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 morning. 

One question we had is whether we can get the production 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 data and re-calculate 

emissions for all the pollutants for each location. 

Second, the sheet appears to be asking for actual 2013 emissions. 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 calculations. How did your 

consultant predict 2013 actual emission rates? 

Finally, depending how we approach the data review, the January 3rd timing will 

be tight for a number of our folks due to Holiday vacation 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 primary aluminum facilities 

Mike, 

Today would be difficult. Can we talk tomorrow? I’ll be available pretty much all day but will be 

working remotely – so it would probably be easier for 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 aluminum facilities 

David, 

We have some questions regarding your request for review of the 

emissions file. Would you be available for a call early 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, Charles L.; Hulse, David G.; Parent, 

Jordan J.; Mitchell, Kathryn M; Rufa, Nathan P.; Bilskis, Patricia A.; Blodgett, Terry L. 

Subject: EXT: Draft emissions file for the Alcoa primary aluminum facilities 

Hello Mike et. al., 

Please find attached to this message a draft emissions file (Excel spreadsheet) for the Alcoa, 

Inc. 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 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 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 Alcoa, Inc. primary aluminum production facilities (note that we did not find any noncategory emissions data for either the Intalco facility or the Wenatchee facility). 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 
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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 filter 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
ALUMINUM—2011 [ADVANCE RELEASE] 5.13

          	 




	  
       	    	 
   




    
    
  	  
                        



  
     



  
    

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Attachment 1. p. 1 of 1