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MEMORANDUM

Date: August 2, 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

Chu and Gassman: Jack Wang

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: Will Boyd, Stan Durkee

EPA/Region V: Margaret Siefert, Rae Trine

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

(PAHs) 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 process 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.

Ambient 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 terrain (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 issues 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 monitor” (as EMI did) or at the source.

EMI and Felman suggested that there is significant drop out of particulate as the 

fume rises as 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 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. 

Other Issues

The plants 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 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 

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 on the use of enhanced local capture 

design parameters to evaluate remaining risk.