Date: October 30, 2007 

To: Karen Rackley, EPA/SPPD 

From: Kristin Parrish, David Randall, and Jeff Coburn 

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

Petroleum Refineries 

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 petroleum refining industry 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 13 26,000 2,100 20,000 1,500 

2 105 1,900,000 18,000 1,800,000 18,000 

3 107 1,900,000 18,000 1,900,000 17,000 

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 estimate that there are approximately 150 currently operating petroleum refineries, 

including asphalt refineries, according to the Oil and Gas Journal1

 and the Energy Information 

Administration.2 Based on 2004 reported crude capacity, we estimate that about two-thirds of 

the existing refineries are classified as “large” (i.e., crude capacity of 50,000 barrels per day or 

greater) and the remaining one-third are classified as “small” (i.e., crude capacity below 

50,000 barrels per day). 

To project the number of new and reconstructed process units at petroleum refineries 

over the next five years, we reviewed information on construction projects reported in the Oil 

and Gas Journal between 2000 and 2005. However, this review revealed that most of the 

construction projects undertaken over the past five years were hydrotreating units and sulfur 

recovery units installed in response to new low-sulfur fuel standards; this trend is not expected to 

be representative of future projects. Also, in the past five years, there have only been a limited 

number of new and reconstructed processes beyond those required to meet the new fuel 

standards. However, the new energy bill, which includes some capital investment incentives, is 

expected to trigger several significant capacity expansion projects. For example, Wynnewood 

Refining in Oklahoma announced an expansion project that will significantly expand the 

refinery’s capacity.3

 BP also recently announced a major renovation project at its refinery in 

Whiting, Indiana.4

 Following proposal, Motiva Enterprises announced plans to begin 

construction on an expansion that will more than double the capacity at their refinery in Port 

Arthur, Texas.5

 Based on discussions with refinery representatives, future projects such as these 

are expected to encompass the full range of refinery process units. In other words, the process 

mix of new projects is expected to look like the overall process mix of existing refineries. Based 

on the above information, we assumed that the new and reconstructed projects over the next five 

years would be equivalent to three complete refineries (crude unit, vacuum distillation unit, 

cracking and reforming units, etc.), two large refineries and one small refinery. This assumption 

is equivalent to assuming an overall refining industry growth rate of 2 percent per year. 

2 
 

We then estimated the average number of each type of process unit at one refinery using 

information about the number of process units across the industry from the Oil and Gas Journal

and information collected for the development of the National Emission Standards for Hazardous 

Air Pollutants (NESHAP) for Petroleum Refineries: Catalytic Cracking Units, Catalytic 

Reforming Units, and Sulfur Recovery Units (40 CFR part 63, subpart UUU).6 Based on 

knowledge of the typical inlet and outlet streams for each process unit, we then estimated the 

fraction of the equipment associated with those process units that are expected to be in VOC 

service and in non-hazardous air pollutant (non-HAP) VOC service. Using these calculations 

and the growth rate described above, we estimate that there will be 217 new or reconstructed 

petroleum refining process units in the next five years, that 195 of those process units will be in 

VOC service, and that 70 of those process units will be in non-HAP VOC service (equivalent to 

about 36 percent of the units in VOC service). 

To determine the total (nationwide) number of pumps and valves in these process units, 

we used the equipment counts presented for small and large refineries in Locating and 

Estimating Air Emissions from Sources of Benzene.

7

 We assumed that the proportion of small to 

large new and reconstructed process units would be equal to the proportion of small to large 

existing refineries. In other words, we assumed that two-thirds of the new and reconstructed 

process units would be at large refineries and used the associated equipment counts for those 

process units. We then calculated the number of pumps and valves in VOC service and in nonHAP VOC service using the fractions described in the previous paragraph. All the calculations 

described up to this point are documented in Attachment A. 

The impacts of Option 1 will be different for the equipment in each process unit 

depending on what Federal rules, regulations, and consent decrees already require monitoring at 

these lower leak definitions. (Some State regulations may require chemical plants and petroleum 

refineries to meet lower leak definitions as well. Therefore, the actual cost and emissions 

impacts of Option 1 may be less than our estimate, but the cost-effectiveness of Option 1 will not 

be affected.) To account for the differences in baseline conditions (e.g., initial costs incurred, 

current leak definition), we developed six models representing new and reconstructed equipment 

and process units subject to the NSPS or more stringent regulations. Assuming that 60 percent 

of the equipment and process units are new and 40 percent are reconstructed, we developed 

separate models for new and reconstructed equipment and 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. We also estimated that on a 

refining capacity basis, 76.5 percent of the petroleum refining industry is subject to a consent 

decree.1, 8 (See Section II.C for a more detailed explanation of how the models differ.) 

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 valves in gas service and light liquid 

service and the number of pumps in light liquid service. We also estimated the number of 

process units for each model in order to calculate the administrative costs that are determined on 

a process unit basis. Table 1 explains how the numbers of process units and equipment in each 

model were developed and shows the number of process units per model as an example. Table 2 

shows the numbers of process units and equipment calculated for each model. Attachment B 

3 
 

includes a pictorial representation of the model development, again using the number of process 

units as an example. 

B. Emission Estimates

The analysis uses industry-supplied data to the extent possible. We started with the data 

that the American Petroleum Institute (API) summarized in the 1997 report Analysis of Refinery 

Screening Data.

9

 The API report summarizes leak frequencies (in leak concentration ranges) for 

leak detection and repair (LDAR) programs that have a leak definition of 1,000 ppm and require 

quarterly monitoring. To estimate baseline emissions (i.e., LDAR programs with leak definitions 

of 10,000 ppm for pumps and valves under NSPS and leak definitions of 2,000 and 1,000 ppm 

for pumps and valves, respectively, under the NESHAP for Petroleum Refineries (40 CFR part 

63, subpart CC) (MACT)) and emissions for Option 1 (i.e., leak definitions of 500 and 2,000 

ppm), we used data from the API report (including the distribution of leaking equipment over 

seven concentration ranges), the correlation equations found in Table 2-10 of the Protocol for 

Equipment Leak Emission Estimates10 (Protocol document), and the following information and 

assumptions: 

 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, an average concentration was chosen for each range 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 data presented in the API report for valves leaking above 500 ppm when the leak 

definition is 1,000 ppm will reasonably represent the percent of valves leaking above 

500 ppm when the leak definition is 500 ppm 

 ninety percent of the equipment with emission rates below 500 ppm have a 

concentration of 0 ppm and 10 percent of the equipment actually have leak 

concentrations between 0 and 500 ppm; and 

 the data provided in the API report for pumps leaking above 1,000 ppm when the leak 

definition is 1,000 ppm will reasonably represent the percentage of pumps leaking 

above 2,000 ppm when the leak definition is 2,000 ppm. 

 

The relevant data from the Protocol document and Analysis of Refinery Screening Data are 

reproduced in Attachment C. 

Before performing our calculations to estimate emissions for the different monitoring 

programs as described above, we applied a factor of 1.7 to the original API leak frequency values 

(“NEIC factor”). The factor was based on a comparison of industry versus U.S. EPA National 

Enforcement Investigations Center (NEIC) data on leak frequency for valves at 17 refineries in 

Enforcement Alert: Proper Monitoring Essential to Reducing 'Fugitive Emissions' Under Leak 

Detection and Repair Programs.

11 Specifically, the NEIC 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 industry. A more rigorous statistical 

4 
 

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, a value of 1.7 for the NEIC factor is more conservative, 

which ensures that emissions estimates are not overestimated due to any limitations in the data 

used in the statistical analysis.12

Our emissions calculations are documented in Attachment D. The first step was to 

calculate leak frequencies for pumps and valves above the leak definition under the various 

LDAR programs (baseline and Option 1). The API data include leak frequencies for gas and 

light liquid valves leaking above 500 ppm and 1,000 ppm as well as a leak frequency for pumps 

leaking above 1,000 ppm. These values are based on quarterly monitoring. The other leak 

frequencies needed for this analysis are as follows: 

 Leak frequencies for semiannual and annual monitoring of valves at 500 and 1,000 

ppm 

 Leak frequencies for valves at 10,000 ppm at various monitoring frequencies 

 Leak frequency for monthly monitoring of pumps at 1,000 ppm 

 Leak frequencies for quarterly and monthly monitoring of pumps at 10,000 ppm 

The results of these calculations are presented in Table 3 and Attachment D. 

Valves – 500 and 1,000 ppm, Semiannual and annual monitoring 

To estimate leak frequencies for valves at monitoring frequencies other than quarterly for 

leak definitions of 500 and 1,000 ppm, we used the numbers of each type of equipment found to 

be leaking more than once in four consecutive quarters as provided in the API report (“repeat 

leakers”) to determine the number of unique leaks found during a particular monitoring event. 

This approach ensures that each leaking valve is counted only once for semiannual and annual 

monitoring scenarios. The calculations can be described by Equations 1 and 2: 

 VFS = 

Q

Q

Q VL

VF

VR VR VR VL *

3

*2

3

*2 4

2 3 ⎟

⎠

⎞ ⎜

⎝

⎛ −−− Equation 1 

where 

VFS = Leak frequency for semiannual monitoring, percent 

VFQ = Leak frequency for quarterly monitoring, percent 

VLQ = Number of valves leaking per quarter 

VR2 = Number of valves leaking twice in four consecutive quarters 

VR3 = Number of valves leaking three times in four consecutive quarters 

VR4 = Number of valves leaking four times in four consecutive quarters 

5 
 

 VFA = (( ) ( )( ))

Q

Q

Q VL

VF

*4 VRVL VR VR **3*2 2 3 −−− 4 Equation 2 

where 

VFA = Leak frequency for annual monitoring, percent 

VFQ = Leak frequency for quarterly monitoring, percent 

VLQ = Number of valves leaking per quarter 

VR2 = Number of valves leaking twice in four consecutive quarters 

VR3 = Number of valves leaking three times in four consecutive quarters 

VR4 = Number of valves leaking four times in four consecutive quarters 

Valves – 10,000 ppm 

The average leak frequency for valves from the NEIC data is 1.28 percent; we assumed 

that these valves are subject to the existing NSPS or equivalent requirements and that half of the 

valves monitored were in gas service and the other half were in light liquid service. Based on 

information provided by the petroleum refining industry,13 we estimated that the average valve 

monitoring frequency for facilities currently subject to NSPS subpart GGG is semiannual 

monitoring. Based on the relationship between the leak frequency of valves in gas/vapor service 

and valves in light liquid service presented in the API report, we calculated leak frequencies of 

1.18 percent for gas valves and 1.38 percent for light liquid valves when monitoring is conducted 

semiannually. To estimate the leak frequency for quarterly monitoring at 10,000 ppm, we 

assumed that the ratio of the leak frequencies for quarterly monitoring to semiannual monitoring 

is equal to the ratio of the leak frequencies for monitoring at 1,000 ppm. The leak frequency for 

annual monitoring was estimated using the same approach. 

Pumps – 1,000 ppm 

For quarterly monitoring of pumps at 1,000 ppm, we selected the leak frequency value 

directly from the API data (2.77 percent). We used this leak frequency and data in the API 

report on the number of repeat leakers to estimate the leak frequency for a monthly monitoring 

program. If there were no repeat leakers, the leak frequency for a monthly program would be 

equal to one-third of the leak frequency under the quarterly monitoring program (i.e., 2.77 

percent/3 = 0.92 percent). However, because of repeat leakers, the actual leak frequency for a 

monthly monitoring program will be higher than 0.92 percent. To estimate the additional 

number of leakers that would be found under a monthly monitoring program, we first assumed 

that all of the pumps in the API study that leaked in each of four consecutive quarters (i.e., 12 

pumps) actually begin leaking in the first month after repair attempts, so that this same number 

of leakers also would be found in the second and third months of a monthly monitoring program. 

We then considered the number of pumps in the API study that leaked twice over four quarters 

(i.e., 207 pumps). Under a monthly monitoring program, one-third of these leakers (i.e., 69 

pumps) would be found to be leaking in each of the three months. We assumed that after repair, 

these pumps would still leak two times per year. Thus, on average, one-sixth of them (i.e., 11.5 

pumps) would leak again in each of the six months after repair. We assumed that this same 

pattern applies to the 11.5 pumps that are repaired after being found leaking in the second month, 

so that one-sixth of them (i.e., 1.9 pumps) will be found leaking in the third month. We followed 

6 
 

a similar strategy to estimate the additional number of leakers from the group of pumps that 

leaked three times in four quarters in the API study. Finally, we added the total number of 

additional leakers to the number of leakers under the quarterly monitoring program. This 

number divided by the number of leakers in the quarterly monitoring program is the escalation 

factor that was multiplied by 0.92 percent. This approach may slightly overstate the leak 

frequency for a monthly monitoring program because the repaired pumps would not necessarily 

continue leaking the same number of times per year. Thus, the actual leak frequency for a 

monthly monitoring program may be between 0.92 percent and the estimate of 0.98 percent 

calculated using the approach described above. This approach can be represented 

mathematically using Equation 3: 

Q

Q Q

M PL

PF PR

PRPR PRPR

PL

PF *

3

*2

4*4*34*3

*2

6*6*36*3

*2

4

2 2 3 3

⎟

⎟

⎟

⎟

⎠

⎞

⎜

⎜

⎜

⎜

⎝

⎛ +++++

= Equation 3 

where 

PFM = Leak frequency for monthly monitoring, percent 

PFQ = Leak frequency for quarterly monitoring, percent 

PLQ = Number of pumps leaking per quarter 

PR2 = Number of pumps leaking twice in four consecutive quarters 

PR3 = Number of pumps leaking three times in four consecutive quarters 

PR4 = Number of pumps leaking four times in four consecutive quarters 

Pumps – 10,000 ppm 

We calculated the quarterly leak frequency value for pumps at 10,000 ppm assuming that 

the ratio of the leak frequency for valves leaking greater than 10,000 ppm at a leak definition of 

10,000 ppm to the leak frequency for valves leaking greater than 10,000 ppm at a leak definition 

of 1,000 ppm is equal to the same ratio for pumps (all monitored quarterly). Specifically, this 

value was calculated using Equation 4: 

⎟

⎟

⎟

⎟

⎟

⎠

⎞

⎜

⎜

⎜

⎜

⎜

⎝

⎛

+

= 2* 000,1;

000,10;

000,1;

000,10;

000,10 000,1

LL

LL

G

G

VF

VF

VF

VF

PF PF Equation 4 

where all variables are for equipment leaking greater than 10,000 ppm and monitored quarterly 

and 

PF10,000 = Leak frequency for pumps with a leak definition of 10,000 ppm, percent 

PF1,000 = Leak frequency for pumps with a leak definition of 1,000 ppm, percent 

(from API data) 

7 
 

VFG;10,000 = Leak frequency for gas valves with a leak definition of 10,000 ppm, 

percent 

VFG;1,000 = Leak frequency for gas valves with a leak definition of 1,000 ppm, percent 

(from API data) 

VFLL;10,000 = Leak frequency for light liquid valves with a leak definition of 10,000 

ppm, percent 

VFLL;1,000 = Leak frequency for light liquid valves with a leak definition of 1,000 ppm, 

percent (from API data) 

We assumed that the ratio of leak frequency values for pumps at a leak definition of 10,000 ppm 

monitored monthly to those monitored quarterly is equal to the ratio of pumps monitored at those 

frequencies with a leak definition of 1,000 ppm. 

Once we calculated the necessary leak frequencies, the next step was to calculate 

emission factors. Our general approach was to calculate an emission rate for each of seven 

concentration ranges using the estimated representative screening value for that range in the 

appropriate correlation equation from the Protocol document. We then scaled the distributions 

presented in the API data based on the leak frequency and multiplied the percent of pumps or 

valves leaking in each range by the emission rate for that range and summed these values to 

estimate the emission factor. 

There are four sets of calculations associated with determining emission factors, two for 

Option 1 (Set 1 and Set 2) and two for baseline (Set 3 and Set 4): 

Set 1 – Leak frequency distribution prior to monitoring, option leak definition 

 The appropriate subsequent leak frequencies (shown in bold type in Table 3) and 

the NEIC factor are used to determine actual leak frequency distributions at leak 

definitions of 500 or 1,000 ppm, depending on the type of equipment, just prior to 

monitoring. Although an emission factor is shown in Attachment D, the purpose 

of this Set is solely to determine the leak frequency distribution for Option 1. 

Set 2 – Average leak frequency, control at option leak definition 

 The Set 1 leak frequencies for ranges that are above the appropriate proposed leak 

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

frequency between monitoring events for that control program. The resulting 

emission factor for this set is used to calculate emissions for Option 1 conditions. 

Set 3 – Leak frequency prior to monitoring, baseline leak definition 

 The appropriate baseline leak frequencies (shown in italics in Table 3) are used to 

scale the API data and obtain an estimate of the leak frequency distribution at 

baseline (e.g., a leak definition of 10,000 ppm for process units complying with 

subpart GGG). Although an emission factor is shown in Attachment D, the 

purpose of this Set is solely to determine the leak frequency distribution at 

baseline. 

Set 4 – Average leak frequency, control at baseline leak definition 

The Set 3 leak frequencies in concentration ranges above the baseline leak 

definition are divided by 2 to estimate the average leak frequency between 

monitoring events at that leak definition (e.g., 10,000 ppm for process units 

8 
 

complying with subpart GGG). The resulting emission factor for this set is used 

to calculate emissions for baseline conditions. 

The last row of each set of calculations shows the emission rate for each range of concentrations. 

As described previously, we calculated the overall emission rates by multiplying the emission 

rate for each range by the percent of equipment in that range and summing those seven 

intermediate values. The resulting emission factors are summarized in kilograms per hour 

(kg/hr) per piece of equipment in the first table in Attachment E. (As a side note, we first 

compared the results of Set 1 for each type of equipment to the emissions documented in the API 

report, and the results were similar. Therefore, we concluded that the procedure could 

reasonably approximate the emissions for baseline and for the two options.) 

Finally, we calculated total emission reductions by determining the difference between 

the baseline and Option 1 emission factors appropriate for each model and multiplying those 

values by the number of pumps and valves in that model. The nationwide emission reductions 

are the sum of the emission reductions for each model. All of the emission reduction values are 

presented in Tables 5 and 6. 

There is one final set of calculations below the emission factor calculations, which is 

used to calculate the initial leak frequencies for the models in which the leak definitions change 

from baseline to Option 1. The initial leak frequency is the leak frequency at the lower leak 

definition the first time the equipment are monitored at that definition rather than the baseline 

leak definition. Set 5 uses the subsequent leak frequency for baseline conditions to scale the leak 

frequency distribution calculated in Set 3. We then calculated the initial leak frequency by 

summing the leak frequencies in all ranges above the new leak definition. For example, the 

baseline subsequent leak frequency for gas valves subject to subpart GGG is 1.18 percent; to find 

the initial leak frequency the first time those valves are monitored at 500 ppm, we added the 

leaks found in the ranges 500 to 1,000 ppm and 1,000 to 10,000 ppm, for an initial leak 

frequency of 4.76 percent. The initial leak frequencies used in the analysis are presented in the 

third table of Attachment E. 

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 petroleum refining 

industry. 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 instruments because petroleum refiners have 

already purchased or made arrangements for those items under the current LDAR requirements. 

Attachment F 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: 

9 
 

Equipment-based costs 

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

$17.70 per piece of equipment includes field identification of subject equipment; 

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

valves, and connectors; 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 

piece of equipment 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 piece of 

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

 Wage (refinery 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 $23.30 per hour is the mean wage rate for Standard 

Occupational Classification (SOC) Code 49-9012 (control and valve installers, except 

mechanical doors) in NAICS 324 (Petroleum and Coal Products Manufacturing) in 

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

(This wage rate is for refinery 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 refinery 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 $68.78 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 ($38.29), 

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

($59.15), and the clerical rate is based on the mean for all office and administrative 

support occupations ($17.46). A 60 percent overhead factor was added to these rates. 

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

Manual 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: The value of $600 per megagram (Mg) is an approximate 

conversion from an estimate of $1.50 per gallon. That estimate assumes that the 

value of recovered VOC would fall between the average of the price of crude ($56.45 

10 
 

per barrel on January 20, 2006) and the nationwide average price of gasoline ($1.849 

per gallon without taxes in January 2006).20

Process unit-based costs 

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

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).21

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

MACT 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;22 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.

The last step in the analysis set-up was to determine values for parameters that influence 

each of the six models, such as initial costs and reporting costs. Table 4 summarizes the values 

and parameters defined for each model. One of these parameters is the monitoring frequency. 

