P.1 

OAR Box 1672 

Prepped by Charmelle Mathews 

Document Number: 

ojzf) ll-B-21 

Docket Number: 

A-98-13 

Printed 9/30/2008 11:01:00 AM Sheet 27 of 132 
P.2 

A-iZ-13 

jr-3-21 

Selected material from Memo: 

From: Kenneth R. Meardon 

To: Group IV Polymers and Resins Docket A-92-45 

Date: October 26,1998 

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

and Resins NESHAP 

This item has been placed in the docket for the Organic Liquids Distribution (nonGasoline) NESHAP because it was used as reference material in determining the environmental 

and cost impacts of equipment leak detection and repair programs. 

These analyses are described in Memo No. 6 of the technical support document, which is 

document no. III-B-1 in this docket. 
P.3 

ATTACHMENTS 

"DETERMINATION OF MACT FLOORS FOR EQUIPMENT LEAKS" 

Memorandum. K. Meardon, PES, to Group IV Resins Docket No. A-92-45. 

March 24,1995 

2 
P.4 

/H7 PACIFIC ENVIRONMENTAL SERVICES, INC. 

Central Park West 

5001 South Miami Boulevard 

PO Box 12077 

Research Triangle Park, NC 27709-2077 

(919)941-0333 FAX (919) 941-0234 

MEMORANDUM 

TO: Group TV Resins Docket No. A-9245 

FROM: Ken Meardon 

Pacific Environmental Services, Inc. 

DATE: March 24,1995 

SUBJECT: Determination of MACT Floors for Equipment Leaks 

The purpose of this memo is to describe the methodology used to calculate the 

MACT floors for the source categories covered by the Group IV Resins national 

emission standards for hazardous air pollutants (NESHAP). The same basic 

methodology, as described below, was used for each source category/subcategory. 

Basic Methodology 

The basic methodology consisted of estimating uncontrolled equipment leak 

emissions, identifying the level of control at each faculty based on that facility's specific 

leak and detection repair (LDAR) program (if one was in place), applying the 

"controlled" equipment leak factors to estimate emissions after control, and then 

calculating the percent emission reduction achieved at each facility within each source 

category/subcategory. The information on the percent reduction achieved by the specific 

programs was then used to determine the MACT floors for each source 

category/subcategory. 

Each individual plant was grouped with all other plants on the basis of the type of 

polymer or resin produced. Where a plant produced polymers or resins in more than 

one source category/subcategory, the equipment components were separated, where 

possible, according to the type of polymer or resin. If this was not possible, then all of 

the components were included in each applicable source category/subcategory for 

purposes of determining the MACT floors. 

Estimating Uncontrolled Emissions 

This step required determining (1) the equipment component counts at each plant 

and (2) the emission factors for each component category (e.g., valve in gas service, 

pump in light liquid service). 

WASHMGTON. O.C • RESEARCH TRIANGLE PARK MC • LOS ANGELES. CA • CMCMNATI. OH 
P.5 

A number of facilities provided information on the component counts at a plant. 

Where these counts were provided, they were used directly in the estimation. 

For facilities that did not provide equipment component counts, an estimate had 

to be made for each component type. There are many variables that affect the number 

of components at a facility. Such variables include, but are not limited to, the age of the 

facility, the number of process lines, and the capacity of each line and of the facility. 

Thus, for example, it is generally recognized that the number of Components and thus 

emissions are related to the capacity of a facility. However, sufficient information was 

not available to perform any sophisticated analysis for estimating the number of 

components for those facilities. 

The available information on equipment components was identified and estimates 

of the number of each component was made in terms of component per process line and 

component per design capacity. The results of this analysis showed, that for this industry, 

but unlike for the synthetic organic chemicalindustry (SOCMI), estimating the number of 

components by components-per-capacity was not necessarily unreasonable. The size of 

individual process lines within a subcategory was fairly similar and many of the facilities 

are of the same generation. Therefore, for estimation purposes, it was decided to use 

the information provided on individual facilities within the source category/subcategory, 

calculate an average count for each component type, and then ratio the design capacity 

of the target plant with the average design capacity of the plants that provided actual 

equipment counts. 

To estimate uncontrolled emissions, the emission factors reported in the 1993 

Protocol document1 were used. These factors were used to provide a consistent baseline 

for estimating the impact of various LDAR programs in use in the source categories. 

For the several facilities that provided specific and clear information, the estimates of 

emissions were adjusted to account for low HAP concentrations and reduced hours of 

operation. 

Identifying Level of Controls 

A number of facilities provided information on the control programs being used to 

reduce emissions from equipment leaks. Other facilities simply identified a LDAR 

program, but did not provide any details. Still other facilities did not indicate any control 

programs for equipment leaks. 

For facilities that provided information on the specific programs, these programs 

were used directly. For facilities that indicated that a LDAR program was being used, 

1

 U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards. 

Protocol for Equipment Leak Emission Estimates. EPA-453/R-93-026, June 1993. 
P.6 

but did not provide specifics, the State regulation that appears to be applicable to the 

plant was used to estimate the specifics. In most cases, this resulted in assuming a CTGlike level of control. In one or two instances, a LDAR program was indicated, but no 

State program could be identified. It is assumed that the LDAR program was therefore 

due to plant policy. For facilities that did not indicate any programs for equipment leaks, 

no control was assumed unless the facility was located in a State with a LDAR program 

that was obviously directed toward that plant or type of plant 

Controlled Emission Factors 

The controlled emission factors associated with various LDAR programs used in 

determining the MACT floors are summarized in Table 1. Table 2 shows the percent 

reduction of the controlled emission factors over the uncontrolled emission factors. In 

most instances, the controlled emission factors are based primarily on information found 

in the 1993 Protocol document The footnotes to Table 1 detail the derivation of the 

controlled emission factors. 

Calculation of Emission Reduction and Controlled Emission Rates 

Using the equipment component counts, uncontrolled emission factors, and 

controlled emission factors, the amount of emission reduction achieved by component 

and for the entire plant was calculated for each plant The percent emission reductions 

were then calculated. Table 3 summarizes the estimated percent reductions for each 

facility within each source category/subcategory. 

MACT Floor Determination 

MACT floors were then determined for existing and new facilities within each 

source category/subcategory. For source categories with less than 5 source categories all 

of the facilities were used to estimate the MACT floor. The MACT floor was calculated 

by taking the average of the percent emission reductions achieved by each of the 

facilities. Thus, for example, the four facilities producing ABS using the batch emulsion 

process were estimated to reduce equipment leak emissions by 91.2, 84.1, 82.0, and 79.5 

percent. The average of these four percent reductions is 84.2 percent, which was used to 

represent the MACT floor for existing sources in this subcategory. 

For source categories/subcategories with more than five facilities, the five facilities 

with the highest percent reductions were identified, and the MACT floor was calculated 

as the average percent reduction achieved by these five facilities. For example, the top 

five polystyrene facilities using a continuous process were identified as achieving 85.8, 

81.9, 80.8, 79.6, and 78.6 percent reduction. The average of these five percent reductions 

is 81.3 percent. 
P.7 

For new facilities, the MACT floor was identified as the best performing facility 

within the source category/subcategory based on the estimated percent reduction. For 

example, in the ABS, batch emulsion source category, the Monsanto, Addyston, OH, 

facility was estimated to be reducing equipment leak emissions by 91.2 percent This was 

then selected as the MACT floor for new sources in this subcategory. 

In all cases, the MACT floors estimated for existing and new sources were 

equivalent to or less stringent than the HON. 

£ 
TABLE 1 

SUMMARY OF EMISSION FACTORS (llM/tir) FOR VARIOUS EOUIPMEMT LEAK CONTROL PROGRAMS 

>l 

— ^ > 

| PROGRAM 

j Uncontrolleo* 

| Annual 

| Annual 

Senl annual 

| Quarterly LDAR 

Quarterly LDAR 

Quarterly LDAR 

Quarterly LDAR" 

Quarterly LDAR 

Monthly LDAR 

Monthly LDAR 

Monthly LDAR 

Monthly LDAR 

Mo Detectable 

Eat salons" 

MOM 

Maintain Leas Then— ^ 

ZX Leaker*' 

Maintain less than 

IX leakers4 

Maintain less than 

0.SX leakers' 

Leak 

Definition 

(Pf»> 

— 

10,000 

1,000 

10.000 

10.000 

1,000 

500 

zoo 

100 

10,000 

1,000 

500 

100 

500 

varies 

10,000 

1.000 

10,000 

10,000 

V.G 

0.0131 

0.0087° 

0.0083 

• 

0.0043° 

0.00345" 

0.00323° 

0.003Z3 

0.00165s 

0.0013° 

0.0012° 

0.0010 

0.001° 

0.00201 

0.000336 

0.000718 

EQUIPMENT CATEGORY* 

J 

V.LI 

0.00887 

0.0062° 

0.00395* 

0.0035* 

0.00273* 

0.00257* 

0.00257 

0.00141* 

0.00106* 

0.001* 

0.001 

0.0011° 

0.00232 

0.000379 

0.000853 

V,HL 

0.000506 

• " 

P.LL 

0.0438 

0.034° 

0.0305 

0.024" 

0.0172" 

0.0157* 

0.0157 

0.0135" 

0.011" 

0.011" 

0.011 

0.011° 

0.00942 

0.00225 

0.00676 

P.HL 

0.01896 

' 

./ 

PRVS 

0.2288 

0.1784° 

0.1724 

0.128* 

0.1166" 

0.1152* 

0.1152 

0.007 

0.007 

0.135 

0.1164 

OELs 

0.00374 

• 

Coop* 

0.5016 

0.419° 

0.33661 

0.007 

0.23 

0.213 

Samp. 

Com. 

0.033 

Connectors 

0.00403 

0.00052d 

0.000334d 

0.000392* 

0.000349* 

0.000194*" 

0.000166d 

0.000166 

0.000166 

0.000264°* 

0.000124° 

0.0001** 

0.000286d 

0.002655 

0.00055 

0.00142 
TABLE 1 

SUMMARY OF EMISSION FACTORS (lta/hr) FOR VARIOUS EQUIPMENT LEAK CONTROL PROGRAMS 

OQ 

PROGRAM 

No Evidence of Leaks* 

"Inspect as suspect" 

Closed-vent System 

DNS w/Bsrrler Fluid" 

Rupture Disk** 

Ueld Together" 

Blind, Cap, Plug, 

Second Valve 

Closed-loop 

Sampling" 

Leak 

Definition 

<PP») 

10,000 

* • • 

V,0 

0.00122 

V,LL 

0.00129 

V,KL P.LL 

0.00999 

0.00438" 

0 

EQUIPMENT CATEGORY* 

P,HL 

0.007 

0.001896" 

0 

PRVs 

0.0978 

V 

0 

• 

0ELS 

0.0033 

0 

Coap. 

0.186 

0.05016" 

0 

Sasp. 

Com . 

" 

0 

Connectors 

0.00054 

0.00334' 

0 

• Not Applicable 

TJ 

CO 
P.10 

FOOTNOTES TO TABLE 1 

* V • valves; P • pumps; PRVs • pressure relief valves; OELe » open-ended lines; Coop. • compressors; Samp. Com. 

sampling connections; G * gas service ; LL • light liquid service ; HL • heavy liquid service . 

U.S. Environmental Protection Agency. Protocol for Equipment Leak Emission Estimates. EPA-453/R-93-026. 

1993. page 2-10. (1993 Protocol document). Converted from kg/hr t o Ibs/hr by: kg/hr x 2. 2 • Ibs/hr. 

June 

Estimated be averaging uncontrolled emission factors and emission factors for quarterly LDAR with leak definition of 

10,000 ppm. For example, for valves in gas services (0.0131 • 0.0043)/2 • 0.0087 Ibs/hr. For some components, this 

Is e conservative estimate as annual programs may not be effective in reducing emissions. 

Derivation of emission factors based on taking known values (shown in double-lined boxes in the following tables), 

bounding unknown values, and taking mid-points ss estimates of unknown emission factors. The first table shows 

known and estimated leak frequencies. The second table shows the known and estimated emission factors. These 

values were based upon the 1993 Protocol document data end equations, and apply only to connectors in gas/vapor 

service and to connectors In light liquid service. 

CONNECTOR LEAK FREQUENCIES 

LDAR PERIOD 

Annual 

Quarterly 

Monthly 

Uncontrolled 

500 

I 0.25 

0.125 

0.063 

3.9 

LEAK DEFINITION (ppm) 

1000 

0.213 

0.106 

0.053 

3.78 

10000 

. 0.138 

0.069 

0.0345 

1.55 

Uncontrolled 

I 1.55 

CONNECTOR EMISSION FACTORS (Ibs/hr) 

LDAR PERIOD 

Annual 

Quarterly 

Monthly 

Uncontrolled 

500 

| 0.000286 | 

" - - ' 

0.000166 

0.000102 

LEAK DEFINITION (ppm) 

1000 

0.000334 

0.000194 

0.000124 

10000 

0.00052 

0.000349 

0.000264 

Uncontrolled 

1.55 

Detailed Discussion 

For annual LDAR, the leek frequency end emission factor at 500 ppm are known (0.25X end 0.000286 Ibs/hr). As 

leak definition goes from 500 to 1000, the leak frequency will decrease. Ue also know that the emission factor will 

increase as the leak frequency increases (within the seme LDAR monitoring period). Using this Information, emtssion 

factors for 1,000 and 10,000 ppm were calculated es follows: 

Annual at 1.000 pom. The leak frequency et 1,000 ppm will be less than 0.25X. Using this leak frequency and 

the appropriate equation from page 5-19 of the 1993 Protocol document, we can calculate a "maximum11 emission factor, 

which is calculated to be 0.00017 kg/hr. Next, the emission factor at 1,000 ppm must be greeter than that at 500 

ppm, which we know to be 0.000134 kg/hr. These two emission factors "bound" the estimate for annual LDAR at 1,000 

ppa. The emission factor for 1,000 ppm was then estimated as the mid-point of these two numbers, which Is 0.000152 

kg/hr (* (0.000134 • 0.00017)/2) or 0.000334 Ibs/hr. 

Annual at 10.000 pom. The first step was to estimate the leak frequency at 1,000 ppm. In the previous step, 

we estimated the emission factor at 1,000 ppm to be 0.000134 kg/hr. Using the appropriate equation on page S-19 of 

the 1993 Protocol document, we can "back-calculate" the equivalent leak frequency, which it calculated to be 0.213 

percent. The leak frequency et 10,000 ppm will be less than 0.213 percent. Using this leak frequency In the 

appropriate equation on page 5-19 yields an emission factor of 0.000321 kg/hr. Ue elso know that the emission 

factor will be greater than that at 1,000 ppm, which was estimated to be 0.00015 kg/hr. The emission factor for 

10,000 ppm Is then bounded by these two emtssion factors, 0.000152 and 0.000321 kg/hr. The emission factor for 

10,000 is then taken again as the mid-point between these two estimates (0.000236 kg/hr or 0.00052 Ibs/hr). 

Emission Factors for Quarterly and Monthly LDAR. In the absence of any information, leak frequencies were 

assumed to decrease by 50 percent from annual to quarterly end 50 percent from quarterly to monthly. The resulting 

leak frequencies were then used In the appropriate equations on page 5-19 to estimate emission factors. 
P.11 

FOOTNOTES TO TABLE 1 

(continued) 

* Derivation of emission factors based on taking known values (shown In double-lined boxes' in the following tables), 

bounding unknown values, and taking mid-points as estimates of unknown emission factors. The first table shows 

known and estimated leak frequencies. The second table shows the known and estimated emission factors. These 

values were based upon the 1993 Protocol docunent data and equations. See footnote d for a detailed discussion of 

the methodology used to estimate the unknown values. The leak frequency for annual at 1,000 ppm was baaed on the 

mid-point of uncontrolled end quarterly at 1,000 ppm leak frequencies. 

