EPA-450/2 -74-018a
     BACKGROUND INFORMATION
 FOR STANDARDS OF  PERFORMANCE:
ELECTRIC SUBMERGED  ARC FURNACES
 FOR PRODUCTION OF  FERROALLOYS
  VOLUME 1:   PROPOSED STANDARDS
           Emission Standards and Engineering Division
           U.S. ENVIRONMENTAL PROTECTION AGENCY
              Office of Air and Waste Management
            Office of Air Quality Planning and Standards
           Research. Triangle Park, North Carolina 27711

                     October 1974

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technical data of interest to a limited number of readers.  Copies are
available free of charge to Federal employees, current contractors and
grantees, and nonprofit organizations - as supplies permit - from the Air
Pollution Technical Information Center, Environmental Protection Agency,
Research Triangle Park, North Carolina 27711;  or, for a fee, from the
National Technical Information Service, 5285 Port Royal Road, Springfield,
Virginia 22161.
                  Publication No. EPA-450/2-74-018®
                                 ii

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                             PREFACE
 A.  Purpose of this Report
      Standards of performance under section 111 of the Clean
 Air Act-  are proposed only-after a very detailed investigation
 of air pollution control  methods available to the affected
 industry and the impact of their costs on the industry.  This
 report summarizes the information obtained from such a study
 of the ferroalloy industry.   It is being distributed in
 connection with formal  proposal  of standards  for that industry
 in the Federal  Register.   Its  purpose  is to explain  the
 background and  basis  of the  proposal  in greater detail  than
 could  be  included in  the  Federal  Register,  and  to  facilitate
 analysis  of the  proposal  by  interested persons,  including  those
 who may not  be  familiar with the  many  technical  aspects of the
 industry.   For additional  information,  for  copies  of  documents
 (other than  published literature)  cited in  the  Background
 Information  Document, or  to comment on  the  proposed standards,
 contact Mr.  Don R. Goodwin, Director,  Emission Standards and
 Engineering  Division, United States Environmental  Protection
 Agency, Research Triangle Park, North Carolina 27711  [(919)688-8146],
 B.  Authority for the Standards
     Standards of performance for new stationary sources are
promulgated in accordance  with  section 111 of the Clean Air Act
 (42 USC 1857c-6), as  amended  in 1970.   Section 111  requires
     I/  Sometimes referred to as "new source performance
standards" (NSPS).
                           in

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the establishment of standards of performance for new stationary
sources of air pollution which "... may contribute significantly
to air pollution which causes or contributes to the endangerment
of public health or welfare."  The Act requires that standards
of performance for such sources reflect "... the degree of
emission limitation achievable through the application of the best
system of emission reduction which (taking into account the cost
of achieving such reduction) the Administrator determines has
been adequately demonstrated."  The standards apply only to
stationary sources, the construction or modification of which
commences after regulations are proposed by publication in
the Federal Register.
     Section 111 prescribes three steps to follow in establishing
standards of performance.
      I.  The Administrator must identify those categuries of
         stationary sources for which standards of performance
         will ultimately be promulgated by listing them in the
         Federal Register.
     2.  The regulations applicable to a category so listed must
         be proposed  by publication in the Federal Register, within
         120 days  of  its listing.  This proposal provides interested
         persons an opportunity for comment.
      3.  Within 90 days after the  proposal, the Administrator
         must promulgate standards with any alterations he deems
         appropriate.
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     It 1s Important to realize that standards of performance,
by themselves, do not guarantee protection of health or welfare;
that 1s, they are not designed to achieve any specific air
quality levels.  Rather, they are designed to reflect best
demonstrated technology (taking Into account costs) for the
affected sources.  The overriding purpose of the collective
body of standards is to maintain existing air quality and to
prevent new pollution problems from developing.
     Previous legal challenges to standards of performance for
Portland cement plants, steam generators, and sulfuric acid
plants have .resulted in several court decisions^ of importance
1n developing future standards.  In those cases, the principal
issues were whether EPA:  (1) made reasoned decisions and
fully explained the basis of the standards, (2) made available
to interested parties the information on which the standards
were based, and (3) adequately considered significant comments
from interested parties.
     Among other things, the court decisions established:
(1) that preparation of environmental impact statements is not
necessary for standards developed under section ill  of the Clean
A1r Act because,  under that section, EPA must consider, any
counter-productive environmental effects of a standard in
determining what  system of control is "best;" (2)  in considering
costs 1t is not necessary to provide a cost-benefit analysis;
     27Portlant Cement Association v Ruckelshaus,  486 F.  2nd
375 (U.C. Cir. 1973); Essex Chemical Corp.  v Ruckelshaus,  486
F. 2nd 427 (D.C. Cir. 1973).

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 (3)   EPA Is  not required  to  justify standards that require different
 levels  of-control  in  different  industries  unless such different
 standards may. be unfairly discriminatory;  and (4) it is
 sufficient  for EPA to show that a  standard can be achieved
 rather  than  that it has been achieved  by existing sources.
      Promulgation of  standards  of  performance does not prevent
 State or local agencies from adopting  more stringent emission
 limitations  for the same  sources.  On  the  contrary section 116
 of the  Act  (42 USC 1857-D-l) makes clear that States and other
 political subdivisions may enact more  restrictive standards.
 Furthermore, for heavily  polluted  areas, more stringent standards
 may be  required under section 110  of the Act (42 USC 1857c-5) in
.order to attain or maintain  national ambient air quality standards
 prescribed  under section  109 (42 USC 1857c-4).  Finally, section  116
 makes clear that a State  may not adopt or  enforce less stringent
 standards than those  adopted by EPA  under  section 111.
      Although it is clear that standards of performance should  be
 in terms of limits -tin"emissions where  feasible,-'' an alternative
 method of requiring control  of air pollution is sometimes
 necessary.   In some cases physical measurement "of emissions
 from a new source may be impractical  or exorbitantly expensive.
      37"'Standards  of performance,'  ...  refers  to the  degree  of
 emission control which can be achieved through  process  changes,
 operation changes, direct emission control, or other methods.   The
 Secretary [Administrator] should not make  a technical  judgment
 as to how the standard should be implemented.  He  should determine
 the achievable limits and let the owner or operator determine  the
 most economical technique to apply."  Senate Report 91-1196.
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  For example,  emissions  of  hydrocarbons from storage vessels for
 petroleum liquids  are  greatest  during storage and tank filling.
 The nature of  the  emissions  (high concentrations for short
 periods  during filling and  low  concentrations for longer
 periods  during storage)  and  the configuration of storage tanks
 make direct emission measurement highly impractical.  Therefore,
 a more practical approach to standards of performance for
 storage  vessels has been equipment specification.
 C.   Selection  of Categories  of Stationary Sources
      Section 111 directs the Administrator to publish and from
 time  to  time revise a list of categories of sources for which
 standards  of performance are to be oroposed.  A cateaory is to
 be  selected "... if [the Administrator] determines it may contribute
 significantly  to air pollution which causes or contributes to the
 endangerment of public health or welfare."
      Since passage of the Clean Air Amendments of 1970,  considerable
 attention  has been given to the development of a system for
 assigning  priorities to various source categories.   In brief,
 the approach that has evolved is as follows.
      First, we assess any areas of emphasis by ^considering the
broad EPA  strategy for implementing the Clean Air Act.   Often,
these "areas" are actually pollutants which are  primarily emitted
by stationary sources.   Source categories  which  emit these
pollutants are then evaluated and ranked by a process  involving

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such factors as (1) the level of emission control  (if any)
already required by State regulations; (2) estimated levels
of control that might result from standards of performance  for the
source category; (3) projections of growth and replacement
of existing facilities for the source category; and (4)  the
estimated incremental amount of air pollution that could be
prevented, in a preselected future year, by standards of
performance for the source category.
     After the relative ranking is complete, an estimate
must be made of a schedule of activities required to develop
a standard.  In some cases, it may not be feasible to immediately
develop a standard for a source category with a very high
priority.  This might occur because a program of research
and development is needed or because techniques for sampling
and measuring emissions may require refinement before study
of the industry can be initiated.  The schedule of activities
must also consider differences in the time required to complete
the necessary investigation for different source categores.
Substantially more time may be necessary, for example, if a
number of pollutants must be investigated in a single source
category.  Even late in the development process the
schedule for completion of a standard may change.  For
example, inability to obtain emission data from

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 well-controlled sources In time to pursue the development
 process 1n a systematic fashion may force a  change in
 scheduling.
      Selection of the  source  category leads  to another major
 decision:   determination of the types of sources  or facilities
 to which the standard  will  apply.   A source  category often
 has several  facilities that cause  air pollution.   Emissions
 from  some  of these facilities may  be insignificant and, at the
 same  time,  very expensive  to  control.  An  investigation of
 economics  may show that, within  the  costs  that  an  owner could
 reasonably afford,  air pollution control is  better served by
 applying standards  to  the more severe  pollution problems.  For
 this  reason  (or perhaps  because there  may  be no adequately
 demonstrated  system for  controlling  emissions from certain
 facilities),  standards often do not  apply  to all sources within
 a category.   For similar reasons, the  standards may not apply
 to all air pollutants emitted by such  sources.  Consequently,
 although a source category may be selected to De covered by a
standard of performance, treatment of some of the pollutants or
 facilities within that source category may be deferred.
D.  Procedure for Development of Standards of Performance
     Congress mandated that sources regulated under section 111
of the Clean Air Act be required to utilize the best practicable
air pollution control  technology that has been adequately
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demonstrated at the time of their design and construction.   In  so
doing, Congress sought to:
     1.  maintain existing high-quality air,
     2.  prevent new air pollution problems, and
     3.  ensure uniform national standards for new facilities.
     The selection of standards of performance to achieve the
Intent of Congress has been surprisingly difficult.  In general,
the standards must (1) realistically reflect best demonstrated
control practice; (2) adequately consider the cost of such control;
(3) be applicable to existing sources that are modified as well
as new installations; and (4) meet these conditions for all
variations of operating conditions being considered anywhere in
the country.
     A major portion of the program for development,of standards
is spent identifying the best system of emission reduction which
"has been adequately demonstrated" and quantifying the emission
rates achievable with the system.  The legislative history of
section 111 and the court decisions referred to above make clear
that the Administrator's judgment of what is adequately demonstrated
is not limited to systems that  are in actual rodtine use.
Consequently, the search may include a technical assessment
of control systems which have been adequately demonstrated but
for which there is limited operational experience.  To date,
determination of the  "degree of emission  limitation achievable"
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has been  commonly  based  on  (but not  restricted to) results
of tests  of emissions  from  existing  sources.  This has
required  worldwide investigation and measurement of emissions
from control systems.  Other countries with heavily populated,
industrialized areas have sometimes  developed more effective
systems of  control  than  those used in the United States.
     Because the best  demonstrated systems of emission reduction may
not be in widespread use, the data base upon which the standards
are established will necessarily be  somewhat limited.  Test
data on existing well-controlled sources are an obvious starting
point in developing emission limits  for new sources.   However,
since the control  of existing sources generally represents
retrofit technology or was originally designed to meet an
existing State or  local regulation, new sources may be able
to meet more stringent emission standards.   Accordingly, other
information must be considered and judgment is necessarily
involved in setting proposed standards.
     Since passage of the Clean Air Amendments of 1970, a
process for the development of a standard has evolved.  In
general,  it follows the guidelines  below.
     1.   Emissions from existing well-controlled  sources
         are measured.
     2.   Data on  emissions from such  sources  are  assessed with
         consideration  of such  factors as:   (a) the representativeness
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of the source tested (feedstock, operation,  size,  age,
etc.); (b) the age and maintenance of the control
equipment tested (and possible degradation in the
efficiency of control of similar new equipment even
with good maintenance procedures); (c) the design
uncertainties for the type of control equipment being
considered; and (d) the degree of uncertainty affecting
the judgment that new sources will be able to achieve
similar" levels of control.
During development of the standards, information from
pilot and prototype installations, guarantees by vendors
of control equipment, contracted  (but not yet constructed)
projects, foreign technology, and published literature
are considered, especially for  sources where "emerging"
technology appears significant.
Where possible, standards are set at a level that  is
achievable with more  than one control technique or
licensed  process.
Where possible, standards are set to encourage  (or at  least
permit)  the  use of process modifications or new processes
as  a  method  of control  rather than  "add-on" systems  of
air pollution control.
Where possible, standards are set to permit use of

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         systems capable of controlling more than one pollutant  ,
         (for example, a scrubber can remove both gaseous and
         particulate matter emissions, whereas an electrostatic
         precipitator is specific to particulate matter).
     7.  Where appropriate, standards for visible emissions are
         established in conjunction with mass emission standards.
         In such cases, the standards are set in such a way that
         a source meeting the'mass emission standard will be able
         to meet the visible emission standard without additional
         controls.  (In some cases, such as fugitive dust, there
         is no mass standard).
     Finally, when all pertinent data are available, judgment
is again required.  Numerical  tests may not be transposed directly
into regulations.  The design and operating conditions of those
sources from which emissions were actually measured cannot be
reproduced exactly by each new source to which the standard of
performance will apply.
E.  How Costs are Considered
     Section 111 of the Clean Air Act requires that cost be
considered in setting standards of performanceT  To do this requires
an assessment of the possible economic effects of implementing
various levels of control  technology in hew plants within a
given industry.   The first step in this analysis requires the
generation of estimates of installed capital  costs and annual
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operating costs for various demonstrated control  systems,
each control system alternative having a different overall
control capability.  The final step in the analysis 1s to
determine the economic Impact of the various control alternatives
upon a new plant 1n the Industry.  The fundamental question to
be addressed in this step is whether or not a new plant would
be constructed given that a certain level of control costs  would
be Incurred.  Other Issues that would be'analyzed 1n this step
would be the effects of control costs upon product prices and the
effects on product and raw material supplies and producer
profitability.
     The economic impact upon an industry of a proposed standard
1s usually addressed both 1n absolute terms and by comparison
with the control costs that would be incurred as a result
of compliance with typical existing State control regulations.
This incremental approach 1s taken since a new. plant would
be required to comply with State regulations 1n the absence
of a Federal standard of performance.  This approach requires
a detailed analysis of the impact upon the industry resulting
from the cost differential that usually exists between the
standard of performance and the typical State standard.
     It should be noted that  the costs for control of air
pollutants are not the only control costs considered.  Total
environmental costs for control of water pollutants as well

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 as air pollutants are analyzed wherever possible.
      A thorough study of the profitability and price-setting
 mechanisms  of the Industry is essential  to the analysis  so
 that  an accurate estimate of potential  adverse economic  impacts
 can be made.   It is  also essential  to know the capital requirements
 placed on plants in  the  absence  of  Federal  standards of  performance
 so that the additional capital  requirements necessitated by these
 standards can  be placed  in  the  proper perspective.  Finally, it
 is necessary to  recognize any constraints  on capital availability
 within  an industry as this,  factor also influences the ability
 of new plants  to generate the capital required  for installation
 of the  additional control equipment needed to meet the standards
 of performance.                •.....•
     The end result of the analysis is a presentation of costs
 and potential  economic impacts-for a series of control
 alternatives.  This information is then a major factor which
 the Administrator considers in selecting a standard.
 F.  Impact on  Existing Sources
     Proposal of standards of performance may affect an existing
source in either of two ways.  First, if modiffed after
proposal of the standards, with" a subsequent increase in
air pollution, it is subject to standards of performance  as
if it were a new source.   (Section 111  of the Act defines a
new source as "any stationary source, the construction  or
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modification of which is commenced after the regulations are
proposed.")—'
     Second, promulgation of a standard of performance requires
States to establish standards of performance for the same pollutant
for existing sources in the same industry under section lll(d)  of
the Act; unless the pollutant limited by the standard for new
sources is one listed under section 108 (requiring promulgation of
                                         \
national ambient air quality standards) or one listed as a
hazardous pollutant under section 112.  If a State does not act,
EPA must establish such standards.  Regulations prescribing
procedures for control of existing sources under section lll(d)
will be proposed as Subpart B of 40 CFR Part 60.
G.  Revision of Standards of Performance
     Congress was aware that the level of air pollution control
achievable by any industry may improve with technological
advances.  Accordingly, section 111 of the Act provides that
the Administrator may revise such standards from time to time.
Although standards proposed and promulgated by EPA under section 111
are designed to require installation of the "... best system of
emission reduction ...  (taking into account the- cost)..."
the standards will be reviewed periodically.  Revisions will be
proposed and promulgated as necessary to assure that the standards
     37Specific provisions dealing with modifications to existing
facilities  are being  proposed by  the Administrator under the
General  Provisions of 40 CFR Part 60.
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continue to reflect the best systems that become available
in the future.  Such revisions will not be retroactive but
will apply to stationary sources constructed or modified after
proposal of the revised standards.
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                               TABLE OF CONTENTS
  I.  THE FERROALLOY INDUSTRY 	    1
      A.  General 	,	    1
      B.  Processes or Facilities and Their Emissions 	    6

 II.  PROPOSED STANDARDS OF PERFORMANCE	 15
      A.  Standards of Performance as Proposed.	 15
      B.  Discussion of Proposed Mass Standards 	 15
      C.  Discussion of Proposed Opacity Standards	18

III.  EMISSION CONTROL TECHNOLOGY 	  21
      A.  Open Furnace 	  21
      B.  The Semi-Enclosed Furnace 	  24
      C.  The Sealed Furnace 	  28
      D.  Control of Fumes During Tapping 	  31
 IV.  ENVIRONMENTAL EFFECTS	  33
      A.  Impact on Air Pollution 	  33
      B.  Impact on Water Pollution 	  37
      C.  Impact on Solid Waste Pollution 	  38
      D.  Energy Considerations 	  39
  V.  SUMMARY OF THE PROCEDURE FOR DEVELOPING STANDARDS 	  41
      A.  Literature Review and Industrial Contacts 	  41
      B.  Selection of Pollutants and Affected Facilities 	  42
      C.  Plant Inspections 	  44
      D.  Sampling and Analytical Procedures	  4$
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      E.  Emission Measurement Program	    46
      F.  Units of the Standard	    47
      G.  Development of Proposed Standards	    48
  VI.  DATA TO  SUBSTANTIATE A  STANDARD	    51
      A.  Concentration  and Mass  Data  	••	    51
      B.  Visible  Emission Data  	    61

 VII.  SUMMARY  OF  ECONOMIC INFORMATION  	    65
      A.  Introduction..	••    65
      B.  Model Plants	    66
      C.  Control  Costs	    68
      D.  Discussion of the  Control  Costs 	    84
      E.  Economic Impact	    87

VIII.  ALTERNATIVE STANDARDS  	    89
      A.  Alternative Standards  for Particulate Matter	     89
       B.   Alternative Standards  for Carbon Monoxide (CO)	     99
       C.   Alternative Standards  for Visible Emissions	    101

  IX.   ENFORCEMENT ASPECTS OF THE PROPOSED STANDARDS.	    103
       A.   Particulate Matter Standard	    103
       B.   Visible Emissions Standard	    107
       C.   Carbon Monoxide Standard	    107
       D.   Emission Monitoring		,	    1°8
       E.   Monitoring of Operations	   108

   X.  MODIFICATIONS		•	   HI
       A.  Open Furnaces	   H3
                                 xix;

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      B.   Semi-Enclosed Furnaces
      C.   Sealed Furnaces 	
113
113
 XI.  MAJOR ISSUES CONSIDERED 	   115
XII.  REFERENCES 	
      A.   Cited References ..
      B.   General  References
 TECHNICAL REPORT  DATA 	
135
135
145
147
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                       I.  THE FERROALLOY INDUSTRY
A.  General
    A ferroalloy is "a crude alloy of iron with one or more other elements
(as metals) used for deoxidizing molten steels and making al,loy steels.    '
A list of the major ferroalloys and their manufacturing processes is shown
in Table 1-1.  Calcium carbide, although not a ferroalloy, is produced at
ferroalloy plants by a process similar to that for ferroalloys.  For purposes
of this report, "ferroalloys" will include calcium carbide unless otherwise
specified.
    The United States is the world's largest producer and user of ferroalloys.
In 1971, about 2,331,000 tons of ferroalloys valued at about 558 million
                                                               (2)
dollars were produced by the United States ferroalloy industry/    Another
400,000 tons of high-carbon ferromanganese were manufactured by the iron
and steel industry in blast furnaces.  An additional 380,000 tons of
ferroalloys were imported.  During the 10 years prior to 1972, the United
States' consumption of ferroalloys increased at an average annual rate of
                                                                       (3)
2 percent while average production increases were 1.5 percent per year.
Table 1-2 shows the companies, plant locations, plant sizes, products, furnace
types and number of furnaces for each domestic producer for the year 1971.
                                                         (4)
In 1971 the industry employment was about 10,100 persons.

