UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION 2 

290 Broadway 

New York, NY 10007-1866 

March 9, 2009 

Mr. Robert Lenney 

Environmental Health and Safety Modernization Manager 

Alcoa Massena Modernization Project 

Park Avenue East, PO Box 150 

Massena, New York 13662 

Re: Alcoa Massena Modernization Project 

 Request for a Single Source Determination 

Dear Mr. Lenney: 

This is in response to Alcoa Inc.’s October 20, 2008 request for a single source 

determination and PSD nonapplicability determination for the Massena East and Massena 

West Plants whose individual property lines are separated by approximately 3.4 miles in 

Massena, New York. This request was augmented by a subsequent submittal dated 

December 2, 2008. For the reasons noted below, EPA has determined that the Massena 

East and West Plants can be considered a single source for purposes of PSD/NSR 

applicability. The issues pertaining to your PSD nonapplicability request will be 

addressed in a separate letter. 

Background 

Alcoa is proposing to modernize their Massena East and Massena West aluminum 

smelter facilities located in New York. The East and West Plant have historically been 

managed as two distinct and separate operating entities. The West Plant has always been 

owned and operated by Alcoa Inc. The East Plant was previously owned and operated by 

the former Reynolds Metals Company. In 2000, Alcoa Inc. acquired the Reynolds Metals 

Company, now a wholly-owned subsidiary of Alcoa Inc. The improvements for the 

proposed modernization include: 

1) At Massena East --- replacing the Soderberg potline with a modern 

technology pre-bake potline. Among the physical changes include the 

shutdown and removal of the following: the anode pin room, the carbon 

plant, the cathode digging, and three alumina/coke conveyance units. New 

units to be constructed include an anode cooling process, a new cruce 

augering, four new bath filling areas, a bath storage silo transfer point, and 

an aluminum fluoride filling area. No changes will be made to the existing 

boilers at the East Plant. Under this proposed modernization project some 

existing units will be “debottlenecked.” 
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2) At Massena West --- increasing the throughput of the anode manufacturing 

facility to supply the needs of the new potline at Massena East as well as the 

existing potline at Massena West. Also, the Massena West Plant will be 

adding metal processing capacity to facilitate the processing of the new 

additional metal production from both the East and West smelters. Among 

the physical changes include the removal of three existing homogenized 

heat treat furnaces. Units to be constructed include 7 new homogenized heat 

treat furnaces, 3 new molten aluminum melting and holding furnaces, 3 new 

in-line filterbox fluxing units. Under this proposed modernization project 

some existing units will also be “debottlenecked.” There will be no changes 

made to the existing boilers at the West Plant except for an increase in load 

demand (debottlenecked). The annual aluminum production at the West 

Plant will increase from an average of 141,998 tons/year to 160,040 

tons/year. 

 The Massena West Plant is located adjacent to the Massena Power Canal in the Village of 

Massena. The Massena East Plant property line is located approximately 3.4 miles east 

of the Massena West Plant property line in Rooseveltown. Alcoa has indicated that after 

the company purchased the East Plant in 2000 its efforts focused on increasing the 

synergies between the two plants to create one Alcoa facility in Massena, NY. According 

to Alcoa, after the proposed modernization is completed, they will be shipping 

intermediate baked anode products and bath from the West Plant to the East Plant at a 

rate of approximately 72 trucks per day and they will also be shipping hot metal from the 

East Plant to the West Plant at a rate of approximately 50 hot crucible trucks per day. 

Furthermore, Alcoa also states that the operations manager is responsible for both 

facilities, as are most of the other support departments, including the environmental 

health and safety, accounting, purchasing, information technology, human resources, and 

security departments. In addition, according to Alcoa, the employees of these 

departments will be travelling between the two plants to perform their jobs. Therefore, 

Alcoa is requesting that, for the purpose of PSD applicability assessment, the East and 

West Plants be viewed as a single source following the modernization project. 

Discussion 

The federal definitions under 40 CFR 52.21 apply. 40 CFR Part 52.21(b)(5) defines a 

stationary source as: 

...any building, structure, facility, or installation which emits or may emit any air 

pollutant subject to regulation under the Act. 

Furthermore, 40 CFR Part 52.21(b)(6) defines a building, structure, facility or 

installation, in pertinent part, as: 

...all of the pollutant-emitting activities which belong to the same industrial 

grouping, are located on one or more contiguous or adjacent properties, and are 
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under the control of the same person (or persons under common control) except 

the activities of any vessel. Pollutant-emitting activities shall be considered as 

part of the same industrial grouping if they belong to the same “Major Group” 

(i.e., which have the same first two digit code) as described in the Standard 

Industrial Classification Manual, 1972, as amended by the 1977 Supplement.... 

Common Control

Because both the Massena East Plant and the Massena West Plant are owned and 

managed by Alcoa Inc., and share the same plant management team and departmental 

personnel, these two facilities are under common control. 

Industrial Grouping 

Both the East and West Plants are under the same industrial grouping with a Standard 

Industrial Classification code of 3334 – Primary Aluminum. 

Contiguous/Adjacent Location

Over the years, EPA has issued guidance in a number of cases regarding the question of 

whether two facilities should be considered contiguous or adjacent. There is no bright 

line, numerical standard for determining how far apart activities may be and still be 

considered “contiguous” or “adjacent.” As explained in the preamble to the August 7, 

1980 PSD rules, such a decision must be made on a case-by-case basis. Moreover, in 

further explaining this factor, EPA has noted that whether or not two facilities are 

adjacent depends on the “common sense” notion of a source and the functional interrelationship of the facilities and is not simply a matter of the physical distance between 

the two facilities. However, the physical distance between two facilities is obviously a 

factor to be considered in deciding whether the two are close enough to be considered 

one source in a given situation. 

Although there is no clear physical connection via a pipeline or dedicated conveyance 

between the East and West Plants, their property lines are separated by approximately 3.4 

miles. This distance is consistent with previous Agency single source determinations 

where additional factors were present suggesting that the plants were contiguous or 

adjacent. In this case, the proposed operation after the modernization, as described by 

Alcoa, will involve considerable trucking of materials between the two plants and sharing 

of personnel. In addition, Alcoa has indicated that their intention since purchasing the 

second plant has been to focus on increasing the synergies between the two plants to 

create one Alcoa facility in Massena, NY. Therefore, there appears to be a functional 

inter-relationship between the two plants’ operations. 

In this particular case, EPA has weighed the information before it and concluded that, 

given the totality of the circumstances, the two facilities should be considered contiguous 

or adjacent for purposes of PSD/NSR. Note that no single factor leads us to this 

conclusion and EPA retains all of its enforcement authorities under the Clean Air Act if 
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Alcoa’s operates in a manner different from what has been represented to the Agency. 

Conclusion

Based on all of the above factors, we have concluded that Alcoa Inc.’s Massena East 

Plant and Massena West Plant do meet the “common sense” notion of a single source and 

that they should be treated as one facility for purposes of PSD and NSR applicability 

determination. This letter is not a final agency action on the part of EPA. 

If you have any questions, please call me at (212) 637-4074 or Mr. Frank Jon, of my 

staff, at (212) 637-4085. 

Sincerely yours, 

 / s / 

Steven C. Riva, Chief 

Permitting Section 

Air Programs Branch 

cc: Gary Keating, ERM 

bcc: Frank Jon, 2DEPP-APB 

 Joseph Siegel, ORC-Air 

 Kristi Smith, OGC 

 Air Chron, ORC-Air 

 File 3A