## MEMORANDUM

**DATE:** February 9 , 201 5 **SUBJECT:** Revised Technology Review for the Off

- Site Waste and Recovery Operations Equipment Leaks **FROM:** Lesley

Stobert, EC/R Inc. **TO:** Paula Hirtz, EPA/OAQPS/SPPD
The EPA proposed amendments to off

- site waste and recovery

operations (OSWRO) national emissions standards for hazardous air pollutants (NESHAP) on July 2, 2014 , based on residual risk and technology review s conducted for the source category

. The purpose of this memorandum is to present a revised anal ys is related to the technology review for equipment leaks at OSWRO facilities , considering comments submitted during the public comment period for the proposed OS WRO NESHAP amendments. **1.0 INTRODUCTION**  On July 2, 2014 (79 FR 37850), the EPA proposed amendments to the OSWRO source category following the results of a review required b y s ection 112(d)(6) of the CAA, which directs the EPA to review previously

issued NESHAP regulations and to revise them as necessary (taking into account developments in practices, processes and control technologies) no less frequently than every

8 years. Section 112(f)(2) of the CAA requires the EPA to assess, within 8 years of promul gation of the original NESHAP for major sources and area sources subject to MACT, the remaining risks due to emissions of HAP from these source categories and determine whether the emissions standards provide an ample margin of safety

to protect public health. These reviews are collectivel y referred to as residual risk and technology

reviews (RTRs). For the July 2014 proposal, a technology review for equipment leaks at O SWRO facilities was conducted. Potential developments in practices, processes and control technologies were identified through the review of subsequent air toxics regulations and the proposed National Uniform Emission Standards for Storage Vessels and Transfer Operations, Equipment L eaks, and Closed Vent Systems and Control Devices (“Uniform Standards”), which were proposed on March 26, 2012. Under CAA section 112(d)(6), the EPA proposed to re quire facilities to follow the m ore stringent leak detection and repair (LDAR) program of 40 CFR part 63, subpart H rather than allowing facilities the choice of complying with either the requirements of that rule or with 40 CFR part 61, subpart V. Following the July

2014 proposal, the EPA received comments from one industry trade association and two companies challenging some of the data and assumption s used in the analy sis of emissions reduction s and costs associated with the LDAR program of 40 CFR part 63, subpart H . We have considered these comments and conducted an analy sis to determine the impacts of these comments on our previousl y estimated emiss ions reductions and costs associated with compliance with 40 CFR part

### 2



## 63, subpart H over the emissions reductions and costs associated with compliance with 40 CFR part 61, subpart V. **2 .**  **0 EQUIPMENT LEAKS**  **RE**
**- ANALYSIS**  2.1 Equipment L eaks at OSWRO Facilities Equipment leaks are emissions emanating from leaking pieces of equipment, such as pumps, compressors, agitators, pressure relief devices, sampling connection sy stems, open
- ended valves or lines, valves, connectors, surge control vessels, bottom s receivers, and instrumentation sy stems in organic HAP service; and any control devices or systems required by subpart DD for these pieces of equipment. The amount of HAP emissions from equipment leaks is proportional to the ty pe and number of pieces of e quipment and the concentration of HAP constituents of the stream passing through the equipment. 2.2 Summary

of Existing MACT L evel of Control The OSWRO MACT standards for equipment leaks apply to the group of all equipment that contains or contacts off

- site material having a total HAP concentration of 10 percent by weight or more and intended to operate in off

- site material service for 300 hours or more during a calendar ye ar. 1 

## For all of the equipment subject to the standards , the owner or operator must compl y with the LD AR requirements of either 40 CF R part 61, subpart V or 40 CFR part 63, subpart H. The primary provisions of these subparts are shown in Table 1

.

1 

### In off

-site material service is defined in subpart DD (§63. 681 ) essentially as any time a piece of equipment either contains or contacts off

- site material

.

