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 JohnWe are still in the process of reviewing the information you sent us last week. I personally believe the 

proposal (95% capture of process fugitive emissions 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 

estimating fugitive manganese emissions 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 Agency 

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, 

JKonrady@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 dioxins/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 materials 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 calls, 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 Method 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.COM
From: 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.Jonathan@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 JohnThis 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 seems 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)