MEMORANDUM

DATE: May 26, 2014 

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 

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

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

and Recovery Operations (OSWRO) MACT standards (40 CFR part 63, subpart DD) apply to 

major sources of hazardous air pollutants (HAP) emissions 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, CAA 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 

every 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 

considers 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 

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

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

identified 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 and amended the rule on July 20, 1999. Subpart DD applies to certain waste management 

and 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 

and the operation is regulated under 40 CFR part 279 subpart F (Standards for Used Oil 

Processors and Refiners). 

 A recovery operation that recycles or reprocesses 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 delivered, 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 

Resource 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: 

 Off-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 

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

We 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 45 facilities that are 

subject to the emission limits, monitoring, recordkeeping and reporting requirements of the 

regulation. 

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

Considered 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 waste 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

Containers

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/absorbers

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

modifications
5 

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 “RACT,” “BACT,” and “LAER” are acronyms for different program requirements 

relevant to the NSR program. RACT, or Reasonably Available Control Technology, is required 

on sources 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 Technology 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 

control 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 

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

process 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 

HAP 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, 

processes 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 

Vessels and Transfer Operations, Equipment Leaks, and Closed Vent Systems and Control 

Devices (“Uniform Standards”) (40 CFR part 65, subparts H, I, J and M), which were proposed 

on March 26, 2012, were also considered in this review. Although these analyses are 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 these emission points would generally be 

cost effective for similar emission points at OSWRO facilities. 

Potential developments in practices, processes and control technologies were identified through 

the review of subsequent air toxics regulations and the proposed Uniform Standards for storage 
7 

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 

specific 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 

processes at OSWRO facilities, emissions from different units, emissions release point 

parameters, 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 

technologies 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, 

process 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. 

For 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 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 

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 

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 roof must 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

Size Control Level

(m3)

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 used 
9 

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 

several 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 

HON thresholds is that tanks of capacities of 75 cubic meters (m3

) and up to 151 m3 would be 

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

greater, 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 

efficiency (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

Applicability Threshold

Control 

Level

Option 1 

Requirements

Option 2 

If Size Requirements

(m3) is

And Vapor 

Pressure 

(kPa) is

Options 1 and 

2

Less than 75 < 76.6 1 Fixed roof 

≥ 76.6 2

a

95% controlb98% controlb

75 ≤ capacity 

< 151

< 13.1 1 Fixed roof

≥ 13.1 2 95% controlb98% 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 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 Control Level 2 size and vapor pressure ranges 

shown in Table 3 were estimated using the OSWRO survey data, which was then scaled up to 

nationwide 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 size and vapor pressure type using the EPA’s TANKS 4.09d2

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 Tank Population Based on CAA 114 Survey Responses

Tank Size/Vapor Pressure

(TS/VP)

Estimated 

Number of 

Tanks in the 

OSWRO 

Source 

Category

Explanation

TS/VP1

≥ 75 m3and ≥ 27.6

kPa 78 tanks

Two of 15 facilities have tanks with this size and 

vapor pressure. Total number of tanks for 2 

facilities is 25, or 13 tanks per facility. Scaling 

up to 45 facilities, 2/15 x 45 = 6 facilities have 

13 tanks each or 78 total tanks.

TS/VP2

75 - 151 m3and 

13.1 ≤ kPa < 27.6 21 tanks

One of 15 facilities has tanks with this size and 

vapor pressure. Total number of tanks for this 

facility is 7. Scaling up to 45 facilities, 1/15 x 45

= 3 facilities have 7 tanks or 21 total tanks.

TS/VP3

≥ 151 m3 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 

45 facilities, 3/18 x 45 = 8 facilities have 1 tank 

each or 8 total tanks.

