| A | B | C | D | E | F | |
|---|---|---|---|---|---|---|
| 1 | Fiscal Impact Estimate | |||||
| 2 | text in red means it needs to be confirmed. | |||||
| 4 | Company | Bullseye Glass | Uroboros Glass | Northstar Glassworks | Trautman Art Glass | Glass Alchemy |
| 5 | Tier | Tier 2 | Tier 2 | Tier 1 | Tier 1 | Tier 1 |
| 6 | 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 |
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 |
|||
| 7 | Total # of furnaces | 20 | 8 | 60 | 40 | 30 |
| 8 | # of furnaces subject to NESHAP 6S | 1+ ? | 1+ ? | none | none | none |
| 9 | # of furnaces using any of 6 metal HAPs | |||||
| 10 | # of furnaces using chrome | |||||
| 12 | Permitting | |||||
| 13 | Currently has ACDP? | Y | N | N | N | N |
| 14 | NESHAP 6S applies? | Y | DEQ says yes, but Uroboros disputes interpretation of 'continuous'. | N | N | N |
| 15 | Art Glass rule will require facility to get additional permit? | required to get Title V because of NESHAP 6S. Already has ACDP | required to get Title V because of NESHAP 6S? Not clear. | Yes, ACDP | Yes, ACDP | Yes, ACDP |
| 16 | Application Fee | $ - | $ - | $ 14,400 | $ 14,400 | $ 14,400 |
| 17 | Consultant to prepare application | $ - | $ - | |||
| 18 | Annual Permit Fee | $ - | $ - | $ 9,216 | $ 9,216 | $ 9,216 |
| 20 | Small Business Status | |||||
| 21 | # of employees | 120 | 30 | 20 | ? | ? |
| 22 | Is a small business? | N | Y | Y | N | N |
| A | B | C | |
|---|---|---|---|
| 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 | old estimate of electricity cost |
| 8 | $40,000 | $70,000 | new estimate of electricity cost 5/17 phone call with Abe |
| 10 | $8,000 | $14,000 | source testing |
| 11 | $50,000 | $90,000 | new 5/5/2016 estimate for source testing (if test method change does not pass EQC on 5/5/2016) |
| 12 | $10,000 | $25,000 | new 5/5/2016 estimate for source testing (if test method change does pass EQC on 5/5/2016)) |
| 14 | $12,000 | $12,000 | monitoring baghouse, assembling for reporting to DEQ (5/5/2016 estimate) |
| 15 | $8,000 | $10,000 | staff time to monitor and report results (previous estimate) |
| 17 | $7,000 | $9,000 | Abe's estimate of initial permit costs |
| 18 | $6,000 | $10,000 | Abe's estimate of annual 'upkeep' costs on the permit |
| 19 | $40,000 | $40,000 | cost to replace the filters, every 4-6 years |
| 22 | 5/17/2016 phone conversation with Abe: | ||
| 23 | Tier 1 facilities have about $2M to $3M per year of total sales in a year | ||
| 25 | Tier 1 furnace runs last about 32 to 48 hours, with raw materials added slowly over time to reduce time needed for air bubbles to work their way out. | ||
| 26 | One batch in a furnace would hold about 28 to 60 lbs of glass. Maybe as much as 75 lbs. | ||
| 28 | Abe suggested that cadmium should be treated like Cr 6. Cadmium has a low melting point, so according to Abe only 20% of it ends up in the glass. | ||
| 29 | 80% goes up the stack. So, Abe feels that Tier 1 facilities shouldn't be able to use cadmium in an uncontrolled furnace. (Just as they can't use Cr6). | ||
| 31 | Abe said that it's easy to measure the amount of metals in the end product glass, and easy to measure what's in the raw materials. | ||
| 32 | You could have a conservative estimate of emissions just using a mass balance approach. | ||
| A | B | |
|---|---|---|
| 4 | Based on email from Paul Trautman 5/12/2016 | |
| 5 | may have to move if landlord doesn't allow install of control device | |
| 6 | $2,072,000 | "cash outlay" for moving the building |
| 7 | $1,105,000 | in lost revenue due to move |
| 9 | Based on phone call with Paul Trautman 5/13/2016 | |
| 10 | does not want to consider source test + modeling due to regulatory environment. Wants flexibility of operation and materials used. | |
| 11 | Does not know what the result of modeling would be, has heard that modeling would cost $15k to $80k and have to be done for each pollutant. | |
