## February 19, 2010

Steve Wright Columbia Falls Aluminum Company, LLC 2000 Aluminum Drive Columbia Falls, MT 59912

RE: Compliance Monitoring Report (CMR) and Full Compliance Evaluation (FCE)

Dear Mr. Wright:

Enclosed is a copy of a CMR for the Columbia Falls Aluminum Company, LLC (CFAC) aluminum smelting facility. This report covers the period from April 17, 2008, to February 19, 2010, and documents a FCE for the same period. During the most recent inspection, the facility appeared to be in compliance with all of the applicable conditions and limitations contained in CFAC’s air quality permits.

Should you have any questions or comments about this report, please contact me at (406) 444-4114.

Sincerely,

Robert Gallagher Environmental Engineer Specialist Air Resources Management Bureau E-mail: rgallagher@mt.gov

Enclosure

cc: Betsy Burns, EPA – Montana Wendee Jacobs, Flathead City – County Health Department

### MONTANA DEPARTMENT OF ENVIRONMENTAL QUALITY AIR RESOURCES MANAGEMENT BUREAU

COMPLIANCE MONITORING REPORT

This report includes a full compliance evaluation, with any partial evaluations and any investigations conducted for the period from April 17, 2008, to February 19, 2010.

Inspector: Robert Gallagher Report Date: February 19, 2010

I. Facility Information

A. Facility Name: Columbia Falls Aluminum Company, LLC Location: Section 3, Township 30 North, Range 20 West, Flathead County Latitude: 48.3928 Longitude: -114.13969 Mailing Address: 2000 Aluminum Drive Columbia Falls, MT 59912

B. Source Contact(s): Steve Wright – Environmental Manager Telephone #: (406) 892-8211

C. Title V Designation (CDS Class) : A – Major

D. Mega-Site Designation: No

E. SIC Code: 3334 – Primary Aluminum Production NAICS Code: 331312 – Primary Aluminum Production

F. AIRS ID #: 30-029-0012

G. Permit #: Montana Air Quality Permit (MAQP) #2655-05 Montana Air Quality Operating Permit (MAQOP) #OP2655-02

H. Area Attainment Status: Attainment, but Adjacent to the Columbia Falls Particulate Matter with an aerodynamic diameter less than or equal to 10 microns (PM 10 

### ) Non-attainment area

I. AFS Action Form Submitted for Full Compliance Evaluation: Yes

II. General Plant Description:

Columbia Falls Aluminum Company, LLC (CFAC) ope rates five vertical stud Soderberg potlines at the Columbia Falls plant. Each potline has 120 individua l cells that produce aluminum by the Hall-Heroult process. The Columbia Falls plant’s annual ope rating capacity is approximately 185,000 tons of aluminum, based on an average current efficiency of 90.5%.

The Hall-Heroult process consists of passing an electric current through aluminum oxide ore, or alumina (Al 2 

### O 3 

### ), dissolved in molten cryolite. The reduction process takes place in a vertical stud Soderberg style pot. Soderberg technology describes the type of consumable carbon anode used in the

### process.

Buildings, called potrooms, house the cells or “pots”. Two potrooms connected electrically in series form one potline. CFAC has 10 potrooms that comp rise the five potlines. Emissions from each pot aredivided into two categories, primary emissions and secondary emissions. The primary-air-pollutioncontrol system treats the primary emissions captured at the pots to remove gaseous and particulate emissions. This control system is an Alcoa designed A398 dry-alumina scrubber. Secondary emissions are fugitive emissions from the pots vented out the roofline of the potrooms.

A molten bath of cryolite, heated to about 950°C (1740°F) receives alumina. Through the electrochemical process, electricity passes from th e anode to the cathode, causing the reduction of aluminum. The aluminum metal sinks below the cryolite bath forming a molten aluminum “pad.” The evolved oxygen atoms bond with the carbon in the anode of the cell forming carbon monoxide and carbon dioxide. Other emissions from the process in clude particulate fluoride and gaseous hydrogen fluoride as well as hydrocarbon emissions containing polycyclic organic matter (POM). The aluminum metal is siphoned from the pot every 48-hours and tran sported to the Casting Department, where it is cast into ingots of various sizes, shapes and alloys. Each pot produces approximately 1,700 pounds of aluminum per day.

III. Applicable Air Programs:

A. State Implementation Plan (SIP) – CFAC has the potential to emit greater than 25 tons per year (TPY) of PM 10 

### , carbon monoxide (CO), oxides of nitrogen (NO x 

### ), sulfur dioxide (SO 2 

### ), and volatile organic compounds (VOC); therefore, an MAQP is required. MAQP #2655-05 has been issued by the Department of Environmental Quality – Air Resources Management Bureau (Department) and lists the conditions under which CFAC must ope rate to be in compliance with the SIP.

