From: John Rego <jrego@jonesday.com>

Sent: Wednesday, May 08, 2013 11:01 AM

To: Chin, Conrad

Cc: Boyd, Rochelle; Chin, Conrad; Jeff.McKinney@erametgroup.com; john.hughes@erametgroup.com; 

nelson.brad@ecrweb.com; Trine, Rae

Subject: Re: Casting production rate

Conrad: 

Your understanding of the relationship between casting at the furnaces and casting at MOR is basically 

correct. MOR is only used to convert high carbon ferromanganese to low carbon and medium carbon 

ferromanganese, and is not used in the production of silicomanganese. 

However, as demonstrated by the recent switch of product between Furnaces 1 and 12, EMI needs the 

operational flexibility to produce any product on either furnace as necessary to respond to market 

demands. This could extend to production of silicomanganese or high carbon ferromanganese on both 

furnaces at the same time. Since this is a market-driven decision, EMI cannot predict what the future 

usage patterns will be. Accordingly, to avoid a challenge from EPA that EMI was underestimating 

production rates to arrive at understated fugitive emissions estimates, the July 2012 submittal included 

"worst case" casting rates for MOR, Furnace 1 and Furnace 12 -- essentially representing a scenario in 

which each furnace is simultaneously producing BOTH silicomanganese (and casting 100% at the 

furnace) and high carbon ferromanganese (and casting 100% at MOR) -- even though this is physically 

impossible and thus results in a double-counting of casting emissions. 

EMI would certainly support a more realistic assumption for purposes of estimating fugitive emissions, 

so long as it does not come at the price of limiting EMI's operational flexibility. 

Please let me know if you would like to discuss this issue further. 

John 

John Rego • Environmental, Health & Safety

901 LAKESIDE AVENUE • CLEVELAND, OHIO 44114 

DIRECT 216.586.7542 • FAX 216.579.0212 • JREGO@JONESDAY.COM

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From: "Chin, Conrad" <Chin.Conrad@epa.gov> 

To: "john.hughes@erametgroup.com" <john.hughes@erametgroup.com>, 

"Jeff.McKinney@erametgroup.com" <Jeff.McKinney@erametgroup.com>, "jrego@JonesDay.com" 

<jrego@JonesDay.com> 
Cc: "Boyd, Rochelle" <Boyd.Rochelle@epa.gov>, "nelson.brad@ecrweb.com" 

nelson.brad@ecrweb.com>, "Chin, Conrad" <Chin.Conrad@epa.gov>, "Trine, Rae" <trine.rae@epa.gov> 

Date: 05/06/2013 01:52 PM 

Subject: Casting production rate

Gentlemen: 

 

In your July 2012 baseline emissions submittal, you had provided casting production rate as 13 Tons/hr, 

12.5 Tons/hr and 25.5 Tons/hr for Furnace 1, Furnace 12, and MOR casting respectively. 

 

Please note that our definition of casting is provided in the November 2011 proposal, and does not 

include emissions from the tapping station. We have the following questions: 

 

1) MOR casting is only for FeMn production (i.e. you do not do MOR casting on SiMn production). Is 

that correct? 

2) When you do MOR cast, there is no casting at the casting station for the corresponding furnace 

that produced FeMn. Is that correct? 

3) For example, if Furnace 1 is producing SiMn, and Furnace 12 is producing FeMn, then there will be 

no casting at the Furnace 12 casting station, since the product will be transferred directly to MOR and 

later MOR casting. Is that correct? 

4) If the answers to the above three questions are yes. We are wondering why the MOR production 

rate is the sum of the casting rate at Furnaces 1 and 12? Have you overestimated the casting rate of 

MOR? 

 

Your clarification will be greatly appreciated. 

 

Conrad Chin 

US EPA