    Section lll(b)(l) of  the Clean Air Act, as amended, requires that the
Environmental  Protection  Agency develop  standards of performance for
sources which  "cause or contribute to the endangerment of public health

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                          Table 1-1

     Major Ferroalloys and Their Manufacturing Processes
Submerged-are furnace process -
Exothermic process -
Electrolytic process -


Vacuum furnace process -

Induction furnace process
Silvery iron
50% Ferrosilicon
65-75% Ferrosilicon
Silicon metal
Calcium silicon
Silicomanganese zirconium (SMZ)
High-carbon (HC) ferromanganese
Silicomanganese
Ferromanganese silicon
Charge chrome and  HC  ferrochrome
Ferrochrome silicon
Calcium carbide

Low-carbon (LC) ferrochrome
LC ferromanganese
Medium-carbon ; (MC) ferromanganese
Chromium metal, FeTi, FeV and FeCb

Chromium metal
Manganese metal

LC ferrochrome

Ferrotitanium

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or welfare."  The major pollutant from ferroalloy plants is participate
matter, a pollutant for which ambient air quality standards were
promulgated in 40 CFR 50.  The health effects data necessary to issue
air quality criteria are based on non-specific particulate matter.  In
addition, particulate matter emissions result in the deleterious effects
of soiling, nuisance properties, reduction of visibility and modification
of atmospheric conditions.  Ferroalloy plants were specifically mentioned
in a Report of the Committee on Public Works, United States Senate,
as a source category to which standards of performance for new sources
could be expected to apply.^ '

     The rate of particulate matter emissions from the United States ferroalloy
industry in 1967 is estimated to have been 160,000 tons per year/6'
This total consists of 1,000 tons from blast furnaces, 150,000 tons from
electric submerged-arc (ESA) furnaces, and 9,000 tons from handling of
materials.  The estimate of 150,000 tons of emissions from ESA furnaces
assumes an average control efficiency of about 40 percent.   It has been
estimated that in 1^70 about 50 percent of the existing ESA furnace capacity
operating in the United States was equipped with particulate matter emission
control systems which had efficiencies ranging from 75 to 99 percent (including
capture and treatment of tap fumes).  '  Obviously the major source of
ferroalloy plant particulate matter emissions  is the ESA furnace.  It is
therefore the primary candidate for standards of performance for new sources.
    There are several  processes,  which are minor sources of emissions
compared to the ESA furnace,  for which standards are not now being

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recommended.  These processes, listed below, are candidates for standards
which may be developed in the future:
    .  The electrolytic process
    .  Vacuum and induction furnaces
    .  Product sizing
    .  Raw materials handling and preparation

    There are only six electrolytic process operations in the United States
ferroalloy industry.  These produce chromium, manganese, and manganese
dioxide.  The electrolytic process results in emissions of ammonia and
              (8)
sulfur oxides.v '

    Vacuum and induction furnaces are used to produce ferroalloys at fewer
than five locations in the United States.

    The final ferroalloy products are marketed in sizes ranging from
75-pound pieces to fine powders.   Several types of crushers and screens
are used for sizing the products.  Although the amount of particulate matter
emitted from crushing and screening operations has not been quantified,
it is substantially less than particulate matter emissions from ESA furnaces.
About half of the existing ferroalloy plants have air pollution abatement
                               (Q]
equipment for these operations.   '  No measurements of emissions from
ferroalloy crushing and sizing operations have been made by EPA.

    Raw materials such as ores,  quartz or quartzite, limestone, scrap
steel, coke, and coal  are delivered to ferroalloy plants by ship,

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railroad cars, or trucks and then are normally transferred to outdoor
storage piles.  These materials range 1n size from 5 Inches to 1/4 Inch,
but contain significant quantities of dust.  Entrainment of the dust by
wind may be minimized by sheltering the storage piles with block walls,
snow fences, or plastic covers, or by spraying with water.
    Additional dust may be generated during loading, unloading, transferring,
and pretreatment of this raw material.  Pretreatment may include operations
such as crushing, sizing, drying, mixing, pelletlzing, and sintering.
Standards of performance for these operations are not recommended at this
time but may be considered 1n the future.

B.  Processes or Facilities and Their Emissions
    1.  The electric submerged-arc furnace production process.
        A typical flow diagram of ferroalloy production is shown in
    Figure 1-1.  As discussed previously, the major source of pollution
    1s the electric submerged-arc furnace which performs the smelting
    operation.  The furnace (Figure 1-2) consists of a hearth lined
    with a high-temperature refractory which has holes to permit tapping
    (or draining) of metal and slag.  The furnace shell and its hood or
    cover components are fabricated from steel.  These are water cooled
    to protect them from the heat of the process*  Above the hearth are
    three carbon electrodes vertically suspended 1n a triangular formation.
    Although these electrodes may be prebaked or of the self-baking,
    1n situ Soderberg type, the trend 1s to use the Soderberg electrodes.

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     Electrodes  extend  three  to  five  feet into the charge materials.
 Three-phase  current  arcs  through  the charge  material  from electrode
 to  electrode.   The charge melts as the  electrical  energy is  converted
 to  heat.  Coke  added to the  furnace  chemically reacts  wiih the oxygen
 in  the metal oxides  to form  carbon monoxide  and reduce the ores to
 base metal.  Large quantities of  by-product  carbon  monoxide  are formed.
 These reaction  gases entrain particulate matter and carry them from
 the  furnace.

     Power is applied continuously to the ESA furnace.   Feed  materials
 may  be charged  continuously  or intermittently.   Molten ferroalloy  c id
 slag are intermittently tapped into  ladles from ports  in  the lower
 furnace wall.   (Furnaces  producing calcium carbide  may be intermittently
 or continuously tapped.)   From the ladles, the  melt is  poured  into
molds or casting machines.  After the product cools and solidifies,
 it is crushed, sized, loaded and  shipped  to  customers.
 2.  Emissions from ESA furnaces.
    A study of emissions  from the United  States  ferroalloy industry by
EPA and The Ferroalloys Association was completed in 1973.   During this
study, which began before promulgation of the Clean Air Act  Amendments
of 1970, EPA measured emissions from several  ferroalloy furnaces and
collected samples of emissions for chemical  analysis from open  furnaces
producing ferrochrome-silicon, silicomanganese, and high-carbon ferro-
chrome.   (Open,  semi-enclosed, and sealed furnaces are described in

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Chapter III of this document.) in addition, metals analyses were
performed on samples of manganese ore, chrome ore, and ferromanganese
slag used as charge material for a silicomanganese furnace.
    No significant concentrations of sulfur dioxide were found in
the exhaust gases from five furnaces tested by EPA.  S02 concentrations
ranged from 1 to 17 ppm and emissions did not exceed 7 pounds per
hour.
     (10)
    A significant amount of carbon monoxide gas is formed as a by-
product of the ESA reduction process.  Depending on the type of
furnace, this gas is either burned at the surface of the charge
material or captured by the emission control system.  If the latter,
it may be flared at the stack  of  the collection device or used for
fuel or other chemical processes.
     No nitrogen oxides are  formed during  the carbon reduction of
oxidic ores.
     Particulate matter emissions,  the major pollutant in this  industry,  may
 vary from 150 to 2,000 pounds per  hour from an uncontrolled ESA furnace.
 The actual rate depends on:^
     .  The type of alloy produced.
     .  Choice and size of raw materials.
     .  Operating techniques.
        Existence of a furnace shutdown or start-up condition.
  10

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     Chemical  analyses  of samples  of participate  emissions  revealed
 no  significant  amounts  of heavy metals  such  as mercury,  beryllium,
                     (12}
 cadmium,  or arsenic./   '   The  physical  properties  and  quantities
 of  particulate  matter  emitted  generally depend upon the  alloy beinq
 produced, but the particle size is  usually below 2 microns.  The
 mass median diameter (the  diameter  at which  50 percent of  the
 particles by weight are smaller and  50  percent are larger) of
 emissions from  open furnaces producing  ferrochrome silicon,
 silicomanganese, and high-carbon  ferrochrome has been measured by
 EPA as between  0.66 to 1.7 micron.'13^

    The type of alloy produced affects the quantity of uncontrolled
emissions.  Uncontrolled particulate matter emissions from open
furnaces tested by EPA (excluding tap fumes) varied from 25 to 144
pounds per megawatt-hour of power consumption for furnaces producing
ferrochrome silicon and silicon metal.  The uncontrolled particulate
matter emission rate will also vary for different grades of a given
product.   For instance, the rate of uncontrolled emissions will
increase with increasing silicon content of the product, so that
a furnace will emit more particulate matter when producing 75 percent
than when producing 50  percent ferrosilicon.
                                                                   11

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    The type and size of raw material also affects the emission rate.
A porous charge promotes uniform gas distribution and furnace operating
stability.  Very fine materials may promote channelization of gas flow
through the furnace charge, and bridging and nonuniform descent of charge
materials.  Collapse of a bridged area causes a momentary surge of gas
which results in unstable furnace operation.  Another factor which
influences furnace operation and emissions is the volatile content
of the charge material, including moisture and undesirable chemicals.
    The design of the furnace and its power consumption affect the
rate of uncontrolled emissions.  A covered or sealed furnace without
control is reported to  generate less emissions than an equivalent
open furnace without control/14'  Uncontrolled emissions from a
furnace producing a given alloy are  related to furnace production
which is  a function of  power consumption/   ''
     Differences  in operating techniques  can also  significantly affect
                                           /1g\
the  uncontrolled emissions  from a furnace/   '  Operation at  higher
voltages  requires the electrodes to  be positioned higher, resulting
in increased  emissions.   Poor  placement  of mix or insufficient feed
rate of the mix increases  emissions  through the  open,  annular areas
around  the  electrodes of a semi-enclosed furnace.  Manufacture of
silicon metal  requires  stoking of  the  charge to  break up  crust,
permitting  uniform evolution  of reaction gases,  and preventing
  12

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violent jets of gas emanating from the furnace reaction zone.
Emissions can vary depending upon the frequency and adequacy of
stoking.

    Furnace shutdowns may be caused by broken electrodes, water leaks,
tap hole problems, utility failures, and many other reasons.  Upon
start up after short shutdown periods, uncontrolled emissions return
to normal levels in a time period approximately equal to the length
of interruption.  When starting up a new furnace or one which has
been shut down for a long time period, heavier-than-norinal uncontrolled
emissions may occur for a period varying from a few days to several weeks.
    Emissions from existing ferroalloy furnaces are restricted by
State regulations.  These are all of the process weight type and most
are the result of State implementation plans developed pursuant to
section 110 of the Clean Air Act, as amended.  Since production rate is a
function of the product being manufactured,  allowable emissions must
be calculated for the particular alloy being produced.  For example,
allowable emissions from a 30-megawatt furnace located in Ohio producing
calcium carbide, silicomanganese, and ferromanganese are about 29, 32,
and 46 pounds per hour respectively (0.97 to T.5 pounds per megawatt-
hour furnace power consumption).   '  It is doubtful that these
regulations can be attained without control of tapping fumes.
Consequently, it would appear that with proper enforcement, the
State regulations will require installation of control systems which
will minimize emissions during the tapping operation.
                                                                      13

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                  II.  PROPOSED STANDARDS OF PERFORMANCE
A.  Standards of Performance as Proposed
    The proposed standards of performance for ferroalloy plants  limit
the discharge of particulate matter as  follows:
    No owner or operator shall  cause to be discharged  to the  atmosphere
    from any affected facility any qases'which:
    1.   Contain participate matter in excess  of  0.45 kg/Mw-hr
        (0.99 Ib/Mw-hr)  while that facility produces silicon
        metal,  ferrosilicon (50  percent silicon  and above),
        calcium silicon, or silicomanganese zirconium.
    2.   Contain particulate matter in excess  of  0.23 kg/Mw-hr
        (0.51 Ib/Mw-hr) while that facility produces high-carbon
        ferrochrome,  charge chrome,  standard  ferromanganese,
        silicomanganese, calcium carbide,  ferrochrome silicon,
        ferromanganese silicon, or silvery  iron.
    3.   Exhibit  20 percent  opacity or greater.  This opacity
        requirement shall apply to all gas streams from the
        affected facility except as  follows:
        (i)   Any emissions  which escape the furnace hood or cover shall not
             be  visually detectable without the aid of instruments.
        (ii)  Any emissions which escape the control device at the tapping
             station shall  not be visually  detectable without the aid of
             instruments for more than 40 percent of each tapping period.
                                     15

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              This  requirement applies  to  fumes which may  escape the device
              (required by the standard) used to  capture tapping fumes.
       (iii)   Any emissions from the dust  handling  equipment  shall  not
              exhibit 10 percent opacity or greater.
     The proposed standards limit the discharge of  carbon  monoxide  as
follows:
     No owner or operator shall discharge  or cause  the  discharge  into
     the atmosphere from any affected facility any  gases which contain
     20 or greater volume percent of carbon monoxide,  dry  basis.
     Combustion of carbon monoxide under conditions acceptable to  the
Administrator shall constitute compliance with this paragraph. Acceptable
conditions include but are not limited to flaring of gases or use of gases
as fuel for other processes such as plant boilers or raw material  dryers.

B.  Discussion of Proposed Mass Standards
     The proposed standards for particulate matter and visible emissions
can be  achieved with open, semi-enclosed and sealed furnaces with appro-
priate  hooding and air pollution control devices (i.e.  venturi scrubbers,
venturi scrubbers in series with electrostatic precipitators, or fabric
filters).  As pointed out  in  Chapter VIII, a standard was considered which
would encourage  the  use of sealed furnaces for those ferroalloy products
that can be  produced in sealed furnaces; however,  such a  standard has a
major disadvantage in  that it would restrict the flexibility  of new furnaces
to respond to fluctuating  market demands.  A specific sealed  furnace can be
 16

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 used  to  produce  only  one  family  of products.   The  sealed  furnace  cannot
 be  adapted  to  the  production  of  other  ferroalloys  without changing the
 electrode spacings  (which are determined by the  product family).  To
 do  this  on  a sealed furnace also  requires replacing the furnace cover.
 Thus, modification  of sealed  furnaces  to produce other products is pro-
 hibitively  expensive.  Product flexibility is  possible at minimum cost
 with  open furnaces  which have multiple transformer taps and adjustable
 electrodes.

      The industry has alleged that  a standard  requiring sealed furnaces
 (with their attendant limited product flexibility) would  severely handicap
 the small domestic  producers:  (1)  It would eliminate his ability to
 respond  to a rapidly  changing world market.  (2)   Only large companies
with  adequate  capital and marketing capabilities could commit a large
 furnace  to one product line.   (3)   Since a few large sealed furnaces
 could supply the entire United States market for select materials, a
 large company could install several and drive the  small producer  from
the market, thereby eliminating domestic competition.

     EPA attempted to determine the need for furnace flexibility.   Data
were obtained on various products made in each furnace over a 5 to 10-year
period from several United States ferroalloy producers, both large and
small.  Some furnaces were reported to have been changed from one product
 to another quite frequently while other furnaces produced the same product
 for the entire period reported.  This was true of both large and small
companies.  Market conditions can fluctuate rapidly in the ferroalloy

                                                                         17

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industry, however, so it is understandable why product flexibility
is advantageous.  For these reasons, we are proposing a standard
which will allow open furnaces to be used in conjunction with the
best available control equipment for open furnaces.   The standard is
also readily achievable by using sealed furnaces with adequate con-
trol equipment.
     EPA's Control Systems Laboratory has contracted for a long-term
study to further investigate the issue of product flexibility.  That
study could ultimately result in standards of performance based on
sealed furnaces.
C.  Discussion of Proposed Opacity Standard
     The visible emission regulations on emissions from the furnace hood
or cover and the tapping station were established to make enforcement
simpler.  The revised regulations no longer require discerning opacities
in order to determine compliance.  The proposed standard specifies no
visually detectable emissions without the aid of instruments.  This pro-
posal does not require a distinction to be made between different opacity
levels because the observations are made inside the shop and the criteria
of Reference Method 9 for determining the opacity of emissions cannot be
followed.  The distinction between no visible emissions and the existence
of visible emissions can be made however.  The emission from the furnace
hood or  cover and the tapping station are a significant portion of the
 18

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 furnace's  total  emissions.  The no visible emissions limitation is
 intended to  require  very good  capture of these emissions.

      In  the  case of  hoods or covers used to capture fumes generated
 within the furnaces, the standard requires that fumes which escape capture
 by  the furnace hood  or cover be invisible at all times.  This require-
 ment  is  supported by observations at four open furnaces and several
 sealed furnaces.  (See Chapter VI.)

      The visible emission limitation on fumes from the tapping station
 is  based on  observations of one tap hood during two tapping periods.
 These data are summarized in Chapter VI.  During these two tapping periods,
 no  visible emissions were observed escaping the hood for 71.4 percent of
 the time during  the first tapping period, and 73 percent of the time
 during the second tapping period.   The remainder of the time, emissions
 of  various opacities escaped capture by the hood.   The proposed standard
was established  to require no visible emissions for at least 60 percent
 of the time because the best system observed had some fumes escaping the
 collector system at the tapping station, and to allow a margin of safety
 between the data base (71.4 to 73 percent of the tapping with no visible
 emissions)  and the proposed standard,   the proposed standard still  requires
 very good collection and control  of tapping fumes.

     The proposed standard limits  the opacity of fugitive emissions from
the dust handling system at or near the  control  device to less than 10
percent to  be consistent with  the  observed  levels of 0 percent opacity
                                                                        19

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and allow a small margin of safety.   Thi-s proposed limitation is  based
on observations of dust handling equipment in the steel  and asphalt
concrete industries.
 20

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                     III.   EMISSION  CONTROL TECHNOLOGY
     Air  pollution  from the electric submerged-arc  furnace  is minimized
 by  good  capture of fumes at the furnace and use of an appropriate
 particulate matter collection device.  The three different furnace
 configurations—open, semi-enclosed, and sealed—strongly  affect the
 efficiency of air  pollution control.  In each type, the hood or cover
 above the furnace  not only collects emissions but  also protects the
 furnace  superstructure and electrode column components.  The three types
 of  furnaces and common control devices are discussed below.  Emissions
 from controlled furnaces of each of three types are discussed and compared
 in  Chapter VI, Data to Substantiate a Standard.
 A.   Open Furnace
     The  open furnace (Figure III-l) has a water-cooled canopy hood, normally
 located 6 to 8 feet above the furnace crucible rim.  This  large opening
 between the furnace crucible and hood permits large quantities of ambient
 air  to be drawn into the air pollution control system diluting the furnace
 off-gas by as much as 50 to I/18'  As the air combines with the hot
 furnace gases, it combusts the carbon monoxide generated in the furnace.
Gas volumes from this type of system range from 100,000 to 400,000 standard
cubic feet per minute (scfm).^  '   Gas volume can  be  reduced by decreasing
the opening between the furnace  and hood.   This  may be done by adding a
skirt to the  hood or with chain  curtains  (lengths  of  chain hung in close
proximity around the perimeter of  the hood).
                                    21

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    Gas cleaning devices used on open ferroalloy furnaces Include high-
energy venturi scrubbers, electrostatic precipitators, and fabric filters.
    1.   Venturi  scrubbers applied to open furnaces.
        Several  designs of venturi  scrubbers are used in the United
    States,  but  the one most common on open furnaces is the flooded-disc
    type.   Because the particulate  matter concentration is relatively
    low (the result of copious  dilution  air) and a high proportion  of
    the particulate is submicron, these  scrubbers must operate  with very
    high pressure  losses  of 60  to 80  inches  water gauge to achieve  removal
    efficiencies of 96 to  99 percent.  The  venturi scrubber for an  open
    30-megawatt furnace producing silicomanganese requires  2,500  horsepower
    for the  fan alone.  The  power required to operate  these  high-energy
    scrubbers  is equivalent  to approximately 10  percent  of  the  power
    requirements for the furnace itself.^20^' ^21^

   2-   Electrostatic  precipitators applied  to open furnaces.
       Only two modern electrostatic precipitators are operating on
   ferroalloy furnaces in the United States.  Both are installed on
   open furnaces producing chrome alloys.

       Most fumes  from ferroalloy furnaces do not have proper electrical
   resistivity for satisfactory precipitator operation unless the gases
   are  humidified  and conditioned with agents  such as ammonia,  or their
   temperatures  are maintained  above 500°F.
                                                                     23

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   3.   Fabric filters  applied to open  furnaces.
       Fabric filter collectors, also  referred to as  baghouses or bag
   filters, are frequently used with open furnaces.   The most common
   type used in the United States is pressurized (fan on the inlet)
   and exhausts through an open top or monitor.  Open grates at the
   bottom of the baghouse permit cooling by natural  convection.  Radiant
   coolers or dilution with  cool, ambient air is used if the gas must
   be cooled before it enters the baghouse.  Cooling with water sprays
   is much less common.   Both felted  and woven fabrics  of many different
   materials have  been used.  Cleaning of the  bags may  be done by  either
   reverse air or  mechanical  shaking.  Air-to-cloth  ratios  vary between
   1.2  and 2 actual  cubic feet  per  minute  (acfm)  per square foot  of cloth
   area.   Because  the particulate matter has  both a  high proportion of
   submicron particles and high electrostatic charge, the pressure drop
    across a filter fabric is relatively high, 10 to  18 inches of water.

B.  The Semi-Enclosed Furnace
    The semi-enclosed furnace (Figure III-2) has a water-cooled cover which
contains gas and fume generated in the furnace.  These emissions are drawn
from beneath the cover through  one or more ducts to a gas cleaning device.
The cover  completely  seals the  furnace except  for annular spaces around
the three  electrodes  through which  raw material is charged.  The feed
material  only partially  closes  the  annuli and  emissions  still pass through
them.   These leaks could be  eliminated or minimized  in  two  ways.   The  air

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pollution control  system could be designed to maintain a negative pressure
within the furnace or the emissions could be captured and controlled by
hoods around the electrodes.
    Because very little air enters a semi-enclosed furnace, the gases from
the furnace are rich in carbon monoxide and can be used as fuel.
                                               l
    Semi-enclosed furnaces have not been used to produce silicon metal
or alloys containing over 75 percent silicon because of inability to stoke
the furnace.  Stoking is necessary to prevent crusting and bridging of
the charge, and "blows" during production of high-silicon alloys.
Crusting and bridging prevent uniform descent of the charge into the
furnace and blows may damage the furnace components.  "Blows" are jets
of extremely hot gas that originate in the high-temperature reaction
zone in the vicinity of the electrode tips, and emerge around the
electrodes at high velocity.
    1.  Wet scrubbers applied to semi-enclosed furnaces.
        Wet scrubbers are the most common air pollution control devices
    applied to semi-enclosed ferroalloy furnaces.  Both multistage
    centrifugal scrubbers and venturi scrubbers are used.  Centrifugal
    scrubbers are generally limited to a maximum air flow of about
                                                                    (22)
    2,800 acfm, sufficient for a medium-size semi-enclosed furnace.
    For larger furnaces, parallel centrifugal scrubbers or a venturi
    scrubber are used.  Depending on the product being made, centrifugal
    scrubbers may have efficiencies of up to 99 percent; venturi scrubber
 26

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 efficiencies are higher.   Pressure losses  of up to 80 Inches  of water
 are common 1n venturi  scrubbers  controlling  emissions from semi-
 enclosed furnaces.   Power  and  water requirements are generally
 higher  for Venturis  than for centrifugal scrubbers.

