Date: November 6, 2014

To: Jeff Telander, EPA/OAQPS/SPPD

From: Thomas Holloway

Subject: Monitoring and Testing Requirements and Costs for the Brick and Structural Clay 

Products NESHAP

I. Introduction

In accordance with section 112 of the Clean Air Act (CAA), the U.S. Environmental 

Protection Agency (EPA) established national emission standards for hazardous air pollutants 

(NESHAP) on May 16, 2003, for the brick and structural clay products (BSCP) manufacturing 

industry. The NESHAP regulated emissions of hydrogen fluoride (HF), hydrogen chloride (HCl), 

and particulate matter (PM)—a surrogate for hazardous air pollutant (HAP) metals—from tunnel 

kilns located at BSCP facilities. On March 13, 2007, the D.C. Circuit Court vacated the emission 

standards for BSCP manufacturing due to issues associated with the methodology used to 

determine the minimum regulatory “floors” for new and existing units.

1 Therefore, the EPA is 

proposing new standards for BSCP manufacturing, including limits for HF, HCl, chlorine (Cl2), 

mercury (Hg), and non-Hg HAP metals (or PM surrogate). The purpose of this memorandum is 

to present the monitoring and testing requirements for the proposed BSCP NESHAP and the

estimated costs for each requirement.

II. Monitoring Requirements and Costs

Monitoring requirements are presented in this memorandum for each emission control 

scenario for the BSCP industry. These requirements were selected based upon a determination of 

the information necessary to ensure that the emission standards are being followed and that 

emission control devices and equipment are maintained and operated properly. These 

requirements are intended to ensure compliance with the BSCP standards without imposing a 

significant additional burden for the facilities that must implement them. Table 1 summarizes the

BSCP monitoring requirements and costs.

For uncontrolled kilns, the cost to monitor kiln process rate is expected to be included in

the cost of normal kiln operation. For controlled kilns, the control device monitoring costs are, in 

most cases, expected to be included in the cost of the control device. Exceptions include the cost 

 1 Sierra Club v. EPA, 479 F.3d 875 (D.C. Cir. 2007).
2

to install and operate a bag leak detector (BLD) and the cost to conduct daily visible emissions 

(VE) monitoring using EPA Method 22, “Visual Determination of Fugitive Emissions from 

Material Sources and Smoke Emissions from Flares,” 40 CFR part 60, appendix A-7.

The BLD costs were determined using an EPA cost model (EPA, 2007), with capitalrelated costs updated to 2011 dollars using the Chemical Engineering Plant Cost Index (CEPCI)

(CE, 2012). Table 2 documents the cost elements included in the BLD costs.

The VE monitoring costs were calculated based on the labor requirements associated with 

conducting a daily 15-minute VE check, preparing for and documenting the results of the VE 

checks, and having two people attend a VE training course every 5 years (Shrager, 2003). The 

VE monitoring costs are also in 2011 dollars. Table 3 documents the calculation of the VE 

monitoring costs.

III. Testing Requirements and Costs

Testing requirements are presented in this memorandum for each pollutant (or set of 

pollutants) for which there is an emission limit in the proposed BSCP NESHAP. Each facility

subject to the proposed BSCP NESHAP would conduct an initial performance test at each tunnel 

kiln stack using specified EPA test methods to demonstrate initial compliance with all applicable 

emission limits. These facilities would conduct a performance test for each affected tunnel kiln 

before renewing their title V operating permit or at least every 5 years following the initial 

performance test, as well as when an operating limit parameter value is being revised. Each 

facility subject to the proposed BSCP NESHAP would measure emissions of HF, HCl, Cl2, Hg, 

and non-Hg HAP metals (or PM surrogate) from each tunnel kiln stack during these performance 

tests.

The performance test costs were estimated assuming that BSCP facilities would measure 

emissions of HF, HCl, and Cl2 using EPA Method 26A, “Determination of Hydrogen Halide and 

Halogen Emissions from Stationary Sources-Isokinetic Method,” 40 CFR part 60, appendix A-8. 

