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From: Putney, David 

Sent: Friday, April 19, 2013 9:28 AM 

To: Nathan P. Rufa 

Cc: Jordan J. Parent; Michael A. Palazzolo; Garwood, Gerri 

Subject: Alcoa-Massena East test data 

Mr. Rufa, 

Thanks so much for providing the test data from previous PM emissions tests conducted on the potlines at the 

Alcoa-Massena East facility. I have reviewed these tests and respond with the following: 

1. Potline Primary: I noticed that the potline primary emissions data were provided in units of lb/hr 

whereas I need that data in units of lb/ton of aluminum. Therefore, the PM data are deemed 

acceptable and fulfill the PM requirements of the testing ICR for the potline primary emissions, 

provided that you submit the PM emissions in units of lb/ton of aluminum and the information cited in 

item 3, below. Note that the testing ICR also requires testing of potline primary emissions from your 

facility for metal HAP by Method 29. Method 29 will provide another set of PM data (a set of PM 

emissions data collected concurrently with the metal HAP emissions data) which would be useful in 

the ongoing risk assessment associated with the primary aluminum sector, if optional steps are 

performed as outlined in the test method. Therefore, please submit both the PM and metal HAP data 

from the upcoming primary potline metal HAP emissions testing. 

2. Potline Secondary: The PM emissions at the potline secondary exhaust were obtained via Method 5 

whereas the primary aluminum testing ICR requires use of Method 17 for this testing. Therefore, this 

PM test data does not fulfill the requirements of the testing ICR for the potline secondary emissions.

Note again that the testing ICR also requires testing of potline secondary emissions from your facility 

for metal HAP by Method 29 which will provide the required PM data, if the optional steps referenced 

in item 1, above, are performed. 

3. Other Required Data: It appears that no emissions calculations were submitted (at least I could not 

find any). Please provide the emissions calculations (or at least example emissions calculations). I will 

also need the applicable data requested on page 4 of 21 in Enclosure 1 of the testing ICR (repeated 

below in red text for convenience). If any of this information was included in the initial submittal and I 

simply overlooked it, please let me know and point it out to me. Otherwise, please submit this 

information at your earliest convenience. 

In addition to the emissions test data, we also require a report of any pollution 

prevention or other hazardous air pollutant emission reduction approaches being implemented 

during the test program, and emissions source and control device operating or monitoring 

parameter information taken at the time of the emissions test. That is, you must fill out Tables 3 

through 7, below, as appropriate, with the applicable data obtained during the emissions test of 

the associated emissions source. 

You must also provide a schematic of the emissions source being tested and the 

associated control device(s) along with a report of relevant emissions source and production 

data during the testing, including: 

• The average rate of aluminum production (tons per hour or Megagrams per Hour) during 

the emissions testing of a potline. For the tested potline you must also report the number of 
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pots, the aluminum production capacity (tons per hour or Megagrams per hour), the 

installation date and the date of the most recent startup; 

• The average rate of green anode processed (tons per hour or Megagrams per Hour) during 

the emissions testing of an anode bake furnace; 

• The average rate of green anode processed (tons per hour or Megagrams per Hour) during 

the emissions testing of a paste plant; and 

• Any other production data utilized by facility personnel to verify normal operation of 

potlines, anode bake furnaces and/or paste plants during the emissions testing of those 

emissions sources. 

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