Century Aluminum of Kentucky ◊ 1627 State Route 271 North ◊ Hawesville, KY 42348 ◊ P - (270) 685-2493 ◊ F - (270) 852-2883 

 May 31, 2011 

David L. Putney 

U.S. Environmental Protection Agency 

Office of Air Quality Planning & Standards 

Research Triangle Park, NC 27711 

RE: Primary Aluminum Information Collection Request

Dear Mr. Putney, 

Enclosed please find Century Aluminum’s response to the Primary Aluminum ICR dated April 25, 2011. 

Please contact me at (270) 685-2493 x 2818 or ksands@centuryky.com if you have any questions 

concerning this submittal. 

Sincerely, 

Kenneth A. Sands 

Environmental Manager 

Enclosures 
Enclosure 1 

Primary Aluminum Reduction Section 114 Enclosure 1 - April 22, 2011 

Page 1 of 20 

Facility Questionnaire for Primary Aluminum Reduction Plants 1,2 

Please provide the information requested in the following forms. Use additional copies of the 

survey forms for additional facilities, as needed, for your response. 

This request for information is divided into four parts to be completed by each facility: 

Part A General Facility Information 

Part B Process and Emissions Control Devices 

Part C Start-ups and Shutdowns 

Part D Previously Performed Testing and Test Report Data 

Note, as stated in the cover letter from EPA, the survey response(s) (Enclosure 1) and the new test 

results (Enclosure 2) are due by May 31, 2011. 

Please separate confidential business information (CBI) from non-CBI for submittal to EPA. Please 

see the instructions in the cover letter for submitting CBI. 

 

1

 See Appendix A for an explanation of acronyms used in this document and Appendix B for a list of Hazardous Air 

Pollutants (HAP). 2

 Please make copies and complete these forms for each facility in your company subject to this request for information, as 

described in the cover letter from EPA. If possible we would prefer receiving the completed forms as electronic files in 

Microsoft® Word format. Please add additional rows to the tables as needed to contain your responses. Blank electronic 

forms are included on the disc provided with this package.
Enclosure 1 

Primary Aluminum Reduction Section 114 Enclosure 1 - April 22, 2011 

Page 2 of 20 

PART A: GENERAL FACILITY INFORMATION 

(Please fill out a separate form for each of your facilities) 

1. Name and address of the PARENT COMPANY that owns the facility: 

Century Aluminum of Kentucky, GP 

P.O. Box 500 – 1627 State Route 271 North 

Hawesville, KY 42348

2. Name and address of legal OPERATOR of the facility, if different than the legal OWNER: 

SAME 

3. Complete street address of facility (physical location): 

1627 State Route 271 North 

Hawesville, Kentucky 42348 

Hancock County 

4. Provide mailing address of the facility if different than physical location: 

1627 State Route 271 North 

PO Box 500 

Hawesville, Kentucky 42348 

Hancock County 

5. Facility contact able to answer technical questions about the completed survey: 

Sean Lane 

Safety & Environmental Manager 

Telephone number: (270)685-2493 ext. 2430 

Fax number: (270) 827-2887 

E-mail: slane@centuryky.com 

6. Please provide an electronic copy of your current Title V operating permit and any pending Title 

V operating permit modification applications (pdf files are preferred). 

Attachment #1

7. Please provide a copy of the facility schematic showing all of the primary aluminum operations 

that are subject to 40 CFR Part 63, Subpart LL. Please include the control device ID numbers in 

the facility schematic. 

Attachment #2
Enclosure 1 

Primary Aluminum Reduction Section 114 Enclosure 1 - April 22, 2011 

Page 3 of 20 

PART B: PROCESSES AND EMISSIONS CONTROL DEVICES 

8. Pitch storage tanks: 

3 - Total number of pitch storage tanks at facility 

No - Is at least one of the pitch storage tanks empty at all times? 

37,760 - Total amount of pitch used (tons per year) assuming facility operation at maximum 

capacity 

8a. Please provide the capacity (tons) of each pitch storage tank at facility (use the same pitch 

storage tank ID numbers as were assigned in the schematic provided in response to question 

7 and add columns if necessary): 

ID No.: 310420 310440 312019

Capacity: 1800 tons 1800 Tons 1800 Tons

8b. Please provide a rationale, if applicable, for why application of an emission standard to the 

pitch storage tank(s) is not practicable economically or technologically 

Not practicable economically: When performing a BACT analysis for PSD purposes, we 

look at the cost per ton of pollutant removed. Typically, costs higher than $10K-$12K per 

ton of pollutant removed are not economically feasible. In our specific case, the projected 

emissions of polycyclic organic matter from these tanks is 3,740 lbs (1.87 tons) per year. 

Knowing this, then costs greater than $18,700 - $22,440 would be considered cost 

prohibitive from a cost per ton basis.

Not practicable technologically: 

9. Anode bake furnaces: 

3 - Total number of anode bake furnaces at facility 

245,100 - Facility-wide green anode production capacity (tons per year) 

204,570 - Total amount of coke used for anode production (tons per year) assuming facility 

operation at maximum capacity 

10. Aluminum production, by potline(s) (use the same potline ID numbers as were assigned in the 

schematic provided in response to question 7): 

Total potlines (number) and combined aluminum capacity (tons per year): 

Total potlines ( 5 ) Aluminum capacity ( 316,000 ) 

Individual potlines (add rows as necessary) and aluminum capacity (tons per year): 

Potline # 424200 Aluminum capacity (62,500) 

Potline # 424220 Aluminum capacity (62,500) 

Potline # 424230 Aluminum capacity (62,500) 

Potline # 424240 Aluminum capacity (62,500) 
Enclosure 1 

Primary Aluminum Reduction Section 114 Enclosure 1 - April 22, 2011 

Page 4 of 20 

Potline # 424250 Aluminum capacity (66,000) 

11. Please describe your facility potline types (add rows as necessary and use the same ID numbers 

as were assigned in the schematic provided in response to question 7): 

11a. Potline ID No. Potline Type * Total No. of Pots 

 Potline # 424200 CWPB3 112

 Potline # 424220 CWPB3 112

Potline # 424230 CWPB3 112

Potline # 424240 CWPB3 112

Potline # 424250 CWPB1 112

* Center-worked pre-bake 1 (CWPB1); Horizontal stud Soderberg 1 (HSS1) 

Center-worked pre-bake 2 (CWPB2); Horizontal stud Soderberg 2 (HSS2) 

Center-worked pre-bake 3 (CWPB3); Vertical stud Soderberg (VSS) 

Side-worked pre-bake (SWPB) 

11b. What is the average frequency, average number, and average duration of cell openings (side 

shield and/or door removals) for each potline? 

Potline 

ID 

Cell opening (side shield and/or door removals) 

Average Frequency a Average Number b Average Duration c

(minutes) 

Side 

shield Door Side shield Door Side shield Door 

424200 100 114 3 3 10 20 

424220 100 114 3 3 10 20 

424230 100 114 3 3 10 20 

424240 100 114 3 3 10 20 

424250 100 119 3 3 10 20 

a

 The average number of times that at least one side shield or door of a given cell of the 

cited potline is opened during a 24 consecutive hour period. 

b

 The average number of cell openings (i.e. side shields and/or doors removed from all the 

cells in the cited potline) at any given time. 

c

 The average length of time, in minutes, that a given side shield or door of a cell of the 

cited potline is removed. 

11c. Describe the exhaust capture/hooding system for each potline including the capture 

efficiency (if known), evacuation rate, and damper system. 
Enclosure 1 

Primary Aluminum Reduction Section 114 Enclosure 1 - April 22, 2011 

Page 5 of 20 

Each pot in potlines (84)(42)(4200), (84)(42)(4220), (84)(42)(4230), (84)(42)(4240), and 

(84)(42)(4250) are shielded with side shields and end doors at all times that work is not 

being performed on the pots. This comprises the capture/hooding system. Each pot is 

connected to an exhaust system and is manually preset to a desired exhaust flow using a 

knife type damper. All pots from lines 4200, 4220, 4230, and 4240 are ducted to a 

common control device that was originally designed for 95% capture efficiency. The 

common control system exhausts about 2700 scfm per pot. All pots from line 4250 are 

ducted to a common control device that was originally designed for 98% capture efficiency. 

The common control system exhausts about 3500 scfm per pot. 

Potline ID 

Capture 

efficiency 

(%) 

Evacuation 

rate 

(scfm) 

Damper system? (i.e. to allow high 

and low flow evacuation rates) 

Yes No 

424200 95 300,000 No 

424220 95 300,000 No 

424230 95 300,000 No 

424240 95 300,000 No 

424250 98 392,000 No 

11d. Please provide a copy of the method(s) used (e.g. inspection checklist or log) to ensure that 

the capture efficiencies cited in the table above are achieved. 

Not applicable. 

12. Is total fluoride emitted from the roof vents measured with a sampling manifold or a cassette 

system? (CHECK one) Yes-2 lines (4240 and 4250) Manifold or Yes-3 Lines (4200, 

4220, & 4230) Cassette 

 12a. What is the total typical exhaust rate from the roof vents of each potroom (scfm)? 

 424200 is about 1,200,000 scfm 

 424220 is about 1,300,000 scfm 

 424230 is about 1,400,000 scfm 

 424240 is about 1,600,000 scfm 

 424250 is about 3,600,000 scfm 

13. Please describe your facility paste plant and emissions controls below: 

0.6% - Typical sulfur content of pitch 

0.8% - Maximum sulfur content of pitch cited in specifications provided to pitch suppliers, if 

applicable

2.2% - Typical sulfur content of coke
Enclosure 1 

Primary Aluminum Reduction Section 114 Enclosure 1 - April 22, 2011 

Page 6 of 20 

3.0% - Maximum sulfur content of coke cited in specifications provided to coke suppliers, if 

applicable

13a. What is the availability and cost of coke and pitch with lower sulfur contents for your 

facility? What is the lowest sulfur content coke and pitch available? 

See Attachment #3 

13b. What company (provide name and contact information) supplies your facility with the raw 

materials used in paste production? Please submit a copy of the current MSDS for these 

materials. 

 See Attachment #4 

13c. Is any coal tar pitch (as opposed to petroleum pitch) used in your facility? 

Yes 

13d. Please provide information on the methodology used [e.g. assumptions made, mass balance 

calculations, assumed variations associated with potline type (e.g. Soderberg versus prebake), etc.] to estimate COS emissions from the facility. 

We have not made any attempt to estimate COS emissions. 

14. a. Please provide information on any air pollution control device(s) controlling emissions from 

the pitch storage tanks, the paste plant, the anode bake furnaces, and/or the potlines at this 

facility using Tables 1, 2, 3, 4, and/or 5, as appropriate. Please use the same ID numbers as 

were assigned in the schematic provided in response to question 7. 

b. Does your operating permit include limits for emissions of particulate matter from the 

potlines and/or limits on the sulfur content of the pitch and/or coke used to produce anodes? 

If so, what are those limits? Yes. 

 PM for 424200, 424220, 424230 and 424240 combined stack = 138.33 #/hr 

 PM10 for 424200, 424220, 424230 and 424240 combined stack = 80.234 #/hr 

 PM for 422092, 422093, 422094 and 422088 Roof Monitors = 20.614 #/hr per Line 

 PM10 for 422092, 422093, 422094 and 422088 Roof Monitors = 11.956 #/hr per Line 

 Petroleum Coke %S limit is 3%. 

 Pitch %S limit is 0.8%. 

 PM for 424250 stack = 13.875 #/hr 

 PM10 for 424250 stack = 8.048 #/hr 

 PM for 423091 Roof Monitor = 37.671 #/hr 

 PM10 for 423091 Roof Monitor = 21.849 #/hr 

c. Do you have any plans to install any new higher efficiency rated control devices, or have any 

pending applications to add on any new controls on sources that are part of the primary 

aluminum reduction facility? 
Enclosure 1 

Primary Aluminum Reduction Section 114 Enclosure 1 - April 22, 2011 

Page 7 of 20 

(CHECK one) ___________ Yes X No 

If “Yes,” please specify and include any copies of pending permit applications as requested in 

item 6 in Part A. 

d. Please indicate below all emission controls that were installed or upgraded AFTER October 

7, 1997 in order to meet the MACT standards for primary aluminum reduction plants (add 

rows as necessary and use the same ID numbers as were assigned in the schematic provided 

in response to question 7): 

Description of new or 

upgraded control 

Emission 

point Emission limit 

Date the control or 

upgrade became 

operational 

Dry Alumina Scrubber 

330140 41 

POM

CB1 - 0.18 lbs/green ton 

CB2 - 0.18 lbs/green ton 

CB3 - 0.05 lbs/green ton 

TF

CB1 – 0.2 lbs/green ton 

CB2 – 0.2 lbs/green ton 

CB3 – 0.02 lbs/green ton

April 1999 

Dry Coke Scrubber 

310126 28 N/A 

Equipment Standard October 1999 

Dry Alumina Scrubber 

480063 89 TF

1.2 lbs/ton AL May 1999 

15. Pollution prevention: Describe any procedures, work practice standards, or materials used at your 

facility to prevent or reduce emissions of HAP from pitch storage tanks, the paste plant, the 

anode bake furnaces, and/or the potlines at this facility (as opposed to controlling pollution after 

it is formed). 

Pitch tanks – None 

Paste Plant – Cannot operate when scrubber is offline 

Bake Furnaces – None 

Potlines – Control number of shields that can be removed and end doors that can be opened at the 

same time during tapping and anode setting. Shielding audit, replacement, and repair program. 

 
Enclosure 1 

Primary Aluminum Reduction Section 114 Enclosure 1 - April 22, 2011 

Page 8 of 20 

Table 1 Wet Scrubber Description

1. Control device description and ID number (or numbers, if several identical control devices 

are used to control a given emission source): Multiple devices in series consisting of 

multiple cyclones, electrostatic precipitators, and wet scrubber spray towers. ID# 432001

2. Stack or vent location of each control device (use NAD83 and include six decimal places and 

add rows as necessary): 

ID No.: 84 Latitude: 37.94332027 Longitude: -86.78662514

ID No.: _________ Latitude: _______________ Longitude: ________________ 

ID No.: _________ Latitude: _______________ Longitude: ________________ 

3. Design collection efficiency and outlet concentration (add rows as necessary): 

Pollutant Collection Outlet Source of 

 efficiency * concentration * Estimation * 

 (if known) (if known) 

 PM Percent 0.4724 mg/dscf 1

 PM10 Percent mg/dscf _________ 

 PM2.5 Percent mg/dscf _________ 

 Total Fluorides Percent 0.0953 mg/dscf 1

 Hydrogen Fluorides Percent 0.0477 mg/dscf 1

 POM Percent mg/dscf _________ 

 COS Percent mg/dscf _________ 

 SO2 Percent 9.07x10-6 mg/dscf 1

 Other (specify) Percent mg/dscf _________ 

 Other (specify) Percent mg/dscf _________ 

* 1 = Performance testing 2 = Engineering judgment 3 = Manufacturer specs. 

 4 = Title V permit application 5 = Other (specify) _______________________ 

4. Device type: Venturi Vertical packed bed 

 Horizontal packed bed X Tray tower spray chamber 

 Other (specify or describe): 

5. Pressure mode of operation: X positive pressure negative pressure 

6. Typical gas temperature: inlet °F outlet 80 to 100 °F 

7. Gas flow rate: acfm (at scrubber outlet) 1,250,000 dscfm 

8. Pressure drop across scrubber: Unknown inches water column (in. H2O) 
Enclosure 1 

Primary Aluminum Reduction Section 114 Enclosure 1 - April 22, 2011 

Page 9 of 20 

9. Liquid to gas ratio: 21.6 gal/1,000 dscf 

10. Chemical usage rate (specify chemical and typical usage rate, if applicable) 

Chemical added Usage rate Units for usage rate 

Lime 367.8 Tons/month 

 

11. Identify each source served by this control device (add rows as necessary). 

Source ID No(s). Source description(s) 

424200 CWPB3 Potline 1 

424220 CWPB3 Potline 2 

424230 CWPB3 Potline 3 

424240 CWPB3 Potline 4 

12. Indicate what operational parameters of the control device are monitored to ensure that the 

control device is operating properly: 

 Volumetric flow rate X Fan amperage 

 Pressure drop X Water flow rate 

Other (specify): Secondary Current and Voltage at ESP

13. What level of a monitored operational parameter triggers corrective action? 

 Volumetric flow rate (acfm) outside 170-210 amps Fan amperage (amps) 

 Pressure drop (in. H2O) varies based upon individual scrubber – 12 

 total scrubbers Water flow rate (gpm) 

Other (specify): Secondary Current and Voltage at ESP – outside 80-156 mAmps & 

20-29mV

All based on 2hr rolling average

14. Has the collected sludge been analyzed? 

_____ Yes ___X__ No – To be completed as a part of this ICR 

If yes, provide the average and range for each HAP constituent analyzed over the past year or 

last 9 samples, whichever is fewer. Alternatively, attach the results of the analyses. Do not 

include results from the Toxicity Characteristic Leaching Procedure (TCLP). 

15. Additional comments and information: 
Enclosure 1 

Primary Aluminum Reduction Section 114 Enclosure 1 - April 22, 2011 

Page 10 of 20 

Table 2 Combination Dry Alumina Scrubber/Bag House Description

1. Control device description and ID number (or numbers, if several identical control devices 

are used to control a given emission source): Dry alumina scrubber ID # 480063

2. Stack or vent location of each control device (use NAD83 and include six decimal places and 

add rows as necessary): 

ID No.: 89 Latitude: 37.94246969 Longitude: -86.78920989

ID No.: _________ Latitude: _______________ Longitude: ________________ 

ID No.: _________ Latitude: _______________ Longitude: ________________ 

3. Design collection efficiency and outlet concentration (add rows as necessary): 

Pollutant Collection Outlet Source of 

 efficiency * concentration * Estimation * 

 (if known) (if known) 

 PM Percent 5.27x10-6 mg/dscf 1

 PM10 Percent mg/dscf _________ 

 PM2.5 Percent mg/dscf _________ 

 Total Fluorides Percent 7.34x10-3 mg/dscf 1

 Hydrogen Fluorides Percent 5.83x10-3 mg/dscf 1

 POM Percent mg/dscf _________ 

 COS Percent mg/dscf _________ 

 Other (specify) Percent mg/dscf _________ 

 Other (specify) Percent mg/dscf _________ 

 Other (specify) Percent mg/dscf _________ 

* 1 = Performance testing 2 = Engineering judgment 3 = Manufacturer specs. 

 4 = Title V permit application 5 = Other (specify) _______________________ 

4. Scrubber device type: 

_____ Fluidized bed __X___ Injection 

_____ Other (specify or describe): _________________________________________ 

5. Bag cleaning method: 

__X___ Pulse jet _____ Reverse air _____ Shaker 

_____ Other (describe) _________________________________________________ 

6. Pressure mode of operation: positive pressure X negative pressure 

7. Typical gas temperature: inlet to scrubber °F outlet from bag house 200 °F 
Enclosure 1 

Primary Aluminum Reduction Section 114 Enclosure 1 - April 22, 2011 

Page 11 of 20 

8. Gas flow rate: acfm (at bag house outlet) 425,000 dscfm 

9. Pressure drop: Across scrubber: 9.5 to 10 inches water column (in. H2O) 

Across bag house: 8 to 9 inches water column (in. H2O) 

10. Solid to gas ratio: 0.5 lb/1,000 acf

11. Alumina usage rate (differentiate between virgin and recycled alumina from potlines) 

Type of Alumina Added Usage rate Units for usage rate 

Virgin alumina 20,000 #/hr 

Recycled alumina 0 0 

Other alumina (specify ________________) 0 0 

12. Identify each emission source served by this control device (add rows as necessary). 

Source ID No(s). Description(s)

(42)(4250) Potline #5 

13. Indicate what operational parameters of the control device are monitored to ensure that the 

control device is operating properly: 

 Volumetric flow rate Fan amperage 

 X Pressure drop X Visible emissions opacity 

Other (specify): Alumina flow

14. What level of a monitored operational parameter triggers corrective action? 

 Volumetric flow rate (acfm) Fan amperage (amps) 

Outside 3.41-3.59 in H2O Pressure drop (in. H2O) >15% Visible emissions opacity (%) 

Other (specify): Alumina Flow <19,623 lbs/hr 

All based on 2 hr rolling average

15. Additional comments and information: 

 
Enclosure 1 

Primary Aluminum Reduction Section 114 Enclosure 1 - April 22, 2011 

Page 12 of 20 

Table 2 Combination Dry Alumina Scrubber/Bag House Description

2. Control device description and ID number (or numbers, if several identical control devices 

are used to control a given emission source): Dry alumina scrubber with evaporative cooling 

tower ID#330140 

16. Stack or vent location of each control device (use NAD83 and include six decimal places and 

add rows as necessary): 

ID No.: 41 Latitude: 37.94872731 Longitude: -86.78756436

ID No.: _________ Latitude: _______________ Longitude: ________________ 

ID No.: _________ Latitude: _______________ Longitude: ________________ 

17. Design collection efficiency and outlet concentration (add rows as necessary): 

Pollutant Collection Outlet Source of 

 efficiency * concentration * Estimation * 

 (if known) (if known) 

 PM Percent 0.09655 mg/dscf 1

 PM10 Percent mg/dscf _________ 

 PM2.5 Percent mg/dscf _________ 

 Total Fluorides Percent 0.00276 mg/dscf 1

 Hydrogen Fluorides Percent 0.000594 mg/dscf 1

 POM Percent 0.0554 mg/dscf 1

 COS Percent mg/dscf _________ 

 Other (specify) Percent mg/dscf _________ 

 Other (specify) Percent mg/dscf _________ 

 Other (specify) Percent mg/dscf _________ 

* 1 = Performance testing 2 = Engineering judgment 3 = Manufacturer specs. 

 4 = Title V permit application 5 = Other (specify) _______________________ 

18. Scrubber device type: 

_____ Fluidized bed __X___ Injection 

_____ Other (specify or describe): _________________________________________ 

19. Bag cleaning method: 

__X___ Pulse jet _____ Reverse air _____ Shaker 

_____ Other (describe) _________________________________________________ 

20. Pressure mode of operation: X positive pressure X negative pressure 
Enclosure 1 

Primary Aluminum Reduction Section 114 Enclosure 1 - April 22, 2011 

Page 13 of 20 

21. Typical gas temperature: inlet to scrubber 170-208 °F 

outlet from bag house 200 °F 

22. Gas flow rate acfm (at bag house outlet) 119,232-145,728 dscfm 

23. Pressure drop: Across scrubber: inches water column (in. H2O) 

Across bag house: 8 to 9 inches water column (in. H2O) 

24. Solid to gas ratio: 0.45 lb/1,000 acf

25. Alumina usage rate (differentiate between virgin and recycled alumina from potlines) 

Type of Alumina Added Usage rate Units for usage rate 

Virgin alumina 43 Tons/day 

Recycled alumina 0 0 

Other alumina (specify ________________) 0 0 

26. Identify each emission source served by this control device (add rows as necessary). 

Source ID No(s). Description(s)

(33)(3301) Carbon Bake Building 1 

(33)(3302) Carbon Bake Building 2 

(33)(3307) Carbon Bake Building 3 

27. Indicate what operational parameters of the control device are monitored to ensure that the 

control device is operating properly: 

 X Volumetric flow rate Fan amperage 

 Pressure drop X Visible emissions opacity 

Other (specify): Alumina Flow

28. What level of a monitored operational parameter triggers corrective action? 

 119,232-145,728 scfm Volumetric flow rate (acfm) 

 Fan amperage (amps) 

 Pressure drop (in. H2O) >15% Visible emissions opacity 

(%) 

Other (specify): Alumina Flow (by monitoring feed rate in hertz of rotary vane feeder 

<43 hertz

All based on 2 hr rolling average

29. Additional comments and information: 
Enclosure 1 

Primary Aluminum Reduction Section 114 Enclosure 1 - April 22, 2011 

Page 14 of 20 

Table 2 Combination Dry Coke Scrubber/Bag House Description

1. Control device description and ID number (or numbers, if several identical control devices 

are used to control a given emission source): Dry coke scrubber ID # 310126

2. Stack or vent location of each control device (use NAD83 and include six decimal places 

and add rows as necessary): 

ID No.: 28 Latitude: 37.9465348 Longitude: -86.78593987

ID No.: _________ Latitude: _______________ Longitude: ________________ 

ID No.: _________ Latitude: _______________ Longitude: ________________ 

3. Design collection efficiency and outlet concentration (add rows as necessary): 

Pollutant Collection Outlet Source of 

 efficiency * concentration * Estimation * 

 (if known) (if known) 

 PM Percent mg/dscf _________ 

 PM10 Percent mg/dscf _________ 

 PM2.5 Percent mg/dscf _________ 

 Percent mg/dscf _________ 

 Percent mg/dscf _________ 

 POM Percent mg/dscf _________ 

 Percent mg/dscf _________ 

 Other (specify) Percent mg/dscf _________ 

 Other (specify) Percent mg/dscf _________ 

 Other (specify) Percent mg/dscf _________ 

* 1 = Performance testing 2 = Engineering judgment 3 = Manufacturer specs. 

 4 = Title V permit application 5 = Other (specify) _______________________ 

4. Scrubber device type: 

_____ Fluidized bed __X___ Injection 

_____ Other (specify or describe): _________________________________________ 

5. Bag cleaning method: 

__X___ Pulse jet _____ Reverse air _____ Shaker 

_____ Other (describe) _________________________________________________ 

6. Pressure mode of operation: positive pressure X negative pressure 

7. Typical gas temperature: inlet to scrubber °F outlet from bag house °F 
Enclosure 1 

Primary Aluminum Reduction Section 114 Enclosure 1 - April 22, 2011 

Page 15 of 20 

8. Gas flow rate: acfm (at bag house outlet) 40,000-55,000 dscfm 

9. Pressure drop: Across scrubber: inches water column (in. H2O) 

Across bag house: 5 to 7 inches water column (in. H2O) 

10. Solid to gas ratio: lb/1,000 acf 

11. Coke usage rate 

Type of Coke Added Usage rate Units for usage rate 

Virgin Coke 1.97 tons/hr 

Recycled Coke 0 0 

Other Coke (specify ________________) 0 0 

12. Identify each emission source served by this control device (add rows as necessary). 

Source ID No(s). Description(s)

(31)(0351) – (31)(0359) Mixer #1 – Mixer #9 

(31)(0362, 0364, 2035, & 2036) Green Mix Belt Conveyors 

(31)(2037) Rejects Chute Flop Gate 

(31)(0425) Pitch Day Tank 

(31)(2006) Surge Hopper 

(31)(0135) Buffer Silo 

(31)(2010) Anode Vibrating Press 

13. Indicate what operational parameters of the control device are monitored to ensure that the 

control device is operating properly: 

 X Volumetric flow rate Fan amperage 

 Pressure drop X Visible emissions opacity 

Other (specify): Coke Flow

14. What level of a monitored operational parameter triggers corrective action? 

 Outside 40,000-55,000 scfm Volumetric flow rate (acfm) 

 Fan amperage (amps) 

 Pressure drop (in. H2O) 

 >15% Visible emissions opacity (%) 

Other (specify): Coke Flow (by monitoring feed rate in hertz of rotary vane feeder <50 hertz

All based on 2 hr rolling average

15. Additional comments and information: 
Enclosure 1 

Primary Aluminum Reduction Section 114 Enclosure 1 - April 22, 2011 

Page 16 of 20 
Enclosure 1 

Primary Aluminum Reduction Section 114 Enclosure 1 - April 22, 2011 

Page 17 of 20 

Table 3 Electrostatic Precipitator (ESP) Description 

1. Control device description and ID number (or numbers, if several identical control devices 

are used to control a given emission source): SEE TABLE 1

2. Stack or vent location of each control device (use NAD83 and include six decimal places and 

add rows as necessary): 

ID No.: 84_______ Latitude: 37.94332027 Longitude: -86.78662514

ID No.: _________ Latitude: _______________ Longitude: ________________ 

ID No.: _________ Latitude: _______________ Longitude: ________________ 

3. Design collection efficiency and outlet concentration (add rows as necessary): 

Pollutant Collection Outlet Source of 

 efficiency * concentration * Estimation * 

 (if known) (if known) 

 PM Percent mg/dscf _________ 

 PM10 Percent mg/dscf _________ 

 PM2.5 Percent mg/dscf _________ 

 Total Fluorides Percent mg/dscf _________ 

 Hydrogen Fluorides Percent mg/dscf _________ 

 POM Percent mg/dscf _________ 

 COS Percent mg/dscf _________ 

 Other (specify) Percent mg/dscf _________ 

 Other (specify) Percent mg/dscf _________ 

 Other (specify) Percent mg/dscf _________ 

* 1 = Performance testing 2 = Engineering judgment 3 = Manufacturer specs. 

 4 = Title V permit application 5 = Other (specify) _______________________ 

4. Device type: High-voltage, single-stage Low-voltage, two-stage 

 Wet X Dry 

 Other (specify or describe): 

5. Pressure mode of operation: positive pressure X negative pressure 

6. Typical gas temperature: inlet °F outlet °F 

7. Gas flow rate: acfm (at ESP outlet) dscfm 

8. Collection plate surface area: __________ ft2
Enclosure 1 

Primary Aluminum Reduction Section 114 Enclosure 1 - April 22, 2011 

Page 18 of 20 

9. Secondary power: _____________ kW 

10. Identify each emission source served by this control device (add rows as necessary). 

Source ID No(s). Description 

424200 CWPB3 Potline 1 

424220 CWPB3 Potline 2 

424230 CWPB3 Potline 3 

424240 CWPB3 Potline 4 

11. Indicate what operational parameters of the control device are monitored to ensure that the 

control device is operating properly: 

 Visible emissions Volumetric flow Fan amperage 

opacity rate 

 X Secondary power X Secondary voltage 

 Other (specify): .

12. What level of a monitored operational parameter triggers corrective action? 

 Visible emissions Volumetric flow Fan amperage 

opacity (%) rate (acfm) (amps) 

 Secondary power Secondary voltage 

(kW) (volts) 

 Other (specify): .

13. Has the collected dust been analyzed? 

_____ Yes _____ No 

If yes, provide the average and range for each HAP constituent analyzed over the past year or 

the last 9 samples, whichever is fewer. Alternatively, attach the results of the analyses. Do 

not include results from the Toxicity Characteristic Leaching Procedure (TCLP). 

14. Additional comments and information: 
Enclosure 1 

Primary Aluminum Reduction Section 114 Enclosure 1 - April 22, 2011 

Page 19 of 20 

Table 4 Bag House Description (Only fill out Table 4 for bag houses that are not associated with 

a dry alumina scrubber. Do not fill out Table 2 and Table 4 for any one bag house.)

1. Control device description and ID number (or numbers, if several identical control devices 

are used to control a given emission source): Not applicable 

2. Stack or vent location of each control device (use NAD83 and include six decimal places and 

add rows as necessary): 

ID No.: _________ Latitude: _______________ Longitude: ________________ 

ID No.: _________ Latitude: _______________ Longitude: ________________ 

ID No.: _________ Latitude: _______________ Longitude: ________________ 

3. Design collection efficiency and outlet concentration (add rows as necessary): 

Pollutant Collection Outlet Source of 

 efficiency * concentration * Estimation * 

 (if known) (if known) 

 PM Percent mg/dscf _________ 

 PM10 Percent mg/dscf _________ 

 PM2.5 Percent mg/dscf _________ 

 Total Fluorides Percent mg/dscf _________ 

 Hydrogen Fluorides Percent mg/dscf _________ 

 POM Percent mg/dscf _________ 

 COS Percent mg/dscf _________ 

 Other (specify) Percent mg/dscf _________ 

 Other (specify) Percent mg/dscf _________ 

 Other (specify) Percent mg/dscf _________ 

* 1 = Performance testing 2 = Engineering judgment 3 = Manufacturer specs. 

 4 = Title V permit application 5 = Other (specify) _______________________ 

4. Bag cleaning method: 

_____ Pulse jet _____ Reverse air _____ Shaker 

_____ Other (describe) _________________________________________________ 

5. Pressure mode of operation: positive pressure negative pressure 

6. Typical gas temperature: inlet °F outlet °F 

7. Gas flow rate: acfm (at bag house outlet) dscfm 

8. Pressure drop: inches water column (in. H2O) 
Enclosure 1 

Primary Aluminum Reduction Section 114 Enclosure 1 - April 22, 2011 

Page 20 of 20 

9. Air to cloth ratio: cfm/sf or fpm 

10. Identify each emission source served by this device (add rows as necessary). 

Source ID No(s). Description(s) 

11. Indicate what operational parameters of the control device are monitored to ensure that the 

control device is operating properly: 

_______ Volumetric flow rate ____________ Fan amperage 

_______ Visible emissions opacity ____________ Pressure drop 

Other (specify): .

12. What level of a monitored operational parameter triggers corrective action? 

_______ Volumetric flow rate (acfm) ____________ Fan amperage (amps) 

_______ Visible emissions opacity (%) ____________ Pressure drop (in. H2O) 

Other (specify): .

13. Has the collected dust been analyzed? 

_____ Yes _____ No 

If yes, provide the average and range for each HAP constituent analyzed over the past year or 

last 9 samples, whichever is fewer. Alternatively, attach the results of the analyses. Do not 

include results from the Toxicity Characteristic Leaching Procedure (TCLP). 

14. Additional comments and information: 
Enclosure 1 

Primary Aluminum Reduction Section 114 Enclosure 1 - April 22, 2011 

Page 21 of 20 

Table 5 Other Air Pollution Control Devices

1. Control device description and ID number (or numbers, if several identical control devices 

are used to control a given emission source): Not applicable 

2. Stack or vent location of each control device (use NAD83 and include six decimal places and 

add rows as necessary): 

ID No.: _________ Latitude: _______________ Longitude: ________________ 

ID No.: _________ Latitude: _______________ Longitude: ________________ 

ID No.: _________ Latitude: _______________ Longitude: ________________ 

3. Design collection efficiency and outlet concentration (add rows as necessary): 

Pollutant Collection Outlet Source of 

 efficiency * concentration * Estimation * 

 (if known) (if known) 

 PM Percent mg/dscf _________ 

 PM10 Percent mg/dscf _________ 

 PM2.5 Percent mg/dscf _________ 

 Total Fluorides Percent mg/dscf _________ 

 Hydrogen Fluorides Percent mg/dscf _________ 

 POM Percent mg/dscf _________ 

 COS Percent mg/dscf _________ 

 Other (specify) Percent mg/dscf _________ 

 Other (specify) Percent mg/dscf _________ 

 Other (specify) Percent mg/dscf _________ 

* 1 = Performance testing 2 = Engineering judgment 3 = Manufacturer specs. 

 4 = Title V permit application 5 = Other (specify) _______________________ 

4. Pressure mode of operation: positive pressure negative pressure 

5. Typical gas temperature: inlet °F outlet °F 

6. Gas flow rate: acfm Specify location: _______________________________ 

 dscfm 

7. Identify each emission source served by this control device (add rows as necessary). 

Source ID No(s). Source description(s) 
Enclosure 1 

Primary Aluminum Reduction Section 114 Enclosure 1 - April 22, 2011 

Page 22 of 20 

8. Indicate what operational parameters of the control device are monitored to ensure that the 

control device is operating properly: 

 Visible emissions opacity Volumetric flow rate 

 Pressure drop 

Other (specify): .

9. What level of a monitored operational parameter triggers corrective action? 

 Visible emissions opacity (%) Volumetric flow rate (acfm) 

 Pressure drop (in. H2O) 

Other (specify): .

10. Has the collected dust or sludge been analyzed? 

_____ Yes _____ No ______ Not Applicable 

If yes, provide the average and range for each HAP constituent analyzed over the past year 

or last 9 samples, whichever is fewer. Alternatively, attach the results of the analyses. Do not 

include results from the Toxicity Characteristic Leaching Procedure (TCLP). 

11. Additional comments and information: 
Enclosure 1 

Primary Aluminum Reduction Section 114 Enclosure 1 - April 22, 2011 

Page 23 of 20 

PART C: START-UPS AND SHUTDOWNS 

Please provide the information in Table 6 and questions below for each Subpart LL potline during 

start-up (the commencement of operation for any purpose) and shutdown (the cessation of operation 

for any purpose) operations. For the purposes of Part C of Enclosure 1 start-up and shutdown refers to 

the commencement and cessation of operations of a potline, not of an individual pot (e.g. after anode 

changes). 

16. Please provide a rationale, if applicable, for why application of the Subpart LL standards to a 

potline during start-up or shutdown is not practicable economically or technologically 

Not practicable economically: Collecting Method 14 or 14A samples representative of an the 

entire potline is not economically practicable because this would require the installation and 

operation of 12 or 13 separate Reference Method sampling systems in each potroom to collect 

representative compliance samples. These sampling systems typically cost more than $250,000 

each to install and this level of expenditure is not practicable for the rare occasion of startup at an 

individual potline.

 

Not practicable technologically: EPA Reference Methods 14 and 14A are designed to measure 

TF roof emissions over only a subset of the smelting pots operating in a pot room (roughly 10 or 

12 pots out of 130 or 150), with the assumption that the pots being sampled represent the entire 

potline during steady-state operation. During potline startup, pots located under a Method 14 or 

14A sampling system do not represent the entire potline because pots throughout the room are in 

various stages of startup or non-steady-state operation. It is not technically practicable to either 

establish a standard for startup or show compliance with a startup standard using the available 

EPA Reference Method. Establishing a standard for startups is further complicated by the fact 

that startups are rare and the conditions of a startup (and associated emissions) will vary 

depending on whether a potline was shut down by an emergency power loss (e.g., an ice storm) 

or whether the potline was intentionally shut down in a controlled manner. Work practice 

standards are the only practicable means of regulating emissions during an aluminum potline 

startup

17. Do you have test data that show any potline hazardous air pollutant (HAP) emissions during a 

start-up or shutdown? (Check one) Y X N 

If yes: 

a. Provide a copy of the test data. 

b. Describe the operating conditions (e.g. tons of aluminum produced per day) at the time of the 

testing. 

___________________________________________________________________________

___________________________________________________________________________

____________________________________________________________ 

18. Do you have an operating plan to minimize emissions during start-up and/or shutdown (e.g. a SS 

Plan)? (CHECK one) ____X______ Yes ____________ No 

If “Yes,” please provide a copy of the operating plan. See Attachment #5
Enclosure 1 

Primary Aluminum Reduction Section 114 Enclosure 1 - April 22, 2011 

Page 24 of 20 

19. Please indicate below how often you perform the following activities during start-up of your 

potlines by adding the following codes: A, S, N for Always, Sometimes, or Never. 

__A___ a. Develop a potroom/potline start-up schedule before start-up 

__A___ b. Perform daily assessment of start-up progress and any schedule changes 

__A___ c. Keep records of number of pots started per day 

___A__ d. Bring potroom/potline scrubbers and exhaust fans on line prior to energizing 

first cell to be restarted 

__N___ e. Supply alumina at a higher rate than during normal pot operation 

If so, how much higher? ____________(percent) 

__A___ f. Keep pots covered during start-up 

__A___ g. Limit removal of covers or panels to pots being worked on 

__A___ h. Keep primary capture/control system operating at all times during the start-up 

__A___ i. Monitor pot lines frequently during start-up to identify sick or unstable pots 

If so, do you use the following methods to manage a “sick” or unstable pot 

___N__ Adjust exhaust flow from pots 

__S___ Adjust cell voltage and feeding levels 

__S___ Monitor and adjust anode current and liquid level 

__N___ Other corrective procedures. Please describe the corrective procedures 

applied (use additional pages if needed): 

____________________________________________________________

____________________________________________________________

__________________________________________________________ 

20. Please list any additional start-up activities in the space below. NA

 
Enclosure 1 

Primary Aluminum Reduction Section 114 Enclosure 1 - April 22, 2011 

Page 25 of 20 

Table 6 Description of most recent potline start-up and shutdown of each potline (Make 

additional copies this table as needed) 

Potline ID 

(as assigned 

in the 

schematic 

of question 

7) 

Date(s), duration, and 

description (e.g. planned 

shutdown for ..., or 

emergency shutdown due 

to ...) of start-up or 

shutdown 

Was the start-up 

or shutdown 

covered by a 

contingency 

plan for 

controlling 

emissions? (Y/N) 

What actions were taken to minimize emissions? 

(42)(4250) Shutdown – March 

2009 

Startup – March 2011 

Y See enclosed SSM Plan (Attachment #5) 

 

 

 

 
APPENDIX C 

Primary Aluminum Reduction Section 114 Appendix C - April 22, 2011 

Page 1 of 1 

PART D: PREVIOUSLY PERFORMED TESTING AND TEST REPORT DATA 

21. Submit emission test report results for calendar year 2010 for polycyclic organic matter 

(POM) and total fluorides (TF) for any sources that have POM and/or TF emissions 

standards under Subpart LL. If available, submit emission test report results for any testing 

conducted from January 1, 2006 to the present for metal HAP (i.e. antimony, arsenic, 

beryllium, cadmium, chromium, hexavalent chromium, cobalt, lead, manganese, nickel, 

and selenium), TF, hydrogen fluoride (HF), particulate matter (PM), POM, speciated 

organic HAP data, and/or carbonyl sulfide (COS) for primary aluminum sources that 

currently do not have emission standards for those pollutants under Subpart LL. 

We would prefer electronic copies of these reports, if available. If electronic copies of the 

test reports are not available, hard copies may be provided or test result summaries may be 

provided. The following details (at a minimum) must be included, if available: 

(a) Pollutants and emission rates measured (e.g., lb/hr, gr/dscf, lb/ton), 

(b) The names of the test methods or procedures used, 

(c) Information on actual production or processing rates during the test, 

(d) For COS emission tests, the sulfur content of the coke and pitch used in the anodes at 

the time the testing was conducted, and 

(e) A statement that the process and any control devices were operating normally during 

the test, or if not, identify any abnormal or unrepresentative conditions. 

See Attachment #6 

22. If emission controls were installed or upgraded for primary aluminum sources after 

October 7, 1997 to control emissions of POM from prebake potlines, emissions of POM 

from existing pitch storage tanks, and/or emissions of COS, please also include test reports, 

if available, including the information specified in 21(a) through (e), for the most recent 

emission testing that was performed before these controls were installed or upgraded and 

identify them as “pre-MACT test reports.” 

 Nothing found. 

23. Has any air monitoring, such as Fourier Transform Infrared (FTIR) spectroscopy, been 

performed at your facility to measure COS concentration and/or emissions of sulfur 

oxides? If so, please provide the most recent data for a normal operating time period. 

Please include a description of the locations of sampling (reference the schematic 

submitted in response to question 7), sampling technique, duration of sampling, production 

rate during sampling, and potroom operations performed during the sampling. 

 No 

24. Has any air monitoring, such as FTIR spectroscopy, been performed at your facility to 

measure emissions of HF at the same time that TF samples were collected from the roof 

monitor? If so, please provide the most recent data for a normal operating time period. 
APPENDIX C 

Primary Aluminum Reduction Section 114 Appendix C - April 22, 2011 

Page 1 of 1 

Please include a description of the locations of sampling (reference the schematic 

submitted in response to question 7), sampling technique, duration of sampling, production 

rate during sampling, and potroom operations performed during the sampling. 

No 

Information Requested in Enclosure #2 

See Attachment #7 and Attachment #8. 
Attachment #1

   
Commonwealth of Kentucky 

Energy and Environment Cabinet 

Department for Environmental Protection 

Division for Air Quality 

200 Fair Oaks Lane, 1st Floor 

Frankfort, Kentucky 40601 

(502) 564-3999 

FINAL 

AIR QUALITY PERMIT

Issued under 401 KAR 52:020 

Permittee Name: Century Aluminum of Kentucky, LLC 

Mailing Address: 1627 KY 271 North 

P.O. Box 500 

 Hawesville, KY 42348 

Source Name: Same as above 

Mailing Address: Same as above 

Source Location: 1627 KY 271 North 

 Hawesville, KY 42348

Permit: V-08-012 

Agency Interest: 1634

Activity: APE20080001 

Review Type: Title V/PSD 

Source ID: 21- 091- 00004 

Regional Office: Owensboro Regional Office 

 3032 Alvey Park Drive W. Suite 700 

 Owensboro, KY 42303-2191 

 (270) 687-7304 

County: Hancock 

Application 

Complete Date: December 13, 2008 

Issuance Date: February 15, 2011 

Expiration Date: February 15, 2016 

John S. Lyons, Director

 Division for Air Quality
 TABLE OF CONTENTS

SECTION DESCRIPTION ISSUANCE PAGE 

A PERMIT AUTHORIZATION Renewal 1 

B 

EMISSION POINTS, EMISSIONS UNITS, 

APPLICABLE 

REGULATIONS, AND OPERATING CONDITIONS 

Renewal 2 

C INSIGNIFICANT ACTIVITIES Renewal 47 

D SOURCE EMISSION LIMITATIONS AND TESTING 

REQUIREMENTS Renewal 49 

E SOURCE CONTROL EQUIPMENT REQUIREMENTS Renewal 50 

F MONITORING, RECORDKEEPING, AND 

REPORTING REQUIREMENTS Renewal 52 

G GENERAL CONDITIONS Renewal 55 

H ALTERNATE OPERATING SCENARIOS Renewal 61 

I COMPLIANCE SCHEDULE Renewal 61 

ATTACHMENT 

A 

COMPLIANCE ASSURANCE MONITORING (CAM) 

PLAN Renewal 

ATTACHMENT SUMMARY OF THE PARAMETRIC MONITORING Renewal 

B PLAN 

Permit 

Type Activity# Complete 

Date 

Issuance 

Date Summary of Action 

V-08-012 Renewal APE20080001 12/13/2008 12/15/2009 Permit Renewal/PSD 

Modification

Version 7-20-10 
Permit Number: V-08-012 Page: 1 of 61

SECTION A – PERMIT AUTHORIZATION 

Pursuant to a duly submitted application the Kentucky Division for Air Quality (Division) hereby authorizes the 

operation of the equipment described herein in accordance with the terms and conditions of this permit. This 

permit has been issued under the provisions of Kentucky Revised Statutes (KRS) Chapter 224 and regulations 

promulgated pursuant thereto. 

The permittee shall not construct, reconstruct, or modify any affected facilities without first submitting a 

complete application and receiving a permit for the planned activity from the permitting authority, except as 

provided in this permit or in 401 KAR 52:020, Title V Permits. 

Issuance of this permit does not relieve the permittee from the responsibility of obtaining any other permits, 

licenses, or approvals required by the Kentucky Energy and Environment Cabinet (Cabinet) or any other 

federal, state, or local agency. 

Century Aluminum of Kentucky, and the adjacent Southwire Company Rod and Cable mill, (AFS # 21-091-

00009), are considered by the Division and the United States Environmental Protection Agency (U.S. EPA) 

Region IV, to be one source as defined in 401 KAR 51:017, Prevention of significant deterioration of air quality 

(PSD). Each source is subject to 401 KAR 52:020 and will be issued individual Title V operating permits. 

Pursuant to the respective Title V permits, each permittee is responsible and liable for their own violations 

unless there is a joint cause for the violations. 

Definitions: The following definitions apply to all abbreviations and variables used in this permit: 

AAQS – Ambient air quality standards 

BACT – Best available control technology 

CB – Carbon bake 

CO – Carbon monoxide 

CWPB3 – Center-worked prebake three potline process 

 Division – Kentucky Division for Air Quality 

 DC – Dust Collector 

 ESP – Electro Static Precipitator 

 HAP – Hazardous Air Pollutant 

HF – Hydrogen Fluoride 

 mmcf – Million cubic feet 

mg/dscf – Milligrams per dry standard cubic foot 

NAAQS – National Ambient Air Quality Standards 

NESHAP – National Emissions Standards for Hazardous Air Pollutants 

NOx – Nitrogen Oxides 

PM – Particulate Matter 

PM10 – Particulate Matter equal to or smaller than 10 micrometers 

 PMACT – NESHAP for Primary Aluminum Reduction Plants, also referred to as “PMACT’ 

 (40 CFR 63, Subpart LL) 

PSD – Prevention of Significant Deterioration of air quality 

PTE – Potential to Emit 

SO2 – Sulfur dioxide 

TF – Total Fluoride 

VOC – Volatile Organic Compounds 

PM/PM10 _ PM and PM10 standards are the same except as noted 

PM2.5/PM10_ PM10 and PM2.5 standards are the same except as noted 

 POM _ polycyclic organic matter
Permit Number: V-08-012 Page: 2 of 61

SECTION B - EMISSION POINTS, EMISSION UNITS, APPLICABLE REGULATIONS, AND 

OPERATING CONDITIONS 

Miscellaneous Particulate Sources

EP Group Equip. 

Desig. 

Cons./ 

date Description Controls & 

Requirements 

Selfimposed 

limits, 

lbs/hr PM/ 

PM10

Operation Limits 

(Tons/Year) 

EMISSION GROUP 10 

1 10 2012 1996 Vacuum Unloading - 

Nozzle 1 (Alumina & Coke) 

DC 102012 0.000565 500,000 

coke/alumina 

2 10 2013 1996 Vacuum Unloading- Nozzle 

2 (Alumina & Coke) 

DC 102013 0.000565 500,000 

coke/alumina 

3 10 0416 1996 Transfer Point, Dock 

Unload to Conveyor 

DC 100416 0.001074 1,000,000 

coke/alumina 

4 10 0220 1996 Unloading Station, Rail DC 100220 0.001074 1,000,000 

coke/alumina 

5 10 0105 1996 Transfer Point, Tower 1 DC 100105 0.001017 1,000,000 

coke/alumina 

6 10 0240 1996 Transfer Point, Tower 5 DC 100240 0.001221 360,000 

coke/alumina 

7 10 0311 1996 Silo, 4000 Ton, Coke #1 

East 

DC 100316 0.000942 250,000 tons 

Coke 

8 10 0310 

0312 

1996 

1969 

Silo, 4000 Ton, Coke #2 

West 

Silo 750 Ton Coke 

DC 100316 0.000942 

0.000660 

250,000 tons 

coke 

175,200 tons coke 

9 10 0030 1969 Silo, 4000 Ton, Alumina, 

1A, (Silo#1) 

DC 100037 0.000085 75,000 tons 

alumina 

10 10 0031 

0160 

1969 

1969 

Silo, 4000 Ton, Alumina, 

1B, (Silo#2) 

Silo, 280 Ton, Lithium 

Carbonate East 

DC 100038 0.000085 

0.000001 

75,000 tons 

alumina 

550 tons lithium 

carbonate 

11 10 0032 

0165 

1969 

1969 

Silo, 4000 Ton, Alumina, 

2A, (Silo # 3) 

Silo, 420 Ton, Aluminum 

Fluoride East 

DC 100039 0.000085 

0.000008 

75,000 tons 

alumina 

7,250 tons 

aluminum 

fluoride 

12 10 0033 1969 Silo, 4000 Ton, Alumina 

2B, (Silo #4) 

DC 100040 0.000085 75,000 tons 

alumina 

13 10 0034 1969 Silo, 4000 Ton, Alumina, 

3A, (Silo #5) 

DC 100041 0.000085 75,000 tons 

alumina 

14 10 0035 1969 Silo, 4000 Ton, Alumina, 

3B, (Silo # 6) 

DC 100042 0.000085 75,000 tons 

alumina 

15 10 0601 

0691 

1969 

1969 

Silo, 4000 Ton, Alumina, 

4A, (Silo # 7) 

Silo, 420 Ton, Aluminum 

Fluoride West 

DC 100611 0.000085 

0.000008 

75,000 tons 

alumina 

7,250 tons 

aluminum 

fluoride 

16 10 0602 

0692 

1969 Silo, 4000 Ton, Alumina, 

4B, (Silo # 8) 

Silo, 420 Tons, Bath, West 

DC 100612 0.000085 

0.000001 

75,000 tons 

alumina 

550 tons bath 

17 10 1100 1999 Silo, 5000 Ton, Alumina, 5, 

(Silo # 9) 

DC 101100 0.000198 175,000 tons of 

Alumina 

 
Permit Number: V-08-012 Page: 3 of 61

SECTION B - EMISSION POINTS, EMISSION UNITS, APPLICABLE REGULATIONS, AND 

OPERATING CONDITIONS (CONTINUED) 

Miscellaneous Particulate Sources

EP Group Equip. 

