# PERMIT TO OPERATE

Under the authority of RSMo 643 and the Federal Clean Air Act the applicant is authorized to operate

the air contaminant source(s) described below, in accordance with the laws, rules, and conditions set

forth here in.



### Operating Permit Num ber: OP2001032

Expiration Date: April 15, 2006



### Project Number: 143

- 0008

- 020

Installation Name and Address

Noranda Aluminum, Inc. #1

#1 Robbins Road

New Madrid, MO 63869

New Madrid County

Parent Company's Name and Address

Noranda Aluminum, Inc.

1 Brentwood Commons, Ste. 175, 750 Old Hickory Rd.

Brentwood, TN 37027

Installation Description:

This installation consists of a primary aluminum reduction plant and a rod

mill. The installation will be divided into segments for operating permit

pur poses, with each segment receiving a separate operating permit. This

permit will be for the boilers and for the furnaces that will not be affected by

the National Emission Standards for Hazardous Air Pollutants (Subparts LL

and/or RRR) and for the river u nloading and railcar unloading.

Effective Date Director or Designee

Department of Natural Resources

## Noranda Aluminum, Inc. 2

Project No. 143

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# Table of Contents

I. I NSTALLATION 

### D ESCRIPTION AND 

### E QUIPMENT 

### L ISTING



### ................................ .......... 3

INSTALLATION DESCRIPTION

................................ ................................ ..................... 3

EMISSION UNITS WITH LIMITATIONS

................................ ................................ .......... 3



### II. P LANT 

### W IDE 

### E MISSION 

### L IMITATIONS



### ................................ ................................ 4

Permit Condition PW001

................................ ................................ .............................. 4

10 CSR 10

- 6.170

................................ ................................ ................................ ................................ . 4



### Permit Condition PW002

................................ ................................ .............................. 5

10 CSR 10

- 6.250

................................ ................................ ................................ ................................ . 5



### Permit Condition PW

- 003

................................ ................................ ............................. 5

10 CSR 10

- 6.080

................................ ................................ ................................ ................................ . 5

40 CFR Part 61 Subpart M

................................ ................................ ................................ .................. 5



### III. E MISSION 

### U NIT 

### S PECIFIC 

### E MISSION 

### L IMITATIONS



### ................................ ................ 6

10 CSR 10

- 3.050

................................ ................................ ................................ ......... 6

10 CSR 10

- 3.060

................................ ................................ ................................ ......... 8

10 CSR 10

- 3.080 and 10 CSR 10

- 6.220

................................ ................................ ....... 8

10 CSR 10

- 6.260

................................ ................................ ................................ ....... 10

10 CSR 10

- 6.260

................................ ................................ ................................ ....... 11



### IV. C ORE 

### P ERMIT 

### R EQUIREMENTS



### ................................ ................................ ...... 12

V. G ENERAL 

### P ERMIT 

### R EQUIREMENTS



### ................................ ................................ . 15

P ERMIT 

### D URATION



### ................................ ................................ ................................ ........ 15

G ENERAL 

### R ECORD 

### K EEPING AND 

### R EPORTING 

### R EQUIREMENTS



### ................................ ............ 15

R ISK 

### M ANAGEMENT 

### P LANS 

### U NDER 

### S ECTION 

### 112( R 

### )

................................ .......................... 16

S EVERABILITY 

### C LAUSE



### ................................ ................................ ................................ .. 16

G ENERAL 

### R EQUIREMENTS



### ................................ ................................ ............................. 16

I NCENTIVE 

### P ROGRAMS 

### N OT 

### R EQUIRING 

### P ERMIT 

### R EVISIONS



### ................................ ................ 17

C OMPLIANCE 

### R EQUIREMENTS



### ................................ ................................ ......................... 17

P ERMIT 

### S HIELD



### ................................ ................................ ................................ ............ 18

E MERGENCY 

### P ROVISIONS



### ................................ ................................ .............................. 19

O PERATIONAL 

### F LEXIBILITY



### ................................ ................................ ............................. 19

O FF



### - P ERMIT 

### C HANGES



### ................................ ................................ ................................ .. 20

R ESPONSIBLE 

### O FFICIAL



### ................................ ................................ ................................ . 20

S TATEMENT OF 

### B A SIS



### ................................ ................................ ................................ .... 21

Attachment A

................................ ................................ ................................ ................................ .... 22

Attachment B

................................ ................................ ................................ ................................ .... 23

## Noranda Aluminum, Inc. 3

Project No. 143

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# I. Installation Description and Equipment Listing

INSTALLATION DESCRIPTION

This installation consists of a primary aluminum reduction plant (using the center

worked prebake process) and a rod mill.

EMISSION UNITS WITH LIMITATIONS

The following list provides a description of the equipment that will be addressed in this

permit which emit air pollutants and which are identified as having unit

- specific

emission limitations.

Emission EIQ Ref. #

Unit # (1997) Description of Emission Unit Make/Model Install.

Date

EU0010 01

- 01 Vacuum Unloader Hartman, Model #MR175 1969

EU0020 02

- 01 Vacuum Unloader Hartman, Model #MR175 1969

EU0030 03

- 01 Airslide Kennedy Van Saun, Airfloat 1970

EU0040 03

- 02 Airslide Kennedy Van Saun, Airfloat 1970

EU0050 03

- 03 Airslide Kennedy Van Saun, Airfloat 1970

EU0060 03

- 04 Airslide Kennedy Van Saun, Airfloat 1970

EU0070 03

- 05 Airslide Kennedy Van Saun, Airfloat 1970

EU0080 03

- 06 Airslide Kennedy Van Saun, Airfloat 1970

EU0090 03

- 07 Airslide Kennedy Van Saun, Airfloat 1970

EU0100 03

- 08 Airslide Kennedy Van Saun, Airfloat 1970

EU0110 04

- 01 Vibrating Feeder Syntr on F

- 98 1969

EU0120 04

- 02 Vibrating Feeder Syntron F

- 98 1969

EU0130 04

- 03 Vibrating Feeder Syntron F

- 98 1969

EU0140 04

- 04 Screw Conveyor Syntron F

- 45 1969

EU0150 04

- 05 Car Shaker Hewitt

- Robbins Model THEB 1969

EU3730 94

- 01 Boiler for Hot Oil System Ec lipse Model 600 BHC

- LT

- WP

- G

- P

- FM 1970

EU3740 95

- 01 Boiler for Hot Oil System Eclipse Model 600 BHC

- LT

- WP

- G

- P

- FM 1970

EU3750 96

- 01 Boiler for Hot Oil System Eclipse Model 300

- 4

- HC

- LT

- WP 1988

EU3760 97

- 01 Carbon Rodding Aluminum Spray

Furnace Warwick 1970

EU4790 AJ

- 01 #1 Homogenizing Furnace Sunbeam 1971

EU4800 AK

- 01 #2 Homogenizing Furnace Sunbeam 1971

EU4810 AL

- 01 #3 Homogenizing Furnace Sunbeam S/N F

- 160

- 82 1982

EU4900 BI

- 01 Hot Water Boiler Orr & Sembower Model P 15 HP 1969

EU4910 BJ

- 01 Hot Water Boiler A.O. Smith Model 750 1981

EU4920 BK

- 01 Hot Water Boiler American Standard

- Kewanee Model M 115 FG 1969

## Noranda Aluminum, Inc. 4

Project No. 143

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# II. Plant Wide Emission Limitations

The installation shall comply with each of the following emission limitations. Consult

the appropriate sectio ns in the Code of Federal Regulations (CFR) and Code of State

Regulations (CSR) for the full text of the applicable requirements.



## Permit Condition PW001

10 CSR 10

- 6.170

Restriction of Particulate Matter to the Ambient Air Beyond the Premises of Origin



### E mission Limitation:

No person may cause or allow to occur any handling, transporting or storing of any material;

construction, repair, cleaning or demolition of a building or its appurtenances; construction

or use of a road, driveway or open area; or oper ation of a commercial or industrial installation

without applying reasonable measures as may be required to prevent, or in a manner which

allows or may allow, fugitive particulate matter to go beyond the premises of origin in

quantities that the particulat e matter:

Remains visible in the ambient air beyond the property line of origin; or

May be found on surfaces beyond the property line of origin.

The nature or origin of the particulate matter shall be determined by microscopy or other

technique proven to be equally accurate and approved by the Director.

Monitoring:

The permittee shall conduct inspections of its installation sufficient to determine compliance

with this regulation. The source representative would maintain a log noting 1) whether any

air e missions (except for water vapor) remain visible in the ambient air beyond the property

line of origin; and 2) whether the visible emissions were normal for the installation. If no

visible or other significant emissions are observed, then no further obser vations would be

required. If a violation of this regulation is discovered, the source representative would

indicate the cause of the abnormal emissions and any corrective action(s) taken. The source

representative will also indicate the total duration of any visible emission incident as part of

the log described above.

