devices for the measurement ofalumina flow and airflowPermitNumber: V-05-088 R2 Page: 13 of52 

### SECTION B - AFFECTED FACILITIES, APPLICABLE REGULATIONS, AND OPERATING CONDITIONS (CONTINUED) d. Pursuant to 40 CFR 63.848(h), if a monitoring device for a primary control device measures an operating parameter outside the limit(s) established pursuant to §63.847(h), orifvisible emissions indicating abnormal operation are observed from the exhaust stack ofa control device during a daily inspection, the permittee shall initiate corrective action procedures within 1 hour. Failure to initiate the corrective action procedures within 1 hourorto takethe necessary corrective actions to remedy theproblemis aviolation.
e. Pursuant to 401 KAR 61:165, Section 6(3), the permittee shall install, operate, and maintain ambient airmonitoring equipment for the detection offluorides. This equipment shall be located at sites specified bythe Division ifrequested. f. SeeSECTION D 1below. g. Pursuant to 401 KAR 51 :017, each dry scrubberlbaghouse system shall be operated when the associated potline is in operation. Compliance Demonstration: Records shall be kept of the times when the units are operating but the control devices are not. Records shall also be kept of the maintenance activities. h. Thepetroleum coke used to make the green anodes shall notexceed 3.0percent sulfurby weight and thepitch shall notexceed 0.80 percent sulfurby weight as measured bythe standard ASTM method, an approved alternativemethod, orby vendor Certificateof Analysis (per shipmentbasis). i. The permittee shall follow good design and combustion practices for the potlines to control CO emissions. The standard operating procedures for following the good operational procedures shall be kept available at site for inspection. Records shall be kept ofcontinuingpractices and maintenance. 2. Emission Limitations:
a. Opacity Standard: Visible emissions £i'om Potlines 1,2, and/or 3 shall not exceed the following limits: i. Pursuantto 40 CFR 63.845(h) and 401 KAR 61 :165, Section 3,10 % opacity from anypotroomroofmonitorduring normal operations. (potlines 1,2 & 3) ii. Pursuantto 40I KAR 61: 165, 40 % opacity from anypotroom roofmonitorlocated directly above sick cells or startup cells. (Potlines I & 2 only) iii. 10 % opacity from any dry scrubbingplantprimary control system. (Potlines 1,2, &3) 40 CFR 63.845(h); 401 KAR 61 :165, Section 3] Compliance Demonstration: Compliance with the opacity limits described above shall be determined through monitoring, maintenance of the records and annual Method 9 readings.PermitNumber: V-05-088 R2 Page: 140f52

[40 CFR 63.847(e)] 

### SECTION B - AFFECTED FACILITIES, APPLICABLE REGULATIONS, AND OPERATING CONDITIONS (CONTINUED) b. 

### TFStandard: Pursuant to 40 CFR 63.843(a)(1), 401 KAR 61:165, Section 4, and 401 KAR 51:017 total fluoride (TF) emissions shall not exceed 1.9 Ibs/ton aluminum produced (or 1.6 Ibs/ton aluminum producedifemission averaging is used) (BACT). Compliance Demonstration: Compliance with the limits described above shall be determined by comparing the allowable rate to the actual monthly average as calculated below: 

### E 

## = (C, 'Q,)+(C, 'Q,) p 

## = p', F p (453600. 

### p;) 'h, Where i is the month, EFP is the actual production-based emission rate oftotal fluorides based on amonthly average (pounds/ton), C1is the average total fluoride concentration in the primary control system effluent gas as determined through the annual testing required 3. Testing Requirements below (milligrams/dry standard cubic foot), 

### QI is primary control system effluent gas flow rate (dry standard cubic feetlhour), Cz is the total fluoride concentration in the roofmonitor effluentgas as determined through the monthly testing required 3. Testing Requirements below (milligrams/dry standard cubic foot), Q2 is roofmonitor effluent gas flow rate (dry standard cubic feetlhour), Pi is the monthly average aluminum production rate during month i (tonslhr), P'i is the actual total aluminum productionduring month i (tons) and hi is the total monthlyhours ofoperation during month i (hours),
c. SOz emissions [(see Section D Item#3 BACT)]. d. Pursuantto 401 KAR 51 :017, CO emissions from the potlines are limited to 233.6Ibs/ton (combined roofmonitors and control stack) ofaluminum produced (BACT). Compliance Demonstration: See performance testing required by condition 3.h. Testing Requirements
e. Pursuant to 401 KAR 51:017, PM emissions from the potlines are limited to 4.88Ibs/ton (combined roofmonitors and control stack) ofaluminum produced (BACT), Compliance Demonstration: Seeperformance testing required by condition 3.1. Testing Requirements f. Pursuant to 401 KAR 51 :017, PMlO/PMz.5 emissions from the potlines are limited to 2.1 Ibs/ton (combined roofmonitors and control stack) ofaluminum produced (BACT). Compliance Demonstration: Seeperformancetesting required by condition 3.1. Testing Requirements 3. Testing Requirements:
a. Pursuant to 40 CFR 63.847(b), thirty days prior to the initial performance test, the permittee shall submit to the Division for approval a site-specific test plan. The plan shall include:PermitNumber: V-05-088 R2 Page: 15 of52 

### SECTION B - AFFECTED FACILITIES, APPLICABLE REGULATIONS, AND OPERATING CONDITIONS (CONTINUED)

I. Procedures for conducting initial and subsequent performance tests as required in 40 CFR 63.848. n. Procedures to ensure that aminimum ofthree test runs areperformed annually for the primarycontrol systemfor each source. iii. Procedures to ensure that secondary emissions testing will occur according to the frequency established below:

• At least onerunperformedbeforethe 15th ofthe month,
• At least one run performed afterthe 15thofthe month,
• There are at least six days between two oftheruns during the month;
IV. Should the permittee wish, an alternateprocedure where measuredTF emissions from one potline can be used to estimate emissions from other potlines provided the permittee can demonstrate that the reference potline is similar in operation and productionto the untested potlines. b. Following approval ofthe site-specific test plan, the permittee shall conduct an initial performance test during the first month following the compliance date.
c. Ifa performance test has been conducted on the plimary control system within the 12 months prior to the compliance date, the results ofthat performance test may be used to determine initial compliance. d. Following the initial performance test, the permittee shall submit to periodic testing as prescribed inthe site-specifictest plan: I. For each primary control system, thepermittee shall perform at leastthree emission testruns peryear. n. Foreach source ofsecondary emissions, thepermittee shall perform at leastthree emission testruns permonth. iii. Ifthe permittee has performed more than threetests ofprimary control system during theprevious 12 consecutivemonths, the average ofall runs performed in the previous 12-monthperiod shall beused to determine the contribution from theprimary emission control system.
e. The initial performance test and all subsequent performance tests shall be conducted in accordance with the requirements ofthe general provisions in 40 CFR 63 Subparts A, the procedures in 40 CFR 63 SubpartLL and the approved testplan. f. The permittee shall use the reference methods listed 40 CFR 63.849 to determine compliance with the applicable emission limits for TF. g. To determine compliance with visible emission limits, the permittee shall perform annual Method 9 readings on each stack, vent or control device associated with the units listed above.PermitNumber: V-05-088 R2 Page: 16 of52 

### SECTION B - AFFECTED FACILITIES, APPLICABLE REGULATIONS, AND OPERATING CONDITIONS (CONTINUED) h. Fortheproductionincreaseproject authorizedthroughpermitV-05-088 R2, thepermittee shall conduct aperformance test within 6 months offinishing the construction ofpotline 3 (or finishing of first potline modification pursuant to V-05-088 R2) using EPA Reference Method 10 to quantify CO emissions from potline 3's A-398 reactor and the M-I06 Downcomer.
I. Fortheproductionincreaseproject authorized throughpermitV-05-088 R2, thepermittee shall conduct aperformance test for particulate emissions (filterable PM, PMIO,PM2.5 and Condensable Particulate) quarterly during the first year and thereafter once a year during the life ofthis permit. The first test shall be performed within 60 days offinishing the construction ofpotline 3 (finishing offirst potlinemodification pursuantto V-05-088 R2) using EPA approved methods to quantify particulate emissions (filterable PM, PMIO, PM2.5 and Condensable Particulate) from potline 3's A-398 reactor and the M-I06 Downcomer. This requirement supersedes thetesting timeframes contained in Section G (4)(e). 4. Specific Monitoring Requirements: For each emissionunit listed above, thepermittee shall monitorthe following parameters:
a. Continuous measurement ofAlumina (scrubbing media) flow, inlet air flow to the dry alumina scrubbers, alumina bed differential pressure and the baghouse differential pressure. b. Pursuant to 40 CFR 63.847(e), monthly total hours ofoperation.
c. Pursuantto 40 CFR 63.847(e), monthly total aluminum production. d. Pursuantto 40 CFR 63.847(e), production-based pollutantemission rates.
e. Pursuantto 40 CFR 63.848(k), weightmeasurement device calibrations. f. Procedures for the proper operation and maintenance of monitoring device(s) or system(s) usedto determine compliance, including: i. Thepermittee shall submitrecommended accuracyrequirements to the DAQ for review and approval. [40 CFR 63.848 (k)] ii. All monitoring devices mustbe certified bythepermitteeto meetthe accuracy requirements and must be calibrated in accordance with themanufacturer's instructions. [40 CFR 63.848 (k)] g. Primary control system TF emissions (based on annual average of at least 3 runs or alternate schedule authorized bythe Division).PermitNumber: V-05-088 R2 h. Secondary TF emissions (based on schedule authorized by the Division). Page: 17 of52 monthly average of at least 3 runs or alternate 

