1

From: David Putney/RTP/USEPA/US

To: bstriete@aluminum.org, cjohnson@aluminum.org, Michael.Palazzolo@alcoa.com

Cc: Rochelle Boyd/RTP/USEPA/US

Date: 03/16/2011 04:20 PM

Subject: Fw: DRAFT ICR testing table

Charles/Bob/Mike,

Please see my previous email to Mike concerning the possible testing to be included in the upcoming ICR 

for the primary aluminum industry. I sent that email only to Mike not in an attempt to avoid the input of 

others but only because I thought he was the lead on this testing portion of the ICR and was going to get 

a small group together (maybe 3 people or so) to discuss the testing in an effort to speed the review. 

Please feel free to share the information with all interested parties but keep in mind that we need to move 

as quickly as possible on the ICR and testing requirements.

In the same way, I would like to set up a conference call for early next week to discuss the testing issues -

but want to keep the number of participants to a reasonable number so as to facilitate quick action. I will 

include myself, Rochelle Boyd, Ron Meyers, and Gerry Garwood from the EPA and Mark Bahner and 

David Green from RTI (our contractors). Please let me know who from the primary aluminum facilities I 

should include in the conference call.

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

----- Forwarded by David Putney/RTP/USEPA/US on 03/16/2011 04:09 PM -----

From: David Putney/RTP/USEPA/US

To: Michael.Palazzolo@alcoa.com

Date: 03/11/2011 03:31 PM

Subject: DRAFT ICR testing table

Mike,

Please take a look at the attached draft version of the testing that we intend to include in the upcoming 

ICR for primary aluminum reduction facilities. It is fairly extensive, but management here has expressed a 

willingness (a preference, actually) to lessen the testing burden, especially if we can get the remaining 

testing done, and get the results in-house, expeditiously.

Let's talk about this next week when you get a chance.

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
Att. 1 p1 of 5

Table 1.1. Summary of Test Methods and Alternative Methods for Primary Capture and 

Control System at Primary Aluminum Reduction Facilities

Pollutant

Recommended 

Method

Alternative 

Method

Other Information Target Reported Units of 

Measure

Carbonyl Sulfide U.S. EPA 

Method 18, 

using the bag 

sample option

and a sulfur 

specific detector

None Three test runs. 

Minimum sample time of 

1 hour per run.

lb/hr

lb/ton of aluminum produced

PM2.5

(filterable plus 

condensable)

U.S. EPA 

Methods 201A 

and 202

None Three test runs. Collect a 

minimum volume of 3 

dscm per run.

lb/hr

lb/ton of aluminum produced

POM

(as PM and 

methylene 

chloride 

extractable 

matter, MCEM)

U.S. EPA 

Method 315

None Three test runs. Collect a 

minimum volume of 3 

dscm per run.

lb/hr

lb/ton of aluminum produced

HAP Metalsaand 

Filterable 

Particulate

U.S. EPA 

Methods 5/29

None Three test runs. Collect a 

minimum volume of 3

dscm per run. Runs 

should overlap with PM2.5 

testing. Maintain a filter 

temperature of 248±25oF. 

lb/hr

lb/ton of aluminum produced

Hexavalent 

Chromium (Cr+6)

SW-846 Method 

0061

None Three test runs. Collect a

minimum sample volume 

of 3 dscm per run (or the 

maximum sample volume 

possible while

maintaining the pH of 

first impinger solution 

above 8.5 if less than 3 

cubic meters can be 

collected) and use a

sample preconcentrator 

according to §§4.4 and 

4.5 of the method.

lb/hr

lb/ton of aluminum produced

Flow rate U.S. EPA 

Method 2, 2F, or 

2G

None Simultaneous with each 

pollutant test run

actual m3/min 

dry standard m

3

/min

Exhaust gas 

composition

(MW)

U.S. EPA 

Method 3

U.S. EPA 

Method 3A

or 3B

Simultaneous with each 

pollutant test run

Molecular weight, g/g mole

Moisture U.S. EPA 

Method 4

None Simultaneous with each 

pollutant test run

Volume %

a Metals to be measured are antimony (Sb), arsenic (As), beryllium (Be), cadmium (Cd), chromium (Cr), cobalt 

(Co), lead (Pb), manganese (Mn), nickel (Ni), and selenium (Se).
Att. 1 p2 of 5

Table 1.2. Summary of Test Methods and Alternative Methods for Roof Monitors With 

Permanently Installed Manifold Systems at Primary Aluminum Reduction Facilities

Pollutant

Recommended 

Method

Alternative 

Method

Other Information Target Reported 

Units of Measure

Carbonyl Sulfide U.S. EPA Method 

18, using the bag 

sample option and 

a sulfur specific 

detector

None Three test runs. Collect a 

minimum sample volume 

of 10 liters per bag. See 

additional sampling

specifications under flow 

rate.

lb/hr

lb/ton of aluminum 

produced

POM

(as PM and 

methylene 

chloride 

extractable 

matter, MCEM)

U.S. EPA Method 

315

None Three test runs. Filter 

media must meet the 

requirements of EPA 

Method 315. Recover and 

analyze POM using 

appropriate procedures in 

section 11 of EPA Method 

315 as specified in 40 CFR 

Part 63 Subpart LL. See 

additional sampling

specifications under flow 

rate. 

