COMMONWEALTH OF PENNSYLVANIADepartment of Environmental Protection

September 14,2015Phone: 814/332-6940Fax: 814/332-6117

SUBJECT: Memorandum of ReviewRenewal of Title V Permit of Alcoa Commercial Windows, LLC, (PreviouslyThree Rivers Aluminum Company, (TRACO))Cranberry Township, Butler County.

TO: File: AQlFacilitieslFAC OP/ TV 10-00267APS ID: 346173, Previous AUTH. ID: 910506Auth. ID: 1061870, PF ID: 242665

FROM:

THROUGH:

Kallol Bhattacharyya~'Permit WriterAir Quality ProgramNorthwest Regional Office

Matthew M. Williams -rYlWFacilities Permitting ChiefAir Quality ProgramNorthwest Regional Office

Edward F. Orris Jr. P.E....-~Program Manager ~V{/Air Quality ProgramNorthwest Regional Office

Introduction:

This Title V renewal Permit is for Alcoa Commercial Windows LLC located in CranberryTownship, Butler County. The facility is engaged in the manufacturing of commercial windows.The previous name of the facility was Three Rivers Aluminum Company (TRACO). On July 30,2010 Alcoa Incorporated purchased TRACO. The company changed its' name to AlcoaIncorporated. This facility is major for Title V purposes because the potential emissions ofVOCare more than the Title V threshold limit of 50 TPY.

Corporate Overview:

From: www.alcoa.com..We pioneered the aluminum industry over 125 years ago, and today, our59,000 people in 30 countries deliver value-add products made of titanium, nickel andaluminum, and produce best-in-class bauxite, alumina and primary aluminum products."

SIC Code: 3442: Manufacturing - Metal Doors, Sash and Trim.

Permit History:

The permit was issued on December 14, 1999 with an expiration date of January 31,2005. Thepermit was renewed on July 19,2005 with an expiration date of June 30, 2010. The permit wasadministratively amended on October 20, 2009 to incorporate the conditions of Plan Approval #10-0267C.The permit was renewed on September 22,2010 with an expiration date August 31,2015. This permit was administratively amended on August 11,2011 to indicate the newresponsible official was Jeffrey 1. Jost - Vice President and General Manager. This permit wasmodified on April 23,2012 to allow the additional compliance options under 40 CFR Part 63,Subpart MMMM to be incorporated in the permit. This is the review memorandum of therenewal Title V permit application, received on February 18,2015.

CAM conditions are remaining the same:

The Compliance Assurance Monitoring rule found at 40 CFR Part 64 is applicable to the spraypainting and baking oven, Sources #101, and #102 because the pre-controlled emission rate ofVolatile Organic Compound (VOC) from each source is greater than 50 tons per year and thesource uses a control device to reduce the VOC. The CAM conditions were developed in theprevious operating permit and remain the same as described in the previous renewal permit.

Updated Sources:

1) Tellkamp Line & Binks Booth, 2) Coated-Extrusion Bake Oven, 3) Fill Line AdhesiveApplication (1 Line), 4) Assembly (Sealing, Cleaning, Touch-up), 5) 1800 Ton ExtrusionPresses & Preheaters, 6) 2750 - Ton Extruder W/Preheater, 7) Extrusion Aging Ovens(2),8) Caustic Anodizing Tank 9) Sulfuric Acid Anodizing Tank (4) (4th tank has beenadded via approved RFD in April 2014), 10) Facility Space Heating ( & HVAC System),11) Miscellaneous atural Gas Usage, 12) Degreaser Units (6) (previously 7), 13) AcidEtch Tank & Heater(New source approved by RFD dated 9/2014), 14)EmergencyGenerators w/315 HP John Deere Engine ( New source RFD approved on 10/2011), 15)Small Batch Paint Mixing-room and 16) Paint Kitchen.

Addition of40 CFR Part 82, Subpart F in the site level:

The following conditions of 40 CFR Part 82, Subpart F have been included in the site level of thepermit pertaining to the protection of stratospheric ozone related to class I and class IIrefrigerants used throughout the facility

The following applicable citations from 40 CFR Part 82 Subpart F were added to the renewalpermit:

82.150, Purpose & Scope82.152, Definitions82.154, Prohibitions82.156, Required Practices82.161, Technician certification82.162, Certification by owners of recovery and recycling equipment82.166, Reporting and recordkeeping requirements.

Removed Sources:

The facility has removed the following sources from the facility:

1) Source ID # 117: Pyrolysis Oven in 2010.2) Source ill # 118: Two Tone Coating Process Line with Oven removed in May 2013.

