Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 2 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

TABLE OF CONTENTS 

A SOURCE SUMMARY 

A.1 General Information [326 IAC 2-7-4(c)] [326 IAC 2-7-5(15)] [326 IAC 

2-7-1(22)] 

A.2 Part 70 Source Definition [326 IAC 2-7-1(22)] 

A.3 Emission Units and Pollution Control Equipment Summary [326 IAC 2-7-

4(c)(3)] 

[326 IAC 2-7-5(15)] 

A.4 Specifically Regulated Insignificant Activities [326 IAC 2-7-1(21)] 

[326 IAC 2-7-4(c)] 

[326 IAC 2-7-5(15)] 

A.5 Part 70 Permit Applicability [326 IAC 2-7-2] 

B GENERAL CONDITIONS 

B.1 Definitions [326 IAC 2-7-1] 

B.2 Permit Term [326 IAC 2-7-5(2)] [326 IAC 2-1.1-9.5] [326 IAC 2-7-

4(a)(1)(D)] [13-15-3-6(a)] 

B.3 Term of Conditions [326 IAC 2-1.1-9.5] 

B.4 Enforceability [326 IAC 2-7-7] 

B.5 Severability [326 IAC 2-7-5(5)] 

B.6 Property Rights or Exclusive Privilege [326 IAC 2-7-5(6)(D)] 

B.7 Duty to Provide Information [326 IAC 2-7-5(6)(E)] 

B.8 Certification [326 IAC 2-7-4(f)] [326 IAC 2-7-6(1)] [326 IAC 2-7-

5(3)(C)] 

B.9 Annual Compliance Certification [326 IAC 2-7-6(5)] 

B.10 Preventive Maintenance Plan [326 IAC 2-7-5(1),(3) and (13)] [326 IAC 

2-7-6(1) and (6)] 

[326 IAC 1-6-3] 

B.11 Emergency Provisions [326 IAC 2-7-16] 

B.12 Permit Shield [326 IAC 2-7-15] [326 IAC 2-7-20] [326 IAC 2-7-12] 

B.13 Prior Permits Superseded [326 IAC 2-1.1-9.5] [326 IAC 2-7-10.5] 

B.14 Termination of Right to Operate [326 IAC 2-7-10] [326 IAC 2-7-4(a)] 

B.15 Deviations from Permit Requirements and Conditions [326 IAC 2-7-

5(3)(C)(ii) 

B.16 Permit Modification, Reopening, Revocation and Reissuance, or 

Termination 

[326 IAC 2-7-5(6)(C)] [326 IAC 2-7-8(a)] [326 IAC 2-7-9] 

B.17 Permit Renewal [326 IAC 2-7-3] [326 IAC 2-7-4] [326 IAC 2-7-8(e)] 

B.18 Permit Amendment or Modification [326 IAC 2-7-11] [326 IAC 2-7-12] 

[40 CFR 72] 

B.19 Permit Revision Under Economic Incentives and Other Programs [326 

IAC 2-7-5(8)] 

[326 IAC 2-7-12 (b)(2)] 

B.20 Operational Flexibility [326 IAC 2-7-20] [326 IAC 2-7-10.5] 

B.21 Source Modification Requirement [326 IAC 2-7-10.5] [326 IAC 2-2-2] 

and/or [326 IAC 2-3-2] 

B.22 Inspection and Entry [326 IAC 2-7-6] [IC 13-14-2-2] [IC 13-30-3-1] 

[IC 13-17-3-2] 

B.23 Transfer of Ownership or Operational Control [326 IAC 2-7-11] 

B.24 Annual Fee Payment [326 IAC 2-7-19] [326 IAC 2-7-5(7)] [326 IAC 2-

1.1-7] 
B.25 Credible Evidence [326 IAC 2-7-5(3)] [326 IAC 2-7-6] [62 FR 8314] 

[326 IAC 1-1-6] 

C SOURCE OPERATION CONDITIONS 

Emission Limitations and Standards [326 IAC 2-7-5(1)] 

C.1 Particulate Emission Limitations for Processes with Process Weight 

Rates Less Than One 

Hundred (100) Pounds per Hour [326 IAC 6-3-2] 

C.2 Opacity [326 IAC 5-1] 

C.3 Open Burning [326 IAC 4-1] [IC 13-17-9] 

C.4 Incineration [326 IAC 4-2] [326 IAC 9-1-2] 

C.5 Fugitive Dust Emissions [326 IAC 6-4] 

C.6 Stack Height [326 IAC 1-7] 

C.7 Asbestos Abatement Projects [326 IAC 14-10] [326 IAC 18] [40 CFR 61, 

Subpart M] 

Testing Requirements [326 IAC 2-7-6(1)] 

C.8 Performance Testing [326 IAC 3-6] 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 3 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

Compliance Requirements [326 IAC 2-1.1-11] 

C.9 Compliance Requirements [326 IAC 2-1.1-11] 

Compliance Monitoring Requirements [326 IAC 2-7-5(1)] [326 IAC 2-7-6(1)] 

C.10 Compliance Monitoring [326 IAC 2-7-5(3)] [326 IAC 2-7-6(1)] 

C.11 Monitoring Methods [326 IAC 3] [40 CFR 60] [40 CFR 63] 

C.12 Instrument Specifications [326 IAC 2-1.1-11] [326 IAC 2-7-5(3)] [326 

IAC 2-7-6(1)] 

Corrective Actions and Response Steps [326 IAC 2-7-5] [326 IAC 2-7-6] 

C.13 Emergency Reduction Plans [326 IAC 1-5-2] [326 IAC 1-5-3] 

C.14 Risk Management Plan [326 IAC 2-7-5(12)] [40 CFR 68] 

C.15 Response to Excursions and Exceedances [326 IAC 2-7-5] [326 IAC 2-7-

6] 

C.16 Actions Related to Noncompliance Demonstrated by a Stack Test [326 

IAC 2-7-5] 

[326 IAC 2-7-6] 

Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-

7-19] 

C.17 Emission Statement [326 IAC 2-7-5(3)(C)(iii)] [326 IAC 2-7-5(7)] 

[326 IAC 2-7-19(c)] 

[326 IAC 2-6] 

C.18 General Record Keeping Requirements [326 IAC 2-7-5(3)] [326 IAC 2-7-

6] [326 IAC 2-2] 

[326 IAC 2-3] 

C.19 General Reporting Requirements [326 IAC 2-7-5(3)(C)] [326 IAC 2-1.1-

11] [326 IAC 2-2] 

[326 IAC 2-3] 

Stratospheric Ozone Protection 

C.20 Compliance with 40 CFR 82 and 326 IAC 22-1 

D.1 FACILITY OPERATION CONDITIONS - Alumina and Aluminum Fluoride 

Handling Plant 

Emission Limitations and Standards [326 IAC 2-7-5(1)] 

D.1.1 Particulate Emissions Limitations for Manufacturing Processes [326 

IAC 6-3-2] 

D.1.2 PSD Minor Limit [326 IAC 2-2] 

Compliance Determination Requirements 

D.1.3 Particulate Control [326 IAC 2-7-6(6)] 

D.1.4 Testing Requirements [326 IAC 2-7-6(1), (6)] [326 IAC 2-1.1-11] 

Compliance Monitoring Requirements [326 IAC 2-7-6 (1)] [326 IAC 2-7-5 

(1)] 

D.1.5 Bag Leak Detection System 

D.1.6 Bag Leak Detection Alarm Activation 

D.1.7 Broken or Failed Bag Detection except Baghouse 112A and Baghouse 

166 

Record Keeping and Reporting Requirement [326 IAC 2-7-5(3)] [326 IAC 2-7-

19] 

D.1.8 Record Keeping Requirements 

D.2 FACILITY OPERATION CONDITIONS - Potline & Potlines Support 

Emission Limitations and Standards [326 IAC 2-7-5(1)] 

D.2.1 Particulate Emissions Limitations for Manufacturing Processes [326 

IAC 6-3-2] 
D.2.2 Warrick County Sulfur Dioxide (SO2) Emissions Limitations [326 IAC 

7-4-10] 

D.2.3 General Provisions Relating to NESHAP [326 IAC 12] [40 CFR 60 

Subpart S] [326 IAC 20-1] 

[40 CFR Part 63, Subpart A] [40 CFR 63.852] 

D.2.4 Total Fluoride (TF) Emissions Limitations [326 IAC 12] [40 CFR 60 

Subpart S] 

[326 IAC 20-24] [40 CFR 63.843] [40 CFR 63.847] 

D.2.5 Plans and Procedures [326 IAC 12] [40 CFR 60 Subpart S] [326 IAC 

20-1] [40 CFR 63.6] 

[326 IAC 20-24] [40 CFR 63.850] 

D.2.6 HAP Emission Limit [326 IAC 2-4.1] 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 4 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

Compliance Determination Requirements 

D.2.7 Particulate Control [326 IAC 2-7-6(6)] 

D.2.8 SO2 Emissions Determination [326 IAC 7-4-10 (b) and (c)] 

D.2.9 HAP Emission Equation 

D.2.10 Testing [326 IAC 7-10-4(b)] [326 IAC 12] [40 CFR 60 Subpart S] 

[326 IAC 20-1] [40 CFR 63, 

Subpart A] [326 IAC 20-24] [40 CFR 63.847] 

D.2.11 HAP Testing 

D.2.12 Test Methods and Procedures [326 IAC 12] [40 CFR 60 Subpart S] 

[326 IAC 20-1] 

[40 CFR 63, Subpart A] [326 IAC 20-24] [40 CFR 63.849] 

Compliance Monitoring Requirements [326 IAC 2-7-6(1)] [326 IAC 2-7-5(1)] 

[40 CFR 63.847] 

[40 CFR 63.848] [326 IAC 20-24] 

D.2.13 Emission Monitoring Requirements [326 IAC 12] [40 CFR 60 Subpart 

S] [40 CFR 63.848] 

[326 IAC 20-24] 

D.2.14 Emission Monitoring Requirements [326 IAC 12] [40 CFR 60 Subpart 

S] [326 IAC 20-24] 

[40 CFR 63.847] [40 CFR 63.848] 

D.2.15 Visible Emissions Notations 

Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-

7-19] [326 IAC 12] 

[40 CFR 60 Subpart S] [326 IAC 20-1] [40 CFR 63, Subpart A] [326 IAC 20-

24] [40 CFR 63.850] 

D.2.16 Record Keeping Requirements 

D.2.17 NESHAP and NSPS Record Keeping Requirements [326 IAC 12] [40 CFR 

60 Subpart S] 

[326 IAC 20-1] [40 CFR 63, Subpart A] [326 IAC 20-24] [40 CFR 63.850 (c) 

and (e)] 

D.2.18 Reporting Requirements 

D.2.19 HAP Reporting Requirements 

D.2.20 NESHAP and NSPS Reporting Requirements [326 IAC 12] [40 CFR 60 

Subpart S] 

[326 IAC 20-1] [40 CFR 63, Subpart A] [326 IAC 20-24] [40 CFR 63.850(b), 

(c), (d), and (e)] 

Quarterly Reporting Forms 

D.3 FACILITY OPERATION CONDITIONS - Green Anode Plant 

Emission Limitations and Standards [326 IAC 2-7-5(1)] 

D.3.1 Particulate Emissions Limitations for Manufacturing Processes [326 

IAC 6-3-2] 

D.3.2 PSD Minor Limitations [326 IAC 2-2] 

D.3.3 General Provisions Relating to NESHAP [326 IAC 20-1] [40 CFR Part 

63, Subpart A] 

[40 CFR 63.852] 

D.3.4 POM Emissions Control Requirement [326 IAC 20-24] [40 CFR 63.843] 

[40 CFR 63.847] 

D.3.5 Plans and Procedures [326 IAC 20-1] [40 CFR 63.6] [326 IAC 20-24] 

[40 CFR 63.850] 

Compliance Determination Requirements 
D.3.6 Particulate Control [326 IAC 2-7-6(6)] 

D.3.7 Testing Requirements [326 IAC 2-7-6(1), (6)] 

Compliance Monitoring Requirements [326 IAC 2-7-6 (1)] [326 IAC 2-7-5 

(1)] [326 IAC 20-1] 

[40 CFR 63, Subpart A] [326 IAC 20-24] [40 CFR 63.847] [40 CFR 63.848] 

D.3.8 Emission Monitoring Requirements [326 IAC 20-1] [40 CFR 63, Subpart 

A] [326 IAC 20-24] 

[40 CFR 63.847] [40 CFR 63.848] 

D.3.9 Bag Leak Detection System and Alternative Monitoring Plan (AMP) 

[SPM 173-21948-00007] 

[326 IAC 20-24] [40 CFR 63.847] [40 CFR 63.848] 

D.3.10 Visible Emissions Notations 

Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-

7-19] [326 IAC 20-1] 

[40 CFR 63, Subpart A] [326 IAC 20-24] [40 CFR 63.850] 

D.3.11 Record Keeping Requirements 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 5 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

D.3.12 NESHAP Record Keeping Requirements [326 IAC 20-1] [40 CFR 63, 

Subpart A] 

[326 IAC 20-24] [40 CFR 63.850(c) and (e)] 

D.3.13 NESHAP Reporting Requirements [326 IAC 20-1] [40 CFR 63, Subpart 

A] [326 IAC 20-24] 

[40 CFR 63.850(c), (d), and (e)] 

D.4 FACILITY OPERATION CONDITIONS - Anode Baking Plant 

Emission Limitations and Standards [326 IAC 2-7-5(1)] 

D.4.1 Particulate Emissions Limitations for Manufacturing Processes [326 

IAC 6-3-2] 

D.4.2 PSD Minor Limitations [326 IAC 2-2] 

D.4.3 PSD Minor Limitations [326 IAC 2-2] 

D.4.4 PSD BACT [326 IAC 2-2-3] 

D.4.5 Warrick County Sulfur Dioxide Emission Limitations [326 IAC 7-4-10] 

D.4.6 General Provisions Relating to NESHAP [326 IAC 12] [40 CFR 60 

Subpart S] [326 IAC 20-1] 

[40 CFR Part 63, Subpart A] [40 CFR 63.852] 

D.4.7 TF and POM Emissions Limitations [326 IAC 12] [40 CFR 60 Subpart S] 

[326 IAC 20-24] 

[40 CFR 63.843] [40 CFR 63.847] 

D.4.8 Plans and Procedures [326 IAC 12] [40 CFR 60 Subpart S] [326 IAC 

20-1] [40 CFR 63.6] 

[326 IAC 20-24] [40 CFR 63.850] 

Compliance Determination Requirements 

D.4.9 TF, POM, and SO2 Control [326 IAC 2-7-6(6)] 

D.4.10 Particulate Control [326 IAC 2-7-6(6)] 

D.4.11 Testing [326 IAC 7-10-4(b)] [326 IAC 12] [40 CFR 60 Subpart S] 

[326 IAC 20-1] [40 CFR 63, 

Subpart A] [326 IAC 20-24] [40 CFR 63.847] 

D.4.12 Sulfur Dioxide [326 IAC 2-2-3] [326 IAC 7-4-10(a)(4)] 

D.4.13 Test Methods and Procedures [326 IAC 12] [40 CFR 60 Subpart S] 

[326 IAC 20-1] 

[40 CFR 63, Subpart A] [326 IAC 20-24] [40 CFR 63.849] 

D.4.14 Testing Requirements [326 IAC 2-7-6(1), (6)] [326 IAC 2-1.1-11] 

D.4.15 Emergency Bypass Engine Operation 

Compliance Monitoring Requirements [326 IAC 2-7-6 (1)] [326 IAC 2-7-5 

(1)] [326 IAC 12] 

[40 CFR 60 Subpart S] [326 IAC 20-1] [40 CFR 63, Subpart A] [326 IAC 20-

24] [40 CFR 63.847] 

[40 CFR 63.848] 

D.4.16 Emission Monitoring Requirements [326 IAC 12] [40 CFR 60 Subpart 

S] [326 IAC 20-24] 

[40 CFR 63.847] [40 CFR 63.848] 

D.4.17 Bag Leak Detection System and Alternative Monitoring Plan (AMP) 

[SPM 173-21948-00007] 

[326 IAC 12] [40 CFR 60 Subpart S] [326 IAC 20-24] [40 CFR 63.847] [40 

CFR 63.848] 

D.4.18 Visible Emissions Notations 

Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-

7-19] [326 IAC 12] 
[40 CFR 60 Subpart S] [326 IAC 20-1] [40 CFR 63, Subpart A] [326 IAC 20-

24] [40 CFR 63.850] 

D.4.19 Record Keeping Requirements 

D.4.20 NESHAP Record Keeping Requirements [326 IAC 12] [40 CFR 60 Subpart 

S] [326 IAC 20-1] 

[40 CFR 63, Subpart A] [326 IAC 20-24] [40 CFR 63.850 (c) and (e)] 

D.4.21 Reporting Requirements 

D.4.22 NESHAP Reporting Requirements [326 IAC 12] [40 CFR 60 Subpart S] 

[326 IAC 20-1] 

[40 CFR 63, Subpart A] [326 IAC 20-24] [40 CFR 63.850(c), (d), and (e)] 

Quarterly Reporting Forms 

D.5 FACILITY OPERATION CONDITIONS - Anode Assembly & Spent Anode Plant

Emission Limitations and Standards [326 IAC 2-7-5(1)] 

D.5.1 Particulate Emissions Limitations for Manufacturing Processes [26 

IAC 6-3-2] 

D.5.2 PSD Minor Limitations [326 IAC 2-2] 

Compliance Determination Requirements 

D.5.3 Testing Requirements [326 IAC 2-7-6(1), (6)] [326 IAC 2-1.1-11] 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 6 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

D.5.4 Particulate Control [326 IAC 2-7-6(6)] 

Compliance Monitoring Requirements [326 IAC 2-7-6(1)] [326 IAC 2-7-5(1)] 

D.5.5 Bag Leak Detection System 

D.5.6 Bag Leak Detection Alarm Activation 

D.5.7 Visible Emissions Notations 

Record Keeping and Reporting Requirement [326 IAC 2-7-5(3)] [326 IAC 2-7-

19] 

D.5.8 Record Keeping Requirements 

D.6 FACILITY OPERATION CONDITIONS - Ingot Plant and Support 

Emission Limitations and Standards [326 IAC 2-7-5(1)] 

D.6.1 Particulate Emissions Limitations for Manufacturing Processes [326 

IAC 6-3-2] 

D.6.2 PSD and Nonattainment New Source Review Minor Limitations [326 IAC 

2-2] 

[326 IAC 2-1.1-5] 

D.6.3 PSD Minor Limitations [326 IAC 2-2] 

D.6.4 PSD Minor Limitations [326 IAC 2-2] 

D.6.5 PSD and Nonattainment New Source Review Minor Limitations [326 IAC 

2-2] 

[326 IAC 2-1.1-5] 

D.6.6 General Provisions Relating to NESHAP [326 IAC 20-1] [40 CFR Part 

63, Subpart A] 

[40 CFR 63.1518] 

D.6.7 Emission Limits for Secondary Aluminum Production Sources and 

Emission Units

[326 IAC 20-70] [40 CFR 63.1505] 

D.6.8 Operating Requirements for Affected NESHAP Emission Units [326 IAC 

20-70] 

[40 CFR 63.1506] 

D.6.9 Alternative Opacity Limitation [326 IAC 5-1-5(b)] [U.S. EPA SIP 

Revisions Revised Opacity 

Limits] 

Compliance Determination Requirements 

D.6.10 NESHAP Performance Test/Compliance Demonstration General 

Requirements 

[326 IAC 20-1] [40 CFR 63, Subpart A] [326 IAC 20-70] [40 CFR 63.1511] 

D.6.11 NESHAP Performance Test/Compliance Demonstration Requirements and 

Procedures 

[326 IAC 20-1] [40 CFR 63, Subpart A] [326 IAC 20-70] [40 CFR 63.1512] 

[40 CFR 63.1513] 

D.6.12 Non NESHAP Emission Units Testing Requirements [326 IAC 2-7-6(1), 

(6)] 

[326 IAC 2-1.1-11] 

D.6.13 PM and PM10 Control from Dross Cooling Operation [326 IAC 2-7-

6(6)] 

D.6.14 PM Control from Coated Scrap Shredder [326 IAC 2-7-6(6)] 

D.6.15 Particulate Control from Rotary Group 1 Furnace [326 IAC 2-7-6(6)] 

D.6.16 Particulate Control from Flux Salt Storage Bin [326 IAC 2-7-6(6)] 

Compliance Monitoring Requirements [326 IAC 2-7-6(1)] [326 IAC 2-7-5(1)] 

[326 IAC 20-1] 
[40 CFR 63, Subpart A] [326 IAC 20-70] [40 CFR 63.1510] 

D.6.17 NESHAP Monitoring Requirements [326 IAC 20-1] [40 CFR 63, Subpart 

A] [326 IAC 20-70] 

[40 CFR 63.1510] 

D.6.18 Bag Leak Detection Systems for Dross Cooling Baghouses and Rotary 

Group 1 Furnace 

Baghouse [326 IAC 2-7-6(1)] [326 IAC 2-7-5(1)] 

D.6.19 Bag Leak Detection Alarm Activation [326 IAC 2-7-6(1)] [326 IAC 2-

7-5(1)] 

D.6.20 Visible Emissions Notations for Flux Salt Storage Silo Bin Vent 

Filter [326 IAC 2-7-6(1)] 

[326 IAC 2-7-5(1)] 

D.6.21 Water Level Monitoring [326 IAC 2-7-6(1)] [326 IAC 2-7-5(1)] 

Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-

7-19] [326 IAC 20-1] 

[40 CFR 63, Subpart A] [326 IAC 20-70] [40 CFR 63.1516] [40 CFR 63.1517] 

D.6.22 NESHAP Record Keeping Requirements [326 IAC 20-1] [40 CFR 63, 

Subpart A] 

[326 IAC 20-70] [40 CFR 63.1517] 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 7 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

D.6.23 Record Keeping Requirements 

D.6.24 NESHAP Reporting Requirements [326 IAC 20-1] [40 CFR 63, Subpart 

A] [326 IAC 20-70] 

[40 CFR 63.1516] 

D.6.25 Reporting Requirements 

Quarterly Reporting Forms 

D.7 FACILITY OPERATION CONDITIONS - Rolling Mills Plant 

Emission Limitations and Standards [326 IAC 2-7-5(1)] 

D.7.1 Particulate Emissions Limitations for Manufacturing Processes [326 

IAC 6-3-2] 

D.7.2 General Provisions Relating to NSPS, Subpart Dc [326 IAC 12] [40 

CFR Part 60, Subpart A] 

D.7.3 Particulate Emissions Limitations for Sources of Indirect Heating 

[326 IAC 6-2-3] 

[326 IAC 6-2-4] 

Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-

7-19] [326 IAC 12] 

[40 CFR 60, Subpart Dc] 

D.7.4 New Source Performance Standard (NSPS) Record Keeping Requirements 

[326 IAC 12] 

[40 CFR 60, Subpart Dc] 

D.8 FACILITY OPERATION CONDITIONS - Coating Plant 

Emission Limitations and Standards [326 IAC 2-7-5(1)] 

D.8.1 Particulate Emissions Limitations for Manufacturing Processes [326 

IAC 6-3-2] 

D.8.2 PSD Minor Limit [326 IAC 2-2] 

D.8.3 PSD Emission Limit [326 IAC 2-2] 

D.8.4 General Provisions Relating to NESHAP [326 IAC 20-1] [40 CFR Part 

63, Subpart A] 

[326 IAC 20-64] [40 CFR 63.5140] 

D.8.5 Coil Coating Lines Emission Limits [326 IAC 12] [326 IAC 20-64] [40 

CFR 63.5120] 

[40 CFR 63.5140] [40 CFR 60.462] [326 IAC 8-2-4] 

D.8.6 Operating Requirements for Coil Coating Lines CCL2 and CCL3 [326 

IAC 12] 

[326 IAC 20-64] [40 CFR Part 63.5121] [40 CFR 60.463] 

D.8.7 General Provisions Relating to Hazardous Air Pollutants [326 IAC 

20-1] [40 CFR Part 63, 

Subpart A] 

D.8.8 National Emission Standards for Hazardous Air Pollutants: Organic 

Liquids Distribution, 

Non-Gasoline [326 IAC 20-83] [40 CFR Part 63, Subpart EEEE] 

D.8.9 Organic Liquid Distribution Operations – Affected Sources [326 IAC 

20-83] [40 CFR 63.2338] 

Compliance Determination Requirements 

D.8.10 Compliance Determination Requirements 

D.8.11 Compliance Demonstration Requirements [326 IAC 12] [326 IAC 20-64] 

[40 CFR63.5170] 

[40 CFR 60.463] [326 IAC 8-2-4] 
D.8.12 Testing Requirements [326 IAC 2-7-6(1), (6)] [326 IAC 2-1.1-11] 

[326 IAC 12] [326 IAC 20-1] 

[40 CFR 63, Subpart A] [326 IAC 20-64] [40 CFR 5160] [40 CFR 60.463] 

Compliance Monitoring Requirements [326 IAC 2-7-6 (1)] [326 IAC 2-7-5 

(1)] [326 IAC 12] 

[326 IAC 20-1] [40 CFR 63, Subpart A] [326 IAC 20-64] [40 CFR 63.5150] 

[40 CFR 60.464] 

D.8.13 Thermal Oxidizer and Capture System Operating Parameters 

Monitoring 

Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-

7-19] [326 IAC 12] 

[326 IAC 20-1] [40 CFR 63, Subpart A] [326 IAC 20-64] [326 IAC 20-83] [40 

CFR 60.465] 

[40 CFR 63.5180] [40 CFR 63.5190] 

D.8.14 Record Keeping Requirements 

D.8.15 Reporting Requirements [326 IAC 20-1] [40 CFR 63, Subpart A] [326 

IAC 12] 

[326 IAC 20-64] [40 CFR 63.5180] [40 CFR 60, Subpart TT] 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 8 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

D.9 FACILITY OPERATION CONDITIONS - Brick Crusher 

Emission Limitations and Standards [326 IAC 2-7-5(1)] 

D.9.1 Part 70 Permit; Source Modification [326 IAC 2-7-10.5] 

D.9.2 Particulate Emissions Limitations for Manufacturing Processes [326 

IAC 6-3-2] 

D.9.3 Preventive Maintenance Plan [326 IAC 2-7-5(13)] 

Compliance Determination Requirements 

D.9.4 Particulate Matter (PM) 

Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-

7-19] [326 IAC 12] 

D.9.5 Record Keeping Requirements 

D.9.6 Reporting Requirements 

Quarterly Reporting Forms 

Certification 

Emergency Occurrence Report 

Quarterly Deviation and Compliance Monitoring Report 

Attachment A: National Emission Standards for Hazardous Air Pollutants 

(NESHAP): Organic Liquids 

Distribution (Non-Gasoline) [40 CFR Part 63, Subpart EEEE] [326 IAC 20-

83] 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 9 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

SECTION A SOURCE SUMMARY 

This permit is based on information requested by Indiana Department of 

Environmental Management (IDEM), 

Office of Air Quality (OAQ). The information describing the source 

contained in Conditions A.1, A.3, and A.4 

is descriptive information and does not constitute enforceable 

conditions. However, the Permittee should be 

aware that a physical change or a change in the method of operation that 

may render this descriptive 

information obsolete or inaccurate may trigger requirements for the 

Permittee to obtain additional permits or 

seek modification of this permit pursuant to 326 IAC 2, or change other 

applicable requirements presented in 

the permit application. 

A.1 General Information [326 IAC 2-7-4(c)] [326 IAC 2-7-5(15)] [326 IAC 

2-7-1(22)] 

The Permittee owns and operates an aluminum production plant, which 

produces aluminum ingot, 

aluminum coils and coated aluminum coils. 

Source Address: Jct. IN Highways 66 and 61, Newburgh, Indiana 47629-0010 

Mailing Address: Bldg. 860 E, P.O. Box 10, Newburgh, Indiana 47629 

General Source Phone Number: 812-853-6111 

SIC Code: 3334 and 3352 

County Location: Warrick 

Source Location Status: Attainment for ozone under the 8-hour standard 

Nonattainment for PM2.5 

Attainment for all other criteria pollutants 

Source Status: Part 70 Permit Program 

Major Source, under PSD and Nonattainment New Source 

Review Rules 

Major Source, Section 112 of the Clean Air Act 

1 of 28 Source Categories 

A.2 Part 70 Source Definition [326 IAC 2-7-1(22)] 

This company consists of two (2) plants: 

(a) Alcoa aluminum production plant, the primary operation, is located at 

Jct. IN Hwys. 66 & 61, 

Newburgh, Indiana. 

(b) Alcoa power plant, the supporting operation, is located at 4700 

Darlington Road, Newburgh, 

Indiana. 

Since the two (2) plants are located on contiguous properties, and are 

owned by one (1) company, 

they will be considered one (1) source. 

Separate Part 70 permits will be issued to Alcoa Inc.- Warrick Operations 

and Alcoa Warrick Power 

Plant solely for administrative purposes. 

These two plants have different plant identification numbers. 

Alcoa Inc. – Warrick Operations ID - 173-00007 

Alcoa Warrick Power Plant ID - 173-00002 
A.3 Emission Units and Pollution Control Equipment Summary [326 IAC 2-7-

4(c)(3)] [326 IAC 2-7-5(15)] 

The source consists of the following operating areas that are made up of 

various types of emissions 

units and pollution control devices. These operating areas correspond to 

the various ―D‖ sections of 

the Part 70 permit and are described in more detail in Appendix A of this 

TSD. 

(a) D.1 Alumina and aluminum fluoride handling Plant: The alumina and 

aluminum fluoride 

handling plant consists of the barge alumina unloading, truck unloading, 

and rail unloading. 

There are various conveyors, and tanks associated with this operation. 

The alumina is finally 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

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Permit Reviewer: Dr. Trip Sinha 

fed to Potlines 1 to 6. The emissions are controlled by several 

baghouses. The detailed 

equipment list is located in Section D.1 of this permit. 

(b) D.2 Center-worked Pre-Bake One Potlines and Potlines Support: The 

Potlines and Potlines 

Support plant consists of the six center-worked prebake one potline 

controlled by fluidized 

bed scrubbers (for potlines 2, 5, and 6), alumina injection and fabric 

filtration systems (for 

potlines 3 and 4, identified as the gas treatment center (GTC) systems), 

and baghouses. It 

includes a hydraulic hammer, auger, crusher, each controlled by a 

baghouse, and 

alumina/butt bath/cake storage tanks. The detailed equipment list is 

located in Section D.2 of 

this permit. 

(c) D.3 Green Anode Plant: The Green Anode Plant consists of the green 

petroleum coke 

storage silos, green petroleum coke and anode butt shaker screens, coke 

storage tanks, 

hammer mill, anode butts and scrap green anode hammer mill, green 

petroleum coke 

intermediate classifier, ball mill, weighting facility, anode forming 

consisting of mixers, 

associated conveying, and hydraulic presses, with emissions controlled by 

the pitch fume 

treatment system, and fixed roof coal tar pitch tanks. The detailed 

equipment list is located in 

Section D.3 of this permit. 

(d) D.4 Anode Baking Plant: The Anode Baking Plant consists of anode 

baking ring furnace, a 

diesel fired emergency bypass engine, reacted alumina storage tank, 

reacted alumina truck 

loadout, baked anode vacuum system, and un-reacted alumina storage 

tank/truck unloading. 

The detailed equipment list is located in Section D.4 of this permit. 

(e) D.5 Anode Assembly & Spent Anode Plant: The Anode Assembly & Spent 

Anode Plant 

consists of anode butt blast machine, tumbleblast, impactor, rod cleaning 

machine, butt 

storage tank, iron casting station, induction furnaces, spent anode 

storage pad, and several 

baghouses. The detailed equipment list is located in Section D.5 of this 

permit. 

(f) D.6 Ingot Plant and Support: The Ingot Plant and Support consists of 

group 1 furnaces, 

in-line fluxers, group 2 furnaces, aluminum pneumatic transport systems, 

a coated scrap 

shredder, dross cooling and handling, and emergency intermittent dutycycled, diesel fired, 
reciprocating internal combustion engines. The detailed equipment list is 

located in Section 

D.6 of this permit. 

(g) D.7 Rolling Mills Plant: The Rolling Mills Plant consists of scalper 

step cutter, hot ingot oxide 

brushing system, silos, hot reversing mill, continuous hot mill, cold 

mills, mist eliminator, 

annealing furnaces, preheat furnaces, and natural gas fired boilers. The 

detailed equipment 

list is located in Section D.7 of this permit. 

(h) D.8 Coating Plant: The Coating Plant consists of electro coil prep 

coating line, coil coating 

lines, coating mixing room and mix stations, and coatings and solvents 

tanks. The detailed 

equipment list is located in Section D.8 of this permit. 

(i) One (1) portable BL Pergson 428 fixed hammer impactor (Brick 

crusher), with a capacity of 

100 tons per hour, with a 20 to 1 reduction ratio, with a 3306 

caterpillar diesel engine, with a 

capacity of 300 hp and using a four (4) wet suppression for control of 

particulate matters (four 

sprays, two on the conveyor and two on the impactor). 

A.4 Specifically Regulated Insignificant Activities [326 IAC 2-7-1(21)] 

[326 IAC 2-7-4(c)] 

[326 IAC 2-7-5(15)] 

The detailed regulated insignificant activities are located in individual 

D sections of this permit. 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 11 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

A.5 Part 70 Permit Applicability [326 IAC 2-7-2] 

This stationary source is required to have a Part 70 permit by 326 IAC 2-

7-2 (Applicability) because: 

(a) It is a major source, as defined in 326 IAC 2-7-1(22); and 

(b) It is a source in a source category designated by the United States 

Environmental Protection 

Agency (U.S. EPA) under 40 CFR 70.3 (Part 70 - Applicability). 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 12 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

SECTION B GENERAL CONDITIONS 

B.1 Definitions [326 IAC 2-7-1] 

Terms in this permit shall have the definition assigned to such terms in 

the referenced regulation. In 

the absence of definitions in the referenced regulation, the applicable 

definitions found in the statutes 

or regulations (IC 13-11, 326 IAC 1-2 and 326 IAC 2-7) shall prevail. 

B.2 Permit Term [326 IAC 2-7-5(2)] [326 IAC 2-1.1-9.5] [326 IAC 2-7-

4(a)(1)(D)] [IC 13-15-3-6(a)] 

(a) This permit, T 173-6627-00007, is issued for a fixed term of five (5) 

years from the issuance 

date of this permit, as determined in accordance with IC 4-21.5-3-5(f) 

and IC 13-15-5-3. 

Subsequent revisions, modifications, or amendments of this permit do not 

affect the 

expiration date of this permit or of permits issued pursuant to Title IV 

of the Clean Air Act and 

326 IAC 21 (Acid Deposition Control). 

(b) If IDEM, OAQ, upon receiving a timely and complete renewal permit 

application, fails to issue 

or deny the permit renewal prior to the expiration date of this permit, 

this existing permit shall 

not expire and all terms and conditions shall continue in effect, 

including any permit shield 

provided in 326 IAC 2-7-15, until the renewal permit has been issued or 

denied. 

B.3 Term of Conditions [326 IAC 2-1.1-9.5] 

Notwithstanding the permit term of a permit to construct, a permit to 

operate, or a permit modification, 

any condition established in a permit issued pursuant to a permitting 

program approved in the state 

implementation plan shall remain in effect until: 

(a) the condition is modified in a subsequent permit action pursuant to 

Title I of the Clean Air Act; 

or 

(b) the emission unit to which the condition pertains permanently ceases 

operation. 

B.4 Enforceability [326 IAC 2-7-7] 

Unless otherwise stated, all terms and conditions in this permit, 

including any provisions designed to 

limit the source's potential to emit, are enforceable by IDEM, the United 

States Environmental 

Protection Agency (U.S. EPA) and by citizens in accordance with the Clean 

Air Act. 

B.5 Severability [326 IAC 2-7-5(5)] 

The provisions of this permit are severable; a determination that any 

portion of this permit is invalid 

shall not affect the validity of the remainder of the permit. 

B.6 Property Rights or Exclusive Privilege [326 IAC 2-7-5(6)(D)] 
This permit does not convey any property rights of any sort or any 

exclusive privilege. 

B.7 Duty to Provide Information [326 IAC 2-7-5(6)(E)] 

(a) The Permittee shall furnish to IDEM, OAQ, within a reasonable time, 

any information that 

IDEM, OAQ may request in writing to determine whether cause exists for 

modifying, revoking 

and reissuing, or terminating this permit, or to determine compliance 

with this permit. The 

submittal by the Permittee does require the certification by the 

"responsible official" as 

defined by 326 IAC 2-7-1(34). Upon request, the Permittee shall also 

furnish to IDEM, OAQ 

copies of records required to be kept by this permit. 

(b) For information furnished by the Permittee to IDEM, OAQ, the 

Permittee may include a claim 

of confidentiality in accordance with 326 IAC 17.1. When furnishing 

copies of requested 

records directly to U. S. EPA, the Permittee may assert a claim of 

confidentiality in 

accordance with 40 CFR 2, Subpart B. 

B.8 Certification [326 IAC 2-7-4(f)] [326 IAC 2-7-6(1)] [326 IAC 2-7-

5(3)(C)] 

(a) Where specifically designated by this permit or required by an 

applicable requirement, any 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

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Permit Reviewer: Dr. Trip Sinha 

application form, report, or compliance certification submitted shall 

contain certification by the 

"responsible official" of truth, accuracy, and completeness. This 

certification shall state that, 

based on information and belief formed after reasonable inquiry, the 

statements and 

information in the document are true, accurate, and complete. 

(b) One (1) certification shall be included, using the attached 

Certification Form, with each 

submittal requiring certification. One (1) certification may cover 

multiple forms in one (1) 

submittal. 

(c) A "responsible official" is defined at 326 IAC 2-7-1(34). 

B.9 Annual Compliance Certification [326 IAC 2-7-6(5)] 

(a) The Permittee shall annually submit a compliance certification report 

which addresses the 

status of the source’s compliance with the terms and conditions contained 

in this permit, 

including emission limitations, standards, or work practices. The initial 

certification shall 

cover the time period from the date of final permit issuance through 

December 31 of the 

same year. All subsequent certifications shall cover the time period from 

January 1 to 

December 31 of the previous year, and shall be submitted no later than 

July 1 of each year 

to: 

Indiana Department of Environmental Management 

Compliance and Enforcement Branch, Office of Air Quality 

100 North Senate Avenue 

MC 61-53 IGCN 1003 

Indianapolis, Indiana 46204-2251 

and 

United States Environmental Protection Agency, Region V 

Air and Radiation Division, Air Enforcement Branch - Indiana (AE-17J) 

77 West Jackson Boulevard 

Chicago, Illinois 60604-3590 

(b) The annual compliance certification report required by this permit 

shall be considered timely if 

the date postmarked on the envelope or certified mail receipt, or affixed 

by the shipper on the 

private shipping receipt, is on or before the date it is due. If the 

document is submitted by 

any other means, it shall be considered timely if received by IDEM, OAQ, 

on or before the 

date it is due. 

(c) The annual compliance certification report shall include the 

following: 

(1) The appropriate identification of each term or condition of this 

permit that is the basis 
of the certification; 

(2) The compliance status; 

(3) Whether compliance was continuous or intermittent; 

(4) The methods used for determining the compliance status of the source, 

currently and 

over the reporting period consistent with 326 IAC 2-7-5(3); and 

(5) Such other facts, as specified in Sections D of this permit, as IDEM, 

OAQ may 

require to determine the compliance status of the source. 

The submittal by the Permittee does require the certification by the 

"responsible official" as 

defined by 326 IAC 2-7-1(34). 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

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Permit Reviewer: Dr. Trip Sinha 

B.10 Preventive Maintenance Plan [326 IAC 2-7-5(1),(3) and (13)] [326 IAC 

2-7-6(1) and (6)] 

[326 IAC 1-6-3] 

(a) If required by specific condition(s) in Section D of this permit, the 

Permittee shall prepare and 

maintain Preventive Maintenance Plans (PMPs) within ninety (90) days 

after issuance of this 

permit or ninety (90) days after initial start-up, whichever is later, 

including the following 

information on each facility: 

(1) Identification of the individual(s) responsible for inspecting, 

maintaining, and 

repairing emission control devices; 

(2) A description of the items or conditions that will be inspected and 

the inspection 

schedule for said items or conditions; and 

(3) Identification and quantification of the replacement parts that will 

be maintained in 

inventory for quick replacement. 

If, due to circumstances beyond the Permittee’s control, the PMPs cannot 

be prepared and 

maintained within the above time frame, the Permittee may extend the date 

an additional 

ninety (90) days provided the Permittee notifies: 

Indiana Department of Environmental Management 

Compliance and Enforcement Branch, Office of Air Quality 

100 North Senate Avenue 

MC 61-53 IGCN 1003 

Indianapolis, Indiana 46204-2251 

The PMP extension notification does not require the certification by the 

"responsible official" 

as defined by 326 IAC 2-7-1(34). 

(b) A copy of the PMPs shall be submitted to IDEM, OAQ upon request and 

within a reasonable 

time, and shall be subject to review and approval by IDEM, OAQ. IDEM, OAQ 

may require 

the Permittee to revise its PMPs whenever lack of proper maintenance 

causes or is the 

primary contributor to an exceedance of any limitation on emissions or 

potential to emit. The 

PMPs do not require the certification by the "responsible official" as 

defined by 

326 IAC 2-7-1(34). 

(c) To the extent the Permittee is required by 40 CFR Part 60/63 to have 

an Operation 

Maintenance, and Monitoring (OMM) Plan for a unit, such Plan is deemed to 

satisfy the PMP 

requirements of 326 IAC 1-6-3 for that unit. 

B.11 Emergency Provisions [326 IAC 2-7-16] 
(a) An emergency, as defined in 326 IAC 2-7-1(12), is not an affirmative 

defense for an action 

brought for noncompliance with a federal or state health-based emission 

limitation. 

(b) An emergency, as defined in 326 IAC 2-7-1(12), constitutes an 

affirmative defense to an 

action brought for noncompliance with a technology-based emission 

limitation if the 

affirmative defense of an emergency is demonstrated through properly 

signed, 

contemporaneous operating logs or other relevant evidence that describe 

the following: 

(1) An emergency occurred and the Permittee can, to the extent possible, 

identify the 

causes of the emergency; 

(2) The permitted facility was at the time being properly operated; 

(3) During the period of an emergency, the Permittee took all reasonable 

steps to 

minimize levels of emissions that exceeded the emission standards or 

other 

requirements in this permit; 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

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Permit Reviewer: Dr. Trip Sinha 

(4) For each emergency lasting one (1) hour or more, the Permittee 

notified IDEM, OAQ, 

and Southwest Regional Office within four (4) daytime business hours 

after the 

beginning of the emergency, or after the emergency was discovered or 

reasonably 

should have been discovered; 

Telephone Number: 1-800-451-6027 (ask for Office of Air Quality, 

Compliance Section), or 

Telephone Number: 317-233-0178 (ask for Compliance Section) 

Facsimile Number: 317-233-6865 

Southwest Regional Office phone: (812) 380-2305; fax: (812) 380-2304. 

(5) For each emergency lasting one (1) hour or more, the Permittee 

submitted the 

attached Emergency Occurrence Report Form or its equivalent, either by 

mail or 

facsimile to: 

Indiana Department of Environmental Management 

Compliance and Enforcement Branch, Office of Air Quality 

100 North Senate Avenue 

MC 61-53 IGCN 1003 

Indianapolis, Indiana 46204-2251 

within two (2) working days of the time when emission limitations were 

exceeded due 

to the emergency. 

The notice fulfills the requirement of 326 IAC 2-7-5(3)(C)(ii) and must 

contain the 

following: 

(A) A description of the emergency; 

(B) Any steps taken to mitigate the emissions; and 

(C) Corrective actions taken. 

The notification which shall be submitted by the Permittee does not 

require the 

certification by the "responsible official" as defined by 326 IAC 2-7-

1(34). 

(6) The Permittee immediately took all reasonable steps to correct the 

emergency. 

(c) In any enforcement proceeding, the Permittee seeking to establish the 

occurrence of an 

emergency has the burden of proof. 

(d) This emergency provision supersedes 326 IAC 1-6 (Malfunctions). This 

permit condition is in 

addition to any emergency or upset provision contained in any applicable 

requirement. 

(e) The Permittee seeking to establish the occurrence of an emergency 

shall make records 

available upon request to ensure that failure to implement a PMP did not 

cause or contribute 

to an exceedance of any limitations on emissions. However, IDEM, OAQ may 

require that 
the Preventive Maintenance Plans required under 326 IAC 2-7-4(c)(9) be 

revised in response 

to an emergency. 

(f) Failure to notify IDEM, OAQ by telephone or facsimile of an emergency 

lasting more than 

one (1) hour in accordance with (b)(4) and (5) of this condition shall 

constitute a violation of 

326 IAC 2-7 and any other applicable rules. 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

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Permit Reviewer: Dr. Trip Sinha 

(g) If the emergency situation causes a deviation from a technology-based 

limit, the Permittee 

may continue to operate the affected emitting facilities during the 

emergency provided the 

Permittee immediately takes all reasonable steps to correct the emergency 

and minimize 

emissions. 

(h) The Permittee shall include all emergencies in the Quarterly 

Deviation and Compliance 

Monitoring Report. 

B.12 Permit Shield [326 IAC 2-7-15] [326 IAC 2-7-20] [326 IAC 2-7-12] 

(a) Pursuant to 326 IAC 2-7-15, the Permittee has been granted a permit 

shield. The permit 

shield provides that compliance with the conditions of this permit shall 

be deemed 

compliance with any applicable requirements as of the date of permit 

issuance, provided that 

either the applicable requirements are included and specifically 

identified in this permit or the 

permit contains an explicit determination or concise summary of a 

determination that other 

specifically identified requirements are not applicable. The Indiana 

statutes from IC 13 and 

rules from 326 IAC, referenced in conditions in this permit, are those 

applicable at the time 

the permit was issued. The issuance or possession of this permit shall 

not alone constitute a 

defense against an alleged violation of any law, regulation or standard, 

except for the 

requirement to obtain a Part 70 permit under 326 IAC 2-7 or for 

applicable requirements for 

which a permit shield has been granted. 

This permit shield does not extend to applicable requirements which are 

promulgated after 

the date of issuance of this permit unless this permit has been modified 

to reflect such new 

requirements. 

(b) If, after issuance of this permit, it is determined that the permit 

is in nonconformance with an 

applicable requirement that applied to the source on the date of permit 

issuance, IDEM, 

OAQ, shall immediately take steps to reopen and revise this permit and 

issue a compliance 

order to the Permittee to ensure expeditious compliance with the 

applicable requirement until 

the permit is reissued. The permit shield shall continue in effect so 

long as the Permittee is in 

compliance with the compliance order. 

(c) No permit shield shall apply to any permit term or condition that is 

determined after issuance 
of this permit to have been based on erroneous information supplied in 

the permit application. 

Erroneous information means information that the Permittee knew to be 

false, or in the 

exercise of reasonable care should have been known to be false, at the 

time the information 

was submitted. 

(d) Nothing in 326 IAC 2-7-15 or in this permit shall alter or affect the 

following: 

(1) The provisions of Section 303 of the Clean Air Act (emergency 

orders), including the 

authority of the U.S. EPA under Section 303 of the Clean Air Act; 

(2) The liability of the Permittee for any violation of applicable 

requirements prior to or at 

the time of this permit's issuance; 

(3) The applicable requirements of the acid rain program, consistent with 

Section 408(a) 

of the Clean Air Act; and 

(4) The ability of U.S. EPA to obtain information from the Permittee 

under Section 114 of 

the Clean Air Act. 

(e) This permit shield is not applicable to any change made under 326 IAC 

2-7-20(b)(2) 

(Sections 502(b)(10) of the Clean Air Act changes) and 326 IAC 2-7-

20(c)(2) (trading based 

on State Implementation Plan (SIP) provisions). 

(f) This permit shield is not applicable to modifications eligible for 

group processing until after 

IDEM, OAQ, has issued the modifications. [326 IAC 2-7-12(c)(7)] 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

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Permit Reviewer: Dr. Trip Sinha 

(g) This permit shield is not applicable to minor Part 70 permit 

modifications until after IDEM, 

OAQ, has issued the modification. [326 IAC 2-7-12(b)(8)] 

B.13 Prior Permits Superseded [326 IAC 2-1.1-9.5] [326 IAC 2-7-10.5] 

(a) All terms and conditions of permits established prior to T 173-6627-

00007 and issued 

pursuant to permitting programs approved into the state implementation 

plan have been 

either: 

(1) incorporated as originally stated, 

(2) revised under 326 IAC 2-7-10.5, or 

(3) deleted under 326 IAC 2-7-10.5. 

(b) Provided that all terms and conditions are accurately reflected in 

this combined permit, all 

previous registrations and permits are superseded by this combined new 

source review and 

part 70 operating permit, except for permits issued pursuant to Title IV 

of the Clean Air Act 

and 326 IAC 21 (Acid Deposition Control) 

B.14 Termination of Right to Operate [326 IAC 2-7-10] [326 IAC 2-7-4(a)] 

The Permittee's right to operate this source terminates with the 

expiration of this permit unless a 

timely and complete renewal application is submitted at least nine (9) 

months prior to the date of 

expiration of the source’s existing permit, consistent with 326 IAC 2-7-3 

and 326 IAC 2-7-4(a). 

B.15 Deviations from Permit Requirements and Conditions [326 IAC 2-7-

5(3)(C)(ii)] 

(a) Deviations from any permit requirements (for emergencies see Section 

B - Emergency 

Provisions), the probable cause of such deviations, and any response 

steps or preventive 

measures taken shall be reported to: 

Indiana Department of Environmental Management 

Compliance and Enforcement Branch, Office of Air Quality 

100 North Senate Avenue 

MC 61-53 IGCN 1003 

Indianapolis, Indiana 46204-2251 

using the attached Quarterly Deviation and Compliance Monitoring Report, 

or its equivalent. 

A deviation required to be reported pursuant to an applicable requirement 

that exists 

independent of this permit, shall be reported according to the schedule 

stated in the 

applicable requirement and does not need to be included in this report. 

The Quarterly Deviation and Compliance Monitoring Report does require the 

certification by 

the "responsible official" as defined by 326 IAC 2-7-1(34). 

(b) A deviation is an exceedance of a permit limitation or a failure to 

comply with a requirement 
of the permit. 

B.16 Permit Modification, Reopening, Revocation and Reissuance, or 

Termination 

[326 IAC 2-7-5(6)(C)] [326 IAC 2-7-8(a)] [326 IAC 2-7-9] 

(a) This permit may be modified, reopened, revoked and reissued, or 

terminated for cause. The 

filing of a request by the Permittee for a Part 70 Operating Permit 

modification, revocation 

and reissuance, or termination, or of a notification of planned changes 

or anticipated 

noncompliance does not stay any condition of this permit. [326 IAC 2-7-

5(6)(C)]The 

notification by the Permittee does require the certification by the 

"responsible official" as 

defined by 326 IAC 2-7-1(34). 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

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(b) This permit shall be reopened and revised under any of the 

circumstances listed in 

IC 13-15-7-2 or if IDEM, OAQ determines any of the following: 

(1) That this permit contains a material mistake. 

(2) That inaccurate statements were made in establishing the emissions 

standards or 

other terms or conditions. 

(3) That this permit must be revised or revoked to assure compliance with 

an applicable 

requirement. [326 IAC 2-7-9(a)(3)] 

(c) Proceedings by IDEM, OAQ to reopen and revise this permit shall 

follow the same 

procedures as apply to initial permit issuance and shall affect only 

those parts of this permit 

for which cause to reopen exists. Such reopening and revision shall be 

made as 

expeditiously as practicable. [326 IAC 2-7-9(b)] 

(d) The reopening and revision of this permit, under 326 IAC 2-7-9(a), 

shall not be initiated 

before notice of such intent is provided to the Permittee by IDEM, OAQ at 

least thirty (30) 

days in advance of the date this permit is to be reopened, except that 

IDEM, OAQ may 

provide a shorter time period in the case of an emergency. [326 IAC 2-7-

9(c)] 

B.17 Permit Renewal [326 IAC 2-7-3] [326 IAC 2-7-4] [326 IAC 2-7-8(e)] 

(a) The application for renewal shall be submitted using the application 

form or forms prescribed 

by IDEM, OAQ and shall include the information specified in 326 IAC 2-7-

4. Such 

information shall be included in the application for each emission unit 

at this source, except 

those emission units included on the trivial or insignificant activities 

list contained in 

326 IAC 2-7-1(21) and 326 IAC 2-7-1(40). The renewal application does 

require the 

certification by the "responsible official" as defined by 326 IAC 2-7-

1(34). 

Request for renewal shall be submitted to: 

Indiana Department of Environmental Management 

Permit Administration and Support Section, Office of Air Quality 

100 North Senate Avenue 

MC 61-53 IGCN 1003 

Indianapolis, Indiana 46204-2251

(b) A timely renewal application is one that is: 

(1) Submitted at least nine (9) months prior to the date of the 

expiration of this permit; 

and 

(2) If the date postmarked on the envelope or certified mail receipt, or 

affixed by the 
shipper on the private shipping receipt, is on or before the date it is 

due. If the 

document is submitted by any other means, it shall be considered timely 

if received 

by IDEM, OAQ on or before the date it is due. 

(c) If the Permittee submits a timely and complete application for 

renewal of this permit, the 

source’s failure to have a permit is not a violation of 326 IAC 2-7 until 

IDEM, OAQ takes final 

action on the renewal application, except that this protection shall 

cease to apply if, 

subsequent to the completeness determination, the Permittee fails to 

submit by the deadline 

specified in writing by IDEM, OAQ any additional information identified 

as being needed to 

process the application. 

B.18 Permit Amendment or Modification [326 IAC 2-7-11] [326 IAC 2-7-12] 

[40 CFR 72] 

(a) Permit amendments and modifications are governed by the requirements 

of 326 IAC 2-7-11 

or 326 IAC 2-7-12 whenever the Permittee seeks to amend or modify this 

permit. 
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(b) Any application requesting an amendment or modification of this 

permit shall be submitted to: 

Indiana Department of Environmental Management 

Permit Administration and Support Section, Office of Air Quality 

100 North Senate Avenue 

MC 61-53 IGCN 1003 

Indianapolis, Indiana 46204-2251 

Any such application shall be certified by the "responsible official" as 

defined by 

326 IAC 2-7-1(34). 

(c) The Permittee may implement administrative amendment changes 

addressed in the request 

for an administrative amendment immediately upon submittal of the 

request. 

[326 IAC 2-7-11(c)(3)] 

B.19 Permit Revision Under Economic Incentives and Other Programs [326 

IAC 2-7-5(8)] 

[326 IAC 2-7-12(b)(2)] 

(a) No Part 70 permit revision shall be required under any approved 

economic incentives, 

marketable Part 70 permits, emissions trading, and other similar programs 

or processes for 

changes that are provided for in a Part 70 permit. 

(b) Notwithstanding 326 IAC 2-7-12(b)(1) and 326 IAC 2-7-12(c)(1), minor 

Part 70 permit 

modification procedures may be used for Part 70 modifications involving 

the use of economic 

incentives, marketable Part 70 permits, emissions trading, and other 

similar approaches to 

the extent that such minor Part 70 permit modification procedures are 

explicitly provided for 

in the applicable State Implementation Plan (SIP) or in applicable 

requirements promulgated 

or approved by the U.S. EPA. 

B.20 Operational Flexibility [326 IAC 2-7-20] [326 IAC 2-7-10.5] 

(a) The Permittee may make any change or changes at the source that are 

described in 

326 IAC 2-7-20(b),(c), or (e) without a prior permit revision, if each of 

the following conditions 

is met: 

(1) The changes are not modifications under any provision of Title I of 

the Clean Air Act; 

(2) Any preconstruction approval required by 326 IAC 2-7-10.5 has been 

obtained; 

(3) The changes do not result in emissions which exceed the limitations 

provided in this 

permit (whether expressed herein as a rate of emissions or in terms of 

total 

emissions); 

(4) The Permittee notifies the: 
Indiana Department of Environmental Management 

Permit Administration and Support Section, Office of Air Quality 

100 North Senate Avenue 

MC 61-53 IGCN 1003 

Indianapolis, Indiana 46204-2251 

and 
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Permit Reviewer: Dr. Trip Sinha 

United States Environmental Protection Agency, Region V 

Air and Radiation Division, Regulation Development Branch - Indiana (AR18J) 

77 West Jackson Boulevard 

Chicago, Illinois 60604-3590 

in advance of the change by written notification at least ten (10) days 

in advance of 

the proposed change. The Permittee shall attach every such notice to the 

Permittee's copy of this permit; and 

(5) The Permittee maintains records on-site, on a rolling five (5) year 

basis, which 

document all such changes and emission trades that are subject to 

326 IAC 2-7-20(b),(c), or (e). The Permittee shall make such records 

available, upon 

reasonable request, for public review. 

Such records shall consist of all information required to be submitted to 

IDEM, OAQ 

in the notices specified in 326 IAC 2-7-20(b)(1), (c)(1), and (e)(2). 

(b) The Permittee may make Section 502(b)(10) of the Clean Air Act 

changes (this term is 

defined at 326 IAC 2-7-1(36)) without a permit revision, subject to the 

constraint of 

326 IAC 2-7-20(a). For each such Section 502(b)(10) of the Clean Air Act 

change, the 

required written notification shall include the following: 

(1) A brief description of the change within the source; 

(2) The date on which the change will occur; 

(3) Any change in emissions; and 

(4) Any permit term or condition that is no longer applicable as a result 

of the change. 

The notification which shall be submitted is not considered an 

application form, report or 

compliance certification. Therefore, the notification by the Permittee 

does not require the 

certification by the ―responsible official‖ as defined by 326 IAC 2-7-

1(34). 

(c) Emission Trades [326 IAC 2-7-20(c)] 

The Permittee may trade emissions increases and decreases at the source, 

where the 

applicable SIP provides for such emission trades without requiring a 

permit revision, subject 

to the constraints of Section (a) of this condition and those in 326 IAC 

2-7-20(c). 

(d) Alternative Operating Scenarios [326 IAC 2-7-20(d)] 

The Permittee may make changes at the source within the range of 

alternative operating 

scenarios that are described in the terms and conditions of this permit 

in accordance with 

326 IAC 2-7-5(9). No prior notification of IDEM, OAQ, or U.S. EPA is 

required. 
(e) Backup fuel switches specifically addressed in, and limited under, 

Section D of this permit 

shall not be considered alternative operating scenarios. Therefore, the 

notification 

requirements of part (a) of this condition do not apply. 

(f) This condition does not apply to emission trades of SO2 or NOX under 

326 IAC 21 or 

326 IAC 10-4. 

B.21 Source Modification Requirement [326 IAC 2-7-10.5] 

A modification, construction, or reconstruction is governed by the 

requirements of 326 IAC 2. 

B.22 Inspection and Entry [326 IAC 2-7-6] [IC 13-14-2-2] [IC 13-30-3-1] 

[IC 13-17-3-2] 

Upon presentation of proper identification cards, credentials, and other 

documents as may be 

required by law, and subject to the Permittee’s right under all 

applicable laws and regulations to 
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assert that the information collected by the agency is confidential and 

entitled to be treated as such, 

the Permittee shall allow IDEM, OAQ, U.S. EPA, or an authorized 

representative to perform the 

following: 

(a) Enter upon the Permittee's premises where a Part 70 source is 

located, or emissions related 

activity is conducted, or where records must be kept under the conditions 

of this permit; 

(b) As authorized by the Clean Air Act, IC 13-14-2-2, IC 13-17-3-2, and 

IC 13-30-3-1, have 

access to and copy any records that must be kept under the conditions of 

this permit; 

(c) As authorized by the Clean Air Act, IC 13-14-2-2, IC 13-17-3-2, and 

IC 13-30-3-1, inspect any 

facilities, equipment (including monitoring and air pollution control 

equipment), practices, or 

operations regulated or required under this permit; 

(d) As authorized by the Clean Air Act, IC 13-14-2-2, IC 13-17-3-2, and 

IC 13-30-3-1, sample or 

monitor substances or parameters for the purpose of assuring compliance 

with this permit or 

applicable requirements; and 

(e) As authorized by the Clean Air Act, IC 13-14-2-2, IC 13-17-3-2, and 

IC 13-30-3-1, utilize any 

photographic, recording, testing, monitoring, or other equipment for the 

purpose of assuring 

compliance with this permit or applicable requirements. 

B.23 Transfer of Ownership or Operational Control [326 IAC 2-7-11] 

(a) The Permittee must comply with the requirements of 326 IAC 2-7-11 

whenever the Permittee 

seeks to change the ownership or operational control of the source and no 

other change in 

the permit is necessary. 

(b) Any application requesting a change in the ownership or operational 

control of the source 

shall contain a written agreement containing a specific date for transfer 

of permit 

responsibility, coverage and liability between the current and new 

Permittee. The application 

shall be submitted to: 

Indiana Department of Environmental Management 

Permit Administration and Support Section, Office of Air Quality 

100 North Senate Avenue 

MC 61-53 IGCN 1003 

Indianapolis, Indiana 46204-2251 

The application which shall be submitted by the Permittee does require 

the certification by 

the "responsible official" as defined by 326 IAC 2-7-1(34). 
(c) The Permittee may implement administrative amendment changes 

addressed in the request 

for an administrative amendment immediately upon submittal of the 

request. 

[326 IAC 2-7-11(c)(3)] 

B.24 Annual Fee Payment [326 IAC 2-7-19] [326 IAC 2-7-5(7)] [326 IAC 2-

1.1-7] 

(a) The Permittee shall pay annual fees to IDEM, OAQ within thirty (30) 

calendar days of receipt 

of a billing. Pursuant to 326 IAC 2-7-19(b), if the Permittee does not 

receive a bill from IDEM, 

OAQ the applicable fee is due April 1 of each year. 

(b) Except as provided in 326 IAC 2-7-19(e), failure to pay may result in 

administrative 

enforcement action or revocation of this permit. 

(c) The Permittee may call the following telephone numbers: 1-800-451-

6027 or 317-233-4230 

(ask for OAQ, Billing, Licensing, and Training Section), to determine the 

appropriate permit 

fee. 
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B.25 Credible Evidence [326 IAC 2-7-5(3)] [326 IAC 2-7-6] [62 FR 8314] 

[326 IAC 1-1-6] 

For the purpose of submitting compliance certifications or establishing 

whether or not the Permittee 

has violated or is in violation of any condition of this permit, nothing 

in this permit shall preclude the 

use, including the exclusive use, of any credible evidence or information 

relevant to whether the 

Permittee would have been in compliance with the condition of this permit 

if the appropriate 

performance or compliance test or procedure had been performed. 
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Permit Reviewer: Dr. Trip Sinha 

SECTION C SOURCE OPERATION CONDITIONS 

Entire Source 

Emission Limitations and Standards [326 IAC 2-7-5(1)] 

C.1 Particulate Emission Limitations for Processes with Process Weight 

Rates Less Than One Hundred 

(100) Pounds per Hour [326 IAC 6-3-2] 

Pursuant to 326 IAC 6-3-2(e)(2), particulate emissions from any process 

not exempt under 

326 IAC 6-3-1(b) or (c) which has a maximum process weight rate less than 

100 pounds per hour and 

the methods in 326 IAC 6-3-2(b) through (d) do not apply shall not exceed 

0.551 pounds per hour. 

C.2 Opacity [326 IAC 5-1] 

Pursuant to 326 IAC 5-1-2 (Opacity Limitations), except as provided in 

326 IAC 5-1-3 (Temporary 

Alternative Opacity Limitations), opacity shall meet the following, 

unless otherwise stated in this 

permit: 

(a) Opacity shall not exceed an average of forty percent (40%) in any one 

(1) six (6) minute 

averaging period as determined in 326 IAC 5-1-4. 

(b) Opacity shall not exceed sixty percent (60%) for more than a 

cumulative total of fifteen (15) 

minutes (sixty (60) readings as measured according to 40 CFR 60, Appendix 

A, Method 9 or 

fifteen (15) one (1) minute nonoverlapping integrated averages for a 

continuous opacity 

monitor) in a six (6) hour period. 

C.3 Open Burning [326 IAC 4-1] [IC 13-17-9] 

The Permittee shall not open burn any material except as provided in 326 

IAC 4-1-3, 326 IAC 4-1-4 

or 326 IAC 4-1-6. The previous sentence notwithstanding, the Permittee 

may open burn in 

accordance with an open burning approval issued by the Commissioner under 

326 IAC 4-1-4.1. 

C.4 Incineration [326 IAC 4-2] [326 IAC 9-1-2] 

The Permittee shall not operate an incinerator or incinerate any waste or 

refuse except as provided in 

326 IAC 4-2 and 326 IAC 9-1-2. This provision does not apply to 

incinerators used as pollutant 

control equipment to control process emissions. 

C.5 Fugitive Dust Emissions [326 IAC 6-4] 

The Permittee shall not allow fugitive dust to escape beyond the property 

line or boundaries of the 

property, right-of-way, or easement on which the source is located, in a 

manner that would violate 

326 IAC 6-4 (Fugitive Dust Emissions). 326 IAC 6-4-2(4) is not federally 

enforceable. 

C.6 Stack Height [326 IAC 1-7] 
The Permittee shall comply with the applicable provisions of 326 IAC 1-7 

(Stack Height Provisions), 

for all exhaust stacks through which a potential (before controls) of 

twenty-five (25) tons per year or 

more of particulate matter or sulfur dioxide is emitted. The provisions 

of 326 IAC 1-7-1(3), 

326 IAC 1-7-2, 326 IAC 1-7-3(c) and (d), 326 IAC 1-7-4, and 326 IAC 1-7-

5(a), (b), and (d) are not 

federally enforceable. 

C.7 Asbestos Abatement Projects [326 IAC 14-10] [326 IAC 18] [40 CFR 61, 

Subpart M] 

(a) Notification requirements apply to each owner or operator. If the 

combined amount of 

regulated asbestos containing material (RACM) to be stripped, removed or 

disturbed is at 

least 260 linear feet on pipes or 160 square feet on other facility 

components, or at least 

thirty-five (35) cubic feet on all facility components, then the 

notification requirements of 

326 IAC 14-10-3 are mandatory. All demolition projects require 

notification whether or not 

asbestos is present. 
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(b) The Permittee shall ensure that a written notification is sent on a 

form provided by the 

Commissioner at least ten (10) working days before asbestos stripping or 

removal work or 

before demolition begins, per 326 IAC 14-10-3, and shall update such 

notice as necessary, 

including, but not limited to the following: 

(1) When the amount of affected asbestos containing material increases or 

decreases 

by at least twenty percent (20%); or 

(2) If there is a change in the following: 

(A) Asbestos removal or demolition start date; 

(B) Removal or demolition contractor; or 

(C) Waste disposal site. 

(c) The Permittee shall ensure that the notice is postmarked or delivered 

according to the 

guidelines set forth in 326 IAC 14-10-3(2). 

(d) The notice to be submitted shall include the information enumerated 

in 326 IAC 14-10-3(3). 

All required notifications shall be submitted to: 

Indiana Department of Environmental Management 

Compliance and Enforcement Branch, Office of Air Quality 

100 North Senate Avenue 

MC 61-53 IGCN 1003 

Indianapolis, Indiana 46204-2251 

The notice shall include a signed certification from the owner or 

operator that the information 

provided in this notification is correct and that only Indiana licensed 

workers and project 

supervisors will be used to implement the asbestos removal project. The 

notifications do not 

require a certification by the "responsible official" as defined by 326 

IAC 2-7-1(34). 

(e) Procedures for Asbestos Emission Control 

The Permittee shall comply with the applicable emission control 

procedures in 

326 IAC 14-10-4 and 40 CFR 61.145(c). Per 326 IAC 14-10-1, emission 

control 

requirements are applicable for any removal or disturbance of RACM 

greater than three (3) 

linear feet on pipes or three (3) square feet on any other facility 

components or a total of at 

least 0.75 cubic feet on all facility components. 

(f) Demolition and Renovation 

The Permittee shall thoroughly inspect the affected facility or part of 

the facility where the 

demolition or renovation will occur for the presence of asbestos pursuant 

to 

40 CFR 61.145(a). 

(g) Indiana Accredited Asbestos Inspector 
The Permittee shall comply with 326 IAC 14-10-1(a) that requires the 

owner or operator, prior 

to a renovation/demolition, to use an Indiana Accredited Asbestos 

Inspector to thoroughly 

inspect the affected portion of the facility for the presence of 

asbestos. The requirement to 

use an Indiana Accredited Asbestos inspector is not federally 

enforceable. 

Testing Requirements [326 IAC 2-7-6(1)] 

C.8 Performance Testing [326 IAC 3-6] 

(a) All testing shall be performed according to the provisions of 326 IAC 

3-6 (Source Sampling 

Procedures), except as provided elsewhere in this permit, utilizing any 

applicable procedures 

and analysis methods specified in 40 CFR 51, 40 CFR 60, 40 CFR 61, 40 CFR

63, 
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40 CFR 75, or other procedures approved by IDEM, OAQ. 

A test protocol, except as provided elsewhere in this permit, shall be 

submitted to: 

Indiana Department of Environmental Management 

Compliance and Enforcement Branch, Office of Air Quality 

100 North Senate Avenue 

MC 61-53 IGCN 1003 

Indianapolis, Indiana 46204-2251 

no later than thirty-five (35) days prior to the intended test date. The 

protocol submitted by 

the Permittee does not require certification by the "responsible 

official" as defined by 

326 IAC 2-7-1(34). 

(b) The Permittee shall notify IDEM, OAQ of the actual test date at least 

fourteen (14) days prior 

to the actual test date. The notification submitted by the Permittee does 

not require 

certification by the "responsible official" as defined by 326 IAC 2-7-

1(34). 

(c) Pursuant to 326 IAC 3-6-4(b), all test reports must be received by 

IDEM, OAQ not later than 

forty-five (45) days after the completion of the testing. An extension 

may be granted by 

IDEM, OAQ if the Permittee submits to IDEM, OAQ, a reasonable written 

explanation not 

later than five (5) days prior to the end of the initial forty-five (45) 

day period. 

Compliance Requirements [326 IAC 2-1.1-11] 

C.9 Compliance Requirements [326 IAC 2-1.1-11] 

The commissioner may require stack testing, monitoring, or reporting at 

any time to assure 

compliance with all applicable requirements by issuing an order under 326 

IAC 2-1.1-11. Any 

monitoring or testing shall be performed in accordance with 326 IAC 3 or 

other methods approved by 

the commissioner or the U. S. EPA. 

Compliance Monitoring Requirements [326 IAC 2-7-5(1)] [326 IAC 2-7-6(1)] 

C.10 Compliance Monitoring [326 IAC 2-7-5(3)] [326 IAC 2-7-6(1)] 

Unless otherwise specified in this permit, all monitoring and record 

keeping requirements not already 

legally required shall be implemented within ninety (90) days of permit 

issuance. If required by 

Section D, the Permittee shall be responsible for installing any 

necessary equipment and initiating 

any required monitoring related to that equipment. If due to 

circumstances beyond its control, that 

equipment cannot be installed and operated within ninety (90) days, the 

Permittee may extend the 

compliance schedule related to the equipment for an additional ninety 

(90) days provided the 
Permittee notifies: 

Indiana Department of Environmental Management 

Compliance and Enforcement Branch, Office of Air Quality 

100 North Senate Avenue 

MC 61-53 IGCN 1003 

Indianapolis, Indiana 46204-2251 

in writing, prior to the end of the initial ninety (90) day compliance 

schedule, with full justification of 

the reasons for the inability to meet this date. 

The notification which shall be submitted by the Permittee does require 

the certification by the 

"responsible official" as defined by 326 IAC 2-7-1(34). 

Unless otherwise specified in the approval for the new emission unit(s), 

compliance monitoring for 

new emission units or emission units added through a source modification 

shall be implemented 

when operation begins. 
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C.11 Monitoring Methods [326 IAC 3] [40 CFR 60] [40 CFR 63] 

Any monitoring or testing required by Section D of this permit shall be 

performed according to the 

provisions of 326 IAC 3, 40 CFR 60, Appendix A, 40 CFR 60, Appendix B, 40 

CFR 63, or other 

approved methods as specified in this permit. 

C.12 Instrument Specifications [326 IAC 2-1.1-11] [326 IAC 2-7-5(3)] [326 

IAC 2-7-6(1)] 

(a) When required by any condition of this permit, an analog instrument 

used to measure a 

parameter related to the operation of an air pollution control device 

shall have a scale such 

that the expected maximum reading for the normal range shall be no less 

than twenty 

percent (20%) of full scale. 

(b) The Permittee may request that the IDEM, OAQ approve the use of an 

instrument that does 

not meet the above specifications provided the Permittee can demonstrate 

that an alternative 

instrument specification will adequately ensure compliance with permit 

conditions requiring 

the measurement of the parameters. 

Corrective Actions and Response Steps [326 IAC 2-7-5] [326 IAC 2-7-6] 

C.13 Emergency Reduction Plans [326 IAC 1-5-2] [326 IAC 1-5-3] 

Pursuant to 326 IAC 1-5-2 (Emergency Reduction Plans; Submission): 

(a) The Permittee prepared and submitted written emergency reduction 

plans (ERPs) consistent 

with safe operating procedures on May 20, 1997; and 

(b) Upon direct notification by IDEM, OAQ, that a specific air pollution 

episode level is in effect, 

the Permittee shall immediately put into effect the actions stipulated in 

the approved ERP for 

the appropriate episode level. [326 IAC 1-5-3] 

C.14 Risk Management Plan [326 IAC 2-7-5(12)] [40 CFR 68] 

If a regulated substance, as defined in 40 CFR 68, is present at a source 

in more than a threshold 

quantity, the Permittee must comply with the applicable requirements of 

40 CFR 68. 

C.15 Response to Excursions or Exceedances [326 IAC 2-7-5] [326 IAC 2-7-

6] 

(a) Upon detecting an excursion or exceedance, the Permittee shall 

restore operation of the 

emissions unit (including any control device and associated capture 

system) to its normal or 

usual manner of operation as expeditiously as practicable in accordance 

with good air 

pollution control practices for minimizing emissions. 

