p. 1 of 7 

From: Putney, David 

Sent: Thursday, August 01, 2013 5:23 PM 

To: 'Backfisch Don (NORALNM)' 

Subject: RE: ICR data 

Don, 

It would be preferable to get a corrected report and spreadsheets since those items will eventually be added 

to the docket for this rulemaking action. That is, it would probably better to simply put the corrected versions 

in the docket as opposed to the originals with additional documents to show corrections. Also, I agree with 

your approach of addressing all the issues before resubmitting the report. However, it would be good to know 

the answers to my questions when you get the information. That is, please inform me of the lab’s response 

when you get it – as opposed to waiting until the revised report is completed. 

I actually have a follow up comment/question to my email from yesterday. Based on a quick review of the 

secondary potline PCB emissions (presented in Table 2-4 of the final report), it appears that those emissions (in 

units of lb/hr) are based on the downcomer flow rate (as opposed to the roof vent flow rate). For example, 

when I attempted to reproduce the Mono PCB emissions associated with run 1 on the roof 2 duct, I came up 

with emissions values of 1.65 E-04 lb/ton and 1.71 E-03 lb/hr. These match the values in your summary 

spreadsheet but not the lb/hr emission value in Table 2-4 of the Final Report. However, the lb/hr emission rate 

for Mono PCB does match if I use the downcomer flow rate instead of the roof vent flow rate. This could be a 

source of confusion during the public comment period. You may want to either modify the table in the report 

to clarify that the lb/hr values are based on the downcomer flow rates, or modify the emissions values to 

represent emissions based on roof vent flow rates. 

Also, as mentioned in my previous email, the reported PCB emissions values appear to be overestimated by a 

factor of 1,000 as a result of the lab reporting their results in units of picograms (pg) but those results being 

changed to units of nanograms (ng) in the spreadsheets and Final Report tables. (See for example, the mass 

value for Mono PCBs from run 1 on the roof 2 duct – cited as 250 ng in the spreadsheets and Table 2-4 in the 

Final Report as opposed to 250 pg as shown in the lab data on page G-149 of the report). This would certainly 

be something that should be revised before putting the document in the docket. 

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: Backfisch Don (NORALNM) [mailto:Don.Backfisch@noralinc.com] 

Sent: Wednesday, July 31, 2013 1:22 PM 

To: Putney, David 

Subject: RE: ICR data 
p. 2 of 7 

I have contacted our contractor to get your questions answered. He has forwarded the questions to 

the lab that did the analyses for clarification. Do you want us to update and submit both the 

spreadsheet and the final report? I don’t know exactly how long it will be before we have the 

response from Clean Air, but I will pass the information on to you as soon as I can. If acceptable to

you, we will probably wait until we have answered all your questions about the data before 

resubmitting the corrected final report. 

Don Backfisch 

From: Putney, David [mailto:putney.david@epa.gov] 

Sent: Wednesday, July 31, 2013 9:41 AM 

To: Halford Nancy (NORALNM) 

Cc: Robuck, Steve (NORALINC); Jones Mark (NORALNM); Backfisch Don (NORALNM) 

Subject: RE: ICR data 

Nancy, 

I have done a quick review of the ICR data submitted for the Noranda primary aluminum facility in New 

Madrid, MO, and have a few comments and questions for you and the testing/lab contractors. Note that in the 

discussions below, unless otherwise specified, please refer to page G-124 of the lab data (see page 626 of 748 

in the pdf Final Report) when discussing dioxin/furan (D/F) data and refer to page G-165 of the lab data (see 

page 667 of 748 in the pdf Final Report) when discussing polychlorinated biphenyl (PCB) data as “typical” 

examples. These data are for run 1 on the paste plant. 

• Some of the target analytes are flagged with an “R” which, according to the footnotes in the lab report, 

indicates that the ion abundance ratio for the compound in question did not meet the acceptance 

criterion. These flags occur in both the PCB and D/F analyses, but are more common in the D/F 

analyses. I need assistance in interpreting the concentration values associated with the analytes 

flagged with an R. How were data flagged with an R handled by the lab? How was the data used in 

interpreting the analyte concentrations? (i.e. What value was used when calculating concentrations?) 

