Alcoa, Inc.

– Warrick Operations Significant Permit Modification No.:

173

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- 00007 Page 2 of 178 Newburgh, Indiana Modified by: Jillian Bertram T 173

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- 00007 Permit Reviewer: Dr. Trip Sinha TABLE OF CONTENTS A SOURCE SUMMARY A.1 General Inf ormation [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 In significant 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 IA C 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 [3 26 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)] [32 6 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- 12] B.13 Prior Permits Superseded [326 IAC 2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 OPERATI ON 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 Burnin g [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 Requi rements [326 IAC 2

- 7

- 6(1)] C.8 Performance Testing [326 IAC 3

- 6]Alcoa, Inc.

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- 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 [32 6 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] [3 26 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 FACI LITY 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] C ompliance 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 Detect ion 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 FAC ILITY 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 Limi tations [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] [3 26 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.

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- 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] [32 6 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, Sub part 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 RequirementsD.3.6 Pa rticulate 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 RequirementsAlcoa, In c.

– Warrick Operations Significant Permit Modification No.:

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- 00007 Permit Reviewer: Dr. Trip Sinha D.3.12 NESHAP Record Keeping Requirements [326 IAC 20

- 1] [40 CF R 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 Emissio n 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.4.2 2 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

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- 00007 Permit Reviewer: Dr. Trip Sinha D.5.4 Par ticulate 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 Manufact uring 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 So urce 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] Complianc e 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 Operat ion [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 Mon itoring 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 Ba g 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 Flu x 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, S ubpart 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.

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- 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 Proce sses [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 Requiremen ts 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 fo r 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 Requiremen ts 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 IA C 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.

– Warri ck Operations Significant Permit Modification No.:

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- 00007 Page 8 of 178 Newburgh, Indiana Modified by: Jillian Bertram T 173

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- 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 Deter mination 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 Certificatio n 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.:

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- 00007 Permit Reviewer: Dr. Trip Sinha SECTION A SOURCE SUMMARY This permit is ba sed 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 enfor ceable 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 an d 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 47 629 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 adminis trative purposes. These two plants have different plant identification numbers. Alcoa Inc.

– Warrick Operations ID

- 173

- 00007 Alcoa Warrick Power Plant ID

- 173

- 00002A.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 d escribed 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 finallyAlcoa, Inc.

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- 00007 Page 10 of 178 Newburgh, Indiana Modified by: Jillian Bertram T 173

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- 00007 Permit R eviewer: 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 an d 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 ce nter (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 P lant: 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 clas sifier, 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 lo cated 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 s ystem, 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 S upport: 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 duty

cycled, diesel fired,reci procating 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 m ill, 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 ele ctro 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 (B rick 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 con veyor 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.A lcoa, Inc.

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- 00007 Permit Reviewer: Dr. Trip Sinha A.5 Part 70 Permit Applicability [326 IAC 2

- 7

- 2] Thi s 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 Prot ection Agency (U.S. EPA) under 40 CFR 70.3 (Part 70

- Applicability).Alcoa, Inc.

– Warrick Operations Significant Permit Modification No.:

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- 00007 Page 12 of 178 Newburgh, Indiana Modified by: Jillian Bertram T 173

- 6627

- 00007 Permit Revie wer: 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 app licable 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 is sued 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 citi zens 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 Per mittee 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 th e 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, anyAlcoa, Inc.

– Warrick Operations Significant Permit Mod ification No.:

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- 00007 Permit Reviewer: Dr. Trip Sinha application form, report, or compliance certification submitted shall contain certification by the "respon sible 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) c ertification 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 em ission 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 10 03 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 compli ance 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 documen t 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 basisof 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 certif ication 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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- 00007 Permit Re viewer: 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 Preven tive 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) responsi ble 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 additi onal 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 t he 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

- b ased 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 demonstra ted 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 fac ility 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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- 00007 Page 15 of 178 Newburgh, Indiana Modified by: Jillian Bertram T 173

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- 00007 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 fo r 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 "re sponsible 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 thatthe Preventive Maintenance Plans requir ed 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 viola tion of 326 IAC 2

- 7 and any other applicable rules.Alcoa, Inc.

– Warrick Operations Significant Permit Modification No.:

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- 00007 Permit Reviewer: Dr. Trip Si nha (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

- 1 5, 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 a pplicable 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 statut es 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 pr omulgated 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 t hat 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 th e 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 issuanceof 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 informa tion 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 Cle an 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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- 00007 Permit Reviewer: Dr. Trip Sinha (g) This permit shield is not applicabl e 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 Environ mental 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 Qua rterly 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 requirementof the p ermit.

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.

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- 00007 Permit Reviewer: Dr. Trip Sinha (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 co ntains 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 revi sion 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 thirt y (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 s ource, 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 I AC 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 theshipper on th e 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 complet e 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 co mpleteness 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 IA C 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.Alcoa, Inc.

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- 00007 Permit Reviewer: Dr. Trip Sinha (b) Any application requesting an amendment or modification of this permit shall be submitted to: Indiana De partment 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 Un der 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 in centives, 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

re quirements 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

Perm it Administration and Support Section, Office of Air Quality 100 North Senate Avenue MC 61

- 53 IGCN 1003 Indianapolis, Indiana 46204

- 2251 andAlcoa, Inc.

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- 00007 Permit Reviewer: Dr. Trip Sinha United States Environmental Protection Agency, Region V Air and Radiation Division, Regulation Development Branch

- Indiana (AR

18J) 77 West Jackson Bo ulevard 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 Permi ttee 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 pub lic 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 ter m 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 d escription 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 submi tted 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 IA C 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 thos e 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 accordan ce 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 toAlcoa, Inc.

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- 00007 Permit Reviewer: Dr. Trip Sinha 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 t he 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 paramet ers 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 equip ment 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 contai ning 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 Sectio n, 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 A pril 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.Alcoa, Inc.

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- 00007 Permit Reviewer: Dr. Trip Sinha 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 violat ed 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 conditio n of this permit if the appropriate performance or compliance test or procedure had been performed.Alcoa, Inc.

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- 00007 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 H undred (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 3 26 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 (6 0%) 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

acc ordance 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 lin e 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 Permi ttee 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) No tification 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.Alcoa, Inc.

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- 00007 Permit Reviewer: Dr. Trip Sinha (b) The Permittee shall ensure that a written notification is sent on a form pro vided 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 th e 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) W aste 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 s hall 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 noti fications 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 4 0 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 0.7 5 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 CF R 61.145(a). (g) Indiana Accredited Asbestos InspectorThe 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 t he 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 te sting 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,Alcoa, Inc.

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- 00007 Permit Reviewer: Dr. Trip Sinha 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 I ndianapolis, 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 Permi ttee 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 writte n 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 alread y 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 thePermittee n otifies:

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.Alcoa, Inc.

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- 00007 Permit Reviewer: Dr. Trip Sinha 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 Specification s [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 th e 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 Permi ttee 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 Emerg ency 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 no rmal 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 andtak ing 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

n ot 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:Alcoa, Inc.

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- 00007 Permit Reviewer: Dr. Trip Sinha (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 ta ken. 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 a ny 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 appr opriate 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 re sults. 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 respon se 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 pre vious 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

- 2251Alcoa, Inc.

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- 00007 Permit Reviewer: Dr. Trip Sinha 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 da te 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 mak es 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 impl emented 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 d escription 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 i n 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 ApplicabilityAlcoa, Inc.

