Sent: Thu 10/17/2013 9:19 AM

Steve & Dave,

Enclosed please find comments on your Wenatchee “Staff Working Document” that was shared with us and the Department of Ecology. If you have any questions or wish to discuss any of our comments, let us know and we will make arrangements for a discussion.



### Jimmy Jones
Alcoa Inc. EHS Services Office: 865

- 977

- 3071 Mobile: 865

- 548

- 8059

## Alcoa Wenatchee Works **: USEPA Draft BART Regulation**  40 CFR, Part 52, §52.2503

Draft Date: September 30, 2013 Date: October 1 7 , 2013

**General C omments** 

1. Alcoa W enatchee Works maintains that the best available retrofit technology (BART) applicability study performed by the State of Washington was properly conducted pursuant to USEPA guidelines. 1

2. The draft regulation has drawn heavily from t he previously proposed federal BART determination and requirements EPA developed for Intalco Aluminum. Although both facilities are primary aluminum reduction plants, there are significant differences between the facilities, both from technological and op erational perspectives. The differences must be recognized and taken into consideration when proposing any site specific regulation. EPA need only look as far as its Primary Aluminum NESHAP to recognize that Wenatchee and Intalco are in different regulato ry subcategories. For this reason, it will not be suitable to import many of the procedural and operational requirements in the Intalco BART into a Wenatchee BART regulation. The State’s determination that Alcoa Wenatchee Works is not subject to BART was factual, proc edurally correct, supported by sound scientific principles, and as a result should prevail

. EPA should forego the development and proposal of a federal alternative to the State of Washington’s determination

.

3. Throughout the draft proposal January 1, 2015 is established as the Wenatchee BA RT compliance date. The proposal should be structured in a manner that the initial compliance date is contingent upon the promulgation of a final rule in the Federal Register . The rule should propose that the compliance date will be 2 years after the eff ective date of a final rule being published in the Federal Register. The actual compliance date will then be shown in the Final Rule once it is published

4. The proposed rule establishes the EPA test methods to be used when measuring pollutant specific emis sion rates. However, none of the pollutant specific compliance demonstrations require Wenatchee measure pollutants to demonstrate compliance . It is believed that a better approach to define EPA’s preferred test methods would be to craft a separate paragr aph at the end of the rule that establishes an obligation to test upon the administrator’s request and lists the relevant test methods . Within that paragraph individual test methods can be identified

. I t is also requested that EPA include language that permits the use of alternative test methods.

1 70 FR 39156. Appendix Y to Part 51, “ Guidelines for BART Determinations Under the Regional Haze Rule .” July 6, 2005

.USEPA Draft BART Regulation Alcoa Wenatchee Works Staff Working Document Review

**2 |**  Page

wenatchee bart rule comments (10

- 1 7

- 13).docx **Item Specific Comments**

**•** §52.2503(a) identifies the Aluminum Corporation of America as the affected entity. The correct company name is Alcoa Inc.

– Wenatchee Works.

**•** §52.2503(b)(1). The proposal should establish the compliance date so that it is contingent upon and consistent with the promulgation of a final rule. The proposal should establish a final compliance date that will be 2 years after the effective date of a final rule being published in the Federal Register. The actual compliance date will be shown in the Final Rule once it is published.

**•** §52.2503(b)(1)(i) only identifies EPA Method 6 as the method for measuring SO 2 , and compliance with the proposal’s SO 2 requirements is to be demonstra ted via a non

measurement methodology

. Although there are other EPA SO 2 measurement methods that are not identified, such as Method 6C , the draft proposal only includes Method 6 . T he

non

- measurement based compliance demonstration of the draft rule provides for a more comprehensive accounting of Potline No. 5 ’s SO 2 emissions , it is consistent with the location’s T itle V permit requirements, and t he non

- measurement compliance demonstration methodology conservatively quantifies all of Potline No. 5’s S O 2 emissions whereas measurement only quantifies a portion. There is no need to measure partial Potline No. 5 SO 2 emissions or to designate Method 6 as the sole measurement method

, because there are better, more efficient, and more inclusive means of quan tifying the SO 2 emissions from Potline No. 5

.

