RADIAN

CORPORATION ~~ECEIVED A-90-20

11-8-6

MEMORANDUM

DATE:

TO:

February 28,

David Markwardt, EPA

FROM: K. J. Hausle and D. J. Whitt, Radian Corporatio~

SUBJECT: Final Cost Impacts Analysis for HaN Equipment Leaks

The purpose of this memorandum is to present the revised

estimated cost impacts analysis associated with the regUlatory

support work 'for the equipment leaks Hazardous Organic NESHAP

(HaN). The analysis presented here replaces the information in

all previous cost impacts memoranda. The six model units A-F

used here refer to the model units developed for the regulatory

impact analysis (see Hohenstein memorandum, "Revised 'Reg Neg'

Controlled Model Unit Emissions from Equipment Leaks,"

March 29, 1991). Model units A, Sf and C are uncontrolled at

baseline and have low, medium, and high equipment counts,

respectively. Model units 0, E, and F are controlled at baseline

and also have low, medium, and high equipment counts,

respectively.

The analysis presented here is based on the control

requirements specified in the equipment leaks negotiated

regUlation (Reg Neg).l The Reg Neg 1 requires quarterly valve

monitoring for units demonstrating leak frequencies below

2 percent. Units with valve leak frequencies of 2 percent or

greater must monitor on a monthly basis. The cost impacts

analysis presented here includes separate cost estimates for both

of these monitoring scenarios. The analysis indicates that

implementation of the controls will result in an annual savings

for all six model units, if valves are monitored quarterly. For

monthly valve monitoring, the analysis indicates an annual

savings for model units A, S, and C, and an annual expense for

model units 0, E, and F. The cost effectiveness ranges from a

savings of $1,060/Mg HAP for model unit C with quarterly valve

monitoring to a cost of $J90/Mg HAP for model unit 0 with monthly

valve monitoring.
Cost Basis

To determine the cost impacts associated with implementation

of Reg Neg 1 Controls for the HON for equipment leaks, the first

step was to determine a base cost for each type of equipment

regulated. These base costs are used in all subsequent

calculations in this analysis. The types of regulated equipment

are:

c'

, '., ...--

service.

1 Reg Neg

all other

. . Pumps, valves, connectors, and agitators in heavy liquid ~.;~. \ I (· __ r

service, instrumentation systems, and pressure relief devices in,~"

liquid service are also covered by the standard. For these

components, the standard requires that the leaking component be

monitored with an organic vapor detection instrument within five

(1) Valves in gas/vapor and light liquid service,

(2) Pump seals in light liquid service,

(J) Connectors in gas/vapor and light liquid service,

(4) Compressor seals,

(5) Pressure relief seals in gas/vapor service,

~6) Open-ended lines,

(7) Product accumulators,

(8) Sample connections, and

(9) Agitator seals in gas/vapor and light liquid

For pumps, valves, agitators, and connectors, the

requires routine leak detection and repair (LDAR). For

types of equipment, the Reg Neg 1 calls for equipment

modifications. The base costs for each type of equipment are

presented in Table 1. These base costs were developed from

several sources of information including vendor quotes, costing

manuals, and previous documentation on control of equipment

leaks. One of the primary sources of information used was the

Fugitive Emission Sources of Organic Compounds - Additi?6al

Information on Emissions, Emission Reductions, and cost(s,. . This

document is referred to as the Fugitives Emissions AID. The

approach for developing the base costs and the sources of

information used are discussed below.

costs.mum 2
TABLE 1. BASE COST DATA

Cost

Equipment Type Phase Ilem (July '89 dollars) Basis

Monitoring Moniloring Instrument 6.500 linstr. Que-te of $6,500/inSIl.

Valves

GasNapor LDAR 2 Icom;Jllest Vendor inlormation (t989)

Light Liquid LDAR 2 Icompllest Vendor information (1989)

Heavy Liquid None

Pump Seals

light Liquid LDAR 2 Icomp/lest Vendor information (1989) \ ./

Replacement Seats 180 Iseal Update Irom AID S113/seal _;1.

with 50% credit lor old seal

CE IndeK (356/224.7)

Heavy Liquid None

ConnectOrs

All LDAR 2 Icompllest Vendor inlormation (1989)

Compressor Seals

GasNapor Closed Vent System

lor Degassing Reservoirs

- 122 m 015.1 em

schedule 40 sleel

pipe 1,090 $261.03/10011. (Richardson)