All models have monthly monitoring for pumps at baseline because all of the applicable rules or 

consent decrees require monthly monitoring. Monthly monitoring of pumps is also assumed for 

Option 1 because other rules with leak definitions of 2,000 ppm also require monthly monitoring. 

The monitoring frequency for valves is quarterly for some models and semiannual for others, 

depending on the applicable requirements. 

For the models “New CD” and “Reconstructed CD,” we assumed the monitoring 

frequency would be quarterly for valves both at baseline and under Option 1. Most consent 

decrees require quarterly monitoring for valves, and many do not allow any quarterly monitoring 

periods to be skipped based on the leak frequency. For the models “New MACT” and 

“Reconstructed MACT,” we assumed the monitoring frequency would be semiannual for valves 

both at baseline and under Option 1. The MACT allows less frequent monitoring for valves in 

new and reconstructed process units depending on the percent of valves determined to be leaking 

(see §63.648(c)(2) and Table 8 to subpart CC to 40 CFR part 63). Annual monitoring is allowed 

if the leak frequency is less than 2 percent, semiannual monitoring is allowed for if the leak 

frequency is less than 3 percent, and quarterly monitoring is allowed if the leak frequency is less 

than 4 percent. As shown in Table 3, leak frequencies for valves are greater than 2 percent when 

monitored annually under an LDAR program with either a 1eak definition of 1,000 or 500 ppm 

(baseline and Option 1, respectively), which suggests that for an average process unit, 

semiannual monitoring would be required. 

For the models “New NSPS” and “Reconstructed NSPS,” we assumed that the “skip 

period” monitoring provisions in §60.483-2 would be followed. As noted in the discussion of 

the average leak frequency for valves at baseline, we assumed that the baseline monitoring 

frequency for valves is semiannual. At the lower leak definitions of Option 1, we estimated that 

the leak frequencies would increase but would remain less than 2 percent for semiannual 

11 
 

monitoring (see Table 3). Therefore, we assumed that most valves would continue to be 

monitored semiannually. See Attachment G for detailed costs for each of the six models. 

III. Monitoring of Connectors 

A. Number of Impacted Sources

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

and the six models described in Section II.A. The number of connectors used in the analysis is 

shown in Table 2; we note that similar to the analysis for pumps and valves, we focused on 

connectors in gas and light liquid service. No Federal regulations currently require petroleum 

refineries to include connectors in their LDAR programs. Therefore, we anticipate that Option 2 

will affect all of the new and reconstructed process units in this analysis. 

B. Emission Estimates

We estimated the emissions from leaking connectors using the procedures described in 

Section II.B with different leak frequencies and a few additional assumptions. Because 

petroleum refiners are not currently required to monitor connectors, we assumed that baseline 

emissions per connector are the same across all six models. We assumed that the initial leak 

frequency in Table G-2 of the Protocol document (1.7 percent) reasonably represents connectors 

at baseline conditions because this is the only available leak frequency data for connectors at 

refineries subject to the existing NSPS. We did not escalate this leak frequency by the NEIC 

factor because the monitoring that generated the data in the Protocol document was assumed to 

be conducted in a manner consistent with monitoring conducted by NEIC. 

The subsequent leak frequency for connectors is based on the data in the API report and 

the assumptions that monitoring is conducted annually. The API report includes leak frequencies 

for connectors in gas service and light liquid service that comply with LDAR programs that 

require quarterly monitoring and a leak definition of 1,000 ppm. Similar to valves, we assumed 

that the data presented in the API report for connectors leaking above 500 ppm will reasonably 

represent the percent of connectors leaking above 500 ppm when the leak definition is 500 ppm. 

We also assumed that half of the affected connectors are in gas service and half are in light liquid 

service, so we averaged the two leak frequencies. To estimate the leak frequency for annual 

monitoring, we used a simplified version of Equation 2 that assumes that multiplying the 

quarterly leak frequency by 4 results in an annual leak frequency that is 10 percent high (i.e., 10 

percent of the leaking connectors leak more than once in a year). The resulting subsequent leak 

frequency is 0.81 percent. 

Once we calculated the necessary leak frequencies, the next step was to calculate 

emission factors. We assumed that half of the connectors are flanges and half are other types of 

connectors. Therefore, we calculated the emission rate in each concentration rate by averaging 

the flange and connector correlation equation results. We then used the same approach as 

described in Section II.B, although we only needed three sets of calculations (Set 1 and Set 2 to 

estimate the Option 2 emissions and Set 3 to estimate baseline emissions). Set 4 and Set 5 are 

not needed because the baseline for connectors is no control. We calculated the overall emission 

rates by multiplying the emission rate for each range by the percent of equipment in that range 

12 
 

and summing those seven intermediate values. The resulting emission factors are summarized in 

kilograms per hour (kg/hr) per piece of equipment in the first table in Attachment E. 

Finally, we calculated total emission reductions by determining the difference between 

the baseline and Option 1 emission factors appropriate for each model and multiplying those 

values by the number of connectors in that model. The nationwide emission reductions are the 

sum of the emission reductions for each model. All of the emission reduction values are 

presented in Tables 5 and 6. 

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 petroleum refining 

industry. To calculate the 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. 

In addition to the unit costs provided in Section II.C, we estimated costs as follows: 

Equipment-based costs 

 Monitoring fee (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.23 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.

Process unit-based costs 

 Planning and training for LDAR program, including connectors: 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, including connectors: 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. 

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. 

13 
 

 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 nearly all (if not all) 

facilities already have enough equipment to be charged the top fee, so adding 

connectors would not drive up the costs. 

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) documenting leaks from OEL 

that currently are subject to standards that require the use of a cap, plug, blind flange, or second 

valve to control emissions from leaks.24 Industry also provided additional data on monitoring 

and repair of OEL at petroleum refineries.25, , 26 27 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 petroleum 

refineries to include OEL in their LDAR programs. 

A. Number of Impacted Sources

To estimate the number of OEL impacted nationwide, we used the analysis described in 

Section II.A (although we did not allocate the OEL to the six models because OEL in all new 

and reconstructed process units would be affected, and there is no difference in the costs for new 

versus reconstructed process units). As mentioned previously, we estimated that there will be 

195 new and reconstructed refinery process units in VOC service over the next five years. The 

number of OEL in these process units was estimated to be 7,349 based on the estimates of the 

number of OEL for different types of process units at small and large model refineries, the 

weighted distribution of the different types of process units at an average refinery, and the 

fraction of OEL per process in VOC service. This analysis is based on monitoring OEL in 

gas/vapor service and light liquid service (not OEL in heavy liquid service). Based on data 

collected prior to proposal of subpart CC to 40 CFR part 63 (presented in Attachment A), 

73 percent of all valves, pumps, and flanges are in gas/vapor and light liquid service. Since OEL 

are in contact with the same types of fluid as other equipment, we assumed that 73 percent of 

OEL, or 5,365 OEL, are also in gas/vapor or light liquid service. Finally, we assumed that 

5 percent of OEL are in sampling connection systems and would therefore not be monitored, 

leaving a total of 5,097 affected OEL. The rationale for not monitoring OEL in sampling 

connection systems is provided below. 

These OEL counts were derived from a summary of equipment counts supplied by the 

industry about 15 years ago in responses to an information collection request that was distributed 

during development of the MACT standards in 40 CFR part 63, subpart CC. However, recentlyprovided industry data included OEL counts that are orders of magnitude higher than those 

earlier counts.25-27 They also are at least an order of magnitude higher than the counts that would 

14 
 

be obtained using models on page 6-3 of the Background Information Document for the 

proposed standards in subpart GGG.28 The reason for the discrepancy is not clear. We 

conducted a sensitivity analysis as part of the revised analysis to assess the impact of higher 

counts and found that the emissions and emission reduction increase in direct proportion with 

number of OEL, but the costs increase at a slower rate. 

B. Emission Estimates

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. Industry also provided additional leak frequency data for OEL.25,27 The baseline 

leak frequency was estimated to be 2.3 percent, the highest value provided in the industry data. 

(Using the average of the data rather than the maximum leak frequency would result in smaller 

emission reductions with little reduction in cost; the maximum leak frequency results in a bestcase cost-effectiveness.) 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 2.3 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. 

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 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 

15 
 

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

provides a reasonable proxy for estimating leaks 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 2.3 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 2.3 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 1.15 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 

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 1.2 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 

16 
 

have been last opened in October, November, or December, and 2.3 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, 2.3 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 5, 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 5 

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 assume 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 6, which we 

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 6 

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 H for 

17 
 

the results of these calculations. The nationwide emission reduction is estimated to be 

2.2 tons/yr, as shown in Tables 5 and 6. 

C. Cost Analysis

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

costs include costs for identifying and integrating OEL 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, 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 $600/Mg for 

emission reductions at petroleum refineries. 

V. Alternate Leak Definition for Valves 

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

the 500 ppm level in Option 1 to 100 ppm. The number of affected valves in each of the six 

models is the same as calculated in Section II.A. The procedures used to calculate the emission 

reduction and cost estimates were similar to the procedures described above for a leak definition 

of 500 ppm. Details of the calculations for this option are provided in the following paragraphs 

and Attachment I. 

As described previously, we calculated leak frequency values for semiannual monitoring 

and repair of leaks at leak definitions of 10,000, 1,000, and 500 ppm. The best fit for these 

values was a logarithmic curve, and we used this curve to extrapolate the trend and estimate the 

percent of valves leaking at 100 ppm. These values were calculated to be 2.45 percent for gas 

valves and 2.25 percent for light liquid valves. Because these values are greater than 2.0 percent, 

we concluded that these valves would require quarterly monitoring. We assumed that the ratio of 

18 
 

the leak frequency for semiannual monitoring to the leak frequency for quarterly monitoring at 

100 ppm is equivalent to the same ratio at 500 ppm. 

For this analysis, we assumed that the distribution of leaking valves above 500 ppm 

remained the same as for the analysis with a leak definition of 500 ppm, so the additional leaking 

valves were all assumed to have a magnitude between 100 ppm and 500 ppm. Emission 

reductions were calculated as described in Section II.B; the only additional calculation needed 

was the initial leak frequency for reconstructed and modified process units subject to a consent 

decree. See Attachment I for the emission factor calculations. The incremental emission 

reduction, or the emission reduction achieved by lowering the valve leak definition from 500 to 

100 ppm, is 8.1 tons per year. 

The unit costs for this analysis are the same as described in Section II.C, and the cost 

calculations are shown in Attachment I. The total cost to repair valves leaking above 100 ppm is 

greater than repairing valves leaking above 500 ppm (Option 1) because more valves need repair. 

In addition, monitoring costs are higher because the additional leaking valves raise the average 

leak frequencies for semiannual monitoring to greater than 2 percent. Therefore, all process 

units are expected to monitor quarterly, not just those process units at refineries subject to a 

consent decree. The incremental cost, or the cost incurred by lowering the valve leak definition 

from 500 to 100 ppm, is $130,000 per year. The cost-effectiveness of achieving the additional 

emission reductions is $16,000 per ton of VOC. 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 5 and 6, respectively. Detailed results are also presented in Attachment J. Results of the 

emissions reductions and annual costs of both options are shown for all six models. As 

discussed in Section II.A, there are no emissions reductions or increased costs under Option 1 for 

process units subject to a consent decree. Only the impacts on the process units subject to 

MACT for new sources or subpart GGG affect the Option 1 cost-effectiveness result. All 

process units show emissions reductions and increased costs for Options 2 and 3. Without 

considering recovery credit, cost-effectiveness ranges from $2,100/ton of VOC reduced under 

Option 1 to $18,000/ton of VOC reduced under both Option 2 and Option 3. When recovery 

credits are included, the cost-effectiveness ranges from $1,500/ton of VOC reduced under 

Option 1 to $18,000/ton of VOC reduced under Option 2; the cost-effectiveness for Option 3 is 

$17,000/ton. Increasing the total number of OEL by a factor of 20 decreases the costeffectiveness for Option 3 slightly to $16,000/ton. 

19 
Table 1. Development of Process Unit and Equipment Counts for Six Models 

Model 

Basis for 

Applicability Service 

Most Stringent 

Requirement at 

Baseline 

Calculation of Number 

Process Units and Equipm

1 “New CD” Construction Total VOC Consent decree = X * CD * N 2 “New MACT” Construction HAP 40 CFR part 63, subpart CC = X * (1 – CD) * HAP * N 3 “New NSPS” Construction Non-HAP VOC 40 CFR part 60, subpart GGG = X * (1 – CD) * (1 – HAP4 “Reconstructed CD” Reconstruction or Modification Total VOC Consent decree = X * CD * R 5 “Reconstructed MACT” Reconstruction or Modification HAP 40 CFR part 63, subpart CC = X * (1 – CD) * HAP * R 6 “Reconstructed NSPS” Reconstruction or Modification Non-HAP VOC 40 CFR part 60, subpart GGG = X * (1 – CD) * (1 – HAP

a Variables are defined as follows: 

X = Total number of process units or equipment (e.g., pumps, valves) CD = Fraction of refinery process units subject to consent decree (0.765) 

HAP = Fraction of process units processing HAP (0.64) N = Fraction of process units subject to GGGa through construction (0.60) R = Fraction of process units subject to GGGa through reconstruction or modification (0.40) 

20 
Table 2. Number of Affected Process Units and Equipment in the Six Models 

Model 

Number of: “New CD” 

“New 

MACT” 

“New 

NSPS” 

“Reconstructed 

CD” 

“Reconstructed 

MACT” 

“Reco

N

Process Units 89 18 10 60 12 Gas Valves 14,014 2,837 1,474 9,343 1,892 Light Liquid Valves 28,223 5,498 3,184 18,815 3,665 2Light Liquid Pumps 802 158 88 535 105 Gas Connectors 33,169 6,739 3,464 22,113 4,493 2Light Liquid Connectors 61,926 12,080 6,970 41,284 8,053 4Gas and Light Liquid OELa a Excludes OEL in sampling connection systems 

21 
 

Table 3. Summary of Leak Frequency Valuesa

Monitoring Frequency Monthly Quarterly Semiannual Annual 

Component and Leak Definition Leak Frequency, percent 

Pumps 

10,000 ppm 0.88 2.47 

1,000 ppm 0.98 2.77 

Gas Valves 

10,000 ppm 0.61 1.18 2.32 

1,000 ppm 0.88 1.69 3.31 

500 ppm 1.00 1.91 3.73 

Light Liquid Valves 

10,000 ppm 0.72 1.38 2.70 

1,000 ppm 0.86 1.65 3.23 

500 ppm 1.03 1.97 3.83 

Connectors 

Baseline 1.7 

500 ppm 0.81 

a Italic font indicates baseline leak frequencies used in this analysis. 

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

22 
Table 4. Model Parameters for Each of the Petroleum Refinery Models 

Model “New CD” “New MACT” “New NSPS” 

“Reconstructed 

CD” 

“Reconstructed 

MACT” 

Leak definition:  Pumpsa Valves  Connectors 

2,000 500 N/A 

2,000 500 N/A 

10,000 10,000 N/A 

2,000 500 N/A 

2,000 500 N/A 

Monitoring frequency:  Pumps  Valves  Connectors 

Monthly Quarterly N/A 

Monthly Semiannual N/A 

Monthly Semiannual N/A 

Monthly Quarterly N/A 

Monthly Semiannual N/A 

Initial leak frequency/ costs 

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

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

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 

Planning and training costs 

320 hours per process unit 

320 hours per process unit 

320 hours per process unit 

320 hours per process unit 

320 hours per process unit 

Baseline 

Administrative report costs 

250 hours per process unit 

250 hours per process unit 

250 hours per process unit 

250 hours per process unit 

250 hours per process unit 

23 
Table 4. (Continued) 

“Reconstructed “Reconstructed 

Model “New CD” “New MACT” “New NSPS” CD” MACT” 

Leak definition:  Pumpsa Valves  Connectors 

2,000 500 N/A 

2,000 500 N/A 

2,000 500 N/A 

2,000 500 N/A 

2,000 500 N/A 

Monitoring frequency:  Pumps  Valves  Connectors 

Monthly Quarterly N/A 

Monthly Semiannual N/A 

Monthly Semiannual N/A 

Monthly Quarterly N/A 

Monthly Semiannual N/A 

Initial leak frequency/ costs 

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

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

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 

Planning and training costs 

320 hours per process unit 

320 hours per process unit 

320 hours per process unit 

320 hours per process unit 

320 hours per process unit

Option 1 

Administrative report costs 

250 hours per process unit

250 hours per process unit

250 hours per process unit

250 hours per process unit

250 hours per process unit

24 
Table 4. (Continued) 

“Reconstructed “Reconstructed 

Model “New CD” “New MACT” “New NSPS” CD” MACT” 

Leak definition:  Pumpsa Valves  Connectors 

2,000 500 500 

2,000 500 500 

2,000 500 500 

2,000 500 500 

2,000 500 500 

Monitoring frequency:  Pumps  Valves  Connectors 

Monthly Quarterly Annual 

Monthly Semiannual Annual 

Monthly Semiannual Annual 

Monthly Quarterly Annual 

Monthly Semiannual Annual 

Initial leak frequency/ costs 

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

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

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

Partial – Only includes initial costs for adding connectors to program 

Partial – Only includes initial costs for adding connectors to program 

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 

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

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

25 
Table 5. Summary of Impacts for Petroleum Refineries Not Including Recovery Credi

Factor New CD 

New 

MACT New NSPS 

Reconstructed 

CD 

Reconstructed 

MACT 

Recons

NS

Baseline costs, $/yra 2,500,000 670,000 250,000 1,400,000 310,000 140

Emission reduction, 

tons/yr 

0 1.2 6.4 0 0.78 4

Option costs, $/yrb 2,500,000 670,000 260,000 1,400,000 310,000 150Annual cost beyond 

baseline, $/yr 

0 7,400 6,400 0 6,400 6,3

Option 1 

Cost effectiveness, $/ton 

VOC removed 

N/A 6,300 1,000 N/A 8,100 1,5

Emission reduction, 

tons/yr 

42 9.5 11 28 6.3 7

Option costs, $/yrb 3,300,000 840,000 350,000 2,000,000 430,000 210Annual cost beyond 

baseline, $/yr 

850,000 180,000 100,000 570,000 120,000 69,

Option 2 

Cost effectiveness, $/ton 

VOC removed 

20,000 19,000 9,100 20,000 19,000 9,4

Emission reduction, 

tons/yr 

Option costs, $/yrb Annual cost beyond 

baseline, $/yr 

Option 3 

Cost effectiveness, $/ton 

VOC removed 

a Costs are only initial costs (if applicable) and ongoing costs for pumps and valves. b Costs are only ongoing costs for pumps, valves, connectors, and OEL; initial repair costs for pumps, valves, and connectors (if applica

training costs to implement the Option requirements. 

c Totals may not sum exactly due to rounding.

26 
Table 6. Summary of Impacts for Petroleum Refineries Including Recovery Credits 

Factor New CD New MACT New NSPS Reconstructed CD Reconstructed MACT Recons

NS

Baseline costs, $/yra 2,500,000 670,000 250,000 1,400,000 310,000 140

Emission reduction, 

tons/yr 

0 1.2 6.4 0 0.78 4

Option costs, $/yrb 2,500,000 670,000 260,000 1,400,000 310,000 140Annual cost beyond 

baseline, $/yr 

0 6,700 2,900 0 6,000 3,9

Option 1 

Cost effectiveness, $/ton 

VOC removed 

N/A 5,700 450 N/A 7,600 9

Emission reduction, 

tons/yr 

42 9.5 11 28 6.3 7

Option costs, $/yrb 3,300,000 840,000 350,000 2,000,000 420,000 210Annual cost beyond 

baseline, $/yr 

830,000 170,000 94,000 550,000 120,000 65,

Option 2 

Cost effectiveness, $/ton 

VOC removed 

20,000 18,000 8,600 20,000 18,000 8,8

Emission reduction, 

tons/yr 

Option costs, $/yrb Annual cost beyond 

baseline, $/yr 

Option 3 

Cost effectiveness, $/ton 

VOC removed 

a Costs are only initial costs (if applicable) and ongoing costs for pumps and valves. b Costs are only ongoing costs for pumps, valves, connectors, and OEL; initial repair costs for pumps, valves, and connectors (if applica

training costs to implement the Option requirements. 

c Totals may not sum exactly due to rounding.

