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

EnclosuresEnclosure 1

Primary Aluminum Reduction Section 114 Enclosure 1 - April 22, 2011 Page 1 of 20 Facility Questionnaire for Prim ary Aluminum Reduction Plants 1,2

Please provide the information requested in the following forms. Use additional copies of the survey forms for additional facili ties, as needed, for your response.

This request for information is divided into four parts to be comp leted 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 comple te 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 form s as electronic files in

Microsoft® Word format. Please add additional rows to the tabl es 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 techni cal 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 curr ent Title V operating permit and any pending Title V operating permit modification applicat ions (pdf files are preferred).

Attachment #1

7. Please provide a copy of the faci lity schematic showing all of the primary aluminum operations that are subject to 40 CFR Part 63, Subpart LL. Pl ease include the control device ID numbers in the facility schematic.

Attachment #2Enclosure 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 y ear) 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 w hy application of an em ission standard to the pitch storage tank(s) is not practic able 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 fe asible. In our specific case, the projected

emissions of polycyclic organic matter from th ese 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 pr oduction 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 ro ws 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 numbe r, 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 ope nings (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 sy stem 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)(4 2)(4220), (84)(42)(4230), (84)(42)(4240), and (84)(42)(4250) are shielded w ith side shields and end doors at all times that work is not being performed on the pots. This comprise s 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 m easured 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 spec ifications provided to pitch suppliers, if applicable

2.2% - Typical sulfur content of cokeEnclosure 1

Primary Aluminum Reduction Section 114 Enclosure 1 - April 22, 2011 Page 6 of 20 3.0% - Maximum sulfur content of c oke cited in specifications pr ovided 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) supplie s your facility with the raw materials used in paste production? Please s ubmit 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 polluti on control device(s) controlling emissions from the pitch storage tanks, the paste plant, the anod e bake furnaces, and/or the potlines at this facility using Tables 1, 2, 3, 4, and/or 5, as a ppropriate. Please use th e same ID numbers as were assigned in the schematic pr ovided in response to question 7.

b. Does your operating permit include limits fo r 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 highe r 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 in clude any copies of pending permit applications as requested in

item 6 in Part A.

d. Please indicate below all emi ssion controls that were insta lled 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 number s 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 fa cility (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. Shie lding audit, replacemen t, 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 seve ral identical control devices

are used to control a given emission source): Multiple devices in series consisting of multiple cyclones, electrostatic precipitators, and wet scr ubber spray towers. ID# 432001

2. Stack or vent location of each control device (use NAD83 and include si x 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 c oncentration (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 = Engineer ing 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. H 2 O)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 cont rol 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 c ontrol 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. H 2 O) 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. Alternativ ely, attach the results of the analyses. Do not include results from the Toxicity Char acteristic 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 seve ral 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 si x 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 c oncentration (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 = Engineer ing 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 sc rubber °F outlet from bag house 200 °FEnclosure 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. H 2 O)

Across bag house: 8 to 9 inches water column (in. H 2 O)

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 c ontrol 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. H 2 O) >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 seve ral 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 si x 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 c oncentration (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 = Engineer ing 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 pressureEnclosure 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. H 2 O)

Across bag house: 8 to 9 inches water column (in. H 2 O)

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 c ontrol 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. H 2 O) >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 seve ral identical control devices

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

2. Stack or vent location of each control devi ce (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 c oncentration (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 = Engineer ing 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 sc rubber °F outlet from bag house °FEnclosure 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. H 2 O)

Across bag house: 5 to 7 inches water column (in. H 2 O)

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 c ontrol 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. H 2 O)

>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 20Enclosure 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 seve ral 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 si x 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 c oncentration (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 = Engineer ing 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: __________ ft 2Enclosure 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 c ontrol 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. Altern atively, 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 seve ral identical control devices are used to control a given em ission source): Not applicable

2. Stack or vent location of each control device (use NAD83 and include si x 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 c oncentration (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 = Engineer ing 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. H 2 O)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 c ontrol device are monitored to ensure that the control device is operating properly:

_______ Volumetric flow rate ____________ Fan amperage

_______ Visible emissions opaci ty ____________ Pressure drop

Other (specify): .

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

_______ Volumetric flow rate (acf m) ____________ Fan amperage (amps)

_______ Visible emissions opacity (%) ____________ Pressure drop (in. H 2 O)

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. Alternativ ely, attach the results of the analyses. Do not include results from the Toxicity Char acteristic 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 seve ral identical control devices are used to control a given em ission source): Not applicable

2. Stack or vent location of each control device (use NAD83 and include si x 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 c oncentration (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 = Engineer ing 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: inle t °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 c ontrol 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. H 2 O)

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. Alterna tively, attach the results of the analyses. Do not include results from the Toxicity Char acteristic 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 po tline, not of an individual pot (e.g. after anode changes).

16. Please provide a rationale, if applicable, for w hy application of the Subpart LL standards to a potline during start-up or shutdown is not pr acticable economically or technologically

Not practicable economically: Collecting Method 14 or 14A samp les representative of an the entire potline is not economically practicable b ecause this would requir e the installation and operation of 12 or 13 separate Reference Method sampling systems in each potroom to collect representative compliance samples. These sa mpling systems typically cost more than $250,000

each to install and this le vel of expenditure is not practicable fo r 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 sm elting 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 po tline startup, pots located under a Method 14 or 14A sampling system do not repr esent the entire potline becaus e pots throughout the room are in various stages of startup or non-st eady-state operation. It is not technically practicable to either establish a standard for startup or show compliance with a start up standard using the available

EPA Reference Method. Establishi ng a standard for startups is further complicated by the fact that startups are rare and th e conditions of a startup (and a ssociated 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 re gulating 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 emi ssions 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 #5Enclosure 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 A lways, S ometimes, or N ever.

__ A ___ a. Develop a potroom/potline st art-up schedule before start-up

__ A ___ b. Perform daily assessment of star t-up progress and any schedule changes

__ A ___ c. Keep records of number of pots started per day

___ A __ d. Bring potroom/potline scrubbers and e xhaust fans on line prior to energizing

first cell to be restarted

__ N ___ e. Supply alumina at a higher ra te than during normal pot operation

If so, how much higher? ____________(percent)

__ A ___ f. Keep pots cove red 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 st art-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 anod e 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. NAEnclosure 1

Primary Aluminum Reduction Section 114 Enclosure 1 - April 22, 2011 Page 25 of 20 Table 6 Description of most recent potline st art-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 PERFORME D TESTING AND TEST REPORT DATA

21. Submit emission test report results for cal endar year 2010 for polycyclic organic matter (POM) and total fluorides (TF) for any sour ces 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 presen t 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 (C OS) for primary aluminum sources that currently do not have emission standard s for those pollutant s 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 mini mum) 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 a nd pitch used in the anodes at the time the testing was conducted, and

(e) A statement that the process and any c ontrol devices were op erating normally during the test, or if not, identify any a bnormal 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 PO M from prebake potlines, emissions of POM from existing pitch storage tanks, and/or emissi ons of COS, please also include test reports, if available, including the information specifi ed in 21(a) through (e), for the most recent emission testing that was performed before th ese controls were inst alled or upgraded and identify them as “pre-MACT test reports.”

Nothing found.

23. Has any air monitoring, such as Fourier Tr ansform Infrared (FTIR) spectroscopy, been performed at your facility to measure COS c oncentration and/or emissions of sulfur oxides? If so, please provide the most re cent data for a normal operating time period. Please include a description of the locatio ns of sampling (reference the schematic submitted in response to question 7), sampli ng technique, duration of sampling, production rate during sampling, and potroom operations performed during the sampling.

No

24. Has any air monitoring, such as FTIR spect roscopy, 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 re cent 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 locatio ns of sampling (reference the schematic submitted in response to question 7), sampli ng 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, 1 st Floor Frankfort, Kentucky 40601 (502) 564-3999 

# FINAL

AIR QUALITY PERMIT

Issued under 401 KAR 52:020

Permittee Name: Century Alum inum 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 OPER ATING CONDITIONS Renewal 2

C INSIGNIFICANT ACTIVITIES Renewal 47

D SOURCE EMISSION LIMI TATIONS AND TESTING REQUIREMENTS Renewal 49

E SOURCE CONTROL EQUIPMEN T 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 1 2/15/20 09 Permit Renewal / PSD
Modification

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

SECTION A – PERMIT AUTHORIZATION

Pursuant to a duly submitted applica tion the Kentucky Division for Air Qualit y (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 Kent ucky Revised Statutes (KRS) Chapter 224 and regulations promulgated pursuant thereto.

The permittee shall not construct, reconstruct, or m odify any affected facilitie s 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 fr om the responsibility of obt aining any other permits, licenses, or approvals required by the Kentucky Energy and Environmen t Cabinet (Cabinet) or any other federal, state, or local agency.

Century Aluminum of Kentucky, and the adjacent S outhwire 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 de terioration 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 permitt ee is responsible and liable for their own violations unless there is a joint cause for the violations.

Definitions: The following definitions apply to all abbr eviations and variables used in this permit: AAQS – Ambient air quality standards

BACT – Best availabl e control technology

CB – Carbon bake

CO – Carbon monoxide CWPB3 – Center-worked preb ake three potline process

Division – Kent ucky 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 Standa rds for Hazardous Air Pollutants

NO

x – Nitrogen Oxides

PM – Particulate Matter

PM 10 – Particulate Matter equal to or smaller than 10 micrometers PMACT – NESHAP for Primary Aluminum Re duction Plants, also referred to as “PMACT’ (40 CFR 63, Subpart LL) PSD – Prevention of Significant De terioration of air quality

PTE – Potential to Emit

SO 2 – Sulfur dioxide

TF – Total Fluoride VOC – Volatile Organic Compounds

PM/PM 10 _ PM and PM 10 standards are the same except as noted

PM 2.5 /PM 10 _ PM 10 and PM 2.5 standards are the same except as noted POM _ polycyclic organic matterPermit 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/

PM 10 Operation Limits (Tons/Year)

E MISSION G ROUP 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- N ozzle 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

AluminaPermit 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/ PM 10 Operation Limits (Tons/Year)

E MISSION G ROUP 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

E MISSION G ROUP 33 N G ROUP 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 aluminaPermit 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/ PM 10 Operation Limits (Tons/Year)

E MISSION G ROUP 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 PM 10 = 0.069630

PM= 0.1090 1,326 tons packing coke dust 48 33 0330 1969 Bin, Baked Anode Dust,

CB2 Vents inside Building PM 10 = 0.051776

PM

= 0.0810 986 tons packing

coke dust

E MISSION G ROUP 34
56 34 2016 1969 Saw, Stub Cut-Off Cyclone

342838 PM 10 =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 gasPermit 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/

PM 10 Operation Limits (Tons/Year)

E MISSION G ROUP 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

E MISSION G ROUP 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 Transf er Point & Receiver Bin, 7.5 ton, Crushed Bath (43) DC 430051 0.000051 45,000 tons

crushed bathPermit 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/ PM 10 Operation Limits (Tons/Year)

E MISSION G ROUP 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) PM 10 =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

E MISSION G ROUP 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 bathPermit 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 constr ucted 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/PM 10 ) of 401 KAR 59:010 and

61:020

1. Operating Limitations :

a) Operational limits listed in the above tables ar e based upon a 12-month rolling total and shall not be exceeded (self-imposed).

b) The baghouses and other control equipment liste d in the above table sh all be maintained and operated in accordance with the Pr eventive Maintenance Plan .

2. Emission Limitations :

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

1) Visible emissions shall not e qual 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 tim e shall not exceed the self-imposed PM/PM 10 emission rates as listed above.

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

1) Visible emissions shall not e qual 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 minimu m specified time shall not exceed the selfimposed PM/PM 10 emission rates as listed above.

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

shall follow the Preventive Maintain ance Plan for baghouses. If the em issions 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 a nd 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 assuran ce that the visible emission limita tions 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 Prev entive Maintainance Plan. Excursions from the requirements of the Preventive Maintainance Plan sh all be corrected within 24 hours; additional time may be granted for just cause.

5. Specific Recordkeeping Requirements :

a) Emission units that have a combined proce ss throughput rate limit sh all be added together.

b) Records shall be maintained of the weekly qua litative visual observatio n, Method 9 observation if performed, monthly amounts and t ypes of process weight, excurs ions from visible emission limitations, and any measures taken to comply with the Preventive Maintainance Plan.

6. Specific Reporting Requirements :

a) Any exceedance over the individua l operational (throughput) limits shall be reported to the Division within thirty days after the exceedance. 1) Following initial notification of a throughput ex ceedance, 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 th e individual emission units monthly average and 12-

month PM/PM 10 emissions to show compliance with any self-imposed limit. 3) Monthly reports shall be submitted until ther e have been 12 consecutive months without any

exceedance of limits.

b) The permittee shall also certify to the Division, annually, that the specified reco rds 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 Regi onal Office a corrective action plan for the Division’s approva l on form DEP7007BB, no later than 30 days from the second

exceedance.

c) The permittee shall cert ify 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 tabl e 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:

NonePermit 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)

E MISSION G ROUP 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

E MISSION G ROUP 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

E MISSION G ROUP 33
- 33 0056 1969 Cleaning, Baked Anode 235,200 tons baked anodes

E MISSION G ROUP 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 buttsPermit 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)

E MISSION G ROUP 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

E MISSION G ROUP 44
- 44 0004 1998 Metal Purification Unit 316,000 tons aluminum - 44 0500 2002 Cleaner, Crucible (45) 8,000 tons bath

E MISSION G ROUP 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, Sec tion 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 equipm ent or erosion by water; and 4) The installation and use of hoods, fans, and fabr ic 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 emissi ons 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 fug itive dust emissions will not be visible beyond the plant’s property the permittee shall monitor the c onditions 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 r easonable precaution taken to prevent fugitive dust from becoming airborne.

6. Specific Reporting Requirements:

If more than two excursions occur in any ro lling six months, the permittee shall submit to the Division’s Owensboro Regional Offi ce 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 :

NonePermit 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)

E MISSION G ROUP 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

*NO

x – 0.0813

PM 10 – 80.234

PM – 138.33

SO 2 – 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

*NO

x – 0.001

PM 10 – 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

*NO

x – 0.001

PM 10 – 11.956

PM – 20.614

SO 2 – 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

*NO

x – 0.001

PM 10 – 11.956

PM – 20.614

SO 2 – 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

*NO

x – 0.001

PM 10 – 11.956

PM – 20.614

SO 2 – see emission

limitations

*VOC – 0.785 62,500 tons

aluminum produced

* VOC and NO

x limits are Synthetic Minor LimitsPermit 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 signifi cant deterioration of air quality

1. Operating Limitations :

The following operational limits ar e to meet BACT and protect NAAQS:

a) Maximum 12-month rolling total aluminum pro duction 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 th e standard ASTM method, an approved alternative method, or by vendor Certificate of Analysis.

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

percent.

d) The permittee shall follow good design and combus tion practices for the potlines to control CO emissions. The standard operating procedures fo r following the good operational procedures shall be kept available at site for inspection. Reco rds 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 40 1 KAR 53:010, the permittee shall not allow the

emissions of total fluorides to ex ceed 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 em ission 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 m onthly individual emissions of TF:

E TF = (C s1 x Q sd ) 1 + (C s2 x Q sd ) 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:

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

− C s1 is the concentration of total fluorides from the primary control system in mg/dscf

− Q sd is the volumetric flow rate of efflue nt gas corresponding to the appropriate subscript location in dscf/hr

− C s2 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 primar y control system effluent gas

− 2 denotes the subscript for th e roof monitor effluent gas

ii) The aluminum production rate (P ) shall be determined by dividi ng 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 performan ce 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 av erage emissions of TF listed, above, shall be determined using Equation 1 except that the su m of emissions from each potline included in the group, determined separate ly using the numerator, is divided by the total aluminum production from all of the potlines co mprising 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 sha ll be combined with the TF results for the primary control system(s) and divi ded 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 alumin um tapped during the calendar

month that includes the three r uns for a performance test. E) The average hourly production for the potli nes comprising the group shall be combined to determine the total aluminum production.

v) Compliance with Division Air Quality Standard s for fluoride shall be demonstrated through continued operation and maintenance of am bient 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 (PM 10 ) and less than or equal to 2.5 microns (PM 2.5 ) from potlines 1-4 (combined roof monitors and control st ack) to exceed 128.1 lbs/hr [daily rolling totals shall be used to calculate hourly average (on a m onthly basis) using the m onthly 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 PM 10 shall be demonstr ated through the use of the following equation:

E PM10 / 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 mon itors 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 fo r PM shall be demonstrated through the use of the following equation:

E PM = [Monthly production in tons X Emission fact or calculated using th e most recent stack

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

Monthly production rate is the sum of daily totals.

e) NO

x 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 (SO 2 ) from potlines 1-4 to exceed 898.97 lbs/hr [daily ro lling totals shall be used to calculate hourly average (on a monthly basis) using th e monthly operational hours] (BACT). Note: This value shall be calculated using the following equation:

Compliance Demonstration:

Compliance with the applicab le hourly emissions of SO 2 :

E SO2 = [monthly production in to ns X emission factor of SO 2 (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 sh all 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 fo r CO shall be demonstrated through the use of the following equation:

E CO = [Monthly production in tons X Emission factor calculated using the most recent stack test or listed in KYEIS (l bs/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 Refe rence 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 authori zed through permit, the permittee shall conduct a performance test for particulate emissions (filterable PM, PM 10, PM 2.5 and Condensable Particulate) quarterly during th e 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, PM 10, PM 2.5 and Condensable Particulate). Where similar potlines exist, the permittee may perform sa mpling on a representative potline. 2) The permittee shall perform Reference Method 6 for sulfur dioxide emi ssions 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 dur ing the life of this permit. Where similar potlines exist, the pe rmittee 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 pe rmittee 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 pe rform sampling on a representative potline. 6) The permittee shall perform Referen ce Method 5 particulate tests for PM quarterly during the first year and thereafter once a ye ar 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 accord ance 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 fo r 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 require d by 40 CFR 63.7, the test plan shall include: i) Procedures to ensure a minimum of three r uns 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 15 th of the month, at least one run is performed after the 15 th of the month, and that there are at leas t 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 aut hority [40 CFR 63.847 (b)(8)]. 5) The permittee shall measure and record at leas t three runs each month for secondary emissions and at least three runs each year for th e primary control system to determine compliance with the applicable emi ssion 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 pl an, and the procedures in 40 CFR 63 Subpart LL. 7) If the permittee has performe d 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 met hods 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 visibl e emission limitations are being met the permittee

shall: 1) Perform visual opacity readi ngs on the stack or vent using Re ference Method 9 on a quarterly basis, or more frequently if requested by th e Division. Opacity readings shall be conducted while the emission units are in operation. 2) Perform a qualitative visual observation of em issions from each stack/vent on a daily basis and maintain a log of the obser vation. 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 sp ecified by the Division.

b) To provide reasonable assurance that the particulate matter (PM, PM 10, PM 2.5 ) 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 operati ng parameters of each control device.

c) Excursions from the control equipment’s operati ng 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 determ ine the daily weight of aluminum produced. 2) The permittee shall maintain ambient air mon itoring equipment for fluoride and monitor the raw

material feed rates a nd cell or potline voltage. 3) The TF emissions from each potline shall be monitored through monthly performance tests specified in the testing requirement section a nd 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 record ed, quarterly, using Equation 2.b above. 5) If prior approval for alternative monitori ng for similar potline has been granted, monthly monitoring shall be performed using the appr oved 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/to n of aluminum produced limit. 6) For the reduced monitoring schedules that ha ve 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. Thereafte r, the permittee must appl y 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 pe rmittee shall install, operate, and maintain a monitoring device. Calibration must be perf ormed 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 emi ssions indicating abnormal operation. 9) Unless prior written approval by the Division fo r alternative control devi ce 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 conti nuous 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 ope ration are observed from the exhaust stack of a control device during a daily inspection, the permittee shall initiate th e corrective action procedures identified in the Startup, Shutdown, a nd Malfunction Plan within 1 hour. ii) Failure to initiate the correc tive action procedures within 1 hour or to take the necessary corrective actions to remedy th e problem is a violation. iii) If the range for a given operating parameter as sociated 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 PM 10 /PM 2.5 emissions from potlines 1-4 shall be monitored through a quarterly performance tests conducted as specified in 3.Testing Requirements above. PM 10 /PM 2.5 emissions shall be computed and recorded using equation 2.c above. 2) The SO 2 emissions from potlines 1-4 shall be monitored through a quarterly performance test conducted as specified in 3.Testing Requirements above. SO 2 emissions shall be computed and recorded using the equation in 2.f above.

f) To preclude PSD (401 KAR 51:017): 1) The NO

x emissions from potlines 1-4 shall be mon itored through a performance test conducted once during the life of this permit. 2) The VOC emissions from po tlines 1-4 shall be monitored th rough a performance test conducted once during the life of this permit.

g) The permittee shall install, operate, calibrate, and maintain a c ontinuous monitoring system for the control equipment pursuant to th e approved parametric monitoring plan, which is summarized in Attachment B to the permit, as provided in 40 CF R 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 pe r 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 ambi ent 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 sha ll maintain the following information: 1) Records of the monthly TF emission ra tes calculated using e quation 40 CFR 63.847(e); 2) Results of each performance test run; 3) Records that demonstrate th at the operating para meters established under 40 CFR 63.847(h) are being met; 4) Records of the calibration for all monitoring devices; 5) Records of the daily pr oduction 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 redu ced sampling of potlines (if applicable); 9) Records supporting the correlation of emissi ons 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 da ily visual inspection of

the exhaust stack for each c ontrol 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 require d by 40 CFR 63.10(c), for a potline equipped with an HF continuous emission monitor (if applicable); 13) Records documenting the corrective actions take n when the limit(s) for an operating parameter established under 40 CFR 63.847(h) were exceede d, 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 particulat e and gaseous fractions ar e quantified separately using an approved test method; 15) Records documenting the acti ons taken during a startup, s hutdown, or a malfunction; and 16) Records of the maintenance performe d on all control and monitoring devices.

