### MEMORANDUM

DATE: May 2 6 , 201 4

SUBJECT: Technology Review for the Off-Site Waste and Recovery Operations Source

Category

FROM: Tanya Parise, EC/R Inc. Lesley Stobert, EC/R Inc.

TO: Paula Hirtz, EPA/OAQPS/SPPD

1.0 INTRODUCTION

Section 112 of the Clean Air Act (CAA) requires the U.S. Environmental Protection Agency (EPA) to establish technology-based standards for listed source categories as national emissions

standa rds for hazardous air pollutants (NESHAP). These technology-based standards are often

re ferred to as maximum achievable control technology (MACT) standards. The Off-site Waste

a nd Recovery Operations (OSWRO) MACT standards (40 CFR part 63, subpart DD) apply to major sources of hazardous air pollutants ( HAP ) em issions that receive certain wastes, used oil, and used solvents from off-site locations for waste management operations or recovery operations at the facility. The MACT standards require HAP emissions reductions and control

for tanks, surface impoundments, containers, oil-water separators, individual drain systems and other material conveyance systems, process vents and equipment leaks.

The CAA section 112 also contains provisions requiring the EPA to periodically revisit these standards. Specifically, CA A section 112(d)(6) states:

(6) REVIEW AND REVISION.

– The Administrator shall review, and revise as necessary (taking into account developments in practices, processes, and control technologies), emissions standards promulgated under this section no less often than

e very 8 years.

To comply with this CAA requirement, the EPA conducted a technology review for the OSWRO MACT standards for major sources. For the purposes of reviewing MACT standards, the EPA

c onsiders a “development” in practices, processes, and control technologies to be:

 Any add-on control technology or other equipment that was not identified and considered during development of the original MACT standards.

 Any improvements in add-on control technology or other equipment (that were identified and considered during development of the original MACT standards) that could result in significant additional emissions reduction.2



###  Any work practice or operational procedure that was not identified or considered during development of the original MACT standards.

 Any process change or pollution prevention alternative that could be broadly applied to the industry and that was not identified or considered during development of the original

MACT standards.

 Any significant changes in the cost (including cost effectiveness) of applying controls (including controls the EPA considered during the development of the original MACT standards).

Section 2 of this memorandum presents background information about the OSWRO source

c ategory. Section 3 presents a summary of the sources of data that were used to conduct the

tec hnology review. Section 4 presents estimated emissions reductions and cost impacts for

identifie d developments in practices, processes and control technologies.

2.0 BACKGROUND FOR THE OFF-SITE WASTE AND RECOVERY OPERATION

SOURCE CATEGORY

The EPA promulgated the final OSWRO NESHAP at 40 CFR part 63, subpart DD on July 1,

1996 a nd amended the rule on July 20, 1999. Subpart DD applies to certain waste management

a nd recovery operations at sites that receive off-site materials and that are major sources for

HAP . The OSWRO NESHAP applies to the following operations:

 A waste management operation that receives off-site material and the operation is regulated as a hazardous waste treatment, storage and disposal facility (TSDF) under either 40 CFR part 264 or part 265.

 A waste management operation that treats wastewater which is an off-site material and the operation is exempted from regulation as a hazardous waste TSDF under 40 CFR 264.1(g)(6) or 40 CFR 265.1(c)(10).

 A waste management operation that treats wastewater which is an off-site material and the operation meets both of the following conditions: (1) the operation is subject to regulation under either section 402 or 307(b) of the Clean Water Act (CWA) but is not owned by a “state” or “municipality;” and (2) the treatment of wastewater received from off-site is the predominant activity performed at the plant site.

 A recovery operation that recycles or reprocesses hazardous waste which is an off-site material and the operation is exempted from regulation as a hazardous waste TSDF under 40 CFR 264.1(g)(2) or 40 CFR 265.1(c)(6).

 A recovery operation that re -refines or reprocesses used oil which is an off-site material

a nd the operation is regulat ed under 40 CFR part 279 subpart F (Standards for Used Oil

P rocessors and Refiners).

 A recovery operation that recycles or reprocess es used solvent which is an off-site material and the operation is not part of a chemical, petroleum, or other manufacturing process that is required to use air emission controls by another subpart of 40 CFR part 63 or 40 CFR part 61.3



### An off-site material is a material that meets all of the following requirements:

 The material is a waste, used oil, or used solvent;

 The waste, used oil or used solvent is not produced or generated within the plant site, but

is deli vered, transferred, or otherwise moved to the plant site from a location outside the plant site boundaries; and

 The waste, used oil or used solvent contains one or more of the HAP listed in Table 1 of subpart DD at the point of delivery.

The following are not off-site materials:

 Household waste;

 Radioactive mixed waste managed in accordance with all applicable regulations under Atomic Energy Act and Nuclear Waste Policy Act authorities;

 Waste that is generated as a result of implementing remedial activities required under the

R esource Conservation and Recovery Act (RCRA) corrective action authorities, Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) authorities, or similar Federal or State authorities;

 Waste containing HAP that is generated by residential households and subsequently is collected as a community service by government agencies, businesses, or other organizations for the purpose of promoting the proper disposal of this waste;

 Waste that is transferred from a chemical manufacturing plant or other facility for which both of the following conditions apply to the waste: (1) the management of the waste at the facility is required either under part 63 subpart F or under another subpart in 40 CFR part 63 to meet the air emission control standards for process wastewater specified in 40 CFR 63.132 through 63.147; and (2) The owner or operator of the facility from which the waste is transferred has complied with the provisions of 40 CFR 63.132(g)(1)(ii) and (g)(2);

 Waste that is transferred from a chemical manufacturing plant, petroleum refinery, or coke by-product recovery plant which is subject to 40 CFR part 61, subpart FF and for

which both of the following conditions apply to the waste: (1) The waste is generated at a facility that is not exempted under the provisions of 40 CFR 61.342(a) from meeting the air emission control standards of 40 CFR part 61, subpart FF; and (2) The owner or operator of the facility from which the waste is transferred has complied with the provisions of 40 CFR 61.342(f)(2);

 Ship ballast water pumped from a ship to an onshore wastewater treatment facility; and

 Hazardous waste that is stored for 10 days or less at a transfer facility in compliance with the provisions of 40 CFR 263.12.

The affected sources are three distinct groups of the emission point types subject to the air emission controls under subpart DD. These include:

 O ff -site material management units

– the group of tanks, containers, surface impoundments, oil-water and organic-water separators, individual drain systems, and other stationary material conveyance systems used to manage off-site material in each of the waste management and recovery operations specified in the rule that are located at the plant site.4



###  Process vents on units used to manage off-site material in each of the waste management and recovery operations specified in the rule that are located at the plant site.

 Equipment pump, compressor, agitator, pressure relief device, sampling connection system, open-ended valve or line, valve, connector, or instrumentation system that may

emit HAP as a result of equipment leaks.

The OSWRO MACT standards include a combination of equipment standards, work practice standards, operational standards and performance standards for each of the emission sources noted above. Various other practices, processes, and control technologies were considered in the

de velopment of the OSWRO MACT standards, which are summarized in Table 1.

W e estimate approximately 52 facilities are currently subject to subpart DD; however, seven facilities are known to be exempt from most of the rule requirements due to the low HAP content of the off-site materials they receive. Therefore, we estimate that there are 4 5 facilities that are subj ect to the emission limits, monitoring, recordkeeping and reporting requirements of the

re gulation.

Table 1. Summary of Practices, Processes, and Control Technologies Identified and

Cons idered During OSWRO MACT Standards Development

Emission Source Practices, Processes, and Control Technologies

Material Management Units (in general) Add

- on emissions controls on equipment (as noted in this table below) or w aste pretreatment: steam stripping, air stripping

, solvent extraction, thin

- film evaporation, biological degradation,

incineration

Tanks and Oil

- Water and Organic

- Water Separators Fixed roof, internal floating roof, external floating roof, closed vent system and control device, pressure tank

Container s Leak

- tight covers, placement in an enclosure with a closed vent system and control device, submerged fill loading, vapor balancing during loading, fitted opening for filling with transfer line purging

Surface Impoundments Floating membrane covers, air

- supported structure with closed vent system and control device, replacement with tanks

Transfer Systems Covers, continuous hard piping, enclosure with closed vent system

and control device

Process Vents Combustion devices, recovery devices, scrubbers/abs orbers

Equipment Leaks Leak detection and repair (LDAR) program, specific equipment

modifications5



### 3 .0 SOURCES OF AVAILABLE CONTROL TECHNOLOGY INFORMATION

To identify developments in practices, processes and control technologies since the MACT standards were developed, we consulted the following sources of data:

 The EPA’s RACT/BACT/LAER Clearinghouse

 Review of subsequent regulatory development efforts

 Data from the 2013 CAA Section 114 survey of OSWRO facilities

3 .1 RACT/BACT/LAER Clearinghouse Database

Under the EPA's New Source Review (NSR) program, if a company is planning to build a new plant or modify an existing plant such that criteria air pollution emissions will increase by a certain amount, then the company must obtain an NSR permit. The NSR permit is a construction permit, which generally requires the company to minimize air pollution emissions by changing the process to prevent air pollution and/or installing air pollution control equipment.

The terms “ RA CT,” “BACT,” and “LAER” are acronyms for different program requirements relevant to the NSR program. RACT, or Reasonably Available Control Technology, is required

on sourc es in areas that are not meeting national ambient air quality standards (non-attainment areas). BACT, or Best Available Control Technology, is required on new or modified major sources in clean areas (attainment areas). LAER, or Lowest Achievable Emission Rate, is required on new or modified major sources in non-attainment areas.

BACT and LAER (and sometimes RACT) are determined on a case- by -case basis, usually by State or local permitting agencies. The EPA established the RACT/BACT/LAER Clearinghouse, or RBLC, to provide a central data base of air pollution technology information (including past BACT and LAER decisions contained in NSR permits) to promote the sharing of information among permitting agencies and to aid in future case- by -case determinations. However, data in the RBLC are not limited to sources subject to RACT, BACT, and LAER requirements. Noteworthy prevention and control technology decisions and information may be included even if they are not related to past RACT, BACT, or LAER decisions. 1



### The RBLC contains over 5,000 air pollution control permit determinations that can help identify appropriate technologies to mitigate most air pollutant emission streams. It was designed to help permit applicants and reviewers make pollution prevention and control technology decisions for stationary air pollution sources, and includes data submitted by several U.S. territories and all 50 States on over 200 different air pollutants and 1,000 industrial processes.

The RBLC provides several options for searching the permit database on-line to locate applicable control technologies. Our search of the RLBC specified processes in the Waste Disposal category, including Waste Combustion Processes, Wastewater/Contaminated

1 Te chnology Transfer Network: Clean Air Technology Center

. RACT/BACT/LAER Clearinghouse Basic Information. http://www.epa.gov/ttn/catc/rblc/htm/welcome_eg.html

.6



### Groundwater Treatment, and Other Waste Processing and Disposal, with permits dating back to

2001 . The search results included the following data fields:

 RBLC ID;

 Facility Name, and State;

 Permit Date;

 Process name;

 Throughput;

 Pollutant;

 Control technology; and

 Percent efficiency of control.

Based on the search conducted for facilities in the Waste Disposal category and the results obtained, it was difficult to discern which facilities and processes are related to OSWRO. Nonetheless, the results of the search are presented in Appendix 1 . As shown in Appendix 1, no

c ontrol technologies more stringent than the OSWRO NESHAP were identified through this search for tanks, containers, oil-water and organic-water separators, transfer systems, or surface

im poundments. Some of the control technologies shown in Appendix 1 could be applied to

proc ess vents, however most are not HAP emissions control devices. HAP emissions can be controlled with themal incineration, and we investigate the use of thermal oxidizers in Section

4.3 below.

