Users Guide to the Monitoring Costs Assessment Tool 

Prepared for: 

Peter Westlin 

U.S. Environmental Protection Agency 

111 T.W. Alexander Drive 

Research Triangle Park, NC 

Prepared by: 

Kathy Boyer, David Hendricks, and Janet Hou 

EC/R Incorporated 

501 Eastowne Drive, Suite 250 

Chapel Hill, North Carolina 27514 

919-484-0222 

www.ecrweb.com

November 30, 2009 
i 

Table of Contents 

Acronyms ...................................................................................................................................... iii

1. Introduction ........................................................................................................................... 1

1.1 Brief History of Tool Development ................................................................................. 1

1.2 Principles of Tool Development and Use ........................................................................ 1

1.3. Limitations of Tool ........................................................................................................... 2

1.3.1. Data inflexible ........................................................................................................... 3

1.3.2. Multiple Monitoring Strategies and Pollutants ........................................................ 3

2. Using the Monitoring Costs Assessment Tool .................................................................... 4

2.1 Stepwise Instructions with Screen Shots .......................................................................... 4

3. Resources/References ............................................................................................................ 15

APPENDIX A. COST VARIABLES AND ASSUMPTIONS ............................................... A-1

A.1 Cost Variables .......................................................................................................... A-1

A.2 Average Costs of Periodic and CPMS Purchased Equipment ................................. A-4

A.3. Labor Costs .............................................................................................................. A-6

A.4. Assumptions .............................................................................................................. A-9

Appendix B. Case Studies Using the MCAT ......................................................................... B-1

B.1 Portland Cement Kilns ................................................................................................. B-1

B.1.1 Introduction .............................................................................................................. B-1

BA.1.2. Methodology ........................................................................................................ B-2

B.1.3. Cost Analysis........................................................................................................... B-2

B.1.4. Results ..................................................................................................................... B-3

B.2 Glass Manufacturing ....................................................................................................... B-5

B.2.1. Introduction ............................................................................................................. B-5

B.2.2. Methodology ........................................................................................................... B-5

B.2.3. Cost Analysis........................................................................................................... B-5

B.2.4. Results ..................................................................................................................... B-6
ii 

List of Tables 

Table A-1. Individual and Average Costs of Monitoring Instruments ...................................... A-5

Table A-2. Base and Loaded Labor Rates ................................................................................. A-7

Table A-3. Labor Cost by Category ........................................................................................... A-8

Table A-4. Monitoring Strategies by Pollutant and Control Strategy ..................................... A-11
iii 

Acronyms 

CAM Compliance Assurance Monitoring 

CEMS Continuous Emissions Monitoring System 

CO Carbon monoxide 

CO2 Carbon dioxide 

CPMS Continuous Parametric Monitoring System 

CRF Capital Recovery Factor 

EPA U.S. Environmental Protection Agency 

HAP Hazardous Air Pollutant 

HCl Hydrogen chloride 

Hg Mercury 

MACT Maximum Achievable Control Technology 

MCAT Monitoring Costs Assessment Tool 

NOX Nitrogen oxide 

NSPS New Source Performance Standards 

OAQPS Office of Air Quality Planning and Standards 

OM Operations and Management 

PM2.5 Particulate Matter with an aerodynamic diameter of 2.5 micrometers or less 

PM10 Particulate Matter with an aerodynamic diameter of 10 micrometers or less 

RATA Relative Accuracy Test Audit 

RCA Response Correlation Audit 

RIA Regulatory Impact Analysis 

RRA Relative Response Audit 

SO2 Sulfur dioxide 

THC Total Hydrocarbon 

VOC Volatile Organic Compound 
 

1 

1. Introduction 

1.1 Brief History of Tool Development 

The Compliance Assurance Monitoring (CAM) Rule, promulgated in 1997, focuses on 

monitoring for “reasonable assurance of compliance” with air pollution regulations. The rule 

targets emissions units with add-on control devices and requires source owners to design 

monitoring that fits the site. The monitoring elements derived from this process are intended to 

satisfy and are incorporated into operating permits. The CAM rule applies to pollutant specific 

emission units that are located at a major source subject to a title V permit and that are: 

1) Subject to an emissions limitation or standard, 

2) Use a control device to achieve compliance, and 

3) Have pre-control emissions that exceed or are equivalent to the major source threshold. 

In 2006, the U.S. Environmental Protection Agency (EPA) undertook to revise the CAM rule to 

expand applicability to a broader range of control measures. 

As part of this revision effort, the EPA has developed a monitoring cost assessment tool 

to assist in completing the regulatory impact analysis. We present an expanded version of the 

Monitoring Cost Assessment Tool (MCAT) to help you, the rule writers, as you prepare source 

category specific or other air pollution emissions reduction rules and the supporting economic 

analyses you need. The MCAT provides information not only about monitoring that would 

satisfy the CAM rule but also for more rigorous and direct emissions monitoring applicable to a 

range of regulatory approaches. The purpose of this tool is to provide you with a user-friendly 

method to make informed decisions about monitoring options as you develop new and revised 

regulations. 

1.2 Principles of Tool Development and Use 

 The MCAT allows you to calculate the economic costs of installing and operating various 

monitoring strategies for a variety of pollutants (i.e., CO2, CO, HCl, Hg, NOX, SO2, organic 

HAPs, PM2.5, PM10, VOC/THCs) and a variety of control measures. Based on the scope of the 

rule you are writing, the pollutants to be covered, and the control measures you expect to be 

used, the MCAT allows you to calculate the initial and annual costs of installing and operating 
 

2 

new monitoring for your rule. You must input information about the control strategy for each 

particular pollutant covered by your rule and select a range of monitoring strategies using a dropdown menu of options. These monitoring options range from periodic manual operational 

parametric or emissions data collection (e.g., observations of emissions that occur in a set 

interval, such as every day, once a week, three times a month, quarterly), continuous parametric 

monitoring (CPMS) (e.g., continuous monitoring of a particular operational condition or 

surrogate pollutant, such as gas flow rate, temperature), design and work practice monitoring 

(e.g., raw material or fuel analyses and inspection records), to a continuous emissions monitoring 

system (CEMS) (i.e., a continuous direct measurement of pollutant emissions). Associated with 

each type of pollutant are required performance tests that can be administered either yearly or 

every five years. 

 Much of the background for the MCAT is based on the experience gained in OAQPS in 

developing guidance materials and regulatory tools related to emissions testing and monitoring 

over the past 35 years. We applied the draft tool in two case studies to gauge its utility. The 

case studies were in support of the regulatory development work for glass manufacturing 

facilities and for cement kilns. The cement kiln case study focused on a proposed rule that 

would regulate criteria pollutants generated by cement kilns including NOX, SO2, and both 

filterable and condensable particulate matter. The glass manufacturing case study focused on a 

proposed area source NESHAP regulation controlling particulate matter. We applied the tool 

assuming control technology most likely used to meet the proposed regulation to determine a 

reasonable array of available monitoring technologies that could apply. From these data, we 

used MCAT to establish the cost to the entire source category to implement those monitoring 

options. Appendix A includes the summary of these two case studies. 

