lBISON

.t:ERING. INC.

June 19, 2008

Callie Videtich

Air Quality Planning and Management Unit

US EPA - Region 8

1595 Wynkoop Street

Denver, CO 80202-1129

REDACTED

Dear Ms. Videtich:

RE: CFAC BART Analysis - Response to EPA Comments - REVISED

Columbia Falls Aluminum Company (CFAC) is re-submitting the response to comments

from your letter dated February 12, 2008. As explained to Laurel Dygowski verbally and

bye-mail, an error was found in CFAC's BART analysis modeling that supported

CFAC's April 14, 2008, BART submittal to EPA. CFAC inadvertently provided Bison

Engineering, Inc. (Bison), CFAC's consultant, with an incorrect stack diameter and an

incorrect stack height for the A398 dry alumina scrubbers. The following table shows the

revised model inputs:

SpecIfic velocIty depends on mdlVldual scrubber

Stack Height Stack Exit Velocity* Version Diameter (feet) (inchesl (feeUsec)

Previous 92 24 56-63

Corrected 111 38 66 - 75 .

CFAC has provided a drawing of an alumina scrubber stack as documentation of the

proper stack parameters (Attachment K).

Bison has corrected the error and fe-run the visibility models. As a result of the revised

models, Bison has revised the April 14, 2008, submittal package. The enclosed

package includes newly updated CALPUFF model results for all of the various

scenarios analyzed for BART. This revision dated June 18, 2008, only changes the

CALPUFF model results, deciview impacts and costs in dollars per deciview. This

revision does not change any other information or data used in the BART analysis.

Because the overall deciview impacts for the existing plant and most of the control

options were reduced, the costs of control per deciview generally are higher in this

revised submittal. CFAC believes this only further emphasizes the conclusion of CFAC's
BART analysis, that all of the examined control strategies are cost-prohibitive, and none

was selected as BART.

The remainder of this submittal is a revised response by CFAC to your letter dated

February 12, 2008, requesting more information. On behalf of GFAG, Bison is pleased

to submit responses to your questions. We have copied EPA's comments from your

letter (numbered and in small type), and furnished CFAG's responses in larger type_

The responses are contained in Attachment A to this letter. Detailed information

referenced in our responses is contained in other attachments, as follows:

Attachment A - Responses to EPA Comments

Attachment B - Single Alkali Scrubber Cost Analysis - CONFIDENTIAL

Attachment C - Dual Alkali Scrubber Cost Analysis - CONFIDENTIAL

Attachment 0 - Spray Dry Absorber (SDA) Cost Analysis - CONFIDENTIAL

Attachment E - Spray Room Scrubber Cost Analysis - CONFIDENTIAL

Attachment F - Fabric Filter Baghouse Cost Analysis - CONFIDENTIAL

Attachment G - Emissions Calculation Spreadsheets

Attachment H - Summary of S02 Control Investigation

Attachment I - Sumitomo Process Conversion Letter

Attachment J - Roof Vent Flowrate Data

Attachment K - Drawing of A398 Scrubber and Stack

Please note that the revisions solely affect the contents of the tables presented in

Appendix A, and the addition of Attachment K. The contents of the other attachments

are unchanged.

CFAC requests that the cost information in the analyses contained in

Attachments B through F be treated as CONFIDENTIAL business information and

not be distributed to the public or published on the Region VIII website.

Please let us know if you have any questions on our responses. I can be reached at

406-442-5768, or Steve Wright (CFAC) can be reached at 406-892-8211.

Sincerely,

BISON ENGINEERING, INC

1kJ /)~

Harold W. Robbins

President

cc: Steve Wright - CFAC

John Parker - PI CO

Attachments
Attachment A

EI'A COllllllent #1

General Comments

1. The CFAC BART analysis uses the 5th edition of the <'EPA Air Pollution Corurol COS1

M<:nuaJ" instead of the 6th edition. CFAe needs [0 redo lhe BA.R.T ancly~is using the 6.h

edition of"EPA's Air Pollution CooLroI Cost Manual" ("EPA Air Pollution Control Cost

Manual", SiXth edition, EPA-452-Q2-QO]. January 200.2).

CFAC Response

In response to the EPA request that CFAC "redo the BART analysis using the 6'h edition

of the EPA's "Air Pollution Control Cost Manual," we have studied the sections related

to this BART study and conclude that there are some minor version-to-version

differences attributed to "the necessary revisions, updates, and expansions of each of

these chap/ers," alluded to on page 1.5 of Version 6 of the manual.I (Incorporation of

these changes does not change the conclusions previously reached.)

These changes are of two types:

• Adjustments to the coefficients or "factors" applied to base costs to account for

"foundations, piping, etc."; and

• Changes to some of the cost algorithms for estimating pumps, blowers, etc.

We have re-estimated the capital costs and annual costs of the various controls and,

where appropriate, substituted the Version 6 values. in the process of reviewing the

cost tables, a small number of other corrections, additions, or deletions have also been

made which effected minor changes (plus and minus) to the overall costs. The effects

of these changes are generally categorized in Table 1 below.

Table 1: 2008 Update Effeets on Detailed Cost Analyses

Changes to Detailed Cost Estimates Cost 1m act (+1-)

Chemical and freiQht cost increases: lime u 80%, NaOH up 66% Laroe Plus

Calcium Chloride was removed from both orimarv S02 scrubber svstems Neqliqible

Cost coefficients increased per EPA Cost Manual version chanQe from 5 to 6 Plus

Decreased operator/maintenance cost oer EPA comments Minus

Site oreelbuildina costs inadvertently omitted in 11/5/07 report Small Plus

Removed 3% sales tax coefficient inadvertently aeelied in 11/5/07 Lar e MinUS

More detailed electrical power cost analYSIS Net Zero

More detailed water cost analysis Small Plus

Applied a 15 year 'IS 10 year capital recovery factor Minus

1 EPA Air Pollution Control Cost Manual, Version 6, Section 1-3, page 1-5.

Attachment A Page 1
In no case did we determine that any of these changes altered the conclusions of the

study.

The revised cost tables and associated detail are attached to this response as follows

(note that the Spray Dry Absorber was newly added in this response, and did not

appear in the November 11, 2007 BART report):

Attachment B - Single Alkali Scrubber Cost Analysis

Attachment C - Dual Alkali Scrubber Cost Analysis

Attachment D - Spray Dry Absorber (SDA) Cost Analysis

Attachment E - Spray Room Scrubber Cost Analysis

Attachment F - Fabric Filter Baghouse Cost Analysis

EPA Comment #2

2. On page 4-33 ofthe analysis it stat::s "Any requirement to implemeot any ofthe pollution

control strategies described in this document will greatly increase CFAC's operating cost

and probably result in tbe shutdown ofthe facility." The B.4R.T Guidelines provide that

"There may be unusual circumStances that justify taking into consideration the conditions

of the plant and the economic effects or requiTing the use of a given control tcdmo!ogy.

These effects wouid include effects on pToduc~ prices, the marlce~ share, and profitability

ofthe source. Wbere tiere are such unusual circumstances Ll-tat arc judged to affect plant

operations, you may take into consideration the conditions of the pla.'11 and the economic

effects ofr~quiring me use of a control technology. Where these efte..."'1.S ar~ judged to

ha....e a severe impeact on plant operations you may consider them in the selection process,

but you may \\'ish to provide an economlc analysis that demonstrates, in su..:.t'ficient detail

for public review, t'f1e specific cconomic effects, parameters, and reasoning. (\Ve

recognize that this review process must preserve tbe confidentiality ofsensitive business

information)" (see 70 FR 39171, July 6, 2005). CFAC Deeds (0 include adetailed

economic and fimmcial analysis for th~i.r facility thGt provides information on how

additional controls would result in the shutdown ofthe facility. The a!'.alysis !leeds to

encompass all BART contra] measures and their associated costs that are part of the

revised BART analysis.

CFAC Response

Although CFAC still believes the original statement to be true, CFAC would like to

withdraw this comment at this time. CFAC believes the original BART submittal, and the

supplemental information in this submittal, show that there is no add-on technology

available to CFAC that meets the definition of BART. Therefore, no further analysis of

CFAC's financial ability to afford any of these technologies has been provided.

Attachment A Page 2
EPA Comment #3

3. CPAC needs to provide the following information as part ofibc revised B.A.RT a.'1alysis:

Tbe source oftbe emissions data used in the analysis (e.g., source testing,

em!ssions monitorir~g equipment, emission factors, other).

Information on what operational data the emLssions provided in Tables 3-4 and 3-

5 ~e based upon. It appears that there are based on 24 hours/day, 365 days a year

operation ofthe facility.

Operational data. iDcludLl.g: bur not limited to, actual emissions aTld typical

operating parameters in hom'S/day a!ld days/year.

The t}'pice.l annual output in Ions/year of aluminum.

Additional documentation on ho\.',' the estimaicd capital equipment cost for the

dual and single alkali 5crubbcrs was calculated (e.g., cost model and inputs used

to dctcrmine costs, or Cl.uotes from vendors, ctc.).

Addiriona[ documentation on how the value for annualized costs for coke sulfur

content reduction was calculated.

Docmnentadon ofthe operating mmerials coscs (e.g., NaOH, Ca(OH)2, and

CaCl/floculant).

CFAC Response

Source of Emissions Data - Emissions estimates have been used for the preparation

of the BART analysis. CFAC is not required to perform stack testing for the pollutants

analyzed for BART. CFAC does not have actual emissions data available for the

sources. A spreadsheet containing the emissions data used in the BART analysis is

provided in the tables in Attachment G. The tables included are:

Table 3a: Sulfur Dioxide Emission Factor Calculation

Table 3b: Sulfur Dioxide Emission Inventory

Table 3c: PM10 Emission Inventory

Table 3d: NOx Emission Inventory

Background information regarding these spreadsheets is prOVided below:

In 2005, the Montana Department of Environmental Quality (MDEQ) requested

emission rates based on the highest daily aluminum production rate. At the time of

MDEQ's request, CFAC was only operating one potline of production. For the purposes

of the BART analysis, it was agreed that CFAC should provide emission data based on

1999 production, which was the most recent year when all three BART-eligible potlines

were operating.

CFAC reviewed production data for 1999 and found the highest daily production rate

occurred on February 3, 1999. The production value for this day was 323 tons of

aluminum/day.

