### MEMORANDUM

**DATE:** October 17 , 201 4 **SUBJECT:** Revised Technology Review for the Off

- Site Waste and Recovery Operations Tanks **FROM:** Lesley

Stobert, EC/R Inc. **TO:** Paula Hirtz, EPA/OAQPS/SPPD The EPA proposed amendments to off

- site waste and recovery

operations (OSWRO) national emissions standards for hazardous air pollutants (NESHAP) on July 2, 2014 , based on residual risk and technology

review s conducted f

or the source category

. The purpose of this memorandum is to present a revised anal ys is related to the technology review for tanks at OSWRO facilities , considering comments submitted during the public comment period for the proposed OSWRO NESHAP amendments

. **1.0 INTRODUCTION**  On July 2, 2014 (79 FR 37850), the EPA proposed amendments to the OSWRO source category following the results of a review required b y s ection 112(d)(6) of the CAA, which directs the EPA to review previously issued NESHAP regulations and to revise them as necessary (taking into account developments in practices, processes and control technologies) no less frequentl y than every

8 years. Section 112(f)(2) of the CAA requires the EPA to assess, within 8 years of promulgation of the origin al NESHAP for major sources and area sources subject to MACT, the remaining risks due to emissions of HAP from these source categories and determine whether the emissions standards provide an ample margin of safety to protect public health. These reviews are collectivel y referred to as residual risk and technology reviews (RTRs). For the July 2014 proposal, a technology review for tanks at OSWRO facilities was conducted. Under CAA section 112(d)(6), the EPA proposed to re quire more stringent emissions control s for tanks of certain capacities storing materials above a specified vapor pressure

. Following the July 2014 proposal, the EPA received comments from one industry trade association challenging some of the data and assumptions used in the analysis of emissions reduction and costs associated with the emissions controls for these tanks . We have considered these comments and revised certain aspects of our technology review analysis for OSWRO tanks.2



### 2 **. 0**  **T ANKS RE**  **- ANALYSIS**  2
. 1 Tanks at OSWRO Faciliti es 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 ty pe of material in the tank , the ty

pe of 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 ye ar. Emissions of 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 f

rom 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

. 2
. 2 Summary

of Existing MACT L evel of Control The current OSWRO MACT standards f or tanks require either Level 1 or Level 2 controls, depending on the tank capacity and the vapor pressure of the materials in the tank. Tanks subject to L evel 1 control requirements are required to be equipped with a fixed roof designed 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 roo f 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 requirements

. For tanks subject to Level 2 control requirements, one of the following five control alternatives must be used : (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 co ntrol device that has a HAP removal or destruction 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 that has a HAP destruction efficiency of 95 percent
. 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 1
.

**Table 1**  **. Tank Control Levels for Tanks at Existing and New Facilities Current**  **OSWRO MACT Requirements**  **Applicability Threshold Control Level**  **Size (**  **m 3**  

### ) **Vapor Pressure**

**( kPa** **)** Existing Sources Less than 75 < 76. 6 1 ≥ 76. 6 2 * 75 ≤ capacity < 151 < 27.6 13 

### ≥ 27.6 2 151 ≤ capacity < 5.2 1 ≥ 5.2 2

New Sources Less than 38 < 76. 6 1 ≥ 76. 6 2 * 38 ≤ capacity < 151 < 13.1 1 ≥ 13.1 2 151 ≤ capacity < 0.7 1 ≥ 0.7 2 * Except that fixed roof tanks equipped with an internal floating roof and tanks equipped with an external floating roof shal l not be used 

### 2.3 Proposed Standard for Tanks At proposal , we identified two potential developments in existing practices and control techniques not currently

required b y the OSWRO MACT standards for tanks at existing sources

. One option we evaluated (Option 1) was to rev ise the applicability of the OSWRO requirements to use the same thresholds for Level 2 control as the thresholds for control required b y other MACT standards, specifically the Hazardous Organic NESHAP (HON) . Based on information received from the industry as part of a CAA section 114 survey , which showed that the industry primarily uses fixed roof tanks vented to control devices, under Option 2 we also considered the impacts of requiring a 98 percent emissions reduction for tanks required to use Level 2 control , rather than the currentl y required 95 percent emissions reduction, along with the revised capacity and vapor pressure thresholds of Option 1 . Based on the estimated control costs and emissions reductions, revisions to the standards for tanks at existing sources to require Option 1 were proposed. Table 2 presents a summary of the tank size and vapor pressure thresholds considered for existing sources under both options. **Table 2**  **. Storage Tank Size Applicability Threshold Alternatives**  **for Existing Sources**  **Regulatory Options**  **Applicability 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. 5 1 Fixed roof ≥ 76. 5 2 a 

