FROM: David Randall, Carrie Richardson Fry, and Karen Schaffner, RTI International

TO: Nick Parsons, EPA/OAQPS

FOR: EPA Docket No. EPA-HQ-OAR-2010-0871

DATE: January 20, 2012

SUBJECT: Survey of Control Technology for Transfer Operations and Analysis of Impacts 

for Transfer Operation Control Options

1. Purpose

This memorandum documents the results of the survey of control technologies for transfer 

operations. One objective of this survey was to identify any new or improved technology, 

monitoring technique or work practice that has not been identified and implemented in an 

existing regulation for the control of emissions from transfer operations. Another objective was 

to estimate the costs and environmental impacts for both existing control alternatives and any 

new alternatives that are identified. The burden and costs of monitoring, recordkeeping, and 

reporting activities for the alternatives were also estimated.

2. Legislative Background

The Clean Air Act (CAA) requires EPA to review promulgated standards periodically to ensure 

that new source performance standards (NSPS) and national emissions standards for hazardous 

air pollutants (NESHAP) reflect advances in emissions reduction technology. Specifically, 

Section 112(d)(6) of the Clean Air Act (CAA) states that “[t]he Administrator shall review, and 

revise as necessary (taking into account developments in practices, processes, and control 

technologies), emission standards promulgated under this section no less often than every 8 

years.” Similarly, Section 111(b)(1)(B) requires EPA to review NSPS for a given source 

category every 8 years, and, if appropriate, revise such standards. To facilitate these required 

reviews, EPA is evaluating key emission sources that exist across several source categories to 

provide a consistent framework when evaluating the emissions from these key sources for a 

particular source category. This memorandum documents the technology review for transfer 

operations.

3. Introduction

Transfer operations consist of loading and unloading of liquids at transfer racks. Only loading 

operations were considered in this analysis. (Unloading consists of transfers typically to storage 

vessels; unloading emissions occur at the storage vessel, and emissions due to displacement of 

vapors from the storage vessel are addressed in a separate technology review.) It is important to 

note that the transfer rack, storage vessel, and connecting piping are typically part of the process 
Technical Memorandum – Technology Review for Transfer Operations

January 20, 2012

2

unit or affected source in existing regulations. Also, the emissions that occur from the connecting 

piping system are part of equipment leak emissions, are subject to equipment leak standards in 

these rules, and control alternatives for the equipment leak emissions are addressed in a separate 

technology review.

Transfer operations are used to transfer materials from the facility, typically from storage 

vessels, to transport vehicles and containers for transport to another site or location. Transport 

vehicles include both tank cars (i.e., railcars) and cargo tanks (e.g., tank trucks). Containers are 

portable cargo units such as drums, portable tanks, or totes. (Transfers to barges or other marine 

vessels are not considered in this analysis. In addition, containers do not include transport 

vehicles or barges.) The transfer rack is the equipment that is used to transfer materials, typically 

liquid products, into transport vehicles and containers. A transfer rack consists of loading (and 

unloading) arms, pumps, meters, shutoff valves, relief valves and other piping and equipment 

that are needed to transfer liquid commodities or products. In general, when the equipment and 

operations are physically separate (i.e., do not share common piping, valves, and other 

equipment), the transfer racks are considered separate transfer racks.

4. Description of Emission Releases

During transfer operations, volatile organic compounds (VOC) and volatile hazardous air 

pollutants (VHAP) are emitted as transferred liquid displaces the vapor in the transport vehicle or 

container. For uncontrolled operations, transfer operation emissions typically occur at the 

loading hatch or opening of the transport vehicle or container. Emissions can also occur from 

leaks in the transport vehicle or container. The rate at which these VOC and VHAP are emitted 

varies depending on which type of transport vehicle or container is being loaded (tanker truck, 

railcar, drum, tote, etc.), whether the transport vehicle or container was empty before filling or 

refilled while still containing a heel and vapors, the physical and chemical characteristics of the 

liquid being loaded, and the type of loading method used.

Loading methods may include either splash loading or one of the two types of submerged 

loading. In splash loading, the fill pipe dispensing the liquid enters through the top opening of 

the transport vehicle or container, is lowered only part way into the tank, and dispenses the 

commodity or liquid above liquid level in the transport vehicle or container. Splash loading 

causes turbulence, vapor/liquid contact, and misting to occur. Use of splash loading, or top 

loading, results in significant vapor generation and loss, and in some cases, can entrain liquid 

droplets in the vented vapors. (Submerged loading and bottom loading are other methods for 

loading, are considered control techniques for loading, and so are discussed below in section 5. It 

is assumed that bottom loading would not be conducted for container loading.)

Transfer operation emissions depend on the physical and chemical characteristics of the liquid 

being loaded. These characteristics include the volatility (or vapor pressure) and molecular 

weight of the liquid being transferred, the temperature and pressure conditions of the transfer 

operation, and the volume of material transferred.
Technical Memorandum – Technology Review for Transfer Operations

January 20, 2012

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Loading emissions occur as the VOC and VHAP vapors present in the transport vehicle or 

container are displaced by the liquid being loaded. The vapors in the transport vehicle or 

container include either vapors generated as the liquid is being loaded, and/or vapors remaining 

from residual commodity or liquid from the previous load (if present).

Whether any residual vapors are present depends on the previous transfer operation that occurred 

in the transport vehicle or container and whether the transfer vehicle or container was cleaned. If 

the previous liquid in the tank was nonvolatile, or if the tank has been cleaned, then the tank 

space likely contains vapor-free air. If the previous liquid in the tank was volatile and has not 

been cleaned or vented, then the air in the tank space will contain VOC or VHAP vapors, which 

will be displaced and expelled during the loading operation along with the new vapors generated 

during loading. If the transport vehicle or container is in dedicated service, then the same liquid 

is loaded, and emissions will be fairly consistent (depending on the loading method and the 

loading condition temperature and pressure). If the transport vehicle or container is in switch 

service, the emissions will vary significantly due to the volatility of the previous liquid loaded. 

Typically, for small container loading, the container is likely empty and clean prior to loading.

5. Identification of Control Options for Transfer Operations

Transfer to Transport Vehicles

No new technologies for transfer operations to transport vehicles have been identified in the 

technology review. Existing technologies include submerged loading and bottom loading. More 

effective technologies include conveying displaced emissions through a closed vent system to a 

control device, vapor balancing, and routing displaced emissions to a fuel gas system. The 

submerged/bottom loading techniques may be implemented alone or in combination with any of 

the more effective techniques. An additional technique that may be implemented with any of 

these control techniques is to load regulated material only into transport vehicles that have been 

demonstrated to be vapor tight.

Submerged loading is a loading technique in which the fill pipe enters through the top opening of 

the transport vehicle, extends into the vertical depth of the tank, and discharges the commodity 

near the bottom of the tank. The discharge point for submerged loading is typically between 6 

and 12 inches above the bottom of the tank. In bottom loading, there is a permanent fill pipe 

installed at the bottom of the tank, and commodity is loaded through this tank opening or fitting 

at the tank bottom. Both submerged loading and bottom loading reduce emissions generated 

from loading of transport vehicles by reducing turbulence and misting.

The technology for the closed vent system to a control device consists of piping that captures 

displaced VOC and VHAP vapors from the vapor space of the transport vehicle and routes them 

to a control device. Alternatively, the closed vent system to control device option could be 

replaced by vapor balancing to the storage vessel from which the liquid being loaded originated. 

Under vapor balancing, displaced vapors from the vapor space are captured and routed through 

piping back to the storage vessel (rather than to a control device). If emissions are routed to a 

fuel gas system, the pollutants are burned, just as in a combustion based control system. The 
Technical Memorandum – Technology Review for Transfer Operations

January 20, 2012

4

performance of each of these systems is considered to be similar. Furthermore, vapor balancing 

may not be feasible if, to prevent venting during transfer, set points on pressure relief devices in 

the system have to be set at levels above the operating design pressure of atmospheric storage 

vessels. In addition, fuel gas systems may be impractical unless the transfer emissions can be 

combined with other, more significant emissions. Therefore, we determined impacts only for the 

closed vent system to control device approach in this analysis.

Management practices to ensure that the transport vehicle is vapor-tight and leak-free include

vapor-tightness testing using EPA Method 27. Current rules require such testing annually. In 

addition to vapor-tightness testing for the transport vehicle, facilities also monitor the 

pressure/vacuum during loading operations, to ensure the loading does not occur outside of the 

P/V settings. 

Thus, alternatives for which impacts were evaluated are:

1. Submerged loading or bottom loading with Method 27 monitoring of transport vehicles 

(Control Option TR1)

2. Control Option TR1 plus venting to control through a closed vent system (Control Option 

TR2)

Transfer to Containers

No new technologies for transfer operations to containers have been identified in the technology 

review. Existing technologies include management practices such as ensuring covers and other 

closure devices are secured in the closed position except when access is needed and testing to 

ensure that containers are vapor tight. The testing could include either vapor tightness testing in 

accordance with EPA Method 27 or monitoring for leaks in accordance with Method 21. Other 

technologies include submerged fill and using containers with a fitted opening through which the 

regulated material is filled (with subsequent purging of the transfer line before removing it from 

the container opening). More effective techniques include conveying displaced emissions 

through a closed vent system to a control device, vapor balancing, and conducting transfer in an 

enclosure that is vented to a control device. The management practice and submerged loading 

techniques can be implemented separately or in combination with any of the other options. 

Submerged loading is a loading technique in which the fill pipe enters the top opening of the 

container, extends to the bottom of the container, and discharges the commodity near the bottom. 

Submerged loading reduces emissions generated from loading of containers by reducing 

turbulence and misting.

The technology for the closed vent system to a control device consists of piping that captures 

displaced vapors from the vapor space of the container and routes them to a control device. A 

vapor balancing system is similar, except that piping routes the displaced vapors back to the 

storage vessel that supplied the liquid that is transferred to the container. In another control 

scenario for venting to a control device, transfer operations to a container is conducted inside an 

enclosure, and the enclosure or room air is vented to a control device. All of these techniques 
Technical Memorandum – Technology Review for Transfer Operations

January 20, 2012

5

have similar performance. Therefore, we evaluated impacts only for a closed vent system to 

control in this analysis.

