MEMORANDUM

DATE: February 9, 2015

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

reviews conducted for the source category. The purpose of this memorandum is to present a revised 

analysis related to the technology review for equipment leaks at OSWRO facilities, considering 

comments submitted during the public comment period for the proposed OSWRO 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 by section 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 promulgation 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 collectively referred to as residual risk and 

technology reviews (RTRs).

For the July 2014 proposal, a technology review for equipment leaks at OSWRO 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 Leaks, 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 require facilities to follow the more 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 assumptions used in the analysis of emissions 

reductions and costs associated with the LDAR program of 40 CFR part 63, subpart H. We have 

considered these comments and conducted an analysis to determine the impacts of these comments on 

our previously estimated emissions 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 Leaks at OSWRO Facilities

Equipment leaks are emissions emanating from leaking pieces of equipment, such as pumps,

compressors, agitators, pressure relief devices, sampling connection systems, open-ended valves or

lines, valves, connectors, surge control vessels, bottoms receivers, and instrumentation systems 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 type and number

of pieces of equipment and the concentration of HAP constituents of the stream passing through the

equipment.

2.2 Summary of Existing MACT Level 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 year.1For all of 

the equipment subject to the standards, the owner or operator must comply with the LDAR requirements 

of either 40 CFR 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, Subpart V and Part 63, Subpart H

Equipment Type 40 CFR part 61

subpart V

40 CFR part 63

subpart H

Valves in 

gas/vapor service

and light liquid 

service

Conduct EPA Method 21 monitoring 

and leak definition of 10,000 ppm

(monthly or less often up to 

quarterly depending on leak rate)

Same as part 61, subpart 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 

monitoring and a leak definition of 

10,000 ppm

Same as part 61, subpart 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)

(type 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 detectable 

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 part 61, subpart V

Open-ended valves 

or lines

Equip with a cap, blind flange, plug 

or second valve Same as part 61, subpart V

2.3 Proposed Standard for Equipment Leaks

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. Leak 

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 by 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 analysis

for the Uniform Standards for equipment leaks. Based on the estimated control costs and emissions 

reductions from this analysis, 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 agitators in gas/vapor service 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 part 63, subpart H, and we did not include the emissions reductions or the costs of 

including an LDAR program in our analysis 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, we have 

revised our analysis of the costs of an LDAR program with the more stringent leak definitions of 40 

CFR part 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 included in the revised analysis. 

Other types of equipment not included in this table are largely 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.

Table 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

monitoring

Sensory

monitoring

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 OSWRO 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 Equipmenta

Pumps (light liquid service) 27

Valves (light liquid service)b910

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 reported 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 

type. 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 type 

at the OSWRO model plant and converted to tons per year (tpy) 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 without

and with connector monitoring). These emissions factors were based on those used in the proposed 

Uniform Standards for equipment leaks analysis, but because the factors used in that analysis are for 

total organic compounds, which for OSWRO facilities are generally 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 Type3

Type of Equipment Emission Factor (kg/hr/equipment piece)

Baseline Option 1/Option 2

Pump Seals – Light Liquid Service 2.05E-03 5.69E-04

Valves – Light Liquid Service 3.19E-04 1.90E-04

Connectors – Gas/Vapor and Light Liquid Service 2.51E-04 2.51E-04/1.33E-04

Agitators – Gas/Vapor and Light Liquid Service 1.01E-02 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 analysis. 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 

information). Table 5 shows the costs and cost effectiveness by 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 these 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 

