## Date: September 2 4 , 2015

To: Sharon Nizich , EPA/OAQPS/SPPD

From: Thomas Holloway , RTI International

Sub ject: Monitoring and Testing Requirements and Costs for the Final Clay Ceramic s Manufacturing 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 v acated 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

, on December 18, 2014, the EPA propo s ed new standards for c lay ceramics

manufacturing

, includ ing limits for HF, HCl, mercury (Hg), non

- Hg HAP metals (specifically,

the PM surrogate) , and dioxins/furans (D/F)

. The EPA provided a 90

- day public comment period

following proposal of the Clay C eramics M anufacturing NESH AP, during which all affected

parties were given the opportunity to comment on the proposed rule. The EPA has considered the

comments received and, as appropriate, incorporated them into the final rule.

The list of affected sources to be regulated ha s 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 final

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

ceramic s facilities ( w all 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

m ajor source thresholds), and would not be subject to the major source C lay C eramics

Manufacturing NESHAP. Th e purpose of th is memorandum is to present the monitoring and

1 

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

## 2 testing requirements for the final C lay C eramics Manufacturing 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 clay ceramics industry. T hese requirements were selected based upon a

deter mination 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 tunnel kilns not equipped with act ivated carbon injection systems

, complian ce with

the D/F emission limit would be demonstrated by monitoring kiln stack temperature

. In their

public comments on the proposed Clay Ceramics Manufacturing NESHAP, the sanitaryware

manufacturing company Kohler Co. asserted that the operating temperatur e limit needs to be

established at a level that affords some operational flexibility

. We agree with the commenter that

redoing performance tests based on variations in kiln temperatures is not an efficient use of

resources when the small kiln temperature variations most likely do not have an effect on the D/F

emissions level. The better par ameter for demonstrating compliance would be the kiln stack

temperature. Dioxins and f urans are known to form in post

- combustion gases in temperature

ranges of 200 to 400 degrees Celsius (°C) (392 to 752 degrees Fahrenheit [°F] ) (Gullet t and

Raghunathan

, 1 997) . Assuring that the maximum kiln stack temperature recorded during the D/F

performance test is never exceeded will assure that the D/F limit is continuously met. Therefore,

we are basing the performance parameter on the kiln stack temperature and not t he kiln operating

temperature.

S pray dryers typically have operating temperatures above th e aforementioned

temperature range, and press dryers typically have operating temperatures below this range

(Abraczinskas and Marinshaw, 1999)

. Consequently

, the temp erature monitoring requirement for

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. As with

tunnel kilns, t he operating limits for spray dryers and press dryers would be established during

the D/F performance tests for the affected sources.

T he costs to monitor kiln process rate and source temperature are expected to be included

in the cost of normal source ope ration. 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 to install

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

mon itoring 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 capital

related costs up dated to 2011 dollars using the Chemical Engineering Plant Cost Index (CEPCI)

(CE

, 2012 )

. The BLD cost estimates are presented in 2011 dollars because 2011 was the latest

year for which an annual cost index value was available for scaling costs at the time that costs

## 3 were first being developed for the clay ceramics manufacturing rule. 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

- mi nute 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 presented in 2011 dollars. Table 3 documents the calculation of the

VE monitoring costs.

A summary of the monitoring costs for each affected facility is presented in Table 4

, based on the assumption that VE monitoring using Method 22 is the only monitoring cost

.

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 final C lay

C eramics Manufacturing NESHAP. Each facility subject to the final C lay C eramics

Manufacturing 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 perfor mance 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, e ach s anitaryware facility subject to the final C lay C eramics

Manufacturing 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 e stimated 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 Fro m 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, a ppendix 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 C lay C eramics Manufacturing NESHAP, a separate set of test costs was developed

for each facility. For one facility, the number of kiln stacks was corrected, resulting in a revision

of test costs for that facility. The test costs for each fa cility are detailed in Attachment A of this

memorandum.

