1

 

MEMORANDUM

DATE: May 17, 2013

SUBJECT: Ferroalloys 2012 Test Report Review

FROM: Bradley Nelson, EC/R, Inc.

TO: Conrad Chin, EPA/OAQPS/SPPD/MMG

1.0 PURPOSE

The purpose of this memorandum is to present a summary and review of the reported results of 

emission testing at the Eramet Marietta (Eramet) and Felman Production (Felman) ferroalloys 

production facilities, conducted in July and August 2012, respectively. The emission testing was 

performed in response to a request from EPA for additional pollutant test data from the furnace and 

tapping operations. Testing at Eramet was conducted on July 23-25, 2012 and the test report 

submitted to EPA is dated September 26, 2012. Testing at Felman was conducted on August 7-17, 

2012 and the test report submitted to EPA is dated December 12, 2012. Emission data reported and 

reviewed in this memo are for the following pollutants of interest emitted in exhaust gases from 

control devices (i.e., process emissions): particulate matter (PM), hydrochloric acid (HCl), 

manganese (Mn), lead (Pb), mercury (Hg), formaldehyde, and polycyclic aromatic hydrocarbons 

(PAH). Visible emissions (VE) observations were made during stack testing but are not reviewed 

in this memo. These emission data are being evaluated as part of the “risk and technology review” 

(RTR) for the Ferroalloy Production source category. 

 

2.0 BACKGROUND

Under the "technology review" provision of CAA section 112(d)(6), EPA is required to review 

maximum achievable control technology (MACT) standards previously issued for emissions of 

hazardous air pollutants (HAP) and to revise them "as necessary (taking into account developments 

in practices, processes and control technologies)" no less frequently than every 8 years. Under the 

"residual risk" provision of the CAA section 112(f), EPA must evaluate the MACT standards within 

8 years after promulgation and promulgate standards if required to provide an ample margin of 

safety to protect public health or prevent an adverse environmental effect. EPA is currently 

conducting and RTR to address these review requirements for the Ferroalloys Production source 

category.
DRAFT FOR INTERNAL REVIEW 5-17-13

3.0 FERROALLOY FACILITY SUMMARY

The following section provides a brief overview of the submitted test reports by the ferroalloy

production facilities. Eramet submitted a test report1on September 26, 2012 for stack testing 

conducted in July 2012. Felman submitted three test reports2for August 2012 testing conducted on 

each of their furnaces on December 12, 2012. [Note that the emission sources in the title for 

Eramet test report are incorrect. The emission sources should be Furnace No. 1 Main Baghouse, 

Furnace No. 1 Tap Hole Baghouse, and Furnace No. 12 Scrubber.]

Eramet Marietta

The Eramet facility is located in Marietta, Ohio and produces ferromanganese (FeMn) and 

silicomanganese (SiMn) using two furnaces, identified as Furnace 1 and Furnace 12. Furnace 1 is a 

submerged arc furnace rated at 30 megawatts (MW). Primary process emissions from the furnace 

(e.g., melting) are controlled by a negative pressure fabric filter, installed in 2011 to replace a wet 

scrubber system. A separate fabric filter system is used to control process fugitive (captured 

secondary) emissions from tapping of this furnace. Furnace 12 furnace is a submerged arc furnace 

rated at 22 MW and is equipped with two wet scrubbers to control primary and secondary emissions 

from the furnace and tapping. The scrubbers operate simultaneously and exhaust through a single 

stack. The facility has a third furnace, EAF 18, which is permitted, but is considered to be 

inoperable until extensive repair can be made to the furnace. Other HAP emission sources include: 

a MOR process controlled by a positive-pressure baghouse which also controls emissions captured 

from casting of the product from MOR, and a crushing and sizing system (C2P) that is controlled 

by three negative pressure baghouses. There are also fugitive emissions that are emitted from each 

of these emissions sources (i.e., those that escape capture), in addition to the fugitive emissions 

from the uncontrolled casting operations for Furnace 1 and Furnace 12.

Felman Production Inc.

The Felman facility is located in New Haven, West Virginia and produces SiMn using three 

furnaces identified as Furnace 2, Furnace 5, and Furnace 7. Furnaces 2, 5, and 7 are open 

submerged arc furnaces rated at 32, 20, and 20 MW respectively. Each of these furnaces is

equipped with a positive-pressure baghouse to limit primary and secondary process emissions of 

PM and metal HAP from the melting and tapping from their respective furnace, as well as 

controlling emissions from casting operations associated with each furnace. The facility has a 

 

1 Emission Measurement Summary Report: Furnace No. 1, Furnace No. 12 Main Baghouse, Furnace 12 Tap Hole 

Baghouse, Filterable Particulate Matter, HCl, Formaldehyde, PAHs, Mercury, Lead, and Manganese, Eramet Marietta, 

September 2012.