     Emissions from two  semi-enclosed  furnaces were measured by EPA.
 One was a  40 to  50 megawatt furnace which  produces 50 percent
 ferrosilicon and  is  controlled by  a venturi  scrubber.  The other is
 a  24 megawatt calcium carbide furnace controlled by  a  centrifugal
 scrubber.   During these tests, large amounts of  dust were  emitted
 from the annular openings at the electrodes.  These  emissions  were
 not  controlled and so reduced the  overall  control  efficiency.   Emissions
 from the scrubber on the furnace producing ferrosilicon averaged 0.078
 pound per Mw-hr  (3.6 pounds per hour); however, measurements of fugitive
 emissions from around the electrodes indicated a total emission rate of
 about 390 pounds per hour.  Emissions from the calcium carbide furnace
 scrubber averaged 0.017 pound per Mw-hr (0.40 pound per hour); however,
measurements of fugitive and tap emissions which were uncontrolled
 indicated a total emission rate of about 4.0 pounds per Mw-hr  (96
 pounds per hour) for this furnace.   Obviously, the emissions from the
electrode ports are of major concern in a semi-enclosed furnace.

 2.  Electrostatic precipitators and fabric  filters applied to
    semi-enclosed furnaces.
    No known semi-enclosed  furnaces are serviced by electrostatic
precipitators or fabric filters.   Fabric filters, and an  electrostatic
                                                                    27

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    precipitator in series  with  venturi  scrubbers  have been  used  on  sealed
    furnaces  in Japan.   The similarity in emissions from semi-enclosed
    and sealed furnaces seems to imply that these  control  devices could
    also be used on semi-enclosed furnaces.  However,  the semi-enclosed
    furnace has a less  positive  seal.   Air leaks through, the annuli  at
    the electrodes may  increase  the danger of explosion.  This  could
    prevent use of fabric filters or electrostatic precipitators.


C.  The Sealed Furnace
    The tops of sealed furnaces  (Figure III-3) have water-cooled covers
which prevent escape of any emissions from treatment by the air pollution
control system.  Packing is used to seal around the electrodes and
charging chutes.  No other openings are required since  the furnaces are
not generally stoked.  They are operated with a slight  positive pressure
to prevent leakage of  air into the furnace.  The furnace exhaust gas,
predominantly carbon monoxide, can be used as fuel.
    Because no  air enters the furnace,  gas volumes  to  the control device
are minimal and can be as  little as 2 to  5 percent  of that  from  an  open
furnace of equivalent  size.  The very low gas volumes  result in  much  lower
mass  of particulate matter emissions  from a  controlled sealed  furnace than
from  an equivalent, well-controlled open  furnace.
 28

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    Sealed furnaces have not yet been used to produce silicon metal or alloys
containing over 75 percent silicon because of inability to stoke the furnace.
Stoking is necessary to prevent crusting and bridging of the charge, and
"blows" during production of high-silicon alloys.

    1.   Wet scrubbers applied to sealed furnaces.
                                    r
        Wet scrubbers are the most common device used to control  air
    pollution from sealed furnaces.   Both multistage centrifugal  and
    venturi scrubbers are used.   Their efficiency and energy requirements
    for control  of sealed furnaces are similar to  those for semi-enclosed
    furnaces.

    2.   Fabric filters applied to sealed furnaces.
        Only one sealed ferroalloy furnace is  known  to use a  fabric
    filter for air pollution  control.   The baghouse  is a  closed  suction
    type cleaned by reverse gas  flow.   Air-to-cloth  ratio  is  about  1.5
    actual  cubic feet per minute per square foot of  cloth  area.  Gas from
    the  furnace  is cooled in  radiant coolers before  entering  the baghouse.
    When necessary,  additional cooling  is  obtained by running water over the
    surface  of the radiant coolers.

    3.   Electrostatic  precipitators applied to sealed  furnaces.
        No applications are known  in which electrostatic precipitators
    alone are  used with sealed ferroalloy furnaces.  However, systems
    consisting of  two venturi scrubbers and a wet electrostatic
30

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    predpltator, all  in series,  have been used to control  emissions from
    three sealed ferroalloy furnaces in Japan.  The venturi scrubbers
    serve as precleaners and gas  conditioners and operate at relatively
    low pressure drops (about 36  inches of water total).  The precipitator
    removes about 97 percent (according to EPA tests) of the particulate
    remaining in the gas stream after the scrubbers.

D.  Control of Fumes During Tapping
    Best systems of emission reduction for ferroalloy furnaces of all
types includes capture and control of tapping fumes.  A hood system
must be used over the tap hole and ladle to capture and direct tapping
fume to a gas cleaning device. The gas cleaning device may be common
to that controlling the furnace fume, or a separate fabric filter or
wet scrubber.
    Efficient capture of tapping  fumes has been difficult.  One new hood
design encloses the ladle during  tapping and can be retracted when tapping
is complete.  When in place, it provides access to the tap hole.  This
allows the hood to be in place to capture fume generated when the tap
hole is burned open with an oxygen lance, and also allows the tap hole
to be rodded during the tap to keep it open.  This system provides very
good capture of the tapping emissions.
                                                                       31

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                     IV.  ENVIRONMENTAL EFFECTS

A.  Impact on Air Pollution
     The objective of standards of performance under section 111 of the
Act, as amended, is to prevent new air pollution problems from developing
by requiring affected facilities to use the best systems of emission
reduction available at a cost and within a time that is reasonable.
These standards pertain directly to emissions from the facility and
are only indirectly related to ambient air quality.  Attainment and
maintenance of national ambient air quality standards is specifically
covered by State implementation plans as provided under section 110 of
the Act.  Nevertheless, the impact of a new submerged arc ferroalloy
furnace on local ambient air quality should be closely investigated.
Such an investigation necessarily depends upon many specific factors
such as topography, meteorological conditions, proximity of other sources
of pollution and the mass of pollutants emitted from all sources in the
local area.  As an illustrative example* maximum ground-level concentrations
of particulate matter were estimated for emissions from five hypothetical
sources employing the control systems of interest using an atmospheric
dispersion model.  These estimates are shown in Table IV-1 for these
hypothetical point sources - control - system cases.  Differing source confi-
gurations and surrounding terrain can cause significantly different results.
The maximum concentrations were estimated for 24-hour and 1-year averaging
periods  for particulate matter.  These averaging periods were selected
to  permit direct comparison with the ambient air quality standard for
                                  33

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particulate matter.  Comparison of these maximum ground-level concentration
estimates with the national ambient air quality standard will not
necessarily indicate whether or not the standard (NAAqs) will be met
unless there is an estimate of background concentration arising from
natural  and manmade sources available for the specific site.  Cases 1 and
3 are based on emissions from a furnace operating in compliance with a
typical State process weight regulation.  Cases 2 and 4 are based on
allowable emissions according to the proposed standards of performance
(Chapter II) and Case 5 is based on emissions of 0.07 Kg/Mw-hr, Alternative
flo.  1,  Chapter VIII (Alternative Standards).
     The dispersion estimates were made using a Gaussian point source
dispersion model developed by Meteorology Laboratory of EPA.
     Because the pollutants emit from a monitor  (no stack) on a baghouse in
Cases  1 through 4, aerodynamic downwash is a chronic problem, particularly
when wind speeds exceed 2  or 3 meters per second (mps).  At  very low wind
speeds  the plume may rise, although probably not more than 20 meters.
     Many of the nation's ferroalloy plants are  in valleys in hilly  country
such as West Virginia and  eastern Ohio.  Since  it was readily available,
and  the topography and  climate are similar to West Virginia  and eastern
Ohio,  one year of  hourly wind  and surface stability  data for Harrisburg,
Pennsylvania was used for  the  calculations.
                                                                        35

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    Maximum concentrations were estimated immediately downwind of the
source, and for distances of 0.3, 2, and 20 kilometers downwind.  Because
of downwash, the overall maximum concentrations were likely to occur just
to the lee of the emission point.  The 24-hour values are estimates of
typical high concentrations during any given year.  Note that the 24-hour
primary national ambient air quality standard (NAAQS) for particulates
(260 yg/n? ) may be exceeded at distances of 0.2 to 1.0 kilometers
downwind, depending on the source.  The annual NAAQS (75 yg/m3) may also
be exceeded, although not as far downwind and perhaps not at all when
a sealed furnace is used (Case 5).

    As an indication of the degree of air pollution reduction achieved
by control systems on submerged arc ferroalloy furnaces, the emission
rates in Table IV-1 for controlled furnaces can be compared with estimated
uncontrolled emission rates of 270 grams per second (39 Kg/Mw-hr) for an
open, 25 Mw silicon furnace, and 190 grams per second (23 Kg/Mw-hr) for
an open, 30 Mw silicomanganese furnace.

    Installation of systems to provide the best air pollution control
technology on all new plants will minimize the increase in emissions from
growth of the ferroalloy industry.  By promulgating standards of
performance, there will be no incentive for a plant to locate in a State
which has less stringent standards.  Without uniform standards of performance
 36

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such an indirect inducement by State and local agencies could create
concentrations of industry and result in significant deterioration of
local air quality.

B.  Impact on Water Pol TutIon
    The control of air pollution from a ferroalloy plant need not affect
water pollution problems at all since fabric filter air pollution control
systems require no water.  Scrubbers and electrostatic precipitators with
wet gas conditioners are potential major sources of water pollution.
Although up to 3,500 gallons of water per Mw-hr may be circulated through
a scrubber serving an open furnace, normally the water is clarified and
recirculated.  As a result, the volume of actual waste water is much less
and is only that required to carry the sediment from the clarifier.  Because
of the much larger volumes of exhaust gas from open furnaces, scrubbers
serving them have much larger water requirements than those for semi-
enclosed or sealed furnaces.  This, of course, necessitates a larger water
treatment system for scrubber-equipped open furnaces.

    The Environmental Protection Agency promulgated water effluent limitations
for the ferroalloy industry on February 22, 1974, (39 FR 6806).'23'  For
new electric ferroalloy furnaces, the standard limits discharges of water
pollutants to levels attained by the "best available technology economically
achievable."  Typically, chemical treatment, clarifier-flocculators, sand
filters, and recirculation would be required to meet the water effluent
standards for electric ferroalloy furnaces if scrubbers are used.
                                                                          37

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C.  Impact on Solid Waste Pollution
    Increased recovery of participate matter normally emitted to the atmosphere
with the exhaust gases from a furnace can only increase the amount of solid
waste for disposal.  This increased quantity of solid waste is a function
of the efficiency, not the type of the control device.  Selection of the
type of device will determine if particulate is collected as a wet or dry
mass.  Although the dry product from a fabric filter may be more prone to
re-entrainment than the sludge from a clarifier, it can easily be wetted
or pelletized to minimize wind losses during handling.
    The domestic industry usually disposes of the collected material as
landfill.  When this method is used practices similar to proper sanitary
landfill technology may be followed.  The principles set forth in EPA's
Land Disposal of Solid Wastes Guidelines (CFR Title 40 of Chapter 1,
Part 241) may be used as guidance for acceptable land disposal techniques.
If hazardous materials are to be disposed of, landfill sites should be
selected to prevent horizontal or vertical migration of this contaminant
to surface or ground waters.  Where geologic conditions may not reasonably
ensure this, adequate precautions such as impervious liners should be
taken to ensure long term protection to the environment.  The location of
solid hazardous materials disposed of in this manner should be permanently
recorded in the appropriate office of the legal jurisdiction in which the
site is located.
 38

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    Although most of the dust captured is hauled to a landfill site, other
dispositions are possible.  In some foreign ferroalloy plants, the dust
captured by the control system is palletized or sintered and returned to
the furnace as feed.  Some of the dust captured by baghouses serving an
open 75 percent ferrosilicon furnace is sold for manufacture of fireproof
building materials.
D.  Energy Considerations
    Because gas volumes from open furnaces are large, power requirements
for the air pollution control system are generally high.  A typical open
furnace control system has a fan of 1,400 to 4,500 horsepower.
                                                              (24)
                                               A venturi
scrubber on an open furnace uses approximately 10 percent of the total
power supplied to a furnace.  Fabric filters or electrostatic precipitators
generally require less power since they operate with lower pressure losses.
One type of venturi scrubber (by Aeronetics)—  is being used on a small,
open sil'icomanganese furnace.  It utilizes heat from the furnace exhaust
gas and nevo- comparatively little external power, only about 10 percent
of that nee •'d by a conventional venturi type.

    Semi-enclosed and sealed furnaces have much lower gas emission rates
than open fun.aces.  Hence, the power requirements for their control
systems are usually much lower than those for open furnaces.  For example,
a control system on a closed furnace would typically need a fan of 100 to
400 horsepower.
               (25)
It is obvious that not only do control systems on
I/
  References to commercial products are not to be considered in any
sense an endorsement of the product by the Government.
                                                                        39

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closed furnaces require only about 10 percent of the power of those on
open furnaces, but the power plant emissions to provide that power are
also commensurately less.
    The exhaust gases from sealed and semi-enclosed furnaces are rich in
carbon monoxide and have significant value.  Twenty to 35 percent of the
power fed to the furnace can be recovered from the heat of combustion of
the gases/  ' which have been used for chemical synthesis and as fuel
for dryers, plant boilers, and other process equipment.
    Collection and control of tapping fumes are the only areas in which
a standard of performance may increase power consumption over present
practice, and even this increase is slight.  Efficient collection of tap
fumes will require 20,000 to 60,000 cfm.  If separate collectors or fans
are used, they need operate only during tapping and can be shut off at
other times to save power.  Although relatively few furnaces now have
control systems for tap fumes, in many cases these will be necessary to
meet requirements of State implementation plans.

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          V.  SUMMARY OF THE PROCEDURE FOR DEVELOPING STANDARDS

A.  Literature Review and Industrial  Contacts
    Information Initially available for use in the development of standards
of performance for new stationary sources in the ferroalloy industry resulted
from a joint study by EPA and The Ferroalloys Association (TFA).  The study
had been in progress for over 2 years prior to the initiation of a program
to develop standards.  The joint study was primarily concerned with emissions
and control techniques of the United States ferroalloy industry.  It utilized
a survey of the industry (performed with questionnaires), a literature search,
and measurements of emissions from several electric submerged-arc (ESA)
furnaces.  The study provided information on the history and trends of
the ferroalloy industry, industry statistics, processes and emissions,
emission control technology and procedures, and economics.
                                                          (27)
    After passage of the Clean Air Act Amendments of 1970, the program
for development of the standard was begun.  Results of the joint study by
The Environmental Protection Agency and The Ferroalloys Association (EPA-
TFA study) were reviewed, additional recent literature was obtained, and
several State agencies and manufacturers of furnaces and control equipment
were consulted.  Meetings were held with .the United States and Japanese
ferroalloy trade associations, and producers of ferroalloys in the United
States, Norway, Belgium, Canada, and Japan to obtain additional information
useful in the development of standards.
                                     41

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B.  Selection of Pollutants and Affected Facilities
    Sulfur oxide emissions from ESA furnaces were investigated as part
of the EPA-TFA study.  Emissions were very low.   The concentrations were
less than 20 parts per million and the rate did not exceed 7 pounds per
hour.
     (28)
There are no nitrogen oxide emissions since NOV is not produced
                                              A
by the carbon reduction process.  Emissions from semi-enclosed and sealed
furnaces may contain 60 to 90 volume percent carbon monoxide (CO)/  '' ^  '
    The rate of particulate matter emissions from the United States ferroalloy
industry in 1968 is estimated to have been 160,000 tons per year of which
1,000 tons were from blast furnaces, 150,000 tons from ESA furnaces, and
                                      (31)
9,000 tons from handling of materials.   '
    Analyses of particulate matter emissions revealed no significant amount of
                                                              (32)
heavy metals such as mercury, beryllium, cadmium, and arsenic/  '  As
might be suspected, significant quantities of manganese are emitted when
manganese ores are used.  There is evidence that the manganese in particulate
matter emissions resulting from production of ferromanganese and silicomanganese
may be hamful to human health.'33'' <34'• <35>' <36>' (37>
    Particulate control technology for electric submerged-arc furnaces
(ESA), the largest source of particulate matter in ferroalloy plants, is well
demonstrated.  Other sources of air pollution in the ferroalloy industry
are minor compared to ESA furnaces.  Therefore, ESA ferroalloy furnaces
were selected as the affected facility for development of the initial
standards of performance for new stationary sources in the ferroalloy
industry.
42

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    Only standards for emissions of participate matter and carbon monoxide
are being proposed at this time.  Equipment now being used to control
emissions from ESA furnaces is designed for particulate matter only; control of
any other pollutants is incidental.  Emissions of pollutants from ESA
furnaces other than particulate matter and carbon monoxide are minor.  A
limitation on particulate matter emissions will also minimize the emission of
materials such as manganese because they are emitted as particulate matter.

    Large quantities  of carbon monoxide generated within  open furnaces are
significantly reduced by combustion with air drawn into the furnace.  Carbon
monoxide from closed furnaces is usually flared at the stack outlet unless
it is used for fuel or other processes.  Since there is no way to measure
the concentration of carbon monoxide downstream from the  flare, a numerical
standard can neither be defined nor enforced; however, a  standard can assure
that the carbon monoxide is always burned before release  to the atmosphere.
    Standards of performance may be developed in the future for other
pollutants and other sources of pollutants in the ferroalloy industry.
Possibilities are product crushing and sizing, raw material preparation,
open-arc ferroalloy furnaces,  casting machines, and the various exothermic
reactions.

    The ferroalloy industry produces a large number of products,  but over
90 percent of the total  United States ESA furnace ferroalloy production
consists of alloys of chromium, manganese, and silicon.(38)»(39'   Although
emission rates from uncontrolled furnaces can vary greatly among  products,
similar alloys often  have similar levels of controlled emissions  from a

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given type of furnace.  For this reason, standards of performance for
new ESA furnaces may be categorized on the basis of product groups.
Each group consists of products having similar emissions (with air
pollution control) and control techniques.  Alternative schemes for
grouping alloys and possible standards are presented and discussed
in Chapter VIII of this report.
C.  Plant Inspections
    EPA engineers visited eight American ferroalloy plants to become
familiar with the industry and to locate those domestic ferroalloy furnaces
which appear to achieve the best air pollution control.  Emissions from
seven of these furnaces at six plants were measured as part of the EPA-
TFA study of the ferroalloy industry.  In addition, measurements were
made on one uncontrolled ESA furnace producing ferrochrome silicon.
    Literature reviews and discussions with both members of industry
and manufacturers of •furnaces revealed that, although there is only
one sealed ferroalloy furnace in the United States, such furnaces are
commonly used in foreign countries.  Since the air volumes from a
sealed furnace average 1/50 (and may be as little as 1/200) those from
an equivalent open furnace, controlled mass emissions from closed furnaces
average only 2 percent (and may be as little as 0.5 percent) of those
from open furnaces of equivalent production rate.
    Because of this obvious superiority for air pollution control inherent
in the design of sealed furnaces, several were surveyed in Japan, Norway,

-------
 Belgium,  and  Canada.   Process,  operating,  and  emission  data were  obtained.
 Emissions were  measured  from two  sealed  furnaces  in  Norway and  three  in
 Japan.  Emissions  were also  measured  from  two  well-controlled open  furnaces
 in  Japan.   They were  well  hooded  and  used  suction-type  fabric filter  collectors
 which  had stacks that provide good  conditions  for sampling.  In contrast,
 most open furnaces in the  United  States  use pressure-type baghouses with
 roof monitors rather  than  stacks.   These complicate  emission measurements.

 D-  Sampling  and Analytical  Techniques
     EPA Method 5 was used to obtain most of the data on which the ferroalloy
standards are based.  Certain modifications to Method 5 sampling apparatus
and the sampling method were necessary at some of the facilities tested.
These changes are discussed case by case in a separate document, Background
Information for Standards of Performance^:  Electric Submerged-Arc Furnaces
for the Production of Ferroalloys - Volume 2, Test
Data Summary.   One such modification occurred when testing sealed and semi-
enclosed furnaces.   The electric heaters for the sampling probe and filter
were turned off because they could ignite the carbon monoxide-rich exhaust
gases if an air leak occurred.  For this reason, probe and filter heaters
are not required by the performance test when testing gas streams  which
contain over 10 volume percent carbon monoxide.

     The proposed particulate matter standard of performance for new ferroalloy
furnaces limits  the mass  emission rate rather than the concentration.   Thus,
the flow rate must also be measured in order to calculate the mass emission

-------
rate.  EPA Method 2 is used to measure gas flow.  It too is specific
in the procedures to be used and can be carried out simultaneously with
Method 5 with little additional effort.  Included in Method 2 is a procedure
for analyzing the stack gas (EPA Method 3 - Orsat Analysis) which will
determine compliance with the provisions of the proposed standard for carbon
monoxide, since an Orsat Analysis includes measurement of carbon monoxide.

