1

MEMORANDUM

TO: Conrad Chin, U.S. Environmental Protection Agency, OAQPS

FROM: Beth Friedman, Jeff Harris, and Brad Nelson, EC/R

DATE: September 19, 2011

SUBJECT: Cost Impacts of the Revised NESHAP for the Ferroalloys Production Source Category

The purpose of this memorandum is to describe the methodology used to estimate the costs and

emissions reductions for the proposed revisions to 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 

results of the impacts analyses are presented for all regulatory options considered in addition to the 

regulatory options that were ultimately chosen for proposal. The development of the emissions estimates

(baseline and for control scenarios) and the maximum achievable control technology (MACT) floors for 

this source category are discussed in other memoranda. The organization of this document is as follows:

1.0 Summary of Cost Estimates and Emissions Reductions for the Regulatory Options

Chosen for Proposal

2.0 Regulatory Options Considered for Proposal

3.0 Methodology for Estimating Control Costs

4.0 Summary of Cost by Facility
2

1.0 SUMMARY OF COST ESTIMATES AND EMISSIONS REDUCTIONS FOR THE 

REGULATORY OPTIONS CHOSEN FOR PROPOSAL

Regulatory options were considered for control of emissions of particulate metal hazardous air 

pollutants (HAP), Mercury (Hg), organic HAP, and Polycyclic Aromatic Hydrocarbons (PAH) from 

furnace stacks, and metal HAP from product sizing stacks and fugitive sources. 

Emissions of each pollutant vary considerably among facilities, and multiple control options are 

available for different groups of pollutants. Because of this, and the limited number of facilities in the 

source category (two), specific regulatory options were assessed for each facility based on both 

technology review and modeled risk. Because of differences in modeled risk and existing controls, some 

options were not considered for all process lines at all facilities. Emissions reductions were estimated 

for each facility based on emissions data received in an information collection request (ICR) sent to the 

industry. 

A brief description of the options selected for the proposed revisions to the NESHAP and the associated 

costs and emissions reductions for each facility in the source category are summarized in Table 1-1. All 

the options considered in this analysis are summarized in Table 1-2, along with the total estimated cost 

for implementing each option. A more detailed description of all the regulatory options considered for 

proposal and their associated cost and emissions reductions estimates are presented in section 2.0 of this 

memorandum. 

The emissions reductions associated with the control options presented in sections 1.0 and 2.0 of this 

memorandum are calculated as the difference between baseline emissions and the estimated emissions 

for each control scenario. Details of the methodology employed to calculate these emissions are 

included in a separate memorandum. All costs are estimated in 2010 dollars. PM emissions in this 

memo refer to total PM. Of the total PM, we assumed approximately 41 percent of the emissions are 

fine particulate (PM2.5). 
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Table 1-1: Summary of the Estimated Costs and Emissions Reductions of Regulatory Options Selected for Proposal

Furnace Fabric 

FIlter Upgrade

Carbon 

Injection

Tap Hood 

Upgrade

Casting 

Capture & 

Control

Building 

Ventilation

Product Sizing 

Fabric Filter 

Upgrade

Facility

PM, Metal 

HAP Hg, PAH, HCHO

PM, Metal 

HAP PM, Metal HAP PM, Metal HAP

PM, Metal 

HAP

$1,413,952 $1,512,930

$756,465

Eramet $2,926,882 227.6 93.3 63.8 $6,647 $16,212 $23

Felman $756,465 398.7 163.5 19.8 $1,897 $4,628 $19

Note: Shaded options were not selected for proposal.

1

 PM2.5 estimated to be approximately 41% of total PM.

2

 ACI costs are not included in these calculations, because it does not affect PM emissions.

Felman

Annual Cost of Control Technology ($)

Eramet

Cost 

Effectiveness 

($/lb HAP)

HAP 

Reduction 

(Tons)

Total Annual 

Cost/Yr ($)

Cost Effectiveness

Facility

Cost 

Effectiveness2 

($/Ton PM2.5)

Cost 

Effectiveness2 

($/Ton PM)

PM2.5 

Reduction1 

(Tons)

PM Reduction 

(Tons)
4

Table 1-2: Summary of the Estimated Costs and Reductions for All Considered Options

Control Option

PM Emission 

Reduction 

(TPY)

PM2.5 

Emission 

Reduction1 

(TPY)

HAP 

Emission 

Reduction 

(TPY)

Capital Cost 

($)

Annual Cost 

($/Yr)

