### 1

From: "Robert Strieter" <bstriete@aluminum.org> To: Donnalee Jones/RTP/USEPA/US@EPA Cc: Rochelle Boyd/RTP/USEPA/US@EPA, "mikepalazzolo" <michael.palazzolo@alcoa.com>, <jperdion@bakerlaw.com> Date: 02/18/2010 01:12 PM Subject: RE: recommendations for the draft list of SSM work practices



### Donna:

Attached for your review and consideration is our compilation of recommendations (in track changes/red

line format) to revise the draft list of PMACT SSM work practices that we received in December. We appreciate the opportunity to review the list and will be happ y to meet with you and your colleagues to further discuss the recommendations we have provided.

Regards, Bob

Bob Strieter VP

- EHS The Aluminum Association bstriete@aluminum.org 703 358

- 2980 cell 571 224

- 6598

1525 Wilson Blvd Suite 600 Arlington, VA 22209

----- Original Message

----- From: Jones.Donnalee@epamail.epa.gov [ mailto:Jones.Donnalee@epamail.epa.gov ] Sent: Friday, December 11, 2009 1:37 PM To: Robert Strieter Cc: boyd.Rochelle@epa.go v Subject: draft list of SSM work practices; article and calcs to estimate fluoride from start

- up

Bob

- I appreciate the call this a.m. Here are the items I talked about on the phone with you.

(1) A Word file (draft

- list of WP's) which is the beginn ing of my list of potential work practices that Ive accumulated from a couple of industry sources. As I explained on the phone, Id like to get a full list of all the possibilities, i.e., any work practice that any facility is using, so that we can turn it into a "check the box" form to be distributed to the entire industry. In order to add start

- up operations to the NESHAP we need to do a "MACT floor" which means first finding out whats being done by everyone in the industry, if at all possible. We'd like to sene the survey out by the end of January, so the sooner as you can get this back to me the better. The facilities can send their comments directly to me or you can collect them and send them all at once. At this point, we dont need to know who is doi ng each work practice.

(2) The other files pertain to the theoretical procedure that was presented to EPA for estimating start

- up emissions in terms of lb/pot

- day fluoride emissions. Ive put all the files in one pdf for easy email distribution and then also attached the actual spreadsheets. I, myself, find it informative to see how each calculation is done, which is a feature of Excel (press F2 on any number to see all the terms involved the calculation). I would be interested to know if anyone had any comments on this method or had another

### 2

method of estimating F emissions. Also, the article says (pg 7) that the equations were only checked against emission data from one cell, so it would be good to find out if there have been any other checks done.

Have a good holiday if I dont speak to you before then. Ill be here most of the time with a few days/hours off here and there.

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ Regards, Donna Lee Jones, Ph .D. U. S. Environmental Protection Agency Office of Air Quality Planning and Standards Sector Policies and Programs Division / Metals & Minerals Group (D243

