Document LeXrEMOG47N9Vy61vdV88Lo5

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 DATE: SUBJECT: FROM: THRU: TO: See date of Section Chief signature below CLEAN AIR ACT INSPECTION REPORT Eramet Marietta, Inc., Marietta, Ohio Shilpa Patel, Environmental Engineer AECAB (MN/OH) Patrick Miller, Environmental Engineer AECAB (MN/OH) Brian Dickens, Section Chief AECAB (MN/OH) File BASIC INFORMATION Facility Name: Eramet Marietta, Inc. (Eramet) Facility Location: 16705 Ohio State Route 7, Marietta, Ohio 45750 Date of Inspection: August 17-19, 2021 EPA Inspector(s): 1. Shilpa Patel, Environmental Engineer 2. Patrick Miller, Environmental Engineer Other Attendees: 1. Mitch Gillian, Plant Manager 2. Mark Carpenter, EHS Engineer Contact Email Address: mark.carpenter@eramet.com Purpose of Inspection: Determine compliance with 40 C.F.R. Part 63 Subpart XXX, including opacity limits on visible emissions from roof monitors by conducting offsite visible emission observations Facility Type: Ferromanganese and silicomanganese production facility Regulations Central to Inspection: 40 C.F.R 63.1620 - 63.1679, including 63.1623(b)(3) On-site Arrival Time: 9:15 AM On-site Departure Time: 1:45 PM Inspection Type: Unannounced Inspection Announced Inspection OPENING CONFERENCE Presented Credentials Stated authority and purpose of inspection Provided Small Business Resource Information Sheet Small Business Resource Information Sheet not provided. Reason: Not a Small Business Provided CBI warning to facility The following information was obtained verbally from Mr. Gillian or Mr. Carpenter unless otherwise noted. Process Description: Eramet produces silicomanganese and ferromanganese from ore in two electric arc furnaces (EAFs) and the metal oxygen refining (MOR) process furnace. The ore is sorted and stored outside in piles. The ore contains about 48 percent manganese. Other raw materials include carbon, silicon, and iron. Furnace #1 produces silicomanganese and primary emissions from melting are controlled by a newly constructed baghouse. Furnace #12 produces ferromanganese and primary emissions from melting are controlled by a venturi scrubber. A third EAF, Furnace #18, is inoperable after suffering an upset that damaged the furnace. Each furnace uses three electrodes to melt the ore. Metal and slag are formed in the furnace as the ore melts. The furnace is tapped and the molten metal and slag are cast into ladles through a runner. Furnace #1 has a hood over the tap hole and the ladle to help capture emissions during tapping and route them to the new baghouse. Furnace #12 does not have hoods over the tap hole and ladle but there is duct work near these areas. Slag, which is less dense and floats on top of the metal, overflows from the main transfer ladle into another smaller ladle. Once the transfer ladle is full, the furnace is plugged to end casting. The transfer ladle is then positioned at the next stage where slag is skimmed off the top surface of the ladle. The transfer ladle is then brought to the MOR for refining. Once the target chemistry is reached, the metal is cast in fines on the ground. Emissions from the casting process are controlled by side draft hoods routed to the MOR baghouse. Once solidified and cooled, the metal is crushed and processed. Any smaller pieces and dust from baghouses can be reused in the process or sold as a product. Page 2 of 5 Staff Interview: Tap to tap time is 2 hours On April 28, 2017, EPA's Office of Air Quality Planning and Standards granted a variance to Eramet to use Method 9 versus Alternative Method 082 for opacity readings on the roof monitors. The variance expires June 20, 2023. TOUR INFORMATION EPA Tour of the Facility: Yes EPA was onsite and toured the Facility on August 18, 2021. We observed the following operations: Furnace #12 during tapping and pouring into the ladle and observed the air emission capture system. Furnace 12 does not have hoods over the tap hole and ladle but there are two locations at which the nearby ductwork is open and some particulate generated by the furnace is pulled into the ductwork and ultimately controlled by the scrubber; Liquid metal transfer into the MOR; and Furnace #1 during tapping and pouring into the ladle and observed the air emission capture system. Furnace #1 has hoods over the tap hole and ladle that aid in capturing emissions. Data Collected and Observations: Offsite visible emission observations were conducted in accordance with EPA Alternative Method 082 on the roof monitor of #12 Furnace on August 17 and 19, 2021. Visible emissions were observed from the roof