Number of tanks requiring 

Level 2 control under current 

OSWRO requirements

86 tanks (TS/VP1+TS/VP3)

Additional number of tanks 

requiring Level 2 control 

under Option 1

21 tanks (TS/VP2)

Number of tanks requiring 

Level 2 control and 98% 

emission reduction under 

Option 2 

107 tanks (TS/VP1+TS/VP2+TS/VP3)
12

Table 5. Estimation of Tank HAP Emission Potential

Size and Vapor 

Pressure 

Range

Capacity1

(gal/m3)

Height1

(Ft)

Diameter1

(ft)

Throughput

2

(gal)

Tank 

Contents 

Vapor 

Pressure3

Location4 Tank HAP Contents5

Speciated and Total 

HAP Emission

Potential6

(lb/yr)

Tank ≥ 75 m3

and ≥ 27.6 kPa

30,000 gal

(113.6 m3)

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% toluene 215

12.5% tetrachloroethylene 137

12.5% methanol 943

Total 15,675

Tank 75 -151

m3and 

13.1<kPaa<27.6

25,000 gal

(94.6 m3)

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

Tank ≥ 151 m3

and kPa ≥ 5.2

60,000 gal

(227.1 m3)

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 Capacity, 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 m3

) tank - 

average 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 the nationwide uncontrolled HAP emissions from the additional tanks that would 

require Level 2 control under Option 1. This was calculated using the estimated tank population 

(TS/VP2) 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 EmissionsTanks: 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 the baseline nationwide HAP emissions from the OSWRO tanks that are currently 

controlled, together with the controlled emissions from the additional tanks that would require 

Level 2 control under Option 1. This was calculated using the estimated tank populations shown 

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

in Table 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 lbyr)] × 0.05

2,000 lb

ton

= 37.1 tpy

Option 2 HAP Emissions =

[(8 tanks × 13,368 lb

yr) + (78 tanks × 15,675 lbyr) + (21 tanks × 7,300 lbyr)] × 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 

estimate the costs for requiring these additional storage tanks 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, and the only additional costs 
14

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 Manual3, 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 

recuperative 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 

calculations were based on data in the EPA Air Pollution Control Cost Manual3

. In addition, the 

median flowrate from tanks from OSWRO facilities using a thermal oxidizer (729 scfm) was 

used 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. 

For 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 operate 

continuously 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 source category have tanks that require Level 2 controls4

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 

Emissions

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 devices.

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 

lines, 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 

equipment. 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 

operate in off-site material service.5 For all of the equipment in off-site waste service subject to the 

standards, 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

subpart V

40 CFR part 63

subpart H

Valves in gas/vapor service and light 

liquid service

Conduct 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 definition 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 

10,000 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 500 ppm annually (or less 

often up to once every 4 years 

depending on leak rate)

Pressure relieve devices in gas/vapor 

service

Operate with no 

detectable emissions (i.e., 

less than 500 ppm above 

background) or equipped 

with a rupture disk or 

routed to an air pollution 

control device

Same as Part 61, Subpart V

Open-ended valves or lines

Equip 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 

stringent 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 

valves 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 

CFR part 63 subpart H. Consequently, we investigated these 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 

independent calculations of the cost effectiveness of monitoring these three equipment types (valves in 

gas/vapor and in light liquid service, pumps in light liquid service, and connectors in gas/vapor and in 

light liquid service) at the alternative levels. Also, as instrument monitoring of connectors can be an 
17

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

definitions 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 “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).” 

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 requirements for the other types of equipment are largely the same under 40 CFR 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 

monitoring; 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

Instrument 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 Equipmenta

Pumps (light liquid service) 27

Valves (light liquid service)b910

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 

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

the baseline (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 Type7

Type of Equipment Emission Factor (kg/hr/equipment piece)

Baseline Option 1/Option 2

Pump Seals – Light Liquid Service 2.05E-03 5.69E-04

Valves - Light Liquid Service 3.19E-04 1.90E-04

Connectors – Gas/Vapor and Light Liquid Service 2.51E-04 2.51E-04/1.33E-04

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 determine 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 

cost 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 

(45 Facilities)

