FROM: Cindy Hancy, RTI International 

TO: Jodi Howard, EPA/OAQPS 

FOR: EPA Docket No. EPA-HQ-OAR-2010-0869 

DATE: December 21, 2011 

SUBJECT: Analysis of Emissions Reduction Techniques for Equipment Leaks 

1. Purpose

This memorandum documents a general review and analysis of emissions reduction techniques 

for equipment leaks. It reviews control alternatives and estimates the costs and environmental 

impacts for the alternatives identified. 

2. Legislative Background

The Clean Air Act (CAA) requires the U.S. Environmental Protection Agency (EPA) to review 

promulgated standards periodically to ensure new source performance standards (NSPS) and 

national emissions standards for hazardous air pollutants (NESHAP) reflect advances in 

emissions reduction technology. Specifically, Section 112(d)(6) of the Clean Air Act (CAA) 

states that “[t]he Administrator shall review, and revise as necessary (taking into account 

developments in practices, processes, and control technologies), emission standards promulgated 

under this section no less often than every 8 years.” Similarly, Section 111(b)(1)(B) requires 

EPA to review NSPS for a given source category every 8 years, and, if appropriate, revise such 

standards. To facilitate these required reviews, EPA is evaluating key emission sources that exist 

across several source categories to provide a consistent framework for regulating emissions from 

these sources. This memorandum provides information that may be considered in the course of 

conducting a technology review for equipment leak emissions from a specific source category in 

the future. 

3. Introduction

Equipment leak standards are designed to reduce or eliminate emissions of volatile organic 

compounds (VOCs), volatile hazardous air pollutants (VHAPs), and organic hazardous air 

pollutants (HAPs) from piping and equipment found in various manufacturing processes. Many 

federal regulations have been written to minimize air emissions from equipment leaks. Currently, 

most equipment leaks are defined within regulations primarily on the basis of a detection 

instrument that reads the airborne concentration of volatile organic carbons at a potential leak 

point on a parts per million (ppm) basis or on the basis of visual observation of certain types of 

equipment. Generally, if the leak exceeds the threshold, or leak definition, of the applicable 
Technical Memorandum – Analysis of Emissions Reduction Techniques for Equipment Leaks 

December 21, 2011 

2

regulation, repair of the leaking equipment is required. This memorandum considers methods to 

reduce emissions from equipment leaks and analyzes the impacts associated with these methods 

(EPA, 1998). 

4. Description of Emission Releases

Emissions from equipment leaks occur in the form of gases or liquids that escape to the 

atmosphere through many types of connection points (e.g., flanges, threaded fittings) or through 

the moving parts of valves, pumps, compressors, pressure relief devices, and certain types of 

process equipment (EPA, 1998). 

Pumps

Pumps are used extensively in chemical manufacturing facilities for moving fluids. The most 

widely used pump is the centrifugal pump. Other types of pumps include positive-displacement, 

reciprocating and rotary action, and special canned-motor and diaphragm pumps. Chemicals 

transferred by pumps can leak at the point of contact between the moving shaft and stationary 

casing. To isolate the pump’s interior from the atmosphere, all pumps, except the sealless type 

(canned-motor and diaphragm), require a seal at the point where the shaft penetrates the housing. 

The most commonly used seals in these pumps are packed and mechanical. However, no seal 

system is perfect, and many pumps are equipped with a closed-vent system. 

Compressors

Centrifugal, reciprocating, and rotary compressors are used in chemical manufacturing facilities. 

The centrifugal compressor uses a rotating element or series of elements containing curved 

blades to increase the pressure of a gas by centrifugal force. Reciprocating and rotary 

compressors increase pressure by confining the gas in a cavity and progressively decreasing the 

volume of the cavity. Reciprocating compressors usually use a piston and cylinder arrangement, 

while rotary compressors use rotating elements such as lobed impellers or sliding vanes. 

As with pumps, seals are required to prevent leakage from compressors. Rotary shaft seals for 

compressors may be labyrinth, restrictive carbon rings, mechanical contact, or liquid film. All of 

these seals are leak restriction devices, but none of them completely eliminate leakage. To 

respond to leakage, many compressors are equipped with ports in the seal area that evacuate 

collected gases to a control device. 

Pressure Relief Devices

Engineering codes require the use of pressure-relieving devices or systems in applications where 

the process pressure may exceed the maximum allowable working pressure of the vessel. The 

pressure relief valve is the most common type of pressure-relieving device used. Typically, relief 

valves are spring-loaded and designed to open when the system pressure exceeds a set pressure, 

allowing the release of vapors or liquids until the system pressure is reduced to its normal 

operating level. When the normal pressure is re-attained, the valve reseats and a seal is again 

formed. The seal is a disc on a seat, and a leak through this seal is a potential source of fugitive 

VOC and HAP emissions. The potential causes of leakage from relief valves are improper 
Technical Memorandum – Analysis of Emissions Reduction Techniques for Equipment Leaks 

December 21, 2011 

3

reseating of the valve after a relieving operation (which occurs when the system pressure comes 

close to the set pressure of the valve); and corrosion or degradation of the valve seat. Some 

pressure relief devices can be vented to a closed vent system for emissions control. 

Rupture discs also may be used to relieve pressure in process units. These discs are made of a 

material that ruptures when a set pressure is exceeded, thus allowing the system to depressurize. 

The advantage of a ruptured disc is that the disc seals tightly and does not allow any emissions to 

escape from the system during normal operations. When the disc ruptures, however, the system 

will depressurize until atmospheric conditions are obtained (and then remain open to the 

atmosphere until the disk is replaced), unless the disc is used with a pressure relief valve. 

Sampling Connections

Process unit operations are checked periodically by routine analysis of feedstocks and products. 

To obtain representative samples for these analyses, sampling lines first must be purged. If the 

flushed fluid is a liquid, it could be drained onto the ground or into a process drain where it 

would evaporate and release emissions to the atmosphere. Gas streams could be purged directly 

to the atmosphere. Closed-loop sampling systems control the purged process fluid by returning it 

directly to the process line, collecting and recycling the fluid, or transporting the fluid to a 

control device. 

Open-ended Lines

Some valves are installed in a system to function with downstream lines open to the atmosphere. 

Open-ended lines, which are used mainly in intermittent service for sampling and venting, 

include purge, drain, and sampling lines. Some open-ended lines are needed to preserve product 

purity. Normally, these are installed between multi-use product lines to prevent products from 

collecting in cross-tie lines during valveseat leakage. A faulty valve seat or incompletely closed 

valve would result in leakage through the valve, releasing emissions to the atmosphere. As 

described in section 5, a cap, plug, blind flange, or secondary valve is used at the end of the 

open-ended line to prevent those emissions from reaching the atmosphere. 

Process Valves

One of the most common types of equipment included in an equipment leak detection and repair 

program is the process valve. Commonly used types are control, globe, gate, plug, ball, relief, 

and check valves. All except the relief valve and check valve are activated through a valve stem, 

which may have either a rotational or linear motion, depending on the design. The valve stem 

requires a seal to isolate the process fluid inside the valve from the atmosphere. The possibility 

of a leak through this seal makes it a potential source of fugitive emissions. A check valve 

typically is not a potential source of fugitive emissions because it has no stem or packing gland; 

however, some check valves have a hinge that penetrates the valve housing, which is a potential 

source of fugitive emissions. 

The stem can be sealed to prevent leakage by using a packing gland or O-ring seals. Valves that 

require the stem to move in and out with or without rotation must use a packing gland. 

Conventional packing glands are suited for a wide variety of packing material. Packing materials 
Technical Memorandum – Analysis of Emissions Reduction Techniques for Equipment Leaks 

December 21, 2011 

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include graphite, graphite-impregnated fibers, and tetrafluorethylene polymer. The packing 

material used depends on the valve application and configuration. These conventional packing 

glands can be used over a range of operating temperatures, but at high pressures, these glands 

must be tight to obtain a good seal. 

Elastomeric O-rings also are used for sealing process valves. These O-rings provide good 

sealing, but are not suitable if sliding motion occurs through the packing gland. These seals are 

used rarely in high pressure service, and operating temperatures are limited by the seal material. 

Bellows seals are generally thought to be more effective for preventing process fluid leaks than 

the conventional packing gland or other gland-seal arrangement. This type of seal incorporates 

formed metal bellows that makes a barrier between the disc and body bonnet joint. The bellows 

are the weak point of this type of system, and service life can be quite variable. Consequently, 

this type of seal normally is backed up with a conventional packing gland and often is fitted with 

a leak detector in case of failure. 

A diaphragm may be used to isolate the working parts of the valve and the environment from the 

process liquid. The diaphragm also may be used to control the flow of the process fluid. In this 

design, a compressor pushes the diaphragm toward the valve bottom, throttling the flow. The 

diaphragm and compressor are connected in a manner so that separating them is impossible 

under normal working conditions. When the diaphragm reaches the valve bottom, it seats firmly 

against the bottom, forming a leak-proof seal. This configuration is recommended for fluids 

containing solid particles and for medium-pressure service. Depending on the diaphragm 

material, this type of valve can be used at temperatures up to 205°C and in severe acid solutions. 

If the seal fails, however, a valve using a diaphragm seal can become a source of leaks. 

Flanges and Other Connectors

Flanges are bolted, gasket-sealed junctions used wherever pipes or other components or 

equipment (such as vessels, pumps, valves, and heat exchangers) may require isolation or 

removal. Connectors are all other nonwelded fittings that serve a similar purpose to flanges, 

which also allow bends in pipes (elbows), joining two pipes (couplings), or joining three or four 

pipes (tees or crosses). Connectors typically are threaded. 

Flanges may become fugitive emissions sources when leakage occurs because of improperly 

chosen gaskets or poorly assembled flanges. The primary cause of flange leakage is thermal 

stress, which causes deformation of the seal between the flange faces. Threaded connectors may 

leak if the threads become damaged or corroded or if tightened without sufficient lubrication or 

torque (EPA Office of Compliance Chemical, Commercial Services, and Municipal Division, 

1998).

Agitators

Agitators are used to stir or blend chemicals. Like pumps and compressors, agitators may leak 

organic chemicals at the point where the shaft penetrates the casing. Consequently, seals are 

required to minimize fugitive emissions. Four seal arrangements commonly are used with 
Technical Memorandum – Analysis of Emissions Reduction Techniques for Equipment Leaks 

December 21, 2011 

5

agitators: compression packing (packed seal), mechanical seals, hydraulic seals, and lip seals. 

Packed seals for agitators are very similar in design and application to packed seals for pumps. 

Although mechanical seals are more costly than the other three types of seals, they offer a greatly 

reduced leakage rate to offset their higher cost. Furthermore, the maintenance frequency of 

mechanical seals is one-half to one-fourth that of packed seals. At pressures greater than 1,140 

kPa (150 psig), the leakage rate and maintenance frequency are so superior that the use of packed 

seals on agitators is rare. As with packed seals, the mechanical seals for agitators are similar in 

design and application to the mechanical seals for pumps. 

Instrumentation Systems 

Instrumentation systems consist of smaller pipes and tubing that carry samples of process fluids 

to be analyzed to determine process operating conditions or to systems for measurement of 

process operating conditions (e.g., composition, pressure, flow, etc.). Valves and connectors are 

the predominant type of equipment used in instrumentation systems; however, other types of 

equipment may also be included in these systems. These components are generally the source of 

leaks from instrumentation systems as well as fluid that is vented or discharged from the 

analyzer or bypass lines. 

Closed-Vent Systems

A closed-vent system can be used to collect and convey gaseous emissions from seal oil 

degassing vents, pump and compressor seal leakage, relief valve leakage, and relief valve 

discharges because of over-pressure operation. A process or portion of a process also can be 

enclosed, and the enclosure can be vented through a closed vent system. A closed-vent system 

consists of piping; equipment such as connectors, open-ended lines, and valves; flame arrestors, 

and, if necessary, flow-inducing devices. Closed-vent systems are designed and operated to 

convey emissions to a control device. However, just like in process lines, equipment in a closed 

vent system is a potential source of emissions due to leaks. 

5. Identification of Control Options for Equipment Leaks

There are two primary techniques for reducing equipment leak emissions: (1) modifying or 

replacing existing equipment, and (2) implementing a leak detection and repair (LDAR) 

program. Modifying or replacing existing equipment is referred to as an “equipment 

modification.” Controlling emissions by equipment modification is achieved by either installing 

additional equipment that eliminates or reduces emissions, or replacing existing equipment with 

sealless types. An LDAR program is a structured program to detect and repair equipment that is 

identified as leaking (U.S. EPA Office of Air Quaility Planning and Standards, 1995). 

Equipment Modification Control Alternatives 

For each equipment type there are one or more equipment modifications that can be implemented 

for emissions control. This section reviews the modification alternatives for different equipment 

leak types. 
Technical Memorandum – Analysis of Emissions Reduction Techniques for Equipment Leaks 

December 21, 2011 

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Pumps

Equipment modifications for pumps include routing leaking vapors through a closed-vent system 

to control or replacing the existing pump with a new pump that is designed with dual mechanical 

seals or is a sealless type. 

A pump with dual mechanical seals contains two seals between which a barrier fluid is 

circulated. Depending on the design of the dual mechanical seals, the barrier fluid can be 

maintained at a pressure that is higher than the pumped fluid or at a pressure that is lower than 

the pumped fluid. If the barrier fluid is maintained at a higher pressure than the pumped fluid, the 

pumped fluid will not leak to the atmosphere. The control efficiency of dual mechanical seals 

with a barrier fluid at a higher pressure than the pumped fluid is essentially 100 percent, 

assuming both the inner and outer seal do not fail simultaneously. If the barrier fluid is 

maintained at a lower pressure than the pumped fluid, a leak in the inner seal would result in the 

pumped fluid entering the barrier fluid. To prevent emissions of the pumped fluid to the 

atmosphere, a barrier fluid reservoir system should be used. At the reservoir, the pumped fluid 

can vaporize (i.e., de-gas) and then be collected by a closed-vent system. 

The actual emissions reduction achievable through use of dual mechanical seals depends on the 

frequency of seal failure. Failure of both the inner and outer seals could result in relatively large 

releases of the process fluid. Pressure monitoring of the barrier fluid may be used to detect 

failure of the seals, allowing for a quick response to a failure. 

Sealless pumps, when operating properly, will not leak because the process fluid cannot escape 

to the atmosphere. Sealless pumps are used primarily in processes where the pumped fluid is 

hazardous, highly toxic, or very expensive, and where every effort must be made to prevent all 

possible leakage of the fluid. Under proper operating conditions, the control efficiency of 

sealless pumps is essentially 100 percent; however, if a catastrophic failure of a sealless pump 

occurs, there is a potential for a large quantity of emissions. 

Compressors

Emissions from compressors may be reduced by collecting and controlling the emissions from 

the seal or by improving seal performance. Shaft seals for compressors are of several different 

types--all of which restrict but do not eliminate leakage. In some cases, compressors can be 

equipped with ports in the seal area to evacuate collected gases using a closed-vent system. 

Additionally, for some compressor seal types, emissions can be controlled by using a barrier 

fluid in a similar manner as described for pumps. 

Pressure Relief Valves 

Equipment leaks from pressure relief valves (PRVs) occur as a result of improper reseating of 

the valve after a release, or if the process is operating too close to the set pressure of the PRV 

and the PRV does not maintain its seal. Emissions occurring from PRVs as a result of an 

overpressure discharge are not considered to be equipment leak emissions. There are two 

primary alternatives for controlling equipment leaks from pressure relief devices: use of a 

rupture disk (RD) in conjunction with the PRV, or use of a closed-vent system. The control 
Technical Memorandum – Analysis of Emissions Reduction Techniques for Equipment Leaks 

December 21, 2011 

7

efficiency of the RD/PRV combination is assumed to be 100 percent when operated and 

maintained properly. 

A closed-vent system can be used to transport equipment leaks from a PRV to a control device. 

However, the equipment leak control efficiency for a closed-vent system installed on a PRV may 

not be as high as the control efficiency that can be achieved by installing a closed-vent system on 

other equipment types. This is due to the difficulty of designing an efficient control device that 

can handle both high and low flow emissions since emissions from pressure relief devices can be 

either high during an overpressure incident or low when associated with equipment leaks. 

Valves 

Emissions from process valves can be eliminated if the valve stem can be isolated from the 

process fluid. Two types of sealless valves are available: diaphragm valves and sealed bellows 

valves. The control efficiency of both diaphragm and sealed bellows valves is virtually 100 

percent. However, a failure of these types of valves has the potential to cause temporary 

emissions much larger than those from other types of valves. 

Connectors

In cases where connectors are not required for safety, maintenance, process modification, or 

periodic equipment removal, emissions can be eliminated by welding the connectors together. 

Open-Ended Lines 

Emissions from open-ended lines can be controlled by properly installing a cap, plug, or second 

valve to the open end. If a second valve is installed, the upstream valve should always be closed 

first after use of the valves to prevent the trapping of fluids between the valves. Capping an 

open-ended line has the potential to achieve nearly 100 percent control. However, monitoring 

has shown that capped open-ended lines often leak due to improper installation. 

Sampling Connections 

Emissions from sampling connections occur as a result of purging the sampling line to obtain a 

representative sample of the process fluid. Emissions from sampling connections can be reduced 

by using a closed-loop sampling system or by collecting the purged process fluid and transferring 

it to a control device, back to the process, or for liquids, to a hazardous waste or other type of 

treatment unit. The closed-loop sampling system is designed to return the purged fluid to the 

process at a point of lower pressure. A throttle valve or other device is used to induce the 

pressure drop across the sample loop. The efficiency of a closed-loop system is assumed to be 

100 percent. Alternatively, in some cases, sampling connections can be designed to collect 

samples without purging the line. If such a sampling connection is installed and no emissions to 

the atmosphere occur when a sample is collected, then the control efficiency can be assumed to 

be 100 percent (U.S. EPA Office of Air Quaility Planning and Standards, 1995). 

Instrumentation Systems 

Emissions from the connectors, valves, and other equipment in instrumentation systems can be 

controlled using the same techniques described above for such equipment in process lines. 
Technical Memorandum – Analysis of Emissions Reduction Techniques for Equipment Leaks 

December 21, 2011 

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Emissions of material that is purged from the system can be controlled using the same types of 

techniques as described above for sampling connections. 

Agitators 

Agitators are used to stir or blend chemicals. Like pumps and compressors, agitators may leak 

organic chemicals at the point where the shaft penetrates the casing. Consequently, seals are 

required to minimize fugitive emissions. Four seal arrangements commonly are used with 

agitators: compression packing (packed seal), mechanical seals, hydraulic seals, and lip seals. 

Packed seals for agitators are very similar in design and application to packed seals for pumps. 

Leak Detection and Repair Program 

An LDAR program is designed to identify pieces of equipment that are emitting sufficient 

amounts of material to warrant reduction of the emissions through repair. Leak detection 

methods can include sensory inspections (i.e., indications of leaks based on sight, sound, or 

smell) or monitoring with portable organic vapor analyzers in accordance with Method 21. 

Typically, Method 21 has been used to monitor equipment in gas/vapor service and equipment in 

contact with relatively volatile liquids. Sensory inspections are generally used for equipment in 

contact with less volatile liquids (i.e., “heavy” liquid service). These programs are best applied to 

equipment types that can be repaired on-line, resulting in immediate emissions reduction, and/or 

to equipment types for which equipment modifications are not feasible. An LDAR program is 

best suited to valves and pumps, and can also be implemented for agitators and connectors. 

For other equipment types, an LDAR program is not as applicable. Compressors are repaired in a 

manner similar to pumps; however, because compressors ordinarily do not have a spare for 

bypass, a process unit shutdown may be required for repair. Compressors are typically controlled 

by seal systems that include a barrier fluid system. Historically, open-ended lines have been 

controlled solely by equipment modifications (because the modification is expected to achieve 

100 percent emissions reduction). Emissions from sampling connections can only be reduced by 

changing the method of collecting the sample (since, by definition, equipment leak emissions are 

the material purged from the line), and cannot be reduced by an LDAR program. Safety 

considerations may preclude the use of an LDAR program on pressure relief valves. 

Many studies have been performed to estimate the control effectiveness of a given LDAR 

program for light liquid pumps, gas valves, light liquid valves, and connectors. The control 

effectiveness is based on the relationship between the percentage of equipment pieces that are 

leaking and the corresponding average leak emission rate for all of the equipment. The main 

factors in determining the control effectiveness are: (1) how a “leak” is defined, (2) the leak 

frequency before the LDAR program is implemented, and (3) the final leak frequency after the 

LDAR program is implemented. The leak definition (or action level) for a piece of equipment is 

the screening value at which a “leak” is indicated if the instrument reading is equal to or greater 

than that value. The leak frequency is the fraction of equipment with screening values equal to or 

greater than the leak definition (EPA, 1995). 
Technical Memorandum – Analysis of Emissions Reduction Techniques for Equipment Leaks 

December 21, 2011 

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New Control Technologies 

No entirely new developments in methods for controlling equipment leak emissions were found. 

However, variations and advancements in existing technologies and practices that are not 

currently required in existing EPA rules have been identified and are listed as follows. 

x Optical gas imaging – Optical gas imaging devices offer the ability to monitor equipment 

from a distance and identify leaks (of a sufficient mass) from equipment within the line 

of sight of the optical imager (Environ International Corporation, 2003). 

x “Low leak” packings – Packing combinations for valves and gaskets for flanges that 

significantly reduce emissions are in place in some facilities, particularly refineries. 

Facilities and packing manufacturers have created emission testing protocols for packings 

in order to study and test their effectiveness. One of these studies, performed by two 

packing manufacturers, revealed that “[s]everal aspects of valve design; including 

tolerances, surface finish, stem straightness and the overall alignment of the stem, stem 

nut and stuffing box were found to be contributing factors to either the failure and/or 

success of a particular stem packing to meet the emission requirements.” These studies 

have lead to advancements such as packing consisting of braided carbon filament end 

rings that encapsulate an Inconel wire mesh with three molded flexible graphite center 

rings (Cornelsen, 2006).

Some packing manufacturers have begun marketing packings as “low-leak” packing and 

providing performance guarantees. Companies have also developed in-house testing 

programs to ensure that packings are suitable for site-specific applications and to evaluate 

the performance of different materials (Reeves, 2011). 

x Monitoring of new equipment – Some local governments require monitoring on types 

equipment that have not been monitored in the past. In some cases, this is based on data 

collected since LDAR programs where first designed and implemented. For example, 

inspection agencies have conducted monitoring of open ended valves and lines (OELs) at 

numerous facilities and found OELs that are leaking due to improper installation of the 

plugs and other control equipment (Wilwerding 2007, Loukeris 2006). Monitoring on 

atmospheric PRVs for releases and leaks is also required by some local governments 

(Douglas, 2005).

The South Coast Air Management Quality District (SCAQMD) requires continuous 

monitoring of a percentage of atmospheric PRDs at refineries by installing a monitoring 

device capable of recording the duration of each release and quantifying emissions. 

Wireless technology allows continuous monitoring of PRDs and makes it easy for 

operators to identify releases and leaks. There are several monitoring devices that can be 

used, including acoustic sensors and pressure/differential pressure sensors. These sensor 

units communicate with a base radio that interfaces with the existing control system 

(Ellis, 2007). 
Technical Memorandum – Analysis of Emissions Reduction Techniques for Equipment Leaks 

December 21, 2011 

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6. Summary of Control Options Analyzed 

For the purposes of this memorandum, the baseline control option is a combination of leak 

detection and repair (LDAR) program elements, equipment design standards, and performance 

standards which were based on a review of the requirements and applicability of existing 

regulations, including federal, state, and local rules. The baseline leak detection and repair 

program is equivalent to the requirements in the National Emission Standards for Equipment 

Leaks--Control Level 1 (40 CFR part 63, subpart TT) and Standards of Performance for 

Equipment Leaks of VOC in the Synthetic Organic Compound Manufacturing Industry for 

which Construction, Reconstruction, or Modification Commenced After January 5, 1981 but 

Before November 7, 2006 (40 CFR part 60, subpart VV) and represents the least stringent set of 

requirements that apply to facilities that are currently subject to equipment leaks standards. Thus, 

it is also considered to be the least stringent alternative for a process unit or facility that is 

currently not subject to standards. Table 1 summarizes the requirements of the baseline for all 

equipment. 

Table 1. Baseline Requirements for all Equipment Types 

Equipment Baseline Requirements 

Pumps in light liquid service (Pumps LL) Monthly Method 21 monitoring 

Leak definition of 10,000 ppm 

Pumps in heavy liquid service (Pumps HL) Sensory Monitoring 

Valves in gas and vapor service and Valves in light 

liquid service (Valves G/LL) 

Monthly Method 21 monitoring (or less frequent 

depending on leaks found) 

Leak definition of 10,000 ppm 

Valves in heavy liquid service (Pumps HL) Sensory Monitoring 

Connectors in gas and vapor service and 

Connectors in light liquid service (Connectors G/LL) 

Sensory Monitoring 

Connectors in heavy liquid service (Connectors HL) Sensory Monitoring 

Agitators in gas and vapor service and Agitators in 

light liquid service (Agitators G/LL) 

Monthly Method 21 monitoring 

Leak definition of 10,000 ppm 

Agitators in heavy liquid service (Agitators HL) Sensory Monitoring 

Compressors Barrier fluid options

Open Ended Lines Cap or comparable 

Sampling Connection Systems (all types of service) All must be closed purge, closed loop, or have a 

closed vent system (CVS) 

Pressure relief devices in gas and vapor service 

(PRV Gas) 

No detectable emissions (or rupture disk CVS/air 

pollution control device (APCD)) 

Pressure relief devices in liquid service (PRV 

Liquid)

Sensory Monitoring 

Instrumentation Systems For large valves: Comply with applicable 

requirements above 

For all other equipment: Sensory monitoring 
Technical Memorandum – Analysis of Emissions Reduction Techniques for Equipment Leaks 

December 21, 2011 

11

In addition, this memorandum also analyzes several alternative means of compliance. From the 

baseline, independent alternatives for each component type were developed and are summarized 

in Table 2. This approach provides the ability to analyze the incremental costs and cost 

effectiveness of each alternative individually, while still distributing costs of certain activities 

(such as the use of a monitoring instrument or a database) that apply to, or can be used for, more 

than one type of equipment. Furthermore, many of these alternatives match current regulatory 

requirements for facilities subject to certain existing rules; these alternatives thus can also serve 

as the baseline in analyses of nationwide impacts of regulatory alternatives for source-category 

specific rules that reference the Uniform Standards. 

Table 2. Summary of Equipment Leak Requirement Options 

Alternative Options Additional Requirements 

Valve Option 1 Lowers leak definition of Valves G/LL to 500 ppm 

Valve Option 2 Lowers leak definition of Valves G/LL to 100 ppm 

Pumps Option 1 Lowers leak definition of Pumps LL to 2,000 ppm1

Pumps Option 2 Lowers leak definition of Pumps LL to 500 ppm 

Connectors Option 1 Adds instrument monitoring for Connectors G/LL at 500 ppm 

1

 Note that the regulatory leak definition for pumps is 2,000 ppm; however, data collected at a leak definition of 1,000 

ppm were often used in this analysis to represent pumps with a leak definition of 2,000 ppm. 

Additional Requirements for Open Ended Lines and Pressure Relief Devices 

In addition to the requirements in Table 2, this memorandum also analyses the incremental cost 

of conducting annual instrument monitoring to demonstrate that the open-ended valve or line 

operates with an instrument reading of less than 500 ppm above background (i.e., that the cap, 

blind flange, plug, or second valve seals the open-ended valve or line at all times). It was 

assumed that the annual monitoring would not provide any additional emissions reductions since 

the baseline requires OELs to be capped, but would result in additional monitoring and repair 

costs. The costs of annual monitoring, including repair of any leaks found, are included in 

Section 8. 

The impacts associated with wireless monitoring for PRDs were also analyzed in this 

memorandum. It was assumed that no additional emissions reductions would occur from this 

requirement, but it would result in additional capital costs. Wireless monitoring costs are 

included in Section 8. 

7. Impact Analysis

Model Facilities 

To calculate cost estimates and emissions reductions for potential equipment leak requirements, 

model plants were developed to represent equipment counts found at different types of chemical 

and refining facilities. Six models were created, three to represent chemical manufacturing 

process units and three to represent petroleum refineries. These models allowed for the 
Technical Memorandum – Analysis of Emissions Reduction Techniques for Equipment Leaks 

December 21, 2011 

12

consideration of the costs and emissions reduction impacts for processes of various sizes in 

multiple industries. The six models are summarized in Table 3. 