B. New Source Performance Standards (NSPS) – CFAC is not an affected facility under NSPS Subpart S – Standards of Performance for Primary Aluminum Reduction Plants because none of the units in the subpart that are present at CFAC were constructed or modified after October 23, 1974.

C. Prevention of Significant Deterioration (PSD) – This facility is subject to PSD, because it is a listed source and has potential emissions greater than 100 TPY for PM 10 

### , CO, SO 2 

### , and VOC.

D. Title V Program – CFAC is a major source under the Title V Operating Permit program because the facility has potential emissions greater than 100 TPY. The facility currently operates under MAQOP #OP2655-02.

E. Maximum Achievable Control Technology (MACT) – CFAC is subject to:

• Primary Aluminum Smelter MACT (40 Code of Federal Regulations (CFR) 63, Subpart LL), and

• Secondary Aluminum Smelter MACT (40 CFR 63, Subpart RRR) for parts of the Casting operation.

F. Acid Rain – CFAC is not subject to the Acid Rain program because it is not designed to produce electricity.

IV. Applicable Requirements:

The following table includes a list of the emitting units and the most recent observation of those units. The observations recorded are from the January 14, 2010, on-site inspection unless otherwise noted.

### Summary of Emitting Units and Compliance Observation

Emission Unit ID Emission Unit Description Pollution Control Device Or Practice Observations

EU001 Ball Mill North – MH01 Baghouse Out of Service EU002 Ball Mill South – MH02 Baghouse Out of Service EU003 Coke Silo – MH04 Baghouse Out of Service EU004 East Alumina Elevator – MH06 Baghouse Out of Service EU005 East Alumina Unloading – MH07 Baghouse Out of Service EU006 East Conveyor Storage – MH08 Baghouse Out of Service EU007 West Alumina Unloading – MH09 Baghouse Out of Service EU008 Anode Dust Control System – MH03 Baghouse Out of Service EU009 Coke Unloading – MH05 Baghouse Out of Service EU010 West Conveyor Storage – MH10 Baghouse Out of Service EU011 Potline Sweeping – AR04 Baghouse Out of Service

EU012 Treatment of Aluminum Crucibles (TAC) Operations – CO10 Baghouse Out of Service

EU013 Pin Cleaning – West Plant – CR07 Baghouse Out of Service EU014 Pin Cleaning – East Plant – CR07a Baghouse Out of Service EU015 Paste Plant Extruder – PP01 Dry Coke Scrubber (Baghouse) Out of Service EU016 Paste Plant Mixer – PP02 Dry Coke Scrubber (Baghouse) Out of Service EU017 Pinhole Paste Drying – PP03 Baghouse Out of Service EU018 Pitch Storage Tank Vents – PP04 Conde nsation Tower/Vent Out of Service EU019 Therminol Oil Heating System – PP05 None Out of Service

EU020 East Plant Dry Scrubber Alumina Transfer (North) – AR01 Baghouse Out of Service

EU021 East Plant Dry Scrubber Alumina Transfer (South) – AR02 Baghouse Out of Service

EU022 West Plant Dry Scrubber Alumina Transfer (North) – AR06 Baghouse Out of Service

EU023 West Plant Dry Scrubber Alumina Transfer (South) – AR07 Baghouse Out of Service

EU024 Primary Gas Collection System – West Plant (Potlines 1 & 2) – AR05 Dry Alumina Scrubber #1 (Reactor #1 & Baghouse) Out of Service

EU025 Primary Gas Collection System – West Plant (Potlines 1 & 2) – AR05 Dry Alumina Scrubber #2 (Reactor #2 & Baghouse) Out of Service

EU026 Primary Gas Collection System – West Plant (Potlines 1 & 2) – AR05 Dry Alumina Scrubber #3 (Reactor #3 & Baghouse) Out of Service

EU027 Primary Gas Collection System – West Plant (Potlines 1 & 2) – AR05 Dry Alumina Scrubber #4 (Reactor #4 & Baghouse) Out of Service

EU028 Primary Gas Collection System – East Plant (Potlines 3, 4, & 5) – AR05 Dry Alumina Scrubber #5 (Reactor #5 & Baghouse) Out of Service

EU029 Primary Gas Collection System – East Plant (Potlines 3, 4, & 5) – AR05 Dry Alumina Scrubber #6 (Reactor #6 & Baghouse) Out of Service

EU030 Primary Gas Collection System – East Plant (Potlines 3, 4, & 5) – AR05 Dry Alumina Scrubber #7 (Reactor #7 & Baghouse) Out of Service

