Updated EMI Crusher Emissions.pdf

Conrad:

Attached are EMI’s responses to the questions you forwarded on August 7, 2012 regarding the estimated

current emissions from crushing/screening operations.

Question 1: ‘You appeared to adjust the secondary crushing emission factor in Table 11.24-2 from PM to

PM1O by assuming the same ratio of PM to PM1O in the primary crushing factor. Is this correct? Do you

have any reason to suspect that the actual number might be higher or lower, and why?”

Response 1: Yes, in the absence of a specific PM1O factor in the set, EMI assumed the same ratio. EMI

has no reason to suspect a difference, either higher or lower.

Question 2: “If we were to add emission factors from the Crushed Stone Processing Operations table

11.19.2-2, it seems that there would be the potential to add one or more factors for screening, such as

0.0087 for uncontrolled “screening.” There is also a factor for “fines” screening, at 0.072. Is thisequivalent to “secondary screening? Similarly, is the emission factor for conveyor transfer point

(0.00110) applicable to any of the processes you currently address using a material handling factor from

Table 11.24-2? Are there any other factors on this table that you think might be appropriate to use?”

Response 2: EMI believes that the AP-42, Table 11.19.2-2 emission factors for “conveyor transfer” and

for “screening” could be applied to EMI’s crushing/screening operations. In fact, most of the points in

EMI’s July 2, 2012 estimate where EMI used the Table 11.24-2 emission factor for “material handling and

transfer” are actually conveyor transfer points. EMI does not have any additional knowledge regarding the

basis and scope of Table 11.19.2-2’s emission factor for “fines” screening. However, EMI does not

believe the factor would be applicable to EMIs operations, in any event, because EMI does not engage in“secondary screening.” Each of the crushers at EMI (primary jaw crusher and secondary jaw crusher) has

a dedicated screen box (screen 01 and screen 02, respectively). Some product passes through both the

primary and secondary crusher, while other product passes through either the primary crusher or

secondary crusher and its dedicated screen box alone. The emissions estimates, however, were

conservatively based on the assumption that all material passes through both crusher systems. Since

both screen box 01 and screen box 02 have been included in the emissions estimates (and the fines from

the primary screen box are not subject to any secondary screening), there is no additional screening to be

accounted for.

Question 3: “Can you indicate for each crushing and fugitive process/emission point, which factor you

think would be appropriate to use?”

Response 3: Attached is an updated emissions estimate that indicates the emission factor used for each

emissions point.
DIRECT 216.586.7542 • FAX 216.579.0212.

JREGO@JONESDAY.COM

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Crushing and Sizing Emissions ‐ Eramet Marietta Plant Max Permitted Hours: 5,840

Product Max Hrs: 3504

Uncontrolled Emissions Factors from AP‐42 Table 11.24‐2, Product Typ Op hrs: 3504

and AP‐42 Table 11.19.2‐2 Slag Max Hrs: 2336

Slag Typ Op hrs: 2336

Type of unit Emission 

Unit ID

Capacity (tons 

/ hour) *

Emission 

factor - 

PM10 

(lb/ton)

Potential 

emissions 

PM10 

(lb/hour) at 

95% 

capture

Total PM10 

Emissions 

(tons/yr)

Factor Notes

Product

Primary Jaw Crusher Receiving P-917 140 5.5E-05 0.008 0.013 Stone, Conveyor Transfer, U/C

Primary Jaw Crusher (including Grizzly) P-917 140 0.0025 0.350 0.613 Metallic, Primary Crushing

Conveyor 1A Belt (at Primary Crusher) P-917 140 0.0030 0.420 0.736 Metallic, Material Handling

Screening 01 Receiving (from #1A Belt) P-917 140 5.5E-05 0.008 0.013 Stone, Conveyor Transfer, U/C

Screening 01 P-917 140 4.35E-04 0.061 0.107 Stone, Screening

Screen 01 to #2 Belt ‐ Out of Service (OOS) P-917 0 5.5E-05 0.000 0 Stone, Conveyor Transfer, U/C

Secondary Jaw Crusher Receiving P-917 140 5.5E-05 0.008 0.01 Stone, Conveyor Transfer, U/C

Secondary Jaw Crusher P-917 140 0.0060 0.840 1.472

Metallic, Secondary Crushing

(ratio from PM‐PM10)

#7 Belt Receiving "A" (at ground level) P-917 140 5.5E-05 0.008 0.013 Stone, Conveyor Transfer, U/C

#7 Belt Receiving "B" (at second level) P-917 140 5.5E-05 0.008 0.013 Stone, Conveyor Transfer, U/C

Screen 02 Receiving (at end of #7 Belt) P-917 140 5.5E-05 0.008 0.013 Stone, Conveyor Transfer, U/C

Screen 02 P-917 140 4.35E-04 0.061 0.107 Stone, Screening

#5 Belt Receiving (fines) P-917 140 5.5E-05 0.008 0.013 Stone, Conveyor Transfer, U/C

#4 Belt Receiving (2"x1/4") P-917 140 5.5E-05 0.008 0.013 Stone, Conveyor Transfer, U/C

#3 Belt Receiving (3"x1") P-917 140 5.5E-05 0.008 0.013 Stone, Conveyor Transfer, U/C

Fines Bin 01 (from #5 Belt) P-917 140 5.5E-05 0.008 0.013 Stone, Conveyor Transfer, U/C

Product Bin 02 (from #4 Belt) P-917 140 5.5E-05 0.008 0.013 Stone, Conveyor Transfer, U/C

Product Bin 03 (from #3 Belt) P-917 140 5.5E-05 0.008 0.013 Stone, Conveyor Transfer, U/C

Product Bin 04 (from #2 Belt ‐ NOT USED) P-917 0 5.5E-05 0.000 0 Stone, Conveyor Transfer, U/C

SLAG

Main Jaw Crusher Receiving (slag only) P-917 140 5.5E-05 0.008 0.009 Stone, Conveyor Transfer, U/C

Main Jaw Crusher (slag only) P-917 140 0.00250 0.350 0.409 Metallic, Primary Crushing

#1A Belt Receiving (slag only) P-917 140 5.5E-05 0.008 0.009 Stone, Conveyor Transfer, U/C

#1 Belt Receiving (slag only) P-917 140 5.5E-05 0.008 0.009 Stone, Conveyor Transfer, U/C

Slag Bin 05 (from #1 Belt) P-917 140 5.5E-05 0.008 0.009 Stone, Conveyor Transfer, U/C

Total Controlled Emissions, tpy

Total PM10 

Emissions 

(tons/yr)

3.6

Total Mn 

Emissions 

(tons/yr) *** 1.476

*  Average annual capacity estimated to be 140 tons per hour.

**  Crushing and sizing emissions capture effiency of hoods is enhanced due to high bulk density of

      product (nominal 270 lbs/ft3) along with material wetting (when necessary).

*** Total Manganese emissions based on 41% of total PM10 emissions.

TOTAL CONTROLLED EMISSIONS **

(Capture efficiency of 95% of PM10 at all pick-up points)