1

MEMORANDUM

Date: July 30, 2012

Subject: EPA

– EMI

– Felman Corporation Teleconference Summary ( Ju ly 16 , 2012)

From: Beth Friedman, EC/R Incorporated

To: Conrad Chin, OAQPS/SPPD/MMG (D243

- 02)

I. Introduction:

A meeting/ conference call was held on Ju ly 16 , 2012 to discuss alternative proposals submitted by Eramat Marietta (EMI) and Felman Production and the planned stack testing in July

. See the docket for a copy of each proposal. This memo provides an overview of the
issues discussed.

II. Participants :

Eramet Marietta : Jeff McKinney Felman Production, Inc. : John Konrady, Rich Lunn, Shawn McCutchan, Robert Powell
Environ : Russell Kemp
TEST Inc. : Paul Chinuntdet Beveridge & Diamond : Amy Lincoln Jones Day : John Rego Policy Navigation Group : Troy Hillier
EPA/ OAQPS : Colin Boswell, Conrad Chin, Mike Ciolek, Jason Dewees, Chuck French, Steve Fruh, Ray Merrill, Ron Meyers, Robin Segall

, Brian Shrager, Darcie Smith, David
Soloman , Mike Toney
EPA/OGC : Jon Averback
EPA/ORD : Stan Durkee EPA/Region V : Margaret Sief ert, Rae Trine EC/R Incorporated (Contractor for EPA) : Bill Battye, Beth Friedman , Brad Nelson

III. Summary of Discussions:

The following topics were discussed.2

Source Testing

.

 EPA’s Mike Toney will attend the July E MI test as an official EPA observer. State observers will also be present at both tests. EPA would probably send an observer to both of the winter 2013 tests, should they occur.

 The plant clarified that the reference to the EMI test method summary tabl e to Method 26 ( hydrochloric acid testing) was a typographical error, and it should be changed to Method 26A.

 Although EMI still believes that their proposed test protocol for mercury testing is based on sound recommendations from their test contractor, th ey agree to use Method 30B because EPA assert s that Method 30B should obtain the desired results in a shorter test run. They stated that a single longer test would not result in breakthrough and the alternative is poor detection limits. EPA stressed that if the test contractor correctly applies Method 30B quality assurance procedures, the plant should be able to collect good data. EPA added that Method 30B should provide better detection limits than use of a continuous emissions monitoring system.

 EMI st ated that they cannot accommodate three runs of polychlorinated aromatic hydrocarbons ( PAH s) in the test schedule in July. They note that the previous test program collected adequate PAH data from the plant. They agreed that a winter 2013 test could prob ably collect additional data if needed.

 EPA asked that the plants collect information on process events during the tests.

 The plants do not see a problem with adding data collection for polychlorinated biphenols (PCBs) and dioxins in the winter round of testing, should it occur. They add that they believe that process conditions in the furnace (temperatures at 1700oF, no plastics) preclude generation of PCBs.

 EMI noted that they will have completed their analysis of mercury emissions and
activated carbon injection (ACI) control before the next round of testing occurs, which should help inform the test protocol for the mercury testing in the winter
2013 test.

 EMI added that scheduling the ACI/mercury test requires 2 months’ notice and that it must take pla ce before late fall. They need certainty regarding the overall extension in order to schedule these tests to occur this year.

Ambient Monitoring

 EPA is still interested in obtaining ambient monitoring data collected with concurrent meteorological data fr om the plants. EPA is working on a draft protocol that would involve a couple of sites at each plant.3  EMI noted that the complex terrain (river valley) will pose a challenge to obtaining useful data. Previous efforts to correlate off

- site ambient data t o plant operations failed.

 EPA asked if measurements at the roof might be possible, for example using a modified Method 14A. Mr. Kemp responded that there would be significant safety and access issues to conducting such a test at Felman and EMI concurre d
that these would also be issues at EMI

. Mr. Kemp added that the episodic nature of the events that result in process fugitives adds to the difficulty. EMI added that emission sources vary and that obtaining a homogeneous sample would be
difficult.

D ata Discrepancies

 EPA noted that corrections to the modeling file discrepancies (roof monitor height, use of new baghouse on Furnace 1, etc.) will be incorporated into EPA’s next modeling effort.

 EPA explained that the original proposal included a separ ate modeling scenario that corrected some of these factors. Based on current draft modeling results, the
current draft of the revised baseline is within 10 tons of the EMI estimate of baseline emissions. EMI asked if they could see a copy of this newer a nalysis.

Role of Emission Factors in Calculating Emissions

 Mr. Kemp described the proposed approach to their use of tapping and hot metal transfer emissions factors to estimate tapping and casting emissions. The group
discussed whether to use factors “at the monitor” (as EMI did) or at the source. EMI and Felman suggested that there is significant drop out of particulate as the
fume risks a s indicated by their frequent sweeping in the furnace shop. However, they cannot quantify the amount of material co llected this way.

 Mr. Kemp noted that the 1974 EPA study that EPA cited as the reference to the higher Ohio emission factor used by EPA has a footnote that suggests that the
monitor hot metal transfer factor is close to the 0.01% loss cited in the 1974

s tudy.

 EPA noted that the 1970’s emission factors used by EMI would likely receive much lower quality grades under the current emission factor protocol. Mr. Meyers suggested that the plant and EPA consider a way to back calculate fugitive emissions using the available off

- site ambient data for EMI.

 The plants assume that there are no fugitive emissions from the furnace top, i.e., primary emissions are completely controlled. The only exception would be when a “blow out” occurs, but this is considered a mal function.4  Mr. Kemp noted that the use of 41 percent manganese content in the collected particulate matter is a worst case assumption. Another worst case assumption is that all of the production from both EMI furnaces is sent to the metal oxygen refining ( MOR) process.

 EPA suggested that the metallic mineral processing emission factors used by EMI for crushing and screening might be out

- of

- date, and the plant and EPA should review the crushed stone processing emission factors, which were more recently
revi sed.

Other Issues

 The plants object to the proposed 10 percent building opacity limit without any
exclusions or excursions . EMI noted that the body of building opacity data is based on the exclusion of exempt events. Some of the “zero” opacity readings would not be observed if the exempt events were included.

 EC/R suggested that the proposed requirement to use a single face velocity as a design requirement and monitoring parameter limit does not address the fact that
several variables can affect face velocity at different points across the hood.

 EC/R described a more detailed process fugitives plan development process that could be used to demonstrate that the actual equipment operates as designed to meet overall capture efficiencies. Mr. Rego expre ssed concern that the plants might not have time to follow a time consuming design and demonstration process and still meet a 2

- year compliance deadline.

 The plants asked EPA to provide more certainty regarding a long term extension before they invest in m ore testing and process fugitives design efforts.

 EPA is discussing a longer term extension with the litigants. Furthermore, EPA is developing a robust control scenario based on the use of enhanced local capture design parameters to evaluate remaining r isk.