Table 3. Model Plants 

 Type of Equipment 

Number of Pieces of Equipment 

Model 1 Model 2 Model 3 Model 4 Model 5 Model 6 

Simple

Chemical

Medium

Chemical

Complex

Chemical

Topping

Refinery 

Small

Refinery 

Large

Refinery 

Pump Seals 

 * Light-liquid service 15 40 56 8 69 176 

 * Heavy-liquid service 0 5 36 8 61 246 

Valves 

 * Gas/vapor service 77 414 1,379 75 1,178 3,263 

 * Light-liquid service 380 1,179 1,980 251 2,428 5,857 

 * Heavy-liquid service 0 71 1,272 216 1,719 3,163 

Connectors 

 * Flanges - gas/vapor 164 2,333 7,641 

 * Flanges - G/LL 731 2,662 7,410 555 4,644 13,379 

 * Flanges - HL 454 4,186 7,725 

Agitators 

* Light-liquid service 0 3 0 0 0 0 

* Heavy-liquid service 0 3 0 0 0 0 

Compressor Vent 0 2 8 2 19 31 

Open-ended Valves 33 141 424 39 238 902 

Sampling Connections 8 35 106 10 70 159 

Pressure Relief Devices 2 45 76 9 79 119 

 

Total Equipment Counts 1,246 4,600 12,747 1,791 17,024 42,661 

Models 1-3 represent a range of chemical manufacturing process units and are based on the 

models used in the Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC 

in the SOCMI (Parrish, 2007). These equipment counts encompassed a large range of individual 

process units at chemical manufacturing facilities. However, a facility with numerous process 

units could have many times more pieces of equipment than Model 3. Focus was placed on small 

facilities since that size range is where the impacts are most likely to be more burdensome. When 

impacts for Model 3 are reasonable, we can be certain that they will also be reasonable for larger 

facilities. 

Models 4-6 represent different size refineries, from a simple topping refinery to a complex 

refinery. The equipment counts presented for small and large refineries in Locating and 

Estimating Air Emissions from Sources of Benzene (EPA, 1998) were used to estimate the 

number of pieces of equipment in each type of refinery process unit. Model 4, the topping 
Technical Memorandum – Analysis of Emissions Reduction Techniques for Equipment Leaks 

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refinery, was assumed to consist of one crude distillation unit. Except for PRV, the equipment 

counts for that model are equal to the counts for a crude distillation unit at a small refinery in 

Locating and Estimating Air Emissions from Sources of Benzene (EPA, 1998). The PRV counts 

were estimated based on a summary of data collected through EPA’s Petroleum Refinery 

Information Collection Request (ICR) (EPA, 2011). 

Models 5 and 6 were developed using information from the U.S. Energy Information 

Administration (EIA) on the number of refineries in the U.S., their capacities, and the types of 

processes at each (U.S. DOE, 2011). The EIA report includes production capacity of facilities in 

barrels per day (bbl/d) and the downstream charge capacity of each plant divided into process 

type (vacuum distillation, delayed coking, fluid coking, visbreaking, and other processes). Since 

Locating and Estimating Air Emissions from Sources of Benzene defines the “large model 

refinery” as a refinery with a crude charge capacity greater than 50,000 barrels per stream day, 

refineries were classified as “large” or “small” based on the capacity in the EIA report. The 

number of each type of process at an average “small” refinery and an average “large” refinery 

was estimated based on the data in the EIA report. For example, the EIA report included 40 

“small” refineries, 24 of which reported vacuum distillation capacity. Therefore, it was assumed 

for purposes of developing a small refinery model that an average small refinery has 0.6 vacuum 

distillation units. Finally, the number of each type of process was multiplied by the appropriate 

equipment counts in Locating and Estimating Air Emissions from Sources of Benzene, and the 

results were summed for each type of equipment except for PRV. The PRV counts were 

estimated based on a summary of data from the Petroleum Refinery ICR. References for model 

facilities are included in attachment 1. 

The goal was to develop models as representative of the potential affected sources as possible so 

that the model plants can be used in the future to develop source category-specific nationwide 

impact estimates in an efficient manner. There are process units and facilities larger than the 

largest model; however, these models are intended to cover a range of sizes representing a 

majority of the potential affected facilities. In addition, the options considered for the Uniform 

Standards that are affected by economies of scale will have a greater impact on smaller processes 

than larger processes. These models can be adjusted as needed based on data for a specific 

source category or industry to represent that source category or industry more accurately. 

Leak Frequencies 

Leak frequency refers to the estimated percentage of equipment that will be found leaking at a 

given leak definition. Leak frequencies were used to calculate both cost and emission estimates 

and are included in Table 4 and 5. Leak frequencies were estimated using several sources 

including the Protocol for Equipment Leak Emissions Estimates and industry data. Attachment 2 

includes the basis for the leak frequencies in Tables 4 and 5. Detailed information on how leak 

frequencies were used in cost and emission estimates is included in the following sections. 
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Table 4. Summary of Equipment Leak Frequency % for Model 1-3

Equipment Leak Frequencies % (Initial/Subsequent) 

Pump Seals 

LL Valves GV Valves LL 

Agitators 

LL

Connectors 

G/V and LL OELs 

Baseline 2.42 / 0.23 0.33 / 0.33 0.33 / 0.33 2.42 / 0.23 NA NA

Valves

Option 1 NA 7.24 / 0.51 4.84 / 0.51 NA NA NA

Valves

Option 2 NA 12.24 / 0.61 8.07 / 0.61 NA NA NA

Pumps

Option 1 13.48 / 0.26 NA NA NA NA NA

Pumps

Option 2 18.43 / 0.33 NA NA NA NA NA

Connectors

Option 1 NA NA NA NA 0.36 / 0.36 NA 

OELs Annual 

Monitoring NA NA NA NA NA 0.90 / 0.45

Table 5. Summary of Equipment Leak Frequency % for Model 4-61

Equipment Leak Frequencies % (Initial/Subsequent) 

Pump

Seals LL Valves GV Valves LL 

Agitators 

LL

Connectors 

G/V

Connectors 

LL OELs 

Baseline 0.88 / 0.88 1.18 / 1.18 1.38 / 1.38 0.88 / 0.88 NA NA NA 

Valves

Option 1 NA 5.95 / 1.91 6.30 / 1.97 NA NA NA NA 

Valves

Option 2 NA 14.73 / 1.28

15.14 / 

1.17 NA NA NA NA 

Pumps

Option 1 3.31 / 0.98 NA NA NA NA NA NA 

Pumps

Option 2 4.57 / 1.26 NA NA NA NA NA NA 

Connectors

Option 1 NA NA NA NA 1.70 / 0.81 1.70 / 0.81 NA 

OELs

Annual

Monitoring

NA NA NA NA NA NA 2.30 / 

1.15

1

 U.S. EPA National Enforcement Investigations Center (NEIC) data on leak frequencies for valves at refineries 

suggest the actual percentage leaking may be higher. In order to account for this, it was estimated that the actual 

percentage leaking is 1.7 times higher than typically measured leak frequencies. This factor represents the 10th 

percentile of the data set (i.e., 90 percent of the NEIC leak frequencies were at least 1.7 times higher than the leak 

frequencies reported by the refineries) and was used determining leak frequencies (Parrish et al., 2007). 
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Emission Reductions 

In order to calculate the emissions reductions that result from the baseline requirements, we first 

had to estimate uncontrolled emissions. Once the emissions reductions of the baseline were 

found, the incremental emissions reductions of each control alternative were also calculated. The 

incremental emissions reductions of each option is incremental with respect to the previous 

option for a given equipment type. For example, the emissions reduction for pumps Option 1 is 

based on the additional emissions reductions of Option 1 with respect to the baseline pump 

emissions; similarly, the emissions reduction of pumps Option 2 is based on the additional 

emission reduction of Option 2 with respect to Option 1. The following sections describe how 

these emissions were calculated. 

The first step in calculating emissions was to establish emission factors for each equipment type. 

Emission factors are the estimated leak rates of an equipment type at a given leak definition and 

are normally given in kg/hr/piece of equipment. Tables 6 and 7 summarize the leak emission 

factors used for Models 1-3 and 4-6, respectively. Attachment 3 includes detailed information on 

the basis for these emission factors.
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Table 6. Emission Factors for Chemical Manufacturing Plant Models 

Emission Factors for Chemical Manufacturing Plant Models 1-3 (kg/hr/piece of equipment)1

Uncontrolled Baseline Valve Option 

1

Valve Option 

2

Pumps

Option 1 

Pumps

Option 2 

Connectors 

Option 1 

Pump Seals LL 1.23E-02 2.51E-03 NA NA 6.95E-04 5.31E-04 NA Valves G/V 5.22E-04 3.52E-04 2.03E-04 1.82E-04 NA NA NA Valves LL 5.86E-04 3.90E-04 2.32E-04 2.05E-04 NA NA NA Connectors – Flanges G/V 3.07E-04 3.07E-04 NA NA NA NA NA Connectors – Flanges G/LL 3.07E-04 3.07E-04 NA NA NA NA 1.62E-04 Agitators LL 1.23E-02 2.51E-03 NA NA NA NA NA Compressor Vent 2.28E-01 2.28E-02 NA NA NA NA NA Open-ended Valves 1.70E-03 3.33E-05 NA NA NA NA NA Sampling Connections 1.50E-02 NA NA NA NA NA NA PRV – Disks 1.04E-01 NA NA NA NA NA NA 

1 Equipment in HL service was not included in this analysis because we are unable to quantify the reductions that are achieved using sensory monitoring. 
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Table 7. Emission Factors for Refinery Models 

Emission Factors for Refinery Plant Models 4-6 (kg/hr/piece of equipment)1

Uncontrolled Baseline Valve Option 

1

Valve Option 

2

Pumps

Option 1 

Pumps

Option 2 

Connectors 

Option 1 

Pump Seals LL 1.05E-03 7.11E-04 NA NA 3.26E-04 3.22E-04 NA Valves G/V 3.71E-04 2.24E-04 8.85E-05 2.10E-05 NA NA NA Valves LL 3.75E-04 2.23E-04 8.88E-05 2.02E-05 NA NA NA Connectors – Flanges G/V 1.04E-04 1.04E-04 NA NA NA NA 3.95E-05 Connectors – Flanges G/LL 8.46E-05 8.46E-05 NA NA NA NA 2.77E-05 Agitators LL 1.05E-03 NA NA NA NA NA NA Compressor Vent 6.36E-01 3.18E-02 NA NA NA NA NA Open-ended Valves 2.30E-03 7.34E-05 NA NA NA NA NA Sampling Connections 1.50E-02 NA NA NA NA NA NA PRV – Disks 1.60E-01 NA NA NA NA NA NA 1 Equipment in HL service was not included in this analysis because we are unable to quantify the reductions that are achieved using sensory monitoring. 
Technical Memorandum – Analysis of Emissions Reduction Techniques for Equipment Leaks 

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Uncontrolled emissions were calculated by multiplying the emission factors in Tables 6 and 7, 

the equipment counts of each model, and the operating hours (which were assumed to be 8,760 

hours/yr). Uncontrolled emissions for each model are summarized in Table 8. Attachment 4 

provides detailed calculations. 

Table 8. Uncontrolled Emissions for Each Model 

Model 

Total Uncontrolled 

Emissions (lb/yr) 

Total Uncontrolled 

Emissions (tpy) 

Model 1 20,400 10.2

Model 2 157,000 78.7

Model 3 326,000 163

Model 4 61,000 30.4

Model 5 548,000 274

Model 6 941,000 471

Once uncontrolled baseline emissions were established, emission estimates were calculated for 

the baseline. The leak definitions under the baseline are 10,000 ppm for pumps LL, valves G/LL, 

and agitators in G/LL. Therefore, the leak emission factors for the baseline (summarized in Table 

6 and 7) for these equipment types are based on a leak definition of 10,000 ppm. These leak 

emission factors were multiplied by the equipment counts for each model and 8,760 hours to get 

annual emissions. As stated in Section 5, the efficiency of the control methodologies for 

sampling connections and PRVs in gas service is expected to be 100 percent; therefore, 

implementing the requirements of the baseline for these types of equipment results in essentially 

zero emissions for those equipment types. Emission reductions from sensory requirements were 

assumed to be zero because we are unable to quantify emissions reductions associated with 

sensory requirements. Baseline compressor vent emissions estimates are based on emission 

factors used in the HON analysis (Whitt, 1991), assuming the seal system barrier fluid would be 

routed to a reservoir where the fluid could degas and the vapors routed to a control device. For 

OELs, we used the emissions factors documented in previous analyses (Parrish and Randall, 

2007; Parrish et al., 2007) at the leak frequencies described earlier in this section. Table 9 

summarizes baseline emissions for all model plants. 
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Table 9. Baseline Emissions Summary 

Option 1 Emissions (lb/yr) 

Equipment Type Model 1 Model 2 Model 3 Model 4 Model 5 Model 6 

Pump Seals 

Light-liquid service 728 1,940 2,717 110 948 2,418 

Valves 

Gas/vapor service 523 2,814 9,374 324 5,092 14,106 

Light-liquid service 2,863 8,884 14,920 1,082 10,471 25,259 

Connectors 

Flanges - gas/vapor 0 0 0 330 4,693 15,371 

Flanges - G/LL 4,334 15,782 43,932 906 7,584 21,849 

Agitators

Light-liquid service 0 146 0 -- -- -- 

Compressor Vent 0 881 3,523 1,228 11,669 19,038 

Open-ended Valves 21 91 273 55 337 1,278 

TOTAL (lb/yr) 8,470 31,538 74,737 4,036 40,795 99,319 

TOTAL (tpy) 4.23 15.27 37.37 2.02 20.40 49.66 

The emission reductions for the baseline were calculated by subtracting total baseline emissions 

from total uncontrolled emissions. The alternative options for each equipment type provide 

additional reductions by increasing the baseline requirements of that equipment type. Table 10 

summarizes emissions reductions of the baseline, as well as the additional reductions of each 

subsequent option. Detailed calculations are included in Attachment 4. 
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Table 10. Emissions Summary 

Emissions Reductions Summary (tpy) 

Model 1 Model 2 Model 3 Model 4 Model 5 Model 6 

Uncontrolled Emissions 10.2 78.7 163 30.4 274 471 

Baseline Emissions 4.23 15.3 37.4 2.02 20.4 49.7 

Baseline Emissions 

Reductions 5.96 63.5 126 28.4 254 421 

Additional Incremental Reductions: 

Valves Option 1 (wrt to 

Baseline valve 

emissions) 

0.69 2.40 5.02 0.42 4.69 11.87 

Valves Option 2 (wrt to 

Valves Option 1) 0.12 0.43 0.92 0.24 2.55 6.65 

Pumps Option 1 (wrt to 

Baseline pump 

emissions) 

0.26 0.70 0.98 0.03 0.26 0.65 

Pumps Option 2 (wrt to 

Pumps Option 1) 0.02 0.06 0.09 0.0003 0.003 0.007 

Connectors Option 1 

(wrt to Baseline 

connector emissions) 

1.02 3.7 10.4 0.41 4.0 12.1 

8. Control Costs

The cost analysis uses a methodology that was originally presented in Impacts from the Control 

of VHAP Emissions from Equipment Leaks in Non-SOCMI Process Units for HON (Whitt, 

1991). The methodology has been tailored specifically for this analysis. Several constant values 

used in this analysis were developed for previous analyses and are detailed in this section. 

Cost calculations can fall into three categories: 

1. Monitoring and Equipment Costs 

2. Leak Repair Costs 

3. Planning and training Costs 

The first step was to estimate the costs of implementing the baseline. Once this was completed, 

the incremental cost of each alternative was calculated. This section will analyze each cost 

estimates and summarize the costs for each option. 

Labor Hour Rates 

Wage rate estimates used to calculate costs were based on data from the U.S. Department of 

Labor, Bureau of Labor Statistics for general manufacturing sectors (Sectors 31, 32, and 33) 

(BLS, 2010). Overhead factors and fringe benefits were added to labor rates when necessary. 

Table 11 summarizes the wage rates and overhead factors used to estimate costs for each option. 
Technical Memorandum – Analysis of Emissions Reduction Techniques for Equipment Leaks 

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Table 11. Summary of 2009 Hourly Labor Rates 

Activity $/hr Basis for Estimate 

General manufacturing - 

Installation, maintenance, repair 

occupations 

22.08

Mean hourly wage for Installation, Maintenance, and Repair 

Occupations 

(Standard Occupational Classification (SOC) Code 49-0000) 

(BLS, 2010) 

Plant and system operators 22.72 Mean hourly wage for Plant and System Operators, All Other 

(SOC Code: 51-8099) (BLS, 2010) 

Environmental engineering 39.53 Mean hourly wage for Environmental Engineers 

(SOC Code: 17-2081) (BLS, 2010) 

General and operations 

managers

57.80 Mean hourly wage for Engineering Managers 

(SOC Code: 11-9041) (BLS, 2010) 

General office and admin support 17.31 

Mean hourly wage for Office and Administrative Support 

Occupations 

(SOC Code: 43-0000) (BLS, 2010) 

Planning and training labor 

charge1 92.72

Weighted average for technical (39.53), management (57.80), 

and clerical labor (17.31). The weighted average assumes 

5 hours of management time and 10 hours of clerical effort per 

100 hours of technical labor. Includes overhead factor for 

planning and training. 

Leak Repair Labor Charge2 66.24 

The general manufacturing sector - Installation, Maintenance, 

and Repair Occupations labor rate with the overhead factor 

applied was used for all repairs 

1

 A planning and training overhead factor of 2.1 was used based on Technology Review for Heat Exchange Systems 

(Coburn, 2011). 

2

 A maintenance and repair overhead factor of 3 was used based on a 200 percent overhead factor (which -correlates 

to a factor of 3) based on the overhead factor used for performance testing contractors in the CEMS Cost Model 

(EPA, 2002). 

Monitoring and Equipment Modification Costs 

Initial monitoring costs are considered capital costs and are higher than annual monitoring costs 

in order to account for implementation. They are incurred once at the start of the program and 

were calculated by multiplying the equipment counts in a given model by an estimated initial 

monitoring fee. Table 12 summarizes the monitoring fees for each equipment type and the basis 

for each. 
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 Table 12. Initial monitoring Fees 

Monitoring Fee ($/ 

equipment piece) Basis 

Pumps LL 23.80 Includes field identification of subject equipment; creating and 

issuing drawings; creating data forms and tags; tagging of the 

pumps and valves; and populating the software. The value also 

assumes that contractors are performing this work. (Updated from 

Eastman Chemical Co, 1999.) 

Valves G/LL 

Agitators LL 

OELs 

Pumps HL 1.10 Based on an estimate of 3 minutes to monitor each piece of 

equipment at a “general manufacturing sector - installation, 

maintenance, and repair occupations” wage rate. (Update from 

Eastman Chemical Co, 1999.) 

Valves HL 

Agitators HL 

Connectors 

Annual monitoring costs vary by the number of times the equipment type has to be monitored 

per year. Table 13 summarizes the annual monitoring fees by equipment type. The annual 

monitoring costs are calculated by multiplying the equipment counts by the monitoring fee and 

the monitoring frequency. 

Table 13. Annual monitoring/maintenance Fees 

Subsequent Monitoring 

Fee ($/equipment piece) Basis 

Pumps LL 1.50 Based on information provided by a monitoring and 

repair contractor (Parrish, 2006) Valves G/LL 

Agitators LL 

OELs 

Connectors GV/LL 2.50

Equipment modification costs are considered to be capital costs and were calculated for the 

baseline requirements to equip open-ended valves with caps or other comparable seals, install 

rupture discs on pressure relief devices in gas service, to equip compressor vents with a seal 

system, and to retrofit sample connection systems to be closed purge, closed loop, or have a 

closed vent system. Table 14 summarizes the initial cost for these requirements and the basis for 

each cost estimate. 
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Table 14. Equipment Modification Costs for PRVs, OEVs, Sampling Connections, and 

Compressor vents 

Equipment/

Device Type 

Initial

Cost 

($2010) Unit Basis Reference 

Pressure Relief 

Devices 

* Disks 

122.11 $/ equipment Cost of one rupture disk. Escalated vendor quote 

(Hausle & Whitt, 1992) 

* Disk holders, 

valves, etc. 6,374.29 $/ equipment 

Equipment cost of 1 gate 

valve, tee, elbow, rupture 

disk holder, pressure 

gauge, bleed valve, steel 

body/trim and labor costs 

(36 labor hours). 

Escalated labor and 

equipment cost (Hausle & 

Whitt, 1992) 

Open-ended

Valves 140.92 $/ equipment 

Cost for one 2.5 cm gate 

valve for open ended 

lines and 1.4 labor hours 

Escalated from costs provided 

in Hausle & Whitt, 1992 

Sampling 

Connections 687.86 $/ equipment 

Equipment cost for 6 

meter pipe, 3 ball valves 

and 2.4 labor hours. 

Escalated from costs provided 

in Hausle & Whitt, 1992 

Compressor 

Vent Seal 10,526.21 $/ equipment 

Equipment cost of 122 

meter pipe, 3 steel 

valves, 1 flame arrestor, 

and 78 labor hours. 

Escalated from costs provided 

in Hausle & Whitt, 1992 

Monitoring instrumentation is also necessary for Method 21 monitoring, as well as a data 

collection system to store monitoring records. Instrumentation and data collection systems are 

capital costs that were estimated at $10,800 and $14,500, respectively, per facility. The estimated 

instrumentation costs are roughly equal to the cost to purchase a standard TVA1000B flame 

ionization detector (FID)-only monitor with probe from Thermo Fisher Scientific (2011). The 

data collection system cost was based on Revised MACT Floor, Regulatory Alternatives, and 

Nationwide Impacts for Equipment Leaks at Chemical Manufacturing Facilities (Shine et al.,

2003).

Initial costs for PRD wireless monitoring device capable of identifying and recording the time 

and duration of each pressure release and calculating the quantity of regulated material released 

were also analyzed in addition to the baseline PRD requirements. There are several types of 

wireless monitoring systems and costs vary depending on the number of PRDs at a facility. 

Based on cost studies from the BAAQMD staff report, the estimated cost of wireless monitoring 

was assumed to be 7,500 dollars per PRD (the midpoint of the range provided by Douglas 

(2005), which includes device parts, installation, maintenance, and data retrieval system. Annual 

operating costs were not included in this analysis because they are assumed to be minimal. 

Because the cost of electronic monitoring is not linear and facilities requiring a large number of 

monitors will benefit from economies of scale, the sixth-tenths rule was applied to calculate 

initial costs which are provided below (Douglas, 2005).
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Leak Frequency and Repair Costs 

The control options summarized in Tables 1 and 2 require Method 21 monitoring and repair of 

leaks for certain equipment types. Repair costs are a function of the leak frequency of a given 

equipment type. An initial leak frequency represents the equipment found to be leaking the first 

time the monitoring is conducted using a particular leak definition. The cost to repair these initial 

leaks is considered as initial LDAR costs (along with initial monitoring fees). The subsequent 

leak frequency represents the equipment found to be leaking after a few monitoring cycles have 

been completed and the program reaches “steady state” the cost to repair subsequent leaks are 

considered annual repair costs. Generally, the subsequent leak frequency is estimated to be less 

than the initial leak frequency, but in some cases they are assumed to be the same. For example, 

the initial leak frequencies for the baseline are the estimated percentages of uncontrolled 

equipment leaking above the 10,000 ppm leak definition, and the subsequent leak frequencies are 

the estimated percentage of “leakers” once the initial leaks are repaired and the requirements are 

in place. If initial or subsequent leak frequencies increase for a control alternative, the initial 

LDAR costs or the annual repair costs can increase because there are more leaks to repair; these 

additional repair costs are considered incremental costs for each alternative option. Leak 

frequencies were estimated using several sources including the Protocol for Equipment Leak 

Emissions Estimates and industry data. As previously stated, attachment 2 includes the basis for 

the leak frequencies in Tables 4 and 5. 

The cost to repair initial and subsequent leaks is also based on whether the repair can be 

performed online and the number of hours required to repair the leak. The general manufacturing 

sector - Installation, Maintenance, and Repair Occupations labor rate with the overhead factor 

applied ($66.24/hr) was used for all repairs. Table 15 includes the assumptions used to estimate 

the cost of repairing leaks and attachment 5 provides detailed cost calculations.

Table 15. Summary of Leak Repair Assumptions 

Equipment Type 

Percent Repaired 

Online

Hours Required 

to repair online 

Leak 

Percent Repaired 

Offline

Hours Required 

to repair Offline 

Leak 

Pumps LL 100% 16.00 0 NA

Agitators 100% 16.00 0 NA 

Valves LL/G 75% 0.17 25% 4.00 

Connectors1 75% 0.17 25% 2.00 

OELs2 75% 0.17 25% 4.00 

1

 Not applicable to Option 1-3 since connectors are not required to perform Method 21 monitoring and leak repair. 

2

 Only applicable to annual monitoring requirement (not used in baseline calculations of OELs). 

As part of the initial (LDAR) repair cost for pumps we assumed that the seals would need to be 

replaced. The cost to purchase replacement pump seals was estimated to be $282.71/leaking 

pump (updated from Hausle, 1992); therefore, initial LDAR cost for pumps also includes the cost 

of replacement pumps seals multiplied by the number of initial leaks (in addition to the initial 

monitoring and repair costs). The annual cost of pump replacements is included as an annual 
Technical Memorandum – Analysis of Emissions Reduction Techniques for Equipment Leaks 

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maintenance cost. Leak repair costs also include additional monitoring of the repaired leaks in 

order to verify the equipment was completely fixed. These costs are considered annual costs and 

were calculated using the subsequent monitoring fee for the equipment type and the subsequent 

number of equipment leaking. 

Baseline cost estimates for OELs only include the costs related to installing caps and annual 

maintenance and do not include any OEL repair costs. OEL repair costs were only used when 

calculating incremental cost of annual monitoring on OELs (see Table 17). 

Maintenance and Miscellaneous Costs 

For pumps and agitators, annual maintenance costs were included and are based on the annual 

number of leaks multiplied by the updated cost of a replacement seal, $282.71 (Hausle, 1992). 

Annual maintenance costs were also included for PRVs, OELs, sampling connections, and 

compressor vents as a percentage of initial monitoring fees. For PRV disk holders, OELs, 

sampling connections, and compressor vents, annual maintenance costs were based on 5 percent 

of initial monitoring costs and 2 percent of initial monitoring costs for PRV disks. 

Annual miscellaneous costs were also included in this analysis for pumps, PRDs, OELs, 

sampling connections, and compressor vents. For pumps and agitators, the miscellaneous costs 

are based on 80 percent of the annual maintenance costs. For PRDs, OELs, sampling connections 

and compressor vents, the annual miscellaneous charges are estimated using 4 percent of initial 

monitoring costs (Hausle, 1992).

Administrative, Reporting, Planning, and Training Labor Costs 

Planning and training costs are initial costs associated with the implementation of an LDAR 

program. These costs include initial review of requirements and training of facility personnel. 

We estimated initial planning and training costs based on an estimate of 320 labor hours and a 

labor rate of $92.72/hr. The value of 320 hours per process unit is based on an estimate of initial 

administration, planning, and training to implement a SOCMI-based LDAR program (Meardon, 

1998). Planning and training costs were included in baseline estimates, and it was assumed that 

no additional planning and training costs would be incurred with any of the alternative options 

for pumps and valves (i.e., incremental costs of planning and training was assumed to be 0 for all 

alternative options). For connectors, it was assumed that an additional 20 hours would be 

required for activities such as adding connectors to the LDAR database for instrument 

monitoring.

Annual reporting and administrative costs were estimated using 250 hours at a labor rate of 

$92.72/hr to account for preparation of annual reports and recordkeeping. The 250 hour estimate 

was based on the ratio of the amount of hours required for LDAR programs with and without 

connectors which is estimated at 8 people at 32 hours each in Equipment Leak Analysis for 

Amino and Phenolic Resins NESHAP (Meardon, 1998). Development of the labor rate is 

discussed in Table 11. Annual reporting costs were included in baseline estimates and it was 

assumed that no additional annual reporting costs would be incurred with any of the alternative 

options for pumps and valves (i.e., incremental costs of planning and training was assumed to be 

$0 for all alternative options). For connectors, it was assumed that an additional 50 hours would 
Technical Memorandum – Analysis of Emissions Reduction Techniques for Equipment Leaks 

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be required for preparation of annual reports and recordkeeping once the LDAR program 

included instrument monitoring for connectors. 

Annualized Initial Costs 

Initial capital costs and labor expenditures were annualized using capital recovery factors. The 

following equation was used to calculate capital recovery factors (EPA, 2002): 

 CRF = [i * (1+i)n

)] / [(1+i)n – 1],

Where, i is the interest rate and n is the life span in years. 

For pump seals and rupture disks, the capital recovery factor is 0.244, assuming a life span of 5 

years. For all other equipment types, the capital recovery factors is 0.142 based on a life span of 

10 years. We also annualized initial repair labor and planning and training costs over 10 years. 

For both factors, an interest rate of 7 percent was used. The impacts analysis also includes a 

recovery credit for the material that is not lost as emissions from equipment leaks. As in the 

Technology Review for Heat Exchange Systems (Coburn, 2011), these credits are $500/ton VOC.