27 
 

VII. References 

1. Stell, J., Ed. “2004 Worldwide Refining Survey.” December 20, 2004. Oil and Gas 

Journal. (Available online only: 

http://www.ogj.com/resourcecenter/survey.cfm#worldref.) 

2. U.S. Department of Energy, Energy Information Administration. June 2005. Petroleum 

Supply Annual 2004, Volume 1. DOE/EIA-0340(04)/1. 

http://www.eia.doe.gov/pub/oil_gas/petroleum/data_publications/petroleum_supply_annu

al/psa_volume1/historical/2004/psa_volume1_2004.html. 

3. OGJ Editors. October 24, 2005. “OGJ Newsletter.” Oil & Gas Journal, Vol. 103, Issue 

40. “Oklahoma refinery expansion planned,” p. 9. 

4. BP Global. September 20, 2006. “Midwest investment at Whiting, Indiana refinery also 

brings potential to add about 1.7 million gallons per day of motor fuels.” Press Release. 

http://www.bp.com/genericarticle.do?categoryId=2012968&contentId=7022964.

 

5. Motiva Enterprises LLC. September 21, 2007. “Motiva Port Arthur Refinery to Become 

Largest Refinery in United States.” Press Release. 

http://www.motivaenterprises.com/home/Framework?siteId=motiva-en&FC2=/motivaen/html/iwgen/motiva_media_center/press_releases/2007/zzz_lhn.html&FC3=/motivaen/html/iwgen/motiva_media_center/press_releases/2007/port_arthur_expansion_092107

.html. 

6. U.S. EPA, Office of Air Quality Planning and Standards. June 1998. Petroleum 

Refineries – Background Information for Proposed Standards: Catalytic Cracking (Fluid 

and Other) Units, Catalytic Reforming Units, and Sulfur Recovery Units. EPA-453/R98-003. 

7. U.S. EPA, Office of Air Quality Planning and Standards. June 1998. Locating and 

Estimating Air Emissions from Sources of Benzene. EPA-454/R-98-011. 

8. U.S. EPA, Office of Enforcement and Compliance Assurance. “Compliance and 

Enforcement: Cases and Settlements.” http://cfpub.epa.gov/compliance/cases/ 

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

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

Publication Number 310. 

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

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

28 
11. U.S. EPA, Office of Enforcement and Compliance Assurance. October 1999. 

Enforcement Alert: Proper Monitoring Essential to Reducing 'Fugitive Emissions' Under 

Leak Detection and Repair Programs. 

12. 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. 

13. Dee, N. March 16, 2006. NSPS VV GGG industry cost-effectiveness data. Email to 

Karen Rackley, USEPA. Docket ID EPA-HQ-OAR-2006-0699-0002. 

 

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. A92-45, 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. Stell, J., Ed. “Statistics.” February 6, 2006. Oil and Gas Journal, Vol. 104, Issue 5. 

“OGJ Gasoline Prices” and “World Crude Prices,” p. 65. 

21. 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. 

22. 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 

29 
PET Facilities Subject to the Group IV Polymers and Resins NESHAP. Docket Item No. 

VIc-B-1. 

 

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

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

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

Enforcement Investigations Center. Transmitted via email to Karen Rackley. 

25. Chittim, R.A. August 8, 2007. Public Comment submitted by American Petroleum 

Institute, National Petrochemical and Refiners Association, and Western States 

Petroleum Association. Docket ID EPA-HQ-OAR-2006-0699-0077. 

26. Greene, A. August 7, 2007. Public Comment submitted by Citgo Petroleum 

Corporation. Docket ID EPA-HQ-OAR-2006-0699-0078. 

27. Hamilton, K. August 8, 2007. Public Comment submitted by Marathon Petroleum 

Company LLC. Docket ID EPA-HQ-OAR-2006-0699-0079. 

28. U.S. EPA, Office of Air Quality Planning and Standards. November 1982. VOC 

Fugitive Emissions in Petroleum Refining Industry: Background Information for 

Proposed Standards. EPA-450/3-81-015a. 

30 
Attachment A 

Projection of Affected Sources 
Estimation of number of new refinery process units and total components nationwide over the next 5 years. Used in all four models to estimate nationwide impa

Assumptions: new processes reflect overall refinery processes

3 new refineries' worth of processes per year / 150 refineries2 % new/modified processes per year

15 new refineries' worth of processes over 5 years

Assume: 10 large refineries

5 small refineries

Each refinery consists of: VOC 

non-HAP 

VOC VOC 

non-HAP 

VOC

1 Crude Distillation 0.8 0.3 0.8 0.3

0.3 Alkylation (sulfuric acid) 1 0.7 0.3 0.210.3 Alkylation (HF) 1 0.7 0.3 0.21

1 Catalytic Reforming 1 0.1 1 0.1

0.3 Hydrocracking 0.8 0.1 0.24 0.03

2 Hydrotreating/Hydrorefining 1 0.3 2 0.6

0.8 Catalytic Cracking 1 0.3 0.8 0.24

0 Thermal Cracking (visbreaking) 0.8 0.1 0 0

0.4 Thermal Cracking (coking) 0.8 0.1 0.32 0.040.6 Hydrogen Plant 0.1 0.1 0.06 0.060.4 Asphalt Plant 0.1 0 0.04 0

1 Product Blending 1 0.3 1 0.3

1.3 Sulfur Plant 00000.9 Vacuum Distillation 0.6 0.3 0.54 0.27

3 Full-Range Distillation 1 0.4 3 1.2

0.5 Isomerization 1 0.8 0.5 0.40.2 Polymerization 1 0.5 0.2 0.1

0.05 MEK Dewaxing 0000

0.1 Other Lube Oil Processes 00000.3 Aromatics 1 0 0.3 0

Total No. Processes over 5 years

216.75

Total No. Processes over 5 years with at least one component in VOC service 195Total No. Processes over 5 years with components in non-HAP VOC service 70

Fraction Unit by Type 

of Srvc

Fraction Comp by 

Type of Srvc

NewProcessEst 
Total components across all new process units

Gas 

Light 

Liquid

Heavy 

Liquid

Light 

Liquid

Heavy 

Liquid

Compressors Gas Light Liquid Heavy Liquid Gas Light Liquid 

Crude Distillation 2415 5655 6060 190 180 30 100 80 145 6310 12595 Alkylation (sulfuric acid) 993 2664 51 90 15 7.5 57 34.5 6 2530.5 5928 Alkylation (HF) 465 2475 477 58.5 28.5 6 45 52.5 3 1440 5700 Catalytic Reforming 3790 5000 2305 160 45 45 105 125 15 8255 11250 Hydrocracking 1320 2515.5 1383 84 49.5 9 43.5 42 6 2811 5421 Hydrotreating/Hydrorefining 5480 7140 6180 190 170 60 230 110 210 11680 16180 Catalytic Cracking 2960 3756 5360 148 152 24 120 104 132 6704 9748 Thermal Cracking (visbreaking) 00000 000000Thermal Cracking (coking) 1056 1584 1554 66 60 8 46 52 66 3028 3636 Hydrogen Plant 2310 471 0 51 2160 24 36 840 0 1884 1122 Asphalt Plant 544 840 500 26 16 4 22 48 18 734 1312 Product Blending 1085 5215 2870 130 155 25 140 190 170 3420 8630 Sulfur Plant 1677 2249 2255.5 143 78 32.5 71.5 624 149.5 4712.5 7540 Vacuum Distillation 2304 1089 4401 45 135 18 54 31.5 45 4729.5 1768.5 Full-Range Distillation 7155 21525 3960 525 120 90 285 300 150 19425 48795 Isomerization 1495 2380 550 67.5 30 15 92.5 50 12.5 2580 5127.5 Polymerization 482 1265 179 24 4 1 24 29 59 958 1600 MEK Dewaxing 245.75 839.5 115 23.25 14.75 2.75 19 6.5 10 951 2306.5 Other Lube Oil Processes 185.5 309 475.5 8.5 18.5 4 10.5 8.5 22.5 263.5 340.5 Aromatics 1137 1500 691.5 48 13.5 13.5 31.5 37.5 4.5 2476.5 3375 Sum components 37,099.3 68,472.0 39,367.5 2,077.8 3,444.8 419.3 1,532.5 2,765.0 1,224.0 84,892.5 152,375.0 Sum VOC Srvc 30,542.6 61,508.1 32,511.7 1,747.7 1,263.2 338.2 1,319.8 1,279.4 964.4 72,287.7 134,959.6 Non-HAP VOC Svc 10,440.4 22,557.4 10,468.6 627.0 573.5 113.7 487.7 496.0 325.1 24,543.2 49,379.0 

Pressure Relief Valves Flanges 

Process Unit 

Valves Pumps

NewProcessEst 
Source: Locating and Estimating Air Emissions from Sources of Benzene, US EPA OAQPS, RTP, NC EPA-454/R-98-011, June 1998.Reference 142

Small Model Refinerya

Process Unit Gas 

Light 

Liquid

Heavy 

Liquid

Light 

Liquid

Heavy 

Liquid

Compressors Gas Light Liquid Heavy Liquid Gas Light Liquid 

Crude Distillation 75 251 216 8 8 2 6 6 5 164 555 Alkylation (sulfuric acid) 278 582 34 18 10 1 12 15 4 705 1296 Alkylation (HF) 102 402 62 13 3 2 12 13 0 300 1200 Catalytic Reforming 138 234 293 8 5 3 5 3 3 345 566 Hydrocracking 300 375 306 12 9 2944 1038 892 

Hydrotreating/Hydrorefining 100 208 218 5 5 2 5 3 5 290 456 Catalytic Cracking 186 375 450 13 14 2 8 8 7 490 943 Thermal Cracking (visbreaking) 206 197 0 7 0 0 4 0 0 515 405 Thermal Cracking (coking) 148 174 277 9 8 2 7 16 13 260 322 Hydrogen Plant 168 41 0 3 0 2 4 2 0 304 78 Asphalt Plant 120 334 250 5 8 2 5 10 9 187 476 Product Blending 67 205 202 6 11 1 10 6 22 230 398 Sulfur Plant 58 96 127 6 6 3 3 88 15 165 240 Vacuum Distillation 54 26 84 6 6 2 2 5 2 105 121 Full-Range Distillation 157 313 118 7 4 2 5 4 6 171 481 Isomerization 270 352 64 9 2 2 7 10 1 432 971 Polymerization 224 563 15 12 0 1 10 5 3 150 450 MEK Dewaxing 145 1208 200 35 39 3 10 14 4 452 1486 Other Lube Oil Processes 153 242 201 7 5 2 5 5 5 167 307 Aromatics 138 234 293 8 5 3 5 3 3 345 566 

a Refineries with crude charge capacities less than 50,000 bbl/sd.

Large Model Refinerya

Process Unit Gas 

Light 

Liquid

Heavy 

Liquid

Light 

Liquid

Heavy 

Liquid

Compressors Gas Light Liquid Heavy Liquid Gas Light Liquid 

Crude Distillation 204 440 498 15 14 2 7 5 12 549 982 Alkylation (sulfuric acid) 192 597 0 21 0 2 13 4 0 491 1328 Alkylation (HF) 104 624 128 13 8 1 9 11 1 330 1300 Catalytic Reforming 310 383 84 12 2 3 8 11 0 653 842 Hydrocracking 290 651 308 22 12 2 10 12 0 418 1361 Hydrotreating/Hydrorefining 224 253 200 7 6 2 9 4 8 439 581 Catalytic Cracking 277 282 445 12 12 2 11 9 13 593 747 Thermal Cracking (visbreaking) 110 246 130 7 6 1 6 3 15 277 563 Thermal Cracking (coking) 190 309 250 12 11 1 8 5 10 627 748 Hydrogen Plant 301 58 0 7 360 3 4 139 0 162 148 Asphalt Plant 76 43 0 4 0 0 3 7 0 90 90 Product Blending 75 419 186 10 10 2 9 16 6 227 664 Sulfur Plant 100 125 110 8 3 1 4 4 4 280 460 Vacuum Distillation 229 108 447 2 12 1 5 1 4 473 136 

Full-Range Distillation 160 561 73 14 2 2 7 8 2 562 1386 

Isomerization 164 300 78 9 5 2 15 5 2 300 540 Polymerization 129 351 82 6 2 0 7 12 28 404 575 MEK Dewaxing 419 1075 130 29 10 4 33 6 18 1676 3870 Other Lube Oil Processes 109 188 375 5 16 3 8 6 20 180 187 Aromatics 310 383 84 12 2 3 8 11 0 653 842 

a Refineries with crude charge capacities greater than 50,000 bbl/sd.

Flanges

Flanges

Pressure Relief Valves

Valves Pumps Pressure Relief ValvesValves Pumps

NewProcessEst 
Attachment B 

Model Determination
B-1 

Process units in 

VOC service 

195 

Subject to 

consent decree 

149 

Not subject to 

consent decree 

46 

(1) New 

89 

(4)

Reconstructed 

60 

Units in 

HAP service

29 

Units in 

non-HAP 

service 

16 

(2) New 

18 

(3) New

10

(5)

Reconstructed 

12 

(6)

Reconstructed

7 

Determination of six petroleum refinery models – Process unit example. 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 six boxes indicate the model that represents those process units. The same 

methodology was used to determine the number of each type of component (gas 

valves, light liquid valves, light liquid pumps, gas connectors, and light liquid 

connectors) in each of the six models.
Model Details

Type of Component

New CD New MACT

New 

NSPS

Reconstructed 

CD

Reconstructed 

MACT

Reconstructed 

NSPS

All Subject VOC 

units

Number of Processes

 * Total Processes 195 195 195 195 195 195 195

 * Affected Processes 89 18 10 60 12 6.6 195

Pump Seals

 * Light-liquid service 802 158 88 535 105 59 1748

 * Heavy-liquid service 580 97 81 386 65 54 1263

Valves

 * Gas/vapor service 14014 2837 1474 9343 1892 982 30543

 * Light-liquid service 28223 5498 3184 18815 3665 2123 61508

 * Heavy-liquid service 14918 3111 1478 9945 2074 985 32512

Connectors

 * Flanges - gas/vapor 33169 6739 3464 22113 4493 2310 72288

 * Flanges - light liquid 61926 12080 6970 41284 8053 4647 134960

 * Flanges - heavy liquid 36292 7315 3849 24195 4877 2566 79094

Pressure Relief Devices

 * Disks 1635 318 185 1090 212 123 3564

 * Disk holders, valves,etc. 1635 318 185 1090 212 123 3564

Open-ended Valves 3372 709 329 2248 473 219 7349

Sampling Connections 658 132 70 438 88 47 1433

Compressor Vent 155 32 16 103 21 11 338

Replacement Pump Seals 802 158 88 535 105 59 1748

Number of Components

Models B-2
Attachment C 

Emission Estimate Inputs 
Protocol for Equipment Leak Emission Estimates, USEPA, November 1995 (EPA-453/R-95-017)

Data from:

 Table 2-10. Petroleum Industry Leak Rate/Screening Value Correlations

 Table 2-12. Default-Zero Values: Petroleum Industry

Equipment

Default-zero 

emission rate 

(kg/hr/ 

component) X Y

Valves 7.8E-06 2.29E-06 0.746

LL Pumps 2.4E-05 5.03E-05 0.610

Connectors 7.5E-06 1.53E-06 0.735

Flanges 3.1E-07 4.61E-06 0.703

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

TABLE G-2. DETERMINATION OF LDAR CONTROL EFFECTIVENESS AT REFINERY 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 11.0 0.0109 0.39 1.72 1.06 0.00258 76

Quarterly 10000 11.0 0.0109 1.15 5.07 3.11 0.00430 61

HON reg neg 500 28.5 0.0109 0.00 2.00 1.00 0.00057 95

Gas Valves Monthly 10000 10.0 0.0268 0.36 1.60 0.98 0.00317 88

Quarterly 10000 10.0 0.0268 1.06 4.69 2.88 0.00813 70

HON reg neg 500 24.0 0.0268 0.00 2.00 1.00 0.00120 96

LL Pumps Monthly 10000 24.0 0.1140 0.00 11.28 5.64 0.03597 68

Quarterly 10000 24.0 0.1140 0.00 24.00 12.00 0.06300 45

HON reg neg 1000 48.0 0.1140 0.00 10.00 5.00 0.01137 88

Connectors HON reg neg 500 1.7 0.00025 0.00 0.50 0.25 0.00005 81

Inputs C-1
Leak frequencies from the 1997 API report: Analysis of Refinery Screening Data

(Leak frequencies used to estimate monitoring frequency and repair costs)

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

Connectors - Gas 0.036 0.143 0.047 0.014 0.032

Connectors - Light Liquid 0.033 0.093 0.034 0.005 0.015

Leak frequencies from the 1997 API report: Analysis of Refinery Screening Data with NEIC factor applied

(Leak frequencies used to estimate emissions)

Percent Leaking at Leak Definition used in emission estimates

500 1000 10000 50000 100000

Valves - Gas 1.709 1.505 0.425 0.185 0.139

Valves - Light Liquid 1.767 1.467 0.495 0.177 0.135

Pumps - Light Liquid 6.072 4.744 1.709 0.490 0.319

Connectors - Gas 0.466 0.404 0.159 0.079 0.055

Connectors - Light Liquid 0.309 0.252 0.093 0.034 0.026

Average Valves 1.738 1.486 0.460

Differences (% within the given range)

Differences (%) 500 1000 10000 50000 100000

Valves - Gas 0.204 1.080 0.240 0.046 0.139

Valves - Light Liquid 0.300 0.972 0.319 0.041 0.135

Pumps - Light Liquid 1.328 3.035 1.219 0.171 0.319

Connectors - Gas 0.062 0.245 0.081 0.024 0.055

Connectors - Light Liquid 0.057 0.159 0.058 0.009 0.026

Inputs C-2
Attachment D 

Leak Frequencies and Emission Estimates 
Leak Def leaks/quarter 2 times/yr 3 times/yr 4 times/yr

VLQ VR2 VR3 VR4

1000 Pumps 861 207 45 12

1000 G Valves 12731 1962 392 48

1000 LL Valves 11472 1777 349 45

500 G Valves 14453 2503 511 81

500 LL Valves 13817 2567 569 94

Subsequent monthly quarterly semiannual annual

Pumps, 10,000 0.88 2.47

Pumps, 1,000 0.98 2.77 5.20 10.00

Gas Valves, 10,000 0.61 1.18 2.32

Gas Valves, 1,000 0.88 1.69 3.31

Gas Valves, 500 1.00 1.91 3.73

LL Valves, 10,000 0.72 1.38 2.70

LL Valves, 1,000 0.86 1.65 3.23

LL Valves, 500 1.03 1.97 3.83

Black = given by API

Red = calc using NEIC average (1.28)

Blue = converted from different leak frequency using API repeat leakers

Purple = calculated using NEIC average and API repeat leakers

Analysis uses shaded values

SubLeakFreq D-1
Emissions estimation calculations for both controlled and baseline scenarios. Distributions for all scenarios based on distribution of leakers reported by API.

Results summarized in "Final Estimates" and used to calculate incremental emissions reductions for the amendments.Assumes 90% of values below 500 are zero and 10% are between 0 and 500 ppmAssumed average point in range 0.33

84.535 9.393 1.33 3.04 1.22 0.17 0.32

PUMPS

New = Monthly 1000, baseline = Monthly 10,000 (VV to VVa)

1 Controlled, with leak frequency as summarized in API report equal to leak fraction (i.e., estimate emission rate when monitored, not average over monitoring period) converted to monthly monitoring

leak range 0 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (1,000 ppm), % 1.69 <-- (this value for monthly monitoring)percent in range 88.057 9.784 0.472 1.079 0.433 0.061 0.113 100.000representative value default 165 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/pump) 0.000024 0.00113301 0.00265149 0.00788552 0.023148116 0.0440037 0.13086701 0.00050503 This is very close to the average o

 of the API report. Therefore, a of leakers is reasonable.

