MEMORANDUM

DATE: November 9

, 2012

TO: Conrad Chin

, EPA OAQPS/SPPD/ MMG

FROM: Bradley Nelson, EC/R, Inc.

SUBJECT: Summary of the November 9

, 20 1 2

, 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
J ohn 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 201 2. 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

exten sion 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 f

airly accurate estimate based on past history.

 The industry believes that there are no fugitive emissions emitted from the furnace s and that they should not be included in the emission inventory. The EPA responded that they
would have a chance to observ e the furnace s 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 unnec essary 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 seas onal 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 co n geners with no toxic equivalency factor (TE F ). They believe these non

- TE F 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 co n geners from the reporting
list for both dioxin/furans and PCB.

 The industry was concerned with the 2 012 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 re presentatives from Eramet Marietta stated that they read the “ future plans ” question in the proposed ICR as a request for information regarding Eramet Marietta ’s
inten tions 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 AGEN DA11/5/12

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 Aft er 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 Assum ptions 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