Incremental Costs 

Once the total initial and annual costs for the implementation of baseline requirements was 

determined, the incremental annual cost of each alternative option was estimated. Similar to 

incremental emissions reductions, incremental costs are the additional costs of the option with 

respect to the preceding option. The incremental costs were based on the additional repair costs 

(initial and subsequent) of the lower leak definition of a given alternative option and any 

additional costs that are calculated as a function of leaks (maintenance costs, annual 

miscellaneous charges, and monitoring costs to verify off line repairs). It was assumed that there 

are no incremental costs associated with monitoring fees, administrative costs, and planning and 

training (except as described for connectors) since these are constant and should not increase 

with a lower leak frequency. Detailed incremental cost calculations are included in attachment 5. 

Cost Summary 

Cost estimates are summarized in Table 16 and Table 17. Detailed cost calculations are included 

in attachment 5 
Technical Memorandum – Analysis of Emissions Reduction Techniques for Equipment Leaks 

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Table 16. Baseline Detail Cost Summary 

Baseline

Model 

Capital Cost 

($) 

Annualized Costs 

Without Recovery 

Credits ($/yr) 

VOC Recovery 

Credit ($/yr) 

Total Annualized 

Cost ($/yr) 

Model 1 90,763 41,009 (2,980) 38,029

Model 2 455,982 129,599 (31,731) 97,867

Model 3 859,162 226,203 (62,822) 163,381

Model 4 156,783 57,067 (14,180) 42,887

Model 5 956,067 263,308 (126,809) 136,499

Model 6 1,658,781 461,483 (210,466) 251,017

Table 17. Summary of Incremental Annualized Cost Estimates for all Control Alternatives 

(Including Recovery Credits) 

Baseline

Valve 

Option 1 

Valve 

Option 2 

Pumps

Option 1 

Pumps

Option 2 

Connectors 

Option 1 

Model Total Cost ($/yr) Incremental Cost ($/yr) 

Model 1 38,029 15 901 312 354 7,360 

Model 2 97,867 97 3,223 831 944 13,861 

Model 3 163,381 358 7,076 1,163 1,322 29,846 

Model 4 42,887 268 2,815 189 437 7,714 

Model 5 136,499 3,033 27,993 1,628 3,772 32,188 

Model 6 251,017 7,725 79,562 4,152 9,622 87,089 

The cost for the additional requirements for PRDs and OELs are summarized in Table 18. 

Incremental costs for each of these options are with respect to the baseline. 

Table 18. Additional Costs of Wireless Monitoring for PRDs and Annual OEL Monitoring 

(Incremental to Baseline) 

Type of 

Facility 

Facility Initial Cost 

PRD Wireless 

Electronic

Monitoring ($)1

Annualized 

Incremental PRD 

Wireless Electronic 

Monitoring ($/yr) 

Capital Cost of 

Annual OEL 

Monitoring ($) 

Annualized 

Incremental Cost 

of Annual OEL 

Monitoring ($/yr) 

Model 1 11,368 1,619 808 176

Model 2 73,619 10,482 3,453 750

Model 3 100,821 14,355 10,383 2,256

Model 4 28,029 3,991 997 234

Model 5 103,190 14,692 6,082 1,429

Model 6 131,944 18,786 23,049 5,415

1

 Costs calculated using six-tenths rule. 
Technical Memorandum – Analysis of Emissions Reduction Techniques for Equipment Leaks 

December 21, 2011 

28

9. Cost Effectiveness

The cost effectiveness of baseline is calculated by dividing the total annual costs (including 

recovery credits) by the total emissions reduction of the baseline. Similarly, incremental cost 

effectiveness was calculated by dividing the incremental cost of each option (including recovery 

credits) by the incremental emissions reductions. Tables 19-22 summarize the cost effectiveness 

of each control alternative analyzed in this memorandum. 

Additional requirements for wireless monitoring for PRDs and annual monitoring of OELs were 

not included in the cost effectiveness summary since no emissions reductions from these 

activities is expected. 

Table 19. Baseline Cost Effectiveness Summary 

Model 

Emission

Reductions 

(tpy) 

Total Annual 

Cost ($/yr) 

Cost 

Effectiveness 

($/ton VOC) 

Model 1 5.96 38,029 6,380

Model 2 63.46 97,867 1,542 

Model 3 125.64 163,381 1,300

Model 4 28.36 42,887 1,512 

Model 5 253.62 136,499 538

Model 6 420.93 251,017 596

Table 20. Valve Options Cost Effectiveness Summary 

Valves Option 1 Valves Option 2 

Model 

Incremental

Annualized 

Cost ($) 

Incremental

Emissions

Reduction 

(tpy) 

Overall Cost 

Effectiveness 

($/ton) 

Incremental

Annualized 

Cost ($) 

Incremental

Emissions

Reduction 

(tpy) 

Overall Cost 

Effectiveness 

($/ton) 

Model 1 15 0.69 22 901 0.12 7,323

Model 2 97 2.40 40 3,223 0.43 7,506

Model 3 358 5.02 71 7,076 0.92 7,701

Model 4 268 0.42 633 2,815 0.24 11,588 

Model 5 3,033 4.69 646 27,993 2.55 10,994 

Model 6 7,725 11.87 651 79,562 6.65 11,966 
Technical Memorandum – Analysis of Emissions Reduction Techniques for Equipment Leaks 

December 21, 2011 

29

Table 21. Pump Options Cost Effectiveness Summary 

Pumps Option 1 Pumps Option 2 

Model 

Incremental

Annualized 

Cost ($) 

Incremental

Emissions

Reduction 

(tpy) 

Overall Cost 

Effectiveness 

($/ton) 

Incremental

Annualized 

Cost ($) 

Incremental

Emissions

Reduction 

(tpy) 

Overall Cost 

Effectiveness 

($/ton) 

Model 1 312 0.26 1,184 354 0.024 14,977 

Model 2 831 0.70 1,184 944 0.063 14,977 

Model 3 1,163 0.98 1,184 1,322 0.088 14,977 

Model 4 189 0.030 6,339 437 0.00031 1,429,098 

Model 5 1,628 0.26 6,339 3,772 0.0026 1,429,098 

Model 6 4,152 0.65 6,339 9,622 0.0067 1,429,098 

Table 22. Connector Option 1 Cost Effectiveness Summary (Incremental to Baseline) 

Connectors Option 1 (Incremental to Baseline) 

Model 

Incremental

Annualized 

Cost ($) 

Incremental

Emissions

Reduction (tpy)

Overall Cost 

Effectiveness 

($/ton) 

Model 1 7,360 1.02 7,192

Model 2 13,861 3.73 3,719

Model 3 29,846 10.37 2,877

Model 4 7,714 0.41 18,957

Model 5 32,188 4.00 8,038

Model 6 87,089 12.11 7,191

9. References

Barnett, Keith. (2000). Memorandum: Final Analysis of Equipment Leak Program for PET 

Facilities Subject to the Group IV Polymers and Resins NESHAP. Docket A-92-45, 

Document No. IXc-B-1. 

Coburn, Jeff. (2011). Technology Review for Heat Exchange Systems. Memorandum to Brenda 

Shine, EPA/OAQPS. July 12, 2011. Docket Item No. EPA-HQ-OAR-2011-0002-0008. 

Cornelsen, Dave. (2006). The development of effective fugitive emissions control for valves. 

Valve World, February 2006, pp 49-52. 
Technical Memorandum – Analysis of Emissions Reduction Techniques for Equipment Leaks 

December 21, 2011 

30

Douglas, Victor. (2005). BAAQMD Staff Report: Proposed Amendments to Regulation 8, Rule 

28: Episodic Release from Pressure Relief Devices at Petroleum Refineries and Chemical 

Plants.

Eastman Chemical Co. (1999). Eastman Chemical Company Comments on U.S. EPA Proposed 

Denial of Petition for Reconsideration - Group IV Polymers and Resins Equipment Leak 

Provisions. August 9, 1999. Docket No. A-92-45, Document No. VIIIc-D-6. 

Ellis, Kennard. (2007). Final Staff Report for Propose Amended Rule 1173. South Coast Air 

Quality Management District (SCAQMD). May 15, 2007. 

Environ International Corporation. (2003, March). The Use of a Gas-imaging Device for 

Detecting Fugitive Emissions in Ethylene Facilities. Retrieved September 2011, from 

http://texasiof.ces.utexas.edu/texasshowcase/pdfs/presentations/c2/msymlie.pdf.

EPA Office of Compliance; Chemical, Commercial Services, and Municipal Division. (1998, 

December). Inspection Manual: Federal Equipment Leak Regulations for the Chemical 

Manufacturing Industry Volume I: Inspection Manual

Hausle, K., & Whitt, D. (1992). Memo: Final Cost Impacts Analysis for HON Equipment Leaks.

Radian Corporation. February 28, 1992. Docket A-90-20, Document No. II-B-6. 

Loukeris, Constantinos. (2006). Cap/Plug Monitoring Data from U.S. EPA Region 5. 

Transmitted via e-mail to Karen Rackley. November 28, 2006. Docket Item No. EPA-HQOAR-2006-0699-0073.

Meardon, Kenneth R. (1998). Memorandum from K. Meardon, Pacific Environmental Services 

Inc. to J Schaefer. EPA/OGC. May, 1998. “Attachment 7: Leak Detection and Repair Cost 

Derivatives” In Equipment Leak Analysis for Amino and Phenolic Resins NESHAP. May 

1998. Docket No. A-92-19, Document No. II-B-11. 

Parrish, Kristin, David Randall, and Jeff Coburn, RTI International. (2007). Final Impacts 

Analysis for Regulatory Options for Equipment Leaks of VOC Petroleum Refineries.

Memorandum to Karen Rackley, EPA/SPPD. October 30, 2007. Docket Item No. EPA-HQOAR-2006-0699-0089.

Parrish, Kristin; Randall, David. (2007). Final Impacts Analysis for Regulatory Options for 

Equipment Leaks of VOC in the SOCMI. Memorandum to Karen Rackley, EPA/SPPD. 

October 30, 2007. Docket Item No. EPA-HQ-OAR-2006-0699-0090. 

Parrish, Kristin. (2006). Memorandum to Docket File. Telephone Conference between Kristin 

Parrish (RTI International) and Timothy Smith (TEAM Industrial Services, Inc.) regarding 

procedure and cost of the drill and tap method of valve repair. March 27, 2006. Docket Item 

No. EPA-HQ-OAR-2006-0699-0012. 

Reeves, David. (2011). Designing for Leak Free Operation: The secret to reducing LDAR costs!

Presented at the ISA 11th LDAR Symposium, May 18-19, 2011, New Orleans, LA. 
Technical Memorandum – Analysis of Emissions Reduction Techniques for Equipment Leaks 

December 21, 2011 

31

Shine, Brenda, Melissa Icenhour, and David Randall. (2003) Memorandum: Revised MACT 

Floor, Regulatory Alternatives, and Nationwide Impacts for Equipment Leaks at Chemical 

Manufacturing Facilities. May 5, 2003. Docket Item No. EPA-HQ-OAR-2003-0121-0004. 

Thermo Fisher Scientific. (2011). Thermo Scientific TVA1000B Toxic Vapor Analyzer. 

Retrieved December 2011 from 

http://www.fishersci.com/ecomm/servlet/fsproductdetail_10652_6471343_29104_-1_0.

U.S. Department of Energy (U.S. DOE). (2011). Refinery Capacity 2011. Energy Information 

Administration, June 24, 2011. Available at http://www.eia.gov/petroleum/refinerycapacity/.

U.S. Department of Labor, Bureau of Labor Statistics (BLS). (2010). May 2009 National 

Industry-Specific Occupational Employment and Wage Estimates: Sectors 31, 32, and 33 - 

Manufacturing. May 14, 2010. Available at http://www.bls.gov/oes/2009/may/naics2_31-

33.htm.

U.S. Environmental Protection Agency (EPA). (1995). Protocol for Equipment Leak Emission 

Estimates. Office of Air Quaility Planning and Standards. November 1995. 

U.S. Environmental Protection Agency (EPA). (1998). Locating and Estimating Air Emissions 

from Sources of Benzene. Office of Air Quality Planning and Standards. EPA-454/R-98-011. 

June 1998. 

U.S. Environmental Protection Agency (EPA). (2002). EPA Air Pollution Control Cost Manual 

Section 1 Chapter 2. Sixth Edition. Office of Air Quality Planning and Standards. 

EPA/452/B-02-001. January 2002. 

U.S. Environmental Protection Agency (EPA). (2011). Petroleum Refinery Database, based on 

Refinery Information Collection Request (ICR) for Calendar Year 2010. March 31, 2011. 

Docket ID No. EPA-HQ-OAR-2010-0682. 

Whitt, Daryl J. (1991). Impacts From the Control of VHAP Emissions from Equipment Leaks in 

non-SOCMI Process Units for the HON. Radian Corporation. Docket No. A-90-20, 

Document No. II-B-7. 

Wilwerding, Joseph. (2007). Refinery Plug Monitoring Data from the National Enforcement 

Investigations Center. Transmitted via email to Karen Rackley. June 14, 2007. Docket Item 

No. EPA-HQ-OAR-2006-0699-0072. 
Attachment 1

Based on data in Refinery Capacity 2010 (U.S. DOE, 2011) and the analysis of amendments to 40 CFR part 60, subpart GGG:

Number of process units in average small refinery: Number of process units in average large refinery:

0.9 Crude Distillation 1 Crude Distillation0.1 Alkylation (sulfuric acid) 0.4 Alkylation (sulfuric acid)0.1 Alkylation (HF) 0.4 Alkylation (HF)0.5 Catalytic Reforming 1.1 Catalytic Reforming0.1 Hydrocracking 0.5 Hydrocracking1.5 Hydrotreating/Hydrorefining 3.7 Hydrotreating/Hydrorefining0.3 Catalytic Cracking 0.9 Catalytic Cracking

0.03 Thermal Cracking (visbreaking) 0.02 Thermal Cracking (visbreaking)

0.1 Thermal Cracking (coking) 0.6 Thermal Cracking (coking)0.2 Hydrogen Plant 0.4 Hydrogen Plant0.7 Asphalt Plant 0.4 Asphalt Plant

1 Product Blending 1 Product Blending

0.7 Sulfur Plant 1.3 Sulfur Plant0.6 Vacuum Distillation 0.9 Vacuum Distillation

2 Full-Range Distillation 3 Full-Range Distillation

0.3 Isomerization 0.6 Isomerization0.2 Polymerization 0.2 Polymerization

0.05 MEK Dewaxing 0.05 MEK Dewaxing

0.2 Other Lube Oil Processes 0.1 Other Lube Oil Processes

0.08 Aromatics 0.2 Aromatics
Chemical Manufacturing Leak Frequencies (Used to calculate Repair Costs)

Type of Equipment

Initial Leak 

Frequency

(%)

Basis

Subsequent

Leak

Frequency

(%)

Basis

Pump Seals * Light-liquid service 2.42

Calculated using table 1 of Revised MACT floor, Regulatory Alternatives, and Nationwide Impacts for Equipment Leaks at Chemical Manufacturing Facilities MON Memorandum5/5/2003 and TABLE 5-4. EQUATIONS RELATING AVERAGE LEAK RATE TO FRACTION LEAKING AT SOCMI UNITS of the Protocol for Equipment Leak Emission Estimates. Calculation of this value shown in this attachment. 0.23

Memorandum: Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC in the SOCMI, Attachment E

Valves

 * Gas/vapor service 0.33

Set equal to the Subsequent Leak Frequency (Calculated a leak frequency of 0.22 using procedure similar to pumps above; however, this value was not used because it is less than the Subsequent Leak Frequency) 0.33

Memorandum: Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC in the SOCMI, Attachment E

 * Light-liquid service 0.33

Set equal to the Subsequent Leak Frequency (Calculated a leak frequency of 0.22 using procedure similar to pumps above; however, this value was not used because it is less than the Subsequent Leak Frequency) 0.33

Memorandum: Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC in the SOCMI, Attachment E

Connectors * Flanges - gas/vapor N/A N/A * Flanges - light liquid N/A N/AAgitators * Light-liquid service 2.42 Same as pump seals 0.23 Same as pump sealsOEL N/A N/A

Baseline

Attachment 2ͲPage 1
Chemical Manufacturing Leak Frequencies (Used to calculate Repair Costs)

Type of Equipment

Initial Leak 

Frequency

(%)

Basis

Subsequent

Leak

Frequency

(%)

Basis

Valves

 * Gas/vapor service 7.24

Sum of Initial Leak Frequency at 10,000 ppm (Baseline; see above) and Initial Leak Frequency at 500 ppm (Memorandum: Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC in the SOCMI, Attachment E) 0.51

Memorandum: Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC in the SOCMI, Attachment E

 * Light-liquid service 4.84

Sum of Initial Leak Frequency at 10,000 ppm (Baseline; see above) and Initial Leak Frequency at 500 ppm (Memorandum: Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC in the SOCMI, Attachment E) 0.51

Memorandum: Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC in the SOCMI, Attachment E

Type of Equipment

Initial Leak 

Frequency

(%)

Basis

Subsequent

Leak

Frequency

(%)

Basis

Pump Seals * Light-liquid service 13.48

Sum of Initial Leak Frequency at 10,000 ppm (Baseline; see above) and Initial Leak Frequency at 1,000 ppm (Memorandum: Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC in the SOCMI, Attachment E) 0.26

Memorandum: Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC in the SOCMI, Attachment E

Type of Equipment

Initial Leak 

Frequency

(%)

Basis

Subsequent

Leak

Frequency

(%)

Basis

Connectors * Flanges - gas/vapor 0.36

Memorandum: Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC in the SOCMI, Attachment E 0.36

Memorandum: Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC in the SOCMI, Attachment E

 * Flanges - light liquid 0.36

Memorandum: Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC in the SOCMI, Attachment E 0.36

Memorandum: Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC in the SOCMI, Attachment E

Option 1 for Pumps 

Option 1 for Connectors 

Option 1 for Valves

Attachment 2ͲPage 2
Chemical Manufacturing Leak Frequencies (Used to calculate Repair Costs)

Type of Equipment

Initial Leak 

Frequency

(%)

Basis

Subsequent

Leak

Frequency

(%)

Basis

Valves

 * Gas/vapor service 12.24

Sum of Initial Leak Frequency at 10,000 ppm (Baseline; see above), Initial Leak Frequency at 500 ppm (Memorandum: Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC in the SOCMI, Attachment E), and Initial Leak Frequency at 100 ppm of 5.00% (Calculation of this value shown in this attachment) 0.61

= Subsequent Leak Frequency for Average Refinery Valves, 100 ppm (Semiannual monitoring) / Subsequent Leak Frequency for Average Refinery Valves, 500 ppm (Semiannual monitoring) x Subsequent Leak Frequency for Chemical Manufacturing Valves, 500 ppm (Semiannual monitoring)

 * Light-liquid service 8.07

Sum of Initial Leak Frequency at 10,000 ppm (Baseline; see above), Initial Leak Frequency at 500 ppm (Memorandum: Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC in the SOCMI, Attachment E), and Initial Leak Frequency at 100 ppm of 3.22% (Calculation of this value shown in this attachment) 0.61

= Subsequent Leak Frequency for Average Refinery Valves, 100 ppm (Semiannual monitoring) / Subsequent Leak Frequency for Average Refinery Valves, 500 ppm (Semiannual monitoring) x Subsequent Leak Frequency for Chemical Manufacturing Valves, 500 ppm (Semiannual monitoring)

Type of Equipment

Initial Leak 

Frequency

(%)

Basis

Subsequent

Leak

Frequency

(%)

Basis

Pump Seals * Light-liquid service 18.43

Sum of Initial Leak Frequency at 10,000 ppm (Baseline; see above), Initial Leak Frequency at 1,000 ppm (Memorandum: Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC in the SOCMI, Attachment E), and Initial Leak Frequency at 500 ppm of 4.95% (Calculation of this value shown in this attachment) 0.33

= Subsequent Leak Frequency for Chemical Manufacturing Pumps, 1,000 ppm (Monthly monitoring) x Subsequent Leak Frequency for Refinery Pumps, 500 ppm (Quarterly monitoring) / Subsequent Leak Frequency for Refinery Pumps, 1,000 ppm (Quarterly monitoring)

Option 2 for Valves

Option 2 for Pumps

Attachment 2ͲPage 3
Chemical Manufacturing Leak Frequencies (Used to calculate Repair Costs)

Type of Equipment

Initial Leak 

Frequency

(%)

Basis

Subsequent

Leak

Frequency

(%)

Basis

OEL 0.90

Memorandum: Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC in the SOCMI, Attachment K 0.45

Assume that since an instrument reading of 500 ppm or 

greater means that the OEL is out of compliance, owners/operators will be more diligent about ensuring that caps and plugs are replaced properly after being removed to collect samples. This increased diligence is expected to lead to a reduction in leaks.

OEL Monitoring

Attachment 2ͲPage 4
Refinery Leak Frequencies (Used to calculate Repair Costs)

Type of Equipment

Initial Leak 

Frequency

(%)

Basis

Subsequent

Leak

Frequency

(%)

Basis

Pump Seals * Light-liquid service 0.88 Set equal to the Subsequent Leak Frequency 0.88

Memorandum: Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC in Petroleum Refineries, Attachment D

Valves

 * Gas/vapor service 1.18 Set equal to the Subsequent Leak Frequency 1.18

Memorandum: Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC in Petroleum Refineries, Attachment D

 * Light-liquid service 1.38 Set equal to the Subsequent Leak Frequency 1.38

Memorandum: Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC in Petroleum Refineries, Attachment D

Connectors * Flanges - gas/vapor N/A N/A * Flanges - light liquid N/A N/AAgitators * Light-liquid service 0.88 Same as pump seals 0.88 Same as pump sealsOEL N/A N/A

Type of Equipment

Initial Leak 

Frequency

(%)

Basis

Subsequent

Leak

Frequency

(%)

Basis

Valves

 * Gas/vapor service 5.95

Sum of Initial Leak Frequency at 10,000 ppm (see above) and Initial Leak Frequency at 500 ppm (Memorandum: Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC in Petroleum Refineries, Attachment E) 1.91

Memorandum: Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC in Petroleum Refineries, Attachment D

 * Light-liquid service 6.30

Sum of Initial Leak Frequency at 10,000 ppm (see above) and Initial Leak Frequency at 500 ppm (Memorandum: Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC in Petroleum Refineries, Attachment E) 1.97

Memorandum: Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC in Petroleum Refineries, Attachment D

Baseline

Option 1 for Valves

Attachment 2ͲPage 5
Refinery Leak Frequencies (Used to calculate Repair Costs)

Type of Equipment

Initial Leak 

Frequency

(%)

Basis

Subsequent

Leak

Frequency

(%)

Basis

Pump Seals * Light-liquid service 3.31

Sum of Initial Leak Frequency at 10,000 ppm (see above) and Initial Leak Frequency at 1,000 ppm (Memorandum: Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC in Petroleum Refineries, Attachment E) 0.98

Memorandum: Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC in Petroleum Refineries, Attachment D

Type of Equipment

Initial Leak 

Frequency

(%)

Basis

Subsequent

Leak

Frequency

(%)

Basis

Connectors * Flanges - gas/vapor 1.70

Protocol for Equipment Leak Emission Estimates, USEPA, November 1995 (EPA-453/R-95-017), Table G-2 0.81

Average Percent Leaking G and LL Connectors, 500 ppm (API Data, Quarterly Monitoring (Memorandum: Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC in Petroleum Refineries, Attachment C)) x 4 quarters/year x 0.9 (10% repeat leakers)

 * Flanges - light liquid 1.70

Protocol for Equipment Leak Emission Estimates, USEPA, November 1995 (EPA-453/R-95-017), Table G-2 0.81

Average Percent Leaking G and LL Connectors, 500 ppm (API Data, Quarterly Monitoring (Memorandum: Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC in Petroleum Refineries, Attachment C)) x 4 quarters/year x 0.9 (10% repeat leakers)

Option 1 for Pumps 

Option 1 for Connectors 

Attachment 2ͲPage 6
Refinery Leak Frequencies (Used to calculate Repair Costs)

Type of Equipment

Initial Leak 

Frequency

(%)

Basis

Subsequent

Leak

Frequency

(%)

Basis

Valves

 * Gas/vapor service 14.73

Sum of Initial Leak Frequency at 10,000 ppm (Baseline; see above), Initial Leak Frequency at 500 ppm (Memorandum: Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC in Petroleum Refineries, Attachment E), and Initial Leak Frequency at 100 ppm of 8.78% (Calculation of this value shown in this attachment) 1.28

Estimated subsequent leak frequency for refinery gas/vapor valves at 500 ppm to be 2.45% based on curve defined by leak frequencies at other leak definitions (see Memorandum: Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC in Petroleum Refineries, Attachment D).Since this value is greater than 2%, quarterly monitoring would be required.Subsequent Leak Frequency, 100 ppm (Quarterly Monitoring) = Subsequent Leak Frequency, 500 ppm (Quarterly Monitoring) / Subsequent Leak Frequency, 500 ppm (Semiannual Monitoring) x Subsequent Leak Frequency, 100 ppm (Semiannual Monitoring)

 * Light-liquid service 15.14

Sum of Initial Leak Frequency at 10,000 ppm (Baseline; see above), Initial Leak Frequency at 500 ppm (Memorandum: Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC in Petroleum Refineries, Attachment E), and Initial Leak Frequency at 100 ppm of 8.83% (Calculation of this value shown in this attachment) 1.17

Estimated subsequent leak frequency for refinery light liquid valves at 500 ppm to be 2.24% based on curve defined by leak frequencies at other leak definitions (see Memorandum: Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC in Petroleum Refineries, Attachment D).Since this value is greater than 2%, quarterly monitoring would be required.Subsequent Leak Frequency, 100 ppm (Quarterly Monitoring) = Subsequent Leak Frequency, 500 ppm (Quarterly Monitoring) / Subsequent Leak Frequency, 500 ppm (Semiannual Monitoring) x Subsequent Leak Frequency, 100 ppm (Semiannual Monitoring)

Option 2 for Valves

Attachment 2ͲPage 7
Refinery Leak Frequencies (Used to calculate Repair Costs)

Type of Equipment

Initial Leak 

Frequency

(%)

Basis

Subsequent

Leak

Frequency

(%)

Basis

Pump Seals * Light-liquid service 4.57

Sum of Initial Leak Frequency at 10,000 ppm (Baseline; see above), Initial Leak Frequency at 1,000 ppm (Memorandum: Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC in Petroleum Refineries, Attachment E), and Initial Leak Frequency at 500 ppm of 1.26% (Calculation of this value shown in this attachment) 1.26

= Subsequent Leak Frequency, 1,000 ppm (Monthly Monitoring) / Subsequent Leak Frequency, 1,000 ppm (Quarterly Monitoring) x Average Percent Leaking Pumps, 500 ppm (API Data, Quarterly Monitoring)

Type of Equipment

Initial Leak 

Frequency

(%)

Basis

Subsequent

Leak

Frequency

(%)

Basis

OEL 2.30

Memorandum: Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC in Petroleum Refineries, Attachment K 1.15

Assume that since an instrument reading of 500 ppm or 

greater means that the OEL is out of compliance, owners/operators will be more diligent about ensuring that caps and plugs are replaced properly after being removed to collect samples. This increased diligence is expected to lead to a reduction in leaks.

OEL Monitoring

Option 2 for Pumps

Attachment 2ͲPage 8
Table 1: Resulting Emission Rates and Program Efficiencies for CMA data. 

