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

Ro chelle,

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 uncon trolled

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 clea r 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

- 4832From: Rochelle Boyd [ mail to: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

th at 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 P M

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 conduc ted 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 te st 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 pr oposed 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 demonstra ted “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 Palaz zolo

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: Pa lazzolo, 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 switche s. 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 o f 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

- 3207Email: boyd.rochelle@epa.gov