Weekly observations shall be conducted for a minimum of eight (8) consecutive weeks.

Should no violations of this regulation be observed in that time period, then periodic

observations sh all be conducted every other week for a period of two (2) calendar months.

Should no violations be observed in this time period, then periodic observations need be done

no more often than once per month. Should violations be observed, then:

The frequency of periodic monitoring will revert to weekly, though the frequency of

monitoring would follow the reduction in frequency of monitoring as just outlined,

provided no further violations were observed.

The permittee will take whatever steps are necessary to bring the installation back in to

compliance with this regulation. These measures will be implemented as soon as is

practicable.

Record Keeping:

The permittee shall maintain records of any exceedances of any of the terms imposed by this

regulation, or a ny equipment malfunctions, which could possibly cause an exceedance of this

regulation. Attachment A, or an equivalent record keeping sheet shall be used to record all

information required by this rule. All records must be maintained for a minimum of fiv e (5)

years. Reporting:

The permittee shall report to the Air Pollution Control Enforcement Section, P.O. Box 176,

Jefferson City, MO 65102, no later than ten (10) days after any exceedance of any of the

terms imposed by this regulation, or any malfuncti on which could possibly cause an

exceedance of this regulation.

## Noranda Aluminum, Inc. 5

Project No. 143

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## Permit Condition PW002

10 CSR 10

- 6.250

Asbestos Abatement Projects

– Certification, Accreditation, and Business Exemption

Requirements

Emission Limitation:

The permittee shall conduct al l asbestos abatement projects within the procedures established

for certification and accreditation by 10 CSR 10

- 6.250.

An individual must receive certification from the department before that individual

participates in an asbestos abatement project operat ing in Missouri according to Section (3).

This certification is annually renewable. Certification as an AHERA inspector, AHERA

management planner and AHERA project designer apply to AHERA

- related projects.

To be a training provider for the purpose of thi s rule a school shall apply for accreditation to

the department and comply with the United States Environmental Protection Agency AHERA

Model Accreditation plan 40 CFR part 763 Appendix C, subpart E. Details of the

requirements for accreditation are found in Section (4).

Monitoring:

Any appropriate monitoring to demonstrate compliance with Certification and Accreditation

standards.

Record keeping:

Any appropriate record keeping to demonstrate compliance with Certification and

Accreditation standards.

R eporting:

Any appropriate reporting to demonstrate compliance with Certification and Accreditation

standards.



## Permit Condition PW

- 003

10 CSR 10

- 6.080

Emission Standards for Hazardous Air Pollutants

40 CFR Part 61 Subpart M

National Emission Standard f or Asbestos

Emission Limitation:

The permittee shall follow the procedures and requirements of 40 CFR Part 61, Subpart M for

any activities occurring at this installation which would be subject to provisions for 40 CFR

Part 61, Subpart M, National Emissi on Standard for Asbestos

. Monitoring:

Any appropriate monitoring to demonstrate compliance with registration, certification,

notification, and Abatement Procedures and Practices standards as specified in 40 CFR Part

61, Subpart M.

Record keeping:

Any appropriate record keeping as specified in 40 CFR Part 61, Subpart M.

Reporting:

Any appropriate reporting as specified in 40 CFR Part 61, Subpart M.

## Noranda Aluminum, Inc. 6

Project No. 143

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# III. Emission Unit Specific Emission Limitations

The installation shall comply with each of the following emission limitations. Consult

the appropriate sections in the Code of Federal Regulations (CFR) and Code of State

Regulations (CSR) for the full text of the applicable requirements.



## 10 CSR 10

- 3.050

Restriction of Emission of Particulate Matter from Ind ustrial Processes

Emission Limitation:

For emission units using baghouses for control (EU0010 through EU0100), the associated

baghouse must be in use at all times when these processes are in operation. The permittee

shall not emit particulate matter in excess of the emission limit, E (lb/hr), shown in the table

below for each given emission unit.

Permit

Condition Emission

Unit EIQ

Ref. #

(1997) Description Manufacturer,

Model # Emission

Limit, E

(lb/hr)

EU0010

- 001 EU0010 01

- 01 Vacuum Unloader Hartman, Model #MR175 40.14

EU0020

- 001 EU0020 02

- 01 Vacuum Unloader Hartman, Model #MR175 40.14

EU0030

- 001 EU0030 03

- 01 Airslide Kennedy Van Saun, Airfloat 16.04

EU0040

- 001 EU0040 03

- 02 Airslide Kennedy Van Saun, Airfloat 16.04

EU0050

- 001 EU0050 03

- 03 Airslide Kennedy Van Saun, Airfloat 16.04

EU0060

- 001 EU0060 03

- 04 Airslide Kennedy Van Saun, Airfloat 16.04

EU0070

- 001 EU0070 03

- 05 Airslide Kennedy Van Saun, Airfloat 16.04

EU0080

- 001 EU0080 03

- 06 Airslide Kennedy Van Saun, Airfloat 16.04

EU0090

- 001 EU0090 03

- 07 Airslide Kennedy Van Saun, Airfloat 16.04

EU0100

- 001 EU0100 03

- 08 Airslide Kennedy Van Saun, Airfloat 16.04

EU0110

- 001 EU0110 04

- 01 Vibrating Feeder Syntron F

- 98 0.93

EU0120

- 001 EU0120 04

- 02 Vibrating Feeder Syntron F

- 98 0.93

EU0130

- 001 EU0130 04

- 0 3 Vibrating Feeder Syntron F

- 98 0.93

EU0140

- 001 EU0140 04

- 04 Screw Conveyor Syntron F

- 45 0.93

EU0150

- 001 EU0150 04

- 05 Car Shaker Hewitt

- Robbins Model THEB 0.93

EU3760

- 001 EU3760 97

- 01 Carbon Rodding

Aluminum Spray

Furnace Warwick 4.10

EU4790

- 001 EU4790 AJ

- 01 #1 Homogenizing

Furnace Sunbeam 4.10

EU4800

- 001 EU4800 AK

- 01 #2 Homogenizing

Furnace Sunbeam 4.10

EU4810

- 001 EU4810 AL

- 01 #3 Homogenizing

Furnace Sunbeam S/N F

- 160

- 82 4.10

## Noranda Aluminum, Inc. 7

Project No. 143

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Monitoring:

Check and document the baghouse pressure drop weekly. If the pressure drop is out of

normal operating range, corrective action shall be taken within eight (8) hours to return

the pressure drop to normal.

Check the cleaning sequence of the baghouse every six (6) months.

Thoroughly inspect bags for leaks and wear eve ry six (6) months.

Inspect structural components, housing, ductwork and hoods (if applicable) associated

with the control system every six (6) months.

If leaks or abnormal conditions are detected the appropriate measures for remediation

shall be implemente d within eight (8) hours.

The baghouse and associated equipment shall be maintained and operated according to

the manufacturer’s specifications.

The permittee shall monitor the monthly throughput of material for these emission

units.

Record keeping:

A wr itten record of weekly baghouse pressure drop readings, all inspections and any

action resulting from inspections shall be maintained. Bag replacement shall also be

documented.

The permittee shall maintain an accurate re cord of throughput, emission factors, and

actual emissions of particulate matter emitted into the atmosphere from these emission

units. These records shall be made available immediately for inspection to the

Department of Natural Resources personnel upon request.

Attachment B contains a log including these record keeping requirements. This log, or

an equivalent created by the permittee, must be used to certify compliance with this

requirement.

Reporting:

The permittee shall report to the APCP Enforcemen t Section, P.O. Box 176, Jefferson City,

MO 65101, no later than 10 days after any exceedance of 10 CSR 10

- 3.050.

## Noranda Aluminum, Inc. 8

Project No. 143

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## 10 CSR 10

- 3.060

Maximum Allowable Emissions of Particulate Matter from Fuel Burning Equipment Used

for Indirect Heating

Emission Limi tation:

The permittee shall not emit particulate matter in excess of 0.61 pounds per million BTU

of heat input.

