MEMORANDUM

DATE: March 17, 2011 

SUBJECT: Cost Effectiveness and Impacts of Lean Oil Absorption for Control of Hazardous 

Air Pollutants from Gasoline Loading - Promulgation 

 Residual Risk and Technology Review for the Marine Tank Vessel Loading 

Operations Source Category 

 EPA Contract No.: EPD06118 

 EPA Project No.: 4-15 

 RTI Project No.: 0210426.004.015 

FROM: David Green and Karen Schaffner, RTI International 

TO: Stephen Shedd, EPA 

 

I. Background 

The purpose of this memorandum is to document and update the methods used to 

estimate capital and annualized costs for reducing hazardous air pollutant (HAP) emissions and 

volatile organic compounds (VOC) from marine tank vessel loading operations (MTVLO) for 

gasoline.1 All cost estimates are based on the application of an add-on control device to reduce 

emissions. Potential control options and nationwide impacts for add-on controls for MTVLO 

facilities are presented. 

II. Total Capital Investment 

Based on information obtained from one vendor, lean oil absorption systems are available 

for control of hazardous air pollutants (HAP) and volatile organic compounds (VOC) emitted 

during loading of gasoline to marine vessels.2

 The equipment cost is based on a typical unit cost 

of $650,000 for a lean oil absorption system for a throughput of 5,000 gal/min associated with 

barge loading of gasoline and a typical unit cost of $1,200,000 for a lean oil absorption system 

for 15,000 gal/min associated with ship loading. The total capital investment (TCI) required was 

estimated using EPA standard costing procedures. First, the purchased equipment cost (PEC) 

was estimated by multiplying the vendor equipment costs by a factor of 1.08. The PEC includes 

costs for auxiliary equipment, instrumentation, sales, freight, etc. The TCI was then estimated 

by multiplying the PEC by a factor of 1.15 to cover the installation costs (i.e., foundation and 

supports, handling and erection, piping, electrical, installation, engineering, construction, startup, 

 

1

 This memorandum is an update to the Cost Memorandum for proposal. Green, D. and K. Schaffner, RTI 

International, to S. Shedd, EPA/OAQPS/SPPD/CCG. Memorandum for Cost Effectiveness and Impacts of Lean Oil 

Absorption for Control of Hazardous Air Pollutants from Gasoline Loading: Residual Risk and Technology Review 

for the Marine Tank Vessel Loading Operations Source Category. August 19. 2010. See Docket Item No. EPAHQ-OAR-2010-0600-0003. 

2

 Telecon with B. Shine, EPA/OAQPS/SPPD, with J. Rex Hewitt, Petrogas. July 8 and 15, 2010. 
and performance tests). Thus, the TCI was estimated to be 1.24 times the vendor equipment 

costs. 

For a typical MTVLO facility, the TCI ranged from $807,000 for barge loading to 

$1,490,000 for ship loading. These values were based on the vendor costs. The TCI for typical 

MTVLO facilities is shown in Table 1. Based on public comments on the October 21, 2010 

proposal, commenters indicated that costs were significantly higher for offshore loading 

terminals and ranged from 1.3 to 2.3 times the costs for a typical MTVLO facility.3,4 The 

equipment costs were assumed to be approximately 2.3 times higher than the costs for a typical 

MTVLO facility.5 For offshore loading terminals, the TCI ranges from $1,860,000 for barge 

loading to $3,430,000 for ship loading. The TCI for offshore loading facilities is shown in 

Table 2. Additional details on the TCI calculations are shown in Attachment A. 

