Felman Historical PM Data with Statistics.XLSX imageool .gif

Conrad — I wanted to respond to your emails over the past few days. Let me start by trying to clarify theemissions associated with the raking/skimming process, as I think we are talking past each other here.You are correct that physically, the raking/skimming process has its own “station,” i.e., that it occurs at

a location that is physically between the tapping and casting operations and somewhat separate from

both. As Amy previously mentioned, however, all of the emissions calculations that we performed werebased on AP-42 emissions factors. Those emissions factors include all of the fugitive emissions

associated with the entire manufacturing process and allocate them to one of three main operations:

tapping, casting, and smelting. For the raking/skimming emissions, AP-42 allocated the emissions to the

casting portion of the process — so they are accounted for as part of that larger process, even if they are

not carved out separately.

Another approach would be to treat the raking/skimming as a separate sub-process, based on its

separate physical location. To do this, however, you would first need to identify which portion of the

total fugitive emissions from the facility is attributable to the raking/skimming process. You would then

need to subtract that amount from the AP-42 emissions factors for casting (which is where those

emissions are currently accounted for). So you would then have emissions factors that are broken

down into four separate processes — tapping, raking/skimming, casting, and smelting. But the

facility-wide total would be the same.The issue with the ICR data will require a little more discussion because of the extensive history here

and many issues involved. To begin, we are somewhat surprised at your comment that Felman waited

for two years before mentioning our concerns, given that Felman questioned the ICR data in its

comments on the proposed rule in February of this year, and the validity of those data — especially

relating to the July, 2010 stack tests — has been a significant recurring issue in your discussions and

emails with Amy and other Felman representatives over the past several months.

Nevertheless, I will attempt to summarize the main issues that I have been able to identify in the past

three days. Please note that this response does not address the new information you just providedabout the recalculated data from November, 2010, which we will need some time to review, but it does

include the April, 2011 stack test results that Rich forwarded to you earlier today. Felman’s concernsinclude:

• The use of the 3% manganese concentration from the July 2010 stack test on Furnace #2. As
• The results from the July 2010 stack test are internally inconsistent in a way that casts doubt on

the testing results. For example, we note that the measured flow rates differed by almost a

factor of two, without any apparent process reason for the difference.

• The results from the July 2010 stack tests are also inconsistent with other data from Furnace #2.

A comparison of the results shows that the emissions measured during the 2010 stack tests

were more than a factor of two higher than the results of the May 2009 stack tests on the samefurnace, again with no apparent process reason for the difference. Similarly, if you compare the

July 2010 data to the 2011 stack test that Felman recently provided, the average PM emissions

rate differ by a factor of 37 (4.65 lb/hr vs. 0.11 lb/hr).

• This conclusion is underscored when the results are corrected for furnace load. At the outset,

we note that the 2010 stack test identified the furnace load as 18 MW for all three runs — aconsistency that is extremely improbably over the course of three separate four-hour test runsover two different days. Felman has accordingly gone back to the furnace operating logs to

identify the actual furnace operating levels during these tests, which — not surprisingly — varied

far more than the test report would imply. We then calculated the lb/MW-hr for each test runto demonstrate the true variability between the 2009 and 2010 stack tests. As you can seefrom the attached spreadsheet, the standard deviation within the test runs range from 8% to

99%, and the relative standard deviation of the furnace-wide results range from 90% to 120%.

You also asked Felman to confirm that its concerns were limited to the Furnace 2 data. This is not

correct, because many of the issues I identified above also apply to the other test data. Specifically,

Felman’s concerns about the high variability — both between different runs during the same stack test

and across multiple stack tests — apply equally strongly to the remaining ICR data. The concerns about

variability are exemplified by looking at the differences in emission rates between the various test dates

for each of the furnaces. Furnace 2 PM emission rate estimates range from 0.11 to 2.06 lb/hr, a 42-folddifference; furnace 5 estimates range from 0.14 to 3.60 lb/hr, a 25-fold difference; and furnace 7estimates range from 0.12 to 5.59 Ib/hr, a 46-fold difference. Note that these differences are derived

from only the average results from each test day; an analysis of the individual runs shows differences

