Date: September 24, 2015 

To: Sharon Nizich, EPA/OAQPS/SPPD 

From: Thomas Holloway 

Subject: Monitoring and Testing Requirements and 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 emission standards for hazardous air pollutants 

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

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

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

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

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

determine the minimum regulatory “floors” for new and existing units.1 Therefore, on December 

18, 2014 the EPA proposed new standards for BSCP manufacturing, including limits for HF, 

HCl, chlorine (Cl2), mercury (Hg), and non-Hg HAP metals (or PM surrogate). The EPA 

provided a 90-day public comment period following proposal of the BSCP Manufacturing 

NESHAP, 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 purpose of this memorandum is to present the monitoring and 

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

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

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

requirements are intended to ensure compliance with the BSCP 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 monitoring requirements and costs. 

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

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

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

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). 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 

were first being developed for the BSCP 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-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 presented in 2011 dollars. 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, “Determination of Particulate Matter Emissions from 

Stationary Sources,” 40 CFR part 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 tests 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 limit in the proposed BSCP Manufacturing NESHAP. 

Each facility subject to the proposed BSCP Manufacturing NESHAP would conduct an initial 

performance test at each tunnel kiln stack using specified EPA test methods to demonstrate 

initial compliance with all applicable emission limits. These facilities would conduct a 

performance test for each affected tunnel kiln before renewing their title V operating permit or at 

least every 5 years following the initial performance test, as well as when an operating limit 

parameter value is being revised. Each facility subject to the proposed BSCP Manufacturing 

NESHAP would measure emissions of HF, HCl, Cl2, Hg, and non-Hg HAP metals (or PM 

surrogate) from each tunnel kiln stack during these performance tests. 

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

emissions of HF, HCl, and Cl2 using EPA Method 26A, “Determination of Hydrogen Halide and 
3 

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

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

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

Sources,” 40 CFR part 60, appendix A-8. Each test would consist of three runs, at 1 hour each. 

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

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

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

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

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

are detailed in Attachment A of this memorandum. In public comments on the proposed BSCP 

Manufacturing NESHAP (Hartman, 2015), Air-Tech Environmental stated that costs for new 

requirements should be added to the test costs and suggested values 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 request and is including these costs for each 

testing scenario in Attachment A, 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 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 Employment 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. 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-HQOAR-2013-0291-0153. 

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. 

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. 

EPA-HQ-OAR-2013-0291. March 19, 2015. Docket 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. 
5 

Table 1. Summary of Monitoring Requirements and Costs1

Emission 

control 

Monitor type/ 

operation/process Monitoring requirements 

Emission limits 

for which 

compliance is demonstrated 

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 

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

frequency to weekly after 30 days with no VE, or opacity ≤10% 

if VE observed. 

PM, non-Hg metals 

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

weight (load cells); or other system. Record all results. Record feeder setting once each shift, on a per ton of fired product basis. 

HF, HCl, Cl2 

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 

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

frequency to weekly after 30 days with no VE or opacity ≤10% 

if VE observed. 

PM, non-Hg metals 

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 or opacity ≤10% 

if VE observed. 

PM, non-Hg metals 

Pressure drop or 

Continuously monitor the pressure drop across the control device. Determine and record 3-hour block averages. 

PM, non-Hg metals 

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 

Limestone feeder setting 

Verify that there is adequate limestone in the hopper and silo. Record limestone feeder setting daily, on a per ton of fired product basis. 

HF, HCl, Cl2 

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

used during performance test. 

HF, HCl, Cl2
6 

Emission 

control 

Monitor type/ 

operation/process Monitoring requirements 

Emission limits 

for which 

compliance is demonstrated 

Wet scrubber pH Continuously monitor the scrubber liquid pH. Determine and 

record 3-hour block averages. 

HF, HCl, Cl2 

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

and record 3-hour block averages. 

All pollutants 

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 

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

frequency to weekly after 30 days with no VE or opacity ≤10% 

if VE observed. 

PM, non-Hg metals 

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

not ≤ limit, collect and record kiln process rate data and reduce data to 3-hour averages. 

HF, HCl, Cl2 

1 Reference: Shrager, 2003 2 No capital cost 3 No cost; included in control device costs 4 No cost; included in kiln operation costs 
7 

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

Cost element Labor Test ODCs 

Total cost, 

2007$ 

First costs, $  Planning $1,462 $0 $352 $1,8 Select equipment $6,346 $0 $643 $6,9 Support facilities $0 $0 $1,030 $1,0 Purchase BLD system hardware $0 $0 $18,232 $18,2 Install and check BLD system $161 $0 $5,022 $5,1 QA/QC Plan $739 $0 $0 $7 Total first costs $8,708 $0 $25,280 $33,9Annual costs, $/yr  Day-to-day activities $2,822 $0 $0 $2,8 Recordkeeping and reporting $254 $0 $0 $2 Annual QA & O&M review and update $384 $0 $3,490 $3,8 Capital recovery $1,240 $0 $3,600 $4,8 Total with capital recovery $4,701 $0 $7,090 $11,7

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 emis

Cost 

year CEPCI1

2007 525.4 2011 585.7 

1 Reference: CE, 2012. 
8 

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

Cost element 

Labor rates, 

$/hr2

Estimated costs, 2011$ 

First 30 days Rest of year Annual 

Annual costs, $/yr 

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

 Prepare for and document 

 Technical $48 $360 $574 $934

 Management4 $88 $33 $53 $86

 Clerical5 $28 $21 $34 $55

 Training every 5 years6 $976 $976

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

1 Reference: Shrager, 2003. 

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

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

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

include overhead. 

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

VE 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 ($2,000 each), amortized over 5 years at 7% interest rate. 