Permit

Condition Emission

Unit EIQ

Ref. #

(1997) Description Manufacturer, Model # Install

. Date

EU3750

- 001 EU3750 96

- 01 Boiler for Hot Oil S ystem Eclipse Model 300

- 4

- HC

- LT

- WP 1988

EU4910

- 001 EU4910 BJ

- 01 Hot Water Boiler A.O. Smith Model 750 1981



### Monitoring:

None

Record keeping:

None

Reporting:

None



## 10 CSR 10

- 3.080 and 10 CSR 10

- 6.220

Restriction of Emission of Visible Air Contami nants

Emission Limitation:

No person may discharge into the ambient air from any single existing source of emission

whatsoever, any air contaminant:

of a shade or density equal to or darker than that designated as No. 2 on the

Ringlemann Chart (40% opaci ty); or

of an opacity as to obscure an observer's view to a degree equal to or greater than does

smoke designated as No. 2 on the Ringlemann Chart (40% opacity).

Permit

Condition Emission

Unit EIQ

Ref. #

(1997) Description Manufacturer, Model # Install.

D ate

EU0010

- 002 EU0010 01

- 01 Vacuum Unloader Hartman, Model #MR175 1969

EU0020

- 002 EU0020 02

- 01 Vacuum Unloader Hartman, Model #MR175 1969

EU0030

- 002 EU0030 03

- 01 Airslide Kennedy Van Saun, Airfloat 1970

EU0040

- 002 EU0040 03

- 02 Airslide Kennedy Van Saun , Airfloat 1970

EU0050

- 002 EU0050 03

- 03 Airslide Kennedy Van Saun, Airfloat 1970

EU0060

- 002 EU0060 03

- 04 Airslide Kennedy Van Saun, Airfloat 1970

EU0070

- 002 EU0070 03

- 05 Airslide Kennedy Van Saun, Airfloat 1970

EU0080

- 002 EU0080 03

- 06 Airslide Kennedy Van Saun, Airfloat 1970

EU0090

- 002 EU0090 03

- 07 Airslide Kennedy Van Saun, Airfloat 1970

EU0100

- 002 EU0100 03

- 08 Airslide Kennedy Van Saun, Airfloat 1970

EU0110

- 002 EU0110 04

- 01 Vibrating Feeder Syntron F

- 98 1969

EU0120

- 002 EU0120 04

- 02 Vibrating Feede r Syntron F

- 98 1969

EU0130

- 002 EU0130 04

- 03 Vibrating Feeder Syntron F

- 98 1969

EU0140

- 002 EU0140 04

- 04 Screw Conveyor Syntron F

- 45 1969

## Noranda Aluminum, Inc. 9

Project No. 143

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EU0150

- 002 EU0150 04

- 05 Car Shaker Hewitt

- Robbins Model THEB 1969

EU3730

- 002 EU3730 94

- 01 Boiler for Hot Oil System Eclipse Model 600 BHC

- LT

- WP

- G

- P

FM 1970

EU3740

- 002 EU3740 95

- 01 Boiler for Hot Oil System Eclipse Model 600 BHC

- LT

- WP

- G

- P

FM 1970

EU3760

- 002 EU3760 97

- 01 Carbon Rodding Aluminum

Spray Furnace Warwick 1970

EU4900

- 002 EU4900 BI

- 01 Hot Water Boiler Orr & S embower Model P 15 HP 1969

EU4920

- 002 EU4920 BK

- 01 Hot Water Boiler American Standard

- Kewanee Model M

115 FG 1969



### Emission Limitation:

No person may discharge into the ambient air from any single new source of emission

whatsoever, any air contaminant:

o f a shade or density equal to or darker than that designated as No. 1 on the Ringlemann

Chart (20% opacity); or

of an opacity as to obscure an observer's view to a degree equal to or greater than does

smoke designated as No. 1 on the Ringlemann Chart (20% opacity).

Permit

Condition Emission

Unit EIQ

Ref. #

(1997) Description Manufacturer, Model # Install

. Date

EU3750

- 002 EU3750 96

- 01 Boiler for Hot Oil System Eclipse Model 300

- 4

- HC

- LT

WP 1988

EU4790

- 002 EU4790 AJ

- 01 #1 Homogenizing Furnace Sunbeam 1971

EU4800

- 002 EU4800 AK

- 01 #2 Homogenizing Furnace Sunbeam 1971

EU4810

- 002 EU4810 AL

- 01 #3 Homogenizing Furnace Sunbeam S/N F

- 160

- 82 1982

EU4910

- 002 EU4910 BJ

- 01 Hot Water Boiler A.O. Smith Model 750 1981



### Monitoring:

The permittee shall conduct opacity me asurements on these emission units using

USEPA Test Method 22. Opacity measurements must be performed on individual

emission units, or, for a group of emission units that discharge to a common control

device, a measurement at the control device is suffici ent for the entire group of emission

units. Readings are only required when the emission unit is operating and when the

weather conditions allow. If no visible or other significant emissions are observed by a

Method 22 reading, then no further observatio ns would be required. For emission units

with visible emissions perceived or believed to exceed the applicable opacity standard,

the source representative would then conduct a Method 9 observation.

The following monitoring schedule must be maintained:

1. Wee kly observations shall be conducted for a minimum of eight (8) consecutive weeks

after permit issuance. Should no violation of this regulation be observed during this

period then

2. Observations must be made once every two weeks for a period of eight (8) we eks. If a

violation is noted, monitoring reverts to weekly. Should no violation of this

regulation be observed during this period then

3. Observations must be made once per month. If a violation is noted, monitoring

reverts to weekly.

If the source revert s to weekly monitoring at any time, monitoring frequency will

progress in an identical manner from the initial monitoring frequency.

The permittee shall conduct an annual opacity measurement on the emission unit by

USEPA Test Method 9 with a certified Meth od 9 observer.

## Noranda Aluminum, Inc. 10

Project No. 143

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Record keeping:

The permittee shall maintain records of all Method 22 results (see Attachment A) noting:

1. Whether any air emissions (except for water vapor) were visible from the emission

units,

2. All emission units from which visible emiss ions occurred, and

3. Whether the visible emissions were normal for the process.

The permittee shall maintain records of any equipment malfunctions.

The permittee shall maintain records of the annual USEPA Method 9 opacity test and

any other Method 9 test per formed in accordance with this permit condition.

Reporting:

The permittee shall report to the Air Pollution Control Enforcement Section, P.O. Box 176,

Jefferson City, MO 65101, no later than 10 days after any exceedance of the opacity limit

established b y 10 CSR 10

- 3.080 or 10 CSR 10

- 6.220, or any malfunction which could

possible cause an opacity exceedance.



## 10 CSR 10

- 6.260

Restriction of Emission of Sulfur Compounds (Direct Heating)

Emission Limitation:

Emissions from any new source operation shal l not contain more than five hundred parts

per million by volume (500 ppmv) of sulfur dioxide.

Emissions from any new source operation shall not contain more than thirty

- five

milligrams (35 mg) per cubic meter of sulfuric acid or sulfur trioxide or any com bination of

those gases averaged on any consecutive three hour time period.

No person shall cause or permit the emission of sulfur compounds from any source which

causes or contributes to concentrations exceeding those specified in 10 CSR 10

- 6.010

Ambient Air Quality Standards.

These emission units shall be limited to burning pipeline quality natural gas or propane.

Permit

Condition Emission

Unit EIQ

Ref. #

(1997) Description Manufacturer, Model # Install

. Date

EU4790

- 003 EU4790 AJ

- 01 #1 Homogenizing Furn ace Sunbeam 1971

EU4800

- 003 EU4800 AK

- 01 #2 Homogenizing Furnace Sunbeam 1971

EU4810

- 003 EU4810 AL

- 01 #3 Homogenizing Furnace Sunbeam S/N F

- 160

- 82 1982



### Emission Limitation:

Emissions from any existing source operation shall not contain more than two th ousand

parts per million by volume (2000 ppmv) of sulfur dioxide.

Emissions from any existing source operation shall not contain more than seventy

milligrams (70 mg) per cubic meter of sulfuric acid or sulfur trioxide or any combination of

those gases aver aged on any consecutive three hour time period.

No person shall cause or permit the emission of sulfur compounds from any source which

causes or contributes to concentrations exceeding those specified in 10 CSR 10

- 6.010

Ambient Air Quality Standards.

This emission unit shall be limited to burning pipeline grade natural gas.

Permit

Condition Emission

Unit EIQ

Ref. #

(1997) Description Manufacturer, Model # Install

. Date

EU3760

- 003 EU3760 97

- 01 Carbon Rodding Aluminum

Spray Furnace Warwick 1970

## Noranda Aluminum, Inc. 11

Project No. 143

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Monitorin

g:

None

Record keeping:

None

Reporting:

None



## 10 CSR 10

- 6.260

Restriction of Emission of Sulfur Compounds (Indirect Heating)

Emission Limitation:

No person shall cause or allow emissions of sulfur dioxide into the atmosphere from any

indirect he ating source in excess of eight pounds of sulfur dioxide per million BTUs actual

heat input averaged on any consecutive three hour time period.