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- 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 increa se 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 increas e 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 f ollowing 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 poll utant 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 indep endent 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 Quar terly 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 da te 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 sha ll 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 fr om 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.:

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- 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 emissio ns, 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 f rom 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, R eports 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 Per mittee 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 i nformation 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 conditio ners 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 app liances must be certified by an approved technician certification program pursuant to 40 CFR 82.161.Alcoa, Inc.

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- 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 des cription 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, i dentified 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, respectivel y. 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 alumi num 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 a t 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, construct ed 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 T ransfer Tower 61B Feed Conveyor (Section3) 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, constru cted 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.

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- 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, constru cted 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 transfe rring 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) bag house, 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 i n 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, andexhausting at Stack 144A.1.

One (1) baghouse, identified as the Tank 141NE Baghouse, wit h 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 al umina 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 transfer ring 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 B aghouse, and exhausting at Stack 144.1;Alcoa, Inc.

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- 00007 Permit Reviewer: Dr. Trip Sinha (14) S even (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 fr esh 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 capac ity 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 F eed 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 Contr ol 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 to ns, 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 freshalumina to flui dized 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 vibra tory 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 T ank 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 transport ing 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.

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- 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) r eacted 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; (2 3A) 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) an d 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 Conveyo r, 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, c ontrolled 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 i n 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 Stac k 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, identi fied 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 ven ting 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 fromAlcoa, Inc.

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- 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 Pol lution 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 Ba ghouse, 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 Cente r (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 an d 166

- FM

- 03 are controlled by the GTC, exhausting at Stack GTC. Airslides 166

- FM

- 02 and 166

- FM

- 03 arecontrolled 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

- B 6

- 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 controll ed 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 Scre en 61

- B5

- FM

- SC

- 01, thence to the feedbox for Airslide 166

- FM

- 05 and Airslide 166

- FM

- 06.Alcoa, Inc.

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- 0000 7 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 S tack 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, const ructed 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, wi th 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 tr ansferring 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 Sta tion 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 Transpo rter 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

- F M

- 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 capa city of 87 tons per hour, controlledAlcoa, Inc.

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- 00007 Permit Reviewer: Dr. Trip Sinha by Baghouse 1 12A, 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 a t 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. Emi ssion 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 Airv eyor 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 Baghouse275 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 Sy stem 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 Al umina 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 1 41A(NE) Baghouse 18 28.4 Tank 141(NE) System Tank 141A (NE) Baghouse 18 28.4Alcoa, Inc.

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- 00007 Permi t 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 con trolled 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

- 0 8 (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 59.7 9 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 Treatm ent 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) Air slide 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,Alcoa, Inc.

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- 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 particulat e 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 emiss ion 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 particu late 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 P M 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 wi th Baghouse 112A and Baghouse 166 shallbe 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.

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- 00007 Permit Rev iewer: 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 Tow er 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 Baghou se 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 an d 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 PollutionControl 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 contro l 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 wh en a facility that the baghouse controls is in operation.Alcoa, Inc.

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- 00007 Permit Reviewer: Dr. Tri p 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 Transp orter 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) Airslide 166

- 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 Requi rements [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 performPM, 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 re adings 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, issue d 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, In c.

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- 00007 Permit Reviewer: Dr. Trip Sinha (a) Each electrodynamic bag leak detection system shall be cal ibrated, 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 e missions 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 detecti on 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 instru mentation 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 adju stment 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 adjustmentfollows 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 s ystem 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 sta ck 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;Alcoa, Inc.

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- 00007 Permit Reviewer: Dr. Trip Sinha (4) A trained em ployee 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 n otations 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 rep aired 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

- Emerge ncy 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 de tector’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, 160 M.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 ofthe exhaust from bin ve nt 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 emiss ions 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 situa tion 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 rea ding 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

nex tAlcoa, Inc.

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- 00007 Permit Reviewer: Dr. Trip Sinha available process down time. Repairs shall be sc heduled 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 co ntinue 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 an d 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 detecti on 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 a t 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 d ay). (f) To document compliance with Condition D.1.7, the Permittee shall maintain records of theMethod 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.

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- 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 describin g 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 2 010, 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 ma ximum 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 monit ors 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 GT C

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 pro duction 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) potlin e, 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 Stack s 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, construct ed 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.

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- 00007 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) flu idized 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 161B 6.1

- 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 Di gging 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, a nd 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 maximu m 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 p articulate 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 3.70Alcoa, Inc.

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- 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 emissi on 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 Whe re: 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 P otlines 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 Po tline 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 scrubber195.2

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 195.2Alcoa, Inc.

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- 00007 Permit Reviewer: Dr. Trip Sinha Facility Venting From SO2 Emission Limit (lbs/hr) Potline No.5 Roof monitors associated with Potline 5 21.7 Po t 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 mon th 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

- Ge neral 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 alum inum 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 o f 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 requ est. 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 indicati ng 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 to tal 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 an y 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.

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- 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 sha ll 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 follo wing 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 o f 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 pr ior 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:Alcoa, Inc.

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- 00007 Permit Reviewer: Dr. Trip Sinha (1) Pro cedures 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 t hat 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 av erage 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: Wher e:

.. . . . . . . .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 cont rol 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 a s 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.

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- 00007 Permit Reviewer: Dr. Trip Sinha D.2.11 HAP Testing Requireme nts 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 th e 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 concent ration 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 fr om 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 test s. 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. ThePermittee 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 controlAlcoa, Inc.

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- 00007 Permit Reviewer: Dr. Trip Sinha 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 Permitt ee 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 violati on. (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 t o 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 Emi ssions 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 do es 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 theopacity exceeds forty percent (40%) per Method 9, then the Permittee

shall perform an additio nal 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 sche duled 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 v isible emissions shall be considered a deviation from this permit.Alcoa, Inc.

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- 00007 Permit Review er: 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 docu ment 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 th roughput 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 Permitte e 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 reading s, 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) Pu rsuant 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 dis ks, 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.

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- 00007 Permit Reviewer: Dr. Trip Sinha (iv) Records, such as a checklist or the equivalent, demonstrating that the daily visual inspection of the exhaust stack for eac h 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 Condit ion 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 roll ing 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 subm itted 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 obli gations 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 c onsistent 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 sta ndard. 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 requ ired information on paper or on a labeled computer disc using commonly available and compatible computer software.Alcoa, Inc.

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- 00007 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 Addre ss: 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 S O2 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.Alcoa, Inc.

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- 00007 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. Quarte r _______ 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 b een reported on: Submitted by: Title/Position: Signature: Date: Phone: Attach a signed certification to complete this report.Alcoa, Inc.

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- 00007 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 faci lity 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 maxim um 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, co ntrolled 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 T ank 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 o f 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 hou r, 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 T

146, constructed in 1959, with a maximum capacity of 18.0 tons per hour, controlled by the baghouse DC

- 2 18, 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, ident ified 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, andexhausting 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 calc ined 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;Alcoa, Inc.

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- 00007 Permit Reviewer: Dr. Trip Sinha (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 Scal e 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 i n 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 exhausti ng 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 a s 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 Manufact uring 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 Si ze 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 28.4Alcoa, Inc.

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- 00007 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 da ta 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 Limitati ons [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 emissio n 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 em ission 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 NESHA P [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 ismixed 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] Purs uant 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 contr ol POM emissions from the anode forming operations (which encompasses initial mixing through final forming);Alcoa, Inc.

