ALCOA 

~ 

March 08, 2013 

David Putney 

U.S. EPA Mailroom (D243-02) 

109 T.W. Alexander Drive 

Research Triangle Park, NC 27709 

Alcoa Primary Metals 

Alcoa Mt. Holly 

3575 Highway 52 

PO Box 1000 

Goose Creek, SC 29445-1000 USA 

Tel: 1 843 572 3700 

Fax: 1 843 572 5378 

via e-mail to putney.david@epa.gov 

Re. Request for Approval of Previous Emissions Test Data - Potline PM and POM Emissions 

Information Collection Request for Primary Aluminum Production NESHAP - HAP Metals 

Alumax of South Carolina, Inc. - NEilD 41217 

Dear Mr. Putney, 

As per the information collection request (ICR) letter dated March 04, 2013, I am requesting that 

the U.S. EPA accept previously conducted POM and PM emissions testing results from a Potline at the 

Alumax of South Carolina, Inc. (Alumax) facility in Goose Creek, South Carolina. This testing was 

conducted in February 2012 to evaluate emissions from the Potline roof monitor and Potline primary 

capture and control system with respect to the POM emission limit that was listed in the proposed 

amendments to the national emissions standards for hazardous air pollutants for Primary Aluminum 

Reduction Plants as published on December 6, 2011 (76FR76260). The PM emissions were determined 

in conjunction with the Method 315 POM testing. As detailed below, Alumax believes that the test 

report and supporting information satisfy the requirements for acceptance of previous test reports that 

were stated in Enclosure 1 of the ICR. 

Attached with this letter is a completed Table 4 - Combination Dry Alumina Scrubber/Bag House 

Description for the tested Potline 162E control device. Accompanying this e-mail submittal is a pdf file 

of the Test Report, Potline Roof Monitor and Scrubber Stack POM Test Program, Alcoa Mt. Holly 

Operations, Goose Creek, SC, March 28, 2012, Revised November 30, 2012. Prepared by TRC 

Environmental Corporation, Raleigh, NC. TRC Project No. 190195. 

We appreciate the EPA's timely review of the provided information as Alumax is planning to 

conduct the remaining requested testing. If you have any questions regarding the information provided, 

please feel free to contact Larry McCaskill of my staff at (843) 572-5246 or via e-mail at 

larry.mccaskill@alcoa.com. 

Environmental Manager 

Enclosure 

cc. Mike Rousseau (letter only) 

Mike Palazzolo (letter only) 

Laurie Shelby (letter only) 

previous DOITl test report acceptance reQuest to eoa.docx 
previous pom test report acceptance request to epa.docx 

March 08, 2013              

David Putney             via e‐mail to putney.david@epa.gov

U.S. EPA Mailroom (D243‐02)

109 T.W. Alexander Drive

Research Triangle Park, NC 27709

Re. Request for Approval of Previous Emissions Test Data – Potline PM and POM Emissions

Information Collection Request for Primary Aluminum Production NESHAP – HAP Metals

Alumax of South Carolina, Inc. ‐ NEI ID 41217

Dear Mr. Putney,

As per the information collection request (ICR) letter dated March 04, 2013, I am requesting that

the U.S. EPA accept previously conducted POM and PM emissions testing results from a Potline at the

Alumax of South Carolina, Inc. (Alumax) facility in Goose Creek, South Carolina.  This testing was

conducted in February 2012 to evaluate emissions from the Potline roof monitor and Potline primary

capture and control system with respect to the POM emission limit that was listed in the proposed

amendments to the national emissions standards for hazardous air pollutants for Primary Aluminum

Reduction Plants as published on December 6, 2011 (76FR76260).  The PM emissions were determined

in conjunction with the Method 315 POM testing.  As detailed below, Alumax believes that the test

report and supporting information satisfy the requirements for acceptance of previous test reports that

were stated in Enclosure 1 of the ICR.

Attached with this letter is a completed Table 4 ‐ Combination Dry Alumina Scrubber/Bag House

Description for the tested Potline 162E control device.  Accompanying this e‐mail submittal is a pdf file

of the Test Report, Potline Roof Monitor and Scrubber Stack POM Test Program, Alcoa Mt. Holly

Operations, Goose Creek, SC, March 28, 2012, Revised November 30, 2012. Prepared by TRC

Environmental Corporation, Raleigh, NC.  TRC Project No. 190195.

We appreciate the EPA’s timely review of the provided information as Alumax is planning to

conduct the remaining requested testing.  If you have any questions regarding the information provided,

please feel free to contact Larry McCaskill of my staff at (843) 572‐5246 or via e‐mail at

larry.mccaskill@alcoa.com.

Sincerely,

Henk J. van der Meyden, PG

Environmental Manager

Enclosure

cc.   Mike Rousseau (letter only) Laurie Shelby (letter only)

Mike Palazzolo (letter only) Larry McCaskill (letter only)

   
previous pom test report acceptance request to epa.docx 

   

Previous Test Report Acceptance Conditions as Applied to Alumax of South Carolina, Inc.’s Potline

Roof Monitor and Potline Primary Control Device POM Emissions Test Results

1. Testing was conducted within the past 3 years.

Response:  The testing was conducted over the period February 20‐24, 2012 and within the past

3 years.

