# 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, 2009i 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-6ii 

# List of Tables

Table A-1. Individual a nd Average Costs of Monitoring Instruments ...................................... A-5 Table A-2. Base and Lo aded Labor Rates ................................................................................. A-7 Table A-3. Labor Cost by Category ........................................................................................... A-8 Table A-4. Monitoring Strategies by Pollutant and Control Strategy ..................................... A-11iii Acronyms CAM Compliance Assurance Monitoring CEMS Continuous Emissions Monitoring System CO Carbon monoxide CO 2 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 NO X Nitrogen oxide NSPS New Source Performance Standards OAQPS Office of Air Qualit y Planning and Standards OM Operations and Management PM 2.5 Particulate Matter with an aerodynamic diameter of 2.5 micrometers or less PM 10 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 SO 2 Sulfur dioxide THC Total Hydrocarbon VOC Volatile Organic Compound1 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 complia nce” with air pollution regulations. The rule targets emissions units with add-on control de vices and requires source owners to design monitoring that fits the site. The monitoring elem ents 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 sour ce subject to a title V permit and that are:

1) Subject to an emissi ons limitation or standard, 2) Use a control device to achieve compliance, and 3) Have pre-control emissions that exceed or ar e 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 broade r range of control measures. As part of this revision effort, the EPA ha s developed a monitoring cost assessment tool to assist in completing the regulatory impact an alysis. We present an expanded version of the Monitoring Cost Assessment Tool (MCAT) to he lp you, the rule writers, as you prepare source category specific or other ai r pollution emissions reduction ru les and the supporting economic analyses you need. The MCAT provides info rmation not only about monitoring that would satisfy the CAM rule but also for more rigorous and direct emissions mon itoring applicable to a range of regulatory approaches. The purpose of th is tool is to provide you with a user-friendly
method to make informed decisions about mon itoring 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 va riety of pollutants (i.e., CO 2 , CO, HCl, Hg, NO X , SO 2 , organic HAPs, PM 2.5 , PM 10 , VOC/THCs) and a variety of control measures. Based on the scope of the rule you are writing, the pollutants to be covere d, and the control measures you expect to be used, the MCAT allows you to cal culate the initial and annual co sts of installing and operating2 new monitoring for your rule. You must input information about the control strategy for each particular pollutant covered by your rule and sele ct a range of monitoring strategies using a dropdown menu of options. These monitoring optio ns range from periodic manual operational parametric or emissions data collection (e.g., obs ervations of emissions that occur in a set interval, such as every day, once a week, three tim es a month, quarterly), continuous parametric monitoring (CPMS) (e.g., continuous monitoring of a particular operational condition or surrogate pollutant, such as ga s flow rate, temperature), desi gn and work practice monitoring (e.g., raw material or fuel analyses and inspecti on records), to a continuous emissions monitoring system (CEMS) (i.e., a continuous direct measurem ent 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 em issions 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 ge nerated by cement kilns including NO X , SO 2 , and both filterable and condensable particulate matter. The glass manufacturing case study focused on a proposed area source NESHAP regulation controlli ng particulate matter. We applied the tool assuming control technology most likely used to meet the propos ed regulation to determine a reasonable array of available monitoring technolo gies that could apply. From these data, we
used MCAT to establish the cost to the enti re source category to implement those monitoring options. Appendix A includes the su mmary of these two case studies.

1.3. Limitations of Tool
While we intend this tool to be user-frien dly 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 pr oceed through a rule development process:3 1.3.1. Data inflexible The cost data for testing, monitoring equipm ent, installation, and operations are fixed in
this version of the MCAT. We c onstructed the tool this way to pr event accidental changes to the database that may prevent the tool from func tioning properly. While Access is a powerful database, it is also very particular about how th e data and tables are created and entered. We
intend that the tool will under go 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 m onitoring 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 conservati ve (i.e., high bias) estimate of monitoring costs. Economies associated with combined use of a data acq uisition system for multi-parameter CPMS or multipollutant CEMS, for example, would reduc e overall costs below what the MCAT would calculate. The tool also assumes the purchas e 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, facil ities will need to control and m onitor the control measures for multiple pollutant emissions (e.g., not only SO 2 or just VOC/THCs). In the future, we intend to enhance the tool to include the ability to sel ect multiple pollutants for monitoring and calculate costs accordingly.4 2. Using the Monitoring Costs Assessment Tool Before starting the tool, there is some info rmation 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 th ere 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 repe at 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 asse ssment. The tool will also calculate costs for multiple emission units for pollutants. For exampl e, 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 calcul ate costs for 50 kilns. The tool will then multiply all costs by 50 to give you a final cost. If 30 percent of the kiln s will use one type of control measure and 70 percent will use another t ype, you can specify the tool to calculate costs for 15 kilns using one control measure and in a se parate 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 th e MCAT. The tool is designed to help you determine the costs and benefits of implem enting a particular co ntrol strategy in the development of new and revi sed air pollution regulations. All text appearing in quotat ion marks indicates text you will see on the computer screen as icons, buttons, or menus. Bold text indicates text seen in th e 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 refe rence while navigating the tool. In this section you will learn how to start and exit from th e tool, save results and calculations from your5 analysis, determine which calculations to make, a nd 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 de sk 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 in structions 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 “F ile” and choose the “Ex it” option

