p. 1 of 2 

From: Coomes, Jamie [mailto:JCoomes@centuryky.com] 

Sent: Wednesday, October 02, 2013 12:26 PM 

To: Putney, David; Lane, Sean 

Subject: RE: TF emissions data 

David attached is your request for TF emissions from potlines for the first semiannual period of 2013.

Thanks 

Jamie 

From: Putney, David [mailto:putney.david@epa.gov] 

Sent: Monday, September 16, 2013 10:28 AM 

To: Lane, Sean; Coomes, Jamie 

Subject: RE: TF emissions data 

Good point Sean, I should have been more specific. 

What I am looking for is TF emissions (primary and secondary) from the potlines. Emissions from the carbon 

bake are low and probably not significantly impacting the risk estimates and TF emissions are not expected 

from the paste plant. 

Thanks, 

David Putney, Environmental Engineer 

U.S. Environmental Protection Agency 

Office of Air Quality Planning and Standards 

Sector Policies and Programs Division 

109 T.W. Alexander Drive, RTP, NC 27711 

Mail Drop D243-02 

Ph: (919) 541-2016 Fax: (919) 541-3207 

Email: putney.david@epa.gov

From: Lane, Sean [mailto:SLane@CenturyKY.com] 

Sent: Monday, September 16, 2013 11:05 AM 

To: Putney, David; Coomes, Jamie 

Subject: RE: TF emissions data 

For which source? CWPB1, CWPB3, Carbon Bake? We have no data for the Paste Plant as it was not required 

to be tested. 

Thanks 

Sean 

 
p. 2 of 2 

From: Putney, David [mailto:putney.david@epa.gov] 

Sent: Monday, September 16, 2013 10:03 AM 

To: Lane, Sean; Coomes, Jamie 

Subject: TF emissions data 

Hello Sean/Jamie, 

We (EPA) are finishing up our review of the emissions test results you submitted in response to the 

Information Collection Request (ICR) sent out in March of 2013. Thank you so much for the time and effort you 

dedicated to conducting those tests and submitting the results. The next step in the residual risk analysis is to 

develop the risk modeling files for your facility. It is essential that we use the best, most accurate estimates of 

your facility’s emissions in these files so as to most accurately estimate the residual risk from your facility (i.e., 

the risk remaining after application of the MACT standards). Through the 2013 ICR we have obtained recent, 

reliable data for emissions of metals and POM. 

However, we did not collect TF data via the 2013 ICR. Since TF affects the multipathway risk assessment, the 

ecological risk assessment, and the acute risk assessment a reduction in the estimates of emissions of that 

pollutant can have a significant impact on the estimate of residual risk associated with your facility. 

With that in mind, I am asking for some recent data on TF emissions from your facility (e.g., from NESHAP 

compliance reports). If possible, could you please send me some data (a summary table of values cited in 

NESHAP compliance reports) for a few recent, representative TF emission rates for your facility by COB this 

Friday (09/20/13)? This data would allow me to avoid using the emission rates allowed under the NESHAP to 

estimate your TF emissions (which would likely overestimate your facility’s TF emissions and the associated 

risks). 

Thanks so much, 

David Putney, Environmental Engineer 

U.S. Environmental Protection Agency 

Office of Air Quality Planning and Standards 

Sector Policies and Programs Division 

109 T.W. Alexander Drive, RTP, NC 27711 

Mail Drop D243-02 

Ph: (919) 541-2016 Fax: (919) 541-3207 

Email: putney.david@epa.gov