### POLYCYCLIC ORGANIC MATTER (POM) TEST REPORT
(as determined by methylene chloride extractable ma tter – EPA Method 315)



### A NODE 

### B AKING 

### F URNACE 

### (A-446)

Performed for:



### ALCAN PRIMARY PRODUCTS CORPORATION

SEBREE WORKS

9404 State Route 2096 Robards, KY 42452

June 5 – 7, 2012

Submitted by:

Air Quality Services, LLC

425 Main Street Evansville, IN 47708 Phone: (812) 452-4785 Fax: (812) 452-4786

AQS Project# 12662-21-001ii



## SOURCE TESTING REPORT CERTIFICATION

Air Quality Services, LLC

425 Main Street Evansville, Indiana 47708 Phone: (812) 452-4785 Fax: (812) 452-4786

Reproducing portions of this test report may omit c ritical substantiating documentation

or be taken out of context and due care should be e xercised in this regard.

I have prepared and reviewed this report and found the information accurate and complete to the best of my ability.

Report Writer

_________________________________ Date_____________

_______ Stephen R. Endress Air Quality Services, LLC

Report Reviewer

_________________________________ Date_____________

_______ Daniel L. Todd, QEP, CHMM Air Quality Services, LLC July 24, 2012

July 24, 2012iii TABLE OF CONTENTS

Page

SECTION 1 EXECUTIVE SUMMARY ....................... ......................................1

SECTION 2 INTRODUCTION ............................ ...............................................2

SECTION 3 SUMMARY OF TEST RESULTS................. .................................3

SECTION 4 PROCESS DESCRIPTION ..................... ........................................5

SECTION 5 SAMPLING AND ANALYTICAL PROCEDURES...... ................6

Location of Measurement Sites .................. .................................6 Stack Gas Velocity and Volumetric Flow Rate .... .......................6 Stack Gas Oxygen and Carbon Dioxide Content.... .....................6

Stack Gas Moisture Content ......................... ...............................7 Methylene Chloride Extractable Matter.......... .............................7

Performance Audits ............................. ........................................7

SECTION 6 QUALITY ASSURANCE / QUALITY CONTROL .... ...............10

APPENDIX A - EXAMPLE CALCULATIONS

APPENDIX B - DATA SUMMARY

APPENDIX C - FIELD DATA

APPENDIX D - LABORATORY DATA APPENDIX E - QUALITY ASSURANCE / QUALITY CONTROLiv LIST OF TABLES

Table Page

1.1 Test Results................................

................................................... ...............1

2.1 Test Program Contacts......................

................................................... ........2

3.1 Summary of Stack Gas Parameters and Test Re sults ..................................4

6.1 Field Equipment Calibration Summary ........ .............................................10

LIST OF FIGURES

Figure Page

5.1 Method 5/13B Stack Sampling Train ............. .............................................8

5.2 Schematic of Sample Locations................

................................................... 9

LIST OF ABBREVIATIONS

acfm actual cubic feet per minute dscfm dry standard cubic feet per minute gr/dscf grains per dry standard cubic foot lb/dscf pound(s) per dry standard cubic foot lb/hr pound(s) per hour fps feet per secondPage 1 of 11 AQS Project# 12662-21-001 SECTION 1

EXECUTIVE SUMMARY

On June 5 – 7, 2012, stack testing for polycyclic o rganic matter (POM) was performed on the

three reactor stacks which exhaust the scrubber of the Anode Baking Furnace (also known as A-446). Testing was conducted at Alcan Primary Pro ducts Corporation, Sebree Works in Robards, Kentucky (Source ID # 21-101-00029).

These tests followed the procedures for EPA Methods 1, 2, 3, and 4 (as specified in 40 CFR 60, Appendix A), and EPA Method 315 (as specified i n 40 CFR 63, Appendix A).

The results of the emissions tests are summarized b elow:

TABLE 1.1

TEST RESULTS

Location POM Controlled

Emission Rate, lbs/ton of green anode POM Controlled

Emission Limit 1

, lbs/ton of green anode

A-446 0.0196 0.18

The green anode throughput during the month of June was 10,674 tons, which averages 14.825 tons per hour.

