EMISSION MEASUREMENT SUMMARY REPORT FILTERABLE PARTI CULATE MATTER FURNACE 12 FITLERABLE PARTICUL ATE MATTER, HCl/HF, AND MANGANESE FURNACE NO. 1 ERAMET MARIETTA, INC. MARIETTA, OHIO

Prepared for:

Eramet Marietta, Inc. P.O. Box 299 State Route 7 South Marietta, Ohio 45750-0299

Prepared by:

Environmental Quality Management, Inc. 1800 Carillon Boulevard Cincinnati, Ohio 45240 (513) 825-7500 Fax (513) 825-7495
www.eqm.com

PN: 050352.0024

June 2011ii CONTENTS

Section Page

1 Introduction................................................................................................................. ..... 1-1

2 Summary of Test Results................................................................................................. 2-1

3 Sampling and Analytical Procedures............................................................................... 3-1 3.1 Location of Measurement Sites ........................................................................... 3-1 3.2 Stack Gas Volumetric Flow Rate......................................................................... 3-1 3.3 Stack Gas Dry Molecular Weight........................................................................ 3-1 3.4 Stack Gas Moisture Content ................................................................................ 3-2 3.5 Filterable Particulate Matter ................................................................................ 3-2 3.6 Hydrogen Chloride and Hydrogen Fluoride ........................................................ 3-2 3.7 Manganese ........................................................................................................... 3-2 3.8 Visible Emissions................................................................................................. 3-3

4 Process Description/Sampling Locations ........................................................................ 4-1

5 Quality Assurance and Quality Control........................................................................... 5-1 5.1 Field Sampling..................................................................................................... 5-1 5.2 Calibration Procedures and Frequency ................................................................ 5-1

Appendices:

A Calculations B Raw Field Data C Analytical Data D Process and Visible Em ission Observation Data E Quality Assurance/Quality Controliii FIGURES

Number Page

3-1 EPA Method 5/29 Sampling Train .................................................................................. 3-4 3-2 EPA Method 26 Sampling Train...................................................................................... 3-5 4-1 Sampling Locations ......................................................................................................... 4-2

TABLES

Number Page

1-1 Sampling Locations and Test Parameters........................................................................ 1-2 2-1 Furnace No. 12 Summary of Stack Conditions ............................................................... 2-3 2-2 Furnace No. 12 Summary of Particulate Emissions and Process Operations.................. 2-3 2-3 Furnace No. 1 Summary of Stack Conditions ................................................................. 2-4 2-4 Furnace No. 1 Summary of PM and Mangane se Emissions and Process Operations ..... 2-5 2-5 Furnace No. 1 Summary of HCl and HF Emissions ....................................................... 2-6 4-1 Sampling Location Parameters ........................................................................................ 4-2 5-1 Field Equipment Calibrations .......................................................................................... 5-2 5-2 Field Checks of Sampling Equipment ............................................................................. 5-21-1 SECTION 1

INTRODUCTION

On May 25 and 26, 2011, Environmental Qua lity Management, Inc. (EQ) personnel conducted a compliance air emission program at the Eramet Marietta Inc. (Eramet) facility in Marietta, Ohio. Sampling was conducted following the procedures of EPA Reference Methods 1 through 5, and 9 to quantify emissions of filte rable particulate matter from Furnace No. 12. Sampling was conducted following the procedures of EPA Reference Methods 1 through 5, 9, 26, and 29 to quantify emissions of filterable pa rticulate matter, hydrogen chloride, hydrogen fluoride acid, and manganese from Furnace No. 1.
EQ utilized EPA Reference Methods 1 and 2 to calculate stack gas velocities and temperatures. EPA Method 3 was used to determ ine the stack gas molecular weight. Moisture, filterable particulate matter, and visible emissions were measured following the procedures of EPA Methods 4, 5, and 9, respectively. Hydrogen ch loride and hydrogen fluoride were measured following the procedures of EPA Method 26. Ma nganese emissions were obtained using EPA Method 29. An outline of the specific sampling met hods and parameters utilized is provided in

