1

MEMORANDUM

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

FROM: Jeff Harris, Brad Nelson, EC/R

DATE: August 13, 2014

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

Address Fugitive HAP Emissions

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

emissions reductions for the main options considered for the supplemental 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 the 

regulatory options that were considered for the supplemental proposal. As described below, the focus of 

this analysis is process fugitive control costs. Process fugitives are emissions generated during the 

Ferroalloys Production process that not captured and sent to a control device.

The development of the emissions estimates (baseline and for the control option) for this source 

category are discussed in Revised Development of the Risk and Technology Review (RTR) Emissions 

Dataset for the Ferroalloys Production Source Category. Development of revised emissions limits for 

particulate matter (PM) are described in the Technology Review memo, and development of maximum 

achievable control technology (MACT) limits for polycyclic aromatic compounds (PAH) and hydrogen 

chloride (HCl) are described in the Revised MACT Floor Analysis for the Ferroalloys Production 

Source Category. Furthermore, the MACT limits for mercury (Hg) are described in the Mercury 

Control Options and Impacts for the Ferroalloys Production Industry document. These four documents 

are available in the docket for this rulemaking.

The organization of this document is as follows:

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

Fugitive Emissions for the Supplemental Proposal

2.0 Regulatory Options for the Supplemental Proposal

3.0 Details of Fugitive Emission Control Options for the Supplemental Proposal

4.0 Methodology for Estimating Control Costs
2

1.0 SUMMARY OF COST ESTIMATES AND EMISSIONS REDUCTIONS FOR THE 

REGULATORY OPTIONS FOR PROCESS FUGITIVE EMISSIONS FOR THE

SUPPLEMENTAL PROPOSAL

At proposal in November 2011,

1

regulatory options were considered for control of emissions of metal

HAP and organic HAP from furnace stacks, and metal HAP from product sizing stacks and fugitive 

sources. For this analysis, we assume the final emissions limits for stacks (PM, formaldehyde, PAH, and 

HCL) will be similar to those proposed in November 2011, and that control of these stack emissions via 

existing control devices will be adequate to meet these limits. Furthermore, the control options for 

mercury emissions from stacks and the costs of those options are evaluated and presented in a separate 

technical memorandum. Therefore, this memorandum only assesses the options and costs for the control 

of fugitive HAP emissions (which are mainly Mn and other HAP metals in particulate form such as 

nickel, cadmium, chromium and lead).

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

available. Because of this, and the limited number of facilities in the source category (two), specific 

regulatory options were considered for each facility. Emissions reductions were estimated for each 

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

along with application of emissions factors, and other data analyses and calculations.

2

Selection of control options for fugitive HAP emissions was less straightforward than those for stack 

emissions. Discussions with vendors and ventilation experts and our research led to a conclusion that 

implementation of fugitive capture and control systems is complex and that system parameters are 

highly dependent on specific localized parameters (e.g., building volume, process locations, and 

airflow.) Any plans to implement a system for ventilation to control fugitive emissions should begin 

with a rigorous, systematic examination of the ventilation requirements throughout the building leading 

to design and implementation of an enhanced fugitive capture and control system (potentially consisting 

of primary hoods, secondary hoods, enclosures and/or building roof monitor ventilation ducted to 

particulate matter control device(s)) that can be designed and operated to achieve effective reductions of 

fugitive emissions (such as about 95%) and meet potential regulatory requirements such as tight opacity 

standards..

Brief descriptions of the costs and emissions reductions associated with the two main options considered 

for the supplemental proposal of the NESHAP are summarized in Table 1-1. Option 1 includes enhanced 

local capture and roofline ventilation for both facilities. Option 2 reflects full building enclosure with 

negative pressure for both facilities. A more detailed description of the regulatory options considered 

 

1 The EPA proposed amendments to the national emission standards for hazardous air pollutants for the ferroalloys 

production source category published in the Federal Register on November 23, 2011 (76 FR 72508).

2

See Revised Development of the Risk and Technology Review (RTR) Emissions Dataset for the Ferroalloys Production 

Source Category, which is available in the docket for this rulemaking.
3

and their associated cost and emissions reductions estimates are presented in the remaining sections of 

this memorandum. 

