MEMORANDUM 

DATE: November 9, 2012

TO: Conrad Chin, EPA OAQPS/SPPD/MMG

FROM: Bradley Nelson, EC/R, Inc.

SUBJECT: Summary of the November 9, 2012, Meeting with the Eramet Marietta, Felman 

Production and the U.S. Environmental Protection Agency

I. INTRODUCTION

Eramet Marietta and Felman Production requested this meeting with EPA to discuss the status of 

the Final Rule for the Ferroalloys Production NESHAP (40 CFR Part 63, subpart XXX). This 

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

OAR–2010–0895). 

II. ATTENDEES

The following is a list of participants in the meeting.

U.S. Environmental Protection Agency

Chuck French

Steve Fruh

Darcie Smith

Rochelle Boyd

Brian Shrager

Colin Boswell

Robin Segall (by phone)

Ray Merrill (11:30am)

Eramet Marietta 

Jeff McKinney, Eramet Marietta

Russell Kemp, Environ

John Rego, Jones Day

Felman Production

John Konrady, Felman Production

Shawn McCutchan, Felman Production

Katie Kulik, LAN Associates (by phone)

Laura McAfee, Beveridge and Diamond (by phone)
Policy Navigation Group

Troy Hiller

EC/R Incorporated

Bradley Nelson 

Jeff Harris

III. SUMMARY OF DISCUSSION

The group discussed the emission estimates, modeling inputs, and the emission control proposals 

sent by the facilities in July 2012. A copy of this agenda is provided in Attachment A of this 

meeting summary. The industry group did not have any specific comments on the agenda. The 

EPA requested that any discussions on Item 4 (regarding July 2012 emission test results) be 

delayed until Ray Merrill was able to attend the meeting. The following is a brief summary of 

the major points that were discussed during the meeting.

Final Rule Status

 The EPA stated that they were currently in negotiation with the litigants regarding an 

extension to the promulgation of the final rule. 

 The EPA stated that in addition to the building evacuation option presented in the 

proposed rule, they are also considering an enhanced local capture control option for the 

final rule.

Ferroalloys Emission Estimates

 The EPA stated that they have revised emission estimates to include the use of AP-42 

emission factors to estimate fugitive emissions from tapping, casting, and crushing and 

sizing. 

 The EPA is using the furnace outlet emission profile to estimate the manganese 

percentage for the tapping and casting fugitives. 

 For Eramet Marietta, the EPA assumed that the emissions from Furnace 1 include the 

production of ferromanganese (FeMn) for 12% of the year. Eramet Marietta agreed that 

this was a fairly accurate estimate based on past history. 

 The industry believes that there are no fugitive emissions emitted from the furnaces and 

that they should not be included in the emission inventory. The EPA responded that they 

would have a chance to observe the furnaces during the site visit next week and would 

make a determination after these observations.
Test Plan Discussion

 The EPA forwarded a draft copy of the emission test requirements to the facilities before 

the meeting and asked the group if they had any comments or questions. 

 The industry representatives asked for clarification and the rationale for testing for 

various HAP and non-HAP emissions. Eramet Marietta representatives pointed out that 

testing for manganese from storage piles was unnecessary because the piles were lump 

ores unlikely to have significant fugitive emissions. EPA agreed to remove from the 

information request testing of these piles. 

 The facilities offered to provide legacy test data from the crushing operations to show 

that HAP emissions from the process are not variable.

 The industry stated that previous tests of hydrochloric acid (HCl), dioxin/furan, 

polychlorinated biphenyls (PCB), and formaldehyde have shown non-detects and that 

they do not believe that these tests should be included in the proposed test plan. The EPA 

responded that in previous discussions with the industry, the facilities have noted that 

HCl emissions can be seasonal due to the anti-freezing chemicals that are sprayed by the 

vendors onto the feedstock. 

 The industry also noted that the dioxin/furan and PCB list included congeners with no

toxic equivalency factor (TEF). They believe these non-TEF congeners could be misused 

and overestimate the total dioxin/furan and PCB emissions from the facility. The EPA 

agreed with this assessment and will remove the non-TEF congeners from the reporting 

list for both dioxin/furans and PCB.

 The industry was concerned with the 2012 production data requested in the ICR. They 

do not feel there is enough time to get this data together before the requested January 15, 

2013 date for test data. The EPA responded that they could provide this data with the test 

results in March.

 The representatives from Eramet Marietta stated that they read the “future plans”

question in the proposed ICR as a request for information regarding Eramet Marietta’s

intentions to rebuild or replace Furnace 18 at their facility. Eramet Marietta stated there 

are no plans to rebuild or replace Furnace 18, even though the permit is still listed in their 

operating permit. The industry stated that because of the uncertainty of the Final Rule, 

they are unable to make any future plans for the facility. The EPA stated that they will 

remove this question from the test plan.
Test Procedures Discussion

 The EPA asked the industry to ensure that the labs perform an external curve calibration 

for the polycyclic aromatic hydrocarbons (PAH) lab analysis. In the July 2012 furnace 

testing at Eramet Marietta, EPA saw very high concentrations of PAH in the stack test 

results. The EPA noted that the lab had to perform multiple dilutions in order to quantify 

the concentrations for many of the compounds. 

 The EPA suggested that discussion of fenceline/ambient monitoring should be deferred 

until a later time. The industry representatives agreed, while noting that they believe that 

ambient monitoring is not useful because results may be strongly and randomly 

influenced by factors other than current facility operations. 
ATTACHMENT A

DRAFT MEETING AGENDA
11/5/12

DRAFT AGENDA 

Ferroalloys Production RTR 

Meeting with Eramet and Felman

In Room D201, at EPA Building, in RTP, NC

Date and Time: November 9, 2012, from 9:00 am - 1 pm (Eastern Time)

Teleconference Number: 919-541-4332

Topics:

1. Introductions.

2. Discussion of the July 2012 Submittal from Eramet

 Baseline Emissions Estimates

 Enhanced Source Control of Process Fugitive Emissions

 Revised Emissions Estimates After Enhanced Source Controls are in Place

 Residual Risk After Enhanced Fugitive Source Control is in Place

 Potential Ventilation and Work Practice Standards for Enhanced Fugitive Controls

 Proposed additional stack testing

 ACI performance testing 

3. Discussion of Recent Submittals from Felman

 Design Narrative for Fugitive Emissions Source Controls

 Cost data for the source controls 

4. Emissions test results from the July/August 2012 testing at Felman and Eramet

5. Draft Test Plan for Potential Emissions Testing for Multiple HAP in 2013

6. Inputs and Assumptions for Dispersion and Exposure Modeling 

 Emissions Estimates

 Release heights

 Other Source Parameters (longitude/latitude, source dimensions, etc...)

 Meteorological data

7. Other Issues, Discussion, Next Steps