From: Rufa, Nathan P. [ mailto:Nathan.Rufa@alcoa.com ]
Sent: Thursday, November 07, 2013 4:31 PM
To: Boyd, Rochelle Subject: RE: RE: FW: RE: FW: Alcoa Massena

- West files



### Rochelle,

Yes, attached is the full stack test report for Furnace #31. Thanks.

Nathan Rufa

Staff Environmental Engineer Alcoa Primary Metals Massena Operations Park Avenue East / PO Box 150 Massena, NY 13662 Tel: 315

- 764

- 4285 Fax: 315

- 764

- 4460 nathan.rufa@alcoa.com

From: Boyd, Rochelle [ mailto:Boyd.Rochelle@epa.gov ]
Sent: Thursday, November 07, 2013 4:20 PM
To: Rufa, Nathan P. Subject: EXT: RE: FW: RE: FW: Alcoa Massena

- West files



### Thanks. Did you ever get the full stack test report in pdf format for furnace #31?

Rochelle Boyd, 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

- 1390 Fax: (919) 541

- 3207

From: Rufa, Nathan P. [ mailto:Nathan.Rufa@alcoa.com ]
Sent: Thursday, November 07, 2013 3:56 PM
To: Boyd, Rochelle Subject: RE: FW: RE: FW: Alcoa Massena

- West files



### Rochelle,

Yes, the maximum capacity would be the same at 36,000 tons/year.

Nathan Rufa
Staff Environmental Engineer Alcoa Primary Metals Massena Operations Park Avenue East / PO Box 150 Massena, NY 13662 Tel: 315

- 764

- 4285 Fax: 315

- 764

- 4460 nathan.rufa@alcoa.comFrom: Boyd, Rochelle [ mailto:Boyd.Rochelle@epa.gov ]
Sent: Thursday, November 07, 2013 2:33 PM
To: Rufa, Nathan P. Subject: EXT: FW: RE: FW: Alcoa Massena

- West files



### Does the new furnace #31 have the same maximum capacity of 36000 tons/year as furnace #14? Thanks

Rochelle Boyd, 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

- 1390 Fax: (919) 541

- 3207

From: Rufa, Nathan P. [ mailto:Nathan.Rufa@alcoa.com ]
Sen t: Thursday, September 19, 2013 1:17 PM
To: Boyd, Rochelle
Cc: Parent, Jordan J. Subject: RE: RE: FW: Alcoa Massena

- West files



### Rochelle,

Yes, in 2012 we permitted the new #31 Furnace which rendered #14 Melter inactive. The new dioxin/furan emission factor from #31 Furnace (M0031) should be used for the following representative sources: M001A, M001B, M003C, M024D, M024F and M0031. Thanks.

Nathan Rufa
Staff Environmental Engineer Alcoa Primary Metals Massena Operatio ns Park Avenue East / PO Box 150 Massena, NY 13662 Tel: 315

- 764

- 4285 Fax: 315

- 764

- 4460 nathan.rufa@alcoa.com

From: Boyd, Rochelle [ ma ilto:Boyd.Rochelle@epa.gov ]
Sent: Thursday, September 19, 2013 1:01 PM
To: Rufa, Nathan P.
Cc: Parent, Jordan J. Subject: EXT: RE: FW: Alcoa Massena

- West files



### Thanks for the update. Has a request been submitted to your permitting authority to
render #1 4 Melter as inactive? Otherwise, we will have to count those originally reported
emissions.

Rochelle Boyd, 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

- 1390 Fax: (919) 541

- 3207From: Rufa, Nathan P. [ mailto:Nathan.Rufa@alcoa.com ]
Sent: Thursday, September 19, 2013 12:48 PM
To: Boyd, Rochelle
Cc: Parent, Jordan J. Subject: RE: FW: Alcoa Massena

- West files



### R ochelle,

You are correct, the summary we sent only had the test results for one furnace, M0031 (31 furnace.) Here’s why:

On March 29 th 

### , 2012 the Massena West Casthouse sustained a major roof fire which completely shut down the entire Casthouse facility and took out all SMACT sources within it. Since then we have restarted the following sources: M0034 (#35 Melter/Holder), M0035 (#36 M elter/Holder), M024D (#33 Melter/Holder) & M024F (#32 Melter/Holder). In addition, we have permanently shut down M003A (#14 Melter/Holder) and have added a new source, M0031 (#31 Melter/Holder)

. All other sources have not restarted and there

are no fore seeable future plans to do so.

We tested M0031 for two purposes. First it was a new source and we had to test it to show initial compliance. Secondly, since it was nearly an identical furnace to M024F and M024D, it was considered a representative sour ce and thus the emission factors from the test will be applied to all other representative

sources.

I have highlighted the changes in the attached excel spreadsheet tab “Modeling_File_Calc_Inputs” and revised table 38a. in tab “2011_MassenaWest_ICR_resp onse” to reflect the changes.

