1

MEMORANDUM

DATE: August 29, 2014

SUBJECT: Revised Technology Review for the Ferroalloys Production Source Category

FROM: Bradley Nelson, EC/R, Inc.

TO: Phil Mulrine, EPA OAQPS/SPPD/MICG

1.0 PURPOSE

The purpose of this memorandum is to summarize the revisions to the technology review to identify 

developments in practices, processes, and control technologies for emissions sources of hazardous 

air pollutants (HAP) from the ferroalloys production source category. This analysis is part of 

EPA’s review efforts in accordance with section 112(d)(6) of the Clean Air Act (CAA). The 

technology review1was re-evaluated using information received after proposal of the amendments 

to the national emission standards for hazardous air pollutants (NESHAP) for the ferroalloys 

production source category published in the Federal Register on November 23, 2011 (76 FR 

72508). 

2.0 BACKGROUND

Under the CAA section 112, EPA must establish technology-based standards for sources of HAP. 

These technology-based standards are often referred to as maximum achievable control technology, 

or MACT, standards. Section 112 also contains provisions requiring EPA to periodically review

these standards. Specifically, paragraph 112(d)(6) states:

(6) REVIEW AND REVISION. – The Administrator shall review, and revise as necessary 

(taking into account developments in practices, processes, and control technologies), 

emissions standards promulgated under this section no less often than every 8 years.

The current National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Ferroalloys 

Production: Ferromanganese and Silicomanganese was promulgated on May 20, 1999 (64 FR 

27450) and codified at 40 CFR part 63, subpart XXX. The 1999 NESHAP (40 CFR 63.1650(a)) 

applies to all new and existing ferroalloys production facilities that manufacture ferromanganese or 

silicomanganese and are major sources or are co-located at major sources of HAP emissions. The 

rule’s product-specific applicability reflected the only known major source at the time of

 

1 Memorandum from Beth Friedman, Jeff Harris, and Brad Nelson, EC/R to Conrad Chin, US EPA, OAQPS, Draft 

Technology Review for the Ferroalloys Production Source Category, October 27, 2011.
2

promulgation. Today, there are two ferroalloys production facilities subject to the MACT rule. No 

new manganese ferroalloys production facilities have been built in over 20 years, and no new 

ferroalloys production facilities are anticipated in the foreseeable future. 

Ferroalloys are alloys of iron in which one or more chemical elements (such as chromium, 

manganese, and silicon) are added into molten metal. Ferroalloys are consumed primarily in iron 

and steel making and are used to produce steel and cast iron products with enhanced or special 

properties. Emissions of HAP are generated from electrometallurgical (furnace) operations (primary 

and tapping), other furnace room operations (ladle treatment and casting), raw material handling 

and product handling, and are primarily emitted from ferroalloys production as process emissions

and process fugitive emissions. There is also potential for some outdoor fugitive dust emissions. 

Process emissions are the exhaust gases from the control devices, primarily from the furnace, metal 

oxygen refining, local ventilation, and crushing operations. The HAP process emissions are 

primarily composed of metals (mostly manganese, arsenic, nickel, lead, mercury and chromium) 

and also include organic compounds (such as PAHs) that result from incomplete combustion of coal 

or coke that is charged to the furnaces as a reducing agent. There are also process metal HAP 

emissions from the product crushing control devices. Process fugitive emissions occur at various 

points during the smelting process (such as during charging and tapping of furnaces and casting) 

and are assumed to be similar in composition to the process emissions. Outdoor fugitive dust 

emissions are believed to be minimal due to required fugitive dust control measures in the 1999 

MACT rule. Nevertheless, some fugitive dust HAP emissions can result due to material handling, 

vehicle traffic, wind erosion from storage piles, and other various activities. 