### SECTION B - AFFECTED FACILITIES, APPLICABLE REGULATIONS, AND OPERATING CONDITIONS (CONTINUED)

I. Pursuantto 401 KAR 61 :165, Section 6(3), ambient airmonitoringresults. J. Pursuantto 40 CFR 63.848(f) and (g), for each dry scrubberlbaghouse control system: i. Operating parameters. ii. Daily visual inspections ofthe equipment. iii. Daily visual qualitative visual observation of visible emissions from each control device exhaust stack. k. Pursuant to 401 KAR 61 :165, Section 3, for each stack, vent orcontrol system: i. Daily observations ofvisible emissions during operation ofassociated equipment. ii. Observations of visible emissions during all periods of control equipment malfunction. iii. Method 9 observation shall be performed ifvisible emissions are seen. 5. SpecificRecord keeping Requirements: The permittee shall maintain records ofthe following information:

a. Pursuant to 40 CFR 63.847(e), monthly total hours ofoperation. b. Pursuant to 40 CFR 63.847(e), monthly total aluminum production.

c. Pursuant to 40 CFR 63.847(e), production-based pollutant emissionrates forTF. d. Pursuant to 40 CFR 63.850(e), primary control system TF emission tests.
e. Pursuantto 40 CFR 63.850(e), secondaryTF emission tests. f. The portion ofTF measured as particulate matter and the portionthatis measured as gaseous when the particulate and gaseous fractions are quantified separately using an approved testmethod. g. Ifemission averaging is used, the currentimplementationplan for emission averaging and records supporting monitoring ofsimilarpotlines and demonstratingthatthe performance ofsimilarpotlines is the same as or betterthan that ofpotlines sampled by manual methods. h. Pursuant to 40 CFR 63.850(e)(xiii), documentation ofcorrective actions taken when any operating parameter limits are exceeded.
I. Pursuant to 40I KAR 61: 165, Section 6, ambient airmonitOling results for fluorides.PermitNumber: V-OS-088 R2 Page: 18 of52 J. Pursuantto 40 CFR63.850(e)(xi), for each dry scrubberlbaghouse control system: i. Operatingparameters. 

### SECTION B - AFFECTED FACILITIES, APPLICABLE REGULATIONS, AND OPERATING CONDITIONS (CONTINUED) ii. Dailyvisual inspections ofthe equipment. iii. Dailyvisual qualitative visual observationofvisible emissions from each control device exhaust stack. k. Foreach stack, ventorcontrol system, alog ofall visible emission observations. If visibleemissions are observed, the log shall indicate: i. Method 9readings ifany visibleemissions are seen. ii. The causeofthe abnormal visible emissions. iii. Any corrective actions taken. 1. Pursuant to 40 CFR 63.850(e)(iii), current startup, shutdown and malfunction (SS&M) plan.
m. A copy ofstandard workpractices shall be kept on site and available for inspection.
n. Continuous measurement ofAlumina (scrubbing media) flow, inlet air flow to the dry alumina scrubbers, alumina bed differential pressure and the baghouse differential pressure.
o. Records shall be kept ofthe sulfur content ofthe petroleum coke and pitch used as raw materials. 6. Specific Reporting Requirements: a, The permittee shall submitto the Division: 

### i. Pursuant to 40 CFR 63.850(a), notification of initial performance test, initial compliance status and compliance approach. 11. Pursuantto 401 KAR 50:045, theresults ofany stack test conducted at the source within 45 days ofthe completion ofany fieldwork associated with the test. iii. Pursuantto 40 CFR 63.850(b), an annual summary ofall performancetests. b. Pursuantto 40 CFR 63.850(d), the permittee shall submitto the Division quarterly excess emission reports (EER, excess emissions shall be defined as any measured emission rate in excess ofthe limits specified in this permit) postmarked by the thirtieth (30th) day following the end ofeach quarter and containing the following information: i. Periods and magnitudes ofexcess emissions. ii. Nature and cause ofeach period ofexcess emissions. iii. Periods during which the continuous monitoring system was inoperative. iv. Records ofcalibration checks, adjustments, and maintenance performed on the monitoring system. v. Periods when no excess emissions have occurred.PermitNumber: V-OS-088 R2 Page: 19 of52 

### SECTION B - AFFECTED FACILITIES, APPLICABLE REGULATIONS, AND OPERATING CONDITIONS (CONTINUED)

c. Pursuant to 40I KAR 61: 165, the pennittee shall submit to the Division quarterly ambient monitoring data reports ifrequired. Ifthe limit for a given operating parameter associated with monitoring a specific control device is exceeded 6 times in any semiannual reporting period, then any subsequent exceedance in that reporting period is a violation. For the purpose ofdetennining the number ofexceedances, no more than one exceedance shall be attributed in any given 24-hourperiod. d. Pursuant to 40 CFR 63.848(i), ifany operating or emission limit on a specific unit or operational group is exceeded more than 6 times in a specified semi-annual reporting period (as defined in SECTION F 6 below), the pennittee shall submit a corrective actionplan to the Owensboro Regional Office for the Division's approval no laterthan 30 days from the due date ofthe semi-annual report.
e. Pursuant to 40I KAR 50:055, with the exception of specific reporting requirements outlined above, the permittee shall report exceedances ofany operating or emission limit specified in this permit to the Division's Owensboro Regional Office as described in SECTION F 8below. 7. Specific Control Equipment Conditions: i. Thepennittee shall always operate the dry alumina scrubbers and baghouses in accordance with manufacturer's specifications (BACT limit). ii. See SECTION D 2below. 8. Compliance Certification: See SECTION D 3 below.PermitNumber: V-05-088 R2 Page: 20 of52 

### SECTION B - AFFECTED FACILITIES, APPLICABLE REGULATIONS, AND OPERATING CONDITIONS (CONTINUED) SUBJECT ITEM 5 REQUIREMENTS: Green Anode Production Unit# Unit Name Rate Construction Date (tons/year) M2 (IE) AnodeMix Conveying 127,020 December 12, 1972 M3 (2E) AnodeMix Conveying 127,020 January I, 1975 M4 (3E) Anode Mix Conveying 127,020 June 19, 1979 M5 (6E, 7E, 8E)"' j Anode Mixers (3) 54,437 August4, 1972 M6 (9E,EA)L, j Anode Mixers (2) 36,291 July 28, 1977 M7 (5E,4E)"' j Anode Mixers (2) 36,291 August4,1972

Emissions from Process units M2 thru M7 are controlled by abaghouse and dry coke scrubber (Unit# EN); 

## ?roC 

## ,0C{ ; 

### r () to ,'-t2 Units M5, M6, and M7 include a common pitch scale not listed as a separateunit 3 Units M5, M6, and M7 prepare materials for two existing Presses Press 1 and Press 2 APPLICABLE REGULATIONS: 401 KAR 61:020 Existing Process Operations for Unit M2, M3, M5 and M7 401 KAR59:010 New Process Operations for Unit M4 and M6 40 CFR 63 Subpart LL Primary Aluminum ProductionNESHAP 1. QperatingLimitations: a. Pursuant to 40 CFR 63.843, the permittee shall install acoke scrubber with closed vent transport system to control polycyclic organic matter (POM) emissions. b. Thepermittee shall specify and provide the basis orrationale for selectingparameters to be monitored and the associated operating limits forthe emission control device.

c. Ifamonitoring device for aprimary control device measures an operatingparameter outsidethe limits established pursuant to 40 CFR 63.847 (h) or ifvisible emissions indicatingabnormal operation are observed from the exhaust stacIe-ofacontrol device during daily inspections, the permittee shall initiate the corrective actionprocedures identified in the startup, shutdown, andmalfunction plan within I hour. Failure to initiate the corrective action procedures within I houror to take the necessary corrective actions to remedy the problem is aviolation. d. See SECTION D 12 below
e. The associated control device(s) shall be operated all the time when the units are in operation. Compliance Demonstration: Records shall be kept ofthe times when the units4.IOpo67 

### , (55.0?,O!!)- 40 PermitNumber: V-05-088 R2 Page: 21 of52 are operatingbut the control devices are not. Records shall also be kept ofthe 

### SECTION B - AFFECTED FACILITIES, APPLICABLE REGULATIONS, AND OPERATING CONDITIONS (CONTINUED) maintenance activities. 2. Emission Limitations: a. OpacityStandard: Visible emissions shall not exceed the following limitations: i. Forequipmentconstructed on or afterJuly 2, 1975: 20 % opacity. 

