p. 1 of 4 

From: Van Der Meyden, Henk [mailto:Henk.VanDerMeyden@alcoa.com] 

Sent: Thursday, April 02, 2015 8:27 AM 

To: Putney, David 

Subject: RE: RE: Comments on Primary Aluminum NESHAP 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. Regarding your 3rd 

question from 3/26, the Wenatchee facility has one operating Potline 

where they do not have a M14 manifold or cassette sampling system. 

They use an HF CEM to measure secondary emissions from 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 NESHAP 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 tomorrow (Thu, 

04/02/15) until 1:00 pm, all day Fri (04/03/15) except 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 other 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.VanDerMeyden@alcoa.com] 

Sent: Wednesday, April 01, 2015 10:20 AM 

To: Putney, David 
p. 2 of 4 

Subject: RE: Comments on Primary Aluminum NESHAP supplemental 

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 

This email and any attachments are intended only for use by the 

addressee(s) named, and may contain legally privileged and/or 

confidential information. If you are not the intended recipient of 

this email, or believe you have received this email in error, please 

immediately notify me at (843) 296-3359 or via response email, and 

permanently delete the original and any copy of the email and 

attachments. 

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 supplemental 

proposal 

Mike/Henk, 

I was recently analyzing some of the comments submitted by Alcoa, 

Inc. (dated 02/05/15 and 02/06/15) in response to the supplemental 

proposal for RTR amendments to the NESHAP for Primary Aluminum 

Reduction Plants (published in the FR on 12/08/14) and have come 

across some 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 item 5.0 

“The PM emission limit for existing anode bake furnaces is not 

achievable in practiced and needs to be recalculated in consideration 

of additional data and data corrections” (found on pages 4 through 6 

of your comments dated 02/05/15) and in the addendum to comments, 
p. 3 of 4 

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 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 differ in that we included 

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

whereas you included 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). 

Second, I am requesting additional information regarding the PM 

emissions from the anode bake furnace at the Intalco facility. My 

records indicate that the anode bake furnace at the Intalco facility 

is controlled via a dry alumina scrubber, which would include 

baghouse controls. However, the emissions data for that emission 

source include individual runs as high as 0.82 lb PM/ton anode and as 

low as 0.03 lb PM/ton anode – a ratio of about 27 times. This is 

surprising variability in PM emissions from a source controlled via a 

baghouse. Further, the average PM emissions from this anode bake 

furnace (0.273 lb PM/ton anode) are about 4 times higher 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 paragraph). 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 fundamental difference in 

the control technologies used? Or perhaps some difference in raw 

materials? 

Third, I am requesting additional information regarding the 

monitoring of secondary potline emissions of existing potlines, as 

mentioned in item 9.0 “The proposed initial compliance dates do not 

provide sufficient time to achieve compliance” (found on pages 11 and 

12 of your 02/05/15 comments). Specifically, on page 12 of your 

comments you state, in part, that “[t]o our knowledge, at least one 

facility will be required to install a Method 14 manifold or Method 

14A cassette system in a currently operating potline for collecting 

roof monitor samples to determine emissions of PM and POM.” This was 

a shock to me as it was my understanding that all potlines had either 

a manifold or a cassette system already installed since all potlines 

are required to monitor TF emissions under the current subpart LL. 

Were you referring to the Intalco facility which monitors roof 

emissions after the wet roof scrubbers? If so, it would appear that 

63.849(b) would address that particular situation. Please provide 

information as to how many Alcoa facilities would need to install 

manifold or cassette systems on existing potlines? Also, please 
p. 4 of 4 

provide cost estimates for installation of manifolds 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