No person shall cause or permit the emission of sulfur compounds from any source which

causes or contributes to concentrations exceeding those specified in 10 CSR 10

- 6.010

Ambient Air Quality Standards.

These emission units shall be limited to burning pipeline quality natural gas or propane.

Permit

Condition Emission

Unit EIQ

Ref. #

(1997) Description Manufacturer , Model # Install.

Date

EU3730

- 003 EU3730 94

- 01 Boiler for Hot Oil System Eclipse Model 600 BHC

- LT

- WP

- G

P

- FM 1970

EU3740

- 003 EU3740 95

- 01 Boiler for Hot Oil System Eclipse Model 600 BHC

- LT

- WP

- G

P

- FM 1970

EU3750

- 003 EU3750 96

- 01 Boiler for Hot Oil System Eclipse Model 300

- 4

- HC

- LT

- WP 1988

EU4900

- 003 EU4900 BI

- 01 Hot Water Boiler Orr & Sembower Model P 15 HP 1969

EU4910

- 003 EU4910 BJ

- 01 Hot Water Boiler A.O. Smith Model 750 1981

EU4920

- 003 EU4920 BK

- 01 Hot Water Boiler American Standard

- Kewanee

Model M 1 15 FG 1969



### Monitoring:

None

Record keeping:

None

Reporting:

None

## Noranda Aluminum, Inc. 12

Project No. 143

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# IV. Core Permit Requirements

The installation shall comply with each of the following emission limitations. Consult

the appropriate sections in the Code of Federal Regulations (CFR) a nd Code of State

Regulations (CSR) for the full text of the applicable requirements.

10 CSR 10

- 6.050, Start

- up, Shutdown and Malfunction Conditions

The permittee shall submit the following information to the director not later

than fifteen (15) days after receipt of the notice of excess emissions.

a) Name and location of installation;

b) Name and telephone number of person responsible for the installation;

c) The identity of the equipment causing the excess emissions;

d) The time and duration of the period of excess emissions.

e) The cause of the excess emissions;

f) The type of air contaminant involved;

g) A best estimate of the magnitude of the excess emissions expressed in

the units of the applicable emission control regulation and the

operating data and calculations used in estimating the magnitude;

h) The measures taken to mitigate the extent and duration of the excess

emissions; and

i) The measures taken to remedy the situation which caused the excess

emissions and the measures taken or planned to prevent the

recurrence of the se situations.

10 CSR 10

- 6.060, Construction Permits Required

The permittee shall not commence construction, modification, or major

modification of any installation subject to this rule, begin operation after

that construction, modification, or major modi fication, or begin operation

of any installation which has been shut down longer than five (5) years

without first obtaining a permit from the permitting authority.

10 CSR 10

- 6.065, Operating Permits

The permittee shall file for renewal of this operating permit no sooner

than eighteen months, nor later than six months, prior to the expiration

date of this operating permit. The permittee shall retain the most

current operating permit issued to this installation on

- site and shall

immediately make such permi t available to any Missouri Department of

Natural Resources personnel upon request.

10 CSR 10

- 6.110, Submission of Emission Data, Emission Fees and

Process Information

The permittee shall complete and submit an Emission Inventory

Questionnaire (EIQ) in ac cordance with the requirements outlined in this

rule.

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### 10 CSR 10

- 6.130, Controlling Emissions During Episodes of High Air

Pollution Potential

This rule specifies the conditions that establish an air pollution alert

(yellow/red), watch or emergency and the associated procedures and

emissions reduction objectives for dealing with each. The permittee shall

submit an appropriate emergency plan if required by the Director.

10 CSR 10

- 6.150, Circumvention

The permittee shall not cause or permit the installation or use of any

device or any other means which, without resulting in reduction in the

total amount of air contaminant emitted, conceals or dilutes an emission

or air contaminant which violates a rule of the Missouri Air Conservation

Commission.

10 CSR 10

- 6.180, Measurement of Emissions of Air Contaminants

a) The director may require any person responsible for the source of

emission of air contaminants to make or have made tests to determine

the quantity or nature, or both, of emission of air contaminants from

the source. The director may specify testing methods to be used in

accordance with good professional practice. The director may observe

the testing. All tests shall be performed by qualified personnel.

b) The director may conduct tests of emissions of air contaminants from

any source. Upon request of the director, the person responsible for

the source to be tested shall provide necessary ports in stacks or ducts

and other safe and proper sampling and testing facilities, exclusive of

instruments and sensin g devices as may be necessary for proper

determination of the emission of air contaminants.

c) The director shall be given a copy of the test results in writing and

signed by the person responsible for the tests.

10 CSR 10

- 3.030, Open Burning Restrictions

a) T he permittee shall not conduct, cause, permit or allow a salvage

operation, the disposal of trade wastes or burning of refuse by open

burning.

b) Exception

- Open burning of trade waste or vegetation may be

permitted only when it can be shown that open burnin g is the only

feasible method of disposal or an emergency exists which requires open

burning.

c) Any person intending to engage in open burning shall file a request to

do so with the director. The request shall include the following:

1) The name, address and telephone number of the person submitting

the application; The type of business or activity involved; A

description of the proposed equipment and operating practices, the

type, quantity and composition of trade wastes and expected

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### composition and amount of air contaminants to be released to the

atmosphere where known;

2) The schedule of burning operations;

3) The exact location where open burning will be used to dispose of the

trade wastes;

4) Reasons why no method other than open burning is feasible; and

5) Evidence t hat the proposed open burning has been approved by the

fire control authority which has jurisdiction.

d) Upon approval of the open burning permit application by the director,

the person may proceed with the operation under the terms of the open

burning permi t. Be aware that such approval shall not exempt the

permittee from the provisions of any other law, ordinance or regulation.

e) The permittee shall maintain files with letters from the director

approving the open burning operation and previous DNR inspectio n

reports.

10 CSR 10

- 3.090, Restriction of Emission of Odors

No person may cause, permit or allow the emission of odorous matter in

concentrations and frequencies or for durations that odor can be

perceived when one (1) volume of odorous air is diluted w ith seven (7)

volumes of odor

- free air for two (2) separate trials not less than fifteen

(15) minutes apart within the period of one (1) hour.

This requirement is not federally enforceable.

10 CSR 10

- 6.100, Alternate Emission Limits

Proposals for alternat e emission limitations shall be submitted on

Alternate Emission Limits Permit forms provided by the department. An

installation owner or operator must obtain an Alternate Emission Limits

Permit in accordance with 10 CSR 10

- 6.100 before alternate emission

limits may become effective.

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# V. General Permit Requirements

Permit Duration

10 CSR 10

- 6.065(6)(C)1.B.

This permit is issued for a term of five (5) years, commencing on the date of issuance.

This permit will expire at the end of this period unless renewed.

General Record Keeping and Reporting Requirements

10 CSR 10

- 6.065(6)(C)1.C

I) Record Keeping

A) All required monitoring data and support information shall be retained for a

period of at least five (5) years from the date of the monitoring sample,

measurement, r eport or application.

B) Copies of all current operating and construction permits issued to this

installation shall be kept on

- site for as long as the permits are in effect. Copies

of these permits shall be made immediately available to any Missouri

Departme nt of Natural Resources’ personnel upon request.

II) Reporting

A) The permittee shall submit a report of all required monitoring by:

1) October 1st for monitoring which covers the January through June time

period, and

2) April 1st for monitoring which covers the July t hrough December time period.

3) Exception: Monitoring requirements which require reporting more frequently

than semi annually shall report no later than 30 days after the end of the

calendar quarter in which the measurements were taken.

B) Each report must ident ify any deviations from emission limitations, monitoring,

record keeping, reporting, or any other requirements of the permit.

C) All reports shall be submitted to the Air Pollution Control Program, Operating

Permit Unit, P.O. Box 176, Jefferson City, MO 65102

. D) Submit supplemental reports as required or as needed. Supplemental reports

are required no later than ten (10) days after any exceedance of any applicable

rule, regulation or other restriction. All reports of deviations shall identify the

cause or prob able cause of the deviations and any corrective actions or

preventative measures taken.

1) Notice of any deviation resulting from an emergency (or upset) condition as

defined in paragraph (6)(C)7 of 10 CSR 10

- 6.065 (Emergency Provisions) shall

be submitted to the permitting authority either verbally or in writing within

two (2) working days after the date on which the emission limitation is

exceeded due to the emergency, if you wish to assert an affirmative defense.