1.3. Limitations of Tool 

While we intend this tool to be user-friendly and to provide a good estimate of the costs 

associated with the various control strategies, you should be aware of and take into account the 

following limitations of the tool as you proceed through a rule development process: 
 

3 

1.3.1. Data inflexible 

The cost data for testing, monitoring equipment, installation, and operations are fixed in 

this version of the MCAT. We constructed the tool this way to prevent accidental changes to the 

database that may prevent the tool from functioning properly. While Access is a powerful 

database, it is also very particular about how the data and tables are created and entered. We 

intend that the tool will undergo periodic updates to ensure labor rates and equipment costs 

remain current and relevant. 

1.3.2. Multiple Monitoring Strategies and Pollutants 

This initial version of the tool assesses monitoring costs for one pollutant and type of 

emissions control measure combination at a time. The MCAT does not yet have the capacity to 

assess combined costs for multiple pollutant emissions or combined strategies. One result of this 

approach is a more conservative (i.e., high bias) estimate of monitoring costs. Economies 

associated with combined use of a data acquisition system for multi-parameter CPMS or 

multipollutant CEMS, for example, would reduce overall costs below what the MCAT would 

calculate. The tool also assumes the purchase and installation of complete new monitoring 

equipment in calculating costs; that is, the tool includes no allowances for building on any 

existing monitoring. 

The tool also does not have the capability to calculate costs for multiple pollutants. 

Under most circumstances, facilities will need to control and monitor the control measures for 

multiple pollutant emissions (e.g., not only SO2 or just VOC/THCs). In the future, we intend to 

enhance the tool to include the ability to select multiple pollutants for monitoring and calculate 

costs accordingly. 
 

4 

2. Using the Monitoring Costs Assessment Tool 

 Before starting the tool, there is some information you should have on-hand to ensure the 

most accurate assessment for your needs. Once you have an industry or source category in mind 

to serve as the focus of your rule development, you will need: 

 the list of pollutants for which there are to be emissions limits, 

 the control measures you expect sources to use to meet those emissions limits, and 

 the test methods you will require to demonstrate compliance. 

 For each pollutant and control measure you repeat the assessment only to the degree that 

a control measure is effective in controlling one or more pollutants. The MCAT will provide a 

report of the findings for each iteration of the assessment. The tool will also calculate costs for 

multiple emission units for pollutants. For example, if you are assessing the costs for 50 cement 

kilns comprising a source category and you expect all cement kilns to use a particular control 

measure, you can tell the tool you want to calculate costs for 50 kilns. The tool will then 

multiply all costs by 50 to give you a final cost. If 30 percent of the kilns will use one type of 

control measure and 70 percent will use another type, you can specify the tool to calculate costs 

for 15 kilns using one control measure and in a separate assessment calculate costs for 35 kilns 

using a different control measure. 

2.1 Stepwise Instructions with Screen Shots 

This section walks you, step by step, through the MCAT. The tool is designed to help 

you determine the costs and benefits of implementing a particular control strategy in the 

development of new and revised air pollution regulations. 

 All text appearing in quotation marks indicates text you will see on the computer screen 

as icons, buttons, or menus. Bold text indicates text seen in the tool. “Clicking” refers to 

clicking one time on the primary left button on the mouse, and “double click” refers to clicking 

two times on the primary left button on the mouse. 

We have included screen shots for your reference while navigating the tool. In this 

section you will learn how to start and exit from the tool, save results and calculations from your 
 

5 

analysis, determine which calculations to make, and step-by-step instructions to determine the 

cost. 

Starting Cost Tool 

 Open “My Computer” on your desktop 

 Double click your CD-ROM drive 

 Copy the “MCAT” file to your desktop 

 Once the tool has been copied onto your desk top, double-click the icon. If you are using 

Microsoft Office 2003 click “Open” when the Security Dialogue box appears: 

 If you use Microsoft Office 2007 follow the instructions in red as seen below: 
 

6 

 Click “Begin Calculating Costs” to begin, or “Quit” to exit the tool 

Exiting MCAT 

 After you have completed your cost analysis and exported or printed your results, click 

on “File” and choose the “Exit” option 

Below is a step-by-step screen shot description of the tool in the “Monitoring Costs” mode. 

 

Step 1 – Choose the pollutant you are controlling. Click on the blue down arrow of the 

“Pollutant” drop-down box and then click the specific pollutant. The options are: 

 Carbon Monoxide (CO) 

 Carbon Dioxide (CO2) 

 Hydrochloride (HCl) 

 Mercury (Hg) 

 Nitrogen Oxide (NOX) 

 Fine Particulate Matter (PM(fine)) 

 Particulate Matter larger than 10 

microns (PM10) 

 Sulfur Dioxide (SO2) 

 Volatile Organic Compounds 

(VOC/THC) 
 

7

Step 2 – Choose the specific strategy you wish to use to control your pollutant. These strategies 

are specific to the pollutant type. The options will change when you change pollutants. Click on 

the blue arrow of the “Control Measure” drop-down box to see the list of control strategies for 

your particular pollutant, and click on the your preferred strategy to continue. 
 

8

Step 3: Once you have chosen your control measure enter in the total number of emission points 

for which you are calculating costs. Then click “Continue” – this button will bring you to the 

next page where you can choose the various control and monitoring strategies. 

Now you must choose which type of monitoring you will use. You can use Periodic Monitoring 

and Inspections, Continuous Parametric Monitoring, or a Continuous Emissions Monitoring 

System (CEMS). Note that the control strategy you chose in Step 2 may determine which 

monitoring type you use – some strategies are available only for Period Monitoring or only for 

Parametric Monitoring. Others may be available in both. Regardless of the control strategy 

chosen in Step 2, each pollutant has a CEMS associated with it. 

 Once you have chosen your pollutant and monitoring strategy, click the blue arrow in the 

“Periodic Monitoring and Inspections:” drop-down box. Click on the strategy you wish to 

cost to select it. 
 

9
 

10

When you select a strategy, if a performance test method is required the box will become live 

and you can select the appropriate test. 

Once you choose an emissions test method, select the appropriate frequency of testing (either a 

1- or 5-year interval). 
 

11

The MCAT will calculate the costs and present the total initial and annual costs for all emission 

units you requested in Step 3 in red. 
 

12

Step 3b – Follow the steps above for CPMS. Again, the values are predetermined and cannot be 

changed by the user. 
 