3 .2 Subsequent Regulatory Development Efforts

The OSWRO MACT standards were promulgated in 1996. Since that time, the EPA has developed air toxics regulations for a number of additional source categories that emit organic

HA P from the same types of emission sources that are present in the OSWRO source category. In subsequent air toxic regulatory actions, the EPA consistently evaluated any new practices,

proc esses and control technologies. A review of these subsequent air toxics regulations, including supporting documentation used in the rulemakings, was conducted to determine if any practices, processes or control technologies could be applied to the OSWRO source category.

The technology review analyses for the National Uniform Emission Standards for Storage

Ve ssels and Transfer Operations, Equipment Leaks, and Closed Vent Systems and Control

De vices (“Uniform Standards”) (40 CF R part 65, subparts H, I, J and M), which were proposed on March 26, 2012, were also considered in this review. Although these analyse s a re not based directly on operations in the OSWRO source category, they are based on chemical manufacturing and refinery processes with similar types of equipment and emissions sources. Thus, it is expected that emissions control and compliance demonstration methods that have been

determined to be cost effective for control of one of the se emission points would generally be cost effective for similar emission points at OSWRO facilities.

P otential developments in practices, processes and control technologies were identified through the review of subsequent air toxics regulations and the proposed Uniform Standards for storage7



### tanks, equipment leaks and process vents. These are discussed further in Sections 4.1 for tanks,

4 .2 for equipment leaks and 4.3 for process vents.

3.3 2013 CAA Section 114 Survey

The EPA conducted a CAA section 114 survey of nine companies that own OSWRO facilities to assist the Agency in reviewing the emission standards for these operations. The EPA requested

spe cific detailed information from OSWRO facilities for their equipment leaks, tanks, containers, process vents, surface impoundments, oil-water and organic-water separators, and transfer systems. Data submitted to the EPA included information from 23 facilities on types of units and

proc esses at OSWRO facilities, emissions from different units, emissions release point

pa rameters, control measures, and control efficiency. The information collected from the ICR OSWRO survey was incorporated into this technology review to the extent that it was possible.

We analyzed the OSWRO data received from the 2013 ICR survey. While the information collected did not reveal any developments in emissions reduction practices, processes or control technologies, the data gathered included information useful in determining the potential emissions reductions and costs of emissions reduction practices, processes or control

tech nologies identified through review of subsequent regulatory development efforts.

4 .0 IDENTIFIED DEVELOPMENTS IN PRACTICES, PROCESSES AND

CONTROL TECHNOLOGIES AND ESTIMATED COST IMPACTS

Through searches of the data sources described in Section 3, several developments in practices,

proc ess or control technologies were identified for the OSWRO source category. The identified developments in practices, process and control technologies for tanks, equipment leaks and process vents are discussed below.

F or the remaining OSWRO HAP emissions release point types, we did not identify: any add-on control technology or other equipment that was not identified and considered during MACT development; any improvements in add-on control technology or other equipment (that was identified and considered during MACT development) that could result in significant additional HAP emission reduction; any work practice or operational procedure that was not identified and considered during MACT development; any process change or pollution prevention alternative that could be broadly applied that was not identified and considered during MACT development; or any significant changes in the cost (including cost effectiveness) of applying controls (including controls the EPA considered during MACT development).

4.1 Tanks

Tanks are used for many different applications at OSWRO facilities to accumulate, store or treat

off -site materials. The amount of HAP emissions from tanks depends on the type of organic

material in the tank, the type o f tank (e.g., fixed roof tanks, internal floating roof tanks, external floating roof tanks), the methods used to fill and empty the tank, and the number of turnovers per

year.8



### Emissions of organic HAP from fixed roof tanks and floating roof tanks are the result of working and breathing losses. Working losses occur when vapors are displaced by a rising level of liquid

in the tank. Breathing losses occur as a result of liquid level changes due to fluctuations in ambient temperature or pressure. The quantity of emissions from tanks depends greatly on the volatility of the organic material in the tanks and whether the tanks are vented to the atmosphere, equipped with a pressure-vacuum relief valve, vented to an air emission control device, or fitted with a floating roof.

4. 1 .1 Summary of Existing MACT Level of Control

The current OSWRO MACT standards for tanks require either Level 1 or Level 2 controls, depending on tank capacity and the vapor pressure of the materials in the tank. Tanks subject to Level 1 control requirements are required to be equipped with a fixed roof with a closure device

de signed to form a continuous barrier over the entire surface area of the liquid in the tank, with no visible cracks, holes, gaps, etc., between roof section joints or where the roof and tank wall meet. Openings in the roof mu st be equipped with a closure device or connected to a closed vent system and routed to a control device. The fixed roof and its closure devices are subject to routine visual inspection and repair.

The control requirements under Level 2 require one of the following five alternatives: (1) equip the fixed roof tank with an internal floating roof; (2) equip the fixed roof tank with an external floating roof; (3) equip the tank with a vapor-tight cover and vent to a control device that has an efficiency of 95 percent; (4) use a pressure tank; and (5) locate the tank inside a permanent total enclosure (PTE) that is vented to a combustion control device.

Tanks used to manage a waste stabilization process are subject to Level 2 requirements. Other tanks are subject to Level 1 or Level 2 controls as shown below in Table 2.

Table 2. Tank Control Levels for Tanks at Existing and New Facilities

Current MACT Requirements Applicability Threshold

Control Level Size ( m 3 

### ) Vapor Pressure ( kPa )

Existing Sources Less than 75 < 76.5 1

≥ 76.5 2 *

75 ≤ capacity < 151 < 4.0 1

≥ 4.0 2

151 ≤ capacity < 5.2 1

≥ 5.2 2

New Sources Less than 75 < 76.5 1

≥ 76.5 2 *

75 ≤ capacity < 151 < 27.6 1

≥ 27.6 2

151 ≤ capacity < 5.2 1

≥ 5.2 2

* Except that fixed roof tanks equipped with an internal floating roof and tanks equipped with an external floating roof shall not

be used9



### 4. 1

. 2 Identified Developments in Control Technologies for Tanks

For existing tanks, we identified two potential developments in existing practices and control techniques not currently required by the OSWRO MACT standards. Through the review of air toxics MACT standards developed subsequent to the OSWRO MACT standards, we noted that

se veral other MACT standards refer to the Hazardous Organic NESHAP (HON) for their storage

tank requirements. We evaluated revising the applicability of the OSWRO existing source requirements to use the same thresholds for Level 2 control as the thresholds for control required by the HON (Option 1). The difference between the existing OSWRO tank thresholds and the

HO N thresholds is that tanks of capacities of 75 cubic meters (m 3 

### ) and up to 151 m 3 

### would be required to use Level 2 control if the vapor pressure of the contents was 13.1 kilopascals (kPa) or

g reater, rather than the current OSWRO threshold level of 27.6 kPa or greater. Table 3 presents

a summary of the tank size and vapor pressure thresholds considered for existing sources. The new source thresholds under the existing OSWRO MACT standards and the HON are the same, so no revised applicability requirements were evaluated for tanks located at new sources.

While the use of a floating roof (internal or external), use of a pressure tank, or use of a PTE that is vented to a combustion control device are options for control allowed by the OSWRO MACT standards, information received from the industry as part of the CAA section 114 survey showed

that none of the surveyed facilities employed the use of floating roofs, pressure tanks, or PTEs

for their tanks, but instead had fixed roof tanks vented to control devices. Based on this information, we expect that the industry primarily uses fixed roof tanks vented to control devices. Although the other MACT standards we reviewed require the same emissions control

e fficiency (95 percent) for fixed roof tank control devices as the current OSWRO MACT standards, it is recognized that many devices are capable of achieving 98 percent emissions control or greater. Therefore, under Option 2 we considered the impacts of requiring a 98 percent emissions reduction for tanks along with the capacity and vapor pressure thresholds of Option 1.

Table 3. Storage Tank Size Applicability Threshold Alternatives

Regulatory Options Appl icability Threshold

Control

Level Option 1

Requirements Option 2

Requirements If Size ( m 3 

### ) is And Vapor

Pressure (kPa) is

Options 1 and

2 Less than 75 < 76.6 1 Fixed roof

≥ 76.6 2 a 

### 95% control b 

### 98% control b



### 75 ≤ capacity

< 151 < 13.1 1 Fixed roof

≥ 13.1 2 95% control b 

### 98% control b



### 151 ≤ capacity < 5.2 1 Fixed roof

≥ 5.2 2 95% control b 

### 98% control b

a Except that fixed roof tanks equipped with an internal floating roof and tanks equipped with an external floating

roof shall not be used

b Control efficiency would apply to tanks vented to a control device and tanks inside a PTE that are vented to a combustion control device; use of an internal or external floating roof or a pressure tank would still be available control options.10



### 4.1.3 Estimation of Tank Emissions

We analyzed the OSWRO CAA section 114 survey response data for tanks to estimate the number of tanks that would be captured under Option 1. We then estimated the emission potential from these tanks and the emission reductions that would occur under Options 1 and 2.

The first step was to estimate the number of tanks existing in the OSWRO source category. The

numbers of tanks within the three different Co ntrol Level 2 size and vapor pressure ranges shown in Table 3 were estimated using the OSWRO survey data, which was then scaled up to

na tionwide values based on the number of known OSWRO facilities. Table 4 shows the estimated number of tanks in each size and vapor pressure range and how each estimate was

calculated.

After estimating the OSWRO tank population, we estimated the emission potential from each

tank siz e and vapor pressure type using the EPA’s TANKS 4.09d 2 

### program, which is a software tool that calculates HAP emissions from fixed and floating roof tanks. The parameters shown in Table 5 were used as inputs to the TANKS program and were based primarily on information reported in the OSWRO CAA section 114 survey responses. The estimated emission potential for each tank size and vapor pressure type are also shown in Table 5. See Appendix 2 for more information on the inputs used and outputs obtained from the TANKS 4.09d program.

2 http://www.epa.gov/ttnchie1/software/tanks/11



### Table 4. Estimated OSWRO Ta nk Population Based on CAA 114 Survey Responses

Tank Size/Vapor Pressure (TS/VP) Estimated

Number of

Tanks in the

OSWRO

Source Category Explanation

TS/VP 1 

### ≥ 75 m 3 

### and ≥ 27.6

kPa 78 tanks Two of 15 facilities hav e tanks with this size and

vapor pressure. Total number of tanks for 2 facilities is 25, or 13 tanks per facility. Scaling up to 4 5 facilities, 2/15 x 4 5 = 6 facilities have

13 tanks each or 78 total tanks.

TS/VP 2 

### 75

- 151 m 3 

### and

13.1 ≤ kPa < 27.6 21 tanks One of 15 facilities ha s tanks with this size and vapor pressure. Total number of tanks for this facility is 7. Scaling up to 4 5 facilities, 1/15 x 45

= 3 facilities have 7 tanks or 21 total tanks.

