1

From: Putney.David@epamail.epa.gov

Sent: Tuesday, April 05, 2011 8:00 AM

To: cjohnson@aluminum.org; Michael.Palazzolo@alcoa.com

Cc: Boyd.Rochelle@epamail.epa.gov; Bahner, Mark A.; Green, David A.; 

Srivastava.Ravi@epamail.epa.gov

Subject: DRAFT ICR for PAL facilities

Attachments: DRAFT PAL_114 letter-survey and testing for RTR_04-05-11.doc

Charles/Mike, 

Please distribute the attached draft version of an information collection request for the primary aluminum (PAL) industry to 

the appropriate PAL personnel. A couple of notes on this document: 

• The court-ordered deadline for this RTR project results in a very tight schedule. This schedule may be further 

stressed if the Congress cannot agree on a budget and the government temporarily shuts down. With these 

issues in mind, please review this document at your earliest convenience. I would like to set up a conference call 

to discuss this ICR with representatives of the PAL industry ASAP. Is there any way we could discuss this 

document Friday (04/08/11)? If not, can you suggest an alternate date (subject, of course, to the possibility of 

temporary government shutdown after this Friday)?

• The deadline for submittal of the requested information is very tight - but the testing that we discussed earlier has 

been removed and only limited grab samples are now requested (as opposed to stack testing).

• I made an attempt at defining "normal facility production hours" and "normal operating year" in question 8 on page 

7 of the document. In addition to any other comments you provide, please provide feedback on how to make 

those definitions more accurate/representative.

• The EPA attorney assigned to this project has submitted some comments to me which I have attempted to 

incorporate in the attached version of this document - however, that attorney has expressed a desire to have a 

meeting concerning this project. That meeting could result in changes to the attached document.

David Putney, Environmental Engineer

U.S. Environmental Protection Agency

Office of Air Quality Planning and Standards

Sector Policies and Programs Division

109 T.W. Alexander Drive, RTP, NC 27711

Mail Drop D243-02

Ph: (919) 541-2016 Fax: (919) 541-3207

Email: putney.david@epa.gov
Page 1 of 37

DRAFT April 11, 2011

Company Contact

Title

Company Name

Address

City, State Zip code

Re: Requirement to provide information and conduct metal hazardous air pollutant analyses 

according to Section 114 of the Clean Air Act

Dear Company contact:

We, at the U.S. Environmental Protection Agency (EPA), are collecting information on 

emissions of hazardous air pollutants (HAP) and other related information from primary 

aluminum reduction facilities, pursuant to our authority under Section 114 of the Clean Air Act

(CAA) (42 U.S.C. 7414). The information gathered will be used by the EPA to perform a review 

of the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Primary 

Aluminum Reduction Plants in 40 CFR part 63, subpart LL, developed under section 112(d) of 

the CAA (62 FR 52407, October 7, 1997). The review of the NESHAP for primary aluminum 

reduction plants is being conducted under sections 112(d) and 112(f) of the CAA.

There are two components to this information request. The first component is a survey 

requesting general facility information, information on production operations and emissions 

controls, and reports of previously performed emissions testing for each of your primary 

aluminum reduction facilities (Enclosure 1). The second component is a requirement for testing 

at your primary aluminum reduction facility and the procedures for reporting the associated test 

data (Enclosure 2).

The authority for EPA's information gathering is included in section 114 of the CAA (42 

U.S.C. 7414). All information submitted to the EPA as part of this request will be made 

available to the public unless a satisfactory showing is made that public access to such 

information would divulge methods or processes entitled to protection as confidential business 

information or trade secrets. If you believe that disclosure of specific pieces of information you 

submit would reveal confidential business information or a trade secret, you should clearly 

identify such pieces of information. Please do not label an entire response “confidential” if only 

certain portions consist of confidential business information or trade secrets. Refer to Enclosure 

3 for the information that the EPA may require, at a later time, to support your confidentiality 

claims. Any information determined to constitute a trade secret will be protected under 18 U.S.C. 

1905, 5 U.S.C.A 552(b)(4), and EPA‟s implementing regulations at 40 C.F.R. Part 2, Subpart B. 

If no claim of confidentially accompanies the information when it is received by the EPA, it may 

be made available to the public by the EPA without further notice (40 CFR part 2.203, 

September 1, 1976). Because section 114(c) of the Act exempts emission data from claims of 

confidentiality, the emission data you provide may be made available to the public. For this 

reason, questions on emissions data are listed in a separate section of the enclosed request for 

information. A clarification of what the EPA considers to be emissions data is contained in 

Enclosure 4. You should not mark the emissions data as confidential business information.
Page 2 of 37

We have contracted EC/R, (Contract No. EP-D-07019) and RTI International (RTI) 

(Contract No. EP-D-06118) to help us gather information about your industry. As noted in 

Enclosure 5, we have designated EC/R (prime contractor) and RTI (subcontractor) to be our 

authorized representatives. Therefore, EC/R and RTI have the same rights EPA has as discussed 

above and in Enclosure 3. This means that EC/R and RTI will have access to all information 

provided to us in your response to this request. As a designated representative of the Agency, 

EC/R and RTI must, by law, also abide by the requirements of 42 U.S.C. 7414(c) in regard to the 

confidentiality of what you claim to be trade secrets.

Enclosure 6 summarizes EPA‟s policies and procedures for handling confidential

information and describes EPA contractor commitments and procedures for use of confidential 

materials. It is EPA‟s policy that compliance by an authorized representative with the 

requirements detailed in Enclosure 6 provides sufficient information for the rights of submitters 

of confidential information.

If you have questions regarding the need for this information request or need clarification 

on the information requested, please contact David Putney with EPA‟s Office of Air Quality 

Planning and Standards.

After you have completed the survey responses, you should remove any components you 

wish to claim as confidential business information (CBI) from your survey and return the 

completed non-confidential survey response and the test results and other requested information 

by May 31, 2011 at the appropriate address provided below. Should you have any problems with 

meeting this deadline, please contact Mr. Putney by telephone at 919-541-2016 or by email at 

putney.david@epa.gov as soon as you are aware of a potential delay in your schedule.