The above sources were not included in the renewal permit.

New Sources have been added:

Source ID # 120: consists of an acid etch tank and heater. This source was exempted fromthe plan approval requirements through a RFD determination dated September 9, 2014. This newacid etch process with rinse tank is controlled by a Viron International Horizontal Cross FlowScrubber System (model VHS-741 08). The tank is heated by a natural gas fired boiler with heatinput of 1.35 MMBTU/Hr. manufactured by Rite Engineering & Mfg. Corporation, Power Boiler(Model 135W) with a Power Flame Type C burner model C1-G-12. The Boiler will provide heatto the etch tank. The acid etch bath is heated to 115°F and agitated resulting in emissions ofHFand ammonia. These emissions are controlled by the scrubber. Based on a 94% removalefficiency, the estimated emissions are 0.016 TPY ofHF (Hydrogen Fluoride) and 3.57 TPY ofammonia. The emission of particulate matter is restricted by 25 Pa. Code §123.13 and theemission of Oxides of Sulfur is restricted by 25 Pa. Code §123.21. The preventive maintenancerecordkeeping and work practice standard requirements for the control device are stated in§127.441.

· .

Flow Diagram:

~;~~e~:Ch -.f Scrubber H Stack Itank

Source ID # 121: consists of an emergency generator w/315 HP John Deere Engine. Thisemergency generator was exempted from the requirements of Plan Approval through anapproved RFD determination dated October 24,2011. The generator is manufactured by TognumGroup Brand DS200D6SRA rated at 200 KW. The generator is operated by a John Deere 315BHP engine model6068HF485 manufactured in 2010. The engine will operate approximately 10days per year. This generator was exempted from plan approval requirements based on the actualemission of OX ofless than100 lbs/hr, 1000 lbs/day, 2.75 tons per ozone season and 6.6 tpy ona 12 month rolling total as stated in 25 Pa. Code §127.14 (a)(8) list #6. These Ox emissionrestrictions have been included in the source level under 25 Pa, Code §127.441. This source issubject to 40 CFR Part 60 Subpart IIII. The following applicable conditions have been includedin source level of the permit.

Applicable conditions of 40 CFR Part 60 Subpart IlIl:

§60.4200 (a) (2), and (a) (4): This condition explains the applicability of this subpart.

§60.4202(a) (2): This condition explains the limits of the certified engine manufactured in 2010pursuant to §60.4205 and §89.112.

§60.4205 (b), (e): This condition explains that the owner ofa stationary emergency engine with amodel year of 2007 or later emergency engine must comply with the emission standards formanufacturers that are explained in §60.4202. If a performance test is conducted it must complywith the ot to Exceed (NTE) Standards of §60.4212.

§60.4206: This conditions explains that the emission standards shall be maintained in accordancewith §60.4205 over the entire life of the engine.

§60.4207 (b): This condition explains that beginning October 1,2010 the owner of a dieselfueled CI ICE shall meet the diesel fuel requirement as per 40 CFR 80.510(b).

§60.4208 (a): This condition explains that after December 31, 2008 the owner of stationary CIICE may not install a stationary CI ICE that do not meet the applicable requirements for 2007

model year engines.

§60.4209 (a): The emergency engine owner or operator must install a non-resettable hour meteron the engine prior to startup of the engine.

§60.4211 (a) (1), (2) and (3), (f) (1 )and (2), (f)(2) (i), and (g) (2): These conditions explain thatthe owner or operator must maintain and operate the engine in accordance with themanufacturer's specification and good air pollution control practices as explained in 40 CFRparts 89,94, and/or 1068 , as applicable. The emergency engine has no time limit for theoperation in emergency situations. The emergency engine will not run for combined readinessand non-emergency purposes for more than 100 hours per year. A maintenance plan record shallbe kept at the site.

§60.4212 (a) - (c) and (e): These conditions explain the details of testing procedure for in-usetesting as per 40 CFR Part 1039 Subpart F, 1039.101(e) and the NTE Standards of1039.102(g)(1). The exhaust emissions from stationary ICE shall comply with the applicableemission limit in 40 CFR 89.112 or 40 CFR 94.8.

§60.4214 (b) and (c): These conditions explain that the owner or operator shall keep a record ofthe operation time of an emergency engine used in emergency and non-emergency purposes andkeep records of the back pressure monitor for particulate if applicable.

§60.4218: This condition explains that the applicability of the General Provisions in §60.1through 60.19.