Below is a step-by-step screen sh ot 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 speci fic pollutant. The options are:

 Carbon Monoxide (CO)

 Carbon Dioxide (CO 2 )

 Hydrochloride (HCl)

 Mercury (Hg)

 Nitrogen Oxide (NO X )

 Fine Particulate Matter (PM(fine))

 Particulate Matter larger than 10 microns (PM 10 )  Sulfur Dioxide (SO 2 )

 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 th e your preferred strategy to continue.8 Step 3: Once you have chosen your control measure en ter in the total number of emission points for which you are calculating costs. Then clic k “Continue” – this butt on will bring you to the next page where you can choose the vari ous control and monitoring strategies.

Now you must choose which type of monitoring you will use. You can use Periodic Monitoring and Inspections, Continuous Parametric Mon itoring, or a Continuous Emissions Monitoring System (CEMS). Note that the control stra tegy 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 availabl e 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 mon itoring strategy, click th e blue arrow in the

“ Periodic Monitoring and Inspections: ” drop-down box. Click on the strategy you wish to
cost to select it.910 When you select a strategy, if a performance te st method is required the box will become live and you can select th e appropriate test.

Once you choose an emissions test method, select th e appropriate frequency of testing (either a 1- or 5-year interval).11 The MCAT will calculate the costs and present the total ini tial 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 printa ble 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, “Nati onal 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,” 8 th Edition, Volume MMVIII. http://www.omega.com/

.

Omega Engineering, “The Flow, Level a nd Environmental Handbook & Encyclopedia,” 7 th
Edition, Volume MMVII. http://www.omega.com/

.

Omega Engineering, “The OMEGA Temp erature Handbook and Encyclopedia,” 5 th Edition,
Volume MMV. http://www.omega.com/

.

Omega Engineering, “The Data Acquisit ion Systems Handbook and Encyclopedia,” 21 st Century
2 nd 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 faci lity to implement monitoring technology. These include purchase of equipmen t, installation, and initial performance demonstration (e.g., calibration). Annual costs are those a facility incurs every year using the monitoring technology. These include annual perf ormance tests, regular quality assurance checks and calibrations, and taxes. The categories of capital and annual costs fo r 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/Aud its (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 SystemA-2  Training Course and Certifica tion (e.g., train technicians to operate purchased equipment or to conduct effective inspections)

Below are the components of the annual co sts for the three type s of monitoring.

CEMS

 Operations and Maintenance (OM) (incl udes 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 Rela tive Response Audit (RRA) (methods used to conduct accuracy au dits 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 certif ied by or traceable to National Institute of Standards and Technology (NIST) in the ra nges specified in 40 CFR 60, Appendix F)

CPMS

 OM

 Annual Relative Accuracy Test A udit (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 f our 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/Certificati on (e.g., training courses or cert ification exams to ensure operators of the monitoring equipment are qua lified to operate the equipment and analyze results)

 Property taxes and insurance

 Quarterly Leak Checks (e.g., checks on equipm ent to ensure ther e 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 manufacturer s requesting pricing information that we then averaged for the purposes of this project. If we were unabl e to obtain a price quote fr om industrial sources we
turned to the Control Cost Manual. “Operations and Management” costs are the su m of 10 percent of th e equipment selection and purchase costs and 10 percent of the insta llation 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 equipmen t (20 years for CEMS and CPMS monitoring equipment and 5 years for peri odic monitoring equipment)

