Fact Sheet Supplemental Proposed Amendments to the Air Toxics Standards for Ferroalloys Production

FACT SHEET
SUPPLEMENTAL PROPOSED AMENDMENTS TO THE AIR TOXICS STANDARDS
FOR FERROALLOYS PRODUCTION
ACTION
• On September 4, 2014, the Environmental Protection Agency (EPA) proposed supplemental
amendments to the air toxics emissions standards covering facilities that produce ferroalloys.
Ferroalloys are compounds that contain iron and other elements such as silicon, and
manganese.
• These proposed amendments supplement EPA's earlier proposal addressing air toxic
emissions from these facilities that was published in the Federal Register in November 2011.
• This supplemental proposal would require ferroalloy production facilities to:
o capture fugitive emissions and route them to control devices;
o meet a tighter opacity limit of 8% to reduce visible emissions;
o meet mercury and polycyclic aromatic hydrocarbons (PAH) emission limits for
silicomanganese and ferromanganese production sources; and
o continue to meet a strengthened particle pollution emission limit that reflects current
performance of control devices in the industry.
• EPA issued the initial air toxics standards for ferroalloy production in May 1999. It currently
covers two existing facilities, one in West Virginia, the other in Ohio. This review of the
standards, known as risk and technology reviews, evaluated:
o If better, new, improved or previously unidentified emission control approaches,
practices or processes were available,
o Whether additional emission reductions were warranted to protect health, and
o If additional changes were needed to assure that the rule was accurate and legally
defensible.
Technology Review
• The Clean Air Act requires EPA to review and revise air toxics standards, as necessary,
taking into account developments in practices, processes, and control technologies since EPA
issued the standards.
• EPA has reevaluated control options for fugitive air toxic metal emissions. Fugitive
emissions come from leaks in process equipment, pipes, and valves rather than stacks or
vents. The Agency has concluded that capturing these emissions, using a combination of
primary and secondary hooding, would be an effective method of control. Primary hooding
involves placing, very close to an emissions source, collection devices (hoods) that would
capture fugitive emissions immediately after they are released. Secondary hoods would be
located higher in the building, near the roofline, to capture the remaining fugitive emissions
that are not captured by the primary hoods.

-------
•	EPA also conducted additional analyses regarding costs and effectiveness of activated carbon
injection for mercury and PAH control.
Residual Risk Assessment
•	The Clean Air Act requires EPA to assess the risk remaining after application of the final air
toxic standards. This is known as a residual risk assessment.
•	The residual risk assessment included the following analyses:
o Estimates of individual source category risk.
o Analysis of air-toxics related risks across different social, demographic and economic
groups living near the facilities,
o Risk estimates based on the actual emissions reported as emitted,
o Risk estimates based on emissions allowed by the current air toxics standards.
•	After assessing the risk from exposure via inhalation and other routes, to toxic air emissions
from ferroalloys production, EPA proposes that the risks are unacceptable based on three
considerations:
1.	The noncancer inhalation hazard quotient range of 4 for actual emissions to 40 for
allowable emissions indicates the potential for the public to be exposed to unacceptable
concentrations of manganese.
2.	The noncancer multipathway hazard quotient of 1 is at the upper end for an acceptable
daily exposure for mercury in fish; and
3.	The lifetime cancer risk estimate ranges from 20-in-l million for actual emissions to 100-
in-1 million for allowable emissions. While 20-in-l million is well within the acceptable
range, risks from allowable emissions are at the upper end of acceptability.
•	The emission controls proposed in this action would lower emissions from fugitive and stack
sources. This would reduce cancer and noncancer risk to acceptable levels and protect public
health with an ample margin of safety.
BACKGROUND
•	In the ferroalloys production source category, there are two main products. Ferromanganese
is a ferroalloy with a high concentration of manganese and iron, and silicomanganese is a
ferroalloy with a high concentration of manganese and silicon. Both products are used in
steelmaking and foundry activities.
•	The Clean Air Act requires the EPA to regulate toxic air pollutants, also known as air toxics,
from large industrial facilities in two phases.
•	The first phase is "technology-based," where EPA develops standards for controlling the
emissions of air toxics from sources in an industry group (or "source category"). These
Maximum Achievable Control Technology (MACT) standards are based on emissions levels
2

-------
that are already being achieved by the controlled and low-emitting sources in an industry.
• Within 8 years of setting the MACT standards, the Clean Air Act directs EPA to assess the
remaining health risks from each source category to determine whether the MACT standards
protect public health with an ample margin of safety, and protect against adverse
environmental effects. This second phase is a "risk-based" approach called residual risk.
Here, EPA must determine whether more health-protective standards are necessary.
• Also, every 8 years after setting the MACT standards, the Clean Air Act requires that EPA
review and revise the standards, if necessary, to account for improvements in air pollution
controls and/or prevention.
• The previously-issued air toxic standards for these production processes are part of 96 air
toxic standards (MACT) that require 174 industry sectors to eliminate 1.7 million tons of 187
toxic air pollutants. Congress listed these toxic air pollutants in the Clean Air Act.
HOW TO COMMENT
• The EPA will accept comment on the proposal for 45 days after publication in the Federal
Register. Comments, identified by Docket ID Number EPA-HQ-OAR-2010-0895 , may be
submitted by one of the following methods:
• Federal eRulemaking Portal: http://www.regulations.gov. Follow the online instructions
for submitting comments.
• Email: A-and-R-Docket@epa.gov. Include Docket ID No. EPA-HQ-OAR-2010-0895 in
the subject line of the message.
• Fax: (202) 566-9744, Attention Docket ID No. EPA-HQ-OAR-2010-0895.
• Mail: Environmental Protection Agency, EPA Docket Center (EPA/DC), Mail Code
28221T, Attention Docket ID No. EPA-HQ-OAR-2010-0895, 1200 Pennsylvania
Avenue, NW, Washington, DC 20460. Please include a total of two copies. In addition,
please mail a copy of your comments on the information collection provisions to the
Office of Information and Regulatory Affairs, Office of Management and Budget
(OMB), Attn: Desk Officer for EPA, 725 17th Street, NW, Washington, DC 20503.
• Hand/Courier Delivery: EPA Docket Center, Room 3334, EPA WJC West Building,
1301 Constitution Avenue, NW, Washington, DC 20004, Attention Docket ID No. EPA-
HQ-OAR-2010-0895. Such deliveries are only accepted during the Docket's normal
hours of operation, and special arrangements should be made for deliveries of boxed
information.
FOR MORE INFORMATION
• Interested parties can download the notice from the EPA's web site at the following address:
http://www.epa.gov/ttn/atw/ferroa/ferropg.html.
3

-------
• Today's proposed rule and other background information are also available either
electronically at http://www.regulations.gov. the EPA's electronic public docket and
comment system, or in hardcopy at the EPA Docket Center's Public Reading Room.
•	The Public Reading Room is located in the EPA Headquarters Library, Room Number
3334 in the EPA West Building, located at 1301 Constitution Avenue, NW, Washington,
DC. Hours of operation are 8:30 a.m. to 4:30 p.m. eastern standard time, Monday through
Friday, excluding Federal holidays.
•	Visitors are required to show photographic identification, pass through a metal detector,
and sign the EPA visitor log. All visitor materials will be processed through an X-ray
machine as well. Visitors will be provided a badge that must be visible at all times.
•	Materials for this proposed action can be accessed using Docket ID Number
EPA-HQ-OAR-2010-0895.
• For further information, contact Phil Mulrine of the EPA's Office of Air Quality Planning
and Standards by phone at (919) 541-5289, or by e-mail at: mulrine.phil@epa.gov.
4

-------