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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 , 2 012 to discuss the status and content of the stack test protocol s 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 s etting 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 Hug h es, Jeff McKinney
Felman Product ion, 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, St eve 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 E MI are coordinating development of their test protocols to ensure they colle ct comparable data. EMI submitted a test proposal from their test2 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 promulg ation 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 eval uate 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 pollu t ants to result in a complete performance test. EPA noted that if the plants need to prioritize the ir 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. P roposed Test Plan.

Letter to Richard Lunn, Felman Production, Inc. from Paul Chinuntdet, TEST, Inc. June 19, 2012. Proposed Test Plan.