2 Controlled estimate using average leak rate as one-half of reported leak frequency, converted to monthly monitoring

leak range 0 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (1,000 ppm), % 1.69 <-- (this value for monthly monitoring)percent in range 88.816 9.868 0.472 0.540 0.217 0.030 0.057 100.000representative value default 165 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/pump) 0.000024 0.00113301 0.00265149 0.00788552 0.023148116 0.0440037 0.13086701 0.00032591

3 Baseline estimate - Apply the industry-based baseline-to-controlled percent leakers ratio for valves to the controlled leak frequency reported by industry for pumps above 10,000 ppm (adjusted to monthly monitoring

Then determine the percent leaking at other leak definitions by assuming the same distribution of leaking pumps as reported by API.leak range 0 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (10,000 ppm), % 1.50 4.18 (at 1,000 ppm)percent in range 85.190 9.466 1.169 2.671 1.072 0.151 0.281 100.000representative value default 165 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/pump) 0.000024 0.00113301 0.00265149 0.00788552 0.023148116 0.0440037 0.13086701 0.00105114

4 Baseline estimate - Apply the industry-based baseline-to-controlled percent leakers ratio for valves to the controlled leak frequency reported by industry for pumps above 10,000 ppm (adjusted to monthly monitoring

Then determine the percent leaking at other leak definitions by assuming the same distribution of leaking pumps as reported by API.leak range 0 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (10,000 ppm), % 1.50percent in range 85.867 9.541 1.169 2.671 0.536 0.075 0.140 100.000representative value default 165 665 3,970 23,200 66,500 397,000average for values above 10,000 zeroemissions (kg/hr/pump) 0.000024 0.00113301 0.00265149 0.00788552 0.023148116 0.0440037 0.13086701 0.00071126

5 Baseline and Initial Leak Freq. Calc.

leak range 0 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (10,000 ppm), % 0.88 2.44 (at 1,000 ppm)percent in range 87.194 9.688 0.682 1.559 0.626 0.088 0.164

Emissions Estimates Calcs 
New = Monthly 1,000, baseline = Quarterly 1,000 (MACT to VVa)

Quarterly monitoring

3 Baseline estimate - Apply the industry-based baseline-to-controlled percent leakers ratio for valves to the controlled leak frequency reported by industry for pumps above 10,000 ppm.

Then determine the percent leaking at other leak definitions by assuming the same distribution of leaking pumps as reported by API.leak range 0 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (1,000 ppm), % 4.74 4.74 (at 1,000 ppm)percent in range 84.535 9.393 1.328 3.035 1.219 0.171 0.319 100.000representative value default 165 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/pump) 0.000024 0.00113301 0.00265149 0.00788552 0.023148116 0.044003699 0.13086701 0.00117595

4 Baseline estimate - Apply the industry-based baseline-to-controlled percent leakers ratio for valves to the controlled leak frequency reported by industry for pumps above 10,000 ppm.

Then determine the percent leaking at other leak definitions by assuming the same distribution of leaking pumps as reported by API.leak range 0 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (1,000 ppm), % 4.74percent in range 86.670 9.630 1.328 1.518 0.609 0.086 0.159 100.000representative value default 165 665 3,970 23,200 66,500 397,000average for values above 10,000 zeroemissions (kg/hr/pump) 0.000024 0.00113301 0.00265149 0.00788552 0.023148116 0.044003699 0.13086701 0.00067214

5 Baseline and Initial Leak Freq. Calc.

leak range 0 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (1,000 ppm), % 2.77 2.77 (at 1,000 ppm)percent in range 86.811 9.646 0.775 1.771 0.711 0.100 0.186

Emissions Estimates Calcs 
GAS VALVES 88.462 9.829 0.20395278 1.07975 0.239944444 0.046275 0.138825

New = Semiannual, 500, Baseline = Annual, 10,000 (VV to VVa)

1 Controlled, with leak frequency as summarized in API report equal to leak fraction (i.e., estimate emission rate when monitored, not average over monitoring period)

leak range 0 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (500 ppm), % 3.28percent in range 87.049 9.672 0.391 2.072 0.460 0.089 0.266 0.816representative value default 165 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/valve) 0.0000078 0.00010329 0.00029219 0.00110798 0.004135133 0.00907111 0.034398 0.00015962 Only 44% of average for GV and L

 Possibly LLV average is a little  because of outliers.

2 Controlled estimate using average leak rate as one-half of reported leak frequency

leak range 0 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (500 ppm), % 3.28 This level would require quarterly 

percent in range 88.524 9.836 0.196 1.036 0.230 0.044 0.133 100.000 case for the data summarized representative value default 165 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/valve) 0.0000078 0.00010329 0.00029219 0.00110798 0.004135133 0.00907111 0.034398 0.00008848

3 Baseline estimate

leak range 0 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (10,000 ppm), % 2.03 8.161 (at 500 ppm)percent in range 82.655 9.184 0.974 5.157 1.146 0.221 0.663 100.000representative value default 165 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/valve) 0.0000078 0.00010329 0.00029219 0.00110798 0.004135133 0.00907111 0.034398 0.00037142

4 Baseline estimate - average above 10,000 ppm

leak range 0 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (10,000 ppm), % 2.03 8.161 (at 500 ppm)percent in range 83.569 9.285 0.974 5.157 0.573 0.111 0.332 100.000representative value default 165 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/valve) 0.0000078 0.00010329 0.00029219 0.00110798 0.004135133 0.00907111 0.034398 0.00022384

5 Baseline and Initial Leak Freq. Calc.

leak range 0 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (10,000 ppm), % 1.18 4.762 (at 500 ppm)percent in range 85.715 9.524 0.568 3.009 0.669 0.129 0.387

Emissions Estimates Calcs 
New = Semiannual, 500, Baseline = Semiannual, 1,000 (mod HON to VVa)

1b Controlled, with leak frequency as summarized in API report equal to leak fraction (i.e., estimate emission rate when monitored, not average over monitoring period)

leak range 0 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (500 ppm), % 3.28percent in range 87.049 9.672 0.391 2.072 0.460 0.089 0.266 0.816representative value default 165 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/valve) 0.0000078 0.00010329 0.00029219 0.00110798 0.004135133 0.00907111 0.034398 0.00015962

2b Controlled estimate using average leak rate as one-half of reported leak frequency

leak range 0 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (500 ppm), % 3.28percent in range 88.524 9.836 0.196 1.036 0.230 0.044 0.133 100.000representative value default 165 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/valve) 0.0000078 0.00010329 0.00029219 0.00110798 0.004135133 0.00907111 0.034398 0.00008848

3b Baseline estimate

leak range 0 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (1,000 ppm), % 2.90 3.297 (at 500 ppm)percent in range 87.033 9.670 0.394 2.083 0.463 0.089 0.268 100.000representative value default 165 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/valve) 0.0000078 0.00010329 0.00029219 0.00110798 0.004135133 0.00907111 0.034398 0.00016039

4b Baseline estimate - average above 1,000 ppm

leak range 0 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (1,000 ppm), % 2.90percent in range 88.339 9.815 0.394 1.042 0.231 0.045 0.134 100.000representative value default 165 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/valve) 0.0000078 0.00010329 0.00029219 0.00110798 0.004135133 0.00907111 0.034398 0.00008941

5b Baseline and Initial Leak Freq. Calc.

leak range 0 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (1,000 ppm), % 1.69 1.924 (at 500 ppm)percent in range 88.269 9.808 0.230 1.216 0.270 0.052 0.156

Emissions Estimates Calcs 
LIGHT LIQUID VALVES 88.410 9.823 0.29993056 0.971775 0.318783333 0.04113333 0.13539722

1 Controlled, with leak frequency as summarized in API report equal to leak fraction (i.e., estimate emission rate when monitored, not average over monitoring period)

leak range 0 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (500 ppm), % 3.38percent in range 86.961 9.662 0.573 1.857 0.609 0.079 0.259 100.000representative value default 165 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/valve) 0.0000078 0.00010329 0.00029219 0.00110798 0.004135133 0.00907111 0.034398 0.00016031 Only 44% of average for GV and L

 Possibly LLV average is a little  because of outliers.

2 Controlled estimate using average leak rate as one-half of reported leak frequency

leak range 0 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (500 ppm), % 3.38 This level would require quarterly 

percent in range 88.481 9.831 0.287 0.928 0.305 0.039 0.129 100.000 case for the data summarized representative value default 165 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/valve) 0.0000078 0.00010329 0.00029219 0.00110798 0.004135133 0.00907111 0.034398 0.00008883

3 Baseline estimate

leak range 0 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (10,000 ppm), % 2.37 8.439 (at 500 ppm)percent in range 82.405 9.156 1.432 4.641 1.523 0.196 0.647 100.000representative value default 165 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/valve) 0.0000078 0.00010329 0.00029219 0.00110798 0.004135133 0.00907111 0.034398 0.00037471

4 Baseline estimate - average above 10,000 ppm

leak range 0 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (10,000 ppm), % 2.37 8.439 (at 500 ppm)percent in range 83.469 9.274 1.432 4.641 0.761 0.098 0.323 100.000representative value default 165 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/valve) 0.0000078 0.00010329 0.00029219 0.00110798 0.004135133 0.00907111 0.034398 0.00022331

5 Baseline and Initial Leak Freq. Calc.

leak range 0 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (10,000 ppm), % 1.38 4.924 (at 500 ppm)percent in range 85.568 9.508 0.836 2.708 0.888 0.115 0.377

Emissions Estimates Calcs 
New = Semiannual, 500, Baseline = Semiannual, 1,000 (mod HON to VVa)

1b Controlled, with leak frequency as summarized in API report equal to leak fraction (i.e., estimate emission rate when monitored, not average over monitoring period)

leak range 0 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (500 ppm), % 3.38percent in range 86.961 9.662 0.573 1.857 0.609 0.079 0.259 0.946representative value default 165 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/valve) 0.0000078 0.00010329 0.00029219 0.00110798 0.004135133 0.00907111 0.034398 0.00016031

2b Controlled estimate using average leak rate as one-half of reported leak frequency

leak range 0 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (500 ppm), % 3.38percent in range 88.481 9.831 0.287 0.928 0.305 0.039 0.129 100.000representative value default 165 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/valve) 0.0000078 0.00010329 0.00029219 0.00110798 0.004135133 0.00907111 0.034398 0.00008883

3b Baseline estimate

leak range 0 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (1,000 ppm), % 2.83 3.409 (at 500 ppm)percent in range 86.932 9.659 0.579 1.875 0.615 0.079 0.261 100.000representative value default 165 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/valve) 0.0000078 0.00010329 0.00029219 0.00110798 0.004135133 0.00907111 0.034398 0.00016170

4b Baseline estimate - average above 10,000 ppm

leak range 0 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (1,000 ppm), % 2.83 3.409 (at 500 ppm)percent in range 87.362 9.707 0.579 1.875 0.308 0.040 0.131 100.000representative value default 165 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/valve) 0.0000078 0.00010329 0.00029219 0.00110798 0.004135133 0.00907111 0.034398 0.00010054

5b Baseline and Initial Leak Freq. Calc.

leak range 0 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (1,000 ppm), % 1.65 1.989 (at 500 ppm)percent in range 88.210 9.801 0.338 1.094 0.359 0.046 0.152

Emissions Estimates Calcs 
GAS CONNECTORS

1 Controlled, with leak frequency as summarized in API report equal to leak fraction (i.e., estimate emission rate when monitored, not average over monitoring period) - 50/50 split of gas flanges and connectors

leak range 0 500 1,000 10,000 50,000 100,000 1,000,000leak frequency, percent 0.47percent in range 89.580 9.953 0.062 0.245 0.081 0.024 0.055 100.000 This is close to values of 0.000015representative value default 165 665 3,970 23,200 66,500 397,000 GC and LLC in figures 3-5 and 3

zero SCAQMD screening data, so ass

emissions (kg/hr/flange) 0.00000031 0.00016695 0.00044478 0.00156189 0.00540305 0.01132777 0.03977871 0.00004988 0.00003954 screening values in the correlatio

emissions (kg/hr/connector) 0.0000075 0.00006524 0.00018175 0.00067578 0.00247358 0.00536371 0.01994355 0.00002920 use to estimate average emissio

 monitoring) over the monitoring p

2 Controlled estimate using average leak rate as one-half of reported leak frequency - 50/50 split of gas flanges and connectors, converted to annual monitoring assuming 10% repeat leakers

leak range 0 500 1,000 10,000 50,000 100,000 1,000,000 Since revised NSPS would not reqleak frequency, percent 1.68 frequently than once per year, th

percent in range 89.245 9.916 0.111 0.441 0.145 0.043 0.099 100.000 likely be higher than 0.272 percerepresentative value default 165 665 3,970 23,200 66,500 397,000 if all leaks are new). Assumed 3

zero because API report indicated abo

emissions (kg/hr/flange) 0.00000031 0.00016695 0.00044478 0.00156189 0.00540305 0.01132777 0.03977871 0.00007621 0.00005907 over 4 quarters.

emissions (kg/hr/connector) 0.0000075 0.00006524 0.00018175 0.00067578 0.00247358 0.00536371 0.01994355 0.00004194

3 Baseline estimate - no monitoring, 50/50 split of gas flanges and connectors

leak range 0 500 1,000 10,000 50,000 100,000 1,000,000leak frequency, percent 1.7 Same distribution as in API summ

percent in range 88.47 9.83 0.225 0.894 0.294 0.088 0.200 100 1.7 percent leakers >500 ppm (frrepresentative value default 165 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/flange) 0.00000031 0.00016695 0.00044478 0.00156189 0.00540305 0.01132777 0.03977871 0.00013699 0.00010417emissions (kg/hr/connector) 0.0000075 0.00006524 0.00018175 0.00067578 0.00247358 0.00536371 0.01994355 0.00007134

Emissions Estimates Calcs 
LIGHT LIQUID CONNECTORS

1 Controlled, with leak frequency as summarized in API report equal to leak fraction (i.e., estimate emission rate when monitored, not average over monitoring period) - 50/50 split of gas flanges and connectors

leak range 0 500 1,000 10,000 50,000 100,000 1,000,000leak frequency, percent 0.31percent in range 89.722 9.969 0.057 0.159 0.058 0.009 0.026 100.000 This is close to values of 0.000015representative value default 165 665 3,970 23,200 66,500 397,000 GC and LLC in figures 3-5 and 3

zero SCAQMD screening data, so ass

emissions (kg/hr/flange) 0.00000031 0.00016695 0.00044478 0.00156189 0.00540305 0.01132777 0.03977871 0.00003401 0.00002773 screening values in the correlatio

emissions (kg/hr/connector) 0.0000075 0.00006524 0.00018175 0.00067578 0.00247358 0.00536371 0.01994355 0.00002144 use to estimate average emissio

 monitoring) over the monitoring p

2 Controlled estimate using average leak rate as one-half of reported leak frequency - 50/50 split of gas flanges and connectors, converted to annual monitoring assuming 10% repeat leakers

leak range 0 500 1,000 10,000 50,000 100,000 1,000,000 Since revised NSPS would not reqleak frequency, percent 1.111 frequently than once per year, th

percent in range 89.500 9.944 0.102 0.287 0.105 0.015 0.046 100.000 likely be higher than 0.272 percerepresentative value default 165 665 3,970 23,200 66,500 397,000 if all leaks are new). Assumed 3

zero because API report indicated abo

emissions (kg/hr/flange) 0.00000031 0.00016695 0.00044478 0.00156189 0.00540305 0.01132777 0.03977871 0.00004764 0.00003781 over 4 quarters.

emissions (kg/hr/connector) 0.0000075 0.00006524 0.00018175 0.00067578 0.00247358 0.00536371 0.01994355 0.00002798

3 Baseline estimate - no monitoring, 50/50 split of gas flanges and connectors

leak range 0 500 1,000 10,000 50,000 100,000 1,000,000leak frequency, percent 1.7 Same distribution as in API summ

percent in range 88.470 9.830 0.312 0.878 0.321 0.047 0.142 100 1.7 percent leakers >500 ppm (frrepresentative value default 165 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/flange) 0.00000031 0.00016695 0.00044478 0.00156189 0.00540305 0.01132777 0.03977871 0.00011084 0.00008456emissions (kg/hr/connector) 0.0000075 0.00006524 0.00018175 0.00067578 0.00247358 0.00536371 0.01994355 0.00005828

Emissions Estimates Calcs 
Attachment E 

Emission Factors and Emissions Estimates 
Emission Factors (kg/hr/component) Pumps LL Valves Gas LL Average

NSPS Baseline, average above 10,000 ppm 0.0007113 0.0002238 0.0002233 0.0002236Estimated controlled over monitoring period assuming average leak fraction

2,000 ppm quarterly 0.0006721

1,000 ppm, semiannual 0.0000894 0.0001005 0.0000950

Estimated controlled over monitoring period assuming average leak fraction

2,000 ppm monthly 0.0003259

500 ppm, semiannual 0.0000885 0.0000888 0.0000887

Estimated controlled over monitoring period assuming average leak fraction

2,000 ppm monthly 0.0003259

500 ppm, quarterly 0.0000544 0.0000548 0.0000546

Emission Factors (kg/hr/component) Gas Flanges

Gas Connectors

Avg. G Connectors LL Flanges

LL Connectors

Avg. LL Connectors

Avg. Connectors

Baseline (10,000) 0.0001370 0.0000713 0.0001042 0.0001108 0.0000583 0.0000846 0.00009436Baseline, average above 10,000 ppm

Controlled, leak definition of 500 ppm 0.0000499 0.0000292 0.0000395 0.0000340 0.0000214 0.0000277 0.00003363Estimated controlled over monitoring period assuming average leak fraction 0.0000762 0.0000419 0.0000591 0.0000476 0.0000280 0.0000378 0.00004844

Uncontrolled CD MACT NSPS

Pumps 0.435596 0.1772139 0.1049032 6.287 0.5696 4.990 1.3Gas Valves 1.271050 0.4228288 0.5497852 19.654 1.9068 16.704 3.0LL Valves 2.575894 0.9213070 1.1850020 41.016 3.8613 33.825 7.2Connectors 19.5565 171.315 10.0391 87.943 83.4

238.273 143.461 94.8

Leak Frequencies (from VV to VVa)Leak Definition (ppm) 500 1000 10000Initial and Baseline, Gas Valves (%) 4.762 1.184Initial and Baseline, Light Liquid Valves (%) 4.924 1.380Initial and Baseline, Pumps (%) 2.436 0.877Leak Frequencies (from MACT to VVa)Leak Definition (ppm) 500 1000 2000 M 2000 QInitial and Baseline, Gas Valves (%) 1.924 1.694Initial and Baseline, Light Liquid Valves (%) 1.989 1.651Initial and Baseline, Pumps (%) 2.768 2.768

Difference 

(Mg/yr)

Total 

Emissions 

Baseline and Controlled Emissions (Mg/yr)

Emissions if 

all controlled 

(kg/hr)

Emissions if 

all 

controlled 

Baseline emissions from facilities complying with each 

rule (kg/hr)

Final Estimates 
Attachment F 

Cost Analysis Inputs 
This page provides inputs for the entire analysis. The cells in yellow highlight are single numbers from various sources that are used

 in cost calculations. The numbers in blue are calculated from various sources (e.g., "NEIC Factor," consent decrees) and are used

 to estimate baseline emissions.

