E

C

/R Incorporated Providing Environmental Technical Support Since 1989

 

MEMORANDUM

DATE: October 14, 2011

SUBJECT: Draft Development of the RTR Emissions Dataset for the Ferroalloys Production 

Source Category

FROM: Bradley Nelson, EC/R, Inc.

TO: Conrad Chin, EPA OAQPS/SPPD/MMG

1.0 PURPOSE

The purpose of this memorandum is to present a summary of the test data and to document the 

methodologies used to estimate pollutant emissions from processes at two ferroalloy facilities. 

The emission estimates developed in this task were used to create a database that will be used to 

model risks as part of the “risk and technology” (RTR) review for the Ferroalloy Production 

source category. 

 

2.0 BACKGROUND

Under the "technology review" provision of CAA section 112, EPA is required to review 

maximum achievable control technology (MACT) standards and to revise them "as necessary 

(taking into account developments in practices, processes and control technologies)" no less 

frequently than every 8 years. Under the "residual risk" provision of the CAA section 112, EPA 

must evaluate the MACT standards within 8 years after promulgation and promulgate standards 

if required to provide an ample margin of safety to protect public health or prevent an adverse 

environmental effect. EPA has combined the two review activities into the RTR reviews for the 

Ferroalloys Production source category. 

The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Ferromanganese 

and Silicomanganese Production applies to new and existing ferroalloy production facilities that 

manufacture ferromanganese and/or silicomanganese and are major sources of HAP emissions or 

are co-located at major sources of HAP emissions. The NESHAP established emissions 

standards for the following HAP emission sources at a ferroalloy production facility:

Submerged arc furnaces

Metal oxygen refining (MOR) process
2

Crushing and screening operations

Fugitive dust sources.

The current rule contains emission standards that limit particulate matter emissions from existing 

and new or reconstructed emission sources. The limits for the submerged arc furnaces depend on 

the product produced and furnace design. The rule also sets limits for the air pollution control 

devices associated with the MOR process and crushing and screening operations. Currently, 

there are two facilities in the U.S. that are affected by this rule; Eramet Marietta, Inc. and Felman 

Production Inc. A summary of the HAP emission sources for each facility is provided in Section 

3.0.

To estimate the facility HAP emissions, an Information Collection Request (ICR) under Section 

114 of the Clean Air Act (CAA) was sent to each of the ferroalloy production facilities to gather 

source testing information from the electric arc furnace (EAF) process (which includes 

emissions that occur during charging, melting, and tapping) and the product crushing process. 

The HAP source test data that were collected from the control device outlet for each furnace 

include: metal HAP (arsenic, chromium, lead, manganese, mercury, and nickel), hydrochloric 

acid, hydrofluoric acid, hexavalent chromium, formaldehyde, polycyclic aromatic hydrocarbons 

(PAH), polychlorinated biphenyls (PCB), and chlorodibenzodioxins and chlorodibenzofurans 

(CDD/CDF). In addition, non-HAP emissions were measured from the EAF control device 

outlet for: carbon monoxide (CO) and particulate matter (PM). Total phosphorus was also 

measured for the ICR using EPA Method 29, however this method does not distinguish between 

white phosphorus (which is a non-HAP) and red phosphorus (which is a HAP). Due to the 

uncertainty of the percentage of red phosphorus in the total phosphorus test results, it was 

concluded that phosphorus would not be incorporated in the emissions used for modeling. The 

source test data collected for the crushing and sizing operations include: particulate matter (PM), 

metal HAP (arsenic, chromium, lead, manganese, mercury, and nickel), and phosphorus. Again, 

total phosphorus was measured using Method 29 and therefore not included in the emissions 

us3ed for modeling. In addition to the source tests, a sample of coal was analyzed for sulfur, 

proximate analysis, and ultimate analysis.

3.0 FERROALLOY FACILITY SUMMARY

The following section describes the HAP emission sources for the Eramet Marietta, Inc. and 

Felman Production Inc. ferroalloy production facilities. 

Eramet Marietta Inc.

The Eramet facility is located in Marietta, Ohio and produces ferromanganese (FeMn) and 

silicomanganese (SiMn) using two electric arc furnaces (EAF) identified as EAF 1 and EAF 12. 

The EAF 1 furnace is a submerged arc furnace rated at 30 megawatts (MW) and is equipped with 
3

a negative pressure fabric filter to control particulate emissions. The fabric filter controls 

emissions from the furnace and was installed in 2011 to replace a wet scrubber system. A 

separate fabric filter system is used to control charging, melting, and tapping emissions from this 

furnace. The EAF 12 furnace is a submerged arc furnace rated at 22 MW and is equipped with 

two wet scrubbers to control primary and secondary emissions from the furnace and tapping. 

The scrubbers operate simultaneously and exhaust through a single stack. The facility has a third 

furnace, EAF 18, which is permitted, but is considered to be inoperable until extensive repair can 

be made to the furnace. Therefore, EAF 18 was not considered an emission source and was not 

included in the emission inventory for Eramet. Other HAP emission sources include: a MOR 

process controlled by a positive-pressure baghouse, and a crushing and sizing system (C2P) that 

is controlled by three negative pressure baghouses. There are also fugitive emissions that are 

emitted from each of these emissions sources, in addition to the fugitive emissions from the 

casting operations for EAF 1, EAF 12, and the MOR process.

The emission sources used for modeling emissions from the Eramet facility were created from 

the plant configuration discussed above. For the EAFs and the MOR process, emission points 

were created for the control device outlet emissions, as well as fugitive emissions from the two 

EAFs and the one MOR process. For the crushing system, emission points were created for each 

of the three baghouse outlets and one emission point for fugitive emissions from the crushing 

operation. Emission points were also created for casting fugitive emissions from each of the two 

EAFs and the one MOR process.

