MEMORANDUM

DATE: January 31, 2014

SUBJECT: Supplemental Technology Review for Equipment Leaks in Group IV Polymers 

and Resins, Pesticide Active Ingredient Production, and Polyether Polyols 

Production Source Categories

FROM: Nick Parsons, EPA/OAQPS/SPPD/RCG

TO: EPA Docket File (EPA-HQ-OAR-2011-0435)

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. These technologybased standards are often referred to as maximum achievable control technology (MACT) 

standards. Section 112 also contains provisions requiring the EPA to periodically revisit these 

standards. Specifically, 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 three 

NESHAP: Group IV Polymers and Resins (P&R IV) under 40 CFR part 63, subpart JJJ 

(subpart JJJ), Pesticide Active Ingredient Production (PAI) under 40 CFR part 63, subpart MMM 

(subpart MMM), and Polyether Polyols Production (PEPO) under 40 CFR part 63, subpart PPP 

(subpart PPP). Based on this technology review, the EPA proposed rule revisions to subparts JJJ, 

MMM, and PPP on January 9, 2012. Comments were received indicating that the EPA was 

deficient in its technology review and identified the following as improvements in technologies 

that EPA should consider for equipment leaks:

the use of low-leak technologies;

the use of passive optical gas imaging (OGI) devices;

lowering the leak definition for valves, connectors and other equipment to 100 ppm and 

lowering the leak definition for pumps, compressors, and pressure relief devices to 

500 ppm; and

requiring tighter timelines of minimization of leaks within 24 hours of identification and 

repairs within seven days.

The purpose of this memorandum is to provide a supplemental technology review to address any 

deficiencies with the original technology review as expressed by the commenters. 
2

2.0 REVISED TECHNOLOGY REVIEW FOR EQUIPMENT LEAKS

Equipment leaks are emissions emanating from pumps, compressors agitators, pressure relief 

devices, sampling connection systems, open-ended valves or lines, valves, connectors or 

instrumentation systems. The amount of HAP emissions from equipment leaks is proportional to 

the type and number of equipment components, and the concentration of HAP constituents of the 

stream passing through the components.

This section presents the supplemental technology review conducted for equipment leaks in the 

P&R IV, PAI, and PEPO source categories. Section 2.1 presents a summary of the level of 

control required by the current MACT standards. Section 2.2 presents an analysis of each of the 

improvements in technologies for reducing equipment leak emissions that were identified by 

commenters to determine whether they are appropriate and cost effective for these source 

categories under section 112(d)(6).

2.1 Summary of Existing MACT Level of Control

For each of the source categories, each piece of equipment subject to the standards is required to 

comply with the provisions of 40 CFR part 63, subpart H. The relevant provisions of part 63 

subpart H are as follows:

Valves in gas and vapor service: conduct monthly EPA Method 21 monitoring; leak 

definition of 500 ppm.

Pumps in light liquid service: conduct monthly EPA Method 21 monitoring; leak 

definition of 1,000 ppm (repair required at 2,000 ppm).

Connectors: sensory monitoring.

Pressure relief devices (PRD) in gas/vapor service: operate with no detectable emissions 

(i.e., less than 500 ppm) or equip with a rupture disk / or route to an air pollution control 

device.

Open-ended lines (OEL) or valves: equip with a sealed cap or comparable device. 

2.2 Evaluation of Potential Developments in Technology for Equipment Leaks

Based on comments received on the proposed amendments to subparts JJJ, MMM and PPP, the 

following control options were evaluated: 

the use of low-leak technologies;

lowering the leak definition for valves, connectors and other equipment to 100 ppm and 

lowering the leak definition for pumps, compressors, and pressure relief devices to 

500 ppm; and

requiring tighter timelines for minimization of leaks to within 24 hours of identification 

and repairs within seven days.

We did not evaluate the use of OGI devices, since the General Provisions for NESHAP at 40 

CFR 63.11(c) through (e) already allows the use of OGI with an annual EPA Method 21 survey 
3

of all of the equipment as an alternative work practice to the traditional leak detection and repair 

(LDAR) monitoring program (e.g., EPA Method 21). 

2.2.1 Model Plants for the P&R IV, PAI, and PEPO Source Categories

Cost estimates and emissions reductions for these control options were estimated using a model 

plant approach to represent equipment counts found at different types of chemical and refining 

facilities.

For the P&R IV source category, no information was readily available regarding component 

counts of model plants that were used for equipment leaks at facilities with P&R IV process 

units. As a result, it was assumed that the P&R IV source category could be best represented by 

the simple, medium, and complex model plants developed for the chemical industry.1Table 1 

presents the model plant component counts for estimating equipment leak impacts from the P&R 

IV source category. 

For the PAI and PEPO source categories, model plant equipment component counts were 

developed for the original MACT standards and are also presented in Table 1.2,3For each model 

plant, the types of equipment included in this analysis are as follows: pumps in light liquid 

service; valves in gas/vapor and light liquid service; connectors in gas and light liquid service; 

pressure relief devices (PRDs); and open ended lines (OELs).

 

1 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.

2 Memorandum from Randall, D. and Karen Schmidtke, Midwest Research Institute to Banker, L., EPA/OAQPS. 

Model Plants for the Pesticide Active Ingredient Manufacturing Industry. April 30, 1997. (included in the 

Supplementary Information Document (SID) for the PAI Proposed NESHAP)

3 Memorandum from Hendricks, D. and Joanne Seaman, EC/R Incorporated to Svendsgaard, D., EPA/OAQPS. 

Estimated Impacts for the Polyether Polyols NESHAP. April 25, 1997. (included in the Supplementary Information 

Document (SID) for the PEPO Proposed NESHAP)
4

Table 1. Model Plants for the P&R IV, PAI, and PEPO Source Categories

Equipment 

Component

Number of Components

P&R IV Source Category

PAI Source 

Category PEPO Source Category

Simple 

Model 

Plant

Medium 

Model 

Plant

Complex 

Model 

Plant

Batch 

Model 

Plant

Continuous 

Model 

Plant

Small 

Model 

Plant

Large 

Model 

Plant

Solvent 

Extraction 

Model 

Plant

Pumps (light liquid 

service) 15 40 56 14 33 2 13 5

Valves (gas/vapor 

service) 77 414 1,379 65 240 125 3 57

Valves (light liquid 

service) 380 1,179 1,980 340 1,100 166 392 218

Connectors (light 

liquid service) 731 2,662 7,410 1,100 1,500 409 385 219

PRDs 2 45 76 2

a

45a8 11 34

OELs 33 141 424 33a141a0 7 58

a No PRDs or OELs were included in model plants in the analysis for the original MACT standards. It was assumed 

that the number of PRDs and OELs at batch and continuous plants would best be represented by the simple and 

medium model plants developed for the chemical industry.