LDAR PERIOD 

Annual 

Quarterly 

Monthly 

Uncontrolled 

LIGHT LIQUID SERVICE VALVES LEAK FREQUENCIES 

LEAK DEFINITION (ppm) 

500 

2.42 

0.896 

8.5 

1000 

3.3 

2.26 

0.83 

8.3 

10000 

1 u. 1 

1 0.54 | 

4.34 

Uncontrolled 

, 

1 

1 4.34 

LIGHT LIQUID SERVICE VALVES EMISSION FACTORS (Ibs/hr) 

' ' ' " 1 

LDAR PERIOD 

Annual 

Quarterly 

Monthly 

Uncontrolled 

500 

0.00257 

0.00099 

LEAK DEFINITION (ppm) 

1000 

0.00395 

0.00273 

0.00106 

10000 

I 0.0035 | 

I 0.00141 I 

Uncontrolled 

I 0.00887 | 

1 Estimated by averaging the emtssion factors for annual LDAR and monthly LDAR both with leek definition of 10,000 

PP"» 

° Derivation of emission factors based on taking known values (shown in double-lined boxes in the following tables), 

bounding unknown values, and taking mid-points as estimates of unknown emission factors. The first table shows 

known and estimated leak frequencies. The second table shows the known and estimated emission factors. These 

values were based upon the 1993 Protocol document data and equations. See footnote d for e detetled discussion of 

the methodology used to estimate the unknown values. The leak frequency for annual at 1,000 ppm waa based on the' 

mid-point of uncontrolled and quarterly at 1,000 ppm leak frequencies. 

LDAR PERIOD 

Annual 

Quarterly 

Monthly 

HON 

Uncontrolled 

500 

1.00 

13.6 

GAS SERVICE VALVES LEAK FREQUENCIES 

LEAK DEFINITION (ppm) 

1000 

3.095 

1.13 

13.3 

I 

10000 

2.33 | 

0.79 n 

I 

7.48 

Uncontrolled 

I 

| 7.48 

JO 
P.12 

FOOTNOTES TO TABLE 1 

(continued) 

GAS SERVICE VALVES EMISSION FACTORS (Ibs/hr) 

LDAR PERIOD 

Annual 

Quarterly 

Monthly 

HON 

Uncontrolled 

500 

0.00323 

0.00121 

0.00099 | 

LEAK DEFINITION (ppm) 

1000 

0.00345 

0.001298 

10000 

| 0.00429 | 

0.00165 | 

Uncontrolled 

I 0.0131 

" Derivation of emission factors baaed on taking known values (shown tn double-lined boxes In the following tables), 

bounding unknown values, end taking mid-points as estimates of unknown emission factors. The ftrat table shows 

known and estimated leak frequencies. The second table shows the known and estimated emtssion factors. These 

values were based upon the 1993 Protocol docunent data and equations. See footnote d for a detelled discussion of 

the methodology used to estimate the unknown values. The leak frequency for annual at 1,000 ppm was baaed on the 

mid-point of uncontrolled and quarterly at 1,000 ppa leak frequencies. 

LIGHT LIQUID SERVICE PUMPS LEAK FREQUENCIES 

LDAR PERIOD 

Annual 

Quarterly 

Monthly 

HON 

Uncontrolled 

500 

7.2 

4.49 

17.6 

LEAK DEFINITION (ppm) 

1000 

6.5 

| 4.02 jj 

I *.02 1 

17.1 I 

10000 

3.75 | 

1.77 | 

7.48 

Uncontrolled 

1 7.48 

LIGHT LIQUID SERVICE PUMPS EMISSION FACTORS (Ibs/hr) 

LDAR PERIOD 

Annual 

Quarterly 

Monthly 

HON 

Uncontrolled 

500 

0.0157 

0.010 

LEAK DEFINITION (ppm) 

1000 

0.0172 

I 0.011 1 

I 0.011 

10000 

| 0.024 | 

0.0135 | 

Uncontrolled 

, 

1 

' 

I 0.0438 

1 Based on emission reduction of 44 percent from uncontrolled level. U.S. Environmental Protection Agency. Fugitive 

Emission Sources of Organic Compounds — Additional Information on Emissions, Emission Reductions, and Costa. EPA 

450/3-82-010. April 1982. (1982 AID document) p. 4-61. 

I Based on 33 percent reduction, CTQ. 

" Total estimated emission reduction effectiveness of 49 percent. Based on an estimated percent reduction of 44 

percent for e quarterly LDAR program with a leak definition of 10,000 ppm (see footnote d above) plus 5 percent 

based on increased effectiveness of decreasing the leak definition from 10,000 ppm to 1,000. 

1 Assuned to be 1 percent more effective than with leak definition of 1,000 ppm. 

K 
P.13 

FOOTNOTES TO TABLE 1 

(continued) 

" Assumed 200 ppm leak definition had same emission factor es 500 ppa. 

* 1993 Protocol docunent, p. 2-21: 

1.90x10* x (500)*** > 0.00318 kg per hour 

0.007 lbs per hour 

° 1993 Protocol document, p. F-4. The emission factor for pups, light liquid service also appltes to agitators. 

0 Calculated using the following equation: 

(Uncontrolled Emission Rate - Emission Bate at IX) 

Uncontrolled Emission Rate 

Emission rates st 1X were calculated using the equations on p. 5-19 of the 1993 Protocol document. For example, the 

average leak rate (kg/hr) for valves In gas service with a leak definition of 10,000 ppa can be calculated as 

follows: 

Average Leak Rate • (0.0781 x 0.01) • 0.000131 

• 0.000912 kg/hr 

• 0.00201 Ibs/hr 

4 Assume maintain IX leakers means an averege of 0.5X leakere actually occur. Used the leak rates for >10,000 and for 

•00,000 (aee first table in footnote e) to estimate emission factors based on percent leaking and not leaking. For 

example. 

For PRVs: kg/hr - (1.691 x 0.005) • (0.0447 X 0.995) • 0.05293 

Ibs/hr > 0.05293 x 2.2 • 0.1164 

' Assume maintain 0.5X leaker* means an average of 0.25X leakers actually occur. Used the leak rates for >10,000 and 

for <10,000 (see first table In footnote s) to estimate emission factors based on percent leaking and not leaking. 

For example. 

For valves In gas service: kg/hr • (0.0782 x 0.0025) • (0.000131 x 0.9975) • 0.000326 

Ibs/hr > 0.000326 x 2.2 - 0.000718 

* Calculation of Emission Factors for "No Evidence of Leaks" Program; Leak Definition of 10,000 ppa. 

CALCULATION OF PERCENT OF COMPONENTS WITH <10,000 PPM AND >10,000 PPM 

j EQUIPMENT TYPE 

fj Valves, gas service 

H Valves, light liquid 

R service 

1 Valves, heavy liquid 

fl service 

H Pump seals, light liquid 

n service 

n Pump seals, heavy liquid 

service 

Pressure relief valves 

Open ended lines 

Compressor seala 

Connectors 

AVERAGE 

EMISSION 

FACTOR 

(kg/hr)" 

0.00597 

• 0.00403 

0.00023 

0.0199 

0.00862 

0.104 

0.0017 

0.228 

0.00183 

> 10,000 ppm 

Emission Factor 

(kg/hr)° 

0.0782 

0.0892 

0.00023 

0.243 

0.216 

1.691 

0.01195 

1.608 

0.113 

< 10,000 ppa 

Emission Factor 

(kg/hr)" 

0.000131 

0.000165 

0.00023 

0.00187 

0.00210 

0.0447 

0.00150 

0.0894 

0.000081 

PERCENT OF 

COMPONENTS 

>10,000 PPM6 

7.48 

4.341 

NA 

7.48 

3.048 

3.6 

1.91 

9.13 

1.55 

PERCENT OF 

COMPONENTS 

<10,000 PPM* 

92.52 

95.659 

NA 

92.52 

96.952 

96.4 1 

98.09 

90.67 

98.45 

NOTE: Program assumed not applicable to sampling connections. 
P.14 

FOOTNOTES TO TABLE 1 

(concluded) 

Footnotes to first table In footnote si 

* 1993 Protocol document, p. 2-10. 

b 1993 Protocol document, p. 2-16. 

° Calculated based on average emission factor and the > 10,000 end <10,000 ppa emission factors. For 

example, solving for valves fn gas service as follows: 

0.00597 kg/hr • 0.0782 (X) • 0.000131 <Y> 

1.00 • X • T 

where: X • percent of components with >10,000 ppa 

Y • percent of components with <10,000 ppm 

CALCULATION OF NO EVIDENCE OF LEAKS (10,000 PPM LEAK DEFINITION) EMISSION FACTORS 

1 EQUIPMENT TYPE 

1 

II Valves, gaa service 

n Valves, light liquid service 

H Valves, heavy liquid service 

| Pumps, light liquid service 

1 Pumps, heavy liquid service 

| Pressure relie f valve* 

1 Open-ended lines' 

1 Compressor seala 

H Connectora 

EMISSION 

FACTOR (kg/hr) 

at 10,000 ppa* 

0.005806 

0.0098823 

0.00023° 

0.03756 

0.03756 

0.03756 

0.0015° 

0.03756 

0.01058 

PERCENT 

<10,000 

PPM 

92.52 

95.659 

NA 

92.52 

96.952 

96.4 

98.09 

90.87 

98.45 

PROGRAM EMISSION FACTOR 

kg/hr 

0.000555 

.000587 

0.00023 

0.004539 

0.00318 

0.0444 

0.00147 

0.0845 

0.000244 

Ibs/hr 

0.00122 

0.00129 

0.000506 

0.00999 

0.007 

0.0977 

0.00324 

0.186 

0.00054 

* Calculated using correlation equations found on page 2-21 of the 1993 Protocol document. 

0 Based on average emission factor for source. 

° Assumed same as <10,000 ppa emission factor. 

Sample calculation: 

Valves, gas service: 0.000555 kg/hr > (0.005806 x 0.0748) • (0.000131 x 0.9252) 

1

 Assuned to be midway in effectiveness between "uncontrolled" and "maintain less than 2X leakers (10,000 ppa)." 

" Based on 90 percent control efficiency. 1993 Protocol document, p.5-2. Actual efficiency of a closed-vent system 

depends on percentage of vapora collected and efficiency of control device to which the vapors are routed. 

* Control efficiency of closed-vent system installed on e pressure relief device may be lower than other closed-vent 

systems, because they must be designed to handle both potentially large and small volume of vapor. 1993 Protocol 

docunent, p. 5*2. 

" Based on 100 percent control efficiency. 1993 Protocol document, P. 5-2. 

/3 
TABLE 2 

SUMMARY OF PERCENT REDUCTION BY COMPONENT FOR VARIOUS EQUIPMENT LEAK CONTROL PROGRAMS* 

PROGRAM 

Uncontrolled 

Annual 

Annual 

Semiannual 

Quarterly LDAR 

Quarterly LDAR 

Quarterly LDAR 

Quarterly LDAR 

Quarterly LOAR 

Monthly LDAR 

Monthly LDAR 

Monthly LDAR 

Monthly LDAR 

No Detectable 

Emissions 

HON 

Msintaln Less Than 

2X Leakers 

Maintain less than 

IX leakers 

Maintain less than 

0.5X leakers 

1 No Evidence of Leaks 

Leak 

Definition 

• • . 

10.000 

1,000 

10.000 

10,000 

1.000 

500 

200 

100 

10.000 

1,000 

500 

100 

500 

varies 

10.000 

1.000 

10,000 

10,000 

10,000 

V,8 

33.6 

36.6 

67.2 

73.7 

75.3 

75.3 

87.4 

90.1 

90.8 

92.4 

92.4 

84.7 

97.4 

94.5 

90.7 

V.LL 

30.1 

55.5 

60.5 

69.2 

71.0 

71.0 

84.1 

88.0 

88.7 

88.7 

87.6 

73.8 

95.7 

90.4 

85.5 

V,HL Ml 

22.4 

30.4 

45.2 

60.7 

64.2 

64.2 

69.2 

74.9 

77.2 

77.2 

• 

74.9 

78.5 

94.9 

84.6 

77.2 

EQUIPMENT CATEGORY" 

P,HL 

63.1 

PRVs 

22.0 

24.7 

44.1 

49.0 

49.7 

49.7 

96.9 

96.9 

41.0 

49.1 

57.3 

OELs 

11.8 

Coop. 

16.5 

32.9 

98.6 

54.1 

57.5 

62.9 

Samp. 

Com. 

Connectors 

87.1 

91.7 

90.3 

91.3 

95.2 

95.9 

95.9 

95.9 

93.4 

96.9 

97.5 

92.9 

34.1 

86.4 

64.8 

86.6 1 
<*. 

TABLE 2 

SUMMARY OF PERCENT REDUCTION BY COMPONENT FOR VARIOUS EQUIPMENT LEAK CONTROL PROGRAMS* 

PROGRAM 

"Inspect es suspect" 

Closed-vent System 

DMS w/Borrter Fluid 

Rupture Disk 

weld Together 

Blind, Cap, Plug, 

Second Valve 

Closed-loop Sampling 

leak 

Definition 

«PP»> 

.. 

.. 

.. 

.. 

— 

--

V,G V.LL 

* 

V.BL P.U 

90.0 

100 

EQUIPMENT CATEGORY0 

P,HL 

90.0 

100 

PRVa 

100 

OEU 

100 

Coop. 

90.0 

100 

Samp. 

Conn. 

100 I 

Connectors 

17.1 

100 

1 

* Calculated using the controlled emission factors and the uncontrolled emission factors reported in Table 1. 

" v • valves; P • pumps; PRVa » pressure relief valves; OELs • open-ended lines; Coap. • compressors; Saap.Com. • sampling connections; 6 • gas service; LL 

light liquid service; HL • heavy liquid service. 

at 
. 

1 

.1 

1 

1 

1 

1 

" 1 

1 

H 

? 

,? 

2 

2 

2 

2 

,* 

,2 

2 

.31 

*S 

> 

3. 

J. 

3. 

,31 

3 

31 

31 

«< 

4 

4' 

4: 

1* 

r? 

n

1 

ty i4! 

i«« 

=f 

?> 

53 

/S4 

f 

w 57 

ss 

*» 60 

M 

i l 

n •A 

as 

1 . 

2 Fwlllty 

> . . . . . 

<_BASF. , 

5, Lo*sn0 . 

' 

1 .. . 

1 

9 

1 

* 3 

4 

S , 

S . 

7 

S . 

• 

) 

1. . . . 

2 

3 

4 

*. . 

1 .. . 

7 

» "*•"!«. 

» ftv 

a _r i 

t . . . < 

2 No. of Monitoring Days .' 

1 NUflUlOl Of SUbCataQOflaP .. 

; PreportmofGas/Vagor 

s andUtflUoMCofiv. 

> ,. 

r Pitjpoftqngf Hsav* 

' UQM OOffaPWMnta' 

» 

> 

. 

! 

> 

. 

S . 

. 

, 

. 

. 

. 

"T 

Proc..* 

U 

1 

1 

J_ 

JM», 

c 

Typs) of Cofflporanl 

. . . 

. 

. PumpS.il. .. . . . . -

•UoftUauldsavlca. ., . 

*HeawtaMnrvkM .... . • - . . — . . 

Vslvss . ... -

rUoJiMouldsantct. .. . . . ... — • 

*Hsaw4aiMssfVlca . ... .. . - .. 

Connactora . .. A . . 

* Flames •aasAnDcr _ . . 

•.Ranges-lojitlquld .. .. . .. . 

Pf*«.ura Rallsf Dsvlcos . . . . 

•as** - ...... 

•DlsKlwMeri.vrtMW.ote. -- . „, 

Opaivsndad Vatvas . , 

A Sampling Connactfona .... . 

c Compressor Vant 

Raplacamont Pump Ssate . 

Monitoring Davies * Buy 

MonHorlng.Dsvlcs - Rarrt . . 

Data Collodion Ovstsra 

Hoavy LtauM Comoonant 

TrfpQhargas .. 

Admlnstratlve and R.ports . . 

. . . . . Track Maavyllqulda 

Planning and Training . 

Haavy Liquid Training 

HMvvUQuMTaat 

TOTALS . 

Caettsl Costs . _ 

1 1

 0 ' 

Nuifbte* flt* Contpoiwnli 

_ ^ . . • . ^ 

.. 

8 m. ^ 

135 . . .... . . . . 

160 . ..._..... . 

471 . .. . 

31S4\6. . . 

4 j 

39 . . . 

9 • _ ...... . 

. . . 0 ...... . . . 

••OS .. . 

. 

0 ...... . . 

1 . 

•1*B35 

«1*B38 

•12*B35 

' 

•300-B35. . . . . 

••638*0.5 

•340*B3S .. 

•20*036 . 

•»SUWF20^48VF2W:414G46 

. 

Am-MCanria j Costs -«4F2»^«f23»f284f27mi4TMrai'M1>W^ ^ 

. . . Atia-alBcaareat 

, 

. 