In summary, the control options for which impacts were evaluated in this analysis are:

1. Combination of submerged fill, management practices, and testing for leaks or vaportightness (Control Option TR3)

2. Control Option TR3 plus venting to a control device through a closed vent system 

(Control Option TR4)

6. Impacts Analysis 

Model Facilities

Transfer Racks to Load Transport Vehicles. To evaluate the control alternatives we used model 

facilities. Parameters that varied among the models included the number of loading arms, the 

total annual throughput through all arms, and the annual average partial pressure of the regulated 

material over all transferred liquids. We assumed that the number of separate transfer racks at a 

facility does not affect the impacts, so that a model facility with multiple loading arms could 

represent actual facilities with either one or multiple transfer racks. The values for the throughput 

and number of arms were approximated from the ranges of parameters in the Background 

Information Document for the hazardous organic NESHAP (HON) (Volume 1C), and ranged 

from 0.5 million gallons/year to 45 million gallons per year and 1-12 arms, respectively (U.S. 

EPA, 1992). Vapor pressure values of 0.08, 0.4, 1, 3, and 6 psia were selected to encompass the 

range of vapor pressures for common petroleum liquids and organic chemicals. A total of 41

model facilities were developed based on various combinations of these parameters, and impacts 

for both Control Option TR1 and Control Option TR2 were estimated for each model. However, 

because the impacts for many of the models were very similar, we selected only subsets of the 

models for discussion in this memorandum. The selected models represent ranges of throughputs 

and vapor pressures over which any regulatory applicability decisions are likely to be made. 

Table 1 lists the characteristics for the models used to illustrate impacts for both of the control 

options (TR1 and TR2). Attachment A summarizes the characteristics and impacts for all 41 of 

the models. 

Transfer Racks to Load Containers. Model transfer racks for container loading were developed 

based on the range of throughputs reported by facilities that responded to a survey for the 

Organic Liquids Distribution (OLD) NESHAP (Smith, 2002a). We also varied annual average 

Reid vapor pressures from 1.5 to 8 psia. All model facilities have a single filling station. 

We developed a total of 28 model facilities based on various combinations of these parameters. 

However, we selected only six models for discussion because these models cover the range of 

impacts as well as the range of throughputs and vapor pressures. Table 2 lists the characteristics 

of these models. Attachment B presents the characteristics and impacts for all 28 of the models. 
Technical Memorandum – Technology Review for Transfer Operations

January 20, 2012

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Table 1. Model facilities for transfer to transport vehicles

Control Option TR1 Control Option TR2

Model

Throughput 

(million 

gal/yr)

Average 

vapor 

pressure 

(psia)

Number of 

arms Model

Throughput 

(million 

gal/yr)

Average 

vapor 

pressure 

(psia)

Number of 

arms

A 2 0.080 1 J 15 1.0 6

B 2 1.0 2 K 15 3.0 2

C 2 3.0 2 L 15 6.0 6

D 21 0.080 4 M 25 1.0 10

E 21 1.0 4 N 25 3.0 8

F 21 3.0 4 O 25 6.0 8

G 45 0.080 12 P 45 1.0 6

H 45 1.0 6 Q 45 3.0 6

I 45 3.0 6 R 45 6.0 12

Table 2. Model facilities for transfer to containers

Model Throughput (thousand gal/yr) Reid Vapor Pressure (psia)

S 100 1.5

T 5,000 1.5

U 100 3.4

V 5,000 3.4

W 100 8.0

X 5,000 8.0

Emission Estimates

For loading transport vehicles:

1. Uncontrolled

Uncontrolled VOC emissions were estimated using equation 1 in AP-42 chapter 5.2-4 (U.S. 

EPA, 1995). For this analysis, we assumed an average operating temperature of 60°F and an 

average vapor molecular weight of 80.1 Other inputs in the equation are the total annual 

throughput and the average annual vapor pressure of the transferred liquids, both of which vary 

by model as noted in Table 1. We also used the saturation factor for splash loading (i.e., 1.45). 

 1 The average molecular weight is approximately the same as for benzene. It is also slightly higher than the vapor 

molecular weight for gasoline while being slightly lower than the molecular weights for common chemicals such as 

toluene and hexane. It is also about the midpoint of the range for most organic HAP.
Technical Memorandum – Technology Review for Transfer Operations

January 20, 2012

7

2. Control Option TR1: Submerged loading performance

According to AP-42 chapter 5.2, the saturation factor for submerged loading is estimated to be 

0.6 (U.S. EPA, 1995). Reducing the saturation factor also reduces the concentration of organic 

compounds in the gases that are displaced by liquid when loading the transport vehicle. Thus, the 

use of submerged loading reduces emissions by about 60 percent compared to the uncontrolled 

emissions. 

3. Control Option TR2: Submerged loading plus closed vent system to control performance

We assumed that the closed vent system and flare reduce emissions by 98 percent. Using this 

control in addition to submerged loading results in an estimated reduction of more than 99 

percent relative to uncontrolled splash loading. Vapor tightness testing of the transport vehicles 

helps ensure that these are the only emissions associated with transfers.

4. Summary

The uncontrolled emissions and controlled emissions for Control Options TR1 and TR2 are 

shown in Table 3 for each model facility that loads transport vehicles.

Table 3. Emissions by control option for model transfer racks that load transport vehicles

Control Option TR1 Control Option TR2

Model

Uncontrolled VOC 

emissions (tpy)

Controlled 

emissions (tpy) Model

Uncontrolled VOC 

emissions (tpy)

Controlled 

emissions (tpy)

A 0.22 0.092 J 21 0.17

B 2.8 1.2 K 62.5 0.52

C 8.3 3.5 L 130 1.0

D 2.3 0.97 M 35 0.29

E 29 12 N 100 0.86

F 88 36 O 210 1.7

G 5.0 2.1 P 62.5 0.52

H 63 26 Q 190 1.6

I 190 78 R 380 3.1

For loading containers:

1. Uncontrolled

Uncontrolled emissions from container loading were estimated using the vehicle refueling 

equation and the transfer loss equation in Chapter 5 of AP-42 (i.e., equation 6 in section 5.2.2.3 

and equation 1 in section 5.2.2.1.1, respectively) (AP-42, 1995). The vehicle refueling equation

previously was selected for estimating baseline emissions from container loading in the analysis 

for the OLD NESHAP because the analysts noted that surveyed OLD facilities were using 

service station type nozzles to dispense liquids into containers, and they determined the results 
Technical Memorandum – Technology Review for Transfer Operations

January 20, 2012

8

using the transfer loss equation to be extremely high (Smith, 2002b). However, a problem with

the vehicle refueling equation is that it is not reliable at low vapor pressures. Specifically, as the 

vapor pressure approaches zero, the emissions are estimated to be negative. Therefore, for this 

analysis we estimated the emissions using both equations, but we modified the splash loading 

saturation factor for the transfer loss equation. If we were to use the splash loading saturation 

factor (i.e., 1.45) in the transfer rack loss equation, the emissions would be much higher than the 

results from the vehicle refueling equation. However, this factor may not be realistic for 

container loading given the much lower filling rate for containers. Thus, we selected a saturation 

factor (i.e., 0.88) that resulted in the same emissions as the vehicle refueling equation when the 

Reid vapor pressure is 3.4 psia as in the OLD analysis. We also assumed the true vapor pressure 

at the assumed operating temperature of 60°F is about 40 percent of the Reid vapor pressure (this 

value is a little high for pure compounds and a little low for gasoline). For higher Reid vapor 

pressures, the transfer loss equation estimates lower emissions than the vehicle refueling 

equation, and vice versa for lower Reid vapor pressures. As in the analysis for transfer racks that 

load transport vehicles, we assumed the average vapor molecular weight is 80. The specific 

results used in the impacts analysis are described in the Cost Effectiveness discussion of this 

memorandum (see Tables 9 and 10).

2. Control Option TR3 performance

As in the analysis for loading transport vehicles, we assumed that the saturation factor for 

submerged loading of containers is 0.6. Thus, the estimated reduction achieved by submerged 

loading is 32 percent ([0.88-0.6]/0.88 = 0.32). Management practices such as ensuring that 

closure devices are secured in the closed position and conducting vapor tightness tests for 

containers are expected to reduce emissions as well, but we lack information to quantify such 

reductions.

3. Control Option TR4 performance

As in the analysis for transfer racks that are used to load transport vehicles, we assumed the flare 

in Control Option TR4 reduces emissions by 98 percent. Using the flare in addition to submerged 

fill reduces emissions by almost 99 percent. 

4. Summary

Table 4 shows the uncontrolled and controlled emissions for Control Options TR3 and TR4 for 

model facilities that load containers.
Technical Memorandum – Technology Review for Transfer Operations

January 20, 2012

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Table 4. Emissions by control option for model transfer racks that load containers

Uncontrolled VOC emissions 

(tpy)

Controlled emissions (tpy)

Model

Control Option TR3 Control Option TR4

TL VR TL VR TL VR

S1 0.051 0.014 0.035 0.0092 0.00069 0.00018

T1 2.5 0.67 1.7 0.46 0.035 0.0092

U 0.11 0.078 0.0016

V 5.7 3.9 0.078

W2 0.27 0.36 0.18 0.25 0.0037 0.0049

X2 13 18 9.2 12 0.18 0.25

1

For models that transfer materials with a low average vapor pressure, the larger uncontrolled emissions 

estimate is obtained when using the transfer loss (TL) equation in AP-42 section 5.2.2.1.1. 2

For models that transfer materials with a high average vapor pressure, the larger uncontrolled emissions 

estimate is obtained when using the vehicle refueling (VR) equation in AP-42 section 5.2.2.3.

Capital Costs

Submerged loading for transport vehicles (Control Option TR1): The total capital investment to 

convert a loading rack from splash loading to submerged loading was estimated based on an 

estimate in the docket for the Gasoline Distribution Area Source NESHAP (Weaver, 2007). This 

estimate was $25,000 in 2006 dollars for a transfer rack with 6 arms. To estimate costs for the 

model facilities in this analysis, we assumed that the cost per arm would be the same regardless 

of the number arms being converted (i.e., no economies of scale). We then scaled the costs from 

2006 dollars to 2010 dollars using the Chemical Engineering Plant Cost Indexes for 2006 and 

2010. For example, we estimated the cost for submerged loading for transport vehicles to be 

$28,000 for 6 loading arms (i.e., $25,000 * 550.8 / 499.6).