6. Specific Reporting Requirements:

a) The permittee may report required information on pape r or in an electronic format using commonly available and compatible computer software.

b) The permittee shall submit a summary of all perfor mance tests on an annual basis except as required below, in an excess emissions report (s ee f, below) and in 40 CFR 63.850(d).

c) The permittee shall maintain a site-specific test plan according to the re quirements of 40 CFR 63.7 (c) for Division review and approval. The plan mu st 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 r uns are performed annually for the primary control system for each source, 2) Procedures for establishing the frequency of testing to ensure that at leas t 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 mont h, or that secondary emissions are measured according to an approved alternate schedule, 3) A test summary, the test schedule, data quality objectives (the pretest e xpectations 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 pa rameter(s) to be monitored, the operating limits, and the monitoring frequency to ensure that each cont rol 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 ta ken during the relevant reporting period during startup, s hutdown, and malfunction were cons istent with the affected source’s startup, shutdown, and ma lfunction 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 w ithin 7 working days after the end of the event, in accordance with 40 CFR 63.10(d)(5) ( unless alternative reporting arra ngement 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 exce ss of the applicable sta ndard. 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-annua l 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 attr ibuted in any given 24-hour period.

7. Specific Control Equipment Operating Conditions:

a) The permittee shall maintain a description of th e parameters to be monitored, the operating limits, and the monitoring frequency to ensure that e ach control device is be ing properly operated and maintained. An explanation of th e criteria used for selection of the parameters, the operating limits, and the monitoring frequency, including how these re late to emission contro l shall also be kept.

b) The permittee shall maintain a continuous parameter monitoring syst em 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 prope rly 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 em issions 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 potlin es are in operation.

8. Compliance Schedule:

The permittee shall implement the parametric monitori ng plan (with latest revi sion 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:

NonePermit 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)

E MISSION G ROUP 42

89 42 4250 1998 Potline #5, CWPB1 Dry Alumina

Scrubber 4800

63 CO – 2,588.308

F – 0.126

HF – 0.685

PM 10 – 8.048

PM – 13.875

SO 2 – 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

PM 10 – 21.849

PM – 37.671

SO 2 – 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 NO

x , carbon monoxide, and sulfur dioxid e emissions established in 1999) 401 KAR 59:010, New process operations

1. Operating Limitations:

The following operational limits ar e 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 th e standard ASTM method, an approved alternative method, or vendor Certificate of Analysis.

c) The design capture efficiency for the collection sy stem 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 emi ssions from each stack/vent on a daily basis and maintain a log of the obser vation. 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 particulatePermit 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 mont hly basis) using the m onthly operational hours] (BACT). Note: This value shall be ca lculated using the following equation:

Compliance Demonstration:

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

E PM = [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 (PM 10 ) 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 PM 10 shall be demonstrated through use of the following equation:

E PM10 = [Monthly production in tons X Emission f actor calculated using the most recent stack test or listed in KYEIS (lbs /ton)]/ Monthly hour s 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):

E TF = (C s1 x Q sd ) 1 + (C s2 x Q sd ) 2 40 CFR 63.847(e) (P x K)

Where:

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

− C s1 is the concentration of total fluorides from the primary control system in mg/dscf

− Q sd is the volumetric flow rate of effluent gas correspo nding to the appropriate

location in dscf/hr

− C s2 is the concentration of total fluorides as measured for roof monitor emissions in mg/dscfPermit 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 contro l system effluent gas

− 2 denotes the secondary control system or roof monitor effluent gas. ii) The aluminum production rate (P ) shall be determined by dividi ng 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 aver age of all performance test runs (40 CFR 63.848(a)). iv) The concentration and volumetric fl ow 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) SO 2 emissions shall not exceed combined 371.96 lbs/hr [da ily 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 applicab le hourly emissions of SO 2 :

E SO2 = [monthly production in tons X emissi on 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 Referen ce 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 th e emission unit’s normal operation.

b) Annual performance tests, starting within 30 cale ndar days of the annivers ary date of the initial performance test, shall be conduc ted on the potline 5 exhaust stack and the roof monitor for SO 2 , CO, VOC, PM and PM 10

.

The permitee shall perform one annual test on those po llutants that were less than or equal to 75% of the permit limit during the previous permit period. If the results of the annua l test remain less than or equal to 75% of the permit limit, then no additio nal 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 perm it period, then annual testing will commence until

two consecutive annual tests demons trate that the emissions of SO 2 , CO, VOC, PM and PM 10 arePermit 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 specifie d 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 test s for PM during the first year of this permit at each of the following sources using Reference Me thod 5 for compliance demonstration with 401 KAR 59:010 and 401 KAR 51:017 and thereafter once a year during the life of th is permit: 1) potline 5 roof monitor and 2) potline 5 control stack.

d) The permittee shall perform quarterly performance te st during the first year of this permit for PM 10 at each of the following sources using Reference Method 201for compliance demonstration with 401 KAR 51:017 and thereafter once a year during the li fe of this permit: 1) potline 5 roof monitor and 2) Potline 5 control stack.

e) The permittee shall utilize the following EPA Re ference Methods for the listed pollutants:

Pollutant Method

PM Reference Method 5

PM 10 Reference Method 201

SO 2 Reference Method 6 CO Reference Method 10, 10A, or 10B

VOC Reference Method 25 or 25A

f) Aluminum production shall also be monitore d and recorded during the performance test.

g) The amount of aluminum tapped shall be dete rmined and recorded dur ing 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 te st plan must include procedures for conducting the performance tests required in 40 CFR 63.848 for emission monito ring. In addition to the information required by 40 CFR 63.7, the test plan shall include: 1) Procedures to ensure a minimum of three r uns are performed annually for the primary control system for each source, and 2) Procedures for establishing the fre quency of testing to ensure that at least one run is performed

before the 15 th of the month, at least one run is performed after the 15 th of the month, and that there are at least six days betw een two of the runs during the m onth, or that secondary emissions are measured according to an alternate schedul e satisfactory to the applicable regulatory authority.

k) The permittee shall measure and record at least three runs each month fo r secondary emissions andPermit 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 requi rements of the general provisions in Subpart A of Part 40 CFR 63, the appr oved test plan, and the pr ocedures in 40 CFR 63 Subpart LL.

m) The permittee shall use the refe rence 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 visibl e emission limitations are being met, the permittee shall perform quarterly visible emission readings on potline st ack using Reference Method 9.

b) To provide reasonable assurance that the PM/PM 10 emissions limitations are being met: 1) The permittee shall monitor the 12-month rolling total amou nt and type of operational throughput added to each emission unit, as sp ecified above, as well as conduct an annual performance test. 2) The permittee shall continuously monitor the air flow rate a nd 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/PM 10 in tons emitted per month.

− TP = actual throughput (opera tion limit) in tons/month.

− PEF = PM/PM 10 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 factor s approved by the Division.

c) Pursuant to 40 CFR 63.848(a), 1) The TF emissions shall be monitored through m onthly 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 r oof monitors shall be monitored quarterly using the approved test sc hedule 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 in stall, operate, and maintain a monitoring device. Calibration must be performed in acco rdance with the manufacturer’s instructions. 3) The permittee shall visually inspect the exhaust stack(s) of each control device on a daily basisPermit 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 emi ssions indicating abnormal operation. 4) The permittee shall maintain a continuous parame ter monitoring system for the emissions control

device. Unless prior written approval by the Division for alternative contro l 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 pursu ant 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 malfunc tion plan within 1 hour. ii) Failure to initiate the corrective action proced ures within 1 hour, or to take the necessary corrective actions to remedy th e problem, is a violation. iii) If the range for a given operating parameter as sociated 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 ta ken 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 ai r monitoring equipment for the detection of fluorides. This equipment shall be located at sites sp ecified by the Division.

f) The permittee shall install, operate , calibrate, and maintain a con tinuous monitoring system for the control equipment pursuant to th e approved parametric monitoring plan, which is summarized in Attachment B to the permit, as provided in 40 CF R 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 r ecorded to assure compliance with the operational limitations.

b) Records shall be maintained of vi sible emission readings using Reference Met hod 9, baghouse pressure drops and air flow rate, monthly specif ied operational limits (throughput), performance test results, the derived emission factor and the monthl y particulate emission calcu lations. 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 occurr ence, measurement, maintenance, corrective action, report, or record. The most rece nt two years of records must be retained at the facility. The remaining three years of records may be retained o ffsite. Records may be retained on microfilm, on a computer, on computer disks, on magnetic tape, or on microfiche. In addition to the general recordsPermit 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 sh all 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 maintenan ce for all monitoring a nd control devices; (if applicable); 5) Records of the daily pr oduction 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 da ily visual inspection of

the exhaust stack for each control device has been performed as requi red in 40 CFR 63.848(g), including the results of each inspection; 10) Records of the information and data requi red by 40 CFR 63.10(c), for a potline equipped with an HF continuous emission monitor (if applicable); 11) Records documenting the corrective actions take n 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 cont rol 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 particulat e 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 da ys 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 contai n individual emission units’ m onthly and 12-month rolling PM/PM 10 emission estimates and a summation of all emission units’ 12-month rolling PM 10 emissions. 3) Monthly reports shall be submitted until ther e have been 12 consecutive months without any

exceedance.

b) The permittee shall also certify to the Division, annually, that the specified reco rds are being kept for this emission point and that any exceedances were reported.

c) The permittee may report required information on pape r 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 require d in (h), below, and in 40 CFR 63.850(d).

e) As part of the compliance test report, the perm ittee shall submit a description of the parameter(s) monitored, the operating limits, and the monitored ra nge to ensure that the each control device is being properly operated and maintained.

f) The permittee shall develop and submit, if reque sted, 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, s hutdown, and malfunction were cons istent with the affected source’s startup, shutdown, and malfunction plan. 1) If action taken during the star tup, shutdown, or malfunc tion is not consistent with the affected source’s plan, the permittee sh all record the action taken for the event and shall report

such actions within two worki ng days after commencing action in consistent 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 altern ative reporting arrangements have been made in advance). 2) Additionally, the permittee shall submit, fo r 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 exce ss 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 require d as a result of excess emissions.

i) The permittee shall submit quarterly ambient monito ring data reports to the Division, if required. If the ambient limit is exceeded 6 times in any se mi-annual reporting period, then any subsequent exceedance in that reporting period is a viola tion. For the purpose of determining the number of exceedances, no more than one exceedance sh all be counted in a ny given 24-hour period.

7. Specific Control Operating Conditions:

a) The dry alumina scrubber shall operate within th e 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 sh all 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 monitori ng plan (with latest revi sion 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:

NonePermit 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)

E MISSION G ROUP 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

*NO

x – 39.565

PM 10 – 3.575

PM -3.575

**POM – 4.22

SO 2 – See emission

limitations

*VOC – 5.461 Combined: 245,100 tons

Green Anodes 900 mmcf/yr

* VOC and NO

x 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 (a pplies to the visible emissions). Self-imposed limitations supersedes the mass em issions standards prescribed by 401 KAR 59:010 401 KAR 51:017, Prevention of significant deterioration of air quality (PSD) (a pplies to carbon monoxide, sulfur dioxide, Fluoride, PM/PM 10 emissions). PSD applies to production increases in anode bake associ ated 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 notexceed 228 mmcf per 12-month period (selfimposed).

e) Combined propane usage shall not exceed 675,000 ga llons/12-month period for all three furnaces combined (self-imposed).

f) The following operational limits ar e BACT limits to protect NAAQS: 1) The petroleum coke used to make the green a nodes 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 byPermit 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 perf ormed 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 ga s, pitch and coke com bustion, expressed as NO 2 , 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 averag e) to preclude PSD applicability.

Note: Nitrogen Oxide emissions from propane, onl y, 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-m onth 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) SO 2 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:

SO 2 emissions in pounds per hour = Sum of SO 2 emissions from green anodes and combustion of natural gas

SO 2 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 th e pitch received from the supplier each month X 2 (factor to convert S to SO 2 based on molar mass of S of 32 versus SO 2 of 64) ÷ hours of anode bake operations (no. of days of bake operations per mo. X 24 hr/day)

SO 2 from combustion of natural gas calculated as follows : Amount of natural gas consumed in anode bake per month (in mmcf)

X 0.06 lbs SO 2 /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 conten t 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 ove r the minimum time specif ied 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. VOC

s shall not exceed 5.461 lbs/hr (monthly average) to preclude PSD applicab ility (Synthetic minor limit).

f) The hourly PM/PM 10 emissions shall not exceed 3.575 lbs/hr (m onthly 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 s ource (furnace 3), emissi ons 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 furn ace #1 (lb/ton) = Controlled em ission 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 furn ace #2 (lb/ton) = Controlled em ission 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 furn ace #3 (lb/ton) = Controlled em ission 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 materi al 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 op erating 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 mo nth into the weight of green anode material used during the calendar mo nth in which the performance test was

conducted.

C) Compliance demonstration for VOC emissions li mits shall be determined by calculating the VOC monthly emissions based on VOC em issions 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 NO

x emissions limits shall be determined by calculating

the NO

x emissions monthly based natural gas c onsumption and weight of green anodes processed that month. The NO

x emissions factor for NO

x process emissions shall be determined from the compliance test.

3. Testing Requirements:

a) Annual performance tests, shall be c onducted on the carbon bake furnaces for SO 2 , CO, NO

x , PM

and PM 10, starting within 30 calendar days of the annivers ary date of the initial performance test.

The permittee shall perform the annual test on those pollu tants that were less than or equal to 75% of the permit limit during the previous permit period. If the results of the annua l test remain less than or equal to 75% of the permit limit, then no additio nal testing of those pollutants is required for the duration of the current permit. If the result(s) of testing are not less than or eq ual to 75% of the permit limit, or if no testing was performed on a pollutant during the previous perm it period, then annual testing will commence until two consecutive annual tests demonstrate that the emissions of CO, NO

x , and PM/PM 10 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 Re ference 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

PM 10 Reference Method 201

VOC Reference Method 25 or 25A CO Reference Method 10, 10A, or 10B

NO

x 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 th e emission unit’s normal operation

.

d) The amount of green anodes bake d and the amount of packing coke used shall be determined and recorded during each performance te st of the carbon bake furnaces.

e) Emission factors shall be deve loped from the most recent perf ormance test and the specified operational limit.

f) Pursuant to 40 CFR 63.847(b) and (d)(4), the permittee shall subm it 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 ra tes 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 sy stem parameter(s) shall be determined from the values recorded during each of th e runs performed during the initial performance test and subsequent compliance tests. See 7. Specific Control Equi pment Operating Condition below.

k) All performance tests (measurements) shall be conduc ted in accordance with the requirements of the general provisions in 40 CFR 63, Su bpart 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 appr opriate Reference Method.

l) For continued PSD compliance demonstr ation, the facility will conduct a SO 2 emissions test pursuant to a) above to confirm that the SO 2 emissions from anode bake do not exceed 139.959 pounds per hour. Additional testing may be requir ed pursuant to 3.a. Testing Requirements above.

m) For continued PSD compliance demonstra tion, the facility wi ll conduct a PM/PM 10 emissions testPermit 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/PM 10 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 demonstr ation, the facility will conduct a CO emissions test pursuant to a) above to confirm that the CO emission s 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 fr om anode bake do not exceed 5.461 lbs/hr. A VOC emission factor shall be developed from this perf ormance 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 NO

x emissions test pursuant to a)

above to confirm that the NOx emissions fr om anode bake do not exceed 39.56 lbs/hr. A NO

x emission factor shall be develope d from this performance test.

4. Specific Monitoring Requirements:

a) The permittee shall monitor and record the monthly fuel usage ra tes of natural gas and propane separately for each of the new and existing ovens.

b) 12-month rolling total throughputs shall be monitore d 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. E ach method shall be approved by the

Division. The method used to determination su lfur content of coke shall assure that the average percent sulfur by weight of each shipme nt 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 Ce rtificate 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 test ing 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 propa ne 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 paramete rs as per the parametric plan, shall be constantly monitored.

h) Monitoring of the VOM contents of the pi tch and petroleum coke shall be maintained.

i) To provide reasonable assurance that the visible emission limitations are being met, the permitteePermit 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 readin gs on the carbon bake furnaces’ primary control system stack using Reference Method 9. Additiona lly, compliance assurance will be provided by the periodic monitoring specifie d in 40 CFR 63, Subpart LL.

j) To provide reasonable assurance that th e particulate matter emission limitations (PM/PM 10 ) are being met, 1) The permittee shall monitor the monthly amount and type of process th roughput added to each emission unit as well as conduct annual performance test. 2) The permittee shall continuously monitor the air flow rate a nd 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/PM 10 emitted in tons/month

− TP = actual throughput (opera tion limit) in tons/month

− PEF = PM/PM 10 particulate emission factor in lbs/ton of throughput

4) The particulate emission factors shall be de termined 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 opera ting ranges shall be prom ptly 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 materi al placed in the furnace shall be monitored. The weight may be determined by monitoring the weight of all anodes or by monitori ng 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 visibl e 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, ope rate, calibrate (performed in acco rdance with the manufacturer’s instructions), and maintain a continuous parame ter monitoring system for each emission controlPermit 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 Divi sion 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 de vice measures an operating parameter outside the limit(s) required to be established pursuan t 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 sh all initiate the corrective action procedures identified in the startup, shutdown, and malfunction pl an within one hour. Failure to in itiate the corrective action procedures within one hour, or to take the neces sary corrective actions to remedy the problem, is

a violation. 2) If the limit for a given operating parameter asso ciated with monitoring a specific control device is exceeded six times in any se miannual reporting period, then any subsequent excee dance in that reporting period is a violation. For the purpose of determining the number of exceedances, no

more than one exceedance shall be attr ibuted 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 NO

x and VOC on a monthly ba sis (and rolling total 12- month period) using fuel usage a nd green anode process rates in or der to confirm that the annual

emission limits for NO

x 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 ai r monitoring equipment for the detection of fluorides. This equipment shall be located at sites sp ecified by the Division.

r) The permittee shall install, operate , calibrate, and maintain a con tinuous monitoring system for the control equipment pursuant to th e approved parametric monitoring plan, which is summarized in Attachment B to the permit, as provided in 40 CF R 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 emissi on readings using Referen ce 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 em ission 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 calcu lated using the equations in section 2. Emission

Limitations Compliance Demonstration; 2) Results of each performance test run; 3) Demonstrating that the operating paramete rs established under S ection 40 CFR 63.847(h) arePermit 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 pl aced under fire each month; 6) A copy of the startup, shutdown, and malfunction plan; 7) Records, such as a checklist or the equivalent, de monstrating that the weekly visual inspection of

the exhaust stack for each cont rol device has been performed as required in 40 CFR 63.848(g), including the results of each inspection; 8) Records documenting the corrective actions take n when the limit(s) for an operating parameter established under 40 CFR 63.847(h) were exceede d, 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 particulat e and gaseous fractions ar e 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 initi al notification of an ex ceedance, monthly reports shall be submitted, by the fifteenth of each mont h, to the Division’s Owensboro Regional Office. The permittee shall also certify to the Division, annually, th at the specified record s are being kept for these emission points and that any exceedances were reported.

b) Any exceedance of the sulfur c ontent 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 equipmen t 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 o ccur in any rolling six months, the permittee shall submit to the Division’s Owensboro Regi onal Office a corrective action plan for the Division’s approval on form DEP7007BB, no late r than 30 days from the second exceedance.

e) Any exceedance over the monthly particulate emissi on 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’ mont hly and 12-month rolling PM/PM 10 emission estimates and a summation of th e emission units’ 12-month rolling PM/PM 10 emissions and results of weekly opacity observations. 3) Monthly reports shall be submitted until ther e 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, th at the specified record s are being kept for these emission points and that any exceedance was reported.

g) The permittee may report required information on pape r, or in an electronic format using commonly available and compatible computer software.

h) The permittee shall submit a summary of all subs equent performance tests on an annual basis except as required, below, in (excess emi ssion report) and in 40 CFR 63.850(d).

i) The permittee must maintain a s ite specific test plan that must include procedures for conducting performance tests required for em ission 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 r uns are performed annually for the primary control system for each source; 2) A test summary, the test schedule, data quality objectives (the pretest e xpectations 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 ta ken during the relevant reporting period during startup, s hutdown, and malfunction were cons istent with the affected source’s startup, shutdown, and malfunction plan. 1) If action taken during the star tup, shutdown, or malfunc tion 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 th e end of the event, in accordance with 40 CFR 63.10(d)(5) (unless alternative re porting arrangements have been made in advance). 2) Additionally, the permittee shall submit fo r 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 exce ss of the applicable sta ndard. 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 ope rate 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 operat e 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. Calibrati ons must be performed in accordance with the

manufacturer’s instruct ions and records of calibrations kept.

