Date: October 30, 2007 

To: Karen Rackley, EPA/SPPD 

From: Kristin Parrish and David Randall 

Subject: Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC in the 

SOCMI 

I. Introduction 

The U. S. Environmental Protection Agency (EPA) is reviewing the new source 

performance standards (NSPS) for equipment leaks of volatile organic compounds (VOC) in the 

synthetic organic chemicals manufacturing industry (SOCMI) (40 CFR part 60, subpart VV) and 

the petroleum refining industry (40 CFR part 60, subpart GGG). During the review, EPA 

identified three potential new requirements that were developed into regulatory options for 

process units constructed, reconstructed, or modified after the date of proposal: (1) lower the 

leak definition for pumps from 10,000 parts per million (ppm) to 2,000 ppm and lower the leak 

definition for valves from 10,000 ppm to 500 ppm; (2) add connectors to the monitoring program 

with a leak definition of 500 ppm; and (3) add open-ended valves or lines (OEL) to the 

monitoring program with a leak definition of 500 ppm. Options 1 and 2 are consistent with 

requirements in other Federal rules, and Option 3 was developed because available information 

shows significant emissions from OEL under the existing equipment standards. EPA proposed 

and/or requested comment on these options on November 7, 2006 (71 FR 65302). To clarify the 

applicability of any new requirements, EPA has decided to create new subparts VVa and GGGa. 

 

The purpose of this memorandum is to document the assumptions and methodology used 

to determine the final estimates of cost and VOC emission reduction impacts for new, 

reconstructed, and modified process units in the SOCMI in the fifth year after proposal. The 

options presented in this memorandum are defined as follows: 

1) Lowering the leak definitions for pumps (2,000 ppm) and valves (500 ppm); 

2) Option 1 plus monitoring of connectors; and 

3) Option 2 plus monitoring of OEL (in addition to already-required caps/plugs). 

The following is a summary of the impacts for each option: 
 

Option 

Emission 

Reduction 

(tons/yr) 

Total Annual 

Cost without 

Recovery 

Credit ($/yr) 

CostEffectiveness 

without Recovery 

Credit ($/ton) 

Total Annual 

Cost with 

Recovery 

Credit ($/yr) 

CostEffectiveness 

with Recovery 

Credit ($/ton) 

1 94 41,000 430 -36,000 -380 

2 328 820,000 2,500 550,000 1,700 

3 353 930,000 2,600 640,000 1,800 

Throughout the remainder of this memorandum, the term “reconstructed” refers to both 

reconstructed and modified process units, and the term “new” refers to process units that 

commence construction after November 7, 2006. 

II. Lower Leak Definitions for Pumps and Valves 

A. Number of Impacted Sources

We used SRI Consulting’s 2004 Directory of Chemical Producers: United States to 

estimate the number of currently-operating process units in the SOCMI.1

 There are 

approximately 1,272 process units that manufacture chemicals listed in §60.489 of subpart VV. 

This estimate is based on the total number of manufacturing sites listed in the SRI Directory for 

310 of the chemicals listed in subpart VV (the other 68 are not listed in the 2004 SRI directory). 

Each site that manufactures a particular chemical was assumed to have one process unit for that 

chemical; several sites have multiple process units because they manufacture more than one 

chemical. Of the 1,272 process units, 879 units manufacture either ethylene or a chemical listed 

in Table 1 to 40 CFR part 63, subpart F (the National Emission Standards for Organic Hazardous 

Air Pollutants for Equipment Leaks (HON)). Ethylene process units would be subject to the 

equipment leak standards in 40 CFR part 63, subpart UU, as specified in the National Emission 

Standards for Hazardous Air Pollutants (NESHAP) for Source Categories: Generic Maximum 

Achievable Control Technology Standards (Ethylene NESHAP) (40 CFR part 63, subpart YY), 

if they are located at major sources of hazardous air pollutant (HAP) emissions. Process units 

manufacturing one of the chemicals listed in Table 1 to subpart F of the HON would be subject 

to the equipment leak standards in 40 CFR part 63, subpart H, of the HON if they use or produce 

an organic HAP as a reactant or a product and are located at a facility that is a major source of 

HAP emissions. For convenience in the discussion that follows, all of the process units that 

manufacture ethylene or a chemical listed in Table 1 of 40 CFR part 63, subpart F, are referred to 

as “HON sources” or are considered to be “manufacturing HON chemicals,” even if they are not 

subject to the above NESHAP (e.g., they are located at area sources of HAP). The remaining 

393 process units are assumed to be manufacturing chemicals that would be subject to the 

NESHAP for Miscellaneous Organic Chemical Manufacturing (MON) (40 CFR part 63, subpart 

FFFF) if they use, process, or generate HAP and are located at major sources of HAP emissions. 

For convenience in the discussion that follows, these 393 process units are collectively referred 

to as “MON sources” or are considered to be “manufacturing MON chemicals,” even if they are 

not subject to the MON (e.g., they are located at area sources of HAP). 

To project the number of new and reconstructed process units at SOCMI facilities over 

the next five years, we assumed the industry growth rate (for both new and reconstructed process 

units) would parallel the growth in gross domestic product (GDP). According to several sources, 

2
 

GDP annual growth projection estimates range from 2.7 percent2 to 3.1 percent.3,4 Based on 

these data, we estimated the overall SOCMI growth rate to be 3 percent per year. Using this 

growth rate, we estimate there will be 191 new or reconstructed process units in the SOCMI over 

the next five years. However, the impacts of Option 1 will be different for the pumps and valves 

in each process unit depending on what Federal rules already require monitoring at these lower 

leak definitions. Not all of the 191 process units will be impacted by amendments to the NSPS 

subpart VV; as previously mentioned, some of these units are subject to the HON, the MON, or 

the Ethylene NESHAP. We developed seven scenarios in order to track which process units will 

be impacted by each option; these seven include separate scenarios for new and reconstructed 

process units to accurately estimate initial costs. Reconstructed units that are covered under an 

LDAR program prior to reconstruction will have fewer initial costs, particularly those associated 

with identifying the equipment, updating the tracking software, and other related tasks. See 

Section II.C of this memorandum for further details on the cost analysis. 

We used several assumptions to determine how many units will be represented by each 

scenario. First, we assumed that the 191 process units constructed or reconstructed in the next 

five years will be split between HON sources and MON sources in the same ratio as the 

1,272 existing process units. Second, we used EPA’s 2002 National Emissions Inventory (NEI)5

and the Envirofacts Data Warehouse6 to determine how many process units are located at area 

sources and, therefore, not subject to any NESHAP. See Attachment A for the details of this 

analysis. Based on the analysis results, we estimated that 15 percent of the process units are 

located at area sources. Third, we made some assumptions regarding whether or not HAP are 

emitted from the process units at major sources. We assumed that the manufacturing of any of 

the chemicals listed in Table 1 to subpart F of the HON would require the use of an organic HAP 

as a reactant or produce an organic HAP as a product. Therefore, we assumed that the 

879 process units manufacturing HON chemicals are emitting HAP. It is possible that some of 

the remaining 393 process units, those making MON chemicals, emit only non-HAP volatile 

organic compounds (VOC). However, we do not have detailed process descriptions or other 

information regarding the manufacture of these chemicals. Therefore, we assumed that a small 

percentage (20 percent) of the MON process units at major sources are emitting only non-HAP 

VOC. Fourth, given the relatively high projected growth rate and the potentially unusually high 

demand for ethanol as fuel, we assumed that new units would predominate in a 60/40 split with 

reconstructed units over the next 5 years. 

The fifth assumption involved the differences in definitions of “new” and “reconstructed” 

affecting sources subject to the MON and subpart VV. The definitions of “new” and 

“reconstructed” in §63.2440(c) of the MON are more limited than the definitions included in the 

General Provisions to subpart 60. In other words, a process unit that would be subject to subpart 

VV would not necessarily be considered a new source for purposes of complying with the MON. 

Therefore, these process units would be affected by any proposed amendments to subpart VV. 

To be a new affected source under the MON, the potential HAP emissions for the individual 

process unit alone must be above the major source thresholds of 10 tons/yr for any single HAP or 

25 tons/yr for collective HAP. Given this high threshold, we assumed that only 20 percent of the 

new and reconstructed process units at existing major source facilities subject to the MON would 

meet the definition of “new” or “reconstructed” in §63.2440(c). (This assumption only affects 

the impacts of Option 2; process units subject to existing source standards under the MON 

3
 

currently have to monitor pumps and valves under an LDAR program equivalent to Option 1, but 

they do not currently have to monitor connectors.) By applying the above calculations to the 

191 estimated new and reconstructed process units, we estimate that 39 new and reconstructed 

process units will be impacted by amendments to subpart VV (see Attachment B for a pictorial 

representation of the calculations and the resulting estimate). 

A majority of the costs and all of the emissions estimates are functions of the number of 

pumps and valves. Therefore, we estimated the number of pumps and valves in model process 

units that represent the 191 affected process units. We represented the affected process units 

with the simple, medium, and complex models developed for the HON.7

 See Attachment C for 

the equipment counts for each model process unit. We also assumed that the distribution of 

these models in the SOCMI is the same as the distribution in the original SOCMI analysis 

(52 percent simple, 33 percent medium, and 17 percent complex).8 These process units were 

divided among the seven scenarios in accordance with the number of process units subject to 

each scenario as described above. The number of pumps and valves in the process units subject 

to each scenario were estimated by multiplying the number of pumps and valves in the simple, 

medium, and complex models by the estimated number of process units. The results are shown 

in Table 1. 

B. Emission Estimates

The analysis uses industry-supplied data to the extent possible. The first step was to 

estimate leak frequencies under both baseline and Option 1 leak detection and repair (LDAR) 

programs. We began by examining valve emissions data collected for the HON residual risk 

analysis (see Attachment D).9 The average leak frequency from this analysis (0.51 percent) was 

selected as the leak frequency for an LDAR program controlling valves at 500 ppm. We then 

used information from a similar analysis we performed to examine the impacts of these same 

regulatory options on the petroleum refining industry.10 

To estimate the leak frequency for SOCMI valves under a baseline LDAR program, we 

assumed the ratio of baseline to Option 1 leak frequencies would be the same for SOCMI sources 

as for refineries. Similarly, to estimate SOCMI baseline and Option 1 pump leak frequencies, we 

assumed that the leak frequency ratios between pumps and valves estimated for refineries would 

also apply to the SOCMI. Attachment E presents the estimated leak frequencies for both 

refineries and SOCMI sources as well as a sample calculation for how each leak frequency was 

determined. Table 2 summarizes the resulting estimated leak frequencies for SOCMI sources. 

Average emission rates per pump and per valve under the baseline and Option 1 LDAR 

programs were estimated using the correlation equations in Table 2-9 of the Protocol for 

Equipment Leak Emission Estimates (the Protocol document).11 The relevant data from the 

Protocol document and the 1997 American Petroleum Institute report Analysis of Refinery 

Screening Data12 are reproduced in Attachment F. In addition, the analysis uses the following 

procedures and assumptions: 

 

 10 screening value ranges were selected as shown in Attachment G (e.g., see page 2 

of Attachment G), 

4
 

 screening values are lognormally distributed, and the geometric mean represents the 

typical screening value in each concentration range; as an approximation of the 

geometric mean, the average screening value was assumed to be one-third of the way 

above the lower end of the range (e.g., 665 ppm for leaks between 500 and 1,000 

ppm), 

 the total percentage of valves and pumps leaking above the applicable leak definition 

over a monitoring cycle was assumed to be equal to one-half of the leak frequency 

just prior to monitoring, 

 the percentage of valves or pumps with screening values within each range above the 

leak definition is proportional to the distribution for uncontrolled equipment with 

screening values above that leak definition as presented in Figures B-3-2 to B-3-4 in 

the Protocol document (similarly, the percentages in screening value ranges below the 

applicable leak definition were assumed to be proportional to the distribution of 

screening values for uncontrolled equipment with screening values below that leak 

definition), and 

 emission rates for equipment with screening values less than 10 ppm were assumed to 

be equal to the default zero emission rates in Table 2-11 of the Protocol document. 

The leak frequencies presented in Attachment E are assumed to be representative of 

facility-measured leak frequencies (and, therefore, representative of the leak frequencies that 

determine repair costs). However, U.S. EPA NEIC data on leak frequencies for valves at 

17 refineries (as documented in Enforcement Alert) suggest the actual percentage leaking may be 

higher. We 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). We chose to use a conservative factor because the report did not 

include information such as the leak definition used by each of the refineries, and all 

17 refineries may not be representative of the entire petroleum refining industry or the SOCMI. 

A more rigorous statistical analysis provided in a separate memorandum shows that the actual 

leak fractions are at least 2.6 times higher than the industry-measured leak fractions at the 

99 percent confidence interval. We did not use this higher factor in the final impacts analysis 

because it did not change the regulatory conclusions. Furthermore, the 1.7 factor is more 

conservative, which ensures that emissions estimates are not overestimated due to any limitations 

in the data used in the statistical analysis.13 

Our emissions calculations for pumps and valves are documented in Attachment G. All 

calculations are based on the leak frequency distributions presented in Figures B-3-2 to B-3-4 in 

the Protocol document. For each type of component, there are five sets of calculations: 

Set 1 – Emissions, no control 

 The Protocol document leak frequency distributions estimated for pumps and 

valves are used to obtain an emissions estimate. This calculation was performed 

only to validate the procedure by showing it estimates uncontrolled emissions 

close to the average uncontrolled emission factors presented in Table 2-1 of the 

Protocol document. 

5
 

Set 2 – Leak frequency distributions prior to monitoring, baseline leak definition 

 The leak frequencies estimated for pumps and valves at 10,000 ppm (as described 

above) are used to scale the Protocol document distributions for the LDAR 

program currently required by subpart VV. 

Set 3 – Average emissions, control at baseline leak definition 

The Set 2 leak frequencies in concentration ranges above 10,000 ppm are divided 

by 2 to estimate the average emissions between monitoring events with a leak 

definition of 10,000 ppm. 

Set 4 – Leak frequency distributions prior to monitoring, proposed leak definition 

 The leak frequencies estimated for pumps and valves at the applicable proposed 

leak definition (as described above) are used to scale the Protocol document 

distributions for an LDAR program with leak definitions of 500 and 1,000 ppm, 

depending on the type of component. 

Set 5 – Average emissions, control at proposed leak definition 

 The Set 5 leak frequencies for ranges that are above the appropriate proposed leak 

definition for each type of component are divided by 2 to estimate the average 

emissions between monitoring events for that control program. 

For each set in Attachment G, the column titled “Percent of values in range” shows the 

scaled leak frequency data from the Protocol document as a percentage of all valves monitored. 

The column titled “Emission rate, kg/hr (per 100 valves)” (or pumps) shows the results of the 

correlation equation for the screening value in each range multiplied by the percentage of all 

valves in that range. The sums of the values in each of those columns are divided by 100 to 

convert the emission factor to a per-component basis. The emission factors estimated in Set 3 

and Set 5 are the factors used to calculate incremental emissions reduction. 

C. Cost Analysis

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.

14 

The methodology has been tailored specifically for this analysis of the SOCMI. In other words, 

we estimated costs only for pumps and valves (including associated planning and administrative 

costs) because all other costs would be constant for implementing Option 1. We also assumed 

there would be no initial costs for purchasing software to track monitoring or renting or 

purchasing monitoring equipment because chemical manufacturers have already purchased or 

made arrangements for those items under the current LDAR requirements. 

Attachment H contains most of the constant values and information used in developing 

our cost estimates. Several constant values used in this analysis were developed for previous 

analyses and are documented in Impacts from the Control of VHAP Emissions from Equipment 

Leaks in Non-SOCMI Process Units for HON. Other constants were developed or estimated as 

follows: 

6
 

Equipment-based costs 

 Initial cost of monitoring equipment in gas and light liquid service: The value of 

$17.70 per component 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.15

 Initial cost of monitoring equipment in heavy liquid service: The value of $1.13 per 

component includes revising or developing drawings to identify equipment in heavy 

liquid service.16

 Monitoring fee (equipment other than connectors): The value of $1.50 per 

component is based on information provided by a monitoring and repair contractor.17

 Wage (chemical manufacturing maintenance) and overhead factor: maintenance and 

repair: We are assuming that monitoring and many first attempts at repair will be 

performed by contractors. The value of $23.19 per hour is the mean wage rate for 

Standard Occupational Classification (SOC) Code 49-9012 (control and valve 

installers, except mechanical doors) in NAICS 325 (Chemical Manufacturing) in the 

May 2006 Bureau of Labor Statistics (BLS) Employment and Wage Estimates.18 

(This wage rate is for chemical manufacturing personnel, not contractors, so it is 

likely to be higher than the actual wage rate.) We are also assuming a 200 percent 

overhead factor (which correlates to an overhead factor of 3) based on the overhead 

factor used for performance testing contractors in the Continuous Emission 

Monitoring System Cost Model (summarized in Section 2, Chapter 4.4 of the EPA Air 

Pollution Control Cost Manual 19).

 Overhead factor: administration, planning, and training: These tasks would be 

performed by chemical manufacturing personnel. The overhead factor of 1.6 

correlates to the average overhead factor of 60 percent suggested in Section 1, 

Chapter 2.5 of the EPA Air Pollution Control Cost Manual for combined payroll and 

plant overhead.

 Planning and training labor charge: The value of $64.21 is a weighted average for 

technical, management, and clerical labor. The weighted average assumes 5 hours of 

management time and 10 hours of clerical effort per 100 hours of technical labor. 

The values were selected from the May 2006 BLS Employment and Wage Estimates. 

The technical rate is based on the mean wage for environmental engineers ($35.41), 

the management rate is based on the mean wage for general and operations managers 

($59.94), and the clerical rate is based on the mean for all office and administrative 

support occupations ($17.16). A 60 percent overhead factor was added to these rates. 

 Capital recovery factors: Equation 2.8a in the EPA Air Pollution Control Cost 

Manual 19 was used to calculate the capital recovery factors (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, we assumed a life span of 5 years, and for all other equipment and initial labor, 

we assumed a life span of 10 years. For both factors, we assumed an interest rate of 

7 percent. 

 VOC Recovery Credit: We estimated a typical recovery credit of $900 per megagram 

(Mg). This value is an estimate based on prices for a number of solvents and 

7
 

intermediates provided by Platts.20,21 Actual chemical prices vary over a wide range. 

Many organic compounds are considerably more expensive. On the other hand, 

common compounds like methanol and ethylene dichloride are considerably less 

costly. The $900/Mg value is weighted towards the lower end of the range because 

this value is representative of prices for common compounds liked toluene, xylene, 

and hexane; and it accounts for the fact that higher volume compounds tend to have 

prices towards the lower end of the range. 

Process unit-based costs 

 Planning and training for LDAR program, current NSPS level and current MON 

level: The value of 320 hours per process unit is based on an estimate of 318 hours of 

initial administration, planning, and training to implement a SOCMI-based LDAR 

program for greater than 500 total pieces of equipment (documented in Attachment 7 

to Equipment Leak Analysis for Amino and Phenolic Resins NESHAP).22

 Planning and training for LDAR program, including connectors (current HON and 

new source MON level): The value of 340 hours per process unit is based on the 

estimate for initial administration, planning, and training to implement an LDAR 

program that includes connector monitoring for greater than 500 total pieces of 

equipment (documented in Attachment 7 to Equipment Leak Analysis for Amino and 

Phenolic Resins NESHAP). 

 Administrative and reports for LDAR program, current NSPS level and current MON 

level: Equipment Leak Analysis for PET Facilities Subject to the Group IV Polymers 

and Resins NESHAP includes an estimate of 300 hours per year for an LDAR 

program that includes connectors;23 the value of 250 hours per process unit is scaled 

down from that estimate based on the ratio of the amount of hours required for LDAR 

programs with and without connectors in Equipment Leak Analysis for Amino and 

Phenolic Resins NESHAP. 

 Administrative and reports for LDAR program, including connectors (current HON 

and new source MON level): The value of 300 hours per process unit is from 

Equipment Leak Analysis for PET Facilities Subject to the Group IV Polymers and 

Resins NESHAP. 

 

Attachment I shows the cost calculations for each of the three models. Pages I-1 to I-4 of 

the cost calculations show the baseline case for process units that become subject to subpart VV 

if no changes are made to the current rule. The parameters include a leak definition of 

10,000 ppm, monthly monitoring for pumps, semiannual monitoring for valves (assuming the 

owner or operator chooses to use the “skip period” monitoring provisions in §60.483-2), and no 

connector monitoring. Pages I-5 to I-10 show the costs for Option 1 for most of the process units 

in the analysis. The third set of calculations, pages I-11 to I-16, is specifically for process units 

currently complying with subpart VV that will meet the definition of “reconstructed” in the next 

five years. This set assumes that the leak frequency for the first monitoring occurrence at a 

lower leak definition, or the initial leak frequency, will be higher than the subsequent leak 

frequencies. (The initial leak frequencies are calculated in Attachment G and summarized in 

Attachment E.) All other parameters are the same as the second set. 