180.00 Cost of replacement pump seals ($)

17.70 Initial cost of monitoring components in gas and light liquid service ($)

1.13 Initial cost of monitoring components in heavy liquid service ($)

1.50 Monitoring Fee ($/component) (excludes connectors)

2.50 Monitoring Fee ($/connector)

23.3 Wage (refinery maintenance) ($, May 2006)

3 Overhead factor, maintenance & and repair (assumes in-house)

1.6 Overhead factor, administration, planning, and training (assumes in-house)

68.78 Planning and training labor charge ($)

0.244 Capital recovery factor: rupture disks and pump seals (from HON analysis), 5 years @ 7%

0.142 Capital recovery factor: all other types of equipment and initial LDAR labor (from HON analysis), 10 years @ 7%

3 Number of refineries' worth of process units that become subject each year (Assumed)

2 Percentage of process units that become subject each year (Assumed)

60 Percentage of affected process units that are new (Assumed)

40 Percentage of affected process units that are reconstructed (Assumed)

320 Planning and training for LDAR program, current NSPS level, hours

320 Planning and training for LDAR program, current MACT 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 MACT level, hours

300 Administrative and reports for LDAR program including connectors, hours

600 VOC Recovery Credit, $/Mg (assumes $1.50/gallon VOC credit)

1.7 NEIC Factor for leak frequency

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)

0.765 Fraction of the industry subject to a consent decree that lowers the leak definitions to Option 1 levels

1.10 tons/Mg

Planning and training labor charge calculation (May 2006)

Category Mean Multiplier Result

Environmental engineering 38.29 1 38.29

General and operations managers 59.15 0.05 2.96

General office and admin support 17.46 0.1 1.746

42.99

Inputs F-1
Attachment G 

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 "Summary" (page 2) 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 Subse

Le

Frequ

(%

Pump Seals

Refinery model process * Light-liquid service 802 17.70 14,194.21 12 1.50 38725.32 17046.82 N/A 0.00 

New CD * Heavy-liquid service 580 1.13 654.97

baseline GGG program

Valves

 * Gas/vapor service 14,014 17.70 248,056.28 4 1.50 84086.88 N/A 0.00  * Light-liquid service 28,223 17.70 499,547.21 4 1.50 169338.04 N/A 0.00  * Heavy-liquid service 14,918 1.13 16,857.34Connectors * Flanges - gas/vapor 33,169 0.00 0.00 0 0.00 0.00 N/A 0.00  * Flanges - light liquid 61,926 0.00 0.00 0 0.00 0.00 N/A 0.00  * Flanges -heavy liquid 36,292 0.00 0.00Replacement Pump Seals 802 180.00 0.00

hr/activity $/hr

Administrative and Reports 89 250 68.78Planning and Training 89 320 68.78 1969326.48TOTALS 779,310.01 1,969,326.48 292,150.23 17,046.82

Initial Costs w/o OVA and Train 2,748,636

Annualized Initial Costs 390,306

Annual Expenses 2,105,523

Annual Fixed Costs ($/yr) 1,942,480

Annual Variable Costs ($/yr) 553,349

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 Subse

Le

Frequ

(%

Pump Seals

Refinery model process * Light-liquid service 158 17.70 2,800.03 4 1.50 5740.85 3152.74 N/A 0.00 

New MACT * Heavy-liquid service 97 1.13 110.01

baseline GGG program

Valves

 * Gas/vapor service 2,837 17.70 50,222.35 2 1.50 8512.26 N/A 0.00  * Light-liquid service 5,498 17.70 97,312.64 2 1.50 16493.67 N/A 0.00  * Heavy-liquid service 3,111 1.13 3,515.86Connectors * Flanges - gas/vapor 6,739 0.00 0.00 0 0.00 0.00 N/A 0.00  * Flanges - light liquid 12,080 0.00 0.00 0 0.00 0.00 N/A 0.00  * Flanges -heavy liquid 7,315 0.00 0.00Replacement Pump Seals 158 180.00 0.00

hr/activity $/hr

Administrative and Reports 18 250 68.78Planning and Training 18 320 68.78 388631.69TOTALS 1,036,791.23 388,631.69 31,224.19 47,294.25

Initial Costs w/o OVA and Train 1,425,423

Annualized Initial Costs 204,942

Annual Expenses 461,848

Annual Fixed Costs ($/yr) 546,396

Annual Variable Costs ($/yr) 120,395

GGG_baseline_APIdata 
Type of Component

Pump Seals

Refinery model process * Light-liquid service

New CD * Heavy-liquid service

baseline GGG program

Valves

 * Gas/vapor service * Light-liquid service * Heavy-liquid serviceConnectors * Flanges - gas/vapor * Flanges - light liquid * Flanges -heavy liquidReplacement Pump SealsAdministrative and ReportsPlanning and TrainingTOTALS

Type of Component

Pump Seals

Refinery model process * Light-liquid service

New MACT * Heavy-liquid service

baseline GGG program

Valves

 * Gas/vapor service * Light-liquid service * Heavy-liquid serviceConnectors * Flanges - gas/vapor * Flanges - light liquid * Flanges -heavy liquidReplacement Pump SealsAdministrative and ReportsPlanning 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)

69.90 105917.60 0 80.00 69.90 0.00 142.06 13637.4669.90 4893.13 25 4.00 69.90 39066.93 838.3569.90 10190.06 25 4.00 69.90 81357.78 1745.8869.90 0.00 25 2.00 69.90 0.00 0.0069.90 0.00 25 2.00 69.90 0.00 0.00

1538536.31

121,000.79 120,424.71 2,726.28 1,538,536.31 13,637.46

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)

69.90 19588.99 0 80.00 69.90 0.00 26.27 2522.1969.90 841.67 25 4.00 69.90 6719.89 144.2069.90 1589.79 25 4.00 69.90 12692.93 272.3869.90 0.00 25 2.00 69.90 0.00 0.0069.90 0.00 25 2.00 69.90 0.00 0.00

303618.51

22,020.45 19,412.81 442.86 303,618.51 37,835.40

GGG_baseline_APIdata 
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 Subse

Le

Frequ

(%

Pump Seals

Refinery model process * Light-liquid service 88 17.70 1,566.34 12 1.50 4273.37 1677.26 N/A 0.00 

New NSPS * Heavy-liquid service 81 1.13 91.47

baseline GGG program

Valves

 * Gas/vapor service 1,474 17.70 26,083.78 2 1.50 4420.98 N/A 0.00  * Light-liquid service 3,184 17.70 56,356.17 2 1.50 9551.89 N/A 0.00  * Heavy-liquid service 1,478 1.13 1,669.73Connectors * Flanges - gas/vapor 3,464 0.00 0.00 0 0.00 0.00 N/A 0.00  * Flanges - light liquid 6,970 0.00 0.00 0 0.00 0.00 N/A 0.00  * Flanges -heavy liquid 3,849 0.00 0.00Replacement Pump Seals 88 180.00 0.00

hr/activity $/hr

Administrative and Reports 10 250 68.78Planning and Training 10 320 68.78 217165.04TOTALS 85,767.50 217165.04 18246.24 1677.26

Initial Costs w/o OVA and Train 302,933

Annualized Initial Costs 43,016

Annual Expenses 211,204

Annual Fixed Costs ($/yr) 214,018

Annual Variable Costs ($/yr) 40,202

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 Subse

Le

Frequ

(%

Pump Seals

Refinery model process * Light-liquid service 535 0.00 0.00 12 1.50 25816.88 11364.55 N/A 0.00 

Reconstructed CD * Heavy-liquid service 386 0.00 0.00

baseline GGG program

Valves

 * Gas/vapor service 9,343 0.00 0.00 4 1.50 56057.92 N/A 0.00  * Light-liquid service 18,815 0.00 0.00 4 1.50 112892.02 N/A 0.00  * Heavy-liquid service 9,945 0.00 0.00Connectors * Flanges - gas/vapor 22,113 0.00 0.00 0 0.00 0.00 N/A 0.00  * Flanges - light liquid 41,284 0.00 0.00 0 0.00 0.00 N/A 0.00  * Flanges -heavy liquid 24,195Replacement Pump Seals 535 180.00 0.00

hr/activity $/hr

Administrative and Reports 60 250 68.78Planning and Training 60 0 68.78 0.00TOTALS 0.00 0.00 194766.82 11364.55

Initial Costs w/o OVA and Train 0

Annualized Initial Costs 0

Annual Expenses 1,403,682

Annual Fixed Costs ($/yr) 1,034,783

Annual Variable Costs ($/yr) 368,899

GGG_baseline_APIdata 
Type of Component

Pump Seals

Refinery model process * Light-liquid service

New NSPS * Heavy-liquid service

baseline GGG program

Valves

 * Gas/vapor service * Light-liquid service * Heavy-liquid serviceConnectors * Flanges - gas/vapor * Flanges - light liquid * Flanges -heavy liquidReplacement Pump SealsAdministrative and ReportsPlanning and TrainingTOTALS

Type of Component

Pump Seals

Refinery model process * Light-liquid service

Reconstructed CD * Heavy-liquid service

baseline GGG program

Valves

 * Gas/vapor service * Light-liquid service * Heavy-liquid serviceConnectors * Flanges - gas/vapor * Flanges - light liquid * Flanges -heavy liquidReplacement Pump SealsAdministrative and ReportsPlanning 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)

69.90 10421.38 0 80.00 69.90 0.00 13.98 1341.8169.90 305.63 25 4.00 69.90 2440.17 52.3669.90 769.51 25 4.00 69.90 6143.79 131.8469.90 0.00 25 2.00 69.90 0.00 0.0069.90 0.00 25 2.00 69.90 0.00 0.00

169660.19

11496.52 8583.96 198.18 169660.19 1341.81

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)

69.90 70611.73 0 80.00 69.90 0.00 94.70 9091.6469.90 3262.09 25 4.00 69.90 26044.62 558.9069.90 6793.37 25 4.00 69.90 54238.52 1163.9269.90 0.00 25 2.00 69.90 0.00 0.0069.90 0.00 25 2.00 69.90 0.00 0.00

1025690.87

80667.20 80283.14 1,817.52 1025690.87 9091.64

GGG_baseline_APIdata 
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 Subse

Le

Frequ

(%

Pump Seals

Refinery model process * Light-liquid service 105 0.00 0.00 4 1.50 3827.23 2101.82 N/A 0.00 

Reconstructed MACT * Heavy-liquid service 65 0.00 0.00

baseline GGG program

Valves

 * Gas/vapor service 1,892 0.00 0.00 2 1.50 5674.84 N/A 0.00  * Light-liquid service 3,665 0.00 0.00 2 1.50 10995.78 N/A 0.00  * Heavy-liquid service 2,074 0.00 0.00Connectors * Flanges - gas/vapor 4,493 0.00 0.00 0 0.00 0.00 N/A 0.00  * Flanges - light liquid 8,053 0.00 0.00 0 0.00 0.00 N/A 0.00  * Flanges -heavy liquid 4,877Replacement Pump Seals 105 180.00 0.00

hr/activity $/hr

Administrative and Reports 12 250 68.78Planning and Training 12 0 68.78 0.00TOTALS 0.00 0.00 20816.13 31529.50

Initial Costs w/o OVA and Train 0

Annualized Initial Costs 0

Annual Expenses 307,899

Annual Fixed Costs ($/yr) 227,636

Annual Variable Costs ($/yr) 80,263

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 Subse

Le

Frequ

(%

Pump Seals

Refinery model process * Light-liquid service 59 0.00 0.00 12 1.50 2848.91 1118.17 N/A 0.00 

Reconstructed NSPS * Heavy-liquid service 54 0.00 0.00

baseline GGG program

Valves

 * Gas/vapor service 982 0.00 0.00 2 1.50 2947.32 N/A 0.00  * Light-liquid service 2,123 0.00 0.00 2 1.50 6367.93 N/A 0.00  * Heavy-liquid service 985 0.00 0.00Connectors * Flanges - gas/vapor 2,310 0.00 0.00 0 0.00 0.00 N/A 0.00  * Flanges - light liquid 4,647 0.00 0.00 0 0.00 0.00 N/A 0.00  * Flanges -heavy liquid 2,566Replacement Pump Seals 59 180.00 0.00

hr/activity $/hr

Administrative and Reports 7 250 68.78Planning and Training 7 0 68.78 0.00TOTALS 0.00 0.00 12164.16 1118.17

Initial Costs w/o OVA and Train 0

Annualized Initial Costs 0

Annual Expenses 140,803

Annual Fixed Costs ($/yr) 114,001

Annual Variable Costs ($/yr) 26,801

GGG_baseline_APIdata 
Type of Component

Pump Seals

Refinery model process * Light-liquid service

Reconstructed MACT * Heavy-liquid service

baseline GGG program

Valves

 * Gas/vapor service * Light-liquid service * Heavy-liquid serviceConnectors * Flanges - gas/vapor * Flanges - light liquid * Flanges -heavy liquidReplacement Pump SealsAdministrative and ReportsPlanning and TrainingTOTALS

Type of Component

Pump Seals

Refinery model process * Light-liquid service

Reconstructed NSPS * Heavy-liquid service

baseline GGG program

Valves

 * Gas/vapor service * Light-liquid service * Heavy-liquid serviceConnectors * Flanges - gas/vapor * Flanges - light liquid * Flanges -heavy liquidReplacement Pump SealsAdministrative and ReportsPlanning 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)

69.90 13059.33 0 80.00 69.90 0.00 17.52 1681.4669.90 561.11 25 4.00 69.90 4479.93 96.1469.90 1059.86 25 4.00 69.90 8461.95 181.5969.90 0.00 25 2.00 69.90 0.00 0.0069.90 0.00 25 2.00 69.90 0.00 0.00

202412.34

14680.30 12941.88 295.24 202412.34 25223.60

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)

69.90 6947.58 0 80.00 69.90 0.00 9.32 894.5469.90 203.75 25 4.00 69.90 1626.78 34.9169.90 513.01 25 4.00 69.90 4095.86 87.8969.90 0.00 25 2.00 69.90 0.00 0.0069.90 0.00 25 2.00 69.90 0.00 0.00

113106.79

7664.34 5722.64 132.12 113106.79 894.54

GGG_baseline_APIdata 
Cost estimates for implementing Option 1. Costs include initial planning and training for process units not already subject to MACT, init

 repairs. Initial capital costs are annualized. Annual costs and expenses used in "Option 1 Emissions" to estimate incremental cost.NOTE: The estimate including connectors is meant to be a check for the impacts of Option 2. These values are not directly used in est

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 Maintenan

Costs ($/y

Pump Seals

Refinery Model process * Light-liquid service 802 17.70 14,194.21 12 1.50 38725.32 17046

New CD * Heavy-liquid service 580 1.13 654.97

Option 1

Valves * Gas/vapor service 14,014 17.70 248,056.28 4 1.50 84086.88  * Light-liquid service 28,223 17.70 499,547.21 4 1.50 169338.04  * Heavy-liquid service 14,918 1.13 16,857.34Connectors * Flanges - gas/vapor 33,169 17.70 613,149.25 1 2.50 82923.07  * Flanges - light liquid 61,926 17.70 1,144,736.63 1 2.50 154815.61  * Flanges -heavy liquid 36,292 1.13 41,010.20Connectors (baseline) * Flanges - gas/vapor 33,169 0.00 0.00 0 0.00 0.00  * Flanges - light liquid 61,926 0.00 0.00 0 0.00 0.00  * Flanges -heavy liquid 36,292 0.00 0.00Replacement Pump Seals 802 180.00 0.00Administrative and Reports hr/activity $/hr

 * No. Processes (valves and pumps) 89 250 68.78 * No. Processes (connectors) 89 50 68.78Planning and Training hr/activity $/hr * No. Processes (valves and pumps) 89 320 68.78 1,969,326.48 * No. Processes (connectors) 89 20 68.78 123,082.90TOTALS without connectors 779,310.01 1,969,326.48 292,150.23 17,046TOTALS with connectors 2,578,206.09 2,092,409.38 529,888.92 17,046

Without connectors

Initial Costs w/o OVA and Train 2,748,636

Annualized Initial Costs 390,306

Annual Expenses 2,105,523

Annual Fixed Costs ($/yr) 1,942,480

Annual Variable Costs ($/yr) 553,349

With connectors

Initial Costs w/o OVA and Train 4,670,615

Annualized Initial Costs 663,227

Annual Expenses 2,686,717

Annual Fixed Costs ($/yr) 2,523,108

Annual Variable Costs ($/yr) 826,836

Option1APIdata 
Type of Component

Pump Seals

Refinery Model process * Light-liquid service

New CD * 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 * No. Processes (valves and pumps) * No. Processes (connectors)Planning and Training * No. Processes (valves and pumps) * No. Processes (connectors)TOTALS 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)

MonitVerify 

(

94.70 100 16.00 69.90 105917.60 0 80.00 69.90 0.00 

558.90 75 0.17 69.90 4893.13 25 4.00 69.90 39066.93 

1163.92 75 0.17 69.90 10190.06 25 4.00 69.90 81357.78 1

269.86 75 0.17 69.90 2362.66 25 2.00 69.90 9431.78 503.83 75 0.17 69.90 4411.04 25 2.00 69.90 17608.93 1

0.00 75 0.17 69.90 0.00 25 2.00 69.90 0.00 0.00 75 0.17 69.90 0.00 25 2.00 69.90 0.00 

121,000.79 120,424.71 2127,774.49 147,465.41 4

Option1APIdata 
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 Maintenan

Costs ($/y

Pump Seals

Refinery Model process * Light-liquid service 158 17.70 2,800.03 12 1.50 7639.17 3362

New MACT * Heavy-liquid service 97 1.13 110.01

Option 1

Valves * Gas/vapor service 2,837 17.70 50,222.35 2 1.50 8512.26  * Light-liquid service 5,498 17.70 97,312.64 2 1.50 16493.67  * Heavy-liquid service 3,111 1.13 3,515.86Connectors * Flanges - gas/vapor 6,739 17.70 124,575.99 1 2.50 16847.81  * Flanges - light liquid 12,080 17.70 223,298.90 1 2.50 30199.22  * Flanges -heavy liquid 7,315 1.13 8,266.35Connectors (baseline) * Flanges - gas/vapor 6,739 0.00 0.00 0 0.00 0.00  * Flanges - light liquid 12,080 0.00 0.00 0 0.00 0.00  * Flanges -heavy liquid 7,315 0.00 0.00Replacement Pump Seals 158 180.00 0.00Administrative and Reports hr/activity $/hr

 * No. Processes (valves and pumps) 18 250 68.78 * No. Processes (connectors) 18 50 68.78Planning and Training hr/activity $/hr * No. Processes (valves and pumps) 18 320 68.78 388,631.69 * No. Processes (connectors) 18 20 68.78 24,289.48TOTALS without connectors 1,036,791.23 388,631.69 33,122.52 47,504TOTALS with connectors 1,392,932.47 412,921.17 80,169.55 47,504

Without connectors

Initial Costs w/o OVA and Train 1,425,423

Annualized Initial Costs 204,942

Annual Expenses 469,235

Annual Fixed Costs ($/yr) 546,564

Annual Variable Costs ($/yr) 127,613

With connectors

Initial Costs w/o OVA and Train 1,805,854

Annualized Initial Costs 258,963

Annual Expenses 584,081

Annual Fixed Costs ($/yr) 661,309

Annual Variable Costs ($/yr) 181,735

Option1APIdata 
Type of Component

Pump Seals

Refinery Model process * Light-liquid service

New MACT * 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 * No. Processes (valves and pumps) * No. Processes (connectors)Planning and Training * No. Processes (valves and pumps) * No. Processes (connectors)TOTALS 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)

MonitVerify 

(

18.68 100 16.00 69.90 20893.88 0 80.00 69.90 0.00 

108.57 75 0.17 69.90 950.55 25 4.00 69.90 7589.25 216.61 75 0.17 69.90 1896.39 25 4.00 69.90 15140.81 

54.83 75 0.17 69.90 480.03 25 2.00 69.90 1916.29 98.28 75 0.17 69.90 860.44 25 2.00 69.90 3434.90 

0.00 75 0.17 69.90 0.00 25 2.00 69.90 0.00 0.00 75 0.17 69.90 0.00 25 2.00 69.90 0.00 

23,740.83 22,730.06 25,081.30 28,081.25 

Option1APIdata 
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 Maintenan

Costs ($/y

Pump Seals

Refinery Model process * Light-liquid service 88 17.70 1,566.34 12 1.50 4273.37 1881

New NSPS * Heavy-liquid service 81 1.13 91.47

Option 1

Valves * Gas/vapor service 1,474 17.70 26,083.78 2 1.50 4420.98  * Light-liquid service 3,184 17.70 56,356.17 2 1.50 9551.89  * Heavy-liquid service 1,478 1.13 1,669.73Connectors * Flanges - gas/vapor 3,464 17.70 64,038.65 1 2.50 8660.67  * Flanges - light liquid 6,970 17.70 128,840.63 1 2.50 17424.57  * Flanges -heavy liquid 3,849 1.13 4,349.05Connectors (baseline) * Flanges - gas/vapor 3,464 0.00 0.00 0 0.00 0.00  * Flanges - light liquid 6,970 0.00 0.00 0 0.00 0.00  * Flanges -heavy liquid 3,849 0.00 0.00Replacement Pump Seals 88 180.00 0.00Administrative and Reports hr/activity $/hr

 * No. Processes (valves and pumps) 10 250 68.78 * No. Processes (connectors) 10 50 68.78Planning and Training hr/activity $/hr * No. Processes (valves and pumps) 10 320 68.78 217,165.04 * No. Processes (connectors) 10 20 68.78 13,572.81TOTALS without connectors 85,767.50 217,165.04 18246.24 1881TOTALS with connectors 282,995.84 230,737.85 44331.48 1881

Without connectors

Initial Costs w/o OVA and Train 302,933

Annualized Initial Costs 43,016

Annual Expenses 217,571

Annual Fixed Costs ($/yr) 214,182

Annual Variable Costs ($/yr) 46,406

With connectors

Initial Costs w/o OVA and Train 513,734

Annualized Initial Costs 72,950

Annual Expenses 281,511

Annual Fixed Costs ($/yr) 278,047

Annual Variable Costs ($/yr) 76,413

Option1APIdata 
Type of Component

Pump Seals

Refinery Model process * Light-liquid service

New NSPS * 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 * No. Processes (valves and pumps) * No. Processes (connectors)Planning and Training * No. Processes (valves and pumps) * No. Processes (connectors)TOTALS 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)