2.2.2 Number of Facilities Represented by Each Model Plant Type

For each source category, the current number of facilities that would be represented by each of 

the model plant types was unknown. Therefore, the number of facilities represented by each type 

of model plant was assigned for the purposes of this analysis. Table 2 presents the distribution of 

the currently identified facilities across the P&R IV, PAI, and PEPO model plants.

From documentation created during development of the P&R IV MACT standards, no 

information was found regarding the distribution of facilities across model plant types. 

Therefore, it was assumed that there would be a relatively even distribution of the currently 

identified facilities across the model plants as follows: 33 percent of facilities would be 

represented by the simple model plant, 34 percent of facilities would be represented by the 

medium model plant, and 33 percent of facilities would be represented by the complex model 

plant.

During the development of the PAI MACT standards, 175 facilities were identified. 138 were 

represented by the batch model plant (79 percent), and 37 were represented by the continuous 

model plant (21 percent). The 18 currently identified PAI facilities were distributed across the 

batch and continuous model plants in the same proportions. As a result, it was estimated that 

there are 14 currently identified facilities represented by the batch model plant and 4 represented 

by the continuous model plant.

For the PEPO source category, during the development of the MACT standards, there were 77 

facilities identified in the source category. Twenty were represented by small model plants (26 

percent of the total facilities), 38 were represented by large model plants (49 percent of the total 

facilities), and 19 were represented by solvent extraction model plants (25 percent of the total 

facilities). The 23 currently existing facilities were distributed across the three model plants in 
5

the same proportions. Therefore, 6 are represented by the small model plant, 11 are represented 

by the large model plant, and 6 are represented by the solvent extraction model plant.

Table 2. Distribution of Currently Identified Facilities Across Model Plants for the 

P&R IV, PAI, and PEPO Source Categories

P&R IV Model Plants PAI Model Plants PEPO Model Plants

Simple Medium Complex Total Batch Continuous Total Small Large

Solvent 

Extraction Total

Number of 

facilities 

during 

MACT 

development

Unknowna138 37 175 20 38 19 77

Percent of 

Totalb 33 34 33 100 79 21 100 26 49 25 100

Number of 

currently 

identified 

facilitiesc

10 11 10 31 14 4 18 6 11 6 23

a No information was readily available regarding the model plants for the P&R IV source categories. 

b An even distribution across model plants for P&R IV source categories was assumed.

c Number of currently identified facilities in each model plant category estimated by distributing according to 

percentage of facilities assumed to be in each category during MACT development.

2.2.3 Analysis of Low-Leak Packing

Low-leak packings for valves that significantly reduce emissions are in place in some facilities 

outside the P&R IV, PAI, and PEPO source categories, particularly at oil refineries.4Facilities 

and packing manufacturers have created emission testing protocols for low leak packings in 

order to study and test their effectiveness.5 We analyzed the emissions reductions and costs that 

would be associated with requiring low-leak valve technology for the P&R IV, PAI, and PEPO

source categories.

To determine the baseline emissions from valves, we used the valve component counts for model 

plants (see Table 1) and applied emission factors to determine the baseline emissions. The 

emissions factors used were based on those used in a recent technology review for equipment 

leaks from chemical manufacturing process units and petroleum refineries (Uniform Standards 

analysis)6, but because the factors used in that analysis are for total organic compounds, which 

for chemical manufacturing facilities are generally volatile organic compounds (VOC), these 

factors were modified to reflect the amount of VOC that are expected to be HAP. In a previous 

risk and technology review action for the synthetic organic chemical manufacturing industry 

(SOCMI) subject to the Hazardous Organic NESHAP (HON) (71 FR 34434), HAP emissions 

were assumed to represent 56 percent of the total VOC emissions from the facilities subject to 

the HON. While we have no information about the HAP to VOC ratio for the P&R IV, PAI, and 

PEPO source categories, we assumed that the HAP to VOC ratio would be similar to that of 

 

4

See Reference 1.

5

See Reference Error! Bookmark not defined..

6

See Reference 1.
6

HON facilities, and we applied this ratio to the equipment leak emissions factors used in the 

Uniform Standards analysis. The resulting emissions factors that were used for the P&R IV, PAI, 

and PEPO source categories are shown in Table 3.

Table 3. Equipment Leak Emission Factors by Component Type

Component Type

Emission Factor 

(kg/hr/component)a

Emission factor adjusted for HAP

(kg/hr/component)b

Valves in Gas/Vapor Service 2.03E-04 1.14E-04

Valves in Light Liquid Service 2.32E-04 1.30E-04

a

See Table 6 of Reference 1.

b Emission factors adjusted to reflect the estimated HAP to VOC ratio (56%).

According to information used to estimate costs for low-leak valves for HON facilities, the 

installed cost of a low-leak valve averaged $12,025 each, and the total capital investment and 

total annualized costs are proportional to the number of valves.7Therefore, assuming that 

emissions from valves are constant and that the cost per valve is constant, we calculated the 

capital and annual costs, along with the cost per ton of HAP reduction that would be associated 

with these low-leak valves for the P&R IV, PAI, and PEPO source categories. For this analysis, 

it was assumed that low-leak valves would achieve a 100 percent reduction in HAP emissions 

from valve leaks.

As shown in Table 4, the estimated baseline HAP emissions from valves at the P&R IV, PAI, 

and PEPO model facilities ranged from 0.34 to 4 tons per year (tpy). Applying the cost per valve 

to the number of valves at these model facilities, estimated capital costs per facility ranged from 

$4.4 million to over $50 million, with annualized capital costs ranging from $600,000/year to 

over $7 million/year. Emission reductions were assumed to be 100 percent of the baseline 

emissions and were estimated to range from 0.34 to 4 tpy per model facility, and the cost 

effectiveness ranged from $1.71 million/ton to $1.80 million/ton of HAP reduction. On a source 

category basis, the estimated baseline HAP emissions from valves at facilities in the P&R IV, 

PAI, and PEPO source categories ranged from 10 to 67 tpy. Estimated capital costs per source 

category ranged from $117 million to $839 million, with annualized capital costs ranging from 

$17 million to $119 million/year. Emission reductions were estimated to range from 

approximately 10 to 67 tpy per source category, and the cost effectiveness ranged from $1.74 

million/ton to $1.78 million/ton of HAP reduction.

