From: "Laura K. McAfee" <LMcAfee@bdlaw.com> 

To: Chuck French/RTP/USEPA/US@EPA 

Cc: Conrad Chin/RTP/USEPA/US@EPA 

Date: 10/04/2012 04:02 PM 

Subject: RE: Summary of 2012 Stack Testing and Historical PM data

Hi Chuck –

I have forwarded this on to the client to see what we have. 

In the interim, I wanted to get back to you on the question you asked a few weeks ago about the 

potential costs associated with using ACI at Felman’s facility. Since we originally spoke, we have had LAN 

looking into this to attempt to develop some cost calculations, although they are understandably rough 

figures given the short time available and the fairly speculative nature of the potential system. 

A few notes:

 First, you specifically asked only about the costs associated with disposing of vs. recycling the 

baghouse dust, because you indicated you already had a good sense of the capital costs 

associated with an activated carbon system from Eramet’s submission. We respectfully disagree 

with that conclusion: as we discussed briefly on the phone, Felman’s existing baghouse system is 

different from Eramet’s (positive pressure vs. negative pressure) and therefore requires a 

different configuration for an ACI system. We have therefore developed cost estimates for both 

capital and operating costs. 

 We have developed two cost estimates reflecting two different alternatives for installing ACI. 

The first would involve adding ACI to the current Felman configuration, i.e., upstream of the 

current positive pressure baghouses. The second would involve replacing Felman’s current 

baghouses with negative pressure baghouses, then adding the ACI system before a new 

polishing baghouse.

 Where possible, we have calculated costs using the same inputs EPA and Eramet used to 

estimate ACI costs at Eramet’s facility, from the cost equations developed for the Utility NESHAP 

(as reflected in a March 2011 Memorandum from Sargent & Lundy). 

 Flow rates are based on the flow rates measured during Felman’s stack tests from July and 

November, 2010 and August 2012. 

 You asked specifically whether the baghouse dust, which is currently recycled to the process for 

its manganese content, would have to be disposed of as a hazardous waste if ACI were installed. 

At this point, we cannot determine whether the mercury in the dust would require disposal as a 
hazardous waste, so we have calculated two different figures to reflect both alternatives. The 

primary concern would be the potential for mercury to accumulate in the dust if the dust was 

recycled to the process, which could create both a health concern for Felman workers and a 

waste disposal concern. As a side note, the Felman facility experienced a similar situation 

several years ago due to the use of an ore with a higher lead content. As a result of the lead 

levels in the baghouse dust, Felman was not able to either recycle the dust or find a purchaser 

for the dust; Felman ultimately paid approximately $750K to dispose of dust that had 

accumulated at the site. Felman is understandably hesitant to pursue any alternatives that 

might re-create a similar situation. 

Option 1 

Option one involves adding ACI upstream of Felman’s current positive pressure baghouses. Felman 

estimates that the capital costs of this installation would be approximately $10MM for all three furnaces 

combined. 

Because this option would install the ACI upstream of the baghouses, Felman would lose the 

opportunity to recycle the baghouse dust back to the process because of the mercury in the dust. 

Felman currently recycles approximately 1,200 tons/month of baghouse dust back to the process from 

all three furnaces combined. Accordingly, this alternative would require Felman to: (i) dispose of 

approximately 1,200 tons/month of dust as waste (which alone would cost between $48,000-

$480,000/month, using Eramet’s estimate of $40/ton for nonhazardous waste disposal and $400/ton for 

hazardous waste disposal); and (ii) purchase the equivalent amount of ore to make up for the 

manganese in the baghouse dust (approximately $750,000-$1MM/year, based on the cost and grade of 

the ore). 

LAN has calculated that the annual operating costs, including capital recovery, would range from 

approximately $3.2MM (if the dust is non-hazardous waste) to $8.5MM (if the dust is hazardous waste). 

Option 2 

Option 2 involves replacing the current positive pressure baghouses with negative pressure baghouses, 

installing ACI downstream of these baghouses, and then installing a new polishing baghouse after the 

ACI system. This system would have the benefit of allowing Felman to continue to recycle the dust from 

the initial baghouses and therefore minimizing both waste disposal and replacement raw material costs. 

However, the costs of installing and operating the new systems more than offset these cost savings. LAN 

has calculated that the capital cost of installing all of the required new baghouse systems would exceed 

$120MM, and that the annual operating costs would exceed $16MM (again including capital recovery). 

As another point of comparison, LAN’s calculations indicate that installing an ACI system at Felman’s 

facility would cost between $28,000-$143,000 per pound of mercury removed (assuming that both the 
assumed mercury levels and assumed mercury removal rates are accurate). Felman believes that these 

figures demonstrate that an ACI system is simply not cost-effective. 

I hope this answers your question. 

Laura

Laura K. McAfee 

Principal 

Beveridge & Diamond, P.C. 

201 North Charles St. Suite 2210 

Baltimore, MD 21201 

T (410) 230-1330 ~ F (410) 230-1389 

LMcAfee@bdlaw.com

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From: Chuck French [mailto:French.Chuck@epamail.epa.gov] 

Sent: Wednesday, October 03, 2012 4:39 PM 

To: Laura K. McAfee 

Cc: Conrad Chin 

Subject: Re: Summary of 2012 Stack Testing and Historical PM data

Hi Laura, 

Thank You very much for sending the test result summaries. The data are helpful. I have another 

request. We are trying to make sure the emissions release heights that we input to the model are as 

accurate as we can get them. Attached is a table of the process units and information we have on 

release heights that we got from the 2010 ICR responses. You will see that several cells are empty (i.e., 

no release height info). Could you and your colleagues please review this table and provide your best 

estimates of release heights for each of these emissions sources? Also, let us know if you have any 

corrections. Please let us know as soon as you can. 

Thank You. 
Let me know if you have questions. 

Chuck French 

Group Leader 

Metals and Inorganic Chemicals Group 

Office of Air Quality Planning and Standards 

U.S. EPA 

Phone: 919-541-7912