p. 1 of 5

From: Putney, David 

Sent: Tuesday, December 24, 2013 10:22 AM 

To: Coomes, Brandon 

Cc: Coomes, Jamie; Sean T. Lane 

Subject: FW: Draft emissions file for the Century Aluminum facilities 

Hello Brandon, 

Thanks for taking a look at the spreadsheet for me – I 

really appreciate your assistance in this risk assessment 

project. 

I have included part of my email response to another 

industry representative who also had questions on this 

modeling exercise (below in red text) and what I was 

requesting. Hopefully that response will help clarify my 

request. Actually, several industry contacts have reached 

out to me for clarification as my initial email was 

evidently a bit confusing (I can see how it would be). The 

direct answer to your question is that we used the 

production capacities found in Table 2 of the attached 

document. However, as I explain below, I am not expecting 

industry to do any emissions calculations at this point 

that would require capacity information. 

“Now, back to your question as to what is meant by 

“Industrial processes ...” in the non category tab portion in 

the spreadsheet? That really gets to the heart of my 

initial request. We got the non category information from 

the National Emission Inventory (NEI) databases and other 

state input. As you can imagine there is quite a bit of 

variation between how the various states and local agencies 

put data in the NEI and how they refer to the associated 

emissions sources. So, the short answer is ... I’m not 

exactly sure what is meant by “Industrial processes ...” in 

the non category tab portion in the spreadsheet. Actually, 

that is the exact sort of thing for which I’m reaching out 

to industry for assistance. I’m hoping that you could tell 

by the location, pollutants and magnitude of emissions what 

is the referenced source. Then, we will include or remove 

the associated emissions in the risk model as appropriate 

(see last paragraph below). 
p. 2 of 5 

Please do not overestimate what I am looking for in

response to my email. It really should not take too long to 

respond to my email. The portion of the spreadsheet that 

shows CY2013 is misleading – we understand that you do not 

have production data for all of CY2013 at this point. I 

believe the current year is used simply to show that it is 

a recent risk analysis and that the facility was operating 

in 2013. Please do not try to correct the spreadsheets to 

reflect your CY2013 production. 

We feel fairly confident in the source category emissions 

and locations of emissions sources since we got industry 

test data to estimate emissions and industry review of 

locations in the previous (initial) proposal. Although, if 

something jumps out at you as being obviously incorrect in 

the source category tab of the spreadsheets then you are 

welcome to bring it to my attention. 

The main thing I am requesting is for industry to review 

the non source category tab of the spreadsheets so as to 

ensure we are not including emissions in the risk modeling 

that should not be included (e.g., for a boiler that no 

longer exists), and not double counting the emissions that 

should be included (e.g., emissions that are part of 

collocated secondary aluminum operations).” 

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

From: Coomes, Brandon [mailto:Brandon.Coomes@centuryaluminum.com] 

Sent: Monday, December 23, 2013 5:22 PM 
p. 3 of 5 

To: Putney, David 

Cc: Carroll, Danny 

Subject: RE: Draft emissions file for the Century Aluminum facilities 

David, 

 

I'm having difficulty confirming the emission data from the actual emissions column (tpy) in the excel

spreadsheet for Century Aluminum Sebree (formerly Alcan). Do know what annual aluminum production rate 

was used with the ICR emission factors when calculating Sebree's emissions (tpy)? 

 

Thanks and Merry Christmas! 

 

Brandon Coomes 

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

Sent: Wednesday, December 18, 2013 8:38 AM 

To: Coomes, Brandon; Coomes, Jamie; Lane, Sean 

Subject: Draft emissions file for the Century Aluminum facilities

Hello Jamie/Brandon/Sean,

 

Please find attached to this message a draft emissions file 

(Excel spreadsheet) for the Century Aluminum primary 

aluminum production facilities. 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 Century Aluminum facilities 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 
p. 4 of 5 

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 Century Aluminum 

primary aluminum production facilities. These 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? 
p. 5 of 5 

 

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. 

 

If I might make a suggestion – you can use the filter 

function in Excel to narrow down the file to review a 

single facility at a time. 

 

I do not have any information for a contact at the Century 

Aluminum facility in West Virginia. Would you please pass 

this email and attachment along to someone at that facility 

that could review this information? Also, would you please 

forward me that person’s contact information? 

 

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
ALUMINUM—2011 [ADVANCE RELEASE] 5.13

          	 




	  
       	    	 
   




    
    
  	  
                        



  
     



  
    

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Attachment 1., p. 1. of 1