From: "Amy M. Lincoln" <ALincoln@bdlaw.com>

To: Con rad Chin/RTP/USEPA/US@EPA

Cc: Chuck French/RTP/USEPA/US@EPA, Darcie Smith/RTP/USEPA/US@EPA, "Beth Friedman" <friedman.beth@ecrweb.com>, Jonathan Averback/DC/USEPA/US@EPA, <jskonrady@fpiwv.com>, "Laura K. McAfee" <LMcAfee@bdlaw.com>, "Richard Lunn" <RLun n@fpiwv.com>, <thillier@policynavigation.com>, <nelson.brad@ecrweb.com>

Date: 08/10/2012 04:28 PM Subject: RE: Felman Fugitive Emissions Control and Test Protocols

Conrad,

Let me respond to your question on slag raking first. For raking (aka skimming) we employed the same method of calculation that EMI used in its July 2 submittal and that we discussed on July 16. That is, we
used an emission factor that is inten ded to represent the full casting process, of which slag raking is a key part. So the slag raking emissions are indeed within our emissions estimate; they are part of the "casting" emissions, just as they are in EMI's table.

Second, on the revised sp readsheet you provided, you asked if we agree with your recalculations that
show a baseline emission level of about 22.5 tons Mn. We do not agree for the reasons I outlined on the phone on July 31. In short, the "furnace stack" and "furnace fugitive" e missions in your chart are all calculated using ICR test data; as we discussed, Felman has serious doubts about the reliability of those data. In fact, these concerns are the primary reason Felman is performing the detailed stack testing going on right now

- that is, to get reliable and representative stack test data. What we provided to you last week were those fugitive emissions sources for which we do have some reliable data or reasonable
emission factors. Until we receive the data from the stack tests, we cannot provide a reliable estimate of our furnace stack emissions (or what you have listed as "furnace fugitives," which are simply back calculated from the ICR data).

I must note that Felman was very concerned to still see the old ICR dat a in your emissions calculations.
We have been very upfront with the Agency about the fact that, due to errors on the part of the test contractor, the ICR data do not accurately reflect the site's emissions. As you know, Felman has made

-- and continu e to makes

-- significant efforts, at its own expense, to obtain more reliable data. We have worked with you every step of the way to ensure that this next round of stack testing will generate reliable data to assist you in developing a supportable, re asonable rule. Hence our surprise and disappointment to hear that the Agency is apparently proceeding based on the inaccurate ICR data, rather than waiting just a few more weeks to obtain the stack test data we have all been working
toward for months. While we understand that EPA is under time pressures to complete this rule, we
also have been reassured that an extension of several months is imminent

-- so, again, we hope that you will wait to compile your final emissions data until the stack test dat a are available.

Thank you,Amy

Amy M. Lincoln Principal Beveridge & Diamond, P.C. 456 Montgomery Street Suite 1800 San Francisco, CA 94104 T (415) 262

- 4029 ~ F (415) 262

- 4040 ALincoln@bdlaw.com

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From: Conr ad Chin [mailto:Chin.Conrad@epamail.epa.gov] Sent: Thursday, August 09, 2012 8:38 AM To: Conrad Chin; Amy M. Lincoln Cc: Chuck French; Darcie Smith; Beth Friedman; Jonathan Averback; jskonrady@fpiwv.com; Laura K. McAfee; Richard Lunn; thillier@policyn avigation.com; nelson.brad@ecrweb.com Subject: RE: Felman Fugitive Emissions Control and Test Protocols Good morning Amy

I have another question on your recent submittal of baseline emissions. It seems the process of slag raking creates significant fugitive emissions, as observed by our Region 3 inspector, Mr. James Hagedorn. Furthermore, Felman is proposing to install the secondary exhaust system to capture fugitive emissions from this process.

