Commonwealth of Kentucky

Energy and Environment Cabinet

Department for Environmental Protection

Division for Air Quality

200 Fair Oaks Lane, 1

5t Floor

Frankfort, Kentucky 40601

(502) 564-3999

AIR QUALITY PERMIT

Issued under 401 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 Park drive W., suite 700

Owensboro, KY 42303-2191

(270) 687-7304

Henderson

December 7, 2005

April 3, 2007

October 4, 2010

April 3, 2012

TABLE CONTENTS

SECTION DATE OF ISSUANCE PAGE

A. PERMIT AUTHORIZATION 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 Permit issuance

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 of the 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 11-19-2009
Permit Number: V-05-088 R2

SECTION A - PERMIT AUTHORIZATION

Page: 1 of 52

BACT

CB

CO

Division

DC

HAP

NAAQS

NESHAP

NOx

PM

PM2.5

PM10

PMACT

Pursuant to a duly submitted application the Kentucky Division for Air Quality (Division)

hereby authorizes the operation of the equipment described herein in accordance with the terms

and conditions of this permit. This permit has been issued under the provisions of Kentucky

Revised Statutes (KRS) Chapter 224 and regulations promulgated pursuant thereto.

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 provided in this permit or in 401 KAR 52:020, Title V Permits.

Issuance of this permit does not relieve the permittee from the responsibility of obtaining any

other permits, licenses, or approvals required by the Kentucky Energy and Environment Cabinet

(Cabinet) or any other federal, state, or local agency.

Definitions: The following definitions apply to all abbreviations and variables used in this

permit:

- Best available control technology

- Carbon bake

- Carbon monoxide

- Kentucky Division for Air Quality

- Dust Co11ector

- Hazardous Air Pollutant

- National Ambient Air Quality Standards

- National Emissions Standards for Hazardous Air Pollutants

- Nitrogen Oxides

- Particulate Matter

- particulate matter equal to or smaller than 2.5 micrometers

- Particulate Matter equal to or smaller than 10 micrometers

- NESHAP for Primary Aluminum Reduction Plants, also referred to as

"PMACT' (40 CFR 63, Subpart LL)

PSD - Prevention of Significant Deterioration of air quality

S02 - Sulfur dioxide

TF - Total Fluoride

POM .- polycyclic organic matter

PMIO / PM25 - PMIO and PM25 standards are the same except as noted

PM / PMIO - PM and PMIO standards are the same except as noted
Permit Number: V-05-088 R2 Page: 20f52

SECTION B - AFFECTED FACILITIES, APPLICABLE REGULATIONS,

AND OPERATING CONDITIONS

SUBJECT ITEM 1 REQUIREMENTS: Existing Process Sources

Unit # Unit Name Material Rate Construction Date

(tons

Iyear)

AI (Tl-D) Barge Unloading Raw Material 585,562 August 4, 1972

total

B4 (S7, S8) Reacted Alumina Storage (2) Reacted Alumina 140,160 August 4, 1972

each

G8 (19) Ingot Casting Dross Loading Dross 5,820 August 4, 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 December 31, 1972

Material

K1 (P1(23)) Bath Crushing/Crucible Anode Cover 54,137 1972

Cleaning

U1 (5P) Bath Transfer to Storage Anode Cover 54,137 January 1, 1972

Processing

Q1 (EF) Electric Arc Furnace ( 1) Charge Materials 168 December 31, 1972

TPY

Backup

A8 (T4) Material Transfer Alumina/Coke 585,562 August 4, 1972

A2 (Sl, S2, Alumina Storage Alumina 417,064 August 4, 1972

S3) total

B6 (S4, S5) Ore Storage Unreacted 140,160 August 4, 1972 I Alumina each

C1 (T5) Material Transfer Rail Car Alumina, 193,970 August 4, 1972

""-

Fluoride, Coke "--

C2 (T6, 2S) Aluminum Fluoride A1F3 3,800 August 4, 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 Surge Tank Anode Butts 70,000 August 4, 1972

K7 (E6) Coke Crushing Petroleum Coke 193,970 December 31, 1972

L1 (E7) Coke Ball Mill Petroleum Coke 193,970 December 31, 1972

L3 (E8) Coke Fines Handling Petroleum Coke 193,970 December 31, 1972

U2 (Cl?) Green Anode Dust Collector Intermediate 17,000 December 31, 1972

Coke
Permit Number: V-05-088 R2 Page: 3 of 52

SECTION B - AFFECTED FACILITIES, APPLICABLE REGULATIONS,

AND OPERATING CONDITIONS (CONTINUED)

Unit # Unit Name Material Rate Construction Date

(tons

/year)

K5 (E5) Butt Impactor Anode Butts 70,000 December 31, 1972

J2 (E2) Anode Butt Cleaning Shot Blast 10,744 Aug 4, 1972

Material

* EmISSIOns from all umts controlled by baghouses.

APPLICABLE REGULATIONS:

401 KAR 61:020 Existing process operations is applicable to units which were constructed

before July 2, 1975

1. Operating Limitations:

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 be kept ofthe times when the units

are operating but the control devices are not. Records shall also be kept 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. PM Standards:

I. For emission units K1 and UI, particulate emissions shall not exceed a maximum exit

particulate emission concentration of 0.02 grains per standard cubic foot. Addition

of dilution air shall not constitute compliance.

Compliance Demonstration: Compliance with the limits described above shall be

determined by annual testing of the 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:

• For process weights < 0.5 tons/hour: 2.58 Ibs/hour

• For process weight < 30 tonslhour: E'PM, = 4.lOP/67

• For process weights? 30 tonslhour: E'PM, = (55.0p/I' )- 40
Permit Number: 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 average process weight for unit j (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 (%) of any air pollution control equipment associated with unit j.

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 monitor the following parameters:

a. Monthly total hours ofoperation.

b. Monthly total material processed (except for Kl and Ul).

c. Hourly pollutant emission rates.

d. Flow rate-based pollutant emission rates.

e. For each stack, vent or control system:

i. Monthly observations of visible emissions during operation of associated 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.
Permit Number: V-05-088 R2 Page: 50f52

SECTION B - AFFECTED FACILITIES, APPLICABLE REGULATIONS,

AND OPERATING CONDITIONS (CONTINUED)

iii. Annual Method 9 readings during operation of associated equipment.

5. Specific Recordkeeping Requirements: For each emission unit listed above, the permittee

shall maintain records ofthe following information:

a. Monthly total hours of operation.

b. Monthly total material processed.

c. Hourly pollutant emission rates.

d. Flow rate-based pollutant emission rates.

e. 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 if any visible emissions are seen.

ii. The cause ofthe abnormal visible emissions.

iii. Any corrective actions taken.

f. For each stack, vent or control 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

more than 6 times 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 of the semiannual report.

b. With the exception of specific 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 2 below.