CE IndelC(356.0/342.5)

- Installation (66 hrs) 1,490 16.6 hrs.ll00 II, (Richardson)

- throe 5.1 em cast

sloel plug valves 2,440 S783.75/valve (Richardson) ,

, CE IndelC(356.0/342.5} ,(

- Installation (6 hrs) 135 2 hrs.lvalve (Richardson)

- ono motal gauze

lIame arrestor 862 Vendor quote 01 S869.00

CE IndeK(356.0/358.7}

-Installation (10 hrs) 225 Labor $22.50Ihr

TOTAL: 6.242

Pressure Reliel Seals

All (new) Rupture Disk Assembly

- one 7.6 em stainless

steel rupture disk 78 Vendor quote 01 $235/3-pak

- one 7.6 em carbon CE Index(356.0/358.7)

steel rupture disk

holder 579 10/90 quote 01 S583/holder

)
TABLE 1. (Continued)

Cost

Equipment Type Phase lIem (July '89 dollars) Basis

- one 0.6 COl pressure CE IndOK(356.0/358.7)

gauge, diallaco 24 UpdalO Irom SOCMI NSPS AID

- one 0.6 cm blood CE IndelC(356.0/224.7)

valvo, carbon slool .10 Updato Irom SOCMI NSPS AID

CE IndoK(356.0/224.7)

- Installalion (16tus) 360 Labor S22.50/1lr

- one 7.6 cm gale val'/o 401 S385.60/valve (Richardson)

CE IndolC(356.0/342.5)

- Inslallation (1.5tns) 34 1.5 hrs.tvalvo (Richardson)

- Ollsot; ono 10.2 crn i

too and ono 10.2 COl .,-!

olbow 49 $35.631teo. S11.731elbow

(Richardson)

CE Indox{356.0/342.5)

- Installation (8.5 hrs) 191 5.7 hrs.ltoo. 2.8 hrs.lolbow

TOTAL: 1.755 (Richardson)

All (rotrolil) Cosls aro the same as lor

a new assembly plus a now

reliol valve.

- ono 7.6 ern slainless

sloel body and trim

reliul valvo 1.950 Updalo Irom SOCMI NSPS AID

CE Indox{356.0/224.7)

- Inslallation (10 hrs) 225 Labor S22.501hr

TOTAL: 3.930

~---

Open-Endod Lines

All one 2.5 em galo valvo 70 S67.50/valvo (Richardson)

CE IndolC(356.0/342.5) ,..;;

- Installalion (1.4 hr) 31 1.4 lus./valvo (Richardson) \

~1-

TOTAL: 102 )

- Sample Connection

All Closed Purgo SySlom

- 6 ma12.5 em

schedule 40 slool .---

pipo 25 S120.64/100 n. (Richardson)

. \,

CE Indox(356.0/342.5)

-Installation (1 hr) 23 12.6 hrs./100 11. (Richardson)

- throo 2.5 em ball ...:'.......

valvos, carbon 610el 267 S85.60/volvo (Richardson) '-l

CE Index(356.01342.5)

- Inslallation (4.2 hrs) 95 1.4 hrs.lvolvo (Richardson) ~/I.-1 TOTAL: 409

4
days of finding evidence of a leak by visual, aUdible, olfactory,

or any ~ther detection method. However, these components neednot

be monitored if, within five days of detection, the visual,

audible, olfactory, or otherwise detected evidence of a leak is

eliminated by best repair practices. since these components are

not required to undergo regular monitoring or increased

maintenance by the standard, they are not included in this

analysis.

Information on the costs of control equipment, the

controlled and uncontrolled emission rates, and the leak

frequencies, for agitators are not available. All of these

factors affect the final cost of control. Therefore, agitators

have not been included in this cost impacts analysis.

The equipment specification for product accumulators

requires a closed-vent system which is connected to an additional

control device (e.g., flare) or vapor recovery header. Some

product accumulator vents, such as distillate receiver vents, are

covered by the broad definition of process vents. As with

agitators, there is limited available information on product

accumulators, and therefore, product accumulator vessels are not

included in this cost analysis.

It was assumed that each process unit would be required to

purchase one portable organic vapor analyzer monitoring device.