### 95% controlb 

### 98% controlb 

### 75 ≤ capacity < 151 < 13.1 1 Fixed roof

≥ 13.1 2 95% controlb 

### 98% controlb 

### 151 ≤ capacity < 5.2 1 Fixed roof

≥ 5.2 2 95% controlb 

### 98% controlb

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 permanent total enclosure ( PTE ) that are vented to a combustion control device; use of an internal or external floating roof or a pressure tank wo uld still be available control options.4



### 2.4 Revised E stimation of Tank Emissions Based on comments regarding the proposed revised tank standards from the Cement Kiln Recycling Coalition (CKRC), an industry trade association, we have revised our anal ys is of tank emissions for tanks with capacities greater than or equal to 75 m 3 

### , but less than 151 m 3 

### , if the vapor pressure of the stored material is 13 kPa or greater

. While we have not revised our estimate of the number of tanks in this size and vapor pressure range that would require controls under Option 1 , we have revised some of the parameters used to estimate emissions potential from these tanks using the EPA’s TANKS 4.09d 1 

### program . T o estimate the number of tanks existing in the OSWRO source category with a capacity range of 75 m 3 

### to 151 m 3 

### and with a vapor pressure of stored material between 13.1 kPa and 27.6 kPa (i.e., those tanks with a stored material vapor pressure of 2.76 kPa are already regulated under the current NESHAP) , OSWRO CAA section 114 survey data was used and then scaled up to nationwide values based on the number of known OSWRO facilities . Table 3 shows the estimated number of tanks in this size and vapor pressure range and how this estimate was calculated. Although CKRC commented that they believe there are more tanks in this size and vapor pressure range than the estimate used at proposal, we received no data to support this assertion, and many of the CKRC member companies submitted data through the CAA section 1 14 survey , which was used in developing this estimate of tanks in this size and vapor pressure range in the source category

. **Table 3. Estimated OSWRO T a**  **nk Population Based on CAA 114 Survey Responses**
**Tank Size/Vapor Pressure**  **Estimated**

**Number of Tanks in**  **the OSWRO**  **Source Category**  **Estimated**

**Number of Tanks in the OSWRO**  **Source Category that Would**  **Require Level 2 Controls**  **Explanation**

75
- 151 m3 and 13.1 ≤ kPa < 27.6 21 tanks 14 tanks One of 15 facilities responding to the survey has tanks with this size and vapor pressure. Total number of tanks for this facility is 7. Scaling up to 49 facilities in the source category , 1/15 x 4 9 = 3 facilities have 7 tanks or 21 total tanks. The one facility reporting tanks of this size and vap or pressure already uses Level 2 emissions controls for these tanks. It is assumed that the tanks of this size and vapor pressure at other facilities are not already controlled with Level 2 controls

.
1 http://www.epa.gov/ttnchie1/software/tanks/5



### W e estimated the emission potential from a model tank in the capacity rang e of 75 m 3 

### to 151 m 3 

### and vapor pressure between 13.1 kPa and 27.6 kPa using the EPA’s TANKS 4.09d program, which is a software tool that calculates HAP emissions from fixed and floating roof tanks. The parameters shown in Table 4 were used as inputs to the TANKS program and were based on information reported in the OSWRO CAA section 114 survey responses and on comments from CKRC. The specific changes incorporated since proposal include:

 T ank conservation vent pressure setting of 0. 5 p si rather than 0.03 psi to reflect probable vent settings currentl y in place under control Level 1;  T ank location of Concordia , KS, rather than Houston, TX. Concordia, KS is the closest city to the geographic center of the continental U.S. included in the TANKS program and is more representative of national average temperatures;  Revised mix of tank constituents to include non

- HAP contents, with an overall HAP content revised to 6 0 percent from 100 percent to more accurately reflect ty pical OSWRO tank contents