8. Compliance Certification: See SECTION D 3 below.
Permit Number: V-OS-088 R2 Page: 60f52

SECTION B - AFFECTED FACILITIES, APPLICABLE REGULATIONS,

AND OPERATING CONDITIONS (CONTINUED)

SUBJECT ITEM 2 REOUIREMENTS: New Process Sources

Unit # Unit Name 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 December 31, 1990

Cleaning

B7 (S6) Ore Storage Unreacted 140,160 July 28, 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 Potliner Process 229 June 17, 1995

System Area

U4 (EQI) Anode Saw Dust Collector Anode 120,888 2004

U5 (EO 72, Pitch Storage Tanks Coal Tar 19,000 1977

73)

¥ EmISSIOns from all umts controlled by baghouse(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. Operating Limitations: See SECTION D 1 below.

a. The permittee shall not operate more than two eleCtric induction furnaces at one time.

[Synthetic Minor Limit]

b. The permittee shall not exceed a total annual induction furnace process rate of 9,360 tons

of cast iron production 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 of the times when the units are operating

but the control devices are not. Records shall also be kept ofthe maintenance activities.
Permit Number: V-05-088 R2 Page: 7 of 52

d. The associated control device(s) must achieve at least 99% actual overall control efficiency.

SECTION B - AFFECTED FACILITIES, APPLICABLE REGULATIONS,

AND OPERATING CONDITIONS (CONTINUED)

Compliance Demonstration: See Record Keeping Requirement below.

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. For process weights < 0.5 tons/hour: 2.34lbslhour

0.62

ii. For process weight < 30 tonslhour:

iii. For process weights :2: 30 tonslhour:

E'PM; = 3.59~

E'PM j = (17.3I~o16)

Where j is the unit, E'PMj is the allowable particulate emISSIOn rate for unit j

(poundslhour) and Pj is the average process weight for unit j (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:

EPM" = 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 (%) of any air pollution control equipment associated with unit j.

c. To preclude the applicability of PSD, 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, the permittee

shall perform annual Method 9 readings on each stack, vent or control device associated with

the units listed above.
Permit Number: 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 monitor the following parameters:

a. Monthly total hours of operation.

b. Monthly total material processed.

c. Hourly pollutant emission rates.

d. For each stack, vent or control system:

i. Monthly observations of visible emissions during operation of associated 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 9 readings during operation of associated equipment.

5. Specific Recordkeeping Requirements: For each emission unit listed above, the permittee

shall maintain records ofthe following information:

a. Monthly total hours of operation.

b. Monthly total material processed.

c. Hourly pollutant emission 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 if any 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

more than 6 times in a specified semi-annual reporting period (as defined in SECTION F

6. below), the permittee shall submit a corrective action plan to the Owensboro Regional
Permit Number: 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 of the semiannual report.

c. With the exception of specific 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 of compliance

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: See SECTION D 2 below.

8. Compliance Certification: See SECTION D 3 below.
Permit Number: V-05-088 R2 Page: 100f52

SECTION B - AFFECTED FACILITIES, APPLICABLE REGULATIONS,

AND OPERATING CONDITIONS (CONTINUED)

SUBJECT ITEM 3 REQUIREMENTS: Heat Exchangers

Unit # Unit Name Fuel Rate Construction Date

(MMBTU/hour)

S5 (EI) Indirect Heat Exchanger - Natnral 12.5 December 31, 1972

(Electrode Boiler) Gas

S6 (EI) Indirect Heat Exchanger Natnral 12.5 December 31, 1972

Gas

APPLICABLE REGULATIONS:

401 KAR 59:015 New indirect heat exchangers (on or after April 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. Opacity Standard:

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 of 40% 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: While burning natural gas, this unit is considered to be

in compliance with opacity standards.

b. PM Standards: Particulate emissions shall not exceed the following limits:

Unit # Unit Name P'hri

(Ibs/MMBTU)

S5 (EI) Indirect Heat Exchanger - (Electrode Boiler) 0.531

S6 (EI) Indirect Heat Exchanger 0.531

Compliance DemonstratIOn: While burnmg natural gas, thiS umt IS considered to be in

compliance particulate standards.

c. S02 Standards: Sulfur dioxide emissions shall not exceed the following limits:

Unit # Unit Name P'hri

(lbs/MMBTUl

S5 (EI) Indirect Heat Exchanger - (Electrode Boiler) 2.74
Permit Number: V-05-088 R2

S6 (EI) Indirect Heat Exchanger

Pa e: 11 of 52

2.74

SECTION B - AFFECTED FACILITIES, APPLICABLE REGULATIONS,

AND OPERATING CONDITIONS (CONTINUED)

Compliance Demonstration: While burning natural gas, this unit is considered to be in

compliance sulfur dioxide standards.

3. Testing Requirements: N/A

4. Specific Monitoring 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: See SECTION D 2 below.
Permit Number: V-05-088 R2 Page: 12 of 52

SECTION B - AFFECTED FACILITIES, APPLICABLE REGULATIONS,

AND OPERATING CONDITIONS (CONTINUED)

SUBJECT ITEM 4 REQUIREMENTS: Potlines (3)

Unit # Unit Name Control Construction Date

EI-2 Potline 1 Dry alumina August 1972

E3-2 Potline 2 scrubber/baghouse for August 1972

E5-2 Potline 3 reactors August 1979

Control Efficiency: 99%

EI-1 Potline 1 roof None - Vents to Atmosphere August 1972

monitor

E3-1 Potline 2 roof August 1972

monitor

E5-1 Potline 3 roof August 1979

monitor

APPLICABLE REGULATIONS:

401 KAR 51 :017 Prevention of significant deterioration of air quality (S02, CO, PMIO, PM2.5

and Fluorides)

401 KAR 61:165 Existing primary aluminum reduction plants (potlines I & 2)

40 CFR 63 Subpart LL Primary Aluminum Production NESHAP (potlines 1,2 and 3)

40 CFR 63 Subpart LL and 401 KAR 61:165 supersede the mass emissions standards

prescribed by 401 KAR 59:010 and 401 KAR 61:020 (see Section 2. Emission Limitations)

1. Operating Limitations:

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 determine the daily weight of aluminum 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 operating parameters, the following monitoring devices shall be installed:

(I) For dry alumina scrubbers, devices for the measurement of alumina flow and air flow
Permit Number: V-05-088 R2 Page: 13 of 52

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),

or if visible emissions indicating abnormal operation are observed from the exhaust stack

of a 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

hour or to take the necessary corrective actions to remedy the problem is a violation.

e. Pursuant to 401 KAR 61:165, Section 6(3), the permittee shall install, operate, and

maintain ambient air monitoring equipment for the detection of fluorides. This equipment

shall be located at sites specified by the Division ifrequested.

f. See SECTION D 1 below.

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. The petroleum coke used to make the green anodes shall not exceed 3.0 percent sulfur by

weight and the pitch shall not exceed 0.80 percent sulfur by weight as measured by the

standard ASTM method, an approved alternative method, or by vendor Certificate of

Analysis (per shipment basis).