The MACT rule applies to process and process fugitive emissions from the submerged arc furnaces, 

the metal oxygen refining process, and the product crushing equipment and outdoor fugitive dust 

emissions sources. For process sources, the NESHAP specifies numerical emissions limits for 

particulate matter (as a surrogate for non-mercury metal HAP) from the electric (submerged) arc 

furnaces, depending on furnace type, size, and product being made. Particulate matter emission 

limits (again as a surrogate for non-mercury metal HAP) exist for the metal oxygen refining process 

and product crushing and screening equipment. Table 2-1 provides a summary of the applicable 

limits.
3

Table 2-1. Emissions Standards in the Ferroalloys NESHAP

(40 CFR part 63, subpart XXX)

New or 

Reconstructed or 

Existing Source Affected Source

Applicable PM Emission 

Standards

New or reconstructed Submerged arc furnace 

0.23 kg/hr/MW (0.51 lb/hr/MW) 

or 

35 mg/dscm (0.015 gr/dscf)

Existing

Open submerged arc furnace producing 

ferromanganese and operating at a 

furnace power input of 22 megawatts 

(MW) or less

9.8 kg/hr (21.7 lb/hr) 

Existing

Open submerged arc furnace producing 

ferromanganese and operating at a 

furnace power input greater than 22 

MW

13.5 kg/hr (29.8 lb/hr) 

Existing

Open submerged arc furnace producing 

silicomanganese and operating at a 

furnace power input greater than 25 

MW

16.3 kg/hr (35.9 lb/hr) 

Existing

Open submerged arc furnace producing 

silicomanganese and operating at a 

furnace power input of 25 MW or less

12.3 kg/hr (27.2 lb/hr) 

Existing

Semi-sealed submerged arc furnace 

(primary, tapping, and vent stacks) 

producing ferromanganese

11.2 kg/hr (24.7 lb/hr) 

New, reconstructed, 

or existing Metal oxygen refining process 69 mg/dscm (0.03 gr/dscf)

New or reconstructed

Individual equipment associated with 

the product crushing and screening 

operation

50 mg/dscm (0.022 gr/dscf)

Existing

Individual equipment associated with 

the product crushing and screening 

operation

69 mg/dscm (0.03 gr/dscf)
4

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 measurements; and maintenance activities associated with submerged arc furnaces 

and casting operations are exempt from the opacity standards. For outdoor fugitive dust sources, 

the 1999 NESHAP requires that plants operate according to an outdoor fugitive dust control plan 

that describes in detail the measures that will be put in place to control outdoor fugitive dust 

emissions from the individual outdoor fugitive dust sources at the facility.

3.0 RE-EVALUATION OF THE PROPOSED RULE AMENDMENTS BASED ON 

DEVELOPMENTS IN PRACTICES, PROCESSES AND CONTROL 

TECHNOLOGIES

The proposed rule amendments to the NESHAP for the ferroalloys production source category 

published in the Federal Register on November 23, 2011 (76 FR 72508) included changes to the 

stack emission limits and requirements for the capture of fugitive emissions. The proposed rule 

included changes to the stack emission limit for PM (as surrogate for metal HAP), in addition to the 

inclusion of HAP emission limits for mercury, formaldehyde, polycyclic aromatic hydrocarbons 

(PAH) and hydrogen chloride (HCl). The 2011 proposed amendments also included a proposed 

requirement for a furnace building ventilation system, which encloses the building and evacuates 

the captured emissions to a control device. These proposed amendments in 2011 for PM were 

based on the initial technology review of the ferroalloys industry. The limits for Hg, PAHs, 

formaldehyde and HCl were proposed under 112(d)(2) and (d)(3) of the Act. A summary of the 

proposed emission limit requirements in the 2011 proposal publication is provided in Table 3-1.