This device would be required either for occasional use by a

unit-employed monitoring team, or as a back-up unit for use by a

sub-contracted monitoring team, should the subcontractor's

instrument fail during a monitoring visit. The cost of this

analyzer was determined to be $6,500 per unit based on price

quotes from vendors. J

The base costs for pumps include the cost of replacement

seals and monitoring and repair labor associated with the LDAR

program. The cost for replacement pump seals was estimated to be

$180 per seal. This cost was adjusted from final quarter 1978

dollars to July, 1989 dollars using the cost in the Fugitives

Emissions

AI04 and the Chemical Engineering (CE) plant cost index ratio of

(356.0/224.7). This ratio is the final July 1989 CE plant cost

CO$~s.mem 5
index (356.0)5 divided by the average of the final 1978 October,

November, and December plant cost indexes (224.7) .6,7,6

The base costs for valves are only those for monitoring and

repair labor associated with the LDAR program. Replacement seals

for valves are not included here because they are typically low

cost items, and are considered to be covered by routine

maintenance costs for the unit.

The control equipment requirements for compressors, pressure

relief devices, open-ended lines, and sample connections were all

updated from component requirements specified in the Fugitives

Emissions AID. 2. The cost for these components was estimated by

using Richardson Process Plant Construction Estimation

Standards9 and by requesting current price quotes from vendors

. t t 10. 11 h' h d . t d on equ1pmen componen s. T ese pr1ces were t en a JUs e

to July, 1989 dollars. To update prices obtained from

Richardson's, a plant cost index of 342.5, which is the annual

cost index for 1988, was used. 5 To update price quotes from

vendors, a plant cost index of 358.7, which is the final cost

index for JUly of 1990, was used. 12 Quotes could not be .J

obtained for all equipment components. For retrofitted

replacement pressure relief valves, pressure gauges, and bleed

valves to be used with rupture disk assemblies, the costs used in

the Fugitives Emissions AID2were adjusted using the CE plant

cost index ratio of (356.0/224.7).

The labor-hour requirements for equipment installation for

retrofitted pressure relief valves, pressure gauges, bleed

valves, and flame arrestors, as shown in Table 1, were taken from

the Fugitives Emissions AID. 2 The labor-hour requirements for

piping and valves other than bleed valves and pressure relief

valves were estimated using Richardson Process Plant Construction

Estimation Standards. 9 The cost for installation labor was

13 14 estimated to be $22.50 per hour.' This labor cost was

estimated using the labor cost in Richardson's and updating it to

July 1989 dollars.

costs .mf!fn 6
capital Costs

The capital costs for bringing existing units up to the

level of control stated in the Reg Neg1were estimated using the

base costs discussed above and the model unit equipment counts.

Table 2 presents the capital costs for equipment for all six

model units. The costs for model units A, S, and C are higher

than for model units 0, E, and F, which are of the same

respective sizes. The costs are higher for units A, B, and C

because these units are defined as uncontrolled, and must

purchase a monitoring instrument. Units 0, E, and F are assumed

to already have a LOAR program in place, and therefore, already

have a monitoring instrument. All other capital costs are

equiv~lent for the uncontrolled and controlled model units.

Leak Detection and Repair Costs

The cost for maintaining a LOAR program is considered to be

an annual operating expense. This expense is a function of the

monitoring frequency, leak frequency, and labor cost. The costs

for operating an LDAR program are estimated to be $2.00 per

component per monitoring event based on monitorings performed by

a sub-contractor. 15 This cost was multiplied by the appropriate

equipment c~.. ..~"~..~_~..m;L.~..equired m~:mi!:9..r.ing .. -frequet:'lci.Qs for eactL___ _

-mo~to obtain the estimated annual costs. This monitoring~

cost includes labor costs for the use of a portable organic vapor \

detector and an initial repair attempt to be made by the \

monitoring team. It is assumed that if a process unit chose to I"

-~duct monitoring internally, and not bring in a subcontractor

for monitoring, the monitoring cost would be the same. __ -------- ....--.---------- The standard requires··-that--v-aTves"lh -gas/vap6Y'service and

valves in light liquid service be monitored quarterly if the

process unit has demonstrated through previous monitoring and

reporting that less than 2 percent of its valves are leaking.

