### 1

From: Putney, David
Sent: Thursday, April 18, 2013 1:20 PM
To: Coomes, Jamie
Cc: McKenzie, Craig; Lane, Sean; Garwood, Gerri Subject: RE: Century PM test data



### Jamie,

Thanks so much for the test data from previous PM e missions tests conducted on the bake furnace and potlines at the Century Aluminum of KY facility. We have reviewed t hese tests and respond with the following:

• Anode Bake Furnace: The PM tests on the bake furnace are acceptable an d fulfill the requirements of the testing ICR for that source.

• Potline Primary: Although the PM tests at the potline primary exhau st had sample sizes of less than the required minimum of 4 dscm, it appears that you were able to obtain enough filterable particulate matter to generate a reliable PM emission rate esti mate. Therefore, the PM data are deemed acceptable and fulfill the requirements of the test ing ICR for the potline primary emissions. Note, however, that the testing ICR also requires testing of a potline at your facility for metal HAP. This metal HAP testing will provide another set of PM data whi ch would be useful in the ongoing risk assessment associated with the primary aluminum sector. Theref ore, please submit both the PM and metal HAP data from the upcoming primary potline metal HAP em issions testing.

• Potline Secondary: The PM emissions at the potline secondary exhaust were obtained via Method 5. In order to maintain consistency of secondary potli ne emissions data between facilities with manifolds and facilities that utilize cassettes, the testing ICR requires use of Method 17 (see item 7 in the FA Q document on the testing ICR website at https://icr2010.rti.org/Industries/PrimaryAluminum/ FrequentlyAskedQuestions.aspx and attached to this message). Therefore, this PM test data does no t fulfill the requirements of the testing ICR for t he potline secondary emissions. 

### 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

### 2

From: Coomes, Jamie [ mailto:JCoomes@centuryky.com ]
Sent: Wednesday, March 13, 2013 4:06 PM
To: Putney, David
Cc: McKenzie, Craig; Lane, Sean; Coomes, Jamie Subject: Century PM test data



### David,

In order to meet the required March 22, 2013 deadli ne , attached is test data from previous emissions tests for PM from the Anode Bake Scrubber, CWPB3 Potline roof an d stack. We are submitting this data in lieu of addi tional PM testing as requested in the ICR. We are current ly testing the potline stack and roof for HAP metals a nd POM. We will be submitting these test results in t he coming weeks.

If you need any additional information please let m e know.

Thanks

Jamie Coomes Senior Environmental Engineer 

## Century ALUMINUM

1627 St. Rt. 271 North Hawesville, KY 42348

Office: 270-852-2818

Cell: 270-231-3813

Fax: 270-852-2883

### Primary Aluminum 2013 ICR
Frequently Asked Questions

1. Is there any flexibility associated with the requirement , in Section 4.0 of Enclosure 1, that a facility notify their regulatory agency of associated testing 60 days prior to the testing?
Yes. The subject text includes the caveat that an alternative date is acceptable provided that it is approved by th e appropriate associated regulatory agency

. 2. Is a quartz fiber filter acceptable for conducting EPA Method 315 sampling?
You may use glass or quartz fiber filters while conducting EPA Method 315 sampling , as long as the filter meets the other requirements of Section 7.1.1 of EPA Method 315

. 3. The EPA Method 14A cassettes that are used by industry to sample secondary potline em issions (i.e., for those potlines that are not equipped with manifolds) will not accommodate a standard
EPA Method 315 filter. Is it acceptable to modify the filter to fit into the cassette?

Y es. We realize that the standard EPA Method 315 filter may not fit into the EPA Method 14A

cassette

. You may cut th e filter to fit the cassette. Please keep in mind that the filter should be weighed after cutting and prior to insertion into the cassette.