Component

LeakDefinition

(ppmv)

No.Monitored No. Leaking

Initial LeakRate (%)

Pumps 500 121 0 0

1000 683 13 1.92000 82 0 0 G Valves 500 20766 104 0.5 0.50

5000 374 39 10.43 5000 161 0 0 0.00

10000 662 13 1.96 10000 7062 41 0.58 0.581

Valves 500 62299 312 0.5 LL Valves 500 41533 208 0.5 0.50

5000 483 0 0 5000 322 0 0 0.00

10000 21185 123 0.58 10000 14123 82 0.58 0.581

Source: Memo: Revised MACT floor, Regulatory Alternatives, and Nationwide Impacts for Equipment Leaks at Chemical ManufacturingFacilities MON. From Brenda Shine, Melissa Icenhour, and David Randall 5/5/2003

Initial Leak FreqͲ10,000 ppm Attachment 2ͲPage 9
Uncontrolled

Emissions NEIC Factor 1.71

ALR @ 500 ppm(kg/hr/source)

Leakfraction @ 10,000 ppm

Leakfraction @ 10,000 ppm (%)

AverageUncontrolledLeak Rate

Average

UncontrolledEmissionFactor(kg/hr/source)

Gas Valves 0.000394 0.00339 0.339 0.501974818 5.22E-04

Light Liquid Va 0.000430 0.00292 0.292 0.467353214 5.86E-04Valves (using L 0.000429764 2.92E-03 2.92E-01 0.46735321 0.000585944

ALR @ 1,000 ppm(kg/hr/source)

Leakfraction @ 10,000 ppm

Leakfraction @ 10,000 ppm (%)

ALR @ 5,000 ppm

Leak fraction @ 10,000 ppm

Leakfraction @ 10,000ppm (%)

AverageUncontrolled Leak Rate

AverageUncontrolledEmission Factor (kg/hr/source)

Pumps 0.004042028 0.00892512 0.89251157 0.03715172 0.146882176 14.68822 4.332354 0.012297649

Rate for costs

ALR @ 500 ppm(kg/hr/source)

Leakfraction @ 10,000 ppm

Leakfraction @ 10,000 ppm (%)

AverageUncontrolledLeak Rate

Valves 0.000262 1.03E-03 1.03E-01 0.22303044

ALR @ 1,000 ppm(kg/hr/source)

Leakfraction @ 10,000 ppm

Leakfraction @ 10,000 ppm (%)

ALR @ 5,000 

ppm(kg/hr/source)

Leak fraction @ 10,000 ppm

Leakfraction @ 10,000ppm

Average

Uncontrolled Leak Rate

Pumps 0.00255 0.00266393 0.26639344 0.02226 0.084833333 8.483333 2.420517

Based on 5-46 of Equipment Leaks Protocol Equations and Revised MACT Floor, reg alternative, and nationwide impacts for equipment leaks... memo. May 5 2003

Initial Leak FreqͲ10,000 ppm Attachment 2ͲPage 10
Chemical Manufacturing Models - Gas Valves - From 500 to 100

EPA's SOCMI data

Protocol no 

control % 

leakersa

leak

concentration

Percent

leakers when 

monitored

assumed typical 

screening value in the 

range to the next 

thresholda

10 26 10 39.7

100 17.5 100 1.05 Option 232500 13.6 500 0.87 Baseline 665

1000 12 1000 1330

2000 10.5 2000 2990

5000 8.7 5000 6650

10000 7.5 10000 23200

50000 5.5 50000 66500

100000 4.5 100000 397000 39700

1000000

Distribution

leak

concentration

Percent

leakers when 

monitored

500 0.72

1000 0.632000 0.525000 0.45

50000 0.33

100000 0.27

Leak Freq calcs 100 500Baseline 0.51Option 8, Initial 5.0Option 8, Subsequent 0.61

aFrom figure B-3-3 in the Protocol document

Emissions New Calcs Attachment 2 - Page 11
Chemical Manufacturing Models - Gas Valves

Use correlation equation to estimate emissions for uncontrolled scenario1 - No control 2 - Baseline before control 3 - Baseline controlled

GV default zero 6.60E-07 Average above

Instantaneous 500

Leak

Definition

Range of 

concentrations

Percent of 

values in 

rangea

Average

screening value 

in range

Emission rate, 

kg/hr (per 100 

valves)

Percent of 

values in 

rangea

Emission rate, 

kg/hr (per 100 

valves)

Percent of 

values in 

rangea

Emission rate, 

kg/hr (per 100 

valves)

<10 74.0 0.00004884 84.9 0.00005604 85.3 0.00005628

10 10 to 100 8.5 39.7 0.000395 9.8 0.000454 9.8 0.000456

100 100 to 500 3.9 232 0.000847 4.5 0.000972 4.5 0.000976500 500 to 1000 1.6 665 0.000872 0.10 0.000056 0.05 0.000028

1000 1000 to 2000 1.5 1330 0.001496 0.10 0.000095 0.05 0.0000482000 2000 to 5000 1.8 2990 0.003642 0.11 0.000232 0.06 0.0001165000 5000 to 10000 1.2 6650 0.004879 0.08 0.000311 0.04 0.000155

10000 10000 to 50000 2.0 23200 0.024207 Pegged value 0.13 0.001543 0.06 0.00077150000 50000 to 100000 1.0 66500 0.030350 0.11 0.06 0.001935 0.03 0.000967

100000 >100000 4.5 310000 0.523616 0.495 0.29 0.033375 0.14 0.016688

Emission rate 

per valve

Emission rate 

per valve

Emission rate 

per valve

0.00590 0.00562 0.00039 0.000203

Emission rate estimated using (500 ppm) (10,000 ppm) (10,000 ppm)

 ALR equation 0.0060 0.00050 0.00032

Leak Frequency Calculations Baseline Option

<10 74.0 <10 85.2 89.1

10 10 to 100 8.5 10 to 100 9.8 10.2

100 100 to 500 3.9 0.61 100 to 500 4.5 0.14

500 500 to 1000 1.6 0.51 500 to 1000 0.06 0.06

1000 1000 to 2000 1.5 1000 to 2000 0.06 0.05

2000 2000 to 5000 1.8 2000 to 5000 0.07 0.06

5000 5000 to 10000 1.2 5000 to 10000 0.04 0.04

10000 10000 to 50000 2.0 10000 to 50000 0.07 0.0750000 50000 to 100000 1.0 50000 to 100000 0.04 0.03

100000 >100000 4.5 >100000 0.17 0.16

Emissions New Calcs Attachment 2 - Page 12
Chemical Manufacturing Models - Gas Valves

Use correlation equation to estimate controlled emissions (for HON program)

4 - Option 8 prior to control 5 - Option 1 controlled

GV default zero 6.60E-07 Average above, assume half repairs are successful b/t 500 and 1

100

Leak

Definition

Range of 

concentrations

Percent of 

values in 

range

Average

screening value 

in range

Emission rate, kg/hr 

(per 100 valves) when 

monitored

Emission

rate after 

repair, kg/hr

Percent of 

values in 

rangea

Emission rate, 

kg/hr (per 100 

valves)

<10 88.8 0.0000586 0.000066 89.3 0.0000589

10 10 to 100 10.2 39.7 0.000474 10.3 0.000477

100 100 to 500 0.23 232 0.000051 0.16 0.000034500 500 to 1000 0.10 665 0.000052 0.05 0.000026

1000 1000 to 2000 0.09 1330 0.000090 0.04 0.0000452000 2000 to 5000 0.11 2990 0.000218 0.05 0.0001095000 5000 to 10000 0.07 6650 0.000292 0.04 0.000146

10000 10000 to 50000 0.12 23200 0.001448 0.06 0.00072450000 50000 to 100000 0.06 66500 0.001816 0.03 0.000908

100000 >100000 0.27 310000 0.031327 0.13 0.015663

Emission rate per 

valve

Emission rate 

per valve

0.000358 0.00000066 0.000182

Average emission rate

 during monitoring period 0.000179

Emissions New Calcs Attachment 2 - Page 13
Chemical Manufacturing Models - Light Liquid Valves - from 500 to 100

EPA's SOCMI data

Protocol no 

control % 

leakersa

leak

concentration

Percent

leakers when 

monitored

assumed typical 

screening value in the 

range to the next 

thresholda

10 18 10 39.7

100 11 100 1.05 Option 232500 8.5 500 0.87 Baseline 665

1000 7 1000 1330

2000 5.8 2000 29905000 5.1 5000 6650

10000 4.5 10000 23200

50000 2.9 50000 66500

100000 2.2 100000 397000 39700

1000000

Distribution

leak

concentration

Percent

leakers when 

monitored

500 0.81

1000 0.672000 0.555000 0.49

10000 0.4350000 0.28

100000 0.21

Leak Freq calcs 500 10000Baseline 0.27Option, Initial 3.2Option, Subsequent 0.61

aFrom figure B-3-4 in the Protocol document

Emissions New Calcs Attachment 2 - Page 14
Chemical Manufacturing Models - Light Liquid Valves

Use correlation equation to estimate emissions for uncontrolled scenario1 - No control 2 - Baseline before control 3 - Baseline controlled

LLV default zero 4.90E-07 Average above

Instantaneous 500

Leak

Definition

Range of 

concentrations

Percent of 

values in 

rangea

Average

screening value 

in range

Emission rate, 

kg/hr (per 100 

valves)

Percent of 

values in 

rangea

Emission rate, 

kg/hr (per 100 

valves)

Percent of 

values in 

rangea

Emission rate, 

kg/hr (per 100 

valves)

<10 82.0 0.0000402 88.8 0.0000435 89.2 0.0000437

10 10 to 100 7.0 39.7 0.000844 7.6 0.000914 7.6 0.000918

100 100 to 500 2.5 232 0.001231 2.7 0.001333 2.7 0.001339500 500 to 1000 1.5 665 0.001709 0.2 0.000174 0.1 0.000087

1000 1000 to 2000 1.2 1330 0.002375 0.1 0.000242 0.1 0.0001212000 2000 to 5000 0.7 2990 0.002643 0.1 0.000270 0.0 0.0001355000 5000 to 10000 0.6 6650 0.004283 0.1 0.000437 0.0 0.000218

10000 10000 to 50000 1.6 23200 0.030922 Pegged value 0.2 0.003154 0.1 0.00157750000 50000 to 100000 0.7 66500 0.031314 0.15 0.1 0.003194 0.0 0.001597

100000 >100000 2.2 310000 0.335657 0.33 0.2 0.034232 0.1 0.017116

Emission rate 

per valve

Emission rate 

per valve

Emission rate 

per valve

Emission rate per valve 0.00411 0.00405 0.00044 0.000232

Emission rate estimated using (500 ppm) (10,000 ppm) (10,000 ppm)

 ALR equation 0.00402 0.00058 0.00037

Leak Frequency Calculations Baseline Option

<10 82.0 <10 89.2 91.6

10 10 to 100 7.0 10 to 100 7.6 7.8

100 100 to 500 2.5 0.61 100 to 500 2.7 0.14

500 500 to 1000 1.5 0.51 500 to 1000 0.1 0.08

1000 1000 to 2000 1.2 1000 to 2000 0.1 0.072000 2000 to 5000 0.7 2000 to 5000 0.0 0.045000 5000 to 10000 0.6 5000 to 10000 0.0 0.03

10000 10000 to 50000 1.6 10000 to 50000 0.1 0.0950000 50000 to 100000 0.7 50000 to 100000 0.0 0.04

100000 >100000 2.2 >100000 0.1 0.12

Emissions New Calcs Attachment 2 - Page 15
Chemical Manufacturing Models - Light Liquid Valves

Use correlation equation to estimate controlled emissions (for HON program)

4 - Option 1 prior to control 5 - Option 1 controlled

LLV default zero 4.90E-07 Average above, assume half repairs are successful b/t 500 and 1

100

Leak

Definition

Range of 

concentrations

Percent of 

values in 

range

Average

screening value 

in range

Emission rate, kg/hr 

(per 100 valves) when 

monitored

Emission

rate after 

repair, kg/hr

Percent of 

values in 

rangea

Emission rate, 

kg/hr (per 100 

valves)

<10 91.2 0.0000447 0.000049 91.7 0.0000449

10 10 to 100 7.8 39.7 0.000938 7.8 0.000943

100 100 to 500 0.24 232 0.000117 0.16 0.000078500 500 to 1000 0.14 665 0.000163 0.07 0.000081

1000 1000 to 2000 0.11 1330 0.000226 0.06 0.0001132000 2000 to 5000 0.07 2990 0.000252 0.03 0.0001265000 5000 to 10000 0.06 6650 0.000408 0.03 0.000204

10000 10000 to 50000 0.15 23200 0.002943 0.08 0.00147250000 50000 to 100000 0.07 66500 0.002981 0.03 0.001490

100000 >100000 0.21 310000 0.031948 0.10 0.015974

Emission rate per 

valve

Emission rate 

per valve

Emission rate per valve 0.000400 0.00000049 0.000205

0.066712

Average emission rate 0.533356

 during monitoring period 0.000200 -0.86658 -0.86657656

vs.

Emissions New Calcs Attachment 2 - Page 16
Chemical Manufacturing Models - Pumps - from 1000 to 500

EPA's SOCMI data

Protocol no 

control % 

leakersa

leak

concentration

Percent

leakers when 

monitored

assumed typical 

screening value in the 

range to the next 

thresholda

10 44 500 0.56 Option 665

100 30 1000 0.44 Baseline 1330500 21 2000 2990

1000 17.1 5000 6650

2000 13.2 10000 23200

5000 9.8 50000 66500

10000 7 100000 397000 39700

50000 3.5 1000000

100000 2

Distribution

leak

concentration

Percent

leakers when 

monitored

500 99.59

1000 99.702000 99.795000 99.86

10000 99.9650000 100.00

100000 100.05

Leak Freq calcs 500 1000Baseline 0.26Option, Initial (NSPS) 4.9Option, Subsequent 0.33

aFrom figure B-3-2 in the Protocol document

Emissions New Calcs Attachment 2 - Page 17
Chemical Manufacturing Models - Pumps

Use correlation equation to estimate emissions for uncontrolled scenario1 - No control 2 - Baseline before control 3 - Baseline controlled

P default zero 7.50E-06 Average above

Instantaneous 1000

Leak

Definition

Range of 

concentrations

Percent of 

values in 

rangea

Average

screening value 

in range

Emission rate, 

kg/hr (per 100 

pumps)

Percent of 

values in 

rangea

Emission rate, 

kg/hr (per 100 

pumps)

Percent of 

values in 

rangea

Emission rate, 

kg/hr (per 100 

pumps)

<10 56.0 0.00042 67.3 0.000504408 67.4 0.000505519

10 10 to 100 14.0 39.7 0.005524 16.8 0.006635 16.9 0.006649

100 100 to 500 9.0 232 0.015211 10.8 0.018268 10.8 0.018308500 500 to 1000 3.9 665 0.015697 4.7 0.018852 4.7 0.018893

1000 1000 to 2000 3.9 1330 0.027789 0.1 0.000714 0.1 0.0003572000 2000 to 5000 3.4 2990 0.047226 0.1 0.001214 0.0 0.0006075000 5000 to 10000 2.8 6650 0.075148 0.1 0.001931 0.0 0.000965

10000 10000 to 50000 3.5 23200 0.263017 Pegged value 0.1 0.006758 0.0 0.00337950000 50000 to 100000 1.5 66500 0.268442 0.62 0.0 0.006898 0.0 0.003449

100000 >100000 2.0 310000 1.272523 1.2400 0.1 0.032698 0.0 0.016349

Emission rate 

per pump

Emission rate 

per pump

Emission rate 

per pump

Emission rate per valve 0.01991 0.01958 0.00094 0.00069

Emission rate estimated using (1,000 ppm) (10,000 ppm) (10,000 ppm)

 ALR equation 0.0000 0.00233 0.00212

Leak Frequency Calculations Baseline Option

<10 56.0 <10 67.4 70.7

10 10 to 100 14.0 10 to 100 16.8 17.7

100 100 to 500 9.0 100 to 500 10.8 11.4500 500 to 1000 3.9 0.33 500 to 1000 4.7 0.06

1000 1000 to 2000 3.9 0.26 1000 to 2000 0.1 0.062000 2000 to 5000 3.4 2000 to 5000 0.1 0.055000 5000 to 10000 2.8 5000 to 10000 0.0 0.04

10000 10000 to 50000 3.5 10000 to 50000 0.1 0.0550000 50000 to 100000 1.5 50000 to 100000 0.0 0.02

100000 >100000 2.0 >100000 0.0 0.03

Emissions New Calcs Attachment 2 - Page 18
Chemical Manufacturing Models - Pumps

Use correlation equation to estimate controlled emissions (for HON program)

4 - Option 9 prior to control 5 - Option 9 controlled

P default zero 7.50E-06 Average above, assume half repairs are successful b/t 1000 and

500

Leak

Definition

Range of 

concentrations

Percent of 

values in 

range

Average

screening value 

in range

Emission rate, kg/hr 

(per 100 pumps) when 

monitored

Emission

rate after 

repair, kg/hr

Percent of 

values in 

rangea

Emission rate, 

kg/hr (per 100 

pumps)

<10 70.5 0.000528656 0.00075 70.7 0.000530239

10 10 to 100 17.6 39.7 0.006954 17.7 0.006974

100 100 to 500 11.3 232 0.019146 11.4 0.019204500 500 to 1000 0.10 665 0.000420 0.07 0.000280

1000 1000 to 2000 0.10 1330 0.000744 0.05 0.0003722000 2000 to 5000 0.09 2990 0.001265 0.05 0.0006325000 5000 to 10000 0.07 6650 0.002013 0.04 0.001006

10000 10000 to 50000 0.09 23200 0.007044 0.05 0.00352250000 50000 to 100000 0.04 66500 0.007189 0.02 0.003595

100000 >100000 0.05 310000 0.034080 0.03 0.017040

Emission rate per 

pump

Emission rate 

per pump

Emission rate per valve 0.000794 0.0000075 0.00053

Average emission rate

 during monitoring period 0.000401

vs.

Emission rate estimated using 

 ALR equation 0.0005771

(HON avg leak rate, kg/hr)

Emissions New Calcs Attachment 2 - Page 19
Refinery Leak Frequencies

PUMPS

New = Monthly 500, baseline = Monthly 1,000

1

leak range 0 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (500 ppm), % 2.16 <-- (this value for monthly monitoring)percent in range 88.057 9.784 0.472 1.079 0.433 0.061 0.113 100.000representative value default 165 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/pump) 0.000024 1.13E-03 2.65E-03 7.89E-03 2.31E-02 4.40E-02 1.31E-01 0.00050503

2 Controlled estimate using average leak rate as one-half of reported leak frequency, converted to monthly monitoring

leak range 0 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (500 ppm), % 2.16 <-- (this value for monthly monitoring)percent in range 88.958 9.884 0.315 0.540 0.217 0.030 0.057 100.000representative value default 165 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/pump) 0.000024 1.13E-03 2.65E-03 7.89E-03 2.31E-02 4.40E-02 1.31E-01 0.00032195

3

Then determine the percent leaking at other leak definitions by assuming the same distribution of leaking pumps as reported by API.

leak range 0 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (1,000 ppm), % 1.69 2.16 (at 1,000 ppm)percent in range 88.057 9.784 0.472 1.079 0.433 0.061 0.113 100.000representative value default 165 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/pump) 0.000024 1.13E-03 2.65E-03 7.89E-03 2.31E-02 4.40E-02 1.31E-01 0.00050503

4

Then determine the percent leaking at other leak definitions by assuming the same distribution of leaking pumps as reported by API.

leak range 0 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (1,000 ppm), % 1.69percent in range 88.816 9.868 0.472 0.540 0.217 0.030 0.057 100.000representative value default 165 665 3,970 23,200 66,500 397,000

average for values above 1,000 zeroemissions (kg/hr/pump) 0.000024 1.13E-03 2.65E-03 7.89E-03 2.31E-02 4.40E-02 1.31E-01 0.00032591

5

Controlled, w/ leak frequency as summarized in API report equal to leak frac. (i.e., estimate emission rate when monitored, notBaseline and Initial Leak Freq. Calc.leak range 0 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (1,000 ppm), % 0.98 1.26 (at 500 ppm)percent in range 88.866 9.874 0.276 0.630 0.253 0.036 0.066

 avg. over monitoring period) convert to monthly monitoring

Baseline estimate - Apply industry-based baseline-to-controlled percent leakers ratio for valves to controlled leak frequency for pumps above 1,000 ppm (adjusted to monthly monitoring).Baseline estimate - Average above 1,000 ppm

Attachment 2 - Page 20
Refinery Leak Frequencies

GAS VALVES

New = Quarterly, 100, Baseline = Semiannual, 500 (VVa to Opt7)

1 Controlled, with leak frequency as summarized in API report equal to leak fraction (i.e., estimate emission rate when monitored, not average over monitoring period)

leak range 0 100 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (100 ppm), % 2.19percent in range 88.031 9.781 1.753 0.052 0.275 0.061 0.012 0.035 0.108representative value default 33 232 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/valve) 0.0000078 3.11E-05 1.33E-04 2.92E-04 1.11E-03 4.14E-03 9.07E-03 3.44E-02 0.00003120

2 Controlled estimate using average leak rate as one-half of reported leak frequency

leak range 0 100 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (100 ppm), % 2.19percent in range 88.752 9.861 1.169 0.026 0.138 0.031 0.006 0.018 100.000representative value default 33 232 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/valve) 0.0000078 3.11E-05 1.33E-04 2.92E-04 1.11E-03 4.14E-03 9.07E-03 3.44E-02 0.00002103

3 Baseline estimate

leak range 0 100 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (500 ppm), % 3.28 10.050 (at 100 ppm)percent in range 87.049 2.902 6.770 0.391 2.072 0.460 0.089 0.266 100.000representative value default 33 232 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/valve) 0.0000078 3.11E-05 1.33E-04 2.92E-04 1.11E-03 4.14E-03 9.07E-03 3.44E-02 0.00015954

4 Baseline estimate - average above 10,000 ppm

leak range 0 100 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (500 ppm), % 3.28 10.050 (at 100 ppm)percent in range 88.524 2.951 6.885 0.196 1.036 0.230 0.044 0.133 100.000representative value default 33 232 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/valve) 0.0000078 3.11E-05 1.33E-04 2.92E-04 1.11E-03 4.14E-03 9.07E-03 3.44E-02 0.00008841

5 Baseline and Initial Leak Freq. Calc.

leak range 0 100 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (500 ppm), % 1.91 8.779 (at 100 ppm)percent in range 88.278 2.943 6.866 0.228 1.209 0.269 0.052 0.155

Attachment 2 - Page 21
Refinery Leak Frequencies

LIGHT LIQUID VALVES

New = Quarterly, 100, Baseline = Semiannual, 500 (VVa to Opt7)

1 Controlled, with leak frequency as summarized in API report equal to leak fraction (i.e., estimate emission rate when monitored, not average over monitoring period)

leak range 0 100 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (100 ppm), % 2.01percent in range 88.192 9.799 1.599 0.070 0.226 0.074 0.010 0.031 100.000representative value default 33 232 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/valve) 0.0000078 3.11E-05 1.33E-04 2.92E-04 1.11E-03 4.14E-03 9.07E-03 3.44E-02 0.00002952

2 Controlled estimate using average leak rate as one-half of reported leak frequency

leak range 0 100 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (100 ppm), % 2.01percent in range 88.856 9.873 1.066 0.035 0.113 0.037 0.005 0.016 100.000representative value default 33 232 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/valve) 0.0000078 3.11E-05 1.33E-04 2.92E-04 1.11E-03 4.14E-03 9.07E-03 3.44E-02 0.00002015

3 Baseline estimate

leak range 0 100 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (500 ppm), % 3.38 3.376 (at 500 ppm)percent in range 86.961 2.899 6.764 0.573 1.857 0.609 0.079 0.259 100.000representative value default 33 232 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/valve) 0.0000078 3.11E-05 1.33E-04 2.92E-04 1.11E-03 4.14E-03 9.07E-03 3.44E-02 0.00016024

4 Baseline estimate - average above 10,000 ppm

leak range 0 100 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (500 ppm), % 3.38 3.376 (at 500 ppm)percent in range 88.481 2.949 6.882 0.287 0.928 0.305 0.039 0.129 100.000representative value default 33 232 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/valve) 0.0000078 3.11E-05 1.33E-04 2.92E-04 1.11E-03 4.14E-03 9.07E-03 3.44E-02 0.00008876

5 Baseline and Initial Leak Freq. Calc.

leak range 0 100 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (500 ppm), % 1.97 8.832 (at 100 ppm)percent in range 88.227 2.941 6.862 0.334 1.083 0.355 0.046 0.151

Attachment 2 - Page 22
Attachment 3 - Emission Factors

SOCMI

Uncontrolled Emission Rates

(kg/hr/piece of 

equipment)

Pump Seals LL 1.23E-02

Valves G/V 5.22E-04

Valves LL 5.86E-04

Agitators LL 1.23E-02

Connectors – Flanges G/V 3.07E-04

Connectors – Flanges G/LL 3.07E-04

Compressor Vent 2.28E-01

Open-ended Valves 1.70E-03

Sampling Connections 1.50E-02

PRV – Disks 1.04E-01

Baseline Emission Rates

(kg/hr/piece of 

equipment)

Pump Seals LL 2.51E-03

Valves G/V 3.52E-04

Valves LL 3.90E-04

Agitators LL 2.51E-03

Connectors – Flanges G/V 3.07E-04

Connectors – Flanges G/LL 3.07E-04

Compressor Vent 2.28E-02

Open-ended Valves 3.33E-05

Valves Option 1

(kg/hr/piece of 

equipment)

Valves G/V 2.03E-04

Valves LL 2.32E-04

V l O ti 2

Calculated using initial leak rates of pumps and valves from facility data used in calculating MACT floors for the MON 

(Table A1) and the equations in Table 5-4 from the Protocol for Equipment Leak Estimates. See sample calculation for 

Model 1 pumps in light liquid service.

See Uncontrolled basis. 

Based on Table 2-1 of Equipment Leaks Protocol. 10 percent of uncontrolled compressor seal value

Based on Memorandum: Analysis of Additional Data on Leaks from Open-Ended Lines

Basis

Based on EPA SOCMI data for Pumps at 10,000 ppm

Based on EPA SOCMI data for Gas Valves at 500 ppm

Based on EPA SOCMI data for LL Valves at 500 ppm

Based on on SOCMI average emission factors in Table 2-1 of the Protocol for Equipment Leak Emission Estimates

Based on Equipment Leak Protocol Table 5-4 and MON leak rate data for connectors at 500 ppm. NEIC Factor applied. 

((0.047*0.360*1.71/100)+1.7E-5)*Equipment Count*8760

Where 1.71 is the NEIC factor, 0.360 is the leak frequency of connectors at 500 ppm from MON data, and 0.047 and 

1.7E-5 are Table 5-4 values. 

Basis

Basis

Based on EPA SOCMI data for Pumps at 10,000 ppm

Based on EPA SOCMI data for Gas Valves at 10,000 ppm

Based on EPA SOCMI data for LL Valves at 10,000 ppm

Attachment 3ͲPage 1

Valves Option 2

(kg/hr/piece of 

equipment)

Valves G/V 1.82E-04

Valves LL 2.05E-04

Pumps Option 1

(kg/hr/piece of 

equipment)

Pump Seals LL 6.95E-04

Pumps Option 2

(kg/hr/piece of 

equipment)

Pump Seals LL 5.31E-04

Connectors Option 1

(kg/hr/piece of 

equipment)

Connectors – Flanges G/LL 1.62E-04 Based on EPA SOCMI data for Connectors at 500 ppm

Basis

Based on EPA SOCMI data for Gas Valves at 100 ppm

Based on EPA SOCMI data for LL Valves at 100 ppm

Basis

Based on EPA SOCMI data for Pumps at 500 ppm

Basis

Based on EPA SOCMI data for Pumps at 1,000 ppm

Basis

Attachment 3ͲPage 1
Refinery Models

Uncontrolled Emission Rates

(kg/hr/piece of 

equipment)

Pump Seals LL 1.05EͲ03

Valves G/V 3.71EͲ04

Valves LL 3.75EͲ04

Agitators LL 1.05EͲ03

Connectors – Flanges G/V 1.04EͲ04

Connectors – Flanges G/LL 8.46EͲ05

Compressor Vent 6.36EͲ01

Open-ended Valves 2.30EͲ03

Sampling Connections 1.50EͲ02

PRV – Disks 1.60EͲ01

Baseline Emission Rates

(kg/hr/piece of 

equipment)

Pump Seals LL 7.11EͲ04

Valves G/V 2.24EͲ04

Valves LL 2.23EͲ04

Connectors – Flanges G/V 1.04EͲ04

Connectors – Flanges G/LL 8.46EͲ05

Compressor Vent 3.18EͲ02

Open-ended Valves 7.34EͲ05

Valves Option 1

(kg/hr/piece of 

equipment)

Valves G/V 8.85E-05

Valves LL 8.88E-05

Valves Option 2

(kg/hr/piece of 

equipment)

Valves G/V 2.10E-05

Valves LL 2.02E-05

Pumps Option 1

(k /h / i f

Basis

Memorandum: Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC in Petroleum Refineries

Basis

Based on on Refinery average emission factors in Table 2-2 of the Protocol for Equipment Leak Emission Estimates

Memorandum: Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC in Petroleum Refineries

Based on on Refinery average emission factors in Protocol for Equipment Leak Emission Estimates

Memorandum: Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC in Petroleum Refineries

Basis

Based on on Refinery average emission factors in Protocol for Equipment Leak Emission Estimates

Basis

Based on on Refinery average emission factors in Protocol for Equipment Leak Emission Estimates

Attachment 3ͲPage 2

(kg/hr/piece of 

equipment)

Pump Seals LL 3.26EͲ04

Pumps Option 2

(kg/hr/piece of 

equipment)

Pump Seals LL 3.22EͲ04

Connectors Option 1

(kg/hr/piece of 

equipment)

Connectors – Flanges G/V 3.95E-05

Connectors – Flanges G/LL 2.77E-05

Basis

Based on on Refinery average emission factors in Protocol for Equipment Leak Emission Estimates

Based on on Refinery average emission factors in Protocol for Equipment Leak Emission Estimates

Basis

Based on on Refinery average emission factors in Protocol for Equipment Leak Emission Estimates

Basis

Attachment 3ͲPage 2
Table A1. Resulting Emission Rates and Program Efficiencies for CMA Data

Leak Definition 

(ppmv) No. Monitored No. Leaking

Initial

Leak

Rate (%)

Pumps 500 121 0 0

1000 683 13 1.9

2000 82 0 0

5000 374 39 10.43

10000 662 13 1.96

Valves 500 62299 312 0.5

5000 483 0 0

10000 21185 123 0.58

Sample calculation for Model 1 pumps in light liquid service is as follows:

Reference: Revised MACT Floor, Regulatory Alternatives, and Nationwide Impacts for Equipment Leaks at Chemical Manufacturing Facilities

MON memorandum

Step 1: Calculate the LKFRAC % @ 10,000 ppm using 1,000 leak definition

ALR @ 1,000 ppm (kg/hr/source) = Equation 1

(0.11 × LKFRAC @1,000 ppm) + 4.6E-04 Table 5-4 Equipment Leak Protocol 

LKFRAC @ 1,000 ppm = Equation 2

(NEIC Factor x 1.9 % Initial Leak Rate of Pumps LL @ 1,000ppm)/100 

Substitute the leak frequency back into Equation 1. 

