MEMORANDUM 

DATE: March 30, 2011

SUBJECT: Regulatory Alternative Impacts for ExxonMobil Group I Polymers and Resins 

Facilities Shutdown Procedures

FROM: Bradley Nelson, EC/R Incorporated

Lesley Stobert, EC/R Incorporated

TO: Nick Parsons, EPA/OAQPS/SPPD/RCG 

Paula Hirtz, EPA/OAQPS/SPPD/RCG

The purpose of this memorandum is to present estimated impacts of regulatory 

alternatives identified to reduce hazardous air pollutant (HAP) emissions from two source 

categories that are subject to the Group I Polymers and Resins National Emission Standards for 

HAP (NESHAP) – 40 CFR 63, subpart U during periods of process shutdown. These source 

categories are Butyl Rubber Production and Ethylene Propylene Rubber Production. The

regulatory alternatives were developed in consideration of comments received from 

ExxonMobil, which has facilities in both of these source categories, on the proposed changes to 

the NESHAP after the Risk and Technology Review (RTR) evaluation under section 112(d)(2), 

112(d)(6) and 112(f)(3) of the Clean Air Act (CAA). Section 1 provides background

information, followed by an identification of the regulatory alternatives in Section 2. Section 3 

summarizes the estimated costs and HAP emission reductions of the alternatives, and Section 4 

summarizes the secondary impacts.

1.0 BACKGROUND

EPA published a proposed rule and supplemental notice of proposed rulemaking in the 

Federal Register On October 21, 2010 (75 FR 65068) that took into consideration the residual 

risk and technology review analyses for several NESHAP, including five of the nine source 

categories regulated by the Group I Polymers and Resins NESHAP – Butyl Rubber Production, 

Epichlorohydrin Production, Ethylene Propylene Rubber Production, Neoprene Production, and 

Nitrile Butadiene Rubber Production. Sources of HAP emissions from these processes include 

raw material storage vessels, front-end process vents, back-end process operations, wastewater 

operations, and equipment leaks. The process “front-end” includes pre-polymerization, reaction, 

stripping, and material recovery operations; and the process “back-end” includes all operations 

after stripping (predominately drying and finishing). The emission sources regulated by the 

NESHAP for these source categories are storage tanks, front-end process vents, equipment leaks, 

and wastewater operations. 

In the proposed amendments to the Group I Polymers and Resins NESHAP, an 

exemption from the standards for periods of startup, shutdown, and malfunction that had been 

included in the rule was removed. After these proposed amendments were published in the 
2

Federal Register, ExxonMobil submitted comments and information stating that some processes 

at its facilities in the Butyl Rubber Production and Ethylene Propylene Rubber Production source 

categories regulated by the Group I Polymers and Resins NESHAP could not comply with the 

emissions standards during periods of shutdown. Specifically, ExxonMobil stated that it was not 

technically feasible to achieve 98 percent organic HAP control from a flare, which is used to 

control front-end process vents, due to low pressure in the front-end process vents during these 

periods. ExxonMobil estimates that there may be one to three shutdown events per year, and the 

upper limit of the amount of time that compliance with the emissions standards could not be met 

would be approximately 24 hours per shutdown event. Considering these comments, two 

regulatory alternatives were identified for processes controlled by flares in these source 

categories. 

2.0 REGULATORY ALTERNATIVES

Considering the information provided by ExxonMobil after the proposal, two regulatory 

alternatives were identified for processes controlled by flares during periods of shutdown for the 

Butyl Rubber Production and Ethylene Rubber Production source categories. The first 

alternative was to require the emissions standards be met until the organic HAP content in the 

stream is less than 50 parts per million by volume (ppmv), at which time emissions streams 

could be vented to the atmosphere. The second alternative was to require streams to continue to 

be sent to the flare until the unit is fully shut down. This alternative would require a pump to 

provide the necessary pressure to send the waning stream to the flare, once the organic HAP 

content in the stream is less than 50 ppmv. 

3.0 COSTS AND EMISSION REDUCTIONS OF REGULATORY ALTERNATIVES

As noted in Section 2, two regulatory alternatives were identified to address organic HAP

emissions from front-end process vents from the Butyl Rubber and Ethylene Propylene Rubber

Production source categories during periods of shutdown. The first alternative would require 

existing controls to be used until the level of HAP in the emissions stream was below 50 ppmv. 

