MEMORANDUM

DATE: October 26

, 201 1

SUBJECT: Estimated Time Needed to Achieve Compl iance 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 a pplies 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 co

located 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 sta ndards 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

li mits for the air pollution control devices associated w ith the MOR process and crushing andscreening operations. Currently, t here 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 complian ce 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 o f persons will be protected from imminent endangerment” (CAA Sectio n 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 Producti on NESHAP is estimated. The results of the analysis are presented in the following sections.

E AF Emission Standards

The EPA is proposing to lower HAP emissions from existing electric arc furnace s ( 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 rou te 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 sum mary 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

P articulate M atter (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%

CO 2 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.

Mercu ry No standard 16 μg/dscm , corrected to 2% CO 2 P olycyclic Aromatic Hydrocarbons No standard 89 μg/dscm , corrected to 2% CO 2 Hydrochloric Acid No standard 809 μg/dscm , corrected to 2% CO 2 Formaldehyde No standard 201 μg/dscm , corrected to 2% CO 2

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 i nstall 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 operatio ns. The PM concentration limit from the control device is proposed to be 24 milligrams per dry standard cubic meter (mg/dscm), corrected to 2percent carbon dioxide (CO 2 ). The proposed rule also requires that the emissions from the shop

building not to e xceed 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 formaldehyd e emission standards using their current control technology configuration. However, it is expected that one facility would be required to install control device s to meet the Hg and PAH emission standards . It is estimated
that retrofitting a control devic e 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 te chnology, 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 contro l device and appropriate monitoring equipment , and 2

- 3 months of operation until stack testing is conducted. Th is facilit y 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 i nstall 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 contr ol 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 constru ction 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/m 3 ) 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 immin ent 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 199 9 NESHAP and various s tate programs which ensure
emissions are limited . Therefore, a 2

- year compliance period is believed to be appropriate for all ferroalloy facilities.