MEMORANDUM 

DATE: September 29, 2014

TO: Phil Mulrine, EPA OAQPS/SPPD

FROM: Bradley Nelson, EC/R

SUBJECT: Summary of the September 24, 2014 Meeting with the Eramet Marietta

Representatives and the U.S. Environmental Protection Agency

I. INTRODUCTION

The purpose of the meeting was to discuss the proposed polycyclic aromatic hydrocarbons 

(PAH) and mercury (Hg) testing at Eramet Marietta. This meeting summary will be available in 

the docket for this rulemaking (Docket ID No. EPA–HQ–OAR–2010–0895). The supplemental 

proposal was signed by the Administrator on September 4, 2011 and posted on the EPA website 

(http://www.epa.gov/ttn/atw/ferroa/ferropg.html), but at this date has not been published in the 

Federal Register. 

II. ATTENDEES

The following is a list of participants in the meeting.

U.S. Environmental Protection Agency

Chuck French

Phil Mulrine

Stef Johnson

Colin Boswell

Ray Merrill

Eramet Marietta 

John Rego, Jones Day

John Hughes, Eramet Marietta

Liz Marble, Eramet Marietta

Glenn England, Environ

Tom Gerstle, Environment Quality Management

Policy Navigation Group

Troy Hillier

EC/R, Incorporated

Bradley Nelson
III. SUMMARY OF DISCUSSION

The purpose of the meeting was to discuss the proposed polycyclic aromatic hydrocarbons (PAH) 

and mercury (Hg) test plan provided by Eramet Marietta. The proposed test plan was sent to the 

EPA by Eramet Marietta prior to the meeting and is provided in Attachment A.

• The representatives from Eramet Marietta propose to perform PAH and Hg testing during 

the week of October 13, 2014 on both Furnaces 1 and 12. Currently Furnace 1 is 

producing ferromanganese (FeMn) and Furnace 12 is producing silicomanganese (SiMn). 

They estimate that the test results would be submitted to the EPA in November 2014.

• The EPA provided preliminary comments on the submitted test plan. They noted that the 

spike recovery in Section 2.4.4 of the proposed test plan is important for the quality 

assurance/quality control of the analytical results. The EPA also recommended that the 

analytical lab use the same external calibration and reporting approach provided in the 

2012 ICR. The approach from the 2012 ICR is shown below:

“Collect a target volume of 1.0 cubic meter per run using a minimum sampling time of 1 

hour. Provide field blank samples for each analyte. Use high resolution mass 

spectroscopy (HRMS) option for analysis. Method 429 analysis requires addition of 

labeled standards prior to sample extraction. If the sample analysis requires dilution of 

the sample that drops the labeled isotope concentration below three times the detection 

limit, or (isotope dilution standard is diluted out or cannot be measured due to 

interference) then the analyst must develop response factors, utilize calibration response 

factors for the native compounds, and relative standard deviation (RSD) for each analyte 

(as in EPA 8270D, section 7.3 - 7.8) and report the results for each analyte following the 

procedures in 8270D, section 11.7.”

• The EPA asked that Eramet Marietta provide information on the electrodes and furnace 

operating conditions during the test. The EPA will provide Eramet Marietta a list of 

operating parameters that it would like the facility to monitor during the PAH and Hg 

tests. The facility representatives stated that they could provide a Material Safety Data 

Sheet (MSDS) that would provide information on the composition of the electrodes.

• The EPA asked about the possibility of Eramet Marietta doing additional PAH testing on 

Furnace 12 during FeMn production. The representatives from Eramet Marietta stated 

that production of FeMn from Furnace 12 is not scheduled until December 2014. Because 

of this timeframe, the representatives are unsure whether the PAH test results could be 

provided to EPA to meet the current final rule deadline of May 28, 2015.

• The EPA also asked the industry group if it would be possible to perform PAH testing at 

the inlet of the control device. They believe this test would provide data on the 

concentration of PAH fugitive emissions from the furnace building. The Eramet Marietta 
representatives responded that their main concern was the maximum achievable control 

technology (MACT) Floor for PAH and didn’t see any benefit from performing inlet 

PAH testing.

IV. Action Items

• The laboratory that Eramet Marietta has selected to do the analysis of the PAH test 

samples will contact Ray Merrill to discuss the calibration and reporting methodology for 

the October 2014 stack tests.

• The EPA will send a list of process parameters to monitor during the October 2014 PAH 

tests and include with the test reports.

• Eramet Marietta will send to EPA a revised test plan for the October 2014 tests.
Appendix A

Eramet Marietta PAH and Hg Test Plan
SUMMARY OF ERAMET VOLUNTARY PAH AND MERCURY EMISSIONS TEST PLAN TO 

SUPPORT FERROMANGANESE AND SILICOMANGANESE NESHAP RULEMAKING

SEPTEMBER 23, 2014; REVISION 0 Page 1 of 3

Eramet Marietta Inc. (EMI) is planning to conduct a voluntary test program during the week of 

October 13, 2014 to characterize polycyclic aromatic hydrocarbon (PAH) and mercury 

emissions from electric arc furnaces 1 (main baghouse outlet) and 12 (scrubber outlet) during 

production of silicomanganese and ferromanganese alloys at its facility in Marietta, Ohio. 