 

7 Memorandum from Oommen, R., ERG, Morrisville, NC, to McDonald, R., U.S. Environmental Protection 

Agency, OAQPS. Cost and Emission Reduction of Leakless Valves for HON facilities. June 1, 2006. Docket No. 

EPA-HQ-OAR-2005-0475-0105
7

Table 4. Low-Leak Valves Cost Analysis

HAP 

Emissions 

from Valves 

(tpy)a

Number 

of 

Valvesb

Capital and 

Installation 

Cost Per 

Valve ($)c

Capital 

Cost Per 

Facility 

(million $)d

Annualized 

Capital and 

Installation 

Cost Per 

Facility 

(million $)

Emission 

Reduction 

(tpy)e

Cost 

Effectiveness 

(million $/ 

ton HAP 

reduction)f

Number 

of 

Facilitiesg

Capital and 

Installation 

Cost 

(million $)

Annualized 

Capital and 

Installation 

Cost 

(million $)

Emission 

Reduction 

(tpy)

Small Model Plant 0.34 291 15,061 4.4 0.62 0.34 1.83 6 26.3 3.7 2.04

Large Model Plant 0.49 395 15,061 5.9 0.84 0.49 1.72 11 65.4 9.3 5.39

Solvent Extraction Model 

Plant 0.34 275 15,061 4.1 0.59 0.34 1.75 6 24.8 3.5 2.02

23 116.6 16.6 9.45

Batch Model Plant 0.50 405 15,061 6.1 0.87 0.50 1.73 14 85.4 12.13 7.00

Continuous Model Plant 1.64 1,340 15,061 20.2 2.87 1.64 1.75 4 80.7 11.46 6.56

18 166.1 23.6 13.56

Simple Model Plant 0.56 457 15,061 6.9 0.98 0.56 1.75 10 68.8 9.77 5.60

Medium Model Plant 1.93 1,593 15,061 24.0 3.41 1.93 1.77 11 263.9 37.47 21.23

Complex Model Plant 3.99 3,359 15,061 50.6 7.18 3.99 1.80 10 505.9 71.83 39.90

P&R IV Source Category Totals 31 838.6 119.1 66.73

Source Category

Model Plant Nationwide

PEPO

PAI

P&R IV

PEPO Source Category Totals

PAI Source Category Totals

a Calculated using emission factors adjusted for a HAP to VOC ratio of 56 percent, see Table 3 and Appendix 1 of this memorandum.

b Based on model plants for each source category, see Table 1 of this memorandum.

c No cost basis for these values was presented in the SOCMI memorandum. Therefore, it was assumed that these costs were presented in 2005 dollars, and the cost per 

valve of $12,025 was adjusted to 2012 dollars using the Chemical Engineering Plant Cost Index (CE Index). The CE Index for 2005 is 468.2 and is 586.4 for 2012.

d Includes capital costs plus a recovery credit of $500 per ton of HAP not emitted.

e Assumes 100 percent reduction in emissions.

f Cost effectiveness varies depending on the proportion of valves in gas/vapor service and the number in light liquid service.

g Estimated number of plants of each model plant types in the source category, see Table 2 of this memorandum.
8

2.2.4 Reduced Leak Definitions 

As stated above, facilities with processes in the P&R IV, PAI, and PEPO source categories are 

subject to the part 63, subpart H requirements. We analyzed the emissions reductions and costs 

that would be associated with requiring leaks to be repaired at lower detection limits for these 

source categories, consistent with some local or regional regulations, such as those of 

California’s Bay Area Air Quality Management District (BAAQMD). Table 5 presents a 

summary of the current equipment leak requirements and the options that were analyzed on a 

component basis.

Table 5. Summary of Equipment Leak Requirement Options

Type of Equipment

Requirements of P&R IV, PAI, and 

PEPO MACT Standardsa Alternative Option Investigated

Pumps – light liquid 

service

Monthly EPA Method 21 monitoring; 

leak definition of 1,000 ppm (repair not 

required until instrument reading of 

2,000 ppm is reached)

Same as current requirements but with 

lower leak definition of 500 ppm 

Valves – gas and light 

liquid service

Monthly EPA Method 21 monitoring; 

leak definition of 500

Same as current requirements but with 

lower leak definition of 100 ppm 

a Represents compliance with part 63, subpart H.

To determine the baseline emissions from valves and pumps, we used the valve and pump 

component counts for model plants (see Table 1) and applied emission factors to determine the 

baseline emissions and another set of emission factors to determine emissions at the more 

stringent leak definition levels. The emission factors used were based on those used in the 

Uniform Standards analysis but modified to reflect the amount of VOC that are expected to be 

HAP, as discussed previously. The resulting emissions factors that were used for the P&R IV, 

PAI, and PEPO source categories in this analysis are shown in Table 6.

Table 6. Equipment Leak Emission Factors by Component Type at Baseline and with More 

Stringent Leak Definitions

Component Type

Baseline Emission Factor 

(kg/hr/component)a

Emission Factor with More 

Stringent Leak Definition 

(kg/hr/component)a

Valves in Gas/Vapor Service 1.14E-04 1.14E-04

Valves in Light Liquid Service 1.30E-04 1.30E-04

Pumps in Light Liquid Service 3.89E-04 2.97E-04

a Emission factors from Table 6 of Reference 1, adjusted to reflect the estimated HAP to VOC ratio (56%).

Costs were determined for the valve and pump equipment leak baseline conditions and for the 

options for each model plant type for the P&R IV, PAI, and PEPO source categories based on 

information from the Uniform Standards analysis. Initial and ongoing monitoring costs were 

determined for the baseline LDAR program for these components and for a program with more 

stringent equipment leaks definitions. See Appendix 2 for detailed cost information.

As shown in Table 7, the estimated baseline HAP emissions from valves at the P&R IV, PAI, 

and PEPO model facilities ranged from 0.34 to 4.0 tpy. Estimated annual costs per facility 
9

ranged from $3,800/yr to over $81,000/yr. Emission reductions were approximately 11 percent 

of the baseline emissions and were estimated to range from 0.03 to 0.45 tpy per model facility, 

and the cost effectiveness ranged from $15,000/ton to $18,000/ton of HAP reduction, which 

varied depending on the proportion of valves in gas/vapor service and the number in light liquid 

service. On a source category basis, the estimated baseline HAP emissions from valves at 

facilities in the P&R IV, PAI, and PEPO source categories ranged from 10 to 67 tpy. Estimated 

annual costs ranged from $17,000/yr to $132,000/yr. Emission reductions were estimated to 

range from 1.1 to 7.5 tpy per source category, and the cost effectiveness ranged from 

$16,000/ton to $18,000/ton of HAP reduction.

