1



### MEMORANDUM

DATE: May 17

, 201 3

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

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

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

(PAH) . V isible emissions (VE) observations were made during stack testi ng but are not reviewed

in this memo

. These e mission 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 standard s 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

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### 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 report 1 

### on September 26, 2012 for stack testing

conducted in July 2012. Felman submitted three test reports 2 

### for 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 ar e 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

silicomanganes e (SiMn) using two fur naces

, identified as Furnace 1 and Furnace 12

. Furnace 1 is a

submerged arc furnace rated at 30 megawatts (MW)

. Pri mary 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 equ ipped 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 a nd sizing system (C2P) that is controlled

by three negative pressure baghouse s . 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 uncon trolled 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 t apping 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 Ho le

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

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

emissions th at 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 we re 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 calculat ed 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).”

G enerally, 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 f

ilter particulate weight gain;

2.80 mg = Reported a cetone probe rinse weight gain;

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

173,616 dscf/min = Reported v olumetric 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 c onversion of minutes to hours.DRAFT FOR INTERNAL REVIEW 5

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### 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 0.67 2

2 0.000924 0.51 0.5 06

3 0.00139 0.71 0.7 06

Average 0.00118 0.63 0.6 28

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 c alcu l ated by EC/R from stack gas parameters and analytical data in test report

.DRAFT FOR INTERNAL REVIEW 5

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### 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 H azardous A ir P

ollutants

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 E PA 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 analytica l results are provided in Table s 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 Table s 4 and 5 . In addition

, Table s 4 and 5 provide the quality assura nce

( 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 blank 3 

### results from the analytical

run results. For Eramet, the laboratory Mn analysis reported 8.17 mi crograms ( 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 f ield b lank results

inc lude total ambient conditions during sampling and laboratory sources of contamination.DRAFT FOR INTERNAL REVIEW 5

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### Table 2 . Summary of 2012 Eramet Marietta and Felman Production

Manganese ( Mn ) Test Results

Emission Source Run

Number Reported M n

Concentration

( μg /dsc m ) 1 

### Reported M n

Emissions

(lb/hr) 2 

### Calculated M n

Emissions

(lb/hr) 3



### Eramet Marietta

Furnace 1 Baghouse Outlet 1 309.3 0.201 0. 194

2 214.5 0.142 0.1 36

3 248.3 0.168 0.16 2

Average 257.4 0.170 0.1 64

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 0.11 5 6 0.1 1 46

2 60 0. 12 27 0.1 2 17

3 30 0. 0 598 0. 05 88

Average 50 0. 099 4 0. 098 4

Furnace 5 Baghouse Outlet 1 80 0. 1053 0. 10 47

2 40 0.0 471 0 .04 65

3 50 0.0 878 0. 087 0

Average 57 0.0 801 0.0 79 4

Furnace 7 Baghouse Outlet 1 3810 3.4 357 3.43 47

2 540 0.4902 0.4 897

3 2830 3.0206 3.0 197

Average 2393 2.3155 2.31 47

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

### μ g/dscm for this table.

2 Emission values reported in submitted test report.

3 Emission values c alcu l ated by EC/R from stack gas parameters and analytical data in test re port

.DRAFT FOR INTERNAL REVIEW 5

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### 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 0.0 0172

2 3.9 0.000935 0.0

3 8.7 0.00191 0.0 0168

Average 7.2 0.00167 0.0 0113

Furnace 12 Scrubber Outlet 1 45.2 0.0246 0.023 6

2 47.6 0.0257 0.023 7

3 49.3 0.0271 0.026 5

Average 47.4 0.0258 0.024 6

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

### μ g/dscm for this table.

2 Emission values reported in submitted test report.

3 Emission values c alcu l ated 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 c alcu l ated by EC/R from stack gas parameters and analytical data in test report

.DRAFT FOR INTERNAL REVIEW 5

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### 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 0.00 236 110.4

---

2 0.704 0.00136 0.00 136

--- ---

3 0.788 0.00 152 0.00 152

--- --- Average 0.907 0.00 175 0.00 1 75

--- ---

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 0.0 0134 0.00 13 4

--- ---

Furnace 5 Baghouse

Outlet 1 1 1.76 0.00216 0.0 0219 114.7

---

2 0.604 0.000746 0.0 0075

--- ---

3 0.871 0.00108 0.0 0108

--- --- Average 1.08 0.00133 0.0 0 134

--- ---

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 c alcu l ated 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 i n

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 detec tion 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 cal culated by summing up the total of the front half and back half

analytical result s, 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 u se 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 procedures 4



### 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, wh ereas 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 wi thin 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

average s 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 a greement 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.pdfDRAFT FOR INTERNAL REVIEW 5

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### 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 Era met 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

. T he test report is

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

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

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 run s 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 bl ank train PAH mass ratio wa s 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 w ere 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 result s 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 calcu late the

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

using 1⁄2 of detection limi t based on guidelines in EPA’s revised procedures for developing

emission factors

.DRAFT FOR INTERNAL REVIEW 5

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### Table 6 . Summary of 2012 Eramet Marietta P AH Test Results

Emission Source Reported

Analytical Result

(ng) Reported

Concentration

( n g/dscm) Reported

Emissions

(lb/hr) 1 Calculated

Emissions

(lb/hr) 2

Furnace 1 Baghouse Outlet

Naphthalene 334889.4 74025.1 0.05246

Not calculated 3 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 calculated 3 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 23.38746DRAFT FOR INTERNAL REVIEW 5

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

Emission Source Reported

Analytical Result

(ng) Reported

Concentration

( n g/dscm) Reported

Emissions

(lb/hr) 1 Calculated

Emissions

(lb/hr) 2

Furnace 1 Baghouse Outlet

Naphthalene 311324.3 72384.2 0.01605

Not calculated 3 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 c alcu l ated 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

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### Table 7 . Summary of 2012 Felman Production PAH Test Results

Emission Source Average

Analytical Result

(ng) Average

Concentration

( n g/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 0.08818DRAFT FOR INTERNAL REVIEW 5

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

Emission Source Average

Analytical Result

(ng) Average

Concentration

( n g/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 c alcu l ated by EC/R from stack gas parameters and analytical data in test report

.DRAFT FOR INTERNAL REVIEW 5

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### 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 0.105 4 0.10 5

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 c alcu l ated by EC/R from stack gas parameters and analytical data in test report

.DRAFT FOR INTERNAL REVIEW 5

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### 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 wa ter 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 Felm an 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 Fe lman 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 analyt ical 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 to tal 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 t he 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 li mit 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 we re 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 e mission 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 comparabl e 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

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### 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 c alcu l ated by EC/R from stack gas parameters and analytical data in test report

.