From: Putney, David 

Sent: Monday, March 25, 2013 4:25 PM 

To: 'Van Der Meyden, Henk' 

Cc: Palazzolo, Michael A. 

Subject: RE: Request for Approval of Previous Emissions 

Test Data - Potline PM and POM - Alumax of South Carolina, 

Inc. 

Mr. van der Meyden, 

According to the methods folks over here the submitted 

potline primary and secondary POM emissions data appears to 

be acceptable. However, since your facility is required to 

conduct metal HAP testing on a potline, you are required to 

conduct a new set of PM tests. That is, we require that the 

PM tests be run simultaneous with the metal HAP tests. 

Also, in order to ensure consistency between facilities 

that sample secondary potline emissions from manifolds and 

those that use cassettes, we are requiring sampling of 

secondary potline emissions at, or near, ambient conditions 

- see item number 7 in the attached FAQ document (this FAQ 

document has been sent to the contractor to be added to the 

primary aluminum RTR website, but I do not believe it has 

been posted yet). 

Thanks, and please feel free to contact me with any

comments/concerns/questions. 

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

1 
Primary Aluminum 2013 ICR

Frequently Asked Questions

1. Is there any flexibility associated with the requirement, in Section 4.0 of Enclosure 1, that a 

facility notify their regulatory agency of associated testing 60 days prior to the testing?

Yes. The subject text includes the caveat that an alternative date is acceptable provided that it is 

approved by the appropriate associated regulatory agency.

2. Is a quartz fiber filter acceptable for conducting EPA Method 315 sampling?

You may use glass or quartz fiber filters while conducting EPA Method 315 sampling, as long as 

the filter meets the other requirements of Section 7.1.1 of EPA Method 315.

3. The EPA Method 14A cassettes that are used by industry to sample secondary potline emissions 

(i.e., for those potlines that are not equipped with manifolds) will not accommodate a standard 

EPA Method 315 filter. Is it acceptable to modify the filter to fit into the cassette?

Yes. We realize that the standard EPA Method 315 filter may not fit into the EPA Method 14A 

cassette. You may cut the filter to fit the cassette. Please keep in mind that the filter should be 

weighed after cutting and prior to insertion into the cassette.

4. How can the tester use EPA Method 315 to sample with an EPA Method 14A cassette?

The tester should use a filter meeting the requirements of EPA Method 315 and analyze the 

results using EPA Method 315. The filter should be set up in the EPA Method 14A cassette 

(cutting to fit, if necessary) for the sample.

5. EPA Method 315 involves analyzing a sample for both polycyclic organic matter (POM) and 

total filterable particulate matter (PM). Is PM data obtained from the EPA Method 315 test 

acceptable in lieu of data obtained from an EPA Method 5 test in cases where a facility is 

required to test a source for POM and PM?

Yes, you may use the total filterable PM data from EPA Method 315 in these cases.

6. Will the EPA allow the use of EPA Method 306 to determine emissions of hexavalent chromium, 

as opposed to SW-846 Method 0061 as specified in the draft ICR?

The EPA will consider this only if you have empirical data for your facility showing that EPA 

Method 306 does not convert the hexavalent chromium during sampling. Measuring hexavalent 

chromium accurately is difficult because it can convert to other forms of chromium in the sample 

train. That is the primary reason why SW-846 Method 0061 was developed. SW-846 Method 

0061 has procedures in place, which EPA Method 306 does not have, to ensure that hexavalent 

chromium is not converted during sampling.

7. The testing ICR specifies use of EPA Methods 17 and 29 for secondary potline emissions of PM 

and metal HAP and EPA Methods 17 and 315 for secondary potline emissions of PM and POM 

from facilities equipped with manifold systems (see Table 1.2). Is this accurate? Does the tester 

need to use both an in-stack and out of stack filter?

In order to maintain consistency of emissions data between facilities with permanently installed 

manifold systems and those that utilize roof cassettes, we have required the use of EPA Method 

17, in lieu of EPA Method 5, with EPA Methods 29 and 315. The cassettes will be sampled at 

ambient, or near ambient, conditions and cannot be temperature controlled to the 248°F (±25°F) 

required by EPA Methods 5, 29, and 315. Therefore, we are requesting that the manifolds also be 

sampled at ambient conditions. However, it was not our intent to require an in-stack filter in 
addition to the EPA Method 29 or 315 filter. Our intent was only to require the ambient sampling 

procedures of EPA Method 17, i.e. the probe and filter holder should not be heated.

8. For sources located in arid climates, how can the tester deal with the loss of impinger solutions

from the EPA Method 29 train?

If a facility is located in an arid climate, and evaporation of impinger solution is known to be a 

major issue, you may add a third nitric acid/hydrogen peroxide impinger to the train. However, 

this should only be done in extreme cases and must be fully documented in the test report.

9. Those primary aluminum reduction facilities which are currently required to demonstrate 

compliance with a polycyclic organic matter (POM) standard in 40 CFR Part 63, Subpart LL 

(i.e., the NESHAP for primary aluminum reduction facilities) are prohibited from including 

emissions data collected during the installation and startup of a cathode in that demonstration 

(refer to 40 CFR §63.847(e)(2)). Does that prohibition against including emissions data collected 

during the installation and startup of a cathode apply to POM sampling associated with the 

testing ICR dated March 4, 2013?

Yes. For purposes of the testing ICR dated March 4, 2013, you should avoid collecting POM 

emissions data during the installation and startup of a cathode.