SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix B: RACT Cost Effectiveness Analysis December 15, 2011 

B - 1 Final Staff Report with Appendices for 

 Revised Proposed Amendments to Rule 4402 

APPENDIX B 

RACT Cost Effectiveness Analysis 

December 15, 2011 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix B: RACT Cost Effectiveness Analysis December 15, 2011 

B - 2 Final Staff Report with Appendices for 

 Revised Proposed Amendments to Rule 4402 

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SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix B: RACT Cost Effectiveness Analysis December 15, 2011 

B - 3 Final Staff Report with Appendices for 

 Revised Proposed Amendments to Rule 4402 

RACT COST EFFECTIVENESS ANALYSIS

I. SUMMARY 

A reasonably available control technology is a control technology that is considered 

reasonable for an operator to install or implement. By EPA definition, RACT must be 

technologically and economically feasible. Whether a control technology is considered 

RACT can vary between air basins and industries as well as over time. A RACT 

analysis integrates several factors, including technological advancements and costs for 

equipment, raw material, or labor. 

The following discussion summarizes the cost effectiveness analyses performed to 

address the concerns as identified by EPA. The cost effectiveness of a control option is 

the added cost of a control technology or technique per ton of VOC emissions reduced 

per year. Costs typically included in a cost effectiveness analysis include capital 

equipment costs, engineering costs, and labor and maintenance costs. 

II. ANALYSIS OF CLEAN PRODUCED WATER COMPLIANCE OPTIONS 

A. Injection of Clean Produced Water 

Although District staff have determined, and stakeholders agree, that it is not feasible to 

install new reinjection wells in order to dispose of wastewater through injection; 

stakeholders represented by the Western States Petroleum Association (WSPA) 

submitted data to the District for capital costs for disposing the wastewater using 

injection wells that show this to be not a cost effective option. WSPA estimates that the 

cost effectiveness of VOC reductions achieved by injection of produced water is 

$0.370/Bbl, or $1,792,452/ton. The WSPA calculations are explained below. 

It is important to note that the ratio of water to each barrel (Bbl) of crude oil produced in 

the Valley is 10:1. The following cost discussion is based on a per barrel amount. In 

order to inject the produced water, the water would have to be treated to prevent the 

plugging of the reservoir. Consequently, operators would incur treating and operating 

costs plus the capital expenditures for the injection well. 

Based on information provided to WSPA by a member company, the unit capital costs 

for treating produced water (annualized over 10 years) is approximately $1.113 per 

barrel (Bbl) and the operating cost is about $0.417/Bbl of produced water. WSPA 

determined the total annualized cost per barrel at $1.53. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix B: RACT Cost Effectiveness Analysis December 15, 2011 

B - 4 Final Staff Report with Appendices for 

 Revised Proposed Amendments to Rule 4402 

Table B-1. Estimated Capital Cost for Water Treating 

Initial Unit 

Capital Cost 

$/Bbl 

Annualized Cost ($) 

Annualized Unit 

Capital Cost1

Operating 

Expense2

Total Annualized 

Cost ($/Bbl) 

6.858 1.113 0.417 1.53 

District staff used the data provided by WSPA to then determine the annualized cost for 

treating a range of capacities of facilities, as illustrated in the table below. 

Table B-2. Annualized cost for treatment (WSPA) 

Capital Cost for Treating of CPW Capital Recover Cost 

Distributed Over 10 Years 

Facility Capacity Cost ($/bbl) Annualized Cost ($/year) 

ID BWPD BWPY 

1 500 182,500 1.53 279,225 

2 1,000 365,000 1.53 558,450 

3 3,000 1,095,000 1.53 1,675,350 

4 5,000 1,825,000 1.53 2,792,250 

5 10,000 3,650,000 1.53 5,584,500 

The following table illustrates the capital expenditures for construction of water injection 

wells for disposal of produced water. This information was provided to the District from 

the Western States Petroleum Association (WSPA). The table below is based off of 

reported numbers to WSPA but has been modified to display different ranges of oil 

production. The table discusses the facility capacity in barrels of water produced per 

day (BWPD) and barrels of water produced per year (BWPY). 

 

1

 The annualized cost (10% at 10 years) is calculated by multiplying the total (initial) annual cost by the 

District’s capital recovery factor (0.1623). 

2

 Members reported treating costs ranging from $0.417/Bbl to $0.59/Bbl. The cost estimates use the 

more conservative estimate. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix B: RACT Cost Effectiveness Analysis December 15, 2011 

B - 5 Final Staff Report with Appendices for 

 Revised Proposed Amendments to Rule 4402 

Table B-3. Capital Expenditure Required for Construction of Water Injection Wells 

Needed for Disposal of Produced Water (WSPA) 

Capital Cost for Injection Wells Capital Recover Cost 

Distributed Over 10 Years 

Facility Capacity Initial Capital Cost 

($) 

Annualized Cost (10 years 

at 10%) 

ID BWPD BWPY 

1 500 182,500 415,721 67,472 

2 1,000 365,000 831,443 134,943 

3 3,000 1,095,000 2,494,328 404,829 

4 5,000 1,825,000 4,157,214 674,716 

5 10,000 3,650,000 8,314,428 1,349,432 

WSPA calculated the emissions reduced using the Water9 software and determined the 

emissions reduced are 2.8 lb VOC/day or 1,022 lb VOC/year (0.51 tons/year). 