Felman Production Inc.

The Felman facility is located in New Haven, West Virginia and produces SiMn using three 

electric arc furnaces identified as Furnace 2, Furnace 5, and Furnace 7. Furnaces 2, 5, and 7 are 

open EAFs rated at 32, 20, and 20 MW respectively. Each of these furnaces is equipped with a 

positive-pressure baghouse to limit emissions of PM and metal HAP from the furnace. The 

facility has a crushing and sizing system controlled using a negative pressure baghouse. There 

are also fugitive emissions that are emitted from each of these emissions sources, in addition to 

the fugitive emissions from the casting operations for Furnace 2, Furnace 5, and Furnace 7.

The Felman facility emission points used for modeling emissions were created from the plant 

configuration discussed above. Emission points were created for the control device outlet 

emissions for each of the three EAFs, as well as a fugitive emission point for each of the three 

EAFs. For the crushing systems, emission points were created for the crusher baghouse outlet 

and fugitive emissions from the crushing units. Emission points were also created for casting 

fugitive emissions from each of the three EAFs.
4

4.0 POLLUTANT EMISSION DATA

The following section describes the test data that was collected from each of the ferroalloy 

facilities. This section will describe the test methods that were used to measure emissions for 

each pollutant from the processes that were tested. A summary of the type of pollutant data 

collected in the ICR is presented in Table 4-1.

Particulate Matter

Test data for PM were received from each of the ferroalloy facilities for one of the electric arc 

furnaces (EAF) and from one of the product crushing operations. Eramet provided PM results 

from the scrubber outlet for EAF 12 and from Baghouse #1 for the crushing and sizing operation

using EPA Method 5. Felman provided PM test results from the Furnace 2 baghouse and the 

baghouse controlling emissions from the crushing and sizing operation using EPA Method 5D 

and EPA method 5 respectively. 

Metal HAP and Phosphorus

Test data for metal HAP (arsenic, chromium, lead, manganese, mercury, and nickel) and 

phosphorus were collected from the scrubber outlet for EAF 12 and from Baghouse #1 for the 

product crushing operation for Eramet. The metal HAP data for Felman were obtained from the 

Furnace 2 baghouse and the baghouse controlling emissions from the crushing and sizing 

operation. The furnace and product crushing test data were collected using EPA Method 29.

Hexavalent Chromium

Hexavalent chromium data were collected from EAF 12 and Furnace 2 for the Felman and 

Eramet facilities respectively, using EPA Method 316. No hexavalent chromium data were

requested for the product crushing operations.

HCl/HF

Test data for hydrochloric acid (HCl) and hydrofluoric acid (HF) were collected from the 

scrubber outlet of EAF 12 at Eramet and the baghouse outlet of Furnace 2 at Felman using EPA 

Method 26A. The product crushing processes were not tested for HCl or HF.

Formaldehyde

Testing for formaldehyde was performed on scrubber outlet of EAF 12 at Eramet and the 

baghouse outlet of Furnace 2 at Felman using EPA Method 316. Formaldehyde testing was not 

performed on any of the product crushing processes.
5

Table 4-1. Summary of Pollutant Data Collected in the ICR

Facility Process

Particulate Matter Metal HAP & 

Phosphorus Cr+6 HCl/ HF Formaldehyde PAH, PCB, CDD/CDF

Method 5D Method 5 Method 29 Method 316 Method 26A Method 316 Method 23 FF Dust

Felman

EAF      

Crusher  

Eramet

EAF      

Crusher  
6

PAH/PCB/CDD/CDF

Data for, polychlorinated biphenyls (PCB), chlorinated dibenzo-p-dioxins (CDD), and 

chlorinated dibenzo-p-furans (CDF) were collected and analyzed using EPA Method 23 from the 

scrubber outlet of EAF 12 at the Eramet facility. The PAH emissions from the scrubber outlet of 

EAF 12 were measured using Method 0010. The PAH, PCB, and CDD/CDF data for Furnace 2 

at Felman facility were obtained from the fabric filter dust using SW 846 Method 3500C/3600, 

and analyzed using SW-846 Method 8270D for PAH and PCBs and SW 846-8280B for 

CDD/CDF. The analysis results were presented for each individual congener for each of the 

CDD/CDF, PCB, and PCB groups. No PAH, PCB, or CDD/CDF emissions data were collected 

for the product crushing units.

Other Data

In addition to the pollutant data described above, analyses of the coal/coke and furnace exhaust 

concentrations of oxygen (O2), carbon dioxide (CO2), and carbon monoxide (CO) were 

measured. The O2 and CO2 concentrations were measured using EPA Method 3A, and the CO 

concentration was measured using EPA Method 10. For coal/coke, the samples were analyzed 

using ASTM D3177-02 for sulfur, D3172-07 for proximate analysis, and D3176-09 for ultimate 

analysis.

5.0 METHODOLOGY FOR DEVELOPING EMISSION ESTIMATES

The test data provided in the ICR was used to develop a modeling emissions database for 

determining if there are risks associated with the HAP emissions from the ferroalloy facilities. 

The analytical results provided in the ICR were used to calculate emissions for each of the 

pollutants. For analytical results reported below the detection limit, one half of the method 

detection limit was used to estimate the results from that test run. This section describes the 

methodology used to estimate annual emissions from all of the sources at each of the ferroalloy 

facilities. 