### 3



## Table **1 . Primary Provisions from Part 61,**  **S ubpart V and Part 63,**  **S ubpart H**  **Equipment Type**  **40 CFR part 61 s**  **ubpart V 40 CFR part 63**  **s ubpart H**  Valves in gas /vapor service and light liquid service C onduct EPA Method 21 monitoring

and leak definition of 10,000 ppm (monthly or less often up to quarterl y depending on leak rate) Same as p art 61, s ubpart V but with leak definition of 500 ppm (monthly or less often up to annually depending on leak rate) Pumps in light liquid service Conduct monthly EPA Method 21 monito ring and a leak definition of

10,000 ppm Same as p art 61, s ubpart V but with leak definition of 1,000 ppm and repair required at 2,000 ppm Connectors in gas/vapor and light liquid service Sensory monitoring (visual, audible, olfactory) (ty pe of service is not specified, no monitoring schedule specified) Conduct EPA Method 21 monitoring with leak definition of 500 ppm annually

(or less often up to once every

4 years depending on leak rate) Pressure relieve devices in gas/vapor service Operate with no detec table

emissions (i.e., less than 500 ppm above background) or equipped with a rupture disk or routed to an air pollution control device Same as p art 61, s ubpart V
Open

- ended valves or lines Equip with a cap, blind flange, plug or second valve Same as p art 61, s ubpart V
2.3 Proposed Standard for Equipment L eaks At proposal, during our review of regulatory development efforts for other rules, we found LDAR programs that incorporate more stringent leak detection limits than the OSWRO MACT standard. L eak definitions of 500 parts per million (ppm) for valves in gas and vapor and in light liquid service, 1,000 ppm for pumps in light liquid service and 500 ppm for connectors in gas and vapor and in light liquid service are the leak definitions currently required for facilities subject to certain existing rules and were considered as regulatory

options for the proposed Uniform Standards for equipment leaks. These leak definitions are the same as those required b y 40 CFR part 63 , subpart H. Consequently , we identified the more stringent leak definitions of the subpart H LDAR program as a development in practices, processes or control technologies. We also identified two options for implementing the requirements of the subpart H LDAR program. As it is possible that it may be cost effective to monitor only certain equipment at certain levels, Option 1 included switching from a subpart V LDAR program to a subpart H LDAR program, without the subpart H monitoring requirements for connectors in gas/vapor and light liquid service. Option 2 included switching from a subpart V LDAR program to a subpart H LDAR program, with the subpart H monitoring requirements for connectors in gas/vapor and light liquid service. We estimated the costs and emissions reduction of both options based on information received from the industry as part of a CAA section 114 survey and on information used in the technology review analysi s for the Uniform Standards for equipment leaks. Based on the estimate d control costs and emissions reductions from this analy sis , we proposed to require equipment leaks Option 2.

### 4



## 2

. 4 Revised Estimation of Emissions Reductions and Costs of a 40 CFR part 63, subpart H LDAR Program Seals on a gitators in gas/vapor servic e and in light liquid service are required by 40 CFR part 63, subpart H to be monitored monthly using Method 21 ; 40 CFR part 61, subpart V has no requirements for agitators. At proposal, we did not consider the requirements for agitators to be among the primary provisions of 40 CFR p art 63, subpart H , and we did not include the emissions reductions or the costs of including an LDAR program in our anal ys is of the 40 CFR part 63, subpart H LDAR program. Based on comments received during the public comment period regarding the proposed revised equipment leak requirements from Clean Harbors, a company with several OSWRO facilities, w e have revise d our anal ys is of the costs of an LDAR program with the more stringent leak d efinitions of 40 CFR p art 63, subpart H to include monitoring of agitators under both Options 1 and 2

. Table 2 presents a summary of the equipment leak options that were include d in the revised anal ys is

. Other ty pes of equipment not included in this table are largel y the same under 40 CFR part 61, subpart V and 40 CFR part 63, subpart H, and were not analyzed in this comparison of emissions reductions and costs for Options 1 and 2. **Tab le**  **2 . Summary of Equipment Leak Options**  **for the OSWRO Source Category**
**Type of Equipment**  **Subpart V**

**(Baseline) Alternative Options**  **Subpart H w/o connectors**  **(Option 1) Subpart H**  **w/connectors (Option 2)** 

Pumps Monthly

Method 21 monitoring; leak definition of 10,000 ppm Monthly Method 21 monitoring; leak definition of 1,000 ppm (repair at 2,000 ppm) Monthly Method 21 monitoring; leak definition of 1,000 ppm (repair at 2,000 ppm) Valves Monthly

Method 21 monitoring; leak definition of 10,000 ppm Monthly Method 21 monitoring; leak definition of 500 ppm Monthly Method 21 monitoring; leak definition of 500 ppm
Connectors Sensory

m onitoring Sensory m onitoring Instrument monitoring for

connectors in gas/vapor and light liquid service at 500 ppm Agitators No requirements Monthly Method 21 monitoring; leak definition of 10,000 ppm Monthly Method 21 monitoring; leak definition of 10,000 ppm We estimated emissions reductions and costs for the two control options using a model plant approach to represent equipment counts found at OSWRO facilities. The median number of pieces of equipment was estimated from the reported data available from the O SWRO CAA section 114 survey

. Table 3 presents the median model plant equipment counts for estimating equipment leak impacts from the OSWRO source category

.