EU031 Primary Gas Collection System – East Plant (Potlines 3, 4, & 5) – AR05 Dry Alumina Scrubber #8 (Reactor #8 & Baghouse) Out of Service

EU032 Primary Gas Collection System – East Plant (Potlines 3, 4, & 5) – AR05 Dry Alumina Scrubber #9 (Reactor #9 & Baghouse) Out of Service

EU033 Primary Gas Collection System – East Plant (Potlines 3, 4, & 5) – AR05 Dry Alumina Scrubber #10 (Reactor #10 & Baghouse) Out of Service

EU034 Potline #1 Roof Vent, West Plant None Out of Service EU035 Potline #2 Roof Vent, West Plant None Out of Service EU036 Potline #3 Roof Vent, East Plant None Out of Service

### Emission Unit ID Emission Unit Description Pollution Control Device Or Practice Observations

EU037 Potline #4 Roof Vent, East Plant None Out of Service EU038 Potline #5 Roof Vent, East Plant None Out of Service EU039 Casting Furnace #3 – CO01 None

The Secondary Aluminum MACT covers the Casting Operations. The MACT II regulates reactive fluxing

in the furnaces. The MACT II Prohibits use of Chlorine, without additional record keeping. EU040 Casting Furnace #4 – CO02 None EU041 Casting Furnace #6 – CO03 None EU042 Casting Furnace #7 – CO04 None EU043 Casting Furnace #8 & #9 – CO05 None EU044 Casting Pit #3 – CO06 None EU045 Casting Pit #4 – CO06 None EU046 Casting Pit #6 & #7 – CO06 None EU047 Casting Pit #8 & #9 – CO06 None EU048 Dross Handling – CO07 None EU049 Sheet Ingot Saw – CO08 Target Box and Cyclone Out of Service EU050 T-Ingot Saw – CO09 Target Box a nd Filter or Cyclone Out of Service EU051 Sandblasting Activities – CR01 None Out of Service EU052 Lectromelt Furnace – CR03 Baghouse Out of Service EU053 Rod Mill / Material Storage – CR04 Baghouse Out of Service EU054 Change House Boiler #1 – MP01 None

All Boilers are Natural Gas Fired Boilers. The Annual Certification

shows that only natural gas or propane fuels these units. See annual Certification received 1/20/10. EU055 Change House Boiler #2 – MP02 None EU056 Lab Boiler #1 – MP07 None EU057 Machine Shop Boiler #1 – MP08 None EU058 Machine Shop Boiler #2 – MP09 None EU059 Paste Plant Boiler #1 – MP11 None EU060 Paste Plant Boiler #2 – MP12 None EU061 Warehouse Boiler #1 – MP16 None EU062 Warehouse Boiler #2 – MP17 None EU063 Haul Road Emissions – MP05 None Out of Service

EU064 Gasoline Storage Tank – MP04 None OK by design of system. See annual Certification received 1/20/10.



### The following tables outline the applicable require ments, emissions limitations, and the compliance status for the emitting units during the period covered by this Compliance Monitoring Report (CMR).

A. FACILITY-WIDE

Condi -tion Rule Citation Rule Descript ion Pollutant/Parameter Limit Compliance Status

A.1 ARM 17.8.331 Fluoride Emi ssions Fluoride emissions 2.6 lbs/ton of alum. produced, averaged over calendar month OUT*

A.2 ARM 17.8.332 Visible Air Contaminants from Potroom Opacity 10% IN

A.3 ARM 17.8.749 Particulate Matter, Airborne Fugitive Emissions Controlled by Baghouse IN

A.4 ARM 17.8.308(2) Particulate Matter, Airborne Reasonable Precaution 0.02 gr/dscf IN

A.5 ARM 17.8.308(3) Particulate Matter, Airborne Reasonable Precaution, Construction 20% IN

A.6 ARM 17.8.309 Particulate Matter, Fuel Burning Equipment Particulate Matter E = 0.882 * H -0.1664 Or E = 1.026 * H -0.233 IN

A.7 ARM 17.8.310 Particulate Matter, Industrial Processes Particulate Matter E = 4.10 * P 0.67 Or E = 55 * P 0.11 - 40 IN

A.8 ARM 17.8.322(4) Sulfur Oxide Emissions, Sulfur in Fuel Sulfur in Fuel (liquid or solid fuels) 1 lb/MMBtu Fired IN

A.9 ARM 17.8.322(5) Sulfur Oxide Emissions, Su lfur in Fuel (gaseous) 50 gr/100 CF INCondi -tion Rule Citation Rule Descript ion Pollutant/Parameter Limit Compliance Status Sulfur in Fuel

A.10 ARM 17.8.324(3) Hydrocarbon Emissions, Petroleum Products Gasoline Storage Tanks ------- IN

