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A

National Emission Standards for Hazardous Air

Pollutants for Primary Aluminum Reduction Plants

Implementation Plan

Potlines

Alcoa Inc.

Rockdale Operationsadin Works

Rockdale, Texas

Prepared by:

Alcoa Inc.

PO Box 472

Rockdale, TX 76567

Created: April 6, 2001 Updated: June 10, 2008
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TABLE OF CONTENTS

TABLE OF CONTENTS ..............................................................................................................2

1.0 INTRODUCTION....................................................................................................................4

2.0 EMISSION SOURCE IDENTIFICATION...........................................................................5

2.1 A-398s

2.2 Wet Scrubbers

2.3 ESPs

2.4 Baghouses

3.0 EMISSION LIMIT ..................................................................................................................6

4.0 APPLICABILITY AND CONTROL DEVICES ..................................................................8

5.0 SITE-SPECIFIC TEST PLAN ...............................................................................................8

5.1 Test Program Summary

5.2 Test Schedule

5.3 Sample Location

5.4 Sampling/Analytical Procedures

5.5 Data Quality Objectives

5.6 Internal Quality Assurance Program

5.7 External Quality Assurance Program

5.8 Exceptions to EPA Methodology

6.0 CONTROL DEVICE MONITORING PLAN ....................................................................16

6.1 Criteria For Parameter Selection

6.2 Alumina Flow

6.3 Air Flow Limit

6.4 Water Flow

6.5 Voltage

6.6 Secondary Current

7.0 COMPLIANCE DEMONSTRATION.................................................................................19
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TABLES

Table 1 – Summary of Abatement Devices By Potline

Table 2 – Summary of Sampling and Laboratory Methods

Table 3 – Summary of Estimated Accuracy and Precision Objectives

Table 4 – Summary of Internal Quality Control Checks, Frequencies, Acceptance Criteria

and Corrective Action for Total Fluoride Analysis

Table 5 – Potroom Parametric Monitoring

 

FIGURES

Figure No. 1 – Potline 3 Primary and Secondary Emission Control Systems

Figure No. 3 – Potline 4 Primary and Secondary Emission Control Systems

Figure No. 4 – Potline 5 Primary and Secondary Emission Control Systems

Figure No. 5 – Potline 6 Primary and Secondary Emission Control Systems

Figure No. 6 – Potline 7 Primary and Secondary Emission Control Systems

Figure No. 7 – Potline 8 Primary and Secondary Emission Control Systems

APPENDICES

Appendix A – EPA Test Methods

Appendix B – EPA-Approved Alternate Air Flow Methodology

Appendix C – Alternate Measurement Site Study
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1.0 INTRODUCTION

On October 7, 1997, the United States Environmental Protection Agency promulgated 

National Emissions Standards For Hazardous Air Pollutants (NESHAP) for Primary Aluminum 

Reductions Plants under 40 CFR Part 63, Subpart LL. These regulations, which are applicable to 

primary aluminum reduction operations, establish total fluoride (TF) emission limits for existing 

potlines and TF and polycyclic organic matter (POM) emission limits for anode bake furnaces. 

In addition to the emissions limits, the Primary Aluminum NESHAP also requires the installation 

and operation of monitoring equipment for certain control devices and process operating 

parameters. The Primary Aluminum NESHAP became applicable to the anode bake furnace in 

1999, to the green mill in 2000, and per Alcoa’s request for an extension was applicable to the 

potlines in October 2001.

The approved August 3, 1999 Parametric Monitoring Plan and Site Specific Test Plan for 

the anode bake furnace and green mill control devices at Alcoa Rockdale were to be modified to 

include the potlines upon applicability of 40 CFR Part 63 Subpart LL to the potlines. However, 

since the potlines are implementing the emissions averaging, per §63.846, this Implementation 

Plan has been prepared separate from those two documents. The Parametric Monitoring Plan and

Site Specific Test Plan were modified to reflect that this Implementation Plan is a separate 

document. 

This Implementation Plan has been prepared for regulatory authority review and approval 

in accordance with 40 CFR Part 63, Subpart LL §63.846(d). The purpose of this Implementation 

Plan is as follows:

Illustrate that the parametric monitoring demonstrates proper operation and 

maintenance of each control device; and 

Perform reference method testing and record production data to demonstrate 

compliance with the average emission limit for the potlines. 

The plan is prepared in accordance with §63.846 that requires the following sections, as 

appropriate:

Section 2 – Identify emission sources in the average;

Section 3 – Assign TF emission limit for the Alcoa Rockdale potlines;

Section 4 – Outline specific control technology used for each emission source in the 

averaging group and the date of its application;

Section 5 – Prepare a Site-Specific Test Plan for the measurement of TF emissions in 

accordance with the requirements in §62.847(b);
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Section 6 – Outline operating parameters to be monitored for each control system per 

§63.848(f) and describe how the operating limits were determined; and

Section 7 – Demonstrate that compliance with the applicable emission limit were

achieved under representative operating conditions.

2.0 EMISSION SOURCE IDENTIFICATION

There are 12 potrooms comprising 6 potlines at Alcoa Rockdale (two potrooms form one 

potline). Emissions at each potline consist of fugitive roof emissions (secondary emissions) and 

emissions from the primary control system. Table 1 summarizes abatement equipment, control 

devices and EPNs for each potline.