§60.4219: This condition explains the definitions used in this subpart.

New Source not added to the permit:

Source ID # 122: consists ofa solvent distillation unit. This source was exempted fromplan approval through a RFD detennination approved on January 5, 2015. This source wasmanufactured by Clean Planet Chemical (Model # A48) and will nonnally process one drum ofsolvent per day. This source has not been installed yet. Thus, this source was not added to thepennit. The source will be included in the pennit through an administrative amendment or at thetime of the next renewal after the installation of this source.

Included New Sources:

Source ID # 123: consists of a small batch paint mixing room. This source is an emittingsource in the Title V pennit because the source is emitting VOCIHAP and has RFD conditions.

This source was exempted from plan approval requirements as stated in 25 Pa. Code §127.14 (a)(8) [#31- Sources of uncontrolled VOC emissions less than 2.7 tons per year]. This condition hasbeen included in the source level as a restriction requirement. The following RFD conditionshave been included in the permit:

(a) The owner/operator shall maintain records sufficient to demonstrate VOC and HAPemissions from the source. This shall include the following at a minimum:

1) The MSDS of each VOC and, HAP containing material shall be maintained,2) The total monthly consumption of each VOC and, HAP containing material shall bemaintained.

(b) All records shall be maintained onsite for a minimum of five years and shall be madereadily available to the Department upon request.

Flow Diagram:

BatchPaintMix

Source ID #124: consist of the paint kitchen. In this room, paint mixing operations takeplace. This source was included in the miscellaneous section of the permit as an insignificantactivity. This source is now subject to 40 CFR Part 63 Subpart MMMM because of paint mixingoperation. This source was included in Group number 4. Group #4 contains the applicableconditions of Subpart MMMM.

Flow Diagram:

PaintKitchen

Fugitives

Applicability of40 CFR Part 63 Subpart DDDDD

Source ID # 111: Caustic Anodizing Tank Heater and Source ID #116: Two wash water heatersand four anodizing line tank heaters are subject to 40 CFR Part 63, Subpart DDDDD.

The following conditions of Subpart 5D have been included in the permit:

§63.7480: This condition explains the applicability of the subpart for boilers and process heaters.The Subpart establishes the requirements for initial and continuous compliance with the emissionlimitations and work practice standards.

§63.7485: This condition explains that the owner or operator of industrial process heaters at amajor source of HAP emission will be subject to this subpart.

§63.7490 (a) (1), (d): This condition explains that a process heater is existing ifit is not new orreconstructed. Based on the construction dates for the process heaters, they are consideredexisting.

§63.7495 (b), (d): This condition explains the compliance date for the existing process heaters(no later than January 31, 2016, the owner or operator of a process heater must comply with thework practice standards of this subpart).

§63.7499 (1): This condition explains the subcategory of the process heaters is units designed tobum gas 1 fuels.

§63.7500 (a) (1), (e) and (f): This condition explains the work practice standards in Table 3(tune-up every 5 years for the process heaters rated less than 5 rnmbtu/hr and every 2 years forthe process heaters rated between 5 and 10 rnmbtuJhr).

§63.7505 (a): This condition explains the source must be in compliance with the work practicestandards.

§63.7510 (e): This condition explains the initial tune-up must be conducted by the compliancedate.

§63.7515 (d): This condition explains the requirements of subsequent tune-ups.

§63.7530 (d), (f): This condition explains the owner or operator of the process heaters mustsubmit a signed statement in the otification of Compliance Status report subsequent to theinitial tune-up.

§63.7540 (a), (12), (13), (b): This condition explains the tune-up frequency for the processheaters based on the heat input.

§63.7545 (a), (b), (e), (1), (6), (7), and (8) (i): This condition explains the initial notification dateand the notification of compliance status

§63.7550 (a). (b), (1)-(4), (h), (3): This condition explains the reporting process for the tune-upsthrough the EPA electronic CEDRl system.

§63.7555 (a) (1), (i), (j): This condition explains the record keeping requirements for the processheaters (each notification and records of startup/shutdown).

§63.7560 (a)-(c): This condition ezeplains format of the record keeping by the facility.

§63.7565: This condition explains that Table 10 describes the General Provisions in §63.1 to§63.15 that are applicable to the facility.

§63.7570 (a), (b): This condition explains the implementation and enforcement of this subpart.

§63.7576: This condition explains the related definitions that apply to this subpart.

Table 3 (1): This table condition describes the tune up process for the process heaters explainedin §63.7540.

