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From: Van Der Meyden, Henk [mailto:Henk.VanDerMeyde n@alcoa.com] Sent: Thursday, April 02, 2015 8:27 AM To: Putney, David Subject: RE: RE: Comments on Primary Aluminum NESHA P supplemental proposal

David, I sent a meeting notice for next Wed at 10:00 AM.

I don’t think we’ll be discussion test methods. R egarding your 3rd question from 3/26, the Wenatchee facility has one operating Potline where they do not have a M14 manifold or cassette s ampling system. They use an HF CEM to measure secondary emissions f rom the roof monitor per the requirements of 63.848(d).

Henk

From: Putney, David [mailto:putney.david@epa.gov] Sent: Wednesday, April 01, 2015 5:01 PM To: Van Der Meyden, Henk Subject: EXT: RE: Comments on Primary Aluminum NESH AP supplemental proposal

Henk,

I’m open on Tues (04/07/15) from 8:00 – 9:00 am and from 11:00 am – 2:00 pm and all day on Wed (04/08). I’m also open t omorrow (Thu, 04/02/15) until 1:00 pm, all day Fri (04/03/15) exc ept for 1:30 – 2:30 pm, and all day on Mon (04/06/15). Please let me know what date/time works best for you and who else from EPA I should invite (that is, will be discussing test methods or some o ther specific issue?).

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

From: Van Der Meyden, Henk [mailto:Henk.VanDerMeyde n@alcoa.com] Sent: Wednesday, April 01, 2015 10:20 AM To: Putney, Davidp. 2 of 4

Subject: RE: Comments on Primary Aluminum NESHAP su pplemental proposal

David, We wanted to see if we could discuss the questions and our planned responses. Are you available for a call next Tue ( late morning or late afternoon) or Wed (anytime)?

Thanks,

Henk

Henk van der Meyden, PG

Sr. Environmental Consultant

Alcoa Inc. Cell: (843) 296-3359 henk.vandermeyden@alcoa.com

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From: Putney, David [mailto:putney.david@epa.gov] Sent: Thursday, March 26, 2015 10:44 AM To: Palazzolo, Michael A.; Van Der Meyden, Henk Cc: Matthew Hakos (mhakos@rti.org); David Green Subject: EXT: Comments on Primary Aluminum NESHAP s upplemental proposal

Mike/Henk,

I was recently analyzing some of the comments submi tted by Alcoa, Inc. (dated 02/05/15 and 02/06/15) in response to t he supplemental proposal for RTR amendments to the NESHAP for Prima ry Aluminum Reduction Plants (published in the FR on 12/08/14) and have come across some items for which I am soliciting additio nal information from you.

First, I am requesting additional information conce rning the

additional anode bake furnace emissions data and re vised MACT floor for PM emissions from anode bake furnaces, as menti oned in item 5.0 “The PM emission limit for existing anode bake furn aces is not achievable in practiced and needs to be recalculate d in consideration of additional data and data corrections” (found on pages 4 through 6 of your comments dated 02/05/15) and in the addendu m to comments,p. 3 of 4

dated 02/06/15. After correcting the anode bake fur nace emissions used in the supplemental proposal for the Alcoa-War rick and Century Aluminum-Sebree facilities and including the additi onal emissions data provided, it appears that the MACT floor pool would now include the Massena West, Wenatchee, Warrick, Alumax and Se bree facilities. That is, it would appear that our analyses differ i n that we included the anode bake furnace at the Sebree facility in th e MACT floor pool whereas you included the anode bake furnace at the Intalco facility. Please explain why you included the anode bake furn ace at the Intalco facility (with average emissions, including the add itional data, of 0.273 lb PM/ton anode) in the MACT floor pool inste ad of the anode bake furnace at the Sebree facility (with average e missions, after correcting the data used initially, of 0.112 lb PM/ ton anode).

Second, I am requesting additional information rega rding the PM

emissions from the anode bake furnace at the Intalc o facility. My

records indicate that the anode bake furnace at the Intalco facility is controlled via a dry alumina scrubber, which wou ld include baghouse controls. However, the emissions data for that emission source include individual runs as high as 0.82 lb P M/ton anode and as low as 0.03 lb PM/ton anode – a ratio of about 27 t imes. This is surprising variability in PM emissions from a sourc e controlled via a baghouse. Further, the average PM emissions from th is anode bake furnace (0.273 lb PM/ton anode) are about 4 times h igher than the average of the MACT floor pool sources (0.067 lb PM /ton anode, if we include the Sebree facility in the MACT floor pool as opposed to the Intalco facility, as described in the preceding par agraph). Please provide some information or thoughts as to why the PM emissions from the anode bake furnace at the Intalco facility are so variable and so much higher than those from the anode bake furnaces at the other primary aluminum facilities. Is there some fundamen tal difference in the control technologies used? Or perhaps some diff erence in raw

materials?

Third, I am requesting additional information regar ding the monitoring of secondary potline emissions of existi ng potlines, as mentioned in item 9.0 “The proposed initial complia nce dates do not provide sufficient time to achieve compliance” (fou nd on pages 11 and 12 of your 02/05/15 comments). Specifically, on pag e 12 of your comments you state, in part, that “[t]o our knowled ge, at least one facility will be required to install a Method 14 ma nifold or Method 14A cassette system in a currently operating potlin e for collecting roof monitor samples to determine emissions of PM a nd POM.” This was a shock to me as it was my understanding that all p otlines had either a manifold or a cassette system already installed s ince all potlines are required to monitor TF emissions under the curr ent subpart LL. Were you referring to the Intalco facility which mo nitors roof emissions after the wet roof scrubbers? If so, it w ould appear that 63.849(b) would address that particular situation. Please provide information as to how many Alcoa facilities would n eed to install manifold or cassette systems on existing potlines? Also, pleasep. 4 of 4

provide cost estimates for installation of manifold s and cassette systems.

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