The costs for this monitoring frequency are presented in

cost.s.mem 7
TABLE 2. CAPITAL COSTS FOR EQUIPMENT FOR EXISTING UNITS

Hodel Unit Identificationa

A B C o

Cost (5)

E F

Honitoring Instrument 6,500 Ob

Compressor Seal Vent

System

Rupture Disk Assemblies

-- Disks -- Holders, valves,

installation

Caps for open-ended

lines

Closed-purge sample

connections

TOTAL

6,500

OC

155

7,704

3,269

17,628

6,500

12,485

3,498

173,340

Od

14,311

210,125

49,940

5,909

292,753

43,312

398,413

155

7,704

3,269

11,128

12,485

3,498

173,340

14,301

203,625

49,940

5,909

292,753

43,312

391,913

aHodel units A, B, and C are simple, moderate, and complex, uncontrolled

units. Hodel units 0, E, and F are simple moderate, and complex units

controlled to the level specified in the SOCHI CTG (EPA-450/3-83-006).

bHodel units 0, E, and F have LDAR monitoring instruments.

cHodel units A and 0 do not have compressors, therefore, the cost for

compressor seal vent systems is $0.00.

d It is assumed that all model units already have installed caps on open-ended

lines.

': I ,-: 0..1.__

\ ;~ ,

. ,

co"t.s.mmn

r··~

'. '-c

'.'

"0 Yo c':,.c•.l.. '7 , ,

B

_ '. ~,

.>
Table 3A. The standard requires that valves be monitored

monthlyif, through previous monitoring and reporting, the process

unit has 2 percent or more of its valves leaking. The costs for

thismonitoring frequency are presented in Table 38. The valve

monitoring frequencies are the only differences between Tables 3A

and 3B. The Reg Neg 1 requires that process units with connectors

having leak frequencies of 0.5 percent or greater monitor once

annually. At connector leak frequencies less than 0.5 percent,

process units are allowed to monitor at less frequent intervals.

Since not all process units are expected to be below 0.5 percent

leaking, annual. monitorings with a 0.5 percent leak frequency

were assumed for connectors for this cost impacts analysis.

Pumps in light liquid service are to be monitored monthly.

Although pressure relief seals have an equipment standard, annual

monitorings are recommended to ensure compliance. Therefore,

annual monitoring of these sources is also included in these cost

estimates. No repair costs are included for pressure relief

valves, since the Reg Neg 1 specifies an equipment standard for

these sources.

Additional costs for the LDAR program will include the costs

for subsequent repair of all components that could not be

adequately repaired at the time of monitoring. The labor cost

for these subsequent repairs is estimated to be $22.50 per

13 hour. For valves, 25 percent of all leaks are estimated to

require further repair. 16 It was assumed that the same

percentage of connectors will require further repair. Any

pressure relief device leaks requiring subsequent repair are

assumed to be covered by routine maintenance costs.

The percentage of leaking pumps requiring further repair was

determined to be 75 percent. This was based on the Reg Neg1 rule

Phase III definition that all pumps with monitor readings over

1,000 ppmv are leaking, but that only pumps with readings over

2,000 ppmv must be repaired. Using the Ethylene Oxide and

Butadiene plant survey screening data, it was determined that

approximately 75 percent of the pumps leaking at levels greater

costs.m"", 9
/

/

than 1,000 ppmv were also leaking at levels greater than

17 2,000 ppmv.

The pump leak frequency of 10 percent was taken from the Reg

Neg las the maximum leak frequency allowed for Phase III without

requiring a Quality Improvement Program. For this analysis, it

was assumed that units would meet the performance standard of

less than 10 percent of their pumps leaking.

In Phase III, the negotiated rule also states that J pumps

may be leaking if this is greater than 10 percent of the total

number of pumps in the process unit. This clause would permit

simple process units to have more than 10 percent of the pumps

leaking at the time of anyone monitoring event without requiring

the implementation of a Quality Improvement Program. Since any

pumps determined to be leaking would still require repairs at a

monit'oring reading of 2,000 ppmv, this clause is not expected to

change the repair requirements for simple process units.

Therefore, a 10 percent leak frequency was used to estimate cost

impacts for these process units, and no cost differences are

expected or reflected in this cost analysis for model units A

and O.

In Tables 3A and 3B, monitoring costs and leak repair costs

(based on 22.50/hour of laborlJ) are presented for each equipment

type. At the bottom of each table, total monitoring and leak

repair costs are presented. Additionally, administrative and

support costs are presented. Administrative and support costs

are estimated as 40 percent of monitoring and leak repair costs. 2

Finally, total LOAR costs are presented.

It was assumed that model units A, B, and C, which are

baseline uncontrolled, do not have a monitoring program in place.