For pumps, as shown in Table 7, the estimated baseline HAP emissions at the P&R IV, PAI, and 

PEPO model facilities ranged from 0.01 to 0.21 tpy. Estimated annual costs per facility ranged 

from approximately $300/yr to over $14,000/yr. Emission reductions were approximately 24 

percent of the baseline emissions and were estimated to range from 0.002 to 0.05 tpy per model 

facility, and the cost effectiveness was approximately $29,000/ton of HAP reduction in each 

case. On a source category basis, the estimated baseline HAP emissions from pumps at facilities 

in the P&R IV, PAI, and PEPO source categories ranged from 0.08 to 0.4 tpy. Estimated annual 

costs ranged from $5,000/yr to $30,000/yr. Emission reductions were estimated to range from 

0.16 to 1 tpy per source category, and the cost effectiveness was approximately $29,000/ton of 

HAP reduction for each source category.
10

Table 7. Reduced Leak Definitions Cost Analysis

Number of 

Valvesa

Baseline 

HAP 

Emissions 

(tpy)b

HAP 

Emissions 

with Valves 

Option (tpy)b

Number of 

Pumpsa

Baseline 

HAP 

Emissions 

(tpy)b

HAP 

Emissions 

with 

Pumps 

Option 

(tpy)b

Number 

of 

Facilitiesc

Annualized 

Cost Above 

Baseline 

($)d

HAP 

Emission 

Reduction 

(tpy)

Annualized 

Cost 

Above 

Baseline 

($)d

HAP 

Emission 

Reduction 

(tpy)

Small Model Plant 291 0.34 0.31 2 0.01 0.01 6 $4,247 0.23 $311 0.01

Large Model Plant 395 0.49 0.44 13 0.05 0.04 11 $9,461 0.63 $3,717 0.13

Solvent Extraction Model Plant 275 0.34 0.30 5 0.02 0.01 6 $3,790 0.23 $779 0.03

23 $17,498 1.09 $4,807 0.16

Batch Model Plant 405 0.50 0.44 14 0.05 0.04 14 $12,773 0.80 $5,095 0.17

Continuous Model Plant 1,340 1.64 1.45 33 0.12 0.09 4 $12,200 0.75 $3,431 0.12

18 $24,973 1.55 $8,526 0.29

Simple Model Plant 457 0.56 0.50 15 0.06 0.04 10 $10,395 0.64 $3,899 0.13

Medium Model Plant 1,593 1.93 1.71 40 0.15 0.11 11 $40,784 2.41 $11,438 0.39

Complex Model Plant 3,359 3.99 3.54 56 0.21 0.16 10 $81,247 4.45 $14,558 0.50

P&R IV Source Category Totals 31 $132,427 7.49 $29,895 1.02

PAI

P&R IV

PEPO

Valves Option Pumps Option

PEPO Source Category Totals

PAI Source Category Totals

Valves Pumps

Source Category/ Model Plant Type

Model Plant Nationwide

a Based on model plants for each source category, see Table 1 of this memorandum.

b Calculated using emission factors adjusted for a HAP to VOC ratio of 56 percent, see Appendix A of this memorandum.

c Estimated number of plants of each model plant types in the source category. See Table 2 of this memorandum.

d Includes a recovery credit of $500/ton of HAP not emitted.
11

2.2.4 Limits on the Number of Components Awaiting Repair 

The BAAQMD Regulation 8, Rule 18 limits the number of components awaiting repairs to 

0.3 percent for valves, 0.025 percent for valves with major leaks (i.e., leaks greater than 10,000 

ppm, including methane) and 1.0 percent for pumps and compressors. The BAAQMD also 

requires mass emission testing for non-repairable components with high leak rates and places an 

emission limit of 15 lbs/day on non-repairable components. A similar rule in place for 

California’s South Coast Air Quality Management District (SCAQMD), Rule 1173, has limits 

for the number of components awaiting repairs of 0.5 percent for valves and 1.0 percent for 

pumps. As stated above, facilities with processes in the P&R IV, PAI, and PEPO source 

categories are subject to the part 63, subpart H requirements. These requirements allow a delay 

of repair for all components, under certain conditions, until the next process shutdown.

Background data for the proposed amendments to the BAAQMD Regulation 8 Rule 18 provides 

incremental costs associated with their amendment that lowers the number of components 

awaiting repairs from 0.5 percent for valves and 1.0 percent for pumps, compressors, and 

pressure relief devices to 0.3 percent for valves and 1.0 percent for pumps, compressors, and 

pressure relief devices.8The BAAQMD analysis was conducted for five refineries located in the 

Bay Area. The estimated reduction in VOC emissions from the Regulation 8 Rule 18 

amendments over that of the current requirements was 73 tpy (or 43 percent).9In this analysis, 

the BAAQMD estimated that an incremental total annualized cost associated with their 

amendment ranged from $34,000 to $172,000/yr per facility.10 These costs are primarily related 

to the annual costs of conducting mass emission rate determinations and the cost to capture and 

control valves with excessive leaks. The BAAQMD estimated that the mass emission rate 

determinations would apply to 60 valves per facility (or about 0.13 percent of the average 

number of valves at a facility) and estimated that the annualized cost of conducting the mass 

emission rate determinations would be range from $20,000 to $114,000/yr, 11 with the midpoint 

of the range at $67,000/yr or $1,120/yr/valve. Of these 60 valves, the BAAQMD assumed that 

about 0.0025 percent of the total number of valves would be required to be controlled, or 2 

valves per facility. The estimated annual cost of controlling these valves ranged from $15,000 to 

$58,000/yr per facility,12 with a midpoint of $36,500 per year or $18,250/yr/valve.

We applied the BAAQMD approach to the P&R IV, PAI, and PEPO source categories model 

plants (see Table 1), assuming the BAAQMD incremental emissions reductions and costs would 

apply to these source categories. The results of this analysis are presented in Table 8. As shown 

in Table 8, the annualized cost associated with mass emission rate determinations for the P&R 

IV, PAI, and PEPO source categories was estimated to range from $1,120/yr to $5,600/yr and the 

annualized cost associated with control of valves with excessive leaks for each of the model 

plants was $18,250/yr. The total program annualized cost ranged from $19,000/yr to 24,000/yr. 

The cost effectiveness ranged from $10,500/ton HAP reduction to $99,000/ton HAP reduction.