Desig. 

Cons./ 

date Description Controls & 

Requirements 

Selfimposed 

limits, 

lbs/hr 

PM/ PM10

Operation Limits 

(Tons/Year) 

EMISSION GROUP 31 

8 31 0023 

2023 

1969 

1969 

Silo, 20 Ton Packed Coke 

Waste 

Silo, 200 Ton, Packing Coke 

DC 100313 0.001785 

0.000004 

3,400 tons fluid 

coke 

3,400 tons fluid 

coke 

21 31 0450 1996 7.5 Ton Fluid, Coke Dust 

Receiver Bin 

DC 310451 0.001313 2,500 tons fluid 

coke 

22 31 0409 1969 Vacuum System DC 310409 0.000768 1,462.92 tons 

coke 

23 31 0214 1969 Silo, 200 Ton, Crushed Butts DC 310217 0.000284 75,500 tons 

crushed butts 

24 31 0056 1969 Ball Mill, 10 Ton DC 310068 0.001500 87,600 tons coke 

25 31 0104 1996 Ball Mill, 15 Ton DC 310109 0.002250 131,400 tons coke 

26 31 0025 

0046 

0144 

0202 

0226 

0274 

0328 

0042 

0336 

0080 

0148 

0278 

0206 

0287 

0034 

0155 

0242 

1969 Bucket Elevator (B-9), 

Bucket Elevator (B-10), 

Bucket Elevator (A-9), 

Bucket Elevator (A-16), 

Bucket Elevator (B-7), 

Bucket Elevator (A-14), 

Bucket Elevator (A-5) 

Crusher Double Roll 

Conveyor Screw 24” (A-1) 

Conveyor Screw 16” (A-10) 

Bin Fine Surge (A-6) 

Bin Butts 5T (A-12), 

Bin Coarse Surge 5T (A-7), 

Bin Scrap 20T (A-11), 

Bin Surge 5T (B-4) 

Conveyor Screw 16” (A-18) 

Conveyor Screw 16” (A-17) 

DC 310380 0.335789 

combined 

204,570 tons coke 

per source 

EMISSION GROUP 33N GROUP 33 

36 33 0056 1969 Cleaning, Baked Anode DC 330075 0.001898 235,200 tons 

baked anodes 

37 33 0095 1969 Silo, 50 Ton, Baked Anode 

Dust Bin 

DC 330092 0.001785 3,400 tons 

packing coke dust 

38 33 0093 

0174 

1969 

1969 

Conveying System, Packing 

Coke, CB1 & CB2 

Silo, 100 Ton, Packing 

Material 

DC 310189 0.001214 

0.000004 

2,312 tons 

packing coke 

3,400 tons 

packing coke 

39 33 3028 1999 Conveying System, Packing 

Coke Dust, CB3 

DC 333028 

Vents inside 

Bldg

0.000571 1,088 tons 

packing coke 

40 33 0365 1969 Vacuum Cleaning System DC 330365 0.000084 160 tons packing 

coke 

41 33 0240 

0244 

1999 

1999 

Silo, 200 Ton, Fresh Alumina 

Silo, 200 Ton, Reacted 

Alumina

Dry Alumina 

Scrubber 

330140 

0.000040 

0.000040 

17,520 tons 

alumina 

17,520 tons 

reacted alumina 
Permit Number: V-08-012 Page: 4 of 61

SECTION B - EMISSION POINTS, EMISSION UNITS, APPLICABLE REGULATIONS, AND 

OPERATING CONDITIONS (CONTINUED) 

Miscellaneous Particulate Sources

EP Group Equip. 

Desig. 

Cons./ 

mod. date Description Controls & Requirements 

Self-imposed 

limits, lbs/hr 

PM/ PM10

Operation Limits 

(Tons/Year) 

EMISSION GROUP 33 

42 33 0054 1969 NKM Crane, CB1N DC 330054 

Vents inside 

Bldg 

0.011216 21,360 tons 

packing coke 

43 33 0055 1969 NKM Crane, CB1S DC 330055 

Vents inside 

Bldg 

0.011216 21,360 tons 

packing coke 

44 33 0310 1969 NKM Crane, CB2N DC 330310 

Vents inside 

Bldg 

0.008412 16,020 tons 

packing coke 

45 33 0350 1969 NKM Crane, CB2S DC 330350 

Vents inside 

Bldg 

0.008412 16,020 tons 

packing coke 

46 33 3001 1999 ECL Crane, CB3 

Multipurpose 

DC 333001 

Vents inside 

Bldg. 

0.016825 32,040 tons 

packing coke 

47 33 0081 1969 Bin, Baked Anode Dust, 

CB1 

Vents inside 

Building 

PM10 = 0.069630 

PM= 0.1090 

1,326 tons 

packing coke dust 

48 33 0330 1969 Bin, Baked Anode Dust, 

CB2 

Vents inside 

Building 

PM10 = 0.051776 

PM = 0.0810 

986 tons packing 

coke dust 

EMISSION GROUP 34 

56 34 2016 1969 Saw, Stub Cut-Off Cyclone 

342838 

PM10=0.163 

PM=0.232877 

1,500 tons anode 

bars 

57 34 2017 1969 Jig #1, Stub Welding Vents to 

Atmosphere 

0.002612 4.4 tons welding 

rod 

58 34 2018 1969 Jig #2, Stub Welding Vents to 

Atmosphere 

0.002612 4.4 tons welding 

rod 

59 34 2019 1969 Jig #3, Stub Welding Vents to 

Atmosphere 

0.002612 4.4 tons welding 

rod 

60 34 2050 2008 Jig #4, Stub Welding Vents to 

Atmosphere 

0.002612 4.4 tons welding 

rod 

61 34 0055 1969 Heater, Cathode – 

Natural Gas 

Vents to 

Atmosphere 

0.013107 38.27 mmcf 

natural gas 

62 34 0020 

0021 

1969 

1969 

Tumble Mill #1 

Tumble Mill #2 

DC 340074 0.034932 

0.034932 

4,000 tons cast 

iron 

4,000 tons cast 

iron 

63 34 2104 

2105 

2115 

1969 

1969 

2011 

Furnace #1, Induction, 

Cast Iron (2 ton) 

Furnace #2, Induction, 

Cast Iron (2 ton) 

Furnace #3, Induction 

Cast Iron (2 ton) 

DC 342100 0.003699 

0.003699 

0.003699 

4,000 tons cast 

iron 

4,000 tons cast 

iron 

4,000 tons cast 

iron 

64 34 0078 1969 Furnace, Aluminum 

Spray 

DC 349052 0.010894 

combined 

2,750 tons 

aluminum 

34.80 mmcf 

natural gas 

 
Permit Number: V-08-012 Page: 5 of 61

SECTION B - EMISSION POINTS, EMISSION UNITS, APPLICABLE REGULATIONS, AND 

OPERATING CONDITIONS (CONTINUED) 

Miscellaneous Particulate Sources 

EP Group Equip. 

Desig. 

Cons./ 

date Description Controls & 

Requirements 

Selfimposed 

limits, 

lbs/hr PM/ 

PM10

Operation Limits 

(Tons/Year) 

EMISSION GROUP 34 

65 34 2028 

2087 

2027 

2021 

1969 

1969 

1969 

1969 

Central Butt Cleaning, Chip 

& Clean 

Central Butt Cleaning, Kent 

Chipper 

Central Butt Cleaning, 

Manual Backup Chipper 

Central Butt Cleaning, Butt 

Chipper 

DC 342074 0.001909 

combined 

50,000 tons anode 

butts per source 

66 34 0096 

0146 

1969 

1969 

Shot Blast Cleaner-Anode 

Butt 

Shot Blast Cleaner-Anode 

Rod/Stub 

DC 340165 0.732591 

0.855822 

75,500 tons spent 

rodded anodes 

88,200 tons anode 

rods 

67 34 0105 

0107 

0113 

2031 

0110 

1969 

1969 

1969 

1969 

2008 

Crusher #1, Primary Butt 

Crusher #2, Primary Butt 

Press #1, Primary Butt 

Press #2, Primary Butt 

Crusher, Intermediate 

DC 340157 0.000745 

combined 

75,500 tons spent, 

rodded anodes 

butts per source 

70 34 1110 

0118 

1969 

1969 

Crusher, Secondary Butt 

Crusher, Tertiary Butt 

DC 340154 0.000186 

0.000186 

75,500 tons spent 

anodes each 

EMISSION GROUP 42 

81 42 0071 

2025 

1996 Silo, 100 Ton, Bath Reclaim 

Silo, 300 Ton, Bath reclaim 

DC 423034 0.000051 

0.000051 

45,000 tons bath 

per source 

82 42 0021 

2026 

2028 

2030 

2031 

2031 

2032 

2032 

2033 

2034 

2036 

1969 

1969 

1969 

1969 

1969 

1969 

1969 

1969 

1969 

1969 

Bath Reclaim including: 

Hopper 

Bucket Elevator 

Screw Conveyor 

Vibrating Screen 

Belt Conveyor BC-3, 

Loading 

Belt Conveyor BC-3, 

Discharge 

Belt Conveyor BC-2, 

Loading 

Belt Conveyor BC-2, 

Discharge 

Belt Conveyor BC-1, 

Crusher 

Vibrating Feeder 

DC 420066 0.000981 

combined 

45,000 tons bath 

per source 

83 42 0034 1969 Transfer Point & Receiver 

Bin, 7.5 ton, Crushed Bath 

(43) 

DC 430051 0.000051 45,000 tons 

crushed bath 

 
Permit Number: V-08-012 Page: 6 of 61

SECTION B - EMISSION POINTS, EMISSION UNITS, APPLICABLE REGULATIONS, AND 

OPERATING CONDITIONS (CONTINUED) 

Miscellaneous Particulate Sources

EP Group Equip. 

Desig. 

Cons./ 

date Description Controls & Reqmnts. 

Self-imposed 

limits, lbs/hr 

PM/ PM10

Operation Limits 

(Tons/Year) 

EMISSION GROUP 42 

84 42 0029 

0030 

0031 

0032 

0315 

0316 

0439 

0440 

0070 

0088 

0018 

0318 

2569 

2580 

1969 

1969 

1969 

1969 

1969 

1969 

1969 

1969 

1969 

1969 

1969 

1969 

Non-PMACT Sources:

Potline 1A-5 Ton Fill 

Station 

Potline 1B-5 Ton Fill 

Station 

Potline 2A-5 Ton Fill 

Station 

Potline 2B-5 Ton Fill 

Station 

Potline 3A-5 Ton Fill 

Station 

Potline 3B-5 Ton Fill 

Station 

Potline 4A-5 Ton Fill 

Station 

Potline 4B-5 Ton Fill 

Station 

Airveying to 5 Ton Silos, 

Lines 1 & 2 (43) 

Airveying to 5 Ton Silos, 

Lines 3 & 4 (43) 

Silo, 100 Ton, Surge Lines 

1 & 2 (43) 

Silo, 100 Ton, Surge Lines 

3 & 4 (43) 

Pelletizer Dryer (43) 

Pelletizer System (43) 

Wet 

Scrubber 

System 

432001 

(Multiclone, 

ESP, Wet 

Scrubber 

Towers) 

PM10=0.0691 

PM= 0.119 

15,374 tons 

15,374 tons 

15,374 tons 

15,374 tons 

15,374 tons 

15,374 tons 

15,374 tons 

15,374 tons 

61,495 tons 

61,495 tons 

15,330 tons 

15,330 tons 

22.73 mmcf 

natural gas 

24,000 tons ESP 

dust 

91 42 1200 1999 Potline 5A-5 Ton, Fill 

Station 

DC 421200 0.000017 15,374 tons

92 42 1100 1999 Potline 5B-5 Ton, Fill 

Station

DC 421100 0.000017 15,374 tons

93 42 0152 1969 Silo, 450 Ton, Lime 

Unloading 

DC 430160 0.002836 5,400 tons lime 

94 42 1615 

1400 

1156 

1800 

1700 

1999 Silo, 150 Ton, Reacted 

Alumina 

Silo, 100 Ton, Anode 

Cleanings 

Silo, 150 Ton, Alumina 

Silo, 600 Ton, Alumina Silo 

5A 

Silo, 600 Ton, Alumina Silo 

5B 

DC 481615 0.000040 

0.000020 

0.000396 

0.000198 

0.000198 

17,520 tons 

8,687 tons 

175,000 tons 

87,500 tons 

87,500 tons 

95 42 1500 1999 Silo, 85 Ton, Sodium 

Carbonate (48) 

DC 481500 0.001103 2,100 tons sodium 

carbonate 

EMISSION GROUP 44 

111 44 0004 1998 Metal Purification Unit DC 440033 0.002399 316,000 tons 

aluminum 

112A 

112B 

44 0500 2002 Cleaner, Crucible (45) DC 450501 

DC 450503 

0.052055 8,000 tons bath 
Permit Number: V-08-012 Page: 7 of 61

SECTION B - EMISSION POINTS, EMISSION UNITS, APPLICABLE REGULATIONS, AND 

OPERATING CONDITIONS (CONTINUED) 

APPLICABLE REGULATIONS

401 KAR 61:020, Existing process operations, applies to emission units constructed before July 2, 1975 

401 KAR 59:010, New process operations, applies to each emission unit constructed on or after July 2, 1975 

Note: The self-imposed limitations supersede the mass emission standards (PM/PM10) of 401 KAR 59:010 and 

61:020 

1. Operating Limitations: 

a) Operational limits listed in the above tables are based upon a 12-month rolling total and shall not be 

exceeded (self-imposed). 

b) The baghouses and other control equipment listed in the above table shall be maintained and 

operated in accordance with the Preventive Maintenance Plan . 

2. Emission Limitations: 

a) 401 KAR 59:010 (New process only) and self-imposed limits: 

1) Visible emissions shall not equal or exceed 20 percent opacity, as determined with Reference 

Method 9, Appendix A, 40 CFR 60. 

2) Hourly particulate emissions as measured by Reference Method 5 (if required), Appendix A, 40 

CFR 60 averaged over the minimum specified time shall not exceed the self-imposed PM/PM10

emission rates as listed above. 

b) 401 KAR 61:020 (Existing process only) and self-imposed limits: 

1) Visible emissions shall not equal or exceed 40 percent opacity, as determined with Reference 

Method 9, Appendix A, 40 CFR 60. 

2) Hourly particulate emissions as measured by Reference Method 5 (if required), Appendix A, 40 

CFR 60, averaged over three hours or the minimum specified time shall not exceed the selfimposed PM/PM10 emission rates as listed above. 

c) To provide reasonable assurance that the visible emission limitations are being met the permittee 

shall follow the Preventive Maintainance Plan for baghouses. If the emissions are observed to be in 

excess of the normal operation, then the permittee shall take the proper measures to correct the 

problem. 

3. Testing Requirements: 

None 

4. Specific Monitoring Requirements: 

a) To provide reasonable assurance that the particulate matter emission limitations are being met, the 

permittee shall monitor the 12-month rolling total and types of throughputs (specified in the table 

under operational limits) processed through each emission unit during a calendar month. 

 
Permit Number: V-08-012 Page: 8 of 61

SECTION B - EMISSION POINTS, EMISSION UNITS, APPLICABLE REGULATIONS, AND 

OPERATING CONDITIONS (CONTINUED) 

b) To provide reasonable assurance that the visible emission limitations are being met the permittee 

shall: 

1) Perform a qualitative visual observation of the opacity of emissions from each stack/vent on a 

weekly basis and maintain a log of the observations. The log shall note: 

i) Whether any air emissions (except for water vapor) were visible from the vent/stack; 

ii) All emission points from which visible emissions occurred; and 

 2) Perform Method 9 observation if visible emissions are observed. 

c) Excursions from the control equipment’s visible emissions shall be promptly corrected. 

d) Additionally, the permittee shall follow the Preventive Maintainance Plan. Excursions from the 

requirements of the Preventive Maintainance Plan shall be corrected within 24 hours; additional time 

may be granted for just cause.

5. Specific Recordkeeping Requirements: 

a) Emission units that have a combined process throughput rate limit shall be added together. 

b) Records shall be maintained of the weekly qualitative visual observation, Method 9 observation if 

performed, monthly amounts and types of process weight, excursions from visible emission 

limitations, and any measures taken to comply with the Preventive Maintainance Plan. 

6. Specific Reporting Requirements: 

a) Any exceedance over the individual operational (throughput) limits shall be reported to the Division 

within thirty days after the exceedance. 

1) Following initial notification of a throughput exceedance, monthly reports for the individual unit 

shall be submitted, by the fifteenth of each month, to the Division’s Owensboro Regional Office. 

2) The report shall contain a calculation of the individual emission units monthly average and 12-

month PM/PM10 emissions to show compliance with any self-imposed limit. 

3) Monthly reports shall be submitted until there have been 12 consecutive months without any 

exceedance of limits. 

b) The permittee shall also certify to the Division, annually, that the specified records are being kept for 

these emission points. If more than two visible emission exceedances occur in any rolling six month 

period, the permittee shall submit to the Division’s Owensboro Regional Office a corrective action 

plan for the Division’s approval on form DEP7007BB, no later than 30 days from the second 

exceedance. 

c) The permittee shall certify to the Division, annually, whether the weekly visible emission surveys 

were conducted and if the specified records have been maintained for these emission points. 

 
Permit Number: V-08-012 Page: 9 of 61

SECTION B - EMISSION POINTS, EMISSION UNITS, APPLICABLE REGULATIONS, AND 

OPERATING CONDITIONS (CONTINUED) 

7. Specific Control Equipment Operating Conditions: 

a) The control equipment specified in the above table shall be maintained per the Preventive 

Maintainance Plan. The Preventive Maintainance Plan shall be kept at the plant and made available 

for inspection. 

b) The control equipment specified in the above table shall be operated within the operating parameters 

listed in the manufacturer’s specification or historic data. 

8. Alternate Operating Scenarios: 

None 

9. Compliance Schedule:

None 

10. Compliance Certification Requirements:

 

None 

 
Permit Number: V-08-012 Page: 10 of 61

 

SECTION B - EMISSION POINTS, EMISSION UNITS, APPLICABLE REGULATIONS, AND 

OPERATING CONDITIONS (CONTINUED) 

Fugitive Sources

EP Group Equip. 

Desig. 

Cons./ 

date Description Operation Limits (Tons/Year) 

EMISSION GROUP 10 

- 10 0018 1969 Conveyor, Barge to Tower 1 1,000,000 tons coke, alumina 

- 10 0416 1969 Transfer Point, Dock Unload to Conveyor 

Belt 

1,000,000 tons coke, alumina 

- 10 0220 1969 Unloading Station, Rail 1,000,000 tons coke, alumina 

- 10 0105 1969 Transfer Point, Tower 1 1,000,000 tons coke, alumina 

- 10 0240 1969 Transfer Point, Tower 5 360,000 tons aluminum fluoride, coke, alumina 

- 10 0230 1969 Conveyor, Railroad Unload Station to 

Tower 5 

360,000 tons aluminum fluoride, coke, alumina 

- 10 0250 1969 Conveyor, Tower 1 to Tower 5 360,000 tons coke, alumina, aluminum fluoride 

- 10 0015 1969 Conveyor, Tower 1 to Alumina Silos 750,000 tons alumina, aluminum fluoride 

- 10 0305 1969 Conveyor, Tower 5 to Coke Silos 250,000 tons coke 

EMISSION GROUP 31 

- 31 0362 1969 Conveyor, Green Mix Belt 108,888.88 tons pitch & coke 

- 31 0364 1969 Conveyor, Green Mix Belt 136,111.11 tons pitch & coke 

- 31 2035 1969 Conveyor, Green Mix Belt 245,000 tons pitch & coke 

- 31 2010 1996 Press, Anode Vibrating (32) 245,000 tons green anodes 

EMISSION GROUP 33 

- 33 0056 1969 Cleaning, Baked Anode 235,200 tons baked anodes 

EMISSION GROUP 34 

- 34 0129 1969 Conveyor, Crushed Butts 75,500 tons crushed anode butts 

- 34 0105 1969 Crusher #1, Primary Butt 75,500 tons anode butts 

- 34 0107 1969 Crusher #2, Primary Butt 75,500 tons anode butts 

- 34 0113 1969 Press #1, Primary Butt 75,500 tons anode butts 

- 34 2031 1969 Press #2, Primary Butt 75,500 tons anode butts 

- 34 1110 1969 Crusher, Secondary Butt 75,500 tons crushed anode butts 

- 34 0118 1969 Crusher, Tertiary Butt 75,500 tons crushed anode butts 

- 34 0014 1969 Casting Wheel 8,000 tons cast iron

- 34 2016 1969 Saw, Stub Cut-Off 1,500 tons rods with stub & cutting disks 

- 34 0020 1969 Mill #1, Cast Iron Thimble Tumbling 4,000 tons cast iron 

- 34 0021 1969 Mill #2, Cast Iron Thimble Tumbling 4,000 tons cast iron 

- 34 2104 1969 Furnace #1, Induction, Cast Iron (2-Ton) 4,000 tons cast iron 

- 34 2105 1969 Furnace #2, Induction, Cast Iron (2-Ton) 4,000 tons cast iron 

- 34 2115 2011 Furnace #3, Induction, Cast Iron (2-Ton) 4,000 tons cast iron 

- 34 0078 1969 Furnace, Aluminum Spray 34.80 mmcf natural gas; 2,750 tons aluminum 

- 34 2021 1969 Central Butt Cleaning, Butt Chipper 50,000 tons anode butts 

- 34 2027 1969 Central Butt Cleaning, Manual Backup 

Chipper 

50,000 tons anode butts 

- 34 2028 1969 Central Butt Cleaning, Chip & Clean 50,000 tons anode butts 

- 34 2087 1969 Central Butt Cleaning, Kent Chipper 50,000 tons anode butts 

 
Permit Number: V-08-012 Page: 11 of 61

SECTION B - EMISSION POINTS, EMISSION UNITS, APPLICABLE REGULATIONS, AND 

OPERATING CONDITIONS (CONTINUED) 

Fugitive Sources

EP Group Equip. 

Desig. 

Cons./ 

Date Description Operation Limits (Tons/Year) 

EMISSION GROUP 42 

- 42 0021 

2026 

2030 

2031 

2031 

2032 

2032 

2033 

2034 

2036 

1969 

1969 

1969 

1969 

1969 

1969 

1969 

1969 

1969 

1969 

Bath Reclaim including: 

Hopper 

Bucket Elevator 

Vibrating Screen 

Belt Conveyor BC-3, Loading 

Belt Conveyor BC-3, Discharge 

Belt Conveyor BC-2, Loading 

Belt Conveyor BC-2, Discharge 

Belt Conveyor BC-1 

Crusher 

Vibrating Feeder 

45,000 tons bath per source 

EMISSION GROUP 44 

- 44 0004 1998 Metal Purification Unit 316,000 tons aluminum 

- 44 0500 2002 Cleaner, Crucible (45) 8,000 tons bath 

EMISSION GROUP 50 

- 50 - 1969 Paved Roads NA 

- 50 - 1969 Unpaved Roads NA 

APPLICABLE REGULATIONS: 

401 KAR 63:010, Fugitive emissions 

 

1. Operating Limitations:

a) Operational limits listed in the above table shall not be exceeded. 

b) Pursuant to 401 KAR 63:010, Section 3(c), the permittee shall take reasonable precaution to prevent 

particulate matter from becoming airborne. Such reasonable precautions shall include, but are not 

limited to: 

1) The application and maintenance of asphalt, oil, water, or suitable chemicals on roads, material 

stockpiles, and other surfaces that can create airborne dusts; 

2) The maintenance of paved roadways in clean condition; 

3) The prompt removal of earth or other material from a paved street which earth or other material 

has been transported thereto by trucking or earth moving equipment or erosion by water; and 

4) The installation and use of hoods, fans, and fabric filters to enclose and vent the handling of 

dusty materials, or the use of water sprays or other measures to suppress the dust emissions 

during handling.

2. Emission Limitations:

a) Pursuant to 401 KAR 63:010, fugitive dust emissions shall not be visible beyond the lot line of the 

plant’s property. 

 
Permit Number: V-08-012 Page: 12 of 61

SECTION B - EMISSION POINTS, EMISSION UNITS, APPLICABLE REGULATIONS, AND 

OPERATING CONDITIONS (CONTINUED) 

3. Testing Requirements: 

None 

4. Specific Monitoring Requirements:

 To provide reasonable assurance that the fugitive dust emissions will not be visible beyond the 

plant’s property the permittee shall monitor the conditions of the roadways and other fugitive dust 

emission units and when appropriate take action to minimize dust. 

5. Specific Record Keeping Requirements:

 Records shall be maintained of the time, date and type of reasonable precaution taken to prevent 

fugitive dust from becoming airborne. 

6. Specific Reporting Requirements: 

 If more than two excursions occur in any rolling six months, the permittee shall submit to the 

Division’s Owensboro Regional Office a corrective action plan for the Division’s approval on form 

DEP7007BB, no later than 30 days from the second exceedance.

7. Control Equipment Operating Conditions:

None 

8. Alternate Operating Scenario: 

None 

 
Permit Number: V-08-012 Page: 13 of 61

SECTION B - EMISSION POINTS, EMISSION UNITS, APPLICABLE REGULATIONS, AND 

OPERATING CONDITIONS (CONTINUED) 

PMACT CWPB3 Sources (Potlines 1-4)

EP Group Equip. 

Desig. 

Cons./ 

Date Description Controls & 

Requirements 

BACT LIMITS 

(lbs/hr) 

Operation Limits 

(Tons/Year) 

EMISSION GROUP 42 

84 42 

4200 

4220 

4230 

4240 

1969 

Potline #1, CWPB3 (45) 

Potline #2, CWPB3 (45) 

Potline #3, CWPB3 (45) 

Potline #4, CWPB3 (45) 

Wet Scrubber 

System 

432001 

(Multiclone, 

ESP, Wet 

Scrubber 

Towers) 

Operation per 

Parametric 

Monitoring 

Plan

Combined emissions 

CO – 6,778 

F – 11.751 

HF – 27.700 

*NOx – 0.0813 

PM10 – 80.234 

PM – 138.33 

SO2 – see emission 

limitations 

*VOC – 27.112 

250,000 tons 

aluminum 

produced from all 

lines 

85 42 2092 1969 Potline #1 Roof Monitor, 

CWPB3 

Operation per 

Parametric 

Monitoring 

Plan 

CO – 89.184 

F – 3.253 

HF – 4.773 

*NOx – 0.001 

PM10 – 11.956 

PM – 20.614 

SO2 – see emission 

limitations 

*VOC – 0.785 

62,500 tons 

aluminum 

produced 

86 42 2093 1969 Potline #2 Roof Monitor, 

CWPB3 

Operation per 

Parametric 

Monitoring 

Plan 

CO – 89.184 

F – 3.253 

HF – 4.773 

*NOx – 0.001 

PM10 – 11.956 

PM – 20.614 

SO2 – see emission 

limitations 

*VOC – 0.785 

62,500 tons 

aluminum 

produced 

87 42 2094 1969 Potline #3 Roof Monitor, 

CWPB3 

Operation per 

Parametric 

Monitoring 

Plan 

CO – 89.184 

F – 3.253 

HF – 4.773 

*NOx – 0.001 

PM10 – 11.956 

PM – 20.614 

SO2 – see emission 

limitations 

*VOC – 0.785 

62,500 tons 

aluminum 

produced 

88 42 2088 1969 Potline #4 Roof Monitor, 

CWPB3 

Operation per 

Parametric 

Monitoring 

Plan 

CO – 89.184 

F – 3.253 

HF – 4.773 

*NOx – 0.001 

PM10 – 11.956 

PM – 20.614 

SO2 – see emission 

limitations 

*VOC – 0.785 

62,500 tons 

aluminum 

produced 

* VOC and NOx limits are Synthetic Minor Limits 
Permit Number: V-08-012 Page: 14 of 61

SECTION B - EMISSION POINTS, EMISSION UNITS, APPLICABLE REGULATIONS, AND 

OPERATING CONDITIONS (CONTINUED) 

APPLICABLE REGULATIONS: 

40 CFR Part 63, Subpart LL, NESHAP for primary aluminum reduction plant

401 KAR 59:010, New process operations

401 KAR 51:017, Prevention of significant deterioration of air quality

1. Operating Limitations:

 The following operational limits are to meet BACT and protect NAAQS: 

a) Maximum 12-month rolling total aluminum production shall not exceed 250,000 cumulative tons 

from potlines 1-4. 

b) The petroleum coke used to make the green anodes shall not exceed 3.0 percent sulfur by weight and 

the pitch shall not exceed 0.80 percent sulfur by weight as measured by the standard ASTM method, 

an approved alternative method, or by vendor Certificate of Analysis. 

 

c) The design capture efficiency for the collection system on potlines 1-4 shall equal, or exceed, 95 

percent. 

d) The permittee shall follow good design and combustion practices for the potlines to control CO 

emissions. The standard operating procedures for following the good operational procedures shall 

be kept available at site for inspection. Records shall be kept of continuing practices and 

maintenance. 

2. Emission Limitations:

a) Pursuant to 401 KAR 59:010: Visible emissions shall not exceed 20 percent opacity. 

Compliance Demonstration Method: 

See Section 4.Specific Monitoring Requirements

b) Pursuant to 40 CFR 63, Subpart LL, and 401 KAR 53:010, the permittee shall not allow the 

emissions of total fluorides to exceed 2.5 lbs/ton of aluminum produced for each potline pursuant to 

40 CFR 63.843 (a)(1)(iii), if emission averaging is not elected. If emission averaging is elected, the 

permittee shall not allow the emissions of TF to exceed those limits referenced in 40 CFR 63.846 

and Table 1, of Subpart LL, for CWPB3. 

Compliance Demonstration: 

i) Compliance with the applicable monthly individual emissions of TF: 

ETF = (Cs1 x Qsd)1 + (Cs2 x Qsd)2 40 CFR 63.847(e) (P x K) 

 
Permit Number: V-08-012 Page: 15 of 61

SECTION B - EMISSION POINTS, EMISSION UNITS, APPLICABLE REGULATIONS, AND 

OPERATING CONDITIONS (CONTINUED) 

Where: 

− ETF is the emission rate of total fluorides from each potline in lb/ton 

− Cs1 is the concentration of total fluorides from the primary control system in mg/dscf 

− Qsd is the volumetric flow rate of effluent gas corresponding to the appropriate 

 subscript location in dscf/hr 

− Cs2 is the concentration of total fluorides as measured for roof monitor emissions in 

mg/dscf, 

− P is the aluminum production rate in tons/hr 

− K is the conversion factor 453,600 mg/lb 

− 1 denotes the subscript for primary control system effluent gas 

− 2 denotes the subscript for the roof monitor effluent gas 

ii) The aluminum production rate (P) shall be determined by dividing the number of hours in the 

calendar month into the weight of aluminum tapped during the calendar month that includes 

the three runs for a performance test. 

iii) The concentration and volumetric flow rate for the primary control system shall be 

determined from the previous 12-month average of all valid performance test runs (40 CFR 

63.848(a)). The concentration and volumetric flow rate for the roof monitor shall be 

determined using the monthly average from at least three performance test runs (40 CFR 

63.848(a)) performed on each potline.

iv) Compliance with the applicable monthly average emissions of TF listed, above, shall be 

determined using Equation 1 except that the sum of emissions from each potline included in 

the group, determined separately using the numerator, is divided by the total aluminum 

production from all of the potlines comprising the group for the month. 

A) The monthly average emissions (in lb/ton) of secondary emissions (roof monitor) and TF 

from the primary control system for each potline shall be determined using test 

provisions specified below and calculated using the numerator in Equation 1. 

B) At least three performance test runs per potline each month must be performed for the 

secondary emission unless quarterly sampling has been approved. 

C) The results of the secondary emissions shall be combined with the TF results for the 

 primary control system(s) and divided by the total aluminum production. 

D) Each potline’s average hourly production rate shall be determined by dividing the number 

of hours in the calendar month into the weight of aluminum tapped during the calendar 

month that includes the three runs for a performance test. 

E) The average hourly production for the potlines comprising the group shall be combined 

to determine the total aluminum production. 

v) Compliance with Division Air Quality Standards for fluoride shall be demonstrated through 

continued operation and maintenance of ambient air monitoring equipment previously 

approved by the Division, pursuant to 401 KAR 61:165. 

c) Pursuant to 401 KAR 51:017: The permittee shall not allow the combined emissions of particulate 

matter less than or equal to 10 microns (PM10) and less than or equal to 2.5 microns (PM2.5) from 

potlines 1-4 (combined roof monitors and control stack) to exceed 128.1 lbs/hr [daily rolling totals 

shall be used to calculate hourly average (on a monthly basis) using the monthly operational hours] 

(BACT). 

 
Permit Number: V-08-012 Page: 16 of 61

SECTION B - EMISSION POINTS, EMISSION UNITS, APPLICABLE REGULATIONS, AND 

OPERATING CONDITIONS (CONTINUED) 

Compliance Demonstration: 

Compliance with the applicable emissions limits for PM10 shall be demonstrated through the use 

of the following equation: 

 EPM10 / PM2.5 = [Monthly production in tons X Emission factor calculated using the most recent 

stack test or listed in KYEIS (lbs/ton)]/ Monthly hours of operation 

 

 Monthly production rate is the sum of daily totals. 

 

d) Pursuant to 401 KAR 51:017, the permittee shall not allow the combined emissions of particulate 

matter (PM) from potlines 1-4 (combined roof monitors and control stack) to exceed 220.786 lbs/hr 

[daily rolling totals shall be used to calculate hourly average (on a monthly basis) using the monthly 

operational hours] (BACT). 

 Note: The value of PM lb/hr shall be calculated using the following equation: 

Compliance Demonstration: 

Compliance with the applicable emissions limits for PM shall be demonstrated through the use of 

the following equation: 

 EPM = [Monthly production in tons X Emission factor calculated using the most recent stack 

 test or listed in KYEIS (lbs/ton)]/ Monthly hours of operation 

 Monthly production rate is the sum of daily totals. 

 

 e) NOx emissions from potlines 1-4 (stack and roof monitors) shall not exceed 0.40 lbs/hr (12-month 

 rolling total) (Synthetic minor limit). 

Compliance Demonstration: 

 Please see 3.Testing requirements below. 

f) Pursuant to 401 KAR 51:017, the permittee shall not allow the combined emissions of sulfur dioxide 

(SO2) from potlines 1-4 to exceed 898.97 lbs/hr [daily rolling totals shall be used to calculate hourly 

average (on a monthly basis) using the monthly operational hours] (BACT). 

 Note: This value shall be calculated using the following equation: 

Compliance Demonstration: 

Compliance with the applicable hourly emissions of SO2: 

ESO2 = [monthly production in tons X emission factor of SO2 (per ton aluminum) using the most 

recent stack test or listed in KYEIS (lbs/ton)]/ monthly hours of operation 

g) Pursuant to 401 KAR 51:017: The permittee shall not allow the combined emissions of carbon 

monoxide (CO) from potlines 1-4 to exceed 7,134 lbs/hr (monthly average) (BACT). 

 Note: This value shall be calculated using the following equation: 
Permit Number: V-08-012 Page: 17 of 61

SECTION B - EMISSION POINTS, EMISSION UNITS, APPLICABLE REGULATIONS, AND 

OPERATING CONDITIONS (CONTINUED) 

Compliance Demonstration: 

Compliance with the applicable emissions limits for CO shall be demonstrated through the use of 

 the following equation: 

ECO = [Monthly production in tons X Emission factor calculated using the most recent stack 

 test or listed in KYEIS (lbs/ton)]/ Monthly hours of operation 

 h) VOC emissions from potlines 1-4 (stack and roof monitors) shall not exceed 30.252 lbs/hr (12-month 

rolling total) (Synthetic minor limit). 

Compliance Demonstration: 

 Please see 3.Testing requirements below. 

 

3. Testing Requirements:

 

a) Pursuant to 401 KAR 59:010: 

Determine the opacity of emissions by Reference Method 9 if qualitative observations of 

emissions from any stack/vent are visible. 

b) Pursuant to 401 KAR 51:017: 

1) For the production increase project authorized through permit, the permittee shall conduct a 

performance test for particulate emissions (filterable PM, PM10, PM2.5 and Condensable 

Particulate) quarterly during the first year and thereafter once a year during the life of this 

permit. The tests shall be performed using EPA approved methods to quantify particulate 

emissions (filterable PM, PM10, PM2.5 and Condensable Particulate). Where similar potlines 

exist, the permittee may perform sampling on a representative potline. 

2) The permittee shall perform Reference Method 6 for sulfur dioxide emissions quarterly during 

first year and once during the next four years of this permit. Where similar potlines exist, the 

permittee may perform sampling on a representative potline. 

3) The permittee shall perform Reference Method 25 or 25A VOC test once during the life of this 

permit. Where similar potlines exist, the permittee may perform sampling on a representative 

potline. 

4) The permittee shall perform Reference Method 7 or 7E NOx test once during the life of this 

permit. Where similar potlines exist, the permittee may perform sampling a representative 

potline. 

5) The permittee shall perform Reference Method 10 CO test once during the life of this permit. 

Where similar potlines exist, the permittee may perform sampling on a representative potline. 

6) The permittee shall perform Reference Method 5 particulate tests for PM quarterly during the 

first year and thereafter once a year during the life of this permit. Where similar potlines exist, 

the permittee may perform sampling on a representative potline. 

c) Pursuant to 40 CFR 63, Subpart LL: 
Permit Number: V-08-012 Page: 18 of 61

SECTION B - EMISSION POINTS, EMISSION UNITS, APPLICABLE REGULATIONS, AND 

OPERATING CONDITIONS (CONTINUED) 

1) The permittee shall perform tests in accordance with 40 CFR 63.847 (b) thru (d) and 40 CFR 

63.849. 

2) The test plan must comply with 40 CFR 63.847 and be in accordance with 40 CFR 63.7. 

3) The test plan must include procedures for conducting the initial performance test and for 

subsequent performance tests required in 40 CFR 63.848 for emission monitoring. 

4) In addition to the information required by 40 CFR 63.7, the test plan shall include: 

i) Procedures to ensure a minimum of three runs are performed annually for the primary control 

system for each source [40 CFR 63.847 (b)(1)]; and 

ii) Procedures for establishing the frequency of testing to ensure that at least one run is 

performed before the 15th of the month, at least one run is performed after the 15th of the 

month, and that there are at least six days between two of the runs during the month, or that 

secondary emissions are measured according to an alternate schedule satisfactory to the 

applicable regulatory authority [40 CFR 63.847 (b)(8)]. 

5) The permittee shall measure and record at least three runs each month for secondary emissions 

and at least three runs each year for the primary control system to determine 

 compliance with the applicable emission limits [40 CFR 63.847(d)(1)] . 

6) The performance tests shall be conducted in accordance with the requirements of the general 

provisions in Subpart A of Part 40 CFR 63, the approved test plan, and the procedures in 40 

CFR 63 Subpart LL. 

7) If the permittee has performed more than one test of primary emission control devices for 

potlines during the previous consecutive 12 months, all tests shall be used to determine the 

contribution from the primary emission control system [40 CFR 63.847(d)(3)]. 

8) The permittee shall use the reference methods listed 40 CFR 63.849 to determine compliance 

with the applicable emission limits for TF. 

4. Specific Monitoring Requirements: 

a) To provide reasonable assurance that the visible emission limitations are being met the permittee 

shall: 

1) Perform visual opacity readings on the stack or vent using Reference Method 9 on a quarterly 

basis, or more frequently if requested by the Division. Opacity readings shall be conducted 

while the emission units are in operation.

2) Perform a qualitative visual observation of emissions from each stack/vent on a daily basis and 

maintain a log of the observation. The log shall note: 

i) Whether any air emissions (except for water vapor) were visible from the vent/stack, 

ii) All emission points from which visible emissions occurred. 

iii) Perform Method 9 observations if visible emissions are observed. 

3) The permittee shall continue to operate and maintain ambient air monitoring equipment for the 

detection of fluorides. This equipment shall be located at sites specified by the Division. 

b) To provide reasonable assurance that the particulate matter (PM, PM10, PM2.5) emission limitations 

are being met, the permittee shall monitor the 12-month rolling amount and type of process weight 

added to each emissions unit and the operating parameters of each control device. 

c) Excursions from the control equipment’s operating ranges shall be promptly corrected as per the 

provisions of the Startup, Shutdown and Malfunction Plan. 

d) Pursuant to 40 CFR 63.848(a): 
Permit Number: V-08-012 Page: 19 of 61

SECTION B - EMISSION POINTS, EMISSION UNITS, APPLICABLE REGULATIONS, AND 

OPERATING CONDITIONS (CONTINUED)

1) The permittee shall maintain systems to determine the daily weight of aluminum produced. 

2) The permittee shall maintain ambient air monitoring equipment for fluoride and monitor the raw 

 material feed rates and cell or potline voltage. 

3) The TF emissions from each potline shall be monitored through monthly performance tests 

 specified in the testing requirement section and in 40 CFR 63, Subpart LL. TF emissions shall 

be computed and recorded using Equation 2.b above. 

4) If a reduced sampling frequency is approved, the TF emissions from each potline shall be 

monitored, quarterly, using the approved test schedule and methods. Compliance with TF 

emissions shall be computed and recorded, quarterly, using Equation 2.b above. 

5) If prior approval for alternative monitoring for similar potline has been granted, monthly 

monitoring shall be performed using the approved alternative monitoring procedures to 

demonstrate compliance with the alternative emission limit for each similar potline as well as 

monitoring one of the similar potlines using monthly performance tests to demonstrate 

compliance with the TF 2.5 lbs/ton of aluminum produced limit. 

6) For the reduced monitoring schedules that have been approved, the permittee may continue to 

utilize the reduced schedules, but shall follow monthly monitoring schedules upon completion of 

construction authorized by this permit. Thereafter, the permittee must apply for and get approval 

from the Division for reduced monitoring frequency.” 

7) The daily amount of aluminum tapped from each potline shall be monitored and recorded. To 

determine the amount of aluminum tapped the permittee shall install, operate, and maintain a 

monitoring device. Calibration must be performed in accordance with the manufacturer’s 

instructions. 

8) The permittee shall visually inspect the exhaust stack(s) of each control device on a daily basis 

for evidence of any visible emissions indicating abnormal operation. 

9) Unless prior written approval by the Division for alternative control device operating parameters 

has been granted, the permittee shall, as a minimum, install devices for the wet scrubbers for the 

measurement of water and air flow.

10) The permittee shall maintain a continuous parameter monitoring system for each 

 emission control device: 

i) If the monitoring system for a primary control device measures an operating parameter 

outside the range required to be established pursuant to 40 CFR 63.847(h), or if visible 

emissions indicating abnormal operation are observed from the exhaust stack of a control 

device during a daily inspection, the permittee shall initiate the corrective action procedures 

identified in the Startup, Shutdown, and Malfunction Plan within 1 hour. 

ii) Failure to initiate the corrective action procedures within 1 hour or to take the necessary 

corrective actions to remedy the problem is a violation. 

iii) If the range for a given operating parameter associated with monitoring a specific control 

device is exceeded six times in any semiannual reporting period, then any subsequent 

exceedance in that reporting period is a violation. 

iv) For the purpose of determining the number of exceedances, no more than one exceedance 

shall be attributed in any given 24-hour period. 

11) The permittee shall monitor the actions taken during any startup, shutdown, and 

malfunction event. 

12) The TF emissions can be measured from one potline and monitored from other similar potlines 

 by alternative procedures provided the permittee demonstrates that the potlines are similar. 

e) Pursuant to 401 KAR 51:017: 
Permit Number: V-08-012 Page: 20 of 61

SECTION B - EMISSION POINTS, EMISSION UNITS, APPLICABLE REGULATIONS, AND 

OPERATING CONDITIONS (CONTINUED) 

1) The PM10/PM2.5 emissions from potlines 1-4 shall be monitored through a quarterly performance 

 tests conducted as specified in 3.Testing Requirements above. PM10/PM2.5 emissions shall be 

computed and recorded using equation 2.c above. 

2) The SO2 emissions from potlines 1-4 shall be monitored through a quarterly performance test 

conducted as specified in 3.Testing Requirements above. SO2 emissions shall be computed and 

 recorded using the equation in 2.f above. 

 

 f) To preclude PSD (401 KAR 51:017): 

 1) The NOx emissions from potlines 1-4 shall be monitored through a performance test conducted 

 once during the life of this permit. 

 2) The VOC emissions from potlines 1-4 shall be monitored through a performance test conducted 

 once during the life of this permit. 

 g) The permittee shall install, operate, calibrate, and maintain a continuous monitoring system for the 

control equipment pursuant to the approved parametric monitoring plan, which is summarized in 

Attachment B to the permit, as provided in 40 CFR 63.848(f). Corrective action shall be as provided 

in 40 CFR 63.848(h). 

5. Specific Record Keeping Requirements:

a) Records shall be maintained of the following: 

1) Daily qualitative visual observation; and Method 9 observations if performed; 

2) Quarterly Reference Method 9 opacity readings; 

3) Control equipment excursions from their established operating ranges; 

4) The daily total aluminum production on Potlines 1-4; 

5) Monthly hours of operation; and 

6) Monthly anode consumption in potline 1-4. 

7) Records of sulfur contents of coal and pitch from standard ASTM method, an approved 

alternative method, or by vendor Certificate of Analysis per barge shipment basis. 

b) Pursuant to 40 CFR 63 Subpart LL, the permittee shall maintain records of the cell or potline 

voltage. 

c) The permittee shall maintain records of ambient air monitoring results of flouroides. 

d) The permittee shall maintain records of all information (including all reports and notifications) 

required by 40 CFR 63.10(b) and by 40 CFR 63 Subpart LL. In addition to the general records 

required by 40 CFR 63.10(b), the permittee shall maintain the following information: 

1) Records of the monthly TF emission rates calculated using equation 40 CFR 63.847(e); 

2) Results of each performance test run; 

3) Records that demonstrate that the operating parameters established under 40 CFR 63.847(h) are 

being met; 

4) Records of the calibration for all monitoring devices; 

5) Records of the daily production rate of aluminum; 

6) A copy of the startup, shutdown, and malfunction plan; 

7) Records supporting the monitoring of similar potlines demonstrating that the performance of 

similar potlines is the same as or better than that of potlines sampled by manual methods (if 

applicable); 
Permit Number: V-08-012 Page: 21 of 61

SECTION B - EMISSION POINTS, EMISSION UNITS, APPLICABLE REGULATIONS, AND 

OPERATING CONDITIONS (CONTINUED) 

8) Records supporting a request for reduced sampling of potlines (if applicable); 

9) Records supporting the correlation of emissions measured by a continuous emission monitoring 

 system to emissions measured by manual methods and the derivation of the alternative emission 

limit derived from the measurements (if applicable); 

10) A copy of the current implementation plan for emission averaging and any subsequent 

amendments (if applicable); 

11) Records, such as a checklist or the equivalent, demonstrating that the daily visual inspection of 

 the exhaust stack for each control device has been performed as required in 40 CFR 63.848(g), 

 including the results of each inspection; 

12) Records of the information and data required by 40 CFR 63.10(c), for a potline equipped with an 

HF continuous emission monitor (if applicable); 

13) Records documenting the corrective actions taken when the limit(s) for an operating parameter 

established under 40 CFR 63.847(h) were exceeded, or when visible emissions indicating 

abnormal operation were observed from a control device stack during a daily inspection required 

under 40 CFR 63.848(g); 

14) Records documenting the portion of TF that is measured as particulate matter and the portion 

that is measured as gaseous when the particulate and gaseous fractions are quantified separately 

using an approved test method; 

15) Records documenting the actions taken during a startup, shutdown, or a malfunction; and 

16) Records of the maintenance performed on all control and monitoring devices.

6. Specific Reporting Requirements:

a) The permittee may report required information on paper or in an electronic format using commonly 

available and compatible computer software.

b) The permittee shall submit a summary of all performance tests on an annual basis except as required 

below, in an excess emissions report (see f, below) and in 40 CFR 63.850(d). 

c) The permittee shall maintain a site-specific test plan according to the requirements of 40 CFR 63.7 

(c) for Division review and approval. The plan must include procedures for conducting the initial 

and subsequent performance tests required for emissions monitoring. In addition to the information 

required by 40 CFR 63.7, the plan shall include the following information: 

1) Procedures to ensure a minimum of three runs are performed annually for the primary control 

system for each source, 

2) Procedures for establishing the frequency of testing to ensure that at least one run is performed 

before the 15th of the month, at least one run is performed after the 15th of the month, and that 

there are at least 6 days between two of the runs during the month, or that secondary emissions 

are measured according to an approved alternate schedule, 

3) A test summary, the test schedule, data quality objectives (the pretest expectations of precision, 

accuracy, and completeness of data), and both an internal and external quality assurance (QA) 

program. The external and internal QA programs shall include, at a minimum, the information 

specified in 40 CFR 63.7 (2)(ii) and (iii), respectively.

d) The permittee shall maintain a description of the parameter(s) to be monitored, the operating limits, 

and the monitoring frequency to ensure that each control device is properly operated and maintained. 

An explanation of the criteria used to select each of the above, including how each relates to 

emission control, shall be included.
Permit Number: V-08-012 Page: 22 of 61

SECTION B - EMISSION POINTS, EMISSION UNITS, APPLICABLE REGULATIONS, AND 

OPERATING CONDITIONS (CONTINUED) 

e) The permittee shall submit semiannually reports that confirm that actions taken during the relevant 

reporting period during startup, shutdown, and malfunction were consistent with the affected 

source’s startup, shutdown, and malfunction plan. If action taken during the startup, shutdown, or 

malfunction is not consistent with the affected source’s plan, the permittee shall record the actions 

taken for the event and shall report such actions within two working days after commencing action 

 inconsistent with the plan followed by a letter within 7 working days after the end of the event, in 

accordance with 40 CFR 63.10(d)(5) (unless alternative reporting arrangement have been made in 

advance). 

f) As required by 40 CFR 63.10(e)(3), the permittee shall submit an excess emissions report (or a 

summary report) if measured emissions are in excess of the applicable standard. The report shall 

contain the information specified in 40 CFR 63.10(e)(3)(v) and be submitted semiannually, unless 

quarterly reports are required as a result of excess emissions. 

g) The permittee shall submit to the Division, quarterly ambient monitoring data reports if required. If 

the limit is exceeded six times in any semi-annual reporting period, then any subsequent exceedance 

in that reporting period is a violation. For the purpose of determining the number of exceedances, no 

more than one exceedance shall be attributed in any given 24-hour period. 

