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
ferr omanganese, 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 respon d 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, t o 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@e crweb.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 over estimated the casting rate of
MOR?

Your clarification will be greatly appreciated.

Conrad Chin

US EPA