For comparison with a lean oil absorption system, capital costs for a refrigerated 

condenser unit were estimated. Capital costs for lean oil absorption systems were roughly 

comparable to costs for refrigerated gasoline vapor recovery systems of similar capacity. Costs 

for refrigerated gasoline vapor recovery systems were based on the OAQPS Control Cost 

Manual,6

 escalated to 2010. The total capital investment of a refrigerated gasoline vapor 

recovery system with a capacity of 5,000 gal/min was estimated at $1,020,000 (2009$). The 

total capital investment for a refrigerated gasoline vapor recovery system with capacity of 

15,000 gal/min was estimated to be $1,870,000 for ship loading at a typical MTVLO. These 

costs are within approximately 25 percent of a similarly sized lean oil absorption system for 

either barge loading or ship loading. 

III. Total Annual Costs 

Annualized costs for the lean oil absorption system were developed based on information 

provided by the vendor and EPA standard costing procedures. The lean oil absorption system is 

estimated to have a variable operating cost of $0.006 per gallon loaded, and the vendor indicated 

that essentially all of this cost is attributable to electricity. The labor costs for 

running/maintaining the control device system were estimated based on an estimated labor 

 

3

 Todd, M., API, to Air and Radiation Docket. Docket ID No. EPA-HQ-OAR-2010-0600, Letter with Comments 

on EPA’s Proposed Rule – Residual Risk and Technology Review (RTR) for National Emission Standards for 

Marine Tank Vessel Loading Operations. Docket item no. EPA-HQ-OAR-2010-0600-0359. Dated December 6, 

2010. 

4

 Colman, C., Hovensa LLC, to Air and Radiation Docket. Docket ID No. EPA-HQ-OAR-2010-0600, Letter with 

Comments on EPA’s Proposed Rule – Residual Risk and Technology Review (RTR) for National Emission 

Standards for Marine Tank Vessel Loading Operations. Docket item no. EPA-HQ-OAR-2010-0600-0280. Dated 

December 6, 2010. 

5

 EPA received comments on the 1995 MTVLO NESHAP on the cost to control vapor emissions from offshore 

loading facilities. In general, commenters cited that offshore loading costs would range from 2 to 5 times the costs 

for typical MTVLO. One commenter that provided specific cost information at that time noted that TCI costs were 

2 times the cost for a typical MTVLO. (See Federal Standards for Marine Tank Vessel Loading Operations and 

National Emission Standards for Hazardous Air Pollutants for Marine Tank Vessel Loading Operations, Technical 

Support Document for Final Standards: Summary of Public Comments and Responses. U.S. Environmental 

Protection Agency. EPA Publication No. EPA-453/R-95-014. July 1995. See Docket No. A-90-44, item no. V-B01.) 

6

 OAQPS Control Cost Manual, Fourth Edition, EPA Publication No. EPA-450/3-90-006, January 1990. 

2
requirement of 1.5 hr/day and an assumed labor rate of $25.76/hr and an estimated maintenance 

labor requirement of 1.5 hr/day and an assumed labor rate of $26.48/hr (these rates were loaded 

with benefits and overhead).7

 The maintenance parts cost was estimated to be 1.0 times the 

maintenance labor costs. Indirect annual costs included administrative charges, property tax, and 

insurance at 4 percent of the TCI, and the capital recovery based on a capital recovery factor of 

0.1424 (interest rate of 7 percent for an equipment life of 10 years). The assumptions for 

estimating the annual costs are provided in Table 3. 

 Control options were developed based on annual gasoline throughput cutoffs, with a 

control efficiency requirement or total organic carbon concentration limit for MTVLO that 

exceed the threshold. Model MTVLO were considered for gasoline throughputs of 1,000,000 

bbl/yr, 5,000,000 bbl/yr, and 7,000,000 bbl/yr. The TAC is dependent on the gasoline 

throughput, since the variable operating cost is based on throughput. The TAC for each gasoline 

throughput model, for both barges and ships at a typical MTVLO facility, is shown in Table 1. 

TAC for both barges and ships at offshore loading facilities is shown in Table 2. Additional 

details on TAC calculations are shown in Attachment A. 