New Insignificant activities:

The facility reported the following insignificant activities those exhausts inside the facility andnot included in the previous permit:

Location Building Equipment Source Source ventedOperation Information

A Autoclave Electric Source- no Outsideemissions, PVB filmused between glass

A Boil Tank Electric source is Insideassociated with R & not regarded as anD was identified emitting source.during audit. This isa 40 gallon electricheater

A Bystronics Line No VOC / fugitive Insideemissions / ventsindoors / product isa paste, noparticulates or dust /no IH monitoring

done for this areaA Edge Deleters (4 Dust collector vents Inside

Units) Bystronics, indoors, areaheat mirror, supervisor estimateslaminating, approximatelytempering 0.01% of glass

weight is lost at theseaming operation(compared to a maxestimate of 1% atglass cutting)

A Lasic / Bender Area Saw has a cloth bag Insideon saw. Chips fall toground.

A Multan Area - Saws are either InsideCutoff Saws (3) vented to indoor

dust collectors/drumor chute/drum. otvented outdoors

A Seamer with dust Dust collector vents Insidecollector or indoors, arealaminating line supervIsIOn

estimatesapproximately0.01 % of glassweight is lost at theseaming operation(compared to a maxestimate of 1% atglass cutting)

A Tempering oven S02 is used to coat InsideS02 the rollers so they

don't make a markon the glass

A receiving Deck Propane Filling Operation N/Apermanentlydiscontinued in May2011

B Bender L2 (Curve Saws are either InsideTop) (4 Saws) vented to indoor

dust collectors /

drum or chute 1drum. Not ventedoutdoors

B Central Saws (-15) Saws are either Insidevented to indoordust collectors 1drum or chute 1drum. ot ventedoutdoors.

B Cutoff Saws- Inside.Assembly, Vinyl,Crating

B Fleet Maintenance - Air exchange OutsideExhaust System (2) system for vehicle

exhaust fromvehicle exhaustfrom vehicle garagearea.

B P & D Saws Saws are either Insidevented to indoordust collectors 1drum or chute 1drum. Not ventedoutdoors.

B Shipping Area Propane Filling Operation N/Apermanentlydiscontinued in May2011

C Aerosol Can VOCs from Aerosol InsidePuncture Device Cans

C Die shop sand Vents indoors Insideblaster (2 Units)

Laboratory A portable fume Vents indoors and is Insidehood or vent system filtered by activatedfor industrial carbon.hygiene in alaboratory

C Filling or paint Fugitive Emissions Insidebottles for external 4 OZI bottle. 75use. bottles 1month. See

"representative"

MSDS forPPGDuracryl AcrylicLacquer, max VOCcontent = 79%

C Finishing Saws (3 Saws are vented to InsideUnits, Press #1, indoor dustPress #2, Press #3 collectors / drum.

Not ventedoutdoors.

C Paint Kitchen Ancillary to Insidepermitted sources101 and 102

C Wood Saw Dust collector vents Insideindoors.

Pool Area Swimming Pool atural Gas Heater OutsideHeater (0.399 MM for swimming PoolBTUIHr.)

All of the above sources have been included in the miscellaneous section of the permit asinsignificant activities.

RFD Tables:

The following table covers the list ofRFD applications and determination results submittedduring last five years:

RFDDateand Description of Determination Inclusion or CommentsNumber RFD exclusion in

renewal Title Vpermit

October 24, Construction of Exempted from This source is All applicable2011, #10- an auxiliary plan approval subject to 40 conditions of000267 emergency requirements as CFR Part 60, Subpart TIn

generator. stated in 25 PA Subpart IIII have beenCode 127.14(a)(8) This source is included in the#6 .an emitting permit.

source and isincluded as anew Source ID# 121.

April 1,2014, Addition of a This source was The new tankRFD #10-000- new sulfuric exempted from was added to00267 acid anodizing plan approval Source ID #

tank to Source requirements of 25 112 with theID #112 Pa. Code §127.14 previous three

(a)(8), #36 acid tanks #15,[deminimis #16 and #17.increase] The number of

Sulfuric Acidtanks is nowfour.

