### 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 Emiss ions
Test Data - Potline PM and POM - Alumax of South Ca rolina,

Inc.

Mr. van der Meyden,

According to the methods folks over here the submit ted potline primary and secondary POM emissions data ap pears to be acceptable. However, since your facility is requ ired to conduct metal HAP testing on a potline, you are req uired to conduct a new set of PM tests. That is, we require that the
PM tests be run simultaneous with the metal HAP tes ts. Also, in order to ensure consistency between facili ties that sample secondary potline emissions from manifo lds and those that use cassettes, we are requiring sampling of secondary potline emissions at, or near, ambient co nditions - see item number 7 in the attached FAQ document (t his FAQ
document has been sent to the contractor to be adde d 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 th e 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 em issions (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?

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

cassette

. You may cut th e 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 a n EPA Method 5 test in cases where a facility is required to test a source for POM and PM?

Y es, y ou 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 em issions 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 sampl ing. Measuring hexavalent
chromium accurately is diffic ult 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 i s 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 Method s 29 and 315

. The ca ssettes will be sampled at ambient , or near ambient, conditions and cannot be temperature controlled to the 248°F (±25°F) required by EPA Method s 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 inaddition to the EPA Method 29 or 315 filter. Our intent was only to require the ambient sam pling

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

8. For sources located i n 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 a cid/hydrogen p eroxide 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 polyc yclic 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 (re fer 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.