The facilities were also assumed to measure emissions of Hg and non-Hg HAP metals (or PM 

surrogate) using EPA Method 29, “Determination of Metals Emissions from Stationary

Sources,” 40 CFR part 60, appendix A-8. To determine PM, sources would weigh the filter and 

report the results as PM filterable. Each test would consist of three runs, at 1 hour each.

Because many BSCP facilities have multiple tunnel kiln stacks that could be tested 

concurrently, we developed Method 26A/29 test costs for every possible testing scenario: one 

test cost for facilities testing a single stack, one for facilities testing two stacks, one for facilities 

testing three stacks, one for facilities testing four stacks, and one for facilities testing five stacks, 

the maximum number of tunnel kiln stacks at a BSCP facility. The costs for each testing scenario 

are detailed in Attachment A of this memorandum. The labor and equipment rental rates and 

analytical laboratory costs are detailed in Attachment B. A summary of the costs for each testing 

scenario is presented in Table 4.

IV. References

BLS (U.S. Department of Labor, Bureau of Labor Statistics). 2012. May 2011 National 

Industry-Specific Occupational Employment and Wage Estimates, NAICS 327100 - Clay 
3

Product and Refractory Manufacturing. Occupational Employment Statistics. March 27, 

2012. Available at: http://www.bls.gov/oes/2011/may/naics4_327100.htm.

CE (Chemical Engineering). 2012. Chemical Engineering Plant Cost Index.

EPA (U.S. Environmental Protection Agency). 1997. Fabric Filter Bag Leak Detection 

Guidance. Publication No. EPA-454/R-98-015. September 1997. Available at: 

http://www.epa.gov/ttnemc01/cem/tribo.pdf.

EPA (U.S. Environmental Protection Agency). 2007. CEMS Cost Model. Technology Transfer 

Network, Emission Measurement Center, Continuous Emission Monitoring – Information, 

Guidance, etc. March 7, 2007. Available at: http://www.epa.gov/ttn/emc/cem/cems.xls.

Shrager, B. 2003. Final Rule: Monitoring and Monitoring Costs. Memorandum from Brian 

Shrager, RTI International, to Mary Johnson, EPA/ESD/CG. February 26, 2003.
4

Table 1. Summary of Monitoring Requirements and Costs1

Emission 

control

Monitor type/

operation/process Monitoring requirements

Emission limits

for which 

compliance is 

demonstrated

Monitoring costs, 

2011$

Capital 

($)

Annual 

($/yr)

Dry injection 

fabric filter

(DIFF) or dry 

lime scrubber/

fabric filter

(DLS)

Bag leak detector

or

Install and operate a bag leak detector in accordance with Fabric 

Filter Bag Leak Detection Guidance. (EPA, 1997)

PM, non-Hg 

metals

$37,888 $12,345

Daily VE check Perform daily 15-minute Method 22 VE check. Can reduce 

frequency to weekly after 30 days with no VE.

PM, non-Hg 

metals

--2 $2,984

Lime injection rate Verify that lime is free-flowing via pressure (flow sensors); weight 

(load cells); or other system. Record all results. Record feeder 

setting once each shift, on a per ton of fired product basis.

HF, HCl, Cl2 --

3

Fabric filter Bag leak detector

or

Install and operate a bag leak detector in accordance with Fabric 

Filter Bag Leak Detection Guidance. (EPA, 1997)

PM, non-Hg 

metals

$37,888 $12,345

Daily VE check Perform daily 15-minute Method 22 VE check. Can reduce 

frequency to weekly after 30 days with no VE.

PM, non-Hg 

metals

--2 $2,984

Dry limestone 

adsorber (DLA)

Daily VE check Perform daily 15-minute Method 22 VE check. Can reduce 

frequency to weekly after 30 days with no VE.

PM, non-Hg 

metals

--2 $2,984

Pressure drop 

or

Continuously monitor the pressure drop across the control 

device. Determine and record 3-hour block averages.

