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Regulatory Impact Analysis for the Proposed
National Emission Standards for Hazardous Air
Pollutants: Integrated Iron and Steel
Manufacturing Facilities Technology Review
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EPA-452/R-23-004
June 2023
Regulatory Impact Analysis for the Proposed National Emission Standards for Hazardous Air
Pollutants: Integrated Iron and Steel Manufacturing Facilities Technology Review
U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Health and Environmental Impacts Division
Research Triangle Park, NC
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CONTACT INFORMATION
This document has been prepared by staff from the Office of Air and Radiation, U.S.
Environmental Protection Agency. Questions related to this document should be addressed to the
Air Economics Group in the Office of Air Quality Planning and Standards, U.S. Environmental
Protection Agency, Office of Air and Radiation, Research Triangle Park, North Carolina 27711
(email: OAQPSeconomics@epa.gov).
ACKNOWLEDGEMENTS
In addition to U.S. Environmental Protection Agency staff, personnel from RTI International
contributed research, data, and analysis to this document.
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TABLE OF CONTENTS
Table of Contents v
List of Tables vii
List of Figures ix
1 Executive Summary 1-1
1.1 Introduction 1-1
1.1.1 Legal Basis for this Rulemaking 1-2
1.1.2 Regulatory Background 1-4
1.1.3 Proposed Requirements 1-5
1.1.3.1 Currently Unregulated Fugitive or Intermittent Particulate Sources 1-5
1.1.3.2 Currently Regulated Fugitive Sources 1-5
1.1.3.3 Dioxins/Furans (D/F) and Poly cyclic Aromatic Hydrocarbons (PAH) from Sinter Plants 1-6
1.1.3.4 Fenceline Monitoring 1-6
1.1.3.5 Other Regulatory Gaps 1-7
1.1.4 Economic Basis for this Rulemaking 1-7
1.2 Results for the Proposed Rulemaking 1-8
1.2.1 Baseline and Regulatory Options 1-8
1.2.2 Methodology 1-8
1.2.3 Summary of Cost and Emissions Impacts 1-9
1.3 Organization of this Report 1-11
2 Industry Profile 2-1
2.1 Introduction 2-1
2.2 Iron Making 2-2
2.3 Steel Making 2-4
2.4 Steel Mill Products 2-8
2.5 Uses and Consumers of Steel Mill Products 2-10
2.6 Industry Organization 2-10
2.6.1 Horizontal and Vertical Integration 2-13
2.6.2 Firm Characteristics 2-15
2.7 Market Conditions 2-15
2.7.1 Domestic Production and Consumption 2-15
2.7.2 Prices 2-17
2.7.3 Foreign Trade 2-18
2.7.4 Trends and Projections 2-19
3 Emissions and Engineering Costs Analysis 3-1
3.1 Introduction 3-1
3.2 Facilities and Emissions Points 3-1
3.2.1 II&S Manufacturing Facilities 3-1
3.2.2 Emission Points at Regulated Facilities 3-2
3.2.2.1 Blast Furnaces 3-2
3.2.2.2 Basic Oxygen Process Furnace Shops 3-5
3.2.2.3 Sinter Plants 3-7
3.2.3 Facility Projections and the Baseline 3-8
3.3 Description of Regulatory Options 3-11
3.3.1 Blast Furnaces and Basic Oxygen Process Furnaces 3-11
3.3.1.1 Fugitive Emissions 3-12
3.3.1.2 Other Regulatory Gaps 3-13
3.3.2 Sinter Plants 3-14
3.3.2.1 Dioxins/Furans and Poly cyclic Aromatic Hydrocarbons 3-14
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3.3.2.2 Other Regulatory Gaps 3-14
3.3.3 Fenceline Monitoring 3-15
3.3.4 Summary of Regulatory Alternatives 3-15
3.4 Emissions Reduction Analysis 3-15
3.4.1 Baseline Emissions Estimates 3-15
3.4.2 Projected Emissions Reduction 3-16
3.5 Engineering Cost Analysis 3-19
3.5.1 Detailed Impacts Tables 3-19
3.5.1.1 Fugitive or Intermittent Particulate Sources 3-19
3.5.1.2 Sinter Plants 3-21
3.5.1.3 Fenceline Monitoring 3-22
3.5.1.4 Summary of Facility-Level Costs 3-23
3.5.2 Summary Cost Tables for the Proposed Regulatory Options 3-25
4 Human Health Benefits of Emissions Reductions 4-1
4.1 Introduction 4-1
4.2 Health Effects from Exposure to Hazardous Air Pollutants (HAP) 4-1
4.2.1 Manganese (Mn) 4-2
4.2.2 Lead (Pb) 4-2
4.2.3 Arsenic (As) 4-3
4.2.4 Chromium (Cr) 4-3
4.2.5 Dioxins/Furans (D/F) 4-4
4.2.6 Polycyclic Aromatic Hydrocarbons (PAH) 4-4
4.2.7 Other Air Toxics 4-5
4.3 Approach to Estimating PM2.5-related Human Health Benefits 4-5
4.3.1 Selecting Air Pollution Health Endpoints to Quantify 4-6
4.3.2 Quantifying Cases of PM2 s-Attributable Premature Death 4-7
4.3.3 Economic Valuation 4-9
4.4 Monetized PM2.5 Benefits 4-10
4.4.1 Benefit-per-Ton Estimates 4-10
4.4.2 PM2 5 Benefits Results 4-12
4.4.3 Characterization of Uncertainty in the Monetized PM2 5 Benefits 4-14
5 Economic Impact Analysis and Distributional Assessments 5-1
5.1 Introduction 5-1
5.2 Economic Impact Analysis 5-1
5.3 Employment Impacts Analysis 5-4
5.4 Small Business Impact Analysis 5-5
6 Comparison of Benefits and Costs 6-1
6.1 Results 6-1
6.2 Uncertainties and Limitations 6-4
7 References 7-1
8 Appendix A 8-1
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LIST OF TABLES
Table 1-1: Current and Proposed Standards for II&S Facility Emissions 1-10
Table 1-2: Monetized Benefits, Compliance Costs, Net Benefits, Emissions Reductions, and Non-Monetized
Benefits for the Proposed NESHAP Amendments, 2025-2034, Discounted to 2023 (million 2022$)a 1-11
Table 2-1: Steel Type by Metallurgical Content, 2020 2-9
Table 2-2: Global Steel Consumption by Category, 2019 2-10
Table 2-3: II&S Facilities 2-11
Table 2-4: EAF Facilities 2-12
Table 2-5: U.S. Taconite Iron Ore Facility Ownership, Production, and Capacity 2-14
Table 2-6: U.S. Coking Facility Ownership and Capacity 2-14
Table 2-7: Taconite Iron Ore Facility Owner Sales and Employment, 2021 2-15
Table 2-8: U.S. Steel Production, Consumption, and Prices, 2010-2021 (volumes in thousand metric tons) 2-16
Table 2-9: Shipments of Steel Mill Products by Type, 2019 and 2020 2-17
Table 2-10: U.S. Steel Mill Products Imports and Exports, 2010-2021 (thousand metric tons) 2-18
Table 2-11: U.S. Steel Mill Product Imports and Exports by Country, 2019 and 2020 (thousand metric tons) 2-19
Table 3-1: II&S Facilities 3-2
Table 3-2: Summary of Facility Work Practices in Baseline 3-9
Table 3-3: Baseline Emissions Estimates for II&S Blast Furnace and Basic Oxygen Process Furnace Fugitive
Emissions3 3-16
Table 3-4: Baseline Emissions Estimates for II&S Sinter Plant Windboxes3 3-16
Table 3-5: II&S Blast Furnace and Basic Oxygen Process Furnace Fugitive Emission Reductions3 3-17
Table 3-6: II&S Sinter Plant Windbox Emission Reductions from More Stringent BTF Limit for D/F and PAH3 3-17
Table 3-7: Estimated Control from Fugitive Work Practice Standards and Windbox ACI 3-18
Table 3-8: II&S Blast Furnace and Basic Oxygen Process Furnace Fugitive Emission Reductions by Source,
Proposed Option (Tons per Year)3 3-18
Table 3-9: Summary of Total Capital Investment and Annual Costs per Year for Fugitive or Intermittent Particulate
Sources (2022$)3 3-20
Table 3-10: Summary of Total Capital Investment and Annual Costs per Year of the Proposed Option by Facility for
Fugitive or Intermittent Particulate Sources (2022$)3 3-20
Table 3-11: Summary of Total Capital Investment and Annual Costs per Year of the Less Stringent Alternative by
Facility for Fugitive or Intermittent Particulate Sources (2022$)3 3-21
Table 3-12: Summary of Total Capital Investment and Annual Costs per Year of the Proposed Option for Sinter
Plants D/F and PAH (2022S) 3-22
Table 3-13: Summary of Total Capital Investment and Annual Costs per Year of the More Stringent Option for
Sinter Plants D/F and PAH (2022$)3 3-22
Table 3-14: Costs by Year for the Proposed Fenceline Monitoring Requirements (2022$)3 3-23
Table 3-15: Summary of Total Capital Investment and Annual Costs per Year of the Proposed Fenceline Monitoring
Requirements (2022$)3 3-23
Table 3-16: Summary of Total Capital Investment and Annual Costs per Year of the Proposed Amendments
(2022S) 3-24
Table 3-17: Summary of Total Capital Investment and Annual Costs per Year of the Less Stringent Alternative
Options (2022S) 3-24
Table 3-18: Summary of Total Capital Investment and Annual Costs per Year of the More Stringent Alternative
Options (2022$)3 3-25
Table 3-19: Costs by Year for the Proposed Options (2022$) 3-26
Table 3-20: Present-Value, Equivalent Annualized Value, and Discounted Costs for Proposed Options, 2025-2034
(million 2022$) 3-26
Table 4-1: Human Health Effects of PM2 5 and whether they were Quantified and/or Monetized in this RIA 4-7
Table 4-2: II&S Benefit per Ton Estimates of PM2 5-Attributable Premature Mortality and Illness for the Proposal,
2025-2035 ($2022) 4-13
Table 4-3: II&S Benefit Estimates of PM2 5-Attributable Premature Mortality and Illness for the Proposal (million
2022S) • 4-13
Table 4-4: Undiscounted Monetized Benefits Estimates of PM2 5-Attributable Premature Mortality and Illness for the
Proposed Option (million 2022$), 2025-20343-b 4-13
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Table 4-5: Undiscounted Monetized Benefits Estimates of PM2 s-Attributable Premature Mortality and Illness for the
Less Stringent Alternative Option (million 2022$), 2025-2034ab 4-14
Table 5-1: II&S Facility Owner Sales and Employment, 2021 5-2
Table 5-2: Total Annualized Cost-to-Sales Ratios for II&S Facility Owners by Regulatory Alternative 5-3
Table 5-3: Total Capital Investment-to-Sales Ratios for II&S Facility Owners by Regulatory Alternative 5-3
Table 6-1: Summary of Monetized Benefits, Compliance Costs, Net Benefits, and Non-Monetized Benefits
PV/EAV, 2025-2034 (million 2022$, discounted to 2023) 6-2
Table 6-2: Undiscounted Net Benefits Estimates for the Proposed Option (million 2022$), 2025-2034ab 6-3
Table 6-3: Undiscounted Net Benefits Estimates for the Less Stringent Alternative Option (million 2022$), 2025-
2034a 6-3
Table 6-4: Undiscounted Net Benefits Estimates for the More Stringent Alternative Option (million 2022$), 2025-
2034a 6-4
Table 8-1: Summary of the Baseline Emission and Emission Reduction Estimates 8-2
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LIST OF FIGURES
Figure 2-1: The Integrated Steel Making Process 2-2
Figure 2-2: Iron Making Process: Blast Furnace 2-4
Figure 2-3: Steel Making Process: Basic Oxygen Process Furnace and Electric Arc Furnace 2-6
Figure 2-4: Ingot Casting and Continuous Casting 2-8
Figure 2-5: Steel Production and Capacity, 2000-2019 2-20
Figure 2-6: Share of BF/BOPF andEAF Steel in the U.S., 2001-2021 2-20
Figure 3 -1: Diagram of a Blast Furnace 3 -3
Figure 3 -2: Diagram of Blast Furnace Fugitive Emissions 3 -5
Figure 3-3: Diagram of a Basic Oxygen Furnace Vessel 3-6
Figure 3-4: Diagram of the Sintering Process 3-7
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1 EXECUTIVE SUMMARY
1.1 Introduction
The U.S. Environmental Protection Agency (EPA) is proposing amendments to the
National Emission Standards for Hazardous Air Pollutants (NESHAP) for Integrated Iron and
Steel (ll&S) Manufacturing Facilities (40 CFR Part 63, Subpart FFFFF), as required by the
Clean Air Act (CAA). The Il&S source category produces steel from iron ore pellets, coke, metal
scrap and other raw materials using furnaces and other processes. The EPA is proposing this rule
to complete the technology review that was originally promulgated on July 13, 2020, and to
address regulatory gaps in the NESHAP for II&S. This document presents the regulatory impact
analysis (RIA) for this proposed rule.
To complete the required technology review, EPA is proposing standards to address
fugitive emissions from five unmeasured fugitive or intermittent particulate (UFIP) sources,
referred to as "fugitive" sources: Bell Leaks, Unplanned Bleeder Valve Openings, Planned
Bleeder Valve Openings, Slag Pits, and Beaching. Also, we are proposing standards for carbonyl
sulfide (COS), carbon disulfide (CS2), mercury (Hg), hydrochloric acid (HC1), and hydrogen
fluoride (HF) from sinter plants. In addition, we are proposing standards for total hydrocarbons
(THC), HC1, and dioxins/furans (D/F) from blast furnaces (BFs) and basic oxygen process
furnaces (BOPFs). As part of an update to the technology review under 112(d)(6), we are
proposing to: revise the current BOPF 20 percent opacity1 limit to a 5 percent opacity limit along
with specific work practices; revise the current BF 20 percent opacity limit to a 5 percent opacity
limit; and D/F standards for sinter plants. Also under 112(d)(6), we are proposing fenceline
monitoring for chromium (Cr) including a work practice action level for Cr; if a monitor exceeds
that level, the facility must conduct a root cause analysis and take corrective action to lower
emissions.
In accordance with E.O. 12866 (as amended by E.O. 14094) and 13563, the guidelines of
OMB Circular A-4 and EPA's Guidelines for Preparing Economic Analyses (U.S. EPA, 2016),
the RIA analyzes the benefits and costs associated with the projected emissions reductions under
1 "Opacity" is the degree to which emissions reduce the transmission of light and obscure the view of an object in
the background (40 CFR § 63.2). Opacity is measured by EPA Method 9. For more information, see 40 CFR part
60, Appendix A-4 (https://www.law.cornell.edu/cfr/text/40/appendix-A-4_to_part_60).
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the proposed requirements, a less stringent set of alternative requirements, and a more stringent
set of alternative requirements to inform the EPA and the public about these projected impacts.
The benefits and costs of the proposed rule and regulatory alternatives are presented for the 2025
to 2034 time period.
1.1.1 Legal Basis for this Rulemaking
Section 112 of the CAA provides the legal authority for this proposed rule. Section 112
of the CAA establishes a two-stage process to develop standards for emissions of HAP from new
and existing stationary sources in various industries or sectors of the economy (i.e., source
categories). Generally, the first stage involves establishing technology-based standards and the
second stage involves assessing whether additional standards are needed to address any
remaining risk associated with HAP emissions from the source category. This second stage is
referred to as the "residual risk review." In addition to the residual risk review, the CAA requires
the EPA to review standards set under CAA section 112 every eight years and revise them as
necessary, taking into account any "developments in practices, processes, or control
technologies." This review is commonly referred to as the "technology review".
In the first stage of the CAA section 112 standard setting process, the EPA promulgates
technology-based standards under CAA section 112(d) for categories of sources identified as
emitting one or more of the HAP listed in CAA section 112(b). Sources of HAP emissions are
either major sources or area sources depending on the amount of HAP the source has the
potential to emit.2
Major sources are required to meet the levels of reduction achieved in practice by the
best-performing similar sources. CAA section 112(d)(2) states that the technology-based
NESHAP must reflect the maximum degree of HAP emissions reduction achievable after
considering cost, energy requirements, and non-air quality health and environmental impacts.
These standards are commonly referred to as maximum achievable control technology (MACT)
standards. MACT standards are based on emissions levels that are already being achieved by the
best-controlled and lowest-emitting existing sources in a source category or subcategory. CAA
section 112(d)(3) establishes a minimum stringency level for MACT standards, known as the
2 "Major sources" are those that emit or have the potential to emit 10 tons per year (tpy) or more of a single HAP or
25 tpy or more of any combination of HAP. All other sources are "area sources."
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MACT "floor." For area sources, CAA section 112(d)(5) gives the EPA discretion to set
standards based on generally available control technologies or management practices (GACT) in
lieu of MACT standards. In certain instances, CAA section 112(h) states that the EPA may set
work practice standards in lieu of numerical emission standards.
The EPA must also consider control options that are more stringent than the MACT floor.
Standards more stringent than the floor are commonly referred to as beyond-the-floor (BTF)
standards. CAA section 112(d)(2) requires the EPA to determine whether the more stringent
standards are achievable after considering the cost of achieving such standards, any non-air-
quality health and environmental impacts, and the energy requirements of additional control.
For major sources and any area source categories subject to MACT standards, the second
stage in the standard-setting process focuses on identifying and addressing any remaining {i.e.,
"residual") risk pursuant to CAA section 112(f) and concurrently conducting a technology
review pursuant to CAA section 112(d)(6). The EPA is required under CAA section 112(f)(2) to
evaluate residual risk within eight years after promulgating a NESHAP to determine whether
risks are acceptable and whether additional standards beyond the MACT standards are needed to
provide an ample margin of safety to protect public health or prevent adverse environmental
effects.3 For area sources subject to GACT standards, there is no requirement to address residual
risk, but technology reviews are required. Technology reviews assess developments in practices,
processes, or control technologies and revise the standards as necessary without regard to risk,
considering factors like cost and cost-effectiveness. The EPA is required to conduct a technology
review every eight years after a NESHAP is promulgated. Thus, the first review after a NESHAP
is promulgated is a residual risk and technology review (RTR) and the subsequent reviews are
just technology reviews.
The EPA is also required to address regulatory gaps {i.e., "gap-filling") when conducting
NESHAP reviews, meaning it must establish missing standards for listed HAP that are known to
be emitted from the source category. {Louisiana Environmental Action Network v. EPA, 955
F.3d 1088 (D.C. Cir. 2020) {LEAN)). Any new MACT standards related to gap-filling must be
3 If risks are unacceptable, the EPA must determine the emissions standards necessary to reduce risk to an
acceptable level without considering costs. In the second step of the approach, the EPA considers whether the
emissions standards provide an ample margin of safety to protect public health in consideration of all health
information as well as other relevant factors, including costs and economic impacts, technological feasibility, and
other factors relevant to each particular decision.
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established under CAA sections 112(d)(2) and (d)(3) or, in specific circumstances, under CAA
sections 112(d)(4) or (h).
1.1.2 Regulatory Background
II&S manufacturing facilities produce finished steel from iron ore using a process
consisting mainly of a blast furnace (BF), a basic oxygen process furnace (BOPF), and in some
cases sinter production. The blast furnace combines sinter, taconite iron ore pellets, coke, and
limestone and creates a chemical reaction that produces molten iron and slag (a by-product
consisting of lime, silicates, and aluminates). The iron is combined with scrap steel in the basic
oxygen furnace to produce molten steel and slag. The slag is separated from the steel, which is
then poured into a ladle for casting. Sinter plants recover the iron-bearing materials from BF and
BOPF waste products for use in the blast furnace, and also produce limestone and dolomite for
use in the blast furnace.
II&S facilities also include several ancillary processes, such as hot metal transfer,
desulfurization, slag-skimming, and ladle metallurgy, but blast furnaces, basic oxygen furnaces,
and sinter plants are the primary sources of HAP and PM emissions from the source category.
There are eight active II&S facilities in the United States, and three include sinter plants.
The EPA finalized the NESHAP for II&S facilities in 2003 under CAA section 1 12(d).
The standards address emissions of HAP from new and existing sinter plants, blast furnaces, and
basic oxygen process furnace (BOPF) shops using particulate matter (PM) and opacity limits as
surrogates for particulate HAP. Sinter plants also need to meet volatile organic compound (VOC)
emission limits or limit oil content in sinter feed. The EPA amended the NESHAP in 2006 to add
a new compliance option, revise emission limitations, reduce the frequency of repeat
performance tests for certain emission units, add corrective action requirements, and clarify
monitoring, recordkeeping, and reporting requirements.4
In 2020, the EPA finalized the RTR for the source category. The 2020 RTR determined
that risks from the source category were acceptable and provide an ample margin of safety to
protect public health. The RTR did not identify cost-effective technology-based developments
4 A discussion of the monitoring, recordkeeping, and reporting requirements under the Paperwork Reduction Act
(PRA) is included in Section VII. B. of the preamble of the proposed rulemaking.
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that would further reduce HAP emissions beyond the original NESHAP. The EPA, however,
finalized a new requirement to limit mercury (Hg) emissions from scrap metal used in steel
operations. The EPA also finalized amendments to clarify that the standards are applicable
during periods of startup, shutdown, and malfunction and require electronic reporting of
performance test results, notifications of compliance status, and semi-annual reports. The final
2020 amendments also revised several monitoring requirements to increase flexibility.5
1,1.3 Proposed Requirements
The proposed requirements are discussed briefly below. These include standards for
currently regulated and unregulated fugitive sources, dioxins/furans and polycyclic aromatic
hydrocarbons (PAH) from sinter plants, fenceline monitoring, and other standards to address
current regulatory gaps. Each regulated emissions source is discussed in more detail in Section
3.2.