IV. Emission Reductions for Model MTVLO 

The emissions and the emission reductions were estimated for barge and ship loading for 

each gasoline throughput model. The VOC emissions from barge loading of gasoline are 

assumed to be 3.4 pounds of VOC per 1,000 gallons gasoline loaded (lb VOC/1,000 gal).8

 The 

VOC emissions from ship loading of gasoline are assumed to be 1.8 lb VOC/1,000 gal.5

 The 

HAP content of the VOC is assumed to be 5.0 percent by weight.9 The overall recovery rate for 

the lean oil absorption system is assumed to be 99 percent. The emissions reductions for VOC 

and HAP for each model are shown in Tables 1 and 2. 

Because the lean oil absorption system recovers gasoline product, a product recovery 

credit was included in the cost analysis. The value of the recovered product was assumed to be 

$560/ton, which partially offsets the operating cost. The TAC considering the recovered 

gasoline, is shown in Tables 1 and 2 for barges and ships, for each gasoline throughput model. 

V. Costs for Model MTVLO Impacts 

Table 4 provides the TCI, TAC, the HAP and VOC emission reductions, and the gasoline 

recovery credit for each gasoline throughput threshold, for barges and ships, and for typical 

MTVLO and for offshore loading terminals. The number of nationwide MTVLO facilities that 

would be covered under each control option was based on information from the Waterborne 

Commerce Statistics Center (WCSC) database. As shown in Table 5, there are 54 facilities with 

 

7

 Operator labor rate is for occupation group 51-0000, and maintenance labor rate is from occupation group 49-

0000; rates used in cost calculations include an additional 110 percent for benefits and overhead. Bureau of Labor 

Statistics. 

8

 U. S. Environmental Protection Agency. Compilation of Air Pollutant Emissions Factors, Volume I, Stationary 

Point and Area Sources. AP-42, Fifth addition. See Section 5.2, Transportation and Marketing of Petroleum 

Liquids. 

9

 Schaffner, K. and J. Coburn, RTI International, to S. Shedd and B. Shine, EPA/OAR/OAQPS/SPPD. HAP 

Content in Vapor Phase of Gasoline. March 9, 2011. 

3
annual gasoline throughput of 1,000,000 bbl to 5,000,000 bbl; 8 facilities with 5,000,000 to 

7,000,000 bbl throughput; and 9 facilities with throughput of 7,000,000 bbl to 10,000,000 bbl. 

 

 The nationwide cost and cost effectiveness estimates, on an average facility basis, are 

shown in Attachment B. A summary of the nationwide costs and cost effectiveness is provided 

in Attachment C. 

VI. Secondary Impacts Estimates for Controlling MTVLO for Gasoline Loading 

The operation of lean oil absorption systems has an impact on electricity consumption. It 

is estimated, based on information from the vendor, that the lean oil absorption systems consume 

approximately 0.1 kWhr/gallon of gasoline loaded. Thus, electrical consumption associated with 

a 1,000,000 bbl/yr applicability threshold would be approximately 9.3 million kWhr/yr on 

average per facility. The electrical consumption associated with a 7,000,000 bbl/yr applicability 

threshold would be 29 million kWhr/yr on average per facility. These impacts and secondary 

emissions for SO2, NOx, and CO2 associated with this electrical consumption are given in 

Table 6. 

4
Table 1. Model Costs - Typical MTVLO 

Barge EF of 3.4 lb VOC/1000 gal gasoline loaded 

 Gasoline loaded, bbl/yr 1,000,000 5,000,000 7,000,000

 

 TCI $807,300 $807,300 $807,300

 TAC $489,760 $1,497,760 $2,001,760

 

3.4 lb VOC/1000 gal loaded VOC emissions, ton/yr 71.4 357.0 499.8

0.17 lb HAP/1000 gal loaded HAP emissions, ton/yr 3.57 17.85 24.99

5.0 % HAP 

 Assume 99% control VOC reduction, ton/yr 70.69 353.4 494.8

 HAP reduction, ton/y 3.53 17.67 24.74

560 $/ton gasoline 

 $/ton * ton recovered VOC recovery credit, $/yr $39,584 $197,921 $277,089

 