## 4 In public comments on the proposed rule for brick and structural clay products (BSCP)

manufacturing (Hartman, 2015), Air

- Tech Environmental stated that costs for new requirements

should be added to th e test costs . The suggested costs for these new requirements are listed

below :

• Audits, $1000

• Electronic Reporting Tool ( ERT ), $2000

• Compliance and Emissions Data Reporting Interface ( CEDRI ), $2000

G iven the similarity of the BSCP and clay ceramics manufact uring processes and

regulatory requirements

, t he EPA has decided to include these additional test costs in

Attachment A for the sanitaryware facilities, with 50 percent of each cost assigned to each

individual stack test

. 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 4

.

IV. References

Abraczinskas, M.

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

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

Zapata, EPA. December 3, 1999.

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 Product and

Refractory Manufacturing. Occupational Employment Statistics

. March 27, 2012. Available

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

. Docket Item No. EPA

- HQ

- OAR

2013

- 0290

- 0176

.

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. Docket Item No

. EPA

- HQ

OAR

- 2013

- 0290

- 0147

.

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. Docket Item No.

EPA

- HQ

- OAR

- 2013

- 0290

- 0161

.

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://www3.epa.gov/ttn/emc/cem/cems.xls

.

Gullett, B.

, and K. Raghunathan. 1997. “ Observations on the Effects of Process Parameters on

Dioxin/Furan Yield in Municipal Waste and Coal Sys tems .” Chemosphere , Vol

. 34 Nos

. 5

- 7,

pp . 1027

- 1032. March

- April 1997.

Hartman, M. 2015. Comment for the Brick MACT Cost of Sampling

. Memorandum from Michael

Hartman, Air

- Tech Environmental, to Brick and Structural Clay MACT Docket ID NO.

## 5 EPA

- HQ

- OAR

- 2013

- 0 291. March 19, 2015. Docket Item No. EPA

- HQ

- OAR

- 2013

- 0291

-

0 539.

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

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

## 6 Table 1. Summary of Monitoring Requirements and 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 $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 throughput 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

(kilns) pH Continuously monitor the scrubber liquid pH. Determine and

record 3

- hour block averages. HF, HCl

-- 3

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

and record 3

- hour block averages. All pollutants

Wet scrubber

(glazing) Pressure drop Continuously monitoring the pressure drop across the scrubber.

Determine and record 3

- hour block averages. PM

-- 3

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

and record 3

- hour block averages. All pollutants

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

## 7 Emission

control Monitor t ype/

operation/p rocess Monitoring requirements Emission

limits for

which

compliance is

demonstrated Monitoring c osts

, 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

Temperature 5

- Continuously monitor the kiln stack temperature and maintain

temperature at or below the highest 4

- hour average kiln stack

temperature established during the dioxin/furan performance

test.

- Continuously monitor the spray dryer operating temperature

and maintain 3

- hour block average temperature at or above the

average spray dryer operating temperature established during

the dioxin/furan performance test

.

- Continuously monitor the press dryer operating temperature

and maintain 3

- hour block average temperature at or below the

average press dryer operating temperature established dur ing

the dioxin/furan performance test

. 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 affected sources with no activated carbon injection control.

## 8 Table 2 . 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 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 emissi on monitoring system

.



### Cost year CEPCI 1

2007 525.4

2011 585.7

1 Reference: CE, 201 2

.