7. Specific Control Equipment Operating Conditions:

a) The permittee shall maintain a description of the parameters to be monitored, the operating limits, 

and the monitoring frequency to ensure that each control device is being properly operated and 

maintained. An explanation of the criteria used for selection of the parameters, the operating limits, 

and the monitoring frequency, including how these relate to emission control shall also be kept. 

b) The permittee shall maintain a continuous parameter monitoring system or equivalent system for 

each emission control device. The control devices shall be inspected at least once each operating 

day to ensure the control device is operating properly and the results of each inspection shall be 

recorded. The permittee shall visually inspect the exhaust stack of each control device on a daily 

basis for evidence of any visible emissions indicating abnormal operation. 

c) The permittee shall submit recommended accuracy requirements to the Division for review and 

approval. 

d) Control equipment shall operate at all times while potlines are in operation.

8. Compliance Schedule:

The permittee shall implement the parametric monitoring plan (with latest revision date of February 

4, 2011) within 120 days of the approval date (U. S. EPA approved the plan on February 7, 2011). 

(See Atttachment B) 

9. Compliance Certification Requirements:

 Pursuant to 40 CFR 63.848(k), the permittee shall certify that the required monitoring system is 

being maintained. 

10. Alternate Operating Scenario: 

None 
Permit Number: V-08-012 Page: 23 of 61

SECTION B - EMISSION POINTS, EMISSION UNITS, APPLICABLE REGULATIONS, AND 

OPERATING CONDITIONS (CONTINUED) 

PMACT CWPB1 Sources (Potline 5)

EP Group Equip. 

Desig. 

Cons./ 

date Description Controls & 

Requirements 

BACT LIMITS 

(lbs/hr) 

Operation Limits 

(Tons/Year) 

EMISSION GROUP 42 

89 42 4250 1998 Potline #5, CWPB1 

Dry Alumina 

Scrubber 4800 

63 

CO – 2,588.308 

F – 0.126 

HF – 0.685 

PM10 – 8.048 

PM – 13.875 

SO2 – 364.52 

VOC – 7.384 

66,000 tons 

aluminum 

produced 

90 42 3091 1998 Potline #5 Roof Monitor, 

CWPB1 

None – Vents 

to Atmosphere 

CO – 52.823 

F – 2.886 

HF – 5.342 

PM10 – 21.849 

PM – 37.671 

SO2 – 7.44 

VOC – 0.166 

66,000 tons 

aluminum 

produced 

APPLICABLE REGULATIONS:

40 CFR Part 63, Subpart LL, NESHAP for primary aluminum reduction plant 

401 KAR 51:017, PSD (applies to NOx, carbon monoxide, and sulfur dioxide emissions established in 1999) 

401 KAR 59:010, New process operations 

1. Operating Limitations:

 The following operational limits are to meet BACT and protect NAAQS: 

a) The permittee shall not exceed an aluminum production rate of 66,000 tons per year based upon a 

12-month rolling total (self-imposed). 

b) The petroleum coke used to make the green anodes shall not exceed 3.0 percent sulfur by weight and 

the pitch shall not exceed 0.80 percent sulfur by weight as measured by the standard ASTM method, 

an approved alternative method, or vendor Certificate of Analysis. 

c) The design capture efficiency for the collection system on the fifth potline shall equal, or exceed, 98 

percent.

2. Emission Limitations:

a) Pursuant to 401 KAR 59:010, visible emissions shall not exceed 20 percent opacity. 

Perform a qualitative visual observation of emissions from each stack/vent on a daily basis and 

maintain a log of the observation. The log shall note: 

i) Whether any air emissions (except for water vapor) were visible from the vent/stack, 

ii) All emission points from which visible emissions occurred. 

iii) Perform a Method 9 observation, if visual observations are observed. 

b) Pursuant to 401 KAR 51:017, the permittee shall not allow the combined emissions of particulate 

 
Permit Number: V-08-012 Page: 24 of 61

SECTION B - EMISSION POINTS, EMISSION UNITS, APPLICABLE REGULATIONS, AND 

OPERATING CONDITIONS (CONTINUED)

 matter greater than 10 microns (PM) from potline 5 to exceed 51.456 lbs/hr [daily rolling totals shall 

be used to calculate hourly average (on a monthly basis) using the monthly operational hours] 

(BACT). Note: This value shall be calculated using the following equation: 

Compliance Demonstration: 

Compliance with the applicable emissions of PM shall be demonstrated through use of the 

following equation: 

 EPM = [Monthly production in tons X Emission factor calculated using the most recent 

 stack test or listed in KYEIS (lbs/ton)]/ Monthly hours of operation 

 Monthly production rate is the sum of daily totals. 

c) Pursuant to 401 KAR 51:017, the permittee shall not allow the combined emissions of particulate 

matter less than or equal to 10 microns (PM10) from potline 5 to exceed 29.897 lbs/hr [daily rolling 

totals shall be used to calculate hourly average (on a monthly basis) using the monthly operational 

hours] (BACT). Note: This value shall be calculated using the following equation: 

Compliance Demonstration: 

Compliance with the applicable emissions of PM10 shall be demonstrated through use of the 

following equation: 

EPM10 = [Monthly production in tons X Emission factor calculated using the most recent 

stack test or listed in KYEIS (lbs/ton)]/ Monthly hours of operation 

 Monthly production rate is the sum of daily totals. 

 

d) Pursuant to 40 CFR 63.844(a)(1), the emissions of TF into the atmosphere shall not exceed 1.2 

lbs/ton of aluminum produced. 

 Compliance Demonstration: 

i) The following equation will be used to demonstrate compliance with the Subpart LL 

requirements 40 CFR 63.847(e): 

ETF = (Cs1 x Qsd)1 + (Cs2 x Qsd)2 40 CFR 63.847(e) (P x K) 

Where: 

− Ep is the emission rate of total fluorides from the potline in lbs/ton 

− Cs1 is the concentration of total fluorides from the primary control system in mg/dscf 

− Qsd is the volumetric flow rate of effluent gas corresponding to the appropriate 

location in dscf/hr 

− Cs2 is the concentration of total fluorides as measured for roof monitor emissions in 

mg/dscf 
Permit Number: V-08-012 Page: 25 of 61

SECTION B - EMISSION POINTS, EMISSION UNITS, APPLICABLE REGULATIONS, AND 

OPERATING CONDITIONS (CONTINUED) 

− P is the aluminum production rate in tons/hr 

− K is the conversion factor of 453,600 mg/lb 

− 1 denotes the primary control system effluent gas 

− 2 denotes the secondary control system or roof monitor effluent gas. 

ii) The aluminum production rate (P) shall be determined by dividing the number of hours in the 

calendar month into the weight of aluminum tapped during the calendar month that includes 

the three runs for a performance test. 

iii) The concentration and volumetric flow rate for the primary control system shall be 

determined from the previous 12-month average of all performance test runs (40 CFR 

63.848(a)). 

iv) The concentration and volumetric flow rate for the roof monitor shall be determined using 

the monthly average from at least three performance test runs (40 CFR 63.848(a)). 

e) SO2 emissions shall not exceed combined 371.96 lbs/hr [daily rolling totals shall be used to calculate 

hourly average (on a monthly basis) using the monthly operational hours]. Hourly sulfur dioxide 

emissions shall be measured by Reference Method 6 and averaged over 3 hours. (BACT) 

Compliance Demonstration: 

Compliance with the applicable hourly emissions of SO2: 

ESO2 = [monthly production in tons X emission factor of SO2 (per ton aluminum) using the most 

recent stack test or listed in KYEIS (lbs/ton)]/ monthly hours of operation 

 f) CO emissions shall not exceed 2641.13 lbs/hr (monthly average). Hourly CO emissions shall be 

measured by Method 10, 10A, or 10B and averaged over the minimum time specified in the standard 

(BACT). 

 g) VOC emissions shall not exceed 7.55 lbs/hour (monthly average). Hourly volatile organic 

compound emissions shall be measured by Reference Method 25 or 25A and averaged over 3 hours 

or the minimum specified time (BACT). 

3. Testing Requirements:

 

a) All performance tests shall be conducted in accordance with Section D of this permit and under 

conditions representative of the emission unit’s normal operation.

b) Annual performance tests, starting within 30 calendar days of the anniversary date of the initial 

performance test, shall be conducted on the potline 5 exhaust stack and the roof monitor for SO2, 

CO, VOC, PM and PM10. 

The permitee shall perform one annual test on those pollutants that were less than or equal to 75% of 

the permit limit during the previous permit period. If the results of the annual test remain less than 

or equal to 75% of the permit limit, then no additional testing of those pollutants is required for the 

duration of the current permit. 

If the result(s) of testing are not less than or equal to 75% of the permit limit or if no testing was 

performed on a pollutant during the previous permit period, then annual testing will commence until 

two consecutive annual tests demonstrate that the emissions of SO2, CO, VOC, PM and PM10 are 
Permit Number: V-08-012 Page: 26 of 61

SECTION B - EMISSION POINTS, EMISSION UNITS, APPLICABLE REGULATIONS, AND 

OPERATING CONDITIONS (CONTINUED) 

less than or equal to 75% of the standards specified herein. No additional testing shall be required 

during the term of this permit once two consecutive annual tests have met these criteria. 

c) The permittee shall perform quarterly performance tests for PM during the first year of this permit at 

each of the following sources using Reference Method 5 for compliance demonstration with 401 

KAR 59:010 and 401 KAR 51:017 and thereafter once a year during the life of this permit: 1) potline 

5 roof monitor and 2) potline 5 control stack. 

d) The permittee shall perform quarterly performance test during the first year of this permit for PM10

at each of the following sources using Reference Method 201for compliance demonstration with 401 

KAR 51:017 and thereafter once a year during the life of this permit: 1) potline 5 roof monitor and 

2) Potline 5 control stack. 

e) The permittee shall utilize the following EPA Reference Methods for the listed pollutants: 

Pollutant Method 

PM Reference Method 5 

PM10 Reference Method 201 

SO2 Reference Method 6 

CO Reference Method 10, 10A, or 10B 

VOC Reference Method 25 or 25A 

f) Aluminum production shall also be monitored and recorded during the performance test. 

 

g) The amount of aluminum tapped shall be determined and recorded during the month of the 

performance test on the potline. 

h) Emission factors shall be developed from the most recent performance test and the specified 

operational limit. 

i) The permittee shall perform tests in accordance with CFR 63.847 (b)-(d) using the test methods and 

procedures in 40 CFR 63.849. 

j) Pursuant to 40 CFR 63.847, the test plan must include procedures for conducting the performance 

 tests required in 40 CFR 63.848 for emission monitoring. In addition to the information required by 

40 CFR 63.7, the test plan shall include: 

1) Procedures to ensure a minimum of three runs are performed annually for the primary control 

system for each source, and 

2) Procedures for establishing the frequency of testing to ensure that at least one run is performed 

before the 15th of the month, at least one run is performed after the 15th of the month, and that 

there are at least six days between two of the runs during the month, or that secondary emissions 

are measured according to an alternate schedule satisfactory to the applicable regulatory 

authority. 

k) The permittee shall measure and record at least three runs each month for secondary emissions and 

 
Permit Number: V-08-012 Page: 27 of 61

SECTION B - EMISSION POINTS, EMISSION UNITS, APPLICABLE REGULATIONS, AND 

OPERATING CONDITIONS (CONTINUED) 

 at least three runs each year for the primary control system to determine compliance with the 

applicable emission limits. 

l) All performance tests shall be conducted in accordance with the requirements of the general 

provisions in Subpart A of Part 40 CFR 63, the approved test plan, and the procedures in 40 CFR 63 

Subpart LL. 

m) The permittee shall use the reference methods listed in 40 CFR 63.849 to determine compliance with 

the applicable emission limits for TF. 

4. Specific Monitoring Requirements: 

a) To provide reasonable assurance that the visible emission limitations are being met, the permittee 

shall perform quarterly visible emission readings on potline stack using Reference Method 9. 

b) To provide reasonable assurance that the PM/PM10 emissions limitations are being met: 

1) The permittee shall monitor the 12-month rolling total amount and type of operational 

 throughput added to each emission unit, as specified above, as well as conduct an annual 

performance test. 

2) The permittee shall continuously monitor the air flow rate and pressure drop across the 

baghouses. 

3) Monthly particulate emissions shall be calculated for each emission point as follows: 

PE = (TP x PEF) 

(2,000 lbs/ton) 

Where: 

− PE = Emissions of PM/PM10 in tons emitted per month. 

− TP = actual throughput (operation limit) in tons/month. 

− PEF = PM/PM10 emission factor in lbs/ton of throughput. 

4) The particulate emission factors used shall be the number determined from the most recent 

compliance test required in the above 3. Testing Requirements Section or other emission test, 

or alternate emission factors approved by the Division. 

c) Pursuant to 40 CFR 63.848(a), 

1) The TF emissions shall be monitored through monthly roof monitor performance tests specified 

in the 3. Testing Requirements section and in 40 CFR 63 Subpart LL. 

 If a reduced sampling frequency is approved the TF emissions from the roof monitors shall be 

monitored quarterly using the approved test schedule and methods. Compliance TF emissions 

shall be computed and recorded quarterly using Equation 2.d above. 

2) The daily amount of aluminum tapped shall be monitored and recorded. To determine the 

amount of aluminum tapped the permittee shall install, operate, and maintain a monitoring 

device. Calibration must be performed in accordance with the manufacturer’s instructions. 

3) The permittee shall visually inspect the exhaust stack(s) of each control device on a daily basis 
Permit Number: V-08-012 Page: 28 of 61

SECTION B - EMISSION POINTS, EMISSION UNITS, APPLICABLE REGULATIONS, AND 

OPERATING CONDITIONS (CONTINUED) 

 for evidence of any visible emissions indicating abnormal operation. 

4) The permittee shall maintain a continuous parameter monitoring system for the emissions control 

device. Unless prior written approval by the Division for alternative control device operating 

parameters has been granted, the permittee shall, as a minimum, install devices for the dry 

alumina scrubbers for the measurement of alumina flow and air flow. 

i) If a monitoring device for a primary control device measures an operating parameter outside 

 the range(s) required to be established pursuant to 40 CFR 63.847(h), or if visible emissions 

 indicating abnormal operation are observed from the exhaust stack of a control device during 

a daily inspection, the permittee shall initiate the corrective action procedures identified in 

the startup, shutdown, and malfunction plan within 1 hour. 

ii) Failure to initiate the corrective action procedures within 1 hour, or to take the necessary 

corrective actions to remedy the problem, is a violation. 

iii) If the range for a given operating parameter associated with monitoring a specific control 

device is exceeded six times in any semiannual reporting period, then any subsequent 

exceedance in that reporting period is a violation. 

iv) For the purpose of determining the number of exceedances, no more than one exceedance 

 shall be attributed in any given 24-hour period. 

5) The permittee shall monitor the actions taken during any startup, shutdown, and malfunction 

event as provided for in 40 CFR 63.6(e)(3). 

6) Monthly throughputs shall be monitored and recorded to assure compliance with the operational 

 limits. 

7) Aluminum production shall be monitored daily. 

8) Anode consumption and hours of operation shall be monitored monthly. 

e) The permittee shall continue to operate and maintain ambient air monitoring equipment for the 

detection of fluorides. This equipment shall be located at sites specified by the Division. 

f) The permittee shall install, operate, calibrate, and maintain a continuous monitoring system for the 

control equipment pursuant to the approved parametric monitoring plan, which is summarized in 

Attachment B to the permit, as provided in 40 CFR 63.848(f). Corrective action shall be as provided 

in 40 CFR 63.848(h). 

 

5. Specific Record Keeping Requirements:

a) Monthly throughputs shall be recorded to assure compliance with the operational limitations. 

b) Records shall be maintained of visible emission readings using Reference Method 9, baghouse 

pressure drops and air flow rate, monthly specified operational limits (throughput), performance test 

results, the derived emission factor and the monthly particulate emission calculations. Records shall 

 be maintained for five years. 

c) The permittee shall maintain records of all information (including all reports and notifications) 

required by 40 CFR 63.10(b) and by 40 CFR 63, Subpart LL. Each record must be maintained for at 

least five years following the date of each occurrence, measurement, maintenance, corrective action, 

report, or record. The most recent two years of records must be retained at the facility. The 

remaining three years of records may be retained offsite. Records may be retained on microfilm, on a 

computer, on computer disks, on magnetic tape, or on microfiche. In addition to the general records 
Permit Number: V-08-012 Page: 29 of 61

SECTION B - EMISSION POINTS, EMISSION UNITS, APPLICABLE REGULATIONS, AND 

OPERATING CONDITIONS (CONTINUED) 

 

 required by 40 CFR 63.10(b), the permittee shall maintain the following information: 

1) Records of the monthly TF emission rates calculated using Equation 2.d above; 

2) Records of the results of each performance test run; 

3) Records demonstrating that the operating parameters established under 40 CFR 63.847(h) are 

being met; 

4) Records of the calibration and maintenance for all monitoring and control devices; (if 

applicable); 

5) Records of the daily production rate of aluminum; 

6) A copy of the startup, shutdown, and malfunction plan; 

7) Records supporting a request for reduced sampling of potlines (if applicable); 

8) Records supporting the correlation of emissions measured by a continuous emission monitoring 

 system to emissions measured by manual methods and the derivation of the alternative emission 

limit derived from the measurements (if applicable); 

9) Records, such as a checklist or the equivalent, demonstrating that the daily visual inspection of 

the exhaust stack for each control device has been performed as required in 40 CFR 63.848(g), 

including the results of each inspection; 

10) Records of the information and data required by 40 CFR 63.10(c), for a potline equipped with 

an HF continuous emission monitor (if applicable); 

11) Records documenting the corrective actions taken when the limit(s) for an operating parameter 

established under 40 CFR 63.847(h) were exceeded, or when visible emissions indicating 

abnormal operation were observed from a control device stack during a daily inspection 

required under 40 CFR 63.848(g); 

12) Records documenting the portion of TF that is measured as particulate matter and the portion 

that is measured as gaseous when the particulate and gaseous fractions are quantified separately 

using an approved test method; and

13) Records documenting the actions taken during a startup, shutdown, or a malfunction.

d) Ambient air monitoring results shall be recorded. 

6. Specific Reporting Requirements: 

a) Any exceedance over the particulate emission limits or opacity limits shall be reported, in writing, to 

the Division no later than 30 days after the exceedance. 

1) Following initial notification of an exceedance, monthly reports shall be submitted, by the 

fifteenth of each month, to the Division’s Owensboro Regional Office. 

2) Monthly reports shall contain individual emission units’ monthly and 12-month rolling PM/PM10 

 emission estimates and a summation of all emission units’ 12-month rolling PM10 emissions. 

3) Monthly reports shall be submitted until there have been 12 consecutive months without any 

exceedance. 

b) The permittee shall also certify to the Division, annually, that the specified records are being kept for 

this emission point and that any exceedances were reported. 

c) The permittee may report required information on paper or in an electronic format using commonly 

available and compatible computer software.

 
Permit Number: V-08-012 Page: 30 of 61

SECTION B - EMISSION POINTS, EMISSION UNITS, APPLICABLE REGULATIONS, AND 

OPERATING CONDITIONS (CONTINUED)

d) The permittee shall report the results of the initial performance test as part of the notification of 

compliance status required in the compliance section. The permittee shall submit a summary of 

all subsequent performance tests on an annual basis except as required in (h), below, and in 40 CFR 

 63.850(d). 

e) As part of the compliance test report, the permittee shall submit a description of the parameter(s) 

 monitored, the operating limits, and the monitored range to ensure that the each control device is 

being properly operated and maintained. 

f) The permittee shall develop and submit, if requested, an engineering plan that describes the 

 techniques that will be used to address the capture efficiency of the reduction cells for gaseous 

hazardous air pollutants in compliance with the specified emission limits. 

g) The permittee shall submit semi-annual reports to confirm that actions taken during the relevant 

reporting period during startup, shutdown, and malfunction were consistent with the affected 

source’s startup, shutdown, and malfunction plan. 

1) If action taken during the startup, shutdown, or malfunction is not consistent with the affected 

source’s plan, the permittee shall record the action taken for the event and shall report 

such actions within two working days after commencing action inconsistent with the plan and 

then follow by submitting a letter within 7 working days after the end of the event, in accordance 

with 40 CFR 63.10(d)(5) (unless alternative reporting arrangements have been made in advance). 

2) Additionally, the permittee shall submit, for the Division’s review and approval, any 

modifications to the affected source’s startup, shutdown, and malfunction plan. 

h) As required by 40 CFR 63.10(e)(3), the permittee shall submit an excess emissions report (or a 

summary report) if measured emissions are in excess of the applicable standard. The report shall 

contain the information specified in 40 CFR 63.10(e)(3)(v) and shall be submitted semi-annually, 

unless quarterly reports are required as a result of excess emissions.

i) The permittee shall submit quarterly ambient monitoring data reports to the Division, if required. If 

the ambient limit is exceeded 6 times in any semi-annual reporting period, then any subsequent 

exceedance in that reporting period is a violation. For the purpose of determining the number of 

exceedances, no more than one exceedance shall be counted in any given 24-hour period. 

7. Specific Control Operating Conditions:

a) The dry alumina scrubber shall operate within the parameters required to be established in the 3.

Testing Requirement section and in 40 CFR 63.847 (h) and (f). 

b) The permittee shall install, maintain, and operate the dry alumina scrubber system in accordance 

 with the manufacturer’s specification. 

c) Control equipment shall operate at all times while potline is in operation.

8. Compliance Schedule:
Permit Number: V-08-012 Page: 31 of 61

SECTION B - EMISSION POINTS, EMISSION UNITS, APPLICABLE REGULATIONS, AND 

OPERATING CONDITIONS (CONTINUED) 

The permittee shall implement the parametric monitoring plan (with latest revision date of February 

4, 2011) within 120 days of the approval date (U. S. EPA approved the plan on February 7, 2011). 

(See Atttachment B) 

9. Compliance Certification Requirements:

 

 Pursuant to 40 CFR 63.848(k), the permittee shall certify that the required monitoring system is 

maintained as required. 

10. Alternate Operating Scenario:

None 
Permit Number: V-08-012 Page: 32 of 61

SECTION B - EMISSION POINTS, EMISSION UNITS, APPLICABLE REGULATIONS, AND 

OPERATING CONDITIONS (CONTINUED) 

PMACT Source – Anode Baking Furnaces (1, 2, and 3) 

EP Group Equip. 

Desig. 

Cons./ 

date Description Controls & 

Requirements 

BACT LIMITS 

(lbs/hr) 

Operation Limits 

(Tons/Year) 

EMISSION GROUP 33 

41 33 3301 

3302 

3307 

1969 

1969 

1999 

Furnace #1, Anode 

Baking (45) 

336 mmcf/year burners 

Furnace #2, Anode 

Baking (45) 

336 mmcf/yr burners 

Furnace #3, Anode 

Baking (45) 

228 mmcf/yr burners 

Dry Alumina 

Scrubber 

330140 

Combined: 

CO – 219.25 

F – 3.220 

HF – 0.697 

*NOx – 39.565 

PM10 – 3.575 

PM -3.575 

**POM – 4.22 

SO2 – See emission 

limitations 

*VOC – 5.461 

Combined: 

245,100 tons 

Green Anodes 

900 mmcf/yr 

* VOC and NOx limits are Synthetic Minor Limits 

** POM is not a BACT limit

APPLICABLE REGULATIONS:

40 CFR Part 63, Subpart LL, NESHAP for primary aluminum reduction plant

401 KAR 59:010, New process operations (applies to the visible emissions). 

Self-imposed limitations supersedes the mass emissions standards prescribed by 401 KAR 59:010 

401 KAR 51:017, Prevention of significant deterioration of air quality (PSD) (applies to carbon monoxide, 

sulfur dioxide, Fluoride, PM/PM10 emissions). 

PSD applies to production increases in anode bake associated with operating capacity increases on Potlines 1-4. 

1. Operating Limitations:

a) The rolling 12-month amount of green anode processed shall not exceed 245,100 tons (selfimposed). 

b) The rolling 12-month amount of packing coke consumed shall not exceed 106,800 tons (selfimposed). 

c) Natural gas usage for Furnaces #1 & #2 shall not exceed 336 mmcf per 12-month period per oven 

(self-imposed). 

d) Natural gas usage for the Furnace #3 shall not exceed 228 mmcf per 12-month period (selfimposed). 

e) Combined propane usage shall not exceed 675,000 gallons/12-month period for all three furnaces 

combined (self-imposed). 

f) The following operational limits are BACT limits to protect NAAQS: 

1) The petroleum coke used to make the green anodes shall not exceed 3.0 percent sulfur by weight 

and the pitch shall not exceed 0.80 percent sulfur by weight as measured by the standard ASTM 

method, an approved alternative method, or by vendor Certificate of Analysis. 

2) The volatile organic matter (VOM) contents of the petroleum coke shall be calculated by 

 
Permit Number: V-08-012 Page: 33 of 61

SECTION B - EMISSION POINTS, EMISSION UNITS, APPLICABLE REGULATIONS, AND 

OPERATING CONDITIONS (CONTINUED) 

subtracting the coking value of the as-received material from one (1) [( 1-coking value = VOM 

content)]. The VOM content of the pitch shall be determined from information submitted by the 

supplier. Performance tests must be performed prior to changes in the coking value. 

2. Emission Limitations:

a) Pursuant to 401 KAR 59:010, visible emissions shall not exceed 20 percent opacity. 

 Compliance Demonstration: 

See 4. Specific Monitoring Requirements

b) NOx emissions from the existing ovens natural gas, pitch and coke combustion, expressed as NO2, 

shall be determined by Reference Method 7 or 7E, Appendix A, 40 CFR 60, shall not exceed 39.57 

lbs/hr and 173.32 tons/yr (monthly average) to preclude PSD applicability. 

Note: Nitrogen Oxide emissions from propane, only, shall not exceed 6.41 tons/yr (Synthetic 

minor limit). 

Compliance Demonstration: 

See 3. Testing Requirements below. Monthly NOx emissions shall be calculated and shall 

added to calculate 12-month rolling total. 

Monthly NOx emissions = [Monthly production in tons X Emission factor calculated using the 

most recent stack test or listed in KYEIS (lbs/ton)]/ Monthly hours of 

operation 

c) SO2 emissions shall not exceed 139.959 lbs/hr (monthly average). Hourly sulfur dioxide emissions 

shall be measured by Reference Method 6 and averaged over 3 hours (BACT). 

Compliance Demonstration: 

SO2 emissions in pounds per hour = Sum of SO2 emissions from green anodes and combustion 

of natural gas 

 SO2 from processing green anodes calculated as follows: 

Pounds of anodes placed under fire for each month (lbs) 

X weighted average pitch percentage in green anode for each month 

X weighted average sulfur percentage in the pitch received from the supplier each month 

X 2 (factor to convert S to SO2 based on molar mass of S of 32 versus SO2 of 64) 

÷ hours of anode bake operations (no. of days of bake operations per mo. X 24 hr/day) 

SO2 from combustion of natural gas calculated as follows: 

Amount of natural gas consumed in anode bake per month (in mmcf) 

X 0.06 lbs SO2/mmcf (million cubic feet) natural gas (US EPA AP42 factor) 

÷ hr. of anode bake operations (no. of days of bake operations per mo. X 24 hr/day) 
Permit Number: V-08-012 Page: 34 of 61

SECTION B - EMISSION POINTS, EMISSION UNITS, APPLICABLE REGULATIONS, AND 

OPERATING CONDITIONS (CONTINUED) 

See 4. Monitoring Requirements below for the sulfur content requirements for raw material 

(coke and pitch) and baked anode. Sulfur content must be determined for each batch produced 

via an ASTM approved method. Records shall be maintained for each batch produced including 

hours of batch operation, mass of sulfur input and mass of sulfur in the baked anode. 

d) Hourly CO emissions shall not exceed 219.246 lbs/hr (monthly average) and shall be measured by 

Reference Method 10, 10A, or 10B and averaged over the minimum time specified in the standard, 

or 3 hours, whichever is less (BACT). 

e) Hourly VOC emissions shall be measured by Reference Method 25 or 25A and averaged over 3 

hours or the minimum time specified in the method. VOCs shall not exceed 5.461 lbs/hr (monthly 

average) to preclude PSD applicability (Synthetic minor limit). 

f) The hourly PM/PM10 emissions shall not exceed 3.575 lbs/hr (monthly average) as measured by 

Reference Method 5, averaged over three hours or the minimum specified time in the standard 

(BACT). 

 

g) Pursuant to 40 CFR 63.843(c) (1) (2), for existing sources (furnaces 1 and 2), emissions of TF and 

POM shall not exceed 0.2 lb/ton of green anode and 0.18 lb/ton of green anode, respectively. 

h) Pursuant to 40 CFR 63.844(c) (1) (2), for new source (furnace 3), emissions of TF and POM shall 

not exceed 0.02 lb/ton of green anode and 0.05 lb/ton of green anode, respectively. 

 Compliance Demonstration: 

A) Compliance with the POM and TF emission rates shall be determined by the following 

equations: 

Furnace # 1(Existing Source)

Controlled emission rate furnace #1 (lb/hr) = (1 – overall dry alumina scrubber control 

efficiency) x the measured emission rate from furnace #1 duct (lb/hr) 

Controlled emission rate furnace #1 (lb/ton) = Controlled emission rate (lb/hr) /average 

hourly production rate for furnace #1 (ton/hr) 

Furnace # 2 (Existing Source)

Controlled emission rate furnace #2 (lb/hr) = (1 – overall dry alumina scrubber control 

efficiency) x the measured emission rate from furnace #2 duct (lb/hr) 

Controlled emission rate furnace #2 (lb/ton) = Controlled emission rate (lb/hr) /average 

hourly production rate for furnace #2 (ton/hr) 

Furnace # 3 (New Source)

Controlled emission rate furnace #3 (lb/hr) = (1 – overall dry alumina scrubber control 

efficiency) x the measured emission rate from furnace #3 duct (lb/hr) 

 
Permit Number: V-08-012 Page: 35 of 61

SECTION B - EMISSION POINTS, EMISSION UNITS, APPLICABLE REGULATIONS, AND 

OPERATING CONDITIONS (CONTINUED) 

Controlled emission rate furnace #3 (lb/ton) = Controlled emission rate (lb/hr) /average 

hourly production rate for furnace #3 (ton/hr) 

WHERE: 

Dry alumina scrubber Control Efficiency = 1 – [(Controlled emission rate (lb/hr) /sum of 

the measured emission rate furnace 1, 2, 3 ducts)] 

Average hourly production rate = The rate of green anode material introduced into the 

furnace shall be determined by dividing the number of operating hours in the calendar 

month into the weight of green anode material used during the calendar month in which 

the performance test was conducted. 

Controlled emission rate is the emission rate after the control and shall be the tested for 

emissions while three furnaces are operating the maximum design rate. 

B) The rate of green anode material introduced into the furnace shall be determined by 

dividing the number of operating hours in the calendar month into the weight of green 

anode material used during the calendar month in which the performance test was 

conducted. 

C) Compliance demonstration for VOC emissions limits shall be determined by calculating 

the VOC monthly emissions based on VOC emissions from natural gas use and VOC 

emissions from the processing of green anodes. The VOC emissions factor shall be 

determined from the compliance test. 

D) Compliance demonstration for NOx emissions limits shall be determined by calculating 

the NOx emissions monthly based natural gas consumption and weight of green anodes 

processed that month. The NOx emissions factor for NOx process emissions shall be 

determined from the compliance test. 

3. Testing Requirements:

 

a) Annual performance tests, shall be conducted on the carbon bake furnaces for SO2, CO, NOx, PM 

and PM10, starting within 30 calendar days of the anniversary date of the initial performance test. 

The permittee shall perform the annual test on those pollutants that were less than or equal to 75% of 

the permit limit during the previous permit period. If the results of the annual test remain less than 

or equal to 75% of the permit limit, then no additional testing of those pollutants is required for the 

duration of the current permit. 

If the result(s) of testing are not less than or equal to 75% of the permit limit, or if no testing was 

performed on a pollutant during the previous permit period, then annual testing will commence until 

two consecutive annual tests demonstrate that the emissions of CO, NOx, and PM/PM10 are less than 

or equal to 75% of the standards specified herein. No additional testing shall be required for the term 

of this permit once two consecutive test have met the criteria. 

b) The permittee shall utilize the following EPA Reference Methods for the listed pollutants: 
Permit Number: V-08-012 Page: 36 of 61

SECTION B - EMISSION POINTS, EMISSION UNITS, APPLICABLE REGULATIONS, AND 

OPERATING CONDITIONS (CONTINUED) 

Pollutant Method

PM Reference Method 5 

PM10 Reference Method 201 

VOC Reference Method 25 or 25A 

CO Reference Method 10, 10A, or 10B 

NOx Reference Method 7 

SO2 Reference Method 6 

POM Reference Method 315 

c) All performance tests shall be conducted in accordance with Section D of this permit and under 

conditions representative of the emission unit’s normal operation.

d) The amount of green anodes baked and the amount of packing coke used shall be determined and 

recorded during each performance test of the carbon bake furnaces. 

 

e) Emission factors shall be developed from the most recent performance test and the specified 

operational limit. 

 

f) Pursuant to 40 CFR 63.847(b) and (d)(4), the permittee shall submit for approval an alternative test 

plan for determining the limits set forth in Section 2.g and 2.h, above. 

g) The parameters to be tested for compliance with the limits set forth in Section 2.g and 2.h, above are: 

1) Measured emission rate from furnace #1,#2, and # 3 ducts 

2) Measured emission rate after the control device while all the furnaces are operational and 

running at maximum design rate 

3) Determine overall dry alumina scrubber control efficiency 

h) All valid data from performance tests shall be included in the annual average. 

i) Compliance is demonstrated when the emission rates of TF and POM are equal to or less than the 

applicable TF and POM emission limit. 

j) The parametric range for the emission control system parameter(s) shall be determined from the 

values recorded during each of the runs performed during the initial performance test and subsequent 

compliance tests. See 7. Specific Control Equipment Operating Condition below.

k) All performance tests (measurements) shall be conducted in accordance with the requirements of the 

general provisions in 40 CFR 63, Subpart A, the approved test plan, the requirements specified in 40 

CFR 63 Subpart LL, the requirements specified in SECTION D of this permit, and shall be 

performed using the appropriate Reference Method. 

l) For continued PSD compliance demonstration, the facility will conduct a SO2 emissions test 

pursuant to a) above to confirm that the SO2 emissions from anode bake do not exceed 139.959 

pounds per hour. Additional testing may be required pursuant to 3.a. Testing Requirements above. 

m) For continued PSD compliance demonstration, the facility will conduct a PM/PM10 emissions test 
Permit Number: V-08-012 Page: 37 of 61

SECTION B - EMISSION POINTS, EMISSION UNITS, APPLICABLE REGULATIONS, AND 

OPERATING CONDITIONS (CONTINUED) 

pursuant to a) above to confirm that the PM/PM10 emissions from anode bake do not exceed 3.575 

lbs/hr. Additional testing may be required pursuant to 3.a. Testing Requirements above. 

n) For continued PSD compliance demonstration, the facility will conduct a CO emissions test pursuant 

to a) above to confirm that the CO emissions from anode bake do not exceed 219.246 lbs/hr. 

Additional testing may be required pursuant to 3.a. Testing Requirements above. 

o) To preclude the applicability of PSD, the facility will conduct a VOC emissions test pursuant to a) 

above to confirm that the VOC emissions from anode bake do not exceed 5.461 lbs/hr. A VOC 

emission factor shall be developed from this performance test. Additional testing may be required 

pursuant to 3.a. Testing Requirements above. 

p) To preclude the applicability of PSD, the facility will conduct one NOx emissions test pursuant to a) 

above to confirm that the NOx emissions from anode bake do not exceed 39.56 lbs/hr. A NOx

emission factor shall be developed from this performance test. 

4. Specific Monitoring Requirements:

a) The permittee shall monitor and record the monthly fuel usage rates of natural gas and propane 

separately for each of the new and existing ovens. 

b) 12-month rolling total throughputs shall be monitored and recorded to assure compliance with the 

operational limitations found in the Operating Limitations section. 

c) Sulfur contents of the coke and the pitch shall be monitored and determined with an ASTM standard, 

alternative method, or utilize vendor Certificates of Analysis. Each method shall be approved by the 

Division. The method used to determination sulfur content of coke shall assure that 

the average percent sulfur by weight of each shipment of coke will not exceed 3.0 percent. The 

percent sulfur by weight of the pitch shall be determined by weekly ASTM, alternative sampling of 

each of the pitch storage tank, or by vendor Certificate of Analysis. The method used to 

determination sulfur content of pitch shall assure that the average percent sulfur by weight of each 

shipment of pitch will not exceed 0.8 percent. 

d) Annual performance testing as specified in the 3. Testing Requirements section. 

e) The permittee shall monitor the total weight of green anodes placed under fire each month and 

monthly hours of operation. 

f) The carbon bake furnaces’ fuel usage rates of natural gas and propane and furnace finish temperature 

shall be monitored monthly. The existing and new furnaces’ natural gas consumption rate shall be 

monitored separately. 

g) Dry scrubber operational parameters as per the parametric plan, shall be constantly monitored. 

h) Monitoring of the VOM contents of the pitch and petroleum coke shall be maintained. 

i) To provide reasonable assurance that the visible emission limitations are being met, the permittee 
Permit Number: V-08-012 Page: 38 of 61

SECTION B - EMISSION POINTS, EMISSION UNITS, APPLICABLE REGULATIONS, AND 

OPERATING CONDITIONS (CONTINUED) 

shall perform quarterly visible emission readings on the carbon bake furnaces’ primary control 

system stack using Reference Method 9. Additionally, compliance assurance will be provided by the 

periodic monitoring specified in 40 CFR 63, Subpart LL. 

j) To provide reasonable assurance that the particulate matter emission limitations (PM/PM10) are 

being met, 

1) The permittee shall monitor the monthly amount and type of process throughput added to each 

emission unit as well as conduct annual performance test. 

2) The permittee shall continuously monitor the air flow rate and pressure drop across the 

baghouses. 

3) Monthly particulate emissions shall be calculated for each emission unit as follows: 

PE = (TP x PEF) 

(2,000 lbs/ton) 

Where: 

− PE = particulate emissions of PM/PM10 emitted in tons/month 

− TP = actual throughput (operation limit) in tons/month 

− PEF = PM/PM10 particulate emission factor in lbs/ton of throughput 

4) The particulate emission factors shall be determined from the most recent compliance test 

required in the above 3. Testing Requirements section, other emission test, or emission factors 

shall be approved by the Division. 

5) Excursions from the control equipment’s operating ranges shall be promptly corrected as per 

Startup/Shutdown Malfunction Plan. 

k) Using the procedures in 40 CFR 63.847, in the approved test plan, and in the 3. Test Requirements

section, above, the permittee shall monitor TF and POM emissions from each anode bake furnace on 

an annual basis. 

l) The amount of green anode material placed in the furnace shall be monitored. The weight may be 

determined by monitoring the weight of all anodes or by monitoring the number of anodes placed in 

the furnace and determining an average weight from measurements of a representative samples of 

anodes. 

 

m) To provide reasonable assurance that the visible emission limitations are being met, the permittee 

shall: 

1) Perform a qualitative visual observation of the opacity of emissions from each stack/vent on a 

weekly basis and maintain a log of the observations. The log shall note: 

i) Whether any air emissions (except for water vapor) were visible from the vent/stack, 

ii) All emission points from which visible emissions occurred, and 

 2) Perform a Method 9 observation if visible emissions are observed. 

n) The permittee shall install, operate, calibrate (performed in accordance with the manufacturer’s 

instructions), and maintain a continuous parameter monitoring system for each emission control 
Permit Number: V-08-012 Page: 39 of 61

SECTION B - EMISSION POINTS, EMISSION UNITS, APPLICABLE REGULATIONS, AND 

OPERATING CONDITIONS (CONTINUED) 

device. Unless prior written approval by the Division for alternative control device operating 

parameters has been granted, the permittee shall, as a minimum, install devices for the dry alumina 

scrubbers for the measurement of alumina flow and air flow. 

1) If a monitoring device for a primary control device measures an operating parameter outside the 

limit(s) required to be established pursuant to 40 CFR 63.847(h), or if visible emissions 

indicating abnormal operation are observed from the exhaust stack of a control device during a 

weekly inspection, the permittee shall initiate the corrective action procedures identified in the 

startup, shutdown, and malfunction plan within one hour. Failure to initiate the corrective action 

procedures within one hour, or to take the necessary corrective actions to remedy the problem, is 

a violation. 

2) If the limit for a given operating parameter associated with monitoring a specific control device 

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 calendar day. 

o) The permittee shall monitor the actions taken during any startup, shutdown, and malfunction event. 

p) The permittee shall monitor the emissions of NOx and VOC on a monthly basis (and rolling total 12-

month period) using fuel usage and green anode process rates in order to confirm that the annual 

emission limits for NOx and VOC do not exceed the limits specified in this permit (In order to 

preclude PSD applicability). 

q) The permittee shall continue to operate and maintain ambient air monitoring equipment for the 

detection of fluorides. This equipment shall be located at sites specified by the Division. 

r) The permittee shall install, operate, calibrate, and maintain a continuous monitoring system for the 

control equipment pursuant to the approved parametric monitoring plan, which is summarized in 

Attachment B to the permit, as provided in 40 CFR 63.848(f). Corrective action shall be as provided 

in 40 CFR 63.848(h). 

5. Specific Record Keeping Requirements: 

a) Records shall be maintained of visible emission readings using Reference Method 9, monthly fuel 

usage rates, baghouse pressure drops and air flow rate, control equipment’s routine and emergency 

maintenance, monthly throughputs, performance test results, the derived emission factor and the 

monthly particulate emission calculations. 

b) The permittee shall maintain records of all information (including all reports and notifications) 

required by Section 40 CFR 63.10(b) and by 40 CFR 63 Subpart LL. In addition to the general 

records required by 40 CFR 63.10(b), the permittee shall maintain records of the following 

information: 

1) Annual TF and POM emission rates calculated using the equations in section 2. Emission 

Limitations Compliance Demonstration; 

2) Results of each performance test run; 

3) Demonstrating that the operating parameters established under Section 40 CFR 63.847(h) are 
Permit Number: V-08-012 Page: 40 of 61

SECTION B - EMISSION POINTS, EMISSION UNITS, APPLICABLE REGULATIONS, AND 

OPERATING CONDITIONS (CONTINUED) 

 being met; 

4) Calibration and maintenance for all monitoring and control devices; 

5) Pounds of green anodes placed under fire each month; 

6) A copy of the startup, shutdown, and malfunction plan; 

7) Records, such as a checklist or the equivalent, demonstrating that the weekly visual inspection of 

the exhaust stack for each control device has been performed as required in 40 CFR 63.848(g), 

including the results of each inspection; 

8) Records documenting the corrective actions taken when the limit(s) for an operating parameter 

established under 40 CFR 63.847(h) were exceeded, or when visible emissions indicating 

abnormal operation were observed from a control device stack during a daily inspection required 

under 40 CFR 63.848(g); 

9) Records documenting the portion of TF that is measured as particulate matter and the portion 

that is measured as gaseous when the particulate and gaseous fractions are quantified separately 

using an approved test method; and 

10) Records documenting the actions taken during a startup, shutdown, or a malfunction. 

6. Specific Reporting Requirements: 

a) Any exceedance over the monthly usage rates shall be reported in writing to the Division, no later 

than 30 days after the exceedance. Following initial notification of an exceedance, monthly reports 

shall be submitted, by the fifteenth of each month, to the Division’s Owensboro Regional Office. 

The permittee shall also certify to the Division, annually, that the specified records are being kept for 

these emission points and that any exceedances were reported. 

b) Any exceedance of the sulfur content of the petroleum coke and pitch shall be reported to the 

Division no later than 30 days after the exceedance. 

c) Exceedance of the VOM content of the pitch and/or coke, as well as any exceedance of the fuel 

usage rates shall be reported to the Division no later than 30 days after the exceedance. 

d) Excursions of control equipment operating parameters as well as the total of green anodes produced 

shall be reported to the Division. 

If more than two excursions and/or exceedances occur in any rolling six months, the permittee 

shall submit to the Division’s Owensboro Regional Office a corrective action plan for the 

Division’s approval on form DEP7007BB, no later than 30 days from the second exceedance. 

e) Any exceedance over the monthly particulate emission limits or opacity limits shall be reported in 

writing to the Division, no later than 30 days after the exceedance. 

1) Following initial notification of an exceedance, monthly reports shall be submitted, by the 

fifteenth of each month, to the Division’s Owensboro Regional Office. 

2) The reports shall contain individual emission units’ monthly and 12-month rolling PM/PM10 

emission estimates and a summation of the emission units’ 12-month rolling PM/PM10 emissions 

and results of weekly opacity observations. 

3) Monthly reports shall be submitted until there have been 12 consecutive months without any 

exceedance. 
Permit Number: V-08-012 Page: 41 of 61

SECTION B - EMISSION POINTS, EMISSION UNITS, APPLICABLE REGULATIONS, AND 

OPERATING CONDITIONS (CONTINUED) 

f) The permittee shall also certify to the Division, annually, that the specified records are being kept for 

these emission points and that any exceedance was reported. 

g) The permittee may report required information on paper, or in an electronic format using commonly 

available and compatible computer software. 

h) The permittee shall submit a summary of all subsequent performance tests on an annual basis except 

as required, below, in (excess emission report) and in 40 CFR 63.850(d). 

i) The permittee must maintain a site specific test plan that must include procedures for conducting 

performance tests required for emission monitoring. In addition to the information required by 40 

CFR 63.7, the plan shall include the following information: 

1) Procedures to ensure a minimum of three runs are performed annually for the primary control 

system for each source; 

2) A test summary, the test schedule, data quality objectives (the pretest expectations of precision, 

accuracy, and completeness of data), and both an internal and external quality assurance (QA) 

program. The external and internal QA programs shall include, at a minimum the information 

specified in 40 CFR 63.7 (2)(ii) and (iii), respectively.

j) The permittee shall submit semi-annual reports that confirm that actions taken during the relevant 

reporting period during startup, shutdown, and malfunction were consistent with the affected 

source’s startup, shutdown, and malfunction plan. 

1) If action taken during the startup, shutdown, or malfunction is not consistent with the affected 

source’s plan, the permittee shall record the action taken for the event and shall report such 

actions within two working days after commencing action inconsistent with the plan, as well as 

submit a letter within seven working days after the end of the event, in accordance with 40 CFR 

63.10(d)(5) (unless alternative reporting arrangements have been made in advance). 

2) Additionally, the permittee shall submit for the Division’s review and approval any 

modifications to the affected source’s startup, shutdown, and malfunction plan. 

k) As required by 40 CFR 63.10(e)(3), the permittee shall submit an excess emissions report (or a 

summary report) if measured emissions are in excess of the applicable standard. The report shall 

contain the information specified in 40 CFR 63.10(e)(3)(v) and be submitted semi-annually unless 

quarterly reports are required as a result of excess emissions. 

7. Specific Control Equipment Operating Conditions: 

a) The permittee shall install, maintain, and operate a dry alumina scrubber system, on the 

carbon, bake furnaces, in accordance with the manufacturer’s guidelines. The dry alumina scrubber 

systems’ operating parameters, such as pressure drop, alumina flow rates, shall be within the 

manufacturers recommendations or the parameters established during the most recent successful 

compliance test. 

b) The dry alumina scrubber system shall operate within the parameters established in the 3. Testing 

Requirement section and in 40 CFR 63.847 (h) and (f). 

 
Permit Number: V-08-012 Page: 42 of 61

SECTION B - EMISSION POINTS, EMISSION UNITS, APPLICABLE REGULATIONS, AND 

OPERATING CONDITIONS (CONTINUED) 

c) Pursuant to 40 CFR 63.848(k), the permittee shall certify that all required monitoring devices meet 

the regulatory accuracy requirements. Calibrations must be performed in accordance with the 

manufacturer’s instructions and records of calibrations kept. 

8. Compliance Schedule:

The permittee shall implement the parametric monitoring plan (with latest revision date of February 

4, 2011) within 120 days of the approval date (U. S. EPA approved the plan on February 7, 2011). 

(See Atttachment B) 

9. Compliance Certification Requirements:

Pursuant to 40 CFR 63.848(k), the permittee shall certify that the required monitoring system is 

maintained as required. 

10. Alternate Operating Scenario:

None 
Permit Number: V-08-012 Page: 43 of 61

SECTION B - EMISSION POINTS, EMISSION UNITS, APPLICABLE REGULATIONS, AND 

OPERATING CONDITIONS (CONTINUED) 

PMACT Source – Anode Paste Production Plant

EP Group Equip. 

Desig. 

Cons./ 

date Description Controls & Requirements 

Emission 

Limits 

(lbs/hr) 

Operation Limits 

(Tons/Year) 

EMISSION GROUP 31 

27 31 0420 

0440 

2019 

1969 Tank #1, Pitch 1800 ton 

Tank #2, Pitch 1800 ton 

Tank #3, Pitch 1800 ton 

Vent to Atm. Combined: 

POM(VOC) – 

0.426987 

124,680 tons pitch 

combined 

28 31 0351 

0352 

0353 

0354 

0355 

0356 

0357 

0358 

0359 

0362 

0364 

2035 

2037 

0425 

2036 

2006 

0135 

2010 

1969 Mixer 1 

Mixer 2 

Mixer 3 

Mixer 4 

Mixer 5 

Mixer 6 

Mixer 7 

Mixer 8 

Mixer 9 

Conveyor Green Mix Belt 

Conveyor Green Mix Belt 

Conveyor Green Mix Belt 

Rejects Chute Flop Gate 

Tank, Pitch Day, 10000 

gallon Conveyor Green 

Mix Belt 

Hopper Surge (32) 

Silo Buffer 

Anode Vibrating Press 

Dry Coke 

Scrubber 

310126 

Combined: 

POM(VOC) – 

13.94 

PM10 – 

0.0015140 

PM – 

0.002294 

27,222.2 tons 

27,222.2 tons 

27,222.2 tons 

27,222.2 tons 

27,222.2 tons 

27,222.2 tons 

27,222.2 tons 

27,222.2 tons 

27,222.2 tons 

108,888.89 tons 

136,111.11 tons 

245,000 tons 

6,500 tons 

39,759.89 tons 

245,000 tons 

245,000 tons 

26,280 tons 

245,000 tons 

APPLICABLE REGULATIONS:

40 CFR Part 63, Subpart LL, NESHAP for primary aluminum reduction plant

401 KAR 59:010, New process operations 

401 KAR 51:017, Prevention of significant deterioration of air quality (PSD) 

1. Operating Limitations:

a) Pursuant to 40 CFR 63.843(b), the permittee shall install, operate, and maintain equipment to capture 

and control polycyclic organic matter (POM) emissions. 

b) The permittee must operate a dry coke scrubber for the hot circuit only. 

c) See operational limits listed above. For compliance, see 4. Specific Monitoring Requirements

below. 

2. Emission Limitations: 

a) Pursuant to 401 KAR 59:010, visible emissions shall not equal or exceed 20 percent opacity, as 

determined with Reference Method 9. 

b) See table above for emission limits (401 KAR 51:017). Compliance with the listed operational limits 

provides reasonable assurance that the total particulate matter (PM) emission and PM10 emission 

limitations are being met.
Permit Number: V-08-012 Page: 44 of 61

SECTION B - EMISSION POINTS, EMISSION UNITS, APPLICABLE REGULATIONS, AND 

OPERATING CONDITIONS (CONTINUED) 

3. Testing Requirements:

 

 Pursuant to 40 CFR 63.847(f), compliance with the emission standards for these emission points 

 shall be demonstrated through site inspections and review of site records, unless testing is required 

 or requested. 

