MEMORANDUM

DATE: September 24

, 201 4

TO: Phil Mulrine

, EPA OAQPS/SPPD

FROM: Bradley Nelson

, E C/R

SUBJECT: Summary of the September 17

, 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 supplemental proposal especially the p roposed emission limits for p olycyclic a romatic h ydrocarbons (PAH)

. 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

Eramet Marietta
J ohn Rego, Jones Day John Hughes, Eramet Marietta Liz Marble, Eramet Marietta Glenn England, Environ

Policy Navigation Group Troy Hillier

EC/R, Incorporated Bradley NelsonIII. SUMMARY OF DISCUSSION

The purpose of the meeting was to discuss the polycyclic aromatic hydrocarbons ( PAH) and mercury (Hg) furnace outlet emission limits in the supplemental proposal that was signed by the
Administrator and posted on the EPA website 1 on September 4, 2014. The following is a brief summary of the major points that were discussed during the meeting

.

• The EPA stated that the October 2012 test data from Eramet Marietta for PAH and Hg that were provided to EPA in August 2014 were not included in the in the datasets used
to calculate the maximum achievable control technology ( MACT ) Floor for the supplemental proposal. The EPA stated that these data had not gone through sufficient quality assurance/quality control ( QA/QC ) to be incorporated into the supplemental proposal

.

• The EPA noted that the reported PAH results for Furnace 12 from the October 2012 tests were 26 times higher than a previous test conducted on the same furnace in A ugust 2010. The representatives from Eramet stated that the test represented normal furnace operations and that the PAH emissions are an unintentional product of the process.

• The EPA stated that the July 2012 PAH test data from Eramet were also not include d in the calculation of the MACT Floor for the supplemental proposal. The July 2012 PAH
test data consisted of a single run from each of the two furnaces (Furnace 1 and Furnace 12) and a single run from the Furnace 1 tapping baghouse. The test data were in validated
due to the e xtreme dilution of the samples

, which br ought into question the quantitative accuracy of the isotope dilution corrections to the data

.

• The Eramet representatives offered to perform additional PAH and Hg testing to supplement the datas ets used to develop the MACT Floor. They estimated the testing could take place in October on both Furnace 1, which is currently producing ferromanganese and Furnace 12, which is currently producing silicomanganese

.

• The EPA stated that test data would need to be received by January 2015 to meet the current deadline for the final rule which is May 28, 2015.

1 http://www.epa.gov/ttn/atw/ferroa/ferropg.html