MEMORANDUM

DATE: April 16, 2015

SUBJECT: Final Rule Mercury Control Options and Impacts for the Ferroalloys Production 

Industry

FROM: Bradley Nelson, EC/R, Inc.

TO: Phil Mulrine, EPA OAQPS/SPPD/MICG

1.0 PURPOSE

The purpose of this memorandum is to present updated mercury (Hg) control impacts for the 

ferroalloy furnace smelting operation based on the revised ferroalloys Risk and Technology 

Review (RTR) emissions data set.

1

 The impacts include the capital and annual control costs, 

emission reductions, and cost effectiveness for each of these Hg control options. 

This analysis supplements the original control option impacts analysis2 prepared in support of

the 2014 supplemental proposed amendments to the national emission standards for hazardous 

air pollutants (NESHAP) for the ferroalloys production source category, published in the Federal 

Register on October 10, 2014 (79 FR 60238).

The Hg emissions estimates have been re-calculated incorporating newly provided test data3,4,5

received prior to and after the publication of the 2014 supplemental proposal. This additional test 

data was received from one of the facilities, and provides additional HAP data for some 

pollutants at previously tested emission sources, including Hg data from each of the operational 

furnaces at a single facility, one furnace producing FerroManganese (FeMn) and the other 

 

1 "Revised Development of the Risk and Technology Review (RTR) Emissions Dataset for the Ferroalloys 

Production Source Category for the 2015 Final Rule ", April 2015, Available in the docket, EPA-HQ-OAR-2010-

0895.

2 "Mercury Control Options and Impacts for the Ferroalloys Production Industry ", August 29, 2014, EPA-HQOAR-2010-0895-0175.

3 "Emission Measurement Summary Report Furnace No. 12 Scrubber PAHs and Mercury Eramet Marietta Inc. 

Marietta, OH", January 2013, Available in the docket, EPA-HQ-OAR-2010-0895.

4 "Polycyclic Aromatic Hydrocarbons and Mercury Emission Summary Report EAF No. 12 Scrubber EAF No. 1 

Baghouse Eramet Marietta Inc. Marietta, OH", November 2014, Available in the docket, EPA-HQ-OAR-2010-0895.

5 "Emission Measurement Summary Report Filterable Particulate Matter Furnaces 1 and 12 Eramet Marietta, Inc. 

Marietta, Ohio", April 2014, Available in the docket, EPA-HQ-OAR-2010-0895.
2

producing SilicoManganese (SiMN), and additional PM data from from one furnace at one of the 

facilities. 

Other than incorporating these additonal emission test data (and their subsequent effects on costs 

and cost effectiveness), the methodology of these analyses are unchanged from those described 

in the previous mercury options & impacts memo.2 Background information, facility summaries, 

mercury control options, and impact calculation methodology are unchanged from the previous 

memorandum, and are not included here. The revised maximum achievable control technology 

(MACT) floor for mercury incorporating the new emissions data is detailed in the revised MACT 

Floor memo, available in the docket.

6

2.0 MERCURY CONTROL OPTION IMPACTS

The impacts of reducing mercury emissions from the furnace smelting process at ferroalloys 

production facilities are based on the costs and emission reductions achieved through the retrofit 

of activated carbon injection (ACI). This section summarizes the estimated capital cost, annual 

cost, and expected mercury emission reduction of retrofitting ACI on the furnaces at Eramet and 

Felman. 

The assumptions and methodology used to estimate these impacts are unchanged from those

detailed in the previous memorandum2, and are not included here. The estimated emissions upon 

which these impact estimates are based have been updated to incorporate the new test data 

described above, and are available in the docket.

1

 

A summary of the impacts for each of the proposed Mercury Control Options is presented in 

Table 2-1. The impacts for Control Option 1 were calculated to be zero. These impacts are 

based on the assumption that the facilities would be able to meet the mercury limits with their 

current furnace controls. 

The impacts for Control Option 2 are based on the installation of ACI on Furnaces 1 and 12 at 

Eramet with operation only during the production of FeMn, and a polishing baghouse on Furnace 

1. The emissions and annual cost for this option are based on the assumption that both furnaces 

produce FeMn 50 percent annually (or 4,380 hours per year).7 The mercury reduction is 

assumed to be 90 percent for the installation of ACI and the polishing baghouse on Furnace 1 at 

Eramet, and 50 percent for installation of ACI and the existing scrubber on Furnace 12 at 

Eramet.

