p. 1 of 4 

From: Rufa, Nathan P. [mailto:Nathan.Rufa@alcoa.com] 

Sent: Friday, January 03, 2014 9:36 AM 

To: Putney, David 

Cc: Palazzolo, Michael A.; Parent, Jordan J. 

Subject: FW: Draft emissions file for the Alcoa primary aluminum facilities 

David, 

I have reviewed the attached draft emissions file for Alcoa 

Massena Operations (West Plant) and for the Reynolds Metals 

St. Lawrence Reduction Plant. In the Alcoa Massena

Operations “Non-Category” tab, I have noted that three rows 

need to be deleted as they are not MACT sources. In 

addition, I revised the X,Y coordinates for the remaining 

sources. In the “Primary Category” tab, the emissions look 

accurate however for the Emission Unit ID PST (Pitch 

Storage Tanks), the X,Y coordinates were off. The 

corrected coordinates should be -74.886435 and 44.960413 

(but there wasn’t a revision column to note that.) 

In the Reynolds Metals St. Lawrence Reduction Plant “NonCategory” tab, I revised the X,Y coordinates for the source 

listed. The “Primary Category” tab looked accurate from 

both an emission standpoint and coordinate standpoint. 

Thanks and please let me know if you need anything else. 

Nathan Rufa 

Staff Environmental Engineer 

Alcoa Primary Metals 

Massena Operations 

Park Avenue East / PO Box 150 

Massena, NY 13662 

Tel: 315-764-4285 

Fax: 315-764-4460 

nathan.rufa@alcoa.com 

From: Putney, David [mailto:putney.david@epa.gov] 

Sent: Wednesday, December 18, 2013 9:33 AM 

To: Palazzolo, Michael A.; Bruntz, Samuel H.; Dobbs, Charles L.; Hulse, David G.; Parent, Jordan J.; Mitchell, 

Kathryn M; Rufa, Nathan P.; Bilskis, Patricia A.; Blodgett, Terry L. 

Subject: EXT: Draft emissions file for the Alcoa primary aluminum facilities 
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Hello Mike et. al., 

Please find attached to this message a draft emissions file 

(Excel spreadsheet) for the Alcoa, Inc. primary aluminum 

production facilities. Columns highlighted in yellow are 

available for revisions or to indicate if records should be 

deleted. Please do not overwrite the data in columns that 

are not highlighted in yellow as this would complicate the 

development of the final emissions file for use in risk 

modeling. 

The tab titled “primary al category12172” includes 

emissions from the primary aluminum production operations 

(e.g., potlines, paste plants, pitch storage tanks, and 

anode bake furnaces) at the Alcoa facilities as estimated 

via emission factors developed from test results obtained 

in response to the testing ICR sent out in April of 2013. I 

expect that the stack parameters are correct as-is since 

industry previously had opportunity to review those items 

in CY2010 before the initial residual risk and technology 

review (RTR) proposal for the primary aluminum production 

source category. There are, however, some emissions (e.g., 

metal HAP, dioxins, PCB, etc.) that are new to the RTR 

analysis for the primary aluminum production source

category and, although these have been QA/QC’d by 

contractor and EPA staff, we do welcome 

feedback/corrections you might have on these emissions. A 

revision column highlighted in yellow is provided for you 

to revise emissions (in units of tons per year, tpy) if 

needed. 

The tab titled “noncategory” includes 2005 NATA NEI, 2008 

NEI and 2010 state HAP data for the Alcoa, Inc. primary 

aluminum production facilities (note that we did not find 

any non-category emissions data for either the Intalco 

facility or the Wenatchee facility). These records are 

intended to include emissions from operations at your 

facility which are not directly associated with primary 

aluminum production (primary aluminum emissions are

addressed under the first tab, discussed above) or 
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secondary aluminum production (secondary aluminum emissions 

will be addressed via the RTR associated with the secondary 

aluminum source category). Revision columns highlighted in 

yellow are included for emissions, pollutants, stack 

parameters, fugitive parameters and latitude/longitude. If 

any of these parameters needs modification, please put the 

corrected value in the associated revision column (again, 

please do not overwrite the data in columns that are not 

highlighted in yellow). Note that fields were also added 

to identify if a record should be deleted, and a reviewer 

comment field where you can add a comment if appropriate. 

Please review these data with the following in mind: 

1. Should the operation be included in the spreadsheet? 

a. Does the operation still exist at the facility? If not, or if it exists but is not legally allowed to 

operate (e.g., you do not have a valid operating permit for this operation) then the operation 

and associated emissions need not be included. 

b. If the operation does exist at the facility, is it part of any secondary aluminum operations that 

may exist at your facility? If so, then the operation and associated emissions need not be 

included (so as to avoid double counting those emissions). 

c. If the operation does exist at the facility, would the emissions from this operation be 

considered part of the monitored primary aluminum emissions? For example, if the emissions 

associated with the operation in question are routed through the control device associated 

with the paste plant and would be monitored as part of the paste plant emissions then the 

operation and associated emissions need not be included (so as to avoid double counting 

those emissions). 

2. If the operation should be included, are the cited emissions representative of that operation? 

3. If the operation should be included but the cited emissions are not representative of that operation,

then please provide representative annual actual emissions in units of tons emitted per year (tpy). 

4. Verify or modify the stack parameters and location as appropriate and necessary. 

If I might make a suggestion – you can use the filter 

function in Excel to narrow down the file to review a 

single facility at a time. 

Mike – I do not have any information for a contact at the 

Lake Charles facility. Would you please pass this email and 
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attachment along to someone at that facility that could 

review this information? Also, would you please forward me 

that person’s contact information? 

Please provide any comments, changes, corrections, etc. to 

this file to me by close of business on Friday, 01/03/14. I 

understand that more time might be preferable with the 

holidays upon us, but please give me what you can by 

01/03/14 and remember that you will have another 

opportunity to make comments and corrections during the 

upcoming public notice and comment period associated with 

the primary aluminum production RTR supplemental proposal. 

If you have any questions concerning these issues, please 

feel free to contact me by email or telephone. 

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 D243-02 

Ph: (919) 541-2016 Fax: (919) 541-3207 

Email: putney.david@epa.gov