EAF Emissions

The EAF annual emissions for all pollutants were estimated using the information provided in 

the facility’s ICR submittal. The annual emissions for the tested EAF units were calculated 

using the pounds per hour test data provided in the facility test report and converting to annual 

emissions assuming 8760 hours of operation per year. For the EAF units that were not tested, 

the annual emissions were estimated using PM test data from previous test data submittals and 

using a pollutant-to-PM ratio to calculate the other pollutants. A more detailed description for 
7

each facility is provided in the paragraphs below. A table of the PM ratios used for estimating 

emissions from EAFs that were not tested is provided in Table 5-1.

The Eramet facility provided ICR test data for EAF 12 which were used to calculate pollutant 

emissions from the scrubber outlet for all of the pollutants. Eramet also provided a supplemental 

test report for the newly installed fabric filter for EAF 1 for the pollutants: PM, manganese, HCl, 

and HF. To estimate the emissions of the pollutants not tested in the supplemental test report, the 

PM emission rate was multiplied by an EAF 12 pollutant-to-PM ratio for the specified pollutant. 

For an example, the arsenic emission rate was estimated using the following equation:

where;

ArsenicEAF 1 = Estimated arsenic emissions from EAF 12 in tons per year,

PMEAF 1 = PM test results in supplemental test report in tons per year,

ArsenicEAF 12 = Arsenic test results from ICR submittal in tons per year, and

PMEAF 12 = PM test results from ICR submittal in tons per year.

This same equation was used for the other pollutants that were not tested in the supplemental test 

report, substituting the pollutant to be estimated for arsenic in the equation. A summary of the 

pollutant emissions for each of the EAFs is presented in Table 5-2.
8

Table 5-1. Summary of PM Ratios Used to Estimate Emissions from EAFs

Facility EAF Unit PM Emissions 

(Tons/yr) PM Ratio Test Date(s)

Eramet EAF 12 24.7 --- 8/17-18/2010

EAF 1 49.1 1.99 5/19/2009

Felman Furnace 2 20.4 --- 7/9-10/2010

Furnace 5 15.5 0.763 11/18/2009

Furnace 7 24.5 1.20 11/17/2009

The Felman facility submitted ICR test data for Furnace 2 which were used to calculate the 

pollutant emissions from this EAF. The PM, metals, phosphorus, HCl, and HF annual emissions 

were calculated using the emissions data from the ICR. The individual species PAH, PCB, and 

CDD/CDF emissions were estimated using the fabric filter dust analysis. This was done by 

estimating the uncontrolled fabric filter dust concentration and multiplying that by the 

uncontrolled PM emissions. The resulting value was then multiplied by the PAH, PCB, and 

CDD/CDF control efficiency to estimate the emission from the fabric filter. The equation below 

shows the calculation. 

where;

PAH, PCB, CDD, CDF Emissions = Estimated PAH, PCB, CDD, or CDF emissions in tons per 

year,

Conc = Concentration of PAH, PCB, CDD, CDF species in the fabric filter dust in ng/Kg,

CEPAH,CDD,CDF = Estimated removal efficiency of PAH, PCB, CDD, or CDF using a fabric filter 

(assumed to be 50%),

PM tons/yr = Calculated PM emissions from Furnace 2 in tons per year, and

CEPM = Estimated removal efficiency of PM using a fabric filter (assumed to be 99%).
9

The other values in the equation are constants to convert the emissions to tons per year. A 

summary of the assumed fabric filter control efficiencies for these pollutants is presented in 

Table 5-3. This equation was used to estimate emissions for each of the congeners for PAH, 

PCB, CDD, and CDF. 

The emissions from Felman Furnaces 5 and 7 were calculated using the pollutant-to-PM ratio 

from Furnace 2 using the same methodology that was used above for Eramet. Compliance test 

data reported in November 2009 were used for the PM emissions for Furnaces 5 and 7. A 

summary of the pollutant emissions for each of the EAFs is presented in Table 5-2.

EAF Fugitive Emissions

The EAF fugitive emissions were estimated by calculating the uncontrolled pollutant emissions 

rate from the furnace and estimating the percentage of the uncontrolled pollutant emissions that 

is captured from the EAF. The difference between the uncontrolled pollutant emission rate and 

the estimated captured pollutant emissions were assumed to be the EAF fugitive emissions. The 

uncontrolled pollutant emissions rate was calculated using the EAF annual emissions for each 

pollutant and the assumed control efficiency for that pollutant. A summary of the assumed fabric 

filter and scrubber control efficiencies for the pollutants is presented in Table 5-3. It was 

assumed that 92 percent of the uncontrolled emissions were generated from the EAF and 8 

percent of the uncontrolled emissions occur during tapping of the EAF. The capture system from 

the EAF was assumed to capture 95 percent of the uncontrolled pollutant emissions generated by 

the furnace and 85 percent of the EAF tapping emissions. 
10

Table 5-2. Summary of Facility Process Annual Emissions for the Ferroalloy Industry

Note:

The red shaded areas indicate annual emissions based on some runs that were measured below the detection limit.

The blue shaded areas indicate annual emissions based on all runs measured below the detection limit.

The grey shaded areas indicate annual emissions were not estimated for these pollutants.

The PAH, CDD/CDF, and PCB emissions are the sum of the mass of all of the individual congeners.

