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 h ave 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 (foun d on pages 6 of 194 and 7 of 194 in the pdf version of the rev ised report you sent me earlier today). That is, th e cited potline secondary cobalt emission rates in the revi sed report are identical to the potline secondary c obalt emission rates included in the initial report. All other metals emissions rates cited in revised Table s 2-2 and 2-3 have been reduced by a factor of 4.

Second, the potline secondary exhaust flow rates st ill appear high. Notice that on page 5 of 82 in the pdf version of the response to the 2011 ICR for your fa cility (attached) the average potline secondary exh aust flow rate was cited as 793,500 scfm whereas in the revis ed report you sent me earlier today (refer to page 5 of 194 and 7 of 194 in the pdf version of that document) t he 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 second ary exhaust flow rates are still overestimated by a fac tor of 4, then so are the potline secondary metal H AP
emission rates.

Please confirm whether or not the cobalt emissions rates and potline secondary exhaust flow rates refe renced above need to be corrected and, if so, please provi de 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 las t night for approval.p. 2 of 7

The problem with the original report was that my co nsultant used 4 times the area in calculating the f low
rate. This has been corrected.

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

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 sche duled to do this every Friday) to follow up with yo u again regarding the revised report for the Ormet primary aluminum facility. Is your consultant back from vac ation yet? If so, do you have a revised emission report f or me yet?

I’m not in panic mode yet, but am eager to make the corrections to the emissions data file for your fa cility as soon as possible and get that information up to the risk assessment folks here at EPA. Those risk asse ssments 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 d o not want to overestimate the risks to public heal th 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 b ack this week. I will talk with him today about ge tting a new report sent out after he fixes the problems tha t 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 concer ning my second bullet item yet (i.e., the issue of apparent overestimation of secondary potline emissi on rates and resulting overestimation of secondary potline pollutant emission rates)?

Not trying to pester you – but my electronic calend ar reminder just popped up and I wanted to reach ou t to you for an update.

Thanks,

David Putney, Environmental Engineer U.S. Environmental Protection Agencyp. 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 sho wing 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 answe red by the end of today, but I am having trouble ge tting in contact with my second consultant. I have left num erous messages with him and he is normally very goo d 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 emission s testing data submitted for the Ormet primary alum inum facility. Please discuss the following issues with the appropriate plant, testing contractor, and labo ratory personnel and let me know the outcome.

• First, there are issues with the lead emissions rep orted for your facility. Specifically, the cited po tline secondary emissions of about 0.14 lb lead per ton o f 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 R eport.pdf”). Perhaps there was some sort of mix up at the lab? Please verify whether the lab is in fac t 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 rulema king).

• 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 H AP Rep-7-13.pdf” – it would appear that this could be due (at least in part) to an overestimate of you r potline secondary flow rates. Specifically, Table 2-1 (on page 2 of the report hard copy, page 5 of 194 o f the pdf version) lists secondary potline flow rat esp. 5 of 7

(11,341,482 dscfm for potline 2 and 14,553,539 dscf m 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 potlin e secondary flow rates were cited at about 793,500 ds cfm. 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 repo rted potline secondary emissions from your facility

.

Again, I want to point out that we have not finishe d reviewing the report yet, and we may have other questions in the future. Again, not trying to pest er you, rather we are trying to resolve questions a s 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 notifyin g them of the special sapling, Ormet’s laboratory t est plan that was followed for sample collection, Ormet’s em ission report , and a revised Table 3-1.

If there are still questions or concerns, please le t 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 th e Ormet primary aluminum facility pursuant to the r ecent 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 Repor t, ITT and cover letter to OEPA, and Ormet ICP PM-MCEM Mtl HAP – 2-13&App) do not appear to addres s secondary potline emissions. The file DAT Labs Cassette Analysis Report includes laboratory a nalyses of the cassettes, but not the emissions report. That is, we know the mass of pollutant capt ured in the cassettes, but not how to convert that to a lb of pollutant per ton of aluminum emission r ate.

• The aluminum production rates listed in Table 3-1 o n page 5 of the report (on the order of 260 tons per hour) appear VERY high. If you will supply a co rrected page 5 we can update the report before submitting it to the docket.

Note that in your earlier email you mentioned havin g trouble using the ERT. My contractor has not been able to locate an ERT report for your facility. If you d id 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 i ncluded in the 3 pdf files you initially submitted?

I also want to let you know that we have not finish ed 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 u ntil 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 tes ting report, and the cassette testing report requir ed 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 da ta 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