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April 10, 2015 

Memorandum 

Subject: Summary of Conference Call with Alcoa and Aluminum Association 

Representatives 

From: David Green and Matt Hakos, RTI International 

To: David Putney, EPA/OAQPS 

I. Purpose 

 The purpose of the call was to clarify issues raised in public 

comments on the supplemental proposal for primary aluminum reduction plants, 

and to get information for improved cost estimates.

II. Date and Time 

 The call was held April 8, 2015 between 10:00 a.m. and 10:45 a.m. 

III. Attendees 

 David Putney, EPA/OAQPS 

 David Green, RTI International 

 Matt Hakos, RTI International 

 Curt Wells, Aluminum Association 

 Mike Palazzolo, Alcoa 

 Henk van der Meyden, Alcoa 

IV. Summary 

 A. Recalculation of Anode Bake Furnace Particulate Matter MACT Floor. 

In their public comment, Alcoa provided corrections to bake oven emissions 

for their facilities and recommended that EPA collect data from previous 

years for all facilities to expand the database. Alcoa representatives 

clarified that their analysis did not take into account data from Century 

Aluminum that was not available to them and thus the recalculation of the 

MACT floor that they provided did not reflect the actual 5 plants making up 

the MACT pool. With regard to additional emissions test data from non-Alcoa 

facilities, EPA stated that Century Aluminum may not be subject to 

particulate matter (PM) limits and may not have PM emissions data available. 

Alcoa suggested that Century may have bake furnace PM data collected during 

EPA Method 315 testing for POM. EPA will contact Century Aluminum and 

request any additional PM emissions data they may have for the anode bake 

furnaces located at their facilities. 

 B. Variability on Intalco Emissions Test Data. 

EPA asked if there was an explanation (e.g. control equipment or raw 

materials) for the unusually high variability in the PM emissions from the 

Intalco anode bake furnace, citing a factor of 27 between the highest and 

lowest test runs. Alcoa representatives noted that all of the other 

facilities had emission test runs with about a ten-fold variation between 

the highest and lowest runs and suggested that the level of variability at 
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Intalco may not be unexpected. Alcoa representatives noted that they did not 

know the reason for the variability at Intalco but that it could be related 

to differences in production rate, or the age of the bags in the fabric 

filter. Alcoa representatives will contact Intalco staff and request any 

information they may have that would account for the higher variability in 

PM emissions from the anode bake furnace located at their facility. 

 C. Installation of Testing Equipment for Proposed Standards. 

Alcoa representatives clarified that the Wenatchee plant had neither a 

manifold system nor a cassette system installed for measurement of secondary 

fluoride emissions in two of their potlines. Wenatchee currently monitors HF 

(as a surrogate for TF) using a CEMS, as permitted by the current rule. In 

order to demonstrate compliance with POM and PM standards for potlines, 

either a manifold or cassette system would be required. Alcoa 

representatives stated that there was no access to the roof. Rough cost 

estimates for installation of sampling systems were $600,000 to $800,000 

however Alcoa agreed to provide more detailed estimates based on previous 

installations in the 1990's and in 2010. EPA also asked about the 

feasibility of basing PM and POM emissions estimates for the potlines 

without manifolds on measurements of those pollutants from the potline that 

is currently equipped with a manifold, as is allowed for HF measurements 

under current §63.848(d). 

 D. Discrepancy Between Test Report and Summary Emissions Data Provided 

in Public Comment. 

Alcoa representatives confirmed that the results for Intalco bake furnace PM 

emissions given in the test report for testing conducted in June of 2011 

were correct and that the data summary table in the public comment contained 

a transcription error. 

 E. Presence of Bag Leak Detection Systems (BLDS) at Alcoa Rockdale and 

Lake Charles Carbon Facilities. 

Alcoa representatives stated that the Rockdale bake furnaces had a total of 

21 stacks, none of which have BLDS; the Rockdale paste plant has one stack 

with no BLDS; and the Lake Charles paste plant has one stack with no BLDS.