From:                              Putney.David@epamail.epa.gov

Sent:                               Monday, June 27, 2011 2:38 PM

To:                                   Bahner, Mark A.; Green, David A.

Subject:                          Fw: Follow up on pitch storage tanks at PAL facilities

 

Mark/David - a pitch storage tank response to my associated follow-up question. 

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 

----- Forwarded by David Putney/RTP/USEPA/US on 06/27/2011 02:37 PM ----- 

 

Please see answers below, and let me know if you have further questions. 

 

Thanks, 

David Hulse 

Alcoa Inc. – Wenatchee Works 

 

From: Putney.David@epamail.epa.gov [mailto:Putney.David@epamail.epa.gov] 

Sent: Wednesday, June 22, 2011 3:01 PM

To: Palazzolo, Michael A.; ksands@centuryky.com; kisnerj@noralnm.com; jvanmatre@centurywv.com; 

danny.carroll@riotinto.com; kisnerj@noralnm.com; John.Reggi@ormet.com; Van Der Meyden, Henk; Mitchell, 

Kathryn M; Bilskis, Patricia A.; Rufa, Nathan P.; Blodgett, Terry L.; Allen, Chris; Hulse, David G.

Cc: cjohnson@aluminum.org; bahner@rti.org

Subject: Follow up on pitch storage tanks at PAL facilities 

 

Hello all, 

Thank you so much for taking the time to respond to the information collection request (ICR) dated April 25, 2011 

concerning the primary aluminum operations conducted at your facility. The information you provided will be 

instrumental in the ongoing associated residual risk/technology review. I have been going through the ICR 

responses I received and have a couple of follow-up questions concerning pitch storage tanks: 

1. The ICR did not directly ask whether or not your facility utilizes any new pitch storage tanks (i.e. tanks 

installed after the proposal of 40 CFR Part 63, Subpart LL on 09/26/96)? Do you have any new pitch storage tanks 

that are subject to Subpart LL at your facility? If so, what controls do you use to meet the 95% POM reduction 

requirement in 40 CFR §63.844(d) [please submit this information on Table(s) 1 through 5 found in the ICR for the 

associated control device(s), if applicable]? 

                                The Wenatchee pitch tanks were installed in 1992. This installation date 

is prior to the September 1996 Primary Aluminum MACT rule proposal, so the pitch 

From: "Hulse, David G." <David.Hulse@alcoa.com> 

To: David Putney/RTP/USEPA/US@EPA 

Cc: "Palazzolo, Michael A." <Michael.Palazzolo@alcoa.com> 

Date: 06/23/2011 12:33 PM 

Subject: RE: Follow up on pitch storage tanks at PAL facilities

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tanks are actually an “existing source”. However, these tanks have a control device 

that gets 95% POM removal and thus represented the “MACT floor” for “New Pitch 

Storage Tanks” under the proposed and final MACT rules. That is why the standard 

for new pitch tanks is 95% control. 

2. It appears, based on the ICR responses I received, that the ICR may not have been clear in regards to 

submitting information on any controls that may be installed on existing pitch storage tanks at your facility that are 

subject to Subpart LL. If you have any existing pitch storage tanks at your facility that are subject to Subpart LL and 

that have emissions controls installed on them (even though those controls are not required under Subpart LL) 

please provide the information necessary to evaluate those controls [i.e. submit Table(s) 1 through 5 found in the 

ICR for the associated control device(s), if applicable]. 

Table 5 was filled out for the Liquid Pitch Scrubber system and was included with the 

submission that was mailed yesterday with the remaining data that was not 

available on May 31. 

I am sorry for the need for this follow-up email. Your time is valuable and I appreciate you taking time out of your 

busy days to provide this information. 

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 

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