Submerged fill for loading containers (Control Option TR3): The total capital investment was 

estimated using the same procedure as for Control Option TR1, except that the average size of 

the drop tube was assumed to be half that of the average for Control Option TR1, and the 

equipment costs were scaled using the six-tenths factor rule. According to the six-tenths factor 

rule, if the cost of a piece of equipment at one capacity is known, then the cost of a similar piece 

of equipment with X times the capacity of the first is X0.6 times the cost of the first piece of 

equipment (Peters et al, 2003). In this analysis, we used the drop tube size as the capacity scaling 

parameter (i.e., X=0.5). We also assumed 10 hours of planning time by an engineer to determine 

needed changes and decide on an approach; labor rates were the same as the rates used in other 

recent analyses (Randall, 2012). Thus, we estimated the total capital investment for submerged 

fill for one container loading station to be $4,000 (($25,000 * 550.8/499.6 * 1 arm / 6 arms) * 

(0.5)

0.6 + 10 hr * $92.72/hr)

Closed vent to control (Control Options TR2 and TR4): The impacts for the closed vent system 

to control options in this analysis were developed from the analysis for the OLD NESHAP. The 

impacts analysis for the OLD NESHAP used enclosed ground flares as the control device 

(Smith, 2002c). These flares were determined to be a commonly used control for transfer racks, 
Technical Memorandum – Technology Review for Transfer Operations

January 20, 2012

10

and they were also determined to be the lowest cost option. Flare system equipment costs (in 

1997 dollars) were estimated for small, medium, and large flares in the OLD analysis. The 

corresponding flare gas flow rates for these models were 130 acfm, 200 acfm, and 260 acfm. We 

plotted the equipment costs versus the flow rates for those models and developed an equation for 

the curve through the three points. We used this equation to estimate the flare equipment costs 

for each model transfer rack in this analysis. As in the OLD analysis, the purchased equipment 

costs, including the flare, instrumentation, taxes, and freight, were estimated to be equal to 1.18 

times the flare equipment costs alone. Direct and indirect installation costs were estimated to be 

equivalent to 92 percent of the purchased equipment costs. We then scaled the total capital 

investment to 2010 dollars using the Chemical Engineering Plant Costs Indexes for 1997 and 

2010.

Annual Costs

Submerged loading (Control Options TR1 and TR3). The total annual costs for submerged 

loading include costs for capital recovery; operation and maintenance; and property taxes, 

insurance, and administration. We also estimated product recovery credits for the submerged 

loading control option. The factors used to estimate these costs are summarized in Table 5.

Table 5. Factors used to estimate annual costs for submerged loading

Costing element Factor Comments

Capital recovery 0.1098 Calculated using standard equation assuming 

equipment life of 15 years and an interest rate of 

7% (U.S. EPA, 2002)

Operation and maintenance 0.03 x TCI From analysis for Gasoline Distribution Area 

Source NESHAP (U.S. EPA, 1984; Hester, 2006)

Property taxes, insurance, and 

administration

0.04 x TCI Standard factor in OAQPS cost estimates (U.S. 

EPA, 2002)

Product recovery credit $900/ton Representative cost for various bulk chemicals 

(Parrish, 2007)

Closed vent system to control device (Control Options TR2 and TR4). The total annual costs for 

Control Options TR2 and TR4 include direct annual costs for operating labor, materials, steam, 

pilot gas, and purge gas related to flare operation. The total annual costs also include indirect 

annual costs for capital recovery, overhead, property taxes, insurance, and administration. The 

factors used to estimate these costs for the model transfer racks are listed in Table 6.
Technical Memorandum – Technology Review for Transfer Operations

January 20, 2012

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Table 6. Factors used to estimate annual costs for closed vent systems and flares

Costing element Factor Comments

Direct annual costs

 Labor charges $22,800 x 1.45 Assumed labor rates increased by 45% 

between 1997 and 2010 (comparable to 

the equipment cost increase)

 Material $10,360 Assumed same value as in the OLD 

analysis (Smith, 2002c)

 Purge gas $400 Assumed average of the values used in the 

OLD analysis (Smith, 2002c)

 Pilot gas $2,045 Assumed same value as in the OLD 

analysis (Smith, 2002c)

 Steam $55.1/acfm Same unit cost as in OLD analysis (Smith, 

2002c)

Indirect annual costs

 Overhead 0.6 x (labor and material) Standard factor in OAQPS analyses (U.S. 

EPA, 2002)

 Property taxes, insurance, 

and administration

0.04 x TCI Standard factor in OAQPS analyses (U.S. 

EPA, 2002)

 Capital recovery 0.1424 x TCI Calculated using standard equation 

assuming equipment life of 10 years 

and an interest rate of 7% (U.S. EPA, 

2002)

Vapor tightness. Costs to conduct EPA Method 27 testing with minimal, if any, maintenance 

was estimated to cost about $350 in 1992 and $300 to $400 in 2006 (U.S. EPA, 1994; Hester, 

2006; Cavalier, 2003). DOT testing was estimated to cost about $200 in 1992 (U.S. EPA, 1994). 

Given the similarity of costs in 1992 and 2006, we assumed Method 27 testing costs in 2010 

were also about $350, and DOT testing costs are still about $200. We do not know how many 

transport vehicles are not already tested in accordance with Method 27. Thus, we conducted a 

sensitivity analysis to determine the effect of 10, 50 and 100 additional transport vehicles being 

subject to Method 27 testing if a model transfer rack becomes subject to the Uniform Standards. 

We also assumed all transport vehicles are already subject to at least the DOT requirements so 

that the additional cost of a Method 27 testing requirement would consist of only the incremental 

cost between DOT testing and Method 27 testing. 
Technical Memorandum – Technology Review for Transfer Operations

January 20, 2012

12

Cost Effectiveness

Table 7 shows the cost and emission impacts of Control Option TR1 with no additional Method 

27 testing and with 100 transport vehicles being subject to Method 27 testing for the first time. 

Figures 1 and 2 show the results graphically for the same model facilities as well as several 

others that are documented in Attachment A. The results show the cost impacts of submerged 

loading alone are low for nearly the entire range of potential facilities, and in many cases 

switching to submerged loading would result in cost savings due to the substantial product 

recovery credit. However, cost effectiveness impacts are significantly higher if a substantial 

number of additional vehicles would be subject to Method 27 testing, but it still results in a 

savings when the throughputs and vapor pressures of the transferred material are relatively high.

Table 7. Impacts for Control Option TR1 (submerged loading) for loading transport 

vehicles

Model

Emission 

reduction 

for 

submerged 

loading 

(tpy)

Total 

Capital 

Cost ($)

Product 

Recovery 

Credit 

($/yr)

Total annual cost ($/yr), 

accounting for product 

recovery

Cost effectiveness 

($/ton)

No 

Method 27 

testing

With 100 

Method 27 

tests per 

year

No 

Method 27 

testing

With 100 

Method 27 

tests per 

year

A 0.13 4,600 (120) 710 16,000 5,400 120,000

B 1.6 9,200 (1,500) 460 15,000 110 9,300

C 4.9 9,200 (4,400) (2,700) 12,000 (560) 2,500

D 1.4 18,000 (1,200) 2,100 17,000 1,500 12,000

E 17 18,000 (15,000) (12,000) 2,900 (710) 170

F 51 18,000 (46,000) (43,000) (28,000) (840) (540)

G 2.9 55,000 (2,600) 7,300 22,000 2,500 7,600

H 37 28,000 (33,000) (28,000) (13,000) (770) (360)

I 110 28,000 (99,000) (94,000) (79,000) (860) (720)
Technical Memorandum – Technology Review for Transfer Operations

January 20, 2012

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Figure 1. Cost effectiveness of Control Option TR1 (without Method 27 vapor tightness 

testing) for model facilities transferring material with annual average vapor pressures 

between 0.08 psia and 3 psia.

Figure 2. Cost effectiveness of Control Option TR1 (with Method 27 vapor tightness testing 

of 100 transport vehicles) for model facilities transferring material with annual vapor 

pressures between 0.08 psia and 3 psia.
Technical Memorandum – Technology Review for Transfer Operations

January 20, 2012

14

Table 8 shows the impacts of Control Option TR2. For a given model, the incremental cost 

effectiveness values for Control Option TR2 are higher (worse) than the cost effectiveness values 

for Control Option TR1 (see Attachment A). Note, however, that the values in Table 8 are not 

much higher than those in Table 7; this is because the model facilities represented in Table 8 

have higher throughputs and material vapor pressures than those in Table 7. In Table 8, also note 

that the total capital and annual costs are the same for models with the same number of loading 

arms because the flows are assumed to be the same for such models.

Table 8. Impacts for Control Option TR2 (submerged loading plus closed vent system to 

flare) for loading transport vehicles

Model

Emissions 

reduction for 

submerged 

loading with 

CVS/flare (tpy)

Total Capital 

Cost ($)

Total Annual 

Cost ($/yr)

Cost 

Effectiveness Vs 

Uncontrolled, no 

Method 27 

testing ($/ton)

Incremental 

Cost 

Effectiveness Vs 

Control Option 

TR1, no Method 

27 testing

($/ton)

J 21 110,000 94,000 4,300 11,000

K 62 60,000 79,000 780 3,100

L 120 110,000 94,000 270 1,900

M 34 200,000 120,000 3,100 8,200

N 100 150,000 100,000 540 2,500

O 210 150,000 100,000 1.8 1,200

P 62 110,000 94,000 1,100 3,700

Q 190 110,000 94,000 0.19 1,200

R 370 270,000 130,000 (150) 860

Table 9 shows the impacts of Control Option TR3 with no Method 27 vapor tightness testing. 

For models with a throughput of 5 million gal/yr, the product recovery credit is large enough that 

the control results in a cost savings. The impacts for models when vapor tightness testing is 

required are not shown in Table 9 because the impacts are extremely high (see Attachment B for 

estimates for model facilities with 100 containers to test). Method 27 testing of containers also 

would be impractical because a very large number of tests would be required, unless the testing 

is limited to large containers and/or containers storing very volatile material. Furthermore, unlike 

transport vehicles, the testing would most likely have to be done onsite because it would be 

difficult to take the containers to a facility that provides a testing service. We do not have 

information on whether testing companies have the capability to conduct testing at a customer’s 

site.
Technical Memorandum – Technology Review for Transfer Operations

January 20, 2012

15

Table 9. Impacts for Control Option TR3 (submerged loading) for loading containers

Model

Emissions reduction for 

submerged loading (tpy)1

Total Capital 

Cost ($)

Total Annual 

Cost ($/yr)

Cost Effectiveness 

($/ton)

S 0.016 4,000 700 43,000

T 0.81 4,000 (13) (16)

U 0.036 4,000 680 19,000

V 1.8 4,000 (920) (510)

W 0.086 4,000 630 5,500

X 4.3 4,000 (3,200) (550)

1

Based on the higher estimate of uncontrolled emissions from Table 4.

Table 10 shows the impacts of Control Option TR4. Both the overall cost effectiveness and the 

incremental cost effectiveness relative to Control Option TR3 are significantly higher than for 

Control Option TR3. Note that models T, V, and X , those with the best cost effectiveness, 

represent facilities with the highest throughput for container loading reported by OLD facilities 

(Smith, 2002a). If a chemical manufacturing facility has higher container loading throughputs 

that the OLD facilities, then the cost impacts would be lower than those estimated for the models 

in Table 10.