Table B-4. WSPA Input to the Water9 Model for Determining VOC Emissions from 

Produced Water Ponds 

Assumptions Units Value 

1 Determine the average daily average flow rate to ponds Gal/day 55,272 

2 Percolation rate for clay and sandy soil (0.8 gal/day *Ft2) Gpd/Ft2 0.8 

3 Determine minimum surface area for water percolation Ft2 69,090 

4 Assume ponds have an average depth of 6 ft Ft2 6 

5 Calculate the volume of the pond Gallons 3,100,966 

6 Calculate the fluid retention time (days) Days 56 

7 Use Water9 default water temperature (77F or 25C) C 25 

8 Use Water9 default assumptions for other parameters Given --- 

9 Model as a quiescent impoundment, well mixed flow Given --- 

10 Determine baseline emissions by modeling using 35 mg/l g/s at 35 mg/l 1.47E-02 

Staff converted g/s from line 10 in the the table above to tons per year using the 

following equation: 

0.0147g/s ÷ 453.6 g/lb x 86400 sec/day x 365 day/year ÷ 2,000 lb/ton = 0.51 tpy 

Staff then determined the cost effectiveness ($/ton reduced) by applying the annuzliaed 

costs mentioned above with the VOC reduced, as illustrated in the following table: 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix B: RACT Cost Effectiveness Analysis December 15, 2011 

B - 6 Final Staff Report with Appendices for 

 Revised Proposed Amendments to Rule 4402 

Table B-5. Cost Effectiveness of VOC Reductions Achieved by Injection of Produced 

Water 

VOC 

Reductions 

(Ton/Year) 

Annualized Costs Cost Effectiveness 

for VOC Reductions 

($/ton) 

 

Treating and 

operating Injection Total 

0.51 279,225 67,472 346,697 679,978 

B. Treatment of Water to Achieve 5 mg/l 

District Analysis 

For purposes of this cost effectiveness analysis for clean produced water, District staff 

used a software program (created by EPA) called Water9. During the public workshop 

stakeholders were asked if they agreed with the District’s choice to use this software or 

if they had recommendations for another software program would provide more 

accurate results. Stakeholders confirmed that Water9 is the software they currently use 

when making similar types of calculations and that it is the most accurate software to 

use to determine VOC emissions from wastewater processing operations, such as 

sumps. 

District staff calculated the difference in emissions from 35 to 5 mg of VOC per liter of 

water in three different scenarios. The variable for each scenario is the retention time, 

meaning the amount of time the water stays in the pond. District staff determined that 

the worst case scenario, one month retention time, resulted in 232 pounds of emissions 

reduced per year per pond. 

District staff used the following assumptions for these calculations: 

• Lagoon – 25 m W x 25 m L x 3 m deep 

• Approximately 6700 ft2

 surface area (this is conservative estimate as average 

known surface area of clean produced water ponds is 5,913 ft2) 

• Approximately 12,000 bbl capacity 

• Surrogate: decane (C10H22, default value for oil) 

• VOC emissions at 35 mg/l of VOC content = 1.69E

-5 g/s 

• VOC emissions at 5 mg/l of VOC content = 2.42 E

-6 g/s 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix B: RACT Cost Effectiveness Analysis December 15, 2011 

B - 7 Final Staff Report with Appendices for 

 Revised Proposed Amendments to Rule 4402 

Table B-6. VOC Emissions from Wastewater Ponds and VOC Emissions Potentially 

Reduced 

Retention Time Oil Concentration VOC Emissions VOC Emissions 

Reduced 

(months) (mg/l) (lb/yr) (lb/yr) 

1 35 242 232 1 5 10 

3 35 81 78 3 5 3 

6 35 40 38 6 5 2 

Preliminary calculations have determined that there are 74 active ponds in the Valley. 

Using the table above to create a worst-case-scenario calculation staff have determined 

the total emissions reduced would be 0.02 tons per day of VOC. 

Stakeholders provided information that a Wemco (oil water separator unit using forced 

air or gas) is the commonly used technology in the Valley to decrease the oil content of 

the CPW. However, a Wemco will generally only get the VOC content down to about 20 

mg/l. To get the VOC levels below 20 mg/l operators will need to install additional 

polishing equipment; one example would be the use of nut shell filters, used to remove 

residual insoluble hydrocarbons from the produced water. The additional systems 

would also require additional support equipment included a feed tank, pumps, and 

backwashing equipment to clean the filters; also, facilities would have additional 

maintenance and labor costs to clean the filter media of the accumulated oil on a routine 

bases. Stakeholders estimate that capital cost of the new equipment would be 

$28,000,000 with additional annual costs of $2,000,000 due to the additional filtration 

systems. The cost effectiveness analysis indicates that this is not a cost effective 

option. District staff used the following analysis to make this determination: 

1. The capital cost of the new equipment is converted to annualized costs using the 

following calculation: 

A = P x CRF where, A = Annualized total capital investment cost 

P = present value of capital 

CRF = capital recovery factor = i(i+1)n / (i+1)n

-1 

i = interest rate = 10% 

n = useful lifetime of equipment in years = 10 

 CRF = 0.1(0.1 +1)10 / (1+0.1)10 - 1 = 0.1627 

A = ($28M) x 0.1627 

 = 4,555,600 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix B: RACT Cost Effectiveness Analysis December 15, 2011 

B - 8 Final Staff Report with Appendices for 

 Revised Proposed Amendments to Rule 4402 

2. The Adjusted annualized cost accounts for the costs discussed above: 

$4,555,600 + 2,000,000 = $6,555,600/yr ≈ $6.5M 

3. Staff estimated the tons per year using the worst case scenario of 232 pounds 

per year as discussed above. 

232 lb/year / 2,000 lb/ton = 0.12 tons/year 

4. Staff determined cost effectiveness ($/ton reduced) using the annualized cost 

discussed above: 

$6.5M/year ÷ 0.12 tons/year = $54,166,666 $/ton 

WSPA Analysis 

WSPA performed an emission reduction analysis independent of the District using the 

Water9 software. To evaluate the VOC emission reductions expected to be achieved 

by the changes in effluent concentration, two modeling runs were made, one at each 

concentration. The difference between the two modeling runs was used to calculate the 

VOC reductions achieved by the proposed change. 

The general procedure used for conducting the modeling; the input to the Water9 model 

and the results of the modeling runs are summarized below. Since roughly 99% of 

sumps are used by small operators, the process information used in the Water9 

modeling was derived from operating data for small operators. WSPA reviewed the 

2010 well production data reported by oilfield operators to the California Division of Oil, 

Gas and Geothermal Resources (DOGGR), showed that only 40 small operators had 

surplus water, with a daily average volume of 1316 BPD, likely to be routed to sumps. 

For this analysis, it is assumed that this produced water would be routed to surface 

percolation ponds for final disposal. 

