MEMORANDUM

DATE: April 2 8

, 201 4

TO: Phil Mulrine

, EPA OAQPS/SPPD/ MMG

FROM: Bradley Nelson, EC/R, Inc.

SUBJECT: Summary of the April 2 1, 201 4 Meeting with the Ferroalloys Production Industry

and the U.S. Environmental Protection Agency

I. INTRODUCTION

The purpose of the teleconference was to follow

- up on the proposed opacity requirements submitted by the industry. 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 Phil Mulrine Colin Boswell

Eramet Marietta Jeff McKinney, Eramet Marietta J ohn Rego

, Jones Day

Felman Production Laura McAfee, Beveridge and Diamond

Policy Navigation Group Troy Hillier

EC/R Incorporated Bradley NelsonIII. SUMMARY OF DISCUSSION

The purpose of the meeting was to continue the discussion of opacity and monitoring options for the supplemental proposal. The industry provided opacity and monitoring options prior to the February 26, 2014 meeting with the industry and were included as an attachment to the meeting minutes. 1 The following is a brief summary of the major points that were discussed during the meeting

.

NESHA P Opacity Standard

 Regarding possible opacity standards, it was mentioned that EPA was considering an
average opacity limit of 6% during the furnace process cycle (e.g., from furnace tap to the next furnace tap) and opacity not to exceed 15% for any 6

- minute reading observation block for the supplemental proposal These values were derived from the opacity data submitted by the facilities, requirements from other rules, and engineering judgment.

 The industry representatives explained that there were substantial uncertainties whether the facilities would be able meet a n average limit of 6% (even after all the fugitive controls were in place ) or a max imum limit of 15 %

. They expressed considerable concern about the ability to meet these opacity levels, especially during non

- routine infrequent

events . Thus, a s an alternative, they suggested a two

- prong approach which includes a 10% average opaci ty limit and 20% cap for any six

- minute period during normal operations, and a 15% average opacity limit and 30% cap during non

- routine events. These non

- routine events include furnace blow, blowing tap, oxygen lancing and/or electrode burndown.

 The industry noted that these non

- routine events are currently not covered by the existing NESHAP and the industry ha s not studied or collected any data from these events

.

 The supplemental proposal requires a weekly opacity reading for each operating furnace. The industry stated that this requirement would necessitate approximately one man

- day to perform the opacity readings, which they believe is excessive.

 The supplemental proposal also requires parametric monitoring of the fugitive capture system. These parametric monitoring requirements are comparable to the current NESHAP monitoring requirements

.
Other Topics D i scussed

 The industry plans on meeting with the OMB to discuss the proposed NESHAP on April 30, 2014. Comments from OMB on the su pplemental proposal are expected to be received following the meeting.

1 Memorandum from Bradley Nelson, EC/R to Phil Mulrine, EPA OAQPS/SPPD/MMG

, Summary of the February 26, 2014 Meeting with the Ferroalloys Production Industry and the U.S. Environmental Protection Agency , March 3, 2014. The EPA expects to finalize the supplemental proposal in mid

- May. The deadline for the

supplemental proposal is May 30, 2014.