A.11 ARM 17.8.324 Hydrocarbon Emissions, Petroleum Products 65,000-Gallon Capacity ------- IN

A.12 ARM 17.8.324 Hydrocarbon Emissions, Petroleum Products Oil-effluent Water Separator ------- IN

A.13 ARM 17.8.1212 Reporti ng Requirements Compliance Monitoring ------- IN A.14 ARM 17.8.1207 Reporti ng Requirements Annual Certification ------- IN A.15 ARM 17.74.336 Asbest os Asbestos ------- IN

A.16 40 CFR Part 63, Subpart LL Aluminum MACT Fluoride, Polycyclic Organic Matter See Appendix G IN

*Violation Letter #VLRAG09-21 was issued for exceedi ng the fluoride emissions limit during July 2009.



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

EU001 – Ball Mill North EU003 – Coke Silo EU002 – Ball Mill South

Conditions Pollutant/ Parameter Permit Limit Compliance Demonstration Reporting Requirements Compliance Status Method Frequency B.1, B.4, B.5, B.7,

B.9 Opacity 20% Method 9 As Required by the Department Semiannual IN
Baghouse I & M (Append. K) Ongoing Semiannual IN B.3, B.6, B.8, B.9 Particulate Matter E = 55*P 0.11 – 40 Method 5 As Required by the Department Semiannual IN



### EU004 – East Alumina Elevator EU005 – East Alumina Unloading EU006 – East Conveyor Storage EU007 – West Alumina Unloading

Conditions Pollutant/ Parameter Permit Limit Compliance Demonstration Reporting Requirements Compliance Status Method Frequency B.2, B.4, B.5, B.7,

B.9 Opacity 40% Method 9 As Required by the Department Semiannual IN
Baghouse I & M (Append. K) Ongoing Semiannual IN B.3, B.6, B.8, B.9 Particulate Matter E = 55*P 0.11 – 40 Method 5 As Required by the Department Semiannual IN



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

EU008 – Anode Dust Control System EU012 – Treatment of Aluminum Crucibles EU009 – Coke Unloading EU013 – Pin Cleaning - West Plant EU010 – West Conveyor Storage EU014 – Pin Cleaning - East Plant EU011 – Potline Sweeping

Conditions Pollutant/ Parameter Permit Limit Compliance Demonstration Reporting Requirements Compliance Status Method Frequency C.1, C.4, C.5, C.7,

C.9 Opacity 20% Method 9 As Required by the Department Semiannual IN
Baghouse I & M (Append. K) Ongoing Semiannual IN C.2, C.6, C.8, C.9 Particulate Matter E = 55*P 0.11 – 40 Method 5 As Required by the Department Semiannual IN

C.3, C.6, C.8. C.9 Particulate Matter 0.02 gr/dscf Method 5 As Required by the Department Semiannual IN

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

EU015 – Paste Plant Extruder EU016 – Paste Plant Mixer

Conditions Pollutant/ Parameter Permit Limit Compliance Demonstration Reporting Requirements Compliance Status Method Frequency D.2, D.5, D.6, D.11, D.13, D.15 Opacity 40% Method 9 As Required by the Department Semiannual IN

Visual Survey Daily Semiannual IN D.3, D.8, D.10, D.12, D.13, D.15 Particulate Matter E = 55*P 0.11 – 40 Method 5 As Required by the Department Semiannual IN

D.4, D.9, D.10, D.13, D.15 Polycyclic Organic Matter (POM) None Operation of Dry Coke Scrubber: CFAC MACT Implementation

Plan (Appendix F) Ongoing Annual Certification IN

Visual Survey Daily Semiannual IN



### EU017 – Pinhole Paste Drying

Conditions Pollutant/ Parameter Permit Limit Compliance Demonstration Reporting Requirements Compliance Status Method Frequency

D.1, D.5, D.7, D.11, D.14, D.15 Opacity 20% Method 9 As Required by the Department Semiannual IN
Baghouse I & M

(Appendix K) Ongoing Semiannual IN

D.3, D.7, D.8, D.12, D.14, D.15 Particulate Matter E = 55*P 0.11 – 40 Method 5 As Required by the Department Semiannual IN



### E. EU018 – PITCH STORAGE TANKS

Conditions Pollutant/ Parameter Permit Limit Compliance Demonstration Reporting Requirements Compliance Status Method Frequency E.1, E.2, E.3, E.4 Opacity 20% Method 9 As Required by the Department Semiannual IN



### F. EU019 – THERMINOL OIL HEATING SYSTEM

Conditions Pollutant/ Parameter Permit Limit Compliance Demonstration Reporting Requirements Compliance Status Method Frequency F.1, F.2, F.3, F.4 Opacity 40% Method 9 As Required by the Department Semiannual IN