 TAC w/recovered $450,175 $1,299,839 $1,724,670

 

 Cost Effectiveness, $/ton VOC $6,369 $3,678 $3,486

 Cost Effectiveness, $/ton HAP $127,373 $73,556 $69,712

 

Ship EF of 1.8 lb VOC/1000 gal gasoline loaded 

 Gasoline loaded, bbl/yr 1,000,000 5,000,000 7,000,000

 

 TCI $1,490,400 $1,490,400 $1,490,400

 TAC $614,357 $1,622,357 $2,126,357

 

1.8 lb VOC/1000 gal loaded VOC emissions, ton/yr 37.8 189.0 264.6

0.09 lb HAP/1000 gal loaded HAP emissions, ton/yr 1.89 9.45 13.23

5.0 % HAP 

 Assume 99% control VOC reduction, ton/yr 37.42 187.11 261.95

 HAP reduction, ton/y 1.87 9.36 13.10

560 $/ton gasoline 

 $/ton * ton recovered VOC recovery credit, $/yr $20,956 $104,782 $146,694

 

 TAC w/recovered $593,401 $1,517,575 $1,979,663

 

 Cost Effectiveness, $/ton VOC $15,698 $8,029 $7,482

 Cost Effectiveness, $/ton HAP $317,140 $162,212 $151,146

 

5
Table 2. Model Costs - OFFSHORE LOADING 

Barge EF of 3.4 lb VOC/1000 gal gasoline loaded 

 Gasoline loaded, bbl/yr 1,000,000 5,000,000 7,000,000

 

 TCI $1,856,790 $1,856,790 $1,856,790

 TAC $681,186 $1,689,186 $2,193,186

 

3.4 lb VOC/1000 gal loaded VOC emissions, ton/yr 71.4 357.0 499.8

0.17 lb HAP/1000 gal loaded HAP emissions, ton/yr 3.57 17.85 24.99

5.0 % HAP 

 Assume 99% control VOC reduction, ton/yr 70.69 353.4 494.8

 HAP reduction, ton/y 3.53 17.67 24.74

560 $/ton gasoline 

 $/ton * ton recovered VOC recovery credit, $/yr $39,584 $197,921 $277,089

 

 TAC w/recovered $641,602 $1,491,266 $1,916,097

 

 Cost Effectiveness, $/ton VOC $9,077 $4,219 $3,872

 Cost Effectiveness, $/ton HAP $181,536 $84,388 $77,449

 

Ship EF of 1.8 lb VOC/1000 gal gasoline loaded 

 Gasoline loaded, bbl/yr 1,000,000 5,000,000 7,000,000

 

 TCI $3,427,920 $3,427,920 $3,427,920

 TAC $967,761 $1,975,761 $2,479,761

 

1.8 lb VOC/1000 gal loaded VOC emissions, ton/yr 37.8 189.0 264.6

0.09 lb HAP/1000 gal loaded HAP emissions, ton/yr 1.89 9.45 13.23

5.0 % HAP 

 Assume 99% control VOC reduction, ton/yr 37.42 187.11 261.95

 HAP reduction, ton/y 1.87 9.36 13.10

560 $/ton gasoline 

 $/ton * ton recovered VOC recovery credit, $/yr $20,956 $104,782 $146,694

 

 TAC w/recovered $946,804 $1,870,979 $2,333,066

 

 Cost Effectiveness, $/ton VOC $25,300.74 $9,999.35 $8,906.40

 Cost Effectiveness, $/ton HAP $506,015 $199,987 $178,128

 

6
Table 3. Assumptions for Annual Costs for Lean Oil Absorption Systems 

Factor Value 

Interest rate 7.0% 

Useful life 10 

Capital Recovery Factor 0.1424 

 