. We note that although CKRC commented that they believe the estimated throughput is too high, we have not changed our estimate. The commenter did not provide detailed information to support the use of a different value. Our e stimate of 4,996,918 gal/y r was developed from data reported in the supporting documentation for the proposed storage tank uniform standards , 2 

### and data from the one facility reporting tanks in this size and vapor pressure range is similar to th is estimate

. The revised estimated emission potential for tank s with capacities greater than or equal to 75 m 3 

### , but less than 151 m 3 

### , if the vapor pressure of the stored material is between 13 .1 kPa and 27.6 kPa is shown in Table 4
. See the Appendix to this document for more information on the inputs used and outputs obtained from the TANKS 4.09d program.

2 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

- 0027.6 

### Table **4 . Estimation of**  **T ank**  **HAP E**  **mission Po**  **tential Size and Vapor**  **Pressure Range Capacity**  **1**

**( gal/**  **m 3**  **) Height**  **1**

**(Ft) Diam**  **eter 1** 

**(ft) Throughput** 

**2 (gal)**  **Tank**

**Contents Vapor**  **Pressure 3**  **(kPa) Location**  **4 Tank Contents**  **5 Speciated**  **and Total Emission**  **Potential 6**  **(lb/yr)**

T ank ≥ 75 to < 151 m3 and 13.1 <kP a< 27.6 25,000 gal

(94.6 m3 ) 28.4 12.3 4,996,918 14.86 Concordia, KS 1 0% methanol * 361

20 % methylene chloride * 2,863 10 % tetrachloroethylene * 52 10 % toluene * 83 1 0% trichloroethane (1,1,1) * 417 2 0% acetone 1,482 6.66 % cyclohexene 204 6.67 % isopropyl alcohol 79 6.67 % methyl ethyl ketone 182

**Total Emissions**  **5,722 Total**  **HAP Emissions 3,776**  1 Capacity, height and diameter based on average of CAA section 114 survey response data for tanks meeting these thresholds

. 2 Due to in sufficient 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)

. This value is similar to the value obtained from the average of the 7 tanks at the one facility reporting tanks in this size and vapor pressure range, which reported an average of 19.161 tons of annual throughput. Based on the tank emissions reported by this facility, the average weight per gallon of stored material is 8 lbs/gal, resulting in an average throughput of 4,790,143 gal. 3 V apor pressure was determined with TA NKS4.0.9d based on the tank contents. 4 L ocation assumed as Concordia, KS, the closest city to the geographic center of the continental U.S. to be representative of a national average. 5 Chemicals included are based on comments from CKRC. The relative amount of each chemical varied to give more weight to chemic als with higher vapor pressure s to make the overall vapor pressure of the tank b e above the 13.1 kPa threshold for regulation. * Denotes chemicals that are HAP. 6 Uncontrolled emissions from TANKS 4.0.9d

.7



### To determine the nationwide emissions reduction that would be achieved under Option 1, we first determined th e nationwide HAP emissions from the additional tanks that would require Level 2 control under Option 1. This was calculated u sing the estimated tank population shown in Table 3 , the Level 1 HAP emissions per tank for this size and vapor pressure type shown in Table 4 , and the estimated number of uncontrolled tanks within the estimated tank population shown in Table 3. This calculation is shown below : Baseline HAP Emissions : . . = 14 tanks × 3 , 776 lb yr 2 , 000 lb ton = 26
. 4 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 26.4 tons per year (tpy)

. 2.5 Revised Estimat e of Option 1 Costs Based on comments from CKRC, we have revised our anal ys is of tank control costs under Option 1. As described above, 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 estimate the costs for requiring these additional storage ta nks to use Level 2 controls, it was assumed 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. We previously assumed that the only

additional costs associate d with Option 1 would be for ductwork for the estimated 21 additional tanks that would be captured under the new vapor pressure threshold. We have made several revisions to our prior cost estimate . First we have revised the anal ys is to include costs for only

the assumed 14 tanks without L evel 2 emissions controls. CKRC commented that the EPA should have included a flame arrestor for each tank to prevent back

