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ENCLOSURE 1

INFORMATION COLLECTION REQUEST FOR

FERROALLOYS PRODUCTION

MANUFACTURING EMISSION POINTS

The Environmental Protection Agency’s (EPA) Office of Air and Radiation (OAR) is conducting

this information collection request to assist the EPA Administrator in developing emission

standards for Ferroalloys Production Manufacturing Emission Points under Clean Air Act (CAA)

section 112. The survey is being sent under the authority of Section 114 of the CAA.

BACKGROUND:

Please complete this information request for operations that comprise ferroalloys production at

each facility operated by your company and located within the United States. The ferroalloys

production source category includes any facility engaged in producing silicomanganese or

ferromanganese. Ferroalloys production includes, but is not limited to, the following unit

operations: ore unloading, ore storage, sintering, crushing, weigh-feeding, smelting, tapping,

casting, screening, metal oxygen refining, and ladle treatment or ladle raking.

CAA section 114(a) states that the Administrator may require any owner or operator subject to

any requirement of this Act to:

(A) Establish and maintain such records; (B) make such reports; (C) install, use, and maintain

such monitoring equipment, and use such audit procedures, or methods; (D) sample such

emissions (in accordance with such procedures or methods, at such locations, at such intervals,

during such periods, and in such manner as the Administrator shall prescribe); (E) keep records

on control equipment parameters, production variables or other indirect data when direct

monitoring of emissions is impractical; (F) submit compliance certifications in accordance with

section 114(a)(3); and (G) provide such other information as the Administrator may reasonably

require.

There are two main components to this CAA section 114 information collection request. The

first component of the information collection involves a short survey requesting information on

your existing and planned processes. The second component requires owners to conduct stack

testing. The testing requirements are mentioned in the cover letter of this packet (CAA section

114 letter) and described in more detail in Enclosure 2.
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DIRECTIONS:

All recipients must complete and return Enclosure 1 by March 30, 2013.

 Please answer all questions unless not applicable to your facility or operations, in which

case note that the question is not applicable. All information should be for the 2012

reporting year (unless otherwise noted).

 Please identify clearly any response(s) that you consider to be confidential business

information (CBI). Any responses not so identified will be included in a publicly

available database. Refer to Enclosures 3, 4, 5, and 6 for more information on the

treatment of CBI and a list of information you may be asked to submit later to

substantiate a claim of confidentiality. Please do not label an entire response

“confidential” if only certain portions consist of trade secret information. If you

wish, you may submit a confidential and a non-confidential version.

To avoid duplicate data and ensure that all data for a particular facility is consolidated, please

submit all of the data requested from your facility in the same manner. To submit your data, mail

a CD or DVD containing an electronic copy of all requested files to the EPA address below:

U.S. Environmental Protection Agency

Office of Air Quality Planning and Standards

U.S. EPA Mailroom (D243-02)

Attn: Mr. Conrad Chin

109 T.W. Alexander Drive

Research Triangle Park, NC 27711

If the process data or other information you are providing is considered confidential, please

create a separate CD or DVD containing only the confidential portion of your data or prepare a

copy of the hard copy materials containing only the pages that include the information you

consider confidential. Clearly mark the disk and/or materials with the words “Confidential

Business Information.” Send these confidential files under separate cover to the attention of Mr.

Roberto Morales at the following address:

U.S. Environmental Protection Agency

Office of Air Quality Planning and Standards

U.S. EPA Mailroom (C404-02)

Attn: Mr. Roberto Morales, Document Control Officer

109 T.W. Alexander Drive

Research Triangle Park, NC 27711

For the security of your data, EPA recommends sending your confidential files to Mr. Morales

via Registered U.S. Mail using return receipt requested, Federal Express, or other method for
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which someone must provide a signature upon receipt. Do not electronically transmit CBI to

EPA. E-mail and facsimile are not secure forms of communication and should never be used to

transmit CBI.

If you have any questions regarding this request, please contact Mr. Conrad Chin at e-mail

chin.conrad@epa.gov
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PLEASE RETURN THIS SURVEY NO LATER THAN MARCH 30, 2013

CONFIDENTIAL BUSINESS INFORMATION (CBI):

Please indicate if any CBI is included in this survey response:  Yes  No

PART I. OWNER INFORMATION

1. Name of Legal Owner: Georgian American Alloys, Inc. (D/B/A Felman Production, LLC.)

a. Address: 200 S. Biscayne Blvd., Suite 5500

b. City: Miami

c. State: Florida

d. Zip: 33131

e. County: Miami-Dade

2. Complete street address of facility (physical location):

a. Address: 4442 Graham Station Road

b. City: Letart

c. State: West Virginia

d. Zip: 25253

e. County: Mason

3. Mailing Address (if different from Facility Street Address):

a. Address: 4442 Graham Station Road

b. City: Letart

c. State: West Virginia

d. Zip: 25253

e. County: Mason
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4. Facility Contact:

a. Name (First/Last): John S. Konrady

b. Title: Plant Manager

c. Telephone Number: (304 )882-1401 Ext

d. Fax Number: (304) 882-3853

e. E-mail: jskonrady@fpiwv.com

5. Facility Description:

a. Number of Facility Employees:

Number of employees associated with ferroalloy production operations at the facility (answer

may be given using the following ranges: 0-100; 101-250; 251-500; 501-750; 751-1,000;

1,001-1,500; and >1,500). Include temporary employees if they are a significant fraction of

your total number of employees.