TS/VP 3 

### ≥ 151 m 3 

### with kPa

≥ 5.2 8 tanks Three of 18 facilities have tanks with this size and vapor pressure. Total number of tanks for 3 facilities is 3, or 1 tank per facility. Scaling up to

4 5 facilities, 3/18 x 4 5 = 8 facilities have 1 tank

each or 8 total tanks. Number of tanks requiring

Level 2 control under current OSWRO requirements 86 tanks ( TS/VP 1 

### +TS/VP 3 

### )

Additional number of tanks requiring Level 2 control under Option 1 21 tanks ( TS/VP 2 

### )

Number of tanks requiring

Level 2 control and 98%

e mission reduction under Option 2 107 tanks ( TS/VP 1 

### +TS/VP 2 

### +TS/VP 3 

### )12 

### Table 5 . Estimation of Tank HAP Emission Potential

Size and Vapor

Pressure Range Capacity 1

( gal/ m 3 ) Height 1

(Ft) Diameter 1

(ft) Throughput

2 (gal) Tank

Contents Vapor

Pressure 3 Locati on 4 Tank HAP Contents 5 Speciated and Total

HAP Emission

Potential 6
(lb/yr)

T ank ≥ 75 m 3

and ≥ 27.6 kPa 30,000 gal

( 113.6 m 3 ) 26.6 15.1 5,140,411 4.37 Houston, TX 50% methylene chloride 13,357

12.5% trichloroethane (1,1,1) 1,023

12.5% tol uene 215

12.5% tetrachloroethylene 137

12.5% methanol 943

Total 15,675

T ank 75

- 151

m 3 and

13.1 < kPa a< 27.6 25,000 gal

( 94.6 m 3 ) 28.4 12.3 4,996,918 2.68 Houston, TX 20% methylene chloride 4,308

20% trichloroethane (1,1,1) 1 ,320

20% toluene 277 20% tetrachloroethylene 177

20% methanol 1,217

Total 7,300

T ank ≥ 151 m 3

and kPa ≥ 5.2 60,000 gal

( 227.1 m 3 ) 42 16.5 6,001,370 2.68 Houston, TX 20% methylene chloride 7,890

20% trichloroethane (1,1,1) 2,417

20% toluene 508
20% tetrachloroethylene 325

20% methanol 2,228

Total 13,368

1 Ca pacity, height and diameter based on average of CAA section 114 survey response data for tanks meeting these thresholds, except for 30,000 gal (113.6 m 3 ) tank -

av erage height and diameter used were the most commonly occurring values for tanks meeting these thresholds (the mode) because the average height and diameter produced a capacity larger than the average capacity.

2 Due to inadequate OSWRO survey response data (data not reported or units not reported), throughput estimated via linear interpolation from data reported in the supporting documentation for the proposed storage tank uniform standards (Memorandum from Randall, D., RTI International, to Parsons, N., EPA/OAQPS. Survey of Control Technology for Storage Vessels and Analysis of Impacts for Storage Vessel Control Options. January 20, 2012. EPA Docket No. EPA- HQ -OAR- 2010

- 0871

- 0027).

3 Vapor pressure was determined with TANKS4.0.9d based on the tank contents.

4 Location assumed as Houston based methodology used in the development of the proposed storage tank uniform standards (Memorandum from Randall, D., RTI International, to Parsons, N., EPA/OAQPS. Survey of Control Technology for Storage Vessels and Analysis of Impacts for Storage Vessel Control Options. January 20,

2012. EPA Docket No. EPA- HQ -OAR- 2010

- 0871 -0027).

5 An even split of the top 5 HAP was assumed where this split resulted in a vapor pressure in the appropriate range and an uneven split was assumed where an even split of the top 5 HAP did not result in a vapor pressure in the appropriate range.

6 Uncontrolled emissions from TANKS 4.0.9d.13



### To determine the emissions reduction that would be achieved under Option 1, we first

determined th e nationwide uncontrolled HAP emissions from the additional tanks that would require Level 2 co ntrol under Option 1. This was calculated u sing the estimated tank population ( TS/VP 2 

### ) shown in Table 4 and the uncontrolled HAP emissions per tank for this size and vapor pressure type shown in Table 5. This calculation is shown below :

Baseline HAP Emiss ions Tanks : 75

− 151 m3 and ≥ 13

. 1 kPa = 21 tanks × 7

, 300 lb

yr

2

, 000 lb

ton = 76

. 6 tpy



### The Option 1 emissions reduction requirement is 95 percent. Application of a 95 percent

emissions reduction to the uncontrolled emissions calculated above results in a reduction of

72.8 tons per year ( tpy )

.

To determine the emissions reduction that would be achieved under Option 2, we first

determined th e baseline nationwide HAP emissions from the OSWRO tanks that are currently controlled, together with the controlled emissions from the additional tanks that would require

L evel 2 control under Option 1. This was calculated u sing the estimated tank populations shown

in Ta ble 4, the uncontrolled HAP emissions per tank for each size and vapor pressure type shown

in Ta ble 5, and the application of 95 percent control to these uncontrolled HAP emissions estimates. The emissions that would occur with Option 2 controls were calculated in the same manner but with the application of 98 percent control to the uncontrolled HAP emissions

estimates. These calculations are shown below:

Baseline HAP Emissions = [(8 tanks × 13

, 368 lb

yr ) + ( 78 tanks × 15

, 675 lb

yr ) + ( 21 tanks × 7, 300 lb

yr )] × 0. 05

2, 000 lb

ton

= 37 .1 tpy

Option 2 HAP Emissions = [(8 tanks × 13

, 368 lb

yr ) + ( 78 tanks × 15

, 675 lb

yr ) + ( 21 tanks × 7, 300 lb

yr )] × 0. 02

2, 000 lb

ton

= 14 .8 tpy



### The additional reduction that would be achieved under Option 2 is the difference between the baseline emissions and the emissions that would occur under Option 2 controls, which is 22.3

tpy.

4.1

. 4 Estimation of Option 1 Costs

As described, Option 1 considers lowering the vapor pressure threshold to apply to more storage tanks, which requires additional storage tanks to control emissions with Level 2 controls. To

e stimate the costs for requiring these additional storage tanks to use Level 2 controls, it was

a ssumed that the emissions from these tanks would be routed to an existing control device at the facility already used to control emissions from other tanks, and the only additional costs14



### associated with Option 1 are for ductwork for the estimated 21 additional tanks that would be captured under the new vapor pressure threshold. Based on information contained in the EPA Air

Pollution Control Cost Manual 3 

### , the nationwide capital costs associated with the additional ductwork were estimated at $76,412 with nationwide annual costs of $20,797. See Appendix 3

for more information about how these costs were determined. The annual HAP emissions reduction from Option 1 is estimated to be 72.8 tpy, and the annual cost per ton of HAP removed is estimated to be $286.

4.1. 5 Estimation of Option 2 Costs

Under Option 2, we considered the impacts of requiring a 98 percent emissions reduction for tanks meeting the capacity and vapor pressure thresholds under Option 1, assuming a

re cuperative thermal oxidizer ( RCO ) would be used to attain this increased level of control. The capital and annual costs of an RCO were estimated in order to determine the cost effectiveness of achieving 98 percent emissions reduction from storage tanks. The majority of the cost

c alculations were based on data in the EPA Air Pollution Control Cost Manual 3 

### . In addition, the median flowrate from tanks from OSWRO facilities using a thermal oxidizer (729 scfm) was

use d in the cost calculation. Using the top five HAP emitted from tanks based on the OSWRO CAA section 114 survey response data, the total emissions rate and heat content were calculated.

F or this analysis, it is assumed that

, due to the relatively low emissions flowrate from tanks at OSWRO facilities, an RCO would be used as the control device and that the RCO would operat e

c ontinuously throughout the year. In addition, the analysis included costs for 10 facilities, based on the OSWRO CAA section 114 survey response data, which showed that only 10 facilities in

the sour ce category have tanks that require Level 2 controls 4 

### and would be required to comply with Option 2.

The nationwide capital costs associated with Option 2, including an RCO and required ductwork to route tank emissions to the control device at 10 facilities were estimated at $2.8 million, with nationwide annual costs of $1.3 million. See Appendix 4 for more information about how these costs were determined. The annual HAP emissions reduction from Option 2 is estimated to be 22.3 tpy, and the annual cost per ton of HAP removed is estimated to be $13,000. The estimated incremental cost effectiveness above Option 1 is $56,000 per ton of HAP removed.

3 EPA Control Cost Manual, Section 3.2 VOC Destruction Controls, Chapter 2 Incinerators, January 2002
(EPA/452/B- 02

- 001)

. 4 Based on CAA section 114 survey responses that indicate 4 of 18 facilities have tanks that currently require control, scaled up to 45 facilities (45/18*4)=10 facilities.15



### Table 6. Nationwide Costs and Emission Reductions of Regulatory Alternatives for Tanks

Regulatory

Alternative HAP

Emission s Reduction (tpy) Capital

Cost ($) Annual

Costs ($/yr) Cost

Effectiveness ($/ton HAP) Incremental

Cost

Effectiveness ($/ton HAP)

Option 1: (HON

TS/ VP thresholds, 95% control) 1 72.8 $76,412 $20,797 $286

-----

Option 2: (HON TS/ VP thresholds, 98% control) 2 22. 3 $2,754,200 $1,271,946 $13,382 $56,249

1 This option assumes tanks requiring control will be routed to an existing control device at the facilities. The costs are for

ductwork to those device s.

2 This option assumes an RCO would be used to control tank emissions. Costs are for RCOs and associated ductwork to the devices. Costs for ductwork per tank are the same as those estimated for Option 1.



### 4. 2 Equipment Leaks

Equipment leaks are emissions emanating from leaking pieces of equipment, such as pumps, compressors, agitators, pressure relief devices, sampling connection systems, open-ended valves or

li nes, valves, connectors, surge control vessels, bottoms receivers, and instrumentation systems in organic HAP service; and any control devices or systems required by subpart DD for these pieces of

e quipment. The amount of HAP emissions from equipment leaks is proportional to the type and number

of pieces of equipment and the concentration of HAP constituents of the stream passing through the equipment.

4.2.1 Summary of Existing MACT Level of Control

The OSWRO MACT standards for equipment leaks apply to the group of all equipment, with a total HAP concentration of 10 percent by weight or more for 300 hours per calendar year or more, intended to

ope rate in off-site material service. 5 

### For all of the equipment in off-site waste service subject to the

standa rds , the owner or operator must choose to comply with the leak detection and repair requirements ( LDAR) of either 40 CFR part 61, subpart V or 40 CFR part 63, subpart H. The primary provisions of

these subparts are shown in Table 7.

5 In off-site material service is defined in subpart DD (§63.681) as any time a piece of equipment either contains or contacts

off-site material.16



### Table 7 . Primary Provisions from Part 61, subpart V and Part 63, subpart H

Equipment Type 40 CFR part 61

s ubpart V 40 CFR part 63

s ubpart H

Valves in gas / vapor service and light liquid service C onduct EPA Method 21 monitoring and leak definition of 10,000 ppm (monthly or less often up to quarterly depending on leak rate) Same as Part 61, Subpart V but

with leak defi nition of 500 ppm (monthly or less often up to annually depending on leak

rate)

Pumps in light liquid service Conduct monthly EPA Method 21 monitoring

and a leak definition of

1 0 ,000 ppm Same as Part 61, Subpart V but

with leak definition of 1,000 ppm and repair required at 2,000 ppm

Connectors in gas/vapor and light liquid service Sensory monitoring (visual, audible, olfactory) (type of service is not specified, no monitoring schedule specified) Conduct EPA Method 21 monitoring with leak definition

of 50 0 ppm annually (or less often up to once every 4 years depending on leak rate)

Pressure relieve devices in gas/vapor

service O perate with no detectable emissions (i.e., less than 500 ppm above background ) or equipped with a rupture disk or

routed to an a ir pollution

control device Same as Part 61, Subpart V

Open

- ended valves or lines E quip with a cap, blind flange, plug or second

valve Same as Part 61, Subpart V

4.2.2 Identified Developments in Control Technologies for Equipment Leaks

For equipment leaks at existing and new facilities, no entirely new developments in methods for controlling equipment leak emissions at OSWRO facilities were found. However, during our review of regulatory development efforts for other rules, we found LDAR programs that incorporate more string ent leak detection limits than the OSWRO MACT standard. As discussed in the documentation for the proposed Uniform Standards for equipment leaks, leak definitions of 500 parts per million (ppm) for

va lves in gas and vapor and in light liquid service,1,000 ppm for pumps in light liquid service and 500 ppm for connectors in gas and vapor and in light liquid service are the leak definitions currently required

for facilities subject to certain existing rules and were considered as regulatory options for the proposed Uniform Standards for equipment leaks. These leak definitions are the same as those required by 40

C FR part 63 subpart H. Consequently, we investigated the se leak definition requirements to determine whether they would be cost effective to implement for the OSWRO source category. As it is possible

that it may be cost effective to monitor only certain equipment at certain levels, the analysis included indepe ndent calculations of the cost effectiveness of monitoring these three eq uipment types (valves in gas/vapor and in light liquid service, pumps in light liquid service, and connectors in gas/vapor and in

li ght liquid service ) a t the alternative levels. Also, as instrument monitoring of connectors can be an17



### expensive component to an LDAR program, the costs of an LDAR program with the more stringent leak

de finitions were considered both without instrument connector monitoring (Option 1) and with instrument connector monitoring (Option 2). This investigation was performed under consideration of

whether there have been “A ny significant changes in the cost (including cost effectiveness) of applying controls (including controls the EPA considered during the development of the original MACT standards) .”