Fugitive roof emissions are generated in the potrooms when sections of the pot fume 

control hooding is removed for anode changing and other operating procedures. Fugitive 

emissions within each potline exit through roof vents. 

Each pot is equipped with a hooding and manifold system that captures and directs the 

emissions to the primary control system. The primary control systems vary between potlines at 

Rockdale which are illustrated on Figures 1 through 6 for potlines 3 through 8, respectively. 

Potline 3 has three electrostatic precipitators (ESPs) and one baghouse, with each ESP and 

baghouse having two wet scrubbers. Potline 4 has three baghouses, where the first baghouse has 

four wet scrubbers, the second baghouse has three wet scrubbers, and the third baghouse has two 

wet scrubbers. Potline 5 has nine dry alumina scrubbers (A-398s). Potline 6 has six ESPs with 

each ESP having two wet scrubbers. Potlines 7 and 8 both have twelve A-398s. These primary 

control systems vent emissions through either a scrubber tower or A-398 stack(s). A description 

of each type of abatement equipment at Alcoa Rockdale is provided below.

2.1 A-398s

Alcoa-designed A-398s operate by introducing smelting grade alumina into one end of 

the A-398 reactor and removing reacted alumina from the other end. The reacted alumina is used 

as feed material in the pots during the alumina reduction process. The alumina fluidizes by 

blowing clean air and potline fume exhaust into the reactor through a series of perforated plates. 

Gaseous fluoride adsorbs (and condenses) onto the alumina surface and fabric filters positioned 

on top of the reactor compartments that collect entrained alumina particles and other particulate 

matter present in the gas stream. 
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2.2 Wet Scrubbers

Wet scrubbers are open spray towers that operate by introducing water into the top of the 

tower and potline fume exhaust from the bottom of the tower. Gaseous fluoride adsorbs (and 

condenses) onto the lime/water mixture. The water and lime mixture is removed from the 

bottom of the tower and is sent to the Scrubber Water Treatment Plant for water treatment. The 

treated water from the Scrubber Water Treatment Plant is reused in the wet scrubbers. 

2.3 ESPs

ESPs operate by introducing an electrical current across a wire hanging between 

grounded plates. Potline fume exhaust passes around the charged wires and between the 

grounded plates causing the particulates to become ionized and attracted to the plates. The airentrained particulates contain fluoride. The particulates collect onto the plates that are 

periodically rapped, causing the particulates to drop to the hopper. ESP catch is removed. 

2.4 Baghouses

Baghouses operate by passing potline fume exhaust through a fabric to filter out entrained 

particulates. The air-entrained particulates contain fluoride. After the particulates have collected 

onto the filter fabric, the particulates are removed. Each baghouse exhausts to a wet scrubber.

3.0 EMISSION LIMIT

Alcoa Rockdale Operations currently operates six potlines. These potlines are defined as 

center-worked prebaked two (CWPB2) pots. Per §63.846(b), the average monthly TF emission 

limit for CWPB2 pots with 6 operating lines is 2.6 pounds of TF per ton of aluminum produced 

(lb TF/ton Al). The emission average (ET) over the six potlines are calculated per §63.846(b)(2) 

by taking the sum of the emissions from the active potlines and dividing by the total monthly 

production of the plant, as illustrated in Equation 1 below. The total emissions from each potline 

are calculated by summing the emissions from the fugitive roof emissions with the potroom 

control system emissions, as illustrated in Equation 2 below. 
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Equation 1

ET = E3 + E4 + E5 + E6 + E7 + E8

 Pn

Where:

ET = Average emission rate of TF from Rockdale Operations (lbs TF/ton Al);

E3 = Emission rate of TF from potline 3 (lb TF/month);

E4 = Emission rate of TF from potline 4 (lb TF/month)

E5 = Emission rate of TF from potline 5 (lb TF/month);

E6 = Emission rate of TF from potline 6 (lb TF/month);

E7 = Emission rate of TF from potline 7 (lb TF/month); and

E8 = Emission rate of TF from potline 8 (lb TF/month).

Pn = Aluminum production rate for all potlines (ton Al/month);

Equation 2

En = [(Cpn x Qpn) + (Cfn x Qfn)]

Where:

En = Emission rate of TF for potline n, where n equals 3 through 8 (lb TF/month);

Cpn = TF concentration from the primary control system (p) for potline n, (lb TF/dscf);

Qpn = Effluent gas volumetric flow rate from the primary control system (p) for potline n 

(dscf/month);

Cfn = TF concentration measured for secondary fugitive roof monitor emissions (f) for 

potline n, (lb TF/dscf); and

Qfn = Effluent gas volumetric flow rate from the secondary fugitive roof monitors (f) for 

potline n, dscf/month.

Total fluoride concentrations, either from the primary control system (Cpn) or from the 

roof monitor emissions (Cfn), are determined by calculating a monthly average TF concentration 

per potline using testing results obtained in accordance with the appropriate method. Effluent 

volumetric flow rates, either from the primary control system (Qpn) or from the roof monitor 

(Qfn), are determined by calculating a monthly average volumetric flow rate per potline using 

testing results obtained in accordance with the appropriate method. 

