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MEMORANDUM

Date: August 2 , 2012

Subject: EPA

– EMI

– Felman Corporation Teleconference Summary ( Ju ly 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 J u ly 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

Chu and Gassman : Jack Wang

Environ : Russell Kemp

TEST Inc. : Paul Chinuntdet Beveridge & Diamond : Amy Lincoln Jones Day : John Rego Policy Navig ation 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 : Will Boyd, St an Durkee EPA/Region V : Margaret Siefert, Rae Trine EC/R Incorporated (Contractor for EPA) : Bill Battye, Beth Friedman , Brad Nelson2

III. Summary of Discussion:

The following topics were discussed.

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. The group discussed the proposed test protocols. EMI agreed to conduct a Method 30B test for mercury with three runs. EPA stressed that if the test contractor correctly appl ies Method 30B quality assurance procedures, the plant should be able to collect good data using this method

. EMI cannot accommodate three runs of polychlorinated aromatic hydrocarbons ( PAH s) in the test schedule in July. EMI agreed that a winter 2013 test could

collect additional data if needed. Also, 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. EPA asked the plants to collect information on pro cess events during the tests.

EMI said 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.

Am bient Monitoring EPA is 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. EMI noted that the complex terrai n (river valley) will pose a challenge to obtaining useful data. The group discussed the possibility of taking measurements at the roof, for example using a modified Method 14A. The plants said that this would be difficult because of safety and access iss ues and the difficulty of obtaining a homogeneous sample.

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

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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 m onitor” (as EMI did) or at the source. EMI and Felman suggested that there is significant drop out of particulate as the

fume ris e s a s indicated by their frequent sweeping in the furnace shop. However, they cannot quantify the amount of material collected this way. 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. Mr. Kemp noted that the u se 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.

Other Issues The pl ants object to the proposed 10 percent building opacity limit without any

exclusions or excursions

. EMI noted that the existing building opacity data is based on the exclusion of exempt events. Some of the “zero” opacity readings

would not be observed if t he 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 stated that it is important to have a robust process for developing and implementing a process fugitive plan to demonstrate that the actual equipment operates as designed to meet overall capture efficiencies. 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 o n the use of enhanced local capture design parameters to evaluate remaining risk.