Table B-7. Small Operator Produced Water Likely to be Routed to a Sump 

Type of Small 

Producer 

Type of 

Production 

Total for All 

Producers Bbl/Day 

Average Per 

Producer Bbl/Day 

 Small Producer 

 Light Oil 4,178 696 

 Heavy Oil 2,489 415 

Total 6,667 1,111 

 Very Small Producer 

 Light Oil 523 12 

 Heavy Oil 8,295 193 

Total 8,818 205 

WSPA calculated the total surface area of ponds used for disposal of the produced 

water by assuming a percolation rate of 0.8 gallons/ft2

. The percolation rate was 

obtained from the Kern County “Standards and Rules and Regulations for Land 

Development” for soil type (5): Soils containing clay with a small amount of sand or 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix B: RACT Cost Effectiveness Analysis December 15, 2011 

B - 9 Final Staff Report with Appendices for 

 Revised Proposed Amendments to Rule 4402 

gravel. 

The holding capacity of the pond was subsequently calculated from the surface area 

using an average depth of six feet. The residence time used in the Water9 modeling 

was then determined by dividing the sump capacity by the daily throughput rate. The 

input parameters used in the Water9 modeling and the VOC emissions predicted for 

disposal of produced water are summarized in the table below. 

Table B-8. WSPA Input to the Water9 Model for Determining VOC Emissions from 

Produced Water Ponds 

Assumptions Units Value 

1 Determine the average daily average flow rate to ponds Gal/day 55,272 

2 Percolation rate for clay and sandy soil (0.8 gal/day *Ft2) Gpd/Ft2 0.8 

3 Determine minimum surface area for water percolation Ft2 69,090 

4 Assume ponds have an average depth of 6 ft Ft2 6 

5 Calculate the volume of the pond Gallons 3,100,966 

6 Calculate the fluid retention time (days) Days 56 

7 Use Water9 default water temperature (77F or 25C) C 25 

8 Use Water9 default assumptions for other parameters Given --- 

9 Model as a quiescent impoundment, well mixed flow Given --- 

10 Determine baseline emissions by modeling using 35 mg/l g/s at 35 mg/l 1.47E-02 

11 Determine controlled emissions by modeling using 5 mg/l g/s at 5 mg/l 6.08E-04 

12 Determine change in VOC emissions to (g/s) ∆ g/s 1.41E-02 

13 Determine total daily emission reductions (Lb/Day) Lb VOC/Day 2.69 

District staff used the table above to calculate the cost effectiveness of treating clean 

produced water to reduce the VOC content from 35 mg/l to 5 mg/l. 

1. Staff estimated the tons per year using the provided 2.69 pound per day 

information from the table above. 

2.69 lb/day x 365 days/year = 982 lbs/day ≈1,000 lbs (or 0.5 tons/year) 

2. Staff determined cost effectiveness ($/ton reduced) using the average reported 

costs discussed above: 

$4 million /year ÷ 0.5 tons/year = $8 million/ ton 

As illustrated by both the cost effectiveness analysis presented by District staff and the 

one performed by WSPA, the treatment of clean produced water from 35 mg/l to 5 mg.l 

is not a cost effective option, and therefore goes beyond RACT. As such, District staff 

proposes to not amend this section of the rule. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix B: RACT Cost Effectiveness Analysis December 15, 2011 

B - 10 Final Staff Report with Appendices for 

 Revised Proposed Amendments to Rule 4402 

Worst Case Scenario 

Based on conversations with EPA staff, District staff performed a third cost 

effectiveness analysis to evaluate a worst case scenario cost effectiveness analysis. 

Emissions from a clean produced water pond will never emit as many emissions as a 

third stage heavy oil sump, but for purposes of performing this worst case scenario 

calculation, staff assumed the emissions from a clean produced water pond are 

equivalent to that of a third stage heavy crude oil production sump. 

The calculations are presented below: 

Staff made the following assumptions: 

• The emission factor for a clean produced water pond is equivalent to third stage 

heavy oil sumps. 

• All VOCs would evaporate from the pond and none would remain in the pond, 

percolate, or undergo biodegradation. 

• A pond is 69,000 ft2

• Annualized costs would be equivalent to the lower costs of the two 

methodologies presented above (District costs versus WSPA costs) at $4 

million/year 

1. Staff calculated the tons of VOC from a pond using the assumptions above. 

0.0051 lb/ft2 x 69,000 ft2 sump ÷ 2,000 lb/ton = 0.18 tons VOC (day) 

2. Staff calculated the tons per year of VOC. 

0.18 tons VOC/day x 365 days/year = 66 tons per year 

3. Assuming all VOC’s evaporate from the pond into the air. 5 mg from 35 mg would 

produce the following reductions: 

(5 mg/l ÷ 35 mg/l) – 100% = 86% reduction 

4. Staff determined the amount of VOCs reduced by 

66 tpy x 0.86 = 56.8 tons VOC reduced 

5. Staff applied determined the cost effectiveness ($/ton reduced) using the 

assumptions above. 

$4 million/year ÷ 56.8 tpy = $70,423 

Even conducting a worst case analysis assuming a clean produced water pond was 

emitting as much as a third stage sump, it is not cost effective to lower the clean 

produced water threshold from 35 mg/l to 5 mg/l and therefore beyond RACT. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix B: RACT Cost Effectiveness Analysis December 15, 2011 

B - 11 Final Staff Report with Appendices for 

 Revised Proposed Amendments to Rule 4402 

III. COMPLIANCE WITH SECTION 5.0 REQUIREMENTS 

District Rule 4402 Section 5.0 (Requirements) provides operators with two options to 

comply with rule requirements; the operator can either install one of three control 

devices, or replace the sump with a tank. The three control devices must also comply 

with other requirements specified in the rule. The three control devices available to 

operators as a means of compliance are as follows: 

1. A flexible floating cover 

2. A rigid floating cover equipped with a closure device between the sump wall and 

the cover edge which maintains the gap between the wall and cover at every 

point around the perimeter at no more than one inch

3. A fixed-roof cover 

Staff performed a cost effectiveness analysis for operators to install and maintain and to 

remain compliant with rule requirements for each of these three sump control devices. 

It is important to note that in determining the cost effectiveness for operators to comply 

with Section 5.0 of Rule 4402, costs used for these analyses are for a 1,000 ft2

 surface 

area sump (the exemption limit for small producers) and are annualized 1986 dollars 

from the ARB TSD document on sump control measures. Staff contacted stakeholders 

and requested additional cost information for sump covers but no facility in the Valley 

has ever installed a cover on a sump. As previously discussed, historically when an 

operator must install a cover on a sump they respond by replacing the sump with a tank. 

