MONTANA DEPARTMENT OF ENVIRONMENTAL QUALITY 

OPERATING PERMIT TECHNICAL REVIEW DOCUMENT 

Permitting and Compliance Division 

1520 E. Sixth Avenue 

P.O. Box 200901

Helena, Montana 59620-0901

Columbia Falls Aluminum Company LLC 

2000 Aluminum Drive 

Columbia Falls, MT 59912 

The following table summarizes the air quality programs testing, monitoring, and reporting requirements 

applicable to this facility. 

Facility Compliance Requirements Yes No Comments

Source Tests Required X Method 5, 13B, 

315, 14 

Ambient Monitoring Required X POM 

COMS Required X 

CEMS Required X 

Schedule of Compliance Required X Appendix I 

Annual Compliance Certification and Semiannual Reporting Required X

Monthly Reporting Required X 

Quarterly Reporting Required X 

Applicable Air Quality Programs 

ARM Subchapter 7 Preconstruction Permitting X Permit 2655-05

New Source Performance Standards (NSPS) X 

National Emission Standards for Hazardous Air Pollutants (NESHAPS) X 40 CFR, 

Subpart M 

Maximum Achievable Control Technology (MACT) X 62 FR 52407 & 

65 FR 15689 

Major New Source Review (NSR) X 

Risk Management Plan Required (RMP) X

Acid Rain Title IV X 

State Implementation Plan (SIP) X MT State SIP 

OP2655-01 1 Date of Decision: 05/21/03

Effective Date: 06/21/03 
TABLE OF CONTENTS

SECTION I. GENERAL INFORMATION...........................................................................................................1

A. PURPOSE........................................................................................................................................................1

B. FACILITY LOCATION.....................................................................................................................................1

C. FACILITY BACKGROUND INFORMATION .....................................................................................................1

F. COMPLIANCE DESIGNATION ........................................................................................................................5

SECTION II. SUMMARY OF EMISSION UNITS .............................................................................................6

A. FACILITY PROCESS DESCRIPTION ................................................................................................................6

EMISSION UNITS AND POLLUTION CONTROL DEVICE IDENTIFICATION ....................................7

B. CATEGORICALLY INSIGNIFICANT EMITTING UNITS/ACTIVITIES ...............................................................8

SECTION III. PERMIT CONDITIONS................................................................................................................8

A. EMISSION LIMITS AND STANDARDS ............................................................................................................8

B. MONITORING REQUIREMENTS .....................................................................................................................9

C. TEST METHODS AND PROCEDURES ...........................................................................................................15

D. RECORDKEEPING REQUIREMENTS .............................................................................................................15

E. REPORTING REQUIREMENTS ......................................................................................................................15

F. PROPOSED PERMIT COMMENTS .................................................................................................................15

SECTION IV. FUTURE PERMIT CONSIDERATIONS.................................................................................16

A. MACT STANDARDS ...................................................................................................................................16

B. NESHAP STANDARDS ...............................................................................................................................16

C. NSPS STANDARDS .....................................................................................................................................16

D. RISK MANAGEMENT PLAN.........................................................................................................................16

SECTION V. OTHER PERMIT CONSIDERATION ...................................................................................16

OP2655-01 2 Date of Decision: 05/21/03

Effective Date: 06/21/03 
SECTION I. GENERAL INFORMATION 

A. Purpose 

B.

C. 

This document establishes the basis for the decisions made regarding the applicable requirements, monitoring

plan, and compliance status of emission units affected by the operating permit proposed for this facility. The

document is intended for reference during review of the proposed permit by the EPA and the public. It is also

intended to provide background information not included in the operating permit and to document issues that

may become important during modifications or renewals of the permit. Conclusions in this document are 

based on information provided in the original application submitted by Columbia Falls Aluminum Company,

LLC (CFAC), on June 12, 1996, and on additional submittals received on April 17, 1997, June 25, 1999,

August 25, 1999, February 14, 2000, March 15, 2000, April 4, 2000, and the minor modification application 

received on August 29, 2002. The Aluminum MACT was promulgated on October 7, 1997. The MACT 

requirements for the VSS2 category of Aluminum Reduction Plants (40 CFR Part 63, Subpart LL) have been 

incorporated into CFAC's operating permit. 

Facility Location

The CFAC facility is located in Section 3, Township 30 North, Range 20 West, Flathead County, Montana. 

The UTM coordinates for the facility are 712.2 km Easting, 5363.8 km Northing (Zone 11). The elevation of 

the plant is 3108 feet, with the nearest significant complex terrain, Teakettle Mountain, rising approximately

2000 additional feet above the valley floor and CFAC. 

The facility is adjacent to the community of Columbia Falls, and the Flathead River passes South of CFAC's

main complex. There are two PSD Class 1 airsheds nearby the facility, the closest being Glacier National Park

whose boundary is approximately 8 miles East of CFAC. The other Class 1 airshed is the Bob Marshall

Wilderness, and it is within approximately 25 miles of Columbia Falls.

Facility Background Information 

CFAC operates five Vertical Stud Soderberg potlines at the Columbia Falls plant. Each potline has 120 

individual cells that produce aluminum by the Hall-Heroult process. Annual operating capacity is

approximately 185,000 tons of Aluminum based on an average current efficiency of 90.5%. The Anaconda 

Company initially constructed two potlines ('53-55), with startup occurring in 1955 (West Plant). A third

potline was constructed and its startup occurred in 1965; the final two potlines were constructed shortly after 

the third, with startup occurring in 1968 (East Plant). 

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

(Al2O3), dissolved in molten cryolite. The reduction process is accomplished in a Vertical Stud Soderberg 

style pot. Soderberg technology describes the type of consumable carbon anode used in the process. CFAC

Soderberg pots (cells) have 60-ton anodes (Positive Electrode) and 100-ton cathodes (negative electrode). 

The cells or “pots” are housed in buildings called potrooms. Two potrooms are connected electrically in series 

to form one potline. Therefore, at CFAC there are 10 potrooms that comprise the 5 potlines. Emissions from

each pot are divided into two categories, primary emissions and secondary emissions. Primary emissions are 

captured at the pots and routed to the primary air pollution control system, the A398 dry alumina scrubbers. 

Secondary emissions are fugitive emissions from the pots that are vented out the roofline of the potrooms 

Alumina is fed into a molten bath of cryolite, and heated to about 1740°F (949°C). Through the 

electrochemical process, electricity passes from the anode to the cathode, causing the aluminum to be reduced.

The aluminum metal sinks below the cryolite bath to form a molten aluminum “pad”. The remaining oxygen 

atoms bond with the carbon from the anode of the cell to form carbon dioxide, which is vented from the pot to 

the primary emission control system. Carbon Monoxide is also generated, and is combusted at the cell. Other 

emissions from the process include both particulate fluoride and gaseous hydrogen fluoride as well as 

hydrocarbon emissions containing polycyclic organic matter. The aluminum metal is siphoned from the pot 

OP2655-01 1 Date of Decision: 05/21/03

Effective Date: 06/21/03 
every 48 hours and transported to the casting Department, where it is cast into ingots of various sizes, shapes 

and alloys. Typically each pot produces approximately 1700 pounds of aluminum per day. Each pot is tapped 

every other day, which results in a pot operational cycle of 48 hours. 

The facility underwent significant improvements between 1976 and 1980, when all aluminum reduction cells 

and potline operation were converted to Sumitomo Technology. Sumitomo Technology was adopted by the 

Anaconda Company in an effort to reduce particulate and fluoride emissions from the facility, and to show 

compliance with Montana’s stringent Fluoride Standard. The Sumitomo Technology, purchased by AAC from

the Sumitomo Chemical Company LTD, is a combination of engineering (structural) changes to the aluminum

reduction cells, operational and process changes, and raw material changes, for Soderberg aluminum reduction

cells and potlines. 

Other benefits, besides reduced power consumption and reduced emissions (power consumption, as claimed by

the Sumitomo Company, could easily be reduced by 15-20 %, and emissions of hydrocarbon smoke and fluoride 

could be reduced by 50%...), realized by AAC when adopting the Sumitomo Technology were a dramatic 

increase in cell operating lifespan and a reduction in man-hours required to operate and maintain the facility.

During that same time period (1976-1980), the Anaconda Company also converted the Columbia Falls facility

from multiclones and wet scrubbers to Alcoa A398 Dry Alumina Scrubbers as its primary emission control 

device, and installed ten dry scrubbers operating in two groups: four dry scrubbers for the West Plant and six 

dry scrubbers for the East Plant. Dry Alumina Scrubbers are designated as appropriate primary pollution 

control devices for purposes of the Aluminum MACT. 

Preconstruction Permit History

The aluminum smelter was constructed prior to 1968 and has been operated as an existing source since that

time. The facility processes alumina ore using electrolytic reduction cells to produce aluminum ingots. CFAC 

has been issued eight previous permits from 1976 to 1990. A description of these previous permits is as 

follows: 

Permit #972 was issued on July 16, 1976, for the installation of a dry scrubbing system - Sumitomo Soderberg 

process to control emissions from the reduction cells. 

Permit #1615 was issued on June 25, 1981, for the conversion of the unloader baghouses controlling the #1 

and #2 alumina unloading systems from shaker type baghouses to pulse-jet baghouses. 

Permit #1620 was issued on September 24, 1981, for the installation of a baghouse to control emissions from

the coke unloading area. 

Permit #1672 was issued on April 20, 1982, for the construction of a new aluminum casting facility. The 

facility was never constructed and the permit will be revoked.

Permit #1688 was issued on July 1, 1982, for the construction of a temporary alumina storage building and the 

associated alumina transfer operation. The transfer operation has been completed and the building is currently

being used for other purposes and CFAC has no intentions of using it to store alumina in this manner again. 

This permit will be revoked.

Permit #1820 was issued on October 21, 1983, for the installation of the west conveyor storage silo baghouse,

the coke and coal distribution baghouse, and the paste plant Draco dust control system. 

Permit #2568 was issued on April 10, 1989, for the installation of a wet scrubber to control emissions from the 

paste plant area. 

Permit #2655 was issued on December 13, 1990, for the installation of an alumina recycle baghouse and a

baghouse to control emissions from the Treatment of Aluminum in Crucibles (TAC) system. 

OP2655-01 2 Date of Decision: 05/21/03

Effective Date: 06/21/03 
Permit Alteration #2655-01 was issued on March 3, 1996, for the conversion of the existing west conveyor 

storage baghouse in the west alumina unloader station and the bucket elevator baghouse in the east alumina

unloader system from shaker-type baghouses to pulse-jet baghouses. The west conveyor storage baghouse

will also be relocated from silo #2 to silo #3. 

Also included in this permitting action is a system name change. The #1 and #2 alumina unloading systems

referred to in Permit #1615 are actually the west and east alumina unloader baghouses, respectively. These

baghouses were authorized to be modified from shaker-type baghouses to pulse-jet baghouses by Permit 

#1615. A more complete description of the unloader station control systems is contained in the analysis for 

Permit #2655-01. 

Permit #2655-02, issued on July 5, 1997, authorized the replacement of the existing anode pin cleaning 

machine with a new machine which will clean ten anode pins at a time. The cleaning system consists of a 

shotblasting machine for the removal of scale from the anode pins. Particulate emissions from the system are 

controlled with a cartridge-type fabric filter. Emissions from the filter will be exhausted inside the pin 

cleaning room. 

Emissions from the facility are expected to decrease from the pin cleaning machine replacement. Because the

system will vent inside the pin cleaning room, a decrease in the particulate exhausted to atmosphere is 

anticipated. The existing system currently exhausts directly to atmosphere. 

After issuance of the Department's preliminary determination, CFAC requested that the west alumina elevator 

baghouse identified in Section II.C.1 of the permit be changed to the west conveyor storage baghouse to be 

consistent with the changes made in Permit #2655-01. 

On June 27, 1996, CFAC submitted a permit application to modify the paste plant anode dust control system. 

This application was given number 2655-03. Based on the soon to be issued de minimis rule - ARM 

17.8.705(1)(q), this project would not require a permit to be issued. CFAC determined that construction would 

not commence until after the rule was promulgated and withdrew the application. Therefore, Permit #2655-03

was never issued. 

Permit #2655-04 allowed CFAC to replace the existing wet scrubber on the paste plant mixers with a dry coke 

pitch fume scrubber for the control of particulates and polycyclic organic matter (POM). The dry scrubber is

required by 40 CFR Part 63, Subpart LL - National Emission Standards for Hazardous Air Pollutants for 

Primary Aluminum Smelters. The new dry scrubber also controlled emissions from the extruders, which is

currently uncontrolled. 

The emissions from the mixers and extruders are collected with hoods and routed to a venturi reactor where 

coke fines are injected. The pitch fume binds with the coke particles and is then collected with a pulse-jet

baghouse. After collection, the solids are returned to the paste plant production system and used as coke in the 

manufacture of anode briquettes. 

Permit #2655-04 allowed the replacement of the wet scrubber, and also allowed the routing of a previouslyuncontrolled source, with a new dry scrubber. The new dry scrubber significantly decreased the emissions of 

both particulate and POM from the paste plant. 

Permit #2655-04 also changed Attachment 1 to remove reporting parameters no longer needed by the

Department. The deadline to submit CFAC’s annual fluoride-in-forage data was also changed from February 1 

to March 1, and the rule references in the permit were also updated to correspond with the newly recodified

Air Quality Rules. 

Permit #2655-05 was issued on December 26, 1999, for the transfer of ownership of Columbia Falls 

Aluminum Company (CFAC) to Glencore AG. The facility has been renamed Columbia Falls Aluminum

Company LLC, and is referred to as "CFAC" within this permit. CFAC informed the Department of the

OP2655-01 3 Date of Decision: 05/21/03

Effective Date: 06/21/03 
ownership change in a letter dated April 16, 1999, and again in a fax transmittal dated May 26, 1999. The last 

communication indicated that the change of ownership would occur no later than June1, 1999. The 

Department acknowledged the change of ownership in a letter to CFAC dated June 22, 1999. 

Title V Permit History

On November 6, 2001, Title V Operating Permit #OP2655-00 was issued to CFAC. The permit included all 

applicable conditions under the Title V of the Clean Air Act. 

D. Current Permit Action

On November 28, 2001, CFAC requested a modification to Permit #OP2655-00. The request was for the

removal of the following items as attachments to the Title V permit: Appendix F – CFAC MACT 

Implementation Plan; Appendix G – CFAC MACT Quick Reference Guide; Appendix H – Startup, Shutdown 

and Malfunction Plan (SSM); Appendix K – Pollution Control Device Inspection & Maintenance Plan. 

Although the hard copies of these appendices have been removed from the permit, the contents of the 

appendices remain applicable requirements as stated in the Title V Operating Permit #OP2655-01. A hard

copy of the fore mentioned appendices, are available at the following locations: 

The Department of Environmental Quality

Permitting and Compliance Division 

Air and Waste Management Bureau

1520 E. Sixth Ave. 

Helena, Montana 59620-0901 

Bureau Phone #: (406) 444-3490 

OR 

Columbia Falls Aluminum Company, LLC 

2000 Aluminum Drive 

Columbia Falls, Montana 59912 

Phone #: (406) 892-8211 

In Section III, B5, C5, D7, G3, N4, and O3, the permit language was changed from “CFAC shall continually 

operate and maintain the baghouse in accordance with Appendix K of this permit” to “CFAC shall operate and 

maintain the baghouse in accordance with Appendix K of this permit”. 

In Appendix J “Potline Roof Vent Opacity Compliance Demonstration”, the last sentence was changed from

“CFAC shall perform daily visual surveys following the procedures outlined above: to “CFAC shall perform

daily visual observations in a manner similar to the Method 9 procedures outlined above and it is understood

by all parties that these daily visual observations are not Method 9 observations.” 

In Section III.I.8 the language was rewritten to state “Method 9 tests shall be conducted in accordance with the 

Montana Source Test Protocol and Procedures Manual. Method 9 test reports shall be maintained on site and 

must be submitted to the Department upon request.” 

In Section III.H.5, the permit language was updated to be consistent with Section III.I.5. Permit #OP2655-01

will replace Permit #OP2655-00. 

E. Taking and Damaging Analysis

HB 311, the Montana Private Property Assessment Act, requires analysis of every proposed state agency 

administrative rule, policy, permit condition or permit denial, pertaining to an environmental matter, to 

determine whether the state action constitutes a taking or damaging of private real property that requires

compensation under the Montana or U.S. Constitution. As part of issuing an operating permit, the Department 

OP2655-01 4 Date of Decision: 05/21/03

Effective Date: 06/21/03 
is required to complete a Taking and Damaging Checklist. As required by 2-10-101 through 105, MCA, the 

Department has conducted a private property taking and damaging assessment and has determined there are no

taking or damaging implications. The checklist was completed on May 5, 2000. 

F. Compliance Designation 

The CFAC facility was inspected on June 22, 2001, January 26, 2000, and September 17, 2002, and 

determined to be in compliance with the terms and conditions of its Preconstruction Permit # 2655-05. The

facility has been conducting testing for Fluorides and POM on the A398 dry scrubbers and the Method 14

manifolds to determine compliance with 40 CFR Part 63, Subpart LL, the "Aluminum MACT.” The 

compliance date for the Aluminum MACT was October 7, 1999, and compliance reporting is performed on a 

quarterly basis. The Aluminum MACT allows 45 days to prepare and submit the report after the conclusion of 

the reporting quarter. CFAC identified in Revision 2 of their MACT Implementation Plan (IP) that the facility

would demonstrate compliance with the 5-line (average) Fluoride emission limit for VSS2 facilities, and the 

single line POM emission limit for VSS2 facilities. 

CFAC has submitted (two) additional revisions to their IP since June 2000. CFAC submitted revision 3 to the IP, by 

fax, on June 14, 2000, and in that submittal indicated that they were electing to perform POM emission averaging,

and that they would demonstrate compliance with the five-line POM emission limit (CFAC elected to demonstrate 

compliance with the single-line POM limit prior to the IP revision 3 submittal). The Department is allowed 120

days to review and either approve or disapprove IP revisions, and prior to responding, CFAC submitted an 

additional IP revision (revision 4) to the Department, as well as an updated SSM. A revision 5 of CFAC's IP was 

submitted on October 2, 2000. The earliest that the five-line POM emission limit would have been applicable, 

allowing a 120-day decision period, is October 12, 2000 (4th quarter of 2000).

CFAC has submitted several MACT compliance reports. The first report, received on February 11, 2000, 

indicated that three potlines were not in compliance with the single line limit for POM, VSS2 category

aluminum reduction plants, during the last quarter of 1999. The first report did indicate that CFAC was in 

compliance with the fluoride emission limit (five-potline average). CFAC has not been able to demonstrate 

compliance with the single line POM emission limit, or the five-line average POM emission limit, up through 

the date that the plant suspended operations in January 2001. CFAC has, however, demonstrated compliance

with the five-line fluoride emission limit since the MACT compliance date.

CFAC initially assumed that the source of their POM problem lied in the testing equipment, methodology, or 

analysis. The facility has been performing extensive in-house testing, and also has a contractor performing

testing, in an attempt to determine the source of POM test result discrepancies and the high POM test results. 

CFAC has also identified several other possible contributing sources for their higher POM test results, including 

operation of the Paste Plant dry coke scrubber, a new supplier of coal tar pitch, changes in operation, and the 

variability intrinsic to Method 315 (POM test method). 

CFAC temporarily shut down 2.5 potlines in the fall of 2000 due to high power costs. CFAC shut down

(temporarily) the remaining 2.5 potlines in January of 2001, also as a result of high power costs. CFAC has 

indicated that the facility intends to request the EPA to revise their current POM emission limit, such that

1999/2000 year testing data shall be used to establish an updated VSS2 POM emission limit. Upon such date

as the facility commences operations (anticipated startup date of January, 2002), they must demonstrate 

compliance with either the existing POM limit, or the proposed/new POM limit within a reasonable period of 

time (180 days) after startup.

The facility will be required to deliver a plan to resolve their POM compliance issues. A compliance schedule is 

provided in Appendix I of Operating Permit #OP2655-00. The Department understands that EPA has a primary

role in establishing a revised POM emission limit, and that EPA may impose alternative timelines for a 

compliance demonstration based upon their assessment of this issue, the test data collected thus far, or other 

relevant data. The Department or EPA may determine that the timeframes identified in the compliance

schedule may need to be altered, dependant upon EPA's response to CFAC's request, CFAC's actual startup 

date, or other pertinent issues. 

OP2655-01 5 Date of Decision: 05/21/03

Effective Date: 06/21/03 
SECTION II. SUMMARY OF EMISSION UNITS 

A. Facility Process Description 

Petroleum Coke and Coal Tar Pitch are transported to CFAC for the production of anode briquettes. The coke

is pulverized by ball mills prior to being mixed with the heated Pitch. The mixture is then extruded into a

water bath, and then transported by conveyor to individual storage locations for the West Plant potlines and

East Plant potlines. The anode briquettes are then loaded into trucks that feed to the top of each of the 

Soderberg anodes once every 48 hours. Unreacted Alumina is brought by rail to the East and West Plant 

unloader and storage silo systems. From those unloading and storage locations, the alumina is conveyed (air 

slides) to the West and East Plant dry scrubbing system silos prior to being injected into the Alcoa A398 

reactors. The reacted alumina is then fed to storage silos, and ultimately to oreing trucks that feed the reacted 

ore to the pots once every 3 hours. 

The five potlines at CFAC each have two potrooms, and each potroom has 60 reduction cells, or pots, for a

total of 600 pots for the production of aluminum. The reduction process occurs when the 120 pots that

comprise one potline are subjected to a continuous (direct) current in excess of 100,000 amps (100 KA). The

pots are connected in series, with the voltage drop across each pot close to, but typically greater than, 4 volts. 

This very high electrical current produces a pot environment of approximately 950°C.

Pots are tapped once every 48 hours, with the metal then going to one of six casting furnaces. The molten 

aluminum can then either be sent directly to casting, or fluxed and alloyed prior to casting. Casting of molten 

aluminum can occur in any of six casting pits. The T-ingots and Sheet ingots from casting are then sent to

saws for cutting to length, then stacked in a storage yard for shipment to CFAC customers. 

Other necessary potline activities to maintain the reduction cells (pots) are Pin Pulling, Jack Slipping, Anode 

Blowdown, Crust Breaking, Skirt Changes, Burner Cleaning, and Floor Sweeping. Ancillary activities 

necessary for CFAC to maintain aluminum production are pin cleaning and pot rebuilding, to name only two.

OP2655-01 6 Date of Decision: 05/21/03

Effective Date: 06/21/03 
Emission Units and Pollution Control Device Identification 

The emission units regulated by this permit are the following (ARM 17.8.1211). 