• I need help interpreting the concentration values associated with the analytes that are flagged with a

“J” (which, according to the footnotes in the lab report, indicates that the analyte was detected below 

the calibrated range) but which have listed concentrations well above the listed EDL. For example, for

Total MonoCB – which is flagged with a J on page G-165 of the final report - the EDL is listed as 24 

picograms (pg) whereas the listed concentration is 2400 pg. 

• The concentration values associated with the analytes that are flagged with both “J” and “R” are listed 

in the spreadsheets as below detection limit (BDL). See for example OCDD (flagged with J and R in the

lab report and listed as BDL in the D/F portion of the associated Excel spreadsheet PrAl_ICR_ 

PastePlant.xls). Why are these data marked as BDL when they were analyzed above the MDL? Data 

that is flagged with only a J is not marked as BDL. This is what we would expect; we would expect only 

U flagged data to be marked BDL. 

• The material throughput rates listed in the Final Report do not always agree with those listed in the 

summary spreadsheets. For example, Tables 2-13, 2-19, 2-23, and 2-28 list throughput rates of 10.33 

tons per hour for potline 2, 6.30 tons per hour for potline 3 (listed as 161 duct), 7.79 tons per hour for 

carbon bake, and 33.7 for paste plant, respectively. However, the PCB summary spreadsheet for 

potline 3 (again, listed as 161 duct) lists a throughput of 7.79 tons per hour. Please confirm the 
p. 3 of 7 

material throughput rates for the tested potlines, the carbon bake furnace and the paste plant during 

the testing. 

• The carbon bake furnace and the paste plant summary spreadsheets indicate throughput materials of 

aluminum as opposed to the expected material of green anode. Please confirm the throughput 

materials for the carbon bake furnace and the paste plant and whether the pounds per ton emissions 

rates cited in these spreadsheets are in units of pounds of pollutant per ton of aluminum produced or 

pounds of pollutant per ton of green anode processed. 

• Specifically regarding the PCB analyses - I notice that although the lab reports cite values of PCB in 

units of pg, those values were listed in the associated summary spreadsheets in units of nanograms 

(ng). That is, for example, the lab results indicate 2,400 pg of total monochlorinated 

biphenyls whereas the PCB portion of the associated spreadsheet (PrAl_ICR_PastePlant.xls) indicates 

2,400 ng of total monochlorinated biphenyls. This would appear to have caused an overestimation of 

PCB emissions from your facility by a factor of 1,000. Please confirm or modify, as appropriate, the PCB 

emissions values cited in the summary spreadsheets.

• Specifically regarding the PCB analyses - I notice that for the homologue group totals the EDL is 

sometimes lower than the cited concentration for those homologue groups flagged with a U. For 

example, for the Total OctaCB homologue group (which is flagged as U) the lab report cites a 

concentration of <23 pg (which would suggest a method detection limit of 23 pg) but an EDL of 9.1 pg. 

Please clarify how the EDL is less than the method detection limit for these groups. 

• Specifically regarding the D/F analyses - When the cited mass for a total homologue group is preceded

by a “<” symbol does this indicate below detection limits? I ask because the lab report does not 

provide a “U” flag for these homologue groups. 

Note that my contractor and I have not finished reviewing the report yet, and we may have other questions in 

the future. We are trying to resolve questions as we find them instead of holding them until the end.

 

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: Putney, David 

Sent: Thursday, July 18, 2013 11:00 AM 

To: 'Halford Nancy (NORALNM)' 

Cc: Robuck, Steve (NORALINC); Jones Mark (NORALNM); Backfisch Don (NORALNM) 

Subject: RE: ICR data 

Nancy, 
p. 4 of 7 

I have downloaded the files from the website - thanks so much for this information. My contractor and I will 

analyze this and get back to you with any questions we might have concerning the data. I will look for the CD in 

the mail soon. 

Thanks again, 

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: Halford Nancy (NORALNM) [mailto:Nancy.Halford@noralinc.com] 

Sent: Wednesday, July 17, 2013 6:22 PM 

To: Putney, David 

Cc: Robuck, Steve (NORALINC); Jones Mark (NORALNM); Backfisch Don (NORALNM) 

Subject: ICR data 

The Excel files and the pdf report were uploaded today to the site you mentioned below. I will be sending a CD 

in the mail to you as well. Please let me know if you need anything else. 