E.  Emission Measurement P ro gram
    EPA has performed emission measurements on a total of 14 controlled
ferroalloy furnaces.  Seven were open, two semi-enclosed, and five were
sealed.  Tests were usually conducted for a time approximately equal to
that of a full furnace cycle (or multiple cycles if they were required
to obtain a sample large enough to weigh accurately).  One complete
tap was included (with one exception) within each sampling period so
that samples were representative of all phases of furnace operation.
During tests, the control system and furnace operation were monitored
to detect process upsets or abnormal operation which might affect the
test results.  Three or more individual test runs were generally made
for each furnace.  No measurements from control systems on tapping
operations were performed, because none were located which had adequate
fume capture efficiency and which had discharges which could be accurately
measured.
    Particulate matter samples were obtained for all furnaces tested.  In
addition, chemical, particle size, gas, x-ray diffraction, and atomic absorption
              »
analyses were performed in conjunction with many of the tests, and some
of the samples were examined optically.
16

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F.  Units of the Standard
    Several systems of units were considered for the proposed standard
for particulate matter.  The units of kilograms per megawatt-hour were
selected for the following reasons:
   1.  Concentration units (grams per standard cubic meter)  permit
   designers of new furnaces to neglect consideration of the volumes
   of gases exhausted.  Disparities in gas volume from existing
   furnaces have resulted in variations in mass emissions by a factor
   of 50 even though the two types of furnaces may have the  same exhaust
   particulate concentration.

   2.  These units of Kg/Mw-hr do not require direct measurement of the
   charge to the furnace or production rates during the test period.   In the
   ferroalloy industry, these quantities can rarely be accurately determined.
   3.  The average power consumed (Mw-hr)  by the furnace is  readily
   obtained from instruments already installed on furnaces.
   4.  The power consumption of a furnace  is a function of its production
   and is related to emission rate.  Consequently,  these units are similar
   to those for standards based on production or raw material  feed rates.
   5.  An open furnace with fabric filter  collection may achieve lower
   exhaust particulate concentration than  a  sealed  furnace which uses
   a scrubber, even though the total  weight  of emissions from  the
                                                                        47

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     sealed furnace 1s only 2 percent of those from the open furnace.
     Under these circumstances, a concentration standard would be more
     easily met by the open furnace and use of the open furnace would
     be encouraged even though Its mass emissions are higher.
G.  Development of Proposed Standards
     On February 20, 1973, the Agency presented a draft technical report
and standard for the ferroalloy industry to the National Air Pollution
Control Techniques Advisory Committee (NAPCTAC).  In summary the report
concluded that best demonstrated technology for control of fumes from
electric submerged arc furnaces producing ferromanganese,
silicomanganese, and calcium carbide is the sealed furnace in conjunction
with appropriate control equipment.  The draft standard did not cover any
other ferroalloy products.  The particulate matter limitation in the draft
standard was 0.15 Ib/MW-hr and 10 percent opacity; the carbon monoxide
limitation was 20 volume percent on a dry basis.  The ferroalloy industry
was represented at the meeting and the representatives expressed their
comments to the committee members and suggested that the standard be 1.0
Ib/MW-hr and 20 percent opacity.  The industry representatives stated
that a standard of 0.15 Ib/MW-hr would preclude the use of furnaces other
than sealed and not allow the use of open furnace configurations.  They
felt the Agency's cost estimates for controlling sealed furnaces were low
and sealed furnaces presented safety hazards.

-------
     The  draft  technical report and standard for the ferroalloy industry
were presented  again to NAPCTAC on May 30., 1973.  At this meeting the
Agency presented additional cost information on open and sealed
furnace configurations and the safety hazards of sealed furnaces.
Ferroalloy industry representatives again expressed their objections
to the draft standard because sealed furnaces in their opinion create
safety hazards  and limit the flexibility of industry to produce a broad
range of  ferroalloy products.  They stated that the domestic industry
must use  open furnaces to maintain competitiveness and flexibility of
furnace products.

     The  ferroalloy industry was again discussed at the NAPCTAC meeting
on January 10,  1974.  The Agency representatives emphasized the advantages
(from an  air pollution and energy standpoint) of sealed furnaces over open
furnaces.  No standard was recommended or discussed and the Committee was
informed  that if time permitted the standards to be proposed for the ferro-
alloy industry would cover the entire industry and Agency representatives
had met with the industry representatives several  times since the May 30th
meeting to discuss the industry's position with respect to open versus
sealed furnaces.  The industry representatives again reaffirmed their
concern to the Committee for any standard that would force the use of
sealed furnaces and not allow open furnaces.
     During October 1973., Agency personnel conducted an extensive testing
program on several  ferroalloy furnaces in Japan.  During the latter part
of 1973 and the early part of 1974, Agency personnel visited additional
domestic furnaces and consulted with industry representatives to
                                                                       49

-------
resolve the issue of product flexibility .and the need for a standard
which would allow open furnaces.  The information obtained by the Agency
during this period of time allowed the proposed standard to cover the
entire product line of the ferroalloy industry and indicated that there
is a need to allow the use of open furnaces.  The rationale for the
Agency's conclusion that the proposed standard should allow open furnaces
is discussed in Chapter II.
  50

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                   VI.  DATA TO SUBSTANTIATE A STANDARD

 A-  Concentration and Mass Data
     Results of emission measurements conducted by EPA and other data
 on emissions from controlled ferroalloy furnaces are shown in Figures
 VI-1  through VI-6.   Brief descriptions of each facility for which emission
 data  were obtained  and tables summarizing the data are in a separate
 document, Background Information  for Standards of Performance:   Electric
 Submerged-Arc Furnaces for the Production of Ferroalloys
 Volume  2, Test Data  Summary.

    Figures  VI-1  and VI-2  show results of measurements of particulate matter
 emissions from sealed ferroalloy  furnaces.   Data for Furnaces Al,  A2,
 B,  S, R,  and K were  obtained  by EPA  on tests  conducted in Norway and
 Japan.  Furnaces  Al  and A2  are  the same.   During runs  designated Al,
 only one  venturi  scrubber was  operated, whereas  during runs  designated
 A2, a second one  was  put in service, providing two separate  but  identical
 venturi scrubbers operated  in parallel.   Data  for Furnaces D, E,  F,  I,
 J,  and H  are results  of tests conducted by Japanese  companies using  the
 Japan Industrial   Standard test method.^41^  This method specifies use
 of  a filter with  at least 99 percent collection  efficiency.  The test
 method used to obtain emission data on Furnace 6, a Russian facility,
 is  unknown.^  '

    Average particulate matter emissions from sealed furnaces ranged from
0.002  gr/dscf to  0.032 gr/dscf and from 0.002 Ib/Mw-hr to 0.036 Ib/Mw-hr,
not including tapping fume.   Fugitive emissions escaped at the electrode

                                  51

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                                                                                       53

-------
seats of Furnace K during the tests.  These emissions could not be measured
quantitatively; however, other sealed furnaces were observed to operate
with no fugitive fumes at the electrode seals.

    Two semi-enclosed furnaces (C and P) were tested by EPA.  Data from
these tests are shown in Figures VI-3 and VI-4.  Outlet loadings from the
control devices of Furnaces C and P averaged 0.030 gr/dscf and 0.058 gr/dscf
(0.017 Ib/Mw-hr and 0.078 Ib/Mw-hr) respectively, not including tapping
emissions or those which emanate from the annular openings around the
electrodes.  Particulate matter emissions from around the electrodes were measured
as 48 Ib/hr (2.0 Ib/Mw-hr) for Furnace C and 390 Ib/hr (8.3 Ib/Mw-hr) for
Furnace P.
    Emissions from the spaces around the electrodes of semi-enclosed furnaces
are much greater than controlled emissions from the control device.  Hoods
and ducts could conceivably be installed to capture fumes from the spaces
around the electrodes and send them to a control device.  If a control device
with 99 percent overall efficiency had been used on these emissions for the
furnaces tested, total emissions (excluding those from tapping) would have
been 0.037 Ib/Mw-hr and 0.16 Ib/Mw-hr for Furnaces C and P respectively.
These values are well below typical emissions from controlled open furnaces.

    Emission data obtained by EPA on open ferroalloy furnaces are shown in
Figures VI-5 and VI-6.  Furnaces U and 0 are in Japan.  LI, L2, and L3 are

-------
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o
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02
•a:
*" 0.03
0.02
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0
FURNACE
CONTROL EQUIPMENT
FURNACE SIZE, Mw
PRODUCT
. 	 	 	 j—
KEY
~ EPA
~ MAXIMUM
- 4k fi DATA POINT ~
frrl AVERAGE
~~ ij MINIMUM ~
e DATA POINT
— —
—
-A
'i I*
€>'
1 1
c (1) P (2)
s v V- VENTURI SCRUBB
24 40 S - THIESEN SCRUBB
CaCz 50% FeSi
(1) DOES NOT INCLUDE 48.2 Ib/hr UNCONTROLLED FUGITIVE FUMES FROM AROUND THE ELECTRODES.

(2) DOES NOT INCLUDE 388 Ib/hr UNCONTROLLED FUGITIVE FUMES FROM AROUND THE ELECTRODES.


      Figure VI-4. Particulate emissions (excluding tapping fumes and fugitive fumes) from semi-enclosed
      electric submerged-arc furnaces producing ferroalloys.
 56

-------
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Hrl AVERAGE
i i ~~~
4 u MINIMUM
* DATA POINT
.
\
—

(1) CORRECTED FOR DILUTION AIR THERMALLY
INDUCED THROUGH THE OPEN BAGHOUSES.
J (2) A P = 57 in. W.G. _

(3) A P =47 in. W.G.

(4) A p= 37 in. W.G.

*>
i i
i

g^T 4 DATA ~~
.. WS POINTS
Ml"1 C
; i «>
- & ** 8 -
5 DATA TT
POINTS ® fly
1 1 1 II V-^ III • .-.
FURNACE LI L2 L3 N T U Q(1) 0 M (1) V- VENTURIS
CONTROL EQUIPMENT V(2) V(3) V(4) V P B B B B P - ELECTROS
FURNACE SIZE. Mw 27 27 27 7 40 18 20 27 17 D n«^nir
PRODUCT
SiMn
I   H.C.   I   FeCrSi I  75%  I  Si
   FeCr             FeSi
                                                                                                     57
 Figure VI-5.  Particulate concentrations in control system exhaust from open electric submerged-arc
 furnaces producing ferroalloys.

-------
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2.5
2.0
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Irrl AVERAGE
! t KfllMlhfll IKfl
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0 DATA POINT

(1) INCLUDES PARTIAL CONTROL OF
f> FUME.
^ (3)AP = 47 in!w'.6!
< (4)AP = 37 in. W.G.
(D |)
'€>
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^ £
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TV 1 1
5 DATA
POINTS
1 1 1 1 1 W 1 1

L •-
—
TAPPING


















FURNACE LI L2 L3 N(l) T(l) U(l) Q 0 M
CONTROL EQUIPMENT V(2) V(3) V(4) V P B B B B V- VENTURI^SCRUBBER
FURNACE SIZE, Mw 27 27 27 7 40 18 20 27 PRECIPITATOR
PRODUCT SiMn 1 H.C. 1 FeCrSi 75% 1 Si B- BAGHOUSE
FeCr FeSi
58
         Figure VI-6. Particulate emissions from open electric submerged-arc furnaces producing ferroalloys.

-------
 the  same  furnace  for which  the  energy  loss across  the venturl scrubber
 was  57, 47,  and 37  Inches water gauge, respectively.  Average emissions
 ranged from  0.0010  gr/dscf  to 0.079 gr/dscf, or from 0.035 Ib/Mw-hr to
 1.5  Ib/Mw-hr.  Where noted, the data in Figures VI-5 and VI-6 include fume
 captured  in  a tapping hood  and  ducted to the furnace control device.
 Capture efficiency  for these tapping hoods was estimated as 20 percent
 for  Furnace  N and 80 percent for Furnaces T and U.  Estimated capture
 efficiencies of the furnace hoods ranged from 95 to 100 percent.

     The  data presented in  Figures VI-19 3 and 5 present a wide variation
 in particulate matter concentrations, but no correlation with furnace
 configuration can be drawn  because data for all three types of furnaces
 have similar variations and span roughly the same range of values.  From
 this, one can conclude that a standard restricting the concentration of
 particulate matter  is not a good choice since it cannot mandate the sealed
 furnace, which obviously provides better overall emission control.  The
 data show that mass emissions in terms of Ib/Mw-hr do vary significantly
with the type of furnace.   Mass emissions from semi-enclosed furnaces
with uncontrolled emissions from the annular spaces around the electrodes
are highest.   Open furnaces with efficient control have the next highest
emissions.  Sealed furnaces have the lowest mass emissions and emissions
 from semi-enclosed furnaces which capture and efficiently control  electrode
 emissions  appear to be intermediate between open and sealed furnaces.
                                                                          59

-------
    No measurement was made of emissions from a tapping operation with
an independent control system because none was found from which they could
be measured with reasonable accuracy.  They were measured at three furnaces
where the tapping hoods exhausted directly into the atmosphere without
control.  Average uncontrolled tapping emission rates were 48 Ib/hr for
Furnace C, 53 Ib/hr for Furnace L, and 82 Ib/hr for Furnace P for the
duration of tapping.  Furnace C is continuously tapped.  If tapping emission
rates for Furnaces L and P were averaged over the entire furnace cycle
instead of only the tapping period, tapping emission rates would be reduced
to about 18 Ib/hr and 16 Ib/hr respectively.  Capture efficiency of the
tapping hood was very good on Furnace C and was estimated as 75 percent on
Furnace P.  Hood capture efficiency was not estimated for Furnace L.  At
other plants, tapping hoods with apparent 100 percent capture efficiency
have been observed.
    Based on measurements of emissions from furnaces where tapping emissions
are not controlled and observation of furnaces which very effectively
capture tapping emissions, calculation methods have been used to determine
the equivalent emissions from a furnace at which tapping emissions are
captured and ducted to an efficient control device.  To determine the
effect of including tapping fumes, a conservatively high value of 150
Ib/hr of uncontrolled tapping emissions was assumed.  If these are
completely captured and enter a control device with 99 percent efficiency,
emissions from tapping a 30-MW, continuously tapped furnace would be 0.05
Ib/Mw-hr.  Continuously tapped furnaces are not common except for calcium
60

-------
carbide production.  Tapping emissions averaged over the entire furnace
cycle for a 30-MW furnace tapped for 15 minutes during a furnace cycle
of 75 minutes (start of one tap to the start of the next tap) would
be 0.01 Ib/Mw-hr.  Comparison of these calculated values for controlled
tapping emissions shows they about equal emissions from well-controlled
sealed ferroalloy furnaces, and are about 10 percent or less of typical
emissions from well-controlled open ferroalloy furnaces.

B.  Visible Emission Data
    Visible emission data were obtained at several facilities.  No sealed
furnace had a residual visible emission after the flare.  Visible emissions
from the scrubber serving semi-enclosed Furnace P also were zero percent
opacity.  Visible emissions from control devices serving open furnaces
varied.  They were consistently zero percent opacity for Furnaces U, M
and N during periods when samples were obtained for quantitative emission
measurements.  Maximum visible emissions from other open furnace control
systems ranged from 5 to 15 percent opacity.  In some cases, visible
emissions were traced to leaking bags in baghouses.  Visible emission
data are summarized in a separate document, Background Informatjgn for
Standards of Performance:  Electric Submerged-Arc Furnaces for the Production
of Ferroalloys -  Volume 2, Test Data Summary.

    Visible emissions from buildings which house electric submerged-arc
ferroalloy furnaces were observed at 100 percent opacity for  brief periods.
These emissions may vary from 0 to  100  percent opacity  depending on what
production operation  is occurring and the capture efficiency  of the hoods.
Possible sources  of participate matter  which may  cause  visible emissions  from
                                                                            61

-------
 buildings are fumes which escape from the furnace,  tapping  operations,
 oxygen lancing of tap holes,  and reladling and pouring  of the  ferroalloy.

     Visible emissions were observed  at one tapping  hood through  two  tapping
 periods,  the first of 19 minutes duration, and the  second of 30  minutes
 duration,  and opacities  of fume  which escaped  the hood  were recorded.
 During the first tapping period  observed,  the  hood  was  moved out of
 place twice for unknown  reasons  for  a total of 1.5  minutes of  the 19.
 Excluding  the observations made  during the 1.5 minutes  when the  hood was
 out  of place,  the  opacities were observed  to be zero percent for 12.5
 minutes (or 71.4 percent of the  time)  and  were observed  to be  less than
 20 percent for 15.75 minutes  (or 90  percent of the  time).  Opacities were
 greater than  or equal  to  20 percent  for 1.75 minutes of  the 17.5 minutes
 during which  the hood  was  in  place.  The maximum opacity  observed was 60
 percent.   During the second tap,  the  tapping hood was left in place
 throughout the tapping period.   Opacities  were  observed to be zero percent
 for  22 minutes  of  the  30 minute  tapping period  (73.3 percent of the time),
 and  the maximum opacity observed was 15 percent.

     Visible emission readings of fume escaping furnace hoods were obtained,
and furnace hood capture efficiencies were estimated at 3 open  ferroalloy
furnaces.   In each of these cases, no visible emissions were observed
escaping the hood, and capture efficiencies were estimated as  100 percent.
One other open furnace was observed and judged to achieve equivalent
collection, but formal opacity readings were not made.   Visible emissions
 62

-------
did not escape the covers of the sealed furnaces observed unless the seals
around the electrodes or charging chutes were leaking.  This condition can
be corrected to prevent visible emissions.
                                                                         63

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                   VI I. SUMMARY OF ECONOMIC INFORMATION

A.  Introduction
    This section will examine the cost of the alternative control systems,
evaluate the economic impact of the control costs on the industry, and
compare the cost of the proposed standard of performance to the cost
of achieving State standards.

    The type of furnace and the method of hooding used to capture the
furnace gases have a great effect on the cost of the emission control
system.  The main factor influencing the cost of the control system
is the gas volume that must be treated.  The carbon monoxide and other
gases evolved from the furnace reaction zone can be withdrawn by an
exhaust system without combustion of the carbon monoxide provided the
furnace has a closed water-cooled cover and mechanical seals around the
electrodes.  Although sealed ferroalloy furnaces cannot  be used to
produce all products, they offer the advantage of smaller gas volumes
to clean than an open furnace.  The small volume of undiluted dirty gases
from a sealed furnace is typically cleaned by venturi scrubbers.  Foreign
installations also use electrostatic precipitators and one uses a sealed
baghouse.

    In the open furnace system, induced air is mixed with the carbon mon-
oxide which burns above the charge.  Depending on the design of the particu-
lar furnace, the evolution of gases may result in flows 50 to 200 times
those generated in a sealed furnace system.  The gas flow rate depends on
                                    65

-------
the hood design, the vertical opening between hood and furnace required
for stoking the charge, and the diameter of the furnace.  Fabric filters
(baghouses) or wet scrubbers are typically used to control open furnaces.

B.  Model Plants
    The control costs were developed for model ferroalloy furnaces
(examples of ferroalloy furnaces typical of furnaces which may be built
in the future).  The values of the parameters of each model were chosen
to represent the expected values for new ferroalloy furnaces.  Because
the trend in the industry is toward larger furnaces than in the past,
the size chosen for the models is large - 30 megawatts (except for the
silicon metal furnace which is 25 megawatts).   Table VII-1  shows the pertinent
design parameters associated with the model furnaces.  Since silicomanganese
(SiMn) can be made in the same furnace interchangeably with high-carbon
ferromanganese (HC FeMn), we have assumed that the control  equipment for
the SiMn furnace will be the same as that for the HC FeMn furnace.
    Another emission source that must be controlled in addition to the
furnace is the tapping operation.  The method of control  assumed for this
cost analysis depends on the furnace type.   For open furnaces the tapping
fumes can be collected with a separate hood and vented into the main
control device.  For sealed furnaces a separate fabric filter control
system was assumed as the most probable method of control.
 66

-------
                       Table VII-1.   Model Furnace Parameters
Parameter
Power rating, Mw
Product rate,9 tons/yr
Gas volume from
sealed furnace.
scfm
Gas volume from open
furnace, b acfm @ 400° F
Tapping fume gas
volume for all furnace
types, acfm @ 150°Fd
Product
HC FeMn
30
99,000
5,000

350,000
60,000

SiMn
30
44,000
50% FeSi
30
47,500
5,000 6,000
|

350,000C
60,000
>

450,000
60,000

HC FeCr
30
51,000
5,000

250,000 ,
1
60,000 \
<
CaCg
30
91 ,000
4,000

200,000
60,000

Si Metal
25
14,100
6,000

750,000
60,000
"

 At 90 percent of full  capacity.


 The gas volumes represent typical  values obtained from the industry survey
 questionnaires.


"Assumed to be the same for the HC  FeMn since the furnace may be designed to produce
 either product.