Emission 

Unit ID 

Emission Unit 

Description 

Pollution Control Device 

or Practice 

EU001 Ball Mill North - MH01 Baghouse 

EU002 Ball Mill South - MH02 Baghouse 

EU003 Coke Silo - MH04 Baghouse 

EU004 East Alumina Elevator - MH06 Baghouse 

EU005 East Alumina Unloading - MH07 Baghouse 

EU006 East Conveyor Storage - MH08 Baghouse 

EU007 West Alumina Unloading - MH09 Baghouse 

EU008 Anode Dust Control System - MH03 Baghouse 

EU009 Coke Unloading - MH05 Baghouse 

EU010 West Conveyor Storage - MH10 Baghouse 

EU011 Potline Sweeping - AR04 Baghouse 

EU012 Treatment of Aluminum Crucibles (TAC) Operations - CO10 Baghouse 

EU013 Pin Cleaning - West Plant - CR07 Baghouse 

EU014 Pin Cleaning - East Plant – CR07a Baghouse 

EU015 Paste Plant Extruder - PP01 Procedair Dry Coke Scrubber (Baghouse) 

EU016 Paste Plant Mixer - PP02 Procedair Dry Coke Scrubber (Baghouse) 

EU017 Pinhole Past Drying - PP03 Baghouse 

EU018 Pitch Storage Tank Vents - PP04 None 

EU019 Therminol Oil Heating System - PP05 None 

EU020 East Plant Dry Scrubber Alumina Transfer (North) - AR01 Baghouse 

EU021 East Plant Dry Scrubber Alumina Transfer (South) - AR02 Baghouse 

EU022 West Plant Dry Scrubber Alumina Transfer (North) - AR06 Baghouse 

EU023 West Plant Dry Scrubber Alumina Transfer (South) - AR07 Baghouse 

EU024 Primary Gas Collection System - West Plant 

(Potlines 1 & 2) - AR05 

Alcoa A398 Dry Alumina Scrubber #1 

(Reactor #1 & Baghouse) 

EU025 Primary Gas Collection System - West Plant 

(Potlines 1 & 2) - AR05 

Alcoa A398 Dry Alumina Scrubber #2 

(Reactor #2 & Baghouse) 

EU026 Primary Gas Collection System - West Plant 

(Potlines 1 & 2) - AR05 

Alcoa A398 Dry Alumina Scrubber #3 

(Reactor #3 & Baghouse) 

EU027 Primary Gas Collection System - West Plant 

(Potlines 1 & 2) - AR05 

Alcoa A398 Dry Alumina Scrubber #4 

(Reactor #4 & Baghouse) 

EU028 Primary Gas Collection System - East Plant 

(Potlines 3, 4, & 5) - AR05 

Alcoa A398 Dry Alumina Scrubber #5 

(Reactor #5 & Baghouse) 

EU029 Primary Gas Collection System - East Plant 

(Potlines 3, 4, & 5) - AR05 

Alcoa A398 Dry Alumina Scrubber #6 

(Reactor #6 & Baghouse) 

EU030 Primary Gas Collection System - East Plant 

(Potlines 3, 4, & 5) - AR05 

Alcoa A398 Dry Alumina Scrubber #7 

(Reactor #7 & Baghouse) 

EU031 Primary Gas Collection System - East Plant 

(Potlines 3, 4, & 5) - AR05 

Alcoa A398 Dry Alumina Scrubber #8 

(Reactor #8 & Baghouse) 

EU032 Primary Gas Collection System - East Plant 

(Potlines 3, 4, & 5) - AR05 

Alcoa A398 Dry Alumina Scrubber #9 

(Reactor #9 & Baghouse) 

EU033 Primary Gas Collection System - East Plant 

(Potlines 3, 4, & 5) - AR05 

Alcoa A398 Dry Alumina Scrubber #10 

(Reactor #10 & Baghouse) 

EU034 Potline #1 Roof Vent, West Plant - AR03 None 

EU035 Potline #2 Roof Vent, West Plant - AR03 None 

EU036 Potline #3 Roof Vent, East Plant - AR03 None 

EU037 Potline #4 Roof Vent, East Plant - AR03 None 

EU038 Potline #5 Roof Vent, East Plant - AR03 None 

EU039 Casting Furnace #3 - CO01 None 

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 

OP2655-01 7 Date of Decision: 05/21/03

Effective Date: 06/21/03 
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 

EU050 T-Ingot Saw – CO09 Target Box and Cyclone 

EU051 Sandblasting Activities - CR01 None 

EU052 Lectromelt Furnace - CR03 Wet Scrubber 

EU053 Rod Mill / Material Storage - CR04 Baghouse 

EU054 Change House Boiler #1 - MP01 None 

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 

EU064 Gasoline Storage Tank - MP04 None 

B. Categorically Insignificant Emitting Units/Activities 

Emission Unit ID Description 

IEU03 Collector Bar Shotblasting - CR02 

IEU04 Anode Debris Storage - CR05 

IEU05 Anode Abrader - CR06 

IEU06 Shed 11 Pot Rebuild / Masonry Mixer - CR08 

IEU07 Diesel Storage Tanks - MP03 

IEU09 Open Burning - MP10 

IEU10 Plantsite Sanitary Landfill - MP13

IEU11 Propane Storage - MP14 

IEU12 Waste Oil Heat Recovery - MP18

IEU13 MSDS Chemicals / Plantwide Usage - MP19 

SECTION III. PERMIT CONDITIONS 

A. Emission Limits and Standards 

The Aluminum MACT allows CFAC to select potline emission limits, applicable to EU024-EU038, based 

upon the following guidelines: 

lb TF / Ton Al produced lb POM / Ton Al produced 

Single Potline (Single Potline) 2.6* 3.6 

Two-Potline Avg. (West Plant) 2.6 3.2 

Three-Potline Avg. (East Plant) 2.5 3.0 

Five-Potline Avg. (Entire Plant) 2.4 2.9 

Plant-Wide Emission Limits for the above sources are based upon the tons of aluminum produced (TAP). 

At this point in time, CFAC has indicated that for TF the facility will comply with the five-potline emission 

limit, and for POM they have selected the single-potline emission limit. CFAC may elect to satisfy an 

alternative scheme identified by the above table (Table C of the MACT Quick Reference Guide (Appendix 

G)), and request to change their IP to reflect their new choice of emission limits. IP changes must be 

submitted to the Department for approval prior to implementation. 

OP2655-01 8 Date of Decision: 05/21/03

Effective Date: 06/21/03 
On June 14, 2000, CFAC faxed a notification to the Department that they would like to change from the single 

potline emission limit for POM, to the five-potline emission limit, or 2.9 lb/TAP, for POM. CFAC will be

required to submit an updated IP, indicating their new POM emission limit selection, for approval, to the 

Department. 

The IP (CFAC’s MACT Implementation Plan (Appendix F)), described above, includes a testing plan that

CFAC will be employing to demonstrate compliance with the above MACT emission limits, as well as the 

emission control device operating parameters that are to be monitored.

Permit #2655-05 imposes the following additional emission limitations: 

1. 2.6-lb TF / TAP single-potline emission limit (as opposed to the 2.7 MACT single-line requirement); 

2. 20% opacity limit for the Primary Control System (Dry Alumina Scrubbers), EU024-EU033; the 

potroom/potline roof monitors, EU034-EU038, are subject to a 10% opacity limit; 

3. 0.02 gr/dscf requirement for EU008 through EU014;and 

4. POM emissions controlled from EU015 and EU016 by a Dry Coke Scrubber. 

EU024-EU038 are expressly excluded from the Process Weight Rule by ARM 17.8.310(3)(a). 

All remaining emission units (EU’s), at a minimum, are subject to Generally Applicable Requirements: ARM 

17.8.304, 17.8.308, 17.8.309, 17.8.310, 17.8.322, 17.8.324, 17.8.1212, and 17.8.1207.

B. Monitoring Requirements

ARM 17.8.1212(1) requires that all monitoring and analysis procedures or test methods required under 

applicable requirements are contained in operating permits. In addition, when the applicable requirement does 

not require periodic testing or monitoring, periodic monitoring must be prescribed that is sufficient to yield

reliable data from the relevant time period that is representative of the source's compliance with the permit. 

The requirements for testing, monitoring, recordkeeping, reporting and compliance certification sufficient to

assure compliance, does not require the permit to impose the same level of rigor for all emission units. 

Furthermore, it does not require extensive testing or monitoring to assure compliance with the applicable 

requirements for emission units that do not have significant potential to violate emission limitations or other 

requirements under normal operating conditions. When compliance with the underlying applicable 

requirement for a insignificant emission unit is not threatened by lack of regular monitoring and when periodic 

testing or monitoring is not otherwise required by the applicable requirement, the status quo (i.e., no

monitoring) will meet the requirements of ARM 17.8.1212(1). Therefore, the permit does not include 

monitoring for insignificant emission units. 

The permit includes periodic monitoring or recordkeeping for each applicable requirement. The information 

obtained from the monitoring and recordkeeping will be used by the permittee to periodically certify

compliance with the emission limits and standards. However, the Department may request additional testing

to determine compliance with the emission limits and standards. 

EU001 – EU007 Material Handling Emitting Units with Baghouses (III.B) 

EU001 - Ball Mill North - MH01 EU005 - East Alumina Unloading - MH07

EU002 - Ball Mill South - MH02 EU006 - East Conveyor Storage - MH08 

EU003 - Coke Silo - MH04 EU007 - West Alumina Unloading - MH09

EU004 - East Alumina Elevator - MH06 

EU001-EU007 are subject to the generally applicable requirements of III.A, as well as the inspection and 

maintenance requirements in the Pollution Control Device Inspection & Maintenance Plan (Appendix ), of this 

operating permit. The potential emissions from these baghouses are such that they do not require a frequent 

testing schedule; therefore, testing is scheduled "as required" by the Department. 

OP2655-01 9 Date of Decision: 05/21/03

Effective Date: 06/21/03 
The Department has confidence that the material handling baghouses identified above are providing good

control of particulate and opacity emissions when CFAC employs a Pollution Control Device Inspection & 

Maintenance Plan (I & M plan) (Appendix K). One component of the I & M plan is a weekly visual survey to 

determine what the visible emissions of the various emission units are. The I & M plan also establishes a 

routine of scheduled maintenance and recordkeeping. In summary, the Department has determined that the 

implementation and continued use of a baghouse I & M plan substantially assures compliance with the opacity

and particulate emission limits. 

EU008 - EU014 Emitting Units with Baghouses & Grain Loading Restrictions (III.C) 

EU008 - Anode Dust Control System - MH03 EU012 - Treatment of Aluminum Crucibles - CO10 

EU009 - Coke Unloading - MH05 EU013 - Pin Cleaning - West Plant - CR07

EU010 - West Conveyor Storage - MH10 EU014 - Pin Cleaning - East Plant - CR07a 

EU011 - Potline Sweeping AR04 

EU008-EU014 are subject to a 0.02 gr/dscf requirement (Permit #2655-05), as well as the generally applicable

requirements of III.A. These material handling baghouses are subject to the I & M requirements of Appendix 

K. The potential emissions from these baghouses are such that they do not require a frequent testing schedule

to demonstrate compliance with their emission limits; therefore, the testing frequency is "as required" by the 

Department. The Department has determined that the material handling baghouses identified above are 

providing good control of particulate and opacity emissions when CFAC employs a baghouse I & M plan, and

that implementation of an I & M plan substantially assures compliance with those limits. 

EU015 - EU019 Paste Plant Emitting Units with Baghouses (III.D) 

EU015 - Paste Plant Extruder - PP01 EU016 - Paste Plant Mixer - PP02 

EU017 - Pinhole Paste Drying - PP03 

The Paste Plant Extruder (EU015) and the Paste Plant Mixer (EU016) are provided emission control by the 

Paste Plant Dry Coke Scrubber, which replaced a wet scrubbing system as part of the facility's effort to comply

with the Aluminum MACT. The MACT and preconstruction permit requires that the coke scrubber operate

whenever the Paste Plant is operating, and that operating parameters are monitored and logged on a daily basis. 

As required by the Department, CFAC shall perform a semiannual Method 9 test to demonstrate compliance 

with the opacity limitation on the dry coke scrubber. 

If the dry coke scrubber operating parameters (as defined in the CFAC MACT IP) are exceeded, CFAC must 

initiate corrective actions. Similarly, a daily visual survey must be performed on the emissions from the 

scrubber stack, and excessive emissions are to be logged and corrective actions initiated. 40 CFR 63.848 (f) - 

(i) requires that CFAC monitor and record operating parameter exceedances, and that the seventh exceedance

during a semiannual period (plus each additional exceedance after the seventh, but only one exceedance for 

any given 24-hour period) shall be reported as a violation. 

EU018 - Pitch Storage Tanks - PP04 (III.E) & EU019 - Therminol Oil Heating System - PP05 (III.F) 

EU018 and EU019 are subject to the generally applicable requirements of this operating permit, specifically

ARM 17.8.304(1) & (2). The opacity limitation for the condensation tower (vent) on the pitch storage tanks 

(EU018) is 20%, while the opacity limitation on the Therminol Oil Heating System (EU019) is 40%. New

Pitch storage tanks have additional requirements imposed by the Aluminum MACT, which this exiting pitch 

storage tank is not subject to. Similarly, the Therminol Oil Heating System is not addressed by the MACT, nor 

are there any applicable requirements, other than generally applicable requirements, that this emission unit is 

subject to. It is unlikely that either of these units will exceed their opacity limitations; therefore, annual 

certification and semiannual reporting are adequate to demonstrate compliance. 

OP2655-01 10 Date of Decision: 05/21/03

Effective Date: 06/21/03 
EU020 - EU023 Primary Scrubber System Alumina Transfer Emitting Units (III.G) 

EU020 - East Plant Dry Scrubber Alumina Transfer 

(North) - AR01 

EU022 - West Plant Dry Scrubber Alumina Transfer 

(North) - AR06 

EU021 - East Plant Dry Scrubber Alumina Transfer 

(South) - AR02

EU023 - West Plant Dry Scrubber Alumina Transfer 

(South) - AR07

The primary scrubbing system alumina transfer baghouses above are subject to the generally applicable 

requirements: ARM 17.8.304(2), 20% opacity, and ARM 17.8.310, particulate matter, based upon process 

weight. The capacity of these baghouses is such that their potential emissions are below the threshold that 

would require periodic testing; therefore, the compliance demonstration will be testing as required by the 

Department. However, the Department is also requiring that these emission units be subject to a baghouse I &

M plan. The I & M plan (Appendix K) provides assurance that these baghouses operate at their maximum

effectiveness.

EU024 - EU033 Primary Gas Collection System Emitting Units (III.H) 

EU025 - Primary Gas Collection System - West Plant - 

Scrubber #1 - AR05 

EU030 - Primary Gas Collection System - East Plant - 

Scrubber #6 - AR05 

EU026 - Primary Gas Collection System - West Plant - 

Scrubber #2- AR05 

EU031 - Primary Gas Collection System - East Plant - 

Scrubber #7 - AR05 

EU027 - Primary Gas Collection System - West Plant - 

Scrubber #3 - AR05 

EU032 - Primary Gas Collection System - East Plant - 

Scrubber #8 - AR05 

EU028 - Primary Gas Collection System - West Plant - 

Scrubber #4 - AR05 

EU033 - Primary Gas Collection System - East Plant - 

Scrubber #9 - AR05 

EU029 - Primary Gas Collection System - East Plant - 

Scrubber #5 - AR05 

EU034 - Primary Gas Collection System - East Plant - 

Scrubber #10 - AR05 

EU024-EU033, the ten Alcoa A398 dry alumina scrubbers that comprise the primary control system, are 

subject to the requirements of 40 CFR Part 63, Subpart LL (Aluminum MACT), as well as requirements 

imposed by CFAC's preconstruction permit (ARM 17.8.315). The primary pollutants for these emission units

that are addressed by the aluminum MACT and CFAC's preconstruction permit are Total Fluoride (TF) and 

Polycyclic Organic Matter (POM). The primary control system effectively captures and processes the fluoride 

gases evolving from each reduction cell (pot). Most of the POM emissions evolve from the anode, and anode

related activities; therefore, most POM emissions are predominantly fugitive in nature and are not captured by

the primary control system. 

The aluminum MACT provides a mechanism for CFAC to average the emissions from their potlines, which 

provides more operational flexibility to the facility. However, with each emission averaging scenario, whether 

averaging the two lines of the West plant, the three lines of the East Plant, or all five lines for the entire plant, 

each averaging scenario imposes a successively more restrictive emission limit for both TF and POM. The rules 

for emission averaging are described in Subpart LL, and CFAC was required to submit an IP describing how 

CFAC would satisfy the requirements of the MACT (Appendix F of this operating permit) before the facility was 

permitted to average their emissions. CFAC's MACT IP was reviewed by the Department and the US EPA, and 

underwent several revisions. The current IP version states that the facility was not going to average POM 

emissions at the current time; however, they elected to average the TF emissions for all five potlines. 

ARM 17.8.310(a) specifically excludes the application of the process weight rule to the particulate matter 

emitted from the reduction cells of a primary aluminum reduction plant. Therefore, excluding opacity, the 

emission limit (Table C, Appendix G) specifies the TF and POM emission limits necessary for CFAC to 

satisfy both the MACT requirements for VSS2 category facilities and their existing preconstruction permit 

requirements. If CFAC demonstrates compliance with the limits specified by Table C, then they will have 

satisfied both the operating permit and the preconstruction permit limits. The primary control system is 

subject to a 20% opacity limitation, and CFAC must perform daily visual surveys for opacity. Similarly,

OP2655-01 11 Date of Decision: 05/21/03

Effective Date: 06/21/03 
CFAC must monitor the operating parameters of the primary control system, and if parameter exceedances 

occur, take corrective action as prescribed in their Startup, Shutdown, and Malfunction Plan (SSM), which is 

Appendix H of this operating permit. 

To demonstrate compliance with the Table C emission limits for TF and POM, CFAC must determine the 

emissions from each potline roof (sampling from the Method 14 Manifold systems) and from the primary control 

system (dry alumina scrubbers), and calculate the total emissions from each potline for both pollutants. The 

primary control system (their are two at CFAC: West Plant and East Plant) must be tested once annually for both 

TF and POM; CFAC will use the test results to maintain a 12-month rolling average of TF emissions from the 

primary control system, and a quarterly average POM emission. Testing the secondary emissions, those emissions 

exiting from the potroom roofs, is performed with a much higher frequency; a minimum of three runs per month for 

TF and one run per month for POM from the Method 14 manifold systems. An important distinction between TF 

and POM emissions is the averaging periods; TF is a monthly average, while POM is a quarterly average. 

Details of the operating permit and MACT testing and reporting requirements are lengthy, and the operating

permit specifies what those requirements are. The quarterly reporting provided to the Department by CFAC

will allow the facility and the Department to determine CFAC's compliance with any of the TF and POM 

emission limits defined by Table C. Also, on a quarterly basis, CFAC must report their compliance status with 

the permit and MACT requirements, including the number of operating parameter exceedances. 

EU034 - EU038 Potline Roof Vent Emitting Units (III.I) 

EU034 - Potline #1 Roof Vent-West Plant - AR03 EU037 - Potline #4 Roof Vent- East Plant - AR03 

EU035 - Potline #2 Roof Vent-West Plant - AR03 EU038 - Potline #5 Roof Vent- East Plant - AR03 

EU036 - Potline #3 Roof Vent- East Plant - AR03 

The potline roof monitors (roof vents) are subject to the requirements of 40 CFR Part 63, Subpart LL 

(Aluminum MACT), as well as the requirements of CFAC's preconstruction permit (ARM 17.8.315). Since 

the MACT emission limits for TF and POM apply to (are imposed upon) all emissions from the reduction cells 

that comprise the potlines, the total emissions from aluminum production at CFAC must be determined from

both the primary control system and from the potline roofs. 

CFAC installed an EPA approved manifold system (Method 14 Manifolds) for each of their five potlines. The 

manifolds are intended to draw a representative sample of potroom fugitive emissions (secondary emissions) 

from the potline roof monitors down to an accessible sampling location. The Method 14 duct has two 

sampling ports at 90° from each other, similar to the port configuration on any exhaust stack. As with the 

primary control system, these manifold ducts must be sampled for both TF and POM emissions. 

As with the primary control system at CFAC, ARM 17.8.310(a) specifically excludes application of the 

process weight rule to determine a particulate matter emission limit for the particulate emissions from of the

potline roofs. The potline roofs are subject to a 10% opacity limitation, and CFAC must perform daily visual

surveys, as well as quarterly Method 9 tests, as described by the procedure proposed by CFAC in Appendix J 

of the operating permit (OP2655-00). 

CFAC initially proposed to perform Method 9 tests on potrooms 1 and 10, suggesting that those two potrooms

are representative of the West and East Plants, to demonstrate compliance with the 10% opacity limit. 

However, in order for CFAC to demonstrate that potrooms 1 and 10 are representative of the entire facility, 

they would first have been required to demonstrate that all potrooms are operated exactly alike, without

significant operation deviations. CFAC would have done this by monitoring operational parameters of the 

potlines. CFAC has, alternatively, proposed a procedure (Appendix J) to determine the opacity from at least a 

portion of each of the five potlines. 

OP2655-01 12 Date of Decision: 05/21/03

Effective Date: 06/21/03 
The emission limit table (Table C, Appendix G) specifies the TF and POM emission limits necessary for 

CFAC to satisfy both the MACT requirements for VSS2 category facilities, and their existing preconstruction

permit requirements. If CFAC demonstrates compliance with the limits specified by Table C, then they will 

have satisfied both the operating permit and the preconstruction permit limits. 

To demonstrate compliance with the Table C emission limits for TF and POM, CFAC must calculate the total 

emissions from each potline for both pollutants. As stated previously, testing the secondary emissions that exit 

from the potline roofs is performed with more frequency than for the primary systems; a minimum of three 

runs per month for TF and one run per month for POM from the Method 14 manifold systems. Again, an 

important distinction between TF and POM emissions is the averaging periods; TF is a monthly average, while

POM is a quarterly average. The test results from all valid test runs must be used to determine compliance 

with the emission limits. 

Details of the operating permit and MACT testing and reporting requirements are lengthy, and the operating

permit specifies what those requirements are. The quarterly reporting provided to the Department by CFAC

will allow the facility and the Department to determine CFAC's compliance with any of the TF and POM 

emission limits defined by Table C. Also, on a quarterly basis, CFAC must report their compliance status with 

the permit and MACT requirements, including the number of operating parameter exceedances. 

EU039 - EU043 Casting Furnace Emitting Units (III.J) 

EU039 - Casting Furnace #3 - CO01 EU042 - Casting Furnace #7 - CO04 

EU040 - Casting Furnace #4 - CO02 EU043 - Casting Furnace #8 & #9 - CO05

EU041 - Casting Furnace #6 - CO03 

The natural gas-fired casting furnaces at CFAC are only subject to generally applicable requirements. Therefore, 

the compliance demonstration required by this permit for the opacity, particulate matter from fuel combustion, 

and sulfur in fuel requirements, for their natural gas boilers shall consist of burning only natural gas or LPG. This 

does not preclude the Department from initiating an enforcement action if a Reference Method test indicates one 

of the limits is being violated. The compliance date for the Secondary Aluminum MACT is March 24, 2003. 

CFAC's operating permit does not currently address the requirements of the Secondary MACT.

EU044 - EU048 Casting Pit Emitting Units (III.K) 

EU044 - Casting Pit #3 - CO06 EU047 - Casting Pit #8 & #9 - CO06

EU045 - Casting Pit #4 - CO06 EU048 – Dross Handling - CO07 

EU046 - Casting Pit #6 & #7 - CO06

All casting is conducted indoors, and the casting pits are subject to the generally applicable requirements of 

ARM 17.8.304(1) and 310. A Method 9 test shall be performed, as required, to determine compliance with the 

40% opacity limit. However, because all casting activities are conducted indoors, Method 9 testing will focus 

on the visible emissions exiting from openings, vents, or stacks of the casting building(s). Demonstrating 

compliance with the opacity requirements shall be indicative of "normal operations,” and also be indicative of 

compliance with the particulate matter emission limit. The compliance date for the Secondary Aluminum

MACT is March 24, 2003. CFAC's operating permit does not currently address the requirements of the 

Secondary MACT. 

EU049 - EU050 Aluminum Saw Emitting Units (III.L) 

 EU049 – Sheet Ingot Saw - CO08 EU050 – T- Ingot Saw - CO09 

EU049-EU050 are subject to the generally applicable requirements of III.A, specifically, ARM 17.8.304(2) 

and 310. The potential emissions from these saws are such that they do not require a frequent testing schedule;

therefore, testing is scheduled as required by the Department. 

OP2655-01 13 Date of Decision: 05/21/03

Effective Date: 06/21/03 
Both of the aluminum saws above have an aluminum chip control and recovery system that is interlocked with 

the operation of the saws. The system referred to, for both saws, has a device that acts as a target box, plus a fan 

and cyclone. Also, each saw has a "bailer" device to form the aluminum chips into a size and shape suitable for 

introduction back into a furnace. The systems are similar, however the cyclone of EU049 vents to atmosphere, 

while EU050 vents indoors. The T-Ingot saw control system also has an alternate operational configuration that 

allows a filter medium to be placed between the cyclone and target box, which is an integral part of the target 

box. When this system is in the "filter" configuration, it bypasses the cyclone, but still vents indoors.

Because the aluminum saws cannot run without their control and recovery systems also running, and both saws

are also operated within buildings, particulate emissions from the aluminum saws (aluminum chips and dust) 

are effectively controlled. Particulate emissions from material handling cyclones are very consistent, and the 

Department is confident that testing as required is sufficient to demonstrate continued compliance with opacity

and particulate limits. 

EU051 – Sandblasting Activities - CR01 (III.M) 

The sandblasting activities are associated with maintenance work being performed, and is conducted outdoors. 

As such, these activities are subject to a 20% opacity limitation. CFAC shall conduct a weekly survey of 

visible emissions from sandblasting activities and, if excessive fugitive emissions are identified by the visual

survey, CFAC must initiate efforts to minimize or curtail the emissions. Also, as required by the Department, 

CFAC shall perform a Method 9 test. CFAC is not required to perform monitoring or testing to demonstrate

compliance with the particulate matter emission limit. 

EU052 – Lectromelt Furnace Emitting Unit - CR03 (III.N) 

The Lectromelt Furnace is currently controlled by a wet scrubber; however, CFAC has recently (June 7, 2000) 

provided a de minimis notification indicating that the scrubber is being replaced by a 13,000-ACFM baghouse 

with an estimated exhaust grain loading of 0.02 gr/dscf. The baghouse will be subject to generally applicable

requirements, as well as the Pollution Control Device Inspection & Maintenance Plan (I&M Plan) (Appendix

K). The potential emissions from this baghouse are such that it does not require a frequent testing schedule, 

therefore testing is scheduled as required by the Department. 

The Department has confidence that the baghouse identified above will provide good control of particulate and 

opacity emissions when CFAC employs a baghouse I & M plan (Appendix K). One component of the I & M

plan is a weekly visual survey. The I & M plan also establishes a routine of scheduled maintenance and 

recordkeeping. In summary, the Department has determined that the implementation and continued use of a 

baghouse I & M plan substantially assures compliance with the opacity and particulate emission limits. 

EU053 – Rod Mill/Material Storage Emitting Unit - CR04 (III.O) 

The Rod Mill Building (this building formerly housed a rod mill) is now used for material storage, and the 

baghouse is used to control emissions generated as a result of material handling. The potential emissions from

this baghouse are such that it does not require a frequent testing schedule, therefore testing is scheduled as 

required by the Department. 

The Department has confidence that a material handling baghouse is providing good control of particulate and 

opacity emissions when CFAC employs a baghouse I & M plan . One component of an I & M plan is a 

weekly visual survey to determine what the visible emissions are from the emission unit. The I & M plan also

establishes a routine of scheduled maintenance plus recordkeeping. In summary, the Department has 

determined that the implementation and continued use of a baghouse I & M plan substantially assures 

compliance with the opacity and particulate emission limits. 