Please let me know if you have any other questions. Thank you.

Nathan Rufa
Staff Environmental Engineer Alcoa Primary Metals Massena Operations Park Avenue East / PO Box 150 Massena, NY 13662 Tel: 315

- 764

- 4285 Fa x: 315

- 764

- 4460 nathan.rufa@alcoa.com

From: Boyd, Rochelle [ mailto:Boyd.Rochelle@epa.gov ]
Sent: Wednesday, September 18, 2013 4:29 PM
To: Parent, Jordan J. Subject: EXT: FW: Alcoa Masse na

- West files



### The summary that you sent me only had the test results for one furnace. Did you test the other equipment emitting dioxins and furans? Can you also review the attached information for accuracy? Thanks

Rochelle Boyd, 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

- 1390 Fax: (919) 541

- 3207

# A lcoa Massena Operations

– West Plant Massena, New York

September 20 13 

# Source Emission Testing of Furnace 31 SOURCE EMISSION COMP LIANCE TEST REPORTSOURCE EMISSION COMP LIANCE TEST REPORT

More than Engineering Solutions 11423 │ 50930



# Source Emission Testing of Furnace 31

REVIEWED BY: PATRICK GRADY, PROJE CT ASSOCIATE

O ’ Brien & Gere Engineers, Inc. 

## Alcoa Massena Operations

– West Plant Massena, New York

PREPARED BY: DAVID OSTASZEWSKI, P .E., SENIOR MANAGING ENGI NEER

O ’ Brien & Gere Engineers, Inc.SOURCE EMISSION TEST ING OF FURNACE 31

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# TABLE OF CONTENTS

**List of Tables**

**................................................................................................ ............................................................................**  **ii**
**List of Appendices**

**................................................................................................ ..................................................................**  **ii**

1. Introduction .......................................................................................................................................................................................... 1

1.1 Emissions Testing Program Objectives .............................................................................................................................. 1

1.2 Emissions Testing Program Participants ........................................................................................................................... 1

2. Source D escription and Process Operating Data ................................................................................................................... 2

2.1 Process Description .................................................................................................................................................................... 2
2.2 Process Operating Conditions During Testing ................................................................................................................ 2

3. T est Program Summary And Sample Procedures ................................................................................................................ 3

3.1 Sampling Site Description and Sampling Locations ...................................................................................................... 3
3.2 Gas Velocity and Volumetric Flow Rate .............................................................................................................................. 3
3.3 Diluent Gas Analysis ................................................................................................................................................................... 3

3.4 Moisture Content .......................................................................................................................................................................... 3
3.5 PM/HCl Emissions ....................................................................................................................................................................... 3

3.6 NOx and CO Emissions ............................................................................................................................................................... 4
3.7 PCDD/DF Test Method ............................................................................................................................................................... 4

3.7.1 PCCD/DF QA/QC Procedures .......................................................................................................................................... 5

4. Results, Discussions and Conclusions ....................................................................................................................................... 6

4.1 PM/HCl Te st Results (Table 1) ............................................................................................................................................... 6
4.2 PCDD/DF Emission Results (Table 2) ................................................................................................................................. 6
4.3 NOx and CO Test Results (Table 3) ....................................................................................................................................... 6

4.4 Conclusions ..................................................................................................................................................................................... 6
5. Quality Assurance/Quality Control ............................................................................................................................................. 7

5.1 Equipment Calibration ............................................................................................................................................................... 7
5.2 Laboratory QA/QC Procedures .............................................................................................................................................. 7
5.3 NOx and CO Sampling ................................................................................................................................................................. 7

5.4 Leak Checks .................................................................................................................................................................................... 7
5.5 Chain of Custody Documentation .......................................................................................................................................... 7
5.6 Blank and Audit Samples .......................................................................................................................................................... 8
5.7 Test Data and Report Review ................................................................................................................................................. 8SOURCE EMISSION TEST ING OF FURNACE 31

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# LIST OF TABLES

1 Summary of Particulate and HCl Emission Results

2 Summary of PCDD/PCDF Emission Results

3 Summary of Nitrogen Oxide and Carbon Monoxide Emission Results



# LIST OF APPENDICES

A Facility Operating Data

B Schematic of the Test Location
C Field Data and Calculations

D Laboratory Data

E Equipment Calibration DataSOURCE EMISSION TEST ING OF FURNACE 31

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### 1. INTRODUCTION

O’Brien & Gere was retained by Alcoa Massena Operations (Alcoa) to conduct source emission testing
on the exhaust of Furnace 31 at their West Plant facility located in Massena, New York. Testing was
conducted on August 5 and 6 , 2013

.