 

8 Douglas, Victor, Compliance and Enforcement Division, BAAQMD. Draft Staff Report: Proposed Amendments 

Regulation 8 Rule 18: Equipment Leaks Control Measure SS-16. December 2003.

9

In the draft staff report (see reference 8) emissions reductions were reported as “organic emissions,” which we 

assume to be VOC. 

10 BAAQMD Costs were assumed to be in 2003 dollars. Costs escalated to 2012 dollars using the Chemical 

Engineering Plant Cost Index. CE Index for 2003 is 402 and for 2012 is 584.6.

11 See Reference 8.

12 See Reference 8.
12

Table 8. Analysis of Applying the BAAQMD Approach for Controlling Valves with Excessive Leaks to the P&R IV, PAI, and 

PEPO Source Categories

a See Table 2 for model plant parameters (i.e., component count).

b Rounded up to the nearest whole number of valves.

c Costs presented in BAAQMD draft staff report (See Reference 8) were escalated to 2012 dollars.

d Calculated by multiplying the cost per valve from the BAAQMD estimate to the number of valves in each model plant.

Batch Continuous Small Large Solvent 

Extraction Simple Medium Complex

Number of Valves per facility 46,600 405 1340 291 395 275 457 1,593 3,359

Current Emissions (tpy) 25.8 0.50 1.64 0.34 0.49 0.34 0.56 1.93 3.99

Percent Reduction (%) 4 3 4 3 4 3 4 3 4 3 4 3 4 3 4 3 4 3

Emission Reduction (tpy) 14.7 0.28 0.93 0.20 0.28 0.19 0.32 1.10 2.27

Percent of total valves requiring 

mass emission determination 0.13% - - - - - - - - - - - - - - - -

Number of valves requiring mass 

emission determinationb

6 0 1 2 1 1 1 1 3 5

Annualized cost of mass emission 

determination ($/yr) 67,000c 1,120 2,240 1,120 1,120 1,120 1,120 3,360 5,600

Annualized cost of mass emission 

determination per valve ($/yr/valve) 1,120 - - - - - - - - - - - - - - - -

Percent of valves with excessive 

leaks requiring control (%) 0.0025 0.0025 0.0025 0.0025 0.0025 0.0025 0.0025 0.0025 0.0025

Number of valves with excessive 

leaks requiring control 2 1 1 1 1 1 1 1 1

Annualized cost of control of 

valves with excessive leaks ($/yr)d 36,500c 18,250 18,250 18,250 18,250 18,250 18,250 18,250 18,250

Annualized cost of control of 

valves with excessive leaks per 

valve ($/yr/valve)

18,250 - - - - - - - - - - - - - - - -

Total annualized cost of BAAQMD 

program ($/yr) 103,500 19,370 20,490 19,370 19,370 19,370 19,370 21,610 23,850

101,333 60,675 19,649 10,488

Polyether Polyols Model Plant Polymers and Resins IV Model 

Plant

Cost Effectiveness ($/ton) 7,041 68,396 21,919 98,573 68,786

Cost Parameter BAAQMD Cost 

Estimate

Pesticide Active Ingredients Model 

Plant
Appendix 1

Detailed Baseline Valve Emissions Estimation Information for P&R IV, 

PAI, and PEPO Source Categories
A1-1

P&R IV Baseline Emissions

Type of Equipment

Emission Factor 

(kg/hr/component) Model Plant 1 - Simple Model Plant 2 - Medium Model Plant 3 - Complex

Baseline*

No. of 

Components

Baseline 

Emissions 

(tpy)

No. of 

Components

Baseline 

Emissions 

(tpy)

No. of 

Components

Baseline 

Emissions 

(tpy)

Valves

Gas/Vapor Service 1.14E-04 77 0.08 414 0.45 1,379 1.51

Light Liquid Service 1.30E-04 380 0.48 1,179 1.48 1,980 2.48

Valves Total 0.56 1.93 4.00

PEPO Baseline Emissions

Type of Equipment

Emission Factor 

(kg/hr/component) Model Plant 1 - Small Model Plant 2 - Large

Model Plant 3 - Solvent 

Extraction

Baseline*

No. of 

Components

Baseline 

Emissions 

(tpy)

No. of 

Components

Baseline 

Emissions 

(tpy)

No. of 

Components

Baseline 

Emissions 

(tpy)

Valves

Gas/Vapor Service 1.14E-04 125 0.14 3 0.00 57 0.06

Light Liquid Service 1.30E-04 166 0.21 392 0.49 218 0.27

Valves Total 0.35 0.50 0.34
A1-2

PAI Baseline Emissions

Type of Equipment

Emission Factor 

(kg/hr/component) Model Plant 1 - Batch

Model Plant 2 -

Continuous

Baseline*

No. of 

Components

Baseline 

Emissions 

(tpy)

No. of 

Components

Baseline 

Emissions 

(tpy)

Valves

Gas/Vapor Service 1.14E-04 65 0.07 240 0.26

Light Liquid Service 1.30E-04 340 0.43 1,100 1.38

Valves Total 0.50 1.64

*Baseline emission factor represents emissions after 40 CFR part 63 subpart H controls. Emission factor is for total organic compounds (TOC) from Table 6 of the 

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, and it is assumed that the TOC is VOC, and 56% of this is HAP based on the HON RTR proposal (National Emission Standards 

for Hazardous Air Pollutants for Organic Hazardous Air Pollutants from the Synthetic Organic Chemical Manufacturing Industry: Proposed Rule. 71 FR 34422, June 14, 

2006.).
Appendix 2

Detailed Cost Information for P&R IV, PAI, and PEPO LDAR Program 

with Reduced Leak Definitions for Valves and Pumps
A2-1

Baseline Baseline Option 1 Option 1 Baseline Baseline Option 1 Option 1 Baseline Baseline Option 1 Option 1

Type of Component valves - gas 

vapor 

valves - light 

liquid

valves - gas 

vapor 

valves - light 

liquid

valves - gas 

vapor 

valves - light 

liquid

valves - gas 

vapor 

valves - light 

liquid

valves - gas 

vapor 

valves - light 

liquid

valves - gas 

vapor 

valves - light 

liquid

Number of Components 77 380 77 380 414 1179 414 1179 1379 1980 1379 1980

Initial Monitoring Fee or Unit Cost ($/comp) $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00

Initial Monitoring Costs ($/yr) (Capital) $451.22 $1,488.63 $1,412.46 $4,595.80 $2,426.04 $4,618.68 $7,594.26 $14,259.06 $8,080.94 $7,756.57 $25,295.85 $23,946.51

