1 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 product ion 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 facilit ies. 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 Progr ams 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’v e 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 schedu les are tight next week. I believe I can get an aggregate industry response to this back to you by Tuesday, the 19 th

. Does t hat work?

Regards,

Chuck2 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 techniq ues (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 techn iques 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 sub

categorized 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 Div ision 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