RecovaryCrsats 

• . . 

Ntt Annual Coals . 

Emissions .. _^^^_ a t 

. RaAfClonfJfkjgfr}. .. 

1 OoMEHMftaMnfSJMa) 

•J4S«K4ei04eiW4e»X4S*Y4a 

AnualFtodOqs»f(S>V-l 

A m * Vttar* Costs rtArl 

2685.86 

. . 

WO5HO04-D86 . .. . 

. 

ESS 

, 

e 

H M Morflortrsj Faa or UnTt 

Cost (Stamp) 

_ 

1.13 *. .. .. . 

_ 

4.65 

4.65 .. . 

1.13 

4.68 .. . 

4.69 

1.13 

78 

3852 

102 

409 ., .. . 

6242 

180 

6500 

116.25 

14S0O 

136. 

1000 

36.95 

36.95 

36.98 

36J8 

1 

. 

. 

. 

•D51+X46tY4e 

•OS4JU8-Y48 

MoaoDta 1 
P 

H M LOAR Costs (Vf) (Ctpjt-I) 

1 

2 

3 

4 

» 

6 «ffD6-E6H*tenP6/1MH36*R61 

7 «rojrT7iHi7TRnoororRn 

8 

9 

io •(((Dio*EtDVMNionpio/iooraio-RioHMioTrio>ioo)-uiovio) 

n •«(Oii*EiiHMii-iPii/ioorQii*Riiw«ti,nii/iooiniii,vm 

12 •f«Di«i2>Mirrfpi2rtooroi»i2>4»,i2TTi2riooruirvia 

13 

14 

15 »mD15*E1SHM18*IP15r100rQ15,,R15H*IJ5TT15/1()0»*U15*V15) 

IB M((O16*E16H*(16TP16*l00rQie-Rl6Wl(lie*(T16*l00ru16-V16) 

17 •f(roi7^17WI17TM7n00rO17^17W«17TT17n00TUirV171 

18 

IS 

20 «D20*E20 

21 .D21-E21 

22 

23 •D23*E23 

24 

23 •D29*C29 

28 

27 •D27*E27 

28 

29 •4MTE29 

30 

31 •D31131 

,32 

«33 •033*E33 

•34 «4034*E34 

3S " 

36 —- ~ 

17

 *^L 1 38 ^ 

39 

40 •4O4rrE40 

41 

42 

43 

44 

48 

46 -«UM(F«F48) 

47 

48 

49 

SO 

81 

52 

53 

54 

55 

58 

57 

58 

59 

80 

81 

62 

61 

84 

66 

O 

HialLDAR 

Ada*. Costs 

•403S-E39 

•SUM(G*UMS) 

H 

Frsrsjancyof MuiluiInQ 

(stass**) 

•2 

4 „ , ,„ 

« . . .. 

1 .. . .... . r 

1 

.. ^^ 

1 . 

1 .... ,. ... 

.. 

12 _ ^ 

1 

aubsaquaraMortk-rtngPaa 

(tfcem?) or Cnsrga (%) 

, 

U 

. 

2J5 

Z 8 . 

ZS 

2 4 

-

2 . ... 

8 ...,-. . 

8 

8 

8. ... .„ 

. 

c 

. 

. 

. 

J 

Amuaj Horttortng Costs (SAO 

-^D6T«3T6>HD6-6rrOA60rR61 

«fD10"H10110» 

•fDi1*H11111) 

. 

-4D16-H151161 

-4D16*H16nim 

•O20*H20*l20 . . 

. . . 

»+e32"E32 

MD35T35 

. 

•sumJtMm . 

. 

I I . _ 

K 

t^KWavam amajWWaWWntm \MMM 

•406*180 

-D20-E20TI21/100) 

'D21*E21TI2V100) 

•D23*E23*(123/100) 

«O28-E281t28r100) 

•OZ7-E27f|Z7/100) 

•+O31M2S0 

. 

•4042*E42 

•SUMflOMOS) 

. 

" 

L 

kMallaak 

Frerjwieyni) 

17.1 

13.6 

BJS 

3.8 

M 

. 

M 

MssJ NisnTMr of 

Laafca 

•OffUS/IOOl 

•OK-aioriotn 

•oi: iLii/iom 

•O18TL16/100) 

•016*0.161100) 

N 

Subsa^isnt Lask 

Fraquaney(«) 

8.04 

0.28 

2 

2 

028 

0.5 

0.8 

0.28 

TJ 

CO 
0 

Ansa* rUttiar of Lasts 

1 

2 

3. 

4 . 

8 . . 

.8. 'OKtmnaorm 

_7. »D7*(N7f100» . 

, 8 . 

.» 

io "Oio*mio/ioomu> 

11 •omNii/iooi-Hn 

12 «D12*(N12*I001 

13 

14 • -

15 'D.16*fN15/1O01-HU 

.18 •O16TN1671O0VH16 

17 •O1TTN17/1001 

18 . . • 

19 . 

20 . •• ' 

21. 

22 

23 

,24 

25 

28 

27 

21 , 

29 ~^ . 

.30 ry% 

31 . " * 

i

M 

X 

34 , 

35 . . 

38 

37, 

38 

39 

40 

41 ,. ._ , . . 

42 -40740124017 

43 

44 

45 

48 

47 

48. 

49 

50 , 

81 

82 

S3. . 

84 

58 

58 

57 , 

58 

80 . . 

.61 

a 

£ a i , . 

as . 

p 

Partar* RspakM 

OnUna 

100 

78 

75 

75 . 

75 

, 

a 

Raps* Tims 

(hows) 

16 

0.167 

0.167. 

. . 

0.167 

0.167 

R 

Lobar Cnsrja 

224 

22.8 

224 

224 

224 

, 

,. 

6 

Annual OnUns Lsak RapaaCoat(Sr|t) 

•SO6*lP6r100rO6*R6 

, 

«soio*(Pio/ioo)*Qion-io 

«S0111P11/10BK>11*R11 

•SO15*rP15rt00l*O16*R18 

-JO16*(P16rt00)*Q16*R16 

. •SUM(S8:S4S) 

T 

PfffOHst RaMfsBTaTaJ 

nstiarRapar 

•100*6 

•100rP10 

•100*11 

•.100-P16 

•100->16 

. 

u 

RspsJrTkna 

(hours) 

80 

4 

4 

2 

2 

am* 

V 

Labor Chargi 

(S»t1 

224 

224 

224 

224 

224 

, 

actrvreaM* 

w 

Amusl OMna Lsak RapskCost(*Ar) 

•SO6*rT6/100rU6*V6 

•joio-aioriooruiovto 

•soiiTTii/iooruiivii 

. 

•SO«*ai8r100rU16V« 

•SO16TT16/100nJ16V16 

. 

•SUM(W6.VV45) 

. 

X 

Amusl Admh. Ccst(*y) 

,. 

. 

. 

. 

. 

••037*637 

•4038*E38*H38 

. . ... •SUM(X6X45) 

. 

Y 

Amusl Mse. Cnsrgss (*Ar) 

•4K6-04 

. 

. . . 

•D20*E20*0.04 

•D21*E21*0.04 . . 

•D23*E23*0.04 

>D25*E28*044 . . . 

, •027*E27*044 

•D31f31*0.04 

•300-D33-385.4/3e«.7 

•D33*E33*0.04 

•SUVKY6.-Y45) 
r 

.1 

2 

3 

4 

8 

8 

i i 

•8 

g 

10 

.11 

IT 

JJ 

14 

JI 

18 

JL 

18 

19 

20 

21 

n 23 

iM 

25 

1» 

27 

28 

29 

30 

31 

32 

33 

34 

35 

38 

37 

38 

39 

40 

41 

42 

43 

44 

45 

48 

4| 

48 

49 

f> 5

1 

M 

s. 

54 

SS 

"6 

57 

ft 

89 

-0 

*1 

62 

86 

A 

Facility 

I d 

HOJMWeal 

H ON nOiafevn 

NlffRtMTOf 

5U>C«aa*flfJrtatl 

Proportion of GMArtpor 

•nd Uflht UQaatd Cottp. 

Piuouffonof IfMv y 

UOJlM GOfeVOslaWsQl 

^ — 

—ft 

-

8 

PlDCatMl 

DMT-B 

1 

f 

1 

c 

Typo of Componant 

Pump Saals 

•UgM-aidsarvkw 

•Hsavy-oMsarvtea 

Valvaa 

• Gastapor servlca 

•UohMoJd sanies 

•HeawJouM service 

Connactora 

* Flanges - gasAnper 

• Flanges -IghtloUd 

• Flanoes -heavy taid 

Praaaure RaHaf Oavlcaa 

•asks 

• Disk holders. vsNeajt-. 

OpotMndsd Vslvse 

Sampling Connactlona 

Compraasor Vant 

Raplacamant Pump 8aala 

Monitoring Davlea .Buy 

Monitoring Davlea • Rant 

Data Coflactton Syatam 

Heavy Liquid Component 

Admlnatiatlva and Rapoita 

Track Heavy UquMa 

Planning and Training 

H.avyUquld Training 

Data Entry -Initial 

Heavy Liquid, Taga 

Data Entry - Subaaqusnt 

TOTALS 

CsoM Costs 

Anruelzed CaoM Costs 

Recovery CreoTts 

NstAirusJ Costs 

Brtatons 

RedBlto (Motel 

D 

NsjitMr of Ocnfumtrttt 

3 

« 

59 

70 

388 

208.1 ., 

13724 

2 

2 

17 . 

4 . • • .. . 

. 0 

•406 

0 

1 

•1*B33 

•1*B38 

•60*835 

•.638*04 

•170*638 

•20*B38 

-(•064010*01140164018) 

•0364010401140184016) 

•SUM(F2aF45M:28-F4H048 

. •ff4R04FW4F234f2S*F27mi4Z>«ro*(W1 WITO*^ ^ 

Anrust Fhed Costs fSNrt 

Anus) VartatSs Costs (SMI 

1277/48 

••06140544W 

1041 

•4060062 

e 

imitators * FaoarUrtt 

CosttSltanp) 

3.75 

1.13 

0.75 

0.78 

1.13 

0.75 

0.78 

1.13 

78 

3862 

102 

409 

6242 

180 

6500 

1200 

138 

38.93 

36.95 

3648 

3648 

148 

1 . 

0.75 

•0S14X464Y46 

.. 1 

TJ 

ho 
p 

H M LDAR Coals (SM) (CspM) 

1 

2 

3 

• * 

5 ... . 

. 6 -i(DrE6>»*l61P8fl00)-Q6*R6) ..... . 

7 -((D7^7W«TIP7/100«J71-7I ..... . 

8 

9 

10 •(«Dio-Eiowi«ibnp^onooi-Qio^io)tMio*rTi(vioo)-uio-vio) 

n •(i(Dii-EiiwniiiPi.i/i(xrt-Qii-RiiH*iiiTrii/iooruii-viii 

« -(«O12^1214«l12-r*>12rt0nroi2-R12>4M12-(T12f100rU12-Via 

« 14

 -

18 •l«O16*615)4»Jl5fP15Yt00l*Q15-R15HM15"lT1»10Ol-m5'V.15l 

.18 '(UD16^16>tM16W16^DOrai6^16)4M16*rri6f100ni1ffVim 

17 -(((Oi7^i7>»4iirrpi7/i«nroiTMi7i«*ii7rrTi77iooruirvi7> 

18 

19 , ! . 

zS. *i*arc « 

21 -DZ1131 

22 . 

.23 -023-E23 

24 . . : . 

28 •D2S'E25 

• » - -

27 "D27-E27 

2» 

29 •4M6*E2B 

30 ... . ... v 

31 «03.1*E31 . 

"33 -D33-E3J V * 

J4 •4034*E34 I V 

38 r*j . 

se . . y • 

37 . 

38 

40 •4O4Q*E40 

41 .+D41-E41 

42 

.43 

44 , 

45 ...... . ... 

48 •SUM(Fef4S). 

47. . . . 

48 , 

49 . 

SO . . 

61 .. . , 

82 

54 

65 

sr . . . . 

58 

.89. . 

.60 . 

St 

.82 . 

64 

65 

a 

HMLOAR 

Adn*v Costs 

1 

• 

. 

•403S-E39 

', 

•SUM(Gft04B) 

. 

. 

H 

Frecjuancyof 

MonSorthg 

(OnssM) 

12 . 

4 

4 . 

1 

1 

. . . 

1 

i 

12 

, 

. 

1 

SiiMaquanl 

MorOorks* Faa 

(Stamp) or Cnargs 

W 

3.78 

0.78 

0.78 

0.78 

0.78 

• • 

S 

8 

8 

8 

, 

. 

, 

J 

Annual Morfortng Coats (SM) 

«<D6*r«Te><D6*82-(04«))-Re) 

«CD10*H10*I10) 

•foii-Minii i 

»(D15*H15-I16) 

«fD16*H161im 

•annmnm 

j 

•40614P61 

•+D43-E43 

•SUMM6J46) 

, 

". '*... .,,. 

AataUal MtaTamVaatfaOa) 

Costs (SM ) 

•406*180 

•021*121*021/100) 

a.O23*E23*(l23r*10O2H 

* 

•D26*E2S*02SrtOO) 

•D27*E27*O27/10O) 

A ^ 

•4031*4280 

^ 

•4042-E42 

•8U^I0KK48] , 

L . 

M M Leak 

RelQJLaWnTy 

<%) 

17.1 , 

13.6 

84 

34 

3 4 

• 

MorOortno Ina 

. 

Jo. of Days 

n Rental 

M 

MMNURtlSTOf 

Laata 

•O6U6/100) 

•D10TL10/100) 

•011*0.11/100) 

•016U1VI001 

•016*0.167100) 

• 

" ' • 

io. or 

dental. 

PanotJ ParlodsM 

. 

1 

I 

2 

3 

! 

« 

, 

11 

I. 

CovaTttolSSSS: 

N 

Sutieaqusnl 

LsakFrstMnc) 

8.04 

039 _ 

2 

2 

028 

04 

0 4 

035. . 

. 

~ostoar 

Jental 

>erlod 

•180*SN$82 

•190-N62 

-245-N62 

•406*1462 

•6301462 

. . 

•388.4/389.2 

I • 

O 

Amial Number of Leaks 

-O61N6/100»*H6 

•07*iN77100) 

•D10"fN10/100)-H10 

•DinNu/ioormi 

•D12W12M00) . . 

«bl5tNJ5/1001*H18 

»D16*fN16fl00l"H16. 

•O17TN17/1001.. 

iL 

. 

. 

. 

•4O740124O17 

-

ientar Costs 

MM56-N56 

•4M57*N57 

•4M5B-N58 

•4M59*N59 

•4M60-N60. . 

-SUI«O9KO60) 

.. 

P 

Percars Rapakad OnUna 

100 

78 

78 

78 

78 

• 

" 

.-

Sally 

CaUralon 

Costs 

.41.25*355.4/358.7 

•+L56*M56*SP-55 

•4L57*M57*SP855 

•4L58*M58*SPS55 

ML59-M59*$P»88 

•4f40*M60**PS66 

.SUM1P66TP60) 

. 

•o 

ho 
a 

Rapes-Tens 

(nous) 

2 

3 

* 5 . 

8 16 

7 

-a 

9 

10 0.167 

11 0.167 

12 

« 14 . 

18 0.167 

16 0.167 

17 

IB 

19 

20 

21 

22 

23 

24 

28 

2S 

27 

28 

29 

30 

S1

 V> 

32 N 

'33 

J4 

39 

38 

37 

38 

39 

40 

41 

42 

43 

44 

45 

46 

47 

48 

49 

50 

91 

82 

S3 

84 

55 

58 

57 

88 

89 . 

80 

61 

82 

S3 

64 

86 

R 

Labor Charge 

<*H) 

.. 

224 

224 

224 

224 

224 

* 

8 

AmueJ OnUns Leak RapesCost (SM) 

-SO6*(P67100rO6-R6 

-sowtpio/iooraio-Rio 

•SO11*(P11r100y-O11*R11 

•sois*iPi»ioorais*RiB 

•$O16*-Pl6*l00rQ18*R16 

»SUM(S&S44) 

T 

Par-art Requiring 

FurtarRapalr 

•10OP6 

• 10OP10 

•10tH>11 

•1Ck%P18 

•1004>1B 

U 

Repair Ttae 

(hows) 

60 

4 

4 

2 

2 

v 

Labor Charge 

(**-) 

224 

224 

224 

224 

224 

W 

Amusl OfBJne Leak Rape* 

Csst(-M) 

•soerrerioorue'VB 

•soioTrionooruKrvio 

•soii*mi/iooruii*vi i 

•SO1STT1-r100)-U1S*V16 

-SO1OT16fl00rU16*V16 

' 

•suucNemsi 

, 

X 

Annual AOnti Cost (SM) 

. 

