January 30, 2015 

Memorandum 

Subject: Summary of Conference Call with Alcoa Representative 

From: David Green, RTI 

To: David Putney, EPA/OAQPS 

I. Purpose

 The purpose of the call was to discuss provisions of the Primary Aluminum Risk and 

Technology Review Supplemental Proposal related to the proposed particulate matter (PM) limit for 

anode bake furnaces, bag leak detection requirements, and work practices. 

II. Date and Time 

 The call was held January 29, 2015 between 1:00 p.m. and 1:45 p.m. 

III. Attendees

 David Putney, EPA/OAQPS 

 David Green, RTI 

 Mike Palazzolo, Alcoa 

IV. Summary

A. Proposed PM Limit for Anode Bake Furnaces 

Mike Palazzolo stated that based on newly conducted PM tests using EPA Method 315 some of 

the anode bake furnaces, including some of those in the MACT floor pool, would not meet the 

proposed emission limit that was derived from reports of PM testing conducted in 2013. Mr. 

Palazzolo agreed to provide summaries of data submitted to EPA in 2011, as well as data from tests 

conducted in 2014 and requested that all of these data be used to determine, and if necessary, revise 

the PM standard for anode bake furnaces. No changes have been made to the furnaces or the control 

systems since 2011. 

Additionally Mr. Palazzolo stated that the 2013 anode bake furnace PM emission data obtained 

from a test of three baghouses at Warrick was misinterpreted in that there were only three tests, with

two of the tests each consisting of 3 runs on different stacks from two baghouses. EPA had 

interpreted the test report on the basis of 6 tests having been conducted. 

B. Bag Leak Detection System Requirements 

Mr. Palazzolo stated that in contrast to most affected sources, three of the older potlines at the 

Warrick plant each had 36 separate exhaust stacks (see Attachment 1) and that the cost of installing 

and operating Bag Leak Detection Systems on each individual stack would be prohibitive, based on 
p. 2 of 4 

vendor quotes. He suggested that the current NESHAP requirements for visible emission monitoring 

might be justified for potline stacks, and planned to provide cost information as part of his written 

comments on the proposal. 

C. Proposed Work Practices for Potlines 

Mr. Palazzolo stated that the proposed work practices in 40 CFR §63.854(a), particularly 

requirements to reseal pot crusts that have been broken, as often and as soon as practicable, and to 

reduce cell temperatures to as low as practicable may not be optimal for minimizing emissions. He 

suggested alternative work practices, taken from the preamble for 40 CFR Part 60, Subpart S i.e., the 

Standards of Performance for Primary Aluminum Reduction Plants (see Attachment 2). 
p. 3 of 4 

Attachment 1. Alcoa Warrick Potline Stacks. 
p. 4 of 4 

Attachment 2. Alternate Work Practices for Potlines Suggested by Alcoa, based on New Source 

Performance Standards.a

1. Hood covers should fit properly and be in good repair; 

2. If the exhaust system is equipped with an adjustable air damper system, the hood exhaust rate for 

individual pots should be increased whenever hood covers are removed from a pot (the exhaust 

system should not, however, be overloaded by placing too many pots on high exhaust); 

3. Hood covers should be replaced as soon as possible after each potroom operation; 

4. Dust entrainment should be minimized during materials handling operations and sweeping of the 

working aisles; 

5. Only tapping crucibles with functional aspirator air return systems (for returning gases under the 

collection hooding) should be used; and 

6. The primary control system should be regularly inspected and properly maintained. 

a

 See 45FR44203 – 44204, June 30, 1980