Please use the address below for delivery by U.S. Mail:

David F. Putney (Mail Code D243-02)

U.S. Environmental Protection Agency

Office of Air Quality Planning and Standards

Research Triangle Park, NC 27711

Please use the address below for delivery by commercial package carriers (e.g. FedEx and UPS):

David Putney (Mail Code D243-02)

109 T.W. Alexander Drive

U.S. Environmental Protection Agency

Office of Air Quality Planning and Standards 

Durham, NC 27709

EPA recommends sending your non-CBI files via Registered U.S. Mail using return receipt 

requests, Federal Express, or other method for which someone must provide a signature upon 

receipt. You may also save the files to the disc provided in Enclosure 7 or send the completed 

forms electronically via email to primaryicr@epa.gov. If you choose to e-mail your data files 

and they are extremely large data files, you may have to zip your files in order to transmit them. 

If you have to zip your files, please change the extension of the zipped file from “zip” to “abc” 

before sending to avoid rejection by the EPA internet security fire wall.
Page 3 of 37

If you are submitting information you wish to claim as CBI as described in Enclosure 6, 

please create a separate CD or DVD containing only the CBI portion of your survey response, 

and mail the CD or DVD to EPA by May 31, 2011 at the appropriate address provided below. 

Clearly mark the disk and/or the materials with the words “Confidential Business Information” 

and send either via U.S. Postal Service Express Mail, registered mail, or private courier to:

Roberto Morales (C404-02)

c/o David Putney (ESD Project 91/43)

U.S. Environmental Protection Agency

Office of Air Quality Planning and Standards 

Research Triangle Park, NC 27711

Please use the street address below for commercial package carriers, such as FedEx and UPS:

Roberto Morales (C404-02)

c/o David Putney (ESD Project 91/43)

109 T.W. Alexander Drive

U.S. Environmental Protection Agency

Office of Air Quality Planning and Standards 

Durham, NC 27709

DO NOT ELECTRONICALLY TRANSMIT CONFIDENTIAL BUSINESS 

INFORMATION TO EPA. E-mail and facsimile (FAX) are not secure forms of communication 

and should never be used to transmit CBI.

If you have questions regarding this request, please contact David Putney, Metals and 

Inorganic Chemicals Group by telephone at 919-541-2016 or by email at putney.david@epa.gov.

I am sure you understand how vital it is for the EPA to use the very best information 

available to develop the most meaningful standards. Your help in providing this information is 

greatly appreciated.

Sincerely,

Peter Tsirigotis

Director

Sectors Policies and Programs Division

7 Enclosures

Enclosure 1: Facility Questionnaire for Primary Aluminum Reduction Plants

Enclosure 2: Test Procedures, Methods, and Reporting Requirements for the Information 

Collection Request for the Primary Aluminum Reduction Source Category

Enclosure 3: EPA‟s Authority to Gather Information (Section 114 of the CAA)

Enclosure 4: A Clarification of What EPA Considers Emissions Data
Page 4 of 37

Enclosure 5: Summary of Contractor‟s Authority as Representative of EPA

Enclosure 6: Procedures for Safeguarding CBI under the CAA

Enclosure 7: Compact Disc containing the electronic version of Enclosure 1 (Word®format) 

and the Test Data Reporting Spreadsheet (Excel®).

cc: State Air Agency (without Enclosures)

EPA Regional Office contact (without Enclosures)
Page 5 of 37

ENCLOSURE 1

Facility Questionnaire for Primary Aluminum Reduction Plants 1,2

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

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

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

Part A General Facility Information 

Part B Process and Emissions Control Devices

Part C Startups 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 out confidential business information (CBI) and non-CBI for submittal to EPA. 

Please see the instructions in the cover letter for submitting CBI.

 

1

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

Pollutants (HAP).

2

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

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

as electronic files in Excel®. Please add additional rows to the tables as needed to contain your responses. Blank 

electronic forms are included on the disc provided with this package.
Page 6 of 37

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:

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

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

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

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

a. Address: _____________________________________________________________

b. City: ________________________________________________________________

c. State: _______________________________________________________________

d. Zip: _________________________________________________________________

e. County: ______________________________________________________________

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

a. Address: _____________________________________________________________

b. City: ________________________________________________________________

c. State: _______________________________________________________________

d. Zip: _________________________________________________________________

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

a. Name (First Name, Last Name): __________________________________________

b. Title: ________________________________________________________________

c. Telephone number: ___________________________ ext. ____________________

d. Fax number: __________________________________________________________

e. E-mail: ______________________________________________________________

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

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

7. Please provide a copy of a schematic of the plant and potline layout. Please include 

beginning and end sequence potline numbers and control device ID numbers in the 

schematic.
Page 7 of 37

8. Please provide the following production information for your facility:

Normal facility production hours (i.e. the hours of facility production that would occur 

presuming typical levels of aluminum orders from customers):

Hours/day: ___________________

Days/week: ___________________

Weeks/year: ___________________

Facility production hours during the most recent full calendar year of operation:

Hours/day: __________________

Days/week: __________________

Weeks/year: __________________

Indicate year: __________________

Amount of aluminum produced by the facility during the most recent full calendar year and 

during the most recent normal operating year of the facility (if different). For the purposes 

of this survey, the most recent normal operating year of the facility means the most recent 

calendar year during which the facility operated under normal facility production hours, as 

defined above, for at least 90% of the calendar year:

_________________ Tons of aluminum produced by the facility during the most recent

full calendar year

_________________ Tons of aluminum produced by the facility during the most recent 

normal operating year

_________________ Indicate the most recent normal operating year
Page 8 of 37

PART B: PROCESSES AND EMISSIONS CONTROL DEVICES

9. Pitch storage tanks:

________________ Total number of pitch storage tanks at facility

________________ Total capacity of each pitch storage tank at facility

________________ Total amount of pitch used during the most recent full calendar year

reported in question 8

________________ Total amount of pitch used during the most recent normal operating 

year reported in question 8

10. Anode bake furnaces:

________________ Total number of anode bake furnaces at facility

________________ Facility-wide anode production capacity (tons per year)

________________ Tons of green anodes produced during the most recent full calendar 

year reported in question 8

________________ Total amount of coke used during the most recent full calendar year

reported in question 8

________________ Tons of green anodes produced during the most recent normal 

operating year reported in question 8

________________ Total amount of coke used during the most recent full calendar year

reported in question 8

10a. Describe the exhaust capture/hooding system for each anode bake furnace including 

the capture efficiency, evacuation rate, and damper system (add rows to the table 

below as necessary and use the same bake furnace ID numbers as were assigned in 

the schematic provided in response to question 7).