•4037*637 

•4038*E38*H38 

•SUMOuUUS) 

V 

Annual Us e Chargss (SM) 

•4+03*04 

•D20*E20*0.04 

•D21*E21*044 

•D23*E23*044 

•O2S*E26*044 

. •O27*E27*044 

•D31*E31-044 

•300-355.4056,7 

«O33*£33*044 

•«UM(YKY48) 
P.23 

MEMORANDUM 

FROM: Ken Meardon 

DATE: September 23,1998 

SUBJECT: Summary Tables for Costs for PET Equipment Leak Program 

The majority of the costing conducted for this project was based on the costing 

algorithms used in the HON equipment leak costing program. The primary memo used from the 

HON equipment leak costing is attached to the end of this memo. 

Many changes have been made, however, to the HON equipment leak costing procedures 

in two main areas — components subject to Method 21 monitoring and components that are in 

heavy liquid service. Table 1 presents the main components of the costing used for components 

that are subject to Method 21 monitoring. Table 2 presents a more detailed breakdown of the 

derivation of initial and subsequent monitoring costs. 

Table 3 presents the costing elements used for components in heavy liquid service. 

Additional information on the costing conducted for the PET equipment leak program can 

be found in the "Summary of Responses to Petitioners' Comments" memo, Docket Item VI-B19, docket A-92-45. 

22 
P.24 

TABLE 1. SUMMARY OF LDAR COST COMPONENTS AND VALUES 

Cost Component 

In-house LDAR 

Program 

Locate and Log 

Subcontractor LDAR 

Program 

Locate and Tag 

Monitoring Cost Fees — Initial/Subsequent ($/component) 

Valves 

Pumps 

Connectors 

' 0.75/0.75 

3.75/3.75 

0.75/0.75 

4.65/2.50 

4.65/2.50 

4.65/2.50 

Monitoring Instrument (Select the least expensive option) 

Purchase 

Rental 

Maintenance 

Daily calibration 

Calibration gases 

1@ $6,500 

This will be a variable rate as follows: 

Each 1 day rental: $180 (including shipping) 

Each 2 day rental: $190 (including shipping) 

Each 3 day rental: $245 (including shipping) 

Each 4 day rental: $300 (including shipping) 

Each 5 day rental: $355 (including shipping) 

Each 6 or 7 day rental: $405 (including 

shipping) 

Rental - none 

Purchase - 4,280/year 

Rental: $41.25/day 

Purchase • none 

Rental: $300/yr 

Purchase - none 

1 

References/Comments 

InHouse Program: Petroleum Refinery 

Equipment Leak CTG. See Table 2. 

Subcontractor Program: From the 

petitioners' estimate, Docket Item VI-B13, Attachment F. 

Reference: 2/28/92 HON memo. 

Adjusted to July 1989 $; references 

telecon of 10/26/90 between DJ. Whht, 

Radian, and J. Johnson, Foxboro 

Equipment Company. Purchase one 

instrument as a backup to the 

contractor's instrument and would be 

used to verify that components identified 

as requiring repair by the contractor 

have been repaired. 

Basis: Rental rates from IntekSouth's 

website (attached) for OVA-108 or 

OVA-128. Shipping charges: two day 

delivery - $30; one overnight return • 

$50. Total $80 each rental period for 

shipping. 

Rental: assumed not incurred because 

rental 

Purchase: 2/28/92 HON memo. 

Updated SOCMI AID using CE Plant 1 

Cost Index ratio. 

Rental: Petroleum Refinery MACT (A93-48, n-B-27) 

Purchase: included in maintenance cost 

above (SOCMI AID, pp. 5-35 and 5-36) 

Rental: Petroleum Refinery MACT (A93-48, II-B-27) 

Purchase: included in maintenance cost 

above (SOCMI AID, pp. 5-35 and 5-36) 

23 
P.25 

TABLE 1. SUMMARY OF LDAR COST COMPONENTS AND VALUES 

(continued) 

Cost Component 

Trips 

In-house LDAR 

Program 

Locate and Log 

None. 

Subcontractor LDAR 

Program 

Locate and Tag 

$l,000/trip 

References/Comments 

InHouse program: not applicable 

Subcontractor program: From 

petitioners' estimate, VI-A-2, Exhibit A, 

p.6. 

Administrative/Reporting/Recordkeeping1 

Initial Planning and 

Training (hours) 

Annual 

Administrative and 

Reporting (hours) 

Database System 

60 

170 

$0 

340 

300 

$14,500 

InHouse: Estimated. 

Subcontractor From petitioners' 

estimate, VI-A-2, Exhibit A, pp. 5 and 6. 

InHouse: Estimated. 

Subcontractor From petitioners' 

estimate, VI-A-2, Exhibit A, pp. 5 and 6. 

Data Acquisition and Recordkeeping ($/component) 

Initial Master 

Database Acquisition 

Subsequent 

Recordkeeping 

1.88 

0.75 

none 

none 

InHouse: Harris memo (A-93-48, II-D343), which states that this includes 

determining and recording process unit, 

component service, stream name/ID, and 

location information and includes 

determination of values, field data 

logging, and keypunching into the 

database. 

Subcontractor Assumed included in 

monitoring fee (VI-B-13, Attachment F). 

InHouse: Harris memo. Covers 

subsequent routine recordkeeping. 

1 Subcontractor Assumed included in 

J monitoring fee (VI-B-13, Attachment F). 

1

 For the reasons stated in the ''Summary of Responses to Petitioners' Comments" 

memo, these costs replace in their entirety the previously used estimate of 40% of total costs. 

The revised costing procedures do not use the 40% factor. 

W 
P.26 

TABLE 1. SUMMARY OF LDAR COST COMPONENTS AND VALUES 

(continued) 

Cost Component 

Labor Costs ($/hr) 

Monitoring 

Admi/Record/Report 

In-house LDAR 

Program 

Locate and Log 

Subcontractor LDAR 

Program 

Locate and Tag 

22.50 

36.95 

References/Comments 

Monitoring: 2/28/92 HON memo. 

Admi/Record/Reporting: Derived from 

Part A of the Supporting Statement, 

where the labor costs for the reporting 

and recordkeeping reported vary 

depending on the type of labor — 

technical at $33/hr, clerical at $15/hr, 

and administrative at $49/hr. In 

addition, clerical labor is estimated at 

10% of the technical labor and 

administrative labor at 5% of the 

technical labor. This results in a 

weighted cost of $36.95 per technical 

hour. 

AS 
P.27 

TABLE 2. INITIAL AND SUBSEQUENT MONITORING 

($/component) 

COMPONENT/ITEM 

Valves 

Pumps 

Flanges 

Locate and Tag 

Locate and Log 

First Attempt at Repair (valves 

only) 

Remonitor after Repair 

Valves 

Pumps 

Flanges 

IN-HOUSE 

PROGRAM 

$0.75 

$3.75 

$0.75 

$2.15 

$0.50 

$3.75 

$0.75 

$3.75 

$0.75 

SUBCONTRACTOR 

PROGRAM 

$2.50 

$2.50 

$2.50 

$2.15 

$0.50 

$3.75 

$2.50 

$2.50 

$2.50 

See NOTE 

1,2 

U 

U 

3 

3 

4 

5 

5 

» 

NOTE 1. In-house monitoring costs are based on the following requirements: 2 minutes/valve; 10 minutes/pump; 20 

minutes/compressor, 16 minutes per pressure relief devices. Flanges were assumed the same as for valves. Labor 

cost of $22.50/hr used to convert these times to $/component The monitoring times are from the Petroleum 

Refinery Equipment Leak CTG. 

NOTE 2. The subcontractor monitoring costs are based on the petitioners' Attachment F quotation (VI-B-13). The 

HON also used $2.50/component 

NOTE 3. The costs for locating and either tagging or logging were taken from the petitioners' Attachment F (VI-B13) 

NOTE 4. The cost for first attempt at repair is based on 10 minutes per leaking component and $22.50/hr labor rate. 

The 10 minutes per leaking component figure is taken from the Petroleum Refinery CTG and was also reported in 

the petitioners* Attachment F (VI-B-13). 

NOTE 5. The cost for remonitonng after repair to ensure the component is no longer leaking. The in-house costs are 

assumed to be the same as for the initial monitoring. For the subcontractor program, die costs shown are those 

reported in the petitioners' Attachment F (VI-B-13). 

2£ 
P.28 

TABLE 3. SUMMARY OF HEAVY LIQUID COMPONENT COSTS 

Cost Item 

Identify equipment in 

heavy liquid service 

Tag leaking 

components 

Set up file to keep tags 

Train staff 

Maintain records 

Cost 

$1.13/heavy liquid 

component 

$1.00/tag 

$136 

$739 

$222/year 

Reference/Comment 

Petitioners' comments (VI-A-2, 

Exhibit A, p. 7). 

Based on petitioners estimate (VI-B13, Attachment F) including 

estimate of 0.25% of heavy liquid 

components leaking per year (Vl-A2, Exhibit A, p. 8). 

Estimate based on the purchase of 

one 4-drawer file cabinet (= $125 

from office supply catalogue) and 

30 minutes (at $22.50 per hour) for 

moving furniture around. 

Estimate based on training 10 

people, 2 hours per person, $36.95 

per hour. 

Estimated based on 0.5 hours per 

month, 12 months per year, and 

$36.95 per hour. 

* 7 
P.29 

A-93-48 

ll-D-343 

MEMORANDUM 

• TO: R. V. Oommen 

FROM: G. E. Harris 

DATE: 9-15-93 

SUBJECT: Equipment Leaks Inspection and Maintenance Startup Costs 

In a true startup situation (one where no previous I&M was being conducted on the 

subject components), the startup costs would include: 

• permanent tagging, 

• acquisition of screening instruments, 

additional data logging, and 

• i data processing/software costs. 

These are costs above and beyond the normal cost of a regular follow-up inspection. 

fjjjjffSIHPft-^ be affixed to the sources subject to most I&M 

regulations, with the exception of flanges which are usually identified by the component 

they are closest to (if they are monitored at all). Tags are most commonly embossed 

stainless steel, but in some cases aluminum tags or paper tags in a plastic envelope may 

provide suitable durability. These tags range in cost from about $050 to $2.00 each 

depending on the type and the number purchased. Tags may be attached using stainless 

steel wire or "zip strips" made of metal or plastic. The cost of the attachment equipment 

is usually negligible compared to the cost of the tag and the labor required to install it I 

would estimate the installation labor to average 2 person-minutes per component, which 

is equivalent to one person tagging about 250 components per day. 

|g0BBKMif|R^PpllB^which meet EPA Method 21 performance criteria will cost from 

$1,200 to $17,000. The flame ionization detectors that are most commonly used will cost 

an average of $7,000 to $9,000 when fully equipped with dilution probe, carrying case, 

hydrogen fill line, charger, and extra battery pack. Photo ionization detectors that are 

often used for monitoring aromatics emissions cost an average of $4,000 to $5,000. 

Simple combustible gas analyzers and some solid state analyzers can cost as little as 

$1,200 to $2,000. A portable infrared analyzer tops the list at a cost of $17,100. Many 

of these analyzers are available with built-in data loggers, which may raise the price 

considerably. 

A company would require at least a second analyzer to provide backup. My experience 

is that the primary analyzer will be available for use about 70% to 80% of the time. 

This includes an estimate of a factory overhaul every six months requiring about 2 weeks, 

which accounts for about 8% unavailability. In addition, there is routine calibration and 

22 , 
P.30 

preventive maintenance that requires about an hour a day, accounting for another 12% 

unavailability. Excessive drift and mechanical problems will cause additional downtime 

on an unpredictable basis. This level of availability indicates a need for one shared 

backup instrument for up to three or four primary instruments. In addition, a small 

stock of parts that commonly fail should be maintained on hand. That should include at 

least one spare battery pack. Other spares that might be kept in a sophisticated system 

include detectors, ignitors, filters, tubing, tubing fittings, etc. It would be good to allow 

about $300 per primary instrument for additional spare parts. 

A good rule of thumb would be that an analyzer can screen about 400 components per 

day under ideal conditions and assuming an 8-hour work day. That would translate into 

an ideal capacity of 2000 components per week (assuming a 5 day work week) or 8,000 

components per month or 24,000 components per quarter. Taking availability into 

account, however, results in actual capacities of about 300 components per day; 1,500 

components per week; 6,000 components per month; 18,000 components per quarter; 

36,000 components per six months; or 72,000 components per year. There needs to be 

another contingency factor added to assure compliance times and to account for nonanalyzer loss of capacity (such as weather, illness of operators, downtimes for units 

scheduled to be screened, etc). Assuming an additional contingency of 10%, a company 

should purchase one analyzer for every 16,000 components if they are required to do 

quarterly monitoring, but in no case less than two instruments and assorted spares. 

Areas with very cold and inclement winters should probably allow a greater than 10% 

contingency, since battery life and other instrument performance characteristics deteriorate rapidly below about 40°F and/or during rain episodes. 

These analyzers are widely available for rent also, so a company could take that approach rather than purchasing a backup. Since rental rates run around 2% to 3% of the 

instrument purchase price per wf>ek of rental, it would not usually be cost effective to 

rent all backup instrumentation. It is reasonable to rent instruments for the unusual 

situations where two or more primary instruments fail at the same time, or to provide 

backup for the time during scheduled factory overhauls of the primary instruments. 

' tife^Si^ins^e ^ 

\vm^Qt7have7toJbe7re^ normally include process 

unit, component type, component service, stream name/ID, and location information. 

The facility may choose to include a more robust description of the component including 

component subtype, size, gasket/packing material age, vibration levels, etc. Some 

companies will choose to do this before the first instrumental screening and others wOl 

combine the tagging, master data acquisition, and first screening into one operation. In 

either case, determining and recording all of this information can take two to three times 

as long as a normal screening inspection. 

esUmateditftiake^ 

values, field data logging, and keypunching into the database.- The actual value for any 

company will depend on the data logging method (data sheets & keypunch vs. automatic 

field data logging) and on the number of parameters tracked in the master database. 

2? 
P.31 

iSubs^uentSoutme recordkeeping Is 1 ^ 

tp^tpninu|e^^ 

Fugitivefl&M generate a large quantity of data.^ T^ to manage this data can 

range from simple spreadsheets and off-the-shelf databases to custom designed databases. Small facilities, those with a few thousand romr^nents up to a few tens of thousand^ 

•WBI^$&rWESI&^ the fugitives inspection data on a spreadsheet costing a few hundred ' 

dollars (and Likely to already be available in house). The spreadsheet approach is best 

suited to emissions estimating using the screening range emission factors, although it may 

be feasible to use the correlation equations for only those leaking components which are 

repaired. Larger facilities can often use a commercial database program and set up their 

own database application. Again the software is often already available in house, but 

more labor hours will be required to structure the database application. CJusfom 

delg&aata^^^^^ 

about{$l,000 to $20,000 depending on the complexity of the software and the number of 

cgpjejs/sitesslicensed. Even with a custom-designed fugitive emissions data management 

packagethere will be intern?! labor rosts frfrjearning the new'SvstenL) There will also 

be $eme!ime required at each reporting periodT) It is very difficult to estimate the time 

required fo^the report preparation] since it will vary from one required format to 

another and from one data management system to another. It can be generally noted 

that the reporting labor should decrease as the sophistication of the data management 

software increases. For instance, a spreadsheet-based system may require a substantial 

time investment at each successive reporting period. A database management package 

may have a high labor requirement to generate the first report of a given type, but that 

should decrease markedly for successive report of the same type. A custom-designed 

fugitives data management package should come with pre-designed report formats to 

reduce reporting effort, but labor will be required to modify those reports in response to 

future changes in regulatory requirements. 

When considering startup costs for I&M activities required under a new MACT, not all 

of the above are likely to apply. Most industrial facilities are already covered under a 

VOC regulation requiring periodic I&M. This means that many of the sources will 

already be tagged and a master database in place. Existing analyzers will be sufficient 

for MACT use in some cases, but for highly substituted chemicals (halogenated, oxygenated, etc), an analyzer which has a better response factor may need to be acquired. 

