E.O. 12866 Ferroalloys RIA 2060-AQ11 Proposal 20111006

Regulatory Impact Analysis (RIA) for the 

Proposed Manganese Ferroalloys RTR 

Final Report
November 2011

Regulatory Impact Analysis (RIA) for the Proposed Manganese Ferroalloys RTR 

By:

Larry Sorrels and Souad Benromdhane

U.S. Environmental Protection Agency

Office of Air Quality Planning and Standards (OAQPS)

Air Economics Group (AEG) and Risk and Benefits Group (RBG)

Research Triangle Park, NC 27711

U.S. Environmental Protection Agency

Office of Air Quality Planning and Standards

Health and Environmental Impacts Division

Research Triangle Park, North Carolina
iii

CONTENTS

Section Page

Table of Contents

Contents................................................................................................................................... iii

Section 1 Executive Summary............................................................................................... 1-1

1.1 Analysis Summary............................................................................................... 1-1

1.2 Organization of this Report.................................................................................. 1-2

Section 2 Introduction............................................................................................................ 2-1

2.1 Background for Proposed Rule............................................................................ 2-1

2.1.1 What is this source category and how did the MACT regulate its 

HAP emissions? ....................................................................................... 2-1

Section 3 Industry Profile ...................................................................................................... 3-1

Section 4 Baseline Emissions, Emission Reductions, And Costs.......................................... 4-1

4.1 Introduction.......................................................................................................... 4-1

Section 5 Economic Impact Analysis and Statutory and Executive Order Analyses............ 5-1

5.1 Background.......................................................................................................... 5-1

5.2 Regulatory Flexibility Act ................................................................................... 5-1

5.3 Energy Impacts .................................................................................................... 5-2

5.4 Unfunded Mandates Reform Act......................................................................... 5-3

5.4.1 Future and Disproportionate Costs ............................................................ 5-3

5.4.2 Effects on the National Economy ............................................................ 5-3
iv

5.5 Executive Order 13045: Protection of Children from Environmental 

Health Risks and Safety Risks............................................................................. 5-3

5.6 Executive Order 12898: Federal Actions to Address Environmental Justice 

in Minority Populations and Low-Income Populations....................................... 5-4

5.7 Employment Impacts Analysis.................................................................. 5-6

5.7.1 Employment Impacts from Pollution Control Requirements.........................5-8

5.7.2 Employment Impacts on the Regulatory Industry.................................. .5-11

Section 6 Human Health Benefits of Emissions Reductions................................................. 6-1

6.1 Synopsis............................................................................................................... 6-1

6.2 Calculation of PM2.5 Human Health Benefits...................................................... 6-1

6.3 Unquantified Benefits........................................................................................ 6-12

6.3.1 HAP Benefits......................................................................................... 6-12

6.4 Characterization of Uncertainty in the Monetized PM2.5 Benefits..................... 6-23

Section 7 Comparison of Monetized Benefits and Costs..................................................... 7-28

7.1 Summary............................................................................................................ 7-28

Section 8 References For RIA ...................................................................................................1
1-1

SECTION 1

EXECUTIVE SUMMARY

The U.S. Environmental Protection Agency (EPA) is proposing amendments to the 

national emissions standards for hazardous air pollutants (NESHAP) for Ferroalloys Production 

to address the results of the residual risk and technology review that EPA is required to conduct 

by the Clean Air Act. These proposed amendments include revisions to particulate matter 

standards for electric arc furnaces, metal oxygen refining process, and crushing and screening 

operations. The amendments add hydrochloric acid, mercury, polycyclic aromatic hydrocarbons, 

and formaldehyde emission limits to electric arc furnaces. The amendments also expand and 

revise the requirements to control fugitive emissions from furnace operations and casting. Other 

requirements related to testing, monitoring, notification, recordkeeping, and reporting 

requirements are included. We are also proposing to revise provisions addressing periods of 

startup, shutdown, and malfunction to ensure that the rules are consistent with a recent court 

decision. 

This is an economically significant rule as defined by Executive Order 12866 since the 

annual effects (in this case, benefits) are estimated to exceed $100 million. Therefore, EPA is 

required to develop a regulatory impact analysis (RIA) as part of the regulatory process. The RIA 

includes an economic impact analysis (EIA), and a benefits analysis along with documentation 

for the methods and results.

1.1 Analysis Summary

The key results of the RIA are as follows:

Engineering Cost Analysis: EPA estimates the revised NESHAP’s total 

annualized costs will be $4.0 million ($2010). This estimate includes all of the 

compliance costs, with both control and administrative (monitoring, testing) costs 

included. 

Economic Impact Analysis: The economic impacts for the firms affected by this 

proposed rule range are annual compliance costs of less than 0.01 percent of sales. 

Thus, consumers will also experience minimal changes in the price of ferroalloy 

output. 

Social Cost Analysis: The estimated social cost of the major source rule will be

$4.0 million, which is also the total annualized cost of compliance ($2010).

Small Entity Analyses: Neither of the two affected firms are small businesses 

according to the Small Business Administration’s (SBA’s) small business size 

standard for this industry. Thus, there are no small business or entity impacts 

associated with this proposed rule. 
1-2

 Benefits Analysis:

– The benefits from reducing some air pollutants have not been monetized in 

this analysis, including reducing arsenic, chromium, nickel, manganese, 

mercury, polycyclic aromatic hydrocarbons (PAH) and other HAP emissions.

We assessed the benefits of these emission reductions qualitatively later in 

this analysis.

– We monetized the benefits from reducing particulate matter (PM). Thus all 

monetized benefits reported reflect decreases in ambient PM2.5 concentrations

due to reduction of close to 257 tons of PM2.5. Although the monetized 

benefits likely underestimate the total benefits, the extent of the underestimate 

is unclear. 

– Using a 3% discount rate, we estimated the total monetized benefits of the 

proposed rule to be $71 million to $170 million (2010 dollars) in the year of 

analysis (2015). Using a 7% discount rate, we estimate the total monetized 

benefits of the proposed rule to be $63 billion to $160 billion (2010 dollars) in 

2015. Using alternative relationships between PM2.5 and premature mortality 

supplied by experts, higher and lower benefits estimates are plausible, but 

most of the expert-based estimates fall between these estimates. 

Net Benefits: For the ferroalloys proposal, the net benefits are $67 million to $170

million in 2015 at a 3% discount rate for the benefits and $59 million to $150 million in 2015 at 

a 7% discount rate for the benefits. These results are shown in Table 1-1.

1.2 Organization of this Report

The remainder of this report supports and details the methodology and the results of the 

RIA:

 Section 2 describes the proposed regulation.

 Section 3 presents the profile of the affected industry.

 Section 4 describes the baseline emissions and emission reductions for the proposed 

regulation.

 Section 5 describes the economic impacts and analyses to comply with Executive 

Orders.

 Section 6 presents the benefits estimates.

 Section 7 presents the net benefits of the proposed rule.

 Section 8 contains the references for the RIA. 
1-3

Table 1-1. Summary of the Annual Monetized Benefits, Social Costs, and Net Benefits for 

the Proposed Ferroalloys RTR in 2015 ($2010 millions)

a

3% Discount Rate 7% Discount Rate

Proposed Standard 

Total Monetized Benefitsb$71 to $170 $63 to $160

Total Social Costs $4.0 $4.0

Net Benefits $67 to $170 $59 to $150

Nonmonetized Benefits Reduced exposure to HAPs, including arsenic, chromium, nickel, manganese, 

mercury and polycyclic aromatic hydrocarbons

Ecosystem effects

Visibility impairment

a All estimates are for the year of implementation (2015) and are rounded to two significant figures. These results 

include units anticipated to come online and the lowest cost disposal assumption. 

b The total monetized benefits reflect the human health benefits associated with reducing exposure to PM2.5 through 

reductions of directly emitted PM2.5 .It is important to note that the monetized benefits include many but not all 

health effects associated with PM2.5 exposure. Benefits are shown as a range from Pope et al. (2002) to Laden et 

al. (2006). These models assume that all fine particles, regardless of their chemical composition, are equally 

potent in causing premature mortality because the scientific evidence is not yet sufficient to allow differentiation 

of effect estimates by particle type. 
SECTION 2

INTRODUCTION

2.1 Background for Proposed Rule

2.1.1 What is this source category and how did the MACT regulate its HAP 

emissions?

The NESHAP (or MACT rule) for Ferroalloys Production: Ferromanganese and 

Silicomanganese was promulgated on May 20, 1999 (64 FR 27450) and codified at 40 

CFR part 63, subpart XXX.1The 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 promulgation. Since then, one other producer of silicomanganese 

has started production.

Today, there are two ferroalloys production facilities that are subject to the 

MACT rule. No new ferroalloys production facilities have been built in over 20 years, 

and we anticipate no new ferroalloys production facilities in the foreseeable future, 

although one facility is currently exploring expanding operations. 

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. 

Ferroalloys within the scope of this source category are produced using 

submerged electric arc furnaces, which are furnaces in which the electrodes are 

submerged into the charge. The submerged arc process is a reduction smelting operation. 

The reactants consist of metallic ores (ferrous oxides, silicon oxides, manganese oxides, 

etc.) and a carbon-source reducing agent, usually in the form of coke, charcoal, high- and 

low-volatility coal, or wood chips. Raw materials are crushed and sized and then 

conveyed to a mix house for weighing and blending. Conveyors, buckets, skip hoists, or 

cars transport the processed material to hoppers above the furnace. The mix is gravity-fed 

 

1 The emission limits were revised on March 22, 2001 (66 FR 16024) in response to a petition for 

reconsideration submitted to EPA following promulgation of the final rule, and a petition for review 

filed in the U.S. Court of Appeals for the District of Columbia Circuit.
through a feed chute either continuously or intermittently, as needed. At high 

temperatures in the reaction zone, the carbon source reacts with metal oxides to form 

carbon monoxide and to reduce the ores to base metal.2The molten material (product and 

slag) is tapped from the furnace, sometimes subject to post-furnace refining, and poured 

into casting beds on the furnace room floor. Once the material hardens, it is transported to 

product crushing and sizing systems and packaged for transport to the customer.

HAP generating processes include electrometallurgical (furnace) operations 

(primary and tapping), other furnace room operations (ladle treatment and casting), 

building fugitives, raw material handling and product handling. HAP are emitted from 

ferroalloys production as process emissions, process fugitive emissions, and outdoor 

fugitive dust emissions. 

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

furnace control device, metal oxygen refining control device and crushing operations 

control device. The HAP in process emissions are primarily composed of metals (mostly 

manganese, arsenic, nickel, lead and chromium) and also may include organic 

compounds that result from incomplete combustion of coal or coke that is charged to the 

furnaces as a reducing agent. There is also evidence of mercury emissions. There are 

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 result from the entrainment of HAP 

in ambient air due to material handling, vehicle traffic, wind erosion from storage piles, 

and other various activities. Outdoor fugitive dust emissions are composed of metal HAP 

only.

The MACT rule applies to process emissions 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 such as roadways, yard areas, and 

outdoor material storage and transfer operations. For process sources, the NESHAP 

specifies numerical emissions limits for particulate matter (as a surrogate for metal HAP) 

from the electric (submerged) arc furnaces (including primary and tapping emissions), 

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

 

2 U.S. Environmental Protection Agency. AP-42, 12.4. Ferroalloy Production. October 1986. 
limits (again as a surrogate for metal HAP) are also in place for the metal oxygen refining 

process and product crushing and screening equipment. Table 2-1 contains a summary of 

the applicable limits.
Table 2-1. Emission Limits in Subpart XXX

New or Reconstructed 

or Existing Source

Affected Source Applicable PM Emission 

Standards

Subpart XXX 

Reference

New or reconstructed Submerged arc furnace 0.23 kilograms per hour per 

megawatt (kb/hr/MW) (0.51 

pounds per hour per 

megawatt (lb/hr/MW) or 35 

milligrams per dry standard 

cubic meter (mg/dscm) (0.015 

grains per dry standard cubic 

foot (gr/dscf)

40 CFR 

63.1652(a)(1) and 

(a)(2)

Existing Open submerged arc furnace producing 

ferromanganese and operating at a furnace 

power input of 22 MW or less

9.8 kg/hr (21.7 lb/hr) 40 CFR 

63.1652(b)(1)

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) 40 CFR 

63.1652(b)(2)
New or Reconstructed 

or Existing Source

Affected Source Applicable PM Emission 

Standards

Subpart XXX 

Reference

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) 40 CFR 

63.1652(b)(3)

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) 40 CFR 

63.1652(b)(4)

Existing Semi-sealed submerged arc furnace 

(primary, tapping, and vent stacks) 

producing ferromanganese

11.2 kg/hr (24.7 lb/hr) 40 CFR 63.1652(c)

New, reconstructed, or 

existing

Metal oxygen refining process 69 mg/dscm (0.03 gr/dscf) 40 CFR 63.1652(d)

New or reconstructed Individual equipment associated with the 

product crushing and screening operation

50 mg/dscm (0.022 gr/dscf) 40 CFR 

63.1652(e)(1)

Existing Individual equipment associated with the 

product crushing and screening operation

69 mg/dscm (0.03 gr/dscf) 40 CFR 

63.1652(e)(2)
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-munute 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 

specified in §63.1653.