PM Cost 

Effectiveness 

($/Ton)

PM2.5 Cost 

Effectiveness 

($/Ton)

HAP Cost 

Effectiveness 

($/lb) Affected Facilities

Replace Furnace Fabric Filter224.6 10.1 2.95 $13,237,000 $1,543,603 $62,761 $153,075 $261 Eramet

Install ACI for Hg and PAH N/A N/A 3.55 $1,673,836 $1,413,952 N/A N/A $199 Eramet

Improve Tapping Capture 63.2 25.9 6.86 $314,922 $81,792 $1,294 $3,155 $6 Eramet, Felman

Casting Capture & Control 100 40.9 22.9 $4,979,039 $1,592,762 $15,949 $38,900 $35 Eramet, Felman

Install Building Ventilation 626 257 80.4 $9,439,500 $2,269,394 $3,623 $8,838 $14 Eramet, Felman

Improve Product Sizing Baghouse 11.4 4.65 4.66 $59,017 $14,394 $1,268 $3,092 $2 Eramet

1

 PM2.5 estimated to be approximately 41% of total PM.

2

 The emission reductions and annual cost for fabric filter replacement are based on the incremental difference between operation of a scrubber and a fabric filter. The 

cost effectiveness values were calculated using the incremental annual cost and the incremental emission reductions between the scrubber and the fabric filter.
5

2.0 REGULATORY OPTIONS CONSIDERED FOR PROPOSAL

This section provides a detailed description of all regulatory options that were considered for the 

proposed revisions to the Ferroalloys NESHAP and their associated costs and emissions reductions.

2.1 Furnace Stack Emissions – Metal HAP

The selected standard for furnace stack emissions of PM (as a surrogate for metal HAP) is based on a 

technology review, and is designed to ensure that the standard in place will reflect actual current 

performance of existing sources. The selected option is a numeric emission standard with which both 

facilities are already in compliance through current controls. Although it was not selected for proposal, 

costs for a beyond-the-floor regulatory option were estimated, and are presented here.

a) Replacement of Existing Control Device with a New Negative-pressure Fabric Filter

This option was considered for a single furnace at one of the facilities, and represents a scenario of 

reducing PM emissions from the facility by 25 tons per year (and HAP emissions by 3 tons per year) by

replacing a wet scrubber with a large negative pressure fabric filter. The total estimated capital cost for 

the replacement fabric filter is $13.2 million. Annualized capital cost and operational and maintenance 

costs are estimated at $2.5 million or $1.5 million above the current annual cost for the existing 

scrubber, according to the facility ICR response. 

2.2 Furnace Stack Emissions – Hg, PAH, Formaldehyde1

The selected standards for Hg and PAH are numeric emission standards that represent a beyond-thefloor option considered under section 112(d) of the Clean Air Act (the Act). We selected this option 

largely based on the potential risk impacts based on multi-pathway screening and because of the 

potential to reduce the global pool of mercury. We determined that only one of the facilities would be 

required to implement controls for these pollutants2. Estimated costs associated with these controls are 

presented here.

a) Addition of Activated Carbon Injection for Fabric Filters and Scrubbers

This option was selected for two furnaces at one facility, and it represents a scenario of reducing 

emissions of Hg, PAH, and Formaldehyde from the facility by 3.2 tons per year by installation of 

activated carbon injection (ACI). The total estimated capital cost for the retrofit of ACI is $1.7 million. 

Annualized capital cost and operational and maintenance costs are estimated at $1.4 million.

 

1 The Hg and PAH control will also achieve co-control of formaldehyde. We propose to set a MACT floor limit for the Hg 

and PAH pollutants because there are no compelling risks or environmental reasons to control the relatively low levels of 

formaldehyde emitted at a beyond-the-floor level. 

2 Memorandum from Bradley Nelson, EC/R to Conrad Chin, EPA OAQPS/SPPD/MMG, Methodology Used to Estimate 

Mercury Control Costs for the Ferroalloys Production Industry, September 8, 2011.
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2.3 Process Fugitive Emissions – Metal HAP

Several regulatory options were considered for control of fugitive metal HAP emissions, based on 

modeled risk. We focused the options on the individual emissions sources at each plant that appeared to 

be risk drivers. We looked at several options to capture and control these process fugitives ranging from 

local ventilation and control, building ventilation and control, and fenceline monitoring. The regulatory 

options considered for control of process fugitive metal HAP emissions are presented in the following 

section.

