# E C 

# / R Incorporated Providing Environmental Technical Support Since 1989

1 MEMORANDUM

DATE: February 28, 2013

TO: Conrad Chin

, EPA OAQPS/SPPD/MMG

FROM: Bradley Nelson, EC/R, Inc.

SUBJECT: Summary of the February 27, 2013 Teleconference with Eramet Marietta and the

U.S. Environmental Protection Agency

I. INTRODUCTION

The primary purpose of this call with Eramet Marietta was to discuss a potential opacity study at the facility and other possible fugitive testing related issues. This meeting summary will be available in the docket for this rulemaking (Docket ID No. EPA

– HQ

– OAR

– 2010

– 0895).

II. ATTENDEES

The following is a list of participants in the teleconference.

U.S. Environmental Protection Agency Conrad Chin Chuck French Steve Fruh Colin Boswell Steffan Johnson
Jason Dewees

Eramet Marietta Jeff McKinney, Eramet Marietta John Hughes, Eramet Marietta Paul Castle, Eramet Marietta Jason Canterbury, Eramet Marietta John Rego, Jones Day Troy Hillier, Policy Navigation Group

EC/R Incorporated Bradley Nelson2

III. SUMMARY OF DISCUSSION

The group discussed issues related to fugitive emissions from the ferroalloys production process at Eramet Marietta. The EPA forwarded a copy of the proposal manganese (Mn) emission estimates using the mass balance approach and the latest Mn emission esti mates using the emission factor approach and is provided in Attachment 1. The following is a brief summary of the major points that were discussed during the call.

Fugitive Emission Estimates

 In the case of cascading tapping, Eramet only considers the removal of product from the
furnace to the first ladle as tapping and the flow of product to the other ladles are considered as casting. The EPA has clarified the definition of tapping in the November 2010 proposal for Ferroalloys Production.

Fugitive Emission Testing

 Eramet Marietta indicated that they could design a study that show opacity, ambient
tempera ture, and weather conditions, as well as indicating which processes were operating at the time of the VE measurement. The study would include VE measurement from the different buildings as well as looking at different segments of the roof line over

a 3

- 4 week period.

 Eramet Marietta stated they would provide a spreadsheet and summary of the proposed opacity testing.

Felman Fugitive Emission Testing

The representatives from Eramet Marietta asked to be included in the Felman Production fugitive emission testing discussions as they pertain to Eramet Marietta.

Other Manganese Modeling Studies

 Eramet Marietta asked if EPA had reviewed the manganese study performed at Marietta College.

.

 The industry noted that other studies were done using portable analyzers and therefore

, in their view, the concentration cannot be pinpointed to a particular location. The study at Marietta College was done at specific locations.3

Eramet Marietta Information Collection Request Test Plan

 Eramet Marietta stated that they planned to perform the Information Collection Request testing the week of March 4, 2013.

 The industry stated that they planned to do all of the requested testing with the exception of the Method 30B testing on the Furnace 1 tapping baghouse. They believe that all of the mercury has volatized in the furnace and do not expect to see any mercury emissions from the tapping source.

 The EPA stated that they have not received a test plan as required in the Information
Collection r equest. They stated that Eramet could provide a table summary of the sources and test methods in lieu of a formal test plan. Eramet Marietta agreed to send the EPA a test plan summary.4 Attachment 1

Summary of Estimated Manganese Emissions for Eramet Marietta by Source5