United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park, NC 27711
EPA-453/R-99-011
October 1999
www.epa.gov/ttn/uatw/
EPA
Plain Language Guide to the Primary Aluminum
NESHAP - 40 CFR Part 63, Subpart LL
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Plain Language Guide to the
Primary Aluminum NESHAP
40 CFR Part 63, Subpart LL
Prepared for:
Emission Standards Division (BSD)
Policy, Planning, and Standards Group (PPSG)
and
Information Transfer and Program Integration Division (ITPID)
Program Review Group (PRG)
Office of Air Quality Planning and Standards
U. S. Environmental Protection Agency
Research Triangle Park, NC 27711
October 1999
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What is the legal status of this guide?
The Office of Air Quality Planning and Standards (OAQPS) of the U. S. Environmental Protection Agency
(EPA) has reviewed this document and approved it for publication.
When using this document, remember that it isn't legally binding and doesn't replace the final rule -
"National Emission Standard for Hazardous Air Pollutants for Primary Aluminum Reduction Plants"
(published in the Federal Register, 10/7/97, 62 FR 52407) or any State, local or tribal rules that may
apply to your facility.
This document isn't intended, nor can you rely on it, to create any rights enforceable by any party in
litigation with the United States. The EPA may change this document at any time without public notice.
This document includes only requirements from the final rule published in the Federal Register 10/7/97, 63
FR 52407.
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Thank You
This document was prepared by a joint partnership among the Environmental Protection
Agency (EPA, or we), State and local agencies for air pollution control, trade associations, and
organizations who produce primary aluminum. At the time of publication, the development
team (including reviewers) had the following members:
Marsha Branscome, Research Triangle Institute
Laura Coleman, Reynolds Metals
Steve Fruh, EPA, OAQPS, BSD
Mike Palazzolo, ALCOA
Robert Stricter, The Aluminum Association
Ingrid Ward, EPA, OAQPS, ITPID
Member Companies of The Aluminum Association
We thank those people for their participation. Their technical insights, experiences, and
suggestions were essential to this guide's development.
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TABLE OF CONTENTS
CHAPTER 1 - Introduction
Why should I use this document? 1
Is there anything I should know before using this document? 1
How do I get copies of this document? 1
We want your feedback 2
CHAPTER 2 - What this rule covers - An Overview
Why was this rule written? 4
How do I know if I'm subject to this rule? 4
Are any processes exempt? 4
How do I know if I have an affected source? 4
What are my requirements for affected sources? 5
When do I need to comply? 5
What pollutants am I emitting? 5
CHAPTER 3 - Complying with requirements for potlines
What do the potline sections of the rule cover? 9
What is exempt under these sections of the rule? 9
Do I have any compliance options? 9
What emission limits must I meet? 10
What monitoring must I do? 12
What records must I keep? 12
What plans and reports must I prepare? 13
How do I show compliance? 13
in
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TABLE OF CONTENTS
CHAPTER 4 - Complying with requirements for anode bake furnaces
What is covered under these sections of the rule? 25
What is exempt under these sections of the rule? 25
Do I have any compliance options? 25
What emission limits must I meet? 25
What monitoring must I do? 26
What records must I keep? 27
What plans and reports must I prepare? 27
How do I show compliance? 27
CHAPTER 5 - Complying with requirements for paste production plants
What is covered under this section? 33
What is exempt under this section? 33
What are the requirements for paste production plants? 33
Do I have any compliance options? 34
What monitoring must I do? 34
What records must I keep? 35
What plans and reports must I prepare? 35
How do I show compliance? 35
CHAPTER 6 - Complying with requirements for new pitch storage tanks
What is covered under this section? 39
What is exempt under this section? 39
What are the requirements? 39
Do I have any compliance options? 39
iv
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TABLE OF CONTENTS
What monitoring must I do? 40
What records must I keep? 40
What plans and reports must I prepare? 40
How do I show compliance? 41
CHAPTER 7 - Calculations, test methods, and procedures
What test methods do I use for TF and POM? 45
How do I get approval to use an alternative test method? 46
What are my requirements for conducting a performance test? 46
How do I sample if I have many stacks for a single control device or several control devices
for a single process? 46
What alternatives are there for performance testing? 46
How do I calculate my emissions when I am using emission averaging? 47
How do I calculate my emission limits if I incorporate the NSPS into
my subpart LL requirements? 47
How do I calculate my TF emissions if I incorporate the NSPS into
my subpart LL requirements? 48
What procedures do I use for new pitch storage tanks? 49
CHAPTER 8 - Plans, notifications, reports, and requests for alternatives
What is a site-specific test plan? 57
What is a continuous parameter monitoring plan? 60
What is an implementation plan for emissions averaging? 60
What is an engineering plan? 61
What is a startup, shutdown and malfunction plan? 61
What do I have to report and when? 62
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TABLE OF CONTENTS
What alternatives are available and how do I request one? 62
Can I change the date my reports are due? 63
Where do I send my reports? 64
Is there a time limit for the regulatory authority to approve or deny my requests? 64
Are example reporting forms available? 65
CHAPTER 9 - Other requirements and information
Who administers this regulation? 88
Are plants in Indian Country regulated by the State? 88
Do I need a title V permit? 88
How do I change my permit to include this rule? 89
What portions of the General Provisions apply? 89
CHAPTER 10- Getting additional help
Whom can I ask for help? 90
Can I get more information on the Web? 91
CHAPTER 11- Supplemental information for State or local agencies and Tribes
How many plants may need to meet the emission limits? 93
How much HAP emissions will the rule reduce? 93
VI
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TABLE OF CONTENTS
LIST OF FIGURES
Figure 2.1 Subpart LL, Does it Apply to Me? 6
Figure 2.2 Compliance Timeline 8
Figure 8.1 Potline Roof Monitor Sampling Options 59
Figure 11.1 There are 23 Primary Aluminum Plants in 14 States 95
Figure B.I Process Flow Diagram for a Soderberg Plant 103
Figure B.2 Process Flow Diagram for a Prebake Plant 104
Figure B.3 Schematic of a Soderberg Paste Plant 105
Figure B.4 Schematic of Prebake Anode Preparation 105
Figure B.5 Ring Furnace Layout 107
Figure B.6 Schematic of Types of Reduction Cells 109
LIST OF TABLES
Table 2.1 Quick Reference Compliance Guide 7
Table 3.1 What Emission Limits Must Existing Prebake Potlines Meet? 14
Table 3.2 What Emission Limits Must Existing Soderberg Potlines Meet? 15
Table 3.3 Monitoring Requirements for Potlines 16
Table 3.4 Recordkeeping Requirements for Potlines 21
Table 3.5 Notifications and Reports for Potlines 24
Table 4.1 What Emission Limits Must Existing Anode Bake Furnaces Meet? 28
Table 4.2 Monitoring Requirements for Anode Bake Furnaces 29
Table 4.3 Recordkeeping Requirements for Anode Bake Furnaces 31
Table 4.4 Notifications and Reports for Anode Bake Furnaces 32
Table 5.1 Monitoring Requirements for Paste Production Plants 36
vii
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TABLE OF CONTENTS
Table 5.2 Recordkeeping Requirements for Paste Production Plants 37
Table 5.3 Notifications and Reports for Paste Production Plants 38
Table 6.1 Monitoring Requirements for New Pitch Storage Tanks 42
Table 6.2 Recordkeeping Requirements for New Pitch Storage Tanks 43
Table 6.3 Notifications and Reports for New Pitch Storage Tanks 44
Table 7.1 Methods for Sampling for TF and POM 45
Table 7.2 Performance Test Requirements for Potlines 50
Table 7.3 Performance Test Requirements for Anode Bake Furnaces 53
Table 7.4 How Do I Qualify for a Monitoring Alternative? 54
Table 8.1 Due Dates for Notifications and Reports 66
Table 8.2 Reporting Requirements 69
Table 10.1 EPA Regional Air Division Offices 92
Table 11.1 Primary Aluminum Reduction Plants in the U.S 94
Appendices
A - Subpart LL, Final Rule 96
(Includes an index for the rule cross referenced to the Federal Register notice by page and column
number as well as rule section numbering)
B- Description of the Process and Emission Points 101
C- Site-Specific Test Plan Outline Ill
Vlll
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List of Acronyms and Abbreviations
ACGIH American Conference of Governmental Industrial Hygienists
ALAPCO Association of Local Air Pollution Control Officials
CAA Clean Air Act (of 1990)
CFR Code of Federal Regulations
CEM Continuous Emission Monitor
CWPB Center Worked Prebake
EPA Environmental Protection Agency
ESD Emission Standards Division (of OAQPS)
FR Federal Register
F£AP Hazardous Air Pollutant
HF Hydrogen Fluoride or Hydrofluoric Acid
HSS Horizontal Stud Soderberg
ITPID Information Transfer & Program Integration Division (of OAQPS)
kg kilograms
Ib pounds
MACT Maximum Achievable Control Technology
NESHAP National Emission Standards for Hazardous Air Pollutants
NTIS National Technical Information Services
OAQPS Office of Air Quality Planning and Standards
OECA Office of Enforcement and Compliance Assurance
OSHA Occupational Safety and Health Administration
POM Polycyclic Organic Matter
PTE Potential to Emit
SSMP Startup, Shutdown and Malfunction Plan
STAPPA State and Territorial Air Pollution Program Administrators
SWPB Side Worked Prebake
TF Total Fluoride
TTN Technology Transfer Network
UATW Unified Air Toxics Website
VSS Vertical Stud Soderberg
WWW World Wide Web
IX
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Chapter 1 - Introduction
Why should I use this document?
This document can help you understand the requirements for the Primary Aluminum NESHAP (also
known as subpart LL) by helping you determine:
! if the subpart applies to your facility and process;
! what compliance options are available;
! what recordkeeping, reporting and monitoring requirements you must follow; and
! the date you must come into compliance with the subpart and other important deadlines.
Is there anything I should know before using this document?
When using this document, remember that it doesn't replace the final rule and covers only requirements
published on or before 10/7/97. You should keep up with new requirements printed after this date by
periodically checking the Federal Register and the
Code of Federal Regulations (CFR). You can ^^^^^^^^^^^^^^^^^^^^^^^^^^^m
, i j T- j i T> • * j.- u -j. j.1 Keep informed of rule changes by checking the Federal
download Federal Register notices by going to the „
Register
Government Printing Office (GPO) website at ^^^^^^^^^^^^^^^^^^^^^^^^^^^^^_
www.access, gpo. gov/su_docs/aces/acesl 40. html.
We've included a copy of the final rule in Appendix A (as published in the Federal Register, 10/7/97, 62
FR 52384), so you can reference the rule while you're using this document.
How do I get copies of this document?
You can get copies of this document in four ways:
! EPA's Unified Air Toxics Website (www.epa.gov/ttn/uatw). Look under Rules and
Implementation, Primary Aluminum
! Library Services Office, (MD-35), U.S. EPA, Research Triangle Park, NC 27711, or
www.epa.gov/natlibra/ols.html (limited supply)
! National Technical Information Services (NTIS), 5285 Port Royal Road, Springfield, VA 22161,
or 1-(800)- 553-6847, or www.fedworld.gov/ntis/ntishome.html (NTIS will charge you a fee for
this document)
! National Center for Environmental Publications and Information, 1-(800)-490-9198 or
www.epa.gov/ncepihom/index.html
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We want your feedback
To serve you better, we've included a survey on the usefulness of this document. If you'd like to
participate, please fill out the survey on page 3 and return it to the address indicated. We'll keep your
responses confidential if you desire, but use them to help us improve future documents.
Help us publish better documents by filling out our
survey
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Survey on the Plain Language Guide to the Primary Aluminum NESHAP
Please help us gauge the usefulness of this document by completing this short form. Your response will be kept
confidential. Your judgment of the document's utility will help EPA to decide how to improve it.
1. What type of business do you work for? (check one of the following)
Manufacturing n Contractor n Tribe n
Government (specify Federal, State, local) Other
2. What are your job responsibilities? (check any of the following that apply)
Plant Operator n Maintenance n Plant Manager n
Environmental Staff n Other:
3. How did you hear about this guidance? (check one of the following)
Co-worker n EPA TIN via dial up modem n EPA TTN via the Web n
Other
Please indicate your agreement with the following statements from 1= Strongly Agree to 5 = Strongly Disagree
Statement
The guidance was timely.
The document provides a good overview of the rule.
This document provides the type information that my organization needs to comply.
The guidance helped us achieve compliance more quickly than if we had developed
our own.
Portions of this document have been incorporated into internal policy documents.
The format of this document was well organized and easy to understand.
1
2
3
4
5
N/A
4. What did you like about this document or what helped you the most? (be as specific as you can)
5. What did you not like about this document or what helped you the least? (be as specific as you can)
6. What would you change about this document (e.g. formats, excluding information or including things that you did not
find in the document)?
7. Did you find the overall usage of this document to be:
extremely useful n very useful n
8. Other comments:
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not useful at all
Provide additional comments on the back of this form or on a separate paper.
Return survey to : ATTN: Primary Aluminum Implementation Contact, U.S. Environmental Protection Agency
(EPA), Research Triangle Park (RTP) MD-12, Research Triangle Park, NC 27711, or fax (919) 541-2664
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Chapter 2 - What this rule covers - An Overview
Why was this rule written?
We wrote this rule to reduce hazardous air pollutants and achieve the environmental benefits intended by
the Clean Air Act (CAA) of 1990.
Our research has shown that emissions from a typical production plant may include a number of HAPs.
The most significant HAPs from primary aluminum processes are hydrogen fluoride (HF) and polycyclic
organic matter (POM).
How do I know if I'm subject to this rule?
You are subject to subpart LL if you:
! Are a major source of HAPs as defined in 40 CFR 63.2; and
! Produce primary aluminum by the electrolytic reduction process.
You can use Figure 2.1 to help determine if you are subject to this subpart.
Are any processes exempt?
Subpart LL covers all major source plants that manufacture aluminum by electrolytic reduction. No
primary aluminum processes are exempt. The rule does not cover reduction cells used solely for research
and development purposes or secondary aluminum manufacturing processes. Appendix B describes the
primary aluminum manufacturing process.
How do I know if I have an affected source?
The rule applies to the following affected sources located at a primary aluminum reduction plant that is a
major source: each new pitch storage tank and each new or existing potline, paste production plant, or
anode bake furnace. It does not apply to one bake furnace in Louisiana that does not have a primary
aluminum production plant (i.e., a potline) onsite. This bake furnace is subject to the State's MACT
determination.
Subpart LL also applies to each new pitch storage tank (for which construction commenced on or after
September 26, 1996). Subpart LL does not apply to existing pitch storage tanks, which are those for
which construction commenced before September 26, 1996.
See Appendix B for a detailed description of each type of affected source.
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What are my requirements for affected sources?
All types of potlines must meet an emission limit for total fluoride (TF). Soderberg potlines must meet an
emission limit for poly cyclic organic matter (POM). Each anode bake furnace must meet limits for both
TF and POM. Provisions also are included for emission averaging by existing potlines and anode bake
furnaces. New pitch storage tanks must reduce POM emissions by 95 percent, and all paste production
plants must be controlled by a dry coke scrubber or approved alternative control device. The rule also
contains requirements for certain types of potlines associated with a new, modified, or reconstructed
potroom group.
The rule also includes requirements for an initial performance test, periodic source testing, monitoring of
emission control device operating parameters, recording of process malfunctions and corrective actions,
and regular reporting of compliance status. Table 2.1 gives a quick reference compliance guide for the
major requirements. Details on the specific requirements for each type of affected source are given in
sections 3, 4, 5 and 6.
When do I need to comply?
If you are an existing source, you must comply with this subpart by October 7, 1999, unless you receive
an extension of the compliance date from the regulatory authority. If you have an existing affected source
or facility or part of a facility that was shutdown at the time compliance would have otherwise been
required, you must provide written notification to your regulatory authority before you begin startup and
demonstrate compliance within 180 days. If you demonstrate to the satisfaction of the regulatory authority
that you need additional time to install or modify emission control equipment, subpart LL allows you to
delay compliance until October 9, 2000. In addition, § 63.6(i)(4) of the NESHAP General Provisions in
40 CFR part 63, subpart A allows the regulatory authority to grant an additional year if it is needed to
install controls, which would extend the compliance date to October 8, 2001. In general, the phrase "for
installation of controls" includes add-on control devices such as scrubbers or incinerators (as well as other
means of reducing air toxics such as pollution prevention, work practices, or operational standards that are
defined as control requirements by the rule) or the installation of technology hardware or software systems
that are ancillary equipment required to properly operate and monitor required pollution control equipment.
If you are a new source, you must comply upon startup. Figure 2.2 outlines important compliance and
reporting dates.
What pollutants am I emitting?
Research by the EPA has shown that HAP emissions from primary aluminum production facilities include
(but are not limited to) hydrogen fluoride (HF) and polycyclic organic matter (POM). Short-term
inhalation exposure to gaseous HF and related fluoride compounds can cause severe respiratory damage in
humans. Long-term inhalation exposure to low levels of HF by humans has been reported to result in
irritation and congestion of the nose, throat, and bronchi while damage to liver, kidney, and lungs has been
observed in animals. POM includes a combination of polycyclic aromatic hydrocarbons (PAHs) such as
anthracene, benzo(a)pyrene, and naphthalene, among others. Several of the PAH compounds, including
benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, benzo(k)fluoranthene, chrysene,
dibenzo(a,h)anthracene, and indeno(l,2,3-cd)pyrene, are probable human carcinogens, and cancer is the
major concern from exposure to these PAHs.
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Figure 2.1 Subpart LL: Does It Apply to Me?
You are a major source if you have the
potential to emit more than 10 tons per year
of any one HAP or 25 tons per year of multiple
HAP. All other sources are area sources.
To determine if you are a major source, base your
determination on all HAP emission points inside
the plant fenceline, not just primary aluminum
production facilities.
Is your facility a
major source?
Is your facility associated
with primary aluminum
production and located at a reduction
facility?
Does your facility nave a new
pitch storage tank, or a new or
existing potline, bake
furnace, or paste
plant?
Subpart LL
does not apply
to your facility
Subpart LL
does not apply
to your facility
Primary aluminum is produced
by the reduction of alumina in
groups of electrolytic cells called
"potlines"
Subpart LL
does not apply
to your facility
£ Subpart LL does apply to
your facility
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Table 2.1 Quick Reference Compliance Guide
Source
Paste production plant
Mixing through pressing,
hot green scrap,
excluding pitch tank
Anode bake furnace
Control device only
Potrooms
Reports
Pollutant
POM
POM
TF
TFand
POM
Standard
Equipment
0.181bPOM/ton
green carbon
0.20 Ib TF/ton
green carbon
TF limits for
prebake (see Table
3-1) and TF/POM
limits for
Soderbergs (see
Table 3-2)
Compliance/Testing
Parametric monitoring
Daily visual opacity inspections
Annual
Annual
Parametric monitoring
Daily visual opacity inspections
Roof Monitor
TF: 3 runs/month minimum - first
potline type. Similar potline options
POM: 3 runs/quarter minimum
Primary Control System (TF and POM)
(1) test/year/potline control device
Parametric monitoring
Daily visual opacity inspections
Notification of applicability
Annual compliance certification
Semi-annual if excess emissions
Method
Preferred / Alternate
Coke scrubber: coke and air flow
measurement
EPA Method 3 15
EPA Method 13 A or 13B
Alumina scrubber: alumina and air flow
measurements
TF: EPA Method 14 or 14A (Alcan
cassette); POM: EPA Method 315
TF:EPA Method 13A or B
POM: EPA Method 3 15
Alumina scrubber: alumina and air flow
Wet scrubber: water and air flow
ESPs: voltage and secondary current
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Figure 2.2 Compliance Timeline (for new sources and plants that must comply in 2 years)
Existing sources
with startup
before 9/26/96
T
By 2/4/98
6 months before intended
compliance with
averaging
60 days before test;
no later than 9/7/99
10/7/99
By 11/6/99
Within 60 days after the
test; no later than 1/5/00
By 30th day following
end of each calendar half
(6 months)
By 30th day following
end of each calendar year
Effective
date: 10/7/97
Initial notification
report
Implementation plan for
emission averaging
Notification of planned
performance test; submit
test plan (if requested)
Notification of compliance
status and report of initial
performance test
Excess emissions
reports (if any)
New sources
with initial
startup after
9/26/96
Within 120 days
of startup
New sources
cannot average
60 days before
the test
Annual report
Upon startup
Within 30 days
following compliance
date
Within 60 days after
the test
By 30th day following
end of each calendar half
(6 months)
By 30th day following
end of each calendar year
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CHAPTER 3 - Complying with requirements for potlines
What do the potline sections of the rule cover?
Different emission limits may apply to your potline according to the type of aluminum production process.
The different types of processes are described in Appendix B. The potline sections of the rule cover
existing potlines, new or reconstructed potlines, and new, modified, or reconstructed potroom groups.
If you are interested in this requirement
See this section of rule for
more information...
TF and POM emission limits for an existing potline
TF and POM emission averaging limits and requirements for multiple
existing potlines
TF and POM emission limits for a new or reconstructed potline
Incorporation of NSPS for potroom groups
Performance test requirements
Emission monitoring when incorporating the NSPS
Emission monitoring for a potline
Notifications, records, and reports
§ 63.843(a)
§ 63.846, Tables 1 and 2
§ 63.844(a)
§ 63.845
§ 63.847
§ 63.848
§ 63.848
§63.850
What is exempt under these sections of the rule?
No potlines are exempt under the rule.
Do I have any compliance options?
If you have an existing potline, you have two main regulatory options:
! Option 1: Meet the emission limits for each individual potline. [§ 63.843(a)]
! Option 2: Average emissions from multiple existing potlines and meet limits based on the
number of potlines in a group. [§ 63.846(b)]
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What emission limits must I meet?
Table 3.1 shows TF emission limits (Ib/ton of aluminum produced) for all existing prebake and Soderberg
potlines Table 3.2 shows POM emission limits for existing Soderberg potlines. These tables give the
emission limits for individual potlines and for emission averaging.
The emission averaging limits are based on the number of potlines in the group. If you choose to use
emission averaging:
! Averaging is restricted to like sources (TF emissions from a potline can be averaged only
with TF emissions from a potline at the same site)
! Averaging of TF and POM emissions is not allowed
! Only existing potlines can use emission averaging
! Emission averaging is not allowed in any State that excludes this option from its approved
operating permit program.
! Your regulatory authority must approve an implementation plan before you begin emission
averaging.
Tables 3.1 and 3.2 also show the plants assigned to each category or subcategory. If you change a potline
(except for a reconstructed potline) such that the applicable subcategory also changes, you must meet the
emission limit for the original subcategory or the new subcategory, whichever is more stringent.
A new or reconstructed potline must meet a TF limit of 1.2 Ib/ton of aluminum produced and a POM
limit of 0.63 Ib/ton of aluminum produced. The TF limit applies to all types of potlines while the POM
limit applies to all Soderberg potlines.
What are the key definitions?
New potline A potline for which you commence
construction on or after September 26, 1996
Reconstructed potline An existing potline where the capital cost of
the new components is over 50 percent of the
capital cost required to construct a
comparable new potline or potline group and
it is technologically and economically
feasible to meet the applicable emission
limits for new sources
Different emission limits apply if you incorporate the the NSPS requirements. If you have an existing
Soderberg, CWPB2, or CWPB3 potline and you add a new potline group or your existing potline is
associated with a potroom group that meets the definition of modified potroom group or reconstructed
potroom group, you can not exceed a lower or upper TF emission limit that you calculate using the
10
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procedures in the rule. Chapter 7 shows how to calculate these limits. A 10-percent opacity limit also
applies unless your regulatory authority approves an alternative opacity limit.
! If you exceed the upper limit for TF, you will be considered in compliance if you
demonstrate that exemplary operation and maintenance were used with respect to the
emission control system and that proper control equipment was operating at the potline at
the time.
! You must recalculate the TF emission limits each time a new potroom group is added to
the potline and each time an additional potroom group meets the definition of "modified
potroom group" or "reconstructed potroom group".
What are the key definitions?
Potroom group
Modified potroom group
Reconstructed potroom group
Uncontrolled potroom, potroom that is
controlled individually, or a group of
potrooms or potroom segments ducted to a
common control system
Existing potroom group to which any
physical change in, or change in the method
of operation of, results in an increase in the
amount of TF emitted into the atmosphere by
that potroom group. See § 63.845(a)(l) for
activities and operations that are not, by
themselves, considered to result in a potroom
group modification.
Existing potroom group for which the
components are replaced to such an extent
the fixed capital cost exceeds 50 percent of
the fixed capital cost that would be required
to construct a comparable entirely new
potroom group and for which it is
technologically and economically feasible to
meet the applicable TF emission limit
What monitoring must I do?
Your major monitoring requirements include:
Monthly measurements of TF secondary emissions (unless you get a monitoring
alternative) with annual measurements of primary emissions [63.848(a)]
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! Quarterly measurements of POM secondary emissions from each Soderberg potline with
annual measurements of primary emissions [63.848(b)]
! Continuous parameter monitoring system for each emission control device [63.848(f)]
! Monitoring device(s) to determine the daily weight of aluminum produced [63.848(j)J
! Daily visual inspection of the exhaust stack(s) of each control device for evidence of any
visible emissions indicating abnormal operation [63.848(g)J
! Daily inspection of wet roof scrubbers for secondary emission control [63.848(f)(5)]
! Initiate corrective action within 1 hour if a monitoring device for a primary control device
measures an operating parameter outside the limit(s) established, if visible emissions
indicating abnormal operation are observed during daily inspection, or if a problem is
detected during the daily inspection of a wet roof scrubber for secondary emission control
[§ 63.848(h)]
! Do not allow the control device operating limit to be exceeded more than six times in a
semi-annual reporting period. Only one violation will be attributed to a given 24-
hour period. 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)]
Table 3.3 gives you details about your monitoring requirements. See Chapter 7 for more information on
test methods, procedures, and how to make the calculations.
What records must I keep?
You must keep records documenting information needed to assess whether you have complied with the
limits and requirements for potlines. Table 3.4 gives a detailed list of record requirements for potlines.
You can keep records on microfilm, on a computer, on computer disks, on magnetic tape or microfiche.
You must keep each record for at least 5 years after the date it was made. You can keep the most recent 2
years of records at your facility, but you can store the other records offsite.
What plans and reports must I prepare?
You may be required to prepare up to five types of plans:
! Site-specific test plan. You must prepare a plan but you don't have to submit it for
approval unless requested by your regulatory authority. [§§ 63.7 and 63.847(b)]
! Startup, shutdown, and malfunction plan. You must prepare and implement a plan but
you don't have to submit it for review unless requested by your regulatory authority.
12
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While you don't have to include the plan in your permit application or operating permit
you must incorporate it by reference in your permit. [§§ 63.6(e)(3) and 63.850(c)]
! Continuous Parameter Monitoring Plan. You must submit this plan to your regulatory
authority for approval as part of the notification of compliance status.
[§ 63.848(f)]
! Monitoring device accuracy and calibration. You must submit recommended accuracy
requirements to your regulatory authority for approval as part of the notification of
compliance status. You also must certify that all devices meet the accuracy requirements.
You must calibrate each monitoring device according to the manufacturer's instructions. [
§ 63.848(k)]
! Implementation Plan for Emissions Averaging. This plan is required only if you elect to
meet the emission limits for averaging emissions from multiple existing potlines.
[§ 63.846(d)]
! Engineering Plan. This plan may be required as part of your notification of compliance
approach. You must submit the plan if requested by your regulatory authority.
[§ 63.850(a)(8)]
You also must provide certain written notifications and make one-time or periodic reports. The
notifications and reports that may apply to potlines are listed in Table 3-5. Chapter 8 describes each type
of plan or report that you must prepare.
How do I show compliance?
First, you must prepare a site-specific test plan. See Chapter 8 for detailed information on the
requirements for your site-specific test plan.
Then, do an initial performance test to show that you meet the limits. The rule requires that you begin the
performance tests starting the first month after your compliance date. Follow the procedures in your site-
specific test plan as well as the procedures in 40 CFR 63.7 and the rule. Chapter 7 explains how to do
the performance test and gives additional information on test methods and calculation procedures.
13
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Table 3.1 What Emission Limits Must EXISTING PREBAKE POTLINES Meet?
CWPBl
Alcan, Henderson, SC
Alcoa, Alcoa, TN
Alcoa, Badin, NC
Alcoa, Wenatchee, WA
Alumax, Mt. Holly, SC
Noranda, New Madrid, MO
I
Meet limit for each line:
I
1.9 Ib/ton TF
Or use emission averaging:
I
No. of
potlines Ib/ton TF
2 1.7
3 1.6
4 1.5
5 1.5
6,7,8 1.4
CWPB2
Alcoa, Rockdale, TX
Kaiser, Mead, WA
Ormet, Hannibal, OH
Century, Ravenswood, WV
Reynolds, Troutdale, OR
Vanalco, Vancouver, WA
I
Meet limit for each line:
I
3.0 Ib/ton TF
Or use emission averaging:
I
No. of
potlines Ib/ton TF
2 2.9
3 2.8
4 2.7
5 2.7
6, 7, 8 2.6
CWPB3
NSA, Hawesville, KY
I
Meet limit for each line:
I
2.5 Ib/ton TF
Or use emission averaging:
I
No. of
potlines Ib/ton TF
2 2.3
3 2.2
4 2.2
5 2.1
6,7,8 2.1
SWPB
Eastalco, Frederick, MD
Intalco, Ferndale, WA
I
Meet limit for each line:
I
1.6 Ib/ton TF
Or use emission averaging:
I
No. of
potlines Ib/ton TF
2 1.4
3 1.3
4 1.3
5 1.2
6,7,8 1.2
14
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Table 3.2 What Emission Limits Must EXISTING SODERBERG POTLINES Meet?