For outdoor fugitive dust sources, as defined in §63.1651, the 1999 NESHAP requires 

that plants prepare and 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. The owner or operator must submit a copy 

of the outdoor fugitive dust control plan to the designated permitting authority on or before the 

applicable compliance date. 

2.1.2 What data collection activities were conducted to support this action?

In April 2010, we issued an information collection request (ICR), pursuant to CAA 

section 114, to the two companies that own and operate the two ferroalloys production facilities 

producing ferromanganese and silicomanganese. The ICR requested available information 

regarding process equipment, control devices, point and fugitive emissions, practices used to 

control fugitive emissions, and other aspects of facility operations. The two companies 

completed the surveys for their facilities and submitted the responses to us in the fall of 2010. 

We also requested that the two facilities conduct additional emissions tests in 2010 for certain 

HAP from specific processes that were considered representative of the industry. Pollutants 

tested included most HAP metals, hydrochloric acid, hydrofluoric acid, formaldehyde, mercury, 

polycyclic aromatic hydrocarbons and dioxins and furans. The results of these tests were 

submitted to the EPA in the fall of 2010 and are available in the docket for this action.

The proposed rule is economically significant according to Executive Order 12866. As 

part of the regulatory process of preparing these standards, EPA has prepared a regulatory impact 

analysis (RIA). This analysis includes an analysis of impacts to small entities as part of 

compliance with the Small Business Regulatory Enforcement Fairness Act (SBREFA) and 

analyses to comply with other Executive Orders.
3-1

SECTION 3

INDUSTRY PROFILE

EPA has developed this industry profile to provide the reader with a general 

understanding of the technical and economic aspects of the industry that would be directly 

affected by this proposal.

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. 

Ferroalloys within the scope of this source category are produced using submerged 

electric arc furnaces, which are furnaces in which the electrodes are submerged into the charge. 

The submerged arc process is a reduction smelting operation. The reactants consist of metallic 

ores (ferrous oxides, silicon oxides, manganese oxides, etc.) and a carbon-source reducing agent, 

usually in the form of coke, charcoal, high- and low-volatility coal, or wood chips. Raw 

materials are crushed and sized and then conveyed to a mix house for weighing and blending. 

Conveyors, buckets, skip hoists, or cars transport the processed material to hoppers above the 

furnace. The mix is gravity-fed through a feed chute either continuously or intermittently, as 

needed. At high temperatures in the reaction zone, the carbon source reacts with metal oxides to 

form carbon monoxide and to reduce the ores to base metal.1The molten material (product and 

slag) is tapped from the furnace, sometimes subject to post-furnace refining, and poured into 

casting beds on the furnace room floor. Once the material hardens, it is transported to product 

crushing and sizing systems and packaged for transport to the customer.

Ferroalloys are master alloys containing iron and one or more non-ferrous metals as 

alloying elements. The ferroalloys are usually classified in two groups: bulk ferroalloys 

(produced in large quantities in electric arc furnaces), and special ferroalloys (produced in 

smaller quantities, but with growing importance). Bulk ferroalloys are used in steel making and 

 

1 U.S. Environmental Protection Agency. AP-42, 12.4. Ferroalloy Production. October 1986. 
3-2

steel or iron foundries exclusively, while the use of special ferroalloys is far more varied (used in 

batteries, animal feed). The U.S. military is a particularly notable consumer of manganese: In 

its weapons systems and munitions, the Department of Defense uses approximately 25,000 short 

tons of manganese ore chemical/metal grade, 7,900 short tons of ferro-manganese (either carbon 

or silicon) and 1,370 short tons of electrolytic manganese metal (EMM) each year. Manganese 

is a key ingredient in the production of ferroalloys for use in the steel and other industries. 

According the U.S. Geological Survey, ―there are no substitutes for manganese in its major 

applications - the manufacture of steel, steel alloys, non-steel alloys, batteries, and fertilizers and 

animal feed.‖ (USGS, 2008). In total, about 87 % of the ferroalloys produced are used in the 

steel industry (European Commission, 2001).

Very little ferroalloy production takes place in the U.S. and Canada. Less than 1 percent 

of worldwide ferroalloy production takes place in the United States (SFSA, 2008). The amount 

of worldwide ferroalloy production occurs in North America has declined over time. As of 

2008, more than 56 percent of ferroalloy production took place in Asia (SFSA, 2008). The 

largest producer of ferroalloys is China, with more than 18 million tons produced in 2008. South 

Africa is second highest production, but is well behind China at around 4 million tons produced 

that same year. More than 80 percent of the ferroalloys consumed in the U.S. are imported. 

Worldwide, the top four ferroalloys produced are: ferrochromium (7.84 million metric 

tons), silicomanganese (7.46 million metric tons), ferrosilicon (7.32 million metric tons), and 

ferromanganese (5.7 million metric tons) (SFSA, 2008). 

Today, there are two ferroalloys production facilities that are subject to the MACT rule. 

No new ferroalloys production facilities have been built in over 20 years, and we anticipate no 

new ferroalloys production facilities in the foreseeable future, although one facility is currently 

exploring expanding operations. 

The affected facilities are owned by the Eramet Group and Group Privat. The Eramet 

Group is a French-owned conglomerate with more than 16,000 employees worldwide and 

revenues in 2010 of around $5 billion. Group Privat is a loose conglomerate of several large 

Ukrainian firms that have interests in metals, chemicals, banking, and other industries in that 
3-3

country and worldwide. There are at least 20,000 employees in this conglomerate and at least 

$10 billion in revenues generated in 2008. The ferroalloys produced by these firms’ U.S. 

facilities use manganese as an input, and the mines for this manganese are owned by these firms. 
4-1

SECTION 4

BASELINE EMISSIONS, EMISSION REDUCTIONS, AND COSTS

4.1 Introduction

This section presents the baseline emissions for the pollutants emitted by affected units and also 

the resulting emissions in 2015 after imposition of the proposed RTR rule. We present the baseline 

emissions and emission reductions for HAP and other emissions such as PM2.5. Emission reductions 

were calculated from the baseline emissions based on the proposed emissions limits, and the emission 

reductions were used as inputs to the benefits analysis presented in Section 7.

4.2 Summary Of Cost Estimates And Emissions Reductions For The Regulatory Options 

Considered 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 4-1. All the options considered in this analysis are summarized in Table 4-2, 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 the cost memorandum for this proposal. 
4-2

The emissions reductions associated with the control options 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. The HAP emission reductions estimated for this proposal are 83.6 tons. 

PM emissions in this memo refer to total PM. Of the total PM, approximately 41 percent of the 

emissions are fine particulate (PM2.5). Thus, of the 626 tons of total PM reduced, 257 tons are PM2.5. 
2

Table 4-1: 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 Pollutant

PM, Metal 

HAP

Hg, PAH, 

HCHO

PM, Metal 

HAP

PM, Metal 

HAP

PM, Metal 

HAP

PM, Metal 

HAP

$1,413,952 $1,512,930 $2,926,882 63.8 $23

$756,465 $756,465 19.8 $19

Note: Shaded options were not selected for proposal.

Felman

Annual Cost of Control Technology ($) Cost Effectiveness

Total Cost/Yr 

($)

HAP 

Reduction 

(Tons)

Cost 

Effectiveness 

($/lb HAP)

Eramet

Table 4-2: 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.
4-1

4.3 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.

4.3.1 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.

4.3.1.1Replacement 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 fugitive 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. 

4.3.2 Furnace Stack Emissions – Hg, PAH, Formaldehyde1

The selected standards for Hg and PAH are numeric emission standards that represent a 

beyond-the-floor 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 

 

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

this pollutant because there are no compelling risk or environmental reasons to control the relatively low levels 

of formaldehyde emitted at a beyond-the-floor level.
4-2

of the facilities would be required to implement controls for these pollutants.2 Estimated costs 

associated with these controls are presented here.

4.3.2.1Addition 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 tpy 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. 

 

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

Estimate Mercury Control Costs for the Ferroalloys Production Industry, September 8, 2011.
4-3

4.3.3 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.

4.3.3.1Improvements 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 tpy (and HAP emissions by 

6.9 tpy) 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. 

4.3.3.2Addition 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 tpy (and HAP emissions 

by 23 tpy) 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. 
4-4

4.3.3.3Building 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 tpy (and HAP emissions 

by 80.4 tpy) 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. 

4.3.3.4Tapping and Casting Control with 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.

4.3.5 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.
4-5

4.3.5.1Upgrade 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 tpy (and HAP 

emissions by 4.6 tpy) 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.

4.3.6 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.

4.4 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.

4.4.1 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 (also known as baghouses). 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. 
4-6

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 vendor was used in 

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

Manual3to 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. 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. 

4.4.2 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 

 

3 U.S. Environmental Protection Agency, EPA Air Pollution Control Cost Manual. October 2002, Sixth Edition, 

Found on the Internet at http://epa.gov/ttn/catc/products.html#cccinfo
4-7

hazardous waste (from contaminated carbon media) and avoid contamination of the saleable 

byproduct baghouse dust, it was 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 ACI were estimated using cost equations developed for the Utility NESHAP4

and information provided by activated carbon vendors.5 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.6

All costs for this estimate were adjusted to 2010 dollars using Chemical Engineering Plant Cost 

Indices (CEPCI). 7 We did not consider the downtime associated with installation for the unit in 

our costs.

4.4.3 Process Fugitive Emissions – Metal HAP

 

4

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/epaipm/docs/append5_3.pdf

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

6 U.S. Office of Management and Budget. Circular A-4, September 17, 2003. Found on the Internet at 

http://www.whitehouse.gov/omb/circulars_a004_a-4/#e. 

7 Estimates of the Chemical Engineering Plant Cost Index can be found at http://www.che.com. CEPCI values 

employed were: 539.1 for 2010, 575.4 for 2008, and 361.3 for 1991. 
4-8

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 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. 
4-9

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 Air Pollution Control Cost Manual) was used8, in conjunction with 

techniques described in the sixth edition of the EPA Air Pollution Control Cost Manual9

to 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 were adjusted to 2010 dollars using 

Chemical Engineering Plant Cost Indices (CEPCI). 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 

 

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

92

9

http://epa.gov/ttn/catc/products.html#cccinfo
4-10

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 Manual10 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 millionvia 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 (CEPCI). 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 

vendor 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 Manual11 to estimate total installed capital 

cost and annual costs. 

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 

 

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

11 http://epa.gov/ttn/catc/products.html#cccinfo
4-11

year life expectancy for the unit and, to be consistent with OMB Guidance in Circular A4, 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.
4-12

4.4.4 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 Manual12 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 

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

4.4 Summary of Cost By Facility 

Table 4-3 summarizes estimated costs for each facility in the Ferroalloys source category, 

assuming implementation of the emission reduction options selected for proposal.

 

12 http://epa.gov/ttn/catc/products.html#cccinfo
4-13

Table 4-3: 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.
5-1

SECTION 5

ECONOMIC IMPACT ANALYSIS AND STATUTORY AND EXECUTIVE ORDER 

ANALYSES

5.1 Background

In this chapter, we present the results of the economic impact analysis and analyses 

prepared in adherence to statutory and Executive Order requirements. 

5.2 Regulatory Flexibility Act

The Regulatory Flexibility Act (RFA) generally requires an agency to prepare a 

regulatory flexibility analysis of any rule subject to notice and comment rulemaking 

requirements under the Administrative Procedure Act or any other statute unless the agency 

certifies that the rule will not have a significant economic impact on a substantial number of 

small entities. Small entities include small businesses, small organizations, and small 

governmental jurisdictions. 

For purposes of assessing the impacts of this proposed rule on small entities, small entity 

is defined as: (1) a small business as defined by the Small Business Administration’s (SBA) 

regulations at 13 CFR 121.201; (2) a small governmental jurisdiction that is a government of a 

city, county, town, school district or special district with a population of less than 50,000; and (3) 

a small organization that is any not-for-profit enterprise that is independently owned and 

operated and is not dominant in its field. For this source category, which has the NAICS code 

331112 (i.e., Electrometallurgical ferroalloy product manufacturing), the SBA small business 

size standard is 750 employees according to the SBA small business standards definitions. 