Table 8 presents a summary of the equipment leak options that were analyzed. This table only shows

pumps in light liquid service and valves and connectors in gas and vapor and light liquid service, since

the r equirements for the other types of equipment are largely the same under 40 CF R part 61, subpart V and 40 CFR part 63, subpart H, as shown in Table 7. As a result, those equipment types were not further analyzed in this comparison of emissions reductions and costs for Options 1 and 2.

Table 8. Summary of Equipment Leak Options for the OSWRO Source Category

Type of Equipment Subpart V

(Baseline) Alternative Options 

### Subpart H

w/o connectors

(Option 1) Subpart H

w/connectors

(Option 2)

Pumps Monthly Method 21

monitoring; leak definition of 10,000 ppm Monthly Method 21

monitorin g; leak definition of 1,000 ppm

(repair at 2,000 ppm) Monthly Method 21 monitoring; leak definition of 1,000 ppm

(repair at 2,000 ppm)

Valves Monthly Method 21

monitoring; leak definition of 10,000 ppm Monthly Method 21 monitoring;

leak definition of 500 ppm Monthly Method 21 monitoring; leak definition of 500 ppm

Connectors Sensory

Monitoring Sensory Monitoring I nstrument monitoring for

connectors in gas/vapor and light liquid service at 500

ppm



### 4.2.3 Alternative Means of Compliance by Equipment Type and for Entire LDAR Program

An analysis of the emissions reductions and costs of the options identified for equipment leaks was performed. Cost estimates and emissions reductions for the two control options were estimated using a model plant approach to represent equipment counts found at OSWRO facilities. The median number of pieces of equipment was estimated from the reported data available from the OSWRO CAA section 114

survey. Table 9 presents the median model plant equipment counts for estimating equipment leak impacts from the OSWRO source category.18 

### Table 9 . Model Plant for OSWRO Equipment Type Number of Pieces of Equipment a 

### Pumps (light liquid service) 27 Valves (light liquid service) b 

### 910 Connectors ( in gas/vapor and light liquid service) 1,350

a The number of pieces of equipment is based on the median value reported by facilities in OSWRO CAA section

114 survey.

b The type of service a valve was in (gas/vapor or light liquid) was not discernible from the CAA section 114 survey responses, and based on the process types present at OSWRO facilities, it was assumed the reported valves were in light liquid service



### .



### Next, using the number of pieces of equipment in Table 9

, emission factors were applied to determine the baseline emissions and the emissions under Options 1 and 2 that would be expected by equipment type. For the baseline, we assumed facilities are complying with 40 CFR part 61, subpart V based on information from the section 114 questionnaire responses, which indicate that most facilities comply with this option. The emission factors were multiplied by the number of pieces of equipment of that type

a t the OSWRO model plant and converted to tons per year (tpy) to arrive at the total emissions in tpy at

the ba seline (40 CFR part 61, subpart V) and for Options 1 and 2 (40 CFR part 63, subpart H with and

without connector monitoring). These emissions factors were based on those used in the Uniform Standards for equipment leaks analysis, but because the factors used in that analysis are for total organic compounds, which for OSWRO facilities are generally volatile organic compounds (VOC), these factors were modified to reflect the amount of VOC that are expected to be HAP. The VOC emission factors were adjusted to HAP emission factors using the HAP to VOC ratio of 82 percent for equipment leaks from the OSWRO MACT development Background Information Document (BID). 6 

### The resulting emissions factors used for the OSWRO source category are shown in Table 10

.

Table 10

. Equipment Leak HAP Emission Factors by Equipment Type 7



### Type of Equipment Emission Factor (kg/hr/ equipmen t piece )

Baseline Option 1/Option 2 Pump Seals

– Light Liquid Service 2.05 E

- 03 5.69 E

- 04

Valves

- Light Liquid Service 3

. 19 E

- 04 1. 90 E

- 04

Connectors

– Gas/Vapor and Light Liquid Service 2. 51 E

- 04 2.51 E

- 04 / 1.33 E

- 0 4

Table 11 shows the amount of HAP estimated at the baseline and considering the more stringent leak definitions for each piece of equipment. This table also shows the total HAP emissions expected at the baseline and under LDAR program Options 1 and 2 for these equipment types.

To de termine the costs of the LDAR program at the baseline and for Options 1 and 2, the approach taken was the approach used for the Uniform Standards for equipment leaks analysis. In determining the costs for the OSWRO source category, the same leak rates, repair times, labor charges and other

6 Off-Site Waste and Recovery Operations Background Information for Proposed Standards. EPA-453/R- 94

- 070a . September

1994.

7 See Table 6 of Memorandum from Hancy, C., RTI International, to Howard, J., EPA/OAQPS. Analysis of Emission Reduction Techniques for Equipment Leaks. December 21, 2011. EPA Docket No. EPA- HQ -OAR- 2010

- 0869 -0029. A HAP to VOC ratio of 0.82:1 was applied to these Table 6 values.19



### administrative and miscellaneous costs were assumed (see Appendix 5 for more detailed cost

information ). Table 10 shows the costs and cost effectiveness by equipment types and as a total for all three equipment types for each option. The cost effectiveness of Option 1 is $979, and for Option 2 the

c ost effectiveness is $3,869. The incremental cost effectiveness of Option 2 is $6,715.20 

### Table 11

. Summary of Cost Effectiveness Analysis for Pumps, Valves and Connectors

Type of equipment Cost Parameter 

### Model Plant OSWRO Source Category (4 5 Facilities)

Baseline (subpart V) a 

### Option 1 (subpart H, w/o connectors) b 

### Option 2

(su bpart H, w/connectors) c 

### Baseline

(subpart V) a 

### Option 1

(subpart H, w/o connectors) b 

### Option 2

(subpart H, w/connectors) c



### Pumps in light liquid

service HAP Emissions 0.5 0.1 24. 1 6. 7

HAP Emission Reduction From Baseline

-- 0.4

-- 17. 4
Capital Cost Above Baseline

-- $4,009

-- $18 0,415

Annualized Cost Above Baseline

-- $808

-- $36

, 362

Cost Effectiveness

-- $2,087

-- $2,087

Valves in light liquid

service HAP Emissions 2.8 1.7 12 6.2 75.1

HAP Emission Reduction From Baseline

-- 1.1

-- 5 1.1
Capital C ost Above Baseline

-- $3,059

-- $1 37,662

Annualized Cost Above Baseline

-- $684

-- $3 0,758

Cost Effectiveness

-- $602

-- $602

Connectors HAP Emissions 3.3 3.3 1.7 147.3 1 47.3 77.8

HAP Emission Reduction From Baseline

-- -- 1.5

-- -- 69.6
Capital C ost Above Baseline

-- -- $34,186

-- -- $1,5 38

, 356

Annualized Cost Above Baseline

-- -- $10,384

-- -- $46 7, 300

Cost Effectiveness

-- -- $6,715

-- -- $6,715

Total LDAR Program Cost HAP Emissions 6.6 5.1 3.5 297.6 297.6 159.5

HAP Emission Reduction Fro m Baseline

-- 1.5 3.1

-- 68.5 1 38.1

Incremental Emission Reduction (baseline  option 1, option 1

-- >2) -- 1.5 1.5

-- 68.5 69.6

Capital Cost Above Baseline d



### -- $7,068 $41,254

-- $3 18,076 $1,8 56,433

Annualized Cost $5,576 $7,068 $17,452 $25 0

, 932 $ 318,052 $4 6 7, 300

Annualized Cost Above Baseline

-- $1,492 $11,876

-- $6 7

, 120 $5 34, 420

Cost Effectiveness

-- $979 $3,869

-- $979 $3,869

Incremental Cost Effectiveness (baseline  option 1, option 1

-- >2) -- $979 $6,715

-- $979 $6,715

a Baseline is associated with 40 CFR part 61, subpart V compliance required by subpart DD (pumps: 10,000 ppm, valves: 10,000 ppm, connectors: sensory monitoring).

b Option 1 is associated with 40 CFR part 63, subpart H level of control for pump and valves only (pumps: 2,000 ppm, valves: 500 ppm).

c Option 2 is associated with 40 CFR part 63,subpart H level of control for pumps, valves, and connectors (pumps: 2,000 ppm, valves: 500 ppm) and instrument monitoring for connectors at 500 ppm.

d Capital costs are the initial monitoring costs.21



### 4. 3 Process Vents

At OSWRO facilities, waste treatment processes are commonly employed when managing off-site

mate rials containing organic compounds. Examples of these treatment processes include distillation units, thin-film evaporators, solvent extraction units, air stripping units, and steam stripping units. Emissions from these types of waste treatment processes primarily occur through the process vent.

A process vent is a pipe, stack, duct, or similar opening through which gases and vapors generated in a process unit or waste management unit are exhausted to the atmosphere. Organic HAP emissions from process vents result primarily from venting organic vapors and evacuation of equipment for vacuum processing. These emissions occur at the point at which the organic-containing vapors and gases exit the process vent outlet into the atmosphere. Included in th e OSW RO source category are the organic HAP emissions from process vents on waste management operations (e.g., distillation process, steam stripping process). Processes which burn waste or recoverable material (e.g., incinerators, boilers, furnaces) are

not i ncluded in OSWRO source category and are not subject to the OSWRO MACT standards, but emissions from these processes are regulated by other standards.

Controlling organic emissions from process vents requires routin g the organic HAP vapors and gases from the process vent through a closed vent system to an organic emissions control device. Considering

the ve nt stream characteristics, the control devices most likely to be used to control organic HAP

e missions from OSWRO facilities are carbon adsorbers, condensers, flares, and vapor incinerators (e.g.,

ther mal oxidizers).

4.3.1 Summary of Existing MACT Level of Control

The current OSWRO MACT requirements for process vents are to route emissions through a closed vent

s ystem to a control device which achieves an emission reduction equal to or greater than 95 percent, or, prior to placing the material in the process equipment associated with the process vent, determine that the average volatile organic HAP (VOHAP) concentration of the off-site material is less than 500 ppm by weight at the point of delivery.

4. 3.2 Identified Control Technologies for Process Vents

As stated above, one compliance option in the current OSWRO MACT requirements for process vents is to route emissions through a closed vent system to a control device which achieves an emission reduction equal to or greater than 95 percent. Therefore, we focused on developments that would

a chieve greater than 95 percent emissions reduction. Through the review of air toxics MACT standards developed subsequent to the OSWRO MACT standards, we noted that several other MACT standards require 98 percent HAP emissions reduction from process vents, such as the MACT standards for Polyether Polyols Production and for Pesticide Active Ingredient Production. Consequently, we investigated increasing the HAP emissions destruction efficiency requirement to 98 percent to determine whether it would be cost effective to implement for the OSWRO source category. This analysis estimates the emissions reductions and costs of increasing the control efficiency from 95 percent to 98 percent for process ven ts , assuming the use of a thermal oxidizer to achieve this HAP emissions

de struction efficiency.22



### Available data from the 2013 OSWRO CAA section 114 survey of facilities that currently use a thermal

oxidizer were used to estimate the baseline HAP emissions per facility. Five OSWRO facilities were identified that currently us e thermal oxidizers to control their process vent emissions and comply with

the e xisting rule. Table 12 lists the facilities with thermal oxidizers and the reported and estimated

emissions at different control levels from these five facilities.