HSS
Kaiser, Tacoma, WA
Reynolds, Longview, WA
Reynolds, Massena, NY
I
Meet limit for each line:
\
2.7 Ib/ton TF
4.7 Ib/ton POM
Or use emission averaging:
\
No. of Ib/ton Ib/ton
potlines TF POM
2 2.5 4.1
3 2.4 3.8
4 2.4 3.7
5 2.3 3.5
6 2.3 3.5
7 2.3 3.4
8 2.3 3.3
VSS1
Goldendale, Goldendale, WA
Northwest, The Dalles, OR
I
Meet limit for each line:
\
2.2 Ib/ton TF
2.4 Ib/ton POM
Or use emission averaging:
\
No. of Ib/ton Ib/ton
potlines TF POM
2 2.0 2.1
3 1.9 2.0
4 1.8 1.9
5 1.7 1.9
6 1.7 1.8
7 1.7 1.8
8 1.7 1.8
VSS2
Columbia Falls, Columbia Falls, MT
I
Meet limit for each line:
\
2.7 Ib/ton TF
3.6 Ib/ton POM
Or use emission averaging:
\
No. of Ib/ton Ib/ton
potlines TF POM
2 2.6 3.2
3 2.5 3.0
4 2.5 2.9
5 2.4 2.9
6 2.4 2.8
7 2.4 2.8
8 2.4 2.7
15
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Table 3.3 Monitoring Requirements for Potlines
If your emission
point is ....
Existing prebake or
Soderberg potline
And you have
chosen, as your
overall
compliance
strategy, the . . .
TF limit for
individual potline
(Option 1)
And you
are using
this type of
control
device . . .
Any
Then you must monitor as described below . . .
Do monthly performance tests to determine compliance with TF limits. Follow the
procedures in you site-specific test plan and in §§ 63.847 and 63.849 of the rule.
According to
these sections of
the rule ...
§ 63.848(a)
OR
TF emission
averaging limit for
multiple potlines
(Option 2)
Compute and record the monthly average from at least three runs for
secondary emissions and the previous 12-month average (minimum of
three runs per year) for the primary control system. linclude all valid
runs done in the monthly average. For secondary emissions, the duration of
each run must represent a complete operating cycle
OR
Instead of measuring TF secondary emissions from each potline, measure
emissions from one potline and monitor other similar potlines by
alternative procedures, such as an hydrogen fluoride (HF) continuous
emission monitoring system
If you qualify for reduced sampling frequency, you can measure secondary
TF emissions quarterly instead of monthly
i 63.848(d)
i 63.848(e)
Existing Soderberg
potline
POM limit for
individual potline
(Option 1)
Any
Do quarterly performance tests to determine compliance with POM limits. Follow
the procedures in your site-specific test plan and in §§ 63.847 and 63.849 of the rule.
§ 63.848(b)
OR
POM emission
averaging limit for
multiple potlines
(Option 2)
Compute and record the the quarterly average from at least one run per
month for secondary emissions and the previous 12 month average of
all runs for the primary control system (3 runs minimum per year).
Include all valid runs in the quarterly average. For secondary emissions,
the duration of each run must represent a complete operating cycle. Sample
the primary control system over an 8-hr period unless your regulatory
authority approves an alterative sampling time
16
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Table 3.3 Monitoring Requirements for Potlines (cont'd)
If your emission
point is ....
And you have
chosen, as your
overall
compliance
strategy, the . . .
And you
are using
this type of
control
device . . . Then you must monitor as described below . . .
According to
these sections of
the rule ...
New or reconstructed
potline
TF limit for
individual potline or
POM limit for
individual potline
Any
Same as above
Existing Soderberg,
CWPB2, or CWPB3
potline that adds a new
potroom group or
associated with a
modified or reconstructed
potroom group
Lower and upper TF Any
limit
Conduct monthly performance tests to determine compliance with TF limits. Follow
the procedures in your site-specific test plan and in §§ 63.845, 63.847 and 63.849 of
the rule.
! Determine the TF emission rate for secondary emissions and the primary
control device for each new, modified, or reconstructed potroom group
! Determine the TF emission rate for secondary emissions and the primary
control device for each potroom group or section of a potroom group within
the potline that is not a new, modified, or reconstructed potroom group.
You can do this either or two ways
(1) Determine the mass emission rate from at least one potroom group
within the potline that is not a new, modified, or reconstructed potroom
group using the methods, procedures, and equations in §§ 63.847, 63.848,
and 63.849
(2) Use the sampling results for the new, modified, or reconstructed
potroom group to represent the entire potline provided the results are
representative of the entire potline. To be representative, all the potroom
groups associated with the potline must be substantially equivalent in
structure, operability, and type, volume, and concentration of emissions.
OR
Instead of sampling each new, modified, or reconstructed potroom group and each
potroom group or section of the potroom group that is not a new, modified, or
recontructed potroom group, you can do representative sampling of the entire potline
if your regulatory authority approves your request
§ 63.845(g)(l)
§ 63.845(g)(2)
§ 63.845(g)(2)(i)
§ 63.845(g)(2)(ii)
§ 63.845(g)(4)
17
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Table 3.3 Monitoring Requirements for Potlines (cont'd)
If your emission
point is ....
And you have
chosen, as your
overall
compliance
strategy, the . . .
And you
are using
this type of
control
device . . . Then you must monitor as described below . . .
According to
these sections of
the rule ...
Any potline
All
Any
Install, operate, and maintain a monitoring device to determine the daily § 63.848(j)
weight of aluminum produced
Any potline
All
Dry alumina ! Install, calibrate, operate, and maintain continuous parameter monitoring § 63.848(f)(l)
scrubber systems to measure and record dry alumina flow and air flow.
or
Alternative operating parameters approved by your regulatory authority § 63.848(1)
! Calibrate it according to the manufacturer's instructions § 63.848(k)
! Visually inspect the control device exhaust stack each day for evidence of
any visible emissions indicating abnormal operation. Record the results of § 63.848(g)
each inspection
! Initiate corrective action procedures within 1 hour if the monitoring device § 63.848(h)
measures an operating parameter outside the established limit(s) or you
observe visible emissions indicating abnormal operation from the exhaust
stack during a daily inspection
Wet scrubber
for primary
emission
control
Install, calibrate, operate, and maintain continuous parameter monitoring § 63.848(f)(3)
systems to measure and record water flow and air flow
or
Alternative operating parameters approved by your regulatory authority § 63.848(1)
Calibrate it according to the manufacturer's instructions § 63.848(k)
Visually inspect the control device exhaust stack each day for evidence of § 63.848(g)
any visible emissions indicating abnormal operation. Record the results of
each inspection
Initiate corrective action within 1 hour if the monitoring device measures an
operating parameter outside the established limit(s) or you observe visible
emissions indicating abnormal operation from the exhaust stack during a § 63.848(h)
daily inspection
18
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Table 3.3 Monitoring Requirements for Potlines (cont'd)
If your emission
point is....
And you have
chosen, as your
overall
compliance
strategy, the ...
And you
are using
this type of
control
device...
Then you must monitor as described below
According to
these sections of
the rule ...
Electrostatic
precipitator
Install, calibrate, operate, and maintain continuous parameter monitoring
system to measure and record voltage and secondary current § 63.848(f)(4)
or
Alternative operating parameters approved by your regulatory authority § 63.848(1)
Calibrate it according to the manufacturer's instructions § 63.848(k)
Visually inspect the control device exhaust stack each day for evidence of
any visible emissions indicating abnormal operation. Record the results of § 63.848(g)
each inspection
Initiate corrective action procedures within 1 hour if the monitoring device § 63.848(h)
measures an operating parameter outside the established limit(s) or you
observe visible emissions from the exhaust stack during a daily inspection
indicating abnormal operation
19
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Table 3.3 Monitoring Requirements for Potlines (cont'd)
If your emission
point is ....
And you have
chosen, as your
overall
compliance
strategy, the . . .
And you
are using
this type of
control
device . . .
Wet roof
scrubber for
secondary
emission
control
Then you must monitor as described below . . .
! Install, calibrate, operate, and maintain continuous parameter monitoring
system to measure and record total water flow
or
Alternative operating parameters approved by your regulatory authority
! Calibrate it according to the manufacturer's instructions
According to
these sections of
the rule ...
§ 63.848(f))(5)(i)
§ 63.848(1)
§ 63.848(k)
Inspect each control device at least once during the operating day to ensure
proper operation and record the results of each inspection § 63.848(f)(5)(ii)
Visually inspect the control device exhaust stack(s) each day for evidence of
any visible emissions indicating abnormal operation. Record the results of § 63.848(g)
each inspection
Initiate corrective action within 1 hour if the monitoring device measures an § 63.848(h)
operating parameter outside the established limit(s) or you observe visible
emissions from the exhaust stack indicating abnormal operation during a
daily inspection or you detect a problem indicating improper operation
during the daily inspection
One not
listed above
Request that regulatory authority include recommended operating
parameters to be monitored in your operating permit
i 63.848(m)
20
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Table 3.4 Recordkeeping Requirements for Potlines
If your emission
point is....
Then you must keep records as described below ...
According to these
sections of the rule .
Any potline
Records required by § 63.10(b) § 63.850(e)(4)
! The occurrence and duration of each startup, shutdown, or malfunction of process equipment
! The occurrence and duration of each malfunction of the air pollution control equipment
! All maintenance performed on the air pollution control equipment
! Actions taken during a startup, shutdown, or malfunction (including corrective action) when
actions are different from the procedures in the startup, shutdown, and malfunction plan
! All information needed to demonstrate conformance with the startup, shutdown, and
malfunction plan (including corrective action) when all your actions are consistent with the § 63.848(d)
procedures in the plan
! Each period a continuous monitoring system is malfunctioning or inoperative
! All required measurements needed to demonstrate compliance with the standard that support § 63.848(e)
data you are required to report (inlcuding but not limited to, data from a continuous monitoring
system and raw data from performance tests and performance evaluations)
! All results of performance test and performance evaluations (including measurements needed to
determine the conditions of the test and performance evaluation
! All calibration checks, adjustments, and maintenance performed on a continuous monitoring
system
! Any information demonstrating whether an affected source is meeting the requirements for a
waiver from recordkeeping or reporting requirements (if applicable)
! All emission levels relative to the criterion for obtaining permission to use an alternative to the
relative accuracy test (if applicable)
Daily production rate of aluminum
Copy of startup, shutdown, and malfunction plan
Records supporting monitoring of similar potlines demonstrating that the performance of similar potlines
is the same as or better than that of potlines sampled by manual methods
: 63.850(e)(4)(i)
: 63.850(e)(4)(iii)
: 63.850(e)(4)(vi)
21
-------
If your emission
point is....
Table 3.4 Recordkeeping Requirements for Potlines (cont'd)
Then you must keep records as described below ...
According to these
sections of the rule .
Records supporting a request for reduced sampling frequency § 63.850(e)(4)(vii)
Records supporting the correlation of emissions measured by a continuous emission monitoring system to § 63.850(e)(4)(viii)
emissions measured by manual methods and the derivation of the alternative emission limit derived from
the measurements
Current implementation plan for emission averaging and any subsequent amendments § 63.850(e)(4)(ix)
Records of the daily visual inspection of each control device for proper operation § 63.850(e)(4)(x)
Records of the daily inspection of each exhaust stack for evidence of visible emissions indicating § 63.850(e)(4)(xi)
abnormal operation
Records documenting the corrective actions taken when the control device operating parameter limits § 63.850(e)(4)(xiii)
were exceeded, when visible emissions indicating abnormal operation were observed during a daily
inspection, or when a problem was detected during the daily inspection of a wet roof scrubber for
secondary control
Records documenting any POM data that are invalidated due to the installation and startup of a cathode § 63.850(e)(4)(xiv)
Records documenting the portion of TF that is measured as particulate matter and the portion that is § 63.850(e)(4)(xv)
measured as gaseous when the particulate and gaseous fractions are quantified separately using an
approved test method
22
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Table 3.4 Recordkeeping Requirements for Potlines (cont'd)
If your emission According to these
point is .... Then you must keep records as described below... sections of the rule.
Any potline with an HF Records required by § 63.10(c): § 63.850(e)(4)(xii)
continuous emission
monitoring system ! All required continuous monitoring system measurements
! The date and time identifying each period the continuous monitoring system was inoperative
except for zero (low-level) and high-level checks or out of control
! The nature of repairs or adjustments to the continuous monitoring system that was inoperative
or out of control. You may use the startup, shutdown and malfunction plan or records to satisfy
this requirement provided it adequately addresses the requirement
! The specific identification (i.e., date and time) of each period of excess emissions and
parameter monitoring exceedances that occurs during a startup, shutdown, or malfunction or
during a period other than a startup, shutdown, or malfunction.
! The nature and cause of any malfunction (if known) and the corrective action taken or
preventive measure adopted. You may use the startup, shutdown, and malfunction plan or
records to satisfy this requirement provided if adequately addresses the requirement
! Total process operating time during the reporting period
! Procedures that are a part of a quality control program
23
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Table 3.5 Notifications and Reports for Potlines
Notifications
Reports
Notification of applicability if you are an area source and subsequently increase your
emissions such that you are a major source subject to the rule
Annual report summarizing all performance tests done after the
initial performance test
Notification of applicability for an affected source if the startup date is before the
effective date (10/7/97)
Startup, shutdown, and malfunction reports
Notification of applicability for an affected source if the affected source is new or
reconstructed, the startup date is after the effective date (10/7/97), and an application for
construction or reconstruction is not required
Semi-annual excess emissions report
If you construct or reconstruct after the effective date (10/7/97) and an application for
approval of construction or reconstruction is required:
Intention to construct or reconstruct
Date construction or reconstruction began
Anticipated date of startup
Actual date of startup
Application for approval or construction or reconstruction
If you choose to comply with the NSPS provisions in the rule:
Report within 30 days of any performance test that shows
emissions that fall between the lower and upper limit
Notification of initial performance test
Annual compliance certification
Notification of compliance status (include results of initial performance test)
Notification of compliance approach (if requested)
If you choose to comply with the NSPS provisions in the rule:
Notification that the capital cost of the proposed new potroom components exceeds 50
percent of the fixed capital cost that would be required to construct a comparable entirely
new potroom group
24
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CHAPTER 4 - Complying with requirements for anode bake furnaces
What is covered under these sections of the rule?
Different emission limits apply to your existing anode bake furnace and your new or reconstructed furnace.
The anode bake furnace sections of the rule cover the emission limits for individual furnaces and groups of
furnaces in an emissions averaging plan.
If you are interested in this requirement See this section of rule for
more information...
TF and POM emission limits for an existing anode bake furnace § 63.843(c)(l)-(2)
TF and POM emission limits for a new or reconstructed anode bake § 63.844(c)
furnace device
TF and POM emission averaging limits and requirements § 63.846, Table 3
Performance test requirements § 63.847(c)(4), (h)
Emission monitoring § 63.848(c), (f)-(l)
Notifications, reports, and records § 63.850
What is exempt under these sections of the rule?
The rule doesn't apply to any existing anode bake furnace that is not located on the same site as a primary
aluminum reduction plant. In this case, you must comply with the State MACT determination from your
regulatory authority [§ 63.840(b)].
Do I have any compliance options?
If you have an existing furnace, you have two major regulatory options:
! Option 1: Meet the emission limits for each individual furnace. An individual furnace
includes multiple bake furnaces controlled by a common control device. [§ 63.843(c)]
! Option 2: Average emissions from multiple existing furnaces and meet limits based on the
number of furnaces in a group. [§ 63.846(c)]
What emission limits must I meet?
TF and POM emission limits (Ib/ton of green anode) for all existing anode bake plants are shown in Table
4.1. This table also gives the emission limits for emission averaging.
25
-------
If you choose to use the limits for emission averaging:
! Averaging is restricted to like sources (TF emissions from an anode bake furnace can be
averaged only with TF emissions from an anode bake furnace at the same site)
! Averaging of TF and POM emissions is not allowed
! Only existing anode bake furnaces can use emission averaging
! Emission averaging is not allowed in any State that excludes this option from its approved
operating permit program.
! Your regulatory authority must approve an implementation plan before you begin emission
averaging.
Emissions of TF from a new or reconstructed anode bake furnace can't be over 0.02 Ib/ton of green
anode. Emissions of POM can't exceed 0.05 Ib/ton of green anode.
What monitoring must I do?
Your major monitoring requirements include:
! Annual performance tests for TF and POM emissions [ § 63.848(c)]
! Continuous parameter monitoring system for each emission control device [63.848(f)]
! Monitoring device(s) to determine the daily weight of green anode placed in the furnace
[63.848(j)]
! Daily visual inspection of the exhaust stack(s) of each control device for evidence of any
visible emissions indicating abnormal operation [63.848(g)]
! Initiate corrective action within 1 hour if a monitoring device for a primary control device
measures an operating parameter outside the limit(s) established or if visible emissions
indicating abnormal operation are observed during daily inspection
[§ 63.848(h)]
! Do not allow the control device operating limit to be exceeded more than six times in a
semi-annual reporting period. Only one violation will be attributed to a given 24-
hour period. 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)]
Table 4.2 gives you details about your monitoring requirements. See Chapter 7 for more information on
test methods, procedures, and how to make the calculations.
26
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What records must I keep?
Table 4.3 gives a detailed list of records you must maintain for anode bake furnaces. You can keep
records on microfilm, on a computer, on a computer disk, on magnetic tape, or on microfiche.
Keep each record at each 5 years after the date it was made. You must keep the most recent 2 years of
records onsite but you can store the others offsite.
What plans and reports must I prepare?
You may need to prepare up to four types of plans:
! Site-specific test plan. You must prepare a plan but you don't have to submit it for
approval unless requested by your regulatory authority. [§§ 63.7 and 63.847(b)]
! Startup, shutdown, and malfunction plan. You must prepare and implement a plan but
you don't have to submit it for review unless requested by your regulatory authority.
While you don't have to include the plan in your permit application or operating permit
you must incorporate it by reference in your permit. [§§ 63.6(e)(3) and 63.850(c)]
! Continuous Parameter Monitoring Plan. You must submit this plan to your regulatory
authority for approval as part of the notification of compliance status.
[§ 63.848(f)]
! Monitoring device accuracy and calibration. You must submit recommended accuracy
requirements to your regulatory authority for approval as part of the notification of
compliance status. You also must certify that all devices meet the accuracy requirements.
You must calibrate each monitoring device according to the manufacturer's instructions.
[§ 63.848(k)]
! Implementation Plan for Emissions Averaging. This plan is required only if you elect to
meet the emission limits for averaging emissions from multiple existing potlines.
[§63.846(d)].
You also must provide certain notifications and make one-time or periodic reports. The notifications and
reports that may apply to bake furnaces are listed in Table 4.4. Chapter 8 describes each type of plan or
report that you must prepare.
How do I show compliance?
First, you must prepare a site-specific test plan. See Chapter 8 for detailed information on the
requirements for your site-specific test plan.
Then, do a performance test for each anode bake furnace to show that you meet the limits. The rule
requires that you begin the performance test starting the first month after your compliance date. Follow
the procedures in your plan as well as the procedures in 40 CFR 63.7 and the rule. Chapter 7 explains
how to do the performance test and gives additional information on test methods and calculation
procedures.
27
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Table 4.1 What Emission Limits Must Existing Anode Bake Furnaces Meet?
TF emissions
Meet limit for each furnace:
i
0.20 Ib/ton of green anode
Or use emission averaging:
i
No. of furnaces Ib/ton of green
anode
2 0.11
3 0.090
4 0.077
5 0.070
POM emissions
Meet limit for each furnace:
i
0.18 Ib/ton of green anode
Or use emission averaging:
i
No. of furnaces Ib/ton of green anode
2 0.17
3 0.17
4 0.17
5 0.17
28
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Table 4.2 Monitoring Requirements for Anode Bake Furnaces
If your emission
point is ....
Existing furnace
And you have
chosen, as your
overall
compliance
strategy, the . . .
TF and POM limit
for individual
furnace (Option 1 )
And you
are using
this type
of control
device . . .
Any
Then you must monitor
as described below . . .
Do annual performance tests to determine compliance with TF and POM limits.
Follow the procedures in you
the rule.
site-specific test plan and in §§ 63.847 and 63.849 of
According to
these sections
the rule ...
§ 63.848(c)
§ 63.848(d)
of
OR
TF or POM emission
averaging limit for
multiple furnaces
(Option 2)
Compute and record the annual average (minimum of three runs per year)
for the primary control device. You must include all valid runs done in the
annual average.
New or reconstructed
furnace
TF and POM limits
for individual
furnace
Any
Same as above
All furnaces
Any
Install, operate, and maintain a monitoring device to determine the daily § 63.848(j)
weight of green anode material placed in the furnace
29
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Table 4.2 Monitoring Requirements for Anode Bake Furnaces (cont'd)
If your emission
point is ....
And you have
chosen, as your
overall
compliance
strategy, the ...
And you
are using
this type
of control
device...
Then you must monitor as described below
According to
these sections of
the rule...
Any furnace
Dry alumina ! Install, calibrate, operate, and maintain continuous parameter monitoring § 63.848(f)(l)
scrubber systems to measure dry alumina flow and air flow
or
Alternative operating parameters approved by your regulatory authority § 63.848(1)
! Calibrate it according to the manufacturer's instructions § 63.848(k)
! Visually inspect the control device exhaust stack each day for evidence of
any visible emissions indicating abnormal operation. Record the results of § 63.848(g)
each inspection
! Initiate corrective action within 1 hour if the monitoring device measures an § 63.848(h)
operating parameter outside the established limit(s) or you observe visible
emissions indicating abnormal operation from the exhaust stack during a
daily inspection
Electrostatic
precipitator
Install, calibrate, operate, and maintain continuous parameter monitoring
system to measure and record voltage and secondary current § 63.848(f)(4)
or
Alternative operating parameters approved by your regulatory authority § 63.848(1)
Calibrate it according to the manufacturer's instructions § 63.848(k)
Visually inspect the control device exhaust stack each day for evidence of
any visible emissions indicating abnormal operation. Record the results of § 63.848(g)
each inspection
Initiate corrective action within 1 hour if the monitoring device measures § 63.848(h)
an operating parameter outside the established limit(s) or you observe
visible emissions from the exhaust stack during a daily inspection indicating
abnormal operation
Not listed
above
Request that regulatory authority include recommended operating
parameters to be monitored in your operating permit
§ 63.848(m)
30
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Table 4.3 Recordkeeping Requirements for Anode Bake Furnaces
You must keep these records for each furnace ...
According to these
sections of the rule ,
Records required by § 63.10(b) § 63.850(e)(4)
! The occurrence and duration of each startup, shutdown, or malfunction of process equipment and each malfunction of air pollution
control equipment
! All maintenance performed on the air pollution control equipment
! Actions taken during a startup, shutdown, or malfunction (including corrective action) when actions are different from the procedures
in the startup, shutdown, and malfunction plan
! All information needed to demonstrate conformance with the startup, shutdown, and malfunction plan (including corrective action)
when all your actions are consistent with the procedures in the plan
! Each period a continuous monitoring system is malfunctioning or inoperative
! All required measurements needed to demonstrate compliance with the standard that support data you are required to report
(including but not limited to, data from a continuous monitoring system , raw data from performance tests and performance
evaluations, and all results of performance test and performance evaluations )
! All calibration checks, adjustments, and maintenance performed on a continuous monitoring system
! Any information demonstrating whether an affected source is meeting the requirements for a waiver from recordkeeping or reporting
requirements (if applicable)
! All emission levels relative to the criterion for obtaining permission to use an alternative to the relative accuracy test (if applicable)
Daily production rate of green anode material added to the furnace
§ 63.850(e)(4)(i)
Copy of startup, shutdown, and malfunction plan
§ 63.850(e)(4)(iii)
Current implementation plan for emission averaging and any subsequent amendments
§ 63.850(e)(4)(ix)
Records of the daily visual inspection of each control device for proper operation
§ 63.850(e)(4)(x)
Records documenting the corrective actions taken when the control device operating parameter limits were exceeded or when visible emissions
indicating abnormal operation were observed during a daily inspection
§ 63.850(e)(4)(xiu)
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Table 4-4 Notifications and Reports for Anode Bake Plants
Notifications
Reports
Notification of applicability if you are an area source and subsequently
increase your emissions such that you are a major source subject to the rule
Annual report summarizing all performance tests done after the initial
performance test
Notification of applicability for an affected source if the startup date is before
the effective date (10/7/97)
Startup, shutdown, and malfunction reports
Notification of applicability for an affected source if the affected source is new
or reconstructed, the startup date is after the effective date (10/7/97), and an
application for construction or reconstruction is not required
Semi-annual excess emissions report
If you construct or reconstruct after the effective date (10/7/97) and an
application for approval of construction or reconstruction is required:
Intention to construct or reconstruct
Date construction or reconstruction began
Anticipated date of startup
Actual date of startup
Application for approval or construction or reconstruction
Annual compliance certification
Notification of initial performance test
Notification of compliance status (include results of initial performance test)
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Chapter 5 - Complying with requirements for paste production plants
What is covered under this section?
The paste plant sections of the rule cover the equipment standard for existing, new, and reconstructed
plants and provisions for use of an alternative control device.
If you are interested in this requirement See this section of rule
for more information...
Equipment standard for existing paste production plants § 63.843(b)(l)-(2)
Request for alternative control device § 63.843(b)(3)
Equipment standard for new or reconstructed paste production plant § 63.844(b)
Performance test requirements § 63.847(f), (h)(2)
Emission monitoring § 63.848 (f)-(i), (k)
Notifications, plans, reports, and records § 63.850
What is exempt under this section?
No paste production plants are exempt from the rule.
What are the requirements for paste production plants?
! Install, operate, and maintain equipment to capture and control POM emissions.
! Capture equipment must meet certain requirements, and you must use a closed vent system
to transport captured emissions to a dry coke scrubber.
! Note: the paste production plant includes all operations from initial mixing to final
forming (i.e., briquettes, paste, green anodes) within the paste plant, including
conveyors and units managing heated liquid pitch. Existing liquid pitch storage tanks
are not regulated by this section.
33
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What are the requirements for a capture system?
Install and operate to meet minimum exhaust rates in chapters 3 and
5 of Industrial Ventilation: Handbook of Recommended Practice
(American Conference of Governmental Industrial Hygienists, 22 ed.,
1995)
Any revisions made to chapters 3 and 5 apply only after amendment
of the rule to require the new information [§ 63.841 (a)]
Chapters 3 and 5 of this handbook are available for inspection in the
docket (A-92-60, Docket Item II-I-42) . You may purchase the
handbook from: Customer Service Department, ACGIH, 1330
Kemper Meadow Drive, Cincinnati, Ohio 45240 (513) 742-2020
Do I have any compliance options?
You can:
! Route emissions to a dry coke scrubber (described above); or
! Request use of an alternative control device. If so, you must provide information and
data showing that the alternative control device achieves less than:
0.011 Ib of POM per ton of paste if your have continuous mixers in your paste
plant
0.024 Ib of POM per ton of paste if you have batch mixers in your paste plant
Chapter 8 gives more information on requesting an alternative control device.
What monitoring must I do?
Table 5.1 describes your monitoring requirements. Your major monitoring requirements are:
! Continuous parameter monitoring system for each emission control device [63.848(f)]
! Daily visual inspection of the exhaust stack(s) of each control device for evidence of any
visible emissions indicating abnormal operation [63.848(g)]
! Initiate corrective action within 1 hour if a monitoring device for a primary control device
measures an operating parameter outside the limit(s) established or if visible emissions
indicating abnormal operation are observed during daily inspection
[§ 63.848(h)]
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Do not allow the control device operating limit to be exceeded more than six times in a
semi-annual reporting period. Only one violation will be attributed to a given 24-
hour period. 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)]
What records must I keep?
Table 5.2 gives a detailed list of records you must maintain for paste plants. You can keep records on
microfilm, on a computer, on a computer disk, on magnetic tape, or on microfiche.
Keep each record at each 5 years after the date it was made. You must keep the most recent 2 years of
records onsite but you can store the others offsite.
What plans and reports must I prepare?
You need to prepare three types of plans:
! Startup, shutdown, and malfunction plan. You must prepare and implement a plan but
you don't have to submit it for review unless requested by your regulatory authority.
While you don't have to include the plan in your permit application or operating permit
you must incorporate it by reference in your permit. [§§ 63.6(e)(3) and 63.850(c)]
! Continuous parameter monitoring plan. You must submit this plan to your regulatory
authority for approval as part of the notification of compliance status.
[§ 63.848(f)]
! Monitoring device accuracy and calibration. You must submit recommended accuracy
requirements to your regulatory authority for approval as part of the notification of
compliance status. You also must certify that all devices meet the accuracy requirements.
You must calibrate each monitoring device according to the manufacturer's instructions.
