Attachment A
Fiscal Impact Calculations
DEQ Art Glass Permanent Rule
Fiscal Impact Estimate for proposed rule- Bullseye Glass Company
Bullseye - Tier 2 | |||
Requirements summary | Install control device on all furnaces using glassmaking HAPs. If using chrome: source test & modeling to develop daily & annual max usage | ||
Cost Estimate | |||
low | high | ||
Permitting costs | |||
NESHAP 6S applies? | Y | ||
Needs Title V permit because of 6S | Y | ||
Cost of Title V application (including DEQ fees + consultant to prepare) | $25,000 | $100,000 | If a facility needs a Title V due to NESHAP 6S, that is independent of this art glass rule, so this cost isn't included in the totals. |
Annual DEQ Title V permit costs | $10,310 | $11,510 | If a facility needs a Title V due to NESHAP 6S, that is independent of this art glass rule, so this cost isn't included in the totals. |
Incremental extra cost of Title V application due to art glass rule | $0 | $5,000 | Assume preparing the permit application would cost 0% to 5% more because of the incremental addition of the proposed rules. |
Incremental extra cost of Title V annual permit fees due to art glass rule | $0 | $0 | The proposed rules would not increase the annual permit fees if the facility would have a Title V anyway. |
Number of Control Devices | |||
# of additional baghouses installed, over and above what would have been installed due to NESHAP 6S alone | 0 | 2 | This is uncertain because changes to comply with NESHAP 6S are happening at the same time as efforts to comply with this rule. |
Cost Per Control Device | |||
Install baghouse | $250,000 | $400,000 | |
Install baghouse leak detection system or HEPA afterfilter | $10,000 | $30,000 | |
One-time ‘grain loading’ source test to demonstrate baghouse is working | $4,000 | $15,000 | Assume length of run depends on detection limits, does not have to be entire production run. |
Annual operation | $15,000 | $70,000 | Electricity, bag replacement etc |
Annual cost to monitor and report on baghouse to DEQ | $12,000 | $17,000 | |
Total one-time costs per baghouse | $264,000 | $445,000 | |
Total annual costs per baghouse | $27,000 | $87,000 | |
Source Testing Costs | |||
One-time source test to measure Cr6 emissions when making products containing Cr3 or Cr6 | $60,000 | $65,000 | Assume 16 hr test runs. May be able to run concurrently with grain loading test, reducing cost. $10-15k if test can be done in 1-3 hr runs. If 16hr runs, $65k. If 4-day runs, $100k. |
Modeling Costs | |||
One-time modeling to find max production rate that results in acceptable source impact level | |||
AERSCREEN model only | $10,000 | - | |
AERSCREEN followed by AERMOD model | - | $30,000 | |
Total Costs
If 0 additional baghouses installed | |||
One-time costs | $70,000 | $100,000 | |
Annual costs | $0 | $0 | |
If 2 additional baghouses installed | |||
One-time costs | $598,000 | $990,000 | |
Annual costs | $54,000 | $174,000 | |
DEQ Art Glass Permanent Rule
Fiscal Impact Estimate for proposed rule- Uroboros Glass Studios, Inc.
Uroboros - Tier 2 | |||
Requirements summary | Install control device on all furnaces using glassmaking HAPs. If using chrome: source test & modeling to develop daily & annual max usage | ||
Cost Estimate | |||
low | high | ||
Permitting costs | |||
NESHAP 6S applies? | Y | ||
Needs Title V permit because of 6S? | Y | ||
Cost of Title V application (including DEQ fees + consultant to prepare) | $15,000 | $55,000 | If a facility needs a Title V due to NESHAP 6S, that is independent of this art glass rule, so this cost isn't included in the totals. |
Annual DEQ Title V permit costs | $8,500 | $8,500 | If a facility needs a Title V due to NESHAP 6S, that is independent of this art glass rule, so this cost isn't included in the totals. |
Incremental extra cost of Title V application due to art glass rule | $0 | $3,000 | Assume preparing the permit application would cost 0% to 5% more because of the incremental addition of the proposed rules. (Rounded to the nearest thousand.) |
Incremental extra cost of Title V annual permit fees due to art glass rule | $0 | $0 | The proposed rules would not increase the annual permit fees if the facility would have a Title V anyway. |
Number of Control Devices | |||