Emission Source

Particulate 

Matter (tpy) Arsenic (tpy)

Manganese 

(tpy) Nickel (tpy) Lead (tpy)

Total 

Chromium 

(tpy)

Chromium +6 

(tpy)

Mercury 

(lb/yr)

Hydrochloric 

Acid (tpy)

Hydrofluoric 

Acid (tpy)

Formaldehyde 

(tpy) PAH (t/yr)

CDD/CDF 

(lb/yr) PCB (lb/yr)

=================================== =================================== =================================== =================================== =================================== =================================== =================================== =================================== =================================== =================================== =================================== =================================== ===================================

Eramet

Furnace 1 scrubber outlet 49.1 0.0107 17.2 0.00852 0.131 0.00780 0.00239 312 1.24 0.0651 0.363 1.84 0.000527 0.000138

Furnace 12 scrubber outlet 24.7 0.00538 8.66 0.00429 0.0830 0.00392 0.00120 157 0.623 0.0328 0.183 0.927 0.000265 0.0000695

Furnace 18 tap/MOR BH outlet 31.1 0.00110 0.981 0.00147 0.000933 0.00434 0.000755 4.23 3.91 0.206 0.115 0.583 0.000167 0.0000437

Crushing C2P BH1 outlet 5.43 0.000199 2.23 0.00227 0.000212 0.00211 0.000645 0.676

Crushing C2P BH2 outlet 5.43 0.000199 2.23 0.00227 0.000212 0.00211 0.000645 0.676

Crushing C2P BH3 outlet 5.43 0.000199 2.23 0.00227 0.000212 0.00211 0.000645 0.676

Furnace 1 fugitives 61.4 0.0134 21.5 0.0107 0.164 0.00975 0.00298 22.9 0.773 0.0407 0.227 0.230 0.0000659 0.0000173

Furnace 12 fugitives 30.9 0.00672 10.8 0.00536 0.104 0.00491 0.00150 11.6 0.389 0.0205 0.114 0.116 0.0000332 0.00000870

Furnace 18 tap/MOR fugitives 38.9 0.00137 1.23 0.00183 0.00117 0.00543 0.00094 0.311 2.45 0.129 0.0718 0.073 0.0000209 0.00000547

Crushing C2P fugitives 33.3 0.00122 13.6 0.0139 0.00130 0.0129 0.00395 0.0487

Furnace 1 casting fugitives 63.0 0.0137 22.1 0.0109 0.168 0.0100 0.00306 23.5 0.793 0.0417 0.232 0.236 0.0000676 0.0000177

Furnace 12 casting fugitives 12.7 0.00276 4.44 0.00220 0.0426 0.00201 0.000616 4.73 0.160 0.00839 0.0468 0.0475 0.0000136 0.00000356

MOR Casting fugitives 21.0 0.000744 0.664 0.000993 0.000632 0.00294 0.000515 0.169 0.133 0.00702 0.0391 0.0397 0.0000114 0.00000298

Plant total 382 0.0576 108 0.0669 0.698 0.0703 0.0198 538 10.5 0.551 1.39 4.09 0.00117 0.000307

Felman

Furnace 2 BH outlet 20.4 0.00430 0.641 0.150 0.319 0.00757 0.00236 43.8 1.99 2.19 0.223 0.0685 0.00313 0.000244

Furnace 5 BH outlet 15.5 0.00328 0.489 0.115 0.243 0.00578 0.00180 33.4 1.52 1.67 0.170 0.0523 0.00239 0.000186

Furnace 7 BH outlet 24.5 0.00516 0.769 0.181 0.382 0.00909 0.00283 52.6 2.39 2.63 0.267 0.0823 0.00375 0.000292

Sizing #2 BH 0.393 0 0.198 0 0.000463 0.000206 0.0000640 0.0139

Furnace 2 fugitives 127 0.0269 4.01 0.941 1.99 0.0474 0.0147 3.22 0.125 0.137 0.0139 0.00857 0.000391 0.0000305

Furnace 5 fugitives 97.2 0.0205 3.06 0.717 1.52 0.0361 0.0112 2.46 0.0951 0.105 0.0106 0.00654 0.000298 0.0000232

Furnace 7 fugitives 153 0.0322 4.81 1.13 2.39 0.057 0.0177 3.87 0.150 0.165 0.0167 0.0103 0.000470 0.0000366

Sizing #2 fugitives 0.802 0 0.404 0 0.000946 0.000420 0.000131 0.000333

Furnace 2 casting fugitives 20.9 0.00441 0.658 0.154 0.327 0.00777 0.00242 0.529 0.0205 0.02 0.002 0.00141 0.0000642 0.00000500

Furnace 5 casting fugitives 15.6 0.00328 0.490 0.115 0.244 0.00579 0.00180 0.394 0.0152 0.0168 0.00170 0.00105 0.0000478 0.00000372

Furnace 7 casting fugitives 17.6 0.00371 0.554 0.130 0.275 0.00655 0.00204 0.446 0.0172 0.0190 0.00192 0.00119 0.0000541 0.00000421

Plant total 494 0.104 16.1 3.63 7.69 0.183 0.0571 141 6.33 6.96 0.707 0.232 0.0106 0.000825
11

An example of the fugitive emission calculation is presented below for arsenic.

where,

Aresenicfugitive = Estimated fugitive emissions from the EAF in tons per year,

AsEAF = Arsenic emissions for the EAF in tons per year,

CE = Control efficiency of the furnace control device,

0.92 = Percentage of uncontrolled emissions from the EAF,

CaptEAF = Assumed capture efficiency for the furnace emissions, and

0.08 = Percentage of uncontrolled emissions from tapping of the EAF.