The proposed furnace stack emission PM limits were a result of a technology review of test data 

received from the 2010 Information Collection Request (ICR). Since the proposed rule was 

published, EPA has received additional test reports from the facilities, including test data in 

response to a 2012 ICR. Based on these new test data, the emission limits proposed in the 

NESHAP amendments were re-evaluated. Because PM limits (as a surrogate for metal HAP) are 

already established in the current NESHAP for Ferroalloys Production, a technology review was 

performed for the proposed rule. The technology review for the 2011 proposed rule found that 

developments in practices, processes, and control technologies had occurred and therefore, EPA 

proposed tighter revised PM emission limits as shown in Table 3-1. These proposed limits were 

significantly more stringent than the limits in the 1999 MACT rule as they reflected the current 

performance of the facilities, and for some of the limits, presented in a different format (i.e., 

mg/dscm, instead of kg/hr).
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Table 3-1. Proposed HAP Emission Standards for the Ferroalloys Production NESHAP that 

were published in the November 2011 Proposal (76 FR 72508)

HAP Pollutant

New or 

Reconstructed or 

Existing Source Affected Source

Proposed Emission 

Standard

PM (surrogate for 

metal HAP) New or reconstructed Electric arc furnace 9.3 mg/dscm corrected to 2% CO2

PM (surrogate for 

metal HAP) Existing Electric arc furnace 24 mg/dscm corrected to 2% CO2

Hg New, reconstructed, or 

existing Electric arc furnace 16 μg/dscm corrected to 2% CO2

PAH New, reconstructed, or 

existing Electric arc furnace 89 μg/dscm corrected to 2% CO2

HCl New, reconstructed, or 

existing Electric arc furnace 809 μg/dscm corrected to 2% CO2

Formaldehyde New, reconstructed, or 

existing Electric arc furnace 201 μg/dscm corrected to 2% CO2

PM (surrogate for 

metal HAP)

New, reconstructed, or 

existing

Local ventilation used 

to capture tapping, 

casting, or ladle 

treatment emissions

24 mg/dscm corrected 

to 2% CO2

PM (surrogate for 

metal HAP)

New, reconstructed, or 

existing MOR process 3.9 mg/dscm corrected to 2% CO2

PM (surrogate for 

metal HAP)

New, reconstructed, or 

existing MOR process 13 mg/dscm corrected to 2% CO2
6

The technology review for this rule was re-evaluated to include the additional test data received 

after the 2011 proposed rule was published. The results of this revised technology review for PM (a 

surrogate for metal HAP) are presented in this memorandum. The results of the PAH and HCl 

analyses can be found in the revised MACT floor memorandum.2 The mercury emission limit was 

re-evaluated and presented in the mercury control option memorandum.3 The formaldehyde 

emission limits were not changed as the new data continued to support the 2011 proposed emission 

limit for formaldehyde.

3.1 PM Furnace Stack Emission Limit

Under Section 112(d)(6) of the CAA, EPA is required to review the emission standards, taking into 

account developments in practices, processes, and control technologies, and revise the standards if 

appropriate based on that review. As shown in Table 2-1, the PM limits, used as a surrogate for 

metal HAP, in the existing NESHAP for the furnaces ranged from 21.7 to 35.9 pounds per hour 

(lbs/hr) depending on the furnace size, type and product being produced. For the 2011 proposed 

rule, the particulate matter (PM) emissions that were reported by the industry in the 2010 ICR were

far below the level specified in the 1999 NESHAP, indicating improvements in the control of PM 

emissions since promulgation of the existing NESHAP. In 2011, based on the initial technology 

review, EPA proposed revised emissions limits for PM, which are shown in Table 3-1. These limits 

were based on limited data from the facilities and did not include test data from each furnace. In 

addition, the 2011 proposed rule revision for the PM furnace limits included a correction for the 

exhaust gas carbon dioxide (CO2) concentration.