ALR @ 1,000 ppm (kg/hr/source) = 

0.11 × (NEIC Factor x 1.9 % Initial Leak Rate of Pumps LL @ 1,000ppm)/100 × 4.6E-04

ALR @ 10,000 ppm (kg/hr/source) = Equation 3

(0.24 × LKFRAC @ 10,000 ppm) + 1.9E-03 Table 5-4 Equipment Leak Protocol 

Rearrange Equation 3 and substitute ALR@ 10,000 ppm with ALR at 1,000 ppm 

LKFRAC % @ 10,000 ppm = 

[(ALR @ 1 000 ppm (kg/hr/source) - 1 9E-03)/0 24] × 100

Attachment 3ͲPage 3

LKFRAC % @ 10,000 ppm = 

[(ALR @ 1,000 ppm (kg/hr/source) - 1.9E-03)/0.24] × 100 

Substitute Equation 3 into Equation 4 

LKFRAC % @ 10,000 ppm = Equation 4

[(0.11 × (((NEIC Factor x 1.9 % Initial Leak Rate of Pumps LL @ 1,000ppm)/100 × 4.6E-04) - 1.9E-03)/0.24] × 100

Step 2: Calculate the LKFRAC % @ 10,000 ppm using 5,000 leak definition

Attachment 3ͲPage 3
Attachment 4

Uncontrolled

Type of Equipment

Pump Seals

kg/yr lb/yr kg/yr lb/yr kg/yr lb/yr kg/yr lb/yr kg/yr lb/yr kg/yr lb/yr

 * Light-liquid service 15 1,616 3,562 40 4,309 9,500 56 6,033 13,300 8 74 162 69 635 1,401 176 1,621 3,573 * Heavy-liquid service 0 -- -- 5 -- -- 36 -- -- 8 -- -- 61 -- -- 246 -- --Valves * Gas/vapor service 77 352 776 414 1,891 4,170 1,379 6,300 13,890 75 244 538 1,178 3,833 8,450 3,263 10,617 23,406 * Light-liquid service 380 1,950 4,300 1,179 6,052 13,342 1,980 10,163 22,406 251 824 1,816 2,428 7,970 17,570 5,857 19,225 42,385 * Heavy-liquid service 0 -- -- 71 -- -- 1,272 -- -- 216 -- -- 1,719 -- -- 3,163 -- --Connectors * Flanges - gas/vapor 0 0 0 0 0 0 0 0 0 164 150 330 2,333 2,129 4,693 7,641 6,972 15,371 * Flanges - G/LL 731 1,966 4,334 2,662 7,159 15,782 7,410 19,927 43,932 555 411 906 4,644 3,440 7,584 13,379 9,911 21,849 * Flanges - HL 0 0 0 0 0 0 0 0 0 454 0 4,186 0 7,725 0Agitators * Light-liquid service 0 0 0 3 323 712 0 0 0 0 0 0 0 0 0 0 0 0 * Heavy-liquid service 0 -- -- 3 -- -- 0 -- -- 0 0 0 000000Compressor Vent 0 0 0 2 3,995 8,806 8 15,978 35,226 2 11,143 24,565 19 105,856 233,372 31 172,712 380,765

Open-ended Valves 33 491 1,083 141 2,100 4,629 424 6,314 13,920 39 786 1,732 238 4,795 10,572 902 18,173 40,066Sampling Connections 8 1,051 2,317 35 4,599 10,139 106 13,928 30,707 10 1,314 2,897 70 9,198 20,278 159 20,893 46,060Pressure Relief Devices * Disks 2 1,822 4,017 45 40,997 90,382 76 69,239 152,646 9 12,614 27,810 79 110,726 244,110 119 166,790 367,710 * Disk holders, valves,etc. 2 -- -- 45 -- -- 76 -- -- 9 0 79 0 119 0TOTAL (lb/yr) 20,390 157,464 326,027 60,758 548,030 941,185TOTAL (tpy) 10.19499 78.73175 163.0133 30.37886 274.0151 470.5923

Count

Emissions

Count

Emissions

Count

Emissions

Count

Emissions

Count

Emissions

Count

Emissions

Model 1 Model 2 Model 3 Model 4 Model 5 Model 6

Attachment 4 - Page 1
Baseline

Type of Equipment

Pump Seals

kg/yr lb/yr kg/yr lb/yr kg/yr lb/yr kg/yr lb/yr kg/yr lb/yr kg/yr lb/yr

 * Light-liquid service 15 330 728 40 880 1,940 56 1,232 2,717 8 50 110 69 430 948 176 1,097 2,418 * Heavy-liquid service 0 -- -- 5 -- -- 36 -- -- 8 -- -- 61 -- -- 246 -- --Valves * Gas/vapor service 77 237 523 414 1,277 2,814 1,379 4,252 9,374 75 147 324 1,178 2,310 5,092 3,263 6,398 14,106 * Light-liquid service 380 1,299 2,863 1,179 4,030 8,884 1,980 6,767 14,920 251 491 1,082 2,428 4,750 10,471 5,857 11,457 25,259 * Heavy-liquid service 0 -- -- 71 -- -- 1,272 -- -- 216 -- -- 1,719 -- -- 3,163 -- --Connectors * Flanges - gas/vapor 0 0 0 0 0 0 0 0 0 164 150 330 2,333 2,129 4,693 7,641 6,972 15,371 * Flanges - G/LL 731 1,966 4,334 2,662 7,159 15,782 7,410 19,927 43,932 555 411 906 4,644 3,440 7,584 13,379 9,911 21,849 * Flanges - HL 0 0 0 0 0 0 0 0 0 454 0 4,186 0 7,725 0Agitators * Light-liquid service 0 0 0 3 66 146 0 0 0 0 -- -- 0 -- -- 0 -- -- * Heavy-liquid service 0 -- -- 3 -- -- 0 -- -- 0 -- -- 0 -- -- 0 -- --Compressor Vent 0 0 0 2 399 881 8 1,598 3,523 2 557 1,228 19 5,293 11,669 31 8,636 19,038Open-ended Valves 33 10 21 141 41 91 424 124 273 39 25 55 238 153 337 902 580 1,278Sampling Connections 8 0 0 35 0 0 106 0 0 10 0 0 70 0 0 159 0 0Pressure Relief Devices * Disks 2 0 0 45 0 0 76 0 0 9 0 0 79 0 0 119 0 0 * Disk holders, valves,etc. 2 -- -- 45 -- -- 76 -- -- 9 0 79 0 119 0TOTAL (lb/yr) 8,470 30,538 74,737 4,036 40,795 99,319TOTAL (tpy) 4.234773 15.26886 37.36873 2.018204 20.39728 49.65975TOTAL REDUCTION (lb/yr) 11,920 126,926 251,289 56,721 507,236 841,865TOTAL REDUCTION (tpy) 5.960215 63.46289 125.6445 28.36066 253.6178 420.9325

Count

Emissions

Count

Emissions

Count

Emissions

Count

Emissions

Count

Emissions

Count

Emissions

Model 1 Model 2 Model 3 Model 4 Model 5 Model 6

Attachment 4 - Page 2
Valves Option 1

Type of Equipment

kg/yr lb/yr kg/yr lb/yr kg/yr lb/yr kg/yr lb/yr kg/yr lb/yr kg/yr lb/yr

Valves * Gas/vapor service 77 136.67 301 414 734.83 1,620 1,379 2,447.67 5,396 75 58 128 1,178 913 2,013 3,263 2,529 5,576 * Light-liquid service 380 770.69 1,699 1,179 2,391.17 5,272 1,980 4,015.70 8,853 251 195 431 2,428 1,889 4,165 5,857 4,558 10,048 * Heavy-liquid service 0 -- -- 71 -- -- 1,272 -- -- 216 -- -- 1,719 -- -- 3,163 -- --Other emissions (Opt 2) 2,306 5,083 8,545 18,839 22,881 50,444 1,193 2,630 11,445 25,231 27,195 59,955TOTAL (lb/yr) 7,083 25,731 64,693 3,188 31,409 75,579TOTAL (tpy) 3.541575 12.86557 32.34645 1.594243 15.70471 37.78925TOTAL REDUCTION (lb/yr) 1,386 4,807 10,045 848 9,385 23,741TOTAL REDUCTION (tpy) 0.6932 2.4033 5.0223 0.4240 4.6926 11.8705Pumps Option 1

Type of Equipment

Pump Seals

kg/yr lb/yr kg/yr lb/yr kg/yr lb/yr kg/yr lb/yr kg/yr lb/yr kg/yr lb/yr

 * Light-liquid service 15 91.27 201 40 243.40 537 56 340.76 751 8 23 50 69 197 434 176 502 1,108 * Heavy-liquid service 0 -- -- 5 -- -- 36 -- -- 8 -- -- 61 -- -- 246 -- --Other emissions (Opt 2) 1,975 4,355 7,665 16,899 21,649 47,727 1,143 2,520 11,015 24,283 26,098 57,537Other emissions (Opt 3) 907 2,000 3,126 6,892 6,463 14,249 253 559 2,802 6,178 7,087 15,624TOTAL (lb/yr) 6,557 24,327 62,728 3,129 30,896 74,269TOTAL (tpy) 3.278368 12.16368 31.36381 1.564474 15.44796 37.13435TOTAL REDUCTION (lb/yr) 526 1,404 1,965 60 513 1,310TOTAL REDUCTION (tpy) 0.263207 0.701884 0.982638 0.029768 0.25675 0.654898Connectors Option 1

Type of Equipment

kg/yr lb/yr kg/yr lb/yr kg/yr lb/yr kg/yr lb/yr kg/yr lb/yr kg/yr lb/yr

Connectors * Flanges - gas/vapor 0 -- -- 0 -- -- 0 -- -- 164 56.8 125 2,333 808.1 1,782 7,641 2,646.7 5,835 * Flanges - G/LL 731 1,037.3 2,287 2,662 3,777.6 8,328 7,410 10,515.4 23,182 555 135 297 4,644 1,128 2,487 13,379 3,249 7,164 * Flanges - HL 0 -- -- 0 -- -- 0 -- -- 454 -- -- 4,186 -- -- 7,725 -- --Other emissions (Opt 2) 10 21 507 1,117 1,721 3,795 582 1,284 5,446 12,006 9,215 20,317Other emissions (Opt 3, 4) 999 2,202 3,369 7,428 6,804 15,001 276 609 2,999 6,613 7,589 16,732TOTAL (lb/yr) 4,510 16,873 41,978 2,315 22,887 50,047TOTAL (tpy) 2.25489 8.436596 20.98901 1.157537 11.44337 25.02346TOTAL REDUCTION (lb/yr) 2,047 7,454 20,750 814 8,009 24,222TOTAL REDUCTION (tpy) 1.023479 3.727086 10.3748 0.406938 4.004589 12.11089

Count

Emissions Reduction

Count

Emissions Reduction

Count

Emissions Reduction

Count

Emissions Reduction

Count

Emissions Reduction

Count

Emissions Reduction

Model 1 Model 2 Model 3 Model 4 Model 5 Model 6

Count

Emissions Reduction

Count

Emissions Reduction

Count

Emissions Reduction

Count

Emissions Reduction

Count

Emissions Reduction

Count

Emissions Reduction

Model 1 Model 2 Model 3 Model 4 Model 5 Model 6

Count

Emissions

Count

Emissions

Count

Emissions

Count

Emissions

Count

Emissions

Count

Emissions

Model 1 Model 2 Model 3 Model 4 Model 5 Model 6

Attachment 4 - Page 3
Valves Option 2

Type of Equipment

kg/yr lb/yr kg/yr lb/yr kg/yr lb/yr kg/yr lb/yr kg/yr lb/yr kg/yr lb/yr

Valves * Gas/vapor service 77 122.61 270 414 659.22 1,453 1,379 2,195.81 4,841 75 13.81 30 1,178 216.98 478 3,263 601.01 1,325 * Light-liquid service 380 682.76 1,505 1,179 2,118.35 4,670 1,980 3,557.53 7,843 251 44.31 98 2,428 428.63 945 5,857 1,033.98 2,280 * Heavy-liquid service 0 -- -- 71 -- -- 1,272 -- -- 216 -- -- 1,719 -- -- 3,163 -- --Other emissions (Opt 2) 0 0 465 1,026 1,598 3,523 557 1,228 5,293 11,669 8,636 19,038Other emissions (Opt 4, 5, 6) 1,129 2,488 4,021 8,865 10,856 23,934 214 473 2,133 4,702 6,399 14,106TOTAL (lb/yr) 4,264 16,014 40,140 1,829 17,794 36,749TOTAL (tpy) 2.131855 8.007205 20.07009 0.914589 8.897193 18.3746TOTAL REDUCTION (lb/yr) 246 859 1,838 486 5,092 13,298TOTAL REDUCTION (tpy) 0.123035 0.429391 0.918926 0.242948 2.546176 6.64886

8865.17

Pumps Option 2

Type of Equipment

Pump Seals

kg/yr lb/yr kg/yr lb/yr kg/yr lb/yr kg/yr lb/yr kg/yr lb/yr kg/yr lb/yr

 * Light-liquid service 15 69.82 154 40 186.20 410 56 260.67 575 8 22.56 50 69 194.60 429 176 496.37 1,094 * Heavy-liquid service 0 -- -- 5 -- -- 36 -- -- 8 -- -- 61 -- -- 246 -- --Other emissions (Opt 2) 0 0 465 1,026 1,598 3,523 557 1,228 5,293 11,669 8,636 19,038Other emissions (Opt 5, 6) 1,037 2,287 3,778 8,328 10,515 23,182 192 422 1,936 4,268 5,896 12,999Other emissions (Opt 8) 805 1,776 2,778 6,123 5,753 12,684 58 128 646 1,423 1,635 3,605TOTAL (lb/yr) 4,216 15,888 39,964 1,829 17,789 36,736TOTAL (tpy) 2.108209 7.944149 19.98181 0.914283 8.894554 18.36787TOTAL REDUCTION (lb/yr) 47 126 177 0.61 5.28 13.47TOTAL REDUCTION (tpy) 0.023646 0.063056 0.088278 0.000306 0.002639 0.006733

Count

Emissions Reduction

Count

Emissions Reduction

Count

Emissions Reduction

Count

Emissions Reduction

Count

Emissions Reduction

Count

Emissions Reduction

Model 1 Model 2 Model 3 Model 4 Model 5 Model 6

Count

Emissions Reduction

Count

Emissions Reduction

Count

Emissions Reduction

Count

Emissions Reduction

Count

Emissions Reduction

Count

Emissions Reduction

Model 1 Model 2 Model 3 Model 4 Model 5 Model 6

Attachment 4 - Page 4
Attachment 5: Cost Effectiveness and Cost Calculations

Uncontrolled

Emissions (tpy) Capital Costs ($)

Annualized

Costs Without 

Recovery

Credits ($/yr)

VOC Recovery 

Credit ($/yr)

Total Annualized 

Cost ($/yr)

Emissions

Reduction (tpy)

Model 1 10.19 90,763 41,009 (2,980) 38,029 5.96

Model 2 78.73 455,982 129,599 (31,731) 97,867 63.46

Model 3 163.01 859,162 226,203 (62,822) 163,381 125.64Model 4 30.38 156,783 57,067 (14,180) 42,887 28.36

Model 5 274.02 956,067 263,308 (126,809) 136,499 253.62Model 6 470.59 1,658,781 461,483 (210,466) 251,017 420.93VALVES

Capital Costs 

($)

Annualized

Costs Without 

Recovery

Credits ($/yr)

VOC Recovery 

Credit ($/yr)

Incremental

Annualized Cost 

($/yr)

Incremental

Emissions

Reduction (tpy)

Overall Cost 

Effectiveness

($/ton)

Incremental

Capital Costs ($)

Incremental

Annualized Cost 

($/yr)

VOC Recovery 

Credit ($/yr)

Incremental

Annualized Cost 

($/yr)

Incremental

Emissions

Reduction (tpy)

Overall Cost 

Effectiveness

($/ton)

Model 1 1,707 362 (347) 15 0.69 22 3,768 963 (62) 901 0.12 7,323

Model 2 6,216 1,299 (1,202) 97 2.40 40 13,716 3,438 (215) 3,223 0.43 7,506

Model 3 14,030 2,869 (2,511) 358 5.02 71 30,944 7,536 (459) 7,076 0.92 7,701

Model 4 1,211 480 (212) 268 0.42 633 5,299 2,937 (121) 2,815 0.24 11,588Model 5 13,356 5,379 (2,346) 3,033 4.69 646 58,507 29,266 (1,273) 27,993 2.55 10,994

Model 6 33,743 13,660 (5,935) 7,725 11.87 651 147,886 82,886 (3,324) 79,562 6.65 11,966PUMPS

Capital Costs 

($)

Annualized

Costs Without 

Recovery

Credits ($/yr)

VOC Recovery 

Credit ($/yr)

Incremental

Annualized Cost 

($/yr)

Incremental

Emissions

Reduction (tpy)

Overall Cost 

Effectiveness

($/ton)

Incremental

Capital Costs ($)

Incremental

Annualized Cost 

($/yr)

VOC Recovery 

Credit ($/yr)

Incremental

Annualized Cost 

($/yr)

Incremental

Emissions

Reduction (tpy)

Overall Cost 

Effectiveness

($/ton)

Model 1 2,231 443 (132) 312 0.26 1,184 998 366 (12) 354 0.02 14,977

Model 2 5,948 1,182 (351) 831 0.70 1,184 2,661 976 (32) 944 0.06 14,977

Model 3 8,328 1,654 (491) 1,163 0.98 1,184 3,725 1,366 (44) 1,322 0.09 14,977

Model 4 262 204 (15) 189 0.03 6,339 135 437 (0) 437 0.00 1,429,098

Model 5 2,259 1,756 (128) 1,628 0.26 6,339 1,168 3,773 (1) 3,772 0.00 1,429,098

Model 6 5,763 4,479 (327) 4,152 0.65 6,339 2,980 9,625 (3) 9,622 0.01 1,429,098

OEL Monitoring (Incremental to Baseline)

CONNECTORS

Capital Costs 

($)

Annualized

Costs Without 

Recovery

Credits ($/yr)

VOC Recovery 

Credit ($/yr)

Incremental

Annualized Cost 

($/yr)

Incremental

Emissions

Reduction (tpy)

Overall Cost 

Effectiveness

($/ton)

Incremental

Capital Cost ($)

Incremental

Annualized Cost 

($/yr)

Model 1 19,368 7,872 (512) 7,360 1.02 7,192 Model 1 808 176Model 2 65,633 15,725 (1,864) 13,861 3.73 3,719 Model 2 3,453 750Model 3 179,391 35,034 (5,187) 29,846 10.37 2,877 Model 3 10,383 2,256

Model 4 19,494 7,918 (203) 7,714 0.41 18,957 Model 4 997 234Model 5 173,029 34,190 (2,002) 32,188 4.00 8,038 Model 5 6,082 1,429

Model 6 517,562 93,145 (6,055) 87,089 12.11 7,191 Model 6 23,049 5,415

Baseline

Valves Option 1 (Incremental to Baseline) Valves Option 2 (Incremental to Option 1)

Pumps Option 1 (Incremental to Baseline) Pumps Option 2 (Incremental to Option 1)

Connectors Option 1 (Incremental to Baseline)

Attachment 5 - Page 1
Baseline Cost Estimates

Type of Component Number of Components

Initial

Monitoring

Fee or Unit 

Cost ($/comp)

Initial LDAR 

Costs ($) 

(Capital)

Initial

LDAR

Admin.

Costs

Frequency of 

Monitoring

(times/yr)

Subsequent

Monitoring

Fee ($/comp) 

or Charge 

(%)

Annual

Monitoring

Costs ($/yr)

Annual

Maintenance

Costs ($/yr)

Initial Leak 

Frequency

(%)

Initial

Number

of Leaks

Subsequent

Leak

Frequency

(%)

Annual

Number

of Leaks

Percent

Repaired

OnLine

Model 1 Pump Seals

 * Light-liquid service 15 23.80 742.42 12 1.50 580.13 116.32 2.42 0.36 0.23 0.41 100 * Heavy-liquid service 0 1.10 0.00Valves * Gas/vapor service 77 23.80 1852.51 2 1.50 231.00 0.33 0.26 0.33 0.51 75 * Light-liquid service 380 23.80 9142.25 2 1.50 1140.00 0.33 1.27 0.33 2.54 75 * Heavy-liquid service 0 1.10 0.00Connectors * Flanges - gas/vapor 0 1.10 0.00 * Flanges - light liquid 731 1.10 807.02 * Flanges -heavy liquid 0 1.10 0.00Agitators * Light-liquid service 0 23.80 0.00 12 1.50 0.00 0.00 2.42 0.00 0.23 0.00 100.00 * Heavy-liquid service 0 1.10 0.00Pressure Relief Devices * Disks 2 122.11 244.21 0 2.00 0.00 4.88 * Disk holders, valves,etc. 2 6,374.29 12748.58 5.00 637.43

OEL 33 140.92 4650.43 5.00 232.52

Sampling Connections 8 687.86 5502.86 5.00 275.14Compressor Vent 0 10526.21 0.00 5.00 0.00Replacement Pump Seals 15 282.71 102.65

Monitoring Instrument 1 10,800 10,800

Data Collection System 1 14,500 14,500

hr/activity $/hr

Administrative and Reports 250 92.72Planning and Training 320 92.72 29670.40TOTALS 61092.92 29670.40 1951.13 1266.30

Capital Costs ($) 90,763

Annualized Capital ($/yr) 12,924

Annual Expenses ($/yr) 28,085

Annual Fixed Costs ($/yr) 37,123 41,009

Annual Variable Costs ($/yr) 3,886

Baseline Attachment 5 - Page 2
Baseline Cost Estimates

Type of Component

Model 1 Pump Seals

 * Light-liquid service * Heavy-liquid serviceValves * Gas/vapor service * Light-liquid service * Heavy-liquid serviceConnectors * Flanges - gas/vapor * Flanges - light liquid * Flanges -heavy liquidAgitators * Light-liquid service * Heavy-liquid servicePressure Relief Devices * Disks * Disk holders, valves,etc.OELSampling ConnectionsCompressor VentReplacement Pump Seals

Monitoring InstrumentData Collection SystemAdministrative and ReportsPlanning and TrainingTOTALS

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

OnLine Leak 

Repair Cost 

($/yr)

Percent

Requiring

Further

Repair

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

Offline Leak 

Repair Cost 

($/yr)

Monitoring

to Verify 

Repair ($)

Annual

Admin.

Cost

($/yr)

Annual

Misc.

Charges

($/yr)

16.00 66.24 436.08 0 80.00 66.24 0.00 0.62 93.06

0.17 66.24 4.27 25 4.00 66.24 34.08 0.770.17 66.24 21.06 25 4.00 66.24 168.17 3.81

16.00 66.24 0.00 0 80.00 66.24 0.00 0.00 0.00

9.77

509.94186.02220.11

0.00

23180.00

461.41 202.25 5.20 23180.00 1018.90

Baseline Attachment 5 - Page 3
Option 1 Cost Estimates

Type of Component Number of Components

Initial

Monitoring

Fee or Unit 

Cost ($/comp)

Initial LDAR 

Costs ($) 

(Capital)

Initial

LDAR

Admin.

Costs

Frequency of 

Monitoring

(times/yr)

Subsequent

Monitoring

Fee ($/comp) 

or Charge 

(%)

Annual

Monitoring

Costs ($/yr)

Annual

Maintenance

Costs ($/yr)

Initial Leak 

Frequency

(%)

Initial

Number

of Leaks

Subsequent

Leak

Frequency

(%)

Annual

Number

of Leaks

Percent

Repaired

OnLine

Model 2 Pump Seals

 * Light-liquid service 40 23.80 1979.78 12 1.50 1547.01 310.20 2.42 0.97 0.23 1.10 100 * Heavy-liquid service 5 1.10 5.52Valves * Gas/vapor service 414 23.80 9960.24 2 1.50 1242.00 0.33 1.38 0.33 2.77 75

 * Light-liquid service 1,179 23.80 28365.03 2 1.50 3537.00 0.33 3.94 0.33 7.88 75 * Heavy-liquid service 71 1.10 78.38Connectors * Flanges - gas/vapor 0 1.10 0.00 * Flanges - light liquid 2,662 1.10 2938.85 * Flanges -heavy liquid 0 1.10 0.00Agitators * Light-liquid service 3 23.80 71.41 12 1.50 140.11 0.00 2.42 0.07 0.23 0.08 100.00

 * Heavy-liquid service 3 1.10 3.31Pressure Relief Devices * Disks 45 122.11 5494.78 0 2.00 0.00 109.90 * Disk holders, valves,etc. 45 6,374.29 286842.95 5.00 14342.15OEL 141 140.92 19870.03 5.00 993.50

Sampling Connections 35 687.86 24075.01 5.00 1203.75

Compressor Vent 2 10526.21 21052.42 5.00 1052.62

Replacement Pump Seals 40 282.71 273.72

Monitoring Instrument 1 10,800 10,800

Data Collection System 1 14,500 14,500

hr/activity $/hr

Administrative and Reports 250 92.72Planning and Training 320 92.72 29670.40TOTALS 426311.44 29670.40 6466.12 18012.11

Capital Costs ($) 455,982

Annualized Capital ($/yr) 65,338

Annual Expenses ($/yr) 64,261

Annual Fixed Costs ($/yr) 103,059 129,599

Annual Variable Costs ($/yr) 26,539

Baseline Attachment 5 - Page 4
Option 1 Cost Estimates

Type of Component

Model 2 Pump Seals

 * Light-liquid service * Heavy-liquid serviceValves * Gas/vapor service * Light-liquid service * Heavy-liquid serviceConnectors * Flanges - gas/vapor * Flanges - light liquid * Flanges -heavy liquidAgitators * Light-liquid service * Heavy-liquid servicePressure Relief Devices * Disks * Disk holders, valves,etc.OELSampling ConnectionsCompressor VentReplacement Pump Seals

Monitoring InstrumentData Collection SystemAdministrative and ReportsPlanning and TrainingTOTALS

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

OnLine Leak 

Repair Cost 

($/yr)

Percent

Requiring

Further

Repair

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

Offline Leak 

Repair Cost 

($/yr)

Monitoring

to Verify 

Repair ($)

Annual

Admin.

Cost

($/yr)

Annual

Misc.

Charges

($/yr)

16.00 66.24 1162.87 0 80.00 66.24 0.00 1.65 248.16

0.17 66.24 22.95 25 4.00 66.24 183.22 4.150.17 66.24 65.35 25 4.00 66.24 521.78 11.82

16.00 66.24 87.22 0 80.00 66.24 0.00 0.12 0.00

219.79

11473.72

794.80963.00842.10

23180.00

1338.39 705.00 17.73 23180.00 14541.57

Baseline Attachment 5 - Page 5
Option 1 Cost Estimates

Type of Component Number of Components

Initial

Monitoring

Fee or Unit 

Cost ($/comp)

Initial LDAR 

Costs ($) 

(Capital)

Initial

LDAR

Admin.