The affirmative defense of emergency shall be demonstrated through properly

signed, contemporaneous operating logs, or other relevant evidence that

indicate an emergency occurred and that you can identify the cause(s) of the

emergency. The permitted installation must show that it was operated

prop erly at the time and that during the period of the emergency the

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### permittee took all reasonable steps to minimize levels of emissions that

exceeded the emission standards or requirements in the permit. The notice

must contain a description of the emergency , the steps taken to mitigate

emissions, and the corrective actions taken.

2) Any deviation that poses an imminent and substantial danger to public

health, safety or the environment shall be reported as soon as practicable.

3) Any other deviations identified in the permit as requiring more frequent

reporting than the permittee's semiannual report shall be reported on the

schedule specified in the permit.

E) Every report submitted shall be certified by the responsible official, except that,

if a report of a deviation must be submitted within ten (10) days after the

deviation, the report may be submitted without a certification if the report is

resubmitted with an appropriate certification within ten (10) days after that,

together with any corrected or supplemental inf ormation required concerning the

deviation.

F) The permittee may request confidential treatment of information submitted in

any report of deviation.

G) These supplemental reports shall be submitted to the Air Pollution Control

Program, Enforcement Section, P.O. Box 176, Jefferson City, MO 65102 no later

than ten (10) days after any exceedance of any applicable rule, regulation, or

other restriction.

Risk Management Plans Under Section 112(r)

10 CSR 10

- 6.065(6)(C)1.D.

The permittee shall comply with the requireme nts of 40 CFR Part 68, Accidental

Release Prevention Requirements, if applicable. If the permittee has more than a

threshold quantity of a regulated substance in process, as determined by 40 CFR

Section 68.115, the permittee shall submit a Risk Management Plan in accordance

with 40 CFR Part 68 no later than the latest of the following dates:

1) June 21, 1999;

2) Three (3) years after the date on which a regulated substance is first listed under

40 CFR Section 68.130; or

3) The date on which a regulated substance is first present above a threshold

quantity in a process.

Severability Clause

10 CSR 10

- 6.065(6)(C)1.F.

In the event of a successful challenge to any part of this permit, all uncontested permit

conditions shall continue to be in force.

General Requirements

10 CSR 10

- 6.065(6)(C)1.G

1) The permittee must comply with all of the terms and conditions of this permit. Any

noncompliance with a permit condition constitutes a violation and is grounds for

## Noranda Aluminum, Inc. 17

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### enforcement action, permit termination, permit revocation and re

- issuance, permit

modification or denial of a permit renewal application.

2) The permittee may not use as a defense in an enforcement action that it would have

been necessary for the permittee to halt or reduce the permitted activity in order to

maintain compl iance with the conditions of the permit.

3) The permit may be modified, revoked, reopened, reissued or terminated for cause.

Except as provided for minor permit modifications, the filing of an application or

request for a permit modification, revocation and re

- issuance, or termination, or the

filing of a notification of planned changes or anticipated noncompliance, will not

stay any permit condition.

4) This permit does not convey any property rights of any sort, nor grant any exclusive

privilege.

5) The permittee shall furnish to the Air Pollution Control Program, upon receipt of a

written request and within a reasonable time, any information that the Air Pollution

Control Program reasonably may require to determine whether cause exists for

modifying, reopening, re issuing or revoking the permit or to determine compliance

with the permit. Upon request, the permittee also shall furnish to the Air Pollution

Control Program copies of records required to be kept by the permittee. The

permittee may make a claim of confi dentiality for any information or records

submitted pursuant to 10 CSR 10

- 6.065(6)(C)1.

Incentive Programs Not Requiring Permit Revisions

10 CSR 10

- 6.065(6)(C)1.H.

No permit revision will be required for any installation changes made under any

approved ec onomic incentive, marketable permit, emissions trading, or other similar

programs or processes provided for in this permit.

Compliance Requirements

10 CSR 10

- 6.065(6)(C)3.

I) Any document (including reports) required to be submitted under this permit shall

c ontain a certification signed by the responsible official.

II) Upon presentation of credentials and other documents as may be required by law,

the permittee shall allow authorized officials of the Missouri Department of Natural

Resources, or their authorized a gents, to perform the following (subject to the

installation’s right to seek confidential treatment of information submitted to, or

obtained by, the Air Pollution Control Program):

A) Enter upon the premises where a permitted installation is located or an

emi ssions

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

conditions of this permit;

B) Have access to and copy, at reasonable times, any records that must be kept

under the conditions of this permit;

C) Inspect, at reasonable times and using reasonable safety practices, any facilities,

equipment (including monitoring and air pollution control equipment), practices,

or operations regulated or required under this permit; and

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### D) As authorized by the Missouri Air Conservation Law, Chapter 643, RSMo or the

Act, sample or monitor, at reasonable times, substances or parameters for the

purpose of assuring compliance with the terms of this permit, and all applicable

requirements as outlined in this permit.

III) All progress reports required under an applicable schedule of compliance shall be

submitted semiannually (or more frequently if specified in the applicable

requirement). These progress reports shall contain the following:

A) Dates for achieving the activities, milestones or compliance required in the

schedu le of compliance, and dates when these activities, milestones or

compliance were achieved, and

B) An explanation of why any dates in the schedule of compliance were not or will

not be met, and any preventative or corrective measures adopted.

IV) The permittee sha ll submit an annual certification that it is in compliance with all

of the federally enforceable terms and conditions contained in this permit, including

emissions limitations, standards, or work practices. These certifications shall be

submitted annually unless the applicable requirement specifies more frequent

submission. The compliance certification shall include the following:

A) The identification of each term or condition of the permit that is the basis of the

certification,

B) The current compliance stat us, as shown by monitoring data and other

information reasonably available to the installation,

C) Whether compliance was continuous or intermittent,

D) The method(s) used for determining the compliance status of the installation,

both currently and over the rep orting period, and

E) Such other facts as the Air Pollution Control Program will require in order to

determine the compliance status of this installation.

Permit Shield

10 CSR 10

- 6.065(6)(C)6.

I) Compliance with the conditions of this permit shall be deemed com pliance with all

applicable requirements as of the date that this permit is issued, provided that:

A) The applicable requirements are included and specifically identified in this

permit; or

B) The permitting authority, in acting on the permit revision or permit application,

determines in writing that other requirements, as specifically identified in the

permit, are not applicable to the installation, and this permit expressly includes

that determination or a concise summary of it.

II) Be aware that there are excepti ons to this permit protection. The permit shield

does not affect the following:

A) The provisions of section 303 of the Act or section 643.090, RSMo concerning

emergency orders,

B) Liability for any violation of an applicable requirement which occurred prior to

, or was existing at, the time of permit issuance,

C) The applicable requirements of the acid rain program,

D) The administrator's authority to obtain information, or

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### E) Any other permit or extra

- permit provisions, terms or conditions expressly

excluded from the pe rmit shield provisions.

Emergency Provisions

10 CSR 10

- 6.065(6)(C)7.

I) An emergency or upset as defined in 10 CSR 10

- 6.065(6)(C)7. shall constitute an

affirmative defense to an enforcement action brought for noncompliance with

technology

- based emissions lim itations. To establish an emergency

- or upset

- based

defense, you must demonstrate, through properly signed, contemporaneous

operating logs or other relevant evidence, the following:

A) That an emergency or upset occurred and that you can identify the source of the

emergency or upset,

B) That the installation was being operated properly,

C) That you took all reasonable steps to minimize emissions that exceeded

technology

- based emissions limitations or requirements in this permit, and

D) That you submitted notice of the emergency to the Air Pollution Control Program

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

due to the emergency. This notice must contain a description of the emergency,

any steps taken to mitigate emissions, and any c orrective actions taken.

II) Be aware that an emergency or upset shall not include noncompliance caused by

improperly designed equipment, lack of preventative maintenance, careless or

improper operation, or operator error.

Operational Flexibility

10 CSR 10

- 6. 065(6)(C)8.

An installation that has been issued a Part 70 operating permit is not required to apply

for or obtain a permit revision in order to make any of the changes to the permitted

installation described below if the changes are not Title I modificati ons, the changes do

not cause emissions to exceed emissions allowable under the permit, and the changes

do not result in the emission of any air contaminant not previously emitted. The

permittee shall notify the Air Pollution Control Program and the Admin istrator at least

seven (7) days in advance of these changes, except as allowed for emergency or upset

conditions. Emissions allowable under the permit means a federally enforceable

permit term or condition determined at issuance to be required by an appl icable

requirement that established an emissions limit (including a work practice standard)

or a federally enforceable emissions cap that the source has assumed to avoid an

applicable requirement to which the source would otherwise be subject.