13

Step 3c – Follow the steps above for a Continuous Emissions Monitoring System. Again, the 

values are predetermined and cannot be changed by the user. 

Create Report 

The tool does not allow you to save your work, but you can create a printable report that you can 

print for your records: 

 Click on the “Create Report” button in the top right corner:
 

14

The report contains the specific cost elements for each monitoring strategy: 
 

15

3. Resources/References 

U.S. Environmental Protection Agency, 2002, “EPA Air Pollution Control Cost Manual, Sixth 

Edition,” EPA 452/B-02-001. http://www.epa.gov/ttncatc1/products.html#cccinfo. 

Research Triangle Institute, 2007, “Continuous Emission Monitoring System (CEMS) Cost 

Model.” http://www.epa.gov/ttn/emc/cem.html. 

U.S. Bureau of Labor Statistics, 2007, “National Compensation Survey: Occupational Wages in 

the United States, 2007.” http://www.bls.gov/ncs/ncswage2007.htm. 

Chemical Engineering, “Chemical Engineering Plant Cost Index.” 

http://www.che.com/business_and_economics/economic_indicators.html. 

Omega Engineering, “The Pressure Strain and Force Handbook,” 8th Edition, Volume MMVIII. 

http://www.omega.com/. 

Omega Engineering, “The Flow, Level and Environmental Handbook & Encyclopedia,” 7th

Edition, Volume MMVII. http://www.omega.com/. 

Omega Engineering, “The OMEGA Temperature Handbook and Encyclopedia,” 5th Edition, 

Volume MMV. http://www.omega.com/. 

Omega Engineering, “The Data Acquisition Systems Handbook and Encyclopedia,” 21st Century 

2nd Edition. http://www.omega.com/. 
 

A-1 

APPENDIX A. COST VARIABLES AND ASSUMPTIONS 

A.1 Cost Variables

 The MCAT will determine both capital (or initial) and annual costs for each option 

selected. Capital costs are costs incurred once by the facility to implement monitoring 

technology. These include purchase of equipment, installation, and initial performance 

demonstration (e.g., calibration). Annual costs are those a facility incurs every year using the 

monitoring technology. These include annual performance tests, regular quality assurance 

checks and calibrations, and taxes. 

 The categories of capital and annual costs for each type of monitoring technology (i.e., 

periodic, CPMS and CEMS) are largely the same although there are a few differences. Below 

are the categories of capital (or initial) costs for each type of monitoring: 

Continuous Emissions Monitoring System (CEMS) and Continuous Parametric 

Monitoring System (CPMS) – Planning and Initial Costs 

 Planning (i.e., labor spent determining which strategy to use and how to implement it) 

 Equipment Selection and Purchase (e.g., the hours and dollars spent determining which 

monitoring technology to purchase, choosing the particular model or brand to use, and 

determining the need for and purchasing of support equipment and facilities to house the 

monitoring technology and to gather and store data) 

 Quality Assurance/Quality Control Plan (i.e., create and then implement QA/QC plan) 

 Installation and Calibration of System (e.g., labor and supplementary equipment 

necessary to install and calibrate chosen monitoring equipment) 

 Initial Performance Tests/Audits (e.g., perform required and other tests and audits to 

ensure equipment is functioning properly) 

Periodic Monitoring 

 Planning 

 Equipment Selection and Purchase 

 Installation and Calibration of System 
 

A-2 

 Training Course and Certification (e.g., train technicians to operate purchased equipment 

or to conduct effective inspections) 

Below are the components of the annual costs for the three types of monitoring. 

CEMS 

 Operations and Maintenance (OM) (includes the day-to-day activities such as 

maintenance and QA/QC checks of the sample collection and conditioning systems, 

analyzers, computer systems, and software) 

 Annual Relative Accuracy Test Audit (RATA) 

 Recordkeeping and Reporting (e.g., annual cost to maintain records and reports of output 

of monitoring equipment) 

 Annual Quality Assurance Reviews and Updates 

 Capital Recovery Factor (0.0944) (see below for explanation and equation to calculate 

the capital recovery factor, or CRF) 

 PM CEMS Response Correlation Audit (RCA)/PM CEMS Relative Response Audit 

(RRA) (methods used to conduct accuracy audits of CEMS specified in 40 CFR 60, 

Appendix B) 

 Cylinder Gas Audits (i.e., an alternative to the relative accuracy audit for a continuous 

emissions monitoring system using gases certified by or traceable to National Institute of 

Standards and Technology (NIST) in the ranges specified in 40 CFR 60, Appendix F) 

CPMS 

 OM 

 Annual Relative Accuracy Test Audit (RATA) or Emission Test 

 Recordkeeping and Reporting 

 Annual Quality Assurance Reviews and Updates 

 Periodic Inspections (i.e., weekly, quarterly, etc. inspections of equipment to ensure 

equipment is working properly) 

 Capital Recovery Factor (0.0944) 
 

A-3 

 Property taxes and insurance (we assumed a four percent rate to account for taxes and 

insurance for the monitoring equipment)Error! Bookmark not defined.

Periodic Monitoring System 

 OM 

 Recordkeeping and Reporting 

 Annual Performance Audits/Emission Tests 

 Semiannual Training/Certification (e.g., training courses or certification exams to ensure 

operators of the monitoring equipment are qualified to operate the equipment and analyze 

results) 

 Property taxes and insurance 

 Quarterly Leak Checks (e.g., checks on equipment to ensure there is no leakage of 

pollutants) 

 Visual Inspections (e.g., inspections to check for any leaks via visibly looking for leaks 

or for the opacity of stack discharges) 

 Capital Recovery Factor (0.2439) 

We obtained the number of hours to conduct each activity from the EPA Air Pollution 

Control Cost Manual, Sixth Edition (Control Cost Manual) 1. We also contacted various 

monitoring equipment manufacturers requesting pricing information that we then averaged for 

the purposes of this project. If we were unable to obtain a price quote from industrial sources we 

turned to the Control Cost Manual.

“Operations and Management” costs are the sum of 10 percent of the equipment selection 

and purchase costs and 10 percent of the installation and calibration of the equipment, as 

recommended by the Control Cost Manual. 

The annualized costs are multiplied by a capital recovery factor (CRF), which represents the 

benefits of the technology after having made the requisite payments to purchase the equipment. 

To calculate the CRF we used the following formula: 

[i(1+i)n

]/[((1+i)n)-1] 

 

1

 US EPA/OAQPS, 2000, “Sixth Edition Control Cost Manual”, Section2, Chapter 4, EPA/452/B-02-001. 
 

