The following items are in this file:

Modeling Data and Instructions Google_Earth_Instructions Alum Assoc Primary Aluminum RTR MTG_Dec 1 Secondary Aluminum SCC_Description CodesModeling Data and Instructions

Please review the attached files and correct them as necessary, so that we will have the most accurate information available to use in residual risk modeling. Please send the corrected files by Friday,
December 10, 2010.

kmz file

- Your facility can use this file to view the release points in Google Earth that are presently in our data base for your emission points

. The yellow points are for MACT emission records and the green points are for non

- MACT emission records

. If this information is in correct, please correct these emission release points through Google Earth. The instructions for making the corrections are attached as a separate document title d “ Google Earth Instructions ” . If you are unable to download Goog le Earth, you may contact me for an alternative means of updating your emission release point coordinates.

ReleasePoint

- This spreadsheet matches the information uploaded in the kmz file. The emission release points listed in column “M” should be all inclusive and used in the Google Earth file. If you need to make corrections, please do so in red in the revision columns. If yo u need to add missing points please

remember to incorporate tho se changes into the KMZ file. The primary keys needed to identify unique release points are STATE_COUNTY_FIPS (Column G), STATE_FACILITY_IDENTIFIER (Column H), and EMISSION_RELEASE_POINT_ID (Column M). We included other information such as SCC and Proces s ID

in this spreadsheet to help you identify the release points.

CategoryHAPs

- Facilities can use this table to see what emissions are assigned to affected sources regulated under the primary aluminum category, MACT Code (0201). You can revise emiss ion values in
the blank revision field, enter comments in the comment field, add rows, and /or add columns

, if

necessary.

WholeFacilityHAPs

- Facilities can use this spreadsheet to see what emissions are included in the data

base for the entire facility ( including primary aluminum and other processes). You can revise emission
values in the blank revision field, enter comments in the comment field, add rows, add columns if

necessary. It does not appear that HAPs from many of the other sources , such as sec ondary aluminum, are represented in this data file.

EmissionsComparisonByHAPCategory

- Facilities can use this spreadsheet to compare category and

whole

- facility modeling data contained in the National Emissions Inventory ( NEI ) to Toxic Release Inventory ( TRI ) emissions. If you see a significant difference in emission values for HAP categories, you may want to investigate those further to see if emission revisions are needed in the CategoryHAPs or WholeFacilityHAPs spreadsheet s. We cannot make official revisions to the TRI data shown in this spreadsheet

. Facilities must make their own revisions to TRI.

EISData

- Facilities can use this spreadsheet to see what emissions are assigned to the facility in 2008 Emission Inventory System ( EIS ) fo r comparison purposes. The EIS replaces the NEI data system. If

you believe there is an error in the 2008 EIS data, record it on the spreadsheet and contact your state or local agency to update their data base

. State and local agencies are responsible for updating their data in the EIS system. In the EIS system, new id's were assigned to data sets and therefore users will not

see all of the same id's in this spreadsheet that are used in the other spreadsheet s.

## Google Earth Instructions

Adding Emission Points and Plant Fence Lines

Installing Google Earth 1. Download and install latest version of Google Earth from here: http://www.google.com/earth/index.html

. 2. Click the “Download Google Earth 5” button.

3. On the nex t web page, uncheck the two options for Google Chrome (unless you really want Google Chrome browser).

4. Click “Agree and Download ” button near the end of the page.

5. Click “Run” from the File Download window when it appears. (May need to have your browser allow popups).

6. Let the program run and install Google Earth. This should only take a few minutes. Google Earth will open up after
installation is complete and you should see a Googl e Earth shortcut icon on your desktop.

Google Earth Initial Use 1. You may want to turn of the Tips window that appears when you first open Google Earth so that it does not show up
every other time you use Google Earth. 2. For less clutter and quicker na vigation of the terrain, only have Borders and Labels and Roads checked in the Layers area to the left of the imagery.

3. For easier navigation, there two options to be changed in Google Earth. Go to the Tools menu, select O p tions

... , then

click on the Na vigation tab.

Move the Fly

- To slider all the way over to Fast

.

Uncheck both boxes under Navigation

.

Click Apply , the n OK

.Navigating the Terrain in Google Earth 1. To go right to a city, enter a city name then state abbreviation (no need for capita l letters) in the Fly To tab in the

Search box in the upper left corner of Google Earth, the n hit your Enter key.

2. To zoom in and out of the imagery, scroll your mouse wheel up and down . If you do not have a mouse wheel, hold
down your Shift key while holding your right mouse button and moving the mouse up and down.

3. To pan around the landscape, hold down your left mouse button and move your mouse.
4. To rotate you r view

, click and hold down your mouse wheel and move your mouse back and forth. If you do not have
a mouse wheel, hold down your Shift key while holding your left mouse button and moving the mouse back and forth. 5. To get back to a north orientation, type your “ N ” key on your keyboard

.

Adding Emission Points 1. Before adding any points, a folder to contain and help keep multiple points organized needs to be added.

2. In the Places box on the left side of Google Earth, create a folder by right

- clicking Temporary Places , then select Add >

Folder

.

3. In the New Folder window , you could name it Emission Points, then click OK . You should now see the folder under
Temporary Places. As you add your points, you will periodically save them to a KMZ file using instructions below.

4. Navigate to your plant location by using the meth od s listed above . Google Earth im agery is very detailed and many individual features can be seen when zooming in close.

5 . To add a point to the Emission Points folder , make sure it is selected by clicking on it, then click the Add Placemark

button . The button looks like a yellow push pin and is located in a row of other buttons above the imagery.

