MEMORANDUM

DATE: October 2 3

, 201 3

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 th is 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 Conrad Chin Darcie Smith Rochelle Boyd Colin Boswell Steffan Johnson Brian Shrager Phil Mulrine

Eramet Marietta John Willoughby , Eramet Marietta Jeff McKinney, Eramet Marietta
J ohn Rego

, Jones DayFelman 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 contr ol 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.

H owever, t he 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 sup plemental 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 emiss ions 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 inf ormation 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)

.