Therefore, stakeholders do not have any cost information to provide the District for 

costs of sump covers. Stakeholders informed District staff that they had asked vendors 

and were unsuccessful in getting cost data for sump covers from them. District staff did 

additional research to obtain this cost information, including requesting it from EPA, and 

because no facilities use sump covers, District staff were equally unsuccessful in 

obtaining said data; as such, District staff have determined that the cost information 

provided in the ARB TSD is the only cost data available, and therefore it is the 

appropriate cost information for these analyses. Staff additionally determined that 

flexible floating covers are not reasonably available control options because no 

operator, manufacturer, or distributer uses, creates, or distributes these covers. 

Flexible floating covers are not available to operators for use. 

As previously discussed, the cost effectiveness of a control measure is the dollars per 

ton of emissions reduced. To create a worst-case scenario, resulting in conservative 

calculations, District staff determined the emissions from second and third stage sumps 

with a surface area of 1000 sq. ft. containing heavy crude oil. Calculations do not 

include light crude oil because the applicability of the Section 4.1.1 exemption is limited 

to small producers of heavy oil, these calculations are illustrated below. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix B: RACT Cost Effectiveness Analysis December 15, 2011 

B - 12 Final Staff Report with Appendices for 

 Revised Proposed Amendments to Rule 4402 

VOC Emission Calculations from Heavy Oil Sumps were calculated using the following 

equations: 

2

nd stage: 1,000 ft2

 x 0.0412 lb/ft2-day = 41.2 lb VOC/day = 7.52 tons VOC/year 

3

rd stage: 1,000 ft2

 x 0.0051 lb/ft2-day = 5.1 lb VOC/day = 0.93 tons VOC/year 

A. Compliance with Section 5.1.1 (flexible floating cover) 

A flexible floating cover is a cover that floats directly on the liquid surface. The purpose 

of a flexible floating cover is to eliminate evaporation by reducing the exposed liquid 

surface area. Flexible floating covers are generally made of polymer materials that can 

resist weathering, high temperatures, and ultraviolet radiation. The ARB TSD cites 

flexible floating covers as having 98% control efficiency. For purposes of this analysis, 

staff will assume the 98% control efficiency is accurate. 

Prior to installation of a flexible floating cover the site must be prepared for that 

installation. 

• Provide a symmetrical impoundment perimeter with uniform sides slope 

• Create a trench around the impoundment perimeter to anchor the flexible floating 

cover 

• Modify pipes and other structures protruding above the liquid surface so that they 

are located below the liquid surface, and install on them shields made of steel or 

polymer to protect the flexible floating cover from damage by the protrusions 

when the sump liquid level is lowered. 

Flexible floating covers are installed and anchored and they are equipped with floats 

which prevent it from sinking if it is ruptured, and weights to increase stability. A hatch 

and an access platform located above the oil skimming mechanism can be installed if 

necessary to permit inspection, maintenance, and adjustment of the skimming 

mechanism. 

For smaller sumps (<1000 sq. ft. surface area), a simplified installation is available 

because there is no need to dig a trench to anchor the membrane; instead the 

membrane can be wrapped around two sand filled tubes and one tube can be anchored 

directly to the ground for stabilization purposes. 

The ARB TSD estimated the total capital costs for flexible floating covers, rigid floating 

covers, and fixed dome roofs. All the cost estimates for covers include the following: 

• The sump cover and its installation, 

• Site preparation necessary for the installation of the cover, 

• Excavation, concrete, and pouring as necessary, 

• Miscellaneous costs including pipe modification, hatch assembly, walkway, and 

seals, and 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix B: RACT Cost Effectiveness Analysis December 15, 2011 

B - 13 Final Staff Report with Appendices for 

 Revised Proposed Amendments to Rule 4402 

• Administrative costs and taxes, which account for approximately ten percent of 

the total cost. 

The ARB TSD lists $7,370/year, 98% control efficiency, and a 5 year life span. 

Adjusting from the annualized cost at 1986 dollars to 2011 dollars (multiplying by 2.75% 

inflation/yr): 

ARB makes the statement in the TSD that flexible floating covers pose a safety hazard 

for sumps where methane is produced or where dissolved gases can enter the sump 

with the feed stream. The flexible floating cover would not allow the escape of these 

gases and could create a situation that would result in explosions. The ARB TSD 

further explains that the combustible gases would that might otherwise accumulate 

beneath the cover would need to be removed and disposed of. The method of disposal 

of collected gas would be to send it to a flare. The cost effectiveness analysis must 

account for these additional costs. 

Additional costs for a vapor compressor skid to mitigate vapors collected under the 

flexible cover and a flare to dispose of the vapors are as follows: 

500 Mscfd Vapor Recovery Unit including suction scrubber, 2 compressors, discharge 

cooler, and discharge scrubber has a total capital cost of $277,000. 

The capital cost of the vapor skid is converted to annualized costs using the following 

calculation: 

A = P x CRF where, A = Annualized total capital investment cost 

P = present value of capital 

CRF = capital recovery factor = i(i+1)n / (i+1)n-1 

i = interest rate = 10% 

n = useful lifetime of equipment in years = 10 

 CRF = 0.1(0.1 +1)10 / (1+0.1)10 - 1 = 0.1627 

A = ($277,000) x 0.1627 

 = 45,068 

The annual cost to install and operate a flare for the incineration of captured gas is 

$79,195 in 2008 dollars. Adjusting from the annualized cost at 2008 dollars to 2011 

dollars (multiplying by 2.75% inflation/yr): 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix B: RACT Cost Effectiveness Analysis December 15, 2011 

B - 14 Final Staff Report with Appendices for 

 Revised Proposed Amendments to Rule 4402 

The Adjusted annualized cost accounts for the costs discussed above: 

$12,437+ 45,068 + $85,729 = $143,234/yr 

The ARB TSD costs were combined with the above mentioned costs to perform the cost 

effectiveness analysis as presented in the table below. 