Costs

Frequency of 

Monitoring

(times/yr)

Subsequent

Monitoring

Fee ($/comp) 

or Charge 

(%)

Annual

Monitoring

Costs ($/yr)

Annual

Maintenance

Costs ($/yr)

Initial Leak 

Frequency

(%)

Initial

Number

of Leaks

Subsequent

Leak

Frequency

(%)

Annual

Number

of Leaks

Percent

Repaired

OnLine

Model 3 Pump Seals

 * Light-liquid service 56 23.80 2771.69 12 1.50 2165.81 434.27 2.42 1.36 0.23 1.54 100 * Heavy-liquid service 36 1.10 39.74Valves * Gas/vapor service 1,379 23.80 33176.74 2 1.50 4137.00 0.33 4.61 0.33 9.21 75

 * Light-liquid service 1,980 23.80 47635.92 2 1.50 5940.00 0.33 6.61 0.33 13.23 75 * Heavy-liquid service 1,272 1.10 1404.29Connectors * Flanges - gas/vapor 0 1.10 0.00 * Flanges - light liquid 7,410 1.10 8180.64 * Flanges -heavy liquid 0 1.10 0.00Agitators * Light-liquid service 0 23.80 0.00 12 1.50 0.00 0.00 2.42 0.00 0.23 0.00 100.00 * Heavy-liquid service 0 1.10 0.00Pressure Relief Devices * Disks 76 122.11 9280.07 0 2.00 0.00 185.60 * Disk holders, valves,etc. 76 6,374.29 484445.88 5.00 24222.29OEL 424 140.92 59751.02 5.00 2987.55Sampling Connections 106 687.86 72912.88 5.00 3645.64Compressor Vent 8 10526.21 84209.70 5.00 4210.48

Replacement Pump Seals 56 282.71 383.21

Monitoring Instrument 1 10,800 10,800

Data Collection System 1 14,500 14,500

hr/activity $/hr

Administrative and Reports 250 92.72Planning and Training 320 92.72 29670.40TOTALS 829491.78 29670.40 12242.81 35685.85

Capital Costs ($) 859,162

Annualized Capital ($/yr) 122,987

Annual Expenses ($/yr) 103,217

Annual Fixed Costs ($/yr) 174,938 226,203

Annual Variable Costs ($/yr) 51,265

Baseline Attachment 5 - Page 6
Option 1 Cost Estimates

Type of Component

Model 3 Pump Seals

 * Light-liquid service * Heavy-liquid serviceValves * Gas/vapor service * Light-liquid service * Heavy-liquid serviceConnectors * Flanges - gas/vapor * Flanges - light liquid * Flanges -heavy liquidAgitators * Light-liquid service * Heavy-liquid servicePressure Relief Devices * Disks * Disk holders, valves,etc.OELSampling ConnectionsCompressor VentReplacement Pump Seals

Monitoring InstrumentData Collection SystemAdministrative and ReportsPlanning and TrainingTOTALS

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

OnLine Leak 

Repair Cost 

($/yr)

Percent

Requiring

Further

Repair

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

Offline Leak 

Repair Cost 

($/yr)

Monitoring

to Verify 

Repair ($)

Annual

Admin.

Cost

($/yr)

Annual

Misc.

Charges

($/yr)

16.00 66.24 1628.02 0 80.00 66.24 0.00 2.30 347.42

0.17 66.24 76.44 25 4.00 66.24 610.29 13.820.17 66.24 109.75 25 4.00 66.24 876.27 19.84

16.00 66.24 0.00 0 80.00 66.24 0.00 0.00 0.00

371.20

19377.84

2390.042916.523368.39

23180.00

1814.21 1486.57 35.97 23180.00 28771.40

Baseline Attachment 5 - Page 7
Option 1 Cost Estimates

Type of Component Number of Components

Initial

Monitoring

Fee or Unit 

Cost ($/comp)

Initial LDAR 

Costs ($) 

(Capital)

Initial

LDAR

Admin.

Costs

Frequency of 

Monitoring

(times/yr)

Subsequent

Monitoring

Fee ($/comp) 

or Charge 

(%)

Annual

Monitoring

Costs ($/yr)

Annual

Maintenance

Costs ($/yr)

Initial Leak 

Frequency

(%)

Initial

Number

of Leaks

Subsequent

Leak

Frequency

(%)

Annual

Number

of Leaks

Percent

Repaired

OnLine

Model 4 Pump Seals

 * Light-liquid service 8 23.80 264.94 12 1.50 309.40 238.15 0.88 0.07 0.88 0.84 100

 * Heavy-liquid service 8 1.10 8.83Valves * Gas/vapor service 75 23.80 1852.89 2 1.50 225.00 1.18 0.89 1.18 1.78 75 * Light-liquid service 251 23.80 6238.36 2 1.50 753.00 1.38 3.46 1.38 6.93 75

 * Heavy-liquid service 216 1.10 238.46Connectors * Flanges - gas/vapor 164 1.10 181.06 * Flanges - light liquid 555 1.10 612.72 * Flanges -heavy liquid 454 1.10 501.22Agitators * Light-liquid service 0 23.80 0.00 12 1.50 0.00 0.00 0.88 0.00 0.88 0.00 100.00 * Heavy-liquid service 0 1.10 0.00Pressure Relief Devices * Disks 9 122.11 1098.96 0 2.00 0.00 21.98 * Disk holders, valves,etc. 9 6,374.29 57368.59 5.00 2868.43OEL 39 140.92 5495.97 5.00 274.80

Sampling Connections 10 687.86 6878.57 5.00 343.93

Compressor Vent 2 10526.21 21052.42 5.00 1052.62

Replacement Pump Seals 8 282.71 19.85

Monitoring Instrument 1 10,800 10,800Data Collection System 1 14,500 14,500

hr/activity $/hr

Administrative and Reports 250 92.72 0.00

Planning and Training 320 92.72 29670.40TOTALS 127112.84 29670.40 1287.40 4799.91

Capital Costs ($) 156,783

Annualized Capital ($/yr) 22,377

Annual Expenses ($/yr) 34,690

Annual Fixed Costs ($/yr) 49,424 57,067

Annual Variable Costs ($/yr) 7,643

Baseline Attachment 5 - Page 8
Option 1 Cost Estimates

Type of Component

Model 4 Pump Seals

 * Light-liquid service * Heavy-liquid serviceValves * Gas/vapor service * Light-liquid service * Heavy-liquid serviceConnectors * Flanges - gas/vapor * Flanges - light liquid * Flanges -heavy liquidAgitators * Light-liquid service * Heavy-liquid servicePressure Relief Devices * Disks * Disk holders, valves,etc.OELSampling ConnectionsCompressor VentReplacement Pump Seals

Monitoring InstrumentData Collection SystemAdministrative and ReportsPlanning and TrainingTOTALS

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

OnLine Leak 

Repair Cost 

($/yr)

Percent

Requiring

Further

Repair

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

Offline Leak 

Repair Cost 

($/yr)

Monitoring

to Verify 

Repair ($)

Annual

Admin.

Cost

($/yr)

Annual

Misc.

Charges

($/yr)

16.00 66.24 892.78 0 80.00 66.24 0.00 1.26 190.52

0.17 66.24 14.74 25 4.00 66.24 117.69 2.670.17 66.24 57.49 25 4.00 66.24 458.97 10.39

16.00 66.24 0.00 0 80.00 66.24 0.00 0.00 0.00

43.96

2294.74

219.84275.14842.10

23180.00

965.01 576.66 14.32 23180.00 3866.30

Baseline Attachment 5 - Page 9
Option 1 Cost Estimates

Type of Component Number of Components

Initial

Monitoring

Fee or Unit 

Cost ($/comp)

Initial LDAR 

Costs ($) 

(Capital)

Initial

LDAR

Admin.

Costs

Frequency of 

Monitoring

(times/yr)

Subsequent

Monitoring

Fee ($/comp) 

or Charge 

(%)

Annual

Monitoring

Costs ($/yr)

Annual

Maintenance

Costs ($/yr)

Initial Leak 

Frequency

(%)

Initial

Number

of Leaks

Subsequent

Leak

Frequency

(%)

Annual

Number

of Leaks

Percent

Repaired

OnLine

Model 5 Pump Seals

 * Light-liquid service 69 23.80 2285.11 12 1.50 2668.59 2054.04 0.88 0.61 0.88 7.27 100 * Heavy-liquid service 61 1.10 67.34Valves * Gas/vapor service 1,178 23.80 29102.67 2 1.50 3534.00 1.18 13.95 1.18 27.91 75

 * Light-liquid service 2,428 23.80 60345.61 2 1.50 7284.00 1.38 33.51 1.38 67.03 75 * Heavy-liquid service 1,719 1.10 1897.78Connectors * Flanges - gas/vapor 2,333 1.10 2575.63 * Flanges - light liquid 4,644 1.10 5126.98 * Flanges -heavy liquid 4,186 1.10 4621.34Agitators * Light-liquid service 0 23.80 0.00 12 1.50 0.00 0.00 0.88 0.00 0.88 0.00 100.00 * Heavy-liquid service 0 1.10 0.00Pressure Relief Devices * Disks 79 122.11 9646.39 0 2.00 0.00 192.93 * Disk holders, valves,etc. 79 6,374.29 503568.74 5.00 25178.44OEL 238 140.92 33539.49 5.00 1676.97Sampling Connections 70 687.86 48150.02 5.00 2407.50

Compressor Vent 19 10526.21 199998.03 5.00 9999.90

Replacement Pump Seals 69 282.71 171.17

Monitoring Instrument 1 10,800 10,800

Data Collection System 1 14,500 14,500

hr/activity $/hr

Administrative and Reports 250 92.72 0.00

Planning and Training 320 92.72 29670.40TOTALS 926396.30 29670.40 13486.59 41509.78

Capital Costs ($) 956,067

Annualized Capital ($/yr) 136,763

Annual Expenses ($/yr) 126,545

Annual Fixed Costs ($/yr) 193,382 263,308

Annual Variable Costs ($/yr) 69,926

Baseline Attachment 5 - Page 10
Option 1 Cost Estimates

Type of Component

Model 5 Pump Seals

 * Light-liquid service * Heavy-liquid serviceValves * Gas/vapor service * Light-liquid service * Heavy-liquid serviceConnectors * Flanges - gas/vapor * Flanges - light liquid * Flanges -heavy liquidAgitators * Light-liquid service * Heavy-liquid servicePressure Relief Devices * Disks * Disk holders, valves,etc.OELSampling ConnectionsCompressor VentReplacement Pump Seals

Monitoring InstrumentData Collection SystemAdministrative and ReportsPlanning and TrainingTOTALS

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

OnLine Leak 

Repair Cost 

($/yr)

Percent

Requiring

Further

Repair

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

Offline Leak 

Repair Cost 

($/yr)

Monitoring

to Verify 

Repair ($)

Annual

Admin.

Cost

($/yr)

Annual

Misc.

Charges

($/yr)

16.00 66.24 7700.24 0 80.00 66.24 0.00 10.90 1643.23

0.17 66.24 231.52 25 4.00 66.24 1848.46 41.860.17 66.24 556.08 25 4.00 66.24 4439.77 100.54

16.00 66.24 0.00 0 80.00 66.24 0.00 0.00 0.00

385.86

20142.75

1341.581926.007999.92

23180.00

8487.84 6288.23 153.29 23180.00 33439.34

Baseline Attachment 5 - Page 11
Option 1 Cost Estimates

Type of Component Number of Components

Initial

Monitoring

Fee or Unit 

Cost ($/comp)

Initial LDAR 

Costs ($) 

(Capital)

Initial

LDAR

Admin.

Costs

Frequency of 

Monitoring

(times/yr)

Subsequent

Monitoring

Fee ($/comp) 

or Charge 

(%)

Annual

Monitoring

Costs ($/yr)

Annual

Maintenance

Costs ($/yr)

Initial Leak 

Frequency

(%)

Initial

Number

of Leaks

Subsequent

Leak

Frequency

(%)

Annual

Number

of Leaks

Percent

Repaired

OnLine

Model 6 Pump Seals

 * Light-liquid service 176 23.80 5828.68 12 1.50 6806.84 5239.29 0.88 1.54 0.88 18.53 100 * Heavy-liquid service 246 1.10 271.58Valves * Gas/vapor service 3,263 23.80 80612.91 2 1.50 9789.00 1.18 38.65 1.18 77.30 75

 * Light-liquid service 5,857 23.80 145570.13 2 1.50 17571.00 1.38 80.84 1.38 161.68 75 * Heavy-liquid service 3,163 1.10 3491.95Connectors * Flanges - gas/vapor 7,641 1.10 8435.66 * Flanges - light liquid 13,379 1.10 14770.42 * Flanges -heavy liquid 7,725 1.10 8528.40Agitators * Light-liquid service 0 23.80 0.00 12 1.50 0.00 0.00 0.88 0.00 0.88 0.00 100.00 * Heavy-liquid service 0 1.10 0.00Pressure Relief Devices * Disks 119 122.11 14530.64 0 2.00 0.00 290.61 * Disk holders, valves,etc. 119 6,374.29 758540.26 5.00 37927.01OEL 902 140.92 127111.84 5.00 6355.59Sampling Connections 159 687.86 109369.32 5.00 5468.47Compressor Vent 31 10526.21 326312.58 5.00 16315.63

Replacement Pump Seals 176 282.71 436.61

Monitoring Instrument 1 10,800 10,800

Data Collection System 1 14,500 14,500

hr/activity $/hr

Administrative and Reports 250 92.72 0.00

Planning and Training 320 92.72 29670.40TOTALS 1629110.97 29670.40 34166.84 71596.60

Capital Costs ($) 1,658,781

Annualized Capital ($/yr) 237,074

Annual Expenses ($/yr) 224,410

Annual Fixed Costs ($/yr) 317,880 461,483

Annual Variable Costs ($/yr) 143,604

Baseline Attachment 5 - Page 12
Option 1 Cost Estimates

Type of Component

Model 6 Pump Seals

 * Light-liquid service * Heavy-liquid serviceValves * Gas/vapor service * Light-liquid service * Heavy-liquid serviceConnectors * Flanges - gas/vapor * Flanges - light liquid * Flanges -heavy liquidAgitators * Light-liquid service * Heavy-liquid servicePressure Relief Devices * Disks * Disk holders, valves,etc.OELSampling ConnectionsCompressor VentReplacement Pump Seals

Monitoring InstrumentData Collection SystemAdministrative and ReportsPlanning and TrainingTOTALS

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

OnLine Leak 

Repair Cost 

($/yr)

Percent

Requiring

Further

Repair

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

Offline Leak 

Repair Cost 

($/yr)

Monitoring

to Verify 

Repair ($)

Annual

Admin.

Cost

($/yr)

Annual

Misc.

Charges

($/yr)

16.00 66.24 19641.19 0 80.00 66.24 0.00 27.80 4191.43

0.17 66.24 641.30 25 4.00 66.24 5120.15 115.950.17 66.24 1341.42 25 4.00 66.24 10709.93 242.53

16.00 66.24 0.00 0 80.00 66.24 0.00 0.00 0.00

581.23

30341.61

5084.474374.77

13052.50

23180.00

21623.91 15830.08 386.27 23180.00 57626.02

Baseline Attachment 5 - Page 13
Pump Option 1 Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) Initial Number of Leaks Subsequent Leak Frequency (%) Annual Number of Leaks

Model 1

Pump Seals * Light-liquid service 15 0.00 2146.74 12 1.50 580.13 130.46 13.48 2.02 0.26 0.46 * Heavy-liquid service 0 0.00 0.00

Replacement Pump Seals 15 282.71 571.84

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00

TOTALS 2718.58 0.00 580.13 130.46

Capital Costs ($) 2,719

Annualized Capital ($/yr) 444

Annual Expenses ($/yr) 1,305

Baseline Monitoring

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) Initial Number of Leaks Subsequent Leak Frequency (%) Annual Number of Leaks

Model 1

Pump Seals * Light-liquid service 15 0.00 385.35 12 1.50 580.13 116.32 2.42 0.36 0.23 0.41 * Heavy-liquid service 0 0.00 0.00

Replacement Pump Seals 15 282.71 102.65

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00

TOTALS 488.00 0.00 580.13 116.32

Monitoring Repair

Baseline Capital Costs ($) 488 488.00

Baseline Annualized Capital ($/yr) 80 79.77

Baseline Annual Expenses ($/yr) 1,226 580.75 552.40

INCREMENTAL COSTS OF PUMP OPTION 1

Incremental Capital Costs ($) 2,230.58

Annualized Capital ($/yr) 364.60

Incremental Annual Expenses ($/yr) 78.53

Pumps Option 1 Attachment 5 - Page 14
Pump Option 1 Cost Estimates

Type of Component

Model 1

Pump Seals * Light-liquid service * Heavy-liquid serviceReplacement Pump Seals

Administrative and ReportsPlanning and TrainingTOTALS

Baseline Monitoring

Type of Component

Model 1

Pump Seals * Light-liquid service * Heavy-liquid serviceReplacement Pump SealsAdministrative and ReportsPlanning and TrainingTOTALS

Percent

Repaired

OnLine

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

OnLine Leak 

Repair Cost 

($/yr)

Percent

Requiring

Further

Repair

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

Offline Leak 

Repair Cost 

($/yr)

Monitoring

to Verify 

Repair ($)

Annual

Admin.

Cost

($/yr)

Annual

Misc.

Charges

($/yr)

100 16.00 66.24 489.08 0 80.00 66.24 0.00 0.69 104.37

0.00

489.08 0.00 0.69 0.00 104.37

Percent

Repaired

OnLine

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

OnLine Leak 

Repair Cost 

($/yr)

Percent

Requiring

Further

Repair

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

Offline Leak 

Repair Cost 

($/yr)

Monitoring

to Verify 

Repair ($)

Annual

Admin.

Cost

($/yr)

Annual

Misc.

Charges

($/yr)

100 16.00 66.24 436.08 0 80.00 66.24 0.00 0.62 93.06

0.00

436.08 0.00 0.62 0.00 93.06

Pumps Option 1 Attachment 5 - Page 15
Pump Option 1 Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) Initial Number of Leaks Subsequent Leak Frequency (%) Annual Number of Leaks

Model 2

Pump Seals * Light-liquid service 40 0.00 5724.65 12 1.50 1547.01 347.90 13.48 5.39 0.26 1.23 * Heavy-liquid service 5 0.00 0.00

Replacement Pump Seals 40 282.71 1524.89

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00

TOTALS 7249.55 0.00 1547.01 347.90

Capital Costs ($) 7,250

Annualized Capital ($/yr) 1,185

Annual Expenses ($/yr) 3,479

Baseline Monitoring

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) Initial Number of Leaks Subsequent Leak Frequency (%) Annual Number of Leaks

Model 2

Pump Seals * Light-liquid service 40 0.00 1027.60 12 1.50 1547.01 310.20 2.42 0.97 0.23 1.10 * Heavy-liquid service 5 0.00 0.00

Replacement Pump Seals 40 282.71 273.72

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00

TOTALS 1301.32 0.00 1547.01 310.20

Monitoring Repair

Baseline Capital Costs ($) 1,301 1,301.32

Baseline Annualized Capital ($/yr) 213 212.71

Baseline Annual Expenses ($/yr) 3,270 1,548.65 1,473.07

INCREMENTAL COSTS OF PUMP OPTION 1

Incremental Capital Costs ($) 5,948.23

Annualized Capital ($/yr) 972.27

Incremental Annual Expenses ($/yr) 209.41

Pumps Option 1 Attachment 5 - Page 16
Pump Option 1 Cost Estimates

Type of Component

Model 2

Pump Seals * Light-liquid service * Heavy-liquid serviceReplacement Pump Seals

Administrative and ReportsPlanning and TrainingTOTALS

Baseline Monitoring

Type of Component

Model 2

Pump Seals * Light-liquid service * Heavy-liquid serviceReplacement Pump SealsAdministrative and ReportsPlanning and TrainingTOTALS

Percent

Repaired

OnLine

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

OnLine Leak 

Repair Cost 

($/yr)

Percent

Requiring

Further

Repair

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

Offline Leak 

Repair Cost 

($/yr)

Monitoring

to Verify 

Repair ($)

Annual

Admin.

Cost

($/yr)

Annual

Misc.

Charges

($/yr)

100 16.00 66.24 1304.22 0 80.00 66.24 0.00 1.85 278.32

0.00

1304.22 0.00 1.85 0.00 278.32

Percent

Repaired

OnLine

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

OnLine Leak 

Repair Cost 

($/yr)

Percent

Requiring

Further

Repair

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

Offline Leak 

Repair Cost 

($/yr)

Monitoring

to Verify 

Repair ($)

Annual

Admin.

Cost

($/yr)

Annual

Misc.

Charges

($/yr)

100 16.00 66.24 1162.87 0 80.00 66.24 0.00 1.65 248.16

0.00

1162.87 0.00 1.65 0.00 248.16

Pumps Option 1 Attachment 5 - Page 17
Pump Option 1 Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) Initial Number of Leaks Subsequent Leak Frequency (%) Annual Number of Leaks

Model 3

Pump Seals * Light-liquid service 56 0.00 8014.51 12 1.50 2165.81 487.06 13.48 7.55 0.26 1.72 * Heavy-liquid service 36 0.00 0.00

Replacement Pump Seals 56 282.71 2134.85

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00

TOTALS 10149.37 0.00 2165.81 487.06

Capital Costs ($) 10,149

Annualized Capital ($/yr) 1,659

Annual Expenses ($/yr) 4,871

Baseline Monitoring

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) Initial Number of Leaks Subsequent Leak Frequency (%) Annual Number of Leaks

Model 3

Pump Seals * Light-liquid service 56 0.00 1438.64 12 1.50 2165.81 434.27 2.42 1.36 0.23 1.54 * Heavy-liquid service 36 0.00 0.00

Replacement Pump Seals 56 282.71 383.21

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00

TOTALS 1821.85 0.00 2165.81 434.27

Monitoring Repair

Baseline Capital Costs ($) 1,822 1,821.85

Baseline Annualized Capital ($/yr) 298 297.79

Baseline Annual Expenses ($/yr) 4,578 2,168.12 2,062.30

INCREMENTAL COSTS OF PUMP OPTION 1

Incremental Capital Costs ($) 8,327.52

Annualized Capital ($/yr) 1,361.17

Incremental Annual Expenses ($/yr) 293.18

Pumps Option 1 Attachment 5 - Page 18
Pump Option 1 Cost Estimates

Type of Component

Model 3

Pump Seals * Light-liquid service * Heavy-liquid serviceReplacement Pump Seals

Administrative and ReportsPlanning and TrainingTOTALS

Baseline Monitoring

Type of Component

Model 3

Pump Seals * Light-liquid service * Heavy-liquid serviceReplacement Pump SealsAdministrative and ReportsPlanning and TrainingTOTALS

Percent

Repaired

OnLine

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

OnLine Leak 

Repair Cost 

($/yr)

Percent

Requiring

Further

Repair

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

Offline Leak 

Repair Cost 

($/yr)

Monitoring

to Verify 

Repair ($)

Annual

Admin.

Cost

($/yr)

Annual

Misc.

Charges

($/yr)

100 16.00 66.24 1825.91 0 80.00 66.24 0.00 2.58 389.65

0.00

1825.91 0.00 2.58 0.00 389.65

Percent

Repaired

OnLine

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

OnLine Leak 

Repair Cost 

($/yr)

Percent

Requiring

Further

Repair

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

Offline Leak 

Repair Cost 

($/yr)

Monitoring

to Verify 

Repair ($)

Annual

Admin.

Cost

($/yr)

Annual

Misc.

Charges

($/yr)

100 16.00 66.24 1628.02 0 80.00 66.24 0.00 2.30 347.42

0.00

1628.02 0.00 2.30 0.00 347.42

Pumps Option 1 Attachment 5 - Page 19
Pump Option 1 Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) Initial Number of Leaks Subsequent Leak Frequency (%) Annual Number of Leaks

Model 4

Pump Seals * Light-liquid service 8 0.00 281.35 12 1.50 309.40 267.10 3.31 0.27 0.98 0.94 * Heavy-liquid service 8 0.00 0.00

Replacement Pump Seals 8 282.71 74.94

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00TOTALS 356.29 0.00 309.40 267.10

Capital Costs ($) 356

Annualized Capital ($/yr) 58

Annual Expenses ($/yr) 1,793

Baseline Monitoring

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) Initial Number of Leaks Subsequent Leak Frequency (%) Annual Number of Leaks

Model 4

Pump Seals * Light-liquid service 8 0.00 74.50 12 1.50 309.40 238.15 0.88 0.07 0.88 0.84 * Heavy-liquid service 8 0.00 0.00Replacement Pump Seals 8 282.71 19.85

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00TOTALS 94.35 0.00 309.40 238.15

Monitoring Repair

Baseline Capital Costs ($) 94 94.35

Baseline Annualized Capital ($/yr) 15 15.42

Baseline Annual Expenses ($/yr) 1,632 310.67 1,130.93

INCREMENTAL COSTS OF PUMP OPTION 1

Incremental Capital Costs ($) 261.95

Annualized Capital ($/yr) 42.82

Incremental Annual Expenses ($/yr) 160.77

Pumps Option 1 Attachment 5 - Page 20
Pump Option 1 Cost Estimates

Type of Component

Model 4

Pump Seals * Light-liquid service * Heavy-liquid serviceReplacement Pump Seals

Administrative and ReportsPlanning and TrainingTOTALS

Baseline Monitoring

Type of Component

Model 4

Pump Seals * Light-liquid service * Heavy-liquid serviceReplacement Pump SealsAdministrative and ReportsPlanning and TrainingTOTALS

Percent

Repaired

OnLine

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

OnLine Leak 

Repair Cost 

($/yr)

Percent

Requiring

Further

Repair

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

Offline Leak 

Repair Cost 

($/yr)

Monitoring

to Verify 

Repair ($)

Annual

Admin.

Cost

($/yr)

Annual

Misc.

Charges

($/yr)

100 16.00 66.24 1001.30 0 80.00 66.24 0.00 1.42 213.68

0.00

1001.30 0.00 1.42 0.00 213.68

Percent

Repaired

OnLine

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

OnLine Leak 

Repair Cost 

($/yr)

Percent

Requiring

Further

Repair

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

Offline Leak 

Repair Cost 

($/yr)

Monitoring

to Verify 

Repair ($)

Annual

Admin.

Cost

($/yr)

Annual

Misc.

Charges

($/yr)

100 16.00 66.24 892.78 0 80.00 66.24 0.00 1.26 190.52

0.00

892.78 0.00 1.26 0.00 190.52

Pumps Option 1 Attachment 5 - Page 21
Pump Option 1 Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) Initial Number of Leaks Subsequent Leak Frequency (%) Annual Number of Leaks

Model 5

Pump Seals * Light-liquid service 69 0.00 2426.65 12 1.50 2668.59 2303.71 3.31 2.29 0.98 8.15 * Heavy-liquid service 61 0.00 0.00

Replacement Pump Seals 69 282.71 646.39

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00

TOTALS 3073.04 0.00 2668.59 2303.71

Capital Costs ($) 3,073

Annualized Capital ($/yr) 502

Annual Expenses ($/yr) 15,464

Baseline Monitoring

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) Initial Number of Leaks Subsequent Leak Frequency (%) Annual Number of Leaks

Model 5

Pump Seals * Light-liquid service 69 0.00 642.59 12 1.50 2668.59 2054.04 0.88 0.61 0.88 7.27 * Heavy-liquid service 61 0.00 0.00

Replacement Pump Seals 69 282.71 171.17

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00

TOTALS 813.76 0.00 2668.59 2054.04

Monitoring Repair

Baseline Capital Costs ($) 814 813.76

Baseline Annualized Capital ($/yr) 133 133.01

Baseline Annual Expenses ($/yr) 14,077 2,679.49 9,754.28

INCREMENTAL COSTS OF PUMP OPTION 1

Incremental Capital Costs ($) 2,259.28

Annualized Capital ($/yr) 369.29

Incremental Annual Expenses ($/yr) 1,386.68

Pumps Option 1 Attachment 5 - Page 22
Pump Option 1 Cost Estimates

Type of Component

Model 5

Pump Seals * Light-liquid service * Heavy-liquid serviceReplacement Pump Seals

Administrative and ReportsPlanning and TrainingTOTALS

Baseline Monitoring

Type of Component

Model 5

Pump Seals * Light-liquid service * Heavy-liquid serviceReplacement Pump SealsAdministrative and ReportsPlanning and TrainingTOTALS

Percent

Repaired

OnLine

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

OnLine Leak 

Repair Cost 

($/yr)

Percent

Requiring

Further

Repair

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

Offline Leak 

Repair Cost 

($/yr)

Monitoring

to Verify 

Repair ($)

Annual

Admin.

Cost

($/yr)

Annual

Misc.

Charges

($/yr)

100 16.00 66.24 8636.20 0 80.00 66.24 0.00 12.22 1842.97

0.00

8636.20 0.00 12.22 0.00 1842.97

Percent

Repaired

OnLine

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

OnLine Leak 

Repair Cost 

($/yr)

Percent

Requiring

Further

Repair

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

Offline Leak 

Repair Cost 

($/yr)

Monitoring

to Verify 

Repair ($)

Annual

Admin.

Cost

($/yr)

Annual

Misc.