We used several sources to develop our cost estimates for the various monitoring technologies, including the Cont rol Cost Manual (primarily to develop the equipment costs of monitoring technology and the emissions test s); 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 annu al 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 equipmen t. While some pieces have fairly uniform prices among retaile rs (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 O 2 (excess air) monitor or soil/c oal moisture as examples) and are thus more expensive. When possible we tr ied 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 mu ch larger selection of prices so that our average co sts are more representative.A-5 Table A-1. Individual and Average Costs of Monitoring Instruments

Company Instrument Name Cost ($2008) O 2 (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 $650A-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. Veloci Check (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 calc ulations 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 overh ead and profit rate. We obtained the fringe
benefit rate from the Bureau of Labor Statisti cs 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 co sts by the average labor hours to obtain the final labor cost. The average labor hour s (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 Comp ensation 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 $37.89898A-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 calcul ate the total annual and capital costs (i.e., summing up the different costs for a particular strategy for a fina l 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 tec hnologies may be expanded in the future, we believe we have captured the majority of current ly available monitoring options. In developing this tool, we have created several set s cenarios based on commonly applied monitoring approaches. This section discusses the assumpti ons made about these set scenarios and how they impact the cost outputs of the assessment tool. We estimated equipment costs by averag ing the costs obtained from various manufacturers for each particular piece of equipmen t. 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 reportin g, installation and calibration and certification
were obtained from the Control Cost Manual. Th e labor rates are the 200 7 labor rates developed by the U.S. Bureau of Labor Statistics 3 . The equipment costs have been escalated to 2008 dollars using the Chemical Engine ering Plant Cost Index (CEPCI) 4 . Aside from these general assumptions, we have also made several assumpti ons were made about sp ecific technologies and are presented below.

Specific technology assumptions

 The equipment cost for the “Fuel Analysis” stra tegy is the same as that of “Liquid Flow Meter.” The reason is because, through discus sions with retailers with some knowledge of fuel analysis, one simply uses a liquid fl ow meter to gather th e 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 an alysis includes a liqui d flow meter and some type of fuel analyzer. As of yet we do not ha ve a price for a fuel analyzer.