OP2655-01 14 Date of Decision: 05/21/03

Effective Date: 06/21/03 
EU054 – EU062 Natural Gas Boiler Emitting Units (III.P) 

EU054 - Change House Boiler #1 - MP01 EU059 - Paste Plant Boiler #1 - MP11

EU055 - Change House Boiler #2 - MP02 EU060 - Paste Plant Boiler #2 - MP12

EU056 - Lab Boiler #1 - MP07 EU061 - Warehouse Boiler #1 - MP16

EU057 - Machine Shop Boiler #1 - MP08 EU062 - Warehouse Boiler #2 - MP17

EU058 - Machine Shop Boiler #2 - MP09

The Department determined that natural gas combustion is sufficient to demonstrate compliance with the 

opacity, particulate matter, and sulfur in fuel limits for these emission units. The age or capacity of these units

is such that NSPS requirements are not applicable. This compliance demonstration does not preclude the 

Department from initiating an enforcement action if testing indicates that an emission limit is exceeded.

EU063 – Truck and Equipment Fugitive Emissions / Haul Road Emissions – MP05 (III.Q) 

CFAC must perform Method 9 tests, as required, to monitor opacity due to truck and equipment activity. CFAC 

must also exercise reasonable precautions such as road maintenance, treatment with water or dust suppressant, 

and reduced truck and equipment speeds to control or mitigate emissions. The Department determined that 

Method 9 testing, plus exercising reasonable precautions, will assure compliance with the opacity limit.

EU064 – Gasoline Storage (Tank) Emitting Unit – MP04 (III.R) 

The capacity of this storage tank is such that the only requirements it is subject to are opacity (ARM 

17.8.304(2)), and use of a submerged fill pipe (or instead of a submerged fill pipe, installation and use of a 

vapor loss control device (ARM 17.8.106)). The Department determined that a demonstration of compliance 

shall be a Method 9 test as required. 

C. 

D.

E.

Test Methods and Procedures 

The operating permit may not require testing for all sources if routine monitoring is used to determine 

compliance, but the Department has the authority to require testing if deemed necessary to determine 

compliance with an emission limit or standard. In addition, the permittee may elect to voluntarily conduct 

compliance testing to confirm its compliance status. 

Recordkeeping Requirements

The permittee is required to keep all records listed in the operating permit as a permanent business record for at

least 5 years following the date of the generation of the record. 

Reporting Requirements

Reporting requirements are included in the permit for each emission unit, and Section V of the operating 

permit, "General Conditions," explains the reporting requirements. However, the permittee is required to

submit semi-annual and annual monitoring reports to the Department and to annually certify compliance with

the applicable requirements contained in the permit. The reports must include a list of all emission limit and 

monitoring deviations, the reason for any deviation, and the corrective action taken as a result of any deviation. 

F. Proposed Permit Comments 

The Department did not receive any comments for proposed permit #OP2655-01. 

OP2655-01 15 Date of Decision: 05/21/03

Effective Date: 06/21/03 
SECTION IV. FUTURE PERMIT CONSIDERATIONS

A.

B.

C.

D.

MACT Standards

CFAC is subject to the requirements of 40 CFR Part 63, Subpart LL, promulgated on October 7, 1997. CFAC

also subject to the National Emission Standards for Hazardous Air Pollutants for Secondary Aluminum

Production, 65 FR 15689, effective March 23, 2000. 

NESHAP Standards

As of the date of issuance of this permit, the only NESHAP standard that this facility is subject to is 40 CFR 

Part 61, Subpart M, "National Emission Standards for Hazardous Air Pollutants for Demolition and 

Renovation;” this standard is applicable to any asbestos project. The Department is unaware of any future

requirement that may be promulgated during the permit term for which this facility must comply. 

NSPS Standards

CFAC was constructed prior to promulgation of 40 CFR Part 60, Subpart S, Standards of Performance for 

Primary Aluminum Reduction Plants; therefore, no NSPS Standards are currently applicable. 

Risk Management Plan 

As of March 12, 2003, this facility does not exceed the minimum threshold quantities for any regulated 

substance listed in 40 CFR 68.115 for any facility process. Consequently, this facility is not required to submit 

a Risk Management Plan. 

Within 3 years after the date on which a regulated substance is first listed under 40 CFR 68.130, or the date on

which a regulated substance is first present in more than a threshold quantity, CFAC must comply with the

requirements of 40 CFR 68.

SECTION V. Other Permit Consideration 

CFAC filed an appeal to the Board of Environmental of Review on June 15, 2001. The appeal was based on

comments on Appendix I of the permit, which contains the Compliance Schedule. The BER made a final 

ruling on November 16, 2001, by issuing a Stipulation and Order that included minor changes to Permit 

OP2655-00. The permit was issued effective on November 16, 2001, with the minor changes included. The 

current Title V Operating Permit #OP2655-01 includes these changes.

OP2655-01 16 Date of Decision: 05/21/03

Effective Date: 06/21/03 
STATE OF MONTANA 

Department of Environmental Quality

Helena, Montana 59620 

AIR QUALITY OPERATING PERMIT NUMBER OP2655-01 

Minor Modification Application Received: August 29, 2002

Additional Submittals: October 1, 2002

Proposed Issue Date: March 12, 2003

End of EPA 45-day Review: April 26, 2003

Date of Decision: May 21, 2003 

Effective Date: June 21, 2003 

Expiration Date: November 16, 2006 

AFS Number: 030-029-0012

In accordance with Sections 75-2-217 and 218, MCA, and Administrative Rules of Montana (ARM), 

ARM Title 17, Chapter 8, Subchapter 12, Operating Permit Program, ARM 17.8.1201, et seq., 

Columbia Falls Aluminum Company, LLC 

2000 Aluminum Drive 

Columbia Falls, MT 59912 

hereinafter referred to as “CFAC,” is authorized to operate a stationary source of air contaminants 

consisting of the emissions units described in this permit. Until this permit expires or is modified or 

revoked, CFAC is allowed to discharge air pollutants in accordance with the conditions of this permit. 

All conditions in this permit are federally and state enforceable unless otherwise specified. Requirements, 

which are only state enforceable are identified in the permit. A copy of this permit must be kept on-site at 

the above named facility. 

Issued by the Department of Environmental Quality

 / / 

 Signature Date 

Permit Issuance and Appeal Processes: In accordance with ARM 17.8.1210(j), the Department of 

Environmental Quality’s (Department) decision regarding issuance of an operating permit is not effective 

until 30 days have elapsed from the date of the decision issued May 21, 2003. The decision may be 

appealed to the Board of Environmental Review by filing a request for a hearing within 30 days after the 

date of decision. If no appeal is filed then the Department will send notification and a final permit cover 

page to be attached to this document stating that the permit is final. In addition, ARM 17.8.1233 allows 

for any person to petition the Environmental Protection Agency (EPA) within 60 days after the expiration 

of EPA’s 45-day review period to object to issuance of this operating permit. If EPA objects to the 

operating permit as a result of a petition prior to the Department’s notification of a final permit, CFAC 

and all affected parties will be informed of the stay of a final permit. If the Department has already

notified CFAC and all affected parties, the Department shall issue a revised permit according to ARM 

17.8.1231. Questions regarding the final issuance date and status of appeals should be directed to the 

Department at (406) 444-3490. 

Permit Number: OP2655-01 i Date of Decision: 05/21/03 

Effective Date: 06/21/03 
`Montana Air Quality Operating Permit 

Department of Environmental Quality

SECTION I. GENERAL INFORMATION.......................................................................................................1

SECTION II. SUMMARY OF EMISSION UNITS.......................................................................................2

A. FACILITY-WIDE................................................................................................................. 4 

B. EU001 – EU007 MATERIAL HANDLING EMITTING UNITS WITH BAGHOUSES............... 6 

C. EU008 – EU014 EU’S WITH BAGHOUSES & GRAIN LOADING RESTRICTIONS ................. 8 

D. EU015 - EU017 PASTE PLANT EMITTING UNITS WITH BAGHOUSES............................... 9 

E. EU018 – PITCH STORAGE TANKS - PP04.......................................................................... 11 

F. EU019 - THERMINOL OIL HEATING SYSTEM - PP05 ....................................................... 11 

G. EU020 - EU023 PRIMARY SCRUBBER SYSTEM ALUMINA TRANSFER EU’S................... 12 

H. EU024 - EU033 PRIMARY GAS COLLECTION SYSTEM EMITTING UNITS ....................... 13 

I. EU034 - EU038 POTLINE ROOF VENT EMITTING UNITS ................................................. 16 

J. EU039 - EU043 CASTING FURNACE EMITTING UNITS .................................................... 18 

K. EU044 - EU048 CASTING PIT EMITTING UNITS ............................................................... 19 

L. EU049 - EU050 ALUMINUM SAW EMITTING UNITS ........................................................ 20 

M. EU051 – SANDBLASTING ACTIVITIES - CR01................................................................. 20 

N. EU052 – LECTROMELT FURNACE EMITTING UNIT - CR03 ............................................ 22 

O. EU053 – ROD MILL/MATERIAL STORAGE EMITTING UNIT - CR04................................ 23 

P. EU054 – EU062 NATURAL GAS BOILER EMITTING UNITS............................................. 23 

Q. EU063 – TRUCK, EQUIPMENT, AND HAUL ROAD EMISSIONS – MP05............................ 24 

R. EU064 – GASOLINE STORAGE (TANK) EMITTING UNIT – MP04 ..................................... 25 

SECTION IV NON-APPLICABLE REQUIREMENTS ............................................................................27

A. FACILITY-WIDE............................................................................................................... 27 

B. EMISSION UNITS ............................................................................................................. 27 

SECTION V – GENERAL PERMIT CONDITIONS ............................................................................................28

A. Compliance Requirements.................................................................................................. 28 

B. Certification Requirements................................................................................................. 28 

C. Permit Shield..................................................................................................................... 29 

D. Monitoring, Recordkeeping, and Reporting Requirements .................................................... 30 

E. Prompt Deviation Reporting ............................................................................................... 31 

F. Emergency Provisions........................................................................................................ 31 

G. Inspection and Entry .......................................................................................................... 32 

H. Fee Payment...................................................................................................................... 32 

I. Minor Permit Modifications................................................................................................ 32 

J. Changes Not Requiring Permit Revision.............................................................................. 33 

K. Significant Permit Modifications......................................................................................... 34 

L. Reopening for Cause .......................................................................................................... 34 

M. Permit Expiration and Renewal........................................................................................... 34 

N. Severability Clause ............................................................................................................ 35 

O. Transfer or Assignment of Ownership ................................................................................. 35 

P. Emissions Trading, Marketable Permits, Economic Incentives.............................................. 35 

Q. No Property Rights Conveyed............................................................................................. 35 

R. Testing Requirements......................................................................................................... 36 

S. Source Testing Protocol...................................................................................................... 36 

T. Malfunctions ..................................................................................................................... 36 

Permit Number: OP2655-01 ii Date of Decision: 05/21/03 

Effective Date: 06/21/03 
U. Circumvention ................................................................................................................... 36 

V. Motor Vehicles.................................................................................................................. 36 

W. Annual Emissions Inventory ............................................................................................... 36 

X. Open Burning .................................................................................................................... 36 

Y. Preconstruction Permits...................................................................................................... 36 

Z. National Emission Standard for Asbestos............................................................................. 37 

AA. Asbestos............................................................................................................................ 37 

BB. Stratospheric Ozone Protection – Servicing of Motor Vehicle Air Conditioners ..................... 37 

CC. Stratospheric Ozone Protection – Recycling and Emission Reductions .................................. 37 

DD. Emergency Episode Plan .................................................................................................... 38 

EE. Definitions......................................................................................................................... 38 

APPENDIX A - RULE CITATION ................................................................................................................... A-1

APPENDIX B - INSIGNIFICANT EMISSION UNITS..................................................................................B-1

APPENDIX C - DEFINITIONS AND ABBREVIATIONS ........................................................................... C-1

APPENDIX D - NOTIFICATION ADDRESSES............................................................................................ D-1

APPENDIX E - AIR QUALITY INSPECTOR INFORMATION.................................................................E-1

APPENDIX F - CFAC MACT IMPLEMENTATION PLAN........................................................................F-1

APPENDIX G - CFAC MACT QUICK REFERENCE GUIDE................................................................... G-1

APPENDIX H - STARTUP, SHUTDOWN AND MALFUNCTION PLAN (SSM)................................... H-1

APPENDIX I - CFAC POM COMPLIANCE SCHEDULE............................................................................I-1

APPENDIX J - POTLINE ROOF VENT OPACITY COMPLIANCE DEMONSTRATION ................. J-1

APPENDIX K - POLLUTION CONTROL DEVICE INSPECTION AND MAINTENANCE PLAN.. K-1

APPENDIX L - 62 FR 52383................................................................................................................................L-1

Permit Number: OP2655-01 iii Date of Decision: 05/21/03 

Effective Date: 06/21/03 
Terms not otherwise defined in this permit or in the Definitions and Abbreviations Appendix of this permit 

have the meaning assigned to them in the referenced regulations. 

SECTION I. GENERAL INFORMATION 

The following general information is provided pursuant to ARM 17.8.1210(1). 

Company Name: Columbia Falls Aluminum Company LLC 

Mailing Address: 2000 Aluminum Drive 

City: Columbia Falls State: MT Zip: 59912 

Plant Location: Columbia Falls; NE1⁄4, SE1⁄4, Section 3, Township 30 North, Range 20 West 

Responsible Official: Mr. Steve Knight Phone: 406-892-8225 

Facility Contact Person(s): Steve Wright Phone: 406-892-8211

 Brian Hohn Phone: 406-892-8212

Primary SIC Code: 3334 

Nature of Business: Primary Aluminum Production 

Description of Process: 

CFAC operates five Vertical Stud Soderberg potlines at the Columbia Falls plant. Each potline has 120 

individual cells that produce aluminum by the Hall-Heroult process. Annual operating 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 

(Al2O3), dissolved in molten cryolite. The reduction process is accomplished in a Vertical Stud Soderberg 

style pot. Soderberg technology describes the type of consumable carbon anode used in the process.

The cells or “pots” are housed in buildings called potrooms; two potrooms are connected electrically in series 

to form one potline. CFAC currently has 10 potrooms that comprise the five potlines. Emissions from each 

pot are divided into two categories: primary emissions and secondary emissions. Primary emissions are 

captured at the pots and routed to the primary air pollution control system, the A398 dry alumina scrubbers. 

Secondary emissions are fugitive emissions from the pots that are vented out the roofline of the potrooms. 

Alumina is fed into a molten bath of cryolite, and heated to about 950°C (1740°F). Through the 

electrochemical process, electricity passes from the anode to the cathode, causing the aluminum to be reduced.

The aluminum metal sinks below the cryolite bath to form a molten aluminum “pad.” The evolved oxygen 

atoms bond with the carbon in the anode of the cell to form carbon monoxide and carbon dioxide. Other 

emissions from the process include both particulate fluoride and gaseous hydrogen fluoride as well as 

hydrocarbon emissions containing polycyclic organic matter. The aluminum metal is siphoned from the pot 

every 48 hours and transported to the Casting Department, where it is cast into ingots of various sizes, shapes 

and alloys. Typically each pot produces approximately 1700 pounds of aluminum per day.

Permit Number: OP2655-01 1 Date of Decision: 05/21/03

Effective Date: 06/21/03
SECTION II. SUMMARY OF EMISSION UNITS 

The emission units regulated by this permit are the following [ARM 17.8.1211]: 

Emission Unit ID Emission Unit 

Description 

Pollution Control Device 

or Practice 

EU001 Ball Mill North - MH01 Baghouse 

EU002 Ball Mill South - MH02 Baghouse 

EU003 Coke Silo - MH04 Baghouse 

EU004 East Alumina Elevator - MH06 Baghouse 

EU005 East Alumina Unloading - MH07 Baghouse 

EU006 East Conveyor Storage - MH08 Baghouse 

EU007 West Alumina Unloading - MH09 Baghouse 

EU008 Anode Dust Control System - MH03 Baghouse 

EU009 Coke Unloading - MH05 Baghouse 

EU010 West Conveyor Storage - MH10 Baghouse 

EU011 Potline Sweeping - AR04 Baghouse 

EU012 Treatment of Aluminum Crucibles (TAC) 

Operations - CO10 

Baghouse 

EU013 Pin Cleaning - West Plant - CR07 Baghouse 

EU014 Pin Cleaning - East Plant - CR07a Baghouse 

EU015 Paste Plant Extruder - PP01 Procedair Dry Coke Scrubber (Baghouse)

EU016 Paste Plant Mixer - PP02 Procedair Dry Coke Scrubber (Baghouse)

EU017 Pinhole Past Drying - PP03 Baghouse 

EU018 Pitch Storage Tank Vents - PP04 Condensation Tower/Vent

EU019 Therminol Oil Heating System - PP05 None 

EU020 East Plant Dry Scrubber Alumina Transfer (North) 

- AR01 

Baghouse 

EU021 East Plant Dry Scrubber Alumina Transfer (South) 

- AR02 

Baghouse 

EU022 West Plant Dry Scrubber Alumina Transfer 

(North) - AR06 

Baghouse 

EU023 West Plant Dry Scrubber Alumina Transfer 

(South) - AR07

Baghouse 

EU024 Primary Gas Collection System - West Plant 

(Potlines 1 & 2) - AR05 

Alcoa A398 Dry Alumina Scrubber #1 

(Reactor #1 & Baghouse) 

EU025 Primary Gas Collection System - West Plant 

(Potlines 1 & 2) - AR05 

Alcoa A398 Dry Alumina Scrubber #2 

(Reactor #2 & Baghouse) 

EU026 Primary Gas Collection System - West Plant 

(Potlines 1 & 2) - AR05 

Alcoa A398 Dry Alumina Scrubber #3 

(Reactor #3 & Baghouse) 

EU027 Primary Gas Collection System - West Plant 

(Potlines 1 & 2) - AR05 

Alcoa A398 Dry Alumina Scrubber #4 

(Reactor #4 & Baghouse) 

EU028 Primary Gas Collection System - East Plant 

(Potlines 3, 4, & 5) - AR05

Alcoa A398 Dry Alumina Scrubber #5 

(Reactor #5 & Baghouse) 

EU029 Primary Gas Collection System - East Plant 

(Potlines 3, 4, & 5) - AR05

Alcoa A398 Dry Alumina Scrubber #6 

(Reactor #6 & Baghouse) 

EU030 Primary Gas Collection System - East Plant 

(Potlines 3, 4, & 5) - AR05

Alcoa A398 Dry Alumina Scrubber #7 

(Reactor #7 & Baghouse) 

EU031 Primary Gas Collection System - East Plant 

(Potlines 3, 4, & 5) - AR05

Alcoa A398 Dry Alumina Scrubber #8 

(Reactor #8 & Baghouse) 

EU032 Primary Gas Collection System - East Plant 

(Potlines 3, 4, & 5) - AR05

Alcoa A398 Dry Alumina Scrubber #9 

(Reactor #9 & Baghouse) 

EU033 Primary Gas Collection System - East Plant 

(Potlines 3, 4, & 5) - AR05

Alcoa A398 Dry Alumina Scrubber #10 

(Reactor #10 & Baghouse) 

EU034 Potline #1 Roof Vent, West Plant - AR03 None 

Permit Number: OP2655-01 2 Date of Decision: 05/21/03

Effective Date: 06/21/03
EU035 Potline #2 Roof Vent, West Plant - AR03 None 

EU036 Potline #3 Roof Vent, East Plant - AR03 None 

EU037 Potline #4 Roof Vent, East Plant - AR03 None 

EU038 Potline #5 Roof Vent, East Plant - AR03 None 

EU039 Casting Furnace #3 - CO01 None 

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 

EU050 T-Ingot Saw – CO09 Target Box and Filter or Cyclone 

EU051 Sandblasting Activities - CR01 None 

EU052 Lectromelt Furnace - CR03 Baghouse 

EU053 Rod Mill / Material Storage - CR04 Baghouse 

EU054 Change House Boiler #1 - MP01 None 

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 

EU064 Gasoline Storage Tank - MP04 None 

Permit Number: OP2655-01 3 Date of Decision: 05/21/03

Effective Date: 06/21/03
Section III Permit Conditions 

The following requirements and conditions are applicable to the facility or to specific emission units located at

the facility (ARM 17.8.1211,1212, and 1213). 

A. FACILITY-WIDE 

Conditions Rule Citation Rule Description Pollutant/Parameter Limit

A.1 ARM 17.8.304(1) Visible Air Contaminants Opacity 40% 

A.2 ARM 17.8.304(2) Visible Air Contaminants Opacity 20% 

A.3 ARM 17.8.308(1) Particulate Matter, Airborne Fugitive Opacity 20% 

A.4 ARM 17.8.308(2) Particulate Matter, Airborne Reasonable Precautions ------- 

A.5 ARM 17.8.308(3) Particulate Matter, Airborne Reasonable Precaution,

Construction 

20% 

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

A.7 ARM 17.8.310 Particulate Matter, Industrial Processes Particulate Matter E = 4.10 * P0.67 Or 

E = 55 * P0.11- 40

A.8 ARM 17.8.322(4) Sulfur Oxide Emissions, Sulfur in Fuel Sulfur in Fuel (liquid or solid 

fuels) 

1 lb/MMBtu Fired 

A.9 ARM 17.8.322(5) Sulfur Oxide Emissions, Sulfur in Fuel Sulfur in Fuel (gaseous) 50 gr/100 CF 

A.10 ARM 17.8.324(3) Hydrocarbon Emissions, Petroleum 

Products 

Gasoline Storage Tanks ------- 

A.11 ARM 17.8.324 Hydrocarbon Emissions, Petroleum 

Products 

65,000-Gallon Capacity ------- 

A.12 ARM 17.8.324 Hydrocarbon Emissions, Petroleum 

Products 

Oil-effluent Water Separator ------- 

A.13 ARM 17.8.1212 Reporting Requirements Compliance Monitoring -------

A.14 ARM 17.8.1207 Reporting Requirements Annual Certification -------

A.15 ARM 17.74.336 Asbestos Asbestos -------

A.16 40 CFR Part 63, 

Subpart LL 

Aluminum MACT Fluoride, 

Polycyclic Organic Matter 

See Appendix G

Conditions

A.1. 

A.2.

A.3. 

A.4.

A.5.

Pursuant to ARM 17.8.304(1), CFAC shall not cause or authorize emissions to be discharged into the

outdoor atmosphere from any source installed on or before November 23, 1968, that exhibit an opacity of

40% or greater averaged over 6 consecutive minutes, unless otherwise specified by rule or in this permit. 

Pursuant to ARM 17.8.304(2), CFAC shall not cause or authorize emissions to be discharged into the 

outdoor atmosphere from any source installed after November 23, 1968, that exhibit an opacity of 20% 

or greater averaged over 6 consecutive minutes, unless otherwise specified by rule or in this permit. 

Pursuant to ARM 17.8.308(1), CFAC shall not cause or authorize the production, handling, transportation, 

or storage of any material unless reasonable precautions to control emissions of particulate matter are taken. 

Such emissions of airborne particulate matter from any stationary source shall not exhibit an opacity of 20% 

or greater averaged over 6 consecutive minutes, unless otherwise specified by rule or in this permit. 

Pursuant to ARM 17.8.308(2), CFAC shall not cause or authorize the use of any street, road or parking 

lot without taking reasonable precautions to control emissions of airborne particulate matter, unless 

otherwise specified by rule or in this permit. 

Pursuant to ARM 17.8.308(3), CFAC shall not operate a construction site or demolition project unless 

reasonable precautions are taken to control emissions of airborne particulate matter. Such emissions of 

airborne particulate matter from any stationary source shall not exhibit an opacity of 20% or greater

averaged over 6 consecutive minutes, unless otherwise specified by rule or in this permit. 

Permit Number: OP2655-01 4 Date of Decision: 05/21/03

Effective Date: 06/21/03
A.6.

A.7.

A.8.

A.9.

A.10.

A.11.

A.12.

Pursuant to ARM 17.8.309, unless otherwise specified by rule or in this permit, CFAC shall not cause 

or authorize particulate matter caused by the combustion of fuel to be discharged from any stack or 

chimney into the outdoor atmosphere in excess of the maximum allowable emissions of particulate 

matter for existing fuel burning equipment and new fuel burning equipment, calculated using the

following equations: 

For existing fuel burning equipment (installed before November 23, 1968): E = 0.882 * H-0.1664

For new fuel burning equipment (installed on or after November 23, 1968): E = 1.026 * H-0.233

Where H is the heat input capacity in million BTU (MMBtu) per hour and E is the maximum allowable 

particulate emission rate in pounds per MMBtu. 

Pursuant to ARM 17.8.310, unless otherwise specified by rule or in this permit, CFAC shall not cause 

or authorize particulate matter to be discharged from any operation, process, or activity into the 

outdoor atmosphere in excess of the maximum hourly allowable emissions of particulate matter, 

calculated using the following equations: 

For process weight rates up to 30 tons per hour: E = 4.10 * P0.67

For process weight rates in excess of 30 tons per hour: E = 55.0 * P0.11

 – 40

Where E is the rate of emissions in pounds per hour and P is the process weight rate in tons per hour. 

ARM 17.8.310(3)(a) states that this rule does not apply to particulate matter emitted from the reduction 

cells of a primary aluminum reduction plant; therefore, ARM 17.8.310 does not apply to particulate 

emissions from the roof monitors of the potline buildings, nor does it apply to particulate emissions 

from the primary control system (Alcoa A398 Dry Alumina Scrubbers). However, ARM 17.8.310 is 

applicable to all other (non combustion) processes at CFAC. 