The overall goal of the tests is to supplement very limited data from previous tests and thereby 

gain a better understanding of the range and variability of actual emissions during production, 

using test measurement methods specified by EPA in the proposed NESHAP. 

Environmental Quality Management, Inc. (EQ) will perform the measurements, with laboratory 

analysis support from ALS in Burlington, Ontario (Canada). This summary outlines key aspects 

of the tests.

1. The objectives of the tests are:

1.1. To obtain at least three valid PAH and mercury emissions measurements at each 

exhaust;

1.2. To determine and document measurement data quality, and achieve 

measurement data quality acceptable for rulemaking purposes;

1.3. To document emissions from Furnace 12 scrubber during silicomanganese 

production;

1.4. To document emissions from Furnace 1 main baghouse during ferromanganese 

production;

1.5. To document furnace feeds and operating conditions during the tests.

2. Following is a summary of planned PAH sampling and analysis activities:

2.1. EQ will conduct four test runs (sampling and analysis) at each location in order to 

assure at least three valid test runs.

2.2. The tests will be conducted under the direction of a Qualified Source Test 

Individual (QSTI).

2.3. Each PAH sampling run will attempt to encompass one entire furnace heat cycle 

(tap to tap). It is anticipated that each sample run time will be approximately 70-

90 minutes. The sampling duration and sample gas volume will be less than in 

the 2012 tests. Based on the PAH amount (~1-160 milligrams) encountered in 

those tests, shorter runs are expected to provide sufficient PAH for analysis.

2.4. EQ will follow the procedures specified in California Air Resources Board (CARB) 

Method 429 to collect and analyze the samples. The method will be used as 

published, except the analytical procedure will be adjusted to accommodate 

potentially higher PAH concentrations based on the results of earlier tests.
SUMMARY OF ERAMET VOLUNTARY PAH AND MERCURY EMISSIONS TEST PLAN TO 

SUPPORT FERROMANGANESE AND SILICOMANGANESE NESHAP RULEMAKING

SEPTEMBER 23, 2014; REVISION 0 Page 2 of 3

2.4.1. High resolution gas chromatography and high resolution mass 

spectroscopy will be used for sample analysis.

2.4.2. Laboratory analysis will be expedited to the extent possible for fastest 

available turnaround consistent with data quality objectives. For high 

resolution analyses, a three-week turnaround is the shortest period 

provided by ALS.

2.4.3. Instrument Calibration range will be 0.002 to 2 ug/mL. The upper range 

will be expanded by dilutions and by increasing the labeled spiking levels 

(i.e. the Split Factor).

2.4.4. XAD-2 resin cartridges will be spiked based on the historic sampling 

results. A spike of 1000 ng per target compound will be used based on a 

split design of 10 and 100 ng per split.

2.4.5. The initial labeled internal standard spiking levels were selected to 

provide measurable quantities anticipating that the sample may need to 

be diluted prior to analysis. The spiking levels are designed to provide 

measurable spike recoveries at over an analytical dilution factor range of 

1 to 50 ng total PAH. At this dilution range and the planned spiking levels, 

the minimum quantifiable total PAH will range from 2.5 to 4000 ng. For a 

sample volume of approximately 1 dscm, the in-stack equivalent of the 

minimum analytical quantification limit corresponds to a total PAH 

concentration of 2.5 to 4000 ng/dscm.

2.4.6. If higher dilutions are required beyond the level at which the labeled 

internal standards can be measured, the dilute will be fortified with the 

labeled internal standards. While this represents a compromise over 

selecting higher initial spiking levels by increasing measurement 

uncertainty, it provides a means of correcting the samples for spike 

recoveries at higher PAH concentrations characteristic of the single 

7/2012 test while also providing reasonably low quantification minimums 

in the event PAH levels are lower, based on the 10/2012 tests.

3. Following is a summary of mercury sampling and analysis activities:

3.1. EQ will conduct four test runs (sampling and analysis) at each location in order to 

assure at least three valid test runs.

3.2. The tests will be conducted under the direction of a Qualified Source Test 

Individual (QSTI).

3.3. Each mercury sampling run will attempt to encompass an entire furnace heat 

cycle. It is anticipated that the sample run time will be approximately 70-90 

minutes.

3.4. Mercury test runs will be conducted during the PAH sampling runs.
SUMMARY OF ERAMET VOLUNTARY PAH AND MERCURY EMISSIONS TEST PLAN TO 

SUPPORT FERROMANGANESE AND SILICOMANGANESE NESHAP RULEMAKING

SEPTEMBER 23, 2014; REVISION 0 Page 3 of 3

3.5. Measurements will be made following USEPA Method 30B (sorbent tube 

approach). 

3.5.1. The method will be performed as published.

3.5.2. Paired sampling tubes operated in parallel will be used during each test 

run. 1 tube will be spiked with a known quantity of mercury for quality 

assurance purposes, as specified in the test method, and the second will 

be unspiked.

4. With expedited lab turnaround it is anticipated that a final report will be available for EPA 

review by November 24, 2014.