In addition, the models represent transfer racks that are dedicated to container loading. If a 

facility loads both transport vehicles and containers at the same rack(s) and can route emissions 

from all arms to the same control device, then the impacts in Table 8 would apply. Note that the 

costs are the same for all models because the fill rate is assumed to be the same for all models so 

the displaced gas flow rate is also the same for all models.

Table 10. Impacts for Control Option TR4 (submerged loading plus closed vent system to 

flare) for loading containers

Model

Emissions 

reduction for 

submerged 

loading and 

CVS/flare (tpy)1

Total 

Capital 

Cost ($)

Total 

Annual Cost 

($/yr)

Cost 

Effectiveness 

($/ton)

Incremental Cost 

Effectiveness Vs 

Control Option TR3 

($/ton)

S 0.050 45,000 80,000 1,600,000 2,400,000

T 2.5 45,000 80,000 32,000 47,000

U 0.11 45,000 80,000 720,000 1,100,000

V 5.6 45,000 80,000 14,000 21,000

W 0.36 45,000 80,000 230,000 330,000

X 18 45,000 80,000 4,300 6,600

1

Based on the higher estimate of uncontrolled emissions from Table 4.
Technical Memorandum – Technology Review for Transfer Operations

January 20, 2012

16

7. Monitoring, recordkeeping, and reporting

Table 11 lists potential initial monitoring, recordkeeping, and reporting activities for each control 

option and the associated labor burden and costs per facility. Table 12 provides similar 

information for recurring monitoring, recordkeeping, and reporting activities. Labor rates were 

assumed to be $92.72/hr of engineering labor (or $80.62/hr of total labor including management 

and administrative labor), as in other recent analyses (Randall, 2012). The labor hours in Tables 

11 and 12 are total labor.

Table 11. Initial monitoring, recordkeeping, and reporting burden and costs for Control 

Options TR1, TR2, TR3, and TR4

Control 

Option Initial Activities Burden (hr)

Initial 

Costs ($) Comments

TR1 Create and post signs at the 

transfer rack(s) to remind 

employees to load only 

transport vehicles that are 

vapor tight

2.3 190

TR2 Create and post signs as for 

Control Option TR1

2.3 190

Identify any potential sources 

of vapor leakage in closed 

vent system to monitor

2.3 190

TR3 None

TR4 Identify any potential sources 

of vapor leakage in closed 

vent system to monitor

2.3 190

Purchase differential pressure 

gas flow meter and 

temperature indicator

84 19,000 Burden and costs were 

developed in a separate analysis 

(Gibson et al, 2012)

Conduct Method 22 test of 

flare

3.5 280 Assumed engineering labor of 2 

hours for the test plus 1 hour for 

preparation and documentation 

of results.
Technical Memorandum – Technology Review for Transfer Operations

January 20, 2012

17

Table 12. Recurring monitoring, recordkeeping, and reporting burden and costs for 

Control Options TR1, TR2, TR3, and TR4

Control 

Option Recurring Activities

Burden 

(hr/yr)

Total 

Annual 

Costs 

($/yr) Comments

TR1 Annualized initial costs N/A 20 Annualized over estimated transfer rack life 

of 15 years, assuming a 7% interest rate

Keep records of vapor 

tightness testing

35 2,800 Assumed 5 min/d or 2.5 hr/mo to track 

paperwork or electronic forms 

TR2 Annualized initial costs N/A 20 Annualized over estimated transfer rack life 

of 15 years, assuming a 7% interest rate

Keep records of transport 

vehicle vapor tightness 

testing

35 2,800 Assumed 5 min/d or 2.5 hr/mo to track 

paperwork or electronic forms 

Conduct LDAR for closed 

vent system

N/A 100 Assumed monitoring is conducted by a 

contractor, and assumed cost is in range of 

estimated costs for closed vent systems that 

convey emissions from storage vessels 

(Randall, 2012)

Conduct monitoring of 

flare

210 17,000 Burden and costs are for a differential 

pressure gas flow meter and a temperature 

indicator (Gibson et al, 2012). Burden and 

costs include recordkeeping and reporting.

TR3 Keep records of Method 

21 or 27 monitoring of 

subject containers

2.3 190 Cost will vary depending on number of 

subject containers, test method used, and 

number of leakers. Assumed engineering 

labor average of 1 hr/yr for recordkeeping 

and 1 hr per year for reporting leaks. 

TR4 Annualized initial costs

for Method 22 test and 

identifying potential 

sources of vapor leakage 

from the closed vent 

system

N/A 52 Annualized initial costs over estimated 

transfer rack life of 15 years, and assumed a 

7% interest rate. Annualized capital costs for 

the flow meter and temperature indicator are 

included below in the annual costs for flare 

monitoring.

Keep records of Method 

21 or 27 monitoring of 

subject containers

2.3 190 Same as for Control Option TR3

Conduct LDAR for closed 

vent system

N/A 100 Assumed monitoring is conducted by a 

contractor, and assumed cost is in range of 

estimated costs for closed vent systems that 

convey emissions from storage vessels 

(Randall, 2012)

Conduct monitoring of 

flare

210 17,000 Same as for Contorl Option TR2.
Technical Memorandum – Technology Review for Transfer Operations

January 20, 2012

18

10. References

Cavalier, J. (2003, November). Summary of telephone conversation between J. Cavalier, 

MACTEC Federal Programs and R. Schaffer, Weld-It. Information on the cost of the 

California tank truck vapor tightness standards. November 11, 1993. Docket Item No. EPAHQ-OAR-2006-0406-0018.

Economic Indicators. Chemical Engineering Plant Cost Index (CEPCI). Chemical Engineering.

Published by Access Intelligence. April 2011.

Economic Indicators. Chemical Engineering Plant Cost Index (CEPCI). Chemical Engineering. 

Published by Access Intelligence. April 2004.

Gibson, G., J. Renzaglia, M. Thomas, and P. Crawford. 2012. Memorandum from G. Gibson, J. 

Renzaglia, M. Thomas, and P. Crawford, ERG, to A. Bouchard and B. Shine, EPA/OAQPS. 

Development of Monitoring Cost Estimates for the Proposed Part 65 Uniform Standards for 

Control Devices—Subpart M. January 20, 2012. Docket No. EPA-HQ-OAR-2010-0868.

Hester, C. (2006, October). Memorandum from C. Hester and T. Stephenson, MACTEC Federal 

Programs, Inc. to S Shedd, EPA/SPPD. Gasoline Distribution Area Source Control Cost 

Estimates. October 3, 2006. Docket Item No. EPA-HQ-OAR-2006-0406-0063.

Parrish, K. (2007, October). Memorandum from K. Parrish and D. Randall, RTI International, to 

K. Rackley, EPA/SPPD. Final Impacts Analysis for Regulatory Options for Equipment Leaks 

of VOC in the SOCMI. October 30, 2007. Docket Item No. EPA-HQ-OAR-2006-0699-0090.

Peters, M., K. Timmerhaus, and R. West. 2003. Plant Design and Economics for Chemical 

Engineers. Fifth Edition. McGraw-Hill, New York, NY. pp. 242-243.

Randall, D. (2012). Memorandum from D. Randall, RTI International to N. Parsons, EPA/SPPD. 

Survey of Control Technology for Storage Vessels and Analysis of Impacts of Storage Vessel 

Control Options. January 20, 2012. Docket No. EPA-HQ-OAR-2010-0871.

Smith, M. (2002a, April). Memorandum from M.Smith, EPA/SPPD. Memo No. 2: Model Plants 

for the OLD Source Category in TSD Update—Organic Liquids Distribution (OLD) 

NESHAP. April 2002. Docket Item No. EPA-HQ-OAR-2003-0138-0053.

Smith, M. (2002b, April). Memorandum from M.Smith, EPA/SPPD. Memo No. 3: Baseline 

Emissions for the OLD Source Category in TSD Update—Organic Liquids Distribution 

(OLD) NESHAP. April 2002. Docket Item No. EPA-HQ-OAR-2003-0138-0053.

Smith, M. (2002c, April). Memorandum from M.Smith, EPA/SPPD. Memo No. 6: 

Environmental and Cost Impacts of the Proposed OLD NESHAP in TSD Update—Organic 

Liquids Distribution (OLD) NESHAP. April 2002. Docket Item No. EPA-HQ-OAR-2003-

0138-0053.
Technical Memorandum – Technology Review for Transfer Operations

January 20, 2012

19

U.S. EPA. (1984, July). Evaluation of Air Pollution Regulatory Strategies for Gasoline 

Marketing Industry. Office of Air Quality Planning and Standards and Office of Mobile 

Sources. EPA-450/3-84-012a.

U.S. EPA. (1992, November). Hazardous Air Pollutant Emissions from Process Units in the 

Synthetic Organic Chemical Manufacturing Industry—Background Information for Proposed 

Standards. Volume 1C: Model Emissions Sources. Office of Air Quality Planning and 

Standards. EPA-453/D-92-016c.

U.S. EPA. (1994, January). Gasoline Distribution Industry (Stage I) – Background Information 

for Proposed Standards. Office of Air Quality Planning and Standards. EPA-453/R-94-002a.

U.S. EPA. (1995, January). Compilation of Air Pollutant Emission Factors, Volume 1: 

Stationary Point and Area Sources, AP-42, Fifth Edition, U.S. Environmental Protection 

Agency, Office of Air Quality Planning and Standards.

U.S. EPA. (2002, January). EPA Air Pollution Control Cost Manual Section 1 Chapter 2. Sixth 

Edition. Office of Air Quality Planning and Standards. EPA-452/B-02-001.

