## 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. I ntroduction

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 c lay 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

. O n 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

propo sing new standards for BSCP manufacturing , including limits for HF, HCl, chlorine (Cl 2 

## ),

mercury (Hg), and non

- Hg HAP metals (or PM surrogate)

. Th e purpose of th is 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. T hese 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 th e BSCP st andards 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 , t he 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 th e 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 cost s were determined us ing an EPA cost model (EPA, 2007) , with capital

related cost s 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 c alculated 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 woul d 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 s ubject to the proposed BSCP NESHAP would measure emissions of HF, HCl, Cl 2 

## , 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 woul d measure

emissions of HF, HCl, and Cl 2 

## 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 f rom 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 co sts 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 A ttachment 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 ). 201 2

. 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). 201 2

. 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. Summ ary of Monitoring Requirements a nd Costs 1



### Emission

control Monitor t ype/

operation/p rocess Monitoring requirements Emission limits

for which

compliance is

demonstrated Monitoring c osts

, 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, Cl

2 

### - - 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 lime stone in the hopper and silo.

R ecord limestone feeder setting daily, on a per ton of fired

product basis. HF, HCl, Cl

2 

### -- 3



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

during performance test. HF, HCl, Cl

2



### Wet scrubber Pressure drop Continuously monitor the pres sure drop across the scrubber.

Determine and record 3

- hour block averages. PM, non

- Hg

metals -- 3



### pH Continuously m onitor the scrubber liquid pH. Determine and

record 3

- hour block averages. HF, HCl, Cl

2



### 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, Cl

2

## 5 Emission

control Monitor t ype/

operation/p rocess Monitoring requirements Emission limits

for which

compliance is

demonstrated Monitoring c osts

, 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, Cl

2 

### -- 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 c osts , $

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

Select e quipment $6,346 $0 $643 $6,989

Support f acilities $0 $0 $1,030 $1,030

Purchase BLD system h ardware $0 $0 $18,232 $18,232

Install and c heck BLD system $161 $0 $5,022 $5,184

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

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

Annual c osts , $/yr

Day

- to

- d ay a ctivities $2,822 $0 $0 $2,822 $2,822

Recordkeeping and r eporting $254 $0 $0 $254 $254

Annual QA & O&M r eview and u pdate $384 $0 $3,490 $3,874 $3,874

Capital r ecovery $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 CEPCI 1



### 2007 525.4

2011 585.7

1 Reference: CE, 201 2

.

## 7 Table 3

. Estimated Costs for Periodic VE Monitoring of BSCP Kiln Emissions 1



### Cost element Labor rates,

$/hr 2 

### Estimated costs, 2011$

First 30 days Rest of year Annual

Annual c osts, $/yr

Conduct 15

- minute VE check 3 

### $ 48 $ 360 $ 574 $ 934

Prepare for and document

Technical $ 48 $ 360 $ 574 $ 934

Management 4 

### $ 88 $ 33 $ 53 $ 86

Clerical 5 

### $ 28 $ 21 $ 34 $ 55

T raining every 5 years 6 

### $ 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 f or 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 As sumed 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, $/yr 1



### 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.

## A ttachment A

Estimated Costs of Emission Tests for Each Testing Scenario

## A

- 2 Table A

- 1 . Estimated Cost o f 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

V olumetric flow sampler 150

CO 2 /O 2 analyzer 600

Sample lines 225

Trailer to haul equipment 600

Rental truck 300

Miscellaneous equipment 900

Total equipment rental cost 2,775

Travel

L abor 1,160

L odging 450

P er diem 120

V ehicle rental 180 One car

Total travel cost 1,910

Testing cost

Mobilization 460 4 hours for site manager and Technician II

S etup equipment 580 Assume 4 hours for 3

- man crew

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

T ake down equipment 290 Assume 2 hours for 3

- man crew

O nsite contingency 124 Approximately 5% of testing cost for short

- term delays

Total testing cost 2,611

Laboratory a nalysis

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 Kiln s

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

V olumetric flow sampler 150

CO 2 /O 2 analyzer 600

Sample lines 225

Trailer to haul equipment 600

Rental truck 300

Miscellaneous equipment 900

Total equipment rental cost 2,775

Travel

L abor 1,160

L odging 450

P er diem 120

V ehicle rental 180 One car

Total travel cost 1,910

Testing cost

Mobilization 460 4 hours for site manager and Technician II

S etup equipment 580 Assume 4 hours for 3

- man crew

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

T ake down equipment 290 Assume 2 hours for 3

- man crew

O nsite contingency 182 Approximately 5% of testing cost for short

- term delays

Total testing cost 3,826

Laboratory a nalysis

Method 26A

- HF/HCl 1,0 00

Method 29

- Metals 5,30 0

Total 6,30 0

Test report

Data reduction and review 4 0 0 2 hr + 2 hr/test

Report preparation 4 40 2 hr + 1 hr/test for technical reviewer; 8 hr + 0.5 hr/test for clerical

