### FROM: David Randall, RTI International

TO: Nick Parsons, EPA/OAQPS

FOR: EPA Docket No. EPA

- HQ

- OAR

- 201 0

- 0871

DATE: January 2 0 , 201 2

SUBJECT: Survey of Control Technology for Storage Vessels and Analysis of Impacts for Storage Vessel Control Options

1. Pur pose

This memorandum documents the survey of control technologies for storage vessels. It reviews control alternatives and estimates the costs and environmental impacts for the alternatives identified. Monitoring, recordkeeping, and reporting burden and co sts are also estimated.

2. Legislative Background

The Clean Air Act (CAA) requires EPA to review promulgated standards periodically to ensure that new source performance standards (NSPS) and national emissions standards for hazardous air pollutants (NESHAP ) reflect advances in emissions reduction technology. Specifically, Section 112(d)(6) of the Clean Air Act (CAA) states that “[t]he Administrator shall review, and revise as necessary (taking into account developments in practices, processes, and control

t echnologies), emission standards promulgated under this section no less often than every 8 years.” Similarly, Section 111(b)(1)(B) requires EPA to review NSPS for a given source category every 8 years, and, if appropriate, revise such standards. To facilit ate these required reviews, EPA is evaluating key emission sources that exist across several source categories to provide a consistent framework when evaluating the emissions from these key sources for a particular source category. This memorandum document s the technology review for storage

vessels.

3. Introduction

Storage vessels are used to store liquid and gaseous feedstocks for use in a process and liquid and gaseous products from a process. Most storage vessels are designed for operation at atmospheric or near atmospheric pressures; high pressure vessels are used to store compressed gases and liquefied gases. Atmospheric storage vessels are typically cylindrical with a vertical orientation, and they are constructed with either a fixed roof or a floating roof. Some, generally small, atmospheric storage vessels are oriented horizontally. High pressure vessels are either spherical or horizontal cylinders. All of the storage vessels in this analysis are aboveground storage vessels; underground storage tanks are not considered.

4. Description of Emission Releases

Emissions from Fixed Roof Storage Vessels

Emissions from fixed roof storage vessels (both vertical and horizontal vessels) occur from working losses, breathing loses, and leaks. Working losses are th e combined emissions fromTechnical Memorandum

– Technology Review for Storage Vessels January 20, 2012



### 2 filling and emptying the storage vessel. Emissions during filling operations result from an increase in the liquid level in the storage vessel. As the liquid level increases, the pressure inside the tank exceeds the relief pressur e and vapors are expelled from the storage vessel. Emissions also occur as a result of withdrawing liquid from the storage vessel because some of the stored liquid evaporates to partially saturate the air that is drawn in as the liquid is withdrawn. This

i ncrease in the amount of vapor causes the pressure to increase; as when filling the storage vessel, when the pressure exceeds the relief pressure, the vent opens and vapors are released to the atmosphere. Factors that affect the mass of working losses incl ude the saturation level of the pollutant in the vapor space, vapor pressure of the stored material, vapor molecular weight, total throughput, and capacity of the storage vessel.

Breathing (or standing) losses are emissions caused by vapor expansion and co ntraction, which are the result of changes in temperature and barometric pressure. These emissions occur without any changes in the liquid level in the storage vessel. Factors that affect the mass of breathing losses are the vapor pressure of the stored ma terial, atmospheric conditions (e.g., daily total solar insolation and daily range of ambient temperatures), breather vent pressure and vacuum settings, vessel dimensions, and vapor molecular weight. If the stored liquid is maintained at a constant

tempera ture, breathing emissions are minimized or eliminated.

Another potential source of emissions from storage vessels is leaks from various improperly closed openings such as defective pressure/vacuum vents and poorly fitting or deteriorated gaskets used to se al closure devices for openings such as access hatches. Procedures for estimating such emissions are not available. However, factors that affect the mass of these emissions are the size and number of openings, the vapor pressure of the stored material, and atmospheric conditions such as wind. Some of the breathing and working emissions may also occur through the leak openings rather than the intended vent.

Emissions from Floating Roof Storage Vessels

During normal operations, a floating roof is floating on the liquid in the storage vessel. Emissions during normal operations occur due to withdrawal losses, rim seal losses, and deck fitting losses. In addition, deck seam losses are a source of emissions from internal floating roofs (IFRs) with bolted decks. W hen the storage vessel is emptied to the point that the floating roof is landed on its supports, emissions also occur due to standing idle losses and filling losses.

Withdrawal losses occur as the liquid level and floating roof are lowered. Some liquid rem ains on the inner wall of the storage vessel and evaporates. Similarly, liquid that remains on the surface of fixed roof support columns in IFR storage vessels will also evaporate. The mass of

these emissions is a function of the surface area

- to

- volume ra tio of the storage vessel, the roughness of the wall (which affects the amount of liquid that can cling to the wall after the liquid level drops), the total throughput, and the density of the stored liquid.

Rim seal losses are emissions that escape through gaps between the rim seal and the inner wall of the storage vessel. The primary mechanism generating rim seal emissions is the wind and thus, rim seal losses for external floating roofs (EFRs) are greater than for IFRs. For average fitting seals, an empir ical relationship has been developed that estimates the emissions as a function of the type of rim seal system (type and number of seals), storage vessel construction (riveted or welded), vapor pressure of the stored liquid, average wind speed, and vapor m olecular weight (U.S

. EPA, 1995a).Technical Memorandum

– Technology Review for Storage Vessels January 20, 2012



### 3 Numerous fittings pass through or are attached to floating roof decks to accommodate structural support components or to allow for operational functions. Typical deck fittings include access hatches, gauge floats, gauge

- h atch/sample ports, rim vents, deck drains, deck legs, vacuum breakers, and guidepoles. Storage vessels with IFRs may also have fixed

- roof support columns, ladders, and stub drains. Empirical relationships have been developed to estimate emissions from

thes e deck fittings; these relationships express emissions as a function of the number of each type of fitting, fitting design (e.g., type of cover, wiper, gasket, or other features to minimize openings), vapor pressure of the stored material, and vapor molecu lar weight (U.S

. EPA, 1995a).

Internal floating roofs with a deck formed from panels bolted together also have emissions through the seams between the panels. These emissions are estimated as a function of the total length of seams, an average emission fa ctor per unit length of seam, the vapor pressure of the stored material, and the vapor molecular weight.

After a floating roof is landed on its supports, each vacuum breaker is open (if the device is

activated when the leg extension associated with the vac uum breaker contacts the floor of the storage vessel). These openings provide a pathway for outside air to circulate through the vapor space under the landed floating roof and for pollutant vapors to escape. Rim seal gaps and other

non

- vapor tight deck fit tings provide additional pathways for circulation. The three mechanisms that contribute to standing idle losses are: (1) breathing losses from the vapor space; (2) wind losses; and (3) clingage losses. The primary factors affecting the amount of emissions are the amount of time the roof is landed, the size of the vapor space, and whether there is a liquid heel.

Additional emissions are generated when the storage vessel is refilled to the point of refloating the floating roof. These emissions occur as the va por is displaced through the vacuum vents and other openings as it is replaced with liquid. The quantity of emissions depends on the saturation level in the vapor space. The saturation level for a vessel with a liquid heel is greater than for a drain dry t ank. Wind effects cause the saturation level for a storage vessel with an EFR to be lower than for a storage vessel with an IFR.

Emissions from Pressure Vessels

Low

- pressure tanks (2.5 to 15 psig) have working losses just like fixed roof tanks, but breath ing losses generally are prevented. High

- pressure tanks are considered closed systems and, if properly maintained and operated, should have virtually no emissions; there may be low levels of fugitive emissions, and vessels storing liquefied gases may be ve nted periodically to purge inerts.

Emissions from Degassing Storage Vessels

All storage vessels must occasionally be shut down for cleaning, maintenance, inspections, or other reasons. If facility personnel need to enter the storage vessel, or residual li quid needs to be removed before refilling with a different material, or the storage vessel is to be taken out of service, the storage vessel first may be degassed. Degassing means the process of removing stored material vapors from the storage vessel. Hist orically, these vapors have been vented to the atmosphere. The mass of emissions will vary depending on the size of the vapor space, the vapor pressure of the stored liquid, the amount of residual liquid in the storage vessel, the degree of

saturation in t he vapor space when degassing begins, and the vapor molecular weight.Technical Memorandum

– Technology Review for Storage Vessels January 20, 2012



### 4 5. Identification of Control Technologies

Fixed roof storage vessels

Working and breathing losses from fixed roof storage vessels can be controlled by: (1) installing an IFR; (2) routin g displaced vapors through a closed vent system to a control device; (3) vapor balancing back to the transport vehicle that supplies the liquid being added to the storage vessel; or (4) replacing the fixed roof storage vessel with a storage vessel that has an EFR. Leaks from fittings on the fixed roof (e.g., conservation vents, access hatches, and emergency pressure relief devices) are another source of emissions. Leaks can be controlled by periodic monitoring for leaks and repair of fittings that are found to be leaking. Table 1 summarizes the four control options that we developed and evaluated in the impacts analysis. These options are based on variations in IFRs and monitoring for leaks. The closed vent system to control device and vapor balancing approa ches generally achieve control levels comparable to, or marginally better than, a well controlled IFR (at least for storage vessels that store materials with higher vapor pressures). However, a closed vent system and control device is more costly than an I FR (U.S. EPA, 1980;

U.S

. EPA, 1984; Randall and Fields, 2000), and vapor balancing may not be feasible for storage vessels that are designed to operate at pressures less than 2.5 psig, which is the required set pressure for pressure relief devices under va por balancing options in current rules ; thus, these techniques are not evaluated as separate control options in this analysis. We also did not develop a control option based on the use of an EFR because a storage vessel with a fixed roof is generally used for material with a lower vapor pressure than storage vessels with an EFR. Furthermore, the cost to construct a new tank and EFR is expected to be more than the cost to install an IFR in an existing fixed roof storage vessel. Thus, we expect facilities gen erally would

not elect to make such a switch.

Table 1. Summary of control options for fixed roof storage vessels

Control Option Technology or work practice Comments

ST1 IFR with single rim seal and typical deck fittings See Table 4 for a list of the typi cal deck fittings and their typical control

ST2 IFR with single rim seal and deck fittings controlled as required by current rules such as 40 CFR part 63, subpart WW See Table 4 for the more effective deck fitting control designs

ST3 Slotted ladder leg c ontrols consisting of a gasketed deck cover, cap on top of the slotted leg, a ladder sleeve, and pole wipers

ST4 Annual leak detection monitoring of fittings on fixed roof using either EPA Method 21 or optical gas imaging, and repair if leak is detected Leak defined as instrument reading greater than 500 ppmv (Method 21) or an image of emissions (optical gas imaging)



### Control Options ST1 and ST2 are based on the use of an IFR. Different levels of control are possible depending on the type of technology used to control deck fittings. Control Option ST1 consists of an IFR with a single rim seal and typical deck fitting controls. Control Option ST2 consists of an IFR with the same rim seal as in Control Option ST1 and more effective deck fittings controls s uch as those required in 40 CFR part 63, subpart WW. See section 6 of this memorandum for details regarding the typical and upgraded fittings under Control Options ST1

and ST2.Technical Memorandum

– Technology Review for Storage Vessels January 20, 2012



### 5 We also evaluated impacts for two narrowly targeted control options. First, slo tted ladder legs that are used for gauging liquid levels are one type of deck fitting that has not been clearly addressed in existing rules. Emissions from such ladders can be controlled using a gasketed deck cover, a cap on the top of the ladder leg, and either a flexible enclosure or various combinations of a ladder sleeve, pole wipers, and/or pole float that eliminate the vapor emission pathway from inside the storage vessel through the ladder slots to air above the floating roof. In this analysis,

Contr ol Option ST3 is based on the use of a ladder sleeve and pole wiper, which is comparable to one of the options for slotted guidepoles in 40 CFR part 63, subpart WW. This control option can be viewed as an extension of either Control Option ST1 or ST2 (both control options assume ladder legs are solid). Second, EPA inspectors have conducted instrument

- based monitoring of fittings on fixed roofs (i.e., using optical gas imaging) and identified leaks that were not detected when conducting visual inspections (P arsons, 201 2 ). Thus, we developed Control Option ST4 to evaluate the impacts of conducting instrument

- based monitoring of fittings on fixed roof storage vessels that are not subject to other controls.

Storage vessels with external floating roofs

Adding an EFR can be a control technique for an open vessel. However, in this analysis we assumed that there are no open

- top vessels storing volatile organic materials and that an external floating roof with one rim seal and typical deck fittings is baseline. Table 2 summarizes the three control options that we developed for evaluation in the impacts analysis. Control Option ST5 consists of adding a second rim seal, Control Option ST6 consists of upgrading the deck fitting controls to be consistent with the requireme nts in current rules such as 40 CFR part 63, subpart WW, and Control Option ST7 consists of installing a geodesic dome over a storage vessel that is meeting the requirements of Control Option ST6. See Table 6 for the typical and more effective deck fitting controls.

Table 2. Summary of control options for EFR storage vessels

Control option Technology and work practices Comments

ST5 Add a second rim seal Baseline is one rim seal and typical deck fittings

ST6 Upgrade a storage vessel that meets the criteria of Control Option ST5 to more effective deck fittings controls consistent with requirements in current rules such as 40 CFR part 63, subpart WW

ST7 Install a geodesic dome over a storage vessel that meets the criteria of Control Option ST6



### Pressure v essels

No control options apply for pressure vessels because pressure vessels are defined as closed systems that do not vent when properly operated and maintained.

Degassing

Degassing emissions can be controlled by drawing vapors from the storage vessel ( below the floating roof, if so equipped) to a control device. State and local rules that require degassing controls require operation of the control system until the concentration in the storage vesselTechnical Memorandum

– Technology Review for Storage Vessels January 20, 2012



### 6 drops below a threshold level, which varies among the rules. For example, Texas requires vapors to be routed to a control device until the VOC concentration is less than 34,000 ppmv expressed as methane (or less than 50 percent of the lower explosive limit), and the South Coast Air Quality Management District (SCAQMD) requires control until the concentration is less than 5,000 ppmv expressed as methane. The required performance of the control devices also varies among existing rules. For example, Texas requires the control device to maintain a control

efficien cy of at least 90 percent, and the SCAQMD requires control devices to reduce emissions to an outlet concentration less than 500 ppmv (TCEQ ; SCAQMD , 2008a ). Typically, facilities control degassing emissions by routing vapors to a mobile control device that is owned and operated by an outside contractor. Mobile control systems that have been used include thermal oxidizers, refrigerated condensers, and internal combustion engines. Some facilities have installed closed vent systems to convey degassing emissions (as well as breathing and working losses) to permanent onsite control devices such as flares and thermal oxidizers ( Moore, 2009 )

. We developed one control option for evaluation in this analysis. Control Option ST8 consists of routing emissions to a mobile thermal oxidizer (operated by a contract service provider) until the concentration of organic compounds in the storage vessel are reduced to less than 5,000 ppmv as

methane.

6. Model Development

Fixed Roof Storage Vessels and Internal Floating Roofs

Th e impacts of Control Options ST1 and ST2 for fixed roof storage vessels were developed using three model storage vessels with the characteristics presented in Table 3. A majority of fixed roof storage vessels that store organic chemicals are smaller than M odel C (U.S. EPA, 1980; Randall and Fields, 2000). Some fixed roof storage vessels are several times larger, but the impacts for model C are such that they adequately represent the impacts for larger storage vessels. Model A was selected because it represe nts the smallest practical size for control with an internal floating roof. For each model, the diameter

- to

- height (D/H) ratio was assumed to be about 1:1, as in previous analyses (U.S. EPA, 1980; U.S. EPA, 1994). The typical throughput was developed based on a survey of turnovers for different sized storage vessels at chemical manufacturing facilities (U.S. EPA, 1980). Each model storage vessel was evaluated with a variety of stored materials representing a wide range of vapor pressures because the total

e missions are a strong function of the vapor pressure.

Table 3. Model fixed roof storage vessels

Parameter Model storage vessel characteristics

Model A B C Capacity, gal 20,000 40,000 200,000 Height, ft 15 19 33
Diameter, ft 15 19 32 Throughput, gal/yr 4,700,000 5,600,000 10,000,000 Vapor pressure of stored material, psia at 25°C 1 Varied Varied Varied

1 Vapor pressures varied from less than 0.1 psia to more than 8 psia (see Table 8).



### The IFRs for the model storage vessels were assumed to have typical f ittings and a typical number of fittings as presented in AP

- 42 chapter 7.1, except that we also included an unslottedTechnical Memorandum

– Technology Review for Storage Vessels January 20, 2012



### 7 guidepole (U.S. EPA 1995a). We examined the impacts for storage vessels with no guidepole and with a slotted guidepole, but only the resul ts for the unslotted guidepole are presented in this memorandum because all three results are similar, and the results for the unslotted guidepole are between those for no guidepole and a slotted guidepole. The typical construction of each deck fitting for Control Option ST1 is also based on information from AP

- 42 chapter 7.1. The modeled deck fittings for Control Option ST2 are consistent with requirements in many recent rules such as 40 CFR part 63, subpart WW. The decks were assumed to be constructed fro m 5

- ft wide panels bolted together. Specific details of the fittings in IFRs for the model storage vessels

are summarized in Table 4.

Table 4. Deck fittings for IFRs

Type of deck fitting Deck fitting counts Deck fitting construction

Model

A Model

B Model

C Control Option ST1 Control Option ST2

Access hatches 1 1 1 Unbolted cover, ungasketed Bolted cover, gasketed

Automatic gauge

float wells 1 1 1 Unbolted cover, ungasketed Bolted cover, gasketed

Column wells 1 1 1 Built up column, ungasketed sliding co ver Built

- up column, gasketed sliding cover

Unslotted guidepole 1 1 1 Ungasketed sliding cover Gasketed sliding cover and pole wiper

Ladder wells 1 1 1 Sliding cover, ungasketed Sliding cover, gasketed Roof legs 7 8 10 Adjustable Sample wells 1 1 1 Sli t fabric seal, 10% open

Stub drains 2 3 9 Slit fabric seal, 10% open

Vacuum breakers 1 1 1 Weighted mechanical actuation, gasketed



### Models in the analysis of Control Option ST3 consisted only of a typical ladder with solid legs versus a comparable ladde r with slots in one leg and a flexible enclosure. The typical ladder was assumed to have an ungasketed sliding deck cover, consistent with information in Table 7.1

- 12

in AP

- 42 (U.S. EPA, 1995a).

