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.
Other Regulatory Gaps
EPA identified two unregulated HAP emitted by BF and BOPF (HCl 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 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.
Sinter Plants
Dioxins/Furans and Polycyclic 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.
Other Regulatory Gaps
EPA identified five unregulated HAP emitted by sinter plants (CS2, COS, HCl, 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.
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.
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.
Emissions Reduction Analysis
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 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 Emissions[a]

                                   Pollutant

                                 Tons per Year
                                      HAP
                                                                            280

                                      PM
                                                                          8,100

                                     PM2.5
                                                                          2,100
                                   2025-2034
                                      HAP
                                                                          2,800

                                      PM
                                                                         81,000

                                     PM2.5
                                                                         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[a]

                                   Pollutant

                                Grams per Year
                                  D/F TEQ[b]
                                     9.07
                                 Tons per Year
                                      PAH
                                       6
                                   2025-2034
                                    D/F TEQ
                                     90.1

                                      PAH
                                      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.
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 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[a]

                                Less Stringent
                                   Proposed
                                 Tons per Year
                                      HAP
                                      39
                                      79

                                      PM
                                     1,100
                                     2,300

                                     PM2.5
                                      240
                                      560
                                   2025-2034
                                      HAP
                                      390
                                      790

                                      PM
                                    11,000
                                    23,000

                                     PM2.5
                                     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 PAH[a]

                                Grams per Year
                                  D/F TEQ[b]
                                      8.2
                                 Tons per Year
                                      PAH
                                       5
                                   2025-2034
                                    D/F TEQ
                                      82

                                      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.

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 PAH[a]
                                      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)[a]
                   Fugitive or Intermittent Emissions Source
                                      PM
                                     PM2.5
                                      HAP
                             Reduction 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%
[a] Totals may not sum due to independent rounding. Numbers rounded to two significant digits unless otherwise noted.

Engineering Cost Analysis
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$.
Fugitive or Intermittent Particulate Sources
Table 3-9 presents total capital investment and annualized costs for proposed and less stringent alternative option for fugitive sources. The less stringent alternative option maintains the current 20 percent opacity limit for BF casthouse and BOPF shop fugitive emissions but are otherwise identical the proposed option. The increased opacity limit for BF casthouse and BOPF shop fugitive emissions account for approximately 27 percent of total capital investment, 27 percent of annual operation and maintenance (O&M) cost, and 59 percent of annualized testing/MRR cost for the proposed fugitive source standards. These estimates include the cost of labor and capital equipment necessary to implement the necessary work practices to meet the limits and monitor compliance.
Table 3-9: Summary of Total Capital Investment and Annual Costs per Year for Fugitive or Intermittent Particulate Sources (2022$)[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.

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 Cost[b]
                             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.

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.
 REF _Ref132191305 \h -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.
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 Cost[b]
                             Cleveland-Cliffs Inc.
                                 Burns Harbor
                                      $0
                                      $0
                                    $15,000

                                Indiana Harbor
                                      $0
                                      $0
                                   $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 Cost[b]
                             Cleveland-Cliffs Inc.
                                 Burns Harbor
                                   $240,000
                                   $550,000
                                   $590,000

                                Indiana Harbor
                                   $240,000
                                   $550,000
                                   $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.
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), 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
                             Cleveland-Cliffs Inc.
                                 Burns Harbor
                                   $100,000
                                   $160,000
                                   $200,000

                                   Cleveland
                                   $100,000
                                   $160,000
                                   $200,000

                                   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
                                  U.S. Steel
                                  Mon Valley
                                   $100,000
                                   $160,000
                                   $200,000

                                     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.

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.

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 Cost[b]
                             Cleveland-Cliffs Inc.
                                 Burns Harbor
                                   $910,000
                                   $320,000
                                   $520,000

                                   Cleveland
                                   $680,000
                                   $370,000
                                   $650,000

                                   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
                                  U.S. Steel
                                  Mon Valley
                                  $1,100,000
                                   $350,000
                                   $750,000

                                     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 Cost[b]
                             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.

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 Cost[b]
                             Cleveland-Cliffs Inc.
                                 Burns Harbor
                                  $1,100,000
                                   $870,000
                                  $1,100,000

                                   Cleveland
                                   $680,000
                                   $370,000
                                   $650,000

                                   Dearborn
                                   $250,000
                                   $260,000
                                   $380,000

                                Indiana Harbor
                                  $1,500,000
                                  $1,000,000
                                  $1,500,000

                                  Middletown
                                   $360,000
                                   $270,000
                                   $370,000

                                  Firm Total
                                  $3,900,000
                                  $2,800,000
                                  $4,000,000
                                  U.S. Steel
                                  Mon Valley
                                  $1,100,000
                                   $350,000
                                   $750,000

                                     Gary
                                  $1,300,000
                                  $1,600,000
                                  $1,900,000

                                 Granite City
                                   $850,000
                                   $340,000
                                   $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.

