p. 1 of 4 

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 primary aluminum facility 

Hello David, 

Attached, please find the draft emissions Excel workbook 

for the Alumax of SC primary aluminum facility with markups 

and comments included that resulted from the requested 

review. 

In the primary Al sheet, we edited some of the emission 

rates. While they are blank, we did not add to the hours 

of operation listed in columns AQ-AT since they were not 

highlighted yellow. We do want to point out that Anode 

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 heater no 

longer exists and should be removed. We also believe that 

several of the other sources should be deleted since they 

are not subject to any of the subcategories promulgated 

under Section 112 c of the CAA. Comments on specific 

applicability requirements are included. Finally, we 

updated some locations coordinates to reflect actual 

location rather than the default ‘center of the facility’ 

used by SC DHEC. 

If you have any questions regarding this, please feel 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) 572-5378 
p. 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 primary aluminum facility 

Hello Henk, 

Please find attached to this message a draft emissions 

file (Excel spreadsheet) for the Alumax of SC primary 

aluminum production facility. Columns highlighted in 

yellow are available for revisions or to indicate if 

records should be deleted. Please do not overwrite

the data in columns that are not highlighted in yellow 

as this would complicate the development of the final 

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 Alumax 

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 and 

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 needed. 

The tab titled “noncategory” includes 2005 NATA 

NEI, 2008 NEI and 2010 state HAP data for the Alumax 

of SC primary aluminum production facility. These 
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records are intended to include emissions from 

operations at your facility which are not directly 

associated with primary aluminum production (primary 

aluminum emissions are addressed under the first tab, 

discussed above) or secondary aluminum production 

(secondary aluminum emissions will be addressed via

the RTR associated with the secondary aluminum source 

category). Revision columns highlighted in yellow are 

included for emissions, pollutants, stack parameters, 

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 fields 

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 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 permit 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 operation and associated 

emissions need not be included (so as to avoid double 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 emissions? 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 emissions 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 annual actual emissions in units of tons emitted 

per year (tpy). 

4. Verify or modify the stack parameters and location as appropriate and necessary. 
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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 by 01/03/14 and remember that you will 

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 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