p. 1 of 5 

From: Putney, David 

Sent: Tuesday, May 28, 2013 7:12 AM 

To: 'Palazzolo, Michael A.' 

Cc: Bilskis, Patricia A. 

Subject: RE: RE: Intalco Wet Scrubber Test Approach 

Mike, 

I understand that the Intalco facility poses some unique challenges associated with sampling of secondary 

potline emissions and that we did spend considerable time finalizing a plan on just how to sample those 

secondary potline emissions. However, I must admit that I was a bit surprised at the length of the extension 

request. Given the tight court-ordered deadline for this rule (03/14/14), this delay poses some concerns. Can 

you please try to shorten the schedule some? For example send the test data by the end of June or early July. 

Nevertheless, I have a couple suggestions to expedite the process, as follows: 

First, we would like to receive the preliminary emissions data as soon as possible. That is, please go ahead and 

submit the emissions data as soon as you have it available and you can submit the final test report(s) later. We 

can use the preliminary test data to get started on our analyses and then modify our analyses as/if necessary 

after the test report QA/QC is competed. 

Second, if the lab can prioritize their analysis of the samples, please ask the lab to analyze the potline POM, PM 

and HAP metal data first and send me those results as soon as you get them. As you know, Intalco is the only 

facility with SWPB potlines and, therefore, the potline emissions data is critical to our analyses as the data will 

be used to establish any resulting proposed MACT standards for the SWPB subcategory. However, I will be 

getting paste plant and bake furnace data from other facilities and this emissions data from Intalco, while still 

valuable and necessary, is less critical to the analysis. Also, I have some POM potline emissions data for this 

facility that you submitted in response to the proposal published 12/06/11 – but the additional data from this 

round of testing will better inform the resulting SWPB potline POM MACT standard. 

Please let me know if you have any questions. 

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: Palazzolo, Michael A. [mailto:Michael.Palazzolo@alcoa.com] 

Sent: Tuesday, May 14, 2013 3:09 PM 

To: Putney, David 

Cc: Bilskis, Patricia A. 

Subject: RE: RE: Intalco Wet Scrubber Test Approach 
p. 2 of 5 

David, 

Our current schedule is to begin the Intalco emissions sampling the week of May 

20th and complete all of the sampling by June 18th. Assuming no significant 

testing delays, we will be able to provide EPA a Final Test Report for Intalco on or 

before July 26th, 2013. 

Please let us know if you have any questions. We understand your schedule 

constraints for the rulemaking and will work to keep the test program on 

schedule. 

Thank you, 

Mike 

Michael Palazzolo 

Alcoa Inc. 

201 Isabella Street 

Pittsburgh, PA 15212-5858 

Ph: 412-553-4832 

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

Sent: Wednesday, May 08, 2013 9:36 AM 

To: Palazzolo, Michael A. 

Cc: Bilskis, Patricia A. 

Subject: EXT: RE: Intalco Wet Scrubber Test Approach 

Mike, 

I spoke with Chuck about these issues yesterday afternoon. First, we believe that, as long as you are 

following the sampling methods described below and the testing ICR requirements for analyzing the 

collected samples, pre-approval of a test protocol is not required. 

Also, while we understand that additional time may be necessary for this facility due to the delay 

associated with addressing the unique aspects of sampling the secondary potline emissions from this 

facility, we ask that the data be submitted ASAP. As you are aware, the court ordered deadline for this 

rulemaking action is very tight and we just do not have much time to give on this project. Please let me 

know the results of your discussion with the test contractor (i.e., the additional time you believe is

necessary) at your earliest convenience. 

Thanks, 

David Putney, Environmental Engineer 

U.S. Environmental Protection Agency 

Office of Air Quality Planning and Standards 
p. 3 of 5 

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: Palazzolo, Michael A. [mailto:Michael.Palazzolo@alcoa.com] 

Sent: Tuesday, May 07, 2013 1:27 PM 

To: Putney, David 

Cc: Bilskis, Patricia A. 

Subject: RE: Intalco Wet Scrubber Test Approach 

David, 

We went out for bids and have finally selected a test contractor to conduct 

the ICR testing at Intalco per the testing approach described below. Do we 

need to send you a Test Protocol for pre-approval or are we OK to proceed 

with the testing based on the description below? 