To start-up LDAR monitoring there will be certain one-time costs.

The initial LOAR costs are considered capital costs for the

purposes of annual cost determinations. These costs are

presented in Table 4 which follows the same format as Tables 3A

and 3B. Since model units 0, E, and F already have a LDAR

program in operation, they will not have these additional costs.

costs.mom 10
(- ( ( '\

'\

\

TABLE JA. ANNUAL NON1TuR1NC "', AND LEAK REPAIR COST ,

"

"- ESTIMATES WITH QUARTERLY VALVE MONITORING )"

.._...- --_.--- ---·---------Estin~ted P~rcent

Times Number of Leaks Requiring Repair Ll]a"- At!I)air laborType 01 Monitored Monitoring Costs· • Leak Per Year Further Time··· Hours R~quir~d Leak Aepair Costs

Source Typo Moniloring Per Year AlO B/E elF Frequency AID 81E elF Repair·· • (Ilrs) AlD elE elF AID BIE CIF

Valves

GasNapor Inslrumenl 4 616 3.312 11,032 0.02 6,2 33.1 110.3 25 4 6.2 33.1 110.3 139 745 2.482

Light LiqUId Instrument 4 3,040 9,432 t5,840 0.02 30.4 94,3 158.4 25 -' :30,4 943 158.4 684 2,122 3,564

Pump Seals

Light liquid Instrument 12 360 960 t,344 0.1 18.0 48.0 67.2 75 16 216.0 5760 206,4 4,860 12.960 t8.144

Visual 52 148 :390 546

Connoctors In5t,ument 1.462 5.324 14.820 0.005 3.7 13.3 37.1 25 2 1 a 67 16,5 41 150 4t7

t-l' Pressure Relief Instrumenl 4 90 152 0 0.0 0,0 0.0 0 0 00 0.0 0.0 0 0 0

Seals·

MODEL UNITS

TOTAL COST ($) AIO B/E elF

Tolal Moniloring Cost 5,628 19.508 43,734

Total Leak Repair Costs 5,724 15.977 24.607

Adminisuative and Support Costs 4.541 14-.'94 27,336

Total Quaner'y LOAR Costs 15.893 49.679 95,677

• A1'hough LOAR is no' requited lor Pressura Relief Seals. it is eslimaled thaI one monitoring will be peffoflMd each year to ensure compliancu With ~quipment standard.

•• Monitoring costs are based on a subContractor's fee 01 $2.00/componenllmonitoring event.

••• Percentages requiring ~urlher repair and repair limes were taken Irom Aeferenc~ 2 Section 5. with the exception of the 15% 01 pumps requiring 'ullher repair.

That value waG calculated u sing data trom Ethylene Oxide and Butadiene plant surveys.
TABLE 3B. ANNUAL MONITORING AND LEAK REPAIR COST

ESTIMATES WITH MONTHLY VALVE MONITORING

E~llIlIah!d Percent

Times Number 01 Leaks Requiring Repair Leak Rolpair LaborType 01 Monitored Moniloring CosIS" Leak Polr Volar Fur'her Time" , Hours Requiled Leak Rtlllall Co~.s

Source Type Monitoring Per Year AID BIE CIF Frequency AID BIE CIF Repair" , (hrs) AID BIE GIF AID BIE CIF

Valves

GasNapor Instrument 12 1,848 9,936 33,096 0.02 185 994 331.0 25 4 'SS 99.4 331.0 416 2.236 7.447

Lighl Liquid Inslrumen' 12 9,120 28,296 47,520 0.02 912 2830 475.2 25 4 91.2 2830 4752 2.os2 6,367 10,692

Pump Seals

Lighl Liquid Instrument .2 360 960 1,344 0.1 18 a 48 a 67.2 75 16 216 a 5760 806.4 4,860 12.960 18.144

Visual 52 146 390 546'

Connectors Inslrumenl 1,462 5,324 14,820 0.005 37 133 37.1 25 2 1 8 67 18.5 41 150 417

N

Pressure ReHel Inslrumen. 4 90 152 0 0.0 0.0 0.0 0 a 0.0 0.0 0.0 0 a a

Seals'

TOTAL COST ($) AID B/E CIF

Tolal Moniloring COSt 12,940 44.996 97,478

To.al Leak Repair Costs 7.369 21,712 36,699

Administralivo and Supporl Costs 8,124 26,683 53,671

Total Monlhly LDAR CostS 28,433 93.391 187,848

, Allhough LDAR is not required lor Pressure Reliel Seals. it is estimated that ono monitoring will be pello/med each year to ensure compliance with equipment slandaul

,. Monitoring cosls are based on a subcontractor's lee 01 $2.00/componenUmonito/ing event.