| A | B | |
|---|---|---|
| 3 | per phone conversation with Eric Durrin on 5/13/2016 | |
| 4 | $250k for installation of baghouse and ductwork for control of 11 furnaces | |
| 5 | may add additional baghouse to control additional furnaces later | |
| 6 | could have HEPA filter (as added backup & for detection of leaks) at exit of baghouse | |
| 7 | bags designed to last a certain number of purge cycles, about 7 years. | |
| 9 | per phone conversation with Eric Durrin 5/31/2016 | |
| 10 | (see also baghouse tab) | |
| 11 | Bullseye plans to install baghouses to cover all furnaces, even ones that don't use the metal HAP. | |
| 13 | Eric will see if another Bullseye person could be available to attend a 2nd fiscal advisory committee meeting if one is held. | |
| 14 | Eric went through the 4 questions DEQ is required to see input on: | |
| 15 | Question | Eric's Answer |
| 16 | 1. Would the rule have a fiscal impact? | Yes |
| 17 | 2. If so, what is the extent of that impact? | [didn't answer this one] |
| 18 | 3. Would the rule have a significant adverse impact on small businesses? | Yes |
| 19 | 4. If so, can the economic impact be reduced, consistent with the public health and safety purpose of the rule | Eric didn't see a way the economic impact could be reduced and still meet the purpose of the rule. |
| A | B | C | D | E | |
|---|---|---|---|---|---|
| 1 | Phone conversation with Eric Lovell 5/31/2016 | ||||
| 2 | All furnances at Uroboros were under the NESHAP 6S thresholds in 2015, but Eric thinks that may not always be true | ||||
| 3 | So, Eric is assuming Uroboros will need to comply with 6S and get a Title V. | ||||
| 4 | Uroboros will only need one baghouse for the entire facility. Some furnaces that don't use the metal HAP will not be controlled with the baghouse. | ||||
| 5 | Uroboros would be adding between zero and 1 baghouses because of this proposed rule, over and above what they would do anyway due to NESHAP 6S. | ||||
| 7 | low | high | |||
| 8 | $350,000 | $550,000 | baghouse install, with city mechanical permit | ||
| 9 | $35,000 | $55,000 | 10% contingency on baghouse install | ||
| 10 | $350,000 | $605,000 | low / high estimates on baghouse install | ||
| 12 | $56,000 | $56,000 | cost estimate for source testing | ||
| 14 | $15,000 | $50,000 | consultant to prepare Title V application | ||
| 15 | $1,500 | $5,000 | 10% contingency on consultant for Title V application | ||
| 16 | $15,000 | $55,000 | low / high estimates on consultant for Title V application | ||
| 18 | $8,000 | $8,000 | annual Title V permit fee | ||
| 19 | $500 | $500 | annual Title V emissions fee | ||
| 21 | $421,000 | $716,000 | initial cost | ||
| 22 | $8,500 | $8,500 | annual cost | ||
| A | B | C | D | E | F | G | |
|---|---|---|---|---|---|---|---|
| 1 | Fiscal Impact Estimate | ||||||
| 3 | Company | Bullseye Glass | Uroboros Glass | Northstar Glassworks | Trautman Art Glass | Glass Alchemy | total |
| 4 | Tier | Tier 2 | Tier 2 | Tier 1 | Tier 1 | Tier 1 | |
| 5 | One-time costs | ||||||
| 6 | low estimate | $324,000 | $324,000 | $24,400 | $24,400 | $24,400 | $721,200 |
| 7 | high estimate | $415,000 | $415,000 | $329,400 | $329,400 | $329,400 | $1,818,200 |
| 8 | |||||||
| 9 | Annual costs | ||||||
| 10 | low estimate | $27,000 | $27,000 | $9,216 | $9,216 | $9,216 | $81,648 |
| 11 | high estimate | $82,000 | $82,000 | $91,216 | $91,216 | $91,216 | $437,648 |
| 12 | |||||||
| 13 | |||||||
| 14 | Unique considerations for this facility | may move factory if current landlord doesn't allow construction of baghouse. They estimate that would cost $2M plus $1M in lost revenue. | |||||
| 16 | Small Business Status | ||||||
| 17 | # of employees | 120 | 30 | 20 | ? | ? | |
| 18 | Is a small business? | N | Y | Y | Y | Y | |