We evaluated impacts of Control Option ST4 for a single typic al storage vessel with 8 fittings on the fixed roof (an access hatch, a gauge hatch, a conservation vent, an emergency pressure relief vent, and 4 miscellaneous valves and instruments). Details of the costs and emissions for Control Option ST4 are presente d in section 10 of this memorandum with analyses for other monitoring, recordkeeping, and reporting options.

External Floating Roofs

Storage vessels designed with EFRs often are much larger than fixed roof storage vessels, particularly at petroleum refine ries. To represent such storage vessels, we developed the six models presented in Table 5. These model storage vessels store three typical types of material at petroleum refineries: crude oil (RVP 5.0), gasoline (RVP 8.3), and jet naphtha. The diameters

an d heights are based on typical values from permits for refineries in Louisiana (RTI, 2002). The throughputs are based on the same data used to estimate throughputs for the models in Table 3. (Many storage vessels at petroleum refineries have much higher th roughputs. However, suchTechnical Memorandum

– Technology Review for Storage Vessels January 20, 2012



### 8 differences do not affect this analysis because changes in throughput affect only withdrawal emissions, and none of the control options reduces withdrawal emissions.) In addition to these six models, we also evaluated impacts for s maller EFR storage vessels at chemical manufacturing facilities using the three models presented in Table 3 (except that they are assumed to have an EFR in this analysis rather than a fixed roof). All of the models have a welded shell, white paint in good condition, a pontoon

- type EFR, and a mechanical shoe rim

seal.

Table 5. Model EFR storage vessels at petroleum refineries

Parameter Model storage vessel characteristics

Model D E F G H I

Stored material Crude oil Crude oil Gasoline Gasoline Jet naphtha J et naphtha Capacity, million gal 3.38 10.9 1.05 10.9 1.90 6.79 Height, ft 40 40 40 40 40 40
Diameter, ft 120 215 67 215 90 170 Throughput, million gal 26.9 40.4 17.9 40.4 22.2 34.3 Vapor pressure of stored material, psia at

25°C 3.97 3.97 5.85 5.85 1. 81 1.81



### For Baseline and Control Option ST5, the count and construction of each deck fitting is assumed to be consistent with designations in Table 7.1

- 12 of AP

- 42, chapter 7.1 (U.S. EPA, 1995a). For Control Option ST6, the model deck fittings are consis tent with requirements in recent rules such as 40 CFR part 63, subpart WW. Specific details of the fittings in EFRs for the model storage vessels are presented in Table 6. For Baseline and all control options, the secondary rim seal is

assumed to be rim

- mo unted. The model storage vessels and EFRs for Control Option ST7 are the same as in Control Option ST6, except that they include a geodesic dome over the storage vessel.

We examined impacts for EFRs with both slotted and unslotted guidepoles. Only the resu lts for slotted guidepoles are presented in this document because storage vessels with slotted guidepoles are used in a significant fraction of EFR storage vessels at petroleum refineries, and both the emissions and costs for control can be significantly h igher than for unslotted guidepoles. Furthermore, the resulting cost effectiveness values are comparable for both types of guidepoles if the most costly control technique (a flexible enclosure) is used for the slotted guidepoles. Therefore, Table 6 shows t he model EFR storage vessels are equipped with a slotted guidepole. Under Baseline and Control Option ST5 the model slotted guidepole was assumed to have an ungasketed cover, and under Control Options ST6 and ST7 the guidepole was assumed to be

controlled with a flexible fabric enclosure.

Pressure Vessels

No model pressure vessels were developed for the control impacts analysis because no control options were developed for pressure vessels.Technical Memorandum

– Technology Review for Storage Vessels January 20, 2012



### 9 Table 6. Deck fittings for EFRs

Type of deck fitting Deck fitting counts Deck fitting construction

Model

A/B/C Model

D Model

E/G Model

F Model

H Model

I Baseline and Control Option

ST5 Control Option

ST6 and Control Option ST7

Access

hatches 1 1 1 1 1 1 Bolted and gasketed cover

Automatic gauge float

wells 1 1 1 1 1 1 Unbolted, ungasketed

cover Bolted and gasketed cover

Vacuum

breakers 1 1 3 1 1 2 Weighted mechanical actuation, gasketed

Slotted guidepoles 1 1 1 1 1 1 Ungasketed sliding cover Gasketed sliding

cover with

flexible

enclosure Gauge

hatch/ sample

wells 1 1 1 1 1 1 Weighted mechanical actuation, gasketed

Roof legs (pontoon area) 4 19 32 13 16 27 Ungasketed

Roof legs (center area) 2 24 83 9 12 49 Ungasketed

Rim vents 1 1 1 1 1 1 Weighted mechanical actuation, gasketed



### Degassing

We evaluated the impact s of degassing controls for a matrix of model storage vessels. The model storage vessels presented in Table 3 were not used in this analysis because the resulting cost impacts are very high for storage vessels in that size range that have a floating roof. Therefore, for this analysis we developed models that resulted in a range of cost effectiveness values between about $2,500/ton of emissions reduction and $10,000/ton of emissions reduction under Control Option ST8. For each type of stored material we deve loped small models that have a cost effectiveness of about $2,500/ton, medium models that have a cost effectiveness of about $5,000/ton, and large models that have a cost effectiveness of about $10,000/ton. To meet these criteria, the model storage vessel sizes differed for each type of stored material. For storage vessels with a floating roof, the volume of vapor space to be degassed is the volume under the roof at its landed height. In this analysis, we assumed the roof lands at a height of 5 feet above

t he floor of each model storage vessel. We varied the model heights in 8

- ft increments based on the standard width of the sheet metal, up to a maximum of 40 feet for petroleum products and 48

feet for chemicals. Diameters for the models were selected based on the following criteria: (1)

the diameter was always equal to or greater than the height ; (2) for the small and medium models, the D/H ratio ranged up to 1.5:1 before going to the next height; and (3) for any model atTechnical Memorandum

– Technology Review for Storage Vessels January 20, 2012



### 10 the maximum height, the diameter was set at whatever size was needed to reach the cost effectiveness value of $2,500/ton. All of the characteristics of the stored materials and resulting model storage vessel dimensions and capacities are presented in Table 7.

7. Emissions Estimates

Uncontrol led emissions from fixed roof storage vessels

Uncontrolled emissions from the model fixed roof storage vessels in Table 3 were calculated using TANKS4.0.9d (U.S. EPA

, 2006) . Meteorological conditions were based on Houston, Texas. The sum of the working and breathing losses are presented in Table 8. We wanted to focus on scenarios where cost impacts of control options ranged from break even to about $10,000/ton of VOC. Therefore, the analysis for small models includes storage of materials with slightly highe r vapor pressures than the analysis for large models.

Controlled emissions from Fixed Rood Storage Vessel (Control Options ST1 and ST2)

Controlled emissions from the model fixed roof storage vessels with characteristics presented in

Tables 3 and 4 were cal culated using a spreadsheet that replicates the procedures in TANKS4.0.9d. The resulting sum of rim seal losses, withdrawal losses, deck fitting losses, and deck seam losses for storage vessels with unslotted guidepoles are presented in Table 9. Only the

d eck fitting losses change between Control Options ST1 and ST2; the difference in deck fitting construction as presented in Table 4 accounts for this difference in emissions.

Baseline and Controlled Emissions for Slotted Ladders (Control Option ST3)

Emissio ns factors for slotted ladder legs are unavailable. However, according to AP

- 42, a ladder with solid legs and a gasketed deck cover has an emission factor (K Fa 

### ) of 56 lbmole/yr. This is about 80 percent higher than the K Fa 

### for an unslotted guidepole with a n ungasketed deck cover in

AP

- 42 (i.e., 31 lbmole/yr). Thus, we assumed the K Fa 

### for a ladder with a slotted leg is also 80 percent higher than the K Fa 

### for a slotted guidepole with a gasketed deck cover (77 lbmole/yr versus 43 lbmole/yr). The emission facto r for a ladder with solid legs and a ladder sleeve in addition to a gasketed deck cover has been estimated to be 29 lbmole/yr (Ferry, 2006). This is about 3.3 times higher than the factor for an unslotted guidepole with the same controls (i.e., 8.6

lbmole/ yr). Assuming the same ratio applies for slotted ladder legs and slotted guidepoles gives a controlled emission factor of about 37 lbmole/yr for a slotted ladder leg controlled with a ladder sleeve and a gasketed deck cover (i.e., 11 x 3.3 = 37). According to the AP

- 42 factors, adding a pole wiper lowers the factor slightly. Therefore, we assumed a factor of 35 lbmole/yr for this analysis.Technical Memorandum

– Technology Review for Storage Vessels January 20, 2012



### 11 Table 7. Characteristics of model storage vessels for analysis of degassing controls

Parameter Characteristics of mod el storage vessels storing various materials

Crude oil (RVP 5) Gasoline (RVP 8.3) Vinylidene

chloride n

- pentane Methylene

chloride Diethylamine Chloroprene Vapor molecular weight 50 68 96.5 72.15 84.94 73.14 88.54 Vapor pressure 1 3.56 5.46 11.06 9.09 7 .32 4.02 3.94 Density of liquid (lb/gal) 7.1 5.6 10.38 5.25 11.12 5.91 8.05 Lower heating value, Btu/lb 18,400 18,700 4,800 19,500 2,500 16,600 3,000 Vessel volume (gal)

Small 611,000 230,000 33,900 103,000 88,100 286,000 205,000

Medium 1 ,580,000 763,000 111,000 348,000 244,000 903,000 541,000 Large 7,280,000 3,730,000 332,000 2,930,000 635,000 4,200,000 1,380,000 Height (ft)

Small 40 32 16 24 24 32 32

Medium 40 40 24 32 32 40 40 Large 40 40 32 48 40 48 48

Diameter (ft)

Small 51 35 19 27 25 39 33

Medium 82 57 28 43 36 62 48 Large 176 126 42 102 52 122 70 Volume degassed for vessel with IFR/EFR (ft 3 ) 2

Small 10, 0 00 4,800 1,400 2,900 2,500 6,000 4,300

Medium 26, 0 00 1 3

, 0 00 3,100 7,300 5,100 15, 0 00 9,000 Large 12 0 ,000 62, 0 00 6,900 41,000 1 1

, 0 00 58, 0 00 19, 0 00

1 Vapor pressure at the temperature of the vapor space, which was assumed to be 74°F for each model storage vessel.

2 Volume under the floating roof determined assuming the floati ng roof lands at a height 5 ft above the floor for each model storage vessel.Technical Memorandum

– Technology Review for Storage Vessels January 20, 2012



### 12 Table 7. Characteristics of model storage vessels for analysis of degassing controls (continued)

Parameter Characteristics of model storage vessels storing various materials

C hloroform n

- hexane 1,1,1

- trichlorethane Methanol Benzene Vapor molecular weight 119.39 86.17 133.42 32.04 78.11 Vapor pressure 1 3.47 2.62 2.25 2.13 1.66 Density of liquid (lb/gal) 12.49 5.53 11.22 6.63 7.37

Lowe r heating value (Btu/lb) 1,500 19,400 4,0 00 9,100 17,400 Vessel volume (gal)

Small 127,000 476,000 24 4 ,000 1,720,000 818,000

Medium 348,000 1,540,000 635,000 3,790,000 2,490,000 Large 903,000 7,960,000 1,670,000 9,440,000 10,100,000 Height (ft)

Small 24 40 32 48 40

Medium 32 48 40 48 48 Large 40 48 48 48 48 Diameter (ft)

Small 30 45 36 78 59

Medium 43 74 52 116 94 Large 62 168 77 183 189 Volume degassed for vessel with IFR/EFR (ft 3 ) 2

Small 3,500 8,000 5,100 2 4

, 0 00 1 4

, 0 00

Medium 7, 300 2 2

, 0 00 1 1

, 0 00 5 3

, 0 00 3 5

, 0 00 Large 15, 0 00 11 0 ,000 23, 0 00 13 0 ,000 140,000

1 Vapor pressure at the temperature of the vapor space, which was assumed to be 74°F for each model storage vessel.

2 Volume under the floating roof determined assuming the flo ating roof lands at a height 5 ft above the floor for each model storage vessel.Technical Memorandum

– Technology Review for Storage Vessels January 20, 2012



### 13 Table 8. Uncontrolled emissions from fixed roof storage vessels

Stored material Vapor pressure at

25°C Uncontrolled emissions, lb/yr

Model A Model B Model C Acrylic acid 0.08 2 70 97 0 Xylene 0.13 620 2,2 00

Toluene 0.55 1, 500 2, 400 8, 400 Methyl methacrylate 0.70 2,0 00 3, 300 1 2

, 000
1,4

- Dioxane 0.72 1,8 00 3,000 1 1

, 000

Formic acid 0.83 1,1 00 1,8 00 6, 400

Isooctane 0.95 3, 200 5, 200 18, 000

Ethanol 1. 2 1,5 00 2, 500 8, 600

T richloroethylene 1.3 5,1 00 8,3 00 2 9

, 000 Ethylene dichloride 1.5 4, 400 7,1 00 2 5

, 000 Methyl ethyl ketone 1.7 3, 700 6,000 2 1

, 000

Acetonitrile 1. 8 2, 200 3, 500 12, 000 Ethyl acetate 1.8 4,7 00 7, 700 26, 000 Jet naphtha 1.8 7, 200 2 5

, 000

Benzene 1.8 4,2 00 6, 9 00 2 4

, 000 Vinyl acetate 2.2 5,6 0 0 9,1 00 31, 000 Acrylonitrile 2.2 3, 500 5,6 00 19, 000

Methanol 2.4 2, 300 3, 700 1 3

, 000
1,1,1

- trichlorethane 2. 6 10, 000 1 7

, 000 56, 000 Methylcyclopentane 2. 7 6, 700 1 1

, 000 3 7

, 000

Hexane 2.9 7, 600 12, 000 4 2

, 000

Chloroform 3. 8 13, 000 2 2

, 000 7 4

, 000 Diethylamine 4.6 10, 000 16, 000 Methylene chloride 8.3 2 3

, 000Technical Memorandum

– Technology Review for Storage Vessels January 20, 2012



### 14 Table 9. Emissions from fixed roof storage vessels controlled with IFR

Stored material Controlled emissions (lb/yr)

Model A Model B Model C

Control Option

ST1 C ontrol Option

ST2 Control Option

ST1 Control Option

ST2 Control Option

ST1 Control Option

ST2 Acrylic acid 12 0 1 20 1 40 13 0 Xylene 15 0 13 0 1 80 1 60

Toluene 3 50 280 3 70 300 4 60 3 90 Methyl methacrylate 46 0 36 0 49 0 400 610 51 0
1,4

- Dioxane 4 40 3 50 46 0 3 80 57 0 48 0

Formic acid 32 0 2 70 33 0 280 40 0 3 50

Isooctane 6 60 500 7 10 5 60 900 74 0

Ethanol 3 60 28 0 3 80 30 0 4 70 39 0 Trichloroethylene 1, 100 8 50 1, 200 930 1, 500 1,2 00 Ethylene dichloride 94 0 73 0 1,0 00 80 0 1, 300 1, 100 Methyl ethyl ketone 77 0 59 0 8 40 65 0 1

, 100 87 0

Acetonitrile 48 0 3 80 5 20 41 0 6 50 54 0 Ethyl acetate 980 7 50 1, 100 8 30 1,3 00 1,1 00 Jet naphtha 98 0 76 0 1,2 00 1,0 00

Benzene 8 90 680 96 0 75 0 1,2 00 1,00 0 Vinyl acetate 1, 200 890 1, 300 9 90 1,6 00 1,3 00 Acrylonitrile 74 0 5 70 800 6 30 1,00 0 8 40

Met hanol 5 10 400 54 0 43 0 680 5 70
1,1,1,

- trichloroethane 2,1 00 1, 600 2, 300 1, 800 2,9 00 2, 400 Methylcyclopentane 1, 400 1,0 00 1, 500 1, 200 1,9 00 1, 600

Hexane 1,5 00 1, 200 1, 700 1,30 0 2, 2 00 1, 800

Chloroform 2,8 00 2,1 00 3, 100 2, 400 3,9 00 3,2 00 Diethylamine 2,1 0 0 1,6 00 2,3 00 1,80 0 Methylene chloride 5, 400 4,0 00



### Baseline and Controlled Emissions from External Floating Roof Storage Vessels

Baseline emissions and the controlled emissions under Control Options ST5, ST6, and ST7 from model storage vessels wit h an EFR and the characteristics in Tables 3, 5, and 6 were estimated using a spreadsheet that replicates the procedures in TANKS4.0.9d. The results are presented in Table 10. The emissions include rim seal losses, withdrawal losses, and deck fitting losse s. As with the fixed roof and IFR storage vessels, meteorological conditions in Houston, Texas were considered to be representative.Technical Memorandum

– Technology Review for Storage Vessels January 20, 2012



### 15 Table 10. Emissions from model storage vessels with an EFR

Stored material Vapor
pressure at
25°C Emissions (lb/yr)

Bas eline Control Option ST5 Control Option ST6 Control Option ST7

Model A Xylene 0.13 71 0 6 40 130 86

Toluene 0.55 2, 600 2, 300 200 10 0 Methyl methacrylate 0.70 3,5 00 3, 200 250 12 0

Formic acid 0.83 2,0 00 1,8 00 200 1 30

Isooctane 0.95 5,5 00 5,000 32 0 12 0

M ethyl ethyl ketone 1.7 6,500 5,8 00 38 0 14 0

Benzene 1.8 7, 600 6,7 00 4 40 16 0

Methanol 2.4 4, 100 3,600 26 0 1 20

Hexane 2.9 1 4

, 000 12, 000 72 0 21 0

Chloroform 3. 8 25, 000 2 3

, 000 1,3 00 41 0

Model B Acrylic acid 0.08 37 0 3 40 10 0 91 Xylene 0.13 730 64 0 1 10 81

Toluene 0.55 2,6 00 2, 300 20 0 10 0 Methyl methacrylate 0.70 3,6 00 3, 200 260 120

Formic acid 0.83 2, 100 1,8 00 20 0 12 0

Isooctane 0.95 5,7 00 5,000 34 0 12 0 Methyl ethyl ketone 1.7 6,7 00 5, 900 4 10 14 0

Benzene 1.8 7, 800 6, 800 4 70 16 0

Methanol 2.4 4, 200 3,6 00 2 80 11 0

Hexane 2.9 14, 000 12, 000 7 80 2 20 8

Model C Acrylic acid 0.08 4 10 34 0 11 0 97 Xylene 0.13 80 0 6 60 120 86

Toluene 0.55 2,900 2,3 00 24 0 11 0 Methyl methacrylate 0.70 4,0 00 3,2 00 31 0 13 0

Formic acid 0.83 2, 300 1, 900 2 40 13 0

Isooctane 0.95 6,3 00 5

, 100 42 0 1 40 Methyl ethyl ketone 1.7 7,4 00 6,000 570 180

Benzene 1.8 8, 600 6, 900 340 130

Methanol 2.4 4,6 00 3,7 00 500 160

Hexane 2.9 1 6

, 000 1 3

, 000 97 0 25 0 Petroleum liquid models Model D (crude oil) 4.0 9,1 00 5, 100 1, 100 4 20 Model E (crude oil) 4.0 1 3

, 000 5,7 00 1, 800 5 80 Model F (gasoline) 5.8 36, 000 24, 000 3,000 73 0 Model G (gasoline) 5.8 6 9

, 000 30,000 8, 500 2, 200 Model H (jet naphtha) 1.8 1 3

, 000 7,7 00 1, 200 31 0 Model I (jet naphtha) 1.8 18,0 00 8,6 00 2, 100 540Technical Memorandum

– Technology Review for Storage Vessels January 20, 2012



### 16 Emissions from Degassing

Uncont rolled emissions from degassing operations were estimated based on data from degassing logs obtained by the SCAQMD during development of degassing regulations in the District (SCAQMD, 2008). Most of the logs were for degassing storage vessels that were use d to store gasoline. These logs showed a wide range in the mass of emissions relative to the amount of gasoline vapor that could be held in the vapor space at saturation. On average, the emissions were 1.3 times the saturated vapor level, which suggests th at in many cases, storage vessels contain residual liquid (alone or as a component in sludge) that volatilizes and is emitted while degassing. In the absence of data for degassing of storage vessels used to store other types of materials, we assumed that t his factor is representative of degassing all storage vessels and used it to estimate typical degassing emissions for all of the model storage vessels in Table 7. The results are presented in Table 11.