[ § 63.848(k)]
You also must provide certain written notifications and make one-time or periodic reports. These are listed
in Table 5.3. Chapter 8 gives additional information on each type of plan, notification, or report.
How do I show compliance?
Install the capture and control equipment for the paste plant by your compliance date. Your regulatory
authority will inspect your paste plant and review your records to ensure that you have installed the
equipment and it meets the requirements in the rule.
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Table 5.1 Monitoring Requirements for Paste Production Plants
If your emission
point is ....
Existing, new, or
reconstructed paste
production plant
And you have
chosen, as your
overall
compliance
strategy, the . . .
Equipment standard
And you
are using
the
following
control
option . . .
Dry coke
scrubber
Then you must monitor as described below . . .
! Install, operate, calibrate, and maintain a continuous parameter monitoring
system for the measurement of coke flow and air flow from each dry coke
scrubber
or
! Alternative control device operating parameters approved by your regulatory
authority
According to
these sections
of the rule ...
§ 63.848(9(2)
§ 63.848(1)
Calibrate according to manufacturer's instructions § 63.848(k)
Visually inspect the exhaust stack of each control device on a daily basis for § 63.848(g)
evidence of any visible emissions indicating abnormal operation. Record
the results of each inspection
If the monitoring device measures an operating parameter outside the § 63.848(j)
established limit(s) or you observe visible emissions indicating abnormal
operation from the exhaust stack during a daily inspection, initiate
corrective action procedures in the startup, shutdown, and malfunction plan
within 1 hour and take the necessary corrective actions to remedy the
problem
Not listed Request that regulatory authority include recommended operating parameters to be § 63.848(m)
monitored in your operating permit
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Table 5.2 Recordkeeping Requirements for Paste Production Plants
You must keep records as described below ...
According to these
sections of the rule ,
Records required by § 63.10(b)
! The occurrence and duration of each startup, shutdown, or malfunction of process equipment
! The occurrence and duration of each malfunction of the air pollution control equipment
! All maintenance performed on the air pollution control equipment
! Actions taken during a startup, shutdown, or malfunction (including corrective action) when actions are different from the procedures in the
startup, shutdown, and malfunction plan
! All information needed to demonstrate conformance with the startup, shutdown, and malfunction plan (including corrective action) when all
your actions are consistent with the procedures in the plan
! Each period a continuous monitoring system is malfunctioning or inoperative
! All required measurements needed to demonstrate compliance with the standard that support data you are required to report (including but
not limited to, data from a continuous monitoring system)
! All calibration checks, adjustments, and maintenance performed on a continuous monitoring system
! Any information demonstrating whether an affected source is meeting the requirements for a waiver from recordkeeping or reporting
requirements (if applicable)
! All emission levels relative to the criterion for obtaining permission to use an alternative to the relative accuracy test (if applicable)
i 63.850(e)(4)
Records of design information for capture system
§ 63.850(e)(4)(iv)
Records of design information for an alternative emission control device
§ 63.850(e)(4)(v)
Copy of startup, shutdown, and malfunction plan
§ 63.850(e)(4)(iii)
Records of the daily visual inspection of each control device for proper operation
§ 63.850(e)(4)(x)
Records documenting the corrective actions taken when the control device operating parameter limits were exceeded, when visible emissions
indicating abnormal operation were observed during a daily inspection
37
§ 63.850(e)(4)(xiii)
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Table 5.3 Notifications and Reports for Paste Production Plants
Notifications
Reports
Notification of applicability if your facility is an an area source and
subsequently increase your emissions such that you are a major source
subject to the rule
Startup, shutdown, and malfunction reports
Notification of applicability for an affected source if the startup date is before
the effective date (10/7/97)
Semi-annual excess emissions report
Notification of applicability for an affected source if the affected source is
new or reconstructed, the startup date is after the effective date (10/7/97),
and an application for construction or reconstruction is not required
Annual compliance certification
If you construct or reconstruct after the effective date (10/7/97) and an
application for approval of construction or reconstruction is required:
Intention to construct or reconstruct
Date construction or reconstruction began
Anticipated date of startup
Actual date of startup
Application for approval or construction or reconstruction
Notification of compliance status
38
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Chapter 6 - Complying with requirements for new pitch storage tanks
What is covered under this section?
The pitch storage tank sections of the rule cover the performance standards for new or reconstructed tanks.
If you are interested in this requirement See this section of rule
for more information...
Performance standard for a new or reconstructed pitch storage tank § 63.844(d)
Performance test requirements § 63.847(g)
Emission monitoring § 63.848(f),(g)(l), (h),
(i), (k), (1), (m)
Notifications, plans, reports, and records § 63.850
What is exempt under this section?
The rule applies to each new or reconstructed pitch storage tank. It does not apply to an existing pitch
storage tank (in place on or before September 26, 1996).
What are the requirements?
You must equip each tank with an emission control system designed and operated to reduce emissions of
POM by 95 percent or more.
Do I have any compliance options?
The performance standard allows you to use any device, system, or method that reduces POM emissions
by at least 95 percent. For example, you can:
I
Use an add-on control device, such as an incinerator, carbon adsorber, or condenser
! Vent emissions to another control device, such as the the dry coke scrubber or alternative
for the paste production plant
! Use a pollution prevention approach that eliminates the formation and release of POM
emissions.
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What monitoring must I do?
Table 6-1 describes your monitoring requirements. Your major monitoring requirements are:
! Continuous parameter monitoring system for each emission control device or system.
[§ 63.848(f)]. Your Continuous Parameter Monitoring Plan has to include a description
of the parameters to be monitored, an explanation of the criteria used for selection of the
parameters), and the frequency with which monitoring will be performed [§ 63.847(g)(l)].
! Daily visual inspection of the exhaust stack(s) of each control device for evidence of any
visible emissions indicating abnormal operation [§ 63.848(g)]
! Initiate corrective action within 1 hour if a monitoring device measures an operating
parameter outside the limit(s) established or if visible emissions indicating abnormal
operation are observed during a daily inspection [§ 63.848(h)]
! Do not allow the control device (or system) operating limit to be exceeded more than
six times in a semi-annual reporting period. Only one violation will be attributed to a
given 24-hour period. 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)]
What records must I keep?
Table 6.2 gives a detailed list of records you must maintain for new pitch storage tanks. You can keep
records on microfilm, on a computer, on a computer disk, on magnetic tape, or on microfiche.
Keep each record at each 5 years after the date it was made. You must keep the most recent 2 years of
records onsite but you can store the others offsite.
What plans and reports must I prepare?
You need to prepare three types of plans:
! Startup, shutdown, and malfunction plan. You must prepare and implement a plan but
you don't have to submit it for review unless requested by your regulatory authority.
While you don't have to include the plan in your permit application or operating permit
you must incorporate it by reference in your permit. [§§ 63.6(e)(3) and 63.850(c)]
! Continuous parameter monitoring plan. You must submit this plan to your regulatory
authority for approval as part of the notification of compliance status.
[§ 63.848(f)]
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Monitoring device accuracy and calibration. You must submit recommended accuracy
requirements to your regulatory authority for approval as part of the notification of
compliance status. You also must certify that all devices meet the accuracy requirements.
You must calibrate each monitoring device according to the manufacturer's instructions.
[ § 63.848(k)]
You also must provide certain written notifications and make one-time or periodic reports. These are listed
in Table 6-3. Chapter 8 gives additional information on each type of plan, notification, or report
How do I show compliance?
You can:
! Do a design evaluation according to the criteria in the rule [§ 63.847(g)(2)].
! Do a performance test according to the criteria in the rule [§ 63.847(g)(3)].
Chapter 7 describes the procedures you must follow for a design evaluation or a test.
41
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Table 6.1 Monitoring Requirements for New Pitch Storage Tanks
If your emission
point is....
And you have
chosen, as your
overall
compliance
strategy, the ...
And you
are using
the
following
control
option...
Then you must monitor as described below
According to
these sections of
the rule ...
New pitch storage tank
Performance
standard
All
Install, operate, calibrate, and maintain a continuous parameter § 63.848(f)(2)
monitoring system to measure and record the parameters) to be monitored
Monitor parameters approved by your regulatory authority § 63.848(g)(l)
Calibrate it according to manufacturer's instructions § 63.848(k)
Visually inspect the exhaust stack of each control device on a daily basis for § 63.848(g)
evidence of any visible emissions indicating abnormal operation. Record
the results of each inspection
If the monitoring device measures an operating parameter outside the § 63.848(j)
established limit(s) or you observe visible emissions indicating abnormal
operation,, initiate corrective action procedures in the startup, shutdown,
and malfunction plan within 1 hour and take the necessary corrective actions
to remedy the problem
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Table 6.2 Recordkeeping Requirements for New Pitch Storage Tanks
You must keep these records for each new pitch storage tank...
According to these
sections of the rule
Records required by § 63.10(b) § 63.850(e)(4)
! The occurrence and duration of each startup, shutdown, or malfunction of process equipment
! The occurrence and duration of each malfunction of the air pollution control equipment
! All maintenance performed on the air pollution control equipment
! Actions taken during a startup, shutdown, or malfunction (including corrective action) when actions are different
from the procedures in the startup, shutdown, and malfunction plan
! All information needed to demonstrate conformance with the startup, shutdown, and malfunction plan (including
corrective action) when all your actions are consistent with the procedures in the plan
! Each period a continuous monitoring system is malfunctioning or inoperative
! All required measurements needed to demonstrate compliance with the standard that support data you are
required to report (including but not limited to, data from a continuous monitoring system)
! All calibration checks, adjustments, and maintenance performed on a continuous monitoring system
! Any information demonstrating whether an affected source is meeting the requirements for a waiver from
recordkeeping or reporting requirements (if applicable)
! All emission levels relative to the criterion for obtaining permission to use an alternative to the relative accuracy
test (if applicable)
Copy of startup, shutdown, and malfunction plan
§ 63.850(e)(4)(iii)
Records of the daily visual inspection of each control device for proper operation
§ 63.850(e)(4)(x)
Records documenting the corrective actions taken when the control device operating parameter limits were outside the
limits
§ 63.850(e)(4)(xiii)
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Table 6.3 Notifications and Reports for New Pitch Storage Tanks
Notifications
Reports
Notification of applicability if your facility is an an area source and subsequently
increase your emissions such that you are a major source subject to the rule
Startup, shutdown, and malfunction reports
Notification of applicability for an affected source if the startup date is before the
effective date (10/7/97)
Semi-annual excess emissions report
Notification of applicability for an affected source if the affected source is new or
reconstructed, the startup date is after the effective date (10/7/97), and an
application for construction or reconstruction is not required
Annual compliance certification
If you construct or reconstruct after the effective date (10/7/97) and an application
for approval of construction or reconstruction is required:
Intention to construct or reconstruct
Date construction or reconstruction began
Anticipated date of startup
Actual date of startup
Application for approval or construction or reconstruction
Notification of compliance status
44
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Chapter 7 - Methods, procedures, and calculations
What test methods do I use for TF and POM?
You must sample for TF and POM emissions using EPA reference methods, an alternative method
previously approved for your specific plant by EPA or your State agency, or an alternative method that you
get approved by the regulatory agency based on showing it is equivalent to the reference method.
Table 7.1 Methods for Sampling for TF and POM
You may use one of these methods....
Stack for the anode bake furnace or potline primary control EPA Method 13A or 13B for TF and EPA Method 315 for
system
POM, or
An alternative method that EPA or the State had previously
approved for your facility, or
An alternative method you demonstrate (to the satisfaction
of the applicable regulatory authority) is equivalent to the
reference method
Potline roof monitor (with no wet roof scrubbers)
EPA Method 14 or 14A for TF and Method 315/Method 14
for POM, or
An alternative method that EPA or the State had previously
approved for your facility (an HF continuous emission
monitoring system is an approved alternative for similar
potlines), or
An alternative method you demonstrate (to the satisfaction
of the applicable regulatory authority) is equivalent to the
reference method
Potline roof monitor (with wet roof scrubbers)
Sample using a method approved by the State agency that
meets the intent of Method 14, and
Analyze for TF using EPA Method 13A or 13B for TF and
EPA Method 315 for POM, or
An alternative method that EPA or the State had previously
approved for your facility (an HF continuous emission
monitoring system is an approved alternative for similar
potlines), or
An alternative method you demonstrate (to the satisfaction
of the applicable regulatory authority) is equivalent to the
reference method
45
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How do I get approval to use an alternative test method?
There are two ways that you can use an alternative method rather than an EPA reference method:
! You have already demonstrated the equivalency of the alternative method and have
received previous approval from EPA or the applicable regulatory authority to use it, or
! You perform simultaneous sampling with the reference method and the alternative method
and show, to the satisfaction of the regulatory authority, that the two methods are
equivalent.
What are my requirements for conducting a performance test?
You must follow the procedures you have outlined in your site-specific test plan. More information is
given on the contents of this plan in Chapter 8, and an example outline of a plan is given in Appendix C
.Table 7.2 summarizes the rule's requirements for conducting a performance test for potlines, and Table
7.3 presents the requirements for anode bake furnaces.
How do I sample if I have many stacks for a single control device or several
control devices for a single process?
When a single control device, such as a dry alumina scrubber, has many stacks, you may develop
procedures to ensure that at least three runs are performed annually by a representative sample of the
stacks. The procedures must be approved by your State agency. Such procedures may include (but are not
limited to) rotating the sampling among the stacks over some period of time, or sampling stacks
representative of all of the stacks and measuring the volumetric flow rate in all of the stacks.
If you have multiple control devices on a single process, such as a potline or bake furnace, you must
conduct at least one run per control device and at least three runs per year for the process. For example,
if you have two control devices, you must conduct at least one run on one device and two runs on the other
one. If you have four control devices, you must conduct one run per device for a total of four runs per year
to meet the requirement of one test of the primary control system each year.
What alternatives are there for performance testing?
The alternatives you have for performance test monitoring are:
! reduced testing for similar potlines,
! reduced monitoring frequency, and
! representative sampling of the entire potline when you have a new, modified, or
reconstructed potroom group.
These alternatives and criteria for approval are described in Table 7.4.
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The provisions for similar potlines allow you to use EPA reference methods for one potline and to monitor
the other similar potlines using alternative methods, such as an HF CEM. Table 7.4 explains the criteria,
which essentially require establishing a correlation between the alternative monitoring procedure and the
reference method. If you choose to use an HF CEM for secondary emissions and manual sampling for the
primary control system, you must develop a procedure or correlation that will ensure the contribution of
both primary and secondary emissions are included in the total. If you use an HF CEM, remember that the
emissions are reported on a monthly basis, so you must develop a monthly average for each month.
You can qualify for reducing the sampling of secondary (roof monitor) emissions of TF from monthly to
quarterly by showing you are consistently below the applicable limit and have low variability in emissions.
You must provide 24 consecutive months of sampling data that show the average TF emissions are less
than 60 percent of the applicable limit and that no single monthly test exceeds 75 percent of the limit.
Alternatively, you may perform a detailed statistical analysis to show low variability. The statistical
procedure is described in Primary Aluminum: Statistical Analysis of Potline Fluoride Emissions and
Alternative Sampling Frequency (EPA-450-86-012, October 1986). This document is available in the
docket for this rule (Docket A-92-60, Docket Item II-A-10). You also can obtain the document by
purchasing it from the National Technical Information Service, 5285 Port Royal Road, Springfield, VA
22161. If you exceed the TF limit after qualifying for reduced sampling frequency, you must return to
monthly sampling for at least one year. Then you may again apply for reduced sampling based on the
criteria described above.
If you have a new, modified, or reconstructed potroom group that would have been subject to the NSPS,
you can perform representative sampling of the entire potline containing that group rather than sampling
both the new potroom group and other potroom groups. Representativeness is based on showing that all of
the potroom groups are essentially equivalent in terms of structure, operability, type of emissions, volume
of emissions, and concentration of emissions.
How do I calculate my emissions when I am using emission averaging?
If you use emission averaging, emissions are calculated from the sum of emissions from all emission points
to be averaged divided by the process production rate for all processes involved in averaging. For example,
suppose you plan to use emission averaging for Potlines 1, 2, and 3. You measure TF emissions from the
primary control system and roof monitor as 384, 192, and 360 Ib/day for the three potlines. The aluminum
production rate is 120, 149, and 192 tons/day for Potlines 1, 2, and 3, respectively. TF emissions for
emission averaging are calculated in Ib/ton:
TF (Ib/ton) = (384 + 192 + 360)7(120 + 149 + 192) = 2.0 Ib/ton.
A similar procedure is used for emission averaging for bake furnaces except that the production (in the
denominator) is based on green anode production.
How do I calculate my emission limits if I incorporate the NSPS into my
subpart LL requirements?
You must calculate a lower and an upper emission limit. If you exceed the lower limit, you would not be in
violation if you met the upper limit and you show that exemplary operation and maintenance procedures
47
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were used with respect to the emission control equipment and that proper control equipment was operating
during the performance test.
The lower limit is calculated from:
LI =fi x LPG1 + (1-fj) x LPL
where
L] = the lower TF emission limit (Ib/ton);
f] = the fraction of the potline's total aluminum production capacity that is contained within all new,
modified, and reconstructed potroom groups;
LPG1 = 1.9 Ib/ton for prebake potlines and 2.0 Ib/ton for Soderberg potlines; and
LpL = the TF emission limit that would normally apply to the potline if subject only to subpart LL.
The upper limit is calculated from:
L2 =fj x LPG2 + (1-fj) x LPL
where
L2 = the upper TF emission limit (Ib/ton); and
LPG1 = 2.5 Ib/ton for prebake potlines and 2.6 Ib/ton for Soderberg potlines.
How do I calculate my TF emissions if I incorporate the NSPS into my subpart
LL requirements?
You have two choices:
! You may sample one section of the potline and use that result (in Ib/ton) to determine compliance if
you can show it is representative of the entire potline. Representativeness is based on showing that
all of the potroom groups are essentially equivalent in terms of structure, operability, type of
emissions, volume of emissions, and concentration of emissions.
! The second choice is to sample two sections of the potline, one section that represents the new,
modified, or reconstructed potroom group and one section that represents the rest of the potline.
The emissions rates are combined based on the relative amount of aluminum produced in each
section:
E =fj x EPG2 + (1-fj) x EPL
where
E = the TF emission rate for the potline in Ib/ton;
48
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f[ = the fraction of the potline's total aluminum production capacity that is contained within all new,
modified, and reconstructed potroom groups;
EPG1 = the TF emission rate in Ib/ton for all new, modified, and reconstructed potroom groups in the
potline; and
EPL = the TF emission rate in Ib/ton for the balance of the potline.
What procedures do I use for new pitch storage tanks?
There are three options for demonstrating compliance for pitch storage tanks:
! Perform sampling for POM at the inlet and outlet of the control device using EPA Method
315 and show that the control efficiency is at least 95 percent, or
! Vent the pitch tank to the control device used for the paste production plant (if you are
complying with the paste production plant requirements, then you are considered to be in
compliance for the pitch storage tank), or
! Perform a design evaluation.
For a design evaluation, you must document that the control device achieves at least 95 percent control
during the maximum filling rate, including the vapor flow rate and POM concentration under varying liquid
level conditions. If vapors (other than fuels) from sources other than the pitch storage tank are received by
the control device, the efficiency consideration must also include these other vapors. Other requirements
depend on the type of control device:
! For enclosed combustion devices ~ a minimum residence time of 0.5 seconds and a
minimum temperature of 760 C. If a thermal incinerator that does not meet these
conditions is used, you must specify the autoignition temperature of the HAP, vapor flow
rate, combustion temperature, and residence time.
! For carbon adsorbers, include the affinity of the organic vapors for carbon, the amount of
carbon in each bed, the number of beds, and the temperature, humidity and flow rate of the
vapor. If the adsorber is regenerable, specify the desorption schedule, regeneration steam
pressure or temperature, and flow rate of the regeneration stream. Include the pressure
drop for vacuum desorption.
! For condensers, include the final vapor temperature, type of condenser, and design flow
rate of the vapor.
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Table 7.2 Performance Test Requirements for Potlines
If your emission
point is ....
Prebake or Soderberg
potline
And you have
chosen, as your
overall
compliance
strategy, the . . .
TF limit for
individual potline
(Option 1)
OR
TF emission
averaging limit for
multiple potlines
(Option 2)
Then you must follow these steps for each performance test . . .
Follow the procedures in your site-specific test plan to measure and record the emission rate of
secondary TF emissions for each potline
! Use Method 13A or 13B and Method 14 or 14A or an approved alternative method to
measure the concentration of TF exiting the roof monitor. If your plant has wet roof
scrubbers, use Method 1 3A or 1 3B or an approved alternative method to measure the
concentration of TF from the stack or duct. See Chapter 7 for additional test method
requirements if you have a VSS potline or a SWPB potline using wet roof scrubbers for
secondary emission control.
! You must do at least at least three runs during a one-month period
Follow the procedures in your site-specific test plan to measure and record the emission rate of TF
According to these
sections of the rule
§ 63.847(d)(l)
§ 63.849(a)(4)
§ 63.849(a)(5)
§ 63.849(b)
§ 63.847(d)(l)
§ 63.847(d)(l)
exiting the outlet of the primary control system for each potline
! Use Method 13A or 13B or an approved alternative method to measure the concentration § 63.849(a)(5)
of TF from the stack or duct
! You must have at least three runs for the year for the primary control system. § 63.847(d)( 1)
! If you have done a performance test on the primary control system for a potline within one
year (12 consecutive months) of your compliance date, you can use the results from that § 63.847(c)
test instead of doing another test
! If you have done more than one test of the primary control device for a potline during the
previous 12 consecutive months, you must use the average of all runs performed during § 63.847(d)(3)
that period to determine the contribution from the primary control system
50
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Table 7.2 Performance Test Requirements for Potlines (cont'd)
If your emission
point is....
And you have
chosen, as your
overall
compliance
strategy, the ...
Then you must follow these steps for each performance test.
According to these
sections of the rule
Soderberg potline
POM limit for
individual potline
(Option 1)
OR
POM emission
averaging limit for
multiple potlines
(Option 2)
Follow the procedures in your site-specific test plan to measure and record the emission rate of § 63.847(d)(2)
secondary POM emissions for each potline
! Use Method 315 and Method 14 or an approved alternative method to measure the § 63.849(a)(7)
concentration of POM exiting the roof monitor. If your plant has wet roof scrubbers, use
Method 315 or an approved alternative method to measure the concentration of TF from § 63.849(a)(6)
the stack or duct. See Chapter 7 for additional test method requirements if you have a VSS
potline or a SWPB potline using wet roof scrubbers for secondary emission control. § 63.849(b)
! You must do at least at least three runs during a quarterly period (one run per month) § 63.847(d)(2)
Follow the procedures in your site-specific test plan to measure and record the emission rate of POM
exiting the outlet of the primary control system for each Soderberg potline § 63.847(d)(2)
! Use Method 315 or an approved alternative method to measure the concentration of POM
from the stack or duct § 63.849(a)(7)
! You must have at least three runs for the year for the primary control system. § 63.847(d)(2)
! If you have done a performance test on the primary control system for a potline within one
year (12 consecutive months) of your compliance date, you can use the results from that § 63.847(c)
test instead of doing another test
! If you have done more than one test of the primary control device for a potline during the
previous 12 consecutive months, you must use the average of all runs performed during § 63.847(d)(3)
that period to determine the contribution from the primary control system
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Table 7.2 Performance Test Requirements for Potlines (cont'd)
If your emission
point is....
And you have
chosen, as your
overall
compliance
strategy, the ...
Then you must follow these steps for each performance test.
According to these
sections of the rule
Existing Soderberg,
CWPB2, or CWPB3
potline that adds a new
potroom group or
associated with a
modified or reconstructed
potroom group
Lower and upper TF
limit
Follow the procedures in your site-specific test plan to measure and record the emission rate of TF § 63.845(g)( 1)
secondary TF emissions and the emission rate of TF exiting the outlet of the primary control system
for each new, modified, or reconstructed potroom group. Use the procedures, methods and
equations in §§ 63.847, 63.848, and 63.849 (see instructions above for determining TF emissions for
an individual potline)
Determine the TF emission rate for secondary emissions and the primary control device for each
potroom group or section of a potroom group within the potline that is not a new, modified, or § 63.845(g)(2)
reconstructed potroom group. You can do this either or two ways:
! Determine the mass emission rate from at least one potroom group within the potline that
is not a new, modified, or reconstructed potroom group using the methods, procedures, and § 63.845(g)(2)(i)
equations in §§ 63.847, 63.848, and 63.849
! Use the sampling results for the new, modified, or reconstructed potroom group to § 63.845(g)(2)(ii)
represent the entire potline provided the results are representative of the entire potline. To
be representative, all the potroom groups associated with the potline must be substantially
equivalent in structure, operability, and type, volume, and concentration of emissions.
OR
Instead of sampling each new, modified, or reconstructed potroom group and each potroom group or
section of the potroom group that is not a new, modified, or recontructed potroom group, you can do § 63.845(g)(4)
representative sampling of the entire potline if your regulaltory authority approves your request
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Table 7.3 Performance Test Requirements for Anode Bake Furnaces
If your emission
point is....
And you have
chosen, as your
overall
compliance
strategy, the ...
Then you must follow these steps for each performance test.
According to
these sections of
the rule ...
Existing anode bake
furnace
TF limit for
individual furnace
(Option 1)
OR
TF emission
averaging limit for
multiple furnaces
(Option 2)
Follow the procedures in your site-specific test plan to measure and record the emission rate of TF § 63.847(d)(4)
emissions exiting the exhaust stack(s) of the primary control system for each furnace
! Use Method 13A or 13B or an approved alternative method to measure the concentration of TF § 63.849(a)(4)
from the stack or duct § 63.849(a)(5)
! You must do at least at least three runs during a one calendar year period § 63.847(d)(4)
! If you have done a performance test on the primary control system for a furnace within one § 63.849(c)
year (12 consecutive months) of your compliance date, you can use the results from that test
instead of doing another test
! If you have done more than one test of the primary control device for a furnace during the § 63.847(d)(3)
previous 12 consecutive months, you must use the average of all runs performed during that
period to determine the contribution from the primary control system
Existing anode bake POM limit for
furnace individual potline
(Option 1)
OR
POM emission
averaging limit for
multiple potlines
(Option 2)
Follow the procedures in your site-specific test plan to measure and record the emission rate of POM
emissions exiting the exhaust stack of the primary control system for each furnace
! Use Method 315 or an approved alternative method to measure the concentration of POM
from the stack or duct
! You must have at least three runs for the year for the primary control system.
! If you have done a performance test on the primary control system for a furnace within one
year (12 consecutive months) of your compliance date, you can use the results from that test
instead of doing another test
! If you have done more than one test of the primary control device for a furnace during the
previous 12 consecutive months, you must use the average of all runs performed during that
period to determine the contribution from the primary control system
§ 63.847(d)(4)
§ 63.849(a)(7)
§ 63.847(d)(4)
§ 63.847(c)
§ 63.849(d)(3)
New or reconstructed
furnace
Same as above
§ 63.847(d)(4)
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Table 7.4 How Do I Qualify for a Monitoring Alternative?
If your emission
point is ....
And you are
required to
monitor . . .
And you wish to
request this
type of
monitoring
alternative...
Then you must follow these steps to get an approved monitoring
alternative . . .
According to these
sections of the rule
Existing, new, or
reconstructed potline
Monthly TF
secondary emissions
limit for individual
potline (Option 1)
Quarterly POM
secondary emissions
an individual potline
OR
Monthly TF
secondary emissions
for multiple existing
potlines under an
emissions averaging
implementation plan
Quarterly POM
secondary emissions
from multiple
existing potlines
under an emissions
averaging
implementation plan
(Option 2)
Similar potlines Criteria for approval: the alternative monitoring method and alternative
emission limit must achieve a level of emission control that is the same as or
better than the level that would have otherwise been achieved by the
applicable emission limit and monitoring method.
(1) Do a performance test using the HF continuous emission monitoring
system or other alternative monitoring method for each similar
potline simultaneously with the emission test done with the methods
and procedures §§ 63.849(a) or 63.849(b) of the rule
! TF emission estimates must account for or include gaseous
emissions and can't be based on measurements of particulate matter
or particulate fluoride alone
! If you are measuring TF and POM secondary emissions, the
alternative monitoring method must meet or exceed Method 14
criteria.
! An HF continuous emission monitoring system is an approved
monitoring alternative for TF emissions
! Do at least 9 simultaneous runs. Each run must represent a full
operating cycle.
(2) Calculate an alternative limit for the HF continuous emission
monitoring system or alternative monitoring system:
! Use the highest value for a run by the alternative monitoring system
that does not exceed the applicable emission limit
OR
! Correlate the results of the two methods (the results using the test
methods and procedures in the rule and the alternative monitoring
system results) and calculate a limit for the alternative monitoring
system that corresponds to the applicable emission limit
§ 63.848(d)
§ 63.848(d)(l)
§ 63.848(d)(l)(i)
§ 63.848(d)(l)(ii)
§ 63.848(d)(2)
§ 63.848(d)(3)
§ 63.848(d)(4)
§ 63.848(d)(4)(i)
§ 63.848(d)(4)(ii)
54
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Table 7.4 How Do I Qualify for a Monitoring Alternative? (cont'd)
If your emission
point is ....
Existing, new, or
reconstructed potline
And you are
required to
monitor . . .