MonitVerify 

(

10.45 100 16.00 69.90 11688.08 0 80.00 69.90 0.00 56.39 75 0.17 69.90 493.69 25 4.00 69.90 3941.60 

125.44 75 0.17 69.90 1098.25 25 4.00 69.90 8768.42 

28.19 75 0.17 69.90 246.76 25 2.00 69.90 985.08 56.71 75 0.17 69.90 496.46 25 2.00 69.90 1981.89 

0.00 75 0.17 69.90 0.00 25 2.00 69.90 0.00 0.00 75 0.17 69.90 0.00 25 2.00 69.90 0.00 

13280.01 12710.02 14023.24 15676.99 

Option1APIdata 
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 Maintenan

Costs ($/y

Pump Seals

Refinery Model process * Light-liquid service 535 0.00 0.00 12 1.50 25816.88 11364

Reconstructed CD * Heavy-liquid service 386 0.00 0.00

Option 1

Valves * Gas/vapor service 9,343 0.00 0.00 4 1.50 56057.92  * Light-liquid service 18,815 0.00 0.00 4 1.50 112892.02  * Heavy-liquid service 9,945 0.00 0.00Connectors * Flanges - gas/vapor 22,113 17.70 408,766.17 1 2.50 55282.05  * Flanges - light liquid 41,284 17.70 763,157.75 1 2.50 103210.41  * Flanges -heavy liquid 24,195 1.13 27,340.13Connectors (baseline) * Flanges - gas/vapor 22,113 0.00 0.00 0 0.00 0.00  * Flanges - light liquid 41,284 0.00 0.00 0 0.00 0.00  * Flanges -heavy liquid 24,195 0.00 0.00Replacement Pump Seals 535 180.00 0.00Administrative and Reports hr/activity $/hr

 * No. Processes (valves and pumps) 60 250 68.78 * No. Processes (connectors) 60 50 68.78Planning and Training hr/activity $/hr * No. Processes (valves and pumps) 60 0 68.78 0.00 * No. Processes (connectors) 60 20 68.78 82,055.27TOTALS without connectors 0.00 0.00 194,766.82 11,364TOTALS with connectors 1,199,264.05 82,055.27 353,259.28 11,364

Without connectors

Initial Costs w/o OVA and Train 0

Annualized Initial Costs 0

Annual Expenses 1,403,682

Annual Fixed Costs ($/yr) 1,034,783

Annual Variable Costs ($/yr) 368,899

With connectors

Initial Costs w/o OVA and Train 1,281,319

Annualized Initial Costs 181,947

Annual Expenses 1,791,145

Annual Fixed Costs ($/yr) 1,421,868

Annual Variable Costs ($/yr) 551,224

Option1APIdata 
Type of Component

Pump Seals

Refinery Model process * Light-liquid service

Reconstructed CD * 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 * No. Processes (valves and pumps) * No. Processes (connectors)Planning and Training * No. Processes (valves and pumps) * No. Processes (connectors)TOTALS 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)

MonitVerify 

(

63.14 100 16.00 69.90 70611.73 0 80.00 69.90 0.00 

372.60 75 0.17 69.90 3262.09 25 4.00 69.90 26044.62 775.94 75 0.17 69.90 6793.37 25 4.00 69.90 54238.52 1179.91 75 0.17 69.90 1575.11 25 2.00 69.90 6287.85 335.89 75 0.17 69.90 2940.69 25 2.00 69.90 11739.28 

0.00 75 0.17 69.90 0.00 25 2.00 69.90 0.00 0.00 75 0.17 69.90 0.00 25 2.00 69.90 0.00 

80,667.20 80,283.14 185,182.99 98,310.28 3

4515.80 18027.13 1

Option1APIdata 
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 Maintenan

Costs ($/y

Pump Seals

Refinery Model process * Light-liquid service 105 0.00 1,162.33 12 1.50 5092.78 2241

Reconstructed MACT * Heavy-liquid service 65 0.00 0.00

Option 1

Valves * Gas/vapor service 1,892 0.00 2,916.72 2 1.50 5674.84  * Light-liquid service 3,665 0.00 5,843.58 2 1.50 10995.78  * Heavy-liquid service 2,074 0.00 0.00Connectors * Flanges - gas/vapor 4,493 17.70 83,050.66 1 2.50 11231.87  * Flanges - light liquid 8,053 17.70 148,865.93 1 2.50 20132.81  * Flanges -heavy liquid 4,877 1.13 5,510.90Connectors (baseline) * Flanges - gas/vapor 4,493 0.00 0.00 0 0.00 0.00  * Flanges - light liquid 8,053 0.00 0.00 0 0.00 0.00  * Flanges -heavy liquid 4,877 0.00 0.00Replacement Pump Seals 105 180.00 186.82Administrative and Reports hr/activity $/hr

 * No. Processes (valves and pumps) 12 250 68.78 * No. Processes (connectors) 12 50 68.78Planning and Training hr/activity $/hr * No. Processes (valves and pumps) 12 0 68.78 0.00 * No. Processes (connectors) 12 20 68.78 16,192.99TOTALS without connectors 10,109.44 0.00 22,081.68 31,669TOTALS with connectors 247,536.94 16,192.99 53,446.37 31,669

Without connectors

Initial Costs w/o OVA and Train 10,109

Annualized Initial Costs 1,455

Annual Expenses 312,824

Annual Fixed Costs ($/yr) 229,203

Annual Variable Costs ($/yr) 85,076

With connectors

Initial Costs w/o OVA and Train 263,730

Annualized Initial Costs 37,469

Annual Expenses 389,387

Annual Fixed Costs ($/yr) 305,699

Annual Variable Costs ($/yr) 121,157

Option1APIdata 
Type of Component

Pump Seals

Refinery Model process * Light-liquid service

Reconstructed MACT * 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 * No. Processes (valves and pumps) * No. Processes (connectors)Planning and Training * No. Processes (valves and pumps) * No. Processes (connectors)TOTALS 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)

MonitVerify 

(

12.45 100 16.00 69.90 13929.26 0 80.00 69.90 0.00 72.38 75 0.17 69.90 633.70 25 4.00 69.90 5059.50 

144.40 75 0.17 69.90 1264.26 25 4.00 69.90 10093.88 

36.55 75 0.17 69.90 320.02 25 2.00 69.90 1277.53 65.52 75 0.17 69.90 573.63 25 2.00 69.90 2289.93 

0.00 75 0.17 69.90 0.00 25 2.00 69.90 0.00 0.00 75 0.17 69.90 0.00 25 2.00 69.90 0.00 

15,827.22 15,153.38 16,720.87 18,720.84 

893.65 3567.46 

Option1APIdata 
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 Maintenan

Costs ($/y

Pump Seals

Refinery Model process * Light-liquid service 59 0.00 1,609.55 12 1.50 2848.91 1254

Reconstructed NSPS * Heavy-liquid service 54 0.00 0.00

Option 1

Valves * Gas/vapor service 982 0.00 3,749.69 2 1.50 2947.32  * Light-liquid service 2,123 0.00 8,377.79 2 1.50 6367.93  * Heavy-liquid service 985 0.00 0.00Connectors * Flanges - gas/vapor 2,310 17.70 42,692.44 1 2.50 5773.78  * Flanges - light liquid 4,647 17.70 85,893.76 1 2.50 11616.38  * Flanges -heavy liquid 2,566 1.13 2,899.37Connectors (baseline) * Flanges - gas/vapor 2,310 0.00 0.00 0 0.00 0.00  * Flanges - light liquid 4,647 0.00 0.00 0 0.00 0.00  * Flanges -heavy liquid 2,566 0.00 0.00Replacement Pump Seals 59 180.00 258.70Administrative and Reports hr/activity $/hr

 * No. Processes (valves and pumps) 7 250 68.78 * No. Processes (connectors) 7 50 68.78Planning and Training hr/activity $/hr * No. Processes (valves and pumps) 7 0 68.78 0.00 * No. Processes (connectors) 7 20 68.78 9,048.54TOTALS without connectors 13,995.73 0.00 12164.16 1254TOTALS with connectors 145,481.29 9,048.54 29554.32 1254

Without connectors

Initial Costs w/o OVA and Train 13,996

Annualized Initial Costs 2,014

Annual Expenses 145,047

Annual Fixed Costs ($/yr) 116,124

Annual Variable Costs ($/yr) 30,937

With connectors

Initial Costs w/o OVA and Train 154,530

Annualized Initial Costs 21,970

Annual Expenses 187,674

Annual Fixed Costs ($/yr) 158,701

Annual Variable Costs ($/yr) 50,942

Option1APIdata 
Type of Component

Pump Seals

Refinery Model process * Light-liquid service

Reconstructed NSPS * 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 * No. Processes (valves and pumps) * No. Processes (connectors)Planning and Training * No. Processes (valves and pumps) * No. Processes (connectors)TOTALS 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)

MonitVerify 

(

6.97 100 16.00 69.90 7792.06 0 80.00 69.90 0.00 

37.59 75 0.17 69.90 329.12 25 4.00 69.90 2627.73 83.63 75 0.17 69.90 732.16 25 4.00 69.90 5845.62 18.79 75 0.17 69.90 164.51 25 2.00 69.90 656.72 37.80 75 0.17 69.90 330.98 25 2.00 69.90 1321.26 

0.00 75 0.17 69.90 0.00 25 2.00 69.90 0.00 0.00 75 0.17 69.90 0.00 25 2.00 69.90 0.00 

8853.34 8473.35 9348.83 10451.33 

Option1APIdata 
SUMMARY OF IMPACTS OF LDAR FOR CONNECTORS (Option 2 only, without Option 1)

Parameter New CD New MACT New NSPS

Reconstructed 

CD

Reconstructed 

MACT

Reconstructed 

NSPS

Total number of processes 89 18 10 60 12 7

Total number of connectors 95,095 18,819 10,434 63,397 12,546 6,956

Total number of heavy liquid connectors 36,292 7,315 3,849 24,195 4,877 2,566

Baseline (no LDAR)

 initial leak frequency, percenta 1.7 1.7 1.7 1.7 1.7 1.7

 emission rate, kg/hr/connectorb 0.0000944 0.0000944 0.0000944 0.0000944 0.0000944 0.0000944

Option 3 (500 ppm LDAR)

 initial number of leaks 1,616.62 319.92 177.38 1,077.75 213.28 118.25

 final leak frequency, percentc 0.81 0.81 0.81 0.81 0.81 0.81

 monitoring frequency, times/yrd 111111

 annual number of leaks 773.70 153.11 84.89 515.80 102.07 56.59

 emission rate, kg/hr/connectore 0.0000484 0.0000484 0.0000484 0.0000484 0.0000484 0.0000484

Time in service, hr/yr 8,760 8,760 8,760 8,760 8,760 8,760

Total emissions reduction, Mg/yr 38.26 7.57 4.20 25.50 5.05 2.80

Baseline cost, $/yr 000000

Option 3 costs

 initial monitoring, gas and light liquid, $/componentf 17.70 17.70 17.70 17.70 17.70 17.70

 initial monitoring, heavy liquid, $/componentf 1.13 1.13 1.13 1.13 1.13 1.13

 initial LDAR cost (monitoring and repair), $ 1,798,896 356,141 197,228 1,199,264 237,427 131,486

 planning and training costs, $ 123,083 24,289 13,573 82,055 16,193 9,049

 monitoring to verify repair for initial leaks, $ 4,042 800 443 2,694 533 296

 annualized initial LDAR cost, $/yrg 273,495 54,135 29,997 182,330 36,090 19,998

 subsequent monitoring fee, $/component 2.50 2.50 2.50 2.50 2.50 2.50

 annual monitoring cost, $/yr 237,739 47,047 26,085 158,492 31,365 17,390

 percent of annual leaks repaired online, percent 75 75 75 75 75 75

 online repair time, hr 0.17 0.17 0.17 0.17 0.17 0.17

 labor charge, $/hrh 69.9 69.9 69.9 69.9 69.9 69.9

 annual online leak repair cost, $/yr 6773.70 1340.47 743.23 4515.80 893.65 495.48

 percent of annual leaks repaired offline, percent 25 25 25 25 25 25

 offline repair time, hr 222222

 labor charge, $/hrh 69.9 69.9 69.9 69.9 69.9 69.9

 annual offline leak repair cost, $/yr 27,041 5,351 2966.97 18027.13 3,567 1977.98

 monitoring to verify repair, $ 1934.24 382.77 212.23 1289.49 255.18 141.49

 annual admin and reporting costs, $ 307,707 60,724 33,932 205,138 40,482 22,621

 total annual cost, $/yr 854,689 168,980 93,936 569,793 112,653 62,624

Cost effectiveness, $/Mg removed 22,342 22,321 22,379 22,342 22,321 22,379

Recovery credits, $/Mg 600 600 600 600 600 600

Nationwide impacts in fifth year after proposal Total

 emission reductions, Mg/yr 38.3 7.6 4.2 26 5.0 2.8 83.4

 total annual costs, $/yr 854,689 168,980 93,936 569,793 112,653 62,624 1,862,676

 total annual costs after recovery credit applied, $/yr 831,736 164,438 91,418 554,491 109,625 60,945 1,812,653

a

Refinery baseline leak frequencies assumed to be 1.7 percent, as in Table G-2 of the Protocol document.

b

Refinery values calculated using the correlation equations with assumed average screening values and 1.7 percent leakers (same as in Protocol

 document) with the same distribution among the concentration ranges as for the controlled emission rate calculation.

c

The API report Analysis of Refinery Screening Values identified about 0.27 percent leakers for connectors in gas service and 0.18 percent for light

 liquid service when monitoring was conducted quarterly. The NSPS would not likely require monitoring more frequently than once per year. At this

 monitoring frequency, the leak frequency could be as much as four times greater (if all leaks are new). The API report indicates that about 10 percent

 of the leaks are repeats over 4 quarters. Thus, assumed 0.81 percent would leak under an annual monitoring program (i.e., (0.27+0.18)/2*4*0.9=0.81). 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

For refineries, the emission rates were estimated using the correlation equation with the same average screening values as in the estimate of the

 uncontrolled emission rate, an average leak fraction equal to one-half of the final leak frequency, and the same distribution of leak concentrations as

 reported in Table 3-1 of the API report Analysis of Refinery Screening Data . 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.

Refinery Model

Option 2 Emissions G-19
Attachment H 

Open Ended Lines 
Baseline Calculations

Baseline conditions = caps/plugs, but not properly installedCalculate baseline emissions assuming emissions from OELs with plugs/caps poorly installed is better represented by correlation equationflanges and 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), % 2.3percent in range 87.700 10.0000 0.2930 0.9376 0.6592 0.2490 0.1611 100.00representative value default 0 758 3,318 22,898 73,829 350,727

zero

emissions (kg/hr/OEL) connectors 0.0000075 0.0000075 0.0002001 0.000592 0.00245 0.005792 0.018207

emissions (kg/hr/OEL) flanges 0.00000031 0.00000031 0.0004877 0.001377 0.005353 0.012192 0.03646

uncapped OEL correlation 0.000002 0.000002 0.0002343 0.000662 0.002581 0.005884 0.017623

Baseline emissionsTotal number of process units subject 195 from Refinery Impacts Analysis memorandum to NSPS in 5th year after proposalTotal number of OELs 7349 from Refinery Impacts Analysis memorandumNumber of OELs in G/V or LL service 5365 fraction in G/V and LL service assumed to be 73 percent based on MACT I data fo

Fraction in sampling systems 0.05Number of OELs to be monitored 5097kg/hr/OEL in G/V or LL service 0.00007 assuming emissions represented using only connectors equation

kg/hr nationwide 0.374kg/d nationwide 8.976kg/yr nationwide 3276.236Mg/yr nationwide 3.276

Emission Reductions

Assume OEL valves are opened with the following frequencies Monitoring Opening

time percent 

period opened What are percent reductions for semi-annual 

once per month 0 6 1 8.333333 

once per quarter 33.333 6 3 25 

once per year 33.333 6 12 75 

once per 2 years 33.333 6 24 100 

overall 66.7 Average subsequent le

Months between

OEL 
Cost Analysis

Notes

Monitoring events per year 2

Percent reduction in emissions 66.67

Mass reduction, nationwide Mg/yr 43.689

Mass reduction, nationwide kg/yr 43,689

Total number of OELs at new and 147,000 From Refinery Impacts Analysis memorandum

 reconstructed units in 5 years after

 proposal

Number of OELs in gas/vapor or light 101,945 assuming OEL in G/V and LL service are 73% of total (see

 liquid service valves, pumps, and flanges in MACT I data in pumps/

 valves refinery spreadsheet and impacts memo) and

 5 percent OEL are in sampling connection systems

Initial costs

Equipment, $

 $/cap 0 because they should already be using caps, plugs, etc.

 $/refinery 0

Initial monitoring, $

 $/OEL 17.70

 nationwide $ 1,804,418

Initial repair, $

 initial percentage leaking 2.3 based on max from industry comments

 repair costs, $ nationwide 58,781 using same assumptions for online vs offline repair fractions

 wage rates, and repair time as for ongoing repair

Total Initial Costs, $ 1,863,199

Annual costs, nationwide $/yr

 Annualized initial costs 204,579 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 305,834 assuming only monitor OELs in gas and LL service

 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 H-2
 Repair

 subsequent leak frequency 1.15

 subsequent number leaking 1172.36

 percentage repaired attempted 95 assuming tightening the valve, or properly installing the plug

 online cap 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 23.3

 overhead factor 3

 online repair cost, $/OEL 13.17 includes monitoring to verify repair

 online repair cost, nationwide $ 29,343

 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 281

 offline repair cost, nationwide $ 32,955

 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 68.78

 annual cost, nationwide $/yr 6,878 assuming 50 of the 150 refineries have at least one process

 unit subject to NSPS

 Total annual cost, nationwide $/yr 579,589

 Recovery credit

 product value, $/Mg 600

 total recovered, Mg nationwide 43.69

 total recovered, tons nationwide 48.16

 total savings, nationwide $/yr 26,213

 TAC with recovery savings, $/yr 553,376

Cost effectiveness, $/Mg removed (with 

recovery credit, OEL only) 12,666

Cost effectiveness, $/ton removed

Sensitivity Analysis

Number 

of OEL

Option 3 

Emission 

Reduction 

(tons)

Option 3 

Cost Beyond 

Baseline ($)

CostEffectiveness 

($/ton)

If number of OEL is increased: 7,349 107 1,924,577 18,000

14,700 109 1,953,217 17,866

36,700 117 2,038,929 17,496

73,500 129 2,182,301 16,971

110,200 141 2,325,284 16,536

147,000 153 2,468,657 16,170

OEL H-3
Attachment I 

Valve Leak Definition of 100 ppm 
monthly quarterly semiannual annual

SubsequenPumps, 10,000 0.88 2.47

Pumps, 1,000 0.98 2.77 5.20 10.00

Gas Valves, 10,000 10,000 0.61 1.18 2.32

Gas Valves, 1,000 1000 0.88 1.69 3.31

Gas Valves, 500 500 1.00 1.91 3.73

Gas Valves, 100 100 1.28 2.45 4.77

LL Valves, 10,000 10,000 0.72 1.38 2.70

LL Valves, 1,000 1000 0.86 1.65 3.23

LL Valves, 500 500 1.03 1.97 3.83

LL Valves, 100 100 1.18 2.25 4.37

Black = given by API

Red = calc using NEIC average (1.28)

Blue = converted from different leak frequency using API repeat leakers

Gray = figure out how to calculate

Purple = calculated using NEIC average and API repeat leakers

Using highlighted values

0.00

0.50

1.00

1.50

2.00

2.50

3.00

0 2,000 4,000 6,000 8,000 10,000 12,000

Series1

Log. (Series1)

SubLeakFreq I-1
GAS VALVES 88.462 9.829 0.20395278 1.07975 0.239944444 0.046275 0.138825

New = Quarterly, 100, Baseline = Annual, 10,000 (VV to VVa)

1 Controlled, with leak frequency as summarized in API report equal to leak fraction (i.e., estimate emission rate when monitored, not average over monitoring period)

leak range 0 100 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (100 ppm), % 4.20percent in range 86.221 9.580 0.920 0.391 2.072 0.460 0.089 0.266 0.816representative value default 33 232 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/valve) 0.0000078 3.11E-05 1.33E-04 0.00029219 0.00110798 0.004135133 0.00907111 0.034398 0.00015376 Only 44% of av

