p. 1 of 4 

From: Bruntz, Samuel H. [mailto:Samuel.Bruntz@alcoa.com] 

Sent: Thursday, January 02, 2014 6:03 PM 

To: Putney, David 

Cc: Palazzolo, Michael A. 

Subject: RE: Draft emissions file for the Alcoa primary aluminum facilities 

David, 

You will find attached the Alcoa Warrick revised emissions 

file. No changes were made to the non-category emission 

sources. The primary aluminum category file was amended by 

adding two potrooms which did not appear in your draft. In 

addition, potlines 3 and 4 exhaust through a common stack. 

The stack parameters reflected the airflow for 2 potlines, 

but emissions from only 1 potline. I thus doubled the 

emissions for the source Id 162 stack, amended its 

description to potlines 3 and 4, and deleted source ID 163. 

Let me know if you have any questions. 

Thanks, 

Sam Bruntz 

Sr. Staff Environmental Engineer 

Alcoa Inc. – Warrick Operations 

(812) 853-1519 

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

Sent: Wednesday, December 18, 2013 8:33 AM 

To: Palazzolo, Michael A.; Bruntz, Samuel H.; Dobbs, Charles L.; Hulse, David G.; Parent, Jordan J.; 

Mitchell, Kathryn M; Rufa, Nathan P.; Bilskis, Patricia A.; Blodgett, Terry L. 

Subject: EXT: 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. 
p. 2 of 4 

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 
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(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). 

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? 
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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