MEMORANDUM

DATE: March 3

, 201 4

TO: Phil Mulrine

, EPA OAQPS/SPPD/ MMG

FROM: Bradley Nelson, EC/R, Inc.

SUBJECT: Summary of the February 2 6

, 201 4 Meeting with the Ferroalloys Production

Industry and the U.S. Environmental Protection Agency

I. INTRODUCTION

The purpose of the teleconference was to discuss the opacity data provided by the facilities and the estimated impact of enhanced particulate capture on routine and non

- routine emissions during ferroalloys production

. This meeting summary will be available in the docket for this rulemaking (Docket ID No. EPA

– HQ

– OAR

– 2010

– 0895 ). The proposed rule for ferroalloys production wa s published in the Federal Re gister on November 23, 20 1 1 (7 6 FR 72508 ).

II. ATTENDEES

The following is a list of participants in the meeting.

U.S. Environmental Protection Agency Chuck French Phil Mulrine Colin Boswell Steffan Johnson

Eramet Marietta Jeff McKinney, Eramet Marietta
J ohn Rego

, Jones Day

Felman Production John Konrady, Felman Production Shawn McCutchen, Felman Production Laura McAfee, Beveridge and Diamond

Policy Navigation Group Troy Hillier

EC/R Incorporated Bradley NelsonIII. SUMMARY OF DISCUSSION

The purpose of the meeting was to discuss the opacity data provided by the facilities and the estimated impact of enhanced particulate capture on routine and non

- routine emissions from ferroalloy production. The following is a brief summary of the major points that were discussed during the meeting

.

NESHAP Opacity Standard

 Prior to the meeting, John Rego sent an email to EPA which provided input on potential opacity stands based on enhanced particulate captu re of ferroalloy operations, and a list
of parametric and operational monitoring parameters that could be used to show compliance with the enhanced particulate control

. A copy of the email and the list of potential monitoring parameters are provided in Att achment A.

 The industry noted that to comply with a low opacity limit during non

- routine conditions (e.g., furnace blow, blowing tap, oxygen lancing, and/or electrode burning) that the building may need to be redesigned and additional controls put into pl ace beyond the types of controls that are currently being considered

.

 The industry stated that opacity data provided to EPA was used to develop the suggested opacity limits provided in the email. The controlled opacity limits from the various events were based on engineering judgment and experience from the facilities. The industry noted that these non

- routine events produce a large volume of particulate
emiss ions which may not be captured by the enhanced controls currently being
considered and may exit to an area of no controls.

 The industry noted that the particulate stack testing has to be performed during normal operations and that the opacity testing shoul d also be required to be performed during normal operation.

 An industry representative stated that some of the capture systems are automated and that certain parameters such as fan amperes or damper position may change during normal operations and should be taken into account in the final rule

. They suggested a requirement that shows that th e automated system is operating.

Other Topics D i scussed

 The industry stated that they have a meeting with Janet McCabe to discuss the proposed
NESHAP.

 A representat ive from Felman stated that they were hoping to receive a ruling on the 10

- year special rate electricity request from the West Virginia’ s Public Service Commission
in mid

- March.ATTACHMENT A

Email from John Rego, Jones Day to Chuck French, EPA, Opacity Standards for Operations with Enhanced Particulate CaptureFrom: John Rego [ mailto:jrego@JonesDay.com ]

Sent: Wednesday, February 26, 2014 10:55 AM To: French, Chuck Cc: thillier@policynavigation.com ; lmcafee@bdlaw.com ; Jeff.McKinney@erametgroup.com ; Shawn R. McCutchan; carricoleman@yahoo.com Subject: Opacity Standards for Operations With Enhanced Particulate Capture

Chuck:

As a follow

- up to prior discussions and submissions regarding the estimated impact of enhanced particulate cap ture on routine and non

- routine emissions during ferroalloys production, Eramet Marietta Inc. has reviewed the issues discussed on February 12, 2014 and has asked me to provide the following input, which we would like to discuss on today's conference call.

Opacity Limits

Based upon the available data and the nature of the additional fugitive particulate controls under consideration, EMI believes that the following should be the minimum opacity standards considered by EPA:

 For "tap to tap" Method 9 test ing conducted during typical operations, an average opacity not exceeding 10% over the length of the test and not exceeding an average of 20% over any six

minute period.



 For tests that include one or more normal, but non

- routine, conditions (i.e., furnac e blow, blowing tap, oxygen lancing and/or electrode burndown), an average opacity not exceeding 15% over the length of the test and not exceeding an average of 30% over any six

- minute period.

(Note that EMI classifies furnace blows as Class A, Class B or Class C, depending upon their severity. Class C furnace blows, which are catastrophic events that could include the full or partial disabling of emissions abatements systems, would exceed even the "non

- routine" standard and should, therefore, either be co nsidered malfunctions or addressed by a separate emissions standard.)

These standards will result in demonstrably reduced visual emissions compared to the existing NESHAP, which exempts not just the non

- routine conditions described above, but also routin e conditions like casting, where allowable visual emissions are capable reaching and exceeding 70%. Reducing the maximum six

- minute average to 20%

- 30% represents a significant reduction compared to the current NESHAP.

In addition, EMI believes that it's critical to remember that residual risk standards almost always present more technical uncertainty than MACT standards, because the latter are (by definition) based upon existing, quantitatively

- demonstrated emissions controls in the subject industry, whi le residual risk standards are not technology

- based and therefore may, as in the case of ferroalloys, be based entirely on engineering judgments regarding hypothetical control systems. Moreover, MACT standards are based not simply on levels of control tha t "can" be achieved, but instead are based on levels of control that can be achieved at a very high statistical confidence level. This is not a challenge to the validity of standards that arise from a residual risk assessment, only a request that EPA ackn owledge the greater uncertainty inherent in the current process when selecting opacity standards for the revised NESHAP. Experience teaches that real world results almost never match engineering predictions, particularly in the early stages of implementat ion.