251-500

b. Number of Corporate Employees:

Approximate number of employees of the business enterprise that owns this plant, including

where applicable, the parent company and all subsidiaries, branches, and unrelated

establishments owned by the parent company.

251-500

6. Permit Conditions:

If any of the ferroalloys production operations at your facility are subject to State or local air

permit limits, please provide a copy of your current operating permit. If you have a title V

permit and it is not available online, please provide a copy of it. If your title V permit renewal

is still pending, please provide a copy of your permit application.

Attachment #1 includes a copy of Felman’s current Title V permit #R30-05300004-2007

(SM01). Attachment #2 includes a copy of the permit renewal application submitted in

February, 2012.
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PART II. GENERAL FACILITY INFORMATION

1. Summary of Ferroalloy Production Unit Operations

Complete the process summary in Table 2A for 2012 for all unit operations at your plant

covered by the ferroalloys production source category. These include storage and

handling of raw materials and products.

Felman requests that its response to this question and Table 2A be treated as

Confidential Business Information.

2. Summary of Raw Materials

Complete the summary of raw materials used, in Table 2B. Include available information

on the components included in the furnace charges for each product, and indicate

approximately how much of each was consumed in 2012.

Felman requests that the raw material usage data contained in Table 2B be treated as

Confidential Business Information.

For each material potentially containing metal HAP, please provide the supplier’s

analysis or Material Safety Data Sheet (MSDS) describing the composition of the

material. Describe the factors that are important in the selection of the raw material.

Felman requests that certain MSDS data be treated as Confidential Business

Information. Other MSDS are included in Attachment #3. Important factors in raw

material selection include product specifications, product availability, schedule and

price.

3. Summary of Products & Production Volume

Complete the summary of products and production volume in Table 2C. List the

products, co-products, and by-products and indicate how much of each was produced in

each of the last 3 years.

Felman requests that its response to this question and Table 2C be treated as

Confidential Business Information.

4. Verification of Area and Point Source Modeling Parameters

Review the point source modeling parameters in Table 2D and the area source modeling

parameters in Table 2E, and make any revisions to the listed values in the respective

columns.
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The modeling parameters set forth in Tables 2D and 2E appear generally correct.

However, Felman has not independently surveyed the property to confirm their accuracy.

PART III. COST ESTIMATES AND PLANS

1. Costs to Implement Enhanced Local Capture at Felman

Please provide capital and annual costs to implement the enhanced local capture system described in

your transmittal of July 11, 2012. Using that transmittal and other information provided by you, we

have developed the following draft scenario of improvements anticipated for each of the major

emission points at the facility. Please review this list and notify us if you would suggest any changes

to this list of capture and control scenarios. Then, provide estimated costs to design, purchase, install

and operate each element, including expenses projected for 2013 and beyond.

 Add mesh curtains on furnace charging floor;

 Furnace 2 tap hood upgrade (replace tapping/pouring damper equipment, modify

ductwork);

 New furnace baghouse fan and motor on Furnace 2;

 Add tapping platform enclosures at each furnace;

 Crushing system upgrades to number 2 crusher;

 Install secondary rooftop ventilation for capture of fugitive furnace emissions;

 Install secondary rooftop ventilation for capture of fugitive emissions from both crushing

systems (2 systems).

Felman cannot at this time provide the detailed cost data requested. At the outset, the list

provided does not accurately portray the enhanced systems provided in the July 11, 2012

transmittal. For example, Felman proposed only a single secondary rooftop ventilation system

in the main furnace building and did not propose a second system in the crushing and sizing

area. Other projects, such as the furnace curtains, have experienced technical problems (e.g.,

premature curtain failure).

Due to these and other concerns, Felman has again retained an engineering firm to re-evaluate

control options for the facility. Felman anticipates that the firm’s review will begin in early

April, and that the company should be able to provide a revised proposal, along with

approximate costs, by the end of May.
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EPA INFORMATION COLLECTION REQUEST FOR

FERROALLOYS PRODUCTION MANUFACTURING EMISSION POINTS

SECTION 2. PLANT OPERATIONS

Table 2A : Summary of Ferroalloy Production Unit Operations

Name of Unit Operations

Using and/or Emitting

HAP

Emission

Point IDa

Operating Cycle Average

Annual

Production,

SiMn

(tons/yr)

Maximum

Annual

Production,

SiMn

(tons/yr)

Average

Annual

Production,

FeMn

(tons/year)

Maximum

Annual

Production,

FeMn

(tons/year)

SiMn

(hr/day,

day/yr)

FeMn

(hr/day,

day/yr)

Submerged Arc Furnace #2 001-01 0 0 0

Submerged Arc Furnace #5 001-02 0 0 0

Submerged Arc Furnace #7 001-03 0 0 0

Crushing and Screening #1 009-01 0 0 0

Crushing and Screening #2 009-02 0 0 0

(a) Please use the same Emission Point ID as used in previous ICR submittals, where possible.

