Attachment 1:

Cost Estimate Provided by Eramet Marietta

Estimated Costs For Potential Fugitive Particulate Control Modifications 

at Eramet Marietta Inc. (as of 11/22/2013) 

The costs estimates below represent the current estimates of the costs to implement and 

operate additional fugitive particulate controls at the Eramet Marietta Inc. facility. These 

estimates are necessarily general due to the fact that control strategies are conceptual and no 

detailed design work has been conducted. Although a 30% contingency has been incorporated in 

the estimates due to the status of the design, no contingency to account for anticipated start-up 

and shakedown costs has been included and EMI therefore believes the actual costs of 

implementing the described controls are likely to be higher. 

Furnace 1: 

 Tapping Hood – Modify hood to increase capture efficiency, vented to existing tapping 

baghouse. 

 Casting Hood – Install capture system (hood) for casting operations, vented to existing 

tapping baghouse. 

 Roof Ventilation – Partition roof canopy (above crane rails) to contain fugitive emissions, 

vented through roof monitors to existing furnace baghouse via ducts. 

1) Furnace 1: Tapping Fan Upgrade 

a. Equipment/materials costs 

i. Ductwork, ID Fan, Dampers, Actuators, Electrical $ 228,000 

ii. Instrumentation 11,000 

iii. Taxes 12,000 

iv. Freight 13,000 

b. Installation cost (inc. labor) 26,000 

c. Engineering & design costs 53,000

 Subtotal $ 343,000 

2) Furnace 1: Casting Hood 

a. Equipment/materials costs 

i. Hood, Ductwork, Dampers, Actuators, Electrical $ 432,000 

ii. Instrumentation 22,000 

iii. Taxes 26,000 

iv. Freight 22,000 

b. Installation cost (inc. labor) 130,000 
‐ 2 ‐ 

c. Engineering & design costs 100,000

Subtotal $ 732,000 

3) Furnace 1: Roof Ventilation 

a. Equipment/materials costs 

i. Ductwork, Hood, Dampers, Structural Steel, Electrical $ 1,093,000 

ii. Instrumentation 109,000 

iii. Taxes 66,000 

iv. Freight 55,000 

 

b. Installation cost (inc. labor) 1,335,000 

c. Engineering & design costs 423,000

Subtotal $ 3,081,000 

 Furnace 1 Total Equipment, Installation, Engineering $ 4,156,0001

 Furnace 1 Retrofit Costs (Downtime) CBI2

 Furnace 1 Annualized Capital Cost Recovery3 $ 392,297 

 Furnace 1 Annual O&M Costs $ 461,211 

 Furnace 1 Annualized Costs (Capital plus O&M) $ 853,508

 

                                                           

1

 Estimate does not include an additional contingency that would be appropriate to account for 

expected start-up and shakedown costs associated with integration of new abatement equipment. 

2

 Downtime costs based on estimated lost sales, which involves confidential business 

information (CBI). These costs are provided under separate cover and should be treated as CBI. 

3

 Calculated in 2012 dollars for 20-year useful life at 7% interest rate in accordance with 

methodology provided in “Engineering Review of Proposed Ferroalloy NESHAP Requirements 

for Eramet Marietta Inc.” (ENVIRON International Corp. 2012), included as Appendix B to 

EMI’s January 31, 2012 comments on proposed NESHAP. The estimated annualized capital 

cost presented does not include any portion of estimated retrofit costs attributable to furnace 

downtime. 
‐ 3 ‐ 

Furnace 12: 

 Tapping Hood – Modify hood to increase capture efficiency, vented to existing scrubber. 

 Roof Ventilation – Partition roof canopy (above crane rails) to contain fugitive emissions, 

vented through roof monitors to existing scrubber via ducts. 

 Upgrades to existing scrubber OR installation of secondary dust collector 

1) Furnace 12: Roof Ventilation/Tap System Capture 

a. Equipment/materials costs 

i. Ductwork, Hood, Dampers, Structural Steel, Electrical $ 1,385,000 

ii. Scrubber Upgrades OR Dust Collector 7,318,000 

iii. Instrumentation 261,000 

iv. Taxes 522,000 

v. Freight 435,000 

 

b. Installation cost 4,956,000 

c. Engineering & design costs 2,183,000

Furnace 12 Total Equipment, Installation, Engineering $ 17,060,0004

 Furnace 12 Retrofit Costs (Downtime) CBI5

 Furnace 12 Annualized Capital Cost Recovery6 $ 1,474,377 

 Furnace 12 Annual O&M Costs $ 2,178,599 

 Furnace 12 Annualized Costs (Capital plus O&M) $ 3,652,975

 

                                                           

4

 Estimate does not include an additional contingency that would be appropriate to account for 

expected start-up and shakedown costs associated with integration of new abatement equipment. 