As discussed in Section 2.0, each individual potline has the same type of abatement 

equipment within the primary control system, except for potline 3. When a potline has different 

types of abatement equipment operating at variable timeframes within a month, the average 

monthly primary control system TF concentrations are accounted for the operating time of each 

type of abatement equipment. 
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4.0 APPLICABILITY AND CONTROL DEVICES

The TCEQ granted Alcoa Rockdale’s request for an extension of MACT LL applicability 

to potlines 1 through 8 until October 07, 2001. Potlines 1 and 2 were dismantled in the early 

2000s leaving Potlines 3 through 8 operational. As of October 7, 2001 MACT LL applies to 

Potlines 3 through 8 at Alcoa Rockdale. 

Primary emissions from each potline are treated through abatement equipment that 

comprise of one or two control devices per potline. Emissions generated from potline 3 are

routed through one control device consisting of three ESPs, one baghouse and eight wet 

scrubbers. Emissions from potline 4 are routed through two control devices: 1) one control 

device consists of one baghouse with four wet scrubbers, and 2) the second control device 

consists of two baghouses with five wet scrubbers. Emissions generated from potline 5 are

routed through one control device that consists of nine A-398s. Emissions generated from 

potline 6 are routed through one control device that consists of six ESPs and twelve wet 

scrubbers before venting to the atmosphere. Emissions generated from potline 7 are routed 

through two control devices – both control devices consist of six A-398s. Likewise, emissions 

generated from potline 8 are routed through two control devices that each consists of six A-398s. 

Each control device are tested to determine the appropriate number of pieces of abatement 

equipment that are required to be operational at any one time per potline to meet the average TF 

emission limit for Rockdale.

5.0 SITE-SPECIFIC TEST PLAN

Applicable emissions testing requirements of the Primary Aluminum NESHAP include 

two requirements: 1) “initial” performance testing and 2) “ongoing” performance testing. 

Following the initial performance test, “on-going” emissions testing have been implemented for 

potroom fugitive emissions and from each control device emissions. Sampling, analysis and 

quality control procedures to be used for both the initial performance test and the on-going 

compliance testing are described in this section of the Implementation Plan. 

The following subsections of this Plan were prepared pursuant to the requirements in 

§62.847(b) and comply with §63.7. Section 5.1 provides a test program summary; Section 5.2 

discusses the test schedule; Section 5.3 discusses the sampling locations; Section 5.4 discusses 

the sampling and analytical procedures; Section 5.5 provides data quality objectives; Section 5.6 

provides internal quality assurance program; Section 5.7 discusses the external quality assurance 

program; and Section 5.8 describes any exceptions to EPA methodology.
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5.1 Test Program Summary

Alcoa Rockdale currently operates six aluminum reduction potlines to which applicable 

emission limits under the Primary Aluminum NESHAP apply. Initial performance testing of the 

fugitive roof emissions and the potline control device emissions was completed in the early 

2000s as required. All previous performance tests as well as ongoing performance tests were and 

are conducted under normal operating procedures. 

On-going performance testing consists of testing fugitive roof monitor emissions and 

primary control device emissions. Fugitive roof monitor emissions are tested at least three times 

per month per potline using either EPA Method 14 (potlines 4, 6 and 8) or EPA Method 14A 

(potlines 3, 5 and 7) protocol. Potline control device emissions are tested at three emission 

points annually using EPA Method 13B. If a control device has different abatement equipment, 

then a minimum of one emission point per year is tested from each type of abatement equipment. 

Fluoride concentrations are measured in the laboratory using either EPA Method 13B or 4076.

5.2 Test Schedule

Initial performance tests on the potline primary control systems as well as fugitive roof 

monitor emissions was completed in the early 2000s.

5.2.1 Initial Performance Test

Initial performance test included conducting emissions testing on the fugitive roof 

monitor emissions and the potline control device emissions. Per §63.847(c), the “initial” 

performance tests for potroom fugitive roof emissions and the control system device emissions 

were implemented during the first month following the applicability of the Primary Aluminum 

NESHAP. Per §63.847(c), if performance tests are conducted on each primary control system 

within the 12 months prior to the compliance date, the results of that performance test may be 

used to determine initial compliance. Each initial performance test was conducted under normal 

process operating conditions. 

A minimum of three test runs were performed to determine fugitive roof emissions from 

each potline per month. In accordance with §63.847(b)(8) of the NESHAP, at least one test run 

was performed before the 15th of the month, one run was performed after the 15th and there were

be at least 6 days between two of the three runs. 
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In accordance with §63.847 of the Primary Aluminum NESHAP, a minimum of three test 

runs were performed for each potline control device. For each test run, an emission point from a 

control device (i.e., wet scrubber or A-398) was selected and tested. All of the stacks of the 

selected abatement device were sampled for an equal time period using a single sample train as 

discussed in Section 5.3.2. 

All sampling and analytical methods listed in Table 2 are in accordance with the 

requirements of §63.847of the Primary Aluminum NESHAP. Fluoride concentrations were 

determined by EPA Method 13B or Alcoa Methods 4075A/4076. Potroom fugitive TF emissions 

were measured over an entire potroom cycle (48 hours) using EPA Method 13B, 14 or 14A. 

Methods 4075A/4076 are approved EPA alternate methods for total fluoride. 

5.2.2 On-Going Compliance Tests

As required, potroom fugitive roof emissions are sampled each month and each potroom 

primary control device is tested on an annual basis. All compliance testing is conducted under 

normal process operating conditions.

A minimum of three test runs are performed monthly to determine fugitive roof emissions 

from each potline. Monthly fugitive emissions testing is performed with at least one test run 

before the 15th of the month, one run after the 15th and at least 6 days between two of the three 

runs. 

