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From: Putney, David 

Sent: Tuesday, December 24, 2013 10:48 AM 

To: Don Backfisch 

Subject: FW: Draft emissions file for the Noranda primary aluminum facility 

Hello Don, 

Several industry contacts have reached out to me for 

clarification regarding my request for review of the draft 

emissions files as my initial email was evidently a bit 

confusing (I can see how it would be). So I am sending this 

follow up email out to (hopefully) clarify my request 

somewhat. Please do not overestimate what I am looking for 

in response to my initial email. It really should not take 

too long to respond to my email. 

Several contacts have requested information on the 

production capacities used for the primary aluminum

facilities and are concerned about estimating CY2013 

emissions since production for CY2013 has not yet ceased. 

In the development of the emissions estimates in the files 

I sent out initially we used the production capacities 

found in Table 2 of the attached document. However, I am 

not expecting industry to do any emissions calculations at 

this point that would require capacity information. Also, 

the portion of the spreadsheet that shows CY2013 is

misleading – we understand that you do not have production 

data for all of CY2013 at this point. I believe the current 

year is used simply to show that it is a recent risk 

analysis and that the facility was operating in 2013. 

Please do not try to correct the spreadsheets to reflect 

your CY2013 production. 

We feel fairly confident in the source category emissions 

and locations of emissions sources since we got industry 

test data to estimate emissions and industry review of 

locations in the previous (initial) proposal. Although, if 

something jumps out at you as being obviously incorrect in 

the source category tab of the spreadsheets then you are 

welcome to bring it to my attention. 
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The main thing I am requesting is for industry to review 

the non source category tab of the spreadsheets so as to 

ensure we are not including emissions in the risk modeling 

that should not be included (e.g., for a boiler that no 

longer exists), and not double counting the emissions that 

should be included (e.g., emissions that are part of 

collocated secondary aluminum operations). We got the non 

category information from the National Emission Inventory 

(NEI) databases and other state input. As you can imagine 

there is quite a bit of variation between how the various 

states put data in the NEI and how they refer to the 

associated emissions sources. I’m hoping that you could 

tell by the location, pollutants and magnitude of emissions 

what is the referenced source. Then, we will include or 

remove the associated emissions in the risk model as 

appropriate. 

Thanks again, 

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 

From: Putney, David 

Sent: Wednesday, December 18, 2013 9:35 AM 

To: Don Backfisch 

Subject: Draft emissions file for the Noranda primary aluminum facility 

Hello Don, 

Please find attached to this message a draft emissions file 

(Excel spreadsheet) for the Noranda primary aluminum 

production facility. Columns highlighted in yellow are 

available for revisions or to indicate if records should be 

deleted. Please do not overwrite the data in columns that 
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are not highlighted in yellow as this would complicate the 

development of the final emissions file for use in risk 

modeling. 

The tab titled “primary Al category” includes emissions 

from the primary aluminum production operations (e.g., 

potlines, paste plants, pitch storage tanks, and anode bake 

furnaces) at the Noranda facility as estimated via emission 

factors developed from test results obtained in response to 

the testing ICR sent out in April of 2013. I expect that 

the stack parameters are correct as-is since industry 

previously had opportunity to review those items in CY2010 

before the initial residual risk and technology review 

(RTR) proposal for the primary aluminum production source 

category. There are, however, some emissions (e.g., metal 

HAP, dioxins, PCB, etc.) that are new to the RTR analysis 

for the primary aluminum production source category and, 

although these have been QA/QC’d by contractor and EPA 

staff, we do welcome feedback/corrections you might have on 

these emissions. A revision column highlighted in yellow 

is provided for you to revise emissions (in units of tons 

per year, tpy) if needed. 

The tab titled “noncategory” includes 2005 NATA NEI, 2008 

NEI and 2010 state HAP data for the Noranda primary

aluminum production facility. These records are intended to 

include emissions from operations at your facility which 

are not directly associated with primary aluminum 

production (primary aluminum emissions are addressed under 

the first tab, discussed above) or secondary aluminum 

production (secondary aluminum emissions will be addressed 

via the RTR associated with the secondary aluminum source 

category). Revision columns highlighted in yellow are 

included for emissions, pollutants, stack parameters, 

fugitive parameters and latitude/longitude. If any of these 

parameters needs modification, please put the corrected 

value in the associated revision column (again, please do 

not overwrite the data in columns that are not highlighted 

in yellow). Note that fields were also added to identify 

if a record should be deleted, and a reviewer comment field 
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where you can add a comment if appropriate. Please review 

these data with the following in mind: 

1. Should the operation be included in the spreadsheet? 

a. Does the operation still exist at the facility? If not, or if it exists but is not legally allowed to 

operate (e.g., you do not have a valid operating permit for this operation) then the operation 

and associated emissions need not be included. 

b. If the operation does exist at the facility, is it part of any secondary aluminum operations that 

may exist at your facility? If so, then the operation and associated emissions need not be 

included (so as to avoid double counting those emissions). 

c. If the operation does exist at the facility, would the emissions from this operation be 

considered part of the monitored primary aluminum emissions? For example, if the emissions 

associated with the operation in question are routed through the control device associated 

with the paste plant and would be monitored as part of the paste plant emissions then the 

operation and associated emissions need not be included (so as to avoid double counting 

those emissions). 

2. If the operation should be included, are the cited emissions representative of that operation? 

3. If the operation should be included but the cited emissions are not representative of that operation,

then please provide representative annual actual emissions in units of tons emitted per year (tpy). 

4. Verify or modify the stack parameters and location as appropriate and necessary. 

Please provide any comments, changes, corrections, etc. to 

this file to me by close of business on Friday, 01/03/14. I 

understand that more time might be preferable with the 

holidays upon us, but please give me what you can by 

01/03/14 and remember that you will have another 

opportunity to make comments and corrections during the 

upcoming public notice and comment period associated with 

the primary aluminum production RTR supplemental proposal. 

If you have any questions concerning these issues, please 

feel free to contact me by email or telephone. 

Thanks, 

David Putney, Environmental Engineer 

U.S. Environmental Protection Agency 
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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