From: John Rego [mailto:jrego@jonesday.com] 

Sent: Tuesday, October 02, 2012 4:55 PM 

To: Conrad Chin 

Cc: Jonathan Averback; chin.conrad@epa.gov; Chuck French; Beth Friedman; Steve Fruh; 

jeff.mckinney@erametgroup.com; jskonrady@fpiwv.com; lmcafee@bdlaw.com; 

thillier@policynavigation.com 

Subject: Re: Ferroalloy - recent emissions test data

Conrad: 

Attached is a revised page from the stack test consultant with a correction to the flow rate discrepancy 

in Table 2-12. Thanks for catching that error. Unfortunately, this demonstrates that the consultant's 

completion of QA/QC, which is documented in the report as Appendix E, does not ensure there are no 

errors in the report. 

In terms of data acceptable for use in the MACT analyses, as I noted in my email, the PAH result for 

Furnace 12 appears to be inconsistent, by multiple orders of magnitude, with all of the other PAH 

measurements at EMI and Felman, so EMI does not believe it is credible. At this point, neither EMI nor 

the testers have identified anything unusual with respect to the operations at the time of the test that 

could account for such a deviation. I will let you know if/when we come up with more. 

I will also let you know if the QA/QC'd results for any other parameters seem anomalous to EMI. 

John 

John Rego • Environmental, Health & Safety

901 LAKESIDE AVENUE • CLEVELAND, OHIO 44114 

DIRECT 216.586.7542 • FAX 216.579.0212 • JREGO@JONESDAY.COM

************************************************************************************

From: Conrad Chin <Chin.Conrad@epamail.epa.gov> 

To: John Rego <jrego@JonesDay.com> 

Cc: Chuck French <French.Chuck@epamail.epa.gov>, "Beth Friedman" <friedman.beth@ecrweb.com>, 

jeff.mckinney@erametgroup.com, Jonathan Averback <Averback.Jonathan@epamail.epa.gov>, 

jskonrady@fpiwv.com, 

lmcafee@bdlaw.com, Steve Fruh <Fruh.Steve@epamail.epa.gov>, thillier@policynavigation.com, 

chin.conrad@epa.gov 

Date: 10/02/2012 04:09 PM 

Subject: Re: Ferroalloy - recent emissions test data

Thanks John. 
My intention was to confirm that the test data had been reviewed and qa/qc by your party. I understand 

now that your review is still ongoing. And we appreciate your effort in providing us a report as quick as 

you can while you are still reviewing the report. 

Could you please let me know once you have completed the review of the test report? We would like to 

know if there are any test data that we should not include in our future analysis. 

For example, the email I sent you yesterday in an effort to clarify the following: 

In Table 2-12, there was only one run. 

How come the volumetric flow rate is different between the run value and the average value? (For 

example, the run value was 158,693 dscfm. The average value was 164,865 dscfm.) 

Thanks and have a wonderful evening. 

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) 

*************************************************************************************

From: John Rego <jrego@JonesDay.com> 

To: Conrad Chin/RTP/USEPA/US@EPA 

Cc: Jonathan Averback/DC/USEPA/US@EPA, Chuck French/RTP/USEPA/US@EPA, "Beth Friedman" 

<friedman.beth@ecrweb.com>, Steve Fruh/RTP/USEPA/US@EPA, jeff.mckinney@erametgroup.com, 

lmcafee@bdlaw.com, jskonrady@fpiwv.com, thillier@policynavigation.com 

Date: 10/02/2012 03:40 PM 

Subject: Re: Ferroalloy - recent emissions test data

Thanks Conrad. You should not, however, assume that EMI considers all reported results from the July 

2012 stack test to be "accurate and representative." RTP has been relentless in asking for the report -- to 

the point of placing daily "When will we get the report?" calls -- so EMI provided RTP with a copy of EQ's 

report as soon as it became available. Our review of the report is ongoing. 
You seem to be disregarding recent correspondence where you and EMI have both acknowledged 

material differences between some of the 2010 data and some of the 2012 data, most notably the 

mercury and PAH data. These data demonstrate, at a minimum, variability in emission rates, which is 

not surprising given the natural variability in raw materials and operating conditions, as well as the low 

concentrations of some parameters, so suggesting that EMI has implicitly agreed that any single data 

point is "representative" is unfair and unscientific to say the least. 

Moreover, as you have previously acknowledged, the reported 2012 PAH concentration from Furnace 12 

is two orders of magnitude higher than the reported 2010 concentration from the same source and, it 

appears, at least two orders of magnitude higher than the reported 2012 PAH concentration from any 

other EMI or Felman ferroalloys furnace. EMI believes the 2012 result is erroneous, but we have not yet 

determined the reason. 

If there is any remaining confusion regarding what may be assumed from EMI's submittal of the 

requested report, let me know and I will attempt to be more clear. 

John 

John Rego • Environmental, Health & Safety

901 LAKESIDE AVENUE • CLEVELAND, OHIO 44114 

DIRECT 216.586.7542 • FAX 216.579.0212 • JREGO@JONESDAY.COM

From: Conrad Chin <Chin.Conrad@epamail.epa.gov> 

To: John Rego <jrego@JonesDay.com> 

Cc: Chuck French <French.Chuck@epamail.epa.gov>, "Beth Friedman" <friedman.beth@ecrweb.com>, 

Jonathan Averback <Averback.Jonathan@epamail.epa.gov>, Steve Fruh <Fruh.Steve@epamail.epa.gov>, 

Jonathan Averback <Averback.Jonathan@epamail.epa.gov>, jeff.mckinney@erametgroup.com 

Date: 10/01/2012 02:40 PM 

Subject: Re: Ferroalloy - recent emissions test data

Good Afternoon JohnThis is to acknowledge that I just received a hard copy of the complete test report for the Eramet July 

tests. I assume Eramet has reviewed the results and considered the results to be accurate and 

representative. We will proceed with our review promptly. 

Thank you! 

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) 

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