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From: Putney.David@epamail.epa.gov

Sent: Friday, May 06, 2011 11:49 AM

To: Michael.Palazzolo@alcoa.com; ksands@centuryky.com; jvanmatre@centurywv.com; 

danny.carroll@riotinto.com; kisnerj@noralnm.com; John.Reggi@ormet.com; 

Henk.VanDerMeyden@alcoa.com

Cc: cjohnson@aluminum.org; Bahner, Mark A.; Green, David A.

Subject: PAL ICR corrections/clarifications

Hello all, 

I have had a couple of issues brought to my attention concerning the recent Information Collection Request (ICR) that 

EPA recently sent out to the primary aluminum (PAL) industry facilities. Specifically, I would like to offer the following 

corrections/clarifications to that document: 

First, question 23 on page 20 of 20 in Part D of Enclosure 1 refers to air monitoring that you may have conducted "to 

measure COS concentration and/or emissions of sulfur oxides." The intent here is to collect information on COS and SOx 

that was collected during the same time period. That is, we want you to submit information (if you have it) on monitoring 

conducted that will provide information on the proportion of anode sulfur that is emitted in COS versus SOx. 

Second, Table 1.2 on page 2 of 3 in Enclosure 2 is incomplete. Specifically, the methods listed in that table only apply 

to liquid samples (such as those collected from the blow down of a wet scrubber). Also, the cited digestion method is not 

the preferred method of digestion. Finally, the methods for solid samples (such as those collected from a bag house or an 

ESP) are not included. To address these issues, please follow the following guidance for solid samples (these methods 

may be used for other samples as well as long as the matrix is appropriate for the analysis): 

1. Acid digestion methods may not be substituted for the microwave assisted acid digestion method for HAP metals. 

SW-846 Method 3052 is the preferred digestion method; if you have already performed analysis using SW-846 Method 

3051A for digestion, as was stated in the ICR, we will accept those results. However, we will not accept results using SW846 Method 3050B for digestion. If you have not already performed sampling and analysis, we request that you use SW846 Method 3052 for these samples. 

2. Hexavalent chromium should be analyzed via SW-846 Method 7199. We recommend the following sample 

preparation/extraction prior to analysis: 

A) Add 5 mL of 20 mM sodium bicarbonate extraction solution to a known weight of bag house particulate (1.0 g) in a 

(~15 mL) disposable polystyrene round bottom tubes with snap cap. [Sodium Bicarbonate Extraction Solution (20 mM), 

dissolve 1.68 grams (g) of sodium bicarbonate) in 2.0 mL DI water.] 

B) Cap the tube tightly with plastic snap caps and shake the extraction tube for a minimum of 5 minutes (do not 

sonicate). 

C) Extracted samples are filtered with 0.45 micrometer or smaller pore size acetate membrane filters to remove 

insoluble material. Collect the extract in a second disposable polystyrene round bottom tube. 

D) Sample filtrate should be washed 2 times with enough 20 mM sodium carbonate to recover 2 ml of wash. Washes 

should be combined with the original sample extract. 

E) Dilute samples to exactly 10.0 mL and analyze by SW-846 Method 7199. 

Thanks to everyone for your patience and feedback on this ICR. Please feel free to contact me if you have any 

comments/questions concerning the ICR in general or these issues specifically. 

Thanks again, 
2

David Putney

Chuck,

Would you please assist me in getting this information to a couple of PAL contacts? I had email addresses for everyone 

that we sent a PAL ICR to except for Dennis Krause of the Reynolds Metals St. Lawrence Reduction Plant facility and 

Heidi Wilson of Intalco Aluminum Corp. Could you please provide me with their email addresses so I can forward this 

message to them?

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