This approach was used to calculate the individual pollutant fugitive emissions from each of the 

EAFs for the Eramet and Felman facilities. A summary of the annual fugitive emissions from each 

of the EAFs is presented in Table 5-2.
12

Table 5-3. Control Efficiencies used to Estimate EAF Exhaust and Fugitive Emissions

Pollutant(s) Scrubber Control 

Efficiency (%)

Fabric Filter

Control 

Efficiency (%)

Particulate Matter 95 99

Metal HAP 95 99

Hexavalent Chromium 95 99

Mercury 15 15

Hydrochloric Acid/Hydrofluoric Acid 90 0

Formaldehyde 90 0

PAH, PCB, CDD/CDF 50 50

Casting Fugitive Emissions

Particulate matter emissions from casting were calculated using a PM emission factor of 2.4 pounds 

of fugitive PM emissions per ton of ferroalloy cast.1 This emission factor was used to estimate the 

fugitive particulate matter emissions from casting operations. The casting emissions for the metal 

pollutants were estimated by developing a pollutant-to-PM profile for each of the EAF pollutants 

and multiplying that profile by the estimated casting fugitive PM emission rate. 

where;

ArsenicCast = Estimated arsenic emissions from casting in tons per year,

PMCast = Estimated PM emissions from casting in tons per year,

ArsenicEAF = Arsenic emissions from the associated EAF in tons per year, and

PMEAF = PM emissions from the associated EAF in tons per year.

A summary of the casting emissions are shown in Table 5-2.

 

1 Ohio Environmental Protection Agency, Reasonably Available Control Measures for Fugitive Dust Sources, Section 

2.14 Ferroalloys Production, September 1980.
13

Product Crushing Operations Emissions

The product crushing emissions were calculated using the test data provided in the ICR for both 

facilities. The hourly emission rate calculated in the test report was multiplied by 8760 hours per 

year to estimate the annual emission from the product crusher. For crushers that were not tested, 

the annual emission rates were assumed to be the same as the crusher that was tested. A summary

of the annual product crusher emissions is presented in Table 5-2.

Product Crushing Operations Fugitive Emissions

The annual fugitive emissions from the product crushing operations were estimated by calculating 

the uncontrolled pollutant emission rates using the pollutant control efficiencies and assuming only 

98 percent of these emissions are captured. The un-captured pollutant emissions were assumed to 

be fugitive. A summary of the annual fugitive emissions from the product crushing operations is 

shown in Table 5-2.

Control Efficiency Sensitivity

The control efficiencies in Table 5-3 used to estimate fugitive emissions are based on the expected 

emission reduction from the control technology. Historical performance shows that PM and metal 

HAP emissions are reduced by 99 percent when routed to a fabric filter control device. However, 

the fabric filter control effectiveness can vary slightly from facility to facility. The effect of this 

variation has a large effect on the calculation of the fugitive emissions, because of the material 

balance approach used to estimate fugitive emissions. Therefore, a sensitivity analysis was 

performed to determine the effect of the fabric filter control efficiency has on the particulate 

emissions. The sensitivity analysis was performed using 99, 98, and 97 percent control efficiency 

for the fabric filter using PM as the pollutant. A summary of the PM results for each of the 

ferroalloy facilities is presented in Table 5-4. As the table shows, the average difference for 

fugitive emission was 28.4 percent when going from 99 to 98 percent control efficiency. The 

average difference between the fugitive emissions for the 99 to 97 percent control efficiency was 

37.9 percent. The percent difference between the fugitive PM emissions ranged from 13.3 percent 

for the 99 to 98 control effectiveness to 58.0 percent for the 99 to 97 percent control effectiveness. 
14

Table 5-4 Summary of Sensitivity Analysis for Estimating Fugitive Emissions

6.0 MODELING DATABASE 

The modeling database was assembled using the annual pollutant emissions calculated for each 

process at the ferroalloy facilities. As shown in Table 5-1, some of the pollutant emissions were 

based on one or more analytical results that were reported below the detection limit. For these 

analytical results, one half of the detection limit was used to estimate the pollutant concentration. 

The run results were then averaged and the average concentration was used to calculate the 

pollutant emissions. After the database was assembled, a peer review of the pollutant emissions 

was conducted to determine if the emissions were representative of the ferroalloy facilities. The 

review raised questions regarding the determination of pollutant emissions from analytical results 

that were reported below the detection limit, and the calculation of emission rates from baghouse 

dust data. 

Modeling Emissions QA/QC

A review of the emissions showed that most of the metal HAP emissions were calculated from test 

data that were measured above the detection limit. The exceptions were lead and chromium from 

the Eramet facility, and mercury from both the Eramet and Felman facilities. In the case of lead at 

the Eramet facility, only the back half samples (impinger contents and rinse) reported results below

the detection limit. The majority of the total measured concentrations for lead were found in the 

front half samples (filter and probe rinse) for each of the tests. Therefore, the results of the test data 

for lead were considered valid and were modeled for EAF emission points. The chromium 

concentration results for the crusher outlet were also reported below the detection limit for one of 

the back half samples. Again the majority of the chromium concentrations were reported from the 

front half samples, and were determined to be valid test results.