September 9, The project is This source was This source has All RFD2014, to install a new exempted from the a scrubber and conditions and

acid etch requirements of a some RFD recordkeepingprocess tank Plan Approval as conditions. and workand associated per 25 Pa. Code Thus anew practiceaccessories to §127.14(a) (2), Source ID #120 standards ofthe facility's combustion unit has been added Scrubber haveexisting rated less than 2.5 to the permit. been includedaluminum MMBTU/Hr. and in the sourceanodizing line. the acid etch level.

process tank wasexempted as per§127.14(a)(8)(#44)

January 5, 2015 The project is This source was The RFD has This source willto install a exempted from some be included insolvent plan approval conditions. The the permit afterdistillation unit requirements as Source is not the successfulto the site's per 25 Pa. Code installed yet, installation ofpainting §127.14 (a)(8) #36 thus, the source the equipmentoperations. is not included through an

in the permit. AdministrativeAmendment orat the time ofrenewal.

April 7, 2015 Replacement of This replacement This is a o changes inthe log oven of log oven was replacement of the renewaland shear on an exempted from equipment. Title V permit.existing plan approval Thus, thealuminum requirements as replacementextrusion press per §127.14(a) (8) does not affectsystem with a #34 and #44. Source ID#

newer log oven 107. The sourceunit, remains the

same as beforewith the newreplacement.

June 8, 2015 Small batch This source has Anew Source All RFDpaint mixing been exempted ID # 123 has conditions haveoperation. from plan approval been created for been inc!uded

requirements as the batch paint in the permit.per §127(a)(8)[#31 mixmgSources of operation room.uncontrolled VOCemissions less than2.7 tpyl

July 17,2015 Portable fume This source was This source has This source washood to extract exempted from been added in exempted fromthe iso-propyl plan approval the insignificant the Title Valcohol from requirements as activities list in permit becausethe breathing per 25 Pa Code the the source islevel and non- §127.14 (9) [#14- miscellaneous used in abreathing zone Installing a fume section of the laboratory andof laboratory. hood or vent permit. is a bench-scale

system for unit as perindustrial hygiene Trivialpurpose or m a Activities listlaboratory] #39: Bench-

scale laboratoryequipment usedfor kineticstudies,mass/energytransportstudies,chemicalsynthesis andphysical orchemicalanalysis

Answer to the comments offacilitv:

On August 19,2015 Mr. Keith Cessna of Alcoa sent the following comments on the draftrenewal Title V permit of Alcoa Commercial Windows, LLC. The Department's answer to thecomments are described hereunder:

1. Risk Management ProgramPage 15, Section B, Condition #026

This facility does not trigger 40 CFR Part 68 requirements. We request that Part 68 regulatorylanguage beginning with paragraph (b) be marked "Not Applicable" and not included in thepermit.

Department's answer: Please note that Section B: General Title V requirements are all pre­programmed conditions. The conditions are applicable to all Title V permits in Pennsylvania.The Regional Office is unable to change any condition of Section B. The Department maychange the conditions of Section B in the future and, the change would be incorporated in thepermit accordingly.

2. Compliance CertificationPage 21, Section C, Part VIII

In the permit renewal application, the facility requested that the annual compliance reportingperiod be adjusted to match the January to December calendar year. The draft permit currentlysays that the annual compliance certification must be submitted "within 30 days of 12/01/2010."The 2010 date appears to be a holdover from the current permit language, and should be changedto "within 30 days of 12/3112015." Requiring submission of the certification within 30 days ofDecember 1 means that the compliance certification cannot represent a calendar year, but isinstead based on a December 1 to November 30 reporting cycle. To address these issues, werequest that the language in the permit be modified to read as follows:

The permittee shall submit within thirty days of 12/31/2015 a certificate of compliancewith all permit terms and conditions set forth in this Title V permit as required undercondition #24 of section B of this permit, and the thirtieth (30th

) day following the endeach calendar year thereafter.

Department's answer: The Department could alter the compliance certification datefrom 12/01/2010 to 12/31/2015 but the rest of the condition will remain the same. Theformat of the condition is pre-programmed. The Region is unable to change any sentenceof the condition at the present time, unless it will be reprogrammed.

3. Part 64 Compliance Assurance Monitoring

The way the permit is laid out, it appears that the requirements of 40 CFR Part 64 (CAM)have been imposed on emissions subject to regulation under 40 CFR 63, SubpartMMMM. Per 40 CFR 64.2(b) (1) (i), "The requirements of this part shall not apply toemission limitations or standards proposed by the Administrator after November 15, 1990pursuant to section III (NSPS) or 112 (NESHAP) of the Act." Sources 101 and 102 atthe facility are subject to NESHAP Subpart MMMM regulations which were promulgatedon January 2, 2004. Because this ESHAP was promulgated after November 15, 1990(and because the facility employs the "emission rate without add-on controls" complianceoption under the NESHAP standard), Part 64 does not apply to the facility. We believethat CAM is only applicable to the facility due to the Title V/State VOC requirements andrequest that the CAM requirements be placed in a different order within the permit toclarify that the requirements apply due to applicability of the State implementation planrequirements for VOCs. (i.e. Title V/State requirements for VOCs not MMMM).

