| A | B | C | D | E | |
|---|---|---|---|---|---|
| 1 | DEQ Art Glass Permanent Rule | ||||
| 2 | Fiscal Impact Estimate for proposed rule- Bullseye Glass Company | ||||
| 4 | Bullseye- Tier 2 | ||||
| 5 | Requirements summary |
Install control device on all furnaces using metal HAPs. If using
chrome: source test & modeling to develop daily & annual max
usage Then follow the max usage limits |
|||
| 6 | Cost Estimate | ||||
| 7 | low | high | |||
| 8 | Permitting costs | ||||
| 9 | NESHAP 6S applies? | Y | |||
| 10 | Needs Title V permit because of 6S? | Y | |||
| 11 | 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. | |
| 12 | 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. | |
| 13 | 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. | |
| 14 | 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. | |
| 16 | Number of Control Devices | ||||
| 17 | # 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. | |
| 19 | Costs Per Control Device | ||||
| 20 | install baghouse | $250,000 | $400,000 | ||
| 21 | One-time source test to demonstrate 99% PM control efficiency | $4,000 | $15,000 | Assume length of run depends on detection limits, does not have to be entire production run to show capture efficiency. | |
| 22 | annual operation | $15,000 | $70,000 | electricity, bag replacement etc | |
| 23 | Annual cost to monitor and report on baghouse to DEQ | $12,000 | $17,000 | ||
| 24 | Total one-time costs per baghouse | $254,000 | $415,000 | ||
| 25 | Total annual costs per baghouse | $27,000 | $87,000 | ||
| 27 | Source Testing Costs | ||||
| 28 | 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 99% control efficiency test, reducing cost. | $10-15k if test can be done in 1-3 hr runs. If 16hr runs, $65k. If 4-day runs, $100k. |
| 30 | Modeling Costs | ||||
| 31 | One-time modeling to find max production rate that results in acceptable source impact level | ||||
| 32 | AERSCREEN model only | $10,000 | - | ||
| 33 | AERSCREEN followed by AERMOD model | - | $30,000 | ||
| 35 | Total Costs | ||||
| 36 | If 0 additional baghouses installed | ||||
| 37 | One-time costs | $70,000 | $100,000 | ||
| 38 | Annual costs | $0 | $0 | ||
| 40 | If 2 additional baghouses installed | ||||
| 41 | One-time costs | $578,000 | $930,000 | ||
| 42 | Annual costs | $54,000 | $174,000 | ||
| A | B | C | D | |
|---|---|---|---|---|
| 1 | DEQ Art Glass Permanent Rule | |||
| 2 | Fiscal Impact Estimate for proposed rule- Uroboros Glass Studios, Inc. | |||
| 4 | Uroboros- Tier 2 | |||
| 5 | Requirements summary |
Install control device on all furnaces using metal HAPs. If using
chrome: source test & modeling to develop daily & annual max
usage Then follow the max usage limits |
||
| 6 | Cost Estimate | |||
| 7 | low | high | ||
| 8 | Permitting costs | |||
| 9 | NESHAP 6S applies? | Y | ||
| 10 | Needs Title V permit because of 6S? | Y | ||
| 11 | 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. |
| 12 | 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. |
| 13 | 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.) |
| 14 | 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. |
| 16 | Number of Control Devices | |||
| 17 | # 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. |
| 19 | Costs Per Control Device | |||
| 20 | install baghouse | $355,000 | $610,000 | |
| 21 | One-time source test to demonstrate 99% PM control efficiency | included in source testing cost below | Assume length of run depends on detection limits, and does not have to be entire production run to show capture efficiency. | |
| 22 | annual operation | $15,000 | $70,000 | electricity, bag replacement etc |
| 23 | Annual cost to monitor and report on baghouse to DEQ | $12,000 | $17,000 | |
| 24 | Total one-time costs per baghouse | $355,000 | $610,000 | |
| 25 | Total annual costs per baghouse | $27,000 | $87,000 | |
| 27 | Source Testing Costs | |||
| 28 | One-time source test to measure Cr6 emissions when making products containing Cr3 or Cr6 | $56,000 | $56,000 | |
| 30 | Modeling Costs | |||
| 31 | One-time modeling to find max production rate that results in acceptable source impact level | |||
| 32 | AERSCREEN model only | $10,000 | - | |
| 33 | AERSCREEN followed by AERMOD model | - | $30,000 | |