,., Percenlages requiring IUllherrepair end repair times were laken Irom Relerence 2 Section 5. with lhe exceplion 01 the 75% 01 pumps requiring IUrlher repair.

Thai value was calculaled using data Irom Ethylene Oxide and Butadiene ptanl surveys.

l
(' r "-

TABLE 4 . INITIAL MONITORING r", A':11l.) LEAK REPAIR COST ESTIMATF.~;

._--- '''\

Percent

"" Inilial·· Eslimated Requiring Repair Leak Repair LaborType 01 Monitoring Costs· Leak Uumber 01 LellklO Further Time··· _ Hours Required Leak Repair COSls

Source Type Monitoring A B C Frequency A B C Repair· •• (hrs) A B C A B C

Valves

GasNapot Instrument 193 1,035 3,448 O,tt4 8.8 47.2 t57.2 25 4 8.8 47.2 t57.2 t98 t.062 .3,537

Light Liquid Inslrument

Pump5eals

950 2,948 4,950 0,065 24.7 76,6 128.7 25 4 24,7 76.6 128.7 556 1,724 2,896

Light Liquid Inslrumenl 38 tOO 140 0.2 3.0 8.0 11".2 75 16 36.0 96.0. t34.4 8tO 2,t60 ~,024

I-'

U

Connectors Instrument 1.828 6.655 18.525 0.02t t5.4 55.9 155.6 25 2 7.7 28.0 77.8 t73 629 t.751

MODEL UNITS

TOTAL COST ($) A B C

Tolal Monitoring Cost ~,O08 to,738 27,063

Total Leak Repair Costs 1,736 5,575 11.207

Administrative and Support Costs 1.897 6,525 15.308

Totallnilial LOAR Costs 6,641 22,838 53,578

• Monitoring cosls are based on a subcontracts lee 01 $2.50/cnmponenUmonitoring oVl!nt.

•• II was assumed Ihatleak Irequencies wore 2 times the leak Irequencies presented in Table 3 lor pumps, All Olher leak Irequencies were

taken Irom Relerenco 30,

••• Percentages ,equiring lurther repair and repair times were taken trom Relerence 2 Section 5, wilh the exception 01 the 75% 01 pumps

requi,ing lurthe, ,epal,. ThaI value was calculated using data trom Elhylene Oxide and-Butadiene plant surveys.
/ For these initial monitorings the monitoring cost increases

to $2.50 per component due to first-time difficulties such as

locating all components, increased numbers of components

requiring tagging, and higher leak frequencies. This monitoring

cost was determined by contacting monitoring sUbcontractors. 1S

The initial leak frequencies for valves and connectors were taken

from the 24-Unit Study.16 The initial leak frequency for pumps

listed in Table 4 was estimated as two times the leak frequency

presented in Table 3 to reflect a higher initial leak frequency,

as would be expected. The value from the 24-Unit Study18 for

pumps was not ~sed because it is lower than the value used for

subsequent annual LDAR.

Annual Control Cost Estimates

The annual costs were calculated based on the procedure

developed during the SOCMI Fugitives NSPS development. 2

Tables 5A and 58 present the annual control costs for all six

model units, for quarterly and monthly valve monitoring,

respectively. These annual costs a~e based on the costs

developed in Tables 1 through 4.

The annualized capital costs are based on a 6-year life at

10 percent interest for the monitoring instrument, a 2-year life

at 10 percent interest for rupture disks, and a 10-year life at

10 percent interest for all other control equipment. 2 The

capital recovery factors are then, 0.23, 0.58, and 0.163,

respectively. Note that units A, a, and C, have initial LOAR

capital expenses.

The annual maintenance charge for the monitoring instrument ~.

includes all materials and labor for maintenance and calibration

of the instrument. The annual cost for monitoring instrument

~aintenance presented in the SOCM! Fugitives AI019was $2,700,

and updating this cost to July 1989 dollars gives a present day

cost of $4,280. The charge for replacement pump seals was

determined by mUltiplying the number of seals requiring

subsequent repair, by the replacement seal cost of $180. All

costs.mem 14
TABLE 5A. ANNUAL CONTROL COSTS FOR MODEL UNITS WITH

QUARTERLY VALVE MONITORINGa

Coslltem Unit A UnilS UnitC UnitD UnilE Unit F
.,/

/~

~.