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- 00007 Permit Reviewer: Dr. Trip Sinha (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 Hyg ienists 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 malfunctio ning 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 informat ion 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 abnor mal 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 associatedfacilities at all times when an emission unit that the baghouse controls

is in ope ration; 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 Sca le 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 fai lure 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

co mpliance 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 c orrective action according to Condition D.3.8(c).Alcoa, Inc.

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- 00007 Permit Reviewer: Dr. Trip Sinha 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 readin gs 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 CF R 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 dai ly 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 f an motorcurrent (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 ID EM, 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 fu me 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 procedur es 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 monitor ing 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 t han one exceedance shall be attributed in any 24

- hour period.Alcoa, Inc.

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- 00007 Permit Reviewer: D r. Trip Sinha 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 bagh ouse 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 l eak 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

a larm 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 ordecreased 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 o therwise 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 exh aust 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 pr evail, 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 expect ed to cause the greatest emissions;Alcoa, Inc.

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- 00007 Permit Reviewer: Dr. Trip Sinha (4) A traine d 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 b ag 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 t ime 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 tak e 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 exc eeds 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 pro cess 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 d oes not exceed forty percent (40%) per the Method 9 observation referenced above, inspection of the baghouse shall be scheduled at the nextavailable 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 unit s 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 b y Condition D.3.7.Alcoa, Inc.

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- 00007 Permit Reviewer: Dr. Trip Sinha (b) To document compliance wi th 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 requi red 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 P ermittee 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 inclu de 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 opera te 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 requiredby 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, o n 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 exha ust 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; andAlcoa, Inc.

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- 00007 Permit Reviewer: Dr. Trip Sinha (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 f rom 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 63.1 0(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 for ms 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.Alcoa, Inc.

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- 00007 Permit Reviewer: Dr. Trip Sinha SECTION D.4 ANODE BAKING PLANT FACILITY OPERATION CONDITIONS F acility 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 cont rol 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, constr ucted 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 t he 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 ef ficiency of 99.5%, and exhausting at Stack 265D.9; (5) One (1) un

- reacted alumina storage tank/truck unloading, constructed in 1981, with a maximumloading 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.Alcoa, Inc.

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- 00007 Permit Reviewer: Dr. Trip Sinha 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 Emi ssion 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 lo adout 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 parti culate 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 gre en 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 po unds 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 ren der 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 loadou t 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 perAlcoa, Inc.

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- 00007 Permit Reviewer: Dr. Trip Sinha hour, respectively. Compliance with these emissions limits shall ensure that the combined potential PM and PM10 emissions from the emissions un its 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, issue d 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 t ar 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 provi de 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 in let 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 s hall 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 withsulfur content below 0.75%. If p itch 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 achiev able 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)

co nsecutive 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] [4 0 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.Alcoa, Inc.

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- 00007 Permit Reviewer: Dr. Trip Sinha D.4.7 T F 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 poly cyclic 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 Subpar t 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 de scribed 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 i f 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. Co mpliance 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

- 446pollution 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 cont inue 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 t ruck loadout Reacted alumina truck loadout baghouse Unreacted alumina storage tank/truck unloading Un

- reacted alumina storage tank/truck unloading baghouseAlcoa, Inc.

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- 00007 Permit Reviewer: Dr. Trip Sinha Facility Baghouse Baked anode vacuum system Baked anode vacuum system baghouse (b) In the event that bag failure is observed in a mu lti

- 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] [4 0 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 mi nimum 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 incondition 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 = volumetri c 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.Alcoa, Inc.

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- 00007 Permit Reviewer: Dr. Trip Sinha (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 Permitt ee 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 pol lution 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 d ividing 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 h our 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, responseletter);

(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 da ily 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.Alcoa, Inc.

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- 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) M ethod 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 Commissio ner. 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. D uring 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 l oading 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

- Perfo rmance Testing. (c) In order to determine compliance with Condition D.4.2(e) and no later than January 5, 2010or 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

- Perfo rmance 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 Sub part 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

- 4 46 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 areAlcoa, Inc.

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- 00007 Permit Reviewer: Dr. Trip Sinha 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 alu mina 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 mainta in 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 malfunctioni ng, 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 t he 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 ofdetermining the number of exceedances, no more than one exceedance shall

be attributed in any 24

- hour period. D.4.17 Bag Lea k Detection System and Alternative Monitoring Plan (AMP) [SPM 173

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- 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 th e 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;Alcoa, Inc.

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- 00007 Permit Reviewer: Dr. Trip Sinha (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 Per mittee 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, fai l 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 a larm 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 leakdetection 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 pro blem 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 determin ed 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 (4 0%) within a reasonable period of time, orAlcoa, Inc.

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- 00007 Permit Reviewer: Dr. Trip Sinha (vi 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 schedul ed 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 no tify 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 visi ble 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 alum ina 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 themost 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 notatio ns of the stack exhaust for A

- 446 pollution control system baghouses, when the applicable bag leak detection system malfunctions, fails or otherwiseAlcoa, Inc.

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- 00007 Permit Reviewer: Dr. Trip Sinha 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 emissi on 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

reco rd 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 Metho d 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 Rec ord 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 Permit tee 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 63.8 50(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 tap e, 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 we re performedincluding 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 param eter 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.Alcoa, Inc.

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- 00007 Permit Reviewer: Dr. Trip Sinha 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 repor ted. 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 act ion 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 summar y 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 emissio ns. 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 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). (d) Pursuant to 40 CFR 63.850(e)(3), the Permitte e may report required information on paper or on a labeled computer disc using commonly available and compatible computer software.Alcoa, Inc.

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- 00007 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 Throughpu t 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

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- 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 P revious 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 complet e this report.Alcoa, Inc.

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- 00007 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, Newbu rgh, Indiana 47629 Part 70 Permit No.: T173

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- 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 emi ssions 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: Attac h a signed certification to complete this report.Alcoa, Inc.

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- 00007 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

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- 0 0007 Facility: Green anode baking ring furnace Parameter: Natural gas throughput Limit: Less than 75 million cubic feet per mon th 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 Mo nth 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.

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- 00007 Permit Reviewer: Dr. Trip Sinha INDIANA DEPARTMENT OF ENVIRO NMENTAL 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

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- 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. . Devi ation/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.

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- 00007 Permit Reviewer: Dr. Trip Sinha INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE OF AIR QUALITY COMPLIANCE DATA SECTION Part 70 Anode Baki ng 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

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- 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.Alco a, Inc.

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- 00007 Permit Reviewer: Dr. Trip Sinha SECTION D.5 ANODE ASSEMBLY & SPENT ANODE PLANT FACILITY O PERATION 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 blast ing 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) bag house, 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 weig ht 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 Stac k 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, controlle d 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 Stac k 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 exh austing 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, identifie d 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 uncont rolled.Alcoa, Inc.

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- 00007 Permit Reviewer: Dr. Trip Sinha Emission Limitations and Standards [326 IAC 2

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- 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 pl ant, 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 t ank 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 p rocess 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 exce eds 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.Alcoa, Inc.