8
 

The last step in the analysis includes determining which initial costs, annual costs, 

monitoring frequencies, and other parameters should be applied to each of the seven scenarios 

described in Section II.A of this memorandum. Table 3 summarizes the values and parameters 

defined for each of these scenarios. The baseline and Option 1 costs for each of these seven 

scenarios are presented in Attachment J. 

III. Monitoring of Connectors 

A. Number of Impacted Sources

We calculated the numbers of impacted connectors and process units using the procedure 

and the seven scenarios described in Section II.A. As mentioned previously, Attachment B 

shows a pictorial representation of the determination of the number of connectors and process 

units in each of the scenarios, and Table 1 shows the estimated connectors in process units 

subject to each of the seven scenarios. Process units subject to the HON or to new source 

requirements in the MON are already required to monitor connectors; process units subject to 

existing source requirements in the MON are not (i.e., new or reconstructed process units under 

the General Provisions that do not meet the criteria for a new affected source under the MON). 

Therefore, Option 2 will affect some new and reconstructed process units subject to the MON as 

well as process units only subject to subpart VVa (i.e., model scenarios 4 through 7). 

B. Emission Estimates

The leak frequency data presented in Revised MACT Floor, Regulatory Alternatives, and 

Nationwide Impacts for Equipment Leaks at Chemical Manufacturing Facilities were used as the 

starting point for the connectors analysis.24 This memorandum summarizes initial leak 

frequency data for connectors at various types of chemical manufacturing plants that were 

conducting their first round of monitoring under an LDAR program. The average leak frequency 

(normalized to a leak definition of 500 ppm) was determined to be 0.36 percent. We assumed 

this value represents the baseline leak frequency for connectors at SOCMI sources that become 

subject to subpart VV. Because this value is less than the performance level of 0.5 percent in the 

HON, we made the conservative assumption that subsequent leak frequencies under an LDAR 

program based on Option 2 would be the same as the initial leak frequency. However, we also 

assumed that these leaking connectors would be fixed so that the average leak frequency over 

each monitoring cycle would be equal to one-half of the subsequent leak frequency (i.e., 

0.18 percent). Similar to the analysis for pumps and valves, the NEIC factor of 1.7 was applied 

to these leak frequencies for purposes of calculating emission factors. As an alternative to the 

emission estimation procedure described in Section II.B for pumps and valves, we used the 

average leak rate equation for connectors at 500 ppm in Table 5-4 of the Protocol document to 

estimate the baseline and Option 2 emission factors. The results using this much simpler 

approach are nearly the same as using the procedure described in Section II.B. 

C. Cost Analysis

The cost analysis methodology is similar to the methodology described in Section II.C. 

The methodology has been tailored specifically for this analysis of the SOCMI. To calculate the 

9
 

cost of Option 2, we estimated costs only for connectors (including associated planning and 

administrative costs) and then added the connector costs to the costs associated with lowering the 

leak definition for pumps and valves. As a check of this method, we also calculated the cost and 

emission reductions for Option 2 overall (including monitoring pumps and valves at 2,000 and 

500 ppm, respectively). Both methods are presented in Attachment I. 

In addition to the unit costs provided in Section II.C, we estimated a monitoring fee for 

connectors. Although we are not aware that monitoring contractors charge a higher fee for 

connectors than for other equipment, industry noted that connectors are more difficult to monitor 

than valves.25 Therefore, we decided to use a value of $2.50 per connector to account for any 

additional potential difficulties associated with monitoring connectors. This value likely 

overstates the actual monitoring costs slightly but does not change the regulatory conclusions. 

Attachment I shows the cost calculations for each of the three models using both methods 

described in this section. Pages I-11 to I-16 show the Option 2 costs for each model, and page I17 shows the costs for connectors only. Page I-17 also includes the nationwide emission costs 

for connectors. The Option 2 costs for each of the seven scenarios are presented in 

Attachment J. 

We considered including a few other costs as well, but we decided they were not needed. 

A list of these additional costs and the rationale for not including them is provided below: 

 We did not include the cost of a monitoring instrument or instrument rental because 

most facilities contract for monitoring services. In the event that they perform the 

monitoring in-house or conduct monitoring to verify repairs, it is likely that an 

instrument already needed to monitor pumps and valves could also be used to monitor 

connectors. 

 We did not include the cost of a data collection system because a facility that needs 

one would already have it for the pump and valve data. Although we are aware that 

at least some vendors charge higher software license fees as the amount of equipment 

increases, these fees increase in a stair-step fashion, eventually reaching a constant 

fee for unlimited additional equipment. We suspect that many facilities already have 

enough equipment to be charged the top fee, so adding connectors would not drive up 

the costs. We do not have sufficient data to estimate the number of facilities with less 

equipment that would incur higher costs by adding connectors. However, if we 

assumed each process unit incurred an additional $6,000 in license fees, the 

nationwide increase in the cost effectiveness would be less than 10 percent. 

IV. Monitoring of Open-Ended Lines or Valves 

Option 3 includes monitoring of OEL at 500 ppm at the same monitoring frequency as 

the associated valve (as well as a requirement to report the number of leaking OEL.) These 

requirements are in addition to the caps, plugs, blind flanges, or secondary valves required by the 

existing NSPS. To estimate emission reductions and costs of monitoring OEL, EPA collected 

data from the National Enforcement Investigations Center (NEIC) and EPA’s Region 5 

documenting leaks from OEL that currently are subject to standards that require the use of a cap, 

10
 

plug, blind flange, or second valve to control emissions from leaks.26,27 Industry also provided 

additional data on monitoring and repair of OEL at SOCMI facilities.28,29 These data were used 

to estimate baseline emissions for the impacts analysis. We anticipate that Option 3 will affect 

all of the new and reconstructed process units in this analysis; no Federal regulations currently 

require SOCMI sources to include OEL in their LDAR programs. See Attachment L for 

calculations supporting the following analysis. 

A. Number of Impacted Sources

As described in Section II.A, we estimated that there will be 191 new or reconstructed 

process units in the SOCMI over the next five years. We estimated the number of OEL per 

process unit based on the total number of OEL per model process (simple, medium, and 

complex) as developed for the HON analysis and the distribution of these models across the 

SOCMI as developed for the original SOCMI impacts analysis. As a result, each process unit 

has an estimated 127 OEL (on average) for a total of 24,300 OEL nationwide. 

To estimate the percent of the total OEL that are in gas/vapor service or light liquid 

service, we reviewed the distribution of the OEL among gas/vapor, light liquid, and heavy liquid 

service as developed for the original SOCMI equipment leak analysis.30 That analysis indicated 

that 9 percent of OEL are in gas/vapor service and 91 percent are in liquid service, and the OEL 

in liquid service were assumed to be evenly split between light liquid service and heavy liquid 

service. However, data from a study of 24 SOCMI process units indicated that of the OEL in 

liquid service, 87 percent are in light liquid service and 13 percent are in heavy liquid service.31 

We used this split in this analysis. As a result, we estimate that 12 percent of all OEL are in 

heavy liquid service (13 percent of 91 percent). Based on these assumptions, the average 

number of OEL in gas/vapor and light liquid service per process unit is 112 (i.e., 88 percent of 

127 OEL), and the total number of OEL in gas/vapor and light liquid service is 21,411. Finally, 

we assumed that 20 percent of OEL are in sampling connection systems and would therefore not 

be monitored, leaving a total of 17,129 affected OEL. 

The original SOCMI models are based on data from 62 SOCMI processes from an 

analysis in the 1970s.8

 The HON models are based on data for 56 SOCMI processes from two 

studies in the 1980s.7 We have no reason to conclude that one set of models is superior to the 

other in terms of how well it represents SOCMI processes. If we were to use the original 

SOCMI models in the OEL analysis, the emissions, emission reductions, and every cost element 

except the reporting and administrative costs would increase in direct proportion with the 

number of OEL (by a factor of about 3). The reporting and administrative costs are related to the 

number of facilities with affected sources rather than the number of OEL. Because the number 

of facilities does not increase when switching from the HON to the SOCMI models, the net 

effect of using models with more OEL (assuming other parameters in the analysis like the 

percent leaking and the concentration profile remain constant) is to reduce the cost-effectiveness. 

The magnitude of the increase in costs would not trigger different statutory requirements, and 

using the HON models and increasing the OEL counts did not affect the regulatory conclusion. 

Therefore, we decided not to change the SOCMI model equipment counts. 

11
 

B. Emissions Estimates

Several industry representatives provided leak frequency data for OEL in 15 facilities.28,29 

We consider this information to be sufficiently representative of the SOCMI industry for the 

purposes of estimating impacts of a standard for OEL. These data are from a variety of chemical 

process units, both SOCMI and non-SOCMI. Most facilities provided data for one process unit, 

but some provided average values for as many as seven process units. All of the data were 

collected using Method 21, which is consistent with the requirement in the new standard in 

subpart VVa. Some of the data are for process units that are subject to the standards for highly 

reactive VOC in Texas, which requires monitoring only of OEL at the end of lines that contain 

HRVOC (and the HRVOC rule also requires monitoring of caps and plugs in direct contact with 

process fluid, which are not OEL in the new standards in subpart VVa). Given the high vapor 

pressure of these compounds, it is possible that the percent leaking in these process units would 

be higher than average for SOCMI process units, but two of these process units reported zero 

leakers. Some facilities also reported the highest leak rate found over several rounds of 

monitoring. On the other hand, the reported percent leaking values for some of the processes are 

averages over 4 or 5 quarters. Presumably these average leak frequencies are lower than the 

initial leak frequencies. Most, if not all, of the data for the HRVOC processes are likely in 

gas/vapor or light liquid service, consistent with the requirements in the new standards in subpart 

VVa. One facility specifically noted that the data were for OEL in gas/vapor and liquid service, 

and another one noted the data were for OEL in heavy liquid service. For other facilities, the 

type of service is not clear. Finally, the reported number of OEL per process unit varied over a 

wide range (although the number for process units subject to the HRVOC rules in Texas may not 

be the total number because only those in HRVOC service have to be monitored). 

Although industry provided equipment counts, leak frequencies, and brief descriptions of 

processes at which OEL monitoring has been conducted, they did not provide individual 

instrument readings or screening values for the leaking OEL. Therefore, a SOCMI-specific 

analysis comparable to the refinery analysis was not possible using these data. However, we 

have no reason to suspect that the distribution of screening values would be significantly 

different than at refineries. In the absence of data that conflict with the NEIC data, we decided to 

use the same concentration profile for both the SOCMI and petroleum refinery OEL. The data 

from NEIC included 157 leaking OEL at various screening values, which we subdivided into six 

concentration intervals. A representative screening value for each interval (e.g., 500 ppm to 

1,000 ppm) was calculated as the arithmetic average of the screening values for OEL leaking in 

that interval from the NEIC data set. These representative screening values were plugged into 

the correlation equation for connectors in Table 2-10 of the Protocol document to estimate the 

leak rate associated with that screening value. The fraction of OEL with screening values less 

than 500 ppm, but not zero, is not available from the NEIC monitoring data. Therefore, all OEL 

with screening values less than 500 ppm were represented with the default zero leak rate. 

Based on the industry-provided data, we estimated the initial leak frequency to be 

0.9 percent. We then scaled the fractions of OEL leaking in each interval above 500 ppm in the 

NEIC data such that the overall percent leaking was 0.9 percent. We multiplied each fraction by 

the corresponding leak rate for each concentration range to estimate weighted average leak rates 

and calculated the baseline emission estimate by summing those weighted leak rates. 

12
 

We chose the correlation equation for connectors rather than the equation for OEL 

because we expect that the openings through which VOC would be emitted around an 

improperly installed cap or plug would be more similar to the opening for a connector than to an 

uncapped open-ended line. We acknowledge that there are no directly applicable equipment leak 

correlations that were developed for capped OEL; however, our technical approach for 

estimating emissions from OEL is logical and provides a reasonably accurate estimate of OEL 

emissions. Depending on how poorly the upstream valve seats, it is quite reasonable that the 

plug acts exactly like a connector. We see two likely scenarios in which capped OEL will leak. 

One scenario is that the cap is poorly seated and offers minimal resistance to any process fluid 

that passes by the upstream valve. In this case, the emissions would be very similar to an 

uncapped OEL. The second scenario is that the cap is seated reasonably well and offers 

significant resistance to flow, but the upstream valve is not seated well. In this case, leaks would 

only occur when pressure builds in the line, and the emissions would parallel releases from inservice connectors. Thus, we believe that the actual emissions from improperly capped OEL will 

fall somewhere between those for uncapped OEL and connectors. 

We do not have equipment leak correlation equations for OEL for the SOCMI, but we do 

have equipment leak correlation equations for OEL for the petroleum refinery industry. For 

petroleum refineries, we estimated the baseline emissions for OEL using the uncapped OEL 

correlation equation and compared them to the baseline emission estimates generated using the 

correlation for connectors. The baseline emission estimates for petroleum refineries using the 

OEL correlation versus the connectors correlation were 3.24 Mg/yr (3.57 tons/yr) versus 

3.45 Mg/yr (3.80 tons/yr), respectively. These values, which are within 7 percent of each other, 

along with the likely scenarios for which OEL will leak, strongly suggest that the connectors 

correlation provides a reasonable proxy for estimating leaks from capped OEL. 

This comparison cannot be made directly for the SOCMI plants because no correlation 

equation exists for OEL. However, we reject the notion that the connectors correlation will overestimate capped OEL based on the leak factors provided in Table 2-5 of the Protocol document. 

In fact, using these correlations and the assumed distribution of leaks, application of Table 2-5 

emission factors actually predicts that emissions from OEL would be three times higher than for 

connectors. The emission factors developed for Table 2-5 presupposes a distribution of leak 

frequency and sizes for the “leakers” and “nonleakers” and that the distribution of leaks will be 

much different for capped OEL versus uncapped OEL. Therefore, we do not believe the 

emission factors presented in Table 2-5 are directly applicable for capped OEL; the correlation 

equations will provide a much better estimate because they directly account for the distribution 

of leaks. 

We acknowledge that the connectors correlation developed for SOCMI plants includes 

flanges, whereas the refinery correlation does not. To estimate the potential difference in the 

emission estimates for connectors versus flanges, we again used the petroleum refinery 

correlations with the projected leak size/frequency distribution developed for capped OEL. The 

baseline petroleum refinery emissions were 6.53 Mg/yr (7.20 tons/yr) when using the flanges 

correlation versus 3.45 Mg/yr (3.80 tons/yr) using the connectors correlation. This analysis 

indicates flanges at these screening levels have emissions levels nearly two times greater than 

connectors. Although there are more flanges than threaded connectors in service at SOCMI 

13
 

plants, threaded connectors leak more frequently than flanges. To assess how biased the SOCMI 

correlation may be for estimating leaks solely from threaded connectors, the relative number of 

threaded connectors to the number of flanges used to develop the correlation equation, not the 

number in service, is needed to estimate the potential bias. Based on the relative number of light 

liquid and gas service flanges and connectors used in developing the refinery correlations, there 

are twice as many leaking connectors as leaking flanges for which bagging data were collected. 

We anticipate that the SOCMI correlation will have a similar fraction of threaded connectors to 

flanges based on the higher frequency of leaks for threaded connectors. As such, we estimate 

that the use of the SOCMI correlation equation may over-estimate the emissions from OEL, 

which are nearly all threaded connectors, by 29 percent. Therefore, we divided the emission 

estimates by a factor of 1.29 to account for the potential bias in this estimate. Based on the 

analyses just described, we concluded that the using the equipment leak correlation for 

connectors provides a reasonable approach for estimating emissions from capped OEL. 

The number of times an OEL is opened in a year will have an impact on the effectiveness 

of monitoring at reducing emissions. The purpose of the OEL generally determines how many 

times it is opened during a year. As noted previously, Option 3 does not require monitoring of 

OEL used for sampling. These OEL may be opened as frequently as daily, and it is not practical 

to conduct monitoring and repair these OEL frequently enough to realize emission reductions 

(since the tightened cap or plug is likely to be removed the day after a repair). The remaining 

OEL are used mainly in intermittent service for purging, venting, and draining. Some of these 

OEL may be opened only once or twice a year, and others may be opened only when the process 

unit is being shut down. For this analysis, we assumed that one-third of the non-sampling OEL 

are opened once per quarter, one-third are opened once per year, and one-third are opened once 

every 2 years. These frequencies are referred to as opening scenarios throughout the rest of this 

memorandum. 

Another factor that will affect the emission reduction is the subsequent leak frequency for 

each monitoring event. Of all the OEL that are opened between monitoring events, we assumed 

that 0.9 percent (the same percentage as at baseline) will be leaking. We made this assumption 

because the subsequent leak frequency is due primarily to the care and technique of the operators 

installing the cap or other control equipment. Properly installed, there should be no leak. For 

this analysis, however, we assumed that operators would continue to install caps and other 

control equipment in the same manner that they currently use. This means that OEL that are 

opened between monitoring events will have the same leak frequency as at baseline, regardless 

of the number of times they are opened or the monitoring interval. Because OEL are monitored 

at the same frequency as the valves in a process unit, we assumed for this analysis that on 

average, monitoring is conducted semiannually. In this case, all OEL that are opened quarterly 

will be opened between monitoring events. Thus, the subsequent leak frequency for these OEL 

is 0.9 percent. On the other hand, only half of the OEL that are opened annually will be opened 

between monitoring events. Thus, the subsequent leak frequency for all OEL opened annually is 

one-half of the baseline level, or 0.45 percent. Finally, we assumed that OEL opened biennially 

are used only for startup and shutdown. Any initial leaks would be repaired the first time these 

OEL are monitored, and they would not leak again because they would not be opened until 

shutdown. Therefore, the assumed emission reduction is 100 percent and the subsequent leak 

14
 

frequency is 0 percent. These assumptions may overstate the actual subsequent leak frequencies, 

so the repair costs may be slightly overstated. 

The overall subsequent leak frequency for monitoring semiannually is calculated as a 

weighted average of the subsequent leak frequencies for the OEL that are opened quarterly, 

annually, and biannually. The weighting is based on the percent opened quarterly, annually, and 

biannually. The resulting overall subsequent leak frequency of the semiannual monitoring 

option is 0.45 percent. To estimate the percent reduction in emissions, we assumed that OEL are 

opened with an even distribution (e.g., if three OEL are opened in a quarter, one is opened 

halfway through each month). 

Semiannual monitoring will affect each opening scenario differently. For example, 

suppose semiannual monitoring occurs in January. The OEL that are opened quarterly would 

have been last opened in October, November, or December, and 0.9 percent of them are leaking. 

We assume that the monitoring event locates all the leaks and they are subsequently fixed. 

However, during the quarter, each of these OEL is opened, so by the end of March, 0.9 percent 

are leaking again. Until the next monitoring event in July of that year, an average 2.3 percent of 

these OEL will continue to leak (the actual OEL that are leaking may vary because a different 

mix of OEL may have the cap installed improperly the second time they are opened during the 

semiannual period). Therefore, in this case, emission reductions are only realized during the 

quarter in which the monitoring occurs, and we assumed an average reduction of 50 percent for 

that quarter (based on the assumption of an even distribution). This reasoning can be described 

by Equation 1, which we used to estimate the emission reductions for OEL that are opened more 

frequently than they are monitored. 

 PR = %100*

M

2

O M

1

M

M

M

⎟

⎟

⎟

⎟

⎠

⎞

⎜

⎜

⎜

⎜

⎝

⎛ −

− Equation 1 

where 

PR = percent reduction in emissions from baseline 

MM = number of months between monitoring events 

OM = number of months between times an OEL is opened 

Our analysis also includes OEL that are monitored more frequently than they are opened. 

For example, suppose a monitoring event occurs in April. The OEL that are opened annually are 

assumed to be distributed evenly throughout the year (i.e., one-twelfth are opened each month). 

Thus, in the semiannual period preceding the monitoring event, about half of these OEL would 

be opened. On average, those that are opened in the previous semiannual period would have 

been opened three months before the monitoring event. We assume that the monitoring event 

locates all of the leaks and they are subsequently fixed, and we assumed that they will not leak 

again until they are opened the following year. This means 9 months’ worth of emissions are 

prevented (for a 75 percent reduction). This reasoning can be described by Equation 2, which we 

15
 

used to estimate the emission reductions for OEL that are monitored more frequently than they 

are opened. 

 PR = %100*

O

M*5.0 1

M

M

⎟

⎟

⎠

⎞

⎜

⎜

⎝

⎛ − Equation 2 

where 

PR = percent reduction in emissions from baseline 

MM = number of months between monitoring events 

OM = number of months between times an OEL is opened 

Finally, we used the specific percent reduction values to calculate an average percent 

reduction, weighted by the percentage of OEL in each opening scenario. See Attachment I for 

the results of these calculations. 