Table B-9. Cost Effectiveness for 1000 sq. ft. Heavy Oil Sump Equipped with a 

Flexible Floating Sump Cover 

Sump VOC 

Emissions 

(tpy) 

Control 

Efficiency 

VOC 

Controlled 

(tpy) 

Adjusted 

Annualized 

Cost 

Cost per ton 

of VOC 

controlled 

2

nd Stage: 7.52 98% 7.37 $143,234 $19,435

3

rd Stage: 0.93 98% 0.91 $143,234 $157,400

B. Compliance with Section 5.1.2 (rigid floating cover with a one-inch gap) 

Rigid floating covers are made with metal, or polymeric compounds reinforced with 

carbon, fiberglass, or other materials. The installation of a rigid floating cover requires 

the following site preparation before it can be installed: 

• Excavation of the sump to create a level bottom and vertical sides 

• Lining of the walls of the sump with reinforced concrete 1⁄2 foot thick 

• Construction of inlet and outlet pipes through the concrete walls, and 

• Installation of five concrete blocks each about three feet high at the bottom of the 

sump to provide support to the rigid floating cover at low fluid levels. 

Rigid floating covers work to reduce evaporation by resting on the liquid surface much 

like flexible floating covers do. This poses the same issues with collection of 

combustible gases under the cover and requires the collection and disposal of such 

gases for safety reasons. Unlike flexible floating covers, rigid floating covers would not 

completely cover the sump liquid surface. Exposed areas would exist along the entire 

perimeter of the cover between the cover and the sump wall. The ARB TSD cites 

control efficiency for rigid floating covers at 90%. For purposes of this analysis, District 

staff will assume the 90% control efficiency is accurate. 

Sumps in the Valley are generally unlined dirt excavations. In order to comply with the 

requirement of having cement reinforced concrete walls for the sumps, operators would 

have the additional costs of emptying existing sumps and either storing or disposing of 

the collected liquid prior to installing the new sumps. As discussed in Section III of this 

final staff report, sumps are not only used for separation of water and oil but also for 

disposal of liquids through percolation. If the sumps were lined with cement, then the 

operator would have the additional costs of disposing of the water after the oil has been 

separated from it, as discussed earlier in this final staff report. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix B: RACT Cost Effectiveness Analysis December 15, 2011 

B - 15 Final Staff Report with Appendices for 

 Revised Proposed Amendments to Rule 4402 

The ARB TSD lists $17,200/year, 90% control efficiency, and a 5 year life span. 

Adjusting from the annualized cost at 1986 dollars to 2011 dollars (multiplying by 2.75% 

inflation/yr): 

Again, this cost data would be combined with the additional capital costs for installing a 

vapor recovery and destruction device to each sump for safety purposes. Using the 

same capital cost data discussed previously in combination with the added cost of 

emptying the sump and storing or disposing of the liquid within it during the construction 

of the new sump would result in the cost effectiveness analysis as presented in the 

table below. 

Additional costs for a vapor compressor skit to mitigate vapors collected under the 

flexible cover and a flare to dispose of the vapors are as follows: 

500 million standard cubic feet per day (Mscfd) Vapor Recovery Unit including suction 

scrubber, 2 compressors, discharge cooler, and discharge scrubber has a total capital 

cost of $277,000. 

The capital cost of the vapor skid is converted to annualized costs using the following 

calculation: 

A = P x CRF where, A = Annualized total capital investment cost 

P = present value of capital 

CRF = capital recovery factor = i(i+1)n / (i+1)n

-1 

i = interest rate = 10% 

n = useful lifetime of equipment in years = 10 

 CRF = 0.1(0.1 +1)10 / (1+0.1)10 - 1 = 0.1627 

A = ($277,000) x 0.1627 

 = 45,068 

The annual cost to install and operate a flare for the incineration of captured gas is 

$79,195 in 2008 dollars. Adjusting from the annualized cost at 2008 dollars to 2011 

dollars (multiplying by 2.75% inflation/yr): 

The Adjusted annualized cost accounts for the costs discussed above: 

$29,025 + 45,068 + $85,729 = $159,822/yr 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix B: RACT Cost Effectiveness Analysis December 15, 2011 

B - 16 Final Staff Report with Appendices for 

 Revised Proposed Amendments to Rule 4402 

Table B-10. Cost Effectiveness for Heavy Oil Sump Equipped with a Rigid Floating 

Sump Cover 

Sump VOC 

Emissions 

(tpy) 

Control 

Efficiency 

VOC 

Controlled 

(tpy) 

Adjusted 

Annualized 

Cost 

Cost per ton of 

VOC controlled 

2

nd Stage: 7.52 90% 6.77 $159,822 $23,067

3

rd Stage: 0.93 90% 0.84 $159,822 $190,264

C. Compliance with Section 5.1.3 (fixed roof cover) 

Fixed roof covers are constructed of polymers, aluminum, or steel. They are either flat 

or dome shaped and completely enclose the contained liquid, but are not in contact with 

the liquid surface. Fixed covers come in two basic shapes, flat and dome shaped. The 

Both types of fixed roof covers require a cement footing to be constructed along the top 

of the sump perimeter in order to permit permanent attachment and sealing of the roof 

to the sump perimeter. Additionally, pressure vacuum (PV) valves would be required on 

the cover to eliminate possible extremes in pressure. Flat fixed covers are not feasible 

for sumps exceeding 20 feet due to required structural support; therefore when 

discussing fixed roof covers throughout this final staff report, District staff are referring 

specifically to dome covers. 

A typical dome cover is made of triangular aluminum sheets that are bolted to a 

triangular framework of aluminum I-beams, which are attached to a concrete foundation 

along the impoundment perimeter by expansion anchors. Neoprene seals are placed 

between the I-beams and the aluminum sheets with silicon caulking applied at each 

node and gusset. ARB determined that the only sources of emissions from a fixed roof 

cover would be fugitive emissions from the PV valve and from other points of potential 

leakage. The control efficiency for fixed roof covers for sumps is 90%. 

Staff contacted numerous manufacturers and vendors and were unable any that 

manufacture or distribute fixed roof covers for sumps. Stakeholders groups also stated 

they asked for this cost information from group members and from vendors and 

because these are not used in the Valley for sumps there is no cost information 

available. 

The ARB TSD lists $5,720/year, 90% control efficiency, and a 20 year life span. 