### 5 

## Table **3 . Model Plant for OSWRO**  **Equipment Type**  **Number of Pieces of Equipment**  **a** 

## Pumps (light liquid service) 27 Valves (light liquid service) b 

## 910 Connectors ( in gas/vapor and light liquid service) 1,350 Agitators (in gas/vapor and light liquid service) 9

a 

### The number of pieces of equipment is based on the median value reported by facilities in responses to the OSWRO CAA section 114 survey. b 

### The type of service a valve was in (gas/vapor or light liquid) was not discernible from the CAA section 114 survey responses, and based on the process types present at OSWRO facilities , it was assumed the r eported valves were in light liquid service



### . 

## Next , using the number of pieces of equipment in Table 3, emission factors were applied to determine the baseline emissions and the emissions under Options 1 and 2 that would be expected by equipment ty pe. For the baseline, we assumed facilities are complying with 40 CFR part 61, subpart V based on information from the section 114 questionnaire responses, which indicate that most facilities comply with this option. The emission factors were multiplied by the number of pieces of equipment of that ty pe at the OSWRO model plant and converted to tons per year (tp y) to arrive at the total emissions in tpy at the baseline (40 CFR part 61, subpart V) and for Options 1 and 2 (40 CFR part 63, subpart H with out and with co nnector monitoring). These emissions factors were based on those used in the proposed Uniform Standards for equipment leaks anal ys is, but because the factors used in that anal ys is are for total organic compounds, which for OSWRO facilities are generall y volatile organic compounds (VOC), these factors were modified to reflect the amount of VOC that are expected to be HAP. The VOC emission factors were adjusted to HAP emission factors using the HAP to VOC ratio of 82 percent for equipment leaks from the OSWRO MACT development Background Information Document (BID )

. 2 

## The resulting emissions factors used for the OSWRO source category are shown in Table 4

. **Table 4**  **. Equipment Leak HAP Emission Factors by Equipment Type**  **3** 

## Type of Equipment **Emission Factor (kg/hr/ equipmen**  **t piece**  **) Baseline**  **Option 1/Option 2**  Pump Seals

– Li ght Liquid Service 2.05 E

- 03 5.69 E

- 04 Valves

– Li ght Liquid Service 3

. 19 E

- 04 1. 90 E

- 04 Connectors

– Gas/Vapor and Light Liquid Service 2. 51 E

- 04 2.51 E

- 04 /1.33 E

- 0 4 Agitators

– Gas/Vapor and Light Liquid Service 1.01 E

- 0 2 2.05E

- 03 To determine the costs of the LDAR program at the baseline and for Options 1 and 2, the approach taken was the approach used for the proposed Uniform Standards for equipment leaks anal ys is. In determining the costs for the OSWRO source category , the same leak rates, repair times, labor charges and other administrative and miscellaneous costs were assumed (see Appendix 1 for more detailed cost in formation). Table 5 shows the costs and cost effectiveness b y equipment types and as a total for all four equipment types for each option. The cost effectiveness of Option 1 is $ 1,426 , and for Option 2 the

2 

### Off

- Site Waste and Recovery Operations Background Information for Proposed Standards. EPA

- 453/R

- 94

- 070a . September 1994. 3 

### See Table 6 of Memorandum from Hancy, C., RTI International, to Howard, J., EPA/OAQPS. Analysis of Emission Reduction Techniques for Equipment Leaks. December 21, 2011. EPA Docket No. EPA

- HQ

- OAR

- 2010

- 0869

- 0029. A HAP to VOC ratio of 0.82:1 was applied to thes e Table 6 values.