Attachment A Page 3
As seen in Table 3a, Sulfur Dioxide Emission Factor Calculation, an S02 emission factor

was calculated by CFAC based on the percent sulfur in the petroleum coke and coal tar

pitch raw materials, and assuming all of the sulfur was emitted from the facility in the

form of SO,.

As can be seen in Table 3b, PM 10 emissions are calculated based on emission factors

from the MDEQ AIRS / annual emission inventory and the aluminum production value

for February 3,1999.

The NOx emission calculations in Table 3d are based on the estimated natural gas use

on February 3, 1999 and the MDEQ AIRS / annual emission inventory emission factor.

Operational Data: The emission estimates are based on CFAC's operations and the

nature of the aluminum electro-reduction process. The emissions estimates are based

on operation of potlines 3, 4 and 5, 24 hours a day, 365 days/year.

Typical Annual Aluminum Output - The annual output of aluminum in tons/year from

the three BART-eligible potlines (3, 4 and 5) varies somewhat year to year. Below are

the production numbers for the years 1997, 1998 and 1999 for these three potlines.

CFAC considers these production rates as typical for these potJines.

Year

1997

1998

1999

Tons of Aluminum Produced

114,041

113,098

112,584

Documentation of Estimated Capital Costs - Detailed analyses and cost estimates

for the dual and single alkali scrubbers have been provided in Attachments Band C. In

addition, updated cost estimates have been provided for a Spray Dry Absorber, Spray

Room Scrubber and Fabric Filter Baghouses in Attachments D, E and F, respectively.

Coke Annualized Costs - In CFAC's original BART analysis (page 4-12), the cost of

switching from a 1 5% sulfur coke to a 0.75% sulfur coke was estimated to be

$7,079,680/year based on 1999 usage of petroleum coke for potlines 3, 4 and 5 (the

BART-eligible potlines). The incremental increased cost of the 0.75% sulfur coke over

CFAC's current coke cost was estimated at $160/ton of coke consumed. Potlines 3, 4

and 5 combined used 44,248 tons of coke in 1999. The $160/ton of coke cost increase

was based on verbal discussions with coke vendors in October, 2007.

Documentation of Operating Materials Costs -

On March 28, 2008, CFAC obtained fresh quotes for the SO, scrubber operating

materials from Hawkins, Inc., an industrial chemical supplier based in Minneapolis.

50% Caustic Soda (NaOH): $584/ton (dry basis) (rail tank cars, FOB Minneapolis)

Hydrated (slaked) Lime [Ca(OHh]: $231/ton (40 ton truckloads, FOB Columbia Falls)

Calcium Chloride (CaCI,): $652/ton (truckload FOB Columbia Falls)

Attachment A Page 4
The price quotes for the original November 2007 BART report were from ICIS Pricing

and Index Mondi, international chemical pricing services. They were increasing daily

but were in the range:

50% Caustic Soda (NaOH): $360/ton (FOB Gulf/Houston)

Hydrated (slaked) Lime [Ca(OH),): $150/ton (FOB Columbia Falls)

EPA Comment #4

4. On page 4-2 oft.i:lc a."1alvsis, CFAC st<l.tes that :une units ere not included in the :~.llalvsis

because they h:J.\'e very "low emission rates. These nine unilS, blcluding the alumina"

elevator, unloader, conveyor storage, oU heating S)'ste!Il, transfer pointS, c2Sting furnace

and pit and. sheet ingot saw, ha,'e combined PMIO emissions of 4.81 Ibs/hour or 21

tons/year. According to the BA.RT Guidelines, lOIn order ro simplify BART

determinations, States may choose 10 identify de minimis levels ofpollutants at BARTeligible sour<::es (bet are not required 1.0 do so). De minimis values should be identified

""ith the purpose ofexcluding only those emissions so rnini..m:zJ that Lhey are tmlikely to

contribute to regional haze. An)' de minimis values t.l)ar you adopt must not be higher

than the PSD applicability levels: 40 tons/yr for 802 and NOX and 15 tonsJyr for PMI O.

These de minirt"js levels may only be applied on a plant-\vicie basis1l (sec 70 FR 39161.

July S. 2006). CFAC exceeds the suggested de minimis lcvcl for PMJO in the BART

Guidelines and l.f}US all BA.T{T eligible units at the facility need to be included in the

BART analysis.

CFAC Response

CFAC understands that the total annual emissions from nine sources of PM,o emissions

are greater than the de minimis threshold of 15 tons per year. In the original submittal,

CFAC stated that, "The other nine units have very low emission rates and were not

analyzed for BART by CFAC." To expand upon this statement, CFAC has followed the

guidance in 40 CFR 51 Appendix Y, Section III, as quoted below. Please note the

underlined section.

III. How To Identify Sources "Subject to BARr'

Once you have compiled your list of BART-eligible sources, you need to determine

whether (1) to make BART determinations for all of them or (2) to consider exempting

some of them from BART because they may not reasonably be anticipated to cause or

contribute to any visibility impairment in a Class I area. If you decide to make BART

determinations for all the BART-eligible sources on your list, you should work with your

regional planning organization (RPO) to show that, collective/y, they cause or contribu/e

to visibility impairment in at least one Class I area. You should then make indIVidual

BART determinations by applying the five statutory factors discussed in Section IV

below.

On the other hand, you also may choose to perform an initial examination to determine

whether a particular BART-eligible source or group of sources causes or con/ributes to

visibility impairment in nearby Class I areas. If your analysis, or information submitted

Attachment A Page 5
by the source, shows that an individual source or group of sources (or certain pollutants

from those sources) is not reasonably anticipated to cause or contribute to any visibility

impairment in a Class I area, then you do not need to make BART determinations for

that source or group of sources (or for certain pollutants from those sources). In such a

case. the source is not "subject to BART" and you do not need to apply the five statutory

factors to make a BART determination. This section of the Guideline discusses severat

approaches that you can use to exempt sources from the BART determination process.

Bison modeled the group of nine PM" sources mentioned above, both at the EPA

supplied emission rates and at a zero pound per hour emission rate. The average

change in deciviews modeled for Glacier National Park was 0.193 deciviews. This delta

deciview result shows the effect of removing these emissions completely; i.e., a 100%

control efficiency. Since any realistic overall control efficiency would be less, this delta

deciview represents the highest possible deciview improvement resulting from the

control of these nine sources. A realistic deciview improvement would also be less. The

deciview improvement result is significantly less than the recommended 0.5 deciview

threshold, where the source or group of sources would be considered to contribute to

visibility impairment. Therefore, Bison concluded that this group of sources "is not

reasonably anticipated to cause or contribute to any visibility impairment in a Class I

area." Following along above, "the source (or group of sources in this case) is not

'subject to BART' and you do not need to apply the five statutory factors to make a

BART determination."

Bison can provide the modeling showing these results upon request.

EPA Comment #5

5. The cost analysis for the coutrol technologies included in the analysis does not cootain the

proper documentation to support the COSts contained in the appendices. The BART

Guidelines state that "Once (he control technology al1ematives and achievable emissions

pedorroance ievels have been identified, you then develop estimates of capital and annual

costs. The basis for eqUipment cost estimates also shouJd be documented, either with duta

supplied by an cquipmem vendor (i.e., budget cst~mates or bids) or by,E referenced source

(such as tbe OAQPS COn/rol COSI Manual, Fifth Edition, February 1996, EPA 453/B.96.

001). In order to rnaintairl and improve consistency, cost estimates should be based on the

OAQPS Control COSI Manual, whe.c possible." (scc 70 FR 39166, July 6,2005), CFAC

needs to provide the proper documentation to support al! of the costs used in the ana!vsis.

Please note that "the "OAQPS Control COSt Manual", Fifth Edition, referenced above~has

been replaced by th~ "EPA Air Pollution Control Cost Menua!", Sixth Edition, January

2002.

CFAC Response

CFAC has attempted to document all cost analyses used but not provided in the original

submittal. Please see the other sections of this attachment for details.

Attachment A Page 6
I~I) A Comment #6

6. CFAC needs 10 include an analysis ofthe controllechJ10Iogies using the most stringent

conrrol efficiency iliat they are capable of achieving. Tne BART Guidelines state that "It

is not our intent to require 2Dalysis of each possible level of efficiency for a control

techoiqu::. as such an analysis would result in .a. large number of options. 1t is important,

however, that in analyzing the technology you take into account the most stringeni:

emission control level that the technology is capable orac}-ojeving. You should consider

recent regulatory decisions and perfoanance d2.t2. (e.g., manufacturer's data, engineering

estimates and the experience of other sources) when identifying an emissions

performance lev:::,] or levels 10 evaluate." (see 70 FR 39166, July 6, 2005). Control

technologies not evaluated "with the most stringent emission control levels resuJts in

inflated ealculated cost eil'cctiven""s velues. CFAC needs 10 redo the analysis for controJ

technologies using the maS! st:riI:!gent cnllssion control level that the technology is

capable of achieving. One e.xample is the analysis for S~. CFAC only estimates a 90%

removal efficiency \...~th additional control technology, but in the EPA COOlrol Cost

Manual, E?A Slates that most absorbers have removal efficiencies in excess of 90%, and

packed tower absorbers have removal efficiencies as high as 99.9% ("EPA Air Pollution

Control Cost ~1anUe.1", Sixth ed., EPA-452-o2-Q01. January 2002. Section 52, Chapter],

pg J-3).

CFAC Response

Theoretical analysis supported by actual reference plant data validates our 90% 802

wet scrubber efficiency assumption as appropriate. We do not believe our S02 control

level of 90% is underestimated.

The scrubbers listed in the EPA Cost Manual (i.e., packed column absorbers) can

remove up to 99% of the SO, from a sufficiently concentrated stream. The absorption

mechanism is driven by a concentration gradient of the absorbed gas between the

scrubbed vapor and the liquid solute. A large majority of the data on SO, scrubbers has

been collected on flue gas streams from coal-fired power plants or sulfide ore

reductions where the SOz concentrations are typically 3-6% or more. A 6% S02

concentration is equivalent to 60,000 ppmv. Removing 99% of this stream still leaves

600 ppm, or approximately double the 300 ppm inlet SO, concentration of an aluminum

primary stream (and 300x Iypical roof emissions.) Even with high liquid/gas ratios (20-

40 gal/1 000 acfm), absorption from these dilute streams will be very slow.