Initial LDAR Admin. Costs

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

Subsequent Monitoring Fee ($/comp) $1.61 $1.61 $1.61 $1.61 $1.61 $1.61 $1.61 $1.61 $1.61 $1.61 $1.61 $1.61

Annual Monitoring Costs ($/yr) $247.94 $1,223.60 $247.94 $1,223.60 $1,333.08 $3,796.38 $1,333.08 $3,796.38 $4,440.38 $6,375.60 $4,440.38 $6,375.60

Annual Maintenance Costs ($/yr)

Initial Leak Frequency (%) 7.24 4.84 12.24 8.07 7.24 4.84 12.24 8.07 7.24 4.84 12.24 8.07

Initial Number of Leaks 5.5748 18.392 9.4248 30.666 29.9736 57.0636 50.6736 95.1453 99.8396 95.832 168.7896 159.786

Subsequent Leak Frequency (%) 0.51 0.51 0.61 0.61 0.51 0.51 0.61 0.61 0.51 0.51 0.61 0.61

Annual Number of Leaks 0.7854 3.876 0.9394 4.636 4.2228 12.0258 5.0508 14.3838 14.0658 20.196 16.8238 24.156

Percent Repaired OnLine 75 75 50 50 75 75 50 50 75 75 50 50

Repair Time (hours) 0.167 0.167 0.167 0.167 0.167 0.167 0.167 0.167 0.167 0.167 0.167 0.167

Repair Labor Charge ($/hr) $71.93 $71.93 $71.93 $71.93 $71.93 $71.93 $71.93 $71.93 $71.93 $71.93 $71.93 $71.93

Annual OnLine Leak Repair Cost ($/yr) $7.08 $34.92 $5.64 $27.84 $38.04 $108.34 $30.34 $86.39 $126.72 $181.95 $101.05 $145.08

Percent Requiring Further Repair 25 25 50 50 25 25 50 50 25 25 50 50

Repair Time (hours) 4 4 4 4 4 4 4 4 4 4 4 4

Annual Offline Leak Repair Cost ($/yr) $56.49 $278.80 $135.14 $666.93 $303.75 $865.02 $726.61 $2,069.25 $1,011.75 $1,452.70 $2,420.27 $3,475.08

Monitoring to Verify Repair ($) $1.26 $6.24 $1.51 $7.46 $6.80 $19.36 $8.13 $23.16 $22.65 $32.52 $27.09 $38.89

Annual Admin. Cost ($/yr) $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00

Annual Misc. Charges ($/yr) $0.00 $1.00 $2.00 $3.00 $0.00 $1.00 $2.00 $3.00 $0.00 $1.00 $2.00 $3.00

Total Capital Costs

Annualized Capital Costs

Annual Expenses

Grand Total (Annual Expenses + Annualized Capital 

Costs)

Incremental cost $1,041.46 $3,709.39 $8,126.67

$15,837.51

$2,248.93

$13,645.27

$15,894.19

$49,242.36

$6,992.42

$17,028.44

$24,020.86

$7,044.72

$1,000.35

$6,471.77

$7,472.12

$21,853.32

$3,103.17

$8,078.34

$11,181.51

$1,939.85

$275.46

$1,857.33

$2,132.79

$6,008.25

$853.17

$2,321.08

$3,174.25

P&R IV Equipment Leaks Valves Costs

P&R IV - simple model plant P&R IV - medium model plant P&R IV - complex model plant
A2-2

Baseline Baseline Option 1 Option 1 Baseline Baseline Option 1 Option 1

Type of Component valves - gas 

vapor 

valves - light 

liquid

valves - gas 

vapor 

valves - light 

liquid

valves - gas 

vapor 

valves - light 

liquid

valves - gas 

vapor 

valves - light 

liquid

Number of Components 65 340 64 340 240 1100 240 1100

Initial Monitoring Fee or Unit Cost ($/comp) $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00

Initial Monitoring Costs ($/yr) (Capital) $380.90 $1,331.94 $1,173.99 $4,112.03 $1,406.40 $4,309.20 $4,402.47 $13,303.62

Initial LDAR Admin. Costs

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

Subsequent Monitoring Fee ($/comp) $1.61 $1.61 $1.61 $1.61 $1.61 $1.61 $1.61 $1.61

Annual Monitoring Costs ($/yr) $209.30 $1,094.80 $206.08 $1,094.80 $772.80 $3,542.00 $772.80 $3,542.00

Annual Maintenance Costs ($/yr)

Initial Leak Frequency (%) 7.24 4.84 12.24 8.07 7.24 4.84 12.24 8.07

Initial Number of Leaks 4.706 16.456 7.8336 27.438 17.376 53.24 29.376 88.77

Subsequent Leak Frequency (%) 0.51 0.51 0.61 0.61 0.51 0.51 0.61 0.61

Annual Number of Leaks 0.663 3.468 0.7808 4.148 2.448 11.22 2.928 13.42

Percent Repaired OnLine 75 75 50 50 75 75 50 50

Repair Time (hours) 0.167 0.167 0.167 0.167 0.167 0.167 0.167 0.167

Repair Labor Charge ($/hr) $71.93 $71.93 $71.93 $71.93 $71.93 $71.93 $71.93 $71.93

Annual OnLine Leak Repair Cost ($/yr) $5.97 $31.24 $4.69 $24.91 $22.05 $101.08 $17.59 $80.60

Percent Requiring Further Repair 25 25 50 50 25 25 50 50

Repair Time (hours) 4 4 4 4 4 4 4 4

Annual Offline Leak Repair Cost ($/yr) $47.69 $249.45 $112.33 $596.73 $176.08 $807.05 $421.22 $1,930.60

Monitoring to Verify Repair ($) $1.07 $5.58 $1.26 $6.68 $3.94 $18.06 $4.71 $21.61

Annual Admin. Cost ($/yr) $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00

Annual Misc. Charges ($/yr) $0.00 $1.00 $2.00 $3.00 $0.00 $1.00 $2.00 $3.00

Total Capital Costs

Annualized Capital Costs

Annual Expenses

Grand Total (Annual Expenses + Annualized Capital 

Costs)

Incremental cost $913.76 $3,054.70

$1,889.33 $2,803.09 $6,255.70 $9,310.40

$1,646.11 $2,052.48 $5,444.08 $6,796.13

$243.22 $750.61 $811.62 $2,514.26

PAI Equipment Leaks Valves Costs

PAI - batch model plant PAI - continuous model plant

$1,712.84 $5,286.02 $5,715.60 $17,706.09
A2-3

Baseline Baseline Option 1 Option 1 Baseline Baseline Option 1 Option 1 Baseline Baseline Option 1 Option 1