The only impact of this alternative would be costs due to the labor associated with the 

calculations, records, and reports to demonstrate compliance. We estimate the labor associated 

with this documentation would be 2 technical labor hours, 0.1 management hour, and 0.2 clerical 

hours per event, and we assume there would be two shutdown events per facility per year. There 

are two facilities that produce butyl rubber: ExxonMobil in Baytown, TX and ExxonMobil in 

Baton Rouge, LA. These costs consider that both ExxonMobil butyl rubber processes would be 

included in the revised Butyl Rubber Production source category. There is one facility in the

Ethylene Propylene Rubber source category: ExxonMobil in Baton Rouge, LA. The estimated 

costs for the first alternative are summarized in Table 1.
3

Table 1. Estimated Impacts for Shutdown Regulatory Alternative 1

Source Category

Emission 

Reduction 

(tpy)

Capital Costs 

($)

Annual 

Costs ($/yr)1

Cost 

Effectiveness 

($/ton)

Butyl Rubber Production 0 $0 $443 N/A

Ethylene Propylene 

Rubber Production 0 $0 $221 N/A

1 The costs associated with this alternative are for labor to produce the necessary documentation for compliance. 

Labor rates based on United States Department of Labor, Bureau of Labor Statistics for NAICS 325200, May 2009 

information, available at http://www.bls.gov/oes/current/naics4_325200.htm. Wages for technical labor are based 

on "Production occupations: Chemical Equipment Operators & Tenders" with a total compensation of $23.38/hour. 

Wages for management labor are taken from "Production occupations: First-line supervisors/managers of 

production and operating workers" with a total compensation of $31.20/hour. Wages for clerical labor are based on 

"Office and administrative support occupations: Office clerks general" with a total compensation of $14.22/hour.

The second alternative would require that the emissions standards be met during the 

entire shutdown event. The costs of this alternative are for one 25-horsepower pump per facility

that would be operated only during shutdown events to obtain the pressure necessary to continue 

to send the emissions stream(s) to the flare. It is assumed these pumps would be operated for 24 

hours per shutdown event and that there would be two shutdown events per year per facility. It 

is also assumed that the flare would achieve a 98 percent HAP destruction efficiency. Table 2

presents the costs of this second regulatory alternative. These costs consider that both 

ExxonMobil butyl rubber processes would be included in the revised Butyl Rubber Production 

source category. Details of these costs estimates are provided in Attachments 1 and 2.
4

Table 2. Estimated Impacts for Shutdown Regulatory Alternative 2

Parameter

Butyl Rubber 

Production Source 

Category 

Ethylene 

Propylene Rubber

Source Category

HAP emissions (TPY)1 0.15 0.09

Pump

Capital Cost $4,268 $2,134

Capital Recovery $469 $234

Flare 

Labor $340 $170

Maintenance Materials $154 $77

Natural Gas $16,000 $3,857

Steam $1,309 $316

Overhead $297 $148

Total Annual Cost $18,568 $4,802

HAP Reduction (TPY) 0.14 0.09

HAP Cost Effectiveness ($/Ton) $130,163 $53,390

HAP Emission After Control 

(TPY) 0.003 0.002

1 HAP emissions associated with a 50 ppmv HAP content stream for 48 hours annually

4.0 SECONDARY ENVIRONMENTAL IMPACTS

While the primary impact of the regulatory alternatives is to address organic HAP 

emissions that would be controlled with a flare during shutdown periods, the application of the 

control technologies that would be required under the second regulatory alternative can also have 

other environmental effects. These impacts can be positive, such as a reduction in non-HAP 

volatile organic compound air emissions; or negative, such as the generation of additional 

wastewater or energy consumption. In this section the secondary impacts on air pollution, water 

pollution, and energy are discussed. The methodologies used to calculate secondary impacts can 

be found in documentation for the MACT standard.1

 1 Memorandum. Estimated Regulatory Alternative Impacts for Elastomer Production Facilities (Polymers and 

Resins I). Norwood, P., EC/R, to Evans, L., EPA/OAQPS/ESD/OCG. May 10, 1995. Contained in Hazardous Air 

Pollutant Emissions from Process Units in the Elastomer Manufacturing Industry--Supplementary Information 

Document for Proposed Standards. EPA-453/R-95-005a. May 1995.
5

Air Pollution

For the ExxonMobil facilities for which we have performed a cost and impact analysis, 

the secondary air pollution impacts are the increased criteria pollutant emissions caused by the 

on-site combustion of organic HAPs and fuels. This combustion results in the emission of 

nitrogenous oxides (NOx), carbon monoxide (CO), particulate matter (PM), and sulfur dioxide 

(SO2). In addition to these five criteria pollutants, emissions of carbon dioxide (CO2) are also 

expected. Table 3 presents the revised estimated secondary air impacts for regulatory alternative 

2. 