Pursuant to ARM 17.8.322(4), CFAC shall not burn liquid or solid fuels containing sulfur in excess of 

1 pound per million BTU fired, unless otherwise specified by rule or in this permit. 

Pursuant to ARM 17.8.322(5), CFAC shall not burn any gaseous fuel containing sulfur compounds in 

excess of 50 grains per 100 cubic feet of gaseous fuel, calculated as hydrogen sulfide at standard

conditions, unless otherwise specified by rule or in this permit. 

Pursuant to ARM 17.8.324(3), CFAC shall not load or permit the loading of gasoline into any

stationary tank with a capacity of 250 gallons or more from any tank truck or trailer, except through a 

permanent submerged fill pipe, unless such tank is equipped with a vapor loss control device or is a 

pressure tank as described in ARM 17.8.324(1), unless otherwise specified by rule or in this permit. 

Pursuant to ARM 17.8.324, unless otherwise specified by rule or in this permit, CFAC shall not place, 

store or hold in any stationary tank, reservoir or other container with more than a 65,000-gallon 

capacity any crude oil, gasoline or petroleum distillate having a vapor pressure of 2.5 pounds per 

square inch absolute or greater under actual storage conditions, unless such tank, reservoir or other 

container is a pressure tank maintaining working pressure sufficient at all times to prevent hydrocarbon 

vapor or gas loss to the atmosphere, or is designed and equipped with a vapor loss control device, 

properly installed, in good working order and in operation. 

Pursuant to ARM 17.8.324, unless otherwise specified by rule or in this permit, CFAC shall not use 

any compartment of any single or multiple-compartment oil-effluent water separator which

compartment receives effluent water containing 200 gallons a day or more of any petroleum product 

from any equipment processing, refining, treating, storing or handling kerosene or other petroleum

product of equal or greater volatility than kerosene, unless such compartment is equipped with a vapor 

loss control device, constructed so as to prevent emission of hydrocarbon vapors to the atmosphere, 

properly installed, in good working order and in operation. 

Permit Number: OP2655-01 5 Date of Decision: 05/21/03

Effective Date: 06/21/03
On or before January 31 and July 31 of each year, CFAC shall submit to the Department the 

compliance monitoring reports required by Section V.D. These reports must contain all 

information required by Section V.D, as well as the information required by each individual 

emissions unit. For the reports due by January 31 of each year, CFAC may submit a single report, 

provided that it contains all the information required by Section V.B & V.D. Per ARM 17.8.1207, 

A.13.

A.14.

A.15.

A.16.

B. 

any application form, report, or compliance certification submitted pursuant to

ARM Title 17, Chapter 8, Subchapter 12 (including semiannual monitoring 

reports), shall contain certification by a responsible official of truth, accuracy 

and completeness. This certification and any other certification required under 

ARM Title 17, Chapter 8, Subchapter 12, shall state that, “based on information 

and belief formed after reasonable inquiry, the statements and information in 

the document are true, accurate and complete.” 

By January 31 of each year, CFAC shall submit to the Department the compliance certification 

report required by Section V.B. The annual certification report required by Section V.B must 

include a statement of compliance based on the information available, which identifies any

observed, documented or otherwise known instance of noncompliance for each applicable 

requirement. Per ARM 17.8.1207, 

any application form, report, or compliance certification submitted pursuant to

ARM Title 17, Chapter 8, Subchapter 12 (including annual certifications), shall 

contain certification by a responsible official of truth, accuracy and 

completeness. This certification and any other certification required under ARM 

Title 17, Chapter 8, Subchapter 12, shall state that, “based on information and 

belief formed after reasonable inquiry, the statements and information in the 

document are true, accurate and complete.” 

Pursuant to ARM 17.74.336, CFAC shall comply with all the limitations and requirements of their 

Asbestos Abatement Annual Permit #MTF0007. 

CFAC shall satisfy all of the applicable requirements, including emission limitations, testing, 

monitoring, recordkeeping, and reporting, of 40 CFR Part 63, Subpart LL, National Emission 

Standards for Hazardous Air Pollutants for Primary Aluminum Reduction Plants (Aluminum MACT). 

CFAC shall also satisfy the requirements of the Compliance Schedule contained in Appendix I of this 

permit. 

EU001 – EU007 MATERIAL HANDLING EMITTING UNITS WITH BAGHOUSES 

EU001 - Ball Mill North - MH01 

EU002 - Ball Mill South - MH02 

EU003 - Coke Silo - MH04 

Condition(s) Pollutant/ Compliance Demonstration 

Parameter 

Permit Limit 

Method Frequency

Reporting 

Requirements

Method 9 As Required by the 

Department 

B.1, B.4, B.5, Semi-annual 

B.7, B.9 

Opacity 20%

Baghouse I & M

(Appendix K) 

Ongoing Semi-annual

B.3, B.6, B.8,

B.9 

Particulate 

Matter 

E = 55*P0.11 – 40 Method 5 As Required by the 

Department 

Semi-annual 

Permit Number: OP2655-01 6 Date of Decision: 05/21/03

Effective Date: 06/21/03
EU004 - East Alumina Elevator - MH06

EU005 - East Alumina Unloading - MH07 

EU006 - East Conveyor Storage - MH08

EU007 - West Alumina Unloading - MH09 

Condition(s) Pollutant/ Compliance Demonstration 

Parameter 

Permit Limit 

Method Frequency

Reporting 

Requirements

Method 9 As Required by the 

Deptartment 

B.2, B.4, B.5, Semi-annual 

B.7, B.9 

Opacity 40%

Baghouse I & M

(Appendix K) 

Ongoing Semi-annual

B.3, B.6, B.8,

B.9 

Particulate Matter E = 55*P0.11 – 40 Method 5 As Required by the 

Department 

Semi-annual 

Conditions

B.1.

B.2.

B.3.

B.4.

B.5.

B.6.

B.7.

B.8.

B.9.

CFAC shall not cause or authorize emissions to be discharged to the atmosphere from the Ball 

Mill North-MH01, Ball Mill South-MH02, and Coke Silo-MH04, that exhibit an opacity of 

20% or greater averaged over 6 consecutive minutes (ARM 17.8.304(2)). 

CFAC shall not cause or authorize emissions to be discharged to the atmosphere from the East

Alumina Elevator-MH06, East Alumina Unloading-MH07, East Conveyor Storage-MH08, and 

West Alumina Unloading-MH09, that exhibit an opacity of 40% or greater averaged over 6 

consecutive minutes (ARM 17.8.304(1)). 

The particulate emissions from process weight shall not exceed the value calculated by E = 

55.0*P0.11

-40, where E is the rate of emissions in pounds per hour and P is the process weight

rate in tons per hour (ARM 17.8.310). 

Compliance Demonstration 

As required by the Department, CFAC shall perform a Method 9 test in accordance with the Montana 

Source Test Protocol and Procedures Manual (ARM 17.8.106). Each observation period shall be a 

minimum of 6 minutes, unless any one reading is greater than the relevant opacity limit (20% or 

40%); then the observation period shall be a minimum of 20 minutes or until a violation of the 

standard has been documented, whichever is a shorter period of time (ARM 17.8.1213). 

CFAC shall operate and maintain the baghouse in accordance with the Pollution control device

Inspection & Maintenance Plan (Appendix K) (ARM 17.8.1213). 

 

As required by the Department, CFAC shall perform a Method 5 test in accordance with the

Montana Source Test Protocol and Procedures Manual (ARM 17.8.1213). 

Recordkeeping 

CFAC shall maintain on-site records of all inspection and maintenance activities performed 

on the baghouses in accordance with the Pollution Control Device Inspection & Maintenance 

Plan (Appendix K) and submit records to the Department upon request (ARM 17.8.1212). 

Method 5 and Method 9 test reports must be maintained on site and must be submitted to the

Department, upon request, in accordance with the Montana Source Protocol and Procedures 

Manual (ARM 17.8.106). 

Reporting

The annual compliance certification report required by Section V.B must contain a 

certification statement for the above applicable requirements. The semiannual compliance 

monitoring reports shall include a summary of (ARM 17.8.1212): 

Permit Number: OP2655-01 7 Date of Decision: 05/21/03

Effective Date: 06/21/03
a. The results of any test conducted during the reporting period; and 

b. Any corrective actions taken as a result of the inspections and maintenance as 

required by the Pollution Control Device Inspection & Maintenance Plan (Appendix 

K). 

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

EU008 - Anode Dust Control System - MH03 EU012 - Treatment of Aluminum Crucibles - CO10 

EU009 - Coke Unloading - MH05 EU013 - Pin Cleaning - West Plant - CR07 

EU010 - West Conveyor Storage - MH10 EU014 - Pin Cleaning - East Plant - CR07a

EU011 - Potline Sweeping AR04 

Condition(s) Pollutant/ Compliance Demonstration 

Parameter 

Permit Limit 

Method Frequency

Reporting 

Requirements

Method 9 As Required by the 

Department 

C.1, C.4, C.5, Semi-annual 

C.7, C.9 

Opacity 20%

Baghouse I & M

(Appendix K) 

Ongoing Semi-annual

C.2, C.6, C.8, C.9 Particulate Matter E = 55*P0.11 – 40 Method 5 As Required by the 

Department 

Semi-annual 

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

Department 

Semi-annual 

Conditions 

C.1. CFAC shall not cause or authorize emissions to be discharged to the atmosphere from the 

Anode Dust Control System-MH03, Coke Unloading-MH05, West Conveyor Storage-MH10,

Potline Sweeping-AR04, Treatment of Aluminum Crucibles-CO10, Pin Cleaning West PlantCR07, and Pin Cleaning East Plant-CR07a, that exhibit an opacity of 20% or greater averaged

over 6 consecutive minutes (ARM 17.8.304(2)). As a result of venting indoors, EU013 and 

EU014 are not currently subject to this (C.1) requirement. 

C.2.

C.3.

C.4.

C.5.

C.6.

C.7. 

The particulate emissions from process weight shall not exceed the value calculated by E = 

55.0*P0.11

- 40, where E is the rate of emissions in pounds per hour and P is the process weight

rate in tons per hour (ARM 17.8.310). 

Particulate emissions shall not exceed the 0.02 gr/dscf (ARM 17.8.715). 

Compliance Demonstration

As required by the Department, CFAC shall perform a Method 9 test in accordance with the Montana 

Source Test Protocol and Procedures Manual (ARM 17.8.106). Each observation period shall be a 

minimum of 6 minutes, unless any one reading is greater than 20%; then the observation period shall 

be a minimum of 20 minutes or until a violation of the standard has been documented, whichever is a 

shorter period of time (ARM 17.8.1213). EU013 and EU014 are not currently subject to C.1 and C.4. 

CFAC shall operate and maintain the baghouse in accordance with the Pollution Control Device

Inspection & Maintenance Plan (Appendix K) of this permit (ARM 17.8.1213). 

As required by the Department, CFAC shall perform a Method 5 test in accordance with the

Montana Source Test Protocol and Procedures Manual (ARM 17.8.1213). 

Recordkeeping

Permit Number: OP2655-01 8 Date of Decision: 05/21/03

Effective Date: 06/21/03

CFAC shall maintain on-site records of all inspection and maintenance activities performed on the

baghouses in accordance with Appendix K and submit the records to the Department upon

request. 
C.8.

C.9.

D. 

Method 5 and Method 9 test reports must be maintained on site and must be submitted to the

Department, upon request, in accordance with the Montana Source Protocol and Procedures 

Manual. 

Reporting

The annual compliance certification report required by Section V.B must contain a 

certification statement for the above applicable requirements. The semiannual compliance 

monitoring reports shall include a summary of (ARM 17.8.1212): 

a. The results of any test conducted during the reporting period; and 

b. Any corrective actions taken as a result of the inspections and maintenance as 

required by the Pollution Control Device Inspection & Maintenance Plan (Appendix 

K). 

EU015 - EU017 PASTE PLANT EMITTING UNITS WITH BAGHOUSES 

EU015 - Paste Plant Extruder - PP01 EU016 - Paste Plant Mixer - PP02 

Condition(s) Pollutant/ Compliance Demonstration 

Parameter 

Permit Limit 

Method Frequency

Reporting 

Requirements

Method 9 As Required by the 

Department 

D.2, D.5, D.6, Semiannual 

D.11, D.13, 

D.15 

Opacity 40%

Visual Survey Daily Semiannual 

D.3, D.8, D.10, 

D.12, D.13, 

D.15 

Particulate 

Matter 

E = 55*P0.11 – 40 Method 5 As Required by the 

Department. 

Semiannual 

Operation of Dry Coke 

Scrubber: CFAC MACT 

Implementation Plan 

(Appendix F) 

Ongoing Annual 

Certification 

D.4, D.9, D.10, 

D.13, D.15 

Polycyclic

Organic Matter 

(POM) 

None 

Visual Survey Daily Semiannual 

EU017- Pinhole Paste Drying - PP03 

Condition(s) Pollutant/ Compliance Demonstration 

Parameter 

Permit Limit 

Method Frequency

Reporting 

Requirements

Method 9 As Required by the 

Department 

D.1, D.5, D.7, Semi-annual 

D.11, D.14, D.15

Opacity 20%

Baghouse I & M

(Appendix K) 

Ongoing Semi-annual

D.3, D.7, D.8, 

D.12, D.14, D.15

Particulate 

Matter 

E = 55*P0.11 – 40 Method 5 As Required by the 

Department. 

Semi-annual 

Conditions

D.1.

D.2.

CFAC shall not cause or authorize emissions to be discharged to the atmosphere from Pinhole Paste 

Drying-PP03 that exhibit an opacity of 20% or greater averaged over 6 consecutive minutes (ARM

17.8.304(2)). 

CFAC shall not cause or authorize emissions to be discharged to the atmosphere from the Paste Plant 

Extruder-PP01 and the Paste Plant Mixer-PP02, that exhibit an opacity of 40% or greater averaged

over 6 consecutive minutes (ARM 17.8.304(1)). 

Permit Number: OP2655-01 9 Date of Decision: 05/21/03

Effective Date: 06/21/03
The particulate emissions from process weight shall not exceed the value calculated by E = 55.0*P0.11

-

40, where E is the rate of emissions in pounds per hour and P is the process weight rate in tons per hour 

(ARM 17.8.310). 

D.3.

D.4.

D.5.

D.6.

D.7.

D.8.

D.9.

D.10.

D.11.

D.12.

D.13.

D.14.

Polycyclic Organic Matter (POM) emissions from the paste plant shall be controlled by the operation 

of a Dry Coke Scrubber (ARM 17.8.302(i), ARM 17.8.342, ARM 17.8.710, and 40 CFR Part 63, 

Subpart LL). 

Compliance Demonstration

As required by the Department, CFAC shall perform a Method 9 test in accordance with the Montana 

Source Test Protocol and Procedures Manual. Each observation period shall be a minimum of 6 

minutes, unless any one reading is greater than the relevant opacity limit (20% or 40%); then the 

observation period shall be a minimum of 20 minutes or until a violation of the standard has been

documented, whichever is a shorter period of time (ARM 17.8.1213).

Daily, CFAC must visually inspect/survey the exhaust stack of the Paste Plant Dry Coke Scrubber for 

evidence of any visible emissions indicating abnormal operation. The person conducting the survey

does not have to be EPA Method 9 certified. However, the individual should be familiar with the 

procedures of EPA Method 9, including the proper location from which to observe the visible

emissions. If excessive emissions are identified, CFAC shall initiate corrective action procedures

identified in the Startup, Shutdown, and Malfunction Plan within 1 hour (ARM 17.8.1213). 

CFAC shall operate and maintain the baghouse (EU017) in accordance with the Pollution Control 

Device Inspection & Maintenance Plan (Appendix K) of this permit (ARM 17.8.1213). 

As required by the Department, CFAC shall perform a Method 5 test in accordance with the Montana 

Source Test Protocol and Procedures Manual (ARM 17.8.1213). 

The Dry Coke Scrubber shall be operated when either EU015 or EU016 are operating, in accordance 

with the CFAC’s MACT Implementaton Plan (Appendix F) of this permit, to control POM emissions

from the Paste Plant. The parameter monitoring system must be operated, calibrated, and maintained 

for the Paste Plant Dry Coke Scrubber (40 CFR 63.848(f)). 

Daily, CFAC must inspect the Paste Plant Dry Coke Scrubber to ensure that the control device is 

operating properly. If a monitoring device measures an operating parameter outside of the limits 

established in CFAC's MACT Implementation Plan (Appendix F), then CFAC shall initiate corrective 

action procedures identified in the Startup, Shutdown, and Malfunction Plan (Appendix H of this

permit) within 1 hour (ARM 17.8.1213). 

Recordkeeping

Method 9 tests shall be conducted in accordance with the Montana Source Test Protocol and 

Procedures Manual. Method 9 reports must be maintained on site and must be submitted to the 

Department upon request (ARM 17.8.106). 

Method 5 test reports must be maintained on site and must be submitted to the Department in

accordance with the Montana Source Test Protocol and Procedures Manual (ARM 17.8.106). 

CFAC shall maintain on-site records of the daily visual emissions observed, the operating parameters 

monitored, any excursions (exceedances) outside of the specified normal operating parameters, and any

maintenance or repair initiated as a result of non-typical operating parameters (ARM 17.8.1212).

CFAC shall maintain on-site records of all inspection and maintenance activities performed on the 

baghouses in accordance with the Pollution control Device Inspection & Maintenance Plan (Appendix 

K) and submit such records to the Department upon request (ARM 17.8.1212). 

Permit Number: OP2655-01 10 Date of Decision: 05/21/03

Effective Date: 06/21/03
Reporting

D.15.

a. 

b.

c.

d.

E.

The annual compliance certification report required by Section V.B must contain a certification 

statement for the above applicable requirements. The semiannual compliance monitoring reports shall 

include a summary of (ARM 17.8.1212): 

The results of any test conducted during the last reporting period;

For EU015 & EU016 only, the number of operating parameter exceedances, including visible 

emissions, occurring during the semiannual reporting period (one exceedance per 24-hr period – 

40 CFR 63.848(i)); 

For EU015 & EU016 only, any corrective actions taken as a result of the daily visual surveys of 

visible emissions and operating parameters (Startup, Shutdown and Malfunction Plan (Appendix

H)); and 

For EU017 only, a summary of any corrective actions taken as a result of the inspections and

maintenance as required by the Pollution Control Device Inspection & Maintenance Plan 

(Appendix K). 

EU018 – PITCH STORAGE TANKS - PP04 

Condition(s) Pollutant/ Compliance Demonstration 

Parameter 

Permit Limit 

Method Frequency

Reporting 

Requirements

E.1, E.2, E.3, E.4 Opacity 20% Method 9 As Required by the Dept. Semiannual 

Conditions

E.1.

E.2.

E.3.

E.4.

F. 

CFAC shall not cause or authorize emissions to be discharged to the atmosphere from the Pitch 

Storage Tanks-PP04 that exhibit an opacity of 20% or greater averaged over 6 consecutive minutes 

(ARM 17.8.304(2)). 

Compliance Demonstration

As required by the Department, CFAC shall perform a Method 9 test in accordance with the Montana 

Source Test Protocol and Procedures Manual (ARM 17.8.1213). Each observation period shall be a 

minimum of 6 minutes, unless any one reading is 20% or greater, at which point the observation

period shall be a minimum of 20 minutes or until a violation of the standard has been documented, 

whichever is the shorter period of time. 

Recordkeeping

Method 9 tests shall be conducted in accordance with the Montana source Test Protocol and 

Procedures Manual. Method 9 reports must be maintained on site and must be submitted to the 

Department upon request (ARM 17.8.106). 

Reporting

The annual compliance certification report required by Section V.B must contain a certification 

statement for the above applicable requirement(s). The semiannual reporting shall provide a summary

of the results of any source testing that was performed (ARM 17.8.1212). 

EU019 - THERMINOL OIL HEATING SYSTEM - PP05 

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration 

Method Frequency

Reporting 

Requirements

F.1, F.2, F.3, F.4 Opacity 40% Method 9 As Required by the 

Department 

Semiannual 

Permit Number: OP2655-01 11 Date of Decision: 05/21/03

Effective Date: 06/21/03
Conditions

F.1.

F.2.

F.3.

F.4.

G. 

CFAC shall not cause or authorize emissions to be discharged to the atmosphere from the Therminol

Oil Heating System-PP05 that exhibit an opacity of 40% or greater averaged over 6 consecutive 

minutes (ARM 17.8.304(1)). 

Compliance Demonstration

As required by the Department, CFAC shall perform a Method 9 test in accordance with the Montana 

Source Test Protocol and Procedures Manual. Each observation period shall be a minimum of 6 

minutes, unless any one reading is 40% or greater, at which point the observation period shall be a 

minimum of 20 minutes or until a violation of the standard has been documented, whichever is the 

shorter period of time (ARM 17.8.1213). 

Recordkeeping

Method 9 tests shall be conducted in accordance with the Montana Source Test Protocol and 

Procedures Manual. Method 9 reports must be maintained on site and must be submitted to the 

Department upon request (ARM 17.8.106). 

Reporting

The annual compliance certification report required by Section V.B must contain a certification 

statement for the above applicable requirements. The semiannual reporting shall provide a summary

of any source testing that was performed (ARM 17.8.1212). 

EU020 - EU023 PRIMARY SCRUBBER SYSTEM ALUMINA TRANSFER EU’S 

EU020 - East Plant Dry Scrubber Alumina 

Transfer (North) - AR01 

EU022 - West Plant Dry Scrubber Alumina 

Transfer (North) - AR06 

EU021 - East Plant Dry Scrubber Alumina 

Transfer (South) - AR02 

EU023 - West Plant Dry Scrubber Alumina 

Transfer (South) - AR07 

Conditions Pollutant/ Compliance Demonstration 

Parameter 

Permit Limit 

Method Frequency

Reporting 

Requirements

Method 9 As Required by the 

Department 

G.1, G.3, G.4, G.6, Semiannual 

G.8 

Opacity 20%

Baghouse I & M

(Appendix K) 

Ongoing Semiannual

G.2, G.5, G.7, G.8 Particulate Matter E = 55*P0.11 – 40 Method 5 As Required by the 

Department 

Semiannual 

Conditions 

G.1.

G.2.

G.3.

CFAC shall not cause or authorize emissions to be discharged to the atmosphere from the East Plant 

Dry Scrubber Alumina Transfer (North)-AR01, the East Plant Dry Scrubber Alumina Transfer 

(South)-AR02, the West Plant Dry Scrubber Alumina Transfer (North)-AR06, and the West Plant Dry

Scrubber Alumina Transfer (South)-AR07, that exhibit an opacity of 20% or greater averaged over 6 

consecutive minutes (ARM 17.8.304(2)). 

The particulate emissions from process weight shall not exceed the value calculated by E = 55.0*P0.11-

40, where E is the rate of emissions in pounds per hour and P is the process weight rate in tons per 

hour (ARM 17.8.310). 

Compliance Demonstration

CFAC shall operate and maintain the baghouse in accordance with the Pollution Control Device

Inspection & Maintenance Plan (Appendix K) (Arm 17.8.1213). 

Permit Number: OP2655-01 12 Date of Decision: 05/21/03

Effective Date: 06/21/03
G.4.

G.5.

G.6.

G.7.

G.8. 

b.

H. 

As required by the Department, CFAC shall perform a Method 9 test in accordance with the Montana 

Source Test Protocol and Procedures Manual. Each observation period shall be a minimum of 6 

minutes, unless any one reading is greater than 20%; then the observation period shall be a minimum

of 20 minutes or until a violation of the standard has been documented, whichever is a shorter period

of time (ARM 17.8.1213). 

As required by the Department, CFAC shall perform a Method 5 test in accordance with the Montana 

Source Test Protocol and Procedures Manual (ARM 17.8.1213). 

Recordkeeping

CFAC shall maintain on-site records of all inspection and maintenance activities performed on the 

baghouses in accordance with the Pollution Control Device Inspection & Maintenance Plan 

(Appendix K) and submit the records to the Department upon request (ARM 17.8.1212). 

Method 5 and Method 9 test reports shall be maintained on site and shall be submitted to the

Department in accordance with the Montana Source Protocol and Procedures Manual (ARM 

17.8.106). 

Reporting

The annual compliance certification report required by Section V.B must contain a certification statement 

for the above applicable requirements. The semiannual compliance monitoring reports shall include 

(ARM 17.8.1212): 

a. The results of any test conducted during the last reporting period; and

Any corrective actions taken as a result of the inspections and maintenance as required by the 

Pollution Control Device Inspection & Maintenance Plan (Appendix K). 

EU024 - EU033 PRIMARY GAS COLLECTION SYSTEM EMITTING UNITS 

EU024 - Primary Gas Collection System - West 

Plant - Scrubber #1 - AR05 

EU029 - Primary Gas Collection System - East 

Plant - Scrubber #6 - AR05 

EU025 - Primary Gas Collection System - West 

Plant - Scrubber #2- AR05 

EU030 - Primary Gas Collection System - East 

Plant - Scrubber #7 - AR05 

EU026 - Primary Gas Collection System - West 

Plant - Scrubber #3 - AR05 

EU031 - Primary Gas Collection System - East 

Plant - Scrubber #8 - AR05 

EU027 - Primary Gas Collection System - West 

Plant - Scrubber #4 - AR05 

EU032 - Primary Gas Collection System - East 

Plant - Scrubber #9 - AR05 

EU028 - Primary Gas Collection System - East 

Plant - Scrubber #5 - AR05 

EU033 - Primary Gas Collection System - East 

Plant - Scrubber #10 - AR05 

Condition(s) Pollutant/ Compliance Demonstration 

Parameter 

Permit Limit 

Method Frequency

Reporting 

Requirements

Method 9 As Required by the

Department 

H.1, H.4, H.5, 

H.9, H.12, H.13

Opacity 20%

Visual Survey Daily

Semi-annual 

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

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

Permit Number: OP2655-01 13 Date of Decision: 05/21/03

Effective Date: 06/21/03
Conditions

H.1.