How come the fugitive e mission from this process was not estimated in your submittal?Conrad K. Chin

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From: Conrad Chin/RTP/USEPA/US To: "Amy M. Lincoln" <ALincoln@bdlaw.co m> Cc: Chuck French/RTP/USEPA/US@EPA, Darcie Smith/RTP/USEPA/US@EPA, "Beth Friedman" <friedman.beth@ecrweb.com>, Jonathan Averback/DC/USEPA/US@EPA, jskonrady@fpiwv.com, "Laura K. McAfee" <LMcAfee@bdlaw.com>, "Richard Lunn" <RLunn@fpiwv.com>, thillier@po licynavigation.com, chin.conrad@epa.gov, nelson.brad@ecrweb.com Date: 08/07/2012 03:12 PM Subject: RE: Felman Fugitive Emissions Control and Test Protocols

Good afternoon Amy

Based on information you provided, I have compiled the draft baseline manganese emissions (in tons

per year) at Felman. As I mentioned in my last email, we are reviewing the methodology you used in deriving the emission factors.

Since you did not pro vide the stack emissions (for furnaces and crushers), we used the 2010 ICR test data. You also did not provide the stack emissions under the after

- controlled scenario, we assume there is no change.

Please review the attached file. and let me know if y ou agree/disagree, or have any questions. If we left out any manganese emission sources, please let me know as well.

Thanks.

Conrad K. Chin
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Meta ls and Minerals Group Sector Policies and Programs Division Office of Air Quality Planning and Standards U.S. Environmental Protection Agency919

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From: "Amy M. Lincoln" <ALincoln@bdlaw.com> To: Conrad Chin/RTP/USEPA/US@EPA Cc: Chuck French/RTP/USEPA/US@EPA, Darcie Smith/RTP/USEPA/US@EPA, "Beth Friedman" <friedman.beth@ecrweb.com>, Jonathan Averback/DC/USEPA/US@EPA, "Laura K. McAfee" <LMcAfee@bdla w.com>, <jskonrady@fpiwv.com>,
"Richard Lunn" <RLunn@fpiwv.com>, <thillier@policynavigation.com> Date: 08/06/2012 12:58 PM Subject: RE: Felman Fugitive Emissions Control and Test Protocols

Conrad,

You’re correct on the crushing and screeni ng system calculations: there was an error in our Excel spreadsheet.

Thanks for alerting us to it. Here is a corrected version.

Amy M. Lincoln Principal Beveridge & Diamond, P.C. 456 Montgomery Street Suite 1800 San Francisco, CA 94104 T (415) 262

- 4 029 ~ F (415) 262

- 4040 ALincoln@bdlaw.com

CONFIDENTIALITY STATEMENT: This electronic message contains information from the law firm of Beveridge & Diamond, P.C. and may be confidential or privileged. The information is intended solely for the use of the individual(s) or entity(ies) named above. If you are not the intended recipient, be aware that any disclosure, copying, distribution, or use of the contents of t his message is prohibited. If you
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IRS CIRCULAR 230 DISCLOSURE: To the extent that tax advice is contain ed in this correspondence or any
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or recommendin g to another party the tax advice contained herein.

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From: Conrad Chin [mailto:Chin.Conrad@epamail.epa.gov] Sent: Monday, August 06, 2012 6:59 AM To: Amy M. Lincoln Cc: Chuck French; Darcie Smith; Beth Friedman; Jonathan Averback; Laura K. McAfee; JKonrady; Conrad
Chin Subject: RE: Felman Fugitive Emissions Control and Test Protocols

Good morning Amy

This is to acknowledge that I received your submittal of the baseline and after

- control manganese emissions. Thank you.

While you are correct that it would be nice to have more manganese test data from your just

- concluded July tests for the baseline manganese emission evaluation, our current schedule may not have this luxury.

W e are going to discuss with you shortly if we agree or disagree with your approach in using the
emission factors for estimating fugitive emissions for tapping and casting operations.