Table 1-1 and detailed in Section 3. Mr. John Hughes of Eramet monitored process operations during testing. Ms. Christina Wieg, Ms. Lisa Duvall, and Mr. Marco Deshaies of the Ohio Environmental Protection Agency (Ohio EPA) observed process operations and sampli ng efforts. Mr. John Rowe of EQ managed the sampling effort. Messrs. Dan Scheffel, Tom Gerstle, Doug Allen, Mike Todd, Gary Drexler, Chris Janzen, and Richard Kelly of EQ conducted the emission testing.1-2 TABLE 1-1. SAMPLING LO CATIONS AND TES T PARAMETERS Stack I.D. Test Method Parameter No. of Samples Run Time/Sample, min Furnace No.12 Scrubber Exhaust May 25, 2011 1-2 3 4 5 9 Flow CO 2 /O 2 Moisture Filterable PM Opacity 3 3 3 3 1 60 60 60 60 60 Furnace No.1 Main and Taphole Baghouse Exhausts May 26, 2011 1-2 3 4 5 9 26 29 Flow CO 2 /O 2 Moisture Filterable PM Opacity HCl/HF Manganese 3 3 3 3 1 3 3 120 120 120 120 60 120 1202-1 SECTION 2

SUMMARY OF TEST RESULTS

Furnace No. 12 (scrubber exhaust) was sampled on May 25, 2011 to quantify emissions of filterable particulate. Fu rnace No. 12 was sampled at a maxi mum furnace load, approximately

19.54 MW. Three 1-hour test runs were conducted at the Furnace No. 12 scrubber exhaust to determine the concentration and mass emission rate of filterable particulate matter. Sampling was conducted following EPA Reference Methods 1 through 5. Furnace No. 1 (2 baghouse exhausts) was sampled on May 26, 2011 to quantify emissions of filterable particulate, manganese, hydrogen chloride, and hydrogen fluoride. The main baghouse controls emissions from the fu rnace and the taphole baghouse controls emissions from the tapping operations. The furnace was sampled at a maximum furnace load, approximately 27.12 MW. Three 2-hour test runs were conducted at each baghouse. Sampling was conducted following EPA Reference Methods 1 through 5, 26, and 29.
EPA Reference 9, “Visible Determination of the Opacity of Emissions from Stationary Sources,” was used to determine opacity from the furnace roof monitor for Furnace Nos. 1 and 12. A 1-hour emission observation was completed in conjunction with the particulate sampling runs. The opacity averaged 3.4% for the Furnace No. 1 roof monitor with occasional 5% to 20% opacity observed during tapping. The opacity averaged 1.7% for the Furnace No. 12 roof

monitor with occasional 5% to 20% opacity observed during tapping. Table 2-1 summarizes the stack gas conditions measured during each sampling run for Furnace No. 12. Stack gas velocity and temperat ure, volumetric flow rates, gas composition
(CO 2 and O 2 ), and moisture content are detailed for each test run. Table 2-2 summarizes the filterable particulate matter and pertinent production data for
each test run for Furnace No. 12. In addition, a tap was conducted during all three test runs. Table 2-3 summarizes the stack gas conditi ons measured during each sampling run for Furnace No. 1. Stack gas velocity and temperatur e, volumetric flow rates, gas composition (CO 2 and O 2 ), and moisture content are detailed for each test run.2-2 Table 2-4 summarizes the filterable particulate matter, manganese emissions, and pertinent production data for each test run for Fu rnace No. 1. In addition, a tap was conducted during all three test runs. Table 2-5 summarizes the hydrogen chlori de (HCl) and hydrogen fluoride (HF)

