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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

r equesting. 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).

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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 poin t. I believe the current year is used simply to show tha t it is a recent risk analysis and that the facility was op erating in 2013. Please do not try to correct the spreadshe ets to reflect your CY2013 production.

We feel fairly confident in the source category emi ssions and locations of emissions sources since we got ind ustry test data to estimate emissions and industry review of locations in the previous (initial) proposal. Altho ugh, if something jumps out at you as being obviously incor rect in the source category tab of the spreadsheets then yo u are welcome to bring it to my attention.

The main thing I am requesting is for industry to r eview the non source category tab of the spreadsheets so as to ensure we are not including emissions in the risk m odeling that should not be included (e.g., for a boiler tha t no longer exists), and not double counting the emissio ns that should be included (e.g., emissions that are part o f 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

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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 A lcan). Do know what annual aluminum production rat e was used with the ICR emission factors when calcula ting 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 faci lities


# Hello Jamie/Brandon/Sean,

Please find attached to this message a draft emissi ons file (Excel spreadsheet) for the Century Aluminum primar y aluminum production facilities. Columns highlighte d 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 yellow as this would complicate the development of the final emiss ions file for use in risk modeling.

The tab titled “primary Al category” includes emiss ions from the primary aluminum production operations (e. g., potlines, paste plants, pitch storage tanks, and an ode bake furnaces) at the Century Aluminum facilities as est imated via emission factors developed from test results ob tained 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 tech nology review (RTR) proposal for the primary aluminum prod uction 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

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feedback/corrections you might have on these emissi ons. A revision column highlighted in yellow is provided f or 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 Aluminu m primary aluminum production facilities. These recor ds are intended to include emissions from operations at yo ur facility which are not directly associated with pri mary aluminum production (primary aluminum emissions are addressed under the first tab, discussed above) or secondary aluminum production (secondary aluminum e missions will be addressed via the RTR associated with the s econdary aluminum source category). Revision columns highlig hted in yellow are included for emissions, pollutants, stac k parameters, fugitive parameters and latitude/longit ude. 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 ar e not highlighted in yellow). Note that fields were also added to identify if a record should be deleted, and a re viewer comment field where you can add a comment if approp riate. 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 pe rmit 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 operati on and associated emissions need not be included (so as to avoid double counting those emis sions).

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 route d 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 incl uded (so as to avoid double counting those emissions).

2. If the operation should be included, are the cited emissions representative of that operation?

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3. If the operation should be included but the cited emissions are not representative of that operation, then please provide representative annual actual em issions 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 filt er 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 pleas e 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 b y 01/03/14 and remember that you will have another opportunity to make comments and corrections during the upcoming public notice and comment period associate d with the primary aluminum production RTR supplemental pr oposal.

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

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