The European Union Document, "Reference Document on Best Available Techniques in

the Non-Ferrous Metallndustries,"z comments on the treatment of dilute streams:

UThe combustion gases add to the overall gas volume and result in a very low

sulfur dioxide content, which is very difficult to remove effectively."

2 European Union "Reference Document on Best Available Techniques In the Non Ferrous Metals

Industries," December 2001, Section 3.1 1 1 1

Attachment A Page 7
Even the hypothetically 95% efficient packed column scrubber example in the EPA Cost

Control Manual' describes an inlet concentration of 1871 ppmv of HCI (a gas with very

high solubility in water).

Both technologies studied most extensively by CFAC, single and dual alkali scrubbers,

use the same primary stage reactor, a fe-circulating NaOH tower. We studied both the

packed column and spray column configurations. The dual alkali stage simply accepts

the outlet stream of the primary stage and precipitates the sulfates as insolubJes. This

secondary reaction has its own efficiency which, although high, is something less than

100%. It is apparent that the efficiency of either system can be no better than that of

the first stage, which, due to the inlet concentrations of only -300 ppmv, we estimate at

90%.

The European Union Document, "Reference Document on Best Available Techniques in

the Non-Ferrous Metal Industries" specifically describes potrine emissions having a

concentration of 50-400 mg/Nm3 prior to wet scrubbing and 5-40 mg/Nm3 after' - a

90% reduction.

In another section, the E.U. Document lists in Table 4.6, Section 4.2.4.2.11, that for

VSS smelters, uncontrolled S02 emissions;; 10-30 kg/metric ton and "wet scrubbed" ;;

1-3.5 kg/metric ton. This corresponds to efficiencies ranging from 88-90%.

VSS operator, Northwest Aluminum (the Dalles, Oregon), collected data from an NaOH

spray column scrubber over a period from 1996-2000 and recorded an average SO,

removal rate of 91%.5

I':PA Comment #7

Modeling

7. The BART analysis contains modeling performed by Bison Engineering. The res.t.lt5

provided in the BART analysis sho'-\' the impact aE Glacier National Park. CFAC needs

to p'ovide the result; ofthe modeling for other Class I areas in the State and report all

maximum impDCCS greater than 0.5 dv for each year.

CFAC Response

Bison had previously completed the modeling for all of the required Class I areas, but

only reported the impacts on Glacier National Park because it is the closest and most

directly impacted. The impacts at all other modeled Class I areas also show maximum

visibility impacts of less than 0.5 deciviews. To be complete, Bison has attached the

results of the modeling on all of the Class I areas. All modeling files can be supplied to

EPA upon request.

3 EPA Cost Manual, 611\ Edition, Section 5 p,1-32,

4 European Union -Reference Document on Best Available Techniques in the Non Ferrous Metals

Industries," December 2001, Section 4.2.1.2.5.

5 NWA S02 analysis data: attached.

Attachment A Page 8
The results listed in Table 2 below are the 8th high, which is considered equal to the 98th

percentile receptor in that Class I area.

Table 2: CFAC Visibility Impacts for All Modeled Class I Areas

Modeled Year

2001 2002 2003 Average of

(Delta Dv) 8th High (Delta 0'1) 8th (Delta Dv) 8th High 3 Years Class I Areas Modeled Hich

Bob Marshall

Wilderness Area 0.462 0.428 0.603 0.498

Mission Mountain

Wilderness Area 0.425 0.448 0.348 0.407

Cabinet Mountain

Wilderness Area 0.199 0.266 0.316 0.260

Scapegoat Wilderness

Area 0.276 0.211 0.306 0.264

EPA Comment #8

S02 .Emissions and Control

8. The BART analysis only examines five adciitiooai technologies as possible BART for

302 control. The BART Guiddincs slate ~'Availablc retrofit control options are those air

pollution control tecr..nologies v.-itb :::l practical potcnriaJ for epplic::!tion to t.1-tc: emissions

unit and the regulmcd pollutant under evaluation. Air.pollution contrel Icchnologies Carl

include a wide variety ofavailable methods, s)'stems1 and techniques for control of the

affected pollutant. Technolog,ie.s required as BACT or L.A.ER are available for BART

Attachment A Page 9
purposes and mus, 1>e included. as control alternatives. The control alternatives can

include not only existing controls for the source category in question but also take into

account technology transrer of controls ~hal have been applied La similar source categories

cmd ga.s .streams." (sce 70 FR 39164). In addition. the BART Guidelines state "Yeu a:.-c

expected Lo identify potentially applicable retrofit control technologies that represent the

full renge oi demonstrated alternatives. Exunples of general infonnauon sources to

consider include: • The EPA ~s Clean Air Technology Center, which inciudes the

RACTIBACTILAER Clearinghouse (RELC);' State and Local Best Available Control

Technology Guidelines--many agencies have online infonnation--ror example SOt.rth

Coast Air Quality lvfanagcment District, Bay Are~ Air Quality !'vjanagement District, and

TexllS Naru..ral Resources Conservation Commission; • Control technology vendors; •

Federal/Stare/Load NSR permilS 2nd associated inspection!performance lest reports; •

Environmental consultants; • Technical journals, reports 2nd newsletters, air pollution

control seminars; and" The EPA's NSR bulletin board-hnp://v..-"\....w.epa.govlttnlnsr: ..

Department ofEnergy's Cle,m Coal Progrem-tcchnical reports; • The NOX Control

Technology :'Cost Tool"-Clean Air Ma.rkets Division Web pagebttpJIVNv"W.epa.govJainnarkets/arp/noxicontroltech.btm.l;· PerfonnGnre ofselecri;:e

catal)l::ic reduction on coal-fired steam generating Wlits-final repon. OARJARD: June

j 997 (also available at hnp:IIVoww.epa:govlalnnarketslarp/noxicoDtroltech.hlmJ);· Cost

estimates for selected applications ofNOX control technologies on stationary combustion

boilers. OARJARD June 1997. (DOCket for NOX SIP Call, A-9&-56; item 11- A--03);'

Investigation of perfo:-oance and cost ofNOX controls as applied 10 group 2 boilers.

OAR/ARD, August 1996. (Docket for Phase II NOX rule, A-95-28, item rv-A-4); •

Comroiling S02 Emissi.ons: A Review ofTechnologies. EP.A.-600IR-OO-Q93, USEPAf

ORDINIl'-1RL, October 2000; and • TI,e OAQPS Control Cost Manual," (see 70 FR

39164).

\Ve have identified other poteotial controls for 802 that CFAC n~ds to include in the

BART analysis. The European Union bas sponsored an analysis of potential controls for

various industries nnd based on their analyses, the follo,~iDg improvements are available

for conventional vertical stud Sederberg electrodes w reduce particulate and sulfur

dioxide emissions (European Commission. 2001. "l{efe::rence Doeurn~nt on Best

Available Tech.rtiques in the Non Ferrous Metals lndustries." Ir.(egrafed Poilu/ion

Prevenlion alld Control (IPCC) scrics, hnp;llc;PDcb.;rc.esJoagcslf....ctivities.htm page

286) (see attached disk).

Automatic alu.rnina point feeding a.'ld control of electrolysis (provides bener

control and more accuraw feeding of alumina to the bath)

~ompJete skirt coverage of bath crust (gas collection skin is connected to a

simple gas burner leading to a gas exhaust tube~ the burncr burns emitted CO

and hydrocarbons)

The use of"ciry paste" V"jth a tower pitch content Improved burner for

:':,cineration of PAHs arid other hydrocarbons in pot exhaUSl gas

Complete hood coverage of tne: anode top, which !s cO£mccted to a separate

gas exhaust a'1d drJ alumina scrubber or dry anode :op in combination with

stud hold paste and increased anode height depending on effectiver~ess

Attachment A Page 10
CFAC Response

As a result of this EPA comment, CFAC again surveyed likely sources of information

concerning 502 controls on aluminum reduction facilities. A brief compilation of

comments appears in Attachment H. CFAC has also reviewed the additional S02

controls listed by EPA, and offers the following comments:

During the years 1976 to 1980. the Columbia Falls aluminum reduction facility was

converted to Sumitomo aluminum reduction technology. Please refer to the attached

July 7, 2003, letter from CFAC to MDEQ that summarizes the Sumitomo conversion

project (Attachment I). Most of the items referred to in the European Commission

document were a part of the CFAC facility's conversion to Sumitomo technology. In

addition, as part of the Sumitomo conversion, the primary air pollution control system

was changed from a wet scrubbing system to a more effective dry scrubbing system.

Below is a summary of the Sumitomo conversion as documented by MDEQ on page 4

of CFAC's Operating Permit Technical Review Document:

"The facility underwent significant improvements between 1976 and 1980, when

all aluminum reduction cells and polline operation were converted to Sumitomo

Technology. Sumitomo Technology was adopted by the Anaconda Aluminum

Company (AAC) in an effort to reduce particulate and fluoride emissions from the

facility, and to show compliance with Montana's stringent Fluoride Standard. The

Sumitomo Technology, purchased by AAC from the Sumitomo Chemical

Company LTD, is a combination of engineering (structural) changes to the

aluminum reduction cells, operational, and process changes, and raw material

changes, for Soderberg aluminum reduction cells and potlines.

Other benefits, besides reduced power consumption and reduced emissions

(power consumption, as claimed by the Sumitomo Company, could easily be

reduced by 15-20% and emissions of hydrocarbon smoke and fluoride could be

reduced by 50%...), realized by AAC when adopting the Sumitomo Technol09Y

were a dramatic increase in cell operating lifespan and a reduction in man-hours

required to operate and maintain the facility.

During that same time period (1976-1980), AAC also converted the Columbia

Falls facility from multiclones and wet scrubbers to Alcoa A398 Dry Alumina

Scrubbers as its primary emission control device, and installed ten dry scrubbers

operating in two groups; four dry scrubbers for the West Plant and six dry

scrubbers for the East Plant. Dry Alumina Scrubbers are designated as

appropriate primary pollution control devices for the purposes of the Aluminum

MACT."

Large fluoride emissions reductions were achieved after the conversion of CFAC pots to

Sumitomo technology. The attached Chart 1 illustrates historical fluoride emissions

from 1957 to 2007. The Sumitomo technology conversion at CFAC was completed in

1980 and the impact of this conversion is evident in the fluoride emissions reduction

illustrated in Figure 1.