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

 We could not locate the source for the fringe benefit rate and the ove rhead and profit rate used in the first User Manual Draft (subm itted 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.htmlA-10  The equipment cost for “Liquid Flow Rate a nd 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 te sts in the tool from various RIAs and technical background documents of rules and regu lations that included the costs for emissions
tests. We have also assumed that each emi ssion 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 to tal costs of the mon itoring technology for these units is simply the costs of one monitoring technology unit multiplied by 50. Table 4 summarizes the pollutants, associated control measur es and associated monitoring options.A-11Table A-4. Monitoring Strategiesby Pollutant and Control StrategyPollutant CEMS Control Strategy Periodic Monitoring CPMSCO COProcess Equipment and Operation forCOInspections and Testing O2(Excess Air)CO2CO2Performance TestingMethod 3A (Instrumental)Method 3B (Manual)NoneHAPVOC (outletonly)VOC (inletand outlet)Capture DevicesPressure DropPortable VOC AnalyzerGas Flow RateFace VelocityExplosive MeterPressure DropGas Flow RateVOC AnalyzerFace Velocity/Flow RateCarbon AdsorberGas Flow Rate (Steam)Pressure Drop (Vacuum)Portable Flame Ionization Detector with EquipmentInspectionsPressure Drop (Vacuum)Gas Flow Rate (Steam)CondenserTemperature (two point)Temperature (single point)TemperatureRegenerative Thermal OxidizerTemperature (single point) and Weekly InspectionsTemperature (two point) and Weekly InspectionsTemperature and WeeklyInspectionsAir-to-fuel DataThermal OxidizerTemperature (two point)Temperature (single point)TemperatureAir-to-fuel DataCatalytic Oxidizer Temperature (single point) and Monthly InspectionsTemperature and MonthlyInspectionsFloating-Roof Tank Inspections and Testing Not ApplicableRepair Equipment Leaks Leak Detection and Repair Not ApplicableFlareFlame Detector with Equipment InspectionsFlame Indicator Detectorwith Equipment InspectionsAir-to-fuel dataUse Low/No HAP Material Product Analysis (Coatings and Solvents)Product Analysis (Coatingsand Solvents)A-12HCl HClDry FGD/Lime-injected FabricFilter/ESPLime Flow Rate (Liquid) and Visible Emissions NoneLime-injected Fabric FilterLime Flow Rate (Liquid)Visible Emissions (M9) and Equipment InspectionsVisible Emissions (DOCS) and Equipment InspectionsBLD (1, 2, 3, or 4 sensors)Wet ScrubberLiquid Flow Rate and pHPeriodic TestingLiquid Flow Rate and pHLiquid Flow RateHg HgCarbon Injection Carbon Injection Rate Carbon Injection RateSCR/Wet Scrubber Periodic Testing Liquid Flow RateWet ScrubberLiquid Flow Rate and pHPeriodic TestingLiquid Flow RateLiquid Flow Rate and pHNOXNOXProcess Equipment and Operation forNOX(EGR)NOXAnalyzer (Quarterly RAAs and Annual RATA)NOXAnalyzer (Monthly RAAs and Annual RATA)NOXAnalyzer (Annual RATA only)NOXAnalyzer (Quarterly RATA)TemperatureProcess Equipment and Operation forNOX(LNB/OFA)NOXAnalyzer (Quarterly RAAs and Annual RATA)NOXAnalyzer (Monthly RAAs and Annual RATA)NOXAnalyzer (Annual RATA only)NOXAnalyzer (Quarterly RATA)TemperatureWater Injection for Gas TemperatureReductionLiquid Flow Rate Liquid Flow RateNSCRNH3Injection RateNOXAnalyzer (Annual RATA only)NOXAnalyzer (Monthly RAAs and Annual RATA)NOXAnalyzer (Quarterly RAAs and Annual RATA)NOXAnalyzer (Quarterly RATA)Pressure DropTemperature (Single Point)Temperature (Inlet)NH3Injection RateO2/CO2(Excess Air)MonitorTemperature (inlet) andMonthly InspectionsSCRNH3Injection RateTemperature (Inlet)NH3Injection RateTemperature (inlet) andMonthly InspectionsA-13NOXNOXSNCRNH3Injection RateTemperature (Inlet)NH3Injection RateTemperature (inlet) andMonthly InspectionsPM(fine)condensablePM (in situ)PM (betagauge)PM(extractive)Dry ESP followed by Fabric FilterTemperature, Voltage/Current/Power, Visible Emissions,and Equipment InspectionsTemperature andVoltage/Current/PowerBLD (1 sensor)Wet ESPVoltage/Current/Power and Liquid Flow RateVoltage/Current/Power andLiquid Flow RateAmbient Temperature Fabric FilterVisible Emissions (M9) and Equipment InspectionsVisible Emissions (DOCS) and Equipment InspectionsBLD (1, 2, 3, or 4 sensors)Venturi Scrubber for PM Control Pressure Drop and Liquid Flow RatePressure Drop and LiquidFlow RatePM/PM(Fine)FilterablePM (in situ)PM (betagauge)PM(extractive)Dust SuppressionVisible Emissions (M9)Soil or Coal MoistureVisible Emissions (DOCS)OpacityElectrified Filter Bed Voltage/Current/Power Voltage/Current/PowerVenturi Scrubber for PM Control Pressure Drop and Liquid Flow RatePressure Drop and LiquidFlow RateDry ESPVisible Emissions (DOCS) and Voltage/Current/PowerVisible Emissions (DOCS) and Voltage/Current/PowerOpacity andVoltage/Current/PowerWet ESP Voltage/Current/Power and Liquid Flow RateVoltage/Current/Power andLiquid Flow RateFabric FilterVisible Emissions (M9) and Equipment InspectionsVisible Emissions (DOCS) and Equipment InspectionsBLD (1, 2, 3, or 4 sensors)SO2SO2Low Sulfur Fuel/Feed Fuel Analysis and Records Not ApplicableDry FGD with Fabric Filter/ESPVisible Emissions (M9) and Equipment InspectionsVisible Emissions (DOCS) and Equipment InspectionsVisible Emissions (DOCS) and Voltage/Current/PowerBLD (1, 2, 3, or 4 sensors)Opacity andVoltage/Current/PowerTemperature andVoltage/Current/PowerWet Scrubber-FGD/Acid GasLiquid Flow Rate and pHLiquid Flow RateLiquid Flow Rate and pHLiquid Flow RateA-14VOC/THCVOC (outletonly)VOC (inletand outlet)Capture DevicesExplosive MeterPortable VOC AnalyzerPressure DropGas Flow RateFace VelocityVOC AnalyzerPressure DropGas Flow RateFace Velocity/Flow RateCarbon AdsorberPortable Flame Ionization Detector with EquipmentInspectionsFlow Rate (Steam)Pressure Drop (Vacuum)Gas Flow Rate (Steam)Pressure Drop (Vacuum)CondenserTemperature (two point)Temperature (single point)TemperatureRegenerative Thermal OxidizerTemperature (single point) and Weekly InspectionsTemperature (two point) and Weekly InspectionsTemperature and WeeklyInspectionsAir-to-fuel DataThermal OxidizerTemperature (two point)Temperature (single point)TemperatureAir-to-fuel DataCatalytic OxidizerTemperature (single point) and Monthly InspectionsTemperature and MonthlyInspectionsFloating-Roof TankInspections and Testing Not ApplicableRepair Equipment LeaksLeak Detection and Repair Not ApplicableFlareFlame Detector with Equipment InspectionFlame Indicator Detectorwith Equipment InspectionsAir-to-fuel DataUse Low/No HAP Material Product Analysis (Coatings and Solvents)Product Analysis (Coatingsand Solvents)B-1 