Baseline 

(subpart 

V)a

Option 1

(subpart H, w/o 

connectors)b

Option 2 

(subpart 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 -- $180,415

Annualized Cost Above Baseline -- $808 -- $36,362

Cost Effectiveness -- $2,087 -- $2,087

Valves in 

light liquid 

service

HAP Emissions 2.8 1.7 126.2 75.1

HAP Emission Reduction From Baseline -- 1.1 -- 51.1

Capital Cost Above Baseline -- $3,059 -- $137,662

Annualized Cost Above Baseline -- $684 -- $30,758

Cost Effectiveness -- $602 -- $602

Connectors

HAP Emissions 3.3 3.3 1.7 147.3 147.3 77.8

HAP Emission Reduction From Baseline -- -- 1.5 -- -- 69.6

Capital Cost Above Baseline -- -- $34,186 -- -- $1,538,356

Annualized Cost Above Baseline -- -- $10,384 -- -- $467,300

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 From Baseline -- 1.5 3.1 -- 68.5 138.1

Incremental Emission Reduction 

(baseline option 1, option 1-->2) -- 1.5 1.5 -- 68.5 69.6

Capital Cost Above Baselined-- $7,068 $41,254 -- $318,076 $1,856,433

Annualized Cost $5,576 $7,068 $17,452 $250,932 $318,052 $467,300

Annualized Cost Above Baseline -- $1,492 $11,876 -- $67,120 $534,420

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 

materials 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 the OSWRO 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 included 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 routing the organic HAP vapors and gases 

from the process vent through a closed vent system to an organic emissions control device. Considering 

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

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

thermal 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 

system 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 

achieve 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 vents, assuming the use of a thermal oxidizer to achieve this HAP emissions 

destruction 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 use thermal oxidizers to control their process vent emissions and comply with 

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

emissions at different control levels from these five facilities. 

Table 12. OSWRO Facilities with Thermal Oxidizer for Process Vent Emissions 

Facility

Reported 

Emissions

(tpy)

Estimated 

Uncontrolled 

Emissions

(tpy)

Estimated 

Emissions 

at 95% 

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 Chemical 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 

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

reported 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 

estimated based on the uncontrolled emissions, and the estimated emissions reductions between 95 and 

98 percent control were calculated. 

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

effectiveness 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 emitted 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 

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

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

facilities, 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 vents9and that only 8 of those would need to 

install new equipment to meet the 98% control requirement10.

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 is 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 Parameters

1

Model Plant 

Cost 

Estimate 

OSWRO 

Source 

Category2 

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 require 

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 Treatmenta

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 INCINERATOR, 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, ROTARY 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 SNPBCDF-070.01 MMDSCF/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.

99
A1-2 

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

BAGHOUSE 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 

REMEDIATION

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 EXISTING SOLID WASTE 

DISPOSAL WITH LANDFILL 

GAS GENERATION

32272000 TONS OF 

WASTE

ACTIVE GAS 

COLLECTION AND 

CONTROL SYSTEM

98

aOff-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): 12.3000
TANKS 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 1,216.88
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): 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): 15.1000
TANKS 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 82.19 943.13
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): 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): 16.5000
TANKS 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, admin. factor: 0.04

 

ANNUAL COSTS Cost ($/yr) Wt.Fact.