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.

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.

Human Health Benefits of Emissions Reductions
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.
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.
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.
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).
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 (ATSDR, 2020). EPA has determined that Pb is a probable human carcinogen (Group 2B) (U.S. EPA, 2004).
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).
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 for Cr+3 toxicity, similar to Cr+6. EPA has not classified Cr+3 with respect to carcinogenicity (U.S. EPA, 1998c).
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).
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[ 1,2,3-c,d]pyrene, as probable human carcinogens (Group B2).
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, (HCl), and hydrogen fluoride (HF). Information regarding the health effects of those compounds can be found in the EPA's IRIS database.
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 PM2.5-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 PM2.5 -and Ozone  -  Attributable Health Benefits (TSD) (U.S. EPA, 2023b) ADDIN CSL_CITATION {"citationItems":[{"id":"ITEM-1","itemData":{"author":[{"dropping-particle":"","family":"U.S. EPA","given":"","non-dropping-particle":"","parse-names":false,"suffix":""}],"id":"ITEM-1","issued":{"date-parts":[["2018"]]},"number":"1.3","publisher":"U.S. EPA","publisher-place":"Research Triangle Park, North Carolina","title":"Environmental Benefits Mapping and Analysis Program--Community Edition (BenMAP-CE)","type":"article"},"uris":["http://www.mendeley.com/documents/?uuid=08f3ad07-dbeb-4b0b-9989-aadc92d5d4e2"]}],"mendeley":{"formattedCitation":"(U.S. EPA 2018)","plainTextFormattedCitation":"(U.S. EPA 2018)","previouslyFormattedCitation":"(U.S. EPA 2018)"},"properties":{"noteIndex":0},"schema":"https://github.com/citation-style-language/schema/raw/master/csl-citation.json"}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 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.
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 PM2.5 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 PM2.5 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 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 PM2.5 and whether they were Quantified and/or Monetized in this RIA
                                   Category
                                    Effect
                               Effect Quantified
                               Effect Monetized
                               More Information
Premature mortality from exposure to PM2.5
Adult premature mortality from long-term exposure (age 65-99 or age 30-99)
                                      ü
                                      ü
PM ISA

Infant mortality (age <1)
                                      ü
                                      ü
PM ISA
Nonfatal morbidity from exposure to PM2.5
Heart attacks (age > 18)
                                      ü
                                      ü
PM ISA

Hospital admissions -- cardiovascular (ages 65-99)
                                      ü
                                      ü
PM ISA

Emergency department visits --  cardiovascular (age 0-99)
                                      ü
                                      ü
PM ISA

Hospital admissions -- respiratory (ages 0-18 and 65-99)
                                      ü
                                      ü
PM ISA

Emergency room visits -- respiratory (all ages)
                                      ü
                                      ü
PM ISA

Cardiac arrest (ages 0-99; excludes initial hospital and/or emergency department visits)
                                      ü
                                      ü
PM ISA

Stroke (ages 65-99)
                                      ü
                                      ü
PM ISA

Asthma onset (ages 0-17)
                                      ü
                                      ü
PM ISA

Asthma symptoms/exacerbation (6-17)
                                      ü
                                      ü
PM ISA

Lung cancer (ages 30-99)
                                      ü
                                      ü
PM ISA

Allergic rhinitis (hay fever) symptoms (ages 3-17)
                                      ü
                                      ü
PM ISA

Lost work days (age 18-65)
                                      ü
                                      ü
PM ISA

Minor restricted-activity days (age 18-65)
                                      ü
                                      ü
PM ISA

Hospital admissions -- Alzheimer's disease (ages 65-99)
                                      ü
                                      ü
PM ISA

Hospital admissions -- Parkinson's disease (ages 65-99)
                                      ü
                                      ü
PM ISA

Other cardiovascular effects (e.g., other ages)
                                       --
                                       --
PM ISA

Other respiratory effects (e.g., pulmonary function, non-asthma ER visits, non-bronchitis chronic diseases, other ages and populations)
                                       --
                                       --
PM ISA

Other nervous system effects (e.g., autism, cognitive decline, dementia)
                                       --
                                       --
PM ISA

Metabolic effects (e.g., diabetes)
                                       --
                                       --
PM ISA

Reproductive and developmental effects (e.g., low birth weight, pre-term births, etc.)
                                       --
                                       --
PM ISA

Cancer, mutagenicity, and genotoxicity effects
                                       --
                                       --
PM ISA