| 35 | Total Costs | |||
| 36 | If 0 additional baghouses installed | |||
| 37 | One-time costs | $66,000 | $89,000 | |
| 38 | Annual costs | $0 | $0 | |
| 40 | If 1 additional baghouse installed | |||
| 41 | One-time costs | $421,000 | $699,000 | |
| 42 | Annual costs | $27,000 | $87,000 | |
| A | B | C | D | E | F | G | |
|---|---|---|---|---|---|---|---|
| 1 | DEQ Art Glass Permanent Rule | ||||||
| 2 | Fiscal Impact Estimate for proposed rule- Tier 1 CAGM | ||||||
| 4 | Tier 1 (Northstar, Trautman and Glass Alchemy) | ||||||
| 5 | 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 | |||||
| 6 | Cost Estimate | ||||||
| 7 | If installing control device | If doing source test and modeling only | If taking permit condition to stop using metal HAPs | ||||
| 8 | low | high | low | high | low | high | |
| 9 | Permitting costs | ||||||
| 10 | NESHAP 6S applies? | N | N | N | |||
| 11 | Rule would require facility to get new permit | Yes, ACDP | Yes, ACDP | Yes, ACDP | |||
| 12 | Application Fee | $ 7,200 | $ 7,200 | $ 7,200 | $ 7,200 | $ 7,200 | $ 7,200 |
| 13 | Consultant to prepare application | - | - | - | - | - | - |
| 14 | Annual Permit Fee (applies at time of application and each year after) | $ 4,608 | $ 4,608 | $ 4,608 | $ 4,608 | $ 4,608 | $ 4,608 |
| 16 | Control Device Costs | ||||||
| 17 | Install baghouse | $250,000 | $400,000 | - | - | - | - |
| 18 | Annual operation (electricity, bag replacement etc) | $15,000 | $70,000 | - | - | - | - |
| 20 | Reporting Costs | ||||||
| 21 | Annual cost to monitor and report on baghouse to DEQ | $12,000 | $17,000 | - | - | - | - |
| 23 | Source Testing Costs | ||||||
| 24 | 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 | ||||
| 25 | 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 | - | - | |
| 26 | One-time source test to demonstrate 99% PM control efficiency | $4,000 | $15,000 | - | - | - | - |
| 28 | Modeling Costs | ||||||
| 29 | One-time modeling to find max production rate that results in acceptable source impact level | ||||||
| 30 | AERSCREEN model only | - | - | $10,000 | - | - | - |
| 31 | AERSCREEN followed by AERMOD model | - | - | - | $30,000 | - | - |
| 33 | Cost of reduced production | ||||||
| 34 | 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. | |
| 35 | Reduced production if source testing shows it's needed to meet receptor conc limits | - | - | unknown | unknown | ||
| 37 | Total Costs | ||||||
| 38 | One-time costs | $261,200 | $422,200 | $32,200 | $127,200 | $7,200 | $7,200 |
| 39 | Annual costs | $31,608 | $91,608 | $4,608 | $4,608 | 50% of facility profit (?) | |
| 40 | One-time costs (rounded) | $261,000 | $422,000 | $32,000 | $127,000 | $7,000 | $7,000 |
| 41 | Annual costs (rounded) | $32,000 | $92,000 | $5,000 | $5,000 | 50% of facility profit (?) | |
| A | B | C | |
|---|---|---|---|
| 1 | Baghouse install and operation costs | ||
| 3 | Cost Estimate for Northstar Glass to add baghouses, as listed by Abe Fleishman on the phone on 4/27/2016 | ||
| 5 | low | high | |
| 6 | $300,000 | $300,000 | installation of baghouse |
| 7 | $14,000 | $16,000 | electricity cost |
| 8 | $40,000 | $70,000 | new estimate of electricity cost 5/17 phone call with Abe |
| 9 | $15,000 | $70,000 | combined estimate |
| 11 | $12,000 | $12,000 | monitoring baghouse, assembling for reporting to DEQ (5/5/2016 estimate) |
| 12 | $8,000 | $10,000 | staff time to monitor and report results (previous estimate) |
| 15 | Cost estimate for Bullseye baghouse installation per phone call with Eric Durrin 5/13/2016 | ||
| 16 | $250k for purchase order for new baghouse to handle 11 furnaces. | ||
| 18 | Cost estimate for monitoring and reporting from 5/27/2016 fiscal advisory committee meeting | ||
| 19 | $0 | per year | monitoring and reporting cost, if computer control system produces the data DEQ needs. But, this didn't consider annual baghouse inspection etc. |
| 20 | $17,000 | per year | upper limit on monitoring and reporting cost, based on labor rate + time to perform estimate |
| 22 | Phone conversation with Eric Durrin (Bullseye) on 5/31/2016 | ||
| 23 | Baghouse 1: currently online and handling 2 furnaces | ||
| 24 | Baghouse 2: being brought online now. Will handle 1 furnace and can later be connected to 1 more furnace | ||