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- 00007 Permit Reviewer: Dr. Trip Sinha Compliance Determination Requirements D.5.3 Testing Requirements [326 IAC 2

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- 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 Commissi oner. 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. Dur ing 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 loa ding 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 op eration 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) da ys 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 sta tus 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

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- 5(1)] D.5.5 Bag Leak Det ection System The Permittee shall operate the continuous bag leak detection system for the anode butt blastmachine. The bag leak detection system shall meet the following

requirements: (a) Each electrodynamic bag leak detection system shall be calib rated, 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 cubi c 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 e asily heard by plant operating personnel; (f) The bag leak detector shall be installed downstream of the fabric filter;Alcoa, Inc.

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- 00007 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 al arm 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 ca se 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)

m onth 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 beconsidered a deviation from this permit.

D.5.6 Bag Leak Det ection 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: F or 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.Alcoa, Inc.

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- 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 eval uation 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 assoc iated 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 Permitt ee 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 perc ent (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 expeditious ly

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) da ys 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 R eporting Requirement [326 IAC 2

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- 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 de tector. (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, whenthe 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 com pliance 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 s tacks. 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,:Alcoa, Inc.

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- 00007 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.

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- 00007 Permit Reviewer: Dr. Trip Si nha 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 enf orceable 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, construct ed 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 furn aces, 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 h olders, 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 aluminu m 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 16tons 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) grou p 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.

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- 00007 Permit Reviewer: Dr. Trip Sinha (9) One (1) group 1 furnace, identified as #8 EMC Complex East Hold er 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, wi th 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 secondar y 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 a luminum 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 forconstruction 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 to ns 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 Rota ry 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 Furn ace 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 ComplexAlcoa, Inc.

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- 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) T wo (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; Alumin um 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 thi s 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, wit h 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 p roduction 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 at70.F, and exhausting at Stack 134.69;

(23) One (1) aluminum p neumatic 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 scrubbe r, 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 th e 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 CoolingAlcoa, Inc.

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- 00007 Permit Reviewer: Dr. Trip Sinha Baghouses, each with an air flow rate of 18,000 acfm at 150oF, and exhaust ing 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 Rota ry 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 cons truction 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, reciprocatin g 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 I AC 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 Su pport, 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 1 2 21.7 #2 Offline West Holder None 12 21.7 #2 Offline East Melter ChargingRotoclone #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 C hip 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 ra tes 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.

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- 00007 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 Interpo lation 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 pe r 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 Mel ters 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 utili zed 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 em ission 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.

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- 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 deter mined 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 purcha sed 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 Mainten ance 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 th an 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 Maintenanc e 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:Alc oa, Inc.

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- 00007 Permit Reviewer: Dr. Trip Sinha Until the modification to the 8EMC west furnace is compl ete 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 n o 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 complianc e 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 fa ctor 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 s alt 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 offeed/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 r ate 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 w ith compliance determined at the end of each month. The following equation shall be utilized to determine compliance:Alcoa, Inc.

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- 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 chlorin e 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 Ma intenance 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 o r 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 l bs/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 spe cified by 40 CFR 63.1505(k)(1), multiplied by 1.46 for combinedchlorine 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 perio d, 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 in put rates less than or equal to 1.14 lbs/ton of feed/charge;Alcoa, Inc.

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- 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 combi ned 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, Mo nitoring, 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 degassin g 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 t he 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/t on 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 tonsper twelve consecutive month period, with compliance de termined 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 emi ssions 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 Conditi on 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.

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- 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 o f 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 fu rnace 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) Pursuan t 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.

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n S(OLG1 tons charged X OLG1 PM Ef/2000) < 202 tons/year; i =l where: OLG1 = Of f

- 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 con secutive 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 pla n. (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 poun ds 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 Baghous e.(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.

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- 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 ch arge/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 scr ap 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 emis sions 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 w hen 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 f rom the Rotary Group 1 Furnace Duct Heater shall not exceed 140 pounds per MMCF of natural gas.Alcoa, Inc.

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- 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 r equirements 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 Polluta nts 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, Subpar t 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 t he 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 alumin um 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) Purs uant 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.

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- 00007 Permit Reviewer: Dr. Trip Sinha (d) Pursuant to 40 CFR 63.1505(k), the Permittee shall comp ly 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 f or 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 con dition 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 mus t 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.

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. .

.. .

.

.

.

.

. 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
para graph (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 in

line 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 oremission 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 b y 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 pl an. (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; andAlcoa, Inc.

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- 00007 Permit Reviewer: Dr. Trip Sinha (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) Initia te 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 t o 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 op erating 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 f urnace using only clean charge as the feedstock; and (2) Operate each group 2 furnace using no reactive flux.Alcoa, Inc.

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- 00007 Permit Reviewer: Dr. Trip Sinha (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

c ontrol practices for minimizing emissions. The corrective actions taken shall include follow

up 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 th e 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, 200 0: (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 Com plex; (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 perio ds, 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 holdin g 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 six

minute averagingperiod, 65 pe rcent 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 site

specific test plan which satisfies all of the requirements, and shall obtain approval of the plan pursuant to the procedures, set forth i n 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 standar d 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).Alcoa, Inc.

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- 00007 Permit Reviewe r: Dr. Trip Sinha (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 applicabl e, 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 63.1 511(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 repres entative of other units if all of the following criteria are satisfied: (1) The tested emission unit shall use feed materials and charge rates which arecomparable to the emission units that it represents;

(2) The tested emission unit shall use the s ame 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.Alcoa, Inc.

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- 00007 Permit Reviewer: Dr. Trip Sinha (f) Establishment of monitoring and operating parameter values [40 CFR 6 3.1511(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 opera ting 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 m ethods 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, S ubpart 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 furn ace 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 te sts to measure emissions of PM and D/F at the outlet of the controldevice 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 monit oring 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) Sec ondary 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 fee d/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;Alcoa, Inc.

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- 00007 Permit Reviewer: Dr. Trip Sinha (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 aff ected 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 esta blish 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 ea ch 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 w eight 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 = Fractio n of solid reactive chloride flux that is chlorine (e.g., F =

0.75 for magnesium chloride); and W2 = Weight of solid reactive flux.Alcoa, Inc.

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- 00007 Permit Reviewer: Dr. Trip Sinha (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 so lid 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

- injec ted 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) U se 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 TE (Eq. 9)

Where: ECPM = The mass

- weighted PM emission s 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 em ission 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 mass

weighted emissions for the secondary alum inum 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)).Alcoa, Inc.

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. .

.. .

.

.

.

.

. n i 1 ti

n i 1 tiHCl ti CHCl T E T E (Eq. 10) Where: ECH Cl = 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 te st 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 mass

weight ed 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 TE (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 c lean 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 measuremen ts 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)]Alcoa, Inc.

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- 00007 Permit Reviewer: Dr. Trip Sinha D.6.12 Non NESHAP Emission Units Testing Requirements [326 IAC 2

- 7

- 6(1), (6)] [326 IAC 2

- 1.1

- 1 1] (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 co oling 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 sensitivi ty 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 year s 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 fiv e (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 leastonce every five (5) years from the date of this valid compliance

demonstrat ion. 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), no t 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 thi s 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 p erform 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 demonstrat e 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 conden sible 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 ConditionAlcoa, Inc.

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- 00007 Permit Reviewer: Dr. Trip Sinha 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 dem onstration. 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 t he 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 operatio n 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 clo sed, 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 s ervice. 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 Rotar y Group 1 Furnace Duct Heater, and the Rotary Group 1 FurnaceBaghouse 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 emiss ions 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, S ubpart 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 t his section. Monitoring requirements for each type of emission unit are summarized in Table 3 to 40 CFR 63, Subpart RRR.Alcoa, Inc.

