p. 1 of 2 

From: Curt Wells [mailto:cwells@aluminum.org] 

Sent: Thursday, April 02, 2015 3:09 PM 

To: Putney, David; Charles D. Johnson 

Subject: RE: Comments on Primary Aluminum NESHAP supplemental 

proposal 

David – 

In answer to your second question below, please see the attached 

matrix which details the status of PP and BF stack continuous 

particulate matter monitoring systems at Association member 

facilities. As you will see, the matrix identifies 53 additional 

stacks at member facilities that would need PM monitoring as these 

were not included in the 388 potline stacks noted in the 

Association’s 2/6/15 comments as requiring monitoring. 

Please also note that the attached matrix does not include Century 

facilities as they are not members of the Association and are 

therefore outside the scope of your request. 

As regards question #1, I look forward to talking with you regarding 

it next Wednesday 4/8 on the call already scheduled with Alcoa 

personnel. 

Please let me know if you have any questions. 

Thanks. 

Curt. 

From: Putney, David [mailto:putney.david@epa.gov] 

Sent: Friday, March 27, 2015 2:41 PM 

To: Charles D. Johnson 

Cc: Curt Wells 

Subject: Comments on Primary Aluminum NESHAP supplemental proposal 

Chuck, 

I was recently analyzing some of the comments submitted by The 

Aluminum Association (dated 02/06/15) in response to the supplemental 

proposal for RTR amendments to the NESHAP for Primary Aluminum 

Reduction Plants (published 12/08/14) and have come across two items 

for which I am soliciting additional information from you. 

First, I am requesting additional information concerning the 

additional anode bake furnace emissions data and revised MACT floor 

for PM emissions from anode bake furnaces, as mentioned in Issue #5 

“Errors in the Existing Anode Bake Furnace PM Limit Calculation” 

(found on pages 5 through 7 of your comments dated 02/06/15). After 

correcting the anode bake furnace emissions used in the supplemental 

proposal for the Alcoa-Warrick and Century Aluminum-Sebree facilities 
p. 2 of 2 

and including the additional emissions data provided, it appears that 

the MACT floor pool would now include the Massena West, Wenatchee, 

Warrick, Alumax and Sebree facilities. That is, it would appear that 

our analyses of the new data differ in that we would include the 

anode bake furnace at the Sebree facility in the MACT floor pool 

whereas you include the anode bake furnace at the Intalco facility. 

Please explain why you included the anode bake furnace at the Intalco 

facility (with average emissions, including the additional data, of 

0.273 lb PM/ton anode) in the MACT floor pool instead of the anode 

bake furnace at the Sebree facility (with average emissions, after 

correcting the data used initially, of 0.112 lb PM/ton anode). In an 

effort to not request duplicate effort from industry I would point 

out that I also posed this question to Alcoa, Inc. staff who had 

submitted a similar comment – The Aluminum Association may want to 

consider a coordinated response with Alcoa to this question. 

Second, I am requesting additional information concerning the current 

monitoring of PM emissions from baghouses installed on anode bake 

furnaces or paste production plants, as mentioned in Issue #14 

“Installation of Continuous Bag Leak Detection Systems” (found on 

pages 17 through 20 of your comments dated 02/06/15). Specifically, 

in paragraph 4 on page 19 you imply that the baghouses associated 

with anode bake furnaces and paste production plants at primary 

aluminum production facilities would need to be equipped with bag 

leak detection systems (BLDS) or particulate matter continuous 

emissions monitoring systems (PM CEMS) in order to comply with the 

proposed revisions to the Primary Aluminum NESHAP. I was under the 

impression that most, if not all, of the baghouses associated with 

existing anode bake furnaces and paste production plants at primary 

aluminum production facilities were already equipped with either BLDS 

or PM CEMS. Would you please poll the facilities in your association 

and provide me information on how many of the baghouses associated 

with existing anode bake furnaces and paste production plants at 

primary aluminum production facilities are not already equipped with 

either BLDS or PM CEMS? 

Thanks so much for your assistance in these matters. 

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 
Aluminum Association Member

Primary Plant PP and BF stack survey

4/2/2015

Location # of PP Stacks # Equipped with BLD's # BF Stacks # Equipped with BLDs

Massena 1 1 1 1

Warrick 1 1 7 7

Wenatchee 1 0 16 0

Intalco 1 0 1 0

New Madrid* 1 0 33 0

Total 5 2 58 8

Total # of stacks without BLD's 53

* New Madrid has 3 bake furnaces. Bake furnaces 1 and 2 are controlled by 4 scrubbers that have 4

modules each. Each module has 4 stacks but a BLD on one of the 4 stacks in the module would detect a 

leak anywhere in that module so 32 BLD's would be needed for bake furnaces 1 and 2 (2 x 4 x 4). Bake 

furnace 3 has all modules ducted to a common stack so 1 BLD would be needed for it resulting in the need 

for 33 total.