MEMORANDUM


DATE:	February 12, 2019

SUBJECT:	Costs/Impacts 40 CFR Part 63 Subparts KKKK and SSSS Monitoring Review Revisions 

FROM:	Paula Hirtz, OAQPS/SPPD/MMG

TO:		Metal Can and Metal Coil Dockets

As part of an ongoing effort to improve compliance with various federal air emission regulations, the EPA reviewed the testing and monitoring requirements of the National Emission Standards for Hazardous Air Pollutants (NESHAP) for the Surface Coating of Metal Can (40 CFR part 63, subpart KKKK) and the Surface Coating of Metal Coil (subpart SSSS) and identified a testing deficiency in both subparts. For facilities that comply with the standards by using emission capture systems and add-on controls, each subpart currently requires an initial performance test during which control device efficiency is measured and the operating limits for the emission capture system and add-on control device are established. Additional periodic performance tests are not required by either subpart, however, they are required by some state and local permitting authorities as part of the 40 CFR part 70 operating permits renewal process. 
The EPA is proposing a requirement for facilities that comply with the standards by using emission capture systems and add-on controls to conduct periodic air emissions performance testing, with the first of the periodic performance tests to be conducted within 3 years of the effective date of the revised standards and thereafter no longer than 5 years following the previous performance test. The 5-year period would correspond to the renewal period for the facility's 40 CFR part 70 operating permits. 
The addition of periodic performance testing to these federal regulations will require all facilities to conduct periodic testing to ensure that emission control systems are checked and properly maintained over time. Periodic testing of control devices ensures the emission control technology remains effective, over and above the parametric monitoring that is currently required by the NESHAP, thereby reducing the potential for acute emissions episodes and non-compliance. 
This proposal would require periodic air emissions testing to measure organic HAP destruction or removal efficiency at the inlet and outlet of the add-on control device, or control device outlet concentration of organic HAP, once every 5 years for existing and new surface coating affected sources using the emission rate with add-on controls compliance option. Emissions would be measured as total gaseous organic mass emissions as carbon using either Method 25 or 25A of appendix A to 40 CFR part 60. 
Note that these subparts specify some emissions limits in terms of organic HAP concentrations or organic HAP destruction efficiencies measured using EPA test methods 25 or 25A. These test methods measure unspeciated total organic compounds. However, most surface coating operations emit volatile organic compounds that are not HAP as well as HAP. We are also aware of situations where the measured gas stream from a coating operation may contain measurable amounts of methane, which is also not a HAP, from natural gas combustion. Using Method 25 or 25A alone in that situation could result in a facility demonstrating non-compliance due to the non-HAP organic compound or methane emissions, although we expect this to be unlikely based on available compliance data from facilities using add-on controls. (These compliance data show facilities using add-on controls with a sufficient margin between the emission limit and their actual emission rates that they should be able to rely on just VOC destruction to demonstrate compliance.) To avoid this potential problem, several NESHAP that cover coating operations contain a provision to use EPA Test Method 18 to measure organic HAP emissions (40 CFR Part 63 subparts EE (Magnetic Tape Manufacturing), GG (Aerospace), JJ (Wood Furniture Manufacturing),  and VVVV (Boat Manufacturing)), or to simultaneously measure methane emissions along with the total organic compound emissions, and allow the methane emissions to be subtracted from the total organic compound emissions measured using Methods 25 or 25A (40 CFR Part 63 subpart KKKK (Metal Can Coating)). We are proposing to add the option of conducting EPA Method 18 of appendix A to 40 CFR part 60 to Subpart SSSS to either specifically measure organic HAP emissions, or to subtract methane emissions from measured total gaseous organic mass emissions as carbon. We think the decision to use the method will be made on a site-specific basis, and based on our knowledge of the industries affected by the two subparts, that the decision to use Method 18 will rarely be necessary. Because it is being proposed as an optional method, we did not include the costs associated with the method in this analysis. Facilities performing testing using EPA Methods 25 or 25A are required to use EPA Methods 1, 2, 3, and 4 to measure gas flow rate, molecular weight, and moisture content. These methods are included in this analysis.
The estimated costs associated with a periodic testing requirement in this analysis for subparts KKKK and SSSS are incremental costs (i.e., the additional cost associated with complying with an additional requirement beyond that required under the current subpart MACT). 
