p. 1 of 3 

From: Putney, David 

Sent: Wednesday, July 31, 2013 1:56 PM 

To: 'Brian Ashbrook' 

Subject: RE: section 114 testing 

Mr. Ashbrook, 

I have a few more questions concerning the emissions testing data submitted for the Ormet primary aluminum 

facility. Please discuss the following issues with the appropriate plant, testing contractor, and laboratory 

personnel and let me know the outcome. 

• First, there are issues with the lead emissions reported for your facility. Specifically, the cited potline 

secondary emissions of about 0.14 lb lead per ton of aluminum produced are very high. I noticed that 

some of the associated lab data lists “iron” where “lead” should be located (see pages 11-26 and 69 of

123 in the file named “DAT Labs Cassette Analysis Report.pdf”). Perhaps there was some sort of mix up 

at the lab? Please verify whether the lab is in fact reporting lead data or iron data in these sheets. In 

any case, it would be good to get a version of this file that lists “lead” instead of “iron” in these spots 

(since it will end up in the docket for this rulemaking). 

• Second, the potline secondary emissions in general (i.e., metals, PM and POM) appear high. After a 

quick review of the file named “Shaw ICP Fug Mtls HAP Rep-7-13.pdf” – it would appear that this could 

be due (at least in part) to an overestimate of your potline secondary flow rates. Specifically, Table 2-1 

(on page 2 of the report hard copy, page 5 of 194 of the pdf version) lists secondary potline flow rates 

(11,341,482 dscfm for potline 2 and 14,553,539 dscfm for potline 3) that are far in excess of what was

cited for your facility in response to the 2011 ICR. In the 2011 ICR response for your facility potline 

secondary flow rates were cited at about 793,500 dscfm. Please confirm or modify appropriately (e.g., 

if the potline secondary flow rates listed in Table 2-1, and presumably used in the emission rate 

calculations, are indeed incorrect) all of the reported potline secondary emissions from your facility. 

Again, I want to point out that we have not finished reviewing the report yet, and we may have other 

questions in the future. Again, not trying to pester you, rather we are trying to resolve questions as we find 

them instead of holding them until the end. 

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

 
p. 2 of 3 

From: Brian Ashbrook [mailto:Brian.Ashbrook@ormet.com] 

Sent: Friday, July 19, 2013 1:13 PM 

To: Putney, David 

Subject: RE: section 114 testing 

Mr. Putney, 

Attached are files that should answer all questions you had during your initial review of Ormet’s 

data. Attached are Ormet’s letter to OEPA notifying them of the special sapling, Ormet’s laboratory test plan 

that was followed for sample collection, Ormet’s emission report , and a revised Table 3-1. 

If there are still questions or concerns, please let me know. 

I can be reached at 740-483-2732. 

Thanks, 

Brian Ashbrook 

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

Sent: Tuesday, July 02, 2013 3:43 PM 

To: Brian Ashbrook 

Subject: RE: section 114 testing 

Mr. Ashbrook, 

During our review of the test data submitted for the Ormet primary aluminum facility pursuant to the recent 

testing ICR, we have found several items for which we need additional information and/or clarification. 

Specifically, 

• It appears that we did not receive the test report associated with secondary potline emissions. The 

submitted reports (DAT Labs Cassette Analysis Report, ITT and cover letter to OEPA, and Ormet ICP 

PM-MCEM Mtl HAP – 2-13&App) do not appear to address secondary potline emissions. The file DAT 

Labs Cassette Analysis Report includes laboratory analyses of the cassettes, but not the emissions 

report. That is, we know the mass of pollutant captured in the cassettes, but not how to convert that 

to a lb of pollutant per ton of aluminum emission rate. 

• The aluminum production rates listed in Table 3-1 on page 5 of the report (on the order of 260 tons 

per hour) appear VERY high. If you will supply a corrected page 5 we can update the report before 

submitting it to the docket. 

Note that in your earlier email you mentioned having trouble using the ERT. My contractor has not been able 

to locate an ERT report for your facility. If you did submit such a report it may be that some of this requested 

information is in that report. Did you ever submit an ERT report for your facility – or was all data included in 

the 3 pdf files you initially submitted? 

I also want to let you know that we have not finished reviewing the report yet, and we may have other 

questions in the future. We are trying to resolve questions as we find them instead of holding them until the 

end. 
p. 3 of 3 

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: Brian Ashbrook [mailto:Brian.Ashbrook@ormet.com] 

Sent: Friday, May 31, 2013 2:14 PM 

To: Putney, David 

Cc: psohi@aluminum.org

Subject: section 114 testing 

Mr. Putney, 

I have attached the ITT for testing, the stack testing report, and the cassette testing report required by Ormet 

Primary Aluminum to fulfill the section 114 request received by Ormet on March 11, 2013. I am having serious 

IT trouble with the ERT access program required by the EPA for submittal and I wanted to submit the data 

before the deadline. I will continue to work with our IT department to remedy this problem. 

Please let me know if there is anything else I need to do. 

Thanks, 

Brian Ashbrook 

Environmental Services Manager 

Ormet Primary Aluminum Corporation 

740-483-2732