We noticed a possible mathematical error in your estimation of crushing fugitives. For example, the PM fugitives for system #1 were estimated to be 6.25 tpy total. If the Mn % is 53%, then the Mn emissions should be 3.3 tpy instead of 1.99 tpy. The same for system #2, Mn emissions should be 2.3 tpy instead of 1.36 tpy.

Please advise and thanks.

Conrad K. Chin
Mail Code D243

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U.S. Envi ronmental Protection Agency
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From: "Amy M. Lincoln" <ALincoln@bdlaw.com>To: Conrad Chin/RTP/USEPA/US@EPA

Cc: Chuck French/RTP/USEPA/US@EPA, "Beth Friedm an" <friedman.beth@ecrweb.com>, Jonathan Averback/DC/USEPA/US@EPA, "JKonrady" <RLunn@fpiwv.comr.powell>, Darcie Smith/RTP/USEPA/US@EPA, "Laura K. McAfee" <LMcAfee@bdlaw.com> Date: 08/03/2012 02:24 PM Subject: RE: Felman Fugitive Emissions Control and Te st Protocols

Conrad,

Attached are current estimates of Felman’s baseline PM and Manganese emissions for crushing/sizing, casting, and tapping fugitive emissions. Also in the attached charts are our current estimates of future
emissions after installation of the fugitive emissions controls described in the Chu & Gassman report you received from me on July 10. As you know, we’re currentl y in the process of performing stack testing at the site, and we need to await the results of that stack testing before estimating our baseline stack emissions and, therefore, the total facility emissions.

As you’ll see in the attached, we’ve estimate d emissions using the Metallic Mineral Processing and Basic Oxygen Furnace emissions factors that were discussed in our July 16 meeting at RTP. These factors appear to generate far more realistic estimates of PM emissions than the mass balance approach E PA used in the proposed rule. Recall that during our July 16 meeting, EPA suggested that the Crushed Stone Processing factors may be more appropriate to use for our operations. We reviewed that Table of emission factors (AP

- 42 Section 11.19.2) and agree that some of those factors may, indeed, be better estimates but there are other key processes (e.g., primary crushing) for which there are no emission factors provided in that Table. We’re open to discussing with your team how best to combine the
Metall ic Mineral and Crushed Stone processing factors to come up with a reasonable estimate for ferroalloy crushing.

You’ll note that the %Mn we’ve used here differs from what EPA used in the proposed rule. The ICR stack testing indicated a %Mn of 3% at Fe lman. While the current stack testing may shed some light on this, we are confident that the 3% number underestimates the manganese in our dust. In the attached estimate, we have used a range of 23

- 53% Mn (depending on where the product is in the process

– furnace versus crushing). These numbers are derived from baghouse dust analyses, which we believe is the most representative data we have at this point. Again, the current stack testing will be helpful in estimating these numbers, but, for now, we bel ieve the 23

- 53% range is a better number to rely on than the 3% from the ICR testing.

Let me know if you have any questions. As I mentioned on the phone earlier this week, I am leaving my practice at B&D to join the in

- house legal team at Chevron later this month. My colleague, Laura McAfee, has taken over for me on the Felman team. She is fully integrated into the team at this point and will be taking over the lead role upon my departure next Friday , August 10th. I will send all of you her contact information under separate cover. In the meantime, I’ve copied her on this email; please copy her on any emails you send to me and think of her as the primary contact for Felman goingforward. I’ve enjoye d working with you all, and, since I will continue to focus on Air work in my new

position at Chevron, I look forward to our paths crossing again soon.