We identified the facilities for which periodic testing would be a new requirement by reviewing the most current operating permits for the known major source facilities in each source category and identifying those with add-on controls and using the emission rate with add-on controls compliance option in each subpart. We also used the permits to identify how many add-on controls were used by each facility. Some facilities had multiple add-on controls, e.g., one for each coating line.
Emissions compliance testing costs were treated as capital costs because facilities routinely contract with a company specializing in emissions testing to perform the tests. Consistent with the EPA Air Pollution Control Cost Manual, the capital costs were annualized at 5.25 percent over the 5-year testing period. Appendix A presents estimated emissions testing costs as facility-specific and nationwide equivalent annualized costs (EAC) for each of the NESHAP. The basis for the testing costs is presented in Appendix B. The one-time estimated cost per add-on control range from approximately $18,500 to $18,750 for Method 25 and 25A, and assumes that emissions are measured simultaneously at the inlet and outlet of the control device to measure destruction efficiency. The one-time estimated costs to conduct Method 18 (manual or direct) are also included. (We assumed that facilities would not use EPA Method 18 of appendix A to 40 CFR part 60 and not subtract methane emissions from measured total gaseous organic mass emissions as carbon. EPA Method 18 is currently listed in subpart KKKK and is being added to subpart SSSS in this proposed action.) These costs were annualized with an interest rate of 5.25 percent resulting in an equivalent annualized cost of about $4,300 per add-on control per facility. These costs also assume that the associated emission capture systems meet the design criteria for a permanent total enclosure in EPA Method 204, so that capture efficiency does not need to be measured.
We applied a 25-percent discount to the cost of testing each additional device at a facility to account for the fact that the testing contractor was already on site and would have no additional travel costs and would have some reduced set up and take down costs. That is, testing the second, third or fourth device at a facility would be $14,060 instead of $18,750, and an equivalent annualized cost of about $3,200 instead of $4,300.
These testing cost estimates were based on conditions in the facility operating permits requiring periodic testing on a specified frequency (annually, every four years, every five years). We did not account for "as-needed" periodic emissions testing required by the permitting authority to measure control device efficiency as part of renewing their operating permits. If a facility had more than one control device (e.g., for two separate coating lines) we assumed that each device would be tested independently.
The total estimated equivalent annualized cost of periodic testing for the Surface Coating of Metal Cans industry (subpart KKKK) is about $11,000. Three metal can surface coating facilities have two or more control devices per facility. One of the three facilities is not using the controls to comply with the NESHAP and the two other facilities are already required to perform testing as a condition of their 40 CFR part 70 operating permits. Therefore, only one of the five facilities is affected by this requirement since it is not currently required to perform testing as part of renewing its 40 CFR part 70 operating permit according to state regulations. Based on recent information, the facility changed ownership and is currently operating three of the four control devices at the facility.
The total estimated equivalent annualized cost of periodic testing for the Surface Coating of Metal Coil industry (subpart SSSS) is about $130,000. There are 48 facilities subject to 40 CFR 63 Subpart SSSS. A review of 46 permits revealed that 5 facilities do not use add-on control devices, 20 facilities use add-on controls and are already required to conduct periodic performance testing for VOC/HAP destruction efficiency, and 21 facilities use add-on controls but are not required to conduct periodic performance testing. These 21 facilities have 30 add-on control devices that will require periodic testing as a result of this proposed amendment. Since it is assumed that 5% of performance tests will need to be repeated, calculations for capital costs for testing include the costs of 30 performance tests plus 2 re-tests in year 3. Nine of the 21 facilities have two add-on control devices, and EPA assumes that both devices will be tested during one visit by the testing company. For the coil coating source category, we also assumed a 5 percent testing failure rate, which would mean two additional tests that would have to be conducted at a later date at a cost of $18,750 per test, for a total of $37,500 and an equivalent annualized cost of $8,600.


Appendix A: Equivalent Annualized Costs (EAC) with Interest Rates by Facility and Industry Sector
                            Facility (City, State)
                                       
                             Process/ Description
                                    Control
                         Do we have operating permit?
                  Is periodic testing required by the permit?
                            Estimated testing costs
                       EAC with 5.25% Interest (5 year)
                           Metal Can Surface Coating
Rocky Mountain Metal Container (Miller-Coors), Golden CO
Can coating includes can lines C04, C05, C24, CX3.