Mr . Nathan Rufa of Alcoa was present to coordinate process operations with the testing. Ms. Melissa Miller of New York State Department of Environmental Conservation (NYSDEC) was present to witness the
field testing.

The remaining sections of this report include a source description, sampling methods, test equipment QA/QC procedures, and test results and discussion.



### 1.1 EMISSIONS TESTING PR OGRAM OBJECTIVES

The objective of the testing was to satisfy the initial Secondary Aluminum Production MACT (SMACT) and NYSDEC source emission testing requirements.



### 1.2 EMISSIONS TESTING PR OGRAM PARTICIPANTS

**Facility**

Name: Alcoa Massena Operations

NYSDEC Facility ID: 6405800003

Address: Park Avenue East Massena, New York 13662

Contact: Nathan Rufa

Telephone number: (315) 764

- 4285 **Source Testing Company**

Name: O’Brien & Gere Engineers, Inc.

A ddress: 7600 Morgan Road Liverpool, New York 13090

Contact: David Ostaszewski, P.E.

Telephone number: (315) 956

- 6033

**Sample Analysis Laborator ies** 

Name: Maxxam Analytics, Inc.

Address: 5555 North Service Road Burlington, Ontario, Canada
L7L 5H7

SSAS Program ID: TNI01292

Contact: Mike Challis

Telephone number: (905) 332

- 8788

Samples Analyzed: Particulate and HCl

Name: SGS Analytical Perspectives

Address: 2714 Exchange Drive Wilmington, North Carolina
28405

Contact: Heather Distel, Ph.D.

Telephone number: (910) 794

- 1613

Samples Analyzed: PCDD/PCDFSOURCE EMISSION TEST ING OF FURNACE 31

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### 2. SOURCE DESCRIPTIO N AND PROCESS OPERAT ING DATA

This section provides descriptions of the process and emissions control equipment, as well as process operating conditions during the SMACT compliance testing.



### 2.1 PROCESS DESCRIPT ION

Furnace 31 is a melter/holder furnace that can process both clean charge as well as non

- uniform scrap. The furnace melts the solid aluminum scrap into molten metal that is subsequently cast into aluminum ingots. The furnace uses r eactive salt flux to remove impurities. Emissions from the source include PM, HCl, PCDD/PCDF and products of
combustion. Emissions from the furnace are exhausted through its own stack that discharges directly to atmosphere. 

### 2.2 PROCESS OPERATING CO ND ITIONS DURING
TESTING

Testing of the furnace exhaust was conducted during a single operating condition that represented typical process operating conditions. During each test run facility personnel monitored and recorded the following process data:

» aluminu m production (lb)

» solid and gaseous chlorine addition rate (lb)

A summary of the aluminum production information

is included in Appendix A.SOURCE EMISSION TEST ING OF FURNACE 31

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### 3. T EST PROGRAM SUMMARY AND SAMPLE PROCEDURES

This section provides a summary of the test program
conducted and a description of the test methods that were utilized as part of the field testing program.

Source emission testing was conducted on the
exhaust of Furnace 31

. A summary of the test
parameters c an be found in Table 3.1 below. Source testing was conducted in triplicate during normal process operating conditions as maintained by facility
operators. T est run durations varied depending on the furnace cycle. Specific test durations can be found in Summary of Result Table s 1 through 3.



### 3. 1 SAMPLING SITE DESCRIPTION AND SAMPLING
LOCATIONS

Test ports in the 58

- inch by 64 inch furnace exhaust are located approximately 48 feet ( 9.6 equivalent diameters) downstream of the furnace exhaust and approximately 20 feet ( 4.0 equiv alent diameters) upstream of the stack exhaust. In accordance with

USEPA Reference Method ( RM ) 1, a 20

- point traverse was conducted during each isokinetic test run. A
schematic of the test location can be found in Appendix B.



### 3. 2 GAS VELOCITY AND VOL UMETRI C FLOW RATE

Exhaust gas velocities were calculated from differential pressure, measured using a stainless steel

S- type pitot tube and an inclined oil manometer, and exhaust gas temperatures, measured using a Type

- K thermocouple atta ched to the pitot tube. US EPA RM 1 was followed to establish equal areas across the

cross

- sectional area of the stack at which differential pressure and temperature were measured.

Table 1 Summary of Test Program – Alcoa Massena West Plant

Test Location Test Parameters Reported Test

Units Number of

Traverse Points Sampled a Number of Test Runs /Test

Durations

West Plant

Furnace 31 PCDD/DF, PM/ HCl, NOx,

and CO lb/hr and lb/ton of Al produced 20 3/Variable b

a Traverse point test data were recorded every 6 minutes during each test run.

b Test run durations varied with production cycles. See summary of result tables for specific test durations

.



### 3. 3 DILUENT GAS ANALYSIS

Exhaust gas concentrations of oxygen and carbon
dioxide were confirmed using a Fyrite apparatus.
These data

, along with the moisture content and velocity data, were used to relate pollutant concentrations to mass emission rates (lb/hr).