## Appendix B. Case Studies Using the MCAT

We developed two case studies to demonstr ate how the tool can be used: Portland cement kilns and glass manufacturers. The case st udies provide an introduction to monitoring in the particular industry, the methodology for calcu lating monitoring costs (including obtaining information and assumptions), and the results. The principal benefit of improved monitoring is associated with re ducing 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 plants 5 , is that by implementing a monitoring program that requires continuous surveilla nce of conditions that affect and are necessary to maintain emissions control, owners and operators of faci lities will achieve a highe r 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 define d 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 exampl e of a cost analysis of implementing continuous emissions monitoring as part of a prop osed area source rule for cement kilns. The regulation would impose PM, SO 2 , and NO X emission limits on kilns, and PM limits on clinker
coolers. For the purposes of this case study, we eval uated the costs of implementing continuous emissions monitoring on particulat e matter (PM), sulf ur dioxide (SO 2 ), and nitrogen oxides (NO X ) 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 th e EPA’s National Emissions Inventory. Table B-1 summarizes these emissions and other parame ters of the case study. We assumed that PM 2.5 comprised 45 percent of total PM emissions and that an 83 percent reduction in total PM emissions (75 percent reduction in PM 2.5 emissions) would be achie ved by installing either pulse-jet or reverse-air fabric filters on affected emission uni ts. Likewise, we assumed a 95 percent reduction in SO 2 would be achieved by installing a wet scrubber, and a 40 percent
reduction in NO X would be achieved by installing sele ctive 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. Kilns a 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
PM 2.5 20 Pulse-Jet FF 135 112 23 Bag Leak Detector 20 Reverse Air FF 135 112 23 Bag Leak Detector
NO X 20 SNCR 1500 600 900 NO X CEMS
SO 2 4 Wet Scrubber 7800 7410 390 SO 2 CEMS Clinker Cooler PM 20 Pulse-Jet FF 300 249 52 Bag Leak Detector 20 Reverse Air FF 300 249 52 Bag Leak Detector
PM 2.5 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 ev aluate costs for a model plant to install and operate continuous emissions monitoring technology on cement kiln and clinke r cooler controls. We obtained costs for continuous emissions monitoring of PM, SO 2 , and NO X 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 SO 2 and NO X air
concentrations to lb/ton of c linker 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 paramete rs 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 PM 2.5 monitoring, $200,000 for SO 2 monitoring, and $990,000 for NO X monitoring. Note that while co sts 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 Cost s 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

PM 2.5 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
NO X SNCR NO X CEMS 20 $2,969,912 $989,873