Monthly TF
secondary emissions
limit for individual
potline (Option 1 )
And you wish to
request this
type of
monitoring
alternative-
Reduced
monitoring
frequency
Then you must follow these steps to get an approved monitoring
alternative . . .
Criteria for approval: secondary emissions of TF have low variability during
normal operations
! Provide 24 consecutive months of sampling to show the average TF
According to these
sections of the rule
§ 63.848(e)(l)
§63.848(e)(l)(i)
OR
Monthly TF
secondary emissions
for multiple existing
potlines under an
emissions averaging
implementation plan
secondary emissions are less than 60 percent of the applicable limit
and that no monthly performance test in the 24 months of sampling
exceeds 75 percent of the applicable limit.
If you have excess emissions:
(1) Return to monthly sampling for at least one year
(2)
To obtain approval for reduced sampling again, you must
provide data showing the average of all tests done over the
most recent 24-month period does not exceed 60 percent of
the applicable limit and that no more than one monthly
performance test in the most recent 24-month period is
over 75 percent of the applicable limit
OR
Provide data and a statistical analysis based on the approach used in
Primary Aluminum: Statistical Analysis of Potline Fluoride
Emissions and Alternative Sampling Frequency (EPA-450-86-012,
October 1986). This document is available in the docket for this rule
(Docket A-92-60, Docket Item II-A-10). You also can obtain the
document by purchasing it from the National Technical Information
Service, 5285 Port Royal Road, Springfield, VA 22161
If you have excess emissions, immediately return to monthly
sampling until your regulatory authority approves another request
§ 63.848(e)(4)
§ 63.848(e)(4)(i)
§ 63.848(e)(4)(ii)
§ 63.848(e)(l)(ii)
§ 63.848(e)(5)
55
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Table 7.4 How Do I Qualify for a Monitoring Alternative? (cont'd)
If your emission
point is ....
Existing Soderberg,
CWPB2, or CWPB3
potline that adds a new
potroom group or
associated with a
modified or reconstructed
potroom group
And you are
required to
monitor . . .
Lower and upper TF
limit
And you wish to
request this
type of
monitoring
alternative...
Representative
sampling of entire
potline
Then you must follow these steps to get an approved monitoring
alternative . . .
Criteria for approval: sampling equipment covers both the new, modified,
or reconstructed potroom group and the balance of the potline
! Coverage for new, modified, or reconstructed potroom group must
meet criteria specified in reference methods (see § 63.849)
! Determine emissions for the potline using procedures, equations, and
test methods in rule (see §§ 63.847, 63.848, and 63.849)
According to these
sections of the rule
§ 63.845(g)(4)
§ 63.845(g)(4)
§ 63.845(g)(4)
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Chapter 8 - Plans, notifications, reports, and requests for alternatives
What is a site-specific test plan?
A site-specific test plan lays out the procedures you will use for conducting the intitial performance test and
subsequent performance tests for potlines or anode bake furnaces. Make sure you read the requirements
for site-specific test plans in 40 CFR 63.7 of the NESHAP General Provisions.
The NESHAP General Provisions require that you submit your notification of performance test at least 60
calendar days before the performance test is scheduled to begin to allow your regulatory authority (upon
request) to review and approve the plan and to have an observer present during the test. You must prepare
a plan but you don't have to submit it for approval unless requested by your regulatory authority.
Key elements in the plan include:
! A test plan summary (include test methods and test schedule)
! Data quality objectives (pretest expectations of precision, accuracy, and completeness)
! Internal QA program consisting, at a minimum, of activities to assess data precision
(replicate sample analysis)
! External QA program based on blind audit samples and potential one-site system audits.
The rule also requires the plan to include:
! Procedures to ensure that at least three runs are done annually for the primary control
system for each potline and/or furnace.
! Procedures to ensure that at least three runs are done annually for a representative
number of stacks satisfactory to your regulatory authority if your potline has a single
control device exhausted through multiple stacks
! Procedures to ensure that at least one run is done annually for each control device by a
representative sample of the stacks satisfactory to your regulatory authority if your
potline has multiple control devices
! Procedures for establishing the frequency of testing secondary emissions to ensure that
you do at least one run before the 15th of the month, at least one run after the 15th, and that
you have at least 6 days between two of the runs. Figure 8.1 illustrates some of the
options for meeting this requirement.
! Procedures for rotating sampling among the scrubbers or other procedures to obtain
representative sampling satisfactory to your regulatory authority if your plant has roof
scrubbers.
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! Procedures to ensure that one fan or one scrubber per potline is sampled for each run if
you have a VSS1 potline
! Procedures to ensure that the average of the sampling results for two fans (or two
scrubbers) per potline is used for each run if your have a SWPB potline
! Procedures for sampling single stacks associated with multiple anode bake furnaces.
We've included an example outline of a site-specific test plan in Appendix C.
58
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Figure 8.1 Potline Roof Monitor Sampling Options
One run before the 15th, one run after the 15th, six days between two of the runs.
Date:
i
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
Maximum samples,
least risk
Minimum time
between runs
Maximum time
between runs
Mininmum samples,
greatest risk
59
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What is a continuous parameter monitoring plan?
As part of your notification of compliance status report, you must submit a written plan to your regulatory
authority for approval that contains:
! A description of parameters to be monitored for each control device
! The proposed upper and/or lower operating limits for each parameter and the criteria used to
select the limit. For a potline or anode bake furnace, the limits can be based on the values
recorded during each run of the initial performance test and from historical data from previous
tests (if the tests were done by the methods required in the rule)
! Monitoring frequency
! Recommended accuracy requirement for measuring each proposed parameter. You also must
certify that each monitoring device meets the accuracy requirements. You can include the
accuracy recommendations required by § 63.848(k) separately or as part of this plan.
! For a new pitch storage tank (where you must select the parameters to be monitored), the
parameters to be monitored, an explanation of the criteria used to select that parameter(s) how
the proposed parameter ensures proper operation and maintenance (i.e., relationship to ,
emission control system performance and emissions), and the frequency of monitoring
! For a paste production plant, the basis or rationale for selecting parameters to be monitored
and the associated operating limits for the emission control device.
What is an implementation plan for emission averaging?
If you plan to comply by emission averaging, you must do an Implementation Plan and submit it to the
regulatory authority for approval. The plan is required at least 6 months before emission averaging will be
used. Section 63.846 of the rule details the requirements for the content of the plan and the procedures for
review and approval of the plan. The required components are:
! Identify all sources in the average
! Identify the TF or POM limit in the average
! Identify the specific control technology or pollution prevention measure to be used for each
affected source and the date of installation or application
I
Site-specific test plan
! Control device or system operating parameters to be monitored and description of how the
operating limits will be determined (Continuous Parameter Monitoring Plan)
! Demonstrate that compliance will be achieved under representative operating conditions
60
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If you want to monitor alternative operating parameters, include:
! The parameters to be monitored and the criteria to select the parameters
! The methods and procedures that demonstrate that the proposed parameter indicates proper
control device operation and the frequency is sufficient to represent proper control device
operating condition, and the frequency and content of monitoring, reporting, and recordkeeping
What is an engineering plan?
This plan may be required by your regulatory authority as part of a notification of compliance approach.
The plan describes the techniques you will use to address the capture efficiency of the reduction cells for
gaseous HAPs in compliance with the emission limits in §§ 63.843, 63.844, and 63.846 of the rule.
What is a startup, shutdown, and malfunction plan?
You must develop and implement a written plan that describes the procedures to be followed and the
corrective actions to be taken when a potline (or potroom), baking furnace, paste production plant, new
pitch storage tank, or associated emission control equipment experience a startup, shutdown, or
malfunction. The purpose of this plan is to ensure that you correct a malfunction as soon as practicable
whenever it occurs.
What is & Malfunction?
...any sudden, infrequent, and not reasonably
preventable failure of air pollution control equipment,
process equipment, or a process to operate in a
normal or usual manner. Failures that are caused in
part by poor maintenance or careless operation are
not malfunctions. [§63.2]
You don't have to submit the plan with the permit application or include it in your operating permit. Your
permitting authority may review the plan on request. You must keep the current version available for
review and inspection by your regulatory authority. (Previous versions of revised plants must be retained
for 5 years and kept available for inspection). The plan is to be revised within 45 days if an event occurs
that the current plan fails to address or expeditiously correct the situation. The revision is to include
provisions for addressing this type of situation in the event of future occurrences.
The plan may be a stand-alone document or take the form of a standard operating procedures manual
provided it covers startup, shutdown, and malfunction events and corrective action procedures. The plan
must contain:
! Detailed procedures for operating and maintaining the affected source during periods of
startup, shutdown, and malfunction
61
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! Program of corrective action for malfunctioning process and control systems used to comply
with the rule
! Procedures, including corrective actions, to be taken if a monitoring device measures an
operating parameter value outside the limits, if visible emissions from an exhaust stack are
indicating abnormal operation of a control device are observed during an inspection, or if a
problem is detected during a daily inspection of a wet roof scrubber for potline secondary
emission control. In these cases, you must initiate corrective action within 1 hour.
! Procedures for documenting each event and confirming whether your actions conform with the
plan.
During a startup, shutdown, or malfunction (or the specific situations listed in the rule) you must keep
records of each event to document that your actions were consistent with the plan requirements.
What do I have to report and when?
Up to six types of notifications and three types of reports may be required. Table 8.1 lists types of
notifications and reports that may be required, the due date, and where you can get additional information.
Table 8.2 describes the information you must include in each type of notification and report.
What alternatives are available and how to I request one?
Two monitoring alternatives are available for potlines. These are:
! Monitoring TF or POM secondary emissions from a potline using the test methods and
procedures in the rule and emissions from similar potlines using an alternative method, such
as an HF continuous emission monitoring system. Potlines are similar if their structure,
operability, type of emissions, volume of emissions, and concentration of emissions are
substantially equivalent. You must demonstrate that the level of emission control performance
for the similar potline is the same or better than would have otherwise been achieved using the
applicable emission limit and test methods in the rule. Using test results, you then establish an
alternative emission limit for the HF continuous emission monitoring system (an approved
alternative) or other alternative monitoring system [§ 63.848(d)]
! Reduced sampling frequency for TF secondary emissions from a potline from monthly to
quarterly. For this alternative, you must demonstrate that secondary emissions ofTF have
low variability during normal operations. If you must meet the new source performance
standards and already have an approved alternative for reduced sampling frequency under §
60.194, you do not need to request another. You are deemed to have approval under this rule.
[§ 63.848(e)]
Two alternatives are available if you have a Soderberg, CWPB2, or CWPB3 potline that must meet the
new source performance standard for potroom groups. You can:
! Instead of sampling each new, modified, or reconstructed potroom group and each potroom
group or section of the potroom group that is not a new, modified, or recontructed potroom
62
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group, you can do representative sampling of TF emissions of the entire potline The
sampling equipment must cover both the new, modified, or reconstructed potroom group and
the balance of the potline. The coverage for the new, modified, or reconstructed potroom
group must meet the criteria specified for the reference methods in § 63.849 of the rule. [§
63.845(g)(4)]
! If your potline passes the TF performance test but fails to meet the 10-percent opacity limit,
you can request an alternative opacity limit. If you meet the requirements in the rule, the
regulatory authority will establish an opacity standard for the potroom group that can be met
by the potroom group at all times during which the potline is meeting the TF limit. The
alternative limit can't be more than 20 percent opacity. [§ 63.845(i)]
If you have a paste production plant, you can request an alternative control device if you do not want to
use a dry coke scrubber. In your request, you must show that the alternative control device meets the
specified emission levels by sampling POM using Method 315. If you use an alternative control device,
you will need to request your regulatory authority to include the recommended parameters to be monitored
in your operating permit and provide a Continuous Parameter Monitoring Plan to establish operating limits.
[§ 63.843(b)(3)]
The rule also includes provisions for all affected sources that allow you to:
! Monitor alternative control device operating parameters. Include the information required
for the Continuous Parameter Monitoring Plan in your request [§ 63.848(1)].
! Use an alternative test method to measure TF or POM emissions. You can do this if you
have already demonstrated that the method is equivalent for your plan and received approval or
if you use the procedures in the rule to demonstrate the alternative meets certain criteria
[§ 63.849(e)]
! Request to change parametric monitoring limits. The revised upper and/or lower limit must
be based on historical data or other information. [§ 63.847(h)(2)]
Your regulatory authority must approve your written request before you can use it. Chapter 7 contains
additional information on the technical procedures to use in making a request for monitoring similar
potlines or seeking a reduced sampling frequency.
Can I change the date my reports are due?
Under the NESHAP General Provisions [see 40 CFR 63.10(a)(5)], you may request a change in the date
you submit your reports. You and your EPA Regional Office or State, local, or Tribal agency for air
pollution control (from now on referred to as "State") must mutually agree to the change and the change
can't affect the frequency that you report. For example, you can request that semi-annual reports that
might be due in June and December be changed to another time frame, such as May and November or one
that coincides with your title V operating permit notifications. This doesn't change your reporting
frequency since you're still submitting your semi-annual reports twice per year.
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Changes to reporting dates can begin 1 year after the compliance date. Reports due before that time can't
be changed and must be reported by the date shown in Table 8.1. Contact your State for more information.
Where do I send my reports?
The NESHAP General Provisions [40 CFR 63.9(a) and 40 CFR 63.10(a)] require you to submit plans,
notifications, reports, and requests to your State or your EPA Regional Office or both (dual reporting).
Whom you send your information to depends on whether your State has been granted authority to
implement the Primary Aluminum NESHAP.
You'll need to submit reports in one of the following ways:
! to your EPA Regional Office if your State has not been delegated the authority to implement
and enforce the rule
! to your State with a copy to your EPA Regional Office, if your State has been granted
delegation and we haven't waived the dual reporting requirement
! to your State if it's been granted delegation and we've waived the dual reporting requirement.
Not all State agencies have been granted delegation. Also, as of this publication, our Region I, III, VIII,
and X offices haven't waived the dual reporting requirement under 40 CFR 63.9 and 40 CFR 63.10. This
means that if your plant is in one of these regions, you'll need to submit your reports to your State, local or
tribal agency and the EPA Regional Office. You'll find a list of our Regional Offices and their addresses
in Chapter 10. Check with your EPA Regional Office or State for the latest information on submitting
reports.
We delegated authority for all aspects of the rule to your State agency. This means that you'll submit your
requests for alternatives to your State. You can do this by using your notification of compliance status,
your application for construction or reconstruction, or at any other time as long as the request includes all
the information required by the rule. Your request must be approved as described in 40 CFR 63.6(g)
before your can use the alternative limit, method, or monitoring program.
Is there a time limit for the regulatory authority to approve or deny my
request?
Section 63.851 contains time limits that the regulatory authority must meet when you submit certain types
of plans or requests. These are:
! The site-specific test plan [63.847(b)]
! Request to change control device operating parameter limits [ § 63.848(h)(2)
! Request for reduced sampling frequency [§ 63.848(e)]
! Request for representative sampling [§ 63.845(g)(4)]
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! Request for alternative test method [§ 63.849(e)(2)]
Your regulatory authority must notify you in writing whether your submission is complete or incomplete.
This must be done within 30 days of receiving your orginal submission or within 30 days of receiving any
additional material you submit. If it is not complete, the regulatory authority must specify the information
needed and give you 30 additional days to provide the information. The regulatory authority also must
notify you in writing of approval or intent to deny approval, or if additional time is needed to review the
submission within 60 days of receiving a complete submission.
Are example reporting forms available?
We've included example forms for the most common reports the rule requires. You'll find the following
example reports in this chapter:
! Notification of applicability
! Application for approval of construction or reconstruction
! Notification of compliance status
! Annual compliance certification
You may use these forms for reporting, but you don't have to use them. You may want to check with your
State agency to make sure they don't have their own forms, or if you do use these forms, check first to see
they meet your State requirements.
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Table 8.1 Due Dates for Notifications and Reports
You must submit this type
of notification or report..
If you have ...
Then submit the report
before...
See the NESHAP
General Provisions and
the rule for more
information
Initial notification of
applicability
An area source not currently subject to the rule that subsequently
increases its emissions so that it becomes a major source that is subject
to the rule
120 days after you become
subject to the standard
§63.9(b)(1)(ii)and
§63.850(a)(1)
An existing affected source (i.e., the startup date was before 10/7/97) . .
A new or reconstructed affected source where the startup date is after
10/7/97 and an application for approval of construction or reconstruction
is not required [§ 63.9(b)(3)]
120 days after the effective date
120 days after initial startup
§ 63.9(b)(2) and §
63.850(a)(2)
§ 63.9(b)(3) and §
63.850(a)(3)
Notifications of construction or
reconstruction
A new or reconstructed major affected source where the startup date is
after 10/7/97 and an application for approval of construction or
reconstruction is required
Intent to construct or reconstruct
Date construction or reconstruction commenced
Before construction or
reconstruction (submit with
application for approval of
constuction or reconstruction)
If construction or reconstruction
commenced before 10/7/97
(effective date), submit with
application for approval of
construction or reconstruction
If construction or reconstruction
commenced after 10/7/97
(effective date), 30 days after
date construction or
reconstruction commenced
i63.9(b)(4)(i)and
i 63.850(a)(4)
i63.9(b)(4)(ii)and
i 63.850(a)(4)
;63.9(b)(4)(iii)and
i 63.850(a)(4)
Anticipated date of startup
Actual date of startup
30 to 60 days before the
anticipated date
15 days after startup
§ 63 9(b)(4)(iv) and
§ 63.850(a)(4)
§ 63 9(b)(4)(v) and
§ 63.850(a)(4)
66
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Table 8.1 Due Dates for Notifications and Reports (cont'd)
You must submit this type If you have ...
of notification or report..
Then submit the report
before...
See the NESHAP
General Provisions and
the rule for more
information
Application for approval of construction or reconstruction, if you
construct or reconstruct after 10/7/97 (effective date)
Application for approval of construction or reconstruction, if
construction or reconstruction started before 10/7/97 (effective
date), but, your initial startup was after 10/7/97 (effective date)
As soon as practicable before
reconstruction is planned to
start but no sooner than 10/7/97 §63.5(d)
(effective date)
As soon as practicable before
reconstruction is planned to
start but no later than 60 days §63.5(d)
after the effective date
Notification of potroom group An existing potroom group
component replacement
As soon as practicable before
before construction but no later
than 60 days before
construction begins
\ 63.845(a)(2)(ii)
Notification of initial
performance test
An existing, new, or reconstructed affected source
At least 60 days before the test
is scheduled
§63.9(e)and§63.850(a)(5)
Notification of compliance status An existing, new, or reconstructed affected source
60 days after the performance
test
§63.9(h)and§63.850(a)(6)
Notification of intent to use HF
continuous emission monitoring
system
An existing, new, or reconstructed affected source
Submit with notification of
compliance status (180 days
after the effective date)
§ 63.850(a)(7)
Notification of compliance
approach
If requested by your regulatory authority for an existing, new, or
reconstructed potline
Submit Engineering Plan with
notitication of compliance
status (180 days after the
effective date)
83.850(a)(8)
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Table 8.1 Due Dates for Notifications and Reports (cont'd)
You must submit this type
of notification or report..
If you have ...
Then submit the report
before...
See the NESHAP
General Provisions and
the rule for more
information
Annual compliance certification An existing, new, or reconstructed affected source
Annually - can submit with
semi-annual excess emissions
report
Title V of the Act
Excess emissions report
Compliance period is for 180 days unless quarterly reports are
required as a result of excess emissions
30 days after each 180-day
period
§63.10(e)(3)and§63.850(d)
Potroom group excess emissions
report
A new, modified, or reconstructed potroom group
30 days after any performance § 63.845(f)
test over limits
Annual performance test report An existing, new, or reconstructed potline or anode bake furnace
Annually - can submit with
semi-annual excess emissions
report
§ 63.850(c)
Startup, shutdown, and
malfunction report
An existing, new, or reconstructed affected source or associated
emission control system if an action taken during a startup, shutdown, or
malfunction is not consistent with the startup, shutdown, and
malfunction plan
Telephone call or fax within 2
working days after you begin
the actions that were
inconsistent with the plan and
follow with a report within 7
working days after the end of
the event
An existing, new, or reconstructed affected source or associated
emission control system if an action taken during a startup, shutdown, or
malfunction is consistent with the startup, shutdown, and malfunction
plan
30 days after the end of each
180-day period (can be
submitted with semi-annual
excess emissions report)
§ 63.6(e)(3)(iv) and
§ 63.850(c)(2)
§63.10(d)(5)(i)and
§ 63.850(c)(2)
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Table 8.2 Reporting Requirements
If you are submitting
this type of notification or
report. ..
Initial notification of
applicability
Then include the following information .. .
Name and address of owner or operator.
Address (physical location) of the facility.
Identify the standard you're subject to.
Compliance date.
Brief description of nature, size, design, and method of operation.
Identify each point of emission for each hazardous air pollutant.
Statement of whether you're a major or area source.
according to this section
of the NESHAP general
provisions or the rule
§63.850(a)(l)-(3)and
§ 63.9(b)
Application for Approval
of Construction or
Reconstruction
Applicant's name and address.
Notification of intent to construct or reconstruct.
Address (physical location) of the facility.
Identify the standard you're subject to.
Date that you expect to start construction or reconstruction.
Date that you expect to finish construction or reconstruction.
Date you expect to start operating (initial startup).
Type and amount of HAP you're emitting or expect to emit.
For construction, description of proposed nature, size, design, method of operation and emission controls and other
information under §63.5(d)(2).
For reconstruction, brief description of the facility, parts to be replaced and emission controls and other information
under §63.5(d)(3).
§ 63.850(a)(4) and
§ 63.5(d)
Notification of potroom
group component
replacement
Name and address of owner or operator
Location of the existing potroom group
Brief description of the existing potroom group and the components that are to be replaced
Description of the existing air pollution control equipment and the proposed air pollution control equipment
An estimate of the fixed capital cost of the replacements and of constructing a comparable entirely new potroom
group
The estimated life of the existing potroom group after the replacements
Discussion of any economic or technical limitations the potroom group may have in complying with the applicable
standards of performance after the proposed replacement
§ 63.845(a)(2)(ii)
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Table 8.2 Reporting Requirements (cont'd)
If you are submitting
this type of notification or
report. ..
Notification of initial
performance test
Then include the following information .. .
Name and address of owner or operator
Address (physical location) of the facility.
Identify the standard you're subject to
Identify affected source to be tested
Anticipated date of test for each affected source
Test methods to be used for pollutants to be tested
Have you prepared a site-specific test plan? (Yes or no)
according to this section
of the NESHAP general
provisions or the rule
§ 63.850(a)(5) and
§ 63.9(e)
Notification of Compliance
Status
Name and address of owner or operator
Address (physical location) of the facility.
Identify the standard you're subject to.
List each affected source and control device or system
Methods used to determine compliance
Results of each initial performance test for potlines and anode bake furnaces
Design evaluation or performance test results for new pitch storage tank
Methods to be used to ensure continuing compliance, including a description of monitoring, reporting, and test
methods
Type and quantity of hazardous air pollutants emitted by the affected source
Statement that you are a major or area source
Continuous Parameter Monitoring Plan
Engineering Plan (if requested)
Certification of compliance
§ 63.850(a)(6) and
§ 63.9(h)
Notification of intent to use Name and address of owner or operator.
an HF continuous emission Address (physical location) of the facility.
monitoring system Identify the standard you're subject to
Identify the specific potline or potline group that will use the HF continuous emission monitoring system
§ 63.850(a)(7)
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Table 8.2 Reporting Requirements (cont'd)
If you are submitting
this type of notification or
report. ..
Notification of compliance
approach
Then include the following information ,
Name and address of owner or operator.
Address (physical location) of the facility.
Identify the standard you're subject to
Engineering Plan
according to this section
of the NESHAP general
provisions or the rule
§ 63.850(a)(8)
Performance test reports
Name and address of owner or operator.
Address (physical location) of the facility.
Identify the standard you're subject to
Results of all performance tests conducted during the year for each affected source
: 63.850(b)
Startup, shutdown, and
malfunction report
(required if actions during a
startup, shutdown, or
malfunction are not
consistent with startup,
shutdown, and malfunction
plan)
By telephone or fax within two working days:
Identity of the affected source
Each of the actions (including corrective actions) that were taken during the startup, shutdown, or malfunction
Written followup within seven working days:
Name, title, and signature of owner or operator or other responsible official who is certifying accuracy of report
Explanation of circumstances of event
Reasons for not following startup, shutdown, and malfunction plan
Whether any excess emissions or parameter monitoring exceedances are believed to have occurred
: 63.850(c)(2) and
: 63.6(e)(3)(iv) and
Startup, shutdown, and
malfunction report (semi-
annual)
Name, title, and signature of the owner or operator or other responsible official who is certifying accuracy of the
report
The affected source or emission control system that experienced the startup, shutdown, or mafunction
The date and time of the startup, shutdown, or malfunction
Statement that actions taken during the startup, shutdown, or malfunction were consistent with the procedures in the
startup, shutdown, and malfunction plan (may be submitted as part of the excess emissions report)
: 63.850(c)(2) and
: 63.10(d)(5)(i)
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Table 8.2 Reporting Requirements (cont'd)
If you are submitting
this type of notification or
report. ..
Excess emissions summary
report
Then include the following information .. .
If the total duration of excess emissions or parameter exceedances for the reporting period is less than 1 percent of
the total operating time for the reporting period and the continuous monitoring system (continuous parameter
monitoring system or a continuous emission monitoring system) downtime for the reporting period is less than 5
percent of the total operating time for the reporting period, submit one summary report for each HAP monitored that
includes:
Company name and address of the affected source
Identification of each HAP monitored at the affected source
Beginning and end dates of the reporting period
Brief description of the process units
Emission and control device/process operating parameter limits
Monitoring equipment manufacture(r) and model numbers(s)
Date of the latest continuous monitoring system certification or audit (if applicable)
Total operating time of the affected source during the reporting period
Emission data summary (or similar summary if you monitor process or control system parameters). Include the total
duration of excess emissions during the reporting period (in hours for gases), the total duration of excess emissions
expressed as a percentage of the total source operating time during the reporting period, and a breakdown of the total
duration of excess emissions during the reporting period into those that are due to startup, shutdown, control
equipment problems, process problems, other known causes, and other unknown causes
Continuous monitoring system performance summary (or similar summary if you monitor process or control system
parameters). Include total continous momitoring system downtime during the reporting period (recorded in hours for
gases), the total duration of CMS downtime expressed as a percent of the total source operating time during that
reporting period, and a breakdown of the total CMS downtime during the reporting period into periods that are due to
monitoring equipment malfunctions, nonmonitoring equipment malfunctions, quality asssurance/quality control
calibrations, other known causes, and other unknown causes
A description of any changes in CMS, processes, or controls since the last reporting period
Name, title, and signature of the responsible official who is certifying the accuracy of the report
according to this section
of the NESHAP general
provisions or the rule
§ 63.850(d) and
§63.10(e)(3)(vi)
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If you are submitting
this type of notification or
report. ..
Excess emissions full
report
Then include the following information .. .
If the total duration of excess emissions or parameter exceedances for the reporting period is 1 percent or more of the
total operating time for the reporting period and the continuous monitoring system (continuous parameter monitoring
system ora continuous emission monitoring system) downtime for the reporting period is 5 percent or more of the
total operating time for the reporting period, submit one summary report for each HAP monitored that includes:
Name, title, and signature of the responsible official who is certifying the accuracy of the report
The date and time identifying each period during which the continuous monitoring system was inoperative except for
zero (low level) and high-level checks
The date and time identifying each period during which the continuous monitoring system was out of control [see §
63.8(c)(7)]
The date and time of each period of excess emissions or parameter monitoring exceedance (include the time it began
and ended) that occurs during a period of startup, shutdown or malfunction of an affected source
The date and time of each period of excess emissions or parameter monitoring exceedance (include the time it began
and ended) that ocurred during a period other than a startup, shutdown, or malfunction of an affected source
The nature and cause of any malfunction (if known)
The corrective action take or preventative measured adopted
The nature or the repairs or adjustments to the continuous monitoring system that was inoperative or out of control
The total process operating time during the reporting period
All information concerning an out of control period for a continuous monitoring system, including start and end dates
and hours and a description of the corrective actions taken
according to this section
of the NESHAP general
provisions or the rule
§ 63.850(d) and
§63.10(e)(3)(v)
§63.10(c)(5)-(13)
§ 63.8(c)(7)-(8)
Potroom group excess
emissions report
Name of owner or operator
Identification of potline associated with the new, modified, or reconstructed potroom group
Performance test results that fall between the lower and upper limit for TF emissions
Identification of the control devices online and their operating condition during the test
Operation and maintenance procedures followed during the test
Explanation for the excess emissions
§ 63.845(f)
Annual Compliance
Certification
Statement that your facility complies with each applicable requirement of the rule.
40 CFR Parts 70 and 71
73
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Example
Initial Notification Report
This is a sample notification form that you can use to comply with 40 CFR 63.850(a).
Applicable Rule: 40 CFR Part 63, Subpart LL - National Emission Standards for Hazardous Air Emissions for
Primary Aluminum Reduction Plants. Initial notification is being made in accordance with
§63.850(a).
