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From: "Van Der Meyden, Henk" <Henk.VanDerMeyden@alcoa.com>

To: David Putney/RTP/USEPA/US@EPA, "Palazzolo, Michael A." <Michael.Palazzolo@alcoa.com>

Date: 03/15/2012 08:13 AM

Subject: RE: Metal HAP limits in Title V permit for Alumax of SC

________________________________________

David, 

In response to your request, I want to clarify that the metals emission rates that you refer to are NOT 

emission limits and they are NOT included in the Title V Permit for Alumax of South Carolina. They are 

modeled emission rates contained in an Attachment to the Title V Permit. Regarding your specific 

questions, I offer the following: 

The source(s) of the metal HAP emissions referenced above; 

The metal HAP emissions are mostly from Primary aluminum production operations (primarily from 

Potlines and some from Anode Baking), with much smaller amounts from Secondary aluminum 

production operations and combustion sources (all NG-fired). The metal HAP emissions from the

Primary aluminum production operations are mostly related to the reacted alumina from the dry scrubbers 

used to control the fluoride emissions. Previously, we had submitted information on the HAP metals 

content in the reacted alumina baghouse catch as part of an Information Collection Request dated 

04/25/2011. 

The source of the associated emission limits cited in the Title V permit for the Alumax facility; and 

The metal emission rates were estimated in the early 1990’s to demonstrate compliance with maximum 

allowable ambient concentrations under SC Regulation 61-62.5 Standard No. 8 – Toxic Air Pollutants 

(“Standard 8”). This was done by conducting short-duration engineering tests on the outlets of various 

emission sources using EPA Method 0012 “Methodology for the Determination of Metals Emissions in 

Exhaust Gases from Hazardous Waste Incineration and Similar Combustion Processes.” The emission 

rates and stack parameters were used in a Screen air dispersion modeling effort to determine maximum 

ambient concentration beyond the fence line and compared to the maximum allowable concentration 

under Standard 8). The results were originally submitted as a permit application to SC DHEC in 

November 1994. The metal emission rates were adjusted and remodeled using CalPuff in conjunction 

with a major source construction permit in 2002. The results showed continued compliance with the 

Standard 8 maximum allowable concentrations. The 2002 modeled emission rates were included in 

Attachment A of Alumax of South Carolina’s Title V Operating Permit in January 2003. 

The method of demonstrating compliance with those metal HAP emission limits.

It is my understanding that compliance with the Standard 8 allowable concentrations is in essence a onetime demonstration unless there is a change in the modeling input parameters that would require 

remodeling, or SC DHEC determines that a facility is or may be contributing to an exceedance of 

Standard. There are no ongoing compliance demonstration requirements for the metal HAP emissions 

contained in the permit. Again, the emission rates are not limits and they are outside of the permit.

If you have any comments or questions concerning the information provided please feel free to contact 

me or Mike Palazzolo.

Sincerely,

Henk van der Meyden, PG

Environmental Manager

Alcoa - Mt. Holly

Office: (843) 572-5361

Cell: (843) 296-3359

Fax: (843) 572-5378
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From: David Putney [mailto:Putney.David@epamail.epa.gov] 

Sent: Sunday, March 11, 2012 4:24 PM

To: Van Der Meyden, Henk; Palazzolo, Michael A.

Subject: Metal HAP limits in Title V permit for Alumax of SC

Henk/Mike,

The purpose of this email is to solicit information that will better inform my response to certain comments 

received on the proposed Residual risk and Technology (RTR) review amendments to the primary 

aluminum reduction plant NESHAP. Specifically, some commenters asserted that the risk assessment 

associated with the referenced proposal should have included assessments of risk from the metal HAP 

that have emission limits in the Title V permit issued to the facility operated by Alumax of SC (i.e., 

chromium, cadmium, arsenic, lead, manganese, nickel).

So, I am specifically soliciting information on the emission limits in the Title V permit issued to the 

Alumax facility for those metal HAP listed above. That is, what is the basis for calculating those limits 

and how do you demonstrate compliance with those limits? For example, those limits may have been 

generated via theoretical calculations based on testing of the alumina or the bauxite ore and assuming 

100% emission of the contaminants. Or, maybe the limits are based on stack testing (perhaps Method 29) 

that were conducted at the Alumax facility? Do you demonstrate compliance with those limits via stack 

testing, via theoretical calculations based on throughput, or some other method? If by stack testing, then 

what test method is utilized?

Also, regardless of the basis of the permit limits and the method of demonstration of compliance, what are 

the expected sources of those metal HAP emissions? That is, are these metal HAP emissions from the 

primary aluminum production operations, the secondary aluminum production operations, combustion 

sources (e.g., fuel oil-fired boilers), some other (unlisted herein) sources, or some combination of those 

sources?

At your earliest convenience, please let me know: 

If you have any comments or questions concerning the requested information please feel free to contact 

me.

Thank you in advance for your assistance,

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