## 'Pro' 0 1c< ; rii. Forequipment constructed before July 2, 1975: 40 % opacity. Compliance Demonstration: Compliance with the opacity limits described above shall be determined through monitoring, maintenance of the records and annual Method 9 readings. b. PMStandards: Hourlyparticulate emissions shall not exceed the following limits: i. For equipment constructed beforeJuly 2, 1975:

• Forprocess weight < 30 tonslhour: E'PM, 

## =

• Forprocess weights 2: 30 tonslhour: E'PM, = II. For equipmentconstructed on orafterJuly 2,1975: F . h 30 Ih E' 3.59po.62 • orprocess welg t < tons our: PM, = , F 'gh 30 Ih E' 17.3Ipo.!6 • orprocess weI ts ;;::: tons our: PM , 

### = I Compliance Demonstration: Compliance with the hourly particulate emISSIOn limits described above shall be determined by comparing the allowable rate to the actual rate as calculated below: E =?'j .EF pM,

# .(1- eE j

# I
PM" hij 100 ) Where i is the month, j is the unit, EpMij is the actual average hourly particulate emission rate from unit j during month i (pounds/hour), Pij is the actual specific operating parameter for month i (units/month), EFpMj is the overall uncontrolled KYEIS particulate emission factor for unit j (pounds/unit), hij is the actual total hours of operation for unit j during month i (hours/month) and CE j is the overall control efficiency (%) ofany air pollution control equipment associated with unitj. 3. Testing Requirements: a, Pursuant to 40 CFR 63 Subpart LL, initial compliance shall be demonstrated through site inspections and review ofsiterecords bythe Division. b, To determine compliance with visible emission limits, the permittee shall perform annual Method 9 readings on each stack, vent or control device associated with the units listed above. 4. Specific Monitoring Requirements: Thepermittee shall monitorthe following parameters: a. Monthly total hours ofoperation.PermitNumber: V-05-088 R2 Page: 22 of52


### SECTION B - AFFECTED FACILITIES, APPLICABLE REGULATIONS, AND OPERATING CONDITIONS (CONTINUED) b. Monthlytotal material processed.

c. Hourlypollutantemission rates. d. Continuous coke and air flow rates.
e. For each control system: i. Operatingparameters. ii. Dailyvisual inspections ofthe equipment. iii. Daily visual qualitative visual observation of visible emissions from each control device exhauststack. f. For each stack, vent or control system: i. Daily observations ofvisible emissions during operation ofassociated equipment. ii. Observations of visible emissions during all periods of control equipment malfunction. iii. Annual Method 9 readings during operation ofassociated equipment. 5. Specific Record keeping Requirements: The permittee shall maintain records of the following information: a. Monthlytotal hours ofoperation b. Monthly total material processed.
c. Hourlypollutantemission rates. d. Design information forthe capture system on the dry coke scrubber.
e. Continuous coke and air flow rates. f. Documentation of corrective actions taken when any operating parameter limits are exceeded. g. For each control system: i. Operatingparameters. ii. Dailyvisual inspections ofthe equipment. iii. Daily visual qualitative visual observation of visible emissions £i'om each control device exhaust stack. h. For each stack, vent or control system, a log of all visible emission observations. If visible emissions are observed, the log shall indicate: i. Method 9 readings ifany visible emissions are seen.Permit Number: V-05-088 R2 ii. The causeofthe abnonnal visible emissions. Page: 23 of52 

### SECTION B - AFFECTED FACILITIES, APPLICABLE REGULATIONS, AND OPERATING CONDITIONS (CONTINUED) iii. Any corrective actions taken. i. For each stack, vent or control system, records ofthe annual Method 9 readings. J. Current startup, shutdown andmalfunction (SS&M) plan. 

### ? 

## s 

## (0.+**f.,o<nJ~** 6. Specific Reporting Requirements:
. (,I)/< (T--
a. The pennittee shall submit to the Division notification ofinitial perfonnatce test, initial compliance status and compliance approach. b. The pennittee shall submit to the Division quarterly excess emiSSIOn reports (EER, excess emissions shall be defined as any measured emission rate in excess of the limitations specified herein) postmarked by the thirtieth (30th) day following the end of each quarter and containingthe following infonnation: i. Periods and magnitudes ofexcess emissions. ii. Nature and cause ofeach period ofexcess emissions. iii. Periods during which the continuous monitoring system was inoperative. iv. Records of calibration checks, adjustments, and maintenance perfonned on the monitoring system. v. Periods when no excess emissions have occurred.
c. Ifthe limit for a given operating parameter associated with monitoring a specific control device is exceeded six times in any semi-annual reporting period, then any subsequent exceedance in thatreporting period is aviolation. Forthepurpose ofdetennining the d. numberofexceedances, no more than one exceedance shall be attributed in any given 24- hourperiod.
e. If any operating or emission limit on a specific unit or operational group is exceeded morethan 6times in a specified semi-annual reporting period (as defined in SECTION F 6 below), the pennittee shall submit a corrective action plan to the Owensboro Regional Office for the Division's approval no later than 30 days from the due date ofthe semiannual report. f. With the exception ofspecific reporting requirements outlined above, the pennittee shall report exceedances of any operating or emission limit specified in this pennit to the Division's Owensboro Regional Office as described in SECTION F 8 below. 7. Specific Control Equipment Conditions:
a. The fabric filters shall be operated and maintained according to manufacturer's specifications.PermitNumber: V-OS-088 R2 Page: 24 of52 

### SECTION B - AFFECTED FACILITIES, APPLICABLE REGULATIONS, AND OPERATING CONDITIONS (CONTINUED) b. The permittee shall maintain the dry coke scrubber such that the generally accepted engineering standards for minimum exhaust rates as published in the "Industrial Ventilation: AHandbook ofRecommended Practice" are met.
c. See SECTION D 2below. 8. Compliance Certification: See SECTION D 3 below.PermitNumber: V-05-088 R2 Page: 25 of52 

### SECTION B - AFFECTED FACILITIES, APPLICABLE REGULATIONS, AND OPERATING CONDITIONS (CONTINUED) SUBJECT ITEM 6 REQUIREMENTS: Anode Bake Furnace N2 (EE) Anode Bake Furnace ("261 Furnace") Description: Processing rate 145,730 tons per yearbaked anodes. FuelUsage: 430 mm scfperyearnatural gas usage. Control equipment: Dry Scrubber/Baghouse System Construction date: August 4, 1972 APPLICABLE REGULATIONS: 401 KAR 51:017 Prevention ofSignificant Deterioration ofAir Quality (S02 and CO) 401 KAR 59:010 New Process Operations 401 KAR 63:002; 40 CFR 63 Subpart LL Primary Aluminum Production NESHAP 1. Operating Limitations:
a. Pursuant to 40 CFR 63.848 (j), the permittee shall install and operate a device that measures and records the daily weight of green anode material introduced into the furnace and ensure that the device is calibrated according to manufacturer's specifications. b. Pursuant to 40 CFR 63.848 (t), the permittee shall install, operate, calibrate, and maintain a continuous parameter monitoring system for each emission control device. All monitoring devices must be calibrated in accordance with the manufacturer's instructions.

c. Pursuant to 40 CFR 63.847 (h), the permittee shall determine upper and/or lower operating limits, as appropriate, for each monitoring device for the emission control system from the values recorded during each ofthe runs from the initial performance test and from historical data. d. Pursuant to 40 CFR 63.848 (h), if a monitoring device for a plimary control device measures an operating parameter outside the limits established pursuant to 63.847 (h) or ifvisible emissions indicating abnormal operation are observed from the exhaust stack of a control device during daily inspections, the permittee shall initiate the corrective action procedures identified in the startup, shutdown, and malfunction plan within I hour. Failure to initiate the corrective action procedures within I hour or to take the necessary corrective actions to remedy the problem is aviolation.

e. See SECTION D 1 below. f. The dry scrubberlbaghouse system shall be operated when the anode bake furnace is in operation.PermitNumber: V-OS-088 R2 Page: 26 of52


### SECTION B - AFFECTED FACILITIES,APPLICABLE REGULATIONS, AND OPERATING CONDITIONS (CONTINUED) g. The permittee shall install and operate an advanced furnace firing and control system to minimize natural gas usage per unit ofbaked anode production and thus, CO emissions. (401 KAR 51 :017; BACTWork Practice) 2. Emission Limitations:
a. Opacity Standard: Pursuant to 401 KAR 59:010 Section 3 (1)(a), visible emissions from each stack or vent associated with the emission units described above shall not equal or exceed 20

### % opacity. Compliance Demonstration: Compliance with the opacity limits described above shall be determined through monitoring, maintenance of the records and annual Method 9 readings. b. PM Standards:
l. Pursuant to 401 KAR 59:010 Section 3 (2), hourly particulate emissions shall not exceed the limit: E'PM = 3.59p062 Where E'PM is the allowable particulate emission rate (pounds/hour) and P is the averageprocess weight (tons/hour). Compliance Demonstration: Compliance with the hourlyparticulate emission limit described above shall be determined by comparing the allowable rate to the actual rate as calculatedbelow: EpM, = P, ·EF pM

# .(1- CE) h, 100 Where i is the month, EPMi is the actual average hourly particulate emission rate during month i (pounds/hour), Pi is the actual throughput for month i (throughput in tons/month), EFpM is the overall uncontrolled KYEIS particulate emission factor (poundslton), hi is the actual total hours ofoperation during month i (hours/month) and CE is the overall control efficiency (%) ofthe dry scrubber/baghouse system. 11. To preclude the requirements of401 KAR 51:017 (V-05-0SS Rl permit action), the permittee shall not allow PM/PM lO emissions from the Anode Bake Furnace to exceed 5.14 lb/hr on a 3-h9.!!r:,average basis (Synthetic Minor Limit).
. . Compliance Demonstration: See performance testing as required by Condition 3.j, and monitoring as required by Conditions 4.g.