 Possibly LLV  because of o

2 Controlled estimate using average leak rate as one-half of reported leak frequency

leak range 0 100 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (100 ppm), % 4.20 This level wou

percent in range 87.972 9.775 0.613 0.196 1.036 0.230 0.044 0.133 100.000 case for the representative value default 33 232 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/valve) 0.0000078 3.11E-05 0.0001332 0.00029219 0.00110798 0.004135133 0.00907111 0.034398 0.00008214

3 Baseline estimate

leak range 0 100 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (10,000 ppm), % 2.03 10.451 (at 100 ppm)percent in range 80.595 8.955 2.290 0.974 5.157 1.146 0.221 0.663 100.000representative value default 33 232 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/valve) 0.0000078 3.10919E-05 0.0001332 0.00029219 0.00110798 0.004135133 0.00907111 0.034398 0.00036761

4 Baseline estimate - average above 10,000 ppm

leak range 0 100 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (10,000 ppm), % 2.03 10.451 (at 500 ppm)percent in range 81.508 9.056 2.290 0.974 5.157 0.573 0.111 0.332 100.000representative value default 33 232 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/valve) 0.0000078 3.11E-05 0.0001332 0.00029219 0.00110798 0.004135133 0.00907111 0.034398 0.00021996

5 Baseline and Initial Leak Freq. Calc.

leak range 0 100 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (10,000 ppm), % 1.18 6.098 (at 100 ppm)percent in range 84.512 9.390 1.336 0.568 3.009 0.669 0.129 0.387

Emissions Estimates Calcs 
New = Quarterly, 100, Baseline = Semiannual, 1,000 (mod HON to VVa)

1b Controlled, with leak frequency as summarized in API report equal to leak fraction (i.e., estimate emission rate when monitored, not average over monitoring period)

leak range 0 100 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (100 ppm), % 4.20percent in range 86.221 9.580 0.920 0.391 2.072 0.460 0.089 0.266 0.816representative value default 33 232 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/valve) 0.0000078 3.10919E-05 0.0001332 0.00029219 0.00110798 0.004135133 0.00907111 0.034398 0.00015376

2b Controlled estimate using average leak rate as one-half of reported leak frequency

leak range 0 100 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (100 ppm), % 4.20percent in range 88.110 9.790 0.460 0.196 1.036 0.230 0.044 0.133 100.000representative value default 33 232 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/valve) 0.0000078 3.10919E-05 0.0001332 0.00029219 0.00110798 0.004135133 0.00907111 0.034398 0.00008195

3b Baseline estimate

leak range 0 100 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (1,000 ppm), % 2.90 4.222 (at 100 ppm)percent in range 86.200 9.578 0.925 0.394 2.083 0.463 0.089 0.268 100.000representative value default 33 232 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/valve) 0.0000078 3.10919E-05 0.0001332 0.00029219 0.00110798 0.004135133 0.00907111 0.034398 0.00015455

4b Baseline estimate - average above 1,000 ppm

leak range 0 100 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (1,000 ppm), % 2.90percent in range 87.507 9.723 0.925 0.394 1.042 0.231 0.045 0.134 100.000representative value default 33 232 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/valve) 0.0000078 3.10919E-05 0.0001332 0.00029219 0.00110798 0.004135133 0.00907111 0.034398 0.00008346

5b Baseline and Initial Leak Freq. Calc.

leak range 0 100 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (1,000 ppm), % 1.69 2.463 (at 100 ppm)percent in range 87.783 9.754 0.540 0.230 1.216 0.270 0.052 0.156

Emissions Estimates Calcs 
Quarterly, 100

1c Controlled, with leak frequency as summarized in API report equal to leak fraction (i.e., estimate emission rate when monitored, not average over monitoring period)

leak range 0 100 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (100 ppm), % 2.19percent in range 88.031 9.781 0.479 0.204 1.080 0.240 0.046 0.139 0.425representative value default 33 232 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/valve) 0.0000078 3.1092E-05 0.0001332 0.00029219 0.001107983 0.00413513 0.00907111 0.034398001 0.00008498

2c Controlled estimate using average leak rate as one-half of reported leak frequency

leak range 0 100 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (100 ppm), % 2.19percent in range 89.015 9.891 0.240 0.102 0.540 0.120 0.023 0.069 100.000representative value default 33 232 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/valve) 0.0000078 3.1092E-05 0.0001332 0.00029219 0.001107983 0.00413513 0.00907111 0.034398001 0.00004755

3c Controlled, with leak frequency as summarized in API report equal to leak fraction (i.e., estimate emission rate when monitored, not average over monitoring period)

leak range 0 100 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (500 ppm), % 1.71 2.692 (at 100 ppm)percent in range 87.578 9.731 0.983 0.204 1.080 0.240 0.046 0.139 0.425representative value default 33 232 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/valve) 0.0000078 3.1092E-05 1.33E-04 0.00029219 0.001107983 0.00413513 0.00907111 0.034398001 0.00008560

4c Controlled estimate using average leak rate as one-half of reported leak frequency

leak range 0 100 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (500 ppm), % 1.71percent in range 88.346 9.816 0.983 0.102 0.540 0.120 0.023 0.069 100.000representative value default 33 232 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/valve) 0.0000078 3.1092E-05 0.0001332 0.00029219 0.001107983 0.00413513 0.00907111 0.034398001 0.00004847

5c Baseline and Initial Leak Freq. Calc.

leak range 0 100 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (500 ppm), % 1.00 1.570 (at 100 ppm)percent in range 88.587 9.843 0.573 0.119 0.630 0.140 0.027 0.081

Emissions Estimates Calcs 
LIGHT LIQUID VALVES 88.410 9.823 0.29993056 0.971775 0.318783333 0.04113333 0.13539722

1 Controlled, with leak frequency as summarized in API report equal to leak fraction (i.e., estimate emission rate when monitored, not average over monitoring period)

leak range 0 100 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (100 ppm), % 3.86percent in range 86.529 9.614 0.480 0.573 1.857 0.609 0.079 0.259 100.000representative value default 33 232 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/valve) 0.0000078 3.11E-05 0.0001332 0.00029219 0.00110798 0.004135133 0.00907111 0.034398 0.00015393 Only 44% of av

 Possibly LLV  because of o

2 Controlled estimate using average leak rate as one-half of reported leak frequency

leak range 0 100 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (100 ppm), % 3.86 This level wou

percent in range 88.265 9.807 0.240 0.287 0.928 0.305 0.039 0.129 100.000 case for the representative value default 33 232 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/valve) 0.0000078 3.11E-05 0.0001332 0.00029219 0.00110798 0.004135133 0.00907111 0.034398 0.00008203

3 Baseline estimate

leak range 0 100 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (10,000 ppm), % 2.37 9.639 (at 500 ppm)percent in range 81.325 9.036 1.200 1.432 4.641 1.523 0.196 0.647 100.000representative value default 33 232 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/valve) 0.0000078 3.10919E-05 0.0001332 0.00029219 0.00110798 0.004135133 0.00907111 0.034398 0.00036957

4 Baseline estimate - average above 10,000 ppm

leak range 0 100 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (10,000 ppm), % 2.37 9.639 (at 100 ppm)percent in range 82.389 9.154 1.200 1.432 4.641 0.761 0.098 0.323 100.000representative value default 33 232 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/valve) 0.0000078 3.10919E-05 0.0001332 0.00029219 0.00110798 0.004135133 0.00907111 0.034398 0.00021809

5 Baseline and Initial Leak Freq. Calc.

leak range 0 100 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (10,000 ppm), % 1.38 5.624 (at 500 ppm)percent in range 85.568 9.438 0.700 0.836 2.708 0.888 0.115 0.377

Emissions Estimates Calcs 
New = Quarterly, 100, Baseline = Semiannual, 1,000 (mod HON to VVa)

1b Controlled, with leak frequency as summarized in API report equal to leak fraction (i.e., estimate emission rate when monitored, not average over monitoring period)

leak range 0 100 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (100 ppm), % 3.86percent in range 86.529 9.614 0.480 0.573 1.857 0.609 0.079 0.259 0.946representative value default 33 232 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/valve) 0.0000078 3.10919E-05 0.0001332 0.00029219 0.00110798 0.004135133 0.00907111 0.034398 0.00015393

2b Controlled estimate using average leak rate as one-half of reported leak frequency

leak range 0 100 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (100 ppm), % 3.86percent in range 88.265 9.807 0.240 0.287 0.928 0.305 0.039 0.129 100.000representative value default 33 232 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/valve) 0.0000078 3.10919E-05 0.0001332 0.00029219 0.00110798 0.004135133 0.00907111 0.034398 0.00008203

3b Baseline estimate

leak range 0 100 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (1,000 ppm), % 2.83 3.894 (at 500 ppm)percent in range 86.496 9.611 0.485 0.579 1.875 0.615 0.079 0.261 100.000representative value default 33 232 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/valve) 0.0000078 3.10919E-05 0.0001332 0.00029219 0.00110798 0.004135133 0.00907111 0.034398 0.00015533

4b Baseline estimate - average above 10,000 ppm

leak range 0 100 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (1,000 ppm), % 2.83 3.894 (at 500 ppm)percent in range 86.926 9.658 0.485 0.579 1.875 0.308 0.040 0.131 100.000representative value default 33 232 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/valve) 0.0000078 3.10919E-05 0.0001332 0.00029219 0.00110798 0.004135133 0.00907111 0.034398 0.00009413

5b Baseline and Initial Leak Freq. Calc.

leak range 0 100 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (1,000 ppm), % 1.65 2.272 (at 500 ppm)percent in range 88.210 9.773 0.283 0.338 1.094 0.359 0.046 0.152

Emissions Estimates Calcs 
Quarterly, 100

1c Controlled, with leak frequency as summarized in API report equal to leak fraction (i.e., estimate emission rate when monitored, not average over monitoring period)

leak range 0 100 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (100 ppm), % 2.02percent in range 88.184 9.798 0.251 0.300 0.972 0.319 0.041 0.135 0.495representative value default 33 232 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/valve) 0.0000078 3.1092E-05 0.0001332 0.00029219 0.001107983 0.00413513 0.00907111 0.034398001 0.00008539

2c Controlled estimate using average leak rate as one-half of reported leak frequency

leak range 0 100 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (100 ppm), % 2.02

percent in range 89.092 9.899 0.126 0.150 0.486 0.159 0.021 0.068 100.000

representative value default 33 232 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/valve) 0.0000078 3.1092E-05 0.0001332 0.00029219 0.001107983 0.00413513 0.00907111 0.034398001 0.00004776

3c Controlled, with leak frequency as summarized in API report equal to leak fraction (i.e., estimate emission rate when monitored, not average over monitoring period)

leak range 0 100 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (500 ppm), % 1.77 2.749 (at 100 ppm)percent in range 87.526 9.725 0.982 0.300 0.972 0.319 0.041 0.135 0.495representative value default 33 232 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/valve) 0.0000078 3.1092E-05 0.0001332 0.00029219 0.001107983 0.00413513 0.00907111 0.034398001 0.00008629

4c Controlled estimate using average leak rate as one-half of reported leak frequency

leak range 0 100 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (500 ppm), % 1.77percent in range 88.321 9.813 0.982 0.150 0.486 0.159 0.021 0.068 100.000representative value default 33 232 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/valve) 0.0000078 3.1092E-05 0.0001332 0.00029219 0.001107983 0.00413513 0.00907111 0.034398001 0.00004881

5c Baseline and Initial Leak Freq. Calc.

leak range 0 100 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (1,000 ppm), % 1.03 1.604 (at 100 ppm)percent in range 88.556 9.840 0.573 0.175 0.567 0.186 0.024 0.079

Emissions Estimates Calcs 
Cost estimates for implementing Option 1. Costs include initial planning and training for process units not already subject to MACT, initial repair, 

 repairs. Initial capital costs are annualized. Annual costs and expenses used in "Option 1 Emissions" to estimate incremental cost.NOTE: The estimate including connectors is meant to be a check for the impacts of Option 2. These values are not directly used in estimating th

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) Init

Fre

Pump Seals

Refinery Model process * Light-liquid service 802 17.70 14,194.21 12 1.50 38725.32 17046.82 

New CD * Heavy-liquid service 580 1.13 654.97

Option 1

Valves * Gas/vapor service 14,014 17.70 248,056.28 4 1.50 84086.88  * Light-liquid service 28,223 17.70 499,547.21 4 1.50 169338.04  * Heavy-liquid service 14,918 1.13 16,857.34Connectors * Flanges - gas/vapor 33,169 17.70 612,585.38 1 2.50 82923.07  * Flanges - light liquid 61,926 17.70 1,143,683.88 1 2.50 154815.61  * Flanges -heavy liquid 36,292 1.13 41,010.20Connectors (baseline) * Flanges - gas/vapor 33,169 0.00 0.00 0 0.00 0.00  * Flanges - light liquid 61,926 0.00 0.00 0 0.00 0.00  * Flanges -heavy liquid 36,292 0.00 0.00Replacement Pump Seals 802 180.00 0.00Adminstrative and Reports hr/activity $/hr * No. Processes (valves and pumps) 89 250 68.78 * No. Processes (connectors) 89 50 68.78Planning and Training hr/activity $/hr * No. Processes (valves and pumps) 89 320 68.78 1,969,326.48 * No. Processes (connectors) 89 20 68.78 123,082.90TOTALS without connectors 779,310.01 1,969,326.48 292,150.23 17,046.82TOTALS with connectors 2,576,589.47 2,092,409.38 529,888.92 17,046.82

Without connectors

Initial Costs w/o OVA and Train 2,748,636

Annualized Initial Costs 390,306

Annual Expenses 2,131,356

Annual Fixed Costs ($/yr) 1,942,480

Annual Variable Costs ($/yr) 579,182

With connectors

Initial Costs w/o OVA and Train 4,668,999

Annualized Initial Costs 662,998

Annual Expenses 2,712,551

Annual Fixed Costs ($/yr) 2,522,879

Annual Variable Costs ($/yr) 852,670

Option1APIdata 
Type of Component

Pump Seals

Refinery Model process * Light-liquid service

New CD * 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 SealsAdminstrative and Reports * No. Processes (valves and pumps) * No. Processes (connectors)Planning and Training * No. Processes (valves and pumps) * No. Processes (connectors)TOTALS 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)

Monitoring to 

Verify Repair 

($)

94.70 100 16.00 69.90 105917.60 0 80.00 69.90 0.00 142.06 

715.70 75 0.17 69.90 6265.92 25 4.00 69.90 50027.34 1073.55

1329.41 75 0.17 69.90 11638.94 25 4.00 69.90 92925.63 1994.11

269.86 75 0.17 69.90 2362.66 25 2.00 69.90 9431.78 674.66503.83 75 0.17 69.90 4411.04 25 2.00 69.90 17608.93 1259.58

0.00 75 0.17 69.90 0.00 25 2.00 69.90 0.00 0.000.00 75 0.17 69.90 0.00 25 2.00 69.90 0.00 0.00

123,822.46 142,952.98 3,209.72 130,596.16 169,993.68 5,143.96 

Option1APIdata 
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) Init

Fre

Pump Seals

Refinery Model process * Light-liquid service 158 17.70 2,800.03 12 1.50 7639.17 3362.75 

New MACT * Heavy-liquid service 97 1.13 110.01

Option 1

Valves * Gas/vapor service 2,837 17.70 50,222.35 4 1.50 17024.52  * Light-liquid service 5,498 17.70 97,312.64 4 1.50 32987.34  * Heavy-liquid service 3,111 1.13 3,515.86Connectors * Flanges - gas/vapor 6,739 17.70 124,461.43 1 2.50 16847.81  * Flanges - light liquid 12,080 17.70 223,093.54 1 2.50 30199.22  * Flanges -heavy liquid 7,315 1.13 8,266.35Connectors (baseline) * Flanges - gas/vapor 6,739 0.00 0.00 0 0.00 0.00  * Flanges - light liquid 12,080 0.00 0.00 0 0.00 0.00  * Flanges -heavy liquid 7,315 0.00 0.00Replacement Pump Seals 158 180.00 0.00Adminstrative and Reports hr/activity $/hr * No. Processes (valves and pumps) 18 250 68.78 * No. Processes (connectors) 18 50 68.78Planning and Training hr/activity $/hr * No. Processes (valves and pumps) 18 320 68.78 388,631.69 * No. Processes (connectors) 18 20 68.78 24,289.48TOTALS without connectors 1,036,791.23 388,631.69 58,128.45 47,504.27TOTALS with connectors 1,392,612.55 412,921.17 105,175.48 47,504.27

Without connectors

Initial Costs w/o OVA and Train 1,425,423

Annualized Initial Costs 204,942

Annual Expenses 500,549

Annual Fixed Costs ($/yr) 546,564

Annual Variable Costs ($/yr) 158,927

With connectors

Initial Costs w/o OVA and Train 1,805,534

Annualized Initial Costs 258,918

Annual Expenses 615,394

Annual Fixed Costs ($/yr) 661,264

Annual Variable Costs ($/yr) 213,049

Option1APIdata 
Type of Component

Pump Seals

Refinery Model process * Light-liquid service

New MACT * 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 SealsAdminstrative and Reports * No. Processes (valves and pumps) * No. Processes (connectors)Planning and Training * No. Processes (valves and pumps) * No. Processes (connectors)TOTALS 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)

Monitoring to 

Verify Repair 

($)

18.68 100 16.00 69.90 20893.88 0 80.00 69.90 0.00 28.02 

144.90 75 0.17 69.90 1268.62 25 4.00 69.90 10128.71 217.35258.97 75 0.17 69.90 2267.28 25 4.00 69.90 18102.07 388.46

54.83 75 0.17 69.90 480.03 25 2.00 69.90 1916.29 137.0798.28 75 0.17 69.90 860.44 25 2.00 69.90 3434.90 245.70

0.00 75 0.17 69.90 0.00 25 2.00 69.90 0.00 0.000.00 75 0.17 69.90 0.00 25 2.00 69.90 0.00 0.00

24,429.79 28,230.78 633.83 25,770.26 33,581.97 1,016.61 

Option1APIdata 
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) Init

Fre

Pump Seals

Refinery Model process * Light-liquid service 88 17.70 1,566.34 12 1.50 4273.37 1881.13 

New NSPS * Heavy-liquid service 81 1.13 91.47

Option 1

Valves * Gas/vapor service 1,474 17.70 26,083.78 4 1.50 8841.96  * Light-liquid service 3,184 17.70 56,356.17 4 1.50 19103.79  * Heavy-liquid service 1,478 1.13 1,669.73Connectors * Flanges - gas/vapor 3,464 17.70 63,979.76 1 2.50 8660.67  * Flanges - light liquid 6,970 17.70 128,722.15 1 2.50 17424.57  * Flanges -heavy liquid 3,849 1.13 4,349.05Connectors (baseline) * Flanges - gas/vapor 3,464 0.00 0.00 0 0.00 0.00  * Flanges - light liquid 6,970 0.00 0.00 0 0.00 0.00  * Flanges -heavy liquid 3,849 0.00 0.00Replacement Pump Seals 88 180.00 0.00Adminstrative and Reports hr/activity $/hr * No. Processes (valves and pumps) 10 250 68.78 * No. Processes (connectors) 10 50 68.78Planning and Training hr/activity $/hr * No. Processes (valves and pumps) 10 320 68.78 217,165.04 * No. Processes (connectors) 10 20 68.78 13,572.81TOTALS without connectors 85,767.50 217,165.04 32219.12 1881.13

TOTALS with connectors 282,818.46 230,737.85 58304.35 1881.13

Without connectors

Initial Costs w/o OVA and Train 302,933

Annualized Initial Costs 43,016

Annual Expenses 235,023

Annual Fixed Costs ($/yr) 214,182

Annual Variable Costs ($/yr) 63,858

With connectors

Initial Costs w/o OVA and Train 513,556

Annualized Initial Costs 72,925

Annual Expenses 298,962

Annual Fixed Costs ($/yr) 278,022

Annual Variable Costs ($/yr) 93,865

Option1APIdata 
Type of Component

Pump Seals

Refinery Model process * Light-liquid service

New NSPS * 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 SealsAdminstrative and Reports * No. Processes (valves and pumps) * No. Processes (connectors)Planning and Training * No. Processes (valves and pumps) * No. Processes (connectors)TOTALS 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)

Monitoring to 

Verify Repair 

($)