Table 3. Secondary Air Impacts for Shutdown Regulatory Alternative 2

Source Category Emissions (tpy)

PM SO2 NOX CO CO2

Butyl Rubber Production 2.43 0.49 0.01 28.36 97,225

Ethylene Propylene Rubber

Production 0.201 0.040 0.001 2.345 8,042

Water Pollution

No impact on water pollution for the second regulatory alternative is anticipated. Control 

of organic HAP emissions using combustion only does not result in any significant increase in 

wastewater discharge, since no water effluents are generated by a flare. 

Energy Impacts

The energy demands associated with the control technologies for the second regulatory 

alternatives include the need for additional natural gas. The total nationwide energy demands 

that would result from implementing regulatory alternative 2 is presented in Table 4. More 

details about the methodologies used can be found in the MACT documentation.2

 

Table 4. Energy Requirements for Shutdown Regulatory Alternative 2

Source Category

Pump and Continued Use of the Flare

Natural Gas Cost 

($/yr)

Natural Gas 

(Mscf/yr)

Butyl Rubber Production $46,437 8,879

Ethylene Propylene Rubber

Production $3,841 734

 2 See footnote 1
Attachment 1

Capital and Annual Cost Summary Sheets
Cost Parameters Estimate

HAP emissions (TPY) 0.0918

Pump

Capital Cost $2,134

Capital Recovery $234

Flare 

Labor $170

Maintenance Materials $77

Natural Gas $34,354

Steam $2,812

Overhead $148

Total Annual Cost $37,796

HAP Reduction (TPY) 0.0899

HAP Cost Effectiveness ($/Ton) $420,202

HAP Emission After Control (TPY) 0.0018

Assumptions:

50 ppm Hexane concentration

5,700 scfm vent gas flow rate

2 Shutdowns/year for 24 hours/shutdown or 48 hours/year

Flare achieves 98% reduction of HAP

Costs include:

1 - 25 HP Pump

Natural gas needed to operate flare

Labor to operate flare

Table 1. Capital and Annual Costs for Alternative 2 for Baytown 

Butyl Rubber 
Table 2. Capital and Annual Costs for Alternative 2 for Baton Rouge 

Butyl Rubber

Cost Parameters Estimate

HAP emissions (TPY) 0.0538

Pump

Capital Cost $2,134 

Capital Recovery $234 

Flare 

Labor $170

Maintenance Materials $77

Natural Gas $12,143

Steam $993

Overhead $148

Total Annual Cost $13,766 

HAP Reduction (TPY) 0.0527 

HAP Cost Effectiveness ($/Ton) $261,191 

HAP Emission After Control (TPY) 0.0011 

Assumptions:

50 ppm Hexane concentration

641 scfm vent gas flow rate

2 Shutdowns/year for 24 hours/shutdown or 48 

hours/year

Flare achieves 98% reduction of HAP

Costs include:

1 - 25 HP Pump

Natural gas needed to operate flare

Labor to operate flare
Cost Parameters Estimate

HAP emissions (TPY) 0.0918

Pump

Capital Cost $2,134

Capital Recovery $234

Flare 

Labor $170

Maintenance Materials $77

Natural Gas $3,857

Steam $316

Overhead $148

Total Annual Cost $4,802

HAP Reduction (TPY) 0.0899

HAP Cost Effectiveness ($/Ton) $53,390

HAP Emission After Control (TPY) 0.0018

Assumptions:

50 ppm Hexane concentration

641 scfm vent gas flow rate

2 Shutdowns/year for 24 hours/shutdown or 48 hours/year

Flare achieves 98% reduction of HAP

Costs include:

1 - 25 HP Pump

Natural gas needed to operate flare

Labor to operate flare

Table 3. Capital and Annual Costs for Alternative 2 for Butyl 

Rubber (Baytown and Baton Rouge Facilities)
Cost Parameters Estimate

HAP emissions (TPY) 0.0918

Pump

Capital Cost $2,134

Capital Recovery $234

Flare 

Labor $170

Maintenance Materials $77

Natural Gas $3,857

Steam $316

Overhead $148

Total Annual Cost $4,802

HAP Reduction (TPY) 0.0899

HAP Cost Effectiveness ($/Ton) $53,390

HAP Emission After Control (TPY) 0.0018

Assumptions:

50 ppm Hexane concentration

641 scfm vent gas flow rate

2 Shutdowns/year for 24 hours/shutdown or 48 hours/year

Flare achieves 98% reduction of HAP

Costs include:

1 - 25 HP Pump

Natural gas needed to operate flare

Labor to operate flare

Table 4. Capital and Annual Costs for Alternative 2 for Baton 

Rouge Ethylene Propylene Rubber 
Attachment 2

Control Device Capital and Annual Cost Spreadsheets
TOTAL ANNUAL COST SPREADSHEET PROGRAM--FLARES [1] 

Baytown Butyl Rubber

COST BASE DATE: March 1990 [2]

VAPCCI (Fourth Quarter 1998--FINAL): [3] 102

INPUT PARAMETERS

Vent flowrate (acfm): 7164.057088 Converted from scfm

(lb/hr): 25753.88763 Calculated using scfm and density

(scfm): 5,700 Calculated from Heat Content Spreadsheet

-- Vent heat content (BTU/scf): 0.23 Calculated from Heat Content Spreadsheet

-- Fuel density (lb/scf): 0.042016807 AP-42

-- Fuel heat content (BTU/scf): 1050 AP-42

-- Vent gas temperature (oF): 203.5 ICR

-- Vent stream density (lb/scf): 0.0753 Assume density of air

-- Vent gas pressure (psig): [4] 100 Estimate

-- Liquid density (lb/ft3): 62.4 AP-42

DESIGN PARAMETERS

-- Gas velocity, max. (ft/sec): 60

-- Auxil. fuel requirement (scfm): 2278.333908

 (lb/hr): 5743.698928

-- Total gas flowrate (scfm): 7978.618908

 (acfm): 1263.121811

 (lb/hr): 31497.58656

-- Flare tip diameter (in.)--actual: 8.947085826

 --rounded: 10

-- Heat release rate (BTU/hr): 143615140.3

-- Flare height (ft): 67.61221707

-- KO drum max. velocity (ft/sec): 5.753903923

-- KO drum min. diameter (in)--actual: 61.67955833

 --rounded: 66

-- KO drum height (in): 198

-- KO drum thickness (in): (see table below) 0.37

-- No. of pilot burners: (see table below) 1

CAPITAL COSTS

Equipment Costs ($):

-- Flare/self-supported: $48,418

-- Flare/guy-supported: $0

-- Flare/derrick-supported: $0

 -------------

 Minimum flare cost: $48,418

 Knockout drum cost: $8,798

 Transport piping cost: [5] $2,261

 Auxiliaries cost: $0

 --------------

-- Total equipment (base): $59,477

 ' ' (escalated): $66,206

Purchased Equipment Cost ($): $78,123

Total Capital Investment ($): $149,995

= = = = =

ANNUAL COST INPUTS

Operating factor (hr/yr): 48

Operating labor rate ($/hr): 23.38 2009 Technical labor rate

Maintenance labor rate ($/hr): 25.718 Operator labor rate*1.1

Operating labor factor (hr/yr): 3.452054795

Maintenance labor factor (hr/sh): 0.5

Steam price ($/1000 lb): 4.65

Natural gas price ($/mscf): 5.23

Annual interest rate (fraction): 0.07

Control system life (years): 15

Capital recovery factor: 0.109794625

Taxes, insurance, admin. factor: 0.04

ANNUAL COSTS

 Item Cost ($/yr) Wt. Factor W.F.(cond.)