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

EU020 – East Plant Dry Scrubber Alumina Transfer (North) EU022 – West Plant Dry Scrubber Alumina Transfer (North) EU021 – East Plant Dry Scrubber Alumina Transfer (South) EU 023 – West Plant Dry Scrubber Alumina Transfer (South)

Conditions Pollutant/ Parameter Permit Limit Compliance Demonstration Reporting Requirements Compliance Status Method Frequency

G.1, G.3, G.4, G.6, G.8 Opacity 20% Method 9 As Required by the Department Semiannual IN
Baghouse I & M

(Append. K) Ongoing Semiannual IN

G.2, G.5, G.7, G.8 Particulate Matter E = 55*P 0.11 – 40 Method 5 As Required by the Department Semiannual IN

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

EU024 – West Plant - Scrubber #1 EU029 – East Plant - Scrubber #6 EU025 – West Plant - Scrubber #2 EU030 – East Plant - Scrubber #7 EU026 – West Plant - Scrubber #3 EU031 – East Plant - Scrubber #8 EU027 – West Plant - Scrubber #4 EU032 – East Plant - Scrubber #9 EU028 – East Plant - Scrubber #5 EU033 – East Plant - Scrubber #10

Conditions Pollutant/ Parameter Permit Limit Compliance Demonstration Reporting Requirements Compliance Status Method Frequency H.1, H.4, H.5, H.9, H.12, H.13 Opacity 20% Method 9 As Required by the Department Semiannual IN Visual Survey Daily

H.2, H.6, H.8, H.10, H.12, H.13 Total Fluoride (TF) 1.3 kg/Mg (per Month) or Table C of Appendix G Method 13B or CFAC MACT Implementation Plan (Appendix F) Annual Quarterly IN

H.3, H.7, H.8, H.11, H.12, H.13 Polycyclic Organic Matter (POM) 1.8 kg/Mg (per Quarter) or Table C of Appendix G Method 315 or CFAC MACT Implementation Plan (Appendix F) Annual Quarterly IN



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

EU034 – Potline #1 Roof Vent – West Plant EU 037 – Potline #4 Roof Vent – East Plant EU035 – Potline #2 Roof Vent – West Plant EU 038 – Potline #5 Roof Vent – East Plant EU036 – Potline #3 Roof Vent – East Plant

Conditions Pollutant/ Parameter Permit Limit Compliance Demonstration Reporting Requirements Compliance Status Method Frequency

I.1, I.4, I.5, I.8, I.9, I.12 Opacity 10% Method 9 (Appendix J) Quarterly Quarterly IN Visual Surveys

(Appendix J) Daily

I.2, I.6, I.10, I.12 Total Fluoride (TF) 1.3 kg/Mg (per Month) or Table C

of Appendix G Method 13B & Method 14 (Appendix F) Three Test Runs per Month Quarterly OUT*

I.3, I.7, I.11, I.12 Polycyclic Organic Matter (POM) 1.8 kg/Mg (per Quarter) or Table C of Appendix G Method 315 & Method 14 (Appendix F) One Test Run per Month Quarterly IN

*Violation Letter #VLRAG09-21 was issued for exceedi ng the fluoride emissions limit during July 2009.



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

EU039 – Casting Furnace #3 EU042 – Casting Furnace #7 EU040 – Casting Furnace #4 EU043 – Casting Furnace #8 & #9 EU041 – Casting Furnace #6

Conditions Pollutant/ Parameter Permit Limit Compliance Demonstration Reporting Requirements Compliance Status Method Frequency J.1, J.4, J.5, J.6 Opacity 40% Natural Gas or Liquid Petroleum Gas Combustion Ongoing Annual Certification IN

J.2, J.4, J.5, J.6 Particulate Matter E = 0.882xH -0.1664 Natural Gas or Liquid Petroleum Gas Combustion Ongoing Annual Certification IN

J.3, J.4, J.5, J.6 Sulfur in Fuel 50 gr/100 cu ft Natural Gas or Liquid Petroleum Gas Combustion Ongoing Annual Certification IN

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

EU044 – Casting Pit #3 EU047 – Casting Pit #8 & #9 EU045 – Casting Pit #4 EU048 – Dross Handling EU046 – Casting Pit #6 & #7

Conditions Pollutant/ Parameter Permit Limit Compliance Demonstration Reporting Requirements Compliance Status Method Frequency K.1, K.3, K.5, K.7 Opacity 40% Method 9 As Required by the Department Semiannual IN

K.2, K.4, K.6, K.7 Particulate Matter E = 4.10*P 0.67 Method 5 As Required by the Department Annual Certification IN