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 of continuing practices 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. Pursuant to 40 CFR 63.845(h) and 401 KAR 61 :165, Section 3,10 % opacity from

any potroom roofmonitor during normal operations. (potlines 1,2 & 3)

ii. Pursuant to 40 I KAR 61: 165, 40 % opacity from any potroom roofmonitor located

directly above sick cells or startup cells. (Potlines I & 2 only)

iii. 10 % opacity from any dry scrubbing plant primary 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.
Permit Number: V-05-088 R2 Page: 140f52

[40 CFR 63.847(e)]

SECTION B - AFFECTED FACILITIES, APPLICABLE REGULATIONS,

AND OPERATING CONDITIONS (CONTINUED)

b. TF Standard: 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 produced if emission 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 of total fluorides

based on a monthly average (pounds/ton), C1 is 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 effluent gas as determined through the monthly

testing required 3. Testing Requirements below (milligrams/dry standard cubic foot), Q2

is roof monitor 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 production during month i (tons) and hi is the total monthly hours of operation

during month i (hours),

c. SOz emissions [(see Section D Item #3 BACT)].

d. Pursuant to 401 KAR 51 :017, CO emissions from the potlines are limited to 233.6Ibs/ton

(combined roofmonitors and control stack) of aluminum 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) of aluminum produced (BACT),

Compliance Demonstration:

See performance 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) of aluminum produced (BACT ).

Compliance Demonstration:

See performance testing 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:
Permit Number: V-05-088 R2 Page: 15 of 52

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 a minimum ofthree test runs are performed annually for the

primary control system for each source.

iii. Procedures to ensure that secondary emissions testing will occur according to the

frequency established below:

• At least one run performed before the 15th ofthe month,

• At least one run performed after the 15th ofthe month,

• There are at least six days between two ofthe runs during the month;

IV. Should the permittee wish, an alternate procedure where measured TF 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

production to the untested potlines.

b. Following approval of the site-specific test plan, the permittee shall conduct an initial

performance test during the first month following the compliance date.

c. If a performance test has been conducted on the plimary control system within the 12

months prior to the compliance date, the results of that performance test may be used to

determine initial compliance.

d. Following the initial performance test, the permittee shall submit to periodic testing as

prescribed in the site-specific test plan:

I. For each primary control system, the permittee shall perform at least three emission

test runs per year.

n. For each source ofsecondary emissions, the permittee shall perform at least three

emission test runs per month.

iii. Ifthe permittee has performed more than three tests of primary control system during

the previous 12 consecutive months, the average of all runs performed in the previous

12-month period shall be used to determine the contribution from the primary

emission control system.

e. The initial performance test and all subsequent performance tests shall be conducted in

accordance with the requirements of the general provisions in 40 CFR 63 Subparts A, the

procedures in 40 CFR 63 Subpart LL and the approved test plan.

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.
Permit Number: V-05-088 R2 Page: 16 of 52

SECTION B - AFFECTED FACILITIES, APPLICABLE REGULATIONS,

AND OPERATING CONDITIONS (CONTINUED)

h. For the production increase project authorized through permit V-05-088 R2, the permittee

shall conduct a performance test within 6 months of finishing the construction of potline

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. For the production increase project authorized through permit V-05-088 R2, the permittee

shall conduct a performance 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 of this permit. The first test shall be performed within 60 days of finishing the

construction ofpotline 3 (finishing of first potline modification pursuant to 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 the testing timeframes contained in Section G

(4)(e).

4. Specific Monitoring Requirements: For each emission unit listed above, the permittee

shall monitor the following parameters:

a. Continuous measurement of Alumina (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 of operation.

c. Pursuant to 40 CFR 63.847(e), monthly total aluminum production.

d. Pursuant to 40 CFR 63.847(e), production-based pollutant emission rates.

e. Pursuant to 40 CFR 63.848(k), weight measurement device calibrations.

f. Procedures for the proper operation and maintenance of monitoring device(s) or

system(s) used to determine compliance, including:

i. The permittee shall submit recommended accuracy requirements to the DAQ for

review and approval. [40 CFR 63.848 (k)]

ii. All monitoring devices must be certified by the permittee to meet the accuracy

requirements and must be calibrated in accordance with the manufacturer'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 by the Division).
Permit Number: V-05-088 R2

h. Secondary TF emissions (based on

schedule authorized by the Division).

Page: 17 of 52

monthly average of at least 3 runs or alternate

SECTION B - AFFECTED FACILITIES, APPLICABLE REGULATIONS,

AND OPERATING CONDITIONS (CONTINUED)

I. Pursuant to 401 KAR 61 :165, Section 6(3), ambient air monitoring results.

J. Pursuant to 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 or control system:

i. Daily observations of visible emissions during operation of associated equipment.

ii. Observations of visible emissions during all periods of control equipment

malfunction.

iii. Method 9 observation shall be performed if visible emissions are seen.

5. Specific Record keeping Requirements: The permittee shall maintain records ofthe

following information:

a. Pursuant to 40 CFR 63.847(e), monthly total hours of operation.

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

c. Pursuant to 40 CFR 63.847(e), production-based pollutant emission rates for TF.

d. Pursuant to 40 CFR 63.850(e), primary control system TF emission tests.

e. Pursuant to 40 CFR 63.850(e), secondary TF emission tests.

f. The portion of TF measured as particulate matter and the portion that is measured as

gaseous when the particulate and gaseous fractions are quantified separately using an

approved test method.

g. If emission averaging is used, the current implementation plan for emission averaging

and records supporting monitoring ofsimilar potlines and demonstrating that the

performance ofsimilar potlines is the same as or better than that of potlines sampled by

manual methods.

h. Pursuant to 40 CFR 63.850(e)(xiii), documentation of corrective actions taken when any

operating parameter limits are exceeded.

I. Pursuant to 40 I KAR 61: 165, Section 6, ambient air monitOling results for fluorides.
Permit Number: V-OS-088 R2 Page: 18 of 52

J. Pursuant to 40 CFR 63.850(e)(xi), for each dry scrubberlbaghouse control system:

i. Operating parameters.

SECTION B - AFFECTED FACILITIES, APPLICABLE REGULATIONS,

AND OPERATING CONDITIONS (CONTINUED)

ii. Daily visual inspections ofthe equipment.

iii. Daily visual qualitative visual observation of visible emissions from each control

device exhaust stack.

k. 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 if any visible emissions are seen.

ii. The cause ofthe 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 of standard work practices shall be kept on site and available for inspection.

n. Continuous measurement of Alumina (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 of the sulfur content of the petroleum coke and pitch used as raw

materials.

6. Specific Reporting Requirements:

a, The permittee shall submit to the Division:

i. Pursuant to 40 CFR 63.850(a), notification of initial performance test, initial

compliance status and compliance approach.

