### 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

Ch arles/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 th ought 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 k eep 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 re asonable 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
sho uld 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 D 243

- 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 testin g 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
Off ice 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 p 1 of 5

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

Control System at Primary Aluminum Red uction 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

PM 2.5 (filterable plus condensable) U.S. EPA

Methods 201A

and 202 None Three test runs

. Collect a

minimum volume of 3

d s cm 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 Metals a and

Filterable

Particulate U.S. EPA

Method s 5/29 None Three test runs . Collect a

minimum volume of 3

dscm per run

. Runs should overlap with PM 2.5 testing. M aintain 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 impinge r 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 m 3 /min

d ry s tandard m 3 /min

Exhaust gas composition (MW) U.S. EPA

Method 3 U.S. EPA

Method 3 A

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 p 2 of 5

Table 1.2

. Summary of Test Methods and Alternative Methods for Roof Monitors With Permanently Installed Manifold Systems at Primary Aluminum Re duction 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 sampl ing 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 6 3 Subpart LL . See

additional sampl ing specifications under flow

rate. lb/hr

lb/ton of aluminum produced

HAP Metals a and

Filterable

Particulate U.S. EPA Method

17 /29 None Three test runs. Use a quartz filter. See

additional sampl ing 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 impinge r 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 o f aluminum produced

### Att. 1 p 3 of 5

Pollutant Recommended

Method Alternative

Method Other Information Target Reported
Units of Measure

Flow rate U.S. EPA Method

14 None Measure s imultaneous with each pollutant test run.

C onduct each run during a period when all normal operations (including a t
least o n e 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 m 3 /min and d ry

s tandard m 3 /min

Moisture Wet bulb

- dry bulb

measurement Drying tubes,

condensation techniques,

stoichiometric calculations, or other appropriate approximation technique Measure s imultaneous 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 p 4 of 5

Table 1.3 . Summary of Test Methods and Alternative Methods for Roof Monitors Without Permanently Installed Manifold Systems at Primary Aluminum Re duction Facili ties

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 two a bag samples

per run near the center of the building. T he bags should be placed at the roof, n ear 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 1 7 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

P art 6 3 Subpart LL . See
additional sampl ing specifications under flow

rate. lb/hr

lb/ton of aluminum produced

HAP Metals c and

Filterable

Particulate U.S. EPA Method

17 b using 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 p 5 of 5

Pollutant Recommended

Method Alternative

Method Other Information Target Reported
Units of Measure

Flow rate U.S. EPA Method

14A None Measure s imultaneous with each pollutant test run.

E ach run shall be a

minimum of 24

- hours and encompass at least eight cassettes per potline (or four cassettes per potroom group). A ll normal operations (including a t
least o n e anode change)

must be performed duri ng the sampling period. A
minimum of 3 dscm of emission gas must be sampled through each

filter. actual m 3 /min and d ry

s tandard m 3 /min

Moisture Wet bulb

- dry bulb

measurement Drying tubes,

condensation techniques,

stoichiometric calculations, or other appropriate approximation technique Measure s imultaneous with

each pollutant test run v olume %

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 cass ette 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).