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

EU049 – Sheet Ingot Saw EU050 – T-Ingot Saw

Conditions Pollutant/ Parameter Permit Limit Compliance Demonstration Reporting Requirements Compliance Status Method Frequency L.1, L.3, L.5, L.6 Opacity 20% Method 9 As Required by the Department Semiannual IN

L.2, L.4, L.5, L.6 Particulate Matter E = 4.10*P 0.67 Method 5 As Required by the Department Semiannual IN



### M. EU051 – SANDBLASTING ACTIVITIES

Conditions Pollutant/ Parameter Permit Limit Compliance Demonstration Reporting Requirements Compliance Status Method Frequency M.1, M.4, M.7, M.9 Opacity 20% Method 9 As Required by the Department Semiannual IN

M.2, M.5, M.7, M.9 Opacity Reasonable Precautions Visual Surveys Weekly Semiannual IN

M.3, M.6, M.7, M.8, M.9 Particulate Matter E = 4.10*P 0.67 Normal Operations Annual Certification Annual Certification IN



## N. EU052 – LECTROMELT FURNACE EMITTING UNIT

Conditions Pollutant/ Parameter Permit Limit Compliance Demonstration Reporting Requirement

s Compliance Status Method Frequency

N.1, N.3, N.4, N.6, N.8 Opacity 20% Method 9 As Required by the Department Semiannual IN
Baghouse I & M (Append. K) Ongoing Semiannual IN N.2, N.4, N.5, N.7, N.8 Particulate Matter E = 4.10*P 0.67 Method 5 As Required by the Department Semiannual IN



### O. EU053 – ROD MILL/MATERIAL STORAGE EMITTING UNIT

Conditions Pollutant / Parameter Permit Limit Compliance Demonstration Reporting Requirements Compliance Status Method Frequency O.1, O.3, O.4, O.5, O.6, O.7 Opacity 20% Method 9 As Required by the Department Semiannual IN
Baghouse I & M (Append. K) Ongoing Semiannual INO.2, O.3, O.4, O.5, O.6, O.7 Particulate Matter E = 55*P 0.11 - 40 Method 5 As Required by the Department Semiannual IN



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

EU054 – Change House Boiler #1 EU059 – Paste Plant Boiler #1 EU055 – Change House Boiler #2 EU060 – Paste Plant Boiler #2 EU056 – Lab Boiler #1 EU061 – Warehouse Boiler #1 EU057 – Machine Shop Boiler #1 EU062 – Warehouse Boiler #2 EU058 – Machine Shop Boiler #2

Conditions Pollutant/ Parameter Permit Limit Compliance Demonstration Reporting Requirements Compliance Status Method Frequency P.1, P.4, P.5, P.6 Opacity 20% Natural Gas Combustion Ongoing Annual Certification IN

P.2, P.4, P.5, P.6 Particulate Matter E = 1.026*H -0.233 Natural Gas Combustion Ongoing Annual Certification IN

P.3, P.4, P.5, P.6 Sulfur in Fuel 50 gr/100 cu ft Natural Gas Combustion Ongoing Annual Certification IN



### Q. EU063 – TRUCK, EQUIPMENT, AND HAUL ROAD EMISSIONS

Conditions Pollutant/ Parameter Permit Limit Compliance Demonstration Reporting Requirements Compliance Status Method Frequency Q.1, Q.3, Q.4, Q.5 Opacity 20% Method 9 As Required by the Department Semiannual IN

Q.2, Q.3, Q.4, Q.5 Opacity Reasonable Precautions Method 9 As Required by the Department Semiannual IN

Maintenance, Treatment, and Speed As Needed Semiannual IN



### R. EU064 – GASOLINE STORAGE (TANK) EMITTING UNIT

Conditions Pollutant/ Parameter Permit Limit Compliance Demonstration Reporting Requirements Compliance Status Method Frequency R.1, R.3, R.5, R.6 Opacity 20% Method 9 As Required by the Department Semiannual IN

R.2, R.4, R.6 Tanks Submerged F ill Certify Semiannual Semiannual IN



### V. Inventory and Description of Regulated Emission Units and Processes:

CFAC reports emissions of Fluoride and POM quarterly for compliance with the Primary Aluminum MACT standard. In July of 2008, plant production decreased as production ceased on 1.75 potlines. In February of 2009, plant production decreased again as production ceased on another 0.75 potlines. There was one potline operating until the end of Oc tober 2009, when plant production was completely curtailed. The world market for aluminum and the ability to negotiate a contract for electricity will dictate as to whether or not CFAC will resume production. The following table shows actual emissions from the facility. Note – Since, allowable emi ssions (Fluoride and POM) are calculated on a pound of emission per ton of aluminum-produced basis, determin ations of allowable emissions are not available.