C. Cost Analysis

The cost impacts analysis includes estimated initial costs and annual costs. The initial 

costs include costs for identifying and integrating open-ended lines into the monitoring program, 

initial monitoring, and repair of initial leakers. Annual costs include capital recovery for initial 

costs, periodic monitoring costs, costs to repair leaking equipment, and additional time to prepare 

semiannual reports.

Unit costs for initial setup and monitoring were assumed to be $17.70 per OEL, and unit 

costs for annual monitoring were assumed to be $1.50 per OEL; both of these are the same as for 

pumps and valves, as described in Section II.C. These costs were estimated only for OEL in 

gas/vapor or light liquid service that are not part of sampling connection systems because, as 

noted above, we assumed the monitoring requirements would apply only to those OEL. 

Repair costs were estimated assuming that 95 percent of the leaks can be repaired online 

in an average of 10 minutes by relatively simple techniques such as tightening the second valve, 

replacing a worn plug, or reinstalling a cap properly. We assumed that 5 percent of the leaks 

would need an offline repair requiring 4 hours to replace the second valve. The number of OEL 

needing repair was estimated based on the baseline and subsequent leak frequencies. Labor rates 

and overhead factors were assumed to be the same as described in Section II.C for the proposed 

changes in the leak definitions for pumps and valves. 

Capital recovery for initial costs was estimated using Equation 2.8a in the EPA Air 

Pollution Control Cost Manual,19 assuming an interest rate of 7 percent and a process life of 

15 years. One hour was added to the time to prepare each semiannual report. We expect that the 

additional reporting burden will be minimal because only the total number of leaks and the 

number for which repair is delayed would have to be reported. We also included a recovery 

credit for the material that is not emitted. As described in Section II.C, the credit is $900/Mg for 

emission reductions at SOCMI facilities. 

16
 

V. Alternate Leak Definition for Valves 

We estimated the incremental impacts of lowering the leak definition for valves from the 

500 ppm level in Option 1 to 100 ppm. The alternative applies to all 191 affected process units, 

73,000 gas valves, and 169,000 light liquid valves over the next five years. To determine the 

percent of valves leaking between 100 ppm and 500 ppm under Option 1, we started with the 

uncontrolled percentages in concentration ranges up to 500 ppm from Figures B-3-3 and B-3-4 

of the Protocol document and scaled them up based on the estimate for Option 1 that 

0.87 percent of valves have leak concentrations greater than 500 ppm. In the 100 to 500 ppm 

range, the uncontrolled leak frequencies of 3.9 percent and 2.5 percent were scaled up to 

4.47 percent and 2.71 percent for gas valves and light liquid valves, respectively. These are 

estimated average leak frequencies over a semiannual monitoring period. The overall 

distributions are presented in the “Percent of values in range” column of Set 4 of the emission 

estimate calculations shown in Attachment G. Multiplying these average leak frequencies by the 

total number of affected valves resulted in estimates that, on average, there would be 3,271 gas 

valves and 4,569 light liquid valves nationwide leaking between 100 and 500 ppm at any given 

time during the semiannual monitoring period. 

The baseline emission factors for valves with leak concentrations between 100 and 

500 ppm were estimated by using a screening value of 232 ppm in the SOCMI correlation 

equations for gas valves and light liquid valves. This representative screening value was 

estimated following the procedures described in Section II.A. We estimated the baseline 

emissions to be 28.5 tons/yr by multiplying these emission factors by the average number of 

valves leaking. 

We estimated a range of potential emission reductions for the option because data 

showing the subsequent leak frequency for an LDAR program with a leak definition of 100 ppm 

are unavailable. Under Option 1, the estimated reduction in the leak frequencies between 

500 and 10,000 ppm is about 95 to 97 percent. This is a reasonable proxy for the emission 

reduction because repaired valves are assumed to have emissions near zero. This is also the 

upper bound on reductions for repairing leaks between 100 and 500 ppm. One petroleum refiner, 

however, has observed that repairs of leaks in this range often make the emissions worse rather 

than better.32 Thus, the actual emissions reduction may be considerably less than 95 to 97 

percent. For the purposes of this analysis we assumed a reduction of 90 percent, so that the 

emission reductions are estimated to be no more than 25.7 tons/yr. 

There are two elements in the cost estimate: monitoring costs and repair costs. We 

calculated only the increase in repair costs because it is not clear what fraction of the process 

units would need to be monitored more frequently than under Option 1. Thus, this approach 

provides a lower bound on the incremental costs that is based on the assumption that the 

monitoring frequency will be the same for both this alternative and Option 1 for all process units. 

To estimate the repair cost, we first doubled the average leak frequencies to estimate the 

actual leak frequencies when semiannual monitoring is conducted. These values include the 

escalation due to the NEIC factor described in Section II.A. Thus, we divided the actual leak 

frequencies by 1.7 to estimate the subsequent leak frequencies that would be observed by 

monitoring crews in the field. We then calculated the number of leaking valves by multiplying 

17
 

the subsequent leak frequencies by the number of total valves and by 2 monitoring events per 

year. To estimate the repair costs, we used the same procedure that we used to estimate repair 

costs for Option 1 (see Attachment I). This procedure assumes that 75 percent of the valves can 

be repaired online in 10 minutes and 25 percent of the valves must be repaired offline, which 

takes 4 hours. Finally, we calculated the cost of monitoring to verify repair for each of the 

leaking valves. 

The resulting lower bound on the incremental cost associated with lowering the valve 

leak definition from 500 to 100 ppm is $150,000 per year. As noted above, the estimated 

maximum emission reduction is 25.7 tons/yr. Under these conditions, the cost-effectiveness of 

this alternative is $5,700 per ton of VOC. However, because the emission reductions are likely 

overstated and the monitoring costs are likely understated, the actual cost-effectiveness is likely 

significantly worse (i.e., it is likely that the cost to reduce 1 ton of VOC is much higher than 

$5,700). The calculations described in this section are summarized in Attachment K. Because 

this cost effectiveness value is high, we recommend not lowering the leak definition below the 

level in Option 1. 

VI. Results 

The results of the impacts analysis without and with recovery credits are summarized in 

Tables 4 and 5, respectively. Detailed results are also presented in Attachment M. Results of the 

emissions reductions and annual costs are shown for all seven scenarios. As discussed in 

Section II.C, there are no emissions reductions or increased costs for the process units already 

subject to any NESHAP that has requirements equivalent to the options presented in this 

memorandum. Only the impacts on 17 process units affect the cost-effectiveness result for 

Option 1, the impacts on 71 process units affect the cost-effectiveness result for Option 2, and 

the impacts on all 191 process units affect the cost-effectiveness result for Option 3. Without 

considering recovery credit, cost-effectiveness ranges from $430/ton of VOC reduced under 

Option 1 to $2,600/ton of VOC reduced under Option 3. Recovery credits lower each of these 

cost-effectiveness values by $800/ton. 

18
Table 1. Number of Affected Process Units and Equipment in the Three Models 

Model 

Number of: 

New units 

subject to 

HON/MON 

ethylene 

Reconstructed 

units 

subject to 

HON/ethylene 

Reconstructed 

units subject 

to 

MON 

New units at 

existing 

sources 

subject to 

MON 

Existing 

units 

subject to 

MON 

New 

units 

subject to 

NSPS 

Recon

un

subj

NS

Process units 

simple 37.5 23.3 1.7 10.0 6.7 12.1 medium 23.8 14.8 1.1 6.3 4.2 7.7 complex 10.8 6.7 0.5 2.9 1.9 3.5 total 72.1 44.8 3.2 19.2 12.8 23.2 

Pumps 

simple 562 350 25 150 100 181 medium 951 592 42 254 169 306 complex 605 377 27 162 108 195 total 2,118 1,318 94 566 377 682 

Gas valves simple 2,885 1,795 128 770 514 928 medium 9,844 6,125 438 2,629 1,752 3,168 complex 14,904 9,273 663 3,980 2,653 4,796 total 27,633 17,192 1,230 7,379 4,919 8,892 Light liquid valves 

simple 14,238 8,858 634 3,802 2,535 4,581 medium 28,034 17,442 1,248 7,486 4,991 9,021 complex 21,400 13,314 952 5,715 3,810 6,886 total 63,672 39,614 2,834 17,003 11,335 20,488 

Connectors 

simple 27,389 17,040 1,219 7,314 4,876 8,813 medium 63,296 39,380 2,817 16,903 11,268 20,367 complex 80,088 49,827 3,564 21,387 14,258 25,770 total 170,773 106,248 7,601 45,603 30,402 54,950 

19 
Table 2. Summary of Leak Frequency Valuesa

Monitoring Frequency Monthly Quarterly Semiannual Annual 

Component and Leak Definition Leak Frequency, percent 

Pumps 

10,000 ppm 0.23 0.64 

1,000 ppm 0.26 0.72 1.36 2.61 

Valves 

10,000 ppm 0.17 0.33 0.65 

1,000 ppm 0.23 0.44 0.85 

500 ppm 0.26 0.51 0.98 

Connectors 

Baseline 0.36 

500 ppm 0.36 

a

 Italic font indicates baseline leak frequencies used in this analysis 

 Bold font indicates subsequent leak frequencies used for Option 1 and Option 2. 

20 
Table 3. Parameters for Each of the SOCMI Scenarios 

Scenario New units 

subject to HON/MON ethylene 

Reconstructed units subject to HON/ethylene 

Reconstructed units (MON def.) subject to MON 

New units (GP def.) subject to MON 

Reconstructed units (GP def.) subject to MON 

New units subject to NSPS 

Leak definition: Pumps Valves Connectors 

1,000 500 500 

1,000 500 500 

1,000 500 500 

1,000 500 N/A 

1,000 500 N/A 

10,000 10,000 N/A 

Monitoring frequency: Pumps Valves Connectors 

Monthly Semiannual Every 4 yrs 

Monthly Semiannual Every 4 yrs 

Monthly Semiannual Every 4 yrs 

Monthly Semiannual N/A 

Monthly Semiannual N/A 

Monthly Annual N/A 

Initial leak frequency/ costs 

Yes – Program starts at set leak definitions; initial leak frequency is same as subsequent leak frequency 

No – Initial costs would have been incurred at construction or reconstruction 

No – Initial costs would have been incurred at construction or reconstruction 

Yes – Program starts at lower leak definitions; initial leak frequency is same as subsequent leak frequency 

No – Initial costs would have been incurred at construction or reconstruction 

Yes – Program starts at seleak definitionsinitial leak frequency same as subsequenleak frequency 

Planning and training costs 

340 hours per process unit 

340 hours per process unit 

340 hours per process unit 

320 hours per process unit 

320 hours per process unit 

320 hours per procesunit 

Baseline 

Administrative report costs 

300 hours per process unit 

300 hours per process unit 

300 hours per process unit 

250 hours per process unit 

250 hours per process unit 

250 hours per procesunit 

21 
Table 3. (Continued) 

Scenario New units Reconstructed Reconstructed New units Reconstructed New units 

subject to HON/MON ethylene 

units subject to HON/ethylene 

units (MON def.) subject to MON 

(GP def.) subject to MON 

units (GP def.) subject to MON 

subject to NSPS 

Leak definition: Pumps Valves Connectors 

1,000 500 500 

1,000 500 500 

1,000 500 500 

1,000 500 N/A 

1,000 500 N/A 

2,000a

500 N/A 

Monitoring frequency: Pumps Valves Connectors 

Monthly Semiannual Every 4 yrs 

Monthly Semiannual Every 4 yrs 

Monthly Semiannual Every 4 yrs 

Monthly Semiannual N/A 

Monthly Semiannual N/A 

Monthly SemiannuaN/A 

Initial leak frequency/ costs 

Yes – Program starts at set leak definitions; initial leak frequency is same as subsequent leak frequency 

No – Initial costs would have been incurred at construction or reconstruction 

No – Initial costs would have been incurred at construction or reconstruction 

Yes – Program starts at lower leak definitions; initial leak frequency is same as subsequent leak frequency 

No – Initial costs would have been incurred at construction or reconstruction 

Yes – Program starts at seleak definitionsinitial leak frequency same as subsequenleak frequency 

Planning and training costs 

340 hours per process unit 

340 hours per process unit 

340 hours per process unit 

320 hours per process unit 

320 hours per process unit 

320 hours per procesunit 

Option 1 

Administrative report costs 

300 hours per process unit 

300 hours per process unit 

300 hours per process unit 

250 hours per process unit 

250 hours per process unit 

250 hours per procesunit 

22
Table 3. (Continued) 

Scenario New units Reconstructed Reconstructed New units Reconstructed New units 

subject to HON/MON ethylene 

units subject to HON/ethylene 

units (MON def.) subject to MON 

(GP def.) subject to MON 

units (GP def.) subject to MON 

subject to NSPS 

Leak definition: Pumps Valves Connectors 

1,000 500 500 

1,000 500 500 

1,000 500 500 

1,000 500 500 

1,000 500 500 

2,000a

500 500 

Monitoring frequency: Pumps Valves Connectors 

Monthly Semiannual Every 4 yrs 

Monthly Semiannual Every 4 yrs 

Monthly Semiannual Every 4 yrs 

Monthly Semiannual Every 4 yrs 

Monthly Semiannual Every 4 yrs 

Monthly SemiannuaEvery 4 yr

Initial leak frequency/ costs 

Yes – Program starts at set leak definitions; initial leak frequency is same as subsequent leak frequency 

No – Initial costs would have been incurred at construction or reconstruction 

No – Initial costs would have been incurred at construction or reconstruction 

Yes – Program starts at lower leak definitions; initial leak frequency is same as subsequent leak frequency 

Partial – Only includes initial costs for adding connectors to program 

Yes – Program starts at seleak definitionsinitial leak frequency same as subsequenleak frequency 

Planning and training costs 

340 hours per process unit 

340 hours per process unit 

340 hours per process unit 

340 hours per process unit 

340 hours per process unit 

340 hours per procesunit 

Option 2 

Administrative report costs 

300 hours per process unit 

300 hours per process unit 

300 hours per process unit 

300 hours per process unit 

300 hours per process unit 

300 hours per procesunit 

a Cost analysis performed with pump leak definition of 1,000 ppm; see Section II.C of this memorandum.

23
Table 4. Summary of Impacts for the SOCMI Not Including Recovery Creditsa

Factor 

New units subject to HON/ ethylene 

Reconstructed units subject to HON/ ethylene 

Reconstructed units (MON def.) subject to MON 

New units (GP def.) subject to MON 

Reconstructed units (GP def.) subject to MON 

New units subject to NSPS 

Baseline costs, $/yrb 2,900,000 1,300,000 110,000 580,000 300,000 680,000 

Emission reduction, 

tons/yr 0 0 0 0 0 56 

Option 1 costs, $/yrc 2,900,000 1,300,000 110,000 580,000 300,000 690,000 Annual cost beyond 

baseline, $/yr 0 0 0 0 0 12,000 

OPTION 1 

Cost effectiveness, 

$/ton removed N/A N/A N/A N/A N/A 210 

Emission reduction, 

tons/yr 0 0 0 64 43 130 

Option 2 costs, $/yrc 2,900,000 1,300,000 110,000 790,000 440,000 950,000 Annual cost beyond 

baseline, $/yr 0 0 0 210,000 140,000 270,000 

OPTION 2 

Cost effectiveness, 

$/ton removed N/A N/A N/A 3,300 3,300 2,000 

Emission reduction, 

tons/yr 

Option 3 costs, $/yrc Annual cost beyond 

baseline, $/yr 

OPTION 3 

Cost effectiveness, 

$/ton removed 

a Costs and emission reductions may not sum exactly due to rounding. b Costs are only ongoing costs for pumps and valves. c Costs are only ongoing costs for pumps, valves, connectors, and OEL (if applicable); initial repair costs for pumps, valves, and connec

for planning and training to implement the Option requirements. 

24 
Table 5. Summary of Impacts for the SOCMI Including Recovery Creditsa

Factor 

New units subject to HON/ ethylene 

Reconstructed units subject to HON/ ethylene 

Reconstructed units (MON def.) subject to MON 

New units (GP def.) subject to MON 

Reconstructed units (GP def.) subject to MON 

New units subject to NSPS 

Baseline costs, $/yrb 2,900,000 1,300,000 110,000 580,000 300,000 680,000 

Emission reduction, 

tons/yr 0 0 0 0 0 56 

Option 1 costs, $/yrc 2,900,000 1,300,000 110,000 580,000 300,000 650,000 Annual cost beyond 

baseline, $/yr 0 0 0 0 0 (34,000) 

OPTION 1 

Cost effectiveness, 

$/ton removed N/A N/A N/A N/A N/A (610) 

Emission reduction, 

tons/yr 0 0 0 64 43 130 

Option 2 costs, $/yrc 2,900,000 1,300,000 110,000 730,000 410,000 840,000 Annual cost beyond 

baseline, $/yr 0 0 0 160,000 110,000 160,000 

OPTION 2 

Cost effectiveness, 

$/ton removed N/A N/A N/A 2,500 2,500 1,200 

Emission reduction, 

tons/yr 

Option 3 costs, $/yrc Annual cost beyond 

baseline, $/yr 

OPTION 3 

Cost effectiveness, 

$/ton removed 

a Costs and emission reductions may not sum exactly due to rounding. b Costs are only ongoing costs for pumps and valves. c Costs are only ongoing costs for pumps, valves, connectors, and OEL (if applicable); initial repair costs for pumps, valves, and connec

for planning and training to implement the Option requirements. 

25
 

VII. References 

1. SRI Consulting. 2004. 2004 Directory of Chemical Manufacturers: United States. 

Menlo Park, CA: SRI Consulting. 

2. The Congress of the United States, Congressional Budget Office. January 2000. The 

Budget and Economic Outlook: Fiscal Years 2001-2010. 

 

3. The Congress of the United States, Congressional Budget Office. January 2006. The 

Budget and Economic Outlook: Fiscal Years 2007-2016. 

4. U. S. Department of Energy, Energy Information Administration. July 2005. “World 

Energy and Economic Outlook.” International Energy Outlook 2005. DOE/EIA0484(2005). http://www.eia.doe.gov/oiaf/archive/ieo05/pdf/0484(2005).pdf. 

5. U.S. Environmental Protection Agency. 2002 National Emission Inventory (NEI), Final 

Version 1. February 2006. http://www.epa.gov/ttn/chief/net/2002inventory.html. 

 

6. U.S. Environmental Protection Agency. Envirofacts Data Warehouse. 

http://www.epa.gov/enviro/. 

7. U. S. EPA, Office of Air Quality Planning and Standards. November 1992. Hazardous 

Air Pollutant Emissions from Process Vents in the Synthetic Organic Chemical 

Manufacturing Industry – Background Information for Proposed Standards, Volume 1C. 

EPA-453/D-92-016c. 

8. U. S. EPA, Office of Air Quality Planning and Standards. November 1980. VOC 

Fugitive Emissions in Synthetic Organic Chemicals Manufacturing Industry – 

Background Information for Proposed Standards. EPA-450/3-80-033a. 

9. Memorandum from R. Oommen, Eastern Research Group, to Randy McDonald, USEPA, 

OAQPS. June 1, 2006. Cost and Emission Reductions of Leakless Valves for HON 

Facilities. Docket Items EPA-HQ-OAR-2005-0475-0105 and EPA-HQ-OAR-2005-

0475-0105.1. 

10. Memorandum from K. Parrish, D. Randall, and J. Coburn, RTI International, to K. 

Rackley, EPA/SPPD. October 30, 2007. Final Impacts Analysis for Regulatory Options 

for Equipment Leaks of VOC in Petroleum Refineries. 

11. U. S. EPA, Office of Air Quality Planning and Standards. November 1995. Protocol for 

Equipment Leak Emission Estimates. EPA-453/R-95-017. 

12. American Petroleum Institute, Health and Environmental Affairs Department. November 

1997. Analysis of Refinery Screening Data. Prepared by Hal Taback Company. 

Publication Number 310. 

26 
13. Memorandum from D. Randall, RTI International, to K. Rackley, USEPA. October 30, 

2007. Statistical Analysis of Valve Leak Frequencies Obtained by Industry and EPA for 

Petroleum Refining Process Units.

14. Memorandum from D.J. Whitt, Radian, to D. Markwordt, EPA/CPB. June 5, 1991. 

Impacts from the Control of VHAP Emissions from Equipment Leaks in Non-SOCMI 

Process Units for HON. Docket No. A-90-20, Item No. II-B-7. 

15. Memorandum to Group IV Polymers and Resins Docket. December 2000. Responses to 

Comments. Docket No. A-92-45, Item No. IXc-C-1. 

16 . Memorandum from K. Barnett, EPA/OAQPS/ESD/OCG, to Group IV Polymers and 

Resins Docket A-92-45. December 2000. Final Analysis of Equipment Leak Program 

for PET Facilities Subject to the Group IV Polymers and Resins NESHAP. Docket No. 

A-92-45, Item No. IXc-B-1. 