Prior to the supplemental proposal, EPA received multiple test data from each of the furnaces at the

two facilities. Under the revised technology review, the emissions and performance of each of the 

furnaces in the source category were again evaluated and compared with the emission limits in the 

1999 MACT rule. The new test data received from the ferroalloy production facilities in response to 

information requests from EPA for this NESHAP review show outlet PM emission rates from the 

furnaces ranging from 0.5 to 12.9 lbs/hr. Based on this evaluation, it was again determined that all 

of the furnaces had PM emissions well below the PM limits in the 1999 MACT rule. Because all of 

furnaces were performing well below the 1999 MACT limit, the potential to establish a lower PM 

limit for furnaces under the technology review was evaluated to reflect the current performance of 

the furnaces and reduce “allowable” PM emissions for the source category without being so 

stringent as to require facilities to replace their current PM control devices. To determine an 

appropriate level for a PM limit that would reflect the improved performance of furnaces since the 

1999 MACT rule, the PM emissions data from the highest emitting furnace (Eramet Furnace 12) 

were evaluated to determine a potential PM limit for the supplemental proposal. Another factor 

considered in selecting the revised proposed PM limit for furnaces is the expectation that Eramet 

 

2 Memorandum from Bradley Nelson, EC/R to Phil Mulrine, EPA OAQPS/SPPD/MICG, Revised MACT Floor 

Analysis for the Ferroalloys Production Source Category, August 29, 2014.

3 Memorandum from Bradley Nelson, EC/R to Phil Mulrine, EPA OAQPS/SPPD/MICG, Mercury Control Options and 

Impacts for the Ferroalloys Production Industry, August 29, 2014.
7

will likely need to upgrade the existing scrubber on Furnace #12 in order to comply with the 

proposed requirements for process fugitive emissions and as described in Eramet’s particulate 

control plan.

4 A summary of the test results and average test data concentrations for each of the 

furnaces is provided in Appendix A. The test data for Eramet Furnace #12 includes five 3-run tests 

and the average of these five PM test data points was calculated to be 16.9 milligrams per dry 

standard cubic meter (mg/dscm) with minimum and maximum test averages of 9.9 and 23.8 

mg/dscm, respectively. Based on these data and the expectations that Eramet will likely need to 

upgrade the controls on that furnace to meet the standards for process fugitive emissions, we 

conclude that all existing furnaces should be able to maintain PM emissions below 25 mg/dscm 

without the need to completely replace their control devices and therefore the EPA is proposing an 

emission limit of 25 mg/dscm for existing ferroalloy production furnaces in the 2014 supplemental 

proposal based on the revised technology review.

The proposed revised new source PM limit was determined by evaluating the test data from the best 

performing furnace from the test data provided to EPA. The average furnace PM outlet 

concentrations were calculated and ranked for each of the furnaces. A summary of the data set used 

for determining the best performing furnace is provided in Appendix A. Based on this ranking, 

Furnace 2 at Felman was selected as the best performing furnace. The test data for Furnace 2 

includes four 3-run tests with an average of 1.67 mg/dscm and minimum and maximum test 

averages of 0.79 and 2.51 mg/dscm, respectively. With regard to all the 12 individual test runs, we 

observe that the highest measured value of all 12 runs was 3.73 mg/dscm. Based on these data and 

analyses, and given that the highest test result from Furnace #2 is 3.73 mg/dscm, we conclude that a 

new source with a similar or better baghouse will be able to meet a PM emissions limit of 4.0. 

Therefore, based on this revised technology review, the EPA is proposing an emission limit of 4.0

mg/dscm for new ferroalloy production furnaces.

A test report was received from Eramet recently that included March 2014 PM test results from the 

Furnace 12 scrubber outlet, Furnace 1 baghouse outlet, and the Furnace 1 tapping baghouse outlet.

However, these data were not included in this analysis because a quality assurance assessment 

could not be performed before the finalization of this memorandum. The test report is available in 

the docket and will be analyzed during the comment period for the supplemental proposal. Potential 

comments on this test report are requested in the Federal Register notice for this supplemental 

proposal.