Anode bake 

furnace ID

Capture 

efficiency

(%)

Evacuation 

rate

(scfm)

Damper system? (i.e. to allow high 

and low flow evacuation rates)

Yes No

11. 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 ( ) Aluminum capacity ( )
Page 9 of 37

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

Potline # _____ Aluminum capacity ( )

Potline # _____ Aluminum capacity ( )

Potline # _____ Aluminum capacity ( )

Individual potlines (add rows as necessary) and aluminum output (tons per year) during the 

most recent normal operating year reported in question 8:

Potline # ________ Aluminum produced ( )

Potline # ________ Aluminum produced ( )

Potline # ________ Aluminum produced ( )

Individual potlines (add rows as necessary) and aluminum output (tons per year) during the 

most recent full calendar year reported in question 8:

Potline # ________ Aluminum produced ( )

Potline # ________ Aluminum produced ( )

Potline # ________ Aluminum produced ( )

12. Please describe your facility potline configurations (add rows as necessary and use the 

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

12a. Potline ID No. Potline Type * Total No. of Pots

Potline # ________ ___________ ___________

Potline # ________ ___________ ___________

Potline # ________ ___________ ___________

* 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)

12b. What is the average frequency, average number, and average duration of cell 

openings (side shield and/or door removals) for each potline?

Potline 

ID

Cell opening (side shield and/or door removals)

Average Frequency a Average Number b Average Duration c

(minutes)

Side shield Door Side shield Door Side shield Door
Page 10 of 37

a

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

the cited potline is opened during a 24 consecutive hour period.

b

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

all the cells in the cited potline) at any given time.

c

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

the cited potline is removed.

12c. Describe the exhaust capture/hooding system for each potline including the capture 

efficiency, evacuation rate, and damper system.

Potline ID

Capture 

efficiency

(%)

Evacuation 

rate

(scfm)

Damper system? (i.e. to allow high 

and low flow evacuation rates)

Yes No

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

cassette system? (CHECK one) ___________ Manifold or ______________ Cassette

13a. What is the total typical exhaust rate from all roof vents (scfm)?

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

________________ Typical sulfur content of pitch

________________ Maximum specified sulfur content of pitch, if applicable

________________ Typical sulfur content of coke

________________ Maximum specified sulfur content of coke, if applicable

14a. 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?

14b. What company (provide name and contact information) supplies your facility with the 

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

for these materials.

14c. Is any coal tar pitch (as opposed to petroleum pitch) used in your facility?
Page 11 of 37

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

from the pitch storage tanks, the paste plant, the anode bake furnaces, and/or the 

potlines at this facility using Tables 1, 2, 3, 4, and/or 5, as appropriate.

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

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

If so, what are those limits?

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

have any pending applications to add on any new controls? If so, please specify and 

include any copies of pending permit applications as requested in item 6 in Part A.

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

October 7, 1997 in order to meet the MACT standards for primary aluminum reduction 

plants (i.e. 40 CFR Part 63, Subpart LL).

Description of new 

control or upgrade Emission point Emission limit

Date the control or 

upgrade became 

operational

16. Pollution prevention: Describe any procedures, work practice standards, or materials used 

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

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

pollution after it is formed).

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________
Page 12 of 37

Table 1 Wet Scrubber Description

1. Control device description and ID number (use the same ID number as was assigned in the 

schematic provided in response to question 7):

2. Stack or vent location (use NAD83 and include six decimal places):

Specify the method used to obtain the latitude/longitude data:

Latitude: _______________________ Longitude: _______________________

3. Year installed: Total installed capital cost:

Annual operating hours: Annual operating and maintenance cost:

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

Pollutant Collection efficiency Outlet concentration

 Percent mg/dscf

 Percent mg/dscf

 Percent mg/dscf

5. Device type: Venturi Vertical packed bed

 Horizontal packed bed Tray tower spray chamber

 Other (specify or describe):

6. Pressure mode of operation: positive pressure negative pressure

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

8. Gas flow rate: acfm dscfm

9. Pressure drop: inches water column

10. Liquid to gas ratio: gal/1,000 acf

11. Chemical usage rate (specify chemical and typical usage rate)

Chemical added Usage rate Units for usage rate
Page 13 of 37

12. Identify each source served by this control device (add rows as necessary and use the same ID 

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

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

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

control device is operating properly:

 Volumetric flow rate Fan amperage

 Pressure drop Water flow rate

Other (specify): .

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

 Volumetric flow rate (acfm) Fan amperage (amps)

 Pressure drop (in. H2O) Water flow rate (gpm)

Other (specify): .

15. Has the collected sludge been analyzed?

_____ Yes _____ No

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

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

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

16. Additional comments and information:
Page 14 of 37

Table 2 Dry Alumina Scrubber Description

1. Control device description and ID number (use the same ID number as was assigned in the 

schematic provided in response to question 7):

2. Stack or vent location (use NAD83 and include six decimal places):

Specify the method used to obtain the latitude/longitude data:

Latitude: _______________________ Longitude: _______________________

3. Year installed: Total installed capital cost:

Annual operating hours: Annual operating and maintenance cost:

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

Pollutant Collection efficiency Outlet concentration

 Percent mg/dscf

 Percent mg/dscf

 Percent mg/dscf

5. Device type (e.g., fluidized bed or injection):

6. Pressure mode of operation: positive pressure negative pressure

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

8. Gas flow rate: acfm dscfm

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

10. Solid to gas ratio: 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

Recycled alumina

Other alumina (specify ________________)
Page 15 of 37

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

same ID numbers as were assigned in the schematic provided in response to question 7).