as high as 100-fold (compare Furnace 7, 11/17/09, run 1 result of 7.95 lb/hr to 4/28/11 run 2 on thesame furnace, with a result of 0.073 lb/hr).We are attaching a spreadsheet that demonstrates these issues. To prepare this spreadsheet, Felman

first confirmed the furnace operating load for all of the test runs and corrected the entries that

inaccurately implied that the loads were the same for all three runs. We then calculated lb/MW-hr

results for each run and recalculate the test averages, where appropriate. These results confirm thehigh degree of variability.
easo

s w

y the data we

e 

app

op

ate

y low or high 

the 

st case (e.g., testing errors, highly

variable operating conditions). Felman does not believe it is appropriate to cherry-pick the data merely

because one result appears too high or too low. If you insist on proceeding on the basis of the existing

ICR data, a more appropriate approach would be to include all of the available readings and then

include a high confidence interval, based on the very high variability within the data set.

Of course, as we have already discussed, Felman believes the most appropriate approach would be to

wait just a few more weeks until the results of the current stack tests are available. It is disheartening,to say the least, to hear that you are unwilling to wait for such a short period of time to obtain these

results. As you know, Felman was so concerned about the reliability of the ICR data that it offered toperform these stack tests, at its own significant cost, for the sole purpose of providing reliable data that

would assist EPA in developing a sound rule. Felman has discussed every aspect of these tests with EPA,

including various discussions of test methods and protocols in order to ensure that the data obtained

were as accurate as possible. EPA knew that these tests were scheduled for July and August — and yet,even though the Agency was operating under a September 15th deadline, not once did EPA suggest that

the test date be moved up or that the Agency might not have time to consider the data. Frankly,

Felman does not understand why this issue has arisen only after the rulemaking deadline has been

extended by more than three months — and after the Company has invested $85,000 on these voluntary

tests that it cannot recoup. I am sure you will understand that many Felman representatives are, at

best, extremely disappointed with this conclusion.

Felman continues to believe that everyone’s interests — EPAs, Felman’s, and the Sierra Club —are best

served by a rule that is grounded in solid, reliable data. Indeed, we understand that the issue of the

dearth of reliable data was raised not just by Felman, but by Sierra Club as well (and will likely continue

to come up in future discussions between all of the parties). We therefore sincerely hope that, after allof these months of discussion, EPA will not rush to judgment now that these data will so soon beavailable.

Thanks, and I hope you enjoy your time off. We look forward to continuing our discussions upon your

return.LauraLaura K. McAfeePrincipalBeveridge & Diamond, P.C.

201 North Charles St. Suite 2210

Baltimore, MD 21201 / T(410) 230-1330F(410) 230-1389 I

LMcAfee@Thd law corn & D1AMOND
Felman Furnaces #2, 5, 7

Run Number Date Sampling Location

Furnace Load 

(MW)

PM 

Concentration 

(gr/dscf)

PM Emissions 

(lb/hr)

Average Test 

PM 

Concentration 

(gr/dscf)

Average Test 

PM Emissions 

(lb/hr)

Average Test 

(lb/hr/MW)

 LAN Review of Furnace Load Based 

on Felman Records

Furnace Load 

(MW) by LAN

Ratio of PM to 

Energy Used 

(lb/hr/MW) by 

LAN

1 5/21/2009 Furnace #2 Baghouse Outlet 18.80 0.000338 1.33 0.071 Confirmed* 18.80 0.071

2 5/21/2009 Furnace #2 Baghouse Outlet 16.90 0.000650 2.36 0.140 Confirmed* 16.90 0.140

3 5/21/2009 Furnace #2 Baghouse Outlet 17.66 0.000652 2.49 0.000547 2.06 0.141 Confirmed* 17.66 0.141

1 7/9/2010 Furnace #2 Baghouse Outlet 18.00 0.001044 6.20 0.344 Should be approximately 22 MW** 22.00 0.282

2 7/9/2010 Furnace #2 Baghouse Outlet 18.00 0.000541 2.59 0.144 Should be approximately 22 MW** 22.00 0.118

3 7/10/2010 Furnace #2 Baghouse Outlet 18.00 0.001631 5.15 0.001072 4.65 0.286 Should be approximately 27.5 MW** 27.50 0.187

