Meeting Minutes Memorandum

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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 was 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 Production, Inc. Rich Lunn, Shawn McCutchan

Beveridge & Diamond: 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 CO2 correction to emissions concentration. Mr. 

McKinney repeated written comments regarding industry concerns with the proposed 

stack emissions format applied to control devices with large amounts of excess air that 

result in a CO2-corrected concentration would be much higher than the proposed 

emission standard. He also raised a concern that the stack test data reported to EPA may 

not actually report CO2 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, PAH, and HCl) is inadequate to set MACT standards that could be 

achieved over the full range of seasonal and raw material variations. The plants suggested

that they would conduct stack emission testing over the 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 written 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 emissions from crushing, 

rake out, etc.

Fenceline emissions monitoring. Mr. McKinney said that EMI has PM10 fenceline data 

that demonstrate that they could not meet an ambient fenceline concentration of 0.1 

μg/dscm due to presence of existing background concentrations 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 weather 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 subpart AA— Standards 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 operations.

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 emissions are being 

controlled.