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**UNITED STA TES ENVIRONMENTA**  **L PROTECTION A GENCY**  **REGION III 1650 A**  **rch Street Philadelphia, Pennsylvania 19103**  **- 2029** 

**DATE** : March 19 , 201 2 **SUBJ** : Inspection Report of Felm an Production, LLC Plant in Letart, West

Virginia
**FROM:** Jam es Hagedorn , Environmental Scientist , Air Enforcement

Jerom e Curtin , Environmental Engineer , Air Enforcement
**VIA:** Chris Pilla, Associate Director , Office of Air Enforcement and Compliance

Assistance and File Room Mailing Address Felm an Production, LLC 4442 Graham

Station Road Letart, West Virginia 25253
EPA Enforcem ent Personnel Jim Hagedorn, Environmental Scientist, EPA, (215) 814

- 2161 Jerry Curtin, Environmental Engineer, EPA, (215) 814

- 3171 West Virginia DAQ Personnel
Jam es Robertson , State Environmental Engineer , (304) 926

- 0499, X

- 1697 Personnel from Felman Production Shawn McCutchan , Maintenance Manager, (304) 882

- 1402 Hal Newhouser , General Supervisor , (304) 882

- 1181 John Konrady, Plant Manager, (304) 882

- 1401 Jay Russell, SLR Corporation , (503) 723

- 44232 Nathaniel Lanham, SLR Corporation , (304) 932

- 3107 Rich Lunn, Environmental Compliance Manager, (304) 882

- 1181 Date of Inspection : 3/13/12

. EPA arrived on site at about 9 :00 am. **Overview** EPA conducted a full com pliance air inspection of the Felm an Production , LLC (Felm an) plant in Letart , Mason County, West Virginia on March 13, 2012

. This was an announced inspection where Felm an knew that EPA was going to inspect the plant in order to give them the tim e to accum ulate specific documents that EPA wished to review onsite. This plant produces silicomanganese for sale to the steel industry which uses it as an additive to steel product s. Felman does have a Title V permit issued by West Virginia in 2007 which regulates the air emissions from the plant. The plant has three submerged arc furnaces named #2, #5 and #7 furnaces. Number 2 furnace is the largest one they have right now. Thi s West Virginia facility sits on a 200 acre site around Letart, WV , and is the headquarters for Felman

. T he CEO of Fel m an is Mordechai Korf

, who is located in Miami, Florida

. This plant has 256 employees at the present time both union people and salaried people. The union representing the Felm an em

ployees is the United Steelworkers Union and the plant operates 24 hours per day and 7 days per week. The plant does not shut down unless there is scheduled maintenance or an unplanned equipm ent problem. They have been averaging about one furnace shutdown per month for a very short period of time (ie one day) according to the Com pany people.
**Narrative**
J im Hagedorn (the lead EPA investigator) and Jerry Curtin arrived on

- site at about 9 :00 am . Also invited was James Robertson who works for the West Virginia Division of Air Quality

. Shortly after arrival, EPA was escorted to a conference room for a detailed discussion of the inspection and agenda. Jerry Curtin and I identified ourselves to the pl ant personnel and presented our EPA credentials and identification. I told the Felm an personnel that EPA was on

- site to perform a comprehensive investigation of their f acility for compliance with the Clean Air Act at as many emission sources as the period of time would allow . I explained that we were looking at their c om pliance with all air regulations (NSPS, PSD, NSR, MACT, NESHAPs, their permit, etc). The Felman facility was targeted for inspection due to the proc ess used to make ferroalloys and the concerns of the Region with emission sources in this industry . EPA had em ailed a message to Felman on February 10 , 201 2 to inform them of our inspection, requesting that they have some documents available dealing with the processes , equipment, and3 emissions at the Letart , WV plant. I explained that EPA Region III oversees the air programs in 5 states (Pennsylvania, Maryland, Virginia, Delaware, and West Virginia) as well as the District of Columbia. I explained some rules as I indicated we wanted to dis cuss the Facility operations initially and then to physically examine the facilities and oth er air emission points . I further indicated that we wanted to take some photographs of the Facility and that we would s upply Felm an with a copy of the photos for their review. If they thought any of the photos were Confidential Business Information (CBI), we would mark them as such and treat them as such. I also indicated that I would be writing an inspection report when I returned to EPA so that if any discussion was to be considered CBI, please let me know so my report might reflect that. I noted that I would send a copy of my inspection report to Felman within about 6 weeks

. During this inspection, EPA reviewed with the Felman personnel some of the inform ation requested in our original email and the Company provided electronic files of the information for EPA review. The Company will send the files to EPA in electronic form

