MEMORANDUM

DATE: February 2 1

, 201 4

TO: Phil Mulrine

, EPA OAQPS/SPPD/ MMG

FROM: Bradley Nelson, EC/R, Inc.

SUBJECT: Summary of the February 12

, 201 4 Meeting with the Ferroalloys Production

Industry and the U.S. Environmental Protection Agency

I. INTRODUCTION

The purpose of the teleconference was to discuss the potential opacity standards in the supplemental proposal

. This meeting summary will be available in the docket for this rulemaking (Docket ID No. EPA

– HQ

– OAR

– 2010

– 0895 ). The proposed rule for ferroalloys production wa s published in the Federal Register on November 23, 20 1 1 (7 6 FR 72508 ).

II. ATTENDEES

The following is a list of participants in the meeting.

U.S. Environmental Protection Agency Chuck French Phil Mulrine Colin Boswell Steffan Johnson

Eramet Marietta Jeff McKinney, Eramet Marietta
J ohn Rego

, Jones Day

Felman Production John Konrady, Felman Production Laura McAfee, Beveridge and Diamond

Policy Navigation Group Troy Hillier

EC/R Incorporated Bradley NelsonIII. SUMMARY OF DISCUSSION

The meeting was used to discuss the development of potential opacity standards in the supplemental proposal . An agenda of the discussion topics for this teleconference is provided by the Policy Navigation Group in Attachment A of this meeting summary

. The following is a brief summary of the major points that were discussed during the meeting

.

NESHAP Opacity Standard

 In the November 23, 2011 proposal, EPA proposed building ventilation and would require that emissions exiting the shop building could not exceed 10 percent opacity for
more than one 6

- minute period or required fenceline monitoring of mang anese concentration

.

 The EPA staff believe that the opacity standard needs to be rigorous to ensure compliance with the supplemental proposal fugitive emission requirements , and would include a low opacity standard and more frequent readings from the roofline o f the furnace buildings.
The EPA staff believe that opacity in the 6

- 8 percent range is reasonable from one furnace tapping period to the next furnace tapping period (e.g., tap

- to

- tap) with the installation and operation of a fugitive control system that achie ves 95 percent reduction of fugitive emissions from the ferroalloys production process.

 The industry noted that there are high opacity events during normal operation that exceed 6 minutes in length and they had concerns with meeting the opacity standard during these

events. The industry also noted that opacity is read in 5 percent increments and there is no discernable difference between 6 percent opacity and 8 percent opacity.

 The industry noted that 95 percent mass reduction in fugitive emissions does not translate to 95 percent reduction in opacity, and have concerns with the fugitive contr ol system achieving 95 percent reduction during high opacity events.

 The EPA staff noted that a 6

- 8 percent opacity standard would allow for the facilities to have several periods of 15 percent opacity and still be able to meet the standard during a
furnace ta p

- to

- tap period.

 The EPA staff stated that the opacity standard is intended to be met at all times and that the proposed limit in the supplemental proposal would probably not include any
exclusions such as blowing taps

, poling, or oxygen lancing of the tap hole which are
included in the current NESHAP.

 The industry noted that they sent a summary of non

- routine operating conditions that warrant a modified fugitive emissions standard on November 26, 2013. They estimate that the opacity during these events to be 20

- 30 percent, and can last from minutes to hours depending on the event.Other Topics D i scussed

 For monitoring, the EPA believes that opacity measurements, fan amperage, and damper placement are parameters that can be used to ensure compliance with a 95 percent reduction in fugitive emissions. They requested additional information from the facilities for additional parameters that could be monitored.ATTACHMENT A

Agenda for 2 / 12 /201 4 Meeting with the Ferroalloys Production Industry and EPAChuck,

As we discussed I put together a brief agenda for our call tomorrow morning. Feel free to make any additions that you think make sense.

Opacity

1. Level of the standard 2. Averaging period 3. Allowable excursions 4. Monitoring frequency (including recordkeeping and reporting requirements)

Other compliance requirements

Schedule and process update

Thanks,

Troy