2 Emission Test Report Felman Production Inc., Furnace #2 Baghouse (ID3001-01); Emission Test Report Felman 

Production Inc., Furnace #5 Baghouse (ID3001-02); and Emission Test Report Felman Production Inc., Furnace #7 

Baghouse (ID3001-03), August 2012.
DRAFT FOR INTERNAL REVIEW 5-17-13

crushing and sizing system controlled using a negative pressure baghouse. There are also fugitive 

emissions that are emitted from each of these emissions sources.

4.0 FERROALLOY TEST DATA SUMMARY

The following section provides a summary of each of the reported PM and hazardous air pollutants 

(HAP) concentrations and emissions from 2012 test reports submitted by Eramet Marietta, Inc. and 

Felman. The summary also includes a discussion of the quality of the field sampling, and analytical 

results.

Particulate Matter

The test report from Eramet provided PM results from Furnaces 1 and 12, and the Furnace 1 

tapping baghouse. The Eramet PM tests were conducted using EPA Method 5. Felman provided 

PM results from Furnaces 2, 5, and 7 using a combined EPA Method 5D and EPA Method 26A. A 

summary of the results for Eramet and Felman are provided in Table 1. For comparison to the PM 

emission rates shown in the test reports, EC/R independently calculated the PM emission rate using 

the stack gas parameters and the analytical data from the test reports. These PM emission rates 

calculated by EC/R are shown in the tables as “Calculated PM Emissions (lb/hr).” 

Generally, PM emission rates were calculated as follows:

( )

 

 

An example of the specific PM emission calculation by EC/R for Run 1 at the Furnace 1 Main 

Baghouse is shown below:

(3.30 mg + 2.80 mg)/(49.324 dscf)*(173,616 dscf/min)*(g/1000 mg)*(lb/453.59 g)*(60 min/hr) = 2.84 lb/hr

Where;

3.30 mg = Reported filter particulate weight gain;

2.80 mg = Reported acetone probe rinse weight gain;

49.324 dscf = Reported volume of dry gas sampled corrected to standard conditions;

173,616 dscf/min = Reported volumetric flow rate – dry basis at standard conditions;

g/1000 mg = Unit conversion of particulate milligrams to grams;

lb/453.59 = Unit conversion of particulate grams to pounds;

60 min/hr = Unit conversion of minutes to hours.
DRAFT FOR INTERNAL REVIEW 5-17-13

Table 1. Summary of 2012 Eramet Marietta and Felman Production PM Test Results

Emission Source Run 

Number

Reported PM 

Concentration 

(gr/dscf)

Reported PM 

Emissions

(lb/hr)1

Calculated PM 

Emissions

(lb/hr)2

Eramet Marietta

Furnace 1 Baghouse Outlet

1 0.00191 2.84 2.84

2 0.00112 1.70 1.70

3 0.00158 2.46 2.46

Average 0.00154 2.33 2.33

Furnace 1 Tapping Baghouse 

Outlet

1 0.00122 0.67 0.672

2 0.000924 0.51 0.506

3 0.00139 0.71 0.706

Average 0.00118 0.63 0.628

Furnace 12 Scrubber Outlet

1 0.00582 7.26 7.26

2 0.00719 8.89 8.89

3 0.00787 9.90 9.90

Average 0.00696 8.68 8.68

Felman Production

Furnace 2 Baghouse Outlet

1 0.0006 2.64 2.51

2 0.0003 1.32 1.53

3 0.0003 1.32 1.36

Average 0.0004 1.76 1.80

Furnace 5 Baghouse Outlet

1 0.0003 1.12 1.15

2 0.0003 0.85 0.853

3 0.0002 0.57 0.703

Average 0.0003 0.85 0.903

Furnace 7 Baghouse Outlet

1 0.0021 4.92 4.98

2 0.0013 3.03 3.04

3 0.0008 1.89 1.85

Average 0.0014 3.28 3.29

1 Emission values reported in submitted test report.

2 Emission values calculated by EC/R from stack gas parameters and analytical data in test report.
DRAFT FOR INTERNAL REVIEW 5-17-13

As shown in the Table 1, the calculated PM emissions rates were comparable to the reported PM 

emission rates in the test report for Eramet. However, there were some slight differences in the 

calculated PM emission rate in comparison to the reported PM emissions rates for Felman. It is 

assumed that the differences in the emissions are due to rounding of the test report stack gas 

parameters (e.g., dscf, dscfm) used to determine the calculated emissions.

Metal Hazardous Air Pollutants

Eramet reported emissions for manganese (Mn), mercury (Hg), and lead (Pb) in their test report for 

the Furnace 1 baghouse outlet, the Furnace 12 scrubber outlet, and the Furnace 1 tapping baghouse. 

The Mn and Pb results were measured using EPA Method 29 and the Hg test results were measured 

using EPA Method 30B. Felman reported emissions of Mn and Hg using EPA Method 29 and 30B 

respectively for Furnace 2, 5, and 7. 