Charges

($/yr)

100 16.00 66.24 7700.24 0 80.00 66.24 0.00 10.90 1643.23

0.00

7700.24 0.00 10.90 0.00 1643.23

Pumps Option 1 Attachment 5 - Page 23
Pump Option 1 Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) Initial Number of Leaks Subsequent Leak Frequency (%) Annual Number of Leaks

Model 6

Pump Seals * Light-liquid service 176 0.00 6189.71 12 1.50 6806.84 5876.12 3.31 5.83 0.98 20.78

 * Heavy-liquid service 246 0.00 0.00Replacement Pump Seals 176 282.71 1648.77

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00

TOTALS 7838.49 0.00 6806.84 5876.12

Capital Costs ($) 7,838

Annualized Capital ($/yr) 1,281

Annual Expenses ($/yr) 39,444

Baseline Monitoring

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) Initial Number of Leaks Subsequent Leak Frequency (%) Annual Number of Leaks

Model 6

Pump Seals * Light-liquid service 176 0.00 1639.08 12 1.50 6806.84 5239.29 0.88 1.54 0.88 18.53

 * Heavy-liquid service 246 0.00 0.00Replacement Pump Seals 176 282.71 436.61

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00

TOTALS 2075.69 0.00 6806.84 5239.29

Monitoring Repair

Baseline Capital Costs ($) 2,076 2,075.69

Baseline Annualized Capital ($/yr) 339 339.28

Baseline Annual Expenses ($/yr) 35,907 6,834.63 24,880.48

INCREMENTAL COSTS OF PUMP OPTION 1

Incremental Capital Costs ($) 5,762.80

Annualized Capital ($/yr) 941.96

Incremental Annual Expenses ($/yr) 3,537.05

Pumps Option 1 Attachment 5 - Page 24
Pump Option 1 Cost Estimates

Type of Component

Model 6

Pump Seals * Light-liquid service * Heavy-liquid serviceReplacement Pump Seals

Administrative and ReportsPlanning and TrainingTOTALS

Baseline Monitoring

Type of Component

Model 6

Pump Seals * Light-liquid service * Heavy-liquid serviceReplacement Pump SealsAdministrative and ReportsPlanning and TrainingTOTALS

Percent

Repaired

OnLine

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

OnLine Leak 

Repair Cost 

($/yr)

Percent

Requiring

Further

Repair

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

Offline Leak 

Repair Cost 

($/yr)

Monitoring

to Verify 

Repair ($)

Annual

Admin.

Cost

($/yr)

Annual

Misc.

Charges

($/yr)

100 16.00 66.24 22028.56 0 80.00 66.24 0.00 31.18 4700.90

0.00

22028.56 0.00 31.18 0.00 4700.90

Percent

Repaired

OnLine

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

OnLine Leak 

Repair Cost 

($/yr)

Percent

Requiring

Further

Repair

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

Offline Leak 

Repair Cost 

($/yr)

Monitoring

to Verify 

Repair ($)

Annual

Admin.

Cost

($/yr)

Annual

Misc.

Charges

($/yr)

100 16.00 66.24 19641.19 0 80.00 66.24 0.00 27.80 4191.43

0.00

19641.19 0.00 27.80 0.00 4191.43

Pumps Option 1 Attachment 5 - Page 25
Pump Option 2 Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) Initial Number of Leaks Subsequent Leak Frequency (%) Annual Number of Leaks

Model 1 Pump Seals

 * Light-liquid service 15 0.00 2934.59 12 1.50 580.13 166.99 18.43 2.76 0.33 0.59

 * Heavy-liquid service 0 0.00 0.00

Replacement Pump Seals 15 282.71 781.70

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00TOTALS 3716.29 0.00 580.13 166.99

Capital Costs ($) 3,716

Annualized Capital ($/yr) 607

Annual Expenses ($/yr) 1,508

INCREMENTAL COSTS OF PUMP OPTION 2

Incremental Capital Costs ($) 998

Annualized Capital ($/yr) 163

Incremental Annual Expenses ($/yr) 203

Pumps Option 2 Attachment 5 - Page 26
Pump Option 2 Cost Estimates

Type of Component

Model 1 Pump Seals

 * Light-liquid service * Heavy-liquid serviceReplacement Pump Seals

Administrative and ReportsPlanning and TrainingTOTALS

Percent

Repaired

OnLine

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

OnLine Leak 

Repair Cost 

($/yr)

Percent

Requiring

Further

Repair

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

Offline Leak 

Repair Cost 

($/yr)

Monitoring

to Verify 

Repair ($)

Annual

Admin.

Cost

($/yr)

Annual

Misc.

Charges

($/yr)

100 16.00 66.24 626.02 0 80.00 66.24 0.00 0.89 133.59

0.00

626.02 0.00 0.89 0.00 133.59

Pumps Option 2 Attachment 5 - Page 27
Pumps Option 2 Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) Initial Number of Leaks Subsequent Leak Frequency (%) Annual Number of Leaks

Model 2 Pump Seals

 * Light-liquid service 40 0.00 7825.59 12 1.50 1547.01 445.31 18.43 7.37 0.33 1.58

 * Heavy-liquid service 5 0.00 0.00

Replacement Pump Seals 40 282.71 2084.53

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00TOTALS 9910.11 0.00 1547.01 445.31

Capital Costs ($) 9,910

Annualized Capital ($/yr) 1,620

Annual Expenses ($/yr) 4,020

INCREMENTAL COSTS OF PUMP OPTION 2

Incremental Capital Costs ($) 2,661

Annualized Capital ($/yr) 435

Incremental Annual Expenses ($/yr) 541

Pumps Option 2 Attachment 5 - Page 28
Pumps Option 2 Cost Estimates

Type of Component

Model 2 Pump Seals

 * Light-liquid service * Heavy-liquid serviceReplacement Pump Seals

Administrative and ReportsPlanning and TrainingTOTALS

Percent

Repaired

OnLine

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

OnLine Leak 

Repair Cost 

($/yr)

Percent

Requiring

Further

Repair

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

Offline Leak 

Repair Cost 

($/yr)

Monitoring

to Verify 

Repair ($)

Annual

Admin.

Cost

($/yr)

Annual

Misc.

Charges

($/yr)

100 16.00 66.24 1669.38 0 80.00 66.24 0.00 2.36 356.25

0.00

1669.38 0.00 2.36 0.00 356.25

Pumps Option 2 Attachment 5 - Page 29
Pumps Option 2 Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) Initial Number of Leaks Subsequent Leak Frequency (%) Annual Number of Leaks

Model 3 Pump Seals

 * Light-liquid service 56 0.00 10955.82 12 1.50 2165.81 623.43 18.43 10.32 0.33 2.21 * Heavy-liquid service 36 0.00 0.00

Replacement Pump Seals 56 282.71 2918.34

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00TOTALS 13874.16 0.00 2165.81 623.43

Capital Costs ($) 13,874

Annualized Capital ($/yr) 2,268

Annual Expenses ($/yr) 5,628

INCREMENTAL COSTS OF PUMP OPTION 2

Incremental Capital Costs ($) 3,725

Annualized Capital ($/yr) 609

Incremental Annual Expenses ($/yr) 757

Pumps Option 2 Attachment 5 - Page 30
Pumps Option 2 Cost Estimates

Type of Component

Model 3 Pump Seals

 * Light-liquid service * Heavy-liquid serviceReplacement Pump Seals

Administrative and ReportsPlanning and TrainingTOTALS

Percent

Repaired

OnLine

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

OnLine Leak 

Repair Cost 

($/yr)

Percent

Requiring

Further

Repair

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

Offline Leak 

Repair Cost 

($/yr)

Monitoring

to Verify 

Repair ($)

Annual

Admin.

Cost

($/yr)

Annual

Misc.

Charges

($/yr)

100 16.00 66.24 2337.13 0 80.00 66.24 0.00 3.31 498.74

0.00

2337.13 0.00 3.31 0.00 498.74

Pumps Option 2 Attachment 5 - Page 31
Pumps Option 2 Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) Initial Number of Leaks Subsequent Leak Frequency (%) Annual Number of Leaks

Model 4 Pump Seals

 * Light-liquid service 8 0.00 388.31 12 1.50 309.40 341.88 4.57 0.37 1.26 1.21

 * Heavy-liquid service 8 0.00 0.00

Replacement Pump Seals 8 282.71 103.43

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00TOTALS 491.74 0.00 309.40 341.88

Capital Costs ($) 492

Annualized Capital ($/yr) 80

Annual Expenses ($/yr) 2,208

INCREMENTAL COSTS OF PUMP OPTION 2

Incremental Capital Costs ($) 135

Annualized Capital ($/yr) 22

Incremental Annual Expenses ($/yr) 415

Pumps Option 2 Attachment 5 - Page 32
Pumps Option 2 Cost Estimates

Type of Component

Model 4 Pump Seals

 * Light-liquid service * Heavy-liquid serviceReplacement Pump Seals

Administrative and ReportsPlanning and TrainingTOTALS

Percent

Repaired

OnLine

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

OnLine Leak 

Repair Cost 

($/yr)

Percent

Requiring

Further

Repair

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

Offline Leak 

Repair Cost 

($/yr)

Monitoring

to Verify 

Repair ($)

Annual

Admin.

Cost

($/yr)

Annual

Misc.

Charges

($/yr)

100 16.00 66.24 1281.65 0 80.00 66.24 0.00 1.81 273.50

0.00

1281.65 0.00 1.81 0.00 273.50

Pumps Option 2 Attachment 5 - Page 33
Pumps Option 2 Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) Initial Number of Leaks Subsequent Leak Frequency (%) Annual Number of Leaks

Model 5 Pump Seals

 * Light-liquid service 69 0.00 3349.14 12 1.50 2668.59 2948.71 4.57 3.16 1.26 10.43

 * Heavy-liquid service 61 0.00 0.00

Replacement Pump Seals 69 282.71 892.12

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00TOTALS 4241.26 0.00 2668.59 2948.71

Capital Costs ($) 4,241

Annualized Capital ($/yr) 693

Annual Expenses ($/yr) 19,046

INCREMENTAL COSTS OF PUMP OPTION 2

Incremental Capital Costs ($) 1,168

Annualized Capital ($/yr) 191

Incremental Annual Expenses ($/yr) 3,582

Pumps Option 2 Attachment 5 - Page 34
Pumps Option 2 Cost Estimates

Type of Component

Model 5 Pump Seals

 * Light-liquid service * Heavy-liquid serviceReplacement Pump Seals

Administrative and ReportsPlanning and TrainingTOTALS

Percent

Repaired

OnLine

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

OnLine Leak 

Repair Cost 

($/yr)

Percent

Requiring

Further

Repair

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

Offline Leak 

Repair Cost 

($/yr)

Monitoring

to Verify 

Repair ($)

Annual

Admin.

Cost

($/yr)

Annual

Misc.

Charges

($/yr)

100 16.00 66.24 11054.21 0 80.00 66.24 0.00 15.65 2358.97

0.00

11054.21 0.00 15.65 0.00 2358.97

Pumps Option 2 Attachment 5 - Page 35
Pumps Option 2 Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) Initial Number of Leaks Subsequent Leak Frequency (%) Annual Number of Leaks

Model 6 Pump Seals

 * Light-liquid service 176 0.00 8542.73 12 1.50 6806.84 7521.35 4.57 8.05 1.26 26.60 * Heavy-liquid service 246 0.00 0.00Replacement Pump Seals 176 282.71 2275.55

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00TOTALS 10818.28 0.00 6806.84 7521.35

Capital Costs ($) 10,818

Annualized Capital ($/yr) 1,768

Annual Expenses ($/yr) 48,581

INCREMENTAL COSTS OF PUMP OPTION 2

Incremental Capital Costs ($) 2,980

Annualized Capital ($/yr) 487

Incremental Annual Expenses ($/yr) 9,138

Pumps Option 2 Attachment 5 - Page 36
Pumps Option 2 Cost Estimates

Type of Component

Model 6 Pump Seals

 * Light-liquid service * Heavy-liquid serviceReplacement Pump Seals

Administrative and ReportsPlanning and TrainingTOTALS

Percent

Repaired

OnLine

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

OnLine Leak 

Repair Cost 

($/yr)

Percent

Requiring

Further

Repair

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

Offline Leak 

Repair Cost 

($/yr)

Monitoring

to Verify 

Repair ($)

Annual

Admin.

Cost

($/yr)

Annual

Misc.

Charges

($/yr)

100 16.00 66.24 28196.24 0 80.00 66.24 0.00 39.91 6017.08

0.00

28196.24 0.00 39.91 0.00 6017.08

Pumps Option 2 Attachment 5 - Page 37
Valve Option 1 Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) Initial Number of Leaks Subsequent Leak Frequency (%) Annual Number of Leaks

Model 1

Valves * Gas/vapor service 77 0.00 423.93 2 1.50 231.00 7.24 5.58 0.51 0.78

 * Light-liquid service 380 0.00 1399.22 2 1.50 1140.00 4.84 18.40 0.51 3.84

 * Heavy-liquid service 0 0.00 0.00

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00TOTALS 1823.15 0.00 1371.00 0.00

Capital Costs ($) 1,823.15

Annualized Capital ($/yr) 259

Annual Expenses ($/yr) 1,723

Baseline Monitoring

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) Initial Number of Leaks Subsequent Leak Frequency (%) Annual Number of Leaks

Model 1

Valves * Gas/vapor service 77 0.00 19.56 2 1.50 231.00 0.33 0.26 0.33 0.51 * Light-liquid service 380 0.00 96.52 2 1.50 1140.00 0.33 1.27 0.33 2.54

 * Heavy-liquid service 0 0.00 0.00

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00

TOTALS 116.08 0.00 1371.00 0.00

Monitoring Repair

Baseline Capital Costs ($) 116.08 116.08

Baseline Annualized Capital ($/yr) 16 16.48

Baseline Annual Expenses ($/yr) 1,603 1,375.58 227.58

INCREMENTAL COSTS OF VALVE OPTION 1

Incremental Capital Costs ($) 1,707.07

Annualized Capital ($/yr) 242.40

Incremental Annual Expenses ($/yr) 119.35

Valves Option 1 Attachment 5 - Page 38
Valve Option 1 Cost Estimates

Type of Component

Model 1

Valves * Gas/vapor service * Light-liquid service * Heavy-liquid serviceAdministrative and ReportsPlanning and TrainingTOTALS

Baseline Monitoring

Type of Component

Model 1

Valves * Gas/vapor service * Light-liquid service * Heavy-liquid serviceAdministrative and ReportsPlanning and TrainingTOTALS

Percent

Repaired

OnLine

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

OnLine Leak 

Repair Cost 

($/yr)

Percent

Requiring

Further

Repair

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

Offline Leak 

Repair Cost 

($/yr)

Monitoring

to Verify 

Repair ($)

Annual

Admin.

Cost

($/yr)

Annual

Misc.

Charges

($/yr)

75 0.17 66.24 6.46 25 4.00 66.24 51.60 1.1775 0.17 66.24 31.89 25 4.00 66.24 254.63 5.77

0.00

38.35 306.22 6.93 0.00 0.00

Percent

Repaired

OnLine

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

OnLine Leak 

Repair Cost 

($/yr)

Percent

Requiring

Further

Repair

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

Offline Leak 

Repair Cost 

($/yr)

Monitoring

to Verify 

Repair ($)

Annual

Admin.

Cost

($/yr)

Annual

Misc.

Charges

($/yr)

75 0.17 66.24 4.27 25 4.00 66.24 34.08 0.7775 0.17 66.24 21.06 25 4.00 66.24 168.17 3.81

0.00

25.33 202.25 4.58 0.00 0.00

Valves Option 1 Attachment 5 - Page 39
Valve Option 1 Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) Initial Number of Leaks Subsequent Leak Frequency (%) Annual Number of Leaks

Model 2

Valves * Gas/vapor service 414 0.00 2279.31 2 1.50 1242.00 7.24 29.98 0.51 4.19 * Light-liquid service 1,179 0.00 4341.26 2 1.50 3537.00 4.84 57.09 0.51 11.93 * Heavy-liquid service 71 0.00 0.00

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00TOTALS 6620.56 0.00 4779.00 0.00

Capital Costs ($) 6,620.56

Annualized Capital ($/yr) 940

Annual Expenses ($/yr) 6,004

Baseline Monitoring

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) Initial Number of Leaks Subsequent Leak Frequency (%) Annual Number of Leaks

Model 2

Valves * Gas/vapor service 414 0.00 105.16 2 1.50 1242.00 0.33 1.38 0.33 2.77

 * Light-liquid service 1,179 0.00 299.48 2 1.50 3537.00 0.33 3.94 0.33 7.88

 * Heavy-liquid service 71 0.00 0.00

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00

TOTALS 404.63 0.00 4779.00 0.00

Monitoring Repair

Baseline Capital Costs ($) 404.63 404.63

Baseline Annualized Capital ($/yr) 57 57.46

Baseline Annual Expenses ($/yr) 5,588 4,794.96 793.30

INCREMENTAL COSTS OF VALVE OPTION 1

Incremental Capital Costs ($) 6,215.93

Annualized Capital ($/yr) 882.66

Incremental Annual Expenses ($/yr) 416.02

Valves Option 1 Attachment 5 - Page 40
Valve Option 1 Cost Estimates

Type of Component

Model 2

Valves * Gas/vapor service * Light-liquid service * Heavy-liquid serviceAdministrative and ReportsPlanning and TrainingTOTALS

Baseline Monitoring

Type of Component

Model 2

Valves * Gas/vapor service * Light-liquid service * Heavy-liquid serviceAdministrative and ReportsPlanning and TrainingTOTALS

Percent

Repaired

OnLine

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

OnLine Leak 

Repair Cost 

($/yr)

Percent

Requiring

Further

Repair

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

Offline Leak 

Repair Cost 

($/yr)

Monitoring

to Verify 

Repair ($)

Annual

Admin.

Cost

($/yr)

Annual

Misc.

Charges

($/yr)

75 0.17 66.24 34.75 25 4.00 66.24 277.41 6.2875 0.17 66.24 98.95 25 4.00 66.24 790.01 17.89

0.00

133.69 1067.42 24.17 0.00 0.00

Percent

Repaired

OnLine

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

OnLine Leak 

Repair Cost 

($/yr)

Percent

Requiring

Further

Repair

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

Offline Leak 

Repair Cost 

($/yr)

Monitoring

to Verify 

Repair ($)

Annual

Admin.

Cost

($/yr)

Annual

Misc.

Charges

($/yr)

75 0.17 66.24 22.95 25 4.00 66.24 183.22 4.1575 0.17 66.24 65.35 25 4.00 66.24 521.78 11.82

0.00

88.30 705.00 15.96 0.00 0.00

Valves Option 1 Attachment 5 - Page 41
Valve Option 1 Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) Initial Number of Leaks Subsequent Leak Frequency (%) Annual Number of Leaks

Model 3

Valves * Gas/vapor service 1,379 0.00 7592.18 2 1.50 4137.00 7.24 99.85 0.51 13.95 * Light-liquid service 1,980 0.00 7290.66 2 1.50 5940.00 4.84 95.88 0.51 20.03 * Heavy-liquid service 1,272 0.00 0.00

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00TOTALS 14882.84 0.00 10077.00 0.00

Capital Costs ($) 14,882.84

Annualized Capital ($/yr) 2,113

Annual Expenses ($/yr) 12,661

Baseline Monitoring

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) Initial Number of Leaks Subsequent Leak Frequency (%) Annual Number of Leaks

Model 3

Valves * Gas/vapor service 1,379 0.00 350.28 2 1.50 4137.00 0.33 4.61 0.33 9.21

 * Light-liquid service 1,980 0.00 502.94 2 1.50 5940.00 0.33 6.61 0.33 13.23

 * Heavy-liquid service 1,272 0.00 0.00

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00

TOTALS 853.21 0.00 10077.00 0.00

Monitoring Repair

Baseline Capital Costs ($) 853.21 853.21

Baseline Annualized Capital ($/yr) 121 121.16

Baseline Annual Expenses ($/yr) 11,783 10,110.66 1,672.76

INCREMENTAL COSTS OF VALVE OPTION 1

Incremental Capital Costs ($) 14,029.63

Annualized Capital ($/yr) 1,992.21

Incremental Annual Expenses ($/yr) 877.22

Valves Option 1 Attachment 5 - Page 42
Valve Option 1 Cost Estimates

Type of Component

Model 3

Valves * Gas/vapor service * Light-liquid service * Heavy-liquid serviceAdministrative and ReportsPlanning and TrainingTOTALS

Baseline Monitoring

Type of Component

Model 3

Valves * Gas/vapor service * Light-liquid service * Heavy-liquid serviceAdministrative and ReportsPlanning and TrainingTOTALS

Percent

Repaired

OnLine

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

OnLine Leak 

Repair Cost 

($/yr)

Percent

Requiring

Further

Repair

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

Offline Leak 

Repair Cost 

($/yr)

Monitoring

to Verify 

Repair ($)

Annual

Admin.

Cost

($/yr)

Annual

Misc.

Charges

($/yr)

75 0.17 66.24 115.73 25 4.00 66.24 924.03 20.9275 0.17 66.24 166.17 25 4.00 66.24 1326.74 30.04

0.00

281.91 2250.77 50.97 0.00 0.00

Percent

Repaired

OnLine

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

OnLine Leak 

Repair Cost 

($/yr)

Percent

Requiring

Further

Repair

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

Offline Leak 

Repair Cost 

($/yr)

Monitoring

to Verify 

Repair ($)

Annual

Admin.

Cost

($/yr)

Annual

Misc.

Charges

($/yr)

75 0.17 66.24 76.44 25 4.00 66.24 610.29 13.8275 0.17 66.24 109.75 25 4.00 66.24 876.27 19.84

0.00

186.19 1486.57 33.66 0.00 0.00

Valves Option 1 Attachment 5 - Page 43
Valve Option 1 Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) Initial Number of Leaks Subsequent Leak Frequency (%) Annual Number of Leaks

Model 4

Valves * Gas/vapor service 75 0.00 339.09 2 1.50 225.00 5.95 4.46 1.91 2.87

 * Light-liquid service 251 0.00 1203.19 2 1.50 753.00 6.30 15.82 1.97 9.89

 * Heavy-liquid service 216 0.00 0.00

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00

TOTALS 1542.28 0.00 978.00 0.00

Capital Costs ($) 1,542.28

Annualized Capital ($/yr) 219

Annual Expenses ($/yr) 1,948

Baseline Monitoring

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) Initial Number of Leaks Subsequent Leak Frequency (%) Annual Number of Leaks

Model 4

Valves * Gas/vapor service 75 0.00 67.55 2 1.50 225.00 1.18 0.89 1.18 1.78 * Light-liquid service 251 0.00 263.43 2 1.50 753.00 1.38 3.46 1.38 6.93 * Heavy-liquid service 216 0.00 0.00

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00

TOTALS 330.97 0.00 978.00 0.00

Monitoring Repair

Baseline Capital Costs ($) 330.97 330.97

Baseline Annualized Capital ($/yr) 47 47.00

Baseline Annual Expenses ($/yr) 1,640 991.06 648.88

INCREMENTAL COSTS OF VALVE OPTION 1

Incremental Capital Costs ($) 1,211.31

Annualized Capital ($/yr) 172.01

Incremental Annual Expenses ($/yr) 308.19

Valves Option 1 Attachment 5 - Page 44
Valve Option 1 Cost Estimates

Type of Component

Model 4

Valves * Gas/vapor service * Light-liquid service * Heavy-liquid serviceAdministrative and ReportsPlanning and TrainingTOTALS

Baseline Monitoring

Type of Component

Model 4

Valves * Gas/vapor service * Light-liquid service * Heavy-liquid serviceAdministrative and ReportsPlanning and TrainingTOTALS

Percent

Repaired

OnLine

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

OnLine Leak 

Repair Cost 

($/yr)

Percent

Requiring

Further

Repair

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

Offline Leak 

Repair Cost 

($/yr)

Monitoring

to Verify 

Repair ($)

Annual

Admin.

Cost

($/yr)

Annual

Misc.

Charges

($/yr)

75 0.17 66.24 23.81 25 4.00 66.24 190.10 4.3075 0.17 66.24 82.04 25 4.00 66.24 655.04 14.83

0.00

105.85 845.14 19.14 0.00 0.00

Percent

Repaired

OnLine

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

OnLine Leak 

Repair Cost 

($/yr)

Percent

Requiring

Further

Repair

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

Offline Leak 

Repair Cost 

($/yr)

Monitoring

to Verify 

Repair ($)

Annual

Admin.

Cost

($/yr)

Annual

Misc.

Charges

($/yr)

75 0.17 66.24 14.74 25 4.00 66.24 117.69 2.6775 0.17 66.24 57.49 25 4.00 66.24 458.97 10.39

0.00

72.23 576.66 13.06 0.00 0.00

Valves Option 1 Attachment 5 - Page 45
Valve Option 1 Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) Initial Number of Leaks Subsequent Leak Frequency (%) Annual Number of Leaks

Model 5

Valves * Gas/vapor service 1,178 0.00 5325.99 2 1.50 3534.00 5.95 70.05 1.91 45.08 * Light-liquid service 2,428 0.00 11638.80 2 1.50 7284.00 6.30 153.07 1.97 95.66

 * Heavy-liquid service 1,719 0.00 0.00

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00TOTALS 16964.79 0.00 10818.00 0.00

Capital Costs ($) 16,964.79

Annualized Capital ($/yr) 2,409

Annual Expenses ($/yr) 21,519

Baseline Monitoring

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) Initial Number of Leaks Subsequent Leak Frequency (%) Annual Number of Leaks

Model 5

Valves * Gas/vapor service 1,178 0.00 1060.92 2 1.50 3534.00 1.18 13.95 1.18 27.91 * Light-liquid service 2,428 0.00 2548.19 2 1.50 7284.00 1.38 33.51 1.38 67.03 * Heavy-liquid service 1,719 0.00 0.00

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00

TOTALS 3609.11 0.00 10818.00 0.00

Monitoring Repair

Baseline Capital Costs ($) 3,609.11 3,609.11

Baseline Annualized Capital ($/yr) 512 512.49

Baseline Annual Expenses ($/yr) 18,036 10,960.40 7,075.83

INCREMENTAL COSTS OF VALVE OPTION 1

Incremental Capital Costs ($) 13,355.68

Annualized Capital ($/yr) 1,896.51

Incremental Annual Expenses ($/yr) 3,482.74

Valves Option 1 Attachment 5 - Page 46
Valve Option 1 Cost Estimates

Type of Component

Model 5

Valves * Gas/vapor service * Light-liquid service * Heavy-liquid serviceAdministrative and ReportsPlanning and TrainingTOTALS

Baseline Monitoring

Type of Component

Model 5

Valves * Gas/vapor service * Light-liquid service * Heavy-liquid serviceAdministrative and ReportsPlanning and TrainingTOTALS

Percent

Repaired

OnLine

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

OnLine Leak 

Repair Cost 

($/yr)

Percent

Requiring

Further

Repair

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

Offline Leak 

Repair Cost 

($/yr)

Monitoring

to Verify 

Repair ($)

Annual

Admin.

Cost

($/yr)

Annual

Misc.

Charges

($/yr)

75 0.17 66.24 373.97 25 4.00 66.24 2985.82 67.6175 0.17 66.24 793.64 25 4.00 66.24 6336.44 143.49

0.00

1167.61 9322.26 211.10 0.00 0.00

Percent

Repaired

OnLine

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

OnLine Leak 

Repair Cost 

($/yr)

Percent

Requiring

Further

Repair

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

Offline Leak 

Repair Cost 

($/yr)

Monitoring

to Verify 

Repair ($)

Annual

Admin.

Cost

($/yr)

Annual

Misc.

Charges

($/yr)

75 0.17 66.24 231.52 25 4.00 66.24 1848.46 41.8675 0.17 66.24 556.08 25 4.00 66.24 4439.77 100.54

0.00

787.60 6288.23 142.40 0.00 0.00

Valves Option 1 Attachment 5 - Page 47
Valve Option 1 Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) Initial Number of Leaks Subsequent Leak Frequency (%) Annual Number of Leaks

Model 6

Valves * Gas/vapor service 3,263 0.00 14752.72 2 1.50 9789.00 5.95 194.02 1.91 124.86

 * Light-liquid service 5,857 0.00 28075.98 2 1.50 17571.00 6.30 369.24 1.97 230.76

 * Heavy-liquid service 3,163 0.00 0.00

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00TOTALS 42828.70 0.00 27360.00 0.00

Capital Costs ($) 42,828.70

Annualized Capital ($/yr) 6,082

Annual Expenses ($/yr) 54,400

Baseline Monitoring

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) Initial Number of Leaks Subsequent Leak Frequency (%) Annual Number of Leaks

Model 5

Valves * Gas/vapor service 3,263 0.00 2938.69 2 1.50 9789.00 1.18 38.65 1.18 77.30 * Light-liquid service 5,857 0.00 6146.94 2 1.50 17571.00 1.38 80.84 1.38 161.68 * Heavy-liquid service 3,163 0.00 0.00

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00

TOTALS 9085.63 0.00 27360.00 0.00

Monitoring Repair

Baseline Capital Costs ($) 9,085.63 9,085.63

Baseline Annualized Capital ($/yr) 1,290 1,290.16

Baseline Annual Expenses ($/yr) 45,531 27,718.47 17,812.79

INCREMENTAL COSTS OF VALVE OPTION 1

Incremental Capital Costs ($) 33,743.07

Annualized Capital ($/yr) 4,791.52

Incremental Annual Expenses ($/yr) 8,868.30

Valves Option 1 Attachment 5 - Page 48
Valve Option 1 Cost Estimates

Type of Component

Model 6

Valves * Gas/vapor service * Light-liquid service * Heavy-liquid serviceAdministrative and ReportsPlanning and TrainingTOTALS

Baseline Monitoring

Type of Component

Model 5

Valves * Gas/vapor service * Light-liquid service * Heavy-liquid serviceAdministrative and ReportsPlanning and TrainingTOTALS

Percent

Repaired

OnLine

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

OnLine Leak 

Repair Cost 

($/yr)

Percent

Requiring

Further

Repair

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

Offline Leak 

Repair Cost 

($/yr)

Monitoring

to Verify 

Repair ($)

Annual

Admin.