2 Regenerative Thermal Oxidizer, but not using add-on controls to comply.
                                      Yes
                                       _
                                       _
                                       _
BWAY Packaging, Homerville, GA
Can coating includes lithographic printing and coating lines which are subject to both KKKK and MMMM; no controls on the can line subject to only KKKK.

1 Regenerative Thermal Oxidizer
                                      Yes
                                      Yes
                                       _
                                       _
BWAY Corp, Chicago, IL
Can coating lithography lines.
1 Thermal Oxidizer and 1 Catalytic Oxidizer
                                      Yes
                                      Yes
                                       _
                                       _

Ball Metal Beverage Container Corporation, Findlay, OH

Can coating lines 1 and 2 (2-Piece aluminum beverage cans) and can line 3 (2-piece steel food cans).
                                       
                                       _
                                      Yes
                                       _
                                       _
                                       _
Ball Metal Food Container Corp, Weirton, WV
(Facility closed in 2017 and a portion was sold and reopened as Maple Manufacturing.)
Sheet Coaters C-1, C-2, C-3, C-4; LTG-1, Sheet coaters C-5, C-6, C-7, C-8, C-9, and C-10; Sheet coating Lines PC-3, PC-4, PC-5, PC-6, and PC-7.


4 Thermal Oxidizers, but only 3 are currently needed.

                                      Yes
                                      No
                                    $46,900
                      ($18,750 for one thermal oxidizer.
                                    $10,830
                      ($4,360 for one thermal oxidizer.)
                          Metal Coil Surface Coating
Agfa Corporation (NJ) 
Coil coating units U6 OS1, U6 OS3, U6 OS5, U6 OS6. 
2 Thermal Oxidizers 
                                      Yes
                                      No
                                    $32,800
                                    $7,630
AK Steel - Zanesville Works (OH) 
Coil Coating Lines #7 and #15.
_
                                      Yes
                                      No
                                       _
                                       _
ALCOA INC Riverdale (IA)
Electrostatic Lube  -  Treatment Line (EU ELUBE01) and 14
Slitter (EU ELUBE02).
                                       _
                                      Yes
                                      No
                                       _
                                       _
ALCOA INC. - WARRICK OPERATIONS (IN)
Electrocoat coil coating line CPL6; coil coating line CCL2; and coil coating line CCL3. 
2 Thermal Oxidizers
                                      Yes
                                      Yes
                                       _
                                       _
Aleris Rolled Products, Inc. (KY)
Area 6 Coil Coating/Finishing (IDs 68, 83, 84, 98, and 104). 
1 Thermal Oxidizer
                                      Yes
                                      Yes
                                       _
                                       _
Aleris Rolled Products, Inc. (OH) 
Wide line primer coating line and wide line finish coating line.
2 Thermal Oxidizers
                                      Yes
                                      No
                                    $32,800
                                    $7,630
ALUMAX MILL PROD INC/MILL PROD (PA)
Sixty-inch coil coating/annealing line.
2 Thermal Oxidizers
                                      Yes
                                      No
                                    $32,800
                                    $7,630
BRIGHTSMITH LLC (PA)
Coil coating operations include prime and finishing lines.
2 Thermal Oxidizers
                                      Yes
                                      Yes
                                       _
                                       _
Centria (OH) 
McKay Coil Coating Paint Line, 60" width.
1 Thermal Oxidizer
                                      Yes
                                      No
                                    $18,750
                                    $4,360
CONSOLIDATED SYSTEMS, INC (now Precoat Metals) (SC)
Coil coating application with primer coater and a finish coater.
1 Regenerative Thermal Oxidizer
                                      Yes
                                      Yes
                                       _
                                       _
CONSTELLIUM (Wise Alloys LLC ) (AL) 
High speed cleaning and coating lines. 
2 Thermal Oxidizers
                                      Yes
                                      No
                                    $32,800
                                    $7,630
Crown Cork & Seal (OH) 
Two 36 in coil coating lines K004 and K005. 
2 Catalytic Incinerators
                                      Yes
                                      Yes
                                       _
                                       _
EDCO Products Inc (MN)
Two coil coating lines. 
1 Thermal Oxidizer 