H.2.

H.3.

H.4.

H.5.

H.6. 

H.7. 

CFAC shall not cause or authorize emissions to be discharged to the atmosphere from West Plant 

Primary Gas Collection System, Scrubbers 1 through 4 (AR05), and the East Plant Primary Gas 

Collection System, Scrubbers 5 through 10 (AR05), that exhibit an opacity of 20% or greater averaged

over 6 consecutive minutes (ARM 17.8.304(2)). 

CFAC shall not cause or authorize Total Fluoride (TF) emissions that exceed 1.3 kg of TF per Mg of 

aluminum produced (2.6 lb TF per ton of aluminum produced) from any single potline; or if CFAC is 

averaging the TF emissions from two or more potlines, the emission limit for the averaging scheme is 

prescribed in Appendix G, Table C, of this permit (ARM 17.8.331 and ARM 17.8.342). 

CFAC shall not cause or authorize Polycyclic Organic Matter (POM) emissions that exceed 1.8 kg of 

POM per Mg of aluminum produced (3.6 lb POM per ton of aluminum produced) from any single

potline; or if CFAC is averaging the POM emissions from two or more potlines, the emission limit for 

the averaging scheme is prescribed in Appendix G, Table C, of this permit (ARM 17.8.331 and ARM 

17.8.342). 

Compliance Demonstration

As required by the Department, CFAC shall perform a Method 9 test in accordance with the Montana 

Source Test Protocol and Procedures Manual. Each observation period shall be a minimum of 6 

minutes, unless any one reading is greater than 20%; then the observation period shall be a minimum

of 20 minutes or until a violation of the standard has been documented, whichever is a shorter period

of time (ARM 17.8.1213). 

Daily, CFAC must visually inspect/survey the potline roof monitors for evidence of any visible 

emissions indicating abnormal operation using the procedures identified in Appendix J. The person

conducting the survey does not have to be EPA Method 9 certified. However, non-certified 

individuals must be familiar with the procedures of EPA Method 9, including the proper location to

observe the visible emissions. Upon identification of excessive emissions, CFAC shall initiate

corrective actions to mitigate the visible emissions (ARM 17.8.1213).

CFAC shall annually perform at least one emission measurement test (three runs) for Total Fluoride (TF) 

on each Primary Control System (West Plant and East Plant). That is, annually, CFAC will perform one 

emission measurement test run for TF on three of the four dry alumina scrubbers that comprise the 

Primary Control System of the West Plant; and annually CFAC will perform one emission measurement 

test run for TF on three of the six dry alumina scrubbers that comprise the Primary Control System of the 

East Plant. Also, CFAC will develop a testing schedule such that all dry aluminum scrubbers shall be 

tested for TF at least once (one test run) every 2 years. CFAC shall maintain a 12-month rolling average 

of TF emissions from the Primary Control Systems using the testing results of this requirement. All 

valid test runs must be used. TF Emissions determined by this requirement are combined with 

(measured) TF secondary emissions, and divided by the total aluminum production, to demonstrate 

compliance with TF emission limits (40 CFR Part 63, Subpart LL and ARM 17.8.1213). 

CFAC shall annually perform at least one emission measurement test (three runs) for Polycyclic Organic 

Matter (POM) on each Primary Control System (West Plant and East Plant). That is, annually, CFAC will 

perform one emission measurement test run for POM on three of the four dry alumina scrubbers that 

comprise the Primary Control System of the West Plant; and annually, CFAC will perform one emission 

measurement test run for POM on three of the six dry alumina scrubbers that comprise the Primary Control 

System of the East Plant. Also, CFAC will develop a testing schedule such that all dry aluminum

scrubbers shall be tested for POM at least once (one test run) every 2 years. CFAC shall maintain a 12-

month rolling average of POM emissions from the Primary Control Systems using the testing results of this 

requirement. All valid test runs must be used. POM Emissions determined by this requirement are 

combined with measured POM secondary emissions, and divided by the total aluminum production, to 

demonstrate compliance with POM emission limits (as prescribed in 40 CFR Part 63, Subpart LL and 

ARM 17.8.1213). 

Permit Number: OP2655-01 14 Date of Decision: 05/21/03

Effective Date: 06/21/03
H.8. 

H.9.

H.10.

H.11.

H.12.

H.13.

a.

b.

c.

d.

e.

f. 

g.

h. 

Daily, CFAC must inspect the dry alumina scrubbers of the Primary Control Systems to ensure that the 

control devices are operating properly. If a monitoring device measures an operating parameter outside 

of the limits established in CFAC's Implementation Plan (Appendix F), then CFAC shall initiate 

corrective action procedures as identified in the Startup, Shutdown, and Malfunction Plan within 1 hour. 

If an operating parameter is exceeded six times in any (semiannual) reporting period, then any

subsequent exceedance in that reporting period is a violation. For the purpose of determining the 

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

(ARM 17.8.1213). 

Recordkeeping

Method 9 tests shall be conducted in accordance with the Montana Source Test Protocol and 

Procedures Manual. Method 9 test reports shall be maintained on site and must be submitted to the 

Department upon request (ARM 17.8.106). 

CFAC shall maintain a record of the results from all valid TF emission measurement runs performed 

on the dry alumina scrubbers of the West and East Primary Control Systems. CFAC must calculate 

the rolling monthly average of TF emissions exhausted from the dry alumina scrubbers. The TF 

emissions from the Primary Control Systems will be calculated based upon the testing required in

III.H.6 (ARM 17.8.1212). 

CFAC shall maintain a record of the results from all valid POM emission measurement runs 

performed on the dry alumina scrubbers of the West and East Primary Control Systems. CFAC must 

calculate the rolling monthly average of POM emissions exhausted from the dry alumina scrubbers. 

The POM emissions from the Primary Control Systems will be calculated based upon the testing 

required in III.H.7 (ARM 17.8.1212). 

CFAC shall maintain on-site records of the daily visible emissions observed, the operating parameters 

monitored, any excursions (exceedances) outside of the specified normal operating parameters, and 

any maintenance or repair initiated as a result of non-typical operating parameters (ARM 17.8.1212). 

Reporting

The annual compliance certification report required by Section V.B shall contain a certification

statement for the above applicable requirements. The semiannual reporting shall provide the number 

of operating parameter exceedances, including visible emissions, occurring during the (semiannual) 

reporting period. The quarterly reporting shall provide (aRM 17.8.1212):

The results of all valid source testing that was performed during the quarter; 

The calculated TF and POM emissions from the Primary Control Systems (TF-Monthly and 

POM-Quarterly); 

The combined TF emissions from the Primary Control System and the secondary emissions from

the potline roof monitors; 

The combined POM emissions from the Primary Control System and the secondary emissions 

from the potline roof monitors; 

The tons of aluminum produced (TAP) for each potline per month and quarter; 

The lb of TF emitted per TAP for each potline, and each emission averaging group, per month; 

The lb of POM emitted per TAP for each potline, and each emission averaging group, per quarter; 

A statement of compliance (or noncompliance) for each condition specified in III.H.1, III.H.2, and 

III.H.3, for each period; and 

Permit Number: OP2655-01 15 Date of Decision: 05/21/03

Effective Date: 06/21/03
i.

I. 

A summary of any corrective actions taken as a result of the daily visual surveys of visible 

emissions and operating parameters. 

Requirements III.H.13(c)-(h) above are the same as those specified in III.I.12(c)-(h). When CFAC 

complies with the requirements of c through h above, it is also satisfying the reporting requirements of 

III.I.12(c)-(h). 

EU034 - EU038 POTLINE ROOF VENT EMITTING UNITS 

EU034 - Potline #1 Roof Vent-West Plant - AR03 EU037 - Potline #4 Roof Vent- East Plant - AR03

EU035 - Potline #2 Roof Vent-West Plant - AR03 EU038 - Potline #5 Roof Vent- East Plant - AR03

EU036 - Potline #3 Roof Vent- East Plant - AR03

Condition(s) Pollutant/ Compliance Demonstration 

Parameter 

Permit Limit 

Method Frequency

Reporting 

Requirements

I.1, I.4, I.5, Method 9 (Appendix J) Quarterly

I.8, I.9, I.12 

Opacity 10%

Visual Surveys 

(Appendix J) 

Daily

Quarterly

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 ) 

Three Test Runs

per Month 

Quarterly

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

Conditions

I.1.

I.2.

I.3.

I.4.

I.5.

CFAC shall not cause or authorize emissions to be discharged to the atmosphere from the Roof Vents 

of Potlines 1 through 5 (AR03) that exhibit an opacity of 10% or greater averaged over 6 consecutive 

minutes (ARM 17.8.332). 

CFAC shall not cause or authorize Total Fluoride (TF) emissions that exceed 1.3 kg of TF per Mg of 

aluminum produced (2.6-lb TF per ton of aluminum produced) from any single potline; or if CFAC is 

averaging the TF emissions from two or more potlines, the emission limit for the averaging scheme is 

prescribed in Appendix G, Table C (ARM 17.8.331 and ARM 17.8.342). 

CFAC shall not cause or authorize Polycyclic Organic Matter (POM) emissions that exceed 1.8 kg of 

POM per Mg of aluminum produced (3.6-lb POM per ton of aluminum produced) from any single

potline; or if CFAC is averaging the POM emissions from two or more potlines, the emission limit for 

the averaging scheme is prescribed in Appendix G, Table C (ARM 17.8.331 and ARM 17.8.342). 

Compliance Demonstration

A quarterly Method 9 test, performed in accordance with the procedures described in Appendix J of 

this permit, must be performed in accordance with the Montana Source Test Protocol and Procedures 

Manual. The Method 9 test shall be used to determine compliance with the 10% opacity limit. Each 

observation period shall be a minimum of 6 minutes, unless any one reading is greater than 10%; then

the observation period shall be a minimum of 20 minutes or until a violation of the standard has been 

documented, whichever is a shorter period of time (ARM 17.8.1213).

Daily, CFAC must visually inspect/survey the potline roof monitors for evidence of any visible 

emissions indicating abnormal operation using the procedures identified in Appendix J. The person

conducting the survey does not have to be EPA Method 9 certified. However, non-certified 

individuals must be familiar with the procedures of EPA Method 9, including the proper location to

observe the visible emissions. Upon identification of excessive emissions, CFAC shall initiate

corrective actions to mitigate the visible emissions (ARM 17.8.1213).

Permit Number: OP2655-01 16 Date of Decision: 05/21/03

Effective Date: 06/21/03
I.6. 

I.7.

I.8.

I.9.

I.10.

I.11.

I.12.

a.

b.

c.

d.

e.

f. 

Monthly, CFAC shall perform at least three emission measurement test runs for Total Fluoride (TF) on 

each potline (each Method 14 manifold system). Test runs must be the same duration as a pot cycle, or

48 hours. The minimum TF secondary emission testing schedule (three times per month) must adhere to 

the schedule defined in 40 CFR 63.847(b)(8); that is, at least one test run must be performed before the 

15th of each month, one test run must be performed after the 15th of each month, and the remaining test 

run can occur at any time during the month, except that there must be at least 6 days between two of the 

runs. All valid test runs must be used when determining the secondary TF emissions. TF Emissions 

determined by this requirement are combined with the TF Primary Control System emissions (rolling 

monthly average), and divided by the total aluminum production, to demonstrate compliance with 

potline TF emission limits (as prescribed in 40 CFR Part 63, Subpart LL and ARM 17.8.1213). 

CFAC shall perform at least one emission measurement test run for Polycyclic Organic Matter (POM) 

each month on each potline (each Method 14 manifold system). Test runs must be the same duration 

as a pot cycle, or 48 hours. All valid test runs must be used when determining the secondary POM 

emissions. POM emissions determined by this requirement are combined with measured POM 

emissions from the Primary Control Systems, and divided by the total aluminum production, to

demonstrate compliance with POM emission limits (as prescribed in 40 CFR Part 63, Subpart LL and

ARM 17.8.1213). 

Recordkeeping

Method 9 tests shall be conducted in accordance to the Montana Source Test Protocol and Procedures 

Manual. The test reports shall be maintained on site and must be submitted to the Department upon

request (ARM 17.8.106). 

CFAC shall maintain on-site records of the daily visible emissions observed from the potline roofs, 

any exceedances above the 10% opacity requirement of III.I.1, and any maintenance or repair initiated 

as a result of excessive visible emissions from the potline roof monitors (ARM 17.8.1212). 

CFAC shall maintain a record of the results from all valid TF emission measurement runs performed 

on the Method 14 Manifolds for all potlines. The potline secondary TF emissions will be calculated

based upon the testing required in III.I.6 (ARM 17.8.1212). 

CFAC shall maintain a record of the results from all valid POM emission measurement runs 

performed on the Method 14 Manifolds for all potlines. The potline secondary POM emissions will

be calculated based upon the testing required in III.I.7 (ARM 17.8.1212). 

Reporting

The annual compliance certification report required by Section V.B must contain a certification 

statement for the above applicable requirements. The quarterly reporting shall provide (ARM 

17.8.1212): 

The results of all valid source testing that was performed during the quarter; 

The calculated secondary TF and POM emissions from the potline roofs (TF-Monthly and POMQuarterly); 

The combined TF emissions from the Primary Control System and the secondary emissions from

the potline roof monitors; 

The combined POM emissions from the Primary Control System and the secondary emissions 

from the potline roof monitors; 

The tons of aluminum produced (TAP) for each potline per month and quarter; 

The lb of TF emitted per TAP for each potline, and each emission averaging group, per month; 

Permit Number: OP2655-01 17 Date of Decision: 05/21/03

Effective Date: 06/21/03
g.

h. 

i.

j.

J.

The lb of POM emitted per TAP for each potline, and each emission averaging group, per quarter; 

A statement of compliance (or noncompliance) for each condition specified in III.I.1, III.I.2, and 

III.I.3, for each period; 

The number of visible emission exceedances occurring during the quarter; and 

A summary of any corrective actions taken as a result of the daily visual surveys of visible 

emissions. 

Requirements III.I.12(c)-(h) above are the same as those specified in III.H.13(c)-(h). When CFAC 

complies with the requirements of c through h above, it is also satisfying the reporting requirements of 

III.H.13(c)-(h). 

EU039 - EU043 CASTING FURNACE EMITTING UNITS 

EU039 - Casting Furnace #3 - CO01 EU042 - Casting Furnace #7 - CO04

EU040 - Casting Furnace #4 - CO02 EU043 - Casting Furnace #8 & #9 - CO05 

EU041 - Casting Furnace #6 - CO03

Condition(s) Pollutant/ Compliance Demonstration 

Parameter 

Permit Limit 

Method Frequency

Reporting 

Requirements

J.1, J.4, J.5, J.6 Opacity 40% Natural Gas or Liquid 

Petroleum Gas Combustion 

Ongoing Annual

Certification 

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 

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 

Conditions

J.1.

J.2.

J.3.

J.4. 

J.5.

CFAC shall not cause or authorize emissions to be discharged to the atmosphere from Casting Furnace

#3-CO01, Casting Furnace #4-CO02, Casing Furnace #6-CO03, Casting Furnace #7-CO04, and 

Casting Furnaces #8 & #9-CO05, that exhibit an opacity of 40% or greater averaged over 6 

consecutive minutes (ARM 17.8.304(1)). 

CFAC shall not cause or authorize particulate matter caused by combustion, from fuel burning 

equipment installed before November 23, 1968, to be discharged from any outdoor stack or chimney

in excess of the value calculated by E = 0.882xH-0.1664, where H is the heat input capacity in MMBtu 

per hour and E is the maximum allowable particulate emissions rate in lb/MMBtu (ARM 17.8.309). 

CFAC shall not burn any gaseous fuel containing sulfur compounds in excess of 50 grains per 100

cubic feet of gaseous fuel, calculated as hydrogen sulfide at standard conditions (ARM 17.8.322(5)). 

Compliance Demonstration

The compliance monitoring required by this permit for the opacity (J.1), particulate matter from fuel 

combustion (J.2), and sulfur in fuel requirements (J.3), for their natural gas boilers shall consist of 

burning only natural gas or liquid petroleum gas. This does not preclude the Department from initiating 

an enforcement action if a Reference Method test indicates one of the limits is being violated (ARM 

17.8.1213). 

Recordkeeping

Recordkeeping is not required to monitor compliance with ARM 17.8.304, ARM 17.8.309, and ARM 

17.8.322 (ARM 17.8.1212).

Permit Number: OP2655-01 18 Date of Decision: 05/21/03

Effective Date: 06/21/03
Reporting

J.6.

K. 

The annual compliance certification report required by Section V.B shall contain a certification

statement for the above applicable requirements, and that only natural gas or liquid petroleum gases 

were combusted (ARM 17.8.1212). 

EU044 - EU048 CASTING PIT EMITTING UNITS 

EU044 - Casting Pit #3 - CO06 EU047 - Casting Pit #8 & #9 - CO06

EU045 - Casting Pit #4 - CO06 EU048 – Dross Handling - CO07 

EU046 - Casting Pit #6 & #7 - CO06

Condition(s) Pollutant/ Compliance Demonstration 

Parameter 

Permit Limit 

Method Frequency

Reporting 

Requirements

K.1, K.3, K.5, K.7 Opacity 40% Method 9 As Required by the

Department 

Semiannual 

K.2, K.4, K.6, K.7 Particulate Matter E = 4.10 x P 0.67 Method 5 As Required by the 

Department 

Annual Certification 

Conditions

K.1.

K.2.

K.3.

K.4. 

K.5.

K.6. 

K.7. 

CFAC shall not cause or authorize emissions to be discharged to the atmosphere from Casting Pits #3, 

#4, #6, #7, #8, #9, (CO06), and Dross Handling-CO07, that exhibit an opacity of 40% or greater 

averaged over 6 consecutive minutes (ARM 17.8.304(1)). 

The particulate emissions from process weight shall not exceed the value calculated by E = 4.10 x P

0.67

, where E is the rate of emissions in pounds per hour and P is the process weight rate in tons per

hour (ARM 17.8.310). 

Compliance Demonstration

As required by the Department, CFAC shall perform a Method 9 test in accordance with the Montana 

Source Test Protocol and Procedures Manual. The Method 9 test shall be used to monitor compliance

with the 40% opacity limit. Because all casting activities are conducted indoors, Method 9 testing will 

only focus on the visible emissions exiting from the openings of the casting buildings (ARM 

17.8.1213). 

CFAC is required to maintain normal operations to monitor compliance with section III.K.2 (ARM 

17.8.1213). 

Recordkeeping

All test reports shall be maintained on site and submitted to the Department in accordance with the

Montana Source Test Protocol and Procedures Manual (ARM 17.8.106). 

CFAC is not required to maintain records of normal operation indicating compliance with section III.K.2 

(ARM 17.8.1212). 

Reporting

The annual compliance certification report required by Section V.B shall contain a certification statement 

for the above applicable requirements. The semiannual compliance monitoring reports shall contain a 

summary of the results of any tests that were requested by the Department. Test reports shall be submitted 

to the Department in accordance with the Montana Source Test Protocol and Procedures Manual. 

Permit Number: OP2655-01 19 Date of Decision: 05/21/03

Effective Date: 06/21/03
L. EU049 - EU050 ALUMINUM SAW EMITTING UNITS 

EU049 – Sheet Ingot Saw - CO08 EU050 – T- Ingot Saw - CO09 

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration 

Method Frequency

Reporting 

Requirements

L.1, L.3, L.5, L.6 Opacity 20% Method 9 As Required by the

Department. 

Semiannual 

L.2, L.4, L.5, L.6 Particulate Matter E = 4.10*P0.67 Method 5 As Required by the

Department. 

Semiannual 

Conditions

L.1.

L.2.

L.3.

L.4.

L.5.

L.6. 

a.

b.

M. 

CFAC shall not cause or authorize emissions from the Sheet Ingot Saw-CO08 that exhibit an opacity

of 20% or greater averaged over 6 consecutive minutes (ARM 17.8.304(2)). As a result of venting 

indoors, EU050 (the T-Ingot Saw) is not currently subject to this requirement. 

The particulate emissions from process weight shall not exceed the value calculated by E = 4.10 x 

P0.67

, where E is the rate of emissions in pounds per hour and P is the process weight rate in tons per

hour (ARM 17.8.310). 

Compliance Demonstration

As required by the Department, CFAC shall perform a Method 9 test in accordance with the Montana 

Source Test Protocol and Procedures Manual. Each observation period shall be a minimum of 6 

minutes, unless any one reading is 20% or greater, at which point the observation period shall be a 

minimum of 20 minutes or until a violation of the standard has been documented, whichever is the 

shorter period of time (ARM 17.8.1213). 

As required by the Department, CFAC shall test the above sources for particulate matter in accordance

with Reference Method 5 to monitor compliance with the limitation contained in Section III.L.2. The 

source test must be performed as specified in the Montana Source Testing Protocol and Procedures

Manual (ARM 17.8.106). 

Recordkeeping

All test reports shall be maintained on site and submitted to the Department in accordance with the

Montana Source Test Protocol and Procedures Manual (ARM 17.8.106). 

Reporting

The annual compliance certification report required by Section V.B must contain a certification 

statement for the above applicable requirements. The semiannual reporting shall provide a summary of 

(ARM 17.8.1212): 

The results of any Method 9 testing conducted during the period; and 

The results of any Method 5 testing performed during the period. 

EU051 – SANDBLASTING ACTIVITIES - CR01 

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration 

Method Frequency

Reporting 

Requirements

M.1, M.4, M.7,

M.9 

Opacity 20% Method 9 As Required by

the Department 

Semiannual 

M.2, M.5, M.7,

M.9 

Opacity Reasonable

Precautions

Visual Surveys Weekly Semiannual 

M.3, M.6, M.7,

M.8, M.9 

Particulate Matter E = 4.10*P0.67 Normal

Operations 

Annual 

Certification 

Annual 

Certification 

Permit Number: OP2655-01 20 Date of Decision: 05/21/03

Effective Date: 06/21/03
Conditions

M.1.

M.2.

M.3.

M.4.

M.5.

M.6. 

M.7.

M.8. 

M.9. 

a. 

b.

c.

CFAC shall not cause or authorize emissions to be discharged to the atmosphere from Sandblasting

Activities-CR01 that exhibit an opacity of 20% or greater averaged over 6 consecutive minutes (ARM 

17.8.304(2)). 

CFAC shall not cause or authorize the production, handling, transportation, or storage of any material 

unless reasonable precautions to control emissions of particulate matter are taken. Such emission of 

airborne particulate matter from any stationary source shall not exhibit an opacity of 20% or greater

averaged over 6 consecutive minutes, unless otherwise specified by rule or in this permit (ARM 

17.8.308(1)). 

CFAC shall not cause or authorize particulate matter to be discharged from any operation, process, or 

activity into the atmosphere in excess of the value calculated by E = 4.10x P0.67, where E is the

emission rate in pounds per hour and P is the process weight rate in tons per hour (ARM 17.8.310). 

Compliance Demonstration

As required by the Department, CFAC shall perform a Method 9 test in accordance with the Montana 

Source Test Protocol and Procedures Manual. Each observation period shall be a minimum of 6 

minutes, unless any one reading is 20% or greater, at which point the observation period shall be a 

minimum of 20 minutes or until a violation of the standard has been documented, whichever is the 

shorter period of time (ARM 17.8.1213). 

For the purpose of compliance certification, CFAC shall conduct a weekly survey of the visible 

emissions from sand blasting activities. Conducting a visual survey does not relieve CFAC from the 

liability of a violation documented with a Method 9 test. The person conducting the visual survey

does not have to be an EPA Method 9 certified observer; however, the individual must be familiar 

with the procedures of EPA Method 9, including the proper location from which to observe visible 

emissions. If excessive fugitive emissions are identified, CFAC shall initiate efforts to minimize or

curtail the emissions (ARM 17.8.1213). 

CFAC is required to maintain normal operations to monitor compliance with section III.M.3 (ARM 

17.8.1212) 

Recordkeeping

All test reports shall be maintained on site and submitted to the Department in accordance with the

Montana Source Test Protocol and Procedures Manual (ARM 17.8.106). The log of weekly visual

survey results shall be maintained on site and submitted to the Department upon request. 

CFAC is not required to perform recordkeeping for III.M.6. 

Reporting

The annual compliance certification report required by Section V.B shall contain a certification statement 

for the above applicable requirements. The semiannual reporting shall provide a summary of (ARM 

17.8.1212): 

Any Method 9 tests that were performed;

All visual surveys that were conducted; and 

Any instances of excessive emissions and any corrective actions taken as a result of excessive 

emissions. 