Cost

($/yr)

Annual

Misc.

Charges

($/yr)

75 0.17 66.24 1035.89 25 4.00 66.24 8270.57 187.2975 0.17 66.24 1914.47 25 4.00 66.24 15285.22 346.13

0.00

2950.36 23555.79 533.42 0.00 0.00

Percent

Repaired

OnLine

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

OnLine Leak 

Repair Cost 

($/yr)

Percent

Requiring

Further

Repair

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

Offline Leak 

Repair Cost 

($/yr)

Monitoring

to Verify 

Repair ($)

Annual

Admin.

Cost

($/yr)

Annual

Misc.

Charges

($/yr)

75 0.17 66.24 641.30 25 4.00 66.24 5120.15 115.9575 0.17 66.24 1341.42 25 4.00 66.24 10709.93 242.53

0.00

1982.72 15830.08 358.47 0.00 0.00

Valves Option 1 Attachment 5 - Page 49
Valve Option 2 Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Total 'Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) Initial Number of Leaks Subsequent Leak Frequency (%) Annual Number of Leaks

Model 1 Valves

 * Gas/vapor service 77 0.00 1314.60 2 1.50 231.00 0.00 12.24 9.42 0.61 0.94 * Light-liquid service 380 0.00 4276.56 2 1.50 1140.00 0.00 8.07 30.65 0.61 4.64

 * Heavy-liquid service 0 0.00 0.00

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00TOTALS 5591.16 0.00 1371.00 0.00

Capital Costs ($) 5,591

Annualized Capital ($/yr) 794

Annual Expenses ($/yr) 2,150

INCREMENTAL COSTS OF VALVE OPTION 2

Incremental Capital Costs ($) 3,768

Annualized Capital ($/yr) 535

Incremental Annual Expenses ($/yr) 427

Valves Option 2 Attachment 5 - Page 50
Valve Option 2 Cost Estimates

Type of Component

Model 1 Valves

 * Gas/vapor service * Light-liquid service * Heavy-liquid serviceAdministrative and ReportsPlanning and TrainingTOTALS

Percent

Repaired

OnLine

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

OnLine Leak 

Repair Cost 

($/yr)

Percent

Requiring

Further

Repair

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

Offline Leak 

Repair Cost 

($/yr)

Monitoring

to Verify 

Repair ($)

Annual

Admin.

Cost

($/yr)

Annual

Misc.

Charges

($/yr)

50 0.17 66.24 5.20 50 4.00 66.24 124.63 1.4150 0.17 66.24 25.68 50 4.00 66.24 615.07 6.96

0.00

30.88 739.70 8.38 0.00 0.00

Valves Option 2 Attachment 5 - Page 51
Valve Option 2 Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Total 'Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) Initial Number of Leaks Subsequent Leak Frequency (%) Annual Number of Leaks

Model 2 Valves

 * Gas/vapor service 414 0.00 7068.10 2 1.50 1242.00 0.00 12.24 50.66 0.61 5.06

 * Light-liquid service 1,179 0.00 13268.59 2 1.50 3537.00 0.00 8.07 95.11 0.61 14.40 * Heavy-liquid service 71 0.00 0.00

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00TOTALS 20336.69 0.00 4779.00 0.00

Capital Costs ($) 20,337

Annualized Capital ($/yr) 2,888

Annual Expenses ($/yr) 7,494

INCREMENTAL COSTS OF VALVE OPTION 2

Incremental Capital Costs ($) 13,716

Annualized Capital ($/yr) 1,948

Incremental Annual Expenses ($/yr) 1,490

Valves Option 2 Attachment 5 - Page 52
Valve Option 2 Cost Estimates

Type of Component

Model 2 Valves

 * Gas/vapor service * Light-liquid service * Heavy-liquid serviceAdministrative and ReportsPlanning and TrainingTOTALS

Percent

Repaired

OnLine

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

OnLine Leak 

Repair Cost 

($/yr)

Percent

Requiring

Further

Repair

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

Offline Leak 

Repair Cost 

($/yr)

Monitoring

to Verify 

Repair ($)

Annual

Admin.

Cost

($/yr)

Annual

Misc.

Charges

($/yr)

50 0.17 66.24 27.98 50 4.00 66.24 670.10 7.5950 0.17 66.24 79.67 50 4.00 66.24 1908.33 21.61

0.00

107.65 2578.43 29.19 0.00 0.00

Valves Option 2 Attachment 5 - Page 53
Valve Option 2 Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Total 'Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) Initial Number of Leaks Subsequent Leak Frequency (%) Annual Number of Leaks

Model 3 Valves

 * Gas/vapor service 1,379 0.00 23543.27 2 1.50 4137.00 0.00 12.24 168.76 0.61 16.85

 * Light-liquid service 1,980 0.00 22283.13 2 1.50 5940.00 0.00 8.07 159.72 0.61 24.19 * Heavy-liquid service 1,272 0.00 0.00

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00TOTALS 45826.40 0.00 10077.00 0.00

Capital Costs ($) 45,826

Annualized Capital ($/yr) 6,507

Annual Expenses ($/yr) 15,802

INCREMENTAL COSTS OF VALVE OPTION 2

Incremental Capital Costs ($) 30,944

Annualized Capital ($/yr) 4,394

Incremental Annual Expenses ($/yr) 3,142

Valves Option 2 Attachment 5 - Page 54
Valve Option 2 Cost Estimates

Type of Component

Model 3 Valves

 * Gas/vapor service * Light-liquid service * Heavy-liquid serviceAdministrative and ReportsPlanning and TrainingTOTALS

Percent

Repaired

OnLine

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

OnLine Leak 

Repair Cost 

($/yr)

Percent

Requiring

Further

Repair

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

Offline Leak 

Repair Cost 

($/yr)

Monitoring

to Verify 

Repair ($)

Annual

Admin.

Cost

($/yr)

Annual

Misc.

Charges

($/yr)

50 0.17 66.24 93.19 50 4.00 66.24 2232.05 25.2750 0.17 66.24 133.80 50 4.00 66.24 3204.83 36.29

0.00

226.99 5436.89 61.56 0.00 0.00

Valves Option 2 Attachment 5 - Page 55
Valve Option 2 Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Total 'Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) Initial Number of Leaks Subsequent Leak Frequency (%) Annual Number of Leaks

Model 4 Valves

 * Gas/vapor service 75 0.00 1540.77 4 1.50 450.00 0.00 14.73 11.04 1.28 3.83 * Light-liquid service 251 0.00 5300.33 4 1.50 1506.00 0.00 15.14 37.99 1.17 11.77

 * Heavy-liquid service 216 0.00 0.00

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00TOTALS 6841.09 0.00 1956.00 0.00

Capital Costs ($) 6,841

Annualized Capital ($/yr) 971

Annual Expenses ($/yr) 4,132

INCREMENTAL COSTS OF VALVE OPTION 2

Incremental Capital Costs ($) 5,299

Annualized Capital ($/yr) 752

Incremental Annual Expenses ($/yr) 2,184

Valves Option 2 Attachment 5 - Page 56
Valve Option 2 Cost Estimates

Type of Component

Model 4 Valves

 * Gas/vapor service * Light-liquid service * Heavy-liquid serviceAdministrative and ReportsPlanning and TrainingTOTALS

Percent

Repaired

OnLine

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

OnLine Leak 

Repair Cost 

($/yr)

Percent

Requiring

Further

Repair

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

Offline Leak 

Repair Cost 

($/yr)

Monitoring

to Verify 

Repair ($)

Annual

Admin.

Cost

($/yr)

Annual

Misc.

Charges

($/yr)

50 0.17 66.24 21.18 50 4.00 66.24 507.42 5.7550 0.17 66.24 65.10 50 4.00 66.24 1559.35 17.66

0.00

86.29 2066.77 23.40 0.00 0.00

Valves Option 2 Attachment 5 - Page 57
Valve Option 2 Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Total 'Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) Initial Number of Leaks Subsequent Leak Frequency (%) Annual Number of Leaks

Model 5 Valves

 * Gas/vapor service 1,178 0.00 24200.33 4 1.50 7068.00 0.00 14.73 173.47 1.28 60.16

 * Light-liquid service 2,428 0.00 51271.68 4 1.50 14568.00 0.00 15.14 367.51 1.17 113.86 * Heavy-liquid service 1,719 0.00 0.00

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00TOTALS 75472.01 0.00 21636.00 0.00

Capital Costs ($) 75,472

Annualized Capital ($/yr) 7,281

Annual Expenses ($/yr) 45,913

INCREMENTAL COSTS OF VALVE OPTION 2

Incremental Capital Costs ($) 58,507

Annualized Capital ($/yr) 4,872

Incremental Annual Expenses ($/yr) 24,394

Valves Option 2 Attachment 5 - Page 58
Valve Option 2 Cost Estimates

Type of Component

Model 5 Valves

 * Gas/vapor service * Light-liquid service * Heavy-liquid serviceAdministrative and ReportsPlanning and TrainingTOTALS

Percent

Repaired

OnLine

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

OnLine Leak 

Repair Cost 

($/yr)

Percent

Requiring

Further

Repair

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

Offline Leak 

Repair Cost 

($/yr)

Monitoring

to Verify 

Repair ($)

Annual

Admin.

Cost

($/yr)

Annual

Misc.

Charges

($/yr)

50 0.17 66.24 332.74 50 4.00 66.24 7969.83 90.2450 0.17 66.24 629.76 50 4.00 66.24 15084.11 170.79

0.00

962.50 23053.93 261.03 0.00 0.00

Valves Option 2 Attachment 5 - Page 59
Valve Option 2 Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Total 'Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) Initial Number of Leaks Subsequent Leak Frequency (%) Annual Number of Leaks

Model 6 Valves

 * Gas/vapor service 3,263 0.00 67033.69 4 1.50 19578.00 0.00 14.73 480.49 1.28 166.64

 * Light-liquid service 5,857 0.00 123681.32 4 1.50 35142.00 0.00 15.14 886.53 1.17 274.66

 * Heavy-liquid service 3,163 0.00 0.00

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00TOTALS 190715.01 0.00 54720.00 0.00

Capital Costs ($) 190,715

Annualized Capital ($/yr) 27,082

Annual Expenses ($/yr) 116,286

INCREMENTAL COSTS OF VALVE OPTION 2

Incremental Capital Costs ($) 147,886

Annualized Capital ($/yr) 21,000

Incremental Annual Expenses ($/yr) 61,886

Valves Option 2 Attachment 5 - Page 60
Valve Option 2 Cost Estimates

Type of Component

Model 6 Valves

 * Gas/vapor service * Light-liquid service * Heavy-liquid serviceAdministrative and ReportsPlanning and TrainingTOTALS

Percent

Repaired

OnLine

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

OnLine Leak 

Repair Cost 

($/yr)

Percent

Requiring

Further

Repair

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

Offline Leak 

Repair Cost 

($/yr)

Monitoring

to Verify 

Repair ($)

Annual

Admin.

Cost

($/yr)

Annual

Misc.

Charges

($/yr)

50 0.17 66.24 921.67 50 4.00 66.24 22076.02 249.9550 0.17 66.24 1519.16 50 4.00 66.24 36386.99 411.99

0.00

2440.83 58463.01 661.95 0.00 0.00

Valves Option 2 Attachment 5 - Page 61
Connectors Option 1 Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) Initial Number of Leaks Subsequent Leak Frequency (%) Annual Number of Leaks

Model 1

Connectors * Flanges - gas/vapor 0 23.80 0.00 0.25 2.50 0.00 0.36 0.00 0.36 0.00

 * Flanges - light liquid 731 23.80 17514.06 0.25 2.50 456.88 0.36 2.63 0.36 0.66 * Flanges -heavy liquid 0 0.00 0.00

hr/activity $/hr

Administrative and Reports 50 92.72Planning and Training 20 92.72 1854.40TOTALS 17514.06 1854.40 456.88 0.00

INCREMENTAL COSTS OF CONNECTORS OPTION 1

Incremental Capital Costs ($) 19,368

Annualized Capital ($/yr) 2,750

Incremental Annual Expenses ($/yr) 5,122

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) Initial Number of Leaks Subsequent Leak Frequency (%) Annual Number of Leaks

Model 2

Connectors * Flanges - gas/vapor 0 23.80 0.00 0.25 2.50 0.00 0.36 0.00 0.36 0.00

 * Flanges - light liquid 2,662 23.80 63778.96 0.25 2.50 1663.75 0.36 9.58 0.36 2.40

 * Flanges -heavy liquid 0 0.00 0.00

hr/activity $/hr

Administrative and Reports 50 92.72

Planning and Training 20 92.72 1854.40TOTALS 63778.96 1854.40 1663.75 0.00

INCREMENTAL COSTS OF CONNECTORS OPTION 1

Incremental Capital Costs ($) 65,633

Annualized Capital ($/yr) 9,320

Incremental Annual Expenses ($/yr) 6,405

Connectors Option 1 Attachment 5 - Page 62
Connectors Option 1 Cost Estimates

Type of Component

Model 1

Connectors * Flanges - gas/vapor * Flanges - light liquid * Flanges -heavy liquidAdministrative and ReportsPlanning and TrainingTOTALS

Type of Component

Model 2

Connectors * Flanges - gas/vapor * Flanges - light liquid * Flanges -heavy liquidAdministrative and ReportsPlanning and TrainingTOTALS

Percent

Repaired

OnLine

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

OnLine Leak 

Repair Cost 

($/yr)

Percent

Requiring

Further

Repair

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

Offline Leak 

Repair Cost 

($/yr)

Monitoring

to Verify 

Repair ($)

Annual

Admin.

Cost

($/yr)

Annual

Misc.

Charges

($/yr)

75 0.17 66.24 0.00 25 2.00 66.24 0.00 0.0075 0.17 66.24 5.46 25 2.00 66.24 21.79 1.64

4636.00

5.46 21.79 1.64 4636.00 0.00

Percent

Repaired

OnLine

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

OnLine Leak 

Repair Cost 

($/yr)

Percent

Requiring

Further

Repair

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

Offline Leak 

Repair Cost 

($/yr)

Monitoring

to Verify 

Repair ($)

Annual

Admin.

Cost

($/yr)

Annual

Misc.

Charges

($/yr)

75 0.17 66.24 0.00 25 2.00 66.24 0.00 0.0075 0.17 66.24 19.88 25 2.00 66.24 79.35 5.99

4636.00

19.88 79.35 5.99 4636.00 0.00

Connectors Option 1 Attachment 5 - Page 63
Connectors Option 1 Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) Initial Number of Leaks Subsequent Leak Frequency (%) Annual Number of Leaks

Model 3

Connectors * Flanges - gas/vapor 0 23.80 0.00 0.25 2.50 0.00 0.36 0.00 0.36 0.00

 * Flanges - light liquid 7,410 23.80 177536.48 0.25 2.50 4631.25 0.36 26.68 0.36 6.67 * Flanges -heavy liquid 0 0.00 0.00

hr/activity $/hr

Administrative and Reports 50 92.72Planning and Training 20 92.72 1854.40TOTALS 177536.48 1854.40 4631.25 0.00

INCREMENTAL COSTS OF CONNECTORS OPTION 1

Incremental Capital Costs ($) 179,391

Annualized Capital ($/yr) 25,474

Incremental Annual Expenses ($/yr) 9,560

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) Initial Number of Leaks Subsequent Leak Frequency (%) Annual Number of Leaks

Model 4

Connectors * Flanges - gas/vapor 164 23.80 4023.60 0.25 2.50 102.50 1.70 2.79 0.81 0.33

 * Flanges - light liquid 555 23.80 13616.44 0.25 2.50 346.88 1.70 9.44 0.81 1.13 * Flanges -heavy liquid 454 0.00 0.00

hr/activity $/hr

Administrative and Reports 50 92.72Planning and Training 20 92.72 1854.40TOTALS 17640.03 1854.40 449.38 0.00

INCREMENTAL COSTS OF CONNECTORS OPTION 1

Incremental Capital Costs ($) 19,494

Annualized Capital ($/yr) 2,768

Incremental Annual Expenses ($/yr) 5,150

Connectors Option 1 Attachment 5 - Page 64
Connectors Option 1 Cost Estimates

Type of Component

Model 3

Connectors * Flanges - gas/vapor * Flanges - light liquid * Flanges -heavy liquidAdministrative and ReportsPlanning and TrainingTOTALS

Type of Component

Model 4

Connectors * Flanges - gas/vapor * Flanges - light liquid * Flanges -heavy liquidAdministrative and ReportsPlanning and TrainingTOTALS

Percent

Repaired

OnLine

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

OnLine Leak 

Repair Cost 

($/yr)

Percent

Requiring

Further

Repair

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

Offline Leak 

Repair Cost 

($/yr)

Monitoring

to Verify 

Repair ($)

Annual

Admin.

Cost

($/yr)

Annual

Misc.

Charges

($/yr)

75 0.17 66.24 0.00 25 2.00 66.24 0.00 0.0075 0.17 66.24 55.33 25 2.00 66.24 220.88 16.67

4636.00

55.33 220.88 16.67 4636.00 0.00

Percent

Repaired

OnLine

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

OnLine Leak 

Repair Cost 

($/yr)

Percent

Requiring

Further

Repair

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

Offline Leak 

Repair Cost 

($/yr)

Monitoring

to Verify 

Repair ($)

Annual

Admin.

Cost

($/yr)

Annual

Misc.

Charges

($/yr)

75 0.17 66.24 2.77 25 2.00 66.24 11.05 0.8375 0.17 66.24 9.37 25 2.00 66.24 37.39 2.82

4636.00

12.13 48.44 3.66 4636.00 0.00

Connectors Option 1 Attachment 5 - Page 65
Connectors Option 1 Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) Initial Number of Leaks Subsequent Leak Frequency (%) Annual Number of Leaks

Model 5

Connectors * Flanges - gas/vapor 2,333 23.80 57238.10 0.25 2.50 1458.13 1.70 39.66 0.81 4.75 * Flanges - light liquid 4,644 23.80 113936.46 0.25 2.50 2902.50 1.70 78.95 0.81 9.45 * Flanges -heavy liquid 4,186 0.00 0.00

hr/activity $/hr

Administrative and Reports 50 92.72Planning and Training 20 92.72 1854.40TOTALS 171174.56 1854.40 4360.63 0.00

INCREMENTAL COSTS OF CONNECTORS OPTION 1

Incremental Capital Costs ($) 173,029

Annualized Capital ($/yr) 24,570

Incremental Annual Expenses ($/yr) 9,620

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) Initial Number of Leaks Subsequent Leak Frequency (%) Annual Number of Leaks

Model 6

Connectors * Flanges - gas/vapor 7,641 23.80 187465.22 0.25 2.50 4775.63 1.70 129.90 0.81 15.54 * Flanges - light liquid 13,379 23.80 328242.00 0.25 2.50 8361.88 1.70 227.44 0.81 27.21 * Flanges -heavy liquid 7,725 0.00 0.00

hr/activity $/hr

Administrative and Reports 50 92.72Planning and Training 20 92.72 1854.40TOTALS 515707.22 1854.40 13137.50 0.00

INCREMENTAL COSTS OF CONNECTORS OPTION 1

Incremental Capital Costs ($) 517,562

Annualized Capital ($/yr) 73,494

Incremental Annual Expenses ($/yr) 19,651

Connectors Option 1 Attachment 5 - Page 66
Connectors Option 1 Cost Estimates

Type of Component

Model 5

Connectors * Flanges - gas/vapor * Flanges - light liquid * Flanges -heavy liquidAdministrative and ReportsPlanning and TrainingTOTALS

Type of Component

Model 6

Connectors * Flanges - gas/vapor * Flanges - light liquid * Flanges -heavy liquidAdministrative and ReportsPlanning and TrainingTOTALS

Percent

Repaired

OnLine

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

OnLine Leak 

Repair Cost 

($/yr)

Percent

Requiring

Further

Repair

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

Offline Leak 

Repair Cost 

($/yr)

Monitoring

to Verify 

Repair ($)

Annual

Admin.

Cost

($/yr)

Annual

Misc.

Charges

($/yr)

75 0.17 66.24 39.37 25 2.00 66.24 157.17 11.8675 0.17 66.24 78.37 25 2.00 66.24 312.85 23.61

4636.00

117.74 470.01 35.48 4636.00 0.00

Percent

Repaired

OnLine

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

OnLine Leak 

Repair Cost 

($/yr)

Percent

Requiring

Further

Repair

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

Offline Leak 

Repair Cost 

($/yr)

Monitoring

to Verify 

Repair ($)

Annual

Admin.

Cost

($/yr)

Annual

Misc.

Charges

($/yr)

75 0.17 66.24 128.94 25 2.00 66.24 514.74 38.8575 0.17 66.24 225.77 25 2.00 66.24 901.29 68.03

4636.00

354.72 1416.04 106.89 4636.00 0.00

Connectors Option 1 Attachment 5 - Page 67
OEL Monitoring Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) Initial Number of Leaks Subsequent Leak Frequency (%) Annual Number of Leaks

Model 1

OEL 140.92 0.00 5.00 0.00

Annual monitoring 33 23.80 808.13 1 1.50 49.50 0.90 0.30 0.45 0.15

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00TOTALS 808.13 0.00 49.50 0.00

Incremental Capital Costs ($) 808.13

Annualized Capital ($/yr) 114.75

Incremental Annual Expenses ($/yr) 60.79

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) Initial Number of Leaks Subsequent Leak Frequency (%) Annual Number of Leaks

Model 2

OEL 140.92 0.00 5.00 0.00

Annual monitoring 141 23.80 3452.93 1 1.50 211.50 0.90 1.27 0.45 0.63

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00TOTALS 3452.93 0.00 211.50 0.00

Incremental Capital Costs ($) 3,453

Annualized Capital ($/yr) 490

Incremental Annual Expenses ($/yr) 260

OEL Monitoring Attachment 5 - Page 68
OEL Monitoring Cost Estimates

Type of Component

Model 1

OEL

Annual monitoring

Administrative and ReportsPlanning and TrainingTOTALS

Type of Component

Model 2

OEL

Annual monitoring

Administrative and ReportsPlanning and TrainingTOTALS

Percent

Repaired

OnLine

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

OnLine Leak 

Repair Cost 

($/yr)

Percent

Requiring

Further

Repair

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

Offline Leak 

Repair Cost 

($/yr)

Monitoring

to Verify 

Repair ($)

Annual

Admin.

Cost

($/yr)

Annual

Misc.

Charges

($/yr)

0.00

75 0.17 66.24 1.23 25 4.00 66.24 9.84 0.22

0.00

1.23 9.84 0.22 0.00 0.00

Percent

Repaired

OnLine

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

OnLine Leak 

Repair Cost 

($/yr)

Percent

Requiring

Further

Repair

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

Offline Leak 

Repair Cost 

($/yr)

Monitoring

to Verify 

Repair ($)

Annual

Admin.

Cost

($/yr)

Annual

Misc.

Charges

($/yr)

0.00

75 0.17 66.24 5.26 25 4.00 66.24 42.03 0.95

0.00

5.26 42.03 0.95 0.00 0.00

OEL Monitoring Attachment 5 - Page 69
OEL Monitoring Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) Initial Number of Leaks Subsequent Leak Frequency (%) Annual Number of Leaks

Model 3

OEL 140.92 0.00 5.00 0.00

Annual monitoring 424 23.80 10383.28 1 1.50 636.00 0.90 3.82 0.45 1.91

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00TOTALS 10383.28 0.00 636.00 0.00

Incremental Capital Costs ($) 10,383

Annualized Capital ($/yr) 1,474

Incremental Annual Expenses ($/yr) 781

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) Initial Number of Leaks Subsequent Leak Frequency (%) Annual Number of Leaks

Model 4

OEL 140.92 0.00 5.00 0.00

Annual monitoring 39 23.80 996.58 1 1.50 58.50 2.30 0.90 1.15 0.45

hr/activity $/hr

Administrative and Reports 0 92.72 0.00

Planning and Training 0 92.72 0.00TOTALS 996.58 0.00 58.50 0.00

Incremental Capital Costs ($) 997

Annualized Capital ($/yr) 142

Incremental Annual Expenses ($/yr) 93

OEL Monitoring Attachment 5 - Page 70
OEL Monitoring Cost Estimates

Type of Component

Model 3

OEL

Annual monitoring

Administrative and ReportsPlanning and TrainingTOTALS

Type of Component

Model 4

OEL

Annual monitoring

Administrative and ReportsPlanning and TrainingTOTALS

Percent

Repaired

OnLine

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

OnLine Leak 

Repair Cost 

($/yr)

Percent

Requiring

Further

Repair

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

Offline Leak 

Repair Cost 

($/yr)

Monitoring

to Verify 

Repair ($)

Annual

Admin.

Cost

($/yr)

Annual

Misc.

Charges

($/yr)

0.00

75 0.17 66.24 15.83 25 4.00 66.24 126.39 2.86

0.00

15.83 126.39 2.86 0.00 0.00

Percent

Repaired

OnLine

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

OnLine Leak 

Repair Cost 

($/yr)

Percent

Requiring

Further

Repair

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

Offline Leak 

Repair Cost 

($/yr)

Monitoring

to Verify 

Repair ($)

Annual

Admin.

Cost

($/yr)

Annual

Misc.

Charges

($/yr)

0.00

75 0.17 66.24 3.72 25 4.00 66.24 29.71 0.67

0.00

3.72 29.71 0.67 0.00 0.00

OEL Monitoring Attachment 5 - Page 71
OEL Monitoring Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) Initial Number of Leaks Subsequent Leak Frequency (%) Annual Number of Leaks

Model 5

OEL 140.92 0.00 5.00 0.00

238 23.80 6081.70 1 1.50 357.00 2.30 5.47 1.15 2.74

hr/activity $/hr

Administrative and Reports 0 92.72 0.00

Planning and Training 0 92.72 0.00TOTALS 6081.70 0.00 357.00 0.00

Incremental Capital Costs ($) 6,082

Annualized Capital ($/yr) 864

Incremental Annual Expenses ($/yr) 565

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) Initial Number of Leaks Subsequent Leak Frequency (%) Annual Number of Leaks

Model 6

OEL 140.92 0.00 5.00 0.00

902 23.80 23049.15 1 1.50 1353.00 2.30 20.75 1.15 10.37

hr/activity $/hr

Administrative and Reports 0 92.72 0.00

Planning and Training 0 92.72 0.00TOTALS 23049.15 0.00 1353.00 0.00

Incremental Capital Costs ($) 23,049

Annualized Capital ($/yr) 3,273

Incremental Annual Expenses ($/yr) 2,142

OEL Monitoring Attachment 5 - Page 72
OEL Monitoring Cost Estimates

Type of Component

Model 5

OELAdministrative and ReportsPlanning and TrainingTOTALS

Type of Component

Model 6

OELAdministrative and ReportsPlanning and TrainingTOTALS

Percent

Repaired

OnLine

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

OnLine Leak 

Repair Cost 

($/yr)

Percent

Requiring

Further

Repair

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

Offline Leak 

Repair Cost 

($/yr)

Monitoring

to Verify 

Repair ($)

Annual

Admin.

Cost

($/yr)

Annual

Misc.

Charges

($/yr)

0.00

75 0.17 66.24 22.71 25 4.00 66.24 181.30 4.11

0.00

22.71 181.30 4.11 0.00 0.00

Percent

Repaired

OnLine

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

OnLine Leak 

Repair Cost 

($/yr)

Percent

Requiring

Further

Repair

Repair

Time

(hours)

Labor

Charge

($/hr)

Annual

Offline Leak 

Repair Cost 

($/yr)

Monitoring

to Verify 

Repair ($)

Annual

Admin.

Cost

($/yr)

Annual

Misc.

Charges

($/yr)

0.00

75 0.17 66.24 86.06 25 4.00 66.24 687.11 15.56

0.00

86.06 687.11 15.56 0.00 0.00

OEL Monitoring Attachment 5 - Page 73