. At the conclusion of the inspection, EPA indicated that we may be contacting the Com pany for more inform ation regarding any remaining issues. Any written responses and documentation provided by this Com pany will be filed in EPA’s file room under Felm an P roduction, Inc. in Letart, WV at the conclusion of EPA’s investigation. The Com pany’s oral responses are noted in this report. EPA did take photographs of the site with a digital camera . A photo log is included at the end of this report. The information on the Felm an facility in Letart, WV , as noted in the following paragraphs , and also in general in this report , was provided to EPA by personnel from Felm an on March 13 , 201 2 as follows:
1. At the opening meeting, the attendees gave their employment history and positions. James Robertson is the State contact for the Felman facility handling inspections and enforcement issues. Shaun McCutchen is the Felman representative handling maintenance in the Letart plant having been with the Company since 12

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- 09. Previously, Shaun was with Century Aluminum in West Virginia and Severstal in Follansbee, WV. John Konrady is the plant manager who also attended the opening meeting and has a long history in industry. John provided a lot of the information contained in this report. SLR Company is the consultant used by Felman for environmental issues. Jay Russell was in attendance and works for SLR Consulting having been with this Company for the last 3 years. Nate Lanham also works for SLR4 Consulting out of their Charleston, WV office and started dealing with the Felman plant in 2005. Richard Lunn has not been with Felm an very long having started with Felman Production in November, 2011 and is curre ntly the Environmental Health and Safety manager for the Company at the Letart plant. Finally, Hal Newhouser was in attendance for Felman and is a production manager in the Letart facility but has only been with the Com pany since July, 2010.
2. The plant was not operating at full production the day of the inspection as the #2 furnace was shut down for maintenance needing baghouse repairs, furnace spout work, and furnace water leak repair. The Nos. 5 and 7 furnaces were in operation and are subm erged elec tric arc furnaces with baghouse particulate emission control devices. The air flowrate to the #2 baghouse (from the #2 furnace) was measured to be 450,000 actual cubic feet per minute at 500 degrees Fahrenheit. Each furnace has its own baghouse for parti culate emission control. The Company installed cooling tubes prior to the baghouses to remove heat from the hot exhaust gases coming from the arc furnaces so the hot gas does not burn the bags in the baghouses. This plant has no continuous opacity monito rs nor any continuous emission monitors but they do have five people certified in accordance with EPA Reference Test Method 9 to be able to evaluate the opacity of emissions coming from plant emission sources for regulation compliance purposes. Each furnace is tested every year to evaluate the emission rate of particulates, nitrogen oxides, sulfur dioxide, volatile organic compounds and carbon monoxide. The EPA publication, AP42, is used by the Company to calculate annual emissions from the pl ant and hazardous air pollutant emission rates are calculated based on an analysis of the dust pickup in the baghouse.
3. The WV air agency just issued a Notice of Violation to Felman for having unpermitted emission sources installed in the plant. These included a material crusher and screening operation but the Company discontinued their operation and had them removed from

the plant.
4. Felm an is owned by Georgian American Alloy s , Inc. , a U.S. company, incorporated in Delaware . This plant was owned by Vanadium Corporation of America initially back in 1951with the first metal h eat coming from the furnaces on July 12, 1952. Foote Minerals Company owned the plant after Vanadium Corporation and held onto ownership for 20 years or more. Foote Minerals eve ntually went bankrupt and the plant was bought out by American Alloys in the 70’s and the plant was resold/transferred at the end of the 90’s in an Employee Stock Ownership Plan to the em ployees. Highlander Alloys then bought the facility in 2000 and oper ated it until approximately 2002

- 03. It then operated under the ownership of Global Industrial Projects until 2005 when it shut down again due to bankruptcy. Igor Kolomo ysky5 form ed Felman Production, Inc. to buy the plant out of bankruptcy in 2006 . Th e com pany was converted to an LLC in 2012.
5. This plant manufactures silicomanganese for the steel industry and their product is 65

- 68 % manganese, 16

- 18% silicon, 15% iron, along with small percentages of carbon, sulfur and phosphorus. The standard spec ification for silicomanganese is given in the Am erican Society for Testing and Materials (ASTM) designation A483

- 04. Felm an sells their product through its sister company, Felman Trading, Inc. (which is based in Miami, FL) to various steelmakers such as Nucor, Gerdau Ameristeel, and Timken to nam e a few.
6. The Felm an plant currently produces approximately xxx xxxx of silicomanganese per day in three submerged arc furnaces and the breakdown is roughly xxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx . Xxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxx . Mr. Konrady stated that the U.S. market for silicomanganese is about 400,000 tons per year. Felm an produced xxxxxxxxxx of saleable product last year in this Letart plant. Er ame t Marietta , I nc. has a plant in Marietta, Ohio that manufactures this same product (as well as ferromanganese, another steel additive)