The permit sections for which this comment concerning part 64 CAM applies are asfollows:

Page Section Source Part Condition #ID

37 D 101 IV 01755 D 101 VI 03157 D 101 VI 03268 D 101 VI 04487 D 102 VI 025

Department's answer: If the permit is saved in a Group format you would see the CAMconditions in Group #3 and in Group #4 you would see the conditions of SubpartMMMM conditions separately. But, through an e-mail fromMr.Keith Cessna, the facilityrequested to print the permit in a Source format. In the Source format, you will not seethe CAM and Subpart MMMM requirements separately.

4. Non-Applicable NESHAP General Provisions Sections

In a few places within the draft permit, sections of the NESHAPS General Provisions thatare not applicable to Subpart MMMM regulated sources are referenced. Table 2 toSubpart MMMM clarifies the non-applicability of these provisions. It is requested thatreferences to the following general provisions sections be marked as on-Applicablewithin the permit.

Page Section Source Part Condition # Non Applicable Section ofID General Provisions per Table 2 to

Subpart MMMM34 D 101 IV 014 63.1 O(b)(2)(xiii)

Renewal Title V Permit of Alcoa Commercial Windows, LLC 15

81 D 102 V 021 63.10(d)(3)98 D 102 VII 037 63.1 O(b)(2)(xiii)

Department's answer: The Department agrees that the above provisions are notapplicable and have been marked as such in the revised permit.

5. NESHAPS General ProvisionsPage 59, Section D, Source 101, Part VII, Condition #036

Table 2 to Subpart MMMM should be incorporated into the permit in its entirety (e.g., asan Appendix) rather than solely incorporated by reference.

Department's answer: As per your request the Department will include the Table 2 inthe renewal permit in Alcoa's permit.

Decommissioned Sources

6. Page 107, Section D, Source 105The facility currently only has one Fill Line Adhesive Application. The information forSource 105 on page 107 of the draft permit should be changed to refer to only one line.

Department's answer: The Department has deleted the word (2 lines) after Fill LineAdhesive Application in Source 1D # 105. Because, there is only one Fill Line AdhesiveApplication source in the permit.

7. Page 109, Section D, Source 107

The facility currently only has one 1800-ton Extrusion Press & Preheater. The secondunit was dismantled and removed in February 2015. The information for Source 107 onpage 109 of the draft permit should be changed to refer to only one source.

Department's answer: The Department will delete the number 2 before, 1800 TonExtrusion Press Preheaters, Source 1D #107. Because, there is only one source present inSource 1D #107.

8. Sources Regulated by Boiler NESHAPPage 127, Section D, Source 116, Part II, Condition #004

Not all of the Miscellaneous Natural Gas combustion units that are included in Source116 are regulated under the Boiler NESHAP (Subpart DDDD). Clarification is needed asto which units are subject to the rule. As indicated in the Addendum to Attachment 5 ofthe permit application package, the 116 source units that are subject to the BoilerNESHAP rules are two Paintline Washer units that are regulated process heaters and fourAnodizing Tank heaters that are also regulated process heaters.

Renewal Title V Pennit of Alcoa Commercial Windows, LLC 16

Department's answer: The Department has included the names of the applicable sourcesto Subpart DDDD of Source ill #116 in paragraph (b) of Section H [Miscellaneous] toclarify that only the paintline washer units and the four anodizing tank heaters are subjectto Subpart DDDD.

9. Emergency Generator NESHAP ApplicabilityPage 140, Section D, Source 121

The draft permit incorporates applicable ew Source Performance Standards (NSPS)regulatory language for this source. However, the permit does not incorporate applicableNESHAP regulatory language for this source. This source is subject to the 40 CFR Part60 NSPS rules and to the 40 CFR Part 63 NESHAP rules under Subpart ZZZZ. It isacknowledged that compliance with the NESHAP is achieved via compliance with the

SPS requirements. We believe that both rule sections are applicable and that both rulesections should be incorporated into the Title V permit language for this source.

Department's answer: The Department has added condition §63.6590 (c)(l) of 40 CFRPart 63, Subpart ZZZZ where it is indicated that the affected new source will be Subjectto 40 CFR Part 60 Subpart 1Ill and no further requirements apply under Subpart ZZZZ.For the purposes of Subpart ZZZZ, a new source means the source that was constructedafter June 12,2006 at an area source facility.