A minimum of three test runs are performed annually on each control device per 

§63.847(b)(2). For a control device that contains different types of abatement equipment, a 

minimum of tests are performed on each type of abatement equipment annually. As discussed in 

Section 5.3.2, emission points with multiple stacks are sampled on an equal time period using a 

single sample train. 

5.3 Sample Locations

Sample locations consist of roof monitors and A-398 and wet scrubber stacks. Samples 

are collected using appropriate EPA or other approved methods. Copies of the reference 

methods are provided in Appendix A.
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5.3.1 Roof Monitors

Roof monitor sampling at Alcoa Rockdale are conducted in accordance with EPA 

Method 14, Method 14A, or an alternate method approved by EPA for the measurement of 

fluoride and total airflow. 

Three of the six potlines (potlines 4, 6 and 8) at Rockdale are equipped with EPA Method 

14 sampling manifolds which are used to determine secondary total fluoride emissions. The 

sampling manifold consists of eight roof monitor nozzles connected to a downcomer duct as 

required by Method 14. The sampling location consists of a nominal 12-inch diameter duct with 

two test ports 90oapart and located greater than 10 duct diameters downstream and greater than 3 

duct diameters upstream from the nearest flow disturbance. At some future date Alcoa may 

conduct a study to demonstrate that a single sample point collects a representative sample using 

the EPA 14 protocol. A discussion of the single-point sampling study is provided in Section 5.8.

Three of the six potlines, 3, 5 and 7, are equipped with cassettes to determine secondary 

total fluoride emissions per EPA Method 14A. Eight cassettes are located at equal intervals 

across one room for each potline.

5.3.2 Potline Control Devices

Potline primary control system emissions are measured at the A-398 stacks and the wet 

scrubber stacks. There are currently two different stack and sampling location configurations on 

the A-398s. The A-398s on potline 7 and one A-398 on potline 5 have a single stack. For each 

test run, a Method 13B sample, or other appropriate method, is collected from the stack. The 

sampling location on each stack consists of two test ports 90oapart. Each duct is the appropriate 

duct diameters upstream and downstream of any flow disturbances.

The remaining eight A-398s on potline 5 and the twelve A-398s on potline 8 have three 

stacks. Devices with multiple stacks, where each stack within the control device is of similar 

design, the approach of collecting a composite sample from each stack provides a representative 

sample of the single piece of equipment. For example, each A-398 at potline 8 contains three 

stacks, referred to in this example as Stacks A, B & C. Each test run on the A-398 is conducted 

by placing a sample train on Stack A for one-third of the test time, Stack B for one-third of the 

test time, and Stack C for one-third of the test time. The sampling location on each stack 

consists of two test ports 90oapart. Each duct is the appropriate duct diameters upstream and 

downstream of any flow disturbances.
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Potfume emissions from potlines 3, 4 and 6 are tested from wet scrubber stacks using 

EPA Method 13 for total fluoride concentrations and EPA Methods 1 and 2 for air flow. Each 

wet scrubber is similar in construction and operation. Typically a wet scrubber consists of an 84-

inch diameter stack that is 96-inches high. The two sampling ports are at 90oto each other 

located approximately 60 to 72 inches downstream of the nearest flow disturbance, the top of the 

15-foot diameter scrubber tower. As discussed in Section 5.8, air flow velocities from the wet 

scrubbers are measured using an Alternate Measurement Site per EPA Method 1, Section 2.5.

5.4 Sampling/Analytical Procedures

Alcoa Method 4075A/4076 or EPA Method 13B is used to determine total fluoride 

emissions from the potroom primary control system. Total fluoride emissions from the potroom 

roof monitor are determined using EPA Method 14 or EPA Method 14A. 

5.4.1 EPA Method 13B

An EPA Method 13B sampling train is used to determine total fluoride emissions from 

the potroom control systems. The sampling train consists of a stainless-steel nozzle and probe; a 

heated quartz-fiber filter; impingers containing de-ionized (DI) water and silica gel; and an EPA 

Method 5 pump and sampling console. Sampling is performed isokinetically and the filter 

temperature is maintained at 250+25oF. A Teflon filter support may be used in place of the 

stainless steel support.

The samples are analyzed for total fluoride according to EPA Method 13B. According to 

this procedure, the particulate fraction of the sample (the particulate filter and two probe rinses) 

is dried, ashed, and fused with NaOH. The fused sample is allowed to cool and is then combined 

with the back-half or gaseous fraction prior to sample distillation and selective ion electrode 

(SIE) analysis. The analysis is carried out in a way that provides separate gaseous and particulate 

fluoride emissions.

5.4.2 EPA Method 14

According to EPA Method 14, gaseous and particulate fluoride emissions are drawn from 

the potroom roof monitor using a permanent sampling manifold with eight large nozzles. The 

sample is transported from the sampling manifold to ground level through a duct where sampling 

is performed to determine total fluoride concentrations. Effluent velocity and volumetric 

flowrate are determined using anemometers located in the roof monitor.
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As an alternative to the propeller anemometers described in Method 14, Alcoa may use 

scintillation anemometers to determine effluent velocity and volumetric gas flowrate through the 

roof monitors. Scintillation anemometers are optical-based systems that use scintillation effects 

(the apparent position or brightness of an object when viewed through the atmosphere) to 

measure path-averaged velocity. EPA has approved this methodology as an alternate method for 

determining total air flow as applicable to 40 CFR 60 Subpart LL. Appendix B contains a copy 

of the approved alternate methodology.