Attachment A Page 11
Figure I: CFAC Historical Fluoride Emissions

1'0

Potlines

Ib F/~ Operating 1

" - '---

, -<Il • o

o , o

. -

CFAC HISTORICAL

FLUORIDE EMISSIONS

,.. ,

: ~=~o-N~i~=~=~O-N~~~=~==O-N~~~=~==O-N~.~!~=~g-N~~~=~J.lu,u,u,u,u,u,ll,U,U.~.~.~ll,IlJJJlJl.ll.Iln.n.OillUUtn._.n..".......JI ~~;~~~~_~~~~~~;;~;~~;~;~;~~~~~~e;;~e;;e_;~;~~~~~~~~

Year

Below are point-by-point responses to questions raised in EPA's letter.

-Automatic alumina point feeding and control of electrolysis (provides better

control and more accurate feeding of alumina to the bath)

In the past, CFAC has investigated and experimented with point feeders on the

pots in the facility. Between 1982 and 1986, GFAG experimented with different

point feeder designs, but abandoned the project due to the feeder plugging up

with alumina are and cryolite bath behind the gas collection skirt. In 1992,

another attempt at point feeding began, with a modification to the previous

design used in the 1980s. Point feeding experiments continued until June 2002,

when the effort was abandoned. At the time of project curtailment, point feeders

were operating on 15 pots. CFAC's point feeder project was ended because of

are feeding difficulties, high iron in the aluminum metal and muck forming in the

bottom of the pots, reducing pot efficiency.

The aluminum reduction process at CFAC is controlled by PLCs (programmable

logic controllers) and computers using voltage input signals from the pots to

determine feed cycles and duration. The software for this system was

customized for CFAC by outside consultants, who continue to work on process

optimization.

-Complete skirt coverage of bath crust (gas collection skirt is connected to a

simple gas burner leading to the gas exhaust tube; the burner bums emitted GO

and hydrocarbons)

Attachment A Page 12
CFAC currently uses this technology. One aspect of the Sumitomo conversion

was the installation of gas collection skirts to improve primary air pollution control

system collection efficiency. Slotted burners were installed on each end of each

pot to allow the induction of combustion air into the pot gas stream to combust

carbon monoxide and hydrocarbons. This system is still in use today .

.The use of "dry paste" with lower pitch content. Improved burner for incineration

of PAHs and other hydrocarbons in the pot exhaust gas

CFAC currently uses this technology. As part of the Sumitomo conversion,

anode operation was converted to use "dry paste" to reduce hydrocarbon

emissions. As mentioned above, slotted burners were installed on each end of

each pot to allow induction of combustion air into the pot gas stream to combust

carbon monoxide and hydrocarbons.

-Complete hood coverage of the anode top, which is connected to a separate

gas exhaust and dry alumina scrubber, or dry anode top in combination with stud

hole paste and increased anode height depending on effectiveness

CFAC has already implemented this measure at the Columbia Falls facility. The

Sumitomo conversion at CFAC specified dry anode tops in combination with stud

hole paste and increased anode height. At CFAC, the effective anode height

was increased by using "dry paste- briquettes and filling the anode shell

completely to the top (rather than partially filling the anode shell with "wet paste"

as had been done prior to the Sumitomo conversion).

As a result of the investigations with the references in Attachment H, CFAC has revised

its opinion of the Spray Dry Absorber (SDA) for primary SO, control. The SDA was

preViously rejected as technically infeasible control technology (in the original BART

analysis dated November 5, 2007). CFAC, after several positive references, now

believes that an SDA would be a technically feasible method of controlling SO, from the

primary gas streams. As such, CFAC has prepared a cost estimate for this control

methodology (found in Attachment D), and has carried that forward to a cost per ton of

S02 removed, and a cost per deciview improvement.

EPA Comment #9

9. On Page 4·9 ofthe report you state "Significam process improvements ovcrthe currem

efficiency. while highJy desirable, are very difficult to achieve: and must be categorized as

technically e>:perimental at this point.': CFAC needs to include an analysis Or technical

justitication in the B.A...~T analysis for this s!ate!TIcnt.

Attachment A Page 13
CFAC Response

CFAC's statement from the November 5,2007, report was intended to point out that the

aluminum reduction process is one in which carbon anodes are consumed by

electrolytic reduction reactions, which are less than 100% stoichiometrically efficient.

Consequently, there is a theoretical limit to how much reduction in carbon usage could

be achieved. The following reactions account for most of the carbon consumption:

1. 2AI203 + 3C 4AI + 3C02 1

2. 2AI203 + 6C 4AI + 6CO 1

An absolute minimum theoretical lower limit of 0.33 Ibs carbon per Ib aluminum was

described in the November 5, 2007, submission. The following is offered to provide a

more detailed explanation:

The 0.33 Ibs carbon per Ib aluminum theoretical limit could only be achieved if 100% of

the reduction reaction took place via reaction (1). In practice, from 10% - 20% of the

reduction takes place via reaction (2), and because the secondary reaction consumes

exactly twice the carbon to reduce the same amount of aluminum, a more realistic lower

limit is about 0.39. Some pre-baked anode facilities operate at ratios as low as 0.45

but, worldwide, Soderberg-anode plants operate at about 0.55.

Whether the theoretical limit is 0.33 or 0.39 is not particularly important, because actual

plants in operation do not approach these theoretical limits. Aluminum producers in the

United States and elsewhere have worked hard to improve process efficiency. A 1956

reference text6 states, "The carbon for the reaction comes from the anode, for which is

required from 0.6 to 0.7 Ib of carbon per pound of metal." Improvements to anode and

cell design have improved these ratios significantly since 1956. A 1994 draft report,

"S02 Emissions from Primary Aluminum Production,,,7 prepared for EPA, described the

23 (US) primary aluminum plants in operation at that time. It states: "The coke and

pitch are consumed at a ratio of roughly 0.45 to 0.55 Ib (carbon) per Ib of aluminum."

Even though it would be a boon to aluminum producers worldwide, that ratio has not

been significantly improved since 1994. The CFAC 1999 data referenced in this BART

analysis describes a carbon/aluminum ratio: Pot Lines 3, 4, 5 - 61659 tons carbon /

112582 tons aluminum = 0.547.

At CFAC (a vertical Soderberg smelter) only a comprehensive conversion to a prebaked anode facility could significantly improve the ratio. A conversion such as this was

accomplished by Reynolds Aluminum at their Messina, N.Y. facility (now owned by

ALCOA) for a cost of - $200M.'

6 The Chemical Process Industries, Shreve, McGraw Hill, 1956, p.317

7 "502 Emissions for Primary Aluminum Production," unpublished review draft, April 1994, Marvin

Branscome, Research Triangle Institute.

S Phone conversation: J. Parker/M. Palazzolo, Alcoa, 3/12108

Attachment A Page 14
EPA Comment #10

to. CfAC needs to document El.I1Q e:-:plairilhe u.s:e ofa 1,5 retrofit factor that is included in

the cost analyses.

CFAC Response

CFAC, Bison and Performance Industrial Company (PICO) collaborated on the cost

estimate methodology used for the various 502 scrubber estimates. All three entities

have experience in applying retrofit cost factors to pollution control systems. The

universal consensus was to use a 1.5 retrofit factor due to the enormous complexity and

size of the proposed systems, and the fact that these types of control systems were not

envisioned to exist or planned for when the plant was originally constructed.

The EPA Air Pollution Control Cost Manual- Sixth Edition (EPA 452/B-02-001), Section

2.5.4.2 - states the following:

"The proper application of a retrofit factor is as much an art as it is a science, in that it

requires a good deal of insight, experience, and intuition on the part of the analyst.

"The magnitude of the retrofit factor varies across the kinds of estimates made as well

as across the spectrum of control devices. At the stUdy level, analysts do not have

sufficient information to fully assess the potential hidden costs of an installation. At this

level, a retrofit factor of as much as 50 percent can be justified. Even at detailed cost

level (± 5 percent accuracy), vendors will not be able to fully assess the uncertainty

associated with a retrofit situation and will include a retrofit factor in their assessments."

Given the experience of the three entities performing the cost estimates and the quasiguidance from the EPA manual, a retrofit factor of 1.5 was chosen for this installation.

EPA Comment #1 t

II. For all analyzed tc:cb_Tlologies in the analysis~ operating labor figures are based on three

full 8-hour shifts with wee to six operators at a time. significantly increasing the laber

costs. In the EPA Control Cost !\,[anual, the number or hours for an operator is a half

hour per 8-hour shift (EPA 2002, Section S, Chapter I, pg. j -26). CFAC needs 10

reevaluate operating labor figures based on Ll,e EPA Control Cost Manual uslog 1,642.5

hours (0.5 hOlliS far each ofthree 8-hour shifts vtith one (1) operator).

CFAC Response

EPA Comment #11 references the EPA Cost Manual's sample calculation for the

operator costs associated with a single packed column device operating at 22,288

Attachment A Page 15
acfm.' At 204,000 acfm, the process equipment we estimate for CFAC would be

approximately 10 times the size of that referenced in the EPA example. All flows of

process chemicals, water, and waste are proportionally higher as well. For this 10X

larger scale operation, process excursions, whatever the cause, have 10X the potential

for financial and environmental impact. As such, CFAC feels 24/7 operator attention is

required. In addition and more importantly, the reaction described in the Cost Manual

reference example is a simple Hel > NaOH reaction in which the waste product, table

salt, is simply discharged to a municipal sewerw The waste products at CFAC,

whether sodium sulfate (in a single alkali process) or the mixed salts, calcium/sodium

sulfite/sulfate (in the dual alkali or spray dry processes), are waste streams which must

be monitored, handled, and disposed of in a controlled manner. All this requires 24/7

operator attention.

After considering EPA Comment #11, CFAC has lowered the Single Alkali operator load

to 1 operator, 3 shifts/day, but argues that the Dual Alkali process with its associated

slurry make·up, reaction vessel monitoring and solids filtration/disposal would require no

less than 2 operators per shift, 3 shifts per day.

Appropriate reductions to operating labor have been made to the affected cost analysis

tables in Attachments B, C, D, E and F.

The operator costs for the Spray Dry Control analysis, which was added in response to

EPA comment #8, are estimated to be the same as the Dual Alkali process.