8. Compliance Schedule:

The permittee shall implement the parametric monitori ng plan (with latest revi sion 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:

NonePermit 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)

E MISSION G ROUP 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

PM 10 – 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 inst all, operate, and mainta in equipment to capture and control polycyclic organi c 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, visi ble 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 list ed operational limits provides reasonable assurance that the tota l particulate matter (PM) emission and PM 10 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 th e emission standards for these emission points shall be demonstrated through site inspections and re view of site records, un less testing is required or requested.

4. Specific Monitoring Requirements:

a) Pursuant to 401 KAR 59:010, to provide reasonab le assurance that the vi sible 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 Refe rence Method 9 if visible emissions from any

stack/vent are observed. 3) Compliance with the listed operational limits provides reasonable assurance that the PM/PM 10 emission limitations are being met. 4) The permittee shall monitor th e rolling 12-month amount and type of throughputs added to each emission unit during a calendar month. 5) Excursions from the control equipment’s ope rating 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 m onitored, the operating limits, and the monitoring frequency to ensure that the c ontrol devices are being properly operated and maintained, and an explanation of the criteria used for their selection and how they re late to the emission control,

shall be submitted. 2) Unless prior written approval by the Division for alternative cont rol 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 emi ssions indicating abnormal operation. 4) If a monitoring device for a primary control de vice measures an operating parameter outside the limit(s) required to be established pursuan t 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 malfuncti on plan within one hour. i) Failure to initiate th e corrective action procedures within one hour or to take the necessary corrective actions to remedy th e 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-a nnual 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 take n during any startup, shutdown, and malfunction

event.

c) The permittee shall install, operate , calibrate, and maintain a con tinuous monitoring system for the control equipment pursuant to th e approved parametric monitoring plan, which is summarized in Attachment B to the permit, as provided in 40 CF R 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, sh utdown, and malfunction plan, 2) Daily records of the contro l equipment operating parameters, 3) Design information of the capture system(s), 4) Records, such as a checklist or the equivalent , demonstrating that the da ily 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 ta ken when the limits for an operating parameter established under 40 CFR 63.847(h) were exceede d, 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 electroni c format using commonly available and compatible computer software.

b) The permittee shall submit semi-annual reports that confirm that actions ta ken during the relevant reporting period during startup, s hutdown, and malfunction were cons istent with the affected source’s startup, shutdown, and malfunction plan. 1) If action taken during the star tup, shutdown, or malfunc tion 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 commenci ng action inconsistent with the plan and also submit a letter within seven working days after th e end of the event, in accordance with 40 CFR 63.10(d)(5) (unless alternative reporting arra ngements 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, fo r the Division’s review and approval, any

modifications to the affected source’ s startup, shutdown, and malfunction plan.

c) Any exceedance over the monthly op acity 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 Divi sion’s Owensboro Regional Office. 2) The reports shall cont ain individual emission uni ts’ opacity readings. 3) Monthly reports shall be submitted until ther e 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 exceedance s occur in any rolling six months, the permittee shall submit to the Division’s Owensboro Regi onal 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 mi nimum exhaust rates as published in Chapter 3 and Chapter 5 of Industrial Ventilation: A Manual of R ecommended 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 monitori ng plan (with latest revi sion 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:

NonePermit 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 de signated as insignificant the permittee must comply with the applicable regulation. Process and emission cont rol equipment at each insignificant activity subject to an opacity standard shall be inspec ted monthly and a qualitative visible em issions evaluation made. Results of the inspection, evalua tion, and any corrective action sh all 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 63:020Permit 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 63:020Permit Number: V-08-012 Page: 49 of 61

SECTION D - SOURCE EMISSION LIMI TATIONS AND TESTING REQUIREMENTS

1. As required by Section 1b of the Cabinet Provisions and Procedur es for Issuing Title V Permits incorporated by reference in 401 KAR 52:020, Section 26; complia nce with annual emissions and processing limitations contained in this permit, sha ll be based on emissions and processing rates for any twelve (12) consecutive months.

2. PM, PM 10 , CO, NO x, SO 2, VOC, F and opacity emissions, measured by applicable reference methods, or an equivalent or alternative method spec ified in 40 C.F.R. Chapter I, or by a test method specified in the state implementation plan shall not exceed th e respective limitations specified herein.Permit Number: V-08-012 Page: 50 of 61

SECTION E - SOURCE CONTRO L EQUIPMENT REQUIREMENTS

1. Pursuant to 401 KAR 50:055, Secti on 2(5), at all times, including periods of startup, shutdown and malfunction, owners and operators shall, to the exte nt 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 base d on information availabl e to the Division which may include, but is not limited to, monitoring result s, 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, sh utdown and malfunction owne rs and operators shall maintain and operate any affected facility source to a standard promulgated pursuant to 112(d), including associated air pollution control equipmen t, in a manner consistent with good air pollution control practice for minimizing emi ssion at least to the levels requi red by the relevant standards.

b) Malfunctions shall be corrected as soon as practic able after their occurrence in accordance with the required startup, shutdow n, and malfunction plan.

c) Operation and maintenance require ments established pursuant to sec tion 112 of the Act are enforceable independent of emissions limitations or other require ments in relevant standards. Determination of whether acceptable operation and maintenance procedur es 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, shut down, and malfunction plan), review of operation and maintenance records, a nd inspection of the source.

d) Startup, shutdown, and malfunction plan and repor ts. The permittee shall develop, by the compliance date, and implement a written startup, shutdown, a nd malfunction plan as described below and in 40 CFR 63.6(e)(3) that contains spec ific 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 an d 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 correctiv e actions, to be followed if a monitoring device measures an operating parameter outside the limit(s) establishe d 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 (re quired 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 desc ribed in 40 CFR 63.6(e)(3)(iv). 3) The plan shall identif y all routine or otherwis e predictable continuous monitoring system (CMS)

malfunctions. 4) The permittee shall keep records during and fo llowing startup, shutdown and malfunction events that confirm conformance with the plan. R ecords may be in the form of “checklists”. 5) The permittee shall keep records in a form suita ble and readily available for expeditious review and inspection.Permit Number: V-08-012 Page: 51 of 61

SECTION E - SOURCE CO NTROL EQUIPMENT REQU IREMENT (CONTINUED)

6) The occurrence and duration of each event shall be recorded. Records must be kept of any action taken during the event (including co rrective 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 demons trate 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 comp liance 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 perfor mance evaluations, opacity and visual observations

shall be recorded. 11) The permittee shall revise the plan within 45 days after an event that the pl an did not address, or failed to inadequately address, to include detail ed procedures for operati on and maintenance during

a similar event and the corrective actions to be taken. 12) All calibration checks, adjust ments 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 Procedur es 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 monitori ng data and support information, in cluding calibrations, maintenance records, and original strip chart recordings, and c opies of all reports require d 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 au thorized 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 fac ility, equipment (includi ng 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, substan ces or parameters to assu re 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 empl oyee 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 monitori ng required by this permit, other th an 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 wh ich had not commenced operat ion at the end of the 6- month period covered by the report and are subject to monitoring requirements in this permit, the repor t shall indicate that no monitoring was performed during th e previous six months because the emission unit wa s 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 th e Technical Services Branch in accordance with the requirements of 401 KAR 59:005, General Provisions, S ection 3(3). All reports shall be certified by a responsible official pursuant to 401 KAR 52:020 Section 23. All devi ations 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 pla nned shutdowns and ensuing startups will exceed the standards,

notification shall be made no later than thr ee (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 st artups 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 emi ssion exceedances covered by Section F.7. above) to the Regional Office listed on the front of this permit w ithin 30 days. Other deviations from permit requirements shall be included in the semiannual re port 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, th e permittee shall annually certify compliance with the terms and conditions contained in this pe rmit, by completing and returning a Compliance Certification Form (DEP 7007CC) (o r 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 th e term or condition;

b) Compliance status of each term or condition of the permit;

c) Whether compliance was c ontinuous 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 complian ce status for the source , currently and over the reporting period, and

e) For an emissions unit that wa s still under construction or which has not commence d 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 th at compliance with any applicable requirements

will be demonstrated within the timeframes specified in the permit.

f) The certification shall be postmarked by Ja nuary 30th of each year. Annual compliance

certifications should be maile d 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 a ll conditions of this permit. Nonc ompliance 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 perm it revision, revocation, reissuance, or termination, or of a notification of a planned cha nge 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 re issued, or terminated for cause in accordance with 401 KAR 52:020, Section 19. The permit will be reopene d for cause and revised accordingly under the following circumstances: (1) If additional applicable requirements become app licable to the source and the remaining permit term is three (3) years or longer. In this case, the reop ening shall be completed no later than eighteen (18) months after promulgation of the applicable re quirement. 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 te rms 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 th e 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 thos e parts of the permit for which cause to reopen exists. Reopenings shall be made as expeditiously as practicable. Reopeni ngs shall not be initiated before a notice of intent to reopen is provided to the source by the Division, at l east 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 informa tion 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 dem onstrate 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 PR OVISIONS (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 inva lidate 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 enfo rcement 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 Procedur es 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 pe rmittee 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 liab ility of the permittee for any violation of applicable requirements prior to or at the time of pe rmit issuance [401 KAR 52: 020, Section 11(3) 2].

l. This permit does not convey pr operty rights or exclusive priv ileges [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 re sponsibility of obtaining any other permits, licenses, or approvals required by the Cabine t or any other federal, state, or local agency.

n. Nothing in this permit shall alter or affect the au thority of U.S. EPA to obtain information pursuant to Federal Statute 42 USC 7414, Inspections, monitori ng, 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, Emerge ncy orders [401 KAR 52: 020, Section 11(3) 1].

p. This permit consolidates the authority of any prev iously 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 requi rement prior to or at the time of permit issuance. Compliance with the conditions of this pe rmit shall be considered compliance with:Permit Number: V-08-012 Page: 57 of 61

SECTION G - GENERAL PR OVISIONS (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, th e authorization to operate within the terms and conditions of this permit, including any permit shiel d, 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 appl y if the source fails to submit additional information requested by the Division after the completeness de termination 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 invol ving the use of economic incentive, marketable permit, emission trading, and ot her 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 releva nt requirements of 401 KAR 52:020, Section 14(2).

b. This permit is not transferable by the permittee. Fu ture 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 pr ovided 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 wi thin ten (10) days following the transfer.

4. Construction, Start-Up, and Initial Compliance Demonstration Requirements

Pursuant to a duly submitted applic ation the Division hereby authorizes the construction of the equipment described herein, EP 84 (New electrical equipment to increas e 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 term s an d conditions of this permit.

a. Construction of any process an d/or air pollution contro l 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 maxi mum production rate specified in the permit applica tion, 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 sp ecified in the permit application was achieved.Permit Number: V-08-012 Page: 58 of 61

SECTION G - GENERAL PR OVISIONS (CONTINUED)

c. Pursuant to 401 KAR 52:020, Sect ion 3(2), unless construction is commenced within eighteen (18) months after the permit is issued, or begins but is di scontinued for a period of eighteen (18) months or is not completed within a reasonable timeframe then the construction and operati ng authority granted by this permit for those affected facilities for whic h construction was not comp leted shall immediately become invalid. Upon written reques t, the Cabinet may extend these ti me 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 specifi ed herein has been demonstrated pursuant to 401 KAR 50:055. If compliance is not demonstrated with in the prescribed timefr ame provided in 401 KAR 50:055, the source shall operate th ereafter only for the purpose of de monstrating compliance, unless otherwise authorized by S ection I of this permit or order of the Cabinet.

e. This permit shall allow time for the initial st art-up, operation, and complian ce 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 c onduct 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 establishe d pursuant to the construction authority of 401 KAR

51:017 or 401 KAR 51:0 52 shall not expire.

5. Testing Requirements

a. Pursuant to 401 KAR 50:045 Sectio n 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 de monstrate 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 cr eate the highest rate of em issions. If [When] the maximum production rate represents a source’s highe st emissions rate and a performance test is conducted at less than the maximum production rate, a s ource 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 specifi ed 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 dem onstrates 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 PR OVISIONS (CONTINUED)

6. Acid Rain Program Requirements

a. If an applicab le requirement of Federal Statute 42 USC 7401 th rough 7671q (the Clean Air Act) is more stringent than an applicable re quirement promulgated pursuant to Federal Statute 42 USC 7651 through 7651o (Title IV of the Act), both provisions shal l apply, and both shall be state and federally

enforceable.

b. The permittee shall comply with all applicable requi rements and conditions of the Acid Rain Permit and the Phase II permit application (i ncluding the Phase II NOx complian ce plan and averaging plan, if applicable) incorporated into the Title V permit issu ed for this source. The source shall also comply with all requirements of any re vised or future acid rain permit(s) issued to this source.

7. Emergency Provisions

a. Pursuant to 401 KAR 52:020 Section 24(1), an emerge ncy 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 contemporane ous 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 permitte e took all reasonable steps to mini mize 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 miti gate emissions, and corrective actions taken. (5) This requirement does not relieve the source of other lo cal, state or federal no tification requirements.

b. Emergency conditions listed in General C ondition 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 perm ittee 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 st andards for recycling and emi ssions reduction pursuant to 40 CFR 82, Subpart F, except as provided for Motor Vehi cle Air Conditioners (MVACs) in Subpart B: (1) Persons opening appliances for maintenance, serv ice, repair, or disposal shall comply with the required practices contained in 40 CFR 82.156. (2) Equipment used during the maintena nce, service, repair, or disposal of appliances shall comply with the standards for recycling and recove ry equipment contained in 40 CFR 82.158. (3) Persons performing maintenance, se rvice, repair, or disposal of appl iances shall be certified by an approved technician certificati on 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 recordkeepi ng requirements pursuant to 40 CFR 82.166 (5) Persons owning commercial or i ndustrial process refrigeration equipm ent shall comply with the leak repair requirements pursuant to 40 CFR 82.156. (6) Owners/operators of appliances normally contai ning 50 or more pounds of refrigerant shall keep records of refrigerant purchas ed and added to such applia nces pursuant to 40 CFR 82.166.Permit Number: V-08-012 Page: 60 of 61

SECTION G - GENERAL PR OVISIONS (CONTINUED)

b. If the permittee performs servic e on motor (fleet) vehicle air condi tioners containing ozone-depleting substances, the source shall comply with all appli cable requirements as specifi ed in 40 CFR 82, Subpart
B, Servicing of Motor Vehicle Air Conditioners

.

9. Risk Management Provisions

a. The permittee shall comply w ith all applicable requirements of 401 KAR Chapter 68, Chemical Accident Prevention, which inco rporates by reference 40 CFR Pa rt 68, Risk Management Plan provisions. If required, the pe rmittee 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 info rmation 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



# C OMPLIANCE ASSURANCE

MONITORING 

# ( CAM 

# ) PLAN

FOR



# P OTLINES 

# 1-4

TOTAL PARTICULATE AND SULFUR DIOXIDE

AND



# P OTLINE 

# 5

TOTAL PARTICULATE

# T ABLE OF 

# C ONTENTS

Potlines 1-4 Total Particul ate .....................................................................

Potlines 1-4 Sulf ur Dioxide ........................................................................

Potline 5 Total Pa rticulate ..........................................................................

## Potlines 1 through 4 Control System Multiple Cyclones and Electrostatic Precipitators for PT Control

I. B ACKGROUND

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/PM 10 Emission Limits: 220.786 lbs PM/hr, 128.1 lbs PM 10 /hr

Monitoring Requirements: Visible emissions, periodic monitoring

c. Control Technology

Multiple

‐ cyclones and Electrostatic Precipitators (ESPs)

II. M ONITORING A PPROACH

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 shiftc. 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. J USTIFICATION

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

– SO 2

IV. B ACKGROUND

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

SO 2 Emission Limits: 898.97 lbs SO 2 /hr

Monitoring
Requirements: Re

‐ circulating pump amperage once per shift, Exhaust

fan amperage once per shift, periodic monitoring

c. Control Technology

Wet Scrubbers

V. M ONITORING A PPROACH

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 shiftc. 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. J USTIFICATION

a. Background

The facility manufactures aluminum. The pollutant SO 2 is generated as a part of the process operation. SO 2 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 SO 2 limit. SO 2 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 isthe 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. B ACKGROUND

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/PM 10 Emission Limits: 51.546 lbs PM/hr, 29.89 lbs PM 10 /hr

Monitoring Requirements: Visible emissions, periodic monitoring

c. Control Technology

Dry alumina injection baghouse

VIII. M ONITORING A PPROACH

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. J USTIFICATION

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 PLANP ARAMETRIC M ONITORING M ETHODOLOGY AND R ATIONALE



## 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 Regulatio ns 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 (Qua litative and Method 9)

C. Control Technology

Dry Alumina Scrubber 330140 as common control device for al l three regulated sources.