 

6 "Revised MACT Floor Analysis for the Ferroalloys Production Source Category ", April 2015, Available in the 

docket, EPA-HQ-OAR-2010-0895.

7 Cost effectiveness varies significantly with the percentage of FeMn production. As shown in Table 2-2, the 

Option 1 cost effectiveness for Eramet EAF 1 at 50% FeMn production is approximately $13,600/lb Hg. For the 

same furnace producing 100% FeMn, the cost effectiveness would be approximately $7,100/lb Hg.
3

The impacts for Control Option 3 were calculated assuming that all furnaces at Eramet and 

Felman would install and operate ACI during FeMn and SiMn production. Again, the 

assumption is that ACI would be installed downstream from the Furnace 1 baghouse and a 

second polishing baghouse would be added. The emissions and annual cost for this option are 

based on the assumption that both furnaces at Eramet produce 50 percent annually (or 4,380 

hours per year) of FeMn and 50 percent annually of SiMn. The furnaces at Felman are assumed 

to produce SiMn only. The mercury reduction is assumed to be 90 percent for the installation of 

ACI and the polishing baghouse on Furnace 1, and 50 percent for installation of ACI and the 

existing scrubber on Furnace 12 at Eramet. The mercury reduction for ACI installed with the 

existing baghouses at Felman is assumed to be 90 percent.

A breakdown of the individual furnace emission reductions and the capital and annual costs are 

provided in Tables 2-2 and 2-3. The spreadsheet calculation sheet with the control cost 

algorithms is provided in Appendix A for Options 2 and 3.
4

Table 2-1. Summary of the Updated Estimated Emissions Reductions and Cost Impacts 

for the Mercury Control Options Considered for Existing Furnaces

Mercury Control 

Option

Hg Emission 

Reductions 

(lb/yr)

Total Capital 

Cost ($2012)

Total Annual 

Cost ($/year)

Cost 

Effectiveness 

($/lb)

Option 1 – MACT 

Floor for FeMn and 

SiMn Production

0 $0 $0 -----

Option 2 – Beyondthe-floor for FeMn 

Production and 

MACT Floor for 

SiMn Production

263 $30,196,000 $3,362,000 $12,800

Option 3 – Beyondthe-floor for FeMn 

and SiMn Production

329 $41,682,000 $6,873,000 $20,900
5

Table 2-2. Summary of Updated Mercury Cost Effectiveness for Control Option 2

(Beyond-the-floor Mercury Control for Furnaces Producing FeMn Only)

Cost Parameter

Eramet EAF 1 

Cost ($2012)

Eramet EAF 12 

Cost ($2012) Total Eramet 

Cost ($2012)1

Existing FF w/ 

ACI & New 

Polishing FF

ACI w/ Existing 

Venturi Scrubber

Polishing Baghouse Capital Cost2 $14,659,265 $0 $14,659,265

Activated Carbon Injection Capital Cost2 $3,184,766 $3,625,211 $6,809,977

Other Installation Capital Cost3 $7,974,497 $752,231 $8,726,729

Total Capital Cost $25,818,528 $4,377,442 $30,195,970

Direct Annual Cost ($/yr)4 $217,476 $318,449 $535,925

Indirect Annual Cost ($/yr)5 $2,334,447 $491,529 $2,825,976

Total Annual Cost ($/yr) $2,551,924 $809,977 $3,361,901

Mercury Emission Rate (lb/yr) 208.6 151.1 359.7

Mercury Emission Reduction w/ ACI (lb/yr)6 187.7 75.6 263.3

Mercury Cost Effectiveness ($/lb) $13,595 $10,718 $12,769

1 Mercury Control Option 1 includes: Eramet EAF 1 - adding ACI and polishing FF to existing EAF #1 w/ FF, 

Eramet EAF 12 - adding ACI to existing EAF #12 w/ VS. 2 ACI and BH costs developed using capital and annual cost algorithms from the IPM Model - Revisions to Cost 

and Performance for APC Technologies, Mercury Control Cost Development Methodology, March 2011.

3 Other installation capital costs include: engineering and construction management, construction labor 

adjustment, and contractor profit & fees.

4 Direct annual costs include: operating labor, administrative and supervisory labor, maintenance labor and 

materials, activated carbon, and non-hazardous dust disposal for Eramet. 5 Indirect annual costs include: overhead, property tax, insurance, administration, and capital recovery (20 

years @ 7% interest).

