From: "Palazzolo, Michael A." <Michael.Palazzolo@alcoa.com>

To: Rochelle Boyd/RTP/USEPA/US@EPA

Date: 08/21/2012 07:46 AM

Subject: RE: FW: Comment Clarification Request

Rochelle,

Sorry for the slow reply. Folks at Lancaster were tied up with other issues.

Below is a summary table showing the number of planned and unplanned maintenance 

events that required Lancaster to switch from Group 1 controlled to Group 1 uncontrolled 

furnace operation. After each repair was complete, Lancaster immediately switched back to 

Group 1 controlled mode. I am not clear on whether EPA would count each of these events 

as “one switch” or “two switches”. Hopefully, the rule will be clear that switching from 

uncontrolled to controlled does not count against any sort of limit established in the rule for 

the number of switches allowed.

Please let us know if you have additional questions. 

Thanks,

Mike

Michael Palazzolo

Alcoa Inc.

201 Isabella Street

Pittsburgh, PA 15212-5858

Ph: 412-553-4832
From: Rochelle Boyd [mailto:Boyd.Rochelle@epamail.epa.gov] 

Sent: Monday, August 13, 2012 12:02 PM

To: Palazzolo, Michael A.

Subject: Re: FW: Comment Clarification Request

Hi Mike, I need some additional information concerning the number of furnace switches. For the years 

that you have listed below, please list how many switches occurred each of those years and specify the 

number of switches during that year that were due to unplanned maintenance, planned maintenance or 

other reason (please specify)? Thanks 

Rochelle Boyd, 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) 541-1390 Fax: (919) 541-3207

Email: boyd.rochelle@epa.gov

From: "Palazzolo, Michael A." <Michael.Palazzolo@alcoa.com>

To: Rochelle Boyd/RTP/USEPA/US@EPA

Date: 08/01/2012 01:24 PM

Subject: FW: Comment Clarification Request

Rochelle,

Below is Alcoa’s response to your request for comment clarification.

- What frequency of furnace designation switches does Alcoa consider necessary and 

why? Do you have records of how often these switches occur, if your current permit allows 

it? 

Alcoa’s Lancaster facility needs the flexibility to perform timely planned and unplanned 

baghouse maintenance without losing substantial furnace operating time. We have 

routinely conducted a second Subpart RRR performance test and established corresponding 

operating limits (i.e., clean scrap only and flux limits) without the baghouse to ensure 

compliance with Subpart RRR (and State emission limits) during these maintenance events. 

The test results and Subpart RRR parametric limits ensure continuous compliance when the 

baghouse must be taken out of service. The alternate operating condition is incorporated in 

the facility’s Title V permit.

As discussed in our earlier comments on the proposed rule, we believe that restricting the 

frequency of switching furnace classifications is ill-advised because such restriction may 

encourage an owner or operator to delay baghouse repairs that could be initiated 

immediately by switching to a demonstrated “cleaner” operating mode while the repairs are 

completed. 
The frequency of switches needed will depend on events. We reviewed records from 2003 

to 2012 and found that the worst year had 9 switches to the clean, uncontrolled operating 

mode. The worst month had 4 switches due to a recurring problem that took several events 

to troubleshoot and then repair. 

We still recommend that EPA to revise §63.1514(e) to allow controlled furnaces to change 

operating modes (and revert to pre-change operating mode) without restriction on 

frequency, especially when the air pollution control device must be shut down for both 

planned and unplanned maintenance. However, if EPA believes a restriction must be 

imposed, we would suggest limiting the number of times a furnace can switch to 15 or 16 

times per calendar year.

Other facilities or companies may require the flexibility to change furnace classifications in 

response to market conditions in addition to baghouse maintenance events. We support 

EPA’s providing such flexibility for market needs as well, provided that compliance with 

Subpart RRR is maintained under the alternative operating mode. 

Please let me know if you have any questions or require further information. 

Thank you, 

Mike

Michael Palazzolo

Alcoa Inc.

201 Isabella Street

Pittsburgh, PA 15212-5858

Ph: 412-553-4832

 

From: Rochelle Boyd [mailto:Boyd.Rochelle@epamail.epa.gov]

Sent: Friday, July 13, 2012 3:10 PM

To: Palazzolo, Michael A.

Subject: Comment Clarification Request

Hi Mike, I have a question concerning one of your comments on the proposed rule. I did not include any requests 

for information on duplicative issues that were brought to our attention by TAA. 

1) What frequency of furnace designation switches does Alcoa consider necessary and why? Do you have records 

of how often these switches occur, if your current permit allows it? Due to enforceability of subpart RRR, we 

cannot allow unlimited switches. The original rule did not prohibit the switching of furnace designations, but the 

rule was not set up to accommodate such occurrences. 

Please let me know. Thanks

Rochelle Boyd, 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) 541-1390 Fax: (919) 541-3207
Email: boyd.rochelle@epa.gov