MEMORANDUM 

DATE: January 16, 2013

TO: Conrad Chin, EPA OAQPS/SPPD/MMG

FROM: Bradley Nelson, EC/R, Inc.

SUBJECT: Summary of the January 15, 2013 Teleconference with the Eramet Marietta, 

Felman Production and the U.S. Environmental Protection Agency

I. INTRODUCTION

The purpose of this teleconference was to discuss the upcoming EPA visit to Felman Production

on January 22, 2013 and Eramet Marietta on January 23, 2013, and to discuss potential testing 

approaches for fugitive emissions from the ferroalloys process. An agenda and potential roof 

vent fugitive emissions measurement approach were sent to each of the participants and are 

provided in the appendix of this memorandum. This meeting summary will be available in the 

docket for this rulemaking (Docket ID No. EPA–HQ–OAR–2010–0895). The proposed rule for 

ferroalloys production was published in the Federal Register on November 23, 2011 (76 FR 

72508), and the deadline for the final rule is currently December 10, 2013 per a Consent Decree. 

II. ATTENDEES

The following is a list of participants in the meeting.

U.S. Environmental Protection Agency

Chuck French

Steve Fruh

Conrad Chin

Jason Dewees

Steffan Johnson

Eramet Marietta 

John Willoughby, Eramet Marietta

Jeff McKinney, Eramet Marietta

John Rego, Jones Day

Felman Production

John Konrady, Felman Production

Shawn McCutchan, Felman Production

Guy Van Doren, LAN Associates

Laura McAfee, Beveridge and Diamond
Paul Chinuntdet, Test Inc.

Policy Navigation Group

Troy Hiller

EC/R Incorporated

Bradley Nelson 

III. SUMMARY OF DISCUSSION

The EPA opened the meeting that the purpose of the meeting was to discuss the logistics of the 

EPA site visit to Felman Production on January 22, 2013 and Eramet Marietta on January 23, 

2013. In addition, EPA wanted to discuss potential approaches and methods to measure fugitive 

emissions from buildings containing furnaces and other production related processes. 

EPA then presented its planned schedule for both site visits.

Fugitive Emission Testing Approach

The EPA stated that the fugitive emission testing approach was based on similar approaches that 

have been used in other sources, such as primary aluminum, chloro-alkali, as well as for research 

purposes. Industry questioned the transferability of what had been done for other source 

categories, sought information on some of the uses of the sampling, and expressed concern about 

some of the sampling locations.

A representative from Felman stated that their biggest concern with the fugitive sampling was 

safety. He indicated that they wanted to make sure that no one was injured during the sampling 

effort and stated that their engineers may be able to help in locating the monitors in the building. 

Another representative stated that other methods for measuring fugitive emissions may be able to 

be used for this purpose and suggested a photoionization method. EPA asked the group to 

forward any literature that provides options for measuring fugitive emissions to the meeting 

group. 

A representative from Eramet Marietta stated that they also had concerns with safety and 

feasibility of sampling for fugitive emissions. He was concerned that the potential approach 

provided by EPA was not an approved test method, and has concerns regarding the usefulness of 

the collected data. He also is concerned with the timeline of the final rule. The EPA responded 

that they were not trying to dictate an approach, but wanted to share ideas on how to measure 

and quantify fugitive emissions. 
The industry asked when the fugitive emission testing would be conducted. The EPA responded 

that they believe that this data gathering could take place during the ICR testing, but would need 

to be completed by April. This would allow the EPA to do the calculations and include the 

results in the emissions file used for modeling. The industry asked if the EPA expected any 

changes to the rulemaking for this category due to news that the Administrator is leaving. The 

EPA responded that they believe that this should have no effect on the rulemaking because they 

are still under a court ordered deadline of December 10, 2013 and a proposed rule is already in 

the public record.

The EPA closed the meeting by stating that any correspondence regarding the site visits or 

approaches for measuring the fugitive emissions from the buildings be copied to all of the 

meeting participants.
ATTACHMENT A

DRAFT MEETING AGENDA

POTENTIAL ROOF VENT FUGITIVE EMISSIONS MEASUREMENT APPROACHES 

FOR MANGANESE FERROALLOYS FACILITIES
1/14/13

DRAFT AGENDA 

Ferroalloys Production RTR 

Teleconference with Eramet and Felman

Date and Time: January 15, 2013, from 4:00 – 5:00 pm (Eastern Time)

Call-in number is: 919-541-1590

Topics:

1. Introductions.

2. Discuss logistics for upcoming site visits at Felman on January 22, 2013 and Eramet on 

January 23, 2013:

 Site visit participants

 Meeting location

 Primary company contact information

 Start time and duration

 Specific activities (meetings, presentations, tour of ferroalloy related processes, etc.)?

 Other logistics

 

3. Discuss potential approaches and methods to measure fugitive emissions from buildings 

containing furnaces and other production related processes

 See attached 1-pager

4. Other Issues/Topics, Open Discussion, Next Steps
Potential Roof Vent Fugitive Emissions Measurement Approaches for 

Manganese Ferroalloys Facilities

Objective: The overall objective of fugitive measurements will be to characterize PM10 and Mn 

concentrations (e.g., mg/m3) and emissions from furnace building roof vents. A sampling system 

would be used in the roof areas above processes (such as tapping, casting, ladle raking, etc.) to 

capture process fugitive emissions of PM10 and Mn.

Potential methods and approaches include the following:

 Measure PM10 and Mn Concentrations:

o A sampling technique would be used to capture PM10 on a filter media which allows 

for Mn speciation (such as a Teflon filter in a Method 14A-type sampling system with 

a stainless steel, Teflon, or plastic filter holder).

o The sampling devices (e.g., monitor, filter media, etc.) would be placed at multiple 

locations in the roof area above the processes that are expected to have fugitive 

emissions (e.g., furnace tapping, casting, ladle raking) such that the measurement 

system captures representative samples of PM10 and Mn fugitive emissions.

 

o Several 24-hour samples would be collected, concurrently, at each sampling location 

to include representative activities and complete production cycles.

 

 Measure Air Flow:

o Appropriate devices (such as propeller anemometers or hot-wire anemometers) would 

be used concurrently (with the filter devices) to measure volumetric air flow.

o The anemometers used would need to record data at sufficient frequency during 

sampling (such as one data point every minute, or more frequently, for the duration of 

the sampling). 

 The sampling systems would be placed in appropriate locations above the processes. The 

roof monitor area associated with each measurement location would also be calculated. 

The number and location of each of the PM10/Mn and Flow samplers would be 

determined based upon the configuration of the processes associated with the sampling 

areas and available/accessible mounting areas at each facility to ensure proper 

representation of the emission rates. 

 All processes, activities, and operations that take place in the production area associated 

with the sampling periods would be monitored and recorded (e.g., description of activity, 

time, date, location, materials, amounts, etc.).

 Mass emission rates for PM10 and manganese based on the mass collected on each filter, 

the sampling time of that filter collection, and the flow rate calculated from the associated 

velocity measurement and cross sectional area would be calculated.