(b) The response shall include minimizing the period of any startup, 

shutdown or malfunction and 
taking any necessary corrective actions to restore normal operation and 

prevent the likely 

recurrence of the cause of an excursion or exceedance (other than those 

caused by excused 

startup or shutdown conditions). Corrective actions may include, but are 

not limited to, the 

following: 

(1) initial inspection and evaluation; 

(2) recording that operations returned to normal without operator action 

(such as through 

response by a computerized distribution control system); or 

(3) any necessary follow-up actions to return operation to within the 

indicator range, 

designated condition, or below the applicable emission limitation or 

standard, as 

applicable. 

(c) A determination of whether the Permittee has used acceptable 

procedures in response to an 

excursion or exceedance will be based on information available, which may 

include, but is 

not limited to, the following: 
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(1) monitoring results; 

(2) review of operation and maintenance procedures and records; and/or 

(3) inspection of the control device, associated capture system, and the 

process. 

(d) Failure to take reasonable response steps shall be considered a 

deviation from the permit. 

(e) The Permittee shall maintain the following records: 

(1) monitoring data; 

(2) monitor performance data, if applicable; and 

(3) corrective actions taken. 

C.16 Actions Related to Noncompliance Demonstrated by a Stack Test [326 

IAC 2-7-5] [326 IAC 2-7-6] 

(a) When the results of a stack test performed in conformance with 

Section C - Performance 

Testing, of this permit exceed the level specified in any condition of 

this permit, the Permittee 

shall take appropriate response actions. The Permittee shall submit a 

description of these 

response actions to IDEM, OAQ, within thirty (30) days of receipt of the 

test results. The 

Permittee shall take appropriate action to minimize excess emissions from 

the affected 

facility while the response actions are being implemented. 

(b) A retest to demonstrate compliance shall be performed within one 

hundred twenty (120) days 

of receipt of the original test results. Should the Permittee demonstrate 

to IDEM, OAQ that 

retesting in one hundred twenty (120) days is not practicable, IDEM, OAQ 

may extend the 

retesting deadline. 

(c) IDEM, OAQ reserves the authority to take any actions allowed under 

law in response to 

noncompliant stack tests. 

The response action documents submitted pursuant to this condition do 

require the certification by 

the "responsible official" as defined by 326 IAC 2-7-1(34). 

Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-

7-19] 

C.17 Emission Statement [326 IAC 2-7-5(3)(C)(iii)] [326 IAC 2-7-5(7)] 

[326 IAC 2-7-19(c)] [326 IAC 2-6] 

(a) Pursuant to 326 IAC 2-6-3(a)(1), the Permittee shall submit by July 1 

of each year an 

emission statement covering the previous calendar year. The emission 

statement shall 

contain, at a minimum, the information specified in 326 IAC 2-6-4(c) and 

shall meet the 

following requirements: 

(1) Indicate estimated actual emissions of all pollutants listed in 326 

IAC 2-6-4(a); 
(2) Indicate estimated actual emissions of regulated pollutants as 

defined by 

326 IAC 2-7-1 (32) (―Regulated pollutant, which is used only for purposes 

of Section 

19 of this rule‖) from the source, for purpose of fee assessment. 

The statement must be submitted to: 

Indiana Department of Environmental Management 

Technical Support and Modeling Section, Office of Air Quality 

100 North Senate Avenue 

MC 61-50 IGCN 1003 

Indianapolis, Indiana 46204-2251 
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The emission statement does require the certification by the ―responsible 

official‖ as defined

by 326 IAC 2-7-1(34). 

(b) The emission statement required by this permit shall be considered 

timely if the date 

postmarked on the envelope or certified mail receipt, or affixed by the 

shipper on the private 

shipping receipt, is on or before the date it is due. If the document is 

submitted by any other 

means, it shall be considered timely if received by IDEM, OAQ on or 

before the date it is due. 

C.18 General Record Keeping Requirements [326 IAC 2-7-5(3)] [326 IAC 2-7-

6] [326 IAC 2-2] 

[326 IAC 2-3] 

(a) Records of all required monitoring data, reports and support 

information required by this 

permit shall be retained for a period of at least five (5) years from the 

date of monitoring 

sample, measurement, report, or application. These records shall be 

physically present or 

electronically accessible at the source location for a minimum of three 

(3) years. The records 

may be stored elsewhere for the remaining two (2) years as long as they 

are available upon 

request. If the Commissioner makes a request for records to the 

Permittee, the Permittee 

shall furnish the records to the Commissioner within a reasonable time. 

(b) Unless otherwise specified in this permit, all record keeping 

requirements not already legally 

required shall be implemented within ninety (90) days of permit issuance 

or ninety (90) days 

of initial start-up, whichever is later. 

(c) If there is a reasonable possibility (as defined in 40 CFR 51.165 

(a)(6)(vi)(A), 40 CFR 51.165 

(a)(6)(vi)(B), 40 CFR 51.166 (r)(6)(vi)(a), and/or 40 CFR 51.166 

(r)(6)(vi)(b)) that a ―project‖ 

(as defined in 326 IAC 2-2-1(qq) and/or 326 IAC 2-3-1(ll)) at an existing 

emissions unit, other 

than projects at a source with a Plantwide Applicability Limitation 

(PAL), which is not part of a 

―major modification‖ (as defined in 326 IAC 2-2-1(ee) and/or 326 IAC 2-3-

1(z)) may result in 

significant emissions increase and the Permittee elects to utilize the 

―projected actual 

emissions‖ (as defined in 326 IAC 2-2-1(rr) and/or 326 IAC 2-3-1(mm)), 

the Permittee shall 

comply with following: 

(1) Before beginning actual construction of the ―project‖ (as defined in 

326 IAC 2-2-1(qq) 
and/or 326 IAC 2-3-1(ll)) at an existing emissions unit, document and 

maintain the 

following records: 

(A) A description of the project. 

(B) Identification of any emissions unit whose emissions of a regulated 

new 

source review pollutant could be affected by the project. 

(C) A description of the applicability test used to determine that the 

project is not 

a major modification for any regulated NSR pollutant, including: 

(i) Baseline actual emissions; 

(ii) Projected actual emissions; 

(iii) Amount of emissions excluded under section 

326 IAC 2-2-1(rr)(2)(A)(iii) and/or 326 IAC 2-3-1 (mm)(2)(A)(iii); and 

(iv) An explanation for why the amount was excluded, and any netting 

calculations, if applicable. 

(d) If there is a reasonable possibility (as defined in 40 CFR 51.165 

(a)(6)(vi)(A) and/or 40 CFR 

51.166 (r)(6)(vi)(a)) that a ―project‖ (as defined in 326 IAC 2-2-1(qq) 

and/or 326 IAC 2-3-1(ll)) 

at an existing emissions unit, other than projects at a source with a 

Plantwide Applicability 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 29 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

Limitation (PAL), which is not part of a ―major modification‖ (as defined 

in 326 IAC 2-2-1(ee) 

and/or 326 IAC 2-3-1(z)) may result in significant emissions increase and 

the Permittee 

elects to utilize the ―projected actual emissions‖ (as defined in 326 IAC 

2-2-1(rr) and/or 

326 IAC 2-3-1(mm)), the Permittee shall comply with following: 

(1) Monitor the emissions of any regulated NSR pollutant that could 

increase as a result 

of the project and that is emitted by any existing emissions unit 

identified in (1)(B) 

above; and 

(2) Calculate and maintain a record of the annual emissions, in tons per 

year on a 

calendar year basis, for a period of five (5) years following resumption 

of regular 

operations after the change, or for a period of ten (10) years following 

resumption of 

regular operations after the change if the project increases the design 

capacity of or 

the potential to emit that regulated NSR pollutant at the emissions unit. 

C.19 General Reporting Requirements [326 IAC 2-7-5(3)(C)] [326 IAC 2-1.1-

11] [326 IAC 2-2] 

[326 IAC 2-3] 

(a) The Permittee shall submit the attached Quarterly Deviation and 

Compliance Monitoring 

Report or its equivalent. Any deviation from permit requirements, the 

date(s) of each 

deviation, the cause of the deviation, and the response steps taken must 

be reported except 

that a deviation required to be reported pursuant to an applicable 

requirement that exists 

independent of this permit, shall be reported according to the schedule 

stated in the 

applicable requirement and does not need to be included in this report. 

This report shall be 

submitted within thirty (30) days of the end of the reporting period. The 

Quarterly Deviation 

and Compliance Monitoring Report shall include the certification by the 

"responsible official" 

as defined by 326 IAC 2-7-1(34). 

(b) The report required in (a) of this condition and reports required by 

conditions in Section D of 

this permit shall be submitted to: 

Indiana Department of Environmental Management 

Compliance and Enforcement Branch, Office of Air Quality 

100 North Senate Avenue 

MC 61-53 IGCN 1003 

Indianapolis, Indiana 46204-2251 
(c) Unless otherwise specified in this permit, any notice, report, or 

other submission required by 

this permit shall be considered timely if the date postmarked on the 

envelope or certified mail 

receipt, or affixed by the shipper on the private shipping receipt, is on 

or before the date it is 

due. If the document is submitted by any other means, it shall be 

considered timely if 

received by IDEM, OAQ on or before the date it is due. 

(d) Unless otherwise specified in this permit, all reports required in 

Section D of this permit shall 

be submitted within thirty (30) days of the end of the reporting period. 

All reports do require 

the certification by the "responsible official" as defined by 326 IAC 2-

7-1(34). 

(e) The first report shall cover the period commencing on the date of 

issuance of this permit and 

ending on the last day of the reporting period. Reporting periods are 

based on calendar 

years, unless otherwise specified in this permit. For the purpose of this 

permit ―calendar 

year‖ means the twelve (12) month period from January 1 to December 31 

inclusive. 

(f) If the Permittee is required to comply with the recordkeeping 

provisions of (d) in Section C –

General Record Keeping Requirements for any ―project‖ (as defined in 326 

IAC 2-2-1(qq) 

and/or 326 IAC 2-3-1(ll)) at an existing emissions unit, and the project 

meets the following 

criteria, then the Permittee shall submit a report to IDEM, OAQ: 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 30 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

(1) The annual emissions, in tons per year, from the project identified 

in (c)(1) in Section 

C – General Record Keeping Requirements exceed the baseline actual 

emissions, 

as documented and maintained under Section C – General Record Keeping 

Requirements (c)(1)(C)(i), by a significant amount, as defined in 326 IAC 

2-2-1(xx) 

and/or 326 IAC 2-3-1(qq), for that regulated NSR pollutant, and 

(2) The emissions differ from the preconstruction projection as 

documented and 

maintained under Section C – General Record Keeping Requirements 

(c)(1)(C)(ii). 

(g) The report for a project at an existing emissions unit other than 

Electric Utility Steam 

Generating Unit shall be submitted within sixty (60) days after the end 

of the year and contain 

the following: 

(1) The name, address, and telephone number of the major stationary 

source. 

(2) The annual emissions calculated in accordance with (d)(1) and (2) in 

Section C –

General Record Keeping Requirements. 

(3) The emissions calculated under the actual-to-projected actual test 

stated in 

326 IAC 2-2-2(d)(3) and/or 326 IAC 2-3-2(c)(3. 

(4) Any other information that the Permittee deems fit to include in this 

report, 

Reports required in this part shall be submitted to: 

Indiana Department of Environmental Management 

Compliance and Enforcement Branch, Office of Air Quality 

100 North Senate Avenue 

MC 61-53, IGCN 1003 

Indianapolis, Indiana 46204-2251 

(h) The Permittee shall make the information required to be documented 

and maintained in 

accordance with (c) in Section C- General Record Keeping Requirements 

available for 

review upon a request for inspection by IDEM, OAQ. The general public may 

request this 

information from the IDEM, OAQ under 326 IAC 17.1. 

Stratospheric Ozone Protection 

C.20 Compliance with 40 CFR 82 and 326 IAC 22-1 

Pursuant to 40 CFR 82 (Protection of Stratospheric Ozone), Subpart F, 

except as provided for motor 

vehicle air conditioners in Subpart B, the Permittee shall comply with 

the standards for recycling and 

emissions reduction: 

(a) Persons opening appliances for maintenance, service, repair, or 

disposal must comply with 

the required practices pursuant to 40 CFR 82.156. 
(b) Equipment used during the maintenance, service, repair, or disposal 

of appliances must 

comply with the standards for recycling and recovery equipment pursuant 

to 40 CFR 82.158. 

(c) Persons performing maintenance, service, repair, or disposal of 

appliances must be certified 

by an approved technician certification program pursuant to 40 CFR 

82.161. 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 31 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

SECTION D.1 ALUMINA & ALUMINUM FLUORIDE HANDLING SYSTEM 

FACILITY OPERATION CONDITIONS 

Facility Description [326 IAC 2-7-5(15)] 

(The information describing the process contained in this facility 

description box is descriptive information 

and does not constitute enforceable conditions.) 

Central Alumina and Aluminum Fluoride Handling System: 

(1) Two (2) barge unloading pneumatic conveyors transferring alumina and 

aluminum fluoride from 

barge, identified as Airveyor No. 1 and Airveyor No. 2, constructed in 

1968, with a maximum 

capacity of 200 tons per hour each, controlled by Airveyor No. 1 Baghouse 

and Airveyor No. 2 

Baghouse, respectively, and exhausting at Stacks 60.2 and 60.3, 

respectively. 

Two (2) baghouses, identified as Airveyor No. 1 Baghouse and Airveyor No. 

2 Baghouse, with an 

air flow rate of 8,400 acfm at 120oF each, and exhausting at Stacks 60.2 

and 60.3, respectively; 

(2) One (1) belt conveyor transferring alumina and aluminum fluoride from 

Airveyor No. 1 and 

Airveyor No. 2 to Transfer Tower 61A, identified as Airveyors Discharge 

Conveyor (Section 1), 

constructed in 1969, with a maximum capacity of 500 tons per hour, 

controlled by Building 60 

Baghouse, and exhausting at Stack 60.8. 

One (1) baghouse, identified as Building 60 Baghouse, controlling the 

Airveyors discharge onto 

the Airveyors Discharge Conveyor, with an airflow rate of 2,200 acfm at 

80oF, and exhausting at 

Stack 60.8; 

(3) One (1) Transfer Tower 61A, constructed in 1969, for transferring 

alumina and aluminum fluoride 

from the Airveyors Discharge Conveyor to Tank 62 Feed Conveyor (Section 

2), with a maximum 

capacity of 500 tons per hour, controlled by Transfer Tower 61A Baghouse, 

and exhausting at 

Stack 61A.1. 

One (1) transfer tower baghouse, identified as Transfer Tower 61A 

Baghouse, with an airflow rate 

of 3,500 acfm at 80oF, and exhausting at Stack 61A.1; 

(4) One (1) alumina/aluminum fluoride storage tank, identified as Tank 

62, constructed in 1969, with a 

maximum storage capacity of 1,800 tons and a transfer rate of 500 tons 

per hour. The Tank 62 

Feed Conveyor discharge into Tank 62 is controlled by Tank 62 Baghouse 

(top of tank), 

exhausting at Stack 62.1. The Tank 62 discharge to Transfer Tower 61B 

Feed Conveyor (Section 
3) occurs in an enclosed building. This transfer point does not exhaust 

to a baghouse. The 112A 

Passageway Conveyor is controlled by BC-24 Baghouse (Tank 62 baghouse, 

ground level), 

exhausting at Stack 62.2. 

Two (2) alumina/aluminum fluoride Tank 62 baghouses, identified as Tank 

62 Baghouse (top of 

tank) and Baghouse BC-24 (Tank 62 baghouse, ground level), with maximum 

gas flow rates of 

3,000 and 710 acfm at 700F, respectively, and exhausting at Stacks 62.1 

and 62.2, respectively; 

Potlines 1 and 2 Alumina and Alumina Fluoride Handling System: 

(5) One (1) belt conveyor transferring alumina and aluminum fluoride from 

Tank 62 to Transfer Tower 

61B, identified as Transfer Tower 61B Feed Conveyor, constructed in 1969, 

with a maximum 

capacity of 275 tons per hour. This transfer point is contained within a 

building and does not 

exhaust to a baghouse; 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 32 of 178

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

(6) One (1) Transfer Tower 61B transferring alumina and aluminum fluoride 

from the Transfer Tower 

61B Feed Conveyor to 104 passageway Conveyor, constructed in 1969, with a 

maximum capacity 

of 275 tons per hour, with the feed and discharge points into/out of 

Transfer Tower 61B controlled 

by Transfer Tower 61B Baghouse, and exhausting at Stack 61B.1; 

(7) One (1) railcar/truck unloading system transferring alumina and 

aluminum fluoride to 104 

Passageway Conveyor, identified as Building 140 Unloading, constructed in 

1958, with a 

maximum capacity of 275 tons per hour, controlled by Building 140 

Baghouse, and exhausting at 

Stack 140.1. 

One (1) baghouse, identified as Building 140 Baghouse, with an airflow 

rate of 1,000 acfm at 700F, 

and exhausting at Stack 140.1; 

(8) One (1) belt conveyor transferring alumina and aluminum fluoride from 

either the railcar/truck 

unloading system or 61B Transfer Tower to Bucket Elevators 141A and/or 

141B, identified as 104 

Passageway Conveyor, constructed in 1969, with a maximum capacity of 280 

tons per hour, 

controlled by 104A Passageway Baghouse, and exhausting at Stack 104.1. 

One (1) baghouse, identified as 104A Passageway Baghouse, with an airflow 

rate of 10,000 acfm 

at 700F, and exhausting at Stack 104.1; 

(9) Two (2) bucket elevators transferring alumina and aluminum fluoride 

from 104 Passageway 

Conveyor to the Tank 144 feed airslide (Airslide 141) or the #8 screw 

conveyor, identified as 

Bucket Elevator 141A and Bucket Elevator 141B, each constructed in 1969, 

with a maximum 

capacity of 100 tons per hour each, controlled by 104A Passageway 

Baghouse at their inlet and 

the 144A Baghouse at their outlet, and exhausting at Stacks 104.1 and 

144.1; 

(10) One (1) Tank 144 feed airslide (Airslide 141) transferring alumina 

from Bucket Elevator 141A and 

Bucket Elevator 141B to Tanks 141BN, 141 BS, 141 CN, 141 CS, 141NE, 

141NW, and 144, 

constructed in 1969, with a capacity of 240 tons per hour. All transfer 

points except those into 

tanks 141NE and 141NW are, controlled by 144A Baghouse, and exhausting at 

Stack 144.1. The 

transfer point into tank 141NE is controlled by the 141ANE baghouse, and 

the transfer point into 

tank 141NW is controlled by the 141ANW baghouse. 

One (1) baghouse, identified as 144A Baghouse, with an airflow of 14,800 

acfm at 700F, and 
exhausting at Stack 144A.1. 

One (1) baghouse, identified as the Tank 141NE Baghouse, with an airflow 

of 3,500 acfm at 700F, 

and exhausting at Stack 141.1NE, 

One (1) baghouse, identified as the Tank 141NW Baghouse, with an airflow 

of 3,500 acfm at 700F, 

and exhausting at Stack 141.1NW; 

(11) One (1) tank transferring alumina to fresh alumina Tanks 160M.1 and 

160M.2, identified as Tank 

144, constructed in 1956, with a maximum storage capacity of 2,235 tons 

and a transfer rate of 

240 tons per hour, controlled by 144A Baghouse, and exhausting at Stack 

144.1; 

(12) One (1) tank transferring alumina to reacted alumina Tank 141A(NE), 

identified as Tank 141BS, 

constructed in 1969, with a maximum storage capacity of 300 tons and a 

discharge rate of 5 tons 

per hour, controlled by 144A Baghouse, and exhausting at Stack 144.1; 

(13) One (1) #8 Screw Conveyor transferring aluminum fluoride and alumina 

from Bucket Elevator 

141A and Bucket Elevator 141B to Tanks 141CN, 141CS, 141D, 141E, and 

141F, constructed in 

1969, with a maximum conveying rate of 200 tons per hour, controlled by 

144A Baghouse, and 

exhausting at Stack 144.1; 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

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Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

(14) Seven (7) tanks, identified as Tanks 141BN, 141BS, 141CN, 141CS, 

141D, 141E, and 141F, 

constructed in 1969, with a maximum capacity of 985 tons each, 144A 

Baghouse, and exhausting 

at Stack 144.1; 

(15) Tank 160M.2 Feed Convair, pneumatically feeding fresh alumina from 

Tank 144 to Tank 160M.2, 

with a capacity of 18 tons per hour, constructed in 1956, controlled by 

the 160M.2 Bin Vent 

Baghouse, and exhausting at Stack 160M.2. 

One (1) baghouse, identified as 160M.2 Bin Vent Baghouse, with an airflow 

rate of 3,000 acfm at 

700F, and exhausting at Stack 160M.2; 

(16) One (1) fresh alumina tank for the supply of alumina to the Potline 

#1 B2 fluidized bed dry 

scrubber and baghouse, identified as Tank 160M.2, constructed in 1956, 

with a maximum 

capacity of 650 tons, controlled by the 160M.2 Bin Vent Baghouse, and 

exhausting at Stack 

160M.2; 

(17) One (1) distribution box and airslide transferring fresh alumina 

from Tank 160M.2 to fluidized bed 

scrubber and B2 Baghouse, identified as the Alumina Feed Airslide B2, 

constructed in 1956, with 

a maximum capacity of 18 tons per hour, controlled by the Airslide B2 

Baghouse, and exhausting 

at Stack 160B2.16. 

One (1) baghouse, identified as Airslide B2 Baghouse, with an airflow 

rate of 750 acfm at a 

temperature 700F, and exhausting at Stack 160B2.16; 

(18) One (1) Tank 160M.1 pneumatic conveyor feeding fresh alumina from 

Tank 144 to Tank 160M.1, 

constructed in 1962, with a capacity of 18 tons per hour, controlled by 

Potline #2 C1 Pollution 

Control System, and exhausting at Stacks 160C.1 through 160C.37. 

One fluidized bed dry scrubber and baghouse system consisting of twelve 

(12) fluidized dry 

scrubbers and baghouses, identified as the Potline #2 C1 Pollution 

Control System, with a total 

gas flow rate of 480,000 acfm at 2000F, and exhausting at Stacks 160C.1 -

160C.36; 

(19) One (1) fresh alumina tank for the supply of alumina to the Potline 

#2 C1 fluidized bed dry 

scrubber and baghouse, identified as Tank 160M.1, with a capacity of 650 

tons, constructed in 

1962, controlled by Potline #2 C1 Pollution Control System, and 

exhausting at Stacks 160C.1 

through 160C.36; 

(20) One (1) distribution box, constructed in 1962, and vibratory screen 

and airslide transferring fresh 
alumina to fluidized bed scrubber and Baghouse C1, identified as the 

Alumina Vibratory Screen 

and C1 East and C1 West Feed Airslide , constructed in 2008 , with a 

capacity of 18 tons per 

hour, controlled by the vibratory screen and C1 east and C1 west 

Airslides vibratory screen and 

C1 east and C1 west airslide bin vents #1, #2, #3, and #4, and exhausting 

at Stacks 160C1.37-1, 

160C1.37-2, 160C1.37-3, and 160C1.37-4. 

4 bin vents, identified as the vibratory screen and C1 east and C1 west 

Airslide bin vents, each 

with an airflow rate of 250 acfm at a temperature 120 0F , and exhausting 

at Stacks 160C.37-1, 

160C.37-2, 160C.37-3, and 160C.37-4. 

(21) One (1) reacted alumina airslides transporting reacted alumina from 

the C1 and B2 Pollution 

Control Systems to Tank 141A(NE), identified as Reacted Alumina Airslide 

C1, constructed in 

1962, with a maximum capacity of 18 tons per hour each, controlled by 

Tank 141A(NE) 

Baghouse, and exhausting at Stack 141.1(NE); 

(21A) One (1) reacted alumina airslides transporting reacted alumina from 

the B2 Pollution Control 

Systems to Tank 141A(NW), identified as Reacted Alumina AirslideB2, 

constructed in 1956, with a 

maximum capacity of 18 tons per hour, controlled by the Tank 141A(NW) 

Baghouse, and 

exhausting at Stack 141.1(NW). 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 34 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

(22) One (1) reacted alumina eductor transporting reacted alumina from 

Tank 141BS to Tank 

141A(NE), identified as Tank 141 BS Eductor, constructed in 1984, with a 

maximum capacity of 5 

tons per hour, controlled by Tank 141A(NE) Baghouse, and exhausting at 

Stack 141.1(NE); 

(23) One (1) reacted alumina storage tank, identified as Tank 141A(NE), 

constructed in 1964, with a 

maximum capacity of 860 tons, controlled by Tank 141A(NE) Baghouse at its 

inlet and 104A 

Baghouse at its discharge, and exhausting at Stacks 141.1(NE) and 104.1; 

(23A) One (1) reacted alumina storage tank, identified as Tank 141A(NW), 

constructed in 1964, with a 

maximum capacity of 860 tons, controlled by Tank 141A(NW) Baghouse at its 

inlet and 104A 

Baghouse at its discharge, and exhausting at Stacks 141.1(NW) and 104.1; 

Potlines 3, 4, 5, and 6 Alumina and Aluminum Fluoride Handling System: 

(24) One (1) belt conveyor transferring alumina and aluminum fluoride 

from Tank 62 to Airlift 

150-FM-AE-01 and Airlift 150-FM-AE-02, identified as 112A Passageway 

Conveyor, constructed 

in 1969, with a maximum capacity of 275 tons per hour, controlled by 112A 

Passageway 

Baghouse, and exhausting at Stack 112A.1. 

One (1) baghouse, identified as Baghouse 112A, with an airflow rate of 

26,900 acfm at 700F, and 

exhausting at Stack 112A.1; 

(24A) One (1) belt conveyor transferring alumina and aluminum fluoride 

from Tank 152 to Airlift 

150-FM-AE-01 and Airlift 150-FM-AE-02, identified as BC26 Conveyor, 

constructed in 1969, with 

a maximum capacity of 275 tons per hour, controlled by 112A Passageway 

Baghouse, and 

exhausting at Stack 112A.1; 

(25) Airlift 150-FM-AE-01 and Airlift 150-FM-AE-02, transferring alumina 

and aluminum fluoride from 

the 112A Passageway Conveyor or the BC26 conveyor to Airslide151, 

constructed in 2000, with 

a maximum capacity of 100 tons per hour each, controlled by 112A 

Passageway Baghouse, and 

exhausting at Stack 112A.1; 

(26) Airslide 151, transferring alumina from Airlifts 150-FM-AE-01 and 

150-FM-AE-02 to Tank 151C, 

Tank 151J, Tank 152, and Tank 154; and aluminum fluoride from Airlift 

150-FM-AE-01 and Airlift 

150-FM-AE-02 to Tank 151F and Tank 151G and to atmosphere constructed in 

1969, with a 

maximum capacity of 225 tons per hour, controlled by Baghouse 112A, and 

exhausting at Stack 

112A.1; 
(27) One (1) aluminum fluoride tank, identified as Tank 151F, constructed 

in 1970, with a maximum 

storage capacity of 850 tons, fed from Airslide 151, and venting to Tank 

151G and to atmosphere; 

(28) One (1) aluminum fluoride tank, identified as Tank 151G, constructed 

in 1970, with a maximum 

storage capacity of 850 tons, fed from Airslide 151, and venting to 

atmosphere; 

(29) One (1) fresh alumina tank, identified as Tank 151C, constructed in 

1969, with a capacity of 985 

tons, and venting to Tank 152. This tank supplies alumina for the anode 

baking ring furnace A-446 

pollution control system and the bath crusher if needed; 

(30) One (1) fresh alumina tank, identified as Tank 151J, fed from 

Airslide 151, constructed in 1969, 

with a maximum storage capacity of 113 tons, venting to Tank 151. This 

tank supplies alumina for 

the anode baking ring furnace A-446 pollution control system; 

(31) One (1) fresh alumina tank, identified as Tank 152, fed from 

Airslide 151, constructed in 1969, 

with a maximum storage capacity of 25,000 tons, and venting to the B5 or 

B6 Pollution control 

system feed airslide baghouses. This tank serves as an emergency supply 

point for alumina. 

Withdrawals from this tank occur via the BC26 Belt Conveyor; 

(32) Feed box B5 and Pollution Control System Alumina Feed Airslide B5, 

transporting alumina from 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 35 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

Tank 154 to the B5 Pollution Control System, constructed in 1969, with a 

maximum capacity of 18 

tons per hour, controlled by Airslide B5 or B6 Baghouse, and exhausting 

at Stack 161.B5.37. 

One (1) baghouse, identified as Airslide B5 Baghouse, with an airflow 

rate of 4,600 acfm at a 

temperature 70oF, and exhausting at Stack 161B5.37; 

(33) Feed box B6 and Pollution Control System Alumina Feed Airslide B6, 

transporting alumina from 

Tank 154 to the B6 Pollution Control System, constructed in 1969, with a 

capacity of 18 tons per 

hour, controlled by Airslide B5 or B6 Baghouse, and exhausting at Stack 

161.B6.37. 

One (1) baghouse, identified as Airslide B6 Baghouse, with an airflow 

rate of 4,600 acfm at a 

temperature 70oF, and exhausting at Stack 161B6.37; 

(34) One (1) fresh alumina tank, identified as Tank 154, fed from 

Airslide 151, feeding to: 

(A) Potline #5 pollution control system, Feed Box B5; 

(B) Potline #6 pollution control system, Feed Box B6; 

(C) Vibratory Screen and GTC Feed Airslide 161-B3-FM-01; and 

(D) Vibratory Screen and GTC Feed Airslide 161-B4-FM-01. 

Tank 154 was constructed in 1969, and has a capacity of 1,200 tons. It is 

controlled by Airslide B5 

Baghouse or Airslide B6 Baghouse, and exhausts at Stacks 161.B5.37 or 

161.B6.37; 

(35) Vibratory Screen and GTC Feed Airslide 161-B3-FM-01, and Vibratory 

Screen and GTC Feed 

Airslide 161-B4-FM-01, transporting fresh alumina from Tank 154 to 

Potlines 3 and 4 Gas 

Treatment Center (GTC) for fluoride control, constructed in 2000, with a 

maximum capacity of 80 

tons per hour each, controlled by Gas Treatment Center (GTC), and 

exhausting at Stack GTC; 

(36) Transfer of reacted alumina from the Potlines 3 and 4 Gas Treatment 

Center (GTC) for fluoride 

control to reacted alumina Airslide 166-FM-03 via: 

(A) Airslide 161B3-FM-03 to Airlift 161B3-AE-01 or Airlift 161B4-AE-02 to 

Vibratory Screen 

161B3-SC-02 or vibratory screen 161B4-SC-02; 

(B) Airslide 166-FM-02. 

Maximum capacity for the equipment described by (A.) is 30 tons per hour 

each, Maximum 

capacity for Airslide 166-FM-02 and Airslide 166-FM-03 is 60 tons per 

hour. All of the airslides, 

airlifts, and vibratory screens described herein, except for airslides 

165-FM-02 and 166-FM-03 are 

controlled by the GTC, exhausting at Stack GTC. Airslides 166-FM-02 and 

166-FM-03 are 
controlled by Baghouse 166, exhausting at Stack 166.1. All of the 

equipment described herein was 

constructed in 2000. 

One (1) baghouse, identified as Baghouse 166, with an airflow rate of 

7,000 standard dry cubic 

foot at 700F, and exhausting at Stack 166.1; 

(37) Transfer of reacted alumina from Potline #6 B6 Pollution Control 

System for fluoride control to 

Airslide 166-FM-03 via Airslide 161-B6-FM-01 to Airlift 166-B6-FM-AE-01, 

thence to Vibratory 

Screen 166-B6-FM-SC-01, and thence to Airslide 166-FM-03. All of this 

equipment except for 

Airslide 166-FM-03 has a maximum capacity of 20 tons per hour, was 

constructed in 2000, and is 

controlled by Baghouse 166, exhausting at Stack 166.1; 

(38) Transfer of reacted alumina from the Potline #5 B5 pollution control 

system for fluoride control to 

reacted alumina Airslide 161-B5-FM-01, thence to Airlift 161-B5-FM-AE-01, 

thence to Vibratory 

Screen 61-B5-FM-SC-01, thence to the feedbox for Airslide 166-FM-05 and 

Airslide 166-FM-06. 
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Permit Reviewer: Dr. Trip Sinha 

All of this equipment except for the feedbox for Airslide 166-FM-05 and 

Airslide 166-FM-06 has a 

maximum capacity of 20 tons per hour, was constructed in 2000, and is 

controlled by the 

Baghouse 166, exhausting at Stack 166.1; 

(39) Feedbox for Airslide 166-FM-05 and Airslide 166-FM-06, transferring 

reacted alumina from the 

GTC, B5, and B6 pollution control systems to Airslide 166-FM-05 and 

Airslide 166-FM-06. This 

feedbox was constructed in 2000, has a maximum capacity of 80 tons per 

hour, and is controlled 

by Baghouse 166, exhausting at Stack 166.1; 

(40) Airslide 166-FM-05, transferring reacted alumina from the feedbox 

for Airslide 166-FM-05 and 

Airslide 166-FM-06 to Airlift 166-AE-01, constructed in 2000, with a 

maximum capacity of 80 tons 

per hour, and controlled by Baghouse 166, exhausting at Stack 166.1; 

(41) Airslide 166-FM-06, transferring reacted alumina from the feedbox 

for Airslide 166-FM-05 and 

Airslide 166-FM-06 to Airlift 166-AE-02, constructed in 2000, with a 

maximum capacity of 80 tons 

per hour, and controlled by Baghouse 166, exhausting at Stack 166.1; 

(42) Airlift 166-AE-02, transferring reacted alumina from Airslide 166-

FM-06 to reacted alumina Airslide 

166-FM-07, constructed in 2000, with a maximum capacity of 80 tons per 

hour, and controlled by 

Baghouse 166, exhausting at Stack 166.1; 

(43) Airlift 166-AE-01, transferring reacted alumina from Airslide 166-

FM-05 to reacted alumina Airslide 

166-FM-07, constructed in 2000, with a maximum capacity of 80 tons per 

hour, and controlled by 

Baghouse 166, exhausting at Stack 166.1; 

(44) Transfer of reacted alumina from Airlift 166-AE-01 and Airlift 166-

AE-02 to Airslide 166-FM-07. 

Airslide 166-FM-07 has a maximum capacity of 80 tons per hour, was 

constructed in 2000, and is 

controlled by Baghouse 166, exhausting at Stack 166.1; 

(45) Unloading Station BL-08, accepting reacted alumina that has been 

trucked from Anode Baking 

Ring Furnace A-446 Pollution Control System, and transferring it to Tank 

151H. Unloading Station 

BL-08 has a maximum capacity of 40 tons per hour, and is controlled by 

Baghouse 112A, 

exhausting at Stack 112A.1; 

(46) One (1) reacted alumina storage tank, identified as Tank 151H, fed 

from Unloading Station BL-08, 

constructed in 1969,with a maximum capacity of 655 tons, controlled by 

Baghouse 112A, 

exhausting at Stack 112A.1; 
(47) Dense Phase Transporter VS-01, transporting reacted alumina from 

Tank 151H to Feed Box 

166-FM-08. Dense Phase Transporter VS-01 was constructed in 2000, has a 

maximum capacity 

of 7 tons per hour, and is controlled by Baghouse 112A, exhausting at 

Stack 112A.1; 

(48) Feed box 166-FM-08, transferring reacted alumina from Dense Phase 

Transporter VS-01 and 

Airslide 166-FM-07, constructed in 2000, with a maximum capacity of 87 

tons per hour, controlled 

by Baghouse 112A, and exhausting at Stack 112A.1; 

(49) Airslide 166-FM-09, transferring reacted alumina from Feed Box 166-

FM-08 to Tank 151A 

Distribution Box 151-FM-1A, constructed in 2000, with a capacity of 87 

tons per hour, controlled 

by Baghouse 112A, and exhausting at Stack 112A.1; 

(50) Tank 151A Distribution Box 151-FM-1A, transferring reacted alumina 

from Airslide 166-FM-09 to 

Tank 151A, constructed in 2000, with a capacity of 87 tons per hour, 

controlled by 

Baghouse112A, and exhausting at Stack 112A.1; 

(51) Airslide 166-FM-10, transferring reacted alumina from Feed Box 166-

FM-08 to Tank 151B 

Distribution Box 151-FM-1B, constructed in 2000, with a capacity of 87 

tons per hour, controlled 
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Permit Reviewer: Dr. Trip Sinha 

by Baghouse 112A, and exhausting at Stack 112A.1; 

(52) Tank 151B Distribution Box 151-FM-1B, transferring reacted alumina 

from Airslide 166-FM-10 to 

Tank 151B, constructed in 2000, with a capacity of 87 tons per hour, 

controlled by Baghouse 

112A, and exhausting at Stack 112A.1; and 

(53) Tanks 151A and 151B, transferring reacted alumina to Potlines 3-6, 

with a storage capacity of 985 

tons each, constructed in 1969, the discharge from each tank controlled 

by Baghouse 112A, and 

exhausting at Stack 112A.1. 

Emission Limitations and Standards [326 IAC 2-7-5(1)] 

D.1.1 Particulate Emissions Limitations for Manufacturing Processes [326 

IAC 6-3-2] 

Pursuant to 326 IAC 6-3 (Particulate Emissions Limitations for 

Manufacturing Processes), the 

allowable PM emission rate from the below listed processes shall be 

limited as follows: 

Facility Control Device 

Maximum 

Process 

Weight 

Rate 

(tons/hr) 

PM 

Emission 

Limit 

(lbs/hr) 

Air Conveyors No. 1 Airveyor No. 1 Baghouse 200 58.5 

Air Conveyors No. 2 Airveyor No. 2 Baghouse 200 58.5 

Airveyor Discharge Conveyor Building 60 Baghouse 500 69 

Transfer Tower 61A Transfer Tower 61A 

Baghouse 

500 69 

Tank 62 loading Tank 62 Baghouse 

(Tank 62 baghouse, top of 

tank) 

500 69 

Tank 62 unloading Baghouse BC-24 (Tank 62 

baghouse, ground level) 

275 62.02 

Transfer Tower 61B Transfer Tower 61B 

Baghouse 

275 62.02 

Building 140 Unloading Building 140 Baghouse 275 62.02 

104 Passageway Conveyor, and 

Bucket Elevator 141A and Bucket 

Elevator 141B 

104A Passageway 

Baghouse 
275 62.02 

Airslide 141, Tank 144, Tank 

141BN, Tank 141BS, Tank 141CN, 

Tank 141CS, Tank 141D, Tank 

141E, Tank 141F, and #8 Screw 

Conveyor 

Tank 144A Baghouse 240 60.5 

Tank 160M.1 Potline #2 C1 Pollution 

Control System 

18 28.4 

Tank 160M.1 Feed Pneumatic 

Conveyor 

18 28.4 

Tank 160M.2 Tank 160M.2 Bin Vent 

Baghouse 

18 28.4 

Tank 160M.2 Pneumatic Conveyor Tank 160M.2 Bin Vent 

Baghouse 

18 28.4 

Alumina Feed Airslide B2 Airslide B2 Baghouse 18 28.4 

Alumina Feed Vibratory Screen and 

C1 east and C1 west Airslides 

Vibratory screen and C1 east 

and C1 west Airslide Bin 

Vents #1, #2, #3, and #4 

18 28.4 

Reacted Alumina Airslide B2 Tank 141A(NW) Baghouse 18 28.4 

Reacted Alumina Airslide C1 Tank 141A(NE) Baghouse 18 28.4 

Tank 141(NE) System Tank 141A (NE) Baghouse 18 28.4 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

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Permit Reviewer: Dr. Trip Sinha 

Facility Control Device 

Maximum 

Process 

Weight 

Rate 

(tons/hr) 

PM 

Emission 

Limit 

(lbs/hr) 

Tank 141(NW) System Tank 141A (NW) Baghouse 18 28.4 

Tank 141 BS Eductor Tank 141A (NE) Baghouse 5 12 

Equipment controlled by Baghouse112A 

(1) 112A Passageway Conveyor 

Baghouse112A 402 66.37 

(2) Airlift 150-FM-AE01 

(3) Airlift 150-FM-AE02 

(4) Airslide 151 

(5) Tank 151H 

(6) Unloading Station BL-08 

(7) Dense Phase Transporter VS-01 

(8) Feed Box 166-FM-08 

(9) Airslide 166-FM-09 

(10) Tank 151A Distribution Box 

151-FM-1A 

(11) Airslide 166-FM-10 

(12) Tank 151B Distribution Box 

151-FM-1B 

(13) Tanks 151A and 151B 

Tank 151F Loading Uncontrolled 225 59.79 

Tank 151G Loading Uncontrolled 225 59.79 

Tank 151C, Tank 151J, Tank 152, 

Tank 154, Feed Box B5 and 

Pollution Control System Alumina 

Feed Airslide B5 and Polllution 

Control System Alumina Feed 

Airslide B6 

Airslide B5 or B6 Baghouse 243 60.54 

Equipment controlled by the Gas Treatment Center (GTC) 

(1) Vibratory Screen and GTC Feed 

Airslide 161-B3-FM-01 

GTC 

60 

46.29 

(2) Vibratory Screen and GTC Feed 

Airslide 161-B4-FM-01 

(3) GTC Reacted Alumina 

161B3-FM-03 Airslide 

(4) GTC Reacted Alumina 

161B3-AE-02 Airlift 
(5) GTC Reacted Alumina 

161B4-AE-02 Airlift 

(6) GTC Reacted Alumina 

161B4-SC-02 Vibratory Screen 

(7) GTC Reacted Alumina 

161B3-SC-02 Vibratory Screen 

Equipment controlled by Baghouse 166 

(1) Airslide 166-FM-01 

Baghouse 166 100 51.3 

(2) Airslide 166-FM-02 

(3) Airslide 161-B6-FM-01 

(4) Airlift 166-B6-FM-AE-01, 

(5) Vibratory Screen 

166-B6-FM-SC-01 

(6) Airslide 166-FM-03; 

(7) Airslide 161-B5-FM-01 

(8) Airlift 166-B5-FM-AE-01, 
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Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

Facility Control Device 

Maximum 

Process 

Weight 

Rate 

(tons/hr) 

PM 

Emission 

Limit 

(lbs/hr) 

(9) Vibratory Screen 

166-B5-FM-SC-01 

(10) Feedbox for Airslide 165-FM-05 

and Airslide 166-FM-06 

(11) Airslide 166-FM-05 

(12) Airslide 166-FM-06 

(13) Airlift 166-AE-02 

(14) Airlift 166-AE-01 

(15) Airslide 166-FM-07 

The above particulate emissions rates were determined from the following 

formulae: 

Interpolation of the data for the process weight rate up to sixty 

thousand (60,000) pounds per hour by 

use of the equation: 

E = 4.10 P0.67 

where: E = rate of emission in pounds per hour; and 

P = process weight rate in tons per hour. 

or 

Interpolation and extrapolation of the data for the process weight rate 

in excess of sixty thousand 

(60,000) pounds per hour by use of the equation: 

E = 55.0 P0.11 - 40 

where: E = rate of emission in pounds per hour; and 

P = process weight rate in tons per hour. 

When the process rate exceeds two hundred (200) tons per hour, the 

allowable emission may exceed 

the emission limits shown in the above table; provided the concentration 

of particulate in the 

discharge gases to the atmosphere is less than one-tenth (0.10) pound per 

thousand (1,000) pounds 

of gases. 

D.1.2 PSD Minor Limit [326 IAC 2-2] 

Pursuant to 326 IAC 2-2 and SSM 173-18836-00007, issued on February 25, 

2005, the combined PM 

and PM10 emissions from Baghouse 112A and Baghouse 116 shall be less than 

5.7 and 3.4 pounds 

per hour, respectively. Compliance with these emissions limits shall 

ensure that the potential PM and 

PM10 emissions from the emissions units associated with Baghouse 112A and 

Baghouse 166 shall 
be less than 25 and 15 tons per year, respectively, which renders the 

requirements of PSD rule 

326 IAC 2-2 not applicable. 

Compliance Determination Requirements 

D.1.3 Particulate Control [326 IAC 2-7-6(6)] 

(a) In order to comply with Condition D.1.1, the PM emissions from the 

following facilities shall 

be controlled by the baghouses as indicated in the table below. Each 

baghouse shall be in 

operation and control emissions from its associated facility at all times 

when a facility that the 

baghouse controls is in operation. 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

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Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

Facility Baghouse 

Airveyor No. 1 Airveyor No. 1 Baghouse 

Airveyor No. 2 Airveyor No. 2 Baghouse 

Airveyor Discharge Conveyor Building 60 Baghouse 

Airveyor Discharge Conveyor 

discharge to Tank 62 Feed conveyor 

Transfer Tower 61A 

Baghouse 

Tank 62 Feed conveyor discharge to 

Tank 62 Tank 62 Baghouse 

Tank 62 discharge point to 

Passageway 112A Feed Conveyor Baghouse BC-24 

Transfer Tower 61B Transfer Tower 61B 

Baghouse 

Building 140 Unloading Building 140 Baghouse 

104 Passageway Conveyor, and 

Bucket Elevator 141A and 

Bucket Elevator 141B 

104A Passageway 

Baghouse 

Airslide 141,Tank 144, Tank 141BN, 

Tank141BS, Tank 141CN, Tank 

141CS, Tank 141D, Tank 141E, 

Tank 141F, and #8 Screw Conveyor 

144A Baghouse 

Tank 160M.2 Feed Pneumatic 

Conveyor 160M.2 Bin Vent Baghouse 

Tank 160M.2 

Alumina Feed Airslide B2 Airslide B2 Baghouse 

Tank 160M.1 Feed Pneumatic 

Conveyor Potline #2 C1 Pollution 

Tank 160M.1 Control System 

Vibratory Screen and C1 east and 

C1 west Alumina Feed Airslides 

Vibratory screen and C1 east 

and C1 west Airslide bin 

vents #1, #2, #3, and #4 

Reacted Alumina Airslide B2 Tank 141A(NW) Baghouse 

Reacted Alumina Airslide C1 Tank 141A(NE) Baghouse 

Tank 141A(NE) 

Tank 141A(NE) Baghouse at 

its inlet and 104A Baghouse 

at its discharge 

Tank 141A(NW) 

Tank 141A(NW) Baghouse 

at its inlet and 104A 

Baghouse at its discharge 

Tank 141 BN Eductor Tank 141A(NE) Baghouse 

Tank 151C, Tank 151J, Tank 152, 

Tank 154, Feed Box B5 and Pollution 
Control System Alumina Feed 

Airslide B5 and Pollution Control 

System Alumina Feed Airslide B6 

Airslide Baghouse B5 or 

Airslide Baghouse B6 

Any equipment controlled by 

Baghouse 112A Baghouse 112A 

Any equipment controlled by 

Baghouse166 Baghouse 166 

Any equipment controlled by the Gas 

Treatment Center (GTC) GTC 

(b) Pursuant to SSM 173-18836-00007, issued on February 25, 2005, and in 

order to comply 

with Condition D.1.2, except as necessary to supply alumina to control 

fluoride emissions, the 

PM and PM10 emissions from the following facilities shall be controlled 

by the baghouses as 

indicated in the table below. Each baghouse shall be in operation and 

control emissions from 

its associated facility at all times when a facility that the baghouse 

controls is in operation. 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

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Permit Reviewer: Dr. Trip Sinha 

Facility Baghouse 

Equipment controlled by Baghouse 112A 

Baghouse 112A 

(1) 112A Passageway Conveyor 

(2) Airlift 150-FM-AE01 

(3) Airlift 150-FM-AE02 

(4) Airslide 151 

(5) Tank 151H 

(6) Unloading Station BL-08 

(7) Dense Phase Transporter VS-01 

(8) Feed Box 166-FM-08 

(9) Airslide 166-FM-09 

(10) Tank 151A Distribution Box 151-FM-1A 

(11) Airslide 166-FM-10 

(12) Tank 151B Distribution Box 151-FM-1B 

(13) Tanks 151A and 151B 

Equipment controlled by Baghouse 166 

(1) Airslide166-FM-01 

Baghouse 166 

(2) Airslide 166-FM-02 

(3) Airslide 161-B6-FM-01 

(4) Airlift 161B6-FM-AE-01, 

(5) Vibratory Screen 161B6-FM-SC-01 

(6) Airslide 166-FM-03; 

(7) Airslide 161-B5-FM-01 

(8) Airlift 161-B5-FM-AE-01 

(9) Vibratory Screen 161-B5-FM-SC-01 

(10) Feedbox for Airslide 165-FM-05 and 

Airslide 166-FM-06 

(11) Airslide 166-FM-05 

(12) Airslide 166-FM-06 

(13) Airlift 166-AE-02 

(14) Airlift 166-AE-01 

(15) Airslide 166-FM-05 

(c) In the event that bag failure is observed in a multi-compartment 

baghouse, if operations will 

continue for ten (10) days or more after the failure is observed before 

the failed units will be 

repaired or replaced, the Permittee shall promptly notify IDEM, OAQ of 

the expected date the 

failed units will be repaired or replaced. The notification shall also 

include the status of the 

applicable compliance monitoring parameters with respect to normal, and 

the results of any 

response actions taken up to the time of notification. 

D.1.4 Testing Requirements [326 IAC 2-7-6(1), (6)] [326 IAC 2-1.1-11] 

In order to comply with Conditions D.1.1 and D.1.2, and no later than 

January 5, 2010 or within 5 

years from the date of the last valid compliance test, whichever is 

later, the Permittee shall perform 
PM, and PM10 testing for Baghouse 112A and Baghouse 166, utilizing 

methods as approved by the 

Commissioner. These tests shall be repeated at least once every five (5) 

years from the date of the 

valid compliance demonstration. PM10 includes filterable and condensable 

PM10. Testing shall be 

conducted in accordance with Section C – Performance Testing. During the 

stack test, the Permittee 

shall determine the sensitivity of the bag leak detection system and 

calibrate the particulate 

concentration readings of the bag leak detector in order to provide an 

output relative to outlet grain 

loading levels. 

Compliance Monitoring Requirements [326 IAC 2-7-6 (1)] [326 IAC 2-7-5 

(1)] 

D.1.5 Bag Leak Detection System 

Pursuant to SSM 173-18836-00007, issued on February 25, 2005, the 

Permittee shall operate a 

continuous bag leak detection system for Baghouse 112A and Baghouse166 

stack exhaust in the 

alumina handling system. The bag leak detection system shall meet the 

following requirements: 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

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Permit Reviewer: Dr. Trip Sinha 

(a) Each electrodynamic bag leak detection system shall be calibrated, 

operated, and 

maintained in accordance with the manufacturer’s specifications; 

(b) The Permittee shall establish alarms representative of 50% of the 

combined permit limit for 

both bag leak detection systems such that an initial investigation alarm 

shall be activated for 

Baghouse 112A, whenever PM emissions from Stack 112A.1 are greater than 

or equal to 

1.35 pounds of PM per hour; and for Baghouse 166, whenever PM emissions 

from Stack 

166.1 are greater than or equal 1.47 pounds of PM and/or PM10 per hour. 

Failure to comply with the requirements in paragraph (b) of this 

condition shall be considered 

a deviation from this permit; 

(c) The bag leak detection system shall be certified by the manufacturer 

to be capable of 

detecting PM emissions at concentrations down to ten (10) milligrams per 

actual cubic meter 

(0.0044 grains per actual cubic foot) or less; 

(d) The bag leak detection system sensor shall provide output of relative 

or absolute PM 

loadings; 

(e) The bag leak detection system shall be equipped with a device to 

continuously record the 

output signal from the sensor; 

(f) The bag leak detection system shall be equipped with an alarm system 

that will sound 

automatically when an increase in relative PM emissions over a preset 

level is detected. The 

alarm shall be located where it is easily heard by plant operating 

personnel; 

(g) The bag leak detector shall be installed downstream of the fabric 

filter; 

(h) Where multiple detectors are required, the system's instrumentation 

and alarm may be 

shared among detectors; 

(i) The baseline output shall be established by adjusting the range and 

the averaging period of 

the device and establishing the alarm set points and the alarm delay 

time; 

(j) Following initial adjustment of the system, the Permittee shall not 

adjust the sensitivity or 

range, averaging period, alarm set points, or alarm delay time except as 

detailed in the PMP. 

In no case may the sensitivity be increased by more than one hundred 

(100%) percent or

decreased more than fifty (50%) percent over a 365-day period unless such 

adjustment 
follows a complete fabric filter inspection which demonstrates that the 

fabric filter is in good 

operating condition; 

(k) In the event that a bag leak detection system should malfunction, 

fail or otherwise need 

repair, the Permittee shall perform visible emissions notations of the 

stack exhausts 

associated with that bag leak detection system as follows: 

(1) Daily visible emission notations of the baghouse stack exhausts shall 

be performed 

during normal daylight operations. A trained employee shall record 

whether 

emissions are normal or abnormal; 

(2) For processes operated continuously, "normal" means those conditions 

prevailing, or 

expected to prevail, eighty percent (80%) of the time the process is in 

operation, not 

counting startup or shut down time; 

(3) In the case of batch or discontinuous operations, readings shall be 

taken during that 

part of the operation that would normally be expected to cause the 

greatest 

emissions; 
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Permit Reviewer: Dr. Trip Sinha 

(4) A trained employee is an employee who has worked at the plant at 

least one (1) 

month and has been trained in the appearance and characteristics of 

normal visible 

emissions for that specific process; and 

(5) If abnormal emissions are observed, the Permittee shall take 

reasonable response 

steps in accordance with Section C – Response to Excursions and 

Exceedances. 

Abnormal emissions alone are not a deviation from this permit. Failure to 

take 

response steps in accordance with Section C - Response to Excursions and 

Exceedances, shall be considered a deviation from this permit. 

D.1.6 Bag Leak Detection Alarm Activation 

In the event that a bag leak detection system alarm is activated for any 

reason, the Permittee shall 

take the following response steps: 

(a) For Baghouse 112A and Baghouse 166 which are single compartment 

baghouses, if failure 

is indicated by a bag leak detection alarm activation that is not a false 

alarm, or if bag failure 

is determined by other means, such as daily visible emissions notations 

and/or daily checks 

of the particulate concentration readings from electrodynamic bag leak 

detectors, then the 

associated process will be shut down after four (4) hours of operation 

following bag failure if 

the failed units have not been repaired or replaced. Operations may 

continue after four (4) 

hours of operation following bag failure only if the event qualifies as 

an emergency and the 

Permittee satisfies the requirements of the emergency provisions of this 

permit (Section C -

Emergency Provisions); and 

(b) After bag failure, if the alumina handling system continues to 

operate, until the failed bag is 

repaired or replaced, the Permittee shall monitor the hourly PM and PM10 

emission rate 

recorded by the electrodynamic bag leak detector’s data acquisition 

system until the failed 

bag is repaired or replaced. 

D.1.7 Visible Emissions Notations 

(a) Visible emission notations of the exhaust from Stacks 60.2 and 60.3, 

60.6, 60.8, 61A.1, 62.1, 

62.2, 61B.1, 140.1, 104.1, 144.1, 160M.2, 160B2.16, 141.1(NE), 161.B5.37, 

160C1.37 and 

161.B6.37, shall be performed once per day during normal daylight 

operations. When the 

baghouse exhausting to stack 160C1.37 is permanently idled, visible 

emission notations of 
the exhaust from bin vent exhausts 160C1.37-1, 160C1.37-2, 160C1.37-3, 

and 160C1.37-4, 

shall be performed once per day during daylight operations. 

(b) In the case of batch or discontinuous operations, readings shall be 

taken during normal 

operations. 

(c) If visible emissions are observed, an employee certified to perform 

an EPA Method 9 

evaluation shall determine whether opacity exceeds forty percent (40%) in 

one (1) six (6) 

minute averaging period as determined in 326 IAC 5-1-4, and: 

(1) If opacity does not exceed forty percent (40%) per Method 9, the 

Permittee shall 

shutdown the associated process as soon as practical unless either: 

(i) the Permittee is able to bring the opacity below forty percent (40%) 

within a 

reasonable period of time, or 

(ii) the situation qualifies as an ―emergency‖ under 326 IAC 2-7-1(12). 

If the Permittee continues to operate the associated process after 

determining the 

opacity exceeds forty percent (40%) per Method 9, then the Permittee 

shall perform 

an additional Method 9 reading every four (4) daylight hours until the 

opacity is below 

forty percent (40%) per Method 9. 

(2) If opacity does not exceed forty percent (40%) per the Method 9 

observation 

referenced above, inspection of the baghouse shall be scheduled at the 

next 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

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Permit Reviewer: Dr. Trip Sinha 

available process down time. Repairs shall be scheduled as expeditiously 

as 

pratical, based on the inspection results. 

(3) If opacity exceeds twenty percent (20%) per any Method 9 observations 

referenced 

above, the Permittee shall notify IDEM, if the Permittee anticipates that 

operations 

will continue for ten (10) days or more before the failed baghouse units 

will be 

repaired or replaced. 

Failure to take the response steps required by Condition D.1.7(c) upon 

observation of visible 

emissions, shall be considered a deviation from this permit.

Record Keeping and Reporting Requirement [326 IAC 2-7-5(3)] [326 IAC 2-7-

19] 

D.1.8 Record Keeping Requirements 

(a) To document compliance with Condition D.1.5 (a), the Permittee shall 

keep a log of the 

calibration test results for Baghouse 112A and Baghouse 166 leak 

detectors. 

(b) To document compliance with Condition D.1.5 (k), the Permittee shall 

maintain records of 

daily visible emission notations of the stack exhaust for Baghouse 112A 

and Baghouse 166, 

when the applicable bag leak detection system malfunctions, fails or 

otherwise needs repair. 

The Permittee shall include in its daily record when a visible emission 

notation is not taken 

and the reason for the lack of visible emission notation (e.g. the 

process did not operate that 

day). 

(c) To document compliance with Condition D.1.6 (a), the Permittee shall 

maintain records of 

each bag leak detection alarm activation for Baghouse 112A and Baghouse 

166. 

(d) To document compliance with Condition D.1.6(b), when bag failure 

occurs at either 

Baghouse 112A or Baghouse 166, the Permittee shall keep a log of the 

hourly PM and PM10 

emission rates recorded by the electrodynamic bag leak detector’s data 

acquisition system. 

(e) To document compliance with Condition D.1.7, the Permittee shall 

maintain records of the 

visible emission notations. The Permittee shall include in its daily 

record when a visible 

emission notation is not taken and the reason for the lack of visible 

emission notation (e.g. 

the process did not operate that day). 

(f) To document compliance with Condition D.1.7, the Permittee shall 

maintain records of the 
Method 9 readings. 

(g) The Permittee shall maintain the following as required under 

Conditions D.1.3, D.1.5, D.1.6, 

and D.1.7: 

(1) Documentation of all response steps implemented per event. 

(h) All records shall be maintained in accordance with Section C -

General Record Keeping 

Requirements, of this permit. 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 45 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

SECTION D.2 POTLINE & POTLINES SUPPORT FACILITY OPERATION CONDITIONS 

Facility Description [326 IAC 2-7-5(15)] 

(The information describing the process contained in this facility 

description box is descriptive 

information and does not constitute enforceable conditions.) 

(1) One (1) advanced technology potline, consisting of 10-15 research 

pots, identified as Potline 

No.1, modified in 2010, with a maximum aluminum production rate of 0.86 

tons per hour and 

5,000 tons per year. Primary emissions are either controlled by either 

the Potline No.1 A-398 

pollution control system (B2) and exhaust at Stacks 160B2.1-160B2.14 or 

controlled by a new 

air pollution control system to be sized for the reduced airflow needed 

only for the research 

pots. Secondary emissions are uncontrolled and exhaust at roof monitor 

102M.1. 

One (1) fluidized bed scrubber and baghouse system, consisting of seven 

(7) fluidized bed 

scrubbers and baghouses, identified as Potline No. 1 A-398 pollution 

control system (B2), with 

a total gas flow rate of 490,000 acfm at 2000F, and exhausting at Stacks 

160B2.1-160B2.14 or 

a newly designed system to be sized for a maximum reduced airflow of 

52,500 acfm at 200F 

required for 10-15 research pots and exhausting at a new exhaust stack;; 

(2) One (1) center-worked prebake one (CWPB1) potline, consisting of 150 

pots, identified as 

Potline No. 2, constructed in 1962 with a maximum aluminum production 

rate of 7.99 tons per 

hour. Primary emissions are controlled by the Potline No.2 A-398 

pollution control system (C1) 

and exhaust at Stacks 160C1.1-160C1.36. Secondary emissions are 

uncontrolled and exhaust 

at roof monitors 103M.1 and 104M.1. 

One (1) fluidized bed scrubber and baghouse system, consisting of twelve 

(12) fluidized bed 

scrubbers and baghouses, identified as Potline No. 2 A-398 pollution 

control system (C1), with 

a total gas flow rate of 480,000 acfm at 2000F, and exhausting at Stacks 

160C1.1-160C1.36; 

(3) One (1) center-worked prebake one (CWPB1) potline, consisting of 150 

pots, identified as 

Potline No. 3, constructed in 1965, with a maximum aluminum production 

rate of 7.99 tons per 

hour. Primary emissions are controlled by the gas treatment center (GTC) 

system and exhaust 

at Stack GTC. Secondary emissions are uncontrolled and exhaust at roof 

monitors 105M.1 and 

106M.1. 
One (1) alumina injection and fabric filtration system, identified as GTC 

system, with a total gas 

flow rate of 1,000,000 acfm at 1700F, and exhausting at Stack GTC; 

(4) One (1) center-worked prebake one (CWPB1) potline, consisting of 150 

pots, identified as 

Potline No. 4, constructed in 1965, with a maximum aluminum production 

rate of 7.99 tons per 

hour. Primary emissions are controlled by the GTC system and exhaust at 

Stack GTC. 

Secondary emissions are uncontrolled and exhaust at roof monitors 107M.1 

and 108M.1; 

(5) One (1) center-worked prebake one (CWPB1) potline, consisting of 150 

pots, identified as 

Potline No. 5, constructed in 1968, with a maximum aluminum production 

rate of 7.99 tons per 

hour. Primary emissions are controlled by the Potline No. 5 A-398 

pollution control system (B5) 

and exhaust at Stacks 161B5.1-161B5.36. Secondary emissions are 

uncontrolled and exhaust 

at roof monitors 109M.1 and 110M.1. 

One (1) fluidized bed scrubber and baghouse system, consisting of twelve 

(12) fluidized bed 

scrubbers and baghouses, identified as Potline No. 5 A-398 pollution 

control system (B5), with 

a total gas flow rate of 480,000 acfm at 2000F, and exhausting at Stacks 

161B5.1-161B5.36; 

(6) One (1) center-worked prebake one (CWPB1) potline, consisting of 150 

pots, identified as 

Potline No. 6, constructed in 1968, with a maximum aluminum production 

rate of 7.99 tons per 

hour. Primary emissions are controlled by the Potline No.6 A-398 

pollution control system (B6) 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

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Permit Reviewer: Dr. Trip Sinha 

and exhaust at Stacks 161B6.1-161B6.36. Secondary emissions are 

uncontrolled and exhaust 

at roof monitors 111M.1 and 112M.1. 

One (1) fluidized bed scrubber and baghouse system, consisting of twelve 

(12) fluidized bed 

scrubbers and baghouses, identified as Potline No.6 A-398 pollution 

control system (B6), with a 

total gas flow rate of 480,000 acfm at 2000F, and exhausting at Stacks 

161B6.1-161B6.36; 

(7) One (1) hydraulic hammer, identified as Pot Digging, constructed in 

1962, with a maximum 

capacity of 2.85 tons per hour, controlled by the Pot Digging baghouse, 

and exhausting at 

Stack 136.4. 

One (1) baghouse, identified as Pot Digging Baghouse, with an airflow 

rate of 70,000 dscfm, 

and exhausting at Stack 136.4; 

(8) One (1) auger, identified as Crucible Digging, constructed in 1988, 

with a maximum capacity of 

0.86 tons per hour, controlled by the Crucible Digging baghouse, and 

exhausting at Stack 

110.1. 

One (1) baghouse, identified as Crucible Digging Baghouse, with an 

airflow rate of 6,560 

dscfm, and exhausting to Stack 110.1; 

(9) One (1) crusher, identified as Potline Bath Crusher, constructed in 

1972, with a maximum 

capacity of 21 tons per hour, controlled by the Potline Bath Crusher 

Baghouse, and exhausting 

at Stack 110.2. 

One (1) baghouse, identified as Potline Bath Crusher Baghouse, with an 

airflow rate of 99,000 

dscfm, and exhausting at Stack 110.2; and 

(10) Four (4) alumina/butt bath/cake bath storage tanks, constructed in 

1972, identified as Tanks 

110H-A, 110H-B, 110H-C, and 110H-D with a capacity of 1000 cubic feet 

each, controlled by 

the Potline Bath Crusher Baghouse, and exhausting at Stack 110.2. 

Emission Limitations and Standards [326 IAC 2-7-5(1)] 

D.2.1 Particulate Emissions Limitations for Manufacturing Processes [326 

IAC 6-3-2] 

Pursuant to 326 IAC 6-3-2 (Particulate Emissions Limitations for 

Manufacturing Processes), the 

allowable particulate emission rate from the Potlines Nos.1, 2, 3, 4, 5, 

and 6, shall be limited as 

follows: 

Facility 

Maximum Process 

Weight Rate 

(tons/hr) 
PM Emission 

Limit 

(lbs/hr) 

Potline No.1 0.86 3.71 

Potline No.2 83.38 49.5 

Potline No.3 83.38 49.5 

Potline No.4 83.38 49.5 

Potline No.5 83.38 49.5 

Potline No.6 83.38 49.5 

Pot Digging 2.85 8.27 

Crucible Digging 0.86 3.70 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

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Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

Facility 

Maximum Process 

Weight Rate 

(tons/hr) 

PM Emission 

Limit 

(lbs/hr) 

Potline Bath Crusher, 

Tanks 110H-A, 110H-B, 

110H-C, and 110H-D 

21 31.5 

The above particulate emissions rates were determined from the following 

formulae: 

Interpolation of the data for the process weight rate up to sixty 

thousand (60,000) pounds per hour by 

use of the equation: 

E = 4.10 P0.67 

Where: E = rate of emission in pounds per hour; and 

P = process weight rate in tons per hour. 

Or 

Interpolation and extrapolation of the data for the process weight rate 

in excess of sixty thousand 

(60,000) pounds per hour by use of the equation: 

E = 55.0 P0.11 - 40 

Where: E = rate of emission in pounds per hour; and 

P = process weight rate in tons per hour. 

D.2.2 Warrick County Sulfur Dioxide (SO2) Emissions Limitations [326 IAC 

7-4-10] 

Pursuant to 326 IAC 7-4-10(a)(4), the allowable sulfur dioxide emission 

from Potlines Nos.1, 2, 3, 4, 

5, and 6, shall be limited as follows: 

(a) 

Facility Venting From SO2 Emission Limit 

(lbs/hr) 

Potline No.1 All stacks associated 

with scrubber 

176.3 

Potline No.1 Roof monitors 

associated with 

Potline 1 

19.6 

Potline No.2 All stacks associated 

with scrubber 

195.2 

Potline No.2 Roof monitors 

associated with 

Potline 2 

21.7 

Pot line No.3 All stacks associated 

with scrubber 
195.2 

Potline No.3 Roof monitors 

associated with 

Potline 3 

21.7 

Pot line No.4 All stacks associated 

with scrubber 

195.2 

Potline No.4 Roof monitors 

associated with 

Potline 4 

21.7 

Potline No.5 All stacks associated 

with scrubber 

195.2 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.:

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Permit Reviewer: Dr. Trip Sinha 

Facility Venting From SO2 Emission Limit 

(lbs/hr) 

Potline No.5 Roof monitors 

associated with 

Potline 5 

21.7 

Pot line No.6 All stacks associated 

with scrubber 

195.2 

Potline No.6 Roof monitors 

associated with 

Potline 6 

21.7 

(b) The total SO2 emissions from Potlines Nos.1, 2, 3, 4, 5, and 6 shall 

be less than 5,608 tons 

per twelve (12) consecutive month period with compliance determined at 

the end of each 

month. 

D.2.3 General Provisions Relating to NESHAP [326 IAC 12] [40 CFR 60 

Subpart S] [326 IAC 20-1] 

[40 CFR Part 63, Subpart A] [40 CFR 63.852] 

The provisions of 40 CFR Part 63, Subpart A- General Provisions, which 

are incorporated by 

reference in 326 IAC 20-1 apply to Potlines Nos. 2, 3, 4, 5, and 6 except 

when otherwise specified in 

40 CFR Part 63, Subpart LL, Appendix A of this subpart. 

D.2.4 Total Fluoride (TF) Emissions Limitations [326 IAC 12] [40 CFR 60 

Subpart S] [326 IAC 20-24] 

[40 CFR 63.843] [40 CFR 63.847] 

Pursuant to 40 CFR 63.843(a)(1) and 40 CFR 63.847(a)(1), the emissions of 

Total Fluoride (TF) (as 

defined in 40 CFR 63.842) shall not exceed 1.9 pounds per ton of aluminum 

produced for each 

Potlines Nos. 2, 3, 4, 5, and 6. 

D.2.5 Plans and Procedures [326 IAC 12] [40 CFR 60 Subpart S] [326 IAC 

20-1] [40 CFR 63.6] 

[326 IAC 20-24] [40 CFR 63.850] 

Pursuant to 40 CFR 63.850 (c)], the Permittee shall develop a written

startup, shutdown, and 

malfunction (SSM) plan as described in 40 CFR 63.6(e)(3) that contains 

specific procedures to be 

followed for operating the source and maintaining the source during 

periods of startup, shutdown, and 

malfunction and a program of corrective action for malfunctioning process 

and control systems used 

to comply with the standard. The plan does not have to be submitted with 

the permit application or 

included in the Part 70 operating permit. IDEM, OAQ may review the plan 

upon request. In addition to 

the information required in 40 CFR 63.6(e)(3), the plan shall include: 
(a) Procedures, including corrective actions, to be followed if for any 

baghouse the fan motor 

current (amperes) are less than that included in the most recent NESHAP 

Parametric Plan 

approved by IDEM, OAQ, if for any dry alumina scrubber the alumina feeder 

revolution per 

minute (rpm) is less than that included in the most recent NESHAP 

Parametric Plan 

approved by IDEM, OAQ, or if visible emissions indicating abnormal 

operation are observed 

from the exhaust stacks of the of the pollution control systems B2, C1, 

B5, B6; and GTC; and 

(b) The SSM plan shall be maintained in the operating record. 

D.2.6 HAP Minor Limit for Potline 1 [326 IAC 2-4.1] 

The total emissions of Hydrogen Fluoride from Potline No. 1 shall be less 

than 10 tons per per twelve 

(12) consecutive month period, with compliance determined at the end of 

each month. 

Compliance with this limit shall limit the total potential to emit of any 

single HAP from Potline No. 1 to 

less than ten (10) tons per twelve (12) consecutive month period and PTE 

of combined HAPs to less 

than 25 tons per twelve (12) consecutive month period and shall render 

326 IAC 2-4.1 (Major 

Sources of Hazardous Air Pollutants (HAP) not applicable to Potline No. 

1. 

Compliance Determination Requirements 

D.2.7 Particulate Control [326 IAC 2-7-6(6)] 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 49 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

(a) In order to comply with Conditions D.2.1 and D.2.4, the PM and 

fluoride emissions from the 

following potlines shall be controlled by the pollution control systems 

as indicated in the table 

below. Each pollution control system shall be in operation and control 

emissions from its 

associated potline at all times when a potline that the pollution control 

system controls is in 

operation. 

Potline Pollution Control System 

Potline No.1 Potline No. 1 A-398 (B2) or a 

newly installed system 

Potline No.2 Potline No. 2 A-398 (C1) 

Potline No.3 Gas Treatment System (GTC) 

Potline No.4 Gas Treatment System (GTC) 

Potline No.5 Potline No. 5 A-398 (B5) 

Potline No.6 Potline No. 6 A-398 (B6) 

(b) In order to comply with Condition D.2.1, the PM emissions from the 

following facilities shall 

be controlled by the baghouses as indicated in the table below. Each 

baghouse shall be in 

operation and control emissions from its associated facilities at all 

times when an emission 

unit that the baghouse controls is in operation; and 

Facility Baghouse 

Pot Digging Pot Digging Baghouse 

Crucible Digging Crucible Digging Baghouse 

Potline Bath Crushing and 

Tanks 110H-A, 110H-B, 

110H-C, and 110H-D 

Potline Bath Crusher 

Baghouse 

D.2.8 SO2 Emissions Determination [326 IAC 7-4-10 (b) and (c)] 

(a) Compliance with SO2 pounds per hour limitation shall be based 

on.material balance data and 

shall include the supporting information upon which the material balance 

data is based. 

(c) Pursuant to 326 IAC 7-4-10(c), compliance with the tons per year 

limitations of SO2 shall be 

based on a rolling twelve (12) consecutive month emission total. The 

monthly SO2 emissions 

shall be determined from calendar month material balances using actual 

average sulfur 

content and material throughput. 

D.2.9 HAP Emission Determination 

In order to determine the compliance status with Condition D.2.6, the 

Permittee shall use the 

following equation: 

TP1 * EFP1HF = Hydrogen Fluoride Emissions from Potline No. 1 

Where: 
TP1 = total aluminum throughput to Potline No.1 in tons, per month. 

