History: 

Conrad, 

RE: Fugitive emissions 

Amy M. Lincoln to: Conrad Chin 

Cc: Chuck French, friedman.beth, JKonrady, Jonathan Averback, 

Rlunn, tshillier, r.powell 

This message has been replied to and forwarded. 

06/12/2012 02:47PM 

There was clearly a misunderstanding on our last call. Felman is not considering building enclosure. 

That remains impractical due to the size and condition of the building and, more importantly, would 

create a serious health risk for our employees. The engineering study currently underway has only 

served to confirm this. What is being considered as part of that engineering study is converting some of 

the existing roof vents to collection points and routing their emissions to the baghouses. This is likely to 

involve only about 3 of the 8 roof vents visible in the picture you sent on June 2. Not only would 

several roof openings remain, but so would the many other existing vents and openings in the building 

walls, as necessary to ensure air inside the building is safe for the employees working there. At this 

time, these plans are preliminary, and our vendor continues to evaluate source-specific fugitive 

emission control options throughout the building in lieu of attempting to control emissions at the roof 

vents. Without a complete engineering study, this is all the detail we can provide you right now. As 

such, I don't see a need for a call this week. Per Troy's June 5 email, both Felman and Eramet expect to 

have the results of their engineering studies ready to share with you by the end of this month, and are 

looking to schedule a time to go over those with you in detail. I will leave it to you and Troy to agree on 

a date that works for everyone. 

Amy 

Amy M. Lincoln 

Principal 

Beveridge & Diamond, P.C. 

456 Montgomery Street Suite 1800 

San Francisco, CA 94104 

T ( 415) 262-4029 - F ( 415) 262-4040 

Alincoln@bdlaw.com 

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Please consider the environment before printing this e-mail. 

From: Conrad Chin [mailto:Chin.Conrad@epamail.epa.gov) 

Sent: Tuesday, June 12, 2012 6:14AM 

To: Amy M. Lincoln 

Cc: Chuck French; friedman.beth@ecrweb.com; JKonrady@fpiwv.com; Jonathan Averback; 

Rlunn@fpiwv.com; Conrad Chin 
Subject: Fugitive emissions 

Good morning AmyDuring our call last Thursday (June 7}, we heard Felman may consider "enclosing" the building. We are 

very much interested in finding out more details on your plans, including technical details, projected costs, 

safety considerations, and emissions reduction projection, etc. 

Is it possible we set up a call tomorrow or Thursday to discuss this? Thanks and best regards, 

Conrad K. Chin 

Mail Code D243-02 

Metals and Minerals Group 

Sector Policies and Programs Division 

Office of Air Quality Planning and Standards 

U.S. Environmental Protection Agency 

919-541-1512 (voice) 

919-541-3207 (fax)