The reported results of the Mn and Pb stack tests and the values calculated by EC/R using the stack 

gas parameters and the analytical results are provided in Tables 2 and 3 respectively. The Hg 

reported test results and the calculated values using the stack gas parameters and the analytical 

results are provided in Tables 4 and 5. In addition, Tables 4 and 5 provide the quality assurance 

(QA) results of the EPA Method 30B testing, which include comparison of the paired samples and 

percent recovery of the spiked samples. The QA procedures for EPA Method 30B are designed to 

provide data of high and known quality for Hg emissions testing and for relative accuracy test 

audits (RATA) testing of Hg monitoring systems, including continuous emissions monitoring 

systems (CEMS) and sorbent trap monitors. These QA procedures include the collection of paired 

sampling sorbent traps to determine measurement precision and verify acceptability of the 

measured emissions data. In addition, a field recovery test which assesses recovery of an elemental 

Hg spike to determine measurement bias is also used to verify data acceptability.

The difference between the reported and calculated Mn emission rates in Table 2 is that the 

emission rates calculated by EC/R subtracted the reported field blank3results from the analytical 

run results. For Eramet, the laboratory Mn analysis reported 8.17 micrograms (μg) in the front half 

field blank and 6.42 μg in the back half of the field blank for a total of 14.59 μg. The reported Mn 

concentrations and emissions in the test report did not subtract the field blank from the analytical 

results. For Felman, the laboratory analysis reported a Mn result of 2.23 μg in the field blank. This 

field blank result was subtracted from the analytical run results for Felman to determine the 

calculated emission rate.

 

3 The primary purpose of field blanks is to trace sources of artificially introduced contamination. The field blank results 

include total ambient conditions during sampling and laboratory sources of contamination.
DRAFT FOR INTERNAL REVIEW 5-17-13

Table 2. Summary of 2012 Eramet Marietta and Felman Production 

Manganese (Mn) Test Results

Emission Source Run 

Number

Reported Mn

Concentration 

(μg/dscm)

1

Reported Mn

Emissions

(lb/hr)2

Calculated Mn

Emissions

(lb/hr)3

Eramet Marietta

Furnace 1 Baghouse Outlet

1 309.3 0.201 0.194

2 214.5 0.142 0.136

3 248.3 0.168 0.162

Average 257.4 0.170 0.164

Furnace 1 Tapping 

Baghouse Outlet

1 112.2 0.027 0.0243

2 103.9 0.025 0.0220

3 149.8 0.033 0.0305

Average 122.0 0.028 0.0256

Furnace 12 Scrubber Outlet

1 2408.6 1.31 1.31

2 2710.5 1.46 1.46

3 3396.8 1.86 1.86

Average 2838.6 1.55 1.54

Felman Production

Furnace 2 Baghouse Outlet

1 60 0.1156 0.1146

2 60 0.1227 0.1217

3 30 0.0598 0.0588

Average 50 0.0994 0.0984

Furnace 5 Baghouse Outlet

1 80 0.1053 0.1047

2 40 0.0471 0.0465

3 50 0.0878 0.0870

Average 57 0.0801 0.0794

Furnace 7 Baghouse Outlet

1 3810 3.4357 3.4347

2 540 0.4902 0.4897

3 2830 3.0206 3.0197

Average 2393 2.3155 2.3147

1 The reported Mn concentrations for Felman were presented in mg/dscm and converted to μg/dscm for this table.

2 Emission values reported in submitted test report.

3

Emission values calculated by EC/R from stack gas parameters and analytical data in test report.
DRAFT FOR INTERNAL REVIEW 5-17-13

Table 3. Summary of 2012 Eramet Marietta Lead (Pb) Test Results

Emission Source Run 

Number

Reported Pb 

Concentration 

(μg/dscm)

Reported Pb 

Emissions 

(lb/hr)1

Calculated Pb 

Emissions 

(lb/hr)2

Eramet Marietta

Furnace 1 Baghouse Outlet

1 11.7 0.00759 0.00647

2 11.7 0.00778 0.00612

3 12.5 0.00843 0.00731

Average 12.0 0.00793 0.00663

Furnace 1 Tapping Baghouse 

Outlet

1 9.0 0.00217 0.00172

2 3.9 0.000935 0.0

3 8.7 0.00191 0.00168

Average 7.2 0.00167 0.00113

Furnace 12 Scrubber Outlet

1 45.2 0.0246 0.0236

2 47.6 0.0257 0.0237

3 49.3 0.0271 0.0265

Average 47.4 0.0258 0.0246

1 The reported Mn concentrations for Felman were presented in mg/dscm and converted to μg/dscm for this table.

2 Emission values reported in submitted test report.

3 Emission values calculated by EC/R from stack gas parameters and analytical data in test report.

 
8

Table 4. Summary of 2012 Eramet Marietta Mercury (Hg) Test Results

Emission Source Spiked/ 

Unspiked

Run 

Number

Reported Hg 

Concentration 

(μg/dscm)

Reported Hg 

Emissions 

(lb/hr)1

Calculated Hg 

Emissions 

(lb/hr)2

Sample Spike 

Recovery (%)