PM, non-Hg 

metals

--3

Bypass stack 

damper position

Continuously monitor the bypass stack damper position at least 

once every 15 minutes during normal kiln operation

PM, non-Hg 

metals

--4

Limestone feeder 

setting

Verify that there is adequate limestone in the hopper and silo. 

Record limestone feeder setting daily, on a per ton of fired 

product basis.

HF, HCl, Cl2 --3

Limestone grade Use the same grade of limestone from the same source as used 

during performance test.

HF, HCl, Cl2

Wet scrubber Pressure drop Continuously monitor the pressure drop across the scrubber. 

Determine and record 3-hour block averages.

PM, non-Hg 

metals

--3

pH Continuously monitor the scrubber liquid pH. Determine and 

record 3-hour block averages.

HF, HCl, Cl2

Liquid flow rate Continuously monitor the scrubber liquid flow rate. Determine 

and record 3-hour block averages.

All pollutants

Chemical addition 

rate

Continuously monitor the scrubber chemical feed rate (if 

applicable). Determine and record 3-hour block averages.

HF, HCl, Cl2
5

Emission 

control

Monitor type/

operation/process Monitoring requirements

Emission limits

for which 

compliance is 

demonstrated

Monitoring costs, 

2011$

Capital 

($)

Annual 

($/yr)

Activated 

carbon injection 

system

Activated carbon 

flow rate

Monitor carbon flow rate once per shift. Record carbon flow rate

for 15 minutes each shift.

Hg --3

No control Daily VE check Perform daily 15-minute Method 22 VE check; can reduce 

frequency to weekly after 30 days with no VE.

PM, non-Hg 

metals

--2 $2,984

Kiln process rate If last calculated total facility maximum potential HCl-equivalent 

not ≤ limit, collect and record kiln process rate data and reduce 

data to 3-hour averages.

HF, HCl, Cl2 --4

1 Reference: Shrager, 2003

2 No capital cost

3 No cost; included in control device costs

4 No cost; included in kiln operation costs
6

Table 2. Estimated Costs for Bag Leak Detection for BSCP Kilns Equipped with Fabric Filters (Baghouses)

1,2

Cost element Labor Test ODCs Total cost, 2007$ Total cost, 2011$

First costs, $

 Planning $1,462 $0 $352 $1,814

 Select equipment $6,346 $0 $643 $6,989

 Support facilities $0 $0 $1,030 $1,030

 Purchase BLD system hardware $0 $0 $18,232 $18,232

 Install and check BLD system $161 $0 $5,022 $5,184

 QA/QC Plan $739 $0 $0 $739

 Total first costs $8,708 $0 $25,280 $33,987 $37,888

Annual costs, $/yr

 Day-to-day activities $2,822 $0 $0 $2,822 $2,822

 Recordkeeping and reporting $254 $0 $0 $254 $254

 Annual QA & O&M review and update $384 $0 $3,490 $3,874 $3,874

 Capital recovery $1,240 $0 $3,600 $4,840 $5,394

 Total with capital recovery $4,701 $0 $7,090 $11,791 $12,345

1 Reference: EPA, 2007. Updated to 2011 dollars using CEPCI. 2 ODC = other direct cost; QA/QC = quality assurance/quality control; O&M = operation and maintenance; and CEMS = continuous emission monitoring system.

Cost 

year CEPCI1

2007 525.4

2011 585.7

1 Reference: CE, 2012.
7

Table 3. Estimated Costs for Periodic VE Monitoring of BSCP Kiln Emissions1

Cost element

Labor rates, 

$/hr2

Estimated costs, 2011$

First 30 days Rest of year Annual

Annual costs, $/yr

 Conduct 15-minute VE check3 $48 $360 $574 $934

 Prepare for and document

 Technical $48 $360 $574 $934

 Management4 $88 $33 $53 $86

 Clerical5 $28 $21 $34 $55

 Training every 5 years6 $976 $976

 Total annual cost $1,750 $1,235 $2,984

1 Reference: Shrager, 2003.

2 Unloaded labor rates from BLS (2012). Technical labor rate based on mean hourly wage for Industrial Engineering 

Technicians. Management labor rate based on mean hourly wage for Industrial Production Managers. Clerical labor 

rate based on mean hourly wage for Office Clerks, General. Labor rates have been increased by 110 percent (%) to 

include overhead.

