p. 1 of 7 

From: Putney, David 

Sent: Friday, August 23, 2013 3:27 PM 

To: 'Brian Ashbrook' 

Subject: RE: section 114 testing 

Mr. Ashbrook, 

I’ve taken a quick look at the revised report and have 2 follow up questions/comments. 

First, I notice that the emissions rates of cobalt have not been corrected in Tables 2-2 and 2-3 (found on pages 

6 of 194 and 7 of 194 in the pdf version of the revised report you sent me earlier today). That is, the cited 

potline secondary cobalt emission rates in the revised report are identical to the potline secondary cobalt 

emission rates included in the initial report. All other metals emissions rates cited in revised Tables 2-2 and 2-3 

have been reduced by a factor of 4. 

Second, the potline secondary exhaust flow rates still appear high. Notice that on page 5 of 82 in the pdf 

version of the response to the 2011 ICR for your facility (attached) the average potline secondary exhaust flow 

rate was cited as 793,500 scfm whereas in the revised report you sent me earlier today (refer to page 5 of 194 

and 7 of 194 in the pdf version of that document) the potline secondary exhaust flow rates are about 4 times 

that previously cited average value. I’m not trying to second guess you, just want to make sure we are not 

overestimating emissions (and the associated risk) from your facility. Note that if the potline secondary 

exhaust flow rates are still overestimated by a factor of 4, then so are the potline secondary metal HAP 

emission rates. 

Please confirm whether or not the cobalt emissions rates and potline secondary exhaust flow rates referenced 

above need to be corrected and, if so, please provide the corrected values. 

Thanks and have a great weekend. 

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: Brian Ashbrook [mailto:Brian.Ashbrook@ormet.com] 

Sent: Friday, August 23, 2013 12:05 PM 

To: Putney, David 

Subject: RE: section 114 testing 

Mr. Putney, 

I have attached the final revision sent from Shaw a short time ago. I was sent an electronic copy last night for 

approval. 
p. 2 of 7 

The problem with the original report was that my consultant used 4 times the area in calculating the flow 

rate. This has been corrected. 

Please call me at 740-483-2732 if there are any questions. 

Thanks, 

Brian Ashbrook 

Environmental Services Manager 

Ormet Primary Aluminum Corp. 

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

Sent: Friday, August 23, 2013 9:54 AM 

To: Brian Ashbrook 

Subject: FW: section 114 testing 

Mr. Ashbrook, 

My electronic calendar just prompted me (it is scheduled to do this every Friday) to follow up with you again 

regarding the revised report for the Ormet primary aluminum facility. Is your consultant back from vacation 

yet? If so, do you have a revised emission report for me yet? 

I’m not in panic mode yet, but am eager to make the corrections to the emissions data file for your facility as 

soon as possible and get that information up to the risk assessment folks here at EPA. Those risk assessments 

are typically time and labor intensive. So, I need to get them started ASAP. 

Thanks again, and have a great weekend. 

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: Putney, David 

Sent: Monday, August 19, 2013 11:13 AM 

To: 'Brian Ashbrook' 

Subject: RE: section 114 testing 

Mr. Ashbrook, 

No apologies necessary – this is the vacation time of year after all. 
p. 3 of 7 

Anyway, please do forward me the revised report as soon as you can so I can update the emission files for your 

facility. This is, of course, very important as I do not want to overestimate the risks to public health 

represented by your facility. 

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

From: Brian Ashbrook [mailto:Brian.Ashbrook@ormet.com] 

Sent: Monday, August 19, 2013 7:24 AM 

To: Putney, David 

Subject: RE: section 114 testing 

Mr. Putney, 

Our consultant has been out of town and should be back this week. I will talk with him today about getting a 

new report sent out after he fixes the problems that need fixed 

Again, I apologize for the delay. 

Thanks, 

Brian Ashbrook 

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

Sent: Friday, August 16, 2013 3:55 PM 

To: Brian Ashbrook 

Subject: RE: section 114 testing 

Mr. Ashbrook, 

Have you heard anything from your consultant concerning my second bullet item yet (i.e., the issue of 

apparent overestimation of secondary potline emission rates and resulting overestimation of secondary 

potline pollutant emission rates)? 

Not trying to pester you – but my electronic calendar reminder just popped up and I wanted to reach out to 

you for an update. 

Thanks, 

David Putney, Environmental Engineer 

U.S. Environmental Protection Agency 
p. 4 of 7 

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: Brian Ashbrook [mailto:Brian.Ashbrook@ormet.com] 

Sent: Friday, August 09, 2013 1:35 PM 

To: Putney, David 

Subject: RE: section 114 testing 

Mr. Putney, 

I have attached the revised pages from DAT Labs showing that the tests were performed on lead instead of 

iron. Dr. Mitchum at DAT Labs confirmed this. 

Also, I wanted to have both of your questions answered by the end of today, but I am having trouble getting in 

contact with my second consultant. I have left numerous messages with him and he is normally very good 

about getting back to me, so he must be on vacation. I will have the second question answered at the 

beginning of the week after talking with him. 

