MEMORANDUM 

DATE: September 24, 2014

TO: Phil Mulrine, EPA OAQPS/SPPD

FROM: Bradley Nelson, EC/R

SUBJECT: Summary of the September 17, 2014 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 proposed 

emission limits for polycyclic aromatic hydrocarbons (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, 2011 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 

John Rego, Jones Day

John Hughes, Eramet Marietta

Liz Marble, Eramet Marietta

Glenn England, Environ

Policy Navigation Group

Troy Hillier

EC/R, Incorporated

Bradley Nelson
III. 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 website1 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 August 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 included 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 invalidated 

due to the extreme dilution of the samples, which brought 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 datasets 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