1.1.3.1 Currently Unregulated Fugitive or Intermittent Particulate Sources
EPA is proposing standards to regulate five currently unregulated fugitive or intermittent
particulate (UFIP) emissions sources: BF unplanned bleeder valve openings ("slips"), BF
planned bleeder valve openings, BF and BOPF slag processing, handling, and storage, BF bell
leaks, and beaching of iron from BFs. For slips, EPA is proposing a limit of 5 per year per BF
and specific work practice standards to limit their likelihood. For BF planned bleeder valve
openings, EPA is proposing an 8 percent opacity limit. EPA is proposing a BTF opacity limit for
BF and BOPF slag processing, handling, and storage of 5 percent. For BF bell leaks, EPA is
proposing work practices and a 10 percent opacity action level. Finally, EPA is proposing a
MACT floor limit for fugitive emissions from the beaching of iron from BFs along with work
practices to meet the limit.
1.1.3.2 Currently Regulated Fugitive Sources
EPA is proposing updated requirements for two currently regulated sources: basic oxygen
process furnace (BOPF) shop and blast furnace (BF) casthouse fugitive emissions. The BOPF
shop houses the entire BOPF and auxiliary activities (such as hot iron transfer, skimming, iron
5 Details of the 2020 Integrated Iron and Steel Manufacturing Facilities NESHAP RTR can be found in the Federal
Register publication at the following link: https://www.federalregister.gov/documents/2020/07/13/2020-
09753/national-emission-standards-for-hazardous-air-pollutants-integrated-iron-and-steel-manufacturing.
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desulfurization, and ladle metallurgy operation). The BF casthouse houses the lower portion of
the BF and encloses the tapping operation and the iron and slag transport operations. Currently,
fugitive emissions from BOPF shop and BF casthouses are covered by a 20 percent opacity limit.
For BOPF shop fugitive emissions, EPA is proposing a 5 percent opacity limit and
specific work practices (such as optimizing the positioning of collection hoods and using higher
draft velocities to capture more fugitives). BOPF shop fugitives are likely the largest contributor
of Cr+6 emissions at II&S facility fencelines, so facilities may need to install better fugitive
capture systems to meet the fenceline action level for Cr+6 (discussed below in Section 1.1.3.4).
For BF casthouse fugitive emissions, EPA is proposing a 5 percent opacity limit but is not
proposing specific work practices to meet the opacity limit.
1.1.3.3 Dioxins/Furans (D/F) and Polycyclic Aromatic Hydrocarbons (PAH) from Sinter
Plants
EPA is proposing a MACT floor limit for D/F and PAH from sinter plant windboxes.
There are currently no specific requirements for these pollutants, but the current VOC and oil
content limits act as a surrogate standard for these HAP. Three II&S facilities have on-site sinter
plants. These plants currently control windbox emissions using a baghouse or scrubber.6 EPA
anticipates II&S facilities can meet the MACT floor limits for D/F and PAH without installing
additional controls. The only costs of these standards are for additional compliance testing.
1.1.3.4 Fenceline Monitoring
EPA is proposing a fenceline monitoring requirement pursuant to CAA 112(d)(6). The
fenceline monitoring requirement incudes a work practice action level for Cr. If a monitor at a
facility exceeds the action level for Cr, the facility must do a root-cause analysis and take
corrective action to lower Cr emissions. Based on current analyses, BOPF shop fugitive
emissions are likely the largest contributor of Cr at II&S facility fencelines. EPA is also
proposing a sunset provision in the fenceline monitoring requirements: if facilities remain below
6 A "baghouse" is an industrial dust and particulate matter collection and filtration system designed to control air
emissions (see: https://www.epa.gov/air-emissions-monitoring-knowledge-base/monitoring-control-technique-
fabric-filters). A "scrubber" is a device designed to remove pollutants from a gaseous exhaust stream. Scrubbers
can be "wet" or "dry" depending on whether or not water is added to the gas stream. A common design of wet
scrubber is the Venturi scrubber (see: https://www3.epa.gov/ttncatcl/dirl/fventuri.pdf).
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the action level for two full years, they can terminate the fenceline monitoring as long as they
continue to comply with all other rule requirements.
1.1.3.5 Other Regulatory Gaps
EPA has also identified five unregulated HAP from sinter plants (CS2, COS, HC1, HF,
and Hg) and two unregulated HAP from blast furnaces (HC1 and total hydrocarbons (THC)), and
one unregulated HAP from basic oxygen furnaces (THC). EPA is proposing MACT floor limits
for each pollutant and anticipates II&S facilities can meet the limits without installing additional
controls. The only expected costs from these proposed standards are from additional compliance
testing and monitoring, recordkeeping, and reporting requirements.
1,1,4 Economic Basis for this Rulemaking
Many regulations are promulgated to correct market failures, which otherwise lead to a
suboptimal allocation of resources within a market. Air quality and pollution control regulations
address "negative externalities" whereby the market does not internalize the full opportunity cost
of production borne by society as public goods such as air quality are unpriced.
While recognizing that the optimal social level of pollution may not be zero, HAP
emissions impose costs on society, such as negative health and welfare impacts, that are not
reflected in the market price of the goods produced through the polluting process. For this
regulatory action the good produced is steel. If the process of using a blast furnace and basic
oxygen furnace to smelt iron and then manufacture steel pollutes the atmosphere, the social costs
imposed by the pollution will not be borne by the polluting firm but rather by society as a whole.
Thus, the producer is imposing a negative externality, or a social cost from these emissions, on
society. The equilibrium market price of steel mill products may fail to incorporate the full
opportunity cost to society of consuming them. Consequently, absent a regulation or some other
action to limit emissions, producers will not internalize the negative externality of pollution due
to emissions and social costs will be higher as a result. This regulation will work towards
addressing this market failure by causing affected producers to begin internalizing the negative
externality associated with HAP emissions.
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1.2 Results for the Proposed Rulemaking
1.2.1 Baseline and Regulatory Options
The impacts of regulatory actions are evaluated relative to a baseline that represents the
world without the regulatory action. In this RIA, we present results for the proposed amendments
to the NESHAP for II&S manufacturing facilities relative to a world without the proposed
amendments. The proposed amendments set standards for five currently unregulated fugitive
emissions sources, revise standards for two currently regulated sources of fugitive emissions, and
set numerical MACT floor limits for D/F and PAH from sinter plants. EPA is also proposing
fenceline monitoring requirements and setting MACT floor limits for seven currently
unregulated HAP (five from sinter plants and two from BF/BOPF).
Throughout this document, the EPA focuses the analysis on the proposed requirements
that result in quantifiable compliance cost or emissions changes compared to the baseline. We
assume each facility achieves emissions control meeting (and in some cases exceeding) current
standards and estimate emissions reductions and cost relative to this baseline. In cases where a
facility is known to undertake work practices or repairs required by the proposed NESHAP
amendments, this information is incorporated into baseline cost and emissions estimates. For a
discussion of the work practices already in place at facilities and how they affect cost and
emissions impact estimates for the proposed amendments, see the discussion in Section 3.2.3.
We also analyze a less stringent and more stringent alternative regulatory option as compared to
our proposed option in adherence to OMB Circular A-4. The results of this analysis are presented
alongside analysis of the proposed option in Chapter 3.
1.2.2 Methodology
The impacts analysis summarized in this RIA reflects a nationwide engineering analysis
of compliance cost and emissions reductions. The EPA estimated costs and expected emissions
reductions of the proposed and alternative regulatory options for each II&S facility individually
and aggregated them to calculate industry-wide impacts for the rule. We calculate cost and
emissions impacts of the proposed and alternative regulatory requirements over a 10-year
analytical timeframe from 2025 to 2034. This timeframe spans the projected first year of full
implementation of the proposed NESHAP amendments for BF/BOPF fugitive emission sources
(under the assumption that the proposed action is finalized in 2023), and presents 10 years of
1-8
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potential regulatory impacts. We assume the number of active facilities in the source category is
constant over the analysis period.
1,2.3 Summary of Cost and Emissions Impacts
The proposed requirements discussed in Section 1.1.3 are presented in Table 1-1 below.
The proposed amendments to the NESHAP for II&S Manufacturing Facilities (Subpart FFFFF)
constitute a significant regulatory action under E.O. 12866 Section 3(f)(1), as amended by E.O.
14094. This rulemaking is a significant regulatory action because it is likely to have an annual
effect on the economy of $200 million or more in any one year or adversely affect in a material
way the economy, a sector of the economy, productivity, competition, jobs, the environment,
public health or safety, or state, local, territorial or tribal governments or communities.
Specifically, the proposed amendments to HAP fugitive standards under Subpart FFFFF are
projected to reduce HAP emissions by about 79 short tons per year and PM2.5 emissions by about
560 short tons per year. The EPA monetized the projected benefits of reducing PM2.5 emissions
in terms of the value of avoided premature deaths and illnesses attributable to PM2.5. The
equivalent annualized value of monetized benefits related to PM2.5 emissions reductions is
greater than $200 million per year, as seen in Table 1-2.
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Table 1-1: Current and Proposed Standards for II&S Facility Emissions
Emissions Segment
Current Standard
Proposed Standard
Fenceline Monitoring
No Requirement
Requirement with Work Practice
Action Level for Cr
BF Unplanned Bleeder Valve Openings
Work Practices; 5 per year per BF
BF Planned Bleeder Valve Openings
8% Opacity Limit
BF/BOPF Slag Processing, Handling,
and Storage
BF Bell Leaks
No Standard
5% Opacity Limit
Work Practices; 10% Opacity
Action Level
BF Iron Beaching
MACT Floor and Work Practices
BOPF Shop Fugitives
BF Casthouse Fugitives
20% Opacity Limit
5% Opacity Limit and Work
Practices
5% Opacity Limit
Sinter Plant: D/F and PAH
VOC and Oil Content Surrogate
Standard7
MACT Floor
Sinter Plant:CS2, COS, HC1, HF, Hg
BF/BOPF: HC1, THC
No Standard
MACT Floor
Table 1-2 presents projected emissions reductions, health benefits, compliance costs, and
net benefits from the proposed amendments to the NESHAP for II&S facilities. Health benefits,
compliance costs and net benefits are presented in terms of present-value (PV) and equivalent
annualized value (EAV) over the period 2025-2034, discounted back to 2023. The EAV
represents a flow of constant annual values that would yield a sum equivalent to the PV. PM
reductions, some fraction of which are expected to be PM2.5, are expected to occur as result of
implementing the proposed standards for BF/BOPF fugitive emissions sources. The EPA
monetized the projected benefits of reducing PM2.5 emissions in terms of the value of avoided
premature mortality and morbidity to particulate matter; the estimated PM-attributable benefits
are quantified using two alternative estimates of the risk of mortality from long-term exposure to
fine particles. Net benefits are calculated as monetized health benefits minus compliance costs.
7 The current NESHAP standard includes an emission limit for VOC from the sinter plant windbox exhaust stream
or, as an alternative, an operating limit for the oil content of the sinter plant feedstock. The VOC and oil content
limits serve as surrogates for all organic HAP emitted from the windbox.
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EPA did not monetize benefits of HAP reductions or non-health benefits of PM/PM2.5 reductions,
both of which are expected to be positive.
Table 1-2: Monetized Benefits, Compliance Costs, Net Benefits, Emissions Reductions, and
Non-Monetized Benefits for the Proposed NESHAP Amendments, 2025-2034, Discounted
to 2023 (million 2022$8)a
3 Percent Discount Rate 7 Percent Discount Rate
PV EAV PV EAV
$260 $1,700 $220
and and and
$280 $1,700 $230
$4.6 $32 $4.6
$260 $1,700 $220
and and and
$280 $1,700 $230
Emissions Reductions
2025-2034 (short tons)
HAP
790
PM
23,000
PM25
5,600
HAP benefits from reducing 790 short tons of HAP from 2025-2034
Non-health benefits from reducing 23,000 tons of PM, of which 5,600 tons is PM2.5,
from 2025-2034
Visibility Effects
Reduced Ecosystem/Vegetation Effects0
a Totals may not sum due to independent rounding. Numbers rounded to two significant digits unless otherwise noted.
b Monetized benefits include health benefits associated with reducing PM2.5 emissions. The monetized health benefits are
quantified using two alternative concentration-response relationships from the Di et al. (2017) and Turner et al. (2016) studies
and presented at real discount rates of 3 and 7 percent. The two benefits estimates are separated by the word "and" to signify that
they are two separate estimates. Benefits from HAP reductions remain unmonetized and are thus not reflected in the table.
c Adverse effects include terrestrial and aquatic acidification, terrestrial nitrogen enrichment and aquatic eutrophication.
1.3 Organization of this Report
The remainder of this report details the methodology and the results of the RIA. Chapter
2 presents a profile of the steel manufacturing industry. Chapter 3 describes emissions, emissions
control options, and engineering costs. Chapter 4 presents the benefits analysis, including a
qualitative discussion of the unmonetized benefits associated with HAP emissions reductions.
Chapter 5 presents an analysis and discussion of economic impacts. Chapter 6 presents a
comparison of benefits and costs. Chapter 7 contains the references for this RIA. Appendix A
A, JTT $2,300
Monetized Health ,
Benefits'3
cenents $24Q()
Compliance Costs $39
$2,300
Net Benefits and
$2,400
Non-Monetized
Benefits
8 When necessary, dollar figures in this RIA have been converted to 2022$ using the annual GDP Implicit Price
Deflator values in the U.S. Bureau of Economic Analysis' (BEA) NIPA Table 1.1.9 found at found at
. 2022$ reflect all inflation though Q3, the most
recent quarter posted at the time of the analysis.
1-11
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includes summary information on how existing facility work practices have been incorporated
into baseline cost and emission estimates.
1-12
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2 INDUSTRY PROFILE9
2.1 Introduction
This industry profile supports the regulatory impact analysis (RIA) of the proposed
amendments to the NESHAP for II&S mills. Iron is produced from iron ore, and steel is
produced by progressively removing impurities from iron ore and scrap metal. The North
American Industry Classification System code (NAICS) for Iron and Steel Mills and Ferroalloy
Manufacturing is 331110, and all integrated iron and steel manufacturing operations fall within
this classification.
There are two primary methods for manufacturing steel. The first uses a blast furnace to
convert iron ore and other raw materials into molten iron, and then produces steel in a basic
oxygen process furnace (BOPF) using primarily molten iron and scrap metal. This is the
BF/BOPF process, and is the method used by II&S manufacturing facilities. The other method is
the electric arc furnace (EAF), which primarily recycles scrap steel into new steel products. The
United States produced 87 million metric tons of raw steel in 2021, about 29 percent of which
was produced by the BF/BOPF process in II&S facilities. EAF produced the remainder (USGS,
2022a). Steel is a primary input to automobiles, home appliances, and residential construction, so
demand for steel is a derived demand that depends on an array of products.
Figure 2-1 illustrates the four-step production process for manufacturing steel products at
II&S facilities. The first step is iron making. Primary inputs to the iron making process are iron
ore or other sources of iron, coke or coal, and flux. Pig iron is the primary output of iron making
and the primary input to the next step in the process, steel making. Metal scrap and flux are also
used in steel making. The steel making process produces molten steel that is shaped into solid
forms at forming mills. Finishing mills then shape, harden, and treat the semi-finished steel to
yield its final marketable condition.
9 This section is derived in part from the Economic Impact Analysis of Final II&S NESHAP (U.S. EPA, 2002).
2-1
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Figure 2-1: The Integrated Steel Making Process
Iron Ore Coke Flux
Finished Steel Products
Source: U.S. EPA. 2002. Economic Impact Analysis ofFinal II&S NESHAP. Available here:
https://www.epa.gOv/sites/default/files/2020-07/documents/iron-steel_eia_neshap_final_09-2002.pdf
2.2 Iron Making
Blast furnaces are the primary site of iron making at integrated facilities where iron ore is
converted into more pure and uniform iron. Blast furnaces are tall steel vessels lined with
refractory brick. They range in diameter from 20 to 50 feet and in height from 70 to 360 feet.10
Conveyor systems of carts and ladles carry inputs and outputs to and from the blast furnace.
Iron ore, coke, and flux are the primary inputs to the iron making process. Iron ore, which
is typically 50 to 70 percent iron, is the primary source of iron for II&S mills. Pellets are the
primary source of iron ore used in iron making at integrated steel mills. Iron can also be captured
10 https://www.britannica.com/technology/blast-furnace. Accessed 1/26/2023.
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by sintering from fine grains, pollution control dust, and sludge. Sintering ignites these materials
and fuses them into cakes that are 52 to 60 percent iron.
Coke is made in ovens that heat metallurgical coal to drive off gases, oil, and tar, which
can be collected by a coke by-product plant to use for other purposes or to sell. Coke may be
generated by an II&S facility or purchased from a merchant coke producer. Flux is a general
name for any material used in the iron or steel making process that is used to collect impurities
from molten metal. Limestone is commonly used as flux in blast furnaces, in addition to silica,
dolomite, and lime.11
Figure 2-2 shows the iron making process at blast furnaces. Once the blast furnace is
fired up, it runs continuously until the lining is worn away. Coke, iron materials, and flux are
charged into the top of the furnace. Hot air is forced into the furnace from the bottom . The hot
air ignites the coke, which provides the fuel to melt the iron. As the iron ore melts, chemical
reactions occur. Coke releases carbon as it burns, which combines with the iron. Carbon bonds
with oxygen in the iron ore to reduce the iron oxide to pure iron. The bonded carbon and oxygen
leave the molten iron in the form of carbon monoxide, which is the blast furnace gas. Some of
the carbon remains in the iron. Carbon is an important component of iron and steel because it
allows iron and steel to harden when they are cooled rapidly.
Flux combines with the impurities in molten iron to form slag. Slag separates from the
molten iron and rises to the surface. A tap removes the slag from the iron while molten iron,
called hot metal, is removed from a different tap at 2,800 to 3,000°F. Producing a metric ton of
iron from a blast furnace requires about 1.6 metric tons of iron ore, 450 kg of coke (740 kg of
coal), and 120 kg of limestone.12
Hot metal may be transferred directly to steel making furnaces. Hot metal that has cooled
and solidified is called pig iron. Pig iron is typically used in steel making furnaces, but it also
may be cast for sale as merchant pig iron. Merchant pig iron may be used by foundries or electric
arc furnace (EAF) facilities that do not have iron making capabilities. In 2021, blast furnaces in
the United States produced 22 million short tons of pig iron (USGS, 2022a).
11 https://www.britannica.com/technology/flux-metallurgy. Accessed 1/26/2023.
12 https://worldsteel.org/steel-topics/raw-materials/. Accessed 1/26/2023.
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Figure 2-2: Iron Making Process: Blast Furnace
Source: U.S. EPA, Office of Compliance. 1995. EPA Office of Compliance Sector Notebook Project: Profile of the
Iron and Steel Industry. Washington, DC: Environmental Protection Agency.
2.3 Steel Making
Steel making is carried out in basic oxygen process furnaces or in EAFs, while iron
making is only carried out in blast furnaces. Basic oxygen furnaces are the standard steel making
furnace used at integrated mills; EAFs are the standard furnace at mini-mills since they use scrap
metal efficiently on a small scale. Open hearth furnaces were used to produce steel prior to 1991
but have not been used in the United States since that time.
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Hot metal or pig iron is the primary input to the steel making process at integrated mills.
Hot metal accounts for up to 70-75 percent of the iron charged into a steel making furnace.13
Scrap metal is also used, which either comes as waste from other mill activities or is purchased
on the scrap metal market. Scrap metal must be carefully sorted to control the alloy content of
the steel. Direct-reduced iron (DRI) may also be used to increase iron content, particularly in
EAFs that use mainly scrap metal for the iron source. DRI is iron that has been formed from iron
ore by a chemical process, directly removing oxygen atoms from the iron oxide molecules.
Figure 2-3 shows the steel making process at basic oxygen furnaces and EAFs. At basic
oxygen furnaces, hot metal and other iron sources are charged into the furnace. An oxygen lance
is lowered into the furnace to inject high purity oxygen—99.5 to 99.8 percent pure—to minimize
the introduction of contaminants. Some basic oxygen furnaces insert the oxygen from below.
Energy for the melting of scrap and cooled pig iron comes from the oxidation of silicon, carbon,
manganese, and phosphorous. Flux is added to collect the oxides produced in the form of slag
and to reduce the levels of sulfur and phosphorous in the metal. Approximately 30-50 kilograms
of lime are needed to produce a metric ton of steel.14 The basic oxygen process can produce
approximately 220 tons in 45 minutes.15 When the process is complete, the furnace is tipped and
the molten steel flows out of a tap into a ladle.
EAFs have removable roofs so that they can be charged from the top. EAFs primarily use
scrap metal for the iron source, but alloys may also be added before the melt. In EAFs, electric
arcs are formed between two or three carbon electrodes. The EAFs require a power source to
supply the charge necessary to generate the electric arc and typically use electricity purchased
from an outside source. If electrodes are aligned so that the current passes above the metal, the
metal is heated by radiation from the arc. If the electrodes are aligned so that the current passes
through the metal, heat is generated by the resistance of the metal in addition to the arc radiation.
Flux is blown or deposited on top of the metal after it has melted. Impurities are oxidized by the
air in the furnace and oxygen injections. The melted steel should have a carbon content of 0.15 to
0.25 percent greater than desired because the excess will escape as carbon monoxide as the steel
boils. The boiling action stirs the steel to give it a uniform composition. When complete, the
13 https://www.wermac.org/steel/steelmaking.html. Accessed 3/15/2023.
14 https://britishlime.org/technical/iron_and_steel.php. Accessed 1/26/2023.
15 https://www.wermac.org/steel/steelmaking.html. Accessed 1/26/2023.
2-5
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furnace is tilted so that the molten steel can be drained through a tap. The slag may be removed
from a separate tap. The EAF process takes about 60 minutes to complete16.