Source ID No(s). Description(s)

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

control device is operating properly:

 Volumetric flow rate Fan amperage

 Pressure drop

Other (specify): .

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

 Volumetric flow rate (acfm) Fan amperage (amps)

 Pressure drop (in. H2O)

Other (specify): .

15. Additional comments and information:
Page 16 of 37

Table 3 Electrostatic Precipitator (ESP) Description

1. Control device description and ID number (use the same ID number as was assigned in the 

schematic provided in response to question 7):

2. Stack or vent location (use NAD83 and include six decimal places):

Specify the method used to obtain the latitude/longitude data:

Latitude: _______________________ Longitude: _______________________

3. Year installed/rebuilt: Total installed capital cost:

Annual operating hours: Annual operating and maintenance cost:

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

Pollutant Collection efficiency Outlet concentration

 Percent mg/dscf

 Percent mg/dscf

 Percent mg/dscf

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

 Wet Dry

 Other (specify or describe):

6. Pressure mode of operation: positive pressure negative pressure

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

8. Gas flow rate: acfm dscfm

9. Collection plate surface area: __________ ft2

10. Secondary power: _____________ kW

11. Identify each emission source served by this control device (add rows as necessary and use 

the same ID numbers as were assigned in the schematic provided in response to question 7).

Source ID No(s). Description
Page 17 of 37

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

control device is operating properly:

 Visible emissions Volumetric flow Fan amperage

opacity rate

 Secondary power Secondary voltage

 Other (specify): .

13. 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): .

14. Has the collected dust or sludge been analyzed?

_____ Yes _____ No

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

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

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

15. Additional comments and information:
Page 18 of 37

Table 4 Fabric Filter Description

1. Control device description and ID number (use the same ID number as was assigned in the 

schematic provided in response to question 7):

2. Stack or vent location (use NAD83 and include six decimal places):

Specify the method used to obtain the latitude/longitude data:

Latitude: _______________________ Longitude: _______________________

3. Year installed: Total installed capital cost:

Annual operating hours: Annual operating and maintenance cost:

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

Pollutant Collection efficiency Outlet concentration

 Percent mg/dscf

 Percent mg/dscf

 Percent mg/dscf

5. Bag cleaning method:

_____ Pulse jet _____ Reverse air _____ Shaker

_____ Other (describe) _________________________________________________

6. Pressure mode of operation: positive pressure negative pressure

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

8. Gas flow rate: acfm dscfm

9. Pressure drop: inches water column

10. Air to cloth ratio: lb/1,000 acf

11. Identify each emission source served by this device (add rows as necessary and use the same 

ID numbers as were assigned in the schematic provided in response to question 7).

Source ID No(s). Description(s)
Page 19 of 37

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

control device is operating properly:

_______ Volumetric flow rate ____________ Fan amperage

_______ Visible emissions opacity ____________ Pressure drop

Other (specify): .

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

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

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

Other (specify): .

14. Has the collected dust been analyzed?

_____ Yes _____ No

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

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

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

15. Additional comments and information:
Page 20 of 37

Table 5 Other Air Pollution Control Devices

1. Control device description and ID number (use the same ID number as was assigned in the 

schematic provided in response to question 7):

2. Stack or vent location (use NAD83 and include six decimal places):

Specify the method used to obtain the latitude/longitude data:

Latitude: _______________________ Longitude: _______________________

3. Year installed: Total installed capital cost:

Annual operating hours: Annual operating and maintenance cost:

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

Pollutant Collection efficiency Outlet concentration

 Percent mg/dscf

 Percent mg/dscf

 Percent mg/dscf

 Percent mg/dscf

5. Pressure mode of operation: positive pressure negative pressure

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

7. Gas flow rate: acfm dscfm

8. Identify each emission source served by this control device (add rows as necessary and use 

the same ID numbers as were assigned in the schematic provided in response to question 7).

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

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

control device is operating properly:

 Visible emissions opacity Volumetric flow rate

 Pressure drop

Other (specify): .
Page 21 of 37

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

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

 Pressure drop (in. H2O)

Other (specify): .

11. Has the collected dust or sludge been analyzed?

_____ Yes _____ No ______ Not Applicable

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

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

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

12. Additional comments and information:
Page 22 of 37

PART C: START-UPS AND SHUTDOWNS

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

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

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

shutdown refers to the commencement and cessation of operations of a potline, not of an 

individual pot (e.g. after anode changes).

17. Is the emission profile of the unit different during start-up and shutdown than during 

normal operating conditions? Y N

If yes, please explain in detail how emissions are different during start-up and shutdown 

and why. Please also provide any information that supports your response to this question:

_________________________________________________________________________

_________________________________________________________________________

_________________________________________________________________________

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

during a start-up or shutdown? Y N

If yes:

a. Provide a copy of the test data.

b. When did you conduct such testing and why?

______________________________________________________________________

______________________________________________________________________

c. What were the operating conditions (e.g. tons of aluminum produced per day) at the 

time of the testing?

______________________________________________________________________

______________________________________________________________________

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

a SSM Plan)? If such an operating plan exists, please provide the start-up and/or shutdown

operation plan and indicate below.

___ Yes, I have provided my start-up/shutdown operating plan.

___ No, I have not provided my start-up/shutdown operating plan because (state reason)

_________________________________________________________________________

20. What was the date of the most recent potline start-up? ______________

Did that start-up follow a planned shutdown or an emergency shutdown?

(CHECK one) ___________ Planned shutdown or ____________ Emergency Shutdown

21. Have you been able to eliminate any types of start-ups or shutdowns? If so, please explain 

how these types of start-ups or shutdowns were eliminated.