A-4 

where: 

i = interest rate of 7 percent 

n = number of years to pay off the equipment (20 years for CEMS and CPMS monitoring 

equipment and 5 years for periodic monitoring equipment) 

 We used several sources to develop our cost estimates for the various monitoring 

technologies, including the Control Cost Manual (primarily to develop the equipment costs of 

monitoring technology and the emissions tests); the 2007 CEMS cost model spreadsheet 

(available at http://www.epa.gov/ttn/emc/cem.html) or other spreadsheets based on the CEMS 

cost model, which provide both capital and annual costs for all CEMS, and industrial estimates 

of technology costs. Complete references for these sources can be found in Section 5 of this 

users guide. 

A.2 Average Costs of Periodic and CPMS Purchased Equipment 

The cost of a particular piece of equipment is obtained from averaging a selection of 

retailer prices for that piece. Table A-1 details the various costs and the averages for several 

monitoring technologies that we obtained for each piece of equipment. While some pieces have 

fairly uniform prices among retailers (such as the flame ionization detector), some have a wider 

range of prices due to additional perks (such as an installation kit, the equipment measures 

multiple emissions, etc.; see the O2 (excess air) monitor or soil/coal moisture as examples) and 

are thus more expensive. When possible we tried to obtain pricing for the specific monitoring 

equipment without the add-ons. Finally, our average costs were based on costs obtained from 

three suppliers at best for each piece of equipment. We would prefer a much larger selection of 

prices so that our average costs are more representative. 
 

A-5 

Table A-1. Individual and Average Costs of Monitoring Instruments 

Company Instrument Name Cost ($2008) 

O2 (Excess air) monitor/carbon injection rate 

Topac.com 

Handheld oxygen monitor $1,358 

Handheld oxygen monitor w/USB 

interface 

$1,716 

Guardian Gas Monitor $2,338 

Interface card for G.G. Monitor $323 

Unigas Monitor $1,189-$3,452 

Ambient CO Sniffer $363 

Unknown Oxygen monitor $348 

General Monitors Toxic sensor without relays $1,450 

AVERAGE COST $1,277.12 

Liquid flow rate and pH monitoring 

Omega Engineering pH Controller $237-$393 

AVERAGE COST $315 

Voltage/current/power 

Omega Engineering Voltage/current differential 

monitor 

$293 

Omega Engineering Voltage/current inputs (panel 

meter) 

$242 

AVERAGE COST $268 

Soil or Coal moisture 

Reliable procurement 

Heavy duty moisture meter $297 

Protimeter (w/hygrometer and data 

storage) 

$980 

Professional Equipment Digital soil moisture meter $288 

Dynamax 

Th2O (meter with readout unit, 

extension handle and moisture 

level chart) 

$990 

SM200 (soil moisture sensor) with 

GP1 Data logger 

$695 

AVERAGE COST $650 
 

A-6 

Company Instrument Name Cost ($2008) 

Flame ionization detector 

Sleuth Portable FID (for hydrocarbon 

measurements) 

$5,720 

Perkins-Elmer Portable FID $4,262 

REPSS.com Photovac MicroFID (includes FID, 

charger, filters, Teflon probe, 

carrying trap) 

$7,356 

AVERAGE COST $5,780 

Face velocity 

Dawson Associates Inc. VelociCheck (includes air velocity 

meter, carrying case, AA batteries, 

manual, NIST calibration cert.) 

$502 

TSI 3650 Model (Fume hood 

controller) – includes sensors and 

controllers 

$1,691 

AVERAGE COST $1,097

A.3. Labor Costs 

We obtained labor costs used in the cost calculations from the Department of Labor June 

2007 Census data.2

 We adjusted these labor rates to obtain loaded labor rates by multiplying 

them by the fringe benefit loading rate and overhead and profit rate. We obtained the fringe 

benefit rate from the Bureau of Labor Statistics and the overhead and profit rate from the 

Information Collection Request developed for the municipal waste combustors New Source 

Performance Standards. We use this loaded labor rate to determine the labor cost for control 

strategies and then multiply the loaded labor costs by the average labor hours to obtain the final 

labor cost. The average labor hours (i.e., level of effort) were obtained from the Control Cost 

Manual. Tables A-2 and A-3 detail the loading rates and calculations. 

 

2

 U.S. Bureau of Labor Statistics, 2007, “National Compensation Survey: Occupational Wages in the United States, 

June 2006”, http://www.bls.gov/ncs/ocs/. 
 

A-7 

Table A-2. Base and Loaded Labor Rates 

Labor Category 

Hourly 

Earnings Fringe Overhead Loaded 

Professional specialty and technical $39.27 1.43 1.67 $93.780687

Executive, admin, managerial $59.72 1.4 1.67 $139.62536

Admin support $16.34 1.41 1.67 $38.475798

Precision production, craft, repair $20.85 1.4 1.67 $48.7473 

Machine operators, assemblers, 

inspectors $16.21 1.4 1.67 $37.89898 
 

A-8 

Table A-3. Labor Cost by Category 

 

 Labor Rate 

Annual 

Cost 

Activity 

Labor 

Category 

Level of 

Effort (hr) $/hr Cost ($) 

Planning 

Technical 36 93.78 $3,376.10 

Management 3.8 139.62 $530.58 

Clerical 3.6 38.48 $138.51 

TOTAL $4,045.19 $4,045.19

Recordkeeping and 

Reporting 

Technical 2.28125 93.78 $213.94 

Management 2.28125 139.62 $318.52 

Clerical 9.125 38.48 $351.09 

Operator 9.125 37.90 $345.83 

TOTAL $1,229.38 $1,229.38

Accuracy Audits 

Technical 2 93.78 $187.56 

Management 0.1 139.62 $13.96 

Clerical 0.2 38.48 $7.70 

TOTAL $209.22 $209.22

Leak Checks 

(quarterly) 

Technical 1 93.78 $93.78 

Management 0.05 139.62 $6.98 

Clerical 0.1 38.48 $3.85 

TOTAL $104.61 $418.44

Visual Inspections 

(weekly) 

Technical 0.25 93.78 $23.45 

Management 0.0125 139.62 $1.75 

Clerical 0.025 38.48 $0.96 

TOTAL $26.15 $1,359.92

Install new sensors 

Technical 2 93.78 $187.56 

Management 0.1 139.62 $13.96 

Clerical 0.2 38.48 $7370 

TOTAL $209.22 $209.22

 Queries are used to calculate the total annual and capital costs (i.e., summing up the 

different costs for a particular strategy for a final cost estimate). The results from each of these 

queries are then placed into Access tables which are then drawn into the user interface. 
 

A-9 

A.4. Assumptions 

 While the list of pollutants and control technologies may be expanded in the future, we 

believe we have captured the majority of currently available monitoring options. In developing 

this tool, we have created several set scenarios based on commonly applied monitoring 

approaches. This section discusses the assumptions made about these set scenarios and how they 

impact the cost outputs of the assessment tool. 

