10877 PM Compliance PAH Enginering Test Program Eramet - 2nd revision.pdf

Good Morning, Conrad,

Please find attached Eramet’s source testing protocol for review prior to our conference call this morning.

The source testing is scheduled to be conducted during the week of July 23.

In addition to the outlined testing, we plan to also perform speciated manganese analyses, omitted from

the original protocol.

Looking forward to our discussion at 10:30.

Thanks,

Jeff

Jeff McKinney

Manager, Safety, Health and Environmental AffairsEramet Marietta Inc.

P.O. Box 299, State Route 7 SouthMarietta, Ohio 45750

Tel: 740-374-1143 Cell: 740-350-1325

Fax: 740-374-1305

To John Rego <jregoJonesDay.com>, Jeff McKinney <jeff.mckinneyerametgroup.com>

cc “Amy M. Lincoln” <ALincoln@bdlaw.com>, Chuck French .g <French.Chuck@epamail.epa.gov>, Darcie Smith <Smith.Darcie©epamail.epa.gov>,

06/21/2012 Beth Friedman <friedman.beth@ecrweb.com>, <Jeff. McKinney©erametgroup.com>,

O2O1 PM <Konrady@fpiwv.com>, Jonathan Averback <Averback.JonathanepamaiI.epa.gov>, Richard Lunn <RLunn@fpiwv.com>, Troy Hillier <thillierpolicynavigation.com>
Our Associate Director, Steve Fruh, would like to talk with both Ferroalloy plants next week to get a better

handle on your upcoming tests in July. I believe we have already set up a call with Felman on Mondaymorning. Steve would like to set up a separate call with Eramet.

He is currently available as below for next week (all pm):Monday 1-4

Tuesday 3-4Wednesday 3-4

Please let me know when would be a good time and I will set up the call. A word of warning: his calendar

could change very fast.

Conrad K. Chin

Mail Code D243-02Metals and Minerals Group

Sector Policies and Programs DivisionOffice of Air Quality Planning and Standards

U.S. Environmental Protection Agency

919-541-1512 (voice)919-541-3207 (fax)
June 5, 2012

Mr. John Hughes

Eramet Marietta Inc.

P.O. Box 299

16705 State Route 7 South

Marietta, Ohio 45750-0299

Re: Furnace 1 Tap Hole Baghouse and Furnace Baghouse

Furnace 12 Scrubber Exhaust

Filterable Particulate Matter Compliance Emission Measurement Program

Polycyclic Aromatic Hydrocarbons, Mercury, Formaldehyde, and Hydrochloric Acid 

Engineering Emission Measurement Program

Proposal No. 10877, 2nd Revision

Dear Mr. Hughes:

Environmental Quality Management, Inc. (EQ) is pleased to submit this 2nd revision proposal 

(originally submitted April 12 and 18, 2012) to plan and conduct a compliance and engineering 

emission measurement program for Furnaces 1 and 12 at the Eramet facility in Marietta, Ohio. 

EQ proposes to conduct the following tasks at the Furnace 1 exhausts (2) and at the Furnace 12 

scrubber outlet:

1) Prepare an Intent-to-Test (ITT) Notification for review by Eramet and submittal to the Ohio 

Environmental Protection Agency (OEPA). The protocol will address filterable particulate 

matter (PM) compliance only.

2) Measure stack gas velocity, temperature, gas composition (CO2, O2 and N2), and moisture 

content according to the procedures outlined in EPA Methods 1 through 4. Three 1-hour test 

runs will be conducted at each test location (Furnace 1 – 2 sites, Furnace 12 – 1 site), during 

PM sampling only.

3) Measure the concentration and mass emission rate of total filterable particulate matter 

following the procedures in EPA Method 5. Three 1-hour test runs will be completed at each 

test location (Furnace 1 – 2 sites, Furnace 12 – 1 site). This sampling may be combined with 

Hydrochloric Acid sampling.

4) Measure the concentration and mass emission rate of Hydrochloric Acid (HCl) following the 

procedures in EPA Method 26A. Three 1-hour test runs will be completed at each test 

location (Furnace 1 – 2 sites, Furnace 12 – 1 site). This sampling may be combined with the 

filterable particulate matter train.
Mr. John Hughes -2- June 5, 2012

5) Measure the concentration and mass emission rate of Polycyclic Aromatic Hydrocarbons 

(PAHs) at each test location. One test run will be completed with a minimum sampling 

volume of 105 dscf. It is estimated that the test run will be 2 to 3 hours in duration. USEPA 

Method 23 will be utilized to complete PAH sampling. A 1-hour sampling run option is 

provided.

6) Measure the concentration and mass emission rate of Mercury (Hg) at each test location. 