| 25 | Baghouse 3: contractors are plumbing and connecting electrical. Will handle 11 furnaces. | ||
| 26 | Baghouse 4: in planning, will start after install and testing of baghouse 3. "Another large baghouse", so it may be same scale as Baghouse 3. After this baghouse is installed, the smaller baghouse 1 and 2 could be repurposed. | ||
| 28 | Eric was not able to say how many furnaces are large enough to be subject to 6S, so difficult to know how many baghouses are 'additional'. | ||
| 29 | Some furnaces are subject to 6S, and some baghouse would be required due to that. I think that estimating 1 additional baghouse is likely to be accurate. I could estimate zero to two. | ||
| 31 | Phone conversation with Eric Lovell (Uroboros) on 5/31/2016 | ||
| 32 | low | high | |
| 33 | $350,000 | $550,000 | baghouse install |
| 34 | $35,000 | $55,000 | 10% contingency on baghouse install |
| 35 | $5,000 | $5,000 | City of Portland mechanical permit |
| 36 | $355,000 | $610,000 | low / high estimates on baghouse install |
| A | B | C | D | |
|---|---|---|---|---|
| 1 | Dispersion modeling cost estimate | |||
| 3 | Phone conversation with Don Caniparoli of CH2M on 5/13/2016 | |||
| 5 | air modeling can be done approximating the multiple stacks as one stack | |||
| 6 | parameters needed: | |||
| 7 | emissions velocity and temperature | |||
| 8 | stack height | |||
| 9 | mass emissions rate (g/hr) | |||
| 10 | topographic data (depends on model) | |||
| 11 | met data (depends on model | |||
| 14 | from simplest and most conservative to more complex: | |||
| 15 | $3k-5k | SCREEN3 | simplest screening model, EPA recommends AERSCREEN as its replacement | |
| 16 | $10k | AERSCREEN | EPA recommended screening model | |
| 17 | $20k | AERMOD | "full modeling", requires hourly met data | |
| 19 | One approach is to go straight to AERMOD. Or, you could start with the simplest and move on if needed based on the results. | |||
| 20 | The modeling could tell you the maximum mass mass emissions rate (g/hr) that will keep the conc at the receptor below the required limit. So you could calculate your max production rate from that, for each pollutant. | |||
| 21 | The above costs are per-facility and not per-pollutant. It doesn't have to be run for each pollutant individually. | |||
| 22 | https://www3.epa.gov/scram001/dispersion_screening.htm | |||
| 24 | Summary cost: | |||
| 25 | $10,000 | low | AERSCREEN only | |
| 26 | $30,000 | high | AERSCREEN then AERMOD | |
| 29 | Talked with Phil Allen at DEQ on 5/23/2016. He thought that the $10k for AERSCREEN, or $30k total for AERSCREEN + AERMOD sounded about right. | |||
| A | |
|---|---|
| 1 | Source testing cost estimate |
| 3 | Talked with Thomas Rhodes at Horizon Environmental |
| 4 | Phone call 5/13/2016 |
| 6 | $65k for three, 16-hr runs at the big Tier 2 manufacturers. (Their batch process takes ~16 hrs) |
| 7 | If they could do the standard shorter runs (three, 1-3hr runs) then that would be $10k to $15k. |
| 9 | The smaller manufacturers use a process that may take 4 days. If source testing had to take place over that entire 4 days, that would be approx $100k. |
| 11 | This is for DEQ method 5 testing at 1 stack. If multiple stacks had to be tested, that would almost be a multiple of the cost. |
| 12 | Total chrome and the other metals can all be tested with a single sample train. |
| 13 | If testing for Cr6, that requires a separate test run (with a separate sample train) so that would be another $65k. |
| 15 | Can't test for Cr6 at the same time as filterable particulate because Cr6 test requires recirculating a fluid to the tip of the sample intake. That fluid would wet and block the filter. |
| 16 | Can test for filterable particulate and metals (total Cr, Cd As etc) in a single sampling train, as long as you aren't testing for Cr6. |
| 18 | Talked with David Monro 5/16/2016 |
| 19 | He used to work for a source testing company. |
| 21 | To test 99% baghouse filterable PM capture efficiency you don't need to measure an entire production run. You just need to compare the input vs the output over a time period long enough that detection limits allow you to demonstrate that if input is X, output is 0.01X. David estimates $4k to $6k for this kind of test if can be done with standard 1-hr runs. |