Table 11. Uncontrolled degassing emissions from model storage vessels

Stored material Uncontrolled degassing emissions, lb/event

Small Medium Large

Crude oil 410 1, 100 4,9 00

Gasoline 410 1, 100 5,2 00 Vinylidene chloride 340 750 1, 700

n

- pentane 430 1, 100 6, 100 Methylene chloride 350 720 1,500 Diethylami ne 400 1,0 00 3,900 Chloroprene 340 720 1,5 00

Chloroform 330 680 1,4 00

n

- hexane 410 1,100 5, 700
1,1,1

- trichlorethane 350 720 1, 600

Methanol 370 820 2,0 00

Benzene 400 1,0 00 4,1 00



### Control devices can be designed and operated to reduce incoming emissio ns by 95 percent or more. However, the overall reduction relative to uncontrolled emissions will also depend on how much material is left in the storage vessel when degassing control stops. If degassing is required until the concentration in the vapor spac e remains below a specified level, then the overall efficiency will also depend on the vapor pressure of the stored material. Specifically, the efficiency will increase as vapor pressure increases. For this analysis, we assumed the model storage vessels ar e degassed to a concentration below 5,000 ppmv and that the floor and walls are dry. With these assumptions, the overall control efficiencies range from 92 percent for benzene to more than 94 percent for vinylidene chloride; the control efficiency for gaso line is 94

percent.Technical Memorandum

– Technology Review for Storage Vessels January 20, 2012



### 17 8. Control Costs

Cost of Fixed Roof Control Options

The unit costs and factors used to estimate costs for a typical internal floating roof retrofit (Control Option ST1), improved deck fittings (Control Option ST2), and slotted ladder leg controls (Control Option ST3) are presented in Table 12. Note that Control Option ST4 is based on monitoring procedures, and the costs are presented in section 10 of this memorandum.

Cost of EFR Control Options

The unit costs and factors used to estim ate costs for secondary rim seals (Control Option ST5), improved fittings control (Control Option ST6), and geodesic domes (Control Option ST7) are presented in Table 13. For Control Option ST6, costs were estimated for only those deck fittings

that are a ssumed not to be controlled to typical regulatory levels at baseline.Technical Memorandum

– Technology Review for Storage Vessels January 20, 2012



### 18 Table 12. Capital and annual cost factors for fixed roof and IFR control options

Costing element Unit cost or costing factor Basis 1

Control Option ST1 (add IFR with single rim seal an d typical deck fittings)

Capital costs

Internal floating roof E = see footnote 2 Fit a c urve to quoted installed costs from three

vendors and then multiplied by the fraction for equipment from one vendor (Dia is in ft)

Mobilization MO = $2,000 Assumed Taxes and freight TF = 0.08 x E EPA Control Cost Manual (U.S. EPA, 2002)

Installation I = see footnote 3 Similar to basis for E Total capital investment TCI = E + MO + TF + I

Annual costs

Capital recovery CR = 0.1098 x TCI Capital recovery factor calculated using equation in OAQPS Control Cost Manual (U.S. EPA, 2002); assumed IFR life of 15 years and

used 7% interest rate

Maintenance MA = 0.05 x TCI From other EPA analyses (U.S. EPA, 1994) Property taxes, insurance,

administration P = 0.04 x TCI EPA Control Cost Manual (U.S. EPA, 2002)

Product recovery credit R = $900/ton for chemicals R = $500/ton for petroleum products Average of typical chemical costs as noted in EL NSPS review memo (Parrish and Randall, 2007)

Total annual cost TAC = CR + MA + P + R Control Option ST2 (upgrade deck fittings)

Capital costs

Bolted, gasketed cover

for access hatches $400/hatch Approximated value based on several quotes for covers on wells for various fittings Bolted, gasketed cover for automatic gauge

floa t wells $400/well Approximated value based on several quotes for covers on wells for various fittings

Column well cover $550/column From vendor quotes

. Ladder cover (gasketed) $400/ladder From vendor quote

Gasketed cover and pole wiper for unslotted

g uidepole $950/guidepole Approximated cover cost based on costs for

column well covers ($550) . No data for pole wipers; assumed no more than $400, a quoted cost for a gauge pole sleeve.

Annual costs Same factors as for Control Option

ST1 Control Option S T3 (slotted ladder leg controls)

Capital costs for slotted ladder leg gasketed deck cover, ladder sleeve, and pole wiper $1,250/ladder Sum of quoted cost s for gasketed cover ($400),

and ladder sleeve ($450), and assumed pole wiper cost ($400) . Equipment c osts (E) assumed to be 50 percent of total.

. Taxes and freight TF = 0.08 x E EPA Control Cost Manual (U.S. EPA, 2002)

Annual costs Same factors as for Control Option

ST1

1 Vendor quotes are maintained in the OAQPS CBI files. Some of the cited costs are averages of two or three quotes; others are based on a single quote. Details are provided in the CBI files (Randall, 2012 a ).

2 E = (29.207 x Dia^0.1796)/100 x (6.3825 x Dia^2 + 374.27 x Dia + 19017).

3 I = (1

– (29.207 x Dia^0.1796)/100 x (6.382 5 x Dia^2 + 374.27 x Dia + 19017 )Technical Memorandum

– Technology Review for Storage Vessels January 20, 2012



### 19 Table 13. Capital and annual cost factors for EFR control options

Costing element Unit cost or costing factor Basis 1
Control Option ST5 (add second rim seal)

Capital costs

Secondary rim seal

materials S = (Circumference) x (383 .47 x (Dia.)^

- 0.262)/2 Curve fit to quoted installed costs; assumed material costs are

50 percent of the total installed

cost . Circumference and Dia are expressed in feet.

Mobilization M = $2,000 Assumed Taxes and freight TF = 0.08 x S EPA Control Cost M anual (U.S. EPA, 2002)

Installation I = S Assumed installation costs are 50 percent of the total installed cost Total capital investment TCI = S + M + TF + I

Annual costs

Capital recovery CR = 0.1098 x TCI Capital recovery calculated using equation in EPA Control Cost Manual (U.S. EPA, 2002); assumed seal life of 15 years and

used 7% interest rate Property taxes, insurance, administration P = 0.04 x TCI EPA Control Cost Manual (U.S. EPA, 2002) Product recovery credit R = $900/ton for chemicals

R = $500/ton for petroleum products Average of typical chemical costs

as noted in EL NSPS review memo (Parrish and Randall, 2007)

Total annual cost TAC = CR + P + R Control Option ST6 (upgrade deck fittings)

Capital costs

Bolted, gasketed cover

for auto matic gauge float

wells $400/well Approximated value based on several quotes for covers on wells for various fittings

Flexible fabric enclosure for slotted guidepole $150/ft of tank height From vendor quotes

Annual costs Same factors as for Control Optio n ST5 Control Option ST7 (add geodesic dome)

Capital costs 13.85 x Dia^2 + 125.62 x Dia + 21572 Curve fit through quotes from 3 vendors as reported in 2001 SCAQMD staff report (SCAQMD, 2001 ; Randall,

2012b ) . Dia is expressed in feet.

Annual costs Same factors as for Control Option ST5

1 The original vendor quotes are maintained in the OAQPS CBI files; procedures used to develop the cited costs in

this table are also maintained in the CBI files (Randall, 2012 a ).Technical Memorandum

– Technology Review for Storage Vessels January 20, 2012



### 20 Cost of Control for Degassing

We conside red two sources of cost information. The SCAQMD determined that degassing companies typically charged between $2,000 and $20,000 to degas storage vessels ($7,000 to $10,000 to degas an average sized storage vessel) when SCAQMD rule 1149 required control fo r at least 2.3 air exchanges (SCAQMD, 2008). ( This cost consisted of a $2,000 flat fee and the remainder as an hourly charge. They also determined that on average, degassing a typical tank for 2.3 air exchanges takes about 8.5 hours. Thus, the hourly rate was estimated to be about $940 (2,000 + 8.5 x 940 = 10,000). For proposed amendments that would require degassing until the organic concentration in the vapor space is less than 5,000 ppmv, SCAQMD estimated the average degassing time would increase to 24 h ours, and the cost would increase to about $24,000. Both of these costs, however, are significantly higher than the unit cost of about $1.5/lb of VOC destroyed presented in literature from E nvent , a company that conducts degassing using

four models of mobi le thermal oxidation units that are capable of controlling between 160 lb VOC/hr and 360 lb VOC/hr (E nvent ). Multiplying this unit cost by the reported VOC destruction capacity and hours to reach less than 20 percent of the LEL (i.e., about 7,000 ppmv for gasoline) for 3.36 million gallon gasoline storage vessel resulted in a total cost of about $3,700. See

attachment A for details of the information available from E nvent

. )

For this analysis we decided to use the cost information from E nvent because it cou ld be customized for different storage vessels. Furthermore, it is apparently an achievable cost for one type of degassing control technology, whereas the information in the SCAQMD analysis is reportedly an average cost for an unknown mix of technologies, some of which may be more costly than others. To use the E nvent costs, we also assumed that the fees would be structured as reported by SCAQMD (i.e., a flat fee plus an hourly charge). Because the overall SCAQMD costs were significantly higher, we assumed both the flat fee and the hourly rate should be lower

for the E nvent costs, but we reasoned that the flat fee obtained by SCAQMD is likely more accurate than the hourly charge. Therefore, we selected a flat fee of $1,600 (20 percent lower than SCAQMD) and an hourly charge of $250/hr (more than 70 percent lower than SCAQMD). As an example, w hen applied to the second largest of the four E nvent degassing control systems, this structure resulted in a total cost of about $3,900 for the 3.36 million gallon gasoli ne storage vessel, which is only about 5 percent higher than total cost that we derived using the data

available from E nvent

. To estimate costs for the model storage vessels with the characteristics presented in Table 7 and the uncontrolled degassing emiss ions presented in Table 11, we first estimated the time to degas the applicable volume (i.e., the volume under a floating roof or the total volume of a fixed roof storage vessel) to an organic compound vapor concentration less than 5,000 ppmv. We assumed

t he thermal oxidation units could handle the same total heat load regardless of the organic compound in the degassing exhaust stream. Thus, the estimated time to degas a storage vessel increases with increases in the lower heating value of the material stor ed in the storage vessel. The resulting estimates of degassing time and cost are presented in Table 14.Technical Memorandum

– Technology Review for Storage Vessels January 20, 2012



### 21 Table 14. Degassing time and cost for model storage vessels

Stored

material Small model (cost

effectiveness =

$10,000/ton) Medium model (cost

effective ness = $5,000/ton) Large model (cost effectiveness = $2,500/ton) Degassing time (hr) Degassing cost ($) Degassing time (hr) Degassing cost ($) Degassing time (hr) Degassing cost ($)

Crude oil 1.4 2,000 3.7 2,5 00 17 5, 900

Gasoline 1.4 2,000 3.8 2,5 00 19 6,2 00 Vinylidene

chloride 0.3 1, 700 0.7 1, 800 1.5 2,000

n

- Pentane 1.6 2,000 4.0 2,600 23 7,2 00 Methylene

chloride 0.2 1,6 00 0.3 1, 700 0.7 1, 800

Diethylamine 1.2 1,9 00 3.1 2, 400 12 4, 700 Chloroprene 0.2 1,6 00 0.4 1,700 0.9 1,8 00

Chloroform 0.1 1,6 00 0.2 1,6 00 0.4 1,700

n

- Hexane 1.5 2,000 4.0 2,600 21 6, 800
1,1,1

- Trichlorethane 0.3 1, 700 0.5 1,7 00 1.2 1, 900

Methanol 0.6 1, 800 1.4 1,9 00 3.4 2, 500

Benzene 1.3 1,9 00 3.3 2,4 00 13 4,9 00



### 9. Impact Estimates for Storage Vessels

Fixed roof

Figures 1 and 2 are plots of the cost effectiveness versus vapor pressure of Control Options ST1 and ST2 for model fixed roof storage vessels. The equations on the graphs can be used to calculate costs for the trendlines through the data for each model storage vessel. E ach trendline is based on a power function. Note that all of the points that are well above the applicable trendlines are for compounds with low molecular weights (i.e., methanol, ethanol, formic acid, acetonitrile, and acrylonitrile). Points well below th e trendlines are for compounds with high molecular weights. The cost effectiveness for Control Option ST2 varies only with the vapor pressure of the stored material, not the size of the storage vessel; the slightly different values (and trendlines) in Figu re 2 are due to slight differences in rounding of the emissions estimates in the product recovery credit calculations. See attachment B for tabular summaries of the capital cost, annual cost, emission reduction, and cost effectiveness for each model and co ntrol option.Technical Memorandum

– Technology Review for Storage Vessels January 20, 2012



### 22 Figure 1. Plot of cost effectiveness versus vapor pressure of Control Option ST1 for Models A, B, and CTechnical Memorandum

– Technology Review for Storage Vessels January 20, 2012



### 23 Figure 2. Plot of cost effectiveness versus vapor pressure of Control Option ST2 for Models A, B, and CTechnical Memorandum

– Technology Review for Storage Vessels January 20, 2012



### 24 Table 15 presents the res ults of the impacts analysis for Control Option ST3 (slotted ladder leg controls) (the results are the same for each model storage vessel because the costs are a function of the number of ladders, which is one for each of the models). The capital costs for the deck cover gasket, ladder sleeve, and pole wiper are the same for all storage vessels regardless of the storage volume. Annual costs also are the same for all storage vessels, but the product recovery credit varies because the mass of emissions preven ted varies depending on the characteristics (vapor pressure and molecular weight) of the stored material. As a result, the cost effectiveness impacts are the same for any size of storage vessel and vary with the vapor pressure of the stored

material. The r esults in Table 15 also show the cost effectiveness to be similar to the cost effectiveness values for Control Option ST1.

Table 15. Impacts of Control Option ST3

Stored

material Vapor
pressure at
25°C Total capital investment ($) Total annual cost ($/yr) Emission

reduction

(lb/yr) Cost

effectiveness ($/ton) Xylene 0.13 1,300 260 8.3 62,000

Toluene 0.55 1,300 240 35 14,000 Methyl methacrylate 0.70 1,300 240 50 9,500

Formic acid 0.83 1,300 250 28 17,000

Isooctane 0.95 1,300 220 8 2 5,400 Methyl ethyl

k etone 1.7 1,300 210 10 0 4,100

Benzene 1.8 1,300 210 12 0 3,400

Methanol 2.4 1,300 230 6 7 6,900

Hexane 2.9 1,300 150 2 40 1,300

Chloroform 3. 8 1,300 56 45 0 250



### EFR

Figures 3 through 5 are plots of the cost effectiveness versus vapor pressure of Control Options ST5, ST6, and ST7 for model EFR storage vessels (for Models A, B, and C, which are smaller storage tanks at chemical manufacturing facilities) . Figure 3 shows the costs are a stronger function of the vapor pressure of the stored material than the s ize of the storage vessel. Trendlines and the corresponding equations based on power functions are also shown on Figure 3. Figure 4 shows Control Option ST6 results in cost savings for nearly all storage vessels except those that store material with a vap or pressure less than about 0.4 psia. Figure 5 shows the costs of Control Option ST7 are much higher than the costs of any of the other control options.