Weaver, P. (2007, January). Letter from P. Weaver, Independent Liquid Terminals Association, 

to S. Shedd, EPA/SPPD. ILTA Responses to EPA Questions Following November 13 

Conference Call. January 5, 2007. Docket Item No. EPA-HQ-OAR-2006-0406-0099.
ATTACHMENT A:  IMPACTS FOR CONTROL OPTIONS TR1 AND TR2
Table A-1. Estimated Impacts of Control Options TR1 and TR2 for Model Transfer Racks That Load Transpor

Rack and Material Characteristics Emissions and Costs per Model Transfer Rack

Number of arms 1 1 2 4 8 4 Total annual throughput per rack, million gal/yr 0.5 2 15 21 25 25 

Average throughput per arm, million gal/yr 0.5 2 7.5 5.25 3.125 6.25 

VOC vapor pressure, psia 0.08 0.08 0.08 0.08 0.08 0.08 

Emissions

Uncontrolled VOC emissions, lb/yr 111 445 3,335 4,670 5,559 5,559 

Uncontrolled emissions, tpy 0.056 0.22 1.67 2.33 2.78 2.78 

Submerged loading VOC emissions, lb/yr 46 184 1,380 1,932 2,300 2,300 

Emissions reduction for submerged loading, lb VOC/yr 65 261 1,955 2,737 3,259 3,259 

Emission reduction for submerged loading, tpy 0.033 0.13 0.98 1.37 1.63 1.63 

Emissions reduction for CVS/flare, tpy1 0.023 0.090 0.676 0.947 1.127 1.127 

Emission stream

VOC flow per arm, lbmole/min 0.00022 0.00022 0.00022 0.00022 0.00022 0.00022 Total gas flow per arm, lbmole/min 0.067 0.067 0.067 0.067 0.067 0.067 

VOC concentration, ppmv 3,267 3,267 3,267 3,267 3,267 3,267 Alternative calc of concentration, ppmv 3,265 3,265 3,265 3,265 3,265 3,265 Displaced gas flow rate per arm, acfm 25.40 25.40 25.40 25.40 25.40 25.40 

Maximum displaced gas flow per rack 25.40 25.40 50.80 101.60 203.21 101.60 

when all arms are in use, acfm

VOC concentration, ppmv 3,267 3,267 3,267 3,267 3,267 3,267 

Stream heating value, BTU/scf 10.32 10.32 10.32 10.32 10.32 10.32 

Minimum rack operating time hr/yr2 Minimum rack operating time, hr/yr 44 175 658 461 274 548 

Costs for submerged loading (Option TR1)

Total capital investment, $ 4,594 4,594 9,187 18,375 36,749 18,375 

Capital recovery 504 504 1,009 2,017 4,035 2,017 

Property taxes, Insurance, Admin (0.04*TCI) 184 184 367 735 1,470 735 

Operation and Maintenance (0.03*TCI) 138 138 276 551 1,102 551 

Product Recovery Credit (29) (117) (880) (1,232) (1,466) (1,466

Total Annual Cost $/yr 797 709 772 2,072 5,141 1,837 

Cost effectiveness without product recovery, $/ton 25,344 6,336 1,690 2,414 4,055 2,028 Cost effectiveness with product recovery, $/ton 24,444 5,436 790 1,514 3,155 1,128 Method 27 testing3 (sensitivity analysis)

10 vehicles 1,500 1,500 1,500 1,500 1,500 1,500 

50 vehicles 7,500 7,500 7,500 7,500 7,500 7,500 100 vehicles 15,000 15,000 15,000 15,000 15,000 15,000 

Cost effectiveness with 100 Method 27 tests per year 484,741 120,510 16,133 12,473 12,361 10,333 

A‐1
Table A-1 Continued

Costs for CVS/flare (Option TR2)

Equipment cost of system, 1997 $4 15,910 15,910 18,483 24,942 45,424 24,942 

Purchased equipment cost, 1997$ (PEC = 1.18 x EC) 18,774 18,774 21,810 29,432 53,600 29,432 

Total capital investment, 2010 $5 51,570 51,570 59,908 80,845 147,231 80,845 

Direct annual costs, 2010 $/yr6 47,264 47,264 48,663 51,461 57,057 51,461 

Indirect annual costs, 2010 $/yr 29,242 29,242 30,763 34,582 46,691 34,582 Total annual cost, $/yr $76,506 $76,506 $79,426 $86,043 $103,748 $86,043 

Cost effectiveness of Option 2 (no Method 27 testing) 1,402,176 350,145 48,490 38,055 39,502 31,881 

Incremental cost effectiveness, $/ton 3,393,795 848,449 117,444 90,877 92,044 76,337 

Incremental CE with 100 Method 27 tests per year 4,059,189 1,014,797 139,624 106,720 105,352 89,645 

InputsTemperature, F 60

Molecular weight 80

Uncontrolled (splash loading) saturation factor 1.45

Controlled (submerged loading) saturation factor 0.6

Price of recovered material, $/ton 900Capital recovery factor 0.1098 assuming 7% interest and 15 yearsaverage transfer rate per arm 190 gal/min (from HON Bid vol 1C for transfer to railcars; slightly lower avera

11,400 gal/hr

Assumed Typical Heating Value of Compound 15,000 BTU/lbCE Plant Index 2006 to 2010 dollars 1.1025

Submerged loading cost in 2010 dollars 27,562 for 6 arms (Quote of $25,000 for converting 6 arms to submerged loa

1Assumes 98 percent control efficiency for the flare.

2Minimum operating time assumes all arms operate simultaneously when the rack is operated.

Actual operating time for racks with more than one arm will be greater than this value.

3Assuming $350/test, but that all vehicles are subject to DOT testing at a cost of $200 so that the incremental cost to conduct Method 27 testing is $150.4CVS/flare costs are based on extrapolation of flare costs in organic liquid distribution analysis. Capital cost of equipment in 1997 dollars estimated using TC5Installation estimated as 92% of PEC. CEPCI for 1997 and 2010 are 385 and 581, respectively.6Annual costs estimated as in OLD analysis, with labor escalated by 45 percent.

A‐2
Table A-1 Continued

Rack and Material Characteristics Emissions and Costs per Model Transfer Rack

Number of arms 1 2 2 6 9 4 Total annual throughput per rack, million gal/yr 0.5 2 15 15 15 21 

Average throughput per arm, million gal/yr 0.5 1 7.5 2.5 1.6667 5.25 

VOC vapor pressure, psia 0.4 0.4 0.4 0.4 0.4 0.4 

Emissions

Uncontrolled VOC emissions, lb/yr 556 2,224 16,677 16,677 16,677 23,348 

Uncontrolled emissions, tpy 0.28 1.11 8.34 8.34 8.34 11.67 

Submerged loading VOC emissions, lb/yr 230 920 6,901 6,901 6,901 9,661 

Emissions reduction for submerged loading, lb VOC/yr 326 1,304 9,776 9,776 9,776 13,687 

Emission reduction for submerged loading, tpy 0.16 0.65 4.89 4.89 4.89 6.84 

Emissions reduction for CVS/flare, tpy1 0.113 0.451 3.381 3.381 3.381 4.734 

Emission stream

VOC flow per arm, lbmole/min 0.00109 0.00109 0.00109 0.00109 0.00109 0.00109 

Total gas flow per arm, lbmole/min 0.067 0.067 0.067 0.067 0.067 0.067 

VOC concentration, ppmv 16,333 16,333 16,333 16,333 16,333 16,333 

Alternative calc of concentration, ppmv 16,327 16,327 16,327 16,327 16,327 16,327 

Displaced gas flow rate per arm, acfm 25.40 25.40 25.40 25.40 25.40 25.40 

Maximum displaced gas flow per rack 25.40 50.80 50.80 152.41 228.61 101.60 

when all arms are in use, acfm

VOC concentration, ppmv 16,333 16,333 16,333 16,333 16,333 16,333 

Stream heating value, BTU/scf 51.62 51.62 51.62 51.62 51.62 51.62 

Minimum rack operating time hr/yr2 Minimum rack operating time, hr/yr 43.86 87.72 657.89 219.30 146.20 460.53 

Costs for submerged loading (Option TR1)

Total capital investment, $ 4,594 9,187 9,187 27,562 41,343 18,375 

Capital recovery 504 1,009 1,009 3,026 4,539 2,017 Property taxes, Insurance, Admin (0.04*TCI) 184 367 367 1,102 1,654 735 Operation and Maintenance (0.03*TCI) 138 276 276 827 1,240 551 Product Recovery Credit (147) (587) (4,399) (4,399) (4,399) (6,159) 

Total Annual Cost $/yr 679 1,065 (2,748) 556 3,034 (2,855) 

Cost effectiveness without product recovery, $/ton 5,069 2,534 338 1,014 1,521 483 

Cost effectiveness with product recovery, $/ton 4,169 1,634 (562) 114 621 (417) 

Method 27 testing3 (sensitivity analysis)

10 vehicles 1,500 1,500 1,500 1,500 1,500 1,500 

50 vehicles 7,500 7,500 7,500 7,500 7,500 7,500 

100 vehicles 15,000 15,000 15,000 15,000 15,000 15,000 

Cost effectiveness with 100 Method 27 tests per year 96,228 24,649 2,507 3,182 3,689 1,775 

A‐3
.

Table A-1 Continued

Costs for CVS/flare (Option TR2)

Equipment cost of system, 1997 $4 15,910 18,483 18,483 33,660 52,768 24,942 

Purchased equipment cost, 1997$ (PEC = 1.18 x EC) 18,774 21,810 21,810 39,718 62,266 29,432 

Total capital investment, 2010 $5 51,570 59,908 59,908 109,101 171,035 80,845 

Direct annual costs, 2010 $/yr6 47,264 48,663 48,663 54,259 58,456 51,461 

Indirect annual costs, 2010 $/yr 29,242 30,763 30,763 39,736 51,033 34,582 

Total annual cost, $/yr $76,506 $79,426 $79,426 $93,995 $109,489 $86,043 

Cost effectiveness of Option 2 (no Method 27 testing) 280,010 73,001 9,272 11,434 13,607 7,185 

Incremental cost effectiveness, $/ton 678,759 176,166 23,489 27,797 32,379 18,175 

Incremental CE with 100 Method 27 tests per year 811,838 209,436 27,925 32,233 36,815 21,344 

)

A‐4
Table A-1 Continued

Rack and Material Characteristics Emissions and Costs per Model Transfer Rack

Number of arms 1 2 2 6 9 4 

Total annual throughput per rack, million gal/yr 0.5 2 15 15 15 21 

Average throughput per arm, million gal/yr 0.5 1 7.5 2.5 1.6667 5.25 

VOC vapor pressure, psia 1 1 1 1 1 1

Emissions

Uncontrolled VOC emissions, lb/yr 1,390 5,559 41,693 41,693 41,693 58,370 69,4

Uncontrolled emissions, tpy 0.69 2.78 20.85 20.85 20.85 29.19 34

Submerged loading VOC emissions, lb/yr 575 2,300 17,252 17,252 17,252 24,153 28,

Emissions reduction for submerged loading, lb VOC/yr 815 3,259 24,441 24,441 24,441 34,217 40,

Emission reduction for submerged loading, tpy 0.41 1.63 12.2 12.2 12.2 17.1 2

Emissions reduction for CVS/flare, tpy1 0.282 1.127 8.454 8.454 8.454 11.835 14.