Quantifying Cases of PM2.5-Attributable Premature Death
      This section summarizes our approach to estimating the incidence and economic value of the PM2.5-related ancillary co-benefits estimated for this rule. In December of 2022, EPA published the Regulatory Impact Analysis (RIA) for the proposed Particulate Matter National Ambient Air Quality Standards (U.S. EPA, 2023c). EPA quantified the PM-related benefits of this rule prior to publishing of the proposed PM NAAQS RIA. For this reason, the PM-related 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) program 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.
Following this approach, we report the estimated PM2.5-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."  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.
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 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 $6.3 million (2000$).
      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).
Monetized PM2.5 Benefits
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 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. In particular, the SAB assessed: the techniques the Agency used to appraise these tools; the Agency's approach for depicting the 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 project. 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.
PM2.5 Benefits Results
     Table 4-2 lists the estimated PM2.5-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 PM2.5-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  REF _Ref125616450 \h -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  REF _Ref126757764 \h - REF _Ref126757767 \h -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.
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
                                      PV
                                      970
                                      and
                                     1,000

                                      700
                                      and
                                      740

                                     2,300
                                      and
                                     2,400

                                     1,700
                                      and
                                     1,700
                                      EAV
                                      110
                                      and
                                      120

                                      94
                                      and
                                      98

                                      260
                                      and
                                      280

                                      220
                                      and
                                      230
[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$), 2025-2034[a][,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
[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$), 2025-2034[a][,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.
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.

Economic Impact Analysis and Distributional Assessments
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.

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.
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. 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. 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

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
                            Ultimate Parent Company
                            Regulatory Alternative
                         2021 Revenue (million 2022$)
                    Total Annualized Cost  (million 2022$)
                                TAC-Sales Ratio
                             Cleveland-Cliffs Inc.
                                Less Stringent
                                    $21,742
                                     $0.9
                                    0.0042%

                                   Proposed

                                     $2.9
                                    0.013%

                                More Stringent

                                     $4.0
                                    0.018%
                                  U.S. Steel
                                Less Stringent
                                    $21,562
                                     $0.8
                                    0.0038%

                                   Proposed

                                     $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
                             Cleveland-Cliffs Inc.
                                Less Stringent
                                    $21,742
                                     $2.2
                                    0.010%

                                   Proposed

                                     $3.4
                                    0.016%

                                More Stringent

                                     $3.9
                                    0.018%
                                  U.S. Steel
                                Less Stringent
                                    $21,562
                                     $2.0
                                    0.0093%

                                   Proposed

                                     $2.8
                                    0.013%

                                More Stringent

                                     $3.3
                                    0.015%

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.
 SEQ CHAPTER \h \r 1Small 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. 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.

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.
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).

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
                                    $2,400
                                     $260
                                      and
                                     $280
                                     $970
                                      and
                                    $1,000
                                     $110
                                      and
                                     $120
                                    $2,300
                                      and
                                    $2,500
                                     $260
                                      and
                                     $280
                               Compliance Costs
                                     $39
                                     $4.6
                                      $18
                                     $2.1
                                     $59
                                     $6.9
                                 Net Benefits
                                    $2,300
                                      and
                                    $2,400
                                     $260
                                      and
                                     $280
                                     $950
                                      and
                                     $980
                                     $110
                                      and
                                     $120
                                    $2,200
                                      and
                                    $2,300

                                     $250
                                      and
                                     $270
                                      7%

                           Monetized Health Benefits
                                    $1,700
                                      and
                                    $1,700
                                     $220
                                      and
                                     $230
                                     $700
                                      and
                                     $740
                                      $94
                                      and
                                      $98
                                    $1,700
                                      and
                                    $1,700
                                     $220
                                      and
                                     $230
                               Compliance Costs
                                     $32
                                     $4.6
                                     $15
                                     $2.1
                                     $47
                                     $6.7
                                 Net Benefits
                                    $1,700
                                      and
                                    $1,700
                                     $220
                                      and
                                     $230
                                     $690
                                      and
                                     $730
                                      $92
                                      and
                                      $96
                                    $1,700
                                      and
                                    $1,700
                                     $210
                                      and
                                     $220
                            Non-monetized Benefits
                                  79 tpy HAP
                                  39 tpy HAP
                   79 tpy HAP, 8.2 grams/year D/F, 5 tpy PAH

                 Health effects of reduced exposure to HAP[c]

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[d]
[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.

     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$), 2025-2034[a,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.

STYLEREF 1 \s-SEQ Table \* ARABIC \s 1: Undiscounted Net Benefits Estimates for the Less Stringent Alternative Option (million 2022$), 2025-2034[a]
                                    Year
                                      3%
                                      7%

[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$), 2025-2034[a]
                                    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.

Table 6-4: Undiscounted Net Benefits Estimates for the More Stringent Alternative Option (million 2022$), 2025-2034[a]
                                     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.

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 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, 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 <https://www.epa.gov/sites/production/files/2019-11/documents/rft_combined_report_10.31.19_final.pdf>.
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.

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