Date: November 6, 2014

To: Jeff Telander, EPA/OAQPS/SPPD

From: Thomas Holloway

Subject: Monitoring and Testing Requirements and Costs for the Clay Ceramics 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 clay ceramics manufacturing industry, specifically the 

sanitaryware and ceramic tile industry sectors. Sanitaryware includes plumbing and bathroom 

fixtures such as toilets and sinks. Ceramic tile is used to cover floors and walls. The NESHAP 

regulated emissions of hydrogen fluoride (HF), hydrogen chloride (HCl), and particulate matter 

(PM)—a surrogate for hazardous air pollutant (HAP) metals—from new and reconstructed kilns 

located at clay ceramics facilities. On March 13, 2007, the D.C. Circuit Court vacated the 

emission standards for clay ceramics 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 clay ceramics manufacturing, including limits 

for HF, HCl, mercury (Hg), non-Hg HAP metals (specifically, the PM surrogate), and 

dioxins/furans (D/F).

The list of affected sources to be regulated has been expanded to include new and 

existing kilns, spray dryers (ceramic tile only), press dryers (floor tile only), and spray glaze 

operations (sanitaryware and floor tile only). The facilities that would be subject to the proposed 

NESHAP based on current operations include three sanitaryware facilities. The other clay 

ceramics facilities (wall and floor tile facilities) have taken the necessary steps to become 

synthetic area sources (i.e., have obtained a federally enforceable limit reducing emissions below 

major source thresholds), and would not be subject to the major source clay ceramics NESHAP. 

The purpose of this memorandum is to present the monitoring and testing requirements for the 

proposed clay ceramics NESHAP and the estimated costs for each requirement.

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

II. Monitoring Requirements and Costs

Monitoring requirements are presented in this memorandum for each emission control 

scenario for the clay ceramics 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 clay ceramics standards without

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

summarizes the clay ceramics monitoring requirements and costs.

For affected sources not equipped with activated carbon injection systems, compliance 

with the D/F emission limit would be demonstrated by monitoring source operating temperature.

The specifics of this monitoring requirement vary depending on the type of affected source. 

Dioxin/furan compounds are typically formed at temperatures between 200 and 450 degrees 

Celsius (°C) (392 and 842 degrees Fahrenheit [°F]) and typically destroyed at temperatures 

ranging from 977°C (1,791°F), at a retention time of 1 second (sec), to 1,000°C (1,832°F), at a 

retention time of 0.5 sec (EPA, 2006). To minimize the formation of D/F, clay ceramics facilities 

would need to limit the operation of their affected sources in the temperature range where D/F

compounds are formed. However, some affected sources (kilns and spray dryers) typically have 

operating temperatures above this range, and some (press dryers) typically have operating 

temperatures below this range; in addition, kilns typically have operating temperatures in the 

range where D/F destruction occurs. (Abraczinskas and Marinshaw, 1999) Consequently, the 

temperature monitoring requirement for kilns and spray dryers is recommended to be a minimum 

temperature limit to operate at or above; for press dryers, it is recommended to be a maximum 

temperature limit to operate at or below. The operating limits would be established during the 

D/F performance tests for the affected sources. Table 2 compares the operating temperatures for 

kilns, spray dryers, and press dryers to the D/F formation and destruction temperatures.

The costs to monitor kiln process rate and source operating temperature are expected to 

be included in the cost of normal source operation. The control device monitoring costs are, in 

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

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 3 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 4 documents the calculation of the VE 

monitoring costs. A summary of the monitoring costs for each affected facility is presented in 

Table 5.
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III. Testing Requirements and Costs

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

pollutants) and affected source type for which there is an emission limit in the proposed clay 

ceramics NESHAP. Each facility subject to the proposed clay ceramics NESHAP would conduct 

an initial performance test at the stack of each affected source using specified EPA test methods

to demonstrate initial compliance with all applicable emission limits. These facilities would 

conduct a performance test for each affected source 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. During these performance tests, each 

sanitaryware facility subject to the proposed clay ceramics NESHAP would measure emissions 

of HF, HCl, Hg, PM, and D/F from the affected kiln stacks and emissions of PM from the 

affected glaze spray booth stacks.

The performance test costs were estimated assuming that the sanitaryware facilities 

would measure emissions from their affected kiln stacks using the following methods:

• HF, HCl: EPA Method 26A, “Determination of Hydrogen Halide and Halogen Emissions 

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

• Hg: EPA Method 29, “Determination of Metals Emissions from Stationary Sources,” 40 

CFR part 60, appendix A-8

• D/F: EPA Method 23, “Determination of Polychlorinated Dibenzo-p-Dioxins and 

Polychlorinated Dibenzofurans From Stationary Sources,” 40 CFR part 60, appendix A-7

The sanitaryware facilities were assumed to measure PM emissions from their glaze 

spray booth stacks using EPA Method 5, “Determination of Particulate Emissions from 

Stationary Sources,” 40 CFR part 60, appendix A-3. The Method 26A, Method 29, and Method 5 

tests would consist of three runs, at 1 hour each. The Method 23 test would consist of three runs, 

at 2 hours each.