_________________________________________________________________________

_________________________________________________________________________
Page 23 of 37

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

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

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

_____ b. Perform daily assessment of startup progress and any schedule changes

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

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

first cell to be restarted

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

If so, how much higher? ____________(percent)

Basis for adjustment? _______________________________________

_____ f. Keep pots covered during start-up

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

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

_____ i. Adjust exhaust flow from pots during pot start-up

Basis for adjustment? _______________________________________

_____ j. Adjust cell voltage and feeding levels during start-up.

Frequency? _______________________________________

Basis for adjustment? _______________________________________

_____ k. Monitor and adjust anode current and liquid level

Frequency? _______________________________________

Basis for adjustment? _______________________________________

_____ l. Monitor pot lines frequently during start-up to identify “sick” pots

_____ m. Have corrective procedures for sick or unstable pot during start-up

Please list these procedures (use additional pages if needed):

_____________________________________________________________

_____________________________________________________________

_____________________________________________________________

_____________________________________________________________

_____________________________________________________________

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

______________________________________________________________________

______________________________________________________________________

______________________________________________________________________

______________________________________________________________________

______________________________________________________________________
Page 24 of 37

Table 6 Description of most recent potline start-ups and shutdowns (Make additional copies this table as needed)

Potline ID

(as assigned in 

the schematic of 

question 7)

Date(s), duration 

(hours), and 

description of 

start-up or 

shutdown

What permit 

conditions were 

exceeded?

Was the start-up 

or shutdown

covered by a 

contingency plan 

for controlling 

emissions? (Y/N)

What actions 

were taken to 

minimize 

emissions?

Estimates of 

emissions 

(specify the 

pounds of each 

pollutant)

Basis for 

emissions 

estimate

Was any monitoring 

data or control 

system parameter 

monitoring 

collected? (Y/N)

(If Y, see note below 

this table)

Note: If any monitoring data or control system parameter monitoring data was collected during an event then provide the data collected, information on the test 

method(s) used, when the testing was conducted and why, and whether the tests were associated with a routine start-up or shutdown.
Page 25 of 37

PART D: PREVIOUSLY PERFORMED TESTING AND TEST REPORT DATA

24. Submit test reports from emission tests that were performed on the sources listed below 

over the past five (5) years (i.e. calendar years 2006 through 2010), or for the most recent 

tests if no tests have been conducted within the past five (5) years, for metal HAP (i.e. 

antimony, arsenic, beryllium, cadmium, chromium, hexavalent chromium, cobalt, lead, 

manganese, nickel, and selenium), total fluorides (TF) and/or hydrogen fluoride (HF), 

particulate matter (PM), polycyclic organic matter (POM, with individual polycyclic 

aromatic hydrocarbons listed by CAS number) and other organic HAP, and/or carbonyl 

sulfide (COS) on the processes listed below (we would prefer electronic copies of these 

reports, if available):

 Paste plants

 Potlines

 Pitch storage tanks

 Anode bake furnaces

 Raw materials used in the primary aluminum reduction process (e.g. test data or 

product specification sheets)

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

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

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

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

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

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

25. If emission controls were installed or upgraded to meet the maximum achievable control 

technology (MACT) standard in Subpart LL of 40 CFR Part 63, please also include test 

reports, including the information specified in 24(a) through (d), for the most recent year 

for any emission testing that was performed before these controls were installed or 

upgraded and identify them as “pre-MACT test reports.”

26. Has any air monitoring, such as Fourier Transform Infrared (FTIR) Spectroscopy, been 

performed inside the potrooms at your facility to measure HF, sulfur oxides, and/or COS

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

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

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

rate during sampling, and potroom operations performed during the sampling.
Page 26 of 37

ENCLOSURE 2

Test Procedures, Methods, and Reporting Requirements for the Information Collection 

Request for the Primary Aluminum Reduction Source Category

This document provides an overview of approved methods, target pollutants and units of 

measure, and reporting requirements for the primary aluminum reduction source category. See 

Enclosure 3 for details about EPA‟s authority under the Clean Air Act (CAA) section 114 (42 

U.S.C. 7414) to request source emission test data. All recipients must complete and submit test 

results by May 31, 2011. This document will be referred to as the „primary aluminum reduction 

test program.‟ The document is organized as follows:

1.0 Sampling and Chemical Analysis Procedures and Methods for Metallic HAP 

(including speciated hexavalent chromium)

2.0 How to Report Data

3.0 How to Submit Data

4.0 Contact Information for Questions on Test Plan and Reporting

1.0 Sampling and Chemical Analysis Procedures and Methods for Metallic HAP 

(including speciated hexavalent chromium)

1.1 Sampling - Bag House and Electrostatic Precipitator Particulate Matter

Sample and analyze the particulate matter collected in the hopper of each of the bag 

houses or electrostatic precipitators used to control particulate matter from primary 

aluminum potlines. In cases where solids from different compartments of a single bag 

house or electrostatic precipitator are collected in multiple hoppers or multiple collection

sacks, a single composite sample will be adequate. Sampling should be conducted once 

per day for five consecutive operating days with a clean uncontaminated scoop or similar 

apparatus, and all samples collected should be stored in a clean air-tight container.

Each sample should be approximately 50 grams, dry weight. Guidance on sample 

collection can be found in of Chapter 4 of the document Superfund Program 

Representative Sampling Guidance, Volume 1: Soil (EPA 540/R-95/141), which is 

available through the following link:

http://www.epa.gov/tio/download/char/sf_rep_samp_guid_soil.pdf

1.2 Sampling – Wet Scrubber Sludge, Injected Slurry (if applicable), and Discharge Water

Sample and analyze the scrubber sludge, injected slurry (if applicable) and any aqueous

blowdown stream discharged from the wet scrubber. Collect a representative grab sample 

of approximately 50 grams dry weight of scrubber sludge. If a separate stream of 

scrubber blowdown is discharged from the scrubber, collect a representative grab sample
Page 27 of 37

of approximately 1000 milliliters of this stream. Sampling should be conducted once per 

day for five consecutive operating days.

