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From: Backfisch Don (NORALNM) [ mailto:Don.Backfisch@noralinc.com ]

Sent: Friday, January 03, 2014 2:16 PM

To: Putney, David Subject: RE: Draft emissions file for the Noranda primary a luminum facility

David,

I reviewed the attached spreadsheets and they appea r to be correct as to the separation of the non-category emission points. In looking at the primary aluminum category tab, I did notice that Emission P oint ID #14749 was duplicated several times. If I’m not mistaken, som e of them should have been for emission points 14752, 14753, and 14754. I als o wanted to point out that the roof vents with ID #14743 through 14754 are roo f vents in our anode cooling room for Potlines 1 and 2 and may not have the same emissions as the ones that exhaust gases from an operating potroom.

Don Backfisch

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

Sent: Tuesday, December 24, 2013 9:49 AM

To: Backfisch Don (NORALNM) Subject: FW: Draft emissions file for the Noranda primary a luminum facility

Hello Don,

Several industry contacts have reached out to me fo r clarification regarding my request for review of th e draft emissions files as my initial email was evidently a bit confusing (I can see how it would be). So I am send ing this follow up email out to (hopefully) clarify my reque st

somewhat. Please do not overestimate what I am look ing for in response to my initial email. It really should n ot take too long to respond to my email.

Several contacts have requested information on the production capacities used for the primary aluminum facilities and are concerned about estimating CY201 3 emissions since production for CY2013 has not yet c eased. In the development of the emissions estimates in th e files I sent out initially we used the production capacit ies found in Table 2 of the attached document. However, I amp. 2 of 5

not expecting industry to do any emissions calculat ions at this point that would require capacity information. Also, the portion of the spreadsheet that shows CY2013 is misleading – we understand that you do not have pro duction data for all of CY2013 at this point. I believe the current year is used simply to show that it is a recent ris k analysis and that the facility was operating in 201 3. Please do not try to correct the spreadsheets to re flect your CY2013 production.

We feel fairly confident in the source category emi ssions and locations of emissions sources since we got ind ustry test data to estimate emissions and industry review of locations in the previous (initial) proposal. Altho ugh, if something jumps out at you as being obviously incor rect in the source category tab of the spreadsheets then yo u are welcome to bring it to my attention.

The main thing I am requesting is for industry to r eview the non source category tab of the spreadsheets so as to ensure we are not including emissions in the risk m odeling that should not be included (e.g., for a boiler tha t no longer exists), and not double counting the emissio ns that should be included (e.g., emissions that are part o f collocated secondary aluminum operations). We got t he non category information from the National Emission Inv entory (NEI) databases and other state input. As you can i magine there is quite a bit of variation between how the v arious states put data in the NEI and how they refer to th e associated emissions sources. I’m hoping that you c ould tell by the location, pollutants and magnitude of e missions what is the referenced source. Then, we will includ e or remove the associated emissions in the risk model a s appropriate.

Thanks again,

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: Putney, David

Sent: Wednesday, December 18, 2013 9:35 AM

To: Don Backfisch Subject: Draft emissions file for the Noranda primary alumi num facility

Hello Don,

Please find attached to this message a draft emissi ons file (Excel spreadsheet) for the Noranda primary aluminu m production facility. Columns highlighted in yellow are available for revisions or to indicate if records s hould be

deleted. Please do not overwrite the data in colum ns that are not highlighted in yellow as this would complic ate the development of the final emissions file for use in risk modeling.

The tab titled “primary Al category” includes emiss ions from the primary aluminum production operations (e. g., potlines, paste plants, pitch storage tanks, and an ode bake furnaces) at the Noranda facility as estimated via emission factors developed from test results obtained in res ponse to the testing ICR sent out in April of 2013. I expect that the stack parameters are correct as-is since indust ry previously had opportunity to review those items in CY2010 before the initial residual risk and technology rev iew (RTR) proposal for the primary aluminum production source category. There are, however, some emissions (e.g., metal HAP, dioxins, PCB, etc.) that are new to the RTR an alysis for the primary aluminum production source category and, although these have been QA/QC’d by contractor and EPA staff, we do welcome feedback/corrections you might have on these emissions. A revision column highlighted in yellow is provided for you to revise emissions (in units o f tons per year, tpy) if needed.p. 4 of 5

The tab titled “noncategory” includes 2005 NATA NEI , 2008 NEI and 2010 state HAP data for the Noranda primary aluminum production facility. These records are int ended to include emissions from operations at your facility which are not directly associated with primary aluminum production (primary aluminum emissions are addresse d under the first tab, discussed above) or secondary alumin um production (secondary aluminum emissions will be ad dressed via the RTR associated with the secondary aluminum source category). Revision columns highlighted in yellow a re included for emissions, pollutants, stack parameter s, fugitive parameters and latitude/longitude. If any of these parameters needs modification, please put the corre cted value in the associated revision column (again, ple ase do not overwrite the data in columns that are not high lighted in yellow). Note that fields were also added to id entify if a record should be deleted, and a reviewer comme nt field where you can add a comment if appropriate. Please review these data with the following in mind:

1. Should the operation be included in the spreadsheet ?

a. Does the operation still exist at the facility? If not, or if it exists but is not legally allowed to operate (e.g., you do not have a valid operating pe rmit for this operation) then the operation

and associated emissions need not be included.

b. If the operation does exist at the facility, is it part of any secondary aluminum operations that may exist at your facility? If so, then the operati on and associated emissions need not be included (so as to avoid double counting those emis sions).

c. If the operation does exist at the facility, would the emissions from this operation be considered part of the monitored primary aluminum e missions? For example, if the emissions associated with the operation in question are route d through the control device associated with the paste plant and would be monitored as part of the paste plant emissions then the operation and associated emissions need not be incl uded (so as to avoid double counting those emissions).

2. If the operation should be included, are the cited emissions representative of that operation?

3. If the operation should be included but the cited emissions are not representative of that operation, then please provide representative annual actual em issions in units of tons emitted per year (tpy).p. 5 of 5

4. Verify or modify the stack parameters and location as appropriate and necessary.

Please provide any comments, changes, corrections, etc. to this file to me by close of business on Friday, 01/ 03/14. I understand that more time might be preferable with the holidays upon us, but please give me what you can b y 01/03/14 and remember that you will have another opportunity to make comments and corrections during the upcoming public notice and comment period associate d with the primary aluminum production RTR supplemental pr oposal.

If you have any questions concerning these issues, please feel free to contact me by email or telephone.

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