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 sheets 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 field data sheets for the end of run 2 and all of run 

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 during the test? If they were changed, at what point 

was the heat removed? If they were changed, what is the testing company’s opinion on how the test 

results will be affected by changing sampling conditions? 

2. The reported emissions of hexavalent chromium are confusing. For example, on Table 7-5C on page 7-

17 of final report, emissions of hexavalent chromium from the paste plant are higher than those for 

total chromium. Similar data are found in the Summary 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 custody 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 finished 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 until 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.gov
p. 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 test 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 is unclear whether the metal HAP and PM samples from

the potline downcomer were collected via a heated sample probe and filter or an unheated sample 

probe and filter. 

The discussion in section 4.6.1 and the data in Table 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 Appendix A and the calibration check on page 44 of 

119 of Appendix A also indicate that ambient temperatures were expected. 

However, the associated field data sheets (see pages 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 and filters associated with sampling from the 

potline downcomer were heated during the testing. 

Thanks, 

David Putney, Environmental Engineer 
p. 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 Meyden, Henk 

Subject: PMACT ICR TEST REPORT 

David, 

Attached is the referenced report and supporting information 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 need 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