After considering the economic impacts of today’s proposed rule on small entities, I 

certify that this action will not have a significant economic impact on a substantial number of 

small entities. Neither of the companies affected by this rule is considered to be a small entity per 

the definition provided in this section. 

Although this proposed rule will not have a significant economic impact on a substantial 

number of small entities, the EPA nonetheless has tried to reduce the impact of this rule on small 
5-2

entities. To reduce the impacts, we are proposing emissions standards in a format that allow 

companies flexibility on how best to comply with them. Moreover, we are proposing stack limits 

that are based on a weighted average approach (as described in Sections V.C and V.D of the 

preamble) and have been established at the least stringent levels that we estimate will still result 

in acceptable risks to public health. Thus, the proposed stack limits are based on the least costly 

approach that will still provide an ample margin of safety for human health and the environment. 

In addition, the proposed compliance testing requirements were established in a way that 

minimizes the costs for testing and reporting while still providing the Agency the necessary 

information needed to ensure continuous compliance with the proposed standards. We continue 

to be interested in the potential impacts of the proposed rule on small entities and welcome 

comments on issues related to such impacts.

5.3 Energy Impacts

Executive Order 13211 (66 FR 28355, May 22, 2001) provides that agencies will prepare 

and submit to the Administrator of the Office of Information and Regulatory Affairs, Office of 

Management and Budget, a Statement of Energy Effects for certain actions identified as 

―significant energy actions.‖ Section 4(b) of Executive Order 13211 defines ―significant energy 

actions‖ as any action by an agency (normally published in the Federal Register) that

promulgates or is expected to lead to the promulgation of a final rule or regulation, including 

notices of inquiry, advance notices of proposed rulemaking, and notices of proposed rulemaking: 

(1) (i) that is a significant regulatory action under Executive Order 12866 or any successor order, 

and (ii) is likely to have a significant adverse effect on the supply, distribution, or use of energy; 

or (2) that is designated by the Administrator of the Office of Information and Regulatory Affairs 

as a significant energy action.

This rule is not a significant energy action as designated by the Administrator of the 

Office of Information and Regulatory Affairs because it is not likely to have a significant adverse 

impact on the supply, distribution, or use of energy. This action will not create any new 

requirements and therefore no additional costs for sources in the energy supply, distribution, or 

use sectors.
5-3

5.4 Unfunded Mandates Reform Act

5.4.1 Future and Disproportionate Costs

The UMRA requires that we estimate, where accurate estimation is reasonably feasible, 

future compliance costs imposed by the rule and any disproportionate budgetary effects. Our 

estimates of the future compliance costs of the proposed rule are discussed previously in this 

RIA. We do not believe that there will be any disproportionate budgetary effects of the proposed 

rule on any particular areas of the country, state or local governments, types of communities 

(e.g., urban, rural), or particular industry segments.

5.4.2 Effects on the National Economy

The UMRA requires that we estimate the effect of the proposed rule on the national 

economy. To the extent feasible, we must estimate the effect on productivity, economic growth, 

full employment, creation of productive jobs, and international competitiveness of U.S. goods 

and services if we determine that accurate estimates are reasonably feasible and that such effect 

is relevant and material. The nationwide economic impact of the proposed rule is presented 

earlier in this RIA chapter. This analysis provides estimates of the effect of the proposed rule on 

most of the categories mentioned above, and these estimates are presented earlier in this RIA 

chapter. The nature of this rule is such that it is not practical for us to use existing approaches, 

such as the Morgenstern et al. approach,

1

to estimate the impact on employment to the regulated 

entities and others from this proposed rule. In addition, we have determined that the proposed 

rule contains no regulatory requirements that might significantly or uniquely affect small 

governments. Therefore, today’s rule is not subject to the requirements of section 203 of the 

UMRA. 

5.5 Executive Order 13045: Protection of Children from Environmental Health Risks 

and Safety Risks

Executive Order 13045, ―Protection of Children from Environmental Health Risks and 

Safety Risks‖ (62 FR 19885, April 23, 1997), applies to any rule that (1) is determined to be 

―economically significant,‖ as defined under Executive Order 12866, and (2) concerns an 

environmental health or safety risk that EPA has reason to believe may have a disproportionate 

effect on children. If the regulatory action meets both criteria, EPA must evaluate the 

environmental health or safety effects of the planned rule on children and explain why the 

 

1 Morgenstern, R. D., W. A. Pizer, and J. S. Shih. 2002. ―Jobs versus the Environment: An Industry-Level 

Perspective.‖ Journal of Environmental Economics and Management 43(3):412-436.
5-4

planned regulation is preferable to other potentially effective and reasonably feasible alternatives 

considered by the Agency.

This proposed rule is not subject to Executive Order 13045 (62 FR 19885, April 23, 

1997) because the Agency does not believe the environmental health risks or safety risks 

addressed by this action present a disproportionate effect on children. If the regulatory action 

meets both criteria, the EPA must evaluate the environmental health or safety effects of the 

planned rule on children and explain why the planned regulation is preferable to other potentially 

effective and reasonably feasible alternatives considered by the Agency. 

This proposed rule is not subject to Executive Order 13045 (62 FR 19885, April 23, 

1997) because the Agency does not believe the environmental health risks or safety risks 

addressed by this action present a disproportionate risk to children. The report, Analysis of 

Socio-Economic Factors for Populations Living Near Ferroalloys Facilities, shows that on a 

nationwide basis, there are approximately 26,000 people exposed to a cancer risk at or above 1-

in-1 million and approximately 28,000 people exposed to a chronic noncancer TOSHI greater 

than 1 due to emissions from the source category. Except for persons in the ―Ages 65 and Up‖ 

demographic group which are slightly elevated compared to the national average, the 

percentages for the other demographic groups, including children 18 years and younger, are 

similar to or lower than their respective nationwide percentages.

This proposed rule is expected to reduce environmental impacts for everyone, including 

children. This action proposes emissions limits at the levels based on MACT, as required by the 

Clean Air Act. Based on our analysis, we believe that this rule does not have a disproportionate 

impact on children. 

The public is invited to submit comments or identify peer-reviewed studies and data that 

assess effects of early life exposure to manganese, lead, arsenic, nickel, or mercury.

5.6 Executive Order 12898: Federal Actions to Address Environmental Justice in 

Minority Populations and Low-Income Populations

Executive Order 12898 (59 FR 7629 (Feb. 16, 1994)) establishes federal executive policy 

on environmental justice. Its main provision directs federal agencies, to the greatest extent 

practicable and permitted by law, to make environmental justice part of their mission by 

identifying and addressing, as appropriate, disproportionately high and adverse human health or 

environmental effects of their programs, policies, and activities on minority populations and lowincome populations in the United States.
5-5

For the proposed ferroalloys rule, the EPA has determined that the current health risks 

posed to anyone by emissions from this source category are unacceptable. There are about 

26,000 to 28,000 people nationwide that are currently subject to health risks which are nonnegligible (i.e., cancer risks greater than 1 in a million or chronic noncancer TOSHI greater than 

1) due to emissions from this source category. The demographic distribution of this ―at-risk‖ 

population is similar or below the national distribution of demographics for all groups except for 

the ―ages 65 and up‖ age group, which is 4 percent greater than its corresponding national 

percentage. The proposed rule will reduce the number of people in this at-risk group from 26,000 

- 28,000 people to about 1,000 people, thereby providing disproportionate benefits to a greater 

percentage of minorities. Therefore, the EPA has determined that the proposed rule will not have 

disproportionately high and adverse human health or environmental effects on minority or lowincome populations. Further, since it so significantly reduces the at-risk population in the process 

of ensuring public health protection with an ample margin of safety, it will actually provide 

disproportionate benefit to people ages 65 and up since they comprise a larger portion of the 

current at-risk group.

5.7 Employment Impact Analysis

In addition to addressing the costs and benefits of the proposed rule, EPA has analyzed 

the potential impacts of this rulemaking on employment, which are presented in this section. 

While a standalone analysis of employment impacts is not included in a standard cost-benefit 

analysis, such an analysis is of particular concern in the current economic climate of sustained 

high unemployment. Executive Order 13563, states, ―Our regulatory system must protect public 

health, welfare, safety, and our environment while promoting economic growth, innovation, 

competitiveness, and job creation‖ (emphasis added). Therefore, we seek to inform the 

discussion of labor demand and job impacts by examining labor requirements for the installation, 

operation, and maintenance of control requirements, as well as reporting and recordkeeping 

requirements. Unlike several recent RIAs, however, we do not provide estimates based on the 

study by Morgenstern et al. (2002); we discuss this decision after presenting estimates of the 

labor requirements associated with reporting and recordkeeping and the installation, operation, 

and maintenance of control requirements. Nor have we quantified the rule’s effects on labor in 

other sectors not regulated by the proposed rule, or the effects induced by changes in workers’ 

incomes. As such, this analysis presents only the gross increase in labor demand caused by the 
5-6

rule. It does not account for possible decreases in labor demand caused by any reduction in 

output or change in production technology.

What follows is an overview of the various ways that environmental regulation can affect 

employment, followed by a discussion of the estimated impacts of this rule. EPA continues to 

explore the relevant theoretical and empirical literature and to seek public comments in order to 

ensure that such estimates are as accurate, useful and informative as possible.

From an economic perspective labor is an input into producing goods and services; if 

regulation requires that more labor be used to produce a given amount of output, that additional 

labor is reflected in an increase in the cost of production. Moreover, when the economy is at full 

employment, we would not expect an environmental regulation to have an impact on overall 

employment because labor is being shifted from one sector to another. On the other hand, in 

periods of high unemployment, an increase in labor demand due to regulation may result in a 

short-term net increase in overall employment due to the potential hiring of previously 

unemployed workers by the regulated sector to help meet new requirements (e.g., to install new 

equipment) or by the environmental protection sector to produce new abatement capital. With 

significant numbers of workers unemployed, the opportunity costs associated with displacing 

jobs in other sectors are likely to be smaller.

To provide a partial picture of the employment consequences of this rule, EPA takes two 

approaches. First, EPA uses information derived from its cost estimation documentation to 

generate estimates of employment impacts. Second, the analysis considers the results of 

Morgenstern, Pizer, and Shih (2002) in estimating the effects of the regulation on the regulated 

industry. This approach has been used by EPA previously in Regulatory Impact Analyses 

prepared recently. EPA is interested in public comments on the merits of including information 

derived in this fashion for assessing the employment consequences of regulations.

5.7.1 Employment Impacts from Pollution Control Requirements

When a new regulation is promulgated, a response of industry is to order pollution control 

equipment and services in order to comply with the regulation when it becomes effective. 
5-7

Revenue and employment in the environmental technology industry have grown steadily 

between 2000 and 2008, reaching an industry total of approximately $300 billion in revenues and 

1.7 million employees in 2008.2 While these revenues and employment figures represent gains 

for the environmental technologies industry, they are costs to the regulated industries required to 

install the equipment. Moreover, it is not clear the 1.7 million employees in 2008 represent new 

employment as opposed to workers being shifted from the production of goods and services to 

environmental compliance activities.

Once the equipment is installed, regulated firms may hire workers to operate and 

maintain the pollution control equipment – much like they hire workers to produce more output. 

Morgenstern et al. (2002) examined how regulated industries respond to regulation. The authors 

found that, on average for the industries they studied, employment increases in regulated firms. 

Of course, these firms may also reassign existing employees to perform these activities.

We do not estimate any potential changes in labor outside of the affected sector. This analysis 

estimates the employment impacts due to the installation, operation, and maintenance of control 

equipment, as well as employment associated with new reporting and recordkeeping 

requirements.

The employment analysis uses a bottom-up engineering-based methodology to estimate 

employment impacts. The engineering cost analysis summarized earlier in this RIA includes 

estimates of the labor requirements associated with implementing the proposed regulations. Each 

of these labor changes may either be required as part of an initial effort to comply with the new 

regulation or required as a continuous or annual effort to maintain compliance. We estimate up-

 

2

In 2008, the industry totaled approximately $315 billion in revenues and 1.9 million employees including indirect

employment effects, pollution abatement equipment production employed approximately 4.2 million workers in

2008. These indirect employment effects are based on a multiplier for indirect employment = 2.24 (1982 value

from Nestor and Pasurka - approximate middle of range of multipliers 1977-1991). Environmental Business

International (EBI), Inc., San Diego, CA. Environmental Business Journal, monthly (copyright).

http://www.ebiusa.com/ EBI data taken from the Department of Commerce International Trade Administration

Environmental Industries Fact Sheet from April 2010:

http://web.ita.doc.gov/ete/eteinfo.nsf/068f3801d047f26e85256883006ffa54/4878b7e2fc08ac6d85256883006c45

2c?OpenDocument
5-8

front and continual, annual labor requirements by estimating hours of labor required and 

converting this number to full-time equivalents (FTEs) by dividing by 2,080 (40 hours per week 

multiplied by 52 weeks). We note that this type of FTE estimate cannot be used to make 

assumptions about the specific number of people involved or whether new jobs are created for 

new employees.

