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MEMORANDUM

TO: Phil Mulrine, U.S. Environmental Protection Agency, OAQPS/SPPD/MICG

FROM: Brad Nelson, EC/R

DATE: May 21, 2015

SUBJECT: Final Cost Impacts of Control Options Considered for the Ferroalloys Production 

NESHAP to Address Fugitive HAP Emissions

The purpose of this memorandum is to provide a summary of the costs and emissions reductions for the 

fugitive emissions option selected for the National Emissions Standards for Hazardous Air Pollutants 

(NESHAP) for the Ferroalloys Production source category. These impacts were calculated for existing 

units only, as no new facilities are expected to become operational within the next 5 years. The 

methodology used to estimate the costs are provided in the costs memorandum1 for the 2014 

supplemental proposal. The emissions estimates (baseline and enhanced capture) for this source 

category are discussed in the modeling emissions memorandum.

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For the 2014 supplemental proposal, the EPA considered two options for reducing fugitive emissions 

from the ferroalloys process; Option 1 includes enhanced local capture and roofline ventilation for both 

facilities. Option 2 reflects full building enclosure with negative pressure for both facilities. The cost 

estimates for Option 1 contained in Table 1 of this memorandum represent controls likely to be installed 

as a result of facility-specific ventilation analyses, the controls likely to be needed to address risk, and 

existing capture and control systems at the facilities. These estimates were based on cost estimates 

supplied by the facilities after discussions with EPA regarding the standards being considered, and 

incorporating their best estimates of the improvements to fugitive emission capture and control they 

would implement to achieve “enhanced” capture”. All costs are estimated in 2012 dollars. The cost 

estimates for Option 2 are based on revised analyses that were conducted after considering comments, 

information and data submitted by the facilities in response to EPA’s November 2011 proposal.

3,4 The 

emissions reductions associated with the control options presented in this memorandum are calculated as 

the difference between baseline or existing emissions and the estimated emissions with enhanced 

 

1 Memorandum from Jeff Harris and Bradley Nelson, EC/R to Phil Mulrine, U.S. Environmental Protection Agency, 

OAQPS/SPPD/MICG, Cost Impacts of Control Options Considered for the Ferroalloys Production NESHAP to Address 

Fugitive HAP Emissions, August 13, 2014. 2 Memorandum from Bradley Nelson, EC/R Inc. to Phil Mulrine, EPA OAQPS/SPPD/MMG, Revised Development of the 

Risk and Technology Review (RTR) Emissions Dataset for the Ferroalloys Production Source Category for the 2015 Final 

Rule, April 21, 2015.

3 Eramet: "Engineering Review of Proposed Ferroalloy NESHAP Requirements for Eramet Marietta Inc.", EPA-HQ-OAR2010-0895-0106. 4 Felman: "Building Ventilation Costs January 30, 2012", EPA-HQ-OAR-2010-0895-0073.
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fugitive capture and control. These estimated reductions reflect full implementation of the options, 

which will likely need to occur 2 years after promulgation of the final standard. A summary of the costs 

and emission reductions for the 2 options is provided in Table 1. The capital costs range from $14.6 

million to $25.2 million for the enhanced capture option and $28.2 million to $33.2 million for the 

building ventilation option. Annual costs range from $1.85 million to $5.34 million for the enhanced 

capture option, and $5.04 million to $ 13.7 million for the building ventilation option. The average cost 

effectiveness were estimated to be $31,420 per ton of PM removed and $46 per pound of HAP removed 

for the enhanced capture option, and $73,780 per ton of PM removed and $112 per pound of HAP 

removed for the building ventilation option.

PM emissions in this memo refer to total PM. Of the total PM, approximately 21 percent of the 

emissions are estimated to be fine particulate (PM2.5), based on analysis performed by EPA's National 

Environmental Investigation Center of TSP data collected in the Marietta area by Ohio EPA and the 

federal Agency for Toxic Substances and Disease Registry (ATSDR) during 2007-8. Costs and 

emissions reductions for Option 2 for Eramet reflect the assumption that building ventilation will not be 

required for Eramet Building #18, which does not contain an operational furnace.

