## Meeting Minutes Memorandum

1

TO: EPA Docket No. EPA

- HQ

- OAR

- 2010

- 0895

FROM: Beth Friedman, EC/R Incorporated

DATE: May 3 , 2012

SUBJECT: Meeting with Representatives of the Ferroalloys Production Industry on May 1,

2012

I. Introduction:

A meeting w as held on May 1, 2012 to discuss technical implementation issues including fugitive source control options related to the proposed Ferroalloys Production standards. This memo provides an overview of the issues discussed.

II. Participants :

Eramet Marietta Inc. : Jeff McKinney
Felman Producti on, Inc. Rich Lunn, Shawn McCutchan Beveridge & D i amond : Amy Lincoln Jones Day : John Rego Policy Navigation Group : Troy Hillier
EPA/ OAQPS : Conrad Chin

, Chuck French EC/R Incorporated (Contractor for EPA) : Beth Friedman , Brad Nelson

III. Summary of Discussion:

The purpose of the call was to discuss technical issues related to implementing the proposed standards for Ferroalloys Production.

Format of stack emission limits: 2 percent CO 2 correction to emissions concentration

. Mr. McKinney repeated written commen ts regarding industry concerns with the proposed
stack emissions format applied to control devices with large amounts of excess air that
result in a CO 2 - corrected concentration would be much higher than the proposed
emission standard . He also raised a conc ern that the stack test data reported to EPA may not actually report CO 2 corrected data.

Format of stack emission limits: Prefer existing NESHAP format . Mr. McKinney and others stated that the format of the current NESHAP, which is expressed in lb/hr per

## Meeting Minutes Memorandum

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product at a specified furnace load (MW) matches better with a standards designed to
address chronic risk from metal HAP.

Additional data collection suggested for previously unregulated HAP . Mr. McCutchan expressed industry concern that the limited data set for unregulated HAP (mercury, formaldehyde, P AH , and HCl) is inadequate to set MACT standards that could be achieved over the full range of seasonal and raw material variation s . The plants suggest ed that they would conduct stack emission testing over t he next 18 months to assess the impact of variability in materials. They plan to conduct the first round of tests in early June to coincide with regularly scheduled compliance testing.

Process fugitives emissions capture . The plants reiterated their writ ten comments that total building ventilation with a negative pressure requirement is not economically feasible for either plant. Instead, they propose to undertake a system of significantly improved local capture to reduce these emissions , including emissi ons from crushing, rake out, etc.

Fenceline emissions monitoring . Mr. McKinney said that EMI has PM 10 fenceline data that demonstrate that they could not meet an ambient fenceline concentration of 0.1 μg/dscm due to presence of existing background concen trations and emissions from other

sources such as welding and another nearby facility (MIE) . He added that EMI was not
able to correlate emissions from EPA monitoring studies to plant processes. He stated
that ambient concentrations have more to do with we ather conditions, particularly inversions, in the river valley. When the wind is blowing away from the monitor, they
still show Mn emissions. Mr. McKinney added that any fenceline monitoring should only address respirable particles (2.5 microns or less).

Building opacity monitoring

. The group discussed the option of requiring a stringent building opacity limit, such as that for the EAF s ubpart AA

— S tandards of Performance for Steel Plants: Electric Arc Furnaces Constructed After October 21, 1974, and On or Before August 17, 1983, set at 6% opacity. Mr. McKinney said that meeting such a standard post tapping (which their permit defines as after the product leaves the tap hole)
is not feasible , even with installation of local hoods on the casting operation s

.

Mr. McKinney added that the opacity test method was designed for a stack and that there is no correlation between opacity and measured emissions. They believe that monitoring process parameters such as; fan amperage, pressure in the duct, face velocity, and pressure drop across the baghouse can provide assurance that emissi o ns are being
controlled.