The results of this employment estimate are presented in Table 5-1 for the proposed 

NESHAP. The tables breaks down the installation, operation, and maintenance estimates by type 

of pollution control evaluated in the RIA and present both the estimated hours required and the 

conversion of this estimate to FTE. For the proposed NESHAP, reporting and recordkeeping 

requirements were estimated requirements were estimated for the entire rule rather than by 

anticipated control requirements; the reporting and recordkeeping estimates are consistent with 

estimates EPA submitted as part of its Information Collection Request (ICR) that is in the 

Supporting Statement for the proposed rule.

The up-front one-time labor requirement is estimated at 27 FTEs for the proposed 

NESHAP. These up-front FTE labor requirements can be viewed as short-term labor 

requirements required for affected entities to comply with the new regulation. Ongoing 

requirements are estimated at about 4 FTEs for the proposed NESHAP. These ongoing FTE 

labor requirements can be viewed as sustained labor requirements required for affected entities to 

continuously comply with the new regulation. It is important to recognize that these seemingly 

precise estimates are not to be assumed to be exact measures of the employment impacts of this 

rulemaking. They represent a rough approximation of the small positive impacts that this rule 

may have on employment.
5-9

Table 5-1. Labor-based Employment Estimates for Reporting and Recordkeeping and 

Installing, Operating, and Maintaining Control Equipment Requirements for Proposed 

NESHAP 

Source/Emissions 

Point/Requirement

Emission 

Control 

Measure

Projected 

No. of 

Affected 

Units

Per-Unit 

OneTime 

Labor 

Estimate 

(Hours)

Total 

OneTime 

Labor 

Estimate 

(Hours)

Total 

Annual 

Labor 

Estimate 

(Hours) 

One-Time 

Full-Time 

Equivalent

Annual 

Full-Time 

Equivalent

Furnace Shop Building 

Ventilatio

n 3

 

13,636 

 

40,909 

 

3,564 19.67 1.71

EAF1

ACI 2

 

545 

 

1,090 

 

904 0.52 0.43

EAF1 ACI + 

Polishing 

Baghouse 1

 

13,563 

 

13,563 

 

3,564 6.52 1.71

Monitoring & 

Testing2

N/A

2 Plants 190 0.00 0.09

Reporting & 

Recordkeeping2

N/A

2 Plants 150 300

 

70 0.14 0.03

TOTAL: 

27,895 

 

55,862

 

8,292 

 

26.9 

 

4.0 

Note: Full-time equivalents (FTE) are estimated by first multiplying the projected number of affected units by the 

per unit labor requirements and then dividing ing by 2,080 (40 hours multiplied by 52 weeks). Totals may not sum 

due to independent rounding.

N/A = Not Applicable.

ACI = Activated Carbon Injection.

1EAF = Electric Arc Furnace. Estimate is from Draft Cost Impacts of the Revised NESHAP for the Ferroalloys 

Production Source Category, October 21, 2011. 

2 Supporting Statement for NESHAP for Ferroalloys Production: Ferromanganese and Silicomanganese, October 27, 

2011. 

5.7.2 Employment Impacts within the Regulated Industry

In recent RIAs we have applied estimates from a study by Morgenstern, Pizer and Shih

(2002)3to derive the employment effects of new regulations within the regulated industry. (See, 

 

3 Morgenstern, R. D., W. A. Pizer, and J. S. Shih. 2002. Jobs versus the Environment: An Industry-Level 

Perspective.‖ Journal of Environmental Economics and Management 43(3):412-436.
5-10

for example, the Regulatory Impact Analyses for the recently released proposed MATS and final 

CSAPR regulations). Determining the direction of employment effects in the regulated industry 

is also challenging due to competing effects. Complying with the new or more stringent 

regulation requires additional inputs, including labor, and may alter the relative proportions of 

labor and capital used by regulated firms in their production processes. Morgenstern, et al. 

(2002) demonstrate that environmental regulations can be understood as requiring regulated 

firms to add a new output (environmental quality) to their product mixes. Although legally 

compelled to satisfy this new demand, regulated firms have to finance this additional production 

with the proceeds of sales of their other (market) products. Satisfying this new demand requires 

additional inputs, including labor, and may alter the relative proportions of labor and capital used 

by regulated firms in their production processes. It should be noted that this study assumes that 

the regulated entities will comply with the regulation and continue to operate. It does not 

provide information on potential entry and exit decisions by firms in the regulated sectors and 

subsequent employment impacts from those decisions.

More specifically, Morgenstern, Pizer, and Shih (2002) decompose the effect of 

regulation on net employment in the regulated sector into the following three subcomponents:

 The Demand Effect: higher production costs from complying with the regulation will 

raise market prices, reducing consumption (and production), thereby reducing 

demand for labor within the regulated industry. The ―extent of this effect depends on 

the cost increase passed on to consumers as well as the demand elasticity of industry 

output.‖ (p. 416)

 The Cost Effect: Assuming that the capital/labor ratio in the production process is 

held fixed, as ―production costs rise, more inputs, including labor, are used to produce 

the same amount of output,‖ (p. 416). For example, to reduce pollutant emissions 

while holding output levels constant, regulated firms may require additional labor. 

 The Factor-Shift Effect: Regulated firms’ production technologies may be more or 

less labor intensive after complying with the regulation (i.e., more/less labor is 

 
5-11

required relative to capital per dollar of output). ―Environmental activities may be 

more labor intensive than conventional production,‖ meaning that ―the amount of 

labor per dollar of output will rise.‖ However, activities may, instead, be less labor 

intensive because ―cleaner operations could involve automation and less employment, 

for example.‖ (p. 416)

The demand effect is expected to have an unambiguously negative effect on employment, 

the cost effect to have an unambiguously positive effect on employment, and the factor-shift 

effect to have an ambiguous effect on employment. Without more information with respect to 

the magnitudes of these competing effects, it is not possible to predict the total effect 

environmental regulation will have on overall employment levels in the regulated sector.

Morgenstern et al. estimated the effects of pollution abatement expenditures on net 

employment in four highly polluting/regulated sectors (pulp and paper, plastics, steel, and 

petroleum refining in 1980s). They conclude that increased abatement expenditures generally 

have not caused a significant change in net employment in those sectors. More specifically, their 

results show that, on average across the industries studied, each additional $1 million (in 1987$) 

spent on pollution abatement results in a (statistically insignificant) net increase of 1.5 jobs. 

While the specific sectors Morgenstern et al. examined are different than the sectors considered 

here, the methodology that Morgenstern et al. developed is still an informative way to 

qualitatively assess the effects of this rulemaking on employment in the regulated sector.

While the theoretical framework laid out by Morgenstern et al. can hold for the 

ferroalloys industry under this proposal, important differences in the markets and regulatory 

settings analyzed in their study and the setting presented here lead us to conclude that it is 

inappropriate to utilize their quantitative estimates to estimate the employment impacts from this 

proposal. The differences between the underlying regulations motivating the abatement 

expenditures studied in Morgenstern et al. are potentially too many to allow for the direct 

transfer of their quantitative estimates for use in analysis of the proposed rule. There are 

important differences between the ferroalloy industry and the four manufacturing industries 

studied by Morgenstern et al. While the steel industry is one of the industries studied by 

Morgenstern et al., and ferroalloys is an important input to steel production, the differences in the 
5-12

two industries are significant enough to lead to questions about how applicable are the 

parameters in Morgenstern et al. in this analysis. In addition, the fact that this proposal only 

impacts a small subset of the regulated industry leads to concerns about whether the Morgenstern 

et al. approach, which uses compliance costs to analyze the impact of environmental compliance 

expenditures on industry employment levels, can be suitable to estimate employment impacts for 

this industry as part of this proposed rule. For these reasons we conclude there are too many 

uncertainties as to the comparability of the Morgenstern et al. study to apply their estimates to 

quantify the employment impacts within the regulated sector for this proposed regulation. 
6-1

SECTION 6

HUMAN HEALTH BENEFITS OF EMISSIONS REDUCTIONS

6.1 Synopsis

In this section, we provide an estimate of the monetized benefits associated with reducing 

particulate matter (PM) for the proposed NESHAP for Ferroalloys Production to address the 

results of the residual risk and technology review, RTR. For this rule, the PM reductions are the 

result of emission limits on the PM2.5. The total PM2.5 reductions are the consequence of the 

technologies installed to meet these limits. These estimates reflect the monetized human health 

benefits of reducing cases of morbidity and premature mortality among populations exposed to 

the PM2.5 reduced by this rulemaking. Using a 3% discount rate, we estimate the total monetized 

benefits of the proposed ferroalloy RTR to be $71 million to $170 million in the implementation 

year (2015). Using a 7% discount rate, we estimate the total monetized benefits of the Ferroalloy 

RTR to be $63 million to $160 million in the year of analysis (2015). All estimates are in 2010$.

These estimates reflect EPA’s most current interpretation of the scientific literature. 

Higher or lower estimates of benefits are possible using other assumptions; examples of this are 

provided in Figure 6-2 below. Data, resource, and methodological limitations prevented EPA 

from monetizing the benefits from several important benefit categories, including benefits from 

reducing hazardous air pollutants and visibility impairment. The benefits from reducing other air 

pollutants have not been monetized in this analysis, including reducing arsenic, chromium, 

nickel, manganese, mercury, polycyclic aromatic hydrocarbons (PAH) and other HAP emissions.

6.2 Calculation of PM2.5 Human Health Benefits

This rulemaking would reduce emissions of PM2.5, and the incidence of PM2.5-related 

health effects. For this rule, the PM reductions are the result of emission limits on directly 

emitted PM, which is used as a surrogate for metal HAP. The total PM2.5 reductions are the 

consequence of the technologies installed to meet these limits. Due to analytical limitations, it 

was not possible to provide a comprehensive estimate of PM2.5-related benefits. Instead, we used 

the ―benefit-per-ton‖ approach to estimate these benefits. The methodology employed in this 

analysis is similar to the work described in Fann, Fulcher, and Hubbell (2009), but represents an 

improvement that EPA feels leads to more reliable estimates of PM2.5-related health benefits for 

emissions reductions in specific sectors. The key assumptions are described in detail below. 
6-2

These PM2.5 benefit-per-ton estimates provide the total monetized human health benefits (the 

sum of premature mortality and premature morbidity) of reducing one ton of PM2.5 from a 

specified source. EPA has used the benefit per-ton technique in several previous RIAs, including 

the recent SO2 NAAQS RIA (U.S. EPA, 2010b). Table 6-1 shows the quantified and 

unquantified benefits captured in those benefit-per-ton estimates.

Table 6-1. Human Health and Welfare Effects of PM2.5 

Category Specific Effect

Effect Has 

Been 

Quantified

Effect Has 

Been 

Monetized

More 

Information

(refers to 

CSAPR RIA)

Improved Human Health

Reduced incidence of 

premature mortality 

from exposure to PM2.5

Adult premature mortality based on cohort 

study estimates and expert elicitation 

estimates (age >25 or age >30)

  Section 5.4

Infant mortality (age <1)   Section 5.4

Reduced incidence of 

morbidity from 

exposure to PM2.5

Non-fatal heart attacks (age > 18)   Section 5.4

Hospital admissions—respiratory (all ages)   Section 5.4

Hospital admissions—cardiovascular (age 

>20)   Section 5.4

Emergency room visits for asthma (all ages)   Section 5.4

Acute bronchitis (age 8-12)   Section 5.4

Lower respiratory symptoms (age 7-14)   Section 5.4

Upper respiratory symptoms (asthmatics 

age 9-11)   Section 5.4

Asthma exacerbation (asthmatics age 6-18)   Section 5.4

Lost work days (age 18-65)   Section 5.4

Minor restricted-activity days (age 18-65)   Section 5.4

Chronic Bronchitis (age >26)   Section 5.4

Emergency room visits for cardiovascular 

effects (all ages) -- -- Section 5.4

Strokes and cerebrovascular disease (age 

50-79) -- -- Section 5.4

Other cardiovascular effects (e.g., other 

ages) -- -- PM ISA2

Other respiratory effects (e.g., pulmonary 

function, non-asthma ER visits, nonbronchitis chronic diseases, other ages and 

populations)

-- -- PM ISA2

Reproductive and developmental effects 

(e.g., low birth weight, pre-term births, etc) -- -- PM ISA2,3

Cancer, mutagenicity, and genotoxicity 

effects -- -- PM ISA2,3

1 We assess these benefits qualitative due to time and resource limitations for this analysis.

2 We assess these benefits qualitatively because we do not have sufficient confidence in available data or methods.

3 We assess these benefits qualitatively because current evidence is only suggestive of causality or there are other 

significant concerns over the strength of the association.
6-3

Consistent with the Portland Cement NESHAP (U.S. EPA, 2009a), the PM2.5 benefits 

estimates utilize the concentration-response functions as reported in the epidemiology literature, 

as well as the 12 functions obtained in EPA’s expert elicitation study as a sensitivity analysis. 