D. Compliance Schedule

The permittee shall implement the parametric m onitoring plan (with latest revision date of February 4, 2011) within 120 da ys of the approval date (U . S. EPA approved the plan on February 7, 2011).Monitoring Approach for Carbon BakeA. IndicatorGas Flow RateAlumina Flow Rate Gas Temperature (BH Inlet)Visible EmissionsMeasurementApproachDifferential pressure iscontinuously measured at multiplelocations by RosemountDifferential Pressure Transmittersand then flow is calculated into atotal flow using calculationdescribed in operating manualSection 2, Page 8-9 (AppendixA).The frequency of the rotary vanefeeder monitored in hertz by 1771-IFE Analog Input Cards, translatedto rotations, and then, knowing thepocket fill, calculated to lbs/hr offlow.The temperature of the exhaustgas entering the baghouse iscontinuously monitoredVisible emissions will be observedby a trained observer at least onceper day if weather permits. Ifvisible emissions are observedwhich are indicative of abnormaloperation, a full Method 9 will beconducted within 1 hour orwhenever weather permits.B. Indicator Range119,232-145,728 scfm >43 Hz (3,475 lbs/hr) 170-208oF Visible Emissions - Daily< 20% - Method 9Excursions trigger inspection,corrective action, and reporting.C. PerformanceCriteriaDataRepresentativenessThe pressure transmitters have aminimum accuracy of +0.075%±0.5% ±0.6% Observations are performed at thestack exhaust while the unit isoperating.Verification ofOperational StatusThe system continuously monitorsfor flow and will alarm the operatorif a low gas flow condition exists.The system has flow sensors atthe rotary airlock discharge, thedistribution box which distributesalumina to the reactor modules,and at each reactor module. If theairlock is not operating, thedistribution box does notdischarge, or the reactor modulesare not receiving flow, then analarm displays on the operatorsscreen requiring operatorintervention.NA NAQA/QC Practices andCriteriaThe pressure transmitters arecalibrated annually to a NISTtraceable standard.Verification that actual flow exitingthe feeder matches expected flowonce per quarter. Inspection andadjustment of vane bladeclearance to manf. specs. onceper quarter.The thermocouples andtemperature transmitters arecalibrated annually to a NISTtraceable standard.Observers recertified to M9 every6 monthsMonitoring Frequency Continuously Continuously Continuously Daily qualitative, M9 quantitative ifvisible emissions are observed.M9 minimum once per weekData CollectionProcedures15 minute instantaneous readingsare recorded. The PLC thencalculates and records 2-hraverage using the 15-minutereadings.15 minute instantaneous readingsare recorded. The PLC thencalculates and records 2-hraverage using the 15-minutereadings.15 minute instantaneous readingsare recorded. The PLC thencalculates and records 2-hraverage using the 15-minutereadings.Qualitative recorded by operatorQuantitative documented onSSOP 810-011FABoth kept for at least five yearsAveraging Period 2 hours 2 hours 2 hours 6 minute

## 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 Regulatio ns 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 (Qua litative and Method 9)

C. Control Technology

Dry Alumina Scrubber 480063 for ducted emi ssions from individual reduction cells

Stack – Emission Point 89

Roof Monitor – Emission Point 90

D. Compliance Schedule

The permittee shall implement the parametric m onitoring plan (with latest revision date of February 4, 2011) within 120 da ys of the approval date (U . S. EPA approved the plan on February 7, 2011).Monitoring Approach for Potline 5A. IndicatorGas Flow RateAlumina Flow RateVisible Emissions Potshield MaintenanceMeasurementApproachGas flow is ensured bymeasurement of systemdifferential pressure at the manifoldleading to the baghouse (systempressure).Alumina flow is measured in lbs/hrby a Milltronics Model E-40 impactflow meter and recorded to thePLC every 15 minutes andcombined as a 2-hour rollingaverage.Visible emissions will be observedby a trained observer at least onceper day if weather permits. Ifvisible emissions are observedwhich are indicative of abnormaloperation, a full Method 9 will beconducted within 1 hour orwhenever weather permits.Shields are informally inspecteddaily by operators as part of theSSOP for anode changing.Shields are formally inspectedweekly.B. Indicator Range3.41-3.59 in H2O > 19,623 lbs/hr Visible Emissions - Daily< 20% - Method 9Excursions trigger inspection,corrective action, and reporting.Informal daily inspections will resultin realignment of shields asnecessary.Formal weekly inspection willidentify damage creating gaps.C. PerformanceCriteriaDataRepresentativenessThe pressure transmitters have aminimum accuracy of +0.075%±0.5% Observations are performed at thestack exhaust while the unit isoperating.NAVerification ofOperational StatusThis system pressure is displayedon the operator's control screen.The system continuously monitorsthe system pressure and alarmsthe operator if it falls below theminimum.The system has flow sensors at thealumina distribution box and ateach reactor module. If thedistribution box does not dischargeor the reactor modules are notreceiving flow, then an alarmdisplays on the operators screenrequiring operator intervention.NA NAQA/QC Practices andCriteriaThe pressure transmitters will becalibrated annually to a NISTtraceable standard.The impact flowmeter will becalibrated annually to a NISTtraceable standard.Observers recertified to M9 every 6monthsOperators are trained to the SSOPand alignment practices.Personnel performing weeklyinspections are trained to indentifyshields that need replacement.Monitoring Frequency Continuously Continuously Daily qualitative, M9 quantitative ifvisible emissions are observed.M9 minimum once per weekInformal – DailyFormal - WeeklyData CollectionProcedures15 minute instantaneous readingsare computed and recorded. ThePLC then calculates and records 2-hr average using the 15-minutereadings.15 minute instantaneous readingsare recorded. The PLC thencalculates and records 2-hraverage using the 15-minutereadings.Qualitative recorded by operatorQuantitative documented on SSOP810-011FABoth kept for at least five yearsInformal – NAFormal – Documentedelectronically with corrective actiontracked to completionAveraging Period 2 hours 2 hours 6 minute NA

## GREEN CARBON

A. Regulated Source(s)

Description: Green Carbon (Anod e 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 Regulatio ns 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 (Qua litative and Method 9)

C. Control Technology

Dry Coke Scrubber (Pitch Fume Scrubber)

D. Compliance Schedule

The permittee shall implement the parametric mon itoring 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 CarbonA. IndicatorGas Flow Rate Coke Flow RateVisible EmissionsMeasurementApproachGas flow is continuously measured usingBrandt Flow Meter located in the exhaust stack.The frequency of the rotary vane feedermonitored in hertz by 1771-IFE Analog InputCards, translated to rotations, and then,knowing the pocket fill, calculated to lbs/hr offlow.Visible emissions will be observed by a trainedobserver at least once per day if weatherpermits. If visible emissions are observedwhich are indicative of abnormal operation, afull Method 9 will be conducted within 1 hour orwhenever weather permits.B. Indicator Range40,000-55,000 SCFM >50 Hz (1.97 tons/hr) Visible Emissions - Daily< 20% - Method 9Excursions trigger inspection, corrective action,and reporting.C. PerformanceCriteriaDataRepresentativenessThe pressure transmitters have a minimumaccuracy of +0.5%±0.5% Observations are performed at the stackexhaust while the unit is operating.Verification ofOperational StatusThis system flow is displayed on the operator'scontrol screen. The system continuouslymonitors the air flow and alarms the operator ifit falls below the minimum.The system has flow sensors at the rotaryairlock discharge, the distribution feeders thatdistribute coke collection system duct work andventure reactor. If the airlock is not operating,the distribution feeders are not operating, or thereactor is not receiving flow, then an alarmdisplays on the operators screen requiringoperator intervention.NAQA/QC Practices andCriteriaThe flow meter will be calibrated annually to aNIST traceable standard.Verification that actual flow exiting the feedermatches expected flow once per month.Inspection and adjustment of vane bladeclearance to manf. specs. once per quarter.Observers recertified to M9 every 6 monthsMonitoring Frequency Continuously ContinuouslyDaily qualitative, M9quantitative if visibleemissions are observed.M9 minimum once per weekData CollectionProcedures15 minute instantaneous readings arecomputed and recorded. The PLC thencalculates and records 2-hr average using the15-minute readings.15 minute instantaneous readings arerecorded. The PLC then calculates andrecords 2-hr average using the 15-minutereadings.Qualitative recorded by operatorQuantitative documented on SSOP 810-011FABoth kept for at least five yearsAveraging 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 Regulatio ns 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 (Qua litative 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 mon itoring 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 1-4A. IndicatorGas Flow Rate Water Flow Rate Secondary Current &VoltageVisible Emissions Potshield MaintenanceMeasurementApproachThe amperage of the fan motorsmonitored by 1771-IFE Analog InputCards.Number of fans in operationWater flow into each individual scrubbervia flow meterESP secondary voltage andcurrent are measured for eachfield. The secondary voltage ismeasured using a voltmeterand the secondary current ismeasured using an ammeter.Visible emissions will be observed by atrained observer at least once per day ifweather permits. If visible emissions areobserved which are indicative ofabnormal operation, a full Method 9 willbe conducted within 1 hour or wheneverweather permits.Shields are informally inspected dailyby operators as part of the SSOP foranode changing.Shields are formally inspectedweekly.B. Indicator Range170-210 amps3 Fans Operating per side (6 total)Water Flow –See Table 3.4.2.(C)-1 onPage 32for indicator rangesSecondary Current80-156 mASecondary Voltage20-29 mVVisible Emissions - Daily< 20% - Method 9Excursions trigger inspection, correctiveaction, and reporting.Informal daily inspections will result inrealignment of shields as necessary.Formal weekly inspection will identifydamage creating gaps.C. PerformanceCriteriaDataRepresentativenessFan Amps ±0.5%# Fans Operating – 100%Flow Meters ±1.0% The voltage and current aremeasured using theinstrumentation themanufacturer provided with theESP.Observations are performed at the stackexhaust while the unit is operating.NAVerification ofOperational StatusThis failure or operation out ofindicator range is displayed on theoperator's control screen. Thesystem continuously monitors the fanamperage and alarms the operator ifit falls below the minimum or a fanshuts down.The system will alarm the operator if thepump shuts down.Confirm the meters read zerowhen the unit is not operating.NA NAQA/QC Practices andCriteriaThe measurement device iscalibrated at least annually to a NISTtraceable standard.The measurement devices are calibratedat least annually to a NIST traceablestandard.The measurement devices arecalibrated at least annually to aNIST traceable standard.Observers recertified to M9 every 6monthsOperators are trained to the SSOPand alignment practices.Personnel performing weeklyinspections are trained to indentifyshields that need replacement.

# Attachment #2Monitoring Frequency ContinuouslyContinuously The secondary voltage andcurrent are measured onceevery 15 minutes to calculatethe total power input onceevery 15 minutes.Daily qualitative, M9quantitative if visibleemissions are observed.M9 minimum once per weekInformal – DailyFormal – WeeklyData CollectionProcedures15 minute instantaneous readings arecomputed and recorded for fan amps.The PLC then calculates and records2-hr average using the 15-minutereadings.15 minute instantaneous readings arerecorded for each scrubber. The PLCthen calculates and records 2-hr averageusing the 15-minute readings.15 minute instantaneousreadings are recorded. ThePLC then calculates andrecords 2-hr average using the15-minute readings.Qualitative recorded by operatorQuantitative documented on SSOP 810-011FABoth kept for at least five yearsInformal – NAFormal – Documented electronicallywith corrective action tracked tocompletionAveraging Period 2 hours 2 hours 2 hours 6 minute NA

# Attachment #3

# Attachment #4

## MATERIAL SAFETY DATA SHEET

1. CHEMICAL PRODUCT AND COMPANY IDENTIFICATION

KOPPERS INC. MEDICAL EMERGE NCIES: 877-737-9047

436 SEVENTH AVENUE MEDICAL EMERGENCIES OU TSIDE U.S.A.: 651-632-9269

PITTSBURGH, PA 15219-1800 TECHNICAL ASSISTANCE: 412-227-2001

naorgmsds@koppers.com MSDS REQUESTS: 866-852-5239

CHEMTREC ASSI STANCE: 800-424-9300

CANUTEC: 613-996-6666

MSDS NUMBER: 00228307



### SUBSTANCE: CARBON PITCH LIQUID

TRADE NAMES/SYNONYMS: 925 PITCH LIQUID; CA RBON 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 ir ritation, eye irritati on, lung cancer, skin cancer, bladder cancer, scrotal cancer

PRECAUTIONARY STATEMENTS: Do not breathe vapor or mist. Do not get in eyes, on skin, or onclothing. Keep container tightly clos ed. Wash thoroughly after handling. Us e only with adequate ventilation. Observe good hygiene and safety practices when handli ng this product. Do not us e 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 coordinati on, 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 s unlight, skin cancer, scrotal cancer

EYE CONTACT:

SHORT TERM EXPOSURE: irritation, sensitivity to sunlight, ey e 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, INFORM ATION 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-BENZPHENANTHRENECAS 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 uncontamin ated area. Give artific ial respiration if not breathing. If breathing is difficult, oxygen should be administered by qua lified 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 l east 15 minutes, or use a wa terless 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 sw allowed, get medical attention. Do not give anything by mouth to unconscious or c onvulsive 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 a nd decomposition products may be released, forming flammable/explosive mi xtures in air. Containers may rupt ure or explode if exposed to heat.

EXTINGUISHING MEDIA: regular dry chemical, carbon di oxide, regular foam, water spray

FIRE FIGHTING: Avoid inhalation of material or combustion by-products. St ay upwind and keep out of low areas. Use extinguishing agents a ppropriate for surrounding fire. Flood with fine water spray. Directly spraying water or foam onto hot burning product may cause frothing. For fires in carg o or storage area: Cool

containers with water from unmanned hose holder or monito r nozzles until well after fire is out. If this is impossible then take the following precautions: Keep unn ecessary people away, isolat e hazard area and deny entry. Withdraw immediately in case of rising sound from venting safety de vice 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 appropr iate container for disposal. In Ca nada, report releases to provincial authorities, municipal author ities, or both, as required. Due to the concentration of Benzo(a)pyrene and the CERCLA (40 CFR 302.4) reportable qua ntity 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-v entilated place. Keep away from heat, sparks and flame. Protect from physical damage. Notify State Emergency Res ponse 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 emergenc y response planning (U.S. EPA 40 CFR 355.30).

HANDLING: Avoid breathing vapors of heated materials. Avoid contact with ey es, skin and clothing. When using, do not eat, drink or smoke. Wash exposed ar eas thoroughly with soap an d water, or a waterless handcleaner, after skin contact a nd before eating, drinking, using t obacco 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 applie d prior to application of a prot ective 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 (ben zene soluble fraction) 0.1 mg/m3 NIOSH recommended TWA 10 hour(s) (cyclohexane extractable fraction)

VENTILATION: Ensure adequate ventilation. Ensure co mpliance with applicab le exposure limits.

EYE PROTECTION: ANSI Z87.1-1989 approved safety glasses w ith side shields. Provide an emergency eye wash fountain and quick drench shower in the immediate work ar ea. 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. Cont aminated 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 ma terial is at an elevated temp erature, 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 ex ceeded, use canister or cartridge respirators, which are MSHA/NIOSH-approved, w ith organic vapor cartridges.



### 9. PHYSICAL AND CHEMICAL PROPERTIESPHYSICAL 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 temp eratures 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, ca rbon 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, (S ee below for additional information on component carcinogen status)

TARGET ORGANS: respiratory tract system, sk in, eyes, bladder, scrotum

MEDICAL CONDITIONS AGG RAVATED 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 car cinogenic in humans. IARC's conclusion is based upon studies suggesting an association betw een skin cancer and chronic occupa tional dermal exposure to coal tar pitches and upon other historical st udies and anecdotal reports showi ng an association between dermal exposure to coal tar pitch and scrotal can cer 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 co al tar pitch vola tiles in excess of the recommended permissible exposure level. Studies also suggest an association between lung cancer and ch ronic inhalation overexposure to coal tar pitch volatile s in excess of the recommended perm issible exposure level. A recent animal study may suggest an associ ation between lung cancer and pulmona ry deposition of particulate matter originating from coal tar pitches. It is not anticipate d, 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 -Confirme d Human Carcinogen (Coa l tar pitch volatiles)

LOCAL EFFECTS: Irritant: skin, eye

MEDICAL CONDITIONS AGG RAVATED 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 TRANSPORTATIO N OF DANGEROUS GOODS:

SHIPPING NAME: Elevated temperature liquid, n.o.s.

UN NUMBER: UN3257

CLASS: 9

PACKING GROUP/RISK GROUP: III



### 15. REGULATORY INFORMATIONU.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 Califor nia 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)FLUORANTHENECancer (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 Syst ems, Inc. All rights reserved.

The information set forth in this Material Safety Da ta Sheet does not purport to be all-inclusive and should be used only as a guid e. While the information and recomm endations 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. Se e 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 b y one or more regulatory agencies and were identifi ed in typical coal tar pitch samples at concentrations greater than 0.01% by weight but less than SARA Se ction 313 de minimis concentrations using gas chromatogra phy/mass spectroscopy USEPA Reference Methods 8240 (volatile organic compounds) and 8270 (semi-vo latile organic compounds), along with sample preparation method USEPA Reference Method 3510 (sep arator 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 ignit ion.

Means of Extinction : Sand, C0
2 , foam, water fog, dry chemical, steam.

Fire Fighting Procedures : Wear complete fire service protective equipment, in cluding full-face MSHA/NIOSH approved self-contained breath ing apparatus. Use water or water spray to cool fire-e xposed containers and structures and to protect personnel. Water/fog can control unconfined pitch fires, but w ater 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. Air borne pitch dust may form explosive mixtures with air. C loud ignition temperature is 710°C minimum. Explosion concentration (dust) 1000 mg/ 0.03 m3. Closed cont ainers may explode when exposed to extreme heat. Liquid (molten) pitch at elevated temperatures will sustai n combustion.

Hazardous Combustion Products : CO
2 , CO, NO x , SO
2 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 mo lten 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 materia l may cause thermal
burns.

Skin Contact : Contact with the skin can result in irritation whic h, 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, folli culitis and more serious skin disorders such as changes in skin pigm entation, ulcerations, benign skin growths and skin cancer.

Inhalation : Inhalation of fumes or vapours may cause temporary respiratory irritation. Acute respiratory effects caused by ov er-exposure to coal tar pitch volatiles may include coughing, sneezing, and swollen or irritated
nasal mucosa or sinuses. Inhalation of fumes or va pours in significant excess of the PEL/TLV may lead to systemic symptoms such as salivation; vomiting; respiratory difficulties; hea dache; loss of pupillary reflexes; central nervous system (CNS) effects such as dizziness, weakness, possible loss of coordination and collaps e; cyanosis; hypothermia; and convulsions.

Ingestion : Ingestion may cause irritation of the gastrointesti nal tract followed by one or more of the following: nausea, vomiting, and abd ominal 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 vol atiles, 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 Chr onic Exposure”
above.

Reproductive Toxicity and Teratogenicity: None known. Although coal tar pitch does contain s ubstances considered to be reproductive hazards by the State of California, no scientific study supports an association between co al 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 “Effect s of Acute Exposure”)
above.

Mutagenicity: Available data characterizes coal tar pitch as a mu tagen.

7 - FIRST AID

Skin Contact : For contact with molten product, do not remove cont aminated clothing. Flush skin immediately with large amounts of cold w ater. If possible, submerge area in cold water. Pack with ice. Seek medical aid immediately. For other contact, remove all contami nated 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 me dical aid immediately.

Inhalation : Remove subject from exposure area to fresh air imme diately. 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 t o prevent further absorption. Do not give anything by mouth to an un conscious person. Give oxygen if respiration is shallow. Seek medica l 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 follo wing, as required: a half-face piece or a full-face piece respirator wit h an organic vapour/ particulate cartridge; or a full-face piece continu ous flow, positive pressure air supplied respirator.

Skin Protection : Wear full body, industrial-type work clothing close d 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 c ertain 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 b efore reuse.

Eye Protection : Wear chemical/industrial safety glasses (with side shields), goggles, or face shields to prevent eye contact. Do not wear c ontact 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 a fter handling and especially before eating, drinking, using tobacco p roducts 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 a nd launder contaminated clothing separate from other laundry b efore reuse.
Saturated shoes/boots should be discarded.

Handling Procedures/ Equipment: Avoid prolonged or repeated contact with skin or br eathing of fumes/ vapours. Observe good personal hygiene practices a nd recommended procedures. Avoid contact with molten material. W ear appropriate protective equipment when performing maintenance on contaminated equipment. Closed system handling of liquid pitch c ould create excessive vapour concentrations in confined spaces; e.g., tanks, rail cars, tank trailers. When entering a confined spac e that has been in liquid pitch service follow confined space entry pr ocedures set forth in the applicable regulations.

Engineering Controls : Provide sufficient general or local exhaust ventila tion 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 ey es. Remove all ignition sources. Try to stop the source of the le ak if possible without hazard. Ventilate the area if spill occurs indoor s. Release or spillage of solid can be treated as a coal spillage and recover y made avoiding skin and eye contact. Shovel into dry, labeled containe rs and secure cover. Contain runoff of fire control water. If hot liqui d 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/fum es/vapours. Provide cleanup personnel with appropriate protective cloth ing.

In cases involving release to the environment, in C anada report to provincial authorities, municipal authorities, or b oth, as required; in the U.S., report the release to The National Response C enter 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 notificatio n.

Waste Disposal : In Canada, dispose of the material in accordance wi th 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 f rom 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 (con tains 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, P G 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, P G 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 (con tains 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. (co ntains benzo (a)pyrene and dibenz(a,h)anthracene), 3, UN 3256, P G 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, R Q (contains benzo(a)pyrene and dibenz(a,h) anthracene).

TSCA Status : This product appears on the Toxic Substances Contro l Act (TSCA) Inventory.

California Proposition 65: WARNING : This product contains a chemical known to the Sta te 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 Emerge ncy 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 lis ted in Section 3 which occur at a concentration gre ater than 0.01 % by weight and which are listed as a car cinogen 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 chromat ograph/mass spectroscopy USEPA Reference Methods 8240 (volatile organic compounds) and 8270 (semi-volatile organic compounds), along with sampl e preparation method USEPA Reference Method 3510 (sep aratory 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 GUIDELINES 1

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/ft 3 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 

# C I I 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 ( o F) Not Applicable Autoignition Temperature ( o F) 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/CO 2 ), 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 

# C I I

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 UnstableMaterial 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/m 3 None Established 10 mg/m 3 Total - Time Weighted Average

3 mg/m 3 5 mg/m 3 None Established Respiratory - Time Weighted Average

None Established 15 mg/m 3 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: 

# C I I

## MATERIAL SAFETY DATA SHEET

1. CHEMICAL PRODUCT AND COMPANY IDENTIFICATION

KOPPERS INC. MEDICAL EMERGE NCIES: 877-737-9047

436 SEVENTH AVENUE MEDICAL EMERGENCIES OU TSIDE U.S.A.: 651-632-9269

PITTSBURGH, PA 15219-1800 TECHNICAL ASSISTANCE: 412-227-2001

naorgmsds@koppers.com MSDS REQUESTS: 866-852-5239

CHEMTREC ASSI STANCE: 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-DIS TILLED 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 ir ritation, eye irritati on, 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 clos ed. Wash thoroughly after handling. Us e only with adequate ventilation. Observe good hygiene and safety practices when handli ng this product. Do not us e 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 coordinati on, 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 s unlight, skin cancer, scrotal cancer

EYE CONTACT:

SHORT TERM EXPOSURE: irritation, sensitivity to sunlight, ey e 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, INFORM ATION 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: 0.67-1.19COMPONENT: 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 uncontamin ated area. Give artific ial respiration if not breathing. If breathing is difficult, oxygen should be administered by qua lified personnel. Get immediatemedical 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 l east 15 minutes, or use a wa terless handcleaner, while removing contaminated clothing and shoes. Get immediate medical attention, if needed.