6 Assumes 90% mercury reduction for FF and 50% mercury reduction with a VS.
Table 2-3. Summary of Updated Mercury Cost Effectiveness for Control Option 3

(Beyond-the-floor Mercury Control for Furnaces Producing FeMn and SiMn)

Felman Furnace 2 

Cost ($2012)

Felman Furnace 5 

Cost ($2012)

Felman Furnace 7 

Cost ($2012)

Eramet EAF 1 Cost 

($2012)

Eramet EAF 12 

Cost ($2012)

ACI w/ Existing 

Fabric Filter

ACI w/ Existing 

Fabric Filter

ACI w/ Existing 

Fabric Filter

Existing FF w/ ACI 

& New Polishing FF

ACI w/ Existing 

Venturi Scrubber

Polishing Baghouse Capital Cost2 $0 $0 $0 $0 $14,659,265 $0 $14,659,265

Activated Carbon Injection Capital Cost2 $3,320,988 $3,069,015 $3,122,161 $9,512,164 $3,184,766 $3,625,211 $6,809,977

Other Installation Capital Cost3 $689,105 $636,821 $647,848 $1,973,774 $7,974,497 $752,231 $8,726,729

Total Capital Cost $4,010,093 $3,705,836 $3,770,009 $11,485,937 $25,818,528 $4,377,442 $30,195,970

Direct Annual Cost ($/yr)4 $653,379 $513,562 $737,893 $1,904,834 $314,092 $534,324 $848,417

Indirect Annual Cost ($/yr)5 $451,132 $417,674 $424,731 $1,293,537 $2,334,447 $491,529 $2,825,976

Total Annual Cost ($/yr) $1,104,511 $931,236 $1,162,624 $3,198,371 $2,648,540 $1,025,853 $3,674,393

Mercury Emission Rate (lb/yr)6 21.5 4.39 8.93 34.8 238.3 165.8 404.1

Mercury Emission Reduction w/ ACI (lb/yr)7 19.3 3.95 8.03 31.3 214.4 82.9 297.3

Mercury Cost Effectiveness ($/lb) $57,143 $235,763 $144,717 $102,143 $12,351 $12,373 $12,357

7

 Assumes 90% mercury reduction for FF and 50% mercury reduction with a VS.

5

 Indirect annual costs include: overhead, property tax, insurance, administration, and capital recovery (20 years @ 7% interest).

Total Eramet Cost 

($2012)1

6

 Eramet mercury enhanced capture emissions based on 50/50 production of FeMn and SiMn. Felman mercury enhanced capture emissions based on 100% production of SiMn.

Total Felman Cost 

($2012)1

1

 Mercury Control Option 1 includes: Eramet EAF 1 - adding ACI and polishing FF to existing EAF #1 w/ FF, Eramet EAF 12 - adding ACI to existing EAF #12 w/ VS.

Cost Parameter

2

 ACI and BH costs developed using capital and annual cost algorithms from the IPM Model - Revisions to Cost and Performance for APC Technologies, Mercury Control Cost Development 

Methodology, March 2011.

3

 Other installation capital costs include: engineering and construction management, construction labor adjustment, and contractor profit & fees.

4

 Direct annual costs include: operating labor, administrative and supervisory labor, maintenance labor and materials, activated carbon, and non-hazardous dust disposal.
Appendix A

ACI Control Cost Spreadsheet Calculation Sheets for the Mercury Control Options
Activated Carbon Injection Model Costs1

 - Option 2

Ferroalloys Furnace Eramet EAF 1

Control Device

Existing FF w/ ACI & 

New Polishing FF

Annual Operating Hours, hr/yr (H) 8760

Exhaust Gas Flow Rate, acfm (Qa) 243,217

Exhaust Gas Flow Rate, dscfm (Q) 187,152

Operating Labor Rate, $/hr (LR) $60.00 Labor rates listed in Eramet Comments

Activated Carbon Cost, $/lb (ACC) $0.85 Cost for from IPM ($1700/Ton, 2012 dollars)

Dust Disposal Cost, $/Ton (DDC, Non-Hazardous) $30.00 Cost based on email from Chuck French 11/05/2013, FW: Question regarding costs of diposing ACI mercury control wastes