 One estimate is based on the concentration-response (C-R) function developed from 

the extended analysis of American Cancer Society (ACS) cohort, as reported in Pope 

et al. (2002), a study that EPA has previously used to generate its primary benefits 

estimate. When calculating the estimate, EPA applied the effect coefficient as 

reported in the study without an adjustment for assumed concentration threshold of 

10 μg/m3as was done in recent (2006–2009) Office of Air and Radiation RIAs.

 One estimate is based on the C-R function developed from the extended analysis of 

the Harvard Six Cities cohort, as reported by Laden et al. (2006). This study, 

published after the completion of the Staff Paper for the 2006 PM2.5 NAAQS, has 

been used as an alternative estimate in the PM2.5 NAAQS RIA and PM2.5 benefits 

estimates in RIAs completed since the PM2.5 NAAQS. When calculating the estimate, 

EPA applied the effect coefficient as reported in the study without an adjustment for 

assumed concentration threshold of 10 μg/m3as was done in recent (2006–2009) 

RIAs.

 Twelve estimates are based on the C-R functions from EPA’s expert elicitation study 

(IEc, 2006; Roman et al., 2008) on the PM2.5 -mortality relationship and interpreted 

for benefits analysis in EPA’s final RIA for the PM2.5 NAAQS. For that study, twelve 

experts (labeled A through L) provided independent estimates of the PM2.5 -mortality 

concentration-response function. EPA practice has been to develop independent 

estimates of PM2.5 -mortality estimates corresponding to the concentration-response 

function provided by each of the twelve experts, to better characterize the degree of 

variability in the expert responses.

Readers interested in reviewing the general methodology for creating the benefit-per-ton 

estimates used in this analysis should consult the draft Technical Support Document (TSD) on 

estimating the benefits per ton of reducing PM2.5 and its precursors from the Ferroalloy Sector.1

The primary difference between the estimates used in this analysis and the estimates reported in 

Fann, Fulcher, and Hubbell (2009) is the air quality modeling data utilized. While the air quality 

data used in Fann, Fulcher, and Hubbell (2009) reflects broad pollutant/source category 

combinations, the source apportionment modeling data used in this analysis is sector-specific. As 

a result, the benefit-per-ton estimates presented herein better reflect the geographic areas and 

population likely to be affected by the proposed rule. In this analysis, we apply the national 

 

1 U.S. Environmental Protection Agency. 2011. Technical support document: Estimating the benefit per ton of 

reducing PM2.5 precursors from the ferroalloy sector (Draft); EPA: Research Triangle Park, NC.
6-4

average benefit-per-ton estimate for a 2016 analysis year and multiply it by the corresponding 

emission reductions of directly emitted PM2.5 to quantify the benefits of this rule. 

These models assume that all fine particles, regardless of their chemical composition, are 

equally potent in causing premature mortality because the scientific evidence is not yet 

sufficient to allow differentiation of effect estimates by particle type (U.S. EPA, 2009b) . 

Directly emitted PM is the only PM2.5 precursor affected by this rule. Even though we assume 

that all fine particles have equivalent health effects, the benefit-per-ton estimates vary between 

precursors because each ton of precursor reduced has a different propensity to form PM2.5 and a 

different pattern of transport, resulting geographic distribution of exposure. When more people 

are exposed, the benefits per ton are greater. For example, VOC emissions have a lower benefitper-ton estimate than direct PM2.5 because it does not directly transform into PM2.5 and because 

particles formed from VOC can transport many miles, including over areas with low populations. 

The benefit-per-ton coefficients in this analysis were derived using modified versions of the 

health impact functions used in the PM NAAQS Regulatory Impact Analysis. Specifically, this 

analysis uses the benefit-per-ton method first applied in the Portland Cement NESHAP RIA 

(U.S. EPA, 2009a), which incorporated three updates: a new population dataset, an expanded 

geographic scope of the benefit-per-ton calculation, and the functions directly from the 

epidemiology studies without an adjustment for an assumed threshold.2 Removing the threshold 

assumption is a key difference between the method used in this analysis of PM benefits and the 

methods used in RIAs prior to the Portland Cement proposal, and we now calculate incremental 

benefits down to the lowest modeled PM2.5 air quality levels. 

Based on our review of the current body of scientific literature, EPA estimated PMrelated mortality without applying an assumed concentration threshold. EPA’s Integrated 

Science Assessment for Particulate Matter (U.S. EPA, 2009b), which was reviewed by EPA’s 

Clean Air Scientific Advisory Committee (U.S. EPA-SAB, 2009a; U.S. EPA-SAB, 2009b), 

concluded that the scientific literature consistently finds that a no-threshold log-linear model 

most adequately portrays the PM-mortality concentration-response relationship while also 

 

2

These updates were already included in Fann et al. (2009). An example of the effect of these updates is available in 

the Portland Cement proposal RIA (U.S. EPA, 2009a). The benefit-per-ton estimates have also been updated 

since the Portland Cement proposal RIA (U.S. EPA, 2009a) to incorporate a revised VSL, as discussed on the next 

page. 
6-5

recognizing potential uncertainty about the exact shape of the concentration-response function. 

Consistent with this finding, we incorporated a ―Lowest Measured Level‖ (LML) assessment, 

which is a method EPA has employed in several recent RIA’s including the Cross-State Air 

Pollution Rule (U.S. EPA, 2011b). One key feature of this LML assessment is that it arrays the 

estimated PM2.5-related avoided deaths relative to an air quality scenario in which the Ferroalloyattributable PM2.5 would be eliminated entirely. While this is a conservative assumption, the 

source apportionment air quality modeling informing this LML assessment is not designed to 

predict PM2.5 levels from marginal changes in emissions from each sector.

For this analysis, policy-specific air quality data is not available due to time or resource 

limitations. For this rule, we are unable to estimate the percentage of premature mortality 

associated with this specific rule’s emission reductions at each PM2.5 level. However, we believe 

that it is still important to characterize the distribution of exposure to baseline air quality levels. 

As a surrogate measure of mortality impacts, we provide the percentage of the population 

exposed at each PM2.5 level using the air quality baseline used for the source apportionment

modeling. Readers interested in a full discussion of the source apportionment air quality 

modeling may consult ―Air Quality Modeling Technical Support Document: Source Sector 

Assessments‖ (EPA, 2011c). It is important to note that baseline exposure is only one parameter 

in the health impact function, along with baseline incidence rates population, and change in air 

quality. In other words, the percentage of the population exposed to air pollution below the LML 

is not the same as the percentage of the population experiencing health impacts as a result of a 

specific emission reduction policy. The most important aspect, which we are unable to quantify 

for rules without air quality modeling, is the shift in exposure associated with this specific rule. 

Therefore, caution is warranted when interpreting the LML assessment. For more information on 

the data and conclusions in the LML assessment for rules without policy-specific air quality 

modeling, please consult the LML TSD (U.S. EPA, 2010d). The results of this analysis are 

provided in Section 6.4 of this RIA.

As is the nature of Regulatory Impact Analyses (RIAs), the assumptions and methods 

used to estimate air quality benefits evolve over time to reflect the Agency’s most current 

interpretation of the scientific and economic literature. For a period of time (2004–2008), the 

Office of Air and Radiation (OAR) valued mortality risk reductions using a value of statistical 
6-6

life (VSL) estimate derived from a limited analysis of some of the available studies. OAR arrived 

at a VSL using a range of $1 million to $10 million (2000$) consistent with two meta-analyses of 

the wage-risk literature. The $1 million value represented the lower end of the interquartile range 

from the Mrozek and Taylor (2002) meta-analysis of 33 studies. The $10 million value 

represented the upper end of the interquartile range from the Viscusi and Aldy (2003) metaanalysis of 43 studies. The mean estimate of $5.5 million (2000$)3 was also consistent with the 

mean VSL of $5.4 million estimated in the Kochi et al. (2006) meta-analysis. However, the 

Agency neither changed its official guidance on the use of VSL in rule-makings nor subjected 

the interim estimate to a scientific peer-review process through the Science Advisory Board 

(SAB) or other peer-review group. 

During this time, the Agency continued work to update its guidance on valuing mortality 

risk reductions; including commissioning a report from meta-analytic experts to evaluate 

methodological questions raised by EPA and the SAB on combining estimates from the various 

data sources. In addition, the Agency consulted several times with the Science Advisory Board 

Environmental Economics Advisory Committee (SAB-EEAC) on the issue. With input from the 

meta-analytic experts, the SAB-EEAC advised the Agency to update its guidance using specific, 

appropriate meta-analytic techniques to combine estimates from unique data sources and 

different studies, including those using different methodologies (i.e., wage-risk and stated 

preference) (U.S. EPA-SAB, 2007). 

Until updated guidance is available, the Agency determined that a single, peer-reviewed 

estimate applied consistently best reflects the SAB-EEAC advice it has received. Therefore, the 

Agency has decided to apply the VSL that was vetted and endorsed by the SAB in the Guidelines 

for Preparing Economic Analyses (U.S. EPA, 2000)

4 while the Agency continues its efforts to 

update its guidance on this issue. This approach calculates a mean value across VSL estimates 

derived from 26 labor market and contingent valuation studies published between 1974 and 

 

3 After adjusting the VSL to account for a different currency year (2010$) and to account for income growth to 

2015, the $5.5 million VSL is $8.0 million. In this analysis, we use 2016 estimates as a surrogate for 2015 

estimates, which results in a slight overestimate of the benefits.

4

In the (draft) update of the Economic Guidelines (U.S. EPA, 2010f), EPA retained the VSL endorsed by the SAB 

with the understanding that further updates to the mortality risk valuation guidance would be forthcoming in the 

near future. Therefore, this report does not represent final agency policy.
6-7

1991. The mean VSL across these studies is $6.3 million (2000$).5 The Agency is committed to 

using scientifically sound, appropriately reviewed evidence in valuing mortality risk reductions 

and has made significant progress in responding to the SAB-EEAC’s specific recommendations.

In implementing these rules, emission controls may lead to reductions in ambient PM2.5 

below the National Ambient Air Quality Standards (NAAQS) for PM in some areas and assist 

other areas with attaining the PM NAAQS. Because the PM NAAQS RIAs also calculate PM 

benefits, there are important differences worth noting in the design and analytical objectives of 

each RIA. The NAAQS RIAs illustrate the potential costs and benefits of attaining a new air 

quality standard nationwide based on an array of emission control strategies for different sources. 

In short, NAAQS RIAs hypothesize, but do not predict, the control strategies that States may 

choose to enact when implementing a NAAQS. The setting of a NAAQS does not directly result 

in costs or benefits, and as such, the NAAQS RIAs are merely illustrative and are not intended to 

be added to the costs and benefits of other regulations that result in specific costs of control and 

emission reductions. However, some costs and benefits estimated in this RIA account for the 

same air quality improvements as estimated in the illustrative PM2.5 NAAQS RIA. 

By contrast, the emission reductions for this RTR rule are from a specific class of wellcharacterized sources (ferroalloy facilities). In general, EPA is more confident in the magnitude 

and location of the emission reductions for these rules. It is important to note that emission 

reductions anticipated from these rules do not result in emission increases elsewhere. Emission 

reductions achieved under these and other promulgated rules will ultimately be reflected in the 

baseline of future NAAQS analyses, which would reduce the incremental costs and benefits 

associated with attaining the NAAQS. EPA remains forward looking towards the next iteration 

of the 5-year review cycle for the NAAQS, and as a result does not issue updated RIAs for 

existing NAAQS that retroactively update the baseline for NAAQS implementation. For more 

information on the relationship between the NAAQS and rules such as analyzed here, please see 

Section 1.2.4 of the SO2 NAAQS RIA (U.S. EPA, 2010b).

