## Date: September 24, 2015

To: Sharon Nizich, EPA/OAQPS/SPPD

From: Thomas Holloway

Subject: Monitoring and Testing Requirements a nd Costs for the Final Brick and Structural Clay Products Manufacturing NESHAP

I. Introduction

In accordance with section 112 of the Clean Air Act (CAA), the U.S. Environmental Protection Agency (EPA) established national em ission standards for hazardous air pollutants (NESHAP) on May 16, 2003, for the brick and struct ural clay products (B SCP) manufacturing industry. The NESHAP regulated emissions of hydrogen fluoride (HF), hydrogen chloride (HCl), and particulate matter (PM)—a surrogate for ha zardous air pollutant (HAP) metals—from tunnel kilns located at BSCP faciliti es. On March 13, 2007, the D.C. Circuit Court vacated the emission standards for BSCP manufacturing due to issu es associated with the methodology used to determine the minimum regulatory “f loors” for new and existing units. 1 

## Therefore, on December 18, 2014 the EPA proposed new standards for BSCP manufacturing, including limits for HF, HCl, chlorine (Cl 2 

## ), mercury (Hg), and non-Hg HAP metals (or PM surrogate). The EPA provided a 90-day public comment period fo llowing proposal of the BSCP Manufacturing NESHAP, during which all affected parties we re given the opportunity to comment on the proposed rule. The EPA has considered the comme nts received and, as appropriate, incorporated them into the final rule. The purpose of this memorandum is to present the monitoring and testing requirements for the final BSCP Manuf acturing 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 requirement s 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 ar e maintained and operated properly. These requirements are intended to ensure compliance w ith the BSCP manufacturing standards without

1 

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

## 2 imposing a significant additional burden for the facilities that must implement them. Table 1 summarizes the BSCP monitori ng 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 mon itoring 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 De termination 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 Ch emical 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 av ailable for scaling costs at the time that costs were first being developed for the BSCP manu facturing rule. Table 2 documents the cost elements included in the BLD costs.

The VE monitoring costs were calculated base d on the labor requireme nts associated with conducting a daily 15-minute VE check, prepari ng for and documenting the results of the VE checks, and having two people attend a VE trai ning course every 5 year s (Shrager, 2003). The VE monitoring costs are also presented in 2011 do llars. Table 3 documents the calculation of the VE monitoring costs.

In the event VE are observed, sources would be required to conduct an opacity test using EPA Method 9, “Visual Determination of the Opacity of Emissions from Stationary Sources,” 40 CFR part 60, appendix A-4. As an alternative to VE monitoring, sources could conduct annual PM testing using EPA Method 5, “Determinati on of Particulate Matter Emissions from Stationary Sources,” 40 CFR pa rt 60, appendix A-3. For purposes of this memorandum, costs for conducting these tests were not estimated, in the absence of any indication of whether or how many sources would need to conduct opacity test s and due to the higher cost of EPA Method 5 testing.

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 lim it in the proposed BSCP Manufacturing NESHAP. Each facility subject to the proposed BSCP Manufacturing NE SHAP would conduct an initial performance test at each tunne l kiln stack using specified EPA test methods to demonstrate initial compliance with all a pplicable emission limits. Th ese facilities would conduct a performance test for each affected tunnel kiln be fore 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 facili ty subject to the proposed BSCP Manufacturing NESHAP would measure em issions 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 would measure emissions of HF, HCl, and Cl 2 

## using EPA Method 26A, “Determination of Hydrogen Halide and

## 3 Halogen Emissions from Statio nary Sources-Isokinetic Method,” 40 CFR part 60, appendix A-8. The facilities were also assumed to measure em issions 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. 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 facilit ies testing four stacks, and one fo r facilities testing five stacks, the maximum number of tunnel kiln stacks at a BS CP facility. The costs for each testing scenario are detailed in Attachment A of this memo randum. In public comments on the proposed BSCP Manufacturing NESHAP (Hartman, 2015), Air-Tech Environmental stated that costs for new requirements should be added to th e test costs and suggested valu es for these costs. These new requirements and their suggested costs include the following:

 Audits, $1000

 Electronic Reporting Tool (ERT), $2000

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

The EPA agrees with the commenter’s reque st and is including these costs for each testing scenario in Attachment A, with 50 percen t 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 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 IndustrySpecific Occupational Employment and Wage Estimates, NAICS 327100 - Clay Product and Refractory Manufacturing. Occupational Empl oyment Statistics. March 27, 2012. Available
at: http://www.bls.gov/oes/2011/may/naics4_327100.htm . Docket Item No. EPA-HQ-OAR2013-0291-0069.