a) Improvements to Capture Hoods for Tapping Operations

This option was considered for tapping operations at two furnaces each for both of the facilities, not 

including some hoods which were recently upgraded. This option represents a scenario of reducing 

fugitive PM emissions from the facilities by 63 tons per year (and HAP emissions by 6.9 tons per year) 

by upgrading the capture efficiency of capture hoods for tapping operations. The total estimated capital 

cost for the hood upgrades is approximately $315,000. Annualized capital cost and operational and 

maintenance costs are estimated at approximately $82,000. 

b) Addition of Capture and Control for Casting Operations

Some casting operations are already controlled at each facility. We developed costs to capture and 

control casting emissions the remaining uncontrolled casting operations. The estimated costs were based 

on the assumption that one of the two facilities would require addition of capture and control for two of 

their three casting operations and the second facility would require addition of capture and control for 

one of their three casting operations. This scenario would reduce fugitive PM emissions from the 

facilities by 100 tons per year (and HAP emissions by 23 tons per year) by adding hoods, ductwork, and 

fabric filters to capture and control emissions from currently uncontrolled casting operations. The total 

estimated capital cost for the hoods, ductwork, and fabric filters is approximately $5 million. Annualized 

capital cost and operational and maintenance costs are estimated at approximately $1.6 million. 

c) Building Ventilation

The selected control option involves installation of building ventilation for furnace buildings instead of 

installing fugitive controls on individual tapping and casting operations. This option would require 

installation of ductwork from the roof vents of furnace buildings and a new fabric filter for each 

building. We assumed that one of the two facilities would require building ventilation for two buildings 

and the second facility would require it for a single building. This option would reduce fugitive PM 

emissions from the facilities by 626 tons per year (and HAP emissions by 80.4 tons per year) by adding 

ductwork and fabric filters to capture and control all fugitive emissions from furnace buildings. The total 

estimated capital cost for the ductwork, and fabric filters is approximately $9.4 million. Annualized 

capital cost and operational and maintenance costs are estimated at approximately $2.3 million. 
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d) Fence line Monitoring

This is an alternative regulatory option selected by EPA for proposal in the revised NESHAP for the 

Ferroalloys Production source category. This option allows facilities who may have already 

implemented improved capture and control of tapping and casting emissions to avoid installation of 

building ventilation by performing ambient monitoring for manganese at or near the boundaries of the 

facilities. Estimated emissions reductions would be the same as for the tapping and casting 

capture/control options described previously. Cost estimates were not prepared for this option.

2.4 Product Sizing Operations– Metal HAP – Improvements to Fabric Filters

The selected standard for product sizing stack emissions of PM (as a surrogate for metal HAP) is based 

on a technology review, and is designed to ensure that the standard in place will reflect actual current 

performance of existing sources. The selected option is a numeric emission standard with which both 

facilities are already in compliance through current controls (fabric filters). Although it was not selected 

for proposal, costs for a beyond-the-floor regulatory option were estimated, and are presented here.

a) Upgrade Fabric Filter

For one facility, improvements to product sizing fabric filters were considered, and represent a scenario 

of reducing fugitive PM emissions from the facility by 11 tons per year (and HAP emissions by 4.6 tons 

per year) by upgrading the bag material of fabric filters and conversion to reverse-air cleaning. The total 

estimated capital cost for the fabric filter upgrades is approximately $59,000. Annualized capital cost 

and operational and maintenance costs are estimated at approximately $14,400.

2.4 Metal Oxygen Refining (MOR) Operations– Metal HAP

Metal Oxygen Refining (MOR) is a post-tapping process applied to the molten metal at one of the 

facilities. The selected standard for MOR stack emissions of PM (as a surrogate for metal HAP) is based 

on a technology review, and is designed to ensure that the standard in place will reflect actual current 

performance of existing sources. The selected option is a numeric emission standard with which the 

facility is already in compliance through current controls (a fabric filter). Modeled risk did not indicate 

any need for consideration of a beyond-the-floor control option, so no costs were estimated for this 

emission source.

3.0 METHODOLOGY FOR ESTIMATING CONTROL COSTS

The following sections present the methodologies used to estimate the costs associated with the 

regulatory options considered for proposal in the revised NESHAP for the Ferroalloys Production source 

category.
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3.1 Furnace Stack Emissions – Metal HAP

The primary technologies used to control furnace stack emissions of metal HAP in the Ferroalloys 

source category are fabric filters. One facility uses a wet scrubber to control emissions from one of their 

furnaces. Data from emission tests performed in conjunction with the ICR indicate that baghouses that 

are properly designed, installed, maintained and operated can meet all of the metal HAP stack emissions 

limits selected for proposal in the revised NESHAP.

