A	B	C	D	E
1	DEQ Art Glass Permanent Rule
2	Fiscal Impact Estimate for proposed rule- Tier 2 CAGM
4	Tier 2 (Bullseye and Uroboros)
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	Incremental extra cost of Title V application due to art glass rule	$0	$5,000
13	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.
15	Control Device Costs
16	install baghouse	$250,000	$300,000	Assume install of 1 additional baghouse, above what would have been installed due to NESHAP 6S.
17	annual operation	$15,000	$70,000	electricity, bag replacement etc
19	Reporting Costs
20	Annual cost to monitor and report on baghouse to DEQ	$12,000	$12,000
22	Source Testing Costs
23	One-time source test to measure Cr6 emissions when making products containing Cr3 or Cr6	$60,000	$65,000	Assume this requires 16 hr 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 1-3 hr runs. If 16hr runs, $65k. If 4-day runs, $100k.
24	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.
26	Modeling Costs
27	One-time modeling to find max production rate that results in acceptable source impact level
28	AERSCREEN model only	$10,000	-
29	AERSCREEN followed by AERMOD model	-	$30,000
31	Total Costs
32	one-time costs	$324,000	$415,000
33	annual costs	$27,000	$82,000

	A	B	C	D	E	F	G	H
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 Source test & modeling to show impact below limits Request permit condition to not use metal HAPs
6		Cost Estimate
7		If doing source test and modeling only		If installing control device		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	$300,000	-	-
18	annual operation	-	-	$15,000	$70,000	-	-	electricity, bag replacement etc
20	Reporting Costs
21	Annual cost to monitor and report on baghouse to DEQ	-	-	$12,000	$12,000	-	-
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)	$0	$65,000	If Tier 1 and using control device, don't have to test for Cr6.		-	-	test length depends on detection limits
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	$32,200	$127,200	$261,200	$322,200	$7,200	$7,200
39	annual costs	$4,608	$4,608	$31,608	$86,608	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.

	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.
19	Talked with David Monro 5/16/2016
20	He used to work for a source testing company.
22	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.
23	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.
24	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.
25	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.
28	Estimate from Don Caniparoli at CH2M on phone 5/24/2016
29	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.

	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