### 6



## cost effectiveness is $3, 598 . The incremental cost effectiveness of Option 2 compared to Option 1 is $6,715. **Table 5**  **. Summary of Cost Effectiveness Analysis for Pumps,**  **Valves ,**  **Connectors and Agitators** 

**Baseline (subpar**  **t V) a**  **Optio n 1**  **(subpar t**  **H, w /o**  **co nnecto**  **rs )**  **b Optio**  **n 2**

**(subpar t H,**  **w/ co**  **nnecto rs**  **) c**  **Baseline**

**(subpar t V)**  **a Optio**  **n 1 (subpar**  **t H, w**  **/o co**  **nnecto rs**  **) b**  **Optio n**  **2**

**(subpar t**  **H, w/**  **co nnecto**  **rs )**  **c** HA P E missi ons d 0.5 26.2 HA P E missi on Reducti

on From Basel

in e -- -- To tal C api tal C ost $877 $42,985 Capi tal Cost A bove Basel

in e -- -- Annual iz ed Cost $2,358 $115,531.76 Annual iz ed Cost A

bove Basel

in e -- -- Cost Effecti

veness -- -- HA P E missi ons d 2.8 137.4 HA P E missi on Reducti

on From Basel

in e -- -- To tal C api tal C ost $224 $10,968 Capi tal Cost A bove Basel

in e -- -- Annual iz ed Cost $3,218 $157,705 Annual iz ed Cost A

bove Basel

in e -- -- Cost Effecti

veness -- -- HA P E missi ons d 3.3 3.3 1.7 160.4 160.4 84.7 HA P E missi on Reducti

on From Basel

in e -- -- 1.5

-- -- 75.8 To tal C api tal C ost
-- -- $34,186

-- -- $1,675,099 Capi tal Cost A bove Basel

in e -- -- $34,186

-- -- $1,675,099 Annual iz ed Cost

-- -- $10,384

-- -- $508,838 Annual iz ed Cost A

bove Basel

in e -- -- $10,384

-- -- $508,838 Cost Effecti

veness -- -- $6,715

-- -- $6,715 HA P E missi ons 0.87 42.9 HA P E missi on Reducti

on From Basel

in e -- -- To tal C api tal C ost
-- -- Capi tal Cost A bove Basel

in e -- -- Annual iz ed Cost

-- -- Annual iz ed Cost A

bove Basel

in e -- -- Cost Effecti

veness -- -- HA P E missi ons 7.5 5.3 3.7 366.9 258.2 182.4 HA P E missi on Reducti

on From Basel

in e -- 2.2 3.8

-- 108.7 184.5 To tal C api tal C ost $1,101 $9,542 $43,727 $53,953 $467,543 $2,142,642 Incremental

Emissi on Reducti

on (basel in e  opti

on 1, opti on 1-->2) -- 2.2 1.5

-- 108.7 75.8 Capi tal Cost A bove Basel

in e -- $8,441 $42,626

-- $413,590 $2,088,689 Annual iz ed Cost $5,576 $8,742 $19,126 $273,237 $428,354 $937,192 Annual iz ed Cost A

bove Basel

in e -- $3,166 $13,550

-- $155,117 $663,955 Cost Effecti

veness -- $1,426 $3,598

-- $1,426 $3,598 Incremental

C ost Effecti

veness (basel in e  opti

on 1, opti on 1-->2) -- $1,426 $6,715

-- $1,426 $6,715

a B aselin e is a ssociated wi th 40 CFR part 61, subpart V compl iance requi

red by subpart DD (pumps:10,000 ppm, val ves:10,000 ppm, connectors:sensory moni tori ng, ag it ators: no requi

rements). bOpti on 1 is associ

ated wi th 40 CFR part 63, subpart H l evel of control

for pumps, val

ves and ag

it ators onl y (pumps:2,000 ppm, val ves:500 ppm, ag

it ators: 10,000 ppm).
cOpti on 2 is associ

ated wi th 40 CFR part 63,subpart H l evel of control

for pumps, val

ves, agit ators and connectors (pumps:2,000 ppm, val ves:500 ppm, ag

igators: 10,000 ppm) and i

nstrument moni

tori ng for connectors at 500 ppm. dC api tal c osts are the i

ni tial moni tori ng c osts. $4,009 $808

$3,059

Connectors **Mo de**  **l Plan**  **t Ty** **pe o f**  **equipment Co**  **st Par ameter** 