5

 Downtime costs based on estimated lost sales, which involves confidential business 

information (CBI). These costs are provided under separate cover and should be treated as CBI. 

6

 Calculated in 2012 dollars for 20-year useful life at 7% interest rate in accordance with 

methodology provided in “Engineering Review of Proposed Ferroalloy NESHAP Requirements 

for Eramet Marietta Inc.” (ENVIRON International Corp. 2012), included as Appendix B to 

EMI’s January 31, 2012 comments on proposed NESHAP. The estimated annualized capital 

cost presented does not include any portion of estimated retrofit costs attributable to furnace 

downtime. 
‐ 4 ‐ 

MOR: 

 Casting Hood – Modify hood to increase capture efficiency, vented to existing MOR 

baghouse. 

 Roof Ventilation – Partition roof canopy (above crane rails) to contain fugitive emissions, 

vented through roof monitors to existing MOR baghouse via ducts. 

1) MOR: Roof Ventilation/Casting Hood 

a. Equipment/materials costs 

i. Roof Modification/Repair $ 650,000 

ii. Ductwork, Hood, Dampers, Structural Steel, Electrical 801,000 

iii. Instrumentation 145,000 

iv. Taxes 87,000 

v. Freight 73,000 

b. Installation cost (inc. labor) 1,613,000 

c. Engineering & design costs 562,000

MOR Total Equipment, Installation, Engineering $ 3,931,0007

 MOR Retrofit Costs (Downtime) CBI8

 MOR Annualized Capital Cost Recovery9 $ 371,059 

 MOR Annual O&M Costs $ 329,586 

 MOR Annualized Costs (Capital plus O&M) $ 700,644

                                                           

7

 Estimate does not include an additional contingency that would be appropriate to account for 

expected start-up and shakedown costs associated with integration of new abatement equipment. 

8

 Downtime costs based on estimated lost sales, which involves confidential business 

information (CBI). These costs are provided under separate cover and should be treated as CBI. 

9

 Calculated in 2012 dollars for 20-year useful life at 7% interest rate in accordance with 

methodology provided in “Engineering Review of Proposed Ferroalloy NESHAP Requirements 

for Eramet Marietta Inc.” (ENVIRON International Corp. 2012), included as Appendix B to 

EMI’s January 31, 2012 comments on proposed NESHAP. The estimated annualized capital 

cost presented does not include any portion of estimated retrofit costs attributable to furnace 

downtime. 
Attachment 2:

Cost Estimate Provided by Felman Production

Answers for EPA 

1. Tapping upgrades:

A. Changing to a drill and plug gun to more efficiently open and close the tap hole 

1. No. 2 Furnace tapping drill and plugging gun:

a. Equipment: $460,000 (ordered 11/2010)

b. Original Structure: $56,000

c. Original Engineering: $5,000

d. Engineering: $10,000.

e. Installation: $30,000.

f. First drill and gun expected arrival mid-April 2012

g. Second drill and gun expected delivery mid-May 2012

h. Total: $561,000

2. No. 5 furnace tapping drill and plugging gun:

a. Original Equipment: $202,000 (purchased in 2007/2008). 

b. Original Structure: $21,000

c. Original Engineering: $2,000

d. Equipment Modifications in 2011-2012: $17,000

e. Engineering for modifications in 2012: $5,000

f. Manpower for conversion in 2011-2012: $3,000

g. Engineering to convert to hydraulics: $2,000

h. Equipment to convert to hydraulics: $50,000

i. Manpower to convert to hydraulics: $20,000

j. Total: $322,000

3. No. 7 furnace tapping drill and plugging gun:

a. Original Equipment: $202,000 (purchased in 2007/2008).

b. Original Structure: $21,000

c. Original Engineering: $2,000

d. Equipment Modifications in 2011-2012: $17,000

e. Engineering for modifications in 2012: $5,000

f. Manpower for conversion in 2011-2012: $3,000

g. Engineering to convert to hydraulics: $2,000

h. Equipment to convert to hydraulics: $50,000

i. Manpower to convert to hydraulics: $20,000

j. Total: $322,000

B. Increasing the size of the tapping hood: This is included in 2B below.

C. Increasing tapping hood ventilation (new baghouse fan/fan housing)

1. No. 2 Furnace Baghouse: Planned for 2013 Capital-Change to 2014/2015 due to market conditions

a. New baghouse fan/fan housing, inlet damper, outlet damper, transitions (2 Required): $ 900,000.

b. Installation labor: $200,000.

c. Baghouse engineering study: $9,000.

d. Fan design engineering: included in cost of equipment.

e. Expansion Joint /ductwork replacement: $220,000.

f. Total: $1,329,000.

