# E C



# / R I ncorporated Providing Environmental Technical Support Since 1989

1 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 o f 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
J ohn Rego, Jones Day Tom Gerstle, Environmental Quality Management2

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 discuss ed 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 a dditional expense of conduct ing 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 bo ttom 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. Johnso n suggested that the test plan be revised to require a minimum sample volume of 1 cubic meter, and the group agreed.3

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 a nd 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 u nlikely. 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.