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MEMORANDUM

Date: July 30, 2012

Subject: EPA – EMI – Felman Corporation Teleconference Summary (June 25, 2012)

From: Beth Friedman, EC/R Incorporated

To: Conrad Chin, OAQPS/SPPD/MMG (D243-02)

I. Introduction:

A conference call was held on June 25, 2012 to discuss the status and content of the stack test 

protocols being developed by Eramat Marietta (EMI) and Felman Production for planned 

stack testing in July. EMI and Felman are coordinating their upcoming particulate matter 

compliance tests in order to obtain additional data on manganese, mercury, polycyclic 

aromatic hydrocarbons (PAHs), formaldehyde and hydrochloric acid (HCl). The plants are 

collecting this information on a voluntary basis with the intent of providing data for EPA to 

consider in setting stack limits for the final Ferroalloys Production National Emissions 

Standards for Hazardous Air Pollutants (NESHAP). This memo provides an overview of the 

issues discussed.

II. Participants:

Eramet Marietta: John Hughes, Jeff McKinney

Felman Production, Inc.: John Konrady, Rich Lunn, Shawn McCutchan, Robert Powell

TEST, Inc.: Paul Chinuntdet

Beveridge & Diamond: Amy Lincoln

Jones Day: John Rego

Policy Navigation Group: Troy Hillier

EPA/OAQPS: Colin Boswell, Conrad Chin, Jason Dewees, Chuck French, Steve Fruh, 

Robin Segall, Peter Westlin

EC/R Incorporated (Contractor for EPA): Beth Friedman, Brad Nelson

III.Summary of Discussions:

The following topics were discussed.

 Felman and EMI are coordinating development of their test protocols to ensure 

they collect comparable data. EMI submitted a test proposal from their test 
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contractor (Environmental Quality Management, Inc.) and Felman submitted a 

test proposal from their test contractor (TEST, Inc.) for EPA’s review. 

 EPA notified the plants that the promulgation deadline has been extended to 

September 14, 2012. 

 EMI’s plan reflects their concern that the mercury and PAH testing methods 

suggested by EPA will not achieve a sufficient detection limit based on a 2-hour 

run time. In the future they want to evaluate different methods for mercury when 

they perform additional testing with an activated carbon injection system 

installed. They also believe they should evaluate continuous emissions 

monitoring systems and Fourier transform infrared spectroscopy (FTIR). EMI 

added that they do not want to invest more resources in a method that did not 

work well in the past. They added that they believe that most of the mercury and 

PAH is gassing off when the furnace is charged. EPA still recommends using 

Method 30B for mercury testing.

 Felman is interested in comparing the results between furnaces 

 Both plants propose to only conduct one test run for some pollutants (EMI: 3 runs 

for particulate matter and HCl. Felman: 3 runs for particulate matter). EPA 

strongly urged the plants to consider performing 3 runs for the tested pollutants to 

result in a complete performance test. EPA noted that if the plants need to 

prioritize their testing resources, EPA would be most interested in obtaining 

additional mercury, manganese, and PAHs data. 

 EPA clarified that the test protocol should specify both EPA Method 23 and 

CARB Method 429 for sampling PAHs.

Attachments:

Letter to John Hughes, Eramet Marietta, Inc., from Tom Gerstle, Environmental Quality 

Management. June 5, 2012. Proposed Test Plan.

Letter to Richard Lunn, Felman Production, Inc. from Paul Chinuntdet, TEST, Inc. June 

19, 2012. Proposed Test Plan.