2. No. 2 Furnace tapping hood modifications (planned 2013): Change to 2014/2015 due to market conditions

a. Replacement of tapping / pouring damper equipment: $50,000.

b. Ductwork modification materials: $20,000.

c. Installation labor: $60,000.

d. Engineering: $20,000.

e. Total: $150,000.

3. No. 5 Furnace Baghouse (May 2012): 

a. New baghouse fan / fan housing, inlet damper, outlet damper, transition: $450,000.

b. Installation labor: $70,000.

c. Baghouse engineering study: $9,000.

d. Fan design engineering: included in cost of equipment.
Answers for EPA 

e. Expansion Joint /ductwork replacement: $220,000.

f. Total: $749,000.

4. No. 7 Furnace Baghouse (3rd Quarter 2012)-Due to market conditions Furnace is currently Shutdown. There is 

no specific start up plans at this time.

a. New baghouse fan / fan housing, inlet damper, outlet damper, transition: $450,000.

b. Installation labor: $70,000.

c. Baghouse engineering study: $9,000.

d. Fan design engineering: included in cost of equipment.

e. Expansion Joint /ductwork replacement: $220,000.

f. Total: $749,000.

D. Adding a tapping platform enclosure.

1. No. 2 Furnace:

a. Materials to enclose both tap holes: $30,000.

b. Labor for enclosing both tap holes: $20,000.

c. Engineering: $5,000.

d. Total: $55,000.

2. No. 5 Furnace:

a. Materials to extend platform and enclose tap hole: $40,000.

b. Labor for extending platform and enclosing tap hole: $20,000.

c. Engineering: $10,000.

d. Total: $70,000.

3. .No. 7 Furnace:

a. Materials to extend platform and enclose tap hole: $40,000.

b. Labor for extending platform and enclosing tap hole: $20,000.

c. Engineering: $10,000.

d. Total: $70,000.

E. Extending No. 7 Tilter Fume capture system to No. 9 Rake-out.

1. Engineering: $5,000.

2. Materials: $30,000.

3. Labor: $25,000.

4. Total: $60,000.

2. Casting Upgrades.

A. Add a ladle tilter and hydraulic system (retrofit vs. purchase new equipment) - The cost of designing, purchasing, and 

installation of a new system is estimated to be $1,000,000 per tilter. Retrofit cost is included in 2B below.

B. Building enclosure around ladle tilter, including movable lid.

1. No. 2 Tilter: Completed 07/2011

a. Engineering: $10,000.

b. Materials: $170,000.

c. Labor: $165,000.

d. Total: $ 345,000.

2. No. 5 Tilter: Initial modification cost 11/2010.

a. Engineering: $5,000.

b. Materials: $100,000.

c. Labor: $80,000.

d. Total: $185,000.

3. No. 5 Tilter: Final modifications. (6/30/2012)

a. Engineering: $5,000.

b. Materials: $100,000.

c. Labor: $100,000.

d. Total: $205,000.

4. No. 7 Tilter: Initial modification cost 11/2010.

a. Engineering: $5,000.
Answers for EPA 

b. Materials: $100,000.

c. Labor: $80,000.

d. Total: $185,000

3. No. 7 Tilter: Final modifications. (4/30/2012)

a. Engineering: $5,000.

b. Materials: $100,000.

c. Labor: $100,000.

d. Total: $205,000.

4. No.2 Tilter: Exhaust Duct replacement (October 2013)

a. Total cost: $86,000

C. Adding covers to slag runners: This is included in 2B above. The hood extensions should capture the fumes. Will reevaluate after modifications.

D. Addition of fans to direct fume from casting nests toward the hood- This will be address if necessary after tilter 

modifications.

3. Furnace fugitive upgrade:

A. Adding mesh curtains on furnace charging floor.- Not practical, curtain life less than 60 days.

1. Materials: $50,000 per furnace.

2. Labor: $2,000 per furnace.

3. Total: $52,000 per furnace= $156,000.

B. Add doors to furnaces

1. Materials: $50,000 per furnace.

2. Labor: $20,000 per furnace.

3. Total: $70,000 per furnace.

4. Crushing plant upgrade.

A. No. 1 Crusher: (Completion 4/2012)- Due to design errors this system failed.

1. Engineering: $78,000.

2. Material: $200,000.

3. Labor: $200,000.

4. Total: $478,000

B. No. 1 Crusher: Completion 2014.

1. Engineering and Materials: $381,078

2. Labor: $100,800

3. Total: $481,878 

C. No. 2 Crusher: (Completion 2013) Due to market conditions furnaces currently Shutdown. There is no specific start up 

plans at this time.