. Felman estimates that, when Eramet is making silicomanganese, the Er ame t and Felm an plants com bined make up about 45% of the U.S. s ilicomanganese market. Currently , China is im porting a lot of this material for their steel industry but Felm an ma in ly supplies U.S. companies. The Company describes its profit margins as extrem ely tight and dependent on, among other factors, the price o f manganese ore and the market price for silicomanganese, which varies considerably (e.g., between October 2011 and March 2012, the market price for silicomanganese fluctuated between $900 and $1200 per ton). At this time, the Company is trying to maximiz e the availability of their furnaces by minimizing breakdowns. Xxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxx xxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxx . 7. Am erican Electric Power (AEP) has two electricity generating stations in the immediate area of Letart, WV and Felm an gets its electric power from AEP. This is a large operating cost for this plant (second only to raw materials)

. Mr. Konrady mentioned that the electricity cost in the plant is approximately 2 million dollars per mo nth. Felm an negotiates its electricity rates with AEP pursuant to a West Virginia law that applies to the top five electricity users in the State. Felm an mi nimizes their electricity cost by being on an interruptible status with AEP where their electricity can be curtailed if conditions deman d additional electricity supply to homeowners (summer, winter, etc.). Felm an does not generate any of its own electric power.
8. The subm erged arc furnaces at Felm an utilize 3 carbon electrodes each to generate6 the heat, from electricity, to melt the fur nace charge materials. Carbon has to be added to the electrodes all the time as the electrodes are used up/consumed in the process. Felm an gets carbon paste prim arily from Elkem Carbon for needed additions to their electrodes.
9. At this time, Felman i s considering shutting down the facility in the next 2

- 3 years if the capital and operating costs associated with new and proposed air emissions control requirements make silicomanganese production in West Virginia uneconomical. If the facility is able to obtain the required air permits, the plant manager did say that there was the possibility of Felman installing an additional 1

- 2 furnace (s) in the plant ( which may be accom panied by a shutdown of 1

- 2 of the existing furnaces) . This would be a 30 mi llion dollar (per furnace) investment in the facility. The plant’s Title V permit was revised on May 12 , 2012 in order for the Company to install and operate a pelletizer, extruder and crusher for material handling purposes. The plant receives process materials via trucks and barges down the Ohio river. Felman Trading, Inc. coordinates the barges and trucks. The trucks are required to be tarped when hauling materials to and from Felm an property. Process m aterials are larg ely i mp orted, as there are no U.S. sources of manganese ore suitable for silicomanganese production

. Felman gets coke and coal from Kentucky , Ohio , and West Virginia

. Coke, coal, dolomite, quartzite and manganese oxide ore (39

- 48% manganese) are charged i nto the arc furnaces for melting. Once melted, the slag (non metal material) is separated from the metal (silicomanganese) . Any dust/fines from the charge material (size of 3/8 inch to 1 inch ) is sent to ACC Company to make briquettes which are shipped back to Felman for charging into their furnaces.
10. The charge material is stored in holding bins over the furnaces. Felm an uses a mi xing buggy with a weigh scale that moves back and forth on tracks weighing out a specific amount of each material into the buggy. The buggy gets dumped into the top of the furnace via a skip hoist . As the solid materials melt , more room is created in the furnace for charging more solid material. After a specified amount of electricity is used, the furnace is tapped at the bottom of the furnace (they make a hole and the molten material flows out). The molten material made of slag and metal is 3 000 degrees Fahrenheit in temperature. Felm an taps the furnace 6 times in a 12 hour shift. The slag is lighter than the metal so it is on top of the molten mass and can be separated from the metal. The slag and metal from the furnace goes to a ladle and the slag is poured off of the ladle into a slag pot which is dumped outside the Melt Shop. A company called Green Global handles the slag for Felman

. The slag can be used for road ballast and also for m aking mineral wool (Armstrong Industries in Millwood, WV, for example, relies on Felm an slag as raw material for its mineral wool production)

. The m etal goes to a casting nest and a cooling bin before being stockpiled. The casting nest is 3 feet wide7 and 40 feet long and 4 feet deep. The metal from the stockpile eventually goes to a crusher and sizing operation with the crushed metal going to a product stockpile. This stockpile is then used to fill a bulk truck which takes the product to the customer (steel com panies).
1 1. Felm an only makes one product but different customers want different sizes. The baghouse for PM control is an American Air Filter positive pressure baghouse with pulse jet bag cleaning; 256 bags per compartment and 11 compartments. The bag material is seamless polyester and can handle the normal gas temperature going thru the baghouse. The dust picked up in the baghouse bags is pelletized and then put back into the process.
12. The Company is going to supply EPA with its fugitive dust plan. The Com pany said that they water the plant roads down to control fugitive dust and have two street sweepers for getting dust off of the roads. Felm an also uses Petrotek dust suppressant on the roads too. The plant has two deepwells on the property for supplying cooling water and sanitary water comes from the Mason County Municipal Authority. The plant has a storm water permit from