We estimated equipment costs by averaging the costs obtained from various 

manufacturers for each particular piece of equipment. If industrial contacts were unable to 

provide price quotes, we turned to the Control Cost Manual. Additionally, the labor hours used 

to calculate costs for recordkeeping and reporting, installation and calibration and certification 

were obtained from the Control Cost Manual. The labor rates are the 2007 labor rates developed 

by the U.S. Bureau of Labor Statistics3. The equipment costs have been escalated to 2008 

dollars using the Chemical Engineering Plant Cost Index (CEPCI)4. Aside from these general 

assumptions, we have also made several assumptions were made about specific technologies and 

are presented below. 

Specific technology assumptions 

 The equipment cost for the “Fuel Analysis” strategy is the same as that of “Liquid Flow 

Meter.” The reason is because, through discussions with retailers with some knowledge 

of fuel analysis, one simply uses a liquid flow meter to gather the data, and then uses 

some type of analyzer to determine the levels of metals in the fuel. Therefore the cost of 

equipment to perform a fuel analysis includes a liquid flow meter and some type of fuel 

analyzer. As of yet we do not have a price for a fuel analyzer. 

 The equipment cost for the “Pressure Drop (Vacuum)” is the same as that of “Pressure 

Drop.” 

 We could not locate the source for the fringe benefit rate and the overhead and profit rate 

used in the first User Manual Draft (submitted September 8, 2006) and so we have used 

the same rates from 2004. 

 

3 http://www.bls.gov/ncs/#tables

4 http://www.che.com/business_and_economics/economic_indicators.html
 

A-10 

 The equipment cost for “Liquid Flow Rate and pH” is the same as “Liquid Flow Rate” 

with the addition of a pH monitor. 

 The equipment costs for “Temperature Single Point/Two Point and Weekly/Monthly 

Inspections” is the same as “Temperature Monitoring Single Point/Two Point” with the 

added labor cost for weekly or monthly inspections. 

We developed the costs for the emissions tests in the tool from various RIAs and 

technical background documents of rules and regulations that included the costs for emissions 

tests. We have also assumed that each emission unit will require one unit of the monitoring 

technology and the subsequent performance tests, calibration costs, etc. Thus if you calculate 

costs for 50 emission units the total costs of the monitoring technology for these units is simply 

the costs of one monitoring technology unit multiplied by 50. Table 4 summarizes the 

pollutants, associated control measures and associated monitoring options.
A-11 

Table A-4. Monitoring Strategies by Pollutant and Control Strategy

Pollutant CEMS Control Strategy Periodic Monitoring C

CO CO Process Equipment and Operation for CO Inspections and Testing OCO2 CO2 Performance Testing Method 3A (Instrumental) Method 3B (Manual) NHAP 

VOC (outlet only) VOC (inlet and outlet) 

Capture Devices 

Pressure Drop Portable VOC Analyzer Gas Flow Rate Face Velocity Explosive Meter 

PrGVFa

Carbon Adsorber 

Gas Flow Rate (Steam) Pressure Drop (Vacuum) Portable Flame Ionization Detector with Equipment Inspections 

PrG

Condenser Temperature (two point) Temperature (single point) TRegenerative Thermal Oxidizer Temperature (single point) and Weekly Inspections Temperature (two point) and Weekly Inspections T

InA

Thermal Oxidizer Temperature (two point) Temperature (single point) T

A

Catalytic Oxidizer Temperature (single point) and Monthly Inspections T

In

Floating-Roof Tank Inspections and Testing NRepair Equipment Leaks Leak Detection and Repair NFlare Flame Detector with Equipment Inspections Fl

wA

Use Low/No HAP Material Product Analysis (Coatings and Solvents) Pr

an
A-12 

HCl HCl 

Dry FGD/Lime-injected Fabric Filter/ESP Lime Flow Rate (Liquid) and Visible Emissions N

Lime-injected Fabric Filter 

Lime Flow Rate (Liquid) Visible Emissions (M9) and Equipment Inspections Visible Emissions (DOCS) and Equipment Inspections 

B

Wet Scrubber Liquid Flow Rate and pH Periodic Testing L

L

Hg Hg 

Carbon Injection Carbon Injection Rate C

SCR/Wet Scrubber Periodic Testing LWet Scrubber Liquid Flow Rate and pH Periodic Testing L

L

NOX NOX

Process Equipment and Operation for NOX (EGR) 

NOX Analyzer (Quarterly RAAs and Annual RATA) 

NOX Analyzer (Monthly RAAs and Annual RATA) NOX Analyzer (Annual RATA only) NOX Analyzer (Quarterly RATA) 

T

Process Equipment and Operation for NOX (LNB/OFA) 

NOX Analyzer (Quarterly RAAs and Annual RATA) 

NOX Analyzer (Monthly RAAs and Annual RATA) NOX Analyzer (Annual RATA only) NOX Analyzer (Quarterly RATA) 

T

Water Injection for Gas Temperature Reduction Liquid Flow Rate LNSCR 

NH3 Injection Rate 

NOX Analyzer (Annual RATA only) 

NOX Analyzer (Monthly RAAs and Annual RATA) NOX Analyzer (Quarterly RAAs and Annual RATA) NOX Analyzer (Quarterly RATA) Pressure Drop Temperature (Single Point) Temperature (Inlet) 

N

O

MTM

SCR NH3 Injection Rate Temperature (Inlet) N

TM
A-13 

NOX NOX SNCR NH3 Injection Rate Temperature (Inlet) N

TM

PM(fine) condensable 

PM (in situ) PM (beta gauge) PM (extractive) 

Dry ESP followed by Fabric Filter Temperature, Voltage/Current/Power, Visible Emissions, and Equipment Inspections T

VB

Wet ESP Voltage/Current/Power and Liquid Flow Rate V

L

Ambient Temperature Fabric Filter Visible Emissions (M9) and Equipment Inspections Visible Emissions (DOCS) and Equipment Inspections BVenturi Scrubber for PM Control Pressure Drop and Liquid Flow Rate Pr

Fl

PM/ PM(Fine) Filterable 

PM (in situ) PM (beta gauge) PM (extractive) 

Dust Suppression 

Visible Emissions (M9) Soil or Coal Moisture Visible Emissions (DOCS) 

O

Electrified Filter Bed Voltage/Current/Power VVenturi Scrubber for PM Control Pressure Drop and Liquid Flow Rate Pr

Fl

Dry ESP Visible Emissions (DOCS) and Voltage/Current/Power Visible Emissions (DOCS) and Voltage/Current/Power O

V

Wet ESP Voltage/Current/Power and Liquid Flow Rate V

L

Fabric Filter Visible Emissions (M9) and Equipment Inspections Visible Emissions (DOCS) and Equipment Inspections B