Permit Number: OP2655-01 21 Date of Decision: 05/21/03

Effective Date: 06/21/03
N. EU052 – LECTROMELT FURNACE EMITTING UNIT - CR03 

Condition(s) Pollutant/ Compliance Demonstration 

Parameter 

Permit Limit 

Method Frequency

Reporting 

Requirements

N.1, N.3, N.4, N.6, N.8 Opacity 20% Method 9 As Required by the Dept. Semi-annual 

Baghouse I & M

(Appendix K) 

Ongoing Semi-annual

N.2, N.4, N.5, N.7, N.8 Particulate Matter E = 4.10*P0.67 Method 5 As Required by the Dept. Semi-annual 

Conditions

N.1.

N.2.

N.3.

N.4.

N.5.

N.6.

N.7.

N.8.

CFAC shall not cause or authorize emissions to be discharged to the atmosphere from the Lectromelt 

Furnace-CR03 that exhibit an opacity of 20% or greater averaged over 6 consecutive minutes (ARM 

17.8.304(2)). 

The particulate emissions from process weight shall not exceed the value calculated by E = 4.10*P0.67

, 

where E is the rate of emissions in pounds per hour and P is the process weight rate in tons per hour

(ARM 17.8.310). 

Compliance Demonstration

As required by the Department, CFAC shall perform a Method 9 test in accordance with the Montana 

Source Test Protocol and Procedures Manual. The Method 9 test shall be used to determine 

compliance with the 20% opacity limit (ARM 17.8.1213). 

CFAC shall operate and maintain the baghouse in accordance with the Pollution Control Device Inspection 

& Maintenance Plan (Appendix K) (ARM 17.8.1213).

As required by the Department, CFAC shall perform a Method 5 test in accordance with the Montana 

Source Test Protocol and Procedures Manual (ARM 17.8.1213). 

Recordkeeping 

CFAC shall maintain on-site records of all inspection and maintenance activities performed on the 

baghouses in accordance with the Pollution Control Device Inspection and Maintenance Plan 

(Appendix K) and submit such records to the Department upon request (ARM 17.8.1212). 

Method 5 and Method 9 test reports shall be maintained on site and shall be submitted to the

Department, upon request, in accordance with the Montana Source Protocol and Procedures Manual 

(ARM 17.8.106). 

Reporting

The annual compliance certification report required by Section V.B must contain a certification 

statement for the above applicable requirements. The semiannual compliance monitoring reports shall 

include a summary of (ARM 17.8.1212): 

a. The results of any test conducted during the reporting period; and 

b. Any corrective actions taken as a result of the inspections and maintenance as required by the 

Pollution Control Device Inspection & Maintenance Plan (Appendix K). 

Permit Number: OP2655-01 22 Date of Decision: 05/21/03

Effective Date: 06/21/03
O. EU053 – ROD MILL/MATERIAL STORAGE EMITTING UNIT - CR04

Condition(s) Pollutant / Compliance Demonstration 

Parameter 

Permit Limit 

Method Frequency

Reporting 

Requirements

Method 9 As Required by the 

Department. 

O.1, O.3, O.4, Semi-annual 

O.5, O.6, O.7 

Opacity 20%

Baghouse I & M

(Appendix K) 

Ongoing Semi-annual

O.2, O.3, O.4, 

O.5, O.6,O.7 

Particulate Matter E = 55*P0.11- 40 Method 5 As Required by the 

Department 

Semi-annual 

Conditions

O.1.

O.2.

O.3. 

O.4.

O.5.

O.6.

O.7. 

P. 

CFAC shall not cause or authorize emissions to be discharged to the atmosphere from the Rod 

Mill/Material Storage Unit-CR04 that exhibit an opacity of 20% or greater averaged over 6 

consecutive minutes (ARM 17.8.304(2)). 

The particulate emissions from process weight shall not exceed the value calculated by E = 55.0 x 

P0.11

- 40, where E is the rate of emissions in pounds per hour and P is the process weight rate in tons 

per hour (ARM 17.8.310). 

Compliance Demonstration

CFAC shall operate and maintain the baghouse in accordance with the Pollution Control Device 

Inspection & Maintenance Plan (Appendix K) (Arm 17.8.1213). 

As required by the Department, CFAC shall perform Method 5 and Method 9 tests in accordance with 

the Montana Source Test Protocol and Procedures Manual (ARM 17.8.1213). 

Recordkeeping

CFAC shall maintain on-site records of all inspection and maintenance activities performed on the 

baghouses in accordance with the Pollution Control Device Inspection & Maintenance Plan 

(Appendix K) and submit such records to the Department upon request (ARM 17.8.1212). 

Method 5 and Method 9 test reports must be maintained on site and must be submitted to the

Department in accordance with the Montana Source Testing Protocol and Procedures Manual (ARM 

17.8.106). 

Reporting

The annual compliance certification report required by Section V.B shall contain a certification statement 

for the above applicable requirements. The semiannual compliance monitoring reports shall include 

(ARM 17.8.1212): 

a. The results of any Method 5 or Method 9 tests conducted during the last reporting period; and 

b. A summary of any corrective actions taken as a result of the inspections and maintenance as 

required by the Pollution Control Device Inspection & Maintenance Plan (Appendix K). 

EU054 – EU062 NATURAL GAS BOILER EMITTING UNITS 

EU054 - Change House Boiler #1 - MP01 EU059 - Paste Plant Boiler #1 - MP11 

EU055 - Change House Boiler #2 - MP02 EU060 - Paste Plant Boiler #2 - MP12 

EU056 - Lab Boiler #1 - MP07 EU061 - Warehouse Boiler #1 - MP16 

EU057 - Machine Shop Boiler #1 - MP08 EU062 - Warehouse Boiler #2 - MP17 

EU058 - Machine Shop Boiler #2 - MP09 

Permit Number: OP2655-01 23 Date of Decision: 05/21/03

Effective Date: 06/21/03
Condition(s) Pollutant/ Compliance Demonstration 

Parameter 

Permit Limit 

Method Frequency

Reporting 

Requirements

P.1, P.4, P.5, P.6 Opacity 20% Natural Gas Combustion Ongoing Annual Certification

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

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

Conditions

P.1.

P.2.

P.3.

P.4.

P.5.

P.6.

Q. 

CFAC shall not cause or authorize emissions to be discharged to the atmosphere from the Change 

House Boilers #1-MP01, Change House Boiler #2-MP02, the Lab Boiler #1-MP07, Machine Shop

Boiler #1-MP08, Machine Shop Boiler #2-MP09, Paste Plant Boiler #1-MP11, Paste Plant Boiler #2-

MP12, Warehouse Boiler #1-MP16, and Warehouse Boiler #2-MP17, that exhibit an opacity of 20% 

or greater averaged over 6 consecutive minutes (ARM 17.8.304(2)). 

CFAC shall not cause or authorize particulate matter caused by combustion, from fuel burning 

equipment installed after November 23, 1968, to be discharged from any outdoor stack or chimney in 

excess of the value calculated by E = 1.026 x H-0.233, where H is the heat input capacity in MMBtu per 

hour and E is the maximum allowable particulate emissions rate in lb/MMBtu (ARM 17.8.309). 

CFAC shall not burn any gaseous fuel containing sulfur compounds in excess of 50 grains per 100

cubic feet of gaseous fuel, calculated as hydrogen sulfide at standard conditions (ARM 17.8.322(5)). 

Compliance Demonstration

Monitoring compliance for Section III.P.1, III.P.2, and III.P.3 may be satisfied for their natural gas 

boilers by burning only natural gas. This does not preclude the Department from initiating an

enforcement action if a Reference Method test indicates one of the limits is being violated (ARM 

17.8.1213). 

Recordkeeping

Recordkeeping is not required to monitor compliance with ARM 17.8.304, ARM 17.8.309, and ARM 

17.8.322 (ARM 17.8.1212).

Reporting

The annual compliance certification report required by Section V.B must contain a certification 

statement for the above applicable requirements, and that only natural gas was combusted (ARM 

17.8.1212). 

EU063 – TRUCK, EQUIPMENT, AND HAUL ROAD EMISSIONS – MP05

Condition(s) Pollutant/ Compliance Demonstration 

Parameter 

Permit Limit 

Method Frequency

Reporting 

Requirements

Q.1, Q.3, Q.4, 

Q.5 

Opacity 20% Method 9 As Required by the

Department 

Semiannual 

Method 9 As Required by the

Department 

Q.2, Q.3, Q.4, Semiannual 

Q.5 

Opacity Reasonable

Precautions

Maintenance,

Treatment, and Speed 

As Needed Semiannual 

Conditions

Q.1. CFAC shall not cause or authorize the production, handling, transportation, or storage of any material,

unless reasonable precautions to control emissions of particulate matter are taken. Such emissions of 

airborne particulate matter from any stationary source shall not exhibit an opacity of 20% or greater

Permit Number: OP2655-01 24 Date of Decision: 05/21/03

Effective Date: 06/21/03
averaged over 6 consecutive minutes, unless otherwise specified by rule or in this permit (ARM 

17.8.308(1)). 

Q.2.

Q.3.

Q.4.

Q.5.

R. 

CFAC shall maintain all portions of the haul roads, access roads, parking lots, and general plant area

as necessary to maintain compliance with ARM 17.8.308. Non-paved roads and plant areas subject to

vehicle and equipment traffic will be treated with water and/or chemical dust suppressants as

necessary to maintain compliance with ARM 17.8.308. 

Compliance Demonstration

As required by the Department, CFAC shall perform a Method 9 test in accordance with the Montana 

Source Test Protocol and Procedures Manual. Each observation period shall be a minimum of 6 

minutes, unless any one reading is 20% or greater, at which point the observation period shall be a 

minimum of 20 minutes or until a violation of the standard has been documented, whichever is the 

shorter period of time (ARM 17.8.1213). 

Recordkeeping

All test reports shall be maintained on site and submitted to the Department in accordance with the

Montana Source Test Protocol and Procedures Manual (ARM 17.8.106). 

Reporting

The annual compliance certification report required by Section V.B must contain a certification stating 

whether CFAC is in compliance with the above applicable requirements. The semiannual compliance

reporting shall include the results of any Method 9 testing conducted during the period (ARM

17.8.1212). 

EU064 – GASOLINE STORAGE (TANK) EMITTING UNIT – MP04 

Condition(s) Pollutant/Parameter Permit Limit Compliance Demonstration 

Method Frequency

Reporting 

Requirements

R.1, R.3, R.5,

R.6 

Opacity 20% Method 9 As Required by

the Department 

Semiannual 

R.2, R.4, R.6 Tanks Submerged Fill Certify Semiannual Semiannual

Conditions

R.1.

R.2.

R.3.

R.4.

CFAC shall not cause or authorize emissions to be discharged to the atmosphere from any Gasoline 

Storage-MP04 that exhibit an opacity of 20% or greater averaged over 6 consecutive minutes (ARM

17.8.304(2)). 

CFAC shall load (fill) the gasoline storage tank only through a permanent submerged fill pipe, or shall

equip the tank with a vapor loss control device (ARM 17.8.324(3)). 

Compliance Demonstration

As required by the Department, CFAC shall perform a Method 9 test in accordance with the Montana 

Source Test Protocol and Procedures Manual. Each observation period shall be a minimum of 6 

minutes, unless any one reading is 20% or greater, at which point the observation period shall be a 

minimum of 20 minutes or until a violation of the standard has been documented, whichever is the 

shorter period of time (ARM 17.8.1213). 

CFAC shall certify that the submerged fill pipe was used during loading (ARM 17.8.1213). 

Permit Number: OP2655-01 25 Date of Decision: 05/21/03

Effective Date: 06/21/03
Recordkeeping

R.5.

R.6.

a. 

b.

All test reports shall be maintained on site and submitted to the Department in accordance with the

Montana Source Test Protocol and Procedures Manual (ARM 17.8.106). 

Reporting

The annual compliance certification report required by Section V.B must contain a certification 

statement for the above applicable requirements. The semiannual reporting shall provide (ARM 

17.8.1212): 

A summary of the results from any source testing that was performed; and 

A statement certifying that the submerged pipe was used during loading operations. 

Permit Number: OP2655-01 26 Date of Decision: 05/21/03

Effective Date: 06/21/03
SECTION IV NON-APPLICABLE REQUIREMENTS 

Air Quality Administrative Rules of Montana (ARM) and Federal Regulations identified as not applicable to

the facility or to a specific emission unit at the time of the permit issuance are listed below (ARM 17.8.1214). 

The following list does not preclude the need to comply with any new requirements that may become

applicable during the permit term. 

A. FACILITY-WIDE 

The following table contains non-applicable requirements that are administrated by the Air and Waste 

Management Bureau of the Department of Environmental Quality.

Rule Citation 

State Federal

Reason 

ARM 17.8.321, 

ARM 17.8.323, and 

ARM 17.8.610 

These rules are not applicable because the facility is not listed in

the source category cited in the rules. 

ARM 17.8 316 

ARM 17.8.320,

ARM 17.8.324(4)-(6) 

These rules are not applicable because the facility does not have

the specific emission unit cited in the rules. 

40 CFR 60, Subparts C, Ca, Cb 

40 CFR 60, Subparts D, Da, Db, Dc 

40 CFR 60, Subparts E-J 

40 CFR 60, Subparts K, Ka, Kb 

40 CFR 60, Subparts L-Z 

40 CFR 60, Subparts AA-EE 

40 CFR 60, Subparts GG-HH 

40 CFR 60, Subparts KK-NN 

40 CFR 60, Subparts PP-XX 

40 CFR 60, Subparts AAA-BBB 

40 CFR 60, Subparts DDD 

40 CFR 60, Subparts FFF-LLL 

40 CFR 60, Subparts NNN-VVV 

40 CFR 61, Subparts B-F 

40 CFR 61, Subparts H-L 

40 CFR 61, Subparts N-R 

40 CFR 61, Subparts V-W 

40 CFR 61, Subpart Y 

40 CFR 61, Subpart BB 

40 CFR 61, Subpart FF 

These requirements are not applicable because the facility is not

an affected source as defined in these regulations.

40 CFR 63, Subpart B 

40 CFR 63, Subparts F-I 

40 CFR 63, Subparts L-M 

40 CFR 63, Subpart Q 

40 CFR 82, Subparts A-E 

40 CFR 82, Subparts G-H 

These requirements are not applicable because the facility is not

an affected source as defined in these regulations.

40 CFR 72 through 

40 CFR 78. 

These requirements are not applicable because the facility is not

an affected source as defined by the acid rain regulations. 

40 CFR 68 This rule is not applicable because the facility does not meet the 

threshold quantity for any regulated substance. 

B. EMISSION UNITS

The permit application identified applicable requirements: non-applicable requirements for individual or 

specific emission units were not listed. The Department has listed all non-applicable requirements in

Section IV.A; these requirements relate to each specific unit as well as facility wide. 

Permit Number: OP2655-01 27 Date of Decision: 05/21/03

Effective Date: 06/21/03
SECTION V – GENERAL PERMIT CONDITIONS 

A. Compliance Requirements 

ARM 17.8, Subchapter 12, Operating Permit Program §1210(2)(a)-(c)&(e), §1206(6)(c)&(b)

1. 

2. 

3. 

4. 

5. 

6. 

The permittee must comply with all conditions of the permit. Any noncompliance with the 

terms or conditions of the permit constitutes a violation of the Montana Clean Air Act, and may 

result in enforcement action, permit modification, revocation and reissuance, or termination, or 

denial of a permit renewal application under ARM Title 17, Chapter 8, Subchapter 12. 

The filing of a request by the permittee for a permit modification, revocation and reissuance, or

termination, or of a notification of planned changes or anticipated noncompliance does not stay 

any permit condition. 

It shall not be a defense for a permittee in an enforcement action that it would have been 

necessary to halt or reduce the permitted activity in order to maintain compliance with the 

conditions of the permit. If appropriate, this factor may be considered as a mitigating factor in 

assessing a penalty for noncompliance with an applicable requirement if the source 

demonstrates that both the health, safety or environmental impacts of halting or reducing 

operations would be more serious than the impacts of continuing operations, and that such 

health, safety or environmental impacts were unforeseeable and could not have otherwise been

avoided. 

The permittee shall furnish to the Department, within a reasonable time set by the Department 

(not to be less than 15 days), any information that the Department may request in writing to 

determine whether cause exists for modifying, revoking and reissuing, or terminating the 

permit, or to determine compliance with the permit. Upon request, the permittee shall also 

furnish to the Department copies of those records that are required to be kept pursuant to the 

terms of the permit. This subsection does not impair or otherwise limit the right of the 

permittee to assert the confidentiality of the information requested by the Department, as 

provided in 75-2-105, MCA. 

Any schedule of compliance for applicable requirements with which the source is not in 

compliance with at the time of permit issuance shall be supplemental to, and shall not sanction

noncompliance with, the applicable requirements on which it was based. 

For applicable requirements that will become effective during the permit term, the source shall 

meet such requirements on a timely basis unless a more detailed plan or schedule is required by 

the applicable requirement or the Department. 

B. Certification Requirements 

ARM 17.8, Subchapter 12, Operating Permit Program §1207 and §1213(7)(a)&(c)-(d)

1. 

2. 

Any application form, report, or compliance certification submitted pursuant to ARM Title 17, 

Chapter 8, Subchapter 12, shall contain certification by a responsible official of truth, accuracy

and completeness. This certification and any other certification required under ARM Title 17, 

Chapter 8, Subchapter 12, shall state that, based on information and belief formed after 

reasonable inquiry, the statements and information in the document are true, accurate and 

complete. 

Compliance certifications shall be submitted by January 31 of each year, or more frequently if 

otherwise specified in an applicable requirement or elsewhere in the permit. Each certification 

must include the required information for the previous calendar year (i.e., January 1 – 

December 31). 

Permit Number: OP2655-01 28 Date of Decision: 05/21/03

Effective Date: 06/21/03
3. 

4. 

Compliance certifications shall include the following:

a. The identification of each term or condition of the permit that is the basis of the 

certification; 

b. The identification of the method(s) or other means used by the owner or operator for 

determining the status of compliance with each term or condition during the certification 

period, and whether such methods or other means provide continuous or intermittent data, 

as well as the additional information required by ARM 17.8.1213(7)(c)(ii); 

c. The status of compliance with the terms and conditions of the permit for the period covered 

by the certification, based on the method or means designated in ARM 17.8.1213(7)(c)(ii), 

as well as the additional information required by ARM 17.8.1213(7)(c)(iii); and 

d. Such other facts as the Department may require to determine the compliance status of the 

source. 

All compliance certifications must be submitted to the Environmental Protection Agency, as 

well as to the Department, at the addresses listed in the Notification Addresses Appendix of this 

permit. 

C. Permit Shield 

ARM 17.8, Subchapter 12, Operating Permit Program §1214(1)-(4)

1. The applicable requirements and non-federally enforceable requirements are included and 

specifically identified in this permit and the permit includes a precise summary of the 

requirements not applicable to the source. Compliance with the conditions of the permit shall

be deemed compliance with any applicable requirements and any non-federally enforceable 

requirements as of the date of permit issuance. 

2. The permit shield described in 1 above shall remain in effect during the appeal of any permit 

action (renewal, revision, reopening, or revocation and reissuance) to the Board of 

Environmental Review (Board), until such time as the Board renders its final decision. 

3. Nothing in this permit alters or affects the following: 

a. The provisions of Sec. 7603 of the FCAA, including the authority of the administrator 

under that section. 

b. The liability of an owner or operator of a source for any violation of applicable 

requirements prior to or at the time of permit issuance.

c. The applicable requirements of the Acid Rain Program, consistent with Sec. 7651g(a) of 

the FCAA. 

d. The ability of the administrator to obtain information from a source pursuant to Sec. 7414 

of the FCAA. 

e. The ability of the Department to obtain information from a source pursuant to the Montana 

Clean Air Act, Title 75, Chapter 2, MCA. 

f. The emergency powers of the Department under the Montana Clean Air Act, Title 75, 

Chapter 2, MCA. 

Permit Number: OP2655-01 29 Date of Decision: 05/21/03

Effective Date: 06/21/03
g. The ability of the Department to establish or revise requirements for the use of Reasonably

Available Control Technology (RACT) as defined in ARM Title 17, Chapter 8. However, 

if the inclusion of a RACT into the permit pursuant to ARM Title 17, Chapter 8, 

Subchapter 12, is appealed to the Board, the permit shield, as it applies to the source’s 

existing permit, shall remain in effect until such time as the Board has rendered its final 

decision. 

4. Nothing in this permit alters or affects the ability of the Department to take enforcement action 

for a violation of an applicable requirement or permit term demonstrated pursuant to ARM 

17.8.106, Source Testing Protocol. 

5. Pursuant to ARM 17.8.132, for the purpose of submitting a compliance certification, nothing in

these rules shall preclude the use, including the exclusive use, of any credible evidence or 

information relevant to whether a source would have been in compliance. However, when 

compliance or noncompliance is demonstrated by a test or procedure provided by permit or 

other applicable requirements, the source shall then be presumed to be in compliance or 

noncompliance unless that presumption is overcome by other relevant credible evidence. 

6. The permit shield will not extend to minor permit modifications or changes not requiring a 

permit revision (see Sections I & J). 

7. The permit shield will extend to significant permit modifications and transfer or assignment of 

ownership (see Sections K & N). 

D. Monitoring, Recordkeeping, and Reporting Requirements 

ARM 17.8, Subchapter 12, operating Permit Program §1212(2)&(3)

1. Unless otherwise provided in this permit, the permittee shall maintain compliance monitoring 

records that include the following information. 

a. The date, place as defined in the permit, and time of sampling or measurement; 

b. The date(s) analyses were performed; 

c. The company or entity that performed the analyses; 

d. The analytical techniques or methods used; 

e. The results of such analyses; and 

f. The operating conditions at the time of sampling or measurement. 

2. The permittee shall retain records of all required monitoring data and support information for a 

period of at least 5 years from the date of the monitoring sample, measurement, report, or 

application. Support information includes all calibration and maintenance records and all 

original strip-chart recordings for continuous monitoring instrumentation, and copies of all 

reports required by the permit. All monitoring data, support information, and required reports 

and summaries may be maintained in computerized form at the plant site if the information is 

made available to Department personnel upon request, which may be for either hard copies or

computerized format. Strip-charts must be maintained in their original form at the plant site and 

shall be made available to Department personnel upon request. 

3. The permittee shall submit to the Department, at the addresses located in the Notification 

Addresses Appendix of this permit, reports of any required monitoring by January 31 and July 

31 of each year, or more frequently if otherwise specified in an applicable requirement or 

Permit Number: OP2655-01 30 Date of Decision: 05/21/03

Effective Date: 06/21/03
elsewhere in the permit. The monitoring report submitted on January 31 of each year must 

include the required monitoring information for the period of July 1 through December 31 of 

the previous year. The monitoring report submitted on July 31 of each year must include the 

required monitoring information for the period of January 1 through June 30 of the current year. 

All instances of deviations from the permit requirements must be clearly identified in such 

reports. All required reports must be certified by a responsible official, consistent with ARM 

17.8.1207. 

E. Prompt Deviation Reporting 

ARM 17.8, Subchapter 12, Operating Permit Program §1212(3)(c)

The permittee shall promptly report deviations from permit requirements, including those 

attributable to upset conditions as defined in the permit, the probable cause of such deviations, and 

any corrective actions or preventive measures taken. To be considered prompt, deviations shall be 

reported as part of the routine reporting requirements under ARM 17.8.1212(3)(b) and, if applicable, 

in accordance with the malfunction reporting requirements under ARM 17.8.110, unless otherwise 

specified in an applicable requirement. 

F. Emergency Provisions 

ARM 17.8, Subchapter 12, Operating Permit Program §1201(13) and §1214(5), (6)&(8)

1. An “emergency” means any situation arising from sudden and reasonably unforeseeable events 

beyond the control of the source, including acts of God, which situation requires immediate 

corrective action to restore normal operation and causes the source to exceed a technologybased emission limitation under this permit due to the unavoidable increases in emissions 

attributable to the emergency. An emergency shall not include noncompliance to the extent 

caused by improperly designed equipment, lack of reasonable preventive maintenance, careless 

or improper operation, or operator error. 

2. An emergency constitutes an affirmative defense to an action brought for noncompliance with a 

technology-based emission limitation if the permittee demonstrates through properly signed, 

contemporaneous logs, or other relevant evidence, that: 

a. An emergency occurred and the permittee can identify the cause(s) of the emergency.

b. The permitted facility was at the time being properly operated. 

c. During the period of the emergency the permittee took all reasonable steps to minimize 

levels of emissions that exceeded the emission standards or other requirements in the 

permit. 

d. The permittee submitted notice of the emergency to the Department within 2 working days

of the time when emission limitations were exceeded due to the emergency. This notice 

fulfills the requirements of ARM 17.8.1212(3)(c). This notice must contain a description 

of the emergency, any steps taken to mitigate emissions, and corrective actions taken. 

3. These emergency provisions are in addition to any emergency, malfunction or upset provision 

contained in any applicable requirement. 

Permit Number: OP2655-01 31 Date of Decision: 05/21/03

Effective Date: 06/21/03
G. Inspection and Entry 

ARM 17.8, Subchapter 12, Operating Permit Program §1213(3)&(4)

1. Upon presentation of credentials and other requirements as may be required by law, the 

permittee shall allow the Department, the administrator, or an authorized representative 

(including an authorized contractor acting as a representative of the Department or the 

administrator) to perform the following: 

a. Enter the premises where a source required to obtain a permit is located or emissionsrelated activity is conducted, or where records must be kept under the conditions of the 

permit. 

b. Have access to and copy, at reasonable times, any records that must be kept under the 

conditions of the permit. 

c. Inspect at reasonable times any facilities, emission units, equipment (including monitoring 

and air pollution control equipment), practices, or operations regulated or required under 

the permit. 

d. As authorized by the Montana Clean Air Act and rules promulgated thereunder, sample or 

monitor, at reasonable times, any substances or parameters at any location for the purpose 

of assuring compliance with the permit or applicable requirements.