Variable Operating Cost, $ per gallon loaded 0.006 

Operator Labor rate, $/hr 25.76 

Maintenance labor rate, $/hr 26.48 

Operating Labor, hr/day 1.5 

Maintenance Labor, hr/day 1.5 

 

Recovery Credit, $/ton gasoline 560 

VOC emission factor for barges, lb/1000 gal loaded 3.4 

HAP emission rate for barges, lb/1000 gal loaded 0.17 

VOC emission factor for ships, lb/1000 gal loaded 1.8 

HAP emission rate for ships, lb/1000 gal loaded 0.09 

VOC recovery rate, % 99% 

HAP content of VOC, wt % 5.0% 

7
Table 4. Costs for Model MTVLO for Sources with Gasoline Loading. 

Gasoline 

Loading 

Threshold 

(million 

bbl/yr) 

Total 

Capital 

Investment 

($) 

Total 

annualized 

cost ($) 

Recovery 

Credit ($) 

Net 

annualized 

cost ($) 

HAP 

emission 

reduction 

(TPY) 

VOC 

emission 

reduction 

(TPY) 

Typical MTVLO facility 

Barges 

7,000,000 807,000 490,000 39,600 450,000 3.6 71 

5,000,000 807,000 1,500,000 198,000 1,300,000 18 350 

1,000,000 807,000 2,000,000 277,000 1,720,000 25 490 

Ships 

7,000,000 1,490,000 614,000 21,000 593,000 1.9 37 

5,000,000 1,490,000 1,620,000 105,000 1,520,000 9.4 190 

1,000,000 1,490,000 2,130,000 147,000 1,980,000 13 260 

Offshore loading facility 

Barges 

7,000,000 1,860,000 680,000 39,600 642,000 3.5 71 

5,000,000 1,860,000 1,690,000 198,000 1,490,000 18 350 

1,000,000 1,860,000 2,190,000 277,000 1,920,000 25 490 

Ships 

7,000,000 3,430,000 968,000 21,000 947,000 1.9 37 

5,000,000 3,430,000 1,980,000 105,000 1,870,000 9.4 190 

1,000,000 3,430,000 2,480,000 147,000 2,330,000 13 260 

Table 5. Facilities by Gasoline Loading Rate. 

Gasoline Loading Rate 

(million bbl/yr) Total Number of Facilities 

7 to 10 9 

5 to 7 8 

1 to 5 54 

8
Table 6. Nationwide Secondary Impacts of Operating Lean Oil Absorption 

Systems for an Average Facility 

 Option 

Annual gasoline threshold, bbl/yr 1,000,000 7,000,000 

Annual gasoline loaded, gal/yr (avg per facility) 2,210,000 7,000,000 

Electricity, kWhr/yr (avg per facility) 9,290,000 29,400,000 

SO2 emissions due to electric generation, ton (avg per facility) 18 56 

NOx emissions due to electric generation, ton (avg per facility) 7.0 22 

CO2 emissions due to electric generation, ton (avg per facility) 6,100 19,000 

Note: 

SO2 emission factor, ton/kwhr 1.90E-06 

NOx emission factor, ton/kwhr 7.50E-07 

CO2 emission factor, ton/kwhr 6.56E-04 

9
Attachment A

TYPICAL MTVLO FACILITY

Barges Ships/Ocean Barges

CAPITAL COSTS

Pre‐packaged

units

1,000,000 5,000,000 7,000,000 1,000,000 

Refrigerated Lean Oil

Absorption‐Barge

Refrigerated Lean Oil

Absorption‐Barge

Refrigerated Lean Oil

Absorption‐Barge

Refrigerated Lean Oil

Absorption‐Ship

Refri

Direct Costs

Purchased equipment costs

Unit + auxiliary equipment A $650,000 $650,000 $650,000 $1,200,000 

Instrumentation $0 $0 $0 $0 

Sales tax 0.03A $19,500 $19,500 $19,500 $36,000 

Freight 0.05A $32,500 $32,500 $32,500 $60,000 

Purchased equipment costs, PEC B=1.08A $702,000 $702,000 $702,000 $1,296,000 

Direct installation costs 0.075B $52,650 $52,650 $52,650 $97,200 

Total Direct Costs, DC 1.075B $754,650 $754,650 $754,650 $1,393,200 

Indirect Costs (Installation)