--------------------------------------------------------------------------------------------------------------------- ------------------------

Operating labor $81 0.001344468 ----

Supervisory labor $12 0.00020167 ----

Maintenance labor $77 0.001285247 ----

Maintenance materials $77 0.001285247 ----

Natural gas $34,354 0.572283631 ----

Steam $2,812 0.046844613 ----

Overhead $148 0.002469979 0.006586611

Taxes, insurance, administrative $6,000 0.099946215 ----

Capital recovery $16,469 0.27433893 0.374285145

--------------------------------------------------------------------------------------------------------------------- ------------------------

Total Annual Cost $60,030 1 1

NOTES:

-------------------

[1] Data used to develop this spreadsheet were taken from Chapter 7 of

the 'OAQPS Control Cost Manual' (5th edition).
[2] Base equipment costs reflect this date.

[3] VAPCCI = Vatavuk Air Pollution Control Cost Index (for flares)

corresponding to year and quarter shown. Base equipment cost, purchased

equipment cost, and total capital investment have been escalated to this

date via the VAPCCI and control equipment vendor data.

[4] The fuel usage and other calculations are based on the vent stream pressure,

which equals the pressure at the flare tip (1 psig, in this case). However, the system

pressure is usually higher (approximately 10 psig).

[5] Pertains to 100 feet of piping, the minimum length recommended. For greater lengths, piping

cost would be prorated by ratio of length to 100 feet (e.g., cost @ 200 ft. = 2 x cost @ 100 ft.).

Lookup Table for Knockout Drum Vessel Diameter vs. Thickness

Diameter (in.) Thickness (in.)

----------------------- -----------------------------------------------------------------------

0 0.25

36 0.37

72 0.5

108 0.75

144 1

Lookup Table for Number of Pilot Burners vs. Flare Tip Diameter

Diameter (in.) # Burners

------------------------------------------------------------------------------------------------

1 1

12 2

30 3

60 4
Flare Average Pollutant Heat Content Calculations

Baytown Butyl Rubber

Component

NEI Emissions 

(lb/hr)

Molecular 

Weight (lb/lbmole)

Volumetric 

Flow Rate 

(scf/min) -ΔHc (KJ/mole)

Heat of 

Combustion 

(Btu/lb)

Heat of 

Combustion 

(Btu/scf)

Volume 

Fraction of 

Component in 

Exhaust Gas

Vent Heat 

Content 

(Btu/scf)

VOC 44.09 0.0 2220 21,665 2,479 0.00E+00 0

Methane 16.04 0.00 890.4 23,884 994 0.00E+00 0

Ethane 30.07 0.00 1559.9 22,321 1,742 0.00E+00 0

Other HAP 44.09 0.00 2220 21,665 2,479 0.00E+00 0

Hexanes 3.82 86.17 0.285 4194.8 20,946 4,684 5.00E-05 0.23

Methyl Chloride 50.49 0.00 841.8 7,174 940 0.00E+00 0

1,3-Butadiene 54.09 0.00 0 0 0 0.00E+00 0

Xylenes 106.16 0.00 4595.2 18,625 5,132 0.00E+00 0

Vent Gas 5,700 0 0 0 1.00E+00 0

Total 3.82 5,700 1.00E+00 0.23

Data Source: ICR Emissions rates & Exxon control device design flow rate.

Assume 50 ppm HAP is 50 ppm Hexane

50 ppm Hexane = 3.824310927 lb/hr
PUMPS

Baytown Butyl Rubber

The EPA Control Cost Manual does not have specific cost equations for pumps. 

25-HP Pump $2,134

Total Cost $2,134

Annual interest rate (fraction): 0.07

Control system life (years): 15

Capital recovery factor: 0.109795

Capital recovery $234.30

Data Source: http://www.grainger.com/Grainger/CENTURY-CloseCoupled-Pump-Motor-1XKP3
TOTAL ANNUAL COST SPREADSHEET PROGRAM--FLARES [1] 

Baton Rouge Butyl Rubber

COST BASE DATE: March 1990 [2]