T able 1 2

. OSWRO Facilities with Thermal Oxidizer for Process Vent Emissions

Facility Reported

Em issions (tpy) Estimated

Uncontrolled

Emissions (tpy) Estimated

Emissions

at 9 5 %

Control (tpy) Estimated

Emissions

at 98%

Control (tpy) Estimated

Emission

Reduction (95% to 98%) (tpy)
Clean Harbors, Ohio 3 291 14.6 5.8 8.8 Hydrite Ch emical 1. 8 35 1.8 0.7 1.1 Safety

- Kleen, Smithfield 1.7 42.5 2.1 0.9 1.2 Safety

- Kleen, Dolton 0.4 8 0.4 0.2 0.2 Safety

- Kleen, Denton 11 220 11 4.4 6.6

Median 1. 8 42.5 2.3 0. 9 1.2

Reported emissions in Table 12 are the emissions in tons per year reported by each facility in the CAA

se ction 114 survey responses. Uncontrolled emissions were calculated using the reported emissions and

re ported control efficiency. The reported control efficiencies were 98.95 percent for the Clean Harbors, Ohio facility, 96 percent for the Safety Kleen, Smithfield facility, and 95 percent for the other Safety Kleen and Hydrite facilities. The HAP emissions reductions at 95 and 98 percent reduction were then

e stimated based on the uncontrolled emissions, and the estimated emissions reductions between 95 and 98 pe rcent control were calculated.

The capital and annual costs of a thermal oxidizer were estimated in order to determine the cost

e ffectiveness of achieving 98 percent HAP emissions reduction from process vents. The majority of the

cost calculations were based on data in the EPA Control Cost Manual. 8 

### However, some inputs to the cost estimation calculations were based on the 2013 OSWRO CAA section 114 survey response data. These inputs include the median flowrate from process vents at OSWRO facilities using a thermal

oxidizer (25,000 standard cubic feet per minute (scfm )) and the emission rate and heat content of toluene (the top emitt ed HAP from process vents reported in the survey response data) were used to estimate the waste gas heat content. It was assumed that the thermal oxidizer would operate continuously, at 8,760 hrs/yr, achieving a 98 percent reduction in HAP emissions. We estimated the costs associated with a regenerative thermal oxidizer, rather than other types of thermal oxidizers, due to the magnitude of the

proc ess vent flowrate from OSWRO facilities and the estimated costs of natural gas needed to operate

the de vices (see Appendix 6 for detailed cost information). In addition, the analysis included costs for 8

fa cilities, based on the OSWRO CAA section 114 survey response data, which showed that only 18

8 EPA Control Cost Manual, Section 3.2 VOC Destruction Controls, Chapter 2 Incinerators, January 2002 (EPA/452/B- 02 -001).23



### facilities in the source category have OSWRO process vents 9 

### and that only 8 of those would need to install new equipment to meet the 98% control requirement 10



### .

A summary of the thermal oxidizer costs are provided in Table 13, along with the calculated cost

effectiveness. The total annual costs for the OSWRO source category are $3.3. million, the HAP emissions reduction beyond the current control requirements i s 9.6 tpy, and the cost effectiveness is $ 346,409.

Table 13. Estimated Costs Associated with a

98% HAP Emissions Reduction from OSWRO Process Vents

Cost Parameter s 1 

### Model Plant

Cost

Estimate OSWRO

Source Category 2



### Total capital investment ($) 1,229,335 9,834,680

Labor ($/yr) 3 

### 34,472 275,776
Maintenance materials ($/yr) 15,875 127,000

Natural gas ($/yr) 4 

### 91,770 734,160

Electricity ($/yr) 5 

### 57,328 458,624
Overhead ($/yr) 29,009 232,072 Taxes, insurance, administrative ($/yr) 49,173 393,384

Capital recovery ($/yr) 134,974 1,079,792

Ducts 5,089 40,712 Total annual cost ($/yr) 415,691 3,325,528
Incremental emission reduction (from 95% to 98%) (tpy) 1. 2 9.6 Incremental cost effectiveness (from 95% to 98%) ($/ton
HAP) 346

, 409 346,409

1 Costs are in 2012 dollars.

2 Based on an estimated 8 facilities in the source category that would need to install new equipment to meet the 98% control requirement.

3 Labor rates based on May 2012 National Industry-Specific Occupational Employment and Wage Estimates NAICS 325000 - Chemical Manufacturing http://www.bls.gov/oes/current/naics3_325000.htm.

4 2012 Natural Gas Prices: http://www.eia.gov/dnav/ng/ng_pri_sum_dcu_nus_a.htm

. 5 2012 Table 5.3. Average Retail Price of Electricity to Ultimate Customers: Industrial http:// www.eia.gov /electricity/monthly/epm_table_grapher.cfm?t=epmt_5_3.

9 Based on CAA section 114 survey responses that indicate 7 of 18 facilities have any OSWRO process vents that currently requir e control, scaled up to 45 facilities (45/18*7)=17.5 or 18 facilities.

10 Based on CAA section 114 survey responses that indicate 3 of 7 facilities with OSWRO process vents do not achieve 98% control or above, scaled up to 18 facilities (3/7*18)=7.7 or 8 facilities.A1-1 

# Appendix 1: Results of RBLC Database Queries

Table 1. Control Technologies Identified for OSWRO Processes in the July 20, 2012, Query of the RBLC Database

RBLCID Facility Name ST Process Name Throughput Throughput

Unit Control Method Emission

Reduction (%)

Emission Process Group: Off

- site Material Treatment a

MI

- 0297 MINERGY DETROIT LLC MI SLUDGE INCINERATOR/GLASS

FURNACE 27.6 T/H @ 10%

H2O BAGHOUSE. 99.9

MI

- 0329 THE DOW CHEMICAL

COMPANY MI INCINERATOR, ROTARY KILN,

HAZARDOUS WASTE 130 MMBTU/H VENTURI, IWS

. 99.9

MI

- 0329 THE DOW CHEMICAL

COMPANY MI INCINERAT OR, ROTARY KILN,

HAZARDOUS WASTE 130 MMBTU/H VENTURI, IWS. 99.9

MI

- 0329 THE DOW CHEMICAL

COMPANY MI INCINERATOR, ROTARY KILN,

HAZARDOUS WASTE 130 MMBTU/H VENTURI, IWS . INPUT FEED LIMIT 280 LB/H. 99.9

MI

- 0329 THE DOW CHEMICAL

COMPANY MI INCINERATOR, ROT ARY KILN,

HAZARDOUS WASTE 130 MMBTU/H VENTURI AND IWS

. 99.9

MI

- 0329 THE DOW CHEMICAL

COMPANY MI INCINERATOR, ROTARY KILN,

HAZARDOUS WASTE 130 MMBTU/H VENTURI, IWS

. 99.9

AR

- 0076 U.S. ARMY, PINE BLUFF

ARSENAL AR BRINE REDUCTION AREA SN

PBCDF

- 07 0.01 MMDS CF/H BAGHOUSE. 99.9

AR

- 0076 U.S. ARMY, PINE BLUFF

ARSENAL AR INCINERATOR COMMON

STACK SN

- PBCDF

- 01 40 ROCKETS/H CYCLONE FOLLOWED

BY VENTURI

SCRUBBER 99.8

MI

- 0329 THE DOW CHEMICAL

COMPANY MI INCINERATOR, ROTARY KILN,

HAZARDOUS WASTE 130 MMBTU/H CAUSTIC/WET

SCRUBBERS 99.7

MI

- 0297 MINERGY DETROIT LLC MI SLUDGE INCINERATOR/GLASS

FURNACE 27.6 T/H @ 10%

H2O QUENCH,

BAGHOUSE. 99A1-2

RBLCID Facility Name ST Process Name Throughput Throughput

Unit Control Method Emission

Reduction (%)

MI

- 0297 MINERGY DETROIT LLC MI SLUDGE INCINERATOR/GLASS

FURNACE 27.6 T/H @ 10%

H2O QUENCH,

BAGHOUSE. 99

MI

- 0297 MINERGY DETROIT LLC MI SLUDGE INCINERATOR/GLASS

FURNACE 27.6 T/H @ 10%

H2O BAGHOUSE

. 99

MI

- 0297 MINERGY DETROIT LLC MI SLUDGE INCINERATOR/GLASS

FURNACE 27.6 T/H @ 10%

H2O BAGHOUSE

. 99

MI

- 0297 MINERGY DETROIT LLC MI SLUDGE INCINERATOR/GLASS

FURNACE 27.6 T/H @ 10%

H2O BAGHO USE 99

MI

- 0297 MINERGY DETROIT LLC MI SLUDGE INCINERATOR/GLASS

FURNACE 27.6 T/H @ 10%

H2O BAGHOUSE 99

NV

- 0047 NELLIS AIR FORCE BASE NV GROUND WATER AND SOIL

REMEDIATION INCINERATION 99

NV

- 0047 NELLIS AIR FORCE BASE NV GROUND WATER AND SOIL

REMEDIAT ION INCINERATION 99

NE

- 0029 ABENGOA BIOENERY

CORPORATION

- YORK NE FERMENTATION AND

DISTILLATION WET SCRUBBERS 98

IL

- 0085 ARCHER DANIELS

MIDLAND COMPANY IL CARBON FURNACES, 3 EACH OXIDIZER SYSTEM 98

OH

- 0281 RUMPKE SANITARY

LANDFILL, INC OH EXIS TING SOLID WASTE

DISPOSAL WITH LANDFILL

GAS GENERATION 32272000 TONS OF

WASTE ACTIVE GAS

COLLECTION AND

CONTROL SYSTEM 98

a Off-site material treatment processes are processes in which an off-site material stream is physically, chemically, thermally, or biologically treated to destroy, degrade, or remove HAP contained in the off-site material for the purposes of complying with the standard.

# Appendix 2:

Tanks 4.0.9d Emissions Report (25,000, 30,000 and 60,000 gallon tanks)TANKS 4.0 Report



### TANKS 4.0.9d

Emissions Report - Detail Format
Tank Indentification and Physical Characteristics

Identification

User Identification: 3 City:

State: Company: Type of Tank: Vertical Fixed Roof Tank Description:

Tank Dimensions Shell Height (ft): 28.40 Diameter (ft): 12.30 Liquid Height (ft) : 25.60 Avg. Liquid Height (ft): 25.60 Volume (gallons): 22,754.81

Turnovers: 219.60 Net Throughput(gal/yr): 4,996,918.00

Is Tank Heated (y/n): N

Paint Characteristics

Shell Color/Shade: White/White

Shell Condition Good

Roof Color/Shade: Aluminum/Diffuse

Roof Condition: Good

Roof Characteristics Type: Cone Height (ft) 0.00 Slope (ft/ft) (Cone Roof) 0.06

Breather Vent Settings Vacuum Settings (psig):

- 0.03 Pressure Settings (psig) 0.03

Meterological Data used in Emissions Calculations: Houston, Texas (Avg Atmospheric Pressure = 14.7 psia)



### TANKS 4.0.9d

Emissions Report - Detail Format
Liquid Contents of Storage Tank

3 - Vertical Fixed Roof Tank

Daily Liquid Surf. Temperature (deg F) Liquid

Bulk Temp Vapor Pressure (psia) Vapor

Mol. Liquid

Mass Vapor

Mass Mol. Basis for Vapor Pressure

Mixture/Component Month Avg. Min. Max. (deg F) Avg. Min. Max. Weight. Fract. Fract. Weight Calculations

even mix small tank All 72.92 65.30 80.54 69.22 2.6822 2.1986 3.2542 71.0958 74.22

Methyl alcohol 2.1414 1.7006 2.6760 32.0400 0.2000 0.1667 32.04 Option 2: A=7.897, B=1474.08, C=229.13

