Document XzR0zEpoN8oBDGMjRje0Ob5Gg

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 DATE: SUBJECT: FROM: THRU: TO: See date of Section Supervisor signature below CLEAN AIR ACT INSPECTION REPORT Eramet Marietta, Inc., Marietta, Ohio 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: November 9, 2022 EPA Inspector(s): 1. Karyn DeFranco, Environmental Engineer 2. Patrick Miller, Environmental Engineer 3. Meaghan Pashen, Environmental Engineer Other Attendees: 1. 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 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: 1:15 PM On-site Departure Time: 5:15 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. 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 pet coke, coal, 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 TOUR INFORMATION EPA Tour of the Facility: Yes EPA observed tapping, slag raking, and casting operations and the process fugitive emission capture system at #12 Furnace. Eramet added metal around the duct opening above the tap hole to aid in the capture of process fugitive emissions at #12 Furnace. EPA observed visible emissions rising to the roof monitor during portions of tapping and throughout slag raking and casting at #12 Furnace. Some particulate generated during these operations are pulled into the ductwork and ultimately controlled by the wet scrubber. While touring the facility, EPA observed visible emissions from the #12 Furnace roof monitor from outside the C2F building. EPA was told the visible emissions were from tapping #12 Furnace into an empty ladle which is a worst-case scenario for emissions during tapping. EPA also observed visible emissions from the wet scrubber stack for #12 Furnace. EPA was told that operational changes are made when the visible emissions from the wet scrubber stack turn yellow to mitigate excess emissions. EPA toured and observed the outdoor storage piles of raw materials and final products. EPA observed the MOR during the refining process and #1 Furnace. #1 Furnace was operating but tapping and slag raking were not observed due to the timing of the tour. Data Collected and Observations: Onsite visible emission observations were conducted in accordance with EPA Alternative Method 082 on the roof monitor of #12 Furnace on November 9, 2022. Visible emissions were observed from the roof monitor of #12 Furnace during the facility walkthrough. Visible emissions on November 9, 2022, were analyzed in accordance with EPA Alternative Method 082. The highest 6-minute average opacity was 58% at the roof monitor of #12 Furnace. Photos and/or Videos: were taken during the inspection. Field Measurements: were taken during this inspection. x Visible emission observations were conducted on November 9, 2022. See Appendix B for opacity reports. RECORDS REQUEST EPA requested the following information and records: x Start and stop times of tapping, slag raking, and casting during visible emission observations of the #12 Furnace Roof Monitor on 11/9/22 (starting around 4:20 pm); x Confirm the dates of the recent #1 Furnace outage 10/24-11/6; x Confirm the date when the bags were changed out of the #1 Furnace main baghouse; x 8/1/22-Present Final Product Storage Pile (F002) Load-Out and Wind Erosion Inspection Records required by Permit P0091078 Condition C.2.d.2; and Page 3 of 5 x 8/1/22-Present Daily Pressure Drop Readings and any investigation reports if the pressure drop deviated from the pressure drop range for the Baghouses that control the Crushers (P917) required by Permit P0091078 Condition C.5.d.3. CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Requested documents: 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 MILLER Date: 2023.01.06 14:39:11 -06'00' Report Author: _________________________________ Section Supervisor: Brian Digitally signed by Brian Dickens Dickens Date: 2023.01.05 16:22:45 -06'00' __________________________________ Page 4 of 5 Facility Name: Eramet Marietta Inc. Facility Location: 16705 Ohio State Route 7, Marietta, Ohio 45750 Date of Inspection: November 9, 2022 APPENDICES AND ATTACHMENTS 1. Digital Image Log 2. Opacity Reports for November 9, 2022 Page 5 of 5 Facility Name: Eramet Marietta Inc. Facility Location: 16705 Ohio State Route 7, Marietta, Ohio 45750 Date of Inspection: November 9, 2022 