 

4

“Estimated Costs For Potential Fugitive Particulate Control Modifications at Eramet Marietta Inc. (as of 11/22/2013)”, 

Eramet Marietta Inc, 11/22/13. “Answers for EPA”, Felman Production Inc, 11/12/13.
8

3.3 PM Local Ventilation Stack Emission Limit

The 1999 MACT rule did not include any PM emission limits for local ventilation control devices

associated with the furnace (e.g., units that control tapping, casting or ladle treatment emissions). 

Only one of the facilities operates a separate baghouse to control emissions from tapping operations 

at the furnace (Eramet Furnace 1 Tapping Baghouse). An emission limit for PM from this emission 

source was included in the 2011 proposed rule, but was based on the PM emission limit from the 

furnace outlet. Since the proposed rule was published, EPA has received three PM test reports that 

include PM emissions test results (with 9 test runs) from the tapping baghouse. Since EPA never 

established a MACT Floor limit for the local ventilation stacks, a standard UPL analysis5 was 

conducted using the 3 emissions tests results (9 test runs) to calculate a 99% UPL. The calculated 

99% UPL is 3.94 mg/dscm. Based on this UPL analysis, EPA is proposing a PM emissions limit of 

4.0 mg/dscm for local ventilation stacks in the supplemental proposal. A summary of the data set

and the UPL calculation for the local ventilation unit is provided in Appendix A.

Because the data set only included test data from one source, the “best performing source” was 

determined to be the Eramet Furnace 1 Tapping Baghouse and therefore, the revised PM MACT 

limit for both new and existing sources for local ventilation devices was determined to be 4.0

mg/dscm.

3.4 PM Metal Oxygen Refining Stack Emission Limit

No additional test data was received after the publication of the proposed rule for the metal oxygen 

refining (MOR) operation. Therefore, the proposed limit of 3.9 mg/dscm that was presented in the 

2011 proposed rule would still be appropriate for new and existing metal oxygen refining operation 

sources based on the technology review.

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3.5 Crushing and Sizing Stack Emission Limit

The technology review for the 2011 proposed rule calculated a proposed stack emission limit of 13 

mg/dscm for crushing and screening equipment that would apply to both new and existing sources. 

No additional test data was received after publication of the proposed rule and therefore the 

proposed limit was not revised.

 

5 Memorandum from Phil Mulrine, EPA OAQPS to Docket ID No. EPA-HQ-OAR-2010-0895, Use of the Upper 

Prediction Limit for Calculating MACT Floors, July 30, 2014.

6 Memorandum from Beth Friedman, Jeff Harris, and Brad Nelson, EC/R to Conrad Chin, US EPA, OAQPS, Draft 

Technology Review for the Ferroalloys Production Source Category, October 27, 2011.
9

3.6 Metal HAP Fugitive Emissions

The technology review for the proposed rule evaluated an option to enclose the furnace building(s) 

and evacuate the fugitive emissions of metal HAP to a control device(s). The determination was 

based on the feasibility of installing enclosures and having the fugitive emissions at the ridge vents 

of the shop building collected under negative pressure and ducted to a control device, with a PM 

emissions limit at the control device stack outlet set at the same level as for the furnace stacks. This 

would allow sources the option to duct some or all process fugitive emissions to an existing furnace 

control device if it has excess capacity.

After proposal, EPA received cost estimates from the two ferroalloy production facilities that show 

that the proposal cost estimates of building evacuation were underestimated. The cost estimates 

algorithms used for the proposed rule building evacuation costs were based on the EPA Control 

Cost Manual.

7

 The facilities provided vendor quotes and engineering designs that estimated the 

cost of building ventilation 2-3 times higher than the EPA estimate. We have reviewed this 

information and agree that the costs and feasibility of building enclosure in the 2011 proposal were 

underestimated. Therefore, the technology review for controlling fugitive metal HAP emissions 

was re-evaluated to determine if other control methods could be used.

Both ferroalloys production facilities submitted alternative control methodologies for controlling 

process fugitive HAP emissions from the furnace buildings based on the principle of enhanced 

capture options.