Figure 2-3: Steel Making Process: Basic Oxygen Process Furnace and Electric Arc Furnace
Basic Oxygea Furnace
Air
Scrap *-
Flux *-
Iron >
Air
Scrap
Electricity
Molten
Steel
Dost/
Sludge
Slag
Source: U.S. EPA, Office of Compliance. 1995. EPA Office of Compliance Sector Notebook Project: Profile of the
Iron and Steel Industry. Washington, DC: Environmental Protection Agency.
Steel often undergoes additional, referred to as secondary, metallurgical processes after it
is removed from the steel making furnace. Secondary steel making takes place in vessels, smaller
furnaces, or the ladle. These sites do not have to be as strong as the primary refining furnaces
' https://www3.epa.gOv/ttncliiel/old/ap42/chl2/s051/reference/ref_02c02s04_2008.pdf. Accessed 1/26/2023.
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because they are not required to contain the powerful primary processes. Secondary steel making
can have many purposes, such as removal of oxygen, sulfur, hydrogen, and other gases by
exposing the steel to a low-pressure environment; removal of carbon monoxide through the use
of deoxidizers such as aluminum, titanium, and silicon; and changing of the composition of
unremovable substances such as oxides to further improve mechanical properties.
Molten steel transferred directly from the steel making furnace is the primary input to the
forming process. Forming must be done quickly before the molten steel begins to cool and
solidify. Two generalized methods are used to shape the molten steel into a solid form for use at
finishing mills: ingot casting and continuous casting machines (see Figure 2-4). Ingot casting is
the traditional method of forming molten steel in which the metal is poured into ingot molds and
allowed to cool and solidify. However, continuous casting currently accounts for greater than 99
percent of steel production (USGS, 2022a). Continuous casting, in which the steel is cast directly
into a moving mold on a machine, reduces loss of steel in processing.
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Figure 2-4: Ingot Casting and Continuous Casting
Molk'ii Steel
Ingot Casting
V7
->¦ Process Water
->¦ Scale
ooo
o o o
~ ~
Continuous Casting
Semi-Finished Steel
Source: U.S. EPA, Office of Compliance. 1995. EPA Office of Compliance Sector Notebook Project: Profile of the
Iron and Steel Industry. Washington, DC: Environmental Protection Agency.
2.4 Steel Mill Products
Carbon steel is the most common type of steel by metallurgical content (see Table 2-1).
By definition, for a metal to be steel it must contain carbon in addition to iron. Increases in
carbon content increase the hardness, tensile strength, and yield strength of steel but can also
make steel susceptible to cracking. Alloy steel is the general name for the wide variety of steels
that manipulate alloy content for a specific group of attributes. Alloy steel does not have strict
alloy limits but does have desirable ranges. Some of the common alloy materials are manganese,
phosphorous, and copper. Stainless steel must have a specific mix of at least 10.5 percent
2-8
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chromium, less than 1.2 percent carbon and other alloying elements, and at least 50 percent
iron.17
Table 2-1: Steel Type by Metallurgical Content, 2020
Thousand Metric Tons
Percent
Carbon Steel
73,200
93%
Stainless Steel
2,480
3%
All Other Alloy Steel
2820
4%
Total
78,500
100%
Source: United States Geological Survey (USGS). 2020. Iron and Steel [table-only release]. Metals and Minerals:
USGS Minerals Yearbook 2020, volume 1. Available at: https://d9-wret.s3.us-west-
2.amazonaws.com/assets/palladium/production/s3fs-public/media/files/mybl-2020-feste-adv.xlsx.
Semi-finished steel forms from the casting process are passed through processing lines at
finishing mills to give the steel its final shape. At rolling mills, steel slabs are flattened or rolled
into pipes. At hot strip mills, slabs pass between rollers until they have reached the desired
thickness. The slabs may then be cold rolled in cold reduction mills. Cold reduction, which
applies greater pressure than the hot rolling process, improves mechanical properties,
machinability, and size accuracy, and produces thinner gauges than possible with hot rolling
alone. Cold reduction is often used to produce wires, tubes, sheet and strip steel products.
After the shape and surface quality of steel have been refined at finishing mills, the metal
often undergoes further processes for cleansing. Pressurized air or water and cleaning agents are
the first step in cleansing. Acid baths during the pickling process remove rust, scales from
processing, and other materials. The cleaning and pickling processes help coatings to adhere to
the steel. Metallic coatings are frequently applied to sheet and strip to inhibit corrosion and
oxidation, and to improve visual appearance. The most common coating is galvanizing, which is
a zinc coating. Other coatings include aluminum, tin, chromium, and lead. Semi-finished
products are also finished into pipes and tubes. Pipes are produced by piercing a rod of steel to
create a pipe with no seam or by rolling and welding sheet metal.
Slag is generated by iron and steel making. Slag contains the impurities of the molten
metal, but it can be sintered to capture the iron content. Slag can also be sold for use by the
cement industry, for railroad ballast, and by the construction industry.
17 https://www.aperam.com/stainless/what-is-stainless-steel/. Accessed 1/16/2023.
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2.5 Uses and Consumers of Steel Mill Products
Table 2-2 shows world steel consumption over a variety of categories. Building and
infrastructure construction accounts for more than half of global steel consumption. The
automotive industry is the largest end-user of domestic steel produced by II&S facilities,
accounting for about 43 percent of U.S. Steel steel shipments and 40 percent of Cleveland-Cliffs
Inc.'s total revenue (as discussed in the next section, these two firms own all II&S facilities in
the U.S.),18 excluding sales to steel wholesalers and converters, with construction for the next
largest share of each firm's sales. Since steel demand is derivative of demand for automobiles
and construction, sales of U.S. steel manufactures sales are particularly responsive to underlying
changes in underlying macroeconomic conditions.
Table 2-2: Global Steel Consumption by Category, 2019
Category Share
Buildings and Infrastructure 52%
Automotive 12%
Metal Products 10%
Mechanical Equipment 16%
Other Transport (inc. airplanes and trains) 5%
Domestic Appliances 2%
Electrical Equipment 3%
Source: https://worldsteel.org/about-steel/steel-facts/. Accessed 1/26/2023.
2.6 Industry Organization
There are currently eight II&S manufacturing facilities in the United States. These
facilities are all in the midwestern United States, across five states: three in Indiana, two in Ohio,
and one each in Illinois, Michigan, and Pennsylvania. A ninth facility, the Great Lakes Works in
Ecorse, Michigan (owned by U.S. Steel) closed its primary iron and steel manufacturing
operations in 2019 (the facility still maintains some secondary operations).19 The facilities range
in steel capacity from 2.5 to 7.5 million metric tons per year. Three II&S facilities use on-site
sinter plants: Burns Harbor Works, Indiana Harbor Works, and Gary Works. The Dearborn
18 Source: U.S. Steel Corporation Form 10-K 2022 and Cleveland-Cliffs Inc. Form 10-K 2022
19 https://www.cnn.eom/2019/12/20/business/us-steel-mill-
closing/index.html#:~:text=The%20mill%2C%20called%20the%20Great,be%201ost%2C%20the%20company%
20said. Accessed 6/8/2023.
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Works permanently idled their hot strip mill, anneal, and temper operations in 2020.20 Table 2-3
lists these facilities. The number of II&S facilities is down from 20 (owned by 14 firms) (U.S.
EPA, 2001) in 2001. Cleveland-Cliffs Inc. facilities account for 59 percent of II&S capacity and
U.S. Steel facilities account for the remaining 41 percent. There are also 88 EAF facilities owned
by 36 firms. Since Cleveland-Cliffs Inc. and U.S. Steel own both II&S facilities and EAF
facilities, there are 96 steel manufacturing facilities owned by 36 firms. EAF facilities require
lower initial capital investment (IEA, 2020) and can thus operate cost-effectively at much
smaller scales than integrated facilities. This may impact the organization and ownership
diversity of EAF facilities relative to integrated facilities.
Table 2-3: II&S Facilities
Ultimate Parent Company
Facility
Location
Steel Capacity
(million metric
tons/year)
Sinter Plant
Burns Harbor Works
Burns Harbor, IN
5
Yes
Cleveland Works
Cleveland, OH
3
No
Cleveland-Cliffs Inc.
Dearborn Works
Dearborn, MI
2.5
No
Indiana Harbor Works
East Chicago, IN
5.5
Yes
Middletown Works
Middletown, OH
3
No
Gary Works
Gary, IN
7.5
Yes
U.S. Steel
Granite City Works
Granite City, IL
2.8
No
Mon Valley Works
Braddock, PA
2.9
No
Sources: US Steel and Cleveland-Cliffs websites https://www.clevelandcliffs.com/operations/steelmaking
https://www.ussteel.com/about-us/locations.
20 https://www.clevelandcliffs.com/operations/steelmaking/dearborn-
works#:~:text=During%202020%2C%20the%20Dearborn%20Works,temper%20operations%20were%20perma
nently%20idled. Accessed 1/23/2023.
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Table 2-4: EAF Facilities
Firm Name
Firm-Owned EAFs
Acciaierie Valbruna S.p.a.
Acerinox S.A.
Allegheny Technologies Inc.
Berkshire Hathaway Inc.
Bluescope Steel Limited
Carpenter Technology Corp.
Charter Manufacturing Company, Inc.
Cleveland-Cliffs Inc.
Commercial Metals Company
Ellwood Group, Inc.
Evraz PLC
G. O. Carlson, Inc.a
Gerdau S.A.
Grupo Simec, S.A.B. De C.V.
Haynes International, Inc.a
Hoganas Holding AB
JSW Steel Limited
KCI Holdings, Inc.
Kyoei Steel Ltd.
Leggett & Piatt, Inc.
Melrose Industries PLC
Nippon Steel Corporation
NLMK, PAO
Nucor Corporation
Outokumpu
Schnitzer Steel Industries, Inc.
SSAB U.S. Holding, Inc.
Steel Dynamics, Inc.
Sumitomo Corporation
Swiss Steel Holding AG
Tenaris Global Services (USA) Corporation
Timkensteel Corporation
U.S. Steel
Universal Stainless & Alloy Products, Inc.a
Vallourec Deutschland Gmbh
Whemco Inc.
2
2
4
9
2
1
1
10
2
1
1
1
1
1
1
1
1
1
21
1
1
2
6
1
1
1
2
2
1
1
1
Grand Total
88
Source: Information on existing EAFs from AIST publication "2021 AIST Electric Arc Furnace Roundup"
aFirm identified as a small business. (See: U.S. EPA (2022))
Estimated employment in iron and steel mills is 86,000 (USGS, 2022a), down from about
160,000 in 2000 and 110,000 in 2010.21 As detailed in Section 2.7.4, United States steel
21 USGS Mineral Commodity Summaries, available here: https://www.usgs.gov/centers/national-minerals-
information-center/iron-and-steel-statistics-and-information. Accessed 1/27/2023.
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production has been trending strongly towards EAF and will likely continue to do so for the
foreseeable future. The fall in employment is closely related to the shift in production to EAF, as
EAF steel requires fewer labor-hours to produce.22
2.6.1 Horizontal and Vertical Integration
Whether a firm is vertically or horizontally integrated depends on the business activity
that the parent company does and the businesses that the facilities or subsidiaries owned by that
company engage in. Vertically integrated companies may own the production process of inputs
that are used in other production processes within the company. In the steel industry, a company
that operates an II&S facility might also own the taconite iron ore mining and processing
facilities, coal mines, and coking facilities, all of which contribute primary inputs to II&S
facilities. Horizontal integration occurs if a firm increases production of a good at the same point
in the supply chain, through growth or acquisitions and mergers. Cleveland-Cliffs Inc. and U.S.
Steel own all taconite iron ore mining and processing facilities in the United States (see Table
2-5). Both companies hold full or partial ownership in facilities that produce coke, with U.S.
Steel owning the largest facility in the country (Clairton, located at the Mon Valley Works) (see
Table 2-6). Finally, Cleveland-Cliffs Inc. owns a facility that produces hot-briquetted iron, a
lower-carbon iron feedstock used primarily as a substitute for scrap metal in EAFs.23 U.S. Steel
and Cleveland-Cliffs Inc. could also be considered horizontally integrated at the steel
manufacturing stage of production because they represent large portions of the industry (and the
entirety of the II&S portion of the industry).
22 https://apnews.com/article/north-america-oh-state-wire-donald-trump-pa-state-wire-business-
cae426730cd74e64932e4be7fa5cdebc. Accessed 1/27/2023.
23 https://www.clevelandcliffs.com/operations/steelmaking/toledo-dr-plant. Accessed 1/27/2023.
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Table 2-5: U.S. Taconite Iron Ore Facility Ownership, Production, and Capacity
State
Facility Name
Parent Company
Annual
Capacity
Production
2020
Production
2019
Minorca Mine
Cleveland-Cliffs Inc.
2.9
2.8
2.8
Hibbing Taconite Mine
Cleveland-Cliffs Inc.
8.1
2.5
7.6
MN
Northshore Mining
United Taconite Mine
Cleveland-Cliffs Inc.
Cleveland-Cliffs Inc.
6.1
5.5
3.9
5.3
5.3
5.4
Keetac Mine
U.S. Steel
5.5
2
5.3
Minntac Mine
U.S. Steel
14.8
12.8
13.1
MI
TildenMine
Cleveland-Cliffs Inc.
8.1
6.4
7.8
Total
51
35.7
47.3
Source: Minnesota Department of Revenue, (2022). Mining Tax Guide.
https://www.revenue.state.mn.us/sites/default/files/2022-10/2022_mining_guide_0.pdf
Source: Tuck. (2022). Iron Ore [tables only release]. U.S. Geological Survey Minerals Yearbook - 2020. Available
at: https://d9-wret.s3.us-west-2.amazonaws.com/assets/palladium/production/s3fs-public/media/files/mybl-
2020-feore-ERT.xlsx.
Table 2-6: U.S. Coking Facility Ownership and Capacity
Parent Company
Facility
Capacity (million
short tons)
Status
Cleveland-Cliffs Inc.
Burns Harbor, IN
Follansbee, WV
Monessen, PA
Middletown, OH
Warren, OH
1.4
N/A
0.35
0.35
0.55
Active
Closing
Active
Idle
Active
DTE Energy Company
EES-River Rouge, MI
0.8
Active
Drummond Company
ABC-Tarrant, AL
0.73
Active
James C. Justice Companies Inc.
Bluestone-Birmingham, AL
0.35
Idle
East Chicago, IN
1.22
Active
Suncoke Energy, Inc.
Franklin Furnace, OH
Granite City, IL
1.1
0.65
Active
Active
Middletown, OH
0.55
Active
Vansant, VA
0.72
Active
U.S. Steel
Clairton, PA
4.3
Active
Source: Firm websites.
Note: Firms owning II&S facilities displayed in bold.
2-14
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2.6,2 Firm Characteristics
Table 2-7 reports 2021 sales and employment data for U.S. Steel and Cleveland-Cliffs
Inc. The data provided in the table were collected from the corporations' Forms 10-K submitted
to the U.S. Securities and Exchange Commission. Each company is headquartered in a traditional
steel-producing city in the Midwest: Pittsburgh and Cleveland. Both companies reported similar
sales revenue, both above $20 billion and both with approximately 25,000 employees worldwide.
Table 2-7: Taconite Iron Ore Facility Owner Sales and Employment, 2021
Parent Company
HQ Location
Legal Form
Sales (million USD)
Employment
U.S. Steel
Pittsburgh, PA
Public
$20,275
24,500
Cleveland-Cliffs Inc.
Cleveland, OH
Public
$20,444
26,000
Total
$40,719
50,500
Sources: U.S. Steel Corporation Form 10-K 2022 and Cleveland-Cliffs Inc. Form 10-K 2022
2.7 Market Conditions
2.7.1 Domestic Production and Consumption
Table 2-8 shows steel production, consumption, and prices in the United States from
2010 to 2021. Steel production, shipments, and consumption were broadly stable over the time
period. Steel production and consumption dipped sharply due to the economic slowdown caused
by the COVID-19 pandemic in 2020, but rebounded in 2021. Table 2-9 shows steel mill product
shipments by product type. Hot-rolled coil (HRC) sheets are the most produced steel mill
product, accounting for about 22 percent of all shipments. HRC steel is a coil of steel rolled on a
hot-strip mill, which can be sold to end users or further processed into other finished products by
steel fabricators.24 The HRC price of steel is commonly used as a benchmark steel price.
24 https://www.steel.org/steel-technology/steel-production/glossary/. Accessed 5/10/2023.
2-15
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Table 2-8: U.S. Steel Production, Consumption, and Prices, 2010-2021 (volumes in
thousand metric tons)
Year
Raw Steel
Production
Shipments
Consumption
Hot Rolled Coil
Steel
($/metric ton)3
HRC Price
Adjusted to
2021 USD
All Steel Mill
Products PPI
2010
80,500
75,700
82
620
1,182
191.7
2011
86,400
83,300
90
735
1,307
216.2
2012
88,700
87,000
98
652
1,249
208
2013
86,900
86,600
100
634
1,338
195
2014
88,200
89,100
107
647
1,326
200.2
2015
78,800
78,500
99
454
1,124
177.1
2016
78,500
78,500
93
533
1,430
167.8
2017
81,600
82,500
99.4
621
1,407
187.4
2018
86,600
86,400
101
835
1,604
211.1
2019
87,800
87,300
99.6
600
1,269
204
2020
72,700
73,500
82.9
607
1,533
184.4
2021
87,000
88,000
98
1,610
1,610
348.5
a Steel prices reflect HRC steel USD/metric ton average monthly prices. Hot rolled sheets are the most produced
steel in the United States; see Table 15. HRC prices were adjusted to 2021 values using the PPI for hot rolled
sheet steel. The PPI for steel mill products index year: 1982 = 100.
Sources:
USGS. Iron and steel. Mineral Commodity Summaries 2011-2022. Available at:
https://www.usgs.gov/centers/national-minerals-information-center/iron-and-steel-statistics-and-information.
U.S. Bureau of Labor Statistics. (2022). Producer Price Index by commodity: metals and metal products: Hot
rolled steel sheet and strip, including tin mill products [WPU101703],
U.S. Bureau of Labor Statistics. (2022). Producer Price Index by commodity: metals and metal products: Steel
mill products. [WPU1017],
Investing.com (2023) US Midwest Domestic Hot-Rolled Coil Steel Futures Historical Data.
https://www. investing.com/commodities/us-steel-coil-futures-historical-data.
2-16
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Table 2-9: Shipments of Steel Mill Products by Type, 2019 and 2020
(thousand metric tons)
Steel mill products:
2019
2020
2019
2020
Ingots, blooms, billets, and slabs
525
424
0.6
0.58
Wire rods
2,860
1,940
3.28
2.65
Structural shapes, heavy
6,240
5,310
7.15
7.22
Plates, cut lengths
5,840
5,120
6.7
6.96
Plates, in coils
2,280
1,680
2.62
2.28
Rails
814
721
0.93
0.98
Railroad accessories
359
295
0.41
0.4
Bars, hot-rolled
4,560
3,210
5.23
4.37
Bars, light-shaped
2,060
1,410
2.36
1.92
Bars, reinforcing
7,740
6,330
8.87
8.61
Bars, cold finished
1,070
721
1.22
0.98
Pipe and tubing, standard pipe
843
532
0.97
0.72
Pipe and tubing, oil country goods
1,700
868
1.95
1.18
Pipe and tubing, line pipe
589
292
0.68
0.4
Pipe and tubing, mechanical tubing
510
376
0.58
0.51
Pipe and tubing, pipe piling
210
151
0.24
0.21
Pipe and tubing, pressure tubing
16
16
0.02
0.02
Pipe and tubing, structural
425
383
0.49
0.52
Wire
445
366
0.51
0.5
Tin mill products, blackplate
43
9
0.05
0.01
Tin mill products, tinplate
875
1,130
1
1.54
Tin mill products, tin free steel
190
36
0.22
0.05
Tin mill products, tin coated sheets
69
58
0.08
0.08
Sheets, hot-rolled
19,900
17,800
22.82
24.27
Sheets, cold-rolled
9,700
8,490
11.11
11.56
Sheets and strip, hot dip galvanized
14,100
12,600
16.11
17.09
Sheets and strip, electrogalvanized
570
415
0.65
0.56
Sheets and strip, other metallic coated
2,100
2,240
2.4
3.04
Strip, hot-rolled
82
83
0.09
0.11
Strip, cold-rolled
582
493
0.67
0.67
Total
87,300
73,500
100
100
Source: USGS. (2020). Iron and steel [tables only release]. U.S. Geological Survey Minerals Yearbook - 2020.
https://www.usgs.gov/centers/national-minerals-information-center/iron-and-steel-statistics-and-information
2.7.2 Prices
Table 2-8 shows the price of hot-rolled coil steel in both nominal and 2021 dollars. Steel
prices spiked in 2021, doubling year-over-year from 2020 to 2021. This was a temporary spike,
as steel production struggled to keep with demand from the construction, automotive, and home
2-17
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appliance sectors and higher energy and raw material costs.25 Prices have since returned to
historical norms, with hot-rolled coil steel futures trading at 775 $/metric ton in January 2023.26
Steel price fluctuations are largely driven by fluctuations in cyclical demand for steel (which is
strongly cyclical) and the prices of raw materials, such as iron ore, coal, electricity (often
provided by natural gas and coal), and scrap steel.
2,7.3 Foreign Trade
Table 2-10 shows steel mill product imports and exports from 2010-2021. The United
States was a net importer over the time period, with the volume of the trade deficit peaking in
2014. Mexico and Canada account for the vast majority of steel mill product exports, while the
U.S. imports significant quantities from Canada, Mexico, Brazil, South Korea, and Japan. Table
2-11 shows the breakdown of imports and exports by country.
