MEMORANDUM

DATE: November 4

, 201 3

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

, Jones Day

Felman Production John Konrady, Felman Production Shawn McCutchan, Felman Production Laura McAfee, Beveridge and Diamond

Policy Navigation Group Troy HillierEC/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 requireme nts for the Ferroalloys Production rulemaking that could be proposed in a possible future supplemental proposal

.

 EPA explained that t he current opacity standa rd 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 followi ng 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 neve r 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 opera tions are exempt from the opacity standards specified in this

section.

 The proposed rule published in November 201 1 included a more stringent proposed opacity standard that would require that emission s exiting the shop building could not exceed 10 percent opacity for more than one 6

- minute period. The industry rep resentative s 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 rep resentative s noted th at 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
include s tapping, casting, and raking . Felman Production believes that their opacity was measured at the roof monitor, but will confirm with the ir opacity readers . Both facilities stated that no corrections were applied to the opacity data.

 The EPA stated that one option being consider ed is to establish a n 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 tes ting 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 wh ether 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 l onger 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 D i scussed

 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 Mer cury 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 ofthe furnaces to estimate mercury emission s

. EPA also said they are analyzing potential

control options including the costs and reductions that could be a chieved with Activated
Carbon I njection (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 mea sured in the 2012 test results for Furnace 7.ATTACHMENT A

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

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 standar d.

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 fol lowing 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.

Ta lk to everyone at 3.