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/R Incorporated Providing Environmental Technical Support Since 1989

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MEMORANDUM 

DATE: December 17, 2012

TO: Conrad Chin, EPA OAQPS/SPPD/MMG

FROM: Beth Friedman, EC/R, Inc.

SUBJECT: Summary of the December 13, 2012 Teleconference with Eramet Marietta, 

Felman Production and the U.S. Environmental Protection Agency

I. INTRODUCTION

The primary purpose of this call with Eramet Marietta and Felman Production was to discuss 

remaining issues associated with development of the pending information collection request 

(ICR) test program. This meeting summary will be available in the docket for this rulemaking 

(Docket ID No. EPA–HQ–OAR–2010–0895). 

II. ATTENDEES

The following is a list of participants in the teleconference.

U.S. Environmental Protection Agency

Rochelle Boyd

Conrad Chin

Chuck French

Stef Johnson

Ray Merrill

Jeff Ryan

Robin Segall

Eramet Marietta 

John Hughes, Eramet Marietta

Jeff McKinney, Eramet Marietta

John Rego, Jones Day

Tom Gerstle, Environmental Quality Management
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Felman Production

John Konrady, Felman Production

Shawn McCutchan, Felman Production

Katie Kulik, LAN Associates

Laura McAfee, Beveridge and Diamond

Derek Saballos, LAN Associates

Joe Gross, LAN Associates

EC/R Incorporated

Beth Friedman

Bradley Nelson 

III. SUMMARY OF DISCUSSION

The group discussed issues related to finalizing the ICR test plan for the plants. Following is a 

brief summary of the major points that were discussed during the call. 

Mercury Data Test Methods

 EPA sees benefit in obtaining mercury data using Method 30B as well as speciated 

mercury data using the Ontario-Hydro method. Instead of assuming that a default 80 

percent of the mercury detected is elemental and 20 percent is oxidized, the actual 

speciation would inform the revised risk analysis.

 Mr. McKinney said that the additional expense of conducting the Ontario-Hydro method 

is not justified because the level of mercury emissions varies during the process, which 

negates the value of a “snapshot.” While he would predict that there would be more 

oxidized mercury in the bottom of the furnace, mercury emissions at the top of the 

furnace may be more in elemental form. Similarly, the profile of emissions from the stack 

probably differs from the profile from fugitive emissions and the profile of the baghouse 

stack differs from the profile of the scrubber stack.

PAH Testing Questions

 Mr. Gerstle questioned the sample volume specified for the PAH test. Dr. Merrill said 

that it is important to avoid too much dilution. Mr. Johnson suggested that the test plan be 

revised to require a minimum sample volume of 1 cubic meter, and the group agreed.
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Fugitive Emissions Testing

 Mr. French noted that EPA is waiting to hear from the plants regarding fugitive emissions 

testing dates and approaches. 

Status of Revised Enhanced Local Capture Options

 The plants are working on updated enhanced local capture options, but are also waiting to 

see the outcome of new baseline emission estimates to help develop them.

Schedule for Releasing ICR and Conducting Testing

 Mr. Rego asked that the plants be allowed to review the final ICR before EPA issues it to 

see how EPA has addressed their comments from the November 9, 2012 meeting.

 At this point, the plants believe that testing in January 2013 is unlikely. Eramet plans to 

use the test to satisfy their 2013 particulate matter testing requirements, which requires a 

30-day notice to the state. They also warned that adverse weather conditions could delay 

testing and so could labor negotiations at Eramet. Mr. Rego noted that they will have 

“winter” ore throughout the first quarter of the year.

 Mr. French stressed the need to have test results to EPA by the end of March 2013.