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### Putney, David

From: Backfisch Don (NORALNM) <Don.Backfisch@noralinc.com> Sent: Tuesday, April 29, 2014 3:49 PM To: Putney, David Cc: Jones Mark (NORALNM) Subject: RE: Potline PM testing Attachments: removed.txt

David,

I don’t have good records for the activities that were going on in the Potline 2 at the time of the tests. I do know that during run 1 there were carbons being set in the vicinity of the sampling manifold that would affect the particulate levels being released. In Potline 2 the alumina is introduce to the pots with an ore bucket that dumps the alumina into an open topped bin on the pot. We don’t maintain records of when the ore is being put out in the Potlines. Potline 3 does not have the same issue since the ore is supplied to the cell through an air slide into an enclosed hopper. Another probable cause is the short timeframe for the particulate testing. When we do our fluoride testing, the time is spread out over an entire cycle (24 hours) of anode setting, tapping, and “quiet time” (when the pots are sealed and no work is taking place). The particulate testing was done with 120 minute run times and captured whatever activities were going on the potline at the time.

Based on observations of the filters from fluoride testing, there is a lot a variability in particulate emissions. Some of thepossible causes we’ve identified include alumina quality, weather conditions (wind, humidity), ventilator position, burnoffs or other issues that cause additional work in and around the pots.

Don Backfisch Environmental Superintendent Noranda (NYSE NOR) Phone: (573) 643-2361 x2126 Fax: (573) 643-6721 E-mail: don.backfisch@noralinc.com Website: www.norandaaluminum.com

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From: Putney, David [mailto:putney.david@epa.gov] Sent: Thursday, April 24, 2014 10:38 PM To: Backfisch Don (NORALNM); Backfisch Don (NORALNM) Subject: Potline PM testing

D on,
My apologies if this email hits you twice – I have two email addresses for you and I’m not sure which one is correct. Anyway, I’ve been going over some of the test results from the testing ICR that we sent out in April of 2013 and I notice some strange results for the PM testing conducted on Potline 2 at your facility.

Specifically, the PM emissions from Potline 2 during runs 1 and 2 were MUCH higher than for any other CWPB1 potlines. In fact, the PM results for those 2 runs were much higher even than the other results at your facility (i.e., run 3 on Potline 2 and runs 1, 2, and 3 on Potline 3). According to the test report, these high PM emissions estimates were the result of very high secondary (roof vent) PM emissions. Do you have any idea what could have been going on at the time2 to cause these high results? For example, were there an unusually high number of anode changes on Potline 2 during runs 1 and 2? Or, were there an unusually high number of anode effects reported during those runs? (I’m hoping you may have some operational records from the day in question that may shed light on this issue.) Are you aware of any operational reason why the results for PM from Potline 2 during runs 1 and/or 2 might not be representative of normal emissions?

Please let me know your thoughts on these (hopefully untypical) PM results.

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