From: Conrad Chin [mailto:Chin.Conrad@epamail.epa.gov]

Sent: Wednesday, July 11, 2012 3:07 PM To: John Rego; Jeff.McKinney@erametgroup.com Cc: Amy M. Lincoln; Chuck French; Beth Friedman; JKonrady@fpiwv.com; Jonathan Averback; RLunn@fpiwv.com; Troy Hillier; Carlton Nash; Bob Schell Subject: Re: Package from Eramet

Hello John

We are still in the process of reviewing the information you sent us last week. I personally believe the proposal (95% capture of process fugitive em issions at the individual source) represents a significant improvement over your original proposal (pages 15 to 16 of Engineering Review dated January 27, 2012). However, it is too early to tell whether this latest proposal is adequate in protecting the health of
the public.

One reason being there are considerable discrepancies in the baseline manganese emissions from your calculations as compared to ours. We would like to go over with you the methodology used in

e stimating fugitive manganese emissi ons on pages 3

- 4 of your letter. If you think the meeting on next Monday is the proper time and place to do it, we can do it then. Or we can pick another time. Anyway, we hope you can invite someone who is familiar with the methodology to explain to us.

One example is the estimation of casting fugitive emissions. Eramet uses an emission factor of 0.056 lb/ton. I recall that I discussed this issue with Eramet before proposal (see first attachment, email from Conrad Chin to John Hughes dated 2/18/2011) . In that email, I informed Eramet that we plan to use an emission factor of 2.4 lb/ton. This emission factor was developed by Ohio EPA, and is currently being used by some other non

- manganese ferroalloy plants, as well as Felman (second attachment). The use of this emission factor was in the docket, and we did not get any comments. We were surprised to see

an emission factor so drastically different from ours.

We will prepare a full list of questions to go over in the near future. Thanks.

(See attached file: 3337_001.pdf) (See attached file: 3336_001.pdf)

Conrad K. Chin
Mail Code D243

- 02 Metals and Minerals Group Sector Policies and Programs Division Office of Air Quality Planning and Standards U.S. Environmental Protection Agenc y 919

- 541

- 1512 (voice)

919

- 541

- 3207 (fax)From: John Rego <jrego@JonesDay.com>

To: Conrad Chin/RTP/USEPA/US@EPA Cc: "Amy M. Lincoln" <ALincoln@bdlaw.com>, Jonathan Averback/DC/USEPA/US@EPA, Colin Boswell/RTP/USEPA/US@EPA, Jason Dewees/RTP/USEPA/US@EPA, Chuck French/RTP/USEPA/US@EPA, Beth Friedman <friedman.beth@ecrweb.com>, Jeff.McKinney@erametgroup.com,

J Konrady@fpiwv.com, Steffan Johnson/RTP/USEPA/US@EPA, Raymond Merrill/RTP/USEPA/US@EPA, Brad Nelson <nelson.brad@ecrweb.com>, Kelly Rimer/RTP/USEPA/US@EPA, RLunn@fpiwv.com, Robin Segall/RTP/USEPA/US@EPA, Darcie Smith/RTP/USEPA/US@EPA Date: 07/03/2012 03:11 PM Subject: Re: Package from Eramet

Conrad:

You are correct that the only part of the yesterday's package that relates to the upcoming stack tests is Appendix D. Please note that the purpose of the materials was to address other issues

-- the companies' request that EPA consider alternatives to total building enclosure and the companies' request that EPA provide time to collect a more robust dataset than was relied upon to set non

- RTR MACT limits for four pollutants. Appendix D identifies the stack test data that EMI is offering to collect in a "cold weather"
test, along with the stack test data that EMI is committing to collect in July. (EPA's request late last week

to incorporate testing for pollutants not covered in the proposed NESHAP (PCBs and dio xins/furans) was received too late to be addressed in the materials, but my understanding is that such parameters could probably be added to the cold weather stack test if we receive sufficient time to conduct that test.)

Please also note that the ma terials also describe a proposal by EMI to conduct performance testing of activated carbon injection on both of its active EAF's, and to include mercury emissions testing via CEM in that work. As Jeff McKinney explained on one of our recent conference ca lls, due to the semi

- batch nature of ferroalloys production, and the likelihood that mercury (and PAH) will volatilize rapidly when added to the furnace, EMI suspects that CEM would provide more useful emission data for ferroalloys production than Metho d 30B; if so, it will be employed in the cold weather test as well.

In light of all of that, EMI believes the best approach is to include an 8

- hour run for mercury an a 3

- hour
run for PAH on each furnace and on MOR.

Have a great holiday as well.

John

John Rego • Environmental, Health & Safety 901 LAKESIDE AVENUE • CLEVELAND, OHIO 44114
DIRECT 216.586.7542 • FAX 216.579.0212 • JREGO@JONESDAY.COMFrom: Conrad Chin <Chin.Conrad@epamail.epa.gov>

To: John Rego <jrego@JonesDay.com>
Cc: "Amy M. Lincoln" <ALincoln@bdlaw.com>, Chuck French <French.Chuck@epamail.epa.gov>, Darcie
Smith <Smith.Darcie@epamail.epa.gov>, Beth Friedman <friedman.beth@ecrweb.com>, Jeff.McKinney@erametgroup.com, JKonrady@fpiwv.com, Jonathan Averback
<Averback.Jon athan@epamail.epa.gov>, Kelly Rimer <Rimer.Kelly@epamail.epa.gov>, Brad Nelson <nelson.brad@ecrweb.com>, RLunn@fpiwv.com, Robin Segall <Segall.Robin@epamail.epa.gov>, Steffan Johnson <Johnson.Steffan@epamail.epa.gov>, Colin Boswell <Boswell.Colin@epamail .epa.gov>, Jason Dewees <Dewees.Jason@epamail.epa.gov>, Raymond Merrill <Merrill.Raymond@epamail.epa.gov>,
Darcie Smith <Smith.Darcie@epamail.epa.gov>

Date: 07/03/2012 02:24 PM Subject: Package from Eramet

Good afternoon John

This is to acknowledge that I received a package from you this afternoon. After reviewing quickly on the package, I believe the only section related to the upcoming July tests is the table in Appendix D. Is that
correct?

In reviewing that table, it se ems Eramet is still planning to test only one run for each of the furnaces for mercury and PAHs. Is that correct?

We will probably discuss in more details during our July 16 meeting. Have a happy 4th.

Conrad K. Chin
Mail Code D243

- 02
Metals and Minerals Group Sector Policies and Programs Division Office of Air Quality Planning and Standards U.S. Environmental Protection Agency
919

- 541

- 1512 (voice)

919

- 541

- 3207 (fax)