MEMORANDUM

DATE: March 16

, 201 5

TO: Phil Mulrine

, EPA OAQPS/SPPD

FROM: Bradley Nelson

, E C/R

SUBJECT: Summary of the February 24

, 201 5 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 Prod uction

. 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
J ohn Rego, Jones Day Liz Marble , Eramet Marietta

Felman Production Laura McAfee, Beveridge & Diamond

Policy Navigation Group Troy Hillier

EC/R, Incorporated Bradley NelsonIII. 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 p olycyclic a romatic hydrocarbons ( PAH ) limits

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

, and 10/2014 test data s ubmitted 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 non

recoverable

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 pas te 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 contr ols 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

co ntrolled 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 par ticipate 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 f erroalloys facilities being built in the U.S., and will likely cause existing plants
to close once the furnaces need to b e modified or replaced.