EFP1HF = Emission Factor determined by the most recent compliant stack 

test, lbs of HF per ton of 

aluminum tapped 

D.2.10 Testing [326 IAC 7-10-4(b)] [326 IAC 12] [40 CFR 60 Subpart S] 

[326 IAC 20-1] 

[40 CFR 63, Subpart A] [326 IAC 20-24] [40 CFR 63.847] 

(a) Pursuant to 40 CFR 63.847(b), the Permittee shall prepare a site 

specific test plan prior to 

the performance test according to the requirements of 40 CFR 67.7(c). The 

test plan shall 

include procedures for conducting the performance tests required in 40 

CFR 63.848 for 

emission monitoring. In addition to the information required by 40 CFR 

63.7, the test plan 

shall include: 
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Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

(1) Procedures to ensure a minimum of three runs are performed annually 

for the 

primary control system for each emission unit; 

(2) For a source with a single control device exhausted through multiple 

stacks, 

procedures to ensure that at least three runs are performed annually by a 

representative sample of the stacks satisfactory to IDEM, OAQ; 

(3) For multiple control devices on a single source, procedures to ensure 

that at least 

one run is performed annually for each control device by a representative 

sample of 

the stacks satisfactory to IDEM, OAQ; and 

(4) Procedures for establishing the frequency of testing to ensure that 

at least one run is 

performed before the 15th of the month, at least one run is performed 

after the 15th 

of the month, and that there are at least 6 days between two of the runs 

during the 

month, or that secondary emissions are measured according to an alternate 

schedule satisfactory to IDEM, OAQ. 

(b) Pursuant to 40 CFR 63.847(d), all performance tests shall be 

conducted in accordance with 

the requirements of the general provisions in Subpart A of 40 CFR 63, the 

approved test 

plan, and the procedures in this section. 

(1) For each potline except potline 1, the Permittee shall measure and 

record the 

emission rate of TF exiting the outlet of the primary control system for 

each potline 

and the rate of secondary emissions exiting through each roof monitor. 

Using the 

equation in paragraph 40 CFR 63.847(e)(1) given below, the Permittee 

shall 

compute and record the average of at least three runs each month for 

secondary 

emissions and at least three runs each year for the primary control 

system to meet 

the emission limit in condition D.2.4; 

Equation to compute the emission rate (Ep) of TF from each potline: 

Where: 

.. . . . . 

. . .Eq.1. 

P K 

C Q C Q 

E s1 sd 1 s2 sd 2 

p . 

. . . 

. 

Ep = emission rate of TF from a potline, kg/Mg (lb/ton); 

Cs1 = concentration of TF from the primary control system, mg/dscf; 
Qsd = volumetric flow rate of effluent gas corresponding to the 

appropriate 

subscript location, dscf/hr; 

Cs2 = concentration of TF as measured for roof monitor emissions, 

mg/dscf; 

P = aluminum production rate, ton/hr; 

K = conversion factor, 453,600 mg/lb; 

1 = subscript for primary control system effluent gas; and 

2 = subscript for secondary control system or roof monitor effluent gas. 

(2) If the Permittee has performed more than one test of primary emission 

control device 

for a potline during the previous consecutive twelve month, 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; 

(3) Determine the weight of the aluminum tapped from the potline using 

the monitoring 

devices as required in Condition D.2.11(c); and 

(4) Determine the aluminum production rate (P) by dividing the number of 

hours in the 

calendar month into the weight of aluminum tapped from the potline during 

the 

calendar month that includes the three runs of a performance test. . 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

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Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

D.2.11 HAP Testing Requirements 

Not later than 180 after startup of the research pots in Potline No. 1, 

in order to demonstrate the 

compliance status with Condition D.2.6, the Permittee shall perform 

hydrogen fluoride testing on 

Potline No.1, utilizing methods as approved by the Commissioner. This 

test shall be repeated at least 

once every five (5) years from the date of this valid compliance 

demonstration. Testing shall be 

conducted in accordance with the provisions of 326 IAC 3-6 (Source 

Sampling Procedures). Section 

C - Performance Testing contains the Permittee's obligations with regard 

to the performance testing 

required by this condition. 

D.2.12 Test Methods and Procedures [326 IAC 12] [40 CFR 60 Subpart S] 

[326 IAC 20-1] 

[40 CFR 63, Subpart A] [326 IAC 20-24] [40 CFR 63.849] 

Pursuant to 40 CFR 63.849, the Permittee shall use the following 

reference methods to determine 

compliance with the applicable emission limits for TF: 

(a) Method 1 in appendix A to 40 CFR Part 60 for sample and velocity 

traverses; 

(b) Method 2 in appendix A to 40 CFR Part 60 for velocity and volumetric 

flow rate; 

(c) Method 3 in appendix A to 40 CFR Part 60 for gas analysis; 

(d) Method 13A or Method 13B in appendix A to 40 CFR Part 60, or an 

approved alternative, for 

the concentration of TF where stack or duct emissions are sampled; and 

(e) Method 13A or Method 13B and Method 14 or Method 14A in appendix A to 

part 60 of this 

chapter or an approved alternative method for the concentration of TF 

where emissions are 

sampled from roof monitors not employing wet roof scrubbers. 

Compliance Monitoring Requirements [326 IAC 2-7-6(1)] [326 IAC 2-7-5(1)] 

[40 CFR 63.847] 

[40 CFR 63.848] [326 IAC 20-24] 

D.2.13 Emission Monitoring Requirements [326 IAC 12] [40 CFR 60 Subpart 

S] [40 CFR 63.848] 

[326 IAC 20-24] 

Pursuant to 40 CFR 63.848(a), using the procedures in 40 CFR 63.847 and 

in the approved test plan, 

the Permittee shall monitor emissions of TF from each potline except 

Potline No.1 by conducting 

monthly performance tests. The Permittee shall compute and record the 

monthly average from at 

least three runs for secondary emissions and the previous 12-month 

average of all runs for the 

primary control system to determine compliance with the emission limit in 

Condition D.2.4. The 
Permittee shall include all valid runs in the monthly average. The 

duration of each run for secondary 

emissions shall represent a complete operating cycle. 

D.2.14 Emission Monitoring Requirements [326 IAC 12] [40 CFR 60 Subpart 

S] [326 IAC 20-24] 

[40 CFR 63.847] [40 CFR 63.848] 

(a) Pursuant to 40 CFR 63.847(h) and 40 CFR 63.848(f), the Permittee 

shall operate, calibrate, 

and maintain continuous parameter monitoring systems for the measurement 

of fan motor 

current (amperes) for air flow and alumina feeder revolution per minute 

(rpm) for alumina flow 

for the dry alumina scrubbers of the pollution control systems C1, B5, 

B6; and GTC at rates 

and frequencies included in the most recent NESHAP Parametric Plan 

approved by IDEM, 

OAQ. 

(b) Pursuant to 40 CFR 63.848(g), the Permittee shall visually inspect 

the exhaust stacks of 

pollution control systems C1, B5, B6; and GTC on a daily basis for 

evidence of any visible 

emissions indicating abnormal operation. 

(c) Pursuant to 40 CFR 63.848(j), the Permittee shall operate, and 

maintain a monitoring device 

to determine the daily weight of aluminum produced. 

(d) Pursuant to 40 CFR 63.848 (h), if the monitoring device for any of 

the pollution control 
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systems C1, B5, B6 or GTC, measures an operating parameter less than the 

limits stated in 

the most recent NESHAP Parametric Plan approved by IDEM, OAQ, or if 

visible emissions 

indicating abnormal operation are observed from the exhaust stacks of the 

pollution control 

systems C1, B5, B6 or GTC during a daily inspection, then the Permittee 

shall initiate the 

corrective action procedures identified in the SSM plan within one (1) 

hour. Failure to initiate 

the corrective action procedures within one (1) hour or to take the 

necessary corrective 

actions to remedy the problem is a violation. 

(e) Pursuant to 40 CFR 63.848(i), 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. 

(f) Pursuant to 40 CFR 63.848(k), the Permittee shall submit recommended 

accuracy 

requirements to IDEM, OAQ, for review and approval. All monitoring 

devices required by this 

section shall be certified by the Permittee to meet the accuracy 

requirements and shall be 

calibrated in accordance with the manufacturer's instructions. 

D.2.15 Visible Emissions Notations 

(a) Visible emission notations of the stack exhaust of Pot Line Bath 

Crusher baghouse shall be 

performed once per day. 

(b) In the case of batch or discontinuous operations, readings shall be 

taken during normal 

operations. 

(c) If visible emissions are observed, an employee certified to perform 

an EPA Method 9 

evaluation shall determine whether opacity exceeds forty percent (40%) in 

one (1) six (6) 

minute averaging period as determined in 326 IAC 5-1-4, and: 

(1) If opacity does not exceed forty percent (40%) per Method 9, the 

Permittee shall 

shutdown the associated process as soon as practical unless either: 

(iii) the Permittee is able to bring the opacity below forty percent 

(40%) within a 

reasonable period of time, or 

(iv) the situation qualifies as an ―emergency‖ under 326 IAC 2-7-1(12). 

If the Permittee continues to operate the associated process after 

determining the 
opacity exceeds forty percent (40%) per Method 9, then the Permittee 

shall perform 

an additional Method 9 reading every four (4) daylight hours until the 

opacity is below 

forty percent (40%) per Method 9. 

(2) If opacity does not exceed forty percent (40%) per the Method 9 

observation 

referenced above, inspection of the baghouse shall be scheduled at the 

next 

available process down time. Repairs shall be scheduled as expeditiously 

as 

pratical, based on the inspection results. 

(3) If opacity exceeds twenty percent (20%) per any Method 9 observations 

referenced 

above, the Permittee shall notify IDEM, if the Permittee anticipates that 

operations 

will continue for ten (10) days or more before the failed baghouse units 

will be 

repaired or replaced. 

Failure to take the response steps required by Condition D.2.15(c) upon 

observation of visible 

emissions shall be considered a deviation from this permit. 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

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Permit Reviewer: Dr. Trip Sinha 

Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-

7-19] [326 IAC 12] 

[40 CFR 60 Subpart S] [326 IAC 20-1] [40 CFR 63, Subpart A] [326 IAC 20-

24] [40 CFR 63.850] 

D.2.16 Record Keeping Requirements 

(a) To document compliance with SO2 in Condition D.2.2, the Permittee 

shall maintain records 

in accordance with (1) and (2) below: 

(1) The records shall include data and methodology used to calculate the 

monthly sulfur 

dioxide emissions; and 

(2) Records shall be complete and sufficient to establish compliance with 

the SO2 limit 

as required in Condition D.2.2. 

(b) To document compliance with Condition D.2.6, the Permittee shall 

maintain records in 

accordance with (1) and (2) below: 

(5) Total aluminum throughput to Potline No. 1 in a month; and 

(6) The most recent HF stack testing results. 

(c) The Permittee shall maintain records of daily visible emission 

notations of each stack exhaust 

for the baghouses as required by Condition D.2.15. The Permittee shall 

include in its daily 

record when a visible emission notation is not taken and the reason for 

the lack of visible 

emission notation (e.g. the process did not operate that day). 

(d) The Permittee shall maintain daily records of Method 9 readings, as 

required by Condition 

D.2.15. 

(e) The Permittee shall maintain the following as required under 

Condition D.2.15: 

(1) Documentation of all response steps implemented per event. 

(f) All records shall be maintained in accordance with Section C –

General Record Keeping 

Requirements, of this permit. 

D.2.17 NESHAP and NSPS Record Keeping Requirements [326 IAC 12] [40 CFR 

60 Subpart S] 

[326 IAC 20-1] [40 CFR 63, Subpart A] [326 IAC 20-24] [40 CFR 63.850 (c) 

and (e)] 

(a) Pursuant to 40 CFR 63.850(c)(2), the Permittee shall keep records of 

each event as required 

by 40 CFR 63.10(b) and record if an action taken during a startup, 

shutdown, or malfunction 

is not consistent with the procedures in the plan as required by 

Condition D.2.5. 

(b) Pursuant to 40 CFR 63.850(e), the Permittee shall maintain files of 

all information (including 

all reports and notifications) required by 40 CFR 63.10(b) and 40 CFR 

63.850. 
(1) The Permittee may retain records on microfilm, on a computer, on 

computer disks, 

on magnetic tape, or on microfiche; and 

(2) In addition to the general records required by 40 CFR 63.10(b), the 

Permittee shall 

maintain records of the following information: 

(i) Daily production rate of aluminum as required in Condition D.2.11(c); 

(ii) A copy of the startup, shutdown, and malfunction plan as required in 

Condition D.2.5(a); 

(iii) Records supporting a request for reduced sampling of potlines; 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

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(iv) Records, such as a checklist or the equivalent, demonstrating that 

the daily 

visual inspection of the exhaust stack for each control device has been 

performed as required in Condition D.2.11(b), including the results of 

each 

inspection; and 

(v) Records documenting the corrective actions taken when the limit for 

an 

operating parameter established in Condition D.2.11(a) were exceeded, or 

when visible emissions indicating abnormal operation were observed from a 

control device stack during a daily inspection required by Condition 

D.2.11(b). 

D.2.18 Reporting Requirements 

In order to determine compliance with Condition D.2.2, a quarterly report 

shall be submitted to the 

address listed in Section C – General Reporting Requirements, of this 

permit, using the reporting 

form located at the end of this section, or its equivalent, containing 

the calendar month and rolling 

twelve month sulfur dioxide emissions from the smelter operation (potline 

scrubber stacks, roof 

monitors). The report shall include documentation of the data and 

methodology used to calculate the 

monthly sulfur dioxide emissions and shall be submitted by the end of the 

month following the end of 

the quarter. The report submitted by the Permittee does require the 

certification by the ―responsible 

official‖ as defined by 326 IAC 2-7-1(34). 

D.2.19 HAP Reporting Requirements 

A quarterly report of the information to document the compliance status 

with Conditions D.2.6 shall be 

submitted, using the reporting forms located at the end of this permit, 

or their equivalent, not later 

than thirty (30) days following the end of each calendar quarter. The 

report submitted by the 

Permittee does require a certification that meets the requirements of 326 

IAC 2-7-6(1) by a 

―responsible official‖ as defined by 326 IAC 2-7-1(34). Section C -

General Reporting Requirements 

contains the Permittee's obligations with regard to the reporting 

required by this condition. 

D.2.20 NESHAP and NSPS Reporting Requirements [326 IAC 12] [40 CFR 60 

Subpart S] [326 IAC 20-1] 

[40 CFR 63, Subpart A] [326 IAC 20-24] [40 CFR 63.850(b), (c), (d), and 

(e)] 

(a) Pursuant to 40 CFR 63.850(b), the Permittee shall submit a summary of 

all performance 

tests to IDEM, OAQ on an annual basis. 

(b) Pursuant to 40 CFR 63.85(c)(2), the Permittee shall report if an 

action taken during a startup, 
shutdown, or malfunction is not consistent with the procedures in the SSM 

plan as required 

by 40 CFR 63.6(e)(3)(iv). 

(c) Pursuant to 40 CFR 63.850(d), the Permittee shall submit an excess 

emission report (or a 

summary report) if measured emissions are in excess of the applicable 

standard. The report 

shall contain the information specified in 40 CFR 63.10(e)(3)(v) and be 

submitted 

semiannually unless quarterly reports are required as a result of excess 

emissions. 

(d) Pursuant to 40 CFR 63.850(e)(3), the Permittee may report required 

information on paper or 

on a labeled computer disc using commonly available and compatible 

computer software. 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

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Permit Reviewer: Dr. Trip Sinha 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION 

Part 70 SO2 Quarterly Report 

Source Name: Alcoa Inc. - Warrick Operations 

Source Address: Jct. IN Hwys. 66 & 61, Newburgh, Indiana 47629-0010 

Mailing Address: Bldg. 860 E, P.O. Box 10, Newburgh, Indiana 47629 

Part 70 Permit No.: T173-6627-00007 

Facility: Potlines Nos. 1, 2, 3, 4, 5, and 6 

Parameter: SO2 Emissions 

Limit: Combined SO2 emissions of 5,608 tons per 12 consecutive month 

period 

Quarter _______ Year: ______ 

Month 

SO2 

(tons) 

SO2 

(tons) 

SO2 

(tons) 

This Month 

Previous 11 

Months 

12 Month 

Total 

Month 1 

Month 2 

Month 3 

. No deviation occurred in this month. 

. Deviation/s occurred in this month. 

Deviation has been reported on: 

Submitted by: 

Title/Position: 

Signature: 

Date: 

Phone: 

Attach a signed certification to complete this report. 
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Permit Reviewer: Dr. Trip Sinha 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION

Part 70 HF Quarterly Report 

Source Name: Alcoa Inc. - Warrick Operations 

Source Address: Jct. IN Hwys. 66 & 61, Newburgh, Indiana 47629-0010 

Mailing Address: Bldg. 860 E, P.O. Box 10, Newburgh, Indiana 47629 

Part 70 Permit No.: T173-6627-00007 

Facility: Potline No. 1 

Parameter: HF Emissions 

Limit: The total emissions of Hydrogen Flouride from Potline No. 1 shall 

be less than 10 tons per per twelve 

(12) consecutive month period, with compliance determined at the end of 

each month. 

Quarter _______ Year: ______ 

Month 

HF 

(tons) 

HF 

(tons) 

HF 

(tons) 

This Month 

Previous 11 

Months 

12 Month 

Total 

Month 1 

Month 2 

Month 3 

. No deviation occurred in this month. 

. Deviation/s occurred in this month. 

Deviation has been reported on: 

Submitted by: 

Title/Position: 

Signature: 

Date: 

Phone: 

Attach a signed certification to complete this report. 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

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Permit Reviewer: Dr. Trip Sinha 

SECTION D.3 GREEN ANODE PLANT FACILITY OPERATION CONDITIONS 

Facility Description [326 IAC 2-7-5(15)]: 

(The Information describing the process contained in this facility 

description box is descriptive 

information and does not constitute enforceable conditions.) 

(1) Ten (10) calcined petroleum coke storage silos, identified as Coke 

Silos, constructed in 1959, 

with a maximum capacity of 1,286 tons each, with maximum filling and 

unfilling rates of 138.0 

and 18.4 tons/hr, respectively; 

(2) Four (4) vibrating screens and size classifying equipment, identified 

as Shaker Screens, 

constructed in 1959, with a maximum coke screening capacity of 16.7 tons 

per hour, controlled 

by the baghouse DC-218, and exhausting at Stack 254.7. 

One (1) baghouse, identified as DC-218, with an air flow rate of 18,000 

acfm at 77oF, 

exhausting at Stack 254.7; 

(3) One (1) coarse sized coke storage tank, identified as Coarse Coke 

Tank T-35, constructed in 

1959, with a maximum incoming coke of 6.94 tons per hour, controlled by 

the baghouse 

DC-218, and exhausting at Stack 254.7; 

(4) One (1) hammermill, identified as 45 Hammermill, constructed in 1959, 

with a maximum 

capacity of 16.7 tons per hour, controlled by the baghouse DC-218, and 

exhausting at Stack 

254.7; 

(5) One (1) intermediate sized coke storage tank, identified as 

intermediate tank T-101, 

constructed in 1959, with a maximum of incoming coke of 15.4 tons per 

hour, controlled by the 

baghouse DC-218, and exhausting at Stack 254.7; and 

(6) One (1) fine sized coke storage tank, identified as Fine Coke Tank T146, constructed in 1959, 

with a maximum capacity of 18.0 tons per hour, controlled by the baghouse 

DC-218, and 

exhausting at Stack 254.7; 

(7) One (1) hammermill, identified as 153 Hammermill, constructed in 

1959, with a maximum 

capacity of 21.0 tons per hour, controlled by the baghouse DC-153, and 

exhausting at Stack 

254.4. 

One (1) baghouse, identified as DC-153, with an air flow rate of 8,000 

acfm at 77oF, exhausting 

at Stack 254.4; 

(8) One (1) intermediate classifier, identified as Intermediate 

Classifier CL-82, constructed in 1959, 

with a maximum capacity of 15.4 tons per hour, controlled by the baghouse 

DCF-221A, and 
exhausting at Stack 254.5. 

One (1) baghouse, identified as DCF-221A, with an air flow rate of 1,200 

acfm at 77oF, 

exhausting at Stack 254.5, and controlling emissions from the following 

equipment; 

(9) One (1) fine calcined petroleum coke and dust (from baghouses 218 and 

153) fines ball mill 

grinding facility, identified as BM-112, constructed in 1959, with a 

maximum capacity of 18.0 

tons per hour, controlled by the baghouse DCF-221B, and exhausting at 

Stack 254.6. 

One (1) ball mill baghouse, identified as DCF-221B, with an air flow rate 

of 4,500 acfm at 77oF, 

exhausting at Stack 254.6; 
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(10) One (1) weighting facility, identified as Greenmill Check-Weigh 

Scale, constructed in 1959, with 

a maximum throughput of 43.6 tons per hour controlled by Check-Weigh 

Scale Baghouse, and 

exhausting at Stack 254.8. 

One (1) baghouse, identified as Check-Weigh Scale Baghouse, with an air 

flow rate of 3,000 

acfm at 77 oF, exhausting at Stack 254.8; 

(11) Ten (10) mixers, identified as Mixer Tanks Nos. 1-10, constructed in 

1959, each with a 

maximum throughput of aggregate material 52.5 tons per hour, controlled 

by Pitch Fume 

Treatment System, and exhausting at Stack 254.13. 

One (1) pitch fume treatment system (formerly green anode forming 

operations), consisting of 

two (2) dry coke scrubbers and two (2) baghouses for PM, PM10, and VOC 

control, identified as 

Pitch Fume Treatment System, constructed in 1999, with a treatment 

capacity of 52.5 tons of 

green anodes per hour, with an airflow rate of 70,000 acfm at 100 oF and 

exhausting at Stack 

254.13. The pitch fume treatment system has a minimum feed rate, as 

specified in the 

approved parametric monitoring plan, of 3.6 tons per hour of calcined 

petroleum coke; 

(12) Two (2) hydraulic presses, identified as North and South Anode 

Press, constructed in 1959, 

with a maximum formation rate of 52.5 tons per hour, controlled by Pitch 

Fume Treatment 

System, and exhausting at Stack 254.13; 

(13) One (1) carbon Press Feed Conveyor, identified as 618 B, constructed 

in 1959, with a 

maximum throughput of 52.5 tons per hour, controlled by Pitch Fume 

Treatment System, and 

exhausting at Stack 254.13; 

(14) Three (3) cooling belts, identified as fans No. 1-3, constructed in 

1959, with a maximum 

throughput of 52.5 tons per hour, controlled by Pitch Fume Treatment 

System, and exhausting 

at Stack 254.13; 

(15) One (1) coal tar pitch tank, identified as Pitch Storage Tank, 

constructed in 1959, with a 

maximum capacity of 4.65 tons per hour, with no control, and exhausting 

inside the green 

anode plant; and 

(16) Three (3) fixed roof pitch storage tanks, identified as Pitch Tanks 

251A, 251B, and 251C, 

constructed in 1959, with a combined maximum storage capacity of 666,000 

gallons, using 

natural draft displacement as control, and exhausting to atmosphere. 
Emission Limitations and Standards [326 IAC 2-7-5(1)] 

D.3.1 Particulate Emissions Limitations for Manufacturing Processes [326 

IAC 6-3-2] 

Pursuant to 326 IAC 6-3 (Particulate Emissions Limitations for 

Manufacturing Processes), the 

allowable particulate emission rate from the below listed processes shall 

be limited as follows: 

Facility Control Equipment Maximum Process 

Weight Rate 

(tons/hr) 

PM Emission 

Limit 

(lbs/hr) 

Coke Silos None 138 54.6 

Size classifying equipment DC-218 baghouse 16.7 27 

153 Hammermill DC-153 baghouse 21 31.5 

Intermediate Classifier 

CL-82 

DCF-221A baghouse 15.4 25.6 

BM-112 Ball mill grinding 

operation 

DCF-221B baghouse 18 28.4 
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Permit Reviewer: Dr. Trip Sinha 

Facility Control Equipment Maximum Process 

Weight Rate 

(tons/hr) 

PM Emission 

Limit 

(lbs/hr) 

Weighting facility Check-Weigh Scale 

Baghouse 

43.6 43.3 

Anode Forming Pitch Fume 

Treatment System 

52.5 45 

The above particulate emissions rates were determined from the following 

formulae: 

Interpolation of the data for the process weight rate up to sixty 

thousand (60,000) pounds per hour by 

use of the equation: 

E = 4.10 P0.67 

Where: E = rate of emission in pounds per hour; and 

P = process weight rate in tons per hour. 

or 

Interpolation and extrapolation of the data for the process weight rate 

in excess of sixty thousand 

(60,000) pounds per hour by use of the equation: 

E = 55.0 P0.11 - 40 

Where: E = rate of emission in pounds per hour; and 

P = process weight rate in tons per hour. 

D.3.2 PSD Minor Limitations [326 IAC 2-2] 

Pursuant to SSM 173-17780-00007, issued on July 21, 2004, the following 

limits shall apply to the 

pitch fume treatment system: 

(a) The emission rate of PM shall not exceed 0.070 pounds of PM per ton 

of green anode; 

(b) The emission rate of PM10 shall not exceed 0.050 pounds PM10 per ton 

of green anode; and 

(c) The emission rate of VOC shall not exceed 0.030 pounds of VOC per ton 

of green anode. 

Compliance with the throughput limits in Conditions D.4.2(a) and D.6.4(a) 

and the emission limits 

specified by Conditions D.3.2(a) through (c), D.4.2(b) through (e), 

D.5.2(a) and (b), and D.6.4(b) and 

(c), shall render the requirements of 326 IAC 2-2 not applicable to the 

green anode plant. 

D.3.3 General Provisions Relating to NESHAP [326 IAC 20-1] [40 CFR Part 

63, Subpart A] 

[40 CFR 63.852] 

The provisions of 40 CFR Part 63, Subpart A- General Provisions, which 

are incorporated by 

reference in 326 IAC 20-1 apply to all operations in the Green Anode 

plant where coal tar pitch is
mixed with calcined petroleum coke and/or spent anode materials except 

when otherwise specified in 

40 CFR Part 63, Subpart LL, Appendix A of this subpart. 

D.3.4 POM Emissions Control Requirement [326 IAC 20-24] [40 CFR 63.843] 

[40 CFR 63.847] 

Pursuant to 40 CFR 63.843(b)(1), (2), and (3) for all operations in the 

Green Anode plant, where coal 

tar pitch is mixed with calcined petroleum coke and/or spent anode 

materials, the Permittee shall 

(a) operate, and maintain equipment to capture and control POM emissions 

from the anode 

forming operations (which encompasses initial mixing through final 

forming); 
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(b) operate the emission capture system to meet the generally accepted 

engineering standards 

for minimum exhaust rates as published by the American Conference of 

Governmental 

Industrial Hygienists in Chapters 3 and 5 of ―Industrial Ventilation: A 

Handbook of 

Recommended Practice‖ (incorporated by reference in 40 CFR 63.841; and 

(c) route the captured emissions through a closed system to a dry coke 

scrubber. 

D.3.5 Plans and Procedures [326 IAC 20-1] [40 CFR 63.6] [326 IAC 20-24] 

[40 CFR 63.850] 

Pursuant to 40 CFR 63.850 (c), the Permittee shall develop a written 

startup, shutdown, and 

malfunction (SSM) plan as described in 40 CFR 63.6(e) (3) that contains 

specific procedures to be 

followed for operating the anode forming process (which encompasses 

initial mixing through final 

forming) and maintaining the anode forming equipment during periods of 

startup, shutdown, and 

malfunction and a program of corrective action for malfunctioning process 

and control systems used 

to comply with the standard. The plan does not have to be submitted with 

the permit application or 

included in the Part 70 operating permit. IDEM, OAQ may review the plan 

upon request. In addition to 

the information required in 40 CFR 63.6(e) (3), the plan shall include: 

(a) Procedures, including corrective actions, to be followed if for any 

baghouse the fan motor 

amperes are less than that included in the most recent NESHAP Parametric 

Plan approved 

by IDEM, OAQ, if for any dry coke scrubber the coke feeder rpm is less 

than that included in 

the most recent NESHAP Parametric Plan approved by IDEM, OAQ, if the 

alarm on any of 

the bag leak detection systems activates, or if visible emissions 

indicating abnormal 

operation are observed from the exhaust stacks of the pitch fume 

treatment system 

whenever the bag leak detection systems are not operational; and 

(b) The Permittee shall maintain a copy of the SSM plan as required by 40 

CFR 63.850(b). 

(c) The SSM plan shall be maintained in the operating record. 

Compliance Determination Requirements 

D.3.6 Particulate Control [326 IAC 2-7-6(6)] 

(a) In order to comply with Condition D.3.1and D.3.2, the PM (PM and PM10 

for Anode forming) 

emissions from the following facilities shall be controlled by the 

baghouses as indicated in the 

table below. Each baghouse shall be in operation and control emissions 

from its associated 
facilities at all times when an emission unit that the baghouse controls 

is in operation; and 

Facility Baghouse 

Size classifying equipment DC-218 baghouse 

153 Hammermill DC-153 baghouse 

Intermediate Classifier CL-82 DCF-221A baghouse 

BM-112 Ball mill grinding 

operation 

DCF-221B baghouse 

Weighting facility Check-Weigh Scale Baghouse 

Anode Forming Pitch Fume Treatment System 

(b) In the event that bag failure is observed in a multi-compartment 

baghouse except the pitch 

fume treatment system baghouse, if operations will continue for ten (10) 

days or more after 

the failure is observed before the failed units will be repaired or 

replaced, the Permittee shall 

promptly notify IDEM, OAQ of the expected date the failed units will be 

repaired or replaced. 

The notification shall also include the status of the applicable 

compliance monitoring 

parameters with respect to normal, and the results of any response 

actions taken up to the 

time of notification. 

(c) In the event that bag failure is observed in a pitch fume treatment 

system baghouse, the 

Permittee shall take corrective action according to Condition D.3.8(c). 
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D.3.7 Testing Requirements [326 IAC 2-7-6(1), (6)] 

In order to comply with Condition D.3.2, and no later than January 5, 

2010 or within 5 years from the 

date of the last valid compliance test, whichever is later, the Permittee 

shall perform PM, PM10 and 

VOC testing for the pitch fume treatment system, utilizing methods as 

approved by the 

Commissioner. These tests shall be repeated at least once every five (5) 

years from the date of the 

valid compliance demonstration. PM10 includes filterable and condensable 

PM10. Testing shall be 

conducted in accordance with Section C – Performance Testing. During the 

stack test, the Permittee 

shall determine the sensitivity of the bag leak detection system and 

calibrate the particulate 

concentration readings of the bag leak detector in order to provide an 

output relative to outlet grain 

loading levels. 

Compliance Monitoring Requirements [326 IAC 2-7-6 (1)] [326 IAC 2-7-5 

(1)] [326 IAC 20-1] [40 CFR 63, 

Subpart A] [326 IAC 20-24] [40 CFR 63.847] [40 CFR 63.848] 

D.3.8 Emission Monitoring Requirements [326 IAC 20-1] [40 CFR 63, Subpart 

A] [326 IAC 20-24] 

[40 CFR 63.847] [40 CFR 63.848] 

(a) Pursuant to 40 CFR 63.848(g), 40 CFR 63.8(f), and Condition D.3.9, 

the Permittee shall 

operate the continuous bag leak detection systems installed on the 

exhaust duct of each 

baghouse of the pitch fume treatment system until such time that the 

continuous broken bag 

detection system for the pitch fume treatment system common exhaust stack 

has been 

installed and calibrated. After the continuous broken bag detection 

system for the pitch fume 

treatment system common exhaust stack has been installed and calibrated, 

the Permittee 

shall comply with the provisions of 40 CFR 63.848(g) and 40 CFR 63.8(f) 

using the pitch 

fume treatment system common exhaust stack continuous broken bag 

detection system. 

Whenever the bag leak detection systems are not operational, the 

Permittee shall visually 

inspect the exhaust stacks of the pitch fume treatment system on a daily 

basis for evidence 

of any visible emissions indicating abnormal operation. 

(b) Pursuant to 40 CFR 63.847(h) and 40 CFR 63.848(f), the Permittee 

shall operate, calibrate, 

and maintain continuous parameter monitoring systems for the measurement 

of fan motor 
current (amperes) for air flow and coke feeder revolution per minute 

(rpm) for coke flow for 

the dry coke scrubbers of the pitch fume treatment system at rates and 

frequencies included 

in the most recent NESHAP Parametric Plan approved by IDEM, OAQ. 

(c) Pursuant to 40 CFR 63.848(f), if for any baghouse the fan motor 

current (amperes) are less 

than that included in the most recent NESHAP Parametric Plan approved by 

IDEM, OAQ, if 

for any dry coke scrubber the coke feeder rpm is less than that included 

in the most recent 

NESHAP Parametric Plan approved by IDEM, OAQ, if the alarm on any of the 

bag leak 

detection systems activates, or if visible emissions indicating abnormal 

operation are 

observed from the exhaust stacks of the pitch fume treatment system 

during the time the bag 

leak detection system is malfunctioning, then the Permittee shall 

initiate the corrective action 

procedures identified in the SSM plan within one (1) hour. Failure to 

initiate the corrective 

action procedures within one (1) hour or to take the necessary corrective 

actions to remedy 

the problem is a violation. 

(d) Pursuant to 40 CFR 63.848(k), the Permittee shall submit recommended 

accuracy 

requirements to IDEM, OAQ, for review and approval. All monitoring 

devices required by this 

section must be certified by the Permittee to meet the accuracy 

requirements and must be 

calibrated in accordance with the manufacturer's instructions. 

(e) Pursuant to 40 CFR 63.848(i), if the limit for a given operating 

parameter monitoring the pitch 

fume treatment system is exceeded six times in any semiannual 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 24-hour 

period. 
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D.3.9 Bag Leak Detection System and Alternative Monitoring Plan (AMP) 

[SPM 173-21948-00007] 

[326 IAC 20-24] [40 CFR 63.847] [40 CFR 63.848] 

Upon installation and calibration, the Permittee shall operate the 

continuous bag leak detection

system installed on the common exhaust stack of the Pitch Fume Treatment 

System and the exhaust 

stack of the DC-218 baghouse. The Permittee shall continue to operate the 

continuous bag leak 

detection system installed on the exhaust duct of each baghouse of the 

pitch fume treatment system 

until the continuous bag leak detection system for the common exhaust 

stack has been installed and 

calibrated. The bag leak detection systems shall meet the following 

requirements: 

(a) Each electrodynamic bag leak detection system shall be calibrated, 

operated, and 

maintained according to the manufacturer's recommendations; 

(b) The bag leak detection system shall be certified by the manufacturer 

to be capable of 

detecting PM emissions at concentrations of ten (10) milligrams per 

actual cubic meter 

(0.0044 grains per actual cubic foot) or less; 

(c) The bag leak detection system sensor shall provide output of relative 

or absolute PM 

loadings; 

(d) The bag leak detection system shall be equipped with a device to 

continuously record the 

output signal from the sensor; 

(e) The bag leak detection system shall be equipped with an alarm system 

that will sound 

automatically when an increase in relative PM emissions over a preset 

level is detected. The 

alarm shall be located where it is easily heard by plant operating 

personnel; 

(f) The bag leak detector shall be installed downstream of the fabric 

filter. 

(g) Where multiple detectors are required, the system's instrumentation 

and alarm may be 

shared among detectors; 

(h) The baseline output shall be established by adjusting the range and 

the averaging period of 

the device and establishing the alarm set points and the alarm delay 

time; 

(i) Following initial adjustment of the system, the Permittee shall not 

adjust the sensitivity or 

range, averaging period, alarm set points, or alarm delay time except as 

detailed in the PMP. 

In no case may the sensitivity be increased by more than one hundred 

(100%) percent or 
decreased more than fifty (50%) percent over a 365-day period unless such 

adjustment 

follows a complete fabric filter inspection which demonstrates that the 

fabric filter is in good 

operating condition. 

(j) In the event that a bag leak detection system should malfunction, 

fail or otherwise need 

repair, the Permittee shall perform visible emissions notations of the 

Pitch Fume Treatment 

System and/or DC-218 stack exhausts associated with that bag leak 

detection system as 

follows: 

(1) Visible emission notations of the stack exhaust shall be performed 

once per day 

during normal daylight operations. A trained employee shall record 

whether 

emissions are normal or abnormal; 

(2) For processes operated continuously, "normal" means those conditions 

prevailing, or 

expected to prevail, eighty percent (80%) of the time the process is in 

operation, not 

counting startup or shut down time; 

(3) In the case of batch or discontinuous operations, readings shall be 

taken during that 

part of the operation that would normally be expected to cause the 

greatest 

emissions; 
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(4) A trained employee is an employee who has worked at the plant at 

least one (1) 

month and has been trained in the appearance and characteristics of 

normal visible 

emissions for that specific process; and 

(5) Pursuant to 40 CFR 63.848(f), if the alarm on the bag leak detection 

systems probe 

on the common exhaust stack of the Pitch Fume Treatment System activates, 

or if 

visible emissions indicating abnormal operation are observed from the 

common 

exhaust stack of the pitch fume treatment system during the time the bag 

leak 

detection system is malfunctioning, then the Permittee shall initiate the 

corrective 

action procedures identified in the SSM plan within one (1) hour. Failure 

to initiate 

the corrective action procedures within one (1) hour or to take the 

necessary 

corrective actions to remedy the problem is a violation. 

D.3.10 Visible Emissions Notations 

(a) Visible emission notations of the stack exhaust for DC-153, DCF-221A, 

DCF-221B, and 

Check-Weigh Scale baghouses shall be performed once per day. 

(b) In the case of batch or discontinuous operations, readings shall be 

taken during normal 

operations. 

(c) If visible emissions are observed, an employee certified to perform 

and EPA Method 9 

evaluation shall determine whether opacity exceeds forty percent (40%) in 

one (1) six (6) 

minute averaging period as determined in 326 IAC 5-1-4, and: 

(1) If opacity does not exceed forty percent (40%) per Method 9, the 

Permittee shall 

shutdown the associated process as soon as practical unless either: 

(v) the Permittee is able to bring the opacity below forty percent (40%) 

within a 

reasonable period of time, or 

(vi) the situation qualifies as an ―emergency‖ under 326 IAC 2-7-1(12). 

If the Permittee continues to operate the associated process after 

determining the 

opacity exceeds forty percent (40%) per Method 9, then the Permittee 

shall perform 

an additional Method 9 reading every four (4) daylight hours until the 

opacity is below 

forty percent (40%) per Method 9. 

(2) If opacity does not exceed forty percent (40%) per the Method 9 

observation 

referenced above, inspection of the baghouse shall be scheduled at the 

next 
available process down time. Repairs shall be scheduled as expeditiously 

as 

pratical, based on the inspection results. 

(3) If opacity exceeds twenty percent (20%) per any Method 9 observations 

referenced 

above, the Permittee shall notify IDEM, if the Permittee anticipates that 

operations 

will continue for ten (10) days or more before the failed baghouse units 

will be 

repaired or replaced. 

Failure to take the response steps required by Condition D.3.10(c) upon 

observation of visible 

emissions shall be considered a deviation from this permit. 

Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-

7-19] [326 IAC 20-1] 

[40 CFR 63, Subpart A] [326 IAC 20-24] [40 CFR 63.850] 

D.3.11 Record Keeping Requirements 

(a) To document compliance with Condition D 3.2, the Permittee shall 

maintain records of the 

stack tests results as required by Condition D.3.7. 
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(b) To document compliance with Condition D.3.9(a), the Permittee shall 

keep a log of the 

calibration test results for pitch fume treatment system baghouses leak 

detectors. Upon 

installation and calibration of the pitch fume treatment system common 

stack and DC-218 

baghouse bag leak detection system, the Permittee shall keep a log of the 

calibration results 

for those detectors. Upon installation and calibration of the pitch fume 

treatment system 

common exhaust stack bag leak detection system; Permittee will no longer 

be required to 

calibrate and operate the bag leak detection system on each baghouse of 

the pitch fume 

treatment system in order to comply with the provisions of 40 CFR 

63.848(g) and 40 CFR 

63.8(f). 

(c) To document compliance with Condition D.3.9 (j), the Permittee shall 

maintain records of 

daily visible emission notations of the stack exhaust for pitch fume 

treatment system 

baghouses, when the applicable bag leak detection system malfunctions, 

fails or otherwise 

needs repair. The Permittee shall include in its daily record when a 

visible emission notation 

is not taken and the reason for the lack of visible emission notation 

(e.g. the process did not 

operate that day). 

(d) To document compliance with Condition D.3.10, the Permittee shall 

maintain records of daily 

visible emission notations for each stack exhaust. The Permittee shall 

include in its daily 

record when a visible emission notation is not taken and the reason for 

the lack of visible 

emission notation (e.g. the process did not operate that day). 

(e) To document compliance with Condition D.3.10, the Permittee shall 

maintain records of the 

Method 9 readings. 

(f) The Permittee shall maintain documentation of all response steps 

implemented per event as 

required under Condition D.3.10. 

(g) All records shall be maintained in accordance with Section C -

General Record Keeping 

Requirements, of this permit. 

D.3.12 NESHAP Record Keeping Requirements [326 IAC 20-1] [40 CFR 63, 

Subpart A] [326 IAC 20-24] 

[40 CFR 63.850(c) and (e)]

(a) Pursuant to 40 CFR 63.850(c)(2), the Permittee shall keep records of 

each event as required 
by 40 CFR 63.10(b) and record if an action taken during a startup, 

shutdown, or malfunction 

is not consistent with the procedures in the plan as required by 

condition D.3.5. 

(b) Pursuant to 40 CFR 63.850(e), the Permittee shall maintain files of 

all information (including 

all reports and notifications) required by 40 CFR 63.10(b) and 40 CFR 

63.850. 

(1) The Permittee may retain records on microfilm, on a computer, on 

computer disks, 

on magnetic tape, or on microfiche; and 

(2) In addition to the general records required by 40 CFR 63.10(b), the 

Permittee shall 

maintain records of the following information: 

(i) A copy of the startup, shutdown, and malfunction plan as required in 

Condition D.3.5; 

(ii) Records of design information for pitch fume treatment system 

capture 

systems; 

(iii) Records, such as a checklist or the equivalent, demonstrating that 

the daily 

visual inspection of the exhaust stack for the baghouse of the pitch fume 

treatment system were performed including the results of each inspection 

during the time a bag leak detection system was malfunctioning, failed or 

otherwise needed repair; and 
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(iv) Records documenting the corrective actions taken when the limit for 

an 

operating parameter established in the most recent NESHAP Parametric 

Plan approved by IDEM, OAQ were exceeded, if the alarm on any of the bag 

leak detection systems was activated, or if visible emissions indicating 

abnormal operation were observed from the exhaust stacks of the pitch 

fume 

treatment system during the time the bag leak detection system was 

malfunctioning, failed or otherwise needed repair. 

D.3.13 NESHAP Reporting Requirements [326 IAC 20-1] [40 CFR 63, Subpart 

A] [326 IAC 20-24] 

[40 CFR 63.850(c), (d), and (e)] 

(a) Pursuant to 40 CFR 63.650(c)(2), the Permittee shall report if an 

action taken during a 

startup, shutdown, or malfunction is not consistent with the procedures 

in the SSM plan as 

required by Condition D.3.5. 

(b) Pursuant to 40 CFR 63.850(d), and 40 CFR Part 63.10(e)(3), the 

Permittee shall submit a 

report, or summary report, if measured emissions are in excess of the 

applicable standard. 

The report shall contain the information specified in 40 CFR Part 

63.10(e)(3)(v) and be 

submitted semiannually unless quarterly reports are required as a result 

of excess emissions. 

The report shall be submitted to the address listed in Section C -

General Reporting 

Requirements, of this permit, using the reporting forms located at the 

end of this permit, or its 

equivalent, within thirty (30) days after the end of the semi-annual or 

if necessary after the 

end of the quarter being reported. The report submitted by the Permittee 

does require the 

certification by the ―responsible official‖ as defined by 326 IAC 2-7-

1(34). 

(c) Pursuant to 40 CFR 63.850(e)(3), the Permittee may report required 

information on paper or 

on a labeled computer disc using commonly available and compatible 

computer software. 
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SECTION D.4 ANODE BAKING PLANT FACILITY OPERATION CONDITIONS 

Facility Description [326 IAC 2-7-5(15)] 

(The information describing the process contained in this facility 

description box is descriptive 

information and does not constitute enforceable conditions.) 

(1) One (1) above-ground, natural gas-fired, green anode baking ring 

furnace, known as Bldg. 295 

Anode Baking Ring Furnace, constructed in 1981 and was restarted in 2003 

after it was rebuilt 

in 2003, with a maximum capacity of 21.42 tons of green anodes per hour, 

equipped with an 

A-446 pollution control system consisting of three (3) reactor sections 

with baghouses for PM 

and PM10 control and dry alumina scrubbers for TF and SO2 control which 

operate at a 

minimum of two (2) reactor sections at any one (1) time, exhausting 

through Stacks 265D.1, 

265D.2, 265D.3, 265D.4, 265D.5, 265D.6, 265D.8, and 265J.1 (which is the 

diesel-fired 

emergency bypass engine stack used for venting ring furnace exhaust gases 

during emergency 

periods of unexpected loss of power to the A-446 dry scrubber fans); 

(2) One (1) diesel-fired emergency bypass engine, constructed in 1990, 

with a maximum output 

capacity of 200 horsepower, with a bypass duct and an emergency bypass 

fan, and venting to 

an emergency bypass Stack 265J.11; 

(3) One (1) reacted alumina storage tank, constructed in 1981, with a 

maximum loading capacity of 

7.5 tons/hr, pneumatically loading, controlled by the bin vent filter, 

and exhausting at Stack 

265D.7. 

One (1) reacted alumina storage tank baghouse, identified as bin vent 

filter, constructed in 

1981, with an air flow rate of 30 acfm at 77oF, and control efficiency of 

99%, and exhausting at 

Stack 265D.7; 

(4) One (1) reacted alumina truck loadout, constructed in 1981, with a 

maximum loading capacity 

of 21.0 tons/hr, controlled by the reacted alumina truck loadout 

baghouse, and exhausting at 

Stack 265D.9. 

One (1) reacted alumina truck loadout baghouse, constructed in 1981, with 

an air flow rate of 

1,750 acfm at 77oF, maximum outlet grain loading of 0.005 gr/dscf, and 

control efficiency of 

99.5%, and exhausting at Stack 265D.9; 

(5) One (1) un-reacted alumina storage tank/truck unloading, constructed 

in 1981, with a maximum 
loading capacity of 21.0 tons/hr, controlled by the un-reacted alumina 

storage tank/truck 

unloading baghouse, and exhausting at Stack 265D.10. 

One (1) un-reacted alumina storage tank/truck unloading baghouse, 

constructed in 1981, with 

an air flow rate of 50 acfm at 77oF, and control efficiency of 99%, and 

exhausting at Stack 

265D.10; 

(6) One (1) Building 265 baked anode vacuum system, constructed in 1981, 

with a maximum 

capacity of 20.25 tons of baked anodes per hour, controlled by the baked 

anode vacuum 

system baghouse, and exhausting at Stack 265D.11; and 

One (1) baked anode vacuum system baghouse, constructed in 1981, with an 

air flow rate of 

4,300 dscfm and maximum grain loading of 0.002 gr/dscf, and exhausting at 

Stack 265D.11. 
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Emission Limitations and Standards [326 IAC 2-7-5(1)] 

D.4.1 Particulate Emissions Limitations for Manufacturing Processes [326 

IAC 6-3-2] 

Pursuant to 326 IAC 6-3 (Particulate Emissions Limitations for 

Manufacturing Processes), the 

allowable particulate emission rate from the below listed processes shall 

be limited as follows: 

Facility Control Equipment Maximum Process 

Weight Rate 

(tons/hr) 

PM Emission 

Limit 

(lbs/hr) 

Green anode baking 

ring furnace 

A-446 pollution control 

system 

21.4 31.9 

Reacted alumina 

storage tank 

Reacted alumina storage 

tank baghouse 

7.5 15.8 

Reacted alumina truck 

loadout 

Reacted alumina truck 

loadout baghouse 

21.00 31.5 

Unreacted alumina 

storage tank/truck 

unloading 

Un-reacted alumina 

storage tank/truck 

unloading baghouse 

21.00 31.5 

Baked anode vacuum 

System 

Baked anode vacuum 

system baghouse 

20.25 30.8 

The above particulate emissions rates were determined from the following 

formulae: 

Interpolation of the data for the process weight rate up to sixty 

thousand (60,000) pounds per hour by 

use of the equation: 

E = 4.10 P0.67 

Where: E = rate of emission in pounds per hour; and 

P = process weight rate in tons per hour. 

D.4.2 PSD Minor Limitations [326 IAC 2-2] 
Pursuant to SSM 173-17780-00007, issued on July 21, 2004, the following 

limits shall apply to the 

green anode baking ring furnace: 

(a) The input of green anodes to the green anode baking ring furnace 

shall be limited to 187,645 

tons per twelve (12) consecutive month period with compliance determined 

at the end of 

each month; 

(b) The emission rate of PM shall not exceed 0.676 pounds of PM per ton 

of green anode; 

(c) The emission rate of PM10 shall not exceed 3.92 pounds of PM10 per 

ton of green anode; 

(d) The emission rate of SO2 shall not exceed 1.11 pounds of SO2 per ton 

of green anode; and 

(e) The emission rate of CO shall not exceed 3.57 pounds of CO per ton of 

green anode. 

Compliance with the throughput limits in Conditions D.4.2(a) and D.6.4(a) 

and the emission limits 

specified by Conditions D.3.2(a) through (c), D.4.2(b) through (e), 

D.5.2(a) and (b), and D.6.4(b) and 

(c), shall render the requirements of 326 IAC 2-2 not applicable to the 

green anode baking ring 

furnace. 

D.4.3 PSD Minor Limitations [326 IAC 2-2] 

The combined PM and PM10 emissions from the reacted alumina storage tank 

baghouse, the 

reacted alumina truck loadout baghouse, the un-reacted alumina storage 

tank/truck unloading 

baghouse, and the baked anode vacuum system baghouse shall be less than 

5.7 and 3.4 pounds per 
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hour, respectively. Compliance with these emissions limits shall ensure 

that the combined potential 

PM and PM10 emissions from the emissions units associated with these 

baghouses shall be less 

than 25 and 15 tons per year, respectively, which renders the 

requirements of PSD rule 326 IAC 2-2 

not applicable. 

D.4.4 PSD BACT [326 IAC 2-2-3] 

Pursuant to Construction Permit PSD (87) 1766, issued on November 3, 

1989; 

(a) Sulfur dioxide emissions from the A-446 dry alumina scrubbers shall 

be limited to 1.13 tons 

per day, and 35 tons per month, and 412 tons per twelve (12) consecutive 

month period with 

compliance determined at the end of each month; 

(b) Alcoa shall use the lowest sulfur content pitch commercially 

available. This shall be limited to 

a maximum of 0.80% sulfur; 

(1) The Permittee shall use the lowest sulfur content pitch commercially 

available. The 

sulfur content of coal tar pitch shall not exceed 0.80%; 

(2) Should pitch with a sulfur content of 0.80% become unavailable and 

the monthly 

average pitch sulfur content exceed this limit, then Alcoa shall have 

thirty (30) days 

from the end of the month in violation to provide to the OAQ 

documentation that 

lower sulfur pitch is not available and documentation for a new proposed 

pitch sulfur 

content BACT limit. The BACT limit in (1) above shall remain in effect 

until such time 

as the Commissioner approves a revised pitch sulfur content BACT limit. 

However, 

enforcement action will not be taken until such time as Alcoa has been 

given the 

opportunity to support, request and obtain approval for a revised BACT 

limit as 

described above. Testing to establish a new A-446 inlet SO2 emission 

rate, similar to 

that described in (1), will be required as part of any revised BACT limit 

approval; 

(3) If the monthly average sulfur content of the pitch used in the anodes 

exceeds 0.75% 

for any calendar month, then the Permittee shall report this to OAQ 

within thirty (30) 

days. This notification shall include a discussion of the reason the 

pitch sulfur content 

has increased and whether Alcoa has been able, or will be able, to obtain 

pitch with 
sulfur content below 0.75%. If pitch with a sulfur content of less than 

0.75% is not 

available, then Alcoa shall submit documentation of this and, within 

ninety (90) days 

of the notification, conduct an A-446 dry scrubber SO2 inlet (ring 

furnace outlet) test 

to reestablish the SO2 inlet emission rate pursuant to 326 IAC 7-4-

10(a)(4)(H), 

previously established in Condition No. 6 of Construction permit No. PSD 

(87) 1766, 

issued November 3, 1989. This test shall be conducted pursuant to 326 IAC 

3-6-2 at 

the current maximum achievable anode production rate and the result will 

be used to 

determine compliance; and 

(c) The natural gas throughput to the green anode baking ring furnace 

shall be less than 75 

million cubic feet per month and 600 million cubic feet per twelve (12) 

consecutive month 

period with compliance determined at the end of each month. 

D.4.5 Warrick County Sulfur Dioxide Emission Limitations [326 IAC 7-4-10] 

Pursuant to 326 IAC 7-4-10(a)(4)(H), the sulfur dioxide emissions from 

the green anode baking ring 

furnace shall not exceed 94.1 pounds per hour and 412 tons per twelve 

(12) consecutive month 

period with compliance determined at the end of each month. 

D.4.6 General Provisions Relating to NESHAP [326 IAC 12] [40 CFR 60 

Subpart S] [326 IAC 20-1] 

[40 CFR Part 63, Subpart A] [40 CFR 63.852] 

The provisions of 40 CFR Part 63, Subpart A- General Provisions, which 

are incorporated by 

reference in 326 IAC 20-1 apply to green anode baking ring furnace except 

when otherwise specified 

in 40 CFR Part 63, Subpart LL, Appendix A of this subpart. 
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D.4.7 TF and POM Emissions Limitations [326 IAC 12] [40 CFR 60 Subpart S] 

[326 IAC 20-24] 

[40 CFR 63.843] [40 CFR 63.847] 

(a) Pursuant to 40 CFR 63.843(c), and 40 CFR 63.847(a)(1), the emissions 

of total fluoride (TF) 

(as defined in 40 CFR 63.842), and polycyclic organic matter (POM) from 

the green anode 

ring furnace shall not exceed 0.20, and 0.18 pounds per ton of green 

anode, respectively. 

(b) Pursuant to 40 CFR 60.190(c), the emission limits in (a) shall 

satisfy the requirements of 

40 CFR 60 Subpart S. 

D.4.8 Plans and Procedures [326 IAC 12] [40 CFR 60 Subpart S] [326 IAC 

20-1] [40 CFR 63.6] 

[326 IAC 20-24] [40 CFR 63.850] 

Pursuant to 40 CFR 63.850 (c), the Permittee shall develop a written 

startup, shutdown, and 

malfunction (SSM) plan as described in 40 CFR 63.6(e) (3) that contains 

specific procedures to be 

followed for operating and maintaining the green anode ring furnace 

during periods of startup, 

shutdown, and malfunction and a program of corrective action for 

malfunctioning process and control 

systems used to comply with the standard. The plan does not have to be 

submitted with the permit 

application or included in the Part 70 operating permit. IDEM, OAQ may 

review the plan upon 

request. In addition to the information required in 40 CFR 63.6(e) (3), 

the plan shall include: 

(a) Procedures, including corrective actions, to be followed if for any 

baghouse the fan motor 

current (amperes) are less than that included in the most recent NESHAP 

Parametric Plan, 

approved by IDEM, OAQ, if dry alumina scrubbers reacted alumina 24-hour 

cumulative 

dense phase unit dumps is less than that included in the most recent 

NESHAP Parametric 

Plan, approved by IDEM, OAQ, if the alarm on any of the bag leak 

detection systems 

activates, or if visible emissions indicating abnormal operation are 

observed from the exhaust 

stacks of the green anode ring furnace whenever the bag leak detection 

systems are not 

operational; and 

(b) The SSM plan shall be maintained in the operating record. 

Compliance Determination Requirements 

D.4.9 TF, POM, and SO2 Control [326 IAC 2-7-6(6)] 

In order to comply with Conditions D.4.2(d), D.4.4(a), D.4.5, and 

D.4.7(a), at least 2 of the 3 A-446 
pollution control system reactor sections for TF, POM, and SO2 control 

shall be in operation at all 

times when the green anode baking ring furnace is in operation. During 

periods of readiness testing 

of the emergency diesel engine driven exhaust fan, emissions from the 

green anode baking ring 

furnace shall continue to exhaust through at least 2 of the 3 A-446 

pollution control system reactor 

sections, and shall not exhaust to the emergency diesel engine driven 

exhaust fan. 

D.4.10 Particulate Control [326 IAC 2-7-6(6)] 

(a) In order to comply with Condition D.4.1, and D.4.2(b) and (c), the PM 

and PM10 emissions 

from the following facilities shall be controlled by the baghouses as 

indicated in the table 

below. Each baghouse shall be in operation and control emissions from its 

associated 

facilities at all times when an emission unit that the baghouse controls 

is in operation; and 

Facility Baghouse 

Green anode baking ring 

furnace 

A-446 pollution control system 

Reacted alumina storage tank Reacted alumina storage tank 

baghouse 

Reacted alumina truck loadout Reacted alumina truck 

loadout baghouse 

Unreacted alumina storage 

tank/truck unloading 

Un-reacted alumina storage 

tank/truck unloading 

baghouse 
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Facility Baghouse 

Baked anode vacuum system Baked anode vacuum system 

baghouse 

(b) In the event that bag failure is observed in a multi-compartment 

baghouse except the A-446 

pollution control system baghouse, if operations will continue for ten 

(10) days or more after 

the failure is observed before the failed units will be repaired or 

replaced, the Permittee shall 

promptly notify IDEM, OAQ of the expected date the failed units will be 

repaired or replaced. 

The notification shall also include the status of the applicable 

compliance monitoring 

parameters with respect to normal, and the results of any response 

actions taken up to the 

time of notification. 

(c) In the event that bag failure is observed in the A-446 pollution 

control system baghouse, the 

Permittee shall take corrective action according to Condition D.4.16(d). 

D.4.11 Testing [326 IAC 7-10-4(b)] [326 IAC 12] [40 CFR 60 Subpart S] 

[326 IAC 20-1] [40 CFR 63, 

Subpart A] [326 IAC 20-24] [40 CFR 63.847] 

(a) Pursuant to 40 CFR 63.847(b), the Permittee shall prepare a site 

specific test plan prior to 

the performance test according to the requirements of 40 CFR 67.7(c). The 

test plan shall 

include procedures for conducting the performance tests required in 40 

CFR 63.848 for 

emission monitoring. In addition to the information required by 40 CFR 

63.7, the test plan 

shall include: 

(1) Procedures to ensure a minimum of three runs are performed annually 

for the 

primary control system for the green anode baking ring furnace; 

(2) Procedures to ensure that at least three runs are performed annually 

by a 

representative sample of the stacks satisfactory to IDEM, OAQ; 

(b) Pursuant to 40 CFR 63.847(d), all performance tests shall be 

conducted in accordance with 

the requirements of the general provisions in Subpart A of 40 CFR 63, the 

approved test 

plan, and the procedures in this section. 

(1) The Permittee shall measure and record the emission rates of TF and 

POM exiting 

the exhaust stacks of the A-446 pollution control system. Using the 

equations in 

paragraphs 40 CFR 63.847(e)(3) and (4) given below, the Permittee shall 

compute 

and record the average of at least three runs each year to meet the 

emission limits in 
condition D.4.7(a); 

Eb = ( Cs x Qsd ) (Equation 2) 

( Pb x K ) 

Where: 

Eb = emission rate of TF, lb/ton of green anodes produced; 

Cs = concentration of TF, mg/dscf; 

Qsd = volumetric flow rate of effluent gas, dscf/hr; 

Pb = quantity of green anode material placed in the furnace, ton/hr; and 

K = conversion factor, 453,600 mg/lb. 
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(2) Compute the emission rate of POM from each anode bake furnace using 

Equation 2, 

Where: 

Cs = concentration of POM, mg/dscf. 

(3) If the Permittee has performed more than one test for the green anode 

baking ring 

furnace during the previous consecutive twelve month, the average of all 

runs 

performed in the previous 12-month period shall be used to determine the 

contribution from the A-446 pollution control system; 

(4) Determine the weight of green anode material placed in the anode bake 

furnace 

using the monitoring devices required in Condition D.4.16(c); and 

(5) Determine the rate of green anode material introduced into the 

furnace by dividing 

the number of operating hours in the calendar month into the weight of 

green anode 

material used during the calendar month in which the performance test was 

conducted. 

D.4.12 Sulfur Dioxide [326 IAC 2-2-3] [326 IAC 7-4-10(a)(4)] 

In order to comply with Conditions D.4.4 and D.4.5, the Permittee shall 

utilize the following methods 

and/or calculations: 

(a) Compliance with the pounds per hour limitations specified in 

Condition D.4.5 shall be based 

on a stack test pursuant to 326 IAC 7-2-1(b); 

(b) Compliance with the tons per year limitations specified in Condition 

D.4.5 shall be based on a 

rolling twelve (12) consecutive month emission total. Monthly sulfur 

dioxide emissions shall 

be determined from calendar month material balances using actual average 

sulfur content 

and material throughput; 

(c) Pursuant to Construction Permit PSD (87) 1766, issued on November 3, 

1989, compliance 

shall be determined from the tested SO2 evolution (A-446 inlet) emission 

factor of 3.69 

pounds of SO2 per ton of baked carbon and the estimated A-446 dry alumina 

scrubber SO2 

removal efficiency based on the A-446 feed; 

(1) Daily records shall be used to calculate the average tons per hour 

baked carbon 

production rate and the average pounds per hour per reactor alumina feed 

rate for 

each day; 

(2) The daily average pounds per reactor alumina feed rate shall be used 

to determine 

the daily average percent SO2 removal based on Figure 1 (Feedrate vs. SO2 

Percent Removal – as submitted by Alcoa in their February 28, 1989, 

response 
letter); 

(3) The daily percent removal shall be used, with the SO2 evolution 

emission factor and 

the average production rate, to calculate the pounds per hour and pounds 

per ton of 

baked carbon daily average SO2 emission rates; 

(4) The daily SO2 emission rates shall be calculated by multiplying the 

daily average 

pounds of SO2 per ton of baked carbon times the daily baked carbon 

production to 

calculate the pounds per day SO2 emission rates; and. 

(5) The daily SO2 emission rates shall then be summed to calculate the 

tons per month 

and the tons per twelve (12) consecutive month period SO2 emission rates. 
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Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

D.4.13 Test Methods and Procedures [326 IAC 12] [40 CFR 60 Subpart S] 

[326 IAC 20-1] 

[40 CFR 63, Subpart A] [326 IAC 20-24] [40 CFR 63.849] 

Pursuant to 40 CFR 63.849, the Permittee shall use the following 

reference methods to determine 

compliance with the applicable emission limits for TF: 

(a) Method 1 in appendix A to 40 CFR Part 60 for sample and velocity 

traverses; 

(b) Method 2 in appendix A to 40 CFR Part 60 for velocity and volumetric 

flow rate; 

(c) Method 3 in appendix A to 40 CFR Part 60 for gas analysis; 

(d) Method 13A or Method 13B in appendix A to 40 CFR Part 60, or an 

approved alternative, for 

the concentration of TF; and 

(e) Method 315 in appendix A to 40 CFR 63 or an approved alternative 

method for the 

concentration of POM. 

D.4.14 Testing Requirements [326 IAC 2-7-6(1), (6)] [326 IAC 2-1.1-11] 

(a) In order to determine compliance with Condition D.4.2(b), and (c), 

and no later than January 

5, 2010 or within 5 years from the date of the last valid compliance 

test, whichever is later, 

the Permittee shall perform PM, and PM10 testing for the green anode 

baking ring furnace, 

utilizing methods as approved by the Commissioner. These tests shall be 

repeated at least 

once every five (5) years from the date of the valid compliance 

demonstration. PM10 

includes filterable and condensable PM10. Testing shall be conducted in 

accordance with 

Section C – Performance Testing. During the stack test, the Permittee 

shall determine the 

sensitivity of the bag leak detection system and calibrate the 

particulate concentration 

readings of the electrodynamic bag leak detector in order to provide an 

output relative to 

outlet grain loading levels. 

(b) In order to determine compliance with Condition D.4.2(d) and no later 

than January 5, 2010 

or 5 years from the date of the last valid compliance test, whichever is 

later, the Permittee 

shall perform SO2 testing for the green anode baking ring furnace, 

utilizing methods as 

approved by the Commissioner. This test shall be repeated at least once 

every five (5) years 

from the date of the valid compliance demonstration. Testing shall be 

conducted in 

accordance with Section C- Performance Testing. 

(c) In order to determine compliance with Condition D.4.2(e) and no later 

than January 5, 2010 
or 5 years from the date of the last valid compliance test, whichever is 

later, the Permittee 

shall perform CO testing for the green anode baking ring furnace, 

utilizing methods as 

approved by the Commissioner. This test shall be repeated at least once 

every five (5) years 

from the date of the valid compliance demonstration. Testing shall be 

conducted in 

accordance with Section C- Performance Testing. 

D.4.15 Emergency Bypass Engine Operation 

Pursuant to Operation Condition 3 of PC (87) 1840, issued on February 26, 

1990, the emergency 

bypass engine shall be operated in accordance with the manufacturer’s 

specifications. 

Compliance Monitoring Requirements [326 IAC 2-7-6 (1)] [326 IAC 2-7-5 

(1)] [326 IAC 12] [40 CFR 60 

Subpart S] [326 IAC 20-1] [40 CFR 63, Subpart A] [326 IAC 20-24] [40 CFR 

63.847] [40 CFR 63.848] 

D.4.16 Emission Monitoring Requirements [326 IAC 12] [40 CFR 60 Subpart 

S] [326 IAC 20-24] 

[40 CFR 63.847] [40 CFR 63.848] 

(a) Pursuant to 40 CFR 63.848(g) and (l), 40 CFR 63.8(f), and SSM 173-

21948-00007, the 

Permittee shall operate the bag leak detection system installed on each 

stack of each 

baghouse of the A-446 pollution control system. The Permittee shall 

visually inspect the 

exhaust stacks of the A-446 pollution control system on a daily basis for 

evidence of any 

visible emissions indicating abnormal operation whenever the bag leak 

detection systems are 
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not operational. 

(b) Pursuant to 40 CFR 63.847(h) and 40 CFR 63.848(f), the Permittee 

shall operate, calibrate, 

and maintain continuous parameter monitoring systems for the measurement 

of fan motor 

current (amperes) for air flow and reacted alumina cumulative 24-hour 

dense phase unit 

dumps for alumina flow for the dry alumina scrubbers of the A-446 

pollution control system at 

rates and frequencies included in the most recent NESHAP Parametric Plan 

approved by 

IDEM, OAQ. 

(c) Pursuant to 40 CFR 63.848(j), the Permittee shall operate, and 

maintain a monitoring device 

to determine the daily weight of the green anode material placed in the 

green anode baking 

ring furnace. 

(d) Pursuant to 40 CFR 63.848(h), if for any baghouse the fan motor 

current (amperes) are less 

than that included in the most recent NESHAP Parametric Plan approved by 

IDEM, OAQ, if 

for any dry alumina scrubber the reacted alumina dense phase unit 24-hour 

cumulative 

dumps are lower than that included in the most recent NESHAP Parametric 

Plan approved 

by IDEM, OAQ, if the alarm on any of the bag leak detection systems 

activates, or if visible 

emissions indicating abnormal operation are observed from the exhaust 

stacks of the A-446 

pollution control system during the time the bag leak detection system is 

malfunctioning, then 

the Permittee shall initiate the corrective action procedures identified 

in the SSM plan within 

one (1) hour. Failure to initiate the corrective action procedures within 

one (1) hour or to take 

the necessary corrective actions to remedy the problem is a violation. 

(e) Pursuant to 40 CFR 63.848(k), the Permittee shall submit recommended 

accuracy 

requirements to IDEM, OAQ, for review and approval. All monitoring 

devices required by this 

section must be certified by the Permittee to meet the accuracy 

requirements and must be 

calibrated in accordance with the manufacturer's instructions. 

(f) Pursuant to 40 CFR 63.848(i), if the limit for a given operating 

parameter monitoring the 

A-446 pollution control system is exceeded six times in any semiannual 

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 24-hour period. 

D.4.17 Bag Leak Detection System and Alternative Monitoring Plan (AMP) 

[SPM 173-21948-00007] 

[326 IAC 12] [40 CFR 60 Subpart S] [326 IAC 20-24] [40 CFR 63.847] [40 

CFR 63.848] 

The Permittee shall operate a continuous bag leak detection system for 

each baghouse of the A-446 

pollution control system. The bag leak detection system shall meet the 

following requirements: 

(a) Each electrodynamic bag leak detection system shall be calibrated, 

operated, and 

maintained according to the manufacturer's recommendations; 

(b) The bag leak detection system shall be certified by the manufacturer 

to be capable of 

detecting PM emissions at concentrations of ten (10) milligrams per 

actual cubic meter 

(0.0044 grains per actual cubic foot) or less; 

(c) The bag leak detection system sensor shall provide output of relative 

or absolute PM 

loadings; 

(d) The bag leak detection system shall be equipped with a device to 

continuously record the 

output signal from the sensor; 

(e) The bag leak detection system shall be equipped with an alarm system 

that will sound 

automatically when an increase in relative PM emissions over a preset 

level is detected. The 

alarm shall be located where it is easily heard by plant operating 

personnel; 
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(f) Where multiple detectors are required, the system's instrumentation 

and alarm may be 

shared among detectors; 

(g) The baseline output shall be established by adjusting the range and 

the averaging period of 

the device and establishing the alarm set points and the alarm delay 

time; 

(h) Following initial adjustment of the system, the Permittee shall not 

adjust the sensitivity or 

range, averaging period, alarm set points, or alarm delay time except as 

detailed in the PMP. 

In no case may the sensitivity be increased by more than one hundred 

(100%) percent or 

decreased more than fifty (50%) percent over a 365-day period unless such 

adjustment 

follows a complete fabric filter inspection which demonstrates that the 

fabric filter is in good 

operating condition; 

(i) In the event that a bag leak detection system should malfunction, 

fail or otherwise need 

repair, the Permittee shall perform visible emissions notations of the 

stack exhaust 

associated with that bag leak detection system as follows: 

(1) Visible emission notations of the stack exhaust shall be performed 

once per day 

during normal daylight operations. A trained employee shall record 

whether 

emissions are normal or abnormal; 

(2) For processes operated continuously, "normal" means those conditions 

prevailing, or 

expected to prevail, eighty percent (80%) of the time the process is in 

operation, not 

counting startup or shut down time; 

(3) In the case of batch or discontinuous operations, readings shall be 

taken during that 

part of the operation that would normally be expected to cause the 

greatest 

emissions; 

(4) A trained employee is an employee who has worked at the plant at 

least one (1) 

month and has been trained in the appearance and characteristics of 

normal visible 

emissions for that specific process; and 

(5) Pursuant to 40 CFR 63.848(f), if the alarm on any of the bag leak 

detection systems 

activates, or if visible emissions indicating abnormal operation are 

observed from the 

exhaust stacks of the A-446 pollution control system during the time the 

bag leak 
detection system is malfunctioning, then the Permittee shall initiate the 

corrective 

action procedures identified in the SSM plan within one (1) hour. Failure 

to initiate 

the corrective action procedures within one (1) hour or to take the 

necessary 

corrective actions to remedy the problem is a violation. 

D.4.18 Visible Emissions Notations 

(a) Visible emission notations of the stack exhaust for baked anode 

vacuum system baghouse 

shall be performed once per day. 

(b) In the case of batch or discontinuous operations, readings shall be 

taken during normal 

operations 

(c) If visible emissions are observed, an employee certified to perform 

an EPA Method 9 

evaluation shall determine whether opacity exceeds forty percent (40%) in 

one (1) six (6) 

minute averaging period as determined in 326 IAC 5-1-4, and: 

(1) If opacity does not exceed forty percent (40%) per Method 9, the 

Permittee shall 

shutdown the associated process as soon as practical unless either: 

(vii) the Permittee is able to bring the opacity below forty percent 

(40%) within a 

reasonable period of time, or 
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(viii) the situation qualifies as an ―emergency‖ under 326 IAC 2-7-1(12). 

If the Permittee continues to operate the associated process after 

determining the 

opacity exceeds forty percent (40%) per Method 9, then the Permittee 

shall perform 

an additional Method 9 reading every four (4) daylight hours until the 

opacity is below 

forty percent (40%) per Method 9. 

(2) If opacity does not exceed forty percent (40%) per the Method 9 

observation 

referenced above, inspection of the baghouse shall be scheduled at the 

next 

available process down time. Repairs shall be scheduled as expeditiously 

as 

pratical, based on the inspection results. 

(3) If opacity exceeds twenty percent (20%) per any Method 9 observations 

referenced 

above, the Permittee shall notify IDEM, if the Permittee anticipates that 

operations 

will continue for ten (10) days or more before the failed baghouse units 

will be 

repaired or replaced. 

Failure to take the response steps required by Condition D.4.18(c) upon 

observation of visible 

emissions shall be considered a deviation from this permit. 

Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-

7-19] [326 IAC 12] 

[40 CFR 60 Subpart S] [326 IAC 20-1] [40 CFR 63, Subpart A] [326 IAC 20-

24] [40 CFR 63.850] 

D.4.19 Record Keeping Requirements 

(a) To document compliance with Condition D.4.2(a), the Permittee shall 

maintain monthly 

records of the throughput of green anodes to the green anode baking ring 

furnace. 

(b) To document compliance with Condition D.4.4, and D.4.12: 

(1) Records of the A-446 outlet SO2 emission rates and of the dry alumina 

scrubber 

operations shall be maintained; 

Records of the dry alumina scrubber operations shall include the 

following: 

(A) An estimate of the daily average alumina feed rates in pounds per 

hour per 

reactor; and 

(B) The time periods when any of the reactors are out of service and 

summary of 

all maintenance (routine, preventative or malfunction related) performed 

on 

the A-446 system. 