EPA Comment #12

12. The analysis used 10 years for the remaining useful life for all of the control technologies.

However, the ty~ical useful life of these control technologies is expected to be 15 years

based on infonnation from the EPA Control Cost Manual (EPA 2002, Section 5.2,

Chapter 1, pg. 1-2&). CFAC needsto reuncl.yze the anIlUclized costs for the contrOL

technologies using fifteen years as provided in the EPA Control Cosr Manual.

CFAC Response

CFAC understands that the useful life expectancy of a wet scrubber is up to 15 years;

however, CFAC still believes a 1O-year basis for BACT and BART analysis is standard

and typical. This is based on financial concerns (i.e., duration of financing rather than

equipment life expectancy). To be complete, CFAC has analyzed the annualized cost

for 15 years. As you can see in Tables 3 and 4 below, the annualized costs for the dual

and single wet SO, scrubbers and spray dryer do decrease; however, the changes are

not large enough to substantially affect the results of CFAC's BART analysis as to

whether the control devices are economically feasible on a $/ton or a $/deciview basis.

II EPA Cost Manual Sixth Edition, Section 5, page t.32.

10 Ibid, page 1.42.

Attachment A Page 16
As a result of the revised cost analyses contained in this attachment, CFAC has

prepared a table (Table 6) containing a matrix of combinations of PM,o and S02 controls

similar to the previous Table 4-8 (Summary of SO,/PM" Emissions Cost Analysis and

Visibility Impacts) contained on page 4-26 of the original BART analysis report. This

table shows a range of combinations of control strategies for 502 and PM,o, with

associated costs, declview improvements, and $ per deciview amounts.

Please note that, although CFAC did add a Spray Dry Absorber (SDA) to the list of

technically feasible SO, control technologies, CFAC has not included the SDA in the

matrix table (Table 6) because it has the same control performance (90% control) as the

single and dual alkali wet scrubbers. The single alkali is the lowest cost option of the

three wet scrubbers, so it represents the wet scrubber primary 502 control category in

the table.

Attachment A Page 17
Table 3: Revised Primary 802 Emission Controls Cost Analysis and Visibility Impacts

I Glacier Nat'l Park

SO, SO,

I

Decivlews

Capilal Annualized Efficiency Emitted Removed Cosl S02 Impact Removed {24 Cost

Control Option COSI Cost (%) (Ipy) (Ipy) (S/ton) (deciviewl hr-ll) . 'Slde1

Spray Dry

~bsorbe~)lLime

10yrlife $34204,364 $12,519,712 90% 153 1377 $9091 2.560 0.693 $16065962

Spray Dry

Absorber ILime

, (15 vr life) $34 204 364 $12179653 90% 153 1 377 S6645 2.560 0.693 $17,575545

Dual Alkali Wet

S02 ScrUbber

Controi'(-10 vr life) $43637616 $11476097 90% 153 1 377 $8333 2.560 0.693 $16560025

Dual Alkali Wet

802 Scrubber

Control (15 vr lile) $43,637,616 $10047,430 90% 153 1377 $7296 2.560 0.693 $14498456

Single Alkali WeI

802 Scrubber

Control

I (10 vr life) $37027,896 $10902,195 90% 153 1377 $7917 2.560 0.693 $15731683

Single Alkali Wet

S02 Scrubber

Control

li,5vetilo) $37027,896 $9 709 526 90% 153 1377 $7051 2.560 0.693 $14010860

Coke Sulfur

Contenl

Reduction SO $7,079,680 42% 887 843 510,245 2.743 0.510 $13,881725

Baseline (Total) SO SO 0% 1,530 0 -- 3.253 0.00 --

Attachment A Page 18
Table 4: Revised Secondary SO, Emission Controls Cost Analysis and Visibility Impacts

Glacier Nat'l Park

SO, S0, Deciviews

Capital Annualized Efficiency Emilled Removed Costb

S02 Impact Removed (24 Cost

Control Option Cost Cost (%) (Ipy) (Ipy) (S/lon) (deciviewl hr - Dl (Sfd,'

Roof Vent S02

Control

(Spray Room)-

10 vr life $42,350.409 $13,121,647 50% 58 58 $227,865 2.435 0.818 $16,041,133

Roof Vent S02

Control

(Spray Room) -

15 vr life} $42,350,409 $11741447 50% 58 58 $203,897 2.435 0.818 $14,353,847

Coke Sulfur

Content

Reduction SO 57,079,680 42% 67 48 $10,245 2.743 0.510 $13,881,725

Baseline /Total} SO $0 0% 115 0 -- 3.253 0.00 --

Attachment A Page 19
EPA Comment #13

Particulate Matter Emi!o>sions and ContToIs

13. In sectiOIl 3.8 you state th::n "la)lthough the six dry alumina scrubbers are eligible for

BART anEllysis, CFAC believes tOa! the current PM10 control is already the best possible

<:.t 99+% cOnlrQland fmther improvement could not be practicru]y accomplished." CFAC

n~ds 10 provide the design para.'1letcrs for th~ dry alumina scrubbers and an analysis of

how the clli,cnl PMJ acontrol is at 99+%.

CFAC Response

The six scrubbers are Alcoa A398 Dry Alumina scrubbers with associated bag houses.

CFAC does not have an air quality permit requirement to perform PM" tests on the

scrubbers, and has not performed these particulate tests. For purposes of this BART

analysis, CFAC has relied on manufacturer's information and generally available

information regarding the particulate capture efficiency of the baghouses.

The baghouses were manufactured by Wheelabrator (now Siemens), and are a modern

design pulse jet baghouse. Each alumina scrubber bag house contains 5406.25" x 107"

polyester felt bags. The bags used by CFAC are GE Energy PEO-72 fabric, a material

typically used in this type of installation in the aluminum industry. GE Energy stated that,

although a complicated test designed to simulate CFAC's specific operating conditions

would have to be performed to quote an outlet grain loading specification, they

nominally rate that type of bag at 99.997% capture efficiency."

Another source of information on baghouse performance, EPA literature (fabric filter fact

sheet: http://www.epa.gov/ttn/catc/dir1/ff-pulse.pdf) shows a modern baghouse with a

99+% removal efficiency for PM10.

CFAC believes that the existing alumina scrubber is a particulate control device that has

one of the highest available capture efficiencies, performing equal to or better than other

types of particulate control devices. Therefore, CFAC has not analyzed the six alumina

scrubbers for additional BART control for PM".

1':1)1\ Comment #14

14. In section 4.3.2 (it) it is staled that "'CFAC believes that added exhaust hood capture

efficiency would b::: expenmen1a] in nature and could only corne at the expense of access

to the pol'; for nomal operations and interference wi'!.b tht existing process." Please

provide evidence and supporting docmnentalicn to show L~at further reduction is not

possible Or is cKpeiimental.

11 Conversation between Chris Hiltunen of Bison and Eric Huggins at GE Energy, 4/8/08.

Attachment A Page 20
CFAC Response

To operate Vertical Stud Soderberg anodes, access must be maintained to the anode

tops for stud (pin) pulling tasks. Stud pulling and re-setting the studs is an integral

operation of a Soderberg anode and is usually done by overhead cranes. Hooding of

anode tops interferes with the existing overhead crane operation. CFAC is not aware of

any commercially available hood retrofits. Any retrofit would have to be custom

engineered, designed, fabricated and prototyped on a trial basis. Experimentation,

testing and optimization would have to be performed to detenmine if hooding that was

actually effective in reducing pot emissions would interfere with required operational

access.

Rather than try to design a system to maintain Soderberg stud pulling activities while

hooding the Soderberg anode, some aluminum companies have chosen to convert the

Soderberg potlines to pre-bake potlines. This option was discussed in the European

Union BAT document. Using estimating techniques from the European Union SAT

document (pg 722), the cost to convert CFAC's facility from a Soderberg facility to a

pre-bake facility is estimated to be:

Vertical Stud Soderberg (VSS) conversion to 2500 - 4000 Euros per Metric ton annual production

Point Feeder Pre-Baked Anode Operation $3400 - $5400 per short ton

Using this approximation, CFAC cost to convert: 5382,000,000 - 5734,000,000 (at 112584 tonslyr

I oroductionl

EPA Comment #15

15. The estimated capital equipment COst for the baghouse includes me use of a gas flow rate

in order to calculate the required fr' offilter bag cloth. The flaw rete used in Appendix C,

which is 3,000.000 acfm per po! :,oorn, is not consistent with the value reported on page

4-6, wlrich is 6,080,000 acfin per potline. Thc values in Appendix C and on page 4-6 ore

also inconsistent viiili the flow rate n::pon<:d [or fugitive sources in the 2005 MOnlana

Deparum:nt of Air QuaHly ernissions inventory for CFAC (330,000 acfm). CFAC needs

to pfO'vide additicnal dQcumen~tion or. the results of any measurements ofthe: flow rate,

on the flow rate used to cal::ulale lhe required ft? offl.lter bag clOI.~ in the tOSt analysis,

and an analysis ofwhy the nwnber useri in Appendix C differs from both the number

used on page 4-6 and the: flov.! mtc reported for fugitive sources in the 2005 Montzna

Dcpa.tT.ment of Air Quality emission inventory.

CFAC Response

The CFAC facility has five potlines, each poUine consisting of two potrooms, for a total

of ten potrooms. CFAC has years of fluoride stack testing data which measured

potroom airflow rates out the roof venls, and believes Ihis is quite accurate. CFAC used

long tenm averages of this data to calculate the flows used in the BART analysis. An

example of this data is included in Attachment J, which is the f10wrate data from the

1999-2000 MACT testing. The airflow rates shown in the one year in the example

provided are approximately 6,000,000 acfm per potline. There are two potrooms per

Attachment A Page 21
potline, so approximately 3,000,000 acfm per potroom multiplied by two equals the longterm average of 6,080,000 acfm per potline.

CFAC is still unsure where the 330,000 acfm came from, but no such flowrate is

reported on the annual MDEQ emissions inventory, and this value is clearly incorrect.

EPA Comment #16

16. CFAC needs to document and explain the use ofa 1.S retrofit iactor that is i..:.'1cJudcd in

the cost a.:.ialyses.

CFAC Response

CFAC, Bison and Pica collaborated on the cost estimale methodology used for the

various PM 10 control technology estimates. All three entities have experience in

applying retrofit cost factors to pollution control systems. The universal consensus was

to use a 1.5 retrofit factor due to the enormous complexity and size of the proposed

systems, and that these types of systems were not envisioned to exist when the plant

was originally constructed.