1. Print or type the following information for each plant in which you produce primary aluminum [§63.9(b)(2)(i)-
(ii)] :
Owner/Operator/Title
Street Address
City State Zip Code
Plant Name
Plant Contact/Title
Plant Contact Phone Number (optional)_
Plant Address (if different than owner/operator's)_
Street Address
City State Zip Code:
2. Show your anticipated compliance date [§63.9(b)(2)(iii)]:
(Insert compliance date)
Upon startup Anticipated startup date
3. Check which affected source(s) (as defined by 40 CFR 63.842) exist at your plant (optional):
Potline
Anode bake furnace
Paste production plant
New pitch storage tank
4. Briefly describe your sources nature, size, design, and method of operation, including its designed operating
capacity. [§63.9(b)(2)(iv)]:
74
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Example Initial Notification Report (Cont'd)
5. Identify each point of emission for each Hazardous Air Pollutant (HAP). If you can't do this definitively yet, do
a preliminary identification. If you need more lines, copy this page [§63.9(b)(2)(iv)].
Please indicate if the information below is:
Definitive
Preliminary
Source ID
Source Location
Source Description
Operation Performed
6. My plant is a major source of Hazardous Air Pollutants (HAPs)
Yes
No
NOTE: Only major sources of HAPs are regulated under this rule [§63.9(b)(2)(v)]. If you are not a major
source, you are not subject to the rule and don't need to submit this initial notification. You should, however,
keep documentation on how you determined you were an area source and maintain those records on file at your
plant.
A major source is a facility that may emit more than 10 tons per year of any one hazardous air pollutant (HAP)
or 25 tons per year of multiple HAPs. All other sources are area sources. Whether a source is a major or area
source depends on all HAP emission-points inside the plant's fenceline, not just the primary aluminum
production facility.
End of Initial Notification Form
75
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Example
Application for Approval of Construction or Reconstruction
This is a sample notification form that you can use to comply with 40 CFR 63.5(d).
Applicable Rule: 40 CFR Part 63, Subpart LL - National Emission Standards for Hazardous Air Emissions for
Primary Aluminum Reduction Plants. Notification is being made in accordance with §63.5(d)
Description: Your Application for Approval of Construction or Reconstruction falls under the General
Provisions, §63.5(d). This section requires anyone constructing or reconstructing a major source
after the effective date of a standard (in this case 10/7/97) to obtain written approval to construct or
reconstruct the source.
By this we mean, approval is required if you do any one of the following:
construct a new major affected source
reconstruct a major affected source
reconstruct a source that becomes a major affected source
This means that if you construct a new source or reconstruct an existing source that is subject to the
rule and that source a major source of HAPs, you will need to submit an Application for Approval
of Construction or Reconstruction. You can find a definition of construction and reconstruction in
the General Provisions, §63.2.
Use a separate form for each construction or reconstruction you are planning.
1 . Print or type the following information for each affected source you're constructing or reconstructing
), (C)]:
Owner/Operator/Title
Street Address
City State Zip Code:
Plant Name (optional)
Plant Contact/Title (optional)_
Plant Contact Phone Number (optional)
Plant Address (if different than owner/operator's)
Street Address
City State Zip Code:
76
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Example
Application for Approval of Construction or Reconstruction (cont'd)
2. I intend to (check only one, use a separate sheet of paper for each separate construction or reconstruction)
construct a new major affected source
reconstruct a major affected source
reconstruct a source that has become a major affected source
3. Describe the type of source you are constructing or reconstructing (optional):
4. I expect to begin construction or reconstruction on (mm/dd/yy) [§64.5(d)(l)(ii)(E)]
I expect to finish construction or reconstruction on (mm/dd/yy) [§64.5(d)(l)(ii)(F)J
I expect to startup on (mm/dd/yy) [§64.5(d)(l)(ii)(G)]
5. Complete this section only if you plan on constructing a new major affected source. All others go to 6
[§64.5(d)(2)].
(a) Describe the size and design capacity of the source you're constructing and at what capacity you intend to
operate:
(b) Identify the type and quantity of Hazardous Air Pollutants (HAPs) emitting after the construction, the
pollution control equipment you intend on using, if any, and it's control efficiency. If you can't do this
definitively, do a preliminary identification.
Please indicate if the information below is: Definitive Preliminary
77
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Example
Application for Approval of Construction or Reconstruction (cont'd)
Note: If you do a preliminary identification, you must submit actual data as soon as practical after it becomes
available, but, no later than your notification of compliance status.
Source ID:
Emission
Point ID
(if applicable)
HAP(s) emitted
Emissions
( units1)
Air Pollution
Control Device
(if applicable)
Control Efficiency of
Control Device
(% efficiency)
1 use the same units, Ib/ton or percent reductions that are required in the subpart
(c) Include with your submittal any technical information such as calculations you made to determine your
estimated emissions.
6. Complete this section only if you plan on reconstructing an existing major affected source or reconstructing a
source that becomes a major affected source after reconstruction. All others go to 7 [§64.5(d)(3)J.
(a) Describe they type of components that you're replacing:
(b) Identify the type and quantity of HAPs emitting after the reconstruction, the pollution control equipment you
currently use and intend on using, if any, and it's control efficiency. If you can't do this definitively, do a
preliminary identification.
Please indicate if the information below is:
Definitive
Preliminary
78
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Example
Application for Approval of Construction or Reconstruction (cont'd)
Note: If you do a preliminary identification, you must submit actual data as soon as practical after it becomes
available, but, no later than your notification of compliance status.
Source ID:
Emission
Point ID
(if applicable)
HAP(s)
emitted
Emissions
( units1)
Air Pollution
Control Device
Currently Used
(if applicable)
Planned
Air Pollution
Control Device
(if applicable)
Control
Efficiency of
Control
Device
(% efficiency)
1 use the same units, Ib/ton or percent reductions that are required in the subpart
(c) Include with your submittal any technical information such as calculations you made to determine your
estimated emissions.
(d) A discussion of any economic or technical limits you'll have in complying with this subpart after
reconstruction. If you don't plan on having any economic or technical limits after reconstruction, go to 7.
(i) Discuss what your economic or technical limits will be, how they effect your compliance under this
subpart, what subparts will be effected, and what alternate methods of compliance you plan on using:
(ii) My estimated fixed capital cost to reconstruct the affected source is : $
79
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Example
Application for Approval of Construction or Reconstruction (cont'd)
(iii) The estimated life of my affected source after reconstruction is: years
(iv) If I were to forgo reconstruction and construct a entirely new affected source, comparable with the one I
am reconstructing, my fixed capital costs would be: $ .00
End of Application for Approval of Construction or Reconstruction
80
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Example
Notification of Compliance Status
This is a sample notification form which you can use to comply with 40 CFR 63.850(a)(6)
Applicable Rule: 40 CFR Part 63, Subpart LL - National Emission Standards for Hazardous Air Emissions for
Primary Aluminum Reduction Plants. Notification of compliance status is being made in
accordance with §63.850(a)(6).
1. Print or type the following information for each primary aluminum reduction plant:
Owner/Operator/Title
Street Address
City State Zip Code:
Plant Name
Plant Contact/Title
Plant Contact Phone Number (optional)
Plant Address (if different than owner/operator's)
Street Address
City State Zip Code:
My facility is a major source area source
2. Fill out only if you have a paste production plant. Otherwise, go to 3.
(a) List your paste production plants and the type of control you use:
Paste production plant
Type of control
(b) My paste plant is subject to the requirements in:
§ 63.843(b)(l) and (2) ~ dry coke scrubber equipment standard
§ 63.844(b)(l) and (3) ~ emission limits for alternative control devices
(c) If your paste plant is subject to emission limits for alternative control devices in § 63.844(b)(3), please
provide the following information.
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Example Notification of Compliance Status (cont'd)
(1) Applicable emission limit:
0.011 Ib POM/ton of paste for continuous mixers
0.024 Ib POM/ton of paste for batch mixers
(2) Average of POM test results: Ib/ton of paste
(3) POM test method
EPA Method 315
Other (describe)
(d) Provide information on parametric monitoring of the control device or attach a copy of the Continuous
Parameter Monitoring Plan [§ 63.848(f)]:
(1) What is monitored?
(2) How frequently is it monitored?.
(3) What are the acceptable operating limits?
(4) Provide the basis or brief rationale for selecting the parameters and operating limits:
(e) My paste production operations are complying with the requirements in § 63.843(b):
Yes
No
3. Fill out only if you have an anode bake furnace. Otherwise, go to 4:
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Example Notification of Compliance Status (cont'd)
(a) List your anode bake furnaces, the type of control you use, the emission limit, and the average of
performance test results:
Anode bake
furnaces
Type of
control
POM emissions (Ib/ton anode)
Limit
Test results
TF emissions (Ib/ton anode)
Limit
Test results
(b) My anode bake furnaces are subject to the requirements in:
§ 63.843(c) ~ single bake furnace limits
§ 63.846(c) ~ emission averaging limits
(c) POM test method
EPA Method 315
Other (describe)
(d) TF test method
EPA Method 13A
EPA Method 13B
Other (describe) _
(e) Provide information on parametric monitoring of the control device or attach a copy of the Continuous
Parameter Monitoring Plan [§ 63.848(f)]:
(1) What is monitored?
(2) How frequently is it monitored?.
(3) What are the acceptable operating limits? .
(4) Provide the basis or brief rationale for selecting the parameters and operating limits:
83
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Example Notification of Compliance Status (cont'd)
(f) My anode bake furnaces are complying with the requirements in § 63.843(c) or § 63.846(c):
Yes
No
4. Fill out only if you have primary aluminum reduction potlines. Otherwise, go to 5.
(a) List your potlines, the type of primary control you use, the emission limit, and the average of performance
test results:
Potline
Type of
control
Soderbers only: POM
emissions (Ib/ton alumnium)
Limit
Test results
TF emissions
(Ib/ton aluminum)
Limit
Test results
(b) My potlines are subject to the requirements in:
§ 63.843(a) ~ single potline limits for existing sources
§ 63.844(a) ~ single potline limits for new or reconstructed sources
§ 63.845 ~ single potline limits for existing potline and NSPS potroom group
§ 63.846(b) ~ emission averaging limits
(c) POM test method
EPA Method 315
Other (describe)
(d) TF test method - primary control system
EPA Method 13A
EPA Method 13B
Other (describe)
84
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Example Notification of Compliance Status (cont'd)
(d) TF test method - secondary emissions
EPA Method 14
EPA Method 14A
State-approved method for wet roof scrubbers
Other (describe)
(e) Provide information on parametric monitoring of the control device or attach a copy of the Continuous
Parameter Monitoring Plan [§ 63.848(1)]:
(1) What is monitored?
(2) How frequently is it monitored?
(3) What are the acceptable operating limits?
(4) Provide the basis or brief rationale for selecting the parameters and operating limits:
(f) My potlines are complying with the applicable requirements listed above:
Yes
No
5. Fill out only if you have a new pitch storage tank (startup after 9/26/96).
(a) List your pitch storage tanks and the type of control system you use:
Pitch storage tank
Type of control
85
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Example Notification of Compliance Status (cont'd)
(b) I have demonstrated compliance for my new pitch storage tank(s) by:
a performance test for POM control efficiency using Method 315 (attach results)
a design evaluation (attached)
(c) Provide information on parametric monitoring of the control device or attach a copy of the Continuous
Parameter Monitoring Plan [§ 63.848(f)]:
(1) What is monitored?
(2) How frequently is it monitored?
(3) What are the acceptable operating limits?
(4) Provide the basis or brief rationale for selecting the parameters and operating limits:
(d) My pitch storage tanks are complying with the requirements in § 63.844(d):
Yes
No
End of Notification of Compliance Status
86
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Example
Annual Compliance Certification
This is a sample notification form that you can use to comply with 40 CFR 63.1306(g).
Applicable Rule: 40 CFR Part 63, Subpart LL - National Emission Standards for Hazardous Air Emissions
for Primary Aluminum Reduction Plants. Notification of compliance status is being made
in accordance with §63.850(a)(6).
You may use compliance certifications required in your State or local operating permit program to satisfy this
reporting requirement as long as the compliance certification is consistent with §63.850(a)(6).
1. Print or type the following information for each primary aluminum potline, anode bake furnace, paste
production plant, or new pitch storage tank:
Owner/Operator/Title
Street Address
City State Zip Code:
Plant Name
Plant Contact/Title
Plant Contact Phone Number (optional)_
Plant Address (if different than owner/operator's)
Street Address
City State Zip Code:
I certify that my potline n anode bake furnace n paste production plant n pitch storage tank n is in
compliance with each applicable requirement in § 63.840 through § 63.8530, the Primary Aluminum Reduction
Plant NESHAP (40 CFR 63, Subpart LL). For operations that are not in compliance, provide a description of
your noncompliant operations.
Signature of Responsible Official: [§63.1306(g)(3)]
Title of Responsible Official:
87
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Chapter 9 - Other requirements and information
Who administers this regulation?
Your State or local agency for air pollution control, or your EPA Regional Office, will regulate you. If
your plant is in Indian Country, your eligible Tribe or your EPA Regional Office will regulate you.
You may be regulated by one or more agencies depending on whether they've been granted delegation
of this rule.
Definition. An eligible Tribe means "a Tribe that has
been determined by the EPA to meet criteria for being
treated in the same manner as a State, pursuant to the
regulations implementing section 301(d)(2) of the Act"
Not all States have been granted delegation, or, if they have been granted delegation, they may not have
been delegated all portions of the rule. Our EPA Regional Offices may also have retained certain
rights even after delegation. You should check with your EPA Regional Office or State for the latest
information.
Are plants in Indian country regulated by the State?
Generally, State rules aren't enforceable in Indian country. When we delegate authority to States
under section 112(d), the authority to regulate doesn't extend to Indian country unless the delegation
agreement says so.
We encourage tribes to develop the capacity to administer section 112(d) programs and to request
delegation. If we don't delegate the authority to carry out section 112(d) rules to an eligible Tribe, the
EPA Regional Office will be the regulatory authority.
Do I need a title V permit?
You'll need a title V permit if you're subject to the Primary Aluminum NESHAP since, under title V,
you must get a permit if your facility is a major source. The Primary Aluminum NESHAP applies to
major sources. All existing primary aluminum reduction plants are believed to be major sources
subject to the rule.
If you question whether your facility is a major source, you'll need to calculate your HAP emissions
from your entire facility, not just your primary aluminum operations. If you don't have federally
enforceable limits in a State permit, you must calculate your emissions by determining your potential
emissions. If you need help determining if your facility is a major source or what your potential
emissions are, see the definitions in the Operating Permits Rule §70.2, or visit our title V policy and
guidance page atwww.epa.gov/ttn/oarpg/t5main.html.
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How do I change my permit to include this rule?
If you've already been issued a final title V permit and you have three or more years left on your
permit, your permitting authority will reopen your permit within 18 months of the publication date of
the final rule or final amendments. If you have less than three years left on your permit, update your
permit during your renewal period. If you have not been issued a final permit, you will need to update
your application to reflect that the primary aluminum MACT rule is an applicable requirement if it was
not previously identified as such.
To summarize, your options are as follows:
If a new rule is effective1'2 Then ...
and you have ...
not been issued a final title V update your permit application or draft
permit permit
less than three years left on update your title V permit during renewal
your permit
three or more years left on your your permitting authority will reopen your
permit permit within 18 months after the publication
date of the final rule or final amendments
1 The rule's effective date is the date the final rule is published in the Federal Register (which is 10/7/97 for this
rule).
2 This also applies if existing rules are modified and final amendments are published in the Federal Register.
Title V permitting rules may change after the publication of this document. Keep abreast of any
changes by checking the Federal Register or visit our title V websites at
www.epa.gov/ttn/oarpg/t5main.html and www.epa.gov/oar/oaqps/permits/.
What portions of the General Provisions apply?
The General Provisions were published in the Federal Register on March 16, 1994 (Volume 59, page
12408) and apply to all NESHAPs, including the primary aluminum rule.
This means that when you became subject to this rule, you also became subject to the General
Provisions. Some sections in this rule over-ride the General Provisions. You'll find that Appendix A
of the final rule shows you which sections of the General Provisions don't apply to this rule. General
Provision requirements, except for notification and reporting, are not addressed in this document.
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Chapter 10 - Getting additional help
Whom can I ask for help?
You can go to a lot of places for help, including all of the following:
! your State, local or Tribal agency for air pollution control
! your State's Small Business Assistance Program (SBAP)
! local, regional, or national trade associations
! your EPA Regional Office
State and local contacts can change frequently. To get the most current contact information, go to the
STAPPA/ALAPCO website (www.4cleanair.org) and then the membership directory. The directory
will give you the latest contact points for major air programs (that is, emission standards for toxic air
pollutants, ozone, etc.) at the State and local level.
If you have questions about this rule, you
should contact your State, local or Tribal
agency before calling the EPA. Their rules
may be more stringent than Federal
requirements.
The Trade
Association representing the primary aluminum industry is listed below. Trade associations sometimes
have rule information for their members.
Trade Association
The Aluminum Association
Telephone #
(202)862-5100
Address
900 19th Street, NW
Washington, B.C.
20006
Many States have a Small Business Assistance Program. If you're a small business and
don't know who your SBAP is, you can call EPA's Control Technology Center Hotline at
(919) 541-0800 or visit EPA's SBAP at www.epa.gov/oar/oaqps/sbap for help.
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Contact numbers for EPA's Regional Air Division Offices may also change frequently. To
obtain the most up-to-date information, you may want to visit your Regional Office's website.
Table 10.1 lists each of our Regional Offices, the Air Toxics Division Phone and Address,
and the Regions internet home page. Make all written inquiries to the attention of "Primary
Aluminum NESHAP Contact."
Can I get more information on the Web?
You can get a wealth of information on the World Wide Web (WWW). Some of the more popular
ways to get information on this rule include:
EPA's Unified Air Toxics Website (www.epa.gov/ttn/uatw)
You can download copies of preambles, regulations, background information documents,
policy memos, and other guidance materials here. All rule pages can be found under the Rules
and Implementation page.
EPA's Applicability Determination Index (ADI) (http://es.epa.gov/oeca/eptdd/adlhtml)
EPA's Office of Enforcement and Compliance Assurance (OECA) posts memos dealing with
applicability and compliance at this site.
STAPPA/ALAPCO home page (http://www.4cleanair.org)
STAPPA/ALAPCO is the State and Territorial Air Pollution Program Administrators
(STAPPA) and Local Air pollution Control Officials (ALAPCO) organization.
STAPPA/ALAPCO has members representing each State and local agency for air pollution
control.
You can get air pollution information at this site, including a document entitled
"Communicating Air Quality: A Compendium of Resources. " It lists educational materials
on air pollution that State and local agencies have created.
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Table 10.1 EPA Regional Air Division Offices
EPA
Region
Region I
Region II
Region III
Region IV
Region V
Region VI
Region VII
Region VIII
Region IX
Region X
States
Covered
CT, ME, MA,
NH, RI & VT
NJ, NY, Puerto
Rico & Virgin
Islands
DE, MD, PA,
VA, WV & DC
AL, FL, GA, KY,
MS, NC, SC &
TN
IL, IN, MI, WI,
MN&OH
AR, LA, NM,
OK&TX
IA, KS, MO &
NE
CO, MT, NO,
SD, UT & WY
AZ, CA, HI, NV,
American
Samoa, & Guam
AK, ID, WA &
OR
Division Phone and Address
Office of Environmental
Stewardship (OES)
1 Congress Street, Suite 1100
Boston, MA 021 14-2023
Division of Environmental Planning
and Protection
290 Broadway, 2 1st Floor
New York, NY 10007-1866
Air Protection Division, 3 API 2
1650 Arch Street
Philadelphia, PA 19103-2029
Air, Pesticides and Toxics
Management Division
Atlanta Federal Center
61 Forsyth Street
Atlanta, GA 30303-3104
Air and Radiation Division
77 West Jackson Blvd.
Chicago, IL 60604-3507
Multimedia Planning and Permitting
Division
1445 Ross Avenue
Dallas, TX 75202-2733
Air, RCRA and Toxics Division
901 North 5th Street
Kansas City, KS 66101
Office of Enforcement, Compliance
and Environmental Justice (ECEJ)
999 18th Street, 1 Denver Place,
Suite 500
Denver, CO 80202-2405
Air Division
75 Hawthorne Street
San Francisco, CA 94105
Office of Air Quality
1200 Sixth A venue
Seattle, WA 98101
Phone and Home
Page
(617)918-1510
www. epa. gov/region 1
(212)637-3735
www. epa. gov/region2
(215)814-2056
www. epa. gov/region3
(404) 562-9077
www. epa. gov/region4
(312)353-2212
www.epa.gov/region5
(214)665-7200
www.epa.gov/region6
(913)551-7020
www. epa. gov/region 7
(303)312-6051
www. epa. gov/region 8
(415)744-1219
www.epa.gov/region9
(206)553-1505
www. epa. gov/region 1 0
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Chapter 11 - Supplemental information for State or local agencies and Tribes
How many plants may need to meet emission limits?
According to information we collected up to 1997, we estimated that approximately 23 existing
primary aluminum plants in 14 States might be affected by this rule. You can find a list of plants that
may be affected by the rule in Table 11.1. We've included the list as a reference for you, not as an
official or complete list of regulated plants. You can see how many plants are in your state by going
to Figure 11.1.
EPA's "Enabling Document: Source Identification Procedures
for Sources Subject to Regulations Under Section 112(d) of the
Clean Air Act as Amended in 1990 ", September 20, 1996
(otherwise known as the "Cookbook "), can help you identify the
steps you can take to locate more sources.
You can download the cookbook by going to
www.epa.gov/ttn/uatw/eparules.html, scroll down until you see
"MACT Implementation Strategy".
How much HAP emissions will the rule reduce?
Nationwide emissions from primary aluminum potlines are estimated at 6,400 tpy of TF. We estimate
that full implementation of the rule will reduce these emissions by almost 50 percent. POM emissions
will be reduced by about 45 percent from their current level of about 3,200 tpy. TF and POM
emissions from bake furnaces are estimated at 700 and 555 tpy, respectively. After control of all bake
furnaces, we estimate a 97-percent reduction in TF emissions and an 84-percent reduction in POM.
POM emisisons from paste production plants will be reduced by about 130 tpy, to about 16 tpy - an 89
percent reduction from the current level.
Emissions of other F£APs included in TF and POM emissions also will be reduced as will non-HAP
pollutants such as particulate matter (PM). For example, PM emissions will be reduced by 16,000 tpy.
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TABLE 11.1. PRIMARY ALUMINUM PRODUCTION PLANTS IN THE U.S.
State
Plant name and location
Type of plant
Indiana
Kentucky
Maryland
Missouri
Montana
New York
North Carolina
Ohio
Oregon
South Carolina
Tennessee
Texas
Washington
West Virginia
Alcoa, Newburgh (Warrick)
NSA, Hawesville
Alcan, Henderson
Eastalco, Frederick (Alumax)
Noranda, New Madrid
Columbia Falls, Columbia Falls
Alcoa, Massena
Reynolds, Massena
Alcoa, Badin
Ormet, Hannibal
Reynolds, Troutdale
Northwest, The Dalles
Alumax, Goose Creek (Mount Holly)
Alcoa, Alcoa
Alcoa, Rockdale
Intalco, Ferndale (Alumax)
Kaiser, Mead
Kaiser, Tacoma
Alcoa, Wenatchee
Reynolds, Longview
Goldendale, Goldendale
Vanalco, Vancouver
Century, Ravenswood
Center-worked prebake
Center-worked prebake
Center-worked prebake
Side-worked prebake
Center-worked prebake
Vertical stud Soderberg
Center-worked prebake
Horizontal stud Soderberg
Center-worked prebake
Center-worked prebake
Center-worked prebake
Vertical stud Soderberg
Center-worked prebake
Center-worked prebake
Center-worked prebake
Side-worked prebake
Center-worked prebake
Horizontal stud Soderberg
Center-worked prebake
Horizontal stud Soderberg
Vertical stud Soderberg
Center-worked prebake
Center-worked prebake
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EPA Regions 6, 7, and 8
haYe 1 plant each;
Regions 2, 3, and 5 haYe 2
plants each;
Region 4 has 5 plants; and
Region 10 has 9 plants
Figure 11-1. There Are 23 Primary Aluminum Plants in 14 States
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APPENDIX A
WHERE TO FIND IT IN THE RULE
AND A COPY OF THE RULE
96
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WHERE TO FIND IT IN THE RULE
Note: Page and column numbers are keyed to the Federal Register promulgation notice of 10/7/97 in this
Appendix.
63.840
a
b
c
63.841
a
b
63.842
63.843
a
b
c
63.844
a
b
c
d
63.845
a
b
c
d
e
f
g
h
i
Provision
Applicability
All potlines, bake furnaces, and paste plants at major sources, except for b
Excludes one offsite bake furnace
NSPS - can comply with 63.845 or NSPS (subpart S in part 60)
Incorporation by reference
Vent manual and ASTM method
Where to get copies
Definitions
Emission limits for existing sources
Potlines (TF, POM; if subcategory changes)
Paste plants
Bake furnaces
Emission limits for new or reconstructed sources
Potlines
Paste plants
Bake furnaces
Pitch storage tanks
Incorporation of NSPS for potroom groups
Applies to new, modified, reconstructed potroom groups
Calculate lower TF limit
Calculate upper TF limit
Recalculate each time another potroom group is modified, reconstructed, or new
Emission limit
Report when between lower and upper limits
Procedures to determine TF emissions
10 percent opacity limit for potroom groups
How to set an alternative opacity limit
Page
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52409
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63.846
a
b
c
d
1
2
3
4
5
6
63.847
a
b
c
d
e
f
g
1
2
3
h
1
2
3
Provision
Emission averaging
May average if State does not exclude it
Procedures for potlines
Procedures for bake furnaces
Implementation plan
Deadlines
Contents
Approval criteria
Prohibitions
Term (allows plan to be revised; also can request averaging after the compliance date)
Operation
Performance tests
Compliance dates (2 years for all, 3 if you can show it is needed to install controls)
Test plan - includes test requirements, site-specific factors (multiple control devices or
stacks), frequency (separate by 6 days), and other testing details
Initial performance test (can use prior test of control devices)
Performance test requirements
Equations to calculate emissions and determine compliance
Paste plants - compliance demonstrated through site inspection and records
Pitch storage tanks
Parameters to be monitored
Documentation for design evaluation
Performance test requirements
Establish limit(s) for parameter monitoring of control devices
Establish limits for potlines and bake furnaces from historical data and performance
tests
Specify parameters for paste plant
How to redetermine operating limits and ask regulatory authority for a change
Page
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52410
52410
52411
52411
52411
52411
52411
52411
52411
52411
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63.848
a
b
c
d
e
f
g
h
i
j
k
1
m
63.849
a
1
2
3
4
5
6
7
b
c
d
e
Provision
Monitoring requirements
TF from potlines - monthly test
POM from Soderbergs - quarterly test
TF and POM from bake furnaces - annual test
Similar potlines - alternatives to monthly manual sampling described for POM and TF
How to get reduced sampling frequency
Monitoring devices - for wet and dry scrubbers, ESPs, and roof scrubbers
Inspect stacks each day for sign of visible emissions indicating abnormal operation
Initiate corrective actions if monitoring parameter exceeded or inspection finds a
problem
Violation if parameter exceeded in more than 6 days in any semiannual reporting
period
Monitor weight of aluminum and anodes
Monitoring devices must meet accuracy requirements
Alternative parameters to those specified may be approved by regulatory authority
Work with regulatory authority to establish parameters and limits for control devices
not specifically covered in (f)
Test methods
For TF and POM
Method 1 - velocity
Method 2 - volumetric flow
Method 3 - gas analysis
Method 13 A or B for TF from stacks
Method 13 A/B and Method 14 for TF from roof monitors (not roof scrubbers)
Method 3 15 for POM from stacks
Method 315 and Method 14 for POM from roof monitors (not roof scrubbers)
For roof scrubbers, sample using existing State methods, analyze by Method 13 (TF)
and Method 3 15 (POM)
In Method 14, "potroom group" means "potline" for this subpart
One Method 14 manifold per potline
Describes procedures to get an alternative method approved
Page
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52414
52414
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52414
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52415
52415
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63.850
a
b
c
d
e
63.851
a
b
63.852
63.853
Provision
Notification, reporting, and recordkeeping
Notifications
Performance test report
Startup, shutdown, and malfunction plan ( includes procedures for corrective actions if
monitoring parameter exceeded or inspection finds a problem)
Excess emissions report
Recordkeeping [includes records of parametric monitoring]
Regulatory authority review procedures
Regulatory authority must approve/disapprove submissions within 60 days
Regulatory authority must notify if complete/incomplete within 30 days
Applicability of General Provisions (Appendix A on p. 52418)
Delegation of authority — all delegated to the State
Page
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Tuesday
October 7, 1997
Part II
Environmental
Protection Agency
40 CFR Parts 9, 60, and 63
National Emission Standards for
Hazardous Air Pollutants for Source
Categories; National Emission Standards
for Hazardous Air Pollutants for Primary
Aluminum Reduction Plants; Final Rule
52383
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Federal Register / Vol. 62, No. 194 / Tuesday, October 7, 1997 / Rules and Regulations 52407
PART 63—NATIONAL EMISSION
STANDARDS FOR HAZARDOUS AIR
POLLUTANTS FOR SOURCE
CATEGORIES
7. The authority citation for part 63
continues to read as follows:
Authority: 42 U.S.C. 7401 et seq.