5.4.3 EPA Method 14A

According to EPA Method 14A, gaseous and particulate fluoride emissions are drawn 

from the potroom roof monitor into a specific cassette arrangement prior to exiting the roof. The 

cassettes are connected by tubing to flowmeters and a manifold system that allows for the equal 

distribution of volume pulled through each cassette, and finally to a dry gas meter. The cassettes 

are arranged with one unaltered cellulose filter and support pad in the first section for solid 

fluoride retention and two cellulose filters with support pads that are impregnated with sodium 

formate for the chemical absorption of gaseous fluorides in the following two sections. Effluent 

velocity and volumetric flowrate are determined using anemometers located in the roof monitor. 

Three potlines, 3, 5 and 7 have EPA Method 14A equipment installed. 

5.4.4 Alcoa Method 4075A

Total fluoride concentrations in the EPA Method 14 duct and the potline primary control 

device stacks are determined using Alcoa Method 4075A. This method is an EPA-approved 

alternative to Method 13B for the determination of total fluoride concentration. The Method 

4075A sampling train consists of a stainless steel nozzle; an in-stack cellulose thimble; stainless 

steel probe; impingers containing a 0.1N NaOH solution and silica gel; and an EPA Method 5 

pump and sampling console. 

The sample is analyzed by selective ion electrode according to Alcoa Method 4076A. 

According to this procedure, the particulate fraction of the sample (the thimble and nozzle rinse) 

is first dried, ashed, and fused with NaOH and then distilled prior to analysis by ion selective 

electrode to determine particulate fluoride. Gaseous fluoride is determined from the impinger 

solution. The solution is evaporated to dryness, and the residue is fused with NaOH, distilled 

and analyzed by ion selective electrode or automated Fanalyzer. Whereas the method allows for 

the determination of the weight fraction of particulate matter, Alcoa Rockdale has chosen not to 

take advantage of the option.
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5.5 Data Quality Objectives

Data quality objectives are the pretest expectations of precision, accuracy, and 

completeness of data. The data quality objectives for each major measurement parameter are 

presented in Table 3. The precision and accuracy objectives for particulate matter, velocity, 

temperature molecular weight, and moisture are based on results from EPA collaborative tests. 

Accuracy and precision estimates for EPA Method 13B and Alcoa Method 4075A are based on 

Alcoa’s experience with these methods. Achievement of the total fluoride objectives are

assessed on an on-going basis through the QA/QC activities described in Sections 5.6 and 5.7 of 

this test plan. 

5.6 Internal Quality Assurance Program

5.6.1 Sampling Activities

Quality control (QC) for sample collection is based on adherence to EPA Reference and 

Alcoa method requirements for equipment calibration, sample train leak checks, isokinetic 

sampling and sample recovery. Acceptance criteria specified for these activities in the applicable 

test methods are used to access data quality and validate test data. For example, pre- and posttest meter calibrations should be within +5%, sample train leak rates should be <0.02 cfm and 

sampling rates should be within 100+10% of isokinetic. 

5.6.2 Analysis Activities

Quality control (QC) for sample analysis is based on adherence to sample preparation 

procedures specified in the EPA Reference and Alcoa methods, proper instrument calibration and 

analysis of QC samples. 

Total Fluoride (Methods 13B and 4076) - Analysis for total fluoride is performed by selective 

ion electrode (SIE) using a Technicon II auto-analyzer. A 5-point calibration (zero plus four 

upscale points) is performed on the instrument with each batch of fluoride samples. Internal 

quality control consists of reagent blanks, QC sample analyses and duplicate sample analyses. 

Analysis frequencies, acceptance criteria and corrective action for the internal quality control 

samples are summarized in Table 4. The analytical QC sample is a sample of known 

concentration (approximately 0.5 ug/mL) prepared from a stock solution that is independent of 

the solution used to prepare the calibration standards. The duplicate analysis is performed by 

taking two sample aliquots from a randomly selected field sample. 
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5.7 External Quality Assurance Program

Following the initial compliance test, audit samples will be requested from EPA or the 

Texas Commission on Environmental Quality (TCEQ). These samples will be analyzed with 

samples collected in the month following the date when the performance samples are received by 

Alcoa. Performance audit samples will be requested for total fluoride (Methods 13B and 

4075A/4076A). Audit results will be reported to the TCEQ Regional Office.

5.8 Exceptions to EPA Methodology

There are two exceptions to EPA methodologies:

Single point sampling alternative to Method 14; and

Alternative Measurement Sites at the wet scrubbers.

Alcoa Rockdale will implement single-point sampling verification study to meet the 

requirements specified in EPA Method 14 Section 2.2.1. This protocol, when approved, will be 

implemented during sampling the ducts at potlines 4, 6 and 8. EPA approved Alcoa’s validation 

test conducted at another Alcoa facility. The TCEQ approved the proposed study in 1999. Alcoa 

Rockdale will conduct the validation test, per the approved plan, and submit these results to the 

TCEQ and EPA Region 6 prior to implementing the single point sampling protocol at Rockdale.