10. Emergency Generator RecordkeepingPage 140, Section D, Source 121, Part IV, Condition #005

The draft permit includes language requiring maintenance of monthly records of Oxemissions to demonstrate that the emissions ofNOx are less than 100 Ibs. /hr., 1000 Ibs./day, 2.75 tons per ozone season and 6.6 tons per year on a 12-month rolling basis. Whenevaluating the 6.6 tons per year limit, the facility would need to operate the emergencygenerator for approximately 1500 hours per year to generate 6.6 tons ofNOx. Thefacility's total combined operating hours for this source since its initial installation in2011 is approximately 30 total hours. It is extremely unlikely that the facility would everoperate this unit for 100 hours/year and unfathomable that it would operate more the 1000hours a year. We believe that monthly recordkeeping to demonstrate compliance withthese emissions limitations is unduly onerous and burdensome. We request that thepermit condition be changed to require annual recordkeeping and annual calculation todocument compliance with the emissions limitations.

Department's answer: Based on the limited number of hours of use by this engine it ishighly unlikely that the engine would need to run 1500 hours per year for emergency use.However, since the 6.6 tons of NOx limit is based on a 12-month rolling basis, thefacility will need to calculate the Ox emissions each month to demonstrate compliance.

11. Solvent Distillation Unit

Renewal Title V Permit of Alcoa Commercial Windows, LLC 17

18

Page 147, Section D, Source 122

The facility has not yet installed this source. Future installation is still being considered,but since the unit is not currently installed our understanding from speaking with thePermit Writer is that the source must be removed from the permit at this time. We arecomfortable with its removal from the permit, and will plan to notify the Agency if thesource will be installed in the future. In the interim, please be aware that the previouslysubmitted Request for Determination is still representative of the source that is beingconsidered for installation.

Department's answer: The Department has removed the Source ill #122: SolventDistillation Unit from the permit because the source has not been installed yet.

12. Small Batch Paint Mixing RoomPage 148, Section D, Source 123, Part IV, Condition #002

Kawneer does not use MSDSs to obtain VOC and/or HAP content information for thematerials, but instead relies upon other manufacturer information, such as EnvironmentalData Sheets. The language for Source 123 should be modeled after the similarrequirements for Source 101 on page 31 of the draft permit, conditions # 010 and #011.Those conditions require that the permittee "maintain a monthly record ofVOCemissions from this source" and "maintain daily records of the following parametersfor each coating, thinner and other component as supplied: (2) The VOC content ofeach coating, thinner and other component as supplied" and "(3) The VOC content ofeach as applied coating," with similar expectations for HAP content.

Accordingly, we request that the language for Condition #002 (a) be modified toeliminate the requirement to use material safety data sheet information. Accordingly,condition #002 (a) should be modified to read as follows:

(a) The owner/operator shall maintain records sufficient to demonstrate VOC andHAP emissions from the source. This shall include the following at a minimum:1) A record of the VOC and, HAP content of each VOC and/or HAP containingmaterial,2) The total monthly consumption of each VOC and, HAP containing material.

Department's answer: The Department has changed the Condition # 002 ofSource ID # 123: Small Batch Paint Mixing Room because, the facility is notgetting the information ofVOC and HAP content from MSDS. Instead, Alcoauses manufacturer's information (such as Environmental Data Sheets) to get theVOC/HAP content. Thus, the condition #-002 (a) 1) has been changed to (a) Theowner/operator shall maintain records sufficient to demonstrate VOC and HAPemissions from the source. This shall include the following at a minimum:

Renewal Title V Permit of Alcoa Commercial Windows, LLC

1) A record of the VOC and, HAP content of each VOC and, HAP containingmaterial,

2) The total monthly consumption of each VOC and, HAP containing material.

13. Miscellaneous SourcesPage 152, Section G, Part a

The following corrections are needed to ensure the accuracy of the Miscellaneous Sourcelist:

• Change the description for Source 21 to "Boil Test Tank".• Remove the Propane Filling station (Source 28) from the list. It has been

removed from service.• Correct the spelling for Source 33 to "P&D Saw," rather than "P&D Save."

Department's answer: The Department will revise the typographical errors in the list ofinsignificant activities stated in the miscellaneous section of the permit on page #152 foritem # 21, #28 and #33 as requested by you.

