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 emissions 

tests conducted on the bake furnace and potlines at the 

Century Aluminum of KY facility. We have reviewed these 

tests and respond with the following:

• Anode Bake Furnace: The PM tests on the bake furnace are acceptable and fulfill the requirements of 

the testing ICR for that source.

 

• Potline Primary: Although the PM tests at the potline primary exhaust 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 estimate. Therefore, the PM data are deemed 

acceptable and fulfill the requirements of the testing 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 which would be useful in the ongoing risk assessment 

associated with the primary aluminum sector. Therefore, please submit both the PM and metal HAP 

data from the upcoming primary potline metal HAP emissions testing. 

 

• Potline Secondary: The PM emissions at the potline secondary exhaust were obtained via Method 5. 

In order to maintain consistency of secondary potline emissions data between facilities with manifolds

and facilities that utilize cassettes, the testing ICR requires use of Method 17 (see item 7 in the FAQ 

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 not fulfill the requirements of the testing ICR for the 

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 deadline , 

attached is test data from previous emissions tests for PM 

from the Anode Bake Scrubber, CWPB3 Potline roof and 

stack. We are submitting this data in lieu of additional 

PM testing as requested in the ICR. We are currently 

testing the potline stack and roof for HAP metals and 

POM. We will be submitting these test results in the 

coming weeks. 

If you need any additional information please let me 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 the 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 emissions 

(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?

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

cassette. You may cut the 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 an EPA Method 5 test in cases where a facility is 

required to test a source for POM and PM?

Yes, you 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 emissions 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 sampling. Measuring hexavalent 

chromium accurately is difficult 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 is 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 Methods 29 and 315. The cassettes will be sampled at 

ambient, or near ambient, conditions and cannot be temperature controlled to the 248°F (±25°F) 

required by EPA Methods 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 in 
addition to the EPA Method 29 or 315 filter. Our intent was only to require the ambient sampling 

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

8. For sources located in 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 acid/hydrogen peroxide 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 polycyclic 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 

(refer 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 faithfully 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 statements 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.