VAPCCI (Fourth Quarter 1998--FINAL): [3] 102

INPUT PARAMETERS

Vent flowrate (acfm): 2529.018219 Converted from scfm

(lb/hr): 9091.50363 Calculated using scfm and density

(scfm): 2,012 Calculated from Heat Content Spreadsheet

-- Vent heat content (BTU/scf): 0.13 Calculated from Heat Content Spreadsheet

-- Fuel density (lb/scf): 0.042016807 AP-42

-- Fuel heat content (BTU/scf): 1050 AP-42

-- Vent gas temperature (oF): 203.5 ICR

-- Vent stream density (lb/scf): 0.0753 Assume density of air

-- Vent gas pressure (psig): [4] 100 Estimate

-- Liquid density (lb/ft3): 62.4 AP-42

DESIGN PARAMETERS

-- Gas velocity, max. (ft/sec): 60

-- Auxil. fuel requirement (scfm): 804.5567764

 (lb/hr): 2028.294394

-- Total gas flowrate (scfm): 2816.841776

 (acfm): 445.943631

 (lb/hr): 11119.79802

-- Flare tip diameter (in.)--actual: 5.31617133

 --rounded: 6

-- Heat release rate (BTU/hr): 50703151.98

-- Flare height (ft): 40.17376574

-- KO drum max. velocity (ft/sec): 5.753903923

-- KO drum min. diameter (in)--actual: 36.64693983

 --rounded: 42

-- KO drum height (in): 126

-- KO drum thickness (in): (see table below) 0.37

-- No. of pilot burners: (see table below) 1

CAPITAL COSTS

Equipment Costs ($):

-- Flare/self-supported: $26,546

-- Flare/guy-supported: $0

-- Flare/derrick-supported: $0

 -------------

 Minimum flare cost: $26,546

 Knockout drum cost: $4,519

 Transport piping cost: [5] $1,175

 Auxiliaries cost: $0

 --------------

-- Total equipment (base): $32,241

 ' ' (escalated): $35,888

Purchased Equipment Cost ($): $42,348

Total Capital Investment ($): $81,307

= = = = =

ANNUAL COST INPUTS

Operating factor (hr/yr): 48

Operating labor rate ($/hr): 23.38 2009 Technical labor rate
Maintenance labor rate ($/hr): 25.718 Operator labor rate*1.1

Operating labor factor (hr/yr): 3.452054795

Maintenance labor factor (hr/sh): 0.5

Steam price ($/1000 lb): 4.65

Natural gas price ($/mscf): 5.23

Annual interest rate (fraction): 0.07

Control system life (years): 15

Capital recovery factor: 0.109794625

Taxes, insurance, admin. factor: 0.04

ANNUAL COSTS

 Item Cost ($/yr) Wt. Factor W.F.(cond.)

------------------------------------------------------------------------------------------------------------------------ ------------------------

Operating labor $81 0.003139109 ----

Supervisory labor $12 0.000470866 ----

Maintenance labor $77 0.003000839 ----

Maintenance materials $77 0.003000839 ----

Natural gas $12,143 0.472300217 ----

Steam $993 0.038613159 ----

Overhead $148 0.005766992 0.015378646

Taxes, insurance, administrative $3,252 0.126495321 ----

Capital recovery $8,927 0.347212658 0.473707979

------------------------------------------------------------------------------------------------ ------------------------------------------------

Total Annual Cost $25,711 1 1

NOTES:

-------------------

[1] Data used to develop this spreadsheet were taken from Chapter 7 of

the 'OAQPS Control Cost Manual' (5th edition).

[2] Base equipment costs reflect this date.

[3] VAPCCI = Vatavuk Air Pollution Control Cost Index (for flares)

corresponding to year and quarter shown. Base equipment cost, purchased

equipment cost, and total capital investment have been escalated to this

date via the VAPCCI and control equipment vendor data.

[4] The fuel usage and other calculations are based on the vent stream pressure,

which equals the pressure at the flare tip (1 psig, in this case). However, the system

pressure is usually higher (approximately 10 psig).

[5] Pertains to 100 feet of piping, the minimum length recommended. For greater lengths, piping

cost would be prorated by ratio of length to 100 feet (e.g., cost @ 200 ft. = 2 x cost @ 100 ft.).

Lookup Table for Knockout Drum Vessel Diameter vs. Thickness

Diameter (in.) Thickness (in.)

