| 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 | |
| A | B | C | D | E | |
|---|---|---|---|---|---|
| 2 | Tier 2 (Bullseye and Uroboros) | ||||
| 3 | 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 |
|||
| 5 | Cost Estimate | ||||
| 6 | low | high | |||
| 7 | Permitting costs | ||||
| 8 | NESHAP 6S applies? | Y | |||
| 9 | Needs Title V permit because of 6S? | Y | |||
| 10 | Cost of Title V application (including DEQ fees + consultant to prepare | $100,000 | $100,000 | this number isn't attributable to the art glass rule, so don't include in totals. | |
| 11 | Extra cost of Title V application due to art glass rule | $0 | $5,000 | ||
| 13 | Control Device Costs | ||||
| 14 | install baghouse | $250,000 | $300,000 | Assume install of 1 additional baghouse, above what would have been installed due to NESHAP 6S. | |
| 15 | annual operation | $15,000 | $70,000 | electricity, bag replacement etc | |
| 17 | Reporting Costs | ||||
| 18 | Annual cost to monitor and report on baghouse to DEQ | $12,000 | $12,000 | ||
| 20 | Source Testing Costs | ||||
| 21 | One-time source test to measure Cr6 emissions when making products containing Cr3 or Cr6 | $60,000 | $65,000 | Would require 16 hr runs just like baghouse efficiency, per Jill Inahara. 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. |
| 22 | One-time source test to demonstrate 99% PM control efficiency | $4,000 | $15,000 | length of run depends on detection limits, does not have to be entire production run to show capture efficiency. | |
| 24 | Modeling Costs | ||||
| 25 | One-time modeling to find max production rate that results in acceptable source impact level | ||||
| 26 | AERSCREEN model only | $10,000 | - | ||
| 27 | AERSCREEN followed by AERMOD model | - | $30,000 | ||
| 29 | Total Costs | ||||
| 30 | one-time costs | $324,000 | $415,000 | ||
| 31 | annual costs | $27,000 | $82,000 | ||
| A | B | C | D | E | F | G | H | |
|---|---|---|---|---|---|---|---|---|
| 2 | Tier 1 (Northstar, Trautman and Glass Alchemy) | |||||||
| 3 | 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 |
||||||
| 5 | Cost Estimate | |||||||
| 6 | If doing source test and modeling only | If installing control device | If taking permit condition to stop using metal HAPs | |||||
| 7 | low | high | low | high | low | high | ||
| 8 | Permitting costs | |||||||
| 9 | NESHAP 6S applies? | N | N | N | ||||
| 10 | Rule would require facility to get new permit | Yes, ACDP | Yes, ACDP | Yes, ACDP | ||||
| 11 | Application Fee | $ 14,400 | $ 14,400 | $ 14,400 | $ 14,400 | $ 14,400 | $ 14,400 | |
| 12 | Consultant to prepare application | - | - | - | - | - | - | |
| 13 | Annual Permit Fee (applies at time of application and each year after) | $ 9,216 | $ 9,216 | $ 9,216 | $ 9,216 | $ 9,216 | $ 9,216 | |
| 15 | Control Device Costs | |||||||
| 16 | install baghouse | - | - | $250,000 | $300,000 | - | - | |
| 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 metal emissions including total Cr. (Total Cr can be used as a proxy for Cr6) | $15,000 | $25,000 | |||||
| 24 | 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 | |
| 25 | One-time source test to demonstrate 99% PM control efficiency | - | - | $4,000 | $15,000 | - | - | |
| 27 | Modeling Costs | |||||||
| 28 | One-time modeling to find max production rate that results in acceptable source impact level | |||||||
| 29 | AERSCREEN model only | $10,000 | - | - | - | - | - | |
| 30 | AERSCREEN followed by AERMOD model | - | $30,000 | - | - | - | - | |
| 32 | Cost of reduced production | |||||||
| 33 | stopping production of materials containing Cr6 (required to take source test + modeling exemption) | ? | ? | - | - | 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. | ||
| 34 | reduced production if source testing shows it's needed to meet receptor conc limits | ? | ? | - | - | |||
| 36 | Total Costs | |||||||
| 37 | one-time costs | $24,400 | $109,400 | $268,400 | $329,400 | $14,400 | $14,400 | |
| 38 | annual costs | $9,216 | $9,216 | $36,216 | $91,216 | 50% of facility profit | ||
| 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? | 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 | |
|---|---|---|---|
| 1 | Baghouse install and operation costs | ||
| 4 | Cost Estimate for Northstar Glass to add baghouses, as listed by Abe Fleishman on the phone on 4/27/2016 | ||
| 6 | low | high | |
| 7 | $300,000 | $300,000 | installation of baghouse |
| 8 | $14,000 | $16,000 | electricity cost |
| 9 | $40,000 | $70,000 | new estimate of electricity cost 5/17 phone call with Abe |
| 10 | $15,000 | $70,000 | combined estimate |
| 12 | $12,000 | $12,000 | monitoring baghouse, assembling for reporting to DEQ (5/5/2016 estimate) |
| 13 | $8,000 | $10,000 | staff time to monitor and report results (previous estimate) |
| 16 | Cost estimate for Bullseye baghouse installation per phone call with Eric Durrin 5/13/2016 | ||
| 17 | $250k for purchase order for new baghouse to handle 11 furnaces. | ||
| A | B | C | D | |
|---|---|---|---|---|
| 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 | |
| A | |
|---|---|
| 2 | Talked with Thomas Rhodes at Horizon Environmental |
| 3 | Phone call 5/13/2016 |
| 5 | $65k for three, 16-hr runs at the big Tier 2 manufacturers. (Their batch process takes ~16 hrs) |
| 6 | If they could do the standard shorter runs (three, 1-3hr runs) then that would be $10k to $15k. |
| 8 | 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. |
| 10 | 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. |
| 11 | Total chrome and the other metals can all be tested with a single sample train. |
| 12 | If testing for Cr6, that requires a separate test run (with a separate sample train) so that would be another $65k. |
| 14 | 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. |
| 15 | 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. |
| 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 | |
|---|---|
| 3 | per phone conversation with Eric Durrin on 5/13/2016 |
| 5 | $250k for installation of baghouse and ductwork for control of 11 furnaces |
| 6 | may add additional baghouse to control additional furnaces later |
| 7 | could have HEPA filter (as added backup & for detection of leaks) at exit of baghouse |
| 8 | bags designed to last a certain number of purge cycles, about 7 years. |