Paired Sample 

Agreement 

(%)

Furnace 1 Baghouse 

Outlet

Unspiked

1 8.51 0.00558 0.00540 --- ---

2 10.74 0.00786 0.00763 --- ---

3 9.92 0.00673 0.00651 --- ---

Average 9.72 0.00672 0.00651 --- ---

Spiked

1 35.76 0.0234 0.00581 102.4 3.6

2 38.33 0.0280 0.00922 108.9 9.5

3 33.17 0.0225 0.00611 97.4 3.1

Average 35.76 0.0247 0.00705 --- ---

Furnace 12 Scrubber 

Outlet

Unspiked

1 79.25 0.0464 0.0436 --- ---

2 119.5 0.0753 0.0711 --- ---

3 105.55 0.0642 0.0592 --- ---

Average 101.44 0.0620 0.0579 --- ---

Spiked

1 104.56 0.0612 0.0435 98.7 0.1

2 141.06 0.0889 0.0691 87.4 1.4

3 132.76 0.0807 0.0605 110.0 1.1

Average 126.13 0.0769 0.0577

1 Emission values reported in submitted test report.

2 Emission values calculated by EC/R from stack gas parameters and analytical data in test report.
DRAFT FOR INTERNAL REVIEW 5-17-13

Table 5. Summary of 2012 Felman Production Mercury (Hg) Test Results

Emission Source Sample Set Run 

Number

Reported Hg 

Concentration 

(μg/dscm)

Reported Hg 

Emissions 

(lb/hr)1

Calculated Hg 

Emissions 

(lb/hr)2

Sample Spike 

Recovery (%)

Paired Sample 

Agreement 

(%)

Furnace 2 Baghouse 

Outlet

1

1 1.23 0.00236 0.00236 110.4 ---

2 0.704 0.00136 0.00136 --- ---

3 0.788 0.00152 0.00152 --- ---

Average 0.907 0.00175 0.00175 --- ---

2

1 0.647 0.00125 0.00125 --- 30.9

2 0.654 0.00126 0.00126 --- 3.7

3 0.778 0.00150 0.00150 --- 0.6

Average 0.693 0.00134 0.00134 --- ---

Furnace 5 Baghouse

Outlet

1

1 1.76 0.00216 0.00219 114.7 ---

2 0.604 0.000746 0.00075 --- ---

3 0.871 0.00108 0.00108 --- ---

Average 1.08 0.00133 0.00134 --- ---

2

1 1.28 0.00158 0.00158 --- 16.2

2 0.654 0.000808 0.00081 --- 4.0

3 1.05 0.00131 0.00131 --- 9.3

Average 0.995 0.00123 0.00123 --- ---

Furnace 7 Baghouse 

Outlet

1

1 0.000357 0.000394 0.00044 99.3 ---

2 0.000689 0.000760 0.00086 --- ---

3 0.00156 0.00188 0.00192 --- ---

Average 0.000869 0.00101 0.00107 --- ---

2

1 0.000336 0.000370 0.00041 --- 3.2

2 0.000677 0.000746 0.00084 --- 0.9

3 0.00151 0.00181 0.00185 --- 1.9

Average 0.000841 0.000975 0.00104 --- ---

1 Emission values reported in submitted test report.

2 Emission values calculated by EC/R from stack gas parameters and analytical data in test report.
10

Differences in reported and calculated Pb emission rates in Table 3 are the result of differences 

in how the non-detects in the analytical results were treated in calculating the Pb emission rate. 

In addition, the reported results in the test report were not field blank corrected as prescribed in 

EPA Method 29 . The analytical report for Pb from the EPA Method 29 tests at Eramet reported 

Pb results above the detection limit in all of the front half run samples, which includes the probe 

rinse and front half filter holder rinse, and below the detection limit for all but one of the back 

half run samples (the Furnace 1 Baghouse, Run 2 back half sample was measured above the 

detection limit), which includes the back half filter holder rinse and the impinger contents. The 

reported Pb emissions were calculated by summing up the total of the front half and back half 

analytical results, dividing by the volume of dry meter gas sampled, and multiplying by the 

volumetric flow rate (see above for sample equation from PM section). In cases where the 

analytical result was reported below the detection limit, the test report used the detection limit for 

the sample result. The EC/R calculated Pb emissions used the same calculation method, but used 

1⁄2 of the detection limit for analytical results reported below the detection limit, and field blank 

corrected the run analytical results to account for the 3.60 μg Pb measured in the field blank 

sample. Therefore, the EC/R calculated emission rates are lower in comparison to the test report 

emission values for Pb. The use of 1⁄2 of the detection limit for calculating emission rates from 

analytical data results reported below the detection limit is based on EPA’s revised procedures4

for developing emission factors. 