SO 2 Wet Scrubber SO 2 CEMS 4 $602,634 $200,031

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

th Edition.B-4Table B-3. Continuous EmissionMonitoring Costs (1 facility)Parameter Description NOXBLD w/ 5 sensors forthe kiln baghouse and5 for the clinkercooler SO2NotesPlanning Engineering and managerial labor for reviewing the regulations,resolving questions, reviewing engineering drawings, andinspecting the source $2,936.02 $2,139.19 $2,936.02Equipment Selection andPurchaseCost of equipment and labor associated with its purchase$96,156.37 $77,197.76 $98,319.37 a, bInstall and Calibrate Travel costs, fees, and labor to install and calibrate equipment$18,076.14 $15,101.72 $18,076.14Performance Test Audits Performance test ofthe monitor conducted once every five years.$10,104.60 $0.00 $10,104.60QA/QC Plan Labor associated with developing a QA/QC Plan$22,332.45 $795.64 $22,332.45Total Capital CEMS $148,495.58 $95,234.31 $150,658.58Operation and Maintenance Labor costs associated with daily activities$9,132.75 $4,148.93 $9,132.75RATA Relative Accuracy TestAudit conducted annually$8,143.80 $0.00 $8,143.80Cylinder Gas Audits EPA testing procedureto ensure the accuracy of CEMS data.Known concentrations of specified gases are passed through theCEMS unit and measurements over a period of time are takenand averaged.$2,718.55 $0.00 $2,718.55Recordkeeping and reporting Annual costs of recordkeeping and reporting$4,441.05 $1,378.84 $4,441.05Annual QA Reviews andUpdateLabor associated with annual quality assurance reviews$3,911.74 $17,769.71 $4,117.74Capital Recovery Equipment and calibration costs calculated at a set interest rateover five years. Factor is .09 for Continuous Monitoring and .24for Periodic Monitoring $21,145.77 $13,561.37 $21,453.78CEMS Total Annual $49,493.66 $36,858.85 $50,007.68[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 $5,700 per sensor plus $750installation cost per sensor. Weassumed that only one BLD apparatus (includingthe data logger and control box) would be needed for both the clinker cooler and kiln baghouse at$11,500.[b] Flow meter costs total $1,110 ($1,024 forthe 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 anal ysis of implementing improved monitoring as part of a proposed area source NESHAP for gl ass manufacturing plants. The rule applies to those plants producing at least 50 tons of gla ss 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 pa rticulate matter (PM) controls, although the rule will only apply to HAP. The followi ng 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 Na tional Emissions Inventory. National baseline uncontrolled PM emissions reported for the aff ected category are 3,965 tons/year. We assumed
that PM 2.5 comprised 91 percent of total PM emissi ons. 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
PM 2.5 emissions) would be achieved by installing either a dry electr ostatic precipita tor (ESP) or a baghouse on affected emission units. 8