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

EPA (U.S. Environmental Protection Agency). 1997. Fabric Filter Bag Leak Detection Guidance. Publication No. EPA-454/R-98-015. Sept ember 1997. Docket Item No. EPA-HQOAR-2013-0291-0153.

EPA (U.S. Environmental Protection Agency). 2007. CEMS Cost Model. Technology Transfer Network, Emission Measurement Center, Con tinuous Emission Monitoring – Information, Guidance, etc. March 7, 2007. Available at: http://www3.epa.gov/ttn/emc/cem/cems.xls

. Hartman, M. 2015. Comment for the Brick MACT Cost of Sampling . Memorandum from Michael Hartman, Air-Tech Environmental, to Brick a nd Structural Clay MACT Docket ID NO. EPA-HQ-OAR-2013-0291. March 19, 2015. Dock et Item No. EPA-HQ-OAR-2013-0291- 0539.

## 4 Shrager, B. 2003. Final Rule: Monitoring and Monitoring Costs. Memorandum from Brian Shrager, RTI International, to Mary Johnson, EPA/ESD/CG. February 26, 2003.5Table 1. Summary of Monitoring Requirements and Costs1EmissioncontrolMonitor type/operation/processMonitoring requirementsEmission limitsfor whichcompliance isdemonstratedMonitoring costs,2011$Capital($)Annual($/yr)Dry injectionfabric filter(DIFF) or drylime scrubber/fabric filter(DLS)Bag leak detectororInstall and operate a bag leak detector in accordance withFabric Filter Bag Leak Detection Guidance. (EPA, 1997)PM, non-Hgmetals$37,888 $12,345Daily VE check Perform daily 15-minute Method 22 VE check. Can reducefrequency to weekly after 30 days with no VE, or opacity≤10%if VE observed.PM, non-Hgmetals--2$2,984Lime injection rate Verify that lime is free-flowing via pressure (flow sensors);weight (load cells); or other system. Record all results. Recordfeeder setting once each shift, on a per ton of fired productbasis.HF, HCl, Cl2--3Fabric filter Bag leak detectororInstall and operate a bag leak detector in accordance withFabric Filter Bag Leak Detection Guidance. (EPA, 1997)PM, non-Hgmetals$37,888 $12,345Daily VE check Perform daily 15-minute Method 22 VE check. Can reducefrequency to weekly after 30 days with no VE or opacity≤10%if VE observed.PM, non-Hgmetals--2$2,984Dry limestoneadsorber(DLA)Daily VE check Perform daily 15-minute Method 22 VE check. Can reducefrequency to weekly after 30 days with no VE or opacity≤10%if VE observed.PM, non-Hgmetals--2$2,984Pressure droporContinuously monitor the pressure drop across the controldevice. Determine and record 3-hour block averages.PM, non-Hgmetals--3Bypass stackdamper positionContinuously monitor the bypass stack damper position atleast once every 15 minutes during normal kiln operationPM, non-Hgmetals--4Limestone feedersettingVerify that there is adequate limestone in the hopper and silo.Record limestone feeder setting daily, on a per ton of firedproduct basis.HF, HCl, Cl2--3Limestone grade Use the same grade of limestone from the same source asused during performance test.HF, HCl, Cl26EmissioncontrolMonitor type/operation/processMonitoring requirementsEmission limitsfor whichcompliance isdemonstratedMonitoring costs,2011$Capital($)Annual($/yr)Wet scrubber pH Continuously monitor the scrubber liquid pH. Determine andrecord 3-hour block averages.HF, HCl, Cl2--3Liquid flow rate Continuously monitor the scrubber liquid flow rate. Determineand record 3-hour block averages.All pollutantsActivatedcarboninjectionsystemActivated carbonflow rateMonitor carbon flow rate once per shift. Record carbon flowrate for 15 minutes each shift.Hg --3No control Daily VE check Perform daily 15-minute Method 22 VE check; can reducefrequency to weekly after 30 days with no VE or opacity≤10%if VE observed.PM, non-Hgmetals--2$2,984Kiln process rate If last calculated total facility maximum potential HCl-equivalentnot≤limit, collect and record kiln process rate data and reducedata to 3-hour averages.HF, HCl, Cl2--41Reference: Shrager, 20032No capital cost3No cost; included in control device costs4No cost; included in kiln operation costs7Table 2. Estimated Costs for Bag Leak Detection for BSCP Kilns Equipped with Fabric Filters (Baghouses)1,2Cost elementLaborTestODCsTotal cost,2007$Total cost,2011$First costs, $Planning $1,462 $0 $352 $1,814Select equipment $6,346 $0 $643 $6,989Support facilities $0 $0 $1,030 $1,030Purchase BLD system hardware $0 $0 $18,232 $18,232Install and check BLD system $161 $0 $5,022 $5,184QA/QC Plan $739 $0 $0 $739Total first costs $8,708 $0 $25,280 $33,987 $37,888Annual costs, $/yrDay-to-day activities $2,822 $0 $0 $2,822 $2,822Recordkeeping and reporting $254 $0 $0 $254 $254Annual QA & O&M review and update $384 $0 $3,490 $3,874 $3,874Capital recovery $1,240 $0 $3,600 $4,840 $5,394Total with capital recovery $4,701 $0 $7,090 $11,791 $12,3451Reference: EPA, 2007. Updated to 2011 dollars using CEPCI.2ODC = other direct cost; QA/QC = quality assurance/quality control; O&M = operation and maintenance; and CEMS = continuous emission monitoring system.CostyearCEPCI12007 525.42011 585.71Reference: CE, 2012.