(subpart V)a

Option 1 

(subpart H, w/o

connectors)

b

Option 2 

(subpart H, 

w/connectors)

c

Baseline 

(subpart V)a

Option 1 (subpart 

H, w/o

connectors)

b

Option 2 

(subpart H, 

w/connectors)

c

HAP Emissions

d

0.5 26.2

HAP Emission Reduction From Baseline -- --

Total Capital Cost $877 $42,985 

Capital Cost Above Baseline -- --

Annualized Cost $2,358 $115,531.76 

Annualized Cost Above Baseline -- --

Cost Effectiveness -- --

HAP Emissions

d

2.8 137.4

HAP Emission Reduction From Baseline -- --

Total Capital Cost $224 $10,968

Capital Cost Above Baseline -- --

Annualized Cost $3,218 $157,705

Annualized Cost Above Baseline -- --

Cost Effectiveness -- --

HAP Emissions

d

3.3 3.3 1.7 160.4 160.4 84.7

HAP Emission Reduction From Baseline -- -- 1.5 -- -- 75.8

Total Capital Cost -- -- $34,186 -- -- $1,675,099

Capital Cost Above Baseline -- -- $34,186 -- -- $1,675,099

Annualized Cost -- -- $10,384 -- -- $508,838

Annualized Cost Above Baseline -- -- $10,384 -- -- $508,838

Cost Effectiveness -- -- $6,715 -- -- $6,715

HAP Emissions 0.87 42.9

HAP Emission Reduction From Baseline -- --

Total Capital Cost -- --

Capital Cost Above Baseline -- --

Annualized Cost -- --

Annualized Cost Above Baseline -- --

Cost Effectiveness -- --

HAP Emissions 7.5 5.3 3.7 366.9 258.2 182.4

HAP Emission Reduction From Baseline -- 2.2 3.8 -- 108.7 184.5

Total Capital Cost $1,101 $9,542 $43,727 $53,953 $467,543 $2,142,642

Incremental Emission Reduction 

(baseline option 1, option 1-->2) -- 2.2 1.5 -- 108.7 75.8

Capital Cost Above Baseline -- $8,441 $42,626 -- $413,590 $2,088,689

Annualized Cost $5,576 $8,742 $19,126 $273,237 $428,354 $937,192

Annualized Cost Above Baseline -- $3,166 $13,550 -- $155,117 $663,955

Cost Effectiveness -- $1,426 $3,598 -- $1,426 $3,598

Incremental Cost Effectiveness 

(baseline option 1, option 1-->2) -- $1,426 $6,715 -- $1,426 $6,715

a

 Baseline is associated with 40 CFR part 61, subpart V compliance required by subpart DD (pumps: 10,000 ppm, valves: 10,000 ppm, connectors: sensory 

monitoring, agitators: no requirements).

b

 Option 1 is associated with 40 CFR part 63, subpart H level of control for pumps, valves and agitators only (pumps: 2,000 ppm, valves: 500 ppm, agitators:

10,000 ppm).

c

 Option 2 is associated with 40 CFR part 63,subpart H level of control for pumps, valves, agitators and connectors (pumps: 2,000 ppm, valves: 500 ppm, agigators:

10,000 ppm) and instrument monitoring for connectors at 500 ppm.

d

 Capital costs are the initial monitoring costs.

$4,009 

$808

$3,059

Connectors

Model Plant

Type of 

equipment Cost Parameter

Total LDAR 

Program Costg

Pumps in light 

liquid service

Valves in light 

liquid service

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

OSWRO Source Category

 (49 Facilities)

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 Alternate 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 analysis to 

determine the potential effects increased connector monitoring costs may have on the cost effectiveness 

of the 40 CFR part 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 analysis, 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 analysis. 

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 

analyses, is based on 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 suggested by the commenters, 

would affect the cost effectiveness of the provisions, we conducted an additional analysis 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 

year 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 reportedly 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, especially considering that connector monitoring may only 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 

analysis of the costs of an LDAR program assuming twice as many hours as we previously 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 includes 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 Program Cost Effectiveness Analysis with Alternate Connector 