Moreover, the NESHAP process provides a mechanism for adjusting opacity standards in the future to ensure that they are appropriately stringent. Once implemented, the actual performance of the enhanced particulate controls envisioned in the residua l risk rule will provide actual data for a subsequent RTR

based assessment. Thus, if real world results exceed the initial standards, the RTR process will reducethose standards to codify what the presently hypothetical controls actually achieve.

Param etric Monitoring Requirements

You requested on February 12, 2014 that the companies' identify appropriate parametric monitoring criteria to supplement periodic Method 9 visual emission testing. Attached is a set of criteria that EMI believes would effec tively confirm the proper ongoing functioning of the enhance particulate controls under consideration. Please note that given the operational differences among EMI's operating furnaces and the MOR unit, some of the parameters would not be applicable to a particular source. For example, requirements for a tapping baghouse would apply to Furnace 1, but not to Furnace 12 or the MOR because the latter two units do not have such a baghouse.

Monitoring Frequency

EMI's current Title V operating permit includ es both mass emission and opacity standards, and ensures compliance via ongoing parmetric monitoring and recordkeeping, with annual stack tests and formal Method 9 visual emissions observations during periods of normal operating conditions. Moreover, the permit requires EMI to maintain compliance at all times and to respond affirmatively to any evidence of

non

- compliance, including self

- reporting of violations. EMI is not aware of any determination by Ohio EPA or U.S. EPA that the current approach has be en deficient for compliance and enforcement
purposes.

The suggestion on February 14 that weekly Method 9 observations of each source (a 5200% increase over the current permit requirements) is under consideration is not justified for compliance purposes and would be a unreasonably expensive expansion of EMI's monitoring requirements, particularly in light of the parallel parametric requirements that would be in place. EMI has three separate sources that would be subject to such a requirement and a "tap to tap" process time of about two hours. Thus, the Method 9 requirements alone would consume a full man

- day of each week, staff time that EMI does not currently have available among its certified smoke readers. The cost of procuring such assistance would cost EMI in excess of $48,000 per year in additional monitoring costs.

Since the particulate provisions of the proposed NESHAP will include the same types of standards imposed under the current NESHAP and will address the same manufacturing operations and pollutants, albeit with an expanded use of the particulate capture and control approaches currently used, there is no technical or legal basis for fundamental changes to the existing monitoring and recordkeeping requirements. An initial expansion of the formal Method 9 opacity testing frequency to quarterly in the first year, to provide a basis for refining the parametric monitoring requirements (if necessary), is the most that should even be considered.

EMI looks forward to discussing these issues with you further later today.

John A. Rego Partner, Environmental, Health & Safety JONES DAY®

- One Firm Worldwide SM 901 Lakeside Avenue Cleveland, Ohio 44114

- 1190 Office +1.216.586.7542

Fax +1.216.579.1212 jrego@jonesday.com

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### Parametric Monitoring/Operational Requirements (as applicable)

Operational

1. Maintenance of the pressure drop across the venturi scrubber or differential pressure across the baghouse, as applicable.

2. Operation of the tapping baghouse while furnace is tapping.

3. Maintenance of the pressure drop across the tapping baghouse while in operation.

4. Development and implementation of a written maintenance plan for each air pollution control device. The plan shall be kept on record and available for the Administrator’s inspection for the life of the air pollution control device or until such emissions unit is no longer subject to t he provisions of Subpart XXX. The procedures specified in the maintenance plan must include a preventative maintenance schedule that is consistent with good air pollution control practices for minimizing emissions.
5. Maintenance of the capture system fan mo tor amperes, flow rate, and/or damper positions within the ranges and/or positions, as appropriate, that were recorded during the initial performance test that demonstrated compliance.

Monitoring/Recordkeeping

1. Performance of daily checks, when the emissio ns unit is in operation and when the weather conditions allow, for any visible particulate emissions for the stacks and for any visible fugitive particulate emissions from the egress points (i.e., building windows, doors, roof monitors, etc.) serving the e missions unit. The presence or absence of any visible emissions shall be noted in an operations log, provided that a formal Method 9 observation by a certified smoke reader is not required.

2. Daily monitoring of the pressure drop across each baghouse cell, or across the baghouse if it is not possible to monitor each cell individually, to ensure the pressure drop is within the normal operating range identified in the maintenance plan.
3. Weekly confirmation that the baghouse dust is being removed from the baghou se hoppers through visual inspection.

4. Daily check of the compressed air supply for pulse

- jet baghouses.
5. Appropriate monitoring of cleaning cycles to ensure proper operation.

6. Monthly check of bag cleaning mechanisms for proper functioning through visual
ins pection or equivalent means.

7. Quarterly visual check of bag tension on reverse air and shaker

- type baghouses to ensure that the bags are not kinked or laying on their sides.
8. Quarterly confirmation of the physical integrity of the baghouses structure through visual inspection of the baghouse interior for air leaks.

9. Semiannual inspection of fans for wear, material buildup, and corrosion through visual inspection, vibration detectors, or equivalent means.10. Monthly inspections of the equipment that is important to the performance of the furnace

capture system to include an examination of the physical condition of the equipment, suitable for detecting holes in ductwork or hoods, flow constrictions in ductwork due to dents or accumulated dust, and operational statu s of flow rate controllers.

11. Check and record the control system fan motor amperes and capture system damper positions once per shift.