Thanks, 

Brian Ashbrook 

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

Sent: Wednesday, July 31, 2013 1:56 PM 

To: Brian Ashbrook 

Subject: RE: section 114 testing 

Mr. Ashbrook, 

I have a few more questions concerning the emissions testing data submitted for the Ormet primary aluminum 

facility. Please discuss the following issues with the appropriate plant, testing contractor, and laboratory 

personnel and let me know the outcome. 

• First, there are issues with the lead emissions reported for your facility. Specifically, the cited potline 

secondary emissions of about 0.14 lb lead per ton of aluminum produced are very high. I noticed that 

some of the associated lab data lists “iron” where “lead” should be located (see pages 11-26 and 69 of

123 in the file named “DAT Labs Cassette Analysis Report.pdf”). Perhaps there was some sort of mix up 

at the lab? Please verify whether the lab is in fact reporting lead data or iron data in these sheets. In 

any case, it would be good to get a version of this file that lists “lead” instead of “iron” in these spots 

(since it will end up in the docket for this rulemaking). 

• Second, the potline secondary emissions in general (i.e., metals, PM and POM) appear high. After a 

quick review of the file named “Shaw ICP Fug Mtls HAP Rep-7-13.pdf” – it would appear that this could 

be due (at least in part) to an overestimate of your potline secondary flow rates. Specifically, Table 2-1 

(on page 2 of the report hard copy, page 5 of 194 of the pdf version) lists secondary potline flow rates 
p. 5 of 7 

(11,341,482 dscfm for potline 2 and 14,553,539 dscfm for potline 3) that are far in excess of what was

cited for your facility in response to the 2011 ICR. In the 2011 ICR response for your facility potline 

secondary flow rates were cited at about 793,500 dscfm. Please confirm or modify appropriately (e.g., 

if the potline secondary flow rates listed in Table 2-1, and presumably used in the emission rate 

calculations, are indeed incorrect) all of the reported potline secondary emissions from your facility. 

Again, I want to point out that we have not finished reviewing the report yet, and we may have other 

questions in the future. Again, not trying to pester you, rather we are trying to resolve questions as we find 

them instead of holding them until the end. 

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

From: Brian Ashbrook [mailto:Brian.Ashbrook@ormet.com] 

Sent: Friday, July 19, 2013 1:13 PM 

To: Putney, David 

Subject: RE: section 114 testing 

Mr. Putney, 

Attached are files that should answer all questions you had during your initial review of Ormet’s 

data. Attached are Ormet’s letter to OEPA notifying them of the special sapling, Ormet’s laboratory test plan 

that was followed for sample collection, Ormet’s emission report , and a revised Table 3-1. 

If there are still questions or concerns, please let me know. 

I can be reached at 740-483-2732. 

Thanks, 

Brian Ashbrook 

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

Sent: Tuesday, July 02, 2013 3:43 PM 

To: Brian Ashbrook 

Subject: RE: section 114 testing 

Mr. Ashbrook, 
p. 6 of 7 

During our review of the test data submitted for the Ormet primary aluminum facility pursuant to the recent 

testing ICR, we have found several items for which we need additional information and/or clarification. 

Specifically, 

• It appears that we did not receive the test report associated with secondary potline emissions. The 

submitted reports (DAT Labs Cassette Analysis Report, ITT and cover letter to OEPA, and Ormet ICP 

PM-MCEM Mtl HAP – 2-13&App) do not appear to address secondary potline emissions. The file DAT 

Labs Cassette Analysis Report includes laboratory analyses of the cassettes, but not the emissions 

report. That is, we know the mass of pollutant captured in the cassettes, but not how to convert that 

to a lb of pollutant per ton of aluminum emission rate. 

• The aluminum production rates listed in Table 3-1 on page 5 of the report (on the order of 260 tons 

per hour) appear VERY high. If you will supply a corrected page 5 we can update the report before 

submitting it to the docket. 

Note that in your earlier email you mentioned having trouble using the ERT. My contractor has not been able 

to locate an ERT report for your facility. If you did submit such a report it may be that some of this requested 

information is in that report. Did you ever submit an ERT report for your facility – or was all data included in 

the 3 pdf files you initially submitted? 

I also want to let you know that we have not finished reviewing the report yet, and we may have other 

questions in the future. We are trying to resolve questions as we find them instead of holding them until the 

end. 

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

From: Brian Ashbrook [mailto:Brian.Ashbrook@ormet.com] 

Sent: Friday, May 31, 2013 2:14 PM 

To: Putney, David 

Cc: psohi@aluminum.org

Subject: section 114 testing 

Mr. Putney, 

I have attached the ITT for testing, the stack testing report, and the cassette testing report required by Ormet 

Primary Aluminum to fulfill the section 114 request received by Ormet on March 11, 2013. I am having serious 

IT trouble with the ERT access program required by the EPA for submittal and I wanted to submit the data 

before the deadline. I will continue to work with our IT department to remedy this problem. 
p. 7 of 7 

Please let me know if there is anything else I need to do. 

Thanks, 

Brian Ashbrook 

Environmental Services Manager 

Ormet Primary Aluminum Corporation 

740-483-2732