The EPA Air Pollution Control Cost Manual - Sixth Edition (EPA 452/B-02-001), Section

2.5.4.2 - states the following:

"The proper application of a retrofit factor is as much an art as it is a science, in that it

requires a good deal of insight, experience, and intuition on the part of the analyst.

"The magnitude of the retrofit factor varies across the kinds of estimates made as well

as across the spectrum of control devices. At the study level, analysts do not have

sufficient information to fully assess the potential hidden costs of an installation. At this

level, a retroflt factor of as much as 50 percent can be justified. Even at detailed cost

level (± 5 percent accuracy), vendors will not be able to fully assess the uncertainty

associated with a retrofit situation and will include a retrofit factor in their assessments."

Given the experience of the three entities performing the cost estimates and the quasiguidance from the EPA manual, a retrofit factor of 1.5 was chosen for this installation.

Attachment A Page 22
EPA Commcnl #17

17. For the analyzed tccp..nologics, operating labor figures are based on 24 hours of labor to

operate the equipment, signifiC3..'1tly increasing the labor costs. b. the EPA Control Cost

Manual, the number of hours for an oper.2toT is 2-4 hours per 8-hour shift (EPA 2002,

Section 6, Chapter I, pg. 1-44). CFAC needs to revise Loe operating labor figures baseo

on the EPA Cont!ul Cost Manual using 2-4 hours per 8 hour shift.

CFAC Response

The secondary ("roof top") processes described here are very large in scale. In the

roof-top Spray Chamber for example, there are 96 secondary spray rooftop chambers

each approximately the size of a railroad boxcar. Each chamber is fitted with 4 spray

bars holding 12 nozzles each (48 individual spray nozzles per chamber) and a 6' x 10'

chevron mist eliminator. These 96 de-mister pads and over 4600 nozzles gradually

plug and foul with precipitated salts and particulates and must be cleaned, replaced and

repaired. The piping which feeds the spray bars is PVC and susceptible to freeze

breakage if flow is impaired during cold weather. An EPA report on the development of

proposed standards for the primary aluminum industry" states that the daily average

low temperature in Columbia Falls is below 27°F 40% of the year, making it mandatory

to keep any water-based system such as the spray chamber flowing 24 hours a day to

avoid freeze-up.

Maintenance and operation of this corrosive system of 4600 nozzles, 48 ten-foot

diameter rooftop fans, each operated by 60 HP motors, and 15,000 feet of associated

piping, along with the monitoring and pH control of the recycle tanks and evaporation

ponds is a 24-hour/day job for at least two operators. These operators could

concurrently keep track of a less demanding, lower maintenance control system such as

a primary scrubber for potline exhaust, but would in fact need to be available strictly to

support rooftop systems when the situation demanded it.

Particularly in the case of the rooftop baghouse concept, one could totally ignore

operating labor and maintenance costs and the annual operating costs would still be

prohibitive.

~:PA Comment #18

t8. The analysis used 10 years for the remaining useful lift: for all or the control technologies.

However, the ty,ical useful life of these control teehnojogies is expecled to be 20 years

based on information from r."'e EP.A~ Control Cost Manual (EPA 2002. Section 5.2,

Chapter 1, pg. J-28). CFAC needs to reanalyze the an.!lUaJized costs ror Li-}e control

!ec.hnologiC,5 usiog 20 year.:; as provided l!llhe EPA Control Cost MGnual.

12 Basis and Purpose Document for the Development of Proposed Standards for the Primary Alummum

Industry, US Environmental Protection Agency, OAQPS, July 19, 1996. page 22.

Attachment A Page 23
CFAC Response

CFAC understands that the useful life expectancy of a fabric filter baghouse is up to 20

years; however, CFAC still believes a la-year basis for BACT and BART analysis is

standard and typical. This is based on financial concems (i.e., duration of financing

rather than equipment life expectancy). CFAC believes the financing and depreciation of

this equipment over 20 years is excessive and could not be accomplished at CFAC. To

be complete, CFAC has analyzed the annualized cost for 15 years, to at least be

consistent with the revised 502 calculations provided in response to EPA Comment

#12. The analysis included updating the cost analysis using EPA's Control Cost Manual,

6th Edition, as discussed in EPA Comment #12. As you can see from Table 5 below, the

annualized cost for the fabric filter baghouses does decrease with the change to 15

years; however, the changes are not large enough to substantially affect the results of

CFAC's BART analysis as to whether the control devices are economically feasible on a

$/ton or a $/deciview basis.

As a result of the revised cost analyses contained in this attachment, CFAC has

prepared a table (Table 6) containing a matrix of combinations of PM,. and SO, controls

similar to the previous Table 4-8 (Summary of S02/PM lO Emissions Cost Analysis and

Visibility Impacts) contained on page 4-26 of the original BART analysis report. This

table shows a range of combinations of control strategies for S02 and PM1o, with

associated costs, deciview improvements, and $ per deciview amounts.

Please note that although CFAC did add a Spray Dry Absorber (SDA) to the list of

technically feasible SO, control technologies, CFAC has not included the SDA in the

matrix table (Table 6) because it has the same control performance (90% control) as the

single and dual alkali wet scrubbers. The single alkali is the lowest cost option of the

three wet scrubbers, so it represents the wet scrubber primary SO, control category in

the matrix table.

Attachment A Page 24
Table 5: Revised Secondary PiVIIO Emission Controls Cost Analysis alld Visibility Impacts

Glacier Nal'l Park'

PM,o PM,o PMIO Declvlews

Capital Efficiency Emilled Removed Cosl Impact Removed Cost

Control Option COSI Annualized Cost (%) Ilpy) Ilpy) (S/lon) fdeciviewl (24 hr -6\ (Side}

Roof Vent Control;

I fBanhollse· 10 r lifel $569149375 $107637826 99% 2.18 216 $498739 1.621 1.632 $65954550

Roof Vent Conlrol:

I fBaahovse - 15 Vf mall $569,149375 $89089,248 99% 2.18 216 $412794 1.621 1.632 554589000

Roof Vent PM'Q

Control: I

(Spray Room - 10 yr

life)) $42 350,409 $13,121,647 50% 109 109 $120.382 2.435 0.818 $16.041,133

Roof Venl PM'Q

Control:

(Spray Room - 15 yr

life) $42350409 $11,741,447 50% 109 109 $107720 2.435 0.818 $14,353,847

Baseline SO 0% 218 a .. 3.253 0.00 ..

Allachment A Page 25
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"EE
Columbia Falls Alumillum Company

20110 Aluminum Drht

Culumhi:t F;llb. .\lT:''}91~

1400) K'):!~:!1l

1·H}6) ~n·~2u; f;u

Julie Ylerkel, Air Quzlity Specialist

Pcrmiuing &. Compliance Di·,.'!s!on

~1omana Depanmen: ofEnvironmemc.! Quality

POBox 200901

Helena. ~1T 59620-090 I

R~ You:, R~quest tor kforrr.atiol1 Concerning Sumiro:TIo Ccnversicr:

De.:!.f .\15 MerkeL

A:; requested in your lener of ~!arch 28. 2003. below is information regarding :he

construction projects completed bet\',:eer, ! 976 and 1980 Zt CFAC" s aluninum ,edl.:ctior.

f:lciiit\'

Th~~ conSlnlction activity conductt:C be:w~cn !976 ami 1980 did not occur on a pmiint.: by

p,1tlin~ basis. so information C3nnOl be supplied on thot basis Belo\v is a summary of

t:ach major task. '.vit!"! Stan and enc dales, and co!>",:,

1. Cell Rebuild and _-\UlOnlation

ThlS uClivily consisted ofr~building each of the 600 pOlS according to Sumitomo de:-;ign

This includ~d changing the anode and cathode contiguratio!ls to match Sumiwmo

Spt.:Cilicntions Key elemems of the pOi convt::lsion to Sumitomo ol:sign included .

• cathode cons"lnJoion changt.:s Ie improve energy cflicicncy and ca;hode life

- anode construction and Oil::'C!.!~On ch::nges to char:t::.e lrcm a wet to a ct,.... anode .. . - - which impro....ed energy efficiency and reduced atlodc hydrocarbon er.1issions

- inst.allation of gas collec[!on skirts to Improve p,lrr:ary 3,r po]Jmion cornroi

:;,v::,!cm collection efticienC"v

• Installatior: of al..:Hmll!.tic crust b:'t;akt;:'"s <::I1C e compu:er:zed con:;ol SyS,t;r:l (1:1

t:~ch pot 10 impron: the 2.lumir:a fccdi:1g cyc:c.
\ll.'r;;:l.'ll<.'!il'·

j;.:,~ - :~Il"

Ccnwr:.ton 0:' !i'1l' pOl:- to SUmiWr.10 design beg,::) in October :97() \\,jl~': a test ;::ot

section W;l.;:. Ii,s: com::=rtcd Af1.er successful op::=r<.llion :.){ C:ll' re$1 pOt !-t'ctio:-., the

n:n1:linin~ pots wer\.' convened rzndo:nly througnou: tne pl:":lil a,;cQr;;::lng tc po: age The

fil":al pcl! cor.vc;"'Iec to Sumitomo desigOl s:o.l.r:ed up CI~ :'.larch :i.. 19800

Thc :·1Il::.1 COS! tOI lhi:> purtiun C! the proJeci \~a;) f:su:na:ec In June I CSf,1 tr. he

S:2t,,-100.nl1O

Description

The SumiIOmo anode design specified a dry anode comprised oi pe:roieum coke and coal

tar pitch Previous 10 Sumitomo. the facility opera:.ed w::h we:. mort:: f.uid anodes. To

manufaciUrt: dry anode briquettes, numerous modificalions were madt: to the exisling

paste plam including,

• installation or <l hOI oil 5)'!>tt'Jn

• redt:sign and construction of extrude:-s to hendle [he dry P<!.SIC

Stan :lr:C Er.d Datt's

?bnning for th~ cOTl\.ersion of the !laste plant to Sumi:omo tecr.nology began 1:1 Augus~

19i6 The paste pi::mt was fully convened and operetional i:1 June 197Q

COSt ofthi:,; phas~ oflhe project W;lS estimated in Junl.' 1980 al SQ6S,OOO

3. Of')' Scrubbtr

A dry scrubbing system for POl gases was designed and installed to improve the air

pollution control of the facility, The dry scrubbing system, srill in use today, is bascd on

Alcoa :'\398 dry scrubbing technology, Key elements of this. p:"ojeci were'

- design. co~struc:ion and instalJetion of d:-v scnl~b~r re2.c:or~ u~cd !a n:.t:d:zcc inco:ni:'l§

alull:Jn.J ere with pot g.a5~S in ord~r to r~cU\.el LJcn~t: <Inc hy::i:-aC<:.~I')l~r: t:lilis,:;:on:-; and

rerun: tne':n to i~~ proces!'
Attachment G
Table 3a: Sulfur Dioxide Emission Factor Calculation I - r

Columbia Falls Aluminum Company I

Regional Haze Emission Inventory

Sulfur Dioxide Emission Factor Calculation

Assume all of the sulfur in the c:oke and pitch is released to the environm~n!!~ sulfur dioxide - Assume none of the sulfur dioxide is captured in Ihe drv alumina scrubbers.

