From: Shawn R. McCutchan <SMcCutchan@fpiwv.com>

Sent: Monday, April 09, 2012 5:44 PM

To: Jeff Harris; 'Beth Friedman'; John Konrady

Cc: r.powell@optimaacq.com; ALincoln@bdlaw.com; Kevin Shumate; Vitaliy Anosov;

thillier@policynavigation.com; jgledhill@policynavigation.com; Chin.Conrad@epamail.epa.gov

Subject: RE: Felman cost data

Jeff,

In answer to your questions.

1) Yes, the costs are based on the fact that we already have the tilters. They are structurally in sound

condition, but need some modifications to ensure we can capture the emissions safely. I would say the

cost of a retrofit depends on how much of the existing system you would need to change to get the

desired results. In our case we were able to use the existing design, while making a few modifications

that allows us to safely capture the emissions. There are other tilter designs that have advantages over

ours, but as we are a small company and with the current market condi tions, we could not financially

justify replacing our current tilters.

2) The $1,000,000 estimate covers the cost of a new design tilter, hydraulic system, and the

installation for this equipment including the enclosure. What I did not figure in th is price would be the

demolition and removal of the existing system, which would also be required as the other tilter designs I

have looked at have a completely different footprint and could require the existing foundation to be

removed and a new founda tion installed. The cost for this I would estimate to be an additional

$100,000

- $150,000.

3) Yes, that is about right for a greenfield installation. By greenfield, I mean an installation in an area

where no existing equipment exists. I did not pursue this avenue any further than our initial estimates,

because it did not make any sense to do so. Also, as we already have existing duct work, fans, and

dampers that tie the tilters into our baghouse, I have no cost data for the engineering, material, or

installation for the required fans, dampers, or duct work that would be required to capture the

emissions.

If you need any further clarification please feel free to contact me>

Thanks,

Shawn

From: Jeff Harris [mailto:harris.j eff@ecrweb.com]

Sent: Saturday, April 07, 2012 7:11 PM

To: Shawn R. McCutchan; 'Beth Friedman'; John KonradyCc: r.powell@optimaacq.com; ALincoln@bdlaw.com; Kevin Shumate; Vitaliy Anosov;

thillier@policynavigation.com; jgledhill@policynavigation.com; Chin.Conrad@epamail.epa.gov

Subject: RE: Felman cost data

Shawn,

Thanks for your reply. I am Jeff Harris, a contractor engineer assisting Conrad Chin of the EPA with the

Ferroalloys RTR NESHAP.

Your response was helpful, but I would like to ask for a couple of clarifications:

1) To be clear

- Is the reason that your retrofit costs were so much lower than the estimated new

system cost because Felman didn’t have to purchase the tilters, you already owned them? I would

typically expect a retrof it to cost MORE than a comparable new installation.

2) Does the $1M cost estimate for a new tilter include the other elements as well (hydraulics,

enclosure, etc.)?

3) So if those assumptions are correct, then the overall cost breakdown for each casting station would

be roughly like this:

a. Ladle tilter $600K

b. hydraulics, enclosure $200K

c. Labor, engineering $200K

Is that about right? Or have I made a mistaken assumption?

Thanks again for your help with this,

Jeff

_____________________ Jeff Harris

EC/R Incorporated

harris.jeff@ecrweb.com

www.ecrweb.com

(919) 433

- 8335

OR (919) 484

- 0222 ext 335

From: Shawn R. McCutchan [mailto:SMcCutch an@fpiwv.com]

Sent: Friday, April 06, 2012 6:40 PM

To: Beth Friedman; John Konrady

Cc: r.powell@optimaacq.com; ALincoln@bdlaw.com; Kevin Shumate; Vitaliy Anosov;thillier@policynavigation.com; jgledhill@policynavigation.com; Chin.Conrad@epamail.epa.go v;

harris.jeff@ecrweb.com

Subject: RE: Felman cost data

Beth,

Good evening, I hope you are having a wonder Good Friday.

I am Shawn McCutchan, Maintenance/Engineering/ and Equipment Reliability Manager at Felman

Production, LLC. I am the one who developed the cost analysis for you and Mr. Chin. In answer to your

question below

, i f you look at Felman’s response on 2A, you will note that the cost estimate for a new

tilter was $1,000,000 each. There are three ( 3) tilters at our plant so the total cost for replacing the

tilters would be $3,000,000. The cost for the upgrades on each of the tilters in 2B of our response was

under $400,000 each. The retrofit cost is less than 1⁄2 the cost of a tilter, including th e ladle tilter,

hydraulic system, and building enclosure around the ladle.

If you have any other questions please feel to contact Mr. Konrady or myself.

Shawn

From: Beth Friedman [mailto:friedman.beth@ecrweb.com]

Sent: Thursday, April 05, 2012 4:31 P M

To: John Konrady

Cc: r.powell@optimaacq.com; ALincoln@bdlaw.com; Shawn R. McCutchan; Kevin Shumate; Vitaliy

Anosov; thillier@policynavigation.com; jgledhill@policynavigation.com; Chin.Conrad@epamail.epa.gov;

harris.jeff@ecrweb.com

Subject: Felman co st data

John

—

Thanks you so much for providing the cost data. It is very helpful.

We do have a question on the casting upgrade costs. Are we correct in assuming that the “retrofit”

costs include the ladle tilter, hydraulic system, and building encl osure around the ladle tilter, including

the removable lid? If so, we are curious why the cost of the retrofitted complete system is less

expensive than the cost of a new ladle tilter and hydraulic system. Can you provide any more details?

Beth