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From: Putney.David@epamail.epa.gov

Sent: Tuesday, April 05, 2011 3:36 PM

To: Charles D. Johnson

Cc: Boyd.Rochelle@epamail.epa.gov; Bahner, Mark A.; Green, David A.

Subject: RE: COS reductions and PAL facility capacities

Chuck, 

Thanks for your rapid response to my requests. Please let me know if Monday is okay with folks to discuss the ICR. Also, 

please let me know who to include on the conference call (or did you want to set that up?). 

Tuesday, April 19, 2011 would be fine for a response on the COS issue. 

Also, let me correct/clarify myself on the question of permitted aluminum production capacity in my earlier email. First, I 

forgot to mention that the cited permitted aluminum production capacity values in the table are in units of short tons per 

year (not metric tons).

Second, please disregard my request to include information on permit modification applications to increase the permitted 

aluminum production capacity for these facilities. Residual risk modeling is conducted based on the current permitted 

aluminum production capacity of the facilities. So, please provide corrections to the cited permitted aluminum production 

capacity, if applicable, but only based on the current permits (i.e. not based on requests for increased capacity submitted 

to the permitting authorities). 

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 

From: "Charles D. Johnson" <cjohnson@aluminum.org>

To: David Putney/RTP/USEPA/US@EPA

Date: 04/05/2011 02:25 PM

Subject: RE: COS reductions and PAL facility capacities

David, I’ll circulate this and get responses ASAP. The revised ICR has already gone out. I’m not available on Friday, but I’ve asked if 

we can get a call in to you on Monday for the ICR. 

 

On the COS information, it may take a bit more time because we have our spring meeting the rest of this week, and some schedules 

are tight next week. I believe I can get an aggregate industry response to this back to you by Tuesday, the 19th. Does that work? 

 

Regards, 

Chuck 

 
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From: Putney.David@epamail.epa.gov [mailto:Putney.David@epamail.epa.gov] 

Sent: Tuesday, April 05, 2011 1:53 PM

To: Charles D. Johnson

Cc: Boyd.Rochelle@epamail.epa.gov; bahner@rti.org; green@rti.org

Subject: COS reductions and PAL facility capacities

Chuck,

During the EPA/PAL RTR conference call last month (on 03/22/11 I believe) we briefly discussed the need for information 

on techniques (e.g. work practice standards, raw material specifications, controls, etc.) that could be used to reduce the 

COS emissions from the potlines at PAL facilities. By way of this email I am soliciting your assistance in getting input on 

COS reduction techniques from the industry representatives. Could you please forward this email on to the appropriate 

PAL facility personnel? Also, any rationale from the industry perspective for why potlines should or should not be subcategorized for purposes of COS (i.e. as they are for POM and TF) would be helpful. That is, is industry aware of any 

reasons why COS emissions would vary between the various prebake and Soderberg potline types if the sulfur content of 

the coke and pitch are held constant? Rochelle and I would appreciate any help/information we can get that would assist 

EPA in addressing COS emissions from PAL facilities.

Also, we (EPA) have become aware that our records of the permitted aluminum production capacity of the individual PAL 

facilities (i.e. that amount of aluminum production allowed under their air quality permit) may not be accurate. Our records 

are as presented in the table below. Please have the PAL facilities provide corrected permitted aluminum production 

capacity information as applicable. Please also indicate if any permit modification applications have been submitted to the 

permitting authority which may result in an increase in the permitted aluminum production capacity.

Thanks so much for your assistance in these matters,

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