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 17, 2013

General Comments

1. Alcoa Wenatchee 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 the 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 operational 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 regulatory 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, procedurally 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 BART 

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 

effective 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 emission 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 paragraph 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. It 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

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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 SO2, and

compliance with the proposal’s SO2 requirements is to be demonstrated via a nonmeasurement methodology. Although there are other EPA SO2 measurement methods 

that are not identified, such as Method 6C, the draft proposal only includes Method 6. The 

non-measurement based compliance demonstration of the draft rule provides for a more 

comprehensive accounting of Potline No. 5’s SO2 emissions, it is consistent with the 

location’s Title V permit requirements, and the non-measurement compliance 

demonstration methodology conservatively quantifies all of Potline No. 5’s SO2 emissions 

whereas measurement only quantifies a portion. There is no need to measure partial 

Potline No. 5 SO2 emissions or to designate Method 6 as the sole measurement method, 

because there are better, more efficient, and more inclusive means of quantifying the SO2 

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 into SO2 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 for 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 calendar 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 matter. For its title V operating permit, Wenatchee regularly 
USEPA Draft BART Regulation

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Staff Working Document Review

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wenatchee bart rule comments (10 - 1 7 - 13).docx

determines particulate emissions using Alcoa Method 4075A-TF2,3

• §52.2503(c)(1)(i) The ASTM method specified in the proposal 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 this 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 typical 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 alternative fuel when permitted or required

to change fuels.

• §52.2503(d)(1) The last ingot furnace, IP-3, should be changed to identify 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 not equipped with a stack to be tested. The 

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 requirement that

requires periodic particulate emission testing and the retrofitting of existing control 

device exhaust systems 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 SO2 

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 shipment. 

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 reporting format, it is not 

possible to offer specific comments on this reporting requirement. As a result, our 

comments at this time are of a general nature. Whatever reporting format adopted by 

EPA should utilize broadly used and readily available off–the–shelf 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.