Electricity $445 0.449631287

Taxes, insurance, administrative $146 0.146966212

Capital recovery $400 0.403402501

------------------------------------------------------------------------------------------------------------------------

Total Annual Cost $990 1
A3-2 

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 

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 stainless 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 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 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

Other 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 0.95435

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+00 1.5581

* Emissions are based on 78 tanks at <151 m3 and kPa >27.6, 21 tanks at 75 to 151 m3 and kPa between 13.1 and 27.6, and 8 tanks >151 m3 and kPa > 5.2

spread between 10 facilities
A4-2 

TOTAL ANNUAL COST SPREADSHEET PROGRAM--RECUPERATIVE THERMAL 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 - Escalated $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 Manufacturing 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.gov/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 Costs
A5-1 

Baseline Option 1 Option 1

Type of Component

valves - 

gas vapor 

valves - 

light liquid

valves - 

gas vapor 

valves - 

light liquid

Connectors (light 

liquid flanges)

Number of Components 27 27 0 910 0 910 1,350

Initial Monitoring Fee or Unit Cost ($/comp) $0 $0 $0 $0 $0 $0 $24

Initial Monitoring Costs ($/yr) (Capital) $692 $3,857 $0 $224 $0 $3,283 $32,331

Initial Pump Seal Replacement Costs ($/yr) (Capital) $185 $1,029 NA NA NA NA NA

Initial LDAR Admin. Costs $0 $0 $0 $0 $0 $0 $1,854

Frequency of Monitoring (times/yr) 12 12 2 2 2 2 0.25

Subsequent Monitoring Fee ($/comp) $2 $2 $2 $2 $2 $2 $3

Annual Monitoring Costs ($/yr) $1,044 $1,044 $0 $2,730 $0 $2,730 $844

Annual Maintenance Costs ($/yr) $211 $238 $0 $0 $0 $0 $0

Initial Leak Frequency (%) 2.42 13.48 0.33 0.33 7.24 4.84 0.36

Initial Number of Leaks 0.65 3.64 0.00 3.00 0.00 44.04 4.86

Subsequent Leak Frequency (%) 0.23 0.26 0.33 0.33 0.51 0.51 0.36

Annual Number of Leaks 0.75 0.84 0.00 6.01 0.00 9.28 1.22

Percent Repaired OnLine 100.00 100.00 75.00 75.00 75.00 75.00 75

Repair Time (hours) 16.00 16.00 0.17 0.17 0.17 0.17 0.17

Repair Labor Charge ($/hr) $66 $66 $66 $66 $66 $66 $66

Annual OnLine Leak Repair Cost ($/yr) $790 $893 $0 $50 $0 $77 $10

Percent Requiring Further Repair 0.00 0.00 25.00 25.00 25.00 25.00 25

Repair Time (hours) 80.00 80.00 4.00 4.00 4.00 4.00 2.00

Replacement Pump Seals ($) $283 $283 NA NA NA NA NA

Annual Offline Leak Repair Cost ($/yr) $0 $0 $0 $398 $0 $615 $40

Monitoring to Verify Repair ($) $1 $1 $0 $9 $0 $14 $3

Annual Admin. Cost ($/yr) $0 $0 $0 $0 $0 $0 $4,636

Annual Misc. Charges ($/yr) $169 $191 $0 $0 $0 $0 $0

Total Capital Costs $877 $4,886 $34,186

Annualized Capital Costs $143 $799 $4,854

Annual Expenses $2,214 $2,367 $5,530

Grand Total (Annual Expenses + Annualized Capital 

Costs) $2,358 $3,166 $10,384

Incremental cost $808 $10,384

Option1

OSWRO model plant

OSWRO Equipment Leaks Costs

$224

$32

$3,187

$3,218

Baseline

$3,283

$466

$3,436

$3,902

$683

pumps - light liquid service

Baseline or Option
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/lbmole)

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

Ethane 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 0.00 605 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): 1600

 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

 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
A6-3 

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 $410,602

1 Median 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 Operators 

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.htm
A6-4 

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 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.): 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): 0.109794625

 Taxes, insurance, admin. factor: 0.04

 

ANNUAL COSTS Cost ($/yr) Wt.Fact.

Electricity $1,897 0.372780515

Taxes, insurance, administrative $852 0.167487848

Capital recovery $2,340 0.459731636

------------------------------------------------------------------------------------------------------------------------

Total Annual Cost $5,089 1
A6-5 

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-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 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 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 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 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