In order to estimate the capital cost associated with a particular option, we first determined which stacks 

would be required to reduce emissions. Only one stack was considered for any emission reductions, the 

one with a wet scrubber, for which an above-the-floor option was considered – replacing the stack with a 

large negative pressure fabric filter. Because the required fabric filter would be a large, custom model, 

we contacted a vendor who had recently supplied a similar model for installation at a ferroalloys facility 

to obtain assistance in developing a cost estimate. The equipment-only cost supplied by the vendor3 was 

used in conjunction with techniques described in the sixth edition of the EPA Air Pollution Control Cost 

Manual4to estimate total installed capital cost and annual costs. 

Our cost model included installation of the fabric filter and any necessary fans, ductwork, and site work. 

The total installed capital cost of a fabric filter designed for a flow-rate of 180,000 actual cubic feet per 

minute (acfm) was estimated at $13.2 million. We did not consider the downtime associated with 

installation for the unit in our costs. The annualized capital cost and operational and maintenance costs 

are estimated at $2.5 million, via techniques described in the sixth edition of the EPA Air Pollution 

Control Cost Manual. The annualized cost assumes a 20 year life expectancy for the unit and, to be 

consistent with OMB Guidance in Circular A-4, a 7 percent cost of capital as an estimate of the 

annualized capital cost as is commonly done for EPA standards such as this one. All costs for this 

estimate were based on 2010 dollars from a current vendor estimate. The annual cost for operation of the 

scrubber was estimated to be $1.0 million based on information obtained from the ICR submitted by the 

facility. Therefore, the incremental annual cost of replacing the current operating scrubber with a new 

negative pressure fabric filter was estimated to be $1.5 million. The incremental cost was used to 

calculate the cost effectiveness of this control option.

3.2 Furnace Stack Emissions – Hg, PAH, Formaldehyde

EPA believes that the most appropriate technology for control of exhaust emissions of Hg, PAH, and 

formaldehyde for the Ferroalloys Production source category is Activated Carbon Injection (ACI). 

Based on the proposed emission limit, we believe one facility would require installation of controls for 

Hg and PAH on two furnaces. To minimize generation of potentially hazardous waste (from 

contaminated carbon media) and avoid contamination of the saleable byproduct baghouse dust, it was 

 

3 E-mail from Scott Gongaware of Mikropul Inc. to Jeff Harris of EC/R Inc., 8/05/2011.

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assumed that the carbon injection would be performed at the outlet of the negative pressure fabric filter, 

with the carbon media collected by a second, small polishing baghouse. Activated carbon for the furnace 

equipped with a scrubber would be injected prior to the scrubber with no additional particulate control 

required.

Costs for Activated Carbon Injection were estimated using cost equations developed for the Utility 

NESHAP5and information provided by activated carbon vendors6. The calculated equipment costs for 

ACI and fabric filters were used in conjunction with techniques described in the sixth edition of the EPA 

Air Pollution Control Cost Manual to estimate total installed capital cost and annual costs. It was 

estimated that one facility would require installation of ACI on two furnaces, one exhausting to a fabric 

filter with an outlet flow rate of 245,000 acfm, and a second exhausting to a scrubber with an outlet flow 

rate of 184,000 acfm. 

Our cost model included installation of the two activated carbon injection systems, one polishing fabric 

filter, and associated fans, ductwork, and site work. The total installed capital cost was estimated at $1.7

million. The annualized capital cost and operational and maintenance costs were estimated at $1.4 

million. Annualized costs assume a 20 year life expectancy for the units and, to be consistent with OMB 

Guidance in Circular A-4, a 7 percent cost of capital as an estimate of the annualized capital cost as is 

commonly done for EPA standards such as this one. All costs for this estimate were adjusted to 2010 

dollars using Chemical Engineering Plant Cost Indices (CEPCI7). We did not consider the downtime 

associated with installation for the unit in our costs.

3.3 Process Fugitive Emissions – Metal HAP

Fugitive emissions of metal HAP at Ferroalloys Production facilities result from several areas of the 

process. Process fugitive emissions primarily result from furnace leaks and incomplete capture of 

emissions during tapping and casting of product. Furnace upsets can result in release of emissions that 

would normally be contained by negative pressure occurring inside furnace hood. Process fugitive 

emissions can also result from incomplete capture of emissions by tapping hoods, or from casting 

operations, some of which are uncontrolled at both facilities. 