                                      Yes
                                      No
                                    $18,750
                                    $4,360
EDCOAT LIMITED PARTNERSHIP (IN)
Upper and Lower Coil Coating lines. 
1 Thermal Oxidizer
                                      Yes
                                      Yes
                                       _
                                       _
FUJI FILM INC P PLANT (SC)
Coil coating and drying operations in series P-Plant Emission units 02 and K-Plant Emission unit 09.
2 Regenerative Thermal Oxidizers
                                      Yes
                                      Yes
                                       _
                                       _
JUPITER ALUMINUM CORPORATION JUPITER (IN)
Aluminum coil coating lines #1 and #2.
1 Direct Flame Incinerator and 1 Regenerative Thermal Oxidizer 
                                      Yes
                                      Yes
                                       _
                                       _
Logan Aluminum Inc (KY)
Aluminum Coil Coating Line 1. 
1 Regenerative Thermal Oxidizer
                                      Yes
                                      Yes
                                       _
                                       _
Material Sciences Corp (IL)
Coil coating emission units include Coating Line #2 and Coating Line #4, and Line #4 Mezzanine. 
5 Thermal Oxidizers 
                                      Yes
                                      Yes
                                       _
                                       _
Metal Coaters (MS)
Coil Coating Operation.
1 Thermal Oxidizer
                                      Yes
                                      No
                                    $18,750
                                    $4,360
Metal Coaters (OH)
Coil Coating Line with four coating stations.
2 Thermal Oxidizers and a rotor VOC concentrator with a catalytic oxidizer
                                      Yes
                                 Yes, partial
                                    $32,800
                                    $7,630
MSC Walbridge Coatings Inc (OH) 
Coil coating with prime paint roll coating application and finish paint roll coating application.
2 Thermal Oxidizers
                                      Yes
                                      No
                                    $32,800
                                    $7,630
NCI GROUP INC., DBA, METAL COATERS OF CA (CA)
_
_
                                      No
                                       _
                                       _
                                       _
NICHOLS ALUMINUM - DAVENPORT - ROCKINGHAM RD (IA)
Coil coating with Prime and Finish Roll Coaters.
1 Regenerative Thermal Oxidizer
                                      Yes
                                      No
                                    $18,750
                                    $4,360
Novelis Corporation (OH) 
Aluminum/metal coil coating K002 Prime & Finish Coating Operation. 
1 Thermal Oxidizer
                                      Yes
                                      No
                                    $18,750
                                    $4,360
Ply Gem (OH) 
Coil coating consists of K001, 39" Line and K002, 54" Line.
1 Thermal oxidizer
                                      Yes
                                      No
                                    $18,750
                                    $4,360
Precoat Metals (AR)
Coil coating with Prime and Finish lines.
2 Thermal Oxidizers

                                      Yes
                                      Yes
                                       _
                                       _
Precoat Metals (IL)
Coil coating Line 3 consisting of a Prime Coating Section and Finish Coating Section.
2 Thermal Oxidizers
                                      Yes
                                      Yes
                                       _
                                       _
Precoat Metals (Hawkesville, KY) 
Metal coil manufacturing and coating operation includes prime coating and finish coat roll coating processes. 
1 Thermal Oxidizer
                                      Yes
                                      Yes
                                       _
                                       _
Precoat Metals (MS)
Coil coating lines with Prime and Finish Coaters (AD-000) and Prime and Finish Curing Ovens (AC-000).
1 Thermal Oxidizer
                                      Yes
                                      No
                                    $18,750
                                    $4,360
Precoat Metals (WV)
Metal coil coating line with prime and finish coating sections.
1 Thermal Oxidizer 
                                      Yes
                                      Yes
                                       _
                                       _
Precoat Metals a Division of Sequa Corp (Portage, IN)
Coil coating with prime coating section and finish coat section.
1 Regenerative Thermal Oxidizer and 1 Recuperative Thermal Oxidizer  
                                      Yes
                                      Yes
                                       