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- 00007 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 aft er 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 determi nes 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 followi ng 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 so urce 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 mainten ance 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) Procedure s 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 whe n 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 cont rol device that is consistent with the manufacturer's instructions and recommendations for routine and long

term maintenance. (8) Documentation of the work practice and pollution prevention measures used to achieve compliance with the applicable em ission limits and a site

specific 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.Alcoa, Inc.

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- 00007 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, an d 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 Permitte e 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 t ime 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 me asured. (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 conti nuously 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 ―Fabri c 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 Cente r (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 i nstalled, 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 emissi ons 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.

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- 00007 Permit Reviewer: Dr. Trip Sinha (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 i s 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 de tector 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 th e 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 d elay 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 dem onstrates 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 i n 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 t emperature 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 Natio nal 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.

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- 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 com plete 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 setti ng 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 r eactive 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 (ii i) 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 gaseo us 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 c ycle 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 a nd record the total reactive flux injection rate for each operating cycle ortime 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:Alcoa, Inc.

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- 00007 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 parameter s 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 f eed/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/char ge 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 ai r 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

c oating

- to

- scrap ratio can be documented), the Permittee may include a program in thesite

- 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/ch arge 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 prop ortion 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 unitsAlcoa, Inc.

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- 00007 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 emissi on 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 limi t 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 emiss ion 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 procedu res 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 a mong 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 period s 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 u nit 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;Alcoa, Inc.

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- 00007 Permit Reviewer: Dr. Trip Sinha (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 b y 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 det ection 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 ofdetecting PM emissions at concentrations of ten (1 0) 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 devi ce 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 alar m 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 a mong detectors;Alcoa, Inc.

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- 00007 Permit Reviewer: Dr. Trip Sinha (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, a veraging 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 adjus tment 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 em ployee 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 st artup 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

s hall 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 spec ified 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 fo ur (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. Operation s 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 V ent 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;Alcoa, Inc.

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- 00007 Permit Reviewer: Dr. Trip Sinha (b) For proc esses 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 operation s, 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 appeara nce 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

– Resp onse 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 monthcommencing on the date it resumes operation.

Record Keeping and R eporting 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 ret ain 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 [4 0 CFR 63.1517(b)(1)]:Alcoa, Inc.

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- 00007 Permit Reviewer: Dr. Trip Sinha (i) If a bag leak detecti on 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 de scription 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 tem peratures 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 ex planation 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) Record s of 15

- minute block average weights of gaseous or liquid reactive flux injection, total reactive flux injection rate and calculations (includingrecords of the identity, composition, and weight of each addition of

gaseous, liquid or solid reactive f lux), 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 furna ce 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 labe ling 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.

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- 00007 Permit Reviewer: Dr. Trip Sinha (11) Records for any approved alternative monitoring or test procedure [40 CFR 63.15 17(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 emi ssions 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 pla n 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 t he 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 e missions 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 8EM C west holding furnace.

(3) NOx emissions from the 8EMC east and west holding furnaces.Alcoa, Inc.

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- 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 docu ment 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 record s 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 8W H 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 t he #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 we st 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 main tain 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 maintai n 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.

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- 00007 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 Con dition 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 we ekly 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 rotoclo ne, 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) Al l 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 shalldevelop 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, shut down, 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) Proce dures 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 actio ns taken to correct the malfunction or minimize emissions.Alcoa, Inc.

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- 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 spec ified 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 duri ng 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 consis tent 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 limitati on 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 andprocedures, 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 requir ed 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.

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- 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.

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- 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 P ermit 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.

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- 00007 Permit Reviewer: Dr. Trip Sinha INDIANA DEPARTMENT OF E NVIRONMENTAL 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: A ttach a signed certification to complete this report.Alcoa, Inc.

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- 00007 Permit Reviewer: Dr. Trip S inha 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/Pos ition: Signature: Date: Phone: Attach a signed certification to complete this report.Alcoa, Inc.

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- 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

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- 00007 Facility: 8EMC east and 8EMC west holding furnaces Parameter: NOx Emissions Limit: Shall not exceed 15.89 to ns 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.

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- 00007 Permit Reviewer: Dr. Trip Sinha INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE OF AIR QUALITY COMPLIANCE DATA SECTION PM Emissions Quarterly Report Source Name: Alco a 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.

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- 00007 Permit Reviewer: Dr. Trip Sinha INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE OF AIR QUALITY COMPLIANCE DATA SECTION PM10 Emission s 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: 8E MC 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 Tot al . 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.

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- 00007 Permit Reviewer: Dr. Trip Sinha INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE OF AIR QUA LITY 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 Opera tion 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 R ate(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.

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- 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 i n 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 Significa nt Permit Modification No.:

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- 00007 Permit Reviewer: Dr. Trip Sinha INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE OF AIR QUALITY COMPLIANCE DATA SECTI ON 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 comp lete this report.Alcoa, Inc.

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- 00007 Permit Reviewer: Dr. Trip Sinha INDIANA DEPARTMENT OF ENVIRONME NTAL 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. B ox 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/Positi on: Signature: Date: Phone: Attach a signed certification to complete this report.Alcoa, Inc.

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- 662 7

- 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/c harge 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. . Devia tion/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.

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- 00007 Permit Reviewer: Dr. Trip Sinha INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE OF AIR QUALITY COMPLIANCE DATA SECTION PM Emissions Quart erly 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.

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- 00007 Permit Reviewer: Dr. Trip Sinha INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE OF AIR QUALITY COMPLIANCE DATA SECTION Natural Ga s 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 Fa cility: 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 1 2 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.Alc oa, Inc.

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- 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, N ewburgh, 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) Dros s (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.

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- 00007 Permit Reviewer: Dr. Tri p 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: T itle/Position: Signature: Date: Phone: Attach a signed certification to complete this report.Alcoa, Inc.

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- 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 Hw ys. 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 twelv e (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.

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- 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 Li mit: 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. . Dev iation/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.

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- 00007 Permit Reviewer: Dr. Trip Sinha SECTION D.7 ROLLING MILLS PLANT FACILITY OPERATION CONDITIONS Facility Description [326 IAC 2

- 7

- 5(15)] (The inf ormation 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, u sing 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, ident ified 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 reduct ion 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 exhaustin g 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 wi th 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,

con structed 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 furna ce, 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 n atural 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, exhaustin g to Stack 816.12;Alcoa, Inc.

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- 00007 Permit Reviewer: Dr. Trip Sinha (14) One (1) annealing furna ce, 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 n atural 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, exhaustin g 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 furnace s, 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 pr eheat 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, identi fied 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 natu ral 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 max imum 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 exhaus ting 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, an d 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.

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- 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 i ngots 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, emissi ons 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 an d 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 th e process weight rate in excess of sixty thousand (60,000) pounds per hour by use of the equation:E = 55.0 P0.11

- 40Alcoa, Inc.

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- 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 emiss ion 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 Relat ing 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 ope rated 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 eac h. 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 spe ed 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 operatin g 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.

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- 00007 Permit Reviewer: Dr. Trip Sinha a = Plume rise factor which is used to make allowance for less than theor etical 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 Limita tions 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 w hich 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 le ss 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 matte r emission rate as follows:Alcoa, Inc.