1 Permit # V-05-088 § B, Subject Item 6, Condition 2 .dPage 2 of 11 AQS Project# 12662-21-001 SECTION 2

INTRODUCTION

Alcan Primary Products Corporation retained Air Qua lity Services, LLC (AQS) to plan and conduct a testing program to determine POM on the b aking furnace exhausts that are connected to the carbon bake dry alumina scrubber a t the Sebree, Kentucky facility, which is part of the Anode Baking Furnace A-446. The tests were conducted on June 5 – 7, 2012.

Testing was conducted to fulfill the permit require d testing under Permit Number V-05-088 R1, Section B, Subject Item 6 Requirements, Conditi on 3 Testing Requirements: b.

The sampling was conducted using EPA Methods 1, 2, 3, 4, and 315 to determine stack sample traverse locations, velocity and volumetric flow rates, molecular weight, moisture content, and methylene chloride extractable matter (MCEM) concentrations, respectively. For the purposes of this test program, the MCEM det ermined by Method 315 is represented as POM. Mr. Neal Stewart, of AQS, performed the sa mpling procedures. Mr. Brandon Coomes, of Alcan Primary Products Corporation, coor dinated the production rate with the testing schedule. There were no agency observers a t this testing program.

The contacts for this test program were as follows:

TABLE 2.1

TEST PROGRAM CONTACTS

Alcan Primary Products Corporation

Sebree Works:

Mr. Brandon Coomes

9404 State Route 2096 Robards, KY 42452 Phone: (270) 521-7454 Fax: (270) 521-7455

E-mail: brandon.coomes@riotinto.com Air Quality Services, LLC:

Mr. Dan Todd / Neal Stewart

425 Main Street Evansville, IN 47708 Phone: (812) 452-4785 Fax: (812) 452-4786 E-mail: dtodd@aqsllc.net nstewart@aqsllc.netPage 3 of 11 AQS Project# 12662-21-001 SECTION 3

SUMMARY OF TEST RESULTS

The testing program at Alcan Primary Products Corpo ration was performed on June 5 – 7, 2012. POM was collected by EPA Test Method 315, a procedure in which MCEM is collected and recovered in a sampling train. For t he purposes of this test program, the MCEM determined by Method 315 is represented as POM . Sample collection and laboratory analyses utilized the applicable procedures as publ ished in the Code of Federal Regulations, Title 40, Part 60, (40 CFR 60) Appendix A and 40 CF R 63, Appendix A.

There are a total of three stacks – one stack per s crubber reactor – that comprise the emission points of the Anode Baking Furnace dry scrubber/bag house system. Testing was conducted above the baghouse in three identical, vertical, ci rcular stacks with an inside diameter of 50.5 inches each. This test program consisted of three (3) four-hour test runs, one per stack.

During June, the bake furnace had 10,674 tons of gr een anode throughput, which averages 14.825 tons of green anode per hour. The emissions were determined in unit of pounds of POM per hour. The overall emissions were determine d by calculating the sum of the three stacks (lb/hr) and dividing by the process throughp ut (ton/hr), resulting in pounds of POM per ton green anode throughput.

The sum of the emissions from Reactors #1, #2, and #3 represent the Anode Baking Furnace

emissions. The A-446 POM emissions totaled 0.0196 lbs/ton.

The POM results are summarized in Table 3.1. More detailed calculations are included in Appendix A. The individual test results and the fi eld data sheets from each test location are located in Appendices B and C, respectively. Appen dix D contains the laboratory data and analysis.Page 4 of 11AQS Project# 12662-21-001TABLE 3.1SUMMARY OF STACK GAS PARAMETERS AND TEST RESULTSFlow POM EmissionsRunNo.Time DateStackTemp.°FO2%CO2%H2O%Velocityft/sacfm dscfm lbs/hrlbs/tongreen anodeC-1 8:12-12:14 06/05/12175.5 17.0 3.0 9.5 27.9 23,269 17,419 0.057 0.0038C-2 5:59-10:06 06/06/12178.5 17.5 3.0 9.3 35.4 29,524 22,168 0.085 0.0058C-3 6:00-10:02 06/07/12177.5 17.5 3.0 9.7 33.1 27,634 20,705 0.149 0.0100Averages 177.2 17.3 3.0 9.5 32.1 26,809 20,097 0.097 0.0065(June average) Tons green anode throughput/hour = 14.825Total POM Emissions, lb/ton green anode = 0.0196Page 5 of 11 AQS Project# 12662-21-001 SECTION 4