- Petroleum Coke % Sulfur Specification 1.5

2007 Pitch % Sulfur 0.7 - .

East Plant Tolal East Plant

Plant Potline 3 Polline 4 Potline 5

1999 Aluminum Production tons 186,178 37,466 37,517 37,601 112,584

Fraction of annual production 0.201 0.202 0.202 . -- 1999 Coke Use - tons 73,171 14,725 14,745 14,778

1999 Pitch Use· tons 28,792 5,794 5,802 5,815

1999 Sulfur in Coke tons 1,098 22' 22' 222

1999 Sulfur in Pitch Ions 202 4' 41 41

Total Sulfur tons 1,299 25' 262 262

Total Sulfur Dioxide tons 2,598 5231 524 525

Tolal Sulfur Dioxide nds 5196433 1,045,728 1 1,047,150 1049,485 ..-

Sulfur dioxide lbslton aluminum 27.9 27.9 27.9 27.9

I ._-

Assume 93% hoodi~ ~!!icie of the ols; ie; 93% of 502 DeS to prima d scrubbers, 7% oes Ihrou h roofs

I

Primary Dry Scrubber S02 Iblton aluminum 25.96 25.96 25.96 25.961 -- Potroom Roof 502 Iblton aluminum 1.95 1.95 1.95 1.951

4/14/2008 Allachment G - Emissions Spreadsheel.xls
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Attachmcnt H
Specific List of EPA-Su~mestodSourcess

Relevant Coulon!;

1 EPA Cloarlng Uouse RBLcl....:..' _

hltpJ/cfpub.epa.gov/rblclhlmlbI02.cfm

RBle: A search orlhe RBLe database using paramelers Alumlnlm and S02 yields only two references

since 10BB describing Aluminum processes trealing S02. Requested edvlce from EPA in locatlng more

relevanl aluminum Industry docs, (see noles below.)

1) (Sept·199B,) involved permiUng for a NEW polline inslallllUon, (SWA ·Southwire. Kentucky) whore on

502 wet scrubber II prescribed to have a design efficiency of 93% or greater. This is for a PREBAKE anode

plant (higher concenlralions and mudllarger flow rates,) plus the requlremenls were lor a NEW installation.

2) (Aug·1995) Involved expansion or an anode bake plant (AlumalC In South CMollna.) NO nevI conlrols

were required. BACT p!!lcllco Was described as ·,lmplY lirolling the suUur cootont 01 tho raw materials,"

I Texas Nalural Rcsourcoss Conservation comml ,I

hltp:II~'AVI,v.lceq.stale.lx.us/permitling/air/rulesilederal --'---'Ac,CeCa""OhC,CI"'~h''"''T"e<c.c,"c",CmmJ=",","~",",7.;17e7r,C,"A"r==""c"cmc,C'"I,C,,7,O,CeC,c.c."id"'"h"eO,ec.c.c,",CaC,7IyC5~,e7reC,".c,7rpC,C,"",c.".-- occurrences In the stale ond thoy would nol be covered In tho database.

QUeeN ElIglnnorln!!, Farmingdale, NY - DanIel Uhr

Ducon was askod 10 recommend and give budgelary estlmatos for a Singlo Alkali, a Dual Alkali, and a Spray

Dry process to coouollow concentrations of S02 in a -220,000 IIcfm 01 nUB gas. Even though their CEO,

has been a developer of the Dual Alkali system, DUCON was In favor of a Spray Dry system over lhe other

two. They believed a Single Alhli system (such as lhe one at NWAI would pose WOller disposal problems.

DUeON submittod budgot cslinlillcs of $28M lor Ihe Spray Dry process and $J5M for lhe Dual Alkali, bolh

or which camo within +f- 30% of the delail estimates PICO made for lhe 18rne processes.

I Control Tochnology Vondorsl-",-'_~_~~~-~_-__- ----------------

Clvde BowrllDn Engjneorjno. Hanover, MD - Rod KImball

Contacted Bergman fe "Lurgl Process· (mentioned in Vatavuk) Bergman Initially boughllhe process Irom

FMC but no longer uses or recommends il. ·uses far more lime· 2.5 .4.0 times stoichiometric reaction, Said

Spray Dry would be a belter choice (or ease of operallon bul 90".4 efficiency may be difficlullo obaln \\;th

anything less Ihao a weI systom.

TurhoS9/lIC Eonlnoorluu. Parsippany, NJ - Marguerite Svldunovlch

Recommended lh81 Singlo Alkali using a packed column would be most successful due \0 low 502

concentrations. Besl resclant 50% NaOH with 10% bleed rolo. 316 type SS reoulred for column. Adding

Caldum sail preclpllaUon (leo Dual AIIaU) would MmOre than doubleMthe cost or the process.

Daln!t Rluflonsa 10 EPA· recommended SOllrce LISI. Shaoll

313012008: 11 13 AM
1 Environmental Engineering Consultantsl ..J

Barr EngineerIng BART an.lVII" Northshore Mining Co;

A BART analysis for 502 emission!! "om Mldwesl region COIlI·fired gonCHaHon plonls used II retrofit factor of

1.6 due 10 crowded work areas,

MACTEC Fodoflll Progr:lms, Ellulnoorlng & Consultlng;

CFAC reviewed eXlensive Midwest RegIonal Planning BART analyses conducted by MACTEC for the Lake

i't.lchlgan Ar Directors Consortium. The anal~is included 502 cootlol and selected the same three controls

as tochnlctllly (easlble: 'Advanced FGO· (a type of dual alkaJl system,) a Wet Scrubbar, and a Spray Dry

scrubber. Siotamant from the repor! "COllllol costs for boilerS with 101'llnlel concentrations of S02, (eg

boilers Ihol firo primarily nalural gilS,) are very high." Allhough baUer processes are Inherently vory different

from aluminum pot lines In torms of nUl gas temperature (>1000F VI .:300F) and S02 concentrallons. Iheir

estimated caplllli costs for slmbr Inlloftallons feU within the aome range as CFAC's for olllhree opllons, ie.-

$40M, However, because S02 INLET concentralions are 100 -1000 limes higher, tolal ton5lyr removed by

these installations Is roughly <lx higher (4500lpy vs 15001py,) Consequently the "cosl elfoctlvenosn" Ihoy

calculate ($/ton removed) Is lower (- $2·3KJton) because Ihelr denominator (tans) Is much higher.

I Industry ASSOCIatlonsl~'

Aluminum Assoclatlol1: Director for Environmonlal Affairs· Roberl Streller

Mr Stroller had been recommended 10 me by David MeisenheImer at EPA. Streiter slated that In genersl,

502 emmlsions hod not been a NSPS issue for the aluminum Industry. A BACT sludy roferenced In Ihe

RBLC described suflur conlent control 01100 coke as ftBACT,ft and lhol BACT standards whould be sufrlCient

10 sallslfy regional haze requiremenls. He reforred me to Mike Polaz;zolo of ALCOA.

I Direct communlcallons Other Industry Contactsl--" _

Golen May· Superintendent NWA, Tho Oollos; This Vertical Soderberg plant Is a very closo anologuo of the

CFAC Inslallation. 502 ond parliculate controls were installed and are referenced throughout our report.

Mike Pnlnuolo· Ofreelor of Environmental Health and Safely, ALCOA Aluminum: Mr. Palazzolo roferenced

ALCOA'a Messina plant (folmerly owned by Reynolds Aluminum) which has been relrofilled with II '.5M

acfm wei scrubber as pari ala complete conversion ollhe facmty to a SWBP plant. The Reynolds cost was

"SlBO·200M and costs have gone up dramatlcaMy since then." The Messina scrubber Is single alkaR using

Na2COJ (lor Max RX efficiency) bul Ihe s!ngle pass emuenl from Ihls mega·scrubber discharflCs dircclly into

the St. Lawrence without posltreatmont A separate 200,000 acfm IImestone·based wet sCfubber for their

prebake furnaces cosl-$30M (Tolollns!alled Cost.)

Delail RelpOn.e to EPA. rec.omlllendl'ld Source U5" Sheen

3130120011: 11'13 At.1
I EPA OPQASI '

--'-!O~,",~',I'MMi.Ei,~,;;,,~"i.';;m;;.;;,=,~EfP~A=,~O~A~9~P~'~I~Ii~E~'D~I~A~BijC~G~';M;;;;:','M.e;;i;,e;;"'he;;;'m~e;;,",;;e~'Oo;mMm~.;;"dd';;d"'I,,;;,"A;~'"'C"O;;";;""'.'N"E<Tr:-.- Documentallon report which yielded lIttle on Aluminum. He asked his fellow worker, larry Sorlcls 10 look but

he also found lillJa. SOffels recommended Steve FfUh as a source closer to the Aluminum Industry. Fruh

had been Instrumental In devolopment of the MACT guldllnos and specialized in lhe Aluminum Industry.

Meisenheimer llSl(cd Frllh to contact mo, which he diet

Sieve Fruh, EPA, Soctor Polls:lo§ and Programs Division, Motllis and Mlnorals Grollp: Mr. Fruh Illid

lhat the EPA hod focussed on Flourides end Particulates in generating !he MACT lulos Dnd (hnt 502

references were Iimiled. Fruh focommonded I contact Marvin Branscome.