### 3. 4 MOISTURE CONTENT

Moisture c ontent during each test run was quantified utilizing procedures identified in US EPA RM 4 in conjunction with each isokinetic test run. A sample of gas was continuously collected using a dry gas meter stack sampling system and condensed in a series of impin gers. The moisture content of the gas was measured as a change in the volume of the water collected in each impinger and the increased weight of the dessicant during each test run. 

### 3. 5 PM/HCL EMISSIONS

PM and HCl samples were withdrawn isokinetically
from the exhaust stack using an US EPA RM 5/26A sampling train. The sample train consisted of a
Teflon ® coated stainless steel nozzle, a heated glass

lined probe, heated filter, six chilled impingers, and a metering console. Each PM sample was collected on a Qua rtz fiber filter maintained at a temperature above

248 **°** F. The first impinger contained 50 milliliters (ml)
of 0.1N sulfuric acid while the second and third impingers contained 100 milliliters (ml) each of 0.1N sulfuric acid. The fourth and fifth impingers contained 100 ml each of 0.1N sodium hydroxide. The sixth impinger contained a known weight of indicating type silica gel. Sampling was conducted isokinetically with readings of the flue gas parameters recorded at every sampling point during the traverse. Sampling was conducted at twenty sampling points (ten points on each diameter) for at least 18 minutes per point.SOURCE EMISSION TEST ING OF FURNACE 31

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- Hol \ Docs \ Reports \ Furnace 31_ReportR1.docx At the completion of each test run the filter was removed from its filter housing, placed in a petri dish, and labeled as sample container #1. The nozzle, probe, and front half of the filter housing were
brushed and rinsed a minimum of three times with acetone and labeled as sample container # 2. The PM samples were analyzed gravimetrically in accordance with the procedures outlined in US EPA RM 5.

Sample recovery of the impinger train consisted of measuring the volume of liquid in impingers one through five. The contents of the first three impingers were placed in container #3. The back half of the filter holder and the first three impingers were rinsed with deionized water and placed in container #3. The contents of impingers four and five were discarded. The contents of container #3 were analyzed for HCl using ion chromatography (IC) procedures. The contents of the fifth impinger (indicating silica gel) were placed into its original container and re

weighed.

PM/HCl samples were delivered under chain of custody to Maxxam Analytics of Burlington, Ontario for analysis.



### 3. 6 NOX AND CO EMISSIONS

Emissions of NO
x and CO were evaluated in accordance with USEPA RMs 7E and 10, respectively. A continuous gas sample was extracted from the exhaust stack at a single point through a sintered filter, stainless steel probe, heated Teflon ® line and through a conditioning sys tem used to remove moisture from the gas stream. All material that came in contact with the sample was constructed of either stainless steel, glass, or Teflon ®

.

NOx and CO a nalyzer outputs were monitored using a laptop computer and PCMCIA card and recorded every two seconds by a data acquisition system (DAS). The DAS reported emissions data as 1

- minute averages for each test run. Pollutant emissions data reported by the DAS was corrected for system zero and span bias.



### 3. 7 PCDD/DF TEST METHOD

PCDD/DF emissio ns testing was conducted following procedures outlined in USEPA R M 23 procedures

. The sample train consisted of a heat

- traced probe with a borosilicate buttonhook nozzle, and an attached thermocouple and Type

- S pitot tube. The glass probe was maintained a t a temperature of 250 o F

**±** 25 o F. After the probe, the gas passed through a heated glass fiber filter. Downstream of the heated filter, the sample gas passed through a water

- cooled module, then through a sorbent module containing the XAD

- 2
sorbent resin. The XAD module, which was kept at a temperature below 20 o C, was followed by a series of four impingers. The XAD inlet temperature was monitored to ensure that the proper temperature was
maintained.

The first impinger, which acted as a condensate

reservo ir, was connected to the outlet of the XAD
module and was modified with a short stem so that the sample gas will not bubble through the collected condensate. The first and third impingers were each empty. The second impinger contained 100 mls of
HPLC Grad e or better water and the fourth impinger contained a pre

- weighed amount of silica gel. All connections within the sample train were either glass or Teflon; no sealant greases was used. The impingers were followed by a pump, dry gas meter,
and a calibrat ed orifice meter.

Sampling was conducted isokinetically with readings of the flue gas parameters recorded at every sampling point during the traverse. Sampling was conducted at
twenty sampling points ( ten points o n each diameter)
for at least 18 minutes pe r point to ensure that a minimum of 3 cubic meters (106 ft 3 ) was collected during each test run.

Prior to sampling all sample train glassware w as prepared in accordance with Section 3A of the Manual of Analytical Methods for Analysis of Pesticide
Residue s in Human and Environmental Samples. Prior to use all glassware w as rinsed acetone, hexane and methylene chloride.