c. S02 Standards: See Section D Item #3Permit Number: V-05-088 R2 Page: 27 of52 

### SECTION B - AFFECTED FACILITIES, APPLICABLE REGULATIONS, AND OPERATING CONDITIONS (CONTINUED) d. TF& POM Standards: Pursuantto §63.843 (c), Total fluoride (TF) emissions shall not exceed 0.20 Ib/ton of green anode and polycyclic organic matter (POM) emissions shall not exceed 0.18 lb/ton ofgreen anode. Compliance Demonstration: Compliance with the limits described above shall be determined bycomparingthe allowablerateto the actual rate as calculatedbelow:
E 

### = (Cx·Q)

### p=~

Xp (453600·p;) 'h, Where X is the pollutant (TF or POM), Ex? is the actual production-based emission rate ofpollutant X based on amonthly average (pounds/ton), Cx is the average total concentration ofpollutant X system effluent gas (milligrams/dry standard cubic toot), Q system effluent gas flow rate (dry standard cubic feet/hour), his the actual monthly hours ofoperation (hours/month), P; is the monthly average aluminum production rate during month i (tonslhr), Pi is the actual total aluminum production during month i (tons) and h; is thetotal monthly hours ofoperation during month i (hours). 3. Testing Requirements: a. Pursuant to 40 CFR 63.847 (b), thirty days prior to the initial performance test, the permittee shall submit to the Division for approval a site-specific test plan that shall include: i. Procedures for conducting initial and subsequent performance tests required in 40 CFR 63.848. 11. Procedures to ensure that aminimum ofthreetest runs are performed annually for the primarycontrol system. 111. Procedures for establishingthe frequency oftesting. b. Followingthe initial performance test, thepermittee shall submitto periodictesting ofTF and POM as prescribed in the site-specifictestplan: i. For each primary control system, the permittee shall perfonn at least three emission test runs peryear. 11. Ifthe permittee has performed more than three tests ofprimary control system during the previous 12 consecutivemonths, the average ofall runs performed in the previous 12-month period shall be used to determine the contribution from the primary emission control system.
c. The initial performance test and all subsequent performance tests shall be conducted in accordance with the requirements ofthe general provisions in 40 CFR 63 Subparts A, the procedures in40 CFR 63 Subpart LL, and the approved test plan. d. The permittee shall use the reference methods listed in 40 CFR 63.849 to determine compliancewith the applicable emission limits for TF.PermitNumber: V-05-088 R2 Page: 28 of52


### SECTION B - AFFECTED FACILITIES, APPLICABLE REGULATIONS, AND OPERATING CONDITIONS (CONTINUED)

e. To detennine compliance with visible emission limits, the pennittee shall perfonn annual Method 9 readings on each stack, vent or control device associated with the units listed above. f. A sample ofgreen anode and baked anode shall be tested monthly for sulfur content. A sample ofpacking coke shall be tested quarterly for sulfurcontent. g. Following the completion oftherefurbishment project authorizedthrough Permit V-05- 088 Revision I, the pennittee shall perfonn aperfonnance test annually within 3 months ofthe anniversary ofthe pennit using EPA ReferenceMethod 10 to quantify CO emissions from each operating reactor stack ofthe dry scrubberlbaghouse system. (The anniversary ofthe pennit is the day ofthe month whenpennit V-05-088 was issued.) h. Thepennittee shall perform aperfonnance test for PM/PMIO within one yearof completing Phase I ofthe refurbishment project authorized through PennitV-05-088 Revision I (i.e., therefurbishment of18 sections of261W) to quantify PM/PMIO emissions from each operating reactor stack ofthe dry scrubberlbaghouse system and to show compliance with the emission limit of5.14 lblhr. Subsequentperfonnancetesting for PM/PMIO shall be completed onceperpennit tenn. EPAReferenceMethod 5 shall be used during the initial demonstration ofcompliance and subsequent tests to quantify PM/PM10 emissions from each operating reactor stack ofthe dry scrubber/baghouse system. 4. Specific Monitoring Requirements: Thepennittee shall monitor the following parameters:
a. Monthly total hours ofoperation. b. Monthly total material processed.
c. Production-based pollutant emissionrates for TF and POM. d. Primary control system TF emissions (based on annual average ofat least 3 runs, all valid 

## runsmust be included in average).
e. Primary control system POM emissions (based on annual average ofat least 3 runs, all valid runs mustbe included in average). f. Procedures for the proper operation and maintenance ofmonitoring device(s) or system(s) used to detennine compliance, including: i. Thepennittee shall submitrecommended accuracyrequirements to the DAQ for review and approval. [40 CFR 63.848 (k)]PermitNumber: V-05-088 R2 Page: 29 of52 

### SECTION B - AFFECTED FACILITIES, APPLICABLE REGULATIONS, AND OPERATING CONDITIONS (CONTINUED) ii. All monitoring devices mustbe certifiedbythepennitteeto meetthe accuracy requirements and mustbe calibrated in accordance withthemanufacturer's instructions. [40 CFR 63.848 (k)] g. For each control system: i. Dailyvisual inspections ofthe equipment. ii. Dailyvisual inspections ofeach control device exhauststack for evidence of abnonnal operation. h. For each stack, vent or control system: i. Dailyobservations ofvisible emissions during operationofassociated equipment. ii. Observations ofvisible emissions during all periods ofcontrol equipment malfunction. iii. Ifvisible emissions are seen, aMethod 9 shall be perfonned to read the opacity. 5. Specific Record keeping Requirements: The pennittee shall maintain records of the following infonnation:
a. Monthlytotal hours ofoperation b. Monthlytotal material processed.
c. Production-basedpollutantemission rates forTF and POM. d. Results ofall TF and POM emission tests. Ifan alternative test method to measure fluoride emissions is selected, records are to be maintained that demonstrate that both the particulate and gaseous portion ofthe fluoride pollutant are measured.
e. Ifemission averaging is selected as the method used to demonstrate compliance with the emissions ofTF orPOM emissions, acopy ofthe currentimplementation plan shall be maintained. f. Documentation of corrective actions taken when any operating parameter-limits are exceeded. g. For the dry scrubber/baghouse control system: i. Dailyvisual inspections ofthe equipment. h. For each stack, vent or control system, a log ofall visible emission observations. If visible emissions are observed, the log shall indicate: i. Method 9 readings. ii. The cause ofthe abnonnal visible emissions. iii. Any corrective actions taken.PermitNumber: V-OS-088 R2 Page: 30 of52 

### SECTION B - AFFECTED FACILITIES, APPLICABLE REGULATIONS, AND OPERATING CONDITIONS (CONTINUED)

1. Current startup, shutdown and malfunction (SS&M) plan. J. Sulfurcontentmeasurements ofgreen anodes, baked anodes, and packing cokeused in quantifying 802 emissions using the Alcan 802 Calculation Engine. 6. Specific Reporting Requirements:
a. Thepermittee shall submitto the Division: i. Notification ofinitial performance test, initial compliance status and compliance approach. ii. Theresults ofany stacktest conducted atthe sourcewithin45 days ofthe completion ofany fieldwork associated with the test. iii. An annual summary ofall performance tests. b. The permittee shall submit for the Division's approval aplan to ensure that each piece of associated control equipmentis properly operated and maintained. The plan shall include the following information: i. The operating parameters to be monitored. ii. Acceptableranges orlimits for each operatingparameter. iii. The monitoring frequency for each parameter. iv. The criteriaused to selecteach parameter, range, limit and frequency includinghow each ofthese relates to emission control. v. Therecommended accuracyrequirements for each monitoringdevice.
c. The permittee shall submit to the Division quarterly excess emission reports (EER, excess emissions shall bedefined as any measured emission rate in excess ofthe limitations specified herein) postmarked bythe thirtieth (30th) day following the end of each quarter and containingthe following information: i. Periods and magnitudes ofexcess emissions. ii. Nature and causeofeachperiod ofexcess emissions. iii. Periods during which the continuous monitoring system was inoperative. iv. Records ofcalibration checks, adjustments, and maintenanceperformed on the monitoring system. v. Periods when no excess emissions have occurred. d. Ifthe limit for a given operating parameter associated with monitoring a specific control device is exceeded six times in any semi-annual reporting period, then any subsequent exceedance in that reporting period is a violation. For the purpose ofdetermining the number ofexceedances, no more than one exceedance shall be attributed in any given 24- hour period.PermitNumber: V-05-088 R2 Page: 31 of52 e. If any operating or emission limit on a specific unit or operational group is exceeded morethan 6times in aspecified semi-annual reporting period (as defined in SECTION F 6below), thepermittee shall submit a corrective actionplan to the Owensboro Regional 

### SECTION B - AFFECTED FACILITIES, APPLICABLE REGULATIONS, AND OPERATING CONDITIONS (CONTINUED) Office for the Division's approval no later than 30 days from the due date ofthe semiannual report. f. With the exception ofspecific reporting requirements outlined above, the permittee shall report exceedances of any operating or emission limit specified in this permit to the Division's Owensboro Regional Office as described in SECTION F 8 below. 7. Specific Control Equipment Conditions: a. The dry scrubberand baghouse system shall beoperated andmaintained according to manufacturer's specifications. b. See SECTION D 2below.PermitNumber: V-05-088 R2 Page: 32 of52 