1. Engineering: $78,000.

2. Material: $200,000.

3. Labor: $200,000.

4. Total: $478,000.

*Capital dollar amount based on actual paid invoices and best estimates from Engineering, contractors, vendors and suppliers.

Attachment 3:

Additional Detailed Cost Estimates for Felman

TOTAL ANNUAL COST SPREADSHEET PROGRAM--STRAIGHT DUCTWORK for Rooftop Ventilation[1]

DUCTS: COST BASE DATE: CEPCI 1993 [2] 359.2

COST ESCALATION: CEPCI 2012 [3] 584.6

INPUT PARAMETERS

Ductwork:

-- Inlet stream flowrate (acfm): 120,000

-- Duct velocity (ft/min): [4] 3,800

-- Duct length (ft): [5] 1000 Estimated based on building dimensions and likely FF location

-- Material of construction: [6] Sheet-galv CS

-- Insulation thickness (in.): (text input) [7] 0

-- Duct design: [8] Circular-longitudinal

-- Cost equation parameters: [9]

 a: 2.03

 b: 0.784

-- Cost equation form: [10] 1

-- Control system installation factor: [11] 1.5

 (if no system, enter '0')

-- Fan-motor combined efficiency (fraction): 0.6

DESIGN PARAMETERS

-- Duct diameter (in.): 76

-- Pressure drop (in. w.c.): [12] 2

CAPITAL COSTS

Ductwork Cost ($)--base: $60,542

Ductwork Cost ($)--escalated: $98,532

Purchased Equipment Cost ($): $106,414

Retrofit Adjustment (100%) $212,829

Total Capital Investment ($): [13] $319,243

ANNUAL COST INPUTS

Operating factor (hours/year): 8760

Electricity price ($/kWhr): 0.0682

Annual interest rate (fractional): 0.07

Ductwork economic life (years): 20

Capital recovery factor (system): 0.094392926

Taxes, insurance, admin. factor: 0.04

Labor, $/hr [15] 17.42

ANNUAL COSTS

Item Cost ($/yr) Wt.Fact.

Electricity $23,910 0.345911107

Taxes, insurance, administrative $12,770 0.184742293

Capital recovery $30,134 0.435959138

Labor [14] $1,442 0.020867164

Overhead [15] $865 0.012520299

Total Annual Cost $69,122 1

Notes:

[1] Data used to develop this program were taken from 'OAQPS Control Cost Manual', 5th edition, Chapter 10. Prices are for CIRCULAR straight ductwork, only.

[2] Chemical Engineering Plant Cost Index CEPCI for base year. Base costs reflect this date.

[3] Chemical Engineering Plant Cost Index CEPCI for year shown. Equipment cost has been escalated to this date via this CEPCI.

[4] See 'Manual,' pp. 10-30 to 10-33.

[5] Duct length is a site-specific parameter that can vary from < 10 to > 1000 ft.

[6] Choices available are: carbon steel sheet (galv. CS sh.), stainless steel sheet (304 SS sh.), coated carbon steel plate (coat. CS pl.), 304 stainless steel plate (304 SS pl.), polyvinyl chloride (PVC), and fiber-reinforced plastic (FRP)

[7] Choices are: 0, 1, and 3.

[8] Choices are: circular spiral (circ.-spiral) and circular longitudinal (circ.-long.)

[9] Equation type and parameters depend on duct material of construction. Parameters reflect 2nd quarter 1993 costs. See 'Manual,' pp. 10-44 to 10-49.

[10] Choices are: power function (1) and exponential (2).

[11] Installation factor depends on control device ductwork is supporting. This factor, when multiplied by Purchased Equipment Cost, yields Total Capital Investment (TCI). If ductwork is installed alone, factor is 1.25 to 1.50. (Default = 1.50.) See 'Manual'.

[12] Pressure drop applies ONLY to circular, spiral-wound galvanized duct with 10 joints per 100 feet. For pressure drop data for other duct types, see 'Manual,' Chapter 10.