2. The processes, emissions controls, and inputs have not changed substantially since the testing

was conducted.

Response: The aluminum reduction process has not changed.  The Potroom process cycle is the

same 48‐hrs as when the testing was conducted.  The operation of the dry alumina scrubbers has

not changed.  The minimum air flow parametric for each scrubber is still three fans operating at

465 amps each.  The minimum fresh alumina feed parametric for each scrubber is still seven tons

per hour.  The supplier of and specifications for the calcined petroleum coke used to form the

anodes and the alumina used to produce aluminum are the same as when the testing was

conducted.  

3. The current production rates are not greater than those when the testing was conducted

Response:  The average aluminum production rate for Potline 2 was 14.38 tons/hour in February

2012 when the Potline was tested.  This was within the range of the monthly average production

rates for all of 2012.  

4. The air pollutants tested are the pollutants of interest in this testing program.

Response:  The pollutant tested was polycyclic organic matter (POM) which is one of the

pollutants of interest in the testing program requested under the ICR.  PM emissions were

determined in conjunction with the Method 315 POM testing.

5. The test methods used are the same or equivalent to the test methods required in this testing

program.

Response:  The test methods used for the POM testing program were EPA Method 1, EPA

Method 2, EPA Method 3, EPA Method 4, and EPA Method 315.  These are the same methods as

the test methods stipulated in the information collection request.  As shown in Tables 7‐1 and 7‐2

of the test report, the smallest sample volume collected for a single run was 311.444 dscf (or

8.820 dscm).   This exceeds the minimum sample volume of 3 dscm specified in Table 1.1 of the

ICR.

As requested on page 4 of Enclosure 1 to the ICR, the following additional information is provided on the

tested emission source.

Source Potline II

Average rate of aluminum production

(tons/hr)  

14.35 tons / hr (2012)

Number of Pots 180

Aluminum production capacity

(tons/yr)

128,075

Installation date June 16, 1980

Date of most recent startup September 30, 1989
previous pom test report acceptance request to epa.docx 

Layout of Alumax facility with the tested sources Potline Scrubber 162E (04) and associated Potroom

roof monitor (04A) shown.  Note that 04A is shown at the center of the 103E and 104E roof monitors.

   
previous pom test report acceptance request to epa.docx 

Table 4 Combination Dry Alumina Scrubber/Bag House Description

1. Control device description: Potline Scrubber 162 East (Source 04, Equipment ID 53004)

2. Stack or vent location of control device (use NAD83 and include six decimal places): 

ID No.: 04 Latitude: 33.053110 Longitude: -80.054276

3. Design collection efficiency and outlet concentration (add rows as necessary): 

Pollutant Collection Outlet Source of 

 efficiency * concentration Estimation * 

 (if known) 

PM Percent 0.0146 mg/dscf ____1___ 

POM Percent 0.0251 mg/dscf ____1___ 

Particulate Fluorides Percent 0.0012 mg/dscf ____1___ 

Hydrogen Fluorides Percent 0.0017 mg/dscf ____1___ 

* 1 = Performance testing 2 = Engineering judgment 3 = Manufacturer specs. 

 4 = Title V permit application 5 = Other (specify) _______________________ 

4. Scrubber device type: 

_____ Fluidized bed __X__ Injection 

_____ Other (specify or describe): _________________________________________ 

5. Bag cleaning method: 

_____ Pulse jet _____ Reverse air __X__ Shaker 

_____ Other (describe) _________________________________________________ 

6. Pressure mode of operation: positive pressure X negative pressure 

7. Typical gas temperature: inlet to scrubber 250 °F outlet from bag house 210 °F 

8. Gas flow rate: 353,901 acfm (at bag house outlet) 280,563 dscfm 

9. Pressure drop: Across scrubber: 7.6 inches water column (in. H2O) 

Across bag house: 7.6 inches water column (in. H2O) 
previous pom test report acceptance request to epa.docx 

10. Solid to gas ratio: 1.05 lb/1,000 acf 

11. Alumina usage rate (differentiate between virgin and recycled alumina from potlines) 

Type of Alumina Added Usage rate Units for usage rate 

Virgin alumina 11 Tons/hour 

Recycled alumina 68 Tons/hour 

Other alumina (specify ________________) 

12. Identify each emission source served by this control device (add rows as necessary). 

Source ID No(s). Description(s)

40103 Potline 2 – Rooms 103 East and 104 East Ridge Vents 

13. Indicate what operational parameters of the control device are monitored to ensure that the 

control device is operating properly: 

 Volumetric flow rate X Fan amperage 

 Pressure drop X Visible emissions opacity 

Other (specify): Fresh alumina feed rate 

14. What level of a monitored operational parameter triggers corrective action? 

 Volumetric flow rate (acfm) <465 Fan amperage (amps) 

 Pressure drop (in. H2O) Any Visible emissions opacity (%) 

Other (specify): < 7 tons/hour Fresh Alumina Feed 

15. Additional comments and information: