MEMORANDUM 

DATE: March 12, 2014

TO: Phil Mulrine, EPA OAQPS/SPPD

FROM: Chuck French, EPA OAQPS/SPPD

SUBJECT: Summary of the March 5, 2014 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 was published in the 

Federal Register on November 23, 2011 (76 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 

John Willoughby, Eramet Marietta

Felman Production

John Konrady, Felman Production

Robert Powell

Policy Navigation Group

Troy Hillier

Jonathan Gledhill
III. 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 brief 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 emissions (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 electrode burndowns), and 

that they would like to have follow-up discussions with appropriate EPA technical staff

to discuss further. EPA agreed to have such follow-up discussions.

 Regarding mercury emissions, the industry representatives expressed significant 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, especially 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 analyses. 

 EPA and the industry representatives agreed to schedule 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.