10.45 100 16.00 69.90 11688.08 0 80.00 69.90 0.00 15.68 75.26 75 0.17 69.90 658.88 25 4.00 69.90 5260.51 112.89

149.98 75 0.17 69.90 1313.04 25 4.00 69.90 10483.36 224.96

28.19 75 0.17 69.90 246.76 25 2.00 69.90 985.08 70.4656.71 75 0.17 69.90 496.46 25 2.00 69.90 1981.89 141.77

0.00 75 0.17 69.90 0.00 25 2.00 69.90 0.00 0.000.00 75 0.17 69.90 0.00 25 2.00 69.90 0.00 0.00

13660.00 15743.87 353.53 14403.23 18710.84 565.76 

Option1APIdata 
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) Init

Fre

Pump Seals

Refinery Model process * Light-liquid service 535 0.00 0.00 12 1.50 25816.88 11364.55 

Reconstructed CD * Heavy-liquid service 386 0.00 0.00

Option 1

Valves * Gas/vapor service 9,343 0.00 11,761.26 4 1.50 56057.92  * Light-liquid service 18,815 0.00 24,193.00 4 1.50 112892.02  * Heavy-liquid service 9,945 0.00 0.00Connectors * Flanges - gas/vapor 22,113 17.70 408,390.25 1 2.50 55282.05  * Flanges - light liquid 41,284 17.70 762,455.92 1 2.50 103210.41  * Flanges -heavy liquid 24,195 1.13 27,340.13Connectors (baseline) * Flanges - gas/vapor 22,113 0.00 0.00 0 0.00 0.00  * Flanges - light liquid 41,284 0.00 0.00 0 0.00 0.00  * Flanges -heavy liquid 24,195 0.00 0.00Replacement Pump Seals 535 180.00 0.00Adminstrative and Reports hr/activity $/hr * No. Processes (valves and pumps) 60 250 68.78 * No. Processes (connectors) 60 50 68.78Planning and Training hr/activity $/hr * No. Processes (valves and pumps) 60 0 68.78 0.00 * No. Processes (connectors) 60 20 68.78 82,055.27TOTALS without connectors 35,954.26 0.00 194,766.82 11,364.55TOTALS with connectors 1,234,140.56 82,055.27 353,259.28 11,364.55

Without connectors

Initial Costs w/o OVA and Train 35,954

Annualized Initial Costs 5,106

Annual Expenses 1,420,904

Annual Fixed Costs ($/yr) 1,039,888

Annual Variable Costs ($/yr) 386,121

With connectors

Initial Costs w/o OVA and Train 1,316,196

Annualized Initial Costs 186,900

Annual Expenses 1,808,367

Annual Fixed Costs ($/yr) 1,426,820

Annual Variable Costs ($/yr) 568,446

Option1APIdata 
Type of Component

Pump Seals

Refinery Model process * Light-liquid service

Reconstructed CD * 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 SealsAdminstrative and Reports * No. Processes (valves and pumps) * No. Processes (connectors)Planning and Training * No. Processes (valves and pumps) * No. Processes (connectors)TOTALS 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)

Monitoring to 

Verify Repair 

($)

63.14 100 16.00 69.90 70611.73 0 80.00 69.90 0.00 94.70 

477.13 75 0.17 69.90 4177.28 25 4.00 69.90 33351.56 715.70886.27 75 0.17 69.90 7759.29 25 4.00 69.90 61950.42 1329.41179.91 75 0.17 69.90 1575.11 25 2.00 69.90 6287.85 449.77335.89 75 0.17 69.90 2940.69 25 2.00 69.90 11739.28 839.72

0.00 75 0.17 69.90 0.00 25 2.00 69.90 0.00 0.000.00 75 0.17 69.90 0.00 25 2.00 69.90 0.00 0.00

82,548.31 95,301.98 2,139.81 87,064.10 113,329.12 3,429.31 

4515.80 18027.13 1289.49 

Option1APIdata 
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) Init

Fre

Pump Seals

Refinery Model process * Light-liquid service 105 0.00 1,162.33 12 1.50 5092.78 2241.83 

Reconstructed MACT * Heavy-liquid service 65 0.00 0.00

Option 1

Valves * Gas/vapor service 1,892 0.00 3,735.02 4 1.50 11349.68  * Light-liquid service 3,665 0.00 6,674.44 4 1.50 21991.56  * Heavy-liquid service 2,074 0.00 0.00Connectors * Flanges - gas/vapor 4,493 17.70 82,974.28 1 2.50 11231.87  * Flanges - light liquid 8,053 17.70 148,729.03 1 2.50 20132.81  * Flanges -heavy liquid 4,877 1.13 5,510.90Connectors (baseline) * Flanges - gas/vapor 4,493 0.00 0.00 0 0.00 0.00  * Flanges - light liquid 8,053 0.00 0.00 0 0.00 0.00  * Flanges -heavy liquid 4,877 0.00 0.00Replacement Pump Seals 105 180.00 186.82Adminstrative and Reports hr/activity $/hr * No. Processes (valves and pumps) 12 250 68.78 * No. Processes (connectors) 12 50 68.78Planning and Training hr/activity $/hr * No. Processes (valves and pumps) 12 0 68.78 0.00 * No. Processes (connectors) 12 20 68.78 16,192.99TOTALS without connectors 11,758.61 0.00 38,752.30 31,669.51TOTALS with connectors 248,972.82 16,192.99 70,116.99 31,669.51

Without connectors

Initial Costs w/o OVA and Train 11,759

Annualized Initial Costs 1,689

Annual Expenses 333,699

Annual Fixed Costs ($/yr) 229,437

Annual Variable Costs ($/yr) 105,951

With connectors

Initial Costs w/o OVA and Train 265,166

Annualized Initial Costs 37,673

Annual Expenses 410,263

Annual Fixed Costs ($/yr) 305,903

Annual Variable Costs ($/yr) 142,032

Option1APIdata 
Type of Component

Pump Seals

Refinery Model process * Light-liquid service

Reconstructed MACT * 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 SealsAdminstrative and Reports * No. Processes (valves and pumps) * No. Processes (connectors)Planning and Training * No. Processes (valves and pumps) * No. Processes (connectors)TOTALS 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)

Monitoring to 

Verify Repair 

($)

12.45 100 16.00 69.90 13929.26 0 80.00 69.90 0.00 18.68 96.60 75 0.17 69.90 845.75 25 4.00 69.90 6752.47 144.90

172.65 75 0.17 69.90 1511.52 25 4.00 69.90 12068.05 258.97

36.55 75 0.17 69.90 320.02 25 2.00 69.90 1277.53 91.3865.52 75 0.17 69.90 573.63 25 2.00 69.90 2289.93 163.80

0.00 75 0.17 69.90 0.00 25 2.00 69.90 0.00 0.000.00 75 0.17 69.90 0.00 25 2.00 69.90 0.00 0.00

16,286.53 18,820.52 422.56 17,180.18 22,387.98 677.74 

893.65 3567.46 255.18 

Option1APIdata 
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) Init

Fre

Pump Seals

Refinery Model process * Light-liquid service 59 0.00 1,609.55 12 1.50 2848.91 1254.09 

Reconstructed NSPS * Heavy-liquid service 54 0.00 0.00

Option 1

Valves * Gas/vapor service 982 0.00 4,801.68 4 1.50 5894.64  * Light-liquid service 2,123 0.00 9,568.98 4 1.50 12735.86  * Heavy-liquid service 985 0.00 0.00Connectors * Flanges - gas/vapor 2,310 17.70 42,653.17 1 2.50 5773.78  * Flanges - light liquid 4,647 17.70 85,814.76 1 2.50 11616.38  * Flanges -heavy liquid 2,566 1.13 2,899.37Connectors (baseline) * Flanges - gas/vapor 2,310 0.00 0.00 0 0.00 0.00  * Flanges - light liquid 4,647 0.00 0.00 0 0.00 0.00  * Flanges -heavy liquid 2,566 0.00 0.00Replacement Pump Seals 59 180.00 258.70Adminstrative and Reports hr/activity $/hr * No. Processes (valves and pumps) 7 250 68.78 * No. Processes (connectors) 7 50 68.78Planning and Training hr/activity $/hr * No. Processes (valves and pumps) 7 0 68.78 0.00 * No. Processes (connectors) 7 20 68.78 9,048.54TOTALS without connectors 16,238.92 0.00 21479.41 1254.09TOTALS with connectors 147,606.22 9,048.54 38869.57 1254.09

Without connectors

Initial Costs w/o OVA and Train 16,239

Annualized Initial Costs 2,332

Annual Expenses 156,682

Annual Fixed Costs ($/yr) 116,442

Annual Variable Costs ($/yr) 42,572

With connectors

Initial Costs w/o OVA and Train 156,655

Annualized Initial Costs 22,271

Annual Expenses 199,308

Annual Fixed Costs ($/yr) 159,003

Annual Variable Costs ($/yr) 62,577

Option1APIdata 
Type of Component

Pump Seals

Refinery Model process * Light-liquid service

Reconstructed NSPS * 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 SealsAdminstrative and Reports * No. Processes (valves and pumps) * No. Processes (connectors)Planning and Training * No. Processes (valves and pumps) * No. Processes (connectors)TOTALS 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)

Monitoring to 

Verify Repair 

($)

6.97 100 16.00 69.90 7792.06 0 80.00 69.90 0.00 10.45 

50.17 75 0.17 69.90 439.25 25 4.00 69.90 3507.01 75.2699.98 75 0.17 69.90 875.36 25 4.00 69.90 6988.91 149.9818.79 75 0.17 69.90 164.51 25 2.00 69.90 656.72 46.9837.80 75 0.17 69.90 330.98 25 2.00 69.90 1321.26 94.51

0.00 75 0.17 69.90 0.00 25 2.00 69.90 0.00 0.000.00 75 0.17 69.90 0.00 25 2.00 69.90 0.00 0.00

9106.67 10495.91 235.68 9602.15 12473.89 377.17 

Option1APIdata 
Nationwide Impacts of 100 ppm Leak

Definition Cost-Effectiveness

(Mg/yr) (tons/yr) Cost ($/Mg) ($/ton)

Alternate Option Impacts 19 21 156,381 8,338 7,564

Incremental Impacts 7.3 8 129,990 17,767 16,118

Summary of emissions reductions and cost estimates for six refinery models

Refinery model

New CD Incremental emission reductions, Mg/yr

Annual cost, $/yr

Pumps plus valves 0.4

Subpart GGG with valves monitored: Pumps, valves, and connectors 38.63

Quarterly 2,495,829

Incremental cost increase, $/yr w/out credit w/ credit

Option 2 with valves monitored:

Quarterly 2,521,662 Pumps plus valves 25,833 25,610

Pumps, valves, and connectors 879,719 856,542

Option 3 with valves monitored:

Quarterly 3,375,548 Incremental cost effectiveness, $/Mg removed

Pumps plus valves 69,267 68,667

Operating hours/yr 8,760 Pumps, valves, and connectors 22,774 22,174

Refinery model

New MACT Incremental emission reductions, Mg/yr

Annual cost, $/yr

Pumps plus valves 3.6

Subpart GGG with valves monitored: Pumps, valves, and connectors 41.86

Semiannually 666,791

Incremental cost increase, $/yr w/out credit w/ credit

Option 2 with valves monitored:

Quarterly 705,491 Pumps plus valves 38,701 36,537

Pumps, valves, and connectors 207,521 182,405

Option 3 with valves monitored:

Quarterly 874,312 Incremental cost effectiveness, $/Mg removed

Pumps plus valves 10,733 10,133

Operating hours/yr 8,760 Pumps, valves, and connectors 4,957 4,357

Refinery model

New NSPS Incremental emission reductions, Mg/yr

Annual cost, $/yr

Pumps plus valves 7.28

Subpart GGG with valves monitored: Pumps, valves, and connectors 11.47

Semiannually 254,221

Incremental cost increase, $/yr w/out credit w/ credit

Option 2 with valves monitored:

Quarterly 278,039 Pumps plus valves 23,819 19,454

Pumps, valves, and connectors 117,667 110,783

Option 3 with valves monitored:

Quarterly 371,887 Incremental cost effectiveness, $/Mg removed

Pumps plus valves 3,274 2,674

Operating hours/yr 8,760 Pumps, valves, and connectors 10,256 9,656

Emission Reduction

Option 1 Emissions I-20
Refinery model

Reconstructed CD Incremental emission reductions, Mg/yr

Annual cost, $/yr

Pumps plus valves 0.25

Subpart GGG with valves monitored: Pumps, valves, and connectors 25.75

Quarterly 1,403,682

Incremental cost increase, $/yr w/out credit w/ credit

Option 2 with valves monitored:

Quarterly 1,426,009 Pumps plus valves 22,328 22,179

Pumps, valves, and connectors 591,585 576,134

Option 3 with valves monitored:

Quarterly 1,995,267 Incremental cost effectiveness, $/Mg removed

Pumps plus valves 89,802 89,202

Operating hours/yr 8,760 Pumps, valves, and connectors 22,972 22,372

Refinery model

Reconstructed MACT Incremental emission reductions, Mg/yr

Annual cost, $/yr

Pumps plus valves 2.4

Subpart GGG with valves monitored: Pumps, valves, and connectors 40.66

Semiannually 307,899

Incremental cost increase, $/yr w/out credit w/ credit

Option 2 with valves monitored:

Quarterly 335,388 Pumps plus valves 27,489 26,047

Pumps, valves, and connectors 140,036 115,641

Option 3 with valves monitored:

Quarterly 447,935 Incremental cost effectiveness, $/Mg removed

Pumps plus valves 11,436 10,836

Operating hours/yr 8,760 Pumps, valves, and connectors 3,444 2,844

Refinery model

Reconstructed NSPS Incremental emission reductions, Mg/yr

Annual cost, $/yr

Pumps plus valves 4.85

Subpart GGG with valves monitored: Pumps, valves, and connectors 7.65

Semiannually 140,803

Incremental cost increase, $/yr w/out credit w/ credit

Option 2 with valves monitored:

Quarterly 159,014 Pumps plus valves 18,211 15,301

Pumps, valves, and connectors 80,777 76,188

Option 3 with valves monitored:

Quarterly 221,580 Incremental cost effectiveness, $/Mg removed

Pumps plus valves 3,755 3,155

Operating hours/yr 8,760 Pumps, valves, and connectors 10,561 9,961

Option 1 Emissions I-21
Attachment J 

Results 
Nationwide Impacts for Future New and Reconstructed Petroleum Refineries

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 303.8 4,476,992 5,269,224 5,269,224

1 292.4 11 4,501,097 24,105 5,295,615 26,391 2,307 5,288,751 19,2 209.0 95 6,620,198 2,143,206 7,158,291 1,889,068 19,924 22,342 7,101,404 1,832,3 165.3 139 8,483,397 4,006,405 7,737,881 2,468,657 17,824 13,266 7,654,780 2,385,

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 334.9 4,476,992 5,269,224 5,269,224

1 322.3 13 4,501,097 24,105 5,295,615 26,391 2,093 5,288,751 19,2 230.4 105 6,620,198 2,143,206 7,158,291 1,889,068 18,075 20,268 7,101,404 1,832,3 182.2 153 8,483,397 4,006,405 7,737,881 2,468,657 16,170 12,035 7,654,780 2,385,

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 linesBaseline represents emissions and costs over the next five years if no changes are made to subparts VV and GGG. The

Baseline and the two Options account for the facilities subject to consent decree and new-source MACT.

Annual cost includes annualized initial cost - Initial costs are included for reference only

Without Recovery Credit With RWithout Recovery Credit With R

Nationwide Impacts Summary 
Summary of emissions reductions and cost estimates for six refinery models

Refinery model

New CD Incremental emission reductions

Annual cost, $/yr Mg/yr tons/yr

Pumps plus valves 0.0 0.0

Subpart GGG with valves monitored: Pumps, valves, and connectors 38.26 42.2

Quarterly 2,495,829

Incremental cost increase, $/yr w/out credit w/ credit

Option 1 with valves monitored:

Quarterly 2,495,829 Pumps plus valves 0 0

Pumps, valves, and connectors 854,116 831,162

Option 2 with valves monitored:

Quarterly 3,349,945 Incremental cost effectiveness

w/out credit w/ credit w/out credit w/ credit

Operating hours/yr 8,760 Pumps plus valves N/A N/A N/A N/A

Pumps, valves, and connectors 22,327 21,727 20,254 19,710

Refinery model

New MACT Incremental emission reductions

Annual cost, $/yr Mg/yr tons/yr

Pumps plus valves 1.1 1.2

Subpart GGG with valves monitored: Pumps, valves, and connectors 8.64 9.5

Semiannually 666,791

Incremental cost increase, $/yr w/out credit w/ credit

Option 1 with valves monitored:

Semiannually 674,178 Pumps plus valves 7,387 6,747

Pumps, valves, and connectors 176,253 171,071

Option 2 with valves monitored:

Semiannually 843,044 Incremental cost effectiveness

w/out credit w/ credit w/out credit w/ credit

Operating hours/yr 8,760 Pumps plus valves 6,923 6,323 6,281 5,736

Pumps, valves, and connectors 20,406 19,806 18,512 17,967

Refinery model

New NSPS Incremental emission reductions

Annual cost, $/yr Mg/yr tons/yr

Pumps plus valves 5.80 6.4

Subpart GGG with valves monitored: Pumps, valves, and connectors 9.99 11.0

Semiannually 254,221

Incremental cost increase, $/yr w/out credit w/ credit

Option 1 with valves monitored:

Semiannually 260,587 Pumps plus valves 6,367 2,889

Pumps, valves, and connectors 100,240 94,244

Option 2 with valves monitored:

Semiannually 354,461 Incremental cost effectiveness

w/out credit w/ credit w/out credit w/ credit

Operating hours/yr 8,760 Pumps plus valves 1,098 498 996 452

Pumps, valves, and connectors 10,030 9,430 9,099 8,554

$/Mg removed $/ton removed

$/Mg removed $/ton removed

$/Mg removed $/ton removed

Option 1 Emissions J-2
Refinery model

Reconstructed CD Incremental emission reductions

Annual cost, $/yr Mg/yr tons/yr

Pumps plus valves 0.00 0.0

Subpart GGG with valves monitored: Pumps, valves, and connectors 25.50 28.1

Quarterly 1,403,682

Incremental cost increase, $/yr w/out credit w/ credit

Option 1 with valves monitored:

Quarterly 1,403,682 Pumps plus valves 0 0

Pumps, valves, and connectors 569,410 554,108

Option 2 with valves monitored:

Quarterly 1,973,092 Incremental cost effectiveness

w/out credit w/ credit w/out credit w/ credit

Operating hours/yr 8,760 Pumps plus valves N/A N/A N/A N/A

Pumps, valves, and connectors 22,327 21,727 20,254 19,710

Refinery model

Reconstructed MACT Incremental emission reductions

Annual cost, $/yr Mg/yr tons/yr

Pumps plus valves 0.7 0.8

Subpart GGG with valves monitored: Pumps, valves, and connectors 5.76 6.3

Semiannually 307,899

Incremental cost increase, $/yr w/out credit w/ credit

Option 1 with valves monitored:

Semiannually 314,278 Pumps plus valves 6,379 5,952

Pumps, valves, and connectors 118,957 115,502

Option 2 with valves monitored:

Semiannually 426,856 Incremental cost effectiveness

w/out credit w/ credit w/out credit w/ credit

Operating hours/yr 8,760 Pumps plus valves 8,968 8,368 8,136 7,591

Pumps, valves, and connectors 20,658 20,058 18,741 18,196

Refinery model

Reconstructed NSPS Incremental emission reductions

Annual cost, $/yr Mg/yr tons/yr

Pumps plus valves 3.86 4.3

Subpart GGG with valves monitored: Pumps, valves, and connectors 6.66 7.3

Semiannually 140,803

Incremental cost increase, $/yr w/out credit w/ credit

Option 1 with valves monitored:

Semiannually 147,061 Pumps plus valves 6,258 3,940

Pumps, valves, and connectors 68,841 64,843

Option 2 with valves monitored:

Semiannually 209,643 Incremental cost effectiveness

w/out credit w/ credit w/out credit w/ credit

Operating hours/yr 8,760 Pumps plus valves 1,619 1,019 1,469 925

Pumps, valves, and connectors 10,332 9,732 9,373 8,829

$/Mg removed $/ton removed

$/Mg removed $/ton removed

$/Mg removed $/ton removed

Option 1 Emissions J-3