One test run will be completed with a minimum sampling volume of 105 dscf. It is estimated 

that the test run will be 2 to 3 hours in duration. USEPA Method 29 will be utilized to 

determine total Hg emissions. If Hg speciation is needed (elemental, oxidized, particle 

bound and total), ASTM D6784-02 could be used as an option. An optional cost for Hg 

speciation and a 1-hour sampling run is provided.

7) Measure the concentration and mass emission rate of formaldehyde at each test location. 

One test run will be completed at each sampling location. USEPA Method 316 will be 

utilized to determine formaldehyde emissions.

8) PAH, HCl, formaldehyde, and Hg sampling will be completed for engineering purposes. A 

single test run is proposed for PAH, formaldehyde, and Hg at each exhaust.

9) Reduce all field data, conduct gravimetric analyses, manage other analyses, and perform 

computer calculations.

10) EQ will prepare two draft reports. An engineering report for HCl, PAH, formaldehyde, and 

Hg will be provided for review and a compliance PM test report will be prepared for review. 

Four bound copies and a digital copy of each final report will be provided. 

Facility personnel will be responsible for monitoring process operations, collecting process data 

for inclusion in the summary report, providing safe and adequate access to the sampling 

locations, and providing sufficient electrical power for testing purposes. Please note that due to 

the quantity of engineering testing to be completed, the scissor lift will not be sufficient to 

complete the testing. Scaffolding (or a similar structure) will be needed at the interior baghouse 

(tap hole) sampling location on Furnace 1 due to the number of sampling trains involved. EQ 

can provide a schematic of the scaffold layout to access the sampling location.

The firm-fixed price to complete the scope of work is $55,500. The optional Hg speciation could 

be completed at an additional cost of $1,500. Six experienced source test personnel have been 

budgeted for four days on site, with two additional test personnel needed for the engineering 

testing on Furnace 1. If 1-hour test runs are chosen rather than 2-hour test runs for the 

engineering portion of the project, the firm-fixed price to complete the scope of work would be 

$54,000. A tentative project schedule is provided in Table 1. I suggest a pretest meeting at your 

convenience to review the schedule prior to the test program.

EQ is available July 23 to July 27, 2012 to complete the test program. The services outlined in 

this proposal are subject to Exhibit 1, “Emissions Testing Terms and Conditions.” Invoices will 
Mr. John Hughes -3- June 5, 2012

be submitted monthly based on percent completion. Our invoice payment options are provided 

at the end of this proposal. Terms are net 30 days. This proposal is valid for 90 days.

Table 1. Tentative Test Schedule

Monday, July 23, 2012 • Set up test equipment at the Furnace 1 baghouses.

• Complete 2 PM compliance test runs.

Tuesday, July 24, 2012 • Complete PM compliance Run 3 at Furnace 1.

• Complete engineering testing at Furnace 1.

• Set up equipment at Furnace 12 scrubber.

Wednesday, July 25, 

2012

• Complete PM compliance testing at Furnace 12 (3 runs).

• Complete engineering testing at Furnace 12.

• Tear down equipment and depart site.

Thursday, July 26, 2012 • Contingency.

EQ’s standard corporate policy requests our clients to provide written authorization to perform 

services. If you have any questions about our proposed approach or cost, or if you need 

additional information, please contact me at (513) 825-7500, extension 251, or e-mail at 

tgerstle@eqm.com. We look forward to working with you again.

Sincerely,

ENVIRONMENTAL QUALITY MANAGEMENT, INC.

Tom Gerstle

Manager, Air Compliance
Mr. John Hughes -4- June 5, 2012

ENVIRONMENTAL QUALITY MANAGEMENT, INC.

EXHIBIT 1

EMISSIONS TESTING TERMS AND CONDITIONS

Client Name: Eramet Marietta, Inc.

1. Delay Time Charges – Client will ensure consistent process operation for the duration of 

each test. If testing is delayed through no fault of EQ, including inclement weather that 

threatens the safety of EQ personnel, Client agrees to pay EQ for the delay time for the 

entire test team at the hourly rate of $950.

2. Cancellation/Postponement – In the event of project cancellation or postponement by the 

client within 15 working days of the scheduled test date, the client agrees to compensate 

EQ for incurred preparation costs in the amount of 10% of the project total.

3. Sampling Ports – Client will provide unobstructed sampling ports that meet the minimum 

requirements of EPA Method 1, and will provide safe access to same that meets OSHA 

requirements.

4. Sampling Platform – Client will inspect each sampling platform that is greater than 10 feet 

from the ground and is exposed to the atmosphere to ensure that it is safe for use. EQ will 

need scaffolding at the Furnace 1 tap hole baghouse.

5. Utilities – Client will provide 60-cycle, 120-volt, 20-ampere, grounded electrical circuit 

within 50 feet of the sampling ports, or as specified by EQ in additional correspondence.

6. Process Information – Client will monitor process conditions during test periods and 

provide to the EQ project manager such information as may be necessary to perform the 

required test calculations and reporting.

