p. 1 of 2 

From: Bilskis, Patricia A. [mailto:Patricia.Bilskis@alcoa.com] 

Sent: Thursday, September 26, 2013 11:23 AM 

To: Putney, David 

Subject: RE: FW: TF data from primary aluminum facilities 

DavidAttached you will find a spreadsheet that contains Intalco potline primary and secondary control device total 

fluoride data, in lb TF/ton Al units. Please let me know if you have any questions concerning this data. 

Thanks much! 

Patricia Bilskis 

Environmental Specialist 

Intalco Aluminum Corporation 

Ferndale WA, 98248 

Office: 360-384-7267 

Cell: 360-201-3430 

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

Sent: Monday, September 16, 2013 8:32 AM 

To: Van Der Meyden, Henk; Bilskis, Patricia A.; Rufa, Nathan P.; Bruntz, Samuel H.; Dorey, Garr E. 

Cc: Palazzolo, Michael A. 

Subject: EXT: FW: TF data from primary aluminum facilities 

Hello all (again), 

My apologies, I realize that I should have been more specific. What I am looking for is TF emissions 

(primary and secondary) from the potlines. Emissions from the carbon bake are low and probably not 

significantly impacting the risk estimates and TF emissions are not expected from the paste plant. 

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

 
p. 2 of 2 

From: Putney, David 

Sent: Monday, September 16, 2013 10:50 AM 

To: Van Der Meyden, Henk; 'Bilskis, Patricia A.'; 'Rufa, Nathan P.'; Bruntz, Samuel H.; 'Dorey, Garr E.' 

Cc: 'Palazzolo, Michael A.' 

Subject: TF data from primary aluminum facilities 

Hello all, 

We (EPA) are finishing up our review of the emissions test results you submitted in response to the 

Information Collection Request (ICR) sent out in March of 2013. Thank you all so much for the time 

and effort you dedicated to conducting those tests and submitting the results. The next step in the 

residual risk analysis is to develop the risk modeling files for your facilities. It is essential that we use 

the best, most accurate estimates of your facilities’ emissions in these files so as to most accurately 

estimate the residual risk from your facilities (i.e., the risk remaining after application of the MACT 

standards). Through the 2013 ICR we have obtained recent, reliable data for emissions of metals and 

POM (including speciated PAH). 

However, we did not collect TF data via the 2013 ICR. During development of the risk modeling file for

the Massena East facility I obtained more recent data on TF emissions (thanks very much for that – 

Nate). The emissions data received for that facility indicated TF emissions were significantly lower than 

I had expected and allowed me to use a lower TF emission rate in the risk file for that facility. Since TF 

affects the multipathway risk assessment, the ecological risk assessment, and the acute risk 

assessment a reduction in the estimates of emissions of that pollutant can have a significant impact on 

the estimate of residual risk associated with your facility. 

With that in mind, I am asking for some recent data on TF emissions from your facilities (e.g., from 

NESHAP compliance reports). If possible, could you please send me some data (a summary table of 

values cited in NESHAP compliance reports) for a few recent, representative TF emission rates for your

facilities by COB this Friday (09/20/13)? This data would allow me to avoid using the emission rates 

allowed under the NESHAP to estimate your TF emissions (which would likely overestimate your 

facilities’ TF emissions and the associated risks).

Thanks so much, 

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