11. Pursuant to 401 KAR 50:045, the results of any stack test conducted at the source

within 45 days ofthe completion of any fieldwork associated with the test.

iii. Pursuant to 40 CFR 63.850(b), an annual summary of all performance tests.

b. Pursuant to 40 CFR 63.850(d), the permittee shall submit to 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 of each

quarter and containing the following information:

i. Periods and magnitudes of excess emissions.

ii. Nature and cause of each period of excess emissions.

iii. Periods during which the continuous monitoring system was inoperative.

iv. Records of calibration checks, adjustments, and maintenance performed on the

monitoring system.

v. Periods when no excess emissions have occurred.
Permit Number: V-OS-088 R2 Page: 19 of 52

SECTION B - AFFECTED FACILITIES, APPLICABLE REGULATIONS,

AND OPERATING CONDITIONS (CONTINUED)

c. Pursuant to 40 I KAR 61: 165, the pennittee shall submit to the Division quarterly

ambient monitoring data reports if required. If the 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 of detennining the number of exceedances, no more than one

exceedance shall be attributed in any given 24-hour period.

d. Pursuant to 40 CFR 63.848(i), if any 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

action plan to the Owensboro Regional Office for the Division's approval no later than 30

days from the due date of the semi-annual report.

e. Pursuant to 40 I KAR 50:055, with the exception of specific 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:

i. The pennittee shall always operate the dry alumina scrubbers and baghouses in

accordance with manufacturer's specifications (BACT limit).

ii. See SECTION D 2 below.

8. Compliance Certification: See SECTION D 3 below.
Permit Number: V-05-088 R2 Page: 20 of 52

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) Anode Mix Conveying 127,020 December 12, 1972

M3 (2E) Anode Mix 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 August 4, 1972

M6 (9E,EA)L, j Anode Mixers (2) 36,291 July 28, 1977

M7 (5E,4E)"' j Anode Mixers (2) 36,291 August 4,1972

Emissions from Process units M2 thru M7 are controlled by a baghouse and dry coke scrubber

(Unit # EN); ?r oC ,0 C{ ; r () to ,'-t2 Units M5, M6, and M7 include a common pitch scale not listed as a separate unit

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 KAR 59:010 New Process Operations for Unit M4 and M6

40 CFR 63 Subpart LL Primary Aluminum Production NESHAP

1. Qperating Limitations:

a. Pursuant to 40 CFR 63.843, the permittee shall install a coke scrubber with closed vent

transport system to control polycyclic organic matter (POM) emissions.

b. The permittee shall specify and provide the basis or rationale for selecting parameters to be

monitored and the associated operating limits for the emission control device.

c. If a monitoring device for a primary control device measures an operating parameter

outside the limits established pursuant to 40 CFR 63.847 (h) or if visible emissions

indicating abnormal operation are observed from the exhaust stacIe-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 a violation.

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 units
4.IOpo67 ,

(55.0?,O!!)- 40

Permit Number: V-05-088 R2 Page: 21 of 52

are operating but 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. Opacity Standard: Visible emissions shall not exceed the following limitations:

i. For equipment constructed on or afterJuly 2, 1975: 20 % opacity. 'Pro' 0 1c< ; rii. For equipment 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. PM Standards: Hourly particulate emissions shall not exceed the following limits:

i. For equipment constructed before July 2, 1975:

• For process weight < 30 tonslhour: E'PM, =

• For process weights 2: 30 tonslhour: E' PM, =

II. For equipment constructed on or after July 2,1975:

F . h 30 Ih E' 3.59po.62 • or process welg t < tons our: PM, = ,

F 'gh 30 Ih E' 17.3Ipo.!6 • or process 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 .EFpM, .(1- eEj 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 CEj is the overall

control efficiency (%) of any air pollution control equipment associated with unit j.

3. Testing Requirements:

a, Pursuant to 40 CFR 63 Subpart LL, initial compliance shall be demonstrated through site

inspections and review ofsite records by the 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: The permittee shall monitor the following parameters:

a. Monthly total hours of operation.
Permit Number: V-05-088 R2 Page: 22 of 52

SECTION B - AFFECTED FACILITIES, APPLICABLE REGULATIONS,

AND OPERATING CONDITIONS (CONTINUED)

b. Monthly total material processed.

c. Hourly pollutant emission rates.

d. Continuous coke and air flow rates.

e. For each 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.

f. For each stack, vent or control system:

i. Daily observations of visible emissions during operation of associated equipment.

ii. Observations of visible emissions during all periods of control equipment

malfunction.

iii. Annual Method 9 readings during operation of associated equipment.

5. Specific Record keeping Requirements: The permittee shall maintain records of the

following information:

a. Monthly total hours of operation

b. Monthly total material processed.

c. Hourly pollutant emission rates.

d. Design information for the 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. Operating parameters.

ii. Daily visual 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 if any visible emissions are seen.
Permit Number: V-05-088 R2

ii. The cause ofthe abnonnal visible emissions.

Page: 23 of 52

SECTION B - AFFECTED FACILITIES, APPLICABLE REGULATIONS,

AND OPERATING CONDITIONS (CONTINUED)

iii. Any corrective actions taken.

i. For each stack, vent or control system, records of the annual Method 9 readings.

J. Current startup, shutdown and malfunction (SS&M) plan.

? s (0.+ f.,o<nJ~ 6. Specific Reporting Requirements: . (,I)/< (T--

a. The pennittee shall submit to the Division notification of initial 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 containing the following infonnation:

i. Periods and magnitudes of excess emissions.

ii. Nature and cause of each period of excess 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. If the 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 of detennining the

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

hour period.

e. If any 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 action plan to the Owensboro Regional

Office for the Division's approval no later than 30 days from the due date of the semiannual report.

f. With the exception of specific 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.
Permit Number: V-OS-088 R2 Page: 24 of 52

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: A Handbook ofRecommended Practice" are met.

c. See SECTION D 2 below.

8. Compliance Certification: See SECTION D 3 below.
Permit Number: V-05-088 R2 Page: 25 of 52

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 year baked anodes.

Fuel Usage: 430 mm scfper year natural gas usage.

Control equipment: Dry Scrubber/Baghouse System

Construction date: August 4, 1972

APPLICABLE REGULATIONS:

401 KAR 51:017 Prevention of Significant Deterioration of Air 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

if visible 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 a violation.

e. See SECTION D 1 below.

f. The dry scrubberlbaghouse system shall be operated when the anode bake furnace is in

operation.
Permit Number: V-OS-088 R2 Page: 26 of 52

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 of baked anode production and thus, CO emissions.

(401 KAR 51 :017; BACT Work 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

average process weight (tons/hour).

Compliance Demonstration: Compliance with the hourly particulate emission limit

described above shall be determined by comparing the allowable rate to the actual

rate as calculated below:

EpM, = P, ·EFpM .(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 of operation during month i (hours/month)

and CE is the overall control efficiency (%) of the dry scrubber/baghouse system.

