MEMORANDUM 

DATE: October 23, 2013

TO: Conrad Chin, EPA OAQPS/SPPD/MMG

FROM: Bradley Nelson, EC/R, Inc.

SUBJECT: Summary of the September 11, 2013 Meeting with the Eramet Marietta, Felman 

Production and the U.S. Environmental Protection Agency

I. INTRODUCTION

The purpose of the teleconference was to discuss the potential control options for fugitive 

emissions that were provided by the Eramet Marietta and Felman Production in the July 31, 2013 

meeting. 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

Conrad Chin

Darcie Smith

Rochelle Boyd

Colin Boswell

Steffan Johnson

Brian Shrager

Phil Mulrine

Eramet Marietta 

John Willoughby, Eramet Marietta 

Jeff McKinney, Eramet Marietta

John Rego, Jones Day
Felman Production

John Konrady, Felman Production

Shawn McCutchan, Felman Production

Laura McAfee, Beveridge and Diamond

Policy Navigation Group

Troy Hillier

Jonathan Gledhill

EC/R Incorporated

Bradley Nelson 

III. SUMMARY OF DISCUSSION

The meeting is intended to follow-up on the potential fugitive emissions capture plans proposed 

by Eramet and Felman in the July 31, 2013 meeting with the EPA. The EPA would like to 

receive additional information on the cost and implementation of the enhanced fugitive capture 

plans. The following is a brief summary of the major points that were discussed during the 

meeting.

 The EPA stated that they are still under a December 10, 2013 consent decree for the final 

rule, but are in discussion with the litigants to obtain an extension. The current proposed 

plan by EPA is to submit a supplemental proposal in March 2014, and finalize the rule in 

late 2014 or early 2015. 

 The facilities would have 2 years after the publication of the final rule to have the control 

in place to be in compliance with the requirements in the final rule.

 Eramet stated that they had rough estimates of the cost of installing an enhanced fugitive 

capture system, and will refine those costs during the final design of the capture system. 

However, the final design cannot be completed until the facility knows what the specific 

requirements of the final rule are. 

 The EPA stated that they need to go through the process of determining the impacts of 

the requirements as part of preparing the supplemental proposal, and would like to use 

the same cost estimates as the facilities. 

 Eramet is currently in development of a new product split that affects mercury emissions 

from the furnace control device outlets.

 The EPA is currently modeling the emissions from the ferroalloy facilities using the test 

data collected from the facilities. For Eramet, EPA used an assumption of 50/50 

production of FeMn and SiMn for estimating emissions from the furnaces. The facilities 

offered to supply any additional information that may be needed to complete the 

modeling.

 The facilities are willing to share opacity information with EPA that includes opacity 

readings during other operations (e.g., casting, skimming, raking).