To tal LDA R Prog ram Costg Pumps inlight liq ui d servi ce

Valv es i n l ight liq ui d servi ce 0.1

$602 $684 0.4 $4,886 $3,166 $2,087 1.7 $160,866 $149,898 $191,197 $33,491.60 1.1 $3,283 $3,902 $155,126 $39,594 $2,087 81.7 55.7 **OS WRO**  **Sou rc**  **e Cat**  **eg or**  **y (49 F** **aci lit**  **ie s)** 

7.3 19.0 $239,437 $196,452

$602

Agitators $1,372 $1,372 $1,674 $1,674 $2,405 $82,031 $2,405 8.7 34.1 $67,240 $67,240 $82,031 0.18 0.7

### 7



## 2

. 5 A lternate Analysis of Connector Monitoring Costs Based on comments from two commenters (the American Chemistry Council (ACC) and Eastman Chemical Company) regarding the costs to monitor connectors , we performed an additional anal ys is to determine the potential effects increased connector monitoring costs may have on the cost effectiveness of the 40 CFR p art 63, subpart H LDAR program as applied to OSWRO facilities. Specifically , the commenters estimate that the ongoing monitoring fee per connector is $6.50, compared with the value of $2.50 used in our anal ys is , and they estimate the administrative costs associated with connector monitoring are $27,000 per year, compared with the value of $4,636 per year used in our anal ys is

. Regarding ongoing monitoring costs, we believe the $2.50 used in our analysis is a reasonable estimate of the monitoring costs per connector. This estimate, which has also been used in previous EPA LDAR anal ys es, is based o n an average monitoring cost per component of $1.00 to $1.50, and then increased to $2.50 to account for industry claims that connectors are more difficult than other components to monitor. 4 

## However, to determine how a fee of $6.50 per connector, as sugges ted by the commenters, would affect the cost effectiveness of the provisions, we conducted an additional analy sis of costs of an LDAR program using this value. Regarding the administrative and reporting costs, the commenters estimate these costs to be $27 ,000 per ye ar for these activities for connectors alone , based on a study Eastman Chemical Company recently undertook at its Kingsport, Tennessee facility to examine its LDAR program costs. The results of this study were summarized in an attachment to the ACC comment letter

. 5 

## Based on information provided in this study, the weighted average labor rate for LDAR administrative activities is $34.56 per hour , which is reportedl y based on labor rates from the U.S. Bureau of Labor Statistics data multiplied by a factor of 1.5 to account for overhead and benefits costs. At these labor rates, administrative costs of $27,000 would equate to 781 hours per year. We do not find this amount of time to be reasonable for connector administrative and reporting costs, especiall y considering that connector monitoring may onl y be required once every

four years. However, it may be possible that our estimate of 50 hours per year at a labor rate of $92.92 per hour overestimates the labor rate and underestimates the amount of time required to complete the necessary administrative requirements. Therefore, we conducted an additional anal ys is of the costs of an LD AR program assuming twice as many hours a s we previousl y estimated and the labor rates provided by the commenter for these administrative actions , in addition to considering the suggested increased costs for connector monitoring described above

. Using these alternate connector monitoring and administrative cost values, the incremental cost effectiveness for connectors would be $ 6,825 /ton of HAP reduced

. This incremental cost effectiveness is still approximately

$7,000 /ton HAP reduced, as was calculated without these alternate connector monitoring values. Table 6 provides a summary of the costs and cost effectiveness for the LDAR program as shown in Table 5, but includ es these alternate connector monitoring costs. See Appendix 2 for more detailed cost information.

4 

### Memorandum from K. Parrish and D. Randall, RTI International , to K. Rackley, USEPA. October 30, 2007. Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC in the SOCMI

. 5 

### This comment letter and the accompanying attachments is available in the OSWRO Rulemaking docket, Docket ID No. EPA

- HQ

- OAR

- 2012

- 0360

- 0061.