Operating Cycle and SiMn Production (tons/yr) submitted separately as Confidential Business Information
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EPA INFORMATION COLLECTION REQUEST FOR

FERROALLOYS PRODUCTION MANUFACTURING EMISSION POINTS

SECTION 2. PLANT OPERATIONS

Table 2B : Summary of Raw Materials

Add materials as necessary, include units for each.

Raw Material

(by product)

Annual Consumption, SiMn

products

(tons)

Annual Consumption, FeMn

Products

(tons)

Supplier's Composition

Analysis or Material Safety

Data Sheet (Y/N)

Coke (dry weight) N/A See attachment 3

Manganese Ore N/A See attachment 3

Quartz N/A See attachment 3

Coal N/A See attachment 3

Electrode Paste N/A See attachment 3

FeSi Dross N/A See attachment 3

Dolomite N/A See attachment 3

Some Raw Materials & Annual Consumption of SiMn Raw Materials submitted separately as Confidential Business Information
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EPA INFORMATION COLLECTION REQUEST FOR

FERROALLOYS PRODUCTION MANUFACTURING EMISSION POINTS

SECTION 2. PLANT OPERATIONS

Table 2C : Summary of Products & Production Volume

Add other products as necessary, include units for each.

Product

2010

(tons/yr)

2011

(tons/yr)

2012

(tons/yr)

Ferromanganese 0 0 0

Silicomanganese

Silifume 0 0 0

Other (List):

Product

2010

(tons/yr)

2011

(tons/yr)

2012

(tons/yr)

Annual Production (tons/yr) and some product information submitted separately as Confidential

Business Information
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EPA INFORMATION COLLECTION REQUEST FOR

FERROALLOYS PRODUCTION MANUFACTURING EMISSION POINTS

SECTION 2. PLANT OPERATIONS

Table 2D: Controlled Emission Point Modeling Parameters (Point Sources)

Emission

Point ID (a) Description Latitude Longitude ReleaseHeight (m)

Stack

Diameter

(m)

Velocity

(m/s)

Exhaust

Temperature

(degrees K)

BH1S Crushing & Screening System 1 38.957957 -81.925265 10.668 0.48768 19.21764 307.591

BH2S Crushing & Screening System 2 38.957891 -81.925391 10.688 0.64008 14.6304 307.591

(a) Please use the same Emission Point ID as used in previous ICR submittals, where possible.
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EPA INFORMATION COLLECTION REQUEST FOR FERROALLOYS PRODUCTION MANUFACTURING

EMISSION POINTS

SECTION 2. PLANT OPERATIONS

Table 2E: Building Roof Vent & Other Fugitive Emissions Modeling Parameters (Area Sources)

Unit Operation Name and Process Diagram ID (a):

Emission

Points

(a)

Description

Release Parameters for Risk Modeling (b)

Coordinates

Release

Height Dimension of Source (c)

Angle of

Rotation (d)

(degrees)

Latitude Longitude (m)

x (length,

m)

y (width,

m)

BH2 Furnace 2 38.958308 -81.927558 25.908 12.192 48.1584 45

Furnace 2 Fugitives 38.957307 -81.927784 24.9936 4.572 4.572 45

DH2 Furnace 2 Tapping Fugitives 38.957307 -81.927784 24.9936 4.572 4.572 45

Furnace 2 Casting Fugitives 38.957307 -81.927784 24.9936 0.9144 10.0584 45

BH5 Furnace 5 38.958571 -81.927117 25.908 12.192 48.1584 45

Furnace 5 Fugitives 38.957781 -81.926727 24.9936 4.572 4.572 45

DH5 Furnace 5 Tapping Fugitives 38.957781 -81.926727 24.9936 4.572 4.572 45

Furnace 5 Casting Fugitives 38.957781 -81.926727 24.9936 0.9144 10.0584 45

BH7 Furnace 7 38.958805 -81.926275 25.908 12.192 48.1584 45

Furnace 7 Fugitives 38.958043 -81.926275 24.9936 4.572 4.572 45

DH7 Furnace 7 Tapping Fugitives 38.958043 -81.926275 24.9936 4.572 4.572 45

Furnace 7 Casting Fugitives 38.958043 -81.926275 24.9936 0.9144 10.0584 45

Crushing System 1 Fugitives 38.957169 -81.926972 24.9936 12.8016 12.8016 45

Crushing System 2 Fugitives 38.957978 -81.925644 24.9936 16.4592 16.4592 45

(a) Please use the same Emission Point ID as used in previous ICR submittals, where possible.

(b) For each building vent with potential to release fugitive emissions, enter the applicable information.

(c) Dimension of source refers to the area defined as a nonpoint source emission (e.g., roof vent).

(d) The angle of rotation specifies the rotation of the source from north (in the clockwise direction).