Monitoring Costs

Baseline 

(subpart V)a

Option 1 

(subpart H, w/o

connectors)

b

Option 2 

(subpart H,

w/connectors)

c

Baseline 

(subpart V)a

Option 1 (subpart 

H, w/o

connectors)

b

Option 2 

(subpart H,

w/connectors)

c

HAP Emissions

d

0.5 26.2

HAP Emission Reduction From Baseline -- --

Total Capital Cost $877 $42,985 

Capital Cost Above Baseline -- --

Annualized Cost $2,358 $115,531.76 

Annualized Cost Above Baseline -- --

Cost Effectiveness -- --

HAP Emissions

d

2.8 137.4

HAP Emission Reduction From Baseline -- --

Total Capital Cost $224 $10,968

Capital Cost Above Baseline -- --

Annualized Cost $3,218 $157,705

Annualized Cost Above Baseline -- --

Cost Effectiveness -- --

HAP Emissions

d

3.3 3.3 1.7 160.4 160.4 84.7

HAP Emission Reduction From Baseline -- -- 1.5 -- -- 75.8

Total Capital Cost -- -- $34,186 -- -- $1,675,099

Capital Cost Above Baseline -- -- $34,186 -- -- $1,675,099

Annualized Cost -- -- $10,554 -- -- $517,168

Annualized Cost Above Baseline -- -- $10,554 -- -- $517,168

Cost Effectiveness -- -- $6,825 -- -- $6,825

HAP Emissions 0.87 42.9

HAP Emission Reduction From Baseline -- --

Total Capital Cost -- --

Capital Cost Above Baseline -- --

Annualized Cost -- --

Annualized Cost Above Baseline -- --

Cost Effectiveness -- --

HAP Emissions 7.5 5.3 3.7 366.9 258.2 182.4

HAP Emission Reduction From Baseline -- 2.2 3.8 -- 108.7 184.5

Total Capital Cost $1,101 $9,542 $43,727 $53,953 $467,543 $2,142,642

Incremental Emission Reduction 

(baseline option 1, option 1-->2) -- 2.2 1.5 -- 108.7 75.8

Capital Cost Above Baseline -- $8,441 $42,626 -- $413,590 $2,088,689

Annualized Cost $5,576 $8,742 $19,296 $273,237 $428,354 $945,522

Annualized Cost Above Baseline -- $3,166 $13,720 -- $155,117 $672,285

Cost Effectiveness -- $1,426 $3,643 -- $1,426 $3,643

Incremental Cost Effectiveness 

(baseline option 1, option 1-->2) -- $1,426 $6,825 -- $1,426 $6,825

d

 Capital costs are the initial monitoring costs.

$4,009 $196,452

a

 Baseline is associated with 40 CFR part 61, subpart V compliance required by subpart DD (pumps: 10,000 ppm, valves: 10,000 ppm, connectors: sensory 

monitoring, agitators: no requirements).

b

 Option 1 is associated with 40 CFR part 63, subpart H level of control for pumps, valves and agitators only (pumps: 2,000 ppm, valves: 500 ppm, agitators:

10,000 ppm).

c

 Option 2 is associated with 40 CFR part 63,subpart H level of control for pumps, valves, agitators and connectors (pumps: 2,000 ppm, valves: 500 ppm, agigators:

10,000 ppm) and instrument monitoring for connectors at 500 ppm.

$3,166 $155,126

$3,902 $191,197

Type of 

equipment Cost Parameter

Model Plant

OSWRO Source Category

 (49 Facilities)

Pumps in light 

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

Agitators 0.18 8.7

0.7 34.1

$1,372 $67,240

Valves in light 

liquid service

$2,405 $2,405

$684 $33,491.60

1.1

Total LDAR 

Program Costg

$1,372 $67,240

$1,674 $82,031

$1,674 $82,031
Appendix 1:

Equipment Leak Model Plant Costs
A-1

Baseline Option 1 Option 1 Option 1

Type of Component

valves - gas 

vapor

valves - 

light liquid

valves - gas 

vapor

valves - 

light liquid

Connectors (light 

liquid flanges)

Agitators - light 

liquid service

Number of Components 27 27 0 910 0 910 1,350 9

Initial Monitoring Fee 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 Pump Seal Replacement Costs ($/yr) (Capital) $185 $1,029 NA NA NA NA NA NA

Initial LDAR Admin Costs $0 $0 $0 $0 $0 $0 $1,854 $927

Frequency of Monitoring (times/yr) 12 12 2 2 2 2 0.25 12

Subsequent Monitoring Fee ($/comp) $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 Maintenance Costs ($/yr) $211 $238 $0 $0 $0 $0 $0 $70