The cost estimates for Option 1 contained in Table 1-1 of this memo represent our expectations of the 

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 are 

directly based on cost estimates supplied by the facilities3after 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”. Attachments 1 and 

2 contain copies of the cost estimates provided by the facilities. The cost estimates for Option 2 

contained in Table 1-1 are based on revised analyses we conducted after considering comments, 

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

4,5

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

calculated as the difference between baseline emissions and the estimated emissions with enhanced 

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 (expected to occur in

2015). All costs are estimated in 2012 dollars. PM emissions in this memo refer to total PM. Of the total 

PM, approximately 21 percent of the emissions are assumed 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.

 

3

“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.

4 Eramet: "Engineering Review of Proposed Ferroalloy NESHAP Requirements for Eramet Marietta Inc.", EPA-HQ-OAR2010-0895-0106.

5

Felman: "Building Ventilation Costs January 30, 2012", EPA-HQ-OAR-2010-0895-0073.
4

Table 1-1: Summary of the Estimated Costs and Emissions Reductions for Control Options 

Eramet $25,147,000 $5,343,095 146 31 61 $36,660 $174,573 $43

Felman $14,627,782 $1,853,325 83 17 16 $22,251 $105,955 $58

Total $39,774,782 $7,196,420 229 48 77 $31,420 $149,619 $46

Eramet4 $33,154,302 $13,670,228 156 33 64 $87,816 $418,174 $107 $839,243 $3,996,395 $1,648

Felman5 $28,228,603 $5,042,545 97 20 19 $52,214 $248,637 $134 $240,123 $1,143,441 $561

Total $61,382,905 $18,712,773 252 53 83 $74,185 $353,264 $113 $496,313 $2,363,394 $1,073

1

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

3

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

5

 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

4

 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.

2

 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 during 2007-8.

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
5

2.0 REGULATORY OPTIONS FOR THE SUPPLEMENTAL PROPOSAL

This section provides a detailed description of regulatory options for fugitive emissions for the 

supplemental proposal of the Ferroalloys NESHAP and their associated costs and emissions reductions.

The first option (Option 1) evaluated for fugitive metal HAP emissions in this document is based on 

enhanced local capture and control, including primary and secondary hooding. The option is mainly 

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 control option (i.e., about 95% capture of 

fugitives) was also used to estimate post control risks under this option. The precise form of the 

standard under this option (which would eventually be presented in the regulatory text) has not yet been 

determined, but will likely include a tight opacity limit which facilities are expected to comply with via 

enhanced fugitive capture and control systems and could also include other requirements. Design of 

these enhanced systems would be preceded by a rigorous, systematic examination of the ventilation 

requirements. The enhanced capture and control systems that would be used by the facilities to comply 

with this type of standard would likely include primary and secondary hoods collecting emissions from 

tapping and casting operations and directing them to control devices (assumed to be fabric filters) and 

capture of fugitive emissions at roof vents over some process areas, directed to control systems 

(assumed to be fabric filters).

The first control option for the supplemental proposal represents a scenario of reducing PM emissions 

from the facilities by an estimated 229 tons per year (and HAP emissions by an estimated 77 tons per 

year) by installing enhanced local capture and control of fugitive emissions (with primary hooding close 

to the tapping and casting operations) and secondary hooding near the roofline to capture and control the 

remaining fugitive emissions (not captured by the primary hooding) and ventilation of those emissions 

to PM control devices. The total estimated capital cost for these fugitive controls is $38 million. 

Annualized capital cost and operational and maintenance costs are estimated at $7 million. 

The second option (Option 2) is full building enclosure. The EPA proposed this option in the November 

2011 proposal. However, EPA received significant comments indicating that EPA had substantially 

underestimated the costs and noted several other issues, such as the need to account for more air 

exchanges to protect workers, and need for additional control capacity, fans, duct work, and structural 

support. Therefore, we are presenting that option again in this document with updated estimates of the 

costs and effectiveness of that option. 

The second control option for the supplemental proposal represents a scenario of reducing PM emissions 

from the facilities by an estimated 252 tons per year (and HAP emissions by an estimated 83 tons per 

year) by installing full building enclosure. The total estimated capital cost for fugitive controls is $61

million. Annualized capital cost and operational and maintenance costs are estimated at $19 million. 
6

Details of the emission control systems for option 1 are presented in Section 3. Details of the estimated 

costs for both options are presented in section 4.

3.0 DETAILS OF FUGITIVE EMISSION CONTROL OPTIONS FOR THE 

SUPPLEMENTAL PROPOSAL

This section contains details of the estimated costs, emission reductions, and cost effectiveness for the 

two presented options for fugitive emissions control, as described in Section 2.