                                       _
                                       _
Precoat Metals Corp. (La Port, IN) 
Coil coating Line 5.
1 Thermal Oxidizer 
                                      Yes
                                      Yes
                                       _
                                       _
PRECOAT METALS DIVISION OF SEQUA CORP (AL) 
Metal coil surface coating operation consisting of a prime roll coater and a finish roll coater. 
1 Thermal Oxidizer
and 1 Afterburner 
                                      Yes
                                      No
                                    $32,800
                                    $7,630
PRECOAT METALS DIVISION SEQUA COATINGS (Greenfield, IN)

Metal coil coating Lines 1 and 2.
2 Thermal Oxidizers 
                                      Yes
                                      Yes
                                       _
                                       _
PRECOAT METALS HOUSTON (TX)
PROCCL5  -  Coil coating process includes prime and finish coating sections.  
1 Thermal oxidizer
                                      Yes
                                      No
                                    $18,750
                                    $4,360
PRECOAT METALS (MO)
Two continuous metal coil surface coating lines. Coil Line 1 and Coil Line 2.
2 Thermal Oxidizers 


                                      Yes
                                      No
                                    $32,800
                                    $7,630
Signode Corp (IL)
Magnus 4 strapping line (i.e., paint dip tank (M4-3), electric paint drying oven (M4-4), wax applicator/electric dryer (M4-5)).
1 Thermal Oxidizer
                                      Yes
                                      No
                                    $18,750
                                    $4,360
SOUTHWIRE COMPANY COPPER ROD MILL (GA)

UV light cured ink application systems.
                                       _
                                      Yes
                                      No
                                       _
                                       _
SPRINGS WINDOW FASHIONS, MONTGOMERY PLT (PA)
                                       _
                                       _
                                      No
                                       _
                                       _
                                       _
USG Interiors, Inc., American Metals Corp., Westlake (OH) 
Coil coating lines K001, K002, K003 and K005.

1 Thermal Oxidizer
                                      Yes
                                      No
                                    $18,750
                                    $4,360
USS MON VALLEY WORKS - IRVIN PLANT (PA)
Continuous galvanizing and aluminum coating line no. 2.
                                       _
                                      Yes
                                      No
                                       _
                                       _
VULCRAFT OF NEW YORK INC (NY) 
Coating Lines P-00001 and P-00002 using waterborne coatings.
                                       _
                                      Yes
                                      No
                                       _
                                       _
Wheeling Corrugating Company (now Jupiter Aluminum Corp and BDC) (WV) 
Coating Line #1 and Coating Line #2 
2 Regenerative Thermal Oxidizers
                                      Yes
                                      No
                                    $32,800
                                    $7,630
Vorteq (formerly Wismarq Corporation) (IL)
Coil coating line with prime and finish application and ovens.
1 Thermal Oxidizer
                                      Yes
                                      Yes
                                       _
                                       _
Wismarq Corporation (WI)
Two (2) metal coil surface coating lines. Line #1 has two coating stations and Line # 2 has one coating station. 
1 Thermal Oxidizer
                                      Yes
                                      Yes
                                       _
                                       _
WOLVERINE ADVANCED MATERIALS  -  BLACKSBURG (VA) 
Coil Coating consists of two metal coil coating lines (CL2 and CL4). 
1 Regenerative Thermal Oxidizer
                                      Yes
                                      No
                                    $18,750
                                    $4,360
WOLVERINE ADVANCED MATERIALS - CEDAR RUN (VA)
Two metal coil coating lines to coat metal with organic coatings rubber coatings, graphite coatings, and/or adhesives.
2 Catalytic Oxidizers and 1 Thermal Incinerator
                                      Yes
                                    partial
                                    $18,750
                                    $4,360
WOLVERINE ADVANCED MATERIALS LLC (FL)
Coil Coating operation for rubber coated sealing materials used in the automotive industry.
1 Regenerative Thermal Oxidizer
                                      Yes
                                      Yes
                                       _
                                       _
                 Testing Costs for All Coil Coating Facilities
                                   $520,200
                                   $121,000
Cost For Two Repeat Tests as a Result of Not Passing Test (Assuming a 5% Failure Rate)
                                    $37,500
                                    $8,700
Total Testing Costs Including Repeat Tests (Rounded to Two Significant Figures)
                                   $560,000
                                   $130,000

