From: Van Der Meyden, Henk [mailto:Henk.VanDerMeyden@alcoa.com] 

Sent: Wednesday, April 22, 2015 10:04 PM

To: Putney, David;

Cc: Palazzolo, Michael A.; Hulse, David G.

Subject: Installation of Method 14 or 14A sampling equipment at Alcoa Wenatchee

This e-mail is to provide additional information regarding the installation of Method 14 or 

Method 14A sampling equipment at Alcoa’s Wenatchee facility. We had previously raised this 

issue in our written comments of February 05, 2015 and during our conference call on April 8, 

2015. As detailed below, we believe that the cost for installing Method 14 or Method 14A 

sampling equipment is cost prohibitive. We recommend that EPA pursue an alternative 

approach for measuring the contribution of roof monitor emissions from existing potlines which 

currently do not have Method 14 or Method 14A sampling equipment installed for determining 

compliance with the proposed emission limits for PM and POM.

Background

Alcoa’s Wenatchee facility has four potlines. Potlines 1, 2 and 3 have similar pot technology 

and primary control equipment. Potline 5 is different from Potlines 1-3. Potlines 1, 2 and 5 are 

operating while Potline 3 is currently curtailed. Potlines 1 and 5 use a Method 14 manifold for 

collecting samples to determine TF emissions from the roof monitors. Potline 2 uses the HF 

CEM approach for similar potlines as described in §63.848(d) of the current rule to determine 

the roof monitor TF emissions. The proposed rule would require testing of roof monitor 

emissions for PM and POM. To our knowledge, there are currently no CEMs for measuring PM 

or POM concentrations in long line sources like potline roof monitors. In order to comply with 

the proposed PM and POM limits, Alcoa Wenatchee would be required to install a Method 14 

or Method 14A sampling equipment in Potlines 2 and 3.

Cost Estimate

We contacted our facilities and obtained the following information on historic installations to 

estimate the cost of future installation of Method 14 or Method 14A sampling equipment.

1. Method 14 Manifold

In 2004, the Massena East smelter had to move an existing manifold from one potroom 

to another while the potline was shutdown. The actual cost just to move and reinstall 

the existing manifold in segments was $400K. This cost did not include moving the 

testing trailer or the manifold's downcomer fan and motor. Massena personnel 

estimate that to install a M14 system where it does not exist today be in excess of 

$500K, when considering engineering, materials, and utilities. Furthermore, installation 

of a Method 14 manifold in an operating potline brings logistical and safety challenges 

that add costs.

2. Method 14A Cassette System

In 2010, one of our Canadian smelters installed a radio-controlled track and trolley 
system to get the cassette and anemometer to sampling point in the roof monitor. The 

cost of this system was about $100K (CAN) per sampling point. We estimate that a 

sampling system comprised of the required minimum 8 sampling points for Method 14A 

will cost in excess of $800K when considering inflation and currency adjustments. A 

system using pulleys to move the cassettes to the roof monitor would be less expensive 

than the track and trolley system. While we have no actual installation costs, we believe 

that a pulley system would still be in excess of $500K. 

Based on the above, the cost impact to Alcoa Wenatchee for installing Method 14 or Method 

14A sampling equipment is estimated at $600K for Potline 2 alone or $1,200K total for both 

Potlines 2 and 3. We believe that this is excessive and that an alternative compliance approach 

is needed for existing potlines which currently do not have Method 14 or Method 14A sampling 

equipment installed.

Alternative Approach

Potlines 1, 2 and 3 at Alcoa Wenatchee are of similar design, use the same CWPB1 pot 

technology (T51 pot design), have similar building and roof monitor dimensions, and are 

controlled by similar primary control systems (fluidized bed alumina scrubbers). We had 

previously established that Potlines 1, 2 and 3 were “similar potlines” as defined in §63.848(d) 

of the current rule for the purpose of monitoring TF emissions. We believe that this similarity 

can extend to PM and POM emissions as well. Since Potline 3 is currently down, we focus the 

remainder of this discussion of an alternative approach on just Potline 2; however, it can be 

applied to Potline 3 as well. 

The anodes used in the Potlines 1 and 2 are of the same size and formulation and come from 

the same anode bake furnace. The work practices of changing anode, tapping molten 

aluminum, and adding alumina are the same in the operating potlines. There should be little 

difference in the evolution of PM and POM from Potline 1 and Potline 2. The use of an HF CEM 

and the emphasis on pot cover placement in proposed §63.854(a)(3) will ensure that the 

emissions capture efficiency in Potlines and 1 and 2 is similar.

We believe that an alternative approach for demonstrating compliance with the POM emissions 

limit for Alcoa Wenatchee’s Potline 2 should be based on the sum of the measured emissions of 

POM from the primary control device for Potline 2 plus the measured concentration of 

secondary emissions of POM from Potline 1 applied to the measured roof monitor air flow from 

Potline 2. An example calculation for POM is shown below. The same approach can be used 

for demonstrating compliance with the PM emission limit.

POM Line2 Total (lbs/ton) = [POM Line2 Total (lbs/day)] /[Production Line2 (tons Al/day)]

POM Line2 Total (lbs/day) = [POM Line2 monitor (lbs/day)] + [POM Line2 control device (lbs/day)]
POM Line2 control device (lbs/day) = tested value from annual compliance test

POM Line2 roof monitor (lbs/day) = [(POM Line1 roof monitor (mg/dscf)) x (Line 2 roof monitor flow (cf/min)) x (1440 

(min/day))] / [453600(mg/lb)] 

We appreciate the opportunity to provide this additional information. We are hopeful that 

these comments will help EPA develop and alternative approach for measuring secondary 

emissions of PM and POM at existing primary aluminum smelter potlines that currently do not 

have Method 14 or Method 14A sampling equipment installed. 

Should you require clarification or further discussion of our comments, please contact me or 

Mike Palazzolo.

Sincerely,

Henk van der Meyden, PG

Sr. Environmental Consultant

Alcoa Inc.

Cell: (843) 296-3359

henk.vandermeyden@alcoa.com