### 8



## Table **6 . Summary of**  **LDAR Prog ram**  **Cost Effectiveness Analysis with**  **Alternate Connector**  **Monitoring Costs**

**Baseline (subpar**  **t V) a**  **Optio n**  **1 (subpar**  **t H,**  **w /o**  **co nnecto**  **rs )**  **b Optio**  **n 2** 

**(subpar t**  **H, w/** **co nnecto**  **rs )**  **c Baseline** 

**(subpar t**  **V) a**  **Optio n 1**  **(subpar t**  **H, w**  **/o co**  **nnecto rs**  **) b**  **Optio n**  **2**

**(subpar t**  **H, w/** **co nnecto**  **rs )**  **c** HA P Emissions d 0.5 26. 2 HA P Emission Reduction From Basel ine -- -- Total C api tal C ost $877 $42, 985 Capi tal C ost Ab ove Basel

in e -- -- An nual iz ed Cost $2, 358 $115, 531. 76 An nual iz ed Cost A

bove Basel

in e -- -- Cost Effecti

veness -- -- HA P Emissions d 2.8 137. 4 HA P Emission Reduction From Basel ine -- -- Total C api tal C ost $224 $10, 968 Capi tal C ost Ab ove Basel

in e -- -- An nual iz ed Cost $3, 218 $157, 705 An nual iz ed Cost A

bove Basel

in e -- -- Cost Effecti

veness -- -- HA P Emissions d 3.3 3.3 1.7 160. 4 160.4 84. 7 HA P Emission Reduction From Basel ine -- -- 1.5

-- -- 75. 8 Total C api tal C ost
-- -- $34, 186

-- -- $1, 675, 099 Capi tal C ost Ab ove Basel

in e -- -- $34, 186

-- -- $1, 675, 099 An nual iz ed Cost

-- -- $10, 554

-- -- $517, 168 An nual iz ed Cost A

bove Basel

in e -- -- $10, 554

-- -- $517, 168 Cost Effecti

veness -- -- $6, 825

-- -- $6, 825 HA P Emissions 0.87 42. 9 HA P Emission Reduction From Basel ine -- -- Total C api tal C ost
-- -- Capi tal C ost Ab ove Basel

in e -- -- An nual iz ed Cost

-- -- An nual iz ed Cost A

bove Basel

in e -- -- Cost Effecti

veness -- -- HA P Emissions 7.5 5.3 3.7 366. 9 258.2 182.4 HA P Emission Reduction From Basel ine -- 2.2 3.8

-- 108.7 184.5 Total C api tal C ost $1, 101 $9, 542 $43, 727 $53, 953 $467, 543 $2, 142, 642 Incremental

Emission Reduction (basel in e  option 1, option 1-->2) -- 2.2 1.5

-- 108.7 75. 8 Capi tal C ost Ab ove Basel

in e -- $8, 441 $42, 626

-- $413, 590 $2, 088, 689 An nual iz ed Cost $5, 576 $8, 742 $19, 296 $273, 237 $428, 354 $945, 522 An nual iz ed Cost A

bove Basel

in e -- $3, 166 $13, 720

-- $155, 117 $672, 285 Cost Effecti

veness -- $1, 426 $3, 643

-- $1, 426 $3, 643 Incremental

C ost Effecti

veness (basel in e  option 1, option 1-->2) -- $1, 426 $6, 825

-- $1,426 $6, 825

d C api tal costs are the i

ni tial moni tori ng c osts. $4, 009 $196,452

a B asel ine isa ssociated wi

th 40 CFR part 61, subpart V c ompl iance requi

red by subpart DD (pumps:1 0,000 ppm, val ves:10,000 ppm, connectors:s ensory moni tori ng, ag it ators:no requi

rements). bOption 1 is associated wi th 40 CFR part 63, subpart H level of control

f or pumps, val

ves and ag

it ators onl

y (pumps:2 ,000 ppm, val ves:5 00 ppm, ag

it ators: 10, 000 ppm). cOption 2 is associated wi th 40 CFR part 63,subpart H l evel o f c ontrol

f or pumps, val

ves, ag it ators and connectors (pumps:2,0 00 ppm, val ves:500 ppm, ag

igators: 10, 000 ppm) and i

nstrument moni

tori ng for connectors at 500 ppm. $3, 166 $155,126

$3, 902 $191,197 **Ty pe o**  **f equipment**  **Co st**  **Par ameter**  **Mo de**  **l Plan t**  **OS WR** **O Sou rc**  **e Ca**  **te gor**  **y (49 F** **acilit ie**  **s)**

