MEMORANDUM 

DATE: November 4, 2013

TO: Conrad Chin, EPA OAQPS/SPPD/MMG

FROM: Bradley Nelson, EC/R, Inc.

SUBJECT: Summary of the October 29, 2013 Meeting with the Eramet Marietta, Felman 

Production and the U.S. Environmental Protection Agency

I. INTRODUCTION

The purpose of the teleconference was to discuss available opacity data and the potential for 

development of revised opacity standards that could potentially be included in the rule as a 

measure to determine improved fugitive emission capture and control. 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). 

II. ATTENDEES

The following is a list of participants in the meeting.

U.S. Environmental Protection Agency

Chuck French

Conrad Chin

Rochelle Boyd

Colin Boswell

Steffan Johnson

Phil Mulrine

Eramet Marietta 

Jeff McKinney, Eramet Marietta

John Rego, Jones Day

Felman Production

John Konrady, Felman Production

Shawn McCutchan, Felman Production

Laura McAfee, Beveridge and Diamond

Policy Navigation Group

Troy Hillier
EC/R Incorporated

Bradley Nelson 

III. SUMMARY OF DISCUSSION

The meeting was used to discuss available opacity data and the potential for development of 

revised opacity standards that could potentially be included in the rule as a measure to determine 

improved fugitive emission capture and control. An agenda of the discussion topics for this 

teleconference is provided by the Policy Navigation Group in Attachment A of this meeting 

summary. The following is a brief summary of the major points that were discussed during the 

meeting.

NESHAP Opacity Standard

 The EPA stated that they were considering a possible regulatory option that would use an 

opacity standard as a measure to demonstrate compliance with the fugitive emissions 

capture requirements for the Ferroalloys Production rulemaking that could be proposed in 

a possible future supplemental proposal. 

 EPA explained that the current opacity standard for ferroalloys production in 40 CFR 

Part 63 subpart XXX states the following: 

§63.1653 Opacity standards.

No owner or operator shall cause emissions exiting from a shop due solely to operations 

of any affected submerged arc furnace, to exceed 20 percent opacity for more than one 6-

minute period during any performance test, with the following exceptions:

(a) Visible particulate emissions from a shop due solely to operation of a semi-closed 

submerged arc furnace, may exceed 20 percent opacity, measured as a 6-minute average, 

one time during any performance test, so long as the emissions never exceed 60 percent 

opacity, measured as a 6-minute average.

(b) Blowing taps, poling and oxygen lancing of the tap hole; burndowns associated with 

electrode measurements; and maintenance activities associated with submerged arc 

furnaces and casting operations are exempt from the opacity standards specified in this 

section.

 The proposed rule published in November 2011 included a more stringent proposed 

opacity standard that would require that emissions exiting the shop building could not 

exceed 10 percent opacity for more than one 6-minute period. 
 The industry representatives noted that the opacity data that they provided to EPA does 

not include unusual operations such as; blowing taps, lancing, or electrode burning. The

industry representatives noted that these are unusual events that occur infrequently, but 

they do occur and are unavoidable. 

 Eramet Marietta stated that the opacity was measured across the furnace roof and 

includes tapping, casting, and raking. Felman Production believes that their opacity was 

measured at the roof monitor, but will confirm with their opacity readers. Both facilities 

stated that no corrections were applied to the opacity data.

 The EPA stated that one option being considered is to establish an opacity limit 

somewhat similar to one proposed in November 2011 (maybe in the range of 5 to 10%), 

but also include a not-to-exceed opacity limit to account for unavoidable occasional 

spikes in emissions. EPA staff also said that they thought available opacity data from 

past testing could potentially be used as a starting point to help EPA understand current 

conditions and to help determine what future opacity limits could be achieved after 

improved controls are installed to reduce fugitive emissions. .

