p. 1 of 5 

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 primary aluminum facility 

OK- thanks for the info. I’m quite sure the “industrial processes” on the non-category tab does relate to 

vehicular traffic on roads around the plant. We do report this as part of our annual emission inventory. 

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 primary aluminum facility

Steve, 

Thanks for taking a look at the spreadsheet for me – I 

really appreciate your assistance in this risk assessment 

project. 

I have included part of my email response to another 

industry representative who also had questions on this 

modeling exercise (below in red text) and what I was 

requesting. Hopefully that response will help clarify my 

request. 

Now, back to your question as to what is meant by 

“Industrial processes ...” in the non category tab portion in 

the spreadsheet? That really gets to the heart of my 

initial request. We got the non category information from 

the National Emission Inventory (NEI) databases and other 

state input. As you can imagine there is quite a bit of 

variation between how the various states and local agencies 

put data in the NEI and how they refer to the associated 

emissions sources. So, the short answer is ... I’m not 

exactly sure what is meant by “Industrial processes ...” in 

the non category tab portion in the spreadsheet. Actually, 

that is the exact sort of thing for which I’m reaching out 

to industry for assistance. I’m hoping that you could tell 
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by the location, pollutants and magnitude of emissions what 

is the referenced source. Then, we will include or remove 

the associated emissions in the risk model as appropriate 

(see last paragraph in red text below). 

“Please do not overestimate what I am looking for in 

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 point. I 

believe the current year is used simply to show that it is 

a recent risk analysis and that the facility was operating 

in 2013. Please do not try to correct the spreadsheets to 

reflect your CY2013 production. 

We feel fairly confident in the source category emissions 

and locations of emissions sources since we got industry 

test data to estimate emissions and industry review of 

locations in the previous (initial) proposal. Although, if 

something jumps out at you as being obviously incorrect in 

the source category tab of the spreadsheets then you are 

welcome to bring it to my attention. 

The main thing I am requesting is for industry to review 

the non source category tab of the spreadsheets so as to 

ensure we are not including emissions in the risk modeling 

that should not be included (e.g., for a boiler that no 

longer exists), and not double counting the emissions that 

should be included (e.g., emissions that are part of 

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) 541-3207 
p. 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 primary 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 roads? 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 primary aluminum facility

Hello Steve, 

I am currently working on a supplemental proposal for the 

residual risk and technology review (RTR) of the NESHAP for 

Primary Aluminum Production facilities. Part of that review 

includes developing an emissions file for each primary 

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 aluminum 

production facility. Columns highlighted in yellow are 

available for revisions or to indicate if records should be 

deleted. Please do not overwrite the data in columns that 

are not highlighted in yellow as this would complicate the 

development of the final emissions file for use in the risk 

modeling. 

The tab titled “primary Al category” includes emissions 

from the primary aluminum production operations (e.g., 

potlines, paste plants, pitch storage tanks, and anode bake 

furnaces) at the CFAC facility as estimated via emission 
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factors developed from test results obtained in response to 

a testing ICR sent out in April of 2013. I expect that 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 aluminum 

production source category. There are, however, some 

emissions (e.g., metal HAP, dioxins, PCB, etc.) that are 

new to the RTR analysis for the primary aluminum production 

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 emissions. A 

revision column highlighted in yellow is provided for 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 aluminum 

production facility. These records are intended to include 

emissions from operations at your facility which are not 

directly associated with primary aluminum production 

(primary aluminum emissions are addressed under the first 

tab, discussed above) or secondary aluminum production 

(secondary aluminum emissions will be addressed via the RTR 

associated with the secondary aluminum source category). 

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 corrected 

value in the associated revision column (again, please do 

not overwrite the data in columns that are not highlighted 

in yellow). Note that fields were also added to identify 

if a record should be deleted, and a reviewer comment 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 permit for this operation) then the operation 

and associated emissions need not be included. 
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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 operation and associated emissions need not be 

included (so as to avoid double counting those emissions). 

c. If the operation does exist at the facility, would the emissions from this operation be 

considered part of the monitored primary aluminum emissions? For example, if the emissions 

associated with the operation in question are routed 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 included (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 emissions 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 by 

01/03/14 and remember that you will have another 

opportunity to make comments and corrections during the 

upcoming public notice and comment period associated with 

the primary aluminum production RTR supplemental proposal. 

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