PROCESS DESCRIPTION

The Anode Baking Furnace, also referred to as A-446 , is the oven process from the production of carbon anodes which are used on-site in the potlines. The carbon anodes are a mixture of carbon coke and tar pitch, which is form ed into green anodes in the Green Mill. The green anodes are placed in a ring furnace for a bake cycle, which consists of pre-heating, baking, and cooling. The furnace operates continuo usly with a production rate of approximately 400 anodes per day. After cooling, t he baked anodes are supplied to the potlines for the use in the production process. Th e emissions from the baking furnace are ducted to a dry aluminum scrubber, which cleans the gases emitted by the baking process. The scrubber employs a baghouse to control the part iculate emissions.Page 6 of 11 AQS Project# 12662-21-001 SECTION 5

SAMPLING AND ANALYTICAL PROCEDURES

The sampling and analytical procedures used in this test program were in accordance with EPA Reference Methods 1, 2, 3, 4, 5 and 315, as pub lished in the Code of Federal Regulations, Title 40, Part 60, (40 CFR 60) Appendi x A and 40 CFR 63, Appendix A.

LOCATION OF MEASUREMENT SITES

EPA Method 1, “Sample and Velocity Traverses for St ationary Sources”, was used to select representative measurement points at both test loca tions.

The Anode Baking Furnace exhausts through three ver tical, circular stacks (#1, #2, and #3),

each with an inside diameter of 50.5 inches. The tw o test ports (90o apart) are located 118 inches (2.3 stack diameters) downstream from a dist urbance and 222 inches (4.3 stack diameters) upstream from the exhaust for each stack . For velocity measurements conforming to Method 315, a total of 24 traverse points were u sed for the measurements, 12 per test port. A copy of the field work sheet is included in Appen dix C.

STACK GAS VELOCITY AND VOLUMETRIC FLOW RATE

EPA Method 2, “Stack Gas Velocity and Volumetric Fl ow Rate”, was used to determine volumetric flow rate. A Type “S” Pitot tube, with a standard coefficient of 0.84, and an inclined manometer were used to measure velocity pr essure at both test locations. A calibrated Type “K” thermocouple attached directly to the Pitot tube was used to measure stack gas temperature, which was displayed on a dig ital temperature indicator. The average stack gas velocity was calculated from the average velocity pressure, the average stack gas temperature, stack gas molecular weight and absolut e static pressure. The volumetric flow rate is the product of stack gas velocity and the s tack cross sectional area. See Appendix A for calculated values based on the field data and Appen dix C for field data sheets.

STACK GAS OXYGEN AND CARBON DIOXIDE CONTENT

EPA Reference Method 3, “Gas Analysis for the Deter mination of Dry Molecular Weight”, was used to measure the oxygen (O 2 ) and carbon dioxide (CO 2 ) concentrations of the stack gas at the test locations. The integrated samples were collected at the exhaust of the dry gas meter and were analyzed using a Fyrite ® analyzer. Each sample was measured in triplicate until a reading was repeated within 0.3%. The resu lts of this testing can be found in Appendix B.Page 7 of 11 AQS Project# 12662-21-001 STACK GAS MOISTURE CONTENT

Concurrent with the Method 315 testing, EPA Referen ce Method 4, “Determination of Moisture Content in Stack Gases”, was utilized. A Method 315 impinger train was used in place of the standard Method 4 condenser train; how ever, both impinger systems are identical in glassware and impinger contents. The moisture t rain consisted of a total of four (4) impingers, with the first two each containing appro ximately 100 milliliters of de-ionized water, followed by a third empty impinger, with the first and third impingers being the modified Greenburg-Smith design, and the second impinger hav ing the standard design. The final impinger contained approximately 300 grams of indic ating silica gel. Each of the impingers was weighed prior to use then reweighed after the t est run to quantify the moisture gained. Following the leak check, the impingers were separa ted, the moisture on the exterior was removed, and they were reweighed to the nearest one -tenth gram. The totaled differences between the initial and final weights represented t he moisture content of the stack gas during

each test run.

METHYLENE CHLORIDE EXTRACTABLE MATTER

EPA Reference Method 315 (40 CFR 63, Appendix A), “ Determination of Particulate and Methylene Chloride Extractable Matter from Stationa ry Sources”, was employed for this test. The collected samples and blanks were sent to a con tract laboratory for analysis.