TABLE 5B. ANNUAL CONTROL COSTS FOR MODEL UNITS

WITH MONTHLY VALVE MONITORING3

Cost Item Un.t A Unit B UnotC Unit 0 Un.t E UnitF
.\ . ~-

\

other annual maintenance charges were calculated using a factor

of 0.05' times the capital cost for each component'. z~

The annual miscellaneous charges were calculated using a - --_.-_.-~-- 20

factor of ,0.04 times the capital cost for each component, with

the exception of the replacement pump seals. Their cost was

calculated as 0.80 times the annual maintenance charge. This

gives an annual miscellaneous charge for pump seals proportional

to the miscellaneous charges for other items.

Cost Effectiveness

The cost effectiveness for each of the six model units is

presented in Tables 6A and 68. The values in Table 6A reflect

quarterly valve monitoring, and the values in Table 68 reflect

monthly valve monitoring.

The cost effectiveness for each of the model units was

determined by mUltiplying the annual emission reduction in

megagrams (Mg) of VOC for each model unit times the average HAP

to VOC ratio to obtain the average HAP emission reduction for

each mcdel unit. The annual emission reductions were taken from

the March 29, 1991 memorandum from Bill Hohenstein, Radian/RTP to

D. Markwordt, EPA/CPB "Revised 'Reg Neg' Controlled Model Unit

Emissions from Equipment Leaks." The VOC emission reductions

were then multiplied by the average chemical cost of $1,590jMg of

VOC to produce the recovered VOC credits. The av~rage HAP to VOC

ratio and the chemical cost were determined by the HON industries

profile based on 135 product-process entries (containing cost

information for 168 VOC's) in the HON-CHEM database. 21 The

recovered VOC credits were subtracted from the control costs to

obtain the total annual costs. The total annual costs were then

~ivided by the VOC and HAP emission reductions respectively,' to

provide the cost effectiveness for each model unit on a VOC and a

HAP basis.

These calculations indicate a net savings for all six model

units with quarterly valve monitoring. The cost effectiveness

costs ,In.!ttl 17
TABLE GA. COST EFFECTIVENESS FOR MODEL UNITS

WITH QUARTERLY VALVE MONITORING

Unit A Unit 8 Unit C Unit 0 Unit E Unit F

Annual Cost· S/yr 30,801 125,993 233.149 27.989 120,149 222.044

Emission Reduc. Mg VOC/yr 36.47 149.19 306.11 21.39 92.57 187.98

Average HAPIVOC ratio 0.78 0.78 0.78 0.78 0.78 0.78

Emission Reduc. Mg HAP/yr 28.45 116.37 238.77 16.68 72.20 146.62

Solvent Cost $/Mg VOC 1.590 1,590 1,590 1.590 1.59'0 1.590

Recovered Credit $/yr 57.987 237,212 486.715 34.010 147.186 298.888

Total Ar:lnual Cost $/yr (27,186) (111,219) (253.565) (6,021 ) (27,037) (76,844)

Cost Effect. $/Mg VOC (750) (750) (830) (280) (290) (410)

Cost Effect. $/Mg HAP (960) (960) (1,060) (360) (370) (520)

• Annual cost value is taken from table SA. -..J

NOTE: Parentheses indicate negative values (ie. savings).

18
,

,.".'

~/ TABLE 6B. COST EFFECTIVENESS FOR MODEL UNITS

WITH MONTHLY VALVE MONITORING

Unit A Unit 8 Unit C Unit D Unit E Unit F

Annual Cost $/yr 43,341 169,705 325.320 40,529 163,861 314,215

Emission Reduc. Mg VOC/yr 36.47 149.19 306.11 21.39 92.57 187.98

Average HAPIVOC ratio 0.78 0.78 0.78 0.78 0.78 0.78

Emission Reduc. Mg HAP/yr 28.45 116.37 238.77 16.68 72.20 146.62

Solvent, Cost $/Mg VOC 1,590 1,590 1,590 1,590 1,590 1,590

Recovered Credit $/yr 57,987 237,212 486,715 34,010 147,186 298,888

Total Annual Cost $/yr (14,646) (67,507) (161,394) 6,519 16,675 15,327

Cost Effect. $/Mg VOC (400) (450) (530) 300 180 80

Cost Effect. S/Mg HAP (510) (580) (680) 390 230 100

• Annual cost value is from table 58.