1 4/26/2011 Furnace #2 Baghouse Outlet 27.34 0.000900 0.10 0.004 27.34 0.004

2 4/26/2011 Furnace #2 Baghouse Outlet 22.50 0.000900 0.09 0.000 22.50 0.004

3 4/26/2011 Furnace #2 Baghouse Outlet 28.75 0.001500 0.14 0.001100 0.11 0.000 28.75 0.005

1 10/29/2007 Furnace #5 Baghouse Outlet 12.69 0.002617 7.03 0.554 Confirmed* 12.69 0.554

2 10/30/2007 Furnace #5 Baghouse Outlet 13.34 0.000664 1.81 0.136 Confirmed* 13.34 0.136

3 10/30/2007 Furnace #5 Baghouse Outlet 13.47 0.000793 1.95 0.001358 3.60 0.145 Confirmed* 13.47 0.145

1 11/17/2008 Furnace #5 Baghouse Outlet 16.74 0.000499 1.44 0.086 Should be approximately 14.04 MW** 14.04 0.103

2 11/17/2008 Furnace #5 Baghouse Outlet 16.74 0.000166 0.31 0.019 Should be approximately 15.04 MW** 15.04 0.021

3 11/17/2008 Furnace #5 Baghouse Outlet 16.74 0.000287 0.30 0.000317 0.68 0.018 Should be approximately 14.61 MW** 14.61 0.021

1 11/18/2009 Furnace #5 Baghouse Outlet 14.76 0.001411 4.80 0.325 Confirmed* 14.76 0.325

2 11/18/2009 Furnace #5 Baghouse Outlet 14.99 0.001430 4.92 0.328 Confirmed* 14.99 0.328

3 11/18/2009 Furnace #5 Baghouse Outlet 15.04 0.000254 0.93 0.001032 3.55 0.062 Confirmed* 15.04 0.062

1 4/27/2011 Furnace #5 Baghouse Outlet 15.40 0.002700 0.17 0.011 15.40 0.011

2 4/27/2011 Furnace #5 Baghouse Outlet 13.75 0.002400 0.13 0.009 13.75 0.009

3 4/27/2011 Furnace #5 Baghouse Outlet 12.55 0.002300 0.13 0.002467 0.14 0.010 12.55 0.010

1 11/18/2008 Furnace #7 Baghouse Outlet 18.60 0.000216 0.80 0.043 Should be approximately 16.08 MW** 16.08 0.050

2 11/18/2008 Furnace #7 Baghouse Outlet 18.60 0.000383 1.10 0.059 Should be approximately 15.99 MW** 15.99 0.069

3 11/18/2008 Furnace #7 Baghouse Outlet 18.60 0.000675 1.80 0.000425 1.23 0.097 Should be approximately 15.05 MW** 15.05 0.120

1 11/17/2009 Furnace #7 Baghouse Outlet 14.91 0.002457 7.95 0.533 Confirmed* 14.91 0.533

2 11/17/2009 Furnace #7 Baghouse Outlet 13.83 0.001524 5.08 0.367 Confirmed* 13.83 0.367

3 11/17/2009 Furnace #7 Baghouse Outlet 13.70 0.001118 3.73 0.001700 5.59 0.272 Confirmed* 13.70 0.272

1 4/28/2011 Furnace #7 Baghouse Outlet 12.80 0.001700 0.14 0.011 12.80 0.011

2 4/28/2011 Furnace #7 Baghouse Outlet 15.30 0.001000 0.07 0.005 15.30 0.005

3 4/28/2011 Furnace #7 Baghouse Outlet 15.4 0.0024 0.1536 0.001700 0.12 0.010 15.40 0.010

loads were calculated from the daily furnace records for the stack test dates, averaged over the time frame during which each run was conducted

* Confirmed by looking at daily furnace records (2007 and November, 2009, records were included in the stack test reports)
Run 

Number Date Sampling Location

PM Emissions 

(lb/hr)

Average PM 

Emissions 

(lb/hr)

Relative 

Standard 

Deviation

Average of 

Furnace PM 

(lb/hr)

