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From: Coomes, Brandon [ mailto:Brandon.Coomes@centuryaluminum.com ]
Sent: Wednesday, September 18, 2013 9:04 AM
To: Putney, David
Cc: Carroll, Danny Subject: RE: TF emissions data

David,

I have attached to this email our facility’s annual PMACT emissions report for 2012. I have also atta ched our 2013 draft report that reflects our facility’s TF e missions to August. The TF emissions results repre sented in the attachments are the combined (primary and secondary ) emissions from our Potlines.

If you have any questions about the attachments or need anymore information please let me know.

Best regards,

Brandon Coomes Environmental Engineer

9404 State Route 2096, Robards, KY 42452

T: +1 (270) 521-7454 M: +1 (270) 860-0057 F: +1 ( 270) 521-7455 brandon.coomes@centuryaluminum.com http://www.sebreeworks.com

From: Putney, David [ mailto:putney.david@epa.gov ]
Sent: Monday, September 16, 2013 1:38 PM
To: Coomes, Brandon
Cc: Carroll, Danny Subject: RE: TF emissions data

Hello Brandon,

No problem – and no apologies needed. I had seen th e headlines about Century buying your facility but it just never “clicked” in my mind that this could very lik ely result in a change in contact information (not location, probably not phone number, but very likely email ad dress).

Anyway, thanks for your efforts on my behalf. I’ll look for the information later this week.

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.govp. 2 of 3

From: Coomes, Brandon [ mailto:Brandon.Coomes@centuryaluminum.com ] Sent: Monday, September 16, 2013 1:47 PM
To: Putney, David
Cc: Carroll, Danny Subject: RE: TF emissions data

Hello David,

I apologize for not notifying you of my email addre ss change. I totally forgot that the ICR had my ol d contact information.

It will be no problem for me to provide you our TF emissions from out potlines. I’ll try to get this data to you by Wednesday.

Best regards,

Brandon Coomes Environmental Engineer

9404 State Route 2096, Robards, KY 42452

T: +1 (270) 521-7454 M: +1 (270) 860-0057 F: +1 ( 270) 521-7455 brandon.coomes@centuryaluminum.com http://www.sebreeworks.com

From: Putney, David [ mailto:putney.david@epa.gov ] Sent: Monday, September 16, 2013 12:35 PM
To: Coomes, Brandon Subject: FW: TF emissions data

Hey Brandon,

Let me try this again. Also, I noticed that my prev ious email should have been more specific. What I a m looking for is TF emissions (primary and secondary) from th e potlines. Emissions from the carbon bake are low and probably not significantly impacting the risk estim ates and TF emissions are not expected from the pas te plant.

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.govp. 3 of 3

From: Putney, David Sent: Monday, September 16, 2013 11:18 AM
To: 'brandon.coomes@riotinto.com' Subject: TF emissions data

Hello Brandon,

We (EPA) are finishing up our review of the emissio ns test results you submitted in response to the Information Collection Request (ICR) sent out in Ma rch of 2013. Thank you so much for the time and eff ort you dedicated to conducting those tests and submitting the results. The next step in the residual risk ana lysis is to develop the risk modeling files for your facility. It is essential that we use the best, most accurate estimates of your facility’s emissions in these files so as to m ost accurately estimate the residual risk from your facility (i.e., the risk remaining after application of the MACT st andards). Through the 2013 ICR we have obtained rec ent, reliable data for emissions of metals and POM from the primary aluminum industry.

However, we did not collect TF data via the 2013 IC R. Since TF affects the multipathway risk assessmen t, the ecological risk assessment, and the acute risk asse ssment a reduction in the estimates of emissions of that pollutant can have a significant impact on the esti mate of residual risk associated with your facility

.

With that in mind, I am asking for some recent data on TF emissions from your facility (e.g., from NES HAP compliance reports). If possible, could you please send me some data (a summary table of values cited in NESHAP compliance reports) for a few recent, repres entative TF emission rates for your facility by COB this Friday (09/20/13)? This data would allow me to avoi d using the emission rates allowed under the NESHAP to estimate your TF emissions (which would likely over estimate your facility’s TF emissions and the assoc iated risks).

Thanks so much,

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