### SECTION B

- AFFECTED FACILITIES, APPLICABLE REGULATIONS, AND OPERATING CONDITIONS (CONTINUED) SUBJECT ITEM 7 REQUIREMENTS: Holding Furnaces Unit# UnitName Control Construction Date F1 (11-16) Holding Furnaces (6) with In-Line Degassers None August4, 1972 F2 (17, 18) Holding Furnaces (2) with In-Line Degassers None August4, 1979 APPLICABLE REGULATIONS: 401 KAR 59:010 New process operations for unit F2 401 KAR 61 :020 Existingprocess operations for unit Fl 40 CFR 63 Subpart RRR Secondary aluminumproduction NESHAP 1. Operating Limitations:

a. The pennittee shall use only clean charge. b. The permittee shall maintain a reactive flux injection rate at orbelow rate used during the perfonnance test for each operating cycle ortime period used in the perfonnance test.
c. The pennittee shall install and operate a device that measures and records the weight of all materials fed/charged and/or aluminum produced to an accuracy of

### ± 1%. The weight measurement device shall be calibrated according to manufacturer's specifications or at leastonce every 6 months. d. The pelmittee shall provide and maintain easily visible labels posted at each emission unit that identify the applicable emission limits and the means ofcompliance.

e. See SECTION D 1 below. 2. Emission Limitations:

a. OpacityStandard: Visible emissions shall not exceed the following limitations: i. Forequipment constructed on orafterJuly 2, 1975: 20 % opacity. --ii. For equipment constructed beforeJuly 2, 1975: 40% opacity. Compliance Demonstration: Compliance with the opacity limits described above shall be detennined through monitoring, maintenance ofthe records and annual Method 9 readings.
4.l0po67 

### ,

= (55.0p,°11)-40 Forprocess weights? 30 tons/hour: E'PM, 

## • b. PMStandards: Particulate emissions shall not exceed the following limits: i. Forequipment constructed before July 2, 1975:

• Forprocess weight < 30 tons/hour: E'PM, =PermitNumber: V-05-088 R2 Page: 33 of52


### SECTION B - AFFECTED FACILITIES, APPLICABLE REGULATIONS, AND OPERATING CONDITIONS (CONTINUED) ii. Forequipment constructed onor afterJuly 2,1975:

• Forprocess weight < 30 tonslhour: E'PM, = 3.59p,°·62

• Forprocess weights :2: 30 tonslhour: E'PM, = 17.31p,°·16 Compliance Demonstration: Compliancewith the hourly particulate emission limits described above shall be determined by comparing the allowablerate to the actual rate as calculated below:



### = Pij' EF pMi

# .(1- CE j ) EpM

, hij 100 Where i is the month, j is the unit, EpMij is the actual average hourly particulate emission rate from unitj during month i (pounds/hour), Pij is the actual specific operating parameter for month i (units/month), EFpMj is the overall uncontrolled KYEIS particulate emission factor for unitj (pounds/unit), hij is the actual total hours ofoperation for unitj during month i (hours/month) and CEj is the overall control efficiency (%) ofany air pollution control equipment associated with unitj.
c. Pursuant to 40 CFR 63 Subpart RRR, emissions from any Group 1 Furnace shall not exceed the following limits: i. Particulate emissions shall notexceed 0.4 lb/ton offeed. ii. Hydrochloric acid (HCI) emissions shall not exceed O.4lb/ton offeed. d. Pursuantto 40 CFR 63 SubpartRRR, emissions from any In-Line Fluxershall not exceed the following limits: i. Particulate emissions from shall not exceed 0.01 lb/ton offeed. ii. Hydrochloric acid (HCI) emissions shall not exceed 0.04 lb/ton offeed.
e. Pursuantto 40 CFR 63 SubpartRRR, the source has a choice to limit emissions from Group I Furnaces and In-Line Fluxers on an individual basis (as in 2.c. and 2.d. above) or as pali ofa SecondaryAluminum Processing Unit (SAPU). i. Ifeach existing Group I Furnace and In-Line Fluxeris in compliancewith individual emission limits, then the SAPU shall be considered to be in compliance and the threedayrollingcalculation shall notberequired. Compliance Demonstration: Compliancewiththe limits described in 2.c. and 2.d. above shall be determined by comparing the allowablerate to the actual rate as calculated below: E E 

### =----r..

X

p 

### P Where X is the pollutant, E xp is production-based emission rate of each limited pollutant (pounds/ton aluminum charged), Ex is the actual hourly emission rate of pollutantX as determined during aperformance test (pounds/hour) and P is the actual total aluminum charged during theperformance test (tonslhour).Permit Number: V-OS-088 R2 Page: 34 of52 

### SECTION B - AFFECTED FACILITIES, APPLICABLE REGULATIONS, AND OPERATING CONDITIONS (CONTINUED)

11. Ifthe source cannotorchooses notto demonstrate compliance with theindividual limits, the permittee shall maintain a 3-dayrolling average ofthe SAPU emission limits. iii. SAPU emission limits for eachpollutant shall be determined by applying the following equation:

n "Ex .p J IJ j=l = n 

# I (L Xj 

### ·P) )=1

### E~ n 

# I (P j ) jol Wherej is the unit, n is the total numberofunits in the SAPU, X is the specific pollutant, E'x is the allowable SAPU emissions forpollutant X (pounds/ton material charged), LXj is the emission limit for pollutantX specific to unitj (pounds/tons material charged), and Pj is the operating rate for unitj (tons material charged/hour). Compliance Demonstration: The 3-dayrolling average for an individual SAPU shall be calculated with the following equations: J LEx, Ex 

## = -,,;-'-'.1

__ 3 n 

# LJt j=l Where i is the day, j is the unit, n is the total numberofunits in SAPU, X is the pollutant, Ex is the 3-dayrolling average emissions ofpollutant X (pounds/tons material processed), Ex; is the estimated actual emissions from the SAPU on day i (pounds/tons material charged), EXj is the measured emission rate ofpollutantX from emission unitj as determined in the performance test (pounds/ton ofmaterial processed), and Pij is the total amount ofmaterial processed in unitj on day i (tons). 3. Testing Requirements:

a. The permittee shall demonstrate initial compliance with each applicable emISSIOn, equipment, work practice, or operational standard for each affected source and emission unit as per40 CFR 63, Subpart RRR, sections 63.1511 and 63.1512(e) and (h).-- b. The permittee shall conduct performance tests every 5 years following the initial compliance test.
c. To determine compliance with visible emission limits, the permittee shall perform annual Method 9 readings on each stack, vent or control device associated with the units listed above. 4. Specific Monitoring Requirements: Thepermittee shall monitorthe following parameters:PermitNumber: V-05-088 R2 a. Monthlytotal hours ofoperation. Page: 35 of52 

### SECTION B - AFFECTED FACILITIES, APPLICABLE REGULATIONS, AND OPERATING CONDITIONS (CONTINUED) b. Monthlytotal aluminum production.
c. Hourlypollutantemission rates. d. Production-based pollutantemission rates.
e. Foreach operating cycle ortimeperiod used in theperformance test, the following parameters: i. Total fluxing hours peroperating cycle. ii. Total HCI added by weightperoperating cycle. iii. Hourly fluxing rate (based on operating cycle average). iv. Otherparameters needed to perform alternative flux injectionrate determination as described in 40 CFR 63 SubpartRRR section 63.1510G)(5). f. Weightmeasurementdevice calibrations. g. Monthly inspections ofequipmentlabels. h. Foreach stack, ventorcontrol system: i. Monthly observations ofvisible emissions during operationofassociated equipment. ii. Observations ofvisible emissions during all periods ofcontrol equipment malfunction.? 

## NoNeiii. Annual Method 9 readings during operation ofassociated equipment. 5. Specific Record keeping Requirements: The permittee shall maintain records of the following information:
a. Monthlytotal hours ofoperation. b. Monthlytotal aluminumproduction.
c. Hourlypollutantemission rates. d. Production-based pollutantemissionrates.
e. Parameters for determining fluxing rate. f. Weight measurement device calibrations. g. Monthlyinspections ofequipmentlabels. h. For each stack, vent or control system, a log ofall visible emission observations. If visible emissions are observed, the log shall indicate:PermitNumber: V-05-088 R2 i. Method 9 readings ifany visible emissions are seen. Page: 36 of52 

### SECTION B - AFFECTED FACILITIES, APPLICABLE REGULATIONS, AND OPERATING CONDITIONS (CONTINUED) ii. The cause ofthe abnormal visible emissions.
iii. Any corrective actions taken.
1. Foreach stack, vent orcontrol system, records ofthe annual Method 9 readings. 6. Specific Reporting Requirements: a. The pennittee shall report to the Division pursuant to 40 CFR 63 Subpart RRR, sections 63.1515, Notifications and 63.1516, Reports. b. With the exception ofspecific reporting requirements outlined above, the pennittee shall report exceedances of any operating or emission limit specified in this pennit to the Division's Owensboro Regional Office as described in SECTION F 8 below. 7. Specific Control Equipment Conditions: See SECTION D 2 below. 8. Compliance Certification: a. The pennittee shall submit semi-annual certification to the Division that only clean charge was used inthe furnaces. '""D",,v-<-**~N** -(.vL &MA<..' 