Report review 36 0 1 hr + 0.5 hr/test for project manager

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

Total test report cost 1,30 0

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 1,30 0

TOTAL 16,11 0

## A

- 4 Table A

- 3 . Estimated Cost o f Emission Test

-- 3 Kiln s

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

V olumetric flow sampler 20 0

CO 2 /O 2 analyzer 8 00

Sample lines 300

Trailer to haul equipment 8 00

Rental truck 4 00

Miscellaneous equipment 1,2 00

Total equipment rental cost 3 ,7 00

Travel

L abor 1,160

L odging 675

P er diem 120

V ehicle rental 240 One car

Total travel cost 2,195

Testing cost

Mobilization 460 4 hours for site manager and Technician II

S etup equipment 580 Assume 4 hours for 3

- man crew

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

T ake down equipment 290 Assume 2 hours for 3

- man crew

O nsite contingency 240 Approximately 5% of testing cost for short

- term delays

Total testing cost 5,041

Laboratory a nalysis

Method 26A

- HF/HCl 1, 500

Method 29

- Metals 7

, 9 50

Total 9,4 50

Test report

Data reduction and review 56 0 2 hr + 2 hr/test

Report preparation 54 0 2 hr + 1 hr/test for technical reviewer; 8 hr + 0.5 hr/test for clerical

Report review 48 0 1 hr + 0.5 hr/test for project manager

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

Total test report cost 1,68 0

SUMMARY

Total equipment rental cost 3,700

Total travel cost 2,195

Total testing cost 5,041

Laboratory analysis cost 9,4 50

Total test report cost 1,68 0

TOTAL 22,070

## A

- 5 Table A

- 4 . Estimated Cost o f Emission Test

-- 4 Kiln s

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

V olumetric flow sampler 2 50

CO 2 /O 2 analyzer 1,0 00

Sample lines 37 5

Trailer to haul equipment 1,0 00

Rental truck 5 00

Miscellaneous equipment 1,5 00

Total equipment rental cost 4

, 62 5

Travel

L abor 1,160

L odging 90 0

P er diem 120

V ehicle rental 30 0 One car

Total travel cost 2,48 0

Testing cost

Mobilization 460 4 hours for site manager and Technician II

S etup equipment 580 Assume 4 hours for 3

- man crew

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

T ake down equipment 290 Assume 2 hours for 3

- man crew

O nsite contingency 298 Approximately 5% of testing cost for short

- term delays

Total testing cost 6,256

Laboratory a nalysis

Method 26A

- HF/HCl 2,0 00

Method 29

- Metals 10 ,6 0 0

Total 12

, 60 0

Test report

Data reduction and review 7 20 2 hr + 2 hr/test

Report preparation 6 40 2 hr + 1 hr/test for technical reviewer; 8 hr + 0.5 hr/test for clerical

Report review 60 0 1 hr + 0.5 hr/test for project manager

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

Total test report cost 2,06 0

SUMMARY

Total equipment rental cost 4,62 5

Total travel cost 2,48 0

Total testing cost 6 ,256

Laboratory analysis cost 12

, 60 0

Total test report cost 2,06 0

TOTAL 28,020

## A

- 6 Table A

- 5 . Estimated Cost o f Emission Test

-- 5 Kiln s

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

V olumetric flow sampler 30 0

CO 2 /O 2 analyzer 1,2 00

Sample lines 4 5 0

Trailer to haul equipment 1,2 00

Rental truck 6 00

Miscellaneous equipment 1,8 00

Total equipment rental cost 5, 5 50

Travel

L abor 1,160

L odging 1,125

P er diem 120

V ehicle rental 360 One car

Total travel cost 2,765

Testing cost

Mobilization 460 4 hours for site manager and Technician II

S etup equipment 580 Assume 4 hours for 3

- man crew

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

T ake down equipment 290 Assume 2 hours for 3

- man crew

O nsite contingency 356 Approximately 5% of testing cost for short

- term delays

Total testing cost 7,471

Laboratory a nalysis

Method 26A

- HF/HCl 2, 500

Method 29

- Metals 13

, 2 50

Total 15

, 7 50

Test report

Data reduction and review 88 0 2 hr + 2 hr/test

Report preparation 7 40 2 hr + 1 hr/test for technical reviewer; 8 hr + 0.5 hr/test for clerical

Report review 7 20 1 hr + 0.5 hr/test for project manager

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

Total test report cost 2,44 0

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 Costs 1



### Daily expenses $/day

Lodging 75

Per diem 40

Vehicle rental 60

Volumetric flow sampler 50

CO

2 

### /O

2 

### analyzer 200

CO analyzer 200

NO

x 

### analyzer 200

SO

2 

### 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 CO 2 = carbon dioxide; O 2 = oxygen; CO = carbon monoxide; NO

x = nitrogen oxides;

SO 2 = sulfur dioxide; FID/GC = flame ionization detector/ gas chromatograph

.