- 02) Research Triangle Park, NC 27711 Tele: (919) 541

- 5251 Fax (919) 541

- 3207

~~~~~~~~~~~~~~~~~~~~~ ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~draft

- List of SSM

- WPs

- Primary

- Aluminum

- 02

- 18

- 10 edits1.doc draft

- List of SSM

- WPs

- Primary

Aluminum

- 12

- 1 8 1

- 09.doc Page 1 of 4

December 11, 2009

Draft l ist of Potential SSM Work Practices for Primary Aluminum Facilities PLEASE ADD TO OR REVISE and return to EPA ( jones.donnalee@epa.gov )

Potroom/potline Start

- up

 Develop a potroom/potline start

- up schedule before start

- up, t hat o include s :

o Sufficient flexibility to restart potline in an orderly and controlled manner

o Target number of cells to be re start ed per week

o Daily assessment of startup progress and any necessary schedule changes Schedule for d ai ly start

- up review

o R ecord keeping procedure f or actual number of pots started per day Documentation procedures for start

- up cell information

 Bring corresponding potroom/potline scrubbers on line prior to energizing first cell to be

re started up

o To the exte nt practicable S s upply alumina at a rate to adequately scrub potentially higher concentration pot gases than during normal pot operation

o Respond to any s S crubber malfunction s according to the facility’s written SSM Plan plan during start

- up is .......

 Determin e and maintain minimum air flows to energized pots to ensure fluoride capture per cell that are needed for proper operation during potroom/potline start

- up

 Keep pots covered and vented to primary capture and control system as much as practicable during sta rt

- up, and limit removal of covers or panels to only those pots being worked on at any given time

. the number of pots that can be open at any given time to no more than ( fill in the blank) open pots

.

 Keep the primary capture and control system on an d operating at all times during the startup.

 Limit the number of pots that can be re

- started on a single day to no more than _____ (fill in the blank) pots. Delete

- number of pots restarted would be addressed in schedule discussed above.

Bla n k off affe cted ducts in the potline start

- up section prior to start

- up except for the few pots that will be initially started. Delete

- this approach is not appropriate for all primary control system designs. The need to ensure adequate flow would instead is addre ssed by maintain ing minimum air flows per cell as required above.

 If air draft settings are available, place pots on high draft during addition of bath to a new pot or during pot startup. at bath up

. and let these remain on high draft until the pots are sufficiently stable and cr

u st is well sealed.

 Monitor pot lines frequently during start

- up to identify “sic k” pots that need attention and initiate countermeasures that need to be replaced

.

 Procedures for attending to sick or unstable pot during start

- u p may include :

o Adjust cell voltage and feeding

. o Monitor and adjust anode current and liquid level

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- List of SSM

- WPs

- Primary

- Aluminum

- 02

- 18

- 10 edits1.doc draft

- List of SSM

- WPs

- Primary

Aluminum

- 12

- 1 8 1

- 09.doc Page 2 of 4

December 11, 2009

o Reduce temperature by adding solid or liquid bath or metal

. Delete

- This is same thing as “adjust liquid level” in bullet above.

o Resea l pot crust if needed to reduce emissions

. Delete

– Adding anode cover or otherwise trying seal m a ke things worse depending on the problem (e.g., hot pot).

 Shielding procedures during start

- up: Delete

- Not applicable as shielding procedures unchanged for startup

 Anode setting , and anode and butt delivery/transport procedures during start

- up: Delete

- Not applicable as procedures are unchanged for startup

 Potline react or procedures during start

- up

– Delete

– potline scrubber operation is already addressed above

 Tapping procedures during start

- up Delete

- Not applicable as procedures are unchanged for startup

 Procedures for cutting out a pot during start

- up Delete

- Not applicable as procedures are unchanged for startup

Anode Bake Furnace Start

- up
Work practices ar e not re levant for startup of anode bake furnaces as startup does not cause excess emission compared to normal operation MACT limits . Emission control device must be operating prior to anode furnace startup to remove combustible materials from the furnace

.

 Startup procedures for anode bake furnace:

 Start

- up for emission capture and control systems on anode bake furnace

o Prior to start

- up of anode bake furnaces is essential to remove combustible materials from the furnace

o After initial start

- up of anod e bake furnaces

 Operation of anode bake furnace to ensure proper furnace combustions conditions during first

_________ (fill in the blank) days/weeks of start

- up

Paste Production Plants

Work practices are not relevant for startup of paste plant becaus e startup does not cause excess emission compared to MACT requirements . Emission control device must be operating prior to paste plant startup as MACT and SSM Plan already require control device to be operat ing

.

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- List of SSM

- WPs

- Primary

- Aluminum

- 02

- 18

- 10 edits1.doc draft

- List of SSM

- WPs

- Primary

Aluminum

- 12

- 1 8 1

- 09.doc Page 3 of 4

December 11, 2009  Start

- up for emission capture and control systems on paste production plants

o Prior to start

- up

o After initial start

- up

 Xx

 xx

 Operation of paste production plants to ensure proper conditions during first

_________ (fill in the blank) days/weeks of start

- up

Pitch Storage Tanks

Work practices are not relevant for startup of pitch storage tanks

– these tanks are operational at all times because they contain pitch all the time. If the tank were emptied for some reason, “startup” would be identical to a normal loading activity where more pitch is added to the tank.

 Startup procedures for pitch storage tanks

o Xx

o Xx

 Start

- up for emissions control systems on pitch storage tanks

o Prior to start

- up

 Xx

 xx

o After initial start

- up

 Xx

 xx

 Operation of pitch s torage tanks to ensure proper conditions during first

_________ (fill in the blank) days/weeks of start

- up:

o Xx

o Xx

Shutdown Procedures

Only “work practice” applicable is to follow written SSM Plan, which requires operation of emission control device until shutdown is complete

.

 Potroom/potlines

o X x

o xx

 Anode Bake Furnace

o X x

o xx

 Paste Plants Formatted: Font: Not Bold, No underline

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- List of SSM

- WPs

- Primary

- Aluminum

- 02

- 18

- 10 edits1.doc draft

- List of SSM

- WPs

- Primary

Aluminum

- 12

- 1 8 1

- 09.doc Page 4 of 4

December 11, 2009

o Xx

o xx

 Pitch Storage Tanks

o X x

o xx

Malfunction Procedures

Only “work practice” applicable is to r espond to any malfunctions according to the facility’s written SSM Plan

 Potroom/potlines

 Anode Bake Furnace

 Paste Plants

 Pitch Storage Tanks Formatted: Font: Italic

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