WV and their permitted outfall goes to the Ohio river. The only water treatm ent done is sedimentation and Felm an does not generate a ny hazardous waste. The Company plans to rebag the #5 baghouse (handles the #5 furnace) in the immediate future. All the baghouses are equipped with magnahelic gauges for measuring the pressure drop across the compartments. Felman maintains one com partm ent’s worth of spare bags on hand all the time.
13. Felman has no flares in the plant. Felman does have the capability to analyze its product and the raw materials coming into the plant via a mass spectrograph in its lab. After looking at the records , EPA and WVDAQ r epresentatives then ate lunch around 12:00 noon with Company personnel and then proceeded with a walkthrough of the entire operation. Numerous pictures were taken of the plant equipment and additional information was obtained. The facility housekeeping was good and everyone was cooperative and helpful. Few odors were observed but heavy fugitive emissions were seen emanating from the Melt Shop Building windows, roof and side walls beginning at 1:45 PM when the facility was raking slag . A photo log is included at the end of this report. After the plant walkthrough, the government representatives convened with the Company in the same conference room to hold a closeout meeting to thank the Com pany representatives for their cooperation and to provide the logistics on them getting the inspection report and photographs. A discussion was held on the information8 to be sent to EPA which basically included all the information that was requested for review in EPA’s original email to Felman

. The Com pany was told of the fugitive emissions being seen coming from the Melt Shop B uilding at 1:45 PM which the Com pany representatives saw themselves

. Everyone was very helpful. EPA left the facility around 4 :00 PM

.

Photo Log Felm an Productions, LeTart, WV Photos taken by Jerry Curtin of EPA On 3/13/2012 beginning around 1:30 PM Photo No. Cam era Photo No. Description 1 0712 Truck Weigh Scale 2 0713 Plant in background. One can see one of the doghouses on the roof

. 3 0714 Shuttlecar to move slag 4 0715 #7 Furnace baghouse 5 0716 Storage area for raw material s - ores are dark, quartzite is l ight

. 6 0717 Fugitive emissions coming from the side o f the Melt Shop

. It is believed that these emissions are from furnace #7 6a 0717a Enhanced view of Photo 6
7 0718 Fugitive emissions coming from furnace #7 and 5 (to the far right) 7a 0718a Enhanced view of Photo 7 8 0719 Shakeout area for Furnace #2 9 0720 Baghouses for Furnaces7, 5 and 2 10 0721 Fugitive emissions from Furnace 5 10a 0721a Enhanced view of Photo 10 11 0722 Fugitives off roof area 12 0723 Tapping off of Furnace 7 12a 0723a Enhanced view of photo 12 13/14 0724

- 25 Casting Nets 15 0726 Tapping of Furnace 5 16 0727 Charging area of Furnace 7 16a 0727a Enhanced view of photo 169 17 0728 Tapping area of Furnace 7 17a 0728a Enhanced view of Photo 17 18 0729 Titler Fan, in operation when pouring ladles 18a 0729a Enhanced view of Photo 18 19 0730 Charging Floor of Furnace 7 20 0731 Charging Floor of Furnace 7 after raw material charge 21 0732 Cooling water used to cool Furnace 7 22 0733 Charging Floor of Furnace 7

- electrodes in middle 23/24 0734

- 35 Storage Bin where raw materials are dumped 24a 0735a Enhanced view of Photo 24 25 0737 #5 Furnace Charging Floor 27 0739 Pouring slag from the #7 Furnace Ladle into the Slag Pot 27a 0739a Enhanced view of Photo 27 29 0741 Raking and Pouring from #7 Ladle in the area of Furnace 9 (shutdown) 29a 0741a Enhanced view of Photo 29 30 0742 Openings in roof

- D oghouses 31. 0743 Portable Crushers 32. 0744 Outside view of Doghouses on top of roof

- EPA counted 8 of them **Information Requested From Felman**  1. Site Map, Organizational Chart 2. Air Permits from 2005 to Present 3. Air Emission Reports (2006

- 2011) 4. Air Emission Sources 5. Fuel Usage/Fuel Quality Reports 6. List of Flares if any. 7. Electricity Usage 8. List of Tanks, Size, Material Stored, Age 9. Testing Reports 2006 to Present 10. Method 9 Readings , CEMs data 11. List of Capital Pro

jects 12. Refrigeration Equipment, Refrigerant, Amount, Technician Certifications 13. List of Parts Cleaners 14. Records Required By Title V Permit 15. NSPS and MACT Records 16. Com pliance Certifications 2009

- 201110 17. Production Records 2006

- 2011 18. Information on Electric Arc Furnaces (Make , Model , Capacity, Manuals) 19. Information on Carbon Additions to Electrodes (How much, How often, Supplier) 20. Schematic of Furnace