11. To preclude the requirements of 401 KAR 51:017 (V-05-0SS Rl permit action), the

permittee shall not allow PM/PMlO 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 #3
Permit Number: V-05-088 R2 Page: 27 of 52

SECTION B - AFFECTED FACILITIES, APPLICABLE REGULATIONS,

AND OPERATING CONDITIONS (CONTINUED)

d. TF& POM Standards:

Pursuant to §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 by comparing the allowable rate to the actual rate as calculated below:

E = (Cx·Q) p=~ X p

(453600·p;) 'h,

Where X is the pollutant (TF or POM), Ex? is the actual production-based emission

rate of pollutant X based on a monthly average (pounds/ton), Cx is the average total

concentration of pollutant X system effluent gas (milligrams/dry standard cubic toot),

Q system effluent gas flow rate (dry standard cubic feet/hour), h is the actual monthly

hours of operation (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 the total 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 a minimum ofthree test runs are performed annually for the

primary control system.

111. Procedures for establishing the frequency oftesting.

b. Following the initial performance test, the permittee shall submit to periodic testing of TF

and POM as prescribed in the site-specific test plan:

i. For each primary control system, the permittee shall perfonn at least three emission

test runs per year.

11. Ifthe permittee has performed more than three tests of primary control system during

the previous 12 consecutive months, the average of all runs performed in the previous

12-month period shall be used to determine the contribution from the primary

emission control system.

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 in 40 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

compliance with the applicable emission limits for TF.
Permit Number: V-05-088 R2 Page: 28 of 52

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 of green anode and baked anode shall be tested monthly for sulfur content. A

sample of packing coke shall be tested quarterly for sulfur content.

g. Following the completion ofthe refurbishment project authorized through Permit V-05-

088 Revision I, the pennittee shall perfonn a perfonnance test annually within 3 months

ofthe anniversary ofthe pennit using EPA Reference Method 10 to quantify CO

emissions from each operating reactor stack ofthe dry scrubberlbaghouse system. (The

anniversary ofthe pennit is the day ofthe month when pennit V-05-088 was issued.)

h. The pennittee shall perform a perfonnance test for PM/PMIO within one year of

completing Phase I ofthe refurbishment project authorized through Pennit V-05-088

Revision I (i.e., the refurbishment of 18 sections of261 W) to quantify PM/PM IO

emissions from each operating reactor stack ofthe dry scrubberlbaghouse system and to

show compliance with the emission limit of 5.14 lblhr. Subsequent perfonnance testing

for PM/PMIO shall be completed once per pennit tenn. EPA Reference Method 5 shall be

used during the initial demonstration of compliance and subsequent tests to quantify

PM/PM10 emissions from each operating reactor stack ofthe dry scrubber/baghouse

system.

4. Specific Monitoring Requirements: The pennittee shall monitor the following parameters:

a. Monthly total hours of operation.

b. Monthly total material processed.

c. Production-based pollutant emission rates for TF and POM.

d. Primary control system TF emissions (based on annual average of at least 3 runs, all valid

runs must be included in average).

e. Primary control system POM emissions (based on annual average of at least 3 runs, all

valid runs must be included in average).

f. Procedures for the proper operation and maintenance ofmonitoring device(s) or

system(s) used to detennine compliance, including:

i. The pennittee shall submit recommended accuracy requirements to the DAQ for

review and approval. [40 CFR 63.848 (k)]
Permit Number: V-05-088 R2 Page: 29 of 52

SECTION B - AFFECTED FACILITIES, APPLICABLE REGULATIONS,

AND OPERATING CONDITIONS (CONTINUED)

ii. All monitoring devices must be certified by the pennittee to meet the accuracy

requirements and must be calibrated in accordance with the manufacturer's

instructions. [40 CFR 63.848 (k)]

g. For each control system:

i. Daily visual inspections ofthe equipment.

ii. Daily visual inspections of each control device exhaust stack for evidence of

abnonnal operation.

h. For each stack, vent or control system:

i. Daily observations of visible emissions during operation of associated equipment.

ii. Observations of visible emissions during all periods of control equipment

malfunction.

iii. If visible emissions are seen, a Method 9 shall be perfonned to read the opacity.

5. Specific Record keeping Requirements: The pennittee shall maintain records of the

following infonnation:

a. Monthly total hours of operation

b. Monthly total material processed.

c. Production-based pollutant emission rates for TF and POM.

d. Results of all TF and POM emission tests. If an 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. If emission averaging is selected as the method used to demonstrate compliance with the

emissions ofTF or POM emissions, a copy ofthe current implementation plan shall be

maintained.

f. Documentation ofcorrective actions taken when any operating parameter-limits are

exceeded.

g. For the dry scrubber/baghouse control system:

i. Daily visual inspections ofthe equipment.

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.

ii. The cause ofthe abnonnal visible emissions.

iii. Any corrective actions taken.
Permit Number: V-OS-088 R2 Page: 30 of 52

SECTION B - AFFECTED FACILITIES, APPLICABLE REGULATIONS,

AND OPERATING CONDITIONS (CONTINUED)

1. Current startup, shutdown and malfunction (SS&M) plan.

J. Sulfur content measurements of green anodes, baked anodes, and packing coke used in

quantifying 802 emissions using the Alcan 802 Calculation Engine.

6. Specific Reporting Requirements:

a. The permittee shall submit to the Division:

i. Notification ofinitial performance test, initial compliance status and compliance

approach.

ii. The results of any stack test conducted at the source within 45 days ofthe

completion of any fieldwork associated with the test.

iii. An annual summary of all performance tests.

b. The permittee shall submit for the Division's approval a plan to ensure that each piece of

associated control equipment is properly operated and maintained. The plan shall include

the following information:

i. The operating parameters to be monitored.

ii. Acceptable ranges or limits for each operating parameter.

iii. The monitoring frequency for each parameter.

iv. The criteria used to select each parameter, range, limit and frequency including how

each ofthese relates to emission control.

v. The recommended accuracy requirements for each monitoring device.

c. The permittee shall submit to the Division quarterly excess emission reports (EER,

excess emissions shall be defined as any measured emission rate in excess ofthe

limitations specified herein) postmarked by the thirtieth (30th) day following the end of

each quarter and containing the following information:

i. Periods and magnitudes of excess emissions.

ii. Nature and cause of each period of excess emissions.

iii. Periods during which the continuous monitoring system was inoperative.

iv. Records of calibration checks, adjustments, and maintenance performed on the

monitoring system.

v. Periods when no excess emissions have occurred.

d. If the 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 of determining the

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

hour period.
Permit Number: V-05-088 R2 Page: 31 of 52

e. If any 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 permittee shall submit a corrective action plan 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 of the semiannual report.

f. With the exception of specific 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 scrubber and baghouse system shall be operated and maintained according to

manufacturer's specifications.

b. See SECTION D 2 below.
Permit Number: V-05-088 R2 Page: 32 of 52

SECTION B - AFFECTED FACILITIES, APPLICABLE REGULATIONS,

AND OPERATING CONDITIONS (CONTINUED)

SUBJECT ITEM 7 REQUIREMENTS: Holding Furnaces

Unit # Unit Name Control Construction Date

F1 (11-16) Holding Furnaces (6) with In-Line Degassers None August 4, 1972

F2 (17, 18) Holding Furnaces (2) with In-Line Degassers None August 4, 1979

APPLICABLE REGULATIONS:

401 KAR 59:010 New process operations for unit F2

401 KAR 61 :020 Existing process operations for unit Fl

40 CFR 63 Subpart RRR Secondary aluminum production NESHAP

1. Operating Limitations:

a. The pennittee shall use only clean charge.

b. The permittee shall maintain a reactive flux injection rate at or below rate used during the

perfonnance test for each operating cycle or time 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

least once 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 of compliance.

e. See SECTION D 1 below.