Methylene chloride 7.5819 6.3760 8.9687 84.9400 0.2000 0.5902 84.94 Option 2: A=7.409, B=1325.9, C=252.6

Tetrachloroethylene 0.3118 0.2457 0.3925 165.8300 0.2000 0.0243 165.83 Option 2: A=6.98, B=1386.92, C=217.53

Toluene 0.4878 0.3886 0.6077 92.1300 0.2000 0.0380 92.13 Option 2: A=6.954, B=1344.8, C=219.48

Trichloroethane (1,1,1) 2.3228 1.9033 2.8204 133.4200 0.2000 0.1808 133.42 Option 2: A=8.643, B=2136.6, C=302.8



### TANKS 4.0.9d

Emissions Report - Detail Format
Detail Calculations (AP-42)

3 - Vertical Fixed Roof Tank

Annual Emission Calcaulations

Standing Losses (lb): 419.0818 Vapor Space Volume (cu ft): 347.9283 Vapor Density (lb/cu ft): 0.0334 Vapor Space Expansion Factor: 0.1401 Vented Vapor Saturation Factor: 0.7061

Tank Vapor Space Volume: Vapor Space Volume (cu ft): 347.9283

Tank Diameter (ft): 12.3000TANKS 4.0 Report

Vapor Space Outage (ft): 2.9281 Tank Shell Height (ft): 28.4000 Average Liquid Height (ft): 25.6000 Roof Outage (ft): 0.1281

Roof Outage (Cone Roof) Roof Outage (ft): 0.1281 Roof Height (ft): 0.0000 Roof Slope (ft/ft): 0.0625

Shell Radius (ft): 6.1500

Vapor Density Vapor Density (lb/cu ft): 0.0334 Vapor Molecular Weight (lb/lb-mole): 71.0958 Vapor Pressure at Daily Average Liquid

Surface Temperature (psia): 2.6822 Daily Avg. Liquid Surface Temp. (deg. R): 532.5909 Daily Average Ambient Temp. (deg. F): 67.9125

Ideal Gas Constant R

(psia cuft / (lb-mol-deg R)): 10.731 Liquid Bulk Temperature (deg. R): 528.8925

Tank Paint Solar Absorptance (Shell): 0.1700

Tank Paint Solar Absorptance (Roof): 0.6000 Daily Total Solar Insulation

Factor (Btu/sqft day): 1,405.5061

Vapor Space Expansion Factor Vapor Space Expansion Factor: 0.1401 Daily Vapor Temperature Range (deg. R): 30.4934 Daily Vapor Pressure Range (psia): 1.0556

Breather Vent Press. Setting Range(psia): 0.0600 Vapor Pressure at Daily Average Liquid

Surface Temperature (psia): 2.6822 Vapor Pressure at Daily Minimum Liquid

Surface Temperature (psia): 2.1986 Vapor Pressure at Daily Maximum Liquid

Surface Temperature (psia): 3.2542 Daily Avg. Liquid Surface Temp. (deg R): 532.5909 Daily Min. Liquid Surface Temp. (deg R): 524.9676 Daily Max. Liquid Surface Temp. (deg R): 540.2143 Daily Ambient Temp. Range (deg. R): 21.3083

Vented Vapor Saturation Factor Vented Vapor Saturation Factor: 0.7061 Vapor Pressure at Daily Average Liquid:

Surface Temperature (psia): 2.6822 Vapor Space Outage (ft): 2.9281

Working Losses (lb): 6,880.6628 Vapor Molecular Weight (lb/lb-mole): 71.0958 Vapor Pressure at Daily Average Liquid

Surface Temperature (psia): 2.6822

Annual Net Throughput (gal/yr.): 4,996,918.0000

Annual Turnovers: 219.5983

Turnover Factor: 0.3033 Maximum Liquid Volume (gal): 22,754.8127 Maximum Liquid Height (ft): 25.6000

Tank Diameter (ft): 12.3000 Working Loss Product Factor: 1.0000

Total Losses (lb): 7,299.7446



### TANKS 4.0.9d

Emissions Report - Detail Format

Individual Tank Emission Totals

Emissions Report for: Annual

3 - Vertical Fixed Roof Tank

Losses(lbs)

Components Working Loss Breathing Loss Total Emissions

even mix small tank 6,880.66 419.08 7,299.74

Methylene chloride 4,061.14 247.35 4,308.49

Trichloroethane (1,1,1) 1,244.18 75.78 1,319.96

Toluene 261.30 15.92 277.21

Tetrachloroethylene 167.02 10.17 177.19

Methyl alcohol 1,147.02 69.86 1,216.88TANKS 4.0 Report



### TANKS 4.0.9d

Emissions Report - Detail Format
Tank Indentification and Physical Characteristics

Identification

User Identification: 3 City:

State: Company: Type of Tank: Vertical Fixed Roof Tank Description:

Tank Dimensions Shell Height (ft): 26.60 Diameter (ft): 15.10 Liquid Height (ft) : 24.00 Avg. Liquid Height (ft): 24.00 Volume (gallons): 29,238.78

Turnovers: 175.81 Net Throughput(gal/yr): 5,140,411.00

Is Tank Heated (y/n): N

Paint Characteristics

Shell Color/Shade: White/White

Shell Condition Good

Roof Color/Shade: Aluminum/Diffuse

Roof Condition: Good

Roof Characteristics Type: Cone Height (ft) 0.00 Slope (ft/ft) (Cone Roof) 0.06

Breather Vent Settings Vacuum Settings (psig): -0.03 Pressure Settings (psig) 0.03

Meterological Data used in Emissions Calculations: Houston, Texas (Avg Atmospheric Pressure = 14.7 psia)



### TANKS 4.0.9d

Emissions Report - Detail Format
Liquid Contents of Storage Tank

3 - Vertical Fixed Roof Tank

Daily Liquid Surf. Temperature (deg F) Liquid

Bulk Temp Vapor Pressure (psia) Vapor

Mol. Liquid

Mass Vapor

Mass Mol. Basis for Vapor Pressure

Mixture/Component Month Avg. Min. Max. (deg F) Avg. Min. Max. Weight. Fract. Fract. Weight Calculations

uneven mix small tank All 72.92 65.30 80.54 69.22 4.3675 3.6355 5.2197 79.3623 77.91

Methyl alcohol 2.1414 1.7006 2.6760 32.0400 0.1250 0.0602 32.04 Option 2: A=7.897, B=1474.08, C=229.13

Methylene chloride 7.5819 6.3760 8.9687 84.9400 0.5000 0.8521 84.94 Option 2: A=7.409, B=1325.9, C=252.6

Tetrachloroethylene 0.3118 0.2457 0.3925 165.8300 0.1250 0.0088 165.83 Option 2: A=6.98, B=1386.92, C=217.53

Toluene 0.4878 0.3886 0.6077 92.1300 0.1250 0.0137 92.13 Option 2: A=6.954, B=1344.8, C=219.48

Trichloroethane (1,1,1) 2.3228 1.9033 2.8204 133.4200 0.1250 0.0653 133.42 Option 2: A=8.643, B=2136.6, C=302.8



### TANKS 4.0.9d

Emissions Report - Detail Format
Detail Calculations (AP-42)

3 - Vertical Fixed Roof Tank

Annual Emission Calcaulations

Standing Losses (lb): 1,365.9798 Vapor Space Volume (cu ft): 493.7720 Vapor Density (lb/cu ft): 0.0606 Vapor Space Expansion Factor: 0.2047

Vented Vapor Saturation Factor: 0.6104

Tank Vapor Space Volume: Vapor Space Volume (cu ft): 493.7720

Tank Diameter (ft): 15.1000TANKS 4.0 Report

Vapor Space Outage (ft): 2.7573 Tank Shell Height (ft): 26.6000 Average Liquid Height (ft): 24.0000

Roof Outage (ft): 0.1573

Roof Outage (Cone Roof)

Roof Outage (ft): 0.1573

Roof Height (ft): 0.0000

Roof Slope (ft/ft): 0.0625

Shell Radius (ft): 7.5500

Vapor Density Vapor Density (lb/cu ft): 0.0606 Vapor Molecular Weight (lb/lb-mole): 79.3623 Vapor Pressure at Daily Average Liquid

Surface Temperature (psia): 4.3675 Daily Avg. Liquid Surface Temp. (deg. R): 532.5909 Daily Average Ambient Temp. (deg. F): 67.9125

Ideal Gas Constant R

(psia cuft / (lb-mol-deg R)): 10.731 Liquid Bulk Temperature (deg. R): 528.8925

Tank Paint Solar Absorptance (Shell): 0.1700

Tank Paint Solar Absorptance (Roof): 0.6000 Daily Total Solar Insulation

Factor (Btu/sqft day): 1,405.5061

Vapor Space Expansion Factor Vapor Space Expansion Factor: 0.2047 Daily Vapor Temperature Range (deg. R): 30.4934 Daily Vapor Pressure Range (psia): 1.5843

Breather Vent Press. Setting Range(psia): 0.0600 Vapor Pressure at Daily Average Liquid

Surface Temperature (psia): 4.3675 Vapor Pressure at Daily Minimum Liquid

Surface Temperature (psia): 3.6355 Vapor Pressure at Daily Maximum Liquid

Surface Temperature (psia): 5.2197 Daily Avg. Liquid Surface Temp. (deg R): 532.5909 Daily Min. Liquid Surface Temp. (deg R): 524.9676 Daily Max. Liquid Surface Temp. (deg R): 540.2143 Daily Ambient Temp. Range (deg. R): 21.3083

Vented Vapor Saturation Factor

Vented Vapor Saturation Factor: 0.6104 Vapor Pressure at Daily Average Liquid:

Surface Temperature (psia): 4.3675 Vapor Space Outage (ft): 2.7573

Working Losses (lb): 14,309.4331 Vapor Molecular Weight (lb/lb-mole): 79.3623 Vapor Pressure at Daily Average Liquid

Surface Temperature (psia): 4.3675

Annual Net Throughput (gal/yr.): 5,140,411.0000

Annual Turnovers: 175.8080

Turnover Factor: 0.3373

Maximum Liquid Volume (gal): 29,238.7838

Maximum Liquid Height (ft): 24.0000

Tank Diameter (ft): 15.1000 Working Loss Product Factor: 1.0000

Total Losses (lb): 15,675.4129



### TANKS 4.0.9d

Emissions Report - Detail Format

Individual Tank Emission Totals

Emissions Report for: Annual

3 - Vertical Fixed Roof Tank

Losses(lbs)

Components Working Loss Breathing Loss Total Emissions

uneven mix small tank 14,309.43 1,365.98 15,675.41

Methylene chloride 12,193.11 1,163.96 13,357.07

Trichloroethane (1,1,1) 933.88 89.15 1,023.03

Toluene 196.13 18.72 214.85

Tetrachloroethylene 125.36 11.97 137.33

Methyl alcohol 860.95 82.19 943.13TANKS 4.0 Report



### TANKS 4.0.9d

Emissions Report - Detail Format
Tank Indentification and Physical Characteristics

Identification

User Identification: 3 City:

State: Company: Type of Tank: Vertical Fixed Roof Tank Description:

Tank Dimensions Shell Height (ft): 42.00 Diameter (ft): 16.50 Liquid Height (ft) : 37.80 Avg. Liquid Height (ft): 37.80 Volume (gallons): 57,582.89

Turnovers: 104.22 Net Throughput(gal/yr): 6,001,370.00

Is Tank Heated (y/n): N

Paint Characteristics

Shell Color/Shade: White/White

Shell Condition Good

Roof Color/Shade: Aluminum/Diffuse

Roof Condition: Good

Roof Characteristics Type: Cone Height (ft) 0.00 Slope (ft/ft) (Cone Roof) 0.06

Breather Vent Settings Vacuum Settings (psig): -0.03 Pressure Settings (psig) 0.03

