MEMORANDUM

DATE: September 2 9

, 201 4

TO: Phil Mulrine

, EPA OAQPS/SPPD

FROM: Bradley Nelson

, E C/R

SUBJECT: Summary of the September 24

, 201 4 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 p olycyclic a romatic h ydrocarbons (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

, 20 1 1 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
J ohn Rego, Jones Day John Hughes, Eramet Marietta Liz Marble, Eramet Marietta Glenn England, Environ Tom Gerstle, Environment Quality Managem ent

Policy Navigation Group Troy Hillier

EC/R, Incorporated Bradley NelsonIII. 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 Furnace s 1 and 1 2. 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 rep orting 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

sp ectroscopy (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 detecti on 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 tes t. The EPA will provide Eramet Marietta a list of operating parameters that it would like the facility to monitor during the PAH and Hg

test s

. The facility representatives stated that the y could provide a M aterial S afety D ata
S heet (MSDS) that w ould provide information on the composition of the electrodes.

• The E PA 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 fr om Furnace 12 is not scheduled until December 2014

. Because of this timeframe, t he 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 gro up 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 Mariettarepresentatives responded that the ir main concern was the maximum achievable control technology ( MACT ) Floor for PAH and did n’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 mo nitor 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 PlanSUMMARY OF ERAMET VOLUNTARY PAH AND MERCURY EMISSIONS TEST PLAN TO SUPPORT FERROMANGANESE AND SILICOMANGANESE NESHAP RULEMAKING

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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 variabi lity 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 unde r 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 duratio n 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 r esolution 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 r esin 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 me asurable 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 an d 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 init ial 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 i n 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 EP A review by November 24, 2014.