Existing software systems may also be acceptable for MACT use, although they wQl 

almost always need some form of modification to meet the specific reporting require-. 

ments. The actual startup costs for an MACT I&M program in refineries may vary from 

insignificant to quite substantial depending on the I&M program already in use. 

The above information can not be referenced to any single report or study. It has been 

accumulated through 17 years experience in the fugitive emissions field. In that time, I 

have directly worked on around ten major fugitive emissions measurement research 

studies for various industries (petroleum refining, organic chemicals, natural gas processing, marketing terminals, etc.). I have also had the experience of helping one domestic 

3o 
P.32 

refinery establish a compliance fugitive I&M program, as well as helping four foreign 

facilities establish fugitive I&M programs on a proactive basis. I have attended, spoken 

at, and chaired a number of workshops, conferences, and symposia in the fugitive 

emissions field, which gave me the opportunity to hear the experiences of others in this 

field. 

3/ 
P.33 

RADIAN 

CORPORATIO N 

A-90-20 

II B-6 

MEMORANDUM Progress Comer 

3200 E. Chapel Hill Rd. SeKon Hu>. 

PO Bo\ I3««H) 

DATE: February 28, 1992 D . _. . a . v - >--lkl 

J

 Research Triangle Park. N.C. T IN . 

TO: David Markwordt, EPA i9r*)» >-*l-*J|tm 

FROM: K. J. Hausle and D. J. Whitt, Radian corporation 

SUBJECT: Final Cost Impacts Analysis for HON Equipment Leaks 

The purpose of this memorandum is to present the revised 

estimated cost impacts analysis associated with the regulatory 

support work for the equipment leaks Hazardous Organic NESHAP 

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

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

used here refer to the model units developed for the regulatory 

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

Controlled Model Unit Emissions from Equipment Leaks," 

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

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

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

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

respectively. 

The analysis presented here is based on the control 

requirements specified in the equipment leaks negotiated 

regulation (Reg Neg).1 The Reg Neg1 requires quarterly valve 

monitoring for units demonstrating leak frequencies below 

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

greater must monitor on a monthly basis. The cost impacts 

analysis presented; here includes separate cost estimates for both 

:of these-mbnitoi^^KscehariOi. • :Th^';afia<;l^ii^^ihd:ic>tes that-.' '-••*•. 

implementation of the controls; will result in an5 annual savings 

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

monthly valve monitoring, the analysis indicates an annual 

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

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

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

monitoring to a cost of $390/Mg HAP for model unit D with monthly 

valve monitoring. 

; 3Z 
P.34 

Cost Basis 

To determine the cost impacts associated with implementation 

of Reg Neg1 Controls for the HON for equipment leaks, the first 

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

regulated. These base costs are used in all subsequent 

calculations in this analysis. The types of regulated equipment 

are: 

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

(2) Pump seals in light liquid service, 

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

(4) Compressor seals, N 

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

(6) Open-ended lines, 

(7) Product accumulators, 

(8) Sample connections, and 

(95) Agitator seals in gas/vapor and light liquid service. 

For pumps, valves, agitators, and connectors, the Reg Neg1 

requires routine leak detection and repair (LDAR). For all other 

types of equipment, the. Reg Neg calls for equipment 

modifications. The base costs for each type of equipment are 

presented in Table 1. These base costs were developed from 

several sources of information including vendor quotes, costing 

manuals, and previous documentation on control of equipment 

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

Fugitive Emission Sources of Organic Compounds - Additional 

Information on Emissions, Emission Reductions, and Costs*2 This 

document is ref erred to as the Fugitives Emissions AID. The 

.'7/ihr£riSavfci&Jr^ "V 77'':'V;'7-'-

• •' '\\:.\£r'--:'i?yy*? '"•••'• Wpf~,.'ii':>i-.'-'-'. •'•77••'•;^h•"7•^;::^7;^•;''•fi,•:•:'• ':':V ' • '•''•:••• '•: :7-.:- . •'• .

 :i<~ •••' ..•••»•.•:•;•.:••>•• 

Pumps, valves, connectors, and agitators in heavy liquid 

service, instrumentation systems,, and pressure relief devices in 

liquid service are also covered by the standard. For these 

components, the standard requires that the leaking component be 

monitored with an organic vapor detection instrument within five 

cost*. I 33 
TABLE 1. BASE COST DATA 

Equipment Type Phase Item 

Cost 

(July'89 dollar-) Batia 

Monitoring Monitoring Instrument 6.500 /instr. 

/ Quote of $6,500/lnstr. 

Valves 

Gat/Vapor 

Ught Liquid 

Heavy Liquid 

Pump Seals 

Light Liquid 

Heavy Liquid 

Connectors 

All 

Compressor Seals 

Gas/Vapor 

• 

Pressure Relief Seals 

:7;U':; ' :/s£v^:(n*4-• 

• 

LOAR. 

LDAR 

None 

LOAR 

Replacement Seals 

None 

LOAR 

Closed Vent System 

for Degassing Reservoirs 

-122m of 8.1 em 

schedule 40 steel 

pipe 

-Installation (68 hrs) 

-three 5.1 cm cast 

steel plug valves 

-Installation (6 hrs) 

- one metal gauze 

flame arrester 

• -Installation {10 hrs) 

TOTAL: 

.:7:7RM^^^;A^mbly 

' -;<we 7A cm «alniess 

steel rupture disK 

-orteTjBcrrii carbon 

steel rupture disk 

holder 

2 /comp/tsst 

2 /compAest 

2 /compAest 

ISO /seal 

2 /compAest 

1.080 

1.490 

2.440 

135 

662 

225 / 

6.242 J 

• f . 

:-7; .TT'^-

•••'•%/ i ••;••-?. % 

• • • . . "• ' 

579 

Vendor information (1989) 

Vendor information (1989) 

• 

Vendor information (1889) 

Update from AID S113/seal 

with 504* credit for old seal 

CE Index (356/224.7) 

Vendor Information (1989) 

$261.03/100 ft. (Richardson) 

CE lndex(356.0/342.5) 

16.6 hrs7100 ft. (Richardson) 

$783.75/valve (Richardson) 

CEIndex(356.0/342.5) 

2 hrsTvalve (Richardson) 

Vendor quote of $869.00 

CE lndex(356.0/3S8.7) 

Labor 822.50/hr 

•'"'••.''" . ". . •'•• • ' ' * '•• • *. ' 

Vendor quote of $235/3-oak 

... CE1ndex(356.0/358.7) 

10/90 quote of S583/holdsr 

34 
TABLE 1. (Continued) 

P.36 

Equipment Type Phase Item 

Cost 

(July'89 dollars) Basis 

All (retrofit) 

Open-Ended Lines 

• one 0.6 cm pressure 

gauge, dial lace 

•one 0:6 cm bleed 

valve, carbon steel 

• Installation (16 hrs) 

- one 7.6 cm gate valve 

-Installation (1.5 hrs) 

-Offset: one 10.2 cm 

tee and one 10.2 cm 

elbow 

24 

40 

360 

401 

34 

49 

CE lndex(356.0/358.7) 

Update from SOCMI NSPS AID 

CE lndex(356.0/224.7) 

Update from SOCMI NSPS AID 

CEIndex(356.0/224.7) 

Labor S22.50/tw 

3385.60/vatve (Richardson) 

CE lndex(356.0/342.5) 

1.5 hrsTvalve (Richardson) 

$35.63/tee. $11.73/tlbow 

-Installation (8.8 hrs) 

TOTAL 

Costs are the same as for 

a new assembly plus a new 

relief valve. 

- one 7.6 cm stainless 

steel body and trim 

relief valve 

-Installation (10 hrs) 

TOTAL: 

191 

1.758 

\<fft 

(Richardson) 

CEIndex(356.0/34&5) 

8.7 hraJtee. 2.8 hrs7eibow 

(Richardson) 

All 

Connection 

Alt' 

i ' 

•> - » 

\ 

one 2.8 cm gate vatve 

- Installation (1.4 hr) 

Closed Purge System 

-6mof2.5cm 

schedule 40 steel 

pipe 

- Installation (IhrV 

-three 2.5 cmball 

valves, carbon steel 

-Installation (4.2 hrs) 

*. 

rOTAL: 

TOTAL: 

70 

31 

102 

25 

23 

267 

95 

409 

1.950 Update from SOCMI NSP8 AID 

CE lndex(356.0/224.7) 

225 Labor 822.50/hr -

3.930 -XlS--1f?oi~ -\<i\0: O ^ ^ 

W7.50/valve (Richardson) 

CEIndex(356.07342J) 

1.4 hrsTvalve (Richardson) 

3120.64/100 ft. (Richardson) 

CE lndex(356.0/342J5) 

12.6 hrai/ioo fL (Richardson) 

$as.60/vatve (Richardson) 

CEIndex(356.W3415)\; ' 

1.4 hrsTvalve (Richardson) .••:;^-'>>ii 

\3S~ 
days of finding evidence of a leak by visual, audible, olfactory, 

or any other detection method. However, these components neednot 

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

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

eliminated by best repair practices. Since these components are 

not required to undergo regular monitoring or increased 

maintenance by the standard, they are not included in this > »-( 

analysis. 

Information on the costs of control equipment, the 

controlled and uncontrolled emission rates, and the leak 

frequencies, for agitators are not available. All of these 

factors affect the final cost of control. Therefore, agitators 

have not been included in this cost impacts analysis. 

The equipment specification for product accumulators 

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

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

product accumulator vents, such as distillate receiver vents, are 

covered by the broad definition of process vents. As with 

agitators, there is limited available information on product 

accumulators, and therefore, product accumulator vessels are not 

included in this cost analysis. 

It was assumed that each process unit would be required to 

purchase one portable organic vapor analyzer monitoring device. 

This device would be required either for occasional use by a 

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

sub-contracted monitoring team, should the subcontractor's 

instrument fail during a monitoring visit. The cost of this 

analyzer was determined to be $6,500 per^uiiit&basfed°n 'iprice 

'\&:--.&:'-'&&-y.-.-i-,'-.'-ik;T?.r^ •'%>•.• . . "••' "•-.'•:. '•'•:.T't'j.^^Mi .-fyx-.&•:. ' -x.-' :*'-^ 

W^iitwi^v.-V??^^^ •''* 

xse.!i&;yan37^ 

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

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

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

Emissions 

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

(356.0/224.7). This ratio is the final July 198* CE plant cost 

COStS .-MM 
index (356.0)5 divided by the average of the final 1978 October, 

November, and December plant cost indexes (224.7) ,

6,7,8 

The base costs for valves are only those for monitoring and 

repair labor associated with the LDAR program. Replacement seals 

for valves are not included here because they are typically low 

cost items, and are considered to be covered by routine 

maintenance costs for the unit. 

The control equipment requirements for compressors, pressure 

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

updated from component requirements specified in the Fugitives 

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

using Richardson Process Plant Construction Estimation 

Standards9 and by requesting current price quotes from vendors 

on equipment components.10,11 These prices were then adjusted 

to July, 1989 dollars. To update prices obtained from 

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

cost index for 1988, was used.9 To update price quotes from 

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

index for July of 1990, was used. Quotes could not be 

. obtained for all equipment components. For retrofitted 

replacement pressure relief valves, pressure gauges, and bleed 

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

the Fugitives Emissions AID2 were adjusted using the CE plant 

cost index ratio of (356.0/224.7). 

The labor-hour requirements for equipment installation for 

retrofitted pressure relief valves, pressure gauges, bleed 

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

the^Fugimvesv Emiss ions AID. TThe - ^ 

Estimation Standards.* The cost for installation labor was 

estimated to be $22.50 per hour.13'

1* This labor cost was 

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

July 1989 dollars. 

37 

cost*, am " ' 6 , 

van 
P.39 

Capital Costs 

The capital costs for bringing existing units up to the 

level of control stated in the Reg Neg1 were estimated using the 

base costs discussed above and the model unit equipment counts. 

Table 2 presents the capital costs for equipment for all six 

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

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

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

because these units are defined as uncontrolled, and must 

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

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

have a monitoring instrument. All other capital costs are 

equivalent for the uncontrolled and controlled model units. 

Leak Detection and Repair Costs 

The cost for maintaining a LDAR program is considered to be 

« 

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

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

for operating an LDAR program are estimated to be 

component per monitoring event based on monitorings performed by 

S^2£2J22^mmiaaiaaaa%%aaaaaaaf ' 

a vflHHMRBr!^, ) This cost was multiplied by the appropriate 

equipment counts and required monitoring frequencies for each 

model unit to obtain the estimated annual costs. This monitoring 

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

detector and an initial repair attempt to be made by the 

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

^ conduct monitoring .internally,, and not bring in a subcontractor, 

for monitoring, the monitoring cost' would be the same. 

The standard requires that valves in gas/vapor service and 

valves in light liquid service be monitored quarterly if the 

process unit has demonstrated through previous monitoring and 

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

The costs for this monitoring frequency are presented in 

38 

COStS.-MB 7 
IB 

TABLE 2 . CAPITAL COSTS FOR EQUIPMENT FOR EXISTING UNITS 

Model Unit Identification* 

B 

Wlv ,v 

C D 

Cost ($) 

E 

j /Monitoring Instrument 

/ Compressor Seal Vent 

System 

i Rupture Disk Assemblies 

* 7-J — Disks 

ny* ~ Holders, valves, 

installation 

/Caps for open-ended 

J lines 

6,500 

12,485 

\ 3,498 

173,340 

6,500 

49,940 

5^909 

292,753 

0

D 0b 0° 

0

C 12,485 49,940 

155 3,498 5,909 

7,704 173,340 292,753 

0d Od 0d 0d 0d 0d 

p9* <£" I Closed-purge sample 

^ connections i/o* *2 

TOTAL 

14.311 43.312 3,269 14.301 43.312 

• 210,125 398,413 11,128 203,625 391,913 

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

units. Model units D, E, and F are simple moderate, and complex units 

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

bModel units D, E, and F have LDAR monitoring instruments. 

cModel units A and D do not. have compressors, therefore, the cost for 

compressor seal vent systems is $0.00. 

°-It is assumed that all model unita already have installed caps on open-ended 

lines. 

<:•.•:'.;?.. ,-

' viV:V!;.r^'KV-;;J'v\;i>;>Ti.'-<^r^'. 'o! '•''

 s" 

•i'-:- '.*•* ". -V;1. vCy.-*.'.v^:•>».-.-.V.•.-: X^M:- •• 

;.•-.*•• .'...i'..". •;'••.-•'• : \ . v . • '•:-.-''" v •••••• •:::\-.;-Vi.y>; 

:•:•'•:''$$*•?• 

3<J 

costs .1 
P.41 

Table 3A. The standard requires that valves be monitored 

monthly if, through previous monitoring and reporting, the process 

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

thismonitoring frequency are presented in Table 3B. The valve 

monitoring frequencies are the only differences between Tables 3A 

and 3B. The Reg Neg1 requires that process units with connectors 

having leak frequencies of 0.5 percent or greater monitor once 

annually. At connector leak frequencies less than 0.5 percent, 

process units are allowed to monitor at less frequent intervals. 

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

leaking, annual monitorings with a 0.5 percent leak frequency 

were assumed for connectors for this cost impacts analysis. 

Pumps in light liquid service are to be monitored monthly. 

Although pressure relief seals have an equipment standard, annual 

monitorings are recommended to ensure compliance. Therefore, 

annual monitoring of these sources is also included in these cost 

estimates. No repair costs are included for pressure relief 

valves, since the Reg Neg1 specifies an equipment standard for 

these sources. 

Additional costs for the LDAR program will include the costs 

for subsequent repair of all components that could not be 

adequately repaired at the time of monitoring. The labor cost 

for these subsequent repairs is estimated to be $22.50 per 

hour.13 For valves, 725 percent of all leaks are estimated to 

require further repair.16 It was assumed that the same 

percentage of connectors will require further repair. Any 

pressure relief device leaks requiring subsequent repair are 

assumed to be'covered by routine maintenance costs. 

