From: Laura K. McAfee <LMcAfee@bdlaw.com>

Sent: Wednesday, August 22, 2012 5:41 PM

To: Conrad Chin

Cc: Chuck French; Darcie Smith; Beth Friedman; James Hagedorn; Jarrett, James F; Robertson, James;

Jonathan Averback; jskonrady@fpiwv.com; nelson.brad@ecrweb.com; Chakrabarty, Renu M; Richard

Lunn; thillier@policynavigation.com; r.powell@optimaacq.com

Subject: RE: Summary of Beveridge abd Diamond email dated 8/16/2012

Conrad

--

Following up on our call yesterday, we agreed to attempt to give you our best estimate of a [Mn+] figure

by COB today, and to set forth our justification for changing the figure from the 23% we previously

provided. As we discussed, we have not yet seen reliable, consistent [Mn+] results from any of the

testing that has been done in the past; we believe and hope that the stack tests that have recently been

completed will provide more reliable data on this issue.

Nevertheless, given your need for a number today, Felman and LAN have be en working since our call

ended to evaluate the prior data and sampling methodologies. Their efforts to date are not definitive

given the short time involved, but they suspect that the baghouse dust samples (which are showing

higher [Mn+]) are more acc urate. Accordingly, while Felman continues to prefer to wait for the more

recent test data, at this time we do not think we have a reason to change the figure we previously gave

you.

I will be off

- line tomorrow until approximately 5:30 PM but then ava ilable again on Friday. Thanks.

Laura

----- Original Message

----- From: Conrad Chin [mailto:Chin.Conrad@epamail.epa.gov]

Sent: Tue 8/21/2012 11:53 AM

To: Laura K. McAfee

Cc: Chuck French; Darcie Smith; Beth Friedman; James Hagedorn; Jarrett, James F; Robertson, James;

Jonathan Averback; jskonrady@fpiwv.com; nelson.brad@ecrweb.com; Chakrabarty, Renu M; Richard

Lunn; thillier@policynavigation.com; Conrad Chin

Subject: Sum mary of Beveridge abd Diamond email dated 8/16/2012

Laura

I apologize for bombarding you with another email. Below is an attempt to summarize the email you

sent dated 8/16. I assume we will discuss all these this afternoon.1. The use of one ICR test using Furnace #2 is incomplete and not representative of the facility

(Felman)'s performance (proposal comment).

2. Felman questioned the 2010 ICR test data

- the use of 3% Mn concentration from the July 2010 stack test on furn ace #2 is inappropriate and

invalid. (Email from Amy Lincoln dated 8/3 said EPA should use 23% for furnace operations and 53% for

crushing operations.

- the measured air flow rates differed by almost a factor or two for the July 2010 test.

- the emissions measured during the 2010 tests were more than a factor of two higher than the

results of the May 2009 tests on the same furnace. The 2011 tests had an emission rate of 0.11 lb/hr.

3. The concerns apply to other test data (on furnaces #5 and #7) as well. Furnace 5 estimates range

from 0.14 to 3.6 lb/hr. Furnace 7 estimates range from 0.12 to 5.59 lb/hr. Felman is concerned about

the high variability.

4. EPA proposed to exc lude one high reading (which was October 2007 tests on Furnace #7). Felman

disagrees strongly with this approach. Felman does not believe it is appropriate to cherry

- pick the data

(even if it fails the standard).

Test data : run #1 = 79 lb/hr

run #2

- 307 lb/hr

run #3

- 17 lb/hr

avg = 134 lb/hr

limit = 27.2 lb/hr (failed the emission limit)

5. Felman was so concerned about the reliability of the ICR data that it offered to perform these stack

tests, for the purpose of providing reliable data that would assist EPA in developing a sound rule. (Is

Felman saying that EPA should ONLY use the July/August 2012 data for rule development?)

Conrad K. Chin

Mail Co de D243

- 02

Metals and Minerals Group

Sector Policies and Programs Division

Office of Air Quality Planning and Standards

U.S. Environmental Protection Agency

919

- 541

- 1512 (voice)

919

- 541

- 3207 (fax)