Total Indirect Costs, IC 0.075B $52,650 $52,650 $52,650 $97,200 

Total Capital Investment, TCI 1.15 B $807,300 $807,300 $807,300 $1,490,400 

ANNUAL COSTS

Refrigerated Lean Oil

Absorption‐Barge

Refrigerated Lean Oil

Absorption‐Barge

Refrigerated Lean Oil

Absorption‐Barge

Refrigerated Lean Oil

Absorption‐Ship

Refri

Direct Annual Costs

Operating Labor 0.5 hr/shift $29,618 $29,618 $29,618 $29,618 

Operator 0.15 of OperatorSupervisorOperating MaterialsMaintenanceLabor 0.5 hr/shift $30,445 $30,445 $30,445 $30,445 

Material 1.0 maintenance $30,445 $30,445 $30,445 $30,445 

Utilities/Electricity $0.006/gallon loa $252,000 $1,260,000 $1,764,000 $252,000 

Indirect Annual Costs

Administrative Charges, Property Tax, and

Insurance

0.04 TCI $32,292 $32,292 $32,292 $59,616 

Capital Recovery CRF TCI $114,960 $114,960 $114,960 $212,233 

Total Annual Cost, TAC $489,760 $1,497,760 $2,001,760 $614,357 
Attachment A

CAPITAL COSTS

Pre‐packaged

units

Direct Costs

Purchased equipment costsUnit + auxiliary equipment A

InstrumentationSales tax 0.03AFreight 0.05APurchased equipment costs, PEC B=1.08A

Direct installation costs 0.075B

Total Direct Costs, DC 1.075B

Indirect Costs (Installation)

Total Indirect Costs, IC 0.075B

OFFSHORE LOADING FACILITY

Barges Ships/Ocean Barges

1,000,000 5,000,000 7,000,000 1,000,000 

Refrigerated Lean Oil

Absorption‐Barge

Refrigerated Lean Oil

Absorption‐Barge

Refrigerated Lean Oil

Absorption‐Barge

Refrigerated Lean Oil

Absorption‐Ship

Refri

$1,495,000 $1,495,000 $1,495,000 $2,760,000 

$0 $0 $0 $0 

$44,850 $44,850 $44,850 $82,800 

$74,750 $74,750 $74,750 $138,000 

$1,614,600 $1,614,600 $1,614,600 $2,980,800 

$121,095 $121,095 $121,095 $223,560 

$1,735,695 $1,735,695 $1,735,695 $3,204,360 

$121,095 $121,095 $121,095 $223,560 

Total Capital Investment, TCI 1.15 B

ANNUAL COSTSDirect Annual Costs

Operating Labor 0.5 hr/shift

Operator 0.15 of OperatorSupervisorOperating MaterialsMaintenanceLabor 0.5 hr/shiftMaterial 1.0 maintenance

Utilities/Electricity $0.006/gallon loa

Indirect Annual Costs

Administrative Charges, Property Tax, and

Insurance

0.04 TCI

Capital Recovery CRF TCI

Total Annual Cost, TAC

$1,856,790 $1,856,790 $1,856,790 $3,427,920 

Refrigerated Lean Oil

Absorption‐Barge

Refrigerated Lean Oil

Absorption‐Barge

Refrigerated Lean Oil

Absorption‐Barge

Refrigerated Lean Oil

Absorption‐Ship

Refri

$29,618 $29,618 $29,618 $29,618 

$30,445 $30,445 $30,445 $30,445 

$30,445 $30,445 $30,445 $30,445 

$252,000 $1,260,000 $1,764,000 $252,000 

$74,272 $74,272 $74,272 $137,117 

$264,407 $264,407 $264,407 $488,136 

$681,186 $1,689,186 $2,193,186 $967,761 
Attachment B.  Nationwide Costs (Typical MTVLO; use 3.4 lb VOC/1000 gal for Barges)

