From: Laura K. McAfee <LMcAfee@bdlaw.com>

Sent: Tuesday, November 12, 2013 4:35 PM

To: Chin, Conrad

Cc: jskonrady@fpiwv.com; French, Chuck; Mulrine, Phil; Bradley Nelson

Subject: RE: Summary of 2012 Stack Testing and Historical PM data

Conrad/Chuck –

As you note below, we have been investigating the reason the estimated manganese concentration 

from the particulate in the Furnace 7 baghouse appears to have been higher than from either Furnace 2 

or Furnace 7 baghouses (or, indeed, higher than expected based on past data). I apologize for allowing 

this to slip through the cracks.

First, we asked the lab to re-run the sample from Furnace 7 to determine whether the result was 

possibly caused by a lab error. The lab re-ran the remaining digested material from the Furnace 7 

sample and obtained the same result. So the result does not appear to be attributable to an analytical 

error. 

In light of this, we also investigated possible operational causes and identified a few possible 

hypotheses:

1. The higher manganese levels might have been caused by the use of fines as an insulator between the 

molten metal and the cast beds. These fines have the same concentration of manganese as the finished 

product and can sublimate when contacted by the molten material, then cool again to form particulatebound manganese within the baghouse. Please note that in this event, the concentration of manganese 

measured in the baghouse would not accurately reflect the manganese emissions to the atmosphere.

2. The way in which manganese concentrations were derived, together with the age of the baghouse, 

may have contributed to different results. 

a. Manganese concentrations: Manganese concentrations were derived by using separate PM and 

manganese testing results – the PM results were based on three test runs on August 7, 2012, between 

1:00 until approximately 5:30, while the manganese results were based on three runs performed 

between August 7 at approximately 21:50 until August 8 at approximately 3:30. These independent PM 

and manganese results were then combined in order to determine a concentration of manganese in the 

particulate; the samples that were analyzed for manganese were not analyzed or weighed for PM.

This approach has been effective under static conditions; for example, the results from Furnaces 2 and 5 

appeared to be consistent with previous testing. However, this approach can lead to widely varying 

results when the equipment in question – here, the Furnace 7 baghouse – is not operating typically. 

There are several factors or rationales that support the idea that this may have been the case here, 

including:
b. Furnace 7 baghouse: Generally speaking, the bags in the Furnace 7 baghouse were older than those 

in the Furnace 2 and 5 baghouses, which had been recently re-bagged prior to testing (the bags in the 

Furnace 7 baghouse have since been replaced as well, but not until after the testing in question). Older 

bags are more likely to experience leaks, which can result in varying emissions rates across the several 

baghouse compartments, and an overall higher emissions rate. A few specific ways this could have 

affected the testing results – especially in light of the testing approach above – include:

(i) If a bag in one of the compartments had broken shortly before or during the manganese testing, it 

would have allowed a larger amount of material through, which may have resulted in higher apparent 

manganese concentrations given the way particulate and manganese results were determined.

(ii) The manganese and PM tests may also have measured different locations within the Furnace 7 

baghouse. If the manganese sampling involved a compartment that contained more tears and/or leaks 

than the compartment used for PM sampling, the results would show an elevated manganese 

concentration. 

(iii) The test company indicated that many of the bags in the Furnace 7 baghouse had been removed 

and capped, and several of the existing bags may have been compromised. These conditions can lead to 

widely variable results, especially if a large mass of fume dust is caught on the filter. As noted above, 

this kind of variability could lead to very different results under the testing approach used here. 

We have not been able to determine whether any of these hypotheses account for the higher 

manganese results. However, the test data itself seems to support the idea that the elevated 

manganese results are attributable to one of the reasons identified above and do not reflect normal 

manganese emissions from Furnace 7 – specifically, that of the individual test runs appear to show 

manganese emissions that exceed the total PM emissions rate from the furnace (compare Mn+ runs 1 

and 3 to PM runs 2 and 3). 

I hope this answers your question. If you need additional information or have additional questions, 

please let me know. Thanks.

Laura

Laura K. McAfee

Principal 

Beveridge & Diamond, P.C. 

201 North Charles St. Suite 2210 

Baltimore, MD 21201 

T (410) 230-1330 ~ F (410) 230-1389 

LMcAfee@bdlaw.com
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From: Chin, Conrad [mailto:Chin.Conrad@epa.gov] 

Sent: Wednesday, October 30, 2013 9:45 AM 

To: Laura K. McAfee 

Cc: jskonrady@fpiwv.com; French, Chuck; Mulrine, Phil; Bradley Nelson 

Subject: FW: Summary of 2012 Stack Testing and Historical PM data

LauraReferring to your email dated 9/28/2012, did you ever find out the reason why the manganese 

emissions were so much higher for furnace 7? If you did, please share with us on your findings.

Thanks.

Conrad Chin 

From: "Laura K. McAfee" <LMcAfee@bdlaw.com> 

To: Chuck French/RTP/USEPA/US@EPA, Conrad Chin/RTP/USEPA/US@EPA 

Cc: <jskonrady@fpiwv.com>, <r.powell@optimaacq.com>, <John.Willoughby@erametgroup.com>, 

<jrego@JonesDay.com>, <jeff.mckinney@erametgroup.com> 

Date: 09/28/2012 02:33 PM 

Subject: Summary of 2012 Stack Testing and Historical PM data

Chuck/Conrad –

 

Attached please find a summary of the results from our recent testing, which LAN has reviewed and 

summarized; we have not yet received the official report and will forward that when we receive it. We 

are also sending an updated version of the historical PM data table, which LAN has revised to include 

these results. A few notes on the data: 

 
1. As you will see, the manganese results for furnace 7 were significantly (order of magnitude) higher 

than the results for furnaces 2 and 5. We are still investigating to see if we can identify a reason for this 

(e.g., lab error, operational issue, etc.). We will let you know as soon as we have more information on 

this issue, but I know you are very anxious to get these data, so I did not want to hold up sending the 

other information to you while we figured that out. 

 

2. There appears to have been an operational issue during one of the runs on the furnace 7 PM/HCl 

testing (highlighted). Again, we are investigating this further. In the interim, LAN has excluded this run 

from the PM emissions average. 

 

Thanks very much; as always, please call or e-mail with any questions. 

 

Laura 

 

Laura K. McAfee 

Principal 

Beveridge & Diamond, P.C. 

201 North Charles St. Suite 2210 

Baltimore, MD 21201 

T (410) 230-1330 ~ F (410) 230-1389 

LMcAfee@bdlaw.com

CONFIDENTIALITY STATEMENT: This electronic message contains information from the law firm of 

Beveridge & Diamond, P.C. and may be confidential or privileged. The information is intended solely for 

the use of the individual(s) or entity(ies) named above. If you are not the intended recipient, be aware 

that any disclosure, copying, distribution, or use of the contents of this message is prohibited. If you 

have received this e-mail in error, please notify us immediately by telephone at (202) 789-6000 or by email reply and delete this message. Thank you. 

Please consider the environment before printing this e-mail.