Meterological Data used in Emissions Calculations: Houston, Texas (Avg Atmospheric Pressure = 14.7 psia)



### TANKS 4.0.9d

Emissions Report - Detail Format
Liquid Contents of Storage Tank

3 - Vertical Fixed Roof Tank

Daily Liquid Surf. Temperature (deg F) Liquid

Bulk Temp Vapor Pressure (psia) Vapor

Mol. Liquid

Mass Vapor

Mass Mol. Basis for Vapor Pressure

Mixture/Component Month Avg. Min. Max. (deg F) Avg. Min. Max. Weight. Fract. Fract. Weight Calculations

uneven mix small tank All 72.92 65.30 80.54 69.22 2.6822 2.1986 3.2542 71.0958 74.22

Methyl alcohol 2.1414 1.7006 2.6760 32.0400 0.2000 0.1667 32.04 Option 2: A=7.897, B=1474.08, C=229.13

Methylene chloride 7.5819 6.3760 8.9687 84.9400 0.2000 0.5902 84.94 Option 2: A=7.409, B=1325.9, C=252.6

Tetrachloroethylene 0.3118 0.2457 0.3925 165.8300 0.2000 0.0243 165.83 Option 2: A=6.98, B=1386.92, C=217.53

Toluene 0.4878 0.3886 0.6077 92.1300 0.2000 0.0380 92.13 Option 2: A=6.954, B=1344.8, C=219.48

Trichloroethane (1,1,1) 2.3228 1.9033 2.8204 133.4200 0.2000 0.1808 133.42 Option 2: A=8.643, B=2136.6, C=302.8



### TANKS 4.0.9d

Emissions Report - Detail Format
Detail Calculations (AP-42)

3 - Vertical Fixed Roof Tank

Annual Emission Calcaulations

Standing Losses (lb): 983.4693 Vapor Space Volume (cu ft): 934.8146 Vapor Density (lb/cu ft): 0.0334 Vapor Space Expansion Factor: 0.1401

Vented Vapor Saturation Factor: 0.6167

Tank Vapor Space Volume: Vapor Space Volume (cu ft): 934.8146

Tank Diameter (ft): 16.5000TANKS 4.0 Report

Vapor Space Outage (ft): 4.3719 Tank Shell Height (ft): 42.0000 Average Liquid Height (ft): 37.8000

Roof Outage (ft): 0.1719

Roof Outage (Cone Roof)

Roof Outage (ft): 0.1719

Roof Height (ft): 0.0000

Roof Slope (ft/ft): 0.0625

Shell Radius (ft): 8.2500

Vapor Density Vapor Density (lb/cu ft): 0.0334 Vapor Molecular Weight (lb/lb-mole): 71.0958 Vapor Pressure at Daily Average Liquid

Surface Temperature (psia): 2.6822 Daily Avg. Liquid Surface Temp. (deg. R): 532.5909 Daily Average Ambient Temp. (deg. F): 67.9125

Ideal Gas Constant R

(psia cuft / (lb-mol-deg R)): 10.731 Liquid Bulk Temperature (deg. R): 528.8925

Tank Paint Solar Absorptance (Shell): 0.1700

Tank Paint Solar Absorptance (Roof): 0.6000 Daily Total Solar Insulation

Factor (Btu/sqft day): 1,405.5061

Vapor Space Expansion Factor Vapor Space Expansion Factor: 0.1401 Daily Vapor Temperature Range (deg. R): 30.4934 Daily Vapor Pressure Range (psia): 1.0556

Breather Vent Press. Setting Range(psia): 0.0600 Vapor Pressure at Daily Average Liquid

Surface Temperature (psia): 2.6822 Vapor Pressure at Daily Minimum Liquid

Surface Temperature (psia): 2.1986 Vapor Pressure at Daily Maximum Liquid

Surface Temperature (psia): 3.2542 Daily Avg. Liquid Surface Temp. (deg R): 532.5909 Daily Min. Liquid Surface Temp. (deg R): 524.9676 Daily Max. Liquid Surface Temp. (deg R): 540.2143 Daily Ambient Temp. Range (deg. R): 21.3083

Vented Vapor Saturation Factor

Vented Vapor Saturation Factor: 0.6167 Vapor Pressure at Daily Average Liquid:

Surface Temperature (psia): 2.6822 Vapor Space Outage (ft): 4.3719

Working Losses (lb): 12,384.6473 Vapor Molecular Weight (lb/lb-mole): 71.0958 Vapor Pressure at Daily Average Liquid

Surface Temperature (psia): 2.6822

Annual Net Throughput (gal/yr.): 6,001,369.9990

Annual Turnovers: 104.2214

Turnover Factor: 0.4545

Maximum Liquid Volume (gal): 57,582.8912

Maximum Liquid Height (ft): 37.8000

Tank Diameter (ft): 16.5000 Working Loss Product Factor: 1.0000

Total Losses (lb): 13,368.1166



### TANKS 4.0.9d

Emissions Report - Detail Format

Individual Tank Emission Totals

Emissions Report for: Annual

3 - Vertical Fixed Roof Tank

Losses(lbs)

Components Working Loss Breathing Loss Total Emissions

uneven mix small tank 12,384.65 983.47 13,368.12

Methylene chloride 7,309.73 580.47 7,890.20

Trichloroethane (1,1,1) 2,239.43 177.83 2,417.26

Toluene 470.32 37.35 507.67

Tetrachloroethylene 300.62 23.87 324.50

Methyl alcohol 2,064.54 163.95 2,228.49

# Appendix 3:

Tanks Option 1 Cost Estimate (Ductwork Costs Per Tank)A3-1

TOTAL ANNUAL COST SPREADSHEET PROGRAM

-- STRAIGHT DUCTWORK [1]



### COST BASE DATE: CEPCI 1993 [2] 359.2

COST ESCALATION: CEPCI 2012 [3] 584.6



### INPUT PARAMETERS
Inlet stream flowrate (acfm):[4] 729



### Duct velocity (ft/min): [5] 3840
Duct length (ft): [6] 150
Material of construction: [7] 304 SS Sheet
Insulation thickness (in.): (text input) [8] 0
Duct design: [9] Circ.

- spiral
Cost equation parameters: [10]

a: 1.56

b: 1
Cost equation form: [11] 1
Control system installation factor: 1.5
(if no system, enter '0')

Fan

- motor combined efficiency (fraction): 0.6

DESIGN PARAMETERS
Duct diameter (in.): 5.89777904
Pressure drop (in. w.c.): [13] 5.314321378

CAPITAL COSTS Equipment Cost ($)

-- base: $1,380

' ' '

-- escalated: $2,246
Purchased Equipment Cost ($): $2,426
Total Capital Investment ($): [14] $3,639

ANNUAL COST INPUTS Operating factor (hours/year): 8760 Electricity price ($/kWhr): [15] 0.067 

### Annual interest rate (fractional): 0.07
Ductwork economic life (years): 15
Capital recovery factor (system): 0.109794625

Taxes, insurance, a dmin. factor: 0.04

ANNUAL COSTS Cost ($/yr) Wt.Fact.
Electricity $445 0.449631287

Taxes, insurance, administrative $146 0.146966 212
Capital recovery $400 0.403402501

------------------------------------------------------------------------------------------------------------------------ Total Annual Cost $990 1A3-2



### Notes:

[1] Data used to develop this program were taken from ' OAQPS Control Cost Manual', 5th edition, Chapter
10. Prices are for CIRCULAR straight ductwork, only.

[2] Base ductwork costs reflect this date.

[3] PPI = Producer Price Index PCU 3444#1 ('Air

- conditioning ducts and stove pipe') for year and quarter

sho wn. Ductwork equipment cost has been escalated to this date via this PPI.

[4] Median flow rate of tanks controlled by thermal oxidizers in OSWRO CAA section 114 survey


### [5] See 'Manual,' pp. 10

- 30 to 10

- 33.

[6] Duct length is a site

- specific parameter t hat can vary from < 10 to > 1000 ft.

[7] Choices available are: carbon steel sheet (galv. CS sh.), stainless steel sheet (304 SS sh.), coated carbon steel plate (coat. CS pl.), 304 stainless steel plate (304 SS pl.), polyvinyl chloride (PVC), and fiber

- re inforced plastic (FRP)

[8] Choices are: 0, 1, and 3.

[9] Choices are: circular spiral (circ.

- spiral) and circular longitudinal (circ.

- long.)

[10] Equation type and parameters depend on duct material of construction. Parameters reflect 2nd

quarter 1993 costs. See 'Manual,' pp. 10

- 44 to 10

- 49.

[11] Choices are: power function (1) and exponential (2).

[12] Installation factor depends on control device ductwork is supporting. This factor, when multiplied by
Purchased Equipment Cost, yields Total Capital Investment (TCI). If ductwork is installed alone, factor is
1.25 to 1.50. (Default = 1.50.) See 'Manual'.

[13] Pressure drop applies ONLY to circular, spiral

- wound galvanized duct with 10 joints per 100 feet. For
pressure drop data for other duct typ es, see 'Manual,' Chapter 10.

[14] Product of installation factor and Purchased Equipment Cost. Costs are presented both in terms of
2nd quarter '93 and above escalation date. Latter costs are based on Producer Price Index PCU 3444#1
('Air

- conditioning ducts and stove pipe')

[15] 2012 Table 5.3. Average Retail Price of Electricity to Ultimate Customers: Industrial http://www.eia.gov/electricity/monthly/epm_table_grapher.cfm?t=epmt_5_3

# Appendix 4:

Tanks Option 2 Cost Estimate

(Pollutant Heat Content and RCO Costs)A4-1



### Option 2 Average Pollutant Heat Content Calculations

OSWRO

Component Emissions

(lb/hr)* Molecular

Weight (lb/lb

- mole) Volumetric

Flow Rate (scf/min) - ΔHc

(KJ/mole) Heat of

Combustion (Btu/lb) Heat of

Combustion
(Btu /scf) Volume

Fraction of

Component

in Exhaust

Gas Vent Heat

Content (Btu/scf)

VOC 44.09 0.000000 2220 21,665 2,479 0.00E+00 0.00000

Methane 16.04 0.000000 890.4 23,884 994 0.00E+00 0.00000

Ethane 30.07 0.000000 1559.9 22,321 1,742 0.00E+00 0.00000

O ther HAP 44.09 0.000000 2220 21,665 2,479 0.00E+00 0.00000

Hexanes 86.17 0.000000 4194.8 20,946 4,684 0.00E+00 0.00000

Benzene 78.11 0.000000 3301.5 18,187 3,687 0.00E+00 0.00000
Methylene Chloride 13.64670 84.94 1.031723 605 3,065 676 1.41E

- 03 0.954 35

Toluene 0.30412 92.13 0.021198 3947.9 18,438 4,409 2.90E

- 05 0.12795
Ethylbenzene 106.16 0.000000 4607.1 18,673 5,145 0.00E+00 0.00000
Xylenes 106.16 0.000000 4595.2 18,625 5,132 0.00E+00 0.00000

Methanol 1.33501 32.04 0.267571 764 10,260 853 3.66E

- 04 0.31255
Tetrachloroethylene 0.19439 165.83 0.007528 830 2,154 927 1.03E

- 05 0.00955

Trichloroethane
(1,1,1) 1.44810 133.42 0.069699 1442 4,650 1,610 9.54E

- 05 0.15367

Air 729 

### 0 0 0 9.98E

- 01 0.00000

Total 16.92833 85.9733609 730 1.00E+0 0 1.5581

* Emissions are based on 78 tanks at < 151 m 3 and kPa > 27.6 , 21 tanks at 75 to 151 m 3 and kPa between 13.1 and 27.6 , and 8 tanks > 151 m 3 and kPa > 5.2 spread between 10 facilitiesA4 -2

TOTAL ANNUAL COST SPREADSHEET PROGRAM

-- RECUPERATIVE THE RMAL OXIDIZERS (RCO)