Mercury emissions from the ferroalloy process will include particle-bound mercury, elemental 

mercury, and oxidized mercury. Particle-bound mercury is the mercury that has condensed onto 

particulate matter. Elemental mercury (Hg0) and oxidized mercury (Hg2

2+, Hg2+) comprise the 

vapor-phase mercury. Particle-bound, elemental, and oxidized mercury combined make up total 

Facility

PM TPY 

Emissions (99% 

CE)

PM TPY 

Emissions (98% 

CE)

PM TPY 

Emissions (97% 

CE)

Percent 

Difference 

(99% - 98%)

Percent 

Difference 

(99% - 97%)

Eramet 232 201 191 13.3% 17.8%

Felman 407 230 171 43.5% 58.0%

Fugitive Average Difference 28.4% 37.9%
15

mercury emissions. Particle-bound mercury emissions from EAFs make up a small percentage of 

the total mercury emissions, because much of the particulate has been captured in the particulate 

control device. The mercury emissions for Eramet and Felman were calculated from analytical 

results that were a mixture of detected and non-detected fractions, which is fairly common in Hg 

results from Method 29. The test method divides the sample into five fractions which include: 

Fraction 1B (rinse of front half glassware), Fraction 2B (rinse of back half acidic peroxide 

impingers), Fraction 3A (rinse of empty impinger), and fractions 3B and 3C (contents of acidic 

permanganate impingers). The Method 29 sampling is designed to measure total mercury by 

capturing particulate mercury in Fraction 1B, and vapor phase mercury in Fractions 2B, 3A, 3B and 

3C. Mercury was reported above the detection limit in all of the Fraction 3C samples, and all but 

one of the Fraction 2B samples from the test data submitted by the facilities, which indicate the 

presence of oxidized and elemental mercury in the gas stream. Therefore, the mercury results were 

determined to be significant and included in the modeling database.

A review of the HCl and HF emissions data found that 50 percent of the analytical data for the HCl 

test runs were measured below the detection limit, and 100 percent of the analytical data for the HF 

test runs were measured below the detection limit. The modeling emissions for HCl and HF were 

calculated by using the analytical results for test runs reported above the detection limit and one 

half of the detection limit for the test runs that were reported below the detection limit. [Note that 

after the modeling was concluded, a decision was made to exclude the HF test and modeling results 

from regulatory action because of the uncertainty of the HF test results.]

The CDD/CDF, PCB, and PAH concentrations for the two facilities were measured using different 

test methods. Eramet used Method 23 to measure the CDD/CDF and PCB concentrations, and 

Method 0010 to measure the PAH concentrations from the outlet of the control device. The outlet 

emissions from Eramet were calculated by multiplying the exhaust gas concentration and the 

exhaust gas flow rate. The Felman CDD/CDF, PCB, and PAH concentrations were obtained from 

the fabric filter dust using SW 846 Method 3500C/3600, and analyzed using SW-846 Method 

8270D for PAH and PCBs and SW 846-8280B for CDD/CDF. The analysis results were presented 

for each individual congener for each of the CDD/CDF, PCB, and PCB groups. The outlet 

emissions from Felman were calculated using a material balance methodology that assumes the 

control efficiency of the fabric filter to estimate the emissions. Because these concentrations were 

measured using different test methods, an analysis of the CDD/CDF, PCB and PAH test results was

conducted to determine the effect of the analytical results reported below the detection limit on the 

emissions. 

Tables 6-1, 6-2, and 6-3 present a summary of the CDD/CDF, PCB, and PAH test results 

respectively and the mass percentages of these values that were reported below the detection limit. 

As the tables show, the percentage of annual emissions that are based on analytical results reported 

below the detection limit for Eramet was 100 percent for the CDD/CDF emissions, 50.7 percent for 
16

the PCB emissions, and 0 percent for the PAH emissions. For Felman, the estimated CDD/CDF 

emissions are based on 5.1 percent non-detects, 18.7 percent non-detects for PCB emissions, and 

32.8 percent non-detects for PAH emissions. The test results from the Eramet tests are considered 

to be more representative of the actual emissions from the emission sources, because they were 

measured from the exhaust gas stream. The CDD/CDF and PCB modeling data from Eramet are 

based on 51 percent non-detects for the mass emissions. Based on these results, it was determined 

that the CDD/CDF and PCB emissions should not be modeled because of the uncertainty of the 

emissions of these pollutants. The PAH modeling data is based on test results above the detection 

limit, and is believed to be representative of the actual emissions from the EAF emissions source. 

Therefore, the PAH emissions data were included in the data used for modeling. 

Table 6-1. Summary of the CDD/CDF Analytical Results

Table 6-2. Summary of the PCB Analytical Results

Facility

Tested Furnace 

Annual CDD/CDF 

Emissions 

(Tons/yr) 1

Tested Furnace 

CDD/CDF Mass 

Emissions 

Percentage NonDetects 2

Comments

Felman 1.56E-06 5.14% Measured from baghouse dust

Eramet 1.33E-07 100.00% Measured using EPA Test Method 23

2

 The non-detect percentage was calculated by summing the total emissions for any congener that 

had one or more runs that were reported below the detection limit and dividing by the total.

1

 The annual emissions are the sum of the individual congeners.

Facility

Tested Furnace 

Annual PCB 

Emissions 

(Tons/yr) 1

Tested Furnace 

PCB Mass 

Emissions 

Percentage NonDetects 2

Comments

Felman 1.22E-07 18.73% Measured from baghouse dust

Eramet 3.48E-08 50.70% Measured using EPA Test Method 23

2

 The non-detect percentage was calculated by summing the total emissions for any congener that 

had one or more runs that were reported below the detection limit and dividing by the total.

1

 The annual emissions are the sum of the individual congeners.
17

Table 6-3. Summary of the PAH Analytical Results 

The PAH emissions were divided into four separate “risk PAH groups” and the groups were 

modeled as individual pollutants. The groups were established by assigning individual PAH 

pollutants with similar inhalation risks based on the unit risk estimate. The group emissions were 

calculated by summing the individual PAH emissions in each group. Table 6-4 provides a 

summary of the individual PAH pollutants that were provided in the ICR test reports and the group 

for which they were assigned. In addition, naphthalene emissions from the facilities were modeled 

separately as an organic HAP and not as a PAH, based on EPA assessment guidelines, which state

that naphthalene is inventoried as a separate HAP and is not included nor summarized in any PAH 

group.