17. Memorandum from K. Parrish to Docket File. March 27, 2006. 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. 

18. U.S. Department of Labor, Bureau of Labor Statistics. May 2006. Occupational 

Employment Statistics: May 2006 Employment and Wage Estimates. 

http://www.bls.gov/oes/home.htm. 

19. U.S. EPA, Office of Air Quality Planning and Standards. January 2002. EPA Air 

Pollution Control Cost Manual. Sixth Edition. EPA/452/B-02-001. 

20. Platts. March 14, 2006. Platts Solventswire. The McGraw Hill Companies, Volume 29, 

Issue 11. 

21. Platts. March 9, 2006. Platts Intermediateswire. The McGraw Hill Companies, Volume 

11, Issue 10. 

22. Memorandum from K. Meardon, Pacific Environmental Services, Inc., to J. Schaefer, 

EPA/OCG. May 4, 1998. “Attachment 7: Leak Detection and Repair Cost Derivatives.” 

In Equipment Leak Analysis for Amino and Phenolic Resins NESHAP. Docket No. A-92-

19, Item No. II-B-11. 

23. Memorandum from K. Meardon, Pacific Environmental Services, Inc., to Group IV 

Polymers and Resins Docket A-92-45. October 28, 1998. Equipment Leak Analysis for 

PET Facilities Subject to the Group IV Polymers and Resins NESHAP. Docket Item No. 

VIc-B-1. 

27
24. Memorandum from B. Shine, North State Engineering, Inc., and M. Icenhour and D. 

Randall, RTI International, to MON Project Files. May 5, 2003. Revised MACT Floor, 

Regulatory Alternatives, and Nationwide Impacts for Equipment Leaks at Chemical 

Manufacturing Facilities. Docket No. A-96-04, Item No. IV-B-3; also Docket Item 

EPA-HQ-OAR-2003-0121-0004. 

25. Elam, R.A. February 13, 2007. Public Comment submitted by the American Chemistry 

Council. Docket ID EPA-HQ-OAR-2006-0699-0066. 

26. Wilwerding, J. June 14, 2007. Refinery Plug Monitoring Data from the National 

Enforcement Investigations Center. Transmitted via email to Karen Rackley. 

27. Loukeris, C. November 28, 2006. Cap/Plug Monitoring Data from U.S. EPA Region 5. 

Transmitted via e-mail to Karen Rackley. 

28. Elam, R.A. August 8, 2007. Public Comment submitted by American Chemistry 

Council. Docket ID EPA-HQ-OAR-2006-0699-0075. 

29. Wesson, D.F. August 8, 2007. Public Comment submitted by Dow Chemical Company. 

Docket ID EPA-HQ-OAR-2006-0699-0076. 

30. U. S. EPA, Office of Air Quality Planning and Standards. April 1982. Fugitive Emission 

Sources of Organic Compounds – Additional Information on Emissions, Emission 

Reductions, and Costs. EPA-450/3-82-010. Page 3-4. 

 

31. U. S. EPA, Office of Air Quality Planning and Standards. April 1982. Fugitive Emission 

Sources of Organic Compounds – Additional Information on Emissions, Emission 

Reductions, and Costs. EPA-450/3-82-010. Page 3-7. 

32. Baker, S. October 17, 2005. Response to Questions on Enhanced Leak Detection and 

Repair (LDAR) Requirements from Shell. Transmitted via e-mail to Karen Rackley. 

Docket ID EPA-HQ-OAR-2006-0699-0024. 

28
Attachment A 

Major/Area Source Analysis 
Number 

Processes Company City State

Facility Designation

Process units 

at Area 

Source

Process units 

at Major 

Source Unknown Notes

2 A.E. Staley Manufacturing Company Duluth MN Area 2 0 0

11 Aceto Corporation Piscataway NJ Unknown 0 0 11 * Not i

2 Adisseo USA Inc. Institute WV Unknown 0 0 2

* not in part of 

1 Advanced Aromatics, L.P. Baytown TX Major 0 1 01 Agrium US Inc. Kenai AK Major 0 1 01 Agrium US Inc. Borger TX Major 0 1 0

10 Air Products and Chemicals, Inc. Pace FL Major 0 10 0

2 Air Products and Chemicals, Inc. Wichita KS Area 2 0 02 Air Products and Chemicals, Inc. Calvert City KY Major 0 2 01 Air Products and Chemicals, Inc. Geismar LA Area 1 0 04 Air Products and Chemicals, Inc. St. Gabriel LA Major 0 4 02 Air Products and Chemicals, Inc. Pasadena TX Major 0 2 01 Akzo Nobel Axis AL Major 0 1 02 Akzo Nobel Chicago IL Unknown 0 0 2 * Not i1 Akzo Nobel Pasadena TX Major 0 1 01 Albemarle Corporation Magnolia AR Major 0 1 03 Albemarle Corporation Orangeburg SC Major 0 3 01 American Acryl Pasadena TX Area 1 0 03 ANGUS Chemical Company Sterlington LA Major 0 3 05 Arch Chemicals, Inc. Brandenburg KY Major 0 5 01 Arch Chemicals, Inc. Lake Charles LA Major 0 1 01 Ashland Specialty Chemical Company Kenova WV Major 0 1 0

11 ATOFINA Chemicals, Inc. Riverview MI Major 0 11 0

1 ATOFINA Chemicals, Inc. Genesco NY Major 0 1 01 ATOFINA Chemicals, Inc. Beaumont TX Major 0 1 02 ATOFINA Chemicals, Inc. Houston TX Major 0 2 02 ATOFINA Petrochemicals, Inc. Port Arthur TX Major 0 2 01 Avecia Inc. Mount Pleasant TN Area 1 0 01 Baker Petrolite Corporation Taft LA Unknown 0 0 1 * May 1 Balchem Corporation Verona MO Major 0 1 02 BASF Corporation Gurnee IL Area 2 0 0

10 BASF Corporation Geismar LA Major 0 10 0

1 BASF Corporation Washington NJ Area 1 0 01 BASF Corporation Rensselaer NY Area 1 0 01 BASF Corporation Spartanburg SC Major 0 1 0

10 BASF Corporation Freeport TX Major 0 10 0

4 BASF Corporation Pasadena TX Major 0 4 01 BASF Corporation Chemicals Div Freeport TX Major 0 1 02 BASF Corporation Plastics and Fibers Div. Freeport TX Major 0 2 03 BASF FINA Petrochemicals LP Port Arthur TX Major 0 3 01 Bayer Chemicals Corporation Baytown TX Major 0 1 02 Bayer CropScience Institute WV Major 0 2 06 Bayer Polymers LLC Baytown TX Major 0 6 05 Bayer Polymers LLC New Martinsville WV Major 0 5 01 Bell Flavors & Fragrances Inc. Northbrook IL Area 1 0 0

Pct_Area 
Number 

Processes Company City State

Facility Designation

Process units 

at Area 

Source

Process units 

at Major 

Source Unknown Notes

1 Borden Chemical, Inc. Demopolis AL Area 1 0 01 Borden Chemical, Inc. Hope AR Area 1 0 01 Borden Chemical, Inc. Fremont CA Area 1 0 01 Borden Chemical, Inc. Louisville KY Area 1 0 01 Borden Chemical, Inc. Geismar LA Major 0 1 01 Borden Chemical, Inc. Missoula MT Area 1 0 02 Borden Chemical, Inc. Fayetteville NC Area 2 0 01 Borden Chemical, Inc. South Glens Falls NY Area 1 0 01 Borden Chemical, Inc. La Grande OR Area 1 0 01 Borden Chemical, Inc. Springfield OR Major 0 1 01 Borden Chemical, Inc. Baytown TX Unknown 0 0 1 * Not i1 Borden Chemical, Inc. Diboll TX Area 1 0 01 Borden Chemical, Inc. Sheboygan WI Major 0 1 02 BP America Inc. Decatur AL Major 0 2 02 BP America Inc. Joliet IL Major 0 2 01 BP America Inc. Whiting IN Area 1 0 04 BP America Inc. Lima OH Major 0 4 01 BP America Inc. Mount Pleasant SC Major 0 1 02 BP America Inc. Alvin TX Major 0 2 04 BP America Inc. Green Lake TX Major 0 4 02 BP America Inc. Pasadena TX Area 2 0 05 BP America Inc. Texas City TX Major 0 5 01 Buckman Laboratories, Inc. Cadet MO Area 1 0 01 Buffalo Color Corporation Buffalo NY Major 0 1 01 Cambrex Charles City, Inc. Charles City IA Major 0 1 01 Capital Resin Corporation Columbus OH Area 1 0 01 Carbide Industries Calvert City KY Major 0 1 01 Carbide Industries Louisville KY Area 1 0 0

* Code permit

1 Carbolabs, Inc. Bethany CT Unknown 0 0 1 * Not i1 Cargill Inc. Eddyville IA Major 0 1 01 Cedar Concepts Corp. Chicago IL Area 1 0 02 Celanese Acetate LLC Rock Hill SC Major 0 2 02 Celanese Acetate LLC Narrows VA Major 0 2 06 Celanese Ltd. Bay City TX Major 0 6 04 Celanese Ltd. Bishop TX Major 0 4 04 Celanese Ltd. Clear Lake TX Major 0 4 07 Celanese Ltd. Pampa TX Major 0 7 03 Celanese Ltd. Chemicals Division Bay City TX Major 0 3 01 Celanese Ltd. Chemicals Division Bishop TX Major 0 1 01 Celanese Ltd. Chemicals Division Pampa TX Major 0 1 01 CF Industries, Inc. Donaldsonville LA Major 0 1 01 Chattem Chemicals, Inc. Chattanoga TN Major 0 1 01 Chemical Products Technologies, LLC Cartersville GA Area 1 0 01 Chemtall, Inc Riceboro GA Major 0 1 02 Chevron Oronite Company LLC Belle Chasse LA Area 2 0 0

Pct_Area 
Number 

Processes Company City State

Facility Designation

Process units 

at Area 

Source

Process units 

at Major 

Source Unknown Notes

2 Chevron Phillips Chemical Company LP St. James LA Major 0 2 03 Chevron Phillips Chemical Company LP Pascagoula MS Major 0 3 02 Chevron Phillips Chemical Company LP Guayama PR Area 2 0 02 Chevron Phillips Chemical Company LP Baytown TX Major 0 2 05 Chevron Phillips Chemical Company LP Borger TX Major 0 5 03 Chevron Phillips Chemical Company LP Port Arthur TX Major 0 3 01 Chevron Phillips Chemical Company LP Sweeny TX Major 0 1 02 ChevronPhillips Chemical Company Baytown TX Major 0 2 01 ChevronPhillips Chemical Company Port Arthur TX Major 0 1 01 ChevronTexaco Corporation Richmond CA Major 0 1 0 SIC 291 Ciba Specialty Chemicals Corporation Suffolk VA Area 1 0 02 CITGO Petroleum Corporation Lemont IL Major 0 2 02 CITGO Petroleum Corporation Lake Charles LA Major 0 2 04 CITGO Petroleum Corporation Corpus Christi TX Major 0 4 01 Clariant Life Science Molecules (America) Inc. Elgin SC Major 0 1 01 Clearon Corp. Theodore AL Unknown 0 0 1 * Not i1 Coastal Chem, Inc. Cheyenne WY Major 0 1 01 Cognis Corporation Charlotte NC Major 0 1 02 Cognis Corporation Cincinnati OH Major 0 2 01 Concord Chemical Company, Inc. Camden NJ Area 1 0 0

* Not iinfo

1 ConocoPhillips Alliance LA Major 0 1 01 ConocoPhillips Borger TX Major 0 1 05 ConocoPhillips Sweeny TX Major 0 5 01 ConocoPhillips Refining Wood River IL Major 0 1 01 ConocoPhillips Refining Alliance LA Major 0 1 01 ConocoPhillips Refining Sweeny TX Major 0 1 02 Cos-Mar Company Carville LA Major 0 2 01 Cyanco Co. Winnemuca NV Area 1 0 03 CyPlus Corporation Theodore AL Major 0 3 02 Cyro Industries Waggaman LA Area 2 0 0 * Not i4 Cytec Industries Inc. Waggaman LA Major 0 4 01 Cytec Industries Inc. Mount Pleasant TN Area 1 0 01 D.B. Western, Inc. LaPorte TX Unknown 0 0 1 * Not i1 DAK Americas LLC Wilmington NC Major 0 1 03 Dakota Gasification Company Beulah ND Area 3 0 03 Degussa Corporation Theodore AL Major 0 3 01 Degussa Corporation Galena KS Area 1 0 01 Deltech Corporation Baton Rouge LA Major 0 1 01 Diaz Intermediates Corporation West Memphis AR Area 1 0 01 Dixie Chemical Company, Inc. Bayport TX Major 0 1 01 Dover Chemical Corporation Dover OH Area 1 0 01 Dow AgroSciences LLC Freeport TX Major 0 1 0

18 Dow Chemical U.S.A. Plaquemine LA Major 0 18 018 Dow Chemical U.S.A. Taft LA Major 0 18 0

Pct_Area 
Number 

Processes Company City State

Facility Designation

Process units 

at Area 

Source

Process units 

at Major 

Source Unknown Notes

12 Dow Chemical U.S.A. Midland MI Major 0 12 0

1 Dow Chemical U.S.A. Nashua NH Area 1 0 03 Dow Chemical U.S.A. Clear Lake TX Major 0 3 01 Dow Chemical U.S.A. Deer Park TX Major 0 1 0

32 Dow Chemical U.S.A. Freeport TX Major 0 32 0

2 Dow Chemical U.S.A. La Porte TX Major 0 2 05 Dow Chemical U.S.A. Oyster Creek TX Major 0 5 0

12 Dow Chemical U.S.A. Seadrift TX Major 0 12 019 Dow Chemical U.S.A. Texas City TX Major 0 19 0

3 Dow Chemical U.S.A. Institute WV Major 0 3 01 Dow Chemical U.S.A. South Charleston WV Major 0 1 01 Dow Corning Corporation Carrollton KY Major 0 1 01 Dow Corning Corporation Midland MI Major 0 1 02 DSM Chemicals North America, Inc. Augusta GA Major 0 2 01 DTE Energy Services River Rouge MI Major 0 1 01 DuPont Louisville KY Major 0 1 01 DuPont Wurtland KY Major 0 1 04 DuPont La Place LA Major 0 4 09 DuPont Deepwater NJ Major 0 9 01 DuPont Memphis TN Major 0 1 01 DuPont Old Hickory TN Major 0 1 05 DuPont Beaumont TX Major 0 5 01 DuPont Corpus Christi TX Major 0 1 02 DuPont Orange TX Major 0 2 01 DuPont Victoria TX Major 0 1 05 DuPont Belle WV Major 0 5 01 DuPont Parkersburg WV Major 0 1 03 DynaChem, Inc. Georgetown IL Major 0 3 01 Dynea USA, Inc. Andalusia AL Area 1 0 01 Dynea USA, Inc. Winnfield LA Major 0 1 01 Dynea USA, Inc. Moncure NC Area 1 0 01 Dynea USA, Inc. Toledo OH Area 1 0 01 Dynea USA, Inc. Springfield OR Area 1 0 03 Eagle-Picher Industries, Inc. Lenexa KS Unknown 0 0 3 * Not i

1 Eastman Longview TX Major 0 1 02 Eastman Chemical Company Columbia SC Major 0 2 0

28 Eastman Chemical Company Kingsport TN Major 0 28 020 Eastman Chemical Company Longview TX Major 0 20 0

1 Eastman Resins Inc. Pleasant Prairie WI Major 0 1 01 El Dorado Chemical Company Cherokee AL Area 1 0 01 El Paso Energy Partners, L.P. St. Helens OR Area 1 0 01 Equistar Chemicals, LP Clinton IA Major 0 1 01 Equistar Chemicals, LP Morris IL Major 0 1 01 Equistar Chemicals, LP Tuscola IL Area 1 0 01 Equistar Chemicals, LP Sulphur LA Major 0 1 05 Equistar Chemicals, LP Alvin TX Major 0 5 0

Pct_Area 
Number 

Processes Company City State

Facility Designation

Process units 

at Area 

Source

Process units 

at Major 

Source Unknown Notes

14 Equistar Chemicals, LP Bayport TX Major 0 14 0

6 Equistar Chemicals, LP Channelview TX Major 0 6 04 Equistar Chemicals, LP Corpus Christi TX Major 0 4 02 Equistar Chemicals, LP La Porte TX Major 0 2 0

17 ExxonMobil Chemical Company Baton Rouge LA Major 0 17 0

4 ExxonMobil Chemical Company Chalmette LA Major 0 4 0

11 ExxonMobil Chemical Company Baytown TX Major 0 11 0

5 ExxonMobil Chemical Company Beaumont TX Major 0 5 01 ExxonMobil Chemical Company Houston TX Major 0 1 01 Farmland Industries, Inc. Coffeyville KS Major 0 1 01 Farmland Industries, Inc. Lawrence KS Area 1 0 01 FBC Industries, Inc. Rochelle IL Area 1 0 05 Ferro Corporation Baton Rouge LA Major 0 5 02 Ferro Corporation Bridgeport NJ Major 0 2 04 First Chemical Corporation Pascagoula MS Major 0 4 02 First Chemical Corporation Baytown TX Area 2 0 08 Flint Hills Resources L.P. Corpus Christi TX Major 0 8 01 FMC Corporation Baltimore MD Major 0 1 01 FMC Corporation Bayport TX Major 0 1 02 Formosa Plastics Corporation, U.S.A. Baton Rouge LA Major 0 2 07 Formosa Plastics Corporation, U.S.A. Point Comfort TX Major 0 7 02 Frontier El Dorado Refining Company El Dorado KS Major 0 2 01 Gabriel Chemicals, L.L.C. Geismar LA Major 0 1 01 Gabriel Performance Products, L.L.C. Ashtabula OH Area 1 0 02 Gaylord Chemical Corporation Bogalusa LA Area 2 0 01 GE Company Mount Vernon IN Major 0 1 01 GE Specialty Chemicals Morgantown WV Area 1 0 02 Geismar Vinyls Company LP Geismar LA Major 0 2 01 General Electric Company Burkville AL Major 0 1 02 General Electric Company Mount Vernon IN Major 0 2 02 General Electric Company Selkirk NY Major 0 2 01 General Electric Company Waterford NY Major 0 1 01 General Electric Company GE Plastics Burkville AL Major 0 1 01 General Electric Company GE Plastics Mount Vernon IN Major 0 1 01 GEO Specialty Chemicals, Inc. Gibbstown NJ Major 0 1 01 GEO Specialty Chemicals, Inc. Allentown PA Major 0 1 01 Geoliquids, Inc. Prospect Heights IL Unknown 0 0 1 * Not i

2 Georgia Gulf Corporation Lake Charles LA Major 0 2 05 Georgia Gulf Corporation Plaquemine LA Major 0 5 04 Georgia Gulf Corporation Pasadena TX Major 0 4 01 Georgia-Pacific Resins, Inc. Crossett AR Major 0 1 01 Georgia-Pacific Resins, Inc. Vienna GA Area 1 0 01 Georgia-Pacific Resins, Inc. Grayling MI Major 0 1 01 Georgia-Pacific Resins, Inc. Louisville MS Major 0 1 01 Georgia-Pacific Resins, Inc. Taylorsville MS Major 0 1 01 Georgia-Pacific Resins, Inc. Conway NC Major 0 1 0

Pct_Area 
Number 

Processes Company City State

Facility Designation

Process units 

at Area 

Source

Process units 

at Major 

Source Unknown Notes

1 Georgia-Pacific Resins, Inc. Denton NC Area 1 0 01 Georgia-Pacific Resins, Inc. Columbus OH Area 1 0 01 Georgia-Pacific Resins, Inc. Albany OR Area 1 0 01 Georgia-Pacific Resins, Inc. White City OR Area 1 0 01 Georgia-Pacific Resins, Inc. Russellville SC Major 0 1 01 Georgia-Pacific Resins, Inc. Lufkin TX Major 0 1 04 GFS Chemicals, Inc. Columbus OH Area 4 0 01 Goodyear Tire & Rubber Company Pasadena TX Major 0 1 03 Great Lakes Chemical Corporation El Dorado AR Major 0 3 01 Hatco Corporation Fords NJ Major 0 1 02 Hawkins Chemical, Inc. Minneapolis MN Area 2 0 03 Heico Chemicals Delaware Water Gap PA Area 3 0 01 Henkel Corporation Atlanta GA Unknown 0 0 1 * Not i3 Hercules Incorporated Louisiana MO Major 0 3 03 Hercules Incorporated Hopewell VA Major 0 3 01 Honeywell International Inc. El Segundo CA Major 0 1 01 Honeywell International Inc. Baton Rouge LA Major 0 1 03 Honeywell International Inc. Hopewell VA Major 0 3 01 Honeywell Specialty Chemicals Baton Rouge LA Major 0 1 02 HOVENSA, L.L.C St. Croix VI Major 0 2 01 Huntsman LLC Pensacola FL Area 1 0 02 Huntsman LLC Geismar LA Major 0 2 01 Huntsman LLC Alvin TX Area 1 0 01 Huntsman LLC Conroe TX Major 0 1 01 Huntsman LLC Odessa TX Major 0 1 03 Huntsman LLC Port Arthur TX Major 0 3 0