# of additional baghouses installed, over and above what would have been installed due to NESHAP 6S alone | 0 | 1 | This is uncertain because changes to comply with NESHAP 6S are happening at the same time as efforts to comply with this rule. |
Cost Per Control Device | |||
Install baghouse | $355,000 | $610,000 | |
Install baghouse leak detection system or HEPA afterfilter | $10,000 | $30,000 | |
One-time ‘grain loading’ source test to demonstrate baghouse is working | Included in source testing cost below | Assume length of run depends on detection limits, does not have to be entire production run. | |
Annual operation | $15,000 | $70,000 | Electricity, bag replacement etc |
Annual cost to monitor and report on baghouse to DEQ | $12,000 | $17,000 | |
Total one-time costs per baghouse | $365,000 | $640,000 | |
Total annual costs per baghouse | $27,000 | $87,000 | |
Source Testing Costs | |||
One-time source test to measure Cr6 emissions when making products containing Cr3 or Cr6 | $56,000 | $56,000 | |
Modeling Costs | |||
One-time modeling to find max production rate that results in acceptable source impact level | |||
AERSCREEN model only | $10,000 | - | |
AERSCREEN followed by AERMOD model | - | $30,000 | |
Total Costs
If 0 additional baghouses installed | |||
One-time costs | $66,000 | $89,000 | |
Annual costs | $0 | $0 | |
If 1 additional baghouse installed | |||
One-time costs | $431,000 | $729,000 | |
Annual costs | $27,000 | $87,000 | |
DEQ Art Glass Permanent Rule
Fiscal Impact Estimate for proposed rule- Tier 1 CAGM
Tier 1 (Northstar, Trautman and Glass Alchemy) | ||||||
Requirements summary | Do 1 of these at all furnaces: Install control device, OR source test & modeling to show impact below limits, OR request permit condition to not use metal HAPs | |||||
Cost Estimate | ||||||
If installing control device | If doing source test and modeling only | If taking permit condition to stop using metal HAPs | ||||
low | high | low | high | low | high | |
Permitting costs | ||||||
NESHAP 6S applies? | N | N | N | |||
Rule would require facility to get new permit | Yes, ACDP | Yes, ACDP | Yes, ACDP | |||
Application Fee | $7,200 | $7,200 | $7,200 | $7,200 | $7,200 | $7,200 |
Consultant to prepare application | - | - | - | - | - | - |
Annual Permit Fee (applies at time of application and each year after) | $4,608 | $4,608 | $4,608 | $4,608 | $4,608 | $4,608 |
Control Device Costs | ||||||
Install baghouse | $250,000 | $400,000 | - | - | - | - |
Install baghouse leak detection system or HEPA afterfilter | Optional, can do this instead of grain loading test | |||||
Annual operation (electricity, bag replacement, etc) | $15,000 | $70,000 | - | - | - | - |
Reporting Costs | ||||||
Annual cost to monitor and report on baghouse to DEQ | $12,000 | $17,000 | - | - | - | - |
Source Testing Costs | ||||||
One-time source test to measure metal emissions including total Cr. (Total Cr can be used as a proxy for Cr6) | - | - | $15,000 | $25,000 | - | - |
One-time source test to measure Cr6 emissions when making products containing Cr3 (optional) | If Tier 1 and using control device, don’t have to test for Cr6 | $0 | $65,000 | - | - | |
One-time ‘grain loading’ source test to demonstrate baghouse is working | $4,000 | $15,000 | - | - | - | - |
Modeling Costs | ||||||
One-time modeling to find max production rate that results in acceptable source impact level | ||||||
AERSCREEN model only | - | - | $10,000 | - | - | - |
AERSCREEN followed by AERMOD model | - | - | - | $30,000 | - | - |
Cost of reduced production | ||||||
Stopping production of materials containing Cr6 (required to take source test + modeling exemption) | - | - | unknown | unknown | About 1/2 of products contain metal HAPs. There may not be workable substitute formulations. Facilities may choose to phase out one or a few metal HAPs but are likely to choose source test & modeling or installation of a control device. | |
Reduced production if source testing shows it's needed to meet receptor conc limits | - | - | unknown | unknown | ||
Total Costs | ||||||
One-time costs | $261,200 | $422,200 | $32,200 | $127,200 | $7,200 | $7,200 |
Annual costs | $31,608 | $91,608 | $4,608 | $4,608 | 50% of facility profit (?) | |
One-time costs (rounded) | $261,000 | $422,000 | $32,000 | $127,000 | $7,000 | $7,000 |
Annual costs (rounded) | $32,000 | $92,000 | $5,000 | $5,000 | 50% of facility profit (?) | |