I) Section 502 (b)(10) changes. Changes that, under section 502(b)(10) of the Act,

contravene an express permit term may be made without a permit revision, except

for changes that would violate applicable requirements of the Act or contravene

federally enforceable monit oring (including test methods), record keeping, reporting

or compliance requirements of the permit.

A) Before making a change under this provision, The permittee shall provide

advance written notice to the Air Pollution Control Program and to the

Administrato r, describing the changes to be made, the date on which the change

## Noranda Aluminum, Inc. 20

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### will occur, and any changes in emission and any permit terms and conditions

that are affected. The permittee shall maintain a copy of the notice with the

permit, and this agency shall place a copy with the permit in the public file.

Written notice shall be provided to the administrator and this agency at least

seven (7) days before the change is to be made. If less than seven (7) days notice

is provided because of a need to respond more qu ickly to these unanticipated

conditions, the permittee shall provide notice to the administrator and the

permitting authority as soon as possible after learning of the need to make the

change.

B) The permit shield shall not apply to these changes.

Off

- Perm it Changes

10 CSR 10

- 6.065(6)(C)9.

I) Except as noted below, The permittee may make any change in its permitted

operations, activities or emissions that is not addressed in, constrained by or

prohibited by this permit without obtaining a permit revision. Ins ignificant

activities listed in the application, but not otherwise addressed in or prohibited by

this permit, shall not be considered to be constrained by this permit for purposes of

the off

- permit provisions of this section. Off

- permit changes shall be s ubject to the

following requirements and restrictions:

A) The change must meet all applicable requirements of the Act and may not violate

any existing permit term or condition; The permittee may not change a permitted

installation without a permit revision, i f this change is subject to any

requirements under Title IV of the Act or is a Title I modification;

B) The permittee must provide written notice of the change to the permitting

authority and to the administrator no later than the next annual emissions

report . This notice shall not be required for changes that are insignificant

activities under paragraph (6)(B)3. of this rule. This written notice shall describe

each change, including the date, any change in emissions, pollutants emitted

and any applicable re quirement that would apply as a result of the change.

C) The permittee shall keep a record describing all changes made at the installation

that result in emissions of a regulated air pollutant subject to an applicable

requirement and the emissions resulting f rom these changes; and

D) The permit shield shall not apply to these changes.

Responsible Official

10 CSR 10

- 6.020(2)(R)12.

The application utilized in the preparation of this was signed by Stephen J. Heddle,

President of Primary Products 

### . If this person terminates employment, or is reassigned

different duties such that a different person becomes the responsible person to

represent and bind the installation in environmental permitting affairs, the owner or

operato r of this air contaminant source shall notify the Director of the Air Pollution

Control Program of the change. Said notification shall be in writing and shall be

submitted within 30 days of the change. The notification shall include the name and

title of the new person assigned by the source owner or operator to represent and bind

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### the installation in environmental permitting affairs. All representations, agreement to

terms and conditions and covenants made by the former responsible person that were

used in the establishment of limiting permit conditions on this permit will continue to

be binding on the installation until such time that a revision to this permit is obtained

that would change said representations, agreements and covenants.

Statement of Bas is

10 CSR 10

- 6.065(6)(E)1.C.

This permit is accompanied by a statement setting forth the legal and factual basis for

the draft permit conditions (including references to applicable statutory or regulatory

provisions). This Statement of Basis, while refere nced by the permit, is not an actual

part of the permit.

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Attachment A



### Visible Emissions Inspection Log

Date Were visible

emissions

observed? Visible emissions were observed

from these emission units. The emissions were

Yes No Less

than

normal Normal Greater

than

normal

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Attachment B



### Particulate Matter Emissions Form

Emission Unit

Date Throughput (T) Emission Factor

(EF ) Hours of

Operation (H) Emission Rate

(T*EF/H)

Units: Lbs./unit Lbs./hr

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# STATEMENT OF BASIS

Permit Reference Documents

These documents w ere relied upon in the preparation of the operating permit. Because

they are not incorporated by reference, they are not an official part of the operating

permit.

1) Part 70 Operating Permit Application, received May 13, 1997; revised 1999

2) Emissions In ventory Questionnaire, received April 1, 1998

3) U.S. EPA document AP

- 42, Compilation of Air Pollutant Emission Factors ; Volume

I, Stationary Point and Area Sources, Fifth Edition.

Applicable Requirements Included in the Operating Permit but Not in the

Ap plication

In the operating permit application, the installation indicated they were not subject to

the following regulation(s). However, in the review of the application, the agency has

determined that the installation is subject to the following regulati on(s) for the reasons

stated.

10 CSR 10

- 6.180, Measurement of Emissions of Air Contaminants

, This rule has been included in the operating permit in order to provide citing for

the allowance of requests for emissions data results. On past forms issued by

the Air Pollution Control Program, including the application for this permit, it

was automatically marked as an administrative rule not required to be listed as

an applicable requirement. It is no longer judged to be solely administrative and

is, therefo re, included in the operating permit.

Other Air Regulations Determined Not to Apply to the Operating Permit

None

Construction Permit Revisions

No revisions

NSPS Applicability

It has been determined that the New Source Performance Standards for steam

g enerating units (40 CFR Part 60 Subparts Da, Db and/or Dc) are not applicable to

any of the steam generating units addressed in this permit (EU3730, EU3740,

EU3750, EU4900, EU4910, EU4920) because of size as shown in the following table.

Emission

Unit # Year Size

(mmbtu/hour) Size for Da

Applicability Size for Db

Applicability Size for Dc

Applicability

EU3730 1970 4.0 >250 >100 10, but 100

EU3740 1970 2.0 >250 >100 10, but 100

EU3750 1988 0.6 >250 >100 10, but 100

EU4900 1969 0.6 >250 >100 1 0, but 100

EU4910 1981 1.2 >250 >100 10, but 100

EU4920 1969 1.2 >250 >100 10, but 100

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### It has been determined that the New Source Performance Standards for Primary

Aluminum Reduction Plants (40 CFR Part 60 Subpart S) is not applicable to any of the

units addressed in this permit because this standard is only applicable to potroom

groups and anode bake plants. None of the equipment addressed in this permit is part

of a potroom group or an anode bake plant.

MACT Applicability

It has been determi ned that the National Emission Standards for Hazardous Air

Pollutants from primary aluminum reduction plants and from secondary aluminum

production are not applicable to any of the units addressed in this permit because of

the following reasons.

40 CFR Pa rt 63 Subpart LL is not applicable to any of the emission units addressed in

this permit because boilers, furnaces and raw material unloading equipment are not

affected units. Affected units are potlines, paste production plants, and anode bake

furnaces.

40 CFR Part 63 Subpart RRR is not applicable to any of the units addressed in this

permit because boilers, raw material unloading equipment and homogenizing furnaces

are not affected units. The furnaces are not affected units because they are not

involve d in melting, holding, refining, fluxing, or alloying. The homogenizing furnaces

just take final product (ingot) and heat without melting.

Other Regulatory Determinations

The installation will be divided into segments for operating permit purposes, with each

segment receiving a separate operating permit. This permit will be for the boilers and

for the furnaces that will not be affected by the National Emission Standards for

Hazardous Air Pollutants (Subparts LL and/or RRR) and for the river unloading and

railcar unloading.

10 CSR 10

- 6.090 is not applicable to any of the emission units addressed in this

permit because the rule only applies to potroom groups and anode bake plants. None

of the units addressed in this permit are part of a potroom group or anode bake plant.

10 CSR 10

- 3.050 was listed as applicable to emission units EU3730, EU3740,

EU3750, EU4900, EU4910, and EU4920 in the supplemental information submitted

by Noranda. It has been determined that this regulation is not applicable to these

e mission points because indirect heating units are exempt. These emission units are

considered indirect heating units because fuel is burned for the primary purpose of

producing steam, hot water or hot air and in the course of doing so, the products of

comb ustion do not come into direct contact with the process materials.

10 CSR 10

- 3.060 is not applicable to emission units EU3730, EU3740, EU4900 and

EU4920 because they are considered existing units (installed prior to April 3, 1971)

with a heat input capaci ty of ten (10) million BTU per hour or less.

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### The following assumptions were made in the review of the application and preparation

of this document.

1. It was assumed that the process weight rate for emission units EU3760, EU4790,

EU4800 and EU4810 was equal to one ton per hour. This was a conservative

assumption and gave 4.1 pounds/hour of allowable particulate matter emissions.

2. It was assumed that emission units EU4790 (year

– 1971) and EU4800 (year

– 1971) meet the definition of new sources under state r egulation 10 CSR 10

- 3.080

and are, therefore, subject to the more restrictive 20% opacity limit instead of the

40% opacity for existing sources. This conservative assumption was made because

the month was not indicated in any of the application documents. The

applicability date for “new” versus “existing” for this regulation is April 3, 1971.

