MEMORANDUM

DATE: October 26, 2011

SUBJECT: Estimated Time Needed to Achieve Compliance with the Proposed Revisions to 

the MACT Standard for Ferroalloy Production Facilities

FROM: Bradley Nelson, EC/R, Inc.

TO: Conrad Chin, EPA OAQPS/SPPD/MMG

1.0 PURPOSE

The purpose of this memorandum is to present a summary of the analysis of time required for the 

ferroalloy production facilities to comply with the proposed revisions to the existing 

Ferromanganese and Silicomanganese Production National Emission Standards for Hazardous 

Air Pollutants (NESHAP) (40 CFR part 63, subpart XXX.

2.0 BACKGROUND

As part of the Risk and Technology Review (RTR) for the Ferroalloy Production source 

category, EPA is proposing revisions to the stack and fugitive emissions standards in the existing 

NESHAP. The NESHAP for Ferromanganese and Silicomanganese Production applies to new 

and existing ferroalloy production facilities that manufacture ferromanganese and/or 

silicomanganese and are major sources of hazardous air pollutants (HAP) emissions or are colocated at major sources of HAP emissions. The NESHAP set emissions standards for the 

following HAP emission sources at a ferroalloy production facility:

Submerged arc furnaces

Metal oxygen refining (MOR) process

Crushing and screening operations

Fugitive dust sources.

The rule contains emission standards that limit particulate matter (PM) emissions, as a surrogate 

for metal HAP, from existing and new or reconstructed emission sources. The limits for the

submerged arc furnaces depend on the product produced and furnace design. The rule also sets 

limits for the air pollution control devices associated with the MOR process and crushing and
screening operations. Currently, there are two facilities in the U.S. that are affected by this rule; 

Eramet Marietta, Inc. and Felman Production Inc. 

3.0 SUMMARY OF PROPOSED REVISIONS

The following section summarizes the proposed revisions to the stack and fugitive emissions 

standards in the existing Ferroalloys Production NESHAP. EPA is proposing these revisions 

under Sections 112(d)(2), 112(d)(3), 112(d)(6), and 112(f)(2) of the Clean Air Act (CAA). As 

outlined in the CAA, sources must comply with any standards proposed under section 112(f)(2)

within 90 days of promulgation. However, the Administrator may grant a waiver allowing up to 

a 2-year compliance period if the Administrator finds that “such period is necessary for the 

installation of controls and that steps will be taken during the period of the waiver to assure that 

the health of persons will be protected from imminent endangerment” (CAA Section 

112(f)(4)(A)-(B)). For existing sources regulated under section 112(d) only, the CAA specifies 

that “the Administrator shall establish a compliance date or dates for each category or 

subcategory of existing sources, which shall provide for compliance as expeditiously as 

practicable, but in no event later than 3 years after the effective date of such standard, ....” In 

this memorandum, the required time for facilities in this source category to comply with the 

proposed revisions to the Ferroalloys Production NESHAP is estimated. The results of the 

analysis are presented in the following sections.

EAF Emission Standards

The EPA is proposing to lower HAP emissions from existing electric arc furnaces (EAF) used 

for ferroalloy production. The proposed revisions require that a capture system must be installed 

and maintained to collect emissions from each EAF (including charging, melting, and tapping 

operations, and emissions from any vent stacks), and to route these emissions to a control device. 

The proposed NESHAP sets standards for particulate matter (PM) as a surrogate for metal HAP, 

mercury (Hg), polycyclic aromatic hydrocarbons (PAH), hydrochloric acid (HCl), and 

formaldehyde. Table 3-1 provides a summary of the current and proposed emission standards 

for EAFs. 
Table 3-1. Current and Proposed Emission Standards for Ferroalloys Production EAFs

HAP Pollutant Current Emission Standard Proposed Emission Standard

Particulate Matter

(Surrogate for Metal HAP)

9.8 kg/hr, for an open furnace 

producing ferromanganese 

with a power input of 22 MW 

or less.

24 mg/dscm, corrected to 2% 

CO2

13.5 kg/hr, for an open 

furnace producing 

ferromanganese with a power 

input of greater than 22 MW.

16.3 kg/hr, for an open 

furnace producing 

silicomanganese with a power 

input of greater than 25 MW.

12.3 kg/hr, for an open 

furnace producing 

silicomanganese with a power 

input of 25 MW or less.

11.2 kg/hr, for a semi-sealed 

furnace producing 

ferromanganese.