3 Perform daily 15-minute Method 22 VE check. Can reduce frequency to weekly for rest of year after 30 days with no 

VE.

4 Assumed to be 5% of technical.

5 Assumed to be 10% of technical. 6 Assumes $2,000 per training course for two people ($2,000 each), amortized over 5 years at 7% interest rate.

Table 4. Summary of Emission Test Costs

No. of tunnel 

kiln stacks

Cost per 

kiln/outlet, $

Annualized 

cost, $/yr1

1 $11,370 $2,770

2 $16,110 $3,930

3 $22,070 $5,380

4 $28,020 $6,830

5 $33,980 $8,290

1 Annualized cost based on 7% interest, 5-yr period.
Attachment A

Estimated Costs of Emission Tests for Each Testing Scenario
A-2

Table A-1. Estimated Cost of Emission Test -- 1 Kiln

Parameter Value Assumptions

Hours of testing 6 Assumes M29, 3 runs, 1 hour each; M26A, 3 runs, 1 hour each

No. of tests

Method 26A - HF/HCl 1 1 kiln stack

Method 29 - Metals 1 1 kiln stack

Total No. of tests 2

Days 3 8 hours of test runs per day, plus 1.5 days for setup and teardown

Nights 2

Travel time to site (hours) 4

Item/Activity Cost Assumptions

Equipment rental

Volumetric flow sampler 150

CO2/O2 analyzer 600

Sample lines 225

Trailer to haul equipment 600

Rental truck 300

Miscellaneous equipment 900

Total equipment rental cost 2,775

Travel

Labor 1,160

Lodging 450

Per diem 120

Vehicle rental 180 One car

Total travel cost 1,910

Testing cost

Mobilization 460 4 hours for site manager and Technician II

Setup equipment 580 Assume 4 hours for 3-man crew

Perform test 1,157 Includes downtime, assumed to be 33% of testing time

Take down equipment 290 Assume 2 hours for 3-man crew

Onsite contingency 124 Approximately 5% of testing cost for short-term delays

Total testing cost 2,611

Laboratory analysis

Method 26A - HF/HCl 500

Method 29 - Metals 2,650

Total 3,150

Test report

Data reduction and review 240 2 hr + 2 hr/test

Report preparation 340 2 hr + 1 hr/test for technical reviewer; 8 hr + 0.5 hr/test for clerical