Leak checks on the sampling train w as conducted at
before and after each test run. A mid test leak check

w as a lso conducted upon moving the sample train to each sample port. The sample train leak checks and leakage rates w ere documented on the field test data sheet for each respective run.

Sample Recovery

Following completion of each test run the USEPA RM
23 sample train was transported to a recovery area

on

- site. The recovery procedures for the sample train
was as follows:

1. At the end of sampling, remove probe from the stack and cap the nozzle. Allow the train to cool briefly.SOURCE EMISSION TEST ING OF FURNACE 31

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<0.02 cfm.

3. The sample probe, nozzle and front

- half of the
filter holder w as brushed and rinsed three times each with acetone (Container #1). Following the acetone rinse all components w ere rinsed three times with toluene and placed in Con tainer #1.

4. Disassemble the filter housing and transfer the filter to its original glass petri dish with hexane rinsed forceps (Container #2). Transfer any particulate matter and filter fibers, which adhere to the filter holder and gasket to the petri dish also. Seal the container with Teflon tape and label it with the appropriate sample information.
5. The XAD module was removed from the train and was sealed immediately (Container #3). The trap
was covered in aluminum foil to minimize the exposure to light and was kept cold until the time of analysis

6. Measure the contents of the first impinger. Rinse
the back

- half filter housing, connecting line
between filter holder and XAD condenser and the first impinger itself three times with acetone, followed by three r inses with toluene into the same container (#4). Note the XAD condenser
was soaked a minimum of 5 minutes with toluene as part of the recovery process.

7. Measure the volume of water in the first and second impinger for moisture determinations and place in Co ntainer #5. Rinse the impingers and connecting glassware three times each with acetone and toluene and place in Container #5.

8. Place the contents of the fourth impinger into its original container and reweigh to obtain net moisture weight gain (Container #7 ) to the

nearest **±** 0.5 g.

9. All containers were checked to ensure they are sealed, labeled and all liquid levels are marked. All samples were logged onto the chain

- of

custody form. The samples remained chilled until analysis. Analysis were conducted using h igh resolution mass spectrometry (HR/MS). PCDD/DF samples were delivered to SGS Analytical Perspectives of Wilmington, North Carolina for analysis.



### 3. 7 .1 PCCD / DF QA/QC Procedures

Field Blank Train - Field bias blanks and reagent
blanks w ere collected at the conclusion of the sampling program. The field bias blank consist ed of preparing a Method 23 train identical to the ones to be used for sampling. The train w as leak checked on
the stack and then was recovered following S teps 1 through 8 above

. Spiked Sam pling Trains - Each XAD module was spiked
with known amounts of labeled internal standards in accordance with specified method procedures . Acceptable recovery of these standards is between 60 percent and 120 percent of the known value.

Laboratory Method Blank – A sample of the resin used to charge the XAD module was analyzed in the same manner as the field samples. The laboratory method blank was also spiked with known amounts of labeled internal standards. The laboratory method blank
must not exceed the practical quantitation limit (PQL) or contain more than 5 percent of the analyte concentrations found in the field samples.

Laboratory Control Sample – The laboratory prepared spiking solutions from stock standards independent
from the standards used for i nstrument calibration. Resin samples were spiked with these solutions and analyzed in the same manner as the samples to demonstrate the ability to generate acceptable test data. Acceptable accuracy of the laboratory control samples is 50 percent to 150 per cent recovery. Note that no USEPA audit sample or analysis were collected or analyzed as part of this testing.SOURCE EMISSION TEST ING OF FURNACE 31

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### 4. RESULTS, DISCUSS IONS AND CONCLUSIONS

The results of the test program are presented in
Table s 1 through 3 . The following section briefly
discusses the results. Field data sheets and emission calculations are presented in Appendix C. Laboratory data is presented in Appendix D.



### 4.1 PM /HCL TEST RESULTS (TABLE 1)

As can be seen in Table 1, filterable PM
concentrations from Furnace 31 were somewhat
variable ranging from 0.0034 to 0.0061 grains per dry
standard cubic foot (gr/dscf), and averaging 0.0051 gr/dscf. Corresponding mass emission rates normalized to aluminum production ranged from

0 .151 to .394 pounds of PM per ton of aluminum produced (lb PM/ton al uminum) . A verage normalized

emissions were approximately 0. 277 lb PM/ton of
aluminum or approximately 69.3 percent of the

S econdary Aluminum MACT limit of 0.4 lb PM/ton of
aluminum.

HCl concentrations ranged from 3.8 milligrams per dry standard cubic meter (mg/dscm) to 7.4 mg/dscm, averaging 6.1 mg/dscm. Corresponding normalized emission rates ranged from 0.07 to 0.22 lb HCl/ton of
aluminum . A verag e normalized HCl emissions were approximately 0.15 lb HCl/ton of alumin um or approximately 36.2 percent of the S econdary
Aluminum MACT limit of 0.4 lb HCl/ton Al.