8. Part 63 is amended by adding
subpart LL to read as follows:
Subpart LL—National Emission Standards
for Hazardous Air Pollutants for Primary
Aluminum Reduction Plants
Sec.
63.840 Applicability.
63.841 Incorporation by reference.
63.842 Definitions.
63.843 Emission limits for existing sources.
63.844 Emission limits for new or
reconstructed sources.
63.845 Incorporation of new source
performance standards for potroom
groups.
63.846 Emission averaging.
63.847 Compliance provisions.
63.848 Emission monitoring requirements.
63.849 Test methods and procedures.
63.850 Notification, reporting, and
recordkeeping requirements.
63.851 Regulatory authority review
procedures.
63.852 Applicability of general provisions.
63.853 Delegation of authority.
63.854-63.859 [Reserved]
Table 1 to Subpart LL—Potline TF Limits for
Emission Averaging
Table 2 to Subpart LL—Potline POM Limits
for Emission Averaging
Table 3 to Subpart LL—Anode Bake Furnace
Limits for Emission Averaging
Appendix A to Subpart LL—
Applicability of General Provisions (40
CFR Part 63, Subpart A) to Subpart LL
Subpart LL—National Emission
Standards for Hazardous Air Pollutants
for Primary Aluminum Reduction
Plants
§63.840 Applicability.
(a) Except as provided in paragraph
(b) of this section, the requirements of
this subpart apply to the owner or
operator of each new pitch storage tank
and new or existing potline, paste
production plant, or anode bake furnace
associated with primary aluminum
production and located at a major
source as defined in § 63.2.
(b) The requirements of this subpart
do not apply to any existing anode bake
furnace that is not located on the same
site as a primary aluminum reduction
plant. The owner or operator shall
comply with the State MACT
determination established by the
applicable regulatory authority.
(c) An owner or operator of an
affected facility (potroom group or
anode bake furnace) under §60.190 of
this chapter may elect to comply with
either the requirements of §63.845 of
this subpart or the requirements of
subpart S of part 60 of this chapter.
§63.841 Incorporation by reference.
(a) The following material is
incorporated by reference in the
corresponding sections noted. This
incorporation by reference was
approved by the Director of the Federal
Register on October 7, 1997, in
accordance with 5 U.S.C. 552(a) and 1
CFR part 51. These materials are
incorporated as they exist on the date of
approval, and notice of any change in
the materials will be published in the
Federal Register. Revisions to
"Industrial Ventilation: A Manual of
Recommended Practice" (22nd ed.) are
applicable only after publication of a
document in the Federal Register to
amend subpart LL to require use of the
new information.
(1) Chapter 3, "Local Exhaust Hoods"
and Chapter 5, "Exhaust System Design
Procedure" of "Industrial Ventilation: A
Manual of Recommended Practice,"
American Conference of Governmental
Industrial Hygienists, 22nd edition,
1995, IBR approved for §§63.843(b) and
63.844(b);and
(2) ASTM D 2986-95A, Standard
Practice for Evaluation of Air Assay
Media by the Monodisperse OOP
(Dioctyl Phthalate) Smoke Test, IBR
approved for section 7.1.1 of Method
315 in appendix A to this part.
(b) The materials incorporated by
reference are available for inspection at
the Office of the Federal Register, 800
North Capitol Street NW., Suite 700, 7th
Floor, Washington, DC, and at the Air
and Radiation Docket Center, U.S. EPA,
401 M Street, SW., Washington, DC. The
materials also are available for purchase
from one of the following addresses:
(1) Customer Service Department,
American Conference of Governmental
Industrial Hygienists (ACGIH), 1330
Kemper Meadow Drive, Cincinnati,
Ohio 45240, telephone number (513)
742-2020; or
(2) American Society for Testing and
Materials, 100 Bar Harbour Drive, West
Conshohocken, Pennsylvania 19428,
telephone number (610) 832-9500.
§63.842 Definitions.
Terms used in this subpart are
defined in the Clean Air Act as
amended (the Act), in § 63.2, or in this
section as follows:
Anode bake furnace means an oven in
which the formed green anodes are
baked for use in a prebake process. This
definition includes multiple anode bake
furnaces controlled by a common
control device (bake furnaces controlled
by a common control device are
considered to be one source).
Center-worked prebake (CWPB)
process means a method of primary
aluminum reduction using the prebake
process in which the alumina feed is
added down the center of the reduction
cell.
Center-worked prebake one (CWPB1)
means all existing center-worked
prebake potlines not defined as center-
worked prebake two (CWPB2) or center-
worked prebake three (CWPB3) potlines.
Center-worked prebake two (CWPB2)
means all existing center-worked
prebake potlines located at Alcoa in
Rockdale, Texas; Kaiser Aluminum in
Mead, Washington; Ormet Corporation
in Hannibal, Ohio; Ravenswood
Aluminum in Ravenswood, West
Virginia; Reynolds Metals in Troutdale,
Oregon; and Vanalco Aluminum in
Vancouver, Washington.
Center-worked prebake three (CWPB3)
means all existing center-worked
prebake potlines that produce very high
purity aluminum, have a wet scrubber
for the primary control system, and are
located at the NSA primary aluminum
plant in Hawesville, Kentucky.
Continuous parameter monitoring
system means the total equipment that
may be required to meet the data
acquisition and availability
requirements of this subpart, used to
sample, condition (if applicable),
analyze, and provide a record of process
or control system parameters.
Horizontal stud Soderberg (HSS)
process means a method of primary
aluminum reduction using the
Soderberg process in which the
electrical current is introduced to the
anode by steel rods (studs) inserted into
the side of a monolithic anode.
Modified potroom group means an
existing potroom group to which any
physical change in, or change in the
method of operation of, results in an
increase in the amount of total fluoride
emitted into the atmosphere by that
potroom group.
Paste production plant means the
processes whereby calcined petroleum
coke, coal tar pitch (hard or liquid),
and/or other materials are mixed,
transferred, and formed into briquettes
or paste for vertical stud Soderberg
(VSS) and HSS processes or into green
anodes for a prebake process. This
definition includes all operations from
initial mixing to final forming (i.e.,
briquettes, paste, green anodes) within
the paste plant, including conveyors
and units managing heated liquid pitch.
Pitch storage tank means any fixed
roof tank that is used to store liquid
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52408 Federal Register / Vol. 62, No. 194 / Tuesday, October 7, 1997 / Rules and Regulations
pitch that is not part of the paste
production plant.
Polycyclic organic matter (POM)
means organic matter extractable by
methylene chloride as determined by
Method 315 in appendix A to this part
or by an approved alternative method.
Potline means a single, discrete group
of electrolytic reduction cells
electrically connected in series, in
which alumina is reduced to form
aluminum.
Potroom means a building unit that
houses a group of electrolytic cells in
which aluminum is produced.
Potroom group means an uncontrolled
potroom, a potroom that is controlled
individually, or a group of potrooms or
potroom segments ducted to a common
control system.
Prebake process means a method of
primary aluminum reduction that uses
an anode that was baked in an anode
bake furnace, which is introduced into
the top of the reduction cell and
consumed as part of the reduction
process.
Primary aluminum reduction plant
means any facility manufacturing
aluminum by electrolytic reduction.
Primary control system means the
equipment used to capture the gases and
particulate matter evacuated directly
from the reduction cell and the emission
control device (s) used to remove
pollutants prior to discharge of the
cleaned gas to the atmosphere. A roof
scrubber is not part of the primary
control system.
Primary emissions means the
emissions discharged from the primary
control system.
Reconstructed potroom group means
an existing potroom group for which the
components are replaced to such an
extent that the fixed capital cost of the
new components exceeds 50 percent of
the fixed capital cost that would be
required to construct a comparable
entirely new potroom group, and for
which it is technologically and
economically feasible to meet the
applicable emission limits for total
fluoride set forth in this subpart.
Reconstruction means the
replacement of components of a source
to such an extent that:
(1) All of the major components of the
source are replaced (for example, the
major components of a potline include
the raw material handling system,
reduction cells, superstructure, hooding,
ductwork, etc.); and
(2) It is technologically and
economically feasible for the
reconstructed source to meet the
standards for new sources established in
this subpart.
Roof monitor means that portion of
the roof of a potroom building where
gases not captured at the cell exit from
the potroom.
Secondary emissions means the
fugitive emissions that are not captured
and controlled by the primary control
system and that escape through the roof
monitor or through roof scrubbers.
Side-workedprebake (SWPB) process
means a method of primary aluminum
reduction using the prebake process, in
which the alumina is added along the
sides of the reduction cell.
Soderberg process means a method of
primary aluminum reduction in which
the anode paste mixture is baked in the
reduction pot by the heat resulting from
the electrolytic process.
Total fluorides (TF) means elemental
fluorine and all fluoride compounds as
measured by Methods 13A or 13B in
appendix A to part 60 of this chapter or
by an approved alternative method.
Vertical stud Soderberg (VSS) process
means a method of primary aluminum
reduction using the Soderberg process,
in which the electrical current is
introduced to the anode by steel rods
(studs) inserted into the top of a
monolithic anode.
Vertical stud Soderberg one (VSS1)
means all existing vertical stud
Soderberg potlines located either at
Northwest Aluminum in The Dalles,
Oregon, or at Goldendale Aluminum in
Goldendale, Washington.
Vertical stud Soderberg two (VSS2)
means all existing vertical stud
Soderberg potlines located at Columbia
Falls Aluminum in Columbia Falls,
Montana.
§63.843 Emission limits for existing
sources.
(a) Potlines. The owner or operator
shall not discharge or cause to be
discharged into the atmosphere any
emissions of TF or POM in excess of the
applicable limits in paragraphs (a)(l)
and (a) (2) of this section.
(1) TF limits. Emissions of TF shall
not exceed:
(i) 0.95kg/Mg(1.91b/ton) of
aluminum produced for each CWPB1
potline;
(ii) 1.5kg/Mg(3.01b/ton)of
aluminum produced for each CWPB2
potline;
(iii) 1.25 kg/Mg (2.5 Ib/ton) of
aluminum produced for each CWPB3
potline;
(iv) 0.8 kg/Mg (1.6 Ib/ton) of
aluminum produced for each SWPB
potline;
(v) 1.1 kg/Mg (2.2 Ib/ton) of aluminum
produced for each VSS1 potline;
(vi) 1.35 kg/Mg (2.7 Ib/ton) of
aluminum produced for each VSS2
potline; and
(vii) 1.35 kg/Mg (2.7 Ib/ton) of
aluminum produced for each HSS
potline.
(2) POM limits. Emissions of POM
shall not exceed:
(i) 2.35 kg/Mg (4.7 Ib/ton) of
aluminum produced for each HSS
potline;
(ii) 1.2 kg/Mg (2.4 Ib/ton) of
aluminum produced for each VSS1
potline; and
(iii) 1.8 kg/Mg (3.6 Ib/ton) of
aluminum produced for each VSS2
potline.
(3) Change in subcategory. Any
potline, other than a reconstructed
potline, that is changed such that its
applicable subcategory also changes
shall meet the applicable emission limit
in this subpart for the original
subcategory or the new subcategory,
whichever is more stringent.
(b) Paste production plants. The
owner or operator shall install, operate,
and maintain equipment to capture and
control POM emissions from each paste
production plant.
(1) The emission capture system shall
be installed and operated to meet the
generally accepted engineering
standards for minimum exhaust rates as
published by the American Conference
of Governmental Industrial Hygienists
in Chapters 3 and 5 of "Industrial
Ventilation: A Handbook of
Recommended Practice" (incorporated
by reference in §63.841 of this part);
and
(2) Captured emissions shall be routed
through a closed system to a dry coke
scrubber; or
(3) The owner or operator may submit
a written request for use of an
alternative control device to the
applicable regulatory authority for
review and approval. The request shall
contain information and data
demonstrating that the alternative
control device achieves POM emissions
less than 0.011 Ib/ton of paste for plants
with continuous mixers or POM
emissions less than 0.024 Ib/ton of paste
for plants with batch mixers. The POM
emission rate shall be determined by
sampling using Method 315 in appendix
A to this part.
(c) Anode bake furnaces. The owner
or operator shall not discharge or cause
to be discharged into the atmosphere
any emissions of TF or POM in excess
of the limits in paragraphs (c)(l) and
(c)(2) of this section.
(1) TF limit. Emissions of TF shall not
exceed 0.10 kg/Mg (0.20 Ib/ton) of green
anode; and
(2) POM limit. Emissions of POM
shall not exceed 0.09 kg/Mg (0.18 lb/
ton) of green anode.
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Federal Register / Vol. 62, No. 194 / Tuesday, October 7, 1997 / Rules and Regulations 52409
§ 63.844 Emission limits for new or
reconstructed sources.
(a) Potlines. The owner or operator
shall not discharge or cause to be
discharged into the atmosphere any
emissions of TF or POM in excess of the
limits in paragraphs (a)(l) and (a) (2) of
this section.
(1) TF limit. Emissions of TF shall not
exceed 0.6 kg/Mg (1.2 Ib/ton) of
aluminum produced; and
(2) POM limit. Emissions of POM from
Soderberg potlines shall not exceed 0.32
kg/Mg (0.63 Ib/ton) of aluminum
produced.
(b) Paste production plants. The
owner or operator shall meet the
requirements in § 63.843(b) for existing
paste production plants.
(c) Anode bake furnaces. The owner
or operator shall not discharge or cause
to be discharged into the atmosphere
any emissions of TF or POM in excess
of the limits in paragraphs (c)(l) and
(c)(2) of this section.
(1) TF limit. Emissions of TF shall not
exceed 0.01 kg/Mg (0.02 Ib/ton) of green
anode; and
(2) POM limit. Emissions of POM
shall not exceed 0.025 kg/Mg (0.05 lb/
ton) of green anode.
(d) Pitch storage tanks. Each pitch
storage tank shall be equipped with an
emission control system designed and
operated to reduce inlet emissions of
POM by 95 percent or greater.
§ 63.845 Incorporation of new source
performance standards for potroom groups.
(a) Applicability. The provisions in
paragraphs (a) through (i) of this section
shall apply to any Soderberg, CWPB2,
and CWPB3 potline that adds a new
potroom group to an existing potline or
that is associated with a potroom group
that meets the definition of "modified
potroom group" or "reconstructed
potroom group."
(1) The following shall not, by
themselves, be considered to result in a
potroom group modification:
(i) Maintenance, repair, and
replacement that the applicable
regulatory authority determines to be
routine for the potroom group;
(ii) An increase in production rate of
an existing potroom group, if that
increase can be accomplished without a
capital expenditure on that potroom
group;
(iii) An increase in the hours of
operation;
(iv) Use of an alternative fuel or raw
material if, prior to the effective date of
this subpart, the existing potroom group
was designed to accommodate that
alternative use;
(v) The addition or use of any system
or device whose primary function is the
reduction of air pollutants, except when
an emission control system is removed
or is replaced by a system that the
applicable regulatory authority
determines to be less environmentally
beneficial; and
(vi) The relocation or change in
ownership of an existing potroom
group.
(2) The provisions in paragraphs
(a)(2)(i) through (a)(2)(iv) of this section
apply when the applicable regulatory
authority must determine if a potroom
group meets the definition of
reconstructed potroom group.
(i) "Fixed capital cost" means the
capital needed to provide all the
depreciable components.
(ii) If an owner or operator of an
existing potroom group proposes to
replace components, and the fixed
capital cost of the new components
exceeds 50 percent of the fixed capital
cost that would be required to construct
a comparable entirely new potroom
group, he/she shall notify the applicable
regulatory authority of the proposed
replacements. The notice must be
postmarked 60 days (or as soon as
practicable) before construction of the
replacements is commenced and must
include the following information:
(A) Name and address of the owner or
operator;
(B) The location of the existing
potroom group;
(C) A brief description of the existing
potroom group and the components that
are to be replaced;
(D) A description of the existing air
pollution control equipment and the
proposed air pollution control
equipment;
(E) An estimate of the fixed capital
cost of the replacements and of
constructing a comparable entirely new
potroom group;
(F) The estimated life of the existing
potroom group after the replacements;
and
(G) A discussion of any economic or
technical limitations the potroom group
may have in complying with the
applicable standards of performance
after the proposed replacements.
(iii) The applicable regulatory
authority will determine, within 30 days
of the receipt of the notice required by
paragraph (a) (2) (ii) of this section and
any additional information he/she may
reasonably require, whether the
proposed replacement constitutes a
reconstructed potroom group.
(iv) The applicable regulatory
authority's determination under
paragraph (a) (2) (iii) of this section shall
be based on:
(A) The fixed capital cost of the
replacements in comparison to the fixed
capital cost that would be required to
construct a comparable entirely new
potroom group;
(B) The estimated life of the potroom
group after the replacements compared
to the life of a comparable entirely new
potroom group;
(C) The extent to which the
components being replaced cause or
contribute to the emissions from the
potroom group; and
(D) Any economic or technical
limitations on compliance with
applicable standards of performance
that are inherent in the proposed
replacements.
(b) Lower TF emission limit. The
owner or operator shall calculate a
lower TF emission limit for any potline
associated with the modified potroom
group, reconstructed potroom group, or
new potroom group using the following
equation:
L1=f! xLpoi + (1-fi) xLpL
Where
Li=the lower TF emission limit in kg/
Mg (Ib/ton);
fi=the fraction of the potline's total
aluminum production capacity that
is contained within all modified
potroom groups, reconstructed
potroom groups, and new potroom
groups;
Lpoi=0.95 kg/Mg (1.9 Ib/ton) for prebake
potlines and 1.0 kg/Mg (2.0 Ib/ton)
for Soderberg potlines; and
LPL=the TF emission limit from
§63.843(a)(l) for the appropriate
potline subcategory that would
have otherwise applied to the
potline.
(c) Upper TF emission limit. The
owner or operator shall calculate an
upper TF emission limit for any potline
associated with the modified potroom
group, reconstructed potroom group, or
new potroom group using the following
equation:
L2=fi x Lpo2 + (1 - fi) x LPL
Where
L2=the upper TF emission limit in kg/
Mg (Ib/ton); and
Lpo2=1.25 kg/Mg (2.5 Ib/ton) for prebake
potlines and 1.3 kg/Mg (2.6 Ib/ton)
for Soderberg potlines.
(d) Recalculation. The TF emission
limits in paragraphs (b) and (c) of this
section shall be recalculated each time
a new potroom group is added to the
potline and each time an additional
potroom group meets the definition of
"modified potroom group" or
"reconstructed potroom group."
(e) Emission limitation. The owner or
operator shall not discharge or cause to
be discharged into the atmosphere
emissions of TF from any potline
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52410 Federal Register / Vol. 62, No. 194 / Tuesday, October 7, 1997 / Rules and Regulations
associated with the modified potroom
group, reconstructed potroom group, or
new potroom group that exceed the
lower emission limit calculated in
paragraph (b) of this section, except that
emissions less than the upper limit
calculated in paragraph (c) of this
section will be considered in
compliance if the owner or operator
demonstrates that exemplary operation
and maintenance procedures were used
with respect to the emission control
system and that proper control
equipment was operating at the potline
during the performance test.
(f) Report. Within 30 days of any
performance test that reveals emissions
that fall between the lower limit
calculated in paragraph (b) of this
section and the upper limit calculated
in paragraph (c) of this section, the
owner or operator shall submit to the
applicable regulatory authority a report
indicating whether all necessary control
devices were online and operating
properly during the performance test,
describing the operating and
maintenance procedures followed, and
setting forth any explanation for the
excess emissions.
(g) Procedures to determine TF
emissions. The owner or operator shall
determine TF emissions for the potline
using the following procedures:
(1) Determine the emission rate of TF
in kg/Mg (Ib/ton) from sampling
secondary emissions and the primary
control system for all new potroom
groups, modified potroom groups, and
reconstructed potroom groups using the
procedures, equations, and test methods
in §§63.847, 63.848, and 63.849.
(2) Determine the emission rate of TF
in kg/Mg (Ib/ton) from sampling
secondary emissions and the primary
control system for potroom groups or
sections of potroom groups within the
potline that are not new potroom
groups, modified potroom groups, or
reconstructed potroom groups according
to paragraphs (g) (2) (i) or (g) (2) (ii) of this
section.
(i) Determine the mass emission rate
of TF in kg/Mg (Ib/ton) from at least one
potroom group within the potline that is
not a new potroom group, modified
potroom group, or reconstructed
potroom group using the procedures,
equations, and test methods in
§§63.847, 63.848, and 63.849, or
(ii) Use the results of the testing
required by paragraph (g)(l) of this
section to represent the entire potline
based on a demonstration that the
results are representative of the entire
potline. Representativeness shall be
based on snowing that all of the
potroom groups associated with the
potline are substantially equivalent in
terms of their structure, operability, type
of emissions, volume of emissions, and
concentration of emissions.
(3) Calculate the TF emissions for the
potline in kg/Mg (Ib/ton) based on the
production-weighted average of the TF
emission rates from paragraphs (g)(l)
and (g) (2) of this section using the
following equation:
E=fixEpGi + (l-f1)xEpL
where
E=the TF emission rate for the entire
potline, kg/Mg (Ib/ton);
fi=the fraction of the potline's total
aluminum production rate that is
contained within all modified
potroom groups, reconstructed
potroom groups, and new potroom
groups;
Epoi=the TF emission rate from
paragraph (g)(l) of this section for
all modified potroom groups,
reconstructed potroom groups, and
new potroom groups, kg/Mg (lb/
ton); and
EPL=the TF emission rate for the balance
of the potline from paragraph (g) (2)
of this section, kg/Mg (Ib/ton).
Compliance is demonstrated when TF
emissions for the potline meet the
requirements in paragraph (e) of this
section.
(4) As an alternative to sampling as
required in paragraphs (g)(l) and (g)(2)
of this section, the owner or operator
may perform representative sampling of
the entire potline subject to the approval
of the applicable regulatory authority.
Such sampling shall provide coverage
by the sampling equipment of both the
new, modified, or reconstructed
potroom group and the balance of the
potline. The coverage for the new,
modified, or reconstructed potroom
group must meet the criteria specified in
the reference methods in § 63.849. TF
emissions shall be determined for the
potline using the procedures, equations,
and test methods in §§ 63.847, 63.848,
and 63.849. Compliance is
demonstrated when TF emissions for
the potline meet the requirements in
paragraph (e) of this section.
(h) Opacity. Except as provided in
paragraph (i) of this section, the owner
or operator shall not discharge or cause
to be discharged into the atmosphere
from the modified potroom group,
reconstructed potroom group, or new
potroom group any emissions of gases
that exhibit 10 percent opacity or
greater.
(i) Alternative opacity limit. An
alternative opacity limit may be
established in place of the opacity limit
in paragraph (h) of this section using the
following procedures:
(1) If the regulatory authority finds
that a potline is in compliance with the
applicable TF standard for which
performance tests are conducted in
accordance with the methods and
procedures in § 63.849 but during the
time such performance tests are being
conducted fails to meet any applicable
opacity standard, the regulatory
authority shall notify and advise the
owner or operator that he/she may
petition the regulatory authority within
10 days of receipt of notification to
make appropriate adjustment to the
opacity standard.
(2) The regulatory authority will grant
such a petition upon a demonstration by
the owner or operator that the potroom
group and associated air pollution
control equipment were operated and
maintained in a manner to minimize the
opacity of emissions during the
performance tests; that the performance
tests were performed under the
conditions established by the regulatory
authority; and that the potroom group
and associated air pollution control
equipment were incapable of being
adjusted or operated to meet the
applicable opacity standard.
(3) As indicated by the performance
and opacity tests, the regulatory
authority will establish an opacity
standard for any potroom group meeting
the requirements in paragraphs (i)(l)
and (i) (2) of this section such that the
opacity standard could be met by the
potroom group at all times during which
the potline is meeting the TF emission
limit.
(4) The alternative opacity limit
established in paragraph (i) (3) of this
section shall not be greater than 20
percent opacity.
§63.846 Emission averaging.
(a) General. The owner or operator of
an existing potline or anode bake
furnace in a State that does not choose
to exclude emission averaging in the
approved operating permit program may
demonstrate compliance by emission
averaging according to the procedures in
this section.
(b) Potlines. The owner or operator
may average TF emissions from potlines
and demonstrate compliance with the
limits in Table 1 of this subpart using
the procedures in paragraphs (b)(l) and
(b)(2) of this section. The owner or
operator also may average POM
emissions from potlines and
demonstrate compliance with the limits
in Table 2 of this subpart using the
procedures in paragraphs (b)(l) and
(b)(3) of this section.
(1) Monthly average emissions of TF
and/or quarterly average emissions of
POM shall not exceed the applicable
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Federal Register / Vol. 62, No. 194 / Tuesday, October 7, 1997 / Rules and Regulations 52411
emission limit in Table 1 of this subpart
(for TF emissions) and/or Table 2 of this
subpart (for POM emissions). The
emission rate shall be calculated based
on the total emissions from all potlines
over the period divided by the quantity
of aluminum produced during the
period, from all potlines comprising the
averaging group.
(2) To determine compliance with the
applicable emission limit in Table 1 of
this subpart for TF emissions, the owner
or operator shall determine the monthly
average emissions (in Ib/ton) from each
potline from at least three runs per
potline each month for TF secondary
emissions using the procedures and
methods in §§ 63.847 and 63.849. The
owner or operator shall combine the
results of secondary TF monthly average
emissions with the TF results for the
primary control system and divide total
emissions by total aluminum
production.
(3) To determine compliance with the
applicable emission limit in Table 2 of
this subpart for POM emissions, the
owner or operator shall determine the
quarterly average emissions (in Ib/ton)
from each potline from at least one run
each month for POM emissions using
the procedures and methods in
§§63.847 and 63.849. The owner or
operator shall combine the results of
secondary POM quarterly average
emissions with the POM results for the
primary control system and divide total
emissions by total aluminum
production.
(c) Anode bake furnaces. The owner
or operator may average TF emissions
from anode bake furnaces and
demonstrate compliance with the limits
in Table 3 of this subpart using the
procedures in paragraphs (c)(l) and
(c)(2) of this section. The owner or
operator also may average POM
emissions from anode bake furnaces and
demonstrate compliance with the limits
in Table 3 of this subpart using the
procedures in paragraphs (c)(l) and
(c)(2) of this section.
(1) Annual emissions of TF and/or
POM from a given number of anode
bake furnaces making up each averaging
group shall not exceed the applicable
emission limit in Table 3 of this subpart
in any one year; and
(2) To determine compliance with the
applicable emission limit in Table 3 of
this subpart for anode bake furnaces, the
owner or operator shall determine TF
and/or POM emissions from the control
device for each furnace at least once a
year using the procedures and methods
in §§63.847 and 63.849.
(d) Implementation plan. The owner
or operator shall develop and submit an
implementation plan for emission
averaging to the applicable regulatory
authority for review and approval
according to the following procedures
and requirements:
(1) Deadlines. The owner or operator
must submit the implementation plan
no later than 6 months before the date
that the facility intends to comply with
the emission averaging limits.
(2) Contents. The owner or operator
shall include the following information
in the implementation plan or in the
application for an operating permit for
all emission sources to be included in
an emissions average:
(i) The identification of all emission
sources (potlines or anode bake
furnaces) in the average;
(ii) The assigned TF or POM emission
limit for each averaging group of
potlines or anode bake furnaces;
(iii) The specific control technology or
pollution prevention measure to be used
for each emission source in the
averaging group and the date of its
installation or application. If the
pollution prevention measure reduces
or eliminates emissions from multiple
sources, the owner or operator must
identify each source;
(iv) The test plan for the measurement
of TF or POM emissions in accordance
with the requirements in § 63.847(b);
(v) The operating parameters to be
monitored for each control system or
device and a description of how the
operating limits will be determined;
(vi) If the owner or operator requests
to monitor an alternative operating
parameter pursuant to § 63.848(1):
(A) A description of the parameter(s)
to be monitored and an explanation of
the criteria used to select the
parameter(s); and
(B) A description of the methods and
procedures that will be used to
demonstrate that the parameter
indicates proper operation of the control
device; the frequency and content of
monitoring, reporting, and
recordkeeping requirements; and a
demonstration, to the satisfaction of the
applicable regulatory authority, that the
proposed monitoring frequency is
sufficient to represent control device
operating conditions; and
(vii) A demonstration that compliance
with each of the applicable emission
limit(s) will be achieved under
representative operating conditions.
(3) Approval criteria. Upon receipt,
the regulatory authority shall review
and approve or disapprove the plan or
permit application according to the
following criteria:
(i) Whether the content of the plan
includes all of the information specified
in paragraph (d)(2) of this section; and
(ii) Whether the plan or permit
application presents sufficient
information to determine that
compliance will be achieved and
maintained.
(4) Prohibitions. The applicable
regulatory authority shall not approve
an implementation plan or permit
application containing any of the
following provisions:
(i) Any averaging between emissions
of differing pollutants or between
differing sources. Emission averaging
shall not be allowed between TF and
POM, and emission averaging shall not
be allowed between potlines and bake
furnaces;
(ii) The inclusion of any emission
source other than an existing potline or
existing anode bake furnace or the
inclusion of any potline or anode bake
plant not subject to the same operating
permit;
(iii) The inclusion of any potline or
anode bake furnace while it is shut
down; or
(iv) The inclusion of any periods of
startup, shutdown, or malfunction, as
described in the startup, shutdown, and
malfunction plan required by
§63.850(c), in the emission calculations.