lb/hr

lb/ton of aluminum 

produced

HAP Metalsaand 

Filterable 

Particulate

U.S. EPA Method 

17/29

None Three test runs. Use a 

quartz filter. See 

additional sampling

specifications under flow 

rate.

lb/hr

lb/ton of aluminum 

produced

Hexavalent 

Chromium (Cr+6)

SW-846 Method 

0061

None Three test runs. SW-846 

Method 0061. Collect a

minimum sample volume 

of 3 dscm per run (or the 

maximum sample volume

possible while maintaining 

the pH of first impinger

solution above 8.5 if less 

than 3 dscm can be 

collected) and use a

sample preconcentrator 

according to §§4.4 and 4.5

of the method. See 

additional sampling 

specifications under flow 

rate.

lb/hr

lb/ton of aluminum 

produced
Att. 1 p3 of 5

Pollutant

Recommended 

Method

Alternative 

Method

Other Information Target Reported 

Units of Measure

Flow rate U.S. EPA Method 

14 

None Measure simultaneous with 

each pollutant test run. 

Conduct each run during a 

period when all normal 

operations (including at 

least one anode change) are 

performed underneath the 

sampling manifold as 

required in Method 14. A 

minimum of 3 dscm of 

emission gas must be 

sampled through each 

filter.

actual m3/min and dry 

standard m

3

/min

Moisture Wet bulb-dry bulb 

measurement

Drying tubes, 

condensation 

techniques, 

stoichiometric 

calculations, or 

other appropriate 

approximation 

technique

Measure simultaneous with 

each pollutant test run

Volume %

a Metals to be measured are antimony (Sb), arsenic (As), beryllium (Be), cadmium (Cd), chromium (Cr), cobalt 

(Co), lead (Pb), manganese (Mn), nickel (Ni), and selenium (Se).
Att. 1 p4 of 5

Table 1.3. Summary of Test Methods and Alternative Methods for Roof Monitors Without 

Permanently Installed Manifold Systems at Primary Aluminum Reduction Facilities

Pollutant

Recommended 

Method

Alternative 

Method

Other Information Target Reported 

Units of Measure

Carbonyl Sulfide U.S. EPA Method 

18, using the bag 

sample option and 

a sulfur specific 

detector

None Three test runs. Collect a 

minimum sample volume 

of 10 liters per bag. 

Samples shall be taken 

concurrently with either 

the POM or metals sample 

and for the same duration 

as the concurrent sample. 

Collect twoabag samples 

per run near the center of 

the building. The bags 

should be placed at the 

roof, near the location of 

the cassettes. See 

additional sampling

specifications under flow 

rate. 

lb/hr

lb/ton of aluminum 

produced

POM

(as PM and 

methylene 

chloride 

extractable 

matter, MCEM)

Sample according 

to U.S. EPA 

Method 17

b

using a 

quartz filter. 

Analyze POM 

using U.S. EPA 

Method 315.

None Three test runs. Filter 

media must meet the 

requirements of EPA 

Method 315. Recover and 

analyze POM using 

appropriate procedures in 

section 11 of EPA Method 

315 as specified in 40 CFR 

Part 63 Subpart LL. See 

additional sampling

specifications under flow 

rate. 

lb/hr

lb/ton of aluminum 

produced

HAP Metalscand

Filterable 

Particulate

U.S. EPA Method 

17busing a quartz 

filter. Analyze 

metals using 

Compendium of 

Methods for the 

Determination of

Inorganic 

Compounds

in Ambient Air

Method IO-3.5. 

None Three test runs. See 

additional sampling 

specifications under flow 

rate.

lb/hr

lb/ton of aluminum 

produced
Att. 1 p5 of 5

Pollutant

Recommended 

Method

Alternative 

Method

Other Information Target Reported 

Units of Measure

Flow rate U.S. EPA Method 

14A 

None Measure simultaneous with 

each pollutant test run. 

Each run shall be a 

minimum of 24-hours and 

encompass at least eight 

cassettes per potline (or 

four cassettes per potroom 

group). All normal 

operations (including at 

least one anode change) 

must be performed during

the sampling period. A 

minimum of 3 dscm of 

emission gas must be 

sampled through each 

filter.

actual m3/min and dry 

standard m

3

/min

Moisture Wet bulb-dry bulb 

measurement

Drying tubes, 

condensation 

techniques, 

stoichiometric

calculations, or 

other appropriate 

approximation 

technique

Measure simultaneous with 

each pollutant test run

volume %

a The two bags will be compared to one another for purposes of precision of analysis. The test may still be 

considered valid with the successful analysis of one bag sample, as long as a good faith attempt is made to capture 

and analyze two bag samples. 

b

The sampling trains for Methods 17 and 315 need not be set up as required in the methods. Instead, the filters 

specified by these methods should be integrated into the roof monitor cassettes. The filter specifications and 

analysis specifications in Methods 17 and 315 should be used for the analysis. For the metal analysis of the 

Method 17 filter and for Method 315, all of the cassette samples per run must be combined prior to analysis.

c Metals to be measured are antimony (Sb), arsenic (As), beryllium (Be), cadmium (Cd), chromium (Cr), cobalt 

(Co), lead (Pb), manganese (Mn), nickel (Ni), and selenium (Se).