7. Expansion of Scope – Work requested by the Client and performed by EQ that is not within 

the original scope of work described in the proposal, will be charged to the Client. EQ will 

inform the Client in writing of the expected cost of the additional work to be performed. 

The Client will alter or reissue the purchase authorization to cover the additional charges.

8. Confidentiality – EQ will maintain the strictest confidentiality on all information 

considered by the Client to be Company Confidential. All test results will be submitted 

only to the Client unless formally directed to do otherwise.

9. Limitation of Liability – In recognition of the relative risks, rewards, and benefits of the 

project to both the Client and EQ, the risks have been allocated such that the Client agrees 

that, to the fullest extent permitted by law, EQ’s total liability to the Client for any and all 

injuries, claims, losses, expenses, damages, or claim expenses arising out of this agreement 

from any cause, shall not exceed EQ’s fee for this project. Such causes include, but are not 

limited to, EQ negligence, errors, omissions, or breach of contract.

Under no circumstances shall EQ or any of its affiliates have any liability whatsoever for 

any compensatory, punitive, special, indirect, incidental, or consequential damages, 
Mr. John Hughes -5- June 5, 2012

including, but not limited to, loss of profit or revenue, loss of use, lost production, or 

consequential property damage; capital cost of replacement equipment; or claims resulting 

from contracts between Client and its customers and/or suppliers.

10. Standard of Care – In providing services under this Agreement, EQ shall perform in a 

manner consistent with that degree of care and skill ordinarily exercised by members of the 

same profession currently practicing under similar circumstances at the same time and in 

the same or similar locality.

11. Indemnification – EQ agrees, to the fullest extent permitted by law, to indemnify and hold 

harmless the Client, its officers, directors and employees (collectively, Client) against all 

damages, liabilities or costs, including reasonable attorneys' fees and defense costs, to the 

extent caused by EQ’s negligent performance of professional services under this 

Agreement and that of its subconsultants or anyone for whom EQ is legally liable.

The Client agrees, to the fullest extent permitted by law, to indemnify and hold harmless 

EQ, its officers, directors, employees, and subconsultants (collectively, EQ) against all 

damages, liabilities, or costs, including reasonable attorneys' fees and defense costs, to the 

extent caused by the Client's negligent acts in connection with the Project and the acts of its 

contractors, subcontractors, or consultants or anyone for whom the Client is legally liable.

Neither the Client nor EQ shall be obligated to indemnify the other party in any manner 

whatsoever for the other party's own negligence or for the negligence of others.

12. Invoicing and Terms of Payment – Invoices for EQ services shall be submitted on a 

periodic basis, and shall be payable within 30 days after the invoice date. If the invoice is 

not paid within 45 days of the due date, invoices shall bear interest at one-and-one-half 

(1.5) percent of the past due amount per month, which shall be calculated from the invoice 

date. Payment thereafter shall first be applied to accrued interest and then to the unpaid 

principal. If the invoice is not paid within 60 days, EQ may, without liability whatsoever to 

the Client and after giving 7 days written notice, suspend services under this agreement 

until all past due accounts have been paid.

13. Dispute Resolution – Any claims or disputes made during design, construction, or postconstruction between the Client and EQ shall be submitted to binding arbitration. The 

Client and EQ agree to include a similar dispute resolution agreement with all contractors, 

subcontractors, subconsultants, suppliers, and fabricators involved in this project, thereby 

providing for arbitration as the primary method for dispute resolution between all parties.

____________________

Authorization to Proceed

____________________

Date
Mr. John Hughes -6- June 5, 2012

ENVIRONMENTAL QUALITY MANAGEMENT, INC.

INVOICE PAYMENT OPTIONS

For your convenience, EQ provides the following options for your payment. Please contact us at 

800-229-7495 with any questions.

1) Check payment by mail:

Environmental Quality Management, Inc.

P.O. Box 643043 

Cincinnati, OH 45264-3043

2) Automated Clearing House (ACH) information:

US Bank

Routing Number 042000013

Account Number 480401595

3) Credit Card Payment:

Please call our corporate office at 800-229-7495 and contact Ms. Barb Ore (extension 

204) or Ms. Shalena Pritchett (extension 276) and provide the following information:

• Invoice number and amount

• Name on credit card

• Credit card number

• Expiration date

• Credit card security code on back of card

• Zip code of credit card billing address

4) Please include the invoice number(s) with all payments.

Thank you for your prompt payment.
Felman Proposal Revision06l 91 2A.pdf

Good Morning Conrad,

Attached is the Felman’s source testing protocol for your review prior to the 10:30 AM EDT conference

call today. We are tentatively scheduled to conduct this stack test the week of July 16, 2012.

Talk with you and your team at 10:30 AM today.

Thank You Conrad

EHS ManagerFelman Production Inc.

4442 Graham Station Road

Letart WV 25253

Direct (304) 882-1413

Cell (304) 812-0799

Fax (304) 882-3853