 

5

In this analysis, we adjust the VSL to account for a different currency year (2010$) and to account for income 

growth to 2015. After applying these adjustments to the $6.3 million value, the VSL is $9.2 million. In this 

analysis, we use 2016 estimates as a surrogate for 2015 estimates, which results in a slight overestimate of the 

benefits.
6-8

Figure 6-1. Breakdown of Monetized PM2.5 Health Benefits Estimates using Mortality 

Function from Pope et al. (2002)a

a This pie chart breakdown is illustrative, using the results based on Pope et al. (2002) as an example. Using the 

Laden et al. (2006) function for premature mortality, the percentage of total monetized benefits due to adult 

mortality would be 97%. This chart shows the breakdown using a 3% discount rate, and the results would be 

similar if a 7% discount rate was used.

Table 6-2 provides a general summary of the primary approach results by pollutant, 

including the emission reductions and monetized benefits-per-ton at discount rates of 3% and 

7%.6 Table 6-3 provides a summary of the reductions in health incidences as a result of the 

pollution reductions. In Table 6-4, we provide the benefits using our anchor points of Pope et al.

and Laden et al. as well as the results from the expert elicitation on PM mortality. Figure 6-2

provides a visual representation of the range of benefits estimates of PM2.5 reductions.

 

6To comply with Circular A-4, EPA provides monetized benefits using discount rates of 3% and 7% (OMB, 2003). 

These benefits are estimated for a specific analysis year (i.e., 2015 using 2016 values as a surrogate), and most of 

the PM benefits occur within that year with two exceptions: acute myocardial infarctions (AMIs) and premature 

mortality. For AMIs, we assume 5 years of follow-up medical costs and lost wages. For premature mortality, we 

assume that there is a ―cessation‖ lag between PM exposures and the total realization of changes in health 

effects. Although the structure of the lag is uncertain, EPA follows the advice of the SAB-HES to assume a 

segmented lag structure characterized by 30% of mortality reductions in the first year, 50% over years 2 to 5, and 

20% over the years 6 to 20 after the reduction in PM2.5 (U.S. EPA-SAB, 2004). Changes in the lag assumptions 

do not change the total number of estimated deaths but rather the timing of those deaths. Therefore, discounting 

only affects the AMI costs after the analysis year and the valuation of premature mortalities that occur after the 

analysis year. As such, the monetized benefits using a 7% discount rate are only approximately 10% less than the 

monetized benefits using a 3% discount rate. 

Adult Mortality - Pope et 

al. 93%

Chronic Bronchitis 4%

AMI 2%

Acute Respiratory Symptoms 

0.5%

Infant Mortality 0.4%

Work Loss Days 0.2%

Hospital Admissions, Cardio 

0.2%

Hospital Admissions, Resp 

0.04%

Asthma Exacerbation 0.01%

Acute Bronchitis 0.01%

Upper Resp Symp 0.00%

Lower Resp Symp 0.00%

ER Visits, Resp 0.00%

Other 1%

Breakdown of Monetized PM2.5 Health Benefits using Pope et al. 

Mortality Function
6-9

Table 6-2. Summary of Monetized Benefits Estimates for the Ferroalloy Industry in 2015

(2010$)

a

Pollutant

Emissions 

Reduction

s (tons)

Benefit per 

ton (Pope, 

3%)

Benefit per 

ton 

(Laden, 

3%)

Benefit per 

ton (Pope, 

7%)

Benefit per 

ton 

(Laden, 

7%)

Total Monetized 

Benefits (millions 

2010$ at 3%)

Total Monetized 

Benefits (millions 

2010$ at 7%)

Direct PM2.5 257 $280,000 $690,000 $250,000 $620,000 $71 to $170 $63 to $160

Total $71 to $170 $63

t

o

$160

a All estimates are for the year of analysis (2015), and are rounded to two significant figures so numbers may not 

sum across columns. In this analysis, we use 2016 estimates as a surrogate for 2015 estimates, which results in a 

slight overestimate of the benefits. These models assume that all fine particles, regardless of their chemical 

composition, are equally potent in causing premature mortality the scientific evidence is not yet sufficient to

allow differentiation of effect estimates by particle type. The benefit-per-ton estimates are updated and reflect new 

air quality modeling specific to the ferroalloys sector. The monetized benefits incorporate the conversion from 

precursor emissions to ambient fine particles. Confidence intervals are unavailable for this analysis because of the 

benefit-per-ton methodology.
6-10

Table 6-3. Summary of Reductions in Health Incidences from PM2.5 Benefits for the 

Ferroalloy Sector in 2015

a

Reductions

Avoided Premature Mortality

Pope et al. 8

Laden et al. 20

Avoided Morbidity

Chronic Bronchitis 5

Acute Myocardial Infarction 9

Hospital Admissions, Respiratory 2

Hospital Admissions, Cardiovascular 3

Emergency Room Visits, Respiratory 5

Acute Bronchitis 11

Work Loss Days 950

Asthma Exacerbation 230

Lower Respiratory Symptoms 140

Upper Respiratory Symptoms 100

a All estimates are for the year of analysis (2015) and are rounded to whole numbers with two significant figures. In 

this analysis, we use 2016 estimates as a surrogate for 2015 estimates, which results in a slight overestimate of the 

benefits. These models assume that all fine particles, regardless of their chemical composition, are equally potent 

in causing premature mortality because the scientific evidence is not yet sufficient to allow differentiation of 

effect estimates by particle type.
6-11

Table 6-4. All PM2.5 Benefits Estimates for the Ferroalloy Sector at Discount Rates of 3% 

and 7% in 2015 (in millions of 2010$)

a

PM2.5 Benefits

3% 7%

Benefit-per-ton Coefficients Derived from Epidemiology 

Literature

Pope et al. $71 $63

Laden et al. $170 $160

Benefit-per-ton Coefficients Derived from Expert Elicitation

Expert A $190 $170

Expert B $62 $56

Expert C $140 $130

Expert D $100 $89

Expert E $230 $210

Expert F $54 $48

Expert G $84 $75

Expert H $110 $95

Expert I $140 $130

Expert J $110 $100

Expert K $13 $11

Expert L $39 $35

a All estimates are rounded to two significant figures. Estimates do not include confidence intervals because they 

were derived through the benefit-per-ton technique described above. The benefits estimates from the expert 

elicitation are provided as a reasonable characterization of the uncertainty in the mortality estimates associated 

with the concentration-response function. Confidence intervals are unavailable for this analysis because of the 

benefit-per-ton methodology. 
6-12

Figure 6-2. Total Monetized PM2.5 Benefits Estimates for the Ferroalloy Sector in 2015

a This graph shows the estimated benefits at discount rates of 3% and 7% using effect coefficients derived from the 

Pope et al. (2002) study and the Laden et al. (2006) study, as well as 12 effect coefficients derived from EPA’s 

expert elicitation on PM mortality. The results shown are not the direct results from the studies or expert 

elicitation; rather, the estimates are based in part on the concentration-response function provided in those studies.

6.3 Unquantified Benefits

The monetized benefits estimated in this RIA only reflect the portion of benefits 

attributable to the health effect reductions associated with ambient fine particles. Methodological 

and time limitations prevented EPA from quantifying or monetizing the benefits from several 

important benefit categories, including benefits from reducing toxic emissions, ecosystem 

effects, and visibility impairment. The health benefits from reducing hazardous air pollutants 

(HAPs) including metals, polycyclic aromatic hydrocarbons (PAH), and mercury have not been 

monetized in this analysis. Because we were unable to monetize the direct benefits associated 

with reducing HAPs among others, the monetized benefits estimate is an underestimate of the 

total benefits. The extent of this underestimate, whether small or large, is unknown. 

6.3.1 HAP Benefits

Even though emissions of air toxics from all sources in the U.S. declined by approximately 

42% since 1990, the 2005 National-Scale Air Toxics Assessment (NATA) predicts that most 

$0

$50,000,000

$100,000,000

$150,000,000

$200,000,000

$250,000,000

Benefits Estimated from 2 Epidemiology Functions 

and 12 Expert Functions

3%

7%
6-13

Americans are exposed to ambient concentrations of air toxics at levels that have the potential to 

cause adverse health effects (U.S. EPA, 2011b).7The levels of air toxics to which people are 

exposed vary depending on where people live and work and the kinds of activities in which they 

engage. In order to identify and prioritize air toxics, emission source types and locations that are 

of greatest potential concern, U.S. EPA conducts the NATA.8 The most recent NATA was 

conducted for calendar year 2005 and was released in March 2011. NATA includes four steps:

1) Compiling a national emissions inventory of air toxics emissions from outdoor sources

2) Estimating ambient and exposure concentrations of air toxics across the United States

3) Estimating population exposures across the United States

4) Characterizing potential public health risk due to inhalation of air toxics including both 

cancer and noncancer effects

Based on the 2005 NATA, EPA estimates that about 5% of census tracts nationwide have 

increased cancer risks greater than 100 in a million. The average national cancer risk is about 50 

in a million. Nationwide, the key pollutants that contribute most to the overall cancer risks are 

formaldehyde and benzene.9 Secondary formation (e.g., formaldehyde forming from other 

emitted pollutants) was the largest contributor to cancer risks, while stationary, mobile and 

background sources contribute almost equal portions of the remaining cancer risk.

Noncancer health effects can result from chronic,10 subchronic,11 or acute12 inhalation 

exposures to air toxics, and include neurological, cardiovascular, liver, kidney, and respiratory 

 

7 The 2005 NATA is available on the Internet at http://www.epa.gov/ttn/atw/nata2005/.

8 The NATA modeling framework has a number of limitations that prevent its use as the sole basis for setting 

regulatory standards. These limitations and uncertainties are discussed on the 2005 NATA website. Even so, 

this modeling framework is very useful in identifying air toxic pollutants and sources of greatest concern, setting 

regulatory priorities, and informing the decision making process. U.S. EPA. (2011d) 2005 National-Scale Air 

Toxics Assessment. http://www.epa.gov/ttn/atw/nata2005/

9 Details about the overall confidence of certainty ranking of the individual pieces of NATA assessments including 

both quantitative (e.g., model-to-monitor ratios) and qualitative (e.g., quality of data, review of emission 

inventories) judgments can be found at http://www.epa.gov/ttn/atw/nata/roy/page16.html.

10 Chronic exposure is defined in the glossary of the Integrated Risk Information (IRIS) database 

(http://www.epa.gov/iris) as repeated exposure by the oral, dermal, or inhalation route for more than 

approximately 10% of the life span in humans (more than approximately 90 days to 2 years in typically used 

laboratory animal species).
6-14

effects as well as effects on the immune and reproductive systems. According to the 2005 

NATA, about three-fourths of the U.S. population was exposed to an average chronic 

concentration of air toxics that has the potential for adverse noncancer respiratory health effects.

Results from the 2005 NATA indicate that acrolein is the primary driver for noncancer 

respiratory risk. 

Figure 6-3 and Figure 6-4 depict the estimated census tract-level carcinogenic risk and 

noncancer respiratory hazard from the assessment. It is important to note that large reductions in 

HAP emissions may not necessarily translate into significant reductions in health risk because 

toxicity varies by pollutant, and exposures may or may not exceed levels of concern. For 

example, acetaldehyde mass emissions are more than double acrolein emissions on a national 

basis, according to EPA’s 2005 National Emissions Inventory (NEI). However, the Integrated 

Risk Information System (IRIS) reference concentration (RfC) for acrolein is considerably lower 

than that for acetaldehyde, suggesting that acrolein could be potentially more toxic than 

acetaldehyde. Thus, it is important to account for the toxicity and exposure, as well as the mass 

of the targeted emissions. 

 

11 Defined in the IRIS database as repeated exposure by the oral, dermal, or inhalation route for more than 30 days, 

up to approximately 10% of the life span in humans (more than 30 days up to approximately 90 days in typically 

used laboratory animal species).

12 Defined in the IRIS database as exposure by the oral, dermal, or inhalation route for 24 hours or less.
6-15

Figure 6-3 Estimated Chronic Census Tract Carcinogenic Risk from HAP exposure 

from outdoor sources (2005 NATA)
6-16

Figure 6-4 Estimated Chronic Census Tract Noncancer (Respiratory) Risk from HAP 

exposure from outdoor sources (2005 NATA)

Due to methodology and time limitations under the court-ordered schedule, we were 

unable to estimate the benefits associated with the hazardous air pollutants that would be reduced 

as a result of these rules. In a few previous analyses of the benefits of reductions in HAPs, EPA 

has quantified the benefits of potential reductions in the incidences of cancer and non-cancer risk 

(e.g., U.S. EPA, 1995). In those analyses, EPA relied on unit risk factors (URF) developed 

through risk assessment procedures.13 These URFs are designed to be conservative, and as such, 

are more likely to represent the high end of the distribution of risk rather than a best or most 

likely estimate of risk. As the purpose of a benefit analysis is to describe the benefits most likely 

to occur from a reduction in pollution, use of high-end, conservative risk estimates would 

 

13The unit risk factor is a quantitative estimate of the carcinogenic potency of a pollutant, often expressed as the 

probability of contracting cancer from a 70-year lifetime continuous exposure to a concentration of one μg/m3of 

a pollutant.
6-17

overestimate the benefits of the regulation. While we used high-end risk estimates in past 

analyses, advice from the EPA’s Science Advisory Board (SAB) recommended that we avoid 

using high-end estimates in benefit analyses (U.S. EPA-SAB, 2002). Since this time, EPA has 

continued to develop better methods for analyzing the benefits of reductions in HAPs.

