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From: Putney, David 

Sent: Wednesday, December 18, 2013 10:02 AM 

To: 'swright@cfaluminum.com' 

Subject: Draft emissions file for the Columbia Falls primary aluminum facility 

Hello Steve, 

I am currently working on a supplemental proposal for the 

residual risk and technology review (RTR) of the NESHAP for 

Primary Aluminum Production facilities. Part of that review 

includes developing an emissions file for each primary 

aluminum production facility which will be used as input to 

the risk models. To that end ... please find attached to this 

message a draft emissions file (Excel spreadsheet) for the 

Columbia Falls Aluminum Company (CFAC) primary aluminum 

production facility. 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 the risk 

modeling. 

The tab titled “primary Al category” includes emissions 

from the primary aluminum production operations (e.g., 

potlines, paste plants, pitch storage tanks, and anode bake 

furnaces) at the CFAC facility as estimated via emission 

factors developed from test results obtained in response to 

a 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 CY2011 

with the initial 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. 
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The tab titled “noncategory” includes 2005 NATA NEI, 2008 

NEI and 2010 state HAP data for the CFAC primary aluminum 

production 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 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. 
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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