The Hg concentrations were measured using EPA Method 30B for both of the facilities. The 

analytical results for all of the Hg runs from all of the test sites were measured above the 

detection limit. The Hg result for the field blank at Eramet was measured to be 0.0 nanograms 

(ng). The Hg result for the field blank and trip blank for the Felman tests averaged 0.39 ng and 

0.75 ng respectively. The facilities each included spiked sorbent trap runs with the Hg test runs 

to meet the QA requirements of the method, but these spiked sorbent traps were collected using

different procedures. The spiked sorbent traps are used to assess the recovery of elemental Hg 

spike to determine measurement bias, and are also used to verify data acceptability. Eramet 

collected a spiked and unspiked sorbent trap for each test run, whereas Felman collected one 

spiked sorbent trap per 3-run test. Table 5 lists the sample spike recovery percentages for each 

of the sorbent traps, and the paired sample agreement for each of the sorbent trap pairs. The 

paired sample agreements were all within 10% for all of the Eramet runs, but the first runs for 

the Hg testing done on Felman Furnaces 2 and 5 were greater than 10%. The method states that 

these runs should not be used in the averaging, but both the reported and calculated emissions 

averages include these tests. These runs were included in the EC/R calculated average for 

purposes of comparing the emission results in the test report with the calculated emission results. 

EPA may decide to include these runs that did not meet the 10% paired agreement in the final 

 

4 Recommended Procedures for Development of Emissions Factors and Use of the WebFIRE Emissions Factor 

Database, Revised Draft Report, December 17, 2010. 

http://www.epa.gov/ttn/chief/efpac/procedures/procedures_draft122010.pdf
DRAFT FOR INTERNAL REVIEW 5-17-13

test average, because these EPA Method 30B tests are not for the purposes of performing RATA 

or CEMS accuracy testing. 

Polycyclic Aromatic Hydrocarbons

The polycyclic aromatic hydrocarbon (PAH) emissions were measured at both Eramet and 

Felman using California Air Resources Board Method 429 (CARB 429).The results are 

presented in Tables 6 and 7. Eramet provided results for one test run for each of the three tested 

emission sources and Felman provided three runs from each of their tested emission sources.

The analytical results for the Eramet tests were reported for three different dilution factors; 1, 

200, and 2000. However, the reported analytical results used to calculate the emission rates were 

different from the analytical results provided in the appendix of the test report. The test report is 

unclear about the origin of the analytical results used to calculate PAH concentrations and 

emissions rates that are presented in the test report. Therefore, the PAH concentration and 

emissions calculations presented in the test report could not be replicated in this review. The 

laboratory report also provided analytical results for a blank sample at a dilution factor of 200 

and a dilution factor of 1. The sample to blank train PAH mass ratio for these analyses were less 

than five and no further corrections to the sample data were needed.

The Felman PAH results reported in the test report matched the laboratory analysis report 

provided in the test report appendix. Only the test runs for the Furnace 2 baghouse outlet listed 

ND values. The ND values were for perylene for Runs 1, 2, and 3, and dibenzo(a,h)anthracene 

for Run 2. There were some detected values for the train and trip blank in the Felman samples, 

however the sample to blank train PAH mass ratio was less than five and no further corrections 

to the sample data were needed. 

Hydrochloric Acid

The hydrochloric acid (HCl) emissions were measured using EPA Method 26 at Eramet and EPA 

method 26A at Felman. At Eramet, HCl data were collected at the outlet of the Furnace 1 

baghouse, the outlet of the Furnace 1 tapping baghouse, and the outlet of the Furnace 12 

scrubber. Felman measured HCl using EPA Method 26A at the baghouse outlets of Furnace 2, 

5, and 7. The test results for the Eramet and Felman HCl emissions are provided in Table 9. The 

analytical results for all of the runs for the Eramet tests were measured as ND. In the test report, 

the detection limit was used to determine the total HCl in the sample and to calculate the 

reported HCl emission rate. By contrast, EC/R calculated the HCl emission rates in Table 8 

using 1⁄2 of detection limit based on guidelines in EPA’s revised procedures for developing 

emission factors. 
DRAFT FOR INTERNAL REVIEW 5-17-13

Table 6. Summary of 2012 Eramet Marietta PAH Test Results

Emission Source

Reported 

Analytical Result 

(ng)

Reported 

Concentration 

(ng/dscm)