NOTE: Parentheses indicate negative values (ie. savings).

19
/

,-

values range from a savings of $1,060jMg HAP for model unit c to . a savi~gs of $J60/Mg HAP for model unit D. For monthly value

monitoring there is a net savings for model units A, Band C, and

a netexpense for model units 0, E, and F. For the monthly valve

monitoring frequency, the cost effectiveness valu~s range from a

savings of $680/Mg HAP for model unit c, to an expense of $J9Q/Mg

HAP for model unit D.

,

\ .'\

..

20
.. /

REFERENCES

1.

2.

3 .

4.

5.

6.

7.

Hazardous Air Pollutants. Announcement of the Negotiated

Regulation for Equipment Leaks. Federal Register,

Volume 56, No. 44, pp. 9315-9339, March 6, 1991.

U. S. Environmental Protection Agenc¥. Fugitive Emission

Sources of Organic Compounds Addit10nal Information on

Emission, Emission Reductions, and Costs. Research Triangle

Park, North Carolina. Publication No.

EPA-450/3-82-010. April, 1982. section 5.

Johnson, J., Charlotte, North Carolina, representative of

Foxboro Equipment Company. Personal communication with

D. J. Whitt, Radian corporation. October 26, 1990 (document~d for the files of D. J. Whitt.)

Reference 2, p. 5-19.

'Economic Indicators. Final July 1989 CE Plant Cost Index,

and Annual 1988 CE Plant Cost Index. Chemical Engineering.

'97 ( 9) : 262 .

Economic Indicators. Final October 1978 CE Plant Cost

Index. Chemical Engineering. 86(3) :7.

Economic Indicators. Chemical Engineering. 86(7) :7.

8. Economic Indicators. Final December 1978 CE Plant Cost

Index. Chemical Engineering. 86(8):7.

9. Richardson Process Plant Construction

Mechanical and Electrical. Volume 3,

Services, Inc., Mesa, Arizona, 1988.

15-55.

Estimation standards:

Richardson Engineering

Sections 15-42, 15-43,

10. Letter from Caracciolo, D., NAO Inc., to D. J. Whitt, Radian

corporation. October 31, 1990. 4 p. Cost data for flame

arrestor.

11. Nagy, D., Charlotte, North CarOlina, representative of BS&B

Safety s¥stems, Inc. Personal communication with

D. J. Wh1tt, Radian Corporation. October 30, 1990.

12. Economic Indicators. Final July 1990 CE Plant Cost Index.

Chemical Engineering. 97(10):270.12.

13. Reference 9, Section 15-0.13.

14. Economic Indicators. Construction Labor Cost Index

(1988 Annual Average Value and Final July 1989 Value).

Chemical Engineering. 96(3) through 97(2), and '97(9).

15. Summary of T. Ponder, PEl Associates, Dallas, Texas,

February 2, 1990 and November 22, 1990 and Darbonne,

Darbonne Services Inc., Lake Charles, Louisiana,

November 27, 1989. Personal communications with E. Moretti,

Radian Corporation.

costs.mom 21
16. Referellce 2, p. 5-).

from Horetti, E. Radian Corporation to

wordt, D. EPA/CPB. Hay 22, 1989. Summary of Work

gnment 42 - Equipment Leak Emission Estimates, VOC/HAP.

Blacksmith, J. R., G. E. Harris, and G. L. Langley.

Problem-Oriented Report: Frequenc¥ of Leak Occurrence for

Fittings in Synthetic Organic Chem1cal Pl3nt Process Plants.

U. S. Environmental Protection Agency. Research Triangle

Park, tiC. EPA Contract ~lo. 68-02-)171. September 1980.

p. 5.

19. Reference 2, p. 5-J4.

20. U. S. EllVirolllnental Protection Agency. Draft voe Fugitive

Enlissions in Synthetic Organic Cllemical Mal,uf~cturirlg

Industry - Background Information for Proposed Standards.

Researctl 'rriangle Park, ~IC. Publication

No. EPA-450/J-80-0JJa. ~lovember, 1980. p. 8-10.

21 _ Radian Corporation.

Processes. Project

Work Assignment No.

HON Industrial Profile Product

files, EPA Contract No. 68-02-4)78,

10). 1990_

22