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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 an d 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 correcte d versions in the docket as opposed to the originals with addi tional documents to show corrections. Also, I agree with your approach of addressing all the issues before r esubmitting the report. However, it would be good t o know the answers to my questions when you get the inform ation. That is, please inform me of the lab’s respo nse when you get it – as opposed to waiting until the r evised report is completed.

I actually have a follow up comment/question to my email from yesterday. Based on a quick review of th e secondary potline PCB emissions (presented in Table 2-4 of the final report), it appears that those em issions (in units of lb/hr) are based on the downcomer flow rat e (as opposed to the roof vent flow rate). For exam ple, when I attempted to reproduce the Mono PCB emission s 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 Tab le 2-4 of the Final Report. However, the lb/hr emis sion rate
for Mono PCB does match if I use the downcomer flow rate instead of the roof vent flow rate. This coul d be a source of confusion during the public comment perio d. You may want to either modify the table in the r eport to clarify that the lb/hr values are based on the d owncomer flow rates, or modify the emissions values to represent emissions based on roof vent flow rates.

Also, as mentioned in my previous email, the report ed PCB emissions values appear to be overestimated by a factor of 1,000 as a result of the lab reporting th eir results in units of picograms (pg) but those re sults being changed to units of nanograms (ng) in the spreadshe ets 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 l ab data on page G-149 of the report). This would ce rtainly 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

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I have contacted our contractor to get your questio ns answered. He has forwarded the questions to the lab that did the analyses for clarification. D o you want us to update and submit both the spreadsheet and the final report? I don’t know exa ctly how long it will be before we have the response from Clean Air, but I will pass the inform ation on to you as soon as I can. If acceptable to you, we will probably wait until we have answered a ll 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); Ba ckfisch Don (NORALNM) Subject: RE: ICR data

Nancy,

I have done a quick review of the ICR data submitte d for the Noranda primary aluminum facility in New Madrid, MO, and have a few comments and questions f or you and the testing/lab contractors. Note that i n the discussions below, unless otherwise specified, plea se refer to page G-124 of the lab data (see page 62 6 of 748 in the pdf Final Report) when discussing dioxin/fur an (D/F) data and refer to page G-165 of the lab da ta (see page 667 of 748 in the pdf Final Report) when discu ssing polychlorinated biphenyl (PCB) data as “typic al” examples. These data are for run 1 on the paste pla nt.

• Some of the target analytes are flagged with an “R” which, according to the footnotes in the lab repor t, indicates that the ion abundance ratio for the comp ound 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 con centration 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. Wha t value was used when calculating concentrations?)

• I need help interpreting the concentration values a ssociated with the analytes that are flagged with a “J” (which, according to the footnotes in the lab r eport, indicates that the analyte was detected belo w the calibrated range) but which have listed concent rations 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 analyt es that are flagged with both “J” and “R” are liste d 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 w hen 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 onl y U flagged data to be marked BDL.

• The material throughput rates listed in the Final R eport do not always agree with those listed in the summary spreadsheets. For example, Tables 2-13, 2-1 9, 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 hou r 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 throu ghput of 7.79 tons per hour. Please confirm the

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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 gre en 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 p ounds of pollutant per ton of aluminum produced or pounds of pollutant per ton of green anode processe d.

• Specifically regarding the PCB analyses - I notice that although the lab reports cite values of PCB i n units of pg, those values were listed in the associ ated summary spreadsheets in units of nanograms (ng). That is, for example, the lab results indicat e 2,400 pg of total monochlorinated biphenyls whereas the PCB portion of the associate d spreadsheet (PrAl_ICR_PastePlant.xls) indicates 2,400 ng of total monochlorinated biphenyls. This w ould appear to have caused an overestimation of PCB emissions from your facility by a factor of 1,0 00. Please confirm or modify, as appropriate, the P CB 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 th ose homologue groups flagged with a U. For example, for the Total OctaCB homologue group (whic h is flagged as U) the lab report cites a concentration of <23 pg (which would suggest a meth od 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 rev iewing the report yet, and we may have other questi ons 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); Ba ckfisch Don (NORALNM) Subject: RE: ICR data

Nancy,

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I have downloaded the files from the website - than ks 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); Ba ckfisch Don (NORALNM) Subject: ICR data

The Excel files and the pdf report were uploaded to day to the site you mentioned below. I will be sen ding 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

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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. The y are estimating that they won’t have the spreadsheet completed until Tuesday, July 16. We w ill 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 he r 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 redu ction 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.

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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 dat a, but in my opinion the easiest, cheapest, and fas test way is to simply upload the files to the testing IC R 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, afte r approved as a user (you will be notified via emai l 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 th e 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

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I just wanted to let you know that I received the C D 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