1 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/cla rifications 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, T able 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 o f 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 pe rformed 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 SW

846 Method 3050B for digestion. If you have not already performed sampling and analysis, we req uest that you use SW

846 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 wate r.]

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 samp le 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 o r 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 Reynol ds 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. Environme ntal 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