Emission stream

VOC flow per arm, lbmole/min 0.00273 0.00273 0.00273 0.00273 0.00273 0.00273 0.00

Total gas flow per arm, lbmole/min 0.067 0.067 0.067 0.067 0.067 0.067 0VOC concentration, ppmv 40,833 40,833 40,833 40,833 40,833 40,833 40

Alternative calc of concentration, ppmv 40,816 40,816 40,816 40,816 40,816 40,816 40

Displaced gas flow rate per arm, acfm 25.40 25.40 25.40 25.40 25.40 25.40 2

Maximum displaced gas flow per rack 25.40 50.80 50.80 152.41 228.61 101.60 25

when all arms are in use, acfm

VOC concentration, ppmv 40,833 40,833 40,833 40,833 40,833 40,833 40

Stream heating value, BTU/scf 129.05 129.05 129.05 129.05 129.05 129.05 129

Minimum rack operating time hr/yr2 Minimum rack operating time, hr/yr 43.86 87.72 657.89 219.30 146.20 460.53 21

Costs for submerged loading (Option TR1)

Total capital investment, $ 4,594 9,187 9,187 27,562 41,343 18,375 45,9

Capital recovery 504 1,009 1,009 3,026 4,539 2,017 5,0

Property taxes, Insurance, Admin (0.04*TCI) 184 367 367 1,102 1,654 735 1,8

Operation and Maintenance (0.03*TCI) 138 276 276 827 1,240 551 1,

Product Recovery Credit (367) (1,466) (10,998) (10,998) (10,998) (15,398) (18,

Total Annual Cost $/yr 459 185 (9,347) (6,043) (3,565) (12,094) (10,0

Cost effectiveness without product recovery, $/ton 2,028 1,014 135 406 608 193 4

Cost effectiveness with product recovery, $/ton 1,128 114 (765) (494) (292) (707) (4

Method 27 testing3 (sensitivity analysis)

10 vehicles 1,500 1,500 1,500 1,500 1,500 1,500 1,

50 vehicles 7,500 7,500 7,500 7,500 7,500 7,500 7,100 vehicles 15,000 15,000 15,000 15,000 15,000 15,000 15,0

Cost effectiveness with 100 Method 27 tests per year 37,951 9,320 463 733 936 170 

A‐5
Table A-1 Continued

Costs for CVS/flare (Option TR2)

Equipment cost of system, 1997 $4 15,910 18,483 18,483 33,660 52,768 24,942 61,

Purchased equipment cost, 1997$ (PEC = 1.18 x EC) 18,774 21,810 21,810 39,718 62,266 29,432 72,

Total capital investment, 2010 $5 51,570 59,908 59,908 109,101 171,035 80,845 198,

Direct annual costs, 2010 $/yr6 47,264 48,663 48,663 54,259 58,456 51,461 59,8

Indirect annual costs, 2010 $/yr 29,242 30,763 30,763 39,736 51,033 34,582 56,0Total annual cost, $/yr $76,506 $79,426 $79,426 $93,995 $109,489 $86,043 $115,9

Cost effectiveness of Option 2 (no Method 27 testing) 111,685 28,881 3,390 4,254 5,124 2,555 3,0

Incremental cost effectiveness, $/ton 271,504 70,466 9,396 11,119 12,952 7,270 8

Incremental CE with 100 Method 27 tests per year 324,735 83,774 11,170 12,893 14,726 8,538 9,

A‐6
Table A-1 Continued

Rack and Material Characteristics Emissions and Costs per Model Transfer Rack

Number of arms 1 2 2 4 8 

Total annual throughput per rack, million gal/yr 0.5 2 15 21 25 

Average throughput per arm, million gal/yr 0.5 1 7.5 5.25 3.125 3

VOC vapor pressure, psia 3 3 3 3 3

Emissions

Uncontrolled VOC emissions, lb/yr 4,169 16,677 125,079 175,111 208,465 333,

Uncontrolled emissions, tpy 2.08 8.34 62.54 87.56 104.23 166Submerged loading VOC emissions, lb/yr 1,725 6,901 51,757 72,460 86,262 138,0

Emissions reduction for submerged loading, lb VOC/yr 2,444 9,776 73,322 102,651 122,204 195,

Emission reduction for submerged loading, tpy 1.22 4.89 36.7 51.3 61.1 9

Emissions reduction for CVS/flare, tpy1 0.845 3.381 25.361 35.505 42.268 67.

Emission stream

VOC flow per arm, lbmole/min 0.00819 0.00819 0.00819 0.00819 0.00819 0.00

Total gas flow per arm, lbmole/min 0.067 0.067 0.067 0.067 0.067 0VOC concentration, ppmv 122,499 122,499 122,499 122,499 122,499 122

Alternative calc of concentration, ppmv 122,449 122,449 122,449 122,449 122,449 122

Displaced gas flow rate per arm, acfm 25.40 25.40 25.40 25.40 25.40 2

Maximum displaced gas flow per rack 25.40 50.80 50.80 101.60 203.21 30

when all arms are in use, acfm

VOC concentration, ppmv 122,499 122,499 122,499 122,499 122,499 122

Stream heating value, BTU/scf 387.14 387.14 387.14 387.14 387.14 387

Minimum rack operating time hr/yr2 Minimum rack operating time, hr/yr 43.86 87.72 657.89 460.53 274.12 29

Costs for submerged loading (Option TR1)

Total capital investment, $ 4,594 9,187 9,187 18,375 36,749 55,

Capital recovery 504 1,009 1,009 2,017 4,035 6,0

Property taxes, Insurance, Admin (0.04*TCI) 184 367 367 735 1,470 2,

Operation and Maintenance (0.03*TCI) 138 276 276 551 1,102 1,

Product Recovery Credit (1,100) (4,399) (32,995) (46,193) (54,992) (87,

Total Annual Cost $/yr (274) (2,748) (31,343) (42,889) (48,384) (78,0

Cost effectiveness without product recovery, $/ton 676 338 45 64 108 

Cost effectiveness with product recovery, $/ton (224) (562) (855) (836) (792) (

Method 27 testing3 (sensitivity analysis)

10 vehicles 1,500 1,500 1,500 1,500 1,500 1,

50 vehicles 7,500 7,500 7,500 7,500 7,500 7,

100 vehicles 15,000 15,000 15,000 15,000 15,000 15,0

Cost effectiveness with 100 Method 27 tests per year 12,050 2,507 (446) (543) (546) (

A‐7
Table A-1 Continued

Costs for CVS/flare (Option TR2)

Equipment cost of system, 1997 $4 15,910 18,483 18,483 24,942 45,424 82,

Purchased equipment cost, 1997$ (PEC = 1.18 x EC) 18,774 21,810 21,810 29,432 53,600 97,

Total capital investment, 2010 $5 51,570 59,908 59,908 80,845 147,231 268,

Direct annual costs, 2010 $/yr6 47,264 48,663 48,663 51,461 57,057 62,

Indirect annual costs, 2010 $/yr 29,242 30,763 30,763 34,582 46,691 68,

Total annual cost, $/yr $76,506 $79,426 $79,426 $86,043 $103,748 $131,

Cost effectiveness of Option 2 (no Method 27 testing) 36,874 9,272 775 497 536 

Incremental cost effectiveness, $/ton 90,501 23,489 3,132 2,423 2,455 1

Incremental CE with 100 Method 27 tests per year 108,245 27,925 3,723 2,846 2,809 2,

A‐8
Table A-1 Continued

Rack and Material Characteristics Emissions and Costs per Model Transfer Rack

Number of arms 1 2 4 2 6 9 

Total annual throughput per rack, million gal/yr 0.5 2 14.25 15 15 15 

Average throughput per arm, million gal/yr 0.5 1 3.563 7.5 2.5 1.667 3

VOC vapor pressure, psia 6 6 6 6 6 6

Emissions

Uncontrolled VOC emissions, lb/yr 8,339 33,354 237,651 250,158 250,158 250,158 416,

Uncontrolled emissions, tpy 4.17 16.68 118.83 125.08 125.08 125.08 208

Submerged loading VOC emissions, lb/yr 3,450 13,802 98,338 103,514 103,514 103,514 172,

Emissions reduction for submerged loading, lb VOC/yr 4,888 19,553 139,312 146,645 146,645 146,645 244,

Emission reduction for submerged loading, tpy 2.44 9.78 69.7 73.3 73.3 73.3 1

Emissions reduction for CVS/flare, tpy1 1.691 6.763 48.186 50.722 50.722 50.722 84.

Emission stream

VOC flow per arm, lbmole/min 0.01639 0.01639 0.01639 0.01639 0.01639 0.01639 0.01

Total gas flow per arm, lbmole/min 0.067 0.067 0.067 0.067 0.067 0.067 0VOC concentration, ppmv 244,999 244,999 244,999 244,999 244,999 244,999 244

Alternative calc of concentration, ppmv 244,898 244,898 244,898 244,898 244,898 244,898 244

Displaced gas flow rate per arm, acfm 25.40 25.40 25.40 25.40 25.40 25.40 2

Maximum displaced gas flow per rack 25.40 50.80 101.60 50.80 152.41 228.61 20

when all arms are in use, acfm

VOC concentration, ppmv 244,999 244,999 244,999 244,999 244,999 244,999 244

Stream heating value, BTU/scf 774.28 774.28 774.28 774.28 774.28 774.28 774

Minimum rack operating time hr/yr2 Minimum rack operating time, hr/yr 43.86 87.72 312.50 657.89 219.30 146.20 27

Costs for submerged loading (Option TR1)

Total capital investment, $ 4,594 9,187 18,375 9,187 27,562 41,343 36,

Capital recovery 504 1,009 2,017 1,009 3,026 4,539 4,0

Property taxes, Insurance, Admin (0.04*TCI) 184 367 735 367 1,102 1,654 1,4

Operation and Maintenance (0.03*TCI) 138 276 551 276 827 1,240 1,

Product Recovery Credit (2,200) (8,799) (62,691) (65,990) (65,990) (65,990) (109,

Total Annual Cost $/yr (1,374) (7,147) (59,387) (64,338) (61,035) (58,557) (103,

Cost effectiveness without product recovery, $/ton 338 169 47 23 68 101 

Cost effectiveness with product recovery, $/ton (562) (731) (853) (877) (832) (799) (8

Method 27 testing3 (sensitivity analysis)

10 vehicles 1,500 1,500 1,500 1,500 1,500 1,500 1,

50 vehicles 7,500 7,500 7,500 7,500 7,500 7,500 7,100 vehicles 15,000 15,000 15,000 15,000 15,000 15,000 15,0

Cost effectiveness with 100 Method 27 tests per year 5,575 803 (637) (673) (628) (594) (

A‐9
Table A-1 Continued

Costs for CVS/flare (Option TR2)

