# E C 

# / R Incorporated Providing Environmental Technical Support Since 1989

1 MEMORANDUM

DATE: February 5

, 2013

TO: Conrad Chin

, EPA OAQPS/SPPD/ MMG

FROM: Bradley Nelson , EC/R, Inc.

SUBJECT: Summary of the February 4, 2013 Teleconference with Felman Production and

the U.S. Environmental Protection Agency

I. INTRODUCTION

The primary purpose of this call with Felman Production was to discuss the proposed fugitive particulate matter (PM) and manganese (Mn) testing at the Felman Production facility. This meeting summary will be available in the docket for this rulemaking (Do cket ID No. EPA

– HQ

– OAR

– 2010

– 0895 ).

II. ATTENDEES

The following is a list of participants in the teleconference.

U.S. Environmental Protection Agency Rochelle Boyd
Conrad Chin
Chuck French
Colin Boswell

Jason Dewees

Felman Production John Konrady, Felman Production Guy Van Doren, LAN Associates Derek Saballos, LAN Associates Joe Gross, LAN Associates Laura McAfee, Beveridge and Diamond Paul Chin, TEST Inc. Troy Hillier, Policy Navigation Group

EC/R Incorporated Bradley Nelson2

III. SUMMARY OF DISCUSSION

The group discussed issues related to the ferroalloys process fugitive emissions testing proposal for the Felman Production facility. The Felman group sent a list of talking points for the meeting and a proposed statistical validation of data which are provided in Attachment 1 and 2 respectively. The following is a brief summary of the major points that were discussed during

the call.

Fugitive Particulate Matter and Manganese Measurement

 LAN Associates provided two types of particulate anal yzers that could be used to measure fugitive PM emissions from the Felman Production ferroalloys production building: filter based particulate analyzers and light

- scattering particulate analyzers.

 EPA believes the filter based particulate analyzers provide the best approach for measuring fugitive PM and Mn. Analytical measurement of the particulate captured on the filter will provide data on the size and shape of the PM, as well the concentration of

Mn in the PM.

 Light

- scattering analyzers can provide time based particulate to show spikes in the concentration of PM, but cannot provide information on the size or shape of the PM or the concentration of Mn. The Felman group suggested collecting fugitive data using both types of analyzers, and using data from the filter based analyzer to correlate Mn emissions from the light scattering analyzer data.

Location of Particulate Analyzers

 EPA stated that the roof construction of the furnace building at Felman creates buffers of fugitive emissions. Because of this , EPA believes the location of the particulate analyzer is not as important as the location of the flow rate monitors and suggested that it should be located in the dog house on top of the roof.

Data Validation and Use

 The Felman group suggested that an arithmetic standard deviation and relative arithmetic mean be used to determine if the fugitive PM and Mn data is viable. LAN Associates provided a summary of this statistical method and shows how this method could be used to compare different sets of dat a.

 Another option is to compare the fugitive PM data with AP

- 42 emission factors. Additional process activity data will need to be collected to provide comparable comparisons.3

 The group agreed that multiple runs should be collected to account for variabil ity of the fugitive emissions from the ferroalloys production process.

 The group also agreed that collection of visible emissions data would also be useful during the collection of the fugitive emissions.

Schedule for Fugitive Emission Testing Plan

 LAN Associates plans to provide a draft fugitive emissions test plan to EPA on February
11, 2013. EPA plans to schedule a meeting on February 14, 2013 to discuss the proposed test plan.

 Felman proposes to do the fugitive emissions testing sometime in April 2013 after the March stack testing is completed. The results of the testing are expected to be available to EPA by May 2013.

 It is unknown whether EPA will observe the fugitive emissions testing.4 ATTACHMENT 1

LIST OF TALKING POINTS5

Talking Points

1) Data Inputs

a) Concentration of Dust leaving the Building

i) Particulate Analyzers

ii) Filter Based Particulate Analyzers

(1) High Volume Samplers

(2) Clogging

(3) Data

- Logging Capabilities

(4) Utilize filtered samples to analyze for manganese content

iii) Light

- Scattering Particulate A nalyzers

(1) Thermo Scientific

(2) 0

– 400 mg/m 3

(3) Passive/Active

(4) Active samplers pull air through the sampler

(5) Data

- Logging Capabilities

iv) Location Of Particulate Analyzers

v) Multiple Units (5 to 10), multiple designs (filter based, light

- scattering)

vi) Doghouses

vii) Suspension

viii) Elevated Platforms (need to reduce amount of disturbance to airflow)

b) Volumetric Flowrate of Air out of the Building (Flow out of doghouses)

i) Utilize velocities exiting doghouses and area of doghouses

ii) Hot

- Wire Anemometers

(1) Problems with Dusty Envir onments

(2) Point (Probe) Measurements

(3) Difficulty in very low velocity situations

(4) Not a good candidate

iii) Micromanometer

(1) Better in Dusty Environments6 (2) Equipped with 16

- point velocity matrix

iv) Quick Averages over square foot

(1) Data

- Logging Capabilities

(2) Ideal for low flow measurements

v) Vertical Propeller Anemometers

(1) Ideal for low flow measurements

(2) Data logging capabilities with external data logger

vi) Location Of Measurements

(1) Relatively close to doghouse openings

(2) Multiple units

2) Data validation and use

a) Statistical Validati on of Data

i) Arithmetic Standard Deviation (ASD)

ii) Provides degree of variance

iii) Convenient for comparing two sets of data

(1) Set A : 1000 +/

- 65

(2) Set B : 935 +/

- 40

(3) Overlap

iv) Relative Arithmetic Standard Deviation (RASD)

v) Ratio of the ASD to the mean expressed as a percentage

vi) Used to determine variability within one set of data

b) Utilizing Data

i) Fugitive emissions have not been quantified properly and need to be understood for

determining the facility’s baseline emissions

ii) Fug itive mass emission rate from testing represents all process fugitives from every

operation contained within the shop building

iii) Pointed emission rates from stack testing coupled with this fugitive emission rate

will determine the facilities’ baseline emissi ons

Path forward7 o Felman to submit proposed protocol

– 2/15

o EPA approval and/or follow

- up call

– 2/218 ATTACHMENT 2

S TATITICAL VALIDATION OF DATA