13 Huntsman LLC Port Neches TX Major 0 13 0

1 IMC Phosphates Company Faustina LA Major 0 1 02 INDOFINE Chemical Company Somerville NJ Unknown 0 0 2 * Not i2 INDSPEC Chemical Corporation Petrolia PA Major 0 2 01 INEOS Oxide Plaquemine LA Major 0 1 02 Ineos Phenol Theodore AL Major 0 2 02 Infineum U.S.A LP Linden NJ Major 0 2 01 Inolex Chemical Company Hopewell VA Unknown 0 0 1 * Not i1 International Flavors & Fragrances, Inc. Jacksonville FL Area 1 0 01 Intertrade Holdings, Inc. Copperhill TN Area 1 0 05 INVISTA Inc. Orange TX Major 0 5 06 INVISTA Inc. Victoria TX Major 0 6 01 J.R. Simplot Co. Pocatello ID Major 0 1 02 Jarchem Industries Inc. Newark NJ Unknown 0 0 2 * Not i1 Javelina Company Corpus Christi TX Area 1 0 0 * Not i5 JLM Chemicals, Inc. Blue Island IL Major 0 5 02 Johnson Matthey, Inc. Ward Hill MA Area 2 0 01 Kao Specialties Americas LLC High Point NC Major 0 1 0

Pct_Area 
Number 

Processes Company City State

Facility Designation

Process units 

at Area 

Source

Process units 

at Major 

Source Unknown Notes

1 Kincaid Enterprises Inc. Nitro WV Area 1 0 0

* Not iinfo

1 Koch Nitrogen Company Fort Dodge IA Major 0 1 01 Koch Nitrogen Company Dodge City KS Area 1 0 01 Koch Nitrogen Company Beatrice NE Major 0 1 01 Koch Nitrogen Company Enid OK Major 0 1 01 Koppers Inc. Cicero IL Major 0 1 03 KoSa Wilmington NC Major 0 3 01 Lomac, LLC Muskegon MI Major 0 1 04 Lonza Inc. Bayport TX Major 0 4 02 Lucite International, Inc. Memphis TN Major 0 2 02 Lucite International, Inc. Beaumont TX Major 0 2 01 Lucite International, Inc. Belle WV Unknown 0 0 1

* not in DuPon

2 Lyondell Chemical Company Lake Charles LA Major 0 2 05 Lyondell Chemical Company Bayport TX Major 0 5 03 Lyondell Chemical Company Channelview TX Major 0 3 01 Lyondell Methanol Company, LP Channelview TX Major 0 1 04 Lyondell-Citgo Refining, LP Houston TX Major 0 4 01 MAK Chemical Corporation Muncie IN Area 1 0 02 Mallinckrodt Baker, Inc. Phillipsburg NJ Major 0 2 05 Mallinckrodt Inc. St. Louis MO Major 0 5 01 Mallinckrodt Inc. Raleigh NC Major 0 1 03 Marathon Ashland Petroleum LLC Catlettsburg KY Major 0 3 02 Marathon Ashland Petroleum LLC Texas City TX Major 0 2 01 MDA Manufacturing, Inc. Decatur AL Area 1 0 02 Merisol Antioxidants LLC Oil City PA Area 2 0 07 Merisol USA LLC Houston TX Major 0 7 03 Millennium Petrochemicals, Inc. La Porte TX Major 0 3 01 MissChem Nitrogen, L.L.C. Yazoo City MS Major 0 1 01 Monsanto Company Muscatine IA Major 0 1 01 Monsanto Company Luling LA Major 0 1 02 Morflex, Inc. Greensboro NC Major 0 2 02 Motiva Enterprises LLC Delaware City DE Major 0 2 01 Nation Ford Chemical Co. Fort Mill SC Major 0 1 02 Nepera, Inc. Harriman NY Major 0 2 02 Niacet Corporation Niagara Falls NY Area 2 0 03 NOVA Chemicals Corp. Bayport TX Area 3 0 01 Noveon Inc. Charlotte NC Major 0 1 03 Noveon Inc. Cincinnati OH Area 3 0 07 Noveon Inc. Kalama WA Major 0 7 01 Occidental Chemical Corporation Convent LA Major 0 1 03 Occidental Chemical Corporation Niagara Falls NY Major 0 3 01 Occidental Chemical Corporation Corpus Christi TX Major 0 1 03 Old World Industries, Inc. Pasadena TX Major 0 3 01 ONDEO Nalco Chemical Company Garyville LA Major 0 1 0

Pct_Area 
Number 

Processes Company City State

Facility Designation

Process units 

at Area 

Source

Process units 

at Major 

Source Unknown Notes

2 Oxymar Ingleside TX Unknown 0 0 2 * Not i2 OxyVinyls LP Deer Park TX Major 0 2 02 OxyVinyls LP La Porte TX Major 0 2 01 PCS Nitrogen Fertilizer, L.P. Augusta GA Major 0 1 01 PCS Nitrogen Fertilizer, L.P. Geismar LA Major 0 1 01 PCS Nitrogen Fertilizer, L.P. Woodstock TN Major 0 1 01 PCS Nitrogen Ohio, L.P. Lima OH Major 0 1 04 PD Glycol Beaumont TX Major 0 4 01 Pelron Corporation Lyons IL Area 1 0 01 Penn Carbose, Inc. Somerset PA Area 1 0 0 * Not i7 Penta Manufacturing Company East Hanover NJ Unknown 0 0 7 * Not i8 Penta Manufacturing Company Fairfield NJ Unknown 0 0 8 * Not i8 Penta Manufacturing Company Livingston NJ Area 8 0 0

* Not iinfo

3 Perstorp Polyols, Inc. Toledo OH Area 3 0 01 Pfizer Inc. Groton CT Major 0 1 01 Pfizer Inc. Chemical Division Holland MI Major 0 1 01 PHH Monomers Lake Charles LA Unknown 0 0 1 * Not i1 Phillips Puerto Rico Core Inc. Guayama PR Area 1 0 03 PMC Specialties Group, Inc. Chicago IL Unknown 0 0 3 * Not i3 PMC Specialties Group, Inc. Cincinnati OH Major 0 3 06 PPG Industries, Inc. Lake Charles LA Major 0 6 01 PPG Industries, Inc. Barberton OH Major 0 1 01 PPG Industries, Inc. La Porte TX Major 0 1 04 PPG Industries, Inc. Natrium WV Major 0 4 03 Praxair, Inc. Geismar LA Area 3 0 01 Primester Kingsport TN Unknown 0 0 1 * Not i1 Quaker Foods & Beverages Cedar Rapids IA Major 0 1 01 Quest International Mount Olive NJ Area 1 0 02 R.S.A. Corporation Danbury CT Area 2 0 02 Reilly Industries, Inc. Indianapolis IN Area 2 0 02 Resolution Performance Products LLC Norco LA Major 0 2 01 Resolution Performance Products LLC Deer Park TX Major 0 1 01 Rhodia Inc. Baton Rouge LA Major 0 1 01 Rohm and Haas Company Philadelphia PA Major 0 1 08 Rohm and Haas Company Deer Park TX Major 0 8 01 Royster-Clark Inc. East Dubuque IL Major 0 1 04 Rubicon, Inc. Geismar LA Major 0 4 02 RUTGERS Organics Corporation Harrison OH Area 2 0 01 RUTGERS Organics Corporation State College PA Area 1 0 01 Sabina Petrochemicals LLC Port Arthur TX Major 0 1 05 Sasol North America Inc. Westlake LA Major 0 5 01 Sasol North America Inc. Baltimore MD Major 0 1 02 Schenectady International Rotterdam Junction NY Major 0 2 06 Schenectady International, Inc. Freeport TX Major 0 6 0

Pct_Area 
Number 

Processes Company City State

Facility Designation

Process units 

at Area 

Source

Process units 

at Major 

Source Unknown Notes

8 Shell Chemical Company Geismar LA Major 0 8 05 Shell Chemical Company Norco LA Major 0 5 0

13 Shell Chemical Company Deer Park TX Major 0 13 0

1 Shell Oil Products US Anacortes WA Major 0 1 01 Shenango Incorporated Pittsburg PA Major 0 1 01 Sloss Industries Corporation Birmingham AL Area 1 0 01 Solutia Inc. Anniston AL Area 1 0 03 Solutia Inc. Decatur AL Major 0 3 03 Solutia Inc. Pensacola FL Major 0 3 07 Solutia Inc. Sauget IL Major 0 7 01 Solutia Inc. Springfield MA Major 0 1 01 Solutia Inc. Trenton MI Major 0 1 04 Solutia Inc. Alvin TX Major 0 4 01 Solvay Solexis, Inc. Thorofare NJ Area 1 0 01 South Hampton Refining Co. Silsbee TX Major 0 1 01 Stepan Company Millsdale IL Major 0 1 08 Sterling Chemicals, Inc. Texas City TX Major 0 8 01 Sunoco, Inc. Claymont DE Major 0 1 03 Sunoco, Inc. Westville NJ Major 0 3 06 Sunoco, Inc. Haverhill OH Major 0 6 04 Sunoco, Inc. Toledo OH Area 4 0 04 Sunoco, Inc. Marcus Hook PA Major 0 4 01 Sunoco, Inc. Neville Island PA Major 0 1 05 Sunoco, Inc. Philadelphia PA Major 0 5 01 Symrise Inc. Aroma Chemical Division Bushy Park SC Area 1 0 01 Syngenta Crop Protection Cold Creek AL Major 0 1 02 Syngenta Crop Protection St. Gabriel LA Major 0 2 01 Terra Industries Inc. Sergeant Bluff IA Major 0 1 02 Terra Industries Inc. Woodward OK Major 0 2 01 Terra Industries Inc. Beaumont TX Major 0 1 01 Terra Nitrogen, Limited Partnership Blytheville AR Major 0 1 01 Terra Nitrogen, Limited Partnership Verdigris OK Major 0 1 04 Texas Petrochemicals LP Houston TX Major 0 4 01 Texmark Chemicals, Inc. Galena Park TX Major 0 1 01 The Goodyear Tire & Rubber Company Beaumont TX Major 0 1 01 The Goodyear Tire & Rubber Company Pasadena TX Major 0 1 01 The Lubrizol Corporation Deer Park TX Major 0 1 02 The Premcor Refining Group Inc. Lima OH Major 0 2 02 The Procter & Gamble Company Sacramento CA Major 0 2 01 The Williams Companies, Inc. Geismar LA Major 0 1 01 Triad Nitrogen, L.L.C. Donaldsonville LA Area 1 0 01 Twin Lake Chemicals Inc. Lockport NY Area 1 0 0 * Not i6 U.S. Amines Ltd. Bucks AL Major 0 6 01 U.S. Army Holston Army Ammunition Plant Kingsport TN Major 0 1 01 Unitex Chemical Corporation Greensboro NC Major 0 1 0

Pct_Area 
Number 

Processes Company City State

Facility Designation

Process units 

at Area 

Source

Process units 

at Major 

Source Unknown Notes

2 Valero Energy Corporation Corpus Christi TX Major 0 2 02 Valero Energy Corporation Three Rivers TX Major 0 2 01 VanDeMark, Inc. Lockport NY Major 0 1 03 Velsicol Chemical Corporation Chattanooga TN Major 0 3 01 Vulcan Chloralkali LLC Geismar LA Major 0 1 04 Vulcan Materials Company Wichita KS Major 0 4 06 Vulcan Materials Company Geismar LA Major 0 6 02 Westlake Monomers Corporation Calvert City KY Major 0 2 01 Westlake Petrochemicals Corporation Sulphur LA Major 0 1 02 Westlake Styrene Corporation Sulphur LA Area 2 0 01 Westlake Vinyls, Inc. Calvert City KY Major 0 1 02 Wright Chemical Corporation Riegelwood NC Major 0 2 0

Calculation of Percentage of Process Units at Area SorucesDesignation Major Area TotalNumber Facilities 303 91 394Percent of Facilities 76.9% 23.1%Number of Processes 916 134 1050Percent of Processes 87.2% 12.8%

Pct_Area 
Attachment B 

Scenario Determination 
Process units in 

VOC service

191

Units manufacturing 

HON compounds

132

Units manufacturing 

MON compounds

59

Area Source

20

Major Source

112

Units 

emitting 

HAP

40

Units 

emitting nonHAP VOC

10

(4) New

(GP)

19

(6) New

5.3

(3) Reconstructed

(MON)

3.2

(7) Reconstructed

3.5

Determination of process units subject to SOCMI regulations. The numbers in bold at the bottom of each box indicate the numbers 

of process units described by the text in that box. The numbers in italics and parentheses in the bottom rows indicate the scenario 

and regulation to which those process units are subject; the boxes marked (6) and (7) represent the process units impacted by 

amendments to subpart VV.

(6) New

12

(7) Reconstructed

7.9

(1) New

67

(2) Reconstructed

45

Major Source

50

Area Source

8.8

(6) New

6.0

(7) Reconstructed

4.0

(1) New

(MON)

4.8

(5) Reconstructed

(GP)

13

B-1
Attachment C 

Model Details 
Models

Type of Component

simple medium complex

Pump Seals

 * Light-liquid service 15 40 56

 * Heavy-liquid service 0 5 36

Valves

 * Gas/vapor service 77 414 1,379

 * Light-liquid service 380 1,179 1,980

 * Heavy-liquid service 0 71 1,272

Connectors

 * Flanges - gas/vapor

 * Flanges - light liquid 731 2,662 7,410

 * Flanges -heavy liquid

Pressure Relief Devices

 * Disks 2 45 76

 * Disk holders, valves,etc. 2 45 76

Open-ended Valves 33 141 424

Sampling Connections 8 35 106

Compressor Vent 028

Replacement Pump Seals 15 40 56

Number of Components

Models C-1
Attachment D 

Data from the HON Residual Risk Analysis 
Data from the HON Residual Risk Analysis

Gas valve Percent leakers

LL valve percent leakers

Avg (50/50) split

weighted by

number of 

valves

17 227,88 160,660 6 15,146 2.79 2.57 2.68 0.21 

74 209,890 112,081 45,931 0.58 0.50 0.54 0.13 

235 57,14 47,030 4 12,676 0.93 0.82 0.88 0.06 

163 42,121 26,073 3,023 2.26 2.07 2.16 0.03 116 13,953 11,037 6,658 0.37 0.30 0.34 0.01 

183 15,75 10,41 5 6,357 4 0.37 0.30 0.33 0.01 

112 13,398 9,620 15,513 0.09 0.04 0.07 0.01 

30 13,726 8,496 4,643 0.42 0.35 0.38 0.01 

107 13,091 8,06 11,03 4 0.12 0.07 0.10 0.01 4 

27 12,281 7,823 8,596 0.17 0.12 0.14 0.01 

78 10,628 6,515 17,547 0.02 -0.02 0.00 0.00 

197 10,89 4,837 5 7,741 0.09 0.04 0.07 0.00 

80 5,780 3,901 7,45 0.06 0.02 0.04 0.00 4 

114 5,730 3,638 5,512 0.10 0.05 0.08 0.00 

168 6,401 3,373 4,160 0.14 0.09 0.12 0.00 

51 5,670 2,999 3,347 0.17 0.11 0.14 0.00 

26 3,175 2,359 145 4.32 4.01 4.17 0.00 

24 2,00 1,755 4 332 1.35 1.22 1.29 0.00 

9 3,608 1,692 331 1.31 1.18 1.24 0.00 

68 1,100 681 4,03 -0.03 -0.07 -0.05 0.00 4 

179 5,30 333 4 135 0.59 0.51 0.55 0.00 

90 509 288 1,111 -0.01 -0.05 -0.03 0.00 

29 461 244 4,54 -0.06 -0.10 -0.08 0.00 4 

228 213 138 434 0.01 -0.03 -0.01 0.00 

81 279 137 1,463 -0.05 -0.09 -0.07 0.00 

255 30 17 1,09 -0.07 -0.11 -0.09 0.00 4 

 188,961 434,206 0.54 0.47 0.58 0.51 

0.51

Shaded rows indicate where actual counts were used from NOCs reports. 18Source: Memorandum from R. Oommen, Eastern Research Group, to Randy McDonald, USEPA, OAQPS. June 1, 2006. Cost and 

Leakless Valves for HON Facilities. Docket Items EPA-HQ-OAR-2005-0475-0105 and EPA-HQ-OAR-2005-0475-0105.

HON ID

 Total Equipment 

HAP Emissions 

(kg/yr) 

 Total Valve 

HAP 

Emissions 

(kg/yr) 

 Number 

of Valves 

HON RR data 
Attachment E 

Leak Frequencies and Emission Factors 
SOCMI Leak Frequencies and Emission factors

500 1,000 10,000 500 1,000 10,00

Equipment OptionGas Valves Baseline 0.33 0.00035

Option 1, Initial (NSPS)a 6.9

Option 1, Subsequent 0.51 0.000203

Light Liquid Valves Baseline 0.33 0.00039

Option 1, Initial (NSPS)a 4.5Option 1, Subsequent 0.51 0.000232

Light Liquid Pumps Baseline 0.23 0.00251

Option 1, Initial (NSPS)a 15.2

Option 1, Subsequent 0.26 0.00069

Connectors Baseline (no control) 0.36 0.000307

Option 2 0.36 0.000162

a Initial leak frequencies calculated to determine repair costs the first time lower leak definition is required. Emissions estimates 

 program are calculated using subsequent leak frequencies.

Derivation of SOCMI leak frequencies from Refinery leak frequencies

Equipment Option Refinery 

Leak 

Frequency, 

%a,b

SOCMI Leak 

Frequency, 

%

Basis for SOCMI Leak Frequency

Gas Valves and Light Liquid Valves Baseline 1.28 0.33

Option 1, Subsequent 1.94e 0.51

Light Liquid Pumps Baseline 0.88 0.23

Option 1, Subsequent 0.98e 0.26

a From 1997 API report Analysis of Refinery Screening Datab From Data and Assumptions used in the Final Equipment Leaks Cost Analysis for Petroleum Refineries.c From Enforcement Alert: Proper Monitoring Essential to Reducing 'Fugitive Emissions' Under Leak Detection and Repair Progrd From Cost and Emission Reductions of Leakless Valves for HON Facilities.e Original data are for LDAR programs with leak definitions of 1,000 ppm and quarterly monitoring for both pumps and valves; le

 pumps presented in this table adjusted to monthly monitoring.

Baseline-to-controlled refinery pump leak frequencyc 

Option 1 pump leak frequency(0.88/0.98 * 0.26 = 0.23)Pump-to-valve refinery leak frequency applied to Opfrequency(0.98/3.78 * 0.98 = 0.26)

Leak Definition (ppm)

Leak Frequencies, % Emission Factor, kg/hr/component

Baseline-to-controlled refinery valve leak frequencyc 

Option 1 leak frequency (all values converted to sem(1.28/1.94 * 0.51 = 0.33)Average of data from HON sourcesd

Final Estimates 
Attachment F 

Emission Estimate Inputs 
Emissions data in Protocol document

Component Monitoring Leak Leak Average Final leak Emission

frequency definition, frequency, leak rate rate,

ppm % fraction, % (kg/hr) kg/hr/componenta

Gas valve Quarterly 10,000 3.80 2.33 0.00195 0.00195

Annually 10,000 2.00 1.23 0.00109

Monthly 500 2.0 1.0 0.00046

Quarterly 500 1.5 0.75 0.00035

Semiannually 500 0.75 0.375 0.00018

Annually 500 0.5 0.25 0.00013

Liquid valve Quarterly 10,000 2.61 1.60 0.00159 0.00159

Annually 10,000 2.00 1.23 0.00126

Monthly 500 2.0 1.0 0.00050

Quarterly 500 1.5 0.75 0.00038

Semiannually 500 0.75 0.375 0.00020

Annually 500 0.5 0.25 0.00014

Pump Monthly 10,000 3.53 1.77 0.00613 0.00615

Monthly 1,000 8.04 4.02 0.00488

Gas connector None 500 3.9 3.9 0.00180

Annually 500 0.50 0.25 0.00013 0.000130

Liquid connector None 500 3.9 3.9 0.00180

Annually 500 0.50 0.25 0.00013 0.000130

a

Using ALR equations from the November 1995 Protocol document (ALR = X*LKFRAC + Y)

TABLE 5-4. EQUATIONS RELATING AVERAGE LEAK RATE TO FRACTION LEAKING AT SOCMI UNITS

Equipment Leak Definition X Y

Gas Valve 500 0.044 1.7E-05

1000 0.05 2.8E-05

2000 0.057 4.3E-05

5000 0.068 8.1E-05

10000 0.078 1.3E-04

Light liquid valve 500 0.047 2.7E-05

1000 0.053 3.9E-05

2000 0.061 5.9E-05

5000 0.077 1.1E-04

10000 0.089 1.7E-04

Pump 500 0.095 3.1E-04

1000 0.11 4.6E-04

2000 0.13 6.7E-04

5000 0.20 1.4E-03

10000 0.24 1.9E-03

Connector 500 0.047 1.7E-05

1000 0.060 2.5E-05

2000 0.073 3.5E-05

5000 0.092 5.4E-05

10000 0.11 8.1E-05

Equation is (ALR = X*LKFRAC + Y)

Inputs F-1
TABLE G-1. DETERMINATION OF LDAR CONTROL EFFECTIVENESS AT SOCMI PROCESS UNITS

Equipment 

type

Control 

program

Leak definition 

(ppmv)

Initial leak 

fraction 

(percent)

Initial leak 

rate (kg/hr)

Immediately 

after LDAR 

monit.