As part of the second prospective analysis of the benefits and costs of the Clean Air Act 

(U.S. EPA, 2011a), EPA conducted a case study analysis of the health effects associated with 

reducing exposure to benzene in Houston from implementation of the Clean Air Act (IEc, 2009). 

While reviewing the draft report, EPA’s Advisory Council on Clean Air Compliance Analysis 

concluded that ―the challenges for assessing progress in health improvement as a result of 

reductions in emissions of hazardous air pollutants (HAPs) are daunting...due to a lack of 

exposure-response functions, uncertainties in emissions inventories and background levels, the 

difficulty of extrapolating risk estimates to low doses and the challenges of tracking health 

progress for diseases, such as cancer, that have long latency periods‖ (U.S. EPA-SAB, 2008).

In 2009, EPA convened a workshop to address the inherent complexities, limitations, and 

uncertainties in current methods to quantify the benefits of reducing HAPs. Recommendations 

from this workshop included identifying research priorities, focusing on susceptible and 

vulnerable populations, and improving dose-response relationships (Gwinn et al., 2011). 

In summary, monetization of the benefits of reductions in cancer incidences requires 

several important inputs, including central estimates of cancer risks, estimates of exposure to 

carcinogenic HAPs, and estimates of the value of an avoided case of cancer (fatal and non-fatal). 

Due to methodology and time limitations under the court-ordered schedule, we did not attempt to 

monetize the health benefits of reductions in HAPs in this analysis. Instead, we provide a 

qualitative analysis of the health effects associated with the HAPs anticipated to be reduced by 

these rules and we summarize the results of the residual risk assessment for the NESHAP. EPA 

remains committed to improving methods for estimating HAP benefits by continuing to explore 

additional concepts of benefits, including changes in the distribution of risk. 

Available emissions data show that several different HAPs are emitted from this sector. 

In the subsequent sections, we describe the health effects associated with the main HAPs of 
6-18

concern. This rule is anticipated to reduce 83.6 tons of total HAPs per year as shown in Chapter 

4 of this RIA, with 81 tons being metal HAP, 0.2 tons being mercury, and 2.5 tons being PAHs.

6.3.3.1 Arsenic (As)

Arsenic, a naturally occurring element, is found throughout the environment and is 

considered toxic through the oral, inhalation and dermal routes. Acute (short-term) high-level 

inhalation exposure to As dust or fumes has resulted in gastrointestinal effects (nausea, diarrhea, 

abdominal pain, and gastrointestinal hemorrhage); central and peripheral nervous system disorders 

have occurred in workers acutely exposed to inorganic As. Chronic (long-term) inhalation 

exposure to inorganic As in humans is associated with irritation of the skin and mucous 

membranes. Chronic inhalation can also lead to conjunctivitis, irritation of the throat and 

respiratory tract and perforation of the nasal septum.14 Chronic oral exposure has resulted in 

gastrointestinal effects, anemia, peripheral neuropathy, skin lesions, hyperpigmentation, and liver 

or kidney damage in humans. Inorganic As exposure in humans, by the inhalation route, has been 

shown to be strongly associated with lung cancer, while ingestion of inorganic As in humans has 

been linked to a form of skin cancer and also to bladder, liver, and lung cancer. EPA has classified 

inorganic As as a Group A, human carcinogen.15

6.3.3.3 Chromium (Cr)16

Chromium may be emitted in two forms, trivalent Cr (Cr+3) or hexavalent Cr (Cr+6). The 

respiratory tract is the major target organ for Cr+6 toxicity, for acute and chronic inhalation 

exposures. Shortness of breath, coughing, and wheezing have been reported from acute exposure 

to Cr+6, while perforations and ulcerations of the septum, bronchitis, decreased pulmonary 

function, pneumonia, and other respiratory effects have been noted from chronic exposures. 

Limited human studies suggest that Cr+6 inhalation exposure may be associated with complications 

during pregnancy and childbirth, but there are no supporting data from animal studies reporting 

 

14 Agency for Toxic Substances and Disease Registry (ATSDR). Medical Management Guidelines for Arsenic. 

Atlanta, GA: U.S. Department of Health and Human Services. Available on the Internet at < 

http://www.atsdr.cdc.gov/mhmi/mmg168.html#bookmark02>

15 U.S. Environmental Protection Agency (U.S. EPA). 1998. Integrated Risk Information System File for Arsenic. 

Research and Development, National Center for Environmental Assessment, Washington, DC. This material is 

available electronically at: http://www.epa.gov/iris/subst/0278.htm.

16 U.S. Environmental Protection Agency. Integrated Risk Information System (IRIS) on Chromium VI. National 

Center for Environmental Assessment, Office of Research and Development, Washington, DC. 1999a. 
6-19

reproductive effects from inhalation exposure to Cr+6. Human and animal studies have clearly 

established the carcinogenic potential of Cr+6 by the inhalation route, resulting in an increased risk 

of lung cancer. EPA has classified Cr+6 as a Group A, human carcinogen. Trivalent Cr is less 

toxic than Cr+6. The respiratory tract is also the major target organ for Cr+3 toxicity, similar to 

Cr+6. EPA has not classified Cr+3 with respect to carcinogenicity.

6.3.3.8 Manganese (Mn)17

Health effects in humans have been associated with both deficiencies and excess intakes of 

Mn. Chronic exposure to high levels of Mn by inhalation in humans results primarily in central 

nervous system effects. Visual reaction time, hand steadiness, and eye-hand coordination were 

affected in chronically-exposed workers. Manganism, characterized by feelings of weakness and 

lethargy, tremors, a masklike face, and psychological disturbances, may result from chronic 

exposure to higher levels. Impotence and loss of libido have been noted in male workers afflicted 

with manganism attributed to inhalation exposures. The EPA has classified Mn in Group D, not 

classifiable as to carcinogenicity in humans.

6.3.3.9 Mercury (Hg)

In this section, we provide a qualitative description of human health and environmental 

effects due to exposure to MeHg. In 2000, the NAS Study was issued which provides a thorough 

review of the effects of MeHg on human health (NRC, 2000)18. Many of the peer-reviewed 

articles cited in this section are publications originally cited in the MeHg Study. In addition, 

EPA has conducted literature searches to obtain other related and more recent publications to 

complement the material summarized by the NRC in 2000.

In its review of the literature, the NAS found neurodevelopmental effects to be the most 

sensitive and best documented endpoints and appropriate for establishing an RfD (NRC, 2000); 

in particular NAS supported the use of results from neurobehavioral or neuropsychological tests. 

 

17 U.S. Environmental Protection Agency. Integrated Risk Information System (IRIS) on Manganese. National 

Center for Environmental Assessment, Office of Research and Development, Washington, DC. 1999b.

18 NRC (2000). Toxicological Effects of Methylmercury. National Research Council. Washington, DC: National 

Academies Press.
6-20

The NAS report noted that studies in animals reported sensory effects as well as effects on brain 

development and memory functions and support the conclusions based on epidemiology studies. 

The NAS noted that their recommended endpoints for an RfD are associated with the ability of 

children to learn and to succeed in school. They concluded the following: ―The population at 

highest risk is the children of women who consumed large amounts of fish and seafood during 

pregnancy. The committee concludes that the risk to that population is likely to be sufficient to 

result in an increase in the number of children who have to struggle to keep up in school.‖

The NAS summarized data on cardiovascular effects available up to 2000. Based on these 

and other studies, the NRC concluded that ―Although the data base is not as extensive for 

cardiovascular effects as it is for other end points (i.e. neurologic effects) the cardiovascular 

system appears to be a target for MeHg toxicity in humans and animals.‖ The NRC also stated 

that ―additional studies are needed to better characterize the effect of methylmercury exposure on 

blood pressure and cardiovascular function at various stages of life.‖

Additional cardiovascular studies have been published since 2000. EPA did not to 

develop a quantitative dose-response assessment for cardiovascular effects associated with 

MeHg exposures, as there is no consensus among scientists on the dose-response functions for 

these effects. In addition, there is inconsistency among available studies as to the association 

between MeHg exposure and various cardiovascular system effects. The pharmacokinetics of 

some of the exposure measures (such as toenail Hg levels) are not well understood. The studies 

have not yet received the review and scrutiny of the more well-established neurotoxicity data 

base. 

The Mercury Study noted that MeHg is not a potent mutagen but is capable of causing 

chromosomal damage in a number of experimental systems. The NAS concluded that evidence 

that human exposure to MeHg caused genetic damage is inconclusive; they note that some earlier 

studies showing chromosomal damage in lymphocytes may not have controlled sufficiently for 

potential confounders. One study of adults living in the Tapajós River region in Brazil (Amorim 

et al., 2000) reported a direct relationship between MeHg concentration in hair and DNA damage 
6-21

in lymphocytes; as well as effects on chromosomes19. Long-term MeHg exposures in this 

population were believed to occur through consumption of fish, suggesting that genotoxic effects 

(largely chromosomal aberrations) may result from dietary, chronic MeHg exposures similar to 

and above those seen in the Faroes and Seychelles populations.

Although exposure to some forms of Hg can result in a decrease in immune activity or an 

autoimmune response (ATSDR, 1999), evidence for immunotoxic effects of MeHg is limited 

(NRC, 2000)20.

Based on limited human and animal data, MeHg is classified as a ―possible‖ human 

carcinogen by the International Agency for Research on Cancer (IARC, 1994) and in IRIS 

(USEPA, 2002) 21,22. The existing evidence supporting the possibility of carcinogenic effects in 

humans from low-dose chronic exposures is tenuous. Multiple human epidemiological studies 

have found no significant association between Hg exposure and overall cancer incidence, 

although a few studies have shown an association between Hg exposure and specific types of 

cancer incidence (e.g., acute leukemia and liver cancer) (NRC, 2000).

There is also some evidence of reproductive and renal toxicity in humans from MeHg 

exposure. However, overall, human data regarding reproductive, renal, and hematological 

toxicity from MeHg are very limited and are based on either studies of the two high-dose 

poisoning episodes in Iraq and Japan or animal data, rather than epidemiological studies of 

chronic exposures at the levels of interest in this analysis.

 

19 Amorim, M.I.M., D. Mergler, M.O. Bahia, H. Dubeau, D. Miranda, J. Lebel, R.R. Burbano, and M. Lucotte. 

2000. Cytogenetic damage related to low levels of methyl mercury contamination in the Brazilian Amazon. An. 

Acad. Bras. Ciênc. 72(4): 497-507.

20 Agency for Toxic Substances and Disease Registry (ATSDR). 1999. Toxicological Profile for Mercury. U.S. 

Department of Health and Human Services, Public Health Service, Atlanta, GA.

21 U.S. Environmental Protection Agency (EPA). 2002. Integrated Risk Information System (IRIS) on 

Methylmercury. National Center for Environmental Assessment. Office of Research and Development. Available 

online at http://www.epa.gov/iris/subst/0073.htm

22 International Agency for Research on Cancer (IARC). 1994. IARC Monographs on the Evaluation of 

Carcinogenic Risks to Humans and their Supplements: Beryllium, Cadmium, Mercury, and Exposures in the 

Glass Manufacturing Industry. Vol. 58. Jalili, H.A., and A.H. Abbasi. 1961. Poisoning by ethyl mercury toluene 

sulphonanilide. Br. J. Indust. Med. 18(Oct.):303-308 (as cited in NRC 2000).
6-22

6.3.3.10 Nickel (Ni)23

Respiratory effects have been reported in humans from inhalation exposure to Ni. No 

information is available regarding the reproductive or developmental effects of Ni in humans, but 

animal studies have reported such effects. Human and animal studies have reported an increased 

risk of lung and nasal cancers from exposure to Ni refinery dusts and nickel subsulfide. The EPA 

has classified nickel subsulfide as a human carcinogen and nickel carbonyl as a probable human 

carcinogen24,25. The IARC has classified Ni compounds as carcinogenic to humans.

6.3.3.11 Other Metals

Metals can cause a range of effects including, mucous membrane irritation (e.g. bronchitis, 

decreased lung function); gastrointestinal effects; nervous system disorders (from loss of function 

to tremors and numbness); skin irritation; and reproductive and developmental disorders. 