| 22 | To measure Cr3 conversion to Cr6 you'd need to source test over the entire production run, so that'd be 16hrs per run for the big facilities. David estimated $60k for Cr6 testing with 16 hr runs. |
| 23 | Tier 1 facilities that opt for source testing + modeliing would be testing for metals instead of PM. Their run length might be determined by modeling, which would show what detection limit was needed in order to show whether emissions were above / below source impact limits. David estimated this testing would be about $15k to $25k. |
| 24 | Tier 1 facilities that opt for source testing + modeling have the option to assume all Cr is Cr6 for modeling purposes. If they chose for some reason to test for Cr6 conversion their cost would also likely be about $60k. |
| 26 | Estimate from Don Caniparoli at CH2M on phone 5/24/2016 |
| 27 | Based on a conversation with a CH2M coworker, Don estimated that a source test for filterable PM and metals (not Cr6) with short 1 to several hour runs would cost $15k. |
| 29 | Estimate from Eric Lovell on phone 5/31/2016 |
| 30 | $56k for complete source test. I assume that means testing the control device meets 99% as well as Cr3 to Cr6 conversion. |
| A | B | C | |
|---|---|---|---|
| 1 | Title V application fee estimate | ||
| 4 | Estimate from Don Caniparoli at CH2M on phone 5/24/2016 | ||
| 5 | low | high | |
| 6 | $25,000 | $50,000 | cost of consultant to prepare Title V app |
| 9 | Estimate from Eric Durrin by phone | ||
| 10 | $100,000 | cost of consultant and DEQ Title V application fees | |
| 12 | Estimate of Title V annual fees from DEQ rules | ||
| 13 | http://arcweb.sos.state.or.us/pages/rules/oars_300/oar_340/340_220.html | ||
| 14 | $0 | no application fee for Title V permits | |
| 15 | $7,910 | annual base fee for 2016. Adjusted annually for inflation. | |
| 16 | $59.81 | emissions fee, per ton of emissions | |
| 17 | low | high | |
| 18 | 40 | 60 | tons of emissions per year (PM10, SO2, Nox) |
| 19 | $2,392 | $3,589 | emissions fee |
| 20 | $2,400 | $3,600 | emissions fee estimate (rounded) |
| 21 | $10,310 | $11,510 | total annual Title V permit fees |
| 24 | combined estimate | ||
| 25 | low | high | |
| 26 | $25,000 | $100,000 | initial cost for consultant to prepare Title V app |
| 27 | $10,310 | $11,510 | annual Title V permit fees |
| 29 | Phone call with Eric Lovell on 5/31/2016 he estimated that his emissions fees would be $500/year. | ||
| 30 | $500 | emissions fees | |
| 31 | $7,910 | annual base fee | |
| 32 | $8,500 | total annual Title V permit fees (rounded) | |
| 34 | $15,000 | $50,000 | consultant to prepare Title V application |
| 35 | $1,500 | $5,000 | 10% contingency on consultant for Title V application |
| 36 | $15,000 | $55,000 | low / high estimates on consultant for Title V application |
| A | |
|---|---|
| 1 | Should legal and financing costs be included? |
| 3 | Phone conversation with Susan Fairchild at US EPA 6/6/2016 |
| 4 | She was involved in EPA's NESHAP 6S rulemaking. |
| 6 | EPA does not include legal fees in the compliance cost estimate for a rule, but it does include costs for reading & understanding the rule |
| 7 | EPA annualizes the initial costs (for purchasing and installing a baghouse, for example), and that estimate includes estimated financing costs. |
| 8 | Susan suggested I contact Larry Sorrels, an EPA economist who can explain more about how that is done. |
| 11 | Phone conversation with Larry Sorrels, economist with the US EPA |
| 12 | US EPA does control equipment cost estimation using the EPA Air Pollution Control Cost Manual |
| 13 | https://www3.epa.gov/ttn/ecas/cost_manual.html |
| 14 | EPA converts capital costs to an annual cost over the assumed lifetime of the equipment. |
| 15 | For baghouses, they assume a 20-year life |
| 16 | EPA uses a 7% assumed interest rate, which is determined by the US Office of Management and Budget (OMB). |
| 17 | Calculation uses a Capital Recovery Factor to annualize the one-time costs, according to a formula that uses equipment lifetime & interest rate. |
| 18 | There are examples in Section 1 Chapter 2 and in Section 6 Chapter 1. |