OSWRO

COST BASE DATE: CEPCI 1999 390.6

COST ESCALATION: CEPCI 2012 584.6

INPUT PARAMETERS

Gas flowrate (scfm):[1] 729

Reference temperature (oF): 78

Inlet gas temperature (oF): 78
Inlet gas density (lb/scf): 0.073763813

Primary heat recovery (fraction): 0.7
Waste gas heat content (BTU/scf): 1.558
Waste gas heat content (BTU/lb): 21.12
Gas heat capacity (BTU/lb

- oF): 0.255

Combustion temperature (oF) : 1600

Heat loss (fraction): 0.01

Exit temperature (oF): 534.6

Fuel heat of combustion (BTU/lb): 21502
Fuel density (lb/ft3): 0.0408

DESIGN PARAMETERS
Auxiliary Fuel Requirement (lb/min): 0.249461881

( scfm): 6.114261787

Total Gas Flowrate (scfm): 735.1142618

TOTAL CAPITAL INVESTMENT ($)

(Cost correlations range: 500 to 50,000 scfm, 70% Heat Recovery)

Total Capital Investment

- Base $178,916

Total Capital Investment

- Esca lated $267,779

ANNUAL COST INPUTS
Operating factor (hr/yr): 8760 Operating labor rate ($/hr):[2] 26.36
Maintenance labor rate ($/hr):[3] 25.32
Operating labor factor (hr/sh): 0.5
Maintenance labor factor (hr/sh): 0.5 Electricity price ($/kwh):[4] 0.067 Natural gas price ($/mscf):[5] 3.86

Annual interest rate (fraction): 0.07
Control system life (years): 15

Capital recovery factor: 0.109794625

Taxes, insurance, admin. factor: 0.04

Pressure drop (in. w.c.): 20

ANNUAL COSTS Cost ($/yr)A4 -3

Operating labor $14,432.10

Supervisory labor $2,164.82

Maintenance labor $13,862.70

Maintenance materials $13,862.70

Natural gas $12,404.71

Electricity $1,682.67

Overhead $26,593.39

Taxes, insurance, administrative $10,711.15

Capital recovery $29,400.68

---------------------------------------------------------------------------------------------------------------- ---
Total Annual Cost $125,115

[1] median flow rate of tanks controlled by thermal oxidizers in OSWRO CAA section 114 survey

[2] May 2012 National Industry

- Specific Occupational Employment and Wage Estimates

NAICS 325000

- Chemical Manufacturi ng Misc. Plant and System Operators http://www.bls.gov/oes/current/naics3_325000.htm

[3] May 2012 National Industry

- Specific Occupational Employment and Wage Estimates

NAICS 325000

- Avg. of Installation, Maintenance and Repair Occupations http://www.bls.g ov/oes/current/naics3_325000.htm

[4] 2012 Table 5.3. Average Retail Price of Electricity to Ultimate Customers: Industrial http://www.eia.gov/electricity/monthly/epm_table_grapher.cfm?t=epmt_5_3

[5] 2012 Natural Gas Prices: http://www.eia.gov/dnav/ng/ng_ pri_sum_dcu_nus_a.htm

# Appendix 5:

Equipment Leak Model Plant CostsA5-1

# Appendix 6:

Process Vents Option Cost Estimate

(Pollutant Heat Content, RTO Costs and Ductwork Costs)A6-1

Average Pollutant Heat Content Calculations

OSWRO Process Vents

Component Emissions

(lb/hr) Molecular

Weight (lb/lb

mole) Volumetric

Flow Rate (scf/min) - ΔHc

(KJ/mole) Heat of

Combustion (Btu/lb) Heat of

Combustion (Btu/scf) Volume

Fraction of

Component

in Exhaust

Gas Vent Heat

Content (Btu/scf)

VOC 44.09 0.0 2220 21,665 2,479 0.00E+00 0.00000

Methane 16.04 0.00 890.4 23,884 994 0.00E+00 0.00000

Ethan e 30.07 0.00 1559.9 22,321 1,742 0.00E+00 0.00000

Other HAP 44.09 0.00 2220 21,665 2,479 0.00E+00 0.00000

Hexanes 86.17 0.000 4194.8 20,946 4,684 0.00E+00 0.00000

Benzene 78.11 0.00 3301.5 18,187 3,687 0.00E+00 0.00000 Methylene

Chloride 84.94 0.0 0 605 3,065 676 0.00E+00 0.00000

Toluene 1.25 92.13 0.09 3947.9 18,438 4,409 3.49E

- 06 0.01538

Ethylbenzene 106.16 0.00 4607.1 18,673 5,145 0.00E+00 0.00000

Xylenes 106.16 0.00 4595.2 18,625 5,132 0.00E+00 0.00000

Air 25,000 0 0 0 1.00E+00 0.00000

Total 1.25 25,000 1.00E+00 0.0154

Data Source: Median toluene emissions from CAA section 114 survey facilities with a thermal oxidizer on process vents.A6-2

TOTAL ANNUAL COST SPREADSHEET PROGRAM

-- REGENERATIVE THERMAL OXIDIZERS (RTO)

OSWRO Process Vents

COST BASE DATE: CEPCI 1999 390.6

COST ESCALATION: CEPCI 2012 584.6

INPUT PARAMETERS

Gas flowrate (scfm): 1 25,000
Reference temperature (oF): 77

Inlet gas temperature (oF): 1 208
Inlet gas density (lb/scf): 0.073901176
Primary heat recovery (fraction): 0.95
Waste gas heat content (BTU/scf): 0.015
Waste gas heat content (BTU/lb): 0.21
Gas heat capacity (BTU/lb

- oF): 0.255
Combustion temperature (oF): 16 00

Heat loss (fraction): 0.01
Exit temperature (oF): 277.6
Fuel heat of combustion (BTU/lb): 21502
Fuel density (lb/ft3): 0.0408

DESIGN PARAMETERS
Auxiliary Fuel Requirement (lb/min): 1.845512399

(scfm ): 45.23314703

Total Gas Flowrate (scfm): 25045.23315

TOTAL CAPITAL INVESTMENT ($)

(Cost correlations range: 10,000 to 100,000 scfm)

Total Capital Investment

- Base $821,379

Total Capital Investment

- Escalated $1,229,335

ANNUAL COST INPUTS
Operating factor (hr/yr): 8760
Operating labor rate ($/hr): 2 26.36

Maintenance labor rate ($/hr): 3 28.996
Operating labor factor (hr/sh): 0.5
Maintenance labor factor (hr/sh): 0.5

Electric ity price ($/kwh): 4 0.067
Natural gas price ($/mscf): 5 3.86

Annual interest rate (fraction): 0.07
Control system life (years): 15

Capital recovery factor: 0.109794625

Taxes, insurance, admin. factor: 0.04

Pressure dr op (in. w.c.): 20A6-3

ANNUAL COSTS

Operating labor $14,432.10

Supervisory labor $2,164.82

Maintenance labor $15,875.31

Maintenance materials $15,875.31

Natural gas $91,769.73

Electricity $57,328.24

Overhead $29,008.52

Taxes, insurance, administrative $49,173.40

Capital recovery $134,974.37

-------------------------------------------------------------------------------------------------------------------
Total Annual Cost $410,60 2

1 M edian flow rate of process vents controlled by thermal oxidizers in OSWRO CAA section 114 survey

2 May 2012 National Industry

- Specific Occupational Employment and Wage Estimates

NAICS 325000

- Chemical Manufacturing Misc. Plant and System Operato rs http://www.bls.gov/oes/current/naics3_325000.htm

3 Operator labor * 1.1

4 2012 Table 5.3. Average Retail Price of Electricity to Ultimate Customers: Industrial http://www.eia.gov/electricity/monthly/epm_table_grapher.cfm?t=epmt_5_3

5 2012 Natural Gas Prices: http://www.eia.gov/dnav/ng/ng_pri_sum_dcu_nus_a.htmA6-4

TOTAL ANNUAL COST SPREADSHEET PROGRAM

-- STRAIGHT DUCTWORK [1]



### COST BASE DATE: CEPCI 1993 [2] 359.2

COST ESCALATION: CEPCI 2012 [3] 584.6



### INPUT PARAMETERS

Inlet stream flowrate (acfm):[4] 25,000 

### Duct velocity (ft/min): [5] 3840
Duct length (ft): [6] 150
Material of construction: [7] 304 SS Sheet
Insulation thickness (in.): (text input) [8] 0
Duct design: [9] Circ.

- spiral

Cost equation parameter s: [10]

a: 1.56

b: 1
Cost equation form: [11] 1
Control system installation factor: 1.5
(if no system, enter '0')

Fan

- motor combined efficiency (fraction): 0.6

DESIGN PARAMETERS

Du ct diameter (in.): 34.53780537
Pressure drop (in. w.c.): [13] 0.660195335

CAPITAL COSTS Equipment Cost ($)

-- base: $8082

' ' '

-- escalated: $13,153
Purchased Equipment Cost ($): $14,206
Total Capital Investment ($) : [14] $21,308

ANNUAL COST INPUTS Operating factor (hours/year): 8760 Electricity price ($/kWhr): [15] 0.067 

### Annual interest rate (fractional): 0.07
Ductwork economic life (years): 15
Capital recovery factor (system): 0.109 794625
Taxes, insurance, admin. factor: 0.04

ANNUAL COSTS Cost ($/yr) Wt.Fact.
Electricity $1,897 0.372780515

Taxes, insur ance, administrative $ 852 0.167487848
Capital recovery $2,340 0.4 59731636

------------------------------------------------------------------------------------------------------------------------ Total Annual Cost $ 5,089 1A6-5



### Notes:

[1] Data used to develop this program were taken from 'OAQPS Control Cost Manual', 5th edition, Chapter
10. Prices are for CIRCULAR straight ductwork, only.

[2] Base ductwork costs reflect this date.

[3] PPI = Producer Price Index PCU 3444#1 ('Air

- condi tioning ducts and stove pipe') for year and quarter
shown. Ductwork equipment cost has been escalated to this date via this PPI.

[4] Median flow rate of process vents controlled by thermal oxidizers in OSWRO CAA section 114 survey


### [5] See 'Manual,' pp. 10

- 30 to 10

- 33.

[6] Duct length is a site

- specific parameter that can vary from < 10 to > 1000 ft.

[7] Choices available are: carbon steel sheet (galv. CS sh.), stainless steel sheet (304 SS sh.), coated carbon steel plate (coat. CS pl.), 304 stainless s teel plate (304 SS pl.), polyvinyl chloride (PVC), and fiber

- reinforced plastic (FRP)

[8] Choices are: 0, 1, and 3.

[9] Choices are: circular spiral (circ.

- spiral) and circular longitudinal (circ.

- long.)

[10] Equation type and parameters depend on duct material of construction. Parameters reflect 2nd
quarter 1993 costs. See 'Manual,' pp. 10

- 44 to 10

- 49.

[11] Choices are: power function (1) and exponential (2).

[12] Installation factor depends on control device ductwork is supporting. This factor, wh en multiplied by Purchased Equipment Cost, yields Total Capital Investment (TCI). If ductwork is installed alone, factor is
1.25 to 1.50. (Default = 1.50.) See 'Manual'.

[13] Pressure drop applies ONLY to circular, spiral

- wound galvanized duct with 10 joints per 100 feet. For
pressure drop data for other duct types, see 'Manual,' Chapter 10.

[14] Product of installation factor and Purchased Equipment Cost. Costs are presented both in terms of
2nd quarter '93 and above escalation date. Latter costs a re based on Producer Price Index PCU 3444#1
('Air

- conditioning ducts and stove pipe')

[15] 2012 Table 5.3. Average Retail Price of Electricity to Ultimate Customers: Industrial http://www.eia.gov/electricity/monthly/epm_table_grapher.cfm?t=epmt_5_3