The 1999 NESHAP established a building opacity limit of 20 percent that is measured during the 

required furnace control device performance test. The rule provides an excursion limit of 60 percent 

opacity for one 6-minute period during the performance test. The opacity observation is focused only on 

emissions exiting the shop due solely to operations of any affected submerged arc furnace. In addition, 

blowing taps, poling and oxygen lancing of the tap hole; burndowns associated with electrode 

 

5

Sargent & Lundy, IPM Model - Revisions to Cost and Performance for APC Technologies, Mercury Control Cost 

Development Methodology Final, March, 2011. http://www.epa.gov/airmarkt/progsregs/epa-ipm/docs/append5_3.pdf

6 Contact Report, Daryl Lipscomb, Albemarle, August 22, 2011.

7 CEPCI values employed: 539.1 for 2010, 575.4 for 2008, and 361.3 for 1991.
10

measurements; and maintenance activities associated with submerged arc furnaces and casting 

operations are exempt from the opacity standards specified in §63.1653.

Both facilities employ negative-pressure hoods to collect emissions from tapping operations and direct 

them to a control device. Some casting operations at both facilities capture emissions and direct them to 

a fabric filter, while some casting operations are currently uncontrolled.

Costs were estimated for several options for process fugitive control:

 Improvements to Capture Hoods for Tapping Operations

 Addition of Capture and Control for Casting Operations

 Building Ventilation

Building ventilation was the option selected for proposal, because it was associated with the lowest 

levels of modeled risk, and would capture any emissions that would have been collected by improved 

tapping capture and capture control of casting emissions, in addition to any furnace fugitives which 

escape current controls.

a) Improvements to Capture Hoods for Tapping Operations

Estimated costs for tap hood improvements were assumed to cover only the cost of an improved 

replacement tapping hood on the assumption that sufficient control device capacity is already in 

place, since both facilities already have tapping capture and control in place. Because the capture 

hood equations in EPA’s cost manual were insufficient for large, metal hoods of the type 

required, an equation from a book by Bill Vatavuk (the author of EPA’s Cost Manual) was used8, 

in conjunction with techniques described in the sixth edition of the EPA Air Pollution Control 

Cost Manual9to estimate total installed capital cost and annual costs. 

Our cost model included installation of the replacement tap hood. The total installed capital cost 

of four replacement tapping hoods (two at each facility) was estimated at $315,000. The 

annualized capital cost and operational and maintenance costs are estimated at $81,000 via 

techniques described in the sixth edition of the EPA Air Pollution Control Cost Manual. The 

annualized cost assumes a 20 year life expectancy for the equipment and, to be consistent with 

OMB Guidance in Circular A-4, a 7 percent cost of capital as an estimate of the annualized 

capital cost as is commonly done for EPA standards such as this one. All costs for this estimate 

 

8 Vatavuk, W.M., Estimating Costs of Air Pollution Control. Chelsea, Michigan, Lewis Book Publishers. 1990. Pp. 92

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were adjusted to 2010 dollars using Chemical Engineering Plant Cost Indices (CEPCI10). We did 

not consider the downtime associated with installation for the unit in our costs.

b) Addition of Capture and Control for Casting Operations

Estimated costs for addition of capture and control of casting emissions were assumed to cover 

the cost of hoods and ductwork for capture, plus a fabric filter for control of particulate 

emissions. Because each facility already has installed capture and control for some of their 

casting operations, we estimated that additional capture and control for two casting operations 

would be required at one facility and for one casting operation at the second. Equipment costs for 

the hoods and ductwork, plus a fabric filter a fabric filter designed for a flow-rate of 60,000 

actual cubic feet per minute (acfm) were estimated via techniques described in the sixth edition 

of the EPA Air Pollution Control Cost Manual11 to estimate total installed capital cost and annual 

costs. 