Additionally, several of the metals accumulate in the environment and in the human body. 

Cadmium, for example, is a cumulative pollutant which causes kidney effects after the cessation of 

exposure. Similarly, the onset of effects from beryllium exposure may be delayed by months to 

years. Many of the metal listed above are also known (arsenic, chromium (VI), nickel) or probable 

(cadmium, nickel carbonyl, lead, and beryllium) human carcinogens.

6.3.3.12 Polycyclic organic matter (POM)

The term polycyclic organic matter (POM) defines a broad class of compounds that 

includes the polycyclic aromatic hydrocarbon compounds (PAHs), of which benzo[a]pyrene is a 

member. POM compounds are formed primarily from combustion and are present in the 

atmosphere in particulate form. Sources of air emissions are diverse and include cigarette smoke, 

vehicle exhaust, home heating, laying tar, and grilling meat. Cancer is the major concern from 

exposure to POM. Epidemiologic studies have reported an increase in lung cancer in humans 

 

23 Nickel (IARC Summary & Evaluation , Volume 49, 1990), 

http://www.inchem.org/documents/iarc/vol49/nickel.html

24 U.S. Environmental Protection Agency. Integrated Risk Information System (IRIS) on Nickel Subsulfide. 

National Center for Environmental Assessment, Office of Research and Development, Washington, DC. 1999c.

25 U.S. Environmental Protection Agency. Integrated Risk Information System (IRIS) on Nickel Carbonyl. National 

Center for Environmental Assessment, Office of Research and Development, Washington, DC. 1999d.
6-23

exposed to coke oven emissions, roofing tar emissions, and cigarette smoke; all of these mixtures 

contain POM compounds. Animal studies have reported respiratory tract tumors from inhalation 

exposure to benzo[a]pyrene and forestomach tumors, leukemia, and lung tumors from oral 

exposure to benzo[a]pyrene. EPA has classified seven PAHs (benzo[a]pyrene, benz[a]anthracene, 

chrysene, benzo[b]fluoranthene, benzo[k]fluoranthene, dibenz[a,h]anthracene, and indeno[1,2,3-

cd]pyrene) as Group B2, probable human carcinogens

6.3.3.13 Other Air Toxics

In addition to the compounds described above, other compounds from the ferroalloy 

sector would be affected by this rule. Information regarding the health effects of these 

compounds can be found in EPA’s IRIS database.26

6.4 Characterization of Uncertainty in the Monetized PM2.5 Benefits

In any complex analysis, there are likely to be many sources of uncertainty. Many inputs 

are used to derive the final estimate of economic benefits, including emission inventories, air 

quality models (with their associated parameters and inputs), epidemiological estimates of 

concentration-response (C-R) functions, estimates of values, population estimates, income 

estimates, and estimates of the future state of the world (i.e., regulations, technology, and human 

behavior). For some parameters or inputs it may be possible to provide a statistical representation 

of the underlying uncertainty distribution. For other parameters or inputs, the necessary 

information is not available. 

The annual benefit estimates presented in this analysis are also inherently variable due to 

the processes that govern pollutant emissions and ambient air quality in a given year. Factors 

such as hours of equipment use and weather are constantly variable, regardless of our ability to 

measure them accurately. As discussed in the PM2.5 NAAQS RIA (Table 4-5) (U.S. EPA, 

2006b), there are a variety of uncertainties associated with these PM benefits. Therefore, the 

estimates of annual benefits should be viewed as representative of the magnitude of benefits 

expected, rather than the actual benefits that would occur every year. 

It is important to note that the monetized benefit-per-ton estimates used here reflect 

specific geographic patterns of emissions reductions and specific air quality and benefits 

modeling assumptions. However, these estimates better reflect local variability in population 

density, meteorology, exposure, baseline health incidence rates, or other local factors than the 

 

26 U.S. EPA Integrated Risk Information System (IRIS) database is available at: www.epa.gov/iris
6-24

benefit-per-ton estimates previously used, due to the sector-specific air quality modeling utilized. 

Nonetheless, use of these $/ton values to estimate benefits associated with different emission 

control programs may lead to higher or lower benefit estimates than if benefits were calculated 

based on direct air quality modeling. Great care should be taken in applying these estimates to 

emission reductions occurring in any specific location, as these represent average benefits-perton for the sector over the entire United States. The benefits-per-ton for emission reductions in 

specific locations may be very different than the estimates presented here.

PM2.5 mortality benefits are the largest benefit category that we monetized in this 

analysis. To better characterize the uncertainty associated with mortality impacts that are 

estimated to occur in areas with low baseline levels of PM2.5, we included the LML assessment. 

This approach summarizes the distribution of avoided PM mortality impacts according to the 

baseline PM2.5 levels experienced by the population receiving the PM2.5 mortality benefit 

(Figures 6-5 and 6-6). We identify on this figure the lowest air quality levels measured in each of 

the two primary epidemiological studies EPA used to quantify PM-related mortality. This 

information allows readers to determine the portion of PM-related mortality benefits occurring 

above or below the LML of each study; in general, our confidence in the estimated PM mortality 

decreases as we consider air quality levels further below the LML in the two epidemiological 

studies. While the LML analysis provides some insight into the level of uncertainty in the 

estimated PM mortality benefits, EPA does not view the LML as a threshold and continues to 

quantify PM-related mortality impacts using a full range of modeled air quality concentrations. 

While this figure describes the relationship between baseline PM2.5 exposure and mortality for 

the air quality modeled policy case, we expect the distribution of mortality impacts to be fairly 

similar between the two cases.

Some proportion of the avoided PM-related impacts we estimate in this analysis occur 

among populations exposed at or above the LML of the Laden et al. (2006) study, while a 

majority of the impacts occur at or above the LML of the Pope et al. (2002) study (Figure 6-5), 

increasing our confidence in the PM mortality analysis. Based on the air quality baseline used for 

the source apportionment modeling, 31% and 89% of the estimated avoided mortality impacts 

occur at or above an annual mean PM2.5 level of 10 μg/m3(the LML of the Laden et al. 2006 

study) and 7.5 μg/m3 (the LML of the Pope et al. 2002 study), respectively. As we model 

mortality impacts among populations exposed to levels of PM2.5 that are successively lower than 

the LML of each study our confidence in the results diminishes.

While the LML of each study is important to consider when characterizing and 

interpreting the overall level PM-related benefits, as discussed earlier in this chapter, EPA 
6-25

believes that both cohort-based mortality estimates are suitable for use in air pollution health 

impact analyses. When estimating PM mortality impacts using risk coefficients drawn from the 

Laden et al. (2006) analysis of the Harvard Six Cities and the Pope et al. (2002) analysis of the 

American Cancer Society cohorts there are innumerable other attributes that may affect the size 

of the reported risk estimates—including differences in population demographics, the size of the 

cohort, activity patterns and particle composition among others. The LML assessment presented 

here provides a limited representation of one key difference between the two studies.

Figure 6-5. Percentage of Total PM-Related Mortalities Avoided by Baseline Air Quality 

Level
6-26

Figure 6-6. Cumulative Percentage of Total PM-Related Mortalities Avoided by Baseline 

Air Quality Level

Above we present the estimates of the total monetized benefits, based on our 

interpretation of the best available scientific literature and methods and supported by the SABHES and the NAS (NRC, 2002). The benefits estimates are subject to a number of assumptions 

and uncertainties. For example, for key assumptions underlying the estimates for premature 

mortality, which typically account for at least 90% of the total monetized benefits, we were able 

to quantify include the following: 

1. PM2.5 benefits were derived through benefit per-ton estimates, which in general do not 

reflect local variability in population density, meteorology, exposure, baseline health 

incidence rates, or other local factors that might lead to an over-estimate or underestimate of the actual benefits of controlling directly emitted fine particulates. 

However, these estimates better reflect variability in these local factors than the 

benefit-per-ton estimates previously used, due to the sector-specific air quality 

modeling utilized.

2. We assume that all fine particles, regardless of their chemical composition, are 

equally potent in causing premature mortality. This is an important assumption, 

because PM2.5 produced via transported precursors emitted from EGUs may differ 

significantly from direct PM2.5 released from diesel engines and other industrial 
6-27

sources, but the scientific evidence is not yet sufficient to allow differentiation of 

effect estimates by particle type. 

3. We assume that the health impact function for fine particles is linear down to the 

lowest air quality levels modeled in this analysis. Thus, the estimates include health 

benefits from reducing fine particles in areas with varied concentrations of PM2.5,

including both regions that are in attainment with fine particle standard and those that 

do not meet the standard down to the lowest modeled concentrations. 

4. To characterize the uncertainty in the relationship between PM2.5 and premature 

mortality (which typically accounts for 85% to 95% of total monetized benefits), we 

include a set of twelve estimates based on results of the expert elicitation study in 

addition to our core estimates. Even these multiple characterizations omit the 

uncertainty in air quality estimates, baseline incidence rates, populations exposed and 

transferability of the effect estimate to diverse locations. As a result, the reported 

confidence intervals and range of estimates give an incomplete picture about the 

overall uncertainty in the PM2.5 estimates. This information should be interpreted 

within the context of the larger uncertainty surrounding the entire analysis. For more 

information on the uncertainties associated with PM2.5 benefits, please consult the 

PM2.5 NAAQS RIA (Table 5-5).

This RIA does not include the type of detailed uncertainty assessment found in the PM 

NAAQS RIA (U.S. EPA, 2006b) because we lack the necessary air quality input and monitoring 

data to run the benefits model. In addition, we have not conducted any air quality modeling for 

this rule. Moreover, it was not possible to develop benefit-per-ton metrics and associated 

estimates of uncertainty using the benefits estimates from the PM RIA because of the significant 

differences between the sources affected in that rule and those regulated here. However, the 

results of the Monte Carlo analyses of the health and welfare benefits presented in Chapter 5 of 

the PM RIA can provide some evidence of the uncertainty surrounding the benefits results 

presented in this analysis.
7-28

SECTION 7

COMPARISON OF MONETIZED BENEFITS AND COSTS

7.1 Summary

Because we were unable to monetize the co-benefits associated with reducing HAPs, all 

monetized benefits reflect improvements in ambient PM2.5 concentrations from reductions in 

PM2.5 emissions. This results in an underestimate of the monetized benefits. Using a 3% 

discount rate, we estimate the total monetized benefits of this proposed rule to be $71 million to 

$170 million in the year of implementation (2015) as shown in Table 7-1. Using a 7% discount 

rate, we estimate the total monetized benefits to be $63 million to $160 million in 2015. The 

annualized social costs are $4.1 million. The net benefits are therefore $67 million to $170

million at a 3% discount rate for the benefits and $59 million to $150 million at a 7% discount 

rate. All estimates are in 2010$. The benefits from reducing other air pollutants have not been 

monetized in this analysis, including reducing tons of, black carbon and several HAPs emissions 

such as formaldehyde, mercury and nickel among others each year. 

Figure 7-1 shows the full range of net benefits estimates (i.e., annual benefits minus 

annualized costs) quantified in terms of PM2.5 benefits for the year of implementation (2015).

Table 7-1. Summary of the Annual Monetized Benefits, Social Costs, and Net Benefits for 

the Proposed Ferroalloys RTR in 2015 ($2010 millions)

a

3% Discount Rate 7% Discount Rate

Proposed Standard 

Total Monetized Benefitsb$71 to $170 $63 to $160

Total Social Costs $4.0 $4.0

Net Benefits $67 to $170 $59 to $150

Nonmonetized Benefits Reduced exposure to HAPs, including arsenic, chromium, nickel, manganese, 

mercury and polycyclic aromatic hydrocarbons

Ecosystem effects

Visibility impairment

a All estimates are for the year of implementation (2015) and are rounded to two significant figures. These results 

include units anticipated to come online and the lowest cost disposal assumption. 

b The total monetized benefits reflect the human health benefits associated with reducing exposure to PM2.5 through 

reductions of directly emitted PM2.5. It is important to note that the monetized benefits include many but not all 

health effects associated with PM2.5 exposure. Benefits are shown as a range from Pope et al. (2002) to Laden et 

al. (2006). These models assume that all fine particles, regardless of their chemical composition, are equally 

potent in causing premature mortality because the scientific evidence is not yet sufficient to allow differentiation 

of effect estimates by particle type. 
7-29

Figure 7-1. Net Annual Benefits Range in 2015 for PM2.5 Reductions for the Proposed 

Standard 

$0

$50,000,000

$100,000,000

$150,000,000

$200,000,000

$250,000,000

Pope et al.

Laden et al.

(2010$)

Cost estimate combined with total monetized benefits estimates derived from 2 

epidemiology functions and 12 expert functions
SECTION 8

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