concentrations and emissions for each test run for Furnace No. 1. Example calculations are include d as Appendix A, raw field da ta is included as Appendix B, analytical data is included in Appendix C, process and visible emissi ons observation data are included in Appendix D, and quali ty assurance/quality control da ta are located in Appendix E.TABLE 2-1. FURNACE NO. 12SUMMARY OF STACK GAS CONDITIONSDates: May 25, 2011 Plant: Eramet - Marietta, OhioVolumetric Flow RateRun No. TimeStack GasVelocity,fpsaacfmbdscfmcTemp,°FMoisture,%CO2, % O2, %12-1 0754-0856 54.5 162,036 133,190 132 6.1 2.0 20.512-2 0951-1100 54.7 162,797 134,572 132 5.6 1.5 20.012-3 1135-1239 54.7 162,869 134,356 132 5.7 1.0 20.0Average 54.6 162,567 134,040 132 5.8 1.5 20.2aFeet per second.bActual cubic feet per minute.cDry standard cubic feet per minute.TABLE 2-2. FURNACE NO. 12SUMMARY OF PARTICULATE EMISSIONS AND PROCESS OPERATIONSDate: May 25, 2011Plant: Eramet - Marietta, OhioFilterable Particulate MatterConcentrationRun No. Timegr/dscfalb/dscfbMass Rate,lb/hrcProcess ThroughputTons/hr at furnace load(MW)Pressure Drop,inches of water12-1 0754-0856 6.03E-03 8.61E-07 6.88 18.98 at 20.20 MW 51.8 east 53.4 west12-2 0951-1100 5.80E-03 8.29E-07 6.69 18.98 at 19.49 MW 52.4 east 53.5 west12-3 1135-1239 4.10E-03 5.86E-07 4.72 18.98 at 18.93 MW 52.4 east 53.4 westAverage 5.31E-03 7.59E-07 6.10 18.98 at 19.54 MW 52.2 east 53.4 westaGrains per dry standard cubic foot.bPounds per dry standard cubic foot.cPounds per hour.

2-3TABLE 2-3. FURNACE NO. 1SUMMARY OF STACK GAS CONDITIONSDates: May 26, 2011 Plant: Eramet - Marietta, OhioVolumetric Flow RateRun No.TimeStack GasVelocity,fpsaacfmbdscfmcTemp,°FMoisture,%CO2, % O2, %Furnace No. 1 Main Baghouse29-MA-1 0734-1008 52.3 246,462 189,240 209 2.3 0.0 21.029-MA-2 1030-1237 51.6 243,330 181,874 228 2.2 0.0 21.029-MA-3 1310-1516 52.2 246,074 184,727 225 2.2 00 21.0Average 52.1 245,289 185,280 221 2.2 0.0 21.0Furnace No. 1 Taphole Baghouse29-ME-1 0734-0944 37.8 48,182 43,666 112 1.6 0.0 21.029-ME-2 1030-1241 37.4 47,710 42,887 117 1.7 0.0 21.029-ME-3 1310-1517 36.7 46,791 41,608 122 1.8 0.0 21.0Average 37.3 47,561 42,720 117 1.7 0.0 21.0aFeet per second.bActual cubic feet per minute.cDry standard cubic feet per minute.

2-4TABLE 2-4. FURNACE NO. 1SUMMARY OF PM AND MANGANESE EMISSIONS AND PROCESS OPERATIONSDate: May 26, 2011Plant: Eramet - Marietta, OhioFilterable Particulate MatterConcentrationRun No. Timegr/dscfalb/dscfbMass Rate,lb/hrcManganeseMass Rate,lb/hrcProcessThroughputTons/hr atfurnace load(MW)Pressure Drop,inches of waterFurnace No. 1 Main Baghouse29-MA-1 0734-1008 1.64E-03 2.34E-07 2.66 0.212 33 at 26.50 8.4529-MA-2 1030-1237 3.89E-04 5.56E-08 0.61 0.186 33 at 27.54 8.3429-MA-3 1310-1516 2.90E-04 4.15E-08 0.46 0.179 33 at 27.31 8.43Average7.73E-04 1.10E-07 1.24 0.192 33 at 27.12 8.41Furnace No. 1 Taphole Baghouse29-ME-1 0734-0944 1.03E-03 1.48E-07 0.39 0.053 33 at 26.50 12.029-ME-2 1030-1241 8.50E-04 1.21E-07 0.31 0.043 33 at 27.54 12.029-ME-3 1310-1517 1.65E-03 2.36E-07 0.59 0.074 33 at 27.31 12.0Average 1.18E-03 1.68E-07 0.43 0.057 33 at 27.12 12.0aGrains per dry standard cubic foot.bPounds per dry standard cubic foot.cPounds per hour.