2. The permittee shall inform the inspector of all workplace safety rules or requirements at the 

time of inspection. This section shall not limit in any manner the Department’s statutory right 

of entry and inspection as provided for in 75-2-403, MCA. 

H. Fee Payment

ARM 17.8, Subchapter 12, Operating Permit Program §1210(2)(f) and ARM 17.8, Subchapter 5, Air 

Quality Permit Application, Operation, and Open Burning Fees §505(3)-(5) (STATE ONLY)

1. The permittee must pay application and operating fees, pursuant to ARM Title 17, Chapter 8, 

Subchapter 5.

2. Annually, the Department shall provide the permittee with written notice of the amount of the

fee and the basis for the fee assessment. The air quality operation fee is due 30 days after 

receipt of the notice, unless the fee assessment is appealed pursuant to ARM 17.8.511. If any

portion of the fee is not appealed, that portion of the fee that is not appealed is due 30 days after 

receipt of the notice. Any remaining fee, which may be due after the completion of an appeal, 

is due immediately upon issuance of the Board’s decision or upon completion of any judicial 

review of the Board’s decision. 

3. If the permittee fails to pay the required fee (or any required portion of an appealed fee) within 

90 days of the due date of the fee, the Department may impose an additional assessment of 15% 

of the fee (or any required portion of an appealed fee) or $100, whichever is greater, plus 

interest on the fee (or any required portion of an appealed fee), computed at the interest rate 

established under 15-31-510(3), MCA.

I. Minor Permit Modifications 

ARM 17.8, Subchapter 12, Operating Permit Program §1226(3)&(11)

1. An application for a minor permit modification need only address in detail those portions of the 

permit application that require revision, updating, supplementation, or deletion, and may

reference any required information that has been previously submitted. 

Permit Number: OP2655-01 32 Date of Decision: 05/21/03

Effective Date: 06/21/03
2. The permit shield under ARM 17.8.1214 will not extend to any minor modifications processed 

pursuant to ARM 17.8.1226. 

J. Changes Not Requiring Permit Revision 

ARM 17.8, Subchapter 12, Operating Permit Program §1224(1)-(3), (5)&(6)

1. The permittee is authorized to make changes within the facility as described below, provided 

the following conditions are met. 

a. The proposed changes do not require the permittee to obtain an air quality preconstruction 

permit under ARM Title 17, Chapter 8, Subchapter7.

b. The proposed changes are not modifications under Title I of the FCAA, or as defined in 

ARM Title 17, Chapter 8, Subchapters 8, 9, or 10. 

c. The emissions resulting from the proposed changes do not exceed the emissions allowable 

under this permit, whether expressed as a rate of emissions or in total emissions. 

d. The proposed changes do not alter permit terms that are necessary to enforce applicable 

emission limitations on emission units covered by the permit. 

e. The facility provides the administrator and the Department with written notification at least 

7 days prior to making the proposed changes. 

2. The permittee and the Department shall attach each notice provided pursuant to 1.e above to 

their respective copies of this permit. 

3. Pursuant to the conditions above, the permittee is authorized to make Section 502(b)(10) 

changes, as defined in ARM 17.8.1201(30), without a permit revision. For each such change, 

the written notification required under 1.e above shall include a description of the change within 

the source, the date on which the change will occur, any change in emissions, and any permit 

term or condition that is no longer applicable as a result of the change. 

4. The permittee may make a change not specifically addressed or prohibited by the permit terms 

and conditions without requiring a permit revision, provided the following conditions are met. 

a. Each proposed change does not weaken the enforceability of any existing permit 

conditions. 

b. The Department has not objected to such change. 

c. Each proposed change meets all applicable requirements and does not violate any existing 

permit term or condition. 

d. The permittee provides contemporaneous written notice to the Department and the 

administrator of each change that is above the level for insignificant emission units as 

defined in ARM 17.8.1201(22) and 17.8.1206(3), and the written notice describes each 

such change, including the date of the change, any change in emissions, pollutants emitted, 

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

5. The permit shield authorized by ARM 17.8.1214 shall not apply to changes made pursuant to 

ARM 17.8.1224(3) and (5), but is applicable to terms and conditions that allow for increases 

and decreases in emissions pursuant to ARM 17.8.1224(4). 

Permit Number: OP2655-01 33 Date of Decision: 05/21/03

Effective Date: 06/21/03
K. Significant Permit Modifications 

ARM 17.8, Subchapter 12, Operating Permit Program §1227(1), (3)&(4)

1. The modification procedures set forth in 2 below must be used for any application requesting a 

significant modification of this permit. Significant modifications include the following: 

a. Any permit modification that does not qualify as either a minor modification or as an 

administrative permit amendment; 

b. Every significant change in existing permit monitoring terms or conditions; 

c. Every relaxation of permit reporting or recordkeeping terms or conditions that limit the 

Department’s ability to determine compliance with any applicable rule, consistent with the 

requirements of the rule; or

d. Any other change determined by the Department to be significant. 

2. Significant modifications shall meet all requirements of ARM Title 17, Chapter 8, including 

those for applications, public participation, and review by affected states and the administrator, 

as they apply to permit issuance and renewal, except that an application for a significant permit 

modification need only address in detail those portions of the permit application that require 

revision, updating, supplementation or deletion. 

3. The permit shield provided for in ARM 17.8.1214 shall extend to significant modifications. 

L. Reopening for Cause 

ARM 17.8, Subchapter 12, Operating Permit Program §1228(1)&(2)

This permit may be reopened and revised under the following circumstances. 

1. Additional applicable requirements under the FCAA become applicable to the facility when 

the permit has a remaining term of 3 or more years. Reopening and revision of the permit 

shall be completed not later than 18 months after promulgation of the applicable 

requirement. No reopening is required under ARM 17.8.1228(1)(a) if the effective date of 

the applicable requirement is later than the date on which the permit is due to expire, unless 

the original permit or any of its terms or conditions have been extended pursuant to ARM 

17.8.1220(12) or 17.8.1221(2). 

2. Additional requirements (including excess emission requirements) become applicable to an 

affected source under the Acid Rain Program. Upon approval by the administrator, excess 

emission offset plans shall be deemed incorporated into the permit. 

3. The Department or the administrator determines that the permit contains a material mistake 

or that inaccurate statements were made in establishing the emission standards or other 

terms or conditions of the permit. 

4. The administrator or the Department determines that the permit must be revised or revoked 

and reissued to ensure compliance with the applicable requirements.

M. Permit Expiration and Renewal 

ARM 17.8, Subchapter 12, Operating Permit Program §1210(2)(g), §1220(11)&(12), and §1205(2)(d)

1. This permit is issued for a fixed term of 5 years. 

Permit Number: OP2655-01 34 Date of Decision: 05/21/03

Effective Date: 06/21/03
2. Renewal of this permit is subject to the same procedural requirements that apply to permit 

issuance, including those for application, content, public participation, and affected state and 

administrator review.

3. Expiration of this permit terminates the permittee’s right to operate unless a timely and 

administratively complete renewal application has been submitted consistent with ARM 

17.8.1221 and 17.8.1205(2)(d). If a timely and administratively complete application has been 

submitted, all terms and conditions of the permit, including the application shield, remain in 

effect after the permit expires until the permit renewal has been issued or denied. 

4. For renewal, the permittee shall submit a complete air quality operating permit application to 

the Department not later than 6 months prior to the expiration of this permit, unless otherwise 

specified. If necessary to ensure that the terms of the existing permit will not lapse before 

renewal, the Department may specify, in writing to the permittee, a longer time period for 

submission of the renewal application. Such written notification must be provided at least 1 

year before the renewal application due date established in the existing permit. 

N. Severability Clause 

ARM 17.8, Subchapter 12, Operating Permit Program §1210(2)(i)&(l)

1. The administrative appeal or subsequent judicial review of the issuance by the Department of an 

initial permit under this subchapter shall not impair in any manner the underlying applicability

of all applicable requirements, and such requirements continue to apply as if a final permit 

decision had not been reached by the Department. 

2. If any provision of a permit is found to be invalid, all valid parts that are severable from the 

invalid part remain in effect. If a provision of a permit is invalid in one or more of its 

applications, the provision remains in effect in all valid applications that are severable from the 

invalid applications. 

O. Transfer or Assignment of Ownership 

ARM 17.8, Subchapter 12, Operating Permit Program §1225(2)&(4)

1. If an administrative permit amendment involves a change in ownership or operational control,

the applicant must include in its request to the Department a written agreement containing a 

specific date for the transfer of permit responsibility, coverage and liability between the current 

and new permittee. 

2. The permit shield provided for in ARM17.8.1214 shall not extend to administrative permit 

amendments. 

P. Emissions Trading, Marketable Permits, Economic Incentives 

ARM 17.8, Subchapter 12, Operating Permit Program §1226(2)

Notwithstanding ARM 17.8.1226(1) and (7), minor air quality operating permit modification 

procedures may be used for permit modifications involving the use of economic incentives, 

marketable permits, emissions trading, and other similar approaches, to the extent that such minor 

permit modification procedures are explicitly provided for in the Montana State Implementation Plan 

or in applicable requirements promulgated by the administrator. 

Q. No Property Rights Conveyed 

ARM 17.8, Subchapter 12, Operating Permit Program §1210(2)(d)

This permit does not convey any property rights of any sort, or any exclusive privilege. 

Permit Number: OP2655-01 35 Date of Decision: 05/21/03

Effective Date: 06/21/03
R. Testing Requirements 

ARM 17.8, Subchapter 1, General Provisions §105

The permittee shall comply with ARM 17.8.105. 

S. Source Testing Protocol 

ARM 17.8, Subchapter 1, General Provisions §106

The permittee shall comply with ARM 17.8.106. 

T. Malfunctions 

ARM 17.8, Subchapter 1, General Provisions §110

The permittee shall comply with ARM 17.8.110. 

U. Circumvention 

ARM 17.8, Subchapter 1, General Provisions §111

The permittee shall comply with ARM 17.8.111. 

V. Motor Vehicles 

ARM 17.8, Subchapter 3, Emission Standards §325

The permittee shall comply with ARM 17.8.325. 

W. Annual Emissions Inventory 

ARM 17.8, Subchapter 5, Air Quality Permit Application, Operation and Open Burning Fees §505 

(STATE ONLY)

The permittee shall supply the Department with annual production and other information for all 

emission units necessary to calculate actual or estimated actual amount of air pollutants emitted 

during each calendar year. Information shall be gathered on a calendar-year basis and submitted to 

the Department by the date required in the emission inventory request, unless otherwise specified in 

this permit. Information shall be in the units required by the Department. 

X. Open Burning 

ARM 17.8, Subchapter 6, Open Burning §604, 605 and 606

The permittee shall comply with ARM 17.8.604, 605 and 606. 

Y. Preconstruction Permits 

ARM 17.8, Subchapter 7, Permit, Construction and Operation of Air Contaminant Sources §743, 

744, 745 and 764 (ARM 17.8.745(1), and 764(1)(b) are STATE ENFORCEABLE ONLY until 

approval by the EPA as part of the SIP)

1. Except as specified, no person shall construct, install, alter or use any air contaminant source or 

stack associated with any source without first obtaining a permit from the Department or Board. 

A permit is not required for those sources or stacks as specified by ARM 17.8.745(1). 

2. The permittee shall comply with ARM 17.8.743, 744, 745, 748 and 764. 

3. ARM 17.8.745(1) specifies de minimis changes as construction or changed conditions of 

operation at a facility holding an air quality preconstruction permit issued under Chapter 8 that 

does not increase the facility’s potential to emit by more than 15 tons per year of any pollutant, 

except (STATE ENFORCEABLE ONLY until approved by the EPA as part of the SIP): 

Permit Number: OP2655-01 36 Date of Decision: 05/21/03

Effective Date: 06/21/03
a. Any construction or changed condition that would violate any condition in the facility’s 

existing air quality preconstruction permit or any applicable rule contained in Chapter 8 is 

prohibited, except as provided in ARM 17.8.745(2). 

b. Any construction or changed conditions of operation that would qualify as a major 

modification under Subchapters 8, 9 or 10 of Chapter 8. 

c. Any construction or changed condition of operation that would affect the plume rise or 

dispersion characteristic of emissions that would cause or contribute to a violation of an 

ambient air quality standard or ambient air increment as defined in ARM 17.8.804. 

d. Any construction or improvement project with a potential to emit more than 15 tons per 

year may not be artificially split into smaller projects to avoid air quality preconstruction 

permitting. 

e. Emission reductions obtained through offsetting within a facility are not included when 

determining the potential emission increase from construction or changed conditions of 

operation, unless such reductions are made federally enforceable. 

4. Any facility making a de minimis change pursuant to ARM 17.8.745(1) shall notify the 

Department if the change would include a change in control equipment, stack height, stack 

diameter, stack gas temperature, source location or fuel specifications, or would result in an 

increase in source capacity above its permitted operation or the addition of a new emission unit. 

The notice must be submitted, in writing, 10 days prior to start up or use of the proposed de 

minimis change, or as soon as reasonably practicable in the event of an unanticipated 

circumstance causing the de minimis change, and must include the information requested in 

ARM 17.8.745(1). (STATE ENFORCEABLE ONLY until approval by the EPA as part of the 

SIP) 

Z. National Emission Standard for Asbestos 

40 CFR, Part 61, Subpart M

The permittee shall not conduct any asbestos abatement activities except in accordance with 40 

CFR 61, Subpart M (National Emission Standard for Hazardous Air Pollutants for Asbestos). 

AA. Asbestos 

ARM 17.74, Subchapter 3, General Provisions and Subchapter 4, Fees

The permittee shall comply with ARM 17.74.301, et seq., and ARM 17.74.401, et seq. (State only)

BB. Stratospheric Ozone Protection – Servicing of Motor Vehicle Air Conditioners 

40 CFR, Part 82, Subpart B

If the permittee performs a service on motor vehicles and this service involves ozone-depleting 

substance/refrigerant in the motor vehicle air conditioner (MVAC), the permittee is subject to all 

the applicable requirements as specified in 40 CFR 82, Subpart B. 

CC. Stratospheric Ozone Protection – Recycling and Emission Reductions 

40 CFR, Part 82, Subpart F

The permittee shall comply with the standards for recycling and emission reductions in 40 CFR 

82, Subpart F, except as provided for MVACs in Subpart B. 

Permit Number: OP2655-01 37 Date of Decision: 05/21/03

Effective Date: 06/21/03
1. Persons opening appliances for maintenance, service, repair, or disposal must comply with the

required practices pursuant to §82.156. 

2. Equipment used during the maintenance, service, repair or disposal of appliances must comply

with the standards for recycling and recovery equipment pursuant to §82.158. 

3. Persons performing maintenance, service, repair or disposal of appliances must be certified by

an approved technical certification program pursuant to §82.161. 

4. Persons disposing of small appliances, MVACs and MVAC-like (as defined at §82.152) 

appliances must comply with recordkeeping requirements pursuant to §82.166. 

5. Persons owning commercial or industrial process refrigeration equipment must comply with the 

leak repair requirements pursuant to §82.156. 

6. Owners/operators of appliances normally containing 50 or more pounds of refrigerant must 

keep records of refrigerant purchased and added to such appliances pursuant to §82.166. 

DD. Emergency Episode Plan 

The permittee shall comply with the requirements contained in Chapter 9.7 of the State of 

Montana Air Quality Control Implementation Plan. 

Each major source emitting 100 tons per year located in a Priority I Air Quality Control Region, 

shall submit to the Department a legally enforceable Emergency Episode Action Plan (EEAP) that 

details how the source will curtail emissions during an air pollutant emergency episode. The 

industrial EEAP shall be in accordance with the Department’s EEAP and shall be submitted 

according to a timetable developed by the Department, following Priority I reclassification 

EE. Definitions 

Terms not otherwise defined in this permit or in the Definitions and Abbreviations Appendix of 

this permit, shall have the meaning assigned to them in the referenced regulations. 

Permit Number: OP2655-01 38 Date of Decision: 05/21/03

Effective Date: 06/21/03
APPENDICES 

Permit Number: OP2655-00 39 Date of Decision: 05/21/03

Effective Date: 06/21/03
Appendix A RULE CITATION 

Pursuant to Chapter 418, Laws of Montana 1995, effective July 1, 1995, the Air Quality Division was 

transferred from the Department of Health and Environmental Sciences to the Department of Environmental 

Quality. To implement the legislation, ARM 16.8.101 through ARM 16.8.2025, and 16.9.101 through 

16.9.106, except any repealed rules, were transferred to the Department of Environmental Quality as ARM 

17.8.101 through 17.8.1234 and 17.80.101 through 17.80.106 effective August 22, 1996. On September 19, 

1997, the rule transfer was submitted to EPA and is pending approval as part of the State Implementation Plan 

(SIP). The old citations are still cited in the SIP until EPA approves the rule transfer. 

NEW CITATION OLD CITATION

Sub-chapter 1 – General Provisions 

17.8.101 Definitions 16.8.701 

17.8.102 Incorporation by Reference - Publication Dates and 

Availability of Referenced Documents 16.8.710 

17.8.103 Incorporation by Reference 16.8.708 

17.8.105 Testing Requirements 16.8.704 

17.8.106 Source Testing Protocol 16.8.709 

17.8.110 Malfunctions 16.8.705 

17.8.111 Circumvention 16.8.707 

17.8.120 Variance Procedures – Initial Application 16.8.101 

17.8.121 Variance Procedures – Renewal Application 16.8.102 

17.8.130 Enforcement Procedures – Notice of Violation –Order to Take 

Corrective Action 16.8.201 

17.8.131 Enforcement Procedures – Appeal to Board 16.8.202 

17.8.140 Rehearing Procedures – Form and Filing of Petition 16.8.302 

17.8.141 Rehearing Procedures – Filing Requirements 16.8.303 

17.8.142 Rehearing Procedures – Board Review 16.8.304 

Sub-chapter 2 – Ambient Air Quality 

17.8.201 Definitions 16.8.806 

17.8.202 Incorporation by Reference 16.8.823 

17.8.204 Ambient Air Monitoring 16.8.807 

17.8.205 Enforceability 16.8.808 

17.8.206 Methods and Data 16.8.809 

17.8.210 Ambient Air Quality Standards for Sulfur Dioxide 16.8.820 

17.8.211 Ambient Air Quality Standards for Nitrogen Dioxide 16.8.816 

17.8.212 Ambient Air Quality Standards for Carbon Monoxide 16.8.811 

17.8.213 Ambient Air Quality Standards for Ozone 16.8.817 

17.8.214 Ambient Air Quality Standards for Hydrogen Sulfide 16.8.814 

17.8.220 Ambient Air Quality Standards for Settled Particulate Matter 16.8.818 

17.8.221 Ambient Air Quality Standards for Visibility 16.8.822 

17.8.222 Ambient Air Quality Standards for Lead 16.8.815 

17.8.223 Ambient Air Quality Standards for PM-10 16.8.821 

17.8.230 Fluoride in Forage 16.8.813 

Sub-chapter 3 – Emission Standards 

17.8.301 Definitions 16.8.1430 

17.8.302 Incorporation by Reference 16.8.1429 

17.8.304 Visible Air Contaminants 16.8.1404 

17.8.308 Particulate Matter, Airborne 16.8.1401 

17.8.309 Particulate Matter, Fuel Burning Equipment 16.8.1402 

17.8.310 Particulate Matter, Industrial Processes 16.8.1403 

17.8.315 Odors 16.8.1427 

17.8.316 Incinerators 16.8.1406 

Permit Number: OP2655-00 A-1 Date of Decision:05/21/03

Effective Date: 06/21/03
17.8.320 Wood-Waste Burners 16.8.1407 

17.8.321 Kraft Pulp Mills 16.8.1413 

17.8.322 Sulfur Oxide Emissions – Sulfur in Fuel 16.8.1411 

17.8.323 Sulfur Oxide Emissions – Primary Copper Smelters 16.8.1412 

17.8.324 Hydrocarbon Emissions – Petroleum Products 16.8.1425 

17.8.325 Motor Vehicles 16.8.1426 

17.8.326 Prohibited Materials for Wood or Coal Residential Stoves 16.8.1428 

17.8.330 Emission Standards for Existing Aluminum Plants- Definitions 16.8.1501 

17.8.331 Emission Standards for Existing Aluminum Plants- Standards for Fluoride 16.8.1502 

17.8.332 Emission Standards for Existing Aluminum Plants- Standard 16.8.1503 

17.8.333 Emission Standards for Existing Aluminum Plants 

- Monitoring and Reporting 16.8.1504 

17.8.334 Emission Standards for Existing Aluminum Plants - Startup and Shutdown 16.8.1505 

17.8.340 Standard of Performance for New Stationary Sources 16.8.1423 

17.8.341 Emission Standards for Hazardous Air Pollutants 16.8.1424 

17.8.342 Emission Standards for Hazardous Air Pollutants for Source Categories 16.8.1431 

Sub-chapter 4 – Stack Heights and Dispersion Techniques

17.8.401 Definitions 16.8.1204 

17.8.402 Requirements 16.8.1205 

17.8.403 Exemptions 16.8.1206 

Sub-chapter 5 – Air Quality Permit Application, Operation, and Open Burning Fees 

17.8.501 Definitions 16.8.1901 

17.8.504 Air Quality Permit Application Fees 16.8.1905 

17.8.505 Air Quality Operation Fees 16.8.1903 

17.8.510 Annual Review 16.8.1902 

17.8.511 Air Quality Permit Application/Operation Fee 16.8.1906 

17.8.514 Air Quality Open Burning Fees 16.8.1907 

17.8.515 Air Quality Open Burning Fees for Conditional, Emergency, Christmas 

Tree Waste, and Commercial Film Production Open Burning Permits 16.8.1908 

Sub-chapter 6 – Open Burning 

17.8.601 Definitions 16.8.1301 

17.8.602 Incorporation by Reference 16.8.1311 

17.8.604 Prohibited Open Burning – When Permit Required 16.8.1302 

17.8.605 Special Burning Periods 16.8.1305 

17.8.606 Minor Open Burning Source Requirements 16.8.1303 

17.8.610 Major Open Burning Source Restrictions 16.8.1304 

17.8.611 Emergency Open Burning Permits 16.8.1308 

17.8.612 Conditional Air Quality Open Burning Permits 16.8.1307 

17.8.613 Christmas Tree Waste Open Burning Permits 16.8.1309 

17.8.614 Commercial Film Production Open Burning Permits 16.8.1310 

17.8.615 Firefighter Training 16.8.1306 

Sub-chapter 7 – Permit, Construction and Operation of Air Contaminant Sources 

17.8.701 Definitions 16.8.1101 

17.8.702 Incorporation by Reference 16.8.1120 

17.8.704 General Procedures for Air Quality Preconstruction Permitting 16.8.1119 

17.8.705 When Permit Required – Exclusions 16.8.1102 

17.8.706 New or Altered Sources and Stacks – Permit Application Requirements 16.8.1105 

17.8.707 Waivers 16.8.1118 

17.8.708 Notification of Emissions Increase 16.8.1121 

17.8.710 Conditions for Issuance of Permit 16.8.1109 

17.8.715 Emission Control Requirements 16.8.1103 

17.8.716 Inspection of Permit 16.8.1115 

17.8.717 Compliance with Other Statutes and Rules 16.8.1117 

Permit Number: OP2655-00 A-2 Date of Decision:05/21/03

Effective Date: 06/21/03
17.8.720 Public Review of Permit Application 16.8.1107 

17.8.730 Denial of Permit 16.8.1110 

17.8.731 Duration of Permit 16.8.1111 

17.8.732 Revocation of Permit 16.8.1112 

17.8.733 Modification of Permit 16.8.1113 

17.8.734 Transfer of Permit 16.8.1114 

Sub-chapter 8 – Prevention of Significant Deterioration of Air Quality

17.8.801 Definitions 16.8.945 

17.8.802 Incorporation by Reference 16.8.946 

17.8.804 Ambient Air Increments 16.8.947 

17.8.805 Ambient Air Ceilings 16.8.948 

17.8.806 Restrictions on Area Classifications 16.8.949 

17.8.807 Exclusions From Increment Consumption 16.8.950 

17.8.808 Redesignation 16.8.951 

17.8.809 Stack Heights 16.8.952 

17.8.818 Review of Major Stationary Sources and Major Modification

– Source Applicability and Exemptions 16.8.953 

17.8.819 Control Technology Review 16.8.954 

17.8.820 Source Impact Analysis 16.8.955 

17.8.821 Air Quality Models 16.8.956 

17.8.822 Air Quality Analysis 16.8.957 

17.8.823 Source Information 16.8.958 

17.8.824 Additional Impact Analyses 16.8.959 

17.8.825 Sources Impacting Federal Class I Areas – Additional 16.8.960 

17.8.826 Public Participation 16.8.961 

17.8.827 Source Obligation 16.8.962 

17.8.828 Innovative Control Technology 16.8.963 

Sub-chapter 9 – Permit Requirements for Major Stationary Sources or Major Modifications Located Within