Nancy Halford 

Environmental Chemist 

Noranda (NYSE NOR) 

office: 573-643-2361 x2184 

email: nancy.halford@noralinc.com 

website: http://www.norandaaluminum.com

From: Putney, David [mailto:putney.david@epa.gov] 

Sent: Friday, July 12, 2013 1:02 PM 

To: Backfisch Don (NORALNM) 

Cc: Jones Mark (NORALNM); Halford Nancy (NORALNM) 

Subject: RE: CD Received 

Thanks so much for the update. I will look for the updated information next Tuesday. 

Thanks, and have a great vacation. 

David Putney, Environmental Engineer 

U.S. Environmental Protection Agency 

Office of Air Quality Planning and Standards 

Sector Policies and Programs Division 
p. 5 of 7 

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: Backfisch Don (NORALNM) [mailto:Don.Backfisch@noralinc.com] 

Sent: Friday, July 12, 2013 1:37 PM 

To: Putney, David 

Cc: Jones Mark (NORALNM); Halford Nancy (NORALNM) 

Subject: RE: CD Received 

We got an update today from our sampling contractor on the progress of getting our test data 

entered into the spreadsheet as you requested. They are estimating that they won’t have the 

spreadsheet completed until Tuesday, July 16. We will get the data to you as soon as we get 

it from our contractor. We will also be sending a copy of the original report with some minor 

corrections. 

I will be on vacation next week, but Nancy Halford will be the one to receive the data and 

pass it on to you. Her contact information is the same as mine, but her phone extension # is 

2184. Her e-mail address is nancy.halford@noralinc.com. I apologize for the delay in getting 

the data to you.

Don Backfisch 

Environmental Superintendent 

Noranda (NYSE: NOR) 

P. O. Box 70 

New Madrid, MO 63869 

Phone: (573) 643-2361 x2126 

Fax: (573) 643-6721 

Email: don.backfisch@noralinc.com

Website: www.norandaaluminum.com

From: Putney, David [mailto:putney.david@epa.gov] 

Sent: Monday, July 01, 2013 1:38 PM 

To: Backfisch Don (NORALNM) 

Subject: FW: CD Received 

Could I please get an estimated date for receiving the test data for the Noranda primary aluminum reduction 

facility? 

I will have several meetings with upper management over the next few weeks concerning the schedule of this 

rulemaking which depends, in no small part, on the test data from your facility. 
p. 6 of 7 

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: Putney, David 

Sent: Monday, June 24, 2013 12:56 PM 

To: 'Backfisch Don (NORALNM)' 

Subject: RE: CD Received 

Okay – glad it got back to you alright. 

You have several options on how to resubmit the data, but in my opinion the easiest, cheapest, and fastest 

way is to simply upload the files to the testing ICR website at 

https://icr2010.rti.org/Industries/PrimaryAluminum.aspx. First, you would need to register as a user (look near 

upper right hand corner of the website). Then, after approved as a user (you will be notified via email once you 

register) you would log into this website and go to (look along left hand edge of website) Industries – Primary 

Aluminum – Upload Files. 

If I recall correctly you thought you would have the corrected results to me by the end of the month. Is this still 

the case? That is, can I expect the corrected file by 06/30/13? If not, when do you expect to be able to submit 

the corrected file? 

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: Backfisch Don (NORALNM) [mailto:Don.Backfisch@noralinc.com] 

Sent: Monday, June 24, 2013 11:17 AM 

To: Putney, David 

Subject: CD Received 
p. 7 of 7 

I just wanted to let you know that I received the CD that you returned to us. We will make our 

revisions and return it to you as soon as possible.

Don Backfisch 

Environmental Superintendent 

Noranda (NYSE: NOR) 

P. O. Box 70 

New Madrid, MO 63869 

Phone: (573) 643-2361 x2126 

Fax: (573) 643-6721 

Email: don.backfisch@noralinc.com

Website: www.norandaaluminum.com