1 of 2 

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; Terry L. Blodgett 

Subject: Draft emissions file for the Alcoa primary aluminum facilities 

Hello Mike et. al., 

Please find attached to this message a draft emissions file (Excel spreadsheet) for the Alcoa, Inc. primary 

aluminum production facilities. 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 risk modeling. 

The tab titled “primary al category12172” includes emissions from the primary aluminum production 

operations (e.g., potlines, paste plants, pitch storage tanks, and anode bake furnaces) at the Alcoa facilities as 

estimated via emission factors developed from test results obtained in response to the 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 CY2010 before the initial residual risk and technology review (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. 

The tab titled “noncategory” includes 2005 NATA NEI, 2008 NEI and 2010 state HAP data for the Alcoa, Inc. 

primary aluminum production facilities (note that we did not find any non-category emissions data for either 

the Intalco facility or the Wenatchee 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). 
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 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. 

If I might make a suggestion – you can use the filter function in Excel to narrow down the file to review 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 facility 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 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