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/R Incorporated Providing Environmental Technical Support Since 1989

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MEMORANDUM 

DATE: March 5, 2013

TO: Conrad Chin, EPA OAQPS/SPPD/MMG

FROM: Jeff Harris, EC/R, Inc.

SUBJECT: Summary of the March 4, 2013, Conference Call with Eramet Marietta 

and the U.S. Environmental Protection Agency regarding Eramet's Testing Plan

I. INTRODUCTION

EPA requested this call with Eramet Marietta to discuss the testing plan submitted by Eramet for 

emission testing to be performed the week of March 4, 2013 in response to EPA's December 21, 

2012 information collection request. 

II. ATTENDEES

The following is a list of participants in the meeting.

U.S. Environmental Protection Agency

Conrad Chin

Chuck French

Steve Fruh

Rochelle Boyd

Colin Boswell

Jason DeWees

Eramet Marietta 

Jeff McKinney, Eramet Marietta

John Hughes, Eramet Marietta

John Rego, Jones Day

Tom Gerstle, Environmental Quality Management, Inc.

EC/R Incorporated

Jeff Harris
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III. SUMMARY OF DISCUSSION

EPA Comments on Test Plan

The discussion began with Eramet's responses to questions raised by EPA regarding the test 

protocol provided by Eramet for the testing to be performed the week of March 4, 1013:

Comment: Manganese must be included in list of analytes for Method 29. The test plan that 

Eramet submitted today lists Mg (magnesium) on page 2-3. We expect that this may be a typo 

(i.e., should be Mn). Nevertheless, the list of metals must include manganese (Mn), and 

magnesium (Mg) is not required.

Response: Yes, this was an error. Testing for Manganese will be performed.

Comment: The tester should conduct field blanks with Method 29 or 26A sampling and CARB 

428 and 429. Refer to the CARB 429 analytical particulars listed in our ICR request. In section 

4 of the test plan there is no mention made of field blank trains being collected for analysis with 

CARB 428 and 429, but we believe that is a requirement of the method, as are field spike 

samples. Field spikes for the other tests are also desirable.

Response: Yes, field blanks will be conducted, including spiking the traps for Method 428-429 

trains.

Comment: For the tapping baghouse, Hg testing using method 30B must be included, as shown 

in the plan received today. However, regarding the spike level (3800 nanograms), we believe 

this would be inappropriate. We suggest a spike level closer to 100 ng for that test, but the tester 

should really do what they judge is best, to support the data, in the field. 3,800 nanograms seems 

like a fairly high spike value for the method 30B (Hg) testing, but determining the correct spike 

value is really up to the tester. We believe that this value should be determined based on the 

criteria in the test method and prior measured values at the source.

Response: Although the method does recommend a spike of 50-150% of expected source 

concentration, testing of the tapping operation has not been previously performed and thus the 

proper level for the spike is unknown. In the absence of further data, they have assumed it is 

similar to the main furnace.

Comment: There should also be discussion of employing Chain of Custody documentation to 

accompany all lab samples from the field.

Response: Yes, chain of custody will be documented. A courier will be employed to handdeliver all samples to the labs.
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Testing Schedule

Next, EPA asked for a brief summary of the expected schedule for the testing. Eramet replied 

that the equipment was currently being unloaded, and testing was expected to begin later in the 

day, and to generally follow the plan laid out in the test plan.

Day 1, Monday 3/4/13: Load in, Begin PM, Metals, Hg

Day 2, Tuesday 3/5/13: Finish PM, Metals, Hg, Start HCl & PCB/Dioxin/Furan

Day 3, Wednesday 3/6/13 Finish HCl, Finish PCB/Dioxin/Furan if possible

Day 4, Thursday 3/7/13 Complete any remaining tests, Load out.

Presence of OH EPA Representative

EPA asked if Ohio EPA would be present for the testing, and if there was a person they could 

contact to discuss it. Eramet stated that Ohio EPA would be present for the compliance testing 

portion, on Tuesday the 5th. The representative will perform periodic monitoring of the 

processes and controls, post-test leak checks, recovery, QA/QC, and observe visible emissions.

EPA requested a conference call be arranged to discuss the possibility of the OH EPA 

representative staying an extra day to witness the PAH testing. The Eramet representatives 

provided a contact for EPA to call for discussion: Dean Ponchak, Air Testing Group Leader, OH 

EPA (740) 380-5297.

Visible Emissions Observation

EPA asked if visible emission testing will be performed. Eramet stated that standard opacity 

testing is a part of the compliance testing being performed on Tuesday. EPA requested that VE 

tests be performed during the other testing as well, if possible. Eramet agreed that it would not 

be difficult to comply with EPA's request, although they would not be performing the VE testing 

on the same schedule as for the compliance tests, since the events being monitored don't always 

last the full hour required for compliance testing.