Pumps inl

ight liquid service 0.1 7.3 0.4 19.0 $4, 886 $239,437

$3, 059 $149,898 $808 $39,594 $2, 087 $2,087 1.7 81.7 55.7 $3, 283 $160,866

$602 $602 Connectors

Agit ators 0. 18 8.7 0.7 34.1 $1, 372 $67,240 Valv es in l ight liquid service

$2, 405 $2,405 $684 $33,491.60 1.1

To tal L DA R Pr og ram Costg $1, 372 $67,240 $1, 674 $82,031 $1, 674 $82,031

# Appendix 1:

Equipment Leak Model Plant Costs

### A

- 1 **Ba sel**  **ine Op**  **ti on 1**  **Op tion 1**  **Op ti**  **on 1**

Ty peof Com pone nt va lve s -gas va por va lve s -

light liquid va lve s -gas

va por va lve s -

light liquid Connect ors (light

liquid flange s) Agitators - light

liquid se rvice Numbe r of Compone nts 27 27 0 910 0 910 1, 350 9 Initial Monitoring Fe e or Unit Cost ($/comp) $0 $0 $0 $0 $0 $0 $24 $24 Initial Monitoring Costs ($/yr) (Capital) $692 $3, 857 $0 $224 $0 $3, 283 $32, 331 $445 Initial Pum p Se al Replacement Costs ($/yr) (Ca pital) $185 $1, 029 NA NA NA NA NA NA Initial LD ARAdmin Costs $0 $0 $0 $0 $0 $0 $1, 854 $927 Fre que ncy of Monitoring (tim es /yr) 12 12 2 2 2 2 0. 25 12 Subse que nt Monitoring Fe e ($ /c om p) $2 $2 $2 $2 $2 $2 $3 $2 Annual Monitoring Costs ($/yr) $1, 044 $1, 044 $0 $2, 730 $0 $2, 730 $844 $162 Annual Mainte nance Cos ts ($/yr) $211 $238 $0 $0 $0 $0 $0 $70 Initial Le ak Fre que ncy (%) 2. 42 13. 48 0. 33 0. 33 7. 24 4. 84 0. 36 2. 42 Initial Num ber of Leaks 0. 65 3. 64 0. 00 3. 00 0. 00 44. 04 4. 86 0. 22 Subse que nt Le ak Fre quency (%) 0. 23 0. 26 0. 33 0. 33 0. 51 0. 51 0. 36 0. 23 Annual Num ber of Leaks 0. 75 0. 84 0. 00 6. 01 0. 00 9. 28 1. 22 0. 25 Pe rce nt R epaired Online 100. 00 100. 00 75. 00 75. 00 75. 00 75. 00 75. 00 100. 00 Repair Time (hours) 16. 00 16. 00 0. 17 0. 17 0. 17 0. 17 0. 17 16. 00 Repair Labor Charge ($/hr) $66 $66 $66 $66 $66 $66 $66 $66 Annual OnlineL eak Repair Cost ($/ hr) $790 $893 $0 $50 $0 $77 $10 $263 Pe rce nt R equiring Furthe r Repair 0. 00 0. 00 25. 00 25. 00 25. 00 25. 00 25. 00 0. 00 Repair Time (hours) 80. 00 80. 00 4. 00 4. 00 4. 00 4. 00 2. 00 80. 00 Replace me nt Pump Se als ($) $283 $283 NA NA NA NA NA NA Annual Offline Leak Repair Cos t ($/yr) $0 $0 $0 $398 $0 $615 $40 $0 Mo nitoring to Ve rify Repair ($) $1 $1 $0 $9 $0 $14 $3 $0 Annual Admin. Cost ($/ yr) $0 $0 $0 $0 $0 $0 $4, 636 $927 Annual Misc. Charge s ( $/yr) $169 $191 $0 $0 $0 $0 $0 $56 **To ta**  **l Ca pital Cos**  **ts** $877 $4, 886 $34, 186 $1, 372 **Annualize d Ca**  **pital Cos ts**  $143 $799 $4, 854 $195 **Annual Ex**  **penses** $2, 214 $2, 367 $5, 530 $1, 479 **Gra nd**  **Tot al**  **(Annua l Expe**  **nse s +** **A nnualiz**  **ed Capita l Costs)**  $2, 358 $3, 166 $10, 384 $1, 674 **In crementa**  **l cos**  **t** $808 $10, 384 $1, 674 **OS WR**  **O E quipme**  **nt Leak Costs**

Base lineor O ption

pum ps - light liquid se rvice **Ba seline**  **Op tion 1**  **OS WR**  **O Model Plant** 