14. Paint Kitchen, Miscellaneous Source No. 39Page 152, Section G, Part a

As part of the permit renewal application, documentation was included to request that thefacility's existing "Paint Kitchen" be added to the permit as an insignificant source. ThePaint Kitchen is an existing emission unit that has been an integral part of the paintingoperation since 1987. Emission estimates indicate the paint kitchen is an insignificantsource ofVOC emissions, at less than one ton/year. However, as a component of theoverall paint line operation, it is subject to the Subpart MMMM NESHAP. As such, werequest that it be noted in the permit that Miscellaneous Source Number 39 is aninsignificant emission unit and that it is subject to the Part 63 Subpart MMMM NESHAPrequirements.

Department's answer: The item #39 has been removed from the insignificant activitieslist and Source 124 has been created in the permit to account for the requirements for thepaint kitchen which are the same as the existing Group #4.

15. Source 116 DescriptionPage 152, Section G, Part b

The description for Source 116 should be changed to read as follows:

(b) For the purpose of this permit, Source #116 is comprised of:

(1) Two wash water heaters(2) One Dry off oven

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(3) Four anodizing line tank heaters

The paint line pre-heater that is shown in the list as Item 3 in the draft permit wasremoved from service in June 2011 and is no longer present onsite. The paint line pre­heater should be removed from the Source #116 description.

Department's answer: The Department has revised the Source ill #116 description inthe miscellaneous section as requested by you.

16. Source 119 Degreaser UnitsPage 153, Section G, Part!

The facility currently has six degreaser units, not seven. There is one 30-gallon unit, andthe remaining five units are 16-gallons each. We believe that the supplier name "SafetyKleen" should be removed from the description of the Source 119 degreaser units."Safety Kleen" is a supplier name and suppliers may change over time. Should the VOCcontent of the degreasing fluid change, an update to the will be provided.

We propose that the permit language read as follows:

(f) Source ID # 119 consists of 6 degreaser units.

Department's answer: The Department has revised Source ID # 119 to indicateit consists of 6 degreaser units and removed the brand name of "Safety Kleen".However, the facility must notify the Department prior to changing any degreaserunit or degreasing solution to verify the quantity ofVOC emissions andrequirements for any new or modified degreasers.

17. General Comment, Part 82 ApplicabilityIt is not noted in the permit that 40 CFR Part 82 requirements apply. The facility operatesappliances containing ozone-depleting substance, some are large units, containing morethan 50-lbs of refrigerant, and other are small units containing less than 50-lbs ofrefrigerant. These units are subject to 40 CFR Part 82 requirements for reducing theemissions of class I and class IIRefrigerants and for maximizing the recapture and recycling of such refrigerants duringthe service, maintenance, repair, and disposal of appliances. Since Part 82 is anapplicable requirement, it should be added to the Title V permit.

Department's answer: The Department has added all applicable conditions of 40 CFRPart 82 Subpart F in the site level for the facility wide emission restriction of refrigerants.

18. Other Minor ChangePage 31, Section D, Source 101, Part IV, Condition #010

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The word "emissions" is misspelled in the second sentence of this paragraph "missions."This sentence should be corrected to read as follows:

Monthly emissions shall be added with the emissions from previous 11 months todetermine the consecutive 12-month total.

Department's answer: The Department has revised the misspelling of the wordemissions in Source ID # 101, Condition #010.

Change ofnumber ofequipments in Source level:

Source ID # 112: Sulfuric Acid anodizing tanks has added one more tank through anapproved RFD dated April. 2014. The number of tanks increased from three to four.

Source ID #119: The number of Degreaser units has changed from seven to six. Onedegreaser unit has been removed from the source level.

All the above changes have been included in the renewal permit.

Prohibition ofair pollution:25 Pa Code §121.7 prohibition of air pollution condition has been added to the workpractice standard requirements in the site level of the permit.

Compliance Issues:

The facility was inspected (Full Compliance Evaluation (FCE)) on July 7, 2011, July 12,2012, May 23,2013, April 30, 2014 and April 30, 2015. No violations were noted fromany of these inspections.

Emission statement:

The actual emissions of pollutants submitted by the facility for the 2014 emissioninventory are as follows:

CO: 4.54 Tons per year (TPY)Ox: 5.41 TPY

1.58 TPYPM10: 1.58PM2.5: 1.58 TPYSOx: 0.03 TPYVOC: 19.08 TPY

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• All the other conditions and sources are the same as the previous operatingpermit and memorandum with Auth. ID # 910506.

After conducting a permit renewal inspection with Mr. Darren Scott Dyll on August 5,2015, I recommend the renewal ofthis permit.

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