2. Emission Limitations:

a. Opacity Standard: Visible emissions shall not exceed the following limitations:

i. For equipment constructed on or after July 2, 1975: 20 % opacity.

--ii. For equipment constructed before July 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 ,

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

b. PM Standards: Particulate emissions shall not exceed the following limits:

i. For equipment constructed before July 2, 1975:

• For process weight < 30 tons/hour: E'PM, =
Permit Number: V-05-088 R2 Page: 33 of 52

SECTION B - AFFECTED FACILITIES, APPLICABLE REGULATIONS,

AND OPERATING CONDITIONS (CONTINUED)

ii. For equipment constructed on or after July 2,1975:

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

• For process weights :2: 30 tonslhour: E'PM, = 17.31p,°·16

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:

= Pij' EFpMi .(1- CEj )

EpM, 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 (%) of any air pollution control equipment associated with unit j.

c. Pursuant to 40 CFR 63 Subpart RRR, emissions from any Group 1 Furnace shall not

exceed the following limits:

i. Particulate emissions shall not exceed 0.4 lb/ton of feed.

ii. Hydrochloric acid (HCI) emissions shall not exceed O.4lb/ton offeed.

d. Pursuant to 40 CFR 63 Subpart RRR, emissions from any In-Line Fluxer shall 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. Pursuant to 40 CFR 63 Subpart RRR, 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 of a Secondary Aluminum Processing Unit (SAPU).

i. If each existing Group I Furnace and In-Line Fluxer is in compliance with individual

emission limits, then the SAPU shall be considered to be in compliance and the threeday rolling calculation shall not be required.

Compliance Demonstration: Compliance with the limits described in 2.c. and 2.d.

above shall be determined by comparing the allowable rate to the actual rate as

calculated below:

E E =----r..

Xp P

Where X is the pollutant, Exp is production-based emission rate of each limited

pollutant (pounds/ton aluminum charged), Ex is the actual hourly emission rate of

pollutant X as determined during a performance test (pounds/hour) and P is the actual

total aluminum charged during the performance test (tonslhour).
Permit Number: V-OS-088 R2 Page: 34 of 52

SECTION B - AFFECTED FACILITIES, APPLICABLE REGULATIONS,

AND OPERATING CONDITIONS (CONTINUED)

11. Ifthe source cannot or chooses not to demonstrate compliance with the individual

limits, the permittee shall maintain a 3-day rolling average ofthe SAPU emission

limits.

iii. SAPU emission limits for each pollutant shall be determined by applying the

following equation:

n

"Ex .p J IJ

j=l =

n

I (L Xj ·P)

)=1

E~ n

I (Pj )

jol

Where j is the unit, n is the total number ofunits in the SAPU, X is the specific

pollutant, E'x is the allowable SAPU emissions for pollutant X (pounds/ton material

charged), LXj is the emission limit for pollutant X specific to unit j (pounds/tons

material charged), and Pj is the operating rate for unit j (tons material charged/hour).

Compliance Demonstration: The 3-day rolling 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 number of units in SAPU, X is the

pollutant, Ex is the 3-day rolling average emissions of pollutant 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 of pollutant X from

emission unit j as determined in the performance test (pounds/ton ofmaterial

processed), and Pij is the total amount ofmaterial processed in unit j 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 per 40 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: The permittee shall monitor the following parameters:
Permit Number: V-05-088 R2

a. Monthly total hours ofoperation.

Page: 35 of 52

SECTION B - AFFECTED FACILITIES, APPLICABLE REGULATIONS,

AND OPERATING CONDITIONS (CONTINUED)

b. Monthly total aluminum production.

c. Hourly pollutant emission rates.

d. Production-based pollutant emission rates.

e. For each operating cycle or time period used in the performance test, the following

parameters:

i. Total fluxing hours per operating cycle.

ii. Total HCI added by weight per operating cycle.

iii. Hourly fluxing rate (based on operating cycle average).

iv. Other parameters needed to perform alternative flux injection rate determination as

described in 40 CFR 63 Subpart RRR section 63.1510G)(5).

f. Weight measurement device calibrations.

g. Monthly inspections of equipment labels.

h. For each stack, vent or control system:

i. Monthly observations of visible emissions during operation of associated equipment.

ii. Observations of visible emissions during all periods of control equipment

malfunction.? No Neiii. Annual Method 9 readings during operation of associated equipment.

5. Specific Record keeping Requirements: The permittee shall maintain records of the

following information:

a. Monthly total hours of operation.

b. Monthly total aluminum production.

c. Hourly pollutant emission rates.

d. Production-based pollutant emission rates.

e. Parameters for determining fluxing rate.

f. Weight measurement device calibrations.

g. Monthly inspections of equipment labels.

h. For each stack, vent or control system, a log of all visible emission observations. If

visible emissions are observed, the log shall indicate:
Permit Number: V-05-088 R2

i. Method 9 readings if any visible emissions are seen.

Page: 36 of 52

SECTION B - AFFECTED FACILITIES, APPLICABLE REGULATIONS,

AND OPERATING CONDITIONS (CONTINUED)

ii. The cause ofthe abnormal visible emissions.

iii. Any corrective actions taken.

1. For each stack, vent or control 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 of specific 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 in the furnaces. '""D",,v-<- ~N -(.vL &MA<..' «-V:>"I f-$.

b. See SECTION D 3 below.
Permit Number: 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

Construction date: 1972

APPLICABLE REGULATIONS:

401 KAR 63:010 Fugitive emissions

1. Operating Limitations: None

2. Emission Limitations:

a. The pennittee shall not cause or penni! the discharge of visible fugitive dust emissions

beyond the lot line ofthe property on which the emissions originate

b. The pennittee shall take reasonable precautions to prevent particulate matter from

becoming airborne. Such reasonable precautions shall include, when applicable, but not

be limited to the following:

i. Application and maintenance of asphalt, water, or suitable chemicals on roads,

material stockpiles, and other surfaces that are sources of airborne dusts.

n. The use ofwater sprays or other measures to suppress the dust emissions during

handling.

3. Testing Requirements: None

4. Specific Monitoring Requirements: The permittee shall monitor the 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 Reporting Requirements: See SECTION F below.