 The figures shown for  the tap fume collection are additive to the open furnace
 volume, based on an open furnace configuration with the collection hood 5 to 7 feet
 above the furnace deck.
                                                                                  67

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C.  Control Costs
    1.  Open Furnace Control Costs
        Control costs for the model open furnaces shown in Table VII-1
    were developed for two types of control devices - fabric filters and
    wet scrubbers.  All costs are in 1972 dollars.
        a.   Fabric Filter Control Costs
            Estimates of investment and operating costs required to control
        open furnaces using fabric filter systems are shown in Table VII-2.
        These costs were  derived  from information developed for EPA by
        the Industrial Gas Cleaning Institute (IGCI).(43)   The tapping fume
        control system is vented into the fabric filter, and the costs for
        that system are included.  The assumptions that form the basis for
        these cost estimates will be discussed below.  The industry's cost
        estimates for fabric filter systems are higher than the figures
        in  Table VII-2 because additional  equipment and installation factors
        are considered.  The industry's cost estimates are shown in
        Table VII-3 and will  be discussed in the second part of this section.
            The capital costs for fabric filter installations as received
        from the IGCI were plotted against the associated  collector inlet
        volumes, and the graph is shown in Figure VH-1. The capital  cost
        for each model  furnace may be determined from Figure Vtl-1  by
        finding the capital  cost that corresponds to  the gas volume flow
        rate for that model.   The capital  costs from  the IGCI study are
        based on a  new plant  situation  (i.e.,  a simple duct run,  no space
68

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Table VI1-2.   Control Costs for Fabric Filters on Open Furnaces
Cost Item
Capital cost
(Thousands of $)
Fab'ric Filter
Auxiliary Equipment
Installation
Total Capital Cost

Annual Cost
(thousands of $
per year)
Operating Labor
Maintenance (6%)
Product
HC FeMn
and SiMn

$ &30
210
1,060
$1 ,900


$ 53
| 114
Electricity 1 87
1
Capital Recovery ! 222
(15 yr. life, 8%
interest) f
s
Administration (2%) I 38
<
Taxes and Insurance
(2%)
Total Annual Cost
Annual Cost Per Ton
50% FeSi

$ 770
250
1,280
$2,300


$ 53
HC FeCr

$ 500
160
840
$1 ,500 •


$ 53
138 | 90
1
106 1 68
a
269 I 175
K
46 | 30
! 1
! 38 \ 46 | 30
1 ' I 1
f $ 552
HC FeMn SiMn
$5.58 $12.55
|
\ $ 658
$13.85
!
$ 446
I $8.75
CaC2

$ 430
140
730
$1 ,300


| $ 53
78
Si
Metal

$1 ,260
520
1,420
$3,200


$ 53
192
57 j 194
1 152 374
26 64
26 I 64
$ 392 j $ 941
I
ft
4
$4.31 j $66.74
                                                                        69

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         Table VI1-3.   Control Costs for Fabric Filters on Open Furnaces
                                  (Estimated by Industry)
Cost Item
Capital Cost ( housands
of $)
Fabric Filter
Auxiliary Equipment
Installation
Total Capital Cost
Annual Cost (Thousands
of $ per year)
Operating Labor
Maintenance (61)
El ectri ci ty
Capital Recovery,
(15 yr. life, 8% interest)
Administration (2%)
Taxes and Insurance (2%)
Total Annual Cost

Product
HC FeMn
and SiMn

$1 ,000
360
1,640
50% FeSi

$1 ,265
455
j
I 2,080
$3,000 j $3,800
|
HC FeCr

$ 700
255
1,145 !
$2,100 !
1
$ 53 t $ 53 1 $ 53 1
i
180 \ 228 126
1 I 1
87 j 106
350 | 444
60 76 j
60
$ 790
76 i
$ 983 ;
68 I
245
?
42 i
5
42 |
$ 576 j
i
HC FeMn SiMnl j j
Annual Cost Per Ton j$7«9S $17.95| $20.69 ! $11.29 1
o » *

CaC£

$ 630
220
1,050
$1 ,900

$ 53
114
57
222
38
38
$ 522

$5.74
Si-
Metal

$1 ,890
780
2,130
$4,800

$ 53
288
194
561
96
96
$1 ,288

$91.35
70

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     4.0
     2.0





     1.5







     1.0




     0.8
     0.6

fe
LU
    0.4
     0.2
       20        30      40    50       7u        100               200               400




                                 INLET GAS VOLUME TO COLLECTOR, acfm x 103




                Figure VI1-1 . Capital costs of open furnace control  with fabric filters.43
800
                                                                                                      71

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     limitations,  etc.)-   The  costs  for  the  furnace  hood and the incremen-
     tal  costs  for increases in  electrical substation capacity are not
     included.   The capital costs  for  the  fabric  filter installations
     include the baghouse, fans, upstream  mechanical collector, dust
     storage bins  with 24-hour capacity, dust  hoppers and conveyors,
     foundation support,  ductwork  connections,  and stack.  The costs
     for engineering design, electrical  and piping  tie-ins, insulation,
     erection,  and performance testing are all  included.  Fiber glass
     bags with  a temperature resistance  of 500° F are assumed to be
     used.  The baghouse  is also assumed to  contain  one extra compart-
     ment which permits  maintenance on  one  section  without shutting
     down the entire baghouse.
         The following assumptions concerning  annual costs of operation
     apply to operation of the control facility for  open furnaces.
         (1)  Replacement parts  and maintenance were estimated at
     6 percent of  the original plant investment for  the purpose of
     replacing 50  percent of the bags  and  10 percent of the air
     valves per year, and for  contingencies.
         (2)  Manpower requirements were estimated to be 1/2 man
     per shift.
         (3)  The  main component of the  electrical costs is the
     power required by the fans  to overcome  the baghouse pressure
     drop.  The pressure  drop  ranges from  10-12 inches of water for
     HC FeCr to 15-20 inches of  water  for  50 percent FeSi.
72

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    (4)  Depreciation and Interest charges are accounted for
by the use of a capital recovery factor based on 15 year life
and on 8 percent interest rate.
    (5)  Administrative costs of 2 percent of original
investment, and another 2 percent for property tax and
insurance were assumed.
    The ferroalloy industry has estimated higher costs  for fabric
filter installations  for   the following reasons:
    (1)  The industry's cost figures are based mainly on
installations at existing plant sites.  Since these instal-
lations must be fitted into the available space, certain cost
items such as ducting will be more expensive.
    (2)  The industry's figures also include items that were
not included in the IGCI cost estimates.  These items are the
furnace hood cost, electrical substation expansion costs,
equipment startup costs, and company engineering and con-
tingency costs.
    If these items are included and installation in an  existing
building is assumed, the capital costs can be as much as 50 percent
higher than the IGCI costs.  Table VII-3 shows the industry's cost
estimates for the model furnaces.
    If the average of the IGCI costs and the industry's costs are
used, the annual cost per ton ranges from a low of $5.03 per ton
for calcium carbide to $79.05 per ton for silicon metal.
                                                                73

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b.  Wet Scrubber Control Co.sts
    Estimates of the investment and operating costs required to
control open furnaces using wet scrubbers are shown in Table VII-4.
These estimates are derived from information from the Industrial
Gas Cleaning institute (IGCI)^43) and are based on equipment and
operating requirements to meet the process weight standard
published in the Federal Register of August 14, 1971  (36  FR 15486),
The costs have been adjusted from IGCI data to reflect the gas
flows of the model plants presented in Table  VIM. The costs in
Table VII-4are based on a new plant installation and do not
include the furnace hood or additional electrical substation
costs.  The industry's experience confirms the costs as presented
in Table  VII-4.
    Plots of investment cost for scrubbers to control furnaces
making 50 percent ferrosilicon that were developed by the IGCI
are shown in Figure '.VI1-2. The cost curve for ferrochrome was
used to develop the costs for all the other alloys except 50
percent ferrosilicon.  The investment costs include a venturi
scrubber, a fan with at least 20 percent excess capacity, an
entrainment separator, aftercoolers, a slurry settler, two
filters to dewater the slurry product, and tapping emissions con-
trol.  The charges for engineering design, electrical wiring.,
piping,  insulation, erection, performance testing, and startup
are all  included.

-------
Table  VI1-4.   Control Costs for Wet Scrubbers on Open  Furnaces
Product
HC FeMn
Cost Item 1 and SiMn 50% FeSi
Capital Cost (thousands of $) 1
Scrubber jj $ 110 I $ 190
Auxiliary equipment I 290 I 510
Installation I 1,400 f 2,450
Total Capital Cost I $1,800 I $3,150
Annual Cost (thousands of $ per year)l I
Operating Labor 1 $ 26 I $ 26
Maintenance (1%) \ 126 I 220 i
Electricity 1 290 J 595 :
Water j 155 ! 298
Capital recovery f 210 | 368
(15 yr. life, 8% interest) I \ \
Taxes and Insurance (2%) 1 35 ' 63 1
Administration (2%) 1 36 63 i
Total Annual Cost ? $ 879 $1 ,633
:HC FeMn SiMn ,
Annual Cost Per Ton • $8.88 $19.97 $34.38 !

HC FeCr

$ 96
254
1,250
$1 ,600

$ 26
112 ;
225 j
118 i
187 j
32 !
32
$ 732 1
1
$14.35 |

CaC2
1
$ 87
233
1,130
$1 ,450

$ 26
102
190
99
169
29
29
$ 644

$7.08
                                                                          75

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       20
30
40   50          80    100              200




            INLET GAS VOLUME, acfm x Ifl3
                                                                                      600
           Figure Vll-2. Capital costs of open furnace control with wet scrubbers.
                                                                                 43
76

-------
    The annual cost per ton of product ranges from a low of
$7.08 per ton for calctuin carbide to a high of $34.38 per ton
for 50 percent ferrosilicon.  Wet scrubber control was not included
for silicon metal because of the difficulty of achieving good
control with wet scrubbers.
c.  Actual Industry Costs
    The Ferroalloy Association submitted to EPA the actual furnace
and air pollution control equipment cost data for several recent
installations.(44)  The specific details of each installation are
somewhat different since each installation was an addition at an existing
plant, and to varying degrees existing equipment was used for the new
furnace.  The costs reported for the control equipment when
adjusted for the year of installation range from -16 percent to
+40 percent of the costs in Figures VII-1  and  VHh2.   Considering the
differences in the bases,, the actual costs compare favorably with the
costs in Figure  VII-1  and  VII-2,,  Since  the EPA estima,te&.,ace
designed to represent typical installations, some differences
for specific installations  are expected.
2.  Sealed Furnace Control Costs
    a.  Furnace Fume Control Cost - Wet Scrubber
        Capital and annual costs are presented in this section for
    control devices on sealed furnaces.  Since the furnace has a
    tight cover with seals around the electrodes, the gas volume
    going to the control device is much smaller than for an open
                                                                      77

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  furnace.  Thus, the cost of the control device is much smaller
  than the control device cost for an open furnace.  However, the
  pollution control equipment is not the only consideration in a com-
  parison of open and sealed furnaces.  Actually, the open and sealed
  furnaces require two different sets of process equipment of which
  the pollution control system is one part.
       In order to make a complete comparision of the two furnace
  types, the total system should be considered from both the process
  side and the air pollution control side.  In this section the costs
  for a sealed furnace are compared to the costs for an open furnace
  to illustrate this point.
       The costs presented here are for a large sealed furnace
  recently constructed in Canada.  These costs should be represen-
  tative of the costs that would be experienced at a U.S. location.
  The maximum power rating for this furnace is 33 Mw for HC FeMn
  and 38 Mw for SiMn.
       The primary control system for the sealed furnace consists
  of the sealed furnace cover, a water spray cooler, a mechanical
  dust separator, and a variable-throat venturi scrubber followed
  by a mist eliminator.  The pressure drop across the scrubber is
  in the range of 75 to 80 inches of water.  The gas flow from the
  furnace is about 6,600 scfm, and the gas flow at the scrubber
  is about 9,700 scfm.  The cleaned gas stream, which is rich in
78

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CO, can be used as a fuel source in the feed pretreatment plant
or diverted to a flare stack.  A complete water treatment system
is included; the treated water is recycled to the scrubber and
the filter cake of solids is recycled to the sintering plant.
    The furnace tapping system is designed with a hood over each
of four tapholes.  A total flow rate of 30,000 acfm is combined
with another 20,000 acfm vent stream and sent to a fabric filter
collector.
   Table  VII-5  shows the costs for the sealed furnace and its
control equipment compared to the company's estimated costs for
an open furnace with a fabric filter collection system.  The
prorated share of the project's utilities, electrical, and
engineering expense for the control system is included in the
control system cost.  In addition to the furnace collection
system and the tapping emission collection system, the company
reported two other cost factors for the totally enclosed furnace
that are different from those of the open furnace.  The first is the
incremental furnace cost which includes such items as more
complex electrode columns and electrical equipment.   The
second item is an incremental feed pretreatment cost which
includes ore and coke dryers and a sinter plant.
    The decision to use the incremental feed pretreatment
must be made after evaluation of the overall process.  Drying and
sintering allow the use of coke and ore fines and the recovered
particulate matter from the  air pollution  control  systems.   Some  foreign
                                                                      79

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       Table  VU-5.   Comparison of Capital and Annual Costs for an
                    upen and a Sealed HC FeMn and SiMn
                    Furnace Producing HC FeMn or SiMn

Cost Item
(45)
Comparison of total capital costs v '
(thousands of ?)
Basic furnace and associated process equipment
Incremental furnace cost
Incremental feed pretreatment
Air pollution control systems

Comparison of control equipment costs
Capital costs'45' (thousands of $)
Primary system
Taphole system (see Table VI-7)
Incremental furnace cost

Annual costs (thousands of $ per year)
Operating cost
Maintenance (6%)
Capital recovery (@ 8% interest)
Administration (2%)
Taxes and insurance (2%)

Open Furnace


$ 8,500
—
—
3,500
$12,000


$ 3,500
(inc. in above)
— ~
$ 3,500

$ 143
210r
409
70
70
Totally Enclosed
Furnace


$ 8,500
1 ,400
3,000
2,100
$15,000


$1 ,700b
400
1 ,400
$3,500

$ 135
210d
! 390
» 70
! 70

Annual cost per, ton

  HC FeMn
  SiMn
a  ($/ton)
                                                   $   902
                                 $9.11
                                $20.50
 $8.84e
$19.89
 Based on 30 Mw for HC FeMn and 34 Mw for SiMn, both at 90% operating rate.

blncluues $900,000 fur the cooler, mechanical separator, scrubber, mist elimina-
 tor, and water treatment equipment; $420,000 for the furnace cover and
 mechanical seals; and $380,000 for the prorated share of electrical utility
 and engineering costs.

 Depreciation  life:   15 years.

Depreciation  lives:  10 years - furnace cover, 15 years - pollution control sys-
 tem, 20 years - incremental furnace costs.


eThis does not include the annualized investment cost or operating cost of the
 incremental feed pretreatment equipment.  The ferroalloy industry has indicated
 that the total manufacturing cost per ton of product is about equal for both
 the open furnace with control and the sealed furnace with control arid feed
 preparation.

   80

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plants with sealed furnaces have these additional  feed pretreatment
steps and some do not.  It is even hard to define  exactly what
should be included as incremental feed pretreatment equipment.
For example, some open furnaces have dryers and some do not
(depending on the availability of dry materials).   Thus, dryers
may or may not be considered as incremental equipment for totally
enclosed furnaces.  The incremental  feed pretreatment cost could
be considered as part of the air pollution control  cost, or could
be considered a process addition for which the economics must be
justified in each individual case.
    In Table V-I.I-5 the capital cost for the incremental feed pre-
treatment is shown, but these costs  are not included in the presen-
tation of the annual cost of the air pollution control equipment.
After an overall evaluation was made, this particular plant decided
that the sealed furnace with the additional feed pretreatment
was the best choice in this case.  Japan Metals and Chemicals,
the largest producer of ferroalloys  in Japan and a  ferroalloy
furnace manufacturer, states that the final cost of product is
the same from either an open or totally enclosed furnace.'46'
The particular method of processing  must be considered separately
for each individual installation.
    It is not possible to generalize from this case to say that
in all cases the totally enclosed furnace with feed pretreatment
would be the most economical.  For example, in the  case where
a furnace is to be added at an.existing plant, an  open furnace
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    could possibly  use  the existing feed preparation and delivery
    system whereas  a  sealed furnace might require a new, separate
    feed preparation  and delivery system.  Also, the open furnace
    could possibly  be installed  in an existing building while the
    taller,  totally enclosed  furnace would probably require a new
    or  expanded  building.  These or other differences at any specific
    site could affect the  costs  enough  to change the choice of the most
    economical type of  furnace to an open furnace.
       The  cost data in Table V.1I-5 are for  sealed furnaces producing
    HC  FeMn  and  SiMn.  Table VII-6 shows the  emission control device
    cost for a sealed 30 megawatt CaC2  furnace.  The costs are
    based  on extrapolation from  the HC  FeMn  costs for the same type
    of  system using the following relationship:
                                                    CaC? gas volume
     Cost of CaC2 System  =  Cost of HC  FeMn  System X HC  FeMn gas volume
    Only the emission control system  is shown in Table VII-6.
    b.   Furnace  Fume Control   Cost  -  Fabric  Filter
        One known company  uses  a fabric filter as  the control device
    on  a sealed furnace.   This  method of control  has not been used
    in  the U.S., and the  domestic industry does not  expect  to use
    this method of control for sealed furnaces.  The estimated
    capital  cost for a  conventional fabric filter control  system*con-
    sisting of a radiant cooler, cyclone, fan, fabric  filter,  dust
    removal and storage equipment,  water seal tanks,  and flare  stack,
82

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         Table VI1-6.   Control Costs for a Sealed CaC2 Furnace
                   Cost Item
 Cost
 Capital  Costs  (Thousands  of $)
   Primary  Control  System
   Taphole  System  (See Table VI-7)
 Total Capital  Cost
$1,280
   400
$1,680
Annual Costs  (Thousands of $ per year)
  Operating Cost
  Maintenance  (6%)
  Capital Recovery (15 year life, 8% interest)
  Administration (2%)
  Taxes and Insurance (2%)
Total Annual Cost
Annual Cost per ton of Product ($/ton)
$  119
   101
   196
    34
    34
$  484
 $5.32
                                                                      83

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       is about $250,000.  However, this system would have to be
       specially designed because of the high concentration of CO gas.
       These added design considerations could substantially increase
       the cost.
       c.  Tapping Fume  Control Cost
           The estimated capital and annual costs presented in Table VU-7
       are based on  a  separate fabric filter control system for emissions
       generated during  the furnace tapping operation.  The assumed flow
       rate was 60,000 acfm at 150° F.  The system includes a hood, fan,
       fabric filter,  and dust removal  and storage equipment.
           Because the tapping operation can be scheduled with some
       flexibility,  this control system could serve more than one
       furnace.  Possibly tapping fume  hoods from two furnaces could  be
       vented to the same fabric filter,which would reduce the control
       cost per furnace. However, for  this analysis a  separate tapping
       fume control  system for each furnace has been assumed.
D.  Discussion of the Control  Costs
    1.  Cost Effectiveness Comparisons
        In general, varying the level  of control  efficiency required will
    result in a change of the control  system cost.   In the case  of the
    ferroalloy furnace controls, the costs do not follow the usual
    pattern.  This can be seen in two comparisons.   Consider first the
    open furnace control systems—fabric filters  and wet scrubbers.

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   Table VII-7.   Control  Costs for a Separate Tapping Fume Collection System
                   Cost Item
                               Cost
 Capital  Cost
   Fabric  Filter
   Auxiliary Equipment
   Installation
 Total Capital Cost
                             $ 85,000
                               55,000
                              260,000
                             $400,000
Annual Cost
  Operating Labor
  Maintenance (10%)
  Electricity
  Capital Recovery (15 yr. life at
  Administration (2%)
  Taxes and Insurance (2%)
Total Annual  Cost
Interest)
$ 10,000
  40,000
  23,000
  47,000
   8,000
   8,000
$136,000
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The fabric filter systems can achieve the best control.   If the
required control efficiency js lowered, wet scrubbers could be used.
But, as Tables V'IJ-2,3, and 4 indicate, the annual  costs  for wet
scrubbers are higher than those for fabric filters.   Therefore,
there is no cost advantage to setting an emisssion standard which
requires a lower efficiency than what can be achieved using a fabric
filter system.
    A second comparison can be made looking at sealed furnaces and
open furnaces for production of HC FeMn, SiMn, and CaC2-   For
these products the cost of the control device for the sealed furnace
(Tables Vir-^,6) is lower than that for a fabric filter on an open furnace
As discussed in section C.2.a., when all costs are considered there
is no  significant cost difference between an open furnace with
fabric filter and a sealed furnace with a wet scrubber.  Therefore,
the choice of system will be influenced'by factors other than
cost.
 2.   Control  Costs  -  New  Source  Performance Standards vs. State Standards
     In  order to  meet typical  State process weight standards, the
 ferroalloy furnaces  must install  fabric  filter  control systems (or
 equivalent)  on open  furnaces  and provide control of tapping fumes.
 This is,  of course,  equivalent  to the  requirements  of  the proposed
 standard of performance.  Therefore, the cost of control  to meet
 the proposed standard of performance is no qreater
 than what the industry must spend to meet  typical state standards.
 86

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 E.   Economic Impact
     It is  estimated that  five  to eight new furnaces will be needed in the
 next   5   years  to  provide  the required new capacity and replacements
 for  existing units.   However,  only one unit is currently under construction
 and  that is  due  for completion in 1975.  In 1972 four producers closed
 their  plants.  Thus,  there  has been a net attrition rather than a slow
 growth in  the industry.   As is true with many products, ferroalloy
 prices  were  frozen  at low levels which severely limited profits and
 consequently  limited funds available for expansion.  With the exception of
 the  new unit mentioned above, the industry is investing a large proportion
 of available capital in pollution control  equipment to meet the 1975
 emission control  guidelines.
     The combination of price controls and  the upsurge  in the steel
 industry have caused a severe shortage of  ferroalloys.   Imported  alloys
 are selling at two and three times  the controlled domestic  prices.  With
price control regulations  relaxed,  it is apparent the  air pollution
control costs ranging from 5 percent  of the selling price for  ferromanganese
to 20 percent for silicon  metal, can be passed  on  to the  consumers.
                                                                        87

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                       VIII.  ALTERNATIVE STANDARDS

     Listed below for each pollutant are alternatives which were considered
in developing the proposed standards of performance.