### 4.2 PCDD/DF EMISSION RES ULTS (TABLE 2)

PCDD/DF emission results outlined in Table 2
indicate that PCDD/DF concentrations in the Furnace

31 exhaust were considerably lower during Run 1, approximately 50 percent lower than during Runs 2 and 3. PCDD/DF TEQ concentrations ranged from 2.92E

- 06 micrograms per dry standard cubic foot (ug/dscf) to 8.17E

- 06 ug/dscf and averaged 5.84E

- 06 ug/dscf. Corresponding mass emission ra tes normaliz ed to production ranged from 1.00 to 3.14 ug TEQ/Mg of aluminum and averaged 2.31 ug TEQ/Mg
of aluminum. T he average of the three test runs is approximately 15.4 percent of the Secondary Aluminum MACT limit of 15 ug TEQ PCDD/PCDF/Mg
of aluminu m.



### 4.3 NOX AND CO TEST RESULTS (TABLE 3)

As can be seen in Table 3, NOx concentrations ranged from 4.2 to 5.6 ppm, and averaged 5.0 ppm. Corresponding NOx mass emissions averaged 0.96 lb/hr. CO concentrations were slightly higher, with concentrations ranging from 13.4 to 28.3 ppm. CO mass emission rates averaged 2.2 lb/hr during the
three test runs conducted.

NOx emissions normalized to furnace heat input ranged from 0.03 to 0.04 pounds per million BTU (lb/MMBtu) and averaged 0.03 lb/MMBtu.
Normalized CO e missions ranged from 0.05 to 0.11 lb/MMBtu and averaged 0.07 lb/MMBtu for the three
test runs conducted.



### 4. 4 CONCLUSIONS

Except as noted, all testing proceeded smoothly with no process operating or sampling problems encountered. Sample train leak checks were within specified parameters and isokinetic sampling rates were within specified criteria (90 to 110 percent) during all three isokinetic test runs conducted

. HCl sample audit results were within specified criteria (See Section 5.6 for details)SOURCE EMISSION TEST ING OF FURNACE 31

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### 5. QUALITY ASSURANCE/QU ALITY CONTROL

QA/QC was based on the recommended QA/QC procedures of the various sampling and analytical methods that were used for the compliance test. The sampling equipmen t calibration documentation are provided in Appendix E. This section summarizes the pertinent QA/QC procedures that were employed during the emissions testing program.



### 5.1 EQUIPMENT CALIBR ATION

Calibration of equipment was conducted in
accordance with the procedures outlined in the USEPA document entitled "Quality Assurance Handbook for Air Pollution Measurement Systems;
Volume III

— Stationary Source Specific Methods" (EPA

- 600/4

- 77

- 027b). Equipment calibration was performed in accordance with USEPA guideline s and/or manufacturer’s recommendations. Documentation of all calibrations is presented in Appendix D. Examples of field equipment used and typical calibration requirements follows:



###  Probe nozzles (QA Handbook Section 3.4.2, pg. 19)

- make three measurement s of the nozzle ID (to the nearest 0.001 in.) using different diameters with a micrometer. Difference between the high
and low values should not exceed 0.004 in. Post

test check - inspect for damage.



###  Pitot tubes (QA Handbook Section 3.1.2, pp. 1

- 13) -

meas ured for appropriate spacing and dimensions or calibrate in a wind tunnel. Rejection criteria given on the calibration sheet. Post

- test check - inspect for damage.



###  Thermocouples (QA Handbook Section 3.4.2, pp.
15

- 18) - verify against a mercury

- in

- glass
the rmometer at two or more points including the anticipated measurement range. Acceptance limits

- impinger ±2°F; DGM ±5.4°F; stack ±1.5 percent of stack temperature



###  Dry gas meters (QA Handbook Section 3.4.2, pp. 1

- 12) - Dry gas meters are calibrated using cr itical orifices. The procedure entails four runs using four separate critical orifices running at an actual

vacuum 1

- 2 in. greater than the theoretical critical vacuum. The minimum sample volume required per orifice is 5 ft 3 . Meter boxes are calibrated

ann ually and then verified by use of the alternative Method 5 post

- test calibration procedure. This procedure is referenced as Approved Alternate
Method ALT

- 009 (June 21, 1994) by EPA’s Emission Measurement Center. The average Y

value obtained by this method must be within 5%
of the initial Y

- value.



###  Field barometer (QA Handbook Section 3.4.2, pp.

18

- 19) - compare against a mercury

- in

- glass barometer or use Airport Station BP and correct for elevation. Acceptance criteria - ± 0.02 in. Hg;
post

- test check - same

. 