Adjusting from the annualized cost at 1986 dollars to 2011 dollars (multiplying by 2.75% 

inflation/yr): 

Again, this cost data would be combined with the additional capital costs for installing a 

vapor recovery and destruction device to each sump for safety purposes. Using the 

same capital cost data discussed previously in combination with the added cost of 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix B: RACT Cost Effectiveness Analysis December 15, 2011 

B - 17 Final Staff Report with Appendices for 

 Revised Proposed Amendments to Rule 4402 

emptying the sump and storing or disposing of the liquid within it during the construction 

of the new sump would result in the cost effectiveness analysis as presented in the 

table below. 

Additional costs for a vapor compressor skit to mitigate vapors collected under the 

flexible cover and a flare to dispose of the vapors are as follows: 

500 Mscfd Vapor Recovery Unit including suction scrubber, 2 compressors, discharge 

cooler, and discharge scrubber has a total capital cost of $277,000. 

To convert the vapor skid capital cost and add in additional flare costs staff used the 

following calculation: 

A = P x CRF where, A = Annualized total capital investment cost 

P = present value of capital 

CRF = capital recovery factor = i(i+1)n / (i+1)n

-1 

i = interest rate = 10% 

n = useful lifetime of equipment in years = 10 

 CRF = 0.1(0.1 +1)10 / (1+0.1)10 - 1 = 0.1627 

A = ($277,000) x 0.1627 

 = 45,068 

The annual cost to install and operate a flare for the incineration of captured gas is 

$79,195 in 2008 dollars. Adjusting from the annualized cost at 2008 dollars to 2011 

dollars (multiplying by 2.75% inflation/yr): 

The Adjusted annualized cost accounts for the costs discussed above: 

$9,653 + 45,068 + $85,729 = $140,450/yr 

Table B-11. Cost Effectiveness for Heavy Oil Sump Equipped with a Fixed Roof Sump 

Cover 

Sump 

VOC 

Emissions 

(tpy) 

Control 

Efficiency

VOC 

Controlled

(tpy) 

Adjusted 

Annualized 

Cost 

Cost per ton of 

VOC controlled 

2

nd Stage: 7.52 90% 6.77 $140,450 $20,745

3

rd Stage: 0.93 90% 0.84 $140,450 $167,202
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix B: RACT Cost Effectiveness Analysis December 15, 2011 

B - 18 Final Staff Report with Appendices for 

 Revised Proposed Amendments to Rule 4402 

D. Cost effectiveness of installing a tank to replace a sump 

District staff performed a cost effectiveness analysis of replacing a sump with a tank to 

determine whether or not is it a cost effective option. As previously discussed, historical 

evidence shows that every time an operator has been required to cover a sump they 

respond by replacing the sump with a tank. Conversations with stakeholders and 

venders have confirmed this assessment and industry representatives have stated that 

operators will continue to respond in this manner in the future. ARB further supports 

this assessment in the TSD by stating “We believe that a fixed-roof tank operated at a 

constant liquid level is the logical choice for sump replacement.”(TSD, 1988, p51) 

If an operator installs a tank to replace a sump, that operation will no longer be subject 

to the requirements of District Rule 4402; instead, the operation will be subject to 

District Rule 4623 (Storage of Organic Liquids). The exemptions in Section 4.1.1 and 

4.1.3 for small and very small producers are limited to the production of heavy crude oil. 

Heavy crude oil in the Valley has an average true vapor pressure (TVP) of less than 0.1 

psia, but theTVP can range from as low as 0.03 psia to as high as 0.3 psia. As such, 

tanks used to replace second and third stage sumps would be exempt from District Rule 

4623 pursuant to Section 4.4 of that rule. Meaning that no PV valve or APC device 

would be required for the tank and operators would have the option of having an open 

roof tank. District staff assumes operators will choose to have open roof tanks rather 

than install PV valves or APC devices because it is the least expensive option available 

for tanks. However, for completeness, District staff performed the following three cost 

effectiveness analyses: 1) for replacing a sump with an open roof tank, 2) for replacing 

a sump with a closed roof tank with a PV vent, and 3) for replacing a sump with a closed 

roof tank with vapor controls. 

1. District Analysis of Replacement Tanks 

District staff determined the following costs using a combination of data from the District 

permit database and information provided by stakeholders, manufacturers, and 

distributers. The costs associated with installing a tank to replace a sump include the 

following: 

 

i) Cost to install the tank (tank, delivery, cement pad to set it on) (capital cost) 

ii) Cost of any additional piping to and/or from tank (capital cost) 

iii) Clean up and backfilling of existing sumps (annual) 

iv) Ongoing maintenance of the tank (annual) 

v) Tank site preparation (one time cost) 

vi) Cleaning of tank bottoms (annual) 

vii) Disposal of wastewater (annual) 

viii)Disposal of waste (annual) 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix B: RACT Cost Effectiveness Analysis December 15, 2011 

B - 19 Final Staff Report with Appendices for 

 Revised Proposed Amendments to Rule 4402 

The costs specific to installing a fixed roof and vapor controls include the costs 

mentioned above in addition to following: 

i) Fixed roof cover 

ii) Vapor collection device (including maintenance and labor) 

iii) Vapor control device(including maintenance and labor) 

District staff performed a Tank cost effectiveness at the 1,000 ft2 sump size is calculated 

as follows: 

Cost Analysis for Tanks Equipped with a PV Vent Replacing a Sump: 

Assumptions: 

• Assume 2 replacement tanks per sump (as sumps are used for the continuous 

separation of oil, water, and sediment; to avoid any interruption in oil production one 

tank would remain in service while the second tank is taken offline for maintenance 

and cleaning) 

• Using average sump size of known surface area = 1,000 ft2

• Assume the reduction in VOC emissions by a sump with a tank ranges from 80% to 

90%. (The 1988 TSD the California Air Resources Board assumed that tanks would 

achieve a 90% reduction in VOC; however, industry believes the control efficiency 

ranges from 75% to 85%.) 