Table 2-10: U.S. Steel Mill Products Imports and Exports, 2010-2021 (thousand metric
tons)
Year
Imports
Finished
Semi-finished"
Exports
Finished
Semi-finished
2010
21,700
17,100
4,600
11,000
10,400
609
2011
25,900
19,800
6,000
12,200
11,300
904
2012
30,400
23,500
6,900
12,500
11,700
817
2013
29,200
22,600
6,600
11,500
11,100
443
2014
40,200
30,600
9,600
10,900
10,600
289
2015
35,200
28,600
6,600
9,050
8,900
138
2016
30,000
23,900
6,000
8,450
8,400
111
2017
34,600
26,800
7,800
9,550
9,400
143
2018
30,600
23,300
7,300
7,980
7,900
94
2019
25,300
19,100
6,200
6,700
6,600
72
2020
20,000
14,600
5,300
6,810
6,700
110
2021
25,000
18,000
6,700
8,300
8,100
100
a Exports and imports rounded to 100,000 metric tons, besides semi-finished exports due to small values.
Source: USGS. (2022). Iron and steel [tables only release]. U.S. Geological Survey Minerals Yearbook - 2020.
Available at: https://www.usgs.gov/centers/national-minerals-information-center/iron-and-steel-statistics-and-
information.
25 https://www.yahoo.com/video/steel-prices-set-upturn-war-
131101512.html?guccounter=l&guce_referrer=aHR0cHM6Ly93d3cuZ29vZ2xlLmNvbS8&guce_referrer_sig=
AQAAAG6jjiF8suwUlzCn-zK8PA5PVGx2b0VE2O-
Md5LDPv7k8NcrOBoT2T6KN2RQOcXjhZdbOJvjE5Mh8LlvPnxMWxI_BxAPijlISSlyDyXJ4onKuQhEj-
PW_Ox3ykCsISBugeXHCOApgncxsJU2Z8winlH_P9SXnFyOnwtmD72vLZbD. Accessed 1/27/2023.
26 https://www.investing.com/commodities/us-steel-coil-futures-historical-data. Accessed 1/27/2023.
2-18
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Table 2-11: U.S. Steel Mill Product Imports and Exports by Country, 2019 and 2020
(thousand metric tons)
Country 2019 2020
Imports
Exports
Imports
Exports
Argentina
178
8
27
6
Belgium
114
28
54
14
Brazil
3,830
38
3,670
24
Canada
5,030
2,940
4,730
2,850
China
498
55
342
65
France
168
8
90
5
Germany
966
21
809
14
Italy
535
18
167
15
Japan
1,140
15
732
14
Republic of Korea
2,340
34
1,830
25
Mexico
3,370
3,050
3,010
2,630
Netherlands
499
6
420
3
Russia
977
--
390
--
Spain
404
24
262
12
Sweden
203
9
138
10
Taiwan
753
13
520
8
Turkey
297
--
510
--
United Kingdom
231
27
190
16
Vietnam
602
--
285
--
Other
3,220
404
1,810
1,090
Total
25,300
6,700
20,000
6,810
Source: USGS. (2022). Iron and steel [tables only release]. U.S. Geological Survey Minerals Yearbook - 2020.
Available at: https://www.usgs.gov/centers/national-minerals-information-center/iron-and-steel-statistics-and-
information.
2.7.4 Trends and Projections
Figure 2-5 shows U.S. steel production and capacity from 2000 to 2019. Total steel
production dropped markedly from 2008 to 2009, but has been around 80-90 million metric tons
per year since 2011. Total capacity has been steady since 2015. Figure 2-6 shows the evolution
of the U.S. steel industry from BF/BOPF to EAF production from 2001 to 2021. The share of
steel produced by II&S facilities has dropped from 53 percent in 2001 to 29 percent in 2021. The
U.S. shift towards EAF-produced steel is a global outlier, as EAF only produced 28 percent of
steel internationally as of 2020.27
27 https://www.globalefficiencyintel.eom/new-blog/2020/9/2/part-2-cleanest-and-dirtiest-countries-for-secondary-
eaf-steel-production. Accessed 1/26/2023.
2-19
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Figure 2-5: Steel Production and Capacity, 2000-2019
140
120
100
80
60
40
20
0
n<^° ' ^\X " ^
f\5 J^P AV .est1 -sS^ .0s _0'
«5 ste -A N.% v°>
V V "F V V V T
o—¦
oooooooooo^~^~—. ~ . ^^^rsirvj
oooooooooooooooooooooo
-------
The EAF process has been gaining prevalence, especially domestically. EAFs produce
fewer emissions, have lower initial costs, use generally smaller operations, and are more efficient
than the traditional process. Compared to the integrated steelmaking process, EAFs are quite
energy efficient, using 2 gigajoules (GJ) of final energy per metric ton, compared to 15 GJ used
by the integrated process (IEA, 2020). The EAF process relies primarily on electricity as an
energy source, while the integrated process relies primarily on coal, resulting in vastly different
emission intensities. Scrap-based EAFs, like those used in the United States, emit about 0.3 t
C02/t of steel produced, while integrated operations emit 2.21 C02/t of steel (IEA, 2020).
However, EAFs typically face higher material costs than integrated steel mills because steel
scrap is more expensive than iron ore. Considering raw material costs along with fuel, fixed
costs, and capital costs, though, EAFs and integrated mills have similar levelized costs,
according to the IEA (2020). Further, since initial capital investment is lower for EAF facilities
(IEA, 2020), EAF production is cost-effective at a smaller scale than BF/BOPF production. The
United States has a long history of steelmaking and steel consumption and, thus, a mature stock
of steel and steel scrap that has supported the transition to EAF production. Developing regions
tend to have newer infrastructure and less steel recycling, often along with a greater supply of
iron ore or cheap coal (China and India, for instance), which favors the continued investment in
integrated steelmaking. The integrated process is still the dominant steelmaking process globally,
accounting for 70 percent of global production (World Steel Association, 2022). Although EAFs
will continue to gain market share of steel production under a business-as-usual scenario,
considering announced and existing steelmaking policies, the IEA projects that by 2050 EAFs
will make up just under 50 percent of global steel production. As the industry has shifted toward
EAF steelmaking, the domestic demand for iron ore has decreased over the past several decades.
As detailed in the Organisation for Economic Co-operation and Development's recent
report Latest Developments in Steelmaking Capacity 2021 (2021), companies invested in 11 new
steelmaking facilities in the United States to start production in 2020 or later, all of which are
EAFs. Although BF/BOPF facilities are still being constructed in India, China, and parts of
Africa and Asia, it appears unlikely that BF/BOPF capacity will increase in the United States in
the near future. As shown in Table 2-6, two II&S facilities have idled over the past 3 years, and
another one closed in 2015 that now houses an EAF. As the United States, as well as other
countries, attempts to reduce carbon emissions to meet climate policy targets, EAFs may become
2-21
-------
more cost competitive because they produce 0.3 t CO2 per metric ton of steel compared with 2.2
t CO2 per metric ton of steel emitted by a BOPF (IEA, 2020). A 2021 IEA report claims that, by
2050, EAFs in the United States will make up about 90 percent of domestic steel production
(IEA, 2020).
2-22
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3 EMISSIONS AND ENGINEERING COSTS ANALYSIS
3.1 Introduction
In this chapter, we present estimates of the projected emissions reductions and
engineering compliance costs associated with the proposed NESHAP amendments for the 2025
to 2034 period. The projected costs and emissions impacts are based on facility-level estimates
of the costs of meeting the proposed emission limits and the expected emissions reduction of
installing the necessary controls and performing the required work practices. The baseline
emissions and emission reduction estimates are based on the number of blast furnaces, basic
oxygen furnaces, and sinter plants each facility, iron and steel production capacity at each
facility, stack testing data, information and assumptions about current installed controls, and the
best available information about emissions factors and activities for each source of fugitive
emissions.
3.2 Facilities and Emissions Points
3,2,1 II&S Manufacturing Facilities
The NESHAP for II&S facilities covers eight facilities owned by two ultimate parent
companies: Cleveland-Cliffs Inc. (five facilities) and U.S. Steel (three facilities). These facilities
are all in the midwestern United States, across five states: three in Indiana, two in Ohio, and one
each in Illinois, Michigan, and Pennsylvania. A ninth facility, the Great Lakes Works in Ecorse,
Michigan (owned by U.S. Steel) closed its primary steel production operations in 2019. The
three sinter plants in the source category are located at Burns Harbor Works, Indiana Harbor
Works, and Gary Works. Table 3-1 lists these facilities.
3-1
-------
Table 3-1: II&S Facilities
Ultimate Parent Company
Facility
Sinter Plant
Burns Harbor Works
Yes
Cleveland Works
No
Cleveland-Cliffs Inc.
Dearborn Works
No
Indiana Harbor Works
Yes
Middletown Works
No
Gary Works
Yes
U.S. Steel
Granite City Works
No
Mon Valley Works
No
Sources: US Steel and Cleveland-Cliffs Inc. websites: https://www.clevelandcliffs.com/operations/steelmaking
https://www.ussteel.com/about-us/locations
II&S facilities manufacture steel by reducing iron ore to iron in a blast furnace and then
feeding the molten iron and scrap steel (along with other additives) to a basic oxygen furnace to
produce steel. Three facilities include sinter plants. Blast furnaces, basic oxygen furnaces, and
sinter plants are the primary sources of HAP and PM emissions from the source category. These
three emissions points are discussed in detail in the next section.
3,2,2 Emission Points at Regulated Facilities28
3.2.2.1 Blast Furnaces
The blast furnace converts feedstock (mainly iron ore and taconite iron ore pellets, coke,
limestone, and sinter) into molten iron. The feedstock enters at the top of the furnace and
descends through the furnace. Coke provides heat and fuel for the chemical reaction in the
furnace and provides carbon to reduce the iron oxide by removing oxygen in the form of carbon
monoxide (CO). As the feedstock burden descends, it is heated by a countercurrent flow of gas.
Hot air is blasted into the bottom of the furnace above the hearth. As the hot air and gas flows
upward counter to the feedstock burden, it consumes the coke, reducing the oxygen content of
the iron and producing CO. The limestone decomposes into slag, which sits on the top of the
molten iron. The iron and slag exit through separate tapholes at the bottom of the furnace, and
are directed to ladles in the casthouse before transportation to the basic oxygen furnace. Figure
28 This section draws heavily from the National Emissions Standards for Hazardous Air Pollutants (NESHAP) for
II&S Plants - Background Information for Proposed Standards (U.S. EPA, 2001) (EPA 453/R-01-005) and the
Development of Emissions Estimates for Fugitive or Intermittent HAP Emissions Sources for an Example II&S
Facility for input to the RTR Risk Assessment (U.S. EPA, 2019c) (Available at:
https://www.regulations.gov/document/EPA-HQ-OAR-2002-0083-0956)
3-2
-------
3-1 provides a diagram of the blast furnace and the chemical reactions produced. For more
detailed information on iron production, see Section 2.2.
Figure 3-1: Diagram of a Blast Furnace
The Blast Furnace
Charge: iron ore, coke, limestone
I
Hot waste gases I Hot waste gases
¦ rVTV
Carbon dioxide reacts
with coke:
C02(g) + C(s)-2CO(g)
Hot air reacts with coke:
C(s) + 02(g)-C02(g)
Hot air blast
4
Source: https://www.metallics.org/pig-iron-bf.htmh
There are several fugitive emissions points in the blast furnace. Figure 3-2 below contains
a diagram. Hood systems in the blast furnace casthouse capture emissions and use a scrubber or
baghouse to remove PM. Fugitive emissions in the casthouse result from incomplete capture by
the emissions systems in place. Fugitive emissions leave the casthouse though roof vents, open
doors, and other building openings. Fugitive emissions also occur through bleeder valve
openings (both planned and unplanned), bell leaks, slag processing, and iron beaching. The gas
leaving the blast furnace is primarily CO and nitrogen and is laden with PM.
There is a pressure/bleeder valve 100-150 feet above the casthouse. Raw material build-
up can occasionally create a pressure surge that leads to an unexpected releases of the bleeder
valve, lasting from seconds up to about ten minutes. These unexpected bleeder valve openings
Reduction of iron ore:
3CO(g) + Fe203(s)—2Fe(l) + 3C02(g)
Limestone decomposes and
slag forms:
CaCOj(s) — CaO(s) + CO,(g)
CaO (s) + Si02(s) — CaSiOjO)
sand
¦ Hot air blast
slag
3-3
-------
are referred to as "slips" and occur up to about seven times per month. Bleeder valves are also
opened periodically for repair about twice per week. The blast furnace is idled prior to planned
bleeder valve openings, leading to lower emissions than during slips.
Blast furnace bells are part of the hopper system on the blast furnace that allow raw
materials to be charged into the furnace without allowing solids or gases to escape into the
atmosphere. The typical bell system consists of a large and small bell arranged in a lock system,
with the small bell on top of the large bell. Feedstock is placed into the small bell with the large
bell closed. Once full, the small bell closes to the atmosphere and its bottom opens into the top of
the large bell, which directs the raw materials into the blast furnace. Exhaust air exits the bell
through uptakes ducts which directs it to a scrubber or baghouse for PM removal. However,
there is a narrow gap in the seal between the bell system and the furnace which allows fugitive
emissions to escape. The gap becomes wider over time as the seal wears down, and typically
needs to be replaced every five years.
The last two sources of fugitives in the blast furnace are slag handling and iron beaching.
Slag is skimmed off the molten iron and exits the casthouse through a system of troughs to large
open pits where the slag cools. The slag emissions occur when the slag is dumped into the open
pits, stored in the open pits, and removed from the pits. Iron beach occurs when the basic oxygen
furnace stops suddenly and cannot receive the molten iron produced by the blast furnace. When
this occurs, molten iron from the blast furnace is dumped onto the ground where it emits fumes.
3-4
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Figure 3-2: Diagram of Blast Furnace Fugitive Emissions
1. Blast Furnace Casthouse (All openings, i.e., roof
vents/doors; regulated)
2. Bell Leaks (Fugitive)
3. Unplanned Openings/Slips (Bleeder valve; intermittent)
4. Planned Openings (Bleeder valve; intermittent)
5. Slag Handling/Storage (Fugitive)
6. Beaching (Fugitive)
Roof Vent
3. and 4. Bleeder Valve
2. Bell Leaks
Taconite ore.
Coke
Limestone.
Sinter
r
-------
to provide heat to melt the scrap. After the oxygen jet starts, lime is added to the furnace to
provide a slag of the basicity, and fluorspar and mill scale are added to manipulate slag fluidity.
Computations are made to determine the necessary percentage of molten iron, scrap, flux
materials, and alloy additions to create steel of the desired specifications. Steelmaking fluxes are
added to reduce the sulfur and phosphorus content of the metal, and the oxidation of silicon,
carbon, manganese, phosphorus, and iron, provide the energy required to melt the scrap, form the
slag, and attain the desired temperature inside the vessel. For more information on steel
production, see Section 2.3.
Figure 3-3: Diagram of a Basic Oxygen Furnace Vessel
Molten iron (70-75%) +
steel scraps (25-30%) +
lime/dolomite
1
BOF converter
Source: Yildirim and Prezzi (2011)
Emissions occur in the BOPF shop from hot metal transfer, desulfurization, charging,
oxygen blow, and tapping. Emissions are captured by a hood system and routed to a wet scrubber
or electrostatic precipitator (ESP) to remove PM. Incomplete capture of emissions from
metallurgical processes inside the BOPF shop result in fugitive emissions, which exit through
roof vents and other building openings. The major HAP emitted from the BOPF shop are
manganese (Mn) and lead (Pb), in addition to smaller amounts of chromium (Cr), copper (Cu),
mercury (Fig), nickel (Ni), selenium (Se), and other metal HAP.
3-6
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3.2.2.3 Sinter Plants
Three II&S facilities include sinter plants: Gary Works, Burns Harbor Works, and
Indiana Harbor Works. Sintering recovers the raw material value of many waste products
generated at II&S facilities that would otherwise be landfilled or stockpiled. The sinter plant
returns waste iron-bearing materials to the blast furnace and also provides part of the flux used in
the iron-making process. Feed material includes iron ore fines, blast furnace dust, mill scale, and
recycled fines from the sintering process.
The sintering machine accepts feed and conveys it down a moving strand. Near the feed
end of the grate, the bed is ignited on the surface by gas burners and, as the mixture moves along
on the traveling grate, air is pulled down through the mixture to burn the fuel by downdraft
combustion; either coke oven gas or natural gas may be used for fuel to ignite the undersize coke
or coal in the feed. As the grates move continuously over a series of windboxes toward the
discharge end of the strand, the combustion front in the bed moves progressively downward.
This creates sufficient heat and temperature to agglomerates the fine particles, forming a cake of
porous clinker. The clinker is discharged to a breaker which reduces the clinker to smaller
pieces. The sinter is then screened, cooled, and transferred to the blast furnace for use as
feedstock. The sintering process is diagrammed in Figure 3-4.
Figure 3-4: Diagram of the Sintering Process
R;m material bunkers
Roll mixer
Mixture bunker
ill IIIIUI
Roll feeder o° 'R'""0"lwH>d
„0°
Cooling and screening
of sinter
1 n n n n yxj&Kc/y n nnnr
^ I HHHHIHHHHhtHHHt
... . . Material flvu Ga* flow
Main e\liaus(er ~ ~
Source: Huang el al. (2018)
3-7
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Emissions from the sintering process occur during raw material handling and mixing,
through windbox exhaust, sinter machine discharge, and crushing, screening, cooling and storage
of sinter. The most significant source of emissions is through the windbox exhaust, which is
collected by an air capture system and directed to a baghouse or scrubber. Sinter plant windboxes
are a potential source of organic HAP in addition to metal HAP and PM. HAP emissions from
sinter plants primarily consist of Mn and Pb, but also include PAH, D/F, and volatile organic
HAP along with smaller quantities of other metal HAP.
3.2.3 Facility Projections and the Baseline
The impacts of regulatory actions are evaluated relative to a baseline that represents the
world without the regulatory action. In this RIA, we present results for the proposed amendments
to NESHAP Subpart FFFFF for II&S manufacturing facilities. Throughout this document, we
focus the analysis on the proposed requirements that result in quantifiable compliance cost or
emissions changes compared to the baseline. Baseline cost and emissions estimates were
developed for each facility based on counts of emissions units and estimates of iron, steel, and
slag output. Facility-level cost and emissions impact estimates were aggregated to produce
national-level estimates.
EPA incorporated current facility work practices, as determined by responses to a Section
114 information request, into estimates of baseline cost and emissions. In estimating costs of the
proposed amendments, if a facility reported already having equipment that the proposed
standards would require, the capital cost of that equipment was not included in the cost estimate
for that facility. Similarly, if a facility reported already using a work practice that is part of the
proposed standards, the annual O&M and labor costs for that work practice were not included in
the cost estimate for that facility. In developing baseline emissions estimates, a percent reduction
was estimated for each work practice in the proposed standards. The percent reductions per work
practice are estimates based on engineering judgement, and all add up to 50% for each UFIP
source. If a facility reported already implementing a proposed work practice, the corresponding
percent reduction was applied to the baseline emissions for that facility. If a facility does not
currently implement a proposed work practice, the corresponding percent reduction was applied
to the estimated reduction impact for that facility. Specific work practices for each source are
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described in Section 3.3.1. A summary of work practices incorporated into the baseline is given
in Table 3-2. For BF bell leaks, no adjustment was made for bell-less tops or bells with non-
replaceable seals. No adjustment was made with respect to large bell work practices since
facilities did not provide information on current replacement rates for large bell seals. Baseline
emission adjustments for small bell seal replacement were made based on how often a facility
reported replacing small bell seals. In certain cases a facility may only be partially implementing
a work practice, in which case the estimated emission reduction achieved at baseline may be less
than that shown in Table 3-2. Facilities are assumed to not be incorporating work practices to
reduce emissions from BF planned openings and casthouse fugitives in the baseline.
Table 3-2: Summary of Facility Work Practices in Baseline
Source
Work Practice
Count of Facilities Currently
Incorporating Work Practice
BF Unplanned Openings
("slips")
Install and operate devices to continuously
measure/monitor material levels in the
furnace, at a minimum of three locations,
using alarms to inform operators of static
conditions that indicate a slip may occur.
Install and operate instruments on the
furnace to monitor temperature and
pressure to help determine when a slip may
occur.
Conduct raw material screening to ensure
only properly-sized raw materials are
charged into the BF.
Develop, and submit to the EPA for
approval, a plan that explains how the
facility will implement these requirements.
BF Bell Leaks
For the small bell, replace or repair seals
prior to a metal throughput limit, specified
by the facility, that has been proven and
documented to produce no opacity from the
small bells.
BOPF Shop Fugitives
Keep all openings, except roof monitors
(vents) and other openings that are part of
the designed ventilation of the facility,
closed during tapping and material transfer
events (the only openings that would be
allowed during these events are the roof
vents and other openings or vents that are
part of the designed ventilation of the
facility).
Optimize positioning of hot metal ladles
with respect to hood face and furnace
mouth.
3-9
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Source
Work Practice
Count of Facilities Currently
Incorporating Work Practice
BOPF Shop Fugitives
Set a maximum hot iron pour/charge rate
(pounds/second) for the first 20 seconds of
hot metal charge (i.e., the process of adding
hot iron from the BF into the basic oxygen
process furnace).
Set a minimum flowrate of the secondary
emission capture system during hot metal
charge.
Set a minimum number of times, but at
least once, the furnace should be rocked
between scrap charge and hot metal charge.
Set a maximum furnace tilt angle during
hot metal charging.
Create an outline of procedures to attempt
to reduce slopping.
8
3
0
8
0
Iron Beaching
Have full or partial enclosures for the
beaching process.
Use C02 to suppress fumes.
Minimize the height, slope, and speed of
beaching.
4
3
6
Slag
Handling/Processing/Storage
Use a water system over pit areas, and
apply water to maintain moist slag and
reduce emissions during digging and
dumping.
If the opacity exceeds limit for 2 6-minute
events in one week, subsequently install
and use water fog spray systems over that
excess emission operation except on days
that, due to weather conditions, applying
fog spray would pose a safety risk.