# «-V:>"If-$. b. See SECTION D 3 below.PermitNumber: V-05-088 R2 Page: 370f52 

### SECTION B - AFFECTED FACILITIES, APPLICABLE REGULATIONS, AND OPERATING CONDITIONS (CONTINUED) SUBJECT ITEM 8 REOUIREMENTS: Roads EP (EP) Unpaved Roads Control equipment: None Constructiondate: 1972 APPLICABLE REGULATIONS: 401 KAR 63:010 Fugitive emissions 1. Operating Limitations: None 2. Emission Limitations:
a. The pennittee shall not cause orpenni! the discharge ofvisible fugitive dust emissions beyond the lot line ofthe property on which the emissions originate b. Thepennittee shall takereasonableprecautions to preventparticulate matter from becoming airborne. Such reasonableprecautions shall include, when applicable, but not be limited to the following: i. Application and maintenance ofasphalt, water, or suitable chemicals on roads, material stockpiles, and other surfaces that are sources ofairborne dusts. n. The use ofwater sprays orothermeasures to suppress the dust emissions during handling. 3. Testing Requirements: None 4. Specific Monitoring Requirements: The permittee shall monitorthe time, date, and type of precaution taken to prevent paIticulate matter from becoming airbome. 5. Specific Record keeping Requirements: The pennittee shall maintain records of the precautions taken to prevent fugitive dust. 6. Specific ReportingRequirements: See SECTION Fbelow. 7. Specific Control Equipment Conditions: None 8. Compliance Certification: See SECTION D 3 below.PermitNumber: V-05-088 R2 Page: 38 of52 

### SECTION B

- AFFECTED FACILITIES, APPLICABLE REGULATIONS, AND OPERATING CONDITIONS (CONTINUED) SUBJECT ITEM 9 REQUIREMENTS: Natural Gas Usage Unit# UnitName Rate Units Construction Date A6 (90) Re-Melt Furnace 64 MMBTU/hr August 1, 1999 HI (11) Homogenizing Furnace 13.5 MMBTU/hr March 1990 H2 (21) Homogenizing Furnace 13.5 MMBTU/hr March 1990 H3 (31) Homogenizing Furnace 13.5 MMBTU/hr March 1990 H4 (I3l) Homogenizing Furnace 14.0 MMBTU/hr December29,2000 APPLICABLE REGULATIONS: 401KAR59:010: New process operations 1. Operating Limitations: Natural gas should be the only fuel to be used for the units defined in Subject Item 9. 2. Emission Limitations: a. The visible emissions shall not exceed 20% opacity. b. The Particulate Matter emission shall not be more than 2.34 Iblhr. 

### Compliance Demonstration: The permittee is assumed to be in compliance, with the particulatematterlimit, while burning natural gas. 3. Testing Requirements: None 4. Specific Monitoring Requirements: The permittee shall monitor source-wide natural gas usage on amonthlybasis. 5. Specific Record keeping Requirements: The permittee shall maintain records ofmonthly source-wide natural gas usage. 6. Specific Reporting Requirements: None 7. Specific Control Equipment Conditions: None 8. Compliance Certification: See SECTION D 3 below.PermitNumber: V-OS-088 Rl 

### SECTION C - INSIGNIFICANT ACTIVITIES Page: 39 of52

The following listed activities have been detennined to be insignificant activities for this source pursuantto 401 KAR 52:020, Section 6. Although these activities are designated as insignificant the pennittee must comply with the applicable regulation. Process and emission control equipment at each insignificant activity subjectto an opacity standard shall be inspectedmonthly and a qualitative visible emissions evaluation made. Results ofthe inspection, evaluation, and any corrective action shall berecorded in alog. Description I. Emergency Generator(Natural gas) (Unit# RW-RCW-26- EMG)- 230kW 2. Anode coverstorageT34 (DC), T35 (DC) 3. 4 Boilers (A2, A3, A4, 41)

- 1.26 to 1.89 MMBTUlhr (Natural Gas) 4. Chip handling system (51) 5. Indirect waste oil heat exchanger (A5) 6. Electrostatic stub coating (EK) 7. Maintenance Area 046- Wood/Refractory Saw (AI) 8. Refractory/Carbon Saw

- Maintenance Saw (EH) 9. Propane vaporizerboiler 10. Gasoline storage fuel tank vent II. Diesel storage fuel tank vent 12. Small form control oven (Natural Gas) 13. A446 DayTank Vent Filter 14. Flex-Kleen Dust Collector Generally Applicable Regulation 401 KAR 61 :020 401 KAR 59:010 401 KAR 59:015 None 401 KAR 59:015 401 KAR 59:010 401 KAR 61:020 401 KAR 59:010 401 KAR 59:015 401 KAR 59:050 401 KAR 59:050 401 KAR 59:010 401 KAR 59:010 401 KAR 59:010PermitNumber: V-05-088 Rl Page: 40 of52 

### SECTIOND - SOURCE EMISSION LIMIT

### ATIONS AND TESTING REQUIREMENTS As required by Section Ib ofthe CabinetProvisions andProceduresfor Issuing Title VPermits incorporated by reference in 401 KAR 52:020, Section 26; compliance with annual emissions and processing limitations contained in this permit, shall be based on emissions and processing rates for any twelve (12) consecutivemonths. 1. The permittee shall follow the requirements described in the preventative maintenance plan for all units. Excursion from the requirements ofthe preventative maintenance plan shall be corrected in atimelymannerper401 KAR 50:055 section I, (4). 2. The facility shall maintain all control device equipment in accordance with the Preventative Maintenance Plan. This plan establishes maintenance management systems that ensure the continuing control capability ofpollution control devices in use at the facility. This plan includes inspection and maintenance work orders on a schedule determined by the O&M requirements and internal maintenance standards, determined by technical, engineeling, operations personnel which follow manufacturer's guidelines for operation and maintenance. 3. Sulfur Dioxide Emissions: Sulfur dioxide (S02) emissions shall not exceed 5,853 total tons in any l2-month consecutive period, from the production ofprimary aluminum by electrolysis (potline operations) and anode bake furnace operations (401 KAR 51:017; BACT Limit). Compliance Demonstration: Compliance with the annual S02 emission limit shall be determined by computing the total primary aluminum production S02 emissions monthly using the Alcan S02 Calculation Engine (an example ofthe form can be found in the Kentucky Division for Air Quality tracking system "TEMPO"); and calculating arolling l2-month S02 emission total for the primary aluminum process (potlines and anode baking furnaces). 4. The permittee shall follow the operation and monitoring requirements implemented in the site-specific OM& M plan for group furnaces: Holding Furnaces (FI (11-16), F2 (17-18)) and group 2 furnace: Re-melt Furnace (A6 (89)).PermitNumber: V-05-088 R2 Page: 41 of52 

### SECTION E - SOURCE CONTROL EQUIPMENT REQUIREMENTS Pursuant to 401 KAR 50:055, Section 2(5), at 

### all times, including periods ofstartup, shutdown and malfunction, owners and operators shall, to the extentpracticable, maintain and operate any affected facility including associated airpollution control equipment in amanner consistent with good air pollution control practice for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used will be based on information available to the Division which may include, but is not limited to, monitoring results, opacity observations, review ofoperating and maintenanceprocedures, and inspectionofthe source.PermitNumber: V-05-088 R2 Page: 42 of52 

### SECTION F - MONITORING, RECORD KEEPING, AND REPORTING REQUIREMENTS I. Pursuant to Section Ib (IV) I ofthe Cabinet Provisions and Procedures for Issuing Title V Permits incorporated by reference in 40I KAR 52:020, Section 26, when continuing compliance is demonstrated by periodic testing or instrumental monitoring, the permittee shall compilerecords ofrequired monitoring informationthat include: a. Date, place as defined in this permit, and time ofsampling ormeasurements; b. Analyses performancedates; c. Company or entitythatperformed analyses; d. Analytical techniques ormethods used; e. Analyses results; and f. Operatingconditions during time ofsampling ormeasurement. 2. Records of all required monitoring data and support information, including calibrations, maintenance records, and original strip chart recordings, and copies ofall reports required by the Division for Air Quality, shall be retained by the permittee for a period offive (5) years and shall be made available for inspection upon request by any duly authorized representative ofthe Division for Air Quality [Sections Ib(IV) 2 and Ia(8) ofthe Cabinet Provisions and Procedures for Issuing Title V Permits incorporated by reference in 401 KAR 52:020, Section 26]. 3. In accordance with the requirements of40I KAR 52:020 Section 3(1)h the permittee shall allow authorized representatives ofthe Cabinet to perform the following during reasonable times: a. Enterupon thepremises to inspect any facility, equipment (including airpollution control equipment), practice, or operation; b. To access and copy anyrecords required by thepermit: c. Sample or monitor, at reasonable times, substances or parameters to assure compliance with the permit or any applicable requirements. Reasonable times are defined as during all hours ofoperation, during normal office hours; or during an emergency. 4. No person shall obstruct, hamper, or interfere with any Cabinet employee or authorized representative while in the process ofcarrying out official duties. Refusal ofentry or access may constitutegrounds for permitrcvocation and assessment ofcivil penalties. 5. Summary reports ofany monitoring required by this permit, other than continuous emission or opacitymonitors shall be submitted to the Regional Office listed on the front ofthis permit at least every six (6) months during the life ofthis permit, unless otherwise stated in this permit. For emission units that were still under construction or which had not commenced operation at the end ofthe 6-month period covered by the report and are subject to monitoring requirements in this permit, the report shall indicate that no monitoring was performed during theprevious six months becausethe emission unitwas notin operation [Section Ib (V )I ofthe Cabinet Provisions and Procedures for Issuing Title V Permits incorporated byreferencePermitNumber: V-OS-088 R2 Page: 43 of52 

