# E C 

# / R Incorporated Providing Environmental Technical Support Since 1989

1 MEMORANDUM

DATE: August 2

, 201 3

TO: Conrad Chin

, EPA OAQPS/SPPD/ MMG

FROM: Bradley Nelson, EC/R, Inc.

SUBJECT: Summary of the July 31, 2013 Meeting with the Eramet Marietta, Felman

Production and the U.S. Environmental Protection Agency

I. INTRODUCTION

Eramet Marietta and Felman Production requested this meeting with EPA to discuss the status of

the Final Rule for the Ferroalloys Production NESHAP (40 CFR Part 63, subpart XXX ). This

meeting summary will be available in the docket for this rulemaking (Docket ID No. EPA

– HQ

–

OAR

– 2010

– 0895 ). The proposed rule for ferroalloys production wa s published in the Federal

Register on November 23, 20 1 1 (7 6 FR 72508 ).

II. ATTENDEES

The following is a list of participants in the meeting.

U.S. Environmental Protection Agency

Chuck French

Steve Fruh

Conrad Chin

Darcie Smith

Rochelle Boyd

Colin Boswell

Steffan Johnson

Donna Lee Jones

Eramet Marietta

John Willoughby , Eramet Marietta (by phone)

Jeff McKinney, Eramet Marietta

Ron Hawks

, QSEM Solutions

J ohn Rego

, Jones Day2

Felman Production

John Konrady, Felman Production

Shawn McCutchan, Felman Production

Laura McAfee, Beveridge and Diamond

Policy Navigation Group

Jonathan Gledhill

EC/R Incorporated

Bradley Nelson

III. SUMMARY OF DISCUSSION

The group discussed the proposed fugitive control options, potential opacity limits, Residual risk

modeling inputs, non

- manganese emission issues, and the schedule for the Ferroalloys Risk and

Technology Review (RTR). A copy of this agenda is provided in Attachment A of this mee ting

summary

. The industry group did not have any specific comments on the agenda. The following

is a brief summary of the major points that were discussed during the meeting

.

John Konrady started the meeting by stating that Felman Production has ceased production of

Silicomanganese (SiMn) from the three furnaces at their facility. He stated that Furnace 5 was

shut down in May 2013 for repairs, and Furnaces 2 and 7 have now ceased operation due to the

SiMn market . He stated that the current sales price for SiMn has gone down so much that it is no

longer economic ally reasonable to produce SiMn at their facility. Felman Production plans to

reevaluate market conditions in September/October of this year to determine whether operations

will resume or if the plant will remain closed for an additional period of time.

Summary of Fugitive Control Options

– Eramet Marietta

 Eramet Marietta provided a presentation of a feasibility study for control of fugitive

emissions. A copy of the presentation is provided in Appendix B.

 Eramet Marietta proposes to partition off the emission areas, improve tapping capture

from the furnaces, install a canopy hood in each of the buildings to capture fugitive

emission, install casting capture in the Furnace 1 building, and improve capture of casting

and metal transfer in the MOR building.

 The captured emissions would be directed to existing control devices located at each of

the buildings. The feasibility study shows that the existing control devices can meet the

increased volume and particulate loading.

 Eramet Marietta believes that opacity emissions from the building will still occur, but

should be greatly reduced with the new capture systems in place.

 Eramet Marietta estimates the capital cost of the proposed changes to be 9

- 12 million

dollars.3

Summary of Fugitive Control Options

– Felman Production

 Felman Production presented some schematics of their proposed capture system, but did

not want to provide a copy to the EPA, because they are still refining the appro a ch.

 Felman Production proposes installing capture along the roofline and routing the captured

emissions to the existing Furnace 5 baghouse. Furnace 5 is currently not in operation and

the plan is to only operate Furnaces 2 and 7.

 The facility plans to close t he roof vents and install 4 fans in various locations along the

roofline to move the fugitive emissions to the Furnace 5 baghouse at an estimated cost of

3

- 4 million dollars.

 The final stage of the proposed plan is to install a new dedicated baghouse to co ntrol the

fugitive emissions from the roofline and operate Furnace 5 with the associated Furnace 5

baghouse.

Residual Risk Model Inputs

 The EPA is currently reviewing the response factor published by the Agency for Toxic

Substances and Disease Registry ( ATSDR) for manganese. The ATSDR listed the

Minimal Risk Level of manganese to be 0.3 micrograms per cubic meter (μg/m 3 )

.

 The response factor for manganese that was used for the Ferroalloys Production

NESHAP proposed rule was 0.05 μg/m 3 published by the EPA Integrated Risk

Information System (IRIS).

 The EPA plans to do a multi

- pathway assessment of mercury emissions from the

facilities. Emissions of dioxin/furans, polycyclic aromatic hydrocarbons (PAH), and

polychlorinated biphenyls (PCB) will also be assessed to determine if a refined analysis

is needed.

 The facilities offered to provide information to EPA to help perform the refined

assessment analyses.

 The EPA acknowledged the receipt of the test results of the March 2013 testing that was

conducted at both Eramet Marietta and Felman Production. The test reports provided test

data from the control device outlets, but no test data for fugitive emissions.

 The EPA intends to use emission factors to estimate pollutant emissions from fugitive

sources. They also plan to use the manganese percentages supplied by the facilities to

estimate manganese fugitive emissions for development of the modeling data.

 The EPA intends to use capture efficiencies that are lower than the facility’s assessments

to estima te HAP pollutant emissions from fugitive sources for development of the

modeling data.4

Non

- Manganese Issues

 The EPA intends to investigate mercury control as an above the floor option for reducing

mercury emissions from the furnaces. The above the floor option will examine the

economics as well as the cost effectiveness of installing activated carbon injection.

 Depending on the results of the risk assessment, the EPA may also review options for

controlling PAH.

 The EPA noted that much of the dioxin/furan and PCB test data was measured below the

detection limit and does not believe these pollutants to be a risk driver.

T imetable/Deliverables

 The EPA believes that the fundamental changes to the proposed rule will require that they

prepare a supplemental proposal, rather than developing a final rule.

 The EPA stated that they are in discussion with the litigants regarding the deadline for the

final rule which is December 10, 2013.5 ATTACHMENT A

DRAFT MEETING AGENDA6 DRAFT AGENDA

Ferroalloys Production RTR

Meeting with EPA, EMI and Felman

in Room E201, EPA Building, Research Triangle Park, NC

Date and Time: July 31, 2013, from 10:30 am

– 2:00 pm (Eastern Time)

Call

- in number is: 919

- 541

- 4557

Topics:

1. Introduction s

2. Summary of Fugitive Particulate Control Options (EMI, Felman): 30

- 40 minutes

3. Potential Opacity Limits (All) : 10

- 20 minutes

4. Update on Residual Risk Model Inputs (EPA)

A. Current particulate emissions inventories: 10

- 15 minutes

B. Updated physical parameters from ICR responses: 5

- 10 minutes

C. Choice of manganese toxicity factor: 5 minutes

5. Update on Non

- Manganese Issues (EPA)

A. Results of supplemental stack tests for curr ently unregulated pollutants: 5

- 10

minutes

B. Multipathway risk assessment: 5 minutes

C. Potential "above the floor" controls: 10

- 15 minutes

6. Completion of Residual Risk Rulemaking

A. Timetable and deliverables ( EPA): 5

- 10 minutes

B. Next steps, follow

- up meetings (EPA, EMI, Felman): 1 5

- 20 minutes7 ATTACHMENT B

QSEM Solutions Presentation