2-5TABLE 2-5. FURNACE NO. 1SUMMARY OF HCL AND HF EMISSIONSDate: May 26, 2011Plant: Eramet - Marietta, OhioHCl HFRun No. TimeConcentration,ppmdvaMass Rate,lb/hrbConcentration,ppmdvaMass Rate,lb/hrbFurnace No. 1 Main Baghouse26-MA-1 0734-0934 2.91E-04 3.13E-04 1.26E-03 7.40E-0426-MA-2 1103-1303 2.89E-04 2.99E-04 1.30E-03 7.34E-0426-MA-3 1315-1523 2.66E-04 2.80E-04 1.22E-03 6.99E-04Average 2.82E-04 2.97E-04 1.26E-03 7.24E-04Furnace No. 1 Taphole Baghouse26-ME-1 0734-0934 3.57E-04 8.82E-05 1.60E-03 2.17E-0426-ME-21030-1230 3.02E-04 8.03E-05 1.35E-03 1.97E-0426-ME-3 1310-1510 2.48E-04 5.86E-05 1.15E-03 1.50E-04Average 3.02E-04 7.57E-05 1.37E-03 1.87E-04aParts per million, dry basisbPounds per hour.

2-63-1 SECTION 3

SAMPLING AND ANALYTICAL PROCEDURES

The sampling and analytical procedures used in this test program conformed to EPA Reference Methods 1 through 5, 9, 26, and 29 as published in the Federal Register.

3.1 Location of Measurement Sites

EPA Method 1, “Sample Velocity Traverses for Stationary Sources,” was used to select representative measurement sites. Sample locations are discussed in Section 4. Exact

measurements were verified on site.

3.2 Stack Gas Volumetric Flow Rate

EPA Method 2, “Determination of Stack Gas Ve locity and Volumetric Flow Rates,” was

used at each location to determin e stack gas volumetric flow rates. Standard and Type “S” pitot tubes meeting EPA specifications and an inclined manometer were used to measure velocity pressures. A calibrated Type “K ” thermocouple attached directly to the pitot tube was used to measure stack gas temperature. The stack gas velocity was calculated from the average square root of the stack gas velocity pressure, aver age stack gas temperature, stack gas molecular weight, and absolute static pres sure. The volumetric flow rate is the product of velocity and

stack cross-sectional area.

3.3 Stack Gas Dry Molecular Weight

EPA Method 3, “Gas Analysis for the Determ ination of Dry Molecular Weight,” was used to determine the stack gas dry molecular wei ght at all sampling locations. Fyrite analyzer readings were conducted for oxygen and carbon dioxide.3-2 3.4 Stack Gas Moisture Content

EPA Method 4, “Determination of Moisture Content in St ack Gases,” was used to determine stack gas moisture content. This method was conducted as part of each particulate

measurement run. The initial and final cont ents of all impingers were determined gravimetrically.

3.5 Filterable Particulate Matter

EPA Method 5, “Determination of Particulate Emissions from Stationary Sources,” wasused to determine filterable particulate matter. The sampling train consisted of a nozzle, glasslined probe, heated quartz-fiber filter, and a series of impingers filled with appropriate reagents, followed by a vacuum pump, dry gas meter, and calibrated orifice. The probe and filter temperatures were maintained at 248 o ± 25 o F. Thermocouples were used to monitor temperatures of the stack gas, sample probe, filt er, and impinger exit gas. Three 1-hour sampling
runs were conducted at Furnace No. 12, and thre e 2-hour sampling runs were conducted at the Furnace No. 1 main and taphole baghouse exhausts. Figure 3-1 is a schematic of the sampling

system.

3.6 HCl and HF

Hydrogen chloride (HCl) and hydrogen fluorid e (HF) emissions were measured at the Furnace No. 1 main and taphole baghouse exhausts following the procedures of EPA Method 26. The sampling reagent consisted of 0.1 Normal sulfuric acid in the first two impingers followed by two impingers containing 0.1 Normal sodium hydroxide. The indivi dual portions were

recovered with a deionized water rinse and an alyzed by ion chromatography. Figure 3-2 is a schematic of the sampling system. Thr ee 2-hour test runs were completed.

3.7 Manganese

EPA Method 29, “Determination of Multiple Meta ls Emissions from Stationary Sources,” was used to determine manganese emissions . Sampling was conducted using a Method 5 sampling train with appropriate re agents in the back half for me tals collection. Analysis was conducted by Inductively Coupled Argon Plasma Spectrometry (ICAP). Figure 3-1 is a3-3 schematic of the sampling train. Three 2-hour test runs were completed at the Furnace No. 1 main and taphole baghouse exhausts in c onjunction with the particulate sampling.