## 8 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 costs, $/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 (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 increas ed by 110 percent (%) to include overhead.

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

VE or opacity ≤ 10% if VE observed.

4 Assumed to be 5% of technical.

5 Assumed to be 10% of technical.

6 Assumes $2,000 per training course for two people ($2,0 00 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 $19,000 $4,600 2 $29,000 $7,100 3 $40,000 $9,800 4 $51,000 $12,400 5 $61,000 $14,900

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

## Attachment A

Estimated Costs of Emission Te sts 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, pl us 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 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 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 Laboratory analysis cost 3,150 Test report Data reduction and review 240 2 hr + 2 hr/test Report preparation 340 2 hr + 1 hr/test for tec hnical 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
Other Audits 1,500 $500 + $500/test ERT 3,000 $1,000 + $1,000/test CEDRI 3,000 $1,000 + $1,000/test Total other cost 7,500

## A-3 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 other cost 7,500 TOTAL 19,000

## A-4 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, pl us 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 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 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 Laboratory analysis cost 6,300 Test report Data reduction and review 400 2 hr + 2 hr/test Report preparation 440 2 hr + 1 hr/test for tec hnical 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
Other Audits 2,500 $500 + $500/test ERT 5,000 $1,000 + $1,000/test CEDRI 5,000 $1,000 + $1,000/test Total other cost 12,500

## A-5 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 other cost 12,500 TOTAL 29,000

## A-6 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, pl us 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 CO 2 /O 2 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 Laboratory analysis cost 9,450 Test report Data reduction and review 560 2 hr + 2 hr/test Report preparation 540 2 hr + 1 hr/test for tec hnical 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
Other Audits 3,500 $500 + $500/test ERT 7,000 $1,000 + $1,000/test CEDRI 7,000 $1,000 + $1,000/test Total other cost 17,500

## A-7 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 other cost 17,500 TOTAL 40,000

## A-8 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, pl us 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 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 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 Laboratory analysis cost 12,600 Test report Data reduction and review 720 2 hr + 2 hr/test Report preparation 640 2 hr + 1 hr/test for tec hnical 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
Other Audits 4,500 $500 + $500/test ERT 9,000 $1,000 + $1,000/test CEDRI 9,000 $1,000 + $1,000/test Total other cost 22,500

## A-9 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 other cost 22,500 TOTAL 51,000

## A-10 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, pl us 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 CO 2 /O 2 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 Laboratory analysis cost 15,750 Test report Data reduction and review 880 2 hr + 2 hr/test Report preparation 740 2 hr + 1 hr/test for tec hnical 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
Other Audits 5,500 $500 + $500/test ERT 11,000 $1,000 + $1,000/test CEDRI 11,000 $1,000 + $1,000/test Total other cost 27,500

## A-11 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 other cost 27,500 TOTAL 61,000

## 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 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.