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- 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 he ight 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

an nealing 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 respec t 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 c apacity, 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 o f 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 num ber 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 p a Q H pa Q hAlcoa, Inc.

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- 00007 Permit Reviewer: Dr. Trip Sinha Where: pa = the actual controll ed 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 e missions 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 pa rticulate 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 terra in. 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 mak e 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 stackheight to represen t 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 parameter s 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.

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- 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.

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- 00007 P ermit 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 n ot 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, iden tified 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

c oating 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 syst em 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 contro l 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 toStacks 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 maxi mum capacity of 8,000 gallons with no control, exhausting to stack 819.20;Alcoa, Inc.

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- 00007 Perm it 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 8 19.17; (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 T ank, 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 con trol, 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 P rocesses), 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 t housand (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 Jul y 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 noless 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 appli cator ("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 volati le 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.

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- 00007 Permit Reviewer: Dr. Trip Sinha

..

. .

.

.

. .

.

.

. 365 y 1
y 365 I Input Limit (tons/365days) Where: I = the VOC inp ut 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/solv ent 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 c ompliance 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 11,2006 99.25 14,933

7 99.5 22,400 The Permittee indicated its selecti on 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.

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- 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 o r 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 clas sified 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 wi th 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 us age 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 sha ll 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 NES HAP [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 sp ecified 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 E mission 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 i n 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 comp liance period; andAlcoa, Inc.

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- 00007 Permit Reviewer: Dr. Trip Sinha (2) No more than 0.28 kilogr am (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 ma lfunction 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 temper ature 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 R elating 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 byreference as 326 IAC 20

- 1

- 1, apply to the affected source, except when

otherwise s pecified 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 organ ic 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.

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- 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 gr ound 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 mater ials (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 demo nstrate 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

ra te. 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 C CL2, CCL3, and CPL 6 (a) Capture and control to achieve the emission rate limit [40 CFR 63.5170(g)]

- Since thePermittee 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 c ondition. (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)];Alcoa, Inc.

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- 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 ef ficiency, 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 i n 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 qj 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 destru ction 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 = vola tile 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; M i = mass of coating material, i, applied in a month, kg;Alcoa, Inc.

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- 00007 Permit Reviewer: Dr. Tri p 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 fo r 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 coatingmaterial, i, expre ssed 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 alw ays - controlled work stations in the facility; p = number of different coating materials applied in a month; andAlcoa, Inc.

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- 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 solidscontent 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 o rganic 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, LANN UAL, using Equation 6 of this section [40 CFR 63.5170(f)(1)(x):Alcoa, Inc.

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- 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 diffe rent 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 re quired 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 t he 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 c oil 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 fo llows: (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.

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- 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 b y 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

r eceived; 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 so lids 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 follo wing 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 solidsapplied, then the coil coating line CPL6 is in compliance with the

standard. Each monthly calculation is a performance test.Alcoa, Inc.

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- 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 th an 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 pa ragraphs (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 re sults 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 th e 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 t he 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

r aw material used, weighted by the mass fraction of each raw material used in thematerial. 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 wit h 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 perfo rmed 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 comp liance 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 t he 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 C FR 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.

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- 00007 Permit Reviewer: Dr. Trip Sinha The Permittee shall use the data collected during the performance test to calcul ate 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 d ate 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 d emonstrating 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 63.5 150] [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 ofthe temperature being monitored in degrees Celsius, or 1 deg. Celsius,

whichever is greater. [40 CFR 63.5150(a)(3)(i)] [40 CFR 60.46 4(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 reco rds 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 captur e 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 a t 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 s ystem. (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.

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- 00007 Permit Reviewer: Dr. Trip Sinha (f) Any deviation from the required operating par ameters, 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 1 2] [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 shal l 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 b e 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 VO C 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) Re cords 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; (i i) 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 efficienc y 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 with40 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 i n accordance with Section C

- General Record Keeping Requirements, of this permit.Alcoa, Inc.

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- 00007 Page 167 of 178 Newburgh, Indiana Modified by: Jillian Bertram T 173

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- 0000 7 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 paragr aphs (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 malfunc tion 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) F or 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 subm it 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 q uarter, 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

- Genera l 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 comp liance 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 formlocated 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 certi fication by the ―responsible official‖ as defined by 326 IAC 2

- 7

- 1(34).Alcoa, Inc.

– Warrick Operations Significant Permit Modification No.:

173

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- 00007 Page 168 of 178 Newburgh, Indiana Modified by: Jillian Bertram T 173

- 6627

- 00007 Permit Re viewer: 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 rati o, 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 s hall 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 t o 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 pe r 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 Preventati ve 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 timeswhen 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

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- 00007 Page 169 of 178 Newburgh, Indiana Modi fied 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, wit hin 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 Per mit 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 V OC 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 Fac ility: 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 (Ton s) 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 mont h. 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

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- 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 U sage 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/Po sition: 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

- 6 627

- 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 m onth 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 Bert ram 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) c onsecutive 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

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- 00007 Page 174 of 178 Newburgh, Indiana Modified b y: 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 oth er 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 Signi ficant Permit Modification No.:

173

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- 00007 Page 175 of 178 Newburgh, Indiana Modified by: Jillian Bertram T 173

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- 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 (Fac simile 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: Descripti on of the Emergency: Describe the cause of the Emergency:Alcoa, Inc.

– Warrick Operations Significant Permit Modification No.:

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- 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 min imize 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 material s 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

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- 00007 Page 177 of 178 Newburg h, 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 MO NITORING 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 Re quirement (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 Deviati on: Number of Deviations: Probable Cause of Deviation: Response Steps Taken:Alcoa, Inc.

– Warrick Operations Significant Permit Modification No.:

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- 00007 Page 178 of 178 Newburgh, Indiana Modified by: Jillian Bertram T 173

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- 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 per mit 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 Deviat ions: 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 Tec hnical 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, 3 334 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) Al coa 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 locate d 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. 1 73

- 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

- 26 942

- 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; andAlcoa 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, 20 00, 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. Warric k 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 Colu mbia 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 R eview 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 therequirements 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 requi rements 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, fug itive 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 Revi ewer: 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 10 0 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 twe nty

- 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 applicati on, 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 Pot line No.1 A

- 398 pollution control system (B2) and exhaust at Stacks 160B2.1

- 160B2.14 or controlled by a new air pollutioncontrol 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 ta nk, 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 alum ina. 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 Po llution 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 f rom 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 airf low 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 pollutio n 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 i ts 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 re quired 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 modif ication 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 L imit 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 mo nth 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 HA Ps 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 Th e 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 permitmodification, and only to the extent that the effect of t he 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 10Alcoa Inc. Warrick Operations Page 6 of 25

Newburgh, Indiana T SD 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 s ource 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 informat ion 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, Nonattainm ent 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 3 26 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 (NESHAP s) (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 uni t 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 invol ved: 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 U nit (Y/N) Potline No. 1

– Potline N 140.62 14.06 100 N NAlcoa 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 Em ission 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 ar e 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 DeterminationThe following state rules are applicable to the source due to the

mod ification: 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 appl icability 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 wi th 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 modifie d 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, Pa rt 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 s ubsequent 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 N o.: 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 wh en 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 a ccomplished 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 t o 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 stat e 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 satisf y 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 v iolation 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 monitori ng 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 to n 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