6. After clicking this button, the New Placemark window appears along with the pushpin symbol with a blinking

crosshairs.
7. Keep the New Placemark window open. This allows y o u to move and edit the pushpin point symbol. With your mouse
pointer, m ove the pushpin to the desired emission location so that the tip of its point is on that location.8. With the New Placemark window still opened, give the point an identifying label b y entering the Emission Release

Point ID

. Nos

. from the enclosed file titled “ ReleasePoint_NEI ”

, Column M by deleting the default “Untitled Placemark”

for the Name and entering the Emission Release Point ID No.

9. You can change the point symbol , color, a nd size by first clicking the symbol to the right of the Name field in the New

Placemark window

...

...then selecting a symbol from the Icon window . Click the box next to Color: to open the Select Color window . Adjust

the icon size by increasing or decreasing the values for Scale:

. You will see the icon on the imagery change. Click OK i n
the Icon window when done.10. While the New Placemark window is open you can still adjust the location of your point. Click OK when finished.

11. Repeat steps 4

– 8 to add additional points. Symbols will be the same as the first one you created. When finished, you should see a listing of points in your Emission Points f older

.

12. If you need to go back and edit any points, right

- click a point in the list or put your mous e pointer over the poin t on the imagery, righ t

- click, and select P roperties . The Edit Placemark window will open for that point. This is basically the
same thing as the New Placemark window when you first created the point. You can the move the point, chang e symbology or the label.

Saving Data to a KMZ File 1. As you are adding points, you will want to periodically save the data to a KMZ file as a backup and to bring back into Google Earth for future viewing or edits.

2. Right

- click the Temporary Places fo lder and select Save Place As...

3. Save it as a KMZ type file in a directory. When you save again, you can just choose and overwrite the same KMZ file. Instructions below show how to open the file to use again in Google Earth.

Creating Fence Lines

1. Si milar to creating an Emission Points folder , add a Fence Line folder under Temporary Places (thi s way when you

save to the KMZ file as sh own above, both points and line folders will get saved in one KMZ file).3. Similar to adding points, first click th e Fence Line folder to make sure it is selected, navigate to where you can see the
entire property, then click the Add Path button . The button looks like two connected lines and is located in a row of
other buttons above the imagery.

4. The New Path wi ndow opens and you r mouse pointer will be a cross hair over the imagery. 5. Before creating any lines, first change the name of the line to Fence Line in the Name: area, then

, so you can see the
line better, select the Style, Color tab and change the Color to yellow and Width to 3.0.

6. With the New Path window still open, click a starting point for the line in the imagery, move crosshairs to where the line varies or turns and click once again. You will then see a line form and continue as you continue to click to create the boundary fence line.

7. Tip: You can scroll the mouse wheel to zoom in and out while you are creating the line. To pan to a different area
while creating line, use you r arrow keys.

See example on next page.8. Double

- click to end the line, then click OK on the New Path window

. You will now see the Fence Line layer in the

folder in the Places box.

9. Right

- click the Temporary Places folder and select Save Place As... to save the KMZ file.

Shutting Down Google Earth
When you cli ck the upper

- right red “ x ” to close down Google Earth, select Discard in the popup window. This will make
things less cluttered the next time you open Google Earth.

Open the KMZ File

1. You should be able to double

- click the KMZ file or right

- click it > Open With... > Google Earth. 2. The KMZ file will open right in Google Earth and you will automatically be zoomed to the area of the data. If closed,
Google Earth will open automatically.

### Agenda

National Emission Standards for Hazardous Air Pollutants for Primary Aluminum Risk and Technology Review December 1, 2010

Purpose of the meeting is to identify key issues that need to be addressed as part of the rule development process for the Residual Risk and Technology Review for Primary Aluminum

1

. Data for the modeling files

a

. Data for the modeling files is being compiled for each facility and will be provided to each company for verification and comments. Each company will receive copies of facility data we plan to use in the risk models consisting of data that was updated in the NEI and the ANPR data revisions. We will also include a KMZ file that can be uploaded into Google Earth so that companies will have the opportunity to correct the l at/longs for each emission unit.

2

. Modeling of actual emissions

a

. We plan to use “maximum actuals” as requested by industry for the modeling of speciated POM emissions for the pot lines. Speciated POM emissions for the Paste Production Plant and the pitch storage tanks will be estimated using existing scientific data and EPA

- 455/R

- 98

- 014. We plan to use the HF data from the NEI for actuals.

3

. Modeling of allowable emissions We are required to model allowable emissions. It was originally assumed

that on ly actual emissions would need to be modeled. Now that we are required to do allowable, we have limited data for prebake pot lines since

there are no POM limits and no data for existing pitch storage tanks. As it turns out we have an obligation to do a M ACT f loor analysis for these sources. This issue has been pointed out in other MACT rules under the petition by NRDC and the Sierra Club

.

4

. MACT determination for Prebake pot lines and existing pitch storage tanks

a

. Any available data

b

. Possible future t esting of these sources

c

. Any facilities with control devices, including vapor balancing on their existing pitch storage tanks?

5

. Carbonyl Sulfide may also be required to have a MACT floor analysis

a

. Is this only emitted from the pot lines?

b

. Is there any test data, i f not, what is the source of the emission inventory

data?

### 6

. Surrogate pollutants

– Is there a possible surrogate pollutant like PM that can used for Carbonyl Sulfide or POM that industry might have data for? (e.g. state requirements for PM)

7

. Metal emissions have been reported from one facility as being emitted from the pot lines. (Stack Test Analysis)