For the 2014 supplemental proposal, the EPA selected the first option (Option 1) based on enhanced 

local capture and control, including primary and secondary hooding. The option was based on the 

assumption that facilities will achieve about 95% capture of the total fugitive emissions with a 

combination of primary and secondary capture of emissions and ventilation of those emissions to a PM 

control device (either a FF or wet scrubber). This assumption is based on information from ventilation 

experts whom reviewed the plans submitted by the facilities and believe that these enhancements would 

achieve 95 percent reduction. The form of the standard under this option includes an opacity limit of 8 

percent with the use of a digital camera opacity system (DOCS) to comply with the enhanced fugitive 

capture and control systems. The costs for the DOCS were updated based on new cost information from 

the vendor. The one-time cost for setting up the DOCS was estimated to be $4,900 per source, and 

includes the cost of 2 cameras to be set up to read from the single roof vent to cover sun angle during 

different times of the day, mounts, cables, computer and accessories, and training. The annual cost of 

operating the system per source was estimated to be $32,300 for weekly monitoring and $16,300 for 

monthly monitoring. The annual cost includes the cost for the software license, analyzing 90 minutes of 

opacity per monitoring event, and quarterly reporting of results. For comparison, the cost of measuring 

opacity using EPA Method 9 was estimated to be $33,900 per source for weekly monitoring and $8,400 

for monthly monitoring. These costs include labor for measuring and analyzing opacity data and EPA 

Method 9 certification costs.
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Table 1. Summary of the Estimated Costs and Emissions Reductions for Control Options 

Eramet $25,150,000 $5,340,000 147 31 61 $36,660 $174,600 $43

Felman $14,630,000 $1,850,000 83 17 16 $22,250 $106,000 $58

Total $39,780,000 $7,190,000 230 48 77 $31,420 $149,600 $46

Eramet4 $33,150,000 $13,670,000 157 33 65 $87,070 $414,600 $105 $833,000 $3,967,000 $1,172

Felman5 $28,230,000 $5,040,000 97 20 19 $52,190 $248,500 $134 $240,200 $1,144,000 $562

Total $61,380,000 $18,710,000 254 53 84 $73,780 $351,400 $112 $494,800 $2,356,000 $901 1

 Annual cost calculated using 7% interest and a 20-year equipment life.

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 HAP reduction estimates assume Eramet Furnaces #1 and #12 both producing silicomanganese 50% of the time, FeMn 50% of the time.

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 Felman building ventilation cost estimate provided by Felman Production Inc, in their comments on the proposed rule: "Building Ventilation Costs January 30, 2012", EPA-HQ-OAR-2010-0895-0073

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 Eramet Building Ventilation costs provided by Eramet Marietta Inc, in their comments on the proposed rule: "Engineering Review of Proposed Ferroalloy NESHAP Requirements for Eramet Marietta Inc.", 

EPA-HQ-OAR-2010-0895-0106. Emissions and costs reflect the assumption that building ventilation will not be required for Eramet building #18.

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 PM2.5 estimated to be approximately 21% of total PM, based on analysis performed by EPA's National Environmental Investigation Center of TSP data collected in the Marietta area by Ohio EPA and ATSDR 

Incremental Cost Effectiveness

Incremental 

Cost 

Effectiveness 

($/Ton PM)

Incremental 

Cost 

Effectiveness 

($/Ton PM2.5)

Incremental 

Cost 

Effectiveness 

($/lb HAP)

Costs

Facility

Cost 

Effectiveness 

($/Ton PM2.5)

Cost 

Effectiveness 

($/Ton PM)

PM2.5 

Reduction2 

(Tons)

PM 

Reduction 

(Tons)

Total Capital 

Cost ($)

Cost 

Effectiveness 

($/lb HAP)

HAP 

Reduction 

(Tons)3

Total Annual 

Cost1 ($/yr)

Emission Reductions Cost Effectiveness

Option 1: Enhanced 

Fugitive Capture

Option 2: Building 

Ventilation

Compliance Option
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In addition, the baghouse systems used to control emissions from the furnaces are required to be 

outfitted with a bag leak detection system (BLS) to ensure proper operation of the baghouse. The 

capital cost for BLS was estimated to be $269,148 per facility with an annual cost of $219,078. 

The total costs for implementation of the enhanced capture system, DOCS and BLS are provided 

in Table 2. As shown in Table 2, the total capital cost of the enhanced capture option for the 

facilities was estimated to be $40.3 million with an annual cost of $7.7 million.

Table 2. Total Costs for Implementation of the Final Ferroalloys Production NESHAP

Facility Control System Capital Cost ($) Annual Cost ($)

Eramet

Enhanced Capture System $25,150,000 $5,340,000

DOCS1 $14,700 $72,900

BLS $269,100 $219,100

Total Facility Cost $25,433,800 $5,632,000

Felman

Enhanced Capture System $14,630,000 $1,850,000

DOCS1 $4,900 $24,300

BLS $269,100 $219,100

Total Facility Cost $14,904,000 $2,093,400

Total Industry Cost $40,337,800 $7,725,400

1 The annual DOCS costs assume weekly monitoring for 26 weeks and monthly monitoring 

thereafter. Eramet is assumed to need 3 DOCS and Felman is assumed to need 1 DOCS.