See attachment C for tabular summaries of the capital cost, annual cost, emission reduction, and

cost e ffectiveness for each model and control option. Tables 16 through 18 show that the impacts for larger model storage tanks storing petroleum products (Models D through I) are in line with the results in Figures 3 through 5 for smaller storage vessels.Technical Memorandum

– Technology Review for Storage Vessels January 20, 2012



### 25 F igure 3. Plot of cost effectiveness versus vapor pressure of Control Option ST5 for Models A, B, and CTechnical Memorandum

– Technology Review for Storage Vessels January 20, 2012



### 26 Figure 4. Plot of cost effectiveness versus vapor pressure of Control Option ST6 for Models A, B, and CTechnical Memorandum

– Technology Review for Storage Vessels January 20, 2012



### 27 Figure 5. Plot of cost effectiveness vers us vapor pressure of Control Option ST7 for Models A, B, and CTechnical Memorandum

– Technology Review for Storage Vessels January 20, 2012



### 28 Table 16. Impacts of Control Option ST5 ( add secondary rim seal) for large storage vessels with EFR that contain petroleum products

Model Stored material Total capital investment ($) Total annual cost ($/yr) Emission

reduction

(lb/yr) Cost

effectiveness ($/ton)

D Crude oil 4 5

, 0 00 5,7 0 0 4,0 00 2,8 00

E Crude oil 68,000 8, 400 7, 300 2,3 00

F Gasoline 30,000 1,4 0 0 12, 0 00 240

G Gasoline 68,000 460 3 9

, 0 00 23

H Jet naphtha 3 7

, 0 00 4,2 00 5,000 1,70 0

I Jet naphtha 57, 0 00 6,2 00 9,4 00 1,3 00



### Table 17. Impacts of Control Option ST6 ( upgrade fittings) for large storage vessels with EFR and slotted guidepole that contain petroleum products

Model Total capital

investment ($) Total

annual cost ($/yr) Emis sion reduction (lb/yr) Cost effectiveness ($/ton)

Versus

baseline Versus

Control Option ST5 Versus

baseline Versus

Control Option ST5

D 51,0 00 5, 70 0 8,0 0 0 4,00 0 1,4 0 0 (1 8 )

E 74,0 00 8,3 0 0 11, 0 00 4

, 00 0 1, 50 0 (18)

F 36, 0 00 ( 2,9 0 0 ) 33, 0 00 21,0 00 ( 1 80 ) ( 410 )

G 74,0 00 ( 3,9 0 0 ) 60, 0 00 21, 0 00 ( 130 ) ( 410 )

H 43, 0 00 3, 60 0 1 2

, 0 00 6,5 0 0 (6 20 ) ( 2 1 0 )

I 6 4

, 0 00 5, 60 0 16,000 6,5 0 0 ( 700 ) (2 10 )



### Table 18. Impacts of Control Option ST7 ( add geodesic dome) for large storage vessels with EFR and slotted guidepole that c ontain petroleum products

Model Total capital investment ($) Total annual cost ($/yr) Emission reduction (lb/yr) Cost effectiveness ($/ton)

Versus

baseline Versus

Control Option

ST 6 Versus

baseline Versus

Control Option ST6

D 29 0 ,000 4 1

, 0 00 8,700 67 0 9, 4 0 0 1 0 0 ,000

E 7 6 0 ,000 1 10 ,000 12, 0 00 1,2 0 0 1 8

, 0 00 170,000

F 130,000 1 0

, 0 00 3 6

, 0 00 2, 30 0 5 8 0 1 2

, 0 00

G 7 6 0 ,000 9 8

, 0 00 6 7

, 0 00 6,3 0 0 2, 9 0 0 3 2

, 0 00

H 19 0 ,000 2 5

, 0 00 12, 0 00 87 0 4, 0 0 0 49

, 0 00

I 51 0 ,000 7 2

, 0 00 1 8

, 0 00 1,5 0 0 8, 2 0 0 8 6 ,000Technical Memorandum

– Technology Review for Storage Vessels January 20, 2012



### 29 Degassing

Figure 6 p resents the storage vessel size and vapor pressure relationships for two cost effectiveness curves ($2,500/ton and $5,000/ton). Curves for higher cost effectiveness values (e.g., $10,000/ton) would be lower on the graph. Curves for lower cost effectiveness values (e.g., $1,500/ton) would be higher on the graph, if they are feasible at all; most materials reach a point of diminishing returns where increasing size of the storage vessel results in essentially equivalent percentage increases in both the cost of degassing and the additional emission reduction. Both of the curves in Figure 6 show the cost impacts of degassing control are much higher than for Control Options ST1, ST2, ST3, ST5, and ST6. Stated another way, for the same cost effectiveness value, the storage vessel size must be significantly large under Control Option ST8 than under the other control options. For example, the $2,500/ton curve shows IFR and EFR storage vessels would have to be over 2,000,000 gal if the vapor pressure is less than 5 psi a. Similarly, the $5,000/ton curve shows IFR and EFR storage vessels would have to be larger than 1,000,000 gal if the vapor pressure is less than 3 psia.

Figure 6. Cost effectiveness curves for degassing controls (Control Option ST8)Technical Memorandum

– Technology Review for Storage Vessels January 20, 2012



### 30 Nationwide Impacts for SOCMI Facilities and Petroleum Refineries

For most chemical manufacturing facilities, the costs to comply with the combined requirements of Control Options ST1, ST2, ST5 and ST6 for atmospheric storage vessels above the proposed thresholds are expecte d to be zero or minimal because they are already subject to current rules that have the same or similar thresholds and control requirements. However, many storage vessels at petroleum refineries are subject to 40 CFR part 63, subpart CC, which does not req uire control of deck fittings (i .e., Control Options ST2 and ST6 ). Based on information provided by petroleum refiners in response to an information request, we determined that nation wide there are approximately 2,4 00 storage vessels with an EFR and 1,400 storage vessels with an IFR that

meet or exceed the thresholds for control in current rules (e.g., the HON), and about 60 percent of these storage vessels have slotted guidepoles ( U.S. EPA, 2011)

. About 50 percent of the I FR storage vessels that have slott ed guidepoles are controlled, and about two

- thirds of the E FR storage vessels that have slotted guidepoles are controlled . We assumed all of the other fittings have typical controls (i.e., consistent with Control Options ST1 and ST5 ). We also assumed each EFR is equipped with two rim seals, as required in 40 CFR part 63, subpa rt CC, and in Control Option ST5 . To estimate current annual emissions, we first represented each storage vessel with one of four model sizes. Each model storage vessel also was assign ed one of four model liquids depending on the reported vapor pressure of the actual stored liquid. Storage vessels containing liquids with the lowest vapor pressures were represented with methyl ethyl ketone. The other storage vessels were organized into t hree groups, each of which was represented with a different grade of gasoline (RVP6, RVP10 and RVP14)

.

We e stimated the current and controlled emissions for each model refinery storage vessel using

the AP

- 42 procedures and other assumptions as described in section 7 of this memorandum . We estimated costs to upgrade fittings for each storage vessel using the same information described

in section 8 of this memorandum . We also applied a product recovery credit of $500/ton of VOC to the prevented petroleum prod uct emissions. The emission reductions associated with upgrading the deck fittings on EFR storage vessels, particularly slotted guidepoles, resulted in a product recovery credit that exceeded the estimate of all costs associated with Control Options

ST2 an d ST 6 . Thus, the nationwide impacts of the control options for petroleum refineries is a cost savings of about $350/ton of VOC controlled. Table 19 summarizes the nationwide number of storage vessels, capital and annual costs, emission reductions and cost effectiveness. Attachment D provides details of the model storage vessels used to represent each of the storage

vessels nationwide.

Table 19. Nationwide impacts of Control Options ST2 and ST6 for petroleum refineries

Type

of
storage
vessel Nationwide

numb er of

storage
vessels Nationwide

VOC

emission

reduction

(tpy) Nationwide total capital

investment ($) Nationwide

total annual costs (without VOC recovery credit) ($/yr) Nationwide

VOC

recovery

credit ($/yr) Nationwide

total annual

cost with

VOC

recovery

cr edit ($/yr) Cost

effectiveness ($/ton VOC controlled)

IFR 1357 874 7,070,000 1,060,000 (437,000) 622,000 710

EFR 2362 10,500 4,540,000 680,000 (5,250,000) (4,570,000) (440)

Total 3719 11,400 11,600,000 1,740,000 (5,690,000) (3,950,000) (350)Technical Memorandum

– Technology Review for Storage Vessels January 20, 2012



### 31 10. Monit oring, Recordkeeping, and Reporting

Monitoring Fittings on Fixed Roofs

We assumed a typical fixed roof has one access hatch, one gauge hatch, one conservation vent, one emergency pressure relief vent, and four miscellaneous valves and instruments. As discu ssed in section 5 of this memorandum, Control Option ST4 is based on periodic monitoring of these fittings for leaks. In this analysis we examined three types of monitoring approaches. Control Option ST4a is based on visual monitoring, Control Option ST4b is based on monitoring using Method 21, and Control Option ST4c is based on monitoring using optical gas imaging.

Emissions for baseline and visual inspections were assumed to be the same (i.e., we do not have

sufficient data to estimate reductions that a re achieved when annual visual inspections are conducted). The baseline emissions for access hatches and gauge hatches were estimated using

AP

- 42 procedures for estimating emissions from such fittings on EFRs. We assumed the access hatch has an unbolted ga sketed cover, and that the gauge hatch has a weighted mechanical actuation and is gasketed. We estimated the baseline emissions for the conservation vent, emergency pressure relief vent, and other valves/instruments using the average emission factors

for o pen ended lines, pressure relief vents, and valves, respectively, in the synthetic organic chemical manufacturing industry from EPA’s Protocol for Equipment Leak Emission Estimates ( U.S. EPA, 1995b). (Note that this methodology may underestimate baseline e missions for storage vessels storing petroleum products if the average emission factors for equipment in petroleum refineries provide a more realistic estimate of emissions for such storage vessels.) Based on the experience of EPA inspectors, we assumed th at monitoring with Method 21 would find an average of one leaking fitting per storage vessel (instrument reading greater than 500 ppmv); thus, 12.5 percent of fittings are assumed to be leaking currently. We assumed 5 percent of the fittings would be found leaking during annual monitoring with Method 21, resulting in an average 80 percent reduction in emissions. In an LDAR program for equipment leaks, optical gas imaging is assumed to achieve comparable performance to Method 21, provided the optical gas

ima ging is conducted more frequently than Method 21 monitoring. For this analysis, we assumed that optical gas imaging conducted semiannually would result in performance comparable to that for annual Method 21 monitoring. Table 20 presents the estimated uncon trolled/baseline emissions and the controlled emissions when annual monitoring is conducted using Method 21 and semiannual monitoring is conducted using optical gas imaging.

The estimated level of effort and cost of monitoring, repair, recordkeeping, and r eporting for three monitoring approaches are presented in Table 2 1 . The average time to conduct either type of instrument monitoring was assumed to be greater than for visual monitoring because of the instrument setup, calibration, and operating requiremen ts. We also assumed the average monitoring time increases slightly with increases in the size of the facility to account for potentially greater travel distances to the storage vessels and a greater percentage of large storage vessels at large facilities ( which take longer to climb and to access all fittings). Initial monitoring costs are lower for optical gas imaging than for monitoring using Method 21 because the initial monitoring with Method 21 finds more leaks that must be repaired. As in analyses for leak detection and repair programs for equipment leaks, repair costs for fittings were estimated assuming 75 percent of the leaks can be repaired by making a simple adjustment that takes an average of about 15 minutes per fitting, and 25 percent require a more extensive offline repair or replacement. Offline repairs for gauge hatches, emergency pressure relief vents, andTechnical Memorandum

– Technology Review for Storage Vessels January 20, 2012



### 32 miscellaneous valves and instruments were assumed to take an average of 4 hours. We assumed leaking access hatches and conservation vents would be replaced at costs of $400 and $651, respectively ( Ellsworth, 2011a and 2011b ) . Reporting costs were estimated assuming 0.5 hr to assemble relevant records of a leaking fitting in an annual periodic report and that 5 percent of fittings leak each y ear. As a result, on average, each storage vessel has a reportable leak once every 2.5 years (or 0.4 reports per year). Labor rates for repair, inspection/monitoring, and recordkeeping/reporting are shown in Table 2 2 . These rates are based on U.S. Departme nt of Labor, Bureau of Labor Statistics labor rates (U.S. DOL, 2010). A fringe benefit loading rate of 1.5 and an overhead and profit rate of 1.4 were multiplied by each hourly rate to obtain loaded rates. Recordkeeping and reporting labor rates are based on 0.5 hr of managerial time and 1 hr of administrative support per hr of environmental engineering time; thus, the weighted average labor rate per hour of engineering time is $92.72/hr.

Table 2 3 presents the total annual cost, emission reduction, and cost effectiveness of the various monitoring options. The costs in Table 2 3 are for a large facility. Monitoring costs for medium and small facilities would be slightly less, as noted in Table 2 1 , but the estimated emissions are an average across all storage v essels. Therefore, the estimated cost effectiveness values would be higher for medium and small facilities.

Table 20 . Estimated emissions from fittings on fixed roof storage vessels

Type of fitting Number of fittings per

storage
vessel Initial leak

rate (k g/hr/fitting) Total annual

baseline

emissions

(lb/yr) Annual

emissions

when conducting

annual

Method 21 monitoring (lb/yr) Annual

emissions

when conducting

semiannual optical gas

imaging

(lb/yr)

Access hatch 1 NA 29 0 58 58 Gauge hatch 1 NA 2 .1 0.4 2 0.4 2

Conservation vent 1 0.0017 0 33 6.6 6.6 Emergency pressure relief vent 1 0.104 2,0 00 40 0 40 0

Valves/instruments 4 0.00597 46 0 93 93

Total 2,8 00 56 0 56 0Technical Memorandum

– Technology Review for Storage Vessels January 20, 2012



### 33 Table 2 1 . Monitoring, repair, recordkeeping, and reporting burden and costs of different monito ring approaches for fittings on fixed roof storage vessels

Type of monitoring MRR labor effort (hr/yr) MRR costs

Monitoring Repair Recordkeeping Reporting Total Initial

and capital costs ($) Annualized

initial and

capital costs ($/yr) Repair

costs ($/yr) Annual monitoring costs ($/yr) Annual recordkeeping and reporting costs ($/yr) Total

annual

costs ($/yr)

Visual 0.5 NA 1 0.025 1.5 0 0 NA 24 95 120

Method 21

Small facility 0.67 0.38 0.5 0.2 1.7 1 70 24 31 32 6 5 15 0 Med facility 0.83 0.38 0.5 0.2 1.9 1 80 25 31 40 6 5 160 Large facility 1.0 0.38 0.5 0.2 2. 1 18 0 26 31 48 6 5 1 70

OGI

Small facility 0.67 0.38 0.5 0.2 2.9 130 19 31 64 11 0 22 0 Med facility 0.83 0.38 0.5 0.2 3.2 1 40 20 31 79 11 0 2 4 0 Large facility 1. 0 0.38 0.5 0.2 3.6 1 50 21 31 95 11 0 2 60Technical Memorandum

– Technology Review for Storage Vessels January 20, 2012



### 34 Table 2 2 . Labor rates for monitoring, repair, recordkeeping, and reporting

(A)
Mean hourly

labor rate 1

($/hr) (B)
Fringe

benefit
loading rate 2 (C)

Overhead
and profit

rate 2 (D=AxBxC)
Loaded wage

rate ($/hr)

Pr ofessional Specialty and
Technical (SOC Code: 17

- 2081) 39.53 1.5 1.4 83.01

Executive, Administrative and
Managerial (SOC Code: 11

- 9041) 57.80 1.5 1.4 121.38

Administrative Support, Including
Clerical (SOC Code: 43

- 0000) 17.31 1.5 1.4 36.35

Installation, Maintenance, and
Repair (SOC Code: 49

- 0000) 22.08 1.5 1.4 47.71

Plant and System Operators, All
(SOC Code: 51

- 8099) 22.72 1.5 1.4 46.37

1 Labor rates as reported by U.S. Department of Labor, Bureau of Labor Statistics for May 2009 (U.S. DOL, 2010).

2 Fac tors estimated to give overall loading of 110 percent as in supporting statements (OMB, 2011).



### Table 2 3 . Cost effectiveness of different monitoring techniques for fittings on fixed roof storage vessels

Control Option Total

annual cost ($/yr) Emission

redu ction

versus baseline (tpy) Cost

effectiveness

versus baseline ($/ton) Incremental

cost
effectiveness ($/ton) ST4a (Visual monitoring) 1 20 NA NA

-- ST4b (Method 21 monitoring) 1 70 1.1 150 NA ST4c (Optical gas imaging) 2 60 1.1 230 Undefined

Monitoring Equipment in Closed Vent Systems and Monitoring Control Device Operating

Parameters

We estimated that, on average, a closed vent system conveying emissions from a storage vessel has six connectors, three valves, and one open

- ended line. We estimated labor burden and costs to monitor the equipment visually, using Method 21, or using optical gas imaging. We assumed no reporting cost because we assumed that reporting would be required only if a facility does not repair leaking fittings and that all facilities would comply with such requirements. Table 2 4 summarizes the burden and cost of each monitoring approach.

We assumed that the typical control device will be a thermal oxidizer. The memorandum “Development of Monitoring Costs for the Proposed Part 65 Unifor m Standards for Control

Devices

— Subpart M” estimates that the total annual cost to monitor temperature, keep records, and report continuous data is $8,400/yr, and the total initial cost, including costs for planning and the costs to purchase and install th e monitor, is $9,900 (Gibson et. al., 201 2 ). We assumed theTechnical Memorandum

– Technology Review for Storage Vessels January 20, 2012



### 35 control device is dedicated to storage tank emission control and included the full cost of monitoring the control device in this analysis.Technical Memorandum

– Technology Review for Storage Vessels January 20, 2012



### 36 Table 2 4 . Burden and cost to inspect or monitor equipmen t in a closed vent system

Type of monitoring Initial

setup cost ($) 1 Annualized

initial cost

($/yr) 2 Frequency of inspection or

monitoring Inspection labor (hr/yr) Inspection or monitoring cost ($/yr) 3 Recordkeeping labor (hr/yr) Recordkeeping cost ($/yr) 4 Total

annual cost ($/yr)

Visual 0 0 1 0.5 24 0.25 23 47

Method 21 2 40 34 footnote 5 N/A 6 14 0.25 23 71

OGI 2 40 34 6 0.25 7 2 0.25 23 1 3 0

1 Based on $23.80 per piece of equipment, as in the analyses for equipment leaks (Hancy, 2011).

2 Capital recovery fa ctor of 0.1098 calculated using standard OAQPS procedures assuming the closed vent system life is 15 years and using an inter est rate of 7

percent (U.S. EPA, 2002)

. 3 For Method 21, based on contractor fees of $2.50/connector and $1.50/valve and OEL (Hancy, 2011). For OGI, we assumed 15 minutes to conduct monitoring of the entire closed vent system. No rules currently specify monitoring frequency for optical gas imaging of storage vessels; therefore, the OGI monitoring frequency was based on maximum allowed monitoring interval in the Alternative Work Practice for equipment leaks (i.e., bimonthly) (40 CFR 63.11(c)). Labor rate for visual inspections and OGI assumed to be $47.71/hr, based on data in Table 2 2

. 4 Labor rate assumed to be $92.72/hr , based on data i n Table 2 2

. 5 Assumed monitoring consistent with the frequency in the analysis for the equipment leaks Uniform Standards (i.e., once every 4 years for connectors, 2 times per year for valves, and 1 time per year for OEL) (Hancy, 2011).

6 Assumed monitoring i s conducted by a contractor.Technical Memorandum

– Technology Review for Storage Vessels January 20, 2012



### 37 Monitoring Rim Seals and Deck Fittings on IFRs and EFRs

Current rules typically require periodic visual inspections of floating roofs, and seal gaps must be measured for storage vessels that are equipped with EFRs. In this ana lysis we estimated the burden and cost to conduct such monitoring for a series of model storage vessels. We also estimated the burden and cost of alternative monitoring based on the use of either optical gas imaging or EPA Method 21. The results for all th ree monitoring approaches are presented in

Table 2 5 . Assumptions used in the analysis are documented in footnotes to Table 2 5

.