3.1 Option 1: Enhanced Local Capture

Table 3-1 contains details of the estimated costs, emission reductions, and cost effectiveness of our best 

estimate of the systems the facilities are likely to install to comply with option 1, based on currently 

existing local emission capture systems. 

As previously mentioned, design of a local ventilation system begins with a detailed analysis of specific 

localized parameters (e.g., building volume, process locations, and airflow) leading to development of a 

site-specific local ventilation plan and installation of custom hoods and ventilation equipment. Such a 

system might rely on a variety of specific ventilation systems. Installed systems may include the 

following:

 Curtains or doors surrounding furnace tops to contain fugitive emissions,

 Improvements to hoods collecting tapping emissions,

 Upgraded fans to improve the airflow of fabric filters controlling fugitive emissions,

 Addition of “Secondary Capture”, or additional hoods to capture emissions from tapping 

platforms or crucibles,

 Addition of fugitive capture for casting operations,

 Addition of additional fabric filters where necessary, and

 Addition of rooftop ventilation, in which fugitive emissions escaping local control are

collected in the roof canopy over process areas through addition of partitions, then 

directed through roof vents and ducts to control systems.

For the purposes of this analysis, it has been assumed that enhanced fugitive capture and control systems 

and roofline ventilation will be installed for all operational furnaces at both facilities, and for MOR 

operations at Eramet Marietta. The specific elements of the capture and control systems selected for 

each facility are based directly on information supplied by the facilities incorporating their best 

estimates of the improvements to fugitive emission capture and control they would implement to achieve 
7

the standards to be included in the supplemental proposal. Attachments 1 and 2 contain copies of the 

cost estimates provided by the facilities.

3.2 Option 2: Full Building Enclosure

Option 2 (i.e., full building enclosure) remains generally the same as in EPA’s November 2011 

proposal.

1

 However, the estimated costs are significantly higher than previously estimated. This control 

option involves installation of full building ventilation at negative pressure 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, structural repairs to buildings, and a 

new fabric filter for each building. For emissions modeling and cost estimation purposes we assumed 

that building ventilation would be required for buildings containing furnaces, (i.e., Eramet buildings #1 

and #12, and the melt shop building at Felman).
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Table 3-1: Option 1: Enhanced Local Capture/Control for Fugitive Emissions

Facility

Current PM 

Emissions 

(Tons/yr)

Current HAP 

Emissions 

(Tons/yr)

Total Capital Cost 

($)

Total Annual Cost 

($)1

 PM Emissions 

(Tons/yr)

HAP Emissions 

(Tons/yr)

PM Emission 

Reduction 

(Tons/yr)

HAP Emission 

Reduction 

(Tons/yr)

PM Cost 

Effectiveness 

($/Ton)

PM2.5 Cost 

Effectiveness 

($/Ton)2

HAP Cost 

Effectiveness 

($/Ton)

HAP Cost 

Effectiveness 

($/lb)

Eramet 251 131 $25,147,000 $5,343,095 106 6 9 146 6 1 $36,660 $174,573 $86,956 $43

Felman 149 6 6 $14,627,782 $1,853,325 6 6 5 0 8 3 1 6 $22,251 $105,955 $115,727 $58

Total 401 197 $39,774,782 $7,196,420 172 119 229 7 7 $31,420 $149,619 $92,905 $46

Facility

Furnace Door 

Capital Cost1 

($)

Furnace Door 

Annual Cost 

($/yr)2 

Tap Hood Upgrade 

Capital Cost (Hood 

+ Ducts) ($)3

Tap Hood Upgrade 

Annual Cost (Hood 

+ Ducts) ($/yr)4 

Furnace/Tap 

BH Fan 

Upgrades 

Capital Cost3 

($)

Furnace/Tap 

BH Fan 

Upgrades 

Annual Cost 

($/yr)4 

Tap Platform 

Enclosure 

Capital Cost3 

($)

Tap Platform 

Enclosure 

Annual Cost 

($/yr)4 

Casting,

 Rake-off 

Capture 

Capital Cost3 

($)

Casting, Rakeoff Capture 

Annual Cost 

($/yr)4 

Roof 

Ventilation 

Baghouse 

Capital Cost3,5 

($)

Roof 

Ventilation 

Baghouse 

Annual Cost 

($/yr)4,5 

Roof 

Ventilation 

Structural 

Capital Cost3 

($)

Roofline 

Ventilation 

Structural 

Annual Cost4 

($)

