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From: Putney, David

Sent: Wednesday, December 18, 2013 9:33 AM

To: Palazzolo, Michael A.; Bruntz, Samuel H.; Charles L. Dobbs; David G. Hulse; Jordan J. Parent; Kathryn M. Mitchell; Nathan P. Rufa; Patricia A. Bilskis; Terr y L. Blodgett Subject: Draft emissions file for the Alcoa primary aluminu m facilities

Hello Mike et. al.,

Please find attached to this message a draft emissi ons file (Excel spreadsheet) for the Alcoa, Inc. pr imary aluminum production facilities. Columns highlighte d in yellow are available for revisions or to indic ate if

records should be deleted. Please do not overwrite the data in columns that are not highlighted in ye llow as this would complicate the development of the final emissions file for use in risk modeling.

The tab titled “primary al category12172” includes emissions from the primary aluminum production operations (e.g., potlines, paste plants, pitch sto rage tanks, and anode bake furnaces) at the Alcoa f acilities as estimated via emission factors developed from test results obtained in response to the testing ICR sen t out in April of 2013. I expect that the stack parameters a re correct as-is since industry previously had oppo rtunity to

review those items in CY2010 before the initial res idual risk and technology review (RTR) proposal for the primary aluminum production source category. There are, however, some emissions (e.g., metal HAP, diox ins, 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 h ighlighted in yellow is provided for you to revise emissions (in units of tons per year, tpy) if needed.

The tab titled “noncategory” includes 2005 NATA NEI , 2008 NEI and 2010 state HAP data for the Alcoa, I nc. primary aluminum production facilities (note that w e did not find any non-category emissions data for either the Intalco facility or the Wenatchee facility). Th ese 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, discus sed above) or secondary aluminum production (second ary aluminum emissions will be addressed via the RTR as sociated with the secondary aluminum source categor y). Revision columns highlighted in yellow are included for emissions, pollutants, stack parameters, fugit ive parameters and latitude/longitude. If any of these parameters needs modification, please put the corre cted value in the associated revision column (again, ple ase do not overwrite the data in columns that are n ot highlighted in yellow). Note that fields were also added to identify if a record should be deleted, a nd 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 pe rmit 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 operati on and associated emissions need not be included (so as to avoid double counting those emis sions).2 of 2 c. If the operation does exist at the facility, would the emissions from this operation be considered part of the monitored primary aluminum e missions? For example, if the emissions associated with the operation in question are route d 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 incl uded (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 em issions in units of tons emitted per year (tpy).

4. Verify or modify the stack parameters and location as appropriate and necessary.

If I might make a suggestion – you can use the filt er function in Excel to narrow down the file to rev iew a single facility at a time.

Mike – I do not have any information for a contact at the Lake Charles facility. Would you please pass this email and attachment along to someone at that facil ity that could review this information? Also, would you please forward me that person’s contact information ?

Please provide any comments, changes, corrections, etc. to this file to me by close of business on Fri day, 01/03/14. I understand that more time might be pref erable with the holidays upon us, but please give m e 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 c omment 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 telephon e.

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