3. It was assumed that emission units EU4790 (year

– 1971) and EU4800 (year

– 1971) meet the definition of new source under state regulation 10 CSR 10

- 6.260

and are, th erefore, subject to the more restrictive 500 ppm sulfur dioxide limit

instead of the 2000 ppm sulfur dioxide limit for existing sources. This conservative

assumption was made because the month was not indicated in any of the

application documents. The ap plicability date for “new” versus “existing” for this

regulation is February 24, 1971.

4. A flow rate of at least 10 cubic feet/second was assumed for the aluminum holding

furnace (EU3760). The flow rate was not given in the emissions inventory

questionnaire so this conservative estimate of flow rate was made based on the flow

rates given for the other similar equipment in the emissions inventory

questionnaire.

5. It was assumed that emission units EU4790, EU4800, and/or EU4810 were not

modified or reconstructed after June 9, 1989, and therefore, New Source

Performance Standards for Small Industrial

- Commercial

- Institutional Steam

Generating Units (NSPS Subpart Dc) would not be applicable. This assumption

was made based on the fact that the application indicated that NSPS Subpart Dc

was not applicable.

6. Because of the negligible sulfur content of natural gas and propane it was assumed

that the units covered by this permit do no cause or contribute to concentrations of

sulfur compounds in the ambient air that exceed those specified in 10 CSR 10

- 6.010. Noranda has provided documents indicating that only low sulfur natural

gas and/or propane is being purchased. (documentation pending)

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### 7. For the purposes of determining compliance with 10 CSR 10

- 3.050, the following cal culations were made:



# Process Weight Limitation Calculations

Column A Col. B Column C Col. D Col. E Column F Col. G Col. H Col. I Col. J Col. K Col. L Col. M Col. N Col. O Col. P Column Q Col. R Col. S Column T Column U

Max. Control Device Rate A llowed Process Emission Factors (EF) Tons Per Year Actual

EIQ Design State UnCont. Cont. Versus

Emission Ref. # Rate Reg. Capture Control Emission Emission Reg. EF EF Uncontrolled Controlled Allowable Complia nce

Unit No. (1997) (tons/hr) Pollutant Number Description Efficiency Efficiency Rate Rate Allowable Units EF Source Rating Units PTE PTE Limit (%) Comments/Description

EU0010 01

- 01 30.6 PM10 3.050 Baghouse 100 9 9 177.712 1.77712 40.14 lb/hr 5.8 FIRE U lb/ton 778.4 7.8 N/A 4.4 in compliance

EU0020 02

- 01 30.6 PM10 3.050 Baghouse 100 99 177.712 1.77712 40.14 lb/hr 5.8 FIRE U lb/ton 778.4 7.8 N/A 4.4 in compliance

EU0030 03

- 01 7.7 PM10 3.050 Baghouse 100 99 44.4425 0.44443 16.04 lb/hr 5.8 FIRE U lb/ton 194.7 1.9 N/A 2.8 in compliance

EU0040 03

- 02 7.7 PM10 3.050 Baghouse 100 99 44.4425 0.44443 16.04 lb/hr 5.8 FIRE U lb/ton 194.7 1.9 N/A 2.8 in compliance

EU0050 03

- 03 7.7 PM10 3.050 Baghouse 100 99 44.4425 0.44443 1 6.04 lb/hr 5.8 FIRE U lb/ton 194.7 1.9 N/A 2.8 in compliance

EU0060 03

- 04 7.7 PM10 3.050 Baghouse 100 99 44.4425 0.44443 16.04 lb/hr 5.8 FIRE U lb/ton 194.7 1.9 N/A 2.8 in compliance

EU0070 03

- 05 7.7 PM10 3.050 Baghouse 100 99 44.4425 0.44443 16.04 lb/hr 5.8 FIRE U lb/ton 194.7 1.9 N/A 2.8 in compliance

EU0080 03

- 06 7.7 PM10 3.050 Baghouse 100 99 44.4425 0.44443 16.04 lb/hr 5.8 FIRE U lb/ton 194.7 1.9 N/A 2.8 in compliance

EU0090 03

- 07 7.7 PM10 3.050 Baghouse 100 99 44.4425 0.44443 16.04 lb/hr 5.8 FIRE U lb/ton 194.7 1.9 N/A 2.8 in compliance

EU0100 03

- 08 7.7 PM10 3.050 Baghouse 100 99 44.4425 0.44443 16.04 lb/hr 5.8 FIRE U lb/ton 194.7 1.9 N/A 2.8 in compliance

EU0110 04

- 01 0.1 PM10 3.050 Cyclone 100 99 0.64 0.00638 0.93 lb/hr 5.8 FIRE U lb/ton 2.79 0 .03 N/A 0.7 in compliance w/o control

EU0120 04

- 02 0.1 PM10 3.050 Cyclone 100 99 0.64 0.00638 0.93 lb/hr 5.8 FIRE U lb/ton 2.79 0.03 N/A 0.7 in compliance w/o control

EU0130 04

- 03 0.1 PM10 3.050 Cyclone 100 99 0.64 0.00638 0.93 lb/hr 5.8 FIRE U lb/ton 2. 79 0.03 N/A 0.7 in compliance w/o control

EU0140 04

- 04 0.1 PM10 3.050 Cyclone 100 99 0.64 0.00638 0.93 lb/hr 5.8 FIRE U lb/ton 2.79 0.03 N/A 0.7 in compliance w/o control

EU0150 04

- 05 0.1 PM10 3.050 Cyclone 100 99 0.64 0.00638 0.93 lb/hr 5.8 FIRE U lb/to n 2.79 0.03 N/A 0.7 in compliance w/o control

EU3760 97

- 01 2.0 PM10 3.050 N/A 0.01 0.0148 4.10 lb/hr 7.6 FIRE D lb/mmcf 0.06 N/A 0.4 in compliance w/o control

EU4790 AJ

- 01 15.0 PM10 3.050 N/A 0.11 0.111003 4.10 lb/hr 7.6 FIRE D lb/mmcf 0.49 N /A 2.7 in compliance

EU4800 AK

- 01 15.0 PM10 3.050 N/A 0.11 0.111003 4.10 lb/hr 7.6 FIRE D lb/mmcf 0.49 N/A 2.7 in compliance

EU4810 AL

- 01 15.0 PM10 3.050 N/A 0.11 0.111003 4.10 lb/hr 7.6 FIRE D lb/mmcf 0.49 N/A 2.7 in compliance



### Column C = p rocess rate weight (P)

Column K = calculated allowable in lb/hr (E)

### Noranda Aluminum, Inc. SB

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### E is calculated from the following formula:

E = 4.1 (P) 0.67



### Uncontrolled emissions (column I) = emission factor (column M) x max. design rate (column C)

Controlled emissions (column J) = uncontrolled emissions (column I) x (1

- (capture efficiency (column G) x control efficiency (column H)/ 10,000))

8. For the purposes of determining compliance with 10 CSR 10

- 3.060, the following calculations were made:



# Indirect Heating Limitation Calculati ons

Column A Col. B Column C Col. D Col. E Column F Col. G Col. H Col. I Col. J Col. K Col. L Col. M Col. N Col. O Col. P Column Q Col. R Col. S Column T Column U

Max. Control Device Rate Allowed Process Emission Factors (EF) Tons Per Year Actual

EIQ Design State UnCont. Cont. Versus

Emission Ref. # Rate Reg. Capture Control Emission Emission Reg. EF EF Uncontrolled Controlled Allowable Compliance

Unit No. (1997) (mmbtu/hr) Pollutant Number Descript ion Efficiency Efficiency Rate Rate Allowable Units EF Source Rating Units PTE PTE Limit (%) Comments/Description

EU3750 96

- 01 0.6 PM10 3.060 N/A 0.01 0.61 lb/mmbtu 7.6 FIRE D lb/mmcf 0.02 N/A 1.2 in comp liance

EU4910 BJ

- 01 1.2 PM10 3.060 N/A 0.01 0.61 lb/mmbtu 7.6 FIRE D lb/mmcf 0.04 N/A 1.2 in compliance



### Column K = calculated allowable in lb/mmbtu (E)

E is calculated from the following formula:

E = 0.90 (Q)

- .174



### Where Q = the installation he at input in millions of BTU per hour (Q=9.6 mmbtu/hour

– this number is obtained from summing all of the indirect heating

units including those exempt from this regulation

Uncontrolled emissions (column I) = emission factor (column M) /1027 mmbtu/mmcf

9. For the purposes of determining compliance with 10 CSR 10

- 6.260 (direct heating), the following calculations were made:

