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 u nique challenges associated with sampling of second ary potline emissions and that we did spend considerabl e time finalizing a plan on just how to sample thos e secondary potline emissions. However, I must admit that I was a bit surprised at the length of the ext ension request. Given the tight court-ordered deadline for this rule (03/14/14), this delay poses some concer ns. Can you please try to shorten the schedule some? For ex ample send the test data by the end of June or earl y July. Nevertheless, I have a couple suggestions to expedi te the process, as follows:

First, we would like to receive the preliminary emi ssions data as soon as possible. That is, please go ahead and submit the emissions data as soon as you have it av ailable 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 ne cessary 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 pot line POM, PM
and HAP metal data first and send me those results as soon as you get them. As you know, Intalco is th e only facility with SWPB potlines and, therefore, the pot line emissions data is critical to our analyses as the data will be used to establish any resulting proposed MACT st andards for the SWPB subcategory. However, I will b e getting paste plant and bake furnace data from othe r facilities and this emissions data from Intalco, while still valuable and necessary, is less critical to the ana lysis. Also, I have some POM potline emissions data for this facility that you submitted in response to the prop osal published 12/06/11 – but the additional data f rom this round of testing will better inform the resulting S WPB 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 Approachp. 2 of 5



### David,

Our current schedule is to begin the Intalco emissions samp ling the week of May
20 th 

### and complete all of the sampling by June 18 th 

### . Assuming no significant testing delays, we will be able to provide EPA a Fin al Test Report for Intalco on or before July 26 th 

### , 2013.

Please let us know if you have any questions. We unde rstand your schedule constraints for the rulemaking and will work to keep t he 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 aft ernoon. 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 sa mpling the secondary potline emissions from this facility, we ask that the data be submitted ASAP. A s you are aware, the court ordered deadline for thi s 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 c ontractor (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 Standardsp. 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 descr ibed below. Do we need to send you a Test Protocol for pre-approval or a re 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 or iginal ICR deadline for results by May 31 st 

### . We are working with the test contractor to confirm when they can have a final report and will get back t o 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; Garwoo d, Gerri Subject: RE: Intalco Wet Scrubber Test Approach

Patricia,

I have discussed the Intalco secondary potline samp ling techniques with Judy Schwieters of the WA Dept. of Ecology. Ms. Schwieters informed me tha t she is reasonably assured that thep. 4 of 5 Intalco operation and maintenance (O&M) plan and fu nctional 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 an d believes that the current method of sampling secondary potline emissions from the Intal co 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 t he requirements of 40 CFR 63.849(b) more closely than would sampling of wet scrubbers near t he ends of the potlines because it more closely meets the intent of the sampling requiremen ts of Method 14.

Given these considerations, SPPD will accept second ary 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 me thod outlined in my 02/28/13 email (i.e., build a circular stack section that me ets 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 require d runs;

• Collect a minimum sample volume of 3 dscm per scrub ber for polycyclic organic matter and a minimum sample volume of 4 dscm per sc rubber for filterable particulate matter and metal HAP; and

• Collect the samples from those wet scrubbers curren tly designated by Intalco as test scrubbers (i.e., the scrubbers that are near the ce nter of the potline and which are already equipped with the necessary safety and elec trical equipment).

Please feel free to contact me with any comments, q uestions, 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 Approachp. 5 of 5

### Mr. PutneyThe PMACT rule recognizes that plants with roof scr ubbers 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 th at such plants “follow the intent” of Method 14 (Determination of Fluoride Emissions From Potroom Roof Monitors For Primary Aluminum Plants) which is the reference tes t 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 met hod 14 criteria. You will also find an updated version of the wet scrubber powerpoint t hat 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 doorwa ys.

In previous conversations, Intalco was asked to des cribe 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 def ined in Potline Parametric Monitoring Plan), and ensuring belts are on both the pump and fan.

If you require any additional information, please l et me know.

Patricia Bilskis Intalco Aluminum Corporation Environmental Specialist Ferndale WA, 98248

360-384-7267