### SECTION F - MONITORING, RECORD KEEPING, AND REPORTING REQUIREMENTS (CONTINUED) in 401 KAR 52:020, Section 26]. 6. The semi-annual reports are due by January 30th and July 30th ofeach year. Data from the continuous emission and opacitymonitors shall be reported to the Technical Services Branch in accordance with the requirements of401 KAR 59:005, General Provisions, Section 3(3). All reports shall be certified by a responsible official pursuant to 401 KAR 52:020 Section 23. All deviations from permitrequirements shall be clearlyidentified inthereports. 7. In accordance with the provisions of401 KAR 50:055, Section I the permittee shall notify the Regional Office listed on the front of this permit concerning startups, shutdowns, or malfunctions as follows: a. When emissions during any planned shutdowns and ensuing startups will exceed the standards notification shall be made no later than three (3) days before the planned shutdown, or immediately following the decision to shut down, ifthe shutdown is due to events which could not have been foreseen three (3) days before the shutdown. b. When emissions due to malfunctions, unplanned shutdowns and ensuing startups are or may be in excess ofthe standards, notification shall be made as promptly as possible by telephone (orother electronic media) and shall submit written notice uponrequest. 8. The permittee shall report emission related exceedances from permit requirements including those attributed to upset conditions (otherthan emission exceedances covered by Section F.7. above) to the Regional Office listed on the front of this permit within 30 days. Other deviations from permit requirements shall be included in the semiannual report required by Section F.6 [Section Ib (V) 3, 4. ofthe Cabinet Provisions and Procedures for IssuingTitle V Permits incorporated by reference in 401 KAR 52:020, Section 26]. 9. Pursuant to 401 KAR 52:020, Permits, Section 21, the permittee shall annually certify compliance with the terms and conditions contained in this permit, by completing and returning a Compliance Certification Form (DEP 7007CC) (or an alternative approved by the regional office) to the Regional Office listed on the front ofthis permit and the U.S. EPA in accordance with the following requirements: a. Identification oftheterm or condition; b. Compliance status ofeach term orcondition ofthepermit; c. Whether compliance was continuous orintermittent; d. The methodused for determining the compliance status for the source, currently and over thereportingperiod. e. For an emissions unit that was still under construction or which has not commenced operation at the end ofthe 12-monthperiod covered by the annual compliance certification, the permittee shall indicate that the unit is under construction and that compliance with any applicablerequirements will bedemonstrated withinthetimeframes specified in thepermit.PermitNumber: V-05-088 R2 Page: 44 of52 

### SECTION F - MONITORING, RECORD KEEPING, AND REPORTING REQUIREMENTS (CONTINUED) f. The certification shall be postmarked by January 30th ofeach year. Annual compliance certifications should be mailed to the following addresses: Division for AirQuality Owensboro Regional Office 3032 Alvey Park Drive W., Suite 700 Owensboro, KY42303-7304 U.S. EPA Region 

### IV AirEnforcement Branch AtlantaFederal Center

61 Forsyth St. Atlanta, GA 30303-8960 10. In accordance with 401 KAR 52:020, Section 22, the permittee shall provide the Division with all information necessary to determine its subject emissions within 30 days ofthe date the Kentucky Emissions Inventory System (KYEIS) emissions survey is mailed to the permittee.PermitNumber: V-05-088 R2 

### SECTION G - GENERAL PROVISIONS 1. General Compliance Requirements Page: 45 of52

a. The permittee shall comply with all conditions ofthis permit. Noncompliance shall be a violation of401 KAR 52:020, Section 3(l)(b), and a violation ofFederal Statute 42 USC 7401 through 7671q (the Clean Air Act). Noncompliance with this permit is grounds for enforcement action including but not limited to termination, revocation and reissuance, revision or denial ofapermit [Section la-3 ofthe CabinetProvisions andProceduresfor Issuing Title VPermits incorporatedbyreference in 401 KAR 52:020, Section26]. b. The filing ofa request by thepermittee for any permitrevision, revocation, reissuance, or termination, or ofa notification ofa planned change or anticipated noncompliance, shall not stay any permit condition [Section la-6 oftbe CabinetProvisions andProceduresfor Issuing Title VPermits incorporated byreference in 401 KAR 52:020, Section 26].
c. This permit may be revised, revoked, reopened and reissued, or terminated for cause in accordance with 401 KAR 52:020, Section 19. The permit will be reopened for cause and revised accordingly underthe following circumstances: (l) If additional applicable requirements become applicable to the source and the remaining permit term is three (3) years or longer. In this case, thereopening shall be completed no later than eighteen (18) months after promulgation ofthe applicable requirement. A reopening shall not be required ifcompliance with the applicable requirement is not required until after the date on which the permit is due to expire, unless this permit or any ofits terms and conditions have been extended pursuant to 401 KAR 52:020, Section 12; (2) The Cabinet or the United States Environmental Protection Agency (U. S. EPA) determines that the permit must be revised or revoked to assure compliance with the applicable requirements; (3) The Cabinet or the U. S. EPA determines that the permit contains a material mistake or that inaccurate statements were made in establishing the emissions standards or other terms or conditions ofthe permit; (4) New requirements become applicable to a source subjectto the Acid Rain Program. Proceedings to reopen and reissue a permit shall follow the same procedures as apply to initial permit issuance and shall affect only those parts ofthe permit for which cause to reopen exists. Reopenings shall be made as expeditiously as practicable. Reopenings shall not be initiated before a notice ofintent to reopen is provided to the source by the Division, at least thirty (30) days in advance ofthe date the permit is to be reopened, except that the Divisionmay provide a shortertime period in the case ofan emergency. d. The permittee shall furnish information upon request ofthe Cabinet to determine ifcause exists for modifying, revoking and reissuing, or terminating the permit; or to determine compliance with the conditions of this permit [Sections la- 7 and 8 of the Cabinet Provisions andProceduresfor Issuing Title VPermits incorporated by reference in 401 KAR 52:020, Section 26].PermitNumber: V-05-088 R2 

### SECTION G - GENERAL PROVISIONS (CONTINUED) Page: 46 of52

e. Emission units described in this pennit shall demonstrate compliance with applicable requirements ifrequested bytheDivision [401 KAR 52:020, Section 3(1)(c)]. f. The pennittee, upon becoming aware that any relevant facts were omitted or incorrect infonnation was submitted in the pennit application, shall promptly submit such supplementary facts or corrected infonnation to the permitting authority [401 KAR 52:020, Section 7(1)]. g. Any condition orportion ofthis pennit which becomes suspended oris ruled invalid as a result ofany legal or other action shall not invalidate any other portion or condition of this pennit [Section 1a-14 ofthe CabinetProvisions andProceduresfor Issuing Title V Permits incorporated byreference in 401 KAR 52:020, Section 26]. h. The permittee shall not use as a defense in an enforcement action the contention that it would have been necessary to halt or reduce the pennitted activity in order to maintain compliance [Section Ia-4 ofthe Cabinet Provisions and Proceduresfor Issuing Title V Permits incorporated byreference in401 KAR 52:020, Section 26].

1. All emission limitations and standards contained in this permit shall be enforceable as a practical matter. All emission limitations and standards contained in this permit are enforceable by the U.S. EPA and citizens except for those specifically identified in this pennit as state-origin requirements. [Section 1a-15 of the Cabinet Provisions and Proceduresfor Issuing Title VPermits incorporated by reference in 401 KAR 52:020, Section 26]. J. This pennit shall be subject to suspension ifthe permittee fails to pay all emissions fees within 90 days after the date of notice as specified in 401 KAR 50:038, Section 3(6) [Section Ia-I0 of the Cabinet Provisions and Proceduresfor Issuing Title VPermits incorporated by reference in 401 KAR 52:020, Section 26]. k. Nothing in this pennit shall alter or affect the liability ofthe permittee for any violation ofapplicable requirements prior to or at the time ofpennit issuance [40I KAR 52:020, Section II(3) 2.]. 1. This permit does not convey property rights or exclusive privileges [S'ection la-9 ofthe CabinetProvisions andProceduresfor Issuing Title VPermits incorporated by reference in 401 KAR 52:020, Section 26].
m. Issuance ofthis permit does not relieve the permittee from the responsibility ofobtaining any other permits, licenses, or approvals required by the Cabinet or any other federal, state, orlocal agency.
n. Nothing in this pennit shall alteror affectthe authority ofU.S. EPA to obtain information pursuant to Federal Statute 42 USC 7414, Inspections, monitoring, and entry [401 KAR 52:020, Section 11 (3) 4.].Permit Number: V-05-088 R2 

### SECTION G - GENERAL PROVISIONS (CONTINUED) Page: 47 of52

o. Nothing in this permit shall alter or affect the authority of U.S. EPA to impose emergency orders pursuant to Federal Statute 42 USC 7603, Emergency orders [401 KAR 52:020, Section 11(3) I.]. p. This permit consolidates the authority ofany previously issued PSD, NSR, or Synthetic Minor source preconstruction permitterms and conditions for various emission units and incorporates all requirements ofthose existing permits into one single permit for this source. q. Pursuant to 401 KAR 52:020, Section 11, a permit shield shall not protect the owner or operator from enforcement actions for violating an applicable requirement prior to or at the time of permit issuance. Compliance with the conditions of this permit shall be considered compliance with: (1) Applicable requirements that are included and specifically identified in this pellliit; and (2) Non-applicable requirements expressly identified in this permit. 2. PermitExpiration and Reapplication Requirements
a. This permit shall remain in effect for a fixed term offive (5) years following the original date ofissue. Permit expiration shall terminate the source's right to operate unless a timely and complete renewal application has been submitted to the Division at least six (6) months prior to the expiration date of the permit. Upon a timely and complete submittal, the authorization to operate within the terms and conditions ofthis permit, including any permit shield, shall remain in effect beyond the expiration date, until the renewal permitis issued or denied bythe Division [401 KAR 52:020, Section 12]. b. The authority to operate granted shall cease to apply if the source fails to submit additional information requested by the Division after the completeness determination has been made on any application, by whatever deadline the Division sets [401 KAR 52:020, Section 8(2)]. 3. PermitRevisions
a. A minor permitrevision procedure may be used for permitrevisions involving the use of economic incentive, marketable permit, emission trading, and other similar approaches, to the extentthat these minorpermitrevision procedures are explicitlyprovided for in the State Implementation Plan (SIP) or in applicable requirements and meet the relevant requirements of401 KAR 52:020, Section 14(2). b. This permitis not transferable bythe permittee. Future owners and operators shall obtain a new permit from the Division for Air Quality. The new permitmay be processed as an administrative amendment ifno other change in this permit is necessary, and provided that a written agreement containing aspecific date for transferofpermitresponsibilityPermitNumber: V-OS-088 R2 

