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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, G erri Subject: Alcoa-Massena East test data

Mr. Rufa,

Thanks so much for providing the test data from pre vious 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 alum inum. Therefore, the PM data are deemed acceptable and fulfill the PM requirements of the t esting 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 requi res 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 meta l HAP emissions data) which would be useful in the ongoing risk assessment associated with the pri mary 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 emissio ns testing.

2. Potline Secondary: The PM emissions at the potline secondary exhaust were obtained via Method 5 whereas the primary aluminum testing ICR requires u se of Method 17 for this testing. Therefore, this PM test data does not fulfill the requirements of t he testing ICR for the potline secondary emissions. Note again that the testing ICR also requires testi ng of potline secondary emissions from your facilit y for metal HAP by Method 29 which will provide the r equired PM data, if the optional steps referenced in item 1, above, are performed.

3. Other Required Data: It appears that no emissions calculations were sub mitted (at least I could not find any). Please provide the emissions calculatio ns (or at least example emissions calculations). I will also need the applicable data requested on page 4 o f 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 a nd 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 req uire a report of any pollution prevention or other hazardous air pollutant emissio n reduction approaches being implemented during the test program, and emissions source and c ontrol device operating or monitoring parameter information taken at the time of the emis sions test. That is, you must fill out Tables 3 through 7, below, as appropriate, with the applicab le 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 h our or Megagrams per Hour) during the emissions testing of a potline. For the tested potline you must also report the number of2



### pots, the aluminum production capacity (tons per ho ur or Megagrams per hour), the
installation date and the date of the most recent s tartup;

• 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 pers onnel to verify normal operation of potlines, anode bake furnaces and/or paste plants d uring 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