3.8 Visible Emissions

EPA Method 9, “Visual Determination of th e Opacity of Emissions from Stationary
Sources,” was used to measure visible emissions from the building roof monitor. One 60-minute

test run was conducted at each test site. Opacity readings were recorded every 15 seconds by a

certified observer.3-4Figure 3-1. EPA Method 5/29 Sampling Train3-5Figure 3-2. EPA Method 26 Sampling Train4-1 SECTION 4

PROCESS DESCRIPTION/SAMPLING LOCATIONS

Eramet Marietta, Inc., operates a facility in Marietta, Ohio. The No. 12 Furnace and No. 1 Furnace were tested at the facility as part of this test program. The No. 12 Furnace, a submerged arc furnace, is rated at 22 MW and util izes two wet scrubbers to control primary and secondary emissions. The scrubbe rs operate simultaneously and exhaust through a single stack. The No. 1 Furnace, a manganese electric ar c furnace, is rated at 30MW and a maximum production rate of 35 tons per hour. A baghouse c ontrols emissions from the furnace tap hole, and a new baghouse, which replaced an existing scr ubber, controls emissions from the furnace. Table 4-1 presents a summary of the samp ling site location. Fi gure 4-1 is a general schematic of the testing locations.4-2 B A

C

Direction of Flow

Figure 4-1. Sampling Locations

TABLE 4-1. SAMPLING LOCATION PARAMETERS Distance from Nearest Disturbance

Stack Identification Stack I.D., Inches

(C) Upstream, Inches

(A) Downstream, Inches

(B) No. of Sampling Points Required, Total

Furnace No. 12 Scrubber 95.35” >194.0 368.0 24

Furnace No. 1 Main Baghouse 120” 480.0” 480.0” 24

Furnace No. 1 Taphole Baghouse 60”x51” >190.0 95.0 245-1 SECTION 5

QUALITY ASSURANCE AND QUALITY CONTROL

5.1 Field Sampling

The field sampling quality assurance for this project included the use of calibrated source sampling equipment, reference test methods, and traceability protocols for recording and calculating data. The analyti cal quality assurance included use of validated analytical procedures, calibration of analytic al instruments, and analysis of control samples and blanks. The calibration and quality control procedures used for this test program are described in the following subsection, and included in Appendix E of this report.

5.2 Calibration Procedures and Frequency

All manual stack gas sampling equipment was calibrated before the test program in accordance with the procedures outlined in the Quality Assurance Handbook for Air Pollution Measurement Systems, Volume III , EPA-600/4-72-027B. Summarized in Table 5-1 are the stack gas sampling equipment calibrations that were pe rformed in preparation for this project. The

meter boxes were re-calibrated after the test.

Listed in Table 5-2 are the additional cal ibration checks that we re performed on the sampling equipment on site, just prior to the test ing, to ensure that equipment was not damaged during transport. Calibration checks were conduct ed before and after each test run. Additional

calibration information is included in Appendix E of this report.5-2 TABLE 5-1. FIELD EQ UIPMENT CALIBRATIONS a

Equipment Calibrated Against Allowable Error

Method 5 meter box Reference test meter Y + 0.02 Y Δ H@ + 0.20 Δ H@ post-test Y + 0.05 Y Pitot tube Geometric specifications See EPA Method 2

Thermocouple ASTM-3F thermometer + 1.5%
Impinger (or condenser thermometer) ASTM-3F + 2 o F

Dry gas meter thermometer ASTM-3F + 5 o F

Probe nozzles Caliper High-low + 0.004 in.

Barometer NBS traceable barometer + 0.1 in.Hg

a As recommended in the Quality Assurance Handbook for Air Pollution Measurement Systems: Volume III. Stationary Source-Specific Methods . EPA-600/4-77-027b, August 1977.

TABLE 5-2. FIELD CHECKS OF SAMPLING EQUIPMENT

Equipment Checked Against Allowable Difference

Pitot tube Inspection No visible damage
Thermocouples ASTM 2F or 3F + 1.5%

Probe nozzles Caliper High-low ± 0.004 in.