Table 4. Summary of Emission Test Costs 

No. of tunnel 

kiln stacks 

Cost per 

kiln/outlet, $ 

Annualized 

cost, $/yr1

1 $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 Tests for Each Testing Scenario 

 
 A-2 

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

Parameter Value Assumptions 

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

No. of tests 

Method 26A - HF/HCl 1 1 kiln stack 

Method 29 - Metals 1 1 kiln stack 

Total No. of tests 2 

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

Nights 2 

Travel time to site (hours) 4 

Item/Activity Cost Assumptions 

Equipment rental 

Volumetric flow sampler 150 

CO2/O2 analyzer 600 

Sample lines 225 

Trailer to haul equipment 600 

Rental truck 300 

Miscellaneous equipment 900 

Total equipment rental cost 2,775 

Travel 

Labor 1,160 

Lodging 450 

Per diem 120 

Vehicle rental 180 One car 

Total travel cost 1,910 

Testing cost 

Mobilization 460 4 hours for site manager and Technician II 

Setup equipment 580 Assume 4 hours for 3-man crew 

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

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

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

Total testing cost 2,611 

Laboratory analysis 

Method 26A - HF/HCl 500 

Method 29 - Metals 2,650 

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 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 

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, plus 1.5 days for setup and teardown 

Nights 2 

Travel time to site (hours) 4 

Item/Activity Cost Assumptions 

Equipment rental 

Volumetric flow sampler 150 

CO2/O2 analyzer 600 

Sample lines 225 

Trailer to haul equipment 600 

Rental truck 300 

Miscellaneous equipment 900 

Total equipment rental cost 2,775 

Travel 

Labor 1,160 

Lodging 450 

Per diem 120 

Vehicle rental 180 One car 

Total travel cost 1,910 

Testing cost 

Mobilization 460 4 hours for site manager and Technician II 

Setup equipment 580 Assume 4 hours for 3-man crew 

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

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

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

Total testing cost 3,826 

Laboratory analysis 

Method 26A - HF/HCl 1,000 

Method 29 - Metals 5,300 

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 technical reviewer; 8 hr + 0.5 hr/test for clerical 

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

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

Total test report cost 1,300 

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, plus 1.5 days for setup and teardown 

Nights 3 

Travel time to site (hours) 4 

Item/Activity Cost Assumptions 

Equipment rental 

Volumetric flow sampler 200 

CO2/O2 analyzer 800 

Sample lines 300 

Trailer to haul equipment 800 

Rental truck 400 

Miscellaneous equipment 1,200 

Total equipment rental cost 3,700 

Travel 

Labor 1,160 

Lodging 675 

Per diem 120 

Vehicle rental 240 One car 

Total travel cost 2,195 

Testing cost 

Mobilization 460 4 hours for site manager and Technician II 

Setup equipment 580 Assume 4 hours for 3-man crew 

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

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

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

Total testing cost 5,041 

Laboratory analysis 

Method 26A - HF/HCl 1,500 

Method 29 - Metals 7,950 

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 technical reviewer; 8 hr + 0.5 hr/test for clerical 

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

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

Total test report cost 1,680 

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, plus 1.5 days for setup and teardown 

Nights 4 

Travel time to site (hours) 4 

Item/Activity Cost Assumptions 

Equipment rental 

Volumetric flow sampler 250 

CO2/O2 analyzer 1,000 

Sample lines 375 

Trailer to haul equipment 1,000 

Rental truck 500 

Miscellaneous equipment 1,500 

Total equipment rental cost 4,625 

Travel 

Labor 1,160 

Lodging 900 

Per diem 120 

Vehicle rental 300 One car 

Total travel cost 2,480 

Testing cost 

Mobilization 460 4 hours for site manager and Technician II 

Setup equipment 580 Assume 4 hours for 3-man crew 

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

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

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

Total testing cost 6,256 

Laboratory analysis 

Method 26A - HF/HCl 2,000 

Method 29 - Metals 10,600 

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 technical reviewer; 8 hr + 0.5 hr/test for clerical 

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

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

Total test report cost 2,060 

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, plus 1.5 days for setup and teardown 

Nights 5 

Travel time to site (hours) 4 

Item/Activity Cost Assumptions 

Equipment rental 

Volumetric flow sampler 300 

CO2/O2 analyzer 1,200 

Sample lines 450 

Trailer to haul equipment 1,200 

Rental truck 600 

Miscellaneous equipment 1,800 

Total equipment rental cost 5,550 

Travel 

Labor 1,160 

Lodging 1,125 

Per diem 120 

Vehicle rental 360 One car 

Total travel cost 2,765 

Testing cost 

Mobilization 460 4 hours for site manager and Technician II 

Setup equipment 580 Assume 4 hours for 3-man crew 

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

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

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

Total testing cost 7,471 

Laboratory analysis 

Method 26A - HF/HCl 2,500 

Method 29 - Metals 13,250 

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 technical reviewer; 8 hr + 0.5 hr/test for clerical 

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

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

Total test report cost 2,440 

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 Costs1

Daily expenses $/day 

Lodging 75 

Per diem 40 

Vehicle rental 60 

Volumetric flow sampler 50 

CO2/O2 analyzer 200 

CO analyzer 200 

NOx analyzer 200 

SO2 analyzer 200 

FID/GC 400 

Sample lines 75 

Trailer to haul equipment 200 

Rental truck 100 

Miscellaneous equipment 300 

 

Labor rates (loaded) $/hr 

Onsite testing staff: 

Site manager 75 

Technician II 40 

Technician I 30 

 

Office staff: 

Project manager 120 

Technical reviewer 40 

Clerical 20 

Financial 50 

Method Analytes Cost, $ Notes 

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

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

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

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