7
1
BF Planned Openings and
Casthouse Fugitives
N/A
N/A
EPA used a variety of sources and assumptions to develop emissions factors for blast
furnace and BOPF shop fugitive emissions and emissions activity estimates for each facility.
This information includes stack testing data collected in 2011 and emission factors and activity
estimates from a variety of sources. For a detailed description of the development of emissions
estimates from these sources, see Development of Emissions Estimates for Fugitive or
Intermittent HAP Emissions Sources for an Example II&S Facility for input to the RTR Risk
Assessment (U.S. EPA, 2019c), available in the docket for the proposed rule (hereafter referred
to as the Emissions Memo).29 For a discussion of the cost and emissions reduction estimates from
29 Available at: https://www.regulations.gov/document/EPA-HQ-OAR-2002-0083-0956
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fugitive sources and sinter plants discussed in the previous two paragraphs, see the
memorandums Unmeasured Fugitive and Intermittent Particulate Emissions and Cost Impacts
for Integrated Iron and Steel Facilities under 40 CFR Part 63, Subpart FFFFF and Maximum
Achievable Control Technology Standard Calculations, Cost Impacts, andBeyond-the-Floor
Cost Impacts for Integrated Iron and Steel Facilities under 40 CFR Part 63, Subpart FFFFF,
also available in the docket (hereafter referred to as the Technical Memos).
For the analysis, we calculate the cost and emissions impacts of the proposed NESHAP
amendments from 2025 to 2034. The initial analysis year is 2025 as we assume the proposed
action will be finalized and thus become effective during 2023, and the proposed rule allows 12
months for compliance with the fugitive emission requirements for BF/BOPF. Facilities must
comply with fenceline monitoring requirements within two years after promulgation of the final
rule, so costs for fenceline monitoring are assumed to begin in 2026. The final analysis year is
2034, which allows us to provide 10 years of potential regulatory impacts after the proposed
amendments are assumed to fully take effect. We assume the number of facilities active in the
source category remains constant during the analysis period. There is a lot of uncertainty in this
assumption, as the II&S source category has significantly shrunk since EPA proposed the
original NESHAP in 2001. Since 2001, the number of II&S facilities has fallen from 20 to 8, and
the number of sinter plants has fallen from 9 to 3 (U.S. EPA, 2001). The most recent closure of a
facility in the source category occurred in 2019. If the number of facilities in the source category
continues to fall during the analysis period, it is likely the impacts projected in this RIA are
overestimated.
3.3 Description of Regulatory Options
This RIA analyzes a less stringent and more stringent alternative package of regulatory
options in addition to the analyzing the proposed amendments to Subpart FFFFF. This section
details the regulatory options examined for each emissions source covered by the rule. In
addition to the emission limits discussed in each section, EPA is also proposing additional
compliance testing and monitoring, recordkeeping, and reporting requirements.
3.3.1 Blast Furnaces and Basic Oxygen Process Furnaces
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3.3.1.1 Fugitive Emissions
EPA is proposing standards to regulate five currently fugitive or intermittent particulate
emissions sources: BF unplanned bleeder valve openings ("slips"), BF planned bleeder valve
openings, BF and BOPF slag processing, handling, and storage, BF bell leaks, and beaching of
iron from BFs. EPA is also proposing updated requirements for fugitive emissions from two
currently regulated sources: BOPF shops and BF casthouses.
For unplanned BF bleeder valve openings, EPA is proposing a limit of 5 per year per BF.
Specific work practices can be used to limit emissions from slips. These work practices include:
• developing a work practice plan to minimize these events and submitting it to
EPA for approval
• installing devices to continuously monitor material levels in the blast furnace, at a
minimum of three locations, with alarms to inform operators of static conditions
which increase likelihood of slips
• installing instruments on the blast furnace to monitor temperature and pressure to
help determine when a slip has occurred
• and requiring raw material screening.
For planned BF bleeder valve openings, EPA is proposing an 8 percent opacity limit but
is not mandating specific work practices to achieve this limit. This allows facilities flexibility in
determining how best to reduce emissions.
For BF bell leaks, EPA is proposing specific work practices and a 10 percent opacity
action level (which is slightly beyond-the-floor). The work practices require facilities to monitor
the top of the blast furnace monthly to identify leaks, measure the opacity of the fugitive
emissions if there is a leak, and repair the bell seal within four months if the opacity action level
is not met. Facilities must also replace the small bell seal every six months or after five million
tons of hot metal throughput.
For BF/BOPF slag processing, handling and storage, EPA is proposing a BTF 5 percent
opacity limit. Facilities can control slag fugitive emissions by spraying water or using fogging as
needed. EPA is also proposing a MACT floor limit for BF iron beaching, along with work
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practice standards that require full or partial enclosures for beached iron and use of CO2 to
suppress fumes.
EPA is proposing updated requirements for BOPF shop and BF casthouse fugitive
emissions. Both sources have a current opacity limit of 20 percent. The proposed standards set a
5 percent opacity limit for both sources, along with specific work practices for minimizing BOPF
shop fugitive emissions. The work practices for BOPF shops include:
• setting a maximum hot iron pour/charge rate (pounds/second) for the first 20
seconds of hot metal pour
• setting a maximum furnace tilt angle during charging
• keeping all openings, except roof monitors, closed during tapping and material
transfer events
• regularly inspecting BOPF shop structure for leaks
• optimizing positioning of hot metal ladles with respect to hood face and furnace
mouth
• setting a maximum furnace tilt angle
• using a higher draft velocity to capture more fugitives at a given distance from
the hood
• and monitoring opacity once per month from all openings for 30 minutes (which
must include a tapping event).
This RIA also analyzes the less stringent regulatory option of maintaining the current 20 percent
opacity limit for BOPF shops and BF casthouses. There are no costs associated with this option.
EPA did not consider more stringent regulatory options for any of the fugitive emissions sources
discussed in this section.
3.3.1.2 Other Regulatory Gaps
EPA identified two unregulated HAP emitted by BF and BOPF (HC1 and THC) and is
proposing a numerical MACT floor limit for each pollutant. It is estimated that each facility
already meets the MACT floor limit, and thus will not need to install additional controls or
3-13
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modify work practices to meet these limits. The only expected costs for these requirements are
from additional compliance testing and monitoring, recordkeeping, and reporting. EPA did not
identify a cost-effective BTF limit for either pollutant, so we are not evaluating a more stringent
option for either as part of this RIA.
3,3.2 Sinter Plants
3.3.2.1 Dioxins/Furans and Poly cyclic Aromatic Hydrocarbons
EPA is proposing a MACT floor limit for D/F and PAH from sinter plant windboxes.
There are currently no specific requirements for these pollutants, but the current VOC and oil
content limits act as a surrogate standard for these HAP. Three II&S facilities have on-site sinter
plants: Gary Works, Burns Harbor Works, and Indiana Harbor Works. Gary Works is owned by
U.S. Steel and both Burns Harbor and Indiana Harbor Works are owned by Cleveland-Cliffs Inc.
These plants currently control windbox emissions using a baghouse, Venturi scrubber, or a
baghouse in combination with a dry scrubber. EPA anticipates these three facilities can meet the
MACT floor limits for D/F and PAH without installing additional controls. The only associated
costs would be for additional compliance testing.
This RIA also analyzes a more stringent regulatory option for D/F and PAH emissions
from II&S sinter plants: setting a BTF limit. EPA anticipates that all three affected facilities
could meet a MACT floor limit by installing an activated carbon injection system to complement
existing windbox controls.
3.3.2.2 Other Regulatory Gaps
EPA identified five unregulated HAP emitted by sinter plants (CS2, COS, HC1, HF, and
Hg) and is proposing a numerical MACT floor limit for each pollutant. It is projected that each
facility can meet the MACT floor limit without installing additional controls or modifying work
practices, so the only expected costs for these requirements are from additional compliance
testing and monitoring, recordkeeping, and reporting. EPA did not identify a cost-effective BTF
limit for any of these pollutants, and so will not be evaluating a more stringent option for any as
part of this RIA.
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3.3.3 Fenceline Monitoring
EPA is proposing a fenceline monitoring requirement pursuant to CAA 112(d)(6). The
fenceline monitoring requirement includes a work practice action level for Cr. If a monitor at a
facility exceeds the action level for Cr, the facility must do a root-cause analysis and take
corrective action to lower Cr emissions. EPA is also proposing a sunset provision in the fenceline
monitoring requirements: if facilities remain below the action level for two full years, they can
terminate the fenceline monitoring as long as they continue to comply with all other rule
requirements. Facilities must comply with fenceline monitoring requirements within two years
following promulgation of the final rule (expected in late 2023). As part of this RIA, EPA is also
analyzing a less stringent alternative regulatory option that does not include fenceline
monitoring.
3.3.4 Summary of Regulatory Alternatives
This RIA analyzes three sets of regulatory alternatives in the emissions and engineering
cost analysis presented in Sections 3.4 and 3.5: the proposed NESHAP amendments along with a
set of less stringent and more stringent alternative regulatory options. The less stringent
alternative regulatory options differ from the proposed amendments in three ways:
• there is a MACT floor limit for D/F and PAH emissions from sinter plants rather
than a BTF limit
• the opacity limit for BF casthouses and BOPF shops is maintained at the current
level
• there is no fenceline monitoring requirement.
The more stringent set of requirements adds the BTF limit for D/F and PAH from sinter plant
windboxes to the proposed requirements.
3.4 Emissions Reduction Analysis
3,4,1 Baseline Emissions Estimates
The baseline emissions estimates for BF/BOPF fugitive emissions and sinter plant
windbox D/F and PAH emissions are presented in Table 3-3 and Table 3-4 below. Estimates are
presented both as emitted tons (or grams, in the case of D/F) per year and over the entire analysis
3-15
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period 2025-2034. Note that, since the number of facilities active in the sector is assumed
constant over the period, and EPA lacks data to project year to year changes in production by
each facility, projected emissions for each pollutant are assumed constant for each year in the
analysis period. For BF/BOPF fugitive emissions, EPA estimated PM emissions and imputed
PM2.5 and HAP emissions by assuming each accounts for a constant share of PM (23 percent for
PM2.5 and 3.7 percent for HAP). The development of the baseline emissions estimates is
described in the Emissions Memo and the Technical Memos. As discussed in Section 3.2.3,
baseline emissions estimates reflect current facility work practices.
Table 3-3: Baseline Emissions Estimates for II&S Blast Furnace and Basic Oxygen Process
Furnace Fugitive Emissions3
Pollutant
HAP
280
Tons per Year
PM
PM2.5
8,100
2,100
HAP
2,800
2025-2034
PM
PM2.5
81,000
21,000
a Totals may not sum due to independent rounding. Numbers rounded to two significant digits unless otherwise
noted.
Table 3-4: Baseline Emissions Estimates for II&S Sinter Plant Windboxes"
Pollutant
Grams per Year
D/F TEQb
9.07
Tons per Year
PAH
6
2025-2034
D/F TEQ
PAH
90.1
60
a Totals may not sum due to independent rounding. Numbers rounded to two significant digits unless otherwise
noted.
b TEQ stands for "toxic-equivalency." TEQs are a weighted-measure based on each member of the dioxin and
dioxin-like compounds category. See https://www.epa.gov/toxics-release-inventory-tri-program/dioxin-and-
dioxin-compounds-toxic-equivalency -information for more information.
3,4,2 Projected Emissions Reduction
Projected emissions reductions for BF/BOPF fugitive emissions are presented in Table
3-5 below. The proposed NESHAP amendments are expected to reduce PM, PM2.5, and HAP
emissions at BF/BOPF roughly 30 percent relative to baseline. The projected emissions
reduction from the more stringent BTF limit for D/F and PAH emissions from sinter plant
windboxes are presented in Table 3-6. The BTF limits for D/F and PAH from sinter plant
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windboxes would control emissions about 90 percent relative to baseline. Table 3-7 shows the
assumed level of control for each emissions source. As demonstrated in the table, the proposed
amendments for each fugitive source are expected to reduce emissions by up to 50 percent.
However, actual estimated reductions at a facility are lower than this if a facility is already
implementing a portion of the proposed work practice requirements. For additional information
on the methods and assumption used to estimate emissions reductions, see the Emissions Memo
and the Technical Memos.
Table 3-5: II&S Blast Furnace and Basic Oxygen Process Furnace Fugitive Emission
Reductions"
Less Stringent
Proposed
HAP
39
79
Tons per Year
PM
1,100
2,300
pm25
240
560
HAP
390
790
2025-2034
PM
11,000
23,000
pm25
2,400
5,600
a Totals may not sum due to independent rounding. Numbers rounded to two significant digits unless otherwise
noted.
Table 3-6: II&S Sinter Plant Windbox Emission Reductions from More Stringent BTF
Limit for D/F and PAHa
Grams per Year
D/F TEQb
8.2
Tons per Year
PAH
5
D/F TEQ
82
2025-2034
PAH
54
a Totals may not sum due to independent rounding. Numbers rounded to two significant digits unless otherwise
noted.
b TEQ stands for "toxic-equivalency." TEQs are a weighted-measure based on each member of the dioxin and
dioxin-like compounds category. See https://www.epa.gov/toxics-release-inventory-tri-program/dioxin-and-
dioxin-compounds-toxic-equivalency -information for more information.
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Table 3-7: Estimated Control from Fugitive Work Practice Standards and Windbox ACI
Source % Control
BF Unplanned Openings 50
BF Planned Openings 50
BF Bell Leaks 50
BF Casthouse Fugitives 50
BOP Shop Fugitives 50
Beaching 50
Slag Handling 50
Sinter Plant Windbox D/F and PAHa 90
a This control percentage refers to the controls necessary to meet the more stringent BTF limit for D/F and PAH, not
the proposed MACT standard.
Table 3-8 shows estimated emissions reductions and total reduction percentage for each
source of BF/BOPF fugitive or intermittent emissions. BOPF shop and bell leak fugitives are by
far the largest sources of emissions reductions, accounting for more than 75 percent of the total.
This explains the large difference in estimated reductions between the proposed option and the
less stringent alternative option (the reductions of which can be obtained by eliminating the
reductions from BF casthouse and BOPF shop fugitives. The less stringent and proposed options
for sinter plant windboxes achieves no emission reductions because EPA projects all three
facilities with sinter plants can meet the MACT floor limit for D/F and PAH without additional
pollution controls.
Table 3-8: II&S Blast Furnace and Basic Oxygen Process Furnace Fugitive Emission
Reductions by Source, Proposed Option (Tons per Year)3
Fugitive or Intermittent Emissions Source
PM
pm25
HAP
tf.euucuon
Percentage
BF Unplanned Openings
14
3.1
0.50
24%
BF Planned Openings
11
2.5
0.41
25%
BF Bell Leaks
830
190
31
41%
BF Casthouse Fugitives
390
90
14
31%
BOPF Shop Fugitives
790
230
25
21%
Iron Beaching
0.09
0.03
0.0035
16%
Slag Handling
220
43
7
25%
Total
2,300
560
79
27%
' Totals may not sum due to independent rounding. Numbers rounded to two significant digits unless otherwise
noted.
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3.5 Engineering Cost Analysis
3,5,1 Detailed Impacts Tables
This section presents detailed cost tables for each section of the proposed amendments.
All tables contain per-year figures with the exception of total capital investment. Total
annualized costs include capital cost annualized using the bank prime rate in accord with the
guidance of the EPA Air Pollution Control Cost Manual (U.S. EPA, 2017), operating and
maintenance costs, annualized costs of increased compliance testing, and costs of additional
monitoring, recordkeeping, and reporting (MRR) (when necessary). Additional compliance
testing for occurs initially and every 5 years thereafter, and is annualized over a 5-year period in
calculating annualized costs. To estimate these annualized costs, the EPA uses a conventional
and widely accepted approach, called equivalent uniform annual cost (EUAC) that applies a
capital recovery factor (CRF) multiplier to capital investments and adds that to the annual
incremental operating expenses to estimate annual costs. This cost estimation approach is
described in the EPA Air Pollution Control Cost Manual (U.S. EPA, 2017). These annualized
costs are the costs to directly affected firms and facilities (or "private investment"), and thus are
not true social costs. Detailed discussion of these costs, including all calculations and
assumptions made in conducting estimates of total capital investment, annual O&M, and
compliance testing/MRR costs, can be found in the Technical Memos. The bank prime rate was
7.00 percent at the time of the analysis but has since risen to 8.25 percent. All cost figures are in
2022$.
3.5.1.1 Fugitive or Intermittent Particulate Sources
Table 3-9 presents total capital investment and annualized costs for proposed and less
stringent alternative option for fugitive sources. The less stringent alternative option maintains
the current 20 percent opacity limit for BF casthouse and BOPF shop fugitive emissions but are
otherwise identical the proposed option. The increased opacity limit for BF casthouse and BOPF
shop fugitive emissions account for approximately 27 percent of total capital investment, 27
percent of annual operation and maintenance (O&M) cost, and 59 percent of annualized
testing/MRR cost for the proposed fugitive source standards. These estimates include the cost of
labor and capital equipment necessary to implement the necessary work practices to meet the
limits and monitor compliance.
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Table 3-9: Summary of Total Capital Investment and Annual Costs per Year for Fugitive
or Intermittent Particulate Sources (2022$)a
Less Stringent
Proposal
Total Capital Investment
$4,200,000
$5,400,000
Annual O&M
$440,000
$1,500,000
Annualized Capital
$1,300,000
$2,400,000
Annualized Testing/MRR
$150,000
$370,000
Total Annualized Cost
$1,900,000
$4,300,000
a Totals may not sum due to independent rounding. Numbers rounded to two significant digits unless otherwise
noted.
Table 3-10 and Table 3-11 present the facility- and firm-level cost breakdown of the
proposed and less stringent alternative option for fugitive sources. For the proposed option, costs
are roughly evenly split between Cleveland-Cliffs Inc. and U.S. Steel, with slightly more of the
cost falling on Cleveland-Cliffs Inc., which owns five of eight II&S facilities.
Table 3-10: Summary of Total Capital Investment and Annual Costs per Year of the
Proposed Option by Facility for Fugitive or Intermittent Particulate Sources (2022$)a
Ultimate Parent Company
Facility
Total Capital
Investment
Annual O&M
Annualized Cost
Burns Harbor
$810,000
$160,000
$290,000
Cleveland
$580,000
$210,000
$450,000
Cleveland-Cliffs Inc.
Dearborn
$150,000
$97,000
$180,000
Indiana Harbor
$1,100,000
$290,000
$700,000
Middletown
$260,000
$100,000
$160,000
Firm Total
$2,900,000
$860,000
$1,800,000
Mon Valley
$1,000,000
$180,000
$550,000
U.S. Steel
Gary
$720,000
$300,000
$470,000
Granite City
$750,000
$180,000
$400,000
Firm Total
$2,500,000
$660,000
$1,400,000
Industry
Total
$5,400,000
$1,500,000
$3,200,000
a Totals may not sum due to independent rounding. Numbers rounded to two significant digits unless otherwise
noted.
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Table 3-11: Summary of Total Capital Investment and Annual Costs per Year of the Less
Stringent Alternative by Facility for Fugitive or Intermittent Particulate Sources (2022$)a
Ultimate Parent Company
Facility Total Capital Investment
Annual O&M
Annualized Costb
Cleveland-Cliffs Inc.
Burns Harbor
$680,000
$53,000
$130,000
Cleveland
$400,000
$62,000
$220,000
Dearborn
$56,000
$24,000
$46,000
Indiana Harbor
$900,000
$110,000
$450,000
Middletown
$170,000
$32,000
$57,000
Firm Total
$2,200,000
$280,000
$920,000
U.S. Steel
Mon Valley
$900,000
$53,000
$400,000
Gary
$450,000
$71,000
$160,000
Granite City
$620,000
$30,000
$260,000
Firm Total
$2,000,000
$150,000
$820,000
Industry
Total
$4,200,000
$440,000
$1,700,000
a Totals may not sum due to independent rounding. Numbers rounded to two significant digits unless otherwise
noted.
b Includes annualized cost of compliance testing and MRR.
3.5.1.2 Sinter Plants
The proposed option for D/F and PAH from sinter plant windboxes sets a MACT floor
limit for each pollutant. EPA estimates all three facilities with on-site sinter plants could meet the
MACT floor without additional controls or changes to work practices, so this option would not
reduce emissions. The only additional costs are for compliance testing.
Table 3-12 and Table 3-13 present the facility- and firm-level costs associated with
proposed and the more stringent BTF limit for D/F and PAH from sinter plant windboxes at II&S
facilities. The estimates assume each facility will install an ACI system on stacks with existing
PM controls. The Gary facility includes two stacks, which the Burns Harbor and Indiana Harbor
facility have one stack each. The annualized costs assume a 20-year equipment life for each
installed ACI system.
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Table 3-12: Summary of Total Capital Investment and Annual Costs per Year of the
Proposed Option for Sinter Plants D/F and PAH (2022$)a
Ultimate Parent Company
Facility
Total Capital
Investment
Annual
O&M
Annualized Costb
Cleveland-Cliffs Inc.
Burns Harbor
Indiana Harbor
$0
$0
$0
$0
$15,000
$15,000
Firm Total
$0
$0
$30,000
U.S. Steel
Gary
$0
$0
$30,000
Firm Total
$0
$0
$30,000
Industry
Total
$0
$0
$60,000
a Totals may not sum due to independent rounding. Numbers rounded to two significant digits unless otherwise
noted.
b Includes annualized cost of compliance testing and MRR.
Table 3-13: Summary of Total Capital Investment and Annual Costs per Year of the More
Stringent Option for Sinter Plants D/F and PAH (2022$)a
Ultimate Parent Company
Facility
Total
Capital
Investment
Annual
O&M
Annualized Costb
Cleveland-Cliffs Inc.