monitor of #12 Furnace in the morning and afternoon on August 17, 2021. Visible emissions on August 17, 2021 were analyzed in accordance with EPA Alternative Method 082. The highest 6-minute average opacity was 67%. Photos and/or Videos: were taken during the inspection. Field Measurements: were taken during this inspection. Visible emission observations were conducted on August 17 and 19, 2021. See Appendix B for opacity reports. RECORDS REVIEW Reviewed examples of Eramet's visible emission observations that were requested; and Reviewed examples of baghouse bypass events and how they are documented for Furnace #1. CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Page 3 of 5 Requested documents: Facility layout; VE Readings for each furnace and MOR for the last six months; Previous four quarters of deviation reports; Description/documentation of upgrades to emission capture and control equipment for NESHAP XXX; and Action Plan for Furnace #12 scrubber. Concerns: EPA discussed concerns the lack of capture of emissions despite ductwork pickups near several locations at Furnace #12 and the potential for visible emissions out of the roof monitor. DIGITAL SIGNATURES PATRICK Digitally signed by PATRICK MILLER Report Author: __M_I_L_L_E__R______D1_6a:_t2e3:_:25_022_-10._51'00_.01'_4 ___________ Section Chief: __________________________________ Page 4 of 5 Facility Name: Eramet Marietta Inc. Facility Location: 16705 Ohio State Route 7, Marietta, Ohio 45750 Date of Inspection: August 19, 2019 APPENDICES AND ATTACHMENTS 1. Digital Image Log 2. Opacity Reports for August 17, 2021 Page 5 of 5 Facility Name: Eramet Marietta Inc. Facility Location: 16705 Ohio State Route 7, Marietta, Ohio 45750 Date of Inspection: August 19, 2021 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: Patrick Miller 2. Archival Record Location: Enf_Eramet Marietta Inc_OH_21/Enf_Eramet Marietta Inc_OH_21_Inspection/Photos Image No. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 File Name IMG_2151.JPG IMG_2152.JPG IMG_2153.JPG IMG_2154.JPG IMG_2155.JPG IMG_2156.JPG IMG_2157.JPG IMG_2158.JPG IMG_2159.JPG IMG_2160.JPG IMG_2161.JPG IMG_2162.JPG IMG_2163.JPG IMG_2164.JPG IMG_2165.JPG IMG_2166.JPG IMG_2167.JPG IMG_2168.JPG IMG_2169.JPG IMG_2170.JPG IMG_2171.JPG IMG_2172.JPG IMG_2173.JPG IMG_2174.JPG IMG_2175.JPG IMG_2176.JPG IMG_2177.JPG Date and Time (Eastern) 2021:08:18 10:38:25 2021:08:18 10:40:26 2021:08:18 10:42:50 2021:08:18 10:43:24 2021:08:18 10:43:49 2021:08:18 10:44:12 2021:08:18 10:47:22 2021:08:18 10:50:52 2021:08:18 10:53:34 2021:08:18 10:55:23 2021:08:18 11:01:46 2021:08:18 11:02:47 2021:08:18 11:03:02 2021:08:18 11:03:08 2021:08:18 11:04:17 2021:08:18 11:05:22 2021:08:18 11:06:02 2021:08:18 11:06:14 2021:08:18 11:30:14 2021:08:18 11:32:19 2021:08:18 11:33:45 2021:08:18 12:33:10 2021:08:18 12:33:25 2021:08:18 12:48:32 2021:08:18 12:48:38 2021:08:18 12:48:53 2021:08:18 12:48:56 Lat. and Long. Description of Image Furnace 12 Spout and Ladle Furnace 12 Tapping Furnace 12 Casting into Ladle Furnace 12 Casting into Ladle with Emissions Furnace 12 Casting into Ladle with Emissions Furnace 12 Casting Hood Above Runner Spout and Side Hood Furnace 12 Casting with Slag Overflowing into Second Ladle Furnace 12 Casting with Slag Overflowing into Second Ladle Furnace 12 Casting with Slag Overflowing into Second Ladle Furnace 12 Plugging Slag skimming of Ladle Slag skimming of Ladle with Side Draft Opening Slag skimming of Ladle with Emissions Slag skimming of Ladle with Emissions Slag skimming of Ladle with Emissions Slag skimming of Ladle with Emissions Slag skimming of Ladle with Emissions Slag skimming of Ladle with Emissions MOR before Transfer MOR during Transfer MOR after Transfer #1 Furnace Baghouse #1 Furnace Baghouse Gas Cooling and Duct Work #1 Furnace Tapping #1 Furnace Tapping with Hood Over Ladle #1 Furnace Tapping #1 Furnace Tapping Appendices Page 1 of 3 Facility Name: Eramet Marietta Inc. Facility Location: 16705 Ohio State Route 7, Marietta, Ohio 45750 Date of Inspection: August 19, 2021 28 IMG_2178.JPG 2021:08:18 12:49:55 29 IMG_2179.JPG 2021:08:18 12:53:54 30 IMG_2180.JPG 2021:08:18 13:06:16 31 IMG_2181.JPG 2021:08:18 13:06:25 32 IMG_2182.JPG 2021:08:18 13:06:34 #1 Furnace Tapping #1 Furnace Tapping Overfilled Ladle with Emissions #1 Furnace Ladle Slag Skimming #1 Furnace Ladle Slag Skimming #1 Furnace Ladle Slag Skimming Appendices Page 2 of 3 Facility Name: Eramet Marietta Inc. Facility Location: 16705 Ohio State Route 7, Marietta, Ohio 45750 Date of Inspection: August 19, 2021 APPENDIX B: OPACITY REPORTS FOR AUGUST 17, 2021 Appendices Page 3 of 3