EYE CONTACT: Immediately flush eyes with plenty of wate r for at least 15 minutes. Then get immediate

medical attention.

INGESTION: DO NOT induce vomiting. If a large amount is sw allowed, get medical attention. Do not give anything by mouth to unconscious or c onvulsive 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 a nd decomposition products may be released, forming flammable/explosive mi xtures in air. Containers may rupt ure or explode if exposed to heat.

EXTINGUISHING MEDIA: regular dry chemical, carbon di oxide, regular foam, water spray

FIRE FIGHTING: Avoid inhalation of material or combustion by-products. St ay upwind and keep out of low areas. Use extinguishing agents a ppropriate for surrounding fire. Flood with fine water spray. Directly spraying water or foam onto hot burning product may cause frothing. For fires in carg o or storage area: Cool

containers with water from unmanned hose holder or monito r nozzles until well after fire is out. If this is impossible then take the following precautions: Keep unn ecessary people away, isolat e hazard area and deny entry. Withdraw immediately in case of rising sound from venting safety de vice 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 hazar d area and deny entry. In Canada, report releases to provincialauthorities, municipal author ities, 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-v entilated place. Keep away from heat, sparks and flame. Protect from physical damage. Keep separated from incompatible substa nces. Notify State Emergency Response Commission for storage or use at amounts greater th an or equal to the TPQ (U.S. EP A 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 ey es, skin and clothing. When using, do not eat, drink or smoke. Wash exposed ar eas thoroughly with soap an d water, or a waterless handcleaner, after skin contact a nd before eating, drinking, using t obacco 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 applie d prior to application of a prot ective 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 (ben zene 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 (ben zene soluble fraction) 0.1 mg/m3 NIOSH recommended TWA 10 hour(s) (cyclohexane extractable fraction)

VENTILATION: Ensure adequate ventilation. Ensure co mpliance with applicab le exposure limits.

EYE PROTECTION: ANSI Z87.1-1989 approved safety glasses w ith side shields. Provide an emergency eye wash fountain and quick drench shower in the immediate work ar ea. 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. Cont aminated 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 ma terial is at an elevated temp erature, wear appropriate heatresistant gloves.

PROTECTIVE MATERIAL TYPES: protective skin creams, chemical resistant material, heat resistant

material

RESPIRATOR: If the applicable TLVs and/or PELs are ex ceeded, use canister or cartridge respirators, which are MSHA/NIOSH-approved, w ith 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 temp eratures 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: car bon 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, (S ee below for additional information oncomponent carcinogen status)

TARGET ORGANS: respiratory system, skin, eyes, bladder, scrotum

MEDICAL CONDITIONS AGG RAVATED 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 co al tar pitches are carcinogenic in hum ans. IARC's conclusion is based upon studies suggesting an association betw een skin cancer and chronic occupa tional dermal exposure to coal tar pitches and upon other historical st udies and anecdotal reports showi ng an association between dermal exposure to coal tar pitch and scrotal can cer 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 co al tar pitch vola tiles in excess of the recommended permissible exposure level. Studies also suggest an association between lung cancer and ch ronic inhalation overexposure to coal tar pitch volatile s in excess of the recommended perm issible exposure level. A recent animal study may suggest an associ ation between lung cancer and pulmona ry deposition of particulate matter originating from coal tar pitches. It is not anticipate d, 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. Informati on 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 -Confirme d Human Carcinogen (Coa l tar pitch volatiles)

LOCAL EFFECTS: Irritant: skin, eye

MEDICAL CONDITIONS AGG RAVATED BY EXPOSURE: respiratory disorders, skin disorders, central nervous system disorders

PETROLEUM PITCH:

MEDICAL CONDITIONS AGG RAVATED 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 sk in cancer in humans under conditions of poor personal hygiene, prolonged/repeated contact, and exposure to s unlight. The National Toxicology Program (NTP) and IARC have independently classified various PAH compounds present in co al tar substances as reasonably anticipated to be human carcinogens (NTP), probabl y carcinogenic to humans (IARC Group 2A), possibly carcinogenic to humans (IARC Group 2B), and not classi fiable as to carcinogenicity to humans (IARC Group 3). The cancers reported in th e studies upon which IARC based its conclusions involved lung, skin, liver, stomach, kidney and blood cancers in animals. Ba sed on the results of anim al experiments PAHs may cause injury to the liver, kidneys, lu ngs, blood and lymph systems. Some PAH's have also been associated with impaired fertility, heritable gene tic 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 1 00 lb(s) (45.4 kg(s)) 1,2-Benzanthracene 10 lb(s) (4.54 kg(s)) 1,2-Benzphenanthrene 1 00 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 de pends on temperature of product. Product in Tank Car or Tank Truck is shipped as 'Elevated temperature liquid, n.o.s.' 'Other regulated substances, soli d, 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 1 00 lb(s) (45.4 kg(s)) 1,2-Benzanthracene 10 lb(s) (4.54 kg(s)) 1,2-Benzphenanthrene 1 00 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 de pends on temperature of product. Product in Tank Car or Tank Truck is shipped as 'Elevated temperature liquid, n.o.s.' 'Other regulated substances, soli d, n.o.s.' applies for all

container sizes.CANADIAN TRANSPORTATIO N 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 Califor nia 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)pyreneCancer (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 Syst ems, Inc. All rights reserved.

The information set forth in this Material Safety Da ta Sheet does not purport to be all-inclusive and should be used only as a guid e. While the information and recomm endations 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 30303Century 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 OPERAT ING 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/A node 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 PR ACTICES/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 ................................................................ 35Century 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/Ano de 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 PlanCentury 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 E nvironmental Protection Agency (EPA) promulgated the National Emissions Standard s for Hazardous Air Pollutants (NESHAP) for Primary Aluminum Reduction Plants (40 CFR Part 63 subpart LL). A speci fic provision of the rule (40 CFR Part 63.850(c)) requires a covered source to de velop and implement a Startup,

Shutdown and Malfunction Plan for processes covered by the rule.

Century Aluminum of Kentucky LLC (Century ), notified the Kent ucky 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 ru le. As a result, Cent ury is required to de velop and implement a Startup, Shutdown and Malfunction Plan for the cove red processes. The plan must be in place no later than October 8, 1999 for the existing so urces and immediately upon startup for potline

five and the new carbon bake oven.

The following plan has been designed to sa tisfy the requirements found in 40 CFR Part 63.850(c) as well as those found in 40 CFR Pa rt 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 in to a single comprehensive document.

This plan does not circumvent any existi ng requirements related to state or local regulations or permits. Those re quirements should be reviewed and if necessary included as part of the reporting and record keep ing 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 proce ss 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 potlin es, several years. The green mill/anode former operates on a more traditiona l shift or hourly basis.

Activities which occur on a routine basi s can result in processes going through the standard startup/shutdown procedure se veral 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 establ ish 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 f acility (SIC 3334) whic h produces aluminum from the electrolytic reduction of alumina (a luminum oxide) to molten aluminum. Alumina is produced off-site at a refinery and is shipped to the Century f acility by way of river barge or

railroad.

Alumina is reduced to aluminum in a r ectangular 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 to tal 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 pr ior to release to the atmosphere. All of the pots are hooded in order to contai n the emissions and allow for the effective capture of generated exhaust gases. These gases are exhausted thr ough ductwork to a polluti on control system that consists of mechanical multiclone collectors, electrostatic precipitators and wet scrubbers. There are some fugitive emissions that escape the captu re system due to ill fitting hood shields or whenCentury 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 electrolyteCentury 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 conti nuous process. Typically, a pot has a service life of five to eight years in length. As a resu lt, startup and shutdown is limited to individual pots and is not typically a daily occurrence, but is scheduled around the proj ected life of the pot.

The following is the typical startup pro cedure 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 peri od of a least tw enty-four hours.

• Between twenty-four and thir ty hours after the pot is st arted, 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 th e 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 remove d two at a time in order to skim material

from around the corner anodes.

• Approximately thirty-six hours after the molte n bath is added, thr ee shields are removed
and an anode removed. At this time, one cr ucible of molten metal is added to the pot through the hole left by the anode. For the ne xt 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 co mpletion of the scrap metal addition, all hood

shields are removed and alumina is adde d 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 pos sible 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 a nodes are pulled from the pot and the hood shields
removed. At this time, the end walls are knoc ked 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 superstr ucture 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 fort y-eight hours. At that time, all material is removed from the pot in order to facilitate repair.

Once pots are repaired or reworked, they ar e placed back into service utilizing the procedures found in Section a.

2.0 Emission Control Equipment

Regulated emissions from potlines one th rough 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 th e initial particulate removal devices. Exhaust gases then exit the multiclones and are tran sported through ductwork to electrostatic precipitators. These units remove additional part iculate prior to the introduction of the exhaust gases to the induced draft fans. After the fa ns, the exhaust gas passes through wet scrubbers which remove the gaseous fluoride from the exhaus t 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 th e system opened and the fans energized.

• At the start of the fans, the multiclone s immediately become operational. The electrostatic precipitato rs are brought up to temperature a nd the fields energized. The wet scrubbers are also brought up to temperatur e and the scrubbing liquor introduced to the

scrubbers.

• After operating for a period of one to two hour s, operating parameters such as voltage on the electrostatic precipitators and liquor feed rate to the we t 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 proce ss 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 uni ts 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 inle t 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 part ially opened to allow the unit to cool prior

to maintenance.

• For the wet scrubbers, the inle t and outlet of the unit are blanked off. Once the unit is isolated, the liquor feed is turned off and th e vessel drained of a ll possible liquid. Access doors are then opened and the unit is allo wed 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 housi ng 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 conditi on, the pot is not operating corr ectly due to some chemical

or electrical imbalance. This condition coul d result in uneven hea ting of the pot, cold spots, or improper breakdown of the materials in the pot. Causes of the condition could be electrical problems, over f eed or underfeed of raw materials, improper ratio of raw materials, anode problems or pot construction problems.

• Anode failure - During this condition, anodes ma y 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 c ould fall into the crust or molten metal causing mixing and heating problems within the pot.

• Anode Effect — This is an el ectrical condition that causes th e voltage of the pot to rise

due to resistance between the anode and the mo lten bath. At this time, there is uneven heating and improper chemical reaction wh ich 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 pow er outage continues. Emissions typically

increase at this time due to cha nging conditions within the pot.

• Crane Failure — The pots are tended by overhead cranes. When the crane fails and cannot be operated there is th e possibility that the pots cannot be pr operly tended. ThisCentury Aluminum of Kentucky LLC - Hawesville, Kentucky 9
Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001) could result in excessive emissions due to the inability to change a nodes, feed materials or tap metal from the pot.

• Compressor Failure — This condition could resu lt 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 sh ields lead to imprope r hooding of the pot which could cause fugitive emissions from th e pot. Hood shields in disrepair will limit the draft on the pot and allow co ld spots to develop as well as increasing emissions from the potline roof monitors.

The aforementioned causes are those that ar e 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 th e 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 de fined as an event that effects the performance

of the control device.

• Multiclones — malfunctions of multiclone s 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, electr odes, 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 th e point that it impact s the operation of

the unit

- Mechanical failure of the co llector or discharge platesCentury Aluminum of Kentucky LLC - Hawesville, Kentucky 10
Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001) • Wet Scrubbers — malfunctions of the we t 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 th e gas flow to the individual units - Plugging of drain lines and or failure of pumps for rem oving collected liquor from

the vessel

• Induced Draft Fans — malfunctions of the system fans are limited to the following

conditions.

- Electrical failure related to a ssociated electrical equipment. - Mechanical failure of components - Failure of inlet and outlet dampers cont rolling the exhaust gas flow through the

individual units.Century Aluminum of Kentucky LLC - Hawesville, Kentucky 11
Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001) B. Potline Five

1.0 Purpose

The purpose of this procedure is to establ ish 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 f acility (SIC 3334) whic h produces aluminum from the electrolytic reduction of alumina (a luminum oxide) to molten aluminum. Alumina is produced off-site at a refinery and is shipped to the Century f acility by way of river barge or

railroad.

Alumina is reduced to aluminum in a r ectangular 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 cr oss 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 emi ssions and allow for the effective capture of generated exhaust gases. These gases are e xhausted through ductwork to a pollution control system that consists of a dry scrubber (alumina injected fabric filter). There are some fugitiveCentury Aluminum of Kentucky LLC - Hawesville, Kentucky 12
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 exha ust through the potline

roof monitors.

3.0 Procedures

a. Startup/Shutdown Practices

1.0 Aluminum Reduction Pots

Reduction of alumina to aluminum is a conti nuous process. Typically, a pot has a service life of five to eight years in length. As a resu lt, 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 st artup procedure for an individu al 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 peri od of a least tw enty-four hours.

• Between twenty-four and thir ty hours after the pot is st arted, 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 th e 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 remove d two at a time in order to skim material

from around the corner anodes.

• Approximately thirty-six hours after the molte n bath is added, thr ee shields are removed
and an anode removed. At this time, one cr ucible of molten metal is added to the pot through the hole left by the anode. For the ne xt 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 13
Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001) • At approximately the same time as the co mpletion of the scrap metal addition, all hood

shields are removed and alumina is adde d 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 pos sible 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 a nodes are pulled from the pot and the hood shields removed. At this time, the end walls are knoc ked 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 superstr ucture 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 ho urs. 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 cont rolled by an alumina injected dry scrubber. Exhaust gases from the individual pots are cap tured 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 th e system opened and the fans energized.Century Aluminum of Kentucky LLC - Hawesville, Kentucky 14
Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001) • At the start of the fans, alumina is intr oduced to the duct ahead of the dry scrubber.

• After operating for a period of one to two hour s, 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 pro cess is continuous, it is rare that all of the

control devices is shutdown. However individua l modules are taken off-line for maintenance

and are restarted in the same manner.

b. Shutdown

Shutdown typically occurs for individual modul es 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 ga s 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 housi ng 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 th an 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 conditi on, the pot is not operating corr ectly due to some chemical

or electrical imbalance. This condition coul d result in uneven hea ting of the pot, cold spots, or improper breakdown of the materials in the pot. Causes of the condition couldCentury Aluminum of Kentucky LLC - Hawesville, Kentucky 15
Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001) be electrical problems, over f eed 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 po wer to the pot. At this point, cold spots could develop or in some cases the anode c ould fall into the crust or molten metal causing mixing and heating problems within the pot.

• Anode Effect — This is an el ectrical condition that causes th e voltage of the pot to rise

due to resistance between the anode and the mo lten bath. At this time, there is uneven heating and improper chemical reaction wh ich 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 pow er outage continues. Emissions typically

increase at this time due to cha nging conditions within the pot.

• Crane Failure — The pots are tended by overhead cranes. When the crane fails and cannot be operated there is th e possibility that the pots cannot be pr operly tended. This

could result in excessive emissions due to the inability to change a nodes, feed materials or tap metal from the pot.

• Compressor Failure — This condition could resu lt 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 sh ields lead to imprope r hooding of the pot which could cause fugitive emissions from th e pot. Hood shields in disrepair will limit the draft on the pot and allow co ld spots to develop as well as increasing emissions from the potline roof monitors.

The aforementioned causes are those that ar e 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 th e 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 de vice 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.Century Aluminum of Kentucky LLC - Hawesville, Kentucky 16
Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001) 

### a. Emission Control Equipment Malfunctions

• Alumina Feed System - malfunctions of th e 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 F ilter 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 a ssociated electrical equipment. - Mechanical failure of components - Failure of inlet and outlet dampers cont rolling the exhaust gas flow through the

individual units.Century Aluminum of Kentucky LLC - Hawesville, Kentucky 17
Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001) C. Carbon Bake Ovens

1.0 Purpose

The purpose of this procedure is to establ ish the steps necessary for the startup and

shutdown of the bake ovens that cure the car bon anodes used in the aluminum reduction pots. This procedure will be used to address all th ree ovens and their individual sections and the

common control device.

2.0 Process Description

Century is a primary aluminum reduction f acility (SIC 3334) whic h produces aluminum from the electrolytic reduction of alumina (a luminum oxide) to molten aluminum. Alumina is produced off-site at a refinery and is shipped to Century by wa y of river barge or railroad.

Alumina is reduced to aluminum in a r ectangular 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. El ectrical current is transferred through a

sacrificial carbon anode to the molten bath. Th e pot is lined with a carbon cathode material which completes the electrical circuit.

Carbon anodes used in the reduction pots are fo rmed in a separate process located onsite. Anodes are formed in the green carbon area of th e 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 achi eve optimum properties.

At Century, there are three individual ovens. Theses ovens are ring fired open top ovens consisting of individual sections of pits or cel ls. 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 mo vable 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.Century Aluminum of Kentucky LLC - Hawesville, Kentucky 18
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 pr ocess. 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 st artup procedure for an indivi dual section of a bake oven

and reflects conditions used for all sec tions 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 ce lls 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 l ead to air burning of the anodes. Then, the top of the oven is se aled and the combustion manifold moved into place.

• When the manifold is in place, the burner s 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 va rious reasons. Shutdown can occur at the end of a bake cycle or during the cycle due to variances in typical pro cess conditions. For the purpose of this section, shutdown is expressed as the procedure co mpleted at the end of a baking cycle.

• Once a baking cycle is complete, the firing manifold is moved to the next section.Century Aluminum of Kentucky LLC - Hawesville, Kentucky 19
Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001) • Once the fire has been removed from the s ection, the anodes are allo wed to cool. They remain in the covered section for up to 20-48 hou rs while they cool to the point in which they can be safely handled. They also rema in covered until the temp erature 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 anode s 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 inspect ed and prepared to r eceive new green anodes.

1.0 Emission Control Equipment

Regulated emissions from th e 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 cont rol device. The gases then pass through an evaporative cooler that is used to reduce the te mperature and volume of the gas stream. Gas then

enters a section of ductwork where alumina is in jected to react with the gaseous emissions. Reacted alumina, particulate and ot her 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 st arted 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 th e system, all functions related to the cooling tower and alumina feed will be tested for proper function.Century Aluminum of Kentucky LLC - Hawesville, Kentucky 20
Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001) • Immediately prior to the introduction of e xhaust gas to the system, the water to the cooling tower should be turned on and alumin a 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 star tup procedure is for startup when the entire system has been down. Since the fabric filt er 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 gr eater than twenty-four hours, cycle through the bag cleaning cycle on the fabric filter a nd remove any alumina from the reactor.

In all cases, the facility procedure for conf ined 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 emi ssions or directly imp act 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 coul d 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 unev en 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 conditi on leads to combustion of the

carbon and the volatiles and de gradation of the anode

• Refractory failure — this malfunction is the resu lt of the failure of the refractory material

that lines each cell in the ove n 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 cr acking 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 se ctions 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 indivi dual sections of an oven.

• Fire — this malfunction can lead to ex cess 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 doc ument. Other conditions may be deemed a malfunction at the time they occur but are typica lly limited in frequency and duration. TheCentury Aluminum of Kentucky LLC - Hawesville, Kentucky 22
Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001) events mentioned above have the highest potenti al 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 im pact the operation of all of the ovens. For the purpose of this section, a malfunction is define d 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 indi vidual 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 possi ble 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 c ontrol 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 degrad es the performance of the control system.

The aforementioned events are those that ar e considered malfunctions that would impact the efficiency of the system. Other events ma y be deemed malfunctions at the time they occur but are not listed because they are typically li mited in frequency and duration. The conditions mentioned above have the highest potential to ca use 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 establ ish 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 w ill 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 whic h produces aluminum from the electrolytic reduction of alumina (a luminum oxide) to molten aluminum. Alumina is produced off-site at a refinery and is shipped to the Century f acility by way of river barge or

railroad.

Alumina is reduced to aluminum in a r ectangular 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 proc ess which consists of mixing and forming of raw materials used to produce green anodes.

Anodes consist of recycled anode material (g reen or baked or butts returned from the potline), petroleum coke and coal tar pitch. Thes e materials are mixed in batches according to a

standard formulation. Batch material is then co nveyed as a paste to the anode former where the material is shaped by vibration and compacti on into what is known as a green anode. Once formed, the green anode proceeds to further proce ssing 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 th e 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.Century Aluminum of Kentucky LLC - Hawesville, Kentucky 24
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-cont inuous batch process. Anodes are produced from a paste mixture made by combining petrol eum coke, coal tar pitch and recycled carbon material in the form of reject paste, crushed an odes or carbon fines. As a result, startup and shutdown for this portion of the plan is limited to the mixers us ed to produce the anode paste.