### B.2.3. Cost Analysis
We used the cost function of the tool to ev aluate 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, opaci ty, and bag leak detection from the CEMS Revised Cost Model (2007). We obtained capita l and installation costs for most periodic monitoring options from the Control Cost Manu al or personal communications with EPA personnel. 9,10 We used an Environmental Security Technology Certification Program report 11 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 em ission 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 co sts 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 un its, or whether other cont rols already exist. Table B-4 presents the monitori ng options available in the to ol 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 parame ters and costs calcul ated 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.htmB-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 cont inuous 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 Moni toring 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 $202,338B-8Table B-6. Costs for Particulate Matter Monitoring Using Dry ESP for One GlassManufacturing FacilityParameter Description CEMSCPMS Periodic MonitoringInitial CostsPM(extractive)PM(in situ)Voltage/Current/PowerVoltage/Current/Power andWeeklyInspectionsVE (DOCS)andVoltage/Current/PowerVE (Method 9)andVoltage/Current/PowerPlanningEngineering and manageriallabor for reviewing theregulations, resolving questions,reviewing engineeringdrawings, and inspecting thesource $850 $850 $3,022.27 $3,022.27 $3,022.27 $3,022.27EquipmentSelection andPurchaseCost of equipment and laborassociated with its purchase $75,830 $45,667 $5,470.00 $5,470.00 $5,000.00 $3,182.64Install andCalibrateTravel costs, fees, and labor toinstall and calibrate equipment $18,467 $15,790 $960.00 $960.00 $159.15 $159.15Training andCertificationTravel costs and labor requiredfor training and certification,plus test fees - - - - $3,140.00 $4,100.00QA/QC PlanLabor associated withdeveloping a QA/QC Plan $19,454 $19,454 - - - -Performance TestAuditsPerformance test of the monitorconducted once every fiveyears. $33,936 $33,936 $159.15 $159.15 - -Total $148,537 $115,697 $9,611.42 $9,611.42 $11,162.27 $19,586.27Annualized CostsOperation andMaintenanceLabor costs associated withdaily activities $2,524 $1,524 $270.00 $270.00 $1,759.00 $10,959.00RATARelative Accuracy Test Auditconducted annually - - - - - -Emission TestAnnualized cost of a stack testconducted once every five years - - $1,956.00 $1,956.00 $1,956.00 $1,956.00Recordkeepingand reportingAnnual costs of recordkeepingand reporting $7,925 $7,925 $3,578.00 $3,578.00 $4,778.00 $4,778.00B-9Annual QAReviews andUpdateLabor associated with annualquality assurance reviews $4,055 $3,055 - - - -Capital RecoveryEquipment and calibration costscalculated at a set interest rateover five years. Factor is .09for Continuous Monitoring and.24 for Periodic Monitoring $21,152 $16,475 $1,040.52 $1,040.52 $1,985.00 $1,064.39PM Monitor RCAResponse Correlation Auditrequired by Part 60 $6,057 $6,057 - - - -PM Monitor RRARelative Response Auditrequired by Part 60 $10,689 $10,689 - - - -Cylinder GasAuditsEPA testing procedure to ensurethe accuracy of CEMS data.Known concentrations ofspecified gases are passedthrough the CEMS unit andmeasurements over a period oftime are taken and averaged. $1,346 $1,346 - - - -PeriodicInspectionsAnnualized cost of weeklyinspections - - - $1,034.49 - -Property Taxes,Insurance, Admin.Calculated as 4% of capitalcosts (Parametric MonitoringOnly). - - $384.46 $384.46 $206.37 $133.67Total $53,748 $47,071 $7,228.98 $8,263.47 $10,684.37 $18,891.06B-10Table B-7. Costs for Particulate Matter Monitoring Using Fabric Filter for One Glass Manufacturing FacilityParameter Description CEMSCPMS Periodic MonitoringInitial CostsPM(extractive)PM(in situ)Bag LeakDetector(1 Sensor) OpacityVisible Emissions(DOCS) andEquipmentInspectionsVisible Emissions(Method 9) andEquipmentInspectionsPlanningEngineering and managerial labor forreviewing the regulations, resolvingquestions, reviewing engineeringdrawings, and inspecting the source $850 $850 $622 $850 $3,022 $3,022Equipment Selectionand PurchaseCost of equipment and labor associatedwith its purchase $75,830 $45,667 $17,524 $33,502 $6,183 $3,183Install and CalibrateTravel costs, fees, and labor to installand calibrate equipment $18,467 $15,790 $3,450 $3,574 $159 -Training andCertificationTravel costs and labor required fortraining and certification, plus test fees - - - - $3,140 $4,100QA/QC PlanLabor associated with developing aQA/QC Plan $19,454 $19,454 $647 $14,731 - -Performance TestAuditsPerformance test of the monitorconducted once every five years. $33,936 $33,936 $1,574 - -Total $148,537 $115,697 $22,243 $54,231 $12,504 $10,305Annual CostsOperation andMaintenanceLabor costs associated with dailyactivities $2,524 $1,524 $2,470 $8,040 $1,355 $10,825RATARelative Accuracy Test Auditconducted annually - - $12,886 - - -Emission TestAnnualized cost of a stack testconducted once every five years - - - - $1,956 $1,956Recordkeeping andreportingAnnual costs of recordkeeping andreporting required by Part 63 $7,925 $7,925 $147 $7,925 $1,200 -B-11Annual QA Reviewsand UpdateLabor associated with annual qualityassurance reviews $4,055 $3,055 $2,106 $3,305 - -Capital RecoveryEquipment and calibration costscalculated at a set interest rate over fiveyears. Factor is .09 for ContinuousMonitoring and .24 for PeriodicMonitoring $21,152 $16,475 $3,167 $7,723 $1,985.00 -PM Monitor RCAResponse Correlation Audit required byPart 60 $6,057 $6,057 - - - -PM Monitor RRARelative Response Audit required byPart 60 $10,689 $10,689 - - - -Cylinder Gas AuditsEPA testing procedure to ensure theaccuracy of CEMS data. Knownconcentrations of specified gases arepassed through the CEMS unit andmeasurements over a period of time aretaken and averaged. $1,346 $1,346 - - - -Periodic Inspections Annualized cost of weekly inspections - - - - $1,034 $1,034Property Taxes,Insurance, Admin.Calculated as 4% of capital costs(Parametric Monitoring Only). - - $890 $1,225 $247.32 $192Total $53,748 $47,071 $21,666 $28,218 $7,777 $14,007