        Appendix B: Detailed Information for Testing Methodology Costs
                 Testing to Determine Destruction Efficiency 
                Required Tests: EPA Methods 1, 2, 3, 4, and 25 
(EPA Method 25 is Total Gaseous Non-Methane Organics reported as Carbon (TGNMOC) manual sample collection and analysis)
Control device inlet and outlet testing conducted simultaneously, three complete test sets at one hour each.
                                    Element
                                     Cost
                                  Assumptions
Labor  -  Preparation and Staging
   P4 = 8 hours 
   P2 = 16 hours
   P1 = 4 hours
                                    $2,168
Test plan/QAPP preparation, equipment preparation, calibrations (pitots, thermocouples, dry gas meters, etc.), packing
Labor  -  Travel to and Set-up
   P4 = 20 hours
   P2  -  20 hours
                                    $3,860
Use of local testing company so travel is minimized. Travel by truck/company vehicle. Set-up of equipment in preparation for first test completed.
Labor  -  Testing 
   P4 = 16 hours
   P2  -  16 hours
                                    $3,088
All three test runs at inlet and outlet conducted in one day.
Labor  -  Travel from and Break-down
   P4 = 20 hours
   P2  -  20 hours
                                    $3,860
Use of local testing company so travel is minimized. Travel by truck/company vehicle. Break-down of equipment after last test run completed.
Labor  -  Recovery
   P2  -  12 hours
                                     $660
Equipment unloading, repair, and post-test calibration checks.
Labor  -  Reporting
   P4 = 6 hours
   P1 = 4 hours
                                    $1,012
Test report preparation including all field data and destruction efficiency determinations.
M25 Equipment
   6 samples ($75/sample)
                                     $450
Trap and tank including pre-cleaning, blanking, and evacuation.
M25 Sample Analysis
   6 samples ($250/sample)
                                    $1,500
TGNMOC from trap and tank
Miscellaneous Expendable Supplies
                                     $500
Fuel, Ice, Dry Ice, Fittings, Hardware, etc.
Shipping: 6 samples ($30/ sample)
                                     $180
Samples to M25 specialty lab for analysis
Lodging: 4 people, 2 nights each ($109/night)
                                     $872
Lodging at site
Meals: 4 people, 3 days each ($51/day)
                                     $612
Meals at site
                                                                          TOTAL
                                    $18,762

P4 - $138/hour, P2 - $55/hour, P1 - $46/hour
                 Testing to Determine Destruction Efficiency 
                Required Tests: EPA Method 1, 2, 3, 4, and 25A
                 (EPA Method 25A is TGNMOC direct measurement)
Control device inlet and outlet testing simultaneously, three complete test sets at one hour each.
                                    Element
                                     Cost
                                  Assumptions
Labor  -  Preparation and Staging
   P4 = 8 hours 
   P2 = 18 hours
   P1 = 4 hours
                                    $2,278
Test plan/QAPP preparation, equipment preparation, calibrations (pitots, thermocouples, dry gas meters, field VOC analyzer, etc.), packing
Labor  -  Travel to and Set-up
   P4 = 22 hours
   P2  -  22 hours
                                    $4,246
Use of local testing company so travel is minimized. Travel by truck/company vehicle. Set-up of equipment in preparation for first test completed.
Labor  -  Testing 
   P4 = 16 hours
   P2  -  16 hours
                                    $3,088
All three test runs at inlet and outlet conducted in one day.
Labor  -  Travel from and Break-down
   P4 = 20 hours
   P2  -  20 hours
                                    $3,860
Use of local testing company so travel is minimized. Travel by truck/company vehicle. Break-down of equipment after last test run completed.
Labor  -  Recovery
   P2  -  16 hours
                                     $880
Equipment unloading, repair, and post-test calibration checks.
Labor  -  Reporting
   P4 = 6 hours
   P1 = 4 hours
                                    $1,012
Test report preparation including all field data and destruction efficiency determinations.
M25A Equipment
   2 field VOC analyzers ($300/unit)
                                     $600
Rental
Miscellaneous Expendable Supplies
                                     $900
Fuel, Ice, Support gases, Calibration gas, Fittings, Hardware, etc.
Shipping
   2 parcels ($75/parcel)
                                     $150
Field VOC rental units returned
Lodging
   4 people, 2 nights each ($109/night)
                                     $872
Lodging at site
Meals
   4 people, 3 days each ($51/day)
                                     $612
Meals at site
                                                                          TOTAL
                                    $18,498