Thanks,

Amy

Amy M. Lincoln Principal Beveridge & Diamond, P.C. 456 Montgomery Street Suite 1 800 San Francisco, CA 94104 T (415) 262

- 4029 ~ F (415) 262

- 4040 ALincoln@bdlaw.com

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IRS CIRCULAR 230 DISCLOSURE: To the extent that tax advice is contained in this correspondence or any
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From: Conrad Chin [mailto:Chin.Conrad@epamail.epa.gov] Sent: Wednesday, July 25, 2012 7:48 AM To: Amy M. Lincoln Cc: Chuck French; Beth Friedman; Jonathan Averback; JKonrady; Darcie Smith Subject: RE: Felman Fugitive Emissions Control and Test Protocols

Good morning Amy

As you know, Eramet provided us their own estimation of baseline emissions recently. I think Felman is
in the process of doing the same. My understanding is this estimation would be completed no later than
the end of July. We are looking forward to receive this information from you soon.Thanks and best regards,

Conrad K. Chin
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From: "Amy M. Lincoln" <ALincoln@bdlaw.com> To: Conrad Chin/RTP/USEPA/US@EPA Cc: Chuck French/RTP/USEPA/US@EPA, "JKonrady" <RLunn@fpiwv.comr.powell>, "Beth Friedman" <friedman.beth@ecrweb.com>, Jonathan Averback/DC/USEPA/US@EPA Date: 07/13/2012 07:04 PM Subject: RE: Felman Fugitive Emissions Control and Test Protocols

Conrad,

We don’t have a schedule breakdown for the July testing, but, as I noted in my earlier email, our testing

contractor will be on the call on Monday to talk about the testing in more detail. We’ve asked him to put
that schedule together and hope to be able to get that to you next week.

On your questions 2 and 3 below, we’ve forwarded those to Jack Wang and he’ll be prepared to explain
the basis for his estimates on Monday. On question 1, we are currently evaluating EPA emissions estimates. As you know, we have serious concerns about the reliability of Felman’s ICR stack testing data, and that was the primary basis for EPA’s estimates of stack emissions in the rulemaking. We are hoping the July and January testing will give us more confidence in those numbers. We are also working on a recalculation of the fugitive emissions estimates, both baseline and post

- control. We’ve asked our

outs ide contractor to complete that analysis as soon as possible, and no later than the end of this
month.

Thanks for your prompt review of our materials. Look forward to seeing you on Monday afternoon.

AmyAmy M. Lincoln

Principal Beveridge & Diamond, P.C. 456 Montgomery Street Suite 1800 San Francisco, CA 94104 T (415) 262

- 4029 ~ F (415) 262

- 4040 ALincoln@bdlaw.com

CONFIDENTIALITY STATEMENT: This electronic message contains information from the law firm of Beveridge & Diamond , P.C. and may be confidential or privileged. The information is intended solely for the use of the individual(s) or entity(ies) named above. If you are not the intended recipient, be aware that any disclosure, copying, distribution, or use of the conte nts of this message is prohibited. If you
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IRS CIRCULAR 230 DISCLOSURE: To the extent that tax advice is contained in this correspondence or any
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Please consider the environment before printing this e

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From: Conrad Chin [mailto:Chin.Conrad@epamail.epa.gov] Sent: Thursday, July 12, 2012 12:36 PM To: Amy M. Lincoln
Cc: Chuck French; JKonrady; Beth Friedman; Jonathan Averback Subject: RE: Felman Fugitive Emissions Control and Test Protocols Hi Amy

Do you have a breakdown of schedule, such as which baghouses and pollutants will be tested starting July 23 on a daily basis ?

We are still reviewing your Tuesday submittal, and I don't think we are ready to ask any meaningful technical questions to the Chu and Gassman representative (Mr. Jack Wang) by tomorrow. Below are just some preliminary questions from me:

1. Felman did not provide its own version of baseline emissions (as Eramet did). Does that mean Felman is in agreement with our estimates? If Felman has its own version of emission estimates, we would like

to review it. We would also like to see the your revised emissions after the proposed conceptual improvement are in place.2. Felman is proposing a total enclosure system for tapping capture. I am personally very positive on this

concept. How do you support the 95% capture estimated? Can you also p rovide a front view of the conceptual design?

3. Will the new casting shields be extending to cover the "runners" ? How do you support the 90%

c apture estimated? Can you provide a front view of the conceptual design?

Conrad K. Chin
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