Monitoring for Floating Roof Landings and Overfill

Table 26 presents an estimate of the capital and annual costs to monitor and p rovide warning of potential floating roof landings in storage vessels that are equipped with a floating roof, and Table 27 presents an estimate of the capital and annual costs to monitor and provide warning of potential overfill in any atmospheric storage vessel. Both types of monitoring are based on monitoring the liquid level in the storage vessel. Levels below a low set point provide warning of a potential floating roof landing, and levels above a high set point provide warning of potential

overfill.

We obtained purchased equipment costs from three vendors for liquid level monitoring systems

that can monitor both high and low level s. Some of the vendors requested that their quotes be maintained as confidential. Therefore, only the average purchased equipm ent cost is presented in this memorandum. The original quotes are maintained in the OAQPS CBI files (Randall, 2012 a ). Other assumptions used in the analysis are documented in footnotes to the Tables.

Monitoring Pressure Vessels

We assumed that pressure ves sels have the same number of fittings as on a fixed roof. Therefore, the monitoring, recordkeeping, and reporting burden and cost estimates in Table 2 1 also apply to monitoring for pressure vessels.Technical Memorandum

– Technology Review for Storage Vessels January 20, 2012



### 38 Table 2 5 . Burden and cost estimates of monitoring opti ons for storage vessels with EFR or IFR

Model

ID Storage vessel capacity (gal) EFR IFR Total labor (hr/yr) Total annual cost ($/yr) 1 Total labor (hr/yr) Total annual cost ($/yr) 1

Visual 2 OGI 3 Method

21 4 Visual OGI Method

21 Visual 5 OGI 6 Method

21 7 Vi sual OGI Method

21

Small 30,000 (SOCMI) 5.4 3.2 3.2 3 50 24 0 24 0 2.6 3.2 N/A 21 0 24 0 N/A

Medium 100,000 (SOCMI) 450,000 (refinery) 6.5 3.3 3.3 40 0 2 50 2 50 2.7 3.3 N/A 2 20 2 50 N/A

Large 2,000,000 (SOCMI) 3,300,000 (refinery) 7.1 3.3 3.3 4 30 2 50 2 50 2.7 3. 3 N/A 2 20 2 50 N/A

Very large 8,000,000 (refinery) 22,000,000 (refinery) 7.2 3.4 3.4 43 0 25 0 25 0 2.7 3.4 N/A 2 20 25 0 N/A

1 Labor rates were $47.71/hr for inspections and gap measurements, and $92.72/hr for recordkeeping and reporting, based on data in Tabl e 2 2

. 2 Activities include annual visual inspection, annual measurement of deck fitting gasket gaps, annual measurement of secondary seal gaps, measurement of primary seal gaps every 5 years, recordkeeping related to each inspection, and reporting of each i nspection failure. We assumed 0.5 hr to conduct visual inspections, regardless of the storage vessel capacity. We assumed the time to measure gaps between deck fitting gaskets and the surfaces they are intended to seal as 0.5 hr for a small storage vessel and 1 hr for medium, large, and very large storage vessels. The supporting statement for information collection request related to the Consolidated Federal Air Rule for the Synthetic Organic Chemical Manufacturing Industry (in the tabular summar y for NSPS subpart Ka) estimated an average of 5 hr to measure secondary seal gaps and 2 hr to measure primary seal gaps (OMB, 201 1 ). For this analysis, we assumed the 5 hr and 2 hr estimates in the ICR were transposed. We also assumed the time would be a little les s than average for small storage vessels and a little more than average for large storage vessels. Specifically, we assumed the time to measure primary seal gaps as 4.5 hr, 5 hr, 5.5 hr, and 6 hr for t he small, medium, large, and very large model storage v essels, respectively. For the secondary seal, we assumed the time to measure gaps as 1.5 hr for small storage vessels, 2 hr f or medium storage vessels, and 2.5 hr for both large and very large storage vessels. We assumed an average of 2 hr to document the results of each inspection, including calculations of seal gap areas. We assumed 0.5 hr to compile the applicable records of an inspection failure into a periodic report, and w e assumed one percent of storage vessels have an inspection failure each year.

3 Same activities as for visual inspection, except seal gap measurements and deck fitting gasket measurements are replaced with annual OGI monitoring of the rim seal and deck fittings. We assumed 0.67 hr, 0.75 hr, 0.83 hr, and 0.92 hr to conduct OGI monitori ng for small, medium, large, and very large storage vessels, respectively. The time was assumed to increase slightly for larger storage vessels to account for potentially more images on larger storage vessels and the time to

climb taller tanks and walk aro und or across larger diameter storage vessels.

4 Assumed the time to setup, calibrate, and conduct Method 21 monitoring is the same as for OGI monitoring. Thus, the estimate burden is also the same.

5 Same as for EFR, except no rim seal gap measurements, and the deck fitting gasket measurements are every 5 years instead of annually.

6 Same level of effort and monitoring frequency as for EFR.

7 Assumed that Method 21 monitoring would not be required inside an operating storage vessel due to safety concerns.Technical Memorandum

– Technology Review for Storage Vessels January 20, 2012



### 39 Tabl e 2 6 . Costs for floating roof landing sensor and alarm systems

Costing element Variable designations and equations Cost Capital and other initial costs ($) Planning 1 PL = 10 hr x $92.72/hr 9 30 Purchased equipment cost 2 PEC 8 50 Freight and sales tax 3 FST = 0.08 x PEC 68

Installation 4 I = 0.47 x (PEC + FST) 4 30

Total initial costs TIC = PL + PEC + FSR + I 2

, 28 0 Annual costs ($/yr)

Maintenance 5 M = 0.1 x (PEC + I) 130 Capital recovery 6 CR = 0.1 424 x TIC 3 20 Property tax, insurance, and admini stration 3 TIA = 0.04 x TIC 91 Recordkeeping 7 REC = 5 hr x $92.72/hr 46 0 Reporting 8 REP = 0.5 hr x $92.72/hr 46

Total annual cost TAC = M + CR + TIA + REC + REP 1,1 0 0

1 Assumed average of 10 hr of an engineer’s time to review rule, research options, a nd initiate purchasing process. Burdened labor rate includes 0.5 hr of management and 1 hr of administrative support per hour of engineering labor.

Refer to Table 2 2 for labor rates

2 Equipment cost based on average of prices for three systems that monitor both high and low levels. Therefore, half of the cost attributed to floating roof landing (i.e., low level) monitoring and half attributed to overfill monitoring as shown in Table 27 (Randall, 2012 a )

. 3 Factor is from EPA Air Pollution Control Cost Manual ( U.S. EPA, 2002).

4 Installation factor is from “Plant Design and Economics for Chemical Engineers” (Peters et. al., 2003).

5 Assumed annual maintenance cost is equal to 10 percent of the total initial cost. Also assumed half of the cost is for

labor and half is for materials. Thus, labor burden is $98/2/$47.71/hr = 1 hr/yr.

6 Capital recovery was calculated using procedures in EPA Air Pollution Control Cost Manual (U.S. EPA, 2002).

Assumed monitor life of 1 0 years, and used interest rate of 7 percent.

7 Assumed rule would specify conditions under which landings are allowed, that emissions would have to be calculated for each landing, and that records documenting the circumstances for each unallowed landing would be required. Assumed average of 2 landings per yea r, one of which is unallowed. Assumed 2 hr to calculate and document emissions from each landing, and 1 hr to document information about the unallowed landing. Estimated

burdened labor rate as described in footnote number 1.

8 Assumed 0.5 hr to compile reco rds of emissions calculations and unallowed landings in periodic reports. Estimated

burdened labor rate as described in footnote number 1.Technical Memorandum

– Technology Review for Storage Vessels January 20, 2012



### 40 Table 2 7 . Costs for overfill sensor and alarm systems

Costing element Variable designations and equations Cost (IFR /EFR) Cost (Fixed Roof) Capital and other initial costs ($) Planning 1 PL = 10 hr x $92.72/hr 930 930 Purchased equipment cost 2 PEC 850 1,70 0 Freight and sales tax 3 FST = 0.08 x PEC 68 140

Installation 4 I = 0.47 x (PEC +FST) 430 86 0

Total initial costs TIC = PL + PEC + FSR + I 2,280 3,6 00 Annual costs ($/yr)

Maintenance 5 M = 0.1 x (PEC + I) 130 26 0 Capital recovery 6 CR = 0.1424 x TIC 320 5 20 Property tax, insurance, and

administration 3 TIA = 0.04 x TIC 91 150

Recordkeeping 7 REC = 3 hr x ( 1/20) x $92.72/hr 14 14 Reporting 8 REP = 0.5 hr x (1/20) x $92.72/hr 2 2

Total annual cost TAC = M + CR + TIA + REC + REP 560 93 0

1 Assumed average of 10 hr of an engineer’s time to review rule, research options, and initiate purchasing process.

Burden ed labor rate includes 0.5 hr of management and 1 hr of administrative support per hour of engineering labor.

Refer to Table 2 2 for labor rates

2 Equipment cost based on average of prices for three systems that monitor both high and low levels. For storage vessels with an IFR or EFR half of the cost is attributed to floating roof landing (i.e., low level) monitoring as shown in Table 26 and half attributed to overfill monitoring. For storage vessels with a fixed roof, the entire cost of the system is assigne d to overfill monitoring (Randall, 2012 a ).

3 Factor is from EPA Air Pollution Control Cost Manual (U.S. EPA, 2002).

4 Installation factor is from “Plant Design and Economics for Chemical Engineers” (Peters et. al., 2003).

5 Assumed annual maintenance cost is equal to 10 percent of the total initial cost. Also assume d half of the cost is for labor and half is for materials. Thus, labor burden is $90/2/$47.71 = 0.94 hr/yr.

6 Capital recovery was calculated using procedures in EPA Air Pollution Control Cost Manual (U.S. EPA, 2002).

Assumed monitor life of 1 0 years, and used interest rate of 7 percent.

7 Assumed rule would require estimate of emissions from each overfill and documentation of the cause of the overfill and actions taken in response to the alarm. Also a ssumed 1 overfill every 20 years, and 3 hr to prepare the required

records. Estimated burdened labor rate as described in footnote number 1.

8 Assumed reporting required only in the event of an overfill (i.e., every 20 years in this analysis). Assumed 0.5 h r to compile records of emissions calculations and other information in periodic reports. Estimated burdened labor rate

as described in footnote number 1.Technical Memorandum

– Technology Review for Storage Vessels January 20, 2012



### 41 Impacts for Model SOCMI Facilities and Model Petroleum Refineries

We estimated the total cost and b urden for several chemical manufacturing facilities and petroleum refineries to comply with all of the monitoring, recordkeeping, and reporting activities

described in this memorandum. These costs and burden estimates were developed for four model

chemical manufacturing facilities and three model petroleum refineries. Tables 2 8 and 2 9 summarize the counts of different types of storage vessels at the model facilities.

The model chemical manufacturing facilities were informed by information provided in

respon se s to an information request for the MON and other available information. The model facilities represent a range of characteristics, but they are not intended to represent the full range of possible storage vessel characteristics throughout all sectors of the chemical manufacturing industry.

The number, type, and sizes of storage vessels at model petroleum refineries were developed based on data provided by petroleum refineries in response to a recent information collection request ( U.S. EPA, 2011 ). The r efineries in the database were sorted into three groups based on the total number of storage vessels equipped with EFRs and IFRs (and that meet or exceed size and vapor pressure thresholds for control in current rules). Small facilities had up to 20 such

s torage vessels, medium facilities had between 20 and 40 such vessels, and large facilities had between 40 and 100 such storage vessels. Small facilities had an average of approximately 5 EFRs and 5 IFRs, medium facilities had an average of approximately 18 EFRs and 12 IFRs, and large facilities had an average of approximately 40 EFRs and 20 IFRs. Storage vessels in the database that are equipped with EFR or IFR were sorted into four size categories: (1) small storage vessels have a capacity less than 1 mill ion gal and were represented with a model that has a capacity of 450,000 gal; (2) medium storage vessels have a capacity between 1 million gal and 5 million gal, and were represented with a model that has a capacity of 3.3 million gal; (3) large storage ve ssels have a capacity between 5 million gal and 17 million gal, and were represented with a model that has a capacity of 8 million gal; and (4) very large storage vessels have a capacity greater than 17 million gal, and were represented with a model that h as a capacity of 22 million gal. Nearly all of the very large storage vessels in the database had an EFR. The ratio of EFRs to IFRs was 5:1 for the large storage vessels, 2:1 for the medium storage vessels, and 0.5:1 for the small storage vessels. This inf ormation was used to estimate the number and distribution of IFRs and EFRs at each model facility; the ratios from the database were adjusted slightly so that the model counts are whole numbers and so that the total capacity

for the models is close to the total capacity of actual storage vessels in each size range. Counts of fixed roof storage vessels that vent to control and pressure vessels at the model facilities were based on average counts of these vessels at refineries in each of the three groups of f acilities described above. The average count of fixed roof storage vessels that vent to atmosphere was lower for the medium facilities in the database (i.e., those with between 20 and 40 EFRs and IFRs) than for small and large facilities; therefore, the av erage number of such storage vessels at all refineries in the database was used for each of the three model petroleum refineries.

Tables 30 and 3 1 present the monitoring, recordkeeping, and reporting costs for each type of monitoring activity at the model facilities. The monitoring for landings and overfill are the individual monitoring activities with the highest total costs. Facilities with storage vessels complying with a control requirement by connecting storage vessels to a closed vent system and

contr ol device were assumed to have a single centralized system that controls emissions from allTechnical Memorandum

– Technology Review for Storage Vessels January 20, 2012



### 42 such storage vessels. The tables show the total costs for visual monitoring and manual measurements are very similar to the total costs for monitoring using Method 21 or optical gas imaging. The tables show the total cost to comply with all monitoring activities described in this memorandum, but the incremental cost relative to current costs will be less for existing facilities that are already implementing some of t he monitoring to comply with current rules or for other

reasons.

Tables 3 2 and 3 3 present the labor burden associated with each type of monitoring option for each of the model SOCMI facilities and petroleum refineries. The tabulated values reflect the

annu al burden per facility, and burden associated with initial setup or planning activities is noted

in footnotes to the tables.

Table 2 8 . Number of storage vessels at model SOCMI facilities

Model facility Fixed roof venting to atmosphere 1 Fixed roof venting to

control Pressure

vessels EFR 2 IFR 2

Total S M L S M L

1 2 0 0 1 0 0 1 0 0 4

2 2 2 0 0 0 0 0 0 0 4

3 6 2 1 1 2 0 2 4 0 18

4 10 4 3 1 1 4 2 2 2 29

1 Storage vessels below size and maximum true vapor pressure ( MTVP ) thresholds for control in curre nt rules.

2 ”S” means a small storage vessel (30,000 gal), “M” means a medium storage vessel (100,000 gal), and “L” means a large storage vessel (2,000,000 gal).



### Table 2 9 . Number of storage vessels at model petroleum refineries

Model facility Fixed roof

v enting to atmosphere 1 Fixed roof venting to

control Pressure

vessels EFR 2 IFR 2

Total S M L VL S M L

1 12 4 3 1 1 3 0 3 1 1 29

2 12 4 9 3 7 8 0 6 3 3 55

3 12 8 16 6 14 17 3 11 6 3 96

1 Storage vessels below size and MTVP thresholds for control in c urrent rules.

2 ”S” means a small storage vessel (450,000 gal), “M” means a medium storage vessel (3,300,000 gal), “L” means a large storage vessel (8,000,000 gal), and “VL” means a very large storage vessel (22,000,000 gal).Technical Memorandum

– Technology Review for Storage Vessels January 20, 2012



### 43 Table 30 . Total monitoring, recordkeeping, and reporting cost for storage vessels at model SOCMI facilities

Model facility Type of monitoring 1 Total annual costs ($/yr)

Pressure vessels

and fixed roof

venting to atmosphere Fixed roof venting to

control EFR IFR 2 Closed

vent
system Control

device 3 Floating roof landings

monitor and

alarm Overfill

monitor

and alarm Total

1 Visual 2 40 0 3 50 21 0 0 0 2

, 1 0 0 1,10 0 4

, 0 00

Method 21 30 0 0 24 0 24 0 0 0 2

, 1 0 0 1,10 0 4

, 0 00

OGI 4 50 0 24 0 24 0 0 0 2

, 1 0 0 1,10 0 4

, 2 00

2 Visual 2 40 2 40 0 0 94 8,40 0 0 1,90 0 11

, 0 00

Method 21 30 0 30 0 0 0 1 4 0 8,400 0 1,90 0 11

, 0 00

OGI 4 50 4 50 0 0 2 6 0 8,400 0 1,90 0 1 1

, 0 00

3 Visual 83 0 2 40 1, 200 1,30 0 94 8,400 9

, 5 00 6

, 9 00 2 8

, 0 00

Method 21 1, 100 30 0 73 0 1, 500 1 4 0 8,400 9

, 5 00 6

, 9 00 2 9

, 0 00

OGI 1, 600 4 50 73 0 1, 500 2 6 0 8,400 9

, 5 00 6

, 9 00 2 9

, 0 00

4 Visual 1,5 00 4 80 2, 500 1,30 0 1 90 8,400 1 3

, 000 10

, 0 00 3 8

, 0 00

Method 21 2, 100 640 1, 500 1, 500 2 8 0 8,400 1 3

, 000 10

, 0 00 3 8

, 0 00

OGI 3,100 960 1, 500 1, 500 51 0 8,400 1 3

, 000 10

, 0 00 3 9 ,000

1 For storage vessels with EFR or IFR, pre ssure vessels, fixed roof storage vessels (all), and closed vent systems.

2 As noted in Table 2 5 , Method 21 monitoring is not likely to be required inside an operating storage vessel; therefore, the costs for the Method 2 1 option are

instead based on costs for optical gas imaging.