### Noranda Aluminum, Inc. SB

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# Sulfur Dioxide Limitation Calculations

Column A Col. B Column C Col. D Col. E Column F Col. G Col. H Col. I Col. J Col. K Col. L Col . M Col. N Col. O Col. P Column Q Col. R Col. S Column T Column U

Max. Control Device Rate Allowed Process Emission Factors (EF) Tons Per Year Actual

Design State UnCont. Cont. Versus

Emission EIQ # Rate Reg. Capture Control Emission Emission Reg. EF EF Uncontrolled Controlled Allowable Compliance

Unit No. (1997) (mmcf/hr) Pollutant Number Description Efficiency Efficiency Rate Rate Allowable Units EF Source Rating Units PTE PTE Limit (%) Comments/D escription

EU3760 97

- 01 0.00195 SO2 6.260 151.04 2000 ppmv 0.6 FIRE A lb/mmcf 0.01 N/A 7.6 in compliance

EU4790 AJ

- 01 0.01461 SO2 6.260 46.81 500 ppmv 0.6 FIRE A lb/mmcf 0.04 N/A 2.3 in compl iance

EU4800 AK

- 01 0.01461 SO2 6.260 46.81 500 ppmv 0.6 FIRE A lb/mmcf 0.04 N/A 2.3 in compliance

EU4810 AL

- 01 0.01461 SO2 6.260 46.81 500 ppmv 0.6 FIRE A lb/mmcf 0.04 N/A 9.4 in compliance



### Uncontrolled emissions (column I) = emissi on factor (column M) x max. design rate (column C) x 453.59 x 10 6 

### g/lb)/stack flow rate (ft 3 

### /min

- from

EIQ)/0.028317 (m 3 

### /ft 3 

### ) x 24.465 (l/mole)/1000 (l/m3) /64 (g/mole)

10. For the purposes of determining compliance with 10 CSR 10

- 6.260 (indirect heati ng), the following calculations were made:

### Noranda Aluminum, Inc. SB

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# Sulfur Dioxide Limitation Calculations

Column A Col. B Column C Col. D Col. E Column F Col. G Col. H Col. I Col. J Col. K Col. L Col. M Col. N Col. O Col. P Column Q Col. R Col. S Column T Column U

Max. Control Device Rate Allowed Process Emission Factors (EF) Tons Per Year Actual

Design State UnCont. Cont. Versus

Emission EIQ # Rate Reg. Capture Control Emission Emission Reg. EF EF Uncontrolled Controlled Allowable Compliance

Unit No. (1997) (mmcf/hr) Pollutant Number Description Efficiency Efficiency Rate Rate Allowable Units EF Source Rating Units PTE PTE Limit (%) Comments/Description

EU3730 94

- 01 0.00389 SO 2 6.260 N/A 0.0006 8 lb/mmbtu 0.6 FIRE A lb/mmcf 0.01 N/A 0.0 in compliance

EU3740 95

- 01 0.00195 SO2 6.260 N/A 0.0006 8 lb/mmbtu 0.6 FIRE A lb/mmcf 0.01 N/A 0.0 in compliance

EU3750 96

- 01 0.00058 SO2 6.260 N/A 0.0006 8 lb/mmbtu 0.6 FIRE A lb/mmcf 0.00 N/A 0.0 in compliance

EU4900 BI

- 01 0.00058 SO2 6.260 N/A 0.0006 8 lb/mmbtu 0.6 FIRE A lb/mmcf 0.00 N/A 0.0 in compliance

EU4910 BJ

- 01 0.00117 SO2 6.260 N/A 0.0006 8 lb/mmbtu 0.6 FIRE A lb/mmcf 0.00 N/A 0.0 in complia nce

EU4920 BK

- 01 0.00117 SO2 6.260 N/A 0.0006 8 lb/mmbtu 0.6 FIRE A lb/mmcf 0.00 N/A 0.0 in compliance



### Uncontrolled emissions (column I) = emission factor (column M) /1027 mmbtu/mmcf

### Noranda Aluminum, Inc. SB

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### Other Regulations Not Cited in the Operating Permit or the A bove Statement of

Basis

Any regulation which is not specifically listed in either the Operating Permit or in the

above Statement of Basis does not appear, based on this review, to be an applicable

requirement for this installation for one (1) or more of t he following reasons:

1. The specific pollutant regulated by that rule is not emitted by the installation;

2. The installation is not in the source category regulated by that rule;

3. The installation is not in the county or specific area that is regulated under the

authority of that rule;

4. The installation does not contain the type of emission unit which is regulated by

that rule;

5. The rule is only for administrative purposes.

Should a later determination conclude that the installation is subject to one (1) or

mo re of the regulations cited in this Statement of Basis or other regulations which

were not cited, the installation shall determine and demonstrate, to the APCP's

satisfaction, the installation's compliance with that regulation(s). If the installation is

n ot in compliance with a regulation, which was not previously cited, the installation

shall submit to the APCP a schedule for achieving compliance for that regulation(s).

Prepared by:

Timothy Paul Hines

Environmental Engineer

### Noranda Aluminum, Inc.

#1 Robbins Road

New Madrid, MO 63869

Re: Noranda Aluminum, Inc.

#1 Robbins Road

New Madrid, MO 63869

Permit Number:

Dear Sir/Madam:

Enclosed with this letter is your operating permit. Please review this document carefully. Operation of

your in stallation in accordance with the rules and regulations cited in this document is necessary for

continued compliance.

If you have any questions or need additional information regarding this permit, please contact the Air

Pollution Control Program (APCP) at (573) 751

- 4817, or you may write to the Department of Natural

Resources, Air Pollution Control Program, P.O. Box 176, Jefferson City, MO 65102.

Sincerely,

AIR POLLUTION CONTROL PROGRAM

Randy Raymond

Permits Section Chief

RER:thk

Enclosures

c: U S EPA Region VII

Southeast Regional Office

PATs File: 143

- 0008

- 020

### David Hart, Environmental Manager CERTIFIED MAIL: Z 321 860 002

Noranda Aluminum, Inc. RETURN RECEIPT REQUESTED

#1 Robbins Road

New Madrid, MO 63869

Re: Draft Title V Operating Permit

– Project No.: 143

- 0008

- 020

Dear Mr. Hart:

The Air Pollution Control Program (APCP) has completed the preliminary review of your Title V permit

application. A public notice will be placed in the Dexter Daily Statesman on July 16, 2000. The

conditions and monitoring requirements of the draft permit are open for comment by the publ ic and you

until August 15, 2000. Standard permit wording (i.e. General Requirements) is not open for comment,

since these provisions are required by law and regulation.

The APCP will accept comments regarding the conditions and monitoring regulations tha t are postmarked

on or before the closing date. Please address comments or recommendations for changes to my attention

at:

Operating Permits Unit

Air Pollution Control Program

P.O. Box 176

Jefferson City, MO 65102

A copy of this draft has also been s ent to the U.S. EPA’s Region VII office in Kansas City for their

review. The Region VII office is afforded, by law, oversight authority on any Title V permit which

Missouri (or any of the other states in the region) may propose to issue. A public hearing may be held if

sufficient interest is expressed by the public.

Should you have any questions, or wish clarification on any items in this draft permit, please feel free to

contact me at (573) 751

- 4817.

Sincerely,

AIR POLLUTION CONTROL PROGRAM

Timothy Paul Hines

Environmental Engineer

TPH/blw

Enclosures

c: PATS File

## Illinois, Kentucky, Arkansas, Tennessee

RE: Affected States Review

– Notification of Proposed Final Part 70 Operating Permit

Dear Mr. {Director’s Name}:

In accor dance with Missouri State Rule 10 CSR 10

- 6.065(6)(F)1. and the Clean Air Act this letter is to

notify you of public notice of the preliminary draft and request for comments for:

Noranda Aluminum, Inc., New Madrid, MO 63869

Project Number

– 143

- 0008

- 0 20

Public notice will be published in the newspaper published in, city, on date.

You are invited to submit any relevant information, materials, and views in support of or in opposition to

the draft operating permits in writing by no later than date + 30 to my attention at Missouri Department of

Natural Resources, Air Pollution Control Program, P.O. Box 176, Jefferson City, MO 65102.

Should you require further information or documentation on this matter, please contact the Operating

Permits Unit at (573) 75 1

- 4817. Thank you for your time and attention.

Sincerely,

AIR POLLUTION CONTROL PROGRAM

Randy Raymond

Permit Section Chief

RDR: TPH ct first initial