(2) Records of pitch sulfur content based on vendor analysis shall be 

maintained for the 
most recent twenty-four (24) month period. 

(c) To document compliance with Condition D.4.4(c), the Permittee shall 

maintain records of the 

monthly ring furnace natural gas throughput. 

(d) To document compliance with Conditions D 4.2(b), (c), (d), and (e), 

and D.4.5, the Permittee 

shall maintain records of the stack tests results as required by 

Conditions D.4.12(a), and 

D.4.14. 

(e) To document compliance with Condition D.4.17(a), the Permittee shall 

keep a log of the 

calibration test results for A-446 pollution control system baghouses 

leak detectors; 

(f) To document compliance with Condition D.4.17(i), the Permittee shall 

maintain records of 

daily visible emission notations of the stack exhaust for A-446 pollution 

control system 

baghouses, when the applicable bag leak detection system malfunctions, 

fails or otherwise 
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needs repair. The Permittee shall include in its daily record when a 

visible emission notation 

is not taken and the reason for the lack of visible emission notation 

(e.g. the process did not 

operate that day). 

(g) To document compliance with Condition D.4.18, the Permittee shall 

maintain records of daily 

visible emission notations for the stack exhaust. The Permittee shall 

include in its daily 

record when a visible emission notation is not taken and the reason for 

the lack of visible 

emission notation (e.g. the process did not operate that day). 

(h) To document compliance with Condition D.4.18, the Permittee shall 

maintain records of the 

Method 9 readings. 

(i) The Permittee shall maintain the following as required under 

Conditions D.4.10 and D.4.18: 

(1) Documentation of all response steps implemented per event. 

(j) All records shall be maintained in accordance with Section C -

General Record Keeping 

Requirements, of this permit. 

D.4.20 NESHAP Record Keeping Requirements [326 IAC 12] [40 CFR 60 Subpart 

S] [326 IAC 20-1] 

[40 CFR 63, Subpart A] [326 IAC 20-24] [40 CFR 63.850 (c) and (e)] 

(a) Pursuant to 40 CFR 63.850(c)(2), the Permittee shall keep records of 

each event as required 

by 40 CFR 63.10(b) and record if an action taken during a startup, 

shutdown, or malfunction 

is not consistent with the procedures in the plan as required by 

Condition D.4.8. 

(b) Pursuant to 40 CFR 63.850(e), the Permittee shall maintain files of 

all information (including 

all reports and notifications) required by 40 CFR 63.10(b) and 40 CFR 

63.850. 

(1) The Permittee may retain records on microfilm, on a computer, on 

computer disks, 

on magnetic tape, or on microfiche; and 

(2) In addition to the general records required by 40 CFR 63.10(b), the 

Permittee shall 

maintain records of the following information: 

(i) A copy of the startup, shutdown, and malfunction plan as required in 

Condition D.4.8; 

(ii) Daily production rate of green anode material placed in the green 

anode 

baking ring furnace; 

(iii) Records, such as a checklist or the equivalent, demonstrating that 

the daily 

visual inspection of the A-446 pollution control exhaust stack were 

performed 
including the results of each inspection during the time a bag leak 

detection 

system was malfunctioning, failed or otherwise needed repair; and 

(iv) Records documenting the corrective actions taken when the limit for 

an 

operating parameter established in the most recent NESHAP Parametric 

Plan approved by IDEM, OAQ were exceeded, if the alarm on any of the bag 

leak detection systems was activated, or if visible emissions indicating 

abnormal operation were observed from the exhaust stacks of the A-446 

pollution control system during the time the bag leak detection system 

was 

malfunctioning, failed or otherwise needed repair. 
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D.4.21 Reporting Requirements 

The Permittee shall report a quarterly summary of the information to 

document compliance with 

Conditions D.4.2(a), 4.4(a) and (c), and D.4.5 to the addresses listed in 

Section C – General 

Reporting Requirements, of this permit, using the reporting forms located 

at the end of this permit, or 

its equivalent, within thirty (30) days after the end of the quarter 

being reported. The report submitted 

by the Permittee does require the certification by the ―responsible 

official‖ as defined by 

326 IAC 2-7-1(34). 

D.4.22 NESHAP Reporting Requirements [326 IAC 12] [40 CFR 60 Subpart S] 

[326 IAC 20-1] [40 CFR 63, 

Subpart A] [326 IAC 20-24] [40 CFR 63.850(c), (d), and (e)] 

(a) Pursuant to 40 CFR 63.650(b), the Permittee shall submit a summary of 

all performance 

tests to IDEM, OAQ on an annual basis. 

(b) Pursuant to 40 CFR 63.650(c)(2), the Permittee shall report if an 

action taken during a 

startup, shutdown, or malfunction is not consistent with the procedures 

in the SSM plan as 

required by Condition D.4.8. 

(c) Pursuant to 40 CFR 63.850(d), and 40 CFR Part 63.10(e)(3), the 

Permittee shall submit a 

report, or summary report, if measured emissions are in excess of the 

applicable standard. 

The report shall contain the information specified in 40 CFR Part 

63.10(e)(3)(v) and be 

submitted semiannually unless quarterly reports are required as a result 

of excess emissions. 

The report shall be submitted to the address listed in Section C -

General Reporting 

Requirements, of this permit, using the reporting forms located at the 

end of this permit, or 

their equivalent, within thirty (30) days after the end of the semiannual or if necessary after 

the end of the quarter being reported. The report submitted by the 

Permittee does require the 

certification by the ―responsible official‖ as defined by 326 IAC 2-7-

1(34). 

(d) Pursuant to 40 CFR 63.850(e)(3), the Permittee may report required 

information on paper or 

on a labeled computer disc using commonly available and compatible 

computer software. 
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Permit Reviewer: Dr. Trip Sinha 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAG 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION 

Part 70 Green Anode Throughput Quarterly Report 

Source Name: Alcoa Inc. - Warrick Operations 

Source Address: Jct. IN Hwys. 66 & 61, Newburgh, Indiana 47629-0010 

Mailing Address: Bldg. 860 E, P.O. Box 10, Newburgh, Indiana 47629 

Part 70 Permit No.: T173-6627-0 0007 

Facility: Green anode baking ring furnace 

Parameter: Throughput of green anodes 

Limit: 187,645 tons per twelve (12) consecutive month period 

Quarter _______ Year: ______ 

Month 

Green anodes (tons) 

Green anodes (tons) 

Green anodes (tons) 

This Month 

Previous 11 Months 

12 Month Total 

. No deviation occurred in this month. 

. Deviation/s occurred in this month. 

Deviation has been reported on: 

Submitted by: 

Title/Position: 

Signature: 

Date: 

Phone: 

Attach a signed certification to complete this report. 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 79 of 178 

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Permit Reviewer: Dr. Trip Sinha 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION 

Part 70 Quarterly Report 

Source Name: Alcoa Inc. - Warrick Operations 

Source Address: Jct. IN Hwys. 66 & 61, Newburgh, Indiana 47629-0010 

Mailing Address: Bldg. 860 E, P.O. Box 10, Newburgh, Indiana 47629 

Part 70 Permit No.: T173-6627-0 0007 

Facility: Green anode baking ring furnace dry scrubber 

Parameter: Sulfur Dioxide Emissions 

Limit: 35 tons per month and 412 tons per twelve (12) consecutive month. 

Monthly sulfur 

dioxide emissions shall be determined from calendar month material 

balances using 

actual average sulfur content and material throughput. 

Quarter _______ Year: ______ 

Month 

Sulfur Dioxide Emissions 

(tons) 

Sulfur Dioxide Emissions 

(tons) 

Sulfur Dioxide Emissions 

(tons) 

This Month 

Previous 11 Months 

12 Month Total 

. No deviation occurred in this month. 

. Deviation/s occurred in this month. 

Deviation has been reported on: 

Submitted by: 

Title/Position: 

Signature: 

Date: 

Phone: 

Attach a signed certification to complete this report. 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

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Permit Reviewer: Dr. Trip Sinha 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION 

Part 70 Anode Baking Furnace Natural Gas Quarterly Report 

Source Name: Alcoa Inc. - Warrick Operations 

Source Address: Jct. IN Hwys. 66 & 61, Newburgh, Indiana 47629-0010 

Mailing Address: Bldg. 860 E, P.O. Box 10, Newburgh, Indiana 47629 

Part 70 Permit No.: T173-6627-0 0007 

Facility: Green anode baking ring furnace 

Parameter: Natural gas throughput 

Limit: Less than 75 million cubic feet per month 

Less than 600 million cubic feet per twelve (12) consecutive month period 

Quarter _______ Year: ______ 

Month 

Natural Gas Usage 

(million cubic feet) 

Natural Gas Usage 

(million cubic feet) 

Natural Gas Usage 

(million cubic feet) 

This Month 

Previous 11 Months 

12 Month Total 

. No deviation occurred in this month. 

. Deviation/s occurred in this month. 

Deviation has been reported on: 

Submitted by: 

Title/Position: 

Signature: 

Date: 

Phone: 

Attach a signed certification to complete this report. 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

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Permit Reviewer: Dr. Trip Sinha 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION 

Part 70 Quarterly Report 

Source Name: Alcoa Inc. - Warrick Operations 

Source Address: Jct. IN Hwys. 66 & 61, Newburgh, Indiana 47629-0010 

Mailing Address: Bldg. 860 E, P.O. Box 10, Newburgh, Indiana 47629 

Part 70 Permit No.: T173-6627-0 0007 

Facility: A-446 Pollution Control System 

Parameter: Maximum monthly calculated pounds of SO2 per ton of baked 

carbon and the 

monthly average percentage sulfur of pitch used in anodes 

Limit: 3.69 pounds of SO2 per ton of baked carbon and 0.80% Sulfur 

Quarter _______ Year: ______ 

Month 

Maximum calculated pounds of 

SO2 per ton of baked Carbon 

Average % S of pitch 

used in anodes 

. No deviation occurred in this month. 

. Deviation/s occurred in this month. 

Deviation has been reported on: 

Submitted by: 

Title/Position: 

Signature: 

Date: 

Phone: 

Attach a signed certification to complete this report. 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

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Permit Reviewer: Dr. Trip Sinha 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION 

Part 70 Anode Baking Plant SO2 Quarterly Report 

Source Name: Alcoa Inc. - Warrick Operations 

Source Address: Jct. IN Hwys. 66 & 61, Newburgh, Indiana 47629-0010 

Mailing Address: Bldg. 860 E, P.O. Box 10, Newburgh, Indiana 47629 

Part 70 Permit No.: T173-6627-00007 

Facility: A-446 Pollution Control System 

Pollutant and Parameter: Maximum calculated daily average pounds of SO2 

per hour, lowest and 

highest daily average alumina feed rate and the maximum average baked 

carbon production and associated aluminum feed rate. 

Quarter _______ Year: ______ 

Parameter First month of the 

quarter 

Second month of the 

quarter 

Third month of the 

quarter 

Maximum calculated daily average lbs 

SO2 per hour (lbs/hr) 

Lowest daily average alumina feed rate 

(lbs/hr/reactor) 

Highest daily average alumina feed rate 

(lbs/hr/reactor) 

Maximum daily average baked carbon 

production rate (tons/hr) 

Daily average alumina feed rate on the 

day when the maximum daily average 

carbon production rate was 

attained(lbs/hr/reactor) 

. No deviation occurred in this month. 

. Deviation/s occurred in this month. 

Deviation has been reported on: 

Submitted by: 

Title/Position: 

Signature: 

Date: 

Phone: 

Attach a signed certification to complete this report. 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

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Permit Reviewer: Dr. Trip Sinha 

SECTION D.5 ANODE ASSEMBLY & SPENT ANODE PLANT FACILITY OPERATION 

CONDITIONS 

Facility Description [326 IAC 2-7-5(15)] 

(The information describing the process contained in this facility 

description box is descriptive 

information and does not constitute enforceable conditions.) 

(1) One (1) mechanical blasting operation, identified as Anode Butt Blast 

Machine, constructed in 

2001, with a maximum process weight rate of 181 tons of spent anode 

assemblies per hour, 

controlled by Anode Butt Blast Machine Baghouse, and exhausting at Stack 

132.9. 

One (1) baghouse, identified as Anode Butt Blast Machine Baghouse, with a 

gas flow rate of 

12,000 acfm at 70.F, and exhausting at Stack 132.9; 

(2) One (1) mechanical blasting operation, identified as Tumbleblast, 

constructed in 1979, with a 

maximum process weight rate of 60 tons of loose butts or cast iron pigs 

per hour, controlled by 

Tumbleblast Baghouse, and exhausting at Stack 132.7. 

One (1) baghouse, identified as Tumbleblast Baghouse, with a gas flow 

rate of 27,000 acfm at 

70.F, and exhausting at Stack 132.7; 

(3) One (1) Impactor, constructed in 1979, with a maximum process weight 

rate of 176 tons of 

loose butts per hour, controlled by Impactor Baghouse, and exhausting at 

Stack 132.7. 

One (1) baghouse, identified as Impactor Baghouse, with a gas flow rate 

of 27,930 acfm at 

70. F, and exhausting at Stack 132.7; 

(4) One (1) Rod Cleaning Machine, constructed in 1996, with a maximum rod 

process rate of 200 

rods per hour, with a maximum process weight rate of 5.23 tons of rods 

per hour, controlled by 

the rod brush cleaning baghouse and exhausting at Stack 132.3; 

(5) One (1) Butt Storage Tank, constructed in 1979, with a maximum 

process weight rate of 174 

tons of loose butts per hour, controlled by Tumbleblast baghouse, and 

exhausting at Stack 

132.7; 

(6) One (1) iron casting station, identified as In-Line Caster, 

constructed in 1979, with a maximum 

process rate of 54 tons of new anodes per hour, 2.28 tons of iron per 

hour, and 5.23 tons of 

rods per hour, emissions uncontrolled, and exhausting at Stack 132.8; 

(7) Two (2) Induction Furnaces, constructed in 1982, with a maximum 

process weight rate of 1.14 

tons of iron per hour each, controlled by Induction Furnace Baghouse, and 

exhausting at Stack 

132.6. 
One (1) baghouse, identified as Induction Furnace Baghouse, with a gas 

flow rate of 10,200 

acfm at 100.F, and exhausting at Stack 132.6; and 

(8) One (1) Spent Anode Storage Pad, constructed in 1979, with a maximum 

process weight rate 

of 1.32 tons per hour, and emissions uncontrolled. 
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Permit Reviewer: Dr. Trip Sinha 

Emission Limitations and Standards [326 IAC 2-7-5(1)] 

D.5.1 Particulate Emissions Limitations for Manufacturing Processes [26 

IAC 6-3-2] 

Pursuant to 326 IAC 6-3-2 (Particulate Emission Limitations for 

Manufacturing Processes), the 

allowable particulate emission rate from the spent anode plant, shall be 

limited as follows: 

Facility Maximum Process Weight Rate 

(tons/hr) 

PM Emission Limit 

(lbs/hr) 

Anode butt blast machine 142.4 tons (121 tons of steel and 21.4 

tons of green anodes) 

54.9 

Tumbleblast blasting and butt 

storage tank operation 

234 60.2 

Impactor 176 57.1 

Rod cleaning machine 5.23 12.4 

Iron casting 61.5 46.5 

Induction furnaces 2.28 7.12 

The above particulate emissions rates were determined from the following 

formulae: 

Interpolation of the data for the process weight rate up to sixty 

thousand (60,000) pounds per hour by 

use of the equation: 

E = 4.10 P0.67 

where: E = rate of emission in pounds per hour; and 

P = process weight rate in tons per hour. 

or 

Interpolation and extrapolation of the data for the process weight rate 

in excess of sixty thousand 

(60,000) pounds per hour by use of the equation: 

E = 55.0 P0.11 - 40 

where: E = rate of emission in pounds per hour; and 

P = process weight rate in tons per hour. 

When the process rate exceeds two hundred (200) tons per hour, the 

allowable emission may exceed 

the emission limits shown in the above table; provided the concentration 

of particulate in the 

discharge gases to the atmosphere is less than one-tenth (0.10) pound per 

thousand (1,000) pounds 

of gases. 

D.5.2 PSD Minor Limitations [326 IAC 2-2] 

Pursuant to SSM 173-17780-00007, issued on July 21, 2004, the following 

limits shall apply to the 

anode butt blast machine: 

(a) The PM emission rate shall not exceed 1.029 pounds per hour; and 

(b) The PM10 emission rate shall not exceed 0.857 pounds per hour. 
Compliance with the throughput limits in Conditions D.4.2(a) and D.6.4(a) 

and the emission limits 

specified by Conditions D.3.2(a) through (c), D.4.2(b) through (e), 

D.5.2(a) and (b), and D.6.4(b) and 

(c), shall render the requirements of 326 IAC 2-2 not applicable to the 

anode butt blast machine. 
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Permit Reviewer: Dr. Trip Sinha 

Compliance Determination Requirements 

D.5.3 Testing Requirements [326 IAC 2-7-6(1), (6)] [326 IAC 2-1.1-11] 

In order to demonstrate compliance with Conditions D.5.1 and D.5.2 and no 

later than July 9, 2013 or 

within 5 years from the date of the last valid compliance test, whichever 

is later, the Permittee shall 

perform PM, and PM10 testing for the anode butt blast machine, utilizing 

methods as approved by the 

Commissioner. These tests shall be repeated at least once every five (5) 

years from the date of the 

valid compliance demonstration. PM10 includes filterable and condensable 

PM10. Testing shall be 

conducted in accordance with Section C- Performance Testing. During the 

stack test, the Permittee 

shall determine the sensitivity of the bag leak detection system and 

calibrate the particulate 

concentration readings of the electrodynamic bag leak detector in order 

to provide an output relative 

to outlet grain loading levels. 

D.5.4 Particulate Control [326 IAC 2-7-6(6)] 

(a) In order to comply with Condition D.5.1, the PM emissions from the 

following facilities shall 

be controlled by the baghouses as indicated in the table below. Each 

baghouse shall be in 

operation and control emissions from its associated facilities at all 

times when an emission 

unit that the baghouse controls is in operation; and 

Facility Baghouse 

Anode butt blast machine Anode butt blast machine 

baghouse 

Tumbleblast blasting and Butt 

Storage Tank operation 

Tumbleblast baghouse 

Impactor Impactor baghouse 

Induction Furnaces Induction furnace baghouse 

(b) In the event that bag failure is observed in a multi-compartment 

baghouse, if operations will 

continue for ten (10) days or more after the failure is observed before 

the failed units will be 

repaired or replaced, the Permittee shall promptly notify IDEM, OAQ of 

the expected date the 

failed units will be repaired or replaced. The notification shall also 

include the status of the 

applicable compliance monitoring parameters with respect to normal, and 

the results of any 

response actions taken up to the time of notification. 

Compliance Monitoring Requirements [326 IAC 2-7-6(1)] [326 IAC 2-7-5(1)] 

D.5.5 Bag Leak Detection System 

The Permittee shall operate the continuous bag leak detection system for 

the anode butt blast 
machine. The bag leak detection system shall meet the following 

requirements: 

(a) Each electrodynamic bag leak detection system shall be calibrated, 

operated, and 

maintained according to the manufacturer's recommendations; 

(b) The bag leak detection system shall be certified by the manufacturer 

to be capable of 

detecting PM emissions at concentrations of ten (10) milligrams per 

actual cubic meter 

(0.0044 grains per actual cubic foot) or less; 

(c) The bag leak detection system sensor shall provide output of relative 

or absolute PM 

loadings; 

(d) The bag leak detection system shall be equipped with a device to 

continuously record the 

output signal from the sensor; 

(e) The bag leak detection system shall be equipped with an alarm system 

that will sound 

automatically when an increase in relative PM emissions over a preset 

level is detected. The 

alarm shall be located where it is easily heard by plant operating 

personnel; 

(f) The bag leak detector shall be installed downstream of the fabric 

filter; 
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Permit Reviewer: Dr. Trip Sinha 

(g) Where multiple detectors are required, the system's instrumentation 

and alarm may be 

shared among detectors; 

(h) The baseline output shall be established by adjusting the range and 

the averaging period of 

the device and establishing the alarm set points and the alarm delay 

time; 

(i) Following initial adjustment of the system, the Permittee shall not 

adjust the sensitivity or 

range, averaging period, alarm set points, or alarm delay time except as 

detailed in the PMP. 

In no case may the sensitivity be increased by more than one hundred 

(100%) percent or 

decreased more than fifty (50%) percent over a 365-day period unless such 

adjustment 

follows a complete fabric filter inspection which demonstrates that the 

fabric filter is in good 

operating condition; and 

(j) In the event that a bag leak detection system should malfunction, 

fail or otherwise need 

repair, the Permittee shall perform visible emissions notations of the 

stack exhausts 

associated with that bag leak detection system as follows: 

(1) Visible emission notations of the stack exhausts shall be performed 

once per day 

during normal daylight operations. A trained employee shall record 

whether 

emissions are normal or abnormal; 

(2) For processes operated continuously, "normal" means those conditions 

prevailing, or 

expected to prevail, eighty percent (80%) of the time the process is in 

operation, not 

counting startup or shut down time; 

(3) In the case of batch or discontinuous operations, readings shall be 

taken during that 

part of the operation that would normally be expected to cause the 

greatest 

emissions; 

(4) A trained employee is an employee who has worked at the plant at 

least one (1) 

month and has been trained in the appearance and characteristics of 

normal visible 

emissions for that specific process and 

(5) For the anode butt blast machine operation, if abnormal emissions are 

observed, the 

Permittee shall take reasonable response steps in accordance with Section 

C –

Response to Excursions and Exceedances. Failure to take response steps in 

accordance with Section C – Response to Excursions and Exceedances, shall 

be 
considered a deviation from this permit. 

D.5.6 Bag Leak Detection Alarm Activation 

In the event that a bag leak detection system alarm is activated for any 

reason, the Permittee shall 

take corrective actions specified in Section C- Response to Excursions 

and Exceedances, and the 

following response steps: 

For the anode butt blast machine baghouse which is a single compartment 

baghouse, if failure is 

indicated by an opacity violation or a bag leak detection alarm 

activation that is not a false alarm, or if 

bag failure is determined by other means, such as daily checks of the 

particulate concentration 

readings from electrodynamic bag leak detectors or visible emissions 

notations, then the associated 

process will be shut down immediately until the failed units have been 

repaired or replaced. 

Operations may continue only if the event qualifies as an emergency and 

the Permittee satisfies the 

requirements of the emergency provisions of this permit (Section C -

Emergency Provisions). 

D.5.7 Visible Emissions Notations 

(a) Visible emission notations of the stack exhaust for Tumbleblast 

Baghouse, and Impactor 

Baghouse shall be performed once per day. 
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Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

(b) In the case of batch or discontinuous operations, readings shall be 

taken during normal 

operations. 

(c) If visible emissions are observed, an employee certified to perform 

and EPA Method 9 

evaluation shall determine whether opacity exceeds forty percent (40%) in 

one (1) six (6) 

minute averaging period as determined in 326 IAC 5-1-4, and: 

(1) If opacity does not exceed forty percent (40%) per Method 9, the 

Permittee shall 

shutdown the associated process as soon as practical unless either: 

(ix) the Permittee is able to bring the opacity below forty percent (40%) 

within a 

reasonable period of time, or 

(x) the situation qualifies as an ―emergency‖ under 326 IAC 2-7-1(12). 

If the Permittee continues to operate the associated process after 

determining the 

opacity exceeds forty percent (40%) per Method 9, then the Permittee 

shall perform 

an additional Method 9 reading every four (4) daylight hours until the 

opacity is below 

forty percent (40%) per Method 9. 

(2) If opacity does not exceed forty percent (40%) per the Method 9 

observation 

referenced above, inspection of the baghouse shall be scheduled at the 

next 

available process down time. Repairs shall be scheduled as expeditiously 

as 

pratical, based on the inspection results. 

(3) If opacity exceeds twenty percent (20%) per any Method 9 observations 

referenced 

above, the Permittee shall notify IDEM, if the Permittee anticipates that 

operations 

will continue for ten (10) days or more before the failed baghouse units 

will be 

repaired or replaced. 

Failure to take the response steps required by Condition D.5.7(c) upon 

observation of visible 

emissions shall be considered a deviation from this permit. 

Record Keeping and Reporting Requirement [326 IAC 2-7-5(3)] [326 IAC 2-7-

19] 

D.5.8 Record Keeping Requirements 

(a) To document compliance with Condition D.5.5(a), the Permittee shall 

keep a log of the 

calibration test results for the anode blast machine baghouse leak 

detector. 

(b) To document compliance with Condition D.5.5(j), the Permittee shall 

maintain records of daily 

visible emission notations of the stack exhaust for the anode blast 

machine baghouse, when 
the applicable bag leak detection system malfunctions, fails or otherwise 

needs repair. The 

Permittee shall include in its daily record when a visible emission 

notation is not taken and 

the reason for the lack of visible emission notation (e.g. the process 

did not operate that day). 

(c) To document compliance with Condition D.5.6, the Permittee shall 

maintain records of the 

occurrences of all bag leak detection alarms. 

(d) To document compliance with Condition D.5.7, the Permittee shall 

maintain daily records of 

visible emission notations of the stacks. The Permittee shall include in 

its daily record when 

a visible emission notation is not taken and the reason for the lack of 

visible emission 

notation (e.g. the process did not operate that day). 

(e) To document compliance with Condition D.5.7, the Permittee shall 

maintain daily records of 

Method 9 readings. 

(f) The Permittee shall maintain the following as required under 

Conditions D.5.5, D.5.6, and 

D.5.7,: 
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Permit Reviewer: Dr. Trip Sinha 

(1) Documentation of all response steps implemented per event. 

(g) All records shall be maintained in accordance with Section C -

General Record Keeping 

Requirements, of this permit. 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 89 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

SECTION D.6 INGOT PLANT AND SUPPORT FACILITY OPERATION CONDITIONS 

Facility Description [326 IAC 2-7-5(15)] 

(The information describing the process contained in this facility 

description box is descriptive 

information and does not constitute enforceable conditions.) 

Under NESHAP Subpart RRR, the following emissions units are considered an 

existing secondary 

aluminum processing unit (SAPU): 

#1 Coil Casting Complex 

(1) One (1) group 1 furnace, identified as #1 Casting Complex 1M2, 

constructed in 1973, 

with a maximum aluminum production rate of 6.85 tons per hour each, when 

used for 

producing cast coils and 49 tons per hour, when used as off-line melters, 

emissions 

uncontrolled, and exhausting at Stack 134.64; 

(2) Two (2) group 1 furnaces, identified as #1 Casting Complex East 

Holder 1EH and West 

Holder 1WH, constructed in 1973, with maximum aluminum production rates 

of 10.27 

tons per hour each, when used for producing cast coils and 49 tons per 

hour each, 

when used as off-line holders, emissions uncontrolled, and exhausting at 

Stacks 

134.63 and 134.66, respectively; 

#5 Furnace Complex 

(3) Three (3) group 1 furnaces, identified as Melters 5M1, 5M2 and 5M3, 

constructed in 

1966, with a maximum aluminum production rate of 97.5 tons per hour each, 

emissions 

uncontrolled, and exhausting at Stacks 134.33, 134.36, and 134.39, 

respectively; 

(4) Two (2) group 1 furnaces, identified as #5 HDC Complex East Holder 

5EH and West 

Holder 5WH, constructed in 1966, with maximum aluminum production rate of 

97.5 

tons per hour each, emissions uncontrolled, and exhausting at Stacks 

134.35 and 

134.38, respectively; 

#6 Furnace Complex 

(5) Three (3) group 1 furnaces, identified as Melters 6M1, 6M2, and 6M3, 

constructed in 

1966, with a maximum aluminum production rate of 12 tons per hour each, 

emissions 

uncontrolled, and exhausting at Stacks 134.40, 134.42, and 134.44, 

respectively; 

(6) Two (2) group 1 furnaces, identified as #6 Furnace Complex East 

Holder 6EH and 

West Holder 6WH, constructed in 1966, with maximum aluminum production 

rate of 16 
tons per hour each, emissions uncontrolled, and exhausting at Stacks 

134.41 and 

134.43, respectively; 

#8 EMC Ingot Casting Complex 

(7) One (1) group 1 furnace, identified as #8 EMC Complex Melter 8M3, 

constructed in 

1985, with a maximum aluminum production rate of 60.0 tons per hour, 

approved for 

modification in 2009 with the addition of low NOx burners, emissions 

uncontrolled, and 

exhausting at Stack 134.89; 

(8) Two (2) group 1 furnaces, identified as #8 EMC Complex Melters 8M1 

and 8M2, 

constructed in 1985, with a maximum aluminum production rate of 47 tons 

per hour 

each, emissions uncontrolled, and exhausting at Stacks 134.84 and 134.80, 

respectively; 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

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Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

(9) One (1) group 1 furnace, identified as #8 EMC Complex East Holder 

8EH, constructed 

in 1985, with a maximum aluminum production rate of 46.02 tons per hour, 

emissions 

uncontrolled, and exhausting at Stack 134.83; 

(10) One (1) group 1 furnace, identified as #8 EMC Complex West Holder 

8WH, 

constructed in 1985, with a maximum aluminum production rate of 58.75 

tons per hour, 

approved for modification in 2009 with the addition of low NOx burners, 

emissions 

uncontrolled, and exhausting at Stack 134.87. 

Upon start-up of the new rotary group 1 furnace, the one (1) group 

furnace, identified 

as #8 EMC Complex East Holder 8EH, constructed in 1985, with a maximum 

aluminum 

production rate of 46.02 tons per hour, emissions uncontrolled, and 

exhausting at 

Stack 134.83, shall be transferred from the existing secondary aluminum 

processing 

unit (SAPU) to the new secondary aluminum processing unit (SAPU); 

Under NESHAP Subpart RRR, the following emissions units are considered a 

new secondary 

aluminum processing unit (SAPU): 

(11) Two (2) degassing units, identified as Alcan Compact Degassing (ACD) 

units, 

constructed in 2003 in conjunction with #1 east holding furnace and #1 

west holding 

furnace in the #1 casting complex, with a maximum capacity 10 tons of 

molten 

aluminum per hour each, emissions uncontrolled, and exhausting at Stacks 

134.63 and 

134.66, respectively; 

(12) One (1) in-line fluxer, identified as 8EMC 8EH 4-rotor A622 in-line 

degassing unit 

replacing the one (1) 8EMC 8EH Alcan compact degassing ACD unit, 

constructed in 

2005, with a maximum aluminum production rate of 70.5 tons of molten 

aluminum per 

hour, emissions uncontrolled, and exhausting at Stack 134.83; 

(13) One (1) in-line fluxer, identified as 8EMC 8WH 4-rotor A622 in-line 

degassing unit, 

replacing the one (1) 8EMC 8WH 3-rotor A662 in-line degassing unit, 

constructed in 

2005, with a maximum aluminum production rate of 70.5 tons per hour, 

emissions 

uncontrolled, and exhausting at Stack 134.87; 

Rotary Group 1 

(14) One (1) rotary group 1 furnace, identified as Rotary Group 1 

Furnace, approved for 
construction in 2007, with a maximum coated scrap aluminum input rate of 

5.73 tons 

per hour and 17,809 tons per year, a maximum dross input rate of 5.50 

tons per hour 

and 29,106 tons per year, a flux salt input rate of 0.98 tons per hour 

and 5434.44 tons 

per year, with a maximum heat input capacity of 20 MMBtu per hour, 

emissions 

controlled by reagent injected baghouse, and exhausting at Stack 134.47; 

One (1) multi-compartment reagent injected baghouse, identified as Rotary 

Group 1 

Furnace Baghouse, approved for construction in 2007, controlling the 

rotary group 1 

furnace operations, with an airflow of 60,000 acfm at 200 0F, and 

exhausting at Stack 

134.47. 

(15) One (1) duct heater, identified as Rotary Group 1 Furnace Duct 

Heater, approved for 

construction in 2007, with a maximum heat input capacity of 12 MMBtu per 

hour, 

emissions controlled by the Rotary Group 1 Furnace Baghouse, and 

exhausting at 

Stack 134.47. 

Group 2 Furnaces, not included in the existing SAPU: 

#2 Offline Furnace Complex 
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Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

(16) Two (2) group 2 furnaces, identified as #2 Offline East Melter and 

West Melter, 

constructed in 1976, each with a maximum aluminum production rate of 12 

tons per 

hour, emissions uncontrolled, and exhausting at Stacks 134.71 and 134.76, 

respectively; 

(17) Two (2) group 2 furnaces, identified as #2 Offline East Holder and 

West Holder, 

constructed in 1976, each with a maximum aluminum production rate of 12 

tons per 

hour, emissions uncontrolled, and exhausting at Stacks 134.73 and 134.75, 

respectively; 

(18) One (1) natural gas fired, group 2 furnace, identified as RSI 

Furnace #10, constructed 

in 1991, with a maximum heat input of 41 MMBtu per hour and a maximum 

capacity of 

15 tons per hour, emissions uncontrolled, exhausting at Stack 134.15; 

Aluminum Shredder 

(19) One (1) aluminum shredder/bailer, identified as Coated Scrap 

Shredder, constructed in 

1999, with a maximum throughput of 25,000 pounds per hour, emissions 

uncontrolled, 

and exhausting inside the building. Under NESHAP Subpart RRR this is 

considered an 

existing aluminum scrap shredder; 

The following emissions units are not regulated under NESHAP Subpart RRR: 

(20) One (1) aluminum pneumatic transport system, identified as #2 

Offline East Melter 

Charging, constructed in 1976, with a maximum production rate of 12 tons 

per hour, 

controlled by Rotoclone #3, and exhausting at Stack 134.68. 

One (1) wet scrubber, identified as Rotoclone #3, with a gas flow rate of 

21,000 acfm at 

70.F, and exhausting at Stack 134.68; 

(21) One (1) aluminum pneumatic transport system, identified as #2 

Offline West Melter 

Charging, constructed in 1976, with a maximum production rate of 12 tons 

per hour, 

controlled by Rotoclone #4, and exhausting at Stack 134.77. 

One (1) wet scrubber, identified as Rotoclone #4, with a gas flow rate of 

12,000 acfm at 

70.F, and exhausting at Stack 134.77; 

(22) One (1) aluminum pneumatic transport system and silo, identified as 

#2 Offline East 

Melter West Chip Silo Input, constructed in 1976, with a maximum 

production rate of 

13.76 tons per hour, controlled by Rotoclone #1, and exhausting at Stack 

134.69. 

One (1) wet scrubber, identified as Rotoclone #1, with a gas flow rate of 

4,500 acfm at 
70.F, and exhausting at Stack 134.69; 

(23) One (1) aluminum pneumatic transport system and silo input, 

identified as #2 Offline 

East Melter East Chip Silo, constructed in 1976, with a maximum 

production rate of 

13.76 tons per hour, controlled by Rotoclone #2, and exhausting at Stack 

134.70. 

One (1) wet scrubber, identified as Rotoclone #2, with a gas flow rate of 

4,500 acfm at 

70.F, and exhausting at Stack 134.70; 

(24) One (1) skim/dross operation, identified as 133 Skim/Dross Building, 

with a maximum 

dross throughput of 66 tons per hour, controlled by the 133 Skim/Dross 

Building 

baghouses, and exhausting at Stacks 133D.1, 133D.2, 133D.3, and 133D.4. 

One (1) 133 Skim/Dross Building baghouses, consisting of: 

(a) Two (2) small baghouses, identified as No.1 and No.2 Skim Cooling 
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Baghouses, each with an air flow rate of 18,000 acfm at 150oF, and 

exhausting 

at Stacks 133D.1 and 133D.2, respectively; and 

(b) Two (2) big baghouses identified as No.3 and No.4 Skim Cooling 

Baghouses, 

each with an air flow rate of 40,000 acfm at 150oF, and exhausting at 

Stacks 

133D.3 and 133D.4; 

(25) One (1) hopper, identified as Rotary Group 1 Furnace Baghouse 

Reagent Hopper, 

approved for construction in 2007, with emissions controlled by the 

Rotary Group 1 

Furnace Baghouse, and exhausting at Stack 134.47. 

(26) One (1) flux salt storage silo, identified as Rotary Group 1 Furnace 

Flux Salt Silo, 

approved for construction in 2007, with a storage capacity of 30 tons, 

with emissions 

controlled by a bin vent filter, and exhausting at Vent 134.48. 

One (1) flux salt storage silo bin vent filter, approved for construction 

in 2007, 

controlling loading events to the rotary group 1 furnace flux salt 

storage silo, with an 

airflow of 650 - 800 acfm at 100oF, and exhausting at Stack 134.48. 

(27) Two (2) Emergency intermittent duty-cycled, diesel-fired, 

reciprocating internal 

combustion engines, identified as Water Pump Diesel Engines #1 and #2, 

constructed 

in December, 2005, with a maximum capacity of 460 brake horsepower each, 

exhausting at Stacks 134.E1 and 134.E2. 

Emission Limitations and Standards [326 IAC 2-7-5(1)] 

D.6.1 Particulate Emissions Limitations for Manufacturing Processes [326 

IAC 6-3-2] 

Pursuant to 326 IAC 6-3-2 (Particulate Emission Limitations for 

Manufacturing Processes), the 

allowable particulate emission rate from Ingot Plant and Support, shall 

be limited as follows: 

Facility Control 

Equipment 

Maximum Process 

Weight Rate 

(tons/hr) 

Allowable PM 

Emissions 

(lbs/hr) 

#2 Offline East Melter None 12 21.7 

#2 Offline West Melter None 12 21.7 

#2 Offline East Holder None 12 21.7 

#2 Offline West Holder None 12 21.7 

#2 Offline East Melter 

Charging 
Rotoclone #3 12 21.7 

#2 Offline West Melter 

Charging 

Rotoclone #4 12 21.7 

#2 Offline East Melter 

East Chip Silo Input 

Rotoclone #2 13.76 23.8 

#2 Offline West Chip 

Silo Input 

Rotoclone #1 13.76 23.8 

133 Skim/Dross 

Operation 

Nos. 1, 2, 3, and 

4 Skim Cooling 

Baghouses 

66 47.2 

Flux Salt Loading 

Operations 

Flux Salt 

Storage Silo Bin 

Vent Filter 

26 36.38 

The above particulate emissions rates were determined from the following 

formulae: 

Interpolation of the data for the process weight rate up to sixty 

thousand (60,000) pounds per hour by 

use of the equation: 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

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Permit Reviewer: Dr. Trip Sinha 

E = 4.10 P0.67 

Where: E = rate of emission in pounds per hour; and 

P = process weight rate in tons per hour. 

or 

Interpolation and extrapolation of the data for the process weight rate 

in excess of sixty thousand 

(60,000) pounds per hour by use of the equation: 

E = 55.0 P0.11 - 40 

Where: E = rate of emission in pounds per hour; and 

P = process weight rate in tons per hour. 

D.6.2 PSD and Nonattainment New Source Review Minor Limitations [326 IAC 

2-2] [326 IAC 2-1.1-5] 

The Permittee shall comply with the following limits: 

8M1, 8M2, and 8M3 Melters 

(a) Nitrogen Oxides (NOx) 

The total NOx emissions from all Melters 8M1, 8M2, and 8M3 shall not 

exceed 63.18 tons 

per twelve (12) consecutive month period, with compliance determined at 

the end of each 

month. The following equations shall be utilized to determine compliance: 

The following equation shall be utilized to determine NOx emissions: 

NOx Emissions = (Z1*A1 + Z2*A2 + Z3*A3)/2000 

Where: 

Z1 = the natural gas usage (MMCF) at Melter 8M1 

Z2 = the natural gas usage (MMCF) at Melters 8M2 

Z3 = the natural gas usage (MMCF) at Melter 8M3 

A1 = the NOx emission factor, as determined from the most recent stack 

test 

performed for the 8M1 melt furnace, pursuant to Condition D.6.12(d). 

A2 = the NOx emission factor, as determined from the most recent stack 

test 

performed for the 8M2 melt furnace, pursuant to Condition D.6.12(d). 

A3 before the modification = the NOx emission factor as determined from 

the most 

recent stack test for the 8M3 melt furnace. 

A3 after the modification = 110.5 pounds of NOx per MMCF of natural gas 

or the 

NOx emission factor as determined from the most recent stack test for the 

8M3 melt 

furnace after modification. 

(b) Particulate Matter (PM) 

The total PM emissions from all Melters 8M1, 8M2, and 8M3 shall not 

exceed 49.57 tons per 

twelve consecutive month period, with compliance determined at the end of 

each month. The 

following equation shall be utilized to determine PM emissions: 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 94 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

PM Emissions = (X1*A1 + X2*A2*1 ton/2000 lbs) 

Where: 

X1 = tons of charges that contain 24,876 pounds or less of purchased oily 

scrap and 

utilize salt input rates less than or equal to 1.65 lbs/ton of feed; 

A1 = the PM emission factor for the X1 operating condition, as provided 

in the most 

recently approved Operating, Monitoring, and Maintenance plan (Per the 

12/07 

OMM, this factor is 0.0943 lb/ton) or the PM emission factor as

determined from 

the most recent stack test; 

X2 = tons of charges that contain no purchased oily scrap, but do contain 

plastic 

banded scrap or alloy of less than or equal to 24,633 lbs per charge and 

utilize 

salt input rates less than or equal to 1.52 lbs/ton of feed; 

A2 = the PM emission factor for the X2 operating condition, as provided 

in the most 

recently approved Operating, Monitoring, and Maintenance plan (Per the 

12/07 

OMM, this factor is 0.158 lb/ton) or the PM emission factor as determined 

from 

the most recent stack test; 

(c) Particulate Matter with aerodynamic diameter of less than or equal to 

10 micrometers (PM10) 

The total PM10 emissions from Melters 8M1, 8M2, and 8M3 shall not exceed 

53.54 tons per 

twelve consecutive month period, with compliance determined at the end of 

each month. The 

following equation shall be utilized to determine PM10 emissions: 

PM10 Emissions = 1.08[(Y1*A1 + Y2*A2)]/2,000 

Where: 

Y1 = tons of charges that contain 24,876 pounds or less of purchased oily 

scrap and 

utilize combined chlorine and salt input rates less than or equal to 1.65 

lbs/ton 

of feed; 

A1 = the PM10 emission factor for the Y1 operating condition, as provided 

in the most 

recently approved Operating, Monitoring, and Maintenance plan (Per the 

12/07 

OMM, this factor is 0.0943 lb/ton) or the PM10 emission factor as 

determined 

from the most recent stack test; 

Y2 = tons of charges that contain no purchased oily scrap but do contain 

plastic 

banded scrap or alloy of less than or equal to 24,633 lbs per charge, and 

utilize 

salt input rates less than or equal to 1.52 lbs/ton of feed; 
A2 = the PM emission factor for the Y2 operating condition, as provided 

in the most 

recently approved Operating, Monitoring, and Maintenance plan (Per the 

12/07 

OMM, this factor is 0.158 lb/ton) or the PM10 emission factor as 

determined from 

the most recent stack test; 

8EMC East Holding Furnace and 8EMC West Holding Furnace 

(d) Nitrogen Oxides (NOx) 

The total NOx emissions from both the 8EMC east holding furnace and west 

holding furnace 

shall not exceed 15.89 tons per twelve (12) consecutive month period, 

with compliance 

determined at the end of each month. The following equations shall be 

used to determine 

compliance: 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 95 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

Until the modification to the 8EMC west furnace is complete the NOx 

emission factor as 

established from the most recent test of either the 8 EMC east or west 

furnace shall remain 

valid. If modifications are not made to the 8 EMC west furnace, retesting 

of the 8EMC east 

or west furnace shall be conducted no later than 5 years from the most 

recent stack test. 

Upon modification of the 8 EMC west furnace, NOx testing shall be 

conducted on the 8 EMC 

west furnace within 180 days of startup and then no later than 5 years 

from the most recent 

valid compliance test of the 8 EMC east and west furnaces. 

The following equation shall be utilized to determine NOx emissions: 

NOx Emissions = (Y1*A1 + Y2*A2)/2000 

Where: 

Y1 = the natural gas (MMCF) usage at 8EMC east holding furnace 

A1 before the modification of the 8EMC west holding furnace = the NOx 

emission 

factor as determined from the most recent stack test for either the 8EMC 

east holding 

furnace or the 8EMC west holding furnace. 

A1 after the modification of the 8EMC west holding furnace = the NOx 

emission 

factor as determined from the most recent stack test for either the 8EMC 

east holding 

furnace or the 8EMC west holding furnace. 

Y2 = the natural gas (MMCF) usage at 8EMC west holding furnace 

A2 before the modification = the NOx emission factor as determined from 

the most 

recent stack test for either the 8EMC west holding furnace or the 8EMC 

west holding 

furnace. 

A2 after the modification = 88.3 lbs of NOx per MMCF of natural gas or 

the NOx 

emission factor as determined from the most recent stack test for the 

8EMC west 

holding furnace. 

(e) Particulate Matter (PM) 

(1) The PM emissions from the 8EMC east holding furnace and the 8EMC west 

holding 

furnace shall be limited to 0.083 lbs/ton of charge for combined chlorine 

and flux salt 

input rates less than or equal to 1.14 lbs/ton of feed/charge; 

(2) The PM emissions from the 8EMC east holding furnace and the 8EMC west 

holding 

furnace shall be limited to 0.165 lbs/ton of feed/charge for combined 

chlorine and flux 

salt input rates greater than 1.14 lbs/ton of feed/charge but less than 

1.20 lbs/ton of 
feed/charge; 

(3) The PM emissions from the 8EMC east holding furnace and the 8EMC west 

holding 

furnace shall be limited to the allowable PM emission rate of 0.40 

lbs/ton of 

feed/charge, as specified by 40 CFR 63.1505 (k)(1) each, for combined 

chlorine and 

flux salt input rates greater than 1.2 lbs/ton of feed/charge, but less 

than 1.76 lbs/ton 

of feed/charge; 

(4) In no event shall the combined chlorine and flux salt rate exceed a 

maximum input 

rate of 1.76 lbs/ton of feed/charge; 

(5) The total PM emissions from both holding furnaces (8EMC east holding 

furnace and 

the 8EMC west holding furnace) shall be limited to 34.17 tons per twelve 

consecutive 

month period with compliance determined at the end of each month. The 

following 

equation shall be utilized to determine compliance: 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 96 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

PM Emissions = (X1*A1 + X2*A2 + X3*A3)/2,000 

Where: 

X1 = tons of charges fluxed with combined chlorine and flux salt input 

rates less than 

or equal to 1.14 lbs/ton of feed/charge; 

A1 = the PM emission factor for the X1 operating condition, as provided 

in the most 

recently approved Operating, Monitoring, and Maintenance plan (Per the 

10/05 

OMM, this factor is 0.0592 lb/ton); 

X2 = tons of charges fluxed with combined chlorine and salt input rates 

less than or 

equal to 1.20 lbs/ton of feed/charge and greater than 1.14 lbs/ton of 

feed/charge; 

A2 = the PM emission factor for the X2 operating condition, as provided 

in the most 

recently approved Operating, Monitoring, and Maintenance plan (Per the 

10/05 

OMM, this factor is 0.165 lb/ton); 

X3 = tons of charges fluxed with combined chlorine and salt input rates 

less than or 

equal to 1.76 lbs/ton of feed/charge and greater than 1.20 lbs/ton of 

feed/charge; 

and 

A3 = the PM emission factor for the X3 operating condition, as provided 

in the most 

recently approved Operating, Monitoring, and Maintenance plan (Per the 

10/05 

OMM, this factor is 0.228 lb/ton). 

(f) Particulate Matter with aerodynamic diameter of less than or equal to 

10 micrometers (PM10) 

(1) The PM10 emissions from the 8EMC east holding furnace and the 8EMC 

west 

holding furnace shall be limited to 0.121 lbs/ton of feed/charge for 

combined chlorine 

and flux salt input rates less than or equal to 1.14 lbs/ton of aluminum 

feed/charge; 

(2) The PM10 emissions from the 8EMC east holding furnace and the 8EMC 

west holding 

furnace shall be limited to 0.241 lbs/ton of feed/charge for combined 

chlorine and flux 

salt input rates greater than 1.14 lbs/ton of feed/charge but less than 

or equal to 1.20 

lbs/ton of feed/charge; 

(3) The PM10 emissions from the 8EMC east holding furnace and the 8EMC 

west 

holding furnace shall be limited to the allowable PM emission rate of 

0.40 lbs/ton of 

feed/charge, as specified by 40 CFR 63.1505(k)(1), multiplied by 1.46 for 

combined 
chlorine and flux salt input rates greater than 1.20 lbs/ton of 

feed/charge, but less 

than or equal to 1.76 lbs/ton of feed/charge; 

(4) In no event shall combined chlorine and flux salt rate exceed a 

maximum input rate 

of 1.76 lbs/ton of feed/charge; 

(5) The total PM10 emissions from both holding furnaces (8EMC east 

holding furnace 

and the 8EMC west holding furnace) shall be limited to 49.89 tons per 

twelve 

consecutive month period, with compliance determined at the end of each 

month. 

The following equation shall be utilized to determine compliance; 

PM10 Emissions = 1.46[(Y1*A1 + Y2*A2+ Y3*A3)]/2,000 

Where: 

Y1 = tons of charges fluxed with combined chlorine and flux salt input 

rates less than 

or equal to 1.14 lbs/ton of feed/charge; 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 97 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

A1 = the PM emission factor for the Y1 operating condition, as provided 

in the most 

recently approved Operating, Monitoring, and Maintenance plan (Per the 

10/05 

OMM, this factor is 0.0592 lb/ton); 

Y2 = tons of charges fluxed with combined chlorine and flux salt input 

rates greater 

than 1.14 lbs/ton of feed/charge but less than or equal to 1.20 lbs/ton 

of feed/charge; 

A2 = the PM emission factor for the Y2 operating condition, as provided 

in the most 

recently approved Operating, Monitoring, and Maintenance plan (Per the 

10/05 

OMM, this factor is 0.165 lb/ton); 

Y3 = tons of charges fluxed with combined chlorine and salt input rates 

greater than 

1.20 lbs/ton of feed/charge, but less than or equal to 1.76 lbs/ton of 

feed/charge; and 

A3 = the PM emission factor for the Y3 operating condition, as provided 

in the most 

recently approved Operating, Monitoring, and Maintenance plan (Per the 

10/05 

OMM, this factor is 0.228 lb/ton). 

8EMC 8EH A622 and 8EMC 8WH A622 in-line degassing units 

(g) The total feed/charge rate to 8EMC 8EHA622 and 8EMC 8WH A622 in-line 

degassing units 

shall not exceed 823,440 tons per twelve (12) consecutive month period 

with compliance 

determined at the end of each month; 

(h) The PM emissions from the 8EMC 8EH A622 and 8EMC 8WH A622 in-line 

degassing units 

shall not exceed 0.02 lbs/ton of feed/charge for chlorine input rates of 

0.11 lbs/ton of 

feed/charge or less. Compliance with this limit and the feed/charge limit 

in Condition D.6.2(g) 

shall ensure that the total PM emissions from the 8EMC 8EH A622 and 8EMC 

8WH A622 

in-line degassing units do not exceed 8.24 tons per year; 

(i) The PM10 emissions from the 8EMC 8EH A622 and 8EMC 8WH A622 in-line 

degassing 

units shall not exceed 0.021 lbs/ton of feed per/charge for chlorine 

input rates of 0.11 lbs/ton 

of feed/charge or less. Compliance with this limit and the feed/charge 

limit in Condition 

D.6.2(g) shall ensure that the total PM10 emissions from 8EMC 8EH A622 

and 8 EMC 8WH 

A622 in-line degassing units do not exceed 8.56 tons per year; 

#1 Complex Alcan Compact Degassing (ACD) units 

(j) The total feed/charge rate to the two (2) #1 complex ACD units shall 

not exceed 172,000 tons 
per twelve consecutive month period, with compliance determined at the 

end of each month; 

(k) The PM emissions from the two (2) #1 complex ACD units shall not 

exceed 0.026 lbs/ton of 

feed/charge. Compliance with this limit and the feed/charge limit in 

Condition D.6.2(j) shall 

ensure that the total PM emissions from the two (2) #1 complex ACD units 

do not exceed 

2.24 tons per year; 

(l) The PM10 emissions from the two (2) #1 complex ACD units shall not 

exceed 0.027 lbs/ton 

of feed/charge. Compliance with this limit and the feed/charge limit in 

Condition D.6.2(j) shall 

ensure that the total PM10 emissions from both #1 complex ACD units do 

not exceed 2.32 

tons per year; 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 98 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

#1 Complex East Holding Furnace and #1 Complex West Holding Furnace 

(m) The PM emissions from the #1 complex east holding furnace and #1 

complex west holding 

furnace shall not exceed 0.045 lbs/ton of charge for flux salt input 

rates less than or equal to 

0.85 lbs/ton of feed/charge. The PM emissions from the #1 complex east 

holding furnace and 

#1 complex west holding furnace shall not exceed 0.084 lbs/ton of 

feed/charge for flux salt 

input rates greater than 0.85 lbs/ton of feed/charge but less than 3.25 

lbs/ton of feed/charge. 

The total PM emissions from these furnaces shall not exceed 3.87 tons per 

twelve 

consecutive month period, with compliance determined at the end of each 

month. The 

following equation shall be utilized to determine compliance: 

PM Emissions = [X1*0.045 + X2*0.084]/2,000 

Where: 

X1 = tons of charge for flux salt input rates less than or equal to 0.85 

lbs/ton of feed/charge; 

and 

X2 = tons of charge for flux salt input rates greater than 0.85 lbs/ ton 

of feed/charge but less 

than or equal to 3.25 lbs/ton of feed/charge. 

(n) The PM10 emissions from the #1 complex east holding furnace and #1 

complex west holding 

furnace shall not exceed 0.066 lbs/ton of charge for flux salt input 

rates less than or equal to 

0.85 lbs/ton of feed/charge. The PM10 emissions from the #1 complex east 

holding furnace 

and #1 complex west holding furnace shall not exceed 0.123 lbs/ton of 

charge for flux salt 

input rates greater than 0.85 lbs/ton of feed/charge but less than 3.25 

lbs/ton of feed/charge. 

The total PM10 emissions from these furnaces shall not exceed 5.65 tons 

per twelve 

consecutive month period, with compliance determined at the end of each 

month. The 

following equation shall be utilized to determine compliance: 

PM10 Emissions = [Y1*0.066 + Y2*0.123]/2,000 

Where: 

Y1 = tons of feed/charge for flux salt input rates less than or equal to 

0.85 lbs/ton of 

feed/charge; and 

Y2 = tons of feed/charge for flux salt input rates greater than 0.85 

lbs/ton of feed/charge 

but less than 3.25 lbs/ton of feed/charge. 

(o) In no event shall flux salt exceed a maximum input rate of 3.25 

lbs/ton of feed/charge; 
(p) The total feed/charge of the #1 complex east holding furnace and the 

#1 complex west 

holding furnace shall not exceed 172,000 tons per twelve consecutive 

month period, with 

compliance determined at the end of each month; and 

(q) The NOx emissions from the #1 complex east holding furnace and #1 

complex west holding 

furnaces shall not exceed 0.148 lbs per ton of feed/charge and compliance 

with this limit and 

the feed/charge limit in Condition D.6.2(p) shall ensure that the total 

NOx emissions from 

these furnaces do not exceed 12.58 tons per year. 

Compliance with these limits renders the requirements of 326 IAC 2-2 

(Prevention of Significant 

Deterioration) not applicable to the emissions units covered by this 

condition. 

D.6.3 PSD Minor Limitations [326 IAC 2-2] 

(a) Pursuant to SPM 173-20246-00007, and revised by this Part 70 permit, 

the amount of 

material charged into the furnace complexes No. 5 and No. 6; and the 

melting furnaces in 

casting complex No.1, shall be limited such that: 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 99 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

n 

S(OLG1 tons charged X OLG1 PM Ef/2000) < 202 tons/year; 

i =l 

where: 

OLG1 = Off-line Group 1, including all melting and holding furnaces in 

the #5 and #6 furnace 

complexes, and the melt furnaces in the #1 casting complex; 

Tons charged = Off line group 1 furnace charging rate, individual OLG1 

basis, and are on a 

tons per 12 consecutive month period basis; and 

OLG1 PM Ef is the pounds of particulate matter (PM) per ton of material 

charged emission 

factor, each individual OLG1 furnace basis, as provided in the most 

recently approved 

Operating, Monitoring, and Maintenance plan. 

(b) The amount of natural gas usage for the OLG1 furnaces shall be less 

than 1,847 million 

cubic feet (MMCF) per twelve (12) consecutive month period, with 

compliance determined at 

the end of each month. 

D.6.4 PSD Minor Limitations [326 IAC 2-2]

Pursuant to SSM 173-17780-00007, issued on July 21, 2004, the following 

limits shall apply to the 

dross cooling operation: 

(a) The throughput of dross and salt cake through the dross cooling 

operation shall be limited to 

38,000 tons per twelve (12) consecutive month period with compliance 

determined at the end 

of each month; 

(b) The emission rate of PM shall not exceed 0.440 pounds of PM per ton 

of dross and salt cake 

throughput; and 

(c) The emission rate of PM10 shall not exceed 0.454 pounds of PM10 per 

ton of dross and salt 

cake throughput. 

Compliance with the throughput limits in Conditions D.4.2(a) and D.6.4(a) 

and the emission limits 

specified by Conditions D.3.2(a) through (c), D.4.2(b) through (e), 

D.5.2(a) and (b), and D.6.4(b) and 

(c), shall render the requirements of 326 IAC 2-2 not applicable to the 

dross cooling operation. 

D.6.5 PSD and Nonattainment New Source Review Minor Limitations [326 IAC 

2-2] [326 IAC 2-1.1-5] 

The following limits shall apply to the Rotary Group 1 operation: 

(a) Particulate Matter (PM) 

(1) The PM emissions from the Rotary Group 1 Furnace, the Rotary Group 1 

Furnace 

Duct Heater, and the Rotary Group 1 Furnace Baghouse Reagent Hopper shall 

be 

controlled by the Rotary Group 1 Furnace Baghouse. 
(2) Total PM emissions when processing dross only shall not exceed 0.673 

pound per 

ton of charge/feed. 

(3) Total PM emissions when processing any amount of scrap shall not 

exceed 0.702 

pound per ton of charge/feed. 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 100 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

(4) The total PM emissions from the Rotary Group 1 Furnace Baghouse shall 

not exceed 

24.90 tons per twelve (12) consecutive month period, with compliance 

determined at 

the end of each month. The following equation shall be utilized to 

determine 

compliance: 

PM Emissions = (Z1*0.673 + Z2*0.702)/2000 

Where: 

Z1 = tons of charge/feed comprised of dross only 

Z2 = tons of charge/feed containing any amount of scrap 

(5) The PM emissions from the flux salt storage silo shall be controlled 

by the salt flux 

storage silo bin vent filter and shall not exceed 0.03 pound per hour 

during loading 

events. 

(b) Particulate Matter with aerodynamic diameter of less than or equal to 

10 micrometers 

(PM10). 

(1) The PM10 emissions from the Rotary Group 1 Furnace, the Rotary Group 

1 Furnace 

Duct Heater, and the Rotary Group 1 Furnace Baghouse Reagent Hopper shall 

be 

controlled by the Rotary Group 1 Furnace Baghouse. 

(2) Total PM10 emissions when processing dross only shall not exceed 

0.558 pound per 

ton of charge/feed. 

(3) Total PM10 emissions when processing any amount of scrap shall not 

exceed 0.582 

pound per ton of charge/feed. 

(4) The total PM10 emissions from the Rotary Group 1 Furnace Baghouse 

shall not 

exceed 14.90 tons per twelve (12) consecutive month period, with 

compliance 

determined at the end of each month. The following equation shall be 

utilized to 

determine compliance: 

PM Emissions = (Z1*0.558 + Z2*0.582)/2000 

Where: 

Z1 = tons of charge/feed comprised of dross and not containing scrap 

Z2 = tons of charge/feed containing scrap 

(5) The PM10 emissions from the flux salt storage silo shall be 

controlled by the salt flux 

storage silo bin vent filter and shall not exceed 0.03 pound per hour 

during loading 

events. 

(c) Nitrous Oxides (NOx) 

(1) The NOx emissions from the Rotary Group 1 Furnace when processing 

dross only 

shall not exceed 400 pounds per MMCF of natural gas. 
(2) The NOx emissions from the Rotary Group 1 Furnace when processing any 

amount 

of scrap shall not exceed 451.57 pounds per MMCF of natural gas. 

(3) The NOx emissions from the Rotary Group 1 Furnace Duct Heater shall 

not exceed 

140 pounds per MMCF of natural gas. 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 101 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

(4) The total NOx emissions from the Rotary Group 1 Furnace and the 

Rotary Group 1 

Furnace Duct Heater shall not exceed 37.18 tons per twelve (12) 

consecutive month 

period, with compliance determined at the end of each month. The 

following equation 

shall be utilized to determine compliance: 

NOx Emissions = (Z1*400 + Z2*451.57 + Z3*140) /2000 

Where: 

Z1 = the natural gas usage (MMCF) at Rotary Group 1 Furnace when the 

charge/feed processed is only dross 

Z2 = the natural gas usage (MMCF) at Rotary Group 1 Furnace when the 

charge/feed processed contains any amount of scrap 

Z3 = the natural gas usage (MMCF) at Rotary Group 1 Furnace Duct Heater 

Burner 

Compliance with these limits renders the requirements of 326 IAC 2-2 

(Prevention of Significant 

Deterioration) and 326 IAC 2-1.1-5 (Nonattainment New Source Review) not 

applicable to the 

emissions units covered by this condition. 

D.6.6 General Provisions Relating to NESHAP [326 IAC 20-1] [40 CFR Part 

63, Subpart A] 

[40 CFR 63.1518] 

The provisions of 40 CFR Part 63, Subpart A - General Provisions, which 

are incorporated by 

reference in 326 IAC 20-1, apply to all the units covered by National 

Emission Standards for 

Hazardous Air Pollutants for Secondary Aluminum Production, 40 CFR 63, 

Subpart RRR. The 

requirements of the general provisions in 40 CFR 63, Subpart A that are 

applicable to the source 

subject to the requirements of this Subpart are shown in appendix A of 40 

CFR 63, Subpart RRR. 

D.6.7 Emission Limits for Secondary Aluminum Production Sources and 

Emission Units [326 IAC 20-70] 

[40 CFR 63.1505] 

(a) Pursuant to 40 CFR 63.1505(b) MSM No. 173-12588, issued on October 

10, 2000, the 

particulate matter (PM) emissions from the Coated Scrap Shredder shall 

not exceed 0.01 

grains per dry standard cubic foot. 

(b) Pursuant to 40 CFR 63.1505(i), the Permittee shall use the following 

emission limits for group 

1 furnace to determine the emission standards for a secondary aluminum 

processing unit 

(SAPU): 

(1) 0.40 lb of PM per ton of feed/charge from a group 1 furnace; 

(2) 2.1 x 10-4 gr of D/F TEQ per ton of feed/charge from a group 1 

furnace; and 

(3) 0.40 lb of HCl per ton of feed/charge from a group 1 furnace. 
(c) Pursuant to 40 CFR 63.1505(j), the Permittee shall use the following 

emission limits for 

in-line fluxers to determine the emission standards for a SAPU: 

(1) 0.04 lb of HCl per ton of feed/charge; and 

(2) 0.01 lb of PM per ton of feed/charge. 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 102 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

(d) Pursuant to 40 CFR 63.1505(k), the Permittee shall comply with the 

emission limits 

calculated using the equations for PM and HCl in paragraph (d)(1) and 

(d)(2) of this condition 

for each secondary aluminum processing unit. The Permittee shall comply 

with the emission 

limit calculated using the equation for D/F in paragraph (d)(3) of this 

condition for each 

secondary aluminum processing unit. 

(1) The owner or operator must not discharge or allow to be discharged to 

the 

atmosphere any 3-day, 24-hour rolling average emissions of PM in excess 

of: 

. . 

.. . 

. 

. 

. 

. 

. 

n

i 1 

ti 

n

i 1 

tiPM ti 

cPM 

T 

L T 

L (Eq. 1) 

Where, 

LtiPM = The PM emission limit for individual emission unit i in paragraph 

(b)(1) of this 

condition for a group 1 furnace or in paragraph (c)(2) of this condition 

for an in-line 

fluxer; 

Tti = The feed/charge rate for individual emission unit I; and 

LcPM = The PM emission limit for the secondary aluminum processing unit. 

Note:In-line fluxers using no reactive flux materials cannot be included 

in this 

calculation since they are not subject to the PM limit. 

(2) The owner or operator must not discharge or allow to be discharged to 

the 

atmosphere any 3-day, 24-hour rolling average emissions of HCl in excess 

of: 

. . 

.. . 

. 

. 

. 
. 

. 

n

i 1 

ti 

n

i 1 

tiHCL ti 

cHCL 

T 

L T 

L (Eq. 2) 

Where, 

LtiHCl = The HCl emission limit for individual emission unit i in 

paragraph (b)(3) of 

this condition for a group 1 furnace or in paragraph (c)(1) of this 

condition for an 

in-line fluxer; and 

LcHCl = The HCl emission limit for the secondary aluminum processing 

unit. 

Note:In-line fluxers using no reactive flux materials cannot be included 

in this 

calculation since they are not subject to the HCl limit. 

(3) The owner or operator must not discharge or allow to be discharged to 

the 

atmosphere any 3-day, 24-hour rolling average emissions of D/F in excess 

of: 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 103 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

. . 

.. . 

. 

. 

. 

. 

. 

n

i 1 

ti 

n

i 1 

tiD/F ti 

cD/F 

T 

L T 

L (Eq. 3) 

Where, 

LtiD/F = The D/F emission limit for individual emission unit i in 

paragraph (b)(2) of 

this condition for a group 1 furnace; and 

LcD/F = The D/F emission limit for the secondary aluminum processing 

unit. 

Note: Clean charge furnaces cannot be included in this calculation since 

they are not 

subject to the D/F limit. 

D.6.8 Operating Requirements for Affected NESHAP Emission Units [326 IAC 

20-70] [40 CFR 63.1506] 

(a) Summary - Pursuant to 40 CFR 63.1506(a), the Permittee shall operate 

all affected emission 

units and control equipment according to the requirements in this 

condition. 

(b) Labeling - Pursuant to 40 CFR 63.1506(b), the Permittee shall provide 

and maintain easily 

visible labels posted at each group 1 furnace, group 2 furnace, and inline fluxer that 

identifies the applicable emission limits and means of compliance, 

including: 

(1) The type of affected source or emission unit (e.g, group 1 furnace, 

group 2 furnace, 

and in-line fluxer); and 

(2) The applicable operational standard(s) and control method(s) (work 

practice). This 

includes, but is not limited to, the type of charge to be used for a 

furnace, etc.), flux 

materials and addition practices, and the applicable requirements as 

incorporated in 

the OM&M plan. 

(c) Capture/collection systems - Pursuant to 40 CFR 63.1506(c), for each 

affected source or 
emission unit equipped with an add-on air pollution control device, the 

Permittee shall: 

(1) Design and install a system for the capture and collection of 

emissions to meet the 

engineering standards for minimum exhaust rates as published by the 

American 

Conference of Governmental Industrial Hygienists in chapters 3 and 5 of 

―Industrial 

Ventilation: A Manual of Recommended Practice‖ (incorporated by reference 

in 

§63.1502 of this subpart); 

(2) Vent captured emissions through a closed system, except that dilution 

air may be 

added to emission streams for the purpose of controlling temperature at 

the inlet to a 

fabric filter; and 

(3) Operate each capture/collection system according to the procedures 

and 

requirements in the OM&M plan. 

(d) Feed/charge weight – Pursuant to 40 CFR 63.1506(d), for each affected 

emission unit 

subject to an emission limit in lb/ton of feed/charge, the Permittee 

shall: 

(1) Operate a device that measures and records or otherwise determines 

the weight of 

feed/charge or throughput for each operating cycle or time period used in 

the 

performance test; and 
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(2) Operate each weight measurement system or other weight determination 

procedure 

in accordance with the OM&M plan. 

(e) Group 1 Furnaces with Add-on Air Pollution Control Devices - Pursuant 

to 

40 CFR 63.1506(m), for a group 1 furnace with emissions controlled by a 

lime-injection fabric 

filter, the Permittee shall: 

(1) If a bag leak detection system is used to meet the monitoring 

requirements in §63.1510, 

the Permittee shall: 

(i) Initiate corrective action within 1 hour of a bag leak detection 

system alarm. 

(ii) Complete the corrective action procedures in accordance with the 

OM&M 

plan. 

(iii) Operate each fabric filter system such that the bag leak detection 

system 

alarm does not sound more than 5 percent of the operating time during a 

6-month block reporting period. In calculating this operating time 

fraction, if 

inspection of the fabric filter demonstrates that no corrective action is 

required, no alarm time is counted. If corrective action is required, 

each 

alarm shall be counted as a minimum of 1 hour. If the Permittee takes 

longer 

than 1 hour to initiate corrective action, the alarm time shall be 

counted as 

the actual amount of time taken by the owner or operator to initiate 

corrective 

action. 

(2) Maintain the 3-hour block average inlet temperature for each fabric 

filter at or below 

the average temperature established during the performance test, plus 14 

°C (plus 

25 °F). 

(3) For a continuous lime injection system, maintain free-flowing lime in 

the hopper to 

the feed device at all times and maintain the lime feeder setting at the 

same level 

established during the performance test. 

(4) Maintain the total reactive chlorine flux injection rate for each 

operating cycle or time 

period used in the performance test at or below the average rate 

established during 

the performance test. 

(f) Group 1 Furnaces without Add-on Air Pollution Control Devices -

Pursuant to 

40 CFR 63.1506(n), the Permittee shall: 
(1) Maintain the total reactive chlorine flux injection rate for each 

operating cycle or time 

period used in the performance test at or below the average rate 

established during 

the performance test; and 

(2) Operate each furnace in accordance with the work practice/pollution 

prevention 

measures documented in the OM&M plan and within the parameter values or 

ranges 

established in the OM&M plan. 

(g) Group 2 Furnace - Pursuant to 40 CFR 63.1506(o), the Permittee shall: 

(1) Operate each group 2 furnace using only clean charge as the 

feedstock; and 

(2) Operate each group 2 furnace using no reactive flux. 
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(h) Corrective Action - Pursuant to 40 CFR 63.1506(p), when a process 

parameter deviates from 

the value or range established during the performance test and 

incorporated in the OM&M 

plan, the Permittee shall initiate corrective action. The corrective 

action shall restore 

operation of the emission unit (including the process) to its normal or 

usual mode of operation 

as expeditiously as practicable in accordance with good air pollution 

control practices for 

minimizing emissions. The corrective actions taken shall include followup actions necessary 

to return the process parameter level(s) to the value or range of values 

established during the 

performance test and steps to prevent the likely recurrence of the cause 

of a deviation. 

D.6.9 Alternative Opacity Limitation [326 IAC 5-1-5(b)] [U.S. EPA SIP 

Revisions Revised Opacity Limits] 

Pursuant to 326 IAC 5-1-5(b) and U.S. EPA SIP Revisions Revised Opacity 

Limits, dated July 5, 

2000: 

(a) #1 Complex East and West holding furnace 

The opacity of emissions may exceed 40 percent during the fluxing portion 

of the production 

cycle up to 80 percent from the East and West holding furnace exhaust 

stacks at the #1 

Complex. This opacity shall be allowed for no more than 6 six-minute 

averaging periods, and 

only during fluxing. For all other portions of the production cycle, the 

opacity limit shall remain 

at 40 percent from the East and West holding furnace exhaust stacks at 

the #1 Complex; 

(b) #8 Complex (EMC) 

For the East and West holding furnace exhaust stacks at the #8 Complex 

(EMC), the opacity 

of emissions may exceed 40 percent during fluxing portion of the 

production cycle up to 85 

percent for 2 six-minute averaging periods, and up to 80 percent opacity 

for 4 additional 

six-minute averaging periods. During all other portions of the production 

cycle, the opacity of 

emissions from the EMC shall be limited to 40 percent; and 

(c) #5 Complex 

For the East and West holding furnace exhaust stacks at the #5 Complex, 

the opacity of 

emissions may exceed 40 percent during fluxing portion of the production 

cycle up to 80 

percent for 3 six-minute averaging periods, 75 percent opacity for 1 sixminute averaging 
period, 65 percent opacity for 1 six-minute averaging period, and 55 

percent opacity for 1 

six-minute averaging period. During all other portions of the production 

cycle, the opacity of 

emissions from the #5 complex East and West holding furnace shall be 

limited to 40 percent. 

Compliance Determination Requirements 

D.6.10 NESHAP Performance Test/Compliance Demonstration General 

Requirements [326 IAC 20-1] 

[40 CFR 63, Subpart A] [326 IAC 20-70] [40 CFR 63.1511] 

(a) Site-specific test plan [40 CFR 63.1511(a)] - Prior to conducting any 

performance test 

required by 40 CFR 63, Subpart RRR, the Permittee shall prepare a sitespecific test plan 

which satisfies all of the requirements, and shall obtain approval of the 

plan pursuant to the 

procedures, set forth in 40 CFR 63.7(c). 

(b) Initial performance test [40 CFR 63.1511(b)] - Following approval of 

the site-specific test 

plan, the Permittee shall demonstrate initial compliance with each 

applicable emission, 

equipment, work practice, or operational standard for each affected 

source and emission unit, 

and report the results in the notification of compliance status report as 

described in 

40 CFR 63.1515(b). For any new affected source for which an initial 

performance test is 

required, the Permittee shall conduct this initial performance test 

within 90 days after the date 

for compliance established by 40 CFR 63.1501(b). Except for the date by 

which the 

performance test must be conducted, the Permittee shall conduct each 

performance test in 

accordance with the requirements and procedures set forth in 40 CFR 

63.7(c). 
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(1) The Permittee shall conduct each test while the affected source or 

emission unit is 

operating at the highest production level with charge materials 

representative of the 

range of materials processed by the unit and, if applicable, at the 

highest reactive 

fluxing rate. 