Facility

Tested Furnace 

Annual PAH 

Emissions 

(Tons/yr) 1

Tested Furnace 

PAH Mass 

Emissions 

Percentage NonDetects 2

Comments

Felman 6.85E-02 32.84% Measured from baghouse dust

Eramet 9.27E-01 0.00% Measured using EPA Test Method 23

1

 The annual emissions 

2

 The non-detect percentage was calculated by summing the total emissions for any congener that 

had one or more runs that were reported below the detection limit and dividing by the total.
18

Table 6-4 List of PAH Groups and their Individual PAH Pollutants

Group Code Group Name Group URE

(1/(μg/m3)) PAH Pollutant

72002 Group 2 8.8E-5

Acenaphthene

Acenaphthylene

Anthracene

Benzo[e]pyrene

Benzo[g,h,i]perylene

Benzofluoranthenes

Fluoranthene

Fluorene

Perylene

Phenanthrene

Pyrene

75002 Group 5 1.6E-3

Benzo[a]pyrene(7-PAH)

Dibenzo[a,h]anthracene

76002 Group 6 1.6E-4

Benz[a]anthracene

Benzo[b]fluoranthene

Benzo[b+k]fluoranthene

Indeno[1,2,3-c,d]pyrene

77002 Group 7 1.6E-5 Chrysene

The total mercury and chromium emissions that were used for modeling were speciated into 

chromium III and chromium VI, and mercuric chloride and elemental mercury. The speciation of 

the mercury samples for these facilities was done using mercury speciation factors developed for 

the ferroalloys industry.2 The speciation factor divides the total mercury emissions into 10 percent 

particulate mercury, 10 percent gaseous mercury, and 80 percent elemental mercury. Using these 

speciation factors, the mercuric chloride was calculated as 20 percent of the total mercury emissions 

and elemental mercury was calculated to be 80 percent of the total mercury emissions. The 

speciation of total chromium was done by subtracting the chromium VI emissions from the total 

chromium emissions to obtain the chromium III emissions.

 

2 Environmental Protection Agency, Emissions Modeling Clearinghouse Speciation, April 2010. 

http://www.epa.gov/ttnchie1/emch/speciation/
19

Emission Process Groups

The emission sources from the test data were divided into emission process groups using the 

Standard Classification Codes (SCC) supplied by the facility in the ICR. The emission groups for 

the Ferroalloys category were; open EAF, fugitive dust sources, raw material crushing and 

screening operations, casting, and other. Table 6-5 presents a summary of the SCC and the 

assigned emission process group. 

Latitude/Longitude QA/QC

The latitude and longitude coordinates provided by the facilities were reviewed to ensure that the 

coordinates matched the location of the emission points. This was done by plotting each emission 

point on a map of the facility using Google Earth. The plotted emission points were then evaluated 

to determine if the emission point matched the expected location of the emission point. If it was 

determined that the emission point did not match the expected location on the facility map, the 

point was moved to the expected location and new latitude and longitude coordinates were 

determined. The map and the emission point coordinates were sent to the facilities for confirmation 

of the locations.

Stack and Fugitive Parameters QA/QC

The stack and fugitive emission parameters provided by the facility in the ICR were verified to 

ensure they were correct. The volumetric flow rates for the point sources were checked by 

calculating the volumetric flow rate using the velocity and duct dimensions. The calculated flow 

rates were compared with the volumetric flow rates provided in the test reports. If the flow rate 

difference exceeded 30 percent, engineering judgments were made to revise the velocity or duct 

dimension data. Fugitive parameters were inputted using the Google Earth map for each of the 

facilities and estimating the length, width, and angle of the fugitive emissions.
20

Table 6-5. Summary of Assigned Emission Process Groups for the Ferroalloys SCC

SCC SCC1_DESCRIPTION SCC3_DESCRIPTION SCC6_DESCRIPTION SCC8_DESCRIPTION Emission Process Group

30300601 Industrial Processes Primary Metal Production Ferroalloy, Open Furnace 50% FeSi: Electric Smelting Furnace Open EAF

30300602 Industrial Processes Primary Metal Production Ferroalloy, Open Furnace 75% FeSi: Electric Smelting Furnace Open EAF

30300603 Industrial Processes Primary Metal Production Ferroalloy, Open Furnace 90% FeSi: Electric Smelting Furnace Open EAF

30300604 Industrial Processes Primary Metal Production Ferroalloy, Open Furnace Silicon Metal: Electric Smelting Furnace Open EAF

30300605 Industrial Processes Primary Metal Production Ferroalloy, Open Furnace Silicomanaganese: Electric Smelting Furnace Open EAF

30300606 Industrial Processes Primary Metal Production Ferroalloy, Open Furnace 80% Ferromanganese Open EAF

30300607 Industrial Processes Primary Metal Production Ferroalloy, Open Furnace 80% Ferrochromium Open EAF

30300608 Industrial Processes Primary Metal Production Ferroalloy, Open Furnace Raw Material Unloading Fugitive Dust Sources

30300609 Industrial Processes Primary Metal Production Ferroalloy, Open Furnace Raw Material Crushing Raw Material Crushing & Screening Operations

30300610 Industrial Processes Primary Metal Production Ferroalloy, Open Furnace Ore Screening Raw Material Crushing & Screening Operations

30300611 Industrial Processes Primary Metal Production Ferroalloy, Open Furnace Ore Dryer Raw Material Crushing & Screening Operations

30300613 Industrial Processes Primary Metal Production Ferroalloy, Open Furnace Raw Material Storage Fugitive Dust Sources