Report review 240 1 hr + 0.5 hr/test for project manager

Supplies (paper, copies, etc.) 100 Assume $100

Total test report cost 920

SUMMARY

Total equipment rental cost 2,775

Total travel cost 1,910

Total testing cost 2,611

Laboratory analysis cost 3,150

Total test report cost 920

TOTAL 11,370
A-3

Table A-2. Estimated Cost of Emission Test -- 2 Kilns

Parameter Value Assumptions

Hours of testing 12 Assumes M29, 3 runs, 1 hour each; M26A, 3 runs, 1 hour each

No. of tests

Method 26A - HF/HCl 2 1 kiln stack

Method 29 - Metals 2 1 kiln stack

Total No. of tests 4

Days 3 8 hours of test runs per day, plus 1.5 days for setup and teardown

Nights 2

Travel time to site (hours) 4

Item/Activity Cost Assumptions

Equipment rental

Volumetric flow sampler 150

CO2/O2 analyzer 600

Sample lines 225

Trailer to haul equipment 600

Rental truck 300

Miscellaneous equipment 900

Total equipment rental cost 2,775

Travel

Labor 1,160

Lodging 450

Per diem 120

Vehicle rental 180 One car

Total travel cost 1,910

Testing cost

Mobilization 460 4 hours for site manager and Technician II

Setup equipment 580 Assume 4 hours for 3-man crew

Perform test 2,314 Includes downtime, assumed to be 33% of testing time

Take down equipment 290 Assume 2 hours for 3-man crew

Onsite contingency 182 Approximately 5% of testing cost for short-term delays

Total testing cost 3,826

Laboratory analysis

Method 26A - HF/HCl 1,000

Method 29 - Metals 5,300

Total 6,300

Test report

Data reduction and review 400 2 hr + 2 hr/test

Report preparation 440 2 hr + 1 hr/test for technical reviewer; 8 hr + 0.5 hr/test for clerical

Report review 360 1 hr + 0.5 hr/test for project manager

Supplies (paper, copies, etc.) 100 Assume $100

Total test report cost 1,300

SUMMARY

Total equipment rental cost 2,775

Total travel cost 1,910

Total testing cost 3,826

Laboratory analysis cost 6,300

Total test report cost 1,300

TOTAL 16,110
A-4

Table A-3. Estimated Cost of Emission Test -- 3 Kilns

Parameter Value Assumptions

Hours of testing 18 Assumes M29, 3 runs, 1 hour each; M26A, 3 runs, 1 hour each

No. of tests

Method 26A - HF/HCl 3 1 kiln stack

Method 29 - Metals 3 1 kiln stack

Total No. of tests 6

Days 4 8 hours of test runs per day, plus 1.5 days for setup and teardown

Nights 3

Travel time to site (hours) 4

Item/Activity Cost Assumptions

Equipment rental

Volumetric flow sampler 200

CO2/O2 analyzer 800

Sample lines 300

Trailer to haul equipment 800

Rental truck 400

Miscellaneous equipment 1,200

Total equipment rental cost 3,700

Travel

Labor 1,160

Lodging 675

Per diem 120

Vehicle rental 240 One car

Total travel cost 2,195

Testing cost

Mobilization 460 4 hours for site manager and Technician II

Setup equipment 580 Assume 4 hours for 3-man crew

Perform test 3,471 Includes downtime, assumed to be 33% of testing time

Take down equipment 290 Assume 2 hours for 3-man crew

Onsite contingency 240 Approximately 5% of testing cost for short-term delays

Total testing cost 5,041

Laboratory analysis

Method 26A - HF/HCl 1,500

Method 29 - Metals 7,950

Total 9,450

Test report

Data reduction and review 560 2 hr + 2 hr/test

Report preparation 540 2 hr + 1 hr/test for technical reviewer; 8 hr + 0.5 hr/test for clerical

Report review 480 1 hr + 0.5 hr/test for project manager

Supplies (paper, copies, etc.) 100 Assume $100

Total test report cost 1,680

SUMMARY

Total equipment rental cost 3,700

Total travel cost 2,195

Total testing cost 5,041

Laboratory analysis cost 9,450

Total test report cost 1,680

TOTAL 22,070
A-5

Table A-4. Estimated Cost of Emission Test -- 4 Kilns

Parameter Value Assumptions

Hours of testing 24 Assumes M29, 3 runs, 1 hour each; M26A, 3 runs, 1 hour each

No. of tests

Method 26A - HF/HCl 4 1 kiln stack

Method 29 - Metals 4 1 kiln stack

Total No. of tests 8

Days 5 8 hours of test runs per day, plus 1.5 days for setup and teardown

Nights 4

Travel time to site (hours) 4

Item/Activity Cost Assumptions

Equipment rental

Volumetric flow sampler 250

CO2/O2 analyzer 1,000

Sample lines 375

Trailer to haul equipment 1,000

Rental truck 500

Miscellaneous equipment 1,500

Total equipment rental cost 4,625

Travel

Labor 1,160

Lodging 900

Per diem 120

Vehicle rental 300 One car

Total travel cost 2,480

Testing cost

Mobilization 460 4 hours for site manager and Technician II

Setup equipment 580 Assume 4 hours for 3-man crew

Perform test 4,628 Includes downtime, assumed to be 33% of testing time

Take down equipment 290 Assume 2 hours for 3-man crew

Onsite contingency 298 Approximately 5% of testing cost for short-term delays

Total testing cost 6,256

Laboratory analysis

Method 26A - HF/HCl 2,000

Method 29 - Metals 10,600

Total 12,600

Test report

Data reduction and review 720 2 hr + 2 hr/test

Report preparation 640 2 hr + 1 hr/test for technical reviewer; 8 hr + 0.5 hr/test for clerical