8,9

 These enhanced capture options methods included;

 Increasing primary capture at the source of fugitive metal HAP emissions,

 Adding primary capture to sources that were previously uncontrolled,

 Adding secondary capture to capture fugitive metal HAP emissions not captured by the 

primary capture system,

 Partitioning of parts of the building where fugitive metal HAP emissions occur, and

 Installing new metal HAP control devices to control the captured fugitive emissions.

The EPA has evaluated these design narratives from the facilities and believes that they provide 

comparable fugitive metal HAP reductions as the building evacuation option. In addition, the total 

cost of installing and operating this enhanced capture option is considerably less than the building 

evacuation option. A comparison of the fugitive emission capture options is provided in the cost

impacts memorandum for ferroalloys production.10 

 

7 EPA Air Pollution Control Cost Manual – Sixth Edition, http://www.epa.gov/ttncatc1/products.html

8 QSEM, National Emissions Standards for Hazardous Air Pollutants: Ferroalloys Production Technical Comments to 

Alternative Approach to NESHAP Subpart XXX Compliance - November 23, 2011 Proposed Rule, June 29, 2012.

9 Chu & Gassman Design Narrative, July 9, 2012.

10 Memorandum from Jeff Harris and Brad Nelson, EC/R to Phil Mulrine, US EPA, OAQPS, Cost Impacts of the 

Controls Options considered for the NESHAP for the Ferroalloys Production Source Category to Address Fugitive HAP

Emissions, August 13, 2014.
10

3.7 Outdoor Fugitive Dust Emissions

Outdoor fugitive emissions are believed to be relatively low. Nevertheless, the technology review 

for the proposed amendments to the Ferroalloys Production NESHAP was unable to quantify HAP 

emissions from these sources and did not identify any additional procedures or controls that could 

be expected to have a significant impact on these emissions. The determination in the technology 

review for controlling outdoor fugitive emissions is that the existing requirements for an outdoor 

fugitive dust control plan still reflect an appropriate control approach for those potential emissions 

sources. No additional data was received for this fugitive emission source, and therefore the 

requirement of the outdoor fugitive dust control plan that is in the 1999 MACT rule was determined 

to still be the best control option for this source.

4.0 CONCLUSIONS

The re-evaluation of the technology review did not identify any new developments in practices, 

processes, or control technologies that have been implemented in this source category since the 

proposed rule was published. However, new test data indicates that both facilities have 

significantly reduced stack emissions of metal HAP compared to allowable levels, primarily 

through improved performance of baghouses. 

Based on the re-evaluation of the technology review, it was concluded that it is feasible and costeffective for facilities to achieve an existing source furnace stack PM emissions limit of 25

mg/dscm and new source furnace stack emissions limit of 4.0 mg/dscm. The re-evaluation also 

determined that new and existing local ventilation control devices could achieve a PM emission 

limit of 4.0 mg/dscm. The previous technology review concluded that a stack PM emission limit of 

13 mg/dscm for new and existing crushing and screening equipment is reasonable. Our analyses 

indicate that a stack emission limit for PM of 3.9 mg/dscm is achievable for new and existing metal 

oxygen refining operations.

We believe that these controls and measures are cost-effective and reflect achievable performance 

for this industry. Details of the costs and emissions reductions associated with these measures are 

available in the cost impacts memorandum available in the docket for the Ferroalloys Production 

source category.
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Appendix A

Furnace and Local Ventilation PM Data Sets 
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Furnace Particulate Matter Emission Test Data

Facility Sample Date Sample Location Product

Run 1 Conc 

(mg/dscm)

Run 2 Conc 

(mg/dscm)

Run 3 Conc 

(mg/dscm)

Average 

Furnace Conc 

(mg/dscm)

Furnace 

Average Conc 

(mg/dscm)