30300614 Industrial Processes Primary Metal Production Ferroalloy, Open Furnace Raw Material Transfer Fugitive Dust Sources

30300615 Industrial Processes Primary Metal Production Ferroalloy, Open Furnace Ferromanganese: Blast Furnace Other

30300616 Industrial Processes Primary Metal Production Ferroalloy, Open Furnace Ferrosilicon: Blast Furnace Other

30300617 Industrial Processes Primary Metal Production Ferroalloy, Open Furnace Cast House Casting

30300618 Industrial Processes Primary Metal Production Ferroalloy, Open Furnace Mix House/Weighing Fugitive Dust Sources

30300619 Industrial Processes Primary Metal Production Ferroalloy, Open Furnace Raw Material Charging Fugitive Dust Sources

30300620 Industrial Processes Primary Metal Production Ferroalloy, Open Furnace Tapping Tapping Operation

30300621 Industrial Processes Primary Metal Production Ferroalloy, Open Furnace Casting Casting

30300622 Industrial Processes Primary Metal Production Ferroalloy, Open Furnace Cooling Fugitive Dust Sources

30300623 Industrial Processes Primary Metal Production Ferroalloy, Open Furnace Product Crushing Product Crushing & Screening Operations

30300624 Industrial Processes Primary Metal Production Ferroalloy, Open Furnace Product Storage Fugitive Dust Sources

30300625 Industrial Processes Primary Metal Production Ferroalloy, Open Furnace Product Loading Fugitive Dust Sources

30300651 Industrial Processes Primary Metal Production Ferroalloy, Open Furnace Sealed Furnace: Ferromanganese: Electric Arc Furnace Other

30300652 Industrial Processes Primary Metal Production Ferroalloy, Open Furnace Sealed Furnace: Ferrochromium: Electric Arc Furnace Other

30300653 Industrial Processes Primary Metal Production Ferroalloy, Open Furnace Sealed Furnace: Ferrochromium Silica: Electric Arc Furnace Other

30300654 Industrial Processes Primary Metal Production Ferroalloy, Open Furnace Sealed Furnace: EAF - Other Alloys: Specify in Comment Other

30300699 Industrial Processes Primary Metal Production Ferroalloy, Open Furnace Other Not Classified Other

30300701 Industrial Processes Primary Metal Production Ferroalloy, Semi-covered Furnace Ferromanganese: Electric Arc Furnace Semi-closed EAF

30300702 Industrial Processes Primary Metal Production Ferroalloy, Semi-covered Furnace Electric Arc Furnace: Other Alloys/Specify Open EAF

30300703 Industrial Processes Primary Metal Production Ferroalloy, Semi-covered Furnace Ferrochromium: Electric Arc Furnace Semi-closed EAF

30300704 Industrial Processes Primary Metal Production Ferroalloy, Semi-covered Furnace Ferrochromium Silicon: Electric Arc Furnace Semi-closed EAF

Note: Highlighted SCCs are included in the Ferroalloys modeling database.
21

7.0 MACT ALLOWABLES

The modeling emissions calculated from the ICR test data represents an estimate of the mass 

emissions actually emitted during the specified annual time period. These “actual” emission levels 

are often lower than the emission levels that a facility might be allowed to emit and still comply 

with the MACT standards. The emissions level allowed to be emitted by the MACT standards is 

referred to as the “MACT-allowable” emissions level. This represents the highest emissions level 

that could be emitted by the facility without violating the MACT standards. The assessment of 

these risks at the MACT-allowable level reflects the maximum level sources could emit and still 

comply with national emission standards.

To estimate emissions at the MACT-allowable level, a ratio of MACT-allowable to actual 

emissions for each source type (i.e., the individual stack emissions) were developed for each of the 

facilities in the source category. This ratio is based on the emission limits required by the MACT 

standards compared to the reported actual emissions. These ratios for each emission point type at 

the facilities in this source category were applied to the maximum chronic risk estimates from the 

inhalation risk assessment to obtain maximum risk estimates based on MACT-allowable emissions. 

A table of the MACT-allowable ratios is presented in Table 7-1.
22

Table 7-1. Summary of MACT-Allowable Ratios for Eramet and Felman

Emission Source Source ID

Actual PM 

Emissons (lb/yr)

MACT Allowable 

PM Emissions 

(lb/hr)

Actual PM Conc. 

(gr/dscf)

MACT Allowable 

PM Conc. 

(gr/dscf)

MACT/Allowable 

Ratio Comment

Furnace 1 Baghouse Outlet M_OE0008 1.24 29.8 24.0 63.1652(b)(2)

Furnace 12 Scrubber Outlet M_OE0009 5.64 35.9 6.4 63.1652(b)(3)

MOR Baghouse Outlet M_SE0006 0.0004 0.03 81.1 63.1652(d)

C2P BH1 Outlet M_PC0014 0.0033 0.03 9.1 63.1652(e)(2)

C2P BH2 Outlet M_PC0015 0.0033 0.03 9.1 63.1652(e)(2)

C2P BH3 Outlet M_PC0016 0.0033 0.03 9.1 63.1652(e)(2)

Furnace 2 BH Outlet M_OE0008 4.64 27.2 5.9 63.1652(b)(4)

Furnace 5 BH Outlet M_OE0012 3.54 27.2 7.7 63.1652(b)(4)

Furnace 7 BH Outlet M_OE0014 5.59 27.2 4.9 63.1652(b)(4)

Sizing #2 BH M_PC0006 0.0011 0.03 27.7 63.1652(e)(2)

Eramet (Facility ID: 39167NEI11660)

Felman (Facility ID: 54053NEIWV053FELMAN)