Sampling locations for all of the wet scrubbers do not meet the requirements of EPA 

Method 1. The sampling port locations are less than the minimum allowable distance of 2.0 duct 

diameters downstream of the scrubber exit and less than the minimum distance of 0.5 duct 

diameters upstream from the top of the stack. Alcoa contracted Fossil Energy Research 

Corporation of Laguna Hills, California (FERC) to conduct an alternate measurement site 

evaluation test on the wet scrubbers at Rockdale. FERC conducted three-dimensional angle and 

velocity measurement tests on the exhaust gas of six scrubber tower exhaust stacks. The tests 

were performed under the provisions of EPA Method 1, Section 2.5, in which a sample location 

that does not meet the normal Method 1 specification for distances from flow disturbances can be 

qualified as an Alternative Measurement Site. The results showed that all six stacks met the 

Method 1 criteria for acceptability as an Alternative Measurement Site. FERC concluded that 

“Because the untested stacks are identical in design and because the test results are similar for 

the stacks tested, it is Fossil Energy Research Corp’s opinion that the flow angles on all 27 

scrubber tower stacks at Rockdale meet the requirements of Method 1 to be classified as 

Alternative Measurement Sites”. A copy of this report is attached as Appendix C.
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6.0 CONTROL DEVICE MONITORING PLAN

This section of the Implementation Plan details the criteria used to select each parameter 

used to monitor the operation and maintenance of each abatement device. A discussion of the 

relationship of each parameter to control device performance, and the selected monitoring 

parameters along with the upper and/or lower operating limits, as appropriate, are included for 

the potline emission control devices at Rockdale. Table 5 summarizes the proposed monitoring 

parameters, frequencies and operating limits for the potline control devices.

6.1 Criteria For Parameter Selection

The criteria used by Alcoa when selecting the parameters to monitor each device was the 

regulatory requirement of 40 CFR Part 63.848(f), which requires the owner/operator to monitor 

the following parameters for each control device:

A-398s – alumina flow and air flow;

Wet scrubbers – water flow and air flow; and

ESPs – voltage and secondary current. 

The specific parameters proposed in this plan are measurements of control device 

operating variables that directly relate to the parameters specified by the regulation. These 

parameters are monitored for each control device during normal operating procedures. In 

addition to these parameters, per §63.848(g), the exhaust stack of each control device is inspected

daily for evidence of any visible emissions indicating abnormal operations. 

Specific upper and/or lower operating limits, as appropriate, were determined during the 

initial performance test and/or from historical data recorded during previous performance tests 

conducted with EPA-approved methods.

If a monitoring device for primary emission control devices for the potline measures a 

parameter outside of the operating limit(s) established, Alcoa will initiate corrective action 

procedures within one hour. The corrective action procedures are contained in the startup, 

shutdown, and malfunction plans located at Rockdale Operations. Per §63.848(i), only one 

parametric exceedance will be attributed to a given 24-hour period. Per EPA1, “An exceedance 

during a startup, shutdown, or malfunction is not counted provided you demonstrate that you 

operated and maintained the affected process and control equipment according to the 

procedures in your startup, shutdown, and malfunction plan. {§63.848(i)}” 

 

1 U.S. Environmental Protection Agency. Plain Language Guide to the Primary aluminum NESHAP – 40 CFR Part 

63, Subpart LL. EPA-453/R-99-011. October 1999. Page 12.
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6.2 Alumina Flow Limit

Wei reports that high alumina surface area in dry alumina scrubbers is necessary to 

achieve high hydrogen fluoride removal efficiencies.2 The surface area available for the removal 

of hydrogen fluoride is directly proportional to the amount of alumina fed into the primary 

emission control device. The A-398 system is designed to provide a large excess capacity for 

fluoride adsorption under normal operation. However, continuous operation with too low an 

alumina flow rate will result in reduced gaseous fluoride removal efficiency. Therefore, Alcoa 

established a lower limit for alumina flow for each A-398 primary control device. No upper limit 

was established for alumina flow because the addition of more alumina would only serve to 

increase fluoride adsorption capacity of the reactor bed. 

The potline control device low alumina flow limit was established by operating the 

control device at a reduced alumina flow rate for a period of approximately 24 hours. After the 

low flow conditions were established, then total fluoride emissions were sampled from the 

control device. Rotary vane feeder revolutions were used to determine alumina flow. The low 

alumina flow rate was established as cumulative hertz per potroom cycle. The length of a 

potroom cycle at Rockdale is 24 or 48 hours.

Alumina is fed to the control device using a rotary vane feeder. Rotation of the feeder is 

determined by continuously monitoring the feeder shaft using a proximity switch. In the event 

that the rotary vane feeder is shut off, a bypass valve is opened and alumina flow is manually 

adjusted. A relationship between feeder Hertz from the variable speed drive and flow meter 

pounds per hour was developed. Rockdale uses an Allen Bradley Model 160-BA03NSF1P1 

Hertz signal follower or similar system to measure the blower motor loads in amps. The 

accuracy of alumina flow rate through a rotary vane feeder depends primarily on variations in the 

bulk density of alumina, which typically varies + 5% across 6 standard deviations.

6.3 Air Flow Limit

Guidelines published by USEPA for use by States when developing fluoride emission 

standards for existing primary aluminum plants reported that exhaust rate is important for 

efficient primary fluoride collection. Exhaust rates that are too low result in low collection 

efficiency.3 Therefore, Alcoa established a lower limit for air flow to ensure the proper 

 

2

In: Anthony J. Buonicor and Wayne T. Davis, Air Pollution Engineering Manual, (New York: Van Nostrand 

Reinhold, 1992), p. 597.