Crushing 

Ventilation 

Upgrade

Capital Cost3 ($)

Crushing 

Ventilation 

Upgrade

Annual Cost 

($)4

Eramet $ 0 $ 0 $2,819,216 $626,134 $343,000 $70,441 $ 0 $ 0 $3,207,903 $591,624 $12,583,921 $2,794,827 $6,192,960 $1,260,069 $ 0 $ 0

Felman $210,000 $42,399 $150,000 $30,285 $2,078,000 $419,547 $195,000 $39,370 $146,000 $29,477 $11,047,661 $1,125,834 $319,243 $69,122 $481,878 $97,291

Total $210,000 $42,399 $2,969,216 $656,419 $2,421,000 $489,988 $195,000 $39,370 $3,353,903 $621,101 $23,631,582 $3,920,661 $6,512,203 $1,329,191 $481,878 $97,291

4

 Annual cost calculated using 7% interest and a 20-year equipment life. O&M Costs Included for Eramet, based on 11/22/13 memo. O&M costs for Felman estimated based on average O&M from Eramet memo.

3

 Upgrade capital costs adapted from cost information provided by facilities (Felman: updated 11/12/13, Eramet: Provided 11/22/13) Felman upgrade costs not included for upgrades listed by the plant as already in place. Totals may not match memos exactly due to 

rounding and differences in calculation methods.

1

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

2

 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 during 2007-8. 

5 Costs for Eramet Furnace 12 Roof ventilation baghouse may represent either a new baghouse or upgrades to existing scrubber, as specified in Eramet's 11/22/13 memo.

Individual Cost Items
9

4.0 METHODOLOGY FOR ESTIMATING CONTROL COSTS

This section contains additional details regarding the methodology employed to estimate the 

costs associated with the two regulatory options described in Section 2.

4.1 Option 1 – Enhanced Fugitive Capture

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. 

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.

As previously mentioned, design of a local ventilation system begins with a detailed analysis of 

specific localized parameters (e.g., building volume, process locations, and airflow) leading to 

development of a site-specific local ventilation plan and installation of custom hoods and 

ventilation equipment. Both facilities which will be subject to the NESHAP have performed 

preliminary analyses to assess the measures that they are likely to need to take to comply with 

EPA’s potential requirements, and have submitted cost estimates to EPA based on their analyses. 

Attachments 1 and 2 contain copies of the cost estimates provided by the facilities.

Costs were estimated for enhanced process fugitive control including roofline ventilation, as 

described in Section 3 above. Details of the methodology employed to estimate these costs 

follow.

4.1.1 General Considerations

As described in Sections 2 and 3, a variety of potential enhancements to local ventilation and 

control of fugitive emissions may be used by the facilities depending on their individual 

situation. Specific enhancements for each facility were selected for cost estimation based on 

estimates directly provided by the facilities based on their own engineering analyses and 

discussions with EPA (see Attachments 1 and 2 for these cost estimates, and Table 3-1 for details 

of the specific options in the cost estimate for each facility). Analyses and cost estimates 

provided by the facilities were reviewed by EPA and then used in the cost impacts assessment 

where they were available. In addition, the following general considerations apply to all 

estimated costs for process fugitives:
10

 Annualized costs assume a 20-year life expectancy for the installed control devices 

and other 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.

 Costs provided by the facility were assumed to be in current dollars. All other costs 

for this estimate were adjusted to 2012 dollars using Chemical Engineering Plant Cost 

Indices (CEPCI6) where necessary.

 Downtime associated with installation was not directly included in in cost estimates.

7

 Costs were not included for items noted by the facilities as currently being in place.

4.1.2 Facility-Specific Considerations

The following facility-specific considerations also apply:

 Felman Production provided two general cost estimate scenarios: 

o The first assumes a scenario in which one of their three furnaces is not in 

operation and its fabric filter is used to control the process fugitive emissions 

collected through roofline capture and ventilation from the other two furnaces;

and

o The second scenario assumes all three furnaces are operational with the 

addition of a new fabric filter to control the process fugitive emissions 

collected from roofline capture and ventilation of fugitives from all three 

furnaces.

 The estimated costs for Felman provided in this memorandum are based on the 

second scenario. This scenario was selected to be in line with modeled emissions, 

which are based on the assumption that all three furnaces are operational. 