Reported 

Emissions 

(lb/hr)1

Calculated 

Emissions 

(lb/hr)2

Furnace 1 Baghouse Outlet

Naphthalene 334889.4 74025.1 0.05246

Not calculated3

2-Methylnaphthalene 111115.1 24561.3 0.01741

Acenaphthylene 77527.2 17136.9 0.01215

Acenaphthene 35534.4 7854.6 0.00557

Fluorene 41210.3 9109.3 0.00646

Phenanthrene 1095162.1 242078.3 0.17157

Anthracene 12315.7 2722.3 0.00193

Fluoranthene 419466.8 92720.3 0.06572

Pyrene 267137.6 59049.0 0.04185

Benzo(a)Anthracene 22803.3 5040.5 0.00357

Chrysene 48983.5 10827.5 0.00767

Benzo(b)Fluoranthene 37201.7 8223.2 0.00583

Benzo(k)Fluoranthene 6484 1433.2 0.00102

Benzo(e)Pyrene 24795.1 5480.8 0.00388

Benzo(a)Pyrene 1540 340.4 0.00024

Perylene 1144 252.9 0.00018

Indeno(1,2,3-cd)Pyrene 716.9 158.5 0.00011

Dibenzo(a,h)Anthracene 5680 1255.5 0.00089

Benzo(g,h,i)Perylene 1180 260.8 0.00018

Total PAH 2544887.1 562530.3 0.39869

Furnace 12 Scrubber Outlet

Naphthalene 18185285.7 4294046.2 2.55246

Not calculated3

2-Methylnaphthalene 4712542.5 1112760.9 0.66144

Acenaphthylene 5543866.7 1309059.4 0.77813

Acenaphthene 656263.6 154961.9 0.09211

Fluorene 2367191.4 558959.0 0.33226

Phenanthrene 41320852.2 9756989.9 5.79973

Anthracene 278000.2 65643.5 0.03902

Fluoranthene 3039167.6 717631.1 0.42657

Pyrene 88831398.4 20975536.8 12.46823

Benzo(a)Anthracene 15688.7 3704.5 0.00220

Chrysene 212659.7 50214.8 0.02985

Benzo(b)Fluoranthene 93621.8 22106.7 0.01314

Benzo(k)Fluoranthene 314300 74214.9 0.04411

Benzo(e)Pyrene 525484 124081.2 0.07376

Benzo(a)Pyrene 314016.4 74147.9 0.04407

Perylene 5018.6 1185.0 0.00070

Indeno(1,2,3-cd)Pyrene 16143.8 3812.0 0.00227

Dibenzo(a,h)Anthracene 49177.1 11612.1 0.00690

Benzo(g,h,i)Perylene 146048.8 34486.1 0.02050

Total PAH 166626727.2 39345154.0 23.38746
DRAFT FOR INTERNAL REVIEW 5-17-13

Table 6. Summary of 2012 Eramet Marietta PAH Test Results (Continued)

Emission Source

Reported 

Analytical Result 

(ng)

Reported 

Concentration 

(ng/dscm)

Reported 

Emissions 

(lb/hr)1

Calculated 

Emissions 

(lb/hr)2

Furnace 1 Baghouse Outlet

Naphthalene 311324.3 72384.2 0.01605

Not calculated3

2-Methylnaphthalene 328121.6 76289.6 0.01692

Acenaphthylene 90415.6 21022.0 0.00466

Acenaphthene 28957.7 6732.8 0.00149

Fluorene 65489.7 15226.6 0.00338

Phenanthrene 532510.8 123810.9 0.02745

Anthracene 57741.2 13425.1 0.00298

Fluoranthene 160930.4 37417.0 0.00830

Pyrene 174921.4 40669.9 0.00902

Benzo(a)Anthracene 29692.7 6903.7 0.00153

Chrysene 19357.7 4500.7 0.00100

Benzo(b)Fluoranthene 1315.5 305.9 0.00007

Benzo(k)Fluoranthene 1746.8 406.1 0.00009

Benzo(e)Pyrene 1969.2 457.8 0.00010

Benzo(a)Pyrene 1750.1 406.9 0.00009

Perylene 1591.9 370.1 0.00008

Indeno(1,2,3-cd)Pyrene 422 98.1 0.00002

Dibenzo(a,h)Anthracene 214.6 49.9 0.00001

Benzo(g,h,i)Perylene 431.6 100.3 0.00002

Total PAH 1808904.5 420577.7 0.09326

1 Emission values reported in submitted test report.

2 Emission values calculated by EC/R from stack gas parameters and analytical data in test report.

3 EC/R was unable to calculate emissions because the test report did not provide the laboratory analysis for the 

reported analytical results.
DRAFT FOR INTERNAL REVIEW 5-17-13

Table 7. Summary of 2012 Felman Production PAH Test Results

Emission Source

Average 

Analytical Result 

(ng)

Average

Concentration 

(ng/dscm)