1.3 Chemical Analysis

Analyze each sample of bag house or electrostatic precipitator particulate matter, 

scrubber sludge, injected slurry (if any), and scrubber blowdown (if any) for individual 

HAP metals as listed in Table 1.1. Also analyze each sample for hexavalent chromium. 

Methods for chemical analysis are given in Table 1.2.

Table 1.1 HAP Metals

Antimony Arsenic Beryllium

Cadmium Chromium Hexavalent Chromium

Cobalt Lead Manganese

Nickel Selenium

Table 1.2 Methods for Analysis of Samples

Analyte Procedure

HAP metals listed 

in Table 1.1

EPA Method 3051A digestion followed by ICP-MS

as detailed in EPA Method 6020

Hexavalent 

chromium

EPA Method 3060A and EPA Method 218.6: 

Extraction and Cr+6 Ion Chromatography

2.0 How to Report Data

2.1 Reporting Bag House or Electrostatic Precipitator Particulate Matter, Wet Scrubber 

Sludge, Injected Slurry, and Discharge Water Chemical Analyses

You must report the results of the chemical analyses of your bag house or electrostatic 

precipitator particulate matter and wet scrubber sludge, injected slurry, and discharge 

water in a Microsoft®Excel Template which is provided. If more than one sample is 

analyzed, you must make a copy of the worksheet and update the source ID in order to 

distinguish between each analysis of particulate matter collected from each selected bag 

house. After completing the worksheet, you must also submit an electronic copy of the 

chemical analysis report (PDF format preferred).

2.2 Calculating and Reporting Values Measured Below Method Detection Levels

See Appendix C – Guidance for calculating and reporting measurements less than 

detection levels for emissions data collection (ICR) programs
Page 28 of 37

3.0 How to Submit Data

Use one of three transmittal methods listed below. In order to avoid duplicate data and keep all 

data for a particular facility together, we request that you submit all of the data requested from 

your company in the same way. To submit your data:

 E-mail an electronic copy of all requested files to primaryicr@epa.gov.

 If the files are too large for your e-mail system, you may upload the electronic files to a 

FTP site; if you would like to use this option, send an email to bahner@rti.org for 

instructions on how to access the site.

 Mail a CD or DVD containing an electronic copy of all requested files to the EPA 

address shown in your Section 114 letter.

If you are submitting CBI, you must mail a separate CD or DVD containing only the CBI 

portion of your data to the EPA address shown in your Section 114 letter.

4.0 Contact Information for Questions on Test Plan and Reporting

For questions on the primary aluminum source category, contact:

David Putney (U.S. EPA)

(919) 541-2016

putney.david@epa.gov

OR

Rochelle Boyd (U.S. EPA)

(919) 541-1390

boyd.rochelle@epa.gov

For questions on the test methods contact:

Gerri Garwood (U.S. EPA)

(919) 541-2406

garwood.gerri@epa.gov

OR

Raymond Merrill (U.S. EPA)

(919) 541-5225

merrill.raymond@epa.gov

For questions on uploading files to the FTP site, contact:

Mark Bahner (RTI, International)

(919) 541-6016

bahner@rti.org
APPENDIX A

Page 29 of 37

Abbreviations, Acronyms, and Unit Conversions

acf actual cubic feet

acfm actual cubic feet per minute

acm actual cubic meters

acmm actual cubic meters per minute

ADL above detection level

APC air pollution control

ASTM American Society for Testing and Materials

atm atmospheres (unit of pressure)

BDL below detection level

Btu/hr British thermal units per hour

Btu/scf British thermal units per standard cubic foot

CAA Clean Air Act

CARB California Air Resources Board

CBI confidential business information

CEMS continuous emission monitoring system

CFR Code of Federal Regulations

CO carbon monoxide

COS carbonyl sulfide

Cr chromium

CS2 carbon disulfide

CTM Conditional Test Method

day/yr days per year

°C degrees Celsius 

°F degrees Fahrenheit

D/F dioxins and furans

DLL detection level limited

dscf dry standard cubic feet

dscfm dry standard cubic feet per minute

dscm dry standard cubic meters

dscmm dry standard cubic meters per minute

EPA U.S. Environmental Protection Agency

ERT Electronic Reporting Tool

ESP electrostatic precipitator

ft foot or feet

ft2square feet

ft3cubic feet

fpm feet per minute (acfm divided by ft2of filter area)

fps feet per second

gal gallon

gpm U.S. gallons per minute

gr/dscf grains per dry standard cubic foot

g gram

HAP hazardous air pollutants

HCl hydrogen chloride

HCN hydrogen cyanide
APPENDIX A

Page 30 of 37

HF hydrogen fluoride

Hg mercury

hr hour or hours

hr/day hours per day

ICR information collection request

in inch or inches

in H2O inches of water (pressure drop)