Burns Harbor
Indiana Harbor
$240,000
$240,000
$550,000
$550,000
$590,000
$590,000
Firm Total
$470,000
$1,100,000
$1,200,000
U.S. Steel
Gary
$470,000
$1,100,000
$1,200,000
Firm Total
$470,000
$1,100,000
$1,200,000
Industry
Total
$950,000
$2,200,000
$2,400,000
a Totals may not sum due to independent rounding. Numbers rounded to two significant digits unless otherwise
noted.
b Includes annualized cost of compliance testing and MRR.
3.5.1.3 Fenceline Monitoring
Table 3-14 presents the estimated costs for the proposed fenceline monitoring
requirements by year. The costs include the capital cost of installing 4 monitors per facility in
year one (2025) and O&M, testing, and MRR costs for each year. Table 3-15 presents facility-
and firm-level costs. EPA is also proposing a sunset provision in the fenceline monitoring
requirements: if facilities remain below the action level for two full years, they can terminate the
fenceline monitoring as long as they continue to comply with all other rule requirements. Costs
could decrease for particular facilities after two years of fenceline monitoring if they meet the
requirements of the sunset provision. Facilities must comply with fenceline monitoring
requirements within two years following promulgation of the final rule (expected in late 2023),
3-22
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so we assume costs are not incurred until 2026. Note that the less stringent alternative option
analyzed in this RIA does not include fenceline monitoring.
Table 3-14: Costs by Year for the Proposed Fenceline Monitoring Requirements (2022$)a
Year
Capital
Annual O&M
Testing/MRR
Total
2025
$0
$0
$0
$0
2026
$800,000
$1,300,000
$0
$2,100,000
2027
$0
$1,300,000
$0
$1,300,000
2028
$0
$1,300,000
$0
$1,300,000
2029
$0
$1,300,000
$0
$1,300,000
2030
$0
$1,300,000
$0
$1,300,000
2031
$0
$1,300,000
$0
$1,300,000
2032
$0
$1,300,000
$0
$1,300,000
2033
$0
$1,300,000
$0
$1,300,000
2034
$0
$1,300,000
$0
$1,300,000
a Totals may not sum due to independent rounding. Numbers rounded to two significant digits unless otherwise
noted.
Table 3-15: Summary of Total Capital Investment and Annual Costs per Year of the
Proposed Fenceline Monitoring Requirements (2022$)a
Ultimate Parent Company
Facility
Total Capital
Investment
Annual O&M
Annualized Cost
Burns Harbor
$100,000
$160,000
$200,000
Cleveland
$100,000
$160,000
$200,000
Cleveland-Cliffs Inc.
Dearborn
$100,000
$160,000
$200,000
Indiana Harbor
$100,000
$160,000
$200,000
Middletown
$100,000
$160,000
$200,000
Firm Total
$500,000
$820,000
$1,000,000
Mon Valley
$100,000
$160,000
$200,000
U.S. Steel
Gary
$100,000
$160,000
$200,000
Granite City
$100,000
$160,000
$200,000
Firm Total
$300,000
$490,000
$610,000
a Totals may not sum due to independent rounding. Numbers rounded to two significant digits unless otherwise
noted.
3.5.1.4 Summary of Facility-Level Costs
Table 3-16, Table 3-17, and Table 3-18 present total facility- and firm-level costs for the
proposed amendments, the less stringent alternative option, and the more stringent alternative
option. For the differences between the three sets of alternatives, see Section 3.3.4.
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Table 3-16: Summary of Total Capital Investment and Annual Costs per Year of the
Proposed Amendments (2022$)a
Ultimate Parent Company
Facility
Total Capital Investment
Annual
O&M
Annualized
Costb
Burns Harbor
$910,000
$320,000
$520,000
Cleveland
$680,000
$370,000
$650,000
Cleveland-Cliffs Inc.
Dearborn
$250,000
$260,000
$380,000
Indiana Harbor
$1,200,000
$460,000
$930,000
Middletown
$360,000
$270,000
$370,000
Firm Total
$3,400,000
$1,700,000
$2,900,000
Mon Valley
$1,100,000
$350,000
$750,000
U.S. Steel
Gary
$820,000
$470,000
$720,000
Granite City
$850,000
$340,000
$600,000
Firm Total
$2,800,000
$1,200,000
$2,100,000
Industry
Total
$6,200,000
$2,800,000
$4,900,000
a Totals may not sum due to independent rounding. Numbers rounded to two significant digits unless otherwise
noted.
b Includes annualized cost of compliance testing and MRR.
Table 3-17: Summary of Total Capital Investment and Annual Costs per Year of the Less
Stringent Alternative Options (2022$)a
Ultimate Parent Company
Facility
Total Capital Investment
Annual
O&M
Annualized
Costb
Burns Harbor
$680,000
$53,000
$130,000
Cleveland
$400,000
$62,000
$220,000
Cleveland-Cliffs Inc.
Dearborn
$56,000
$24,000
$46,000
Indiana Harbor
$900,000
$110,000
$450,000
Middletown
$170,000
$32,000
$57,000
Firm Total
$2,200,000
$280,000
$920,000
Mon Valley
$900,000
$53,000
$400,000
U.S. Steel
Gary
$450,000
$71,000
$160,000
Granite City
$620,000
$30,000
$260,000
Firm Total
$2,000,000
$150,000
$820,000
Industry
Total
$4,200,000
$440,000
$1,700,000
a Totals may not sum due to independent rounding. Numbers rounded to two significant digits unless otherwise
noted.
b Includes annualized cost of compliance testing and MRR.
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Table 3-18: Summary of Total Capital Investment and Annual Costs per Year of the More
Stringent Alternative Options (2022$)a
Ultimate Parent Company
Facility
Total Capital Investment
Annual
O&M
Annualized
Costb
Cleveland-Cliffs Inc.
Burns Harbor
Cleveland
Dearborn
Indiana Harbor
Middletown
$1,100,000
$680,000
$250,000
$1,500,000
$360,000
$870,000
$370,000
$260,000
$1,000,000
$270,000
$1,100,000
$650,000
$380,000
$1,500,000
$370,000
Firm Total
$3,900,000
$2,800,000
$4,000,000
U.S. Steel
Mon Valley
Gary
Granite City
$1,100,000
$1,300,000
$850,000
$350,000
$1,600,000
$340,000
$750,000
$1,900,000
$600,000
Firm Total
$3,300,000
$2,300,000
$3,200,000
Industry
Total
$7,200,000
$5,000,000
$7,200,000
a Totals may not sum due to independent rounding. Numbers rounded to two significant digits unless otherwise
noted.
b Includes annualized cost of compliance testing and MRR.
3,5.2 Summary Cost Tables for the Proposed Regulatory Options
Table 3-19 presents estimated costs by year based on when costs are likely to be incurred.
Although firms may spread capital investment across the three years prior to full implementation
of the proposed standards, we conservatively assume that all initial capital investment occurs in
the first year of full implementation to represent a highest-cost scenario. Additional compliance
testing occurs initially and once every five years thereafter to monitor compliance with the
proposed MACT standards for BF/BOPF and sinter plants. Since compliance must occur within
one year of the effective date of the proposed amendments, these costs are assumed to occur in
2025 (the first year of full implementation). Facilities must comply with fenceline monitoring
requirements within two years following promulgation of the final rule (expected in late 2023),
so we assume costs for that provision are not incurred until 2026. Table 3-20 presents total costs
for each year discounted to 2023, along with the present-value (PV) and equivalent annualized
value (EAV) over the analysis period, using both a 3 percent and 7 percent social discount rate.
The EAV represents a flow of constant annual values that would yield a sum equivalent to the
PV. The estimated present-value of compliance costs in 2023 is about $39 million ($4.6 million
EAV) using a 3 percent social discount rate and about $32 million ($4.6 million EAV) using a 7
percent social discount rate from 2025-2034.
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Table 3-19: Costs by Year for the Proposed Options (2022$)
Year
Capital
Annual O&M
Testing/MRR
Total
2025
$5,400,000
$1,500,000
$1,600,000
$8,500,000
2026
$1,900,000
$2,800,000
$60,000
$4,800,000
2027
$1,100,000
$2,800,000
$60,000
$4,000,000
2028
$1,100,000
$2,800,000
$60,000
$4,000,000
2029
$1,100,000
$2,800,000
$60,000
$4,000,000
2030
$1,100,000
$2,800,000
$1,600,000
$5,500,000
2031
$1,100,000
$2,800,000
$60,000
$4,000,000
2032
$1,100,000
$2,800,000
$60,000
$4,000,000
2033
$1,100,000
$2,800,000
$60,000
$4,000,000
2034
$1,100,000
$2,800,000
$60,000
$4,000,000
Note: Totals may not sum due to independent rounding. Numbers rounded to two significant digits unless otherwise
noted.
Table 3-20: Present-Value, Equivalent Annualized Value, and Discounted Costs for
Proposed Options, 2025-2034 (million 2022$)
Year
Discount Rate (Discounted to 2023)
3%
7%
2025
$8.0
$7.4
2026
$4.4
$3.9
2027
$3.6
$3.1
2028
$3.5
$2.9
2029
$3.3
$2.7
2030
$4.5
$3.4
2031
$3.2
$2.3
2032
$3.1
$2.2
2033
$3.0
$2.0
2034
$2.9
$1.9
PV
$39
$32
EAV
$4.6
$4.6
Note: Totals may not sum due to independent rounding. Numbers rounded to two significant digits unless otherwise
noted.
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4 HUMAN HEALTH BENEFITS OF EMISSIONS REDUCTIONS
4.1 Introduction
Implementing emissions controls required by the final NESHAP amendments is expected
to reduce HAP emissions, including emissions of manganese (Mn), lead (Pb), arsenic (As),
chromium/chromium VI (Cr/Cr+6), dioxins/furans (D/F), polycyclic aromatic hydrocarbons
(PAH), and other HAP. The emission controls are also expected to reduce emissions of non-HAP
pollutants, such as particulate matter (including PM2.5). In this chapter, we provide the benefits
analysis for the proposed NESHAP amendments. Data, resource, and methodological limitations
prevented the EPA from monetizing some of the human health benefits from reduced exposure to
the HAP directly targeted by this proposed rule. In addition, the potential benefits from reduced
adverse ecosystem effects and improved visibility (from reduced haze caused by PM) from the
reduction in PM2 5 emissions are also not monetized here. Adverse ecosystem effects of nitrogen
and sulfur deposition include terrestrial and aquatic acidification, terrestrial nitrogen enrichment
and aquatic eutrophication. The EPA provides a qualitative discussion of HAP health effects
later in this chapter.
In this section, we quantify the economic value of benefits of this proposed rule such as
those associated with potential reductions in PM2.5-related premature deaths and illnesses
expected to occur as a result of implementing this rule. PM2 5 emissions reductions occur as a
result of implementing the HAP emission controls described earlier in the RIA.
The PV of the lower-bound benefits for the proposed option for this rule are $2.3 billion at
a 3 percent discount rate to $1.7 billion at a 7 percent discount rate with an EAV of $260 and
$220 million respectively. The PV of the upper-bound benefits for the proposed option for this
rule are $2.4 billion at a 3 percent discount rate to $1.7 billion at a 7 percent discount rate with an
EAV of $280 to $230 million respectively. All estimates are reported in 2022 dollars.
4.2 Health Effects from Exposure to Hazardous Air Pollutants (HAP)
In the subsequent sections, we describe the health effects associated with the main HAP
controlled by the proposed NESHAP amendments: manganese (Mn), lead (Pb), arsenic (As), and
chromium (Cr). This proposal is projected to reduce 79 tons HAP per year. With the data
available, it was not possible to estimate the change in emissions of each individual HAP.
4-1
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Quantifying and monetizing the economic value of reducing the risk of cancer and non-
cancer effects is made difficult by: the lack of a central estimate of estimate of cancer and non-
cancer risk and estimates of the value of an avoided case of cancer (fatal and non-fatal) and
morbidity effects. Due to methodology and data limitations, we did not attempt to monetize the
health benefits of reductions in HAP in this analysis. Instead, we are providing a qualitative
discussion of the health effects associated with HAP emitted from sources subject to control
under the proposed action.
4.2.1 Manganese (Mn)
Health effects in humans have been associated with both deficiencies and excess intakes
of Mn. Chronic exposure to high levels of Mn by inhalation in humans results primarily in
central nervous system effects. Visual reaction time, hand steadiness, and eye-hand coordination
were affected in chronically-exposed workers. Manganism, characterized by feelings of
weakness and lethargy, tremors, a masklike face, and psychological disturbances, may result
from chronic exposure to higher levels. Impotence and loss of libido have been noted in male
workers afflicted with manganism attributed to inhalation exposures. The EPA has classified Mn
in Group D, not classifiable as to carcinogenicity in humans (U.S. EPA, 1995).
4.2.2 Lead(Pb)
Lead is associated with toxic effects in every organ system including adverse renal,
cardiovascular, hematological, hepatic, reproductive, and developmental effects. However, the
major target for Pb toxicity is the nervous system, both in adults and children. Long-term
exposure of adults to Pb at work has resulted in decreased performance in some tests that
measure functions of the nervous system. Lead exposure may also cause weakness in fingers,
wrists, or ankles. Lead exposure also causes small increases in blood pressure, particularly in
middle-aged and older people and may also cause anemia. Children are more sensitive to the
health effects of Pb than adults. No safe blood Pb level in children has been determined. At
lower levels of exposure, Pb can affect a child's mental and physical growth. Fetuses exposed to
Pb in the womb may be born prematurely and have lower weights at birth. Exposure in the
womb, in infancy, or in early childhood also may slow mental development and cause lower
intelligence later in childhood. There is evidence that these effects may persist beyond childhood
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(ATSDR, 2020). EPA has determined that Pb is a probable human carcinogen (Group 2B) (U.S.
EPA, 2004).
4.2.3 Arsenic (As)
Arsenic, a naturally occurring element, is found throughout the environment, and is
considered toxic through the oral, inhalation and dermal routes. Acute (short-term) high-level
inhalation exposure to As dust or fumes has resulted in gastrointestinal effects (nausea, diarrhea,
abdominal pain, and gastrointestinal hemorrhage); central and peripheral nervous system
disorders have occurred in workers acutely exposed to inorganic As. Chronic (long-term)
inhalation exposure to inorganic As in humans is associated with irritation of the skin and
mucous membranes. Chronic inhalation can also lead to conjunctivitis, irritation of the throat and
respiratory tract, and perforation of the nasal septum (ATSDR, 2007).
Chronic oral exposure has resulted in gastrointestinal effects, anemia, peripheral
neuropathy, skin lesions, hyperpigmentation, and liver or kidney damage in humans. Inorganic
As exposure in humans, by the inhalation route, has been shown to be strongly associated with
lung cancer, while ingestion of inorganic As in humans has been linked to a form of skin cancer
and also to bladder, liver, and lung cancer. EPA has classified inorganic As as a Group A, human
carcinogen (U.S. EPA, 1998a).
4.2.4 Chromium (Cr)
Chromium may be emitted in two forms, trivalent Cr (Cr+3) or hexavalent Cr (Cr+6).
The respiratory tract is the major target organ for Cr+6 toxicity, for acute and chronic inhalation
exposures. Shortness of breath, coughing, and wheezing have been reported from acute exposure
to Cr+6, while perforations and ulcerations of the septum, bronchitis, decreased pulmonary
function, pneumonia, and other respiratory effects have been noted from chronic exposures.
Limited human studies suggest that Cr+6 inhalation exposure may be associated with
complications during pregnancy and childbirth. Further, animal studies have reported adverse
reproductive effects from exposure to Cr+6. Human and animal studies have clearly established
the carcinogenic potential of Cr+6 by the inhalation route, resulting in an increased risk of lung
cancer (ATSDR, 2012). EPA has classified Cr+6 as a Group A, human carcinogen (U.S. EPA,
1998b). Trivalent Cr is less toxic than Cr+6. The respiratory tract is also the major target organ
4-3
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for Cr+3 toxicity, similar to Cr+6. EPA has not classified Cr+3 with respect to carcinogenicity
(U.S. EPA, 1998c).
4.2.5 Dioxins/Furans (D/F)
Dioxins and furans are a group of chemicals formed as unintentional byproducts of
incomplete combustion. They are released to the environment during the combustion of fossil
fuels and wood, and during the incineration of municipal and industrial wastes. Dioxins and
furans are generally compared to 2,3,7,8-Tetrachlorodibenzo-p-dioxin (2,3,7,8-TCDD) as a
reference (or index) chemical because it is relatively well-studied and the most toxic compound
within the group. Out of all HAPs for which a health benchmark has been assigned, 2,3,7,8-
TCDD is the most potent for both cancer and non-cancer hazard. 2,3,7,8-TCDD causes chloracne
in humans, a severe acne-like condition. It is known to be a developmental toxicant in animals,
causing skeletal deformities, kidney defects, and weakened immune responses in the offspring of
animals exposed to 2,3,7,8-TCDD during pregnancy. Human studies have shown an association
between 2,3,7,8-TCDD and soft-tissue sarcomas, lymphomas, and stomach carcinomas
(ATSDR, 1998). EPA has classified 2,3,7,8- TCDD as a probable human carcinogen (Group B2)
(U.S. EPA, 1985).
4.2.6 Polycyclic Aromatic Hydrocarbons (PAH)
PAH are a group of chemicals that are formed as byproducts of incomplete combustion.
PAHs can be released to the environment during the burning of coal, oil, gas, wood, garbage,
tobacco, or charbroiled meat. There are over 100 individual PAH compounds, and the health
effects of these individual chemicals can vary (ATSDR, 1995). PAH are generally compared to
benzo(a)pyrene as a single reference (or index) chemical as it is relatively well-studied and
among the most toxic compound within the group. In animals, benzo[a]pyrene has been
associated with adverse developmental, reproductive, and immunological effects. In humans,
exposure to PAH mixtures is associated with adverse birth outcomes (including reduced birth
weight, postnatal body weight, and head circumference), neurobehavioral effects, and decreased
fertility. EPA has classified benzo(a)pyrene as carcinogenic to humans (U.S. EPA, 2017). In
addition EPA has classified other PAH including, benz[a]anthracene, benzo[b]fluoranthene,
benzo[k]fluoranthene, chrysene, dibenz[a,h]anthracene, and indeno[ l,2,3-c,d]pyrene, as
probable human carcinogens (Group B2).
4-4
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4,2,7 Other Air Toxics
In addition to the compounds described above, other toxic compounds might be affected
by this action. Other HAP that are emitted by II&S facilities that could be reduced by the
proposed NESHAP amendments include copper (Cu), mercury (Hg), nickel (Ni), selenium (Se),
carbonyl sulfide (COS), carbon disulfide (CS2), hydrogen chloride, (HC1), and hydrogen fluoride
(HF). Information regarding the health effects of those compounds can be found in the EPA's
IRIS database.30
4.3 Approach to Estimating PM2.5-related Human Health Benefits
This section summarizes the EPA's approach to estimating the incidence and economic
value of the PIVh.s-related benefits estimated for this rule. The Regulatory Impact Analysis for
the Proposed National Emission Standards for Hazardous Air Pollutants: Coal- and Oil-Fired
Electric Utility Steam Generating Units Review of the Residual Risk and Technology Review
(U.S. EPA, 2023a) and its corresponding Technical Support Document Estimating PM25-and
Ozone - Attributable Health Benefits (TSD) (U.S. EPA, 2023b) provide a full discussion of the
EPA's approach for quantifying the incidence and value of estimated air pollution-related health
impacts. In these documents, the reader can find the rationale for selecting the health endpoints
quantified; the demographic, health and economic data applied in the environmental Benefits
Mapping and Analysis Program—Community Edition (BenMAP-CE); modeling assumptions;
and the EPA's techniques for quantifying uncertainty.
Implementing this rule will affect the distribution of PM2.5 concentrations throughout the
U.S.; this includes locations both meeting and exceeding the NAAQS for PM. This RIA
estimates avoided PM2.5-related health impacts that are distinct from those reported in the RIA
for the PM NAAQS (U.S. EPA, 2022). The PM2.5 NAAQS RIA hypothesizes, but does not
predict, the benefits and costs of strategies that States may choose to enact when implementing a
revised NAAQS; these costs and benefits are illustrative and cannot be added to the costs and
benefits of policies that prescribe specific emission control measures.
We estimate the quantity and economic value of air pollution-related effects by
estimating counts of air pollution-attributable cases of adverse health outcomes, assigning dollar
30 U.S. EPA Integrated Risk Information System (IRIS) database is available at www.epa.gov/iris. Accessed March
30, 2022.
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values to these counts, and assuming that each outcome is independent of one another. We
construct these estimates by adapting primary research—specifically, air pollution epidemiology
studies and economic value studies—from similar contexts. This approach is sometimes referred
to as "benefits transfer." Below we describe the procedure we follow for: (1) selecting air
pollution health endpoints to quantify; (2) calculating counts of air pollution effects using a
health impact function; (3) specifying the health impact function with concentration-response
parameters drawn from the epidemiological literature.
4,3,1 Selecting Air Pollution Health Endpoints to Quantify
As a first step in quantifying PM2.5-related human health impacts, the EPA consults the
Integrated Science Assessment for Particulate Matter (PM ISA) (U.S. EPA, 2019a) as
summarized in the TSD for the Final Revised Cross State Air Pollution Rule Update (U.S. EPA,
2021b). This document synthesizes the toxicological, clinical, and epidemiological evidence to
determine whether each pollutant is causally related to an array of adverse human health
outcomes associated with either acute (i.e., hours or days-long) or chronic (i.e., years-long)
exposure. For each outcome, the ISA reports this relationship to be causal, likely to be causal,
suggestive of a causal relationship, inadequate to infer a causal relationship, or not likely to be a
causal relationship.
The ISA for PM2 5 found acute exposure to PM25 to be causally related to cardiovascular
effects and mortality (i.e., premature death), and respiratory effects as likely-to-be-causally
related. The ISA identified cardiovascular effects and total mortality as being causally related to
long-term exposure to PM25 and respiratory effects as likely-to-be-causal; and the evidence was
suggestive of a causal relationship for reproductive and developmental effects as well as cancer,
mutagenicity, and genotoxicity.