1 5/21/2009 1.33

2 5/21/2009 2.36 2.06

3 5/21/2009 2.49

1 7/9/2010 6.20

2 7/9/2010 2.59 4.65

3 7/10/2010 5.15

1 4/26/2011 0.104

2 4/26/2011 0.089 0.11

3 4/26/2011 0.139

1 10/29/2007 7.03

2 10/30/2007 1.81 3.60

3 10/30/2007 1.95

1 11/17/2008 1.44

2 11/17/2008 0.31 0.68

3 11/17/2008 0.30

1 11/18/2009 4.80

2 11/18/2009 4.92 3.55

3 11/18/2009 0.93

1 4/27/2011 0.166

2 4/27/2011 0.126 0.14

3 4/27/2011 0.126

1 11/18/2008 0.80

2 11/18/2008 1.10 1.23

3 11/18/2008 1.80

1 11/17/2009 7.95

2 11/17/2009 5.08 5.59

3 11/17/2009 3.73

1 4/28/2011 0.137

2 4/28/2011 0.073 0.12

3 4/28/2011 0.154

2.27

1.99

2.31

40%

31%

Furnace #2 Baghouse Outlet

Furnace #5 Baghouse Outlet

Furnace #7 Baghouse Outlet

23%

17%

35%

39%

42%

64%

96%

83%
Relative Standard 

Deviation of 

Furnace

97%

117%

118%
Run 

Number Date Sampling Location

 

to Energy 

Used 

(lb/MWh)

Relative 

Standard 

Deviation

Average of 

Furnace PM 

(lb/MWh)

Relative Standard 

Deviation of 

Furnace

1 5/21/2009 0.071

2 5/21/2009 0.140

3 5/21/2009 0.141

1 7/9/2010 0.344

2 7/9/2010 0.144

3 7/10/2010 0.286

1 4/26/2011 0.004

2 4/26/2011 0.000

3 4/26/2011 0.000

1 10/29/2007 0.554

2 10/30/2007 0.136

3 10/30/2007 0.145

1 11/17/2008 0.086

2 11/17/2008 0.019

3 11/17/2008 0.018

1 11/18/2009 0.325

2 11/18/2009 0.328

3 11/18/2009 0.062

1 4/27/2011 0.011

2 4/27/2011 0.009

3 4/27/2011 0.010

1 11/18/2008 0.043

2 11/18/2008 0.059

3 11/18/2008 0.097

1 11/17/2009 0.533

2 11/17/2009 0.367

3 11/17/2009 0.272

1 4/28/2011 0.011

2 4/28/2011 0.005

3 4/28/2011 0.010

Furnace #2 Baghouse Outlet 0.13 99%

Furnace #5 Baghouse Outlet 0.14 122%

40%

167%

8%

34%

86%

96%

64%

Furnace #7 Baghouse Outlet

42%

34% 0.16 123%

38%
Run 

Number Date Sampling Location

 

to Energy 

Used 

(lb/MWh)

Relative 

Standard 

Deviation

Average of 

Furnace PM 

(lb/MWh)

Relative Standard 

Deviation of 

Furnace

1 5/21/2009 0.071

2 5/21/2009 0.140

3 5/21/2009 0.141

1 7/9/2010 0.282

2 7/9/2010 0.118

3 7/10/2010 0.187

1 4/26/2011 0.004

2 4/26/2011 0.004

3 4/26/2011 0.005

1 10/29/2007 0.554

2 10/30/2007 0.136

3 10/30/2007 0.145

1 11/17/2008 0.103

2 11/17/2008 0.021

3 11/17/2008 0.021

1 11/18/2009 0.325

2 11/18/2009 0.328

3 11/18/2009 0.062

1 4/27/2011 0.011

2 4/27/2011 0.009

3 4/27/2011 0.010

1 11/18/2008 0.050

2 11/18/2008 0.069

3 11/18/2008 0.120

1 11/17/2009 0.533

2 11/17/2009 0.367

3 11/17/2009 0.272

1 4/28/2011 0.011

2 4/28/2011 0.005

3 4/28/2011 0.010

Furnace #2 Baghouse Outlet 0.11 90%

Furnace #5 Baghouse Outlet 0.14 120%

42%

13%

8%

34%

86%

99%

64%

Furnace #7 Baghouse Outlet

45%

34% 0.16 118%

38%