 Because Felman Production did not provide detailed estimated costs for the additional 

fabric filter included in the second scenario, total installed capital cost and annual 

costs for the fabric filter were estimated using EPA’s Integrated Planning Model 

 

6 CEPCI values employed: 584.6 for 2012, 521.9 for 2009, and 359.2 for 1993.

7 Eramet Marietta provided costs for downtime associated with installation, while Felman did not. These costs were 

significant, but because these costs were declared to be confidential by Eramet, they were considered by EPA, but 

not directly included in these analyses.
11

(IPM) for Particulate Control Cost Development8, with additional costs for ductwork 

estimated using EPA’s Air Pollution Control Cost Manual.

9

The estimated cost for 

this fabric filter is significantly higher than Felman Production’s brief estimate of the 

difference between the two cost scenarios, but the higher estimate has been retained 

to be conservative. Details of these cost estimates are included in Attachment 3.

 Eramet’s cost estimate assumed capital costs of about $7.3M for addition of 

“Scrubber upgrades OR dust collector” for Furnace #12. Adding proportional 

amounts of the associated installation and engineering costs results in total capital 

costs of approximately $12.5M for upgrades to the control device for Furnace #12. 

Furnace #12 currently is equipped with 2 venturi scrubbers used to control fugitive 

emissions from the furnace and tapping. The scrubbers are designed to handle 

approximately 127,000 acfm each and the average flow rate from the current capture 

configuration is 171,000 acfm, or roughly 67% of the estimated capacity of the 

scrubbers. Assuming that the enhanced capture system which Eramet has suggested 

for Furnace 12 (increased tapping capture and roof line ventilation) would increase 

the required airflow over current levels by 50 to 100% (i.e., to a total of 256,000 to 

342,000 acfm), the low end of the estimated range would put them very near the 

maximum capacity of the current controls in place. Accordingly, it seems reasonable 

to assume that additional control capacity will be required, whether in the form of 

upgrades to the scrubber(s) or their replacement with a fabric filter.

4.2 Option 2 – Building Ventilation

As described in Sections 2 and 3, EPA proposed the full building enclosure option in the 

November 2011 proposal. However, EPA received significant comments and information 

indicating that EPA had substantially underestimated the cost. Both Eramet and Felman provided 

extensive comments and information regarding implementation of building ventilation, including 

cost estimates based on their own engineering analyses. After further review and evaluation, we 

have determined it is appropriate to incorporate much of the analyses and cost estimates provided 

by the facilities in developing our revised cost estimates. In addition, the following facilityspecific considerations apply to estimated costs for building ventilation:

 Felman’s cost estimate5applied overhead and contingency adjustments to ductwork costs 

twice (once in the ductwork cost calculations by Chu & Gassman, and again in the costs 

prepared by Lan Associates). Our cost estimate corrects this. For consistency with the 

overhead adjustments used in preparation of the two sections of Felman's overall cost 

estimate, we have calculated the Total Capital Investment (TCI) for the fabric filter as

 

8

Sargent & Lundy, IPM Model - Updates to Cost and Performance for APC Technologies, Particulate Control Cost 

Development Methodology Final, March 2013

9

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

2.17*Purchased Equipment Cost (PEC), and for ductwork as TCI=1.41*PEC. Details of 

the revised cost estimate for Felman are included in Attachment 4.

 Eramet’s cost estimate4included costs for installation of building ventilation for building 

#18. For consistency with the option contained in the 2011 proposal, and with modeled 

emissions, our cost estimate only assumes building ventilation is installed for buildings 

#1 and #12. Only the “Building 1” and “Building 12” costs from Eramet’s cost estimate 

are included.
13

4.3 Options for Monitoring Process Fugitive Emissions

In addition to the fugitive control options, the EPA also considered various monitoring options to 

help ensure the effective capture of fugitive emissions from the ferroalloy production buildings. 

These monitoring options include: EPA Method 9 furnace opacity readings; digital opacity 

compliance system (DOCS) to measure opacity; the installation of roof monitors to measure 

fugitive emissions at the roof vent; and fenceline monitoring. A brief description of these 

monitoring approaches and the estimated costs for each of these options is provided in the 

following sections. 

4.3.1 Method 9 Opacity Readings

One option for determining continuing compliance with the fugitive capture requirements in the 

NESHAP is to require weekly EPA Method 9 opacity readings to measure opacity from the 

ferroalloy production buildings and demonstrate that those readings are below an established 

opacity limit in the rule. Opacity limits can ensure effective capture and control of these fugitive 

emissions if they are established at the appropriate levels and have appropriate compliance 

monitoring requirements to ensure the fugitive emissions are minimized continuously over time.

