# p. 1 of 5

From: Putney, David Sent: Friday, December 20, 2013 7:07 AM To: 'Palazzolo, Michael A.' Subject: FW: RE: Draft emissions file for the Alcoa primary aluminum facilities



# One more time – but this time with the attachment.

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: Putney, David Sent: Friday, December 20, 2013 7:06 AM To: 'Palazzolo, Michael A.' Subject: RE: RE: Draft emissions file for the Alcoa primary aluminum facilities



# Mike,

I got your meeting notice and accepted the invitation – thanks for setting that up.

The production rates we used for the Alcoa facilities can be found in the attached document (see Table 2) except that the capacity of the Massena East facility was decreased by about 33% (due to the recent shutdown of one of the potlines at that facility), the capacity of the Rockdale facility was decreased by about 40% due to the shutdown of 2 of the potlines at that facility, and the capacity of the TN facility was decreased by 100% due to the shutdown of that facility.

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, and I’ll talk with you later this morning.

# p. 2 of 5

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: Palazzolo, Michael A. [ mailto:Michael.Palazzolo@alcoa.com ] Sent: Thursday, December 19, 2013 12:33 PM To: Putney, David Subject: RE: RE: Draft emissions file for the Alcoa primary aluminum facilities


# David,
I sent you an Outlook meeting notice for Friday morni ng.
One question we had is whether we can get the producti on rates (2013 actuals) and the pollutant emission factors used to calculate the potline emissions. It would take less time for us to simply review and comment on those rather than develop our own set of emission factors from the ICR dat a and re-calculate emissions for all the pollutants for each location.
Second, the sheet appears to be asking for actual 2013 e missions. We will not have data for December until sometime in January. So , I am assuming you just want us to forecast December production to do these calcula tions. How did your consultant predict 2013 actual emission rates?
Finally, depending how we approach the data review, the January 3 rd 

# timing will be tight for a number of our folks due to Holiday vaca tion plans.
Thanks. Talk with you tomorrow.

Mike

Michael Palazzolo Alcoa Inc. 201 Isabella Street Pittsburgh, PA 15212-5858 Ph: 412-553-4832

# p. 3 of 5

From: Putney, David [ mailto:putney.david@epa.gov ] Sent: Thursday, December 19, 2013 11:52 AM To: Palazzolo, Michael A. Subject: EXT: RE: Draft emissions file for the Alcoa primar y aluminum facilities



# Mike,

Today would be difficult. Can we talk tomorrow? I’l l be available pretty much all day but will be working remotely – so it would probably be easier f or me to contact you unless you want to set up a conference line.

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

From: Palazzolo, Michael A. [ mailto:Michael.Palazzolo@alcoa.com ] Sent: Thursday, December 19, 2013 10:08 AM To: Putney, David Subject: RE: Draft emissions file for the Alcoa primary alu minum facilities


# David,
We have some questions regarding your request for revie w of the emissions file. Would you be available for a call ear ly this afternoon to discuss? Please let me know what time works for you.
Thanks,

Mike

Michael Palazzolo Alcoa Inc. 201 Isabella Street Pittsburgh, PA 15212-5858 Ph: 412-553-4832

From: Putney, David [ mailto:putney.david@epa.gov ] Sent: Wednesday, December 18, 2013 9:33 AM

# p. 4 of 5 To: Palazzolo, Michael A.; Bruntz, Samuel H.; Dobbs, C harles L.; Hulse, David G.; Parent, Jordan J.; Mitchell, Kathryn M; Rufa, Nathan P.; Bi lskis, Patricia A.; Blodgett, Terry L. Subject: EXT: Draft emissions file for the Alcoa primary al uminum facilities



# Hello Mike et. al.,

Please find attached to this message a draft emissi ons file (Excel spreadsheet) for the Alcoa, Inc. primary aluminum production facilities. Colum ns highlighted in yellow are available for revisions or to indicate if records should be delet ed. 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 category12172” includes emissions from the primary aluminum production operations (e.g., potlines, paste plants , pitch storage tanks, and anode bake furnaces) at the Alcoa 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 previou sly had opportunity to review those items in CY2010 before the initial residual risk and technol ogy review (RTR) proposal for the primary aluminum production source category. There are, how ever, some emissions (e.g., metal HAP, dioxins, PCB, etc.) that are new to the RTR analysi s 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 thes e 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 Alcoa, Inc. primary aluminum production facilit ies (note that we did not find any noncategory emissions data for either the Intalco faci lity or the Wenatchee facility). These records are intended to include emissions from operations a t your facility which are not directly associated with primary aluminum production (primar y 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 a re included for emissions, pollutants, stack 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 are not h ighlighted in yellow). Note that fields were also added to identify if a record should be delete d, and a reviewer comment field where you can add a comment if appropriate. Please review the se 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 e missions 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

# p. 5 of 5 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.

If I might make a suggestion – you can use the filte r function in Excel to narrow down the file to review a single facility at a time.

Mike – I do not have any information for a contact at the Lake Charles facility. 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

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# Attachment 1. p. 1 of 1