< * ,ii ^ The percentage^of leaking pumps' requiring further repair was 

, determined ^to\be^7S^ef 6Mt* -This was~'bVsed>on the Reg*Neg1 rule 

Phase III definition that all pumps with Monitor readings over 

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

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

Butadiene plant survey screening data, it was determined that 

approximately 75 percent of the pumps leaking at levels greater 

costs.awn 9 
than 1,000 ppmv were also leaking at levels greater than 

2,000 ppmv.17 

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

Neg1 as. the maximum leak frequency allowed for Phase III without 

requiring a Quality Improvement Program. For this analysis, it 

was assumed that units would meet the performance standard of 

less than 10 percent of their pumps leaking. 

In Phase III, the negotiated rule also states that 3 pumps 

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

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

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

leaking at the time of any one monitoring event without requiring 

the implementation of a Quality Improvement Program. Since any 

pumps determined to be leaking would still require repairs at a 

monitoring reading of 2,000 ppmv, this clause is not expected to. 

change the repair requirements for simple process units. 

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

impacts for these process units, and no cost differences are 

expected or reflected in this cost analysis for model units A 

and D. 

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

(based on 22.50/hour of labor13) are presented.for each equipment 

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

repair costs are presented. Additionally, administrative and 

support costs are presented. Administrative and support costs 

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

Finally, total LDAR costs are presented. 

im 

cost determinations. These costs are 

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

and 3B. «^^efi«-:4KS(9ja£'^^ra^^llf^bv"'"'JB'^eia^^^eSirfe*tiy'^li^^ a-LDAR 

program^d^.^pejpatipn,,;^ 

.••tf-A1' 

• ••

c.'.vV--. 

•'•i'#6 

4/ 

coats. 10 
.:--.3-."-'::-..

:. • 

y'CSi ••••'•• .•.•••' 

:!;iv^TABLE 3A. 

ANNUAL MONITORING AND LEAK REPAIR COST 

ESTIMATES WITH QUARTERLY VALVE MONITORING 

~ ' ' > -I*?- *-* Source Type Monl 

t ^ V 

Estimated Percent 

Number of Leaks Requiring Repair Leak Repair LaborTypei of";'•'•'•.:

•'.i-t^^nd^ Monitoring Costs'* Leak Per Year Further Time"" Hours Required . Leak Repair Costs 

Per Year AID B/E C/F Frequency A/D B/E C/F Repair*" (hrs) A/D B/E C/F A/D B/E C/F 

• • ^^Timee: , .„ 

MP 

Valves 

Gas/Vapor Instrument' 

\S 2^° Ught Liquid Instrument 

Pump Seals 

Ught Liquid Instrument 

l > Visual 

Connectors Instrument 

12 

OASTS, ft 

1 

es* 

'I 3.312 11.032 0.02 6 4 33.1 110.3 

9.432 15.840 0.02 30.4 04.3 158.4 

/•T960 1.344 0.1 (18.0") 48.0 074 

390 548 ^- ^ 

'5.324 14.820 0.005 3.7 13.3 37.1 

I.l -V 1 * 

25 4- 30.4 944 158.4 

75 '** 16-^-216.0 576.0 808.4 

25 1.8 6.7 18.5 

745 2.482 

2.122 3.564 

12.960 18.144 

150 417 

H Pressure Relief Instrument 

Seals' 

$* 90 . 152 0.0 0.0 0.0 0.0 0.0 0.0 

<Ut 

oTOTAL COST (S) 

MODEL UNIT8 

A/D B/E C/F 

Total Monitoring Cost 

Total Leak, Repair Costs 

Admlnjstratlve and Support Cost* 4o*U 

Total Quarterly LDAR Costs k#. 

19.508 

15.977 

14.194 

49.679 

43,734 

24.607 

27,336 

95.677 

*,ivi 

\ J . Although LDAR Is not required lofpjessure Relief Seals. H is estimated that one monitoring wffl be per formed each year to ensure compliance with equipment standard. ( 

' * Monitoring coats are based on a.subcorltractor'e fee of $2.00/eoniponent/monftorlng event 

* * * Percentages requiring: furthefrepair anci repair times were taken from Reference 2 Bection S. with the exception of Ihe 75H of pumps requiring further repair. 

That vaiue wae calculated using data from Gmylem Oxide and Butadiene plant eurveya. 

L 

S 
TABLE 3B. ANNUAL MONITORING AND LEAK REPAIR COST 

ESTIMATES WITH MONTHLY VALVE MONITORING 

Source Type 

,,-:-_ . Estimated Percent 

,T[jnes Number of Leake Requiring . Repair Leak Repair LaborType of ^'^pnjtgred ,^ Monitoring Costs'* Leak Per Year Further Time*** Hours Requited Leak Repair Costs 

Monitoring ^gerYoar A/D B/E C/F Frequency A/D B/E C/F Repair*** (hrs) A/D B/E C/F A/D B/E C/F 

Valves 

Oas/Vapor Instrument JT7 12 1,848 9.036 33.096 0.02 t8.6 99.4 331.0 25 4 18.S 99.4 331.0 416 2.236 7.447 

Light Liquid Instrument 

Pump Seals 

12 9,120 28496 47.620 0.02 914 283.0 4754 25 4 914 283.0 4764 2.052 6.367 10.692 

Light Liquid Instrument 

visual 

12 360 960 1444 

62 146 390 646* 

0.1 18.0 48.0 674' 75 16 216.0 576.0 806.4 4460 12.960 18.144 

to 

Connectors Instrument 1 1.462 6,324 14,820 0.005 3.7 134 37.1 25 2 1.8 6.7 18.6 41 150 417 

- f c Pressure Relief Instrument 

U ) Seals * 

90 162 0.0 0.0 0.0 0 0.0 0.0 0.0 

TOTAL COST ($) A/D B/E C/F 

Total Monitoring Cost 

Total Leak Repair Costs -- £ 

Administrative and Support Cost*-' v 

Total Monthly LDAR Costs

 v 

12.940 

7469 

8.124 

28,433 

44.996 

21.712 

26,663 

93491 

97.478 

36,699 

53.671 

187,848 

* Although LOAR is not required lor Pressure Relief Seals, it is estimated that one monitoring will be performed each year to ensure compliance with equipment standard. 

* * Monitoring costs are based on v<Sibj-ortractor"e fee of $2.00/eoinponent/monrtoring event 

• " Percentages requiring rurtfi«jnip£ir end repafr timea were taken frxxn Reference 2 Section S.wim the except 

That value was calculated using 'data from EmyleneOxld^ and Butadiene plameurveya. 

< r T 
'•$$jj$& 4 . INITIAL MONITORING AND LEAK REPAIR COST ESTIMATES 

iJv'-r^VS-'V _• 

%;i^fe|7 '• •• • 

Type of 77::.;'^ifering Costs* 

Percent 

initial" Estimated Requiring Repair Leak Repair LaborLeak Number of Leaks Further Time**' Hours Required Leak Repair Costs 

M ' Valves 

Source Type Monttorir^::;..^^t;, B C Frequency AB C Repair*** (hrs) B B 

•Hkxm>:% 

'

;

'$f?i:i

y

-':\ 

y~7y^\ Gas/Vapor Instrument! 

•T-am • 

«-*! ' Light Uquid Instrur^**••"*»«*«»-—' 

I CT Pump 

\ ** )d ^ Ught Uquid Ini 

S»*lH_ lectors Im 

1o-W5 

4: 

T> 

1.035 3.448 10.114 ) v 8.8) 474 1674 V28 / V 4 ) i8-

8

 r7-

2

 •*>7-2 

* 

«S 

*»• * 

'2.948 4460 0.065 24.7 76.6 128.7 26 4 24.7 76.6 128.7 

) '1.062 3.537 

* 1.724 2,896 

100 140 0.2 3.0 8.0 114 76 16 36.0 96.0 134.4 HP * 2.160 3.024 

16.626 0.021 15.4 554 165.6 25 2 7.7 28.0 77.8 173 629 1.761 

TOTAL COST ($) 

'?•&$&!$£. '".A. MODEL UNITS 

BliPtf-- A - B C 

- & 

(TZJL H<^VS+ T^

 LJ^ '^~ 

vo.^t 

* Monitoring costs are based .crt;'a".sur>«xrtiact81 

" I t waa assumed that leattaguehcleti wire2 timee the leak frequencies presented In Teble 3 for pumpe. All other leak frequencies were 

taken *omfWanr«ic*^-^y^^ . 

-**' Percentagec requiring!^ 

VfX J*** 

..arid repair timee were taken from Reference 2 SecUon 5. wlm the exception of the 75% of pumps 

requiring further repair. Wk^^^M^'^&bUA using data from Ethylene Oxide artrJ-ButadTene ptant surveys. 

•>P 

* # 

'•'•-IJ*: :!(. -
For these initial monitorings the monitoring cost increases 

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

locating all components, increased numbers of components 

requiring tagging, and higher leak frequencies. This monitoring 

cost was determined by contacting monitoring subcontractors.19 

The initial leak frequencies for valves and connectors were taken 

from the 24-Unit Study.18 The initial leak frequency for pumps 

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

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

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

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

subsequent annual LDAR. 

Annual Control Cost Estimates 

The annual costs were calculated based on the procedure 

developed during the SOCMI Fugitives NSPS development.2 

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

model units, for quarterly and monthly valve monitoring, 

respectively. These annual costs are based on the costs 

developed in Tables 1 through 4.. 

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

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

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

10 percent interest for all other control equipment.2 The 

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

respectively. Note that units A, B, and C, have initial LDAR 

••••••^M -

rial's-'.'-

7

c'w-;-vv 

A' 

• ;•' ' "1 9 •, 

maintenance presented in the SOCMI Fugitives AID was $2,700, 

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

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

determined by multiplying the number of seals requiring 

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

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

QUARTERLY VALVE MONITORING* 

Cost Hem Unit A UnitB UnitO UnitD UnltE UnttF 

Annualized capital charges 

if Control Equipment 

Ja. Monitoring Instrument 

J b. Compressor Seal Vent System 

I c. Rupture Disk Assemblies 

Disks 

0 - Disk holders, valves, etc. 

d. Caps tor Open-Ended Lines 

e. Closed-Loop Sampling 

2. Initial Leak Repair 

a. Labor, Admin, and Support 

i 

r « 

c«» 

I O 

1.495 

2.035 J 8.' 

1.495 

140 

2.029 3.427 

jr*/ o o 

"Y\,l1> JlBf ^ 2.331 7.060 

\\|1> Maw * 3.723 8.733 

b. Replacement Pump Seals Lfof- x t flp, 626 877 

0 

2.035 

0 

0 

0 

8.140 

80 2.029 3.427 

1.256 28.264 47.719 

0 0 0 

533 2431 7.000 

Subtotal: $ 40.494 77.451 1.879 34.650 66446 

Operating Costs 

iv^u ^ M-Jnt.runcs Croros. f 

..^rtpringj^umw t 

b. Compressor Seal Vent System 

c. Rupture Disk Assemblies 

- Rupture disks 

- Disk holders, valves, etc. 

d. Caps for Open-Ended Lines "V*-C-o '«.©*-* 

e. Closed-Loop Sampling A **,*•*>» rQ* ^ *• 

PumpSeaJajTp*\t° , 

•$&W0dr/f 

fy(\^L Replacement Pump 

y/a.. MonitoringInstrument 

y/ V b. Compressor Seal Vent Systsm * o. compressor seat vent systsm . ( 

- y/c . Rupturs Olskstf-ulit*--/i£^>itorr>rt\<t 

;7..: .fltfAd.Capsfor^Open-EndedUnes %>j^*V«tM 

±/~ e. Closed-Loop Sampling ' v*^V)r **«•"» 

<i/ f. Replacement Pump Seals *I^V^^^^ y 

a. LDAR Monitoring 

D. Subsequent Repair 

c. Administrative and Support 

4480 

624 

175 

8,667 

717 

715 

'6.480 

«B* 

7.074 

573 

,972 

5.184 

19408 

15.977 

14.194 

4480 

2.497 

295 

14.638 

2.156 

2.166 

9,072 

260 

1.996 

11.946 

, 1.7H 

<t.7Mv 

7466 

43.734 

24.607 

27.336 

4.280 

0 

8 

385 

168 

. 103 

2.430 

260 

0 

31+ 

134 

131 

1.944 

6.628 

6.724 

4441 

4.280 

624 

178 

8.067 

717 

716 

6,480 

'..'260 

7499-

••7^4 ••-. 

•:$$&*% • 

-

 :mim -8;il47 

19.506 

15,977 

14.194 

4480 

2.497 

296 

14438 

2.155 

2,166 

9,072 

•;&B0:. 

1498 

7$$£ 

^3t!72$ 

w«fijir 

i ••i;!i-v.;.;'\i 

43.734 

24,607 

27436 

.-•;« & 

•••;&•¥ W 

Subtotal: 85.500 155.699 26,110 85,500 156,009 

Total I ijaflSOfrr 125.993 233.149 27.989 120.149 222.044 | 

aThese annual costs do not include recovery credits for VOC 

emission reductions. LL£, 

15 
P.48 

TABLE 5B. ANNUAL CONTROL COSTS FOR MODEL UNITS 

WITH MONTHLY VALVE MONITORINGf 

Cost Hem Unit A UnitB Unite UnltD UnitE UnitP 

Annualized capital charges 

1. Control Equipment 

a. Monitoring Instrument 

b. Compressor Seal Vent System 

c. Rupture Disk Assemblies 

-Disks 

- Disk holders, valves, etc. 

d. Cepe for Open-Ended Lines 

e. Closed-Loop Sampling 

2. Initial Leak Repair 

a. Labor. Admin, and Support 

b. Replacement Pump Seals 

1.495 

0 

90 

1456 

0 

633 

1.082 

235 

1.495 

2.035 

2.029 

28454 

0 

2.331 

3.723 

626 

1.495 

8.140 

3.427 

47.719 

0 

7.060 

8.733 

877 

0 

0 

90 

1.256 

0 

533 

0 

0 

0 

2.038 

2.029 

28454 

0 

2.331 

0 

0 

. 0 

8.140 

3.427 

47.719 

0 

7.060 

0 

0 

Subtotal: 4.691 40.494 77.451 1.879 34.650 66.346 

Operating Costa 

1. Annual Maintenance Charges 

a. Monitoring Instrument 

b. Compressor Seal Vent System 

c. Rupture Dick Assemblies 

-Rupture disks 

- Disk holders, valves, etc. 

d. Caps lor Open-Ended Lines 

e. Closed-Loop Sampling 

f. Replacement Pump' Seals 

2. Annual Miscellaneous {taxes, 

insurance, administration) 

a. Mooitorjir^^lni^ment 

. b. Cc^pfiir^/S^IVem System 

;r..y ^f^&^M^^'.x.'hLW^. • 

;.-'.' w::,d7cipe;%6|pprided:Llnei 

,;,v .^sXiose^l ^ Sarnty%^ -•; 

•vV^i:^Be•plac^meW|PMp!Seah>.••. 

•-''i'Ufioy^hsrges^ ^ '--•'#•"•' •'*' 

' a. LOAR Monitoring 

b. Subsequent Repair 

c. Administrative and Support 

Subtotal: 

.*R>\r-' 

4.280 

0 

8 

385 

168 

163 

2.430 

•7MQ* 

'••••;<$,• 

4.280 

624 

176 

8.667 

717 

718 

6.480 

260. 

...•499.-. 

4.280 

2.497 

295 

14,638 

2.186 

2.166 

9.072 

..;; 280. 

1.998 . 

4480 

0 

8 

385 

168 

163 

2.430 

,4.260 

• 0 

4.280 

624 

178 

8.667 

717 

716 

6.480 

.•Mfc-i.., 

'. ••.••(•:»•,.:; \S \ 

4.280 

2.497 

298 

14.638 

2.168 

2.188 

.8472 

:, M 

"•71^94 

r

f^'M^^^m^'^^ii?W^^M^^^k- :-T-: 

12.940 44,996 97.478 12.940 44.996 97.478 

7469 21.712 36.699 7469 21.712 36.699 

8.124 26.683 53.671 8.124 26.683 53.671 

38.850 129411 247.870 38.650 129411 247470 

Total | 43.341 169.705 325.320 40.529 163.861 314.2151 

aThese annual costs do not include recovery credits for VOC 

emission reductions. n-y , 

1 c 
other annual maintenance charges were calculated using a factor 

of 0.05 times the capital cost for each component.20 

The annual miscellaneous charges were calculated using a 

factor of 0.04 times the capital cost for each component,20 with 

the exception of the replacement pump seals. Their cost was 

calculated as 0*80 times the annual maintenance charge. This 

gives an annual miscellaneous charge for pump seals proportional 

to the miscellaneous charges for other items. 