[13] Product of installation factor and Purchased Equipment Cost. Costs are presented both in terms of 2nd quarter '93 and above escalation date. Latter costs are based on Producer Price Index PCU 3444#1 ('Air-conditioning ducts and stove pipe')

[14] Labor of 17.42/hr ; 6 hr/month ; 15% supervision factor, from Bureau of Labor Statistics National Compensation survey, 2009, for Metal Furnace & Kiln Operators

[15] 60% of Labor costs

Electricity price for Industrial sector in 2011 - taken from 

Average Retail Price of Electricity to Ultimate Customers by 

End-Use Sectors 2001 through 2011 

http://www.eia.gov/electricity/data.cfm#sales
"Phase II" Additional Fabric Filter for Felman

Replaces Furnace 7 FF as roofline ventilation FF for scenario with all three operational furnaces

Ferroalloys Furnace Fugitive Emissions Felman Roof Vent

Control Device New Roof Vent FF

Annual Operating Hours, hr/yr (H) 8760Exhaust Gas Flow Rate, acfm (Qa) 120,000 Necessary for 12 ACH, as cited in Chu & Gassman Design Narrative, 7/9/12 provided by Felman.

Operating Labor Rate, $/hr (LR) $29.96 Labor of 29.96/hr ; from Bureau of Labor Statistics National Compensation survey, 2012, for First‐Line Supervisors of Production and Operating Workers at Iron and Ste

Capital Recovery Factor (CRF) 0.094392926 CRF calculated assuming 20‐year equipment life and 7% interest

Retrofit Factor 1.2BH Total Capital Investmant, $ (TCI) $8,271,684 Calculated using algorithm1 530*Retrofit Factor*(acfm^0.81) for 6.0 cloth‐to‐air ratio

Engineering & Construction Management $827,168 10% of total TCI w/ baghouse, 5% of TCI w/o baghouse

Labor Adjustment (shift, per diem, etc.) $413,584 5% of total TCI

Contractor Profit and Fees $413,584 5% of total TCI

Capital, Engineering, and Construction Cost, $ (CECC) $9,926,021

5522265

Owner's costs, inc "Home Office" costs (OC) $496,301 5% of CECC

AFUDC for PJFF: 6% for a 2 yr engr and const cycle. $625,339 6% of (CECC +OC)

Total Project Cost, $ (TPC) $11,047,661 CECC+OC+AFUDC

Direct Annual Cost, $/yr (DAC)

Operating Labor $8,202 Calculated using (0.25 hr/8‐hr shift) x 3 shifts/day x 365 days/yr x LR

Administration & Supervisory Labor $660 Calculated using 3% of the sum of the Operating Labor and 40% of the Maintainance

Maintenance & Materials $34,465 Fixed O&M additional maintenance material and labor costs

Indirect Annual Cost, $/yr (IAC)

Overhead $25,996 OAQPS Control Cost Manual ‐ calculated using 0.6 x (Labor + Maintenance)

Property Tax, Insurance, & Admin $275,723 OAQPS Control Cost Manual ‐ calculated using 0.04 x TCI

Capital Recovery $780,788 Calculated using CRF x TCI

Total Annual Cost $1,125,834 Sum of DAC + IAC1 Sargent & Lundy, IPM Model ‐ Updates to Cost and Performance for APC Technologies, Particulate Control Cost Development Methodology Final, March 2013
Attachment 4:

Revised Building Ventilation Cost Estimates for Felman

Revised Felman Building Ventilation Costs

Based on costs provided by Felman in comments on EPA's November 2011 Proposal.

"Building Ventilation Costs January 30, 2012", EPA‐HQ‐OAR‐2010‐0895‐0073

Baghouse $6,200,000

Ductwork $10,478,442

Total Capital Investment (TCI)1 $28,228,603

Amortized Capital Cost (20 yr, 7% Int.) $2,664,580

Annual Costs $2,377,965

Total Annualized Costs $5,042,545

CRF (20 years, 7% interest) 0.094392926

Ductwork Purchased Equipment Cost (PEC) Capital Labor

Metal corrugated panels $8,848 $10,080

20'x20' coiling door $11,800 $3,940

10'x10' coiling door $5,325 $1,770

15'x10' coiling door $5,900 $1,966

17'x22' coiling door $11,800 $3,940

Misc Matl & Labor $6,537 $6,537

Ductwork (Corten steel) $775,000 $8,525,000

HV units $1,000,000 $100,000

Total $1,825,210 $8,653,233

Purchased Equipment Cost (PEC)

1

Felman's estimate applied overhead and contingency adjustments to ductwork

costs twice.  As per Felman's estimates, TCI = 2.17*PEC for the baghouse, and

TCI=1.41*PEC for ductwork.