Marvin Branscome, Rese"rch TriallCiIo Instill/te, contractor for lha EPA: Mr Branscomo said Ihal he

had partic'pated In 8 short alOOy on 502 tonlrolln the aluminum indusl/)' In 1994 and would sond me II copy

of the draft repor\. II was nevor publlshod. low concentrations of 502 in prima/)' aluminum slroams made II

"doubly hald to deal with." He sloted thallho doslgnallon VSS2 was specincally cronted to descrIbe the

Columbia Falls Sodoruorg facility because the weather conditons in the ragion of the plenl prohlblled the use

of rooftop scrubbers such liS woro used nt lhe other Iwo V5S1 plants, NWAlumlnum and Goldllndnlo. bolh

near Porlland on the Columbia river. He said thai the four plants total with wet roof serubuels for secondary

exhausls wero 40·60-/. offlclent nnd were considered a "prohibilively expensive" option for the MACT

standard. He rocalled they were casted al "aboul $5Of.1 15-20 years ago." The control method which had

been accepted was 10 control the lIulfur conlent of the anode coke which, 15 years ago, cost about $7/10n for

each 1% of reduction.

I NOX Control Technology "Cost Tool"l "

\w...v.epa.gov/alrmarkelsfa rp/noxleonlroltech. hlmlL.;'-,W::;:"'~=O"d",~"C.""~"kC.lc"",;:."It,,,C."~""d"bOV'"'--P"A""C,o.C,"',"to"'b.=,,,,,,,=.c'","b"'.', ""cow'.c,'.",Cmc.",",co',~.,",o',",",..=,,"'o',=m'.",,=o,,--

following lhall1nk, referred to In the Roglon 0 comment, was related to NOX: I.e. "The NOX Conlrol

Technology "Cost Tool", www.opD.gov/nirmarkelsfarpJnoxlcontroltech,Cost estimatos for teleeled

appllcalions of NQX control technologios on stal10nary combustion bollars, OAR/ARO June 1997. (Dockot 101

NOX SIP call), Investigation of performnnclI and cost of NOX controls as applied 10 group 2 bailors, etc. etc.

Because lhls study was not focussed on NOX. bUI on 502 and pantculatas. it Is not ciear why Region 0

chose to lequesl we investigate these NOX specific sources.

I Use of the EPA Control Cost Manual- Version 61'-" _

The EPA Cost Control Manull Version 6 was used extensively and relerences cited throughoutlhe analysis

CFAC made 1II1dcxtensive Revlow of Ihe European document and responded to the SPIICInC comments by

Reg'on a. A serHlrale altachmnnt describes this review in detail.

1 European Union: BATII,Noll Ferrous Meta'sl_,,'~==-~- -_~_--_--__--__-_-__------

OctaD ReSllOll$O Ie EPA. lecommcndcd Source lIst Sheell

313012008 11 13 AM
Attachment I
\kn~l'! kllC'

JLlh -.2th,I'

- desIgn Clms::ucl.lO[; 3:1d inst<!.H3HOI; .,f baghousl.: ~YSlt:Jl!~ on :op of t:H:: dn ;:,;';!"'Jb!Jt':

lcaClor::.

• dt.'siull. cnnSUl.lClIon aGd mSlailaiion 0: dUC:WOfi\: for coll~ctiO!~ "rthe :)0: :.:.a:.l.:.5 - . -

- :--.:mova: Oflhc exi$t:ng wcr scrubomg 5\'S1<:0:

~,:Ht and! I1C Dalt:s

Deslg.n of,he w~s: plan~ dry sca~bbing S}Stl:m, .... hich WllIrol!> ciJlissiol:s froill pOll:ncs :

and 2, beg.an in AU~L1si. 1976. Stanup ofthe west plam Ot;> s;;rubbmg systcn: was Ja:lUary

0. lQ7S

D~.!olgn of the: t'3St plar.t dry sc:ubb:ng s~'s':c:T'., whict': c~tJtrol!' e:r.:s:;;ons from iJO::ines 3.

-L and 5 b:.:gar. ir. September 19i7 S:3!"mp of the caSt pia:li. c::; scrubo!ng ~Y!'te::1 W:l!'

De:cember .: 1. ! 978

The tm",1 COst ofthe west and t:~st pl:.!.nl dry s;;rubb:ng l>yStcm wa:- esti:na:...:: lil Ju:w : ';;80

;:0 bC' $5.134,000,

-L Potlinc Suppon Equipment, Techrwlog)' Licensing :H1d olher activities

De~cription

Tn suppon the

r...:dmology 2nd

made. $uch as

changt:s made to the facility tiS ::l fCSllh of the adopt:ol~ of Sun:itomo

Alcoa or\' sca:bbiJl~ tt:dlllO]Og\. Ollt"':l '!iJ~ra<h.:~ 31ld c,pcndi:urcs \\crl': . - _. .-

• specify <!ond puchase SilUnt l11achtncs

- spl-cify and puchase pin service machines

- spccify and ?urcha..o.;e stud pul1in~ ow.cbino:

- upg!<!dc air compress-or sys'lem

~.J!.l1.d-'·.nd Dates

T!IC'5e aCli\ itie$ "ere cor:~ tk:::wccTl Aug.usi: 1976 anc bnt.: : 980.

Th~' co:-1 uf podinc support ~l!ipmcnl. !cdmoiog.y li:::::n.sing fees a:ld C;U1:tl:lgl;nCll:~ \l';!.S

l::stm131l:d ir: jUll,,; jCl~i:J to bl: S9.900.:)()(i,
.. i , , L

! -

.f \k~kL:1 kitcl

Ju.\' '7 :U().i

T!l~' ovcr:l.!! C~l~1 of !h~' \\Ol~, cl:mplclc:! bl..'I\\'l:l..'ll :\Ugl!SI

aiumimijJ\ produc,iQr: facili:\" \.';a:-; estimated in June:

S·CAOO,OOO

P1CJ.Si' call if you ha\'e fiJrthe:- questions on this ma:!t:~

Sincerel~,

,.- .. '">,_L f I I

./ }LtL:.-:-t v SI~eW:igh:

Etlv:;ol!m~mal &: Labormory \'lan\!.gc:

cc Caltn Laughner. Esq

Sie\e Knigh:

1(:'7(, ;:nd l:mr.: l.,)Srl Ui ::ll

1%:1 10 bl' <:lp?IOXli:Ul'..:iy
Attachment J
Columbia Falls Aluminum Company

Pothne Roof Exit Velocities, Temperatures & Flows

As measured via EPA Method 14

for nuoride and POM emission compliance testing as

required by the primary aluminum MACT regulations

Roof Cross Single Roof

Velocity Temperature S~tional Area Flow Polline Roof Flow I

Date R~f ftlmin F ft2 actual ftJ/min actual ftJ/min

Potline J

10/111999 , 3437 77.~ 9.125 3,136.263 6.272,525

11'111999 5 '" 5

" 9.125 3,116.188 6,232,375

12/211999 5 3239 "., 9,125 2.955.566 5,911,175

113/2000 , 3004 52 9,125 2,741.150 5,462.300

2/812000 5 307.3 69.2 9,125 2,e04,113 5,508,225

31112000 5 317 1 72.3 9.125 2,893.535 5,787,075

4/15/2000 , 358.4 77.2 9,125 3,270.400 6.540,800

""'000 5 350.6 82,'\ 9.125 3,H}9,225 6,398,450

6112/2000 5 351.6

" 1l.125 3,263,100 6,526,200

7/512000 5 360.6 87.2 9.125 3.290.475 6.580.950

'MOOO 5 '''' 10lL3 9.125 3.253.975 6,507.950

"""000 , '"

,

83,1 9.125 3.117.100 6,23<4.200

"1/212000 5 349,5 79,9 9,125 3.189.188 6,378.375

l1t112lll10 5 367.7 66.' 9,125 3.355.253 6.710.525

AlIl!fage 341.2 77.6 9,125 3,113,254 6.226.509

Potlino 4

101111999 7 360.6 64.9 9,125 3,290,475 6.580,950

111211999 7 331.5 63,9 9,125 3,024,938 6,049,875

1212/1999 7 334.2 69,4 9,125 3,049,575 6.099.150

1/4/2000 7 310,4 65.1 9,125 2.832,~00 5.66<:.800

""""0 7 271.5 60.8 1l,125 2,477.438 4,954,875

~1nooo 7 339.7 ".7 9,125 3,099.763 6,199,525

414/2000 7 333.7 60 9,125 3,045,013 6,090.025

"""'10 7 363.4 72.3 1l,125 3,316,025 6.632.050

,,",,000 7 '" '" 9.125 3,513,125 7,026.250

7/5/2000 7 36a.• 85.' 9.125 3,366,213 6,732.425

81112000 7 3SO,4 103.7 9.125 3,562,~OO 7,124,800

91512000 7 399,1 607 9,125 3,641,788 7.283.575

10'2J2000 7 378.8

" 9,125 3.456,550 6,913.100

11/112000 7 365,4 55.7 9,125 3,334,275 6,658.550

Avel:lDe 352.3 74.2 9,125 3,214,998 5,429.996

Potline 5

101JJ1999 • 279.5 81' 9,125 2,550,438 5.100.875

111211999 • "" '" 9.125 2.3111.575 4.639.150

12/1'1999 • 262.9 73.1 9,125 2.398.953 4,797.925

lft2J2ooo • 235.3 62.9 9,125 2,156,238 <.312.<75

mnooo • 211 4 71' 9,125 1,929.025 J.B58.G50

311/2000 • 237,4 7t 9,125 2.166,275 4,332,550

4/</2000 • 2<:1.2 73,4 9,125 2.200.950 4.401.900

""'000 • 301.7 77.7 9,125 2,753,013 5,506,025

15112/2000 • 298,6 79.7 9,125 2,724.725 5,449,<:50

71512000 • 325.9 8<:.8 9,125 2,973,838 5.947,675

8/1/2000 • 327.8 '" 9,125 2,991.175 5,982,350

91512000 • 316.0 50.' 9,125 2.888.975 5,777.950

101212000 • 298.6 78.5 9,125 2,724.725 5.449.450

11/112000 • 270.3 66.' 9,125 2,466.488 4.932.975

A\/Crage 275.9 76,8 9,125 2.517,457 5,034.914

, eao;h pOWne is o;ompr;l'ed of two (2) potrooms

AVERAGE 2,948.570 5,897.140
Attachment K