Immediately 

prior to LDAR 

monit. Cycle average

Final leak 

rate (kg/hr)

LDAR control 

effectiveness 

(percent)

LL Valves Monthly 10000 4.3 0.0040 0.20 0.88 0.54 0.00064 84

Quarterly 10000 4.3 0.0040 0.59 2.61 1.60 0.00159 61

HON reg neg 500 8.5 0.0040 0.00 2.00 1.00 0.00050 88

Gas Valves Monthly 10000 7.5 0.0060 0.29 1.29 0.79 0.00075 87

Quarterly 10000 7.5 0.0060 0.86 3.80 2.33 0.00195 67

HON reg neg 500 13.6 0.0060 0.00 2.00 1.00 0.00045 92

LL Pumps Monthly 10000 7.5 0.0199 0.00 3.53 1.77 0.00613 69

Quarterly 10000 7.5 0.0199 0.00 7.50 3.75 0.01092 45

HON reg neg 1000 17.1 0.0199 0.00 8.04 4.02 0.00501 75

Connectors HON reg neg 500 3.9 0.0018 0.00 0.50 0.25 0.00013 93

Table 2-9. SOCMI Leak Rate/Screening Value Correlations

Table 2-11. Default-Zero Values: SOCMI Process Units

Table 2-13. 10,000 ppmv and 100,000 ppmv Screening Value Pegged Emission Rates for SOCMI Process Units

Equipment

Default-zero 

emission rate 

(kg/hr/ 

component) X Y

10,000 ppmv 

pegged 

emission rate 

(kg/hr/ 

component)

100,000 ppmv 

pegged 

emission rate 

(kg/hr/ 

component)

Gas Valves 6.60E-07 1.87E-06 0.873 0.024 0.11

LL Valves 4.90E-07 6.41E-06 0.797 0.036 0.15

LL Pumps 7.50E-06 1.90E-05 0.824 0.14 0.62

Connectors 6.10E-07 3.05E-06 0.885 0.044 0.22

Equation is Leak rate (kg/hr) = X * (SV)^Y, SV = screening value in ppmv

Inputs F-2
MON data

Component Monitoring Leak Leak Average Emission

frequency definition, frequencya leak rate,

ppm fraction, %b kg/hr/componentc

Gas valve annually 10,000 0.323 0.162 0.000256

semiannually 500 0.582 0.291 0.000145

Liquid valve annually 10,000 0.193 0.097 0.000256

semiannually 500 0.502 0.251 0.000145

Pump monthly 10,000 3.150 1.575 0.00568

monthly 1,000 6.073 3.036 0.00380

Connector none 500 0.360 0.360 0.000186

every 4 yrs 500 0.360 0.180 0.0001016

a Assumed leak frequency at end of monitoring period equals twice the average leak fraction, except for connectors at baseline where the absence

 of an LDAR program means the leak fraction doesn't vary over the year.

b Leak fractions calculated using ALR equations in the Protocol document (ALR = X*LKFRAC + Y), except for connectors at baseline where the

 leak frequency is always 0.36%.

c Values used in MON analysis for control under subpart TT (10,000 ppm) and subpart VV (500 ppm).

Calculation of Estimate of Baseline Initial Leak Frequency

Component

Average 

Uncontrolled 

Emission Rate 

(kg/hr/ 

component)a

Initial Leak 

Frequency 

(%)b

Gas Valvesc 3.68E-04 0.305

LL Valves 3.68E-04 0.222

Pumps 7.56E-03 2.358

Connectors 1.86E-04 0.360

a From Table 1. Resulting Emission Rates and Program Efficiencies for CMA Data in Revised MACT Floor, Regulatory Alternatives, and Nationwide

 Impacts for Equipment Leaks at Chemical Manufacturing Facilities

b Leak fractions calculated using ALR equations in the Protocol document (ALR = X*LKFRAC + Y)

c Used value for valves in light liquid service

Leak frequencies from the 1997 API report: Analysis of Refinery Screening Data

Direct API Data for Total Leaking at Leak Definition, %

500 1000 10000 50000 100000

Valves - Gas 0.997 0.878 0.248 0.108 0.081

Valves - Light Liquid 1.031 0.856 0.289 0.103 0.079

Pumps - Light Liquid 3.543 2.768 0.997 0.286 0.186

Connectors - Gas 0.272 0.236 0.093 0.046 0.032

Connectors - Light Liquid 0.180 0.147 0.054 0.020 0.015

Average Valves 1.014 0.867 0.269

Differences (% within the given range)

500 1000 10000 50000 100000

Valves - Gas 0.119 0.630 0.140 0.027 0.081

Valves - Light Liquid 0.175 0.567 0.186 0.024 0.079

Pumps - Light Liquid 0.775 1.771 0.711 0.100 0.186

Inputs F-3
Attachment G 

Emission Factors and Emission Estimates 
Gas Valves - NSPS

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 26 500 0.87 Option 665

100 17.5 1000 1330500 13.6 2000 2990

1000 12 5000 66502000 10.5 10000 0.57 Baseline 232005000 8.7 50000 66500

10000 7.5 100000 397000 3970050000 5.5 1000000

100000 4.5

Distribution

leak 

concentration

Percent 

leakers when 

monitored

500 0.87

1000 0.762000 0.675000 0.55

50000 0.35

100000 0.29

Leak Freq calcs 500 100Baseline 0Option, Initial (NSPS) 6.9Option, Subsequent 0.51

aFrom figure B-3-3 in the Protocol document

Emissions 
Gas Valves

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

GV default zero 6.60E-07 Average ab

Instantaneous 10000

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

<10 74.0 0.00004884 79.5 0.00005250 79.8 

10 10 to 100 8.5 39.7 0.000395 9.1 0.000425 9.2 

100 100 to 500 3.9 232 0.000847 4.2 0.000911 4.2 500 500 to 1000 1.6 665 0.000872 1.7 0.000937 1.7 

1000 1000 to 2000 1.5 1330 0.001496 1.6 0.001608 1.6 2000 2000 to 5000 1.8 2990 0.003642 1.9 0.003915 1.9 5000 5000 to 10000 1.2 6650 0.004879 1.3 0.005245 1.3 

10000 10000 to 50000 2.0 23200 0.024207 Pegged value 0.2 0.001848 0.1 50000 50000 to 100000 1.0 66500 0.030350 0.11 0.1 0.002317 0.0 

100000 >100000 4.5 310000 0.523616 0.495 0.3 0.039972 0.2 

Emission rate 

per valve

Emission rate 

per valve

0.00590 0.00562 0.00057 

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

 ALR equation 0.0060 0.00058 

Leak Frequency Calculations Baseline Option

<10 74.0 <10 79.7 85.2

10 10 to 100 8.5 10 to 100 9.2 9.8

100 100 to 500 3.9 100 to 500 4.2 4.5500 500 to 1000 1.6 0.51 500 to 1000 1.7 0.06

1000 1000 to 2000 1.5 1000 to 2000 1.6 0.062000 2000 to 5000 1.8 2000 to 5000 1.9 0.075000 5000 to 10000 1.2 5000 to 10000 1.3 0.04

10000 10000 to 50000 2.0 0.33 10000 to 50000 0.1 0.0750000 50000 to 100000 1.0 50000 to 100000 0.0 0.04

100000 >100000 4.5 >100000 0.2 0.17

Emissions 
Gas Valves

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

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

GV default zero 0.00000066 Average above

500

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 84.9 0.0000560 0.000066 85.3 0.0000563

10 10 to 100 9.8 39.7 0.000454 9.8 0.000456

100 100 to 500 4.5 232 0.000217 4.5 0.000976500 500 to 1000 0.10 665 0.000056 0.05 0.000028

1000 1000 to 2000 0.10 1330 0.000095 0.05 0.0000482000 2000 to 5000 0.11 2990 0.000232 0.06 0.0001165000 5000 to 10000 0.08 6650 0.000311 0.04 0.000155

10000 10000 to 50000 0.13 23200 0.001543 0.06 0.00077150000 50000 to 100000 0.06 66500 0.001935 0.03 0.000967

100000 >100000 0.29 310000 0.033375 0.14 0.016688

Emission rate per 

valve

Emission rate 

per valve

0.000383 0.00000066 0.000203

Average emission rate

 during monitoring period 0.000192

Emission rate estimated using 

 ALR equation 0.00020771

(HON avg leak rate, kg/hr)

Emissions 
Light Liquid Valves - NSPS

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 18 500 0.87 Option 665

100 11 1000 1330500 8.5 2000 2990

1000 7 5000 66502000 5.8 10000 0.57 Baseline 232005000 5.1 50000 66500

10000 4.5 100000 397000 3970050000 2.9 1000000

100000 2.2

Distribution

leak 

concentration

Percent 

leakers when 

monitored

500 0.87

1000 0.712000 0.595000 0.52

10000 0.4650000 0.30

100000 0.22

Leak Freq calcs 500 100Baseline 0Option, Initial (NSPS) 4.5Option, Subsequent 0.51

aFrom figure B-3-4 in the Protocol document

Emissions 
Light Liquid Valves

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

LLV default zero 4.90E-07 Average ab

Instantaneous 10000

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

<10 82.0 0.0000402 85.4 0.0000418 85.6 

10 10 to 100 7.0 39.7 0.000844 7.3 0.000878 7.3 

100 100 to 500 2.5 232 0.001231 2.6 0.001281 2.6 500 500 to 1000 1.5 665 0.001709 1.6 0.001779 1.6 

1000 1000 to 2000 1.2 1330 0.002375 1.2 0.002473 1.3 2000 2000 to 5000 0.7 2990 0.002643 0.7 0.002751 0.7 5000 5000 to 10000 0.6 6650 0.004283 0.6 0.004460 0.6 

10000 10000 to 50000 1.6 23200 0.030922 Pegged value 0.2 0.003934 0.1 50000 50000 to 100000 0.7 66500 0.031314 0.15 0.1 0.003984 0.0 

100000 >100000 2.2 310000 0.335657 0.33 0.3 0.042706 0.1 

Emission rate 

per valve

Emission rate 

per valve

Emission rate per valve 0.00411 0.00405 0.00064 

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

 ALR equation 0.00402 0.00068 

Leak Frequency Calculations Baseline Option

<10 82.0 <10 85.6 89.2

10 10 to 100 7.0 10 to 100 7.3 7.6

100 100 to 500 2.5 100 to 500 2.6 2.7500 500 to 1000 1.5 0.51 500 to 1000 1.6 0.09

1000 1000 to 2000 1.2 1000 to 2000 1.3 0.072000 2000 to 5000 0.7 2000 to 5000 0.7 0.045000 5000 to 10000 0.6 5000 to 10000 0.6 0.04

10000 10000 to 50000 1.6 0.33 10000 to 50000 0.1 0.1050000 50000 to 100000 0.7 50000 to 100000 0.1 0.04

100000 >100000 2.2 >100000 0.2 0.13

Emissions 
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 0.00000049 Average above

500

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 0.0000435 0.000049 89.2 0.0000437

10 10 to 100 7.6 39.7 0.000914 7.6 0.000918

100 100 to 500 2.7 232 0.001333 2.7 0.001339500 500 to 1000 0.15 665 0.000174 0.08 0.000087

1000 1000 to 2000 0.12 1330 0.000242 0.06 0.0001212000 2000 to 5000 0.07 2990 0.000270 0.04 0.0001355000 5000 to 10000 0.06 6650 0.000437 0.03 0.000218

10000 10000 to 50000 0.16 23200 0.003154 0.08 0.00157750000 50000 to 100000 0.07 66500 0.003194 0.04 0.001597

100000 >100000 0.22 310000 0.034232 0.11 0.017116

Emission rate per 

valve

Emission rate 

per valve

Emission rate per valve 0.000440 0.00000049 0.000232

Average emission rate

 during monitoring period 0.000220

vs.

Emission rate estimated using 

 ALR equation 0.00023071

(HON avg leak rate, kg/hr)

Emissions 
Pumps

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 44 500 665

100 30 1000 0.44 Option 1330500 21 2000 2990

1000 17.1 5000 66502000 13.2 10000 0.39 Baseline 232005000 9.8 50000 66500

10000 7 100000 397000 3970050000 3.5 1000000

100000 2

Distribution

leak 

concentration

Percent 

leakers when 

monitored

500 5.12

1000 0.442000 0.345000 0.25

10000 0.1850000 0.09

100000 0.05

Leak Freq calcs 500 100Baseline 0Option, Initial (NSPS) 15.2Option, Subsequent 0.26

aFrom figure B-3-2 in the Protocol document

Emissions 
Pumps

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

P default zero 0.0000075 Average ab

Instantaneous 10000

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

<10 56.0 0.00042 60.0 0.000449844 60.1 

10 10 to 100 14.0 39.7 0.005524 15.0 0.005917 15.0 

100 100 to 500 9.0 232 0.015211 9.6 0.016292 9.7 500 500 to 1000 3.9 665 0.015697 4.2 0.016813 4.2 

1000 1000 to 2000 3.9 1330 0.027789 4.2 0.029764 4.2 2000 2000 to 5000 3.4 2990 0.047226 3.6 0.050582 3.6 5000 5000 to 10000 2.8 6650 0.075148 3.0 0.080488 3.0 

10000 10000 to 50000 3.5 23200 0.263017 Pegged value 0.2 0.014720 0.1 50000 50000 to 100000 1.5 66500 0.268442 0.62 0.1 0.015024 0.0 

100000 >100000 2.0 310000 1.272523 1.2400 0.1 0.071220 0.1 

Emission rate 

per pump

Emission rate 

per pump

Emission rate per valve 0.01991 0.01958 0.00301 

Emission rate estimated using (1,000 ppm) (10,000 ppm) 

 ALR equation 0.0193 0.00284 

Leak Frequency Calculations Baseline Option

<10 56.0 <10 60.1 67.4

10 10 to 100 14.0 10 to 100 15.0 16.8

100 100 to 500 9.0 100 to 500 9.7 10.8500 500 to 1000 3.9 500 to 1000 4.2 4.7

1000 1000 to 2000 3.9 0.26 1000 to 2000 4.2 0.062000 2000 to 5000 3.4 2000 to 5000 3.6 0.055000 5000 to 10000 2.8 5000 to 10000 3.0 0.04

10000 10000 to 50000 3.5 0.23 10000 to 50000 0.1 0.0550000 50000 to 100000 1.5 50000 to 100000 0.0 0.02

100000 >100000 2.0 >100000 0.1 0.03

Emissions 
Pumps

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

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

P default zero 0.0000075 Average above

1000

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 67.3 0.000504408 0.00075 67.4 0.000505519

10 10 to 100 16.8 39.7 0.006635 16.9 0.006649

100 100 to 500 10.8 232 0.018268 10.8 0.018308500 500 to 1000 4.7 665 0.018852 4.69 0.018893

1000 1000 to 2000 0.10 1330 0.000714 0.05 0.0003572000 2000 to 5000 0.09 2990 0.001214 0.04 0.0006075000 5000 to 10000 0.07 6650 0.001931 0.04 0.000965

10000 10000 to 50000 0.09 23200 0.006758 0.04 0.00337950000 50000 to 100000 0.04 66500 0.006898 0.02 0.003449

100000 >100000 0.05 310000 0.032698 0.03 0.016349

Emission rate per 

pump

Emission rate 

per pump

Emission rate per valve 0.000945 0.0000075 0.00069

Average emission rate

 during monitoring period 0.000476

vs.

Emission rate estimated using 

 ALR equation 0.0007017

(HON avg leak rate, kg/hr)

Emissions 
Attachment H 

Cost Analysis Inputs 
This page provides inputs for the entire analysis. The first section (yellow highlight) are single numbers from various sources that are used in cost

 calculations. The numbers in blue are calculated from various sources.

180.00 Cost of replacement pump seals ($)

17.70 Initial cost of monitoring valves and pumps in gas and light liquid service ($)

1.13 Initial cost of monitoring connectors and other components in heavy liquid service ($)

1.50 Monitoring Fee ($/component) (excludes connectors)

2.50 Monitoring Fee ($/connector)

23.19 Wage (chemical manufacturing maintenance) ($, May 2006)

3 Overhead factor, maintenance & and repair (assumes contractor)

1.6 Overhead factor, administration, planning, and training (assumes in-house)

64.21 Planning and training labor charge ($) *

0.244 Capital recovery factor: rupture disks and pump seals (from HON analysis)

0.142 Capital recovery factor: all other types of equipment and initial LDAR labor (from HON analysis)

1272 Total number of subpart VV process units nationwide (estimate based on total number of manufacturing sites listed in 2004 SRI

 Consulting Directory of Chemical Producers for 310 of the chemicals listed in subpart VV; the other 68 are not listed in the 2004

 SRI directory)

879 Number of process units making HON/ethylene MACT compounds

393 Number of process units making MON compounds (plus any processes not subject to any MACT, if they have only VOC, no HAP)

20 Percentage of process units at MON major sources emitting VOC only (no HAP)

15 Percentage of process units at area sources (assumed)

3 Percentage of process units that become subject each year (Assumed)

20 Percentage of process units that manufacture MON chemicals that will meet the definition of new or reconstructed in 63.2440(c)

60 Percentage of affected process units that are new (Assumed)

40 Percentage of affected process units that are reconstructed (Assumed)

52 Percentage of process units represented by simple model (from HON analysis)

33 Percentage of process units represented by medium model (from HON analysis)

15 Percentage of process units represented by complex model (from HON analysis)

320 Planning and training for LDAR program, current NSPS level, hours

320 Planning and training for LDAR program, current MON level, hours

340 Planning and training for LDAR program including connectors, hours

250 Administrative and reports for LDAR program, current NSPS level, hours

250 Administrative and reports for LDAR program, current MON level, hours

300 Administrative and reports for LDAR program including connectors, hours

900.00 VOC Recovery Credit, $/Mg

1.28 Average valve leak frequency found by 17 refineries (Enforcement Alert: Proper Monitoring Essential to Reducing 'Fugitive Emissions'

 Under Leak Detection and Repair Programs )

1.71 NEIC Factor for leak frequency

1.10 tons/Mg

* Planning and training labor charge calculation (May 2006)

Category Mean Multiplier Result

Environmental engineering 35.41 1 35.41

General and operations managers 59.94 0.05 3

General office and admin support 17.16 0.1 1.72

40.13

Inputs H-1
Attachment I 

Cost Estimates 
Baseline cost estimates before implementing Option 1. Costs include online and offline repairs for valves and pumps leaking above 10,000 ppm.

 Annual expenses used in "Option 1 Emissions" to estimate incremental cost.