SO2 SO2

Low Sulfur Fuel/Feed Fuel Analysis and Records N

Dry FGD with Fabric Filter/ESP 

Visible Emissions (M9) and Equipment Inspections Visible Emissions (DOCS) and Equipment Inspections Visible Emissions (DOCS) and Voltage/Current/Power 

BOVTV

Wet Scrubber-FGD/Acid Gas Liquid Flow Rate and pH Liquid Flow Rate L

L
A-14 

VOC/THC 

VOC (outlet only) VOC (inlet and outlet) 

Capture Devices 

Explosive Meter Portable VOC Analyzer Pressure Drop Gas Flow Rate Face Velocity 

VPrGFa

Carbon Adsorber 

Portable Flame Ionization Detector with Equipment Inspections Flow Rate (Steam) Pressure Drop (Vacuum) 

GPr

Condenser Temperature (two point) Temperature (single point) TRegenerative Thermal Oxidizer Temperature (single point) and Weekly Inspections Temperature (two point) and Weekly Inspections T

InA

Thermal Oxidizer Temperature (two point) Temperature (single point) T

A

Catalytic Oxidizer Temperature (single point) and Monthly Inspections T

In

Floating-Roof Tank Inspections and Testing NRepair Equipment Leaks Leak Detection and Repair NFlare Flame Detector with Equipment Inspection 

FlwA

 Use Low/No HAP Material Product Analysis (Coatings and Solvents) Pr

an
 

B-1

Appendix B. Case Studies Using the MCAT 

We developed two case studies to demonstrate how the tool can be used: Portland 

cement kilns and glass manufacturers. The case studies provide an introduction to monitoring in 

the particular industry, the methodology for calculating monitoring costs (including obtaining 

information and assumptions), and the results. 

The principal benefit of improved monitoring is associated with reducing the uncertainty 

of compliance status, and as a result, reducing emissions. Improving the knowledge of emissions 

control device or control measure performance and ongoing compliance status at facilities has 

been shown to reduce emissions. This assertion, tested and confirmed by a study on the use of 

continuous monitors at Portland cement plants5

, is that by implementing a monitoring program 

that requires continuous surveillance of conditions that affect and are necessary to maintain 

emissions control, owners and operators of facilities will achieve a higher level of compliance, 

and lower emissions, than they otherwise would be able to achieve. Improved monitoring may 

impact emissions in two ways: (1) facilities operating outside the range of conditions that 

indicate compliance (i.e., excursions) as defined by the monitoring will act to return operations 

to acceptable conditions, thus reducing emissions, and (2) periods of excursions from acceptable 

conditions will be identified more quickly with continuous monitoring than with less frequent 

approaches, thus reducing the duration of such excursions. 

B.1 Portland Cement Kilns 

B.1.1 Introduction 

 This case study provides you with an example of a cost analysis of implementing 

continuous emissions monitoring as part of a proposed area source rule for cement kilns. The 

regulation would impose PM, SO2, and NOX emission limits on kilns, and PM limits on clinker 

coolers. For the purposes of this case study, we evaluated the costs of implementing continuous 

emissions monitoring on particulate matter (PM), sulfur dioxide (SO2), and nitrogen oxides 

(NOX) emissions. The following sections present the methodology and cost comparisons. 

 5

 U.S. Environmental Protection Agency, Study on Benefits of Continuous Opacity Monitors Applied 

to Portland Cement Kilns. May 15, 1991. 
 

B-2

BA.1.2. Methodology 

 We obtained data for cement kilns from the EPA’s National Emissions Inventory. Table 

B-1 summarizes these emissions and other parameters of the case study. We assumed that PM2.5

comprised 45 percent of total PM emissions and that an 83 percent reduction in total PM 

emissions (75 percent reduction in PM2.5 emissions) would be achieved by installing either 

pulse-jet or reverse-air fabric filters on affected emission units. Likewise, we assumed a 95 

percent reduction in SO2 would be achieved by installing a wet scrubber, and a 40 percent 

reduction in NOX would be achieved by installing selective non-catalytic reduction (SNCR) 

technology on kilns.6

 

Table B-1. Parameters for Estimating Costs of Continuous Emissions Monitoring on Cement Kilns 

Emission 

Point Pollutant 

No. 

Kilnsa

Control 

Technology 

Uncontrolled 

Emissions 

(tpy) 

Emission 

Reductions 

(tpy) 

Controlled 

Emissions 

(tpy) 

Emissions 

Monitoring 

Option 

Kiln PM 20 Pulse-Jet FF 300 249 52 Bag Leak Detector 

 20 Reverse Air FF 300 249 52 Bag Leak Detector 

PM2.5 20 Pulse-Jet FF 135 112 23 Bag Leak Detector 

 20 Reverse Air FF 135 112 23 Bag Leak Detector 

NOX 20 SNCR 1500 600 900 NOX CEMS 

SO2 4 Wet Scrubber 7800 7410 390 SO2 CEMS 

Clinker 

Cooler PM 20 Pulse-Jet FF 300 249 52 Bag Leak Detector 

 20 Reverse Air FF 300 249 52 Bag Leak Detector 

PM2.5 20 Pulse-Jet FF 135 112 23 Bag Leak Detector 

 20 Reverse Air FF 135 112 23 Bag Leak Detector a

 This represents the number of kilns that would be subject to the new regulation in the case study. 

B.1.3. Cost Analysis 

 We used the cost function of the tool to evaluate costs for a model plant to install and 

operate continuous emissions monitoring technology on cement kiln and clinker cooler controls. 

We obtained costs for continuous emissions monitoring of PM, SO2, and NOX from the CEMS 

 

6

 Email communication with Jeffrey Cole, April 21, 2008. 
 

B-3

Revised Cost Model (2007) and flow meter equipment costs to convert SO2 and NOX air 

concentrations to lb/ton of clinker from the Omega Green Book.7 

 We then applied those model plant costs to the kilns expected to be controlled by the new 

rule. Costs may be over- or under-estimated due to variability in plant size, modifications 

required to install control equipment on emission units, or whether other controls already exist. 

B.1.4. Results 

Table B-2 presents a summary of the parameters and costs calculated for all applicable 

cement kilns. Table B-3 presents a cost breakdown of CEMS for an individual cement kiln. 

Cumulative annualized costs are $203,000 for PM and PM2.5 monitoring, $200,000 for SO2

monitoring, and $990,000 for NOX monitoring. Note that while costs are borne by the facilities, 

benefits are realized by a larger population. Any cost savings realized by individual facilities 

have not been calculated as part of this case study. 

Table B-2. Industry-wide Costs of Continuous Emissions Monitoring on Cement Kilns 

Pollutant 

Control 

Technology Monitoring 

No. 