3 U. S. Environmental Protection Agency. Primary Aluminum: Guidelines for Control of Fluoride Emissions from 

Existing Primary Aluminum Plants. EPA-450/2-78-049b. December 1979. p. 6-19.
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collection, operation and efficiency of the A-398 and wet scrubber primary emission control 

devices. No upper air flow limit was established because high gas flow reportedly does not cause 

a negative impact on the control system performance. High gas flow is also limited by control 

device fan capacity and normal operation is at full capacity. 

The lower air flow limit was established by operating the potroom control device at 

minimum air flow conditions. After the low air flow limits were established, the total fluoride 

emissions were sampled. A measure of fan amperage (amps) was used as a direct indicator of gas 

flow. The lower gas flow limit was established as cumulative fan amps for any potroom cycle. 

Fan amps are measured using a relay attached to each motor. 

Centrifugal blower motors are used to regulate the flow of exhaust gas to control system. 

The blower motors deliver flow that is both predictable and repeatable according to a fan curve 

that is provided by the manufacturer. The fan curve uses motor amps as a key variable to 

determine air flow expressed in cfm, or unit volume per unit time. Rockdale uses an Acromag 

Model 1701 current transmitter or similar system to measure the blower motor loads in amps. 

Typical amp meter accuracy is + 10%.

6.4 Water Flow

Water flow rate is an important parameter in wet scrubber control devices for the efficient 

primary fluoride collection. Flow rates that are too low result in low collection efficiency. Alcoa 

established a lower limit for water flow to ensure the proper collection, operation and efficiency 

of the wet scrubber primary emission control devices. No upper water flow limit was established 

because high water flow reportedly does not cause negative impact on the control system 

performance. 

The lower water flow limit was established by operating the potroom control device at 

minimum water flow condition. After the low flow conditions were established, the total 

fluoride emissions were sampled. An ultrasonic Panametrics Model XMT868 or Dynasonics 

Series 901 flow meter, or other similar device, is used to measure water flow. The lower water 

flow limit was established as cumulative gallons per minute per control device per potroom 

cycle. 

6.5 Voltage

Voltage is an important parameter in ESP control devices for the efficient primary 

fluoride collection. Voltages that are too low result in low collection efficiency. Alcoa 

established a lower limit for voltage to ensure the proper collection and operation efficiency of 

the ESP primary control devices. No high voltage limit was established because high voltage 

reportedly does not cause negative impact on the control system performance.
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The lower voltage limit was established by operating the potroom control device at 

minimum voltage condition. After the low voltage conditions were established, the total fluoride 

emissions were sampled. Voltage was measured using a Power Guard Model SQ-300 

precipitator controller or similar operating device that measures voltage at the transformer 

rectifier sets of the ESP. The lower voltage limit was established as cumulative volts per control 

device per potroom cycle. 

6.6 Secondary Current

Secondary current is an important parameter in ESP control devices for the efficient 

primary fluoride collection. Secondary currents that are too low result in low collection 

efficiency. Alcoa established a lower limit for secondary current to ensure the proper collection, 

operation efficiency of the ESP primary control devices. No high secondary current limit was

established because high secondary current reportedly does not cause negative impact on the 

control system performance.

The lower secondary current limit was established by operating the potroom control 

device at minimum current conditions. After the low current conditions were established, the 

total fluoride emissions were sampled. Secondary current is measured using a Power Guard 

Model SQ-300 precipitator controller or similar operating device that measures amps at the 

transformer rectifier sets of the ESP. The lower secondary current limit was established as 

cumulative amps per control device per potroom cycle. 

7.0 COMPLIANCE DEMONSTRATION

The initial demonstration of compliance was conducted in the early 2000s and 

submitted to both the state and federal regulatory agencies. Ongoing testing as previously 

described in this document are occurring.
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TABLES
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Table 1. Summary of Abatement Devices by Potline

