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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

1650 Arch Street

Philadelphia, Pennsylvania 19103-2029

DATE : March 19, 2012

SUBJ: Inspection Report of Felman Production, LLC Plant in Letart, West 

Virginia

FROM: James Hagedorn, Environmental Scientist, Air Enforcement 

Jerome Curtin, Environmental Engineer, Air Enforcement 

VIA: Chris Pilla, Associate Director, Office of Air Enforcement and Compliance

Assistance

and

File Room

Mailing Address

Felman Production, LLC

4442 Graham Station Road

Letart, West Virginia 25253

EPA Enforcement Personnel

Jim Hagedorn, Environmental Scientist, EPA, (215) 814-2161

Jerry Curtin, Environmental Engineer, EPA, (215) 814-3171

West Virginia DAQ Personnel

James 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) 723-4423
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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 compliance air inspection of the Felman Production, LLC

(Felman) plant in Letart, Mason County, West Virginia on March 13, 2012. This was 

an announced inspection where Felman knew that EPA was going to inspect the plant in 

order to give them the time to accumulate 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 products. 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. This West Virginia facility sits on a 200 acre site 

around Letart, WV, and is the headquarters for Felman. The CEO of Felman 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 

Felman employees 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 equipment problem. They have been averaging about one 

furnace shutdown per month for a very short period of time (ie one day) according to 

the Company people.

Narrative

Jim 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 plant personnel and presented our EPA credentials and identification. I told the 

Felman personnel that EPA was on-site to perform a comprehensive investigation of 

their facility 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 compliance with 

all air regulations (NSPS, PSD, NSR, MACT, NESHAPs, their permit, etc). The Felman

facility was targeted for inspection due to the process used to make ferroalloys and the 

concerns of the Region with emission sources in this industry. EPA had emailed a 

message to Felman on February 10, 2012 to inform them of our inspection, requesting 

that they have some documents available dealing with the processes, equipment, and 
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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 discuss the Facility operations 

initially and then to physically examine the facilities and other air emission points. I 

further indicated that we wanted to take some photographs of the Facility and that we 

would supply Felman 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 

information 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 

Company for more information regarding any remaining issues. Any written responses 

and documentation provided by this Company will be filed in EPA’s file room under 

Felman Production, Inc. in Letart, WV at the conclusion of EPA’s investigation. The 

Company’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 Felman facility in Letart, WV,

as noted in the following paragraphs, and also in general in this report, was provided to 

EPA by personnel from Felman on March 13, 2012 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 12-2-09. 

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 SLR 
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Consulting out of their Charleston, WV office and started dealing with the Felman plant 

in 2005. Richard Lunn has not been with Felman very long having started with Felman 

Production in November, 2011 and is currently 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 

Company 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 

submerged electric 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 

particulate 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 monitors 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 

plant 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. Felman is owned by Georgian American Alloys, Inc., a U.S. company, 

incorporated in Delaware. This plant was owned by Vanadium Corporation of America 

initially back in 1951with the first metal heat 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 eventually 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 

employees. Highlander Alloys then bought the facility in 2000 and operated 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 Kolomoysky
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formed Felman Production, Inc. to buy the plant out of bankruptcy in 2006 . The 

company 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 specification for silicomanganese is given in the 

American Society for Testing and Materials (ASTM) designation A483-04. Felman

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 

name a few.

6. The Felman 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. Felman produced xxxxxxxxxx of 

saleable product last year in this Letart plant. Eramet Marietta, Inc. 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 

Eramet and Felman plants combined make up about 45% of the U.S. silicomanganese 

market. Currently, China is importing a lot of this material for their steel industry but 

Felman mainly supplies U.S. companies. The Company describes its profit margins as 

extremely tight and dependent on, among other factors, the price of 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 maximize the availability of 

their furnaces by minimizing breakdowns. Xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx 

xxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxx.

7. American Electric Power (AEP) has two electricity generating stations in the 

immediate area of Letart, WV and Felman 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 

month. Felman negotiates its electricity rates with AEP pursuant to a West Virginia law 

that applies to the top five electricity users in the State. Felman minimizes their 

electricity cost by being on an interruptible status with AEP where their electricity can 

be curtailed if conditions demand additional electricity supply to homeowners (summer, 

winter, etc.). Felman does not generate any of its own electric power.

8. The submerged arc furnaces at Felman utilize 3 carbon electrodes each to generate 
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the heat, from electricity, to melt the furnace charge materials. Carbon has to be added 

to the electrodes all the time as the electrodes are used up/consumed in the process. 

Felman gets carbon paste primarily from Elkem Carbon for needed additions to their 

electrodes.

9. At this time, Felman is 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 accompanied by a shutdown of 1-2 of the existing furnaces). This would be a 30 

million 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 Felman property. Process materials are largely imported, 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 into 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. Felman uses a 

mixing 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 3000 degrees 

Fahrenheit in temperature. Felman 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 making mineral wool (Armstrong Industries in Millwood, WV, for example, relies 

on Felman slag as raw material for its mineral wool production). The metal goes to a 

casting nest and a cooling bin before being stockpiled. The casting nest is 3 feet wide 
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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 

companies).

11. Felman 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 Company 

said that they water the plant roads down to control fugitive dust and have two street 

sweepers for getting dust off of the roads. Felman 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 

stormwater permit from WV and their permitted outfall goes to the Ohio river. The only 

water treatment done is sedimentation and Felman does not generate any 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 

compartment’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 representatives 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 

Company representatives for their cooperation and to provide the logistics on them 

getting the inspection report and photographs. A discussion was held on the information 
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to be sent to EPA which basically included all the information that was requested for 

review in EPA’s original email to Felman. The Company was told of the fugitive 

emissions being seen coming from the Melt Shop Building at 1:45 PM which the 

Company representatives saw themselves . Everyone was very helpful. EPA left the 

facility around 4:00 PM.

Photo Log

Felman Productions, LeTart, WV

Photos taken by Jerry Curtin of EPA

On 3/13/2012 beginning around 1:30 PM

Photo No. Camera 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 materials-ores are dark, quartzite is

light.

6 0717 Fugitive emissions coming from the side of 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 16
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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-Doghouses

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 Projects

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. Compliance Certifications 2009-2011
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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