Average

Emissions 

(lb/hr)1

Calculated 

Emissions 

(lb/hr)2

Furnace 2 Baghouse Outlet

Naphthalene 32733.3 6740.2 0.01402 0.01402

2-Methylnaphthalene 31833.3 6556.5 0.01364 0.01364

Acenaphthylene 6616.7 1361.6 0.00283 0.00283

Acenaphthene 3990.0 822.5 0.00171 0.00171

Fluorene 4833.3 995.3 0.00207 0.00207

Phenanthrene 21500.0 4425.7 0.00921 0.00921

Anthracene 1333.3 274.6 0.00057 0.00057

Fluoranthene 9363.3 1928.3 0.00401 0.00401

Pyrene 4690.0 965.7 0.00201 0.00201

Benzo(a)Anthracene 320.0 66.0 0.00014 0.00014

Chrysene 1397.0 288.1 0.00060 0.00060

Benzo(b)Fluoranthene 565.3 116.6 0.00024 0.00024

Benzo(k)Fluoranthene 127.6 26.3 0.00005 0.00005

Benzo(e)Pyrene 644.3 132.9 0.00028 0.00028

Benzo(a)Pyrene 28.3 5.8 0.00001 0.00001

Perylene 14.3 3.0 0.00001 0.00001

Indeno(1,2,3-cd)Pyrene 54.3 11.2 0.00002 0.00002

Dibenzo(a,h)Anthracene 26.9 5.5 0.00001 0.00001

Benzo(g,h,i)Perylene 67.7 13.9 0.00003 0.00003

Total PAH 120139.2 24739.8 0.05147 0.05147

Furnace 5 Baghouse Outlet

Naphthalene 48300.0 9048.0 0.01365 0.01365

2-Methylnaphthalene 41233.3 7725.5 0.01167 0.01167

Acenaphthylene 26533.3 4970.7 0.00751 0.00751

Acenaphthene 16066.7 2990.1 0.00441 0.00441

Fluorene 24366.7 4530.2 0.00665 0.00665

Phenanthrene 56766.7 10627.3 0.01601 0.01601

Anthracene 7860.0 1494.0 0.00237 0.00237

Fluoranthene 39666.7 7420.2 0.01115 0.01115

Pyrene 32133.3 6023.8 0.00912 0.00912

Benzo(a)Anthracene 2666.7 506.3 0.00080 0.00080

Chrysene 9766.7 1828.8 0.00276 0.00276

Benzo(b)Fluoranthene 3390.0 644.9 0.00103 0.00103

Benzo(k)Fluoranthene 647.3 123.0 0.00019 0.00019

Benzo(e)Pyrene 2530.0 481.0 0.00076 0.00076

Benzo(a)Pyrene 101.7 19.4 0.00003 0.00003

Perylene 27.0 5.1 0.00001 0.00001

Indeno(1,2,3-cd)Pyrene 84.5 15.9 0.00002 0.00002

Dibenzo(a,h)Anthracene 35.2 6.6 0.00001 0.00001

Benzo(g,h,i)Perylene 95.0 17.9 0.00003 0.00003

Total PAH 312270.7 58478.6 0.08818 0.08818
DRAFT FOR INTERNAL REVIEW 5-17-13

Table 7. Summary of 2012 Felman Production PAH Test Results (Continued)

Emission Source

Average

Analytical Result 

(ng)

Average

Concentration 

(ng/dscm)

Average

Emissions 

(lb/hr)1

Calculated 

Emissions 

(lb/hr)2

Furnace 7 Baghouse Outlet

Naphthalene 47033.3 8154.0 0.00819 0.00819

2-Methylnaphthalene 44833.3 7801.4 0.00781 0.00781

Acenaphthylene 35366.7 6156.5 0.00616 0.00616

Acenaphthene 21533.3 3706.7 0.00374 0.00374

Fluorene 26500.0 4567.7 0.00460 0.00460

Phenanthrene 60333.3 10465.9 0.01050 0.01050

Anthracene 10080.0 1730.3 0.00175 0.00175

Fluoranthene 42366.7 7367.9 0.00738 0.00738

Pyrene 36100.0 6274.3 0.00629 0.00629

Benzo(a)Anthracene 3643.3 621.2 0.00064 0.00064

Chrysene 16826.7 2871.9 0.00294 0.00294

Benzo(b)Fluoranthene 3476.7 594.1 0.00061 0.00061

Benzo(k)Fluoranthene 837.7 143.0 0.00015 0.00015

Benzo(e)Pyrene 2976.7 509.8 0.00052 0.00052

Benzo(a)Pyrene 285.3 48.9 0.00005 0.00005

Perylene 63.7 11.0 0.00001 0.00001

Indeno(1,2,3-cd)Pyrene 233.7 40.6 0.00004 0.00004

Dibenzo(a,h)Anthracene 52.0 9.0 0.00001 0.00001

Benzo(g,h,i)Perylene 209.3 36.3 0.00004 0.00004

Total PAH 352751.7 61110.6 0.06141 0.06141

1 Emission values reported in submitted test report.

2 Emission values calculated by EC/R from stack gas parameters and analytical data in test report.
DRAFT FOR INTERNAL REVIEW 5-17-13

Table 8. Summary of 2012 Eramet Marietta and Felman Production 

Hydrochloric Acid (HCl) Test Results

Emission Source Run 

Number

Reported HCl

Concentration 

(mg/dscm)