Dust Disposal Cost, $/Ton (DDC, Hazardous) N/A Dust is assumed not to be hazardous waste

Capital Recovery Factor (CRF) 0.094392926 CRF calculated assuming 20-year equipment life and 7% interest

ACI Adjustment Factor (AF) 0.9 Estimated Hg control efficiency

ACI Injection Rate (lb/MMacf) 2.0

ACI Injection Rate, lb/hr (M) 29.2 Calculated using acfm*60*ACI Injection Rate (lb/MMACF)/1000000

Retrofit Factor 1.2

Outlet PM Emission Rate (Tons/yr) 9.9 PM emission rate during FeMn production

ACI Total Capital Investment, $ (TCI) $3,184,766 Calculated using algorithm1

 1,600,000*Retrofit Factor*ACI Injection Rate (lb/hr) (2012 dollars)

BH Total Capital Investmant, $ (TCI) $14,659,265 Calculated using algorithm1

 530*Retrofit Factor*(acfm^0.81) for 6.0 cloth-to-air ratio (2012 dollars)

Engineering & Construction Management $1,784,403 10% of total TCI w/ baghouse, 5% of TCI w/o baghouse

Labor Adjustment (shift, per diem, etc.) $1,784,403 10% if baghouse addition, else 5% of total TCI

Contractor Profit and Fees $1,784,403 10% if baghouse addition, else 5% of total TCI

Capital, Engineering, and Construction Cost, $ (CECC) $23,197,240

Owners costs $1,159,862 5% of CECC (Owners engineering, management, and procurement activities)

Engineering and construction cycle $1,461,426 6% of CECC + Owners cost for additional baghouse (2-year engineering and construction cycle), 0% for ACI only (1-year engineering and construction cycle)

Total Project Cost, $ (TPC) $25,818,528

Direct Annual Cost, $/yr (DAC)

Operating Labor $16,425 Calculated using (0.25 hr/8-hr shift) x 3 shifts/day x 365 days/yr x LR

Administration & Supervisory Labor $1,385 Calculated using 3% of the sum of the Operating Labor and 40% of the Maintainance

Maintenance & Materials $74,350 Fixed O&M additional maintenance material and labor costs (0.01 for ACI only, 0.005 BH and ACI)

Activated Carbon $217,319

Dust Disposal (Non-Hazardous) $33,313 Calculated using ACI injection rate, 99% capture efficiency, and non-hazardous disposal cost

Indirect Annual Cost, $/yr (IAC)

Overhead $55,296 OAQPS Control Cost Manual - calculated using 0.6 x (Labor + Maintenance)

Property Tax, Insurance, & Admin $594,801 OAQPS Control Cost Manual - calculated using 0.04 x TCI

Capital Recovery $1,684,350.28 Calculated using CRF x TCI

Total Annual Cost $2,677,240 Sum of DAC + IAC

1

 Sargent & Lundy, IPM Model - Revisions to Cost and Performance for APC Technologies, Mercury Control Cost Development Methodology Final, March 2013
9

Activated Carbon Injection Model Costs1

 - Option 3

Ferroalloys Furnace Felman EAF 2 Felman EAF 5 Felman EAF 7 Eramet EAF 1 Eramet EAF 12

Control Device

ACI w/ Existing 

Fabric Filter

ACI w/ Existing 

Fabric Filter

ACI w/ Existing 

Fabric Filter

Existing FF w/ ACI & 

New Polishing FF

ACI w/ Existing 

Venturi Scrubber

Annual Operating Hours, hr/yr (H) 8760 8760 8760 8760 8760

Exhaust Gas Flow Rate, acfm (Qa) 321,558 190,022 213,065 243,217 230,724 Scrubber outlet flow rates for EAF 12 corrected to 375 F to estimate inlet flow rate

Exhaust Gas Flow Rate, dscfm (Q) 195,393 123,696 142,661 187,152 146,142

Operating Labor Rate, $/hr (LR) $60.00 $60.00 $60.00 $60.00 $60.00 Labor rates listed in Eramet Comments

Activated Carbon Cost, $/lb (ACC) $0.75 $0.75 $0.75 $0.75 $0.75 Cost for from IPM ($1500/Ton, 2009 dollars)

Dust Disposal Cost, $/Ton (DDC, Non-Hazardous) $30.00 $30.00 $30.00 $30.00 $30.00 Cost based on email from Chuck French 11/05/2013, FW: Question regarding costs of diposing ACI mercury control wastes