Type of Component valves - gas valves - light valves - gas valves - light valves - gas valves - light valves - gas valves - light valves - gas valves - light valves - gas valves - light 

Number of Components 125 166 125 166 3 392 3 392 57 218 57 218

Initial Monitoring Fee or Unit Cost ($/comp) $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00

Initial Monitoring Costs ($/yr) (Capital) $732.50 $650.30 $2,292.95 $2,007.64 $17.58 $1,535.64 $55.03 $4,740.93 $334.02 $854.01 $1,045.59 $2,636.54

Initial LDAR Admin. Costs

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

Subsequent Monitoring Fee ($/comp) $1.61 $1.61 $1.61 $1.61 $1.61 $1.61 $1.61 $1.61 $1.61 $1.61 $1.61 $1.61

Annual Monitoring Costs ($/yr) $402.50 $534.52 $402.50 $534.52 $9.66 $1,262.24 $9.66 $1,262.24 $183.54 $701.96 $183.54 $701.96

Annual Maintenance Costs ($/yr)

Initial Leak Frequency (%) 7.24 4.84 12.24 8.07 7.24 4.84 12.24 8.07 7.24 4.84 12.24 8.07

Initial Number of Leaks 9.05 8.0344 15.3 13.3962 0.2172 18.9728 0.3672 31.6344 4.1268 10.5512 6.9768 17.5926

Subsequent Leak Frequency (%) 0.51 0.51 0.61 0.61 0.51 0.51 0.61 0.61 0.51 0.51 0.61 0.61

Annual Number of Leaks 1.275 1.6932 1.525 2.0252 0.0306 3.9984 0.0366 4.7824 0.5814 2.2236 0.6954 2.6596

Percent Repaired OnLine 75 75 50 50 75 75 50 50 75 75 50 50

Repair Time (hours) 0.167 0.167 0.167 0.167 0.167 0.167 0.167 0.167 0.167 0.167 0.167 0.167

Repair Labor Charge ($/hr) $71.93 $71.93 $71.93 $71.93 $71.93 $71.93 $71.93 $71.93 $71.93 $71.93 $71.93 $71.93

Annual OnLine Leak Repair Cost ($/yr) $11.49 $15.25 $9.16 $12.16 $0.28 $36.02 $0.22 $28.72 $5.24 $20.03 $4.18 $15.97

Percent Requiring Further Repair 25 25 50 50 25 25 50 50 25 25 50 50

Repair Time (hours) 4 4 4 4 4 4 4 4 4 4 4 4

Annual Offline Leak Repair Cost ($/yr) $91.71 $121.79 $219.39 $291.35 $2.20 $287.60 $5.27 $688.00 $41.82 $159.94 $100.04 $382.61

Monitoring to Verify Repair ($) $2.05 $2.73 $2.46 $3.26 $0.05 $6.44 $0.06 $7.70 $0.94 $3.58 $1.12 $4.28

Annual Admin. Cost ($/yr) $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00 $0.00

Annual Misc. Charges ($/yr) $0.00 $1.00 $2.00 $3.00 $0.00 $1.00 $2.00 $3.00 $0.00 $1.00 $2.00 $3.00

Total Capital Costs

Annualized Capital Costs

Annual Expenses

Grand Total (Annual Expenses + Annualized Capital 

Costs)

Incremental cost $711.07 $861.84 $634.81

$1,379.40 $2,090.47 $1,826.05 $2,687.89 $1,286.75 $1,921.56

$1,183.04 $1,479.79 $1,605.49 $2,006.86 $1,118.05 $1,398.70

$196.36 $610.68 $220.56 $681.03 $168.70 $522.86

PEPO Equipment Leaks Valves Costs

PEPO - small model plant PEPO - large model plant PEPO - solvent extraction model plant

$1,382.80 $4,300.59 $1,553.22 $4,795.96 $1,188.03 $3,682.12
A2-4

Baseline Option 1 Baseline Option 1 Baseline Option 1

Type of Component

Number of Components 15 15 40 40 56 56

Initial Monitoring Fee or Unit Cost ($/comp) $0.00 $0.00 $0.00 $0.00 $0.00 $0.00

Initial Monitoring Costs ($/yr) (Capital) $2,327.08 $3,181.61 $6,205.54 $8,484.29 $8,687.76 $11,878.00

Initial Pump Seal Replacement Costs ($/yr) (Capital) $611.65 $836.26 $1,631.08 $2,230.03 $2,283.51 $3,122.04

Initial LDAR Admin. Costs

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

Subsequent Monitoring Fee ($/comp) $1.61 $1.61 $1.61 $1.61 $1.61 $1.61

Annual Monitoring Costs ($/yr) $6,411.09 $6,411.09 $17,096.24 $17,096.24 $23,934.74 $23,934.74

Annual Maintenance Costs ($/yr) $141.57 $179.68 $377.52 $479.16 $528.53 $670.82

Initial Leak Frequency (%) 13.48 18.43 13.48 18.43 13.48 18.43

Initial Number of Leaks 2.022 2.7645 5.392 7.372 7.5488 10.3208

Subsequent Leak Frequency (%) 0.26 0.33 0.26 0.33 0.26 0.33

Annual Number of Leaks 0.468 0.594 1.248 1.584 1.7472 2.2176

Percent Repaired OnLine 100 100 100 100 100 100

Repair Time (hours) 16 16 16 16 16 16

Repair Labor Charge ($/hr) $71.93 $71.93 $71.93 $71.93 $71.93 $71.93

Annual OnLine Leak Repair Cost ($/yr) $538.61 $683.62 $1,436.30 $1,822.99 $2,010.82 $2,552.19

Percent Requiring Further Repair 0 0 0 0 0 0

Repair Time (hours) 80 80 80 80 80 80

Replacement Pump Seals ($) $302.50 $302.50 $302.50 $302.50 $302.50 $302.50

Annual Offline Leak Repair Cost ($/yr) $0.00 $0.00 $0.00 $0.00 $0.00 $0.00

Monitoring to Verify Repair ($) $0.75 $0.96 $2.01 $2.55 $2.81 $3.57

Annual Admin. Cost ($/yr) $0.00 $0.00 $0.00 $0.00 $0.00 $0.00

Annual Misc. Charges ($/yr) $113.26 $143.75 $302.02 $383.33 $422.82 $536.66

Total Capital Costs $2,938.73 $4,017.87 $7,836.62 $10,714.32 $10,971.27 $15,000.04