Potline Equipment On the Number of Equipment Per Control EPN Numbers

Potline Control Device Abatement Equipment Roof Monitors

Devices

3

3 Electrostatic

Precipitators

8 Wet Scrubbers

1 Baghouse

1

1 ESP & 2 Wet Scrubbers

1 ESP & 2 Wet Scrubbers

1 ESP & 2 Wet Scrubbers

1 Baghouse & 2 Wet

Scrubbers

10C1, 10C2, 10C3,

10C4, 10C5, 10C6,

10C7, 10C8

F10C1,

F10C2,

F10C3,

F10C4

4

3 Baghouses

9 Wet Scrubbers 2

1 Baghouse & 4 Wet Scrubbers 10D1, 10D2,

10D8, 10D9

F10D1,

F10D2,

2 Baghouses & 5 Wet 

Scrubbers

10D3, 10D4, 10D5,

10D6, 10D7

F10D3,

F10D4

5

9 Dry Alumina

Scrubbers 1

9 Dry Scrubbers 10E1, 10E2, 10E3,

10E4, 10E5, 10E6,

10E7, 10E8, 10E9

F10E1,

F10E2,

F10E3,

F10E4

6

6 Electrostatic

Precipitators

12 Wet Scrubbers 1

6 ESPs &

12 Wet Scrubbers

10F1, 10F2, 10F3,

10F4, 10F5, 10F6,

10F7, 10F8, 10F9,

10F10, 10F11, 10F12

F10F1,

F10F2,

F10F3,

F10F4

7

12 Dry Alumina 

Scrubbers 2

6 Dry Scrubbers 10G1, 10G2, 10G3,

10G4, 10G5, 10G6

F10G1,

F10G2,

6 Dry Scrubbers 10G7, 10G8, 10G9,

10G10, 10G11, 10G12

F10G3,

F10G4

8

12 Dry Alumina 

Scrubbers 2

6 Dry Scrubbers 10H1, 10H2, 10H3,

10H4, 10H5, 10H6

F10H1,

F10H2,

6 Dry Scrubbers 10H7, 10H8, 10H9,

10H10, 10H11, 10H12

F10H3,

F10H4
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Table 2. Summary of Sampling and Laboratory Test Methods

Potline Parameter Roof Monitors

EPA Sample Collection 

Method

Control Device

EPA Sample Collection 

Method

EPA Laboratory

Test Method

3 Fluoride 14A 13B or 4075A 13B or 4076A

Air Flow

Scintillation 

Anemometer (1) 1 and 2 NA

4 Fluoride 14 13B or 4075A 13B or 4076A

Air Flow

Scintillation 

Anemometer (1) 1 and 2 NA

5 Fluoride 14A 13B or 4075A 13B or 4076A

Air Flow

Scintillation 

Anemometer (1) 1 and 2 NA

6 Fluoride 14 13B or 4075A 13B or 4076A

Air Flow

Scintillation 

Anemometer (1) 1 and 2 NA

7 Fluoride 14A 13B or 4075A 13B or 4076A

Air Flow

Scintillation 

Anemometer (1) 1 and 2 NA

8 Fluoride 14 13B or 4075A 13B or 4076A

Air Flow

Scintillation 

Anemometer (1) 1 and 2 NA
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Table 3. Summary of Estimated Accuracy and Precision Objectives

Parameter (Method) Precision Accuracy

Total Fluoride

(Method 13B)

±10%b±15%c

Total Fluoride

(Method 4075A/4076A)

±10%b±15%c

Velocity/volumetric flow

(Methods 1 and 2)

±6%a±10%a

Gas Molecular Weight

(Method 3)

±10%

a

±20%a

Gas Moisture Content

(Method 4)

±20%a±10%a

a Precision and accuracy estimates based on results of EPA collaborative tests.

b Relative percent difference (RPD) based on duplicate analyses, where

[(First_Value)1- (Second_Value)2]*2

 RPD= ______________________________ x 100%

 (First_Value)1 + (Second_Value)2

c Relative error (%) for control sample analyses, where

 Measured_Value – Theoretical_Value

Relative error = __________________________________ x 100%

Theoretical_Value

d Procedures for this method similar to EPA Method 5. Precision and accuracy estimated based on EPA collaborative tests for Method 5.
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Table 4. Summary of Internal Quality Control Checks, Frequencies, Acceptance Criteria

and Corrective Action for Total Fluoride Analysis

Quality Control Check Frequency Acceptance Criteria Corrective Action

Filter reagent blank

(M13B)

Once per lot of 

filters

<0.015 mgF/cm2

1. Repeat reagent blank

2. Obtain alternate supply of low-F filters

3. Repeat reagent blank

Thimble reagent blank

(4076A)

One every 3 

months

<0.8 mgF/thimble

1. Repeat reagent blank

2. Obtain alternate supply of cellulose 

thimbles

3. Repeat reagent blank

NaOH reagent blank

(0.1N NaOH solution –

4076A)

One every 3 

months

≤0.06 mg/L

1. Repeat reagent blank

2. Obtain alternate supply of NaOH

3. Repeat reagent blank

QC sample analysis

Once with each 

batch of 

samples

±15% agreement with 

QC value

1. Repeat QC sample analysis

2. If still unacceptable, repeat instrument 

calibration

Duplicate analysis

Once with each 

batch of 

samples

Relative percent 

difference of ±10%

1. Repeat duplicate analysis

2. If still unacceptable, service instrument
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Table 5. Potroom Parametric Monitoring

Parameter Measurement Compliance Frequency

Alumina Flow Rotary Vane Feeder Operations Cumulative cycles (hertz) per control device 

per potroom cycle

Air Flow Fan Amperage Cumulative amps per control device per 

potroom cycle

Water Flow Water Flow Meters

Cumulative gallons per control device per 

potroom cycle

ESP Primary Voltage Volt Meter in Motor Control Centers

Cumulative volts per control device per 

potroom cycle

ESP Secondary Current Amp Meter in Motor Control 

Centers

Cumulative ESP Milliamps per potroom 

cycle
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FIGURES
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Potline_Diagrams 

MACT.xls
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APPENDIX A

EPA TEST METHODS
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METHOD_13b.pdf METHOD_14.pdf METHOD_14A.pdf METHOD_4075A-Thi

mble.pdf

METHOD_4076A-94.

pdf

EPA Approval 

Method 4075A 4076.pdf
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APPENDIX B

EPA-APPROVED ALTERNATE AIR FLOW METHODOLOGY
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EPA Approved Alt Air 

Flow Meth.pdf
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APPENDIX C

ALTERNATE MEASUREMENT SITE STUDY
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Alt Measurement Site 

Study.pdf