(2) Each performance test for a continuous process must consist of 3 

separate runs; 

pollutant sampling for each run must be conducted for the time period 

specified in the 

applicable method or, in the absence of a specific time period in the 

test method, for 

a minimum of 3 hours. 

(3) Each performance test for a batch process must consist of three 

separate runs; 

pollutant sampling for each run must be conducted over the entire process 

operating 

cycle. 

(4) Initial compliance with an applicable emission limit or standard is 

demonstrated if the 

average of three runs conducted during the performance test is less than 

or equal to 

the applicable emission limit or standard. 

(c) Test methods [40 CFR 63.1511(c)] - The Permittee shall use the 

following methods in 

appendix A to 40 CFR Part 60 to determine compliance with the applicable 

emission limits: 

(1) Method 1 for sample and velocity traverses; 

(2) Method 2 for velocity and volumetric flow rate; 

(3) Method 3 for gas analysis; 

(4) Method 4 for moisture content of the stack gas; 

(5) Method 5 for the concentration of PM; 

(6) Method 23 for the concentration of D/F; and 

(7) Method 26A for the concentration of HCl. 

(d) Repeat tests [40 CFR 63.1511(e)] - The Permittee shall conduct a 

performance test every 5 

years following the initial performance test. 

(e) Testing of representative emission units [40 CFR 63.1511(f)] - With 

the prior approval of the 

IDEM, OAQ, the Permittee shall utilize emission rates obtained by testing 

a particular type of 

group 1 furnace, or by testing an in-line flux box, to determine the 

emission rate for other 

units of the same type at this source. Such emission test results may 

only be considered to 

be representative of other units if all of the following criteria are 

satisfied: 

(1) The tested emission unit shall use feed materials and charge rates 

which are 
comparable to the emission units that it represents; 

(2) The tested emission unit shall use the same type of flux materials in 

the same 

proportions as the emission units it represents; 

(3) The tested emission unit shall be operated utilizing the same work 

practices as the 

emission units that it represents; 

(4) The tested emission unit shall be of the same design as the emission 

units that it 

represents; and 

(5) The tested emission unit shall be tested under the highest load or 

capacity 

reasonably expected to occur for any of the emission units that it 

represents. 
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(f) Establishment of monitoring and operating parameter values [40 CFR 

63.1511(g)]– The 

Permittee shall establish a minimum or maximum operating parameter value, 

or an operating 

parameter range for each parameter to be monitored as required by 40 CFR 

63.1510 

(Condition D.6.17) that ensures compliance with the applicable emission 

limit or standard. To 

establish the minimum or maximum value or range, the Permittee shall use 

the appropriate 

procedures in this section. The Permittee may use existing data in 

addition to the results of 

performance tests to establish operating parameter values for compliance 

monitoring 

provided each of the following conditions are met to the satisfaction of 

the IDEM, OAQ: 

(1) The complete emission test report(s) used as the basis of the 

parameter(s) is 

submitted; 

(2) The same test methods and procedures as required by this Subpart were 

used in the 

test; 

(3) The Permittee certifies that no design or work practice changes have 

been made to 

the source, process, or emission control equipment since the time of the 

report; and 

(4) All process operating parameters required to be monitored were 

monitored as 

required in 40 CFR 63.1510 and documented in the test report. 

D.6.11 NESHAP Performance Test/Compliance Demonstration Requirements and 

Procedures 

[326 IAC 20-1] [40 CFR 63, Subpart A] [326 IAC 20-70] [40 CFR 63.1512] 

[40 CFR 63.1513] 

(a) Aluminum scrap shredders [40 CFR 63.1512(a)] - The Permittee shall 

conduct performance 

tests to measure PM emissions at the inlet of baghouse that is available 

for controlling 

emissions from the coated scrap shredder/baler in 2010, and at 5-year 

intervals thereafter, 

provided however that testing of this shredder/baler will not be required 

if Alcoa obtains a 

waiver from testing this unit, pursuant to 40 CFR 63.7(h). 

(b) Group 1 furnace with add-on air pollution control devices [40 CFR 

63.1512(d)]. 

(1) For a group 1 furnace that processes scrap other than clean charge 

materials with 

emissions controlled by a lime-injected fabric filter, the Permittee 

shall conduct 

performance tests to measure emissions of PM and D/F at the outlet of the 

control 
device and emissions of HCl at the outlet (for the emission limit). 

(c) Group 1 furnaces without add-on air pollution control devices [40 CFR 

63.1512(e)] - In the 

site-specific monitoring plan required by 40 CFR 63.1510(o) (Condition 

D.6.17(i)), the 

Permittee shall include data and information demonstrating compliance 

with the applicable 

emission limits. 

(1) The Permittee shall conduct emission tests to measure emissions of 

PM, and HCl at 

the representative Group 1 furnace exhaust outlet. 

(2) The Permittee shall conduct emission tests to measure emissions D/F 

at the furnace 

exhaust outlet from representative group 1 furnaces that process other 

than clean 

charge. 

(d) Secondary aluminum processing unit [40 CFR 63.1512(j)] - The 

Permittee shall conduct 

performance tests as described in paragraph (1) and (2) of this 

condition. The results of the 

performance tests shall be used to establish emission rates in lb/ton of 

feed/charge for PM 

and HCl for each group 1 furnace and in-line fluxer and grain of D/F 

TEQ/ton of feed/charge 

for D/F emissions from each group 1 furnace. These emission rates are 

used for compliance 

monitoring in the calculation of the 3-day, 24-hour rolling average 

emission rates using the 

equation in 40 CFR 63.1510(t) (Condition D.6.17(m)(4)). A performance 

test is required for: 

(1) Representative group 1 furnaces to measure emissions of PM, D/F; and 

HCl; 
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(2) Representative in-line fluxers to measure emissions of PM and HCl. 

(e) Feed/charge weight measurement [40 CFR 63.1512(k)] - During the 

emission tests 

conducted to determine compliance with emission limits in a lb/ ton 

format, the Permittee 

shall measure (or otherwise determine) and record the total weight of 

feed/charge to the 

affected emission unit for each of the three test runs and calculate and 

record the total 

weight. 

(f) Inlet gas temperature [40 CFR 63.1512(n)] - For a group 1 furnace 

using a lime-injected 

fabric filter, the Permittee shall use these procedures to establish an 

operating parameter 

value or range for the inlet gas temperature. 

(1) Continuously measure and record the temperature at the inlet to the 

lime-injected 

fabric filter every 15 minutes during the HCl and D/F performance tests; 

(2) Determine and record the 15-minute block average temperatures for the 

3 test runs; 

and 

(3) Determine and record the 3-hour block average of the recorded 

temperature 

measurements for the 3 test runs. 

(g) Flux injection rate [40 CFR 63.1512(o)] - The Permittee must use 

these procedures to 

establish an operating parameter value or range for the total reactive 

chlorine flux injection 

rate: 

(1) Continuously measure and record the weight of gaseous or liquid 

reactive flux 

injected for each 15 minute period during the HCl and D/F tests, 

determine and 

record the 15-minute block average weights, and calculate and record the 

total 

weight of the gaseous or liquid reactive flux for the 3 test runs; 

(2) Record the identity, composition, and total weight of each addition 

of solid reactive 

flux for the 3 test runs; 

(3) Determine the total reactive chlorine flux injection rate by adding 

the recorded 

measurement of the total weight of chlorine in the gaseous or liquid 

reactive flux 

injected and the total weight of chlorine in the solid reactive flux 

using Equation 5; 

Wt .F1W1 .F2 W2 .Eq.5. 

Where: 

Wt = Total chlorine usage, by weight; 

F1 = Fraction of gaseous or liquid flux that is chlorine; 

W1 = Weight of reactive flux gas injected; 
F2 = Fraction of solid reactive chloride flux that is chlorine (e.g., F = 

0.75 for 

magnesium chloride); and 

W2 = Weight of solid reactive flux. 
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(4) Divide the weight of total chlorine usage (Wt) for the 3 test runs by 

the recorded 

measurement of the total weight of feed for the 3 test runs; and 

(5) If a solid reactive flux other than magnesium chloride is used, the 

Permittee must 

derive the appropriate proportion factor subject to approval by IDEM, 

OAQ. 

(h) Lime injection [40 CFR 63.1512(p)] - For an affected source or 

emission unit using a 

lime-injected fabric filter system, the Permittee shall use these 

procedures during the HCl and 

D/F tests to establish an operating parameter value for the feeder 

setting for each operating 

cycle or time period used in the performance test. 

(1) For continuous lime injection systems, ensure that lime in the feed 

hopper or silo is 

free-flowing at all times; and 

(2) Record the feeder setting for the 3 test runs. If the feed rate 

setting varies during the 

runs, determine and record the average feed rate from the 3 runs. 

(i) Secondary aluminum processing unit [40 CFR 63.1513(e)] – The 

Permittee shall use the 

following procedures to determine compliance with the emission limits of 

PM, HCl, and D/F 

emissions for a secondary aluminum processing unit: 

(1) Use Equation 9 to compute the mass-weighted PM emissions for a 

secondary 

aluminum processing unit. Compliance is achieved if the mass-weighted 

emissions 

for the secondary aluminum processing unit (EcPM) is less than or equal 

to the 

emission limit for the secondary aluminum processing unit calculated 

using Equation 

1 in 40 CFR 63.1505(k) (Condition D.6.7(d)(1)). 

. . 

.. . 

. 

. 

. 

. 

. 

n

i 1 

ti 

n

i 1 

tiPM ti 

CPM 

T 

E T 
E (Eq. 9) 

Where: 

ECPM = The mass-weighted PM emissions for the secondary aluminum 

processing unit; 

EtiPM = Measured PM emissions for individual emission unit i; 

Tti = The average feed rate for individual emission unit i during the 

operating cycle or performance test period; and 

n = The number of emission units in the secondary aluminum 

processing unit. 

(2) Use Equation 10 to compute the aluminum mass-weighted HCl emissions 

for the 

secondary aluminum processing unit. Compliance is achieved if the massweighted 

emissions for the secondary aluminum processing unit (EcHCl) is less than 

or equal 

to the emission limit for the secondary aluminum processing unit 

calculated using 

Equation 2 in 40 CFR 63.1505(k) (Condition D.6.7(d)(2)). 
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. . 

.. . 

. 

. 

. 

. 

. 

n

i 1 

ti 

n

i 1 

tiHCl ti 

CHCl 

T 

E T 

E (Eq. 10) 

Where: 

ECHCl = The mass-weighted HCl emissions for the secondary aluminum 

processing unit; 

EtiHCl = Measured HCl emissions for individual emission unit i; 

Tti = The average feed rate for individual emission unit i during the 

operating cycle or performance test period; and 

n = The number of emission units in the secondary aluminum 

processing unit. 

(3) Use Equation 11 to compute the aluminum mass-weighted D/F emissions 

for the 

secondary aluminum processing unit. Compliance is achieved if the massweighted 

emissions for the secondary aluminum processing unit is less than or 

equal to the 

emission limit for the secondary aluminum processing unit calculated 

using Equation 

3 in 40 CFR 63.1505(k) (Condition D.6.7(d)(3)). 

. . 

.. . 

. 

. 

. 

. 

. 

n

i 1 

ti 

n

i 1 

tiD/F ti 

CD/F 

T 

E T 
E (Eq. 11) 

Where: 

ECD/F = The mass-weighted D/Fl emissions for the secondary aluminum 

processing unit; 

EtiD/F = Measured D/F emissions for individual emission unit i that 

processes other than clean charge materials; 

Tti = The average feed rate for individual emission unit i during the 

operating cycle or performance test period; and 

n = The number of emission units in the secondary aluminum 

processing unit. 

(j) To convert D/F measurements to TEQ units, the Permittee must use the 

procedures and 

equations in ―Interim Procedures for Estimating Risks Associated with 

Exposures to Mixtures 

of Chlorinated Dibenzo-p-Dioxins and -Dibenzofurans (CDDs and CDFs) and 

1989 Update‖ 

(EPA–625/3–89–016), incorporated by reference in 40 CFR 63.1502, 

available from the 

National Technical Information Service (NTIS), 5285 Port Royal Road, 

Springfield, Virginia, 

NTIS no. PB 90–145756. [40 CFR 63.1513(d)] 
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D.6.12 Non NESHAP Emission Units Testing Requirements [326 IAC 2-7-6(1), 

(6)] [326 IAC 2-1.1-11] 

(a) In order to demonstrate compliance with Condition D.6.4 and no later 

than August 20, 2013 

or within 5 years after the date of the last valid compliance test, 

whichever is later, the 

Permittee shall perform PM, and PM10 testing for the dross cooling 

operation while operating 

with one (1) large baghouse and one (1) small baghouse, and two (2) small 

baghouses only 

in operation, utilizing methods as approved by the Commissioner. These 

tests shall be 

repeated at least once every five (5) years from the date of the last 

valid compliance 

demonstration. PM10 includes filterable and condensable PM10. Testing 

shall be conducted 

in accordance with Section C- Performance Testing. During the stack test, 

the Permittee 

shall determine the sensitivity of the bag leak detection system and 

calibrate the particulate 

concentration readings of the electrodynamic bag leak detector in order 

to provide an output 

relative to outlet grain loading levels. 

(b) No later than January 5, 2010 or within 5 years from the date of the 

last valid compliance 

test, whichever is later, the Permittee shall perform NOx testing on a 

representative #1 

complex holder (east holding furnace or west holding furnace). These 

tests shall be repeated 

at least once every five (5) years from the date of the last valid 

compliance demonstration. 

Testing shall be conducted in accordance with Section C- Performance 

Testing. 

(c) In order to demonstrate compliance with D.6.2(a), the Permittee shall 

perform NOx testing for 

the 8EMC Melter 8M3, before it is modified no later than January 5, 2010 

and not later than 

one hundred eighty (180) days after initial startup of the modified 8M3 

melter, utilizing 

methods as approved by the Commissioner. These tests shall be repeated at 

least once 

every five (5) years from the date of this valid compliance 

demonstration. Testing shall be 

conducted in accordance with Section C - Performance Testing. 

(d) No later than January 5, 2010, in order to demonstrate compliance 

with D.6.2(a), the 

Permittee shall perform NOx testing for the 8EMC Melter 8M1 and 8EMC 

Melter 8M2, 

utilizing methods as approved by the Commissioner. These tests shall be 

repeated at least 
once every five (5) years from the date of this valid compliance 

demonstration. Testing shall 

be conducted in accordance with Section C - Performance Testing. 

(e) In order to demonstrate compliance with D.6.2(d), ―A2 after the 

modification‖, the Permittee 

shall perform NOx testing for the 8EMC west holding furnace (8WH), not 

later than one 

hundred eighty (180) days after initial startup of the modified 8EMC west 

holding furnace 

(8WH), utilizing methods as approved by the Commissioner. These tests 

shall be repeated 

at least once every five (5) years from the date of this valid compliance 

demonstration. 

Testing shall be conducted in accordance with Section C - Performance 

Testing. No later 

than January 7, 2010, in order to demonstrate compliance with D.6.2(d), 

A1 and A2 before 

the modification, the Permittee shall perform NOx testing on a 

representative 8EMC holder 

(east holding furnace or west holding furnace), utilizing methods 

approved by the 

Commissioner. Testing shall be conducted in accordance with Section C -

Performance 

Testing. No later than October 2, 2014, in order to demonstrate 

compliance with D.6.2(d), A1 

after the 8 EMC west holding furnace has been modified, the Permittee 

shall perform NOx 

testing on the 8 EMC east holding furnace, utilizing methods as approved 

by the 

Commissioner. Testing shall be conducted in accordance with Section C -

Performance 

Testing. These tests shall be repeated at least once every five (5) years 

from the date of this 

valid compliance demonstration. 

(f) No later than August 19, 2013 and in order to demonstrate compliance 

with Conditions 

D.6.5(a)(2) and (3), and D.6.5(b)(2) and (3), the Permittee shall perform 

PM and PM10 

testing for the Rotary Group 1 Furnace Baghouse, utilizing methods as 

approved by the 

Commissioner. PM10 includes filterable and condensible PM10. These tests 

shall be 

repeated at least once every five (5) years from the date of this valid 

compliance 

demonstration. Testing shall be conducted in accordance with Section C -

Performance 

Testing. 

(g) No later than August 19, 2013 and in order to demonstrate compliance 

with Condition 
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D.6.5(c)(1) and (2), the Permittee shall perform NOx testing for the 

Rotary Group 1 Furnace, 

utilizing methods as approved by the Commissioner. These tests shall be 

repeated at least 

once every five (5) years from the date of this valid compliance 

demonstration. Testing shall 

be conducted in accordance with Section C - Performance Testing. 

(h) No later than August 19, 2013 and in order to demonstrate compliance 

with Condition 

D.6.5(c)(1), (2) and (3), the Permittee shall perform NOx testing for the 

Rotary Group 1 

Furnace and Rotary Group 1 Furnace Duct Heater, utilizing methods as 

approved by the 

Commissioner. These tests shall be repeated at least once every five (5) 

years from the date 

of this valid compliance demonstration. Testing shall be conducted in 

accordance with 

Section C - Performance Testing. 

D.6.13 PM and PM10 Control from Dross Cooling Operation [326 IAC 2-7-

6(6)] 

In order to comply with Condition D.6.4, at least two baghouses 

controlling PM and PM10 shall be in 

operation at all times when the dross cooling is in operation, and shall 

follow the following: 

(a) When the dross cooling operation is controlled by one (1) small 

baghouse and one (1) large 

baghouse, all roll-up doors in the dross cooling building shall be 

closed, except when 

vehicles are entering or exiting the building, and hot dross shall be 

placed beneath a canopy 

hood that exhausts to the large baghouse; and 

(b) When the dross cooling process is operating and neither large 

baghouse is operating, all 

skim room doors shall be closed, except when trucks enter to deliver hot 

dross, or move 

dross to the rotary group I furnace and further provided that loadout to 

third party dross trucks 

was suspended until at least one large baghouse is returned to service. 

D.6.14 PM Control from Coated Scrap Shredder [326 IAC 2-7-6(6)] 

In order to comply with Condition D.6.7(a), the Coated Scrap Shredder 

shall not operate at a 

throughput of greater than 25,000 pounds per hour. 

D.6.15 Particulate Control from Rotary Group 1 Furnace [326 IAC 2-7-6(6)] 

(a) In order to comply with Condition D.6.5(a)(1) and (b)(1), the Rotary 

Group 1 Furnace 

Baghouse for particulate control shall be in operation and control 

emissions from the Rotary 

Group 1 Furnace, the Rotary Group 1 Furnace Duct Heater, and the Rotary 

Group 1 Furnace 
Baghouse Reagent Hopper at times the Rotary Group 1 Furnace , the Rotary 

Group 1 

Furnace Duct Heater, and the Rotary Group 1 Furnace Baghouse Reagent 

Hopper are in 

operation. 

(b) In the event that bag failure is observed in a multi-compartment 

baghouse, if operations will 

continue for ten (10) days or more after failure is observed before the 

failed units will be 

repaired or replaced, the Permittee shall promptly notify the IDEM, OAQ 

of the expected date 

the failed units will be repaired or replaced. The notification shall 

also include the status of 

the applicable compliance monitoring parameters with respect to normal, 

and the results of 

any response actions taken up to the time of notification. 

D.6.16 Particulate Control from Flux Salt Storage Bin [326 IAC 2-7-6(6)] 

In order to comply with Condition D.6.5(a)(5) and (b)(5), the flux salt 

storage bin vent filter for 

particulate control shall be in operation and control emissions from the 

flux salt storage bin and the 

salt flux loading operations at times the flux salt storage bin is being 

loaded from the delivery truck. 

Compliance Monitoring Requirements [326 IAC 2-7-6(1)] [326 IAC 2-7-5(1)] 

[326 IAC 20-1] [40 CFR 63, 

Subpart A] [326 IAC 20-70] [40 CFR 63.1510] 

D.6.17 NESHAP Monitoring Requirements [326 IAC 20-1] [40 CFR 63, Subpart 

A] [326 IAC 20-70] 

[40 CFR 63.1510] 

The Permittee shall monitor all control equipment and processes according 

to the requirements in this 

section. Monitoring requirements for each type of emission unit are 

summarized in Table 3 to 

40 CFR 63, Subpart RRR. 
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Permit Reviewer: Dr. Trip Sinha 

(a) Operation, maintenance, and monitoring (OM&M) plan [40 CFR 

63.1510(b)] - The Permittee 

shall prepare for each affected emission unit regulated by 40 CFR 63, 

Subpart RRR, a 

written operation, maintenance, and monitoring (OM&M) plan. The plan 

shall be 

accompanied by a written certification by the Permittee that the OM&M 

plan satisfies all the 

requirements of 40 CFR 63.1510 and is otherwise consistent with the 

requirements of 

40 CFR 63, Subpart RRR. The Permittee shall comply with all of the 

provisions of the OM&M 

plan as submitted to the IDEM, OAQ, unless and until the plan is revised 

in accordance with 

the following procedures. If IDEM, OAQ determines at any time after 

receipt of the OM&M 

plan that any revisions of the plan are necessary to satisfy the 

requirements of 

40 CFR 63.1510 or Subpart RRR, the Permittee shall promptly make all 

necessary revisions 

and resubmit the revised plan. 

If the Permittee determines that any other revisions of the OM&M plan are 

necessary, such 

revisions will not become effective until the Permittee submits a 

description of the changes 

and a revised plan incorporating them to the IDEM, OAQ. Each plan shall 

contain the 

following information: 

(1) Process and control device parameters to be monitored to determine 

compliance, 

along with established operating levels or ranges, as applicable, for 

each process 

and control device. 

(2) A monitoring schedule for each affected source and emission unit. 

(3) Procedures for the proper operation and maintenance of each process 

unit and 

add-on control device used to meet the emission limits in 40 CFR 63.1505 

(Condition 

D.6.7). 

(4) Procedures for the proper operation and maintenance of monitoring 

devices or 

systems used to determine compliance, including: 

(i) Calibration and certification of accuracy of each monitoring device, 

at least 

once every 6 months or according to the manufacturer's instructions; and 

(ii) Procedures for the quality control and quality assurance of 

continuous 

emission as required by the general provisions in Subpart A of this 

40 CFR 63. 

(5) Procedures for monitoring process and control device parameters. 
(6) Corrective actions to be taken when process or operating or add-on 

control device 

parameters deviate from the value or range established in paragraph 

(a)(1) of this 

Condition, including: 

(i) Procedures to determine and record the cause of an deviation or 

excursion, 

and the time the deviation or excursion began and ended; and 

(ii) Procedures for recording the corrective action taken, the time 

corrective 

action was initiated, and the time/date corrective action were completed. 

(7) A maintenance schedule for each process and control device that is 

consistent with 

the manufacturer's instructions and recommendations for routine and longterm 

maintenance. 

(8) Documentation of the work practice and pollution prevention measures 

used to 

achieve compliance with the applicable emission limits and a sitespecific monitoring 

plan as required in paragraph (i) of this condition for each group 1 

furnace not 

equipped with an add-on air pollution control device. 
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Permit Reviewer: Dr. Trip Sinha 

(b) Labeling [40 CFR 63.1510(c)] - The Permittee shall inspect the labels 

for each group 1 

furnace, group 2 furnace, and in-line fluxer at least once per calendar 

month to confirm that 

posted labels as required by the operational standard in 40 CFR 

63.1506(b) (Condition 

D.6.8(b)) are intact and legible. 

(c) Capture/collection system [40 CFR 63.1510(d)] - the Permittee shall: 

(1) Install, operate, and maintain a capture/collection system for each 

affected source 

and emission unit equipped with an add-on air pollution control device; 

and 

(2) Inspect each capture/collection and closed vent system at least once 

each calendar 

year to ensure that each system is operating in accordance with the 

operating 

requirements in §63.1506(c) and record the results of each inspection. 

(d) Feed/charge weight [40 CFR 63.1510(e)] - For an emission unit 

regulated by 40 CFR 63, 

Subpart RRR and subject to an emission limit in lb/ton of feed/charge, 

the Permittee shall 

calibrate, operate, and maintain a device to measure and record the total 

weight of 

feed/charge to the affected emission unit over the same operating cycle 

or time period used 

in the performance test. Feed/charge within SAPUs shall be measured and 

recorded on an 

emission unit-by-emission unit basis. 

(1) The accuracy of the weight measurement device or procedure shall be 

+/-1 percent 

of the weight being measured. 

(2) The Permittee shall verify the calibration of the weight measurement 

device in 

accordance with the schedule specified by the manufacturer, or if no 

calibration 

schedule is specified, at least once every 6 months. 

(e) Fabric filters and lime-injected fabric filters [40 CFR 63.1510(f)] -

for an affected source or 

emission unit using a fabric filter or lime-injected fabric filter to 

comply with the requirements 

of this subpart, the Permittee shall install, calibrate, maintain, and 

continuously operate a bag 

leak detection system as required in paragraph (e)(1) of this condition. 

(1) These requirements apply to the owner or operator of a new or 

existing affected 

source or existing emission unit using a bag leak detection system. 

(i) The owner or operator must install and operate a bag leak detection 

system 

for each exhaust stack of a fabric filter. 
(ii) Each triboelectric bag leak detection system must be installed, 

calibrated, 

operated, and maintained according to the ―Fabric Filter Bag Leak 

Detection 

Guidance,‖ (September 1997). This document is available from the U.S. 

Environmental Protection Agency; Office of Air Quality Planning and 

Standards; Emissions, Monitoring and Analysis Division; Emission 

Measurement Center (MD–19), Research Triangle Park, NC 27711. This 

document also is available on the Technology Transfer Network (TTN) under 

Emission Measurement Technical Information (EMTIC), Continuous 

Emission Monitoring. Other bag leak detection systems must be installed, 

operated, calibrated, and maintained in a manner consistent with the 

manufacturer's written specifications and recommendations. 

(iii) The bag leak detection system must be certified by the manufacturer 

to be 

capable of detecting PM emissions at concentrations of 10 milligrams per 

actual cubic meter (0.0044 grains per actual cubic foot) or less. 

(iv) The bag leak detection system sensor must provide output of relative 

or 

absolute PM loadings. 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

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(v) The bag leak detection system must be equipped with a device to 

continuously record the output signal from the sensor. 

(vi) The bag leak detection system must be equipped with an alarm system 

that 

will sound automatically when an increase in relative PM emissions over a 

preset level is detected. The alarm must be located where it is easily 

heard 

by plant operating personnel. 

(vii) For positive pressure fabric filter systems, a bag leak detection 

system must 

be installed in each baghouse compartment or cell. For negative pressure 

or 

induced air fabric filters, the bag leak detector must be installed 

downstream 

of the fabric filter. 

(viii) Where multiple detectors are required, the system's 

instrumentation and 

alarm may be shared among detectors. 

(ix) The baseline output must be established by adjusting the range and 

the 

averaging period of the device and establishing the alarm set points and 

the 

alarm delay time. 

(x) Following initial adjustment of the system, the Permittee shall not 

adjust the 

sensitivity or range, averaging period, alarm set points, or alarm delay 

time 

except as detailed in the OM&M plan. In no case may the sensitivity be 

increased by more than 100 percent or decreased more than 50 percent 

over a 365-day period unless such adjustment follows a complete fabric 

filter 

inspection which demonstrates that the fabric filter is in good operating 

condition. 

(f) Fabric filter inlet temperature [40 CFR 63.1510(h)] - for a group 1 

furnace using a 

lime-injected fabric filter, in order to comply with the requirements of 

40 CFR 63, 

Subpart RRR, the Permittee shall: 

(1) The Permittee shall install, calibrate, maintain, and operate a 

device to continuously 

monitor and record the temperature of the fabric filter inlet gases 

consistent with the 

requirements for continuous monitoring systems in 40 CFR 60, Subpart A. 

(2) The temperature monitoring device must meet each of these performance 

and 

equipment specifications: 

(i) The monitoring system must record the temperature in 15-minute block 

averages and calculate and record the average temperature for each 3-hour 

block period. 
(ii) The recorder response range must include zero and 1.5 times the 

average 

temperature established according to the requirements in §63.1512(n) 

(Condition XYZ). 

(iii) The reference method must be a National Institute of Standards and 

Technology calibrated reference thermocouple-potentiometer system or 

alternate reference, subject to approval by the Administrator. 

(g) Lime injection [40 CFR 63.1510(i)] - for an affected source or 

emission unit using a 

lime-injected fabric filter to comply with the requirements of 40 CFR 63, 

Subpart RRR, the 

Permittee shall. 

(1) The Permittee shall verify that the lime of a continuous lime 

injection system is 

always free-flowing by: 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 116 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

(i) Subject to the approval of the permitting agency, installing, 

operating and 

maintaining a load cell, carrier gas/lime flow indicator, carrier gas 

pressure 

drop measurement system or other system to confirm that lime is 

free-flowing. If lime is found not to be free-flowing, the Permittee 

shall 

promptly initiate and complete corrective action. A plan to assure that 

lime is 

free-flowing was submitted on July 11, 2007. IDEM, OAQ has reviewed and 

approved the submitted plan. 

(2) For a continuous lime injection system, the Permittee shall record 

the lime feeder 

setting once each day of operation. 

(h) Total reactive flux injection rate [40 CFR 63.1510(j)] - These 

requirements apply to a group 1 

furnace (with or without add-on air pollution control devices) or in-line 

fluxer. The Permittee 

shall: 

(1) calibrate, operate, and maintain a device to continuously measure and 

record the 

weight of gaseous or liquid reactive flux injected to each affected 

emission unit; 

(i) The monitoring system shall record the weight for each 15-minute 

block 

period, during which reactive fluxing occurs, over the same operating 

cycle 

or time period used in the performance test; 

(ii) The accuracy of the weight measurement device shall be +/- 1 percent 

of the 

weight of the reactive component of the flux being measured; and 

(iii) The Permittee shall verify the calibration of the weight 

measurement device 

in accordance with the schedule specified by the manufacturer, or if no 

calibration schedule is specified, at least once every 6 months. 

(2) Calculate and record the gaseous or liquid reactive flux injection 

rate (lb/ton) for each 

operating cycle or time period used in the performance test using the 

procedure in 

40 CFR 63.1512(o) (ConditionD.6.11(g)); 

(3) Record, for each 15-minute block period during each operating cycle 

or time period 

used in the performance test during which reactive fluxing occurs, the 

time, weight, 

and type of flux for each addition of: 

(i) Gaseous or liquid reactive flux other than chlorine; and 

(ii) Solid reactive flux. 

(4) Calculate and record the total reactive flux injection rate for each 

operating cycle or 
time period used in the performance test using the procedure in 40 CFR 

63.1512(o) 

(Condition D.6.11(g)). 

(i) Group 1 furnace without add-on air pollution control devices [40 CFR 

63.1510(o)] – The 

following requirements apply: 
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Permit Reviewer: Dr. Trip Sinha 

(1) The Permittee must develop, in consultation with the IDEM, OAQ, a 

written 

site-specific monitoring plan. The site-specific monitoring plan shall be 

submitted to 

the IDEM, OAQ as part of the OM&M plan. The site-specific monitoring plan 

shall

contain sufficient procedures to ensure continuing compliance with all 

applicable 

emission limits and shall demonstrate, based on documented test results, 

the 

relationship between emissions of PM, HCl, and D/F and the proposed 

monitoring 

parameters for each pollutant. Test data shall establish the highest 

level of PM, HCl, 

and D/ F that will be emitted from the furnace. This may be determined by 

conducting 

performance tests and monitoring operating parameters while charging the 

furnace 

with feed/charge materials containing the highest anticipated levels of 

oils and 

coatings and fluxing at the highest anticipated rate. If IDEM, OAQ 

determines that 

any revisions of the site-specific monitoring plan are necessary to meet 

the 

requirements of 40 CFR 63.1510 or 40 CFR 63,Subpart RRR, the Permittee 

shall 

promptly make all necessary revisions and resubmit the revised plan to 

the IDEM, 

OAQ; 

(2) Each site-specific monitoring plan shall document each work practice, 

equipment/design practice, pollution prevention practice, or other 

measure used to 

meet the applicable emission standards; and 

(3) Each site-specific monitoring plan shall include provisions for unit 

labeling as 

required in Condition paragraph (b) of this condition, feed/charge weight 

measurement as required in paragraph (d) of this condition and flux 

weight 

measurement as required in paragraph (h) of this condition. 

(j) Monitoring of scrap contamination level by calculation method for 

group 1 furnace without 

add-on air pollution control devices [40 CFR 63.1510(q)] - For a group 1 

furnace dedicated to 

processing a distinct type of furnace feed/charge composed of scrap with 

a uniform 

composition (such as rejected product from a manufacturing process for 

which the 

coating-to-scrap ratio can be documented), the Permittee may include a 

program in the 
site-specific monitoring plan for determining, monitoring, and certifying 

the scrap contaminant 

level using a calculation method rather than a scrap inspection program. 

A scrap contaminant 

monitoring program using a calculation method shall include: 

(1) Procedures for the characterization and documentation of the 

contaminant level of 

the scrap prior to the performance test; 

(2) Limitations on the furnace feed/charge to scrap of the same 

composition as that used 

in the performance test - If the performance test was conducted with a 

mixture of 

scrap and clean charge, limitations on the proportion of scrap in the 

furnace 

feed/charge to no greater than the proportion used during the performance 

test; and 

(3) Operating, monitoring, recordkeeping, and reporting requirements to 

ensure that no 

scrap with a contaminant level higher than that used in the performance 

test is 

charged to the furnace. 

(k) Group 2 furnace [40 CFR 63.1510(r)] - These requirements apply to the 

group 2 furnace. The 

Permittee shall: 

(1) Record a description of the materials charged to each furnace, 

including any 

nonreactive, non-HAP-containing/non-HAP-generating fluxing materials or 

agents; 

and 

(2) Submit a certification of compliance with the applicable operational 

standard for 

charge materials in 40 CFR 63.1506(o) (Condition D.6.8(g)) for each 6-

month 

reporting period. Each certification shall contain the information in 

40 CFR 63.1516(b)(2)(v). 

(l) Site-specific requirements for secondary aluminum processing units 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

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Permit Reviewer: Dr. Trip Sinha 

[40 CFR 63.1510(s)]: 

(1) The Permittee shall include, within the OM&M plan prepared in 

accordance with 

paragraph (a) of this condition, the following information: 

(i) The identification of each emission unit in the secondary aluminum 

processing unit; 

(ii) The specific pollution prevention measure to be used for each 

emission unit 

in the secondary aluminum processing unit and the date of its 

installation or 

application; 

(iii) The emission limit calculated for each secondary aluminum 

processing unit 

and performance test results with supporting calculations demonstrating 

initial compliance with each applicable emission limit; 

(iv) Information and data demonstrating compliance for each emission unit 

with 

all applicable design, equipment, work practice or operational standards 

of 

40 CFR 63 Subpart RRR; and 

(v) The monitoring requirements applicable to each emission unit in a 

secondary 

aluminum processing unit and the monitoring procedures for daily 

calculation 

of the 3-day, 24-hour rolling average using the procedure in paragraph 

(m) of 

this condition. 

(2) The SAPU compliance procedures within the OM&M plan shall not contain 

any of the 

following provisions: 

(i) Any averaging among emissions of differing pollutants; 

(ii) The inclusion of any affected sources other than emission units in a 

secondary aluminum processing unit; 

(iii) The inclusion of any emission unit while it is shutdown; or 

(iv) The inclusion of any periods of startup, shutdown, or malfunction in 

emission 

calculations. 

(3) To revise the SAPU compliance provisions within the OM&M plan prior 

to the end of 

the permit term, the Permittee shall submit a request to the IDEM, OAQ 

containing 

the information required by paragraph (l)(1) of this condition and obtain 

approval of 

the IDEM, OAQ prior to implementing any revisions. 

(m) Secondary aluminum processing unit [40 CFR 63.1510(t)] - The 

Permittee shall calculate and 

record the 3-day, 24-hour rolling average emissions of PM, HCl, and D/F 

for each secondary 

aluminum processing unit on a daily basis. To calculate the 3-day, 24-

hour rolling average, 
the Permittee shall: 

(1) Calculate and record the total weight of material charged to each 

emission unit in the 

secondary aluminum processing unit for each 24-hour day of operation 

using the 

feed/charge weight information required in paragraph (d) of this 

condition. 

(2) Multiply the total feed/charge weight to the emission unit, for each 

emission unit for 

the 24-hour period by the emission rate (in lb/ton of feed/ charge) for 

that emission 

unit (as determined during the performance test) to provide emissions for 

each 

emission unit for the 24-hour period, in pounds; 
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(3) Divide the total emissions for each SAPU for the 24-hour period by 

the total material 

charged to the SAPU over the 24-hour period to provide the daily emission 

rate for 

the SAPU; 

(4) Compute the 24-hour daily emission rate using Equation 4: 

. . 

. 

. 

. 

. 

. 

. 

n 

i 1 

i 

n

i 1 

i i 

day 

T

T ER 

E (Eq. 4) 

Where: 

Eday = The daily PM, HCl, or D/F emission rate for the secondary aluminum 

processing unit for the 24-hour period; 

Ti = The total amount of feed for emission unit i for the 24-hour period 

(tons); 

ERi = The measured emission rate for emission unit i as determined in the 

performance test (lb/ton of feed/charge); and 

n = The number of emission units in the secondary aluminum processing 

unit. 

(5) Calculate and record the 3-day, 24-hour rolling average for each 

pollutant each day 

by summing the daily emission rates for each pollutant over the 3 most 

recent 

consecutive days and dividing by 3. 

D.6.18 Bag Leak Detection Systems for Dross Cooling Baghouses and Rotary 

Group 1 Furnace Baghouse 

[326 IAC 2-7-6(1)] [326 IAC 2-7-5(1)] 

The Permittee shall operate the continuous bag leak detection system for 

the dross cooling system 

and for the Rotary Group 1 Furnace Baghouse. The bag leak detection 

systems shall meet the 

following requirements: 

(a) Each electrodynamic bag leak detection system shall be calibrated, 

operated, and 

maintained according to the manufacturer's recommendations; 

(b) Each bag leak detection system shall be certified by the manufacturer 

to be capable of 
detecting PM emissions at concentrations of ten (10) milligrams per 

actual cubic meter 

(0.0044 grains per actual cubic foot) or less; 

(c) Each bag leak detection system sensor shall provide output of 

relative or absolute PM 

loadings; 

(d) Each bag leak detection system shall be equipped with a device to 

continuously record the 

output signal from the sensor; 

(e) Each bag leak detection system shall be equipped with an alarm system 

that will sound 

automatically when an increase in relative PM emissions over a preset 

level is detected. The 

alarm shall be located where it is easily heard by plant operating 

personnel; 

(f) Each bag leak detector shall be installed downstream of the fabric 

filter; 

(g) Where multiple detectors are required, the system's instrumentation 

and alarm may be 

shared among detectors; 
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(h) The baseline outputs shall be established by adjusting the range and 

the averaging period of 

each device and establishing the alarm set points and the alarm delay 

times; 

(i) Following initial adjustment of each system, the Permittee shall not 

adjust the sensitivity or 

range, averaging period, alarm set points, or alarm delay time except as 

detailed in the PMP. 

In no case may the sensitivity be increased by more than one hundred 

(100%) percent or 

decreased more than fifty (50%) percent over a 365-day period unless such 

adjustment 

follows a complete fabric filter inspection which demonstrates that the 

fabric filter is in good 

operating condition; and 

(j) In the event that a bag leak detection system should malfunction, 

fail or otherwise need 

repair, the Permittee shall perform visible emissions notations of the 

stack exhausts 

associated with that bag leak detection system as follows: 

(1) Visible emission notations of the stack exhausts shall be performed 

once per day 

during normal daylight operations. A trained employee shall record 

whether 

emissions are normal or abnormal; 

(2) For processes operated continuously, "normal" means those conditions 

prevailing, or 

expected to prevail, eighty percent (80%) of the time the process is in 

operation, not 

counting startup or shut down time; 

(3) In the case of batch or discontinuous operations, readings shall be 

taken during that 

part of the operation that would normally be expected to cause the 

greatest 

emissions; 

(4) A trained employee is an employee who has worked at the plant at 

least one (1) 

month and has been trained in the appearance and characteristics of 

normal visible 

emissions for that specific process and 

(5) For the dross cooling operation, if abnormal emissions are observed, 

the Permittee 

shall take reasonable response steps in accordance with Section C –

Response to 

Excursions and Exceedances. Failure to take response steps in accordance 

with 

Section C – Response to Excursions and Exceedances, shall be considered a 

deviation from this permit. 

D.6.19 Bag Leak Detection Alarm Activation [326 IAC 2-7-6(1)] [326 IAC 2-

7-5(1) 
In the event that a bag leak detection system for the dross cooling 

system alarm is activated 

for any reason, the Permittee shall take the corrective action specified 

in Section C -

Response to Excursions or Exceedances, and the following response steps: 

The tests performed on December 17, 2004, confirmed that the dross 

cooling operation can 

meet the PM limit by operating only two small baghouses. For the four (4) 

dross cooling 

operation baghouses, which are single compartment baghouses, when more 

than two (2) of 

the four (4) baghouses fail, if failure indicated by an opacity violation 

or a bag leak detection 

alarm activation that is not a false alarm, or if bag failure is 

determined by other means, such 

as daily checks of the particulate concentration readings from 

electrodynamic bag leak 

detectors or visible emissions notations, then the associated process 

will be shut down 

immediately. Operations may continue only if the event qualifies as an 

emergency and the 

Permittee satisfies the requirements of the emergency provisions of this 

permit (Section C -

Emergency Provisions). 

D.6.20 Visible Emissions Notations for Flux Salt Storage Silo Bin Vent 

Filter [326 IAC 2-7-6(1)] 

[326 IAC 2-7-5(1)] 

(a) Visible emission notations of the flux salt storage silo bin vent 

filter stack exhausts shall be 

performed once per week during normal daylight operations. A trained 

employee shall record 

whether emissions are normal or abnormal; 
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(b) For processes operated continuously, "normal" means those conditions 

prevailing, or 

expected to prevail, eighty percent (80%) of the time the process is in 

operation, not counting 

startup or shut down time; 

(c) In the case of batch or discontinuous operations, readings shall be 

taken during that part of 

the operation that would normally be expected to cause the greatest 

emissions; 

(d) A trained employee is an employee who has worked at the plant at 

least one (1) month and 

has been trained in the appearance and characteristics of normal visible 

emissions for that 

specific process and 

(e) For the flux salt storage silo operation, if abnormal emissions are 

observed, the Permittee 

shall take reasonable response steps in accordance with Section C –

Response to 

Excursions and Exceedances. Failure to take response steps in accordance 

with Section C 

– Response to Excursions and Exceedances, shall be considered a deviation 

from this 

permit. 

D.6.21 Water Level Monitoring [326 IAC 2-7-6(1)] [326 IAC 2-7-5(1)] 

(a) The Permittee shall track the operation of the solenoid, which 

controls a water level electrode 

of automatic water control boxes on the #2 Offline East Melter Charging 

rotoclone, #2 Offline 

West Melter Charging rotoclone, #2 Offline East Melter West Chip Silo 

rotoclone, and #2 

Offline East Melter East Chip Silo rotoclones. Whenever the automatic 

control fails, the 

Permittee shall fill the rotoclone by hand. 

(b) The failure of the automatic control is not a deviation. Failure to 

take response steps in 

accordance with Section C - Response to Excursions or Exceedances shall 

be considered a 

deviation from this permit. 

(c) The Permittee shall completely clean out the #2 Offline East Melter 

Charging rotoclone, #2 

Offline West Melter Charging rotoclone, #2 Offline East Melter West Chip 

Silo rotoclone, and 

#2 Offline East Melter East Chip Silo rotoclones at least once per month. 

In the event that a 

rotoclone and its associated process have been shutdown, its cleaning 

schedule shall be 

amended commencing on the date of the shutdown such that it is cleaned 

within 4 weeks of 

the shutdown date. It shall be returned to a cleaning schedule of at 

least once per month 
commencing on the date it resumes operation. 

Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-

7-19] [326 IAC 20-1] 

[40 CFR 63, Subpart A] [326 IAC 20-70] [40 CFR 63.1516] [40 CFR 63.1517] 

D.6.22 NESHAP Record Keeping Requirements [326 IAC 20-1] [40 CFR 63, 

Subpart A] [326 IAC 20-70] 

[40 CFR 63.1517] 

(a) Pursuant to 40 CFR 63.10(b), the Permittee shall maintain files of 

all information (including all 

reports and notifications) required by the general provisions and Subpart 

RRR of 40 CFR 63. 

[40 CFR 63.1617(a)] 

(1) The Permittee may retain records on microfilm, computer disks, 

magnetic tape, or 

microfiche; 

(2) The Permittee shall report required information on paper or on a 

labeled computer 

disk using commonly available and EPA-compatible computer software; and 

(b) Pursuant to 40 CFR 63.1517(b) - In addition to the general records 

required by 

40 CFR 63.10(b), the Permittee shall maintain records of: 

(1) For each affected source and emission unit with emissions controlled 

by a fabric filter 

or a lime-injected fabric filter [40 CFR 63.1517(b)(1)]: 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

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Permit Reviewer: Dr. Trip Sinha 

(i) If a bag leak detection system is used, the number of total operating 

hours 

for the affected source or emission unit during each 6-month reporting 

period, records of each alarm, the time of the alarm, the time corrective 

action was initiated and completed, and a brief description of the cause 

of 

the alarm and the corrective action(s) taken. 

(2) For each group 1 furnace, subject to D/F and HCl emission standards 

with emissions 

controlled by a lime-injected fabric filter, records of 15-minute block 

average inlet 

temperatures for each lime-injected fabric filter, including any period 

when the 3-hour 

block average temperature exceeds the compliant operating parameter value 

+14 °C 

(+25 °F), with a brief explanation of the cause of the excursion and the 

corrective 

action taken [40 CFR 63.1517(b)(3)]. 

(3) For each affected source and emission unit with emissions controlled 

by a 

lime-injected fabric filter [40 CFR 63.1517(b)(4)]: 

(i) Records of inspections at least once every 8-hour period verifying 

that lime 

is present in the feeder hopper or silo and flowing, including any 

inspection 

where blockage is found, with a brief explanation of the cause of the 

blockage and the corrective action taken, and records of inspections at 

least 

once every 4-hour period for the subsequent 3 days. If flow monitors, 

pressure drop sensors or load cells are used to verify that lime is 

present in 

the hopper and flowing, records of all monitor or sensor output including 

any 

event where blockage was found, with a brief explanation of the cause of 

the 

blockage and the corrective action taken; 

(ii) If lime feeder setting is monitored, records of daily inspections of 

feeder 

setting, including records of any deviation of the feeder setting from 

the 

setting used in the performance test, with a brief explanation of the 

cause of 

the deviation and the corrective action taken. 

(4) For each group 1 furnace (with or without add-on air pollution 

control devices) and 

each in-line fluxer [40 CFR 63.1517(b)(5)]; 

(i) Records of 15-minute block average weights of gaseous or liquid 

reactive 

flux injection, total reactive flux injection rate and calculations 

(including 
records of the identity, composition, and weight of each addition of 

gaseous, 

liquid or solid reactive flux), including records of any period the rate 

exceeds 

the compliant operating parameter value and corrective action taken. 

(5) For each continuous monitoring system, records required by 40 CFR 

63.10(c) 

[40 CFR 63.1517(b)(6)]; 

(6) For each emission unit subject to an emission standard in lb/ton of 

feed/charge, 

records of feed/charge weights for each operating cycle or time period 

used in the 

performance test [40 CFR 63.1517(b)(7)]; 

(7) Approved site-specific monitoring plan for a group 1 furnace with 

records 

documenting conformance with the plan [40 CFR 63.1517(b)(8)]; 

(8) Records of all charge materials and fluxing materials or agents for a 

group 2 furnace 

[40 CFR 63.1517(b)(12)]; 

(9) Records of monthly inspections for proper unit labeling for each 

affected emission 

unit subject to labeling requirements [40 CFR 63.1517(b)(13)]; 

(10) Records of annual inspections of emission capture/collection and 

closed vent 

systems [40 CFR 63.1517(b)(14)];. 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

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Permit Reviewer: Dr. Trip Sinha 

(11) Records for any approved alternative monitoring or test procedure 

[40 CFR 63.1517(b)(15)]; 

(12) Current copy of all required plans, including any revisions, with 

records documenting 

conformance with the applicable plan, including [40 CFR 63.1517(b)(16)]: 

(i) Startup, shutdown, and malfunction plan; 

(ii) OM&M plan; and 

(iii) Site-specific secondary aluminum processing unit emission plan. 

(13) For each secondary aluminum processing unit, records of total charge 

weight, for 

each 24-hour period and calculations of 3-day, 24-hour rolling average 

emissions 

[40 CFR 63.1517(b)(17)]; 

(14) For each group 1 furnace, records of the 3-day, 24-hour rolling 

average emissions of 

PM, HCl, and D/F emissions calculations; and 

(15) For each in-line degasser, records of the 3-day, 24-hour rolling 

average emissions of 

PM, and HCl emissions calculations. 

(c) The Permittee shall keep a record of the written startup, shutdown, 

and malfunction plan and 

a program of corrective action for malfunctioning process and air 

pollution control equipment. 

The Permittee shall also keep records of each event as required by 40 CFR 

63.10(b). 

(d) The Permittee shall keep records of each event as required by 40 CFR 

63.10(b) and record if 

an action taken during a startup, shutdown, or malfunction is not 

consistent with the 

procedures in the plan as described in 40 CFR 63.6(e)(3). 

(e) The Permittee shall keep records as required by 40 CFR 63.1510(q) 

(Condition D.6.17(j)). 

D.6.23 Record Keeping Requirements 

(a) To document compliance with Condition D.6.2(a)(3), the Permittee 

shall maintain the 

following: 

(1) Records of the natural gas consumption of Melter 8M1. 

(2) Records of the natural gas consumption of Melters 8M2 and 8M3. 

(3) Records of NOx emissions from Melters 8M1, 8M2, and 8M3. 

(b) To document compliance with Condition D.6.2(b)(4) and (c)(4), the 

Permittee shall maintain 

records of the combined chlorine and flux salt input rates to 8M1, 8M2, 

and 8M3. 

(c) To document compliance with Conditions D.6.2(b)(5) and (c)(5), the 

Permittee shall maintain 

records of PM and PM10 emissions from 8M1, 8M2, and 8M3. 

(d) To document compliance with Condition D.6.2(d), the Permittee shall 

maintain records of the 

following: 

(1) The natural gas consumption of the 8EMC east holding furnace. 
(2) The natural gas consumption of the 8EMC west holding furnace. 

(3) NOx emissions from the 8EMC east and west holding furnaces. 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

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Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

(e) To document compliance with Conditions D.6.2(e)(4),and (f)(4), the 

Permittee shall maintain 

records of the combined chlorine and flux salt rates to 8 EMC east and 8 

EMC west holding 

furnaces. 

(f) To document compliance with Conditions D.6.2(e)(5),and (f)(5), the 

Permittee shall maintain 

records of PM and PM10 emissions from the 8 EMC east and west holding 

furnaces. 

(g) To document compliance with Condition D.6.2(g), the Permittee shall 

maintain records of the 

feed/charge rates of the 8EMC 8EH A622 and 8EMC 8WH A622 in-line 

degassing units. 

(h) To document compliance with Conditions D.6.2(h), and (i), the 

Permittee shall maintain 

records of the chlorine input rates to the 8EMC 8EH A622 and 8EMC 8WH 

A622 in-line 

degassing units. 

(i) To document compliance with Condition D.6.2(j), the Permittee shall 

maintain records of the 

feed/charge rate of the #1 complex ACD units. 

(j) To document compliance with Condition D.6.2(m) and (n), the Permittee 

shall maintain 

records of PM and PM10 emissions from the #1 complex east holding furnace 

and the #1 

complex west holding furnace. 

(k) To document compliance with Condition D.6.2(o), the Permittee shall 

maintain records of flux 

salt input rates to the #1 complex east holding furnace and the #1 

complex west holding 

furnace. 

(l) To document compliance with Condition D.6.2(p), the Permittee shall 

maintain records of the 

feed/charge rate for the #1 complex east holding furnace and the #1 

complex west holding 

furnace. 

(m) To document compliance with Condition D.6.3(a), the Permittee shall 

maintain records of the 

amount of material charged to OLG1, and the OLG1 PM Ef. 

(n) To document compliance with Condition D.6.3(b), the Permittee shall 

maintain records of the 

amount of natural gas usage for OLG1 furnaces. 

(o) To document compliance with Condition D.6.4(a), the Permittee shall 

maintain records of the 

throughput of the dross and salt cake. 

(p) To document compliance with Conditions D.6.5(a)(4) and D.6.5(b)(4), 

the Permittee shall 

maintain records of the following: 

(1) The charge/feed rate when the Rotary group 1 Furnace is processing 

only dross. 
(2) The charge/feed rate when the charge/feed processed at the Rotary 

group 1 Furnace 

contains any amount of scrap. 

(3) Total PM emissions from the Rotary Group 1 Furnace operations. 

(4) Total PM10 emissions from the Rotary Group 1 Furnace operations. 

(q) To document compliance with Condition D.6.5(c)(4), the Permittee 

shall maintain records of 

the following: 

(1) The natural gas consumption of the Rotary Group 1 Furnace when 

processing only 

dross. 

(2) The natural gas consumption of the Rotary Group 1 Furnace when 

processing any 

amount of scrap. 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

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Permit Reviewer: Dr. Trip Sinha 

(3) The natural gas consumption of the Rotary Group 1 Furnace Duct 

Heater. 

(4) Total NOx emissions from the Rotary Group 1 Furnace and the Rotary 

Group 1 

Furnace Duct Heater. 

(r) To document compliance with Condition D.6.14, the Permittee shall 

maintain records of the 

average throughput of the Coated Scrap Shredder. 

(s) To document compliance with Condition D.6.18(a), the Permittee shall 

keep a log of the 

calibration test results for the dross cooling baghouses leak detectors 

and the Rotary Group 

1 Furnace Baghouse leak detectors. 

(t) To document compliance with Condition D.6.18(j), the Permittee shall 

maintain records of 

daily visible emission notations of the stack exhaust for the dross 

cooling baghouses and the 

Rotary Group 1 Furnace Baghouse, when the applicable bag leak detection 

system 

malfunctions, fails or otherwise needs repair. 

(u) To document compliance with Condition D.6.19, the Permittee shall 

maintain records of the 

occurrences of all bag leak detection alarms. 

(v) To document compliance with Condition D.6.20 the Permittee shall 

maintain a weekly record 

of visible emission notations of flux salt storage silo bin vent filter 

stack exhausts. 

(w) To document compliance with Condition D.6.21(a), the Permittee shall 

maintain records of 

the automatic water level control and the response steps taken. 

(x) To document compliance with Condition D.6.22(c), the Permittee shall 

maintain records of 

cleanout dates for #2 Offline East Melter Charging rotoclone, #2 Offline 

West Melter 

Charging rotoclone, #2 Offline East Melter West Chip Silo rotoclone, and 

#2 Offline East 

Melter East Chip Silo rotoclone. 

(y) The Permittee shall maintain the following as required under 

Conditions D.6.18, D.6.19, 

D.6.20, D.6.21, and D.6.22: 

(1) Documentation of all response steps implemented per event. 

(z) All records shall be maintained in accordance with Section C -

General Record Keeping 

Requirements, of this permit. 

D.6.24 NESHAP Reporting Requirements [326 IAC 20-1] [40 CFR 63, Subpart 

A] [326 IAC 20-70] 

[40 CFR 63.1516] 

(a) Startup, shutdown, and malfunction plan/reports [40 CFR 63.1516(a)] -

The Permittee shall 
develop and a written plan as described in 40 CFR 63.6(e)(3) that 

contains specific 

procedures to be followed for operating and maintaining the source during 

periods of startup, 

shutdown, and malfunction, and a program of corrective action for 

malfunctioning process 

and air pollution control equipment used to comply with the standard. In 

addition to the 

information required in 40 CFR 63.6(e)(3), the plan shall include: 

(1) Procedures to determine and record the cause of the malfunction and 

the time the 

malfunction began and ended; and 

(2) Corrective actions to be taken in the event of a malfunction of a 

process or control 

device, including procedures for recording the actions taken to correct 

the 

malfunction or minimize emissions. 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

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Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

(b) Excess emissions/summary report [40 CFR 63.1516(b)] - As required by 

40 CFR 63.10(e)(3), 

the Permittee shall submit semiannual reports within 60 days after the 

end of each 6-month 

period. Each report shall contain the information specified in 40 CFR 

63.10(c). When no 

deviations of parameters have occurred, the Permittee shall submit a 

report stating that no 

excess emissions occurred during the reporting period. 

(1) A report shall be submitted if any of these conditions occur during a 

6-month 

reporting period: 

(i) The corrective action specified in the OM&M plan for a bag leak 

detection 

system alarm was not initiated within 1 hour. 

(ii) An excursion of a compliant process or operating parameter value or 

range 

(e.g., screw feeder setting, total reactive chlorine flux injection rate, 

afterburner operating temperature, definition of acceptable scrap, or 

other 

approved operating parameter); 

(iii) An action taken during a startup, shutdown, or malfunction was not 

consistent with the procedures in the plan as described in 

40 CFR 63.6(e)(3); 

(iv) The emission units (including an emission unit in a secondary 

aluminum 

processing unit) was not operated according to the requirements of 

40 CFR 63, Subpart RRR; and 

(v) A deviation from the 3-day, 24-hour rolling average emission limit 

for a 

secondary aluminum processing unit. 

(2) Each report shall include each of the following certifications, as 

applicable: 

(i) For each group 2 furnace: Only clean charge materials were processed 

in 

any group 2 furnace during this reporting period, and no fluxing was 

performed or all fluxing performed was conducted using only nonreactive, 

non-HAP-containing/non-HAP-generating fluxing gases or agents, except for 

cover fluxes, during this reporting period; 

(ii) The Coated Aluminum Shredder did not operate in excess of an hourly 

aluminum scrap throughput of 25,000 lbs/hr. Compliance with 25,000 lbs/hr 

aluminum scrap throughput limitation satisfies the PM emissions 

limitation 

specified by 40 CFR 63, Subpart RRR, i.e. 0.01 grains / dry standard 

cubic 

foot; 

(3) The Permittee shall submit the results of any performance test 

conducted during the 

reporting period, including one complete report documenting test methods 

and
procedures, process operation, and monitoring parameter ranges or values 

for each 

test method used for a particular type of emission point tested. 

(c) Annual compliance certifications - For the purpose of annual 

certifications of compliance 

required by 40 CFR Part 70, the Permittee shall certify continuing 

compliance based upon, 

but not limited to, the following conditions: 

(1) Any period of excess emissions, as defined in paragraph (b)(1) of 

this Condition, that 

occurred during the year were reported as required by 40 CFR 63 Subpart 

RRR; and 

(2) All monitoring, recordkeeping, and reporting requirements were met 

during the year. 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

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Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

D.6.25 Reporting Requirements 

A monthly summary of the information to document compliance with 

Conditions D.6.2 (a)(3), (b)(5), 

(c)(5), (d)(3), (e)(5), (f)(5), (g), (j), (m), (n), and (p), D.6.3(a) and 

(b), D.6.4(a), and D.6.5(a)(4), (b)(4), 

and (c)(4) shall be submitted to the addresses listed in Section C -

General Reporting Requirements, 

of this permit, using the reporting forms located at the end of this

permit, or its equivalent, within thirty 

(30) days after the end of the quarter being reported. The report 

submitted by the Permittee does 

require the certification by the ―responsible official‖ as defined by 326 

IAC 2-7-1(34). 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

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Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY

COMPLIANCE DATA SECTION 

NOx Emissions Quarterly Report 

Source Name: Alcoa Inc.- Warrick Operations 

Source Address: Jct. IN Hwys. 66 & 61, Newburgh, Indiana 47629-0010 

Mailing Address: Bldg. 860 E, P.O. Box 10, Newburgh, Indiana 47629 

Part 70 Permit No.: T173-6627-00007 

Facility: Melters 8M1, 8M2, and 8M3 

Parameter: NOx Emissions 

Limit: Shall not exceed 63.18 tons per twelve (12) consecutive month 

period. 

Quarter _______ Year: ______ 

Month 

NOx 

(tons) 

NOx 

(tons) 

NOx 

(tons) 

This Month Previous 11 Months 12 Month Total 

. No deviation occurred in this month. 

. Deviation/s occurred in this month. 

Deviation has been reported on: 

Submitted by: 

Title/Position: 

Signature: 

Date: 

Phone: 

Attach a signed certification to complete this report. 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 129 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION 

PM Emissions Quarterly Report 

Source Name: Alcoa Inc.- Warrick Operations 

Source Address: Jct. IN Hwys. 66 & 61, Newburgh, Indiana 47629-0010 

Mailing Address: Bldg. 860 E, P.O. Box 10, Newburgh, Indiana 47629 

Part 70 Permit No.: T173-6627-00007 

Facility: Melters 8M1, 8M2, and 8M3 

Parameter: PM Emissions 

Limit: 49.57 tons per twelve (12) consecutive month period 

Quarter _______ Year: ______ 

Month 

PM 

(tons) 

PM 

(tons) 

PM 

(tons) 

This Month 

Previous 11 Months 

12 Month Total 

. No deviation occurred in this month. 

. Deviation/s occurred in this month. 

Deviation has been reported on: 

Submitted by: 

Title/Position: 

Signature: 

Date: 

Phone: 

Attach a signed certification to complete this report. 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 130 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION 

PM10 Emissions Quarterly Report 

Source Name: Alcoa Inc.- Warrick Operations 

Source Address: Jct. IN Hwys. 66 & 61, Newburgh, Indiana 47629-0010 

Mailing Address: Bldg. 860 E, P.O. Box 10, Newburgh, Indiana 47629 

Part 70 Permit No.: T173-6627-00007 

Facility: Melters 8M1, 8M2, and 8M3 

Parameter: PM10 Emissions 

Limit: 53.54 tons per twelve (12) consecutive month period 

Quarter _______ Year: ______ 

Month 

PM10 

(tons) 

PM10 

(tons) 

PM10 

(tons) 

This Month 

Previous 11 Months 

12 Month Total 

. No deviation occurred in this month. 

. Deviation/s occurred in this month. 

Deviation has been reported on: 

Submitted by: 

Title/Position: 

Signature: 

Date: 

Phone: 

Attach a signed certification to complete this report. 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 131 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION 

NOx Emissions Quarterly Report 

Source Name: Alcoa Inc.- Warrick Operations 

Source Address: Jct. IN Hwys. 66 & 61, Newburgh, Indiana 47629-0010 

Mailing Address: Bldg. 860 E, P.O. Box 10, Newburgh, Indiana 47629 

Part 70 Permit No.: T173-6627-00007 

Facility: 8EMC east and 8EMC west holding furnaces 

Parameter: NOx Emissions 

Limit: Shall not exceed 15.89 tons per twelve (12) consecutive month 

period 

Quarter _______ Year: ______ 

Month 

NOx 

(tons) 

NOx 

(tons) 

NOx 

(tons) 

This Month Previous 11 Months 12 Month Total 

. No deviation occurred in this month. 

. Deviation/s occurred in this month. 

Deviation has been reported on: 

Submitted by: 

Title/Position: 

Signature: 

Date: 

Phone: 

Attach a signed certification to complete this report. 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 132 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION 

PM Emissions Quarterly Report 

Source Name: Alcoa Inc.- Warrick Operations 

Source Address: Jct. IN Hwys. 66 & 61, Newburgh, Indiana 47629-0010 

Mailing Address: Bldg. 860 E, P.O. Box 10, Newburgh, Indiana 47629 

Part 70 Permit No.: T173-6627-00007 

Facility: 8EMC east holding and 8EMC west holding furnace 

Parameter: PM 

Limit: 34.17 tons per twelve (12) consecutive month period 

Quarter _______ Year: ______ 

Month 

PM 

(tons) 

PM 

(tons) 

PM 

(tons) 

This Month Previous 11 Months 12 Month Total 

. No deviation occurred in this month. 

. Deviation/s occurred in this month. 

Deviation has been reported on: 

Submitted by: 

Title/Position: 

Signature: 

Date: 

Phone: 

Attach a signed certification to complete this report. 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 133 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION 

PM10 Emissions Quarterly Report 

Source Name: Alcoa Inc.- Warrick Operations 

Source Address: Jct. IN Hwys. 66 & 61, Newburgh, Indiana 47629-0010 

Mailing Address: Bldg. 860 E, P.O. Box 10, Newburgh, Indiana 47629 

Part 70 Permit No.: T173-6627-00007 

Facility: 8EMC east holding and 8EMC west holding furnace 

Parameter: PM10 

Limit: 49.89 tons per twelve (12) consecutive month period 

Quarter _______ Year: ______ 

Month 

PM10 

(tons) 

PM10 

(tons) 

PM10 

(tons) 

This Month Previous 11 Months 12 Month Total 

. No deviation occurred in this month. 

. Deviation/s occurred in this month. 

Deviation has been reported on: 

Submitted by: 

Title/Position: 

Signature: 

Date: 

Phone: 

Attach a signed certification to complete this report. 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 134 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION 

Feed/Charge Quarterly Report 

Source Name: Alcoa, Inc. - Warrick Operations 

Source Address: Jct. IN Hwys. 66 & 61, Newburgh, Indiana 47629-0010 

Mailing Address: Bldg. 860 E, P.O. Box 10, Newburgh, Indiana 47629 

Operation Permit No.: T173-6627-00007 

Facilities: 8EMC 8EH A622 and 8EMC 8WH A622 in-line degassing units 

Parameter: Feed/Charge Rate 

Limit: Total 823,440 tons per twelve (12) consecutive month period 

Quarter _______ Year: ______ 

Month 

Feed/Charge Rate(tons) Feed/Charge Rate(tons) Feed/Charge Rate(tons) 

This Month Previous 11 Months 12 Month Total 

8EMC 8EH and8EMC 8WH 8EMC 8EH and 8EMC 

8WH 

8EMC 8EH and8EMC 8WH 

. No deviation occurred in this month. 

. Deviation/s occurred in this month. 

Deviation has been reported on: 

Submitted by: 

Title/Position: 

Signature: 

Date: 

Phone: 

Attach a signed certification to complete this report. 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 135 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION 

Feed/Charge Quarterly Report 

Source Name: Alcoa, Inc. - Warrick Operations 

Source Address: Jct. IN Hwys. 66 & 61, Newburgh, Indiana 47629-0010 

Mailing Address: Bldg. 860 E, P.O. Box 10, Newburgh, Indiana 47629 

Operation Permit No.: T173-6627-00007 

Facility: #1 complex ACD Units 

Parameter: Feed/Charge 

Limit: 172,000 tons per twelve (12) consecutive month period 

Quarter _______ Year: ______ 

Month 

Feed/Charge 

(tons) 

Feed/Charge 

(tons) 

Feed/Charge 

(tons) 

This Month Previous 11 

Months 

12 Month Total 

. No deviation occurred in this month. 

. Deviation/s occurred in this month. 

Deviation has been reported on: 

Submitted by: 

Title/Position: 

Signature: 

Date: 

Phone: 

Attach a signed certification to complete this report. 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 136 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION 

PM Emissions Quarterly Report 

Source Name: Alcoa, Inc. - Warrick Operations 

Source Address: Jct. IN Hwys. 66 & 61, Newburgh, Indiana 47629-0010 

Mailing Address: Bldg. 860 E, P.O. Box 10, Newburgh, Indiana 47629 

Operation Permit No.: T173-6627-00007 

Facility: #1 complex east holding furnace and #1 complex west holding 

furnace 

Parameter: PM 

Limit: 3.87 tons per twelve (12) consecutive month period 

Quarter _______ Year: ______ 

Month 

PM 

(tons) 

PM 

(tons) 

PM 

(tons) 

This Month Previous 11 

Months 

12 Month Total 

. No deviation occurred in this month. 

. Deviation/s occurred in this month. 

Deviation has been reported on: 

Submitted by: 

Title/Position: 

Signature: 

Date: 

Phone: 

Attach a signed certification to complete this report. 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 137 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION 

PM10 Emissions Quarterly Report 

Source Name: Alcoa, Inc. - Warrick Operations 

Source Address: Jct. IN Hwys. 66 & 61, Newburgh, Indiana 47629-0010 

Mailing Address: Bldg. 860 E, P.O. Box 10, Newburgh, Indiana 47629 

Operation Permit No.: T173-6627-00007 

Facility: #1 complex east holding furnace and #1 complex west holding 

furnace 

Parameter: PM10 

Limit: 5.65 tons per twelve (12) consecutive month period 

Quarter _______ Year: ______ 

Month 

PM10 

(tons) 

PM10 

(tons) 

PM10 

(tons) 

This Month Previous 11 

Months 

12 Month Total 

. No deviation occurred in this month. 

. Deviation/s occurred in this month. 

Deviation has been reported on: 

Submitted by: 

Title/Position: 

Signature: 

Date: 

Phone: 

Attach a signed certification to complete this report. 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 138 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION 

Feed/Charge Quarterly Report 

Source Name: Alcoa, Inc. - Warrick Operations 

Source Address: Jct. IN Hwys. 66 & 61, Newburgh, Indiana 47629-0010 

Mailing Address: Bldg. 860 E, P.O. Box 10, Newburgh, Indiana 47629 

Operation Permit No.: T173-6627-00007 

Facility: #1 complex East and West Holding Furnaces 

Parameter: Feed/Charge 

Limit: Total 172,000 tons feed/charge per twelve (12) consecutive month 

period 

Quarter _______ Year: ______ 

Month 

Feed/Charge 

(tons) 

Feed/Charge 

(tons) 

Feed/Charge 

(tons) 

This Month Previous 11 

Months 

12 Month Total 

. No deviation occurred in this month. 

. Deviation/s occurred in this month. 

Deviation has been reported on: 

Submitted by: 

Title/Position: 

Signature: 

Date: 

Phone: 

Attach a signed certification to complete this report. 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 139 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION 

PM Emissions Quarterly Report 

Source Name: Alcoa, Inc. - Warrick Operations 

Source Address: Jct. IN Hwys. 66 & 61, Newburgh, Indiana 47629-0010 

Mailing Address: Bldg. 860 E, P.O. Box 10, Newburgh, Indiana 47629 

Operation Permit No.: T173-6627-00007 

Facility: OLG1 Furnaces 

Parameter: PM 

Limit: Less than 202 tons per twelve (12) consecutive month period 

Quarter _______ Year: ______ 

Month 

PM (tons) PM (tons) PM (tons) 

This Month Previous 11 

Months 

12 Month Total 

. No deviation occurred in this month.

. Deviation/s occurred in this month. 

Deviation has been reported on: 

Submitted by: 

Title/Position: 

Signature: 

Date: 

Phone: 

Attach a signed certification to complete this report. 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 140 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION 

Natural Gas Usage Quarterly Report 

Source Name: Alcoa, Inc. - Warrick Operations 

Source Address: Jct. IN Hwys. 66 & 61, Newburgh, Indiana 47629-0010 

Mailing Address: Bldg. 860 E, P.O. Box 10, Newburgh, Indiana 47629 

Operation Permit No.: T173-6627-00007 

Facility: OLG1 Furnaces 

Natural gas usage Limit: 1,847 million cubic feet per twelve (12) 

consecutive month period 

Quarter _______ Year: ______ 

Month 

Natural Gas 

(MMCF) 

Natural Gas 

(MMCF) 

Natural Gas 

(MMCF) 

This Month Previous 11 Months 12 Month Total 

. No deviation occurred in this month. 

. Deviation/s occurred in this month. 

Deviation has been reported on: 

Submitted by: 

Title/Position: 

Signature: 

Date: 

Phone: 

Attach a signed certification to complete this report. 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 141 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION 

Dross and Salt Cake Throughput Quarterly Report 

Source Name: Alcoa, Inc. - Warrick Operations 

Source Address: Jct. IN Hwys. 66 & 61, Newburgh, Indiana 47629-0010 

Mailing Address: Bldg. 860 E, P.O. Box 10, Newburgh, Indiana 47629 

Operation Permit No.: T173-6627-00007 

Facility: Dross Cooling Operation 

Parameter: Dross and salt cake 

Limit: 38,000 tons per twelve (12) consecutive month period 

Quarter _______ Year: ______ 

Month 

Dross 

(tons) 

Dross 

(tons) 

Dross 

(tons) 

This Month Previous 11 

Months 

12 Month Total 

. No deviation occurred in this month. 

. Deviation/s occurred in this month. 

Deviation has been reported on: 

Submitted by: 

Title/Position: 

Signature: 

Date: 

Phone: 

Attach a signed certification to complete this report. 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 142 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION 

NOx Emissions Quarterly Report 

Source Name: Alcoa Inc.- Warrick Operations 

Source Address: Jct. IN Hwys. 66 & 61, Newburgh, Indiana 47629-0010 

Mailing Address: Bldg. 860 E, P.O. Box 10, Newburgh, Indiana 47629 

Part 70 Permit No.: T173-6627-00007 

Facility: Rotary Group 1 Furnace 

Parameter: NOx Emissions 

Limit: Shall not exceed 39.90 tons per twelve (12) consecutive month 

period 

Quarter _______ Year: ______ 

Month 

NOx 

(tons) 

NOx 

(tons) 

NOx 

(tons) 

This Month Previous 11 Months 12 Month Total 

. No deviation occurred in this month. 

. Deviation/s occurred in this month. 