7. Specific Control Equipment Conditions: None

8. Compliance Certification: See SECTION D 3 below.
Permit Number: V-05-088 R2 Page: 38 of 52

SECTION B - AFFECTED FACILITIES, APPLICABLE REGULATIONS,

AND OPERATING CONDITIONS (CONTINUED)

SUBJECT ITEM 9 REQUIREMENTS: Natural Gas Usage

Unit # Unit Name 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 December 29,2000

APPLICABLE REGULATIONS:

401KAR 59:010: 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

particulate matter limit, while burning natural gas.

3. Testing Requirements: None

4. Specific Monitoring Requirements: The permittee shall monitor source-wide natural gas

usage on a monthly basis.

5. Specific Record keeping Requirements: The permittee shall maintain records of monthly

source-wide natural gas usage.

6. Specific Reporting Requirements: None

7. Specific Control Equipment Conditions: None

8. Compliance Certification: See SECTION D 3 below.
Permit Number: V-OS-088 Rl

SECTION C - INSIGNIFICANT ACTIVITIES

Page: 39 of 52

The following listed activities have been detennined to be insignificant activities for this source

pursuant to 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 subject to an opacity standard shall be inspected monthly

and a qualitative visible emissions evaluation made. Results of the inspection, evaluation, and

any corrective action shall be recorded in a log.

Description

I. Emergency Generator (Natural gas) (Unit# RW-RCW-26-

EMG)- 230kW

2. Anode cover storage T34 (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 vaporizer boiler

10. Gasoline storage fuel tank vent

II. Diesel storage fuel tank vent

12. Small form control oven (Natural Gas)

13. A446 Day Tank 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 59:010
Permit Number: V-05-088 Rl Page: 40 of 52

SECTION D - SOURCE EMISSION LIMITATIONS AND TESTING

REQUIREMENTS

As required by Section Ib ofthe Cabinet Provisions and Procedures for Issuing Title V Permits

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) consecutive months.

1. The permittee shall follow the requirements described in the preventative maintenance

plan for all units. Excursion from the requirements of the preventative maintenance plan

shall be corrected in a timely manner per 401 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 of pollution 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 of primary 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 of the form can be found in the

Kentucky Division for Air Quality tracking system "TEMPO"); and calculating a rolling

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)).
Permit Number: V-05-088 R2 Page: 41 of 52

SECTION E - SOURCE CONTROL EQUIPMENT REQUIREMENTS

Pursuant to 401 KAR 50:055, Section 2(5), at all times, including periods of startup, shutdown

and malfunction, owners and operators shall, to the extent practicable, maintain and operate any

affected facility including associated air pollution control equipment in a manner 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 maintenance procedures, and inspection ofthe source.
Permit Number: V-05-088 R2 Page: 42 of 52

SECTION F - MONITORING, RECORD KEEPING, AND REPORTING

REQUIREMENTS

I. Pursuant to Section Ib (IV) I of the Cabinet Provisions and Procedures for Issuing Title V

Permits incorporated by reference in 40 I KAR 52:020, Section 26, when continuing

compliance is demonstrated by periodic testing or instrumental monitoring, the permittee

shall compile records ofrequired monitoring information that include:

a. Date, place as defined in this permit, and time ofsampling or measurements;

b. Analyses performance dates;

c. Company or entity that performed analyses;

d. Analytical techniques or methods used;

e. Analyses results; and

f. Operating conditions during time ofsampling or measurement.

2. Records of all required monitoring data and support information, including calibrations,

maintenance records, and original strip chart recordings, and copies of all reports required by

the Division for Air Quality, shall be retained by the permittee for a period of five (5) years

and shall be made available for inspection upon request by any duly authorized

representative of the Division for Air Quality [Sections Ib(IV) 2 and Ia(8) of the 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 of 40 I KAR 52:020 Section 3(1)h the permittee shall

allow authorized representatives of the Cabinet to perform the following during reasonable

times:

a. Enter upon the premises to inspect any facility, equipment (including air pollution control

equipment), practice, or operation;

b. To access and copy any records required by the permit:

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 of operation, 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 of carrying out official duties. Refusal of entry or access

may constitute grounds for permit rcvocation and assessment of civil penalties.

5. Summary reports of any monitoring required by this permit, other than continuous emission

or opacity monitors shall be submitted to the Regional Office listed on the front ofthis permit

at least every six (6) months during the life of this permit, unless otherwise stated in this

permit. For emission units that were still under construction or which had not commenced

operation at the end of the 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

the previous six months because the emission unit was not in operation [Section Ib (V )I ofthe

Cabinet Provisions and Procedures for Issuing Title V Permits incorporated by reference
Permit Number: V-OS-088 R2 Page: 43 of 52

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 of each year. Data from the

continuous emission and opacity monitors shall be reported to the Technical Services Branch

in accordance with the requirements of 401 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 permit requirements shall be clearly identified in the reports.

7. In accordance with the provisions of 401 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, if the 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 of the standards, notification shall be made as promptly as possible by

telephone (or other electronic media) and shall submit written notice upon request.

8. The permittee shall report emission related exceedances from permit requirements including

those attributed to upset conditions (other than 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 Issuing Title 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 of this permit and the U.S. EPA in

accordance with the following requirements:

a. Identification ofthe term or condition;

b. Compliance status of each term or condition ofthe permit;

c. Whether compliance was continuous orintermittent;

d. The method used for determining the compliance status for the source, currently and over

the reporting period.

e. For an emissions unit that was still under construction or which has not commenced

operation at the end ofthe 12-month period covered by the annual compliance certification,

the permittee shall indicate that the unit is under construction and that compliance with any

applicable requirements will be demonstrated within the timeframes specified in the permit.
Permit Number: V-05-088 R2 Page: 44 of 52

SECTION F - MONITORING, RECORD KEEPING, AND REPORTING

REQUIREMENTS (CONTINUED)

f. The certification shall be postmarked by January 30th of each year. Annual compliance

certifications should be mailed to the following addresses:

Division for Air Quality

Owensboro Regional Office

3032 Alvey Park Drive W., Suite 700

Owensboro, KY 42303-7304

U.S. EPA Region IV

Air Enforcement Branch

Atlanta Federal 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 of the date

the Kentucky Emissions Inventory System (KYEIS) emissions survey is mailed to the

permittee.
Permit Number: V-05-088 R2

SECTION G - GENERAL PROVISIONS

1. General Compliance Requirements

Page: 45 of 52

a. The permittee shall comply with all conditions of this permit. Noncompliance shall be a

violation of401 KAR 52:020, Section 3(l)(b), and a violation of Federal 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 ofa permit [Section la-3 ofthe Cabinet Provisions and Proceduresfor

Issuing Title V Permits incorporated by reference in 401 KAR 52:020, Section 26].

b. The filing of a request by the permittee for any permit revision, revocation, reissuance, or

termination, or of a notification of a planned change or anticipated noncompliance, shall

not stay any permit condition [Section la-6 oftbe Cabinet Provisions and Proceduresfor