Cost Effectiveness 

The cost effectiveness for each of the six model units is 

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

quarterly valve monitoring, and the values in Table 6B reflect 

monthly valve monitoring. 

The cost effectiveness for each of the model units was 

determined by multiplying the annual emission reduction in 

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

to VOC ratio to obtain the average HAP emission reduction for 

each model unit. The annual emission reductions were taken from 

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

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

Emissions from Equipment Leaks.n The VOC emission reductions 

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

VOC to produce the recovered VOC credits. The average HAP to VOC 

ratio and the chemical cost were determined by the HON industries 

profile based on 135 product-process entries (containing cost 

information for 168 VOC's) in the HON-CHEM database.11 The. 

recovered VOC credits were subtracted from the control costs to 

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

divided by the VOC and HAP emission reductions respectively/ to 

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

HAP basis. 

These calculations indicate a net savings for all six model 

units with quarterly valve monitoring. The cost effectiveness 

• • w 

costs,aaa 1 7 ! 

J," 

V J 
TABLE 6A. COST EFFECTIVENESS FOR MODEL UNITS 

WITH QUARTERLY VALVE MONITORING 

Unit A UnitB UnitC UnitD UnitE 

•• 

Unit F 

P.50 

Annual Cost* $/yr 

Emission Reduc. Mg VOC/yr 

Average HAP/VOC ratio 

Emission Reduc. Mg HAP/yr 

Solvent Cost $/Mg VOC 

Recovered Credit $/yr 

Total Annual Cost $/yr 

Cost Effect. $/Mg VOC 

Cost Effect. $/Mg HAP 

30,801 125,993 233.149 27,989 120,149 222,044 

36.47 149.19 306.11 21.39 92.57 187.98 

0.78 0.78 0.78 0.78 0.78 0.78 

28.45 116.37 238.77 16.68 72.20 146.62 

1,590 1.590 1.590 1.590 1.590 1.590 

57.987 237.212 486.715 34,010 147,186 298,888 

(27,186) (111,219) (253,565) (6,021) (27.037) (76.844) 

(750) (75Q) . (830) (280) (290) (410) 

(960) (960) (1.060) (360) (370) (520) 

Annual cost value is taken from table 5A. 

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

:-:'&S5^«VvV 

'. .•' •ivv:;i..''^vvJ-.VA';*'iV'.i'r::*fcv,•v.!.*. /•&•:$>.!•••'• 

''•i]-y:T 

18 m 
P.51 

TABLE 6B. COST EFFECTIVENESS FOR MODEL UNITS 

WITH MONTHLY VALVE MONITORING 

Unit A UnitB UnitC UnitD UnitE UnitF 

Annual Cost* $/yr 43.341 169,705 325,320 40,529 163,861 314,215 

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

Average HAP/VOC ratio 0.78 0.78 0.78 0.78 0.78 0.78 

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

Solvent Cost $/Mg VOC 1,590 1,590 1.590 1,590 1.590 1.590 

Recovered Credit $/yr 57,987 237,212 486,715 34.010 147.186 298.888 

Total Annual Cost $/yr (14,646) (67,507) (161,394) 6,519 16,675 15.327 

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

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

* Annual cost value is from table 58. 

NOTE: Parentheses indicate negative values fie. savings). 

Ji' 

" so 
values range from a savings of $i,060/Mg HAP for model unit C to 

a savings of $360/Mg HAP for model unit D. For monthly value 

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

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

monitoring frequency; the cost effectiveness values range from a 

savings of $680/Mg HAP for model unit C, to an expense of $390/Mg 

HAP for model unit D. 

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P.53 

REFERENCES 

1. Hazardous Air Pollutants. Announcement of the Negotiated 

Regulation for Equipment Leaks. Federal Register. 

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

2. U. S. Environmental Protection Agency. Fugitive Emission 

Sources of Organic Compounds - Additional Information on 

Emission, Emission Reductions, and Costs. Research Triangle 

Park, North Carolina. Publication No. 

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

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

Foxboro Equipment Company. Personal communication with 

D. J. Whitt, Radian Corporation. October 26, 1990 

(documented for the files of D. J. Whitt.) 

4. Reference 2, p. 5-19. 

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

and Annual 1988 CE Plant Cost Index. Chemical Engineering. 

9j7.(9):262. 

6. Economic Indicators. Final October 1978 CE Plant Cost 

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

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

8. Economic Indicators. Final December 1978 CE Plant Cost 

Index. Chemical Engineering. §1(8):7. 

9. Richardson Process Plant Construction Estimation Standards: 

Mechanical and Electrical. Volume 3, Richardson Engineering 

Services, Inc., Mesa, Arizona, 1988. Sections 15-42, 15-43, 

15-55. 

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

Corporation. October 31, 1990.' 4 p. Cost data for flame 

arrestor. 

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

Safety Systems, Inc. Personal communication with 

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

:'?•' '•'••• \' v-: '

- ; ^'V?^'K--^ :

' - , : V •'"•••?'"• ' ' ' " ' ' '•'•' '"•;••••••••<••••'.'••• ••;•;• ' . ; .. . •'..'. . 

12. Economic indicators. Final July 1990 CE Plant Cost. Index. '•'•.TM 

Chemical^Engineering, „£2(10) :.27t).a2. >•<. . *iy.. .

 ;f ^*I| 

13. Reference 9, Section 15-0.13. 

14. Economic Indicators. Construction Labor Cost Index 

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

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

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

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

Darbonne Services Inc., Lake Charles, Louisiana, 

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

Radian Corporation. 

COStS.MS 2 1 

::•.>."£<; 
16. Reference 2, p. 5-3. 

17. Memorandum from Moretti, E. Radian Corporation to 

Markwordt, D. EPA/CPB. May 22, 1989. Summary of Work 

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

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

Problem-Oriented Report: Frequency of Leak Occurrence for 

Fittings in Synthetic Organic Chemical Plant Process Plants, 

U. S. Environmental Protection Agency. Research Triangle 

Park, NC. EPA Contract No. 68-02-3171. September 1980. 

p. 5. 

19. Reference 2, p. 5-34. 

20. U. S. Environmental Protection Agency. Draft VOC Fugitive 

Emissions in Synthetic Organic Chemical Manufacturing 

Industry - Background Information for Proposed Standards. 

Research Triangle Park, NC. Publication 

No. EPA-450/3-80-033a. November, 1980. p. 8-10. 

21. Radian Corporation. HON Industrial Profil e Product 

Processes. Project files. EPA Contract No. 68-02-437B, 

Work Assignment No. 103. 1990. 

'KViVuSji.'^K:::-y-;-.',.-.^>\.i.'.

 :v 

••A»*!>t •;•.-'!*••.'• ••_•>.• **••.;J. ,;•'•. vr . ;*. • 

'•::• • -. ^ •?•' ' 

••'..' ....fl'Wtf.'! 

53 

coats. 22 
A-93-48 Gai * 

MEMORANDUM " . &L*t*W 

DATE: June 27, 1994 

SUBJECT: Methodology for Estimating National* Impacts of 

Controlling Leaking Refinery Equipment 

FROM: Roy V. Oomaen 

Radian Corporation/RTP 

TO: James Durham 

U. S. Environmental Protection Agency 

Chemical and Petroleum Branch (MD-13) 

1.0 INTRODUCTION 

The purpose of this memorandum is to present the methodology 

used to estimate the national impacts of controlling emissions 

from leaking refinery equipment. The results of the impacts 

analysis are presented in another memorandum.1 The results were 

used to decide which control options will be chosen for 

regulating petroleum refinery equipment leaks. 

Responses to survey questionnaire sent to the petroleum 

refinery industry indicated that four control levels are used at 

refineries across the United States: (l) no.control; (2) 

petroleum refinery control techniques guideline (CTG); (3) the 

synthetic organic chemical manufacturing industry (SOCMI) CTG; or 

(4) the petroleum refinery new source performance standard 

(NSPS). 

Impacts were estimated for controlling refinery process 

units from the existing level of control to 3 control options: 

(1) the petroleum refinery NSPS; (2) the hazardous organic NESHAP 

(HON) negotiated regulation for equipment leaks, without 

connector monitoring provisions, and (3) the negotiated 

regulation for equipment leaks. The best-controlled process 

units in the equipment leaks data base control emissions using 

the requirements in the petroleum refinery NSPS. The negotiated 

regulation options represent options more stringent than the MACT 

floor level of control. 

Cost impacts of achieving the control requirements in each 

program were estimated using cost factors from previous analyses. 

St 
P.56 

and surveys sent to equipment leak control vendors and industry. 

Emissions impacts were estimated using control efficiencies 

developed in previous EPA studies. 

Section 2.0 presents control program requirements for 

existing levels of control and control options analyzed in this 

analysis. Section 3.0 presents cost factors for each control 

requirement. Section 4.0 presents the methodology for estimating 

emissions. 

2.0 REQUIREMENTS FOR CONTROL PROGRAMS 

. The control requirements for the existing equipment leak 

control programs and for the negotiated regulation are summarized 

in Table 1. Each of the control requirements in Table 1 are also 

classified as one of two basic control techniques for reducing 

emissions from leaking equipment in a process unit: equipment 

modifications or part of the leak detection and repair (LOAR) 

program. The LDAR requirements include the frequency that 

components are required to be monitored with a hydrocarbon 

analyzer and "the VOC concentration at which a component is 

considered leaking, and visual inspection. Equipment 

modifications include all controls added to equipment to reduce 

emissions, such as closed-vent systems on compressors or caps or 

blind flanges on open-ended lines. 

3.0 ESTIMATION OF NATIONAL IMPACTS 

Impacts from controlling leaking refinery equipment include 

emissions reductions, total annual cost, and capital investment 

costs. Emissions reductions are estimated by multiplying the 

control efficiency of each equipment modification or LDAR 

requirement by the baseline emissions from each equipment. The 

efficiencies of each control requirement and baseline emissions 

are presented, in a previous memorandum; they are not discussed 

here.2 The cost factors used to estimate total annual cost and 

capital investment costs are presented in the following sections. 

3.1 General Cost Variables 

As used in this discussion, annual expenses include any 

costs that occur each year, such as annual maintenance costs or 

SS 
TABLE 1 . CONTROLS REQUIRED BY EQUIPMENT LEAK CONTROL PROGRAMS 

Equipment type Service Petrolcun refinery CTO SOCMI CTG Petroleum refinery USPS HOH negotiated rule 

Valves 

Pimps 

Compressors 

Connectors 

Pressure relief 

devices 

Sampling 

connections 

Cat 

Light 

liquid 

Light 

liquid 

Gat 

Gas and 

Light 

liquid 

Gas 

All 

Open-ended lines All 

Quarterly LDAR 

810,000 ppra 

Annual LDAR 

810,000 ppm 

Annual LDAR 

810,000 ppm; 

Weekly visual 

Inspection 

Quarterly LDAR 

810,000 ppm 

Rent 

Quarterly LOAR 

810,000 ppm 

Cap, blind flange, 

plug, or second valve 

Quarterly LDAR 

810,000 ppm 

Quarterly LDAR 

810,000 ppm 

Quarterly LDAR 

810,000 ppm; 

Weekly visual 

Inspection 

Quarterly LDAR 

810,000 ppm 

None 

Quarterly LDAR 

810,000 ppm 

None 

Cap, blind flange, 

»lug, or second valve 

Monthly LOAR 810,000; 

Decreasing frequency with good performance 

Monthly LDAR 810,000; 

Decreasing frequency with good performance 

Monthly LDAR 810,000 ppm; 

Weekly visual inspection; 

or dual mechanical seals with controlled 

degassing vents 

Dally visual Inspection; 

Dual mechanical sesl with barrier fluid and 

closed-vent system or maintained at a 

higher pressure than the compressed gas 

None 

Monthly LDAR with > 2X leakers; 

Quarterly LDAR with < 2% leakers; 

Decreasing frequency with good performance; 

Initially 810,000 ppm, annually 8500 ppm 

Monthly LDAR with > 2X leakers; 

Quarterly LOAR with < 2% leakers; 

Decreasing frequency with good performance; 

Initially 810,000 ppm, annually 8500 ppm 

Monthly LDAR; Weekly visual Inspection; 

Leak definition decreases from 10,000 ppm; 

or dual mechanical seals or closed-vent 

system 

Dally visual inspection; 

Dual mechanical seal with barrier fluid and 

closed-vent system er maintained at a higher 

pressure than the compressed gas 

Annual LDAR 8500 ppm with > 0.5X leakers; 

Decreasing frequency with good performance 

No detectable emissions or closed* vent 

system 

Ho detectable emissions 

Closed-loop or fn situ sampling 

Cap, blind flange, plug, or second valve Cap, blind flange, plug, or second valve 

Closed-loop, closed-purge, closed*vent or In 

situ sampling 
P.58 

administrative and support costs. The total annual cost of 

equipment leak controls is calculated using the following 

equation: * 

TAC «= VAC + FAC - RC 

where: TAC «= Total annual cost 

VAC = Variable annual cost 

FAC «= Fixed annual cost 

RC «= Recovery credits 

Variable costs are costs that are dependent on operating 

conditions. These include utilities, raw materials, maintenance, 

replacement parts, and labor. Fixed costs are those costs that 

are independent of operating conditions. They include overhead, 

administrative charges, property taxes, insurance, and capital 

recovery. 

Capital recovery costs are capital investment costs 

converted to an annual cost. Capital investment costs include 

the cost of purchasing and installing control equipment. A 

capital investment cost is converted to capital recovery cost 

(annualized capital costs) by multiplying it by the capital 

recovery factor. The capital recovery factor is based on the 

economic life of the capital and the interest rate, and it can be 

calculated using the following equation: 

CRF - [i*(l+i)B]/[(l+i)B -1] 

where: CRF = Capital recovery factor 

i «= Interest rate -

n «-» Economic life of equipment 

Detailed capital investment costs and annual costs for each 

control requirement presented in Table 1 are discussed in 

section 3.2. .. 

Recovery credits are savings equal to the value of material 

remaining in the process which would otherwise have been released 

to the atmosphere had the equipment leak control not been 

implemented. Recovery credit is calculated by multiplying the 

S7 
P.59 

amount of VOC recovered or saved because of upgrading control 

options and the recovery credit cost. An EPA analysis in 1982 

presented a recovery credit cost from controlling refinery 

equipment leaks of $215/Mg of volatile organic compounds (VOC),3 

This factor was converted to first quarter 1992 dollars by 

multiplying it by the ratio of producer price index from first 

quarter 1992 and the annual value from 1982 (59.7/100 or 0.597). 

Based on this data, a recovery credit of $130/Mg of voc was used 

for this analysis. 

3.2 Cost Factors' for Estimating National Impacts 

Cost factors for equipment modification and LDAR 

requirements were obtained from previous analyses and survey 

responses from equipment leak control vendors and facilities 

using an LDAR program. This section describes these data sources 

and the cost factor determination methodology. All costs are in 

first quarter 1992 dollars. 

3.2.1 Equipment Modification Costs 

Capital costs for equipment modifications include the cost 

of purchased equipment and the costs to install the equipment. 

tt. Table 1 indicates that for components require equipment 

modifications: compressors, open-ended lines, sample 

connections, and pressure relief devices. For each equipment 

modification, it is assumed that the equipment requirements are 

the same as described in the 

CtenneiAuiiiiii8MCiiaM3*-fl ., hereafter referred 

to as the equipment leaks enabling.document.\ Table 2 summarizes 

total capital investment costs for modifications to compressors, 

open-ended lines, sample connections, and pressure relief 

devices. It is assumed compressors will be controlled with a 

closed-vent system routed to a combustion device; open-ended 

lines with a second valve; sampling connections with a closedloop sampling system; and pressure relief devices with a rupture 

disk assembly. A detailed discussion of the development of these 

costs are presented in the equipment leaks enabling document. 