(5) Term. Following review, the
applicable regulatory authority shall
approve the plan or permit application,
request changes, or request additional
information. Once the applicable
regulatory authority receives any
additional information requested, the
applicable regulatory authority shall
approve or disapprove the plan or
permit application within 120 days.
(i) The applicable regulatory authority
shall approve the plan for the term of
the operating permit;
(ii) To revise the plan prior to the end
of the permit term, the owner or
operator shall submit a request to the
applicable regulatory authority; and
(iii) The owner or operator may
submit a request to the applicable
regulatory authority to implement
emission averaging after the applicable
compliance date.
(6) Operation. While operating under
an approved implementation plan, the
owner or operator shall monitor the
operating parameters of each control
system, keep records, and submit
periodic reports as required for each
source subject to this subpart.
§63.847 Compliance provisions.
(a) Compliance dates. The owner or
operator of a primary aluminum plant
shall demonstrate initial compliance
with the requirements of this subpart
by:
(1) October 7, 1999, for an owner or
operator of an existing plant or source;
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52412 Federal Register / Vol. 62, No. 194 / Tuesday, October 7, 1997 / Rules and Regulations
(2) October 9, 2000, for an existing
source, provided the owner or operator
demonstrates to the satisfaction of the
applicable regulatory authority that
additional time is needed to install or
modify the emission control equipment;
(3) October 8, 2001, for an existing
source that is granted an extension by
the regulatory authority under section
112(i)(3)(B) of the Act; or
(4) Upon startup, for an owner or
operator of a new or reconstructed
source.
(b) Test plan. The owner or operator
shall prepare a site-specific test plan
prior to the initial performance test
according to the requirements of
§63.7(c) of this part. The test plan must
include procedures for conducting the
initial performance test and for
subsequent performance tests required
in § 63.848 for emission monitoring. In
addition to the information required by
§ 63.7, the test plan shall include:
(1) Procedures to ensure a minimum
of three runs are performed annually for
the primary control system for each
source;
(2) For a source with a single control
device exhausted through multiple
stacks, procedures to ensure that at least
three runs are performed annually by a
representative sample of the stacks
satisfactory to the applicable regulatory
authority;
(3) For multiple control devices on a
single source, procedures to ensure that
at least one run is performed annually
for each control device by a
representative sample of the stacks
satisfactory to the applicable regulatory
authority;
(4) Procedures for sampling single
stacks associated with multiple anode
bake furnaces;
(5) For plants with roof scrubbers,
procedures for rotating sampling among
the scrubbers or other procedures to
obtain representative samples as
approved by the applicable regulatory
authority;
(6) For a VSS1 potline, procedures to
ensure that one fan (or one scrubber) per
potline is sampled for each run;
(7) For a SWPB potline, procedures to
ensure that the average of the sampling
results for two fans (or two scrubbers)
per potline is used for each run; and
(8) Procedures for establishing the
frequency of testing to ensure that at
least one run is performed before the
15th of the month, at least one run is
performed after the 15th of the month,
and that there are at least 6 days
between two of the runs during the
month, or that secondary emissions are
measured according to an alternate
schedule satisfactory to the applicable
regulatory authority.
(c) Initial performance test. Following
approval of the site-specific test plan,
the owner or operator shall conduct an
initial performance test during the first
month following the compliance date in
accordance with the procedures in
paragraph (d) of this section. If a
performance test has been conducted on
the primary control system for potlines
or for the anode bake furnace within the
12 months prior to the compliance date,
the results of that performance test may
be used to determine initial compliance.
(d) Performance test requirements.
The initial performance test and all
subsequent performance tests shall be
conducted in accordance with the
requirements of the general provisions
in subpart A of this part, the approved
test plan, and the procedures in this
section.
(1) TF emissions from potlines. For
each potline, the owner or operator shall
measure and record the emission rate of
TF exiting the outlet of the primary
control system for each potline and the
rate of secondary emissions exiting
through each roof monitor, or for a plant
with roof scrubbers, exiting through the
scrubbers. Using the equation in
paragraph (e)(l) of this section, the
owner or operator shall compute and
record the average of at least three runs
each month for secondary emissions
and at least three runs each year for the
primary control system to determine
compliance with the applicable
emission limit. Compliance is
demonstrated when the emission rate of
TF is equal to or less than the applicable
emission limit in §§ 63.843, 63.844, or
63.846.
(2) POM emissions from Soderberg
potlines. For each Soderberg (HSS,
VSS1, and VSS2) potline, the owner or
operator shall measure and record the
emission rate of POM exiting the
primary emission control system and
the rate of secondary emissions exiting
through each roof monitor, or for a plant
with roof scrubbers, exiting through the
scrubbers. Using the equation in
paragraph (e)(2) of this section, the
owner or operator shall compute and
record the average of at least three runs
each quarter (one run per month) for
secondary emissions and at least three
runs each year for the primary control
system to determine compliance with
the applicable emission limit.
Compliance is demonstrated when the
emission rate of POM is equal to or less
than the applicable emission limit in
§§63.843, 63.844, or 63.846.
(3) Previous control device tests. If the
owner or operator has performed more
than one test of primary emission
control device (s) for a potline or for a
bake furnace during the previous
consecutive 12 months, the average of
all runs performed in the previous 12-
month period shall be used to determine
the contribution from the primary
emission control system.
(4) TF and POM emissions from
anode bake furnaces. For each anode
bake furnace, the owner or operator
shall measure and record the emission
rate of TF and POM exiting the exhaust
stacks(s) of the primary emission control
system for each anode bake furnace.
Using the equations in paragraphs (e) (3)
and (e)(4) of this section, the owner or
operator shall compute and record the
average of at least three runs each year
to determine compliance with the
applicable emission limits for TF and
POM. Compliance is demonstrated
when the emission rates of TF and POM
are equal to or less than the applicable
TF and POM emission limits in
§§63.843, 63.844, or 63.846.
(e) Equations. The owner or operator
shall determine compliance with the
applicable TF and POM emission limits
using the following equations and
procedures:
(1) Compute the emission rate (Ep) of
TF from each potline using Equation 1:
EP =
[(CslxQsd)1+(Cs2xQsd)2]
(PxK)
(Equation 1)
Where
Ep=emission rate of TF from a potline,
kg/Mg (Ib/ton);
Csi=concentration of TF from the
primary control system, mg/dscm
(mg/dscf);
Qsd=volumetric flow rate of effluent gas
corresponding to the appropriate
subscript location, dscm/hr (dscf/
hr);
CS2=concentration of TF as measured for
roof monitor emissions, mg/dscm
(mg/dscf);
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Federal Register / Vol. 62, No. 194 / Tuesday, October 7, 1997 / Rules and Regulations 52413
P=aluminum production rate, Mg/hr
(ton/hr);
Reconversion factor, 106 mg/kg
(453,600 mg/lb);
i = subscript for primary control system
effluent gas; and
2 = subscript for secondary control
system or roof monitor effluent gas.
(2) Compute the emission rate of POM
from each potline using Equation 1,
Where:
Ep = emission rate of POM from the
potline, kg/mg (Ib/ton); and
Cs = concentration of POM, mg/dscm
(mg/dscf). POM emission data
collected during the installation
and startup of a cathode shall not be
included in Cs.
(3) Compute the emission rate (Eb) of
TF from each anode bake furnace using
Equation 2,
(CsxQ
sen
(PbxK)
(Equation 2)
Where:
Eb = emission rate of TF, kg/mg (Ib/ton)
of green anodes produced;
Cs = concentration of TF, mg/dscm (mg/
dscf);
Qsd = volumetric flow rate of effluent
gas, dscm/hr (dscf/hr);
Pb = quantity of green anode material
placed in the furnace, mg/hr (ton/
hr); and
K = conversion factor, 106 mg/kg
(453,600 mg/lb).
(4) Compute the emission rate of POM
from each anode bake furnace using
Equation 2,
Where:
Cs = concentration of POM, mg/dscm
(mg/dscf).
(5) Determine the weight of the
aluminum tapped from the potline and
the weight of the green anode material
placed in the anode bake furnace using
the monitoring devices required in
§63.848(j).
(6) Determine the aluminum
production rate (P) by dividing the
number of hours in the calendar month
into the weight of aluminum tapped
from the potline during the calendar
month that includes the three runs of a
performance test.
(7) Determine the rate of green anode
material introduced into the furnace by
dividing the number of operating hours
in the calendar month into the weight
of green anode material used during the
calendar month in which the
performance test was conducted.
(f) Paste production plants. Initial
compliance with the standards for
existing and new paste production
plants in §§63.843(b) and 63.844(b) will
be demonstrated through site
inspection(s) and review of site records
by the applicable regulatory authority.
(g) Pitch storage tanks. The owner or
operator shall demonstrate initial
compliance with the standard for pitch
storage tanks in §63.844(d) by preparing
a design evaluation or by conducting a
performance test. The owner or operator
shall submit for approval by the
regulatory authority the information
specified in paragraph (g)(l) of this
section, along with the information
specified in paragraph (g) (2) of this
section where a design evaluation is
performed or the information specified
in paragraph (g)(3) of this section where
a performance test is conducted.
(1) A description of the parameters to
be monitored to ensure that the control
device is being properly operated and
maintained, an explanation of the
criteria used for selection of that
parameter (or parameters), and the
frequency with which monitoring will
be performed; and
(2) Where a design evaluation is
performed, documentation
demonstrating that the control device
used achieves the required control
efficiency during reasonably expected
maximum filling rate. The
documentation shall include a
description of the gas stream that enters
the control device, including flow and
POM content under varying liquid level
conditions, and the information
specified in paragraphs (g) (2) (i) through
(g)(2)(vi) of this section, as applicable.
(i) If the control device receives
vapors, gases, or liquids, other than
fuels, from emission points other than
pitch storage tanks, the efficiency
demonstration is to include
consideration of all vapors, gases, and
liquids, other than fuels, received by the
control device;
(ii) If an enclosed combustion device
with a minimum residence time of 0.5
seconds and a minimum temperature of
760°C (1,400°F) is used to meet the
emission reduction requirement
specified in §83.844(d), documentation
that those conditions exist is sufficient
to meet the requirements of §83.844(d);
(iii) Except as provided in paragraph
(g) (2) (ii) of this section, for thermal
incinerators, the design evaluation shall
include the autoignition temperature of
the organic HAP, the flow rate of the
organic HAP emission stream, the
combustion temperature, and the
residence time at the combustion
temperature;
(iv) If the pitch storage tank is vented
to the emission control system installed
for control of emissions from the paste
production plant pursuant to
§63.843(b), documentation of
compliance with the requirements of
§ 63.843(b) is sufficient to meet the
requirements of § 63.844(d);
(v) For carbon adsorbers, the design
evaluation shall include the affinity of
the organic vapors for carbon, the
amount of carbon in each bed, the
number of beds, the humidity of the
feed gases, the temperature of the feed
gases, the flow rate of the organic HAP
emission stream, and if applicable, the
desorption schedule, the regeneration
stream pressure or temperature, and the
flow rate of the regeneration stream. For
vacuum desorption, the pressure drop
shall be included; and
(vi) For condensers, the design
evaluation shall include the final
temperature of the organic HAP vapors,
the type of condenser, and the design
flow rate of the organic HAP emission
stream.
(3) If a performance test is conducted,
the owner or operator shall determine
the control efficiency for POM during
tank loading using Method 315 in
appendix A to this part. The owner or
operator shall include the following
information:
(i) Identification of the pitch storage
tank and control device for which the
performance test will be submitted; and
(ii) Identification of the emission
point(s) that share the control device
with the pitch storage tank and for
which the performance test will be
conducted.
(h) Selection of monitoring
parameters. The owner or operator shall
determine the operating limits and
monitoring frequency for each control
device that is to be monitored as
required in §63.848(1).
(1) For potlines and anode bake
furnaces, the owner or operator shall
determine upper and/or lower operating
limits, as appropriate, for each
monitoring device for the emission
control system from the values recorded
during each of the runs performed
during the initial performance test and
from historical data from previous
performance tests conducted by the
methods specified in this subpart.
(2) For a paste production plant, the
owner or operator shall specify and
provide the basis or rationale for
selecting parameters to be monitored
and the associated operating limits for
the emission control device.
(3) The owner or operator may
redetermine the upper and/or lower
operating limits, as appropriate, based
on historical data or other information
and submit an application to the
applicable regulatory authority to
change the applicable limit(s). The
redetermined limits shall become
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52414 Federal Register / Vol. 62, No. 194 / Tuesday, October 7, 1997 / Rules and Regulations
effective upon approval by the
applicable regulatory authority.
§63.848 Emission monitoring
requirements.
(a) TF emissions from potlines. Using
the procedures in § 63.847 and in the
approved test plan, the owner or
operator shall monitor emissions of TF
from each potline by conducting
monthly performance tests. The owner
or operator shall compute and record
the monthly average from at least three
runs for secondary emissions and the
previous 12-month average of all runs
for the primary control system to
determine compliance with the
applicable emission limit. The owner or
operator must include all valid runs in
the monthly average. The duration of
each run for secondary emissions must
represent a complete operating cycle.
(b) POM emissions from Soderberg
potlines. Using the procedures in
§ 63.847 and in the approved test plan,
the owner or operator shall monitor
emissions of POM from each Soderberg
(HSS, VSS1, and VSS2) potline every
three months. The owner or operator
shall compute and record the quarterly
(3-month) average from at least one run
per month for secondary emissions and
the previous 12-month average of all
runs for the primary control systems to
determine compliance with the
applicable emission limit. The owner or
operator must include all valid runs in
the quarterly (3-month) average. The
duration of each run for secondary
emissions must represent a complete
operating cycle. The primary control
system must be sampled over an 8-hour
period, unless site-specific factors
dictate an alternative sampling time
subject to the approval of the regulatory
authority.
(c) TF and POM emissions from anode
bake furnaces. Using the procedures in
§ 63.847 and in the approved test plan,
the owner or operator shall monitor TF
and POM emissions from each anode
bake furnace on an annual basis. The
owner or operator shall compute and
record the annual average of TF and
POM emissions from at least three runs
to determine compliance with the
applicable emission limits. The owner
or operator must include all valid runs
in the annual average.
(d) Similar potlines. As an alternative
to monthly monitoring of TF or POM
secondary emissions from each potline
using the test methods in § 63.849, the
owner or operator may perform monthly
monitoring of TF or POM secondary
emissions from one potline using the
test methods in §§ 63.849 (a) or (b) to
represent the performance of similar
potline(s). The similar potline(s) shall
be monitored using an alternative
method that meets the requirements of
paragraphs (d)(l) through (d)(7) of this
section. Two or more potlines are
similar if the owner or operator
demonstrates that their structure,
operability, type of emissions, volume
of emissions, and concentration of
emissions are substantially equivalent.
(1) To demonstrate (to the satisfaction
of the regulatory authority) that the level
of emission control performance is the
same or better, the owner or operator
shall perform an emission test using an
alternative monitoring procedure for the
similar potline simultaneously with an
emission test using the applicable test
methods. The results of the emission
test using the applicable test methods
must be in compliance with the
applicable emission limit for existing or
new potlines in §§ 63.843 or 63.844. An
alternative method:
(i) For TF emissions, must account for
or include gaseous fluoride and cannot
be based on measurement of particulate
matter or particulate fluoride alone; and
(ii) For TF and POM emissions, must
meet or exceed Method 14 criteria.
(2) An HF continuous emission
monitoring system is an approved
alternative for the monitoring of TF
secondary emissions.
(3) An owner or operator electing to
use an alternative monitoring procedure
shall establish an alternative emission
limit based on at least nine
simultaneous runs using the applicable
test methods and the alternative
monitoring method. All runs must
represent a full process cycle.
(4) The owner or operator shall derive
an alternative emission limit for the HF
continuous emission monitor or an
alternative method using either of the
following procedures:
(i) Use the highest value from the
alternative method associated with a
simultaneous run by the applicable test
method that does not exceed the
applicable emission limit; or
(ii) Correlate the results of the two
methods (the applicable test method
results and the alternative monitoring
method results) and establish an
emission limit for the alternative
monitoring system that corresponds to
the applicable emission limit.
(5) The owner or operator shall
submit the results required in paragraph
(d) (4) of this section and all supporting
documentation to the applicable
regulatory authority for review and
approval.
(6) The regulatory authority shall
review and approve or disapprove the
request for an alternative method and
alternative emission limit. The criterion
for approval shall be a demonstration (to
the satisfaction of the regulatory
authority) that the alternative method
and alternative emission limit achieve a
level of emission control that is the
same as or better than the level that
would have otherwise been achieved by
the applicable method and emission
limit.
(7) If the alternative method is
approved by the applicable regulatory
authority, the owner or operator shall
perform monthly emission monitoring
using the approved alternative
monitoring procedure to demonstrate
compliance with the alternative
emission limit for each similar potline.
(e) Reduced sampling frequency. The
owner or operator may submit a written
request to the applicable regulatory
authority to establish an alternative
testing requirement to reduce the
sampling of secondary TF emissions
from potlines from monthly to quarterly.
(1) In the request, the owner or
operator shall provide information and
data demonstrating, to the satisfaction of
the applicable regulatory authority, that
secondary emissions of TF from potlines
have low variability during normal
operations using the procedures in
paragraphs (e)(l)(i) or (e)(l)(ii) of this
section.
(i) Submit data from 24 consecutive
months of sampling that show the
average TF emissions are less than 60
percent of the applicable limit and that
no monthly performance test in the 24
months of sampling exceeds 75 percent
of the applicable limit; or
(ii) Submit data and a statistical
analysis that the regulatory authority
may evaluate based on the approach
used in "Primary Aluminum: Statistical
Analysis of Potline Fluoride Emissions
and Alternative Sampling Frequency"
(EPA-450-86-012, October 1986),
which is available from the National
Technical Information Service (NTIS),
5285 Port Royal Road, Springfield, VA
22161.
(2) An approved alternative
requirement must include a test
schedule and the method to be used to
measure emissions for performance
tests.
(3) The owner or operator of a plant
that has received approval of an
alternative sampling frequency under
§60.194 of this chapter is deemed to
have approval of the alternative
sampling frequency under this subpart.
(4) If emissions in excess of the
applicable TF limit occur while
performing quarterly sampling approved
under paragraph (e)(l)(i) of this section,
the owner or operator shall return to
monthly sampling for at least 12 months
and may reduce to quarterly sampling
when:
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Federal Register / Vol. 62, No. 194 / Tuesday, October 7, 1997 / Rules and Regulations 52415
(i) The average of all tests performed
over the most recent 24-month period
does not exceed 60 percent of the
applicable limit, and
(ii) No more than one monthly
performance test in the most recent 24-
month period exceeds 75 percent of the
applicable limit.
(5) If emissions in excess of the
applicable TF limit occur while
performing quarterly sampling approved
under paragraph (e)(l)(ii) of this section,
the owner or operator shall immediately
return to the monthly sampling
schedule required by paragraph (a) of
this section until another request for an
alternative sampling frequency is
approved by the applicable regulatory
authority.
(f) Monitoring parameters for
emission control devices. The owner or
operator shall install, operate, calibrate,
and maintain a continuous parameter
monitoring system for each emission
control device. The owner or operator
shall submit for approval by the
regulatory authority a description of the
parameter(s) to be monitored, the
operating limits, and the monitoring
frequency to ensure that the control
device is being properly operated and
maintained. An explanation of the
criteria used for selection of the
parameter(s), the operating limits, and
the monitoring frequency, including
how these relate to emission control
also shall be submitted to the regulatory
authority. Except as provided in
paragraph (1) of this section, the
following monitoring devices shall be
installed:
(1) For dry alumina scrubbers, devices
for the measurement of alumina flow
and air flow;
(2) For dry coke scrubbers, devices for
the measurement of coke flow and air
flow;
(3) For wet scrubbers as the primary
control system, devices for the
measurement of water flow and air flow;
(4) For electrostatic precipitators,
devices for the measurement of voltage
and secondary current; and
(5) For wet roof scrubbers for
secondary emission control:
(i) A device for the measurement of
total water flow; and
(ii) The owner or operator shall
inspect each control device at least once
each operating day to ensure the control
device is operating properly and record
the results of each inspection.
(g) Visible emissions. The owner or
operator shall visually inspect the
exhaust stack(s) of each control device
on a daily basis for evidence of any
visible emissions indicating abnormal
operation.
(h) Corrective action. If a monitoring
device for a primary control device
measures an operating parameter
outside the limit(s) established pursuant
to §63.847(h), if visible emissions
indicating abnormal operation are
observed from the exhaust stack of a
control device during a daily inspection,
or if a problem is detected during the
daily inspection of a wet roof scrubber
for potline secondary emission control,
the owner or operator shall initiate the
corrective action procedures identified
in the startup, shutdown, and
malfunction plan within 1 hour. Failure
to initiate the corrective action
procedures within 1 hour or to take the
necessary corrective actions to remedy
the problem is a violation.
(i) Exceedances. If the limit for a
given operating parameter associated
with monitoring a specific control
device is exceeded six times in any
semiannual reporting period, then any
subsequent exceedance in that reporting
period is a violation. For the purpose of
determining the number of exceedances,
no more than one exceedance shall be
attributed in any given 24-hour period.
(j) Weight of aluminum and green
anodes. The owner or operator of a new
or existing potline or anode bake
furnace shall install, operate, and
maintain a monitoring device to
determine the daily weight of aluminum
produced and the weight of green anode
material placed in the anode bake
furnace. The weight of green anode
material may be determined by
monitoring the weight of all anodes or
by monitoring the number of anodes
placed in the furnace and determining
an average weight from measurements
of a representative sample of anodes.
(k) Accuracy and calibration. The
owner or operator shall submit
recommended accuracy requirements to
the regulatory authority for review and
approval. All monitoring devices
required by this section must be
certified by the owner or operator to
meet the accuracy requirements and
must be calibrated in accordance with
the manufacturer's instructions.
(1) Alternative operating parameters.
The owner or operator may monitor
alternative control device operating
parameters subject to prior written
approval by the applicable regulatory
authority.
(m) Other control systems. An owner
or operator using a control system not
identified in this section shall request
that the applicable regulatory authority
include the recommended parameters
for monitoring in the facility's part 70
permit.
§63.849 Test methods and procedures.
(a) The owner or operator shall use
the following reference methods to
determine compliance with the
applicable emission limits for TF and
POM emissions:
(1) Method 1 in appendix A to part 60
of this chapter for sample and velocity
traverses;
(2) Method 2 in appendix A to part 60
of this chapter for velocity and
volumetric flow rate;
(3) Method 3 in appendix A to part 60
of this chapter for gas analysis;
(4) Method ISA or Method 13B in
appendix A to part 60 of this chapter,
or an approved alternative, for the
concentration of TF where stack or duct
emissions are sampled;
(5) Method 13A or Method 13B and
Method 14 or Method 14A in appendix
A to part 60 of this chapter or an
approved alternative method for the
concentration of TF where emissions are
sampled from roof monitors not
employing wet roof scrubbers;
(6) Method 315 in appendix A to this
part or an approved alternative method
for the concentration of POM where
stack or duct emissions are sampled;
and
(7) Method 315 in appendix A to this
part and Method 14 in appendix A to
part 60 of this chapter or an approved
alternative method for the concentration
of POM where emissions are sampled
from roof monitors not employing wet
roof scrubbers.
(b) The owner or operator of a VSS
potline or a SWPB potline equipped
with wet roof scrubbers for the control
of secondary emissions shall use
methods that meet the intent of the
sampling requirements of Method 14 in
appendix A to part 60 of this chapter
and that are approved by the State.
Sample analysis shall be performed
using Method ISA or Method 13B in
appendix A to part 60 of this chapter for
TF, Method 315 in appendix A to this
part for POM, or an approved alternative
method.
(c) Except as provided in
§63.845(g)(l), references to "potroom"
or "potroom group" in Method 14 in
appendix A to part 60 of this chapter
shall be interpreted as "potline" for the
purposes of this subpart.
(d) For sampling using Method 14 in
appendix A to part 60 of this chapter,
the owner or operator shall install one
Method 14 manifold per potline in a
potroom that is representative of the
entire potline, and this manifold shall
meet the installation requirements
specified in section 2.2.1 of Method 14
in appendix A to part 60 of this chapter.
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52416 Federal Register / Vol. 62, No. 194 / Tuesday, October 7, 1997 / Rules and Regulations
(e) The owner or operator may use an
alternative test method for TF or POM
emissions providing:
(1) The owner or operator has already
demonstrated the equivalency of the
alternative method for a specific plant
and has received previous approval
from the Administrator or the applicable
regulatory authority for TF or POM
measurements using the alternative
method; or
(2) The owner or operator
demonstrates to the satisfaction of the
applicable regulatory authority that the
results from the alternative method meet
the criteria specified in §§ 63.848(d) (1)
and (d)(3) through (d)(6). The results
from the alternative method shall be
based on simultaneous sampling using
the alternative method and the
following reference methods:
(i) For TF, Methods 13 and 14 or
Method 14A in appendix A to part 60
of this chapter; or
(ii) For POM, Method 315 in appendix
A to this part and Method 14 in
appendix A to part 60 of this chapter.
§63.850 Notification, reporting, and
recordkeeping requirements.
(a) Notifications. The owner or
operator shall submit the following
written notifications:
(1) Notification for an area source that
subsequently increases its emissions
such that the source is a major source
subject to the standard;
(2) Notification that a source is subject
to the standard, where the initial startup
is before the effective date of the
standard;
(3) Notification that a source is subject
to the standard, where the source is new
or has been reconstructed, the initial
startup is after the effective date of the
standard, and for which an application
for approval of construction or
reconstruction is not required;
(4) Notification of intention to
construct a new major source or
reconstruct a major source; of the date
construction or reconstruction
commenced; of the anticipated date of
startup; of the actual date of startup,
where the initial startup of a new or
reconstructed source occurs after the
effective date of the standard, and for
which an application for approval of
construction or reconstruction is
required [see §§63.9(b)(4) and (b)(5)];
(5) Notification of initial performance
test;
(6) Notification of initial compliance
status;
(7) One-time notification for each
affected source of the intent to use an
HF continuous emission monitor; and
(8) Notification of compliance
approach. The owner or operator shall
develop and submit to the applicable
regulatory authority, if requested, an
engineering plan that describes the
techniques that will be used to address
the capture efficiency of the reduction
cells for gaseous hazardous air
pollutants in compliance with the
emission limits in §§ 63.843, 63.844,
and 63.846.
(b) Performance test reports. The
owner or operator shall report the
results of the initial performance test as
part of the notification of compliance
status required in paragraph (a) (6) of
this section. Except as provided in
paragraph (d) of this section, the owner
or operator shall submit a summary of
all subsequent performance tests to the
applicable regulatory authority on an
annual basis.
(c) Startup, shutdown, and
malfunction plan and reports. The
owner or operator shall develop and
implement a written plan as described
in §63.6(e)(3) that contains specific
procedures to be followed for operating
the source and maintaining the source
during periods of startup, shutdown,
and malfunction and a program of
corrective action for malfunctioning
process and control systems used to
comply with the standard. The plan
does not have to be submitted with the
permit appplication or included in the
operating permit. The permitting
authority may review the plan upon
request. In addition to the information
required in §63.6(e)(3), the plan shall
include:
(1) Procedures, including corrective
actions, to be followed if a monitoring
device measures an operating parameter
outside the limit(s) established under
§63.847(h), if visible emissions from an
exhaust stack indicating abnormal
operation of a control device are
observed by the owner or operator
during the daily inspection required in
§63.848(g), or if a problem is detected
during the daily inspection of a wet roof
scrubber for potline secondary emission
control required in §63.848(1)(5)(ii); and
(2) The owner or operator shall also
keep records of each event as required
by § 63.10(b) and record and report if an
action taken during a startup, shutdown,
or malfunction is not consistent with
the procedures in the plan as described
in§63.6(e)(3)(iv).
(d) Excess emissions report. As
required by §63.10(e)(3), the owner or
operator shall submit a report (or a
summary report) if measured emissions
are in excess of the applicable standard.
The report shall contain the information
specified in §63.10(e)(3)(v) and be
submitted semiannually unless
quarterly reports are required as a result
of excess emissions.
(e) Recordkeeping. The owner or
operator shall maintain files of all
information (including all reports and
notifications) required by §63.10(b) and
by this subpart.
