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.
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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
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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'
__________________________________
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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
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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
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IMG_3611.JPG
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IMG_3612.JPG
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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
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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
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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