The following are the typical startup and shut down procedures for an individual mixer and the paste transport conveyor. These conditions re flect 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 ra w materials to the mixer. Once that occurs,

the mixer is turned on and the materials mixe d 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 ti me 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 transpor ts 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.Century Aluminum of Kentucky LLC - Hawesville, Kentucky 25
Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001) 2.0 Anode Former

Formation of green anodes is a mechanical process that uses pre ssure 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, th e batch mixers and conveyors should be on line and operating.

• Prior to startup, the feed bin, conveying syst em 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 syst em should be checked for function.

• Once all of the preliminary steps are comple ted, 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 fl ow 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.Century Aluminum of Kentucky LLC - Hawesville, Kentucky 26
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 sy stem, 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 w ould 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 ventur i 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 l onger than twenty-four hours, cycle through the cleaning cycle and remove any c oke 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 malfuncti ons 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 syst em is interrupted causing an imbalance in the recipe.

• Heater failure — heat to th e pitch is disabled causing impr oper feed rate to the mixer.

• Mixer failure - The mixer ceases proper operation.

• Conveyor failure — Transport of mixed past e ceases causing a b ackup 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 aforem entioned 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 occu r 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 re sult in increased emissions from the process.

• Power failure — power to the system is discontinued causing a b ackup in the system.

• System plugging — the feed bin plugs cau sing material flow to be discontinued.

• Conveyor failure — conveyors bringing past e 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.Century Aluminum of Kentucky LLC - Hawesville, Kentucky 28
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 reas ons. For the purpose of this section, a

malfunction is defined as an event that eff ects 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 cont rol 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 degrad es the performance of the control system.

The aforementioned events are those that ar e considered malfunctions that would impact the efficiency of the system. Other events ma y be deemed malfunctions at the time they occur but are not listed because they are typically li mited in frequency and duration. The conditions mentioned above have the highest potential to ca use excessive or greater than normal emissions from the systemCentury 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 th e corrective action pract ices and procedures for conditions that

could occur outside of no rmal-operating procedures.

The individual practices and procedures c over 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 ba sis and are typically re lated 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 main tenance 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 th at may arise as a result of st artup, shutdown or malfunction of covered processes. For the purpose of this procedure, the correctiv e 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 a nd procedures expressed in this section are to be used to correct problems that could resu lt in greater than normal emissions from the covered processes.

a. Startup And Shutdown

1.0 Aluminum Reduction Pots

Startup and shutdown of reducti on pots occurs on a routine basis depending on the life cycle of the individual pots. Startup of individual pots shall o ccur as detailed in Section II A (3.0)(a) of this manual. Shutdown of individua l pots shall occur as de tailed in Section II A (3.0)(b) of this manual.

Deviation from the aforementioned procedures shall not be percei ved as a malfunction requiring corrective action unless em issions generated as a result of the deviation are typically greater than those genera ted 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 possi ble but in no case greate r than twenty-four hours

after the condition is identified unless circumst ances prevent the correction. In that case, notification will be made following the proced ures found in Section V of this manual.

The following is the procedure for identifyi ng 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 situ ation in order to alleviate th e 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 31
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 re sult of failure of equipm ent, process upsets or other issues beyond the normal control of facil ity 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 no t 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 exce ss of those typical during normal startup and shutdown procedures shall be corr ected 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 identif ying the condition and implementing corrective

action.

• Identify the condition and determine if it is outside of the norma l startup and shutdown procedures.

• Take action to correct the situati on in order to alleviate the problem.

• If the condition results in emissions be yond 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 ar e found in Section II(A)(3.0)(b) of this

manual. These malfunctions are those that have th e potential to generate emissions in excess of normal conditions for a period great er than one hour in length.Century Aluminum of Kentucky LLC - Hawesville, Kentucky 32
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 relate d to the identified problem

- If the problem cannot be corrected within twenty-four (24) h ours, 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 condi tion 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 corr ection action to quench the effect using the computer or manual controls or using a physical means of alte ring the resistance.

• Power Outage - Make all efforts to restore power to th e impacted equipment as soon as possible. If the duration of the outage is longer than one hour, initiate pr ocedures to isolate and idle the pots to maintain heat.

• Crane Failure - Make all efforts to repair the crane or move a repl acement into place to tend the

pots. - If the duration of the repair is long, initi ate procedures to alte rnately tend affected

pots.

• Compressor Failure - Make necessary repairs or provide an alternate means of supplying air to the

affected area.Century Aluminum of Kentucky LLC - Hawesville, Kentucky 33
Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001) • Hood Shield Failure

- Repair or replace affected sh ields 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 pe rformance of the control device

and lead to an increase in emissions.

• Identify the cause of the problem.

• Initiate corrective action which could in clude equipment shutdown, maintenance or optimization.

• Document the condition and duration of th e 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 th at may arise as a result of st artup, shutdown or malfunction of covered processes. For the purpose of this procedure, the correctiv e 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 a nd procedures expressed in this section are to be used to correct problems that could resu lt in greater than normal emissions from the covered processes.

a. Startup And Shutdown

1.0 Aluminum Reduction Pots

Startup and shutdown of reduc tion pots occurs on a routine basis depending on the life cycle of the individual pots. Startup of individual pots shall o ccur as detailed in Section II B (3.0)(a) of this manual. Shutdown of individua l pots shall occur as de tailed in Section II B (3.0)(a) of this manual.

Deviation from the aforementioned procedures shall not be percei ved as a malfunction requiring corrective action unless em issions generated as a result of the deviation are typically greater than those genera ted 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 possi ble but in no case greate r than twenty-four hours after the condition is identified, unless circumstances prevent the correction. In that case, notification will be made following procedur es found in Section V of this manual.

The following is the procedure for identif ying 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 situ ation in order to alleviate th e 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 a ddressed as part of th is plan. This plan will only involve non-routine issues that are the re sult of failure of equipm ent, process upsets or other issues beyond the normal control of facil ity 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 no t 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 exce ss of those typical during normal startup and shutdown procedures shall be corr ected 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 identif ying the condition and implementing corrective

action.

• Identify the condition and determine if it is outside of the norma l startup and shutdown procedures.

• Take action to correct the situati on in order to alleviate the problem.

• If the condition results in emissions be yond 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) h ours, 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 condi tion 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 corr ection action to quench the effect using the computer or manual controls or using a physical means of alte ring the resistance.

• Power Outage - Make all efforts to restore power to th e impacted equipment as soon as possible. If the duration of the outage is longer than one hour, initiate pr ocedures to isolate and idle the pots to maintain heat.

• Crane Failure - Make all efforts to repair the crane or move a repl acement into place to tend the

pots. - If the duration of the repair is long, initi ate procedures to alte rnately 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 sh ields 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 pe rformance of the control device

and lead to an increase in emissions.

• Identify the cause of the problem.

• Initiate corrective action which could in clude equipment shutdown, maintenance or optimization.

• Document the condition and duration of th e 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 th at may arise as a result of st artup, shutdown or malfunction of the covered processes. For the purpose of this procedure, th e 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 a nd procedures expressed in this section are to be used to correct problems that could resu lt in greater than normal emissions from the covered processes.

a. Startup and Shutdown

1.0 Carbon Bake Ovens

Startup and shutdown of secti ons of the bake oven or the entire oven occu r on a routine

basis as detailed in Section II C (3 .0)(a) of this document.

Deviation from the aforementioned procedures shall not be percei ved as a malfunction requiring corrective action unless em issions generated as a result of the deviation are typically greater than those genera ted 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 possi ble but in no case greate r than twenty-four hours

after the condition is identified unless circumst ances prevent the correction. In that case, notification will be made following the proced ures found in Section V of this manual.

The following is the procedure for identif ying the condition and implementing corrective

action.

• Identify the condition or event and determin e if it is outside of the normal startup and shutdown procedures.

• Take action to correct the situ ation in order to alleviate th e 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 t ypically does not occur on a routine basis. If the system goes through startup and shutdown, the procedures f ound in Section II C (3.0)(a) will apply.

Deviation from the aforementioned procedures shall not be percei ved as a malfunction requiring corrective action unless emi ssions generated as a result of the deviation are greater than those generated during normal st artup and shutdown procedures.

Conditions that generate emissions in excess of those typical during startup and shutdown procedures shall be corrected as soon as possi ble but in no case greate r than twenty-four hours

after the condition is identified unless circumst ances prevent the correction. In that case, notification will be made following the proced ures found in Section V of this document.

The following is the procedure for identif ying the condition and implementing corrective

action.

• Identify the condition or event and determin e if it is outside of the normal startup and shutdown procedures.

• Determine if as a result of the condition or event there is the pote ntial for greater than normal emissions from the process.

• Take action to correct the situ ation in order to alleviate th e problem and the potential for greater than normal emissions.

• If the condition or event results in emi ssions beyond the norm, document the condition and duration utilizing the form found in Appendix A

• If the condition or event exceeds a twenty-f our hour period, report the condition or event as required following the procedures f ound 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 th e potential to generate emissions in excess of normal conditions for a period great er 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 th e 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 condi tion 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 th e 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 repl acement 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 possi ble and activate fire system.

2.0 Emission Control Equipment

Malfunctions requiring corrective action ar e found in Section II(C)(3.0)(b). These

malfunctions are those that have the potential to impair the pe rformance of the control device

and lead to an increase in emissions.Century Aluminum of Kentucky LLC - Hawesville, Kentucky 41
Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001) • Identify the cause of the problem.

• Initiate corrective action which could in clude 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 th at may arise as a result of st artup, shutdown or malfunction of the covered processes. For the purpose of this procedure, th e 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 a nd procedures expressed in this section are to be used to correct problems that could resu lt in greater than normal emissions from the covered processes.

a. Startup and Shutdown

1.0 Batch Mixers

Startup and shutdown of secti ons of the Batch Mixers occur on a routine basis depending on the need. Startup of individua l mixers shall occur as detailed in Section II D (3.0)(a) of this

manual. Shutdown of individual mixers shall occu r as detailed in Section II D (3.0)(a) of this

manual.

Deviation from the aforementioned procedures shall not be percei ved as a malfunction requiring corrective action unless em issions generated as a result of the deviation are typically greater than those genera ted 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 possi ble but in no case greate r than twenty-four hours

after the condition is identified unless circumst ances prevent the correction. In that case, notification will be made following the proced ures found in Section V of this manual.

The following is the procedure for identif ying 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 situ ation in order to alleviate th e 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. St artup of the anode former shall occur as detailed in Section II DCentury 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 percei ved as a malfunction requiring corrective action unless em issions generated as a result of the deviation are typically greater than those genera ted 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 possi ble but in no case greate r than twenty-four hours

after the condition is identified unless circumst ances prevent the correction. In that case, notification will be made following the proced ures found in Section V of this manual.

The following is the procedure for identif ying 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 situ ation in order to alleviate th e 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 a ddressed as part of th is plan. This plan will only involve non-routine issues that are the re sult of failure of equipm ent, process upsets or other issues beyond the normal control of facil ity 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 no t 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 possi ble but in no case greate r 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 identif ying the condition and implementing corrective

action.

• Identify the condition and determine if it is outside of the norma l startup and shutdown procedures.

• Take action to correct the situati on in order to alleviate the problem.

• If the condition results in emissions be yond 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 th e potential to generate emissions in excess of normal conditions for a period great er than one hour in length.

2.0 Corrective Action Procedures

• System Plugging

- Identify the cause of the problem.

- Initiate corrective action rela ted to the identified problem.

- Document the condition and the durati on of the problem using procedures found

in Section IV of this manual.

• Heater Failure - Identify the affected heater and take co rrection action to repair or remove it from

service.

• Mixer Failure - Identify the affected mixer and take corre ction 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, initi ate procedures to cl ear 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 th e impacted equipment as soon as possible. If the duration of the outage is longer than one hour, initiate pr ocedures 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 perf ormance 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 re quirements 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 po rtion 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, shut down, 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 r ecords 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 a ffected sources emission control equipment.

c. Activities performed during start up, 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 th is 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 complete d in duplicate in or der to provide the copies needed for records management f ound in Section 1 of this portion of the plan.

d. Off-site Management

All records maintained off-site shall be ma intained in a manner such that if necessary, they can be retrieved within 24 hours of a writte n request. Maintenance of these records shall follow the facility practices and procedures curr ently 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 reporti ng in relation to the Startup, Shutdown and Malfunction Plan requirem ents found in 40 CFR 63.10 (d)(5)(I) and (ii). Reporting requirements related to this manual are for th e affected sources found in Section II of

this manual.

2.0 Reporting Requirements

a. Periodic Startup, Shut down, Malfunction Reports

1. This section requires reports related onl y to those actions taken in compliance with the Startup, Shutdo wn, 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 requirement s of this section shall consist of the following.

a. A letter containing the name, title and signature of the owner operator responsible official that certifi es 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 th e appropriate agency semiannually. The letter should be postmarked no later than 30 days after the end of each

calendar half.

b. Immediate Startup, Shut down, Malfunction Reports

1. This section requires reports related to actions taken that do not comply with the procedures found in the Start up, Shutdown and Malfunction Plan.

2. Reports are required anytime the pro cedures 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 requir ements shall consist of the following.

a. A letter containing the name, title and signature of the owner operator responsible official that certifies the acc uracy of the report.

b. The letter shall explain the circumstan ces 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 agen cy per the schedule

found in item 2 above.

c. Other Reporting Requirements

1. This section relates to sources in wh ich 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 Syst em performance evaluations shall be submitted simultaneously with the results of the performance test.

b. Excess emissions and parameter monito ring 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 m onitoring 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 occu rs 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 shoul d 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 FormCentury 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 requirem ents of 40 CFR Part 63.850 which requires that malfunctions during startup and shutdown of affect ed sources and the rela ted 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 RosterCentury 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, th is 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 222Century 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 respon sibility of the Environmen tal, Health and Safety Manager.Century Aluminum of Kentucky LLC - Hawesville, Kentucky Startup, Shutdown, Malfunction Plan - April 1999 (Revised July 2001) 