Issuing Title V Permits incorporated by reference 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 under the 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, the reopening shall be

completed no later than eighteen (18) months after promulgation of the applicable

requirement. A reopening shall not be required if compliance with the applicable

requirement is not required until after the date on which the permit is due to expire,

unless this permit or any of its 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 subject to 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 of the permit for which cause to

reopen exists. Reopenings shall be made as expeditiously as practicable. Reopenings

shall not be initiated before a notice of intent to reopen is provided to the source by the

Division, at least thirty (30) days in advance of the date the permit is to be reopened,

except that the Division may provide a shorter time period in the case of an emergency.

d. The permittee shall furnish information upon request of the Cabinet to determine if cause

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 and Procedures for Issuing Title V Permits incorporated by reference in 401

KAR 52:020, Section 26].
Permit Number: V-05-088 R2

SECTION G - GENERAL PROVISIONS (CONTINUED)

Page: 46 of 52

e. Emission units described in this pennit shall demonstrate compliance with applicable

requirements ifrequested by the Division [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 or portion ofthis pennit which becomes suspended or is ruled invalid as a

result of any legal or other action shall not invalidate any other portion or condition of

this pennit [Section 1a-14 of the Cabinet Provisions and Procedures for Issuing Title V

Permits incorporated by reference 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 of the Cabinet Provisions and Procedures for Issuing Title V

Permits incorporated by reference in 401 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

Procedures for Issuing Title V Permits incorporated by reference in 401 KAR 52:020,

Section 26].

J. This pennit shall be subject to suspension if the 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-I 0 of the Cabinet Provisions and Procedures for Issuing Title V Permits

incorporated by reference in 401 KAR 52:020, Section 26].

k. Nothing in this pennit shall alter or affect the liability of the permittee for any violation

of applicable requirements prior to or at the time of pennit issuance [40 I KAR 52:020,

Section II (3) 2.].

1. This permit does not convey property rights or exclusive privileges [S'ection la-9 of the

Cabinet Provisions and Procedures for Issuing Title V Permits incorporated by reference

in 401 KAR 52:020, Section 26].

m. Issuance of this permit does not relieve the permittee from the responsibility of obtaining

any other permits, licenses, or approvals required by the Cabinet or any other federal,

state, or local agency.

n. Nothing in this pennit shall alter or affect the authority of U.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 of 52

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 of any previously issued PSD, NSR, or Synthetic

Minor source preconstruction permit terms and conditions for various emission units and

incorporates all requirements of those 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. Permit Expiration and Reapplication Requirements

a. This permit shall remain in effect for a fixed term of five (5) years following the original

date of issue. 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 of this permit,

including any permit shield, shall remain in effect beyond the expiration date, until the

renewal permit is issued or denied by the 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. Permit Revisions

a. A minor permit revision procedure may be used for permit revisions involving the use of

economic incentive, marketable permit, emission trading, and other similar approaches,

to the extent that these minor permit revision procedures are explicitly provided for in the

State Implementation Plan (SIP) or in applicable requirements and meet the relevant

requirements of 401 KAR 52:020, Section 14(2).

b. This permit is not transferable by the permittee. Future owners and operators shall obtain

a new permit from the Division for Air Quality. The new permit may be processed as an

administrative amendment if no other change in this permit is necessary, and provided

that a written agreement containing a specific date for transfer of permit responsibility
Permit Number: V-OS-088 R2

SECTION G - GENERAL PROVISIONS (CONTINUED)

Page: 48 of 52

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 of the 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 of this

permit.

b. Within thirty (30) days following commencement of construction and within fifteen (15)

days following start-up and attainment of the maximum production rate specified in the

permit application, or within fifteen (15) days following the issuance date of this 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 in this 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, or begins but is discontinued for a period

of eighteen (18) months or is not completed within a reasonable timeframe then the

construction and operating authority granted by this permit for those affected facilities for

which constmction was not completed shall immediately become invalid. Upon written

request, the Cabinet may 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. If compliance is

not demonstrated within the prescribed timeframe provided in 401 KAR 50:055, the

source shall operate thereafter only for the purpose of demonstrating compliance, unless

otherwise authorized by Section I ofthis permit or order ofthe Cabinet.

e. This permit shall allow time for the initial start-up, operation, and compliance

demonstration of the 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 after initial start-up ofsuch facilities, the permittee
Permit Number: V-05-088 R2

SECTION G - GENERAL PROVISIONS (CONTINUED)

Page: 49 of 52

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 of sixty

(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 least thirty (30) days prior to 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 of the source's operations and

create the highest rate of emissions. If [When] the maximum production rate represents a

source's highest emissions rate and a performance test is conducted at less than the

maximum production rate, a source shall be limited to a production rate of no greater than

110 percent of the average production rate during the performance tests. If and when the

facility is capable of operation 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 if the source demonstrates

to the Division's satisfaction that the source is in compliance with all applicable

requirements.

c. Results of performance 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. If an applicable requirement of Federal 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 of the Act), both provisions shall

apply, and both shall be state and federally enforceable.

b. The permittee shall comply with all applicable requirements and conditions of the Acid

Rain Permit and the Phase II permit application (including the Phase II NOx compliance

plan and averaging plan, if applicable) incorporated into the Title V permit issued for this
Permit Number: V-OS-088 R2

SECTION G - GENERAL PROVISIONS (CONTINUED)

Page: 50 of 52

source. The source shall also comply with all requirements of any revised or future acid

rain permit(s) issued to this source.

7. Emergency Provisions

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

operating logs or relevant evidence that:

(1) An emergency occurred and the permittee can identifY the cause ofthe emergency;

(2) The permitted facility was at the time being properly 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 of the emergency, steps taken to

mitigate emissions, and corrective actions taken.

(5) This requirement does not relieve the source of other local, state or federal

notification requirements.

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 of an

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 the required 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 program pursuant to 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 the recordkeeping requirements
Permit Number: V-05-088 R2

SECTION G - GENERAL PROVISIONS (CONTINUED)

Page: 51 of 52

pursuant to 40 CFR 82.166

(5) Persons owning commercial or industrial process refrigeration equipment shall

comply with the leak repair requirements pursuant to 40 CFR 82.156.

(6) Owners/operators of appliances nonnally containing 50 or more pounds ofrefrigerant

shall keep records of refrigerant 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 in 40 CFR 82, Subpart B, Servicing ofMotor Vehicle Air Conditioners.

9. Risk Management Provisions

a. The pennittee shall comply with all applicable requirements of 401 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 a Risk Management Plan to:

RMP Reporting Center

P.O. Box 1515

Lanham-Seabrook, MD 20703-1515.

b. Ifrequested, submit additional relevant infonnation to the Division or the U.S. EPA.
Permit Number: V-OS-088

SECTION H - ALTERNATE OPERATION SCENARIOS

None

SECTION I - COMPLIANCE SCHEDULE

None

Page: 52 of 52