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From: Steve Wright [ mailto:swright@cfaluminum.com ]
Sent: Friday, December 20, 2013 9:59 AM
To: Putney, David Subject: RE: Draft emissions file for the Columbia Falls pr imary aluminum facility

OK- thanks for the info. I’m quite sure the “indus trial processes” on the non-category tab does relat e to vehicular traffic on roads around the plant. We do report this as part of our annual emission invento ry.

Steve Wright Environmental Manager Columbia Falls Aluminum Company 406-892-8211 406-892-8208 (fax) swright@cfaluminum.com

From: Putney, David [ mailto:putney.david@epa.gov ]
Sent: Friday, December 20, 2013 5:43 AM

To: Steve Wright Subject: RE: Draft emissions file for the Columbia Falls pr imary aluminum facility

Steve,

Thanks for taking a look at the spreadsheet for me – I really appreciate your assistance in this risk asse ssment project.

I have included part of my email response to anothe r industry representative who also had questions on t his modeling exercise (below in red text ) and what I was requesting. Hopefully that response will help clari fy my request.

Now, back to your question as to what is meant by “Industrial processes ...” in the non category tab po rtion in the spreadsheet? That really gets to the heart of m y initial request. We got the non category informatio n from the National Emission Inventory (NEI) databases and other state input. As you can imagine there is quite a bi t of

variation between how the various states and local agencies put data in the NEI and how they refer to the assoc iated emissions sources. So, the short answer is ... I’m no t exactly sure what is meant by “Industrial processes ...” in the non category tab portion in the spreadsheet. Ac tually, that is the exact sort of thing for which I’m reach ing out to industry for assistance. I’m hoping that you cou ld tellp. 2 of 5

by the location, pollutants and magnitude of emissi ons what is the referenced source. Then, we will include or remove the associated emissions in the risk model as appro priate (see last paragraph in red text below).

“Please do not overestimate what I am looking for i n response to my email. It really should not take too long to respond to my email. The portion of the spreadsheet that shows CY2013 is misleading – we understand that you do not have production data for all of CY2013 at this poin t. I believe the current year is used simply to show tha t it is a recent risk analysis and that the facility was op erating in 2013. Please do not try to correct the spreadshe ets to reflect your CY2013 production.

We feel fairly confident in the source category emi ssions and locations of emissions sources since we got ind ustry test data to estimate emissions and industry review of locations in the previous (initial) proposal. Altho ugh, if something jumps out at you as being obviously incor rect in the source category tab of the spreadsheets then yo u are welcome to bring it to my attention.

The main thing I am requesting is for industry to r eview the non source category tab of the spreadsheets so as to ensure we are not including emissions in the risk m odeling that should not be included (e.g., for a boiler tha t no longer exists), and not double counting the emissio ns that should be included (e.g., emissions that are part o f collocated secondary aluminum operations).”

Thanks again,

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) 541-3207p. 3 of 5

Email: putney.david@epa.gov

From: Steve Wright [ mailto:swright@cfaluminum.com ]
Sent: Thursday, December 19, 2013 1:12 PM

To: Putney, David Subject: RE: Draft emissions file for the Columbia Falls pr imary aluminum facility

DavidI’m looking over the spreadsheet you sent. On the “ non-category” tab, what activity is covered by the “Industrial processes, ...” ? Is this road traffic on unpaved roa ds? Are the PAH/POM emissions from vehicular sources? Thanks.

Steve Wright Environmental Manager Columbia Falls Aluminum Company 406-892-8211 406-892-8208 (fax) swright@cfaluminum.com

From: Putney, David [ mailto:putney.david@epa.gov ]
Sent: Wednesday, December 18, 2013 8:02 AM

To: Steve Wright Subject: Draft emissions file for the Columbia Falls primar y aluminum facility

Hello Steve,

I am currently working on a supplemental proposal f or the residual risk and technology review (RTR) of the NE SHAP for Primary Aluminum Production facilities. Part of tha t review includes developing an emissions file for each prim ary aluminum production facility which will be used as input to the risk models. To that end ... please find attached to this message a draft emissions file (Excel spreadsheet) for the Columbia Falls Aluminum Company (CFAC) primary alum inum production facility. Columns highlighted in yellow are available for revisions or to indicate if records s hould be

deleted. Please do not overwrite the data in colum ns that are not highlighted in yellow as this would complic ate the development of the final emissions file for use in the risk modeling.

The tab titled “primary Al category” includes emiss ions from the primary aluminum production operations (e. g., potlines, paste plants, pitch storage tanks, and an ode bake furnaces) at the CFAC facility as estimated via emi ssionp. 4 of 5

factors developed from test results obtained in res ponse to a testing ICR sent out in April of 2013. I expect t hat the stack parameters are correct as-is since industry previously had opportunity to review those items in CY2011 with the initial RTR proposal for the primary alumi num production source category. There are, however, som e emissions (e.g., metal HAP, dioxins, PCB, etc.) tha t are new to the RTR analysis for the primary aluminum pr oduction source category and, although these have been QA/QC ’d by contractor and EPA staff, we do welcome feedback/corrections you might have on these emissi ons. A revision column highlighted in yellow is provided f or you to revise emissions (in units of tons per year, tpy ) if

needed.

The tab titled “noncategory” includes 2005 NATA NEI , 2008 NEI and 2010 state HAP data for the CFAC primary al uminum production facility. These records are intended to include emissions from operations at your facility which ar e not directly associated with primary aluminum productio n (primary aluminum emissions are addressed under the first tab, discussed above) or secondary aluminum product ion (secondary aluminum emissions will be addressed via the RTR associated with the secondary aluminum source categ ory). Revision columns highlighted in yellow are included for emissions, pollutants, stack parameters, fugitive parameters and latitude/longitude. If any of these parameters needs modification, please put the corre cted value in the associated revision column (again, ple ase do not overwrite the data in columns that are not high lighted in yellow). Note that fields were also added to id entify if a record should be deleted, and a reviewer comme nt field where you can add a comment if appropriate. Please review these data with the following in mind:

1. Should the operation be included in the spreadsheet ?

a. Does the operation still exist at the facility? If not, or if it exists but is not legally allowed to operate (e.g., you do not have a valid operating pe rmit for this operation) then the operation

and associated emissions need not be included.p. 5 of 5 b. If the operation does exist at the facility, is it part of any secondary aluminum operations that may exist at your facility? If so, then the operati on and associated emissions need not be included (so as to avoid double counting those emis sions).

c. If the operation does exist at the facility, would the emissions from this operation be considered part of the monitored primary aluminum e missions? For example, if the emissions associated with the operation in question are route d through the control device associated with the paste plant and would be monitored as part of the paste plant emissions then the operation and associated emissions need not be incl uded (so as to avoid double counting those emissions).

2. If the operation should be included, are the cited emissions representative of that operation?

3. If the operation should be included but the cited emissions are not representative of that operation, then please provide representative annual actual em issions in units of tons emitted per year (tpy).

4. Verify or modify the stack parameters and location as appropriate and necessary.

Please provide any comments, changes, corrections, etc. to this file to me by close of business on Friday, 01/ 03/14. I understand that more time might be preferable with the holidays upon us, but please give me what you can b y 01/03/14 and remember that you will have another opportunity to make comments and corrections during the upcoming public notice and comment period associate d with the primary aluminum production RTR supplemental pr oposal.

If you have any questions concerning these issues, please feel free to contact me by email or telephone.

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