Initial Leak Frequency (%) 2.42 13.48 0.33 0.33 7.24 4.84 0.36 2.42

Initial Number of Leaks 0.65 3.64 0.00 3.00 0.00 44.04 4.86 0.22

Subsequent Leak Frequency (%) 0.23 0.26 0.33 0.33 0.51 0.51 0.36 0.23

Annual Number of Leaks 0.75 0.84 0.00 6.01 0.00 9.28 1.22 0.25

Percent Repaired 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 Online Leak Repair Cost ($/hr) $790 $893 $0 $50 $0 $77 $10 $263

Percent Requiring Further 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

Replacement Pump Seals ($) $283 $283 NA NA NA NA NA NA

Annual Offline Leak Repair Cost ($/yr) $0 $0 $0 $398 $0 $615 $40 $0

Monitoring to Verify Repair ($) $1 $1 $0 $9 $0 $14 $3 $0

Annual Admin. Cost ($/yr) $0 $0 $0 $0 $0 $0 $4,636 $927

Annual Misc. Charges ($/yr) $169 $191 $0 $0 $0 $0 $0 $56

Total Capital Costs $877 $4,886 $34,186 $1,372

Annualized Capital Costs $143 $799 $4,854 $195

Annual Expenses $2,214 $2,367 $5,530 $1,479

Grand Total (Annual Expenses + Annualized Capital Costs) $2,358 $3,166 $10,384 $1,674

Incremental cost $808 $10,384 $1,674

OSWRO Equipment Leak Costs

Baseline or Option

pumps - light liquid service

Baseline Option 1

OSWRO 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

Baseline Option 1 Option 1 Option 1

Type of Component

valves - gas

vapor

valves -

light liquid

valves - gas 

vapor

valves - 

light liquid

Connectors (light 

liquid flanges)

Agitators - light 

liquid service

Number of Components 27 27 0 910 0 910 1,350 9

Initial Monitoring Fee 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 Pump Seal Replacement Costs ($/yr) (Capital) $185 $1,029 NA NA NA NA NA NA

Initial LDAR Admin Costs $0 $0 $0 $0 $0 $0 $1,854 $927

Frequency of Monitoring (times/yr) 12 12 2 2 2 2 0.25 12

Subsequent Monitoring Fee ($/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 Maintenance Costs ($/yr) $211 $238 $0 $0 $0 $0 0 $70

Initial Leak Frequency (%) 2.42 13.48 0.33 0.33 7.24 4.84 0.36 2.42

Initial Number of Leaks 0.65 3.64 0.00 3.00 0.00 44.04 4.86 0.22

Subsequent Leak Frequency (%) 0.23 0.26 0.33 0.33 0.51 0.51 0.36 0.23

Annual Number of Leaks 0.75 0.84 0.00 6.01 0.00 9.28 1.22 0.25

Percent Repaired 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 Online Leak Repair Cost ($/hr) $790 $893 $0 $50 $0 $77 $10 $263

Percent Requiring Further 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

Replacement Pump Seals ($) $283 $283 NA NA NA NA NA NA

Annual Offline Leak Repair Cost ($/yr) $0 $0 $0 $398 $0 $615 $40 $0

Monitoring 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. Charges ($/yr) $169 $191 $0 $0 $0 $0 $0 $56

Total Capital Costs $877 $4,886 $34,186 $1,372

Annualized Capital Costs $143 $799 $4,854 $195

Annual Expenses $2,214 $2,367 $5,700 $1,479

Grand Total (Annual Expenses + Annualized Capital Costs) $2,358 $3,166 $10,554 $1,674

Incremental cost $808 $10,554 $1,674

$3,218 $3,902

$683

$224 $3,283

$32 $466

$3,187 $3,436

OSWRO Equipment Leak Costs with Alternate Connector Monitoring Costs

Baseline or Option

OSWRO Model Plant

Baseline Option 1

pumps - light liquid service