Kilns 

Total Initial 

Costs 

Total 

Annualized 

Costs 

 

PM Puls-Jet FF 

BLD w/ 5 sensors for the kiln 

baghouse and 5 for the clinker cooler 20 $1,904,686 $737,177 

 

Reverse Air 

FF 

BLD w/ 5 sensors for the kiln 

baghouse and 5 for the clinker cooler 20 $1,904,686 $737,177 

PM2.5 Puls-Jet FF 

BLD w/ 5 sensors for the kiln 

baghouse and 5 for the clinker cooler 20 $1,904,686 $737,177 

 

Reverse Air 

FF 

BLD w/ 5 sensors for the kiln 

baghouse and 5 for the clinker cooler 20 $1,904,686 $737,177 

NOX SNCR NOX CEMS 20 $2,969,912 $989,873 

SO2 Wet Scrubber SO2 CEMS 4 $602,634 $200,031 

 

7 Omega Handbook Series: The Green Book. Flow, Level, and Environmental Handbook, p. F-17. Volume MMVII 

7th Edition. 
B-4

Table B-3. Continuous Emission Monitoring Costs (1 facility) 

Parameter Description NOX

BLD w/ 5 sensors for 

the kiln baghouse an

5 for the clinker 

cooler 

Planning Engineering and managerial labor for reviewing the regulations, 

resolving questions, reviewing engineering drawings, and inspecting the source $2,936.02 $2,139.1

Equipment Selection and Purchase 

Cost of equipment and labor associated with its purchase 

$96,156.37 $77,197.7

Install and Calibrate Travel costs, fees, and labor to install and calibrate equipment $18,076.14 $15,101.7Performance Test Audits Performance test of the monitor conducted once every five years. 

$10,104.60 $0.0

QA/QC Plan Labor associated with developing a QA/QC Plan $22,332.45 $795.6

Total Capital CEMS $148,495.58 $95,234.3

Operation and Maintenance Labor costs associated with daily activities $9,132.75 $4,148.9RATA Relative Accuracy Test Audit conducted annually $8,143.80 $0.0Cylinder Gas Audits EPA testing procedure to ensure the accuracy of CEMS data. 

Known concentrations of specified gases are passed through the CEMS unit and measurements over a period of time are taken and averaged. 

$2,718.55 $0.0

Recordkeeping and reporting Annual costs of recordkeeping and reporting $4,441.05 $1,378.8Annual QA Reviews and Update 

Labor associated with annual quality assurance reviews 

$3,911.74 $17,769.7

Capital Recovery Equipment and calibration costs calculated at a set interest rate 

over five years. Factor is .09 for Continuous Monitoring and .24 for Periodic Monitoring $21,145.77 $13,561.3CEMS Total Annual $49,493.66 $36,858.8

[a] For BLD monitoring, we assumed that 5 sensors would be installed on the clinker cooler baghouse and 5 would be installed on the kiln baghouse at $5

installation cost per sensor. We assumed that only one BLD apparatus (including the data logger and control box) would be needed for both the clinker coo

$11,500. 

[b] Flow meter costs total $1,110 ($1,024 for the meter plus 8 percent for tax and freight). 
 

B-5

B.2 Glass Manufacturing 

B.2.1. Introduction

 In this case study, we provide a cost analysis of implementing improved monitoring as 

part of a proposed area source NESHAP for glass manufacturing plants. The rule applies to 

those plants producing at least 50 tons of glass per year by melting raw materials that includes 

one or more HAP metals. For the purposes of this case study, we evaluated the costs of 

implementing improved monitoring on area source particulate matter (PM) controls, although the 

rule will only apply to HAP. The following sections present the methodology and cost 

comparisons. 

B.2.2. Methodology 

 We obtained PM emissions data for the portion of the glass manufacturing industry 

subject to the proposed rule from the EPA’s National Emissions Inventory. National baseline 

uncontrolled PM emissions reported for the affected category are 3,965 tons/year. We assumed 

that PM2.5 comprised 91 percent of total PM emissions. For the purpose of this case study, we 

also assumed that an 84 percent reduction in total PM emissions (and a 75 percent reduction in 

PM2.5 emissions) would be achieved by installing either a dry electrostatic precipitator (ESP) or a 

baghouse on affected emission units.8 

B.2.3. Cost Analysis 

We used the cost function of the tool to evaluate costs for a model plant to install and 

operate improved monitoring technology on a baghouse or a dry ESP. We obtained all costs for 

continuous emissions monitoring of PM, opacity, and bag leak detection from the CEMS 

Revised Cost Model (2007). We obtained capital and installation costs for most periodic 

monitoring options from the Control Cost Manual or personal communications with EPA 

personnel.9,10 We used an Environmental Security Technology Certification Program report11 for 

 

8

 Personal communication with Susan Fairchild, EPA on May 23, 2007. 

9

 EPA Air Pollution Control Cost Manual - Sixth Edition (EPA 452/B-02-001) 

10 Personal communication with Peter Westlin and Barrett Parker, EPA. 11 Source: Environmental Security Technology Certification Program (2005) "An Alternative to EPA Method 9 -- 

Field Validation of the Digital Opacity Compliance System (DOCS)" Final Report Project Number CP-200119 May 

2005. 
 

B-6

the costs associated with conducting a visible emission test All labor rates are in 2006 dollars, 

and we obtained the rates from the Department of Labor.12

We then applied those costs model plant costs to the 15 facilities expected to be 

controlled. Costs may be over- or under-estimated due to variability in plant size, modifications 

required to install control equipment on emission units, or whether other controls already exist. 

Table B-4 presents the monitoring options available in the tool for the corresponding control 

technologies. 

Table B-4. Monitoring Options for Selected PM Control Scenarios 

Control 

Technology Periodic Monitoring 

Continuous 

Parametric 

Monitoring 

Continuous 

Emissions 

Monitoring 

Baghouse Visible Emissions using 

Method 9, plus equipment 

inspections 

Bag Leak Detector 

(1 sensor) 

PM (extractive) 

 

Visible Emissions using 

Computer-Based Photographic 

Analysis System, plus 

equipment inspections 

Opacity PM (in situ) 

Dry ESP Visible Emissions using 

Method 9, plus 

voltage/current/power 

Voltage/Current/ 

Power 

PM (extractive) 

 

Visible Emissions using 

Computer-Based Photographic 

Analysis System, plus 

voltage/current/power 

Voltage/Current/ 

Power and 

Equipment 

Inspections 

PM (in situ) 

B.2.4. Results 

Table B-5 presents a summary of the parameters and costs calculated for facilities 

applicable to the proposed NESHAP. Table B-6 presents a cost breakdown of various 

 

12 U.S. Department of Labor, Bureau of Labor Statistics. May 2006 National Industry-Specific Occupational 

Employment and Wage Estimates, NAICS 327200: Glass and Glass Product Manufacturing Available: 

http://www.bls.gov/oes/current/naics4_327200.htm 
 

B-7

monitoring options for a dry ESP. Table B-7 presents similar information for a fabric filter. 