4. Specific Monitoring Requirements: 

a) Pursuant to 401 KAR 59:010, to provide reasonable assurance that the visible emission limitations 

are being met, the permittee shall: 

1) Perform a qualitative visual observation of the opacity of emissions from each stack/vent on a 

daily basis and maintain a log of the observations. The log shall note: 

i) Whether any air emissions (except for water vapor) were visible from the vent/stack, 

ii) All emission points from which visible emissions occurred, and 

 2) Determine the opacity of emissions by Reference Method 9 if visible emissions from any 

stack/vent are observed. 

3) Compliance with the listed operational limits provides reasonable assurance that the PM/PM10

emission limitations are being met. 

4) The permittee shall monitor the rolling 12-month amount and type of throughputs added to each 

emission unit during a calendar month. 

5) Excursions from the control equipment’s operating ranges shall be corrected within 24 hours; 

additional time may be granted for just cause. 

b) Pursuant to 40 CFR 63 Subpart LL, the permittee shall maintain a continuous parameter monitoring 

system for each emission control device. 

1) A description of the parameters to be monitored, the operating limits, and the monitoring 

frequency to ensure that the control devices are being properly operated and maintained, and an 

explanation of the criteria used for their selection and how they relate to the emission control, 

shall be submitted. 

2) Unless prior written approval by the Division for alternative control device operating parameters 

has been granted, devices for the measurement of coke flow and airflow shall be installed and 

monitored for the dry coke scrubbers. 

3) The permittee shall visually inspect the exhaust stack(s) of each control device on a daily basis 

for evidence of any visible emissions indicating abnormal operation. 

4) If a monitoring device for a primary control device measures an operating parameter outside the 

limit(s) required to be established pursuant to 40 CFR 63.847(h), or if visible emissions 

indicating abnormal operation are observed from the exhaust stack of a control device during a 

daily inspection, the permittee shall initiate the corrective action procedures identified in the 

startup, shutdown, and malfunction plan within one hour. 

i) Failure to initiate the corrective action procedures within one hour or to take the necessary 

corrective actions to remedy the problem is a violation. 

ii) If the limit for a given operating parameter associated with monitoring a specific control 

device is exceeded six times in any semi-annual reporting period, then any subsequent 

exceedance in that reporting period is a violation. 

 
Permit Number: V-08-012 Page: 45 of 61

SECTION B - EMISSION POINTS, EMISSION UNITS, APPLICABLE REGULATIONS, AND 

OPERATING CONDITIONS (CONTINUED) 

iii) For the purpose of determining the number of exceedances, no more than one exceedance 

shall be counted in any given 24-hour period. 

5) The permittee shall monitor the actions taken during any startup, shutdown, and malfunction 

event. 

c) The permittee shall install, operate, calibrate, and maintain a continuous monitoring system for the 

control equipment pursuant to the approved parametric monitoring plan, which is summarized in 

Attachment B to the permit, as provided in 40 CFR 63.848(f). Corrective action shall be as provided 

in 40 CFR 63.848(h). 

5. Specific Record Keeping Requirements: 

a) The permittee shall maintain records of the daily qualitative visual observation and Method 9 

observation if performed, quarterly Reference Method 9 opacity readings, control equipment 

excursions from their operating ranges, and the appropriate throughputs for the units in the above 

table. 

b) The permittee shall maintain records of all information (including all reports and notifications) 

required by Section 40 CFR 63.10(b) and by 40 CFR 63 Subpart LL. In addition to the general 

records required by 40 CFR 63.10(b), the permittee shall maintain records of the following 

information: 

1) A copy of the startup, shutdown, and malfunction plan, 

2) Daily records of the control equipment operating parameters, 

3) Design information of the capture system(s), 

4) Records, such as a checklist or the equivalent, demonstrating that the daily visual inspection of 

the exhaust stack for each control device has been performed, including the results of each 

inspection, 

5) Records documenting the corrective actions taken when the limits for an operating parameter 

established under 40 CFR 63.847(h) were exceeded, or when visible emission indication 

abnormal operation were observed from a control device stack, and 

6) Records documenting the actions taken during a startup, shutdown, or a malfunction. 

6. Specific Reporting Requirements:

a) The permittee may report required information on paper, or an electronic format using commonly 

available and compatible computer software. 

b) The permittee shall submit semi-annual reports that confirm that actions taken during the relevant 

reporting period during startup, shutdown, and malfunction were consistent with the affected 

source’s startup, shutdown, and malfunction plan. 

1) If action taken during the startup, shutdown, or malfunction is not consistent with the affected 

source’s plan, the permittee shall record the action taken for the event and shall report such 

actions within two working days after commencing action inconsistent with the plan and also 

submit a letter within seven working days after the end of the event, in accordance with 40 CFR 

63.10(d)(5) (unless alternative reporting arrangements have been in advance). 

 
Permit Number: V-08-012 Page: 46 of 61

SECTION B - EMISSION POINTS, EMISSION UNITS, APPLICABLE REGULATIONS, AND 

OPERATING CONDITIONS (CONTINUED) 

2) Additionally, the permittee shall submit, for the Division’s review and approval, any 

modifications to the affected source’s startup, shutdown, and malfunction plan. 

c) Any exceedance over the monthly opacity limits shall be reported in writing to the Division, no later 

than 30 days after the exceedance. 

1) Following initial notification of an exceedance, monthly reports shall be submitted, by the 

fifteenth of each month to the Division’s Owensboro Regional Office. 

2) The reports shall contain individual emission units’ opacity readings. 

3) Monthly reports shall be submitted until there has been 12 consecutive months without any 

exceedance. 

d) The permittee shall also certify to the Division, annually, that a daily visible emission survey is 

conducted and that the specified records are being kept for these emission points. 

 If more than three visible emission exceedances occur in any rolling six months, the permittee 

shall submit to the Division’s Owensboro Regional Office a corrective action plan for the 

Division’s approval on form DEP7007BB, no later than 30 days from the third exceedance. 

 

7. Specific Control Equipment Operating Conditions: 

a) Pursuant to 40 CFR 63.843(b), the emission capture system shall be installed and operated to meet 

the generally accepted engineering standards for minimum exhaust rates as published in Chapter 3 

and Chapter 5 of Industrial Ventilation: A Manual of Recommended Practice, American Conference 

of Governmental Industrial Hygienists, 22nd edition, 1995.

b) Captured emissions of polycyclic organic matter (POM) shall be routed through a closed system to a 

dry coke scrubber. 

8. Compliance Certification Requirements:

 Pursuant to 40 CFR 63.848(k), the permittee shall certify that the required monitoring system is 

being maintained per the manufacturer’s instructions. 

9. Compliance Schedule:

The permittee shall implement the parametric monitoring plan (with latest revision date of February 

4, 2011) within 120 days of the approval date (U. S. EPA approved the plan on February 7, 2011). 

(See Atttachment B) 

10. Alternate Operating Scenario:

 

None 
Permit Number: V-08-012 Page: 47 of 61

SECTION C - INSIGNIFICANT ACTIVITIES 

The following listed activities have been determined to be insignificant activities for this source pursuant to 401 

KAR 52:020, Section 6. Although these activities are designated as insignificant the permittee must comply 

with the applicable regulation. Process and emission control equipment at each insignificant activity subject to 

an opacity standard shall be inspected monthly and a qualitative visible emissions evaluation made. Results of 

the inspection, evaluation, and any corrective action shall be recorded in a log. 

Insig 

Item # Group Equip. Desig. Description Generally Applicable 

Regulation 

1 31 2022 Cooling Conveyor, Green Anode (32) NA 

2 31 2028 Cooling Conveyor, Green Anode (32) NA 

3 31 0415 Heater, Hot Oil System NA 

4 31 2052 Cooling Tower, Green Carbon NA 

5 31 0035 Tank, Hot Oil, 5,280 Gallon NA 

6 33 0228 Cooling Tower, Scrubber NA 

7 34 0006 Dryer, Anode Hole 401 KAR 61:020 

8 34 0132 Press #1, Thimble, North NA 

9 34 0134 Press #2, Thimble, South NA 

10 34 2004 Straightener, Rod & Stub NA 

11 34 2033 Tank, Graphite Dip 401 KAR 59:010 

12 34 0144 Dry, Stub – Natural Gas 401 KAR 61:020 

13 34 2049 Dryer, Scrap Anode 401 KAR 61:020 

14 34 0160 Cooling Tower, North, Rodding 401 KAR 63:010 

15 34 0158 Cooling Tower, South, Rodding 401 KAR 63:010 

16 42 0811 Cooling Tower, Rectifier Line 1A (24) 401 KAR 63:010 

17 42 2001 Cooling Tower, Rectifier Line 1B (24) 401 KAR 63:010 

18 42 0821 Cooling Tower, Rectifier Line 2A (24) 401 KAR 63:010 

19 42 2002 Cooling Tower, Rectifier Line 2B (24) 401 KAR 63:010 

20 42 0831 Cooling Tower, Rectifier Line 3A (24) 401 KAR 63:010 

21 42 2003 Cooling Tower, Rectifier Line 3B (24) 401 KAR 63:010 

22 42 0841 Cooling Tower, Rectifier Line 4A (24) 401 KAR 63:010 

23 42 2004 Cooling Tower, Rectifier Line 4B (24) 401 KAR 63:010 

24 42 0855 Cooling Tower, Rectifier Line 5A 401 KAR 63:010 

25 42 0865 Cooling Tower, Rectifier Line 5B 401 KAR 63:010 

26 44 3000 Casting, Sow 401 KAR 59:010 

27 50 4702 Spent Potliner Building (45) 401 KAR 59:010 

28 50 5508 Shell Repair Welding (45) 401 KAR 59:010 

29 50 - Welding, Maintenance 401 KAR 59:010 

30 50 0111 Engine, Diesel, Fire Pump (53) NA 

31 50 3728 Engine, Diesel, Generator, Admin (12) NA 

32 50 3721 Engine, Natural Gas, Generator, HR (12) NA 

33 50 3019 Tank, Kerosene, 1,000 Gallon (55) 401 KAR 63:020 

34 50 9108 Tanks, Propane System (78) 401 KAR 63:020 

35 50 4310 Tank, Diesel, 550 Gallon (45) 401 KAR 63:020 

36 50 4410 Tank, Kerosene, 300 Gallon (45) 401 KAR 63:020 

37 50 3036 Tank, Used Oil, 5,000 Gallon (45) 401 KAR 63:020 

38 50 0242 Tank, Rectifier Oil #1, 10,000 Gallon (23) 401 KAR 63:020 

39 50 0242 Tank, Rectifier Oil #2, 10,000 Gallon (23) 401 KAR 63:020 

40 50 0242 Tank, Rectifier Oil #3, 10,000 Gallon (23) 401 KAR 63:020 

41 50 3753 Tank, Oil, Mobile, 500 Gallon (12) 401 KAR 63:020 

42 50 9131 Tank, Gasoline AST, 15,000 Gallon (78) 401 KAR 63:020 

43 50 9132 Tank, Diesel AST, 15,000 Gallon (78) 401 KAR 63:020 

44 50 9128 Tank, Used Oil, 470 Gallon (78) 401 KAR 63:020 

45 50 9135 Parts Washer, Garage (78) 401 KAR 63:020 

 
Permit Number: V-08-012 Page: 48 of 61

SECTION C - INSIGNIFICANT ACTIVITIES (CONTINUED) 

Insig 

Item # Group Equip. Desig. Description Generally Applicable Regulation 

46 50 9136 Parts Washer, Potlines (78) 401 KAR 63:020 

47 50 9137 Parts Washer, Carbon Bake (78) 401 KAR 63:020 

48 50 9138 Parts Washer, Casthouse (78) 401 KAR 63:020 

49 50 9139 Parts Washer, Rodding (78) 401 KAR 63:020 

50 50 2033 Cooling Tower, Compressors 1-5 (53) 401 KAR 63:010 

51 50 2014 Cooling Tower, Marley (53) 401 KAR 63:010 

52 50 2043 Cooling Tower, Compressors 6-7 (53) 401 KAR 63:010 

53 50 9010 Boiler, Water < 10 mmBtu/hr Natural Gas 

(78) 401 KAR 59:010 

54 50 9253 Parts Washer, Cell Lining (78) 401 KAR 63:020 

55 50 9134 Parts Washer, Hydraulic Shop (78) 401 KAR 63:020 

 
Permit Number: V-08-012 Page: 49 of 61

SECTION D - SOURCE EMISSION LIMITATIONS AND TESTING REQUIREMENTS

1. As required by Section 1b of the Cabinet Provisions and Procedures for Issuing Title V Permits

incorporated by reference in 401 KAR 52:020, Section 26; compliance with annual emissions and 

processing limitations contained in this permit, shall be based on emissions and processing rates for any 

twelve (12) consecutive months. 

2. PM, PM10, CO, NOx, SO2, VOC, F and opacity emissions, measured by applicable reference methods, or an 

equivalent or alternative method specified in 40 C.F.R. Chapter I, or by a test method specified in the state 

implementation plan shall not exceed the respective limitations specified herein. 

 
Permit Number: V-08-012 Page: 50 of 61

SECTION E - SOURCE CONTROL EQUIPMENT REQUIREMENTS

1. Pursuant to 401 KAR 50:055, Section 2(5), at all times, including periods of startup, shutdown and 

malfunction, owners and operators shall, to the extent practicable, maintain and operate any affected 

facility including associated air pollution control equipment in a manner consistent with good air 

pollution control practice for minimizing emissions. Determination of whether acceptable operating and 

maintenance procedures are being used will be based on information available to the Division which 

may include, but is not limited to, monitoring results, opacity observations, review of operating and 

maintenance procedures, and inspection of the source. 

2. Pursuant to 40 CFR 63.6 (e)(1): 

a) At all times, including periods of startup, shutdown and malfunction owners and operators shall 

maintain and operate any affected facility source to a standard promulgated pursuant to 112(d), 

including associated air pollution control equipment, in a manner consistent with good air pollution 

control practice for minimizing emission at least to the levels required by the relevant standards. 

b) Malfunctions shall be corrected as soon as practicable after their occurrence in accordance with the 

required startup, shutdown, and malfunction plan. 

c) Operation and maintenance requirements established pursuant to section 112 of the Act are enforceable 

independent of emissions limitations or other requirements in relevant standards. Determination of 

whether acceptable operation and maintenance procedures are being used will be based on information 

available which may include, but is not limited to, monitoring results, review of operation and 

maintenance procedures (including the startup, shutdown, and malfunction plan), review of operation 

and maintenance records, and inspection of the source. 

d) Startup, shutdown, and malfunction plan and reports. The permittee shall develop, by the compliance 

date, and implement a written startup, shutdown, and malfunction plan as described below and in 40 

CFR 63.6(e)(3) that contains specific procedures to be followed for operating the source and 

maintaining the source during periods of startup, shutdown, and malfunction and a program of corrective 

action for malfunctioning process and control systems used to comply with the standard. The Division 

may review the plan upon request. In addition to the information required in 40 CFR 63.6(e)(3), the 

plan shall include: 

1) Procedures, including corrective actions, to be followed if a monitoring device measures an 

operating parameter outside the limit(s) established under the testing requirement section (Sec. 40 

CFR 63.847(h)), or if visible emissions from an exhaust stack indicating abnormal operation of a 

control device are observed by the permittee during the daily inspection (required in Sec. 40 CFR 

63.848(g)); and 

2) The permittee shall also keep records of each event as required by 40 CFR 63.10(b) and record and 

report if an action taken during a startup, shutdown, or malfunction is not consistent with the 

procedures in the plan as described in 40 CFR 63.6(e)(3)(iv). 

3) The plan shall identify all routine or otherwise predictable continuous monitoring system (CMS) 

malfunctions. 

4) The permittee shall keep records during and following startup, shutdown and malfunction events 

that confirm conformance with the plan. Records may be in the form of “checklists”. 

5) The permittee shall keep records in a form suitable and readily available for expeditious review 

and inspection. 

 
Permit Number: V-08-012 Page: 51 of 61

SECTION E - SOURCE CONTROL EQUIPMENT REQUIREMENT (CONTINUED) 

 

6) The occurrence and duration of each event shall be recorded. Records must be kept of any action 

taken during the event (including corrective action) that is different than the action specified in the 

startup, shutdown, and malfunction plan. 

7) Each period in which a CMS is malfunctioning or inoperative (including out of-control periods) 

shall be recorded. 

8) All required measurements needed to demonstrate compliance (including, but not limited to, 15 

minute averages of CMS data, raw materials used, performance testing measurements and 

performance evaluation measures, etc.) and that support other compliance data shall be recorded. 

9) All measurements necessary to determine the conditions of performance tests and performance 

evaluations shall be recorded. 

10) All results of performance tests, CMS performance evaluations, opacity and visual observations 

shall be recorded. 

11) The permittee shall revise the plan within 45 days after an event that the plan did not address, or 

failed to inadequately address, to include detailed procedures for operation and maintenance during 

a similar event and the corrective actions to be taken. 

12) All calibration checks, adjustments and maintenance performed on each CMS shall be recorded. 

 
Permit Number: V-08-012 Page: 52 of 61

SECTION F - MONITORING, RECORD KEEPING, AND REPORTING REQUIREMENTS

1. Pursuant to Section 1b – IV -1 of the Cabinet Provisions and Procedures for Issuing Title V Permits

incorporated by reference in 401 KAR 52:020, Section 26, when continuing compliance is demonstrated 

by periodic testing or instrumental monitoring, the permittee shall compile records of required 

monitoring information that include: 

a) Date, place as defined in this permit, and time of sampling or measurements; 

b) Analyses performance dates; 

c) Company or entity that performed analyses; 

d) Analytical techniques or methods used; 

e) Analyses results; and 

f) Operating conditions during time of sampling or measurement. 

2. Records of all required monitoring data and support information, including calibrations, maintenance 

records, and original strip chart recordings, and copies of all reports required by the Division for Air 

Quality, shall be retained by the permittee for a period of five (5) years and shall be made available for 

inspection upon request by any duly authorized representative of the Division for Air Quality. [Sections 

1b(IV) 2 and 1a(8) of the Cabinet Provisions and Procedures for Issuing Title V Permits incorporated 

by reference in 401 KAR 52:020, Section 26]. 

3. In accordance with the requirements of 401 KAR 52:020 Section 3(1)h the permittee shall allow 

authorized representatives of the Cabinet to perform the following during reasonable times: 

a) Enter upon the premises to inspect any facility, equipment (including air pollution control 

equipment), practice, or operation; 

b) To access and copy any records required by the permit: 

c) Sample or monitor, at reasonable times, substances or parameters to assure compliance with the 

permit or any applicable requirements. 

Reasonable times are defined as during all hours of operation, during normal office hours; or during an 

emergency. 

4. No person shall obstruct, hamper, or interfere with any Cabinet employee or authorized representative 

while in the process of carrying out official duties. Refusal of entry or access may constitute grounds 

for permit revocation and assessment of civil penalties. 

 
Permit Number: V-08-012 Page: 53 of 61

SECTION F - MONITORING, RECORD KEEPING, AND REPORTING REQUIREMENTS 

(CONTINUED) 

5. Summary reports of any monitoring required by this permit, other than continuous emission or opacity 

monitors, shall be submitted to the Regional Office listed on the front of this permit at least every six (6) 

months during the life of this permit, unless otherwise stated in this permit. For emission units that were 

still under construction or which had not commenced operation at the end of the 6-month period covered by 

the report and are subject to monitoring requirements in this permit, the report shall indicate that no 

monitoring was performed during the previous six months because the emission unit was not in operation 

[Section 1b (V )1 of the Cabinet Provisions and Procedures for Issuing Title V Permits incorporated by 

reference in 401 KAR 52:020, Section 26]. 

6. The semi-annual reports are due by January 30th and July 30th of each year. Data from the continuous 

emission and opacity monitors shall be reported to the Technical Services Branch in accordance with the 

requirements of 401 KAR 59:005, General Provisions, Section 3(3). All reports shall be certified by a 

responsible official pursuant to 401 KAR 52:020 Section 23. All deviations from permit requirements 

shall be clearly identified in the reports. 

7. In accordance with the provisions of 401 KAR 50:055, Section 1 the permittee shall notify the Regional 

Office listed on the front of this permit concerning startups, shutdowns, or malfunctions as follows: 

a) When emissions during any planned shutdowns and ensuing startups will exceed the standards, 

notification shall be made no later than three (3) days before the planned shutdown, or 

immediately following the decision to shut down, if the shutdown is due to events which could 

not have been foreseen three (3) days before the shutdown. 

b) When emissions due to malfunctions, unplanned shutdowns and ensuing startups are or may be 

in excess of the standards, notification shall be made as promptly as possible by telephone (or 

other electronic media) and shall be submitted in writing upon request. 

8. The permittee shall report emission related exceedances from permit requirements including those 

attributed to upset conditions (other than emission exceedances covered by Section F.7. above) to the 

Regional Office listed on the front of this permit within 30 days. Other deviations from permit 

requirements shall be included in the semiannual report required by Section F.6. [Section 1b (V) 3, 4. of 

the Cabinet Provisions and Procedures for Issuing Title V Permits incorporated by reference in 401 

KAR 52:020, Section 26]. 

9. Pursuant to 401 KAR 52:020, Permits, Section 21, the permittee shall annually certify compliance with 

the terms and conditions contained in this permit, by completing and returning a Compliance 

Certification Form (DEP 7007CC) (or an alternative approved by the regional office) to the Regional 

Office listed on the front of this permit and the U. S. EPA in accordance with the following 

requirements: 

a) Identification of the term or condition; 

b) Compliance status of each term or condition of the permit; 

c) Whether compliance was continuous or intermittent; 
Permit Number: V-08-012 Page: 54 of 61

SECTION F - MONITORING, RECORD KEEPING, AND REPORTING REQUIREMENTS 

(CONTINUED) 

d) The method used for determining the compliance status for the source, currently and over the 

reporting period, and 

e) For an emissions unit that was still under construction or which has not commenced operation at 

the end of the 12-month period covered by the annual compliance certification, the permittee shall 

indicate that the unit is under construction and that compliance with any applicable requirements 

will be demonstrated within the timeframes specified in the permit. 

f) The certification shall be postmarked by January 30th of each year. Annual compliance 

certifications should be mailed to the following addresses:

Division for Air Quality U.S. EPA Region IV 

Owensboro Regional Office Air Enforcement Branch 

3032 Alvey Park Dr., Ste 700 Atlanta Federal Center 

Owensboro, KY 42303 61 Forsyth St. 

Atlanta, GA 30303-8960 

10. In accordance with 401 KAR 52:020, Section 22, the permittee shall provide the Division with all 

information necessary to determine its subject emissions within thirty (30) days of the date the KYEIS 

emission survey is mailed to the permittee. 

 
Permit Number: V-08-012 Page: 55 of 61

SECTION G - GENERAL PROVISIONS 

1. General Compliance Requirements

a. The permittee shall comply with all conditions of this permit. Noncompliance shall be a violation of 

401 KAR 52:020 Section 3(1)(b) and a violation of Federal Statute 42 USC 7401 through 7671q (the 

Clean Air Act). Noncompliance with this permit is grounds for enforcement action including but not 

limited to termination, revocation and reissuance, revision or denial of a permit [Section 1a-3 of the 

Cabinet Provisions and Procedures for Issuing Title V Permits incorporated by reference in 401 KAR 

52:020 Section 26]. 

b. The filing of a request by the permittee for any permit revision, revocation, reissuance, or termination, or 

of a notification of a planned change or anticipated noncompliance, shall not stay any permit condition 

[Section 1a-6 of the Cabinet Provisions and Procedures for Issuing Title V Permits incorporated by 

reference in 401 KAR 52:020, Section 26]. 

c. This permit may be revised, revoked, reopened and reissued, or terminated for cause in accordance with 

401 KAR 52:020, Section 19. The permit will be reopened for cause and revised accordingly under the 

following circumstances: 

(1) If additional applicable requirements become applicable to the source and the remaining permit term 

is three (3) years or longer. In this case, the reopening shall be completed no later than eighteen (18) 

months after promulgation of the applicable requirement. A reopening shall not be required if 

compliance with the applicable requirement is not required until after the date on which the permit is 

due to expire, unless this permit or any of its terms and conditions have been extended pursuant to 

401 KAR 52:020, Section 12; 

(2) The Cabinet or the United States Environmental Protection Agency (U. S. EPA) determines that the 

permit must be revised or revoked to assure compliance with the applicable requirements; 

(3) The Cabinet or the U. S. EPA determines that the permit contains a material mistake or that 

inaccurate statements were made in establishing the emissions standards or other terms or conditions 

of the permit; 

(4) New requirements become applicable to a source subject to the Acid Rain Program. 

Proceedings to reopen and reissue a permit shall follow the same procedures as apply to initial permit 

issuance and shall affect only those parts of the permit for which cause to reopen exists. Reopenings 

shall be made as expeditiously as practicable. Reopenings shall not be initiated before a notice of intent 

to reopen is provided to the source by the Division, at least thirty (30) days in advance of the date the 

permit is to be reopened, except that the Division may provide a shorter time period in the case of an 

emergency. 

d. The permittee shall furnish information upon request of the Cabinet to determine if cause exists for 

modifying, revoking and reissuing, or terminating the permit; or to determine compliance with the 

conditions of this permit [Sections 1a- 7 and 8 of the Cabinet Provisions and Procedures for Issuing 

Title V Permits incorporated by reference in 401 KAR 52:020, Section 26]. 

e. Emission units described in this permit shall demonstrate compliance with applicable requirements if 

requested by the Division [401 KAR 52:020 Section 3(1) (c)]. 

 
Permit Number: V-08-012 Page: 56 of 61

SECTION G - GENERAL PROVISIONS (CONTINUED)

f. The permittee, upon becoming aware that any relevant facts were omitted or incorrect information was 

submitted in the permit application, shall promptly submit such supplementary facts or corrected 

information to the permitting authority [401 KAR 52:020, Section 7(1)]. 

g. Any condition or portion of this permit which becomes suspended or is ruled invalid as a result of any 

legal or other action shall not invalidate any other portion or condition of this permit [Section 1a-14 of 

the Cabinet Provisions and Procedures for Issuing Title V Permits incorporated by reference in 401 

KAR 52:020, Section 26]. 

h. The permittee shall not use as a defense in an enforcement action the contention that it would have been 

necessary to halt or reduce the permitted activity in order to maintain compliance [Section 1a-4 of the 

Cabinet Provisions and Procedures for Issuing Title V Permits incorporated by reference in 401 KAR 

52:020, Section 26]. 

i. All emission limitations and standards contained in this permit shall be enforceable as a practical matter. 

All emission limitations and standards contained in this permit are enforceable by the U.S. EPA and 

citizens except for those specifically identified in this permit as state-origin requirements. [Section 1a-15 

of the Cabinet Provisions and Procedures for Issuing Title V Permits incorporated by reference in 401 

KAR 52:020, Section 26]. 

j. This permit shall be subject to suspension if the permittee fails to pay all emissions fees within 90 days 

after the date of notice as specified in 401 KAR 50:038, Section 3(6) [Section 1a-10 of the Cabinet 

Provisions and Procedures for Issuing Title V Permits incorporated by reference in 401 KAR 52:020, 

Section 26]. 

k. Nothing in this permit shall alter or affect the liability of the permittee for any violation of applicable 

requirements prior to or at the time of permit issuance [401 KAR 52:020, Section 11(3) 2]. 

l. This permit does not convey property rights or exclusive privileges [Section 1a-9 of the Cabinet 

Provisions and Procedures for Issuing Title V Permits incorporated by reference in 401 KAR 52:020, 

Section 26]. 

m. Issuance of this permit does not relieve the permittee from the responsibility of obtaining any other 

permits, licenses, or approvals required by the Cabinet or any other federal, state, or local agency. 

n. Nothing in this permit shall alter or affect the authority of U.S. EPA to obtain information pursuant to 

Federal Statute 42 USC 7414, Inspections, monitoring, and entry [401 KAR 52:020, Section 11(3) 4]. 

o. Nothing in this permit shall alter or affect the authority of U.S. EPA to impose emergency orders 

pursuant to Federal Statute 42 USC 7603, Emergency orders [401 KAR 52:020, Section 11(3) 1]. 

p. This permit consolidates the authority of any previously issued PSD, NSR, or Synthetic Minor source 

preconstruction permit terms and conditions for various emission units and incorporates all requirements 

of those existing permits into one single permit for this source. 

q. Pursuant to 401 KAR 52:020, Section 11, a permit shield shall not protect the permittee from 

enforcement actions for violating an applicable requirement prior to or at the time of permit issuance. 

Compliance with the conditions of this permit shall be considered compliance with: 
Permit Number: V-08-012 Page: 57 of 61

 

SECTION G - GENERAL PROVISIONS (CONTINUED) 

(1) Applicable requirements that are included and specifically identified in the permit; 

and

(2) Non-applicable requirements expressly identified in this permit. 

2. Permit Expiration and Reapplication Requirements

a. This permit shall remain in effect for a fixed term of five (5) years following the original date of issue. 

Permit expiration shall terminate the source's right to operate unless a timely and complete renewal 

application has been submitted to the Division at least six (6) months prior to the expiration date of the 

permit. Upon a timely and complete submittal, the authorization to operate within the terms and 

conditions of this permit, including any permit shield, shall remain in effect beyond the expiration date, 

until the renewal permit is issued or denied by the Division [401 KAR 52:020, Section 12]. 

b. The authority to operate granted shall cease to apply if the source fails to submit additional information 

requested by the Division after the completeness determination has been made on any application, by 

whatever deadline the Division sets [401 KAR 52:020 Section 8(2)]. 

3. Permit Revisions

a. A minor permit revision procedure may be used for permit revisions involving the use of economic 

incentive, marketable permit, emission trading, and other similar approaches, to the extent that these 

minor permit revision procedures are explicitly provided for in the State Implementation Plan (SIP) or in 

applicable requirements and meet the relevant requirements of 401 KAR 52:020, Section 14(2). 

b. This permit is not transferable by the permittee. Future owners and operators shall obtain a new permit 

from the Division for Air Quality. The new permit may be processed as an administrative amendment if 

no other change in this permit is necessary, and provided that a written agreement containing a specific 

date for transfer of permit responsibility coverage and liability between the current and new permittee 

has been submitted to the permitting authority within ten (10) days following the transfer. 

4. Construction, Start-Up, and Initial Compliance Demonstration Requirements

Pursuant to a duly submitted application the Division hereby authorizes the construction of the equipment 

described herein, EP 84 (New electrical equipment to increase capacity for aluminum production on 

potlines 1-4), EP 67 (Installation of new intermediate crusher) and EP 63 (Installation of a new Induction 

Furnace #3) in accordance with the terms an d conditions of this permit. 

a. Construction of any process and/or air pollution control equipment authorized by this permit shall be 

conducted and completed only in compliance with the conditions of this permit. 

b. Within thirty (30) days following commencement of construction and within fifteen (15) days following 

start-up and attainment of the maximum production rate specified in the permit application, or within 

fifteen (15) days following the issuance date of this permit, whichever is later, the permittee shall furnish 

to the Regional Office listed on the front of this permit in writing, with a copy to the Division's 

Frankfort Central Office, notification of the following: 

 (1) The date when construction commenced. 

(2) The date of start-up of the affected facilities listed in this permit. 

(3) The date when the maximum production rate specified in the permit application was achieved. 
Permit Number: V-08-012 Page: 58 of 61

SECTION G - GENERAL PROVISIONS (CONTINUED) 

c. Pursuant to 401 KAR 52:020, Section 3(2), unless construction is commenced within eighteen (18) 

months after the permit is issued, or begins but is discontinued for a period of eighteen (18) months or is 

not completed within a reasonable timeframe then the construction and operating authority granted by 

this permit for those affected facilities for which construction was not completed shall immediately 

become invalid. Upon written request, the Cabinet may extend these time periods if the source shows 

good cause. 

d. For those affected facilities for which construction is authorized by this permit, a source shall be allowed 

to construct with the proposed permit. Operational or final permit approval is not granted by this permit 

until compliance with the applicable standards specified herein has been demonstrated pursuant to 401 

KAR 50:055. If compliance is not demonstrated within the prescribed timeframe provided in 401 KAR 

50:055, the source shall operate thereafter only for the purpose of demonstrating compliance, unless 

otherwise authorized by Section I of this permit or order of the Cabinet. 

e. This permit shall allow time for the initial start-up, operation, and compliance demonstration of the 

affected facilities listed herein. However, within sixty (60) days after achieving the maximum 

production rate at which the affected facilities will be operated but not later than 180 days after initial 

start-up of such facilities, the permittee shall conduct a performance demonstration on the affected 

facilities in accordance with 401 KAR 50:055, General compliance requirements. Testing must also be 

conducted in accordance with General Provisions G.5 of this permit. 

f. Terms and conditions in this permit established pursuant to the construction authority of 401 KAR 

51:017 or 401 KAR 51:052 shall not expire. 

5. Testing Requirements

a. Pursuant to 401 KAR 50:045 Section 2, a source required to conduct a performance test shall submit a 

completed Compliance Test Protocol form, DEP form 6028, or a test protocol a source has developed 

for submission to other regulatory agencies, in a format approved by the cabinet, to the Division's 

Frankfort Central Office a minimum of sixty (60) days prior to the scheduled test date. Pursuant to 401 

KAR 50:045, Section 7, the Division shall be notified of the actual test date at least Thirty (30) days 

prior to the test. 

b. Pursuant to 401 KAR 50:045 Section 5, in order to demonstrate that a source is capable of complying 

with a standard at all times, any required performance test shall be conducted under normal conditions 

that are representative of the source’s operations and create the highest rate of emissions. If [When] the 

maximum production rate represents a source’s highest emissions rate and a performance test is 

conducted at less than the maximum production rate, a source shall be limited to a production rate of no 

greater than 110 percent of the average production rate during the performance tests. If and when the 

facility is capable of operation at the rate specified in the application, the source may retest to 

demonstrate compliance at the new production rate. The Division for Air Quality may waive these 

requirements on a case-by-case basis if the source demonstrates to the Division's satisfaction that the 

source is in compliance with all applicable requirements. 

c. Results of performance test(s) required by the permit shall be submitted to the Division by the source or 

its representative within forty-five days or sooner if required by an applicable standard, after the 

completion of the fieldwork. 

 
Permit Number: V-08-012 Page: 59 of 61

SECTION G - GENERAL PROVISIONS (CONTINUED)

6. Acid Rain Program Requirements

a. If an applicable requirement of Federal Statute 42 USC 7401 through 7671q (the Clean Air Act) is more 

stringent than an applicable requirement promulgated pursuant to Federal Statute 42 USC 7651 through 

7651o (Title IV of the Act), both provisions shall apply, and both shall be state and federally 

enforceable. 

b. The permittee shall comply with all applicable requirements and conditions of the Acid Rain Permit and 

the Phase II permit application (including the Phase II NOx compliance plan and averaging plan, if 

applicable) incorporated into the Title V permit issued for this source. The source shall also comply 

with all requirements of any revised or future acid rain permit(s) issued to this source. 

7. Emergency Provisions

a. Pursuant to 401 KAR 52:020 Section 24(1), an emergency shall constitute an affirmative defense to an 

action brought for the noncompliance with the technology-based emission limitations if the permittee 

demonstrates through properly signed contemporaneous operating logs or relevant evidence that: 

(1) An emergency occurred and the permittee can identify the cause of the emergency; 

(2) The permitted facility was at the time being properly operated; 

(3) During an emergency, the permittee took all reasonable steps to minimize levels of emissions that 

exceeded the emissions standards or other requirements in the permit; and 

(4) Pursuant to 401 KAR 52:020, 401 KAR 50:055, and KRS 224.01-400, the permittee notified the 

Division as promptly as possible and submitted written notice of the emergency to the Division 

when emission limitations were exceeded due to an emergency. The notice shall include a 

description of the emergency, steps taken to mitigate emissions, and corrective actions taken. 

(5) This requirement does not relieve the source of other local, state or federal notification requirements. 

b. Emergency conditions listed in General Condition G.7.a above are in addition to any emergency or upset 

provision(s) contained in an applicable requirement [401 KAR 52:020, Section 24(3)]. 

c. In an enforcement proceeding, the permittee seeking to establish the occurrence of an emergency shall 

have the burden of proof [401 KAR 52:020, Section 24(2)]. 

8. Ozone Depleting Substances

a. The permittee shall comply with the standards for recycling and emissions reduction pursuant to 40 CFR 

82, Subpart F, except as provided for Motor Vehicle Air Conditioners (MVACs) in Subpart B: 

(1) Persons opening appliances for maintenance, service, repair, or disposal shall comply with the 

required practices contained in 40 CFR 82.156. 

(2) Equipment used during the maintenance, service, repair, or disposal of appliances shall comply with 

the standards for recycling and recovery equipment contained in 40 CFR 82.158. 

(3) Persons performing maintenance, service, repair, or disposal of appliances shall be certified by an 

approved technician certification program pursuant to 40 CFR 82.161. 

(4) Persons disposing of small appliances, MVACs, and MVAC-like appliances (as defined at 40 CFR 

82.152) shall comply with the recordkeeping requirements pursuant to 40 CFR 82.166 

(5) Persons owning commercial or industrial process refrigeration equipment shall comply with the leak 

repair requirements pursuant to 40 CFR 82.156. 

(6) Owners/operators of appliances normally containing 50 or more pounds of refrigerant shall keep 

records of refrigerant purchased and added to such appliances pursuant to 40 CFR 82.166. 
Permit Number: V-08-012 Page: 60 of 61

SECTION G - GENERAL PROVISIONS (CONTINUED)

b. If the permittee performs service on motor (fleet) vehicle air conditioners containing ozone-depleting 

substances, the source shall comply with all applicable requirements as specified in 40 CFR 82, Subpart 

B, Servicing of Motor Vehicle Air Conditioners. 

9. Risk Management Provisions

a. The permittee shall comply with all applicable requirements of 401 KAR Chapter 68, Chemical 

Accident Prevention, which incorporates by reference 40 CFR Part 68, Risk Management Plan 

provisions. If required, the permittee shall comply with the Risk Management Program and submit a 

Risk Management Plan to: 

RMP Reporting Center 

P.O. Box 1515 

Lanham-Seabrook, MD 20703-1515. 

b. If requested, submit additional relevant information to the Division or the U.S. EPA. 

 
Permit Number: V-08-012 Page: 61 of 61

SECTION H - ALTERNATE OPERATING SCENARIOS 

None 

SECTION I - COMPLIANCE SCHEDULE

None 
 

ATTACHMENT A

COMPLIANCE ASSURANCE 

MONITORING (CAM) PLAN

FOR

POTLINES 1-4 

TOTAL PARTICULATE AND SULFUR DIOXIDE

AND

POTLINE 5 

TOTAL PARTICULATE
 

 

 

TABLE OF CONTENTS

Potlines 1-4 Total Particulate ..................................................................... 

Potlines 1-4 Sulfur Dioxide ........................................................................ 

Potline 5 Total Particulate .......................................................................... 

 
 

Potlines 1 through 4 Control System

Multiple Cyclones and Electrostatic Precipitators for PT Control

I. BACKGROUND

a. Emission Unit

Description: Potlines 1 through 4 Control System

Control Equipment Identification: Wet Scrubber System #432001

Facility: Century Aluminum of Kentucky

1627 State Route 271 North

Hawesville, KY   42348

   

b. Applicable Regulation, Emission Limit and Monitoring Requirements

Regulation No.: 40 CFR Part 64

PM/PM10 Emission Limits: 220.786 lbs PM/hr, 128.1 lbs PM10/hr

Monitoring Requirements: Visible emissions, periodic monitoring

c. Control Technology

Multiple‐cyclones and Electrostatic Precipitators (ESPs)

II. MONITORING APPROACH

a. Indicator

• Visible emissions (Method 9)

• ESP amperage and voltage

• Exhaust fans operational

b. Measurement Approach

• Visible emissions monitored daily using a qualitative method and quarterly using EPA

Method 9

• ESP amperage and voltage recorded once per shift

• Exhaust fan amperage once per shift
 

c. Indicator Range

• Visible emission not to exceed 15%

• ESP amperage 50 to 200 amps; voltage 15 to 30 kva

• Fan amperage 100 to 210 and 6 fans operational

d. QIP Threshold

• QIP Threshold is 6 excursions per monitoring period per indicator

e. Performance Criteria

• Data representativeness:

− Readings taken at the emission point or control device

• Verification of Operational Status:  

− Not applicable

• QA/QC Criteria:  

− Observer shall be a M9 trained

• Monitoring Frequency:

− Daily qualitative by operator

− quarterly six‐minute M9

− Shift readings for ESP amps, ESP volts and Fans operational and amps

III. JUSTIFICATION

a. Background

The facility manufactures aluminum.  The pollutant particulate matter (PT) is generated as a

part of material handling and process operation.    PT is controlled by multiple‐cyclones and

electrostatic precipitators in series and is capable of handling approximately 1,500,000 cubic

feet of air from the potlines.

b. Rational for Selection of Performance Indicator

Visible emissions were selected as a performance indicator because it is indicative of operation

of the control system in a manner necessary to comply with the particulate emission standard.  

In addition, the ESP amperage, ESP voltage and the fan amperage were selected to ensure the

system is operated within the performance criteria.
 

c. Rational for Selection of Indicator Level

The selected indicator range for visible emissions is 15%.    When an excursion occurs,

corrective action will be initiated, beginning with an evaluation of the occurrence to determine

the action required to correct the situation.  A 15% opacity reading would be an indicator of an

operational problem with the electrostatic precipitators.   All excursions will be documented

and reported.  The indicated range was selected as this is the permit limit and daily qualitative

accompanied by quarterly M9 observations would be indicative of consistent operation.

The indicators ESP amps, ESP volts and operational fan amp ranges were selected to effectively

monitor the electrostatic precipitator control device operation as per the manufactures

guidance for the ESPs.  The fan amps are indicative of air flow with the range per the fan motor

electrical limitations.

These same parameters have been deemed sufficiently reliable by EPA in determining MACT

compliance based on enhanced monitoring principles.  Particulate Fluoride is removed by the

cyclones and electrostatic precipitators in the same manner as particulate matter; therefore

the reliability of this proposed compliance assurance monitoring has already been established.

The selected QIP is 6 excursions per indicator in a 6‐month reporting period.    This level is

about 3% of the total observations for visual observations and 1.5% for the ESP and Fan

indicators.  If the QIP threshold is exceeded in a semi‐annual reporting period, a QIP will be

developed and implemented.

Note:  15% opacity triggers inspection of the control device
 

Potlines 1 through 4 Control System

Wet Scrubbers – SO2

IV. BACKGROUND

a. Emission Unit

Description: Potlines 1 through 4 Control System

Control Equipment Identification: Wet Scrubber System #432001

Facility: Century Aluminum of Kentucky

1627 State Route 271 North

Hawesville, KY   42348

   

b. Applicable Regulation, Emission Limit and Monitoring Requirements

Regulation No.: 40 CFR Part 64

SO2 Emission Limits: 898.97 lbs SO2/hr

Monitoring

Requirements:

Re‐circulating pump amperage once per shift, Exhaust

fan amperage once per shift, periodic monitoring

c. Control Technology

Wet Scrubbers

V. MONITORING APPROACH

a. Indicator

• Water re‐circulation pumps operational

• Exhaust fans operational  

b. Measurement Approach

• Re‐circulating pump amperage once per shift

• Exhaust fan amperage once per shift   
 

c. Indicator Range

• Water pump amperage between 40 and 70 and 3 pumps operational

• Fan amperage 100 to 210 and 6 fans operational  

d. QIP Threshold

• QIP Threshold is 6 excursions per monitoring period per indicator

e. Performance Criteria

• Data representativeness:

− Readings taken at the emission point or control device

• Verification of Operational Status:  

− Not applicable

• QA/QC Criteria:  

− Not applicable

• Monitoring Frequency:

− Shift readings for re‐circulating pump and fans operational and amps

VI. JUSTIFICATION

a. Background

The facility manufactures aluminum.  The pollutant SO2 is generated as a part of the process

operation.    SO2 is controlled by the wet scrubbers incidentally with control of gaseous

fluorides.  The system is capable of handling approximately 1,500,000 cubic feet of air from the

potlines.

b. Rational for Selection of Performance Indicator

Re‐circulating pump and fan amperes were selected as performance indicators because it is

indicative of operation of the control system in a manner necessary to comply with the

proposed SO2 limit.  SO2 scrubbing is enhanced by good air and water contact.

c. Rational for Selection of Indicator Level

The selected indicator range for re‐circulating pumps is 40 to 70 amperes and 3 re‐circulating

pumps operational.  When an excursion occurs, corrective action will be initiated, beginning

with an evaluation of the occurrence to determine the action required to correct the situation.  

All excursions will be documented and reported.  The indicated range was selected as this is
 

the identified range necessary to ensure water availability.

The selected indicator range for fans operating is 100 to 210 amperes per fan and 6 fans

operational.  When an excursion occurs, corrective action will be initiated, beginning with an

evaluation of the occurrence to determine the action required to correct the situation.   All

excursions will be documented and reported.  The indicated range was selected as this is the

identified range necessary to ensure air flow.

These same parameters have been deemed sufficiently reliable by EPA in determining MACT

compliance based on enhanced monitoring principles.   Gaseous Fluoride is removed by the

wet scrubbers in the same manner as it incidentally removes sulfur dioxide, therefore the

reliability of this proposed compliance assurance monitoring has already been established.

The selected QIP is 6 excursions per indicator in a 6‐month reporting period.    This level is

about 1.5% for the re‐circulating pump and fan indicators.  If the QIP threshold is exceeded in a

semi‐annual reporting period, a QIP will be developed and implemented.
 

Potline 5 Control System

Dry Alumina Injection Baghouse

VII. BACKGROUND

a. Emission Unit

Description: Potline 5  

Control Equipment Identification: Dry Aluminum Scrubber #480040 CFR 63

Facility: Century Aluminum of Kentucky

1627 State Route 271 North

Hawesville, KY   42348

   

b. Applicable Regulation, Emission Limit and Monitoring Requirements

Regulation No.: 40 CFR Part 64, Permit # V‐01‐019 R1

PM/PM10 Emission Limits: 51.546 lbs PM/hr, 29.89 lbs PM10/hr

Monitoring Requirements: Visible emissions, periodic monitoring

c. Control Technology

Dry alumina injection baghouse

VIII. MONITORING APPROACH

a. Indicator

• Visible emissions (Method 9)

• Alumina flow

• System Pressure

• Fan current (amperes)

b. Measurement Approach
 

• Visible emissions monitored daily using a qualitative method (Method 9  readings required

if any visible emissions are observed) and quarterly using EPA Method 9

• Alumina flow by weigh scale

• System flow by pressure drop

• Fan amperes by reading

c. Indicator Range

• Visible emission not to exceed 15%

• Alumina flow between 13,000 to 24,000 pounds per hour

• System flow between 2 and 4 inches of water

• Fan amps between 425 to 500

d. QIP Threshold

• QIP Threshold is 6 excursions per monitoring period per indicator

e. Performance Criteria

• Data representativeness:

− Readings taken at the emission point or control device

• Verification of Operational Status:  

− Not applicable

• QA/QC Criteria:  

− Observer shall be a M9 trained

• Monitoring Frequency:

− Daily qualitative by operator

− Quarterly six‐minute M9

− Computer readings at 15 minute intervals

IX. JUSTIFICATION

a. Background

The facility manufactures aluminum.  The pollutant particulate matter (PT) is generated as a

part of material handling and process operation.   PT is controlled by a baghouse capable of

approximately 500,000 cubic feet of air.

   
 

b. Rational for Selection of Performance Indicator

Visible emissions were selected as a performance indicator because it is indicative of operation

of the control system in a manner necessary to comply with the particulate emission standard.

c. Rational for Selection of Indicator Level

The selected indicator range for visible emissions is 15%.    When an excursion occurs,

corrective action will be initiated, beginning with an evaluation of the occurrence to determine

the action required to correct the situation.  A 15% opacity reading would be an indicator of an

operational problem with the baghouse.  All excursions will be documented and reported.  The

indicated range was selected as this is the permit limit and daily qualitative accompanied by

quarterly M9 observations would be indicative of consistent operation.

The indicators alumina flow, system pressure and fan amps were selected to effectively

monitor the control device operation as per the manufacturer’s guidance.

These same parameters have been deemed sufficiently reliable by EPA in determining MACT

compliance based on enhanced monitoring principles.  Particulate Fluoride is removed by the

baghouse in the same manner as particulate matter is removed; therefore the reliability of this

proposed compliance assurance monitoring has already been established.

The selected QIP is 6 excursions per indicator in a 6‐month reporting period.    This level is

about 3% of the total observations for visual observations and 1.5% for the scrubber and fan

indicators.  If the QIP threshold is exceeded in a semi‐annual reporting period, a QIP will be

developed and implemented.

 
 

ATTACHMENT B 

SUMMARY OF THE PARAMETRIC

MONITORING PLAN 

 
 

PARAMETRIC MONITORING METHODOLOGY AND RATIONALE

CARBON BAKE 

A. Regulated Source(s) 

 

Description: Anode Baking Furnaces 1, 2, & 3 

Emission Source 

Group: 

33 

Equip 

Designation(s): 

3301, 3302, 3307 

Facility: Century Aluminum of KY 

 

B. Applicable Regulations and Emission Limits 

 

Regulation(s): 40 CFR Part 63, Subpart LL 

401 KAR 59:010 

401 KAR 51:017 

Emission 

Limit(s): 

Total Fluoride 

(Gaseous+Particulate) 

 Polycyclic Organic Matter 

(POM) 

0.2 lbs/ton green anode 

(existing) 

0.02 lbs/ton green anode 

(new) 

0.18 lbs/ton green anode 

(existing) 

0.05 lbs/ton green anode 

(new) 

Monitoring 

Requirement(s): 

Alumina Flow Rate 

Exhaust Gas Flow Rate 

Gas Temperature (inlet to baghouse) 

Visible Emissions (Qualitative and Method 9) 

C. Control Technology 

 

Dry Alumina Scrubber 330140 as common control device for all three regulated sources. 

D. Compliance Schedule 

The permittee shall implement the parametric monitoring plan (with latest revision date of 

February 4, 2011) within 120 days of the approval date (U. S. EPA approved the plan on 

February 7, 2011). 
Monitoring Approach for Carbon Bake 

A. Indicator Gas Flow Rate Alumina Flow Rate Gas Temperature (BH Inlet) Vis

Measurement 

Approach 

Differential pressure is continuously measured at multiple locations by Rosemount Differential Pressure Transmitters and then flow is calculated into a total flow using calculation described in operating manual Section 2, Page 8-9 (Appendix 

A). 

The frequency of the rotary vane feeder monitored in hertz by 1771-IFE Analog Input Cards, translated to rotations, and then, knowing the pocket fill, calculated to lbs/hr of flow. 

The temperature of the exhaust gas entering the baghouse is continuously monitored 

Visiby a per visibwhiopeconwhe

B. Indicator Range 119,232-145,728 scfm >43 Hz (3,475 lbs/hr) 170-208 oF Visi

< 20Exccorr

C. Performance Criteria 

Data 

Representativeness 

The pressure transmitters have a minimum accuracy of + 0.075% 

±0.5% ±0.6% Obs

stacope

Verification of 

Operational Status 

The system continuously monitors for flow and will alarm the operator if a low gas flow condition exists. 