Annualized Capital Costs $479.69 $655.84 $1,279.17 $1,748.90 $1,790.84 $2,448.45

Annual Expenses $7,205.28 $7,419.10 $19,214.08 $19,784.27 $26,899.72 $27,697.98

Grand Total (Annual Expenses + Annualized Capital 

Costs) $7,684.97 $8,074.94 $20,493.25 $21,533.17 $28,690.55 $30,146.43

Incremental cost $389.97 $1,039.91 $1,455.88

P&R IV Equipment Leaks Pumps Costs

P&R IV - simple model plant P&R IV - medium model plant P&R IV - complex model plant

pumps - light liquid service pumps - light liquid service pumps - light liquid service
A2-5

Baseline Option 1 Baseline Option 1

Type of Component

Number of Components 14 14 33 33

Initial Monitoring Fee or Unit Cost ($/comp) $0.00 $0.00 $0.00 $0.00

Initial Monitoring Costs ($/yr) (Capital) $2,171.94 $2,969.50 $5,119.57 $6,999.54

Initial Pump Seal Replacement Costs ($/yr) (Capital) $570.88 $780.51 $1,345.64 $1,839.77

Initial LDAR Admin. Costs

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

Subsequent Monitoring Fee ($/comp) $1.61 $1.61 $1.61 $1.61

Annual Monitoring Costs ($/yr) $5,983.68 $5,983.68 $14,104.40 $14,104.40

Annual Maintenance Costs ($/yr) $132.13 $167.71 $311.45 $395.31

Initial Leak Frequency (%) 13.48 18.43 13.48 18.43

Initial Number of Leaks 1.8872 2.5802 4.4484 6.0819

Subsequent Leak Frequency (%) 0.26 0.33 0.26 0.33

Annual Number of Leaks 0.4368 0.5544 1.0296 1.3068

Percent Repaired OnLine 100 100 100 100

Repair Time (hours) 16 16 16 16

Repair Labor Charge ($/hr) $71.93 $71.93 $71.93 $71.93

Annual OnLine Leak Repair Cost ($/yr) $502.70 $638.05 $1,184.95 $1,503.97

Percent Requiring Further Repair 0 0 0 0

Repair Time (hours) 80 80 80 80

Replacement Pump Seals ($) $302.50 $302.50 $302.50 $302.50

Annual Offline Leak Repair Cost ($/yr) $0.00 $0.00 $0.00 $0.00

Monitoring to Verify Repair ($) $0.70 $0.89 $1.66 $2.10

Annual Admin. Cost ($/yr) $0.00 $0.00 $0.00 $0.00

Annual Misc. Charges ($/yr) $105.71 $134.16 $249.16 $316.25

Total Capital Costs $2,742.82 $3,750.01 $6,465.21 $8,839.31

Annualized Capital Costs $447.71 $612.11 $1,055.32 $1,442.84

Annual Expenses $6,724.93 $6,924.50 $15,851.62 $16,322.02

Grand Total (Annual Expenses + Annualized Capital $7,172.64 $7,536.61 $16,906.93 $17,764.86

Incremental cost $363.97 $857.93

PAI Equipment Leaks Pumps Costs

PAI - batch model plant PAI - continuous model plant

pumps - light liquid service pumps - light liquid service
A2-6

Baseline Option 1 Baseline Option 1 Baseline Option 1

Type of Component

Number of Components 2 2 13 13 5 5

Initial Monitoring Fee or Unit Cost ($/comp) $0.00 $0.00 $0.00 $0.00 $0.00 $0.00

Initial Monitoring Costs ($/yr) (Capital) $310.28 $424.21 $2,016.80 $2,757.39 $775.69 $1,060.54

Initial Pump Seal Replacement Costs ($/yr) (Capital) $81.55 $111.50 $530.10 $724.76 $203.88 $278.75

Initial LDAR Admin. Costs

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

Subsequent Monitoring Fee ($/comp) $1.61 $1.61 $1.61 $1.61 $1.61 $1.61

Annual Monitoring Costs ($/yr) $854.81 $854.81 $5,556.28 $5,556.28 $2,137.03 $2,137.03

Annual Maintenance Costs ($/yr) $18.88 $23.96 $122.69 $155.73 $47.19 $59.89

Initial Leak Frequency (%) 13.48 18.43 13.48 18.43 13.48 18.43

Initial Number of Leaks 0.2696 0.3686 1.7524 2.3959 0.674 0.9215

Subsequent Leak Frequency (%) 0.26 0.33 0.26 0.33 0.26 0.33

Annual Number of Leaks 0.0624 0.0792 0.4056 0.5148 0.156 0.198

Percent Repaired OnLine 100 100 100 100 100 100

Repair Time (hours) 16 16 16 16 16 16

Repair Labor Charge ($/hr) $71.93 $71.93 $71.93 $71.93 $71.93 $71.93

Annual OnLine Leak Repair Cost ($/yr) $71.81 $91.15 $466.80 $592.47 $179.54 $227.87

Percent Requiring Further Repair 0 0 0 0 0 0

Repair Time (hours) 80 80 80 80 80 80

Replacement Pump Seals ($) $302.50 $302.50 $302.50 $302.50 $302.50 $302.50

Annual Offline Leak Repair Cost ($/yr) $0.00 $0.00 $0.00 $0.00 $0.00 $0.00

Monitoring to Verify Repair ($) $0.10 $0.13 $0.65 $0.83 $0.25 $0.32

Annual Admin. Cost ($/yr) $0.00 $0.00 $0.00 $0.00 $0.00 $0.00

Annual Misc. Charges ($/yr) $15.10 $19.17 $98.16 $124.58 $37.75 $47.92

Total Capital Costs $391.83 $535.72 $2,546.90 $3,482.15 $979.58 $1,339.29

Annualized Capital Costs $63.96 $87.44 $415.73 $568.39 $159.90 $218.61

Annual Expenses $960.70 $989.21 $6,244.58 $6,429.89 $2,401.76 $2,473.03

Grand Total (Annual Expenses + Annualized Capital 

Costs) $1,024.66 $1,076.66 $6,660.31 $6,998.28 $2,561.66 $2,691.65

Incremental cost $52.00 $337.97 $129.99

PEPO Equipment Leaks Pumps Costs

PEPO - small model plant PEPO - large model plant PEPO - solvent extraction model plant

pumps - light liquid service pumps - light liquid service pumps - light liquid service