## 9 Table 3

. Estimated Costs for Periodic VE Monitoring of Clay Ceramics Sources 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

Training 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 ( 201 2 )

. 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

rat e 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 Assume d 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 Monitoring and Test ing Costs for Affected Clay Ceramics Facilities

Facility Affected source

type No. of

stacks Pollutants tested Test

cost, $ Annualized

test cost,

$/yr 1 

### Annual

monitoring

cost, $/yr

Kohler

Spartanburg Kiln 6 HF, HCl, PM, Hg, D/F $142,000 $35,000 $17,906

Glaze spray booth 8 PM

Kohler

Brownwood Kiln 1 HF, HCl, PM, Hg, D/F $54,000 $13,200 $2,984

Glaze spray booth 10 PM

Kohler

Wisconsin Kiln 2 HF, HCl, PM, Hg, D/F $71,000 $17,300 $5,969

Glaze spray booth 9 PM

Total $267,000 $65,500 $26,858

1 Annualized cost based on 7% interest, 5

- yr period.

## A ttachment 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 72 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 6 6 kiln stacks

Method 29

- Metals 6 6 kiln stacks; includes metals and PM testing

Method 23

– D/F 6 6 kiln stacks

Total No. of tests 2 6

Days 11 8 hours of test runs per day, plus 1.5 days for setup and teardown

Nights 10

Travel time to site (hours) 4

Item/Activity Cost Assumptions

Equipment rental

V olumetric flow sampler 550

CO 2 /O 2 analyzer 2,200

Sample lines 825

Trailer to haul equipment 2,200

Rental truck 1,100

Miscellaneous equipment 3,300

Total equipment rental cost 10,175

Travel

L abor 1,160

L odging 2,250

P er diem 120

V ehicle rental 660 One car

Total travel cost 4,190

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 13,885 Includes downtime, assumed to be 33% of testing time

T ake down equipment 290 Assume 2 hours for 3

- man crew

O nsite contingency 761 Approximately 5% of testing cost for short

- term delays

Total testing cost 15,976

Laboratory a nalysis

Method 5

- PM 1,080

Method 26A

- HF/HCl 3,000

Method 29

- Metals 15,900

Method 23

– D/F 18,720

Laboratory analysis cost 38,700

Test report

Data reduction and review 2,160 2 hr + 2 hr/test

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

Report review 1,680 1 hr + 0.5 hr/test for project manager

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

Total test report cost 5,480

Other

Audits 13,500 $500 + $500/test

ERT 27,000 $1,000 + $1,000/test

CEDRI 27,000 $1,000 + $1,000/test

Total other cost 67,500

## A

- 3 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 other cost 67,500

TOTAL 142,000

## A

- 4 Table A

- 2 . Estimated Cost of Emission Test

– Kohler

- Brownwood, TX

Parameter Value Assumptions

Hours of testing 1 2 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

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 5

- PM 1,350

Method 26A

- HF/HCl 500

Method 29

- Metals 2

, 6 50

Method 23

– D/F 3,120

Laboratory analysis cost 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

Other

Audits 7,000 $500 + $500/test

ERT 14,000 $1,000 + $1,000/test

CEDRI 14,000 $1,000 + $1,000/test

Total other cost 35,000

## A

- 5 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 other cost 35,000

TOTAL 54,000

## A

- 6 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 stack s

Method 29

- Metals 2 2 kiln stack s ; 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

V olumetric flow sampler 250

CO 2 /O 2 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

L abor 1,160

L odging 900

P er diem 120

V ehicle rental 300 One car

Total travel cost 2,480

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 5

- PM 1,215

Method 26A

- HF/HCl 1 ,0 00

Method 29

- Metals 5

, 3 0 0

Method 23

– D/F 6,240

Laboratory analysis cost 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

Other

Audits 8,000 $500 + $500/test

ERT 16,000 $1,000 + $1,000/test

CEDRI 16,000 $1,000 + $1,000/test

Total other cost 40,000

## A

- 7 SUMMARY

Total equipment rental cost 4,62 5

Total travel cost 2,48 0

Total testing cost 6 ,256

Laboratory analysis cost 1 3

, 755

Total test report cost 3,39 0

Total other cost 40,000

TOTAL 71,000

## 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

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 CO 2 = carbon dioxide; O 2 = oxygen; CO = carbon monoxide; NOx = nitrogen oxides;

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