Deviation has been reported on: 

Submitted by: 

Title/Position: 

Signature: 

Date: 

Phone: 

Attach a signed certification to complete this report. 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 143 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION 

PM Emissions Quarterly Report 

Source Name: Alcoa Inc.- Warrick Operations 

Source Address: Jct. IN Hwys. 66 & 61, Newburgh, Indiana 47629-0010 

Mailing Address: Bldg. 860 E, P.O. Box 10, Newburgh, Indiana 47629 

Part 70 Permit No.: T173-6627-00007 

Facility: Rotary Group 1 Furnace 

Parameter: PM Emissions 

Limit: Shall not exceed 24.90 tons per twelve (12) consecutive month 

period 

Quarter _______ Year: ______ 

Month 

PM 

(tons) 

PM 

(tons) 

PM 

(tons) 

This Month Previous 11 Months 12 Month Total 

. No deviation occurred in this month. 

. Deviation/s occurred in this month. 

Deviation has been reported on: 

Submitted by: 

Title/Position: 

Signature: 

Date: 

Phone: 

Attach a signed certification to complete this report. 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 144 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION 

PM10 Emissions Quarterly Report 

Source Name: Alcoa Inc.- Warrick Operations 

Source Address: Jct. IN Hwys. 66 & 61, Newburgh, Indiana 47629-0010 

Mailing Address: Bldg. 860 E, P.O. Box 10, Newburgh, Indiana 47629 

Part 70 Permit No.: T173-6627-00007 

Facility: Rotary Group 1 Furnace 

Parameter: PM10 Emissions 

Limit: Shall not exceed 14.90 tons per twelve (12) consecutive month 

period 

Quarter _______ Year: ______ 

Month 

PM10 

(tons) 

PM10 

(tons) 

PM10 

(tons) 

This Month Previous 11 Months 12 Month Total 

. No deviation occurred in this month. 

. Deviation/s occurred in this month. 

Deviation has been reported on: 

Submitted by: 

Title/Position: 

Signature: 

Date: 

Phone: 

Attach a signed certification to complete this report. 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 145 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

SECTION D.7 ROLLING MILLS PLANT FACILITY OPERATION CONDITIONS 

Facility Description [326 IAC 2-7-5(15)] 

(The information describing the process contained In this facility 

description box is descriptive information and 

does not constitute enforceable conditions.) 

Rolling Mills 

(1) One (1) gauge reduction of aluminum facility, identified as hot 

reversing mill, using mineral spirits as 

lubricant, constructed in 1964, with a maximum capacity production of 

aluminum ingot of 225 tons per 

hour, controlled by a mist eliminator, and exhausting to Stack 811.1; 

(2) One (1) gauge reduction of aluminum facility, identified as 

continuous hot mill, using mineral spirits as 

lubricant, constructed in 1964, with a maximum capacity production of 

aluminum ingot of 225 tons per 

hour, controlled by a mist eliminator, and exhausting to Stack 814.1; 

(3) One (1) gauge reduction of aluminum facility, identified as cold mill 

#2, constructed in 1963, with a 

maximum capacity production of aluminum sheet of 75 tons per hour, using 

base oil as a coolant, 

emissions are uncontrolled, and exhausting to Stack 816.21; 

(4) One (1) gauge reduction of aluminum facility, identified as cold mill 

#4, constructed in 1970, with a 

maximum capacity production of aluminum sheet of 88.6 tons per hour, 

using base oil as a coolant, 

emissions are controlled by a mist eliminator, and exhausting to Stacks 

816.23 and 816.24. 

One (1) mist eliminator, constructed in 1970, and exhausting to Stacks 

816.23 and 816.24; 

Annealing furnaces 

(5) One (1) annealing furnace, identified as annealing furnace #5, 

constructed in 1964, using natural gas 

with a maximum heat input rate of 15 MMBtu/hr, exhausting to Stack 816.4; 

(6) One (1) annealing furnace, identified as annealing furnace #6, 

constructed in 1964, using natural gas 

with a maximum heat input rate of 15 MMBtu/hr, exhausting to Stack 816.5; 

(7) One (1) annealing furnace, identified as annealing furnace #7, 

constructed in 1964, using natural gas 

with a maximum heat input rate of 15 MMBtu/hr, exhausting to Stack 816.6; 

(8) One (1) annealing furnace, identified as annealing furnace #8, 

constructed in 1964, using natural gas 

with a maximum heat input rate of 15 MMBtu/hr, exhausting to Stack 816.7; 

(9) One (1) annealing furnace, identified as annealing furnace #9, 

constructed in 1964, using natural gas 

with a maximum heat input rate of 15 MMBtu/hr, exhausting to Stack 816.8; 

(10) One (1) annealing furnace, identified as annealing furnace #10, 

constructed in 1967, using natural 

gas with a maximum heat input rate of 15 MMBtu/hr, exhausting to Stack 

816.9; 
(11) One (1) annealing furnace, identified as annealing furnace #11, 

constructed in 1967, using natural 

gas with a maximum heat input rate of 15 MMBtu/hr, exhausting to Stack 

816.10; 

(12) One (1) annealing furnace, identified as annealing furnace #12, 

constructed in 1969, using natural 

gas with a maximum heat input rate of 15 MMBtu/hr, exhausting to Stack 

816.11; 

(13) One (1) annealing furnace, identified as annealing furnace #13, 

constructed in 1969, using natural 

gas with a maximum heat input rate of 15 MMBtu/hr, exhausting to Stack 

816.12; 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 146 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

(14) One (1) annealing furnace, identified as annealing furnace #14, 

constructed in 1970, using natural 

gas with a maximum heat input rate of 48 MMBtu/hr, exhausting to Stack 

816.13; 

(15) One (1) annealing furnace, identified as annealing furnace #15, 

constructed in 1970, using natural 

gas with a maximum heat input rate of 48 MMBtu/hr, exhausting to Stack 

816.14; 

(16) One (1) annealing furnace, identified as annealing furnace #16, 

constructed in 1970, using natural 

gas with a maximum heat input rate of 48 MMBtu/hr, exhausting to Stack 

816.15; 

(17) One (1) annealing furnace, identified as annealing furnace #17, 

constructed in 1972, using natural 

gas with a maximum heat input rate of 48 MMBtu/hr, exhausting to Stack 

816.16; 

Preheat furnaces 

(18) Five (5) preheat furnaces, identified as preheat furnace #2 - #6, 

constructed prior to 1973 and rebuilt 

in 1975, using natural gas with a maximum heat input rate of 18 MMBtu/hr 

each, and exhausting to 

Stacks 811.2 thru 811.6; 

(19) Ten (10) preheat furnaces, identified as preheat furnace #7 - #10, 

#28-#29, #31-#34, constructed in 

1966, using natural gas with a maximum heat input rate of 18 MMBtu/hr 

each, and exhausting to 

Stacks #811.7- #811.10, #811.28-#811.29, and #811.31-#811.34; 

(20) One (1) preheat furnaces, identified as preheat furnace #35, 

constructed in 1966, using natural gas 

with a maximum heat input rate of 18 MMBtu/hr, and exhausting to Stack 

811.35; 

(21) Eight (8) preheat furnaces, identified as preheat furnace #12 - #19, 

constructed in 1965, using natural 

gas with a maximum heat input rate of 12 MMBtu/hr each, and exhausting to 

Stacks #811.12-

#811.19, and #811.26; 

(21A) Three (3) preheat furnaces, identified as preheat furnace #22, #24, 

and #26, constructed in 1965, 

using natural gas with a maximum heat input rate of 18 MMBtu/hr each, and 

exhausting to Stacks 

#811.22, #811.24, and #811.26; 

(22) Five (5) preheat furnaces, identified as preheat furnace #36 - #40, 

constructed in 1969 and rebuilt in 

1978, using natural gas with a maximum heat input rate of 18 MMBtu/hr 

each, and exhausting to 

Stacks #811.36- #811.40; 

(23) Three (3) preheat furnaces, identified as preheat furnace #41 - #43, 

constructed in 1973, using 

natural gas with a maximum heat input rate of 18 MMBtu/hr each, and 

exhausting to Stacks #811.41-
#811.43; 

(24) Seven (7) preheat furnaces, identified as preheat furnace #11, #20, 

#21, #23, #25, #27, and #30, 

constructed in 1969 and rebuilt in 1990, using natural gas with a maximum 

heat input rate of 18 

MMBtu/hr each, and exhausting to Stacks #811.11, #811.20, #811.21, 

#811.23, #811.25, #811.27, 

and #811.30; 

Boilers 

(25) One (1) natural gas fired boiler, identified as Castrol reprocessing 

system boiler #1, constructed in 

1998, with a maximum heat input rate of 12 MMBtu/hr, exhausting to Stack 

816B1; 

(26) One (1) natural gas fired, boiler, identified as Castrol 

reprocessing system boiler #2, constructed in 

1998, with a maximum heat input rate of 12 MMBtu/hr, exhausting to Stack 

816B2; and 

(27) One (1) natural gas fired, boiler, identified as Castrol 

reprocessing system boiler #3, constructed in 

1998, with a maximum heat input rate of 12 MMBtu/hr, exhausting to Stack 

816B3. 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 147 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

Ingot Surface Treatment, consisting of: 

(28) One (1) scalper step cutter, with a maximum capacity of scalping 172 

tons of aluminum ingots per 

hour, constructed in 2001, exhausting to West Silo No. 1, which is 

controlled by the West Silo No.1 

Cyclone, which exhausts at stack 379.1. 

(29) One (1) Hot Ingot Oxide Brushing System, with a maximum capacity of 

225 tons of aluminum ingot 

per hour, constructed in 2000, exhausts inside the rolling bay building, 

and does not directly exhaust 

externally. 

(30) One (1) silo, identified as West Silo No. 1, with a maximum scrap 

throughput of 13.76 tons per hour, 

constructed in 1965, emissions uncontrolled, and exhausts at stack 379.1. 

(31) One (1) silo, identified as East Silo No. 2, with a maximum scrap 

throughput of 15.00 tons per hour, 

constructed in 1965, emissions uncontrolled, and exhausts at stack 379.2. 

Emission Limitations and Standards [326 IAC 2-7-5(1)] 

D.7.1 Particulate Emissions Limitations for Manufacturing Processes [326 

IAC 6-3-2] 

Pursuant to 326 IAC 6-3-2 (Particulate Emission Limitations for 

Manufacturing Processes), the 

allowable particulate emission rate from the Rolling Mills emission units 

shall be limited as follows: 

Facility Maximum Process 

Weight Rate 

(tons/hr) 

PM Emission 

Limit 

(lbs/hr) 

Ingot scalping 13.76 23.75 

Ingot preheating operation 172 56.9 

Ingot brush 225 59.8 

Reversing mills 172 56.9 

Continuous hot mills 172 56.9 

Annealing furnaces 172 56.9 

Ingot cold rolling 172 56.9 

East Silo No. 2 15 25.2 

The above particulate emissions rates were determined from the following 

formulae: 

Interpolation of the data for the process weight rate up to sixty 

thousand (60,000) pounds per hour by 

use of the equation: 

E = 4.10 P0.67 

Where: E = rate of emission in pounds per hour; and 

P = process weight rate in tons per hour. 

or 

Interpolation and extrapolation of the data for the process weight rate 

in excess of sixty thousand 

(60,000) pounds per hour by use of the equation: 
E = 55.0 P0.11 - 40 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 148 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

Where: E = rate of emission in pounds per hour; and 

P = process weight rate in tons per hour. 

When the process rate exceeds two hundred (200) tons per hour, the 

allowable emission may exceed 

the emission limits shown in the above table; provided the concentration 

of particulate in the 

discharge gases to the atmosphere is less than one-tenth (0.10) pound per 

thousand (1,000) pounds 

of gases. 

D.7.2 General Provisions Relating to NSPS, Subpart Dc [326 IAC 12] [40 

CFR Part 60, Subpart A] 

The provisions of 40 CFR 60, Subpart A – General Provisions, which are 

incorporated as 

326 IAC 12-1, apply to the boilers described in this section except when 

otherwise specified in 

40 CFR 60, Subpart Dc. 

D.7.3 Particulate Emissions Limitations for Sources of Indirect Heating 

[326 IAC 6-2-3] [326 IAC 6-2-4] 

(a) Pursuant to 326 IAC 6-2-4 (Particulate Emissions Limitations for 

Sources of Indirect Heating), 

the allowable particulate matter (PM) emissions from boiler #1, boiler 

#2, and boiler #3 shall 

be limited to 0.10 lb/MMBtu each. The above particulate emissions rates 

were determined 

from the following formula: 

Q0.26 

1.09 

Pt . 

Where: 

Pt = Pounds of particulate matter emitted per million Btu (lb/MMBtu) heat 

input; and 

Q = Total source maximum operating capacity rating in million Btu per 

hour (MMBtu/hr) heat 

input. The maximum operating capacity rating is defined as the maximum 

capacity at which 

the facility is operated or the nameplate capacity, whichever is 

specified in the facility's permit 

application, except when some lower capacity is contained in the 

facility's operation permit; in 

which case, the capacity specified in the operation permit shall be used. 

(b) Pursuant to 326 IAC 6-2-3(b) (Particulate Emissions Limitations for 

Sources of Indirect 

Heating), the allowable particulate matter (PM) emissions from annealing 

furnaces #5-#16, 

and preheat furnaces #7 - #40 shall be limited to 0.021 lb/MMBtu each. 

The above particulate 

emissions rate was determined from the following formula: 

76.5 Q0.75 N0.25 

C a h 

Pt 
. . 

. . 

. 

Where: 

C = Maximum ground level concentration with respect to distance from the 

point source at 

the critical wind speed for level terrain. This shall equal 50 micrograms 

per cubic meter 

(μ/m3) for a period not to exceed a sixty (60) minute time period; 

Pt = Pounds of particulate matter emitted per million Btu heat input 

(lb/MMBtu); 

Q = Total source maximum operating capacity rating in million Btu per 

hour (MMBtu/hr) heat 

input. The maximum operating capacity rating is defined as the maximum 

capacity at which 

the facility is operated or the nameplate capacity, whichever is 

specified in the facility's 

operation permit application, except when some lower capacity is 

contained in the facility's 

operation permit; in which case, the capacity specified in the operation 

permit shall be used; 

N = Number of stacks in fuel burning operation; 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 149 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

a = Plume rise factor which is used to make allowance for less than 

theoretical plume rise. 

The value 0.67 shall be used for Q less than or equal to 1,000 MMBtu/hr 

heat input; and 

h = Stack height in feet. If a number of stacks of different heights 

exist, the average stack 

height to represent N stacks shall be calculated by weighing each stack 

height with its 

particulate matter emission rate as follows: 

. 

.

. 

. 

. 

. . 

. 

N

i 1 

N

i 1 

pai Q

Hi pai Q 

h 

Where: 

pa = the actual controlled emission rate in lb/MMBtu using the emission 

factor from AP-42 or 

stack test data. Stacks constructed after January 1, 1971, shall be 

credited with GEP stack 

height only. GEP stack height shall be calculated as specified in 326 IAC 

1-7. 

Q, N, and h shall include the parameters for all facilities in operation 

on June 8, 1972. The 

resulting Pt is the emission limitation for annealing furnaces #5-#16, 

and preheat furnaces 

#7 - #40 and will not be affected by the addition of any subsequent 

facility. 

(c) Pursuant to 326 IAC 6-2-3(a) (Particulate Emissions Limitations for 

Sources of Indirect 

Heating), the allowable particulate matter (PM) emissions from annealing 

furnace #17 shall 

be limited to 0.021 lb/MMBtu. The above particulate emissions rate was 

determined from the 

following formula: 

76.5 Q0.75 N0.25 

Pt C a h

. . 

. . 

. 

Where: 
C = Maximum ground level concentration with respect to distance from the 

point source at 

the critical wind speed for level terrain. This shall equal 50 micrograms 

per cubic meter 

(μ/m3) for a period not to exceed a sixty (60) minute time period; 

Pt = Pounds of particulate matter emitted per million Btu heat input 

(lb/MMBtu); 

Q = Total source maximum operating capacity rating in million Btu per 

hour (MMBtu/hr) heat 

input. The maximum operating capacity rating is defined as the maximum 

capacity at which 

the facility is operated or the nameplate capacity, whichever is 

specified in the facility's 

operation permit application, except when some lower capacity is 

contained in the facility's 

operation permit; in which case, the capacity specified in the operation 

permit shall be used; 

N = Number of stacks in fuel burning operation; 

a = Plume rise factor which is used to make allowance for less than 

theoretical plume rise. 

The value 0.67 shall be used for Q less than or equal to 1,000 MMBtu/hr 

heat input; and 

h = Stack height in feet. If a number of stacks of different heights 

exist, the average stack 

height to represent N stacks shall be calculated by weighing each stack 

height with its 

particulate matter emission rate as follows: 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 150 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

. 

.

. 

. 

. 

. . 

. 

N

i 1 

i 

N

i 1 

i i

pa Q

H pa Q 

h 

Where: 

pa = the actual controlled emission rate in lb/MMBtu using the emission 

factor from AP-42 or 

stack test data. Stacks constructed after January 1, 1971, shall be 

credited with GEP stack 

height only. GEP stack height shall be calculated as specified in 326 IAC 

1-7. 

Q, N, and h shall include the parameters for all facilities in operation 

prior to the installation of 

annealing furnace #17. The resulting Pt is the emission limitation for 

annealing furnace #17 

and will not be affected by the addition of any subsequent emissions 

unit. 

(d) Pursuant to 326 IAC 6-2-3(a) (Particulate Emissions Limitations for 

Sources of Indirect 

Heating), the allowable particulate matter (PM) emissions from preheat 

furnaces #2 - #6 shall 

be limited to 0.020 lb/MMBtu each. The above particulate emissions rate 

was determined 

from the following formula: 

76.5 Q0.75 N0.25 

Pt C a h

. . 

. . 

. 

Where: 

C = Maximum ground level concentration with respect to distance from the 

point source at 

the critical wind speed for level terrain. This shall equal 50 micrograms 

per cubic meter 

(μ/m3) for a period not to exceed a sixty (60) minute time period; 

Pt = Pounds of particulate matter emitted per million Btu heat input 

(lb/MMBtu); 
Q = Total source maximum operating capacity rating in million Btu per 

hour (MMBtu/hr) heat 

input. The maximum operating capacity rating is defined as the maximum 

capacity at which 

the facility is operated or the nameplate capacity, whichever is 

specified in the facility's 

operation permit application, except when some lower capacity is 

contained in the facility's 

operation permit; in which case, the capacity specified in the operation 

permit shall be used; 

N = Number of stacks in fuel burning operation; 

a = Plume rise factor which is used to make allowance for less than 

theoretical plume rise. 

The value 0.67 shall be used for Q less than or equal to 1,000 MMBtu/hr 

heat input; and 

h = Stack height in feet. If a number of stacks of different heights 

exist, the average stack 

height to represent N stacks shall be calculated by weighing each stack 

height with its 

particulate matter emission rate as follows: 

. 

.

. 

. 

. 

. . 

. 

N

i 1 

i 

N

i 1 

i i

pa Q

H pa Q 

h 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 151 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

Where: 

pa = the actual controlled emission rate in lb/MMBtu using the emission 

factor from AP-42 or 

stack test data. Stacks constructed after January 1, 1971, shall be 

credited with GEP stack 

height only. GEP stack height shall be calculated as specified in 326 IAC 

1-7. 

Q, N, and h shall include the parameters for all facilities in operation 

prior to the installation of 

preheat furnaces #2 - #6. The resulting Pt is the emission limitation for 

preheat furnaces #2 -

#6, and will not be affected by the addition of any subsequent emissions 

unit. 

(e) Pursuant to 326 IAC 6-2-3(a) (Particulate Emissions Limitations for 

Sources of Indirect 

Heating), the allowable particulate matter (PM) emissions from preheat 

furnaces #41 - #43 

shall be limited to 0.019 lb/MMBtu each. The above particulate emissions 

rate was 

determined from the following formula: 

76.5 Q0.75 N0.25 

Pt C a h

. . 

. . 

. 

Where: 

C = Maximum ground level concentration with respect to distance from the 

point source at 

the critical wind speed for level terrain. This shall equal 50 micrograms 

per cubic meter 

(μ/m3) for a period not to exceed a sixty (60) minute time period; 

Pt = Pounds of particulate matter emitted per million Btu heat input 

(lb/MMBtu); 

Q = Total source maximum operating capacity rating in million Btu per 

hour (MMBtu/hr) heat 

input. The maximum operating capacity rating is defined as the maximum 

capacity at which 

the facility is operated or the nameplate capacity, whichever is 

specified in the facility's 

operation permit application, except when some lower capacity is 

contained in the facility's 

operation permit; in which case, the capacity specified in the operation 

permit shall be used; 

N = Number of stacks in fuel burning operation; 

a = Plume rise factor which is used to make allowance for less than 

theoretical plume rise. 

The value 0.67 shall be used for Q less than or equal to 1,000 MMBtu/hr 

heat input; and 

h = Stack height in feet. If a number of stacks of different heights 

exist, the average stack 
height to represent N stacks shall be calculated by weighing each stack 

height with its 

particulate matter emission rate as follows: 

. 

.

. 

. 

. 

. . 

. 

N

i 1 

i 

N

i 1 

i i

pa Q

H pa Q 

h 

Where: 

pa = the actual controlled emission rate in lb/MMBtu using the emission 

factor from AP-42 or 

stack test data. Stacks constructed after January 1, 1971, shall be 

credited with GEP stack 

height only. GEP stack height shall be calculated as specified in 326 IAC 

1-7. 

Q, N, and h shall include the parameters for all facilities in operation 

prior to the installation of 

preheat furnaces #41 - #43. The resulting Pt is the emission limitation 

for preheat furnaces 

#41 - #43 and will not be affected by the addition of any subsequent 

emissions unit. 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

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Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-

7-19] [326 IAC 12] 

[40 CFR 60, Subpart Dc] 

D.7.4 New Source Performance Standard (NSPS) Record Keeping Requirements 

[326 IAC 12] 

[40 CFR 60, Subpart Dc] 

Pursuant to 40 CFR 60.48c(g), the Permittee shall record and maintain 

records of the amounts of 

natural gas combusted in each boiler during each calendar month. 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 153 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

SECTION D.8 COATING PLANT FACILITY OPERATION CONDITIONS 

Facility Description [326 IAC 2-7-5(15)] 

(The information describing the process contained in this facility 

description box is descriptive information and 

does not constitute enforceable conditions.) 

(1) One (1) electro coat coil coating line no. 6, identified as CPL6, 

constructed in 1984, with emissions 

uncontrolled and exhausting to Stacks 819.7, and 819.13-819.15; 

(2) One (1) coil coating line no. 2, identified as CCL2, constructed in 

1987, with a temporary total 

enclosure system surrounding the coating stations. Emissions captured by 

the temporary total 

enclosure system and generated within the bake oven are controlled by a 

thermal oxidizer. Total 

coating line emissions exhausting to Stacks 826.5 and 826.6. 

One (1) thermal oxidizer system exhausting to Stacks 826.5; 

(3) One (1) coil coating line no. 3, identified as CCL3, constructed in 

1987, with a temporary total 

enclosure system surrounding the coating stations. Emissions captured by 

the temporary total 

enclosure system and generated within the bake oven are controlled by a 

thermal oxidizer. Total 

coating line emissions exhausting to Stacks 826.1 and 826.2. 

One (1) thermal oxidizer system exhausting to Stacks 826.1; 

Mix room 

(4) One (1) mixing room of solvents for coil coating lines process vats, 

installed in 1972, with a maximum 

of coating and solvents usage of 240,000 tons per year, with no control, 

and exhausting to Stack 

847.2; 

(5) Ten (10) coating mix stations, identified as Mix Room Stations #1-

#10, with a total of fourteen (14) 

400 gallon tanks with flat lids. Each of the fourteen (14) total tanks is 

vertical fixed roof tank located 

inside Building 847 with no control devices; 

Above ground tank farm 

(6) Two (2) fixed roof above ground tanks, identified as tanks, 01 and 

02, installed in 1997, with a 

maximum capacity of coatings or solvents storing 16,000 gallons, with no 

control, exhausting to 

Stacks 849.1 and 849.2; 

(7) Six (6) fixed roof above ground tanks, identified as tanks, 03, 04, 

05, 06, 07, and 08, installed in 

1997, with a maximum capacity of coatings or solvents storing of 9,700 

gallons, with no control, 

exhausting to Stacks 849.3 – 849.8; 

(8) Four (4) fixed roof above ground tanks, identified as tanks, B, C, D, 

and E, installed in 1997, with a 

maximum capacity of coatings or solvents storing of 7,800 gallons, with 

no control, exhausting to 
Stacks 849.B – 849.E; 

Process Support 

(9) One (1) underground storage tank, identified as Hazardous Waste 

Storage Tank, installed in 1992 

with a maximum capacity of 7,500 gallons with no control, exhausting to 

Stack 847.1. One (1) fixed 

roof above ground Unload tank, installed in 1996, with a maximum capacity 

of 8,000 gallons with no 

control, exhausting to stack 819.20; 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

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Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

(10) Two (2) fixed roof above ground tanks, identified as clear and gold 

electrocoat coating Dump Tanks, 

installed in 1996, with a maximum capacity of 20,000 gallons each, with 

no control, exhausting to 

Stacks 819.16 and 819.17; 

(11) One (1) fixed roof above ground tank, identified as gold electrocoat 

coating Unload Tank, installed in 

1996, with a maximum capacity of 8,000 gallons, with no control, 

exhausting to Stack 819.18; 

(12) One (1) fixed roof above ground tank, identified as clear 

electrocoat coating Day Tank, installed in 

1996, with a maximum capacity of 3,500 gallons, with no control, 

exhausting to stack 820.01; 

(13) One (1) fixed roof above ground tank, identified as experimental 

electrocoat coating Day Tank, 

installed in 1996, with a maximum capacity of 3,500 gallons, with no 

control, exhausting inside the 

building to stack 820.02; 

(14) One (1) fixed roof above ground tank, identified as gold electrocoat 

coating Day tank, installed in 

1996, with a maximum capacity of 3,500 gallons, with no control, 

exhausting to Stack 819.19; and 

(15) One (1) carbon silo, identified as 879 Carbon Silo, installed in 

1998 with a maximum capacity of 

50,000 pounds and a fill rate of 12.66 tons per hour, with no control, 

exhausting to Stack 877.4. 

Emission Limitations and Standards [326 IAC 2-7-5(1)] 

D.8.1 Particulate Emissions Limitations for Manufacturing Processes [326 

IAC 6-3-2] 

Pursuant to 326 IAC 6-3-2 (Particulate Emission Limitations for 

Manufacturing Processes), the 

allowable particulate emissions rates from Carbon Silo shall be limited 

to 22.5 lbs/hr. 

The above particulate emissions rate was determined from the following 

formula: 

Interpolation of the data for the process weight rate up to sixty 

thousand (60,000) pounds per hour by 

use of the equation: 

E = 4.10 P0.67 

Where: E = rate of emission in pounds per hour; and 

P = process weight rate in tons per hour. 

D.8.2 PSD Minor Limit [326 IAC 2-2] 

(a) Pursuant to CP 173-3276, issued on July 14, 1994, the total amount of 

volatile organic 

compounds (VOC) delivered to the coater head of the coil coating line 

CCL2 shall be less 

than 7,675 tons per 365 consecutive day period, with compliance 

demonstrated at the end of 

each day (the overall control efficiency of the VOC capture and control 

system shall be no 
less than 96%). Compliance with these VOC limits and the thermal 

oxidizer’s control 

efficiency of 96% shall render the requirements of Prevention of 

Significant Deterioration 

(PSD) rule, 326 IAC 2-2, not applicable for the coil coating line CCL2. 

(b) Pursuant to Amendment A 173-5524 to CP 173-4501 issued on May 6, 

1996: 

(1) The total amount of volatile organic compounds delivered to the coil 

coating line 

CCL3 coater head applicator ("Input") shall be less than the amount 

determined by 

equation 1 using parameters from Table 1. In addition, the total amount 

of volatile 

organic compounds delivered to the coater head applicator shall be 

limited such that 

the calculated volatile organic compound emissions, calculated using 

equation 2, 

shall be less than 112 tons per 365 consecutive day period, with 

compliance 

demonstrated at the end of each day. 

Equation 1: 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 155 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

.. 

. . 

.

. 

. . 

.

. 

. 

365 

y 1 

y 

365 

I 

Input Limit (tons/365days) 

Where: 

I = the VOC input parameter from Table 1 on day y; 

y = the day number in the 365-day roll; 

Equation 2: 

. . . . 

.2,000 lbs / ton. 

100% R * L D W 

Emission (tons/365 days) 

j 

i i y 

365

y 1 

y . .. 

. 

. 

Where: 

y = the day number in the 365-day roll;

j = each subsequent coating and solvent consumed per day; 

R = the most recently demonstrated overall reduction efficiency (ORE) on 

day 1; 

L = the quantity of the coating/solvent consumed per day (gallons/day); 

D = the density of the coating/solvent consumed (lb/gallon); and 

W = the weight percent VOC content of the coating/solvent consumed (as a 

decimal fraction). 

The Permittee may select alternate overall reduction efficiency/ VOC 

input parameter 

combinations from the following list of compliance options (Table 1): 

Compliance Option Required ORE 

(%) 

VOC input parameter 

(tons/365-days) 

1 98.0 5,600 

2 98.25 6,400 

3 98.5 7,467 

4 98.75 8,960 

5 99.0 11,200 
6 99.25 14,933 

7 99.5 22,400 

The Permittee indicated its selection of Option #4, commencing on May 1, 

2004. The 

Permittee may establish an alternate option through written notification 

to OAQ at 

least 14 days prior to the calendar month in which an alternate option is 

to begin 

being used for compliance purposes. This notification shall include the 

following: 

(i) The compliance option presently being used, and the new option to be 

used; 

(ii) The date on which the new compliance option is to take effect; 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 156 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

(iii) Documentation showing that the required ORE associated with the new 

compliance option is less than or equal to the most recently demonstrated 

ORE in testing conducted pursuant to 326 IAC 3-2.1 (Source Sampling 

Procedures) using test methods acceptable to the Commissioner; and 

(iv) Calculated VOC emissions for the 365 – day period ending prior to 

submission of the notification. 

(2) The enclosure room, the capture system, and the capture system fan’s 

measuring 

and recording devices shall be operating properly at all times during 

actual coating 

operations, at an electrical current across one or more of the fans that 

provide 

ventilation exhaust from the coating enclosure that has been demonstrated 

to 

maintain an average facial velocity of at least 200 feet per minute 

across all natural 

draft openings as measured by EPA Method 204, Equation 204-3. All doors 

and 

windows not classified as natural draft openings remain closed at all 

times during 

actual coating operations except for brief periods to allow personnel 

entrance to and 

exit from the enclosure room All doors and windows not classified as 

natural draft 

openings remain closed at all times during actual coating operations 

except for brief 

periods to allow personnel entrance to and exit from the enclosure room, 

and to 

replace empty coating or solvent containers. 

Compliance with these limits shall render the requirements of PSD rule 

326 IAC 2-2 not 

applicable for the No. 3 coil coating line. 

D.8.3 PSD Emission Limit [326 IAC 2-2] 

Pursuant to PSD Permit PSD (87) 1549 issued on May 29, 1984: 

(a) The total amount of VOC usage from the electro coat coil coating line 

CPL6 minus the VOC 

lost to the wastewater, shall not exceed 404 tons per twelve consecutive 

month period with 

compliance demonstrated at the end of each month; 

(b) The Permittee shall measure the wastewater flow from the electro coat 

line (CPL6) 

continuously and record the flow totalizing meter each week. The 

Permittee shall procure 

VOC samples of the wastewater each week and analyze for VOC content in 

the wastewater. 

The VOC lost to the wastewater shall be calculated monthly by multiplying 

the monthly 

average VOC content of the wastewater by the total monthly metered flow; 

and 
(c) The Permittee shall only use water based coatings in coil coating 

line CPL6. 

D.8.4 General Provisions Relating to NESHAP [326 IAC 20-1] [40 CFR Part 

63, Subpart A] [326 IAC 20-64] 

[40 CFR 63.5140] 

The provisions of 40 CFR Part 63, Subpart A - General Provisions, which 

are incorporated by 

reference in 326 IAC 20-1, apply to all coating lines except when 

otherwise specified in 40 CFR Part 

63, Subpart SSSS. Table 2 of 40 CFR 63 Subpart SSSS provides cross 

references to 40 CFR 63, 

Subpart A, indicating the applicability of the General Provisions 

requirements to 40 CFR 63, 

Subpart SSSS. 

D.8.5 Coil Coating Lines Emission Limits [326 IAC 12] [326 IAC 20-64] [40 

CFR 63.5120] [40 CFR 63.5140] 

[40 CFR 60.462] [326 IAC 8-2-4] 

(a) The Permittee shall limit average equivalent organic HAP emissions 

from coil coating lines 

CCL2, CCL3, and CPL6 to the level specified in paragraphs (a)(1) of this 

condition, and also 

limit VOC emissions from coating line CPL6 to the level specified in 

(a)(2) of this condition: 

(1) No more than 0.046 kilogram (kg) of organic HAP per liter of solids 

applied during 

each 12 - month compliance period; and 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 157 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

(2) No more than 0.28 kilogram (kg) of volatile organic compounds (VOC) 

per liter of 

solids applied for each calendar month. 

(b) The coil coating lines CCL2 and CCL3 shall be in compliance with the 

standards in Condition 

D.8.5(a)(1) and the operating requirements in Condition D.8.6 at all 

times, except during 

periods of start-up, shutdown, and malfunction of any capture system and 

control device 

used to comply with the standards. 

(c) The coil coating line CPL6 shall be in compliance with the standards 

in Condition D.8.5(a)

and (b) at all times, including periods of start-up, shutdown, and 

malfunction. 

D.8.6 Operating Requirements for Coil Coating Lines CCL2 and CCL3 [326 

IAC 12] [326 IAC 20-64] 

[40 CFR Part 63.5121] [40 CFR 60.463] 

The Permittee shall establish the operating limits during the performance 

test according to the 

requirements in 40 CFR 63.5160(d)(3).The Permittee shall meet the 

operating limits at all times after 

the operating limits are established except during periods of start-up, 

shutdown, and malfunction of 

any capture system and control device used to comply with the emission 

limits in Condition D.8.5. 

The Permittee must meet the applicable operating limits as described 

below: 

(a) The Permittee shall not allow the average combustion temperature of 

the thermal oxidizer in 

any 3 – hour period to fall below the combustion temperature limit 

established according to 

40 CFR 63.5160(d)(3)(i). The Permittee shall demonstrate continuous 

compliance with the 

operating limit by; 

(1) collecting the combustion temperature data according to 40 CFR 

63.5150(a)(3); 

(2) reducing the data to 3 – hour block averages; and 

(3) maintaining the 3 – hour average combustion temperature at or above 

the 

temperature limit. 

(b) The Permittee shall develop a monitoring plan for the capture system 

that identifies the 

operating parameter to be monitored and specifies the operating limits 

according to 

40 CFR 63.5150(a)(4) and conduct monitoring according to 40 CFR 

63.5150(a)(4). 

D.8.7 General Provisions Relating to Hazardous Air Pollutants [326 IAC 

20-1] [40 CFR Part 63, Subpart A] 

The provisions of 40 CFR Part 63, Subpart A- General Provisions, which 

are incorporated by 
reference as 326 IAC 20-1-1, apply to the affected source, except when 

otherwise specified by Table 

12 to 40 CFR Part 63, Subpart EEEE. 

D.8.8 National Emission Standards for Hazardous Air Pollutants: Organic 

Liquids Distribution, 

Non-Gasoline [326 IAC 20-83] [40 CFR Part 63, Subpart EEEE] 

The Permittee which engages in the organic liquid coating of aluminum 

coils shall comply with the 

following provisions of 40 CFR Part 63, Subpart EEEE (included as 

Attachment A of this permit), with 

a compliance date of February 5, 2007: 

(1) 40 CFR 63.2343(a), 

(2) 40 CFR 63.2343(b)(1)(i), 

(3) 40 CFR 63.2343(b)(ii)(B), 

(4) 40 CFR 63.2343(b)(iii), 

(5) 40 CFR 63.2343(b)(2)(i), 

(6) 40 CFR 63.2343(b)(3), and 

(7) 40 CFR 63.2343(d). 

D.8.9 Organic Liquid Distribution Operations – Affected Sources [326 IAC 

20-83] [40 CFR 63.2338] 

The following emissions units comprise the affected source that is 

subject to 40 CFR 63, 

Subpart EEEE: 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 158 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

(a) Two (2) fixed roof above ground tanks, identified as tanks, 01 and 

02; 

(b) Six (6) fixed roof above ground tanks, identified as tanks, 03, 04, 

05, 06, 07, and 08; 

(c) Four (4) fixed roof above ground tanks, identified as tanks, B, C, D, 

and E; 

(d) One (1) underground storage tank, identified as Hazardous Waste 

Storage Tank; 

(e) One (1) fixed roof above ground tanks, identified as gold electrocoat 

coating Dump Tank; and 

(f) One (1) fixed roof above ground tank, identified as gold electrocoat 

coating Unload Tank. 

Compliance Determination Requirements 

D.8.10 Compliance Determination Requirements 

Compliance with the PSD Emission Limit in Condition D.8.3 shall be 

determined by combining the 

weekly samples and analyzing the composite of the weekly samples once per 

month. 

D.8.11 Compliance Demonstration Requirements [326 IAC 12] [326 IAC 20-64] 

[40 CFR63.5170] 

[40 CFR 60.463] [326 IAC 8-2-4] 

The Permittee shall include all coating materials (as defined in 40 CFR 

63.5110) used in the coating 

lines when determining compliance with the applicable emission limit in 

Condition D.8.5. 

Table - Compliance Demonstration Requirements Index 

Coil Coating Lines If the Permittee chooses to 

demonstrate compliance by: 

Then the Permittee shall 

demonstrate that: 

Coating Lines CCL2, 

CCL3, and CPL6, in 

combination. 

Use of a combination of ―as 

applied‖ coatings and control 

devices and maintaining an 

acceptable equivalent emission 

rate. 

Average equivalent emission rate 

does not exceed 0.046 kg HAP 

per liter solids on a rolling 

12-month average as applied 

basis, determined monthly. 

[D.8.5(a)(1)]. 

Streamlined Compliance Demonstration for Combination of Coil Coating 

Lines CCL2, CCL3, and 

CPL 6 

(a) Capture and control to achieve the emission rate limit [40 CFR 

63.5170(g)] - Since the 
Permittee uses two capture systems, two thermal oxidizers, operate one 

never controlled 

coating line and limits the organic HAP emission rate to no more than 

0.046 kg organic HAP 

emitted per liter of solids applied on a 12-month average as-applied 

basis, the Permittee 

must demonstrate compliance according to the procedures in paragraphs 

(a), (b), (c), (d), (e), 

(f), and (g) of this condition. 

(b) The Permittee shall use the following procedures to determine the 

organic HAP emissions 

from coating lines CCL2 and CCL3: 

(1) For each thermal oxidizer, each month of the 12-month compliance 

period, the 

Permittee shall: 

(i) Monitor combustion temperature of the thermal oxidizers to ensure 

that the 

thermal oxidizers's destruction efficiencies are maintained 

[40 CFR 63.5170(g)(3)(i)]; 
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Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

(ii) Monitor fan motor current (amperes) for each fan specified in the 

capture 

monitoring plan as established in 40 CFR 63.5150(a)(4) to ensure capture 

efficiency [40 CFR 63.5170(g)(3)(ii)]; and 

(iii) Determine the organic HAP emissions for coating lines CCL2 and CCL3 

in 

accordance with the following [40 CFR 63.5170(g)(3)(iii)]: 

(A) For each oxidizer, determine the oxidizer destruction efficiency, 

DRE, using the procedure in 40 CFR 63.5160(d) 

[40 CFR 63.5170(f)(1)(i)]; 

(B) Whenever a work station is operated, continuously monitor the 

combustion temperature in accordance with 40 CFR 63.5150(a)(3) 

[40 CFR 63.5170(f)(1)(ii)]; 

(C) Determine the capture system capture efficiency, CE, for each 

coating line in accordance with 40 CFR 63.5160(e) 

[40 CFR 63.5170(f)(1)(iii)]; 

(D) Whenever a coating line is operated, continuously monitor the fan 

motor current (amperes) established in accordance with 

40 CFR 63.5150(a)(4) [40 CFR 63.5170(f)(1)(iv)]; 

(E) Calculate the overall organic HAP control efficiency, R, achieved 

using equation (7) [40 CFR 63.5170(f)(1)(v)]; and 

. . 

. . 

. . . 

. . 

. . . 

. 

. . 

.

. 

. . 

.

.

. . . 

.

. 

. . . 

.

. 

. . 

. . 

q

j 1 

vi j 

p

i 1 

i 

W

A 1 

q
j 1 

vi Aj 

p

i 1 

k A Ai

MC M 

DRE CE M C M 

R 100 (Eq. 7) 

Where: 

R = overall organic HAP control efficiency, percent; 

DREk = organic volatile matter destruction efficiency of the 

thermal oxidizer, k, percent; 

CEA = organic volatile matter capture efficiency of the 

capture system for work station, A, percent; 

MAi = mass of coating material, i, applied on work station, 

A, in a month, kg; 

Cvi = volatile matter content of coating material, i, 

expressed as a weight fraction, kg/kg; 

MAj = mass of solvent, thinner, reducer, diluent, or other 

non-solids-containing coating material (including 

H2O), j, applied on work station, A, in a month, kg; 

Mi = mass of coating material, i, applied in a month, kg; 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

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Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

Mj = mass of solvent, thinner, reducer, diluent, or other 

non-solids-containing coating material (excluding 

H2O), j, applied in a month, kg; 

w = number of always-controlled work stations in the 

facility; 

p = number of different coating materials applied in a 

month; and 

q = number of different solvents, thinners, reducers, 

diluents, or other non-solids-containing coating 

materials applied in a month. 

(F) Calculate the organic HAP emitted during the month, He, for each 

month for coating lines CCL2 and CCL3 using equation (8) 

[40 CFR 63.5170(f)(1)(ix)]. 

. . . . . 

. . . . . . .

. 

. . . 

.

. 

. . . 

.

. 

. . . 

.

. 

. . . 

.

. 

. . . 

.

. 

. . . . 

w

A 1 

p

i 1 

q

j 1 

He 1 DREk CEA ChiMAi ChijMAij Eq. (8) 

Where: 

He = total monthly organic HAP emitted, kg; 

DREk = organic volatile matter destruction efficiency of 

control device, k, percent; 

CEA = organic volatile matter capture efficiency of the 

capture system for work station, A, percent; 

Chi = organic HAP content of coating material, i, 

expressed as a weight-fraction, kg/kg; 

MAi = mass of coating material, i, applied on work station, 

A, in a month, kg; 

Chij = organic HAP content of solvent, j, added to coating 
material, i, expressed as a weight fraction, kg/kg; 

MAij = mass of solvent, thinner, reducer, diluent, or other 

non-solids-containing coating material, j, added to 

solids-containing coating material, i, applied on work 

station, A, in a month, kg; 

w = number of always-controlled work stations in the 

facility; 

p = number of different coating materials applied in a 

month; and 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

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Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

q = number of different solvents, thinners, reducers, 

diluents, or other non-solids-containing coating 

materials applied in a month. 

For periods when the thermal oxidizer has not operated within its 

established operating limit, the control device efficiency is 

determined to be zero. 

(c) The Permittee shall use the following procedures for coating line 

CPL6 [40 CFR 63.5170 

(g)(5)]: 

(1) Each month of the 12-month compliance period the Permittee must 

determine the 

organic HAP applied on coating line CPL6 using equation 9. The organic 

HAP 

emitted from coating line CPL6 is equal to the organic HAP applied on 

coating line 

CPL6: 

. . . 

. . . . . . 

.

. 

. . . 

.

. 

. . 

x 

A 1 

Aij 

q

j 1 

Ai hij 

p

i 1 

Hm Chi M C MA Eq. (9) 

Where: 

Hm = total monthly organic HAP applied on coating line CPL6, kg; 

Chi = organic HAP content of coating material, i, expressed as a 

weight-fraction, kg/kg; 

MAi = mass of coating material, i, applied on coating line CPL6, A, in a 

month, kg; 

Chij = organic HAP content of solvent, j, added to coating material, i, 

expressed as a weight fraction, kg/kg; 

MAij = mass of solvent, thinner, reducer, diluent, or other 

non-solids-containing coating material, j, added to solids-containing 

coating material, i, applied on coating line CPL6, A, in a month, kg; 

x = number of uncontrolled coating line = 1; 

p = number of different coating materials applied in a month; and 

q = number of different solvents, thinners, reducers, diluents, or other 

non-solids-containing coating materials applied in a month. 

(d) In each month of the 12-month compliance period, the Permittee shall 

determine the solids 
content of each coating material applied during the month following the 

procedure in 

40 CFR 63.5160(c) [40 CFR 63.5170(g)(6)]. 

(e) The Permittee shall determine the organic HAP emissions for all coil 

coating lines for each 

12-month compliance period by summing all monthly organic HAP emissions 

[40 CFR 63.5170(g)(7)]. 

(f) Organic HAP emission rate based on solids applied for the 12-month 

compliance period, 

LANNUAL. Calculate the organic HAP emission rate based on solids applied 

for the 12-month 

compliance period, LANNUAL, using Equation 6 of this section [40 CFR 

63.5170(f)(1)(x): 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 162 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

. .

. 

. .

. 

. . 

.

. 

. . 

.

. 

. 

12 

y 1 

p

i 1 

si i 

12

y 1 

e 

ANNUAL 

C M 

H 

L Eq. (6) 

Where: 

LANNUAL = mass organic HAP emitted per volume of solids applied for the 

12-month 

compliance period, kg/liter; 

He = total monthly organic HAP emitted, kg; 

Csi = solids content of coating material, i, expressed as liter of 

solids/kg of 

material; 

Mi = mass of coating material, i, applied in a month, kg; 

y = identifier for months; and 

p = number of different coating materials applied in a month. 

(g) Compare actual performance to performance required - The coating 

lines CCL2, CCL3, and 

CPL6 are in compliance with condition D.8.5(a) for the 12-month 

compliance period if all the 

operating parameters required to be monitored under paragraph (b)(1) of 

this condition were 

maintained at the values established in 40 CFR 63.5150; and the total 

mass of organic HAP 

emitted by the coating lines was not more than 0.046 kg HAP per liter of 

solids applied for the 

12-month compliance period [40 CFR 63.5170(g)(8)]. 

Coil Coating Line CPL6 (40 CFR 60, Subpart TT) 

(h) Calculate the volume-weighted average of the total mass of VOC’s per 

unit volume of coating 

solids applied (G) during each calendar month for coil coating line CPL6 

as follows: 
(1) Calculate the volume-weighted average of the total mass of VOC’s 

consumed per 

unit volume of coating solids applied (G) during each calendar month, 

except as 

provided under paragraph 40 CFR 60.463(c)(1)(iv) as follows: 

(i) Calculate the mass of VOC’s used (Mo+Md) during each calendar month 

by 

the following equation: 

dj 

m

j 1 

ci oi dj 

n

i 1 

Mo Md .LciD W .L D 

. . 

. . . 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 163 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

Where: 

Mo = Mass of VOC’s in coatings consumed, as received in kilogram 

(kg) based on either formulation data supplied by the 

manufacturer, or by an analysis of each coating as specified 

by EPA Method 24; 

Md = Mass of VOC-solvent added to the coatings, in kg; 

Lc = the volume of each coating consumed, as received in liters; 

Ld = the volume of each VOC-solvent added to the coatings in liters 

(l) 

Wo = the proportion of VOC’s in each coating, as received (fraction 

by weight); 

Dd = density of each VOC-solvent added to the coatings (kg/l); 

. Ldj Ddj = will be 0 if no VOC solvent is added to the coatings, as 

received; 

n = the number of different coatings used during calendar month, 

and 

m = the number of different VOC solvents added to coatings used 

during the calendar month. 

(ii) Calculate the total volume of coating solids used (Ls) in each 

calendar 

month by the following equation: 

ci 

n 

i 1 

si s L V L .. 

. 

Where: 

Vs = the proportion of solids in each coating, as received (fraction by 

volume); 

Lc = the volume of each coating consumed, as received in liters; 

Ls = total volume of solids used in a calendar month; and 

n = the number of different coatings used during the calendar month. 

(iii) Calculate the volume-weighted average mass of VOCs used per unit 

volume 

of coating solids applied (G) during the calendar month by the following 

equation: 

s 

o d 

L 

M M 

G 

. 

. 

(2) If the volume-weighted average mass of VOC’s emissions, adjusted for 

the amount 

of as-supplied VOC removed in the wastewater and other available material 

balance 

data for each calendar month (G) is less than or equal to 0.28 kg/l of 

coating solids 
applied, then the coil coating line CPL6 is in compliance with the 

standard. Each 

monthly calculation is a performance test. 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 164 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

(3) If each individual coating used in coil coating line CPL6 has a VOC 

content, as 

received, that is equal to or less than 0.28 kg/l of coating solids, coil 

coating line 

CPL6 is in compliance provided no VOCs are added to the coatings during 

distribution or application. 

D.8.12 Testing Requirements [326 IAC 2-7-6(1), (6)] [326 IAC 2-1.1-11] 

[326 IAC 12] [326 IAC 20-1] 

[40 CFR 63, Subpart A] [326 IAC 20-64] [40 CFR 5160] [40 CFR 60.463] 

(a) Organic HAP content and solids volume – The Permittee shall determine 

the organic HAP 

weight fraction of each coating material applied by following one of the 

procedures in 

paragraphs (a)(1) through (2) of this condition: 

(1) Method 311 - The Permittee shall test the material in accordance with 

Method 311 of 

40 CFR 63, appendix A. The Method 311 determination may be performed by 

the 

manufacturer of the material and the results provided to the Permittee. 

The organic 

HAP content must be calculated according to the criteria and procedures 

in 

paragraphs (a)(1)(i) through (iii) of this condition: 

(i) Count only those organic HAP that are measured to be present at 

greater 

than or equal to 0.1 weight percent for Occupational Safety and Health 

Administration (OSHA)-defined carcinogens as specified in 29 CFR 

1910.1200(d)(4) and greater than or equal to 1.0 weight percent for other 

organic HAP compounds; 

(ii) Express the weight fraction of each organic HAP you count according 

to 

paragraph (b)(1)(i) of this condition as a value truncated to four places 

after 

the decimal point (for example, 0.3791); and 

(iii) Calculate the total weight fraction of organic HAP in the tested 

material by 

summing the counted individual organic HAP weight fractions and 

truncating 

the result to three places after the decimal point (for example, 0.763). 

(2) Formulation data - The Permittee may use the formulation data 

provided that the 

information represents each organic HAP present at a level equal to or 

greater than 

0.1 percent for OSHA-defined carcinogens as specified in 29 CFR 

1910.1200(d)(4) 

and equal to or greater than 1.0 percent for other organic HAP compounds 

in any 

raw material used, weighted by the mass fraction of each raw material 

used in the 
material. Formulation data may be provided to the Permittee by the 

manufacturer of 

the coating material. In the event of any inconsistency between test data 

obtained 

with the test methods specified in paragraphs (a)(1) through (2) of this 

condition and 

formulation data, the test data will govern. 

(b) Solids content - The Permittee must determine the solids content of 

each coating material 

applied. The Permittee may determine the volume solids content using ASTM 

D2697–86 

(Reapproved 1998) or ASTM D6093–97 (incorporated by reference, see 

§63.14), or an EPA 

approved alternative method. The ASTM D2697–86 (Reapproved 1998) or ASTM 

D6093–97 

determination may be performed by the manufacturer of the material and 

the results provided 

to the Permittee. Alternatively, the Permittee may rely on formulation 

data provided by 

material providers to determine the volume solids. 

(c) Within 5 years from the date of last compliance stack test or one 

hundred and eighty (180) 

days after issuance of this permit, whichever is later, the Permittee 

must conduct a 

performance test to establish the overall VOC removal efficiency across 

coating lines CCL2 

and CCL3, according to the methods and procedures in 40 CFR 63.5160(d)(2) 

and (3)(iii). 

During the performance test, the Permittee must establish the combustion 

temperature of 

each thermal oxidizer, required by 40 CFR 63.5121, according to the 

methods and 

procedures in 40 CFR 63.5160(d)(3). This test shall be repeated at least 

once every five 

years from the date of the most recent valid compliance demonstration. 

Testing shall be 

conducted in accordance with Section C - Performance Testing. 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 165 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

The Permittee shall use the data collected during the performance test to 

calculate and 

record the average combustion temperature maintained during the 

performance test for each 

thermal oxidizer. The average combustion temperature determined is the 

minimum operating 

limit for the thermal oxidizer. 

(d) Within 5 years from the date of last compliance test or one hundred 

and eighty (180) days 

after issuance of this permit, whichever is later, the Permittee must 

conduct a performance 

test to establish the capture efficiency of each capture system, 

according to the methods and 

procedures in 40 CFR 63.5160(e)(2) and (3). During the performance test, 

the Permittee 

must establish the fan motor current (ampere) for each fan for each 

capture system, required 

by 40 CFR 63.5121, according to the methods and procedures in 40 CFR 

63.5160(d)(3). This 

test shall be repeated at least once every five years from the date of 

the most recent valid 

compliance demonstration. Testing shall be conducted in accordance with 

Section C -

Performance Testing. 

The Permittee shall use the data collected during the performance test to 

calculate and 

record the average value of the fan motor current (ampere) maintained 

during the 

performance test for each fan for each capture system. The average ampere 

values 

determined for the fans of each capture system are the minimum operating 

limits for the 

coater to oven fan and the maximum operating limits for the floor sweeps 

fan. A fan amps 

range can be specified in the capture monitoring plan if a demonstration 

is included in the 

test report demonstrating the impact of the requested range on VOC 

emissions capture and 

removal efficiency. 

Compliance Monitoring Requirements [326 IAC 2-7-6 (1)] [326 IAC 2-7-5 

(1)] [326 IAC 12] [326 IAC 20-1] 

[40 CFR 63, Subpart A] [326 IAC 20-64] [40 CFR 63.5150] [40 CFR 60.464] 

D.8.13 Thermal Oxidizer and Capture System Operating Parameters 

Monitoring 

(a) The Permittee shall calibrate, maintain, and operate temperature 

monitoring equipment 

according to the manufacturer's specifications. Each temperature

monitoring device shall be 

equipped with a continuous recorder. The device shall have an accuracy of 

0.75 percent of 
the temperature being monitored in degrees Celsius, or 1 deg. Celsius, 

whichever is greater. 

[40 CFR 63.5150(a)(3)(i)] [40 CFR 60.464(c)] 

(b) The Permittee shall collect the combustion temperature data according 

to 

40 CFR 3.5150(a)(3); reduce the data to 3-hour block averages; and 

maintain the 3-hour 

average combustion temperature at or above the temperature limit. 

(c) The records required by 40 CFR 60.7 shall identify each such 

occurrence and its duration. 

(d) The Permittee shall develop a capture system monitoring plan 

containing the information 

specified in 40 CFR 63.5150(a)(4)(i) and (ii). The Permittee shall 

monitor the capture system 

in accordance with 40 CFR 63.5150 (a)(4)(iii). The monitoring plan shall 

be available for 

inspection by IDEM, OAQ upon request. 

(1) The monitoring plan shall identify the operating parameter to be 

monitored to ensure 

that the capture efficiency measured during the initial compliance test 

is maintained, 

explain why this parameter is appropriate for demonstrating ongoing 

compliance, and 

identify the specific monitoring procedures. 

(2) The plan also must specify operating limits at the capture system 

operating 

parameter value, or range of values, that demonstrates compliance with 

the 

standards in Condition D.8.5. The operating limits must represent the 

conditions 

indicative of proper operation and maintenance of the capture system. 

(e) The Permittee has selected to monitor the fan motor current as a 

capture system operating 

parameter in the current capture system monitoring plan. The Permittee 

shall conduct 

monitoring in accordance with the plan, submitted to IDEM, OAQ. 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 166 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

(f) Any deviation from the required operating parameters, which are 

monitored in accordance 

with 40 CFR 63.5150 (a)(3) and (4), unless otherwise excused, will be 

considered a deviation 

from the operating limit. 

Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-

7-19] [326 IAC 12] 

[326 IAC 20-1] [40 CFR 63, Subpart A] [326 IAC 20-64] [326 IAC 20-83] [40 

CFR 60.465] 

[40 CFR 63.5180] [40 CFR 63.5190] 

D.8.14 Record Keeping Requirements 

(a) To document compliance with Conditions D.8.2, the Permittee shall 

maintain records as 

stated below and shall be complete and sufficient to establish compliance 

with the VOC 

usage limit established in Condition D.8.2 for coil coating lines CCL2 

and CCL3. 

The VOC content of each coating material and solvent used less water. 

Records shall 

include recorded VOC and HAP application rates and material safety data 

sheets (MSDS) 

necessary to verify the type and amount used. 

(b) To document compliance with Conditions D.8.3, the Permittee shall 

maintain records as 

stated below and shall be complete and sufficient to establish compliance 

with the VOC 

usage limit established in condition D.8.3 for electro coat coil coating 

line CPL6. 

The VOC content of each coating material and solvent used less water. 

Records shall 

include recorded VOC and HAP application rates and material safety data 

sheets (MSDS) 

necessary to verify the type and amount used. 

(c) To document compliance with condition D.8.5, the Permittee shall 

maintain the records in 

accordance with 40 CFR 63.10(b)(1): 

(1) Records specified in 40 CFR 63.10(b)(2) of all measurements needed to 

demonstrate compliance, including: 

(i) Average combustion temperature and average fan motor current (ampere) 

data in accordance with 40 CFR 63.5150(a)(3), and (4), respectively; 

(ii) Organic HAP content data for the purpose of demonstrating compliance 

in 

accordance with 40 CFR 63.5160(b); 

(iii) Solids content data for the purpose of demonstrating compliance in 

accordance with 40 CFR 63.5160(c); 

(iv) Overall control efficiency determination in accordance with 

40 CFR 63.5160(d) and (e), and 

(v) Material usage, HAP usage, volatile matter usage, and solids usage 

and 

compliance demonstrations using these data in accordance with 
40 CFR 63.5170(g). 

(2) Records specified in 40 CFR 63.10(b)(3). 

(d) To document compliance with Conditions D.8.2, D.8.3, and D.8.5, the 

Permittee shall 

maintain records of all data and calculations used to determine the 

emission rates specified 

therein. 

(e) All records shall be maintained in accordance with Section C -

General Record Keeping 

Requirements, of this permit. 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 167 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

D.8.15 Reporting Requirements [326 IAC 2-2] [326 IAC 20-1] [40 CFR 63, 

Subpart A] [326 IAC 12] 

[326 IAC 20-64] [40 CFR 63.5180] [40 CFR 60, Subpart TT] 

(a) The Permittee shall submit the reports specified in paragraphs (a) 

(1) through (3) of this 

condition to the U.S. EPA Regional Office 5 and to IDEM, OAQ: 

(1) Start-up, shutdown, and malfunction reports as specified in 40 CFR 

63.10(d)(5) for 

coating lines CCL2 and CCL3. Separate start-up, shutdown, or malfunction 

reports 

are not required if the information is included in the report specified 

in the following 

paragraph (5) of this condition. 

(2) Semi-annual compliance reports containing the information specified 

in 

40 CFR 63.5180(g)(i) and (ii). 

(3) For each deviation occurring at a coil coating line, the semi-annual 

compliance report 

containing the information in paragraphs 40 CFR 63.5180(g)(2)(i) through 

(iv) and 

the information in 40 CFR 63.5180 (h)(1) through (3). 

(b) The Permittee shall submit the reports specified in paragraphs (b) 

(1) through (4) of this 

condition to IDEM, OAQ: 

(1) Performance test reports as specified in 40 CFR 63.10(d)(2). 

(2) Identify, record and submit a written report every calendar quarter 

of each instance in 

which the volume weighted average of the total mass of the VOCs emitted 

per 

volume of applied coating solids from coil coating line CPL6 is greater 

than the limit 

specified under 40 CFR 60.462. If no such instances have occurred during 

a 

particular quarter, a report stating this shall be submitted 

semiannually. 

(3) A monthly summary of the information to document compliance with 

condition D.8.2, 

for coil coating lines CCL2 and CCL3 shall be submitted to the addresses 

listed in 

Section C - General Reporting Requirements, of this permit, using the 

reporting 

forms located at the end of this permit, or their equivalent, within 

thirty (30) days after 

the end of the quarter being reported. 

(4) A monthly summary of the information to document compliance with 

condition D.8.3 

and D.8.10 for coil coating line CPL6 shall be submitted to the addresses 

listed in 

Section C - General Reporting Requirements, of this permit, using the 

reporting form 
located at the end of this permit, or its equivalent, within thirty (30) 

days after the end 

of the quarter being reported. 

(c) These reports shall be submitted to the addresses listed in Section C 

- General Reporting 

Requirements, of this permit. The reports submitted by the Permittee 

require the certification 

by the ―responsible official‖ as defined by 326 IAC 2-7-1(34). 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 168 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

SECTION D.9 FACILITY OPERATION CONDITIONS 

Facility Description [326 IAC 2-7-5(15)] 

(i) One (1) portable BL Pergson 428 fixed hammer impactor (Brick 

Crusher), with a capacity of 

100 tons per hour, with a 20 to 1 reduction ratio, with a 3306 

caterpillar diesel engine, with a 

capacity of 300 hp and using a four (4) wet suppression for control of 

particulate matters (four 

sprays, two on the conveyor and two on the impactor). 

(The information describing the process contained in this facility 

description box is descriptive information and 

does not constitute enforceable conditions.) 

Emission Limitations and Standards [326 IAC 2-7-5(1)] 

D.9.1 PSD Minor Limits and Part 70 Minor Source Modification [326 IAC 2-

2] [326 IAC 2-7-10.5] 

Pursuant to 326 IAC 2-7-10.5(d)(4)(B): 

(a) The total hours of operation for the diesel engine shall be less than 

720 hours per twelve 

(12) consecutive month period, with compliance determined at the end of 

each month. 

(b) The NOx emissions shall not exceed 9.3 pounds per hour. 

Compliance with the above limits will limit the diesel engine NOx 

emissions to less than 25 tons per 

year and render the requirements of 326 IAC 2-2 (PSD) and 326 IAC 2-7-

10.5 (Minor Source Limit) 

not applicable to this emission unit. 

D.9.2 Particulate Emissions Limitations for Manufacturing Processes [326 

IAC 6-3-2] 

Pursuant to 326 IAC 6-3-2, the allowable particulate matter (PM) from the 

fixed hammer impactor 

(brick crusher) shall not exceed 51.28 pounds per hour when operating at 

a process weight rate of 

100 tons per hour. The pound per hour limitation was calculated with the 

following equation: 

Interpolation and extrapolation of the data for the process weight rate 

in excess of sixty thousand 

(60,000) pounds per hour shall be accomplished by use of the equation: 

E = 55.0 P 0.11 – 40 

Where: 

E = rate of emission in pounds per hour; and 

P = process weight rate in tons per hour 

D.9.3 Preventive Maintenance Plan [326 IAC 2-7-5(13)] 

A Preventative Maintenance Plan, in accordance with Section B -

Preventive Maintenance 

Plan of this permit, is required for these facilities and their control 

devices. 

Compliance Determination Requirements 

D.9.4 Particulate Matter (PM) 

In order to comply with Condition D.9.2, all four (4) wet suppressions 

shall be in operation at all times 
when the four sprays are in operation. 

Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-

7-19] 

D.9.5 Record Keeping Requirements 

(a) To document compliance with Condition D.9.1, the Permittee shall 

maintain monthly records 

of hours of operation of the Diesel engine. 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 169 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

(b) All records shall be maintained in accordance with Section C -

General Record 

Keeping Requirements of this permit. 

D.9.6 Reporting Requirements 

(a) A quarterly summary of the information to document compliance with 

Conditions D.9.1 shall 

be submitted to the addresses listed in Section C - General Reporting 

Requirements, of this 

permit, using the reporting form located at the end of this permit, or 

its equivalent, within thirty 

(30) days after the end of the quarter being reported. The reports 

submitted by the Permittee 

does require the certification by the ―responsible official‖ as defined 

by 326 IAC 2-7-1(34). 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 170 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION 

VOC Usage Quarterly Report 

Source Name: Alcoa Inc. - Warrick Operations 

Source Address: Jct. IN Hwys. 66 & 61, Newburgh, Indiana 47629-0010 

Mailing Address: Bldg. 860 E, P.O. Box 10, Newburgh, Indiana 47629 

Part 70 Permit No.: T173-6627-0 0007 

Facility: Coil Coating line CCL2 

Parameter: VOC Usage 

Limit: 7,675 tons/365-days of VOC input 

Quarter:___________ Month:______________ Year:________ 

Day This Day 

(Tons) 

Previous 364 

Days 

(Tons) 

365 Days 

Total 

(Tons) 

Day This Day 

(Tons) 

Previous 

364 Days 

(Tons) 

365 Days 

Total 

(Tons) 

1 17 

2 18 

3 19 

4 20 

5 21 

6 22 

7 23 

8 24 

9 25 

10 26 

11 27 

12 28 

13 29 

14 30 

15 31 

16 

. No deviation occurred in this month. 

. Deviation/s occurred in this month. 

Deviation has been reported on: 

Submitted by: 

Title/Position: 

Signature: 
Date: 

Phone: 

Attach a signed certification to complete this report. 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 171 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION 

VOC Usage Quarterly Report 

Source Name: Alcoa Inc. - Warrick Operations 

Source Address: Jct. IN Hwys. 66 & 61, Newburgh, Indiana 47629-0010 

Mailing Address: Bldg. 860 E, P.O. Box 10, Newburgh, Indiana 47629 

Part 70 Permit No.: T173-6627-00007 

Facility: Coil Coating line CCL3 

Parameter: VOC Usage 

Limit: 112 tons/365-days 

Quarter:___________ Month:______________ Year:________ 

Day This Day 

(Tons) 

Previous 364 

Days 

(Tons) 

365 Days 

Total 

(Tons) 

Day This Day 

(Tons) 

Previous 

364 Days 

(Tons) 

365 Days 

Total 

(Tons) 

1 17 

2 18 

3 19 

4 20 

5 21 

6 22 

7 23 

8 24 

9 25 

10 26 

11 27 

12 28 

13 29 

14 30 

15 31 

16 

. No deviation occurred in this month. 

. Deviation/s occurred in this month. 

Deviation has been reported on: 

Submitted by: 

Title/Position: 

Signature: 
Date: 

Phone: 

Attach a signed certification to complete this report. 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 172 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION 

VOC Usage Quarterly Report 

Source Name: Alcoa, Inc. - Warrick Operations 

Source Address: Jct. IN Hwys. 66 & 61, Newburgh, Indiana 47629-0010 

Mailing Address: Bldg. 860 E, P.O. Box 10, Newburgh, Indiana 47629 

Operation Permit No.: T173-6627-00007 

Facility: Electro Coat Coating Line CPL6 

Parameter: VOC Usage 

Limit: 404 tons per twelve (12) consecutive month period 

Quarter: Year: ________ 

Month 

This Month 

(tons) 

Previous 11 Months 

(tons) 

12 Month Total 

(tons) 

. No deviation occurred in this month. 

. Deviation/s occurred in this month. 

Deviation has been reported on: 

Submitted by: 

Title/Position: 

Signature: 

Date: 

Phone: 

Attach a signed certification to complete this report. 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 173 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION 

Quarterly Report 

Source Name: Alcoa, Inc. - Warrick Operations 

Source Address: Jct. IN Hwys. 66 & 61, Newburgh, Indiana 47629-0010 

Mailing Address: Bldg. 860 E, P.O. Box 10, Newburgh, Indiana 47629 

Operation Permit No.: T173-6627-00007 

Facility: Diesel Engine 

Parameter: NOx Emissions 

Limit: less than 720 hours of operation per twelve (12) consecutive month 

period 

Quarter: Year: ________ 

Month 

This Month 

(hours) 

Previous 11 Months 

(hours) 

12 Month Total 

(hours) 

. No deviation occurred in this month. 

. Deviation/s occurred in this month. 

Deviation has been reported on: 

Submitted by: 

Title/Position: 

Signature: 

Date: 

Phone: 

Attach a signed certification to complete this report. 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 174 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

PART 70 OPERATING PERMIT 

CERTIFICATION 

Source Name: Alcoa, Inc. - Warrick Operations 

Source Address: Jct. IN Hwys. 66 & 61, Newburgh, Indiana 47629-0010 

Mailing Address: Bldg. 860 E, P.O. Box 10, Newburgh, Indiana 47629 

Operation Permit No.: T173-6627-00007 

This certification shall be included when submitting monitoring, testing 

reports/results 

or other documents as required by this permit. 

Please check what document is being certified: 

Annual Compliance Certification Letter 

Test Result (specify) 

Report (specify) 

Notification (specify) 

Affidavit (specify) 

Other (specify) 

I certify that, based on information and belief formed after reasonable 

inquiry, the statements and 

information in the document are true, accurate, and complete. 

Signature: 

Printed Name: 

Title/Position: 

Phone: 

Date: 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 175 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE BRANCH

100 North Senate Avenue 

MC 61-53 IGCN 1003 

Indianapolis, Indiana 46204-2251 

Phone: 317-233-0178 

Fax: 317-233-6865 

PART 70 OPERATING PERMIT 

EMERGENCY OCCURRENCE REPORT 

Source Name: Alcoa, Inc. - Warrick Operations 

Source Address: Jct. IN Hwys. 66 & 61, Newburgh, Indiana 47629-0010 

Mailing Address: Bldg. 860 E, P.O. Box 10, Newburgh, Indiana 47629 

Operation Permit No.: T173-6627-00007 

This form consists of 2 pages Page 1 of 2 

This is an emergency as defined in 326 IAC 2-7-1(12) 

. The Permittee must notify the Office of Air Quality (OAQ), within four 

(4) business hours 

(1-800-451-6027 or 317-233-0178, ask for Compliance Section); and 

. The Permittee must submit notice in writing or by facsimile within two 

(2) working days 

(Facsimile Number: 317-233-6865), and follow the other requirements of 

326 IAC 2-7-16. 

If any of the following are not applicable, mark N/A 

Facility/Equipment/Operation: 

Control Equipment: 

Permit Condition or Operation Limitation in Permit: 

Description of the Emergency: 

Describe the cause of the Emergency: 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 176 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

If any of the following are not applicable, mark N/A Page 2 of 2 

Date/Time Emergency started: 

Date/Time Emergency was corrected: 

Was the facility being properly operated at the time of the emergency? Y 

N 

Describe: 

Type of Pollutants Emitted: TSP, PM-10, SO2, VOC, NOX, CO, Pb, other: 

Estimated amount of pollutant(s) emitted during emergency: 

Describe the steps taken to mitigate the problem: 

Describe the corrective actions/response steps taken: 

Describe the measures taken to minimize emissions: 

If applicable, describe the reasons why continued operation of the 

facilities are necessary to prevent 

imminent injury to persons, severe damage to equipment, substantial loss 

of capital investment, or loss 

of product or raw materials of substantial economic value: 

Form Completed by: 

Title / Position: 

Date: 

Phone: 

A certification is not required for this report. 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 177 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION 

PART 70 OPERATING PERMIT 

QUARTERLY DEVIATION AND COMPLIANCE MONITORING REPORT 

Source Name: Alcoa, Inc. - Warrick Operations 

Source Address: Jct. IN Hwys. 66 & 61, Newburgh, Indiana 47629-0010 

Mailing Address: Bldg. 860 E, P.O. Box 10, Newburgh, Indiana 47629 

Operation Permit No.: T173-6627-00007 

Months: to Year: 

Page 1 of 2 

This report shall be submitted quarterly based on a calendar year. Any 

deviation from the 

requirements, the date(s) of each deviation, the probable cause of the 

deviation, and the response 

steps taken must be reported. A deviation required to be reported 

pursuant to an applicable 

requirement that exists independent of the permit, shall be reported 

according to the schedule stated 

in the applicable requirement and does not need to be included in this 

report. Additional pages may

be attached if necessary. If no deviations occurred, please specify in 

the box marked "No deviations 

occurred this reporting period". 

NO DEVIATIONS OCCURRED THIS REPORTING PERIOD. 

THE FOLLOWING DEVIATIONS OCCURRED THIS REPORTING PERIOD 

Permit Requirement (specify permit condition #) 

Date of Deviation: 

Duration of Deviation: 

Number of Deviations: 

Probable Cause of Deviation: 

Response Steps Taken: 

Permit Requirement (specify permit condition #) 

Date of Deviation: 

Duration of Deviation: 

Number of Deviations: 

Probable Cause of Deviation: 

Response Steps Taken: 
Alcoa, Inc. – Warrick Operations Significant Permit Modification No.: 

173-29035-00007 Page 178 of 178 

Newburgh, Indiana Modified by: Jillian Bertram T 173-6627-00007 

Permit Reviewer: Dr. Trip Sinha 

Page 2 of 2 

Permit Requirement (specify permit condition #) 

Date of Deviation: 

Duration of Deviation: 

Number of Deviations: 

Probable Cause of Deviation: 

Response Steps Taken: 

Permit Requirement (specify permit condition #) 

Date of Deviation: 

Duration of Deviation: 

Number of Deviations: 

Probable Cause of Deviation: 

Response Steps Taken: 

Permit Requirement (specify permit condition #) 

Date of Deviation: 

Duration of Deviation: 

Number of Deviations: 

Probable Cause of Deviation: 

Response Steps Taken: 

Form Completed By: 

Title/Position: 

Date: 

Phone: 

Attach a signed certification to complete this report. 
Indiana Department of Environmental Management 

Office of Air Quality 

Technical Support Document (TSD) for a Part 70 Significant Permit 

Modification 

Source Description and Location 

Source Name: Alcoa Inc. Warrick Operations 

Source Location: Jct. IN Hwy. 66 and 61, Newburgh, IN 47629 

County: Warrick 

SIC Code: 3352, 3334 

Operation Permit No.: T173-6627-00007 

Operation Permit Issuance Date: January 5, 2007 

Significant Permit Modification No.: T173-29035-00007 

Permit Reviewer: Jillian Bertram 

Source Definition 

This company consists of two (2) plants: 

(a) Alcoa aluminum production plant, the primary operation, is located at 

Jct. IN Hwy. 66 & 61, 

Newburgh, Indiana. 