Report review 600 1 hr + 0.5 hr/test for project manager

Supplies (paper, copies, etc.) 100 Assume $100

Total test report cost 2,060

SUMMARY

Total equipment rental cost 4,625

Total travel cost 2,480

Total testing cost 6,256

Laboratory analysis cost 12,600

Total test report cost 2,060

TOTAL 28,020
A-6

Table A-5. Estimated Cost of Emission Test -- 5 Kilns

Parameter Value Assumptions

Hours of testing 30 Assumes M29, 3 runs, 1 hour each; M26A, 3 runs, 1 hour each

No. of tests

Method 26A - HF/HCl 5 1 kiln stack

Method 29 - Metals 5 1 kiln stack

Total No. of tests 10

Days 6 8 hours of test runs per day, plus 1.5 days for setup and teardown

Nights 5

Travel time to site (hours) 4

Item/Activity Cost Assumptions

Equipment rental

Volumetric flow sampler 300

CO2/O2 analyzer 1,200

Sample lines 450

Trailer to haul equipment 1,200

Rental truck 600

Miscellaneous equipment 1,800

Total equipment rental cost 5,550

Travel

Labor 1,160

Lodging 1,125

Per diem 120

Vehicle rental 360 One car

Total travel cost 2,765

Testing cost

Mobilization 460 4 hours for site manager and Technician II

Setup equipment 580 Assume 4 hours for 3-man crew

Perform test 5,786 Includes downtime, assumed to be 33% of testing time

Take down equipment 290 Assume 2 hours for 3-man crew

Onsite contingency 356 Approximately 5% of testing cost for short-term delays

Total testing cost 7,471

Laboratory analysis

Method 26A - HF/HCl 2,500

Method 29 - Metals 13,250

Total 15,750

Test report

Data reduction and review 880 2 hr + 2 hr/test

Report preparation 740 2 hr + 1 hr/test for technical reviewer; 8 hr + 0.5 hr/test for clerical

Report review 720 1 hr + 0.5 hr/test for project manager

Supplies (paper, copies, etc.) 100 Assume $100

Total test report cost 2,440

SUMMARY

Total equipment rental cost 5,550

Total travel cost 2,765

Total testing cost 7,471

Laboratory analysis cost 15,750

Total test report cost 2,440

TOTAL 33,980
Attachment B

Basic Rates and Analytical Costs
B-2

Table B-1. Basic Rates for Labor, Per Diem, and Equipment Rental and Analytical Costs1

Daily expenses $/day

Lodging 75

Per diem 40

Vehicle rental 60

Volumetric flow sampler 50

CO2/O2 analyzer 200

CO analyzer 200

NOx analyzer 200

SO2 analyzer 200

FID/GC 400

Sample lines 75

Trailer to haul equipment 200

Rental truck 100

Miscellaneous equipment 300

Labor rates (loaded) $/hr

Onsite testing staff:

Site manager 75

Technician II 40

Technician I 30

Office staff:

Project manager 120

Technical reviewer 40

Clerical 20

Financial 50

Method Analytes Cost, $ Notes

26A Acid gases 500 $50/analyte, 3 runs + 2 blanks

29 Metals 2,650 $530 per run, 3 runs + 2 blanks

1 CO2 = carbon dioxide; O2 = oxygen; CO = carbon monoxide; NOx = nitrogen oxides; 

SO2 = sulfur dioxide; FID/GC = flame ionization detector/gas chromatograph.