Because the numbers and types of affected sources differ for each sanitaryware facility 

subject to the clay ceramics NESHAP, a separate set of test costs was developed for each facility. 

The test costs for each facility 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 test costs for each facility is presented in Table 5.

IV. References

Abraczinskas, M. and Marinshaw, R. 1999. Characterization of the Ceramic Manufacturing 

Industry. Memorandum from Mike Abraczinskas and Rick Marinshaw, MRI, to Susan 

Zapata, EPA. December 3, 1999.

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

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

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

2012. Available at: http://www.bls.gov/oes/2011/may/naics4_327100.htm.
4

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). 2006. An Inventory of Sources and 

Environmental Releases of Dioxin-Like Compounds in the United States for the Years 1987, 

1995, and 2000. Publication No. EPA/600/P-03/002F. November 2006. Available at: 

http://www.epa.gov/ncea/pdfs/dioxin/2006/dioxin.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.
5

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 $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 --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 --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 $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 --2 $2,984

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

Determine and record 3-hour block averages.

PM --3

pH Continuously monitor the scrubber liquid pH. Determine and 

record 3-hour block averages.

HF, HCl

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

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, D/F --3

Water curtain Periodic inspection Conduct a daily inspection to verify the presence of water flow to 

the wet control system, conduct weekly visual inspections of the 

system ductwork and control equipment for leaks, and conduct 

annual inspections of the interior of the control equipment (if 

applicable) to determine the structural integrity and condition of the 

control equipment.

PM --3

Baffles Annual inspection Conduct an annual visual inspection of the baffles to confirm the 

baffles are in place.

PM --3
6

Emission 

control

Monitor type/

operation/process Monitoring requirements

Emission limits

for which 

compliance is 

demonstrated

Monitoring costs, 

2011$

Capital 

($)

Annual 

($/yr)

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 --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 --4

Temperature5 Continuously monitor the operating temperature. Determine and 

record 3-hour block averages.

D/F --4

1 Reference: Shrager, 2003.

2 No capital cost

3 No cost; included in control device costs

4 No cost; included in source operation costs 5 To be monitored by kilns with no activated carbon injection control.
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Table 2. Comparison of Clay Ceramic Affected Source Operating Temperatures to Dioxin/Furan Formation/Destruction 

Temperatures

Parameter

Temp., °C Temp., °F

Min. Max. Min. Max. Notes Reference

D/F formation 200 450 392 842 Maximum formation at 350°C (662°F) EPA, 2006 (section 2)

D/F destruction 977 1,000 1,791 1,832 Based on retention times of 1 sec and 0.5 sec, 

respectively

Id. (section 2.1)

Kiln operation

 Ceramic tile 980 1,200 1,800 2,200 Stay at or above temperature operating limit 

established during performance test to maximize 

D/F destruction

Abraczinskas and Marinshaw, 

1999 (section IV.A, Table 10)

 Sanitaryware 950 1,260 1,750 2,300 Id. (section IV.B)

Spray dryer operation 70 570 160 1,050 Stay at or above temperature operating limit 

established during performance test to minimize 

D/F formation

Id. (section IV.A)

Press dryer operation

 Ceramic tile 40 260 100 500 Stay at or below temperature operating limit 

established during performance test to minimize 

D/F formation

Id. (section IV.A)

 Sanitaryware 60 100 140 210 Id. (section IV.B)
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Table 3. Estimated Costs for Bag Leak Detection for Clay Ceramics Sources 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.
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Table 4. Estimated Costs for Periodic VE Monitoring of Clay Ceramics Sources1

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 5. Summary of Monitoring and Testing Costs for Affected Clay Ceramics Facilities