- flash to the tanks. W e have revised th e estimated costs to include costs for flam e arrestor s. However, since one flame arrestor typicall y i s installed in the piping system that serves several tanks, we have assumed that two arrestors per facility (i.e., two arrestors to serve the 7 tanks at each facility) would be installed. In addition, we have added costs associated with adding a carbon adsorption system. While some air pollution control devices may have sufficient capacity to control additional tanks, it is possible that the facilities with these tanks may not have excess capacity to control emission s from these tanks. In this case, depending on the control device(s) already in place, an additional carbon adsorption unit may be needed or could be used for these tanks rather than other control devices already at the facility . Based on the relativel y lo w flow rate expected for these tanks and the costs of the different ty pes of carbon adsorption systems, we assumed carbon canisters would be used for these tanks. We did not add, as the commenter suggested, costs for a nitrogen blanketing s ys tem, as these systems are not required and could already be in place on these tanks. Based on information contained in the EPA Air Pollution Control Cost Manual 3 

### , the revised nationwide capital costs asso ciated with the Tank Option 1, including ductwork , flame arrestors, and carbon

3 Data used were from 'OAQPS Control Cost Manual', 5th edition. See the Appendix to this memo for more specific information regarding the specific values and calculations used in this estimate.8



### adsorption canisters, w ere estimated to be $1 39 ,000 with nationwide annual cost s of $ 1 92 ,000
. See the Appendix to this document for more information about how these costs were determined. The revised annual HAP emissions reduc tion estimate for Option 1 is 26.4 tpy , and the revised estimate of the annual cost per ton of HAP removed is $ 7, 000
. These cost estimates are summarized in Table 5.
**Table 5**  **. Revised**  **Nationwide Costs and Emission Reduction s of Regulatory**  **Option 1 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 26.4 $ 1 39,497 $ 191,886 $ 7, 268

-----

1 The costs associated with this option are for ductwork , flame arrestors and a carbon adsorption system (canisters)

.

# AppendixA

- 1

**Baseline Av er** **age Poll ut**  **ant Heat C ontent Calculations**  **OSWRO**

Com po nent Em issio ns

(l b/hr)* Mo lec ul ar

Weig ht (lb/lbmo le) lb- mo les Vo lumetric

Flo w Rate (s cf/m in ) -Δ Hc

(KJ/mo le) Heat of

Com bustio n (B tu/lb) Heat of

Com bustio n (B tu/sc f) Vo lume

Fra ction o f Com po nent in Exh au st Ga s Vent Heat

Con tent (B tu/scf ) Mo le Frac tio n Freundlich K Freu ndlic h M Refer enc e VOC 1. 55582 61. 27 0. 025395 0.163075 2220 15,591 2,479 3.92E-01 971. 54997 0.391890366 0. 412 0. 389 1 Metha ne 16. 04 0.000000 890.4 23,884 994 0. 00E+00 0. 00000 Eth an e 30. 07 0.000000 1559.9 22,321 1,742 0. 00E+00 0. 00000 Other HAP 44. 09 0.000000 2220 21,665 2,479 0. 00E+00 0. 00000 Hexan es 86. 17 0.000000 4194.8 20,946 4,684 0. 00E+00 0. 00000 Ben zene 78. 11 0.000000 3301.5 18,187 3,687 0. 00E+00 0. 00000 Methylene C hlo ride 2. 28779 84. 94 0. 026934 0.172962 605 3,065 676 4.16E-01 280. 82144 0.415649541 7. 175 0. 469 2 Tolu ene 0. 06632 92. 13 0. 000720 0.004623 3947.9 18,438 4,409 1.11E-02 48. 97889 0.011109518 0. 551 0. 11 3 Eth ylbenzene 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 Metha no l 0. 28847 32. 04 0. 009003 0.057817 764 10,260 853 1.39E-01 118. 54244 0.138941796 0. 22 0. 383 4 Tetr ach lo ro ethylene 0. 04155 165. 83 0. 000251 0.001609 830 2,154 927 3.87E-03 3. 58413 0.00386686 0. 436 1. 47 5 Trichlo ro etha ne (1,1,1)