$683 $224 $32 $3, 187 $3, 218 $3, 283 $466 $3, 436 $3, 902

# Appendix 2: Equipment Leak Model Plant Costs with Alternate Connector

Monitoring Cost Values

### A

- 2 **Ba seli**  **ne Op**  **tion 1 Op**  **tion 1 Op**  **tion 1**

Ty peof Compone nt va lve s -gas va por valve s -

light liquid va lve s - gas

va por valves -

light liquid Connectors (light

liquid flange s) Agitators - light

liquid se rvice Numbe r of Compone nts 27 27 0 910 0 910 1, 350 9 In itial Monitoring Fe e or Unit Cost ($/c om p) $0 $0 $0 $0 $0 $0 $24 $24 In itial Monitoring Costs ($/yr) (Capital) $692 $3, 857 $0 $224 $0 $3, 283 $32, 331 $445 In itial Pump Se al Re placem en t C osts ( $/yr) (Capital) $185 $1, 029 NA NA NA NA NA NA In itial LDARAdmin Costs $0 $0 $0 $0 $0 $0 $1, 854 $927 Fre que ncy of Monitoring (times/yr) 12 12 2 2 2 2 0. 25 12 Subsequent M onitoring Fe e ($ /comp) $2 $2 $2 $2 $2 $2 6. 50 $2 Annual Monitoring Costs ($/yr) $1, 044 $1, 044 $0 $2, 730 $0 $2, 730 $2, 194 $162 Annual Mainte nanceCosts ($/yr) $211 $238 $0 $0 $0 $0 0 $70 In itial Le ak Fre quency (%) 2. 42 13. 48 0. 33 0. 33 7. 24 4. 84 0. 36 2. 42 In itial Number of Le aks 0. 65 3. 64 0. 00 3. 00 0. 00 44. 04 4. 86 0. 22 Subsequent Le ak Fre que ncy (%) 0. 23 0. 26 0. 33 0. 33 0. 51 0. 51 0. 36 0. 23 Annual Numbe r of Le aks 0. 75 0. 84 0. 00 6. 01 0. 00 9. 28 1. 22 0. 25 Pe rcent Re paire d O nline 100. 00 100. 00 75. 00 75. 00 75. 00 75. 00 75. 00 100. 00 Rep air Time (hours) 16. 00 16. 00 0. 17 0. 17 0. 17 0. 17 0. 17 16. 00 Rep air Labor Charge( $/hr) $66 $66 $66 $66 $66 $66 $66 $66 Annual OnlineL eakR ep air Cost ($/hr) $790 $893 $0 $50 $0 $77 $10 $263 Pe rcent Re quiring Further Re pair 0. 00 0. 00 25. 00 25. 00 25. 00 25. 00 25. 00 0. 00 Rep air Time (hours) 80. 00 80. 00 4. 00 4. 00 4. 00 4. 00 2. 00 80. 00 Rep lacem en t Pump Se als ($) $283 $283 NA NA NA NA NA NA Annual OfflineLe ak R epair Cos t ($/yr) $0 $0 $0 $398 $0 $615 $40 $0 Mo nitoring to Verify Repair ($) $1 $1 $0 $9 $0 $14 $8 $0 Annual Admin. Cost ($/yr) $0 $0 $0 $0 $0 $0 $3, 456 $927 Annual Misc

. Charge s ($/yr) $169 $191 $0 $0 $0 $0 $0 $56 **Total Ca**  **pital Costs** $877 $4, 886 $34, 186 $1, 372 **Annualiz ed Ca**  **pital Costs** $143 $799 $4, 854 $195 **Annual Ex**  **pe nses**  $2, 214 $2, 367 $5, 700 $1, 479 **Gra nd T** **ota l (Annual Expe**  **nse s +**  **Annualiz ed**  **Capital Costs)** $2, 358 $3, 166 $10, 554 $1, 674 **In cre**  **menta l cost**  $808 $10, 554 $1, 674 $3, 218 $3, 902 $683 $224 $3, 283 $32 $466 $3, 187 $3, 436 **OS WR**  **O E quipme**  **nt Le ak**  **Costs with Alterna te Connector Monitoring Costs** 

Baselineor Option **OS WR**  **O Model Plant**  **Ba sel**  **ine Op**  **tion 1**

pumps -light liquid se rvice