Equipment cost of system, 1997 $4 15,910 18,483 24,942 18,483 33,660 52,768 45,4

Purchased equipment cost, 1997$ (PEC = 1.18 x EC) 18,774 21,810 29,432 21,810 39,718 62,266 53,

Total capital investment, 2010 $5 51,570 59,908 80,845 59,908 109,101 171,035 147,

Direct annual costs, 2010 $/yr6 47,264 48,663 51,461 48,663 54,259 58,456 57,0

Indirect annual costs, 2010 $/yr 29,242 30,763 34,582 30,763 39,736 51,033 46,Total annual cost, $/yr $76,506 $79,426 $86,043 $79,426 $93,995 $109,489 $103,

Cost effectiveness of Option 2 (no Method 27 testing) 18,171 4,370 226 122 266 411 

Incremental cost effectiveness, $/ton 45,251 11,744 1,786 1,566 1,853 2,159 1

Incremental CE with 100 Method 27 tests per year 54,123 13,962 2,097 1,862 2,149 2,454 1,4

A‐10
ATTACHMENT B:  IMPACTS FOR CONTROL OPTIONS TR3 AND TR4
Table B-1. Estimated Impacts of Control Options TR3 and TR4 for Model Transfer Racks That Load Contain

Rack and Material Characteristics Emissions and Costs per Model Transfer Rack

# of filling stations 1 1 1 1 1

Total annual throughput per rack, 103 gal/yr1 2 10 100 1,000 2,250 

Total 55 gallon drums/yr 37 182 1819 18182 40910 

Total 550 gallon drums/yr 4 19 182 1819 4091 

Reid Vapor Pressure 1.5 1.5 1.5 1.5 1.5 

Emissions

Uncontrolled VOC emissions (method 1), lb/yr2 0.54 2.70 26.99 269.85 607.17 

Uncontrolled VOC emissions (method 1), tpy2 0.000270 0.001349 0.01349 0.1349 0.30359 

Controlled emissions (submerged fill), lb/yr 0.37 1.84 18.40 183.99 413.98 

Controlled emissions (submerged fill), tpy 0.000184 0.000920 0.00920 0.0920 0.2070 Controlled emissions (flare), lb/yr 0.007 0.037 0.368 3.680 8.280 

Controlled emissions (flare), tpy 0.00000368 0.00001840 0.00018399 0.0018399 0.0041398 0

Emissions reduction (submerged fill), lb/yr 0.17 0.86 8.59 85.86 193.19 

Emissions reduction (flare), lb VOC/yr 0.36 1.80 18.03 180.31 405.70 

Total emissions reduction, lb/yr 0.53 2.66 26.62 266.17 598.89 

Emissions reduction (submerged fill), tpy 0.00009 0.00043 0.00429 0.04293 0.09660 

Emission reductions (flare), tpy 0.00018 0.00090 0.00902 0.09016 0.20285 

Total emissions reduction, tpy 0.00027 0.00133 0.01331 0.13309 0.29945 

Uncontrolled VOC emissions (method 2), lb/yr3 2.02 10.12 101.2 1,012 2,277 

Uncontrolled VOC emissions (method 2), tpy3 0.001012 0.005061 0.05061 0.5061 1.1387 

Controlled emissions (submerged fill), lb/yr 1.38 6.90 69.01 690.09 1552.71 

Controlled emissions (submerged fill), tpy 0.000690 0.003450 0.03450 0.3450 0.7764 Controlled emissions (flare), lb/yr 0.03 0.14 1.38 13.80 31.05 

Controlled emissions (flare), tpy 0.00001380 0.00006901 0.00069009 0.0069009 0.015527 0

Emissions reduction (submerged fill), lb/yr 0.64 3.22 32.20 322.04 724.60 1Emissions reduction (flare), lb VOC/yr 1.35 6.76 67.63 676.29 1,521.65 2Total emissions reduction, lb/yr 2.00 9.98 99.83 998.33 2,246.25 3

Emissions reduction (submerged fill), tpy 0.00032 0.00161 0.01610 0.16102 0.36230 

Emission reductions (flare), tpy 0.00068 0.00338 0.03381 0.33815 0.76083 

Total emissions reduction, tpy 0.00100 0.00499 0.04992 0.49917 1.12313 

Emission stream

Displaced gas flow rate per filling station 1.34 1.34 1.34 1.34 1.34 

Maximum displaced gas flow per rack 1.34 1.34 1.34 1.34 1.34 

when all filling stations are in use, acfm

Maximum rack operating time, hr/yr4 3 17 167 1,667 3,750 

B‐1
v

Table B-1 Continued

Capital costs and other costs

Total installed cost and planning (submerged fill), $5 3,958 3,958 3,958 3,958 3,958 

Total capital investment for flare system, $6 44,745 44,745 44,745 44,745 44,745 

Annual costs, $/yr

submerged fill7 711 710 697 567 386 

flare8 $79,897 $79,897 $79,897 $79,897 $79,897 $

Method 27 testing (100 containers)9 $17,500 $17,500 $17,500 $17,500 $17,500 $

Cost effectiveness, $/ton

Submerged fill 2,208,834 441,047 43,295 3,519 1,064 

Sumerged fill and M27 testing 212,098,316 42,416,963 4,238,658 420,828 185,159 1Flare incremental‐‐Emissions Method 1 443,106,380 88,621,276 8,862,128 886,213 393,872 

Flare incremental‐‐emissions Method 2 118,140,475 23,628,095 2,362,809 236,281 105,014 

Overall (Submerged fill and flare) 80,743,171 16,148,402 1,614,579 161,197 71,482 

Emissions ratio (Method 1/Method 2) 0.27 0.27 0.27 0.27 0.27 

InputsTemperature, F 60

Molecular weight 80

Saturation factor for splash fill 0.88

Saturation factor for submerged fill 0.6

Flare Control Efficiency (%) 98

Average container fill rate10 600

1Range of throughputs is from facility responses to ICR for the Organic Liquids Distribution NESHAP and summarized in the model plants memo in the TSD.

Lowest throughputs may be for racks that fill small containers as well as large containers.

2Calculated using equation for estimating emissions from vehicle refueling as described in baseline emissions memorandum for the Organic Liquid Distribution3Calculated assuming displaced vapor is 88 percent saturated (This results in equivalent emissions for the two options when RVP is 3.37 psia, as in OLD analysis)

Also assumed true vapor pressure at 60F is 40% of RVP (high for pure components; low for gasoline).

4Time would be lower if some racks actually have more than one filling station (maximum flow to the flare also would be higher).

5Assumed cost for drop tube can be scaled from the cost for the transport vehicle scenario based on the six‐tenths rule with the total mass of material in the dr

tube as the scaling parameter. Assumed one station per rack, and assume the total mass for the container loading scenario is half the mass for the transport

overstated. Assumed containers are already equipment with the necessart closure devices so that this design requirement would add no costs.

6Calculated by extrapolating equipment costs for flare system used in OLD cost analysis, with same instrumentation and installation factprs, and scaling up from

to 2010 dollars using the CEPCI.

7Includes capital recovery (15 year life, 7% interest); operation and maintenance (3% of TCI); property tax, insurance, and administration (4% of TCI), and produ

($900/ton). Assumed 10 hours engineering labor for planning ($92.72/hr, loaded with management and clerical labor).

8Annual costs estimated as in OLD analysis; labor costs escalated by 45 percent (similar to the equipment cost increase).9No information available on the fee to conduct testing of containers. Therefore, cost was assumed to be $175, or half of the fee for transport vehicles because

the smaller size.

10 gal/hr (assuming containers filled using nozzles like vehicle refueling pumps and with similar flow rate)

B‐2
Table B-1 Continued

Rack and Material Characteristics Emissions and Costs per Model Transfer Rack

# of filling stations 1 1 1 1 1

Total annual throughput per rack, 103 gal/yr1 2 10 100 1,000 2,250 3

Total 55 gallon drums/yr 37 182 1819 18182 40910 63

Total 550 gallon drums/yr 4 19 182 1819 4091 6

Reid Vapor Pressure 2 2 2 2 2

Emissions

Uncontrolled VOC emissions (method 1), lb/yr2 1.61 8.04 80.45 804.47 1,810.06 2,815

Uncontrolled VOC emissions (method 1), tpy2 0.000804 0.004022 0.04022 0.4022 0.9050 1.4

Controlled emissions (submerged fill), lb/yr 1.10 5.49 54.85 548.50 1,234.13 1,919

Controlled emissions (submerged fill), tpy 0.000549 0.002743 0.02743 0.2743 0.6171 0.9

Controlled emissions (flare), lb/yr 0.022 0.110 1.097 10.970 24.683 38Controlled emissions (flare), tpy 0.00001097 0.00005485 0.00054850 0.00548502 0.01234130 0.01919Emissions reduction (submerged fill), lb/yr 0.51 2.56 25.60 255.97 575.93 89

Emissions reduction (flare), lb VOC/yr 1.08 5.38 53.75 537.53 1,209.45 1,881

Total emissions reduction, lb/yr 1.59 7.93 79.35 793.50 1,785.37 2,777

Emissions reduction (submerged fill), tpy 0.00026 0.00128 0.01280 0.12798 0.28796 0.44

Emission reductions (flare), tpy 0.00054 0.00269 0.02688 0.26877 0.60472 0.94

Total emissions reduction, tpy 0.00079 0.00397 0.03967 0.39675 0.89269 1.38

Uncontrolled VOC emissions (method 2), lb/yr3 2.70 13.50 135.0 1,350 3,036 4

Uncontrolled VOC emissions (method 2), tpy3 0.001350 0.006748 0.06748 0.6748 1.5182 2.3

Controlled emissions (submerged fill), lb/yr 1.84 9.20 92.01 920.12 2070.28 322

Controlled emissions (submerged fill), tpy 0.000920 0.004601 0.04601 0.4601 1.0351 1.6

Controlled emissions (flare), lb/yr 0.04 0.18 1.84 18.40 41.41 6

Controlled emissions (flare), tpy 0.00001840 0.00009201 0.00092012 0.0092012 0.020703 0.032Emissions reduction (submerged fill), lb/yr 0.86 4.29 42.94 429.39 966.13 150

Emissions reduction (flare), lb VOC/yr 1.80 9.02 90.17 901.72 2028.87 315

Total emissions reduction, lb/yr 2.66 13.31 133.11 1331.11 2995.00 465

Emissions reduction (submerged fill), tpy 0.00043 0.00215 0.02147 0.21470 0.48306 0.75

