Proposed Amendments to the Ferroalloys Production NESHAP



On October 6, 2014, the United States Environmental Protection Agency (EPA) published proposed amendments to the National Emission Standards for Hazardous Air Pollutants (NESHAPs) for Ferroalloys Production at major sources of HAP codified in Title 40, Code of Federal Regulations, Part 63 (40 CFR 63), Subpart XXX. This action supplements the amendments proposed on November 23, 2011, based on initial technology and residual risk reviews and considers the merits of the comments received on the 2011 proposal. This amendment presents the revised technology and residual risk reviews and proposes revisions to the standards and compliance requirements based on these revisions. EPA is not proposing any changes to the compliance dates set forth in the 2011 proposal.

The affected sources are facilities identified by NAICS 331110, Ferroalloys Production. The ferroalloys products that are the focus of the NESHAP are ferromanganese (FeMn) and silicomanganese (SiMn), which (according to EPA) are produced by two facilities in the United States: Eramet, located in Marietta, Ohio, and Felman, located in Letart, West Virginia.

The existing Ferroalloys Production NESHAP rule applies to process emissions from the submerged arc furnaces, the metal oxygen refining process and the product crushing equipment; process fugitive emissions from the furnace; and outdoor fugitive dust emissions sources such as roadways, yard areas and outdoor material storage and transfer operations. For the electric (submerged) arc furnace process, the NESHAP specifies numerical emissions limits for particulate matter (as a surrogate for non-mercury (or particulate) metal HAP). The NESHAP also includes emissions limits for particulate matter (again as a surrogate for particulate metal HAP) for process emissions from the metal oxygen refining process and product crushing and screening equipment.

The proposed amendments in the 2011 proposal which EPA is revisiting include the following:

  • Revisions to particulate matter (PM) standards for electric arc furnaces and local ventilation control devices;
  • Emission limits for mercury, polycyclic aromatic hydrocarbons (PAHs), and hydrochloric acid (HCl);
  • Proposed requirements to control process fugitive emissions based on full-building enclosure with negative pressure, or fenceline monitoring as an alternative;
  • A provision for emissions averaging;
  • Amendments to the monitoring, notification, recordkeeping and testing requirements; and
  • Proposed provisions establishing an affirmative defense to civil penalties for violations caused by malfunctions.

Further details on the proposed amendments can be obtained from the proposed rule published in the Federal Register on October 6, 2014.