1 

### Putney, David

From: Mitchell, Kathryn M <Kathryn.Mitchell@alcoa.com> Sent: Friday, June 06, 2014 8:05 PM To: Putney, David Cc: Bilskis, Patricia A.; Palazzolo, Michael A. Subject: RE: FW: PM from paste plant at Intalco facility

Hi David,

We have been actively looking into this, and, we do have some preliminary insights. First, it has beco me apparent that the fundamental underlying issue is that the Intalc o Paste Plant Dry Coke Scrubber is steady state and our production is variable. Specially, Intalco has two parallel press es (A phase and B phase) that can run either simult aneously or independently. The first two source test runs were conducted during the operation of only one pha se for the majority of time. The third run was conducted durin g full production (A phase and B phase operating simultaneously). Production in tons/hr for runs 1, 2, and 3 were 18.2, 11.9, and 30.8 respectively.

Accordingly, if you look only at the third run, our result was 0.039 lbs PM/short ton anode produced. Although I’m uncertain about the exact statistics you intend to use to set the standard, if you average the best fi ve source tests from all facilities plus two sigma, then the limit would be 0.050 lbs PM/short ton.

So, although we haven’t fully vetted o ur collective thoughts on this, we are thinking abo ut what it might look like to set a standard in the rule with the requirement for sourc e testing to occur during full production (both pre sses running).

We are also talking with the other facilities to as sess if there is anything else especially different about the paste plant at Intalco from those found at the other primary alumi num reduction facilities. We are still collecting i nfo and have planned a discussion to review this issue again int ernally on Tuesday.

What is your current timeline for your next deadlin e and would you be available sometime to talk next Wednesday, June
11th?

Sincerely, Kathryn Mitchell
Alcoa Intalco Works Environmental Manager

360.961.6720

From: Putney, David [mailto:putney.david@epa.gov] Sent: Friday, June 06, 2014 1:29 PM
To: Mitchell, Kathryn M Subject: EXT: FW: PM from paste plant at Intalco facility

Hello Kathryn,2

Just got my electronic reminder again. Do you have any insights as to the cause of the higher PM emiss ions from the paste plant at the Intalco facility? Are these emissions untypically high (unrepresentative) for t hat source? Or, was the baghouse perhaps hampered by a bag leak at the time of the testing?

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: Putney, David

Sent: Friday, May 30, 2014 8:46 PM

To: 'Mitchell, Kathryn M'

Cc: Palazzolo, Michael A.; Bilskis, Patricia A. Subject: RE: PM from paste plant at Intalco facility

Hello Kathryn,

Just wanted to touch base on the paste plant PM tes ting (not trying to pester you, it’s just that the reminder popped up on my electronic calendar). Have you come across any historical test data (or maybe even mor e recent data) that suggests PM emissions from the pa ste plant at your facility are typically lower than the 0.092 lb/ton anode that the 2013 ICR test data indicated? Or, did you maybe discover that something was “dif ferent” during the ICR test that renders those results unre presentative of the normal paste plant operations?

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: Mitchell, Kathryn M [ mailto:Kathryn.Mitchell@alcoa.com ]

Sent: Friday, May 23, 2014 11:47 AM

To: Putney, David; Bilskis, Patricia A.

Cc: Palazzolo, Michael A. Subject: RE: PM from paste plant at Intalco facility

Thanks David f or the feedback. Good questions. Trish and I will p ull some info together for you and circle back as soon as practicable.

Meanwhile, can you provide us the grain loading for the other facilities you referenced?3

Kathryn Mitchell

From: Putney, David [ mailto:putney.david@epa.gov ]
Sent: Friday, May 23, 2014 7:45 AM
To: Bilskis, Patricia A. Cc: Mitchell, Kathryn M; Palazzolo, Michael A. Subject: EXT: PM from paste plant at Intalco facility

Hello Patricia,

I’ve been going over the 2013 testing ICR results w ith my contractor and the results for PM testing fr om the paste plant at the Intalco facility caught my e ye. Specifically, the average PM emissions from you r paste plant (i.e., 0.092 lb PM/ton anode) are about 2 1⁄2 times those of the next highest emitting paste plant that was tested (i.e., 0.036 lb PM/ton anode, which was in turn more than twice the value of th e next highest emitter). The practical implications o f this situation is that it would appear (at this p oint, anyway) that the paste plant at the Intalco facilit y would not meet the MACT floor for PM (surrogate f or metal HAP) without upgrades.

So, I’m wondering if there is anything especially d ifferent about the paste plant at the Intalco facil ity from those found at the other primary aluminum redu ction facilities. That is, are you aware of any specific reason(s) why the PM emissions from the pa ste plant at Intalco would be higher than those from the paste plants at the other facilities? For example, do the other facilities utilize membrane b ags whereas Intalco does not?

Of course, we (my contractor and I) could simply ha ve an error in our math. That is to say, if you fin d a different value for average PM emissions from the p aste plant at the Intalco facility (i.e., different than 0.092 lb PM/ton anode) based on the testing done la st year, then please point that out to me and we’ll look at the situation again. Obviously I want to ge t the MACT floors correct in the upcoming supplemental proposal associated with the primary a luminum NESHAP RTR amendments.

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