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: Meaghan Pashen 2. Archival Record Location: Enf_Eramet Marietta Inc_OH_21/Enf_Eramet Marietta Inc_OH_23_Inspection/Digital Images Image No. File Name 1 IMG_3608.JPG 2 IMG_3609.JPG 3 IMG_3610.JPG 4 IMG_3611.JPG 5 IMG_3612.JPG 6 IMG_3613.JPG 7 IMG_3614.JPG 8 IMG_3615.JPG 9 IMG_3616.JPG 10 IMG_3617.JPG 11 IMG_3618.JPG 12 IMG_3619.JPG 13 IMG_3620.JPG 14 IMG_3621.JPG 15 IMG_3622.JPG 16 IMG_3623.JPG 17 IMG_3624.JPG 18 IMG_3625.JPG 19 IMG_3626.JPG 20 IMG_3627.JPG 21 IMG_3628.JPG 22 IMG_3629.JPG 23 IMG_3630.JPG Date and Time (Eastern) Lat. and Long. Appendices Page 1 of 4 Description of Image Visible emissions during #12 Furnace tapping Visible emissions during #12 Furnace tapping Visible emissions during #12 Furnace tapping Visible emissions during #12 Furnace tapping Visible emissions during #12 Furnace tapping Visible emissions during #12 Furnace tapping Visible emissions during #12 Furnace tapping Visible emissions during #12 Furnace tapping Visible emissions during #12 Furnace tapping Visible emissions during #12 Furnace tapping Visible emissions during #12 Furnace tapping Visible emissions during #12 Furnace tapping Visible emissions during #12 Furnace pouring Visible emissions during #12 Furnace tapping #12 Furnace pouring #12 Furnace pouring #12 Furnace pouring #12 Furnace pouring Visible emissions during #12 Furnace tapping #12 Furnace slag raking #12 Furnace slag raking Visible emissions during #12 Furnace slag raking Visible emissions during #12 Furnace slag raking Facility Name: Eramet Marietta Inc. Facility Location: 16705 Ohio State Route 7, Marietta, Ohio 45750 Date of Inspection: November 9, 2022 24 IMG_3631.JPG 25 IMG_3632.JPG 26 IMG_3633.JPG 27 IMG_3634.JPG 28 IMG_3635.JPG 29 IMG_3636.JPG 30 IMG_3637.JPG 31 IMG_3638.JPG 32 IMG_3639.JPG 33 IMG_3640.JPG 34 IMG_3641.JPG 35 MVI_3642.JPG 36 MVI_3643.JPG 37 IMG_3644.JPG 38 IMG_3645.JPG 39 IMG_3646.JPG 40 IMG_3647.JPG 41 IMG_3648.JPG 42 IMG_3649.JPG 43 IMG_3650.JPG 44 MVI_3651.JPG 45 IMG_3652.JPG 46 IMG_3653.JPG 47 IMG_3654.JPG Appendices Page 2 of 4 Visible emissions during #12 Furnace slag raking Visible emissions during #12 Furnace slag raking Visible emissions during #12 Furnace slag raking Visible emissions during #12 Furnace slag raking Visible emissions during #12 Furnace slag raking Visible emissions during #12 Furnace slag raking Visible emissions during #12 Furnace slag raking Visible emissions during #12 Furnace slag raking Visible emissions during #12 Furnace slag raking Visible emissions during #12 Furnace slag raking Visible emissions during #12 Furnace slag raking Video of visible emissions during #12 Furnace casting Video of visible emissions during #12 Furnace casting and ductwork Visible emissions during #12 Furnace casting and ductwork Visible emissions during #12 Furnace casting and ductwork Visible emissions during #12 Furnace casting and ductwork Visible emissions during #12 Furnace casting and ductwork Visible emissions during #12 Furnace casting Visible emissions during #12 Furnace casting Visible emissions during #12 Furnace casting Video of visible emissions during #12 Furnace casting Visible emissions during #12 Furnace casting Visible emissions during #12 Furnace casting Visible emissions during #12 Furnace casting Facility Name: Eramet Marietta Inc. Facility Location: 16705 Ohio State Route 7, Marietta, Ohio 45750 Date of Inspection: November 9, 2022 48 IMG_3655.JPG 49 IMG_3656.JPG 50 IMG_3657.JPG 51 IMG_3658.JPG 52 IMG_3659.JPG 53 IMG_3660.JPG 54 IMG_3661.JPG 55 IMG_3662.JPG 56 IMG_3663.JPG 57 IMG_3664.JPG 58 IMG_3665.JPG 59 IMG_3666.JPG Visible emissions during #12 Furnace casting Visible emissions during #12 Furnace casting Visible emissions during #12 Furnace casting Visible emissions during #12 Furnace casting #12 Furnace operations #12 Furnace operations #12 Furnace operations Visible emissions from #12 Furnace stack Visible emissions from #12 Furnace stack Visible emissions at #12 Furnace roof monitor Visible emissions at #12 Furnace roof monitor Visible emissions at #12 Furnace roof monitor Appendices Page 3 of 4 Facility Name: Eramet Marietta Inc. Facility Location: 16705 Ohio State Route 7, Marietta, Ohio 45750 Date of Inspection: November 9, 2022 APPENDIX B: OPACITY REPORTS FOR NOVEMBER 9, 2022 Appendices Page 4 of 4