MEMORANDUM 

DATE: February 21, 2014

TO: Phil Mulrine, EPA OAQPS/SPPD/MMG

FROM: Bradley Nelson, EC/R, Inc.

SUBJECT: Summary of the February 12, 2014 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 was 

published in the Federal Register on November 23, 2011 (76 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

John Rego, Jones Day

Felman Production

John Konrady, Felman Production

Laura McAfee, Beveridge and Diamond

Policy Navigation Group

Troy Hillier

EC/R Incorporated

Bradley Nelson 
III. 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 manganese 

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 of 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 achieves 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 control 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 tap-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 Discussed

 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 2/12/2014 Meeting with the Ferroalloys Production Industry and EPA
Chuck,

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