MEMORANDUM

DATE: January 16

, 201 3

TO: Conrad Chin

, EPA OAQPS/SPPD/ MMG

FROM: Bradley Nelson, EC/R, Inc.

SUBJECT: Summary of the January 15

, 20 1 3 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 wa s published in the Federal Register on November 23, 20 1 1 (7 6 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

Con rad Chin

Jason Dewees

Steffan Johnson

Eramet Marietta John Willoughby, Eramet Marietta Jeff McKinney, Eramet Marietta

J ohn Rego

, Jones Day

Felman Production John Konrady, Felman Production Shawn McCutchan, Felman Production Guy V an Doren , LAN Associates Laura McAfee, Beveridge and DiamondPaul 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 P roduction on January 22, 2013 and Eramet Marietta on January 23,
2013. In addition, EPA wanted to discuss potential approaches and met hods 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 tes ting 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 sur e 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 regardi ng 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 ind ustry 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 calculati ons and include the

results in the e missions 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 shoul d 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

a pproaches 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 FACILITIES1/14/13

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, tou r 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 PM 10 and Mn concentrations (e.g., mg/m 3 ) 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 PM 10 and Mn.

Potential methods and approaches include the following :

 Measure PM 10 and Mn Concentrations:

o A sampling technique would be used to capture PM 10 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 PM 10 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 PM 10 /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

re presentation 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, am ounts, etc.).

 Mass emission rates for PM 10 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 calc ulated.