- 000 07. 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 FACILI TY OPERATION CONDITIONSAlcoa Inc. Warrick Operations Page 9 of 25

Newburgh, Indiana TSD for Significant Permit Modification No.: 173

- 29035

- 00007 Permit Reviewer: Jillian Bertram Facility Description [326 IAC 2

- 7

- 5(15)] (The information descri bing 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) Fe ed 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 exha usting 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 Emiss ions Limitations for Manufacturing Processes), the allowable PM emission rate from the below listed processes shall be limited as follows:Alcoa Inc. Warrick Operations Page 10 of 25

Newburgh, Indiana TSD for Significant Permit Modification No.: 1 73

- 29035

- 00007 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 Fe ed 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 Baghou se 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 p rocess 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, ident ified 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.Alc oa Inc. Warrick Operations Page 11 of 25

Newburgh, Indiana TSD for Significant Permit Modification No.: 173

- 29035

- 00007 Permit Reviewer: Jillian Bertram One (1) fluidized bed scrubber and baghouse system, consisting of seven (7) fluidized bed scrub bers 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,

a nd 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 a ssociated 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 compl iance 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 an d 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 pot line 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 determi ne the compliance status with Condition D.2.6, the Permittee shall use the following equation: TP1 * EFP1HF = Hydrogen Fluoride Emissions from Potline No. 1Alcoa Inc. Warrick Operations Page 12 of 25

Newburgh, Indiana TSD for Significant Permit M odification No.: 173

- 29035

- 00007 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 aluminu m 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 suff icient 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 N o. 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 l ocated 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 O FFICE 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 perAlcoa Inc. Warrick Operations Page 13 of 25

Newburgh, Indiana TSD for Significant Permit Modification No.: 173

- 29035

- 00007 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/Pos ition: 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, t he 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

ac cording 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 shallinclude the certification by the "responsible official" as defined by 326

IAC 2

- 7

- 1(34).Alcoa Inc. Warrick Operations Page 14 of 25

Newburgh, Indiana TSD for Significant Permit Modification No.: 173

- 29035

- 00007 Permit Reviewer: Ji llian Bertram 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 prov ided 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(N E), 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 p revailing, 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 EPAMethod 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 pro cess down time. Repairs shall be scheduled as expeditiously as practical, based on the inspection results.Alcoa Inc. Warrick Operations Page 15 of 25

Newburgh, Indiana TSD for Significant Permit Modification No.: 173

- 29035

- 00007 Permit Reviewer : Jillian Bertram (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 ba ghouse 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 re sponse 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 ope rations. (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 fort y 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 situati on 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 thePermittee shall perform an additional Method 9 readi ng 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

nex t 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 toAlcoa In c. Warrick Operations Page 16 of 25

Newburgh, Indiana TSD for Significant Permit Modification No.: 173

- 29035

- 00007 Permit Reviewer: Jillian Bertram Excursions and Exceedances. Abnormal emissions alone are not a deviation from this permit. Failure t o 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 No tations (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 pro cess. (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 reaso nable 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 t he 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 accordan ce 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 Sec tion C

- Response to Excursions and Exceedances, shall be considered a deviation from this permit. ***Alcoa Inc. Warrick Operations Page 17 of 25

Newburgh, Indiana TSD for Significant Permit Modification No.: 173

- 29035

- 00007 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 disco ntinuous 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 fo r 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 determin ed 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 (4 0%) 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 obse rvations 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 resp onse steps in accordance with Section C

– Response toExcursions 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 Impacto r Baghouse shall be performed once per day. A trained employee shall record whether emissions are normal or abnormal.Alcoa Inc. Warrick Operations Page 18 of 25

Newburgh, Indiana TSD for Significant Permit Modification No.: 173

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- 00007 Pe rmit Reviewer: Jillian Bertram (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 o f 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) min ute 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 fort y 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 Permitte e 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 observat ion 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 14 0 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 d ay 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, theAlcoa Inc. Warrick Operations Page 19 of 25

Newburgh, Indiana TSD for Significant Permit Modification No.: 173

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- 00007 Permit Reviewer: Jillian Bertram Permittee shall take reasonable response steps in accordance with Section C

- Response to Excursions and Exceedances. A pr essure 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 Det ection 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 un til 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 complet ion 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.1.1 08 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 ta ken 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 Part iculate 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 BaghouseAlcoa Inc. Warrick Operations Page 20 of 25

Newburgh, Indiana TSD for Significant Permit Modification No.: 173

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- 00007 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, OA Q 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 ti me 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 r ange 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 qualifi es as an emergency and the Permittee satisfies the requirements of the emergency provisions of thispermit (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 pressu re 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 sha ll 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 Scal e 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 ofAlcoa Inc. Warrick O perations Page 21 of 25

Newburgh, Indiana TSD for Significant Permit Modification No.: 173

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- 00007 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 cal ibrated 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

un til 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 f ailure 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 o f 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 di d 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 pre ssure 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 ment ioned 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 pressur e 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

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- 00007 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 baghous e 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 un der 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 emergen cy 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 repla ced. 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 p rovisions 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, fl ow rate, air infiltration, and leaks.Alcoa Inc. Warrick Operations Page 23 of 25

Newburgh, Indiana TSD for Significant Permit Modification No.: 173

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- 00007 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 Pe rmittee 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 Con ditions 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 test ing, 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 Subp art 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 on ce every five (5) years from thedate 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

- Performan ce 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 performanc e 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 f or 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;Alco a Inc. Warrick Operations Page 24 of 25

Newburgh, Indiana TSD for Significant Permit Modification No.: 173

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- 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) Pu rsuant 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 potl ine 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 63.8 47(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; Equat ion 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 contr ol 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 o f 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 t he 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

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- 0 0007 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 sha ll 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 Signifi cant 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 Partici pation and Permit Guide on the Internet at: www.idem.in.govIndiana Department of Environmental Management

Office of Air Quality Addendum to the Technical Support Document (ATSD) for a Part 70 Significant Permit Modification Source Backgroun d 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 permi t 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 w hether 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 require d 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 Appendi x 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

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- 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, O ffice 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 Intern et 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.govPart 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

- 00007Alcoa Inc.

– Warrick Operations Significant Source Modification No. 173

-

29096

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- 2 9035

- 00007 T173

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- 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 Emissio n 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 Plat e 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 material s 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 am ounts 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, s uch 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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- 00007 Permit Reviewer: Jillian Bert ram (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 t he 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 con tain 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 op erations 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 coa ting 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 commenc ed 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 theArmed 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 pro duce 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 ex clusively 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, wh ichever is later. Standards and Compliance RequirementsAlcoa Inc.

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- 00007 Permit R eviewer: Jillian Bertram § 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 paragraph s (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 requir ements 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 un vented 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 subpar t?‖, 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 blast ing 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 op erate 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 t hem 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 inparagraphs (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 h olding 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 o bjects 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 meter s) 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 manage ment 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 spe cified in paragraphs (a)(3)(i)(A) through (E) of this section.Alcoa Inc.

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- 00007 Per mit Reviewer: Jillian Bertram (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 c onveyors 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 specif ied 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 out doors, 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 t hat 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 determinatio ns 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 p erform 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

e missions in accordance with §63.11517(a), ―Monitoring Requirements.‖ (B) You must report all instances where visible emissions are detected, along with any corrective actiontaken and the results of subsequent follow

- up inspections for visible

emissi ons, 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 m ust 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 s ubpart?‖, 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 necessa ry 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.Alcoa Inc.