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($/yr) (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 Subs

Le

Freq

(%

SOCMI model process Pump Seals

simple * Light-liquid service 15 17.70 303.72 12 1.50 722.21 74.06 0.23 0.03 

baseline VV program * Heavy-liquid service 0 1.13 0.00

Valves * Gas/vapor service 77 17.70 1383.42 2 1.50 231.00 0.33 0.26  * Light-liquid service 380 17.70 6827.28 2 1.50 1140.00 0.33 1.27  * Heavy-liquid service 0 1.13 0.00Connectors * Flanges - gas/vapor 0.00 0.00 0 0.00 0.00 N/A 0.00  * Flanges - light liquid 731 0.00 0.00 0 0.00 0.00 N/A 0.00  * Flanges -heavy liquid 0.00 0.00Replacement Pump Seals 15 180.00 6.17

hr/activity $/hr

Administrative and Reports 250 64.21

Planning and Training 320 64.21 20547.20TOTALS 8520.59 20547.20 2093.21 74.06

Capital Costs 29,068

Annualized Capital Costs 4,128

Annual Expenses 18,981

Annual Fixed Costs ($/yr) 20,240

Annual Variable Costs ($/yr) 2,869

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($/yr) (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 Subs

Le

Freq

(%

SOCMI model process Pump Seals

medium * Light-liquid service 40 17.70 809.91 12 1.50 1925.88 197.50 0.23 0.09 

baseline VV program * Heavy-liquid service 5 1.13 5.65

Valves * Gas/vapor service 414 17.70 7438.14 2 1.50 1242.00 0.33 1.38  * Light-liquid service 1,179 17.70 21182.53 2 1.50 3537.00 0.33 3.94  * Heavy-liquid service 71 1.13 80.23Connectors * Flanges - gas/vapor 0.00 0.00 0 0.00 0.00 N/A 0.00  * Flanges - light liquid 2,662 0.00 0.00 0 0.00 0.00 N/A 0.00  * Flanges -heavy liquid 0.00 0.00Replacement Pump Seals 40 180.00 16.46

hr/activity $/hr

Administrative and Reports 250 64.21

Planning and Training 320 64.21 20547.20TOTALS 29532.93 20547.20 6704.88 197.50

Capital Costs 50,080

Annualized Capital Costs 7,113

Annual Expenses 25,185

Annual Fixed Costs ($/yr) 23,324

Annual Variable Costs ($/yr) 8,975

VV_baseline 
Type of Component

SOCMI model process Pump Seals

simple * Light-liquid service

baseline VV program * Heavy-liquid service

Valves * Gas/vapor service * Light-liquid service * Heavy-liquid serviceConnectors * Flanges - gas/vapor * Flanges - light liquid * Flanges -heavy liquidReplacement Pump SealsAdministrative and Reports

Planning and TrainingTOTALS

Type of Component

SOCMI model process Pump Seals

medium * Light-liquid service

baseline VV program * Heavy-liquid service

Valves * Gas/vapor service * Light-liquid service * Heavy-liquid serviceConnectors * Flanges - gas/vapor * Flanges - light liquid * Flanges -heavy liquidReplacement Pump SealsAdministrative and Reports

Planning and TrainingTOTALS

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)

69.57 458.00 0 80.00 69.57 0.00 0.62 59.2569.57 4.48 25 4.00 69.57 35.79 0.7769.57 22.12 25 4.00 69.57 176.63 3.8169.57 0.00 25 2.00 69.57 0.00 0.0069.57 0.00 25 2.00 69.57 0.00 0.00

16052.50

484.60 212.42 5.20 16052.50 59.25

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)

69.57 1221.33 0 80.00 69.57 0.00 1.65 158.0069.57 24.10 25 4.00 69.57 192.43 4.1569.57 68.64 25 4.00 69.57 548.01 11.8269.57 0.00 25 2.00 69.57 0.00 0.0069.57 0.00 25 2.00 69.57 0.00 0.00

16052.50

1314.07 740.44 17.61 16052.50 158.00

VV_baseline 
Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($/yr) (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 Subs

Le

Freq

(%

SOCMI model process Pump Seals

complex * Light-liquid service 56 17.70 1133.88 12 1.50 2696.23 276.50 0.23 0.13 

baseline VV program * Heavy-liquid service 36 1.13 40.68

Valves * Gas/vapor service 1,379 17.70 24775.84 2 1.50 4137.00 0.33 4.61  * Light-liquid service 1,980 17.70 35573.72 2 1.50 5940.00 0.33 6.61  * Heavy-liquid service 1,272 1.13 1437.36Connectors * Flanges - gas/vapor 0.00 0.00 0 0.00 0.00 N/A 0.00  * Flanges - light liquid 7,410 0.00 0.00 0 0.00 0.00 N/A 0.00  * Flanges -heavy liquid 0.00 0.00Replacement Pump Seals 56 180.00 23.04

hr/activity $/hr

Administrative and Reports 250 64.21

Planning and Training 320 64.21 20547.20

TOTALS 62984.52 20547.20 12773.23 276.50

Capital Costs 83,532

Annualized Capital Costs 11,864

Annual Expenses 32,826

Annual Fixed Costs ($/yr) 28,138

Annual Variable Costs ($/yr) 16,552

VV_baseline 
Type of Component

SOCMI model process Pump Seals

complex * Light-liquid service

baseline VV program * Heavy-liquid service

Valves * Gas/vapor service * Light-liquid service * Heavy-liquid serviceConnectors * Flanges - gas/vapor * Flanges - light liquid * Flanges -heavy liquidReplacement Pump SealsAdministrative and Reports

Planning and TrainingTOTALS

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)

69.57 1709.86 0 80.00 69.57 0.00 2.30 221.2069.57 80.28 25 4.00 69.57 640.97 13.8269.57 115.27 25 4.00 69.57 920.33 19.8469.57 0.00 25 2.00 69.57 0.00 0.0069.57 0.00 25 2.00 69.57 0.00 0.00

16052.50

1905.42 1561.30 35.97 16052.50 221.20

VV_baseline 
Cost estimates for implementing Option 1. Costs include initial planning and training for process units not already subject to MACT, initial r

 repairs. Initial capital costs are annualized. Annual costs and expenses used in "Option 1 Emissions" to estimate incremental cost.

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($/yr) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) 

Pump Seals

SOCMI Model process * Light-liquid service 15 17.70 308.36 12 1.50 722.21 83.0

simple * Heavy-liquid service 0 1.13 0.00

Option 1

Valves * Gas/vapor service 77 17.70 1393.97 2 1.50 231.00  * Light-liquid service 380 17.70 6879.34 2 1.50 1140.00  * Heavy-liquid service 0 1.13 0.00Connectors * Flanges - gas/vapor 17.70 0.00 0.25 2.50 0.00  * Flanges - light liquid 731 17.70 13059.75 0.25 2.50 456.88 

0.00 * Flanges -heavy liquid 1.13 0.00

Connectors (baseline) * Flanges - gas/vapor 0.00 0.00 * Flanges - light liquid 731 0.00 0.00 * Flanges -heavy liquid 0.00 0.00Replacement Pump Seals 15 180.00 0.07Administrative and Reports hr/activity $/hr * Without connectors 250 64.21 * With connectors 50 64.21Planning and Training hr/activity $/hr * Without connectors 320 64.21 20547.20 * With connectors 20 64.21 1284.20TOTALS without connectors 8581.75 20547.20 2093.21 83.0TOTALS with connectors 21641.50 21831.40 2550.08 83.0TOTALS initial for connectors only 13059.75 1284.20 2550.08 83.0

Without connectors

Capital Costs w/o OVA and Train 29,129

Annualized Capital Costs 4,136

Annual Expenses 19,178

Annual Fixed Costs ($/yr) 20,255

Annual Variable Costs ($/yr) 3,059

With connectors

Capital Costs w/o OVA and Train 43,473

Annualized Capital Costs 6,173

Annual Expenses 22,876

Annual Fixed Costs ($/yr) 25,503

Annual Variable Costs ($/yr) 3,547

Initial costs for connectors only

Capital Costs w/o OVA and Train 14,344

Annualized Capital Costs 2,037

Annual Expenses 22,876

Annual Fixed Costs ($/yr) 21,366

Annual Variable Costs ($/yr) 3,547

Option1MONdata 
Type of Component

Pump Seals

SOCMI Model process * Light-liquid service

simple * Heavy-liquid service

Option 1

Valves * Gas/vapor service * Light-liquid service * Heavy-liquid serviceConnectors * Flanges - gas/vapor * Flanges - light liquid

0.00 * Flanges -heavy liquid

Connectors (baseline) * Flanges - gas/vapor * Flanges - light liquid * Flanges -heavy liquidReplacement Pump SealsAdministrative and Reports * Without connectors * With connectorsPlanning and Training * Without connectors * With connectorsTOTALS without connectorsTOTALS with connectorsTOTALS initial for connectors only

Annual 

Number of 

Leaks

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)

MonitorinVerify Re

($)

0.46 100 16.00 69.57 513.67 0 80.00 69.57 0.00 00.78 75 0.17 69.57 6.79 25 4.00 69.57 54.19 3.84 75 0.17 69.57 33.50 25 4.00 69.57 267.43 50.00 75 0.17 69.57 0.00 25 2.00 69.57 0.00 00.66 75 0.17 69.57 5.73 25 2.00 69.57 22.89 

553.95 321.62 7559.68 344.50 9559.68 344.50 9

Option1MONdata 
Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($/yr) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) 

Pump Seals

SOCMI Model process * Light-liquid service 40 17.70 822.30 12 1.50 1925.88 221.5

medium * Heavy-liquid service 5 1.13 5.65

Option 1

Valves * Gas/vapor service 414 17.70 7494.86 2 1.50 1242.00  * Light-liquid service 1,179 17.70 21344.07 2 1.50 3537.00  * Heavy-liquid service 71 1.13 80.23Connectors * Flanges - gas/vapor 17.70 0.00 0.25 2.50 0.00  * Flanges - light liquid 2,662 17.70 47558.21 0.25 2.50 1663.75  * Flanges -heavy liquid 1.13 0.00Connectors (baseline) * Flanges - gas/vapor 0.00 0.00 * Flanges - light liquid 2,662 0.00 0.00 * Flanges -heavy liquid 0.00 0.00Replacement Pump Seals 40 180.00 0.18Administrative and Reports hr/activity $/hr * Without connectors 250 64.21 * With connectors 50 64.21Planning and Training hr/activity * Without connectors 320 64.21 20547.20 * With connectors 20 64.21 1284.20TOTALS without connectors 29747.30 20547.20 6704.88 221.5TOTALS with connectors 77305.52 21831.40 8368.63 221.5TOTALS initial for connectors only 47558.21 1284.20 8368.63 221.5

Without connectors

Capital Costs w/o OVA and Train 50,295

Annualized Capital Costs 7,142

Annual Expenses 25,813

Annual Fixed Costs ($/yr) 23,372

Annual Variable Costs ($/yr) 9,584

With connectors

Capital Costs w/o OVA and Train 99,137

Annualized Capital Costs 14,077

Annual Expenses 30,798

Annual Fixed Costs ($/yr) 33,518

Annual Variable Costs ($/yr) 11,358

Initial costs for connectors only

Capital Costs w/o OVA and Train 48,842

Annualized Capital Costs 6,936

Annual Expenses 30,798

Annual Fixed Costs ($/yr) 26,376

Annual Variable Costs ($/yr) 11,358

Option1MONdata 
Type of Component

Pump Seals

SOCMI Model process * Light-liquid service

medium * Heavy-liquid service

Option 1

Valves * Gas/vapor service * Light-liquid service * Heavy-liquid serviceConnectors * Flanges - gas/vapor * Flanges - light liquid * Flanges -heavy liquidConnectors (baseline) * Flanges - gas/vapor * Flanges - light liquid * Flanges -heavy liquidReplacement Pump SealsAdministrative and Reports * Without connectors * With connectorsPlanning and Training * Without connectors * With connectorsTOTALS without connectorsTOTALS with connectorsTOTALS initial for connectors only

Annual 

Number of 

Leaks

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)

MonitorinVerify Re

($)

1.23 100 16.00 69.57 1369.78 0 80.00 69.57 0.00 4.19 75 0.17 69.57 36.49 25 4.00 69.57 291.36 6

11.93 75 0.17 69.57 103.92 25 4.00 69.57 829.73 17

0.00 75 0.17 69.57 0.00 25 2.00 69.57 0.00 02.40 75 0.17 69.57 20.88 25 2.00 69.57 83.34 5

1510.20 1121.08 261531.08 1204.42 321531.08 1204.42 32

Option1MONdata 
Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($/yr) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) 

Pump Seals

SOCMI Model process * Light-liquid service 56 17.70 1151.22 12 1.50 2696.23 310.1

complex * Heavy-liquid service 36 1.13 40.68

Option 1

Valves * Gas/vapor service 1,379 17.70 24964.78 2 1.50 4137.00  * Light-liquid service 1,980 17.70 35845.00 2 1.50 5940.00  * Heavy-liquid service 1,272 1.13 1437.36Connectors * Flanges - gas/vapor 17.70 0.00 0.25 2.50 0.00  * Flanges - light liquid 7,410 17.70 132384.06 0.25 2.50 4631.25  * Flanges -heavy liquid 1.13 0.00Connectors (baseline) * Flanges - gas/vapor 0.00 0.00 * Flanges - light liquid 7,410 0.00 0.00 * Flanges -heavy liquid 0.00 0.00Replacement Pump Seals 56 180.00 0.26Administrative and Reports hr/activity $/hr * Without connectors 250 64.21 * With connectors 50 64.21Planning and Training hr/activity $/hr * Without connectors 320 64.21 20547.20 * With connectors 20 64.21 1284.20TOTALS without connectors 63439.31 20547.20 12773.23 310.1TOTALS with connectors 195823.36 21831.40 17404.48 310.1TOTALS initial for connectors only 132384.06 1284.20 17404.48 310.1

Without connectors

Capital Costs w/o OVA and Train 83,987

Annualized Capital Costs 11,926

Annual Expenses 34,015

Annual Fixed Costs ($/yr) 28,227

Annual Variable Costs ($/yr) 17,715

With connectors

Capital Costs w/o OVA and Train 217,655

Annualized Capital Costs 30,907

Annual Expenses 42,164 27129

Annual Fixed Costs ($/yr) 50,418

Annual Variable Costs ($/yr) 22,653

Initial costs for connectors only

Capital Costs w/o OVA and Train 133,668

Annualized Capital Costs 18,981

Annual Expenses 42,164

Annual Fixed Costs ($/yr) 38,492

Annual Variable Costs ($/yr) 22,653

Option1MONdata 
Type of Component

Pump Seals

SOCMI Model process * Light-liquid service

complex * Heavy-liquid service

Option 1

Valves * Gas/vapor service * Light-liquid service * Heavy-liquid serviceConnectors * Flanges - gas/vapor * Flanges - light liquid * Flanges -heavy liquidConnectors (baseline) * Flanges - gas/vapor * Flanges - light liquid * Flanges -heavy liquidReplacement Pump SealsAdministrative and Reports * Without connectors * With connectorsPlanning and Training * Without connectors * With connectorsTOTALS without connectorsTOTALS with connectorsTOTALS initial for connectors only

Annual 

Number of 

Leaks

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)

MonitorinVerify Re

($)

1.72 100 16.00 69.57 1917.70 0 80.00 69.57 0.00 2

13.95 75 0.17 69.57 121.55 25 4.00 69.57 970.48 2020.03 75 0.17 69.57 174.53 25 4.00 69.57 1393.44 30

0.00 75 0.17 69.57 0.00 25 2.00 69.57 0.00 06.67 75 0.17 69.57 58.11 25 2.00 69.57 231.98 16

2213.78 2363.92 532271.89 2595.90 702271.89 2595.90 70

Option1MONdata 
Cost estimates for implementing Option 1 for units currently subject to a leak definition of 10,000 ppm. Costs include initial planning and tra

 subject to MACT, initial repair, and online and offline repairs. Initial capital costs are annualized. Annual costs and expenses used in "O incremental cost.

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($/yr) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) 

Pump Seals

SOCMI Model process * Light-liquid service 15 0.00 2506.49 12 1.50 722.21 83.0

simple * Heavy-liquid service 0 0.00 0.00

Option 1

Valves * Gas/vapor service 77 0.00 393.23 2 1.50 231.00  * Light-liquid service 380 0.00 1213.55 2 1.50 1140.00  * Heavy-liquid service 0 0.00 0.00Connectors * Flanges - gas/vapor 0 17.70 0.00 0.25 2.50 0.00  * Flanges - light liquid 731 17.70 13059.75 0.25 2.50 456.88  * Flanges -heavy liquid 0 1.13 0.00Connectors (baseline) * Flanges - gas/vapor 0 0.00 0.00 * Flanges - light liquid 731 0.00 0.00 * Flanges -heavy liquid 0 0.00 0.00Replacement Pump Seals 15 180.00 4.12Administrative and Reports hr/activity $/hr * Without connectors 250 64.21 * With connectors 50 64.21Planning and Training hr/activity $/hr * Without connectors 0 64.21 0.00 * With connectors 20 64.21 1284.20TOTALS without connectors 4117.38 0.00 2093.21 83.0TOTALS with connectors 17177.13 1284.20 2550.08 83.0

Without connectors

Capital Costs w/o OVA and Train 4,117

Annualized Capital Costs 585

Annual Expenses 19,178

Annual Fixed Costs ($/yr) 16,704

Annual Variable Costs ($/yr) 3,059

With connectors

Capital Costs w/o OVA and Train 18,461

Annualized Capital Costs 2,622

Annual Expenses 22,876

Annual Fixed Costs ($/yr) 21,951

Annual Variable Costs ($/yr) 3,547

Option1NSPS 
Type of Component

Pump Seals

SOCMI Model process * Light-liquid service

simple * Heavy-liquid service

Option 1

Valves * Gas/vapor service * Light-liquid service * Heavy-liquid serviceConnectors * Flanges - gas/vapor * Flanges - light liquid * Flanges -heavy liquidConnectors (baseline) * Flanges - gas/vapor * Flanges - light liquid * Flanges -heavy liquidReplacement Pump SealsAdministrative and Reports * Without connectors * With connectorsPlanning and Training * Without connectors * With connectorsTOTALS without connectorsTOTALS with connectors

Annual 

Number of 

Leaks

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)

MonitorinVerify Re

($)

0.46 100 16.00 69.57 513.67 0 80.00 69.57 0.00 00.78 75 0.17 69.57 6.79 25 4.00 69.57 54.19 3.84 75 0.17 69.57 33.50 25 4.00 69.57 267.43 50.00 75 0.17 69.57 0.00 25 2.00 69.57 0.00 00.66 75 0.17 69.57 5.73 25 2.00 69.57 22.89 

553.95 321.62 7559.68 344.50 9

Option1NSPS 
Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($/yr) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) 

Pump Seals

SOCMI Model process * Light-liquid service 40 0.00 6683.96 12 1.50 1925.88 221.5

medium * Heavy-liquid service 5 0.00 0.00

Option 1

Valves * Gas/vapor service 414 0.00 2114.22 2 1.50 1242.00  * Light-liquid service 1,179 0.00 3765.19 2 1.50 3537.00  * Heavy-liquid service 71 0.00 0.00Connectors * Flanges - gas/vapor 0 17.70 0.00 0.25 2.50 0.00  * Flanges - light liquid 2,662 17.70 47558.21 0.25 2.50 1663.75  * Flanges -heavy liquid 0 1.13 0.00Connectors (baseline) * Flanges - gas/vapor 0 0.00 0.00 * Flanges - light liquid 2,662 0.00 0.00 * Flanges -heavy liquid 0 0.00 0.00Replacement Pump Seals 40 180.00 10.98Administrative and Reports hr/activity $/hr * Without connectors 250 64.21 * With connectors 50 64.21Planning and Training hr/activity * Without connectors 0 64.21 0.00 * With connectors 20 64.21 1284.20TOTALS without connectors 12574.35 0.00 6704.88 221.5TOTALS with connectors 60132.57 1284.20 8368.63 221.5

Without connectors

Capital Costs w/o OVA and Train 12,574

Annualized Capital Costs 1,787

Annual Expenses 25,813

Annual Fixed Costs ($/yr) 18,016

Annual Variable Costs ($/yr) 9,584

With connectors

Capital Costs w/o OVA and Train 61,417

Annualized Capital Costs 8,722

Annual Expenses 30,798

Annual Fixed Costs ($/yr) 28,163

Annual Variable Costs ($/yr) 11,358

Option1NSPS 
Type of Component

Pump Seals

SOCMI Model process * Light-liquid service

medium * Heavy-liquid service

Option 1

Valves * Gas/vapor service * Light-liquid service * Heavy-liquid serviceConnectors * Flanges - gas/vapor * Flanges - light liquid * Flanges -heavy liquidConnectors (baseline) * Flanges - gas/vapor * Flanges - light liquid * Flanges -heavy liquidReplacement Pump SealsAdministrative and Reports * Without connectors * With connectorsPlanning and Training * Without connectors * With connectorsTOTALS without connectorsTOTALS with connectors

Annual 

Number of 

Leaks

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)

MonitorinVerify Re

($)

1.23 100 16.00 69.57 1369.78 0 80.00 69.57 0.00 4.19 75 0.17 69.57 36.49 25 4.00 69.57 291.36 6

11.93 75 0.17 69.57 103.92 25 4.00 69.57 829.73 17

0.00 75 0.17 69.57 0.00 25 2.00 69.57 0.00 02.40 75 0.17 69.57 20.88 25 2.00 69.57 83.34 5

1510.20 1121.08 261531.08 1204.42 32

Option1NSPS 
Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($/yr) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) 