• Assume 2 sump replacement tank cleanings per year 

• Labor required for daily gauging and inspection of the tanks (1 hr/day) 

• Labor required to clean tanks annually (72 man hours per year x 2 tanks) 

• Labor rate of $65/hr 

Capital cost for an API 650 5,000 bbl welded tank = $344,000 

Operating and labor cost for cleaning the tanks are calculated as: 

(1 hr/day x 365 days/year) + (72 hrs/tank x 2 tanks/year) = 509 hrs/year 

509 hrs/year x $65/hr = $33,085/year 

From EPA’s Alternative Control Techniques Document: Volatile Organic Liquid Storage 

in Floating and Fixed Roof Tanks, January 1994: for a 4,762 bbl tank (smaller than that 

proposed) degassing and cleaning generates 3,000 gallons of hazardous waste (1,000 

gallons of rinseate and 2,000 gallons of sludge), and hazardous waste costs $5/gallon 

to dispose of. For this size tank it would cost (3,000 x $5) = $15,000/year in 1994 

dollars per cleaning, with two tank cleanings per year. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix B: RACT Cost Effectiveness Analysis December 15, 2011 

B - 20 Final Staff Report with Appendices for 

 Revised Proposed Amendments to Rule 4402 

Adjusting from the annualized cost at 1994 dollars to 2011 dollars (multiplying by 2.75% 

inflation/yr): 

The following formula was used to determine annualized costs: 

A = P x CRF where, A = Annualized total capital investment cost 

 P = present value of capital 

 CRF = capital recovery factor = i(i+1)n / (i+1)n

-1 

 i = interest rate = 10% 

 n = useful lifetime of equipment in years = 10 

CRF = 0.1(0.1 +1)10 / (1+0.1)10 - 1 = 0.1627; so, 

A = ($344,000 + $344,000) x 0.1627 + $33,085 + $44,025 = $189,048/yr 

VOC Emissions from Heavy Oil Sumps were determined as follows: 

2

nd stage: 1,000 ft2

 x 0.0412 lb/ft2-day = 41.2 lb VOC/day = 7.52 tons VOC/year 

3

rd stage: 1,000 ft2

 x 0.0051 lb/ ft2-day = 5.1 lb VOC/day = 0.93 tons VOC/year 

Table B-12. Cost Effectiveness for Heavy Oil Sump Replacement with Tank Equipped 

with PV Vent (District) 

 

tons-VOC/yr 

from sump 

Control 

Efficiency

tons-VOC 

Controlled

Adjusted 

Annualized Cost

Cost per ton of 

VOC controlled 

2

nd Stage: 7.52 80% 6.02 $189,048 $31,403 

7.52 90% 6.77 $189,048 $27,924 

3

rd Stage: 

0.93 80% 0.74 $189,048 $255,470 

0.93 90% 0.84 $189,048 $255,057 

Based on the analysis above, the cost effectiveness of replacing a 2nd stage sump with 

a tank ranges from $28,000/year to $31,000/year, while the cost for a 3rd stage sump 

replacement is over $255,000/year. Therefore, the costs are beyond reasonable and 

not RACT. 

Cost Analysis for Tanks Equipped with Vapor Control Replacing a Sump: 

Assumptions: (Same as above and including the following) 

• Assume tanks equipped with vapor control exhibit 95% control (5% accounts for 

miscellaneous fugitive losses and destruction efficiency of any device) 

• Labor required for inspection and maintenance of the vapor control skid (1 hr/day) 

• Labor rate of $65/hr 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix B: RACT Cost Effectiveness Analysis December 15, 2011 

B - 21 Final Staff Report with Appendices for 

 Revised Proposed Amendments to Rule 4402 

Total capital cost of a 500 Mscfd Vapor Recovery Unit including suction scrubber, 2 

compressors, discharge cooler, and discharge scrubber = $277,000. 

Annual labor and maintenance cost for the vapor recovery skid: 

(1 hr/day * 365 days/year) * ($65/hr) = $23,725/year 

The annual cost to install and operate a flare for the incineration of captured gas is 

$79,195 in 2008 dollars. 

Adjusting from the annualized cost at 2008 dollars to 2011 dollars (multiplying by 2.75% 

inflation/yr): 

A = ($344,000 + $344,000 + $277,000) x 0.1627 + $33,085 + $44,025 + $23,725 + 

$85,729 = $343,570/yr 

Table B-13. Cost Effectiveness for Heavy Oil Sump Replacement Tank Equipped with 

Vapor Control (District) 

 

tons-VOC/yr 

from sump 

Control 

Efficiency

tons-VOC 

Controlled

Adjusted 

Annualized Cost

Cost per ton of 

VOC controlled 

2

nd Stage: 7.52 95% 7.14 $343,570 $48,119 

3

rd Stage: 0.93 95% 0.88 $343,570 $390,420 

Based on the analysis above, the cost effectiveness of replacing a 2nd stage sump with 

a tank vented to a vapor recovery and control system is $48,119/year, while the cost for 

a 3rd stage sump replacement is over $390,000/year. Therefore, the costs are beyond 

reasonable and not RACT. 

2. WSPA Analysis of Replacement Tanks 

WSPA also performed a cost effectiveness analysis independent of the District as 

discussed below. WSPA used a different approach to determining costs and in 

determining what types of costs would impact the replacement of the sump with a tank 

with various controls. District staff included this analysis to illustrate that after analyses 

were conducted by WSPA the replacement of sumps with tanks is not a cost effective 

option for operators in the Valley. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix B: RACT Cost Effectiveness Analysis December 15, 2011 

B - 22 Final Staff Report with Appendices for 

 Revised Proposed Amendments to Rule 4402 

To obtain cost estimates in terms of 2011 dollars, the 1986 costs provided by ARB in 

the TSD were multiplied by the ratio of the 2010 Producer Price Index (PPI) relative to 

the 1986 PPI. Since tanks consist primarily of steel, the PPI for “Fabricated Plate work” 

was used for escalating the 1986 costs. The PPI for fabricated Plate Work” was 

obtained from the Bureau of Labor Statistics (BLS). 

Because sumps are used for the continuous separation of oil, water, and sediment at 

least two tanks will be required to replace a single sump. One tank would remain in 

service while the second tank is taken out of service for maintenance and cleaning to 

remove accumulated sediment. To account for the second “standby” tank, the cost 

estimated by the ARB equation was doubled. The equation used for estimating the 

capital costs of replacing heavy oil production sumps with tanks are summarized below. 

Table B-14. Capital Cost Estimate for Tanks Replacing Heavy Oil Sump3 (WSPA) 

Capital cost Equation 

Average 

Area (S) Ft2

Cost 

Escalation 

Factor 

Cost for Two Tanks 

Cost ($) = 

 45.7(S)+0.12*(s)1.5+52,350 

Total Cost 

2010 ($) 

Annualized 

Costs 

($) 

Secondary 2,010.94 1.8924 586,916 95,256 

Tertiary 2,413.97 1.8924 669,534 108,665 

Operating Costs for Tanks 

The Operating costs associated with the tank replacements are summarized below. 