Reported HCl

Emissions 

(lb/hr)1

Calculated 

HCl Emissions 

(lb/hr)2

Eramet Marietta

Furnace 1 Baghouse Outlet

1 0.60 0.38 0.191

2 0.42 0.30 0.151

3 0.46 0.30 0.150

Average 0.49 0.33 0.164

Furnace 1 Tapping Baghouse 

Outlet

1 0.55 0.12 0.061

2 0.41 0.09 0.045

3 0.46 0.10 0.051

Average 0.47 0.10 0.052

Furnace 12 Scrubber Outlet

1 0.50 0.28 0.138

2 0.52 0.29 0.144

3 0.50 0.28 0.140

Average 0.51 0.28 0.141

Felman Production

Furnace 2 Baghouse Outlet

1 0.23 0.4453 0.445

2 0.29 0.5522 0.552

3 0.26 0.5019 0.502

Average 0.26 0.4998 0.500

Furnace 5 Baghouse Outlet

1 0.09 0.1054 0.105

2 0.10 0.1214 0.121

3 0.09 0.1172 0.117

Average 0.09 0.1147 0.115

Furnace 7 Baghouse Outlet

1 0.17 0.1753 0.175

2 0.26 0.2629 0.263

3 0.14 0.1487 0.149

Average 0.19 0.1956 0.196

1 Emission values reported in submitted test report.

2 Emission values calculated by EC/R from stack gas parameters and analytical data in test report.
DRAFT FOR INTERNAL REVIEW 5-17-13

All of the Felman analytical results were measured above the detection limit and were used to 

calculate the stack gas HCl concentration and emission rate. The reported and calculated 

emission rates were comparable. However, the blank sulfuric acid and water samples were 

measured at 580 and 350 μg HCl respectively, which are roughly the same results for the run 

samples. None of the run samples shown in Table 9 were blank corrected.

Formaldehyde

Formaldehyde emissions were measured at both Eramet and Felman using EPA Method 316. At 

Eramet, only one run was measured at each of the sample locations; the outlet of the Furnace 1 

baghouse, outlet of the Furnace 1 tapping baghouse, and outlet of the Furnace 12 scrubber. 

Three runs of formaldehyde testing at Felman were conducted on each of the baghouse outlets of 

Furnace 2, 5, and 7. The reported formaldehyde concentration and emission rates for Eramet and 

Felman are provided in Table 10, along with emission rates calculated by EC/R for comparison.

The analytical results for Eramet results listed one measurement above the detection limit, which 

was the run at the outlet of the Furnace 1 baghouse. The other two tests were measured as ND. 

There appears to be a discrepancy in the calculation of concentration and emission rate for the 

three tests as presented in the test report. The test report used the analytical concentration (e.g., 

micrograms per milliliter, μg/ml) detected in the sample, rather than the total μg, which is 

calculated by multiplying the analytical concentration by the sample volume. Therefore, the 

reported formaldehyde emission rate for the Furnace 1 baghouse outlet should be multiplied by 

the 480 milliliter (ml) sample volume to calculate the correct emission rate. The other two tests 

were listed as ND and the detection limit was used, but was not multiplied by the sample volume 

to obtain the correct total μg in the sample. The calculated emission rate in Table 9 uses 1⁄2 of the 

detection limit based on guidelines in EPA’s revised procedures for developing emission factors, 

and multiplies that value by the sample volume. The blank was measured as ND and was not 

used to blank correct the run samples. 

The run samples for the Felman tests were all measured above the detection limit with the 

exception of Run 1 from Furnace 2. For this run, the test report values reported for concentration 

and emission rate are based on using the detection limit for the analysis. The calculated 

formaldehyde emission rate in Table 9 for this run was calculated using 1⁄2 of the detection limit

based on guidelines in EPA’s revised procedures for developing emission factors. The 

formaldehyde emission rates calculated by EC/R for the other run samples were comparable to 

the reported emission rates in the test report. The blank was measured as ND, therefore no blank 

correction of the samples were done. 
DRAFT FOR INTERNAL REVIEW 5-17-13

Table 9. Summary of 2012 Eramet Marietta and Felman Production 

Formaldehyde Test Results

Emission Source Run 

Number

Reported 

Formaldehyde 

Concentration 

(mg/dscm)

Reported 

Formaldehyde 

Emissions 

(lb/hr)1

Calculated 

Formaldehyde 

Emissions 

(lb/hr)2

Eramet Marietta

Furnace 1 Baghouse Outlet 1 0.00023 0.00016 0.0771

Furnace 1 Tapping Baghouse 

Outlet 1 0.00020 0.000045 0.0087

Furnace 12 Scrubber Outlet 1 0.00019 0.00011 0.0244

Felman Production

Furnace 2 Baghouse Outlet

1 0.0058 0.0129 0.0065

2 0.1157 0.2574 0.2573

3 0.0165 0.0371 0.0370

Average 0.0460 0.1025 0.1003

Furnace 5 Baghouse Outlet

1 0.0938 0.1751 0.1751

2 0.0111 0.0207 0.0207

3 0.0086 0.0160 0.0160

Average 0.0378 0.0706 0.0706

Furnace 7 Baghouse Outlet

1 0.1194 0.1316 0.1316

2 0.1382 0.1663 0.1663

3 0.0998 0.1205 0.1205

Average 0.1191 0.1395 0.1395

1 Emission values reported in submitted test report.

2 Emission values calculated by EC/R from stack gas parameters and analytical data in test report.