(b) Alcoa power plant, the supporting operation, is located at 4700 

Darlington Road, 

Newburgh, Indiana. 

Since the two (2) plants are located on contiguous properties, and are 

owned by one (1) company, 

they will be considered one (1) source. 

Separate Part 70 permits will be issued to Alcoa Inc.- Warrick Operations 

and Alcoa Warrick Power 

Plant solely for administrative purposes. 

These two plants have different plant identification numbers. 

Alcoa Inc. – Warrick Operations ID - 173-00007 

Alcoa Warrick Power Plant ID - 173-00002 

Existing Approvals 

The source was issued Part 70 Operating Permit No. T173-6627-00007 on 

January 5, 2007. The 

source has since received the following approvals: 

(a) Significant Source Modification No. 173-24020-00007, issued on 

September 24, 2007; 

(b) Significant Permit Modification No. 173-24585-00007, issued on 

October 30, 2007; 

(c) Exemption No. 173-25797-00007, issued January 11, 2008; 

(d) Significant Source Modification No. 173-26029-00007, issued on July 

8, 2008; 

(e) Significant Permit Modification No. 173-26037-00007, issued on July 

25, 2008; 

(f) Significant Source Modification No. 173-26942-00007, issued on 

December 10, 2008; 

(g) Significant Permit Modification No. 173-27019-00007, issued December 

30, 2008; 

(h) Minor Source Modification No. 173-27188-00007, issued on March 31, 

2009; 

(i) Significant Permit Modification No. 173-27454-00007, issued on June 

16, 2009; 

(j) Minor Source Modification No. 173-27716-00007, issued on April 20, 

2009; 
(k) Minor Permit Modification No. 173-27764-00007, issued on June 18, 

2009; 

(l) Administrative Amendment No. 173-27723-00007, issued on April 8, 

2009; and 
Alcoa Inc. Warrick Operations Page 2 of 25 

Newburgh, Indiana TSD for Significant Permit Modification No.: 173-29035-

00007 

Permit Reviewer: Jillian Bertram 

(m) Significant Permit Modification No. 173-28362-00007, issued on 

November 13, 2009. 

County Attainment Status 

The source is located in Warrick County. 

Pollutant Designation 

SO2 Cannot be classified. 

CO Unclassifiable or attainment effective November 15, 1990. 

O3 Attainment effective January 30, 2006, for the Evansville area, 

including Warrick 

County, for the 8-hour ozone standard.1 

PM10 Unclassifiable effective November 15, 1990. 

NO2 Cannot be classified or better than national standards. 

Pb Not designated. 

1Unclassifiable or attainment effective October 18, 2000, for the 1-hour 

ozone standard which 

was revoked effective June 15, 2005. 

Basic nonattainment designation effective federally April 5, 2005, for 

PM2.5. 

(a) Ozone Standards 

Volatile organic compounds (VOC) and Nitrogen Oxides (NOx) are regulated 

under the 

Clean Air Act (CAA) for the purposes of attaining and maintaining the 

National Ambient 

Air Quality Standards (NAAQS) for ozone. Therefore, VOC and NOx emissions 

are 

considered when evaluating the rule applicability relating to ozone. 

Warrick County has 

been designated as attainment or unclassifiable for ozone. Therefore, VOC 

and NOx 

emissions were reviewed pursuant to the requirements for Prevention of 

Significant 

Deterioration (PSD), 326 IAC 2-2. 

(b) PM2.5 

U.S. EPA, in the Federal Register Notice 70 FR 943 dated January 5, 2005, 

has 

designated Warrick County as nonattainment for PM2.5. On March 7, 2005, 

the Indiana 

Attorney General’s Office, on behalf of IDEM, filed a lawsuit with the 

Court of Appeals for 

the District of Columbia Circuit challenging U.S. EPA’s designation of 

nonattainment 

areas without sufficient data. However, in order to ensure that sources 

are not potentially 

liable for a violation of the Clean Air Act, the OAQ is following the 

U.S. EPA’s New Source 

Review Rule for PM2.5 promulgated on May 8, 2008. These rules became 

effective on 

July 15, 2008. Therefore, direct PM2.5 and SO2 emissions were reviewed 

pursuant to the 
requirements of Nonattainment New Source Review, 326 IAC 2-1.1-5. See the 

State Rule

Applicability – Entire Source section. 

(c) Other Criteria Pollutants 

Warrick County has been classified as attainment or unclassifiable in 

Indiana for all other 

criteria pollutatnts. Therefore, these emissions were reviewed pursuant 

to the 

requirements for Prevention of Significant Deterioration (PSD), 326 IAC 

2-2. 

Fugitive Emissions 

Since this source is considered one of the twenty-eight (28) listed 

source categories, as specified 

in 326 IAC 2-2, 326 IAC 2-3, or 326 IAC 2-7. Therefore, fugitive 

emissions are counted toward the 

determination of PSD, Emission Offset, and Part 70 Permit applicability. 
Alcoa Inc. Warrick Operations Page 3 of 25 

Newburgh, Indiana TSD for Significant Permit Modification No.: 173-29035-

00007 

Permit Reviewer: Jillian Bertram 

Source Status 

The table below summarizes the potential to emit of the entire source, 

prior to the proposed 

modification, after consideration of all enforceable limits established 

in the effective permits: 

Pollutant Emissions (ton/yr) 

PM >100 

PM10 >100 

PM2.5 >100 

SO2 >100 

VOC >100 

CO >100 

NOX >100 

Single HAPs >10 

Total >25 

(a) This existing source is a major stationary source, under PSD (326 IAC 

2-2), because a 

regulated pollutant is emitted at a rate of 100 tons per year or more, 

and it is one of the 

twenty-eight (28) listed source categories, as specified in 326 IAC 2-2-

1(gg)(1). 

(b) This existing source is a major stationary source, under 

nonattainment new source review 

rules (326 IAC 2-1.1-5) since direct PM2.5 and/or SO2 is emitted at a 

rate of 100 tons per 

year or more. 

This existing source is a major source of HAPs, as defined in 40 CFR 

63.2, because HAP 

emissions are greater than ten (10) tons per year for a single HAP and 

greater than twenty-five 

(25) tons per year for a combination of HAPs. Therefore, this source is a 

major source under 

Section 112 of the Clean Air Act (CAA). 

Description of Proposed Modification 

The Office of Air Quality (OAQ) has reviewed a modification application, 

submitted by Alcoa inc. 

Warrick Operations on March 2, 2010, relating to the replacement of 

existing pots in Line 1 with 

research pots and increase in flow to Airslide B6 Baghouse. The following 

is a list of the modified 

emission unit: 

(a) One (1) advanced technology potline, consisting of 10-15 research 

pots, identified as Potline 

No.1, modified in 2010, with a maximum aluminum production rate of 0.86 

tons per hour, and 

5,000 tons per year. Primary emissions are either controlled by the 

Potline No.1 A-398 pollution 

control system (B2) and exhaust at Stacks 160B2.1-160B2.14 or controlled 

by a new air pollution 
control system to be sized for the reduced airflow needed only for the 

research pots.. Secondary 

emissions are uncontrolled and exhaust at roof monitor 102M.1. 

One (1) fluidized bed scrubber and baghouse system, consisting of seven 

(7) fluidized bed 

scrubbers and baghouses, identified as Potline No. 1 A-398 pollution 

control system (B2), with a 

total gas flow rate of 490,000 acfm at 2000F, and exhausting at Stacks 

160B2.1-160B2.14 or a 

newly designed system to be sized for a maximum reduced airflow of 52,500 

acfm at 2000F 

required for 10-15 research pots and exhausting at a new exhaust stack; 

(b) One (1) fresh alumina tank, identified as Tank 152, fed from Airslide 

151, constructed in 1969, 

with a maximum storage capacity of 25,000 tons, and venting to the B5 or 

B6 Pollution control 

system feed airslide baghouses. This tank serves as an emergency supply 

point for alumina. 

Withdrawals from this tank occur via the BC26 Belt Conveyor; 
Alcoa Inc. Warrick Operations Page 4 of 25 

Newburgh, Indiana TSD for Significant Permit Modification No.: 173-29035-

00007 

Permit Reviewer: Jillian Bertram 

(c) Feed box B5 and Pollution Control System Alumina Feed Airslide B5, 

transporting alumina from 

Tank 154 to the B5 Pollution Control System, constructed in 1969, with a 

maximum capacity of 18 

tons per hour, controlled by Airslide B5 or B6 Baghouse, and exhausting 

at Stack 161.B5.37. 

One (1) baghouse, identified as Airslide B5 Baghouse, with an airflow 

rate of 4,600 acfm at a 

temperature 70oF, and exhausting at Stack 161B5.37; 

(d) Feed box B6 and Pollution Control System Alumina Feed Airslide B6, 

transporting alumina from 

Tank 154 to the B6 Pollution Control System, constructed in 1969, with a 

capacity of 18 tons per 

hour, controlled by Airslide B5 or B6 Baghouse, and exhausting at Stack 

161.B6.37. 

One (1) baghouse, identified as Airslide B6 Baghouse, with an airflow 

rate of 4,600 acfm at a 

temperature 70oF, and exhausting at Stack 161B6.37; 

(e) One (1) fresh alumina tank, identified as Tank 154, fed from Airslide 

151, feeding to: 

(A) Potline #5 pollution control system, Feed Box B5; 

(B) Potline #6 pollution control system, Feed Box B6; 

(C) Vibratory Screen and GTC Feed Airslide 161-B3-FM-01; and 

(D) Vibratory Screen and GTC Feed Airslide 161-B4-FM-01. 

Tank 154 was constructed in 1969, and has a capacity of 1,200 tons. It is 

controlled by Airslide B5 

Baghouse or Airslide B6 Baghouse, and exhausts at Stacks 161.B5.37 

or161.B6.37; 

Enforcement Issues 

There are no pending enforcement actions. 

Emission Calculations 

See Appendix A of this Technical Support Document for detailed emission 

calculations. 

Permit Level Determination – Part 70 

Pursuant to 326 IAC 2-1.1-1(16), Potential to Emit is defined as ―the 

maximum capacity of a 

stationary source or emission unit to emit any air pollutant under its 

physical and operational 

design. Any physical or operational limitation on the capacity of a 

source to emit an air pollutant, 

including air pollution control equipment and restrictions on hours of 

operation or type or amount 

of material combusted, stored, or processed shall be treated as part of 

its design if the limitation is 

enforceable by the U. S. EPA, IDEM, or the appropriate local air 

pollution control agency.‖ 
Alcoa Inc. Warrick Operations Page 5 of 25 

Newburgh, Indiana TSD for Significant Permit Modification No.: 173-29035-

00007 

Permit Reviewer: Jillian Bertram 

The following table is used to determine the appropriate permit level 

under 326 IAC 2-7-10.5. This 

table reflects the PTE before controls. Control equipment is not 

considered federally enforceable 

until it has been required in a federally enforceable permit. 

PTE Before Controls of the Modification 

Pollutant Potential To Emit (ton/yr) 

PM -191.90 

PM10 -128.89 

PM2.5 -151.32 

SO2 0.00 

VOC 0.00 

CO 0.00 

NOX -0.48 

Single HAPs (HF) 0 

Combined HAPs (HF) 0 

Appendix A of this TSD reflects the unrestricted potential emissions of 

the modification. 

There is no increase in the potential to emit of any regulated pollutants 

associated with this 

modification. This modification is not subject to the source modification 

requirements under 326 

IAC 2-7-10.5. The changes will be incorporated into the permit as a 

Significant Permit 

Modification under 326 IAC 2-7-12(d) because it requires a case-by-case 

determination of an 

emission limitation or standard. 

HAP Limit 

In order to avoid case-by-case MACT requirements, single HAP emissions 

will be limited to less 

than 10 tons per year. 

(1) The total emissions of Hydrogen Fluoride from Potline No. 1 shall be 

less than 10 tons per 

per twelve (12) consecutive month period, with compliance determined at 

the end of each 

month. 

Compliance with this limit shall limit the total potential to emit of any 

single HAP from Potline No. 1 

to less than ten (10) tons per 12 consecutive month period and PTE of 

combined HAPs to less 

than 25 tons per twelve (12) consecutive month period and shall render 

326 IAC 2-4.1 (Major 

Sources of Hazardous Air Pollutants (HAP) not applicable to Potline No. 1 

modification. 

Permit Level Determination – PSD and Nonattainment NSR 

The table below summarizes the potential to emit, reflecting all limits, 

of the emission units. Any 

control equipment is considered federally enforceable only after issuance 

of this Part 70 permit 
modification, and only to the extent that the effect of the control 

equipment is made practically 

enforceable in the permit. 

Table 1: Projected Change in Actual Emissions (ton/yr) 

Process / Emission Unit CO NOX PM PM10 PM2.5 SO2 VOC TF 

Future Actual 0.00 0.87 78.89 45.73 50.52 0.00 0.00 17.22 

Baseline Actual 

0.00 1.67 53.99 30.83 41.41 0.00 0.00 14.23 

Total for Modification 0.00 -0.8 24.90 14.90 9.11 0.00 0.00 2.90 

PSD Significant Level 100 40 25 15 40 40 15 

Nonattainment NSR 10 
Alcoa Inc. Warrick Operations Page 6 of 25 

Newburgh, Indiana TSD for Significant Permit Modification No.: 173-29035-

00007 

Permit Reviewer: Jillian Bertram 

Table 1: Projected Change in Actual Emissions (ton/yr) 

Process / Emission Unit CO NOX PM PM10 PM2.5 SO2 VOC TF 

Significant Level 

This modification to an existing major stationary source is not major for 

PSD because the 

emissions increases are less than the PSD significant levels. Therefore, 

pursuant to 326 IAC 2-2, 

the PSD requirements do not apply. 

This modification to an existing major stationary source is not major for 

Nonattainment NSR 

because the emissions increase is less than the Nonattainment NSR 

significant level. Therefore, 

pursuant to 326 IAC 2-1.1-5, the Nonattainment NSR requirements do not 

apply. 

The Permittee has provided information as part of the application for 

this approval that based on 

Actual to Projected Actual test in 326 IAC 2-2-2 this modification at a 

major stationary source will 

not be major for Prevention of Significant Deterioration under 326 IAC 2-

2-1, Nonattainment NSR 

326 IAC 2-1.1.5. IDEM, OAQ has not reviewed this information and will not 

be making any 

determination in this regard as part of this approval. The applicant will 

be required to keep records 

and report in accordance with Source obligation in 326 IAC 2-2-8. See TSD 

App B for detailed 

ATPA calculations. 

Federal Rule Applicability Determination 

NSPS: 

(a) There are no New Source Performance Standards (NSPS)(326 IAC 12 and 

40 CFR Part 

60) applicable to this proposed modification. The same portions of 40 CFR 

60, Subpart, S, 

New Source Performance Standards for Primary Aluminum Reduction Plants 

apply as are 

listed in the current operating permit. 

NESHAP: 

(b) There are no National Emission Standards for Hazardous Air Pollutants 

(NESHAPs) (326 

IAC 14, 326 IAC 20 and 40 CFR Part 63) applicable to this proposed 

modification. 

(c) Pursuant to 40 CFR 64.2, Compliance Assurance Monitoring (CAM) is 

applicable to new 

or modified emission units that involve a pollutant-specific emission 

unit and meet the 

following criteria: 

(1) has a potential to emit before controls equal to or greater than the 

Part 70 major 

source threshold for the pollutant involved; 
(2) is subject to an emission limitation or standard for that pollutant; 

and 

(3) uses a control device, as defined in 40 CFR 64.1, to comply with that 

emission 

limitation or standard. 

The following table is used to identify the applicability of each of the 

criteria, under 40 CFR 64.1, 

to each new or modified emission unit involved: 

CAM Applicability Analysis 

Emission Unit Control 

Device 

Used 

Emission 

Limitation 

(Y/N) 

Uncontrolled 

PTE 

(ton/yr) 

Controlled 

PTE 

(ton/yr) 

Part 70 

Major 

Source 

Threshold 

(ton/yr) 

CAM 

Applicable 

(Y/N) 

Large 

Unit 

(Y/N) 

Potline No. 1 – Potline N 140.62 14.06 100 N N 
Alcoa Inc. Warrick Operations Page 7 of 25 

Newburgh, Indiana TSD for Significant Permit Modification No.: 173-29035-

00007 

Permit Reviewer: Jillian Bertram 

CAM Applicability Analysis 

Emission Unit Control 

Device 

Used 

Emission 

Limitation 

(Y/N) 

Uncontrolled 

PTE 

(ton/yr) 

Controlled 

PTE 

(ton/yr) 

Part 70 

Major 

Source 

Threshold 

(ton/yr) 

CAM 

Applicable 

(Y/N) 

Large 

Unit 

(Y/N) 

PM10 No. 1 

A-398 

(B2) 

Potline No. 1 –

PM2.5 

Potline 

No. 1 

A-398 

(B2) 

N 161.03 14.06 100 N N 

Potline No. 1 -

PM 

Potline 

No. 1 

A-398 

(B2) 

Y, 326 

IAC 6-3-2 

123.87 12.39 100 Y N 

Based on this evaluation, the requirements of 40 CFR Part 64, CAM are 

applicable to Potline No. 

1 for PM upon issuance of the Title V Renewal. A CAM plan must be 

submitted as part of the 

Renewal application. 

State Rule Applicability Determination 
The following state rules are applicable to the source due to the 

modification: 

326 IAC 2-1.1-5 (Nonattainment New Source Review) 

Nonattainment New Source Review applicability is discussed under the 

Permit Level 

Determination – PSD and Emission Offset section. 

326 IAC 2-2 and 2-3 (PSD) 

PSD and Emission Offset applicability is discussed under the Permit Level 

Determination – PSD. 

326 IAC 2-4.1 (Major Sources of Hazardous Air Pollutants (HAP)) 

The operation of Potline No.1 will be limited to less than ten (10) tons 

per year for a single HAP 

and less than twenty-five (25) tons per year for a combination of HAPs. 

Therefore, 326 IAC 2-4.1 

does not apply. 

In order to render the requirements of 326 IAC 2-2 326 IAC 2-4.1 (Major 

Sources of Hazardous Air 

Pollutants (HAP)) not applicable, the source shall comply with the 

following: 

Single HAP emissions Potline No. 1 shall be limited to less than 10 tons 

per twelve consecutive 

month period with compliance determined at the end of every month. 

Compliance with this limit shall limit the HAP emissions from modified 

Potline No. 1 to less than 

10 tons per 12 consecutive month period and will render 326 IAC 2-4.1 not 

applicable to this 

modification. 

326 IAC 2-6 (Emission Reporting) 

Since this source is required to have an operating permit under 326 IAC 

2-7, Part 70 Permit 

Program, this source is subject to 326 IAC 2-6 (Emission Reporting). In 

accordance with the 

compliance schedule in 326 IAC 2-6-3, an emission statement must be 

submitted annually. The 

first report is due no later than July 1, 2006, and subsequent reports 

are due every year thereafter. 

The emission statement shall contain, at a minimum, the information 

specified in 326 IAC 2-6-4. 
Alcoa Inc. Warrick Operations Page 8 of 25 

Newburgh, Indiana TSD for Significant Permit Modification No.: 173-29035-

00007 

Permit Reviewer: Jillian Bertram 

326 IAC 6-3-2 (Particulate Emission Limitations for Manufacturing 

Processes) 

Pursuant to 326 IAC 6-3-2, the particulate matter (PM) from the Potline 

No. 1 shall not exceed 

8.35 pounds per hour when operating at a process weight rate of 2.892 

tons per hour. The pound 

per hour limitation was calculated with the following equation: 

(a) Interpolation of the data for the process weight rate up to sixty 

thousand (60,000) pounds 

per hour shall be accomplished by use of the equation: 

E = 4.10 P 0.67 where E = rate of emission in pounds per hour and 

P = process weight rate in tons per hour 

Potline No. 1 A-398 (B2) shall be in operation at all times the Potline 

No. 1 is in operation, in order 

to comply with this limit. 

Compliance Determination and Monitoring Requirements 

Permits issued under 326 IAC 2-7 are required to ensure that sources can 

demonstrate 

compliance with all applicable state and federal rules on a continuous 

basis. All state and federal 

rules contain compliance provisions; however, these provisions do not 

always fulfill the 

requirement for a continuous demonstration. When this occurs, IDEM, OAQ, 

in conjunction with 

the source, must develop specific conditions to satisfy 326 IAC 2-7-5. As 

a result, Compliance 

Determination Requirements are included in the permit. The Compliance 

Determination 

Requirements in Section D of the permit are those conditions that are 

found directly within state 

and federal rules and the violation of which serves as grounds for 

enforcement action. 

If the Compliance Determination Requirements are not sufficient to 

demonstrate continuous 

compliance, they will be supplemented with Compliance Monitoring 

Requirements, also in Section 

D of the permit. Unlike Compliance Determination Requirements, failure to 

meet Compliance 

Monitoring conditions would serve as a trigger for corrective actions and 

not grounds for 

enforcement action. However, a violation in relation to a compliance 

monitoring condition will 

arise through a source’s failure to take the appropriate corrective 

actions within a specific time 

period. 

The following compliance monitoring requirements apply to the modified 

Potline No. 1: 

(a) In order to determine compliance with the HF Minor limit; 

TP1 * EFP1HF = Hydrogen Fluoride Emissions from Potline No. 1 

Where: 
TP1 = total aluminum throughput to Potline No.1 per month. 

EFP1HF = Emission Factor determined by the most recent compliant stack 

test, lbs of HF 

per ton of aluminum tapped 

(b) Testing requirements have been added for Potline No. 1 to establish 

the HF emission 

factor required in the equation above. 

Proposed Changes 

The changes listed below have been made to Part 70 Operating Permit 

No.173-6627-00007. 

Deleted language appears as strikethroughs and new language appears in 

bold: 

Change No. 1 

Feedbox and alumina tank descriptions have been changed to reflect new 

exhaust scenarios. 

SECTION D.1 ALUMINA & ALUMINUM FLUORIDE HANDLING SYSTEM 

FACILITY OPERATION CONDITIONS 
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Permit Reviewer: Jillian Bertram 

Facility Description [326 IAC 2-7-5(15)] 

(The information describing the process contained in this facility 

description box is descriptive information 

and does not constitute enforceable conditions.) 

*** 

(31) One (1) fresh alumina tank, identified as Tank 152, fed from 

Airslide 151, constructed in 1969, 

with a maximum storage capacity of 25,000 tons, and venting to the B5 and 

or B6 Pollution 

control system feed airslide baghouses. This tank serves as an emergency 

supply point for 

alumina. Withdrawals from this tank occur via the BC26 Belt Conveyor; 

(32) Feed box B5 and Pollution Control System Alumina Feed Airslide B5, 

transporting alumina from 

Tank 154 to the B5 Pollution Control System, constructed in 1969, with a 

maximum capacity of 18 

tons per hour, controlled by Airslide B5 or B6 Baghouse, and exhausting 

at Stack 161.B5.37. 

One (1) baghouse, identified as Airslide B5 Baghouse, with an airflow 

rate of 3,500 4,600 acfm at 

a temperature 70oF, and exhausting at Stack 161B5.37; 

(33) Feed box B6 and Pollution Control System Alumina Feed Airslide B6,

transporting alumina from 

Tank 154 to the B6 Pollution Control System, constructed in 1969, with a 

capacity of 18 tons per 

hour, controlled by Airslide B5 or B6 Baghouse, and exhausting at Stack 

161.B6.37. 

One (1) baghouse, identified as Airslide B6 Baghouse, with an airflow 

rate of 3,500 4,600 acfm at 

a temperature 70oF, and exhausting at Stack 161B6.37; 

(34) One (1) fresh alumina tank, identified as Tank 154, fed from 

Airslide 151, feeding to: 

(A) Potline #5 pollution control system, Feed Box B5; 

(B) Potline #6 pollution control system, Feed Box B6; 

(C) Vibratory Screen and GTC Feed Airslide 161-B3-FM-01; and 

(D) Vibratory Screen and GTC Feed Airslide 161-B4-FM-01. 

Tank 154 was constructed in 1969, and has a capacity of 1,200 tons. It is 

controlled by Airslide B5 

Baghouse and or Airslide B6 Baghouse, and exhausts at Stacks 161.B5.37 

and or 161.B6.37; 

*** 

D.1.1 Particulate Emissions Limitations for Manufacturing Processes [326 

IAC 6-3-2] 

Pursuant to 326 IAC 6-3 (Particulate Emissions Limitations for 

Manufacturing Processes), the 

allowable PM emission rate from the below listed processes shall be 

limited as follows: 
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Permit Reviewer: Jillian Bertram 

Facility Control Device 

Maximum 

Process 

Weight 

Rate 

(tons/hr) 

PM 

Emission 

Limit 

(lbs/hr) 

Tank 151C, Tank 151J, Tank 152, 

Tank 154, Feed Box B5 and 

Pollution Control System Alumina 

Feed Airslide B5 and Polllution 

Control System Alumina Feed 

Airslide B6 

Airslide B5 or B6 Baghouse 243 60.54 

Tank 151C, Tank 151J, Tank 152, 

Tank 154, Feed Box B6 and 

Pollution Control System Alumina 

Feed Airslide B6 

Airslide B6 Baghouse 243 60.54 

*** 

D.1.3 Particulate Control [326 IAC 2-7-6(6)] 

(a) In order to comply with Condition D.1.1, the PM emissions from the 

following facilities 

shall be controlled by the baghouses as indicated in the table below. 

Each baghouse shall 

be in operation and control emissions from its associated facility at all 

times when a facility 

that the baghouse controls is in operation. 

Facility Baghouse 

Tank 151C, Tank 151J, Tank 152, 

Tank 154, Feed Box B5 and Pollution 

Control System Alumina Feed 

Airslide B5 and Polllution Control 

System Alumina Feed Airslide B6 

Airslide Baghouse B5 or 

Airslide Baghouse B6 

Tank 151C, Tank 151J, Tank 152, 

Tank 154, Feed Box B6 and Pollution 

Control System Alumina Feed 

Airslide B6 

Airslide Baghouse B6 

Change No. 2 

The description of Potline No. 1 has been updated to incorporate this 

modification. 

SECTION D.2 POTLINE & POTLINES SUPPORT FACILITY OPERATION CONDITIONS 

Facility Description [326 IAC 2-7-5(15)] 
(The information describing the process contained in this facility 

description box is descriptive 

information and does not constitute enforceable conditions.) 

(1) One (1) advanced technology center-worked prebake one (CWPB1) 

potline, consisting of 150 

pots 10-15 research pots, identified as Potline No.1, constructed in 1956 

modified in 2010, 

with a maximum aluminum production rate of 7.08 0.86 tons per hour, and 

5,000 tons per 

year. Primary emissions are either controlled by the Potline No.1 A-398 

pollution control 

system (B2) and exhaust at Stacks 160B2.1-160B2.14 or controlled by a new 

air pollution 

control system to be sized for the reduced airflow needed only for the 

research pots. 

Secondary emissions are uncontrolled and exhaust at roof monitor 101M.1 

and 102M.1. 
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One (1) fluidized bed scrubber and baghouse system, consisting of seven 

(7) fluidized bed 

scrubbers and baghouses, identified as Potline No. 1 A-398 pollution 

control system (B2), with 

a total gas flow rate of 490,000 acfm at 2000F, and exhausting at Stacks 

160B2.1-160B2.14 or 

a newly designed system to be sized for a maximum reduced airflow of 

52,500 acfm at 

2000F required for 10-15 research pots and exhausting at a new exhaust 

stack; 

Change No. 3 

The particulate emission limitation, pursuant to 326 IAC 6-3, has been 

updated to reflect the process 

weight rate of the modified potline. 

D.2.1 Particulate Emissions Limitations for Manufacturing Processes [326 

IAC 6-3-2] 

Pursuant to 326 IAC 6-3-2 (Particulate Emissions Limitations for 

Manufacturing Processes), the 

allowable particulate emission rate from the Potlines Nos.1, 2, 3, 4, 5, 

and 6, shall be limited as 

follows: 

Facility 

Maximum Process 

Weight Rate 

(tons/hr) 

PM Emission 

Limit 

(lbs/hr) 

Potline No.1 75.83 0.86 48.5 3.71 

Change No. 4 

A single HAP, HF emission limitation has been added to the permit as well 

as associated compliance 

determination and recordkeeping requirements. 

D.2.6 HAP Minor Limit [326 IAC 2-4.1] 

The total emissions of Hydrogen Fluoride from Potline No. 1 shall be less 

than 10 tons per 

per twelve (12) consecutive month period, with compliance determined at 

the end of each 

month. 

Compliance with this limit shall limit the potential to emit of any 

single HAP from Potline 

No. 1 to less than ten (10) tons per twelve (12) consecutive month period 

and combined 

HAPs less than 25 tons per twelve (12) consecutive month period, and 

shall render 326 IAC 

2-4.1 (Major Sources of Hazardous Air Pollutants (HAP) not applicable to 

Potline No. 1. 

*** 

D.2.7 Particulate Control [326 IAC 2-7-6(6)] 
(a) In order to comply with Conditions D.2.1 and D.2.4, the PM and 

fluoride emissions from 

the following potlines shall be controlled by the pollution control 

systems as indicated in 

the table below. Each pollution control system shall be in operation and 

control emissions 

from its associated potline at all times when a potline that the 

pollution control system 

controls is in operation. 

Potline Pollution Control System 

Potline No.1 Potline No. 1 A-398 (B2) or a 

newly installed system 

D.2.9 HAP Emission Determination 

In order to determine the compliance status with Condition D.2.6, the 

Permittee shall use 

the following equation: 

TP1 * EFP1HF = Hydrogen Fluoride Emissions from Potline No. 1 
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Permit Reviewer: Jillian Bertram 

Where: 

TP1 = total aluminum throughput to Potline No.1 in tons, per month. 

EFP1HF = Emission Factor determined by the most recent compliant stack 

test, lbs of HF per 

ton of aluminum tapped 

*** 

D.2.11 HAP Testing Requirements 

Not later than 180 days after startup of the research pots in Potline No. 

1, in order to 

demonstrate the compliance status with Condition D.2.6, the Permittee 

shall perform 

hydrogen fluoride testing on Potline No.1, utilizing methods as approved 

by the 

Commissioner. This test shall be repeated at least once every five (5) 

years from the date of 

this valid compliance demonstration. Testing shall be conducted in 

accordance with the 

provisions of 326 IAC 3-6 (Source Sampling Procedures). Section C -

Performance Testing 

contains the Permittee's obligations with regard to the performance 

testing required by this 

condition. 

*** 

D.2.18 Record Keeping Requirements 

(a) To document compliance with SO2 in Condition D.2.2, the Permittee 

shall maintain 

records in accordance with (1) and (2) below: 

(1) The records shall include data and methodology used to calculate the 

monthly 

sulfur dioxide emissions; and 

(2) Records shall be complete and sufficient to establish compliance with 

the SO2 

limit as required in Condition D.2.2. 

(b) To document compliance with Condition D.2.6, the Permittee shall 

maintain records 

in accordance with (1) and (2) below: 

(1) Total aluminum throughput to Potline No. 1 in a month; and 

(2) The most recent HF stack testing results. 

*** 

D.2.21 HAP Reporting Requirements 

A quarterly report of the information to document the compliance status 

with Conditions 

D.2.6 shall be submitted, using the reporting forms located at the end of 

this permit, or 

their equivalent, not later than thirty (30) days following the end of 

each calendar quarter. 

The report submitted by the Permittee does require a certification that 

meets the 

requirements of 326 IAC 2-7-6(1) by a ―responsible official‖ as defined 

by 326 IAC 2-7-1(34). 
Section C - General Reporting Requirements contains the Permittee's 

obligations with 

regard to the reporting required by this condition. 

*** 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION 

Part 70 HF Quarterly Report 

Source Name: Alcoa Inc. - Warrick Operations 

Source Address: Jct. IN Hwys. 66 & 61, Newburgh, Indiana 47629-0010 

Mailing Address: Bldg. 860 E, P.O. Box 10, Newburgh, Indiana 47629 

Part 70 Permit No.: T173-6627-00007 

Facility: Potlines No. 1 

Parameter: HF Emissions 

Limit: The total emissions of Hydrogen Flouride from Potline No. 1 shall 

be less than 10 tons per 
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Permit Reviewer: Jillian Bertram 

per twelve (12) consecutive month period, with compliance determined at 

the end of each 

month. 

Quarter _______ Year: ______ 

Month 

HF 

(tons)

HF 

(tons) 

HF 

(tons) 

This Month 

Previous 11 

Months 

12 Month 

Total 

Month 1 

Month 2 

Month 3 

. No deviation occurred in this month. 

. Deviation/s occurred in this month. 

Deviation has been reported on: 

Submitted by: 

Title/Position: 

Signature: 

Date: 

Phone: 

Attach a signed certification to complete this report. 

Change No. 5 

Condition C.19 has been modified to contain the reporting relief provided 

by the Quarterly Deviation and 

Monitoring Report form. 

C.19 General Reporting Requirements [326 IAC 2-7-5(3)(C)] [326 IAC 2-1.1-

11] [326 IAC 2-2] 

[326 IAC 2-3] 

(a) The Permittee shall submit the attached Quarterly Deviation and 

Compliance Monitoring 

Report or its equivalent. Any deviation from permit requirements, the 

date(s) of each 

deviation, the cause of the deviation, and the response steps taken must 

be reported 

except that a deviation required to be reported pursuant to an applicable 

requirement that exists independent of this permit, shall be reported 

according to 

the schedule stated in the applicable requirement and does not need to be 

included 

in this report. This report shall be submitted within thirty (30) days of 

the end of the 

reporting period. The Quarterly Deviation and Compliance Monitoring

Report shall 
include the certification by the "responsible official" as defined by 326 

IAC 2-7-1(34). 
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Change No. 6 

Condition D.6.13 was written prior to the construction of rotary group I 

furnace. This condition has been 

updated to reflect actual operational parameters. 

D.6.13 PM and PM10 Control from Dross Cooling Operation [326 IAC 2-7-

6(6)] 

*** 

(c) When the dross cooling process is operating and neither large 

baghouse is operating, all 

skim room doors shall be closed, except when trucks enter to deliver hot 

dross, or move 

dross to the rotary group I furnace, and further provided that loadout to 

third party 

dross trucks was suspended until at least one large baghouse is returned 

to service. 

Change No. 7 

Consistent with a stay agreement between IDEM and Alcoa Inc. Warrick 

Operation on June 5, 2007, 

conditions related to visible emission notations have been modified as 

follows. 

D.1.7 Visible Emissions Notations 

(a) Visible emission notations of the exhaust from Stacks 60.2 and 60.3, 

60.6, 60.8, 61A.1, 

62.1, 62.2, 61B.1, 140.1, 104.1, 144.1, 160M.2, 160B2.16, 141.1(NE), 

161.B5.37, 

160C1.37 and 161.B6.37, shall be performed once per day during normal 

daylight 

operations. When the baghouse exhausting to stack 160C1.37 is permanently 

idled, 

visible emission notations of the exhaust from bin vent exhausts 

160C1.37-1, 160C1.37-2, 

160C1.37-3, and 160C1.37-4, shall be performed once per day during 

daylight operations. 

A trained employee shall record whether emissions are normal or abnormal. 

(b) For processes operated continuously, "normal" means those conditions 

prevailing, or 

expected to prevail, eighty percent (80%) of the time the process is in 

operation, not 

counting startup or shut down time. 

(c)(b) In the case of batch or discontinuous operations, readings shall 

be taken during normal 

operations. 

(d) A trained employee is an employee who has worked at the plant at 

least one (1) month 

and has been trained in the appearance and characteristics of normal 

visible emissions 

for that specific process. 

(e)(c) If abnormal visible emissions are observed, an employee certified 

to perform an EPA 
Method 9 evaluation shall determine whether opacity exceeds forty percent 

(40%) in 

one (1) six (6) minute averaging period as determined in 326 IAC 5-1-4, 

and: 

(1) If opacity does not exceed forty percent (40%) per Method 9, the 

Permittee 

shall shutdown the associated process as soon as practical unless either: 

(i) the Permittee is able to bring the opacity below forty percent (40%) 

within a reasonable period of time, or 

(ii) the situation qualifies as an ―emergency‖ under 326 IAC 2-7-1(12). 

If the Permittee continues to operate the associated process after 

determining the opacity exceeds forty percent (40%) per Method 9, then 

the 

Permittee shall perform an additional Method 9 reading every four (4) 

daylight hours until the opacity is below forty percent (40%) per Method 

9. 

(2) If opacity does not exceed forty percent (40%) per the Method 9 

observation 

referenced above, inspection of the baghouse shall be scheduled at the 

next available process down time. Repairs shall be scheduled as 

expeditiously as practical, based on the inspection results. 
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(3) If opacity exceeds twenty percent (20%) per any Method 9 observations 

referenced above, the Permittee shall notify IDEM, if the Permittee 

anticipates that operations will continue for ten (10) days or more 

before the 

failed baghouse units will be repaired or replaced. 

the Permittee shall take reasonable response steps in accordance with 

Section C – Response to 

Excursions and Exceedances. Abnormal emissions alone are not a deviation 

from this permit. 

Failure to take the response steps required by Condition D.1.7(c) upon 

observation of visible 

emissions in accordance with Section C - Response to Excursions and 

Exceedances, shall be 

considered a deviation from this permit. 

*** 

D.2.15 Visible Emissions Notations 

(a) Visible emission notations of the stack exhaust of Pot Line Bath 

Crusher baghouse shall 

be performed once per day. A trained employee shall record whether 

emissions are 

normal or abnormal. 

(b) For processes operated continuously, "normal" means those conditions 

prevailing, or 

expected to prevail, eighty percent (80%) of the time the process is in 

operation, not 

counting startup or shut down time. 

(c)(b) In the case of batch or discontinuous operations, readings shall 

be taken during normal 

operations. 

(d) A trained employee is an employee who has worked at the plant at 

least one (1) month 

and has been trained in the appearance and characteristics of normal 

visible emissions 

for that specific process. 

(e)(c) If abnormal visible emissions are observed, an employee certified 

to perform an EPA 

Method 9 evaluation shall determine whether opacity exceeds forty percent 

(40%) in 

one (1) six (6) minute averaging period as determined in 326 IAC 5-1-4, 

and: 

(1) If opacity does not exceed forty percent (40%) per Method 9, the 

Permittee 

shall shutdown the associated process as soon as practical unless either: 

(iii) the Permittee is able to bring the opacity below forty percent 

(40%) 

within a reasonable period of time, or 

(iv) the situation qualifies as an ―emergency‖ under 326 IAC 2-7-1(12). 

If the Permittee continues to operate the associated process after 

determining the opacity exceeds forty percent (40%) per Method 9, then 

the 
Permittee shall perform an additional Method 9 reading every four (4) 

daylight hours until the opacity is below forty percent (40%) per Method 

9. 

(2) If opacity does not exceed forty percent (40%) per the Method 9 

observation 

referenced above, inspection of the baghouse shall be scheduled at the 

next available process down time. Repairs shall be scheduled as 

expeditiously as practical, based on the inspection results. 

(3) If opacity exceeds twenty percent (20%) per any Method 9 observations 

referenced above, the Permittee shall notify IDEM, if the Permittee 

anticipates that operations will continue for ten (10) days or more 

before the 

failed baghouse units will be repaired or replaced. 

the Permittee shall take reasonable response steps in accordance with 

Section C – Response to 
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Excursions and Exceedances. Abnormal emissions alone are not a deviation 

from this permit. 

Failure to take the response steps required by Condition D.2.15(c) upon 

observation of 

visible emissions in accordance with Section C - Response to Excursions 

and Exceedances, 

shall be considered a deviation from this permit. 

*** 

D.3.10 Visible Emissions Notations 

(a) Visible emission notations of the stack exhaust for DC-153, DCF-221A, 

DCF-221B, and 

Check-Weigh Scale baghouses shall be performed once per day. A trained 

employee 

shall record whether emissions are normal or abnormal. 

(b) For processes operated continuously, "normal" means those conditions 

prevailing, or 

expected to prevail, eighty percent (80%) of the time the process is in 

operation, not 

counting startup or shut down time. 

(c)(b) In the case of batch or discontinuous operations, readings shall 

be taken during normal 

operations. 

(d) A trained employee is an employee who has worked at the plant at 

least one (1) month 

and has been trained in the appearance and characteristics of normal 

visible emissions 

for that specific process. 

(e)(c) If abnormal visible emissions are observed, an employee certified 

to perform and EPA 

Method 9 evaluation shall determine whether opacity exceeds forty percent 

(40%) in 

one (1) six (6) minute averaging period as determined in 326 IAC 5-1-4, 

and: 

(1) If opacity does not exceed forty percent (40%) per Method 9, the 

Permittee 

shall shutdown the associated process as soon as practical unless either: 

(v) the Permittee is able to bring the opacity below forty percent (40%) 

within a reasonable period of time, or 

(vi) the situation qualifies as an ―emergency‖ under 326 IAC 2-7-1(12). 

If the Permittee continues to operate the associated process after 

determining the opacity exceeds forty percent (40%) per Method 9, then 

the 

Permittee shall perform an additional Method 9 reading every four (4) 

daylight hours until the opacity is below forty percent (40%) per Method 

9. 

(2) If opacity does not exceed forty percent (40%) per the Method 9 

observation 

referenced above, inspection of the baghouse shall be scheduled at the 

next available process down time. Repairs shall be scheduled as 

expeditiously as practical, based on the inspection results. 
(3) If opacity exceeds twenty percent (20%) per any Method 9 observations 

referenced above, the Permittee shall notify IDEM, if the Permittee 

anticipates that operations will continue for ten (10) days or more 

before the 

failed baghouse units will be repaired or replaced. 

the Permittee shall take reasonable response steps in accordance with 

Section C – Response to 

Excursions and Exceedances. Abnormal emissions alone are not a deviation 

from this permit. 

Failure to take the response steps required by Condition D.3.10(c) upon 

observation of 

visible emissions in accordance with Section C - Response to Excursions 

and Exceedances, 

shall be considered a deviation from this permit. 

*** 
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Permit Reviewer: Jillian Bertram 

D.4.18 Visible Emissions Notations 

(a) Visible emission notations of the stack exhaust for baked anode 

vacuum system 

baghouse shall be performed once per day. A trained employee shall record 

whether 

emissions are normal or abnormal.

(b) For processes operated continuously, "normal" means those conditions 

prevailing, or 

expected to prevail, eighty percent (80%) of the time the process is in 

operation, not 

counting startup or shut down time. 

(c)(b) In the case of batch or discontinuous operations, readings shall 

be taken during normal 

operations 

(d) A trained employee is an employee who has worked at the plant at 

least one (1) month 

and has been trained in the appearance and characteristics of normal 

visible emissions 

for that specific process. 

(e)(c) If abnormal visible emissions are observed, an employee certified 

to perform an EPA 

Method 9 evaluation shall determine whether opacity exceeds forty percent 

(40%) in 

one (1) six (6) minute averaging period as determined in 326 IAC 5-1-4, 

and: 

(1) If opacity does not exceed forty percent (40%) per Method 9, the 

Permittee 

shall shutdown the associated process as soon as practical unless either: 

(vii) the Permittee is able to bring the opacity below forty percent 

(40%) 

within a reasonable period of time, or 

(viii) the situation qualifies as an ―emergency‖ under 326 IAC 2-7-1(12). 

If the Permittee continues to operate the associated process after 

determining the opacity exceeds forty percent (40%) per Method 9, then 

the 

Permittee shall perform an additional Method 9 reading every four (4) 

daylight hours until the opacity is below forty percent (40%) per Method 

9. 

(2) If opacity does not exceed forty percent (40%) per the Method 9 

observation 

referenced above, inspection of the baghouse shall be scheduled at the 

next available process down time. Repairs shall be scheduled as 

expeditiously as practical, based on the inspection results. 

(3) If opacity exceeds twenty percent (20%) per any Method 9 observations 

referenced above, the Permittee shall notify IDEM, if the Permittee 

anticipates that operations will continue for ten (10) days or more 

before the 

failed baghouse units will be repaired or replaced. 

the Permittee shall take reasonable response steps in accordance with 

Section C – Response to 
Excursions and Exceedances. Abnormal emissions alone are not a deviation 

from this permit. 

Failure to take the response steps required by Condition D.4.18(c) upon 

observation of 

visible emissions in accordance with Section C - Response to Excursions 

and Exceedances, 

shall be considered a deviation from this permit. 

*** 

D.5.7 Visible Emissions Notations 

(a) Visible emission notations of the stack exhaust for Tumbleblast 

Baghouse, and Impactor 

Baghouse shall be performed once per day. A trained employee shall record 

whether 

emissions are normal or abnormal. 
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(b) For processes operated continuously, "normal" means those conditions 

prevailing, or 

expected to prevail, eighty percent (80%) of the time the process is in 

operation, not 

counting startup or shut down time. 

(c)(b) In the case of batch or discontinuous operations, readings shall 

be taken during normal 

operations. 

(d) A trained employee is an employee who has worked at the plant at 

least one (1) month 

and has been trained in the appearance and characteristics of normal 

visible emissions 

for that specific process. 

(e)(c) If abnormal visible emissions are observed, an employee certified 

to perform and EPA 

Method 9 evaluation shall determine whether opacity exceeds forty percent 

(40%) in 

one (1) six (6) minute averaging period as determined in 326 IAC 5-1-4, 

and: 

(1) If opacity does not exceed forty percent (40%) per Method 9, the 

Permittee 

shall shutdown the associated process as soon as practical unless either: 

(ix) the Permittee is able to bring the opacity below forty percent (40%) 

within a reasonable period of time, or 

(x) the situation qualifies as an ―emergency‖ under 326 IAC 2-7-1(12). 

If the Permittee continues to operate the associated process after 

determining the opacity exceeds forty percent (40%) per Method 9, then 

the 

Permittee shall perform an additional Method 9 reading every four (4) 

daylight hours until the opacity is below forty percent (40%) per Method 

9. 

(2) If opacity does not exceed forty percent (40%) per the Method 9 

observation 

referenced above, inspection of the baghouse shall be scheduled at the 

next available process down time. Repairs shall be scheduled as 

expeditiously as practical, based on the inspection results. 

(3) If opacity exceeds twenty percent (20%) per any Method 9 observations 

referenced above, the Permittee shall notify IDEM, if the Permittee 

anticipates that operations will continue for ten (10) days or more 

before the 

failed baghouse units will be repaired or replaced. 

the Permittee shall take reasonable response steps in accordance with 

Section C – Response to 

Excursions and Exceedances. Abnormal emissions alone are not a deviation 

from this permit. 

Failure to take the response steps required by Condition D.5.7(c) upon 

observation of visible 

emissions in accordance with Section C - Response to Excursions and 

Exceedances, shall be 

considered a deviation from this permit. 
Change No. 7 

Consistent with a stay agreement between IDEM and Alcoa Inc. Warrick 

Operation on June 5, 2007, 

conditions related to parametric monitoring and failed and broken 

baghouse detection have been removed 

from the permit. Record keeping conditions have also been updated to 

reflect this change. 

D.1.8 Parametric Monitoring 

The Permittee shall record the pressure drops across Airveyor No. 1 

Baghouse, Airveyor No. 2 

Baghouse, Building 60 Aspiration Baghouse, Transfer Tower 61A Baghouse, 

Tank 62 Baghouse, 

Baghouse BC-24 (Tank 62 baghouse, ground level), Transfer Tower 61B 

Baghouse, Building 140 

Baghouse, 104A Passageway Baghouse, Baghouse 144A, 160M.2 Bin Vent 

Baghouse, Airslide 

B2 Baghouse, Airslide C1 Baghouse, Tank 141A(NE) Baghouse, Airslide B5 

Baghouse, Airslide 

B6 Baghouse, used in conjunction with the facilities at least once per 

day when the processes are 

in operation. When for any one reading, the pressure drop across the 

baghouse is outside the 

normal range of 3.0 and 6.0 inches of water or a range established during 

the latest stack test, the 
Alcoa Inc. Warrick Operations Page 19 of 25 

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Permit Reviewer: Jillian Bertram 

Permittee shall take reasonable response steps in accordance with Section 

C- Response to 

Excursions and Exceedances. A pressure reading that is outside the above 

mentioned range is 

not a deviation from this permit. Failure to take response steps in 

accordance with Section C –

Response to Excursions and Exceedances, shall be considered a deviation 

from this permit. 

The instrument used for determining the pressure shall comply with 

Section C - Instrument 

Specifications, of this permit, shall be subject to approval by IDEM, OAQ 

and shall be calibrated at 

least once every six (6) months. 

D.1.9 Broken or Failed Bag Detection except Baghouse 112A and Baghouse 

166 [326 IAC 2-7-5(3)] 

(a) For a single compartment baghouse controlling emissions from a 

process operated 

continuously, a baghouse with failed bags and the associated process 

shall be shut down 

immediately until the failed bag(s) have been repaired or replaced. 

Operations may 

continue only if the event qualifies as an emergency and the Permittee 

satisfies the 

requirements of the emergency provisions of this permit (Section B -

Emergency 

Provisions). 

(c) For a single compartment baghouse controlling emissions from a batch 

process, the feed 

to the process shall be shut down immediately until the failed bags have 

been repaired or 

replaced. The emissions unit shall be shut down no later than the 

completion of the 

processing of the material in the line. Operations may continue only if 

the event qualifies 

as an emergency and the Permittee satisfies the requirements of the 

emergency 

provisions of this permit (Section B - Emergency Provisions). 

D.1.108 Record Keeping Requirements 

*** 

(f) To document compliance with Condition D.1.87, the Permittee shall 

maintain records of 

Method 9 readings the pressure drop. The Permittee shall include in its 

daily record 

when a pressure drop reading is not taken and the reason for the lack of 

the pressure 

drop reading (e.g. the process did not operate that day). 

(g) The Permittee shall maintain the following as required under 

Conditions D.1.3, D.1.5, 

D.1.6, and D.1.7, D.1.8, and D.1.9: 

*** 
D.2.7 Particulate Control [326 IAC 2-7-6(6)] 

*** 

(b) In order to comply with Condition D.2.1, the PM emissions from the 

following facilities 

shall be controlled by the baghouses as indicated in the table below. 

Each baghouse shall 

be in operation and control emissions from its associated facilities at 

all times when an 

emission unit that the baghouse controls is in operation; and 

Facility Baghouse 

Pot Digging Pot Digging Baghouse 

Crucible Digging Crucible Digging Baghouse 

Potline Bath Crushing and 

Tanks 110H-A, 110H-B, 

110H-C, and 110H-D 

Potline Bath Crusher 

Baghouse 
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Permit Reviewer: Jillian Bertram 

(1) In the event that bag failure is observed in a multi-compartment 

baghouse, if 

operations will continue for ten (10) days or more after the failure is 

observed 

before the failed units will be repaired or replaced, the Permittee shall 

promptly 

notify IDEM, OAQ of the expected date the failed units will be repaired 

or 

replaced. The notification shall also include the status of the 

applicable 

compliance monitoring parameters with respect to normal, and the results 

of any 

response actions taken up to the time of notification. The Permittee 

shall not 

operate the failed compartment until the failed bags are repaired or 

replaced. 

*** 

D.2.16 Parametric Monitoring 

(a) The Permittee shall record the pressure drop across the Pot Line Bath 

Crusher baghouse, 

used in conjunction with the Pot Line Bath Crusher at least once per day 

when the Pot 

Line Bath Crusher is in operation. When for any one reading, the pressure 

drop across 

the baghouse is outside the normal range of 3.0 and 6.0 inches of water 

or a range 

established during the latest stack test, the Permittee shall take 

reasonable response 

steps in accordance with Section C – Response to Excursions or 

Exceedances. A 

pressure reading that is outside the above mentioned range or set point 

is not a deviation 

from this permit. Failure to take response steps in accordance with 

Section C – Response 

to Excursions or Exceedances shall be considered a deviation from this 

permit. 

(b) The instrument used for determining the pressure shall comply with 

Section C –

Instrument Specifications, of this permit, shall be subject to approval 

by IDEM, OAQ, and 

shall be calibrated at least once every six (6) months. 

D.2.17 Broken or Failed Bag Detection [326 IAC 2-7-5(3)] 

For a single compartment baghouse controlling emissions from a process 

operated continuously, 

a baghouse with failed bags and the associated process shall be shut down 

immediately until the 

failed bag(s) have been repaired or replaced. Operations may continue 

only if the event qualifies 

as an emergency and the Permittee satisfies the requirements of the 

emergency provisions of this 
permit (Section B – Emergency Provisions). 

*** 

D.2.186 Record Keeping Requirements 

*** 

(d) The Permittee shall maintain daily records of Method 9 readings, as 

required by 

Condition D.2.15 of the pressure drop during normal operation as required 

by Condition 

D.2.16. The Permittee shall include in its daily record when a pressure 

drop record is not 

taken and the reason for the lack of a pressure drop record (e.g. the 

process did not 

operate that day). 

(e) The Permittee shall maintain the following as required under 

Conditions D.2.15, D.2.16, 

and D.2.17: 

(1) Documentation of all response steps implemented per event. 

(f) All records shall be maintained in accordance with Section C –

General Record Keeping 

Requirements, of this permit. 

*** 

D.3.11 Parametric Monitoring 

(a) The Permittee shall record the pressure drop across DC-218, DC-153, 

DCF-221A, 

DCF-221B, and Check-Weigh Scale baghouses, used in conjunction with the 

facilities at 

least once per day when the processes are in operation. When for any one 

reading, the 

pressure drop across the baghouse is outside the normal range of 3.0 and 

6.0 inches of 
Alcoa Inc. Warrick Operations Page 21 of 25 

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Permit Reviewer: Jillian Bertram 

water or a range established during the latest stack test, the Permittee 

shall take 

reasonable response steps in accordance with Section C – Response to 

Excursions or 

Exceedances. A pressure reading that is outside the above mentioned range 

is not a 

deviation from this permit. Failure to take response steps in accordance 

with Section C –

Response to Excursions or Exceedances shall be considered a deviation 

from this permit. 

(b) The instrument used for determining the pressure shall comply with 

Section C –

Instrument Specifications, of this permit, shall be subject to approval 

by IDEM, OAQ and 

shall be calibrated at least once every six (6) months. 

D.3.12 Broken or Failed Bag Detection 

For a single compartment baghouse controlling emissions from a process 

operated continuously, 

a failed unit and the associated process shall be shut down immediately 

until the failed unit has 

been repaired or replaced. Operations may continue only if the event 

qualifies as an emergency 

and the Permittee satisfies the requirements of the emergency provisions 

of this permit (Section B 

– Emergency Provisions). 

Bag failure can be indicated by a significant drop in the baghouse’s 

pressure reading with 

abnormal visible emissions, by an opacity violation, or by other means 

such as gas temperature, 

flow rate, air infiltration, or leaks. 

Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-

7-19] [326 IAC 20-1] 

[40 CFR 63, Subpart A] [326 IAC 20-24] [40 CFR 63.850] 

D.3.131 Record Keeping Requirements 

*** 

(e) To document compliance with Condition D.3.110, the Permittee shall 

maintain records of 

Method 9 readings. the daily pressure drop of the baghouses during normal 

operation. 

The Permittee shall include in its daily record when a pressure drop 

record is not taken 

and the reason for the lack of a pressure drop record (e.g. the process 

did not operate 

that day). 

(f) The Permittee shall maintain documentation of all response steps 

implemented per event 

as required under Conditions D.3.10, D.3.11, and D.3.12. 

*** 

D.4.19 Parametric Monitoring 
(a) The Permittee shall record the pressure drop across baked anode 

vacuum system 

baghouses, used in conjunction with the facilities at least once per day 

when the 

processes are in operation. When for any one reading, the pressure drop 

across the 

baghouse is outside the normal range of 3.0 and 6.0 inches of water or a 

range 

established during the latest stack test, the Permittee shall take 

reasonable response 

steps in accordance with Section C – Response to Excursions or 

Exceedances. A 

pressure reading that is outside the above mentioned range is not a 

deviation from this 

permit. Failure to take response steps in accordance with Section C –

Response to 

Excursions or Exceedances shall be considered a deviation from this 

permit. 

(b) The instrument used for determining the pressure shall comply with 

Section C –

Instrument Specifications, of this permit, shall be subject to approval 

by IDEM, OAQ and 

shall be calibrated at least once every six (6) months. 
Alcoa Inc. Warrick Operations Page 22 of 25 

Newburgh, Indiana TSD for Significant Permit Modification No.: 173-29035-

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Permit Reviewer: Jillian Bertram 

D.4.20 Broken or Failed Bag Detection [326 IAC 2-7-5(3)] 

For a single compartment baghouse controlling emissions from a process 

operated continuously, 

a baghouse with failed bags and the associated process shall be shut down 

immediately until the 

failed bag(s) have been repaired or replaced. Operations may continue 

only if the event qualifies 

as an emergency and the Permittee satisfies the requirements of the

emergency provisions of this 

permit (Section B – Emergency Provisions). 

Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-

7-19] [326 IAC 12] 

[40 CFR 60 Subpart S] [326 IAC 20-1] [40 CFR 63, Subpart A] [326 IAC 20-

24] [40 CFR 63.850] 

D.4.2119Record Keeping Requirements 

*** 

(h) To document compliance with Condition D.4.198, the Permittee shall 

maintain records of 

Method 9 readings. the daily pressure drop of the baked anode vacuum 

system 

baghouse during normal operation. The Permittee shall include in its 

daily record when a 

pressure drop record is not taken and the reason for the lack of a 

pressure drop record 

(e.g. the process did not operate that day). 

(i) The Permittee shall maintain the following as required under 

Conditions D.4.10 and 

D.4.18, D.4.19, and D.4.20: 

*** 

D.5.8 Parametric Monitoring 

(a) The Permittee shall record the pressure drops across the Tumbleblast 

Baghouse, and 

Impactor Baghouse, used in conjunction with the facilities at least once 

per day when the 

processes are in operation. When for any one reading, the pressure drop 

across the 

baghouse is outside the normal range of 2 to 5, and 3 to 6 inches of 

water, respectively, 

or the ranges established during the latest stack tests, the Permittee 

shall take reasonable 

response steps in accordance with Section C- Response to Excursions and 

Exceedances. A pressure reading that is outside the above mentioned range 

is not a 

deviation from this permit. Failure to take response steps in accordance 

with Section C –

Response to Excursions and Exceedances, and Reports, shall be considered 

a deviation 

from this permit. 

(b) The instrument used for determining the pressure shall comply with 

Section C -
Instrument Specifications, of this permit, shall be subject to approval 

by IDEM, OAQ and 

shall be calibrated at least once every six (6) months. 

D.5.9 Broken or Failed Bag Detection 

(a) For a single compartment baghouse controlling emissions from a 

process operated 

continuously, a failed unit and the associated process shall be shut down 

immediately 

until the failed unit has been repaired or replaced. Operations may 

continue only if the 

event qualifies as an emergency and the Permittee satisfies the 

requirements of the 

emergency provisions of this permit (Section B - Emergency Provisions). 

(b) For a single compartment baghouse controlling emissions from a batch 

process, the feed 

to the process shall be shut down immediately until the failed unit has 

been repaired or 

replaced. The emissions unit shall be shut down no later than the 

completion of the 

processing of the material in the line. Operations may continue only if 

the event qualifies 

as an emergency and the Permittee satisfies the requirements of the 

emergency 

provisions of this permit (Section B - Emergency Provisions). 

Bag failure can be indicated by a significant drop in the baghouse’s 

pressure reading with 

abnormal visible emissions, by an opacity violation, or by other means 

such as gas temperature, 

flow rate, air infiltration, and leaks. 
Alcoa Inc. Warrick Operations Page 23 of 25 

Newburgh, Indiana TSD for Significant Permit Modification No.: 173-29035-

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Permit Reviewer: Jillian Bertram 

Record Keeping and Reporting Requirement [326 IAC 2-7-5(3)] [326 IAC 2-7-

19] 

D.5.108 Record Keeping Requirements 

*** 

(e) To document compliance with Condition D.5.87, the Permittee shall 

maintain daily records 

of Method 9 readings the pressure drop of the baghouses during normal 

operation. The 

Permittee shall include in its daily record when a pressure drop record 

is not taken and 

the reason for the lack of a pressure drop record (e.g. the process did 

not operate that 

day). 

(f) The Permittee shall maintain the following as required under 

Conditions D.5.5, D.5.6, and 

D.5.7, D.5.8, and D.5.9: 

Change No. 8 

There is no EPA test method available to properly test SO2 emissions from 

the potlines, therefore, IDEM 

has agreed to allow the source to use material balance, as opposed to 

stack testing, to demonstrate 

compliance with Condition D.2.2, 

D.2.8 SO2 Emissions Determination [326 IAC 7-4-10 (b) and (c)] 

(a) Pursuant to 326 IAC 7-4-10(b), Compliance with SO2 pounds per hour 

limitation shall be 

based on material balance data and shall include the supporting 

information upon 

which the material balance data is based a stack test pursuant to 326 IAC 

7-2-1(b). 

(d) Pursuant to 326 IAC 7-4-10(c), compliance with the tons per year 

limitations of SO2 shall 

be based on a rolling twelve (12) consecutive month emission total. The 

monthly SO2 

emissions shall be determined from calendar month material balances using 

actual 

average sulfur content and material throughput. 

*** 

D.2.10 Testing [326 IAC 7-10-4(b)] [326 IAC 12] [40 CFR 60 Subpart S] 

[326 IAC 20-1] 

[40 CFR 63, Subpart A] [326 IAC 20-24] [40 CFR 63.847] 

(a) In order to comply with Condition D.2.8, and no later than January 5, 

2010 or 5 years from 

the date of the last valid compliance test, whichever is later, the 

Permittee shall perform 

SO2 testing for the Potlines Nos.1, 2, 3, 4, 5, and 6, utilizing methods 

as approved by the 

Commissioner or shall obtain approval allowing material balance 

calculations in lieu of 

stack testing. These tests shall be repeated at least once every five (5) 

years from the 
date of the valid compliance demonstration, unless IDEM determines that 

material 

balance calculations are a satisfactory demonstration of compliance. 

Testing shall be 

conducted in accordance with Section C - Performance Testing. 

(b)(a) Pursuant to 40 CFR 63.847(b), the Permittee shall prepare a site 

specific test plan prior to 

the performance test according to the requirements of 40 CFR 67.7(c). The 

test plan shall 

include procedures for conducting the performance tests required in 40 

CFR 63.848 for 

emission monitoring. In addition to the information required by 40 CFR 

63.7, the test plan 

shall include: 

(1) Procedures to ensure a minimum of three runs are performed annually 

for the 

primary control system for each emission unit; 

(2) For a source with a single control device exhausted through multiple 

stacks, 

procedures to ensure that at least three runs are performed annually by a 

representative sample of the stacks satisfactory to IDEM, OAQ; 
Alcoa Inc. Warrick Operations Page 24 of 25 

Newburgh, Indiana TSD for Significant Permit Modification No.: 173-29035-

00007 

Permit Reviewer: Jillian Bertram 

(3) For multiple control devices on a single source, procedures to ensure 

that at least 

one run is performed annually for each control device by a representative 

sample 

of the stacks satisfactory to IDEM, OAQ; and 

(4) Procedures for establishing the frequency of testing to ensure that 

at least one 

run is performed before the 15th of the month, at least one run is 

performed after 

the 15th of the month, and that there are at least 6 days between two of 

the runs 

during the month, or that secondary emissions are measured according to 

an 

alternate schedule satisfactory to IDEM, OAQ. 

(c)(b) Pursuant to 40 CFR 63.847(d), all performance tests shall be 

conducted in accordance 

with the requirements of the general provisions in Subpart A of 40 CFR 

63, the approved 

test plan, and the procedures in this section. 

(1) For each potline except potline 1, the Permittee shall measure and 

record the 

emission rate of TF exiting the outlet of the primary control system for 

each 

potline and the rate of secondary emissions exiting through each roof 

monitor. 

Using the equation in paragraph 40 CFR 63.847(e)(1) given below, the 

Permittee 

shall compute and record the average of at least three runs each month 

for 

secondary emissions and at least three runs each year for the primary 

control 

system to meet the emission limit in condition D.2.4; 

Equation to compute the emission rate (Ep) of TF from each potline: 

Where: 

.. . . . . 

. . .Eq.1. 

P K 

C Q C Q 

E s1 sd 1 s2 sd 2 

p . 

. . . 

. 

Ep = emission rate of TF from a potline, kg/Mg (lb/ton); 

Cs1 = concentration of TF from the primary control system, mg/dscf; 

Qsd = volumetric flow rate of effluent gas corresponding to the 

appropriate subscript location, dscf/hr; 

Cs2 = concentration of TF as measured for roof monitor emissions, 

mg/dscf; 

P = aluminum production rate, ton/hr; 

K = conversion factor, 453,600 mg/lb; 
1 = subscript for primary control system effluent gas; and 

2 = subscript for secondary control system or roof monitor effluent 

gas. 

(2) If the Permittee has performed more than one test of primary emission 

control 

device for a potline during the previous consecutive twelve month, 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; 

(3) Determine the weight of the aluminum tapped from the potline using 

the 

monitoring devices as required in Condition D.2.11(c); and 

(4) Determine the aluminum production rate (P) by dividing the number of 

hours in 

the calendar month into the weight of aluminum tapped from the potline 

during the 

calendar month that includes the three runs of a performance test. . 

Change No. 9 

At the source’s request, Condition D.1.5(b) has been changed to trigger 

bag leak investigation at 50% of 

the permit limit, as opposed to a grain loading rate. The condition has 

also been changed to only include 

detection of PM emissions because the sensor only detects PM. 
Alcoa Inc. Warrick Operations Page 25 of 25 

Newburgh, Indiana TSD for Significant Permit Modification No.: 173-29035-

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Permit Reviewer: Jillian Bertram 

D.1.5 Bag Leak Detection System 

*** 

(b) The Permittee shall establish alarms representative of 50% of the 

combined permit 

limit for both bag leak detection systems such that an initial 

investigation alarm shall be 

activated for Baghouse 112A, whenever PM and/or PM10 emissions from Stack 

112A.1 

are greater than or equal to 0.003 grains per dry standard cubic foot, 

equivalent to greater 

than or equal to 0.692 1.35 pounds of PM and/or PM10 per hour; and for

Baghouse 166, 

whenever PM and/or PM10 emissions from Stack 166.1 are greater than or 

equal to 

0.0115 grains per dry standard cubic foot, equivalent to greater than or 

equal to 0.69 1.47 

pounds of PM and/or PM10 per hour. 

Failure to comply with the requirements in paragraph (b) of this 

condition shall be 

considered a deviation from this permit; 

Conclusion and Recommendation 

The operation of this proposed modification shall be subject to the 

conditions of the attached 

proposed Part 70 Significant Permit Modification No. 173-29035-00007. The 

staff recommends to 

the Commissioner that this Part 70 Significant Permit Modification be 

approved. 

IDEM Contact 

(a) Questions regarding this proposed permit can be directed to Jillian 

Bertram at the Indiana 

Department Environmental Management, Office of Air Quality, Permits 

Branch, 100 North Senate 

Avenue, MC 61-53 IGCN 1003, Indianapolis, Indiana 46204-2251 or by 

telephone at (317)233-

1782 or toll free at 1-800-451-6027 extension 3-1782. 

(b) A copy of the findings is available on the Internet at: 

http://www.in.gov/ai/appfiles/idem-caats/ 

(c) For additional information about air permits and how the public and 

interested parties can 

participate, refer to the IDEM’s Guide for Citizen Participation and 

Permit Guide on the Internet at: 

www.idem.in.gov 
Indiana Department of Environmental Management 

Office of Air Quality 

Addendum to the Technical Support Document (ATSD) for a 

Part 70 Significant Permit Modification 

Source Background and Description 

Source Name: Alcoa Inc. Warrick Operations 

Source Location: Jct. IN Hwy. 66 and 61, Newburgh, IN 47629 

County: Warrick 

SIC Code: 3352, 3334 

Operation Permit No.: T173-6627-00007 

Operation Permit Issuance Date: January 5, 2007 

Significant Permit Modification No.: T173-29035-00007 

Permit Reviewer: Jillian Bertram 

On July 8, 2010, the Office of Air Quality (OAQ) had a notice published 

in Boonville Standard, Boonville, 

Indiana, stating that Alcoa Inc. Warrick Operations had applied for a 

significant permit modification relating 

to relating to the replacement of existing pots in Line 1 with research 

pots and increase in flow to Airslide 

B6 Baghouse. The notice also stated that the OAQ proposed to issue a 

significant permit modificationfor 

this operation and provided information on how the public could review 

the proposed permit and other 

documentation. Finally, the notice informed interested parties that there 

was a period of thirty (30) days to 

provide comments on whether or not this permit should be issued as 

proposed. 

Additional Changes 

(a) It has been determined that a significant source modification 

approval is necessary for the 

proposed changes. This language is to correct statements in the TSD. 

There are no 

changes to the permit. 

The following table is used to determine the appropriate permit level 

under 326 IAC 2-7-10.5. This 

table reflects the PTE before controls. Control equipment is not 

considered federally enforceable 

until it has been required in a federally enforceable permit. 

PTE Before Controls of the Modified Units 

Pollutant Potential To Emit (ton/yr) 

PM 174.70 

PM10 98.40 

PM2.5 108.97 

SO2 0.00 

VOC 0.00 

CO 0.00 

NOX 0.34 

Single HAPs (HF) 0 

Combined HAPs (HF) 0 

Appendix A of this TSD reflects the unrestricted potential emissions of 

the modification. 
Alcoa Inc. Warrick Operations Page 2 of 2 

Newburgh, Indiana ATSD for SPM No. 173-29035-00007 

Permit Reviewer: Jillian Bertram 

This source modification is subject to 326 IAC 2-7-10.5(f)(4) because the 

potential to emit PM, 

PM10, and PM2.5 from the new units is greater than twenty-five (25) tons 

per year. Additionally, 

The changes will be incorporated into the permit as a Significant Permit 

Modification under 326

IAC 2-7-12(d) because it requires a case-by-case determination of an 

emission limitation or 

standard. 

IDEM Contact 

(a) Questions regarding this proposed SPM can be directed to Jillian 

Bertram at the Indiana 

Department Environmental Management, Office of Air Quality, Permits 

Branch, 100 North Senate 

Avenue, MC 61-53 IGCN 1003, Indianapolis, Indiana 46204-2251 or by 

telephone at (317)233-

1782 or toll free at 1-800-451-6027 extension 3-1782. 

(b) A copy of the permit is available on the Internet at: 

http://www.in.gov/ai/appfiles/idem-caats/ 

(c) For additional information about air permits and how the public and 

interested parties can 

participate, refer to the IDEM’s Guide for Citizen Participation and 

Permit Guide on the Internet at: 

www.idem.in.gov 
Part 70 Operating Permit 

OFFICE OF AIR QUALITY 

Alcoa Inc. - Warrick Operations 

Jct. IN Hwys 66 & 61 

Newburgh, IN 47629-0010 

Attachment A 

Title 40: Protection of Environment 

Part 63 - National Emission Standards for Hazardous Air 

Pollutants 

Subpart EEEE—Organic Liquids Distribution (Non-Gasoline) 

T173-6627-00007 
Alcoa Inc. – Warrick Operations Significant Source Modification No. 173-

29096-00007 Page 2 of 22 

Newburgh, Indiana Significant Permit Modification No. 173-29035-00007 

T173-6627-00007 

Permit Reviewer: Jillian Bertram 

Title 40: Protection of Environment 

PART 63—NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS FOR 

SOURCE 

CATEGORIES 

Browse Previous | Browse Next 

Subpart XXXXXX—National Emission Standards for Hazardous Air Pollutants 

Area Source 

Standards for Nine Metal Fabrication and Finishing Source Categories 

Source: 73 FR 43000, July 23, 2008, unless otherwise noted. 

Applicability and Compliance Dates 

§ 63.11514 Am I subject to this subpart? 

(a) You are subject to this subpart if you own or operate an area source 

that is primarily engaged in the 

operations in one of the nine source categories listed in paragraphs 

(a)(1) through (9) of this section. 

Descriptions of these source categories are shown in Table 1 of this 

subpart. ―Primarily engaged‖ is defined 

in §63.11522, ―What definitions apply to this subpart?‖ 

(1) Electrical and Electronic Equipment Finishing Operations; 

(2) Fabricated Metal Products; 

(3) Fabricated Plate Work (Boiler Shops); 

(4) Fabricated Structural Metal Manufacturing; 

(5) Heating Equipment, except Electric; 

(6) Industrial Machinery and Equipment Finishing Operations; 

(7) Iron and Steel Forging; 

(8) Primary Metal Products Manufacturing; and 

(9) Valves and Pipe Fittings. 

(b) The provisions of this subpart apply to each new and existing 

affected source listed and defined in 

paragraphs (b)(1) through (5) of this section if you use materials that 

contain or have the potential to emit 

metal fabrication or finishing metal HAP (MFHAP), defined to be the 

compounds of cadmium, chromium, 

lead, manganese, and nickel, or any of these metals in the elemental form 

with the exception of lead. 