The annual operating cost estimate includes: 

• Operation and Maintenance (estimated to be 1.5% of the total capital cost); 

• Cost for demulisfier/corrosion4 inhibitors required for treating produced water; 

• Cost of labor required for daily gauging and inspection of the tanks (1Hr/day); 

• Cost of labor required to clean tanks annually (72 man hours per year x 2 tanks). 

Table B-15. Annual Operating Cost for Tanks Replacing a Heavy Oil Sump5

 (WSPA) 

Sump 

Type 

O&M 

($/Year)

Treating Cost Labor Costs Total 

Cost 

($/Year) $/Bbl Bbl/Year $/Year Hr/Year $/Hr $/Year

Secondary 5,423 ≈ 0.05 85,745 4,287 437 65 28,405 32,692 

Tertiary 6,756 ≈ 0.05 136,145 6,807 437 65 28,408 35,212 

 

3

 Annualized costs are calculated using a capital recovery factor of 0.1623 (10 years at 10%). 

4

 Additional treating cost will be incurred due to the shorter residence time of the produced water in tanks 

(compared to sumps) and cost for corrosion inhibitors. WSPA conservatively used $0.05 per barrel for 

the incremental treating costs. Some members reported higher chemical treating costs. 

5

 Produced water volumes are distributed to sumps based on the surface area of the sump type. 

Produced water column were obtained from the California DOGGR 2010 well production database. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix B: RACT Cost Effectiveness Analysis December 15, 2011 

B - 23 Final Staff Report with Appendices for 

 Revised Proposed Amendments to Rule 4402 

Small operators do not have significant amounts of gas production. Consequently, field 

gas gathering systems for transport of gas to incineration devices are unavailable. If 

vapor recovery systems were installed on tanks, then many operators would also have 

to construct new pipeline segments to transport vapors to the nearest produced gas 

collection system (which could be miles away). 

The other alternative would be the installation of an onsite VOC destruction device (i.e. 

flare). However, the vapors recovered from the tanks would have a low heating value, 

to sustain combustion supplemental fuel would need to be provided. As discussed 

above, in most cases delivery of fuel gas for tank blanketing or use as supplemental fuel 

in a VOC destruction device would require the installation of new pipelines. 

Given the issues discussed above, and based on discussions with engineers 

knowledgeable in design of vapor recovery systems, depending on the distance to 

nearby pipelines, WSPA believes that it could cost $350,000 to $500,000 (or more) to 

install the piping and equipment required for a tank VRS and a VOC destruction device. 

For the purpose of conducting the cost effectiveness analysis for replacing sumps with 

tanks equipped with a VRS, WSPA assumed an initial capital cost fo $350,000 (or an 

annualized cost of $56,805). 

Table B-16. Capital Costs Incurred for Replacing a Heavy Oil Sump with Tanks and 

Vapor Recovery (WSPA) 

Sump 

Type 

Initial 

Capital 

Costs ($) 

Annualized Costs 

(10 years at 10%) 

Total Annualized 

Cost ($/Year) 

Total 

Annualized 

Cost 

Tanks VRS Tanks VRS ($/Year) 

Secondary 586,914 350,000 95,256 56,805 152,061 

Tertiary 669,534 350,000 108,665 56,805 165,470 

The operating cost associated with a tank replacement and the installation of a vapor 

recovery system includes the operating costs for tanks (discussed previously) plus the 

additional operating cost for the VRS. The incremental, annual operating cost for the 

VRS includes the following: 

• Operation and maintenance (estimated to be 1.5% of the VRS capital cost); 

• Cost of labor required for daily inspection and operation of VRS (1 HR/Day); 

• Annual cost of electricity and fuel required for equipment (not included). 

The incremental operating costs for the VRS are assumed to be independent of the type 

of crude oil production and the type of production sump (secondary, tertiary). The 

incremental, annual operating costs for the operation of the VRS are summarized 

below. 
SAN JOAQUIN VALLEY UNIFIED AIR POLLUTION CONTROL DISTRICT 

Appendix B: RACT Cost Effectiveness Analysis December 15, 2011 

B - 24 Final Staff Report with Appendices for 

 Revised Proposed Amendments to Rule 4402 

Table B-17. Incremental, Annual Operating Cost for a Tank with VRS Replacing a 

Sump (WSPA) 

O&M 

($/Year) 

Fuel and Electricity6 Labor Costs Total 

Cost 

($/Year) 

Fuel and 

Electricity Electricity Hr/Year $/Hr $/Year 

5,250 --- --- 365 65 23,725 28,975 

District staff combined the cost information provided above by WSPA and calculated the 

cost effectiveness using emissions information provided above from the District 

emission inventory. Please refer to Appendix A for the discussion regarding the WSPA 

emission inventory calculations and estimations. 

Table B-18. Cost Effectiveness of Replacing a Heavy Oil Sump with a Tank 

Sump 

Type 

Emissions 

Reduced 

(80%) 

VOC 

(Ton/Year)

Annualized 

Captial Cost 

($/Year) 

Annual 

Operating 

Cost ($/Year) 

Total 

Annual 

Cost 

$/Year 

Control Cost 

Effectiveness 

($/Ton) 

Secondary 6.02 95,256 32,692 127,948 21,254 

Tertiary 0.75 108,665 35,212 143,877 191,836 

Table B-19. Cost Effectiveness of Replacing a Heavy Oil Sump with a Tank with a 

Vapor Recovery System 

Sump 

Type 

Emissions 

Reduced 

(99%) VOC 

(Ton/Year) 

Annualized Cost 

($/Year) 

Annual 

Opeating Cost 

($/Year) 

Total 

Annual 

Cost 

$/Year 

Control Cost 

Effectiveness 

($/Ton) Tanks VRS Tanks VRS 

Secondary 7.45 95,256 56,805 32,692 23,725 208,478 27,984 

Tertiary 0.92 108,665 56,805 35,212 23,725 224,407 243,921 

 

6

 Incremental cost of fuel and electricity are not included because they are not available at the level of 

detail for this cost analysis.