0. 33322 133. 42 0. 002498 0.016038 1442 4,650 1,610 3.85E-02 62. 06492 0.038541919 1. 06 0. 161 3 Air 0 0 0 0. 00E+00 0. 00000 Total 4. 57317 70. 57 0. 06480 0.416 1. 00E+00 1485. 5418 3. 22 0. 414 * Em issions a rebased on model tank of 25,000 gal and kPa 14.86 References 1 Bas ed on values for acetone, EPA Control Cost Manual Table 1.1: Param et ers for Se le ct ed Adsorption I sothe rms 2 K a nd M (1/n) value s obtaine d from Tsai, W.-T. and Chang, C.-Y. (1994), Adsorption of m et hyle nechloridevapor on activate d c arbons. J . Chem. Technol. Biotechnol., 61: 145–151. 3 EPA Control Cost Manual Table 1. 1: Pa rame te rs for Se lected Adsorption Isothe rms 4 K a nd M value s wereobtained from Agarwal M, Dave M, Upadhayaya S. Adsorption of Formaldehyde on Treate d Activate d Carbon and Activated Alum ina. Curr World E nviron 2011:6( 1);53- 59. 5 K a nd M value s wereobtained from Erto A., Andreozzi R., Di Natale F. , Lancia A., M usmarra D ., 2 009, Expe rime nt al and isotherm -m odels analysis on TCE and PCEadsorption onto activate d carbon,A

- 2

**TOTAL ANNUAL COST SPREADSHEET PROGRAM --**  **STRAIGHT DUCTWORK [1]** COST BASE DATE: CEPCI 1993 [2] 359.2 COST ESCALATION: CEPCI 2013 [3] 567.3 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: [12] 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: $2,180 Purchased Equipment Cost ($): $2,354 Total Capital Investment ($): [14] $3,531

==================================================================== ANNUAL COST INPUTS Operating factor (hours/year): 8760 Electricity price ($/kWhr): [15] 0.067 Annual interest rate (fractional): 0.07 Ductwork economic life (years): 15 Capital recovery factor (system): 0.109794625 Taxes, insurance, admin. factor: 0.04 ANNUAL COSTS Cost ($/yr) Wt.Fact. Electricity $445 0.457075677 Taxes, insurance, administrative $141 0.144978319 Capital recovery $388 0.397946003

------------------------------------------------------------------------------------------------------------------------ Total Annual Cost $974 1A

- 3

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 shown. 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 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 stainle ss steel 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, 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 duc t 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. Latt er 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_3A

- 4

**TOTAL ANNUAL COST --**  **DETONATION ARRESTOR** CAPITAL COSTS Equipment Cost ($): 1 $10,000 Sales Tax and Freight (fractional): 0.08 Purchased equipment cost: $10,800.00 Direct and indirect installation costs (fractional): 2 0.5 Direct installation costs ($): $5,000.00 Total Capital Investment ($): [14] $15,800

==================================================================== ANNUAL COST INPUTS Operating factor (hours/year): 8760 Annual interest rate (fractional): 0.07 Economic life (years): 15 Capital recovery factor (system): 0.109794625 Taxes, insurance, admin. factor: 0.04 Maintenance labor rate ($/hr): 3 54.117 Maintenance labor factor (hr/year): 4 ANNUAL COSTS Cost ($/yr) Wt.Fact. Taxes, insurance, administrative $632 0.244655604 Capital recovery $1,735 0.671546755 Maintenance labor $216

------------------------------------------------------------------------------------------------------------------------ Total Annual Cost $2,583 0.916202359 Notes: 1 Based on equipment price stated by commenter CKRC, docket ID EPA

- HQ
- OAR
- 2012
- 0360
- 0066 2 Based on 'OAQPS Control Cost Manual', 5th edition, Section 2, Chapter 1, page 1

- 50 for equipment that would have similar installation costs (hoods and ducts)
3 May 2013 National Industry

- Specific Occupational Employment and Wage Estimates NAICS 325000

- Mean of Installation, Maintenance and Repair Occupations http://www.bls.gov/oes/current/naics3_325000.htm plus 110% overheadA

- 5

**Carbon Working Capacity Calculat ion**  INPUT PARAMETERS: Inlet stream flowrate (acfm): 1 8.90 Inlet stream temperature ( o F): 2 78 Inlet stream pressure (atm): 3 1 Inlet VOC flowrate (lb/hr): 4 4.573 VOC molecular weight (lb/lb