The system has flow sensors at the rotary airlock discharge, the distribution box which distributes alumina to the reactor modules, and at each reactor module. If the airlock is not operating, the distribution box does not discharge, or the reactor modules are not receiving flow, then an alarm displays on the operators screen requiring operator intervention. 

NA NA 

QA/QC Practices and 

Criteria 

The pressure transmitters are calibrated annually to a NIST traceable standard. 

Verification that actual flow exiting the feeder matches expected flow once per quarter. Inspection and adjustment of vane blade clearance to manf. specs. once per quarter. 

The thermocouples and temperature transmitters are calibrated annually to a NIST traceable standard. 

Obs6 m

Monitoring Frequency Continuously Continuously Continuously Dai

visibM9 

Data Collection 

Procedures 

15 minute instantaneous readings are recorded. The PLC then calculates and records 2-hr average using the 15-minute readings. 

15 minute instantaneous readings are recorded. The PLC then calculates and records 2-hr average using the 15-minute readings. 

15 minute instantaneous readings are recorded. The PLC then calculates and records 2-hr average using the 15-minute readings. 

QuaQuaSSOBot

Averaging Period 2 hours 2 hours 2 hours 6 m
 

 POTLINE 5 

A. Regulated Source(s) 

 

Description: Potline 5 (Stack and Roof Monitor) 

Emission Source 

Group: 

42 

Equip Designation(s): 4250, 3091 

Facility: Century Aluminum of KY 

 

B. Applicable Regulations and Emission Limits 

 

Regulation(s): 40 CFR Part 63, Subpart LL 

Emission 

Limit(s): 

Total Fluoride 

(Gaseous+Particulate) 

1.2 lbs/ton of Al produced 

Monitoring 

Requirement(s): 

Alumina Flow Rate 

Exhaust Gas Flow Rate 

Visible Emissions (Qualitative and Method 9) 

C. Control Technology 

Dry Alumina Scrubber 480063 for ducted emissions from individual reduction cells 

Stack – Emission Point 89 

Roof Monitor – Emission Point 90 

D. Compliance Schedule 

The permittee shall implement the parametric monitoring plan (with latest revision date of 

February 4, 2011) within 120 days of the approval date (U. S. EPA approved the plan on 

February 7, 2011). 
Monitoring Approach for Potline 5 

A. Indicator Gas Flow Rate Alumina Flow Rate Visible Emissions P

Measurement 

Approach 

Gas flow is ensured by measurement of system differential pressure at the manifold leading to the baghouse (system pressure). 

Alumina flow is measured in lbs/hr by a Milltronics Model E-40 impact flow meter and recorded to the 

PLC every 15 minutes and combined as a 2-hour rolling average. 

Visible emissions will be observed by a trained observer at least once per day if weather permits. If visible emissions are observed which are indicative of abnormal operation, a full Method 9 will be conducted within 1 hour or whenever weather permits. 

SdSSw

B. Indicator Range 3.41-3.59 in H2O > 19,623 lbs/hr Visible Emissions - Daily 

< 20% - Method 9 Excursions trigger inspection, corrective action, and reporting. 

Inin nFid

C. Performance Criteria 

Data 

Representativeness 

The pressure transmitters have a minimum accuracy of + 0.075% 

±0.5% Observations are performed at the 

stack exhaust while the unit is operating. 

N

Verification of 

Operational Status 

This system pressure is displayed on the operator's control screen. The system continuously monitors the system pressure and alarms the operator if it falls below the minimum. 

The system has flow sensors at the alumina distribution box and at each reactor module. If the distribution box does not discharge or the reactor modules are not receiving flow, then an alarm displays on the operators screen requiring operator intervention. 

NA N

QA/QC Practices and 

Criteria 

The pressure transmitters will be calibrated annually to a NIST traceable standard. 

The impact flowmeter will be calibrated annually to a NIST traceable standard. 

Observers recertified to M9 every 6 months 

OaPins

Monitoring Frequency Continuously Continuously Daily qualitative, M9 quantitative if 

visible emissions are observed. M9 minimum once per week 

InF

Data Collection 

Procedures 

15 minute instantaneous readings are computed and recorded. The PLC then calculates and records 2-hr average using the 15-minute readings. 

15 minute instantaneous readings are recorded. The PLC then calculates and records 2-hr average using the 15-minute readings. 

Qualitative recorded by operator Quantitative documented on SSOP 810-011FA Both kept for at least five years 

InFetr

Averaging Period 2 hours 2 hours 6 minute N
 

GREEN CARBON 

A. Regulated Source(s) 

 

Description: Green Carbon (Anode Paste Production Plant) 

 Group: 31 

Equip 

Designation(s): 

0351-0359, 0362, 0364, 2035, 2037, 0425, 2036, 2006, 

0135, 2010 

Facility: Century Aluminum of KY 

 

B. Applicable Regulations and Emission Limits 

 

Regulation(s): 40 CFR Part 63, Subpart LL 

401 KAR 59:010 

401 KAR 51:017 

Emission 

Limit(s): 

Polycyclic Organic Matter 13.94 lbs/hr POM (VOC) 

Monitoring 

Requirement(s): 

Coke Flow Rate 

Exhaust Gas Flow Rate 

Visible Emissions (Qualitative and Method 9) 

C. Control Technology 

Dry Coke Scrubber (Pitch Fume Scrubber) 

D. Compliance Schedule 

The permittee shall implement the parametric monitoring plan (with latest revision date of 

February 4, 2011) within 120 days of the approval date (U. S. EPA approved the plan on 

February 7, 2011). 
Monitoring Approach for Green Carbon 

A. Indicator Gas Flow Rate Coke Flow Rate Visible Emissi

Measurement 

Approach 

Gas flow is continuously measured using Brandt Flow Meter located in the exhaust stack. 

The frequency of the rotary vane feeder monitored in hertz by 1771-IFE Analog Input Cards, translated to rotations, and then, knowing the pocket fill, calculated to lbs/hr of flow. 

Visible emissionobserver at leaspermits. If visibwhich are indicafull Method 9 wwhenever weat

B. Indicator Range 40,000-55,000 SCFM >50 Hz (1.97 tons/hr) Visible Emissio

< 20% - Method Excursions triggand reporting. 

C. Performance Criteria 

Data 

Representativeness 

The pressure transmitters have a minimum accuracy of + 0.5% 

±0.5% Observations a

exhaust while th

Verification of 

Operational Status 

This system flow is displayed on the operator's control screen. The system continuously monitors the air flow and alarms the operator if it falls below the minimum. 

The system has flow sensors at the rotary airlock discharge, the distribution feeders that distribute coke collection system duct work and venture reactor. If the airlock is not operating, the distribution feeders are not operating, or the reactor is not receiving flow, then an alarm displays on the operators screen requiring operator intervention. 

NA 

QA/QC Practices and 

Criteria 

The flow meter will be calibrated annually to a NIST traceable standard. 

Verification that actual flow exiting the feeder matches expected flow once per month. Inspection and adjustment of vane blade clearance to manf. specs. once per quarter. 

Observers rece

Monitoring Frequency Continuously Continuously Daily qualitative

emissions are oM9 minimum on

Data Collection 

Procedures 

15 minute instantaneous readings are computed and recorded. The PLC then calculates and records 2-hr average using the 15-minute readings. 

15 minute instantaneous readings are recorded. The PLC then calculates and records 2-hr average using the 15-minute readings. 

Qualitative recoQuantitative doBoth kept for at 

Averaging Period 2 hours 2 hours 6 minute 
 

POTLINES 1-4 

A. Regulated Source(s) 

 

Description: Potlines 1-4 (Stack and Roof Monitors) 

Emission Source 

Group: 

42 

Equip 

Designation(s): 

4200, 4220, 4230, 4240, 2092, 2093, 2094, 2095 

Facility: Century Aluminum of KY 

 

B. Applicable Regulations and Emission Limits 

 

Regulation(s): 40 CFR Part 63, Subpart LL 

401 KAR 59:010 

401 KAR 51:017 

Emission 

Limit(s): 

Total Fluoride 

(Gaseous+Particulate) 

2.5 lbs/ton of Al produced 

Monitoring 

Requirement(s): 

Exhaust Gas Flow Rate 

Water Flow Rate 

Secondary Current and Voltage 

Visible Emissions (Qualitative and Method 9) 

C. Control Technology 

Multiclone, Electrostatic Precipitator & Wet Scrubber Control System 

Emission Point 84 – (Stack) 

Emission Point 85 – (Potline #1 Roof Monitor) 

Emission Point 86 – (Potline #2 Roof Monitor) 

Emission Point 87 – (Potline #3 Roof Monitor) 

Emission Point 88 – (Potline #4 Roof Monitor) 

D. Compliance Schedule 

The permittee shall implement the parametric monitoring plan (with latest revision date of 

February 4, 2011) within 120 days of the approval date (U. S. EPA approved the plan on 

February 7, 2011). 
Monitoring Approach for Potlines 1-4 

A. Indicator Gas Flow Rate Water Flow Rate Secondary Current & 

Voltage 

Measurement 

Approach 

The amperage of the fan motors monitored by 1771-IFE Analog Input Cards. Number of fans in operation 

Water flow into each individual scrubber via flow meter 

ESP secondary voltage and current are measured for each field. The secondary voltage is measured using a voltmeter and the secondary current is measured using an ammeter. 

B. Indicator Range 170-210 amps 

3 Fans Operating per side (6 total) 

Water Flow – See Table 3.4.2.(C)-1 on Page 32 for indicator ranges 

Secondary Current 

80-156 mA 

Secondary Voltage 

20-29 mV 

C. Performance Criteria 

Data 

Representativeness 

Fan Amps ±0.5% # Fans Operating – 100% 

Flow Meters ±1.0% The voltage and current are 

measured using the instrumentation the manufacturer provided with the ESP. 

Verification of 

Operational Status 

This failure or operation out of indicator range is displayed on the operator's control screen. The system continuously monitors the fan amperage and alarms the operator if it falls below the minimum or a fan shuts down. 

The system will alarm the operator if the pump shuts down. 

Confirm the meters read zero when the unit is not operating. 

QA/QC Practices and 

Criteria 

The measurement device is calibrated at least annually to a NIST traceable standard. 

The measurement devices are calibrated at least annually to a NIST traceable standard. 

The measurement devices are calibrated at least annually to a NIST traceable standard. 
Attachment #2

   






Monitoring Frequency Continuously Continuously The secondary voltage and 

current are measured once every 15 minutes to calculate the total power input once every 15 minutes. 

Data Collection 

Procedures 

15 minute instantaneous readings are computed and recorded for fan amps. The PLC then calculates and records 2-hr average using the 15-minute readings. 

15 minute instantaneous readings are recorded for each scrubber. The PLC then calculates and records 2-hr average using the 15-minute readings. 

15 minute instantaneous readings are recorded. The PLC then calculates and records 2-hr average using the 15-minute readings. 

Averaging Period 2 hours 2 hours 2 hours 
Attachment #3

   

















Attachment #4
MATERIAL SAFETY DATA SHEET 

1. CHEMICAL PRODUCT AND COMPANY IDENTIFICATION 

KOPPERS INC. MEDICAL EMERGENCIES: 877-737-9047

436 SEVENTH AVENUE MEDICAL EMERGENCIES OUTSIDE U.S.A.: 651-632-9269

PITTSBURGH, PA 15219-1800 TECHNICAL ASSISTANCE: 412-227-2001

naorgmsds@koppers.com MSDS REQUESTS: 866-852-5239

CHEMTREC ASSISTANCE: 800-424-9300

CANUTEC: 613-996-6666

MSDS NUMBER: 00228307 

SUBSTANCE: CARBON PITCH LIQUID

TRADE NAMES/SYNONYMS:

925 PITCH LIQUID; CARBON PITCH MELTED 

CHEMICAL FAMILY: hydrocarbons, coal-tar 

PRODUCT USE: process chemical 

REVISION DATE: Jun 14 2007 

2. HAZARDS IDENTIFICATION 

NFPA RATINGS (SCALE 0-4): HEALTH=2 FIRE=1 REACTIVITY=0 

EMERGENCY OVERVIEW:

COLOR: black 

PHYSICAL FORM: changes from solid to liquid as temperature increases 

ODOR: coal tar odor 

SIGNAL WORD: WARNING! 

MAJOR HEALTH HAZARDS: respiratory tract irritation, skin irritation, eye irritation, lung cancer, skin 

cancer, bladder cancer, scrotal cancer 

PRECAUTIONARY STATEMENTS: Do not breathe vapor or mist. Do not get in eyes, on skin, or on 
clothing. Keep container tightly closed. Wash thoroughly after handling. Use only with adequate ventilation. 

Observe good hygiene and safety practices when handling this product. Do not use this product until the 

MSDS has been read and understood. 

POTENTIAL HEALTH EFFECTS:

INHALATION:

SHORT TERM EXPOSURE: irritation 

LONG TERM EXPOSURE: changes in body temperature, vomiting, difficulty breathing, headache, 

drowsiness, dizziness, loss of coordination, convulsions, lung cancer, bladder cancer 

SKIN CONTACT:

SHORT TERM EXPOSURE: irritation, sensitivity to sunlight, skin discoloration, skin disorders, thermal 

burns from heated material 

LONG TERM EXPOSURE: skin disorders, sensitivity to sunlight, skin cancer, scrotal cancer 

EYE CONTACT:

SHORT TERM EXPOSURE: irritation, sensitivity to sunlight, eye damage, thermal burns from heated 

material 

LONG TERM EXPOSURE: irritation, sensitivity to sunlight, eye damage 

INGESTION:

SHORT TERM EXPOSURE: irritation, nausea, vomiting, stomach pain 

LONG TERM EXPOSURE: no information on significant adverse effects 

3. COMPOSITION, INFORMATION ON INGREDIENTS 

COMPONENT: HIGH TEMPERATURE COAL TAR PITCH 

CAS NUMBER: 65996-93-2 

PERCENTAGE: 100 

COMPONENT: BENZO(G,H,I)PERYLENE 

CAS NUMBER: 191-24-2 

PERCENTAGE: 0.91-1.48 

COMPONENT: BENZO(A)PYRENE 

CAS NUMBER: 50-32-8 

PERCENTAGE: 1.22-1.43 

COMPONENT: FLUORANTHENE 

CAS NUMBER: 206-44-0 

PERCENTAGE: 0.77-1.40 

COMPONENT: INDENO(1,2,3-CD)PYRENE 

CAS NUMBER: 193-39-5 

PERCENTAGE: 0.98-1.37 

COMPONENT: PYRENE 

CAS NUMBER: 129-00-0 

PERCENTAGE: 0.72-1.26 

COMPONENT: 1,2-BENZPHENANTHRENE 
CAS NUMBER: 218-01-9 

PERCENTAGE: 0.77-1.06 

COMPONENT: 1,2-BENZANTHRACENE 

CAS NUMBER: 56-55-3 

PERCENTAGE: 0.78-1.04 

COMPONENT: DIBENZO(A,H)PYRENE 

CAS NUMBER: 189-64-0 

PERCENTAGE: 0.52-0.98 

COMPONENT: BENZO(B)FLUORANTHENE 

CAS NUMBER: 205-99-2 

PERCENTAGE: 0.83-0.93 

COMPONENT: BENZO(J)FLUORANTHENE 

CAS NUMBER: 205-82-3 

PERCENTAGE: 0.59-0.66 

COMPONENT: BENZO(K)FLUORANTHENE 

CAS NUMBER: 207-08-9 

PERCENTAGE: 0.55-0.62 

COMPONENT: DIBENZO(A,E)PYRENE 

CAS NUMBER: 192-65-4 

PERCENTAGE: 0.34-0.60 

COMPONENT: DIBENZO(A,I)PYRENE 

CAS NUMBER: 189-55-9 

PERCENTAGE: 0.22-0.51 

COMPONENT: DIBENZ(A,H)ANTHRACENE 

CAS NUMBER: 53-70-3 

PERCENTAGE: 0.22-0.33 

COMPONENT: CARBAZOLE 

CAS NUMBER: 86-74-8 

PERCENTAGE: 0.01-0.10 

4. FIRST AID MEASURES 

INHALATION: If adverse effects occur, remove to uncontaminated area. Give artificial respiration if not 

breathing. If breathing is difficult, oxygen should be administered by qualified personnel. Get immediate 

medical attention. 

SKIN CONTACT: For thermal burns, cool affected areas as quickly as possible by drenching or immersing 

in water. Wash skin with soap and water for at least 15 minutes, or use a waterless handcleaner, while 

removing contaminated clothing and shoes. Get immediate medical attention, if needed. 
EYE CONTACT: Immediately flush eyes with plenty of water for at least 15 minutes. Get medical 

attention, if needed. 

INGESTION: DO NOT induce vomiting. If a large amount is swallowed, get medical attention. Do not give 

anything by mouth to unconscious or convulsive person. If vomiting occurs, keep head lower than hips to 

help prevent aspiration. 

5. FIRE FIGHTING MEASURES 

FIRE AND EXPLOSION HAZARDS: During fire conditions, vapors and decomposition products may be 

released, forming flammable/explosive mixtures in air. Containers may rupture or explode if exposed to heat. 

EXTINGUISHING MEDIA: regular dry chemical, carbon dioxide, regular foam, water spray 

FIRE FIGHTING: Avoid inhalation of material or combustion by-products. Stay upwind and keep out of 

low areas. Use extinguishing agents appropriate for surrounding fire. Flood with fine water spray. Directly 

spraying water or foam onto hot burning product may cause frothing. For fires in cargo or storage area: Cool 

containers with water from unmanned hose holder or monitor nozzles until well after fire is out. If this is 

impossible then take the following precautions: Keep unnecessary people away, isolate hazard area and deny 

entry. Withdraw immediately in case of rising sound from venting safety device or any discoloration of tanks 

due to fire. 

FIRE FIGHTING PROTECTIVE EQUIPMENT: Full fire fighting turn-out gear (bunker gear). 

SENSITIVITY TO MECHANICAL IMPACT: No 

SENSITIVITY TO STATIC DISCHARGE: Yes (dust) 

FLASH POINT: >374 F (>190 C) (PMCC) 

AUTOIGNITION: >750 F (>399 C) 

FLAMMABILITY CLASS (OSHA): IIIB 

6. ACCIDENTAL RELEASE MEASURES 

WATER RELEASE:

Subject to California Safe Drinking Water and Toxic Enforcement Act of 1986 (Proposition 65). Keep out of 

water supplies and sewers. 

OCCUPATIONAL RELEASE:

Stop leak if possible without personal risk. Small spills: Absorb with sand or other non-combustible material. 

Collect spilled material in appropriate container for disposal. In Canada, report releases to provincial 

authorities, municipal authorities, or both, as required. Due to the concentration of Benzo(a)pyrene and the 

CERCLA (40 CFR 302.4) reportable quantity of 1 pound, the release of 70 pounds (6 gallons) of this product 

requires National Response Center notification. 
7. HANDLING AND STORAGE 

STORAGE: Store and handle in accordance with all current regulations and standards. Label all containers. 

Keep container in a well-ventilated place. Keep away from heat, sparks and flame. Protect from physical 

damage. Notify State Emergency Response Commission for storage or use at amounts greater than or equal 

to the TPQ (U.S. EPA SARA Section 302). SARA Section 303 requires facilities storing a material with a 

TPQ to participate in local emergency response planning (U.S. EPA 40 CFR 355.30). 

HANDLING: Avoid breathing vapors of heated materials. Avoid contact with eyes, skin and clothing. 

When using, do not eat, drink or smoke. Wash exposed areas thoroughly with soap and water, or a waterless 

handcleaner, after skin contact and before eating, drinking, using tobacco products, or restrooms. Use 

protective skin cream on exposed skin before and during work shift. To reduce sun sensitivity a sun-blocking 

lotion (SPF 15+) can also be applied prior to application of a protective cream. Contaminated clothing 

should be removed and laundered before reuse. 

8. EXPOSURE CONTROLS, PERSONAL PROTECTION 

EXPOSURE LIMITS:

HIGH-TEMP. COAL TAR PITCH:

COAL TAR PITCH VOLATILES:

0.2 mg/m3 OSHA TWA (benzene soluble fraction) 

0.2 mg/m3 ACGIH TWA (benzene soluble fraction) 

0.1 mg/m3 NIOSH recommended TWA 10 hour(s) (cyclohexane extractable fraction) 

VENTILATION: Ensure adequate ventilation. Ensure compliance with applicable exposure limits. 

EYE PROTECTION: ANSI Z87.1-1989 approved safety glasses with side shields. Provide an emergency 

eye wash fountain and quick drench shower in the immediate work area. At elevated temperatures: A 

faceshield is recommended. 

CLOTHING: Wear protective clothing to prevent contact. Use protective skin cream on exposed skin 

before and during work shift. Contaminated clothing should be removed and laundered before reuse. When 

material is at an elevated temperature, wear appropriate heat resistant clothing. 

GLOVES: Wear appropriate gloves. When material is at an elevated temperature, wear appropriate heat 

resistant gloves. 

PROTECTIVE MATERIAL TYPES: protective skin creams, chemical resistant material, heat resistant 

material 

RESPIRATOR: If the applicable TLVs and/or PELs are exceeded, use canister or cartridge respirators, 

which are MSHA/NIOSH-approved, with organic vapor cartridges. 

9. PHYSICAL AND CHEMICAL PROPERTIES 
PHYSICAL STATE: liquid 

COLOR: black 

TEXTURE: viscous 

PHYSICAL FORM: changes from solid to liquid as temperature increases 

ODOR: coal tar odor 

BOILING POINT: >464 F (>240 C) 

MELTING POINT: 104-356 F (40-180 C) 

VAPOR PRESSURE: negligible 

VAPOR DENSITY (air=1): >1 

SPECIFIC GRAVITY (water=1): 1.26-1.34 @ 15.5 C 

WATER SOLUBILITY: almost insoluble 

PH: Not applicable 

VOLATILITY: Not available 

ODOR THRESHOLD: Not available 

EVAPORATION RATE: Not available 

COEFFICIENT OF WATER/OIL DISTRIBUTION: Not available 

10. STABILITY AND REACTIVITY 

REACTIVITY: Stable at normal temperatures and pressure. 

CONDITIONS TO AVOID: Avoid heat, flames, sparks and other sources of ignition. Avoid contact with 

incompatible materials. 

INCOMPATIBILITIES: oxidizing materials 

HAZARDOUS DECOMPOSITION:

Thermal decomposition products: carbon monoxide, carbon dioxide, oxides of nitrogen, polynuclear 

aromatic hydrocarbons 

POLYMERIZATION: Will not polymerize. 

11. TOXICOLOGICAL INFORMATION 

CARBON PITCH LIQUID:

CARCINOGEN STATUS: OSHA: No, NTP: Yes, IARC: Yes, (See below for additional information on 

component carcinogen status) 

TARGET ORGANS: respiratory tract system, skin, eyes, bladder, scrotum 

MEDICAL CONDITIONS AGGRAVATED BY EXPOSURE: respiratory disorders, skin disorders, 

central nervous system disorders (i.e. headache, drowsiness, dizziness, loss of coordination) 

ADDITIONAL DATA: This product is coal tar pitch. Volume 35 of the IARC monograph states that there 

is sufficient evidence that coal tar pitches are carcinogenic in humans. IARC's conclusion is based upon 

studies suggesting an association between skin cancer and chronic occupational dermal exposure to coal tar 

pitches and upon other historical studies and anecdotal reports showing an association between dermal 

exposure to coal tar pitch and scrotal cancer in the absence of good hygiene practices. 
Epidemiological studies of aluminum reduction workers showed an excess risk of developing bladder cancer 

for workers with chronic inhalation overexposure to coal tar pitch volatiles in excess of the recommended 

permissible exposure level. Studies also suggest an association between lung cancer and chronic inhalation 

overexposure to coal tar pitch volatiles in excess of the recommended permissible exposure level. A recent 

animal study may suggest an association between lung cancer and pulmonary deposition of particulate matter 

originating from coal tar pitches. It is not anticipated, however, that use of this product in liquid form will 

create a respirable dust. 

HIGH-TEMP. COAL TAR PITCH:

CARCINOGEN STATUS: NTP: Known Human Carcinogen; IARC: Human Sufficient Evidence, Animal 

Sufficient Evidence, Group 1; ACGIH: A1 -Confirmed Human Carcinogen (Coal tar pitch volatiles) 

LOCAL EFFECTS:

Irritant: skin, eye 

MEDICAL CONDITIONS AGGRAVATED BY EXPOSURE: respiratory disorders, skin disorders, 

central nervous system disorders 

12. ECOLOGICAL INFORMATION 

Not available 

13. DISPOSAL CONSIDERATIONS 

Dispose in accordance with all applicable regulations. 

14. TRANSPORT INFORMATION 

U.S. DOT 49 CFR 172.101:

PROPER SHIPPING NAME: Elevated temperature liquid, n.o.s. RQ 

ID NUMBER: UN3257 

HAZARD CLASS OR DIVISION: 9 

PACKING GROUP: III 

LABELING REQUIREMENTS: 9 

OTHER INFORMATION: Product in Tank Car or Tank Truck is shipped as 'Elevated temperature liquid, 

n.o.s.' 

CANADIAN TRANSPORTATION OF DANGEROUS GOODS:

SHIPPING NAME: Elevated temperature liquid, n.o.s. 

UN NUMBER: UN3257 

CLASS: 9 

PACKING GROUP/RISK GROUP: III 

15. REGULATORY INFORMATION 
U.S. REGULATIONS:

SARA TITLE III SECTION 302 EXTREMELY HAZARDOUS SUBSTANCES (40 CFR 355.30): 

PYRENE: 1000/10000 LBS TPQ 

SARA TITLE III SECTION 304 EXTREMELY HAZARDOUS SUBSTANCES (40 CFR 355.40): 

PYRENE: 5000 LBS RQ 

SARA TITLE III SARA SECTIONS 311/312 HAZARDOUS CATEGORIES (40 CFR 370.21): 

ACUTE: Yes 

CHRONIC: Yes 

FIRE: No 

REACTIVE: No 

SUDDEN RELEASE: No 

SARA TITLE III SECTION 313 (40 CFR 372.65): 

BENZO(G,H,I)PERYLENE

Benzo(a)pyrene

FLUORANTHENE

Indeno (1,2,3-cd)pyrene

1,2-Benzphenanthrene (Chrysene)

1,2-Benzanthracene

Dibenzo(a,h)pyrene

BENZO(B)FLUORANTHENE

BENZO(J)FLUORANTHENE

BENZO(K)FLUORANTHENE

Dibenzo(a,e)pyrene

Dibenzo(a,i)pyrene

Dibenz(a,h)anthracene

STATE REGULATIONS:

California Proposition 65: 

Known to the state of California to cause the following: 

Soots, tars, and mineral oils (untreated and mildly treated oils and used engine oils)

Cancer (Feb 27, 1987) 

Benzo(a)pyrene

Cancer (Jul 01, 1987) 

Indeno (1,2,3-cd)pyrene

Cancer (Jan 01, 1988) 

1,2-Benzphenanthrene (Chrysene)

Cancer (Jan 01, 1990) 

1,2-Benzanthracene

Cancer (Jul 01, 1987) 

Dibenzo(a,h)pyrene

Cancer (Jan 01, 1988) 

BENZO(B)FLUORANTHENE

Cancer (Jul 01, 1987) 

BENZO(J)FLUORANTHENE

Cancer (Jul 01, 1987) 

BENZO(K)FLUORANTHENE
Cancer (Jul 01, 1987) 

Dibenzo(a,e)pyrene

Cancer (Jan 01, 1988) 

Dibenzo(a,i)pyrene

Cancer (Jan 01, 1988) 

Dibenz(a,h)anthracene

Cancer (Jan 01, 1988) 

Carbazole

Cancer (May 01, 1996) 

CANADIAN REGULATIONS:

WHMIS CLASSIFICATION: D2A. 

NATIONAL INVENTORY STATUS:

U.S. INVENTORY (TSCA): Listed on inventory. 

TSCA 12(b) EXPORT NOTIFICATION: Not listed. 

CANADA INVENTORY (DSL/NDSL): All components of this product are listed on either the DSL or the 

NDSL. 

16. OTHER INFORMATION 

MSDS SUMMARY OF CHANGES

2. HAZARDS IDENTIFICATION 

3. COMPOSITION, INFORMATION ON INGREDIENTS 

11. TOXICOLOGICAL INFORMATION 

©Copyright 1984-2007 MDL Information Systems, Inc. All rights reserved.

The information set forth in this Material Safety Data Sheet does not purport to be all-inclusive and 

should be used only as a guide. While the information and recommendations set forth herein are 

believed to be accurate, the company makes no warranty regarding such information and 

recommendations and disclaims all liability from reliance thereon. 
RUETGERS Canada Inc. 

725 Strathearne Ave. N., Hamilton, ON L8H 5L3 

Tel: (905) 544-2891; Fax: (905) 544-4942

MATERIAL SAFETY DATA SHEET: COAL TAR PITCH 

Page 1 of 8 

EMERGENCY NUMBER: 905-544-3722 OR CANUTEC (TOLL FREE): 613-996-6666

1 - PRODUCT IDENTIFIER: COAL TAR PITCH 

Product Name(s): 

Pitch (Liquid), Pitch (Flaked) 

Formula: 

Complex mixture of aromatic and heterocyclic 

hydrocarbons 

Synonym(s): 

Electrode Pitch, Binder Pitch, Aromatic Pitch 

Chemical Family: 

Aromatic hydrocarbons

Product Use(s): 

Electrode Binder, Anode Binder 

WHMIS Classification: 

Class(es): D.2A, D.2B

T.D.G. Classification & Shipping Name: 

Not Regulated 

NFPA Hazard Classification: 

Flammability: 1 

Health: 2 

Reactivity: 0 

IMO Number: 

None

DOT Shipping Numbers: 

NA 3077, UN 3077, UN 3256, UN 3257, depending on 

the shipping mode, temperature and flash point. See 

Section 8.

2 - PHYSICAL DATA 

Odour And Appearance: Temperature dependent. Black solid when allowed to

cool. 

Physical State: Solid @ 21.1°C 

Solubility In Water: Negligible 

Specific Gravity (Water=1): 1.33 ± 0.03 @ 25°C 

Boiling Point: >240°C 

Freezing Point: Not applicable 

Odour Threshold: Not available 

Coefficient of Water/Oil Distribution: Not available 

% Volatiles: 0% @ 360°C (132M & 150M) 

Up to 5% @ 360°C (110M) 

Vapour Density (Air = 1): >1 

Vapour Pressure (mm Hg): None @ 20°C 

pH: Not applicable 

Evaporation Rate (butyl acetate = 1): Not available 
RUETGERS Canada Inc. 

725 Strathearne Ave. N., Hamilton, ON L8H 5L3 

Tel: (905) 544-2891; Fax: (905) 544-4942

MATERIAL SAFETY DATA SHEET: COAL TAR PITCH 

Page 2 of 8 

EMERGENCY NUMBER: 905-544-3722 OR CANUTEC (TOLL FREE): 613-996-6666

3 - HAZARDOUS INGREDIENTS 

Ingredients C.A.S. # Conc. % (W/W) L.D. 50 ( Species & Route) 

Coal Tar Pitch 65996-93-2 100 Skin-Mouse 

TDLo: 3600 mg/kg/18W-I 

Oral-Rat: 6200 mg/kg 

The following substances are considered hazardous by one or more regulatory agencies and were identified 

in typical coal tar pitch samples at concentrations greater than 0.01% by weight but less than SARA Section 

313 de minimis concentrations using gas chromatography/mass spectroscopy USEPA Reference Methods 

8240 (volatile organic compounds) and 8270 (semi-volatile organic compounds), along with sample 

preparation method USEPA Reference Method 3510 (separator funnel liquid extraction with methylene 

chloride): 

Component CAS No.

2-methylnaphthalene 91-57-6 

Acenaphthene 82-32-9 

Anthracene 120-12-7 

Benzo-c-acridine 225-51-4 

Benzo(e)pyrene 192-97-2 

Benzo-g,h,i-perylene 191-24-2 

Benzo(a)pyrene 50-32-8 

Benzo(j)fluoranthene 205-82-3 

Benzo(k)fluoranthene 207-08-9 

Benzo-c-acridine 225-51-4 

Chrysene 218-01-9 

Dibenzofuran 132-64-9 

Dibenz(a, h)anthracene 53-70-3 

Fluoranthene 206-44-0 

Fluorene 86-73-7 

Indeno(1,2,3-cd)pyrene 193-39-5 

Naphthalene 91-20-3 

Phenanthrene 85-01-8 

Pyrene 129-00-0 

Substances subject to reporting under SARA Section 313 are listed in Section 9. 

4 - FIRE & EXPLOSION HAZARDS 

Flash Point (PMCC): 

110M 

132M 

150M 

234-245°C 

242-271°C 

262-284°C 

U.F.L and L.F.L.: Not available 

Auto-Ignition Temperature: > 399°C 

Sensitivity to Mechanical Impact: None 
RUETGERS Canada Inc. 

725 Strathearne Ave. N., Hamilton, ON L8H 5L3 

Tel: (905) 544-2891; Fax: (905) 544-4942

MATERIAL SAFETY DATA SHEET: COAL TAR PITCH 

Page 3 of 8 

EMERGENCY NUMBER: 905-544-3722 OR CANUTEC (TOLL FREE): 613-996-6666

4 - FIRE & EXPLOSION HAZARDS (continued)

Sensitivity to Static Discharge: Yes, for solid pitch dust. 

Conditions of Flammability: At elevated temperatures may generate vapours that may 

ignite in the presence of air and a source of ignition. 

Means of Extinction: Sand, C02

, foam, water fog, dry chemical, steam. 

Fire Fighting Procedures: Wear complete fire service protective equipment, including 

full-face MSHA/NIOSH approved self-contained breathing 

apparatus. Use water or water spray to cool fire-exposed 

containers and structures and to protect personnel. 

Water/fog can control unconfined pitch fires, but water may 

cause frothing or eruption in closed tanks. 

Unusual Fire and Explosion: Burning may emit hazardous fumes/vapours which can 

form flammable/explosive mixtures in air and which may 

be in concentrations greater than the PEL/TLV. Airborne 

pitch dust may form explosive mixtures with air. Cloud 

ignition temperature is 710°C minimum. Explosion 

concentration (dust) 1000 mg/ 0.03 m3. Closed containers 

may explode when exposed to extreme heat. Liquid 

(molten) pitch at elevated temperatures will sustain 

combustion. 

Hazardous Combustion Products: CO2

, CO, NOx, SO2 and PAH's 

5 - REACTIVITY DATA 

Chemical Stability: Yes 

Conditions Contributing To Instability: None known @ STP 

Hazardous Polymerization: None 

Incompatibility: Avoid contact with water when confined and in a molten 

state. Avoid contact with strong oxidizing agents.

Reactivity: None 

Hazardous Decomposition Products: Does not decompose at ambient temperatures. Upon 

burning or heating may emit hazardous fumes/vapours in 

concentrations greater than the PEL/TLV. 
RUETGERS Canada Inc. 

725 Strathearne Ave. N., Hamilton, ON L8H 5L3 

Tel: (905) 544-2891; Fax: (905) 544-4942

MATERIAL SAFETY DATA SHEET: COAL TAR PITCH 

Page 4 of 8 

EMERGENCY NUMBER: 905-544-3722 OR CANUTEC (TOLL FREE): 613-996-6666

6 - TOXICOLOGICAL PROPERTIES 

Route of Entry: Skin X Eye X Ingestion X Inhalation X

Effects of Acute Exposure: Irritating to skin, eyes, throat and nose. Severe burn and inflammation 

may result after contact with liquid. 

Eye Contact: Exposure to fumes or vapours, may cause irritation and burning to the 

eyes. Reversible symptoms may include irritation, a burning sensation, 

intolerance to light, redness/swelling/tearing, and possible erosion of the 

surface of the cornea. Contact with heated material may cause thermal 

burns. 

Skin Contact: Contact with the skin can result in irritation which, when accentuated by 

sunlight, may result in a phototoxic skin reaction. Contact with heated 

material may cause thermal burns. Hot/molten coal tar pitch is a severe 

burn hazard. Prolonged and repeated skin contact in the absence of 

recommended hygiene practices may cause acne, folliculitis and more 

serious skin disorders such as changes in skin pigmentation, 

ulcerations, benign skin growths and skin cancer. 

Inhalation: Inhalation of fumes or vapours may cause temporary respiratory 

irritation. Acute respiratory effects caused by over-exposure to coal tar 

pitch volatiles may include coughing, sneezing, and swollen or irritated 

nasal mucosa or sinuses. Inhalation of fumes or vapours in significant 

excess of the PEL/TLV may lead to systemic symptoms such as 

salivation; vomiting; respiratory difficulties; headache; loss of pupillary 

reflexes; central nervous system (CNS) effects such as dizziness, 

weakness, possible loss of coordination and collapse; cyanosis; 

hypothermia; and convulsions. 

Ingestion: Ingestion may cause irritation of the gastrointestinal tract followed by one 

or more of the following: nausea, vomiting, and abdominal discomfort. 

Effects Of Chronic Exposure: See “Skin Contact Effects” above. 

Carcinogenicity: NTP X IARC X OSHA X ACGIH X

Exposure Limit: OSHA PEL/ACGIH TLV=0.2 mg/m3 (as coal tar pitch volatiles, benzene 

soluble fraction). 

Sensitization: None known 
RUETGERS Canada Inc. 

725 Strathearne Ave. N., Hamilton, ON L8H 5L3 

Tel: (905) 544-2891; Fax: (905) 544-4942

MATERIAL SAFETY DATA SHEET: COAL TAR PITCH 

Page 5 of 8 

EMERGENCY NUMBER: 905-544-3722 OR CANUTEC (TOLL FREE): 613-996-6666

6 - TOXICOLOGICAL PROPERTIES (continued)

Synergistic Effects: None known 

Irritancy: See “Effects of Acute Exposure” and “Effects of Chronic Exposure” 

above. 

Reproductive Toxicity and 

Teratogenicity:

None known. Although coal tar pitch does contain substances 

considered to be reproductive hazards by the State of California, no 

scientific study supports an association between coal tar pitch 

exposures and human reproductive hazards. 

Persons More Susceptible to 

Exposure:

Individuals with chronic respiratory disorders may be more susceptible 

to the effects of exposure to any airborne material. Individuals with 

preexisting skin disorders may be more susceptible to irritation, 

dermatitis and phototoxic reactions. Persons with a history of central 

nervous system (CNS) functional illness may be more susceptible to the 

effects when working with this product (see “Effects of Acute Exposure”) 

above. 

Mutagenicity: Available data characterizes coal tar pitch as a mutagen. 

7 - FIRST AID 

Skin Contact: For contact with molten product, do not remove contaminated clothing. 

Flush skin immediately with large amounts of cold water. If possible, 

submerge area in cold water. Pack with ice. Seek medical aid 

immediately. For other contact, remove all contaminated clothing and 

wash exposed area thoroughly with non-abrasive soap and water, or a 

mild detergent. 

Eye Contact: Flush eyes immediately with large amounts of water for at least 15 

minutes, occasionally lifting the eyelids. Seek medical aid immediately. 

Inhalation: Remove subject from exposure area to fresh air immediately. If 

breathing is difficult, give oxygen. If breathing has stopped, administer 

artificial respiration (e.g. mouth-to-mouth). Seek medical aid 

immediately. 

Ingestion: If the person is conscious, first induce vomiting to prevent further 

absorption. Do not give anything by mouth to an unconscious person. 

Give oxygen if respiration is shallow. Seek medical aid immediately. 
RUETGERS Canada Inc. 

725 Strathearne Ave. N., Hamilton, ON L8H 5L3 

Tel: (905) 544-2891; Fax: (905) 544-4942

MATERIAL SAFETY DATA SHEET: COAL TAR PITCH 

Page 6 of 8 

EMERGENCY NUMBER: 905-544-3722 OR CANUTEC (TOLL FREE): 613-996-6666

8 - PREVENTATIVE MEASURES 

Respiratory Protection: The need for respiratory protection depends on the type and magnitude 

of exposure. Use a MSHA/NIOSH approved respirator. Approved 

MSHA/ NIOSH respirators include either of the following, as required: a 

half-face piece or a full-face piece respirator with an organic vapour/ 

particulate cartridge; or a full-face piece continuous flow, positive 

pressure air supplied respirator. 

Skin Protection: Wear full body, industrial-type work clothing closed at the neck and 

sleeves. As required to prevent skin contact, wear chemical resistant 

gloves, footwear and coveralls; wear heat resistant gloves when 

handled at elevated temperatures. Application of certain protective 

creams for coal tar products and sunscreens before and during work 

may be beneficial and are recommended. Remove and launder 

contaminated clothing separate from other laundry before reuse. 

Eye Protection: Wear chemical/industrial safety glasses (with side shields), goggles, or 

face shields to prevent eye contact. Do not wear contact lenses when 

handling this material. Chemical splash goggles or face shields are 

highly recommended if handling molten material. 

Personal Hygiene: Wash exposed areas thoroughly with soap and water after handling and 

especially before eating, drinking, using tobacco products or rest rooms. 

Take a complete soap and water shower at the end of each work day. 

Do not smoke or eat in areas where this material is handled. Work 

clothes should be laundered before reuse. Remove and launder 

contaminated clothing separate from other laundry before reuse. 

Saturated shoes/boots should be discarded. 

Handling Procedures/ 

Equipment:

Avoid prolonged or repeated contact with skin or breathing of fumes/ 

vapours. Observe good personal hygiene practices and recommended 

procedures. Avoid contact with molten material. Wear appropriate 

protective equipment when performing maintenance on contaminated 

equipment. Closed system handling of liquid pitch could create 

excessive vapour concentrations in confined spaces; e.g., tanks, rail 

cars, tank trailers. When entering a confined space that has been in 

liquid pitch service follow confined space entry procedures set forth in 

the applicable regulations. 

Engineering Controls: Provide sufficient general or local exhaust ventilation in pattern/volume 

to maintain concentrations below the PEL/TLV and to maintain areas 

below flammable vapour concentrations. 
RUETGERS Canada Inc. 

725 Strathearne Ave. N., Hamilton, ON L8H 5L3 

Tel: (905) 544-2891; Fax: (905) 544-4942

MATERIAL SAFETY DATA SHEET: COAL TAR PITCH 

Page 7 of 8 

EMERGENCY NUMBER: 905-544-3722 OR CANUTEC (TOLL FREE): 613-996-6666

8 - PREVENTATIVE MEASURES (continued)

Spill or Leak Procedures: Avoid breathing vapours or contact with skin and eyes. Remove all 

ignition sources. Try to stop the source of the leak if possible without 

hazard. Ventilate the area if spill occurs indoors. Release or spillage of 

solid can be treated as a coal spillage and recovery made avoiding skin 

and eye contact. Shovel into dry, labeled containers and secure cover. 

Contain runoff of fire control water. If hot liquid is spilled, contain by 

dyking/berming with absorbent solids, such as sand, ashes, earth or 

other inert material as necessary to prevent entry into sewers or open 

bodies of water. Avoid contact with hot liquid/fumes/vapours. Provide 

cleanup personnel with appropriate protective clothing. 

In cases involving release to the environment, in Canada report to 

provincial authorities, municipal authorities, or both, as required; in the 

U.S., report the release to The National Response Center at 1-800-424-

8802. 

Due to the concentration of benzo(a)pyrene in coal tar pitch and the 

reportable quantity for benzo(a)pyrene of one pound, a CERCLA 

(Superfund) release of approximately 8 gallons (80 pounds) of coal tar 

pitch requires National Response Center notification. 

Waste Disposal: In Canada, dispose of the material in accordance with provincial 

regulations. In the U.S., dispose of the material as required by 

applicable federal, state and local regulations. 

Storage Requirements: Store in a labeled container in a clean, dry, well-ventilated area away 

from all sources of ignition. Protect containers from physical damage. 

Maintain good housekeeping. 

SPECIAL SHIPPING INFORMATION: 

DOT Shipping Description: 

(shipped below 100°C)

Other regulated substances, Solid, n.o.s. (contains benzo(a)pyrene and 

dibenz(a,h)anthracene), 9, NA 3077, PG III, RQ (contains benzo 

(a)pyrene and dibenz(a,h) anthracene). 

DOT Shipping Description: 

(shipped below 100°C)

Environmentally Hazardous Substance, Solid, n.o.s. (contains benzo 

(a)pyrene and dibenz(a,h)anthracene), 9, UN 3077, PG III, RQ (contains 

benzo(a)pyrene and dibenz(a,h) anthracene). 

DOT Shipping Description: 

(shipped below 100°C for marine 

bulk solid shipments)

Environmentally Hazardous Substance, Solid, n.o.s. (contains benzo 

(a)pyrene and dibenz(a,h)anthracene), 9, UN 3077, PG III, RQ (contains 

benzo(a)pyrene and dibenz(a,h) anthracene). 

DOT Shipping Description: 

(shipped above 100°C but below 

flash point)

Elevated Temperature Liquid, n.o.s. (contains benzo(a)pyrene and 

dibenz(a,h)anthracene), 9, UN 3257, PG III, RQ (contains benzo 

(a)pyrene and dibenz(a,h) anthracene). 
RUETGERS Canada Inc. 

725 Strathearne Ave. N., Hamilton, ON L8H 5L3 

Tel: (905) 544-2891; Fax: (905) 544-4942

MATERIAL SAFETY DATA SHEET: COAL TAR PITCH 

Page 8 of 8 

EMERGENCY NUMBER: 905-544-3722 OR CANUTEC (TOLL FREE): 613-996-6666

SPECIAL SHIPPING INFORMATION: (continued)

DOT Shipping Description:

(shipped at or above flash point)

Elevated Temperature Liquid, flammable, n.o.s. (contains benzo 

(a)pyrene and dibenz(a,h)anthracene), 3, UN 3256, PG III, RQ (contains 

benzo(a)pyrene and dibenz(a,h) anthracene). 

IMO Shipping Description: 

(Pitch prill hazardous only in 

bulk) 

Environmentally Hazardous Substance, Solid, n.o.s. (contains benzo 

(a)pyrene and dibenz(a,h)anthracene), 9, UN 3077, RQ (contains 

benzo(a)pyrene and dibenz(a,h) anthracene). 

TSCA Status: This product appears on the Toxic Substances Control Act (TSCA) 

Inventory. 

California Proposition 65: WARNING: This product contains a chemical known to the State of 

California to cause cancer. 

SARA Section 313: This product contains the following toxic chemicals subject to the 

reporting requirements of Section 313 of the Emergency Planning and 

Community Right-to-Know Act of 1986, and of 40 CFR Part 372, 

Subpart D: 

Component CAS No.

Benzo(a)anthracene 56-55-3 

Benzo(b)fluoranthene 205-99-2 

Benzo(a)pyrene 50-32-8 

9 - ENVIRONMENTAL/REGULATORY STATUS 

There are no known ingredients other than those listed in Section 3 which occur at a concentration greater 

than 0.01 % by weight and which are listed as a carcinogen in the IARC Monographs on the Report on 

Carcinogens or OSHA 29 CFR 1910.1001-1047 subpart Z Toxic and Hazardous Substances (Specifically 

Regulated Substances). This is based on gas chromatograph/mass spectroscopy USEPA Reference 

Methods 8240 (volatile organic compounds) and 8270 (semi-volatile organic compounds), along with sample 

preparation method USEPA Reference Method 3510 (separatory funnel liquid extraction with methylene 

chloride) on typical samples of coal tar pitch. 

 

Prepared By: Technical Manager 

Telephone: 905-544-2891 

Effective Date: June 2009 
CII Carbon, L.L.C Calcined Petroleum Coke

800 Rockmead Drive, Suite 250 Revised 02/28/2006

Kingwood TX 77339 Page 1 of 3

SECTION I - MATERIAL IDENTIFICATION 24 HOUR EMERGENCY INFORMATION

PRODUCT/CHEMICAL NAME: CII Carbon, LLC (281) 359-1487

CHEMTREC (800) 424-9300

IDENTIFICATION No.: COKE - 3 HMIS/NEPA

CHEMICAL FAMILY: HAZARD RATING

CAS No.: 64743-05-1

SECTION II - CHEMICAL COMPOSITION & RECOMMENDED EXPOSURE LIMITS

EXPOSURE GUIDELINES1 COMPOSITION/ CAS No. % WEIGHT (Dry Basis) ACGIH* OSHA*** 1910.1000

TLV (8-hr TWA)** PEL  (8-hr TWA)** 

Carbon / 7440-44-0 97 - 99% Not Established Not Established

Sulfur / 7704-34-9 0.5 - 4.5% Not Established Not Established

Dust ---------------- Note 2 Note 2

1. State, local or other agencies may have established more stringent limits. Consult local agencies for further information.

2. See Additional Information Section IX.

* ACGIH = American Conference of Governmental Industrial Hygienist *** OSHA = Occupational Safety and Health Administration

** TLV-T WA = Threshold Limit Value-Time Weighted Average **** PEL = Permissible Exposure Limit

SECTION III - PHYSICAL AND CHEMICAL PROPERTIES

Appearance & Odor Irregular, steel gray to black, 

granular, odorless solid Solubility in Water < 0.1%

Boiling Point Not Applicable Specific Gravity 2 (typically)

Bulk Density 45-55 lbs/ft3 Vapor Pressure Not Applicable

Freezing/Melting Point NA Vapor Density Not Applicable

Heat Value ~14,000 BTU/lb Volatility by weight Negligible

SECTION IV - HEALTH & SAFETY DATA

HEALTH HAZARDS Avoid contact with eyes. Wash thoroughly after handling.

PHYSICAL HAZARDS Keep away from all sources of ignition.

POTENTIAL HEALTH EFFECTS ACUTE CHRONIC

EYE CONTACT No Data Available

INHALATION (Breathing)

Repeated overexposure to dusts may result in 

irritation of the respiratory tract, pneumoconiosis 

(dust congested lungs), pneumontis (lung 

inflammation), coughing, and shortness of 

breath.

INGESTION (Swallowing) No Data Available

SKIN No Data Available

CII Material Safety Data Sheet

No significant irritation expected. Possible mechanical irritation. 

Possible irritation of respiratory tract. May aggravate pre-existing 

respiratory conditions. 

No significant health hazards expected. If large quantities are 

ingested, or discomfort occurs, seek medical attention.

First aid is not normally required. May be abrasive and mildy 

irritating. Prolonged or repeated contact may cause skin irritation or 

dermatitis to susceptible individuals.

Health No significant irritation expected. Possible abrasive mechanical 

irritation, dust may cause stinging, watering, or redness. Flush eyes 

with plenty of water.

Calcined Delayed Petroleum 

Coke, Shot Coke, or Ti-Coke

Carbon, carbonaceous 

material resulting from high 

temperature treatment of 

green petroleum coke

 4 = Extreme

 3 = Serious

 2 = Moderate

 1 = Minimal

0

0

1

Fire

Reactivity

Health

Other
Calcined Petroleum Coke

Page 2 of 3 Revised 02/28/2006

Flash Point (oF) Not Applicable Autoignition Temperature (oF) Not Applicable

Flammable Limits in Air (% by volume) Upper NA% Lower NA%

Extinguishing Media Dry chemical type preferred, carbon dioxide, foam, water spray, sand, or earth is recommended.

Special Fire Fighting Procedures

Unusual Fire & Explosion Hazards

Stability

Hazardous Polymerization

Conditions to Avoid None known

Incompatibility (Materials to avoid)

Typical Decomposition Products Sulfur oxides, carbon oxides (CO/CO2

), metal oxides.

SECTION V - FIRST AID MEASURES

EYES

INHALATION (Breathing)

INGESTION (Swallowing)

SKIN First aid is not normally required. Wash any chemical from the skin with soap and water.