P4 - $138/hour, P2 - $55/hour, P1 - $46/hour
                                       
          Testing to Accomplish Destruction Efficiency Determinations
 Optional Test: EPA Method 18 (Methane manual sample collection and analysis)
Control device inlet and outlet testing conducted simultaneously, three complete test sets at one hour each.
                                    Element
                                     Cost
                                  Assumptions
Labor  -  Preparation and Staging
   P4 = 2 hours 
   P2 = 8 hours
   P1 = 1 hours
                                     $762
Test plan/QAPP preparation (addition), equipment preparation, calibrations, packing
Labor  -  Travel to and Set-up
   P2  -  20 hours
                                    $1,100
Use of local testing company so travel is minimized. Travel by truck/company vehicle. Set-up of equipment in preparation for first test completed.
Labor  -  Testing 
   P2  -  16 hours
                                     $880
All three test runs at inlet and outlet conducted in one day.
Labor  -  Travel from and Break-down
   P2  -  20 hours
                                    $1,100
Use of local testing company so travel is minimized. Travel by truck/company vehicle. Break-down of equipment after last test run completed.
Labor  -  Recovery
   P2  -  8 hours
                                     $440
Equipment unloading, repair, and post-test calibration checks.
Labor  -  Reporting
   P4 = 1 hours
   P1 = 1 hours
                                     $184
Methane data added to test report prepared for the required testing.
M18 Equipment
   6 samples ($50/sample)
                                     $300
Train and Tedlar bag or canister including pre-cleaning, blanking, and evacuation (as needed).
M18 Sample Analysis
   6 samples ($50/sample)
                                     $300
Methane from Tedlar bag or canister
Miscellaneous Expendable Supplies
                                     $400
Fuel, Fittings, Hardware, etc.
Shipping
   6 samples ($30/ sample)
                                     $180
Samples to M18 specialty lab for analysis
Lodging
   2 people, 2 nights each ($109/night)
                                     $436
                                       
Lodging at site
Meals
   2 people, 3 days each ($51/day)
                                     $306
                                       
Meals at site
                                                                          TOTAL
                                    $6,388

P4 - $138/hour, P2 - $55/hour, P1 - $46/hour
          Testing to Accomplish Destruction Efficiency Determinations
           Optional Test: EPA Method 18 (Methane direct measurement)
Control device inlet and outlet testing conducted simultaneously, three complete test sets at one hour each.
                                    Element
                                     Cost
                                  Assumptions
Labor  -  Preparation and Staging
   P4 = 2 hours 
   P2 = 8 hours
   P1 = 1 hours
                                     $762
Test plan/QAPP preparation (addition), equipment preparation, calibrations, packing
Labor  -  Travel to and Set-up
   P2  -  20 hours
                                    $1,100
Use of local testing company so travel is minimized. Travel by truck/company vehicle. Set-up of equipment in preparation for first test completed.
Labor  -  Testing 
   P2  -  16 hours
                                     $880
All three test runs at inlet and outlet conducted in one day.
Labor  -  Travel from and Break-down
   P2  -  20 hours
                                    $1,100
Use of local testing company so travel is minimized. Travel by truck/company vehicle. Break-down of equipment after last test run completed.
Labor  -  Recovery
   P2  -  8 hours
                                     $440
Equipment unloading, repair, and post-test calibration checks.
Labor  -  Reporting
   P4 = 1 hours
   P1 = 1 hours
                                     $184
Methane data added to test report prepared for the required testing.
M18 Equipment
   2 field Methane analyzers ($300/unit)
                                     $600
Rental
Miscellaneous Expendable Supplies
                                     $500
Fuel, Support gases, Calibration standard, Fittings, Hardware, etc.
Shipping
   2 parcels ($75/parcel)
                                     $150
Field Methane rental units returned
Lodging
   2 people, 2 nights each ($109/night)
                                     $436
                                       
Lodging at site
Meals
   2 people, 3 days each ($51/day)
                                     $306
                                       
Meals at site
                                                                          TOTAL
                                    $6,458

P4 - $138/hour, P2 - $55/hour, P1 - $46/hour