Assumption:  5.0 % HAP content in gasoline

Gasoline throughput, bbl/yr 1,000,000 5,000,000 7,000,000

Total facilities covered 71 17 9

facilities loading 7 to 10 million bbl/yr 999

facilities loading 5 to 7 million bbl/yr 8 8 not covered

facilities loading 3 to 5 million bbl/yr 10 not covered not covered

facility loading 1 to 3  million bbl/yr 44 not covered not covered

HAP at 5.0% HAP at 5.0% HAP at 5.0%

TCI $57,318,300 $13,724,100 $7,265,700

TAC w/recovered $54,478,530 $25,920,743 $15,522,034

Average TAC (with recovery) per facility $767,303 $1,524,750 $1,724,670

VOC recovered 12,511 7,281 4,453

HAP recovered 625.6 364.0 222.7

Cost Effectiveness, $/ton VOC $4,354 $3,560 $3,486

Cost Effectiveness, $/ton HAP $87,086 $71,204 $69,712

CompareCosts_2011March17.xlsx

AttB_Nationwide Cost

Nationwide Costs (Typical MTVLO; use 1.8 lb VOC/1000 gal for Ships/Ocean Barges)

Assumption:  5.0 % HAP content in gasoline

Gasoline throughput, bbl/yr 1,000,000 5,000,000 7,000,000

Total facilities covered 71 17 9

facilities loading 7 to 10 million bbl/yr 999

facilities loading 5 to 7 million bbl/yr 8 8 not covered

facilities loading 3 to 5 million bbl/yr 10 not covered not covered

facility loading 1 to 3  million bbl/yr 44 not covered not covered

HAP at 5.0% HAP at 5.0% HAP at 5.0%

TCI $105,818,400 $25,336,800 $13,413,600

TAC w/recovered $66,622,076 $29,957,567 $17,816,964

Average TAC (with recovery) per facility $938,339 $1,762,210 $1,979,663

VOC recovered 6,624 3,854 2,358

HAP recovered 331.2 192.7 117.88

Cost Effectiveness, $/ton VOC $10,058 $7,772 $7,557

Cost Effectiveness, $/ton HAP $201,163 $155,443 $151,146

CompareCosts_2011March17.xlsx

AttB_Nationwide Cost

12
Attachment C. Nationwide Cost for Options (Average per Facility)

(Barge to Ship) (Barge to Ship) (Barge to Ship) (Barge to Ship) (Barge to Sh

7,000,000 Offshore $1,856,790 to $3,427,920 $1,916,097 to $2,333,066 24.74 to 13.10 494.8 to 262.0 $77,449 to $1

Existing <10/25 ton $807,300 to $1,490,400 $1,724,670 to $1,979,663 24.74 to 13.10 494.8 to 262.0 $69,712 to $1

1,000,000 Offshore $1,856,790 to $3,427,920 $641,602 to $946,804 3.570 to 1.871 70.69 to 37.42 $181,536 to $5

Existing <10/25 ton $807,300 to $1,490,400 $767,303 to $938,339 8.811 to 4.665 176.2 to 93.3 $87,086 to $2

"Existing <10/25 ton" subcategory is based on the Nationwide Costs and Nationwide Emission reductions, and then "averaged" by dividing by the number of facilities affected

"Offshore" subcategory is based on the model costs (capital multiplied by 1.3x to 2.3x; no change to most Annual costs, except the annualized capital cost) and the model emission red

HAP reduction, ton

(Avg per facility)

VOC reduction, ton (Avg

per facility)

Cost effectivenes

HAP

Gasolinethroughput,bbl/yr Subcategory

TCI (Avg per facility)

TAC, with recovery (Avg

per facility)