### Appendix C

Site PlanCentury 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 #6Attachment#6‐TestReportSummarySourceControlDeviceYear PollutantEmissionRateEmissionRateUnitsTestMethodProductionRateProductionRateUnitsControlDeviceOperationedNormally(Y/N)GreenCarbon 310126 N/A NoTestDataCarbonBakeScrubber 330140 Apr‐06 POM 0.075 lbs/GT EPAM5&315 14,758GreenTons YCarbonBakeScrubber 330140 Apr‐06 HF 0.013 lbs/hr EPAM5&13B 14,758GreenTons YCarbonBakeScrubber 330140 Apr‐06 TF 0.0012 lbs/GT EPAM5&13B 14,758GreenTons YCarbonBakeScrubber 330140 Apr‐06 PM 1.31 lbs/hr EPAM5 14,758GreenTons YCarbonBakeScrubber 330140 Apr‐07 POM 0.125 lbs/GT EPAM5&315 15,004GreenTons YCarbonBakeScrubber 330140 Apr‐07 HF 0.029 lbs/hr EPAM5&13B 15,004GreenTons YCarbonBakeScrubber 330140 Apr‐07 TF 0.002 lbs/GT EPAM5&13B 15,004GreenTons YCarbonBakeScrubber 330140 Apr‐07 PM 3.04 lbs/hr EPAM5 15,004GreenTons YCarbonBakeScrubber 330140 Apr‐08 POM 0.046 lbs/GT EPAM5&315 15,879GreenTons YCarbonBakeScrubber 330140 Apr‐08 HF 0.0141 lbs/hr EPAM5&13B 15,879GreenTons YCarbonBakeScrubber 330140 Apr‐08 TF 0.00122 lbs/GT EPAM5&13B 15,879GreenTons YCarbonBakeScrubber 330140 Apr‐08 PM 1.77 lbs/hr EPAM5 15,879GreenTons YCarbonBakeScrubber 330140 Apr‐09 POM 0.023 lbs/GT EPAM5&315 12,284GreenTons YCarbonBakeScrubber 330140 Apr‐09 HF 0.0326 lbs/hr EPAM5&13B 12,284GreenTons YCarbonBakeScrubber 330140 Apr‐09 TF 0.00266 lbs/GT EPAM5&13B 12,284GreenTons YCarbonBakeScrubber 330140 Apr‐09 PM 0.56 lbs/hr EPAM5 12,284GreenTons YPotline5Scrubber 480063 Oct‐06 HF 0.048 lbs/tonAl EPAM5&13B 9,702,852lbsAl YPotline5Scrubber 480063 Oct‐06 TF 0.059 lbs/tonAl EPAM5&13B 9,702,852lbsAl YPotline5Scrubber 480063 Oct‐06 PM 2.3 lbs/hr EPAM5&13B 9,702,852lbsAl YPotline5Scrubber 480063 Nov‐07 HF 0.102 lbs/tonAl EPAM5&13B 8,882,406lbsAl YPotline5Scrubber 480063 Nov‐07 TF 0.119 lbs/tonAl EPAM5&13B 8,882,406lbsAl YPotline5Scrubber 480063 Nov‐07 PM 2.14 lbs/hr EPAM5&13B 8,882,406lbsAl YPotline5Scrubber 480063 Oct‐08 HF 0.05 lbs/tonAl EPAM5&13B 9,610,298lbsAl YPotline5Scrubber 480063 Oct‐08 TF 0.063 lbs/tonAl EPAM5&13B 9,610,298lbsAl YTestReportSummary(Jan2006‐December2010)CenturyAluminumofKY5/31/2011Page1of13Attachment#6‐TestReportSummarySourceControlDeviceYear PollutantEmissionRateEmissionRateUnitsTestMethodProductionRateProductionRateUnitsControlDeviceOperationedNormally(Y/N)TestReportSummary(Jan2006‐December2010)Potline5Scrubber 480063 Oct‐08 PM 2.04 lbs/hr EPAM5&13B 9,610,298lbsAl YPotline5RoofMonitor 423091 Feb‐06 HF 0.615 lbs/tonAl EPAM5&13B 8,725,406lbsAl YPotline5RoofMonitor 423091 Feb‐06 TF 0.856 lbs/tonAl EPAM5&13B 8,725,406lbsAl YPotline5RoofMonitor 423091 Feb‐06 PM 33.5 lbs/hr EPAM5&13B 8,725,406lbsAl YPotline5RoofMonitor 423091 Apr‐06 HF 0.647 lbs/tonAl EPAM5&13B 9,308,043lbsAl YPotline5RoofMonitor 423091 Apr‐06 TF 0.925 lbs/tonAl EPAM5&13B 9,308,043lbsAl YPotline5RoofMonitor 423091 Apr‐06 PM 32.4 lbs/hr EPAM5&13B 9,308,043lbsAl YPotline5RoofMonitor 423091 Aug‐06 HF 0.647 lbs/tonAl EPAM5&13B 9,930,872lbsAl YPotline5RoofMonitor 423091 Aug‐06 TF 0.911 lbs/tonAl EPAM5&13B 9,930,872lbsAl YPotline5RoofMonitor 423091 Aug‐06 PM 21.7 lbs/hr EPAM5&13B 9,930,872lbsAl YPotline5RoofMonitor 423091 Nov‐06 HF 0.477 lbs/tonAl EPAM5&13B 9,460,788lbsAl YPotline5RoofMonitor 423091 Nov‐06 TF 0.896 lbs/tonAl EPAM5&13B 9,460,788lbsAl YPotline5RoofMonitor 423091 Nov‐06 PM 35.7 lbs/hr EPAM5&13B 9,460,788lbsAl YPotline5RoofMonitor 423091 Jan‐07 HF 0.639 lbs/tonAl EPAM5&13B 9,505,169lbsAl YPotline5RoofMonitor 423091 Jan‐07 TF 1.063 lbs/tonAl EPAM5&13B 9,505,169lbsAl YPotline5RoofMonitor 423091 Jan‐07 PM 39.5 lbs/hr EPAM5&13B 9,505,169lbsAl YPotline5RoofMonitor 423091 Jun‐07 HF 0.458 lbs/tonAl EPAM5&13B 9,242,223lbsAl YPotline5RoofMonitor 423091 Jun‐07 TF 0.724 lbs/tonAl EPAM5&13B 9,242,223lbsAl YPotline5RoofMonitor 423091 Jun‐07 PM 31 lbs/hr EPAM5&13B 9,242,223lbsAl YPotline5RoofMonitor 423091 Aug‐07 HF 0.622 lbs/tonAl EPAM5&13B 9,638,137lbsAl YPotline5RoofMonitor 423091 Aug‐07 TF 0.904 lbs/tonAl EPAM5&13B 9,638,137lbsAl YPotline5RoofMonitor 423091 Aug‐07 PM 46.5 lbs/hr EPAM5&13B 9,638,137lbsAl YPotline5RoofMonitor 423091 Dec‐07 HF 0.579 lbs/tonAl EPAM5&13B 9,647,548lbsAl YPotline5RoofMonitor 423091 Dec‐07 TF 0.932 lbs/tonAl EPAM5&13B 9,647,548lbsAl YPotline5RoofMonitor 423091 Dec‐07 PM 29.6 lbs/hr EPAM5&13B 9,647,548lbsAl YPotline5RoofMonitor 423091 Mar‐08 HF 0.63 lbs/tonAl EPAM5&13B 9,624,687lbsAl YCenturyAluminumofKY5/31/2011Page2of13Attachment#6‐TestReportSummarySourceControlDeviceYear PollutantEmissionRateEmissionRateUnitsTestMethodProductionRateProductionRateUnitsControlDeviceOperationedNormally(Y/N)TestReportSummary(Jan2006‐December2010)Potline5RoofMonitor 423091 Mar‐08 TF 1.021 lbs/tonAl EPAM5&13B 9,624,687lbsAl YPotline5RoofMonitor 423091 Mar‐08 PM 46.3 lbs/hr EPAM5&13B 9,624,687lbsAl YPotline5RoofMonitor 423091 Apr‐08 HF 0.585 lbs/tonAl EPAM5&13B 9,394,293lbsAl YPotline5RoofMonitor 423091 Apr‐08 TF 0.968 lbs/tonAl EPAM5&13B 9,394,293lbsAl YPotline5RoofMonitor 423091 Apr‐08 PM 35.4 lbs/hr EPAM5&13B 9,394,293lbsAl YPotline5RoofMonitor 423091 Aug‐08 HF 0.56 lbs/tonAl EPAM5&13B 9,603,396lbsAl YPotline5RoofMonitor 423091 Aug‐08 TF 0.887 lbs/tonAl EPAM5&13B 9,603,396lbsAl YPotline5RoofMonitor 423091 Aug‐08 PM NA lbs/hr EPAM5&13B 9,603,396lbsAl YPotline5RoofMonitor 423091 Nov‐09 HF 0.666 lbs/tonAl EPAM5&13B 9,341,810lbsAl YPotline5RoofMonitor 423091 Nov‐09 TF 0.965 lbs/tonAl EPAM5&13B 9,341,810lbsAl YPotline5RoofMonitor 423091 Nov‐09 PM NA lbs/hr EPAM5&13B 9,341,810lbsAl YPotline5RoofMonitor 423091 Feb‐09 HF 0.584 lbs/tonAl EPAM5&13B 8,226,524lbsAl YPotline5RoofMonitor 423091 Feb‐09 TF 0.975 lbs/tonAl EPAM5&13B 8,226,524lbsAl YPotline5RoofMonitor 423091 Feb‐09 PM NA lbs/hr EPAM5&13B 8,226,524lbsAl YPotlines1thru4WetScrubber 432001 Oct‐06 HF 0.826 lbs/tonAl EPAM5&13B 37,023,547lbsAl YPotlines1thru4WetScrubber 432001 Oct‐06 TF 1.049 lbs/tonAl EPAM5&13B 37,023,547lbsAl YPotlines1thru4WetScrubber 432001 Oct‐06 PM 46.5 lbs/hr EPAM5&13B 37,023,547lbsAl YPotlines1thru4WetScrubber 432001 Nov‐07 HF 0.359 lbs/tonAl EPAM5&13B 36,027,548lbsAl YPotlines1thru4WetScrubber 432001 Nov‐07 TF 0.639 lbs/tonAl EPAM5&13B 36,027,548lbsAl YPotlines1thru4WetScrubber 432001 Nov‐07 PM 52 lbs/hr EPAM5&13B 36,027,548lbsAl YPotlines1thru4WetScrubber 432001 Nov‐08 HF 0.247 lbs/tonAl EPAM5&13B 36,291,774lbsAl YPotlines1thru4WetScrubber 432001 Nov‐08 TF 0.61 lbs/tonAl EPAM5&13B 36,291,774lbsAl YPotlines1thru4WetScrubber 432001 Nov‐09 HF 0.228 lbs/tonAl EPAM5&13B 36,240,197lbsAl YPotlines1thru4WetScrubber 432001 Nov‐09 TF 0.993 lbs/tonAl EPAM5&13B 36,240,197lbsAl YPotlines1thru4WetScrubber 432001 May‐10 HF 0.562 lbs/tonAl EPAM5&13B 37,639,560lbsAl YPotlines1thru4WetScrubber 432001 May‐10 TF 0.76 lbs/tonAl EPAM5&13B 37,639,560lbsAl YCenturyAluminumofKY5/31/2011Page3of13Attachment#6‐TestReportSummarySourceControlDeviceYear PollutantEmissionRateEmissionRateUnitsTestMethodProductionRateProductionRateUnitsControlDeviceOperationedNormally(Y/N)TestReportSummary(Jan2006‐December2010)Potlines1thru4WetScrubber 432001 May‐10 PM 38.17 lbs/hr EPAM5&13B 37,639,560lbsAl YPotline1RoofMonitor 422092 Feb‐06 HF 0.251 lbs/tonAl EPAM14A&13B 8,394,065lbsAl YPotline1RoofMonitor 422092 Feb‐06 TF 0.429 lbs/tonAl EPAM14A&13B 8,394,065lbsAl YPotline1RoofMonitor 422092 Apr‐06 HF 0.461 lbs/tonAl EPAM14A&13B 9,021,826lbsAl YPotline1RoofMonitor 422092 Apr‐06 TF 0.811 lbs/tonAl EPAM14A&13B 9,021,826lbsAl YPotline1RoofMonitor 422092 Aug‐06 HF 0.771 lbs/tonAl EPAM14A&13B 9,313,972lbsAl YPotline1RoofMonitor 422092 Aug‐06 TF 1.203 lbs/tonAl EPAM14A&13B 9,313,972lbsAl YPotline1RoofMonitor 422092 Nov‐06 HF 0.363 lbs/tonAl EPAM14A&13B 9,048,886lbsAl YPotline1RoofMonitor 422092 Nov‐06 TF 0.611 lbs/tonAl EPAM14A&13B 9,048,886lbsAl YPotline1RoofMonitor 422092 Feb‐07 HF 0.173 lbs/tonAl EPAM14A&13B 8,387,164lbsAl YPotline1RoofMonitor 422092 Feb‐07 TF 0.424 lbs/tonAl EPAM14A&13B 8,387,164lbsAl YPotline1RoofMonitor 422092 Apr‐07 HF 0.268 lbs/tonAl EPAM14A&13B 9,060,354lbsAl YPotline1RoofMonitor 422092 Apr‐07 TF 0.608 lbs/tonAl EPAM14A&13B 9,060,354lbsAl YPotline1RoofMonitor 422092 Aug‐07 HF 0.803 lbs/tonAl EPAM14A&13B 9,315,977lbsAl YPotline1RoofMonitor 422092 Aug‐07 TF 1.057 lbs/tonAl EPAM14A&13B 9,315,977lbsAl YPotline1RoofMonitor 422092 Nov‐07 HF 0.539 lbs/tonAl EPAM14A&13B 9,050,592lbsAl YPotline1RoofMonitor 422092 Nov‐07 TF 0.871 lbs/tonAl EPAM14A&13B 9,050,592lbsAl YPotline1RoofMonitor 422092 Jan‐08 HF 0.483 lbs/tonAl EPAM14A&13B 9,258,993lbsAl YPotline1RoofMonitor 422092 Jan‐08 TF 0.829 lbs/tonAl EPAM14A&13B 9,258,993lbsAl YPotline1RoofMonitor 422092 May‐08 HF 0.558 lbs/tonAl EPAM14A&13B 9,319,679lbsAl YPotline1RoofMonitor 422092 May‐08 TF 0.814 lbs/tonAl EPAM14A&13B 9,319,679lbsAl YPotline1RoofMonitor 422092 Aug‐08 HF 0.896 lbs/tonAl EPAM14A&13B 9,333,305lbsAl YPotline1RoofMonitor 422092 Aug‐08 TF 1.368 lbs/tonAl EPAM14A&13B 9,333,305lbsAl YPotline1RoofMonitor 422092 Oct‐08 HF 0.498 lbs/tonAl EPAM14A&13B 9,337,524lbsAl YPotline1RoofMonitor 422092 Oct‐08 TF 0.763 lbs/tonAl EPAM14A&13B 9,337,524lbsAl YPotline1RoofMonitor 422092 Jan‐09 HF 0.402 lbs/tonAl EPAM14A&13B 9,434,040lbsAl YCenturyAluminumofKY5/31/2011Page4of13Attachment#6‐TestReportSummarySourceControlDeviceYear PollutantEmissionRateEmissionRateUnitsTestMethodProductionRateProductionRateUnitsControlDeviceOperationedNormally(Y/N)TestReportSummary(Jan2006‐December2010)Potline1RoofMonitor 422092 Jan‐09 TF 0.635 lbs/tonAl EPAM14A&13B 9,434,040lbsAl YPotline1RoofMonitor 422092 Apr‐09 HF 0.451 lbs/tonAl EPAM14A&13B 9,114,243lbsAl YPotline1RoofMonitor 422092 Apr‐09 TF 0.606 lbs/tonAl EPAM14A&13B 9,114,243lbsAl YPotline1RoofMonitor 422092 Jul‐09 HF 1.405 lbs/tonAl EPAM14A&13B 8,342,343lbsAl YPotline1RoofMonitor 422092 Jul‐09 TF 1.744 lbs/tonAl EPAM14A&13B 8,342,343lbsAl YPotline1RoofMonitor 422092 Nov‐09 HF 0.557 lbs/tonAl EPAM14A&13B 9,087,068lbsAl YPotline1RoofMonitor 422092 Nov‐09 TF 0.896 lbs/tonAl EPAM14A&13B 9,087,068lbsAl YPotline1RoofMonitor 422092 Jan‐10 HF 0.359 lbs/tonAl EPAM14A&13B 9,402,407lbsAl YPotline1RoofMonitor 422092 Jan‐10 TF 0.659 lbs/tonAl EPAM14A&13B 9,402,407lbsAl YPotline1RoofMonitor 422092 Apr‐10 HF 0.679 lbs/tonAl EPAM14A&13B 9,048,054lbsAl YPotline1RoofMonitor 422092 Apr‐10 TF 0.932 lbs/tonAl EPAM14A&13B 9,048,054lbsAl YPotline1RoofMonitor 422092 Jul‐10 HF 0.982 lbs/tonAl EPAM14A&13B 9,270,439lbsAl YPotline1RoofMonitor 422092 Jul‐10 TF 1.265 lbs/tonAl EPAM14A&13B 9,270,439lbsAl YPotline1RoofMonitor 422092 Oct‐10 HF 0.749 lbs/tonAl EPAM14A&13B 9,503,051lbsAl YPotline1RoofMonitor 422092 Oct‐10 TF 1.13 lbs/tonAl EPAM14A&13B 9,503,051lbsAl YPotline2RoofMonitor 422093 Feb‐06 HF 0.097 Lbs/tonAl EPAM14A&13B 8,337,519lbsAl YPotline2RoofMonitor 422093 Feb‐06 TF 0.337 Lbs/tonAl EPAM14A&13B 8,337,519lbsAl YPotline2RoofMonitor 422093 Apr‐06 HF 0.192 Lbs/tonAl EPAM14A&13B 9,016,722lbsAl YPotline2RoofMonitor 422093 Apr‐06 TF 0.375 Lbs/tonAl EPAM14A&13B 9,016,722lbsAl YPotline2RoofMonitor 422093 Aug‐06 HF 0.279 Lbs/tonAl EPAM14A&13B 9,172,511lbsAl YPotline2RoofMonitor 422093 Aug‐06 TF 0.492 Lbs/tonAl EPAM14A&13B 9,172,511lbsAl YPotline2RoofMonitor 422093 Nov‐06 HF 0.317 Lbs/tonAl EPAM14A&13B 8,990,265lbsAl YPotline2RoofMonitor 422093 Nov‐06 TF 0.505 Lbs/tonAl EPAM14A&13B 8,990,265lbsAl YPotline2RoofMonitor 422093 Feb‐07 HF 0.143 Lbs/tonAl EPAM14A&13B 8,407,001lbsAl YPotline2RoofMonitor 422093 Feb‐07 TF 0.418 Lbs/tonAl EPAM14A&13B 8,407,001lbsAl YPotline2RoofMonitor 422093 Apr‐07 HF 0.244 Lbs/tonAl EPAM14A&13B 8,992,353lbsAl YCenturyAluminumofKY5/31/2011Page5of13Attachment#6‐TestReportSummarySourceControlDeviceYear PollutantEmissionRateEmissionRateUnitsTestMethodProductionRateProductionRateUnitsControlDeviceOperationedNormally(Y/N)TestReportSummary(Jan2006‐December2010)Potline2RoofMonitor 422093 Apr‐07 TF 0.566 Lbs/tonAl EPAM14A&13B 8,992,353lbsAl YPotline2RoofMonitor 422093 Jul‐07 HF 0.427 Lbs/tonAl EPAM14A&13B 9,300,375lbsAl YPotline2RoofMonitor 422093 Jul‐07 TF 0.699 Lbs/tonAl EPAM14A&13B 9,300,375lbsAl YPotline2RoofMonitor 422093 Oct‐07 HF 0.582 Lbs/tonAl EPAM14A&13B 9,334,209lbsAl YPotline2RoofMonitor 422093 Oct‐07 TF 0.715 Lbs/tonAl EPAM14A&13B 9,334,209lbsAl YPotline2RoofMonitor 422093 Jan‐08 HF 0.351 Lbs/tonAl EPAM14A&13B 9,261,038lbsAl YPotline2RoofMonitor 422093 Jan‐08 TF 0.586 Lbs/tonAl EPAM14A&13B 9,261,038lbsAl YPotline2RoofMonitor 422093 Apr‐08 HF 0.568 Lbs/tonAl EPAM14A&13B 8,988,276lbsAl YPotline2RoofMonitor 422093 Apr‐08 TF 0.795 Lbs/tonAl EPAM14A&13B 8,988,276lbsAl YPotline2RoofMonitor 422093 Jul‐08 HF 0.69 Lbs/tonAl EPAM14A&13B 9,311,302lbsAl YPotline2RoofMonitor 422093 Jul‐08 TF 0.888 Lbs/tonAl EPAM14A&13B 9,311,302lbsAl YPotline2RoofMonitor 422093 Oct‐08 HF 0.537 Lbs/tonAl EPAM14A&13B 9,366,721lbsAl YPotline2RoofMonitor 422093 Oct‐08 TF 0.792 Lbs/tonAl EPAM14A&13B 9,366,721lbsAl YPotline2RoofMonitor 422093 Jan‐09 HF 0.328 Lbs/tonAl EPAM14A&13B 9,381,867lbsAl YPotline2RoofMonitor 422093 Jan‐09 TF 0.488 Lbs/tonAl EPAM14A&13B 9,381,867lbsAl YPotline2RoofMonitor 422093 Apr‐09 HF 0.279 Lbs/tonAl EPAM14A&13B 8,930,475lbsAl YPotline2RoofMonitor 422093 Apr‐09 TF 0.373 Lbs/tonAl EPAM14A&13B 8,930,475lbsAl YPotline2RoofMonitor 422093 Jul‐09 HF 1.066 Lbs/tonAl EPAM14A&13B 8,453,845lbsAl YPotline2RoofMonitor 422093 Jul‐09 TF 1.42 Lbs/tonAl EPAM14A&13B 8,453,845lbsAl YPotline2RoofMonitor 422093 Nov‐09 HF 0.415 Lbs/tonAl EPAM14A&13B 9,116,768lbsAl YPotline2RoofMonitor 422093 Nov‐09 TF 0.636 Lbs/tonAl EPAM14A&13B 9,116,768lbsAl YPotline2RoofMonitor 422093 Jan‐10 HF 0.403 Lbs/tonAl EPAM14A&13B 9,452,528lbsAl YPotline2RoofMonitor 422093 Jan‐10 TF 0.967 Lbs/tonAl EPAM14A&13B 9,452,528lbsAl YPotline2RoofMonitor 422093 Apr‐10 HF 0.936 Lbs/tonAl EPAM14A&13B 9,121,963lbsAl YPotline2RoofMonitor 422093 Apr‐10 TF 1.259 Lbs/tonAl EPAM14A&13B 9,121,963lbsAl YPotline2RoofMonitor 422093 Jul‐10 HF 0.845 Lbs/tonAl EPAM14A&13B 9,205,953lbsAl YPotline2RoofMonitor 422093 Jul‐10 TF 1.19 Lbs/tonAl EPAM14A&13B 9,205,953lbsAl YCenturyAluminumofKY5/31/2011Page6of13Attachment#6‐TestReportSummarySourceControlDeviceYear PollutantEmissionRateEmissionRateUnitsTestMethodProductionRateProductionRateUnitsControlDeviceOperationedNormally(Y/N)TestReportSummary(Jan2006‐December2010)Potline2RoofMonitor 422093 Oct‐10 HF 0.515 Lbs/tonAl EPAM14A&13B 9,492,721lbsAl YPotline2RoofMonitor 422093 Oct‐10 TF 0.826 Lbs/tonAl EPAM14A&13B 9,492,721lbsAl YPotline3RoofMonitor 422094 Jan‐06 HF 0.296 Lbs/tonAl EPAM14A&13B 9,240,894lbsAl