 To EPA’s question as to whether the companies had any additional opacity data they 

would like to share with EPA, Eramet Marietta stated that they performed some initial 

tests for opacity but did not develop a full monitoring report. Felman Production stated 

they would look and see if additional opacity data are available. 

 The industry representatives believe that a reasonable averaging time is needed to 

coincide with their ferroalloys production. They suggested the averaging time be linked 

to the furnace cycle (e.g., tap-to-tap). They also stated that there are three critical events 

(e.g., tapping, raking, casting) that could also be used as markers. Felman Production 

noted that their furnaces are located in the same building and they stagger the tapping of 

each of the furnaces, therefore tapping, raking or casting from one of the furnaces is most 

likely occurring inside the building at any time.

 The industry representatives believe that a longer averaging time or exemptions are 

needed to comply with an opacity standard during oxygen lancing, blowing taps, poling, 

and electrode burning. The EPA stated they would like to receive additional information 

about these events including: how and why they occur, the duration of the event, and the 

expected opacity during the event.

Other Topics Discussed

 The EPA are in the process of reanalyzing the mercury control options for the furnace 

melting operation. This includes developing cost for the installation of activated mercury 

injection (ACI) using the cost algorithms from the Mercury and Air Toxics Standards 

(MATS).

 The EPA noted that they are currently using the test data provided by the facilities, and 

for Eramet Marietta, and plan to assume a 50:50 production of FeMn and SiMn in each of 
the furnaces to estimate mercury emissions. EPA also said they are analyzing potential 

control options including the costs and reductions that could be achieved with Activated 

Carbon Injection (ACI). Based on limited available information, EPA staff stated that 

for the initial draft analyses, the staff was leaning toward using the assumption that ACI 

would achieve 90% reduction when applied to the furnaces controlled with baghouses, 

but that ACI applied to wet scrubbers would likely achieve less reductions, such as 

maybe 70%. However, EPA also clearly stated that this was just the staff’s initial 

thinking and that further review and evaluation was necessary regarding the potential 

costs and reductions for mercury controls and that the assumptions and calculations could 

change as we get further along. 

 The EPA also reminded the companies that EPA will need to estimate the costs of all the 

controls options being considered, and that the companies are welcome to submit cost 

information they may have to help inform the EPA’s cost analyses, and if so, the 

companies should send such information in November so that EPA has time to fully 

consider it in the analyses of various control options. 

 The EPA also asked Felman if they had any information or explanation for unusually 

high manganes emissions measured in the 2012 test results for Furnace 7. 
ATTACHMENT A

Agenda for 10/29/2013 Meeting with Eramet Marietta, Felman Production, and EPA
Chuck,

The following is a draft of the agenda that you and I discussed to help guide the conversation on our 

teleconference later today regarding development of an opacity standard for measuring compliance 

with the fugitive emissions reductions envisioned in the ferroalloy production NESHAP. I am including 

all participants on this message so that everyone has a chance to review and suggest any changes.

Agenda for Opacity Standard Discussion

1. Brief statement of understanding of the role of the opacity standard in the context of the 

NESHAP.

2. Review of the existing standard and proposed standard.

3. Questions regarding existing data.

a. EPA questions regarding existing data

b. Status of any additional data

c. EPA Technical questions regarding methodology

4. Discussion of main issues regarding prospective standard

a. What is a reasonable and achievable level for an opacity based enforcement standard?

b. What is an appropriate averaging period for such a standard?

c. How will the standard address variability and potential expected excursions?

In addition to the opacity discussion, and time allowing, you suggested the following additional topics 

for discussion:

1. Update on status on mercury cost-effectiveness analysis

2. Addressing company questions related to the request for cost information

3. Explanation for high reported manganese number at Felman furnace 7 in 2012 test data 

(probably best handled in a separate conversation as the people most familiar with that data are 

not scheduled to be part of this call).

If I have left anything off, or issues that you and I did not identify that others want to add, please let me 

know.

Talk to everyone at 3.