Mercury No standard 16 μg/dscm, corrected to 2% 

CO2

Polycyclic Aromatic 

Hydrocarbons No standard 89 μg/dscm, corrected to 2% 

CO2

Hydrochloric Acid No standard 809 μg/dscm, corrected to 2% 

CO2

Formaldehyde No standard 201 μg/dscm, corrected to 2% 

CO2

Process Fugitive Emission Standards

The current standard for process fugitive emissions from the shop building is a limit of 20 

percent opacity for more than one 6-minute period from the shop building. The EPA is 

proposing to lower process fugitive HAP emissions by requiring facilities to install a building 

ventilation system to capture process fugitive emissions from the various operations in the shop 

building and route them to a control device. These operations include tapping, casting, ladle 

treatment, and crushing and screening operations. The PM concentration limit from the control 

device is proposed to be 24 milligrams per dry standard cubic meter (mg/dscm), corrected to 2 
percent carbon dioxide (CO2). The proposed rule also requires that the emissions from the shop 

building not to exceed 10 percent opacity for more than one 6-minute period.

MOR Process Emission Standards

The current standard for the exhaust PM concentration from the MOR process is 69 mg/dscm. 

The EPA is proposing to lower this exhaust concentration standard to 1.5 mg/dscm.

Crushing and Screening Equipment Emission Standards

The EPA is proposing to lower the current PM concentration standard of 69 mg/dscm for all 

equipment associated with crushing and screening to 13 mg/dscm. 

4.0 EXHAUST EMISSION STANDARDS

The proposed revisions to the exhaust emissions standards include the EAF, Local Ventilation, 

MOR Process, and Crushing and Screening Equipment. For the EAF, it is expected that the two 

facilities will be able to meet the proposed PM, HCl, and formaldehyde emission standards using 

their current control technology configuration. However, it is expected that one facility would be 

required to install control devices to meet the Hg and PAH emission standards. It is estimated 

that retrofitting a control device would require 21 to 24 months to be fully operational. This 

includes 2-4 months for evaluation of potential control devices and development of an 

engineering plan to meet the revised emissions limits, evaluation and selection of appropriate 

monitoring technology, and assessment of potential waste disposal issues, 2-4 months for pilot 

testing of potential control device(s), 2-3 months for capital approval, 5-7 months for delivery of 

the control device, 2-4 months for construction and installation of control device and appropriate 

monitoring equipment, and 2-3 months of operation until stack testing is conducted. This facility

would also likely have several other ongoing projects to comply with the proposed revisions to 

the fugitive emissions standards.

5.0 PROCESS FUGITIVE EMISSION STANDARDS

Based on the revisions to the process fugitive emissions standards described in section 3.0, it is 

estimated that the two ferroalloy facilities would be required to install a process fugitive 

emissions capture and control system. It is estimated that installing a process fugitive capture 

and control system would require 21 to 24 months to be fully operational. This includes 2-4 

months for evaluation of potential control devices and development of an engineering plan to 

meet the revised emissions limits and evaluation and selection of appropriate monitoring 

technology, 2-3 months for capital approval, 5-7 months for delivery of the control device, 4-8

months for construction and installation of capture equipment, control device, and appropriate 

monitoring equipment, and 2-3 months of operation until stack testing is conducted.
Facilities have the option of installing ambient manganese monitors to demonstrate compliance

instead of constructing a capture system. If chosen, we estimate that the minimum amount of 

time required to have the necessary monitoring equipment operational would be approximately 

6-8 months. This includes time to draft a monitoring plan, submit that draft plan to the

Administrator for review, revise the monitoring plan as appropriate, and potentially resubmit to

the Administrator for further review. Once an agreement with the permitting authority is

reached, the facilities would need to purchase the appropriate equipment, acquire the necessary

monitors, set up the necessary power supply, set-up and test the equipment, do QA/QC, and

eventually put these compliance monitors in full operation. Once the ambient monitors are

operational, facilities would need to calculate a 10-sample rolling average to demonstrate initial 

compliance with the 0.10 microgram per cubic meter (μg/m3) manganese standard.

6.0 CONCLUSIONS

Based on the analysis, both of the ferroalloy facilities affected by the proposed revisions to the 

existing MACT standards would need 21 to 24 months to complete the projects necessary for 

compliance. With regard to the steps that will be taken during the period to assure that the health 

of persons will be protected from imminent endangerment, it was concluded that the public will 

be protected from imminent endangerment during these extra months because facilities will 

continue to comply with the existing 1999 NESHAP and various state programs which ensure 

emissions are limited. Therefore, a 2-year compliance period is believed to be appropriate for all 

ferroalloy facilities.