A.  Alternative Standards for Participate Matter
     1.   Alternative No.  1.-!/
         No owner or operator shall  cause to be discharged into the
     atmosphere from any affected facility any gases which:
         a.
         b.
    Contain particulate matter in excess of 0.45 kg/Mw-hr
    (0.99 Ib/Mw-hr) while that facility produces silicon metal,
    ferrosilicori (60 percent and above), calcium silicon, or
    silicomanganese zirconium.

    Contain particulate matter in excess of 0.23 kg/Mw-hr
    (0.51 Ib/Mw-hr) while that facility produces charge chrome,
    ferromanganese silicon, or silvery iron (5 to 24 percent
    silicon).

c.  Contain particulate matter in excess of 0.07 kg/Mw-hr
    (0.15 Ib/Mw-hr) while that facility produces silicomanganese,
    ]_/  The  limitations of parts  (a) and  (b) of Alternatives  1 and 2
 can be achieved by  an open furnace with good control equipment such as
 a  fabric  filter.  Part  (c) will probably  require  a well-controlled sealed
 furnace although a  tightly hooded open furnace with very  good control may
 suffice (see data for Plant U in Chapter  VI).
                                     89

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           ferromanganese, calcium carbide, high-carbon ferrochrome,

           nominal 50 percent ferrosilicon, or ferrochrome silicon.


   Advantages


   1)  This option mandates  "best technology."


   2)  It  strongly encourages use of sealed furnaces for those product

       lines for which they  have been demonstrated.  This has the

       following advantages:


       (a)  A  sealed furnace results in  nearly 100 percent capture

            of emissions.


       (b)  Restriction  of air  flow rate through  the control system

            minimizes emissions.-'


        (c)  Emissions of CO  from a sealed furnace are  sufficiently

            concentrated that CO can be  recovered for  fuel or chemical

            synthesis.—
    %  Air volumes and therefore mass emissions (for a fixed exit concentra-
tion) from a sealed furnace are only about 2 percent as much as from an
equivalent open furnace.

    &  The recoverable energy from a sealed furnace may approximate 20 to
35 percent of the total power input.  For a 30 megawatt furnace this is
approximately equivalent to 15,000 gallons of fuel  oil per day.  In foreign
countries, this gas is commonly used to fire dryers and plant boilers, or
for chemical synthesis.
90

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         (d)  This limitation improves the working environment of employees
              because the sealed furnace maximizes capture  at  the furnace
              of emissions potentially harmful  to  human  health.

         (e)  Sealed  furnaces maximize product  yield  by  minimizing loss
              of charge material  through the  stack or as fugitive emissions.

         (f)  The sealed  furnace  minimizes  power requirements  for air
              pollution control  to about 10 percent that required for
              open  furnaces.—'

         (g)  Large sealed furnaces can  be  readily automated to reduce
              labor and operating costs.

         (h)   Capital cost of  control equipment is minimized because
              sealed furnaces  with their attendant  low volumes of exhaust
              gas require smaller and less  expensive control devices.
         (i)  The use of sealed furnaces may provide for closer process
             control  by analysis and monitoring of gas consitutents.
    3)  Open furnaces with good control systems are permitted  for those
        products for which sealed furnace technology is  not known to be
        demonstrated.
    4/
    -'  Energy requirements for equipment to control  air pollution  on  open
furnaces approximate 10 percent of the power input to the furnace.   For a
sealed furnace, control equipment power requirements  approximate  one percent
of the furnace power input.
                                                                         91

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   4)  This alternative permits the use of scrap steel 1n open furnaces
       for the production of silvery Iron.
   5)  This alternative requires control of tap fumes for all furnace
       configurations and also requires control of any emissions occurring
       from the annular openings at the electrodes of semi-enclosed furnaces.

   Disadvantages
   1)  A regulation that requires sealed furnaces:
        (a)  Would restrict their use to a certain "family" of products
            (precluding manufacture of certain other  products), thereby
            restricting the flexibility of new furnaces to respond to
            market demands.
        (b)  Could indirectly encourage construction of open  furnaces
            outside of the United  States  where pollution  requirements
                                                                   5/
            are  less  stringent in  order to retain the flexibility.-
    2)   Sealed furnaces require additional  safety precautions and  facilities
        for the transfer  and treatment of  CO  gas.  (See  Issue 2, Chapter  XI.)
    &  Such a trend could ultimately make the United States dependent on
foreign sources for steel  additives (ferroalloys)  necessary for defense
and consumer goods.  However, this reason is somewhat mitigated by our
present dependence on foreign sources for ferroalloy ores (such as manganese)
Foreign suppliers are already beginning to process their own ores and may
one day ship only the ferroalloy to United States markets.
92

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  3)  Sealed furnaces may require additional pretreatment of raw
      materials for production of some ferroalloys.  (See Issue 3,
      Item  1, Chapter XI).
  4)  This  alternative  could  prevent  the  use of scrap steel turnings
      in  the production of  50 percent ferrosilicon,  thereby increasing
      costs and reducing capacity for production  of  this  ferroalloy.
       (See  Issue  3,  Item 3, Chapter XI).
   5)  -Limited  data are  available for sealed furnaces producing some
       alloys  included in Part 3 of  this  alternative.
       (a)  Only one sealed furnace  each  is known  to  produce high-carbon
            ferrochrome and ferrochrome silicon.
       (b)  Only two sealed furnaces are known to produce 50 percent
            ferrosilicon.
   2.  Alternative No._2.-^' -
       No owner or operator shall cause to  be discharged  into the
   atmosphere from any  affected  facility  any gases which:
       a.   Contain particulate matter in  excess of 0.45 kg/Mw-hr
            (0.99  Ib/Mw-hr)  while that facility produces silicon
    6/  The emission limits of Alternatives  1  and 2 are identical._  Some
ferroalloys have been taken out of category  c  and put into categories  a
and b.
                                                                       93

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           metal,  ferrosilicon  (50  percent and above), calcium
           silicon,  or silicomanganese zirconium.
      b.   Contain particulate matter in excess of 0.23 kg/Mw-hr
           (0.51 Ib/Mw-hr) while that facility produces high-carbon
           ferrochrome, ferrochrome silicon, silvery iron, ferromanganese
           silicon, or charge chrome.

      c.   Contain particulate matter in excess of 0.07 kg/Mw-hr
           (0.15 Ib/Mw-hr) while that facility produces silicomanganese,
          ferromanganese, or calcium carbide.
  Advantages

  1)  This alternative is consistent with  the  "best technology  (taking
      into account the cost)"  requirement  of the  Clean Air Act.
  2)  This alternative  permits  50  percent  ferrosilicon, high-carbon
      ferrochrome,  and  ferrochrome  silicon to  be  produced  in  open
      furnaces.

  3)   This alternative permits the  use of scrap steel  turnings for
      producing 50 percent ferrosilicon and  silvery iron.   (See
      Issue No. 3, Item 3, Chapter XI).

 4)   The  technology to produce ferromanganese, silicomanganese and
      calcium carbide in sealed furnaces is well demonstrated by over
      20 years experience in foreign countries.
94

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   5)   This  alternative increases  the  industry's  flexibility.   Fewer
       sealed furnaces  will  be  built since  fewer  products will  be
       required to be produced  in  them.
   6)   This  alternative minimizes  the  number of products which  will
       require pretreatment of  raw materials.-'
                                                 \
   7)   This  alternative, by increasing the allowable number of  open
       furnaces, may decrease any tendency of the domestic  industry  to
       build new furnaces outside the United States.

   8)   Advantage 5 of Alternative Number 1 applies.
   9)   The emission limitations of categories a and b of this alternative
       could be easily met through use of sealed furnaces for those
       products for which sealed furnaces have been demonstrated.
   10)  For  category c  of this alternative, Advantages 2(a) through 2(i)
       of Alternative  Number 1 apply.

   Disadvantages
   1)  Open furnaces,  with  their  inherently  larger air volumes, will:
        (a)   Emit  more  participate than  the sealed  furnace.-/
    ~U  Ferromanganese,  silicomanganese,  and calcium carbide  are  produced
in sealed furnaces in foreign countries without substantial feed  pre-
treatment.
                                                                       95

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      (b)   Consume  greater  quantities of energy and incur higher
           operating costs  for air pollution control than sealed
           furnaces.

  2)  This  alternative fails to encourage the development of technology
     to overcome the limitations in product flexibility of the sealed
     furnace.

 3)  Disadvantages 1 and 2 of Alternative Number 1 apply to category
     c.

 3.  Alternative No. 3.
     No owner or operator shall  cause to be discharged into the
 atmosphere from any affected facility any gases which:

     a.  Contain particulate matter in excess of 0.45 kg/Mw-hr
         (0.99 Ib/Mw-hr) while that facility produces silicon
         metal, ferrosilicon (50 percent and above),  calcium
         silicon, or silicomanganese zirconium.
     b.  Contain particulate matter in excess of 0.23 kg/Mw-hr
         (0.51 Ib/Mw-hr) while that facility produces high-carbon
         ferrochrome,  ferrochrome silicon,  silvery iron,  charge
         chrome, silicomanganese, ferromanganese,  ferromanganese
         silicon,  or calcium carbide.
96

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Advantages
1)  This alternative permits the use of open furnaces for the production
    of all ferroalloys.
2)  This alternative permits the use of scrap steel for the production
    of ferrosilicon.
3)  This alternative does not introduce any problems of product
    flexibility.
4)  This alternative will not encourage the domestic industry to
    build new furnaces outside  the United States.
5)  This alternative will also  permit  use of  sealed furnaces where
    appropriate.
6)  Advantage 5 of Alternative  Number  1 applies.
Disadvantages
 1)  Disadvantages 1 and  2 of Alternative  Number 2 apply.
 2)  This alternative does not require  new facilities to utilize
     the best methods of air pollution  control for some ferroalloy
     products.
 4.  Alternative No. 4.
     No owner or operator shall  cause to be discharged into the
 atmosphere from:
                                                                      97

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     a.  Any affected open furnace facility any gases which contain
         participate matter in excess of 0.45 kg/Mw-hr (0.99 Ib/Mw-hr)
         while that facility produces silicon metal, ferrosilicon
         (50 percent silicon and above), calcium silicon,  or silico-
         manganese zirconium.

     b.   Any affected open furnace facility any gases which contain
         particulate matter in excess of 0.23 kg/Mw-hr (0.51  Ib/Mw-hr)
         while  that facility produces high-carbon  ferrochrome, ferro-
         chrome silicon,  silvery iron,  charge chrome,  silicomanganese,
         ferromanganese,  ferromanganese silicon, or  calcium carbide.

    c.   Any affected  sealed furnace  facility any gases which contain
         particulate matter  in excess of 0.07  kg/Mw-hr (0.15 Ib/Mw-hr)
         while  that facility produces silicomanganese, ferromanganese,
         calcium carbide, high-carbon ferrochrome, nominal  50 percent
         ferrosilicon, or ferrochrome silicon.
Advantages

1)  Advantages 1 through 4 of Alternative Number 3 apply to categories
    a and b of this limitation.

2)  Categories  a and b of this limitation require  any operator  installing
    open furnaces to use best  control technology for open  furnaces.
98

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B.
3)  Category c of this limitation requires any operator installing
    sealed furnaces to use best control  technology for sealed furnaces.

4)  Advantage 5 of Alternative Number 1  applies.

Disadvantages
1)  Disadvantages 1 and 2 of Alternative Number 2 apply to categories
    a and b of this limitation.
2)  This alternative permits greater emissions from an open furnace
    than from a sealed furnace even when producing the same product.
    This could discourage the installation of sealed furnaces.

Alternative Standards for Carbon Monoxide (CO)
1.  Alternative No. 1.-'
    No owner or operator shall cause to be discharged  into the
atmosphere from any affected facility any gases which  contain
on  a  dry basis, 20 or greater volume percent of carbon monoxide.
Combustion of  such gases under conditions acceptable to the
Administrator  shall constitute compliance with  this requirement.
    y  Consultation with a manufacturer of CO flares and incinerators
revealed that CO will support combustion in air at 12.5 percent or greater
CO by volume.  (The lower limit is subject to minor variation depending on
the gas's temperature and humidity.)  In the open furnace, CO burns upon
contact with ingested air at the surface of the charge material.  In semi-
enclosed and sealed furnaces, which operate at slight positive pressure,
the CO exits from the furnace at a concentration of between 50 and 90
percent by volume.
                                                                         99

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Advantages
1)  The operation of open furnaces is not affected.
2)  The operator using semi-enclosed or sealed furnaces must flare
    the furnace gas or use it as fuel.
3)  Enforcement and compliance are simple and inexpensive.

Disadvantages
    None apparent.
2.  Alternative No. 2.
    Set no standard of performance for CO.  Individual  States will  set
standards on the basis of air quality.
Advantages
    None apparent.
Disadvantages
1)  This would not require installation of best demonstrated technology
    to preclude the creation of new air pollution problems  by sealed
    or semi-enclosed furnaces.
2)  This could result in high localized concentrations  of CO.
TOO

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C.   Alternative Standards  for Visible Emissions
    1.  Alternative No. 1.
        No owner or operator shall cause to be discharged into the
    atmosphere from any affected facility any gases which exhibit 10
    percent opacity or greater.

    Advantages

    1)  This alternative is consistent with the intent of the Clean Air
        Act to mandate best technology.

    2)  This alternative requires control of tap fumes.

    3)  Open furnaces with scrubber or baghouse control devices can meet
        this limitation.
    4)  This alternative minimizes the emissions since visibility of the
        exhaust is a gross indication of particulate mattar content.

    Disadvantage
        It is possible that this limitation can be exceeded while the
                                              9/
        mass emission limitation is being met.—
    -'  One open furnace producing 75 percent ferrosilicon equipped with
a closed suction baghouse had emissions of up to 15 percent opacity while
nearly meeting a mass standard of 0.99 Ib/Mw-hr.
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 2.   Alternative No.  2.
     No  owner or operator  shall  cause  to  be discharged  into the
 atmosphere from any  affected  facility any gases which  exhibit
 20  percent opacity or greater.

 Advantages

 1)   Advantages  1  through  3  of Alternative No.  1 apply.
 2)   It  is  not likely that this  requirement can be exceeded while
     still  meeting the mass  emission requirement.

 Disadvantage

     This alternative would  permit  greater emissions.
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            IX.  ENFORCEMENT ASPECTS OF THE PROPOSED STANDARDS

     The proposed standard includes limitations on particulate matter,
visible, and carbon monoxide emissions.  Open, sealed, and semi-enclosed
furnaces with proper control equipment could be used to meet the proposed
standard.

A. 'Particulate Matter Standard
     The proposed standard limits all emissions of particulate matter from
the electric submerged arc furnace and includes those which occur during
the tap cycle of the furnace.   Uncontrolled particulate matter emissions
will  vary with the alloy produced, type and size of raw materials, operating
techniques, furnace design, and the input power at which the furnace is
operated.

     When  a new furnace  is installed, a record should be made of the products
  for which the furnace is designed and the maximum furnace power rating for
  each.  The control system must be designed to assure that the standards of
  performance for each product will be achieved when the furnace is producing
  at the maximum power input for that product.  If possible, the performance
  test should be performed when the furnace is producing the product having
  the emissions most difficult to control.   For example, the performance test
  for a furnace designed to produce 75 percent ferrosilicon and silicon metal
 should be performed while producing silicon metal.

     Control devices on existing furnaces  exhaust the  effluent in  three
 possible ways:   (1) through a single stack,  (2)  through multiple  stacks,
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 and (3) unconstrained (total  absence of a stack or duct).   Enforcement
 aspects of measuring particulate matter which vary according to these
 categories, are discussed below:

     1.   Effluent discharged through a single stack.
         This configuration  is  most easily tested.   The  methods  for measurement
     of particulate emissions  are specified in 40 CFR 60 (Reference Methods  1,
     2,  3,  4, and 5).

         New sources should  be  designed to assure optimum sampling conditions.
     For example, the optimum sampling location is  not less  than 8 diameters
     downstream and two diameters upstream from anything in  the  duct which
     might  disturb the gas flow.   Although the Methods permit deviation
     from these optimum criteria, there should be a design goal  to ensure the
     most accurate and precise  results possible of  any measurements of emissions,
         Platforms,  utilities and sampling ports should  be located to
     facilitate sampling at  new or modified sources.
     2.   Effluent exhausted  through multiple stacks.
         The problems presented by this possibility are  merely time and
     expense.   The number of tests required and their attendant  costs  may
     make a rigorous compliance test impractical.   In such a  case,  the
     source and the  enforcement agency should agree on a specific  plan
     for measuring emissions which will  provide the data necessary to
     determine  compliance at a  reasonable  cost.   The  optimum  plan  will
     vary from  source to source.
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    Portable opacity instruments have recently become available
and represent low-cost means of showing comparability between stacks.
These instruments may be a desirable tool  for use in a test plan.

3.  Effluent not constrained within a stack.
    This category includes emissions that discharge through roof
monitors, open or pressurized baghouses, and, in some cases, open-
faced filters. Performance test methods for this category have not
been specified because of the lack of proven test techniques, a
consequence of limited sampling experience.
    Several problems surface when attempts are made to measure
unconstrained effluent.  The first is the difficulty of obtaining
a representative sample.  Large and sometimes multiple areas (cross
sections) from which emissions exhaust make it impractical or impossible
to sample at sufficient points to represent the entire discharge area.
The accuracy of any alternative depends on the validity of the
engineering assumptions necessary.  One alternative is to subdivide
the total flow area into sub-areas which are then sampled.  Sampling
may parallel Method 5, or other techniques such as high-volume sampling
may be used.  One scheme includes traversing across the horizontal
cross section of a roof monitor with a high-volume sampler.  Another,
used in the aluminum industry, requires multipoint sampling by a
permanent sampling manifold mounted beneath the roof monitor.  The
manifold discharges to a small stack which can be sampled using Method 5.
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    A second problem results from the very low flow rates commonly
encountered in these systems.  Often they cannot be measured with
conventional sampling equipment.  This precludes accurate isokinetic
sampling and determination of volumetric flow rates.  The isokinetic
sampling problem is usually resolved by determining average velocities
using extremely sensitive measuring devices and then sampling at this
average rate.  Volumetric flow rate may be determined in a similar
manner.  (It is usually possible to determine volumetric flow rate
more accurately by measuring flow on the inlet side of the control
device.)
    The presence of dilution air presents a third and equally serious
impediment to determining accurate emission values.  To determine if
a source complies with a concentration limitation, a correction must
be made for any dilution air present.  To determine a mass emission
rate requires knowledge of the actual volumetric flow rate at the
sampling location.  In either case, it is necessary to measure dilution
air flow rates.  The difficulty in measuring dilution air may prevent
or at least will seriously limit accurate emission measurements.
    Due to these problems, the accuracy and precision with which the
mass rate of emissions can be determined appears limited and, in
fact, the configuration of certain sources totally defies representative
sampling.  Because of the potential cost of testing, the source and the
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    enforcement agency should agree on a specific test plan or means
    for determining compliance prior to construction of a new source.

        EPA is  reviewing discharge configurations from control
    devices being sold in an  attempt to improve test procedures.
    As this investigation progresses, certain criteria can probably be
    specified which will improve the accuracy of testing.  Until  such
    criteria are available,  new plants should be equipped with  exhaust
    systems which will allow representative sampling.

B.  Visible Emissions  Standards
    The visible emissions  standards  serve  three purposes:
    1.  To assure the capture and control  of all particulate matter
    emissions from the furnace and its tapping station.
    2.  To provide a quick and inexpensive means of enforcing proper
    maintenance and operation of the control  device, furnace hoods,
    tapping hoods, and ducting.

    3.  To ensure that dust captured by the control  device(s) is  properly
    handled and not reentrained in the atmosphere.
C.  Carbon  Monoxide Standard
    Enforcement of the CO standard is easy.  An open furnace cannot violate
the standard since the CO is  burned with ingested air at the surface of the
charge materi al.
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    The gases exhausted from the control device on a semi-enclosed or
sealed furnace contain 50 to 90 volume percent CO.  The exhaust gases
from these furnaces must be flared prior to entering the atmosphere or
must be used in other processes.

D.  Emission Monitoring
     The proposed standard requires that a photoelectric or other type
smoke detector and recorder be installed to continuously monitor and
record the opacity of gases discharged into the atmosphere from the
control device(s).
    EPA proposed performance specifications for opacity monitors on
September 11, 1974 (39 FR 32852).  Instruments commercially available
which conform to these specifications are capable of measuring opacity
within a narrow path 50 or more feet long.  Instruments which are
installed and operated in accordance with the specifications will
produce reliable opacity data.  Effluent discharged through a stack or
duct can be readily monitored.
E.  Monitoring of Operations
    To ensure that the furnace and pollution control systems are being
operated within design parameters and at conditions for which the
compliance tests are representative, the following records must be made:

    1.  A daily record of the product being produced.

    2.  A daily record of the charge constituents to the furnace
    including the proportions by weight of each constituent.
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    3.  Records of the average power input to the furnace during each cyc7e,
    in megawatts.