### Actual Emission Inventory Summary (TPY )

Pollutant Permitted Actual 2009 Emissions Actual 2008 Emissions Particulate Matter 128.2 601.7 PM 10 

### 42.5 222.8 SO 2 

### 260.3 1007.8 NO x 

### 1.3 4.5 CO 3292.5 14656.9 VOC 35.0 155.6 Fluoride 17.0 69.4

POM 10.6 70.9

VI. Recent Compliance History:

On March 12, 2009, the Department issued Warning Letter #WLRAG09-08 to CFAC for not maintaining and not operating emission controls in a manner consistent with good air pollution control practices for minimizing emissions while bypassing the exhaust gases past the emission control equipment. However, the Department made the determination not to pursue enforcement.

Also, on November 19, 2009, the Department issu ed Violation Letter #VLRAG09-21 to CFAC for exceeding the permitted limit of 2.6 lbs of fluoride/ton of aluminum produced for Fluoride emissions in July 2009. This non-compliance issue is being re viewed by the Department to determine the appropriate response.

VII. Compliance Monitoring Activities:

During the reporting period, CFAC conducted mainte nance at the facility in accordance with the Administrative Rules of Montana (ARM) 17.8.335 – Maintenance of Air Pollution Control Equipment for Existing Aluminum Plants. In September 2008 and September 2009, CFAC conducted maintenance and complied with the provisions of ARM 17.8.335.

The Department most recently conducted an inspecti on on January 14, 2010. I arrived at 2:30 p.m. and met with Steve Wright, the Environmental Manager. Mr. Wright and I talked about the U.S. Environmental Protection Agency’s (EPA) green hou se gas reporting requirements and I was informed that CFAC produces perfluorocarbons in the crucibles holding the molten aluminum. Mr. Wright asked about emission factors and I suggested contacting the EPA. We talked about the recent curtailing of aluminum production at the facility and the possibility of CFAC restating someday. There were approximately 7 workers on site during the inspection. Mr. Wright said that it would take CFAC entering into an electricity contract and better worl dwide aluminum prices before the facility could look at restarting. Mr. Wright stated that there were current negotiations regarding the electricity contract and that CFAC officials had been estimating the cost of a restart. The only emitting units that were still operating were some natural gas heaters that are used in conjunction with the water treatment at CFAC.

Upon departure, I took two pictures of the parking ar ea and the roofs (emitting units) at the facility (See Pictures #1 & #2). I noted no visible emissions from the facility during the latest inspection. During

### the inspection, the facility appeared to be in co mpliance with regard to visible emissions. The inspection ended at 4:00 p.m.

VIII. Facility Compliance Report Review:

The following table is a list of compliance reports the facility submitted during the review period.

Report Title Date Due Date Received Date Reviewed Quarterly Report 1 st Quarter 2008 May 15, 2008 Apr 11, 2008 Apr 21, 2008 Maintenance Event Request for 9/08 Jul 26, 2008 Jul 23, 2008 Sept 2, 2008 Periodic Startup, Shutdown & Malfunction Report January through June 2008 Jul 31, 2008 Jul 22, 2008 Jul 22, 2008

Semiannual Report & Seconda ry MACT Requirements January through June 2008 Jul 31, 2008 Jul 22, 2008 Jul 22, 2008

Quarterly Report 2 n d Quarter 2008 Aug 15, 2008 Jul 17, 2008 Jul 22, 2008 Fluoride & POM Emission Testing – Bison Engi neering Nov 4, 2008 Nov 5, 2008 Dec 18, 2008 Maintenance Event Report Nov 14, 2008 Oct 3, 2008 Oct 14, 2008 Quarterly Report 3 r d Quarter 2008 Nov 15, 2008 Oct 16, 2008 Oct 17, 2008 Periodic Startup, Shutdown & Malfunction Report July through December 2008 Jan 31, 2009 Jan 12, 2009 Jan 27, 2009

Semiannual Report & Seconda ry MACT Requirements July through December 2008 Jan 31, 2009 Jan 12, 2009 Jan 27, 2009

Title V Annual Certification 2008 Jan 31, 2009 Jan 12, 2009 Feb 5, 2009 Annual Emission Inventory Data Reque st Feb 15, 2009 Jan 14, 2009 Jan 23, 2009 Quarterly Report 4 th Quarter 2008 Feb 15, 2009 Jan 12, 2009 Jan 27, 2009

Fluoride in Forage Report 2008 Ma r 1, 2009 Feb 27, 2009 Mar 25, 2009 Quarterly Report 1 st Quarter 2009 May 15, 2009 Apr 16, 2009 Apr 20, 2009 Maintenance Event Request for 9/09 NA Jul 17, 2009 Jul 30, 2009 Periodic Startup, Shutdown & Malfunction Report January through June 2009 Jul 31, 2009 Jul 17, 2009 Jul 23, 2009