3 Assumed to be a thermal oxidizer.Technical Memorandum

– Technology Review for Storage Vessels January 20, 2012



### 44 Table 3 1 . Total monitoring, recordkeeping, and reporting cost for storage vessels at model petroleum refineries

Model facility Type of monitoring 1 Total annual costs ($/yr)

Pressure

vessels an d

fixed roof venting to atmosphere Fixed roof venting to

control EFR IFR 2 Closed

vent
system Control

device 3 Floating roof landings

monitor and

alarm Overfill

monitor and

alarm Total

1 Visual 1, 800 4 80 2,1 00 1, 100 1 90 8,400 11 ,0 00 9,3 00 34

, 0 00

Method 21 2,40 0 640 1, 3 00 1,2 00 2 9 0 8,400 11 ,0 00 9,3 00 34

, 0 00

OGI 3,600 960 1, 300 1,2 00 51 0 8,400 11 ,0 00 9,3 00 3 6

, 0 00

2 Visual 2, 500 4 80 7, 700 2,6 00 1 90 8,400 32 ,0 00 21

, 000 74

, 0 00

Method 21 3, 600 6 80 4,5 00 3,000 2 9 0 8,400 32 ,0 00 21

, 000 73

, 0 00

OGI 5,400 1,000 4,5 00 3,000 51 0 8,400 32 ,0 00 21

, 000 75

, 0 00

3 Visual 3,3 00 950 17,0 00 4, 400 3 80 8,400 63 ,0 00 41

, 000 1 4 0 ,000

Method 21 4,7 00 1, 400 10,0 00 5,000 5 7 0 8,400 63 ,0 00 41

, 000 1 3 0,000

OGI 7,200 2,100 10,0 00 5,000 1,00 0 8,400 63 ,0 00 41

, 000 1 4 0 ,000

1 For storage vessels with EFR or IFR, pressure vessels, fixed roof storage vessels (all), and closed vent systems.

2 As noted in Table 2 5 , Method 21 monitoring is not likely to be required inside an operating storage vessel; therefore, the costs for the Method 2 1 optio n are instead based on costs for optical gas imaging.

3 Assumed to be a thermal oxidizer.Technical Memorandum

– Technology Review for Storage Vessels January 20, 2012



### 45 Table 3 2 . Total monitoring, recordkeeping, and reporting burden for storage vessels at model SOCMI facilities

Model facility Type of monitoring 1 Total annual burden (hr/yr)

Pressure vessels

and fixed roof

venting to atmosphere Fixed roof venting to

control EFR IFR 2 Closed

vent
system 3 Control

device 4 Floating roof landings

monitor and

alarm 5 Overfill

monitor

and alarm 5 Total

1 Visual 3.1 0 5.4 2.6 0 0 23 2.2 40

Method 21 3.5 0 3.2 3.2 0 0 23 2.2 40

OGI 5.8 0 3.2 3.2 0 0 23 2.2 40

2 Visual 3.1 3.1 0 0 1.5 110 0 2.2 120

Method 21 3.5 3.5 0 0 0.5 110 0 2.2 120

OGI 5.8 5.8 0 0 1.0 110 0 2.2 130

3 Visual 11 3.1 18 16 1.5 110 59 12 230

Method 21 12 3.5 9.7 1 9 0.5 110 59 12 230

OGI 20 5.8 9.7 19 1.0 110 59 12 240

4 Visual 20 6.1 40 16 3.0 110 78 18 290

Method 21 25 7.6 20 20 1.0 110 78 18 280

OGI 42 13 20 20 2.0 110 78 18 300

1 For storage vessels with EFR or IFR, pressure vessels, fixed roof storage ve ssels (all), and closed vent systems.

2 As noted in Table 2 5 , Method 21 monitoring is not likely to be required inside an operating storage vessel; therefore, the costs for the Method 2 1 option are instead based on costs for optical gas imaging.

3 Also one

- t ime initial burden of 23 minutes per piece of equipment for initial setup when monitoring using Method 21 or OGI.

4 Assumed to be a thermal oxidizer. Also one

- time initial burden of 42 hr for planning.

5 Also one

- time initial burden of 11.5 hr per storage ve ssel for planning.Technical Memorandum

– Technology Review for Storage Vessels January 20, 2012



### 46 Table 3 3 . Total monitoring, recordkeeping, and reporting burden for storage vessels at model petroleum refineries

Model facility Type of monitoring 1 Total annual costs ($/yr)

Pressure vessels

and fixed roof

venting to atmosphere Fixe d roof venting to

control EFR IFR 2 Closed

vent
system 3 Control

device 4 Floating roof landings

monitor and

alarm 5 Overfill

monitor

and alarm 5 Total

1 Visual 23 6.1 35 14 3.0 110 65 16 270

Method 21 29 7.6 17 17 1.0 110 65 16 260

OGI 49 13 17 17 2.0 110 65 16 290

2 Visual 32 6.1 130 32 3.0 110 195 38 540

Method 21 44 8.3 61 40 1.0 110 195 38 500

OGI 75 14 61 40 2.0 110 195 38 540

3 Visual 43 12 280 54 6.0 110 390 76 970

Method 21 58 17 130 66 2.0 110 390 76 850

OGI 100 29 130 66 4.0 110 390 76 910

1 For storage vessels with EFR or IFR, pressure vessels, fixed roof storage vessels (all), and closed vent systems.

2 As noted in Table 2 5 , Method 21 monitoring is not likely to be required inside an operating storage vessel; therefore, the costs for th e Method 21 option are instead based on costs for optical gas imaging.

3 Also one

- time initial burden of 23 minutes per piece of equipment for initial setup.

4 Assumed to be a thermal oxidizer. Also one

- time initial burden of 42 hr for planning.

5 Also one

- ti me initial burden of 11.5 hr per storage vessel for planning when monitoring using Method 21 or OGI.Technical Memorandum

– Technology Review for Storage Vessels January 20, 2012



### 47 11. References

John M. Ellsworth Co., Inc. 2011 a . “Shand & Jurs 2” Conservation Vent (Pressure/Vacuum)”.

Retrieved from http://www.jmesales.com/item/130113/Shand

- Jurs

- Conservation

- Vents

Pressure

- Vacuum

- Model

- 94020.aspx . Accessed November 2011.

John M. Ellsworth Co., Inc. 2011b. “Shand & Jurs 4 ” Aluminum Gauge Hatch Model 95021”.

Retrieved from http://www.jmesales.com/item/136311/Shand

- Jurs

- Gauge

- Hatches

- Model

95021.aspx . Accessed November 2011.

E nvent

. 2011. Environmental Protection Applications

- Comparison of Degassing Methods

. Retrieved from: http://www.degassingsafely.com/ . Last accessed in November 2011.

Ferry, R. 2006. Emission Factors for a Ladder/Gu idepole Combination . Prepared by R. Ferry, the TGB partnership.

Gibson, G., J. Renzaglia, M. Thomas, and P. Crawford. 201 2 . Memorandum from G. Gibson, J. Renzaglia, M. Thomas, and P. Crawford, ERG, to A. Bouchard and B. Shine, EPA/OAQPS. Development of Mon itoring Cost Estimates for the Proposed Part 65 Uniform Standards for

Control Devices

— Subpart M

. January 20 , 201 2 . Docket No. EPA

- HQ

- OAR

- 2010

- 0868.

Hancy, C. 2011. Memorandum from C. Hancy, RTI International to J. Howard, EPA/OAQPS. Technology Review for E quipment Leaks

. December 21 , 2011. Docket No. EPA

- HQ

- OAR

2010

- 0869.

Moore, J. 2009. Letter from J. Moore, Baker Botts, LLP, to E. Lin, TCEQ. Comments on Chapter 115 Degassing Rules . December 11, 2009.

Office of Management and Budget (OMB). 2011. Supporting Statement for Consolidated Air Rule for Synthetic Organic Chemical Manufacturing Industry. OMB Control Number 2060

- 0443. Retrieved from http://www.reginfo.gov/public/ do/PRAViewDocument?ref_nbr=201102

- 2060

- 018 . Last

accessed in November 2011.

Parrish, K. and D. Randall. 2007. Memorandum from K. Parrish and D. Randall, RTI International, to K. Rackley, EPA/SPPD. Final Impacts Analysis for Regulatory Options for Equipmen t Leaks of VOC in the SOCMI . October 30, 2007. Docket Item No. EPA

- HQ

- OAR

2006

- 0699

- 0090.

Parsons, N. 201 2 . Memorandum from N. Parsons, EPA/OAQPS. Leaks Observed from Fixed Roof and Floating Roof Fittings

. February 6 , 201 2

.

Peters, Timmerhaus, and West. 20 03. Plant Design and Economics for Chemical Engineers

. Fifth Edition. McGraw Hill, New York, NY. p. 251.

Randall, D. and J. Fields. 2000. Memorandum from D. Randall and J. Fields, Midwest Research Institute, to MON Project File. MACT Floor, Regulatory Alte rnatives, and Nationwide Impacts for Storage Tanks at Miscellaneous Organic Chemical Manufacturing Facilities.Technical Memorandum

– Technology Review for Storage Vessels January 20, 2012



### 48 July 31, 2000. Part of Hazardous Air Pollutant Emissions for Miscellaneous Organic Chemical Manufacturing, Supplementary Information Document for Proposed Standards

. December 2000. Docket A

- 96

- 04, Item No. II

- B

- 28.

Randall, D. 2012 a . Memorandum from D. Randall, RTI International, to Uniform Standards

Docket. Development of Costs for Floating Roofs, Rim Seals, Deck Fitting Controls , and Liquid Level Sensor/Alarm Systems . January 17 , 2012.

Randall, D. 2012b. Memorandum from D. Randall, RTI International, to N. Parsons, EPA/OAQPS. Geodesic Dome Costs . January 17, 2012.

RTI. 2002. Petroleum Refinery Source Characterization and Emission Model for Residua l Risk

Assessment . Prepared for U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park, NC. EPA Contract No. 68

- D6

- 0014. July 2,

2002. Docket Item No. EPA

- HQ

- OAR

- 2003

- 0146

- 0083.

South Coast Air Quality Ma nagement District (SCAQMD). 2001. Further Reductions of VOC Emissions From Storage Tanks at Petroleum Facilities . Final Staff Report Proposed Rule 1178. December 11, 2001. Retrieved from: http://www.a qmd.gov/hb/2001/011233a.html

. Last accessed in November 2011.

South Coast Air Quality Management District. (SCAQMD). 2008 a . Rule 1149. Storage Tank and Pipeline Cleaning and Degassing. Retrieved from: http://www.aqmd.gov/rules/reg/reg11/r1149.pdf . Last accessed in November 2011.

South Coast Air Quality Management District (SCAQMD). 2008 b

. Proposed Amended Rule

1149

— Storage Tank and Pipeline Cleaning and Degassing . Final Staff Report. Retrieved

from: http://www.aqmd.gov/hb/2008/May/080534a.htm . Last accessed in November 2011.

Texas Commission on Environmental Quality (TCEQ). Chapter 115

- Control of Air Pollution from Volatile Organic Comp ounds, Subchapter F: Miscellaneous Industrial Sources, Division 3: Degassing of Storage Tanks, Transport Vessels, and Marine Vessels. Retrieved

from: http://www.tceq. texas.gov/assets/public/legal/rules/rules/pdflib/115f.pdf . Last accessed

in November 2011.

U.S. Department of Labor (DOL ), Bureau of Labor Statistics. 20 10

. Occupational Employment Statistics: May 2009 Occupational Employment and Wage Estimates , National Sector NAICS Industry

- Specific Estimates

. Last modified date May 14, 2010. Retrieved from: http://www.bls.gov/oes/2009/may/naics2_31

- 33.htm . Last accessed in November 2011.

U.S. EPA. 1980. Or ganic Chemical Manufacturing Volume 3: Storage, Fugitive, and Secondary

Sources , Office of Air Quality Planning and Standards. EPA

- 450/3

- 80

- 025.

U.S. EPA. 1984. VOC Emissions from Volatile Organic Liquid Storage Tanks

— Background Information for Proposed St andards . Office of Air Quality Planning and Standards. EPA

450/3

- 81

- 003a.Technical Memorandum

– Technology Review for Storage Vessels January 20, 2012



### 49 U.S. EPA. 1992. Hazardous Air Pollutant Emissions from Process Units in the Synthetic Organic Chemical Manufacturing Industry

— Background Information for Proposed

Standards. Volume 1C : Model Emissions Sources . Office of Air Quality Planning and

Standards. EPA

- 453/D

- 92

- 016c.

U.S. EPA. 1994. Alternative Control Techniques Document: Volatile Organic Liquid Storage in Floating and Fixed Roof Tanks . Office of Air Quality Planni n g and Standa rds. EPA

- 453/R

94

- 001.

U.S. EPA. 1995a. Compilation of Air Pollutant Emission Factors

, Volume 1: Stationary Point and Area Sources, AP

- 42, Fifth Edition, Office of Air Quality Planning and Standards. Available at http://www.epa.gov/ttn/chief/ap42/index.htm l.

U.S. EPA. 1995 b

. Protocol for Equipment Leak Emission Estimates

. Office of Air Quaility Planning and Standards. EPA

- 453/R

- 95

- 017.

U.S. EPA. 2002. EPA Air Pollution Control Cost Manual Section 1 Chapter 2. Sixth Edition

. Office of Air Quality Planning an d Standards. EPA

- 452/B

- 02

- 001.

U.S. EPA. 2006. TANKS Emission Estimation Software, Version 4.09D . Office of Air Quality Planning and Standards, Technology Transfer Network, Clearinghouse for Inventories and Emissions Factors, Available at: http://www.epa.gov/ttn/chief/software/tanks/index.html

.

U.S. EPA. 2011. Petroleum Refinery Database, Based on Refinery Information Collection Request (ICR) for Calendar Year 2010. March 31, 2011. Dock et No. EPA

- HQ

- OAR

- 2010

- 0682.[this page intentionally left blank]

## Attachment A: Costs for Envent’s Degassing Control Systems[this page intentionally left blank]

## Sizing Comparison Chart for Degassing Control Systems a

Thermal oxidizers In i tial

flow rate

from

tank (scfm) End of job

flow rate

(scfm) b VOC

destruction

capacity

(lb/hr) Time to degas to

20% LEL (hr) Make

- up fuel (LPG)
required (gal/hr) Typ ical costs ($/lb

VOC destroyed) Calculated VOC

emission reduction (lb) c Calculated job cost ($) d Calculated
cost using algorithm ($) e

1,000 scfm; low Btu unit 72 1,000 80 42 4.7 2.25 3,360 7,560

2,000 scfm; EMTOS

- 20 144 2,000 160 16 8.7 1 .55 2,560 3,968 5,600

2,500 scfm; EMTOS

- 25 180 2,500 200 14 10.9 1.5 2,800 4,200 5,100

3,500 scfm; EMTOS

- 35 252 3,500 280 9 15.5 1.45 2,520 3,654 3,850

4,500 scfm; EMTOS

- 45 324 4,500 360 6 19.2 1.4 2,160 3,024 3,100

a Data in first 7 columns of the table were obtained from Envent's website at: http://www.degassingsafely.com/. The reported data are for degassing a

typical 80,000 bbl gasoline storage vessel, drained dry.

b When VOC concentration has dropped below 50% LEL.

c Ass uming system achieves VOC destruction capacity every hour of operation.

d Calculated as product of calculated VOC emission reduction times the typical costs in $/lb VOC destroyed.

e Calculated assuming a base fee of $2,000 per job plus a variable f ee of $250/hr.[this page intentionally left blank]

## Attachment B: Impacts for Model Storage Vessels that are Controlled

Using an IFR[this page intentionally left blank]TABLE B.1
Impacts for Control Option ST1 for model storage vessels with no guidepoles

Xylene Toluene Methyl
methacrylate 1,4-Dioxane Formic acid Isooctane Ethanol Trichloroethylene Ethylene

dichloride Methyl ethyl

ketone Acetonitrile

Model A Total capital investment ($) 29,058 29,058 29,058 29,058 29,058 29,058 29,058 29,058 29,058 29,058 Total annual cost ($/yr) 5,295 5,085 5,159 5,438 4,642 5,271 3,956 4,222 4,466 5,035
Emission reduction (tpy) 0.57 0.80 0.72 0.41 1.29 0.59 2.06 1.76 1.49 0.86 Cost effectiveness ($/ton) 9,330 6,352 7,180 13,312 3,590 8,865 1,924 2,399 3,002 5,882

Model B Total capital investment ($) 31,560 31,560 31,560 31,560 31,560 31,560 31,560 31,560 31,560 31,560 Total annual cost ($/yr) 5,393 5,029 5,153 5,630 4,273 5,355 3,063 3,530 3,969 4,951
Emission reduction (tpy) 1.01 1.42 1.28 0.75 2.26 1.06 3.60 3.08 2.60 1.51 Cost effectiveness ($/ton) 5,318 3,545 4,026 7,496 1,892 5,068 850 1,145 1,529 3,290

Model C Total capital investment ($) 41,163 41,163 41,163 41,163 41,163 41,163 41,163 41,163 41,163 41,163 41,163 Total annual cost ($/yr) 7,299 4,649 3,275 3,742 5,538 483 4,562 (4,087) (2,290) (578) 3,089
Emission reduction (tpy) 1.03 3.97 5.50 4.98 2.99 8.60 4.07 13.68 11.68 9.78 5.71 Cost effectiveness ($/ton) 7,096 1,170 595 751 1,855 56 1,121 (299) (196) (59) 541Model A Total capital investment ($)
Total annual cost ($/yr)

Emission reduction (tpy) Cost effectiveness ($/ton)

Model B Total capital investment ($)
Total annual cost ($/yr)

Emission reduction (tpy) Cost effectiveness ($/ton)

Model C Total capital investment ($)
Total annual cost ($/yr)

Emission reduction (tpy) Cost effectiveness ($/ton) TABLE B.1
Impacts for Control Option ST1 for model storage vessels with no guidepoles

Ethyl acetate Benzene Acrylonitrile Vinyl acetate Methanol 1,1,1-

trichlorethane Methylcyclopentane Hexane Chloroform Diethylamine Methylene

chloride

29,058 29,058 29,058 29,058 29,058 29,058 29,058 29,058 29,058 29,058 29,058

4,084 4,265 4,553 3,749 4,997 2,074 3,365 3,043 913 2,112 (2,168)

1.91 1.71 1.39 2.29 0.90 4.15 2.71 3.07 5.44 4.10 8.86

2,136 2,491 3,271 1,641 5,565 500 1,241 992 168 515 (245)

31,560 31,560 31,560 31,560 31,560 31,560 31,560 31,560 31,560 31,560 31,560

3,306 3,619 4,118 2,727 4,885 (175) 2,071 1,520 (2,191) (102) (1,382)

3.33 2.99 2.43 3.98 1.58 7.20 4.71 5.32 9.44 7.12 8.54

992 1,212 1,694 686 3,096 (24) 440 286 (232) (14) (162)

41,163 41,163 41,163 41,163 41,163 41,163 41,163 41,163 41,163
(3,054) (1,883) 5 (5,175) 2,870 (15,960) (7,563) (9,577) (23,342)

12.53 11.23 9.13 14.89 5.95 26.87 17.54 19.78 35.07
(244) (168) 1 (348) 482 (594) (431) (484) (666)TABLE B.2
Impacts for Control Option ST1 for model storage vessels with unslotted guidepoles