SECTION VI - PRECAUTIONS FOR SAFE HANDLING & USE

EYE PROTECTION

RESPIRATORY PROTECTION

VENTILATION

SKIN PROTECTION

OTHER PROTECTIVE CLOTHING OR EQUIPMENT

SECTION VII - REGULATORY INFORMATION

Acute: Fire: Reactive

Chronic: Pressure:

SARA 313

EPA (CERCLA) REPORTABLE QUANTITY None

PRECAUTIONS FOR SAFE HANDLING & STORAGE

SPILLS OR RELEASES

DISPOSAL CONSIDERATIONS

Material Safety Data Sheet CII

This material contains no chemicals subject to the reporting requirements of SARA 313 and 40 CFR 372

Approved eye protection, such as safety glasses or goggles, to safeguard against potential eye contact is 

recommended.

Mechanically ventilate the work environment to reduce dust concentration and to maintain normal atmospheric oxygen 

levels.

First aid is not normally required. If breathing difficulties develop, move victim away from source of exposure and into 

fresh air. Seek medical attention.

First aid is not normally required. There are no known health effects form ingestion of small amounts. If swallowed and 

symptoms or discomfort develops, seek medical attention.

Appropriate respirator depends upon the type and magnitude of exposure. A NIOSH/MSHA approved dust respirator 

(i.e., type 95 [R or P] particulate filter) may be used under conditions where airborne concentrations are expected to 

exceed exposure limits for dust (see Section IX). Use a positive pressure air respirator, if there is potential for 

uncontrolled release, exposure levels are not known, or any other circumstances where air purifying respirators may 

not provide adequate protection. 

Contain and remove by mechanical means (scoop, sweep or vacuum). Prevent spilled material from entering sewers, 

storm drains, or other unauthorized treatment drainage systems and natural waterways.

Recommend using good personal hygiene practices and a clean source of water for flushing eyes and skin.

Not required. However, it is considered good practice to wear gloves when handling.

Incompatible with strong oxidizing agents, perchlorates, peroxides, nitric acid, especially when heated.

This material may burn , but will not ignite readily. When water is used to extinguish a fire in a confined storage space 

there is the possibility of a steam explosion. Whenever possible, the burning coke in a confined storage space should 

be removed and the material drenched in an open area to extinguish fire.

Reactivity Use washdown and spread out method. For fires beyond the incipient stage, emergency responders in the immediate 

SARA 311/312

No special requirements. However, material should be stored to minimize dust formation. The use of appropriate 

respiratory protection is advised when concentrations exceed any established exposure limits. Wash thoroughly after 

handling. Use good personal hygiene practices.

This material, if discarded as product, is not a RCRA "listed" or "characteristic" hazardous waste. Product may be 

processed by an approved recycler, or disposed of at an approved waste disposal facility. Method of disposal selected 

is subject to compliance with applicable federal, state and local laws and regulations and product characteristics at the 

time of disposal. Fire & Exposure

If irritation or redness develops, move victim away from exposure and into fresh air. Flush eyes with clean water. If 

symptoms persist, seek medical attention.

 Stable 

 Will Not Occur Will Occur 

 Yes 

 Yes 

 Yes No

 Yes 

 No Yes No

 No No

Unstable
Material Safety Data Sheet

Calcined Petroleum Coke

Page 3 of 3 Revised 02/28/2006

SECTION VIII - TRANSPORTATION INFORMATION

PROPER SHIPPING NAME Petroleum Coke REQUIRED PLACARDING None

HAZARD CLASS Non-Hazardous PACKING GROUP (P.G.)

SECTION IX - ADDITIONAL INFORMATION

ACGIH OSHA MSHA*

10 mg/m3 None Established 10 mg/m3 Total - Time Weighted Average

3 mg/m35 mg/m3 None Established Respiratory - Time Weighted Average

None Established 15 mg/m3 None Established Total - Short Term Exposure Limit (STEL) * Mining Health and Safety Administration

SECTION X - DOCUMENTARY INFORMATION

ISSUE DATE February 2006

PREVIOUS ISSUE DATE August 2005

IDENTIFICATION No. COKE-3

SECTION XI - DISCLAIMER OF EXPRESSED AND IMPLIED WARRANTIES

The conditions or methods of handling, storage, use and disposal of the product are beyond the supplier's control and may be beyond the 

supplier's knowledge. For this and other reasons, the supplier does not assume responsibility and expressly disclaims liability for loss, damage 

or expense arising out of or in connection with the handling, storage, use or disposal of the product.

The information in this MSDS was obtained from sources believed reliable. HOWEVER, THE INFORMATION IS PROVIDED WITHOUT ANY 

REPRESENTATION OR WARRANTY EXPRESSED OR IMPLIED REGARDING THE ACCURACY, COMPLETENESS OR CORRECTNESS 

OF THE INFORMATION, THE RESULTS TO BE OBTAINED FROM THE USE OF THIS INFORMATION OR THE PRODUCT, THE SAFETY 

OF THIS PRODUCT, OR THE HAZARDS RELATED TO ITS USE. Although certain hazards are described, we can not guarantee that these 

are the only hazards that exist.

If dust is generated the following exposure guidelines have been established for airborne particulates:

CII
MATERIAL SAFETY DATA SHEET 

1. CHEMICAL PRODUCT AND COMPANY IDENTIFICATION 

KOPPERS INC. MEDICAL EMERGENCIES: 877-737-9047

436 SEVENTH AVENUE MEDICAL EMERGENCIES OUTSIDE U.S.A.: 651-632-9269

PITTSBURGH, PA 15219-1800 TECHNICAL ASSISTANCE: 412-227-2001

naorgmsds@koppers.com MSDS REQUESTS: 866-852-5239

CHEMTREC ASSISTANCE: 800-424-9300

CANUTEC: 613-996-6666

MSDS NUMBER: 00228333 

SUBSTANCE: CARBON PITCH TYPE A

TRADE NAMES/SYNONYMS:

INDUSTRIAL PITCH / COAL TAR PETROLEUM; CARBON PITCH TYPE A - SOLID; CARBON 

PITCH TYPE A - LIQUID; CARBON PITCH CO-DISTILLED TYPE A; COAL TAR PITCH; PENCIL 

PITCH TYPE A 

CHEMICAL FAMILY: hydrocarbons, coal-tar 

PRODUCT USE: process chemical 

REVISION DATE: Jun 14 2007 

2. HAZARDS IDENTIFICATION 

NFPA RATINGS (SCALE 0-4): HEALTH=2 FIRE=1 REACTIVITY=0 

EMERGENCY OVERVIEW:

COLOR: black 

PHYSICAL FORM: changes from solid to liquid as temperature increases 

ODOR: coal tar odor 

SIGNAL WORD: WARNING! 

MAJOR HEALTH HAZARDS: respiratory tract irritation, skin irritation, eye irritation, lung cancer, skin 

cancer, bladder cancer, scrotal cancer, (See Section 11 for additional information on potential hazards of 

constituents of the product.) 
PRECAUTIONARY STATEMENTS: Do not breathe vapor or fumes. Do not get in eyes, on skin, or on 

clothing. Keep container tightly closed. Wash thoroughly after handling. Use only with adequate ventilation. 

Observe good hygiene and safety practices when handling this product. Do not use this product until the 

MSDS has been read and understood. 

POTENTIAL HEALTH EFFECTS:

INHALATION:

SHORT TERM EXPOSURE: irritation 

LONG TERM EXPOSURE: changes in body temperature, vomiting, difficulty breathing, headache, 

drowsiness, dizziness, loss of coordination, convulsions, lung cancer, bladder cancer 

SKIN CONTACT:

SHORT TERM EXPOSURE: irritation, sensitivity to sunlight, skin discoloration, skin disorders, thermal 

burns from heated material 

LONG TERM EXPOSURE: skin disorders, sensitivity to sunlight, skin cancer, scrotal cancer 

EYE CONTACT:

SHORT TERM EXPOSURE: irritation, sensitivity to sunlight, eye damage, thermal burns from heated 

material 

LONG TERM EXPOSURE: irritation, sensitivity to sunlight, eye damage 

INGESTION:

SHORT TERM EXPOSURE: irritation, nausea, vomiting, stomach pain 

LONG TERM EXPOSURE: no information on significant adverse effects 

3. COMPOSITION, INFORMATION ON INGREDIENTS 

COMPONENT: HIGH TEMPERATURE COAL TAR PITCH 

CAS NUMBER: 65996-93-2 

PERCENTAGE: 70-100 

COMPONENT: PETROLEUM PITCH 

CAS NUMBER: 68187-58-6 

PERCENTAGE: 0-30 

COMPONENT: BENZO(A)PYRENE 

CAS NUMBER: 50-32-8 

PERCENTAGE: 1.11-1.42 

COMPONENT: BENZO(G,H,I)PERYLENE 

CAS NUMBER: 191-24-2 

PERCENTAGE: 0.88-1.30 

COMPONENT: FLUORANTHENE 

CAS NUMBER: 206-44-0 

PERCENTAGE: 0.77-1.27 

COMPONENT: PYRENE 

CAS NUMBER: 129-00-0 

PERCENTAGE: 0.67-1.19 
COMPONENT: INDENO(1,2,3-CD)PYRENE 

CAS NUMBER: 193-39-5 

PERCENTAGE: 0.97-1.15 

COMPONENT: 1,2-BENZANTHRACENE 

CAS NUMBER: 56-55-3 

PERCENTAGE: 0.71-1.04 

COMPONENT: 1,2-BENZPHENANTHRENE 

CAS NUMBER: 218-01-9 

PERCENTAGE: 0.72-1.03 

COMPONENT: BENZO(B)FLUORANTHENE 

CAS NUMBER: 205-99-2 

PERCENTAGE: 0.72-0.92 

COMPONENT: DIBENZO(A,H)PYRENE 

CAS NUMBER: 189-64-0 

PERCENTAGE: 0.50-0.81 

COMPONENT: BENZO(J)FLUORANTHENE 

CAS NUMBER: 205-82-3 

PERCENTAGE: 0.51-0.66 

COMPONENT: BENZO(K)FLUORANTHENE 

CAS NUMBER: 207-08-9 

PERCENTAGE: 0.48-0.62 

COMPONENT: DIBENZO(A,E)PYRENE 

CAS NUMBER: 192-65-4 

PERCENTAGE: 0.26-0.50 

COMPONENT: DIBENZO(A,I)PYRENE 

CAS NUMBER: 189-55-9 

PERCENTAGE: 0.16-0.44 

COMPONENT: DIBENZ(A,H)ANTHRACENE 

CAS NUMBER: 53-70-3 

PERCENTAGE: 0.22-0.30 

COMPONENT: CARBAZOLE 

CAS NUMBER: 86-74-8 

PERCENTAGE: 0.02-0.10 

4. FIRST AID MEASURES 

INHALATION: If adverse effects occur, remove to uncontaminated area. Give artificial respiration if not 

breathing. If breathing is difficult, oxygen should be administered by qualified personnel. Get immediate 
medical attention. 

SKIN CONTACT: For thermal burns, cool affected areas as quickly as possible by drenching or immersing 

in water. Wash skin with soap and water for at least 15 minutes, or use a waterless handcleaner, while 

removing contaminated clothing and shoes. Get immediate medical attention, if needed. 

EYE CONTACT: Immediately flush eyes with plenty of water for at least 15 minutes. Then get immediate 

medical attention. 

INGESTION: DO NOT induce vomiting. If a large amount is swallowed, get medical attention. Do not give 

anything by mouth to unconscious or convulsive person. If vomiting occurs, keep head lower than hips to 

help prevent aspiration. 

5. FIRE FIGHTING MEASURES 

FIRE AND EXPLOSION HAZARDS: During fire conditions, vapors and decomposition products may be 

released, forming flammable/explosive mixtures in air. Containers may rupture or explode if exposed to heat. 

EXTINGUISHING MEDIA: regular dry chemical, carbon dioxide, regular foam, water spray 

FIRE FIGHTING: Avoid inhalation of material or combustion by-products. Stay upwind and keep out of 

low areas. Use extinguishing agents appropriate for surrounding fire. Flood with fine water spray. Directly 

spraying water or foam onto hot burning product may cause frothing. For fires in cargo or storage area: Cool 

containers with water from unmanned hose holder or monitor nozzles until well after fire is out. If this is 

impossible then take the following precautions: Keep unnecessary people away, isolate hazard area and deny 

entry. Withdraw immediately in case of rising sound from venting safety device or any discoloration of tanks 

due to fire. 

FIRE FIGHTING PROTECTIVE EQUIPMENT: Full fire fighting turn-out gear (bunker gear). 

SENSITIVITY TO MECHANICAL IMPACT: No 

SENSITIVITY TO STATIC DISCHARGE: Yes (dust) 

FLASH POINT: >374 F (>190 C) (PMCC) 

AUTOIGNITION: >750 F (>399 C) 

6. ACCIDENTAL RELEASE MEASURES 

WATER RELEASE:

Subject to California Safe Drinking Water and Toxic Enforcement Act of 1986 (Proposition 65). Keep out of 

water supplies and sewers. 

OCCUPATIONAL RELEASE:

Collect spilled material in appropriate container for disposal. Keep out of water supplies and sewers. Keep 

unnecessary people away, isolate hazard area and deny entry. In Canada, report releases to provincial 
authorities, municipal authorities, or both, as required. Due to the concentration of Benzo(a)pyrene and the 

CERCLA (40 CFR 302.4) reportable quantity of 1 pound, the release of 70 pounds of this product requires 

National Response Center notification. 

7. HANDLING AND STORAGE 

STORAGE: Store and handle in accordance with all current regulations and standards. Label all containers. 

Keep container in a well-ventilated place. Keep away from heat, sparks and flame. Protect from physical 

damage. Keep separated from incompatible substances. Notify State Emergency Response Commission for 

storage or use at amounts greater than or equal to the TPQ (U.S. EPA SARA Section 302). SARA Section 

303 requires facilities storing a material with a TPQ to participate in local emergency response planning 

(U.S. EPA 40 CFR 355.30). 

HANDLING: Avoid breathing vapors of heated materials. Avoid contact with eyes, skin and clothing. 

When using, do not eat, drink or smoke. Wash exposed areas thoroughly with soap and water, or a waterless 

handcleaner, after skin contact and before eating, drinking, using tobacco products, or restrooms. Use 

protective skin cream on exposed skin before and during work shift. To reduce sun sensitivity a sun-blocking 

lotion (SPF 15+) can also be applied prior to application of a protective cream. Contaminated clothing 

should be removed and laundered before reuse. 

8. EXPOSURE CONTROLS, PERSONAL PROTECTION 

EXPOSURE LIMITS:

HIGH-TEMP. COAL TAR PITCH:

COAL TAR PITCH VOLATILES:

0.2 mg/m3 OSHA TWA (benzene soluble fraction) 

0.2 mg/m3 ACGIH TWA (benzene soluble fraction) 

0.1 mg/m3 NIOSH recommended TWA 10 hour(s) (cyclohexane extractable fraction) 

PETROLEUM PITCH:

COAL TAR PITCH VOLATILES:

0.2 mg/m3 OSHA TWA (benzene soluble fraction) 

0.2 mg/m3 ACGIH TWA (benzene soluble fraction) 

0.1 mg/m3 NIOSH recommended TWA 10 hour(s) (cyclohexane extractable fraction) 

VENTILATION: Ensure adequate ventilation. Ensure compliance with applicable exposure limits. 

EYE PROTECTION: ANSI Z87.1-1989 approved safety glasses with side shields. Provide an emergency 

eye wash fountain and quick drench shower in the immediate work area. At elevated temperatures: A 

faceshield is recommended. 

CLOTHING: Wear protective clothing to prevent contact. Use protective skin cream on exposed skin 

before and during work shift. Contaminated clothing should be removed and laundered before reuse. When 

material is at an elevated temperature, wear appropriate heat resistant clothing. 

GLOVES: Wear appropriate gloves. When material is at an elevated temperature, wear appropriate heat 
resistant gloves. 

PROTECTIVE MATERIAL TYPES: protective skin creams, chemical resistant material, heat resistant 

material 

RESPIRATOR: If the applicable TLVs and/or PELs are exceeded, use canister or cartridge respirators, 

which are MSHA/NIOSH-approved, with organic vapor cartridges. 

9. PHYSICAL AND CHEMICAL PROPERTIES 

PHYSICAL STATE: solid 

COLOR: black 

PHYSICAL FORM: changes from solid to liquid as temperature increases 

ODOR: coal tar odor 

BOILING POINT: >464 F (>240 C) 

MELTING POINT: >70 F (>21 C) 

VAPOR PRESSURE: 0 mmHg @ 20 C 

VAPOR DENSITY (air=1): >1 

SPECIFIC GRAVITY (water=1): 1.26-1.34 @ 15.5 C 

WATER SOLUBILITY: almost insoluble 

PH: Not applicable 

VOLATILITY: Not applicable 

ODOR THRESHOLD: Not available 

EVAPORATION RATE: Not applicable 

COEFFICIENT OF WATER/OIL DISTRIBUTION: Not available 

10. STABILITY AND REACTIVITY 

REACTIVITY: Stable at normal temperatures and pressure. 

CONDITIONS TO AVOID: Avoid heat, flames, sparks and other sources of ignition. Avoid contact with 

incompatible materials. 

INCOMPATIBILITIES: oxidizing materials 

HAZARDOUS DECOMPOSITION:

Thermal decomposition products: carbon monoxide, carbon dioxide, oxides of nitrogen, sulfur compounds, 

polynuclear aromatic hydrocarbons 

POLYMERIZATION: Will not polymerize. 

11. TOXICOLOGICAL INFORMATION 

CARBON PITCH TYPE A:

CARCINOGEN STATUS: OSHA: No, NTP: Yes, IARC: Yes, (See below for additional information on 
component carcinogen status) 

TARGET ORGANS: respiratory system, skin, eyes, bladder, scrotum 

MEDICAL CONDITIONS AGGRAVATED BY EXPOSURE: respiratory disorders, skin disorders, eye 

disorders, central nervous system disorders (i.e. headache, drowsiness, dizziness, loss of coordination) 

ADDITIONAL DATA: This product contains coal tar pitch. Volume 35 of the IARC monograph states that 

there is sufficient evidence that coal tar pitches are carcinogenic in humans. IARC's conclusion is based upon 

studies suggesting an association between skin cancer and chronic occupational dermal exposure to coal tar 

pitches and upon other historical studies and anecdotal reports showing an association between dermal 

exposure to coal tar pitch and scrotal cancer in the absence of good hygiene practices. 

Epidemiological studies of aluminum reduction workers showed an excess risk of developing bladder cancer 

for workers with chronic inhalation overexposure to coal tar pitch volatiles in excess of the recommended 

permissible exposure level. Studies also suggest an association between lung cancer and chronic inhalation 

overexposure to coal tar pitch volatiles in excess of the recommended permissible exposure level. A recent 

animal study may suggest an association between lung cancer and pulmonary deposition of particulate matter 

originating from coal tar pitches. It is not anticipated, however, that use of this product in liquid form will 

create a respirable dust. 

In addition to containing information about the product as a whole, this data sheet also contains information 

about individual components of the product. Information of this nature may not have been derived from 

studies or data relating to this product and/or may have been derived from studies or data that did not involve 

human exposure and involved animal exposure only. 

HIGH-TEMP. COAL TAR PITCH:

CARCINOGEN STATUS: NTP: Known Human Carcinogen; IARC: Human Sufficient Evidence, Animal 

Sufficient Evidence, Group 1; ACGIH: A1 -Confirmed Human Carcinogen (Coal tar pitch volatiles) 

LOCAL EFFECTS:

Irritant: skin, eye 

MEDICAL CONDITIONS AGGRAVATED BY EXPOSURE: respiratory disorders, skin disorders, 

central nervous system disorders 

PETROLEUM PITCH:

MEDICAL CONDITIONS AGGRAVATED BY EXPOSURE: respiratory disorders, skin disorders, eye 

disorders 

POLYCYCLIC AROMATIC HYDROCARBONS:

ADDITIONAL DATA: Some polycyclic aromatic hydrocarbons (PAHs), found in coal tar complex 

substances, have been reported to cause lung and skin cancer in humans under conditions of poor personal 

hygiene, prolonged/repeated contact, and exposure to sunlight. The National Toxicology Program (NTP) and 

IARC have independently classified various PAH compounds present in coal tar substances as reasonably 

anticipated to be human carcinogens (NTP), probably carcinogenic to humans (IARC Group 2A), possibly 

carcinogenic to humans (IARC Group 2B), and not classifiable as to carcinogenicity to humans (IARC 

Group 3). The cancers reported in the studies upon which IARC based its conclusions involved lung, skin, 

liver, stomach, kidney and blood cancers in animals. Based on the results of animal experiments PAHs may 

cause injury to the liver, kidneys, lungs, blood and lymph systems. Some PAH's have also been associated 

with impaired fertility, heritable genetic damage and birth defects in mice. 
12. ECOLOGICAL INFORMATION 

Not available 

13. DISPOSAL CONSIDERATIONS 

Dispose in accordance with all applicable regulations. 

14. TRANSPORT INFORMATION 

U.S. DOT 49 CFR 172.101:

PROPER SHIPPING NAME: Other regulated substances, solid, n.o.s. RQ 

ID NUMBER: NA3077 

HAZARD CLASS OR DIVISION: 9 

PACKING GROUP: III 

LABELING REQUIREMENTS: 9 

DOT HAZARDOUS SUBSTANCE(S):

Benzo(a)pyrene 1 lb(s) (0.454 kg(s)) 

Fluoranthene 100 lb(s) (45.4 kg(s)) 

Indeno(1,2,3-cd)pyrene 100 lb(s) (45.4 kg(s)) 

1,2-Benzanthracene 10 lb(s) (4.54 kg(s)) 

1,2-Benzphenanthrene 100 lb(s) (45.4 kg(s)) 

Benzo(b)fluoranthene 1 lb(s) (0.454 kg(s)) 

OTHER INFORMATION: This material contains reportable quantity (RQ) Hazardous Substances. 

Applicable shipping classification depends on temperature of product. Product in Tank Car or Tank Truck is 

shipped as 'Elevated temperature liquid, n.o.s.' 'Other regulated substances, solid, n.o.s.' applies for all 

container sizes. 

U.S. DOT 49 CFR 172.101:

PROPER SHIPPING NAME: Elevated temperature liquid, n.o.s. RQ 

ID NUMBER: UN3257 

HAZARD CLASS OR DIVISION: 9 

PACKING GROUP: III 

LABELING REQUIREMENTS: 9 

DOT HAZARDOUS SUBSTANCE(S):

Benzo(a)pyrene 1 lb(s) (0.454 kg(s)) 

Fluoranthene 100 lb(s) (45.4 kg(s)) 

Indeno(1,2,3-cd)pyrene 100 lb(s) (45.4 kg(s)) 

1,2-Benzanthracene 10 lb(s) (4.54 kg(s)) 

1,2-Benzphenanthrene 100 lb(s) (45.4 kg(s)) 

Benzo(b)fluoranthene 1 lb(s) (0.454 kg(s)) 

OTHER INFORMATION: This material contains reportable quantity (RQ) Hazardous Substances. 

Applicable shipping classification depends on temperature of product. Product in Tank Car or Tank Truck is 

shipped as 'Elevated temperature liquid, n.o.s.' 'Other regulated substances, solid, n.o.s.' applies for all 

container sizes. 
CANADIAN TRANSPORTATION OF DANGEROUS GOODS:

SHIPPING NAME: Elevated temperature liquid, n.o.s. 

UN NUMBER: UN3257 

CLASS: 9 

PACKING GROUP/RISK GROUP: III 

OTHER INFORMATION: Applicable shipping classification depends on temperature of product. No 

classification is assigned when material is not at an elevated temperature. 

15. REGULATORY INFORMATION 

U.S. REGULATIONS:

SARA TITLE III SECTION 302 EXTREMELY HAZARDOUS SUBSTANCES (40 CFR 355.30): 

PYRENE: 1000/10000 LBS TPQ 

SARA TITLE III SECTION 304 EXTREMELY HAZARDOUS SUBSTANCES (40 CFR 355.40): 

PYRENE: 5000 LBS RQ 

SARA TITLE III SARA SECTIONS 311/312 HAZARDOUS CATEGORIES (40 CFR 370.21): 

ACUTE: Yes 

CHRONIC: Yes 

FIRE: No 

REACTIVE: No 

SUDDEN RELEASE: No 

SARA TITLE III SECTION 313 (40 CFR 372.65): 

Benzo(a)pyrene

BENZO(G,H,I)PERYLENE

FLUORANTHENE

Indeno (1,2,3-cd)pyrene

1,2-Benzanthracene

1,2-Benzphenanthrene (Chrysene)

BENZO(B)FLUORANTHENE

Dibenzo(a,h)pyrene

BENZO(J)FLUORANTHENE

BENZO(K)FLUORANTHENE

Dibenzo(a,e)pyrene

Dibenzo(a,i)pyrene

Dibenz(a,h)anthracene

STATE REGULATIONS:

California Proposition 65: 

Known to the state of California to cause the following: 

Soots, tars, and mineral oils (untreated and mildly treated oils and used engine oils)

Cancer (Feb 27, 1987) 

Benzo(a)pyrene

Cancer (Jul 01, 1987) 

Indeno (1,2,3-cd)pyrene
Cancer (Jan 01, 1988) 

1,2-Benzanthracene

Cancer (Jul 01, 1987) 

1,2-Benzphenanthrene (Chrysene)

Cancer (Jan 01, 1990) 

BENZO(B)FLUORANTHENE

Cancer (Jul 01, 1987) 

Dibenzo(a,h)pyrene

Cancer (Jan 01, 1988) 

BENZO(J)FLUORANTHENE

Cancer (Jul 01, 1987) 

BENZO(K)FLUORANTHENE

Cancer (Jul 01, 1987) 

Dibenzo(a,e)pyrene

Cancer (Jan 01, 1988) 

Dibenzo(a,i)pyrene

Cancer (Jan 01, 1988) 

Dibenz(a,h)anthracene

Cancer (Jan 01, 1988) 

Carbazole

Cancer (May 01, 1996) 

CANADIAN REGULATIONS:

WHMIS CLASSIFICATION: D2A. 

NATIONAL INVENTORY STATUS:

U.S. INVENTORY (TSCA): Listed on inventory. 

TSCA 12(b) EXPORT NOTIFICATION: Not listed. 

CANADA INVENTORY (DSL/NDSL): All components of this product are listed on either the DSL or the 

NDSL. 

16. OTHER INFORMATION 

MSDS SUMMARY OF CHANGES

2. HAZARDS IDENTIFICATION 

3. COMPOSITION, INFORMATION ON INGREDIENTS 

11. TOXICOLOGICAL INFORMATION 

©Copyright 1984-2007 MDL Information Systems, Inc. All rights reserved.

The information set forth in this Material Safety Data Sheet does not purport to be all-inclusive and 

should be used only as a guide. While the information and recommendations set forth herein are 

believed to be accurate, the company makes no warranty regarding such information and 

recommendations and disclaims all liability from reliance thereon. 
Attachment #5

   
STARTUP, SHUTDOWN, MALFUNCTION PLAN 

Prepared for 

CENTURY ALUMINUM OF KENTUCKY LLC 

HAWESVILLE, KENTUCKY 

April 1999 

(Revised July 2001) 
STARTUP, SHUTDOWN, MALFUNCTION PLAN 

Prepared for 

CENTURY ALUMINUM OF KENTUCKY LLC 

HAWESVILLE, KENTUCKY 

April 1999 

(Revised July 2001) 

Prepared by 

URS Corporation 

235 Peachtree Street NE 

North Tower, Suite 2000 

Atlanta, Georgia 30303 
Century Aluminum of Kentucky LLC - Hawesville, Kentucky iii 

Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001)

CONTENTS 

I. PURPOSE OF THE PLAN ...........................................................................1 

II. STANDARD OPERATING PROCEDURES ................................................2 

 A. Potlines One Through Four ................................................................3 

 1.0 Purpose ....................................................................................3 

 2.0 Process Description .................................................................3 

 3.0 Procedures ...............................................................................5 

 a. Startup/Shutdown Practices ...........................................5 

 b. Malfunction Practices .....................................................8 

 B. Potline Five ...................................................................................... 11 

 1.0 Purpose ................................................................................. 11 

 2.0 Process Description .............................................................. 11 

 3.0 Procedures ............................................................................ 12 

 a. Startup/Shutdown Practices ........................................ 12 

 b. Malfunction Practices .................................................. 14 

 C. Carbon Bake Ovens ........................................................................ 17 

 1.0 Purpose ................................................................................. 17 

 2.0 Process Description .............................................................. 17 

 3.0 Procedures ............................................................................ 18 

 a. Startup/Shutdown Practices ........................................ 18 

 b. Malfunction Practices .................................................. 21 

 D. Green Mill/Anode Former ................................................................ 23 

 1.0 Purpose ................................................................................. 23 

 2.0 Process Description .............................................................. 23 

 3.0 Procedures ............................................................................ 24 

 a. Startup/Shutdown Practices ........................................ 24 

 b. Malfunction Practices .................................................. 27 

III. CORRECTIVE ACTION PRACTICES/PROCEDURES ............................ 29 

 A. Potlines One Through Four ............................................................. 30 

 1.0 Purpose ................................................................................. 30 

 2.0 Practices and Procedures ..................................................... 30 

 a. Startup/Shutdown ........................................................ 30 

 b. Malfunctions ................................................................ 31 

 B. Potline Five ...................................................................................... 34 

 1.0 Purpose ................................................................................. 34 

 2.0 Practices and Procedures ..................................................... 34 

 a. Startup and Shutdown ................................................. 34 

 b. Malfunctions ................................................................ 35 
Century Aluminum of Kentucky LLC - Hawesville, Kentucky iv 

Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001)

C. Carbon Bake Ovens ........................................................................ 38 

 1.0 Purpose ................................................................................. 38 

 2.0 Practices and Procedures ..................................................... 38 

 a. Startup and Shutdown ................................................. 38 

 b. Malfunctions ................................................................ 39 

D. Green Mill/Anode Former ................................................................ 42 

 1.0 Purpose ................................................................................. 42 

 2.0 Practices and Procedures ..................................................... 42 

 a. Startup and Shutdown ................................................. 42 

 b. Malfunctions ................................................................ 44 

IV. RECORD KEEPING .................................................................................. 47 

 1.0 Purpose ........................................................................................... 47 

 2.0 Record Keeping Requirements ....................................................... 47 

V. REPORTING REQUIREMENTS ............................................................... 48

 1.0 Purpose ........................................................................................... 49 

 2.0 Reporting Requirements ................................................................. 49 

APPENDICES 

Appendix A Malfunction Report Form 

Appendix B Malfunction Reporting Call Roster 

Appendix C Site Plan 
Century Aluminum of Kentucky LLC - Hawesville, Kentucky 1 

Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001)

I. PURPOSE OFTHE PLAN 

On October 7, 1997 the United States Environmental Protection Agency (EPA) 

promulgated the National Emissions Standards for Hazardous Air Pollutants (NESHAP) for 

Primary Aluminum Reduction Plants (40 CFR Part 63 subpart LL). A specific provision of the 

rule (40 CFR Part 63.850(c)) requires a covered source to develop and implement a Startup, 

Shutdown and Malfunction Plan for processes covered by the rule. 

Century Aluminum of Kentucky LLC (Century), notified the Kentucky Division of Air 

Quality and USEPA Region IV on November 11, 1997 that some of the facility processes were 

subject to the provisions of the rule. As a result, Century is required to develop and implement a 

Startup, Shutdown and Malfunction Plan for the covered processes. The plan must be in place 

no later than October 8, 1999 for the existing sources and immediately upon startup for potline 

five and the new carbon bake oven. 

The following plan has been designed to satisfy the requirements found in 40 CFR Part 

63.850(c) as well as those found in 40 CFR Part 63.6(e), 40 CFR Part 63.10(b), 40 CFR Part 

63.847(h) and 40 CFR part 63.848 (f)(5)(ii). The plan is designed to incorporate all of the 

affected sources both existing and new into a single comprehensive document. 

This plan does not circumvent any existing requirements related to state or local 

regulations or permits. Those requirements should be reviewed and if necessary included as part 

of the reporting and record keeping provisions of this plan. 
Century Aluminum of Kentucky LLC - Hawesville, Kentucky 2 

Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001)

II. STANDARD OPERATING PROCEDURES 

 This portion of the plan is divided into four individual sections with three subsections per 

section. Each section covers the standard procedures for startup, shutdown and potential 

malfunctions of the affected sources; 

 The individual procedures cover the process as well as any related pollution control 

equipment. One should be aware that with the exception of the green mill/anode former, startup 

and shutdown occurs on a scheduled basis and is based on long term production requirements. 

The time between startup and shutdown typically exceeds twenty-four hours and could be as 

long as several weeks or in the case of the potlines, several years. The green mill/anode former 

operates on a more traditional shift or hourly basis. 

 Activities which occur on a routine basis can result in processes going through the 

standard startup/shutdown procedure several times over a given period of time. 
Century Aluminum of Kentucky LLC - Hawesville, Kentucky 3 

Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001)

A. Potlines One Through Four 

1.0 Purpose 

The purpose of this procedure is to establish the steps necessary for the startup and 

shutdown of aluminum reduction pots. For the purpose of this document, the startup and 

shutdown procedures detailed in this section will represent the procedure for all of the pots in 

lines one through four. Line five will be addressed separately. 

2.0 Process Description 

Century is a primary aluminum reduction facility (SIC 3334) which produces aluminum 

from the electrolytic reduction of alumina (aluminum oxide) to molten aluminum. Alumina is 

produced off-site at a refinery and is shipped to the Century facility by way of river barge or 

railroad. 

Alumina is reduced to aluminum in a rectangular cell called a pot. These pots are 

arranged together in a series to form a potline. Potlines are housed in long buildings called 

potrooms. Century operates five potlines of which four were built in 1969 and the fifth built in 

1998-1999 and commenced operation in April of 1999. 

 Each potline is constructed to facilitate the electrolytic reduction of alumina to aluminum. 

Figure One shows a cross section of a typical center worked prebake cell similar to those in use 

at Century. Potlines at Century consist of 112 pots per line with a total rated capacity of 278,000 

tons (lines one through five) of aluminum per year. 

Aluminum is produced by the electrolysis of alumina dissolved in a molten cyrolite 

(sodium aluminum fluoride) based electrolyte. In this process, electrical current is used to 

reduce the alumina into aluminum and oxygen. Electrical current is transferred through a 

sacrificial carbon anode to the molten bath. The pot is lined with carbon cathode material which 

completes the electrical circuit. 

The process is continuous in nature with molten aluminum tapped (removed) from the 

pot on a scheduled basis. The pot is recharged with alumina and cyrolite to make up for the 

material consumed in the process. 

Emissions from this operation are controlled prior to release to the atmosphere. All of the 

pots are hooded in order to contain the emissions and allow for the effective capture of generated 

exhaust gases. These gases are exhausted through ductwork to a pollution control system that 

consists of mechanical multiclone collectors, electrostatic precipitators and wet scrubbers. There 

are some fugitive emissions that escape the capture system due to ill fitting hood shields or when
Century Aluminum of Kentucky LLC - Hawesville, Kentucky 4 

Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001)

Prebake Cell 

(Figure 1.0) 

Air cylinder 

Steel shell 

Crust breaker

Insulation

Molten 

Aluminum

Molten 

electrolyte
Century Aluminum of Kentucky LLC - Hawesville, Kentucky 5 

Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001)

the hood shields are removed to tend the pot. These emissions are uncontrolled and exhaust 

through the potline roof monitors. 

3.0 Procedures 

a. Startup/Shutdown Practices 

1.0 Aluminum Reduction Pots 

 Reduction of alumina to aluminum is a continuous process. Typically, a pot has a service 

life of five to eight years in length. As a result, startup and shutdown is limited to individual pots 

and is not typically a daily occurrence, but is scheduled around the projected life of the pot. 

 The following is the typical startup procedure for an individual pot and reflects 

conditions used for all pots in a designated line. 

a. Startup 

• Once a pot has been placed back into the line, anodes are placed in the superstructure and 

the electrical isolation devices removed. The shielded pot is then energized and allowed 

to bake in or cure for a period of a least twenty-four hours. 

• Between twenty-four and thirty hours after the pot is started, three pot shields are 

removed from the hood and the back wall of the pot is loaded with dry electrolyte and the 

shields replaced. 

• Between thirty and thirty-six hours, three pot shields are removed and an anode pulled 

from the bath. Two crucibles of molten bath are introduced into the pot through the hole 

left by the anode. 

• Approximately eight to twelve hours after the molten bath is introduced into the pot, the 

hood shields at the corners of the pot are removed two at a time in order to skim material 

from around the corner anodes. 

• Approximately thirty-six hours after the molten bath is added, three shields are removed 

and an anode removed. At this time, one crucible of molten metal is added to the pot 

through the hole left by the anode. For the next seventy-two hours, two hood shields are 

removed every four hours to add scrap metal to the open anode hole. Once this cycle is 

complete, the anode is reset. 
Century Aluminum of Kentucky LLC - Hawesville, Kentucky 6 

Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001)

• At approximately the same time as the completion of the scrap metal addition, all hood 

shields are removed and alumina is added to the pot around the anodes and along the 

back wall. The hood shields are replaced when this activity is completed. 

• Once this activity is complete, the normal pot cycle commences and the pot is put on a 

regularly scheduled production cycle. 

b. Shutdown 

 Pots designated for shutdown due to the end of their operational life or a need for cold 

repair are shutdown in the following manner. 

• Once a pot is scheduled for shutdown, all possible metal is removed from the pot. Once 

all of the molten metal is removed, the pot is electrically isolated and the cooling cycle 

commences. 

• At the onset of the cooling cycle, all anodes are pulled from the pot and the hood shields 

removed. At this time, the end walls are knocked down into the pot (if the pot is being 

removed from service). The pot then cools unshielded for a period of twenty-fours hours. 

• After cooling, the pot superstructure is lifted off and the shell physically removed from 

the line. 

• Pots designated for cold repair are repaired in place and not removed from the line. These 

pots are allowed to cool for forty-eight hours. At that time, all material is removed from 

the pot in order to facilitate repair. 

Once pots are repaired or reworked, they are placed back into service utilizing the 

procedures found in Section a. 

2.0 Emission Control Equipment 

Regulated emissions from potlines one through four are controlled by a series of 

pollution control devices. Exhaust gases from the individual pots are captured by the pot hoods 

and ducted to multiclone collectors which act as the initial particulate removal devices. Exhaust 

gases then exit the multiclones and are transported through ductwork to electrostatic 

precipitators. These units remove additional particulate prior to the introduction of the exhaust 

gases to the induced draft fans. After the fans, the exhaust gas passes through wet scrubbers 

which remove the gaseous fluoride from the exhaust gas. Treated gas is then exhausted to the 

atmosphere through a 400-foot concrete stack. 
Century Aluminum of Kentucky LLC - Hawesville, Kentucky 7 

Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001)

 a. Startup 

 The emission control devices are started up in the following manner. 

• Prior to startup, all dampers within the system opened and the fans energized. 

• At the start of the fans, the multiclones immediately become operational. The 

electrostatic precipitators are brought up to temperature and the fields energized. The wet 

scrubbers are also brought up to temperature and the scrubbing liquor introduced to the 

scrubbers. 

• After operating for a period of one to two hours, operating parameters such as voltage on 

the electrostatic precipitators and liquor feed rate to the wet scrubbers are adjusted to 

optimize performance. 

This same startup procedure is utilized to bring individual units on-line after outages for 

maintenance and repairs. Since the production process is continuous, it is rare that all of the fans 

or the control devices are shutdown at the same time. 

b. Shutdown 

Shutdown typically occurs for individual units so the following is the sequence for 

shutdown of individual units. 

• For the multiclone units, the inlet and outlet dampers of the selected unit are closed in 

order to isolate the unit. 

• For the electrostatic precipitators, the inlet and outlet dampers are closed. Once the unit 

has been isolated, the fields are de-energized and the units rapped to remove dust from 

the collector plates. Access doors are then partially opened to allow the unit to cool prior 

to maintenance. 

• For the wet scrubbers, the inlet and outlet of the unit are blanked off. Once the unit is 

isolated, the liquor feed is turned off and the vessel drained of all possible liquid. Access 

doors are then opened and the unit is allowed to cool prior to maintenance. 

• For the induced draft fans, the inlet and outlet dampers are closed and the fan deenergized. Once the unit is isolated, the housing is opened or removed for maintenance if 

necessary. 
Century Aluminum of Kentucky LLC - Hawesville, Kentucky 8 

Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001)

In all cases facility procedures for confined space entry and lock-out/tag-out are followed 

prior to entry to the interior of any of the pollution control devices. 

 b. Malfunction Practices 

1.0 Aluminum Reduction Pots 

Malfunctions of a aluminum-reduction pot can take place for a multitude of reasons. 

Some of these malfunctions can cause greater than normal emissions from the pots. For the 

purpose of this document, only those malfunctions that have the potential to cause increased 

emissions will be addressed. 

a. Pot Malfunctions 

Malfunctions can occur for various reasons. Listed below are the common malfunctions 

that could occur and generate excess emissions. 

• Sick Pot - During this condition, the pot is not operating correctly due to some chemical 

or electrical imbalance. This condition could result in uneven heating of the pot, cold 

spots, or improper breakdown of the materials in the pot. Causes of the condition could 

be electrical problems, over feed or underfeed of raw materials, improper ratio of raw 

materials, anode problems or pot construction problems. 

• Anode failure - During this condition, anodes may crack or fail to the point that they can 

no longer act as the mechanism to transmit power to the pot. At this point, cold spots 

could develop or in some cases the anode could fall into the crust or molten metal causing 

mixing and heating problems within the pot. 

• Anode Effect — This is an electrical condition that causes the voltage of the pot to rise 

due to resistance between the anode and the molten bath. At this time, there is uneven 

heating and improper chemical reaction which could cause the generation of excess 

emissions. 

• Power Outage — When power fails to the pot or potline, the electrolytic reaction ceases 

to occur and the pot loses its source of heat. This condition could cause various problems 

and could result in a frozen pot if the power outage continues. Emissions typically 

increase at this time due to changing conditions within the pot. 

• Crane Failure — The pots are tended by overhead cranes. When the crane fails and 

cannot be operated there is the possibility that the pots cannot be properly tended. This 
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Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001)

could result in excessive emissions due to the inability to change anodes, feed materials 

or tap metal from the pot. 

• Compressor Failure — This condition could result in similar problems as in a failure of a 

crane. Most of the functions performed on the pot involve the use of compressed air and 

failure of the compressor could lead to the inability to properly tend the pot. 

• Shield Failure — Damaged or failed hood shields lead to improper hooding of the pot 

which could cause fugitive emissions from the pot. Hood shields in disrepair will limit 

the draft on the pot and allow cold spots to develop as well as increasing emissions from 

the potline roof monitors. 

The aforementioned causes are those that are considered malfunctions. Other conditions 

may be deemed a malfunction at the time they occur but are typically limited in frequency and 

duration. The conditions mentioned above have the highest potential for causing excessive or 

greater than normal emissions. 

2.0 Emission Control Equipment 

Malfunctions can occur due to various reasons. Due to the arrangement of the emissions 

controls on potlines one through four, each type of control device shall be addressed separately. 

For the purpose of this section, a malfunction is defined as an event that effects the performance 

of the control device. 

• Multiclones — malfunctions of multiclones are limited to the following conditions. 

- Failure of individual cyclones or multiple cyclones due to plugging or mechanical 

failure 

- Plugging of the inlet transition 

- Mechanical failure of the ductwork or dampers leading to and from each unit 

• Electrostatic Precipitators — malfunctions of the electrostatic precipitators are limited to 

the following conditions. 

- Failure of the electrical controls, electrodes, insulators, transformers or any other 

electrically-related pieces of equipment 

- Failure of the collector plate cleaning mechanisms 

- Failure of the inlet and outlet dampers that control exhaust gas flow to the unit 

- Plugging of the dust transport system to the point that it impacts the operation of 

the unit 

- Mechanical failure of the collector or discharge plates 
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• Wet Scrubbers — malfunctions of the wet scrubbers are limited to the following 

conditions 

- Failure of the liquor feed pumps 

- Failure of the spray nozzles or manifold 

- Failure of the dampers controlling the gas flow to the individual units 

- Plugging of drain lines and or failure of pumps for removing collected liquor from 

the vessel 

• Induced Draft Fans — malfunctions of the system fans are limited to the following 

conditions. 

- Electrical failure related to associated electrical equipment. 

- Mechanical failure of components 

- Failure of inlet and outlet dampers controlling the exhaust gas flow through the 

individual units. 
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Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001)

B. Potline Five 

 1.0 Purpose 

 The purpose of this procedure is to establish the steps necessary for the startup and 

shutdown of aluminum reduction pots. For the purpose of this document, the startup and 

shutdown procedures detailed in this section will represent the procedure for all of the pots in 

line five. 

2.0 Process Description 

 Century is a primary aluminum reduction facility (SIC 3334) which produces aluminum 

from the electrolytic reduction of alumina (aluminum oxide) to molten aluminum. Alumina is 

produced off-site at a refinery and is shipped to the Century facility by way of river barge or 

railroad. 

 Alumina is reduced to aluminum in a rectangular cell called a pot. These pots are 

arranged together in a series to form a potline. Potlines are housed in long buildings called 

potrooms. Century operates five potlines of which four were built in 1969 and the fifth built in 

1998-1999 and commenced operation in April of 1999. 

 Each potline is constructed to facilitate the electrolytic reduction of alumina to 

aluminum. Figure One shows a cross section of a typical center worked prebake cell similar to 

those in use at Century. Potlines at Century consist of 112 pots per line with a total rated capacity 

of 278,000 tons (lines one through five) of aluminum per year. 

 Aluminum is produced by the electrolysis of alumina dissolved in a molten cryolite 

(sodium aluminum fluoride) based electrolyte. In this process, electrical current is used to 

reduce the alumina into aluminum and oxygen. Electrical current is transferred through a 

sacrificial carbon anode to the molten bath. The pot is lined with carbon cathode material which 

completes the electrical circuit. 

 The process is continuous in nature with molten aluminum tapped (removed) from the 

pot on a scheduled basis. The pot is recharged with alumina and cryolite to make up for the 

material consumed in the process. 

 Emissions from this operation are controlled prior to release to the atmosphere. All of 

the pots are hooded in order to contain the emissions and allow for the effective capture of 

generated exhaust gases. These gases are exhausted through ductwork to a pollution control 

system that consists of a dry scrubber (alumina injected fabric filter). There are some fugitive 
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Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001)

emissions that escape the capture system due to ill fitting hood shields or when the hood shields 

are removed to tend the pot. These emissions are uncontrolled and exhaust through the potline 

roof monitors. 

 3.0 Procedures 

 a. Startup/Shutdown Practices 

 1.0 Aluminum Reduction Pots 

 Reduction of alumina to aluminum is a continuous process. Typically, a pot has a service 

life of five to eight years in length. As a result, startup and shutdown is limited to individual pots 

and is not typically a daily occurrence but is scheduled around the projected life of the pot. 

 The following is the typical startup procedure for an individual pot and reflects conditions 

used for all pots in a designated line. 

 a. Startup 

• Once a pot has been placed back into the line, anodes are placed in the superstructure and 

the electrical isolation devices removed. The shielded pot is then energized and allowed 

to bake in or cure for a period of a least twenty-four hours. 

• Between twenty-four and thirty hours after the pot is started, three pot shields are 

removed from the hood and the back wall of the pot is loaded with dry electrolyte and the 

shields replaced. 

• Between thirty and thirty-six hours, three pot shields are removed and an anode pulled 

from the bath. Two crucibles of molten bath are introduced into the pot through the hole 

left by the anode. 

• Approximately eight to twelve hours after the molten bath is introduced into the pot, the 

hood shields at the corners of the pot are removed two at a time in order to skim material 

from around the corner anodes. 

• Approximately thirty-six hours after the molten bath is added, three shields are removed 

and an anode removed. At this time, one crucible of molten metal is added to the pot 

through the hole left by the anode. For the next seventy-two hours, two hood shields are 

removed every four hours to add scrap metal to the open anode hole. Once this cycle is 

complete, the anode is reset. 
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Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001)

• At approximately the same time as the completion of the scrap metal addition, all hood 

shields are removed and alumina is added to the pot around the anodes and along the 

back wall. The hood shields are replaced when this activity is completed. 

• Once this activity is complete, the normal pot cycle commences and the pot is put on a 

regularly scheduled production cycle. 

 b. Shutdown 

 Pots designated for shutdown due to the end of their operational life or a need for cold 

repair are shutdown in the following manner. 

• Once a pot is scheduled for shutdown, all possible metal is removed from the pot. Once 

all of the molten metal is removed, the pot is electrically isolated and the cooling cycle 

commences. 

• At the onset of the cooling cycle, all anodes are pulled from the pot and the hood shields 

removed. At this time, the end walls are knocked down into the pot (if the pot is being 

removed from service). The pot then cools unshielded for a period of twenty-fours hours. 

• After cooling, the pot superstructure is lifted off and the shell physically removed from 

the line. 

• Pots designated for cold repair are repaired in place and not removed from the line. 

These pots are allowed to cool for forty-eight hours. At that time, all material is removed 

from the pot in order to facilitate repair. 

 Once pots are repaired or reworked, they are placed back into service utilizing the 

procedures found in Section a. 

 2.0 Emission Control Equipment 

 Regulated emissions from potline five are controlled by an alumina injected dry scrubber. 

Exhaust gases from the individual pots are captured by the pot hoods and ducted to dry scrubber 

which acts to remove particulate and gaseous fluoride. Exhaust gases then exit to the induced 

draft fans. Treated gas is then exhausted to the atmosphere through a 200-foot steel stack. 

 a. Startup 

 The emission control devices are started up in the following manner. 

• Prior to startup, all dampers within the system opened and the fans energized. 
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Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001)

• At the start of the fans, alumina is introduced to the duct ahead of the dry scrubber. 

• After operating for a period of one to two hours, operating parameters such as the recycle 

rate and bag cleaning cycle are adjusted to optimize performance. 

 This same startup procedure is utilized to bring individual units on-line after outages for 

maintenance and repairs. Since-the production process is continuous, it is rare that all of the 

control devices is shutdown. However individual modules are taken off-line for maintenance 

and are restarted in the same manner. 

 b. Shutdown 

 Shutdown typically occurs for individual modules of the dry scrubber so the following is 

the sequence for shutdown of individual units. 

• For the fabric filter units, the inlet and outlet dampers of the selected unit are closed in 

order to isolate the unit and gas directed to the other unit. 

• For the induced draft fans, the inlet and outlet dampers are closed and the fan deenergized. Once the unit is isolated, the housing is opened or removed for maintenance if 

necessary. 

 In all cases facility procedures for confined space entry and lock-out/tag-out are followed 

prior to entry to the interior of any of the pollution control devices. 

 b. Malfunction Practices 

 1.0 Aluminum Reduction Pots 

 Malfunctions of a aluminum reduction pot can take place for a multitude of reasons. 

Some of these malfunctions can cause greater than normal emissions from the pots. For the 

purpose of this document, only those malfunctions that have the potential to cause increased 

emissions will be addressed. 

a. Pot Malfunctions 

 Malfunctions can occur for various reasons. Listed below are the common malfunctions 

that could occur and generate excess emissions. 