For this NESHAP, the EPA Method 9 option would involve taking opacity readings at the roof 

line above the furnace during a complete furnace cycle (e.g., from one tapping event to the next 

subsequent tapping event). Tapping at the furnaces occurs approximately every 2 hours (and 

typically lasts about 90 minutes), therefore the opacity readings during each cycle would take 

approximately 90 minutes. We assume the reader would also need another 30 minutes for set-up 

and documentation. Therefore, each reading would require 2 hours of labor. As a result, the cost 

for doing Method 9 opacity readings was estimated to be approximately $200 per furnace for 

each occurrence, which includes the costs for labor (technical, managerial, and administrative). 

Assuming that facilities would need to do the Method 9 opacity readings once per week per 

furnace, we estimate that the annual operating costs would be $10,400 per furnace. The same 

costs would also apply to the MOR. Therefore, the total costs for Opacity readings for the source 

category (assuming once per week for each of the 5 furnaces and for the one MOR operation) is 

estimated to be $62,400 per year (or $31,200 per facility). 

4.3.2 Digital Opacity Compliance System

Another compliance monitoring option that is being considered is the use of a Digital Opacity 

Compliance System (DOCS). The DOCS translates images from an imaging digital camera into 

visual plume opacity measurements using computer software, and is proposed as an alternate 

reporting method to EPA Method 9 (see Preliminary Method 008). Currently the American 

Society for Testing and Materials (ASTM) has approved a method for the use of the DOCS (see 

ASTM D7520-09). For this option, the DOCS would read 6 minutes of opacity every hour 

during the daylight at the roof of each of the ferroalloy production buildings (every day per 

year). The cost for setting up the system was estimated to be $4,900 per furnace building, 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. Annual 

cost of operating the system per furnace building was estimated to be $129,000 and includes the 

costs for the software license, analyzing and review of images, and quarterly reporting of results. 
14

As explained in the FR Notice, EPA is also considering the possibility of including a provision in 

the rule whereby if a facility achieves DOCS readings over an extended period of time that are 

well below the opacity limit then that facility may be able to reduce the frequency of such 

readings and therefore the annual operating costs would also decrease accordingly.

4.3.3 Roof Monitors

The third option that is being considered involves the use of PM monitors to capture and measure 

the fugitive emissions from the roof vents of the ferroalloy production buildings. The monitors 

would capture PM on a Teflon filter and the filters would be analyzed for manganese (Mn). In 

addition, the velocity of the fugitive emissions would be measured and used to calculate fugitive 

Mn emission rates. The EPA is considering an option where the system would include 3 PM 

monitors installed along the length of the roof opening for each furnace building. Each monitor 

would capture 2 to 5 samples per monitor each week. The capital cost of the monitors, filter, and 

filter holders are estimated to be $25,770 for each furnace building. The capital cost of the 

anemometers and associated equipment are estimated to be $2,414. The total cost of installing 

the PM monitoring system is estimated to be $166,000 per building and includes the cost of 

equipment, mounting labor, operating labor, filter analysis, filter shipping, data acquisition and 

reporting of the analyses. Annual operating costs are estimated to be between $60,000 and 

$150,000 per building depending on the number of samples taken each week. 

4.3.4 Fenceline Ambient Monitoring:

The fourth option being considered is fugitive fence line filter based measurements of particulate 

matter and manganese emissions at the facilities with no less than 3 monitoring systems at the 

property boundaries to monitor trends in ambient concentrations at these locations and to use this 

information (along with meteorological data and modeling tools) to attempt to quantify trends in 

emissions that are leaving and entering the facility property. The rental cost for each monitoring 

system is estimated to be $20,000 per year. If we assume each monitor takes one 24-hour sample 

of PM and manganese every 6 days (i.e., about 70 samples per year) and the analysis is 

approximately $100 per sample then the total costs for lab analyses would be $7,000 per 

year. Regarding the labor to obtain the filter samples and replace with new filters, we estimated 1 

hour of labor per sample for an additional $7,000 per year. This yields an annual cost of $34,000 

per monitor which would be a total operating cost of approximately $100,000 per year per 

facility. 
15

Attachment 1:

Cost Estimate Provided by Eramet Marietta
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Attachment 2:

Cost Estimate Provided by Felman Production
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Attachment 3:

Additional Detailed Cost Estimates for Felman
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Attachment 4:

Revised Building Ventilation Cost Estimates for Felman
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