**•** §52.2503(b)(1)(ii) The time intervals specified in this portion of the Draft should be clarified to be “calendar month” values.

**•** §52.2503(b)(1)(ii)(c) The correct percentage of sulfur converted from sulfur in to SO 2 at Wenatchee should be 90% rather than the 95% value that originated from the Intalco BART. This is an example of one of the operational differences mentioned in the General Comment above.

**•** §52.2503(b)(1)(iii)(a) The requirement to sample anodes f or their sulfur content should be clarified by stating that the value is a minimum of four “baked” anode samples. Paragraph (a) should be written to say that “As a minimum, Alcoa must collect no less than four (4) baked anode core samples during each cale ndar week.

**•** §52.2503(b)(2) The proposal should establish the compliance date so that it is contingent upon and consistent with the promulgation of a final rule. The proposal should establish a final compliance date that will be 2 years after the effective date of a final rule being published in the Federal Register. The actual compliance date will be shown in the Final Rule once it is published.

**•** §52.2503(b)(2) The proposed regulation should be clarified to establish that the pollutant concentration limitation established via the rule is a limitation on the exhaust from the Potline #5 GTC emission control device

.

**•** §52.2503(b)(2)(1) The proposal imposes the use of EPA Method 17 as the measurement method for particulate matte r. For its title V operating permit, Wenatchee regularlyUSEPA Draft BART Regulation Alcoa Wenatchee Works Staff Working Document Review

**3 |**  Page

wenatchee bart rule comments (10

- 1 7

- 13).docx determines particulate emission s using Alcoa Method 4075A

- TF 2

, 3

**•** §52.2503(c)(1) (i) The ASTM method specified in the p roposal was withdrawn in 2012. The reference to and requirement to comply via this particular testing methodology should be edited or removed entirely. . Method 4075A is an EPA approved alternative test method for fluoride, which also provides a measure of particulate emissions. Alcoa requests that t his portion of the proposal be written to also allow determination of particulate emissions using Alcoa Method 4075A

- TF for compliance with the BART potline particulate emission limit.

**•** §52.2503(c)(2)(i) Make note of the general comment regarding the use of approved alternatives to the t ypical EPA test methods.

**•** §52.2503(c)(3) Permanently restricting the anode baking furnace fuel to natural gas, places the facility at risk of closure in the event of a mandated natural gas curtailment. Provisions should be made for the use of an alternati ve fuel when permitted or required to change fuels

.

**•** §52.2503(d)(1) The last ingot furnace, IP

- 3

, should be changed to identif y it as Ingot Furnace No. 11 (IP

- 11)

.

**•** §52.2503( f )(1) The alumina handling fabric filtration system 21

- M (OH

- 18) and fabric filtration system 19C (OH

- 21) are currently no t equipped with a stack to be tested. T he BART proposal should refrain from imposing requirements that will be costly and will have no meaningful affect on Class 1 area visibility. To impose a requirem ent that require s periodic particulate emission testing and the retrofitting of existing control device exhaust system s with sampling ports and platforms will be neither cost effective nor environmentally beneficial

.

**•** §52.2503(g)( 1 ) The requirement needs to specify that the calendar month potline SO 2 calculation is specific to Potline No. 5

.

**•** §52.2503(h)(3) The requirement should be to report the average sulfur content of coke received during each calendar month, rather than the sulfur content of each shi pment. Records of each shipment are to be maintained pursuant to §52.2503( g )(7) and will be available to verify underlying data used to compute the monthly sulfur content of incoming coke.

**•** §52.2503(h)(4) Without further definition of the electronic report ing format, it is not possible to offer specific comments on this reporting requirement. As a result, our

comment s at this time are of a general nature. Whatever reporting format adopted by EPA s hould utilize broadly used and readily available off

– the

– sh elf software (e.g. word processor, spreadsheet software); it should not be costly ; and it should not require extensive employee training in order for the reports to be filed.

2 Federal Register, Volume 42, No. 17, January 26, 1977

3 Hunt, William F. Correspondence to Michael Palazzolo, August 9. 1996.