    4.  Records of the time and duration of each tapping period and the
    identification of material tapped (slag or product).

    In addition, a wattmeter must be installed, calibrated, maintained, and
operated to continuously monitor and record the power consumption of the
furnace.
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                             X.  MODIFICATIONS
    Under conditions defined in section 111 of the Clean Air Act and
supplemented in §60.2 of 40 CFR 60, an existing source which is modified
may become subject to standards of performance.

    Modifications to a ferroalloy furnace which could render the facility
subject to standards of performance are changes in raw materials which
force physical  alterations to the furnace, changes in product grades or
"families" which increase emissions, and increasing the transformer capacity
to increase production (hence emission) rates.  These changes are ways to
meet market demands, increase production, or respond to availability of
raw materials without investment of the large amount of capital necessary
for an entirely new furnace.

    Any such modification will  require that the air pollution control
system on an existing furnace be upgraded to meet the standards of
performance.  This may be very costly, and in some cases almost
physically impossible.   Reasons for this are:

    A.  The building which houses the furnace may prevent installation
        of a hood or furnace cover because of space limitations above
        the furnace.

    B.  Prohibitively expensive revisions of electrical  components may
        be required to install  a hood or cover.

    C.  Installation of a hood or cover may require changes in the
        furnace feed delivery system.
                                     Ill

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4    D.  Extensive changes to electrode columns and suspension systems
         might  be required.
     Changes to the ferroalloy electric submerged arc furnace that would
 not be considered a modification  include:
     A.  Changing proportions of  the charge materials to the furnace
         if the products  are ferroalloys for which the furnace was
         originally designed.
     B.  Changes in reducing agents, types of  scrap steel,  or use of
         slags  to produce ferroalloys  for which the furnace was
         originally designed.
     C.  Replacement  of carbon  hearths, furnace linings, mix chutes,
         furnace covers, hoods,  ductwork,  replacement of transformers
          in kind,  furnace digouts, tap hole  repairs,  or electrode spacing
          adjustments, so long  as production  capacity  was not increased  and
          the modifications did not result  in changing the  furnace capability
          to permit manufacture of products  other  than those for  which  the
          furnace was  originally designed.
      The impact of compliance with the standards  of performance  for new sources
 will vary depending on the type of furnace.   It is generally  accepted  that
 the open and perhaps even the semi-enclosed furnaces  cannot be economically
 altered to achieve the standards of performance if it is  based on technology or
 emission rates from sealed furnaces.  In  such a case  it would  be less  expensive
 to construct an entirely new facility.

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A.  Open Furnaces
     An existing open furnace can be substantially modified, upgraded and
controlled for about $3 to $5 million..  An equivalent new installation
would cost $15 to $20 million.  Obviously, the economics dictate up-
grading.  A modified existing open furnace with proper control  equip-
ment can comply with the proposed standards of performance for a new furnace.

B.  Semi-Enclosed Furnaces
     If the cover is removed from an existing semi-enclosed furnace to
permit the manufacture of a greater variety of alloys, the modified
furnace should become subject to the standards of performance.   As with
the open furnace, a semi-enclosed furnace modified in this way probably
can comply with the standards if proper control equipment and adequate
hooding are used.
C.  Sealed Furnaces
     The possibility of a modification to an existing sealed furnace is
remote since there is only one in the United States.  It is difficult to
imagine a modification which would preclude the ability of a sealed
furnace to meet the standards of performance for new sources.  One
possible (but highly improbable) modification would be conversion to an
open furnace.  The incentive would be to permit production of a different
product family than that for which it was designed.  This very expensive
change would also require significant alterations to the transformer and
electrodes.  The modified furnace could be controlled to meet the proposed
standard of performance.
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                    .XI.   MAJOR ISSUES CONSIDERED

    The mandate to base the standards of performance for ferroalloy electric
submerged arc furnaces on the best air pollution control technology which
has been demonstrated and which is economically viable seems clear.
In effect, however, repercussions from a standard which would allow only sealed
furnaces could be felt far beyond the ferroalloy industry.
    A standard which restricts new furnaces to the totally sealed configuration
could:

    A.  Result in multinational corporations building new open furnaces
        outside the United States where pollution requirements are less
        stringent.

    B.  Cause the demise of portions of the United States ferroalloy
        industry and place the country in the untenable position of
        dependence on foreign sources of some steel additives (ferroalloys)
        necessary for defense and consumer goods.—

    The major areas of issue are tabulated as follows:

    A.  Do sealed furnaces represent demonstrated technology?
    ]_/  This reason is somewhat ameliorated by the fact that the United
States ferroalloy industry must rely on foreign sources for some ores
(such as manganese and chromium ores).  These foreign suppliers are
beginning to process their own ores and may soon ship only the ferroalloy
to the United States market.
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     B.  Does use of the sealed furnace create a safety hazard?
     C.  Does use of the sealed furnace place the United States
         industry at an economic disadvantage in the world market?
A.  Issue 1.  Does the Sealed Furnace Represent Demonstrated Technology?

     Discussion
     Section lll(a)(l) of the Clean Air Act, as amended, states:  "The
term 'standard of performance1 means a standard for emissions of air
pollutants which reflects the degree of emission limitation achievable
through the application of the best system of emission reduction which
(taking into account the cost of achieving such reduction) the
Administrator determines has been adequately demonstrated."  The term
"available control technology" is further defined in a report of the
Committee on Public Works, United States Senate, when air pollution con-
trol Was still a function of the Department of Health, Education and
Welfare, as follows:  ". . . 'available control technology,' is intended
to mean that the Secretary should examine the degree of emission control
that has been or can be achieved through the application of technology
which is available or normally can be made available.  This does not
mean that the technology must be in actual routine use somewhere.  It
does mean that the technology must be available at a cost and at a time
which the Secretary determines to be reasonable.  This implicit con-
sideration of economic factors in determining whether technology is
'available' should not affect  the usefulness of this section.  The
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overriding purpose of this section would be to prevent new air pollution
problems, and toward that end, maximum feasible control of new sources
at the time of their construction is seen by the Committee as the most
effective and in the long run, the least expensive approach."^  '

    Sealed furnaces have been used in foreign countries to manufacture
silicomanganese, ferromanganese and calicum carbide since about 1954/48)'
In Japan and Norway, all standard ferromanganese is produced in sealed
furnaces.      Almost all silicomanganese produced in Norway is made in
sealed furnaces and future plans presume that, ultimately, all will  be produced
in them/     EPA measured emissions from sealed furnaces producing  silico-
manganese and ferromanganese in Porsgrunn, Norway/  '* ^52'

    Sealed furnaces have been used to produce ferromanganese, silicomanganese
and calcium carbide in Japan since at least 1962/53^' ^54^  The Japanese
also use sealed furnaces to produce 50 percent ferrosilicon (two furnaces
which have operated since 1968 and 1972 respectively), 75 percent ferro-
silicon (one furnace which has operated for 2 to 3 years), ferrochrome
silicon (one furnace, operated since 1970), and high-carbon ferrochrome
(one furnace, operated since 1971).   These are the only sealed furnaces known
to be producing these ferroalloys/   '   Emission measurements were also
made by EPA on sealed furnaces in Japan producing 50 percent ferrosilicon,
ferrochrome silicon, and high-carbon ferrochrome/56'

    Union Carbide of Canada has installed and is operating a large sealed
furnace for the production of ferromanganese and silicomanganese,  and
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Interlake Steel Corporation 1s planning a similar Installation 1n Mexico.
The only known sealed furnace for the production of ferromanganese and
silIcomanganese in the United States is operated by Airco Alloys and
Carbide at its Theodore, Alabama, plant.

    Conclusions
    Ferroalloy manufacturers compete in the world market not only for the
sale of ferroalloys, but for ores and other raw materials as well.  Since
foreign producers economically make a variety of ferroalloys in sealed
furnaces using raw materials also available to the United States ferroalloy
industry, it must be concluded that use of sealed furnaces is technically
feasible in the United States and that sealed furnaces are "demonstrated
technology."
B.   Issue 2.  Does the Use of Sealed Furnaces Present a Safety Hazard?

     The United States ferroalloy industry has stated that sealed furnaces are
unsafe for the following reasons^57)' ^58^

     1.  Fusion or bonding together of the raw material charge is
        characteristic of production processes for 75 percent ferrosilicon
        and silicon metal.  Similar behavior, but to a lesser degree, can
        occur in the production of the high-silicon grades of ferrochrome
        silicon and silicomanganese.  Silicomanganese operations may be
        subject to "slag boils" where the charge materials become crusted
        over with slag which prevents uniform descent of the feed material
 118

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    within the furnace.  Such fusion or crusting of materials requires
    the use of open furnaces to permit the charge to be "stoked" to
    allow Its uniform descent and uniform evolution of gas formed by
    the reduction of the ores.

2.  Moisture from water in the charge or from water leaks in furnace
    components can result in an explosive-type gas release which may
    lift the furnace cover and eject a major portion of the furnace
    contents.

3.  Production of high-silicon ferrosilicon and silicon metal is
    characterized by high-temperature gas "blows," generally in the
    vicinity of the electrodes.  Jets of hot gas originate directly
    from the high-temperature zones of the furnace near the bottom of
    the electrodes.  Hot as a cutting torch, they can destroy furnace
    components.

4.  Scrap steel is normally used for the domestic production of
    ferrosilicon alloys.  Such a highly conductive raw material
    can short out the electrodes through the charge chutes, causing
    component damage and water leaks if sealed furnaces are used.
5.  The sealed furnaces generate carbon monoxide, a hazard to personnel.
    In open furnaces, the carbon monoxide is combusted to carbon dioxide
    with ingested air at the hot surface of the charge material.
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     Discussion
     The  preceding items were  investigated  during  the  development  of  standards
 of performance for the industry with  results  as follows:

     1.   The  problems  of slag  boils  and  crusting or  bridging of the furnace
         charge constituents are more  commonly associated with production
         of the high-silicon (> 75 percent) ferroalloys.  These problems
         are  no longer considered serious for  the  production of calcium
         carbide,  ferromanganese, and  silicomanganese  in sealed
         furnaces.(59)' (60)>  (61)>  <62>  "Enclosed  furnaces are being
         used increasingly where raw materials do  not  collect to build
         bridges within the furnace, but instead sink  evenly of their own
         accord.   Examples include the production  of pig iron, carbide,
         and the ferroalloys ferromanganese and silicomanganese."^63^
        In a meeting with EPA engineers, a representative of one major
        ferroalloy producer in the United States  stated that properly
        operated sealed furnaces producing ferromanganese, silicomanganese,
        and calcium carbide are no more dangerous  than equivalent open
        furnaces producing these products.
    2.   EPA engineers discussed with personnel of foreign plants  the
        danger of explosions from water contained  in the feed or from
       water leaks.  Foreign  industry personnel  state that they  feel
       safe  working around a  sealed furnace  and  that working conditions
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    are vastly improved by them.^64'* '65'  They elaborated that
    fatalities are not unique to sealed furnaces; injuries and
    fatalities have also been caused by expulsion of the charge
    from open furnaces during gas "blows.
                                         ,,(66)
    Explosions did occur during early development of sealed furnace
    technology, but this type of hazard has been overcome with increased
    knowledge of the operation and design of closed furnaces.  Such
    incidents are precluded by:'67)' (68>> (69>> (70>> <71>» ™

    a.  Where necessary, proper pretreatment of furnace charge materials.

    b.  Proper design of the furnace and its charging system.

    c.  Proper monitoring of the process.  This may involve monitoring:
        (1) furnace feed and product rates; (2) chemical  compositions
        of furnace feed, product and slag; (3) furnace temperatures;
        (4) moisture content of charge material; (5) furnace power
        consumption; (6) furnace off-gas chemical composition, and
        possibly other furnace operating parameters.

3.  It is generally agreed that the technology has not been developed
    to produce silicon metal and ferrosilicon which contains greater
    than 75 percent silicon in sealed furnaces.  However, a Japanese
    manufacturer of electric submerged arc furnaces predicts that silicon
    metal will be produced in sealed furnaces by 1977.
                                                      (73)
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   4.  Scrap steel is normally used by the United States industry for
       the open furnace production of ferrosilicon alloys.  Union Carbide
       is using a semi-enclosed furnace with steel scrap feed to produce
       50 percent ferrosilicon.

       The Japanese use pelletized iron ore as a feed material to their
       sealed furnaces producing 50 percent ferrosilicon and "mill scale"
       to the sealed furnace producing 75 percent ferrosilicon.  They state
       that a reason for this is that large quantities of high-quality
       steel scrap are not available and economics justifies use of the
       Iron ore.

       One reason given by the United States industry for inability to
       use scrap steel in a sealed furnace (although it is used in the
       semi-enclosed furnace) is that it can conduct electricity from the
       electrodes to the mix delivery bins and cause arcing which could
       severely damage furnace components.

   5.  Foreign plants with sealed furnaces use CO alarm
       systems, proper building ventilation and proper maintenance of
       the CO handling system to minimize hazards of this gas.  Semi-
       enclosed furnaces, which present the same CO hazards, have been
       used for years by the United States industry.  Obviously, the
       methods for safely handling CO gas are proven.
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    Conclusions
    The following conclusions are made regarding the safety aspects of
ferroalloy production in sealed furnaces:

    1.   Sealed furnaces for the production of silicomanganese,  ferro-
        manganese, and calcium carbide have been used in foreign countries
        for over 20 years.   When properly  monitored, operated,  and maintained,
        sealed furnaces for the manufacture of those products appear to be more
        dangerous than open furnaces.

    2.   There is no known technology for the production  of ferrosilicon
        with greater than 75 percent silicon in sealed furnaces.

    3.   Production of 50 percent ferrosilicon in sealed  furnaces is being
        safely accomplished in Japan with  iron ores  as a feed material.
        Although no known use of scrap steel  as feed material to a sealed
        furnace exists, it  does appear technically possible.
    4.   The safe handling of carbon  monoxide gas has been accomplished by
        the domestic and foreign ferroalloy industries.

    5.   The Japanese are also safely using sealed furnaces as follows:

        a.   One has produced 75 percent ferrosilicon since about September
            1971.

        b.   One has produced high-carbon ferrochrome since 1971.
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        c.  One has produced ferrochrome silicon since June 1970.

        These are the only known sealed furnaces producing these products.

    6.  The safe production of ferromanganese, silicomanganese and calcium
        carbide in sealed furnaces has been demonstrated.  A standard for
        these products could be recommended based on the sealed furnace.
    Recommendations
    Since the safe production of 50 percent ferrosilicon has been demonstrated
only when using iron ore feed, and since only one sealed furnace each exists
to produce 75 percent ferrosilicon, ferrochrome silicon, and high-carbon
ferrochrome, standards for these products should be based on open furnaces.
Standards for these products should be reviewed as additional experience
with sealed furnaces is accumulated.

C.  Issue 3.  Would a Regulation That Mandates Sealed Furnaces Place the
              United States Industry at an Economic Disadvantage in the
              World Market?
    The United States ferroalloy industry has stated that successful sealed
furnace technology and economics in foreign countries cannot be directly
extrapolated to the domestic industry for the following reasons:^74''

    1.  Sealed furnace operation requires extensive pretreatment of raw
        material.   This may include sintering or pelletizing.
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 2.  Foreign producers have operating schedules and practices which
     allow greater furnace downtime for maintenance.

 3.  The only known sealed furnaces producing 50 percent ferrosilicon
     use iron ore instead of scrap steel.   This is  not economical  in
     the United States where steel scrap is abundant  and cheap.

 4.  A  sealed furnace  is  restricted to production of  one "family"  of
     products.   Unless a  large  captive market for that family exists,
     the United States industry must maintain the flexibility to produce
     a  variety of products  required by rapidly changing  world demands.
 Discussion
 1-   Pretreatment of raw materials.
     Almost all  ferroalloy  producers  pretreat  their raw materials  in
 some way to  obtain smooth  furnace  operation and the desired  quality
 of the  product.(76)»  (77)»  (78>   Pretreatment  processes include crushing,
 sizing, mixing,  drying, sintering, and pelletizing.  Crushing and sizing
 of raw materials are  performed at nearly all ferroalloy plants and for
 all  types of furnaces.  Raw materials are also mixed at nearly all
 ferroalloy plants, regardless of the furnace type,  to meet product
 specifications and to obtain the composition, physical properties,
and  (sometimes) moisture content desirable for safe,  smooth furnace
operation.(79)>  (8°)»  (81)» <82)   Raw materials are often dried for all
three types of furnaces.   Dry feed materials result in reduced off-gas
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volumes and smoother furnace operation.  Sintering and pelletizlng are
less common pretreatment processes.  These could be used 1n conjunction
with any type of furnace, but are most commonly used with foreign sealed
furnaces.  Both pell eti zing and sintering are means of upgrading less
expensive or friable ores which could not otherwise be used in ferroalloy
furnaces because of 'bridging (i.e., charge material fusing to prevent
uniform descent of charge into a furnace's reaction zone), high raw
material losses caused by its entrainment in the furnace gases, and
low porosity which would prevent escape of gases from the reaction zone.
Also, by pell eti zing or sintering dust captured by the air pollution
control system, it can be recycled as feed to the furnace.
    Ferromanganese and silicomanganese are produced in sealed furnaces
without drying, sintering, or pelletizing raw materials.  Such furnaces
were observed in Norway and Belgium by EPA engineers and a representative
of The Ferroalloys Association.
                               ^83^'
                                            EPA  engineers monitored the
 process and measured emissions from two of these furnaces  in Norway,
 one producing  silicomanganese and  the  other  producing  ferromanganese.
 A  sealed  furnace  in the  United States  has produced  ferromanganese and
 silicomanganese without  extensive  material pretreatment.   EPA engineers
 observed  sealed furnaces producing these products  in Japan.  Some used
 drying, sintering, and pelletizing as  pretreatment  processes, while
 others only  performed routine mixing,  crushing, and sizing.
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     The Japanese  sealed  furnace  producing  high-carbon  ferrochrome  uses
 materials  which are  dried,  crushed,  pelletized,  dry roasted,  and then
 "hot charged"  at  900°C to the  furnace.   Pellets  charged  to  the  furnace
 may be  either  "prereduced"  (provided coke  is  added  to  the ore before
 pelletizing) or not.  Cheaper  friable ores are used in this furnace.

     Pretreatment  for the Japanese  sealed furnace producing  ferrochrome
 silicon consists  of  material sizing  and  drying.   No special pretreatment
 of  charge  materials  is performed for the Japanese sealed furnace producing
 75  percent ferrosilicon.  Fine iron  ore  is pelletized  and baked in a shaft
rfurnace prior  to  being fed  to  the  sealed furnaces producing 50  percent
 ferrosilicon.

     Although some sealed furnaces  may be used without  pretreatment
 processes  such as drying, pelletizing, or  sintering, several  reasons
 may favor  such preprocessing:

     a.   Even with the added cost of  preprocessing,  cheap and  abundant
         fine-sized or friable  ores may be  less expensive than the
         relatively expensive lump  ore.   (Use of  friable ores may
         become more common as  world  supplies of  high-grade "lump" ores
         are depleted.)<85>' (86>>  <87>

     b.   Preprocessing ores increases  the product  yield.7'5  ^88^
     c.   Twenty to 35 percent of the  energy supplied to a closed furnace
         can be recovered by fueling  preprocessing equipment such as
                                                                      127

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       dryers, pellet furnaces, and sintering machines with carbon
       monoxide-rich exhaust gas from the furnace.
   d.   Preprocessing may decrease furnace power consumption by as
       much as 10 percent.<9°>- <91>' <92)
   e.   One preprocessing step, sintering, may reduce coke consumption
       and increase furnace thermal efficiency.
                                               (93)
   f.  Preprocessing reduces furnace particulate emissions.   '*
   g.  Preprocessing equipment permits recycle of particulate matter
       collected by emission control equipment.^  ''       (For a
       closed furnace producing ferromanganese, some 21.2 tons of
       particulate may be recovered and recycled for every 100 tons
       of alloy produced.
                         x(96)
2.  Foreign operating practices allow more furnace down-time.
    Personnel at foreign installations who have experience with all
three types of furnaces state that maintenance requirements are no
greater for sealed furnaces than for other types of comparable
size/97^' ^98^J ^"'  "Due to the heat from the burning reaction
gases above open furnaces, there has been, throughout the years,
a tendency towards more down-time on these furnaces than on covered
ones, in spite of the Tatter's more complicated equipment.
                                                          ,,(100)
    Operating schedules and practices for installations in foreign
countries do not appear to allow any greater furnace down-time for
128

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maintenance and repair than that experienced at United States
installations.  Company personnel estimate that the sealed furnaces
tested by EPA in Norway operate 97 to 98 percent of the time for the
ferromanganese furnace, and 96.2 to 98.2 percent of the time for the
silicomanganese furnace."  '  Japanese ferroalloy manufacturers
estimate that sealed furnaces producing ferromanganese, silicomanganese,
high-carbon ferrochrome, and ferrochrome silicon operate from 95 to almost
100 percent of the time based on their experience to date.'   '  The
United States ferroalloy industry estimates that normal furnace operating
times in the United States vary from 90 to 95 percent.  A large percentage
of furnace down-time is for maintenance of air pollution control equipment
common to all three types of furnaces.^   '  Maintenance for the much
larger air pollution control equipment on open furnaces should far
exceed that for similar equipment on totally enclosed furnaces,
primarily because the open-furnace equipment must handle gas volumes
typically 50 times larger.
3.  Sealed furnaces producing 50 percent ferrosilicon are charged with
    iron ore.  Use of ore is not economical in the United States"
    The two known sealed furnaces which produce 50 percent ferrosilicon
(located in Japan) use iron ore as a feed material instead of the scrap
steel feed normally used by the United States industry.  The United States
ferroalloy industry used about 270,000 tons of scrap steel for the
production of 50 percent ferrosilicon and about 500,000 tons of scrap
steel for the production of all grades of ferrosilicon in 1972.  Their
reasons for using steel scrap rather than iron ore are as follows:
                                                                        129

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    a.  Steel scrap turnings have historically been  abundant  and low
        priced.  (They are the lowest cost iron sources  for United States
        ferrosilicon production.)
    b.  The use of steel  scrap results in less electrical  energy and
        coke consumption  than if iron ore or mill  scale  were  used.
    c.  Because of decreased charge resistance, furnace  production
        capacity is greater with steel scrap than  with iron ore or
        mill scale.  This increased capacity is equivalent to about
        60,000 tons per year of 50 percent ferrosilicon  which has
        a value of about  $9,600,000.

    d.  The type of scrap steel used for ferroalloy  production is
        not suitable for recycling to new steel and, if  not used
        for ferroalloys,  would add to the solid waste disposal problem.

    e.  Delivered price is high for the select grades of iron ore
        required to produce 50 percent ferrosilicon.
    In discussions with Japanese ferroalloy producers, EPA engineers
asked if use of the sealed furnace for producing 50  percent ferrosilicon
would preclude the use of scrap metal and how the  use of iron ore affected
the economics of production.  They answered that the use of iron ore  in
a sealed furnace is economically better than the use of  scrap steel and
that this is true in the United States as well  as Japan because:
130
                                                               .(105)

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    a.  Japan has to import Iron ores while the United States has
        natural iron ore resources.

    b.  Iron ore assures a more stable furnace operation.