Materials that contain MFHAP are defined to be materials that contain 

greater than 0.1 percent for 

carcinogens, as defined by OSHA at 29 CFR 1910.1200(d)(4), and greater 

than 1.0 percent for 

noncarcinogens. For the MFHAP, this corresponds to materials that contain 

cadmium, chromium, lead, or 

nickel in amounts greater than or equal to 0.1 percent by weight (of the 

metal), and materials that contain 

manganese in amounts greater than or equal to 1.0 percent by weight (of 

the metal), as shown in 

formulation data provided by the manufacturer or supplier, such as the 

Material Safety Data Sheet for the 

material. 
(1) A dry abrasive blasting affected source is the collection of all 

equipment and activities necessary to 

perform dry abrasive blasting operations which use materials that contain 

MFHAP or that have the potential 

to emit MFHAP. 
Alcoa Inc. – Warrick Operations Significant Source Modification No. 173-

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Newburgh, Indiana Significant Permit Modification No. 173-29035-00007 

T173-6627-00007 

Permit Reviewer: Jillian Bertram 

(2) A machining affected source is the collection of all equipment and 

activities necessary to perform 

machining operations which use materials that contain MFHAP, as defined 

in §63.11522, ―What definitions 

apply to this subpart?‖, or that have the potential to emit MFHAP. 

(3) A dry grinding and dry polishing with machines affected source is the 

collection of all equipment and 

activities necessary to perform dry grinding and dry polishing with 

machines operations which use materials 

that contain MFHAP, as defined in §63.11522, ―What definitions apply to 

this subpart?‖, or have the potential 

to emit MFHAP. 

(4) A spray painting affected source is the collection of all equipment 

and activities necessary to perform 

spray-applied painting operations using paints which contain MFHAP. A 

spray painting affected source 

includes all equipment used to apply cleaning materials to a substrate to 

prepare it for paint application 

(surface preparation) or to remove dried paint; to apply a paint to a

substrate (paint application) and to dry or 

cure the paint after application; or to clean paint operation equipment 

(equipment cleaning). Affected 

source(s) subject to the requirements of this paragraph are not subject 

to the miscellaneous surface coating 

provisions of subpart HHHHHH of this part, ―National Emission Standards 

for Hazardous Air Pollutants: 

Paint Stripping and Miscellaneous Surface Coating Operations at Area 

Sources.‖ 

(5) A welding affected source is the collection of all equipment and 

activities necessary to perform welding 

operations which use materials that contain MFHAP, as defined in 

§63.11522, ―What definitions apply to this 

subpart?‖, or have the potential to emit MFHAP. 

(c) An affected source is existing if you commenced construction or 

reconstruction of the affected source, as 

defined in §63.2, ―General Provisions‖ to part 63, before April 3, 2008. 

(d) An affected source is new if you commenced construction or 

reconstruction of the affected source, as 

defined in §63.2, ―General Provisions‖ to part 63, on or after April 3, 

2008. 

(e) This subpart does not apply to research or laboratory facilities, as 

defined in section 112(c)(7) of the 

Clean Air Act (CAA). 

(f) This subpart does not apply to tool or equipment repair operations, 

facility maintenance, or quality control 

activities as defined in §63.11522, ―What definitions apply to this 

subpart?‖ 

(g) This subpart does not apply to operations performed on site at 

installations owned or operated by the 
Armed Forces of the United States (including the Coast Guard and the 

National Guard of any such state), 

the National Aeronautics and Space Administration, or the National 

Nuclear Security Administration. 

(h) This subpart does not apply to operations that produce military 

munitions, as defined in §63.11522, 

―What definitions apply to this subpart?‖, manufactured by or for the 

Armed Forces of the United States 

(including the Coast Guard and the National Guard of any such state), or 

equipment directly and exclusively 

used for the purposes of transporting military munitions. 

(i) You are exempt from the obligation to obtain a permit under 40 CFR 

part 70 or 40 CFR part 71, provided 

you are not otherwise required by law to obtain a permit under 40 CFR 

70.3(a) or 40 CFR 71.3(a). 

Notwithstanding the previous sentence, you must continue to comply with 

the provisions of this subpart. 

§ 63.11515 What are my compliance dates? 

(a) If you own or operate an existing affected source, you must achieve 

compliance with the applicable 

provisions in this subpart by July 25, 2011. 

(b) If you own or operate a new affected source, you must achieve 

compliance with the applicable provisions 

in this subpart by July 23, 2008, or upon startup of your affected 

source, whichever is later. 

Standards and Compliance Requirements 
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§ 63.11516 What are my standards and management practices? 

(a) Dry abrasive blasting standards. If you own or operate a new or 

existing dry abrasive blasting affected 

source, you must comply with the requirements in paragraphs (a)(1) 

through (3) of this section, as 

applicable, for each dry abrasive blasting operation that uses materials 

that contain MFHAP, as defined in 

§63.11522, ―What definitions apply to this subpart?‖, or has the 

potential to emit MFHAP. These 

requirements do not apply when abrasive blasting operations are being 

performed that do not use any 

materials containing MFHAP or do not have the potential to emit MFHAP. 

(1) Standards for dry abrasive blasting of objects performed in totally 

enclosed and unvented blast 

chambers. If you own or operate a new or existing dry abrasive blasting 

affected source which consists of an 

abrasive blasting chamber that is totally enclosed and unvented, as 

defined in §63.11522, ―What definitions 

apply to this subpart?‖, you must implement management practices to 

minimize emissions of MFHAP. 

These management practices are the practices specified in paragraph 

(a)(1)(i) and (ii) of this section. 

(i) You must minimize dust generation during emptying of abrasive 

blasting enclosures; and 

(ii) You must operate all equipment associated with dry abrasive blasting 

operations according to the 

manufacturer's instructions. 

(2) Standards for dry abrasive blasting of objects performed in vented 

enclosures. If you own or operate a 

new or existing dry abrasive blasting affected source which consists of a 

dry abrasive blasting operation 

which has a vent allowing any air or blast material to escape, you must 

comply with the requirements in 

paragraphs (a)(2)(i) and (ii) of this section. Dry abrasive blasting 

operations for which the items to be blasted 

exceed 8 feet (2.4 meters) in any dimension, may be performed subject to 

the requirements in paragraph 

(a)(3) of this section. 

(i) You must capture emissions and vent them to a filtration control 

device. You must operate the filtration 

control device according to manufacturer's instructions, and you must 

demonstrate compliance with this 

requirement by maintaining a record of the manufacturer's specifications 

for the filtration control devices, as 

specified by the requirements in §63.11519(c)(4), ―What are my 

notification, recordkeeping, and reporting 

requirements?‖ 

(ii) You must implement the management practices to minimize emissions of 

MFHAP as specified in 
paragraphs (a)(2)(ii)(A) through (C) of this section. 

(A) You must take measures necessary to minimize excess dust in the 

surrounding area to reduce MFHAP 

emissions, as practicable; and 

(B) You must enclose dusty abrasive material storage areas and holding 

bins, seal chutes and conveyors 

that transport abrasive materials; and 

(C) You must operate all equipment associated with dry abrasive blasting 

operations according to 

manufacturer's instructions. 

(3) Standards for dry abrasive blasting of objects greater than 8 feet 

(2.4 meters) in any one dimension. If 

you own or operate a new or existing dry abrasive blasting affected 

source which consists of a dry abrasive 

blasting operation which is performed on objects greater than 8 feet (2.4 

meters) in any one dimension, you 

may implement management practices to minimize emissions of MFHAP as 

specified in paragraph (a)(3)(i) 

of this section instead of the practices required by paragraph (a)(2) of 

this section. You must demonstrate 

that management practices are being implemented by complying with the 

requirements in paragraphs 

(a)(3)(ii) through (iv) of this section. 

(i) Management practices for dry abrasive blasting of objects greater 

than 8 feet (2.4 meters) in any one 

dimension are specified in paragraphs (a)(3)(i)(A) through (E) of this 

section. 
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(A) You must take measures necessary to minimize excess dust in the 

surrounding area to reduce MFHAP 

emissions, as practicable; and 

(B) You must enclose abrasive material storage areas and holding bins, 

seal chutes and conveyors that 

transport abrasive material; and 

(C) You must operate all equipment associated with dry abrasive blasting 

operations according to 

manufacturer's instructions; and 

(D) You must not re-use dry abrasive blasting media unless contaminants

(i.e., any material other than the 

base metal, such as paint residue) have been removed by filtration or 

screening, and the abrasive material 

conforms to its original size; and 

(E) Whenever practicable, you must switch from high particulate matter 

(PM)-emitting blast media (e.g., 

sand) to low PM-emitting blast media (e.g., crushed glass, specular 

hematite, steel shot, aluminum oxide), 

where PM is a surrogate for MFHAP. 

(ii) You must perform visual determinations of fugitive emissions, as 

specified in §63.11517(b), ―What are my 

monitoring requirements?‖, according to paragraphs (a)(3)(ii)(A) or (B) 

of this section, as applicable. 

(A) For abrasive blasting of objects greater than 8 feet (2.4 meters) in 

any one dimension that is performed 

outdoors, you must perform visual determinations of fugitive emissions at 

the fenceline or property border 

nearest to the outdoor dry abrasive blasting operation. 

(B) For abrasive blasting of objects greater than 8 feet (2.4 meters) in 

any one dimension that is performed 

indoors, you must perform visual determinations of fugitive emissions at 

the primary vent, stack, exit, or 

opening from the building containing the abrasive blasting operations. 

(iii) You must keep a record of all visual determinations of fugitive 

emissions along with any corrective action 

taken in accordance with the requirements in §63.11519(c)(2), ―What are 

my notification, recordkeeping, and 

reporting requirements?‖ 

(iv) If visible fugitive emissions are detected, you must perform 

corrective actions until the visible fugitive 

emissions are eliminated, at which time you must comply with the 

requirements in paragraphs (a)(3)(iv)(A) 

and (B) of this section. 

(A) You must perform a follow-up inspection for visible fugitive 

emissions in accordance with §63.11517(a), 

―Monitoring Requirements.‖ 

(B) You must report all instances where visible emissions are detected, 

along with any corrective action 
taken and the results of subsequent follow-up inspections for visible 

emissions, with your annual certification 

and compliance report as required by §63.11519(b)(5), ―Notification, 

recordkeeping, and reporting 

requirements.‖ 

(b) Standards for machining. If you own or operate a new or existing 

machining affected source, you must 

implement management practices to minimize emissions of MFHAP as 

specified in paragraph (b)(1) and (2) 

of this section for each machining operation that uses materials that 

contain MFHAP, as defined in 

§63.11522, ―What definitions apply to this subpart?‖, or has the 

potential to emit MFHAP. These 

requirements do not apply when machining operations are being performed 

that do not use any materials 

containing MFHAP and do not have the potential to emit MFHAP. 

(1) You must take measures necessary to minimize excess dust in the 

surrounding area to reduce MFHAP 

emissions, as practicable; and 

(2) You must operate all equipment associated with machining according to 

manufacturer's instructions. 
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(c) Standards for dry grinding and dry polishing with machines. If you 

own or operate a new or existing dry 

grinding and dry polishing with machines affected source, you must comply 

with the requirements of 

paragraphs (c)(1) and (2) of this section for each dry grinding and dry 

polishing with machines operation that 

uses materials that contain MFHAP, as defined in §63.11522, ―What 

definitions apply to this subpart?‖, or 

has the potential to emit MFHAP. These requirements do not apply when dry 

grinding and dry polishing 

operations are being performed that do not use any materials containing 

MFHAP and do not have the 

potential to emit MFHAP. 

(1) You must capture emissions and vent them to a filtration control 

device. You must demonstrate 

compliance with this requirement by maintaining a record of the 

manufacturer's specifications for the 

filtration control devices, as specified by the requirements in 

§63.11519(c)(4), ―Notification, recordkeeping, 

and reporting Requirements.‖ 

(2) You must implement management practices to minimize emissions of 

MFHAP as specified in paragraphs 

(c)(2)(i) and (ii) of this section. 

(i) You must take measures necessary to minimize excess dust in the 

surrounding area to reduce MFHAP 

emissions, as practicable; 

(ii) You must operate all equipment associated with the operation of dry 

grinding and dry polishing with 

machines, including the filtration control device, according to 

manufacturer's instructions. 

(d) Standards for control of MFHAP in spray painting. If you own or 

operate a new or existing spray painting 

affected source, as defined in §63.11514 (b)(4), ―Am I subject to this 

subpart?,‖ you must implement the 

management practices in paragraphs (d)(1) through (9) of this section 

when a spray-applied paint that 

contains MFHAP is being applied. These requirements do not apply when 

spray-applied paints that do not 

contain MFHAP are being applied. 

(1) Standards for spray painting for MFHAP control. All spray-applied 

painting of objects must meet the 

requirements of paragraphs (d)(1)(i) through (iii) of this section. These 

requirements do not apply to affected 

sources located at Fabricated Structural Metal Manufacturing facilities, 

as described in Table 1, ―Description 

of Source Categories Affected by this Subpart,‖ or affected sources that 

spray paint objects greater than 15 

feet (4.57 meters), that are not spray painted in spray booths or spray 

rooms. 
(i) Spray booths or spray rooms must have a full roof, at least two 

complete walls, and one or two complete 

side curtains or other barrier material so that all four sides are 

covered. The spray booths or spray rooms 

must be ventilated so that air is drawn into the booth and leaves only 

though the filter. The roof may contain 

narrow slots for connecting fabricated products to overhead cranes, 

and/or for cords or cables. 

(ii) All spray booths or spray rooms must be fitted with a type of filter 

technology that is demonstrated to 

achieve at least 98 percent capture of MFHAP. The procedure used to 

demonstrate filter efficiency must be 

consistent with the American Society of Heating, Refrigerating, and AirConditioning Engineers (ASHRAE) 

Method 52.1, ―Gravimetric and Dust-Spot Procedures for Testing AirCleaning Devices Used in General 

Ventilation for Removing Particulate Matter, June 4, 1992‖ (incorporated 

by reference, see §63.14). The test 

coating for measuring filter efficiency shall be a high-solids bake 

enamel delivered at a rate of at least 135 

grams per minute from a conventional (non-High Volume Low Pressure) airatomized spray gun operating at 

40 psi air pressure; the air flow rate across the filter shall be 150 

feet per minute. Owners and operators may 

use published filter efficiency data provided by filter vendors to 

demonstrate compliance with this 

requirement and are not required to perform this measurement. 

(iii) You must perform regular inspection and replacement of the filters 

in all spray booths or spray rooms 

according to manufacturer's instructions, and maintain documentation of 

these activities, as detailed in 

§63.11519(c)(5), ―Notification, recordkeeping, and reporting 

requirements.‖ 

(iv) As an alternative compliance requirement, spray booths or spray 

rooms equipped with a water curtain, 

called ―waterwash‖ or ―waterspray‖ booths or spray rooms that are 

operated and maintained according to the 

manufacturer's specifications and that achieve at least 98 percent 

control of MFHAP, may be used in lieu of 

the spray booths or spray rooms requirements of paragraphs (d)(1)(i) 

through (iii) of this section. 
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(2) Standards for spray painting application equipment of all objects 

painted for MFHAP control. All paints 

applied via spray-applied painting must be applied with a high-volume, 

low-pressure (HVLP) spray gun, 

electrostatic application, airless spray gun, air-assisted airless spray 

gun, or an equivalent technology that is 

demonstrated to achieve transfer efficiency comparable to one of these 

spray gun technologies for a 

comparable operation, and for which written approval has been obtained 

from the Administrator. The 

procedure used to demonstrate that spray gun transfer efficiency is 

equivalent to that of an HVLP spray gun 

must be equivalent to the California South Coast Air Quality Management 

District's ―Spray Equipment 

Transfer Efficiency Test Procedure for Equipment User, May 24, 1989‖ and 

―Guidelines for Demonstrating 

Equivalency with District Approved Transfer Efficient Spray Guns, 

September 26, 2002‖, Revision 0 

(incorporated by reference, see §63.14). 

(3) Spray system recordkeeping. You must maintain documentation of the 

HVLP or other high transfer 

efficiency spray paint delivery methods, as detailed in §63.11519(c)(7), 

―Notification, recordkeeping, and 

reporting requirements.‖ 

(4) Spray gun cleaning. All cleaning of paint spray guns must be done 

with either non-HAP gun cleaning 

solvents, or in such a manner that an atomized mist of spray of gun 

cleaning solvent and paint residue is not 

created outside of a container that collects the used gun cleaning 

solvent. Spray gun cleaning may be done 

with, for example, by hand cleaning of parts of the disassembled gun in a 

container of solvent, by flushing 

solvent through the gun without atomizing the solvent and paint residue, 

or by using a fully enclosed spray 

gun washer. A combination of these non-atomizing methods may also be 

used.

(5) Spray painting worker certification. All workers performing painting 

must be certified that they have 

completed training in the proper spray application of paints and the 

proper setup and maintenance of spray 

equipment. The minimum requirements for training and certification are 

described in paragraph (d)(6) of this 

section. The spray application of paint is prohibited by persons who are 

not certified as having completed 

the training described in paragraph (d)(6) of this section. The 

requirements of this paragraph do not apply to 

the students of an accredited painting training program who are under the 

direct supervision of an instructor 
who meets the requirements of this paragraph. The requirements of this 

paragraph do not apply to operators 

of robotic or automated painting operations. 

(6) Spray painting training program content. Each owner or operator of an 

affected spray painting affected 

source must ensure and certify that all new and existing personnel, 

including contract personnel, who spray 

apply paints are trained in the proper application of paints as required 

by paragraph (d)(5) of this section. 

The training program must include, at a minimum, the items listed in 

paragraphs (d)(6)(i) through (iii) of this 

section. 

(i) A list of all current personnel by name and job description who are 

required to be trained; 

(ii) Hands-on, or in-house or external classroom instruction that 

addresses, at a minimum, initial and 

refresher training in the topics listed in paragraphs (d)(6)(ii)(A) 

through (D) of this section. 

(A) Spray gun equipment selection, set up, and operation, including 

measuring paint viscosity, selecting the 

proper fluid tip or nozzle, and achieving the proper spray pattern, air 

pressure and volume, and fluid delivery 

rate. 

(B) Spray technique for different types of paints to improve transfer 

efficiency and minimize paint usage and 

overspray, including maintaining the correct spray gun distance and angle 

to the part, using proper banding 

and overlap, and reducing lead and lag spraying at the beginning and end 

of each stroke. 

(C) Routine spray booth and filter maintenance, including filter 

selection and installation. 

(D) Environmental compliance with the requirements of this subpart. 

(iii) A description of the methods to be used at the completion of 

initial or refresher training to demonstrate, 

document, and provide certification of successful completion of the 

required training. Alternatively, owners 

and operators who can show by documentation or certification that a 

painter's work experience and/or 
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training has resulted in training equivalent to the training required in 

paragraph (d)(6)(ii) of this section are 

not required to provide the initial training required by that paragraph 

to these painters. 

(7) Records of spray painting training. You must maintain records of 

employee training certification for use of 

HVLP or other high transfer efficiency spray paint delivery methods as 

detailed in §63.11519(c)(8), 

―Notification, recordkeeping, and reporting requirements.‖ 

(8) Spray painting training dates. As required by paragraph (d)(5) of 

this section, all new and existing 

personnel at an affected spray painting affected source, including 

contract personnel, who spray apply 

paints must be trained by the dates specified in paragraphs (d)(8)(i) and 

(ii) of this section. 

(i) If your source is a new source, all personnel must be trained and 

certified no later than January 20, 2009, 

180 days after startup, or 180 days after hiring, whichever is later. 

Training that was completed within 5 

years prior to the date training is required, and that meets the 

requirements specified in paragraph (d)(6)(ii) 

of this section satisfies this requirement and is valid for a period not 

to exceed 5 years after the date the 

training is completed. 

(ii) If your source is an existing source, all personnel must be trained 

and certified no later than July 25, 

2011, or 180 days after hiring, whichever is later. Worker training that 

was completed within 5 years prior to 

the date training is required, and that meets the requirements specified 

in paragraph (d)(6)(ii) of this section, 

satisfies this requirement and is valid for a period not to exceed 5 

years after the date the training is 

completed. 

(9) Duration of training validity. Training and certification will be 

valid for a period not to exceed 5 years after 

the date the training is completed. All personnel must receive refresher 

training that meets the requirements 

of this section and be re-certified every 5 years. 

(e) [Reserved] 

(f) Standards for welding. If you own or operate a new or existing 

welding affected source, you must comply 

with the requirements in paragraphs (f)(1) and (2) of this section for 

each welding operation that uses 

materials that contain MFHAP, as defined in §63.11522, ―What definitions 

apply to this subpart?‖, or has the 

potential to emit MFHAP. If your welding affected source uses 2,000 

pounds or more per year of welding rod 

containing one or more MFHAP (calculated on a rolling 12-month basis), 

you must demonstrate that 
management practices or fume control measures are being implemented by 

complying with the 

requirements in paragraphs (f)(3) through (8) of this section. The 

requirements in paragraphs (f)(1) through 

(8) of this section do not apply when welding operations are being 

performed that do not use any materials 

containing MFHAP or do not have the potential to emit MFHAP. 

(1) You must operate all equipment, capture, and control devices 

associated with welding operations 

according to manufacturer's instructions. You must demonstrate compliance 

with this requirement by 

maintaining a record of the manufacturer's specifications for the capture 

and control devices, as specified by 

the requirements in §63.11519(c)(4), ―Notification, recordkeeping, and 

reporting requirements.‖ 

(2) You must implement one or more of the management practices specified 

in paragraphs (f)(2)(i) through 

(v) of this section to minimize emissions of MFHAP, as practicable, while 

maintaining the required welding 

quality through the application of sound engineering judgment. 

(i) Use welding processes with reduced fume generation capabilities 

(e.g., gas metal arc welding (GMAW)—

also called metal inert gas welding (MIG)); 

(ii) Use welding process variations (e.g., pulsed current GMAW), which 

can reduce fume generation rates; 

(iii) Use welding filler metals, shielding gases, carrier gases, or other 

process materials which are capable of 

reduced welding fume generation; 
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(iv) Optimize welding process variables (e.g., electrode diameter, 

voltage, amperage, welding angle, shield 

gas flow rate, travel speed) to reduce the amount of welding fume 

generated; and 

(v) Use a welding fume capture and control system, operated according to 

the manufacturer's specifications. 

(3) Tier 1 compliance requirements for welding. You must perform visual 

determinations of welding fugitive 

emissions as specified in §63.11517(b), ―Monitoring requirements,‖ at the 

primary vent, stack, exit, or 

opening from the building containing the welding operations. You must 

keep a record of all visual 

determinations of fugitive emissions along with any corrective action 

taken in accordance with the 

requirements in §63.11519(c)(2), ―Notification, recordkeeping, and 

reporting requirements.‖ 

(4) Requirements upon initial detection of visible emissions from 

welding. If visible fugitive emissions are 

detected during any visual determination required in paragraph (f)(3) of 

this section, you must comply with 

the requirements in paragraphs (f)(4)(i) and (ii) of this section. 

(i) Perform corrective actions that include, but are not limited to, 

inspection of welding fume sources, and 

evaluation of the proper operation and effectiveness of the management 

practices or fume control measures 

implemented in accordance with paragraph (f)(2) of this section. After 

completing such corrective actions, 

you must perform a follow-up inspection for visible fugitive emissions in 

accordance with §63.11517(a), 

―Monitoring Requirements,‖ at the primary vent, stack, exit, or opening 

from the building containing the 

welding operations. 

(ii) Report all instances where visible emissions are detected, along 

with any corrective action taken and the 

results of subsequent follow-up inspections for visible emissions, and 

submit with your annual certification 

and compliance report as required by §63.11519(b)(5), ―Notification, 

recordkeeping, and reporting 

requirements.‖ 

(5) Tier 2 requirements upon subsequent detection of visible emissions. 

If visible fugitive emissions are 

detected more than once during any consecutive 12 month period 

(notwithstanding the results of any followup 

inspections), you must comply with paragraphs (f)(5)(i) through (iv) of 

this section. 

(i) Within 24 hours of the end of the visual determination of fugitive 

emissions in which visible fugitive 

emissions were detected, you must conduct a visual determination of 

emissions opacity, as specified in 
§63.11517(c), ―Monitoring requirements,‖ at the primary vent, stack, 

exit, or opening from the building 

containing the welding operations. 

(ii) In lieu of the requirement of paragraph (f)(3) of this section to 

perform visual determinations of fugitive 

emissions with EPA Method 22, you must perform visual determinations of 

emissions opacity in accordance 

with §63.11517(d), ―Monitoring Requirements,‖ using EPA Method 9, at the 

primary vent, stack, exit, or 

opening from the building containing the welding operations. 

(iii) You must keep a record of each visual determination of emissions 

opacity performed in accordance with 

paragraphs (f)(5)(i) or (ii) of this section, along with any subsequent 

corrective action taken, in accordance 

with the requirements in §63.11519(c)(3), ―Notification, recordkeeping, 

and reporting requirements.‖ 

(iv) You must report the results of all visual determinations of 

emissions opacity performed in accordance 

with paragraphs (f)(5)(i) or (ii) of this section, along with any 

subsequent corrective action taken, and submit 

with your annual certification and compliance report as required by 

§63.11519(b)(6), ―Notification, 

recordkeeping, and reporting requirements.‖ 

(6) Requirements for opacities less than or equal to 20 percent but 

greater than zero. For each visual 

determination of emissions opacity performed in accordance with paragraph 

(f)(5) of this section for which 

the average of the six-minute average opacities recorded is 20 percent or 

less but greater than zero, you 

must perform corrective actions, including inspection of all welding fume 

sources, and evaluation of the 

proper operation and effectiveness of the management practices or fume 

control measures implemented in 

accordance with paragraph (f)(2) of this section. 
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(7) Tier 3 requirements for opacities exceeding 20 percent. For each 

visual determination of emissions 

opacity performed in accordance with paragraph (f)(5) of this section for 

which the average of the six-minute 

average opacities recorded exceeds 20 percent, you must comply with the 

requirements in paragraphs 

(f)(7)(i) through (v) of this section. 

(i) You must submit a report of exceedence of 20 percent opacity, along 

with your annual certification and 

compliance report, as specified in §63.11519(b)(8), ―Notification, 

recordkeeping, and reporting 

requirements,‖ and according to the requirements of §63.11519(b)(1), 

―Notification, recordkeeping, and 

reporting requirements.‖ 

(ii) Within 30 days of the opacity exceedence, you must prepare and 

implement a Site-Specific Welding 

Emissions Management Plan, as specified in paragraph (f)(8) of this 

section. If you have already prepared a 

Site-Specific Welding Emissions Management Plan in accordance with this 

paragraph, you must prepare 

and implement a revised Site-Specific Welding Emissions Management Plan 

within 30 days. 

(iii) During the preparation (or revision) of the Site-Specific Welding 

Emissions Management Plan, you must 

continue to perform visual determinations of emissions opacity, beginning 

on a daily schedule as specified in 

§63.11517(d), ―Monitoring Requirements,‖ using EPA Method 9, at the 

primary vent, stack, exit, or opening 

from the building containing the welding operations. 

(iv) You must maintain records of daily visual determinations of 

emissions opacity performed in accordance 

with paragraph (f)(7)(iii) of this section, during preparation of the 

Site-Specific Welding Emissions 

Management Plan, in accordance with the requirements in §63.11519(b)(9), 

―Notification, recordkeeping, 

and reporting requirements.‖ 

(v) You must include these records in your annual certification and 

compliance report, according to the 

requirements of §63.11519(b)(1), ―Notification, recordkeeping, and 

reporting requirements.‖ 

(8) Site-Specific Welding Emissions Management Plan. The Site-Specific 

Welding Emissions Management 

Plan must comply with the requirements in paragraphs (f)(8)(i) through 

(iii) of this section. 

(i) Site-Specific Welding Emissions Management Plan must contain the 

information in paragraphs (f)(8)(i)(A) 

through (F) of this section. 

(A) Company name and address; 
(B) A list and description of all welding operations which currently 

comprise the welding affected source; 

(C) A description of all management practices and/or fume control methods 

in place at the time of the 

opacity exceedence; 

(D) A list and description of all management practices and/or fume 

control methods currently employed for 

the welding affected source; 

(E) A description of additional management practices and/or fume control 

methods to be implemented 

pursuant to paragraph (f)(7)(ii) of this section, and the projected date 

of implementation; and 

(F) Any revisions to a Site-Specific Welding Emissions Management Plan 

must contain copies of all previous 

plan entries, pursuant to paragraphs (f)(8)(i)(D) and (E) of this 

section. 

(ii) The Site-Specific Welding Emissions Management Plan must be updated 

annually to contain current 

information, as required by paragraphs (f)(8)(i)(A) through (C) of this 

section, and submitted with your annual 

certification and compliance report, according to the requirements of 

§63.11519(b)(1), ―Notification, 

recordkeeping, and reporting requirements.‖ 
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(iii) You must maintain a copy of the current Site-Specific Welding 

Emissions Management Plan in your 

records in a readily-accessible location for inspector review, in 

accordance with the requirements in 

§63.11519(c)(12), ―Notification, recordkeeping, and reporting 

requirements.‖ 

§ 63.11517 What are my monitoring requirements? 

(a) Visual determination of fugitive emissions, general. Visual 

determination of fugitive emissions must be 

performed according to the procedures of EPA Method 22, of 40 CFR part 

60, Appendix A–7. You must 

conduct the EPA Method 22 test while the affected source is operating 

under normal conditions. The 

duration of each EPA Method 22 test must be at least 15 minutes, and 

visible emissions will be considered 

to be present if they are detected for more than six minutes of the 

fifteen minute period. 

(b) Visual determination of fugitive emissions, graduated schedule. 

Visual determinations of fugitive 

emissions must be performed in accordance with paragraph (a) of this 

section and according to the 

schedule in paragraphs (b)(1) through (4) of this section. 

(1) Daily Method 22 Testing. Perform visual determination of fugitive 

emissions once per day, on each day 

the process is in operation, during operation of the process. 

(2) Weekly Method 22 Testing. If no visible fugitive emissions are 

detected in consecutive daily EPA Method 

22 tests, performed in accordance with paragraph (b)(1) of this section 

for 10 days of work day operation of 

the process, you may decrease the frequency of EPA Method 22 testing to 

once every five days of operation 

of the process (one calendar week). If visible fugitive emissions are 

detected during these tests, you must 

resume EPA Method 22 testing of that operation once per day during each 

day that the process is in 

operation, in accordance with paragraph (b)(1) of this section. 

(3) Monthly Method 22 Testing. If no visible fugitive emissions are 

detected in four consecutive weekly EPA 

Method 22 tests performed in accordance with paragraph (b)(2) of this 

section, you may decrease the 

frequency of EPA Method 22 testing to once per 21 days of operation of 

the process (one calendar month). 

If visible fugitive emissions are detected during these tests, you must 

resume weekly EPA Method 22 in 

accordance with paragraph (b)(2) of this section. 

(4) Quarterly Method 22 Testing. If no visible fugitive emissions are 

detected in three consecutive monthly 

EPA Method 22 tests performed in accordance with paragraph (b)(3) of this 

section, you may decrease the 
frequency of EPA Method 22 testing to once per 60 days of operation of 

the process (3 calendar months). If 

visible fugitive emissions are detected during these tests, you must 

resume monthly EPA Method 22 in 

accordance with paragraph (b)(3) of this section. 

(c) Visual determination of emissions opacity for welding Tier 2 or 3, 

general. Visual determination of 

emissions opacity must be performed in accordance with the procedures of 

EPA Method 9, of 40 CFR part 

60, Appendix A–4, and while the affected source is operating under normal 

conditions. The duration of the 

EPA Method 9 test shall be thirty minutes. 

(d) Visual determination of emissions opacity for welding Tier 2 or 3, 

graduated schedule. You must perform 

visual determination of emissions opacity in accordance with paragraph 

(c) of this section and according to 

the schedule in paragraphs (d)(1) through (5) of this section. 

(1) Daily Method 9 testing for welding, Tier 2 or 3. Perform visual 

determination of emissions opacity once 

per day during each day that the process is in operation. 

(2) Weekly Method 9 testing for welding, Tier 2 or 3. If the average of 

the six minute opacities recorded 

during any of the daily consecutive EPA Method 9 tests performed in 

accordance with paragraph (d)(1) of 

this section does not exceed 20 percent for 10 days of operation of the 

process, you may decrease the 

frequency of EPA Method 9 testing to once per five days of consecutive 

work day operation. If opacity 

greater than 20 percent is detected during any of these tests, you must 

resume testing every day of 

operation of the process according to the requirements of paragraph 

(d)(1) of this section. 
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(3) Monthly Method 9 testing for welding Tier 2 or 3. If the average of 

the six minute opacities recorded 

during any of the consecutive weekly EPA Method 9 tests performed in 

accordance with paragraph (d)(2) of 

this section does not exceed 20 percent for four consecutive weekly 

tests, you may decrease the frequency 

of EPA Method 9 testing to once per every 21 days of operation of the 

process. If visible emissions opacity 

greater than 20 percent is detected during any monthly test, you must 

resume testing every five days of 

operation of the process according to the requirements of paragraph 

(d)(2) of this section. 

(4) Quarterly Method 9 testing for welding Tier 2 or 3. If the average of 

the six minute opacities recorded 

during any of the consecutive weekly EPA Method 9 tests performed in 

accordance with paragraph (d)(3) of 

this section does not exceed 20 percent for three consecutive monthly 

tests, you may decrease the 

frequency of EPA Method 9 testing to once per every 120 days of operation 

of the process. If visible 

emissions opacity greater than 20 percent is detected during any 

quarterly test, you must resume testing 

every 21 days (month) of operation of the process according to the 

requirements of paragraph (d)(3) of this 

section. 

(5) Return to Method 22 testing for welding, Tier 2 or 3. If, after two 

consecutive months of testing, the 

average of the six minute opacities recorded during any of the monthly 

EPA Method 9 tests performed in 

accordance with paragraph (d)(3) of this section does not exceed 20 

percent, you may resume EPA Method 

22 testing as in paragraphs (b)(3) and (4) of this section. In lieu of 

this, you may elect to continue performing 

EPA Method 9 tests in accordance with paragraphs (d)(3)and (4) of this 

section. 

§ 63.11518 [Reserved] 

§ 63.11519 What are my notification, recordkeeping, and reporting 

requirements? 

(a) What notifications must I submit? —(1) Initial notification. If you 

are the owner or operator of an area 

source in one of the nine metal fabrication and finishing source 

categories, as defined in §63.11514 ―Am I 

subject to this subpart?,‖ you must submit the Initial Notification 

required by §63.9(b) ―General Provisions,‖ 

for a new affected source no later than 120 days after initial startup or 

November 20, 2008, whichever is 

later. For an existing affected source, you must submit the Initial 

Notification no later than July 25, 2011. 
Your Initial Notification must provide the information specified in 

paragraphs (a)(1)(i) through (iv) of this 

section. 

(i) The name, address, phone number and e-mail address of the owner and 

operator; 

(ii) The address (physical location) of the affected source; 

(iii) An identification of the relevant standard (i.e., this subpart); 

and 

(iv) A brief description of the type of operation. For example, a brief 

characterization of the types of products 

(e.g., aerospace components, sports equipment, etc.), the number and type 

of processes, and the number 

of workers usually employed. 

(2) Notification of compliance status. If you are the owner or operator 

of an existing affected source, you 

must submit a notification of compliance status on or before November 22, 

2011. If you are the owner or 

operator of a new affected source, you must submit a notification of 

compliance status within 120 days after 

initial startup, or by November 20, 2008, whichever is later. You are 

required to submit the information 

specified in paragraphs (a)(2)(i) through (iv) of this section with your 

notification of compliance status: 

(i) Your company's name and address; 

(ii) A statement by a responsible official with that official's name, 

title, phone number, e-mail address and 

signature, certifying the truth, accuracy, and completeness of the 

notification and a statement of whether the

source has complied with all the relevant standards and other 

requirements of this subpart; 

(iii) If you operate any spray painting affected sources, the information 

required by §63.11516(e)(3)(vi)(C), 

―Compliance demonstration,‖ or §63.11516(e)(4)(ix)(C), ―Compliance 

demonstration,‖ as applicable; and 
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(iv) The date of the notification of compliance status. 

(b) What reports must I prepare or submit? –(1) Annual certification and 

compliance reports. You must 

prepare and submit annual certification and compliance reports for each 

affected source according to the 

requirements of paragraphs (b)(2) through (7) of this section. The annual 

certification and compliance 

reporting requirements may be satisfied by reports required under other 

parts of the CAA, as specified in 

paragraph (b)(3) of this section. 

(2) Dates. Unless the Administrator has approved or agreed to a different 

schedule for submission of reports 

under §63.10(a), ―General Provisions,‖ you must prepare and submit each 

annual certification and 

compliance report according to the dates specified in paragraphs 

(b)(2)(i) through (iii) of this section. Note 

that the information reported for each of the months in the reporting 

period will be based on the last 12 

months of data prior to the date of each monthly calculation. 

(i) The first annual certification and compliance report must cover the 

first annual reporting period which 

begins the day after the compliance date and ends on December 31. 

(ii) Each subsequent annual certification and compliance report must 

cover the subsequent semiannual 

reporting period from January 1 through December 31. 

(iii) Each annual certification and compliance report must be prepared 

and submitted no later than January 

31 and kept in a readily-accessible location for inspector review. If an 

exceedence has occurred during the 

year, each annual certification and compliance report must be submitted 

along with the exceedence reports, 

and postmarked or delivered no later than January 31. 

(3) Alternate dates. For each affected source that is subject to 

permitting regulations pursuant to 40 CFR 

part 70 or 40 CFR part 71, ―Title V.‖ 

(i) If the permitting authority has established dates for submitting 

annual reports pursuant to 40 CFR 

70.6(a)(3)(iii)(A) or 40 CFR 71.6(a)(3)(iii)(A), ―Title V,‖ you may 

prepare or submit, if required, the first and 

subsequent compliance reports according to the dates the permitting 

authority has established instead of 

according to the date specified in paragraph (b)(2)(iii) of this section. 

(ii) If an affected source prepares or submits an annual certification 

and compliance report pursuant to this 

section along with, or as part of, the monitoring report required by 40 

CFR 70.6(a)(3)(iii)(A) or 40 CFR 

71.6(a)(3)(iii)(A), ―Title V,‖ and the compliance report includes all 

required information concerning 
exceedences of any limitation in this subpart, its submission will be 

deemed to satisfy any obligation to 

report the same exceedences in the annual monitoring report. However, 

submission of an annual 

certification and compliance report shall not otherwise affect any 

obligation the affected source may have to 

report deviations from permit requirements to the permitting authority. 

(4) General requirements. The annual certification and compliance report 

must contain the information 

specified in paragraphs (b)(4)(i) through (iii) of this section, and the 

information specified in paragraphs 

(b)(5) through (7) of this section that is applicable to each affected 

source. 

(i) Company name and address; 

(ii) Statement by a responsible official with that official's name, 

title, and signature, certifying the truth, 

accuracy, and completeness of the content of the report; and 

(iii) Date of report and beginning and ending dates of the reporting 

period. The reporting period is the 12-

month period ending on December 31. Note that the information reported 

for the 12 months in the reporting 

period will be based on the last 12 months of data prior to the date of 

each monthly calculation. 

(5) Visual determination of fugitive emissions requirements. The annual 

certification and compliance report 

must contain the information specified in paragraphs (b)(5)(i) through 

(iii) of this section for each affected 
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source which performs visual determination of fugitive emissions in 

accordance with §63.11517(a), 

―Monitoring requirements.‖ 

(i) The date of every visual determination of fugitive emissions which 

resulted in detection of visible 

emissions; 

(ii) A description of the corrective actions taken subsequent to the 

test; and 

(iii) The date and results of the follow-up visual determination of 

fugitive emissions performed after the 

corrective actions. 

(6) Visual determination of emissions opacity requirements. The annual 

certification and compliance report 

must contain the information specified in paragraphs (b)(6)(i) through 

(iii) of this section for each affected 

source which performs visual determination of emissions opacity in 

accordance with §63.11517(c), 

―Monitoring requirements.‖ 

(i) The date of every visual determination of emissions opacity; 

(ii) The average of the six-minute opacities measured by the test; and 

(iii) A description of any corrective action taken subsequent to the 

test. 

(7) [Reserved] 

(8) Exceedences of 20 percent opacity for welding affected sources. As 

required by §63.11516(f)(7)(i), 

―Requirements for opacities exceeding 20 percent,‖ you must prepare an 

exceedence report whenever the 

average of the six-minute average opacities recorded during a visual 

determination of emissions opacity 

exceeds 20 percent. This report must be submitted along with your annual 

certification and compliance 

report according to the requirements in paragraph (b)(1) of this section, 

and must contain the information in 

paragraphs (b)(8)(iii)(A) and (B) of this section. 

(A) The date on which the exceedence occurred; and 

(B) The average of the six-minute average opacities recorded during the 

visual determination of emissions 

opacity. 

(9) Site-specific Welding Emissions Management Plan reporting. You must 

submit a copy of the records of 

daily visual determinations of emissions recorded in accordance with 

§63.11516(f)(7)(iv), ―Tier 3 

requirements for opacities exceeding 20 percent,‖ and a copy of your 

Site-Specific Welding Emissions 

Management Plan and any subsequent revisions to the plan pursuant to 

§63.11516(f)(8), ―Site-specific 

Welding Emission Management Plan,‖ along with your annual certification 

and compliance report, according 

to the requirements in paragraph (b)(1) of this section. 
(c) What records must I keep? You must collect and keep records of the 

data and information specified in 

paragraphs (c)(1) through (13) of this section, according to the 

requirements in paragraph (c)(14) of this 

section. 

(1) General compliance and applicability records. Maintain information 

specified in paragraphs (c)(1)(i) 

through (ii) of this section for each affected source. 

(i) Each notification and report that you submitted to comply with this 

subpart, and the documentation 

supporting each notification and report. 

(ii) Records of the applicability determinations as in §63.11514(b)(1) 

through (5), ―Am I subject to this 

subpart,‖ listing equipment included in its affected source, as well as 

any changes to that and on what date 

they occurred, must be maintained for 5 years and be made available for 

inspector review at any time. 
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(2) Visual determination of fugitive emissions records. Maintain a record 

of the information specified in 

paragraphs (c)(2)(i) through (iii) of this section for each affected 

source which performs visual determination 

of fugitive emissions in accordance with §63.11517(a), ―Monitoring 

requirements.‖ 

(i) The date and results of every visual determination of fugitive 

emissions; 

(ii) A description of any corrective action taken subsequent to the test; 

and 

(iii) The date and results of any follow-up visual determination of 

fugitive emissions performed after the 

corrective actions. 

(3) Visual determination of emissions opacity records. Maintain a record 

of the information specified in 

paragraphs (c)(3)(i) through (iii) of this section for each affected 

source which performs visual determination 

of emissions opacity in accordance with §63.11517(c), ―Monitoring 

requirements.‖ 

(i) The date of every visual determination of emissions opacity; and 

(ii) The average of the six-minute opacities measured by the test; and 

(iii) A description of any corrective action taken subsequent to the 

test. 

(4) Maintain a record of the manufacturer's specifications for the 

control devices used to comply with 

§63.11516, ―What are my standards and management practices?‖ 

(5) Spray paint booth filter records. Maintain a record of the filter 

efficiency demonstrations and spray paint 

booth filter maintenance activities, performed in accordance with 

§63.11516(d)(1)(ii) and (iii), ―Requirements 

for spray painting objects in spray booths or spray rooms.‖ 

(6) Waterspray booth or water curtain efficiency tests. Maintain a record 

of the water curtain efficiency 

demonstrations performed in accordance with §63.11516(d)(1)(ii), 

―Requirements for spray painting objects 

in spray booths or spray rooms.‖ 

(7) HVLP or other high transfer efficiency spray delivery system 

documentation records. Maintain 

documentation of HVLP or other high transfer efficiency spray paint 

delivery systems, in compliance with 

§63.11516(d)(3), ―Requirements for spray painting of all objects.‖ This 

documentation must include the 

manufacturer's specifications for the equipment and any manufacturer's 

operation instructions. If you have 

obtained written approval for an alternative spray application system in 

accordance with §63.11516(d)(2), 

―Spray painting of all objects,‖ you must maintain a record of that 

approval along with documentation of the 

demonstration of equivalency. 
(8) HVLP or other high transfer efficiency spray delivery system employee 

training documentation records. 

Maintain certification that each worker performing spray painting 

operations has completed the training 

specified in §63.11516(d)(6), ―Requirements for spray painting of all 

objects,‖ with the date the initial training 

and the most recent refresher training was completed. 

(9)–(10) [Reserved] 

(11) Visual determination of emissions opacity performed during the 

preparation (or revision) of the SiteSpecific Welding Emissions Management Plan. You must maintain a record of 

each visual determination of 

emissions opacity performed during the preparation (or revision) of a 

Site-Specific Welding Emissions 

Management Plan, in accordance with §63.11516(f)(7)(iii), ―Requirements 

for opacities exceeding 20 

percent.‖ 

(12) Site-Specific Welding Emissions Management Plan. If you have been 

required to prepare a plan in 

accordance with §63.11516(f)(7)(iii), ―Site-Specific Welding Emissions 

Management Plan,‖ you must 

maintain a copy of your current Site-Specific Welding Emissions 

Management Plan in your records and it 

must be readily available for inspector review. 
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(13) Manufacturer's instructions. If you comply with this subpart by 

operating any equipment according to 

manufacturer's instruction, you must keep these instructions readily 

available for inspector review. 

(14) Welding Rod usage. If you operate a new or existing welding affected 

source which is not required to 

comply with the requirements of §63.11516(f)(3) through (8) because it 

uses less than 2,000 pounds per 

year of welding rod (on a rolling 12-month basis), you must maintain 

records demonstrating your welding rod 

usage on a rolling 12-month basis. 

(15) Your records must be maintained according to the requirements in 

paragraphs (c)(14)(i) through (iii) of 

this section. 

(i) Your records must be in a form suitable and readily available for 

expeditious review, according to 

§63.10(b)(1), ―General Provisions.‖ Where appropriate, the records may be 

maintained as electronic 

spreadsheets or as a database. 

(ii) As specified in §63.10(b)(1), ―General Provisions,‖ you must keep 

each record for 5 years following the 

date of each occurrence, measurement, corrective action, report, or 

record. 

(iii) You must keep each record on-site for at least 2 years after the 

date of each occurrence, measurement, 

corrective action, report, or record according to §63.10(b)(1), ―General 

Provisions.‖ You may keep the 

records off-site for the remaining 3 years. 

§ 63.11520 [Reserved] 

Other Requirements and Information 

§ 63.11521 Who implements and enforces this subpart? 

(a) This subpart can be implemented and enforced by EPA or a delegated 

authority such as your state, 

local, or tribal agency. If the EPA Administrator has delegated authority 

to your state, local, or tribal agency, 

then that agency, in addition to EPA, has the authority to implement and 

enforce this subpart. You should 

contact your EPA Regional Office to find out if implementation and 

enforcement of this subpart is delegated 

to your state, local, or tribal agency. 

(b) In delegating implementation and enforcement authority of this 

subpart to a state, local, or tribal agency 

under 40 CFR part 63, subpart E, the authorities contained in paragraph 

(c) of this section are retained by 

the EPA Administrator and are not transferred to the state, local, or 

tribal agency. 

(c) The authorities that cannot be delegated to state, local, or tribal 

agencies are specified in paragraphs 

(c)(1) through (5) of this section. 
(1) Approval of an alternative non-opacity emissions standard under 

§63.6(g), of the General Provisions of 

this part. 

(2) Approval of an alternative opacity emissions standard under 

§63.6(h)(9), of the General Provisions of this 

part. 

(3) Approval of a major change to test methods under §63.7(e)(2)(ii) and 

(f), of the General Provisions of this 

part. A ―major change to test method‖ is defined in §63.90. 

(4) Approval of a major change to monitoring under §63.8(f), of the 

General Provisions of this part. A ―major 

change to monitoring‖ under is defined in §63.90. 

(5) Approval of a major change to recordkeeping and reporting under 

§63.10(f), of the General Provisions of 

this part. A ―major change to recordkeeping/reporting‖ is defined in 

§63.90. 
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§ 63.11522 What definitions apply to this subpart? 

The terms used in this subpart are defined in the CAA; and in this 

section as follows: 

Adequate emission capture methods are hoods, enclosures, or any other 

duct intake devices with ductwork, 

dampers, manifolds, plenums, or fans designed to draw greater than 85 

percent of the airborne dust 

generated from the process into the control device. 

Capture system means the collection of components used to capture gases 

and fumes released from one or 

more emissions points and then convey the captured gas stream to a 

control device or to the atmosphere. A 

capture system may include, but is not limited to, the following 

components as applicable to a given capture 

system design: duct intake devices, hoods, enclosures, ductwork, dampers, 

manifolds, plenums, and fans. 

Cartridge collector means a type of control device that uses perforated 

metal cartridges containing a pleated 

paper or non-woven fibrous filter media to remove PM from a gas stream by 

sieving and other mechanisms. 

Cartridge collectors can be designed with single use cartridges, which 

are removed and disposed after 

reaching capacity, or continuous use cartridges, which typically are 

cleaned by means of a pulse-jet 

mechanism. 

Confined abrasive blasting enclosure means an enclosure that includes a 

roof and at least two complete 

walls, with side curtains and ventilation as needed to insure that no air 

or PM exits the enclosure while dry 

abrasive blasting is performed. Apertures or slots may be present in the 

roof or walls to allow for 

mechanized transport of the blasted objects with overhead cranes, or 

cable and cord entry into the dry 

abrasive blasting chamber. 

Control device means equipment installed on a process vent or exhaust 

system that reduces the quantity of 

a pollutant that is emitted to the air. 

Dry abrasive blasting means cleaning, polishing, conditioning, removing 

or preparing a surface by propelling 

a stream of abrasive material with compressed air against the surface. 

Hydroblasting, wet abrasive blasting, 

or other abrasive blasting operations which employ liquids to reduce 

emissions are not dry abrasive blasting. 

Dry grinding and dry polishing with machines means grinding or polishing 

without the use of lubricating oils 

or fluids in fixed or stationary machines. Hand grinding, hand polishing, 

and bench top dry grinding and dry 

polishing are not included under this definition. 
Fabric filter means a type of control device used for collecting PM by 

filtering a process exhaust stream 

through a filter or filter media; a fabric filter is also known as a 

baghouse. 

Facility maintenance means operations performed as part of the routine 

repair or renovation of process 

equipment, machinery, control equipment, and structures that comprise the 

infrastructure of the affected 

facility and that are necessary for the facility to function in its 

intended capacity. Facility maintenance also 

includes operations associated with the installation of new equipment or 

structures, and any processes as 

part of janitorial activities. Facility maintenance includes operations 

on stationary structures or their 

appurtenances at the site of installation, to portable buildings at the 

site of installation, to pavements, or to 

curbs. Facility maintenance also includes operations performed on mobile 

equipment, such as fork trucks, 

that are used in a manufacturing facility and which are maintained in 

that same facility. Facility maintenance 

does not include spray-applied coating of motor vehicles, mobile 

equipment, or items that routinely leave 

and return to the facility, such as delivery trucks, rental equipment, or 

containers used to transport, deliver, 

distribute, or dispense commercial products to customers, such as 

compressed gas canisters. 

Filtration control device means a control device that utilizes a filter 

to reduce the emissions of MFHAP and 

other PM. 

Grinding means a process performed on a workpiece to remove undesirable 

material from the surface or to 

remove burrs or sharp edges. Grinding is done using belts, disks, or 

wheels consisting of or covered with 

various abrasives. 
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Machining means dry metal turning, milling, drilling, boring, tapping, 

planing, broaching, sawing, cutting, 

shaving, shearing, threading, reaming, shaping, slotting, hobbing, and 

chamfering with machines. Shearing 

operations cut materials into a desired shape and size, while forming 

operations bend or conform materials 

into specific shapes. Cutting and shearing operations include punching,

piercing, blanking, cutoff, parting, 

shearing and trimming. Forming operations include bending, forming, 

extruding, drawing, rolling, spinning, 

coining, and forging the metal. Processes specifically excluded are handheld devices and any process 

employing fluids for lubrication or cooling. 

Material containing MFHAP means a material containing one or more MFHAP. 

Any material that contains 

cadmium, chromium, lead, or nickel in amounts greater than or equal to 

0.1 percent by weight (as the 

metal), and contains manganese in amounts greater than or equal to 1.0 

percent by weight (as the metal), 

as shown in formulation data provided by the manufacturer or supplier, 

such as the Material Safety Data 

Sheet for the material, is considered to be a material containing MFHAP. 

Metal fabrication and finishing HAP (MFHAP) means any compound of the 

following metals: Cadmium, 

chromium, lead, manganese, or nickel, or any of these metals in the 

elemental form, with the exception of 

lead. 

Metal fabrication and finishing source categories are limited to the nine 

metal fabrication and finishing 

source categories with the activities described in Table 1, ―Description 

of Source Categories Affected by this 

Subpart.‖ Metal fabrication or finishing operations means dry abrasive 

blasting, machining, spray painting, or 

welding in any one of the nine metal fabrication and finishing area 

source categories listed in Table 1, 

―Description of Source Categories Affected by this Subpart.‖ 

Military munitions means all ammunition products and components produced 

or used by or for the U.S. 

Department of Defense (DoD) or for the U.S. Armed Services for national 

defense and security, including 

military munitions under the control of the DoD, the U.S. Coast Guard, 

the National Nuclear Security 

Administration (NNSA), U.S. Department of Energy (DOE), and National 

Guard personnel. The term military 

munitions includes: Confined gaseous, liquid, and solid propellants, 

explosives, pyrotechnics, chemical and 

riot control agents, smokes, and incendiaries used by DoD components, 

including bulk explosives and 
chemical warfare agents, chemical munitions, biological weapons, rockets, 

guided and ballistic missiles, 

bombs, warheads, small arms ammunition, grenades, mines, torpedoes, depth 

charges, cluster munitions 

and dispensers, demolition charges, nonnuclear components of nuclear 

weapons, wholly inert ammunition 

products, and all devices and components of any items listed in this 

definition. 

Paint means a material applied to a substrate for decorative, protective, 

or functional purposes. Such 

materials include, but are not limited to, paints, coatings, sealants, 

liquid plastic coatings, caulks, inks, 

adhesives, and maskants. Decorative, protective, or functional materials 

that consist only of protective oils 

for metal, acids, bases, or any combination of these substances, or paper 

film or plastic film which may be 

pre-coated with an adhesive by the film manufacturer, are not considered 

paints for the purposes of this 

subpart. 

Polishing with machines means an operation which removes fine excess 

metal from a surface to prepare the 

surface for more refined finishing procedures prior to plating or other 

processes. Polishing may also be 

employed to remove burrs on castings or stampings. Polishing is performed 

using hard-faced wheels 

constructed of muslin, canvas, felt or leather, and typically employs 

natural or artificial abrasives. Polishing 

performed by hand without machines or in bench top operations are not 

considered polishing with machines 

for the purposes of this subpart. 

Primarily engaged means the manufacturing, fabricating, or forging of one 

or more products listed in one of 

the nine metal fabrication and finishing source category descriptions in 

Table 1, ―Description of Source 

Categories Affected by this Subpart,‖ where this production represents at 

least 50 percent of the production 

at a facility, and where production quantities are established by the 

volume, linear foot, square foot, or other 

value suited to the specific industry. The period used to determine 

production should be the previous 

continuous 12 months of operation. Facilities must document and retain 

their rationale for the determination 

that their facility is not ―primarily engaged‖ pursuant to §63.10(b)(3) 

of the General Provisions. 

Quality control activities means operations that meet all of the 

following criteria: 
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Permit Reviewer: Jillian Bertram 

(1) The activities are intended to detect and correct defects in the 

final product by selecting a limited number 

of samples from the operation, and comparing the samples against specific 

performance criteria. 

(2) The activities do not include the production of an intermediate or 

final product for sale or exchange for 

commercial profit; for example, parts that are not sold and do not leave 

the facility. 

(3) The activities are not a normal part of the operation; 

(4) The activities do not involve fabrication of tools, equipment, 

machinery, and structures that comprise the 

infrastructure of the facility and that are necessary for the facility to 

function in its intended capacity; that is, 

the activities are not facility maintenance. 

Responsible official means responsible official as defined in 40 CFR 

70.2. 

Spray-applied painting means application of paints using a hand-held 

device that creates an atomized mist 

of paint and deposits the paint on a substrate. For the purposes of this 

subpart, spray-applied painting does 

not include the following materials or activities: 

(1) Paints applied from a hand-held device with a paint cup capacity that 

is less than 3.0 fluid ounces (89 

cubic centimeters). 

(2) Surface coating application using powder coating, hand-held, nonrefillable aerosol containers, or nonatomizing 

application technology, including, but not limited to, paint brushes, 

rollers, hand wiping, flow 

coating, dip coating, electrodeposition coating, web coating, coil 

coating, touch-up markers, or marking 

pens. 

(3) Painting operations that normally require the use of an airbrush or 

an extension on the spray gun to 

properly reach limited access spaces; the application of paints that 

contain fillers that adversely affect 

atomization with HVLP spray guns, and the application of paints that 

normally have a dried film thickness of 

less than 0.0013 centimeter (0.0005 in.). 

(4) Thermal spray operations (also known as metallizing, flame spray, 

plasma arc spray, and electric arc 

spray, among other names) in which solid metallic or non-metallic 

material is heated to a molten or semimolten 

state and propelled to the work piece or substrate by compressed air or 

other gas, where a bond is 

produced upon impact. 

Spray booth or spray room means an enclosure with four sides and a roof 

where spray paint is prevented 

from leaving the booth during spraying by the enclosure. The roof of the 

spray booth or spray room may 
contain narrow slots for connecting the parts and products to overhead 

cranes, or for cord or cable entry into 

the spray booth or spray room. 

Tool or equipment repair means equipment and devices used to repair or 

maintain process equipment or to 

prepare molds, dies, or other changeable elements of process equipment. 

Totally enclosed and unvented means enclosed so that no air enters or 

leaves during operation. 

Totally enclosed and unvented dry abrasive blasting chamber means a dry 

abrasive blasting enclosure 

which has no vents to the atmosphere, thus no emissions. A typical 

example of this sort of abrasive blasting 

enclosure is a small ―glove box‖ enclosure, where the worker places their 

hands in openings or gloves that 

extend into the box and enable the worker to hold the objects as they are 

being blasted without allowing air 

and blast material to escape the box. 

Vented dry abrasive blasting means dry abrasive blasting where the blast 

material is moved by air flow from 

within the chamber to outside the chamber into the atmosphere or into a 

control device. 

Welding means a process which joins two metal parts by melting the parts 

at the joint and filling the space 

with molten metal. 
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Newburgh, Indiana Significant Permit Modification No. 173-29035-00007 

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Permit Reviewer: Jillian Bertram 

Welding rod containing MFHAP means a welding rod that contains cadmium, 

chromium, lead, or nickel in 

amounts greater than or equal to 0.1 percent by weight (as the metal), or 

that contains manganese in 

amounts greater than or equal to 1.0 percent by weight (as the metal), as 

shown in formulation data 

provided by the manufacturer or supplier, such as the Material Safety 

Data Sheet for the welding rod. 

§ 63.11523 What General Provisions apply to this subpart? 

The provisions in 40 CFR part 63, subpart A, applicable to sources 

subject to §63.11514(a) are specified in 

Table 2 of this subpart. 

Table 1 to Subpart XXXXXX of Part 63—Description of Source Categories 

Affected by This 

Subpart 

Metal fabrication 

and finishing source 

category Description 

Electrical and 

Electronic Equipment 

Finishing Operations 

Establishments primarily engaged in manufacturing motors and 

generators; and electrical machinery, equipment, and supplies, not 

elsewhere classified. The electrical machinery equipment and 

supplies industry sector of this source category includes 

establishments primarily engaged in high energy particle 

acceleration systems and equipment, electronic simulators, 

appliance and extension cords, bells and chimes, insect traps, and 

other electrical equipment and supplies not elsewhere classified. 

The motors and generators sector of this source category includes 

establishments primarily engaged in manufacturing electric motors 

(except engine starting motors) and power generators; motor 

generator sets; railway motors and control equipment; and motors, 

generators and control equipment for gasoline, electric, and oilelectric 

buses and trucks. 

Fabricated Metal 

Products 

Establishments primarily engaged in manufacturing fabricated 

metal products, such as fire or burglary resistive steel safes and 

vaults and similar fire or burglary resistive products; and 

collapsible tubes of thin flexible metal. Also, establishments 

primarily engaged in manufacturing powder metallurgy products, 

metal boxes; metal ladders; metal household articles, such as ice 

cream freezers and ironing boards; and other fabricated metal 

products not elsewhere classified. 

Fabricated Plate 

Work (Boiler Shops) 

Establishments primarily engaged in manufacturing power marine 

boilers, pressure and nonpressure tanks, processing and storage 
vessels, heat exchangers, weldments and similar products. 

Fabricated Structural 

Metal Manufacturing 

Establishments primarily engaged in fabricating iron and steel or 

other metal for structural purposes, such as bridges, buildings, and 

sections for ships, boats, and barges. 

Heating Equipment, Establishments primarily engaged in manufacturing 

heating 
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Newburgh, Indiana Significant Permit Modification No. 173-29035-00007 

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Permit Reviewer: Jillian Bertram 

except Electric equipment, except electric and warm air furnaces, 

including gas, 

oil, and stoker coal fired equipment for the automatic utilization of 

gaseous, liquid, and solid fuels. Products produced in this source 

category include low-pressure heating (steam or hot water) boilers, 

fireplace inserts, domestic (steam or hot water) furnaces, domestic 

gas burners, gas room heaters, gas infrared heating units, 

combination gas-oil burners, oil or gas swimming pool heaters, 

heating apparatus (except electric or warm air), kerosene space 

heaters, gas fireplace logs, domestic and industrial oil burners, 

radiators (except electric), galvanized iron nonferrous metal range 

boilers, room heaters (except electric), coke and gas burning 

salamanders, liquid or gas solar energy collectors, solar heaters, 

space heaters (except electric), mechanical (domestic and 

industrial) stokers, wood and coal-burning stoves, domestic unit 

heaters (except electric), and wall heaters (except electric). 

Industrial Machinery 

and Equipment 

Finishing Operations 

Establishments primarily engaged in construction machinery 

manufacturing; oil and gas field machinery manufacturing; and 

pumps and pumping equipment manufacturing. The construction 

machinery manufacturing industry sector of this source category 

includes establishments primarily engaged in manufacturing heavy 

machinery and equipment of types used primarily by the 

construction industries, such as bulldozers; concrete mixers; 

cranes, except industrial plant overhead and truck-type cranes; 

dredging machinery; pavers; and power shovels. Also 

establishments primarily engaged in manufacturing forestry 

equipment and certain specialized equipment, not elsewhere 

classified, similar to that used by the construction industries, such 

as elevating platforms, ship cranes, and capstans, aerial work 

platforms, and automobile wrecker hoists. The oil and gas field 

machinery manufacturing industry sector of this source category 

includes establishments primarily engaged in manufacturing 

machinery and equipment for use in oil and gas fields or for 

drilling water wells, including portable drilling rigs. The pumps 

and pumping equipment manufacturing sector of this source 

category includes establishments primarily engaged in 

manufacturing pumps and pumping equipment for general 

industrial, commercial, or household use, except fluid power 

pumps and motors. This category includes establishments 

primarily engaged in manufacturing domestic water and sump 

pumps. 

Iron and Steel 

Forging 

Establishments primarily engaged in the forging manufacturing 

process, where purchased iron and steel metal is pressed, pounded 

or squeezed under great pressure into high strength parts known as 
forgings. The forging process is different from the casting and 

foundry processes, as metal used to make forged parts is never 
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Newburgh, Indiana Significant Permit Modification No. 173-29035-00007 

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Permit Reviewer: Jillian Bertram 

melted and poured. 

Primary Metals 

Products 

Manufacturing 

Establishments primarily engaged in manufacturing products such 

as fabricated wire products (except springs) made from purchased 

wire. These facilities also manufacture steel balls; nonferrous metal 

brads and nails; nonferrous metal spikes, staples, and tacks; and 

other primary metals products not elsewhere classified. 

Valves and Pipe 

Fittings 

Establishments primarily engaged in manufacturing metal valves 

and pipe fittings; flanges; unions, with the exception of purchased 

pipes; and other valves and pipe fittings not elsewhere classified. 

Table 2—to Subpart XXXXXX of Part 63—Applicability of General Provisions 

to Metal 

Fabrication or Finishing Area Sources 

Instructions for Table 2 —As required in §63.11523, ―General Provisions 

Requirements,‖ you must meet 

each requirement in the following table that applies to you. 

Citation Subject 

63.11 Applicability. 

63.2 Definitions. 

63.3 Units and abbreviations. 

63.4 Prohibited activities. 

63.5 Construction/reconstruction. 

63.6(a), (b)(1)–(b)(5), (c)(1), 

(c)(2), (c)(5), (g), (i), (j) 

Compliance with standards and maintenance 

requirements. 

63.9(a)–(d) Notification requirements. 

63.10(a), (b) except for (b)(2), 

(d)(1), (d)(4) 

Recordkeeping and reporting. 

63.12 State authority and delegations. 

63.13 Addresses of State air pollution control agencies and 

EPA regional offices. 

63.14 Incorporation by reference. 

63.15 Availability of information and confidentiality. 

63.16 Performance track provisions. 

1§63.11514(g), ―Am I subject to this subpart?‖ exempts affected sources 

from the obligation to obtain title V 

operating permits. 
INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

We Protect Hoosiers and Our Environment. 

Mitchell E. Daniels Jr. 100 North Senate Avenue 

Governor Indianapolis, Indiana 46204 

(317) 232-8603 

Thomas W. Easterly Toll Free (800) 451-6027 

Commissioner www.idem.IN.gov 

Recycled Paper An Equal Opportunity Employer Please Recycle 

SENT VIA U.S. MAIL: CONFIRMED DELIVERY AND SIGNATURE REQUESTED 

TO: Sam Bruntz 

ALCOA, Inc. Warrick 

Bldg 860 E PO Box 10 

Newburgh, IN 47629-0010 

DATE: September 14, 2010 

FROM: Matt Stuckey, Branch Chief 

Permits Branch 

Office of Air Quality 

SUBJECT: Final Decision 

Title V 

173-29035-00007 

Enclosed is the final decision and supporting materials for the air 

permit application referenced above. 

Please note that this packet contains the original, signed, permit 

documents. 

The final decision is being sent to you because our records indicate that 

you are the contact person for this 

application. However, if you are not the appropriate person within your 

company to receive this document, 

please forward it to the correct person. 

A copy of the final decision and supporting materials has also been sent 

via standard mail to: 

Ed Hemmersbach, Responsible Official 

OAQ Permits Branch Interested Parties List 

If you have technical questions regarding the enclosed documents, please 

contact the Office of Air Quality, 

Permits Branch at (317) 233-0178, or toll-free at 1-800-451-6027 (ext. 3-

0178), and ask to speak to the 

permit reviewer who prepared the permit. If you think you have received 

this document in error, please 

contact Joanne Smiddie-Brush of my staff at 1-800-451-6027 (ext 3-0185), 

or via e-mail at 

jbrush@idem.IN.gov. 

Final Applicant Cover letter.dot 11/30/07 
INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

We Protect Hoosiers and Our Environment. 

Mitchell E. Daniels Jr. 100 North Senate Avenue 

Governor Indianapolis, Indiana 46204 

(317) 232-8603 

Thomas W. Easterly Toll Free (800) 451-6027 

Commissioner www.idem.IN.gov 

Recycled Paper An Equal Opportunity Employer Please Recycle 

September 14, 2010 

TO: Ohio Township Public Library System 

From: Matthew Stuckey, Branch Chief 

Permits Branch 

Office of Air Quality 

Subject: Important Information for Display Regarding a Final 

Determination 

Applicant Name: Alcoa, Inc. 

Permit Number: 173-29035-00007 

You previously received information to make available to the public 

during the public comment 

period of a draft permit. Enclosed is a copy of the final decision and 

supporting materials for the 

same project. Please place the enclosed information along with the 

information you previously 

received. To ensure that your patrons have ample opportunity to review 

the enclosed permit, we 

ask that you retain this document for at least 60 days. 

The applicant is responsible for placing a copy of the application in 

your library. If the permit 

application is not on file, or if you have any questions concerning this 

public review process, 

please contact Joanne Smiddie-Brush, OAQ Permits Administration Section 

at 1-800-451-6027, 

extension 3-0185. 

Enclosures 

Final Library.dot 11/30/07 
FACSIMILIE OF PS Form 3877 

Mail Code 61-53 

IDEM Staff DPABST 9/14/2010 

ALCOA - Warrick Operations 173-29035-00007 (Final) 

AFFIX STAMP 

HERE IF 

USED AS 

CERTIFICATE 

OF MAILING 

Name and 

address of 

Sender . Indiana Department of Environmental 

Management 

Office of Air Quality – Permits Branch 

100 N. Senate 

Indianapolis, IN 46204 

Type of Mail: 

CERTIFICATE OF 

MAILING ONLY 

Line Article 

Number 

Name, Address, Street and Post Office Address Postage Handing 

Charges 

Act. Value 

(If Registered) 

Insured 

Value 

Due Send if 

COD 

R.R. 

Fee 

S.D. Fee S.H. 

Fee 

Rest. 

Del. Fee 

Remarks 

1 Sam Bruntz ALCOA - Warrick Operations Bldg 860 E PO Box 10 Newburgh IN 

47629-0010 (Source CAATS) (CONFIRM DELIVERY) 

2 Ed Hemmersbach Ops Mg,r Rigid Products ALCOA - Warrick Operations Bldg 

1 PO Box 10 Newburgh IN 47629-0010 (RO CAATS) 

3 Warrick County Board of Commissioners 107 W. Locust Street Suite # 301 

Boonville IN 47601-0585 (Local Official) 

4 Warrick County Health Department 107 W Locust, Suite 204 Boonville IN 

47601-1701 (Health Department) 

5 Mr. Charles L. Berger Berger & Berger, Attorneys at Law 313 Main Street 

Evansville IN 47700 (Affected Party) 

6 Mr. Randy Brown Plumbers & Steam Fitters Union, Local 136 2300 St. Joe 

Industrial Park Dr Evansville IN 47720 (Affected Party) 

7 Dr. Jeff Seyler Univ. of So Ind., 8600 Univ. Blvd. Evansville IN 47712 

(Affected Party) 

8 Mr. Don Mottley Save Our Rivers 6222 Yankeetown Hwy Boonville IN 47601 

(Affected Party) 

9 Newburgh Town Council and Town Manager P.O Box 6 Newburgh IN 47630 

(Local Official) 
10 Kim Sherman 3355 Woodview Drive Newburgh IN 47630 (Affected Party) 

11 Mr. Mark Wilson Evansville Courier Press - News Desk P.O. Box 268 

Evansville IN 47702 (Affected Party) 

12 Joanne Alexandrovich Vanderburgh County Health Dept. 420 Mulberry ST. 

Evansville IN 47713 (Affected Party) 

13 Carly Watson 8666 Hanover Dr. Newburgh IN 47630 (Affected Party) 

14 Mr. Bill Musgrove PO Box 565 Boonville IN 47601 (Affected Party) 

15 Mr. Bil Musgrove PO Box 520 Chandler IN 47610 (Affected Party) 

Total number of pieces 

Listed by Sender 

Total number of Pieces 

Received at Post Office 

Postmaster, Per (Name of 

Receiving employee) 

The full declaration of value is required on all domestic and 

international registered mail. The 

maximum indemnity payable for the reconstruction of nonnegotiable 

documents under Express 

Mail document reconstructing insurance is $50,000 per piece subject to a 

limit of $50, 000 per 

occurrence. The maximum indemnity payable on Express mil merchandise 

insurance is $500. 

The maximum indemnity payable is $25,000 for registered mail, sent with 

optional postal 

insurance. See Domestic Mail Manual R900, S913, and S921 for limitations 

of coverage on 

inured and COD mail. See International Mail Manual for limitations o 

coverage on international 

mail. Special handling charges apply only to Standard Mail (A) and 

Standard Mail (B) parcels. 
FACSIMILIE OF PS Form 3877 

Mail Code 61-53 

IDEM Staff DPABST 9/14/2010 

ALCOA - Warrick Operations 173-29035-00007 (Final) 

AFFIX STAMP 

HERE IF 

USED AS 

CERTIFICATE 

OF MAILING 

Name and 

address of 

Sender . Indiana Department of Environmental 

Management 

Office of Air Quality – Permits Branch 

100 N. Senate 

Indianapolis, IN 46204 

Type of Mail: 

CERTIFICATE OF 

MAILING ONLY 

Line Article 

Number 

Name, Address, Street and Post Office Address Postage Handing 

Charges 

Act. Value 

(If Registered) 

Insured 

Value 

Due Send if 

COD 

R.R. 

Fee 

S.D. Fee S.H. 

Fee 

Rest. 

Del. Fee 

Remarks 

1 John 800 Adams Ave Evansville IN 47713 (Affected Party) 

2 Elizabeth Joshi 2377 Lakeridge Dr Newburgh IN 47630 (Affected Party) 

3 Ohio Township Public Library System IN Hwy. 66 & Bell Oaks Rd Newburgh 

IN 46730 (Library) 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

Total number of pieces 

Listed by Sender 
Total number of Pieces 

Received at Post Office 

Postmaster, Per (Name of 

Receiving employee) 

The full declaration of value is required on all domestic and 

international registered mail. The 

maximum indemnity payable for the reconstruction of nonnegotiable 

documents under Express 

Mail document reconstructing insurance is $50,000 per piece subject to a 

limit of $50, 000 per 

occurrence. The maximum indemnity payable on Express mil merchandise 

insurance is $500. 

The maximum indemnity payable is $25,000 for registered mail, sent with 

optional postal 

insurance. See Domestic Mail Manual R900, S913, and S921 for limitations 

of coverage on 

inured and COD mail. See International Mail Manual for limitations o 

coverage on international 

mail. Special handling charges apply only to Standard Mail (A) and 

Standard Mail (B) parcels. 
=