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### *. 'Wnw'"

.... £'$ " CTD rrrz- ) &:t) tn ., 3''*' rw X 1m seems '.,-' 

# 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 Neg1 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 Neg1 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 2TABLE 1. BASE COST DATA

Cost Equipment Type Phase Ilem (July'89dollars) Basis
Monitoring Moniloring Instrument 6.500 linstr. Que-teof$6,500/inSIl.

Valves GasNapor LDAR 2 Icom;Jllest Vendorinlormation (t989) Light Liquid LDAR 2 Icompllest Vendorinformation (1989) HeavyLiquid None
Pump Seals light Liquid LDAR 2 Icomp/lest Vendorinformation (1989) \ ./ Replacement Seats 180 Iseal Update IromAID S113/seal _;1. with 50%credit lorold seal CE IndeK(356/224.7) HeavyLiquid None ConnectOrs All LDAR 2 Icompllest Vendor inlormation (1989) Compressor Seals GasNapor Closed Vent System lor Degassing Reservoirs

- 122m015.1 em

schedule40 sleel pipe 1,090 $261.03/10011. (Richardson) CE IndelC(356.0/342.5)

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

- throe5.1 emcast sloel plugvalves 2,440 S783.75/valve(Richardson) , , CE IndelC(356.0/342.5} ,(

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

- ono motalgauze

lIamearrestor 862 Vendorquote01 S869.00 CE IndeK(356.0/358.7} -Installation (10hrs) 225 Labor$22.50Ihr TOTAL: 6.242 Pressure Reliel Seals All (new) Rupture DiskAssembly

- one7.6em stainless

steel rupturedisk 78 Vendorquote01 $235/3-pak

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

steel rupture disk holder 579 10/90quote01 S583/holder

)TABLE 1. (Continued)

Cost EquipmentType Phase lIem (July'89dollars) Basis

- one0.6 COlpressure CE IndOK(356.0/358.7) gauge, diallaco 24 UpdalO Irom SOCMI NSPSAID

- one0.6cm blood CE IndelC(356.0/224.7) valvo, carbon slool .10 Updato Irom SOCMI NSPSAID CE IndoK(356.0/224.7)

- Installalion(16tus) 360 LaborS22.50/1lr

- one7.6cm galeval'/o 401 S385.60/valve(Richardson) CE IndolC(356.0/342.5)

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

- Ollsot; ono 10.2crn i tooandono 10.2COl .,-! olbow 49 $35.631teo.S11.731elbow (Richardson) CE Indox{356.0/342.5)

- Installation (8.5hrs) 191 5.7hrs.ltoo.2.8hrs.lolbow TOTAL: 1.755 (Richardson) All (rotrolil) Coslsarothe sameas lor anewassemblyplusanow reliolvalve.

- ono7.6ern slainless

sloel bodyandtrim reliulvalvo 1.950 Updalo Irom SOCMI NSPSAID CE Indox{356.0/224.7)

- Inslallation (10 hrs) 225 LaborS22.501hr TOTAL: 3.930**~---** Open-Endod Lines All one2.5em galovalvo 70 S67.50/valvo(Richardson) CE IndolC(356.0/342.5) ,..;;

- Installalion(1.4hr) 31 1.4lus./valvo(Richardson) \**~1-** TOTAL: 102 )



# - SampleConnection All Closed Purgo SySlom - 6ma12.5em

schedule40slool .--- pipo 25 S120.64/100n.(Richardson) . \, CE Indox(356.0/342.5) -Installation(1 hr) 23 12.6hrs./10011.(Richardson)

- throo2.5em ball . ..:'....... valvos, carbon 610el 267 S85.60/volvo(Richardson) '-l CE Index(356.01342.5)

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

4days 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** 5index (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 AID2 were 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 6capital Costs
The capital costs for bringing existing units up to the level of control stated in the Reg Neg1 were 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 7TABLE 2. CAPITAL COSTS FOR EQUIPMENT FOR EXISTING UNITS
Hodel Unit Identificationa A B C 

### o Cost (5) E F
6,500 Ob Honitoring Instrument 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. dIt is assumed that all model units already have installed caps on open-ended

lines.

': I ,-: 0..1.

__ 

### \**;~** ,

. 

### ,

co"t.s.mmn**r··~** '. '-c

'.'

"0Yoc':,.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 Neg1 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 Negl as 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 Numberof Leaks Requiring Repair Ll]a"- At!I)air laborType01 Monitored MonitoringCosts·• Leak Per Year Further Time··· Hours**R~quir~d** LeakAepairCosts SourceTypo 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 1a 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 TOTALCOST($) AIO B/E elF Tolal MoniloringCost 5,628 19.508 43,734 Total Leak RepairCosts 5,724 15.977 24.607 Adminisuativeand SupportCosts 4.541 14-.'94 27,336 Total Quaner'yLOARCosts 15.893 49.679 95,677

• A1'hough LOARisno'requited lor Pressura ReliefSeals. itiseslimaledthaI one monitoringwill bepeffoflMd each yeartoensurecompliancuWith**~quipment** standard

. •• Monitoringcostsarebasedon asubContractor'sfee01 $2.00/componenllmonitoring event.

