MEMORANDUM 

DATE: April 28, 2014

TO: Phil Mulrine, EPA OAQPS/SPPD/MMG

FROM: Bradley Nelson, EC/R, Inc.

SUBJECT: Summary of the April 21, 2014 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 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

Phil Mulrine

Colin Boswell

Eramet Marietta 

Jeff McKinney, Eramet Marietta

John Rego, Jones Day

Felman Production

Laura McAfee, Beveridge and Diamond

Policy Navigation Group

Troy Hillier

EC/R Incorporated

Bradley Nelson 
III. 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.1The following is a brief summary of the major points that were discussed during the 

meeting.

NESHAP 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 an average limit of 6% (even after all the fugitive 

controls were in place) or a maximum limit of 15%. They expressed considerable concern 

about the ability to meet these opacity levels, especially during non-routine infrequent 

events. Thus, as an alternative, they suggested a two-prong approach which includes a 

10% average opacity 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 has 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 Discussed

 The industry plans on meeting with the OMB to discuss the proposed NESHAP on April 

30, 2014. Comments from OMB on the supplemental 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.