The EPA estimates the incidence of air pollution effects for those health endpoints listed
above where the ISA classified the impact as either causal or likely-to-be-causal. Table 4-1
reports the effects we quantified and those we did not quantify in this RIA. The list of benefit
categories not quantified shown in the table is not exhaustive. Among the effects we quantified,
we might not have been able to completely quantify either all human health impacts or economic
values. The table below omits health effects associated with SO2 and NO2, and any welfare
effects such as acidification and nutrient enrichment. These effects are described in the Technical
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Support Document "Estimating PM2.5- and Ozone-Related Benefits", which details the approach
EPA followed for selecting and quantifying PM-attributable effects (U.S. EPA, 2023b).
Table 4-1: Human Health Effects of PlVb.sand whether they were Quantified and/or
Monetized in this RIA
Category
Effect
Effect
Quantified
Effect
Monetized
More
Information
Premature
Adult premature mortality from long-term exposure (age 65-99
V
~
PM ISA
mortality
from
or age 30-99)
exposure
Infant mortality (age <1)
V
~
PM ISA
to PM2.5
Heart attacks (age >18)
V
•/
PM ISA
Hospital admissions—cardiovascular (ages 65-99)
V
•/
PM ISA
Emergency department visits— cardiovascular (age 0-99)
V
-/
PM ISA
Hospital admissions—respiratory (ages 0-18 and 65-99)
V
-/
PM ISA
Emergency room visits—respiratory (all ages)
V
-/
PM ISA
Cardiac arrest (ages 0-99; excludes initial hospital and/or
emergency department visits)
-------
benefits reported in this RIA reflect methods consistent with an earlier version of the TSD (U.S.
EPA, 2021b). Though the methodology employed in this RIA is largely consistent with the PM
NAAQS RIA, here we estimate PM-attributable mortality using concentration-response
parameters that differ from those applied in the PM NAAQS RIA. Specifically, we estimate PM-
attributable deaths using concentration-response parameters from the Di et al. (2017) and Turner
et al. (2016) long-term exposure studies of the Medicare and American Cancer Society cohorts,
respectively. The user manual for the environmental Benefits Mapping and Analysis Program-
Community Edition (BenMAP-CE) program31 separately details EPA's approach for quantifying
and monetizing PM-attributable effects in the BenMAP-CE program. In these documents the
reader can find the rationale for selecting health endpoints to quantify; the demographic, health
and economic data we apply within BenMAP-CE; modeling assumptions; and our techniques for
quantifying uncertainty.
The PM ISA, which was reviewed by the Clean Air Scientific Advisory Committee of the
EPA's Science Advisory Board (U.S. EPA-SAB-CASAC, 2019), concluded that there is a causal
relationship between mortality and both long-term and short-term exposure to PM2.5 based on the
body of scientific evidence. The PM ISA also concluded that the scientific literature supports the
use of a no-threshold log-linear model to portray the PM-mortality concentration-response
relationship while recognizing potential uncertainty about the exact shape of the concentration-
response function. The PM ISA identified epidemiologic studies that examined the potential for a
population-level threshold to exist in the concentration-response relationship. Based on such
studies, the ISA concluded that".. .the evidence from recent studies reduce uncertainties related
to potential co-pollutant confounding and continues to provide strong support for a linear, no-
threshold concentration-response relationship" (U.S. EPA, 2019a). Consistent with this evidence,
the EPA historically has estimated health impacts above and below the prevailing NAAQS.32
31 BenMAP-CE Manual and Appendices, 2022. https://www.epa.gov/benmap/benmap-ce-manual-and-appendices
32 The Federal Register Notice for the 2012 PM NAAQS notes that "[i]n reaching her final decision on the
appropriate annual standard level to set, the Administrator is mindful that the CAA does not require that primary
standards be set at a zero-risk level, but rather at a level that reduces risk sufficiently so as to protect public health,
including the health of at-risk populations, with an adequate margin of safety. On balance, the Administrator
concludes that an annual standard level of 12 ug/m3 would be requisite to protect the public health with an
adequate margin of safety from effects associated with long- and short-term PM2 5 exposures, while still
recognizing that uncertainties remain in the scientific information."
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Following this approach, we report the estimated PIVh.s-related benefits (in terms of both
health impacts and monetized values) calculated using a log-linear concentration-response
function that quantifies risk from the full range of simulated PM2.5 exposures (U.S. EPA, 2021b).
As noted in the preamble to the 2020 PM NAAQS final rule, the "health effects can occur over
the entire distributions of ambient PM2.5 concentrations evaluated, and epidemiological studies
do not identify a population-level threshold below which it can be concluded with confidence
that PM-associated health effects do not occur."33 In general, we are more confident in the size
of the risks we estimate from simulated PM2.5 concentrations that coincide with the bulk of the
observed PM concentrations in the epidemiological studies that are used to estimate the benefits.
Likewise, we are less confident in the risk we estimate from simulated PM2.5 concentrations that
fall below the bulk of the observed data in these studies (U.S. EPA, 2021b). As described
further below, we lacked the air quality modeling simulations to perform such an analysis for this
proposed rule and thus report the total number of avoided PM2.5-related premature deaths using
the traditional log-linear no-threshold model noted above.
4.3.3 Economic Valuation
After quantifying the change in adverse health impacts, we estimate the economic value
of these avoided impacts. Reductions in ambient concentrations of air pollution generally lower
the risk of future adverse health effects by a small amount for a large population. Therefore, the
appropriate economic measure is willingness to pay (WTP) for changes in risk of a health effect.
For some health effects, such as hospital admissions, WTP estimates are generally not available,
so we use the cost of treating or mitigating the effect. These cost-of-illness (COI) estimates
generally (although not necessarily in every case) understate the true value of reductions in risk
of a health effect. They tend to reflect the direct expenditures related to treatment but not the
value of avoided pain and suffering from the health effect. The unit values applied in this
analysis are provided in Section 5.1 of the TSD for the Revised Cross State Update rule (U.S.
EPA, 2021b).
Avoided premature deaths account for 98 percent of monetized PM-related benefits. The
economics literature concerning the appropriate method for valuing reductions in premature
mortality risk is still developing. The value for the projected reduction in the risk of premature
33 https://www.govinfo.gov/content/pkg/FR-2020-12-18/pdf/2020-27125.pdf
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mortality is the subject of continuing discussion within the economics and public policy analysis
community. Following the advice of the SAB's Environmental Economics Advisory Committee
(SAB-EEAC), the EPA currently uses the value of statistical life (VSL) approach in calculating
estimates of mortality benefits, because we believe this calculation provides the most reasonable
single estimate of an individual's WTP for reductions in mortality risk (U.S. EPA-SAB, 2000).
The VSL approach is a summary measure for the value of small changes in mortality risk
experienced by a large number of people.
The EPA continues work to update its guidance on valuing mortality risk reductions and
consulted several times with the SAB-EEAC on the issue. Until updated guidance is available,
the EPA determined that a single, peer-reviewed estimate applied consistently best reflects the
SAB-EEAC advice it has received. Therefore, the EPA applies the VSL that was vetted and
endorsed by the SAB in the Guidelines for Preparing Economic Analyses while the EPA
continues its efforts to update its guidance on this issue (U.S. EPA, 2016). This approach
calculates a mean value across VSL estimates derived from 26 labor market and contingent
valuation studies published between 1974 and 1991. The mean VSL across these studies is $6.3
million (2000$).34
The EPA is committed to using scientifically sound, appropriately reviewed evidence in
valuing changes in the risk of premature death and continues to engage with the SAB to identify
scientifically sound approaches to update its mortality risk valuation estimates. Most recently,
the Agency proposed new meta-analytic approaches for updating its estimates which were
subsequently reviewed by the SAB-EEAC. The EPA is taking the SAB's formal
recommendations under advisement (U.S. EPA-SAB, 2017).
4.4 Monetized PM2.5 Benefits
4,4.1 Benefit-per- Ton Estimates
The EPA did not conduct air quality modeling for this rule. Rather, we quantified the
value of reducing PM concentrations using a "benefit-per-ton" approach, due to the relatively
small number of facilities and the fact that these facilities are located in a discrete location.
These BPT estimates provide the total monetized human health benefits (the sum of premature
34 In 1990$, this base VSL is $4.8 million. In 2016$, this base VSL is $10.7 million.
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mortality and premature morbidity) of reducing one ton of PM2.5 (or PM2.5 precursor such as
NOx or SO2) from a specified source. The method used to derive these estimates is described in
the BPT Technical Support Document (BPT TSD) on Estimating the Benefit per Ton of
Reducing Directly-Emitted PM2.5,PM2.5 Precursors and Ozone Precursors from 21 Sectors and
its precursors from 21 sectors (U.S. EPA, 2023d). The PM2.5 BPT estimates for the Integrated
Iron and Steel sector were used for the analysis, converted to 2022 dollars. As noted above, we
were unable to quantify the value of changes in exposure to HAP, CO, NO2.
As noted below in the characterization of uncertainty, all BPT estimates have inherent
limitations. Specifically, all national-average BPT estimates reflect the geographic distribution of
the modeled emissions, which may not exactly match the emission reductions that would occur
due to rulemaking, and they may not reflect local variability in population density, meteorology,
exposure, baseline health incidence rates, or other local factors for any specific location. Given
use of a regional, sector specific BPT and the small changes in emissions considered in this
rulemaking, the difference in the quantified health benefits that result from the BPT approach
compared with if EPA had used a full-form air quality model should be minimal.
The EPA systematically compared the changes in benefits, and concentrations where
available, from its BPT technique and other reduced-form techniques to the changes in benefits
and concentrations derived from full-form photochemical model representation of a few different
specific emissions scenarios. Reduced form tools are less complex than the full air quality
modeling, requiring less agency resources and time. That work, in which we also explore other
reduced form models is referred to as the "Reduced Form Tool Evaluation Project", began in
2017, and the final report became available in 2019 (Industrial Economics, Inc., 2019). The
Agency's goal was to create a methodology by which investigators could better understand the
suitability of alternative reduced-form air quality modeling techniques for estimating the health
impacts of criteria pollutant emissions changes in the EPA's benefit-cost analysis, including the
extent to which reduced form models may over- or under-estimate benefits (compared to full-
scale modeling) under different scenarios and air quality concentrations. The EPA Science
Advisory Board (SAB) convened a panel to review this report.35 In particular, the SAB assessed:
the techniques the Agency used to appraise these tools; the Agency's approach for depicting the
35 85 FR 23823. April 29, 2020.
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results of reduced-form tools; and steps the Agency might take for improving the reliability of
reduced-form techniques for use in future Regulatory Impact Analyses.
The scenario-specific emission inputs developed for this project are currently available
online. The study design and methodology are described in the final report summarizing the
results of the project36. Results of this project found that total PM2.5 BPT values were within
approximately 10 percent of the health benefits calculated from full-form air quality modeling
when analyzing the Pulp and Paper sector. The ratios for individual species varied, and the
report found that the ratio for the directly emitted PM2.5 for the pulp and paper sector was 0.7 for
the BPT approach compared to 1.0 for full air quality modeling combined with BenMAP. This
provides some initial understanding of the uncertainty which is associated with using the BPT
approach instead of full air quality modeling.
4.4,2 PM2.5 Benefits Results
Table 4-2 lists the estimated PIVh.s-related benefits per ton applied in this national level
analysis. Benefits are estimated using two concentration-response parameters for quantifying
PM-attributable mortality and discounted at 3 and 7 percent for a 2022 currency year. For all
estimates, we summarize the monetized PIVh.s-related health benefits using discount rates of 3
percent and 7 percent for the 10-year analysis period of this rule discounted back to 2023
rounded to 2 significant figures as presented in Table 4-3.
The PV of the lower-bound benefits for the proposed option for this rule are $2.3 billion at
a 3 percent discount rate to $1.7 billion at a 7 percent discount rate with an EAV of $260 and
$220 million respectively. The PV of the upper-bound benefits for the proposed option for this
rule are $2.4 billion at a 3 percent discount rate to $1.7 billion at a 7 percent discount rate with an
EAV of $280 to $230 million respectively. All estimates are reported in 2022 dollars.
Undiscounted benefits are presented by year for the proposed and less stringent alternative
options in Table 4-4 and Table 4-5. The more stringent set of regulatory options does not change
the benefits estimates relative to the proposed requirements, so results for the more stringent
option are not presented. For the full set of underlying calculations see the "Integrated Iron and
Steel Benefits workbook", available in the docket for the proposal.
36 Available here: https://www.epa.gov/benmap/reduced-form-evaluation-project-report.
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Table 4-2: II&S Benefit per Ton Estimates of PM2.5-Attributable Premature Mortality and
Illness for the Proposal, 2025-2035 ($2022)
Discount Rate
Year
3 Percent
7 Percent
2025
$459,177
and
$466,351
$412,542
and
$419,716
2030
$486,679
and
$507,008
$437,653
and
$456,785
2035
$532,119
and
$566,796
$478,309
and
$510,595
Note: The standard reporting convention for EPA benefits is to round all results to two significant figures. Here, we report all
significant figures so that readers may reproduce the results reported below. The monetized health benefits are quantified using
two alternative concentration-response relationships from the Di et al. (2016) and Turner et al. (2017) studies and presented at
real discount rates of 3 and 7 percent.
Table 4-3: II&S Benefit Estimates of PM2.5-Attributable Premature Mortality and Illness
for the Proposal (million 2022$)a'b'c
Less Stringent Regulatory Option Proposed Regulatory Option
Discount Rate Discount Rate
3 Percent 7 Percent 3 Percent 7 Percent
P
V
970
and
1,000
700
and
740
2,300
and
2,400
1,700
and
1,700
E
A
110
and
120
94
and
98
260
and
280
220
and
230
V
a Discounted to 2023
b Rounded to 2 significant figures.
c The monetized health benefits are quantified using two alternative concentration-response relationships from the Di et al. (2016)
and Turner et al. (2017) studies and presented at real discount rates of 3 and 7 percent.
Table 4-4: Undiscounted Monetized Benefits Estimates of PM2.5-Attributable Premature
Mortality and Illness for the Proposed Option (million 2022$), 2025-2034a'b
Year
3%
7%
2025
$250 and $250
$220 and $220
2026
$250 and $270
$230 and $240
2027
$250 and $270
$230 and $240
2028
$260 and $270
$230 and $240
2029
$260 and $270
$230 and $240
2030
$260 and $270
$230 and $240
2031
$260 and $300
$260 and $270
2032
$260 and $300
$260 and $270
2033
$280 and $300
$260 and $270
2034
$280 and $300
$260 and $270
a Rounded to 2 significant figures
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b The monetized health benefits are quantified using two alternative concentration-response relationships from the Di et al. (2016)
and Turner et al. (2017) studies and presented at real discount rates of 3 and 7 percent.
Table 4-5: Undiscounted Monetized Benefits Estimates of PM2.5-Attributable Premature
Mortality and Illness for the Less Stringent Alternative Option (million 2022$), 2025-
2034a'b
Year
3%
7%
2025
$97 and $99
$87 and $89
2026
$97 and $110
$93 and $97
2027
$97 and $110
$93 and $97
2028
$100 and $110
$93 and $97
2029
$100 and $110
$93 and $97
2030
$100 and $110
$93 and $97
2031
$100 and $120
$100 and $110
2032
$100 and $120
$100 and $110
2033
$110 and $120
$100 and $110
2034
$110 and $120
$100 and $110
a Rounded to 2 significant figures
b The monetized health benefits are quantified using two alternative concentration-response relationships from the Di et al. (2016)
and Turner et al. (2017) studies and presented at real discount rates of 3 and 7 percent.
4.4.3 Characterization of Uncertainty in the Monetized PM2.5 Benefits
In any complex analysis using estimated parameters and inputs from a variety of models,
there are likely to be many sources of uncertainty. This analysis is no exception. This analysis
includes many data sources as inputs, including emission inventories, air quality data from
models (with their associated parameters and inputs), population data, population estimates,
health effect estimates from epidemiology studies, economic data for monetizing benefits, and
assumptions regarding the future state of the world (i.e., regulations, technology, and human
behavior). Each of these inputs are uncertain and generate uncertainty in the benefits estimate.
When the uncertainties from each stage of the analysis are compounded, even small uncertainties
can have large effects on the total quantified benefits. Therefore, the estimates of annual benefits
should be viewed as representative of the magnitude of benefits expected, rather than the actual
benefits that would occur every year.
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5 ECONOMIC IMPACT ANALYSIS AND DISTRIBUTIONAL ASSESSMENTS
5.1 Introduction
The proposed NESHAP amendments are projected to result in environmental control
expenditures and work practice adjustments to comply with the rule. The national-level
compliance cost analysis in Section 3.5 does not speak directly to potential economic and
distributional impacts of the proposed rule, which may be important consequences of the action.
This section is directed towards complementing the compliance cost analysis and includes an
analysis of potential firm-level impacts of regulatory costs and a discussion of potential
employment and small entity impacts.
5.2 Economic Impact Analysis
Although facility-specific economic impacts (production changes or closures, for
example) cannot be estimated by this analysis, the EPA conducted a screening analysis of
compliance costs compared to the revenue of firms owning II&S facilities. The EPA often
performs a partial equilibrium analysis to estimate impacts on producers and consumers of the
products or services provided by the regulated firms. This type of economic analysis estimates
impacts on a single affected industry or several affected industries, and all impacts of this rule on
industries outside of those affected are assumed to be zero or inconsequential (U.S. EPA, 2016).
If the compliance costs, which are key inputs to an economic impact analysis, are small
relative to the receipts of the affected industries, then the impact analysis may consist of a
calculation of annual (or annualized) costs as a percent of sales for affected parent companies.
This type of analysis is often applied when a partial equilibrium or more complex economic
impact analysis approach is deemed unnecessary given the expected size of the impacts. The
annualized cost per sales for a company represents the maximum price increase in the affected
product or service needed for the company to completely recover the annualized costs imposed
by the regulation. We conducted a cost-to-sales analysis to estimate the economic impacts of this
proposal, given that the EAV of the compliance costs range are $4.6 million using a 7 percent or
a 3 percent discount rate in 2022 dollars, which is small relative to the revenues of the steel
industry.
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The EPA prefers a "sales test" as the impact methodology in economic impact analyses
as opposed to a "profits test", in which annualized compliance costs are calculated as a share of
profits.37 This is consistent with guidance published by the U.S. Small Business Administration
(SBA) Office of Advocacy, which suggests that cost as a percentage of total revenues is a metric
for evaluating cost impacts on small entities relative to large entities.38 This is because revenues
or sales data are commonly available for entities impacted by the EPA regulations and profits
data are often private or tend to misrepresent true economic profits earned by firms after
undertaking accounting and tax considerations.
While a "sales test" can provide some insight as to the economic impact of an action such
as this one, it assumes that the impacts of a rule are solely incident on a directly affected firm
(therefore, no impact to consumers of an affected product), or solely incident on consumers of
output directly affected by this action (therefore, no impact to companies that are producers of
affected product). Thus, an analysis such as this one is best viewed as providing insight on the
polar examples of economic impacts: maximum impact to either directly affected companies or
their consumers. A "sales test" analysis does not consider shifts in supply and demand curves to
reflect intermediate economic outcomes such as output adjustments in response to increased
costs.
As discussed in Chapter 2, only two firms own the eight remaining II&S manufacturing
facilities in the United States: Cleveland-Cliffs Inc. (Burns Harbor, Cleveland, Dearborn, Indiana
Harbor, and Middletown Works) and U.S. Steel (Gary, Granite City, and Mon Valley Works).
Both firms reported sales greater than $20 billion in 2021 (see Table 5-1).
Table 5-1: II&S Facility Owner Sales and Employment, 2021
Parent Company
HQ Location
Legal Form
Sales (million USD)
Employment
U.S. Steel
Pittsburgh, PA
Public
$20,275
24,500
Cleveland-Cliffs Inc.
Cleveland, OH
Public
$20,444
26,000
Total
$40,719
50,500
Sources: U.S. Steel Corporation Form 10-K 2021 and Cleveland-Cliffs Inc. Form 10-K 2021
37 More information on sales and profit tests as used in analyses done by U.S. EPA can be found in the Final
Guidance for EPA Rulewriters: Regulatory Flexibility Act as Amended by the Small Business Regulatory
Enforcement Fairness Act, November 2006, pp. 32-33.
38 U.S. SBA, Office of Advocacy. 2010. A Guide for Government Agencies, How to Comply with the Regulatory
Flexibility Act, Implementing the President's Small Business Agenda and Executive Order 13272.
5-2
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Table 5-2 and Table 5-3 present total annualized cost and total capital investment relative
to sales for each set of regulatory alternatives. Firm revenues have been converted to 2022
dollars to accord with the dollar-year of the cost estimates. As shown in the tables, both total
annualized cost and total capital investment (which could potentially be incurred by each firm in
a single year) are small compared to total revenue for each firm (less than 0.02 percent). These
costs include the costs of BF/BOPF fugitive emission work practices and monitoring, the costs of
installing ACI at sinter plants to meet the BTF limit for D/F and furans, the costs of fenceline
monitoring, and the cost of additional compliance testing and monitoring, recordkeeping, and
reporting. Based on this estimate, the maximum necessary price increase caused by the proposed
regulation is small relative to the size of the firms that own facilities in the source category, and
the potential economic impacts of the proposed rule are likely to be small.
Table 5-2: Total Annualized Cost-to-Sales Ratios for II&S Facility Owners by Regulatory
Alternative
2021
Revenue
(million
2022$)
Total Annualized
Ultimate Parent Company
Regulatory Alternative
Cost (million
2022$)
TAC-Sales Ratio
Less Stringent
$0.9
0.0042%
Cleveland-Cliffs Inc.