Emission reductions (flare), tpy 0.00090 0.00451 0.04509 0.45086 1.01444 1.57

Total emissions reduction, tpy 0.00133 0.00666 0.06656 0.66556 1.49750 2.32

Emission stream

Displaced gas flow rate per filling station 1.34 1.34 1.34 1.34 1.34 

Maximum displaced gas flow per rack 1.34 1.34 1.34 1.34 1.34 

when all filling stations are in use, acfm

Maximum rack operating time, hr/yr4 3 17 167 1,667 3,750 5

B‐3
Table B-1 Continued

Capital costs and other costs

Total installed cost and planning (submerged fill), $5 3,958 3,958 3,958 3,958 3,958 3,

Total capital investment for flare system, $6 44,745 44,745 44,745 44,745 44,745 44,

Annual costs, $/yr

submerged fill7 711 710 692 518 277 

flare8 $79,897 $79,897 $79,897 $79,897 $79,897 $79,

Method 27 testing (100 containers)9 $17,500 $17,500 $17,500 $17,500 $17,500 $17,

Cost effectiveness, $/ton

Submerged fill 1,656,401 330,560 32,246 2,415 573 

Sumerged fill and M27 testing 71,146,657 14,228,124 1,421,454 140,787 61,733 39,

Flare incremental‐‐Emissions Method 1 148,637,223 29,727,445 2,972,744 297,274 132,122 84

Flare incremental‐‐emissions Method 2 88,605,356 17,721,071 1,772,107 177,211 78,760 50

Overall (Submerged fill and flare) 60,557,306 12,111,229 1,210,862 120,825 53,539 34

Emissions ratio (Method 1/Method 2) 0.60 0.60 0.60 0.60 0.60 

B‐4
Table B-1 Continued

Rack and Material Characteristics Emissions and Costs per Model Transfer Rack

# of filling stations 1 1 1 1 1

Total annual throughput per rack, 103 gal/yr1 2 10 100 1,000 2,250 3

Total 55 gallon drums/yr 37 182 1819 18182 40910 6

Total 550 gallon drums/yr 4 19 182 1819 4091 

Reid Vapor Pressure 3.37 3.37 3.37 3.37 3.37 

Emissions

Uncontrolled VOC emissions (method 1), lb/yr2 4.54 22.69 226.93 2,269 5,106 7

Uncontrolled VOC emissions (method 1), tpy2 0.002269 0.01135 0.1135 1.1347 2.5530 3.

Controlled emissions (submerged fill), lb/yr 3.09 15.47 154.73 1,547 3,481 5

Controlled emissions (submerged fill), tpy 0.001547 0.007736 0.07736 0.7736 1.741 2

Controlled emissions (flare), lb/yr 0.062 0.309 3.095 30.945 69.627 108

Controlled emissions (flare), tpy 0.00003095 0.00015473 0.0015473 0.015473 0.034813 0.0

Emissions reduction (submerged fill), lb/yr 1.44 7.22 72.21 722.06 1,624.62 2,52

Emissions reduction (flare), lb VOC/yr 3.03 15.16 151.63 1,516 3,412 5

Total emissions reduction, lb/yr 4.48 22.38 223.84 2,238 5,036 7

Emissions reduction (submerged fill), tpy 0.00072 0.00361 0.03610 0.36103 0.81231 1.

Emission reductions (flare), tpy 0.00152 0.00758 0.07582 0.75816 1.7059 2.

Total emissions reduction, tpy 0.00224 0.01119 0.11192 1.1192 2.5182 3.

Uncontrolled VOC emissions (method 2), lb/yr3 4.55 22.7 227 2,274 5,116 7

Uncontrolled VOC emissions (method 2), tpy3 0.002274 0.01137 0.1137 1.1370 2.5582 3.

Controlled emissions (submerged fill), lb/yr 3.10 15.50 155.04 1,550.41 3,488.42 5,42

Controlled emissions (submerged fill), tpy 0.001550 0.007752 0.07752 0.7752 1.744 2

Controlled emissions (flare), lb/yr 0.06 0.31 3.10 31.01 69.77 10

Controlled emissions (flare), tpy 0.00003101 0.00015504 0.0015504 0.015504 0.034884 0.0

Emissions reduction (submerged fill), lb/yr 1.45 7.24 72.35 723.52 1,627.93 2,53

Emissions reduction (flare), lb VOC/yr 3.04 15.19 151.94 1,519.40 3,418.65 5,31

Total emissions reduction, lb/yr 4.49 22.43 224.29 2,242.92 5,046.58 7,85

Emissions reduction (submerged fill), tpy 0.00072 0.00362 0.03618 0.36176 0.81396 1.2

Emission reductions (flare), tpy 0.00152 0.00760 0.07597 0.75970 1.70932 2.6

Total emissions reduction, tpy 0.00224 0.01121 0.11215 1.12146 2.52329 3.9

Emission stream

Displaced gas flow rate per filling station 1.34 1.34 1.34 1.34 1.34 

Maximum displaced gas flow per rack 1.34 1.34 1.34 1.34 1.34 

when all filling stations are in use, acfm

Maximum rack operating time, hr/yr4 3 17 167 1,667 3,750 5

B‐5
Table B-1 Continued

Capital costs and other costs

Total installed cost and planning (submerged fill), $5 3,958 3,958 3,958 3,958 3,958 3

Total capital investment for flare system, $6 44,745 44,745 44,745 44,745 44,745 44

Annual costs, $/yr

submerged fill7 711 708 679 386 (21) 

flare8 $79,897 $79,897 $79,897 $79,897 $79,897 $79

Method 27 testing (100 containers)9 $17,500 $17,500 $17,500 $17,500 $17,500 $17

Cost effectiveness, $/ton

Submerged fill 982,661 195,812 18,771 1,067 (26) 

Sumerged fill and M27 testing 25,221,034 5,043,485 503,537 49,542 21,518 13

Flare incremental‐‐Emissions Method 1 52,691,710 10,538,342 1,053,834 105,383 46,837 30

Flare incremental‐‐emissions Method 2 52,584,781 10,516,956 1,051,696 105,170 46,742 30

Overall (Submerged fill and flare) 35,938,936 7,187,555 718,494 71,588 31,656 20

Emissions ratio (Method 1/Method 2) 1.00 1.00 1.00 1.00 1.00 

B‐6
Table B-1 Continued

Rack and Material Characteristics

# of filling stations 1 1 1 1 1

Total annual throughput per rack, 103 gal/yr1 2 10 100 1,000 2,250 3

Total 55 gallon drums/yr 37 182 1819 18182 40910 6

Total 550 gallon drums/yr 4 19 182 1819 4091 

Reid Vapor Pressure 8 8 8 8 8

Emissions

Uncontrolled VOC emissions (method 1), lb/yr2 14.44 72.20 721.99 7,220 16,245 25

Uncontrolled VOC emissions (method 1), tpy2 0.007220 0.03610 0.36099 3.6099 8.1223 12

Controlled emissions (submerged fill), lb/yr 9.85 49.23 492.26 4,922.6 11,076 17

Controlled emissions (submerged fill), tpy 0.004923 0.02461 0.2461 2.461 5.538 8

Controlled emissions (flare), lb/yr 0.197 0.985 9.845 98.453 221.518 344

Controlled emissions (flare), tpy 0.00009845 0.00049226 0.0049226 0.04923 0.11076 0.1Emissions reduction (submerged fill), lb/yr 4.59 22.97 229.72 2,297.23 5,168.76 8,04

Emissions reduction (flare), lb VOC/yr 9.65 48.24 482.42 4,824.18 10,854.40 16,88

Total emissions reduction, lb/yr 14.24 71.21 712.14 7,121.40 16,023.16 24,92

Emissions reduction (submerged fill), tpy 0.00230 0.01149 0.11486 1.14861 2.58438 4.0

Emission reductions (flare), tpy 0.00482 0.02412 0.24121 2.41209 5.42720 8.4

Total emissions reduction, tpy 0.00712 0.03561 0.35607 3.56070 8.01158 12.4

Uncontrolled VOC emissions (method 2), lb/yr3 10.80 53.98 539.8 5,398 12,146 18

Uncontrolled VOC emissions (method 2), tpy3 0.005398 0.02699 0.26990 2.6990 6.0728 9

Controlled emissions (submerged fill), lb/yr 7.36 36.80 368.05 3680.49 8281.11 1288Controlled emissions (submerged fill), tpy 0.003680 0.01840 0.1840 1.840 4.141 6

Controlled emissions (flare), lb/yr 0.15 0.74 7.36 73.61 165.62 25

Controlled emissions (flare), tpy 0.00007361 0.00036805 0.0036805 0.03680 0.08281 0.1Emissions reduction (submerged fill), lb/yr 3.44 17.18 171.76 1,717.56 3,864.52 6,01Emissions reduction (flare), lb VOC/yr 7.21 36.07 360.69 3,606.88 8,115.49 12,62

Total emissions reduction, lb/yr 10.65 53.24 532.44 5,324.45 11,980.00 18,63

Emissions reduction (submerged fill), tpy 0.00172 0.00859 0.08588 0.85878 1.93226 3.0

Emission reductions (flare), tpy 0.00361 0.01803 0.18034 1.80344 4.05774 6.3

Total emissions reduction, tpy 0.00532 0.02662 0.26622 2.66222 5.99000 9.3

Emission stream

Displaced gas flow rate per filling station 1.34 1.34 1.34 1.34 1.34 

Maximum displaced gas flow per rack 1.34 1.34 1.34 1.34 1.34 

when all filling stations are in use, acfm

Maximum rack operating time, hr/yr4 3 17 167 1,667 3,750 5

B‐7
Table B-1 Continued

Capital costs and other costs

Total installed cost and planning (submerged fill), $5 3,958 3,958 3,958 3,958 3,958 3

Total capital investment for flare system, $6 44,745 44,745 44,745 44,745 44,745 44

Annual costs, $/yr

submerged fill7 710 704 634 (61) (1,027) (1

flare8 $79,897 $79,897 $79,897 $79,897 $79,897 $79

Method 27 testing (100 containers)9 $17,500 $17,500 $17,500 $17,500 $17,500 $17

Cost effectiveness, $/ton

Submerged fill 309,105 61,283 5,523 (53) (398) 

Sumerged fill and M27 testing 7,926,985 1,584,859 157,880 15,182 6,374 3

Flare incremental‐‐Emissions Method 1 16,561,848 3,312,370 331,237 33,124 14,722 9

Flare incremental‐‐emissions Method 2 22,151,339 4,430,268 443,027 44,303 19,690 12

Overall (Submerged fill and flare) 11,319,028 2,263,632 226,168 22,421 9,844 6

Emissions ratio (Method 1/Method 2) 1.34 1.34 1.34 1.34 1.34 

B‐8