Nonattainment Areas 

17.8.901 Definitions 16.8.1701 

17.8.902 Incorporation by Reference 16.8.1702 

17.8.904 When Air Quality Preconstruction Permit Required 16.8.1703 

17.8.905 Additional Conditions of Air Quality Preconstruction Permit 16.8.1704 

17.8.906 Baseline for Determining Credit for Emissions and Air Quality Offsets 16.8.1705 

Sub-chapter 10 – Preconstruction Permit Requirements for Major Stationary Sources or Major Modifications

Located Within Attainment or Unclassified Areas 

17.8.1001 Definitions 16.8.1801 

17.8.1002 Incorporation by Reference 16.8.1802 

17.8.1004 When Air Quality Preconstruction Permit Required 16.8.1803 

17.8.1005 Additional Conditions of Air Quality Preconstruction Permit 16.8.1804 

17.8.1006 Review of Specified Sources for Air Quality Impact 16.8.1805 

17.8.1007 Baseline for Determining Credit for Emissions and Air Quality Offsets 16.8.1806 

Sub-chapter 11 – Visibility Impact Assessment 

17.8.1101 Definitions 16.8.1002 

17.8.1102 Incorporation by Reference 16.8.1009 

17.8.1103 Applicability – Visibility Requirements 16.8.1001 

17.8.1106 Visibility Impact Analysis 16.8.1003 

17.8.1107 Visibility Models 16.8.1004 

17.8.1108 Notification of Permit Application 16.8.1005 

17.8.1109 Adverse Impact of Federal Land Manager 16.8.1006 

17.8.1110 Visibility Monitoring 16.8.1007 

17.8.1111 Additional Impact Analysis 16.8.1008 

Permit Number: OP2655-00 A-3 Date of Decision:05/21/03

Effective Date: 06/21/03
Sub-chapter 12 – Operating Permit Program

17.8.1201 Definitions 16.8.2002 

17.8.1202 Incorporation by Reference 16.8.2003 

17.8.1203 Air Quality Operating Permit Program Overview 16.8.2001 

17.8.1204 Air Quality Operating Permit Program Applicability 16.8.2004 

17.8.1205 Requirements for Timely and Complete Air Quality Permit Applications 16.8.2005 

17.8.1206 Information Required for Air Quality Operating Permit Applications 16.8.2006 

17.8.1207 Certification of Truth, Accuracy, and Completeness 16.8.2007 

17.8.1210 General Requirements for Air Quality Operating Permit Content 16.8.2008 

17.8.1211 Requirements for Air Quality Operating Permit Content Relating to 

Emission Limitations and Standards, and Other Requirements 16.8.2009 

17.8.1212 Requirements for Air Quality Operating Permit Content Relating 

to Monitoring, Recordkeeping and Reporting 16.8.2010 

17.8.1213 Requirements for Air Quality Operating Permit Content Relating to 

Compliance 16.8.2011 

17.8.1214 Requirements for Air Quality Operating Permit Content 

Relating to the Permit Shield and Emergencies 16.8.2012 

17.8.1215 Requirements for Air Quality Operating Permit Content Relating 

to Operational Flexibility 16.8.2013 

17.8.1220 Air Quality Operating Permit Issuance, Renewal, Reopening and 

Modification 16.8.2014 

17.8.1221 Operation Without an Air Quality Operating Permit and Application Shield 16.8.2015 

17.8.1222 General Air Quality Operating Permits 16.8.2016 

17.8.1223 Temporary Air Quality Operating Permits 16.8.2017 

17.8.1224 Additional Requirements for Operational Flexibility and Air Quality

Operating Permit Changes that do not Require Revisions 16.8.2018 

17.8.1225 Additional Requirements for Air Quality Operating Permit Amendments 16.8.2019 

17.8.1226 Additional Requirements for Minor Air Quality Operating Permit 

Modifications 16.8.2020 

17.8.1227 Additional Requirements for Significant Air Quality Operating Permit 

Modifications 16.8.2021 

17.8.1228 Additional Requirements for Air Quality Operating Permit Revocation, 

Reopening and Revision for Cause 16.8.2022 

17.8.1231 Notice of Termination, Modification, or Revocation and Reissuance

by the Administrator for Cause 16.8.2023 

17.8.1232 Public Participation 16.8.2024 

17.8.1233 Permit Review by the Administrator and Affected States 16.8.2025 

17.8.1234 Acid Rain – Permit Regulation 16.8.2026 

 

Chapter 80 – Air and Water Quality – Tax Certification 

Sub-chapter 1 – Tax Certification for Pollution Control Equipment 

17.80.101 Definitions 16.9.101 

17.80.102 Application for Certification as Air or Water Pollution Equipment 16.9.102 

17.80.103 Eligibility Criteria 16.9.103 

17.80.104 Apportionment Procedures 16.9.104 

17.80.105 Compliance 16.9.105 

17.80.106 Informal Conference 16.9.106 

Permit Number: OP2655-00 A-4 Date of Decision:05/21/03

Effective Date: 06/21/03
Permit Number: OP2655-01 B-1 Date of Decision: 05/21/03 

Effective Date: 06/21/03

Appendix B - INSIGNIFICANT EMISSION UNITS 

Disclaimer: The information in this appendix is not State or Federally enforceable, but is presented to assist 

CFAC, the permitting authority, inspectors, and the public. 

Pursuant to ARM 17.8.1201(22)(a), an insignificant emission unit means any activity or emission unit located 

within a source that: (i) has a potential to emit less than 5 tons per year of any regulated pollutant; (ii) has a 

potential to emit less than 500 pounds per year of lead; (iii) has a potential to emit less than 500 pounds per 

year of hazardous air pollutants listed pursuant to section 7412 (b) of the FCAA; and (iv) is not regulated by an 

applicable requirement, other than a generally applicable requirement that applies to all emission units subject 

to Subchapter 12. 

List of Insignificant Activities:

The following table of insignificant sources and/or activities were provided by CFAC. Because there are no 

requirements to update such a list, the emission units and/or activities may change from those specified in the 

table. 

Emission Unit ID Description 

IEU03 Collector Bar Shotblasting - CR02 

IEU04 Anode Debris Storage - CR05 

IEU05 Anode Abrader - CR06 

IEU06 Shed 11 Pot Rebuild / Masonry Mixer - CR08 

IEU07 Diesel Storage Tanks - MP03 

IEU08 Natural Gas Space Heaters - MP06 

IEU09 Open Burning - MP10 

IEU10 Plant Site Sanitary Landfill - MP13 

IEU11 Propane Storage - MP14 

IEU12 Waste Oil Heat Recovery - MP18 

IEU13 MSDS Chemicals / Plant-wide Usage - MP19 

IEU14 Carpenter Shop Cyclone 
Permit Number: OP2655-01 C-1 Date of Decision: 05/21/03 

Effective Date: 06/21/03

Appendix C - DEFINITIONS and ABBREVIATIONS 

"Act" means the Clean Air Act, as amended, 42 U.S. 7401, et seq. 

"Administrative permit amendment" means an air quality operating permit revision that: 

(a) Corrects typographical errors; 

(b) Identifies a change in the name, address or phone number of any person identified in the air 

quality operating permit, or identifies a similar minor administrative change at the source; 

(c) Requires more frequent monitoring or reporting by CFAC; 

(d) Requires changes in monitoring or reporting requirements that the Department deems to be no 

less stringent than current monitoring or reporting requirements; 

(e) Allows for a change in ownership or operational control of a source if the Department has 

determined that no other change in the air quality operating permit is necessary, consistent with 

ARM 17.8.1225; or 

(f) Incorporates any other type of change that the Department has determined to be similar to those 

revisions set forth in (a)-(e), above. 

"Applicable requirement" means all of the following as they apply to emission units in a source requiring an 

air quality operating permit (including requirements that have been promulgated or approved by the 

Department or the administrator through rule making at the time of issuance of the air quality operating permit, 

but have future-effective compliance dates, provided that such requirements apply to sources covered under the 

operating permit). 

(a) Any standard, rule, or other requirement, including any requirement contained in a consent decree 

or judicial or administrative order entered into or issued by the Department, that is contained in 

the Montana state implementation plan approved or promulgated by the administrator through 

rule making under Title I of the FCAA; 

(b) Any federally enforceable term, condition or other requirement of any air quality preconstruction 

permit issued by the Department under subchapters 7, 8, 9 and 10 of this chapter, or pursuant to 

regulations approved or promulgated through rule making under Title I of the FCAA, including 

parts C and D; 

(c) Any standard or other requirement under sec. 7411 of the FCAA, including sec. 7411(d); 

(d) Any standard or other requirement under sec. 7412 of the FCAA, including any requirement 

concerning accident prevention under sec. 7412(r)(7), but excluding the contents of any risk 

management plan required under sec. 7412(r); 

(e) Any standard or other requirement of the acid rain program under Title IV of the FCAA or 

regulations promulgated thereunder; 

(f) Any requirements established pursuant to sec. 7661c(b) or sec. 7414(a)(3) of the FCAA; 

(g) Any standard or other requirement governing solid waste incineration, under sec. 7429 of the 

FCAA; 

(h) Any standard or other requirement for consumer and commercial products, under sec. 7511b(e) of 

the FCAA; 
Permit Number: OP2655-01 C-2 Date of Decision: 05/21/03 

Effective Date: 06/21/03

(i) Any standard or other requirement for tank vessels, under sec. 7511b(f) of the FCAA; 

(j) Any standard or other requirement of the regulations promulgated to protect stratospheric ozone 

under Title VI of the FCAA, unless the administrator determines that such requirements need not 

be contained in an air quality operating permit; 

(k) Any national ambient air quality standard or increment or visibility requirement under part C of 

Title I of the FCAA, but only as it would apply to temporary sources permitted pursuant to sec. 

7661c(e) of the FCAA; or 

(l) Any federally enforceable term or condition of any air quality open burning permit issued by the 

Department under subchapter 6. 

"Department" means the Montana Department of Environmental Quality. 

"Emission unit" means any part or activity of a stationary source that emits or has the potential to emit any 

regulated air pollutant or any pollutant listed under sec. 7412(b) of the FCAA. This term is not meant to alter 

or affect the definition of the term "unit" for purposes of Title IV of the FCAA. 

“Excess emissions” means any visible emissions from a stack or source, viewed during the visual surveys, 

believed to exceed the visible emissions during normal operating conditions. 

“Excess fugitive emissions” means any visible emissions that leave the plant site boundaries. 

"FCAA" means the Federal Clean Air Act, as amended. 

"Federally enforceable" means all limitations and conditions which are enforceable by the administrator, 

including those requirements developed pursuant to 40 CFR Parts 60 and 61, requirements within the Montana 

State Implementation Plan, and any permit requirement established pursuant to 40 CFR 52.21 or under 

regulations approved pursuant to 40 CFR Part 51, Subpart I, including operating permits issued under an EPA 

approved program that is incorporated into the Montana State Implementation Plan and expressly requires 

adherence to any permit issued under such program. 

"Fugitive emissions" means those emissions that could not reasonably pass through a stack, chimney, vent, or 

other functionally equivalent opening. 

"General air quality operating permit" or "general permit" means an air quality operating permit that 

meets the requirements of ARM 17.8.1222, covers multiple sources in a source category, and is issued in lieu 

of individual permits being issued to each source. 

"Hazardous air pollutant" means any air pollutant listed as a hazardous air pollutant pursuant to section 

112(b) of the FCAA. 

"Non-federally enforceable requirement" means the following as they apply to emission units in a source 

requiring an air quality operating permit. 

(a) Any standard, rule, or other requirement, including any requirement contained in a consent 

decree, or judicial or administrative order entered into or issued by the Department, that is not 

contained in the Montana State Implementation Plan, approved or promulgated by the 

administrator through rule making under Title I of the FCAA; 

(b) Any term, condition or other requirement contained in any air quality preconstruction permit 

issued by the Department under subchapters 7, 8, 9 and 10 of this chapter that is not federally 

enforceable; 

(c) Does not include any Montana ambient air quality standard contained in Subchapter 2 of this 

chapter. 
Permit Number: OP2655-01 C-3 Date of Decision: 05/21/03 

Effective Date: 06/21/03

"Permittee" means the owner or operator of any source subject to the permitting requirements of this 

subchapter, as provided in ARM 17.8.1204, that holds a valid air quality operating permit or has submitted a 

timely and complete permit application for issuance, renewal, amendment, or modification pursuant to this 

subchapter. 

"Regulated air pollutant" means the following: 

(a) Nitrogen oxides or any volatile organic compounds. 

(b) Any pollutant for which a national ambient air quality standard has been promulgated. 

(c) Any pollutant that is subject to any standard promulgated under sec. 7411 of the FCAA. 

(d) Any Class I or II substance subject to a standard promulgated under or established by Title VI of 

the FCAA. 

(e) Any pollutant subject to a standard or other requirement established or promulgated under sec. 

7412 of the FCAA, including but not limited to the following: 

(i) Any pollutant subject to requirements under sec. 7412(j) of the FCAA. If the administrator 

fails to promulgate a standard by the date established in section 7412(e) of the FCAA, any 

pollutant for which a subject source would be major shall be considered to be regulated on the 

date 18 months after the applicable date established in section 7412(e) of the FCAA. 

(ii) Any pollutant for which the requirements of section 7412(g)(2) of the FCAA have been met 

but only with respect to the individual source subject to sec. 7412(g)(2) requirement. 

"Responsible official" means one of the following: 

(a) For a corporation: a president, secretary, treasurer, or vice-president of the corporation in charge 

of a principal business function, or any other person who performs similar policy or decisionmaking functions for the corporation, or a duly authorized representative of such person if the 

representative is responsible for the overall operation of one or more manufacturing, production, 

or operating facilities applying for or subject to a permit and either: 

(i) The facilities employ more than 250 persons or have gross annual sales or expenditures 

exceeding $25 million (in second quarter 1980 dollars); or 

(ii) The delegation of authority to such representative is approved in advance by the Department. 

(b) For a partnership or sole proprietorship: a general partner or the proprietor; respectively. 

(c) For a municipality, state, federal, or other public agency: either a principal executive officer or 

ranking elected official. For the purposes of this part, a principal executive officer of a federal 

agency includes the chief executive officer having responsibility for the overall operations of a 

principal geographic unit of the agency (e.g., a regional administrator of the environmental 

protection agency). 

(d) For affected sources: the designated representative in so far as actions, standards, requirements, or 

prohibitions under Title IV of the FCAA or the regulations promulgated thereunder are 

concerned, and the designated representative for any other purposes under this subchapter. 
Permit Number: OP2655-01 C-4 Date of Decision: 05/21/03 

Effective Date: 06/21/03

Abbreviations:

ARM Administrative Rules of Montana 

ASTM American Society of Testing Materials 

BACT Best Available Control Technology 

BDT bone dry tons 

BTU British Thermal Unit 

CFR Code of Federal Regulations 

CO carbon monoxide 

DEQ Department of Environmental Quality 

dscf dry standard cubic foot 

dscfm dry standard cubic foot per minute 

EEAP Emergency Episode Action Plan 

EPA U.S. Environmental Protection Agency 

EPA Method Test methods contained in 40 CFR 60, Appendix A 

EU emission unit 

FCAA Federal Clean Air Act 

gr grains 

HAP hazardous air pollutant 

IEU insignificant emission unit 

Mbdft thousand board feet 

Method 5 40 CFR 60, Appendix A, Method 5 

Method 9 40 CFR 60, Appendix A, Method 9 

MMbdft million board feet 

MMBTU million British Thermal Units 

NOx oxides of nitrogen 

NO2 nitrogen dioxide 

O2 oxygen 

Pb lead 

PM particulate matter 

PM10 particulate matter less than 10 microns in size 

psi pounds per square inch 

scf standard cubic feet 

SIC Source Industrial Classification 

SO2 sulfur dioxide 

SOx oxides of sulfur 

tpy tons per year 

U.S.C. United States Code 

VE visible emissions 

VOC volatile organic compound 
Permit Number: OP2655-01 D-1 Date of Decision: 05/21/03 

Effective Date: 06/21/03

Appendix D - NOTIFICATION ADDRESSES 

Compliance Notifications: 

Montana Department of Environmental Quality 

Permitting and Compliance Division 

Air & Waste Management Bureau 

P.O. Box 200901 

Helena, MT 59620-0901 

United States EPA 

Air Program Coordinator 

Region VIII, Montana Office 

10 W. 15th Suite 3200 

Helena, MT 59626 

Permit Modifications: 

Montana Department of Environmental Quality 

Permitting and Compliance Division 

Air & Waste Management Bureau 

P.O. Box 200901 

Helena, MT 59620-0901 

Office of Partnerships and Regulatory Assistance 

Air and Radiation Program 

US EPA Region VIII 8P-AR 

999 18th Street, Suite 500 

Denver, CO 80202-2466 
Permit Number: OP2655-01 E-1 Date of Decision: 05/21/03 

Effective Date: 06/21/03 

1. 

2. 

3. 

Appendix E - AIR QUALITY INSPECTOR INFORMATION 

Disclaimer: The information in this appendix is not State or Federally enforceable but is presented to 

assist CFAC, permitting authority, inspectors, and the public. 

Direction to Plant: 

 CFAC is adjacent to the community of Columbia Falls, Montana, with a physical address of 2000 

Aluminum Drive. 

Safety Equipment Required:

Safety Equipment required to enter the facility are: hard hat, protective eyewear, and safety shoes or boots. 

Additional personal protective equipment may be necessary in certain areas, such as respiratory protection. 

Facility Plot Plan:

 A copy of the facility plot plan was submitted with the operating permit application on June 12, 1996. 
Permit Number: OP2655-01 F-1 Date of Decision: 05/21/03 

Effective Date: 06/21/03 

Appendix F - CFAC MACT IMPLEMENTATION PLAN 

Although the hard copy of Appendix F have been removed from the permit, the contents of Appendix F, 

CFAC MACT Implementation Plan remain as applicable requirements as stated in the Title V Operating 

Permit #OP2655-01. To receive a hard copy of this appendix, please contact one of the following: 

The Department of Environmental Quality 

Permitting and Compliance Division 

Air and Waste Management Bureau 

1520 E. Sixth Ave. 

P.O. Box 200901 

Helena, Montana 59620-0901 

Bureau Phone # : (406) 444-3490 

OR 

Columbia Falls Aluminum Company, LLC 

2000 Aluminum Drive 

Columbia Falls, Montana 59912 

Phone # : (406) 892-8211 
Permit Number: OP2655-01 G-1 Date of Decision: 05/21/03 

Effective Date: 06/21/03 

Appendix G - CFAC MACT QUICK REFERENCE GUIDE 

Although the hard copy of Appendix G have been removed from the permit, the contents of Appendix G, 

CFAC MACT Quick Reference Guide remain as applicable requirements as stated in the Title V Operating 

Permit #OP2655-01. To receive a hard copy of this appendix, please contact one of the following: 

The Department of Environmental Quality 

Permitting and Compliance Division 

Air and Waste Management Bureau 

1520 E. Sixth Ave. 

P.O. Box 200901 

Helena, Montana 59620-0901 

Bureau Phone # : (406) 444-3490 

OR 

Columbia Falls Aluminum Company, LLC 

2000 Aluminum Drive 

Columbia Falls, Montana 59912 

Phone # : (406) 892-8211 
Permit Number: OP2655-01 H-1 Date of Decision: 05/21/03 

Effective Date: 06/21/03 

Appendix H - STARTUP, SHUTDOWN AND MALFUNCTION PLAN (SSM) 

Although the hard copy of Appendix H have been removed from the permit, the contents of Appendix H, 

Startup, Shutdown and Malfunction Plan (SSM) remain as applicable requirements as stated in the Title V 

Operating Permit #OP2655-01. To receive a hard copy of this appendix, please contact one of the following: 

The Department of Environmental Quality 

Permitting and Compliance Division 

Air and Waste Management Bureau 

1520 E. Sixth Ave. 

P.O. Box 200901 

Helena, Montana 59620-0901 

Bureau Phone # : (406) 444-3490 

OR 

Columbia Falls Aluminum Company, LLC 

2000 Aluminum Drive 

Columbia Falls, Montana 59912 

Phone # : (406) 892-8211 
Permit Number: OP2655-01 I-1 Date of Decision: 05/21/03 

Effective Date: 06/21/03

Appendix I - CFAC POM Compliance Schedule 

CFAC has been shut down since January 2001. However, at the time of shutdown, CFAC was out of 

compliance with the applicable requirement ARM 17.8.342 ((40 CFR 63.843(a) and 63.846(b)). Therefore, 

CFAC was/is required to submit a narrative description of how the source will achieve compliance and provide 

a schedule of compliance (ARM 17.8.1206). 

1. CFAC shall submit a summary and status report of the POM testing and compliance issues to the 

Department and EPA within 60 days after final issuance of Permit #OP2655-00. The report shall 

include the facility’s description to either request EPA to revise the existing VSS2 POM emission 

limit, and all supporting documentation that is the basis for the decision. CFAC shall submit detailed 

progress reports quarterly to the Department and EPA. 

2. Within 60 days after final issuance of Permit #OP2655-00, CAFC shall submit to the Department a 

plan, including a schedule, describing actions CFAC will take leading to compliance with 40 CFR 63, 

Subpart LL (Primary Aluminum Reduction Plants MACT). 

3. Within 180 days after startup (of the first pot), CFAC must demonstrate compliance with the VSS2 

POM emission limit in effect at that time. 
Permit Number: OP2655-01 J-1 Date of Decision: 05/21/03 

Effective Date: 06/21/03 

Appendix J - POTLINE ROOF VENT OPACITY COMPLIANCE DEMONSTRATION 

Proposal to Perform Method 9 Visual Observations on Potroom Roofs 

CFAC proposes to perform Method 9 visual observations on portions of each potline’s roof in order to 

demonstrate compliance with ARM 17.8.332. This is similar in concept to EPA Method 14 where a manifold 

extracts emissions from either a 35-meter (115 feet) length of a roofline, or from 8% length of the roofline to 

determine compliance with emission standards for the entire potline. CFAC proposes to perform Method 9 

observations on the following roofs: 

Approximately 50% of Room 1 length (457 ft, representing potline 1) 

Approximately 35% of Room 3 length (321 ft, representing potline 2) 

Approximately 35% of Room 6 length (321 ft, representing potline 3) 

Approximately 35% of Room 7 length (321 ft, representing potline 4) 

Approximately 35% of Room 10 length (321 ft, representing potline 5) 

Specifically, CFAC proposes to demonstrate compliance with ARM 17.8.332 by performing quarterly Method 

9 visual observations as described below. Each Method 9 observation period will be a minimum of 6 minutes 

unless any one reading is greater than 10%; then the observation period will be a minimum of 20 minutes. 

Room 1 (potline 1): Method 9 observations will be taken by an observer located on the Room 2 roof, 

looking westward. Method 9 observations will be taken at more than one location along the north 

50% of Room 1. The Method 9 observation results will be averaged to produce a final result. 

Room 3 (potline 2): Method 9 observations will be taken by an observer located on the staircase to 

the Room 4 roof. The west plant ore silos will serve as a backdrop for the Method 9 observations. 

The ore silos provide a backdrop, which is approximately 321 feet, or approximately 35% of the total 

length of the Room 3 roof. Method 9 observations will be taken at more than one location along the 

north 35% of Room 3. The Method 9 observation results will be averaged to produce a final result. 

Room 6 (potline 3): Method 9 observations will be taken by an observer located on the staircase to 

the Room 5 roof. The east plant ore silos will serve as a backdrop for the Method 9 observations. The 

ore silos provide a backdrop, which is approximately 321 feet, or approximately 35% of the total 

length of the Room 6 roof. Method 9 observations will be taken at more than one location along the 

north 35% of Room 3. The Method 9 observation results will be averaged to produce a final result. 

Room 7 (potline 4): Method 9 observations will be taken by an observer located on the staircase to 

the Room 8 roof. The east plant ore silos will serve as a backdrop for the Method 9 observations. The 

ore silos provide a backdrop, which is approximately 321 feet, or approximately 35% of the total 

length of the Room 7 roof. Method 9 observations will be taken at more than one location along the 

north 35% of Room 7. The Method 9 observation results will be averaged to produce a final result. 

Room 10 (potline 5): Method 9 observations will be taken by an observer located on the staircase to 

the Room 9 roof, looking eastward. Method 9 observations will be taken at more than one location 

along the north 35% of Room 10. The Method 9 observation results will be averaged to produce a 

final result. 

CFAC shall perform daily visual surveys in a manner similar to the Method 9 procedures outlined 

above and it is understood by all parties that these daily visual observations are not Method 9 

observations. 
Permit Number: OP2655-01 K-1 Date of Decision: 05/21/03 

Effective Date: 06/21/03 

Appendix K - Pollution Control Device Inspection and Maintenance Plan 

Although the hard copy of Appendix K have been removed from the permit, the contents of Appendix K 

Pollution Control Device Inspection and Maintenance Plan remain as applicable requirements as stated in the 

Title V Operating Permit #OP2655-01. To receive a hard copy of this appendix, please contact one of the 

following: 

The Department of Environmental Quality 

Permitting and Compliance Division 

Air and Waste Management Bureau 

1520 E. Sixth Ave. 

P.O. Box 200901 

Helena, Montana 59620-0901 

Bureau Phone # : (406) 444-3490 

OR 

Columbia Falls Aluminum Company, LLC 

2000 Aluminum Drive 

Columbia Falls, Montana 59912 

Phone # : (406) 892-8211 
Permit Number: OP2655-01 L-1 Date of Decision: 05/21/03 

Effective Date: 06/21/03 

Appendix L - 62 FR 52383