### SECTION G - GENERAL PROVISIONS (CONTINUED) Page: 48 of52

coverage and liability between the current and new permittee has been submitted to the permitting authority within ten (10) days following the transfer. 4. Construction, Start-Up, and Initial Compliance Demonstration Requirements Potlines (3) Pursuant to a duly submitted application the Kentucky Division for Air Quality hereby authorizes the construction ofthe equipment described herein, emission points EI, E3, E5, E! a, E3a and E5a in accordance with the terms and conditions ofthis permit.
a. Construction of any process and/or air pollution control equipment authorized by this permit shall be conducted and completed only in compliance with the conditions ofthis permit. b. Within thirty (30) days following commencement ofconstruction and within fifteen (15) days following start-up and attainment ofthe maximum production rate specified in the permit application, or within fifteen (15) days following the issuance date ofthis permit, whichever is later, the permittee shall furnish to the Regional Office listed on the front of this permit in writing, with a copy to the Division's Frankfort Central Office, notification ofthe following: (I) The date when construction commenced. (2) The date ofstart-up ofthe affected facilities listed inthis permit. (3) The date when the maximum production rate specified in the permit application was achieved.
c. Pursuant to 401 KAR 52:020, Section 3(2), unless construction is commenced within eighteen (18) months after the permit is issued, orbegins but is discontinued for aperiod of eighteen (18) months or is not completed within a reasonable timeframe then the construction and operating authority granted bythis permit for those affected facilities for which constmction was not completed shall immediately become invalid. Upon written request, the Cabinetmay extend these time periods ifthe source shows good cause. d. For those affected facilities for which construction is authorized by this permit, a source shall be allowed to construct with the proposed permit. Operational or final permit approval is not granted by this permit until compliance with the applicable standards specified herein has been demonstrated pursuant to 401 KAR 50:055. Ifcompliance is not demonstrated within the prescribed timeframe provided in 401 KAR 50:055, the source shall operate thereafter only for the purpose ofdemonstrating compliance, unless otherwise authorized by Section Iofthis permitororderofthe Cabinet.
e. This permit shall allow time for the initial start-up, operation, and compliance demonstration ofthe affected facilities listed herein. However, within sixty (60) days after achieving the maximum production rate at which the affected facilities will be operated but not later than 180 days afterinitial start-up ofsuch facilities, the permitteePermitNumber: V-05-088 R2 

### SECTION G - GENERAL PROVISIONS (CONTINUED) Page: 49 of52

shall conduct a performance demonstration on the affected facilities in accordance with 401 KAR 50:055, General compliance requirements. Testing must also be conducted in accordance with General Provisions G.5 ofthis permit. f. Terms and conditions in this permit established pursuant to the construction authority of 401 KAR 51:017 or401 KAR 51:052 shall not expire. 5. Testing Requirements

a. Pursuant to 401 KAR 50:045, Section 2, a source required to conduct a performance test shall submit a completed Compliance Test Protocol form, DEP form 6028, or a test protocol a source has developed for submission to other regulatory agencies, in a format approved by the cabinet, to the Division's Frankfort Central Office a minimum ofsixty (60) days prior to the scheduled test date. Pursuant to 401 KAR 50:045, Section 7, the Division shall be notified ofthe actual test date at leastthirty (30) days priorto the test. b. Pursuant to 401 KAR 50:045, Section 5, in order to demonstrate that a source is capable of complying with a standard at all times, any required performance test shall be conducted under normal conditions that are representative ofthe source's operations and create the highest rate ofemissions. If[When] the maximum production rate represents a source's highest emissions rate and a performance test is conducted at less than the maximum productionrate, a source shall be limited to aproductionrate ofno greaterthan 110percent ofthe average production rate during the performance tests. Ifand when the facility is capable ofoperation at the rate specified in the application, the source may retest to demonstrate compliance at the new production rate. The Division for Air Quality may waive these requirements on a case-by-case basis ifthe source demonstrates to the Division's satisfaction that the source is in compliance with all applicable requirements.

c. Results ofperformance testes) required by the permit shall be submitted to the Division by the source or its representative within forty-five days or sooner if required by an applicable standard, after the completion ofthe fieldwork. 6. Acid Rain Program Requirements
a. Ifan applicable requirement ofFederal Statute 42 USC 7401 through 7671q (the Clean Air Act) is more stringent than an applicable requirement promulgated pursuant to Federal Statute 42 USC 7651 through 76510 (Title IV ofthe Act), both provisions shall apply, and both shall be state and federally enforceable. b. The permittee shall comply with all applicable requirements and conditions ofthe Acid Rain Permit and the Phase II permit application (including the Phase II NOx compliance plan and averaging plan, ifapplicable) incorporated into the Title V permit issued for thisPermitNumber: V-OS-088 R2 

### SECTION G - GENERAL PROVISIONS (CONTINUED) Page: 50 of52

source. The source shall also comply with all requirements ofany revised or future acid rainpermit(s) issued to this source. 7. EmergencyProvisions
a. Pursuant to 401 KAR 52:020, Section 24(1), an emergency shall constitute an affirmative defense to an action brought for the noncompliance with the technology-based emission limitations if the permittee demonstrates through properly signed contemporaneous operatinglogs orrelevant evidencethat: (1) An emergency occurred and the permittee can identifYthe causeofthe emergency; (2) Thepermitted facility was at the time beingproperly operated; (3) During an emergency, the permittee took all reasonable steps to minimize levels of emissions that exceeded the emissions standards or other requirements in the permit; and (4) Pursuant to 401 KAR 52:020, 401 KAR 50:055, and KRS 224.01-400, the permittee notified the Division as promptly as possible and submitted written notice of the emergency to the Division when emission limitations were exceeded due to an emergency. The notice shall include a description ofthe emergency, steps taken to mitigate emissions, and corrective actions taken. (5) This requirement does not relieve the source of other local, state or federal notificationrequirements. b. Emergency conditions listed in General Condition G.7.a above are in addition to any emergency or upset provision(s) contained in an applicable requirement [401 KAR 52:020, Section 24(3)].
c. In an enforcement proceeding, the permittee seeking to establish the occurrence ofan emergency shall have the burden ofproof[401 KAR 52:020, Section 24(2)]. 8. Ozone Depleting Substances
a. The permittee shall comply with the standards for recycling and emissions reduction pursuant to 40 CFR 82, Subpali F, except as provided for Motor Vehicle Air Conditioners (MVACs) in Subpart B: (1) Personso"jjeJiing appliances for maintenance, service, repair, ordisj)osal shall comply with therequired practices contained in 40 CFR 82.156. (2) Equipment used during the maintenance, service, repair, or disposal of appliances shall comply with the standards for recycling and recovery equipment contained in 40 CFR 82.158. (3) Persons performing maintenance, service, repair, or disposal of appliances shall be certified by an approved technician certification programpursuantto 40 CFR 82.161. (4) Persons disposing of small appliances, MVACs, and MVAC-like appliances (as defined at 40 CFR 82.152) shall comply with therecordkeeping requirementsPermitNumber: V-05-088 R2 

### SECTION G - GENERAL PROVISIONS (CONTINUED) Page: 51 of52

pursuantto 40 CFR 82.166 (5) Persons owning commercial or industrial process refrigeration equipment shall complywith the leakrepairrequirements pursuant to 40 CFR 82.156. (6) Owners/operators ofappliances nonnally containing 50 ormore pounds ofrefrigerant shall keep records ofrefrigerant purchased and added to such appliances pursuant to 40 CFR 82.166. b. If the pennittee perfonns service on motor (fleet) vehicle air conditioners containing ozone-depleting substances, the source shall comply with all applicable requirements as specified in40 CFR 82, Subpart B, Servicing of Motor VehicleAir Conditioners. 9. Risk ManagementProvisions

a. The pennittee shall comply with all applicable requirements of401 KAR Chapter 68, Chemical Accident Prevention, which incorporates by reference 40 CFR Part 68, Risk Management Plan provisions. If required, the pennittee shall comply with the Risk Management Program and submit aRisk Management Planto: RMP Reporting Center P.O. Box 1515 Lanham-Seabrook, MD 20703-1515. b. Ifrequested, submit additional relevant infonnation to the Divisionorthe U.S. EPA.Permit Number: V-OS-088 

### SECTION H- ALTERNATE OPERATION SCENARIOS None 

### SECTION I- COMPLIANCE SCHEDULE

None Page: 52 of52