Also, due to the extra time required to define a test approach for the wet 

roof scrubbers, Intalco will not be able to meet the original ICR deadline for 

results by May 31st. We are working with the test contractor to confirm 

when they can have a final report and will get back to you soon with an 

alternate date. 

Thank you, 

Mike 

Michael Palazzolo 

Alcoa Inc. 

201 Isabella Street 

Pittsburgh, PA 15212-5858 

Ph: 412-553-4832 

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

Sent: Friday, April 05, 2013 11:47 AM 

To: Bilskis, Patricia A. 

Cc: Palazzolo, Michael A.; Mitchell, Kathryn M; Garwood, Gerri 

Subject: RE: Intalco Wet Scrubber Test Approach 

Patricia, 

I have discussed the Intalco secondary potline sampling techniques with Judy Schwieters of the 

WA Dept. of Ecology. Ms. Schwieters informed me that she is reasonably assured that the 
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Intalco operation and maintenance (O&M) plan and functional integrity (FI) inspections for the 

wet scrubbers ensure the proper maintenance of the wet scrubbers near the ends of the 

potlines. She further informed me that Intalco has a good record of meeting the O&M 

requirements and conducting those FI inspections and believes that the current method of 

sampling secondary potline emissions from the Intalco facility provides representative samples 

of emissions from those sources. 

Also, as pointed out by Intalco staff, the current method of sampling secondary potline 

emissions from the Intalco facility complies with the requirements of 40 CFR 63.849(b) more 

closely than would sampling of wet scrubbers near the ends of the potlines because it more 

closely meets the intent of the sampling requirements of Method 14. 

Given these considerations, SPPD will accept secondary potline emissions data obtained via 

the sampling approach that we discussed with you on 03/19/13 for the Intalco facility. That is, 

for the purposes of the testing ICR dated 03/04/13, Intalco will: 

• Sample the secondary potline emissions using the method outlined in my 02/28/13 

email (i.e., build a circular stack section that meets its own Method 1 criteria and is 

used to traverse the wet scrubber exit vents using a 7x7 rectangular traverse scheme); 

• Sample 3 wet scrubbers during each of the 6 required runs; 

• Collect a minimum sample volume of 3 dscm per scrubber for polycyclic organic 

matter and a minimum sample volume of 4 dscm per scrubber for filterable particulate 

matter and metal HAP; and 

• Collect the samples from those wet scrubbers currently designated by Intalco as test 

scrubbers (i.e., the scrubbers that are near the center of the potline and which are 

already equipped with the necessary safety and electrical equipment). 

Please feel free to contact me with any comments, questions, or concerns you might have 

regarding these issues. 

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: Bilskis, Patricia A. [mailto:Patricia.Bilskis@alcoa.com] 

Sent: Tuesday, March 26, 2013 11:08 AM 

To: Putney, David 

Cc: Palazzolo, Michael A.; Mitchell, Kathryn M 

Subject: Intalco Wet Scrubber Test Approach 
p. 5 of 5 

Mr. PutneyThe PMACT rule recognizes that plants with roof scrubbers do not conform to the standard 

model for roof monitor emissions and makes special provisions for plants like 

Intalco. Section 63.849(b) of the rule requires that such plants “follow the intent” of 

Method 14 (Determination of Fluoride Emissions From Potroom Roof Monitors For 

Primary Aluminum Plants) which is the reference test for TF from potline roof monitors. 

Attached you will find a document that details how Intalco’s current source testing 

method was developed with the intent of meeting method 14 criteria. You will also find 

an updated version of the wet scrubber powerpoint that was previously submitted to you 

that has been amended with three slides at the end, that contain pictures that show the 

orientation of the potline wet scrubbers and doorways.

In previous conversations, Intalco was asked to describe our minimum functional integrity 

checks of our wet scrubbers. At a minimum, a daily functional integrity inspection of the 

potroom wet scrubbers is performed that includes a visual check of visible emissions, a 

visual check of adequate water flow (parameters defined in Potline Parametric Monitoring 

Plan), and ensuring belts are on both the pump and fan. 

If you require any additional information, please let me know. 

Patricia Bilskis 

Intalco Aluminum Corporation 

Environmental Specialist 

Ferndale WA, 98248 

360-384-7267