• Sick Pot- During this condition, the pot is not operating correctly due to some chemical 

or electrical imbalance. This condition could result in uneven heating of the pot, cold 

spots, or improper breakdown of the materials in the pot. Causes of the condition could 
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Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001)

be electrical problems, over feed or underfeed of raw materials, improper ratio of raw 

materials, anode problems or pot construction problems. 

• Anode failure — During this condition, anodes may crack or fail to the point that they 

can no longer act as the mechanism to transmit power to the pot. At this point, cold spots 

could develop or in some cases the anode could fall into the crust or molten metal causing 

mixing and heating problems within the pot. 

• Anode Effect — This is an electrical condition that causes the voltage of the pot to rise 

due to resistance between the anode and the molten bath. At this time, there is uneven 

heating and improper chemical reaction which could cause the generation of excess 

emissions. 

• Power Outage — When power fails to the pot or potline, the electrolytic reaction ceases 

to occur and the pot loses its source of heat. This condition could cause various problems 

and could result in a frozen pot if the power outage continues. Emissions typically 

increase at this time due to changing conditions within the pot. 

• Crane Failure — The pots are tended by overhead cranes. When the crane fails and 

cannot be operated there is the possibility that the pots cannot be properly tended. This 

could result in excessive emissions due to the inability to change anodes, feed materials 

or tap metal from the pot. 

• Compressor Failure — This condition could result in similar problems as in a failure of a 

crane. Most of the functions performed on the pot involve the use of compressed air and 

failure of the compressor could lead to the inability to properly tend the pot. 

• Shield Failure — Damaged or failed hood shields lead to improper hooding of the pot 

which could cause fugitive emissions from the pot. Hood shields in disrepair will limit 

the draft on the pot and allow cold spots to develop as well as increasing emissions from 

the potline roof monitors. 

The aforementioned causes are those that are considered malfunctions. Other conditions 

may be deemed a malfunction at the time they occur but are typically limited in frequency and 

duration. The conditions mentioned above have the highest potential for causing excessive or 

greater than normal emissions. 

 2.0 Emission Control Equipment 

Malfunctions can occur due to various reasons. Due to the arrangement of the emissions 

controls on potline five, each type of control device shall be addressed separately. For the 

purpose of this section, a malfunction is defined as an event that effects the performance of the 

control device. 
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Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001)

 a. Emission Control Equipment Malfunctions 

• Alumina Feed System - malfunctions of the alumina feed system are limited to the 

following conditions. 

- Plugging of the alumina transport system. 

- Plugging of alumina feeder. 

- Mechanical failure of the feeder. 

- Mechanical failure of the transport system. 

• Fabric Filter - malfunctions of the Fabric Filter are limited to the following conditions. 

- Bag failure. 

- Bag cleaning mechanism failure. 

- Dust collection and covering system failure. 

• Induced Draft Fans — malfunctions of the system fans are limited to the following 

conditions. 

- Electrical failure related to associated electrical equipment. 

- Mechanical failure of components 

- Failure of inlet and outlet dampers controlling the exhaust gas flow through the 

individual units. 
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Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001)

C. Carbon Bake Ovens 

 1.0 Purpose 

 The purpose of this procedure is to establish the steps necessary for the startup and 

shutdown of the bake ovens that cure the carbon anodes used in the aluminum reduction pots. 

This procedure will be used to address all three ovens and their individual sections and the 

common control device. 

 2.0 Process Description 

 Century is a primary aluminum reduction facility (SIC 3334) which produces aluminum 

from the electrolytic reduction of alumina (aluminum oxide) to molten aluminum. Alumina is 

produced off-site at a refinery and is shipped to Century by way of river barge or railroad. 

 Alumina is reduced to aluminum in a rectangular cell called a pot. These pots are 

arranged together in a series to form a potline. Potlines are housed in long buildings called 

potrooms. Century operates five potlines of which four were built in 1969 and the fifth built in 

1998-1999 which commenced operation in April of 1999. 

 Aluminum is produced by the electrolysis of alumina dissolved in a molten cyrolite 

(sodium aluminum fluoride) based electrolyte. In this process, electrical current is used to 

reduce the alumina to aluminum and oxygen. Electrical current is transferred through a 

sacrificial carbon anode to the molten bath. The pot is lined with a carbon cathode material 

which completes the electrical circuit. 

 Carbon anodes used in the reduction pots are formed in a separate process located onsite. 

Anodes are formed in the green carbon area of the plant and then transported to the carbon bake 

ovens for curing. Anodes are baked in the ovens at about 2100 degrees F for an extended period 

of time in order to achieve optimum properties. 

 At Century, there are three individual ovens. Theses ovens are ring fired open top ovens 

consisting of individual sections of pits or cells. The cells are filled with green anodes, air 

spaces or voids are filled with packing coke and the top is sealed with insulating material. Each 

section is then placed under fire by way of a movable manifold consisting of natural gas burners 

and blowers. The baking process can last from 28 to 40 hours depending on the properties of the 

green anode. After the baking cycle, anodes are cooled and then removed from the cells and 

stored prior to use in the pots. 

Emissions from the process are controlled by an alumina injected dry scrubber prior to 

release to the atmosphere. 
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Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001)

3.0 Procedures 

a. Startup/Shutdown Practices 

1.0 Bake Oven Sections or Cells 

Baking of green anodes is a semi-continuous process. Typically, the furnace operates in 

a cycle with individual sections being loaded, baked, cooled and unloaded in series. At a given 

time, different sections of the oven will be found in one of the above conditions. 

The following is the typical startup procedure for an individual section of a bake oven 

and reflects conditions used for all sections of each of the ovens at Century. 

a. Startup 

• When a section of an oven is ready for use, it is loaded with green anodes in horizontal 

rows. Each section consists of six to seven cells so the entire section is loaded prior to 

commencement of the cycle. Each cell is loaded with ten to twelve anodes. 

• Once the green anodes are placed into the cell, packing coke is introduced into all of the 

voids to provide insulation and eliminate any air pockets to could lead to air burning of 

the anodes. Then, the top of the oven is sealed and the combustion manifold moved into 

place. 

• When the manifold is in place, the burners are ignited and the baking process begins. 

Natural gas and the volatiles from the anodes act to sustain the temperature needed to 

bake or cure the anodes. 

b. Shutdown 

Shutdown of an oven section can occur for various reasons. Shutdown can occur at the 

end of a bake cycle or during the cycle due to variances in typical process conditions. For the 

purpose of this section, shutdown is expressed as the procedure completed at the end of a baking 

cycle. 

• Once a baking cycle is complete, the firing manifold is moved to the next section. 
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Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001)

• Once the fire has been removed from the section, the anodes are allowed to cool. They 

remain in the covered section for up to 20-48 hours while they cool to the point in which 

they can be safely handled. They also remain covered until the temperature in the section 

is low enough to prevent air burning of the anodes. 

• Once cooling is complete, the packing coke is vacuumed from the top of and from around 

the anodes. 

• Once the packing coke is removed, the anodes are removed from the section and placed 

into the inventory. 

• Once all anodes are removed and any debris or packing coke has been removed, the cells 

of the section are inspected and prepared to receive new green anodes. 

1.0 Emission Control Equipment 

 Regulated emissions from the bake ovens are controlled by an alumina injected dry 

scrubber. Exhaust gases from the bake ovens are drawn from the bottom of each oven through a 

manifold to the ductwork that feeds the control device. The gases then pass through an 

evaporative cooler that is used to reduce the temperature and volume of the gas stream. Gas then 

enters a section of ductwork where alumina is injected to react with the gaseous emissions. 

Reacted alumina, particulate and other materials are then collected on a fabric filter. Exhaust gas 

then passes to the atmosphere through a 200-foot stack. 

a. Startup 

 The emission control device is started up in the following manner. 

• Prior to start-up, the following pieces of equipment should be evaluated for proper 

function. 

3⁄4 Compressed air circuit 

3⁄4 Compressed air dryer 

3⁄4 Systems dampers 

3⁄4 Cooling tower spray system 

3⁄4 Cooling water supply tank 

3⁄4 Fabric filter pulse system 

3⁄4 Alumina handling and feed system 

• Prior to the introduction of exhaust gas to the system, all functions related to the cooling 

tower and alumina feed will be tested for proper function. 
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Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001)

• Immediately prior to the introduction of exhaust gas to the system, the water to the 

cooling tower should be turned on and alumina feed to the injector/reactor started. 

• The exhaust fan should also be engaged at this time and the system damper opened

slightly to allow the system to come up to temperature. 

• Once startup of the system has occurred, the alumina and water flow to the system should 

be adjusted to manufacturer’s recommendations. 

• Once the system has run for two hours, adjust the material flow to the alumina feed 

reactor to optimize the recycle rate. This startup procedure is for startup when the entire 

system has been down. Since the fabric filter is modular, it would not be necessary to 

shutdown and restart the system during normal maintenance. 

b. Shutdown 

 Shutdown would typically occur only when all of the bake ovens are shut down or when 

a major malfunction occurs. The following is the procedure for isolating the emission control 

system in the event the system must be shutdown. 

• Close all exhaust manifold dampers and shut down exhaust fans. 

• Open the bypass to exhaust or vent the system to eliminate any excess heat from the 

system. 

• Turn off the water to the evaporative cooler. 

• Close the exhaust damper to isolate the system. 

• Turn off alumina flow to the reactor. 

• If the system is to be down for a period greater than twenty-four hours, cycle through the 

bag cleaning cycle on the fabric filter and remove any alumina from the reactor. 

 In all cases, the facility procedure for confined space entry and lock out / tag out should 

be followed prior to entry into the system. 
Century Aluminum of Kentucky LLC - Hawesville, Kentucky 21 

Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001)

b. Malfunction Practices 

1.0 Carbon Bake Ovens 

Malfunctions in the carbon baking process can take place for various reasons. Some of 

the malfunctions can cause greater than normal emissions or directly impact the performance of 

the emission control system. For the purpose of this document, only those malfunctions that 

have the potential to cause increased emissions will be addressed. 

 a. Bake Oven Malfunctions 

 Malfunctions can occur for various reasons. Listed below are the most common types 

of malfunctions that occur and could result in increased emissions. 

• Loss of fire - this malfunction is the result of a loss of heat to the section or sections of 

the oven. This scenario can lead to uneven curing, air burning of anodes or poor 

combustion of volatiles from the anodes. 

• Air burning — this malfunction is actually a common process condition that is the result 

of to much air to a cell in an oven section. This condition leads to combustion of the 

carbon and the volatiles and degradation of the anode 

• Refractory failure — this malfunction is the result of the failure of the refractory material 

that lines each cell in the oven section. This condition can lead to air burning of anodes 

as well as improper baking and or fires. 

• Green anode failure — this malfunction is actually a common process condition that is 

the result of a green anode cracking and starting to burn. This condition can lead to 

combustion of the carbon and the volatiles in the anode. 

• Fan failure — this malfunction can cause the loss of draft on the sections under fire and 

can lead to poor combustion or incomplete curing of the anodes. 

• Crane failure — this malfunction can lead to the inability to move the firing manifold or 

properly maintain the individual sections of an oven. 

• Fire — this malfunction can lead to excess emissions and damage to equipment. 

• Power failure — this malfunction can lead to excess emissions and damage to equipment. 

 The aforementioned events are those that are considered malfunctions for use in 

implementing the procedures found in this document. Other conditions may be deemed a 

malfunction at the time they occur but are typically limited in frequency and duration. The 
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Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001)

events mentioned above have the highest potential to cause excess or greater than normal 

emissions from the process. 

 b. Emission Control System 

 Malfunctions can occur due to various reasons. All three bake ovens are controlled by a 

common control device, so any malfunctions will impact the operation of all of the ovens. For 

the purpose of this section, a malfunction is defined as an event that effects the performance of 

the control device. 

• Alumina Feed System — the loss of alumina feed to the reactor degrades the ability of the 

system to absorb the hydrogen fluoride and POM emissions from the process. 

• Fabric Filter — loss of individual bags or sections of the unit could lead to excess 

emissions due to a reduction in effective collection surface. 

• Evaporative Cooling Tower — loss of water feed to the tower will expose the fabric filter 

to high temperatures and possible damage from the heat. 

• System Fans — loss of fans will not allow for the proper operation of the control system. 

• Compressor failure — loss of air to the control system could lead to inefficient bag 

cleaning and degradation of performance. 

• Excessive heat — exposure of the fabric filter to excessive heat due to fire or cooling 

tower failure will cause damage that degrades the performance of the control system. 

 The aforementioned events are those that are considered malfunctions that would impact 

the efficiency of the system. Other events may be deemed malfunctions at the time they occur 

but are not listed because they are typically limited in frequency and duration. The conditions 

mentioned above have the highest potential to cause excessive or greater than normal emissions 

from the system. 
Century Aluminum of Kentucky LLC - Hawesville, Kentucky 23 

Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001)

D. Green Mill/Anode Former 

1.0 Purpose 

 The purpose of this procedure is to establish the steps necessary for the startup and 

shutdown of the green mill/anode former. For the purpose of this document, the startup and 

shutdown procedures detailed in this section will represent the procedure for processes which 

result in the formation of green anodes. 

2.0 Process Description 

 Century is a primary aluminum reduction facility (SIC 3334 which produces aluminum 

from the electrolytic reduction of alumina (aluminum oxide) to molten aluminum. Alumina is 

produced off-site at a refinery and is shipped to the Century facility by way of river barge or 

railroad. 

 Alumina is reduced to aluminum in a rectangular cell called a pot. These pots are 

arranged together in a series to form a potline. Potlines are housed in long buildings called 

potrooms. Century operates five potlines of which four were built in 1969 and the fifth built in 

1998-1999 which commenced operation in April of 1999. 

 Aluminum is produced by the electrolysis of alumina dissolved in a molten cyrolite 

(sodium aluminum fluoride) based electrolyte. In this process, electrical current is used to 

reduce the alumina into aluminum and oxygen. Electrical current is transferred through a 

sacrificial carbon anode to the molten bath. The pot is lined with carbon cathode material which 

completes the electrical circuit. 

 Anodes are produced at the green mill. This process is separate from the production of 

molten aluminum. Anode forming is a batch process which consists of mixing and forming of 

raw materials used to produce green anodes. 

 Anodes consist of recycled anode material (green or baked or butts returned from the 

potline), petroleum coke and coal tar pitch. These materials are mixed in batches according to a 

standard formulation. Batch material is then conveyed as a paste to the anode former where the 

material is shaped by vibration and compaction into what is known as a green anode. Once 

formed, the green anode proceeds to further processing steps prior to use in the reduction cells. 

 Emissions from this operation are controlled prior to release into the atmosphere. The 

batch mixers, paste conveyor and the anode former are hooded in order to capture any 

particulate and gaseous emissions generated by the process. These gases are exhausted through 

ductwork to a pollution control system that consists of a dry coke scrubber and a fabric filter. 

There are some fugitive emissions that escape the process which are exhausted through building 

vents. 
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Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001)

3.0 Procedures 

a. Startup/Shutdown Practices 

1.0 Batch Mixers 

 Production of green anodes is a semi-continuous batch process. Anodes are produced 

from a paste mixture made by combining petroleum coke, coal tar pitch and recycled carbon 

material in the form of reject paste, crushed anodes or carbon fines. As a result, startup and 

shutdown for this portion of the plan is limited to the mixers used to produce the anode paste. 

 The following are the typical startup and shutdown procedures for an individual mixer and 

the paste transport conveyor. These conditions reflect those for all of the mixers found in the 

green mill. 

a. Startup 

• Green anode raw materials are mixed in one of nine (9) paste mixers. Each mixer is 

vertical in configuration with material added to the top and the paste discharged from the 

bottom. 

• Startup commences with the addition of the raw materials to the mixer. Once that occurs, 

the mixer is turned on and the materials mixed to the proper consistency. The mixers are 

sequenced in such a manner as to assure an uninterrupted flow of material to the paste 

conveyor. 

• Transport conveyors are started at the same time as the mixers and will continue to run 

until all paste is conveyed to the anode former or sent to the reject pile. 

• Reject paste is directed to another conveyer which transports the material to a storage 

bunker for use back into the process. 

b. Shutdown 

• Raw material flow to an individual mixer is discontinued by closing slide gates that 

effectively isolate the mixer from the feed conveyor. 

• The individual mixer continues to run until all paste is removed from the mixer. At that 

point, power to the mixer is discontinued. 

• During a complete shutdown, all material conveyors are also run empty and then 

shutdown as needed. 
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Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001)

 2.0 Anode Former 

 Formation of green anodes is a mechanical process that uses pressure and vibration to 

form the green anode from mixed paste. The following is the typical startup and shutdown 

procedure for the anode former. 

a. Startup 

• Prior to the startup of the anode former, the batch mixers and conveyors should be on line 

and operating. 

• Prior to startup, the feed bin, conveying system and heating system for the anode former 

should be operating. 

• Prior to startup of the anode former, the feed bin should contain green paste. 

• Prior to startup, the vibration system should be checked for function. 

• Once all of the preliminary steps are completed, the anode former should be activated and 

green paste introduced to the anode former from the feed bin. 

b. Shutdown 

• For a complete shutdown, green paste flow from the mixers is discontinued. 

• The material in the feed bin for the anode former is run out until the bin is empty. 

• The vibrating system is shutdown and the bin heater turned off (if all material has been 

removed). 

• For partial shutdowns, the same procedure is used except the anode former feed bin is not 

shutdown and the heater continues to operate. 

 3.0 Emission Control Equipment 

 Regulated emissions from the green mill/anode former are controlled by a coke injected 

dry scrubber. Exhaust from the mixers, feed conveyors and the anode former are collected and 

ducted to the dry scrubber. The coke acts to absorb the organic emissions from the process 

which in turn is collected by the fabric filter. Treated exhaust gas is then ducted to the 

atmosphere through a sixty (60) foot stack. 
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Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001)

a. Startup 

• Prior to startup, the following equipment should be evaluated for proper function. 

3⁄4 Compressed air circuit 

3⁄4 Compressed air dryer 

3⁄4 System dampers 

3⁄4 Coke feed system 

3⁄4 Coke silo air circuit 

3⁄4 Coke level in silo 

• Prior to introduction of exhaust gas to the system, all functions related to the coke feed 

and fabric filter system will be tested for proper function. 

• Open all dampers and energize system fans. 

• Turn on coke flow to the ductwork and coke flow to the venturi. 

• Once startup has occurred, the coke feed rate should be adjusted to the manufacturer’s 

recommendations. 

b. Shutdown 

• Shutdown of this emission control device would only occur when the process is down or 

when the control device experiences a problem that inhibits its function. 

• To shutdown the control device, the equipment should be isolated from the process. This 

requires that all system dampers be closed and the system fan shut down 

• The coke feed to the venturi and the ductwork should cease. 

• The system bypass should be opened to allow any trapped gas to vent from the system. 

• If the system is to go down for a period longer than twenty-four hours, cycle through the 

cleaning cycle and remove any coke from the venturi system. 
Century Aluminum of Kentucky LLC - Hawesville, Kentucky 27 

Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001)

b. Malfunction Practices 

1.0 Batch mixers 

a. Batch mixer malfunctions 

 Malfunctions can occur for various reasons. The following is a list of the most common 

incidents that could be considered malfunctions and result in an increase in emissions. 

• Power failure - Power to the process ceases and equipment does not perform as required. 

• System plugging — Raw material to the system is interrupted causing an imbalance in 

the recipe. 

• Heater failure — heat to the pitch is disabled causing improper feed rate to the mixer. 

• Mixer failure - The mixer ceases proper operation. 

• Conveyor failure — Transport of mixed paste ceases causing a backup in the system. 

 From a process standpoint, none of the listed process malfunctions has a great potential to 

result in an increase of emissions. The aforementioned events are those that are considered 

malfunctions for use in implementing the procedures found in this document. Other events may 

be deemed a malfunction at the time they occur but are typically limited in frequency and 

duration. 

2.0 Anode Former 

a. Anode Former Malfunctions 

 Malfunctions can occur for various reasons. The following is a list of the most common 

types of malfunctions that can occur and could result in increased emissions from the process. 

• Power failure — power to the system is discontinued causing a backup in the system. 

• System plugging — the feed bin plugs causing material flow to be discontinued. 

• Conveyor failure — conveyors bringing paste to the former or carrying anodes away 

causing a backup of the system. 

• Vibrator failure — vibrator does not operate correctly causing malformed or misshapen 

anodes. 

• Feed bin — heater failure causes material to clog the system. 
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Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001)

 The aforementioned events are those that are considered malfunctions for implementing 

the procedures found in this document. Other events may be deemed a malfunction at the time 

that they occur but are typically limited in frequency and duration. 

3.0 Emission Control Equipment 

a. Emission Control Equipment Malfunctions 

 Malfunctions can occur due to various reasons. For the purpose of this section, a 

malfunction is defined as an event that effects the performance of the control device. 

• Coke Feed System — the loss of coke feed to the reactor degrades the ability of the 

system to absorb the POM emissions from the process. 

• Fabric Filter — loss of individual bags or sections of the unit could lead to excess 

emissions due to a reduction in effective collection surface. 

• System Fans — loss of fans will not allow for the proper operation of the control system. 

• Compressor failure — loss of air to the control system could lead to inefficient bag 

cleaning and degradation of performance. 

• Excessive heat — exposure of the fabric filter to excessive heat due to fire or cooling 

tower failure will cause damage that degrades the performance of the control system. 

 The aforementioned events are those that are considered malfunctions that would impact 

the efficiency of the system. Other events may be deemed malfunctions at the time they occur 

but are not listed because they are typically limited in frequency and duration. The conditions 

mentioned above have the highest potential to cause excessive or greater than normal emissions 

from the system 
Century Aluminum of Kentucky LLC - Hawesville, Kentucky 29 

Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001)

III CORRECTIVE ACTION PRACTICES AND PROCEDURES 

This portion of the plan is divided into four individual sections with two subsections per 

section. Each section covers the corrective action practices and procedures for conditions that 

could occur outside of normal-operating procedures. 

The individual practices and procedures cover the listed malfunctions related to the 

processes and emission control equipment listed in Section II of this document. Conditions 

addressed by this section occur on a non-routine basis and are typically related to process upsets 

or equipment failures. 

Normal maintenance activities which occur on a routine, scheduled basis are not included 

as part of this plan. However, normal maintenance activities that involve the startup and 

shutdown of the affected processes will follow the procedures found in Section II of this 

document. If a malfunction were to occur as the result of a normal maintenance activity, 

procedures found in Section III will be followed. 
Century Aluminum of Kentucky LLC - Hawesville, Kentucky 30 

Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001)

A. Potlines One Through Four 

1.0 Purpose 

The purpose of this section of the plan is to establish the practices and procedures 

necessary to correct problems that may arise as a result of startup, shutdown or malfunction of 

covered processes. For the purpose of this procedure, the corrective action practices and 

procedures in this section will be for the individual pots and associated emissions controls for 

potlines one through four. 

2.0 Practices And Procedures 

The corrective action practices and procedures expressed in this section are to be used to 

correct problems that could result in greater than normal emissions from the covered processes. 

a. Startup And Shutdown 

1.0 Aluminum Reduction Pots 

Startup and shutdown of reduction pots occurs on a routine basis depending on the life 

cycle of the individual pots. Startup of individual pots shall occur as detailed in Section II A 

(3.0)(a) of this manual. Shutdown of individual pots shall occur as detailed in Section II A 

(3.0)(b) of this manual. 

Deviation from the aforementioned procedures shall not be perceived as a malfunction 

requiring corrective action unless emissions generated as a result of the deviation are typically 

greater than those generated during normal startup and shutdown procedures. 

Conditions that generate emissions in excess of those typical during startup and shutdown 

procedures shall be corrected as soon as possible but in no case greater than twenty-four hours 

after the condition is identified unless circumstances prevent the correction. In that case, 

notification will be made following the procedures found in Section V of this manual. 

The following is the procedure for identifying the condition and implementing corrective 

action. 

• Identify the condition and determine if it is outside the normal startup and shutdown 

procedures. 

• Take action to correct the situation in order to alleviate the problem and the potential for 

excess emissions. 

• If the condition results in emissions beyond the norm, document the condition and 

duration utilizing the form found in Appendix A. 
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Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001)

• If the condition exceeds a twenty-four hour period, report the condition as required 

following the procedures found in Section V of this manual. 

2.0 Emission Control Equipment 

 Startup and shutdown of emission control equipment can occur on a routine basis for 

scheduled maintenance. This type of activity will not be addressed as part of this plan. This plan 

will only involve non-routine issues that are the result of failure of equipment, process upsets or 

other issues beyond the normal control of facility personnel. Startup of emission control 

equipment shall occur as detailed in Section II(A)(3 .0)(a) of this manual. Shutdown of emission 

control equipment shall occur as detailed in Section II(A)(3 .0)(a) of this manual. 

 Deviation from these procedures shall not be perceived as a malfunction requiring 

corrective action unless emissions are in excess of those typical of those associated with normal 

startup and shutdown practices. 

 Conditions that generate emissions in excess of those typical during normal startup and 

shutdown procedures shall be corrected as soon as possible but in no case should last greater than 

twenty-four hours after the condition is identified. 

 The following is the procedure for identifying the condition and implementing corrective 

action. 

• Identify the condition and determine if it is outside of the normal startup and shutdown 

procedures. 

• Take action to correct the situation in order to alleviate the problem. 

• If the condition results in emissions beyond the norm, document the conditions and the 

duration of the event utilizing the form found in Appendix A. 

• If the condition exceeds a twenty-four hour period, report as required following the 

procedures found in Section V of the manual. 

b. Malfunctions 

1.0 Aluminum Reduction Pots 

 Malfunctions requiring corrective action are found in Section II(A)(3.0)(b) of this 

manual. These malfunctions are those that have the potential to generate emissions in excess of 

normal conditions for a period greater than one hour in length. 
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Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001)

2.0 Corrective Action Procedures 

• Sick Pot 

- Identify the cause of the problem. 

- Initiate corrective action related to the identified problem 

- If the problem cannot be corrected within twenty-four (24) hours, the pot should 

be removed from service. 

- Document the condition and duration of the problem using the procedures found 

in Section IV of this manual. 

• Anode Failure 

- Identify the location and condition of the anode in question. 

- Determine if the anode can be removed and replaced or if it has fallen into the 

bath and needs to be retrieved. 

- If the anode can be removed and replaced following normal procedures, then 

there is no need to document the event. 

- If the anode needs to be removed from the bath and requires the removal of more 

hood shields than are typically removed during anode changes, document the 

effort as detailed in Section IV of this manual. 

• Anode Effect 

- Identify the affected pot and take correction action to quench the effect using the 

computer or manual controls or using a physical means of altering the resistance. 

• Power Outage 

- Make all efforts to restore power to the impacted equipment as soon as possible. 

If the duration of the outage is longer than one hour, initiate procedures to isolate 

and idle the pots to maintain heat. 

• Crane Failure 

- Make all efforts to repair the crane or move a replacement into place to tend the 

pots. 

- If the duration of the repair is long, initiate procedures to alternately tend affected 

pots. 

• Compressor Failure 

- Make necessary repairs or provide an alternate means of supplying air to the 

affected area. 
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Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001)

• Hood Shield Failure 

- Repair or replace affected shields as soon as possible. 

3.0 Emission Control Equipment 

Malfunctions requiring corrective action are found in Section II A (3.0)(b). These 

malfunctions are those that have the potential to impair the performance of the control device 

and lead to an increase in emissions. 

• Identify the cause of the problem. 

• Initiate corrective action which could include equipment shutdown, maintenance or 

optimization. 

• Document the condition and duration of the problem using procedures found in Section 

IV of this manual. 

• If required, report using procedures found in Section V of this manual. 
Century Aluminum of Kentucky LLC - Hawesville, Kentucky 34 

Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001)

B. Potline Five 

1.0 Purpose 

 The purpose of this section of the plan is to establish the practices and procedures 

necessary to correct problems that may arise as a result of startup, shutdown or malfunction of 

covered processes. For the purpose of this procedure, the corrective action practices and 

procedures in this section will be for the individual pots and associated emissions controls for 

potline five. 

2.0 Practices And Procedures 

 The corrective action practices and procedures expressed in this section are to be used to 

correct problems that could result in greater than normal emissions from the covered processes. 

a. Startup And Shutdown 

1.0 Aluminum Reduction Pots 

 Startup and shutdown of reduction pots occurs on a routine basis depending on the life 

cycle of the individual pots. Startup of individual pots shall occur as detailed in Section II B 

(3.0)(a) of this manual. Shutdown of individual pots shall occur as detailed in Section II B 

(3.0)(a) of this manual. 

 Deviation from the aforementioned procedures shall not be perceived as a malfunction 

requiring corrective action unless emissions generated as a result of the deviation are typically 

greater than those generated during normal startup and shutdown procedures. 

 Conditions that generate emissions in excess of those typical during startup and shutdown 

procedures shall be corrected as soon as possible but in no case greater than twenty-four hours 

after the condition is identified, unless circumstances prevent the correction. In that case, 

notification will be made following procedures found in Section V of this manual. 

 The following is the procedure for identifying the condition and implementing corrective 

action. 

• Identify the condition and determine if it is outside the normal startup and shutdown 

procedures. 

• Take action to correct the situation in order to alleviate the problem and the potential for 

excess emissions. 

• If the condition results in emissions beyond the norm, document the condition and 

duration utilizing the form found in Appendix A. 
Century Aluminum of Kentucky LLC - Hawesville, Kentucky 35 

Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001)

• If the condition exceeds a twenty-four hour period, report the condition as required 

following the procedures found in Section V of this manual. 

2.0 Emission Control Equipment 

 Startup and shutdown of emission control equipment can occur on a routine basis for 

scheduled maintenance. This type of activity will not be addressed as part of this plan. This plan 

will only involve non-routine issues that are the result of failure of equipment, process upsets or 

other issues beyond the normal control of facility personnel. Startup of emission control 

equipment shall occur as detailed in Section II B (3.0)(a) of this manual. Shutdown of emission 

control equipment shall occur as detailed in Section II B (3.0)(a) of this manual. 

 Deviation from these procedures shall not be perceived as a malfunction requiring 

corrective action unless emissions are in excess of those typical of those associated with normal 

startup and shutdown practices. 

 Conditions that generate emissions in excess of those typical during normal startup and 

shutdown procedures shall be corrected as soon as possible but in no case should last greater than 

twenty-four hours after the condition is identified. 

 The following is the procedure for identifying the condition and implementing corrective 

action. 

• Identify the condition and determine if it is outside of the normal startup and shutdown 

procedures. 

• Take action to correct the situation in order to alleviate the problem. 

• If the condition results in emissions beyond the norm, document the conditions and the 

duration of the event utilizing the form found in Appendix A. 

• If the condition exceeds a twenty-four hour period, report as required following the 

procedures found in Section V of the manual. 

b. Malfunctions 

1.0 Aluminum Reduction Pots 

 Malfunctions requiring corrective action are found in Section II B (3.0)(b) of this manual. 

These malfunctions are those that have the potential to generate emissions in excess of normal 

conditions for a period greater than one hour in length. 
Century Aluminum of Kentucky LLC - Hawesville, Kentucky 36 

Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001)

2.0 Corrective Action Procedures 

• Sick Pot 

- Identify the cause of the problem. 

- Initiate correction action related to the identified problem 

- If the problem cannot be corrected within twenty-four (24) hours, the pot should 

be removed from services. 

- Document the condition and duration of the problem using the procedures found 

in Section IV of this manual. 

• Anode Failure 

- Identify the location and condition of the anode in question. 

- Determine if the anode can be removed and replaced or if it has fallen into the 

bath and needs to be retrieved. 

- If the anode can be removed and replaced following normal procedures, then 

there is no need to document the event. 

- If the anode needs to be removed from the bath and requires the removal of more 

hood shields than are typically removed during anode changes, document the 

effort as detailed in Section IV of this manual. 

• Anode Effect 

- Identify the affected pot and take correction action to quench the effect using the 

computer or manual controls or using a physical means of altering the resistance. 

• Power Outage 

- Make all efforts to restore power to the impacted equipment as soon as possible. 

If the duration of the outage is longer than one hour, initiate procedures to isolate 

and idle the pots to maintain heat. 

• Crane Failure 

- Make all efforts to repair the crane or move a replacement into place to tend the 

pots. 

- If the duration of the repair is long, initiate procedures to alternately tend affected 

pots. 

• Compressor Failure 

- Make necessary repairs or provide an alternate means of supplying air to the 

affected area. 

• Hood Shield Failure 

- Repair or replace affected shields as soon as possible. 
Century Aluminum of Kentucky LLC - Hawesville, Kentucky 37 

Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001)

3.0 Emission Control Equipment 

Malfunctions requiring corrective action are found in Section II B (3.0)(b). These 

malfunctions are those that have the potential to impair the performance of the control device 

and lead to an increase in emissions. 

• Identify the cause of the problem. 

• Initiate corrective action which could include equipment shutdown, maintenance or 

optimization. 

• Document the condition and duration of the problem using procedures found in Section 

IV of this manual. 

• If required, report using procedures found in Section V of this manual. 
Century Aluminum of Kentucky LLC - Hawesville, Kentucky 38 

Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001)

C. Carbon Bake Ovens 

1.0 Purpose 

 The purpose of this section of the plan is to establish the practices and procedures 

necessary to correct problems that may arise as a result of startup, shutdown or malfunction of 

the covered processes. For the purpose of this procedure, the corrective action practices and 

procedures will be used for all three bake ovens and the common emission control device. 

2.0 Practices and Procedures 

 The corrective action practices and procedures expressed in this section are to be used to 

correct problems that could result in greater than normal emissions from the covered processes. 

a. Startup and Shutdown 

1.0 Carbon Bake Ovens 

 Startup and shutdown of sections of the bake oven or the entire oven occur on a routine 

basis as detailed in Section II C (3 .0)(a) of this document. 

Deviation from the aforementioned procedures shall not be perceived as a malfunction 

requiring corrective action unless emissions generated as a result of the deviation are typically 

greater than those generated during normal startup and shutdown procedures. 

 Conditions that generate emissions in excess of those typical during startup and shutdown 

procedures shall be corrected as soon as possible but in no case greater than twenty-four hours 

after the condition is identified unless circumstances prevent the correction. In that case, 

notification will be made following the procedures found in Section V of this manual. 

 The following is the procedure for identifying the condition and implementing corrective 

action. 

• Identify the condition or event and determine if it is outside of the normal startup and 

shutdown procedures. 

• Take action to correct the situation in order to alleviate the problem and the potential for 

excess emissions. 

• If the condition results in emissions beyond the norm, document the condition and 

duration utilizing the form found in Appendix A. 

• If the condition exceeds a twenty-four hour period, report the condition as required 

following the procedures found in Section V of this document. 
Century Aluminum of Kentucky LLC - Hawesville, Kentucky 39 

Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001)

2.0 Emission Control System 

 Startup and shutdown of the control system typically does not occur on a routine basis. If 

the system goes through startup and shutdown, the procedures found in Section II C (3.0)(a) will 

apply. 

 Deviation from the aforementioned procedures shall not be perceived as a malfunction 

requiring corrective action unless emissions generated as a result of the deviation are greater than 

those generated during normal startup and shutdown procedures. 

 Conditions that generate emissions in excess of those typical during startup and shutdown 

procedures shall be corrected as soon as possible but in no case greater than twenty-four hours 

after the condition is identified unless circumstances prevent the correction. In that case, 

notification will be made following the procedures found in Section V of this document. 

 The following is the procedure for identifying the condition and implementing corrective 

action. 

• Identify the condition or event and determine if it is outside of the normal startup and 

shutdown procedures. 

• Determine if as a result of the condition or event there is the potential for greater than 

normal emissions from the process. 

• Take action to correct the situation in order to alleviate the problem and the potential for 

greater than normal emissions. 

• If the condition or event results in emissions beyond the norm, document the condition 

and duration utilizing the form found in Appendix A 

• If the condition or event exceeds a twenty-four hour period, report the condition or event 

as required following the procedures found in Section V of this document. 

b. Malfunctions 

1.0 Carbon Bake Ovens 

 Malfunctions requiring corrective action are found in Section II C (3 .0)(b) of this 

manual. These malfunctions are those that have the potential to generate emissions in excess of 

normal conditions for a period greater than one hour in length. 
Century Aluminum of Kentucky LLC - Hawesville, Kentucky 40 

Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001)

• Loss of fire 

- Identify the cause of the problem 

- Initiate corrective action related to the identified problem utilizing standard 

operating procedures 

- Document the condition and the duration of the problem using procedures found 

in Section IV of this manual. 

• Air Burning 

- Identify the location and condition of the anode in question. 

- Determine if the anode can be removed and replaced. 

- If the anode can be removed and replaced following normal procedures, then 

there is no need to document the event. 

- If the anode needs to be removed from the oven, document the effort as detailed 

in Section IV of this manual. 

• Refractory Failure 

- Identify the affected section and take correction action to isolate, unload and 

repair the section. 

• Power Outage 

- Make all efforts to restore power to the impacted section or oven as soon as 

possible. If the duration of the outage is longer than one hour, initiate procedures 

to isolate and idle the oven to maintain heat. 

• Crane Failure 

- Make all efforts to repair the crane or move a replacement into place to tend the 

ovens. 

- If the duration of the repair is long, initiate procedures to alternately tend affected 

ovens. 

• Green Anode Failure 

- Make necessary efforts to identify the failed anode and remove it from the oven 

section. 

• Fire 

- Cease operation as soon as possible and activate fire system. 

2.0 Emission Control Equipment 

 Malfunctions requiring corrective action are found in Section II(C)(3.0)(b). These 

malfunctions are those that have the potential to impair the performance of the control device 

and lead to an increase in emissions. 
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Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001)

• Identify the cause of the problem. 

• Initiate corrective action which could include equipment shutdown, maintenance or 

optimization. 

• Document the condition and duration of the problem using the procedures found in 

Section IV of this manual. 

• If required, report using procedures found in Section V of this manual. 
Century Aluminum of Kentucky LLC - Hawesville, Kentucky 42 

Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001)

D. Green Mill / Anode Former 

1.0 Purpose 

 The purpose of this section of the plan is to establish the practices and procedures 

necessary to correct problems that may arise as a result of startup, shutdown or malfunction of 

the covered processes. For the purpose of this procedure, the corrective action practices and 

procedures in this section will be for all batch mixers, conveyors and the anode former. 

2.0 Practices and Procedures 

 The corrective action practices and procedures expressed in this section are to be used to 

correct problems that could result in greater than normal emissions from the covered processes. 

a. Startup and Shutdown 

1.0 Batch Mixers 

 Startup and shutdown of sections of the Batch Mixers occur on a routine basis depending 

on the need. Startup of individual mixers shall occur as detailed in Section II D (3.0)(a) of this 

manual. Shutdown of individual mixers shall occur as detailed in Section II D (3.0)(a) of this 

manual. 

 Deviation from the aforementioned procedures shall not be perceived as a malfunction 

requiring corrective action unless emissions generated as a result of the deviation are typically 

greater than those generated during normal startup and shutdown procedures. 

 Conditions that generate emissions in excess of those typical during startup and shutdown 

procedures shall be corrected as soon as possible but in no case greater than twenty-four hours 

after the condition is identified unless circumstances prevent the correction. In that case, 

notification will be made following the procedures found in Section V of this manual. 

 The following is the procedure for identifying the condition and implementing corrective 

action. 

• Identify the condition and determine if it is outside the normal startup and shutdown 

procedures. 

• Take action to correct the situation in order to alleviate the problem and the potential for 

excess emissions. 

2.0 Anode Former 

 Startup and shutdown of the anode former occurs on a routine basis depending on need 

cycle of the individual pots. Startup of the anode former shall occur as detailed in Section II D 
Century Aluminum of Kentucky LLC - Hawesville, Kentucky 43 

Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001)

(3.0)(a) of this manual. Shutdown of the anode former shall occur as detailed in Section II D 

(3.0)(a) of this manual. 

 Deviation from the aforementioned procedures shall not be perceived as a malfunction 

requiring corrective action unless emissions generated as a result of the deviation are typically 

greater than those generated during normal startup and shutdown procedures. 

 Conditions that generate emissions in excess of those typical during startup and shutdown 

procedures shall be corrected as soon as possible but in no case greater than twenty-four hours 

after the condition is identified unless circumstances prevent the correction. In that case, 

notification will be made following the procedures found in Section V of this manual. 

 The following is the procedure for identifying the condition and implementing corrective 

action. 

• Identify the condition and determine if it is outside the normal startup and shutdown 

procedures. 

• Take action to correct the situation in order to alleviate the problem and the potential for 

excess emissions. 

• If the condition results in emissions beyond the norm, document the condition and 

duration utilizing the form found in Appendix A. 

• If the condition exceeds a twenty-four hour period, report the condition as required 

following the procedures found in Section V of this manual. 

3.0 Emission Control Equipment 

 Startup and shutdown of emission control equipment can occur on a routine basis for 

scheduled maintenance. This type of activity will not be addressed as part of this plan. This plan 

will only involve non-routine issues that are the result of failure of equipment, process upsets or 

other issues beyond the normal control of facility personnel. Startup of emission control 

equipment shall occur as detailed in Section II D (3.0)(a) of this manual. Shutdown of emission 

control equipment shall occur as detailed in Section II D (3 .0)(a) of this manual. 

 Deviation from these procedures shall not be perceived as a malfunction requiring 

corrective action unless emissions are in excess of those typical of those associated with normal 

startup and shutdown practices. 

 Conditions that generate emissions in excess of those typical during startup and shutdown 

procedures shall be corrected as soon as possible but in no case greater than twenty-four hours 

after the condition is identified. 
Century Aluminum of Kentucky LLC - Hawesville, Kentucky 44 

Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001)

 The following is the procedure for identifying the condition and implementing corrective 

action. 

• Identify the condition and determine if it is outside of the normal startup and shutdown 

procedures. 

• Take action to correct the situation in order to alleviate the problem. 

• If the condition results in emissions beyond the norm, document the conditions and the 

duration of the event utilizing the form found in Appendix A. 

• If the condition exceeds a twenty-four hour period, report as required following the 

procedures found in Section V of the manual. 

b. Malfunctions 

1.0 Batch Mixers 

 Malfunctions requiring corrective action are found in Section II D (3 .0)(b) of this 

manual. These malfunctions are those that have the potential to generate emissions in excess of 

normal conditions for a period greater than one hour in length. 

2.0 Corrective Action Procedures 

• System Plugging 

- Identify the cause of the problem. 

- Initiate corrective action related to the identified problem. 

- Document the condition and the duration of the problem using procedures found 

in Section IV of this manual. 

• Heater Failure 

- Identify the affected heater and take correction action to repair or remove it from 

service. 

• Mixer Failure 

- Identify the affected mixer and take correction action to repair or remove it from 

service. 

• Power Outage 

- Make all effort to restore power to the impacted equipment as soon as possible. 
Century Aluminum of Kentucky LLC - Hawesville, Kentucky 45 

Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001)

• Conveyor Failure 

- Make all efforts to repair the conveyor. 

- If the duration of the repair is long, initiate procedures to clear the conveyors of 

paste. 

3.0 Anode Former 

 Malfunctions requiring corrective action are found in Section II D (3.0)(b) of this manual. 

These malfunctions are those that have the potential to generate emissions in excess of normal 

conditions for a period greater than one hour in length. 

4.0 Corrective Action Procedures 

• System Plugging 

- Identify the cause of the problem. 

- Initiate correction action related to the identified problem. 

- Document the condition and duration of the problem using the procedures found 

in Section IV of this manual. 

• Conveyor Failure 

- Identify the cause of the problem. 

- Initiate correction action related to the identified problem. 

- Document the condition and duration of the problem using the procedures found 

in Section IV of this manual. 

• Heater Failure 

- Identify the cause of the problem. 

- Initiate correction action related to the identified problem. 

- Document the condition and duration of the problem using the procedures found 

in Section IV of this manual. 

• Power Outage 

- Make all efforts to restore power to the impacted equipment as soon as possible. 

If the duration of the outage is longer than one hour, initiate procedures to isolate 

and idle the process. 

5.0 Emission Control Equipment 

 Malfunctions requiring corrective action are found in Section II(D)(3.0)(b)(3.0). These 

malfunctions are those that have the potential to impair the performance of the control device 

and lead to an increase in emissions. 
Century Aluminum of Kentucky LLC - Hawesville, Kentucky 46 

Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001)

• Coke Feed System 

- Identify the cause of the problem. 

- Initiate corrective action which could include equipment shutdown, maintenance 

or optimization. 

- Document the condition and duration of the problem using procedures found in 

Section IV of this manual. 

- If required, report using procedures found in Section V of this manual. 

• Fabric Filter 

- Identify the cause of the problem. 

- Initiate corrective action which could include equipment shutdown, maintenance 

or optimization. 

- Document the condition and duration of the problem using procedures found in 

Section IV of this manual. 

- If required, report using procedures found in Section V of this manual. 

• System Fan 

- Identify the cause of the problem. 

- Initiate corrective action which could include equipment shutdown, maintenance 

or optimization. 

- Document the condition and duration of the problem using procedures found in 

Section IV of this manual. 

- If required, report using procedures found in Section V of this manual. 

• Compressor Failure 

- Identify the cause of the problem. 

- Initiate corrective action which could include equipment shutdown, maintenance 

or optimization. 

- Document the condition and duration of the problem using procedures found in 

Section IV of this manual. 

- If required, report using procedures found in Section V of this manual. 

• Excessive Heat 

- Identify the cause of the problem. 

- Initiate corrective action which could include equipment shutdown, maintenance 

or optimization. 

- Document the condition and duration of the problem using procedures found in 

Section IV of this manual. 

- If required, report using procedures found in Section V of this manual. 
Century Aluminum of Kentucky LLC - Hawesville, Kentucky 47 

Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001)

IV. RECORD KEEPING 

1.0 Purpose 

 The purpose of this section is to detail the requirements for keeping records related to the 

startup, shutdown, and malfunction provisions of the Primary Aluminum NESHAP (40 CFR 63 

Subpart LL). Records kept in relation to this portion of the manual are for the affected sources 

detailed in Section II of this manual. General record keeping requirements used to develop this 

section are found in 40 CFR Part 63.10. 

2.0 Record Keeping Requirements 

a. General Requirements 

1. All records related to the startup, shutdown, and malfunction of affected sources 

found in Section II of this document shall be maintained for a period of five years. 

At a minimum, the last two years of records shall be maintained on site. The 

remaining three years of records may be maintained off site if needed. 

2. Records may be maintained on microfilm, computer databases, computer floppy 

disks, magnetic tape cassettes, microfiche, or hard copy files. 

3. All electronic files should be backed up either electronically or in hard copy. 

b. Specific Requirements 

1. At a minimum, the following records must be maintained related to the startup, 

shutdown, and malfunction plan. 

a. The occurrence and duration of each startup, shutdown or malfunction of 

the affected source or emission control equipment. 

b. Maintenance performed on all affected sources emission control 

equipment. 

c. Activities performed during startup, shutdown, or malfunctions including 

corrective action which is different from the procedures found in this plan. 

d. Related information deemed necessary to demonstrate or confirm 

compliance with the established plan. 

c. On-site Management 

1. Records maintained per Section 2.0 (a)(b) of Part IV of this document shall be 

maintained in the following manner: 
Century Aluminum of Kentucky LLC - Hawesville, Kentucky 48 

Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001)

a. Records shall be maintained at a designated central location (i.e., 

Superintendent’s office) associated with the affected process. 

b. Records shall also be maintained on file in the facility environmental 

manager’s office. 

2. All information maintained in order to show compliance with the procedures 

found in this document shall be completed in duplicate in order to provide the 

copies needed for records management found in Section 1 of this portion of the 

plan. 

d. Off-site Management 

 All records maintained off-site shall be maintained in a manner such that if necessary, 

they can be retrieved within 24 hours of a written request. Maintenance of these records shall 

follow the facility practices and procedures currently in place for off-site record management. 
Century Aluminum of Kentucky LLC - Hawesville, Kentucky 49 

Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001)

V. REPORTING REQUIREMENTS 

1.0 Purpose 

 The purpose of this section is to detail the requirements for reporting in relation to the 

Startup, Shutdown and Malfunction Plan requirements found in 40 CFR 63.10 (d)(5)(I) and (ii). 

Reporting requirements related to this manual are for the affected sources found in Section II of 

this manual. 

2.0 Reporting Requirements 

a. Periodic Startup, Shutdown, Malfunction Reports 

1. This section requires reports related only to those actions taken in compliance 

with the Startup, Shutdown, and Malfunction Plan. 

2. Reports are only required to document the activity that occurred during the stated 

reporting period. 

3. Reports filed according to the requirements of this section shall consist of the 

following. 

a. A letter containing the name, title and signature of the owner operator 

responsible official that certifies the accuracy of the report. 

b. The letter shall list or detail any startup, shutdown or malfunctions that 

occurred during the period. The letter shall also list any corrective action 

taken to correct any malfunctions reported during the period. 

c. The letter shall be submitted to the appropriate agency semiannually. The 

letter should be postmarked no later than 30 days after the end of each 

calendar half. 

b. Immediate Startup, Shutdown, Malfunction Reports 

1. This section requires reports related to actions taken that do not comply with the 

procedures found in the Startup, Shutdown and Malfunction Plan. 

2. Reports are required anytime the procedures are not followed. The owner 

operator shall report within two (2) days by telephone or facsimile and follow up 

with a letter within seven (7) days. 
Century Aluminum of Kentucky LLC - Hawesville, Kentucky 50 

Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001)

3. Reports filed according to these requirements shall consist of the following. 

a. A letter containing the name, title and signature of the owner operator 

responsible official that certifies the accuracy of the report. 

b. The letter shall explain the circumstances of the event, the reasons for not 

following the plan and whether any excess emissions or parameter 

monitoring exceedances are believed to have occurred. 

c. The letter shall be submitted to the appropriate agency per the schedule 

found in item 2 above. 

c. Other Reporting Requirements 

1. This section relates to sources in which Continuous Emission Monitoring Systems 

are used to measure emissions. 

2. Reports required in this section are related to Continuous Emission Monitoring 

System performance, excess emission reporting and system evaluation. 

3. Affected sources are required to submit reports related to this section based upon 

the following. 

a. Continuous Emission Monitoring System performance evaluations shall 

be submitted simultaneously with the results of the performance test. 

b. Excess emissions and parameter monitoring exceedances shall be reported 

semiannually unless: 

1. More frequent reporting is specified in other standards 

2. CMS data is used directly for compliance determinations and the 

source experienced excess emissions. In this case quarterly reports 

will be required. 

c. Performance Tests 

4. Affected sources are required to submit reports related to this section based upon 

the following. 

a. All excess emission reports and monitoring system performance reports 

shall be submitted no later than the 30~ day following the end of each 

calendar half. 
Century Aluminum of Kentucky LLC - Hawesville, Kentucky 51 

Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001)

b. Reports shall contain the following: 

1. The date and time identifying each period during which the CMS 

was inoperative. 

2. The total process operating time during the period. 

3. The date and time identifying each period the CMS was out of 

control. 

4. Identification of each period of excess emissions and parameter 

monitoring exceedances that occurs during startup, shutdown and 

malfunctions. 

5. Identification of each period of excess emissions and parameter 

monitoring exceedances that occurs during other than startup, 

shutdown and malfunctions. 

6. The nature and cause of the malfunction. 

7. Corrective action taken. 

8. The nature of the repairs or adjustments to the CMS that was 

inoperative or out of control. 