------------------------------------------------------------------------ ------------------------

0 0.25

36 0.37

72 0.5

108 0.75

144 1

Lookup Table for Number of Pilot Burners vs. Flare Tip Diameter

Diameter (in.) # Burners

------------------------------------------------------------------------------------------------

1 1

12 2

30 3

60 4
Flare Average Pollutant Heat Content Calculations

Baton Rouge Butyl Rubber

Component

NEI Emissions 

(lb/hr)

Molecular 

Weight (lb/lbmole)

Volumetric 

Flow Rate 

(scf/min) -ΔHc (KJ/mole)

Heat of 

Combustion 

(Btu/lb)

Heat of 

Combustion 

(Btu/scf)

Volume 

Fraction of 

Component in 

Exhaust Gas

Vent Heat 

Content 

(Btu/scf)

VOC 44.09 0.0 2220 21,665 2,479 0.00E+00 0

Methane 16.04 0.00 890.4 23,884 994 0.00E+00 0

Ethane 30.07 0.00 1559.9 22,321 1,742 0.00E+00 0

Other HAP 44.09 0.00 2220 21,665 2,479 0.00E+00 0

Hexanes 86.17 0.000 4194.8 20,946 4,684 0.00E+00 0

Methyl Chloride 2.24 50.49 0.29 841.8 7,174 940 1.42E-04 0.133

1,3-Butadiene 54.09 0.00 0 0 0 0.00E+00 0

Xylenes 106.16 0.00 4595.2 18,625 5,132 0.00E+00 0

Vent Gas 2,012 0 0 0 1.00E+00 0

Total 2.24 2,012 1.00E+00 0.133

Data Source: ICR Emissions rates & Exxon control device design flow rate.

Assume 50 ppm HAP is 50 ppm Methyl Chloride

50 ppm Methyl Chloride = 2.240796782 lb/hr
PUMPS

Baton Rouge Butyl Rubber

The EPA Control Cost Manual does not have specific cost equations for pumps. 

25-HP Pump $2,134

Total Cost $2,134

Annual interest rate (fraction): 0.07

Control system life (years): 15

Capital recovery factor: 0.109795

Capital recovery $234.30

Data Source: http://www.grainger.com/Grainger/CENTURY-CloseCoupled-Pump-Motor-1XKP3
TOTAL ANNUAL COST SPREADSHEET PROGRAM--FLARES [1] 

Baton Rouge Ethylene Propylene Rubber

COST BASE DATE: March 1990 [2]

VAPCCI (Fourth Quarter 1998--FINAL): [3] 102

INPUT PARAMETERS

Vent flowrate (acfm): 805.7589145 Converted from scfm

(lb/hr): 2896.602343 Calculated using scfm and density

(scfm): 641 Calculated from Heat Content Spreadsheet

-- Vent heat content (BTU/scf): 2.08 Calculated from Heat Content Spreadsheet

-- Fuel density (lb/scf): 0.042016807 AP-42

-- Fuel heat content (BTU/scf): 1050 AP-42

-- Vent gas temperature (oF): 203.5 ICR

-- Vent stream density (lb/scf): 0.0753 Assume density of air

-- Vent gas pressure (psig): [4] 100 Estimate

-- Liquid density (lb/ft3): 62.4 AP-42

DESIGN PARAMETERS

-- Gas velocity, max. (ft/sec): 60

-- Auxil. fuel requirement (scfm): 254.669872

 (lb/hr): 642.0248873

-- Total gas flowrate (scfm): 895.7947818

 (acfm): 141.8162642

 (lb/hr): 3538.62723

-- Flare tip diameter (in.)--actual: 2.997933579

 --rounded: 4

-- Heat release rate (BTU/hr): 16124306.07

-- Flare height (ft): 30

-- KO drum max. velocity (ft/sec): 5.753903923

-- KO drum min. diameter (in)--actual: 20.68541773

 --rounded: 24

-- KO drum height (in): 72

-- KO drum thickness (in): (see table below) 0.25

-- No. of pilot burners: (see table below) 1

CAPITAL COSTS

Equipment Costs ($):

-- Flare/self-supported: $18,777

-- Flare/guy-supported: $0

-- Flare/derrick-supported: $0

 -------------

 Minimum flare cost: $18,777

 Knockout drum cost: $1,484

 Transport piping cost: [5] $699

 Auxiliaries cost: $0

 --------------

-- Total equipment (base): $20,960

 ' ' (escalated): $23,331

Purchased Equipment Cost ($): $27,531

Total Capital Investment ($): $52,859

= = = = =

ANNUAL COST INPUTS

Operating factor (hr/yr): 48

Operating labor rate ($/hr): 23.38 2009 Technical labor rate
Maintenance labor rate ($/hr): 25.718 Operator labor rate*1.1

Operating labor factor (hr/yr): 3.452054795

Maintenance labor factor (hr/sh): 0.5

Steam price ($/1000 lb): 4.65

Natural gas price ($/mscf): 5.23

Annual interest rate (fraction): 0.07

Control system life (years): 15

Capital recovery factor: 0.109794625

Taxes, insurance, admin. factor: 0.04

ANNUAL COSTS

 Item Cost ($/yr) Wt. Factor W.F.(cond.)