Proposed
$21,742
$2.9
0.013%
More Stringent
$4.0
0.018%
Less Stringent
$0.8
0.0038%
U.S. Steel
Proposed
$21,562
$2.1
0.0097%
More Stringent
$3.2
0.015%
Table 5-3: Total Capital Investment-to-Sales Ratios for II&S Facility Owners by
Regulatory Alternative
Ultimate Parent Company
Regulatory Alternative
2021
Revenue
(million
2022$)
Total Capital
Investment
(million 2022$)
TCI-Sales Ratio
Less Stringent
$2.2
0.010%
Cleveland-Cliffs Inc.
Proposed
$21,742
$3.4
0.016%
More Stringent
$3.9
0.018%
Less Stringent
$2.0
0.0093%
U.S. Steel
Proposed
$21,562
$2.8
0.013%
More Stringent
$3.3
0.015%
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5.3 Employment Impacts Analysis
This section presents a qualitative overview of the various ways that environmental
regulation can affect employment. Employment impacts of environmental regulations are
generally composed of a mix of potential declines and gains in different areas of the economy
over time. Regulatory employment impacts can vary across occupations, regions, and industries;
by labor and product demand and supply elasticities; and in response to other labor market
conditions. Isolating such impacts is a challenge, as they are difficult to disentangle from
employment impacts caused by a wide variety of ongoing, concurrent economic changes. The
EPA continues to explore the relevant theoretical and empirical literature and to seek public
comments in order to ensure that the way the EPA characterizes the employment effects of its
regulations is reasonable and informative.
Environmental regulation "typically affects the distribution of employment among
industries rather than the general employment level" (Arrow, et al., 1996). Even if impacts are
small after long-run market adjustments to full employment, many regulatory actions have
transitional effects in the short run (Office of Management and Budget, 2015). These movements
of workers in and out of jobs in response to environmental regulation are potentially important
and of interest to policymakers. Transitional job losses have consequences for workers that
operate in declining industries or occupations, have limited capacity to migrate, or reside in
communities or regions with high unemployment rates.
As indicated by the potential impacts on II&S manufacturing firms discussed in Section
5.2 , the proposed requirements are unlikely to cause large shifts in steel production and prices.
As a result, demand for labor employed in steel production activities and associated industries is
unlikely to see large changes but might experience adjustments as there may be increases in
compliance-related labor requirements such as labor associated with the manufacture,
installation, and operation of pollution control devices as well as changes in employment due to
quantity effects in directly-regulated sectors and sectors that consume steel produced by
integrated manufacturing facilities. For this proposal, however, we do not have the data and
analysis available to quantify these potential labor impacts.
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5.4 Small Business Impact Analysis
To determine the possible impacts of the proposed NESHAP amendments on small
businesses, parent companies producing iron and steel in integrated facilities are categorized as
small or large using the Small Business Administration's (SBA's) general size standards
definitions. For NAICS 331110 (Iron and Steel Mills and Ferroalloy Manufacturing), these
guidelines indicate a small business employs 1,500 or fewer workers.39 Only two ultimate parent
companies, Cleveland-Cliffs Inc. and U.S. Steel, own II&S manufacturing facilities in the United
States. Based on the SBA definition and the company employment shown in Table 5-1, this
industry has no small businesses.
39 U.S. Small Business Administration, Table of Standards, Effective December 19, 2022. Available at:
https://www.sba.gov/document/support--table-size-standards. Accessed January 17, 2023.
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6 COMPARISON OF BENEFITS AND COSTS
In this chapter, we present a comparison of the benefits and costs of this proposed action.
As explained in the previous chapters, all costs and benefits outlined in this RIA are estimated as
the change from the baseline, which reflects the requirements already promulgated. As stated
earlier in this RIA, there is no monetized estimate of the benefits for the HAP emission
reductions expected to occur as a result of this proposed action. Further, the monetized benefits
associated with PM2.5 only include health benefits associated with reduced premature mortality
and morbidity associated with exposure to PM2.5, and do not include other health and
environmental impacts associated with reduced PM emissions, such as ecosystem effects and
reduced visibility. EPA expects these benefits are positive, and as a result the net benefits
presented in this section are likely understated.
6.1 Results
As part of fulfilling analytical guidance with respect to E.O. 12866, EPA presents
estimates of the present value (PV) of the benefits and costs over the period 2025 to 2034. To
calculate the present value of the social net benefits of the proposed action, annual benefits and
costs are in 2022 dollars and are discounted to 2023 at 3 percent and 7 percent discount rates as
directed by OMB's Circular A-4. The EPA also presents the equivalent annualized value (EAV),
which represents a flow of constant annual values that would yield a sum equivalent to the PV.
The EAV represents the value of a typical cost or benefit for each year of the analysis, consistent
with the estimate of the PV, in contrast to year-specific estimates.
Table 6-1 presents a summary of the monetized benefits, compliance costs, and net
benefits of the proposed NESHAP amendments, and the more and less stringent alternative
regulatory options, in terms of present value (PV) and equivalent annualized value (EAV). Table
6-1 lists benefits using two alternative concentration-response from Di et al. (2016) and Turner et
al. (2017).
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Table 6-1: Summary of Monetized Benefits, Compliance Costs, Net Benefits, and Non-Monetized Benefits PV/EAV, 2025-2034
(million 2022$, discounted to 2023)a'b
Proposal
Less Stringent Alternative
More Stringent Alternative
3%
PV
EAV
PV
EAV
PV
EAV
Monetized Health
Benefits
$2,300
and
$260
and
$970
and
$110
and
$2,300
and
$260
and
$2,400
$280
$1,000
$120
$2,500
$280
Compliance Costs
$39
$4.6
$18
$2.1
$59
$6.9
$2,300
$260
$950
$110
$2,200
$250
Net Benefits
and
and
and
and
and
and
$2,400
$280
$980
$120
$2,300
$270
7%
Monetized Health
Benefits
$1,700
and
$220
and
$700
and
$94
and
$1,700
and
$220
and
$1,700
$230
$740
$98
$1,700
$230
Compliance Costs
$32
$4.6
$15
$2.1
$47
$6.7
$1,700
$220
$690
$92
$1,700
$210
Net Benefits
and
and
and
and
and
and
$1,700
$230
$730
$96
$1,700
$220
79 tpy HAP 39 tpy HAP 79 tpy HAP, 8.2 grams/year D/F, 5 tpy PAH
Non-monetized Health effects of reduced exposure to HAP0
Benefits Non-health benefits from reducing 23,000 (11,000) tons of PM, of which 5,600 (2,400) tons is PM2.5, from 2025-2034 under Proposed
(Less Stringent) Options
Reduced Ecosystem/Vegetation Effects'1
a Rounded to two significant figures. Rows may not appear to add correctly due to rounding.
b Monetized benefits include health benefits associated with reductions in PM2.5 emissions. The health benefits are associated with several point estimates and are presented at real
discount rates of 3 and 7 percent. The monetized health benefits are quantified using two alternative concentration-response relationships from the Di et al. (2016) and Turner et
al. (2017) studies and presented at real discount rates of 3 and 7 percent. Benefits from HAP reductions remain unmonetized and are thus not reflected in the table. Rows may not
appear to add correctly due to rounding.
c For details on HAP health effects associated with the rule, see Section 4.2.
d Adverse effects include terrestrial and aquatic acidification, terrestrial nitrogen enrichment and aquatic eutrophication.
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Given these results, the EPA expects that implementation of the proposed NESHAP
amendments, based solely on an economic efficiency criterion, will provide society with a
substantial net gain in welfare, notwithstanding the set of health and environmental benefits and
other impacts we were unable to quantify such as monetization of benefits from HAP emission
reductions. Further quantification of directly-emitted PM2.5 and HAP would increase the
estimated net benefits of the proposed action. Undiscounted net benefits of the proposed
amendments are presented in Table 6-2, Table 6-3, and Table 6-4 below.
Table 6-2: Undiscounted Net Benefits Estimates for the Proposed Option (million 2022$),
2025-2034a'b
Year
3%
7%
2025
$240 and $240
$210 and $210
2026
$250 and $270
$230 and $240
2027
$250 and $270
$230 and $240
2028
$260 and $270
$230 and $240
2029
$260 and $270
$230 and $240
2030
$250 and $260
$220 and $230
2031
$260 and $300
$260 and $270
2032
$260 and $300
$260 and $270
2033
$280 and $300
$260 and $270
2034
$280 and $300
$260 and $270
a Rounded to 2 significant figures
b The monetized health benefits are quantified using two alternative concentration-response relationships from the Di et al. (2016)
and Turner et al. (2017) studies and presented at real discount rates of 3 and 7 percent.
Table 6-3: Undiscounted Net Benefits Estimates for the Less Stringent Alternative Option
(million 2022$), 2025-2034a
Year
3%
7%
2025
$91 and $93
$81 and $83
2026
$96 and $110
$92 and $96
2027
$96 and $110
$92 and $96
2028
$99 and $110
$92 and $96
2029
$99 and $110
$92 and $96
2030
$97 and $110
$90 and $94
2031
$99 and $120
$99 and $110
2032
$99 and $120
$99 and $110
2033
$110 and $120
$99 and $110
2034
$110 and $120
$99 and $110
a Rounded to 2 significant figures
b The monetized health benefits are quantified using two alternative concentration-response relationships from the Di et al. (2016)
and Turner et al. (2017) studies and presented at real discount rates of 3 and 7 percent.
6-3
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Table 6-4: Undiscounted Net Benefits Estimates for the More Stringent Alternative Option
(million 2022$), 2025-2034a
Year
3%
7%
2025
$240 and $240
$210 and $210
2026
$240 and $260
$220 and $230
2027
$240 and $260
$220 and $230
2028
$250 and $260
$220 and $230
2029
$250 and $260
$220 and $230
2030
$250 and $260
$220 and $230
2031
$250 and $290
$250 and $260
2032
$250 and $290
$250 and $260
2033
$270 and $290
$250 and $260
2034
$270 and $290
$250 and $260
a Rounded to 2 significant figures
b The monetized health benefits are quantified using two alternative concentration-response relationships from the Di et al. (2016)
and Turner et al. (2017) studies and presented at real discount rates of 3 and 7 percent.
6.2 Uncertainties and Limitations
Throughout the RIA, we considered a number of sources of uncertainty, both
quantitatively and qualitatively, regarding the benefits, and costs of the proposed NESHAP
amendments. We summarize the key elements of our discussions of uncertainty here:
• Projection methods and assumptions: The number of facilities in operation is
assumed to be constant over the course of the analysis period. Multiple facilities have
idled or closed over the last several years, and if this trend were to continue then the
costs and emissions impacts of the proposal may be overestimated. Unexpected
facility closure or idling affects the number of facilities subject to the proposed
amendments. We also assume 100 percent compliance with these proposed rules and
existing rules, starting from when the source becomes affected. If sources do not
comply with these rules, at all or as written, the cost impacts and emission reductions
may be overestimated. Additionally, new control technology may become available in
the future at lower cost, and we are unable to predict exactly how industry will
comply with the proposed rules in the future.
• Years of analysis: The years of the cost analysis are 2025, to represent the first-year
facilities are fully compliant with the proposed amendments, through 2034, to present
10 years of potential regulatory impacts, as discussed in Chapter 3. Extending the
6-4
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analysis beyond 2034 would introduce substantial and increasing uncertainties in the
projected impacts of the proposed regulations.
• Compliance Costs: There is uncertainty associated with the costs required to install
and operate the equipment and perform the work practices necessary to meet the
proposed emissions limits. There is also uncertainty associated with the exact controls
a facility may install to comply with the requirements, and the interest rate they are
able to obtain if financing capital purchases. There may be an opportunity cost
associated with the installation of environmental controls (for purposes of mitigating
the emission of pollutants) that is not reflected in the compliance costs included in
Chapter 3. If environmental investment displaces investment in productive capital, the
difference between the rate of return on the marginal investment (which is
discretionary in nature) displaced by the mandatory environmental investment is a
measure of the opportunity cost of the environmental requirement to the regulated
entity. To the extent that any opportunity costs are not included in the control costs,
the compliance costs presented above for this proposed action may be
underestimated. There is also uncertainty over which facilities will require fenceline
monitoring after the sunset provision takes effect after two years; to the extent some
facilities become exempt from these requirements, the costs presented in this RIA are
overstated.
• Emissions Reductions: Baseline emissions and projected emissions reductions are
based on AP-42 emissions factors, assumptions about current emissions controls, and
facility stack testing. To the extent that any of these data or assumptions are
unrepresentative, the emissions reductions (and therefore benefits) associated with the
proposed amendments could be over or underestimated.
• BPT estimates: All national-average BPT estimates reflect the geographic
distribution of the modeled emissions, which may not exactly match the emission
reductions that would occur due to the action, and they may not reflect local
variability in population density, meteorology, exposure, baseline health incidence
rates, or other local factors for any specific location. Recently, the EPA
systematically compared the changes in benefits, and concentrations where available,
6-5
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from its BPT technique and other reduced-form techniques to the changes in benefits
and concentrations derived from full-form photochemical model representation of a
few different specific emissions scenarios. Reduced form tools are less complex than
the full air quality modeling, requiring less agency resources and time. That work, in
which we also explore other reduced form models is referred to as the "Reduced
Form Tool Evaluation Project" (Project), began in 2017, and the initial results were
available at the end of 2018. The Agency's goal was to better understand the
suitability of alternative reduced-form air quality modeling techniques for estimating
the health impacts of criteria pollutant emissions changes in the EPA's benefit-cost
analysis. The EPA continues to work to develop refined reduced-form approaches for
estimating benefits. The scenario-specific emission inputs developed for this project
are currently available online. The study design and methodology are described in the
final report summarizing the results of the project, available at
.
• Non-monetized benefits: Numerous categories of health and welfare benefits are not
quantified and monetized in this RIA. These unquantified benefits, including benefits
from reductions in emissions of pollutants such as HAP which are to be reduced by
this proposed action, are described in detail in Chapter 4 of this RIA.
• PM health impacts: In this RIA, we quantify an array of adverse health impacts
attributable to emissions of PM. The Integrated Science Assessment for Particulate
Matter (U.S. EPA, 2019) identifies the human health effects associated with ambient
particles, which include premature death and a variety of illnesses associated with
acute and chronic exposures. As described in the TSD "Estimating PM2.5 and Ozone-
Attributable Health Benefits" (U.S. EPA, 2023b), EPA did not quantify endpoints
classified in the ISA as being "less than causally" related to PM2.5.
6-6
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03/documents/revi sedcsaprupdateriafinal. pdf.
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8 APPENDIX A
A summary of work practices incorporated into the baseline is given in Table 8-1 below.
The structure of the table is as follows. The column "Proposed Work Practice Standards and
Capital Investments" contains the proposed standards and an itemized list of work practices and
capital investments. The "Baseline Emissions Adjustments" column describes numerically how
baseline emissions calculations have been adjusted if a given work practice is already in use at a
facility. The "Emission Reductions" column describes how emission reductions have been
calculated based on the estimated baseline emissions at a facility.
For example, consider a BF at a hypothetical facility. This BF already conducts raw
material screening and includes devices at three locations to monitor material levels and inform
operators of static conditions. To estimate baseline emissions and reductions from unplanned
openings at this BF, the following procedure would be used:
1. Develop an initial estimate of baseline emissions, Ei, from emissions factors and
facility data on slips.
2. Adjust Ei by multiplying it by a factor [1 - 0.1 - 0.15] = 0.75. This gives a final
baseline emissions estimate E2 = 0.75*Ei.
3. Emissions reductions are calculated as [0.75-0.5]*Ei.
An analogous procedure is followed for each emissions source.
8-1
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Table 8-1: Summary of the Baseline Emission and Emission Reduction Estimates
Source
Proposed Work Practice Standards and Capital
Investments
Baseline Emissions
Adjustments
Emission
Reductions
BF Unplanned
Openings
("Slips")
Limit of 5 unplanned openings per year per BF
1. Install and operate devices to
continuously measure/monitor
material levels in the furnace, at a
minimum of three locations, using
alarms to inform operators of static
conditions that indicate a slip may
occur, and therefore, in turn, alert
facilities that there is a need to take
action to prevent the slips from
occurring.
2. Install and operate instruments on the
furnace to monitor temperature and
pressure to help determine when a
slip may occur.
3. Conduct raw material screening to
ensure only properly-sized raw
materials are charged into the BF.
4. Develop, and submit to the EPA for
approval, a plan that explains how the
facility will implement the above
requirements.
Applied a factor of [1 -
(sum of values presented
below)]
If work practice from
previous column is used:
Reduction of
([factor in previous
column]-0.5) *100
1.
0.1
2.
0.1
3.
0.15
4.
0.15
8% opacity limit
No proposed work practices
BF Planned
Openings
Updated using the
number of planned
openings each facility
gave us for the most
recent typical year.
Furnaces with an
opacity average of
8% or less were
estimated to have a
0% reduction.
Furnaces with an
average of x%
opacity (greater than
8%) were estimated
to have a reduction
of (x-8)/x, with a
max of 50%.
Facilities with no
opacity data were
assigned a default
reduction value of
50%.
BF Bell Leaks
1.
2.
If opacity is greater than 10 percent
(based on a 3-minute average), the
large bell seals will need to be
repaired or replaced within 4 months.
For the small bell, we are proposing
that facilities will need to replace or
repair seals prior to a metal
throughput limit, specified by the
facility, that has been proven and
Assumed 50% of
emissions come from the
large bell and 50% of
emissions come from the
small bell.
No adjustment was made
for furnaces with bell-
less tops or bells with
non-replaceable seals.
25% reduction for
all large bells.
Reduction of
([factor in previous
column]-0.75)* 100
for each small bell.
8-2
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Source
Proposed Work Practice Standards and Capital
Investments
Baseline Emissions
Adjustments
Emission
Reductions
documented to produce no opacity
from the small bells.
Applied a factor as low
as 0.75 for one furnace
based on how often
small bell seals were
reported to be replaced.
The current cost
estimates are based on
an assumption that the
small bell seals would
need to be repaired every
6 months under the
proposed rule. Furnaces
repairing their small bell
seal every 6 months or
less got a factor of 0.75.
The furnace with the
lowest reported
frequency of repairing
the bell seal got a factor
of 1. Facilities with a
frequency of x which is
between 6 months and
the max frequency got a
factor of l-0.25*(max
frequency - x)/(max
frequency).
BF Casthouse
Fugitives
5% opacity limit
Keep all openings, except roof monitors,
closed during tapping and material transfer
events (the only openings allowed during these
events are those that were present in the
original design of the shop).
No facility reported
using this work practice;
no adjustment made.
Reduction based on
comparing facility
opacity to proposed
opacity limit.
5% opacity limit
BOPF Shop
Fugitives
2.
Keep all openings, except roof
monitors (vents) and other openings
that are part of the designed
ventilation of the facility, closed
during tapping and material transfer
events (the only openings that would
be allowed during these events are the
roof vents and other openings or
vents that are part of the designed
ventilation of the facility) to allow for
more representative opacity
observations from a single opening.
Operators conduct regular inspections
of BOPF shop structure for
unintended openings and leaks.
Applied a factor of 1-
[sum of values presented
below (max 0.5)]
If work practice from
previous column is used:
1. 0.125
2. No adj.
3. 0.03
4. No adj.
5. ...
a. No adj.
b. 0.225
c. 0.03 for each i.-
iv.
Reduction of
([factor in previous
column]-0.5) *100
for one BOPF shop.
8-3
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Proposed Work Practice Standards and Capital Baseline Emissions Emission
Investments Adjustments Reductions
3. Optimize positioning of hot metal
ladles with respect to hood face and
furnace mouth.
4. Monitor opacity twice per month
from all openings, or from the one
opening known to have the highest
opacity, for a full steel cycle, which
must include a tapping event.
5. Develop and operate according to an
Operating Plan to minimize fugitives
and detect openings and leaks. We
are proposing that the BOPF Shop
Operating Plan shall include:
a. an explanation regarding
how the facility will address
and implement the four
specific work practices listed
above
b. a maximum hot iron
pour/charge rate
(pounds/second) for the first
20 seconds of hot metal
charge (i.e., the process of
adding hot iron from the BF
into the basic oxygen
process furnace)
c. A description of operational
conditions of the furnace and
secondary emission capture
system that must be met
prior to hot metal charge,
including:
i. A minimum
flowrate of the
secondary emission
capture system
during hot metal
charge
ii. A minimum
number of times,
but at least once,
the furnace should
be rocked between
scrap charge and
hot metal charge
iii. A maximum
furnace tilt angle
during hot metal
charging
iv. An outline of
procedures to
attempt to reduce
slopping.
8-4
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Source
Proposed Work Practice Standards and Capital
Investments
Baseline Emissions
Adjustments
Emission
Reductions
Iron Beaching
1.
2.
Have full or partial enclosures for the
beaching process or use C02 to
suppress fumes.
Minimize the height, slope, and speed
of beaching.
Applied a factor of 1-
[sum of values presented
below]
If work practice from
previous column is used:
1.
2.
0.125 for
enclosure;
0.125 for fume
supp.
0.25
Reduction of
([factor in previous
column]-0.5) *100
5% opacity limit
Slag Handling
1.
2.
Use a water system over pit areas,
and apply water to maintain moist
slag and reduce emissions during
digging and dumping
If the opacity from BF pit filling,
BOPF slag pit filling, BF pit digging;
BOPF slag pit digging, or slag
handling (either truck loading or
dumping slag to slag piles) exceed the
limit 2 6-minute events in one week,
subsequently install and use water fog
spray systems over that excess
emission operation, except on days
that, due to weather conditions,
applying fog spray would pose a
safety risk.
Applied a factor of 1-
[sum of values presented
below]
If work practice from
previous column is used:
Reduction of
([factor in previous
column]-0.5) *100
1.
2.
0.25
0.25
8-5
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United States Office of Air Quality Planning and Standards Publication No. EPA-452/R-23-004
Environmental Protection Health and Environmental Impacts Division June 2023
Agency Research Triangle Park, NC
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