MEMORANDUM

DATE: March 12

, 201 4

TO: Phil Mulrine

, EPA OAQPS/SPPD

FROM: Chuck French, EPA OAQPS/SPPD

SUBJECT: Summary of the March 5

, 201 4 Meeting with the Ferroalloys Production Industry

Representatives and the U.S. Environmental Protection Agency

I. INTRODUCTION

The purpose of the meeting was to discuss the upcoming supplemental proposal especially the potential proposed control requirements for HAP metals such as manganese and mercury

. This meeting summary will be available in the docket for this rulemaking (Docket ID No. EPA

– HQ

– OAR

– 2010

– 0895 ). The initial proposed rule for ferroalloys production wa s published in the Federal Register on November 23, 20 1 1 (7 6 FR 72508 ).

II. ATTENDEES

The following is a list of participants in the meeting.

U.S. Environmental Protection Agency Chuck French Steve Fruh Peter Tsirigotis Janet McCabe
Tom Powers

Eramet Marietta
J ohn Willoughby , Eramet Marietta

Felman Production John Konrady

, Felman Production Robert Powell

Policy Navigation Group Troy Hillier Jonathan GledhillIII. SUMMARY OF DISCUSSION

The purpose of the meeting was to discuss possible control approaches to reduce process fugitive emissions, monitoring options for the fugitive emissions (such as opacity standards) and possible options to address mercury emissions

, and the economic impacts of such options

. The following is a b rief summary of the major points that were discussed during the meeting

.

 The industry representatives explained that they are prepared to make significant improvements with the capture and control of process fugitive emissions to reduce HAP
metals emi s sio ns ( especially manganese ) based on enhanced local capture using combination of primary and/or secondary hooding.

 They said they believe monitoring such emissions through opacity standards is a reasonable approach , but that they still had potential concerns regarding the details of such opacity standards such as what opacity levels would be appropriate and feasible, how frequently readings would be required, and how to account for non

- routine, infrequent events (such as blowing tap, oxygen lancing and/or ele ctrode burndowns), and that they would like to have follow

- up discuss ions with appropriate EPA technical staff to discuss further. EPA agreed to have such follow

- up discussions.

 Regarding mercury emissions, the industry representatives expressed signific ant concerns regarding the potential economic impacts of mercury control using activated carbon injection especially given that these costs would be in addition to the costs that they expect to incur to control the process fugitive HAP emissions, especiall y manganese.

 The industry representatives recommended that we do additional analyses regarding the potential economic impacts of the mercury controls, and that such analyses should include consideration of the global market, imports/exports, market elasticity, effect on price and production, and other factors.

 EPA asked the companies to provide more data, especially economic data, which would help EPA conduct a more thorough economic impact analys e s.

 EPA and the industry representatives agreed to sc hedule a follow

- up meeting between EPA and industry technical experts, especially the economists, to discuss in detail what economic analyses could be done to better understand the potential economic impacts of the control options.