  „  c.  Iron ore provides easier control against product impurities
        in production of 50 percent ferrosilicon compared to scrap
        steel.<106>

     Although no unequivocal  conclusion can be drawn from the above,  it
appears that scrap steel has the economic advantage as a raw material
for 50 percent ferrosilicon production in the United States.

4.  Sealed furnaces do riot have the flexibility necessary to produce
    a variety of products.
    Manufacturers of ferroalloy products and manufacturers of ESA
furnaces stated the following:

    a.  For a given furnace design, only certain products can be
        economically manufactured, regardless of whether the furnace
        construction is the open or totally enclosed type.  It is not
        economical to dejsign and use a large ESA ferroalloy furnace for
        several product lines.  To do so requires movable electrodes and
        multiple transformer capacities, since combinations of raw
        materials differ in resistivity for different ferroalloy products.
        Consequently, crucible size, electrode spacing, and transformer
        size are a function of the product being manufactured.  Therefore,
                                                                       131

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        to minimize  capital  investment  in the transformer, to reduce
        down-time  for changeover  (moving electrodes, etc.), to reduce
        waste  produced by  a  furnace, and to optimize furnace efficiency,
        companies  design furnaces for manufacture of only one family
        of products.   Within those  families, it  is  possible to switch
        products  in  a totally enclosed  furnace just as readily as in
        an open furnace.   For products  outside of the design family of
        products,  however, the furnace  must undergo substantial  re-
        construction for  changing  the electrode  spacings.  On a  sealed
        furnace this change requires replacement of the  furnace  cover.
        This reconstruction of sealed furnaces to produce other  products
        is prohibitively  expensive. Modification of an  open furnace to
        produce another family of products requires replacement  of the
        hood.  The costs  for changing from one product family to another
        for  open  furnaces  is significantly less  than those for sealed
        furnaces.   Limited product flexibility could ultimately  result
        in  decreased intercorporate competition.

    b.  In  order  to  remain  competitive, manufacturers of
        ferroalloy products are converting to use of larger
        furnaces. 007), 008), (109),   (110)   New fem)alloy furnaces
        will probably be 30 Mw or  larger because large furnaces  require
        less labor,  less raw material  and less electric power per ton
        of product.  In most cases, the large furnace  also  requires
        a lower capital investment per ton of production.
132

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Conclusions
Based on the Information available, the following conclusions are made:

1.  a.  Ferromanganese and silicomanganese can be safely and economically
        produced in sealed furnaces with or without substantial pre-
        treatment of feed material.

    b.  Calcium carbide can be safely produced in sealed furnaces without
        additional pretreatment beyond that already performed by domestic
        producers.
     c.  For products other than those listed in (a) and (b) above,
         foreign manufacturers use varying levels of feed pretreatment,
         but can safely and economically produce 50 percent ferrosilicon,
         75 percent ferrosilicon, high-carbon ferrochrome, and ferro-
         chrome silicon in sealed furnaces.
  2.   The argument  that maintenance requirements  and operating  schedules
      of foreign manufacturers  are significantly  different from those of
      domestic  users seems  unfounded.
  3.   There appear to  be  several  economic  advantages for the  United States
      industry  to  use  steel  scrap rather than  iron  ore  for the  production
      of ferrosilicon.
  4.  It appears that the use of sealed furnaces would place the
      domestic industry at a competitive disadvantage in the world
      market by restricting the flexibility of new furnaces to respond
      to fluctuating market demands.
                                                                        133

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 Recommendations
      It is  recommended that the standards of performance allow open
 furnaces  to be used in conjunction with the best available control
 equipment.   Although sealed furnaces  are superior from an air  pollution
 control  aspect, restricting the industry to this process could ultimately
 result in limited product  flexibility and possible decreased intercorporate
 competition.   The disadvantages arising from decreased competition out-
 weigh  the incremental  benefits  of  the additional  reduction in  air
 pollution.   EPA's Control  Systems  Laboratory is  further  investigating the
 technical and  economic feasibility of using sealed furnaces to produce all
 types  of  ferroalloys.   This  study  could  ultimately result  in standards of
 performance based on sealed  furnaces.
134

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                            XII.  REFERENCES
A.  Cited References
    1.  Webster's Third International Dictionary, 6.  C. Merriam Company,
        Springfield, Massachusetts, 1966.
    2.  Fisher, Frank L., "Ferroalloys," Minerals Yearbook, Volume 1,
        Bureau of Mines, United States Department of Interior, 1971.
    3.  Environmental Protection Agency - The Ferroalloys Association
        Cooperative Study, Air Pollution Control Engineering and Cost
        Study of the Ferroalloy Industry, draft document, January 21,
        1974, p. II-l.
    4.  Data from  Department of Commerce, Bureau of  the Census Annual
         Survey  of  Manufacturers,  SIC number  3313, 1971.
    5.   "National  Air  Quality  Standards  Act  of  1970,"  Report  of the
         Committee  on  Public  Works, United States Senate,  Report No.
         91-1196,  September 17,  1970, p.  16.
     6.   Vandegrift, A. E., et  al., "Particulate Air  Pollution in  the United
         States," Journal  of the Air Pollution Control  Association.  June  1971,
         p. 321-328.

     7.  Ref. 3, p. 11-10.
     8.  Ref. 3, p. V-9.
     9.  Ref. 3, p. VI-8.
                                     135

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10.  Ref. 3, p. VI-48.

11.  Ref. 3, p. VI-11 to VI-41.
12.  Ref. 3, Appendix E, p. 1-75.

13.  Ref. 3, p. VI-47.

14.  Coetzee, J. J., and Smit, N., "The Production of Ferroalloys,"
     presented at the Commonwealth Mining and Metallurgical  Congress,
     1961, p. 1047.

15.  Elutin, V. P., et al., "Production of Ferroalloys Electrometallurgy,"
     2nd edition, Washington, D. C., National Science Foundation  and
     Department of the Interior (translated from Russian by  the Israel
     Program for Scientific Translations, 1957).
16.  Person, R. A., "Control of Emissions from Ferroalloy Furnace
     Processing," Journal  of Metals, April 1971, p. 19.

17.  Duncan, L. J., "Analysis of Final  State Implementation  Plans - Rules
     and Regulations," APTD-1334, EPA Contract No. 68-02-0248,  July 1972,
     p. 30.

18.  Ref. 16, p. 20.

19.  Ref. 3, p, VI-26.

20.  Ref. 16, p. 24.
136

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21.  Letter from Mr. Richard D. Turner, Chromium Mining and Smelting
     Corporation, to Mr. John Quarles, EPA, November 15, 1973.

22.  Ref. 3, p. VII-16.
23.  Environmental Protection Agency, "Ferroalloy Manufacturing Point
     Source Category - Effluent Limitations Guidelines and Standards,"
     Federal Register, 39 (37):  6806-6812, February 22, 1974.

24.  Ref. 21.
25.  Durkee, Kenneth R., EPA,  International Trip Report, "Survey
     of  Japanese  Ferroalloy Furnaces," August 9, 1973, p. 1-48.

26.  Ref. 16,  p.  28.
27.  Ref. 3, Chapters  I-X, Appendices A-G.
28.  Ref. 3, p.  VI-48.

29.  Ref. 25.
30.  Kelly,  Winton  E., "Emissions  from Electric  Arc  Ferroalloy  Furnaces
     at  Elkem  A/S Porsgunn  Elektrometallurgiske, PEA,"  Porsgunn,  Norway,
     EPA Project No.  72-PC-15, June  1973,  Table  II1-4.

 31.  Ref.  6.
 32.  Ref.  3, Appendix E,, p.  1-75.
                                                                        137

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 33.   Sullivan,  Ralph  J.,  "Preliminary Air  Pollution Survey of Manganese
      and  its  Compounds,"  prepared  for U. S. Department of Health,
      Education  and Welfare  under Contract  No. PH 22-68-25, October 1969,
      p. 1-10.

 34.   Fredriksen, H.,  "Pollution Problems of the Norwegian Ferroalloy
      Industry," Reprint No. 3197,  KJEMI. No. 1, 1972.  (EPA Translation
      No. TR 1677.)

 35.   "Pollution Problems by Electric Furnace Ferroalloy Production,"
      prepared by SINTEF, the Engineering Research Foundation at the
     Technical University of Norway, for the Royal Norwegian Department
     of Industry, September 28, 1968, p. 1-17.

 36.  Horiguchi, et a!., "A Survey on the Actual  Conditions of Factories
     Handling Manganese Compounds," Sangui  Igaku (Japanese Journal  of
     Industrial Health), 8_ (6):  19-28,  June 1966, APTIC Translation
     No. TR 1525.

37.  Manganese, prepared by Panel  on Manganese,  Committee on Biologic
     Effects of Atmospheric Pollutants,  National  Academy of Engineering,
     under EPA Contract No.  68-02-0542,  1973, Chapter 11,  p.  205-211.
38.  "Mineral  Facts  and Problems,"  Bureau of Mines Bulletin 650,  1970
     Edition,  p. 245.
39.  Ref.  3,  p.  III-9.
 138

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40.  Environmental Protection Agency, "Standards of Performance for
     New Stationary Sources," Federal Register, 36 (247):   24882-24895,
     December 23, 1971.
41.  Japanese Industrial Standard JIS-8808-1970, "Methods  of Measuring
     Dust Content in Stack Gas," revised June 1970.

42.  Dobryakov, G. G., et al., "Operation of a Gas-Cleaning System
     on a Closed-Top Electric Furnace," Steel in the USSR, May 1971,
     p. 2.
43.  "Air Pollution Control Technology and Costs in Nine Selected Areas,"
     prepared by  Industrial Gas Cleaning Institute under EPA Contract
     No. 68-02-0301, September 30,  1972.
44.  Letter from George A. Watson,  The Ferroalloys Association, to
     Kenneth R.  Durkee, EPA,  March  18, 1974.
 45.  Letter from D.  J. Maclntyre, Manager, Environmental Affairs,  Union
     Carbide Canada, Limited, to  Paul  A. Boys,  EPA, March  9,  1973.

 46.   Ref.  25, p. 20.

 47.  Ref.  5, p.  5-17.
 48.  Lorck, K., "The Development of the Elkem Covered Rotating Furnace
      for the Production of Carbide and Ferro-alloys," reprint from
      proceedings of Hie Congres International D'Electro Thermie,
      Paris, May 18-23, 1953, p. 1-7.
                                                                        139

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 49.  Bacalu, Ph., and Burzzone, G., "A Study of the Principal
      Characteristics of a High Powered Carbide Furnace," from the
      report presented at the V International Congress on Electro-Heat,
      Wiesboden, Germany, 1963 (EPA Translation No. TR 1864),  p.  1-19.
 50.  Ref. 34, p. 25.

 51.  Ref. 30.

 52.  Durkee, Kenneth R., EPA, International  Trip Report,  "Tests  of
      Ferroalloy Furnaces in  Norway," April  2,  1973.
 53.  Ref. 25.

 54.  "Tanabe,  Electric Reduction  Furnaces Reference  List,"  informational
      brochure of Tanabe  Kakoki  Company, Ltd., Tokyo, Japan.
 55.   Ref.  25.

 56.   Seiffert,  Randy D.,  EPA, International Trip Report, "Testing of
      Japanese  Ferroalloy  Plants," April 5, 1974.

 57.   Letter with  attachments from George A. Watson, The Ferroalloys
     Association, to Stanley T. Cuffe, EPA, May 9, 1973.

 58.  Letter from George A. Watson, The Ferroalloys Association, to
     Stanley T. Cuffe, EPA, April 25, 1973.
59.  Ref. 34, p. 6-7.

60.  Ref. 25.
140

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61.  Rosserayr, Lars, "Manganese Alloy Production in a Large Submerged
     Arc Furnace," Electric Furnace Proceedings, 1970, p. 121-123.

62.  Hooper, Rex T., "The Production of Ferromanganese," Journal of
     Metals, May 1968, p. 88-92.

63.  Ref. 34, p. 6-7.

64.  Ref. 25.

65.  Ref. 34, p. 3.

66.  Ref. 25.

67.  Ref. 25.

68.  Ref. 61.

69.  Ref. 62.

70.  Kanoh, Yasuhisa, "Solid State Reduction of Chrome Ores," Ferroalloys
     Special Issue, published by Metal Bulletin Limited, London, England,
     1971, p. 82-85.

71.  Naruse, W., "Production by the Sintering Process," Ferroalloys Special
     Issue, published by Metal Bulletin Limited, London, England, p.  86-90.

72.  Tada, Y., et al., "On 50 Percent Eutectic Ferrosilicon and Refining
     It In Closed Furnaces," Ferroalloys, 19 (1):  1-5, 1970 (EPA
     Translation No. TR 362-73).

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73.  Salto, Fred, "Self-taught Amateur Now Leading Ferroalloy Architect,"
     ferroalloys section of American Metal Market, May 23,  1973.

74.  Ref. 57.

75.  Ref. 58.

76.  Ref. 35, p. 8.

77.  Ref. 49.

78.  Ref. 3, p. VI-13 to VI-18.

79.  Ref. 62.

80.  Ref. 61.

81.  Ref. 30.

82.  Ref. 3, p. V-12 to V-13.

83.  Ref. 52.

84.  Dealy, James 0. and Kill in, Arthur M., International  Trip Report,
     "Observation of Covered Ferroalloy Furnaces Operating in Belgium
     and Norway," 1972.

85.  Ref. 25, p. 13 and 40.

86.  Ref. 14, p. 1046.
 142

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 87.  Naruse, W., op. cit., p. 86-90.



 88.  Hooper, R. T.t "Australian Industry," Ferroalloys Special Issue,


      published by Metal Bulletin Limited, London, England, 1971,

      p. 114-118.



 89.  Ref. 16, p. 28.



 90.  Ref. 70, p. 84-85.



 91.  Ref. 71, p. 86-92.



 92.  Ref. 25, p. 13, 23, 35, 40.



 93.  Ref. 71.



 94.  Ref. 88.



 95.  Ref. 25, p. 11, 12, 14, 20.



 96.  Ref. 14, p. 86-90.



 97.  Ref. 25.



 98.  Ref. 52.



 99.  Ref. 56.



100.  Schanche, C. H.,  et al., "Todays Trend Towards Larger Electric


      Smelting Furnaces - Some Features in Design and Operation,"
                              i,
      presented at the  24th Electric Furnace Conference of the American
                                                                      143

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      Institute of Mining, Metallurgical, and Petroleum Engineers,
      Philadelphia, Pennsylvania, December 7, 1966;  reprint from the
      Journal of Metals. 1967.

101.  Letter from Mr. P. H. Hynne, El kern A.S., Porsgunn,  Norway, to
      Mr. Kenneth R. Durkee, EPA, November 2, 1972.

102.  Ref. 25.
103.  Ref. 61.
104.  Ref. 58.
105.  Ref. 25, p. 39.

106.  Ref. 72.

107.  Ref. 100.
108.  Ref. 61.
109.  Ref. 54.

110.  Saito, F., "Japan Becoming Major Exporter of Ferroalloy Furnaces,
      Equipment," American Metal Market. Vol. LXXVIII-35,  February  22,  1971

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B.  General References

    1.  "Trends 1n the Use of Ferroalloys by the Steel  Industry of the
        United States," a report of the National Advisory Board,  Washington,
        D. C., PB-204-142, July 1971.

    2.  "JIS Handbook, 1972,  Ferrous Materials and Metallurgy," Japanese
        Standards Association,  Tokyo,  Japan, 1972.

    3.  Environmental  Protection Agency - The Ferroalloys Association
        Cooperative Study,, Air  Pollution Control Engineering  and  Cost
        Study of the Ferroalloy Industry, draft document, January 21, 1974.

    4.  Sandberg, 0.,  and Braaten,  0.,  "Progress in Electric  Furnace Smelting
        of Calcium Carbide and  Ferroalloys," presented at the Vth International
        Congress on Electro-Heat, Weisboden, Germany, 1963.

    5.  Ferrari, Renzo,  "Experiences 1n Developing an Effective Pollution
        Control  System for a  Submerged  Arc Ferroalloy Furnace Operation,"
        Journal  of Metals.  April  1968,  p.  95-104.

    6.  Prochazka,  R.s  "Dust  Measurements  in the Immediate Vicinity of
        Electric Arc Furnaces for Ferro-Alloys," Staub-Reinhalt.   Luft..
        31(9):   8-16,  September, 1971.

    7.  Silverman and  Davidson,  "Electric Furnace  Ferrosilicon  Fume
        Collection," Journal  of  Metals.  December 1955, p. 1327-1335.
                                                                           145

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 8.  Takeshi, N., et al., "Concerning Dust Collection in Metal  Silicon
     Manufacturing," Ferroalloys, 21. (1):   46-57, 1972,  EPA-APTIC
     46141.
 9.  Andersen, H. C., "Some Significant Metallurgical Aspects of Smelting
     Pig Iron in an Electric Furnace," reprint from The  Canadian Mining and
     Metallurgical Bulletin, July 1963.
10.  Hamby,  D. E., "Hollow Electrode System For Calcium  Carbide Furnaces,"
     Journal of Metals, 1_9. (1):  45-48, January 1967.

11.  Sem, M. 0., "Closed Electric Reduction Furnaces Permit Utilization
     of Furnace Gas," Journal of Metals, 6;  3-32, 1954.

12.  Sem, M. 0., and Collins, F. C., "Fume Problems in Electric Smelting
     and Contributions to Their Solution," Journal of the Air Pollution
     Control Association. 5_ (3):  157-8, November 1955.
13.  "Development Document for Effluent Limitations Guidelines  and
     Standards of Performance - Ferroalloys Industry," draft document
     prepared under EPA Contract No. 68-01-1527, June 1973.
 146

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                                    TECHNICAL REPORT DATA
                             (Please read Instructions on the reverse before completing)
 1. REPORT NO.

  EPA-450/2—• 018a
              3. RECIPIENT'S ACCESSION-NO.
 4. TITLE AND SUBTITLE
  Background Information for  Standards of Performance:
  Electric Submerged Arc Furnaces Producing Ferroalloys
  Volume  1, Proposed Standards	
                                                            5. REPORT
                                                              Ve&ober
              6. PERFORMING ORGANIZATION CODE
 7. AUTHOR(S)
                                                            8..PERFORMING ORGANIZATION REPORT NO
 9. PERFORMING ORGANIZATION NAME AND ADDRESS

  U. S.  Environmental  Protection Agency
  Office of  Air Quality Planning and Standards
  Research Triangle Park,  NC   27711
              10. PROGRAM ELEMENT NO.
              11. CONTRACT/GRANT NO.
 12. SPONSORING AGENCY NAME AND ADDRESS
                                                            13. TYPE OF REPORT AND PERIOD COVERED
                                                            14. SPONSORING AGENCY CODE
 15. SUPPLEMENTARY NOTES
  This  volume is the first  in  a series on the  standard of performance  for electric
  submerged arc furnaces producing ferroalloys.   This volume provides  background
  information and the rationale used in the development of the proposed  standard
  of performance.  The economic and environmental  impacts of the standard are
  discussed.
                                KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
                                              b.lDENTIFIERS/OPEN ENDED TERMS
                                                                         c.  COSATI Field/Group
 Air  Pollution, Calcium Silicon
 Pollution Control, Ferromanganese Silicon
 Standards of Performance,  Charge Chrome
 Ferroalloys, Silicomanganese Zirconium
 Silicon  Metal, High-Carbon  Ferrochrome
 50%  Ferrosilicon, Ferrochrome Silicon, Sil\ery  Iron
 65-75% Ferrosilicon, Ferromanganese, Calciim  Carbide
 Air Pollution  Control
 8. DISTRIBUTION STATEMENT
  Unlimtted
19. SECURITY CLASS (ThisReport)'
 Unclassified
21. NO. OF PASE_S
      •-  163
                                              20. SECURITY CLASS (This page)
                                               Unclassified
EPA Form 2220-1 (9-73)
                                             147

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