Xylene Toluene Methyl
methacrylate 1,4-Dioxane Formic acid Isooctane Ethanol Trichloroethylene Ethylene

dichloride Methyl ethyl

ketone Acetonitrile

Model A Total capital investment ($) 29,058 29,058 29,058 29,058 29,058 29,058 29,058 29,058 29,058 29,058 Total annual cost ($/yr) 5,305 5,100 5,172 5,446 4,664 5,281 3,991 4,252 4,493 5,050
Emission reduction (tpy) 0.56 0.78 0.70 0.40 1.27 0.58 2.02 1.73 1.46 0.84 Cost effectiveness ($/ton) 9,532 6,500 7,347 13,632 3,677 9,058 1,980 2,464 3,081 6,020

Model B Total capital investment ($) 31,560 31,560 31,560 31,560 31,560 31,560 31,560 31,560 31,560 31,560 Total annual cost ($/yr) 5,403 5,043 5,166 5,637 4,295 5,365 3,099 3,561 3,996 4,966
Emission reduction (tpy) 1.00 1.40 1.27 0.74 2.23 1.05 3.56 3.05 2.57 1.49 Cost effectiveness ($/ton) 5,387 3,594 4,081 7,592 1,923 5,134 870 1,168 1,557 3,338

Model C Total capital investment ($) 41,163 41,163 41,163 41,163 41,163 41,163 41,163 41,163 41,163 41,163 41,163 Total annual cost ($/yr) 7,301 4,658 3,288 3,754 5,545 504 4,572 (4,053) (2,260) (553) 3,103
Emission reduction (tpy) 1.03 3.96 5.48 4.97 2.98 8.58 4.06 13.64 11.65 9.75 5.69 Cost effectiveness ($/ton) 7,120 1,176 600 756 1,863 59 1,127 (297) (194) (57) 545Model A Total capital investment ($)
Total annual cost ($/yr)

Emission reduction (tpy) Cost effectiveness ($/ton)

Model B Total capital investment ($)
Total annual cost ($/yr)

Emission reduction (tpy) Cost effectiveness ($/ton)

Model C Total capital investment ($)
Total annual cost ($/yr)

Emission reduction (tpy) Cost effectiveness ($/ton) TABLE B.2
Impacts for Control Option ST1 for model storage vessels with unslotted guidepoles

Ethyl acetate Benzene Acrylonitrile Vinyl acetate Methanol 1,1,1-

trichlorethane Methylcyclopentane Hexane Chloroform Diethylamine Methylene

chloride

29,058 29,058 29,058 29,058 29,058 29,058 29,058 29,058 29,058 29,058 29,058

4,118 4,295 4,578 3,790 5,014 2,148 3,413 3,100 1,015 2,190 (1,969)

1.88 1.68 1.36 2.24 0.88 4.06 2.66 3.01 5.32 4.02 8.64

2,195 2,560 3,355 1,692 5,701 529 1,284 1,031 191 545 (228)

31,560 31,560 31,560 31,560 31,560 31,560 31,560 31,560 31,560 31,560 31,560

3,339 3,650 4,142 2,768 4,901 (101) 2,120 1,576 (2,089) (23) (1,280)

3.30 2.95 2.40 3.93 1.56 7.12 4.65 5.26 9.33 7.03 8.43

1,013 1,237 1,723 704 3,142 (14) 456 300 (224) (3) (152)

41,163 41,163 41,163 41,163 41,163 41,163 41,163 41,163 41,163
(3,022) (1,854) 29 (5,136) 2,886 (15,889) (7,516) (9,523) (23,243)

12.50 11.20 9.11 14.84 5.93 26.79 17.49 19.72 34.96
(242) (166) 3 (346) 487 (593) (430) (483) (665)TABLE B.3
Impacts for Control Option ST2 for model storage vessels with no guidepoles

Xylene Toluene Methyl
methacrylate 1,4-Dioxane Formic acid Isooctane Ethanol Trichloroethylene Ethylene

dichloride Methyl ethyl

ketone Acetonitrile

Model A Incremental total capital investment ($) 1,750 1,750 1,750 1,750 1,750 1,750 1,750 1,750 1,750 1,750 Incremental total annual cost ($/yr) 324 314 317 330 293 323 258 270 283 310
Incremental emission reduction (tpy) 0.029 0.040 0.036 0.022 0.063 0.030 0.10 0.088 0.074 0.044 Incremental cost effectiveness ($/ton) 11,368 7,952 8,812 14,993 4,650 10,755 2,528 3,073 3,825 7,138

Model B Incremental total capital investment ($) 1,750 1,750 1,750 1,750 1,750 1,750 1,750 1,750 1,750 1,750 Incremental total annual cost ($/yr) 324 314 317 330 293 323 258 270 283 310
Incremental emission reduction (tpy) 0.029 0.040 0.036 0.022 0.063 0.030 0.10 0.088 0.074 0.044 Incremental cost effectiveness ($/ton) 11,368 7,952 8,812 14,993 4,694 10,755 2,528 3,073 3,825 7,046

Model C Incremental total capital investment ($) 1,750 1,750 1,750 1,750 1,750 1,750 1,750 1,750 1,750 1,750 1,750 Incremental total annual cost ($/yr) 343 324 314 317 329 292 322 256 269 282 310
Incremental emission reduction (tpy) 0.008 0.029 0.040 0.037 0.023 0.064 0.031 0.10 0.090 0.075 0.045 Incremental cost effectiveness ($/ton) 45,719 11,157 7,841 8,679 14,640 4,563 10,564 2,478 3,007 3,762 6,957Model A Incremental total capital investment ($)
Incremental total annual cost ($/yr)

Incremental emission reduction (tpy) Incremental cost effectiveness ($/ton)

Model B Incremental total capital investment ($)
Incremental total annual cost ($/yr)

Incremental emission reduction (tpy) Incremental cost effectiveness ($/ton)

Model C Incremental total capital investment ($)
Incremental total annual cost ($/yr)

Incremental emission reduction (tpy) Incremental cost effectiveness ($/ton) TABLE B.3
Impacts for Control Option ST2 for model storage vessels with no guidepoles

Ethyl acetate Benzene Acrylonitrile Vinyl acetate Methanol 1,1,1-

trichlorethane Methylcyclopentane Hexane Chloroform Diethylamine Methylene

chloride

1,750 1,750 1,750 1,750 1,750 1,750 1,750 1,750 1,750 1,750 1,750

264 273 286 246 309 159 225 208 91 151 (151)

0.10 0.086 0.071 0.12 0.046 0.21 0.14 0.16 0.29 0.22 0.56

2,761 3,189 4,025 2,127 6,784 753 1,615 1,320 316 682 (272)

1,750 1,750 1,750 1,750 1,750 1,750 1,750 1,750 1,750 1,750 1,750

264 273 286 246 308 159 225 208 91 151 205

0.10 0.086 0.071 0.12 0.046 0.21 0.14 0.16 0.29 0.22 0.29

2,761 3,189 4,025 2,140 6,701 753 1,615 1,320 316 682 708

1,750 1,750 1,750 1,750 1,750 1,750 1,750 1,750 1,750

262 271 285 244 308 156 223 206 88

0.10 0.087 0.072 0.12 0.047 0.22 0.14 0.16 0.29

2,705 3,119 3,956 2,076 6,619 726 1,580 1,285 302TABLE B.4
Impacts for Control Option ST2 for model storage vessels with unslotted guidepoles

Xylene Toluene Methyl
methacrylate 1,4-Dioxane Formic acid Isooctane Ethanol Trichloroethylene Ethylene

dichloride Methyl ethyl

ketone Acetonitrile

Model A Incremental total capital investment ($) 2,700 2,700 2,700 2,700 2,700 2,700 2,700 2,700 2,700 2,700 Incremental total annual cost ($/yr) 508 496 500 515 471 507 428 444 458 492
Incremental emission reduction (tpy) 0.035 0.049 0.044 0.027 0.077 0.037 0.12 0.11 0.091 0.053 Incremental cost effectiveness ($/ton) 14,736 10,223 11,360 19,079 6,152 13,879 3,468 4,165 5,061 9,278

Model B Incremental total capital investment ($) 2,700 2,700 2,700 2,700 2,700 2,700 2,700 2,700 2,700 2,700 Incremental total annual cost ($/yr) 508 496 500 516 471 507 428 443 458 492
Incremental emission reduction (tpy) 0.035 0.048 0.044 0.027 0.077 0.037 0.12 0.11 0.091 0.053 Incremental cost effectiveness ($/ton) 14,736 10,338 11,501 19,456 6,152 13,879 3,450 4,142 5,061 9,278

Model C Incremental total capital investment ($) 2,700 2,700 2,700 2,700 2,700 2,700 2,700 2,700 2,700 2,700 2,700 Incremental total annual cost ($/yr) 531 508 496 500 515 471 507 428 443 458 492
Incremental emission reduction (tpy) 0.009 0.035 0.048 0.044 0.027 0.077 0.037 0.12 0.11 0.091 0.053 Incremental cost effectiveness ($/ton) 59,038 14,736 10,338 11,360 19,079 6,152 13,879 3,450 4,142 5,061 9,278Model A Incremental total capital investment ($)
Incremental total annual cost ($/yr)

Incremental emission reduction (tpy) Incremental cost effectiveness ($/ton)

Model B Incremental total capital investment ($)
Incremental total annual cost ($/yr)

Incremental emission reduction (tpy) Incremental cost effectiveness ($/ton)

Model C Incremental total capital investment ($)
Incremental total annual cost ($/yr)

Incremental emission reduction (tpy) Incremental cost effectiveness ($/ton) TABLE B.4
Impacts for Control Option ST2 for model storage vessels with unslotted guidepoles

Ethyl acetate Benzene Acrylonitrile Vinyl acetate Methanol 1,1,1-

trichlorethane Methylcyclopentane Hexane Chloroform Diethylamine Methylene

chloride

2,700 2,700 2,700 2,700 2,700 2,700 2,700 2,700 2,700 2,700 2,700

435 445 462 413 489 309 388 367 224 297 (72)

0.12 0.10 0.086 0.14 0.056 0.26 0.17 0.19 0.35 0.27 0.68

3,750 4,262 5,373 2,953 8,733 1,203 2,301 1,910 639 1,105 (106)

2,700 2,700 2,700 2,700 2,700 2,700 2,700 2,700 2,700 2,700 2,700

435 445 462 413 489 309 388 367 224 297 363

0.12 0.10 0.086 0.14 0.056 0.26 0.17 0.19 0.35 0.27 0.35

3,771 4,262 5,373 2,953 8,733 1,203 2,301 1,910 641 1,105 1,033

2,700 2,700 2,700 2,700 2,700 2,700 2,700 2,700 2,700

435 445 462 413 489 308 387 366 224

0.12 0.10 0.086 0.14 0.056 0.26 0.17 0.19 0.35

3,750 4,262 5,373 2,953 8,733 1,199 2,292 1,902 639TABLE B.5
Impacts for Model Petroleum Products Storage Vessels

Model Model Model Model Model Model

D E F G H I
Control Option ST1
Models with no guidepoles Total capital investment ($) 166,441 420,701 78,361 420,701 111,873 284,795 Total annual cost ($/yr) (1,118) 8,869 (29,303) (87,585) (153) 9,796
Emission reduction (tpy) 68.7 150 89.9 343 45.0 94.2 Cost effectiveness ($/ton) (16) 59 (326) (255) (3) 104
Models with unslotted guidepoles Total capital investment ($) 166,441 420,701 78,361 420,701 111,873 284,795 Total annual cost ($/yr) (1,107) 8,879 (29,246) (87,528) (136) 9,813
Emission reduction (tpy) 68.7 150 89.8 343 45.0 94.2 Cost effectiveness ($/ton) (16) 59 (326) (255) (3) 104
Models with slotted guidepoles Total capital investment ($) 166,441 420,701 78,361 420,701 111,873 284,795 Total annual cost ($/yr) (1,103) 8,884 (29,224) (87,506) (129) 9,820
Emission reduction (tpy) 68.7 150 89.8 343 45.0 94.2 Cost effectiveness ($/ton) (16) 59 (326) (255) (3) 104
Control Option ST2
Models with no guidepoles Incremental total capital investment ($) 5,050 13,300 1,750 13,300 4,500 10,000 Incremental total annual cost ($/yr) 953 2,531 205 1,977 816 1,836
Incremental emission reduction (tpy) 0.11 0.25 0.29 1.36 0.17 0.32 Incremental cost effectiveness ($/ton) 8,590 10,003 706 1,452 4,884 5,676
Models with unslotted guidepoles Incremental total capital investment ($) 6,000 14,250 2,700 14,250 5,450 10,950 Incremental total annual cost ($/yr) 1,138 2,715 363 2,136 996 2,017
Incremental emission reduction (tpy) 0.12 0.26 0.35 1.42 0.19 0.34 Incremental cost effectiveness ($/ton) 9,286 10,264 1,033 1,501 5,354 5,888
Models with slotted guidepoles Incremental total capital investment ($) 6,400 14,650 3,100 14,650 5,850 11,350 Incremental total annual cost ($/yr) 1,215 2,793 433 2,205 1,073 2,093
Incremental emission reduction (tpy) 0.13 0.27 0.37 1.44 0.19 0.35 Incremental cost effectiveness ($/ton) 9,608 10,401 1,163 1,527 5,587 6,007[this page intentionally left blank]

## Attachment C: Impacts for Model Storage Vessels that are Controlled

Using an EFR[this page intentionally left blank]TABLE C.1
Impacts for Control Option ST5 for model storage vessels with unslotted guidepoles
Xylene Toluene MM Formic acid Isooctane MEK Benzene MeOH Hexane Chloroform

Model A Total capital investment ($) 11,244 11,244 11,244 11,244 11,244 11,244 11,244 11,244 11,244 11,244 Total annual cost ($/yr) 1,654 1,565 1,518 1,592 1,420 1,373 1,323 1,492 1,019 473
Emission reduction (tpy) 0.034 0.13 0.19 0.10 0.29 0.35 0.40 0.21 0.74 1.35 Cost effectiveness ($/ton) 48,639 11,764 8,204 15,453 4,829 3,968 3,300 6,971 1,379 352

Model B Total capital investment ($) 13,006 13,006 13,006 13,006 13,006 13,006 13,006 13,006 13,006 Total annual cost ($/yr) 1,910 1,797 1,737 1,831 1,613 1,554 1,491 1,704 1,106
Emission reduction (tpy) 0.043 0.17 0.23 0.13 0.37 0.44 0.51 0.27 0.94 Cost effectiveness ($/ton) 44,408 10,662 7,408 14,029 4,330 3,543 2,939 6,276 1,181

Model C Total capital investment ($) 18,170 18,170 18,170 18,170 18,170 18,170 18,170 18,170 18,170 Total annual cost ($/yr) 2,656 2,467 2,367 2,524 2,157 2,310 2,057 1,952 1,303
Emission reduction (tpy) 0.073 0.28 0.39 0.22 0.63 0.46 0.74 0.86 1.58 Cost effectiveness ($/ton) 36,385 8,701 5,999 11,500 3,438 5,056 2,783 2,282 827TABLE C.2
Impacts for Control Option ST5 for model storage vessels with slotted guidepoles
Xylene Toluene MM Formic acid Isooctane MEK Benzene MeOH Hexane Chloroform

Model A Total capital investment ($) 11,244 11,244 11,244 11,244 11,244 11,244 11,244 11,244 11,244 11,244 Total annual cost ($/yr) 1,653 1,565 1,518 1,592 1,420 1,373 1,323 1,492 1,019 473
Emission reduction (tpy) 0.035 0.133 0.185 0.103 0.294 0.346 0.401 0.214 0.739 1.35 Cost effectiveness ($/ton) 47,921 11,764 8,204 15,453 4,829 3,968 3,300 6,971 1,379 352

Model B Total capital investment ($) 13,006 13,006 13,006 13,006 13,006 13,006 13,006 13,006 13,006 Total annual cost ($/yr) 1,910 1,797 1,737 1,831 1,613 1,554 1,491 1,704 1,106
Emission reduction (tpy) 0.043 0.169 0.235 0.131 0.373 0.439 0.508 0.272 0.936 Cost effectiveness ($/ton) 44,408 10,662 7,408 14,029 4,323 3,543 2,935 6,276 1,181

Model C Total capital investment ($) 18,170 18,170 18,170 18,170 18,170 18,170 18,170 18,170 18,170 Total annual cost ($/yr) 2,657 2,467 2,366 2,524 2,157 2,310 2,059 1,952 1,303
Emission reduction (tpy) 0.073 0.28 0.40 0.22 0.63 0.46 0.74 0.86 1.58 Cost effectiveness ($/ton) 36,642 8,701 5,991 11,500 3,434 5,056 2,796 2,282 826TABLE C.3
Impacts for Control Option ST6 for model storage vessels with unslotted guidepoles
Xylene Toluene MM Formic acid Isooctane MEK Benzene MeOH Hexane Chloroform

Model A Incremental total capital investment ($) 1,350 1,350 1,350 1,350 1,350 1,350 1,350 1,350 1,350 1,350 Incremental total annual cost ($/yr) 94 (334) (545) (213) (985) (1,195) (1,416) (663) (2,779) (5,228)
Incremental emission reduction (tpy) 0.154 0.60 0.83 0.46 1.32 1.55 1.80 0.96 3.31 6.03 Incremental cost effectiveness ($/ton) 612 (561) (656) (462) (747) (770) (788) (690) (839) (866)

Model B Incremental total capital investment ($) 1,350 1,350 1,350 1,350 1,350 1,350 1,350 1,350 1,350 Incremental total annual cost ($/yr) 65 (334) (545) (213) (985) (1,195) (1,416) (663) (2,779)
Incremental emission reduction (tpy) 0.153 0.60 0.83 0.46 1.32 1.55 1.80 0.96 3.31 Incremental cost effectiveness ($/ton) 422 (560) (656) (462) (747) (770) (788) (690) (839)

Model C Incremental total capital investment ($) 1,350 1,350 1,350 1,350 1,350 1,350 1,350 1,350 1,350 Incremental total annual cost ($/yr) 65 (334) (545) (213) (985) (604) (1,168) (1,502) (2,779)
Incremental emission reduction (tpy) 0.153 0.60 0.83 0.46 1.32 0.90 1.52 1.89 3.31 Incremental cost effectiveness ($/ton) 422 (561) (656) (462) (747) (674) (767) (793) (839)TABLE C.4
Impacts for Control Option ST6 for model storage vessels with slotted guidepoles
Xylene Toluene MM Formic acid Isooctane MEK Benzene MeOH Hexane Chloroform