9. If no excess emissions or parameter exceedances were 

experienced, this information should be included in the report. 
Century Aluminum of Kentucky LLC - Hawesville, Kentucky Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001)

Appendix A 

Malfunction Report Form 
Century Aluminum of Kentucky LLC - Hawesville, Kentucky Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001)

Malfunction Report Form 

I. Purpose of the Form 

This form is designed to meet the requirements of 40 CFR Part 63.850 which requires that 

malfunctions during startup and shutdown of affected sources and the related emission control 

equipment be documented. 

II. Malfunction Report 

 A. Date and Time of Malfunction: 

 B. Affected Process or Control Equipment: 

 

 C. Description of the Malfunction: 

 

 

 D. Reason for the Malfunction: 

 

 E. Duration of the Malfunction: 

 
Century Aluminum of Kentucky LLC - Hawesville, Kentucky Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001)

Appendix B 

Malfunction Reporting Call Roster 
Century Aluminum of Kentucky LLC - Hawesville, Kentucky Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001)

Malfunction Reporting Call Roster 

I. Purpose 

In the event of a malfunction that results in excess emissions, a spill or worker exposure or any 

other event that would impact the environment or personnel on or off site, this roster details who 

the internal contact are and what the procedure is for reporting. 

II. Malfunction Reporting 

In the event of the need to report a malfunction, the following individuals will be notified in the 

order listed below. For the purpose of internal reporting, a malfunction is defined as a deviation 

from the normal startup, shutdown procedures or is a listed malfunction found in Section II of 

this manual. 

Position Work Phone Home Phone

1. Ken Sands 

 Environmental, Health 

 and Safety Manager 

(502) 927-6921

ext 208

(812) 362-8025 

2. Rick Hammond 

 Director of Safety and 

 Security 

(502) 927-6921

ext 469

(502) 685-4383 

3. Jim Poteat 

 Environmental Engineer 

(502) 927-6921

ext 240

(502) 685-3685 

4. Shift Maintenance Supv. (502) 927-6921

ext 359

5. Security Guardhouse (502) 927-6921

ext 222
Century Aluminum of Kentucky LLC - Hawesville, Kentucky Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001)

III. Reporting Responsibility 

Reporting of the malfunction is the responsibility of the supervisor on duty in the area in which 

the malfunction occurs. Internal reporting shall be limited to notifying any two of the listed 

individuals found in Section II. in all cases, the Environmental, Health and Safety Manager 

should be the first individual contacted. 

External reporting of the event will be the responsibility of the Environmental, Health and Safety 

Manager. 
Century Aluminum of Kentucky LLC - Hawesville, Kentucky Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001)

Appendix C 

Site Plan 
Century Aluminum of Kentucky LLC - Hawesville, Kentucky Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001)

III Corrective Action 

A. Date Corrective Action Implemented: 

B. Description of Corrective Action: 

 

 C. Return to Compliance Yes No 

 Date: 

Signature 

(Name) 

(Title) 

(Date) 
Attachment #6

   
Attachment #6 ‐ Test Report Summary

Source

Control

Device Year Pollutant Emission Rate Emission Rate Units Test Method Production Rate Product

Un

Green Carbon 310126 N/A No Test Data

Carbon Bake Scrubber 330140 Apr‐06 POM 0.075 lbs/GT EPA M5 & 315 14,758 Gree

Carbon Bake Scrubber 330140 Apr‐06 HF 0.013 lbs/hr EPA M5 & 13B 14,758 Gree

Carbon Bake Scrubber 330140 Apr‐06 TF 0.0012 lbs/GT EPA M5 & 13B 14,758 Gree

Carbon Bake Scrubber 330140 Apr‐06 PM 1.31 lbs/hr EPA M5 14,758 Gree

Carbon Bake Scrubber 330140 Apr‐07 POM 0.125 lbs/GT EPA M5 & 315 15,004 Gree

Carbon Bake Scrubber 330140 Apr‐07 HF 0.029 lbs/hr EPA M5 & 13B 15,004 Gree

Carbon Bake Scrubber 330140 Apr‐07 TF 0.002 lbs/GT EPA M5 & 13B 15,004 Gree

Carbon Bake Scrubber 330140 Apr‐07 PM 3.04 lbs/hr EPA M5 15,004 Gree

Carbon Bake Scrubber 330140 Apr‐08 POM 0.046 lbs/GT EPA M5 & 315 15,879 Gree

Carbon Bake Scrubber 330140 Apr‐08 HF 0.0141 lbs/hr EPA M5 & 13B 15,879 Gree

Carbon Bake Scrubber 330140 Apr‐08 TF 0.00122 lbs/GT EPA M5 & 13B 15,879 Gree

Carbon Bake Scrubber 330140 Apr‐08 PM 1.77 lbs/hr EPA M5 15,879 Gree

Carbon Bake Scrubber 330140 Apr‐09 POM 0.023 lbs/GT EPA M5 & 315 12,284 Gree

Carbon Bake Scrubber 330140 Apr‐09 HF 0.0326 lbs/hr EPA M5 & 13B 12,284 Gree

Carbon Bake Scrubber 330140 Apr‐09 TF 0.00266 lbs/GT EPA M5 & 13B 12,284 Gree

Carbon Bake Scrubber 330140 Apr‐09 PM 0.56 lbs/hr EPA M5 12,284 Gree

Potline 5 Scrubber 480063 Oct‐06 HF 0.048 lbs/ton Al EPA M5 & 13B 9,702,852 lb

Potline 5 Scrubber 480063 Oct‐06 TF 0.059 lbs/ton Al EPA M5 & 13B 9,702,852 lb

Potline 5 Scrubber 480063 Oct‐06 PM 2.3 lbs/hr EPA M5 & 13B 9,702,852 lb

Potline 5 Scrubber 480063 Nov‐07 HF 0.102 lbs/ton Al EPA M5 & 13B 8,882,406 lb

Potline 5 Scrubber 480063 Nov‐07 TF 0.119 lbs/ton Al EPA M5 & 13B 8,882,406 lb

Potline 5 Scrubber 480063 Nov‐07 PM 2.14 lbs/hr EPA M5 & 13B 8,882,406 lb

Potline 5 Scrubber 480063 Oct‐08 HF 0.05 lbs/ton Al EPA M5 & 13B 9,610,298 lb

Potline 5 Scrubber 480063 Oct‐08 TF 0.063 lbs/ton Al EPA M5 & 13B 9,610,298 lb

Test Report Summary (Jan 2006 ‐ December 2010)

Century Aluminum of KY 5/31/2011 
Attachment #6 ‐ Test Report Summary

Source

Control

Device Year Pollutant Emission Rate Emission Rate Units Test Method Production Rate Product

Un

Test Report Summary (Jan 2006 ‐ December 2010)

Potline 5 Scrubber 480063 Oct‐08 PM 2.04 lbs/hr EPA M5 & 13B 9,610,298 lb

Potline 5 Roof Monitor 423091 Feb‐06 HF 0.615 lbs/ton Al EPA M5 & 13B 8,725,406 lb

Potline 5 Roof Monitor 423091 Feb‐06 TF 0.856 lbs/ton Al EPA M5 & 13B 8,725,406 lb

Potline 5 Roof Monitor 423091 Feb‐06 PM 33.5 lbs/hr EPA M5 & 13B 8,725,406 lb

Potline 5 Roof Monitor 423091 Apr‐06 HF 0.647 lbs/ton Al EPA M5 & 13B 9,308,043 lb

Potline 5 Roof Monitor 423091 Apr‐06 TF 0.925 lbs/ton Al EPA M5 & 13B 9,308,043 lb

Potline 5 Roof Monitor 423091 Apr‐06 PM 32.4 lbs/hr EPA M5 & 13B 9,308,043 lb

Potline 5 Roof Monitor 423091 Aug‐06 HF 0.647 lbs/ton Al EPA M5 & 13B 9,930,872 lb

Potline 5 Roof Monitor 423091 Aug‐06 TF 0.911 lbs/ton Al EPA M5 & 13B 9,930,872 lb

Potline 5 Roof Monitor 423091 Aug‐06 PM 21.7 lbs/hr EPA M5 & 13B 9,930,872 lbPotline 5 Roof Monitor 423091 Nov‐06 HF 0.477 lbs/ton Al EPA M5 & 13B 9,460,788 lb

Potline 5 Roof Monitor 423091 Nov‐06 TF 0.896 lbs/ton Al EPA M5 & 13B 9,460,788 lb

Potline 5 Roof Monitor 423091 Nov‐06 PM 35.7 lbs/hr EPA M5 & 13B 9,460,788 lb

Potline 5 Roof Monitor 423091 Jan‐07 HF 0.639 lbs/ton Al EPA M5 & 13B 9,505,169 lb

Potline 5 Roof Monitor 423091 Jan‐07 TF 1.063 lbs/ton Al EPA M5 & 13B 9,505,169 lb

Potline 5 Roof Monitor 423091 Jan‐07 PM 39.5 lbs/hr EPA M5 & 13B 9,505,169 lb

Potline 5 Roof Monitor 423091 Jun‐07 HF 0.458 lbs/ton Al EPA M5 & 13B 9,242,223 lb

Potline 5 Roof Monitor 423091 Jun‐07 TF 0.724 lbs/ton Al EPA M5 & 13B 9,242,223 lb

Potline 5 Roof Monitor 423091 Jun‐07 PM 31 lbs/hr EPA M5 & 13B 9,242,223 lb

Potline 5 Roof Monitor 423091 Aug‐07 HF 0.622 lbs/ton Al EPA M5 & 13B 9,638,137 lb

Potline 5 Roof Monitor 423091 Aug‐07 TF 0.904 lbs/ton Al EPA M5 & 13B 9,638,137 lb

Potline 5 Roof Monitor 423091 Aug‐07 PM 46.5 lbs/hr EPA M5 & 13B 9,638,137 lbPotline 5 Roof Monitor 423091 Dec‐07 HF 0.579 lbs/ton Al EPA M5 & 13B 9,647,548 lb

Potline 5 Roof Monitor 423091 Dec‐07 TF 0.932 lbs/ton Al EPA M5 & 13B 9,647,548 lb

Potline 5 Roof Monitor 423091 Dec‐07 PM 29.6 lbs/hr EPA M5 & 13B 9,647,548 lb

Potline 5 Roof Monitor 423091 Mar‐08 HF 0.63 lbs/ton Al EPA M5 & 13B 9,624,687 lb

Century Aluminum of KY 5/31/2011 
Attachment #6 ‐ Test Report Summary

Source

Control

Device Year Pollutant Emission Rate Emission Rate Units Test Method Production Rate Product

Un

Test Report Summary (Jan 2006 ‐ December 2010)

Potline 5 Roof Monitor 423091 Mar‐08 TF 1.021 lbs/ton Al EPA M5 & 13B 9,624,687 lb

Potline 5 Roof Monitor 423091 Mar‐08 PM 46.3 lbs/hr EPA M5 & 13B 9,624,687 lb

Potline 5 Roof Monitor 423091 Apr‐08 HF 0.585 lbs/ton Al EPA M5 & 13B 9,394,293 lb

Potline 5 Roof Monitor 423091 Apr‐08 TF 0.968 lbs/ton Al EPA M5 & 13B 9,394,293 lb

Potline 5 Roof Monitor 423091 Apr‐08 PM 35.4 lbs/hr EPA M5 & 13B 9,394,293 lb

Potline 5 Roof Monitor 423091 Aug‐08 HF 0.56 lbs/ton Al EPA M5 & 13B 9,603,396 lb

Potline 5 Roof Monitor 423091 Aug‐08 TF 0.887 lbs/ton Al EPA M5 & 13B 9,603,396 lb

Potline 5 Roof Monitor 423091 Aug‐08 PM NA lbs/hr EPA M5 & 13B 9,603,396 lbPotline 5 Roof Monitor 423091 Nov‐09 HF 0.666 lbs/ton Al EPA M5 & 13B 9,341,810 lb

Potline 5 Roof Monitor 423091 Nov‐09 TF 0.965 lbs/ton Al EPA M5 & 13B 9,341,810 lb

Potline 5 Roof Monitor 423091 Nov‐09 PM NA lbs/hr EPA M5 & 13B 9,341,810 lb

Potline 5 Roof Monitor 423091 Feb‐09 HF 0.584 lbs/ton Al EPA M5 & 13B 8,226,524 lb

Potline 5 Roof Monitor 423091 Feb‐09 TF 0.975 lbs/ton Al EPA M5 & 13B 8,226,524 lb

Potline 5 Roof Monitor 423091 Feb‐09 PM NA lbs/hr EPA M5 & 13B 8,226,524 lb

Potlines 1 thru 4 Wet Scrubber 432001 Oct‐06 HF 0.826 lbs/ton Al EPA M5 & 13B 37,023,547 lb

Potlines 1 thru 4 Wet Scrubber 432001 Oct‐06 TF 1.049 lbs/ton Al EPA M5 & 13B 37,023,547 lb

Potlines 1 thru 4 Wet Scrubber 432001 Oct‐06 PM 46.5 lbs/hr EPA M5 & 13B 37,023,547 lb

Potlines 1 thru 4 Wet Scrubber 432001 Nov‐07 HF 0.359 lbs/ton Al EPA M5 & 13B 36,027,548 lb

Potlines 1 thru 4 Wet Scrubber 432001 Nov‐07 TF 0.639 lbs/ton Al EPA M5 & 13B 36,027,548 lb

Potlines 1 thru 4 Wet Scrubber 432001 Nov‐07 PM 52 lbs/hr EPA M5 & 13B 36,027,548 lb

Potlines 1 thru 4 Wet Scrubber 432001 Nov‐08 HF 0.247 lbs/ton Al EPA M5 & 13B 36,291,774 lb

Potlines 1 thru 4 Wet Scrubber 432001 Nov‐08 TF 0.61 lbs/ton Al EPA M5 & 13B 36,291,774 lb

Potlines 1 thru 4 Wet Scrubber 432001 Nov‐09 HF 0.228 lbs/ton Al EPA M5 & 13B 36,240,197 lb

Potlines 1 thru 4 Wet Scrubber 432001 Nov‐09 TF 0.993 lbs/ton Al EPA M5 & 13B 36,240,197 lb

Potlines 1 thru 4 Wet Scrubber 432001 May‐10 HF 0.562 lbs/ton Al EPA M5 & 13B 37,639,560 lb

Potlines 1 thru 4 Wet Scrubber 432001 May‐10 TF 0.76 lbs/ton Al EPA M5 & 13B 37,639,560 lb

Century Aluminum of KY 5/31/2011 
Attachment #6 ‐ Test Report Summary

Source

Control

Device Year Pollutant Emission Rate Emission Rate Units Test Method Production Rate Product

Un

Test Report Summary (Jan 2006 ‐ December 2010)

Potlines 1 thru 4 Wet Scrubber 432001 May‐10 PM 38.17 lbs/hr EPA M5 & 13B 37,639,560 lb

Potline 1 Roof Monitor 422092 Feb‐06 HF 0.251 lbs/ton Al EPA M14A & 13B 8,394,065 lb

Potline 1 Roof Monitor 422092 Feb‐06 TF 0.429 lbs/ton Al EPA M14A & 13B 8,394,065 lb

Potline 1 Roof Monitor 422092 Apr‐06 HF 0.461 lbs/ton Al EPA M14A & 13B 9,021,826 lb

Potline 1 Roof Monitor 422092 Apr‐06 TF 0.811 lbs/ton Al EPA M14A & 13B 9,021,826 lb

Potline 1 Roof Monitor 422092 Aug‐06 HF 0.771 lbs/ton Al EPA M14A & 13B 9,313,972 lb

Potline 1 Roof Monitor 422092 Aug‐06 TF 1.203 lbs/ton Al EPA M14A & 13B 9,313,972 lb

Potline 1 Roof Monitor 422092 Nov‐06 HF 0.363 lbs/ton Al EPA M14A & 13B 9,048,886 lb

Potline 1 Roof Monitor 422092 Nov‐06 TF 0.611 lbs/ton Al EPA M14A & 13B 9,048,886 lb

Potline 1 Roof Monitor 422092 Feb‐07 HF 0.173 lbs/ton Al EPA M14A & 13B 8,387,164 lb

Potline 1 Roof Monitor 422092 Feb‐07 TF 0.424 lbs/ton Al EPA M14A & 13B 8,387,164 lb

Potline 1 Roof Monitor 422092 Apr‐07 HF 0.268 lbs/ton Al EPA M14A & 13B 9,060,354 lb

Potline 1 Roof Monitor 422092 Apr‐07 TF 0.608 lbs/ton Al EPA M14A & 13B 9,060,354 lb

Potline 1 Roof Monitor 422092 Aug‐07 HF 0.803 lbs/ton Al EPA M14A & 13B 9,315,977 lb

Potline 1 Roof Monitor 422092 Aug‐07 TF 1.057 lbs/ton Al EPA M14A & 13B 9,315,977 lb

Potline 1 Roof Monitor 422092 Nov‐07 HF 0.539 lbs/ton Al EPA M14A & 13B 9,050,592 lb

Potline 1 Roof Monitor 422092 Nov‐07 TF 0.871 lbs/ton Al EPA M14A & 13B 9,050,592 lb

Potline 1 Roof Monitor 422092 Jan‐08 HF 0.483 lbs/ton Al EPA M14A & 13B 9,258,993 lb

Potline 1 Roof Monitor 422092 Jan‐08 TF 0.829 lbs/ton Al EPA M14A & 13B 9,258,993 lb

Potline 1 Roof Monitor 422092 May‐08 HF 0.558 lbs/ton Al EPA M14A & 13B 9,319,679 lb

Potline 1 Roof Monitor 422092 May‐08 TF 0.814 lbs/ton Al EPA M14A & 13B 9,319,679 lb

Potline 1 Roof Monitor 422092 Aug‐08 HF 0.896 lbs/ton Al EPA M14A & 13B 9,333,305 lb

Potline 1 Roof Monitor 422092 Aug‐08 TF 1.368 lbs/ton Al EPA M14A & 13B 9,333,305 lb

Potline 1 Roof Monitor 422092 Oct‐08 HF 0.498 lbs/ton Al EPA M14A & 13B 9,337,524 lb

Potline 1 Roof Monitor 422092 Oct‐08 TF 0.763 lbs/ton Al EPA M14A & 13B 9,337,524 lb

Potline 1 Roof Monitor 422092 Jan‐09 HF 0.402 lbs/ton Al EPA M14A & 13B 9,434,040 lb

Century Aluminum of KY 5/31/2011 
Attachment #6 ‐ Test Report Summary

Source

Control

Device Year Pollutant Emission Rate Emission Rate Units Test Method Production Rate Product

Un

Test Report Summary (Jan 2006 ‐ December 2010)

Potline 1 Roof Monitor 422092 Jan‐09 TF 0.635 lbs/ton Al EPA M14A & 13B 9,434,040 lb

Potline 1 Roof Monitor 422092 Apr‐09 HF 0.451 lbs/ton Al EPA M14A & 13B 9,114,243 lb

Potline 1 Roof Monitor 422092 Apr‐09 TF 0.606 lbs/ton Al EPA M14A & 13B 9,114,243 lb

Potline 1 Roof Monitor 422092 Jul‐09 HF 1.405 lbs/ton Al EPA M14A & 13B 8,342,343 lb

Potline 1 Roof Monitor 422092 Jul‐09 TF 1.744 lbs/ton Al EPA M14A & 13B 8,342,343 lb

Potline 1 Roof Monitor 422092 Nov‐09 HF 0.557 lbs/ton Al EPA M14A & 13B 9,087,068 lb

Potline 1 Roof Monitor 422092 Nov‐09 TF 0.896 lbs/ton Al EPA M14A & 13B 9,087,068 lb

Potline 1 Roof Monitor 422092 Jan‐10 HF 0.359 lbs/ton Al EPA M14A & 13B 9,402,407 lb

Potline 1 Roof Monitor 422092 Jan‐10 TF 0.659 lbs/ton Al EPA M14A & 13B 9,402,407 lb

Potline 1 Roof Monitor 422092 Apr‐10 HF 0.679 lbs/ton Al EPA M14A & 13B 9,048,054 lb

Potline 1 Roof Monitor 422092 Apr‐10 TF 0.932 lbs/ton Al EPA M14A & 13B 9,048,054 lb

Potline 1 Roof Monitor 422092 Jul‐10 HF 0.982 lbs/ton Al EPA M14A & 13B 9,270,439 lb

Potline 1 Roof Monitor 422092 Jul‐10 TF 1.265 lbs/ton Al EPA M14A & 13B 9,270,439 lb

Potline 1 Roof Monitor 422092 Oct‐10 HF 0.749 lbs/ton Al EPA M14A & 13B 9,503,051 lb

Potline 1 Roof Monitor 422092 Oct‐10 TF 1.13 lbs/ton Al EPA M14A & 13B 9,503,051 lb

Potline 2 Roof Monitor 422093 Feb‐06 HF 0.097 Lbs/ton Al EPA M14A & 13B 8,337,519 lb

Potline 2 Roof Monitor 422093 Feb‐06 TF 0.337 Lbs/ton Al EPA M14A & 13B 8,337,519 lb

Potline 2 Roof Monitor 422093 Apr‐06 HF 0.192 Lbs/ton Al EPA M14A & 13B 9,016,722 lb

Potline 2 Roof Monitor 422093 Apr‐06 TF 0.375 Lbs/ton Al EPA M14A & 13B 9,016,722 lb

Potline 2 Roof Monitor 422093 Aug‐06 HF 0.279 Lbs/ton Al EPA M14A & 13B 9,172,511 lb

Potline 2 Roof Monitor 422093 Aug‐06 TF 0.492 Lbs/ton Al EPA M14A & 13B 9,172,511 lb

Potline 2 Roof Monitor 422093 Nov‐06 HF 0.317 Lbs/ton Al EPA M14A & 13B 8,990,265 lb

Potline 2 Roof Monitor 422093 Nov‐06 TF 0.505 Lbs/ton Al EPA M14A & 13B 8,990,265 lb

Potline 2 Roof Monitor 422093 Feb‐07 HF 0.143 Lbs/ton Al EPA M14A & 13B 8,407,001 lb

Potline 2 Roof Monitor 422093 Feb‐07 TF 0.418 Lbs/ton Al EPA M14A & 13B 8,407,001 lb

Potline 2 Roof Monitor 422093 Apr‐07 HF 0.244 Lbs/ton Al EPA M14A & 13B 8,992,353 lb

Century Aluminum of KY 5/31/2011 
Attachment #6 ‐ Test Report Summary

Source

Control

Device Year Pollutant Emission Rate Emission Rate Units Test Method Production Rate Product

Un

Test Report Summary (Jan 2006 ‐ December 2010)

Potline 2 Roof Monitor 422093 Apr‐07 TF 0.566 Lbs/ton Al EPA M14A & 13B 8,992,353 lb

Potline 2 Roof Monitor 422093 Jul‐07 HF 0.427 Lbs/ton Al EPA M14A & 13B 9,300,375 lb

Potline 2 Roof Monitor 422093 Jul‐07 TF 0.699 Lbs/ton Al EPA M14A & 13B 9,300,375 lb

Potline 2 Roof Monitor 422093 Oct‐07 HF 0.582 Lbs/ton Al EPA M14A & 13B 9,334,209 lb

Potline 2 Roof Monitor 422093 Oct‐07 TF 0.715 Lbs/ton Al EPA M14A & 13B 9,334,209 lb

Potline 2 Roof Monitor 422093 Jan‐08 HF 0.351 Lbs/ton Al EPA M14A & 13B 9,261,038 lb

Potline 2 Roof Monitor 422093 Jan‐08 TF 0.586 Lbs/ton Al EPA M14A & 13B 9,261,038 lb

Potline 2 Roof Monitor 422093 Apr‐08 HF 0.568 Lbs/ton Al EPA M14A & 13B 8,988,276 lb

Potline 2 Roof Monitor 422093 Apr‐08 TF 0.795 Lbs/ton Al EPA M14A & 13B 8,988,276 lb

Potline 2 Roof Monitor 422093 Jul‐08 HF 0.69 Lbs/ton Al EPA M14A & 13B 9,311,302 lb

Potline 2 Roof Monitor 422093 Jul‐08 TF 0.888 Lbs/ton Al EPA M14A & 13B 9,311,302 lb

Potline 2 Roof Monitor 422093 Oct‐08 HF 0.537 Lbs/ton Al EPA M14A & 13B 9,366,721 lb

Potline 2 Roof Monitor 422093 Oct‐08 TF 0.792 Lbs/ton Al EPA M14A & 13B 9,366,721 lb

Potline 2 Roof Monitor 422093 Jan‐09 HF 0.328 Lbs/ton Al EPA M14A & 13B 9,381,867 lb

Potline 2 Roof Monitor 422093 Jan‐09 TF 0.488 Lbs/ton Al EPA M14A & 13B 9,381,867 lb

Potline 2 Roof Monitor 422093 Apr‐09 HF 0.279 Lbs/ton Al EPA M14A & 13B 8,930,475 lb

Potline 2 Roof Monitor 422093 Apr‐09 TF 0.373 Lbs/ton Al EPA M14A & 13B 8,930,475 lb

Potline 2 Roof Monitor 422093 Jul‐09 HF 1.066 Lbs/ton Al EPA M14A & 13B 8,453,845 lb

Potline 2 Roof Monitor 422093 Jul‐09 TF 1.42 Lbs/ton Al EPA M14A & 13B 8,453,845 lb

Potline 2 Roof Monitor 422093 Nov‐09 HF 0.415 Lbs/ton Al EPA M14A & 13B 9,116,768 lb

Potline 2 Roof Monitor 422093 Nov‐09 TF 0.636 Lbs/ton Al EPA M14A & 13B 9,116,768 lb

Potline 2 Roof Monitor 422093 Jan‐10 HF 0.403 Lbs/ton Al EPA M14A & 13B 9,452,528 lb

Potline 2 Roof Monitor 422093 Jan‐10 TF 0.967 Lbs/ton Al EPA M14A & 13B 9,452,528 lb

Potline 2 Roof Monitor 422093 Apr‐10 HF 0.936 Lbs/ton Al EPA M14A & 13B 9,121,963 lb

Potline 2 Roof Monitor 422093 Apr‐10 TF 1.259 Lbs/ton Al EPA M14A & 13B 9,121,963 lb

Potline 2 Roof Monitor 422093 Jul‐10 HF 0.845 Lbs/ton Al EPA M14A & 13B 9,205,953 lb

Potline 2 Roof Monitor 422093 Jul‐10 TF 1.19 Lbs/ton Al EPA M14A & 13B 9,205,953 lb

Century Aluminum of KY 5/31/2011 
Attachment #6 ‐ Test Report Summary

Source

Control

Device Year Pollutant Emission Rate Emission Rate Units Test Method Production Rate Product

Un

Test Report Summary (Jan 2006 ‐ December 2010)

Potline 2 Roof Monitor 422093 Oct‐10 HF 0.515 Lbs/ton Al EPA M14A & 13B 9,492,721 lb

Potline 2 Roof Monitor 422093 Oct‐10 TF 0.826 Lbs/ton Al EPA M14A & 13B 9,492,721 lb

Potline 3 Roof Monitor 422094 Jan‐06 HF 0.296 Lbs/ton Al EPA M14A & 13B 9,240,894 lb

Potline 3 Roof Monitor 422094 Jan‐06 TF 0.531 Lbs/ton Al EPA M14A & 13B 9,240,894 lb

Potline 3 Roof Monitor 422094 Feb‐06 HF 0.301 Lbs/ton Al EPA M14A & 13B 8,439,318 lb

Potline 3 Roof Monitor 422094 Feb‐06 TF 0.57 Lbs/ton Al EPA M14A & 13B 8,439,318 lb

Potline 3 Roof Monitor 422094 Mar‐06 HF 0.33 Lbs/ton Al EPA M14A & 13B 9,365,106 lb

Potline 3 Roof Monitor 422094 Mar‐06 TF 0.723 Lbs/ton Al EPA M14A & 13B 9,365,106 lb

Potline 3 Roof Monitor 422094 Apr‐06 HF 0.5 Lbs/ton Al EPA M14A & 13B 8,907,312 lb

Potline 3 Roof Monitor 422094 Apr‐06 TF 0.897 Lbs/ton Al EPA M14A & 13B 8,907,312 lb

Potline 3 Roof Monitor 422094 May‐06 HF 0.793 Lbs/ton Al EPA M14A & 13B 9,310,096 lb

Potline 3 Roof Monitor 422094 May‐06 TF 1.208 Lbs/ton Al EPA M14A & 13B 9,310,096 lb

Potline 3 Roof Monitor 422094 Jun‐06 HF 0.925 Lbs/ton Al EPA M14A & 13B 9,009,378 lb

Potline 3 Roof Monitor 422094 Jun‐06 TF 1.274 Lbs/ton Al EPA M14A & 13B 9,009,378 lb

Potline 3 Roof Monitor 422094 Jul‐06 HF 1.192 Lbs/ton Al EPA M14A & 13B 9,260,744 lb

Potline 3 Roof Monitor 422094 Jul‐06 TF 1.653 Lbs/ton Al EPA M14A & 13B 9,260,744 lb

Potline 3 Roof Monitor 422094 Aug‐06 HF 1.037 Lbs/ton Al EPA M14A & 13B 8,998,544 lb

Potline 3 Roof Monitor 422094 Aug‐06 TF 1.533 Lbs/ton Al EPA M14A & 13B 8,998,544 lb

Potline 3 Roof Monitor 422094 Sep‐06 HF 0.75 Lbs/ton Al EPA M14A & 13B 8,977,893 lb

Potline 3 Roof Monitor 422094 Sep‐06 TF 1.117 Lbs/ton Al EPA M14A & 13B 8,977,893 lb

Potline 3 Roof Monitor 422094 Oct‐06 HF 0.518 Lbs/ton Al EPA M14A & 13B 9,248,014 lb

Potline 3 Roof Monitor 422094 Oct‐06 TF 0.891 Lbs/ton Al EPA M14A & 13B 9,248,014 lb

Potline 3 Roof Monitor 422094 Nov‐06 HF 0.449 Lbs/ton Al EPA M14A & 13B 8,950,000 lb

Potline 3 Roof Monitor 422094 Nov‐06 TF 0.722 Lbs/ton Al EPA M14A & 13B 8,950,000 lb

Potline 3 Roof Monitor 422094 Dec‐06 HF 0.359 Lbs/ton Al EPA M14A & 13B 9,270,190 lb

Potline 3 Roof Monitor 422094 Dec‐06 TF 0.716 Lbs/ton Al EPA M14A & 13B 9,270,190 lb

Century Aluminum of KY 5/31/2011 
Attachment #6 ‐ Test Report Summary

Source

Control

Device Year Pollutant Emission Rate Emission Rate Units Test Method Production Rate Product

Un

Test Report Summary (Jan 2006 ‐ December 2010)

Potline 3 Roof Monitor 422094 Jan‐07 HF 0.314 Lbs/ton Al EPA M14A & 13B 9,333,483 lb

Potline 3 Roof Monitor 422094 Jan‐07 TF 0.579 Lbs/ton Al EPA M14A & 13B 9,333,483 lb

Potline 3 Roof Monitor 422094 Feb‐07 HF 0.231 Lbs/ton Al EPA M14A & 13B 8,314,080 lb

Potline 3 Roof Monitor 422094 Feb‐07 TF 0.631 Lbs/ton Al EPA M14A & 13B 8,314,080 lb

Potline 3 Roof Monitor 422094 Mar‐07 HF 0.681 Lbs/ton Al EPA M14A & 13B 9,281,269 lb

Potline 3 Roof Monitor 422094 Mar‐07 TF 1.22 Lbs/ton Al EPA M14A & 13B 9,281,269 lb

Potline 3 Roof Monitor 422094 Apr‐07 HF 0.453 Lbs/ton Al EPA M14A & 13B 8,825,347 lb

Potline 3 Roof Monitor 422094 Apr‐07 TF 0.817 Lbs/ton Al EPA M14A & 13B 8,825,347 lb

Potline 3 Roof Monitor 422094 May‐07 HF 0.585 Lbs/ton Al EPA M14A & 13B 9,262,696 lb

Potline 3 Roof Monitor 422094 May‐07 TF 0.983 Lbs/ton Al EPA M14A & 13B 9,262,696 lb

Potline 3 Roof Monitor 422094 Jun‐07 HF 0.723 Lbs/ton Al EPA M14A & 13B 8,958,417 lb

Potline 3 Roof Monitor 422094 Jun‐07 TF 1.16 Lbs/ton Al EPA M14A & 13B 8,958,417 lb

Potline 3 Roof Monitor 422094 Jul‐07 HF 0.585 Lbs/ton Al EPA M14A & 13B 9,311,870 lb

Potline 3 Roof Monitor 422094 Jul‐07 TF 0.99 Lbs/ton Al EPA M14A & 13B 9,311,870 lb

Potline 3 Roof Monitor 422094 Aug‐07 HF 0.707 Lbs/ton Al EPA M14A & 13B 9,338,292 lb

Potline 3 Roof Monitor 422094 Aug‐07 TF 0.962 Lbs/ton Al EPA M14A & 13B 9,338,292 lb

Potline 3 Roof Monitor 422094 Sep‐07 HF 0.874 Lbs/ton Al EPA M14A & 13B 8,980,225 lb

Potline 3 Roof Monitor 422094 Sep‐07 TF 1.293 Lbs/ton Al EPA M14A & 13B 8,980,225 lb

Potline 3 Roof Monitor 422094 Oct‐07 HF 0.769 Lbs/ton Al EPA M14A & 13B 9,263,708 lb

Potline 3 Roof Monitor 422094 Oct‐07 TF 1.023 Lbs/ton Al EPA M14A & 13B 9,263,708 lb

Potline 3 Roof Monitor 422094 Nov‐07 HF 0.732 Lbs/ton Al EPA M14A & 13B 9,018,467 lb

Potline 3 Roof Monitor 422094 Nov‐07 TF 1.084 Lbs/ton Al EPA M14A & 13B 9,018,467 lb

Potline 3 Roof Monitor 422094 Dec‐07 HF 0.584 Lbs/ton Al EPA M14A & 13B 9,163,044 lb

Potline 3 Roof Monitor 422094 Dec‐07 TF 1.04 Lbs/ton Al EPA M14A & 13B 9,163,044 lb

Potline 3 Roof Monitor 422094 Jan‐08 HF 0.738 Lbs/ton Al EPA M14A & 13B 9,187,681 lb

Potline 3 Roof Monitor 422094 Jan‐08 TF 1.113 Lbs/ton Al EPA M14A & 13B 9,187,681 lb

Potline 3 Roof Monitor 422094 Feb‐08 HF 0.38 Lbs/ton Al EPA M14A & 13B 8,700,798 lb

Century Aluminum of KY 5/31/2011 
Attachment #6 ‐ Test Report Summary

Source

Control

Device Year Pollutant Emission Rate Emission Rate Units Test Method Production Rate Product

Un

Test Report Summary (Jan 2006 ‐ December 2010)

Potline 3 Roof Monitor 422094 Feb‐08 TF 0.629 Lbs/ton Al EPA M14A & 13B 8,700,798 lb

Potline 3 Roof Monitor 422094 Mar‐08 HF 0.346 Lbs/ton Al EPA M14A & 13B 9,262,713 lb

Potline 3 Roof Monitor 422094 Mar‐08 TF 0.566 Lbs/ton Al EPA M14A & 13B 9,262,713 lb

Potline 3 Roof Monitor 422094 Apr‐08 HF 0.554 Lbs/ton Al EPA M14A & 13B 9,008,783 lb

Potline 3 Roof Monitor 422094 Apr‐08 TF 0.862 Lbs/ton Al EPA M14A & 13B 9,008,783 lb

Potline 3 Roof Monitor 422094 May‐08 HF 0.854 Lbs/ton Al EPA M14A & 13B 9,281,107 lb

Potline 3 Roof Monitor 422094 May‐08 TF 1.274 Lbs/ton Al EPA M14A & 13B 9,281,107 lb

Potline 3 Roof Monitor 422094 Jun‐08 HF 0.984 Lbs/ton Al EPA M14A & 13B 8,976,608 lb

Potline 3 Roof Monitor 422094 Jun‐08 TF 1.359 Lbs/ton Al EPA M14A & 13B 8,976,608 lb

Potline 3 Roof Monitor 422094 Jul‐08 HF 1.066 Lbs/ton Al EPA M14A & 13B 9,351,166 lb

Potline 3 Roof Monitor 422094 Jul‐08 TF 1.427 Lbs/ton Al EPA M14A & 13B 9,351,166 lb

Potline 3 Roof Monitor 422094 Aug‐08 HF 0.697 Lbs/ton Al EPA M14A & 13B 9,290,320 lb

Potline 3 Roof Monitor 422094 Aug‐08 TF 1.17 Lbs/ton Al EPA M14A & 13B 9,290,320 lb

Potline 3 Roof Monitor 422094 Sep‐08 HF 0.763 Lbs/ton Al EPA M14A & 13B 9,065,654 lb

Potline 3 Roof Monitor 422094 Sep‐08 TF 1.03 Lbs/ton Al EPA M14A & 13B 9,065,654 lb

Potline 3 Roof Monitor 422094 Oct‐08 HF 0.566 Lbs/ton Al EPA M14A & 13B 9,332,936 lb

Potline 3 Roof Monitor 422094 Oct‐08 TF 0.985 Lbs/ton Al EPA M14A & 13B 9,332,936 lb

Potline 3 Roof Monitor 422094 Nov‐08 HF 0.396 Lbs/ton Al EPA M14A & 13B 9,081,217 lb

Potline 3 Roof Monitor 422094 Nov‐08 TF 0.809 Lbs/ton Al EPA M14A & 13B 9,081,217 lb

Potline 3 Roof Monitor 422094 Dec‐08 HF 0.225 Lbs/ton Al EPA M14A & 13B 9,450,350 lb

Potline 3 Roof Monitor 422094 Dec‐08 TF 0.506 Lbs/ton Al EPA M14A & 13B 9,450,350 lb

Potline 3 Roof Monitor 422094 Jan‐09 HF 0.235 Lbs/ton Al EPA M14A & 13B 9,367,079 lb

Potline 3 Roof Monitor 422094 Jan‐09 TF 0.56 Lbs/ton Al EPA M14A & 13B 9,367,079 lb

Potline 3 Roof Monitor 422094 Feb‐09 HF 0.225 Lbs/ton Al EPA M14A & 13B 8,430,487 lb

Potline 3 Roof Monitor 422094 Feb‐09 TF 0.477 Lbs/ton Al EPA M14A & 13B 8,430,487 lb

Potline 3 Roof Monitor 422094 Mar‐09 HF 0.238 Lbs/ton Al EPA M14A & 13B 9,268,900 lb

Potline 3 Roof Monitor 422094 Mar‐09 TF 0.406 Lbs/ton Al EPA M14A & 13B 9,268,900 lb

Century Aluminum of KY 5/31/2011 
Attachment #6 ‐ Test Report Summary

Source

Control

Device Year Pollutant Emission Rate Emission Rate Units Test Method Production Rate Product

Un

Test Report Summary (Jan 2006 ‐ December 2010)

Potline 3 Roof Monitor 422094 Apr‐09 HF 0.401 Lbs/ton Al EPA M14A & 13B 8,790,104 lb

Potline 3 Roof Monitor 422094 Apr‐09 TF 0.575 Lbs/ton Al EPA M14A & 13B 8,790,104 lb

Potline 3 Roof Monitor 422094 May‐09 HF 0.55 Lbs/ton Al EPA M14A & 13B 8,988,942 lb

Potline 3 Roof Monitor 422094 May‐09 TF 0.788 Lbs/ton Al EPA M14A & 13B 8,988,942 lb

Potline 3 Roof Monitor 422094 Jun‐09 HF 0.776 Lbs/ton Al EPA M14A & 13B 8,447,647 lb

Potline 3 Roof Monitor 422094 Jun‐09 TF 1.08 Lbs/ton Al EPA M14A & 13B 8,447,647 lb

Potline 3 Roof Monitor 422094 Jul‐09 HF 0.967 Lbs/ton Al EPA M14A & 13B 8,444,381 lb

Potline 3 Roof Monitor 422094 Jul‐09 TF 1.218 Lbs/ton Al EPA M14A & 13B 8,444,381 lb

Potline 3 Roof Monitor 422094 Aug‐09 HF 0.706 Lbs/ton Al EPA M14A & 13B 8,587,985 lb

Potline 3 Roof Monitor 422094 Aug‐09 TF 0.966 Lbs/ton Al EPA M14A & 13B 8,587,985 lb

Potline 3 Roof Monitor 422094 Sep‐09 HF 0.687 Lbs/ton Al EPA M14A & 13B 8,622,863 lb

Potline 3 Roof Monitor 422094 Sep‐09 TF 0.91 Lbs/ton Al EPA M14A & 13B 8,622,863 lb

Potline 3 Roof Monitor 422094 Oct‐09 HF 1.098 Lbs/ton Al EPA M14A & 13B 9,251,317 lb

Potline 3 Roof Monitor 422094 Oct‐09 TF 1.657 Lbs/ton Al EPA M14A & 13B 9,251,317 lb

Potline 3 Roof Monitor 422094 Nov‐09 HF 0.626 Lbs/ton Al EPA M14A & 13B 8,952,631 lb

Potline 3 Roof Monitor 422094 Nov‐09 TF 1.024 Lbs/ton Al EPA M14A & 13B 8,952,631 lb

Potline 3 Roof Monitor 422094 Dec‐09 HF 0.393 Lbs/ton Al EPA M14A & 13B 9,506,696 lb

Potline 3 Roof Monitor 422094 Dec‐09 TF 0.824 Lbs/ton Al EPA M14A & 13B 9,506,696 lb

Potline 3 Roof Monitor 422094 Jan‐10 HF 0.541 Lbs/ton Al EPA M14A & 13B 9,453,388 lb

Potline 3 Roof Monitor 422094 Jan‐10 TF 1.152 Lbs/ton Al EPA M14A & 13B 9,453,388 lb

Potline 3 Roof Monitor 422094 Feb‐10 HF 0.483 Lbs/ton Al EPA M14A & 13B 8,594,939 lb

Potline 3 Roof Monitor 422094 Feb‐10 TF 1.007 Lbs/ton Al EPA M14A & 13B 8,594,939 lb

Potline 3 Roof Monitor 422094 Mar‐10 HF 0.698 Lbs/ton Al EPA M14A & 13B 9,508,437 lb

Potline 3 Roof Monitor 422094 Mar‐10 TF 1.279 Lbs/ton Al EPA M14A & 13B 9,508,437 lb

Potline 3 Roof Monitor 422094 Apr‐10 HF 0.733 Lbs/ton Al EPA M14A & 13B 9,165,538 lb

Potline 3 Roof Monitor 422094 Apr‐10 TF 0.991 Lbs/ton Al EPA M14A & 13B 9,165,538 lb

Potline 3 Roof Monitor 422094 May‐10 HF 0.762 Lbs/ton Al EPA M14A & 13B 9,429,889 lb

Century Aluminum of KY 5/31/2011 
Attachment #6 ‐ Test Report Summary

Source

Control

Device Year Pollutant Emission Rate Emission Rate Units Test Method Production Rate Product

Un

Test Report Summary (Jan 2006 ‐ December 2010)

Potline 3 Roof Monitor 422094 May‐10 TF 0.956 Lbs/ton Al EPA M14A & 13B 9,429,889 lb

Potline 3 Roof Monitor 422094 Jun‐10 HF 0.755 Lbs/ton Al EPA M14A & 13B 9,133,322 lb

Potline 3 Roof Monitor 422094 Jun‐10 TF 1.302 Lbs/ton Al EPA M14A & 13B 9,133,322 lb

Potline 3 Roof Monitor 422094 Jul‐10 HF 0.955 Lbs/ton Al EPA M14A & 13B 9,388,120 lb

Potline 3 Roof Monitor 422094 Jul‐10 TF 1.384 Lbs/ton Al EPA M14A & 13B 9,388,120 lb

Potline 3 Roof Monitor 422094 Aug‐10 HF 0.766 Lbs/ton Al EPA M14A & 13B 9,464,384 lb

Potline 3 Roof Monitor 422094 Aug‐10 TF 1.07 Lbs/ton Al EPA M14A & 13B 9,464,384 lb

Potline 3 Roof Monitor 422094 Sep‐10 HF 0.815 Lbs/ton Al EPA M14A & 13B 9,186,359 lb

Potline 3 Roof Monitor 422094 Sep‐10 TF 1.062 Lbs/ton Al EPA M14A & 13B 9,186,359 lb

Potline 3 Roof Monitor 422094 Oct‐10 HF 0.575 Lbs/ton Al EPA M14A & 13B 9,536,447 lb

Potline 3 Roof Monitor 422094 Oct‐10 TF 0.894 Lbs/ton Al EPA M14A & 13B 9,536,447 lb

Potline 3 Roof Monitor 422094 Nov‐10 HF 0.444 Lbs/ton Al EPA M14A & 13B 9,138,227 lb

Potline 3 Roof Monitor 422094 Nov‐10 TF 0.725 Lbs/ton Al EPA M14A & 13B 9,138,227 lb

Potline 3 Roof Monitor 422094 Dec‐10 HF 0.463 Lbs/ton Al EPA M14A & 13B 9,533,763 lb

Potline 3 Roof Monitor 422094 Dec‐10 TF 0.929 Lbs/ton Al EPA M14A & 13B 9,533,763 lb

Potline 4 Roof Monitor 422088 Feb‐06 HF 0.201 Lbs/ton Al EPA M14 & 13B 8,463,582 lb

Potline 4 Roof Monitor 422088 Feb‐06 TF 0.424 Lbs/ton Al EPA M14 & 13B 8,463,582 lb

Potline 4 Roof Monitor 422088 Apr‐06 HF 0.306 Lbs/ton Al EPA M14 & 13B 8,982,254 lb

Potline 4 Roof Monitor 422088 Apr‐06 TF 0.465 Lbs/ton Al EPA M14 & 13B 8,982,254 lb

Potline 4 Roof Monitor 422088 Aug‐06 HF 0.616 Lbs/ton Al EPA M14 & 13B 9,321,359 lb

Potline 4 Roof Monitor 422088 Aug‐06 TF 0.942 Lbs/ton Al EPA M14 & 13B 9,321,359 lb

Potline 4 Roof Monitor 422088 Nov‐06 HF 0.361 Lbs/ton Al EPA M14 & 13B 8,840,183 lb

Potline 4 Roof Monitor 422088 Nov‐06 TF 0.709 Lbs/ton Al EPA M14 & 13B 8,840,183 lb

Potline 4 Roof Monitor 422088 Jan‐07 HF 0.225 Lbs/ton Al EPA M14 & 13B 9,352,799 lb

Potline 4 Roof Monitor 422088 Jan‐07 TF 0.567 Lbs/ton Al EPA M14 & 13B 9,352,799 lb

Potline 4 Roof Monitor 422088 Apr‐07 HF 0.311 Lbs/ton Al EPA M14 & 13B 9,073,923 lb

Century Aluminum of KY 5/31/2011 
Attachment #6 ‐ Test Report Summary

Source

Control

Device Year Pollutant Emission Rate Emission Rate Units Test Method Production Rate Product

Un

Test Report Summary (Jan 2006 ‐ December 2010)

Potline 4 Roof Monitor 422088 Apr‐07 TF 0.55 Lbs/ton Al EPA M14 & 13B 9,073,923 lb

Potline 4 Roof Monitor 422088 Aug‐07 HF 0.28 Lbs/ton Al EPA M14 & 13B 9,301,751 lb

Potline 4 Roof Monitor 422088 Aug‐07 TF 0.404 Lbs/ton Al EPA M14 & 13B 9,301,751 lb

Potline 4 Roof Monitor 422088 Oct‐07 HF 0.485 Lbs/ton Al EPA M14 & 13B 9,203,666 lb

Potline 4 Roof Monitor 422088 Oct‐07 TF 0.696 Lbs/ton Al EPA M14 & 13B 9,203,666 lb

Potline 4 Roof Monitor 422088 Jan‐08 HF 0.417 Lbs/ton Al EPA M14 & 13B 9,280,085 lb

Potline 4 Roof Monitor 422088 Jan‐08 TF 0.649 Lbs/ton Al EPA M14 & 13B 9,280,085 lb

Potline 4 Roof Monitor 422088 Apr‐08 HF 0.453 Lbs/ton Al EPA M14 & 13B 8,970,316 lb

Potline 4 Roof Monitor 422088 Apr‐08 TF 0.662 Lbs/ton Al EPA M14 & 13B 8,970,316 lb

Potline 4 Roof Monitor 422088 Aug‐08 HF 0.364 Lbs/ton Al EPA M14 & 13B 9,366,612 lb

Potline 4 Roof Monitor 422088 Aug‐08 TF 0.534 Lbs/ton Al EPA M14 & 13B 9,366,612 lb

Potline 4 Roof Monitor 422088 Nov‐08 HF 0.175 Lbs/ton Al EPA M14 & 13B 9,029,139 lb

Potline 4 Roof Monitor 422088 Nov‐08 TF 0.355 Lbs/ton Al EPA M14 & 13B 9,029,139 lb

Potline 4 Roof Monitor 422088 Feb‐09 HF 0.253 Lbs/ton Al EPA M14 & 13B 8,388,613 lb

Potline 4 Roof Monitor 422088 Feb‐09 TF 0.487 Lbs/ton Al EPA M14 & 13B 8,388,613 lb

Potline 4 Roof Monitor 422088 Apr‐09 HF 0.186 Lbs/ton Al EPA M14 & 13B 8,872,047 lb

Potline 4 Roof Monitor 422088 Apr‐09 TF 0.35 Lbs/ton Al EPA M14 & 13B 8,872,047 lb

Potline 4 Roof Monitor 422088 Jul‐09 HF 0.347 Lbs/ton Al EPA M14 & 13B 8,300,016 lb

Potline 4 Roof Monitor 422088 Jul‐09 TF 0.562 Lbs/ton Al EPA M14 & 13B 8,300,016 lb

Potline 4 Roof Monitor 422088 Oct‐09 HF 0.168 Lbs/ton Al EPA M14 & 13B 9,416,024 lb

Potline 4 Roof Monitor 422088 Oct‐09 TF 0.327 Lbs/ton Al EPA M14 & 13B 9,416,024 lb

Potline 4 Roof Monitor 422088 Jan‐10 HF 0.425 Lbs/ton Al EPA M14 & 13B 9,460,466 lb

Potline 4 Roof Monitor 422088 Jan‐10 TF 0.866 Lbs/ton Al EPA M14 & 13B 9,460,466 lb

Potline 4 Roof Monitor 422088 Apr‐10 HF 0.54 Lbs/ton Al EPA M14 & 13B 9,174,029 lb

Potline 4 Roof Monitor 422088 Apr‐10 TF 0.723 Lbs/ton Al EPA M14 & 13B 9,174,029 lb

Potline 4 Roof Monitor 422088 Jul‐10 HF 0.543 Lbs/ton Al EPA M14 & 13B 9,407,850 lb

Potline 4 Roof Monitor 422088 Jul‐10 TF 0.735 Lbs/ton Al EPA M14 & 13B 9,407,850 lb

Century Aluminum of KY 5/31/2011 
Attachment #6 ‐ Test Report Summary

Source

Control

Device Year Pollutant Emission Rate Emission Rate Units Test Method Production Rate Product

Un

Test Report Summary (Jan 2006 ‐ December 2010)

Potline 4 Roof Monitor 422088 Oct‐10 HF 0.807 Lbs/ton Al EPA M14 & 13B 9,544,149 lb

Potline 4 Roof Monitor 422088 Oct‐10 TF 1.091 Lbs/ton Al EPA M14 & 13B 9,544,149 lb

Century Aluminum of KY 5/31/2011 
Attachment #8