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From: Van Der Meyden, Henk [ mailto:Henk.VanDerMeyden@alcoa.com ]
Sent: Thursday, January 02, 2014 10:08 AM
To: Putney, David
Cc: Palazzolo, Michael A.; McCaskill, William L.; Van Der Meyden, Henk Subject: RE: Draft emissions file for the Alumax of SC prim ary aluminum facility

Hello David,

Attached, please find the draft emissions Excel wor kbook for the Alumax of SC primary aluminum facility with markups and comments included that resulted from the reques ted
review.

In the primary Al sheet, we edited some of the emis sion rates. While they are blank, we did not add to the hours of operation listed in columns AQ-AT since they wer e not highlighted yellow. We do want to point out that A node Paste Plant is NOT a continuous operation and that this needs to be properly reflected in the risk modeling

.

In the noncategory sheet, the waste oil fired heate r no longer exists and should be removed. We also belie ve that
several of the other sources should be deleted sinc e they are not subject to any of the subcategories promulg ated under Section 112 c of the CAA. Comments on specif ic applicability requirements are included. Finally, w e updated some locations coordinates to reflect actua l
location rather than the default ‘center of the fac ility’ used by SC DHEC.

If you have any questions regarding this, please fe el free

to contact me.

Regards,

Henk van der Meyden, PG Environmental Manager Alcoa - Mt. Holly Office: (843) 572-5361 Cell: (843) 296-3359 Fax: (843) 572-5378p. 2 of 4

From: Putney, David [ mailto:putney.david@epa.gov ]
Sent: Wednesday, December 18, 2013 9:37 AM
To: Van Der Meyden, Henk Subject: EXT: Draft emissions file for the Alumax of SC pri mary aluminum facility

Hello Henk,

Please find attached to this message a draft emissi ons file (Excel spreadsheet) for the Alumax of SC prima ry aluminum production facility. Columns highlighted in yellow are available for revisions or to indicate i f
records should be deleted. Please do not overwrite the data in columns that are not highlighted in yel low as this would complicate the development of the fin al emissions file for use in risk modeling.

The tab titled “primary Al category” includes emissions from the primary aluminum production operations (e.g., potlines, paste plants, pitch storage tanks, and anode bake furnaces) at the Alum ax of SC facility as estimated via emission factors developed from test results obtained in response to the testing ICR sent out in April of 2013. I expect that the stack parameters are correct as-is since industry previously had opportunity to review those
items in CY2010 before the initial residual risk an d technology review (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 analysis 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 of tons per year, tpy) if neede d.

The tab titled “noncategory” includes 2005 NATA NEI, 2008 NEI and 2010 state HAP data for the Aluma x of SC primary aluminum production facility. Thesep. 3 of 4

records are intended to include emissions from operations at your facility which are not directly associated with primary aluminum production (primar y aluminum emissions are addressed under the first ta b, discussed above) or secondary aluminum production (secondary aluminum emissions will be addressed via the RTR associated with the secondary aluminum sour ce 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
corrected value in the associated revision column (again, please do not overwrite the data in columns that are not highlighted in yellow). Note that fie lds were also added to identify if a record should be deleted, and a reviewer comment field where you can add a comment if appropriate. Please review these d ata 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 o perating permit for this operation) then the operation and associated emissions need no t 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 operation and associated emissions need not be included (so as to avoid doub le counting those emissions).

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 routed 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 e missions need not be included (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 annua l actual emissions in units of tons emitted per year (tpy).

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

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 gi ve me what you can by 01/03/14 and remember that you w ill have another opportunity to make comments and corrections during the upcoming public notice and comment period associated with the primary aluminum production RTR supplemental proposal.

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

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