Table B-5 shows that the cumulative costs of periodic monitoring are less than continuous 

monitoring. However, Table B-6 shows that continuous monitoring costs are less than periodic 

monitoring of a dry ESP for an individual plant. 

Table B-5. Summary of Parameters and Costs for Glass Manufacturing Plants 

Parameters 

Total No. Facilities Expecting Control: 15 

PM2.5 Emissions After Control (tons/yr): 975 

Control Scenario: 

HAP Raw Materials, 

Nationwide 

 

Particulate Matter Monitoring Costs Summary 

 Control 

Technology 

No. 

Facilities 

Continuous Emission 

Monitoring 

Continuous Parametric 

Monitoring Periodic Monitoring 

 Capital Annual Capital Annual Capital Annual 

Dry ESP 10 $1,321,168 $504,095 $96,114 $77,462 $111,623 $147,877 

Baghouse 5 $660,584 $252,048 $191,185 $141,090 $57,023 $54,461 

Total 15 $1,981,752 $756,143 $287,299 $218,552 $168,645 $202,338 
B-8

Table B-6. Costs for Particulate Matter Monitoring Using Dry ESP for One Glass Manufacturin

Parameter Description CEMS CPMS Periodic M

Initial Costs 

PM 

(extractive) 

PM 

(in situ) 

Voltage/Current 

/Power 

Voltage/Current 

/Power and 

Weekly 

Inspections 

VE (DOCS) 

and 

Voltage/Current 

/Power 

Planning 

Engineering and managerial labor for reviewing the regulations, resolving questions, reviewing engineering drawings, and inspecting the source $850 $850 $3,022.27 $3,022.27 $3,022.27 

Equipment Selection and Purchase 

Cost of equipment and labor associated with its purchase $75,830 $45,667 $5,470.00 $5,470.00 $5,000.00 

Install and Calibrate 

Travel costs, fees, and labor to install and calibrate equipment $18,467 $15,790 $960.00 $960.00 $159.15 

Training and Certification 

Travel costs and labor required for training and certification, plus test fees - - - - $3,140.00 

QA/QC Plan 

Labor associated with developing a QA/QC Plan $19,454 $19,454 - - - 

Performance Test Audits 

Performance test of the monitor conducted once every five years. $33,936 $33,936 $159.15 $159.15 - Total $148,537 $115,697 $9,611.42 $9,611.42 $11,162.27 

Annualized Costs Operation and Maintenance 

Labor costs associated with daily activities $2,524 $1,524 $270.00 $270.00 $1,759.00 

RATA 

Relative Accuracy Test Audit conducted annually - - - - - 

Emission Test 

Annualized cost of a stack test conducted once every five years - - $1,956.00 $1,956.00 $1,956.00 

Recordkeeping and reporting 

Annual costs of recordkeeping and reporting $7,925 $7,925 $3,578.00 $3,578.00 $4,778.00 
B-9

Annual QA Reviews and Update 

Labor associated with annual quality assurance reviews $4,055 $3,055 - - - 

Capital Recovery 

Equipment and calibration costs calculated at a set interest rate over five years. Factor is .09 for Continuous Monitoring and .24 for Periodic Monitoring $21,152 $16,475 $1,040.52 $1,040.52 $1,985.00 

PM Monitor RCA 

Response Correlation Audit required by Part 60 $6,057 $6,057 - - - 

PM Monitor RRA 

Relative Response Audit required by Part 60 $10,689 $10,689 - - - 

Cylinder Gas Audits 

EPA testing procedure to ensure the accuracy of CEMS data. Known concentrations of specified gases are passed through the CEMS unit and measurements over a period of time are taken and averaged. $1,346 $1,346 - - - 

Periodic Inspections 

Annualized cost of weekly inspections - - - $1,034.49 - 

Property Taxes, Insurance, Admin. 

Calculated as 4% of capital costs (Parametric Monitoring Only). - - $384.46 $384.46 $206.37 Total $53,748 $47,071 $7,228.98 $8,263.47 $10,684.37 
B-10

Table B-7. Costs for Particulate Matter Monitoring Using Fabric Filter for One Glass Manufactu

Parameter Description CEMS CPMS Per

Initial Costs 

PM 

(extractive) 

PM 

(in situ) 

Bag Leak 

Detector 

(1 Sensor) Opacity 

Visible Emis

(DOCS) a

Equipmen

Inspection

Planning 

Engineering and managerial labor for reviewing the regulations, resolving questions, reviewing engineering drawings, and inspecting the source $850 $850 $622 $850 $3,022 

Equipment Selection and Purchase 

Cost of equipment and labor associated with its purchase $75,830 $45,667 $17,524 $33,502 $6,183 

Install and Calibrate 

Travel costs, fees, and labor to install and calibrate equipment $18,467 $15,790 $3,450 $3,574 $159 

Training and Certification 

Travel costs and labor required for training and certification, plus test fees - - - - $3,140 

QA/QC Plan 

Labor associated with developing a QA/QC Plan $19,454 $19,454 $647 $14,731 - 

Performance Test Audits 

Performance test of the monitor conducted once every five years. $33,936 $33,936 $1,574 - Total $148,537 $115,697 $22,243 $54,231 $12,504 

Annual Costs Operation and Maintenance 

Labor costs associated with daily activities $2,524 $1,524 $2,470 $8,040 $1,355 

RATA 

Relative Accuracy Test Audit conducted annually - - $12,886 - - 

Emission Test 

Annualized cost of a stack test conducted once every five years - - - - $1,956 

Recordkeeping and reporting 

Annual costs of recordkeeping and reporting required by Part 63 $7,925 $7,925 $147 $7,925 $1,200 
B-11

Annual QA Reviews and Update 

Labor associated with annual quality assurance reviews $4,055 $3,055 $2,106 $3,305 - 

Capital Recovery 

Equipment and calibration costs calculated at a set interest rate over five years. Factor is .09 for Continuous Monitoring and .24 for Periodic Monitoring $21,152 $16,475 $3,167 $7,723 $1,985.0

PM Monitor RCA 

Response Correlation Audit required by Part 60 $6,057 $6,057 - - - 

PM Monitor RRA 

Relative Response Audit required by Part 60 $10,689 $10,689 - - - 

Cylinder Gas Audits 

EPA testing procedure to ensure the accuracy of CEMS data. Known concentrations of specified gases are passed through the CEMS unit and measurements over a period of time are taken and averaged. $1,346 $1,346 - - - 

Periodic Inspections Annualized cost of weekly inspections - - - - $1,034 Property Taxes, Insurance, Admin. 

Calculated as 4% of capital costs (Parametric Monitoring Only). - - $890 $1,225 $247.32 Total $53,748 $47,071 $21,666 $28,218 $7,777