(1) The owner or operator must retain
each record for at least 5 years following
the date of each occurrence,
measurement, maintenance, corrective
action, report, or record. The most
recent 2 years of records must be
retained at the facility. The remaining 3
years of records may be retained offsite;
(2) The owner or operator may retain
records on microfilm, on a computer, on
computer disks, on magnetic tape, or on
microfiche;
(3) The owner or operator may report
required information on paper or on a
labeled computer disc using commonly
available and compatible computer
software; and
(4) In addition to the general records
required by §63.10(b), the owner or
operator shall maintain records of the
following information:
(i) Daily production rate of aluminum;
(ii) Daily production rate of green
anode material placed in the anode bake
furnace;
(iii) A copy of the startup, shutdown,
and malfunction plan;
(iv) Records of design information for
paste production plant capture systems;
(v) Records of design information for
an alternative emission control device
for a paste production plant;
(vi) Records supporting the
monitoring of similar potlines
demonstrating that the performance of
similar potlines is the same as or better
than that of potlines sampled by manual
methods;
(vii) Records supporting a request for
reduced sampling of potlines;
(viii) Records supporting the
correlation of emissions measured by a
continuous emission monitoring system
to emissions measured by manual
methods and the derivation of the
alternative emission limit derived from
the measurements;
(ix) The current implementation plan
for emission averaging and any
subsequent amendments;
(x) Records, such as a checklist or the
equivalent, demonstrating that the daily
inspection of a potline with wet roof
scrubbers for secondary emission
control has been performed as required
in §63.848(f)(5)(ii), including the results
of each inspection;
(xi) Records, such as a checklist or the
equivalent, demonstrating that the daily
visual inspection of the exhaust stack
for each control device has been
performed as required in §63.848(g),
including the results of each inspection;
(xii) For a potline equipped with an
HF continuous emission monitor,
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Federal Register / Vol. 62, No. 194 / Tuesday, October 7, 1997 / Rules and Regulations 52417
records of information and data required
by§63.10(c);
(xiii) Records documenting the
corrective actions taken when the
limit(s) for an operating parameter
established under §63.847(h) were
exceeded, when visible emissions
indicating abnormal operation were
observed from a control device stack
during a daily inspection required
under § 63.848(g), or when a problem
was detected during the daily
inspection of a wet roof scrubber for
potline secondary control required in
§63.848(1) (5) (ii);
(xiv) Records documenting any POM
data that are invalidated due to the
installation and startup of a cathode;
and
(xv) Records documenting the portion
of TF that is measured as particulate
matter and the portion that is measured
as gaseous when the particulate and
gaseous fractions are quantified
separately using an approved test
method.
§ 63.851 Regulatory authority review
procedures.
(a) The applicable regulatory
authority shall notify the owner or
operator in writing of the need for
additional time to review the
submissions in paragraphs (a)(l)
through (a) (5) of this section or of
approval or intent to deny approval of
the submissions in paragraphs (a)(l)
through (a) (5) of this section within 60
calendar days after receipt of sufficient
information to evaluate the submission.
The 60-day period begins after the
owner or operator has been notified that
the submission is complete.
(1) Thetestplanin§63.847(b);
(2) Request to change limits for
operating parameters in §63.847(h)(3);
(3) Request for similar potline
monitoring in §63.848(d)(5);
(4) Request for reduced sampling
frequency in §63.848(e); and
(5) Request for an alternative method
in§63.849(e)(2).
(b) The applicable regulatory
authority shall notify the owner or
operator in writing whether the
submission is complete within 30
calendar days of receipt of the original
submission or within 30 days of receipt
of any supplementary information that
is submitted. When a submission is
incomplete, the applicable regulatory
authority shall specify the information
needed to complete the submission and
shall give the owner or operator 30
calendar days after receipt of the
notification to provide the information.
§ 63.852 Applicability of general
provisions.
The requirements of the general
provisions in subpart A of this part that
are not applicable to the owner or
operator subject to the requirements of
this subpart are shown in appendix A of
this subpart.
§ 63.853 Delegation of authority.
In delegating implementation and
enforcement authority to a State under
section 112(d) of the Act, all authorities
are transferred to the State.
§§63.854-63.859 [Reserved]
TABLE 1 To SUBPART LL—POTLINE TF LIMITS FOR EMISSION AVERAGING
Type
Monthly TF limit (1b/ton)
[for given number of potlines]
CWPB1
CWPB2
CWPB3
VSS1
VSS2
HSS
SWPB
2 lines
1.7
29
23
2
2.6
2.5
1.4
3 lines
1.6
28
22
1 9
2.5
2.4
1.3
4 lines
1.5
27
22
1 8
2.5
2.4
1.3
5 lines
1.5
27
2 1
1 7
2.4
2.3
1.2
6 lines
1.4
26
2 1
1 7
2.4
2.3
1.2
7 lines
1.4
26
2 1
1 7
2.4
2.3
1.2
8 lines
1.4
26
2 1
1 7
2.4
2.3
1.2
TABLE 2 TO SUBPART LL—POTLINE POM LIMITS FOR EMISSION AVERAGING
Type
Quarterly POM limit (Ib/ton)
[for given number of potlines]
HSS
VSS1
VSS2
2 lines
4.1
2 1
32
3 lines
3.8
20
30
4 lines
3.7
1 9
29
5 lines
3.5
1 9
29
6 lines
3.5
1 8
28
7 lines
3.4
1 8
28
8 lines
3.3
1 8
27
TABLE 3 TO SUBPART LL—ANODE BAKE FURNACE LIMITS FOR EMISSION AVERAGING
Number of furnaces
Emission limit (Ib/ton of
anode)
2
3
4
5
TF
0 11
0090
0.077
0.070
POM
0 17
0 17
0.17
0.17
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52418 Federal Register / Vol. 62, No. 194 / Tuesday, October 7, 1997 / Rules and Regulations
APPENDIX A TO SUBPART LL—APPLICABILITY OF GENERAL PROVISIONS
[40 CFR part 63, subpart A to Subpart LL]
General provisions citation
63 1 (c)(2)
63 2 Definition of "reconstruction"
63.6(c)(1)
63 6(h)
63.8(c)(4)-(c)(8)
63.8(d)
63 8(e)
63 9(e)
63.9(f)
63.9(g)
63.10(d)(2)
63 1 0(d)(3)
63 1 0(e)(2)
63.11(a)-(b)
Requirement
Compliance date for existing
sources.
Opacity/VE standards
CMS operation and maintenance
Quality control
Performance evaluation for CMS
Notification of performance test
Notification of VE or opacity test
Additional CMS notification
Performance test reports
Reporting VE/opacity observations
Reporting performance evaluations
Control device requirements
Applies to subpart LL
No
No
No
Only in §63845
No
No
No
No
Only in §63.845
No
No
Only in §63845
No
No
Comment
All are major sources
Subpart LL defines "reconstruction "
Subpart LL specifies compliance
date for existing sources.
Opacity standards applicable only
when incorporating the NSPS re-
quirements under §63.845.
Subpart LL does not require COMS/
CMS or CMS performance speci-
fications.
Subpart LL does not require CMS or
CMS performance evaluation.
Subpart LL specifies notification of
performance tests.
Notification is required only when in-
corporating the NSPS require-
ments under §63.845.
Subpart LL specifies performance
test reporting.
Reporting is required only when in-
corporating the NSPS require-
ments under §63.845.
Subpart LL does not require per-
formance evaluation for CMS.
Flares not applicable.
9. Appendix A to part 63 is amended
by adding, in numerical order, Method
315 to read as follows:
Appendix A to Part 63—Test Methods
Method 315—Determination of Particulate
and Methylene Chloride Extractable Matter
(MCEM) From Selected Sources at Primary
Aluminum Production Facilities
Note: This method does not include all of
the specifications (e.g., equipment and
supplies) and procedures (e.g., sampling and
analytical) essential to its performance. Some
material is incorporated by reference from
other methods in this part. Therefore, to
obtain reliable results, persons using this
method should have a thorough knowledge
of at least the following additional test
methods: Method 1, Method 2, Method 3,
and Method 5 of 40 CFR part 60, appendix
A.
1.0 Scope and Application.
1.1 Analytes. Particulate matter (PM). No
CAS number assigned. Methylene chloride
extractable matter (MCEM). No CAS number
assigned.
1.2 Applicability. This method is
applicable for the simultaneous
determination of PM and MCEM when
specified in an applicable regulation. This
method was developed by consensus with
the Aluminum Association and the U.S.
Environmental Protection Agency (EPA) and
has limited precision estimates for MCEM; it
should have similar precision to Method 5
for PM in 40 CFR part 60, appendix A since
the procedures are similar for PM.
1.3 Data quality objectives. Adherence to
the requirements of this method will enhance
the quality of the data obtained from air
pollutant sampling methods.
2.0 Summary of Method.
Particulate matter and MCEM are
withdrawn isokinetically from the source.
PM is collected on a glass fiber filter
maintained at a temperature in the range of
120 ± 14 °C (248 ± 25 °F) or such other
temperature as specified by an applicable
subpart of the standards or approved by the
Administrator for a particular application.
The PM mass, which includes any material
that condenses on the probe and is
subsequently removed in an acetone rinse or
on the filter at or above the filtration
temperature, is determined gravimetrically
after removal of uncombined water. MCEM is
then determined by adding a methylene
chloride rinse of the probe and filter holder,
extracting the condensable hydrocarbons
collected in the impinger water, adding an
acetone rinse followed by a methylene
chloride rinse of the sampling train
components after the filter and before the
silica gel impinger, and determining residue
gravimetrically after evaporating the solvents.
3.0 Definitions. [Reserved]
4.0 Interferences. [Reserved]
5.0 Safety.
This method may involve hazardous
materials, operations, and equipment. This
method does not purport to address all of the
safety problems associated with its use. It is
the responsibility of the user of this method
to establish appropriate safety and health
practices and determine the applicability of
regulatory limitations prior to performing
this test method.
6.0 Equipment and Supplies.
Note: Mention of trade names or specific
products does not constitute endorsement by
the EPA.
6.1 Sample collection. The following
items are required for sample collection:
6.1.1 Sampling train. A schematic of the
sampling train used in this method is shown
in Figure 5-1, Method 5, 40 CFR part 60,
appendix A. Complete construction details
are given in APTD-0581 (Reference 2 in
section 17.0 of this method); commercial
models of this train are also available. For
changes from APTD-0581 and for allowable
modifications of the train shown in Figure 5—
1, Method 5, 40 CFR part 60, appendix A, see
the following subsections.
Note: The operating and maintenance
procedures for the sampling train are
described in APTD-0576 (Reference 3 in
section 17.0 of this method). Since correct
usage is important in obtaining valid results,
all users should read APTD-0576 and adopt
the operating and maintenance procedures
outlined in it, unless otherwise specified
herein. The use of grease for sealing sampling
train components is not recommended
because many greases are soluble in
methylene chloride. The sampling train
consists of the following components:
6.1.1.1 Probe nozzle. Glass or glass lined
with sharp, tapered leading edge. The angle
of taper shall be <30°, and the taper shall be
on the outside to preserve a constant internal
diameter. The probe nozzle shall be of the
button-hook or elbow design, unless
otherwise specified by the Administrator.
Other materials of construction may be used,
subject to the approval of the Administrator.
A range of nozzle sizes suitable for isokinetic
sampling should be available. Typical nozzle
-------
APPENDIX B
DESCRIPTION OF THE PROCESS AND EMISSION POINTS
101
-------
APPENDIX B. DESCRIPTION OF THE PROCESS AND EMISSION POINTS
This appendix provides an overview of the
processes found at primary aluminum plants and
concludes with a description of the pollutants and
emission points affected by this rule.
B.I WHAT IS IN A PRIMARY
ALUMINUM PLANT?
The major components of a primary aluminum
plant are:
shipping and receiving areas for raw
materials and finished product;
one or more potlines where alumina (A12O3)
is reduced into aluminum in a cryolite
(Na3AlF6) electrolytic bath;
a cast house where the aluminum is
reheated and purified, its characteristics are
modified to meet various specifications, and
it is cast into solid forms including ingots
and billets, or transported in a molten state;
a rectifier for converting alternating current
(AC) voltage into the direct current (DC)
voltage used in the reduction process;
maintenance and repair facilities;
an anode paste plant, where coke and pitch
are mixed to form anode paste, briquettes,
or green anodes; and
an anode bake plant (located only at
facilities using the prebake process).
A simplified diagram of atypical Soderberg plant
showing material flow patterns is provided in
Figure B-l. Similarly, Figure B-2 shows a
simplified schematic of the process operations
performed in a typical prebake plant. The
processes labeled "secondary operations" in
the figure are not covered by subpart LL;
these sources will be addressed in a separate
MACT rulemaking.
The sequence of process operations is paste
production, anode baking (for prebake processes
only because the anode is baked in place in the
Soderberg process), and primary aluminum
prodcution in groups of reduction cells called
potlines.
B.2 WHAT HAPPENS IN PASTE
PRODUCTION?
The anode paste plant is termed the "green mill"
by the industry and may produce anode paste for
Soderberg cells, cathode paste, or green pressed
anodes to be baked for prebake cells. Carbon
paste production consists of the following
processes:
• crushing;
• grinding;
• screening and classifying;
combining of carefully sized fractions
with a pitch binder; and
• mixing and forming.
Figure B-3 shows a typical flowsheet for a
Soderberg paste production plant and Figure B-4
shows a typical flowsheet for the prebake paste
and green anode production.
Solid raw materials (calcined petroleum coke,
anthracite coal, and solid pitch, as required for
various kinds of paste mixes) are received in bulk
and transported to carbon plant storage.
Material is reclaimed from storage by front-end
loaders with enclosed cabs, airslide, or conveyors
and fed to combinations of crushing equipment in
closed circuit with vibrating screens followed by
grinding units. Sized fractions of crushed and
ground material are separated and stored in mix
bins for make-up of paste composition. Cleaned
reclaimed spent anodes and anode scrap from
prebake plant operations are similarly crushed
and sized for recycle to prebake anode
preparation.
102
-------
Product
&
Coke
Pitch
Paste
Molten Aluminum
ALUMINUM
&
AUXILIARY
Molten Aluminum
ALUMINUM
CASTING
Aluminum Ingots
FIGURE B-l. PROCESS FLOW DIAGRAM FOR A SODERBERG PLANT
103
-------
Product
Raw
&
Coke
Pitch
Crushed
Anode
Butts
PREPARATION
Anode
&
Baked
Anodes
BUTT
CRUSHING
Anode Butts
ALUMINUM
PRODUCTION
POTLINES
Molten Aluminum
Molten Aluminum
ALUMINUM
TAPPING
ALUMINUM
FLUXING & ALLOYING
Molten Aluminum
ALUMINUM
CASTING, ROLLING, ETC.
FIGURE B-2. PROCESS FLOW DIAGRAM FOR A PREBAKE PLANT
104
-------
Calcined
Petroleum Coke
Storage
L J.
V x
Wei
Sea"
X Y
^T^
Steam
i
t
— I
Liquid Pitch
Storage
Meter 1+ xj M
xer
1
or
To
O O
"ram Car
Conveyor
Electrolytic
Cell
O O
Transfer Cart
O
FIGURE B-3. SCHEMATIC OF SODERBERG PASTE PLANT
\ Coal Tar Pitch 'l L
y ^^ 1
Coarse
Particles
X
r1! V
LJ scales
I Tram Car
I or Conveyor
To Electrolytic
FIGURE B-4. SCHEMATIC OF PREBAKE ANODE PREPARATION
105
-------
Dry solids are drawn from the sized mix bins in
controlled proportions either in weighed batches
for batch mixers or continuously for continuous
mixers. Mixers are jacketed and heated with
either steam or hot oil. For baked anode pastes
the mixer feed contains either solid crushed coal
tar pitch, which is softened and blended in the
mixers or hot liquid pitch to provide the paste
binder.
For Soderberg paste, a liquid pitch is used and is
metered to the mixers. The hot Soderberg paste
is discharged directly from the batch mixers to
transfer cars that convey it to the cell rooms for
anode replenishment, or may be cooled and
formed into briquettes. Briquettes are conveyed
by conveyor belts, trucks, or front-end loaders.
The prebake paste, less fluid than the Soderberg
material, is transferred from the mixers to anode
molds, in which the self-supporting green anode
is formed by hydraulic or vibratory compaction.
B.3 WHAT IS ANODE BAKING?
Anode bake furnaces (used only at prebake
plants) vary greatly in size and production rate,
but all have the same basic layout and operating
parameters. Figure B-5 shows atypical ring
furnace used for anode baking. Each furnace
consists of a large number of indirectly fired
sunken ovens or pits arranged in rows. The pits
are open-topped and made of brick. Some of the
spaces between the bricks are mortared, while
others are intentionally left open. The pits sit in
a flue which surrounds them. The flue is split
down the middle by a wall. The wall is slightly
shorter than the flue to permit the flue gases to
pass from one side to the other at each end. A
large pipe or duct circles the furnace and leads to
an exhaust fan. Double-sealed manholes are
spaced along the top of this duct, with at least
one manhole per furnace section. Each one-half
row of pits, from the center wall out, is called a
section.
An operating furnace will have one or more
"fires" operating continuously. A fire has three
phases: preheat, bake, and cool-down. Each fire
gradually traverses the length of the furnace on
one side in a series of steps, one section per step.
It then returns on the other side. Ahead of the
fire(s), pits are filled with green anodes to within
about 3 feet of the surface. Petroleum coke is
then dumped into the pits from an overhead
hopper and packed around the anodes. The
anodes are then covered with petroleum coke or
some other insulating material to cover the tops
of the pits. After the fire has passed by and the
baked anodes have cooled, the packing coke is
removed from the pits by vacuuming or other
means, and reused. The baked anodes are then
removed and necessary pit repairs are performed
while the pits are empty.
B.4 HOW IS ALUMINUM MADE?
Primary aluminum is produced by the reduction
of alumina by electrolysis in a molten bath of
natural or synthetic cryolite (Na3AlF6), which
serves as an electrolyte and as a solvent for the
alumina. The reduction cells or pots containing
the bath are about 10 to 15 feet wide, 20 to 40
feet long, and about 3 to 4 feet deep, lined with
carbon, and connected in electrical series of 100
to 240 cells to form a potline. From 800 to
3,000 pounds of aluminum metal are produced
per day in each pot. The carbon lining is in
contact with the molten aluminum metal and
serves as the cathode.
An aluminum reduction potline is typically
housed in one or two long, narrow buildings
called potrooms. A potline is made up of a series
of electrically connected cells called aluminum
reduction pots. The pots are shallow, rectangular
vessels that may be lined up side-by-side or end-
to-end in one or more rows down the center of the
potroom. The pots are large heat sources;
consequently, the potrooms are ventilated to
maintain reasonable working conditions and to
help with proper pot operation. Usually this
ventilation air enters at the sides of a potroom
and exits through roof
106
-------
Flue Gas
Exhaust
Header „
t o
Exhaust
Duct
o
Gas Flow
tn nin*
iron
DDD
D
Exhaust to
Control Device
FIGURE B-5. RING FURNACE LAYOUT
Pits
• Double
Sealed
Exhaust
Port
• Flues
Movable
Firing
Frame
Ambient
Air Inlet
Header
EB-
107
-------
vents (roof monitors). This ventilation is the
major source of potroom fugitive emissions.
Primary aluminum operations are differentiated
by the type of anode used, the method by which
the pot is worked, and the method by which the
anode is introduced into the cell. There are two
major types of processes: prebake and
Soderberg. A majority of the primary aluminum
plants in the U.S. currently use prebake
technology (17 of 23 plants).
The pots in prebake plants use multiple anodes
that are formed and baked prior to consumption
in the pots, while the Soderberg pots use a single,
continuous anode that is shaped and baked in
place directly in the pot. Each of these pot types
has two variations. The pots in prebake plants
are classified as center-worked prebake (CWPB)
or side-worked prebake (SWPB), depending on
where the pot working (crust breaking and
alumina addition) takes place. Soderberg pots,
on the other hand, are differentiated by the
positioning of the current-carrying studs in the
anodes, which may be inserted vertically or
horizontally. The four basic types of primary
aluminum reduction technology are illustrated in
Figure B-6 and include:
1. Center-work prebake (CWPB)
2. Side-work prebake (SWPB)
3. Vertical stud Soderberg (VSS)
4. Horizontal stud Soderberg (HSS)
In the Soderberg method, a reinforced
rectangular steel shell, approximately 3 to 5 feet
high and open at the top and bottom, is
suspended above the pot. The carbon mass (coke
and pitch) of paste or briquettes within the shell
forms the anode and is added periodically as the
anode is consumed. Current enters the anode
through rows of pins inserted into the carbon
mass either vertically or horizontally. The heat
of the bath and the heat resulting from the
electrical resistance of the carbon bake the anode
paste so that it becomes a hard monolithic mass
from the surface of the electrolyte to a point
approximately 20 inches above the bath. As the
carbon anode is consumed and additional carbon
descends through the rectangular steel shell and
is consumed, the lowest pins are withdrawn and
replaced at higher levels in the carbon mass.
In the prebaked anode system, sets of 16 to 24
prebaked carbon blocks are used for the anode.
The size of the blocks varies from plant to plant;
typical blocks are about 20 inches wide, about 30
inches long, and 12 to 18 inches high. They
weigh 400 to 600 pounds. Steel studs or rods,
which suspend the block in the bath and conduct
the current to the carbon, are sealed in the anode
block by pouring molten iron around the rod and
allowing it to solidify. The anode blocks are
raised or lowered to maintain proper position
with respect to the metal levels in the cell. When
consumed, anode blocks are replaced.
Periodically, the aluminum is removed from the
pots by a process called "tapping" and
transferred, still molten, to the cast house in
crucibles. There it is placed in a holding furnace,
alloyed with other materials (iron, silicon,
magnesium, and manganese), and fluxed
(generally with chlorine or argon) to remove
impurities. The purified alloyed aluminum, still
molten, is then direct chilled cast into ingots,
billets, or slabs. Unalloyed molten aluminum is
poured into "sow" molds to cool. After cooling,
the aluminum products are transferred to storage
or prepared for shipment.
108
-------
Hood
Horizontal Stud Soderberg Pot
Hood
Side-Worked Prebake Pot
Hood
1. Fume evacuation
pipe
2. Carbon anode.
3. Bath of molten
cryolite
4. Cathode of liquid
aluminum
5. Carbon cathode
6. Iron cathode bars
7. Cathode insulation
of alumina or
refractory bricks
8. Iron shell
9. Blanket of alumina
10. Crust of solidified
bath
Vertical Stud Sdderberg Pot
Central-Worked Prebake Pot
FIGURE B-6. SCHEMATICS OF TYPES OF REDUCTION CELLS ("POTS")
109
-------
B.5 WHAT ARE THE HAPs AND
EMISSION POINTS?
One of the major HAP of concern is a family of
compounds collectively called POM. These
compounds enter the process with the pitch,
which is derived from the tar produced as a by-
product at plants that distill coal to produce coke.
The pitch enters the process as either a solid or
as a heated viscous liquid. POM emissions occur
from pitch storage tanks when the liquid is
pumped into the tank and when it is heated to
keep it fluid.
POM emissions also occur from the paste
production plant as the heated pitch is
transferred and combined with petroleum coke to
make green anodes or paste. The emissions
occur wherever heated pitch is handled, including
day tanks for pitch storage, mixers, formers,
and transfer systems. The rule requires that
these emission points be enclosed and evacuated
to a dry coke scrubber or alternative control
device to control POM emissions.
POM emissions occur from the anode bake
furnace when the green anodes are exposed to
high temperatures. In addition, HF emissions
occur because fluoride is introduced into the bake
furnace from fluoride compounds that adhere to
"anode butts", which are the remnants of anodes
that are recycled after they have been replaced in
the reduction cell. The fluoride that leaves the
bake furnace is primarily in the form of HF. The
emissions of POM and HF at most bake furnaces
are controlled by the use of dry alumina
scrubbers.
Fluoride emissions (both in gaseous and
particulate form) occur from the reduction
cells and are termed "secondary emissions"
(fugitive) and "primary emissions " (from the
control device). The vast majority of the
fluoride that evolves from the cell or pot is
captured and recovered for recycle by the
emission control system, usually a dry alumina
scrubber. The fugitive or secondary emissions
that escape from the cell are usually emitted
through the roof. A few plants use wet roof
scrubbers to control these secondary emissions.
In addition to fluoride, POM is emitted from
Soderberg potlines. The source of the POM is
the anode paste that is baked in place in the
reduction cell. In contrast, POM emissions from
prebake potlines are minimal because the anodes
have been "prebaked" in the anode bake furnace.
110
-------
APPENDIX C
SITE-SPECIFIC TEST PLAN OUTLINE
111
-------
DRAFT OUTLINE FOR SITE-SPECIFIC TEST PLAN
Introduction
This section simply includes a description of what the plan is for and the specific tests to be conducted at
the facility. The scope of the plan should include both initial compliance tests and ongoing compliance
testing. The intent to use any previous emissions data collected at the facility could also be noted in the
introduction.
Test Description and Schedule
This section should give a brief description of overall plant operations and then describe and the specific
sources to be sampled under the performance test plan. Also include a description of the control equipment
used at each source to comply with the rule.
Provide a table or "test matrix" showing each source to be tested , the "initial" tests to be performed, the
on-going tests to be performed, the frequency of testing, the duration of each test and the sampling and
analytical methods to be used at each specific source.
Describe the approach that will be used to ensure that one test run on the roof monitor is performed
before 15th of each month, one test run is performed after the 15th of each month and that there are no less
than 6 days between any 2 test runs conducted in the same month.
Describe rationale for the number of stacks. The rule requires testing of a "representative number of the
stacks" satisfactory to the regulatory authority.
Summarize any past compliance test data we intend to use in demonstrating initial compliance. Any data
collected with EPA approved alternate or reference methods up to 12 months before the compliance date
may be used.
Sampling Locations
[Note: Information on sampling locations is not specifically required by the rule or General Provisions;
however, it is useful information that is often included in test plans.]
Provide detailed descriptions of each location to be used for emissions testing. The following information
should be provided for each location as appropriate:
sampling port size and location;
• stack shape (circular or rectangular) and dimensions;
distances to upstream and downstream flow disturbances;
• number and location of traverse points required at each sampling location per EPA
Methods 1 and 2; and
• sampling location access and safety considerations.
112
-------
Sampling location descriptions should be provided for the following sources as applicable:
Method 14 manifold, dry alumina scrubbers, pitch storage tanks, wet scrubbers, electrostatic precipitators.
Sampling/Analytical Procedures
Provide a brief summary of the test methods to be used for compliance testing. Attach a copy of the
reference or approved alternate methods to the test plan as an appendix:
Method 14
Method 13A and 13B
Method 14A (Alcan Cassette Method)
Method 315
HFCEM
Data Quality Objectives
Provide table summary of data quality objectives for each test method. The table needs to include the basis
on which the data quality objective will be evaluated. For example, accuracy and precision of fluoride
analyses may be evaluated based on matrix spike and matrix spike duplicate analyses.
Sample Custody Procedures
Describe procedures to be used for the proper labeling of samples and for transportation of samples to the
laboratory.
Internal Quality Control and Quality Assurance Checks
Describe procedures to be used for calibration of field sampling and laboratory analytical equipment. This
would include calibration of dry gas meters, thermocouples, probe nozzles, etc. for stack sampling, as well
as calibration of analytical balances and ion selective electrodes use in the laboratory. The internal QA/QC
program also needs to describe procedures to be used for determining measurement accuracy and precision,
such as regular analysis of a fluoride QC sample, analysis of matrix spike and matrix spike duplicates, and
duplicate analysis of selected stack samples.
External Quality Assurance
This section should describe our intent to request Method 13 total fluoride and Method 315 total POM
performance audit ("blind") samples from EPA at least 45 days prior to the test date and analyze these
samples with stack samples collected during the initial performance test. Results from the performance
audit samples will be used by EPA to independently assess test data accuracy and precision.
113
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TECHNICAL REPORT DATA
1. REPORT NO.
EPA-453/R-99-011
2. 3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
Plain Language Guide to the Primary Aluminum NESHAP - 40 CFR Part 63,
Subpart LL
7. AUTHOR(S)
Steve Fruh, EPA/OAQPS/ESD/PPSG
Marsha Branscome, Research Triangle Institute
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Research Triangle Institute
3040 Cornwallis Road
P.O. Box 12194
12. SPONSORING AGENCY NAME AND ADDRESS
Office of Air Quality Planning and Standards
Office of Air and Radiation
U.S. Environmental Protection Agency
5. REPORT DATE
October 1999
6. PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT
NO.
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68D60014
13. TYPE OF REPORT AND PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
EPA/200/04
15. SUPPLEMENTARY NOTES
Project Officer is Carolyn Wigington, Mail Drop 13 (919-541-5374)
Task Order Project Officer is Steve Fruh, Mail Drop 13 (919-541-2837)
16. ABSTRACT
National emissions standards to control emissions of HAP from major sources at primary aluminum reduction
plants were published in Federal Register 10/7/97, 63 FR 52407. This document contains information to help
State and local agencies for air pollution control, as well as the regulated community, carry out these standards.
The document summarizes the NESHAP requirements and provides example calculations, inspection checklists,
and example notification and reporting forms. The document also provides information on where to submit
reports, go to for additional help, and applicability of requirements in the NESHAP General Provisions and Title
V of the Clean Air Act. A copy of the rule is provided in hard copy format. An electronic version of this
document can be downloaded aHwww.epa.gov/ttn/uatw under Rules and Implementation, Primary Aluminum..
17. KEY WORDS AND DOCUMENT ANALYSIS
a. DESCRIPTORS
b. IDENTIFIERS/OPEN ENDED TERMS c. COSATT
Air pollution Title III Air pollution control
Air pollution control NESHAP Aluminum
National emissions standards Compliance Anode bake furnace
Hazardous air pollutants 40 CFR Part 63 Paste production plant
Primary aluminum Subpart LL Potline
18. DISTRIBUTION STATEMENT
Unlimited
19. SECURITY CLASS (Report) 21. NO. OF PAGES
Unclassified 1 38 (hard copy)
125 (UATW)
20. SECURITY CLASS (Page) 22. PRICE
Unclassified no cost
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