------------------------------------------------------------------------------------------------------------------------ ------------------------

Operating labor $81 0.006463953 ----

Supervisory labor $12 0.000969593 ----

Maintenance labor $77 0.006179231 ----

Maintenance materials $77 0.006179231 ----

Natural gas $3,857 0.308878364 ----

Steam $316 0.025302591 ----

Overhead $148 0.011875205 0.031667214

Taxes, insurance, administrative $2,114 0.169339009 ----

Capital recovery $5,804 0.464812822 0.634151831

------------------------------------------------------------------------------------------------ ------------------------------------------------

Total Annual Cost $12,486 1 1

NOTES:

-------------------

[1] Data used to develop this spreadsheet were taken from Chapter 7 of

the 'OAQPS Control Cost Manual' (5th edition).

[2] Base equipment costs reflect this date.

[3] VAPCCI = Vatavuk Air Pollution Control Cost Index (for flares)

corresponding to year and quarter shown. Base equipment cost, purchased

equipment cost, and total capital investment have been escalated to this

date via the VAPCCI and control equipment vendor data.

[4] The fuel usage and other calculations are based on the vent stream pressure,

which equals the pressure at the flare tip (1 psig, in this case). However, the system

pressure is usually higher (approximately 10 psig).

[5] Pertains to 100 feet of piping, the minimum length recommended. For greater lengths, piping

cost would be prorated by ratio of length to 100 feet (e.g., cost @ 200 ft. = 2 x cost @ 100 ft.).

Lookup Table for Knockout Drum Vessel Diameter vs. Thickness

Diameter (in.) Thickness (in.)

------------------------------------------------------------------------ ------------------------

0 0.25

36 0.37

72 0.5

108 0.75

144 1

Lookup Table for Number of Pilot Burners vs. Flare Tip Diameter

Diameter (in.) # Burners

------------------------------------------------------------------------------------------------

1 1

12 2

30 3

60 4
Flare Average Pollutant Heat Content Calculations

Baton Rouge Ethylene Propylene Rubber

Component

NEI Emissions 

(lb/hr)

Molecular 

Weight (lb/lbmole)

Volumetric 

Flow Rate 

(scf/min) -ΔHc (KJ/mole)

Heat of 

Combustion 

(Btu/lb)

Heat of 

Combustion 

(Btu/scf)

Volume 

Fraction of 

Component in 

Exhaust Gas

Vent Heat 

Content 

(Btu/scf)

VOC 44.09 0.0 2220 21,665 2,479 0.00E+00 0

Methane 16.04 0.00 890.4 23,884 994 0.00E+00 0

Ethane 30.07 0.00 1559.9 22,321 1,742 0.00E+00 0

Other HAP 44.09 0.00 2220 21,665 2,479 0.00E+00 0

Hexanes 3.82 86.17 0.285 4194.8 20,946 4,684 4.45E-04 2.08

Methyl Chloride 50.49 0.00 841.8 7,174 940 0.00E+00 0

1,3-Butadiene 54.09 0.00 0 0 0 0.00E+00 0

Xylenes 106.16 0.00 4595.2 18,625 5,132 0.00E+00 0

Vent Gas 641 0 0 0 1.00E+00 0

Total 3.82 641 1.00E+00 2.08

Data Source: ICR Emissions rates & Exxon control device design flow rate.

Assume 50 ppm HAP is 50 ppm Hexane

50 ppm Hexane = 3.824310927 lb/hr
PUMPS

Baton Rouge Ethylene Propylene Rubber

The EPA Control Cost Manual does not have specific cost equations for pumps. 

25-HP Pump $2,134

Total Cost $2,134

Annual interest rate (fraction): 0.07

Control system life (years): 15

Capital recovery factor: 0.109795

Capital recovery $234.30

Data Source: http://www.grainger.com/Grainger/CENTURY-CloseCoupled-Pump-Motor-1XKP3