Our cost model included installation of casting hoods, ductwork, and a fabric filter. The total 

installed capital cost to add capture and control for three casting operations was estimated at $5.0

million. The annualized capital cost and operational and maintenance costs are estimated at $1.6 

million via techniques described in the sixth edition of the EPA Air Pollution Control Cost 

Manual. The annualized cost assumes a 20 year life expectancy for the equipment and, to be 

consistent with OMB Guidance in Circular A-4, a 7 percent cost of capital as an estimate of the 

annualized capital cost as is commonly done for EPA standards such as this one. All costs for 

this estimate were adjusted to 2010 dollars using Chemical Engineering Plant Cost Indices 

(CEPCI12). We did not consider the downtime associated with installation for the unit in our 

costs.

c) Building Ventilation

To estimate the cost for the building ventilation fabric filter, EPA contacted a vendor13 who had 

recently supplied a fabric filter to one of the facilities to obtain assistance in developing a cost 

estimate for the installation. The equipment-only cost supplied by the vendor was used in 

conjunction with techniques described in the sixth edition of the EPA Air Pollution Control Cost 

Manual14 to estimate total installed capital cost and annual costs. 

 

10 CEPCI values employed: 539.1 for 2010, 359.2 for 1993, and 342.5 for 1988.

11 http://epa.gov/ttn/catc/products.html#cccinfo

12 CEPCI values employed: 539.1 for 2010, 389.5 for 1998, 359.2 for 1993, and 342.5 for 1988.

13 E-mail from Scott Gongaware of Mikropul Inc. to Jeff Harris of EC/R Inc., 8/05/2011.

14 http://epa.gov/ttn/catc/products.html#cccinfo
12

Our cost model included installation of the baghouse and any necessary fans, ductwork, and site 

work, including extra ductwork for connection to the building roof monitors. The total installed 

capital cost of three fabric filters (two at one facility, one at the second facility) designed for a 

flow-rate of 150,000 actual cubic feet per minute (acfm) was estimated at $9.4 million. The 

annualized capital cost and operational and maintenance costs are estimated at $2.3 million, via 

techniques described in the sixth edition of the EPA Air Pollution Control Cost Manual. The 

annualized cost assumes a 20 year life expectancy for the unit and, to be consistent with OMB 

Guidance in Circular A-4, a 7 percent cost of capital as an estimate of the annualized capital cost

as is commonly done for EPA standards such as this one. All costs for this estimate were based 

on 2010 dollars from a current vendor estimate. We did not consider the downtime associated 

with installation for the unit in our costs.

3.4 Product Sizing Operations– Metal HAP – Improvements to Fabric Filters

The primary technology used to control emissions of particulate metal HAP from product sizing 

operations in the Ferroalloys Production source category are fabric filters. The fabric filters currently in 

use at the facilities are capable of meeting the proposed standard. Although it was not selected for 

proposal, costs for a beyond-the-floor regulatory option were estimated, and are presented here. The 

beyond-the-floor option was based on modeled risk, and only one product sizing line at one facility was 

determined to pose any exiting risk. The option considered was an upgrade to the fabric filter via

improved bag materials and conversion to reverse-air cleaning. The costs associated with this upgrade 

were calculated via techniques described in the sixth edition of the EPA Air Pollution Control Cost 

Manual15 to estimate total installed capital cost and annual costs. At the end, we concluded that the 

potential risk reduction was not meaningful compared to the risk reduction achieved by the building 

ventilation option.

The total installed capital cost of the fabric filter upgrade was estimated at $59,000. The Annualized 

capital cost and operational and maintenance costs are estimated at $14,000, via techniques described in 

the sixth edition of the EPA Air Pollution Control Cost Manual. The annualized cost assumes a 5 year 

life expectancy for the equipment (fabric filter bags) and, to be consistent with OMB Guidance in 

Circular A-4, a 7 percent cost of capital as an estimate of the annualized capital cost as is commonly 

done for EPA standards such as this one. All costs for this estimate were adjusted to 2010 dollars using 

Chemical Engineering Plant Cost Indices (CEPCI16). We did not consider the downtime associated with 

installation for the unit in our costs.

 

15 http://epa.gov/ttn/catc/products.html#cccinfo

16 CEPCI values employed: 539.1 for 2010, and 389.5 for 1998.
13

4.0 SUMMARY OF COST BY FACILITY

Table 4.1 summarizes estimated costs for each facility in the Ferroalloys source category, assuming 

implementation of the emission reduction options selected for proposal.

Table 4-1: Summary Cost Estimates by Facility*

Facility Total Capital Cost Total Annual Cost

Eramet $7,966,836 $2,926,882

Felman $3,146,500 $756,465

Total $11,113,336 $3,683,347

*Overall cost estimates may be overstated since some facilities may be able to comply with the rule under the alternative 

compliance option (i.e., monitoring at facility boundary and improved casting/tapping capture & control) and may not need to 

install building ventilation. If so, actual costs would be significantly lower than shown here.