### 5.2 LABORATORY QA/QC PROCEDURES

Laboratory analysis utilizes a number of different types of QA/QC checks to document the validity of the generated data. Internal QA/QC procedures were conducted by the laboratory in accordance with individual method requ irements. These specifications include the types of QA/QC checks required, the frequency of each check, and the QA/QC acceptance
criteria for these checks.

The laboratory documents that both initial and ongoing instrument and analytical functions have
been met. Sample analyses did not proceed unless these calibration requirements were met.



### 5. 3 NOX AND C O S AMPLING

As discussed in Section 3 , NO x and CO concentrations

w ere measured on

- site with real

- time instrumental gas analyzers . These analyzers w ere calibrated on

- site
with US EPA Protocol 1 reference gas standards.

C alibration error and system bias were evaluat ed each testing test day in accordance with US EPA method procedures. Zero and span drift w ere evaluated approximately every two hours during ea ch test run. Calibration gas certificates for the calibration gases used can be found in Appendix E

.



### 5.4 LEAK CHECKS

Pitot tube leak checks were conducted in accordance
with US EPA RM 2. Leak checks were conducted on the
isokinetic sampling train s prior to and following each

test run in accordance with procedures specified in
each test method

.



### 5.5 CHAIN OF CUSTODY DOC UMENTATION

Chain of custody forms were completed for samples
delivered to the laborator ies . Copies of the completed
chain

- of

- custody forms are included with the laboratory reports (Appendix D).SOURCE EMISSION TEST ING OF FURNACE 31

8 | FINAL : SEPTEMBER 19 , 2013

I: \ Alcoa.11423 \ 50930.No31

- Melter

- Hol \ Docs \ Reports \ Furnace 31_ReportR1.docx 

### 5. 6 BLANK AND A UDIT SAMPLES

Field blanks were collected for each sample train in accordance with specified method procedures. A field
blank of the acetone used to recover the US EPA RM 5 sample train was a nalyzed to determine sample
contamination. The results of the blank were used to adjust field sample results in accordance with the method. The blank correction weight for the acetone used does not exceed 0.001 percent of the weight of the acetone blank, a s described in Section 12.8 of EPA
RM 5.

Reagent and sorbent blanks for the USEPA RM 26A and RM 23 trains were also collected as part of the of the field test program. In accordance with the USEPA Stationary Source Audit Sample Program (SSASP) a single HCl audit sample was procured from an accredited audit sample provider and analyzed in conjunction with the field samples. The audit s ample was obtained from ERA of
Golden , Colorado. Results of this audit were within specified audit analysis criteria. The ERA audit analytical results can be found in Appendix D.



### 5. 7 TEST DATA AND REPORT REVIEW

Test data input and emission calculations were
double

- chec ked for accuracy. The test results were reviewed by senior personnel for reasonableness and accuracy. The final report was peer reviewed by senior personnel and certified by the project

manager.TABLES

More than Engineering Solutions1 of 1 | FINAL: 9/10/2013

I:\Alcoa.11423\50930.No31-Melter-Hol\N-D\Furnace 31 PM-HCl.xlsx\Summary Table 

### Run Identification **Run 1 Run 2**  **Run 3 Average**  **Percent of**

**Standard a,b** 



### Run Date 05Aug13 06Aug13 06Aug13 Start/Stop Time 2300-1257 1427-2305 2358-1219 Test Duration (min) 788 514 712

Production Data Aluminum production (total tons) 67.8 44.5 42.6 51.6 Aluminum production (tons/hr) 5.16 5.20 3.59 4.65 Chlorine addition (lb/ton of Aluminum) 0.52 0.79 0.82 0.71

Exhaust Gas Conditions Temperature (deg. F) 398 443 412 418 Moisture (volume %) 3.4 3.4 3.0 3.3 Oxygen (dry volume %) 20.9 20.9 20.9 20.9 Carbon Dioxide (dry volume %) 0.0 0.0 0.0 0.0

Volumetric Flow Rate

acfm 47,472 47,751 47,194 47,472
dscfm 28,206 27,040 27,834 27,693

Filterable Particulate Matter gr/dscf 0.0061 0.0034 0.0059 0.0051 lb/hr 1.48 0.79 1.41 1.23 lb PM/ton of aluminum 0.286 0.151 0.394 0.277 **69.3**
HCl mg/dscm 7.1 3.79 7.40 6.11 lb/hr 0.75 0.38 0.77 0.64 lb HCl/ton of aluminum 0.146 0.074 0.215 0.145 **36.2**

a 

### PM standard is 0.4 lb/PM/ton Al

b 

### HCl standard is 0.4 lb HCl/ton of Aluminum 

### Massena, New York **Table 1 Summary of Particulate and HCl Emission Results** 

**Furnace 31 Exhaust**

**Alcoa West**1 of 1 | FINAL: 9/10/2013

I:\Alcoa.11423\50930.No31-Melter-Hol\N-D\particulate-0030Alcoa.xlsx\Summary Table 