Dust Disposal Cost, $/Ton (DDC, Hazardous) N/A N/A N/A N/A N/A Dust is assumed not to be hazardous waste

Capital Recovery Factor (CRF) 0.094392926 0.094392926 0.094392926 0.094392926 0.094392926 CRF calculated assuming 20-year equipment life and 7% interest

ACI Adjustment Factor (AF) 0.9 0.9 0.9 0.9 0.5 Estimated Hg control efficiency

ACI Injection Rate (lb/MMacf) 2.0 2.0 2.0 2.0 5.0

ACI Injection Rate, lb/hr (M) 38.6 22.8 25.6 29.2 69.2 Calculated using acfm*60*ACI Injection Rate (lb/MMacf)/1000000

Retrofit Factor 1.2 1.2 1.2 1.2 1.2

Outlet PM Emission Rate (Tons/yr) 14.5 13.2 21.7 8.9 41.1

ACI Total Capital Investment, $ (TCI) $3,320,988 $3,069,015 $3,122,161 $3,184,766 $3,625,211 Calculated using algorithm1

 1,600,000*Retrofit Factor*ACI Injection Rate (lb/hr) (2012 dollars)

BH Total Capital Investmant, $ (TCI) $0 $0 $0 $14,659,265 $0 Calculated using algorithm1 530*Retrofit Factor*(acfm^0.81) for 6.0 cloth-to-air ratio (2012 dollars)

Engineering & Construction Management $166,049 $153,451 $156,108 $1,784,403 $181,261 10% of total TCI w/ baghouse, 5% of TCI w/o baghouse

Labor Adjustment (shift, per diem, etc.) $166,049 $153,451 $156,108 $1,784,403 $181,261 10% if baghouse addition, else 5% of total TCI

Contractor Profit and Fees $166,049 $153,451 $156,108 $1,784,403 $181,261 10% if baghouse addition, else 5% of total TCI

Capital, Engineering, and Construction Cost, $ (CECC) $3,819,136 $3,529,367 $3,590,485 $23,197,240 $4,168,993

Owners costs $190,957 $176,468 $179,524 $1,159,862 $208,450 5% of CECC (Owners engineering, management, and procurement activities)

Engineering and construction cycle $0 $0 $0 $1,461,426 $0 6% of CECC + Owners cost for additional baghouse (2-year engineering and construction cycle), 0% for ACI only (1-year engineering and construction cycle)

Total Project Cost, $ (TPC) $4,010,093 $3,705,836 $3,770,009 $25,818,528 $4,377,442

Direct Annual Cost, $/yr (DAC)

Operating Labor $16,425 $16,425 $16,425 $16,425 $16,425 Calculated using (0.25 hr/8-hr shift) x 3 shifts/day x 365 days/yr x LR

Administration & Supervisory Labor $825 $800 $805 $1,385 $855 Calculated using 3% of the sum of the Operating Labor and 40% of the Maintainance

Maintenance & Materials $27,675 $25,575 $26,018 $74,350 $30,210 Fixed O&M additional maintenance material and labor costs (0.01 for ACI only, 0.005 BH and ACI)

Activated Carbon $253,516 $149,813 $167,980 $191,752 $454,757

Dust Disposal (Non-Hazardous) $132,762 $119,050 $194,378 $30,180 $32,077 Calculated using ACI injection rate, 99% capture efficiency, and non-hazardous disposal cost

Additional ore for loss of BH dust $222,176 $201,899 $332,287 $0 $0 $756,361

Indirect Annual Cost, $/yr (IAC)

Overhead $26,955 $25,680 $25,949 $55,296 $28,494 OAQPS Control Cost Manual - calculated using 0.6 x (Labor + Maintenance)

Property Tax, Insurance, & Admin $110,700 $102,300 $104,072 $594,801 $120,840 OAQPS Control Cost Manual - calculated using 0.04 x TCI

Capital Recovery $313,478 $289,693 $294,710 $1,684,350 $342,194.27 Calculated using CRF x TCI

Total Annual Cost $882,336 $729,337 $830,337 $2,648,540 $1,025,853 Sum of DAC + IAC

1

 Sargent & Lundy, IPM Model - Revisions to Cost and Performance for APC Technologies, Mercury Control Cost Development Methodology Final, March 2013