Semiannual Report & Seconda ry MACT Requirements January through June 2009 Jul 31, 2009 Jul 17, 2009 Jul 23, 2009

Quarterly Report 2 n d Quarter 2009 Aug 15, 2009 Jul 13, 2009 Jul 14, 2009 Maintenance Event Report Nov 9, 2009 Oct 2, 2009 Oct 15, 2009 Quarterly Report 3 r d Quarter 2009 Nov 15, 2009 Oct 9, 2009 Nov 13, 2009 Fluoride & POM Emission Testing – Bison Engi neering Dec 14, 2009 Nov 23, 2009 Dec 23, 2009 Periodic Startup, Shutdown & Malfunction Report July through December 2009 Jan 31, 2010 Jan 14, 2010 Jan 26, 2010

Semiannual Report & Seconda ry MACT Requirements July through December 2009 Jan 31, 2010 Jan 15, 2010 Jan 26, 2010

Title V Annual Certification 2009 Jan 31, 2010 Jan 20, 2010 Jan 26 ,2010 Quarterly Report 4 th Quarter 2009 Feb 15, 2010 Jan 8, 2010 Jan 26, 2010 Annual Emission Inventory Data Reque st Feb 15, 2010 Jan 20, 2010 Feb 3, 2010 Fluoride in Forage Report 2009 Mar 1, 2010 Nov 23, 2009 Nov 25, 2009



### IX. Visible Emission Observation Information:

During the inspection, no visible emission documentation took place. Since the facility was not operating, the visible emissions were well within the limitations of the permits. Also, when the facility was operating, CFAC completed observations of the potline roof vents on a daily basis and observed various control equipment vents weekly.

X. Stack Test Review:

### CFAC conducts an ongoing stack test program. Testing for Fluoride and POM takes place monthly. Testing of the dry scrubbers takes place annually for Fluoride and POM. CFAC submits results of these tests quarterly. The following tables summarize the results.

Summary of POM Results (All Values in Pounds of POM per Ton of Aluminum Produced) 

### POM Date Actual Limit 1 s t



### Qtr 2008 1.4 3.0* 2 n d 

### Qtr 2008 1.9 3.0* 3 r d 

### Qtr 2008 1.7 3.0* 4 th 

### Qtr 2008 1.7 3.2* 1 s t



### Qtr 2009 1.2 3.6 2 n d 

### Qtr 2009 1.5 3.6 3 r d 

### Qtr 2009 1.4 3.6 4 th 

### Qtr 2009 1.3 3.6 *More restrictive limit with more potlines in production.



### Summary of Fluoride Results (All Values in Pounds of Fluoride per Ton of Aluminum Produced) 

### Fluoride Date Actual Limit January 2008 1.1 2.5** February 2008 1.4 2.5**

March 2008 1.6 2.5** April 2008 1.7 2.5** May 2008 2.1 2.5** June 2008 2.2 2.5** July 2008 1.9 2.5** August 2008 1.3 2.6 September 2008 1.6 2.6

October 2008 1.6 2.6 November 2008 1.8 2.6 December 2008 1.8 2.6

January 2009 1.8 2.6 February 2009 1.5 2.6

March 2009 1.9 2.6 April 2009 1.8 2.6 May 2009 2.6 2.6 June 2009 2.2 2.6 July 2009 2.9 # 

### 2.6 August 2009 1.9 2.6 September 2009 2.3 2.6

October 2009 2.1 2.6 November 2009 NA 2.6 December 2009 NA 2.6 **More restrictive limit with more potlines in production.

# 

### Exceedence of the limit.

### XI. Findings and Recommendations:

During the reporting period on March 12, 2009, the Department issued Warning Letter #WLRAG09-08 to CFAC for not maintaining and not operating emi ssion controls in a manner consistent with good air pollution control practices for minimizing emissions while bypassing the exhaust gases past the emission control equipment. However, the Depa rtment made the determination not to pursue enforcement.

Also, during the reporting period on November 19, 2009, the Department issued Violation Letter #VLRAG09-21 to CFAC for exceeding the permitted lim it of 2.6 lbs of Fluoride/ton of Aluminum produced for Fluoride emissions in July 2009. Other than violation letter #VLRAG09-21, the Department believes CFAC is in compliance with th e applicable requirements contained in CFAC’s air quality permits based upon: the information gather ed at the time of the facility inspection; the observations made during the inspection; and the review of reports and compliance certifications submitted by CFAC during the review period.

### Picture #1. A picture from the entrance at CFAC showing the black roofs (emitting units).

Picture #2. The relatively empty parking lot at CFAC.