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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 l imits 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 Pe rmit 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 emissi ons 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 par t 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 maxi mum 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 “Methodolog y 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 conc entration 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 Cal Puff 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 T itle 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 one

time 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 c omments 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

- 53782

From: Da vid 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 informat ion 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

associ ated 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 l imits? 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)

tha t 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 produc tion 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