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- 00007 Permit Reviewer: Jillian Bertram (c) Standards for dry grinding and dry polishing with machines. If you own or oper ate 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 material s 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 specifica tions 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 parag raphs (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 grind ing 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 d efined 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 w hen 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

re quirements 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 si des 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 cabl es. (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 So ciety of Heating, Refrigerating, and Air

Conditioning Engineers (ASHRAE) Method 52.1, ―Gravimetric and Dust

- Spot Procedures for Testing Air

Cleaning Devices Used in General Ventilation for Removing Particulate Matter, June 4, 1992‖ (incorporated by ref erence, 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) air

atomized spray gun operating at 40 ps i 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 t his 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), ―No tification, 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.Alcoa Inc.

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- 00007 Permit Reviewer: Jillian Bertram (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 techn ology 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 sp ray 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 ―Guideli nes 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 sol vents, 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 requirem ents of this paragraph do not apply to the students of an accredited painting training program who are under the direct supervision of an instructorwho meets the requirements of this paragraph. The requirements of this

paragraph do not apply to operat ors 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 personn el, 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, a nd 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 descri ption 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/orAlcoa Inc.

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- 00007 Permit Re viewer: Jillian Bertram 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 specifie d 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 traini ng 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) [R eserved] (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 ba sis), you must demonstrate thatmanagement 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

a ccording 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), ―Notif ication, 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 requ ired 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 proces s 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;Alcoa Inc.

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- 00007 Permit Reviewer: Jillian Bertram (iv) Optimize welding process variables (e.g., electrod e 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) Requir ements 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 i n 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, a nd 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 emis sions 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 d etermination 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 fr om 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 opac ity 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 emissio ns 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 opacit y 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 fum e 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.Alcoa Inc.

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- 00007 Permit Reviewer: Jillian Bertram (7) Tier 3 requirements for opacities exceeding 20 percent. For each visual determination of emi ssions 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 sect ion. (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 requir ements 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 ad dress;(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 a nd 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, ac cording to the requirements of §63.11519(b)(1), ―Notification, recordkeeping, and reporting requirements.‖Alcoa Inc.

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- 00007 Permit Reviewer: Jillian Bertram (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 accorda nce 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 emissi ons 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 fug itive 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 pe r 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 th is 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 fug itive 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 thefrequency of EPA Method 22 testing to once per 60 days of operation of

the process (3 calendar months). If visible fugitive emissions are detected duri ng 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 opacitie s 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.Alcoa Inc.

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- 00007 Permit Reviewer: Jillian Bertram (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 w eekly 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 Metho d 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 vi sible 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 exce ed 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 [Res erved] § 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 finish ing 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, 2 008, 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 t ype 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 complian ce 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) Y our 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; andAlcoa Inc.

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- 00007 Permit Rev iewer: Jillian Bertram (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 ea ch 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 parag raph (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 repo rt 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 c alculation. (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 insp ector 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 affe cted 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 sect ion. (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 concerningexceedences 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, subm ission 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 certificati on 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) Comp any 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 calcula tion. (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 affectedAlcoa Inc.

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- 00007 Permit Reviewer: Jillian Bertram source which performs visual determination of fugitive em issions 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 o f 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 Pl an 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 Emission s 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.Alcoa Inc.

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- 00007 Permit Reviewer: Jillian Bertram (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 tak en 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 o f 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 devi ces 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 acc ordance 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 i n 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 tran sfer 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 ins tructions. 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 demonstratio n 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 Site

Specific 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 a ccordance 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.Alcoa Inc.

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- 00007 Permit Reviewer: Jillian Bertram (13) Manufacturer's instructions. If you comply with this subpart by operating any equipment a ccording 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 maintaine d 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

re cord. (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 remaini ng 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 impleme ntation 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 authoriti es 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 paragra phs (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 Genera l 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 unde r §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 r ecordkeeping/reporting‖ is defined in §63.90.Alcoa Inc.

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- 00007 Permit Reviewer: Ji llian Bertram § 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 duc twork, 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 f rom 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 inta ke 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 ga s 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 mecha nism. 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 proce ss 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 withou t 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 collect ing 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, c ontrol 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 n ew 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 cus tomers, 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.Alcoa Inc.

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- 00007 Permit Reviewer: Jillian Bertram Machining means dry metal turning, milling, drilling, boring, tapping, planing, broaching, sawing, cutting, shaving, shearing, threading, re aming, 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 hand

held devices and any process emp loying 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 mate rial 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 fabricatio n 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, t he 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 cont rol agents, smokes, and incendiaries used by DoD components, including bulk explosives andchemical 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 functiona l 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 purpose s 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 operation s 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 descri ptions 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 foo t, 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:Alcoa Inc.

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- 00007 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 f rom 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 an d 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 necessa ry 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 wit h a paint cup capacity that is less than 3.0 fluid ounces (89 cubic centimeters). (2) Surface coating application using powder coating, hand

- held, non

refillable aerosol containers, or nonatomizing application technology, including, but not limited t o, 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 sp ray 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 centim eter (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 prope lled 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 maycontain 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 d evices 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 unve nted 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 t he 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 molte n metal.Alcoa Inc.

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- 00007 Permit Reviewer: Jillian Bertram Welding rod containin g 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 so urces 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 indu stry 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 equ ipment 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 prod ucts, 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 p ower marine boilers, pressure and nonpressure tanks, processing and storagevessels, heat exchangers, weldments and similar products.

Fabricated Structural Metal Manufacturing Establishments primarily engaged in fabricating iron and steel or ot her metal for structural purposes, such as bridges, buildings, and sections for ships, boats, and barges. Heating Equipment, Establishments primarily engaged in manufacturing heatingAlcoa Inc.

– Warrick Operations Significant Source Modification No . 173

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- 00007 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, do mestic 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 oi l 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), mechani cal (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 constr uction 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, aeri al 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 indust rial, 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 forg ing manufacturing process, where purchased iron and steel metal is pressed, pounded or squeezed under great pressure into high strength parts known asforgings. The forging process is different from the casting and

foundry processes, as metal used to make forged parts is neverAlcoa Inc.

– Warrick Operations Significant Source Modification No. 173

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- 00007 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; nonfe rrous 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; fla nges; 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 f or 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 Prohi bited 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 confi dentiality. 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 Pleas e 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 Ai r Quality SUBJECT: Final Decision Title V 173

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- 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, pleas e 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 contac t 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 11/30/07INDIANA 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

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- 000 07 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 a long 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 app lication 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. Enc losures Final Library.dot 11/30/07FACSIMILIE OF PS Form 3877

Mail Code 61

- 53 IDEM Staff DPABST 9/14/2010 ALCOA

- Warrick Operations 173

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- 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 Add ress 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 (Sourc e 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 O fficial) 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 Boonvi lle 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 56 5 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 t o 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 For m 3877

Mail Code 61

- 53 IDEM Staff DPABST 9/14/2010 ALCOA

- Warrick Operations 173

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- 00007 (Final) AFFIX STAMP HERE IF USED AS CERTIFICATE OF MAILING Name and address of Sender . Indiana Department of Environmental Management O ffice 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 Pub lic 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 SenderTotal number of Pieces

Received at Post Office Postmaster, Per (Name of Recei ving 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 $50,00 0 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 Mai l 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.=