DEQ Art Glass Permanent Rule
Fiscal Impact Estimate for proposed rule- Tier 2 CAGM
Tier 2 (Bullseye and Uroboros) | |||
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 | ||
Cost Estimates | |||
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. |
Incremental extra cost of Title V application due to are glass rule | $0 | $5,000 | |
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. |
Control Device Costs | |||
Install baghouse | $250,000 | $300,000 | Assume install of 1 additional baghouse, above what would have been installed due to NESHAP 6S. |
Annual operation | $15,000 | $70,000 | Electricity, bag replacement etc |
Reporting Costs | |||
One-time source test to measure Cr6 emissions when making products containing Cr3 or Cr6 | $60,000 | $65,000 | Assume this requires 16hr runs. At some facilities, may be able to run concurrently with 99% control efficiency test, reducing cost. $10-15k if test can be done in 1-3hr runs. If 16hr runs, $65k. If 4-day runs, $100k. |
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. |
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 | |||
One-time costs | $324,000 | $415,000 | |
Annual costs | $27,000 | $82,000 | |
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 Source test & modeling to show impact below limits Request permit condition to not use metal HAPs | |||||
Cost Estimate | ||||||
If doing source test and modeling only | If installing control device | 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 | $300,000 | - | - |
Annual operation (electricity, bag replacement, etc) | - | - | $15,000 | $70,000 | - | - |
Reporting Costs | ||||||
Annual cost to monitor and report on baghouse to DEQ | - | - | $12,000 | $12,000 | - | - |
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) | $0 | $65,000 | If Tier 1 and using control device, don’t have to test for Cr6 | - | - | |
One-time source test to demonstrate 99% PM control efficiency | - | - | $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 | $17,200 | $102,200 | $261,200 | $322,200 | $7,200 | $7,200 |
Annual costs | $4,608 | $4,608 | $31,608 | $86,608 | 50% of facility profit (?) | |