Number of 

Test Runs in 

Furnace 

Average

Eramet 5/26/2011 Furnace 1 Baghouse Outlet SiMn 3.750 0.891 0.664 1.768

Eramet 11/29/2011 Furnace 1 Baghouse Outlet FeMn 3.181 4.439 4.096 3.905

Eramet 7/23/2012 Furnace 1 Baghouse Outlet SiMn 4.367 2.559 3.624 3.517

Eramet 3/4/2013 Furnace 1 Baghouse Outlet FeMn 1.995 1.445 2.714 2.051 2.810 1 2

Eramet 8/16/2010 Furnace 12 Scrubber Outlet FeMn 7.320 9.426 12.999 9.915

Eramet 5/25/2011 Furnace 12 Scrubber Outlet FeMn 13.795 13.280 9.385 12.154

Eramet 11/30/2011 Furnace 12 Scrubber Outlet SiMn 32.494 21.007 17.849 23.783

Eramet 7/25/2012 Furnace 12 Scrubber Outlet FeMn 13.307 16.455 18.010 15.924

Eramet 3/4/2013 Furnace 12 Scrubber Outlet SiMn 21.411 22.576 24.251 22.746 16.904 1 5

Felman 7/9/2010 Furnace 2 Baghouse Outlet SiMn 2.389 1.238 3.731 2.453

Felman 4/26/2011 Furnace 2 Baghouse Outlet SiMn 2.066 2.130 3.348 2.515

Felman 8/13/2012 Furnace 2 Baghouse Outlet SiMn 1.303 0.794 0.705 0.934

Felman 3/20/2013 Furnace 2 Baghouse Outlet SiMn 0.860 0.724 0.792 0.792 1.673 1 2

Felman 11/9/2010 Furnace 5 Baghouse Outlet SiMn 4.479 3.574 2.646 3.566

Felman 4/27/2011 Furnace 5 Baghouse Outlet SiMn 6.275 5.504 5.207 5.662

Felman 8/9/2012 Furnace 5 Baghouse Outlet SiMn 0.940 0.691 0.565 0.732

Felman 3/13/2013 Furnace 5 Baghouse Outlet SiMn 0.608 0.877 0.857 0.781 2.685 1 2

Felman 11/10/2010 Furnace 7 Baghouse Outlet SiMn 1.139 1.174 1.852 1.388

Felman 4/28/2011 Furnace 7 Baghouse Outlet SiMn 3.796 2.195 5.441 3.811

Felman 8/7/2012 Furnace 7 Baghouse Outlet SiMn 4.866 2.984 1.794 3.214 2.805 9
13

Local Ventilation Particulate Matter Emission Test Data

Facility Sample Date Sample Location Product

Run 1 Conc 

(mg/dscm)

Run 2 Conc 

(mg/dscm)

Run 3 Conc 

(mg/dscm)

Average Conc 

(mg/dscm)

Source 

Average Conc 

(mg/dscm)

Number of 

Test Runs in 

Furnace 

Average

Eramet 5/26/2011 Furnace 1 Tapping Baghouse Outlet SiMn 2.367 1.946 3.780 2.69747

Eramet 7/23/2012 Furnace 1 Tapping Baghouse Outlet SiMn 2.789 2.126 3.182 2.69894

Eramet 3/4/2013 Furnace 1 Tapping Baghouse Outlet FeMn 3.379 2.790 2.810 2.99300 2.796 9

UPL Calculation - Furnace 1 Tapping Baghouse

Total Facility Count 1 # Facilities

Total Furnace Count 1 # Furnaces

Average - All Runs 2.80 mg/dscm

Minimum - All Runs 1.946 mg/dscm

Maximum - All Runs 3.78 mg/dscm

Sample Size (n) 9 # of runs

Skewness (S) 0.16

Std Error of Skewness (SES) 0.82

0.20 S/SES 

Normal S/SES>2

Kurtosis (K) -0.60

Std Error of Kurtosis (SEK) 1.63

-0.37 K/SEK 

Normal K/SEK>2

99% UPL (normal distribution) 3.94 mg/dscm

Skewness Test (reported values)

Kurtosis Test (reported values)