YPotline3RoofMonitor 422094 Jan‐06 TF 0.531 Lbs/tonAl EPAM14A&13B 9,240,894lbsAl YPotline3RoofMonitor 422094 Feb‐06 HF 0.301 Lbs/tonAl EPAM14A&13B 8,439,318lbsAl YPotline3RoofMonitor 422094 Feb‐06 TF 0.57 Lbs/tonAl EPAM14A&13B 8,439,318lbsAl YPotline3RoofMonitor 422094 Mar‐06 HF 0.33 Lbs/tonAl EPAM14A&13B 9,365,106lbsAl YPotline3RoofMonitor 422094 Mar‐06 TF 0.723 Lbs/tonAl EPAM14A&13B 9,365,106lbsAl YPotline3RoofMonitor 422094 Apr‐06 HF 0.5 Lbs/tonAl EPAM14A&13B 8,907,312lbsAl YPotline3RoofMonitor 422094 Apr‐06 TF 0.897 Lbs/tonAl EPAM14A&13B 8,907,312lbsAl YPotline3RoofMonitor 422094 May‐06 HF 0.793 Lbs/tonAl EPAM14A&13B 9,310,096lbsAl YPotline3RoofMonitor 422094 May‐06 TF 1.208 Lbs/tonAl EPAM14A&13B 9,310,096lbsAl YPotline3RoofMonitor 422094 Jun‐06 HF 0.925 Lbs/tonAl EPAM14A&13B 9,009,378lbsAl YPotline3RoofMonitor 422094 Jun‐06 TF 1.274 Lbs/tonAl EPAM14A&13B 9,009,378lbsAl YPotline3RoofMonitor 422094 Jul‐06 HF 1.192 Lbs/tonAl EPAM14A&13B 9,260,744lbsAl YPotline3RoofMonitor 422094 Jul‐06 TF 1.653 Lbs/tonAl EPAM14A&13B 9,260,744lbsAl YPotline3RoofMonitor 422094 Aug‐06 HF 1.037 Lbs/tonAl EPAM14A&13B 8,998,544lbsAl YPotline3RoofMonitor 422094 Aug‐06 TF 1.533 Lbs/tonAl EPAM14A&13B 8,998,544lbsAl YPotline3RoofMonitor 422094 Sep‐06 HF 0.75 Lbs/tonAl EPAM14A&13B 8,977,893lbsAl YPotline3RoofMonitor 422094 Sep‐06 TF 1.117 Lbs/tonAl EPAM14A&13B 8,977,893lbsAl YPotline3RoofMonitor 422094 Oct‐06 HF 0.518 Lbs/tonAl EPAM14A&13B 9,248,014lbsAl YPotline3RoofMonitor 422094 Oct‐06 TF 0.891 Lbs/tonAl EPAM14A&13B 9,248,014lbsAl YPotline3RoofMonitor 422094 Nov‐06 HF 0.449 Lbs/tonAl EPAM14A&13B 8,950,000lbsAl YPotline3RoofMonitor 422094 Nov‐06 TF 0.722 Lbs/tonAl EPAM14A&13B 8,950,000lbsAl YPotline3RoofMonitor 422094 Dec‐06 HF 0.359 Lbs/tonAl EPAM14A&13B 9,270,190lbsAl YPotline3RoofMonitor 422094 Dec‐06 TF 0.716 Lbs/tonAl EPAM14A&13B 9,270,190lbsAl YCenturyAluminumofKY5/31/2011Page7of13Attachment#6‐TestReportSummarySourceControlDeviceYear PollutantEmissionRateEmissionRateUnitsTestMethodProductionRateProductionRateUnitsControlDeviceOperationedNormally(Y/N)TestReportSummary(Jan2006‐December2010)Potline3RoofMonitor 422094 Jan‐07 HF 0.314 Lbs/tonAl EPAM14A&13B 9,333,483lbsAl YPotline3RoofMonitor 422094 Jan‐07 TF 0.579 Lbs/tonAl EPAM14A&13B 9,333,483lbsAl YPotline3RoofMonitor 422094 Feb‐07 HF 0.231 Lbs/tonAl EPAM14A&13B 8,314,080lbsAl YPotline3RoofMonitor 422094 Feb‐07 TF 0.631 Lbs/tonAl EPAM14A&13B 8,314,080lbsAl YPotline3RoofMonitor 422094 Mar‐07 HF 0.681 Lbs/tonAl EPAM14A&13B 9,281,269lbsAl YPotline3RoofMonitor 422094 Mar‐07 TF 1.22 Lbs/tonAl EPAM14A&13B 9,281,269lbsAl YPotline3RoofMonitor 422094 Apr‐07 HF 0.453 Lbs/tonAl EPAM14A&13B 8,825,347lbsAl YPotline3RoofMonitor 422094 Apr‐07 TF 0.817 Lbs/tonAl EPAM14A&13B 8,825,347lbsAl YPotline3RoofMonitor 422094 May‐07 HF 0.585 Lbs/tonAl EPAM14A&13B 9,262,696lbsAl YPotline3RoofMonitor 422094 May‐07 TF 0.983 Lbs/tonAl EPAM14A&13B 9,262,696lbsAl YPotline3RoofMonitor 422094 Jun‐07 HF 0.723 Lbs/tonAl EPAM14A&13B 8,958,417lbsAl YPotline3RoofMonitor 422094 Jun‐07 TF 1.16 Lbs/tonAl EPAM14A&13B 8,958,417lbsAl YPotline3RoofMonitor 422094 Jul‐07 HF 0.585 Lbs/tonAl EPAM14A&13B 9,311,870lbsAl YPotline3RoofMonitor 422094 Jul‐07 TF 0.99 Lbs/tonAl EPAM14A&13B 9,311,870lbsAl YPotline3RoofMonitor 422094 Aug‐07 HF 0.707 Lbs/tonAl EPAM14A&13B 9,338,292lbsAl YPotline3RoofMonitor 422094 Aug‐07 TF 0.962 Lbs/tonAl EPAM14A&13B 9,338,292lbsAl YPotline3RoofMonitor 422094 Sep‐07 HF 0.874 Lbs/tonAl EPAM14A&13B 8,980,225lbsAl YPotline3RoofMonitor 422094 Sep‐07 TF 1.293 Lbs/tonAl EPAM14A&13B 8,980,225lbsAl YPotline3RoofMonitor 422094 Oct‐07 HF 0.769 Lbs/tonAl EPAM14A&13B 9,263,708lbsAl YPotline3RoofMonitor 422094 Oct‐07 TF 1.023 Lbs/tonAl EPAM14A&13B 9,263,708lbsAl YPotline3RoofMonitor 422094 Nov‐07 HF 0.732 Lbs/tonAl EPAM14A&13B 9,018,467lbsAl YPotline3RoofMonitor 422094 Nov‐07 TF 1.084 Lbs/tonAl EPAM14A&13B 9,018,467lbsAl YPotline3RoofMonitor 422094 Dec‐07 HF 0.584 Lbs/tonAl EPAM14A&13B 9,163,044lbsAl YPotline3RoofMonitor 422094 Dec‐07 TF 1.04 Lbs/tonAl EPAM14A&13B 9,163,044lbsAl YPotline3RoofMonitor 422094 Jan‐08 HF 0.738 Lbs/tonAl EPAM14A&13B 9,187,681lbsAl YPotline3RoofMonitor 422094 Jan‐08 TF 1.113 Lbs/tonAl EPAM14A&13B 9,187,681lbsAl YPotline3RoofMonitor 422094 Feb‐08 HF 0.38 Lbs/tonAl EPAM14A&13B 8,700,798lbsAl YCenturyAluminumofKY5/31/2011Page8of13Attachment#6‐TestReportSummarySourceControlDeviceYear PollutantEmissionRateEmissionRateUnitsTestMethodProductionRateProductionRateUnitsControlDeviceOperationedNormally(Y/N)TestReportSummary(Jan2006‐December2010)Potline3RoofMonitor 422094 Feb‐08 TF 0.629 Lbs/tonAl EPAM14A&13B 8,700,798lbsAl YPotline3RoofMonitor 422094 Mar‐08 HF 0.346 Lbs/tonAl EPAM14A&13B 9,262,713lbsAl YPotline3RoofMonitor 422094 Mar‐08 TF 0.566 Lbs/tonAl EPAM14A&13B 9,262,713lbsAl YPotline3RoofMonitor 422094 Apr‐08 HF 0.554 Lbs/tonAl EPAM14A&13B 9,008,783lbsAl YPotline3RoofMonitor 422094 Apr‐08 TF 0.862 Lbs/tonAl EPAM14A&13B 9,008,783lbsAl YPotline3RoofMonitor 422094 May‐08 HF 0.854 Lbs/tonAl EPAM14A&13B 9,281,107lbsAl YPotline3RoofMonitor 422094 May‐08 TF 1.274 Lbs/tonAl EPAM14A&13B 9,281,107lbsAl YPotline3RoofMonitor 422094 Jun‐08 HF 0.984 Lbs/tonAl EPAM14A&13B 8,976,608lbsAl YPotline3RoofMonitor 422094 Jun‐08 TF 1.359 Lbs/tonAl EPAM14A&13B 8,976,608lbsAl YPotline3RoofMonitor 422094 Jul‐08 HF 1.066 Lbs/tonAl EPAM14A&13B 9,351,166lbsAl YPotline3RoofMonitor 422094 Jul‐08 TF 1.427 Lbs/tonAl EPAM14A&13B 9,351,166lbsAl YPotline3RoofMonitor 422094 Aug‐08 HF 0.697 Lbs/tonAl EPAM14A&13B 9,290,320lbsAl YPotline3RoofMonitor 422094 Aug‐08 TF 1.17 Lbs/tonAl EPAM14A&13B 9,290,320lbsAl YPotline3RoofMonitor 422094 Sep‐08 HF 0.763 Lbs/tonAl EPAM14A&13B 9,065,654lbsAl YPotline3RoofMonitor 422094 Sep‐08 TF 1.03 Lbs/tonAl EPAM14A&13B 9,065,654lbsAl YPotline3RoofMonitor 422094 Oct‐08 HF 0.566 Lbs/tonAl EPAM14A&13B 9,332,936lbsAl YPotline3RoofMonitor 422094 Oct‐08 TF 0.985 Lbs/tonAl EPAM14A&13B 9,332,936lbsAl YPotline3RoofMonitor 422094 Nov‐08 HF 0.396 Lbs/tonAl EPAM14A&13B 9,081,217lbsAl YPotline3RoofMonitor 422094 Nov‐08 TF 0.809 Lbs/tonAl EPAM14A&13B 9,081,217lbsAl YPotline3RoofMonitor 422094 Dec‐08 HF 0.225 Lbs/tonAl EPAM14A&13B 9,450,350lbsAl YPotline3RoofMonitor 422094 Dec‐08 TF 0.506 Lbs/tonAl EPAM14A&13B 9,450,350lbsAl YPotline3RoofMonitor 422094 Jan‐09 HF 0.235 Lbs/tonAl EPAM14A&13B 9,367,079lbsAl YPotline3RoofMonitor 422094 Jan‐09 TF 0.56 Lbs/tonAl EPAM14A&13B 9,367,079lbsAl YPotline3RoofMonitor 422094 Feb‐09 HF 0.225 Lbs/tonAl EPAM14A&13B 8,430,487lbsAl YPotline3RoofMonitor 422094 Feb‐09 TF 0.477 Lbs/tonAl EPAM14A&13B 8,430,487lbsAl YPotline3RoofMonitor 422094 Mar‐09 HF 0.238 Lbs/tonAl EPAM14A&13B 9,268,900lbsAl YPotline3RoofMonitor 422094 Mar‐09 TF 0.406 Lbs/tonAl EPAM14A&13B 9,268,900lbsAl YCenturyAluminumofKY5/31/2011Page9of13Attachment#6‐TestReportSummarySourceControlDeviceYear PollutantEmissionRateEmissionRateUnitsTestMethodProductionRateProductionRateUnitsControlDeviceOperationedNormally(Y/N)TestReportSummary(Jan2006‐December2010)Potline3RoofMonitor 422094 Apr‐09 HF 0.401 Lbs/tonAl EPAM14A&13B 8,790,104lbsAl YPotline3RoofMonitor 422094 Apr‐09 TF 0.575 Lbs/tonAl EPAM14A&13B 8,790,104lbsAl YPotline3RoofMonitor 422094 May‐09 HF 0.55 Lbs/tonAl EPAM14A&13B 8,988,942lbsAl YPotline3RoofMonitor 422094 May‐09 TF 0.788 Lbs/tonAl EPAM14A&13B 8,988,942lbsAl YPotline3RoofMonitor 422094 Jun‐09 HF 0.776 Lbs/tonAl EPAM14A&13B 8,447,647lbsAl YPotline3RoofMonitor 422094 Jun‐09 TF 1.08 Lbs/tonAl EPAM14A&13B 8,447,647lbsAl YPotline3RoofMonitor 422094 Jul‐09 HF 0.967 Lbs/tonAl EPAM14A&13B 8,444,381lbsAl YPotline3RoofMonitor 422094 Jul‐09 TF 1.218 Lbs/tonAl EPAM14A&13B 8,444,381lbsAl YPotline3RoofMonitor 422094 Aug‐09 HF 0.706 Lbs/tonAl EPAM14A&13B 8,587,985lbsAl YPotline3RoofMonitor 422094 Aug‐09 TF 0.966 Lbs/tonAl EPAM14A&13B 8,587,985lbsAl YPotline3RoofMonitor 422094 Sep‐09 HF 0.687 Lbs/tonAl EPAM14A&13B 8,622,863lbsAl YPotline3RoofMonitor 422094 Sep‐09 TF 0.91 Lbs/tonAl EPAM14A&13B 8,622,863lbsAl YPotline3RoofMonitor 422094 Oct‐09 HF 1.098 Lbs/tonAl EPAM14A&13B 9,251,317lbsAl YPotline3RoofMonitor 422094 Oct‐09 TF 1.657 Lbs/tonAl EPAM14A&13B 9,251,317lbsAl YPotline3RoofMonitor 422094 Nov‐09 HF 0.626 Lbs/tonAl EPAM14A&13B 8,952,631lbsAl YPotline3RoofMonitor 422094 Nov‐09 TF 1.024 Lbs/tonAl EPAM14A&13B 8,952,631lbsAl YPotline3RoofMonitor 422094 Dec‐09 HF 0.393 Lbs/tonAl EPAM14A&13B 9,506,696lbsAl YPotline3RoofMonitor 422094 Dec‐09 TF 0.824 Lbs/tonAl EPAM14A&13B 9,506,696lbsAl YPotline3RoofMonitor 422094 Jan‐10 HF 0.541 Lbs/tonAl EPAM14A&13B 9,453,388lbsAl YPotline3RoofMonitor 422094 Jan‐10 TF 1.152 Lbs/tonAl EPAM14A&13B 9,453,388lbsAl YPotline3RoofMonitor 422094 Feb‐10 HF 0.483 Lbs/tonAl EPAM14A&13B 8,594,939lbsAl YPotline3RoofMonitor 422094 Feb‐10 TF 1.007 Lbs/tonAl EPAM14A&13B 8,594,939lbsAl YPotline3RoofMonitor 422094 Mar‐10 HF 0.698 Lbs/tonAl EPAM14A&13B 9,508,437lbsAl YPotline3RoofMonitor 422094 Mar‐10 TF 1.279 Lbs/tonAl EPAM14A&13B 9,508,437lbsAl YPotline3RoofMonitor 422094 Apr‐10 HF 0.733 Lbs/tonAl EPAM14A&13B 9,165,538lbsAl YPotline3RoofMonitor 422094 Apr‐10 TF 0.991 Lbs/tonAl EPAM14A&13B 9,165,538lbsAl YPotline3RoofMonitor 422094 May‐10 HF 0.762 Lbs/tonAl EPAM14A&13B 9,429,889lbsAl YCenturyAluminumofKY5/31/2011Page10of13Attachment#6‐TestReportSummarySourceControlDeviceYear PollutantEmissionRateEmissionRateUnitsTestMethodProductionRateProductionRateUnitsControlDeviceOperationedNormally(Y/N)TestReportSummary(Jan2006‐December2010)Potline3RoofMonitor 422094 May‐10 TF 0.956 Lbs/tonAl EPAM14A&13B 9,429,889lbsAl YPotline3RoofMonitor 422094 Jun‐10 HF 0.755 Lbs/tonAl EPAM14A&13B 9,133,322lbsAl YPotline3RoofMonitor 422094 Jun‐10 TF 1.302 Lbs/tonAl EPAM14A&13B 9,133,322lbsAl YPotline3RoofMonitor 422094 Jul‐10 HF 0.955 Lbs/tonAl EPAM14A&13B 9,388,120lbsAl YPotline3RoofMonitor 422094 Jul‐10 TF 1.384 Lbs/tonAl EPAM14A&13B 9,388,120lbsAl YPotline3RoofMonitor 422094 Aug‐10 HF 0.766 Lbs/tonAl EPAM14A&13B 9,464,384lbsAl YPotline3RoofMonitor 422094 Aug‐10 TF 1.07 Lbs/tonAl EPAM14A&13B 9,464,384lbsAl YPotline3RoofMonitor 422094 Sep‐10 HF 0.815 Lbs/tonAl EPAM14A&13B 9,186,359lbsAl YPotline3RoofMonitor 422094 Sep‐10 TF 1.062 Lbs/tonAl EPAM14A&13B 9,186,359lbsAl YPotline3RoofMonitor 422094 Oct‐10 HF 0.575 Lbs/tonAl EPAM14A&13B 9,536,447lbsAl YPotline3RoofMonitor 422094 Oct‐10 TF 0.894 Lbs/tonAl EPAM14A&13B 9,536,447lbsAl YPotline3RoofMonitor 422094 Nov‐10 HF 0.444 Lbs/tonAl EPAM14A&13B 9,138,227lbsAl YPotline3RoofMonitor 422094 Nov‐10 TF 0.725 Lbs/tonAl EPAM14A&13B 9,138,227lbsAl YPotline3RoofMonitor 422094 Dec‐10 HF 0.463 Lbs/tonAl EPAM14A&13B 9,533,763lbsAl YPotline3RoofMonitor 422094 Dec‐10 TF 0.929 Lbs/tonAl EPAM14A&13B 9,533,763lbsAl YPotline4RoofMonitor 422088 Feb‐06 HF 0.201 Lbs/tonAl EPAM14&13B 8,463,582lbsAl YPotline4RoofMonitor 422088 Feb‐06 TF 0.424 Lbs/tonAl EPAM14&13B 8,463,582lbsAl YPotline4RoofMonitor 422088 Apr‐06 HF 0.306 Lbs/tonAl EPAM14&13B 8,982,254lbsAl YPotline4RoofMonitor 422088 Apr‐06 TF 0.465 Lbs/tonAl EPAM14&13B 8,982,254lbsAl YPotline4RoofMonitor 422088 Aug‐06 HF 0.616 Lbs/tonAl EPAM14&13B 9,321,359lbsAl YPotline4RoofMonitor 422088 Aug‐06 TF 0.942 Lbs/tonAl EPAM14&13B 9,321,359lbsAl YPotline4RoofMonitor 422088 Nov‐06 HF 0.361 Lbs/tonAl EPAM14&13B 8,840,183lbsAl YPotline4RoofMonitor 422088 Nov‐06 TF 0.709 Lbs/tonAl EPAM14&13B 8,840,183lbsAl YPotline4RoofMonitor 422088 Jan‐07 HF 0.225 Lbs/tonAl EPAM14&13B 9,352,799lbsAl YPotline4RoofMonitor 422088 Jan‐07 TF 0.567 Lbs/tonAl EPAM14&13B 9,352,799lbsAl YPotline4RoofMonitor 422088 Apr‐07 HF 0.311 Lbs/tonAl EPAM14&13B 9,073,923lbsAl YCenturyAluminumofKY5/31/2011Page11of13Attachment#6‐TestReportSummarySourceControlDeviceYear PollutantEmissionRateEmissionRateUnitsTestMethodProductionRateProductionRateUnitsControlDeviceOperationedNormally(Y/N)TestReportSummary(Jan2006‐December2010)Potline4RoofMonitor 422088 Apr‐07 TF 0.55 Lbs/tonAl EPAM14&13B 9,073,923lbsAl YPotline4RoofMonitor 422088 Aug‐07 HF 0.28 Lbs/tonAl EPAM14&13B 9,301,751lbsAl YPotline4RoofMonitor 422088 Aug‐07 TF 0.404 Lbs/tonAl EPAM14&13B 9,301,751lbsAl YPotline4RoofMonitor 422088 Oct‐07 HF 0.485 Lbs/tonAl EPAM14&13B 9,203,666lbsAl YPotline4RoofMonitor 422088 Oct‐07 TF 0.696 Lbs/tonAl EPAM14&13B 9,203,666lbsAl YPotline4RoofMonitor 422088 Jan‐08 HF 0.417 Lbs/tonAl EPAM14&13B 9,280,085lbsAl YPotline4RoofMonitor 422088 Jan‐08 TF 0.649 Lbs/tonAl EPAM14&13B 9,280,085lbsAl YPotline4RoofMonitor 422088 Apr‐08 HF 0.453 Lbs/tonAl EPAM14&13B 8,970,316lbsAl YPotline4RoofMonitor 422088 Apr‐08 TF 0.662 Lbs/tonAl EPAM14&13B 8,970,316lbsAl YPotline4RoofMonitor 422088 Aug‐08 HF 0.364 Lbs/tonAl EPAM14&13B 9,366,612lbsAl YPotline4RoofMonitor 422088 Aug‐08 TF 0.534 Lbs/tonAl EPAM14&13B 9,366,612lbsAl YPotline4RoofMonitor 422088 Nov‐08 HF 0.175 Lbs/tonAl EPAM14&13B 9,029,139lbsAl YPotline4RoofMonitor 422088 Nov‐08 TF 0.355 Lbs/tonAl EPAM14&13B 9,029,139lbsAl YPotline4RoofMonitor 422088 Feb‐09 HF 0.253 Lbs/tonAl EPAM14&13B 8,388,613lbsAl YPotline4RoofMonitor 422088 Feb‐09 TF 0.487 Lbs/tonAl EPAM14&13B 8,388,613lbsAl YPotline4RoofMonitor 422088 Apr‐09 HF 0.186 Lbs/tonAl EPAM14&13B 8,872,047lbsAl YPotline4RoofMonitor 422088 Apr‐09 TF 0.35 Lbs/tonAl EPAM14&13B 8,872,047lbsAl YPotline4RoofMonitor 422088 Jul‐09 HF 0.347 Lbs/tonAl EPAM14&13B 8,300,016lbsAl YPotline4RoofMonitor 422088 Jul‐09 TF 0.562 Lbs/tonAl EPAM14&13B 8,300,016lbsAl YPotline4RoofMonitor 422088 Oct‐09 HF 0.168 Lbs/tonAl EPAM14&13B 9,416,024lbsAl YPotline4RoofMonitor 422088 Oct‐09 TF 0.327 Lbs/tonAl EPAM14&13B 9,416,024lbsAl YPotline4RoofMonitor 422088 Jan‐10 HF 0.425 Lbs/tonAl EPAM14&13B 9,460,466lbsAl YPotline4RoofMonitor 422088 Jan‐10 TF 0.866 Lbs/tonAl EPAM14&13B 9,460,466lbsAl YPotline4RoofMonitor 422088 Apr‐10 HF 0.54 Lbs/tonAl EPAM14&13B 9,174,029lbsAl YPotline4RoofMonitor 422088 Apr‐10 TF 0.723 Lbs/tonAl EPAM14&13B 9,174,029lbsAl YPotline4RoofMonitor 422088 Jul‐10 HF 0.543 Lbs/tonAl EPAM14&13B 9,407,850lbsAl YPotline4RoofMonitor 422088 Jul‐10 TF 0.735 Lbs/tonAl EPAM14&13B 9,407,850lbsAl YCenturyAluminumofKY5/31/2011Page12of13Attachment#6‐TestReportSummarySourceControlDeviceYear PollutantEmissionRateEmissionRateUnitsTestMethodProductionRateProductionRateUnitsControlDeviceOperationedNormally(Y/N)TestReportSummary(Jan2006‐December2010)Potline4RoofMonitor 422088 Oct‐10 HF 0.807 Lbs/tonAl EPAM14&13B 9,544,149lbsAl YPotline4RoofMonitor 422088 Oct‐10 TF 1.091 Lbs/tonAl EPAM14&13B 9,544,149lbsAl YCenturyAluminumofKY5/31/2011Page13of13

# Attachment #8