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From: "Hulse, David G." <David.Hulse@alcoa.com>

To: David Putney/RTP/USEPA/US@EPA

Cc: "Palazzolo, Michael A." <Michael.Palazzolo@alcoa.com>

Date: 06/23/2011 12:33 PM

Subject: RE: Follow up on pitch storage tanks at PAL facilities

Please see answers below, and let me know if you have further questions.

Thanks,

David Hulse

Alcoa Inc. – Wenatchee Works

From: Putney.David@epamail.epa.gov [mailto:Putney.David@epamail.epa.gov] 

Sent: Wednesday, June 22, 2011 3:01 PM

To: Palazzolo, Michael A.; ksands@centuryky.com; kisnerj@noralnm.com; jvanmatre@centurywv.com; 

danny.carroll@riotinto.com; kisnerj@noralnm.com; John.Reggi@ormet.com; Van Der Meyden, Henk; 

Mitchell, Kathryn M; Bilskis, Patricia A.; Rufa, Nathan P.; Blodgett, Terry L.; Allen, Chris; Hulse, David G.

Cc: cjohnson@aluminum.org; bahner@rti.org

Subject: Follow up on pitch storage tanks at PAL facilities

Hello all,

Thank you so much for taking the time to respond to the information collection request (ICR) dated April 

25, 2011 concerning the primary aluminum operations conducted at your facility. The information you 

provided will be instrumental in the ongoing associated residual risk/technology review. I have been going

through the ICR responses I received and have a couple of follow-up questions concerning pitch storage 

tanks:

1. The ICR did not directly ask whether or not your facility utilizes any new pitch storage tanks (i.e. 

tanks installed after the proposal of 40 CFR Part 63, Subpart LL on 09/26/96)? Do you have any new 

pitch storage tanks that are subject to Subpart LL at your facility? If so, what controls do you use to meet 

the 95% POM reduction requirement in 40 CFR §63.844(d) [please submit this information on Table(s) 1 

through 5 found in the ICR for the associated control device(s), if applicable]?

 The Wenatchee pitch tanks were installed in 1992. This installation 

date is prior to the September 1996 Primary Aluminum MACT rule proposal, so the 

pitch tanks are actually an “existing source”. However, these tanks have a control 

device that gets 95% POM removal and thus represented the “MACT floor” for “New 

Pitch Storage Tanks” under the proposed and final MACT rules. That is why the 

standard for new pitch tanks is 95% control.

2. It appears, based on the ICR responses I received, that the ICR may not have been clear in regards 

to submitting information on any controls that may be installed on existing pitch storage tanks at your 

facility that are subject to Subpart LL. If you have any existing pitch storage tanks at your facility that are 

subject to Subpart LL and that have emissions controls installed on them (even though those controls are 

not required under Subpart LL) please provide the information necessary to evaluate those controls [i.e. 

submit Table(s) 1 through 5 found in the ICR for the associated control device(s), if applicable].

Table 5 was filled out for the Liquid Pitch Scrubber system and was included with 

the submission that was mailed yesterday with the remaining data that was not 

available on May 31.

I am sorry for the need for this follow-up email. Your time is valuable and I appreciate you taking time out 
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of your busy days to provide this information.

Thanks again,

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