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MEMORANDUM

Date: July 30, 2012

Subject: EPA – EMI – Felman Corporation Teleconference Summary (July 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 July 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 Siefert, Rae Trine

EC/R Incorporated (Contractor for EPA): Bill Battye, Beth Friedman, Brad Nelson

III.Summary of Discussions:

The following topics were discussed.
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Source Testing.

 EPA’s Mike Toney will attend the July EMI 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 table 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, they agree to use 

Method 30B because EPA asserts 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 stated that they cannot accommodate three runs of polychlorinated aromatic 

hydrocarbons (PAHs) 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 probably 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 place 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 from the plants. EPA is working on a draft 

protocol that would involve a couple of sites at each plant. 
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 EMI noted that the complex terrain (river valley) will pose a challenge to 

obtaining useful data. Previous efforts to correlate off-site ambient data to 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 concurred 

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. 

Data 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 separate 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 analysis.

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 as indicated by their frequent sweeping in the furnace shop. However, 

they cannot quantify the amount of material collected 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 

study. 

 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 malfunction.
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 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 

revised.

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 expressed 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 more 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 risk.