p. 1 of 3

From: Putney, David
Sent: Monday, July 01, 2013 2:48 PM
To: 'McCaskill, William L.'
Cc: Palazzolo, Michael A.; Van Der Meyden, Henk; Serne , Jim; Garwood, Gerri Subject: RE: RE: PMACT ICR TEST REPORT

Larry,

I have several questions about the test report, and I am requesting your assistance (and that of your testing company) in interpreting the test results.

1. As mentioned in my previous email, the field data s heets associated with sampling of the potline downcomer (see pages 46 – 51 of 119 of Appendix A) indicate that the sample probe and filter were heated during run 1 and most of run 2 whereas the f ield data sheets for the end of run 2 and all of ru n 3 cite these temperatures as “NA.” You stated that the technician made a mistake and began the test using heat. When the mistake was realized, did the technician continue under the same sampling conditions or were sampling conditions changed duri ng the test? If they were changed, at what point was the heat removed? If they were changed, what i s the testing company’s opinion on how the test results will be affected by changing sampling condi tions?

2. The reported emissions of hexavalent chromium are c onfusing. For example, on Table 7-5C on page 7- 17 of final report, emissions of hexavalent chromiu m from the paste plant are higher than those for
total chromium. Similar data are found in the Summa ry of Results section of Appendix B (see pages 51 – 53 of 121 in Appendix B). Is there a reason why the hexavalent chromium is higher than the total
chromium?

3. The total chromium and hexavalent chromium analyses do not appear to match what was requested via chain of custody forms (see sample chain of cus tody form on page 59 of 121 in Appendix B). The chain of custody forms request hexavalent and total chromium analyses on all three sample fractions. It appears that one sample fraction was analyzed for hexavalent chromium and the other two were analyzed for total chromium. I could not find any explanation for this change in the lab report or test narrative.. Is this interpretation of what happened correct?

I also want to let you know that we have not finish ed reviewing the report yet, and we may have other questions in the future. We are trying to resolve questions as we find them instead of holding them u ntil the
end.

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.govp. 2 of 3

From: McCaskill, William L. [ mailto:Larry.McCaskill@alcoa.com ] Sent: Wednesday, June 26, 2013 10:45 AM
To: Putney, David
Cc: Palazzolo, Michael A.; Van Der Meyden, Henk; Serne , Jim Subject: RE: RE: PMACT ICR TEST REPORT

David,

Your observation is correct. After consulting with TRC, the technician made a mistake and began the te st using heat and the mistake was realized during the second run and corrected. 

# Larry McCaskill

Sr Air Compliance Specialist ALCOA - Mt Holly

FAX 843-572-5378

VOICE 843-572-5246

MOBILE 704-773-1077 INTERNET Larry

. McCaskill @ Alcoa

. com

From: Putney, David [ mailto:putney.david@epa.gov ] Sent: Tuesday, June 25, 2013 4:14 PM
To: McCaskill, William L. Cc: Palazzolo, Michael A.; Van Der Meyden, Henk Subject: EXT: RE: PMACT ICR TEST REPORT

William,

During our analysis of the ICR emissions testing at your facility we came across an inconsistency for which I need some clarification. Specifically, it i s unclear whether the metal HAP and PM samples from the potline downcomer were collected via a heated s ample probe and filter or an unheated sample probe and filter.

The discussion in section 4.6.1 and the data in Tab le 7-3A of the final report (see pages 4-3 and 7-8 of the Final Report attachment, respectively) indicate that the sample probe and filter were not heated. The discussion of Method 1 on page 40 of 119 of App endix A and the calibration check on page 44 of 119 of Appendix A also indicate that ambient temper atures were expected.

However, the associated field data sheets (see page s 46 – 51 of 119 of Appendix A) indicate that the sample probe and filter were heated. Actually, the field data sheets for run 1 and most of run 2 indicate heating of these devices whereas the field data sheets for the end of run 2 and all of run 3 cite these temperatures as “NA.”

Please clarify/confirm whether the sample probes an d filters associated with sampling from the potline downcomer were heated during the testing.

Thanks,

David Putney, Environmental Engineerp. 3 of 3

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: McCaskill, William L. [ mailto:Larry.McCaskill@alcoa.com ]
Sent: Thursday, May 30, 2013 9:28 AM
To: Putney, David
Cc: Shroup, Michael; Palazzolo, Michael A.; Van Der Me yden, Henk Subject: PMACT ICR TEST REPORT

David,

Attached is the referenced report and supporting in formation for the testing that was conducted at the Alcoa – Mt Holly facility in April. I will also be forwarding a hard copy of the report to you in the regular mail.

Please let me know if you have any questions or nee d additional information.



# Larry McCaskill

Sr Air Compliance Specialist ALCOA - Mt Holly

FAX 843-572-5378

VOICE 843-572-5246

MOBILE 704-773-1077 INTERNET Larry

. McCaskill @ Alcoa

. com