- mole): 4 70.57 VOC inlet volume fraction: 4.767688E
- 02 VOC inlet partial pressure (psia): 0.7007 Freundlich isotherm equation constants for VOC (see Table 1 below): VOC number (enter Table 1 # or zero, if no data): K: 5 3.223 M: 5 0.414 DESIGN PARAMETERS: Carbon equilibrium capacity

-- Freundlich (lb VOC/lb carb): 2.7819 Carbon working capacity (lb VOC/lb carbon): 1.3909

1 Flow rate calculated using 219.6 turnovers/yr and 22754.81 gal for working loss and breathing loss emission rate (0.0266 lb/hr) and vapor density (0.0274 lb/ft3) for 7 tanks 2 Assumed ambient temperature 3 Assumed ambient pressure 4 Based on model tank emissions 5 The K and M constants were calculated using a mole fraction weighting of the emission components (see "Heat content
- mid tanks"). **Table 1. Freundlich Constants for Selected Compounds.** These constants fit the following equation: Q = K(P)^M where: Q = equilibrium adsorption capacity (lb/lb carbon), P = VOC partial pressure (psia at 1 atm & listed temperature) Correlation Range (psia) VOC name VOC number K M Temperatur e (F) Minimum Maximum Benzene 1001 0.597 0.176 77 0.0001 0.05 Chlorobenzene 1002 1.05 0.188 77 0.0001 0.01 Cyclohexane 1003 0.508 0.210 100 0.0001 0.05 Dichloroethane 1004 0.976 0.281 77 0.0001 0.04 Phenol 1005 0.855 0.153 104 0.0001 0.03 Trichloroethane 1006 1.06 0.161 77 0.0001 0.04 Vinyl chloride 1007 0.200 0.477 100 0.0001 0.05 m - Xylene (low

- pressure range) 1008 0.708 0.113 77 0.0001 0.001 m - Xylene (high

- pressure range) 1009 0.527 0.0703 77 0.001 0.05 Acrylonitrile 1010 0.935 0.424 100 0.0001 0.015 Acetone 1011 0.412 0.389 100 0.0001 0.05 Toluene 1012 0.551 0.110 77 0.0001 0.05 Note: This program has been based on data and procedures in Chapter 4 of the OAQPS CONTROL COST MANUAL (5th edition).A

- 6

**Carbon Adsorption Canister System (1,000 lb Canister System)**  COST BASE DATE: CEPCI 1999 390.6 COST ESCALATION: CEPCI 2013 567.3 Capital Costs

-- Carbon canister equipment cost (1,000 lb carbon): ($1999) a $5,600

-- Carbon canister installation cost (1,000 lb carbon): ($1999) a $3,200

-- Carbon canister equipment cost (1,000 lb carbon): ($2013) $8,133

-- Carbon canister installation cost (1,000 lb carbon): ($2013) $4,648 Purchased Equipment Cost ($): ($2013) $8,784 Total Capital Investment ($): ($2013) b $13,432

-- Carbon canister, total (lb) 1000

-- Inlet VOC flowrate (lb/hr) 4.573

-- Carbon working capacity (lb VOC/lb carbon) c 2.0864

-- Days per canister (days/canister) 19.01

-- Number of canister exchanges per year 19.2 Annual Costs Cost of carbon replacement ($/lb)($1999) d 2.00 Cost of carbon replacement ($/lb)($2013) 2.90 Annual cost of carbon replacement $81,005 Annual maintenance e $940 Capital recovery f $1,475 Taxes, insurance, administrative g $537 Total Annual Cost (without credits) $83,957

a Cost from Section 1.3.2 of Carbon Adsorbers from the EPA Control Cost Manual b Includes vessel, instrumentation, sales tax, and freight
c Assumes 75% of the equilibrium capacity d Average carbon cost from Section 1.3.2 of Carbon Adsorbers from the EPA Control Cost Manual
e Assumes 7% of installed capital cost f Assumes 15 year equipment life and 7% interest g Assumes 4% of installed capital costA

- 7

**Total Tank Control Costs** Total Capital Investment ($): ($2013) 1,000 lb canister system $13,432 ducts $24,717 flame arrestor $31,600 $69,749 per facility $139,497 per source category Total Annual Cost (with credits) 1,000 lb canister system $83,957 ducts $6,819 flame arrestor $5,166 $95,943 per facility $191,886 per source category