Model A Incremental total capital investment ($) 2,650 2,650 2,650 2,650 2,650 2,650 2,650 2,650 2,650 2,650 Incremental total annual cost ($/yr) 186 (544) (914) (332) (1,687) (2,056) (2,443) (1,121) (4,836) (9,133)
Incremental emission reduction (tpy) 0.27 1.05 1.46 0.81 2.32 2.73 3.16 1.69 5.81 10.6 Incremental cost effectiveness ($/ton) 694 (521) (628) (410) (729) (754) (774) (665) (832) (863)

Model B Incremental total capital investment ($) 3,250 3,250 3,250 3,250 3,250 3,250 3,250 3,250 3,250 Incremental total annual cost ($/yr) 245 (455) (824) (242) (1,597) (1,966) (2,353) (1,031) (4,746)
Incremental emission reduction (tpy) 0.27 1.05 1.46 0.81 2.32 2.73 3.16 1.69 5.81 Incremental cost effectiveness ($/ton) 910 (435) (566) (299) (690) (721) (746) (611) (816)

Model C Incremental total capital investment ($) 5,350 5,350 5,350 5,350 5,350 5,350 5,350 5,350 5,350 Incremental total annual cost ($/yr) 560 (140) (509) 72 (1,282) (643) (1,618) (2,146) (4,431)
Incremental emission reduction (tpy) 0.27 1.05 1.46 0.81 2.32 1.61 2.69 3.27 5.81 Incremental cost effectiveness ($/ton) 2,085 (134) (350) 89 (554) (602) (655) (401) (762)TABLE C.5
Impacts for Control Option ST7 for model storage vessels with unslotted guidepoles
Xylene Toluene MM Formic acid Isooctane MEK Benzene MeOH Hexane Chloroform

Model A Incremental total capital investment ($) 26,573 26,573 26,573 26,573 26,573 26,573 26,573 26,573 26,573 26,573 Incremental total annual cost ($/yr) 3,944 3,956 3,947 3,962 3,926 3,917 3,908 3,941 3,845 3,735
Incremental emission reduction (tpy) 0.006 0.027 0.0375 0.021 0.060 0.0705 0.081 0.0435 0.15 0.273 Incremental cost effectiveness ($/ton) 657,404 146,523 105,245 188,644 65,440 55,560 48,241 90,604 25,636 13,680

Model B Incremental total capital investment ($) 28,959 28,959 28,959 28,959 28,959 28,959 28,959 28,959 28,959 Incremental total annual cost ($/yr) 4,331 4,309 4,298 4,316 4,275 4,264 4,252 4,292 4,181
Incremental emission reduction (tpy) 0.0080 0.0315 0.044 0.0245 0.0695 0.082 0.095 0.0505 0.175 Incremental cost effectiveness ($/ton) 541,331 136,809 97,687 176,155 61,515 52,001 44,762 84,998 23,959

Model C Incremental total capital investment ($) 39,774 39,774 39,774 39,774 39,774 39,774 39,774 39,774 39,774 Incremental total annual cost ($/yr) 5,947 5,917 5,900 5,926 5,867 5,850 5,833 5,891 5,728
Incremental emission reduction (tpy) 0.012 0.046 0.064 0.036 0.10 0.12 0.14 0.074 0.26 Incremental cost effectiveness ($/ton) 495,597 130,044 92,193 164,599 57,799 48,957 42,118 79,613 22,419TABLE C.6
Impacts for Control Option ST7 for model storage vessels with slotted guidepoles
Xylene Toluene MM Formic acid Isooctane MEK Benzene MeOH Hexane Chloroform

Model A Incremental total capital investment ($) 26,573 26,573 26,573 26,573 26,573 26,573 26,573 26,573 26,573 26,573 Incremental total annual cost ($/yr) 3,939 3,939 3,923 3,948 3,889 3,872 3,856 3,914 3,751 3,562
Incremental emission reduction (tpy) 0.0115 0.046 0.064 0.0355 0.102 0.12 0.139 0.074 0.255 0.465 Incremental cost effectiveness ($/ton) 342,524 85,631 61,294 111,225 38,316 32,270 27,840 52,890 14,710 7,669

Model B Incremental total capital investment ($) 28,959 28,959 28,959 28,959 28,959 28,959 28,959 28,959 28,959 Incremental total annual cost ($/yr) 4,327 4,293 4,275 4,303 4,237 4,220 4,201 4,264 4,086
Incremental emission reduction (tpy) 0.013 0.050 0.070 0.039 0.11 0.13 0.15 0.082 0.28 Incremental cost effectiveness ($/ton) 346,128 85,857 61,069 110,327 38,004 32,213 27,638 52,325 14,592

Model C Incremental total capital investment ($) 39,774 39,774 39,774 39,774 39,774 39,774 39,774 39,774 39,774 Incremental total annual cost ($/yr) 5,943 5,899 5,877 5,913 5,829 5,782 5,863 5,806 5,634
Incremental emission reduction (tpy) 0.017 0.065 0.0905 0.0505 0.144 0.196 0.105 0.169 0.36 Incremental cost effectiveness ($/ton) 349,569 90,761 64,934 117,080 40,619 29,576 55,843 34,354 15,650TABLE C.7
Impacts for Model Petroleum Products Storage Vessels

Model Model Model Model Model Model

D E F G H I
Control Option ST5
Models with unslotted guidepoles Total capital investment ($) 44,889 67,956 29,897 67,956 36,685 57,461 Total annual cost ($/yr) 5,712 8,366 1,448 455 4,247 6,249
Emission reduction (tpy) 2.02 3.63 6.06 19.45 2.50 4.72 Cost effectiveness ($/ton) 2,822 2,307 239 23 1,701 1,325
Models with slotted guidepoles Total capital investment ($) 44,889 67,956 29,897 67,956 36,685 57,461 Total annual cost ($/yr) 5,712 8,366 1,448 455 4,247 6,249
Emission reduction (tpy) 2.02 3.63 6.06 19.45 2.50 4.72 Cost effectiveness ($/ton) 2,822 2,307 239 23 1,701 1,325
Control Option ST6
Models with unslotted guidepoles Incremental total capital investment ($) 1,350 1,350 1,350 1,350 1,350 1,350 Incremental total annual cost ($/yr) (365) (365) (2,838) (2,838) (730) (730)
Incremental emission reduction (tpy) 1.13 1.13 6.08 6.08 1.86 1.86 Incremental cost effectiveness ($/ton) (322) (322) (467) (467) (392) (392)
Models with slotted guidepoles Incremental total capital investment ($) 6,400 6,400 6,400 6,400 6,400 6,400 Incremental total annual cost ($/yr) (36) (36) (4,377) (4,377) (677) (677)
Incremental emission reduction (tpy) 1.99 1.99 10.67 10.67 3.27 3.27 Incremental cost effectiveness ($/ton) (18) (18) (410) (410) (207) (207)
Control Option ST7
Models with unslotted guidepoles Incremental total capital investment ($) 236,086 688,797 92,161 688,797 145,063 443,192 Incremental total annual cost ($/yr) 35,214 102,902 13,336 101,696 21,542 66,033
Incremental emission reduction (tpy) 0.301 0.552 0.939 2.964 0.376 0.710 Incremental cost effectiveness ($/ton) 116,990 186,417 14,202 34,310 57,292 93,004
Models with slotted guidepoles Incremental total capital investment ($) 236,086 688,797 92,161 688,797 145,063 443,192 Incremental total annual cost ($/yr) 35,196 102,884 13,239 101,600 21,512 66,003
Incremental emission reduction (tpy) 0.337 0.588 1.133 3.157 0.436 0.770 Incremental cost effectiveness ($/ton) 104,439 174,973 11,690 32,182 49,396 85,774[this page intentionally left blank]

### Attachment D: Nationwide Impacts for Storage Vessels at Petroleum Refineries[this page intentionally left blank]Model size 2 Model vapor

pressure 3 Nationwide

number of Tanks 4 Nationwide VOC

emissions reduction (tpy) Nationwide total capital investment ($) 5 Nationwide total

annual costs

without VOC recovery credit ($/yr) Nationwide

VOC credit $/yr 6 Nationwide total

annual costs with VOC recovery credit ($/yr)

External floating roof

Slotted guidepole Small low 13 35.7 83,200 12,463 17,843 (5,379)

Slotted guidepole Small medium 19 136 121,600 18,216 68,025 (49,809)

Slotted guidepole Small high 19 257 121,600 18,216 128,393 (110,177)

Slotted guidepole Small very high 7 151 44,800 6,711 75,460 (68,749)

Slotted guidepole Medium low 23 63.2 147,200 22,051 31,579 (9,528)

Slotted guidepole Medium medium 84 602 537,600 80,532 300,804 (220,272)

Slotted guidepole Medium high 94 1,271 601,600 90,120 635,323 (545,203)

Slotted guidepole Medium very high 60 1,293 384,000 57,523 646,275 (588,752)

Slotted guidepole Large low 4 11.0 25,600 3,835 5,487 (1,652)

Slotted guidepole Large medium 42 87.4 268,800 40,266 43,680 (3,414)

Slotted guidepole Large high 55 771 352,000 52,730 385,688 (332,958)

Slotted guidepole Large very high 22 492 140,800 21,092 245,960 (224,868)

Slotted guidepole Extra Large low 0 0 0 0 0 0

Slotted guidepole Extra Large medium 10 71.6 94,000 14,081 35,800 (21,719)

Slotted guidepole Extra Large high 3 40.6 28,200 4,224 20,276 (16,052)

Slotted guidepole Extra Large very high 1 21.6 9,400 1,408 10,775 (9,367)

Solid guidepole Small low 37 56.5 49,950 7,483 28,259 (20,776)

Solid guidepole Small medium 59 235.1 79,650 11,932 117,572 (105,641)

Solid guidepole Small high 31 233.2 41,850 6,269 116,599 (110,330)

Solid guidepole Small very high 17 204.2 22,950 3,438 102,085 (98,647)

Solid guidepole Medium low 58 88.7 78,300 11,729 44,327 (32,597)

Solid guidepole Medium medium 220 877 297,000 44,491 438,460 (393,969)

Solid guidepole Medium high 174 1,309 234,900 35,188 654,458 (619,269)

Solid guidepole Medium very high 90 1,079 121,500 18,201 539,663 (521,462)

Solid guidepole Large low 19 29.0 25,650 3,842 14,488 (10,645)

Solid guidepole Large medium 78 92.8 105,300 15,774 46,410 (30,636)

Solid guidepole Large high 42 337 56,700 8,494 168,630 (160,136)

Solid guidepole Large very high 14 179 18,900 2,831 89,670 (86,839)

Solid guidepole Extra Large low 1 1.53 1,350 202 764 (562)

Solid guidepole Extra Large medium 12 47.8 16,200 2,427 23,910 (21,483)

Solid guidepole Extra Large high 6 45.1 8,100 1,213 22,568 (21,354)

Solid guidepole Extra Large very high 5 60.0 6,750 1,011 30,000 (28,989)

Controlled guidepole Small low 23 0.98 9,200 1,378 489 889

Controlled guidepole Small medium 42 4.73 16,800 2,517 2,363 154

Controlled guidepole Small high 18 3.87 7,200 1,079 1,935 (856)

Controlled guidepole Small very high 23 7.94 9,200 1,378 3,968 (2,589)

Controlled guidepole Medium low 52 2.26 20,800 3,116 1,131 1,985

Controlled guidepole Medium medium 154 17.2 61,600 9,228 8,624 604 Type of storage vessel 1Model size 2 Model vapor

pressure 3 Nationwide

number of Tanks 4 Nationwide VOC

emissions reduction (tpy) Nationwide total capital investment ($) 5 Nationwide total

annual costs

without VOC recovery credit ($/yr) Nationwide

VOC credit $/yr 6 Nationwide total

annual costs with VOC recovery credit ($/yr) Type of storage vessel 1

Controlled guidepole Medium high 195 41.4 78,000 11,684 20,719 (9,034)

Controlled guidepole Medium very high 202 69.2 80,800 12,104 34,593 (22,489)

Controlled guidepole Large low 18 0.72 7,200 1,079 360 719

Controlled guidepole Large medium 94 9.87 37,600 5,632 4,935 697

Controlled guidepole Large high 97 69.8 38,800 5,812 34,920 (29,108)

Controlled guidepole Large very high 70 81.2 28,000 4,194 40,600 (36,406)

Controlled guidepole Extra Large low 6 0.26 2,400 360 132 228

Controlled guidepole Extra Large medium 22 2.48 8,800 1,318 1,238 81

Controlled guidepole Extra Large high 19 4.04 7,600 1,138 2,019 (880)

Controlled guidepole Extra Large very high 8 2.80 3,200 479 1,400 (921)

Totals for External Floating Roofs: 2,362 10,500 4,542,650 680,000 5,249,000 (4,568,000)

Internal floating roof

Slotted guidepole Small low 39 4.19 120,900 18,111 2,096 16,015

Slotted guidepole Small medium 75 20.7 232,500 34,829 10,350 24,479

Slotted guidepole Small high 43 22.3 133,300 19,968 11,126 8,842

Slotted guidepole Small very high 32 26.6 99,200 14,860 13,280 1,580

Slotted guidepole Medium low 22 4.29 152,900 22,904 2,145 20,759

Slotted guidepole Medium medium 68 34.7 472,600 70,795 17,340 53,455

Slotted guidepole Medium high 61 59.2 423,950 63,508 29,585 33,923

Slotted guidepole Medium very high 35 54.3 243,250 36,439 27,125 9,314

Slotted guidepole Large low 8 2.69 104,000 15,579 1,344 14,235

Slotted guidepole Large medium 13 11.5 169,000 25,316 5,753 19,564

Slotted guidepole Large high 23 38.5 299,000 44,790 19,263 25,528

Slotted guidepole Large very high 20 52.7 260,000 38,948 26,350 12,598

Slotted guidepole Extra Large low 0 0 0 0 0 0

Slotted guidepole Extra Large medium 2 2.99 45,800 6,861 1,495 5,366

Slotted guidepole Extra Large high 3 8.45 68,700 10,291 4,223 6,069

Slotted guidepole Extra Large very high 0 0 0 0 0 0

Solid guidepole Small low 54 5.18 145,800 21,841 2,592 19,249

Solid guidepole Small medium 89 22.0 240,300 35,997 10,992 25,005

Solid guidepole Small high 45 20.3 121,500 18,201 10,125 8,076

Solid guidepole Small very high 25 18.6 67,500 10,112 9,313 799

Solid guidepole Medium low 38 7.03 248,900 37,285 3,515 33,770

Solid guidepole Medium medium 89 43.2 582,950 87,326 21,583 65,743

Solid guidepole Medium high 68 62.2 445,400 66,721 31,110 35,611

Solid guidepole Medium very high 31 45.3 203,050 30,417 22,630 7,787

Solid guidepole Large low 3 0.98 37,800 5,662 488 5,175

Solid guidepole Large medium 8 6.84 100,800 15,100 3,420 11,680Model size 2 Model vapor

pressure 3 Nationwide

number of Tanks 4 Nationwide VOC

emissions reduction (tpy) Nationwide total capital investment ($) 5 Nationwide total

annual costs

without VOC recovery credit ($/yr) Nationwide

VOC credit $/yr 6 Nationwide total

annual costs with VOC recovery credit ($/yr) Type of storage vessel 1

Solid guidepole Large high 6 9.72 75,600 11,325 4,860 6,465

Solid guidepole Large very high 2 5.17 25,200 3,775 2,585 1,190

Solid guidepole Extra Large low 0 0 0 0 0 0

Solid guidepole Extra Large medium 0 0 0 0 0 0

Solid guidepole Extra Large high 0 0 0 0 0 0

Solid guidepole Extra Large very high 0 0 0 0 0 0

Controlled guidepole Small low 28 2.10 49,000 7,340 1,050 6,290

Controlled guidepole Small medium 74 14.1 129,500 19,399 7,030 12,369

Controlled guidepole Small high 58 20.9 101,500 15,205 10,440 4,765

Controlled guidepole Small very high 40 23.2 70,000 10,486 11,600 (1,114)

Controlled guidepole Medium low 24 3.96 134,400 20,133 1,980 18,153

Controlled guidepole Medium medium 72 31.0 403,200 60,399 15,480 44,919

Controlled guidepole Medium high 71 57.5 397,600 59,560 28,755 30,805

Controlled guidepole Medium very high 59 75.2 330,400 49,494 37,613 11,881

Controlled guidepole Large low 1 0.31 11,650 1,745 153 1,593

Controlled guidepole Large medium 5 4.00 58,250 8,726 2,000 6,726

Controlled guidepole Large high 3 4.50 34,950 5,236 2,250 2,986

Controlled guidepole Large very high 20 48.2 233,000 34,903 24,100 10,803

Controlled guidepole Extra Large low 0 0 0 0 0 0

Controlled guidepole Extra Large medium 0 0 0 0 0 0

Controlled guidepole Extra Large high 0 0 0 0 0 0

Controlled guidepole Extra Large very high 0 0 0 0 0 0

Totals for Internal Floating Roofs: 1,357 874 7,073,000 1,060,000 437,100 622,500

Nationwide Totals: 3,719 11,400 11,616,000 1,740,000 5,686,000 (3,946,000)

1

2

3

4

5

6 Assumed all storage vessels need additional deck fitting controls as specified in Tables 4 and 6 for Control Options ST2 and ST6, except additional guidepole controls are not included for

storage vessels that currently have controlled guidepoles. Costs for these controls were based on the information in Tables 12 and 13 of this memorandum.

Assumed a VOC recovery credit of $500/ton. Assumed all solid guidepoles currently are equipped with an ungasketed deck cover. Controlled guidepoles are slotted guidepoles that meet regulatory requirements like those in 40 CFR
part 63, subpart WW.

The small model represents storage vessels with capacities less than 1 million gallons, the medium model represents storage vessels with capacities of 1 million gallons to less than 6 million
gallons, the large model represents storage vessels with capacities of at least 6 million gallons to less than 17 million gallons, and the very large model represents storage vessels with
capacities of 17 million gallons or greater. The model sizes are 450,000 gal; 3,300,000 gal; 8,000,000 gal; and 22,000,000 gal.

Model vapor pressures are based on methyl ethyl ketone, gasoline (RVP 6), gasoline (RVP 10), and gasoline (RVP 14). The low, medium, high, and very high models represent materials
with vapor pressures of 0.7 psia to 1.9 psia, >1.9 psia to 5 psia, >5 psia to 8 psia, and >8 psia, respectively.

The number of storage vessels meeting the model guidepole, size, and vapor pressure criteria are based on information in the Refineries ICR database (U.S. EPA, 2011). This analysis
excluded wastewater storage vessels and storage vessels for which no vapor pressure was reported. Storage vessels without a reported size were represented with the appropriate small
model storage vessel.