kg kilogram

kPa kilopascals

kv kilovolt

kw-hr kilowatt hour

lb pound

lb/day pounds per day

lb/gal pounds per U.S. gallon

lb/hr pounds per hour

lb/ton pounds per ton

m meter

m

3

cubic meters

MACT maximum achievable control technology

min minute or minutes

Mg megagram

mg milligram

mg/kg milligram per kilogram

mg/l milligrams per liter

MM btu/hr millions of British thermal units per hour

MM scf millions of standard cubic feet

MMlb/yr million pounds per year

μg/m3 microgram per cubic meter

μm micrometer

NAICS North American Industry Classification System

NaOH sodium hydroxide

NESHAP National Emission Standards for Hazardous Air Pollutants

NOx nitrogen oxides

OAQPS Office of Air Quality Planning and Standards

OTM Other Test Method

PAH polynuclear aromatic hydrocarbon

PAL primary aluminum reduction facility

pdf Image file format produced with Adobe© or similar software

PM particulate matter

PM2.5 particulate matter that is 2.5 micrometers or less in diameter

POM polycyclic organic matter

ppmv parts per million by volume

ppmw parts per million by weight

RATA Relative Accuracy Test Audit

% percent

s second or seconds
APPENDIX A

Page 31 of 37

scf standard cubic feet

scf/hr standard cubic feet per hour

scfm standard cubic feet per minute

scm standard cubic meters

SO2 sulfur dioxide

SPPD Sector Policies and Programs Division

SS startup or shutdown

TCLP toxicity characteristic leaching procedure

TF total fluorides

THC total hydrocarbons

tpd tons (short) per day

tph tons (short) per hour

tpy tons (short) per year 

TSP total suspended particulate

vol% volume percent, or percent by volume

wt% weight percent, or percent by weight

yr year

To convert from To Multiply by

°C °F multiply by 1.8, then add 32

°F °C subtract 32, then multiply by 0.556

ft m 0.3048

ft/min m/min 0.3048

ft2m

2

0.0929

ft3 m

3

0.028

g lb 0.0022

g/m3lb/ft30.0000624

gr lb 0.000143

gr/dscf mg/dscm 2,290

in H2O mm H2O 25.4

kg/hr lb/hr 2.205

lb g 454

lb gr 7000

lb/ft3g/m316,000

lb/hr kg/hr 0.454

m ft 3.28

m/min ft/min 3.28

mm H2O in H2O 0.0394

m

2

ft210.76

mg/dscm gr/dscf 0.00044

m

3

ft335.31

Mg ton 1.1

ton (short) Mg 0.907
APPENDIX B

Page 32 of 37

List of Hazardous Air Pollutants (HAP)

CAS 

Number Chemical Name

Antimony Compounds

Arsenic Compounds (inorganic including arsine)

Beryllium Compounds

Cadmium Compounds

Chromium Compounds

Cobalt Compounds

Coke Oven Emissions

Cyanide Compounds1

Glycol ethers2

Lead Compounds

Manganese Compounds

Mercury Compounds

Fine mineral fibers3

Nickel Compounds

Polycylic Organic Matter4(Report individual polycyclic 

aromatic hydrocarbons by CAS number).

Radionuclides (including radon)5

Selenium Compounds

75070 Acetaldehyde

60355 Acetamide

75058 Acetonitrile

98862 Acetophenone

53963 2-Acetylaminofluorene

107028 Acrolein

79061 Acrylamide

79107 Acrylic acid

107131 Acrylonitrile

107051 Allyl chloride

92671 4-Aminobiphenyl

62533 Aniline

90040 o-Anisidine

1332214 Asbestos

71432 Benzene (including benzene from gasoline)

92875 Benzidine

98077 Benzotrichloride

100447 Benzyl chloride

92524 Biphenyl

117817 Bis(2-ethylhexyl)phthalate (DEHP)

542881 Bis(chloromethyl)ether

75252 Bromoform

106990 1,3-Butadiene

156627 Calcium cyanamide
APPENDIX B

Page 33 of 37

CAS 

Number Chemical Name

133062 Captan

63252 Carbaryl

75150 Carbon disulfide

56235 Carbon tetrachloride

463581 Carbonyl sulfide

120809 Catechol

133904 Chloramben

57749 Chlordane

7782505 Chlorine

79118 Chloroacetic acid

532274 2-Chloroacetophenone

108907 Chlorobenzene

510156 Chlorobenzilate

67663 Chloroform

107302 Chloromethyl methyl ether

126998 Chloroprene

1319773 Cresols/Cresylic acid (isomers and mixture)

95487 o-Cresol

108394 m-Cresol

106445 p-Cresol

98828 Cumene

94757 2,4-D, salts and esters

3547044 DDE

334883 Diazomethane

132649 Dibenzofurans

96128 1,2-Dibromo-3-chloropropane

84742 Dibutylphthalate

106467 1,4-Dichlorobenzene(p)

91941 3,3-Dichlorobenzidene

111444 Dichloroethyl ether (Bis(2-chloroethyl)ether)

542756 1,3-Dichloropropene

62737 Dichlorvos

111422 Diethanolamine

121697 N,N-Diethyl aniline (N,N-Dimethylaniline)

64675 Diethyl sulfate

119904 3,3-Dimethoxybenzidine

60117 Dimethyl aminoazobenzene

119937 3,3'-Dimethyl benzidine

79447 Dimethyl carbamoyl chloride

68122 Dimethyl formamide

57147 1,1-Dimethyl hydrazine

131113 Dimethyl phthalate

77781 Dimethyl sulfate

534521 4,6-Dinitro-o-cresol, and salts
APPENDIX B

Page 34 of 37

CAS 

Number Chemical Name

51285 2,4-Dinitrophenol

121142 2,4-Dinitrotoluene

123911 1,4-Dioxane (1,4-Diethyleneoxide)

122667 1,2-Diphenylhydrazine

106898 Epichlorohydrin (l-Chloro-2,3-epoxypropane)

106887 1,2-Epoxybutane

140885 Ethyl acrylate

100414 Ethyl benzene

51796 Ethyl carbamate (Urethane)

75003 Ethyl chloride (Chloroethane)

106934 Ethylene dibromide (Dibromoethane)

107062 Ethylene dichloride (1,2-Dichloroethane)

107211 Ethylene glycol

151564 Ethylene imine (Aziridine)

75218 Ethylene oxide 

96457 Ethylene thiourea

75343 Ethylidene dichloride (1,1-Dichloroethane)

50000 Formaldehyde

76448 Heptachlor

118741 Hexachlorobenzene

87683 Hexachlorobutadiene

77474 Hexachlorocyclopentadiene

67721 Hexachloroethane

822060 Hexamethylene-1,6-diisocyanate

680319 Hexamethylphosphoramide

110543 Hexane

18540299 Hexavalent chromium

302012 Hydrazine

7647010 Hydrochloric acid

7664393 Hydrogen fluoride (Hydrofluoric acid)

123319 Hydroquinone

78591 Isophorone

58899 Lindane (all isomers)

108316 Maleic anhydride

67561 Methanol

72435 Methoxychlor

74839 Methyl bromide (Bromomethane)

74873 Methyl chloride (Chloromethane)

71556 Methyl chloroform (1,1,1-Trichloroethane)

60344 Methyl hydrazine

74884 Methyl iodide (Iodomethane)

108101 Methyl isobutyl ketone (Hexone)

624839 Methyl isocyanate

80626 Methyl methacrylate
APPENDIX B

Page 35 of 37

CAS 

Number Chemical Name

1634044 Methyl tert butyl ether

101144 4,4-Methylene bis(2-chloroaniline)