SS 
P.60 

TABLE 2. EQUIPMENT MODIFICATION CAPITAL INVESTMENT COSTS* 

Equipment type Control Cost 

Compressor 

Open-ended lines 

Sample connections 

Pressure relief valves 

Closed-vent system 

Second valve 

Closed-loop system 

Rupture disk 

$6,280 

$102 

$413 

$3,960 ^ 

aCosts were obtained from the equipment leaks enabling 

document 

51 
P.61 

Total annual costs for equipment modifications include only 

fixed costs (capital recovery costs, annual maintenance cost, and 

annual miscellaneous costs), and recovery credits. The 

assumptions used to calculate these costs are the same as those 

presented in the equipment leaks enabling document. All of the 

control equipment with the exception of rupture disks are assumed 

to have an economic life of 10 years; rupture disks are assumed 

to have an economic life of 5 years. Based on an interest rate 

of 7 percent, the capital recovery factor for all control 

equipment except rupture disks is 0.143,-and the capital recovery 

factor for rupture disks is 0.244. The cost of maintaining the 

control equipment is assumed to be 5 percent of the capital 

investment costs. Miscellaneous costs include taxes, insurance, 

and administrative expenses, and are assumed to be 4 percent of 

the capital investment costs. Annual costs for equipment 

modifications are summarized in Table 3. 

For most equipment modifications, emissions from the 

controlled equipment are prevented from occurring, and, 

therefore, material that would otherwise be emitted is recovered 

and remains in the process resulting in a cost savings. The 

recovery credit is calculated by multiplying the emission 

reduction by the value of the material. An exception is for a 

closed-vent system that routes vapors to a combustion device 

where the collected vapors may have some energy value, however 

they are not recovered for reuse in the process, and recovery 

credits are assumed to be negligible. 

3.2.2 Leak Detection and Repair Costs 

This section presents the costs associated with the 

initiation and continuation of a LDAR program for the control of 

VOC or volatile organic hazardous air pollutant (VHAP) emissions 

from pumps, valves, and connectors. Table 4 lists each of the 

LDAR costs considered in this analysis. 

Cost information was obtained from previous analyses and 

responses to survey questionnaires sent to equipment leak vendors 

and facilities that use control programs. Questionnaire 

7 

&o 
TABLE 3. ANNUAL 

BASIS 

Equipment 

• Modification 

Closed vent 

system 

Second valve 

Closed loop 

system 

Rupture disk 

COSTS OF EQUIPMENT MODIFICATIONS, ON A COMPONENT 

• 

Capital 

Recovery 

890 

15 

59 

966 

Costs ($/component) 

Miscellaneous 

251 

4 

16 

158 

Maintenance 

314 

5 

21 

198 

Total 

1,455 

# 

24 

96 

1,322 

P.62 

8 

6/ 
recipients were requested to supply a range of costs for each 

variable identified as contributing to LDAR costs. Five vendors 

and one facility supplied information.5""10 This information was 

combined to develop average cost factors that could be used for 

the national impacts analysis. Table 5 presents the average of 

the capital investment costs for LDAR programs supplied by 

vendors and facilities. 

3.2.2.1 Capital Investment Costs for LDAR Programs 

Capital investment costs of initiating a LDAR program 

include purchasing hardware and start-up expenses. The start-up 

of a LDAR program is considered a capital cost because it 

includes certain first-time expenses associated with the initial 

monitoring survey. . The monitoring costs reflect the expense for 

a monitoring survey team to "screen" each piece of equipment / 

using,a portable monitoring instrument to determine which pieces 

of^eqiiipment require maintenance'. The monitoring team $lso tags 

leaking components - to be regularly monitored*. The tagging 'and ' 

identification costs also include the cost of the tags.' 

For this analysis, it is assumed that an electronic LDAR 

program (i.e., computerized data gathering and storage) will be 

used instead of recordkeeping on paper. Equipment leak 

monitoring hardware include a hydrocarbon analyzer, reader, data 

logger, data management system^computer and accessories), and 

software to run the data management system. Additionally, there 

would be costs for initially entering data, setting up the data 

management system, and training personnel to use the data 

management system. 

Based on vendor responses, one hydrocarbon analyzer.is 

required for. every 16,000 components monitored on a quarterly 

basis, and for every 7,000 components monitored on a monthly 

basis. It is also assumed that this estimate is also applicable 

for readers. The remaining hardware costs are assumed to be 

independent of the number of components monitored. When a 

facility has components that are monitored both quarterly and 

10 

£Z 
TABLE 4. LDAR COST PARAMETERS 

Capital Investment 

£ Tagging and identifying 

^ Initial Monitoring 

-^ Simple valve maintenance 

*)C Monitoring closed vent systems 

J Data collection system 

- Data management system 

- Setting up data management system 

- Training 

- Software 

- Data logger 

- Reader 

- Hydrocarbon analyzer 

- Data entry 

v/pump seal replacement parts 

^Initial repair 

Annual 

<5\ 

<J0 

to 

Variable annual expenses 

y" - Monitoring 

*^ - Simple valve maintenance 

*s - Data logging of monitored components 

>C - Monitoring closed vent systems 

- Trip charges 

~

//-> Calibration gases 

w / - Calibrations - quarterly 

*

/-* Calibrations - daily 

*

/- Visual inspection/weekly - pumps 

-/- Visual inspection/daily - compressors 

- Pump seal replacement parts 

- Repair 

Fixed annual expenses 

- Miscellaneous expenses 

T. Maintenance expenses 

- Capital recovery cost 
P.65 

TABLE 5. INITIAL LDAR COSTSa 

LDAR Parameter -¥- Average Cost*0 

Tagging and identifying 

Initial monitoring 

Simple valve maintenance 

Monitoring closed vent systems 

Data collection system 

$2.15/compr 

$3.20/comp. 

$-2.60/comp-r-

?"— Data management system 

- Setting up data management system 

- Training 

$16,000 ' 

$57,700 

$25,060 

"^ Software 

'. ^—DatsT logger 

- Reader 

^v - Hydrocarbon analyzer 

a* M J A A \l 

- Data entry 

$4,400 

$1,625 1\ 

$7.500'[/ 

$0.80/comp. 

information obtained from survey responses. References 5-^0. 

-^Average of cost data from References 5-10. 

11 

W 
P.66 

monthly, the following equation was used to estimate the number 

of analyzers and readers required: 

. 

• analyzers «= (# quarterly components/16,000) + 

(# monthly components/7,000) 

The monitoring team makes a first attempt at repair, each 

leak by tightening the packing gland on valves (simple 

maintenance) or by some other technique that does not require 

removing the equipment from service. Repair costs are for 

repairs necessary if a more significant problem exists and the 

first attempt at repair by the monitoring team is unsuccessful. 

Initial repair costs are estimated by multiplying the following 

factors for each equipment type: 

• •'- The number of leaks detected by the monitoring team; 

• the percentage of leaking components that could not' be 

repaired on the first attempt (simple maintenance); 

• the time required to repair the equipment piece; and 

Annual repair costs are estimated by multiplying the same 

factors, and the number of times a year the components are 

monitored (monitoring frequency)• 

The number of leaks detected by the monitoring team in a 

one-year period is estimated from the number of components 

monitored, the monitoring frequency, and the leak frequency. For 

example, if a process unit has 10 pumps that are monitored 

monthly and have a leak frequency of 10 percent (i.e., 10 percent 

of the pumps screen at a value above the leak definition) the 

number of leaks in a year is: 

10 pumps * 12 times/yr * 0.10 •» 12 leaks over a year 

The equipment leaks enabling document presented leak frequencies 

for the initial survey and for all subsequent surveys for various 

control programs. The initial leak frequency is normally higher 

than subsequent leak frequencies because it is prior to 

implementing the required LDAR program. Table 6 presents leak 

frequencies for each control program. 

12 

GS 
P.67 

TABLE 6. LEAK FREQUENCIES FOR CONTROL PROGRAMSa 

=^= 

Component 

Control Programs fl 

Petroleum 

Refinery 

CTG 

SOCMI CTG 

Petroleum 

Refinery 

NSPS 

Negotiated I 

Rule 1 

I Initial leak frequency 

1 Gas valves 

fl Light liquid valves 

1 Light liquid pumps 

fl Compressors 

fl Connectors 

(%) 

10 

11 

24 

50.7 

.— 

. 10 

11 

24 

50.7 

-

10 

11 

24 

— 

— 

24 1 

28.5 

48 

— ' 1 

1.7 | 

1 Subsequent leak frequency (%) 

Gas valves 

Light liquid valves 

Light liquid pumps 

Compressors 

I Connectors 

4.69 

3.11 

24 

24 

-

4.69 

3.11 

24 

24 

-

1.60 

1.72 

11.3 

-

-

2 

2 

1 1 

-

0.005 | 

information from the equipment leaks enabling document. 

13 

66 
P.68 

The equipment leaks enabling document also supplied the time 

required to repair each of the components that are monitored, and 

the percent of components that may be assumed to be 

unsuccessfully repaired after simple maintenance. This 

information is presented in Table 7. In this analysis only 

valves undergo simple maintenance procedures. Therefore, valves 

are the only components that are considered to be successfully 

repaired to some degree using simple maintenance procedures. 

When a pump is identified as leaking, the seal must be 

replaced. The cost of the seal and miscellaneous expenses 

associated with the seal are considered part of the LDAR costs. 

The first quarter 1992 cost for each replacement single seal is 

estimated to be $180, which includes a 50 percent credit for the 

old seal. The cost of replacement pump seals is estimated by 

multiplying the replacement cost and the leak frequency of pumps 

presented in Table 6. Replacement parts used to repair valves 

and flanges are inexpensive and the costs of these parts can be 

assumed to be part of routine maintenance costs. 

3.2.2.2 Total Annual Costs for LDAR Programs 

Total' annual costs for LDAR programs are the sum of fixed 

costs (capital recovery costs, miscellaneous costs, and 

maintenance costs), annual expenses, and recovery credits. Table 

8 presents the average of the annual costs of conducting an LDAR 

program supplied by vendors and facilities. The annual expenses 

of conducting a LDAR program include such costs as monitoring, 

data entry, compliance tests, monitoring closed vent systems, 

trip charges, calibration gases, quarterly calibrations, and 

daily calibrations. The costs of the initial survey are higher 

than the costs of subsequent surveys because of difficulties in 

initially locating all components, increased numbers of leaking 

components, and increased time needed to number and tag 

equipment/ Visual-inspection costs were calculated assuming 

"seconds to inspect equipment, and a labor charge rate of 

$22.50/hour. 

14 

a 
P.69 

TABLE 7. REPAIR TIME AND PERCENT UNSUCCESSFULLY REPAIRED* 

Component 

Repair time 

(hours) 

Components 

unsuccessfully 

repaired(%)b 

Gas valves 

Light liquid valves 

Light liquid pumps 

Compressors" 

Connectors 

aData. are from the equipment leaks enabling document. 

-^Unsuccessfully repaired after simple maintenance^ -.. 

15 

6 8 
P.70 

TABLE 8. ANNUAL LDAR COSTSa 

LDAR Parameter Average Cost*3 

Monitoring 

^Simple /valve maintenance 

Data logging 

Monitoring closed vent systems 

Trip charges, travel expenses 

Calibration gases 

Calibrations - quarterly 

Calibrations - daily 

$2.20/compu 

$3.20/com^. 

*?0.56/compv-

$2_ij60/comp. 

$i,ooo/tr1 

~~§300/yr 

$80/analyzer 

$41.25/analyzer^ 

' •—• '•(. 

^Information obtained from survey responses. References 5-10. 

^Average'of cost information from References 5-10. 

0 

16 

61 
P.71 

Annual costs also include maintenance and miscellaneous 

-osts, pumps seal replacement costs, and repair costs, 

(aintenance costs are assumed to be 5 percent of the capital 

investment costs, except for the hydrocarbon analyzer. 

Maintenance costs for the hydrocarbon analyzer are assumed to be 

^69£_pJ dtal investment cost. nMXscellaneous costs are 

assumed to be 4 percent of capital investment costs;) and pump 

seal replacemen^_ci*5ts-ar«-^18i]^pumpmultiplied by the pump les 

[requency. ^Repair costs were discussed previously. 

' The initial LDAR expenses (excep-c for replacement pump seals 

and the hydrocarbon analyzer) are annualized based on a 10 year 

life and 7 percent interest rate, giving a capital recovery 

factor of 0.14. Replacement pump seals are assumed to have an 

economic life of 5 years which, assuming a 7 percent interest 

rate, gives a capital recovery factor of 0.244. The hydrocarbon 

analyzer> is assumed to have a six-year economic life which, 

assuming a 7 percenc interest rate, gives a capital recovery 

factor of 0.21. Emission reductions as a result of implementing 

the LDAR programs are multiplied by the material costs to 

determine__therecovery credits. . ; 

ETOMETHODOLOGY FOR ESTIMATING NATIONAL IMPACTS 

National impacts of controlling leaking refinery equipment 

from the current level of control to the options were estimated 

by following a 3-step process: 

(1) Costs and emissions reductions of going from no control to 

the existing level of control requirements, (II), were 

estimated. 

(2) Costs and emissions reductions of going from no control to 

the control required by the option, (12), were calculated. 

(3) Impacts were estimated by subtracting the cost and emissions 

reductions of the existing; level of control from the option, 

(12 - II). 

National impacts were estimated from component specific 

impacts and refinery impacts. The estimation of emissions and 

emissions reductions from controlling leaking equipment are 

17 

< 

lo 
P.72 

component specific calculations. Emissions impacts on a refinery 

basis were estimated by summing the emissions reductions from- the 

affected equipment. National emissions impacts were estimated by 

summing the emissions reductions from all the refineries in the 

United States. The cost factors described in section 3.0 may be 

component specific or refinery specific factors. Table 9 

identifies which factors are treated as refinery specific factors 

for this analysis. 

Cost impacts were calculated on a component basis by 

multiplying the applicable cost factor, the number of components 

affected (controlled), and, when applicable, the number of times 

a year the component is monitored. Refinery costs were estimated 

by adding the refinery specific cost factors to the sum of the 

component costs. National impacts costs were estimated by 

summing the refinery costs. Appendix A presents a sample 

calculation that illustrates the impacts estimation methodology. 

18 

7/ 
P.73 

TABLE 9. REFINERY SPECIFIC 

COST FACTORS 

Data management system 

Setting up data management 

system 

Training 

Software 

Data logger 

Reader 

Hydrocarbon analyzer 

Trip charges 

Calibration gases 

Calibrations 

19 

72. 
P.74 

5.0 REFERENCES 

1. Costs for the MACT Floor Level of Control and Control 

Options Above the Floor for Controlling Emissions from 

Leaking Refinery Equipment. Memorandum from Roy Oommen, 

Radian Corporation to Jim Durham, EPA. November 23, 1993. 

2. Control Effectiveness of Refinery Equipment Leak Control 

Programs. Memorandum from Roy Oommen, Radian Corporation to 

James Durham, EPA. December 26, 1993. 

3. Internal Instruction Manual for ESP Regulation Development: 

Leaking Refinery Equipment — Pumps, Valves, Compressors, 

Safety Relief Valves. U. S. Environmental Protection Agency, 

Research Triangle Park, North Carolina. July 1992. 

4. voc Emissions in Petroleum Refining Industry - Background 

Information for Proposed Standards. U. S. Environmental 

Protection Agency, Research Triangle Park, North Carolina. 

November 1992. p. 8-15. 

5. Survey response from Michael Smylie of Systems Applications 

International, San Rafael, CA to Roy Oommen, Radian IJ-o~3^<\ 

Corporation. Leak Detection and Repair Costs. November, 

1993. 

6. Survey response from Tony Scataglia and Mike Hebert, TEAM 

Environmental Services, Inc., Webster, Texas to Roy Oommen, LT-0-3W-| 

Radian Corporation. Leak Detection and Repair Costs. 

November 1993. 

7. Survey response from Gary Anderle, International Technology tf-o-%^ 

Corporation to Roy Oommen, Radian Corporation. Leak 

Detection and Repair Costs. November 1993. 

8. Survey response from Jim Rouge, Radian Corporation to Roy -jv0-?1*-

Oommen, Radian Corporation. Leak Detection and Repair 

Costs. November 1993. 

9. Equipment Leak Inspection and Maintenance Start-up-Costs. -.. 

Memorandum from G. E. Harris, Radian Corporation to Roy l-l-O-S\$ 

Oommen, Radian Corporation. September 1993. 

10. Survey response from Eric Landofsky, Shell Chemical to Roy 0,3M-) 

Oommen, Radian Corporation. Leak Detection and Repair (rU-

 M ' 

Costs. November 1993. — 

20 

73 
P.75 

INTEK COPRPORATION-SOUTH Rental Equipment Page 1 of2 

INTEK CORPORATION-SOUTH 

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