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 respons e 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@c enturyky.com; kisnerj@noralnm.c om; 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 alum inum operations conducted at your facility. The inform ation 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 fo llow-up questions concerning pitch storage tanks:

1. The ICR did not directly ask whethe r 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 Su bpart 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 info rmation on Table(s) 1 through 5 found in the ICR for the

associated control device(s), if applicable]? The Wenatchee pitch tanks were installe d in 1992. This installation date
is prior to the September 1 996 Primary Aluminum MACT ru le 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 Pa g e 1 of 2

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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 “M ACT floor” for “New Pitch
Storage Tanks” under the prop osed 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, th at the ICR may not have been clear in regards to submitting informati on on any controls that may be in stalled on existing pitch storage tanks at your facility that are subject to Subpart LL. If you have any existing pitch stor age tanks at your fa cility 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 wi th the remaining da ta that was not
available on May 31.

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

busy days to provid e 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 Pa g e 2 of 2

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...