MEMORANDUM 

DATE: March 16, 2015

TO: Phil Mulrine, EPA OAQPS/SPPD

FROM: Bradley Nelson, EC/R

SUBJECT: Summary of the February 24, 2015 Meeting with Representatives from Eramet 

Marietta and Felman Production and the U.S. Environmental Protection Agency

I. INTRODUCTION

The purpose of the meeting was to discuss the main comments on the supplemental proposal 

submitted by Eramet Marietta and Felman Production. This meeting summary will be available 

in the docket for this rulemaking (Docket ID No. EPA–HQ–OAR–2010–0895). The 

supplemental proposal was published in the Federal Register on October 6, 2014 (79 FR 60238). 

II. ATTENDEES

The following is a list of participants in the meeting.

U.S. Environmental Protection Agency

Chuck French

Phil Mulrine

Stef Johnson

Eramet Marietta 

John Rego, Jones Day

Liz Marble, Eramet Marietta

Felman Production

Laura McAfee, Beveridge & Diamond

Policy Navigation Group

Troy Hillier

EC/R, Incorporated

Bradley Nelson
III. SUMMARY OF DISCUSSION

The purpose of the meeting was to discuss the main comments submitted by the industry on the 

supplemental proposal (79 FR 60238). The industry proposed an agenda of six topics that they 

wanted to discuss. The following is a summary of those topics.

1. Revisions to polycyclic aromatic hydrocarbons (PAH) limits 

• The industry stated that the calculation of the PAH limit should include 7/2012, 10/2012, 

and 10/2014 test data submitted to EPA. Note that the 7/2012 was excluded because of 

substantial dilution of the sample. The 10/2012 test report was received prior to the 

publication of the supplemental proposal and the 10/2014 test was received during the 

comment period for the supplemental proposal.

• The industry believes that the 7/2012 should not have been excluded from the calculation 

of the PAH maximum achievable control technology (MACT) Floor. They noted that 

EPA has used 1-run test data in the past and not all of the PAH compounds were nonrecoverable

2. Earthjustice electrode paste comment 

• The industry believes that there is no technical basis for switching to low PAH electrodes 

used in the aluminum production industry and no available information that states it will 

reduce PAH emissions. The industry notes that these electrodes are not a commercial 

product.

• They note that the same electrodes used for ferromanganese (FeMn) production are used 

in silicomanganese (SiMn) production and they believe that the electrode paste is a small 

source of PAH emissions. They believe that the main difference between PAH emissions 

from the FeMn process and the SiMn process is more carbon and higher temperatures are

used to produce FeMn.

3. Compliance period(s) 

• The industry believes that EPA is not limited to a 2-year compliance period for putting 

the controls in place and requests that a 3-year period be provided.

• The industry states that they need time to obtain capital and to install the controls and that 

installing fugitive controls on 3 buildings in 2 years is not achievable. The industry stated 

that they could provide more information.
4. Revised particulate limits (scrubber vs. baghouse)

• The industry believes that there should be separate particulate matter limits for furnaces 

controlled with a baghouse and furnaces controlled with a scrubber.

5. Monitoring frequency and methods 

• The industry believes that the opacity requirements in the supplemental proposal are too 

stringent. They note that the opacity monitoring increased from once a year to 52 times a 

year.

• The industry notes that the digital camera opacity technique (DCOT) is not feasible 

because fugitive emissions come from different parts of the building. The representative 

from Felman Production noted that they did not participate in the example DCOT setup 

provided by a vendor in the comments on the supplemental proposal.

• The industry also stated that rooftop monitoring and fenceline monitoring are not good 

tools for ensuring compliance.

6. Activated carbon injection requirement for new ferroalloy furnaces 

• The industry stated that they agree with the activated carbon injection (ACI) cost 

estimates in the supplemental proposal for existing sources, but do not agree with the 

finding that ACI is cost effective for new sources.

• The industry believes that the new source mercury standard will reduce the probability of 

any new ferroalloys facilities being built in the U.S., and will likely cause existing plants 

to close once the furnaces need to be modified or replaced.