### Run Identification **Run 1 Run 2**  **Run 3 Average**  **Percent of**

**Standard a** 



### Run Date 05Aug13 06Aug13 06Aug13 Start/Stop Time 2300-1257 1427-2305 2358-1219 Run Duration (min.) 788 514 712

Production Data Aluminum production (total tons) 67.8 44.5 42.6 51.6 Aluminum production (tons/hr) 5.16 5.20 3.59 4.65 Aluminum production (Mg/hr) 4.69 4.72 3.26 4.22 Chlorine addition (lb/ton of Aluminum) 0.52 0.79 0.82 0.71

Exhaust Gas Conditions Temperature (deg. F) 406 423 398 409 Moisture (volume %) 3.2 3.3 2.7 3.1 Oxygen (dry volume %) 20.9 20.9 20.9 20.9 Carbon Dioxide (dry volume %) 0.0 0.0 0.0 0.0

Sample Data Sample Volume (dscf) 465.3 294.9 423.1 394.4 Volumetric Flow Rate (acfm) 45,364 46,274 44,170 45,270 Volumetric Flow Rate (dscfm) 26,748 26,829 26,578 26,719

Dioxin/Furan Results
PCDD/DF TEQ (pg) b 

### 1360 2410 2720 2163 PCDD/DF TEQ (ug) 0.0014 0.0024 0.0027 0.0022 PCDD/DF TEQ (ug/dscf) 2.92E-06 8.17E-06 6.43E-06 5.84E-06 PCDD/DF TEQ emission rate (ug/hr) 4.7 13.2 10.3 9.4 PCDD/DF emission rate (ug TEQ/Mg of Al) 1.00 2.79 3.14 2.31 **15.4**

a 

### PCDD/DF emission limit is 15 ug TEQ/Mg Al

b 

### ITEF TEQ factors used in TEQ calculation. 

### Table 2 **Summary of PCDD/PCDF Emission Results**

**Furnace 31 Exhaust**

**Alcoa - West Plant Massena, New York** 1 of 1 | FINAL: 9/19/2013

I:\Alcoa.11423\50930.No31-Melter-Hol\N-D\Furnace 31 CEMS.xlsx\Summary Table 

### Table 3 **Summary of Nitrogen Oxide and Carbon Monoxide Emission Results**

**Furnace 31 Exhaust**

**Alcoa - West Plant**

**Massena, New York**

**Run Identification Run 1**  **Run 2 Run 3**  **Average**

Run Date 05Aug13 06Aug13 06Aug13 Start/Stop Time 2300-1257 1427-2305 2358-1219 Run Duration (min.) 788 514 712

Production Data Aluminum production (total tons) 67.8 44.5 42.6 51.6 Aluminum production (tons/hr) 5.16 5.20 3.59 4.65 Aluminum production (Mg/hr) 4.69 4.72 3.26 4.22 Chlorine addition (lb/ton of Aluminum) 0.52 0.79 0.82 0.71 Average Furnace Natural Gas Flowrate (scfh) 28,762 28,762 28,762 28,762 Furnace Heat Input (MMBtu/hr) a 29.6 29.6 29.6 29.6

Exhaust Gas Conditions Temperature (deg. F) 406 423 398 409 Moisture (volume %) 3.2 3.3 2.7 3.1 Oxygen (dry volume %) 20.90 20.90 20.90 20.90 Carbon Dioxide (dry volume %) 0.00 0.00 0.00 0.00

Volumetric Flow Rate

acfm 45,364 46,274 44,170 45,270

dscfm 26,748 26,829 26,578 26,719

Carbon Monoxide ppm, dry 13.4 13.9 28.3 18.5 lb/hr 1.6 1.6 3.3 2.2 lb/MMBtu 0.05 0.06 0.11 0.07

Nitrogen Oxide ppm, dry 4.2 5.3 5.6 5.0 lb/hr 0.81 1.02 1.07 0.96 lb/MMBtu 0.03 0.03 0.04 0.03

a Heat content of natural gas used in furnace heat input calculation is 1,028 BTU/scf.APPENDIX A

360° Engineering and Project Delivery Solutions 

# Facility Operating DataAPPENDIX B

360° Engineering and Project Delivery Solutions 

# Schematic of the

Test LocationAPPENDIX C

360° Engineering and Project Delivery Solutions 

# Field Data and CalculationsAPPENDIX D

360° Engineering and Project Delivery Solutions 

# Laboratory DataAPPENDIX E

360° Engineering and Project Delivery Solutions 

# Equipment Calibration Data Equipment Calibration Data

# 360° Engineering and Project Delivery Solutions

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