4. How can the tester use EPA Method 315 to sample with an EPA Method 14A cassette?
The tester should use a filter meeting the requirements of EPA Method 315 and analyze the results using EPA Method 315. The filter should be set up in the EPA Method 14A cassette (cutting to fit

, if necessary) for the sample.

5. EPA Method 315 involves analyzing a sample for both polycyclic organic matter (POM) and total filterable particulate matter (PM). Is PM data obtained from the EPA Method 315 test acceptable in lieu of data obtained from a n EPA Method 5 test in cases where a facility is required to test a source for POM and PM?

Y es, y ou may use the total filterable PM data from EPA Method 315 in these cases.

6. Will the EPA allow the use of EPA Method 306 to determine em issions of hexavalent chromium, as opposed to SW

- 846 Method 0061 as specified in the draft ICR ?
The EPA will consider this only if you have empirical data for your facility showing that EPA Method 306 does not convert the hexavalent chromium during sampl ing. Measuring hexavalent chromium accurately is diffic ult because it can convert to other forms of chromium in the sample train. That is the primary reason why SW

- 846 Method 0061 was developed. SW

- 846 Method 0061 has procedures in place, which EPA Method 306 does not have, to ensure that hexavalent chromium i s not converted during sampling.

7. The testing ICR specifies use of EPA Methods 17 and 29 for secondary potline emissions of PM and metal HAP and EPA Methods 17 and 315 for secondary potline emissions of PM and POM from facilities equipped with manifold systems (see Table 1.2) . Is this accurate? Does the tester need to use both an in

- stack and out of stack filter?
In order to maintain consistency of emissions data between facilities with permanently installed manifold systems and those that utilize roof cassettes, we have required the use of EPA Method 17 , in lieu of EPA Method 5, with EPA Method s 29 and 315

. The ca ssettes will be sampled at ambient , or near ambient, conditions and cannot be temperature controlled to the 248°F (±25°F) required by EPA Method s 5 , 29, and 315. Therefore, we are requesting that the manifolds also be sampled at ambient conditions

. However , it was not our intent to require an in

- stack filter inaddition to the EPA Method 29 or 315 filter. Our intent was only to require the ambient sam pling

procedures of EPA Method 17, i.e. the probe and filter holder should not be heated.

8. For sources located i n arid climates, how can the tester deal with the loss of impinger solutions from the EPA Method 29 train?

If a facility is located in an arid climate, and evaporation of impinger solution is known to be a major issue, you may add a third nitric a cid/hydrogen p eroxide impinger to the train. However, this should only be done in extreme cases and must be fully documented in the test report

.

9. Those primary aluminum reduction facilities which are currently required to demonstrate compliance with a polyc yclic organic matter (POM) standard in 40 CFR Part 63, Subpart LL (i.e., the NESHAP for primary aluminum reduction facilities) are prohibited from including emissions data collected during the installation and startup of a cathode in that demonstration (re fer to 40 CFR §63.847(e)(2)). Does that prohibition against including emissions data collected during the installation and startup of a cathode apply to POM sampling associated with the testing ICR dated March 4, 2013?
Yes. For purposes of the testing ICR dated March 4, 2013, you should avoid collecting POM
emissions data during the installation and startup of a cathode.

10. Does the information submitted by a primary aluminum reduction facility in response to the testing ICR need to be certified?

Yes. The EPA believes it appropriate for a responsible official to certify the data submittal for this effort just as they do for other data submittals required by various permitting agencies. It is one way that we can ensure that the data have been gathered fa ithfully and responsibly and lessens the chances that inaccurate data will be provided. It is up to the company submitting the ICR data to determine the appropriate official to sign and date the statement s shown below : Permitted Facility Representative

Name: Signature:

Title: Company: Date Signed:
Based on information and belief formed after reasonable inquiry, I certify that the statements and information in this test report are true, accurate, and complete.

Testing Company

Name: Signature:

Title: Company: Date Signed:
I have reviewed all testing details and results in this test report and hereby certify that the test report is accurate and correct.