75092 Methylene chloride (Dichloromethane)

101688 Methylene diphenyl diisocyanate (MDI)

101779 4,4'¬-Methylenedianiline

91203 Naphthalene

98953 Nitrobenzene

92933 4-Nitrobiphenyl

100027 4-Nitrophenol

79469 2-Nitropropane

684935 N-Nitroso-N-methylurea

62759 N-Nitrosodimethylamine

59892 N-Nitrosomorpholine

56382 Parathion

82688 Pentachloronitrobenzene (Quintobenzene)

87865 Pentachlorophenol

108952 Phenol

106503 p-Phenylenediamine

75445 Phosgene

7803512 Phosphine

7723140 Phosphorus

85449 Phthalic anhydride

1336363 Polychlorinated biphenyls (Aroclors)

1120714 1,3-Propane sultone

57578 beta-Propiolactone

123386 Propionaldehyde

114261 Propoxur (Baygon)

78875 Propylene dichloride (1,2-Dichloropropane)

75569 Propylene oxide

75558 1,2-Propylenimine (2-Methyl aziridine)

91225 Quinoline

106514 Quinone

100425 Styrene

96093 Styrene oxide

1746016 2,3,7,8-Tetrachlorodibenzo-p-dioxin

79345 1,1,2,2-Tetrachloroethane

127184 Tetrachloroethylene (Perchloroethylene)

7550450 Titanium tetrachloride

108883 Toluene

95807 2,4-Toluene diamine

584849 2,4-Toluene diisocyanate

95534 o-Toluidine

8001352 Toxaphene (chlorinated camphene)

120821 1,2,4-Trichlorobenzene
APPENDIX B

Page 36 of 37

CAS 

Number Chemical Name

79005 1,1,2-Trichloroethane

79016 Trichloroethylene

95954 2,4,5-Trichlorophenol

88062 2,4,6-Trichlorophenol

121448 Triethylamine

1582098 Trifluralin

540841 2,2,4-Trimethylpentane

108054 Vinyl acetate

593602 Vinyl bromide

75014 Vinyl chloride

75354 Vinylidene chloride (1,1-Dichloroethylene)

1330207 Xylenes (isomers and mixture)

95476 o-Xylenes

108383 m-Xylenes

106423 p-Xylenes

NOTE: For all listings above which contain the word "compounds" and for glycol 

ethers, the following applies: Unless otherwise specified, these listings are defined as 

including any unique chemical substance that contains the named chemical (i.e., 

antimony, arsenic, etc.) as part of that chemical's infrastructure.

1: X'CN where X = H' or any other group where a formal dissociation may occur. For 

example KCN or Ca(CN)2

2: Includes mono- and di- ethers of ethylene glycol, diethylene glycol, and triethylene 

glycol R-(OCH2CH2)n -OR' where:

n = 1, 2, or 3

R = alkyl or aryl groups

R' = R, H, or groups which, when removed, yield glycol ethers with the structure: 

R-(OCH2CH)n-OH. Polymers are excluded from the glycol category. Also 

excludes ethylene glycol monobutyl ether (EGBE) (2-Butoxyethanol) 

(Chemical Abstract Service (CAS) No. 111-76-2) and surfactant alcohol 

ethoxylates and their derivatives (SAED).

3: Includes mineral fiber emissions from facilities manufacturing or processing glass, 

rock, or slag fibers (or other mineral derived fibers) of average diameter 1 

micrometer or less.

4: Includes organic compounds with more than one benzene ring, and which have a 

boiling point greater than or equal to 100o C. Report individual polycyclic aromatic 

hydrocarbons by CAS number.

5: A type of atom which spontaneously undergoes radioactive decay.
APPENDIX C

Page 37 of 37

Guidance For Calculating And Reporting Measurements Less Than

Method Detection Levels For Test Data Submitted in Response

to Information Collection Request (ICR) Programs

Identify the status of measured values relative to detection levels on the spreadsheet using the 

following descriptions:

 BDL (below detection level) – all analytical values used to calculate and report a fabric 

filter particulate matter, electrostatic precipitator particulate matter, sludge, or scrubber 

blowdown metal analysis are less than the laboratory‟s reported detection level(s);

 DLL (detection level limited) – at least one, but not all, values used to calculate and 

report a fabric filter particulate matter, electrostatic precipitator particulate matter, sludge, 

or scrubber blowdown metal analysis are less than the laboratory‟s reported detection 

level(s); or

 ADL (above detection level) – all analytical values used to calculate and report a fabric 

filter particulate matter, electrostatic precipitator particulate matter, sludge, or scrubber 

blowdown metal analysis are greater than the laboratory‟s reported detection level(s).

For each reported emissions value, insert the appropriate flag (i.e. BDL, DLL, or ADL) in 

the Note line of Excel emission test spreadsheet template.

When reporting and calculating individual test run data:

 For analytical data reported from the lab as “nondetect” or “below detection level;”

 Include a brief description of the procedures used to determine the analytical 

detection levels in the Note line of Excel®emission test spreadsheet template.

 Describe these procedures completely in a separate attachment including the 

measurements made, the standards used, and the statistical procedures applied.

 Report the calculated emissions concentration or rate result as a bracketed “less 

than” detection level value (e.g., [<0.0105]) in the Excel®emission test

spreadsheet template

 Report as numerical values (i.e., no brackets or < symbol) any analytical data 

measured above the detection level including any data between the analytical 

detection level and a laboratory-specific reporting or quantification level (i.e., flag 

as ADL).