Facility

Affected source 

type

No. of 

stacks Pollutants tested

Test 

cost, $

Annualized 

test cost, 

$/yr1

Annual 

monitoring 

cost, $/yr

KohlerSpartanburgKiln 4 HF, HCl, PM, Hg, D/F $52,350 $12,770 $11,937

Glaze spray booth 8 PM

KohlerBrownwoodKiln 1 HF, HCl, PM, Hg, D/F $19,140 $4,670 $2,984

Glaze spray booth 10 PM

KohlerWisconsinKiln 2 HF, HCl, PM, Hg, D/F $30,510 $7,440 $5,969

Glaze spray booth 9 PM

Total $102,000 $24,880 $20,890

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

Estimated Costs of Emission Tests for Each Affected Clay Ceramics Facility
A-2

Table A-1. Estimated Cost of Emission Test – Kohler-Spartanburg, SC

Parameter Value Assumptions

Hours of testing

48 Assumes M5, 3 runs, 1 hour each; M29, 3 runs, 1 hour each;

M26A, 3 runs, 1 hour each; M23, 3 runs, 2 hours each

No. of tests

Method 5 – PM 8 8 glaze spray booth stacks

Method 26A - HF/HCl 4 4 kiln stacks

Method 29 - Metals 4 4 kiln stacks; includes metals and PM testing

Method 23 – D/F 4 4 kiln stacks

Total No. of tests 20

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

Nights 7

Travel time to site (hours) 4

Item/Activity Cost Assumptions

Equipment rental

Volumetric flow sampler 400

CO2/O2 analyzer 1,600

Sample lines 600

Trailer to haul equipment 1,600

Rental truck 800

Miscellaneous equipment 2,400

Total equipment rental cost 7,400

Travel

Labor 1,160

Lodging 1,575

Per diem 120

Vehicle rental 480 One car

Total travel cost 3,335

Testing cost

Mobilization 460 4 hours for site manager and Technician II

Setup equipment 580 Assume 4 hours for 3-man crew

Perform test 9,257 Includes downtime, assumed to be 33% of testing time

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

Onsite contingency 529 Approximately 5% of testing cost for short-term delays

Total testing cost 11,116

Laboratory analysis

Method 5 - PM 1,080

Method 26A - HF/HCl 2,000

Method 29 - Metals 10,600

Method 23 – D/F 12,480

Total 26,160

Test report

Data reduction and review 1,680 2 hr + 2 hr/test

Report preparation 1,240 2 hr + 1 hr/test for technical reviewer; 8 hr + 0.5 hr/test for clerical

Report review 1,320 1 hr + 0.5 hr/test for project manager

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

Total test report cost 4,340

SUMMARY

Total equipment rental cost 7,400

Total travel cost 3,335

Total testing cost 11,116

Laboratory analysis cost 26,160

Total test report cost 4,340

TOTAL 52,350
A-3

Table A-2. Estimated Cost of Emission Test – Kohler-Brownwood, TX

Parameter Value Assumptions

Hours of testing 12 Assumes M5, 3 runs, 1 hour each; M29, 3 runs, 1 hour each;

M26A, 3 runs, 1 hour each; M23, 3 runs, 2 hours each

No. of tests

Method 5 - PM 10 10 glaze spray booth stacks

Method 26A - HF/HCl 1 1 kiln stack

Method 29 - Metals 1 1 kiln stack; includes metals and PM testing

Method 23 – D/F 1 1 kiln stack

Total No. of tests 13

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 5 - PM 1,350

Method 26A - HF/HCl 500

Method 29 - Metals 2,650

Method 23 – D/F 3,120

Total 7,620

Test report

Data reduction and review 1,120 2 hr + 2 hr/test

Report preparation 890 2 hr + 1 hr/test for technical reviewer; 8 hr + 0.5 hr/test for clerical

Report review 900 1 hr + 0.5 hr/test for project manager

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

Total test report cost 3,010

SUMMARY

Total equipment rental cost 2,775

Total travel cost 1,910

Total testing cost 3,826

Laboratory analysis cost 7,620

Total test report cost 3,010

TOTAL 19,140
A-4

Table A-3. Estimated Cost of Emission Test – Kohler-Kohler-WI

Parameter Value Assumptions

Hours of testing 24 Assumes M5, 3 runs, 1 hour each; M29, 3 runs, 1 hour each;

M26A, 3 runs, 1 hour each; M23, 3 runs, 2 hours each

No. of tests

Method 5 - PM 9 9 glaze spray booth stacks

Method 26A - HF/HCl 2 2 kiln stacks

Method 29 - Metals 2 2 kiln stacks; includes metals and PM testing

Method 23 2 2 kiln stacks

Total No. of tests 15

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 5 - PM 1,215

Method 26A - HF/HCl 1,000

Method 29 - Metals 5,300

Method 23 – D/F 6,240

Total 13,755

Test report

Data reduction and review 1,280 2 hr + 2 hr/test

Report preparation 990 2 hr + 1 hr/test for technical reviewer; 8 hr + 0.5 hr/test for clerical

Report review 1,020 1 hr + 0.5 hr/test for project manager

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

Total test report cost 3,390

SUMMARY

Total equipment rental cost 4,625

Total travel cost 2,480

Total testing cost 6,256

Laboratory analysis cost 13,755

Total test report cost 3,390

TOTAL 30,510
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

5 PM 135 $45 per run, 3 runs

23 D/F 3,120 $1,040 per run, 3 runs

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.