••• Percentagesrequiring**~urlher** repairand repair limeswere taken Irom**Aeferenc~** 2Section 5.with theexception ofthe15% 01 pumpsrequiring 'ullher repair. ThatvaluewaGcalculated using datatrom EthyleneOxideand Butadieneplantsurveys.TABLE 3B. ANNUAL MONITORING AND LEAK REPAIR COST ESTIMATES WITH MONTHLY VALVE MONITORING**E~llIlIah!d** Percent Times Number01 Leaks Requiring Repair Leak Rolpair LaborType 01 Monitored MoniloringCosIS" Leak Polr Volar Fur'her Time" , Hours Requiled Leak Rtlllall**Co~.s** Source Type Monitoring PerYear 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 PumpSeals

Lighl Liquid Instrument .2 360 960 1,344 0.1 18a 48a 67.2 75 16 216a 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'

TOTALCOST($) AID B/E CIF Tolal Moniloring COSt 12,940 44.996 97,478 To.al LeakRepairCosts 7.369 21,712 36,699 Administralivoand SupporlCosts 8,124 26,683 53,671 Total MonlhlyLDARCostS 28,433 93.391 187,848

, Allhough LDARisnotrequired lorPressure Reliel Seals. itisestimatedthatonomonitoringwill bepello/med eachyeartoensurecompliancewith equipmentslandaul

,. Monitoringcoslsarebasedon asubcontractor's lee01 $2.00/componenUmonito/ing event.

,., Percenlagesrequiring IUllherrepairend repairtimeswerelaken Irom Relerence2Section 5. with lheexceplion01the75% 01pumpsrequiring IUrlherrepair. Thai valuewascalculaledusingdataIrom EthyleneOxideandButadieneptanlsurveys. 

# l

# (' 

# r "- 

### TABLE 4 . 

### INITIAL 

# r", MONITORING A':11l.) 

### LEAK REPAIR COST**ESTIMATF.~;** 

# '''\
._--- Percent 

# "" Inilial·· Eslimated Requiring Repair LeakRepairLaborType 01 MonitoringCosts· Leak Uumber01 LellklO Further Time···

_ HoursRequired LeakRepairCOSls SourceType 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

LightLiquid 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

MODELUNITS TOTALCOST($) A B C Tolal MonitoringCost**~,O08** to,738 27,063 Total LeakRepairCosts 1,736 5,575 11.207 Administrativeand SupportCosts 1.897 6,525 15.308 TotallnilialLOARCosts 6,641 22,838 53,578

• Monitoringcoslsare basedonasubcontractslee01 $2.50/cnmponenUmonitoring oVl!nt

. •• IIwasassumed IhatleakIrequencieswore2timestheleakIrequenciespresentedinTable3lorpumps, All OlherleakIrequencieswere taken Irom Relerenco30,
••• Percentages,equiring lurtherrepairand repairtimesweretaken trom Relerence2Section5,wilhtheexception01 the75%01 pumps requi,ing lurthe, ,epal,. ThaIvaluewascalculated usingdatatrom ElhyleneOxideand-Butadieneplantsurveys.

# / 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 AI019 was $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 14TABLE 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 UnitB UnotC Unit0 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 17TABLE GA. COST EFFECTIVENESS FOR MODEL UNITS WITH QUARTERLY VALVE MONITORING

UnitA Unit8 UnitC Unit0 Unit E UnitF

Annual Cost· S/yr 30,801 125,993 233.149 27.989 120,149 222.044 Emission Reduc. MgVOC/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 SolventCost$/MgVOC 1.590 1,590 1,590 1.590 1.59'0 1.590 Recovered Credit$/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. $/MgVOC (750) (750) (830) (280) (290) (410) Cost Effect. $/MgHAP (960) (960) (1,060) (360) (370) (520)

• Annual costvalue istaken from table SA. 

# -..J
NOTE: Parentheses indicate negativevalues (ie. savings).

18,
,.".'

### ~/ TABLE 6B. COST EFFECTIVENESS FOR MODEL UNITS WITH MONTHLY VALVE MONITORING

UnitA Unit8 UnitC UnitD Unit E Unit F

Annual Cost $/yr 43,341 169,705 325.320 40,529 163,861 314,215
Emission Reduc. Mg VOC/yr 36.47 149.19 306.11 21.39 92.57 187.98 Average HAPIVOC ratio 0.78 0.78 0.78 0.78 0.78 0.78
Emission Reduc. Mg HAP/yr 28.45 116.37 238.77 16.68 72.20 146.62 Solvent,Cost$/MgVOC 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. $/MgVOC (400) (450) (530) 300 180 80
Cost Effect. S/Mg HAP (510) (580) (680) 390 230 100

• Annual costvalue isfrom table 58. NOTE: Parentheses indicate negativevalues (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

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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 2116. 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