Method 315 specifies the use of the standard partic ulate sampling train described in Method 5 (40 CFR 60, Appendix A). In Method 5, the gas sa mple is pulled though a sampling nozzle, probe, and a filter – all are heated to 250 °F. At the point the gas leaves the filter holder, it is no longer heated. Downstream of the filter, the gas is cooled in a condenser consisting of a train of impingers. Following each test run, the front half of the sample train (nozzle, probe liner, front of filter holder) is br ushed and acetone-rinsed, then brushed and rinsed with methylene chloride. The water in the c ondenser is recovered, and then the back half of the sample train (back of filter holder, al l impingers, and all connecting lines) is rinsed with water, then acetone, then methylene chloride. These preparation, sampling, and recovery procedures were followed without deviation

.

PERFORMANCE AUDITS

Testing commenced on June 5, 2012. In accordance w ith the applicable requirements specified in 40 CFR 63.7(c)(2)(iii), the USEPA Web site was accessed at least 60-days prior to the test date (calculates to be April 6, 2012). At that time, there were commercially available performance audit samples for POM from on e supplier. EPA rules do not require the use of performance audit samples unless there a re at least two suppliers. No audit samples were utilized in this test program.Page 8 of 11 AQS Project# 12662-21-001 FIGURE 5.1

METHOD 5 STACK SAMPLING TRAIN (as specified in Method 315)Page 9 of 11 AQS Project# 12662-21-001 FLOW 118 inches

222 inches Top of stack = 70 feet above grade

Sample Ports 50.5 inches

Top of baghouse

FIGURE 5.2

SCHEMATIC OF SAMPLE LOCATIONS A-446 Reactors #1, #2, and #3 (Identical Stacks)

(not to scale)Page 10 of 11 AQS Project# 12662-21-001 SECTION 6

QUALITY ASSURANCE/QUALITY CONTROL

All manual stack gas sampling equipment was calibra ted before the test program in accordance with the procedures outlined in the Quality Assurance Handbook for Air Pollution Measurement Systems, Volume III , EPA-600/4-72-027B. The stack gas sampling equipment calibrations that were performed in prepa ration for this project are summarized in Table 6.1. The dry gas meter system was calibrated after the test. Calibration data are included in Appendix E.

TABLE 6.1

FIELD EQUIPMENT CALIBRATION SUMMARY

Field Equipment Calibrated Against Allowable Error

Method 5 Dry Gas Meter Stainless Steel Critical Ori fice Set Y + 0.02 Y

∆ H @ + 0.15

Post Test Y + 0.05 Y

Pitot Tube Geometric Specifications See EPA Method 2

Probe nozzles Calipers Max. Difference 0.004 in.

between two measurements

Thermocouple ASTM – 3F thermometer + 1.5%

Condenser Thermometer ASTM – 3F thermometer + 2°F

Dry Gas Thermometer ASTM – 3F thermometer + 5°F

Barometer NBS Traceable Barometer + 0.01 in. Hg

AQS’ stack testing policies and practices conform t o ASTM D7036-04 “Standard Practice for Competence of Air Emission Testing Bodies” for emission testing programs affected by the requirements of 40 CFR 75.21(f), as performed o n Part 72 sources and Part 75 sources.

ASTM D7036-04 notwithstanding, it is our mission to be a trusted provider of air-related environmental services. We aspire to exceed client expectations by imparting exceptional quality and value in meeting corporate needs and fu lfilling regulatory requirements.

The AQS Quality Objectives are:

• to continually monitor and improve our ability to d eliver the scope of services

• to assign qualified test personnel to satisfy the n eeds of our clientsPage 11 of 11 AQS Project# 12662-21-001 • to comply with quality control procedures establish ed in test methods, in the AQS Quality Manual, and by regulatory agencies that hav e jurisdiction over test programs

• to prepare reports that clearly communicate test pr ogram results

• to utilize recordkeeping systems that allow for dat a retrieval and reconstruction

• to keep clients apprised of project progress and pr omptly respond to concernsAPPENDIX A

EXAMPLE CALCULATIONSAPPENDIX B

DATA SUMMARYAPPENDIX C

FIELD DATAAPPENDIX D

LABORATORY DATAAPPENDIX E

QUALITY ASSURANCE / QUALITY CONTROL