Pump Seals

SOCMI Model process * Light-liquid service 56 0.00 9357.54 12 1.50 2696.23 310.1

complex * Heavy-liquid service 36 0.00 0.00

Option 1

Valves * Gas/vapor service 1,379 0.00 7042.30 2 1.50 4137.00  * Light-liquid service 1,980 0.00 6323.22 2 1.50 5940.00  * Heavy-liquid service 1,272 0.00 0.00Connectors * Flanges - gas/vapor 0 17.70 0.00 0.25 2.50 0.00  * Flanges - light liquid 7,410 17.70 132384.06 0.25 2.50 4631.25  * Flanges -heavy liquid 0 1.13 0.00Connectors (baseline) * Flanges - gas/vapor 0 0.00 0.00 * Flanges - light liquid 7,410 0.00 0.00 * Flanges -heavy liquid 0 0.00 0.00Replacement Pump Seals 56 180.00 15.37Administrative and Reports hr/activity $/hr * Without connectors 250 64.21 * With connectors 50 64.21Planning and Training hr/activity $/hr * Without connectors 0 64.21 0.00 * With connectors 20 64.21 1284.20TOTALS without connectors 22738.44 0.00 12773.23 310.1TOTALS with connectors 155122.50 1284.20 17404.48 310.1

Without connectors

Capital Costs w/o OVA and Train 22,738

Annualized Capital Costs 3,230

Annual Expenses 34,015

Annual Fixed Costs ($/yr) 19,531

Annual Variable Costs ($/yr) 17,715

With connectors

Capital Costs w/o OVA and Train 156,407

Annualized Capital Costs 22,211

Annual Expenses 42,164

Annual Fixed Costs ($/yr) 41,722

Annual Variable Costs ($/yr) 22,653

Option1NSPS 
Type of Component

Pump Seals

SOCMI Model process * Light-liquid service

complex * Heavy-liquid service

Option 1

Valves * Gas/vapor service * Light-liquid service * Heavy-liquid serviceConnectors * Flanges - gas/vapor * Flanges - light liquid * Flanges -heavy liquidConnectors (baseline) * Flanges - gas/vapor * Flanges - light liquid * Flanges -heavy liquidReplacement Pump SealsAdministrative and Reports * Without connectors * With connectorsPlanning and Training * Without connectors * With connectorsTOTALS without connectorsTOTALS with connectors

Annual 

Number of 

Leaks

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)

MonitorinVerify Re

($)

1.72 100 16.00 69.57 1917.70 0 80.00 69.57 0.00 2

13.95 75 0.17 69.57 121.55 25 4.00 69.57 970.48 2020.03 75 0.17 69.57 174.53 25 4.00 69.57 1393.44 30

0.00 75 0.17 69.57 0.00 25 2.00 69.57 0.00 06.67 75 0.17 69.57 58.11 25 2.00 69.57 231.98 16

2213.78 2363.92 532271.89 2595.90 70

Option1NSPS 
SUMMARY OF IMPACTS OF LDAR FOR CONNECTORS (Option 2 incremental only, without Option 1)

Parameter simple medium complex

Total number of connectors 731 2,662 7,410

Baseline (no LDAR)

 initial leak frequency, percenta 0.36 0.36 0.36

 emission rate, kg/hr/connectorb 0.000307 0.000307 0.000307

Option 2 (500 ppm LDAR)

 initial number of leaks 2.63 9.58 26.68

 final leak frequency, percentc 0.36 0.36 0.36

 monitoring frequency, times/yrd 0.25 0.25 0.25

 annual number of leaks 0.66 2.40 6.67

 emission rate, kg/hr/connectore 0.000162 0.000162 0.000162

Time in service, hr/yr 8,760 8,760 8,760

Total emissions reduction, Mg/yr 0.9285 3.381 9.412

Baseline cost, $/yr 0 0 0

Option 2 costs

 initial monitoring fee, $/componentf 17.70 17.70 17.70

 initial LDAR cost (monitoring and repair), $ 13,053 47,534 132,317

 planning and training costs, $ 1,284 1,284 1,284

 monitoring to verify repair for initial leaks, $ 6.58 23.96 66.69

 annualized initial LDAR cost, $/yrg 2,037 6,936 18,981

 subsequent monitoring fee, $/component 2.50 2.50 2.50

 annual monitoring cost, $/yr 457 1,664 4,631

 percent of annual leaks repaired online, percent 75 75 75

 online repair time, hr 0.167 0.167 0.167

 labor charge, $/hrh 69.57 69.57 69.57

 annual online leak repair cost, $/yr 5.73 20.88 58.11

 percent of annual leaks repaired offline, percent 25 25 25

 offline repair time, hr 2 2 2

 labor charge, $/hrh 69.57 69.57 69.57

 annual offline leak repair cost, $/yr 22.89 83.34 231.98

 monitoring to verify repair, $ 1.64 5.99 16.67

 annual admin and reporting costs, $ 3210.50 3210.50 3210.50

 total annual cost, $/yr 5,734 11,920 27,129

Cost effectiveness, $/Mg removed 6,176 3,525 2,882

Recovery credits, $/yr

CostNationwide impacts in fifth year after proposal Total Effectiveness

 number of affected processesi 36.8 23.3 10.6 70.7

 emission reductions, Mg/yr 34.1 79 100 213

 total annual costs, $/yr 210,853 278,148 287,749 776,750 3,649

 total annual costs after recovery credit applied, $/yr 585,172 2,749

a

Baseline leak frequencies based on industry-supplied data for the MON.

b

SOCMI values based on industry data used in the analysis for the MON.

c

Assumed the final leak frequency would be the same as the initial leak frequency (same approach as in PET analysis for P&R IV).

d

Monitoring frequencies based on assumption that option 3 would require annual monitoring for leak frequencies greater than or equal to 0.5, every 4

 years for leak frequencies greater than or equal to 0.25, and every 8 years for leak frequencies less than 0.25.

e

SOCMI values calculated using one-half of assumed subsequent leak frequency in the average leak rate equation for leak definition of 500 ppm

 (Table 5-4 in the Protocol document). 

f

From PET analysis for P&R IV (memo from K. Barnett to P&R IV docket. December 2000)

g

Assuming annualized over 10 years at 7 percent interest.

h

May 2006 wage rates for BLS OCC Code 4909012 (Control and valve installers and repairers, except mechanical doors) in NAICS 324 and 325;

 plus assumed 50 percent overhead.

i

Assuming 1,272 total processes producing chemicals listed in subpart VV (from SRI Consulting directory) Of those processes, 392 make MON

 compounds and the remainder make HON/ethylene MACT compounds. Of the MON processes, 2 percent become affected sources each year

 (assumed value); and distribution of models is 33 percent simple, 52 percent medium; and 17 percent complex (from the HON analysis). Assume

 10 percent of the HON/ethylene facilities are area sources and 2 percent of those become subject each year. Of the major sources, assume that 

 20 percent will be required to monitor connectors at baseline because they meet the definition of new or reconstructed in §63.2440(c).

j

Assume each affected process unit will be at a different facility.

SOCMI model

Option 2 Emissions I-17
Attachment J 

Final Cost Estimates 
CALCULATION OF BASELINE AND OPTION COSTS

(1) (2) (3) (4) (5) (6) 

Total New Reconstructed Reconstructed New units at Existing New Rec

number of process units process units process units existing sources process units process units pro

process complying w/ complying w/ complying w/ complying w/ complying w/ complying w/ com

units HON/eth. & MON HON/eth. MON MON * MON * NSPS 

simple 99.2 37.5 23.3 1.7 10.0 6.7 12.1 medium 63.0 23.8 14.8 1.1 6.3 4.2 7.7 complex 28.6 10.8 6.7 0.5 2.9 1.9 3.5 total 190.8 72.1 44.8 3.2 19.2 12.8 23.2 BaselineInitial Costs 6,338,524 $ - $ 139,907 $ 853,201 $ - $ 1,024,111 $ 

$ 

Annual Costs 2,945,203 $ 1,272,399 $ 110,889 $ 575,123 $ 302,646 $ 681,144 $ 

$ 

Option 1Initial Costs 6,338,524 $ - $ 139,907 $ 853,201 $ - $ 1,028,070 $ 

$ 

Annual Costs 2,945,203 $ 1,272,399 $ 110,889 $ 575,123 $ 302,646 $ 692,998 $ 

$ 

Increment - $ - $ - $ - $ - $ 11,854 $ 

$ 

Option 2Initial Costs 6,338,524 $ - $ 139,907 $ 1,692,642 $ 559,627 $ 2,039,560 $ 

$ 

Annual Costs 2,945,203 $ 1,272,399 $ 110,889 $ 786,488 $ 443,556 $ 947,684 $ 

$ 

Increment - $ - $ - $ 211,365 $ 140,910 $ 266,539 $ 

$ 

* These are individual process units that meet the definition of new and reconstructed in the General Provisions to part 60 but not the MON  process units would be subject to subpart VV in the absence of the MON.The numbers in parentheses above each column correspond to the numbers in the diagram in Attachment B.

Option 1 Summary 
Attachment K 

Open Ended Lines 
Baseline Calculations

Baseline conditions = caps/plugs, but not properly installedNumber of OELs (based on total number per model process in the HON analysis, distributed among gas, LL, and HL service as in the original SOCMI EL analysis in 1980)Original Model gas LL* HL* total

A 9 82.65 12.35 104B 37 328.86 49.14 415C 115 1010.94 151.06 1277

* Original model units assumed 50/50 split between light liquid and heavy liquid. The ratio of light liquid to heavy liquid components for this analysis is based on the 24 individual units.Proportion to fit HON model Model gas LL HL total (from model) Fraction split

A 2.9 26.2 3.9 33 0.52B 12.6 111.7 16.7 141 0.33C 38.2 335.7 50.2 424 0.15Avg per 11.4 100.9 15.1process

G&LL All

112.2 127.3

# of new processes 190.8 190.8 Consistent with number in analysis for lower pump and valve leak definitFraction in sampling systems 0.2Nationwide # of OELs 17,129 24,287

Calculate baseline emissions assuming emissions from OELs with plugs/caps poorly installed is better represented by correlation equations for connectors than by the correlation equation for OELs.leak range 0 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (500 ppm), % 0.9percent in range 89.100 10.0000 0.1146 0.3669 0.2580 0.0975 0.0631 100.00representative value default 0 758 3,318 22,898 73,829 350,727

zero

emissions (kg/hr/OEL) connectors 0.00000061 0.00000061 0.0010785 0.003984 0.022015 0.062042 0.246376Baseline emissionskg/hr/OEL 0.0003kg/d/OEL 0.0069kg/yr/OEL 2.532Mg/yr/OEL 0.0025Mg/yr nationwide 43.375 Assuming 17,129 OELs in G or LL service subject to NSPS in 5th year after proposal

 and not in sampling systems

Emission Reductions

Basis: 1

Assume OEL valves are opened with the following frequencies Monitoring Opening No. time

time percent What are the percent reductions for semi-annual monitoring? Subsequ

period opened 6 1 8.333333 0.9

once per month 0 6 3 25 0.9

once per quarter 33.333 6 12 75 0.4

once per year 33.333 6 24 100 

once per 2 years 33.333 overall 66.7 Average subsequent leak frequency: 0.4

Months between

OEL 
1.29 Emission overestimate factor for flange equation

Cost Analysis

Notes

Monitoring events per year 2

Percent reduction in emissions 66.67

Mass reduction, nationwide Mg/yr 22

Mass reduction, nationwide kg/yr 2,249

Total number of OELs at new and 24,287

 reconstructed units in 5 years after

 proposal

Number of OELs in gas/vapor or light 17,129 assuming OELs in G/V and LL service are 88% of total

 liquid service and that OELs not in sampling connection systems are 80%

of those in G/V and LL service.

Initial costs

Equipment, $

 $/cap 0 because they should already be using caps, plugs, etc.

 $/process 0

Initial monitoring, $

 $/OEL 17.7 probably overstated since the affected OELs are all related to

 known valves.

 nationwide $ 303,186 assuming only monitor OELs in gas and LL service that are not in 

Initial repair, $ sampling connection systems

 initial percentage leaking 0.9 based on industry comments

 repair costs, $ nationwide 4,078 using same assumptions for online vs offline repair fractions,

 wage rates, and repair time as for ongoing repair

Total Initial Costs, $ 307,264

Annual costs, nationwide $/yr

 Annualized initial costs 33,738 CRF=0.1098 (7% interest and 15 year life)

 Annual monitoring cost

 monitoring frequency, times/yr 2

 cost per OEL 1.50

 nationwide cost, $/yr 51,387 assuming only monitor OELs in gas and LL service that are not in

sampling connection systems

 Maintenance 0 factor based on equipment cost, which should not change with

 monitoring

 Miscellaneous 0 factor based on equipment cost, which should not change with

 monitoring

OEL K-2
 Repair

 subsequent leak frequency 0.45

 subsequent number leaking 77.08

 percentage repaired attempted 95 assuming tightening the valve, or properly installing the plug/cap

 online is attempted for all that are found to be leaking, and it works

 for all leaking OELs, except those with second valves

 time to repair online, hr 0.167

 wage rate for repair labor, $/hr 23.19

 overhead factor 3

 online repair cost, $/OEL 13.12 includes monitoring to verify repair

 online repair cost, nationwide $ 1,921

 percentage repaired offline 5 assumed fraction of OELs with second valves

 time to repair offline, hr 4 assume same as for repairing valve when it has an external leak

 offline repair cost, $/OEL 280 includes monitoring to verify repair

 offline repair cost, nationwide $ 2,157

 Administrative and Reports

 additional time to prepare

 each semiannual report, hr 1 should be minimal effort to ensure that info about leakers is

 documented

 wage rate, $/hr 64.21

 annual cost, nationwide $/yr 24,503 assuming each process unit is at a different facility

 Total annual cost, nationwide $/yr 113,705

 Recovery credit

 product value, $/Mg 900

 total recovered, Mg nationwide 22.49

 total recovered, ton nationwide 24.79

 total savings, nationwide $/yr 20,237

 TAC with recovery savings, $/yr 93,468

Cost effectiveness, $/ton removed

 with recovery credit 3,771

 without recovery credit 4,587

OEL K-3
Attachment L 

Valve Leak Definition of 100 ppm 
Valve Leak Definition of 100 ppm

Emissions Assume 90 percent reduction

Gas Valves Light Liquid Valves Total

Number of Valves 73,174 168,604 241,778

Percent leaking between 100 ppm and 500 ppm 4.47 2.71

Number of valves leaking 3,274 4,567 7,841

Baseline emission factor 0.000217 0.000492

Baseline emissions 6.23 19.7 25.9

Maximum emission reductions, Mg 5.61 17.7 23.3

Maximum emission reductions, tons 6.18 19.5 25.7

Monitoring Costs Not estimated

Repair Costs

Percent leaking 0.5222 0.316

Number of valves leaking 764 1,066 1,830

Percent of annual leaks repaired online 75 75

Online repair time, hr 0.167 0.167

Labor charge, $/hr 69.57 69.57

Annual online leak repair cost, $/yr $6,659 $9,287 $15,946

 percent of annual leaks repaired offline, percent 25 25

 offline repair time, hr 4 4

 labor charge, $/hrh 69.57 69.57

 annual offline leak repair cost, $/yr $53,165 $74,149 $127,314

Monitoring fee 1.50 1.50

 monitoring to verify repair, $ $1,146 $1,599 $2,745

Total Repair Costs $146,005

Cost-effectiveness ($/ton) $5,678

100 ppm Leak Def L-1
Attachment M 

Results 
Nationwide Impacts for Future New and Reconstructed SOCMI Plants

Option

VOC Emissions 

at Selected 

Option (Mg/yr)

Cumulative 

Emission 

Reduction 

(Mg/yr)

Initial Cost 

($)

Initial Cost 

Beyond 

Baseline ($)

Annual Cost 

($/yr)

Annual Cost 

Beyond 

Baseline ($/yr)

Cost 

Effectiveness 

($/Mg)

Incremental 

Cost 

Effectiveness 

($/Mg)

Annual Cost 

($/yr)

Annual Co

Beyond 

Baseline ($

Baseline 1478 8,355,743 6,244,532 6,244,532

1 1393 85 8,509,652 153,909 6,285,239 40,707 479 6,208,801 -35,2 1180 298 11,594,536 3,238,793 7,061,989 817,457 2,745 3,649 6,793,974 549,3 1158 320 11,901,800 3,546,057 7,175,694 931,162 2,907 5,057 6,887,442 642,

Option

VOC Emissions 

at Selected 

Option (tons/yr)

Cumulative 

Emission 

Reduction 

(tons/yr)

Initial Cost 

($)

Initial Cost 

Beyond 

Baseline ($)

Annual Cost 

($/yr)

Annual Cost 

Beyond 

Baseline ($/yr)

Cost 

Effectiveness 

($/ton)

Incremental 

Cost 

Effectiveness 

($/ton)

Annual Cost 

($/yr)

Annual Co

Beyond 

Baseline ($

Baseline 1629 8,355,743 6,244,532 6,244,532

1 1384 94 8,509,652 153,909 6,285,239 40,707 435 6,208,801 -35,2 1150 328 11,594,536 3,238,793 7,061,989 817,457 2,490 3,310 6,793,974 549,3 1125 353 11,901,800 3,546,057 7,175,694 931,162 2,637 4,587 6,887,442 642,

Option 1: Leak definitions of 500 ppm for valves and 2,000 ppm for pumps, new or reconstructed in the five years after proposal

of the amended NSPS.

Option 2: Option 1 + Monitor and repair connectors at 500 ppm, new or reconstructed in the five years of the

new subpart

Option 3: Option 1 + semiannual monitoring of open-ended lines

Without Recovery Credit With RWithout Recovery Credit With R

Nationwide Impacts Summary 
New NSPS

 

Annual cost, $/yr 

SOCMI model:

simple Using emission

data from the

MON analysis Incremental emission reductions

Mg/yr tons/yr

Subpart VV with valves monitored: Pumps plus valves 0.87 0.96

Semiannually 23,109 Pumps, valves, and connectors 1.80 1.98

Option 1 with valves monitored: Incremental cost increase, $/yr

Semiannually 23,315 w/out credit w/ credit

Pumps plus valves 205 -576

Option 2 with valves monitored: Pumps, valves, and connectors 5,940 4,323

Semiannually 29,049

Incremental cost effectiveness

Operating hours/yr 8,760 w/out credit w/ credit w/out credit w/ credit

Pumps plus valves 237 -663 215 -602

Pumps, valves, and connectors 3,307 2,407 3,000 2,184

Annual cost, $/yr

SOCMI model:

medium Using emission

data from the

MON analysis Incremental emission reductions

Mg/yr tons/yr

Subpart VV with valves monitored: Pumps plus valves 2.82 3.11

Semiannually 32,298 Pumps, valves, and connectors 6.20 6.83

Option 2 with valves monitored: Incremental cost increase, $/yr

Semiannually 32,955 w/out credit w/ credit

Pumps plus valves 657 -1,878

Option 3 with valves monitored: Pumps, valves, and connectors 12,577 6,999

Semiannually 44,875

Incremental cost effectiveness

Operating hours/yr 8,760 w/out credit w/ credit w/out credit w/ credit

Pumps plus valves 233 -667 212 -605

Pumps, valves, and connectors 2,029 1,129 1,841 1,024

Annual cost, $/yr

SOCMI model:

complex Using emission

data from the

MON analysis Incremental emission reductions

Mg/yr tons/yr

Subpart VV with valves monitored: Pumps plus valves 5.45 6.00

Semiannually 44,690 Pumps, valves, and connectors 14.86 16.38

Option 2 with valves monitored: Incremental cost increase, $/yr

Semiannually 45,941 w/out credit w/ credit

Pumps plus valves 1,251 -3,652

Option 3 with valves monitored: Pumps, valves, and connectors 28,381 15,007

Semiannually 73,071

Incremental cost effectiveness

w/out credit w/ credit w/out credit w/ credit

Operating hours/yr 8,760 Pumps plus valves 230 -670 208 -608

Pumps, valves, and connectors 1,910 1,010 1,733 916

$/Mg removed $/ton removed

$/Mg removed $/ton removed

$/Mg removed $/ton removed

Option 1 Summary M-2
Calculation of Nationwide Emissions Estimates and Costs -- Option 1

Total number of process units potentially subject to subpart VV 1,272Total number of affected process units in fifth year after proposal 191Total number of new/reconstructed sources subject to Option 1 in 5th year 39 (assumes 15 percent of processes are at area sources and 20 percent of the process units at major sources subject to the MON emit VOC only, not HAP; also assumes that these process units are the only process units not already subject to a NESHAP that has the same requirements as Option 1)OPTION 1

Emission Incremental Increm

reduction Number of total emiss

per process, process annual reduct

Mg/yr baseline option 1 Incremental units costs, $/yr Mg/

Newsimple 0.87 23,109 23,315 205 12.1 2,474 10 medium 2.82 32,298 32,955 657 7.7 5,028 22 complex 5.45 44,690 45,941 1,251 3.5 4,352 19 Reconstructedsimple 0.87 18,981 19,764 782 8.0 6,287 7 medium 2.82 25,185 27,600 2,415 5.1 12,318 14 complex 5.45 32,826 37,246 4,419 2.3 10,247 13 total 38.6 40,707 84.

w/ Credit -35,731 

Total annual cost per process, $

Nationwide impacts in fifth year af

Option 1 Summary