1 

Technical Memorandum 

TO: EPA Docket No. EPA-HQ-OAR-2010-0682 

 

FROM: Brenda Shine, Environmental Engineer 

 Refining and Chemicals Group, SPPD (E143-01) 

DATE: January 17, 2014 

SUBJECT: Fenceline Monitoring Technical Support Document 

I. Purpose 

The objective of this document is to provide cost information and other technical 

information regarding the implementation of a fenceline monitoring and corrective action 

program at petroleum refineries. 

II. Background 

Certain emissions sources, such as fugitive leaks from equipment and wastewater 

collection and treatment systems, are inherently difficult to quantify with methods currently 

available. In general, uncertainties in emissions estimates are related to the omission or 

mischaracterization of significant emission sources; among them are: 

 Exclusion of nonroutine emissions 

 Omission of sources that are unexpected, not measured, or not considered part of the 

affected source, such as emissions from process sewers, wastewater systems, or other 

fugitive emissions 

 Improper characterization of sources for emission models and emission factors 

 Inherent uncertainty in emissions estimation methodologies 

In 2010, the EPA undertook an extensive information collection effort focused on 

sending an information collection request (ICR) to all domestic refineries. The ICR was 

accompanied by an emission estimation protocol which was intended to provide consistent 

requirements for generating emission inventories. Our review of the information submitted 

through the ICR process reveals many gaps in emissions information. For example, in spite of 

the detailed protocol that was developed to address gaps in emissions inventories and the 

methodologies used to determine emissions, many refineries did not report their emissions 
2 

according to the protocol. In one such instance, approximately 20% of the major source 

refineries did not report any emissions from wastewater collection and treatment systems. This 

notable gap was in spite of detailed guidance and model spreadsheet made available to assess 

these emissions. 

Recent emission studies show differences between facility emission reporting, the 

modeling of that data, and the actual measured concentrations. A study in 2010, funded by an 

EPA grant to the City of Houston, evaluated differential absorption LIDAR (DIAL) testing of 

benzene and VOC at Shell’s Deer Park Refinery and Chemical Plant.1 The purpose of the study 

was to obtain more information regarding the accuracy of emission factors and emission 

estimating methods. The DIAL study measured emissions from various process areas. The 

results pointed to significant differences between emission estimate method results and actual 

emissions data collected, with measured results most commonly far greater than estimated. 

Similar results were also found in 2008, when a DIAL test was conducted at the BP Texas City 

Refinery. Among the findings, emissions from tanks were found to be higher than estimates 

calculated from emissions factors.2

Evidence regarding the underestimation of VOC and HAP emissions has been reported in 

the past. Of note is the Texas Air Quality Study-2000, where ambient concentrations of highly 

reactive VOC were found to be 10 to 1000 times greater than were reported in the Texas 

emission inventory for that year. In another study, the NARSTO Emission Inventory 

Assessment concluded that reported VOC emissions should be multiplied six fold before models 

and ambient measurements correlated.3 Finally, the EPA’s Office of Inspector General, in a 

March 22, 2006 report specifically recognized that the problem of underreporting of VOC and 

HAP emissions from the refining sector and concurred with the Agency shifting towards more 

direct, continuous monitoring and measurement of emissions from all major sources.4 

 

1 Loren Raun and Dan W. Hoyt, Bureau of Pollution Control and Prevention City of Houston, Measurement and Analysis of 

Benzene and VOC Emissions in the Houston Ship Channel Area and Selected Surrounding Major Stationary Sources Using 

DIAL (Differential Absorption Light Detection and Ranging) Technology to Support Ambient HAP Concentrations 

Reductions in the Community (DIAL Project), July 20, 2011. 

2 USEPA. Critical Review of DIAL Emission Test Data for BP Petroleum Refinery in Texas City, Texas. EPA 453/R-10-002. 

December 2010. 

3 Improving Emission Inventories for Effective Air Quality Management Across North America. NARSTO 05-001. August 

2005. 

4 Office of Inspector General Report. Report No. 2006-P-00017. EPA CAN Improve Emission Factors Development and 

Management. March 22,, 2006. 
3 

 In 2009, the EPA conducted a year-long diffusive tube monitoring pilot project at the 

fenceline of Flint Hills West Refinery in Corpus Christi. As a result of the year-long fenceline 

monitoring pilot project at Flint Hills West Refinery in Corpus Christi, we found the diffusive 

tube monitoring technology to be capable of providing cost-effective, relatively robust 

monitoring data. The technology was implementable by modestly trained personnel and 

provided useful information on overall concentration levels and source identification using 

simple upwind and downwind comparisons. This memorandum provides guidance and impact 

estimates for fenceline diffusive tube monitoring. 

III. Fenceline Monitoring - Monitor Selection and Placement Guidance 

A. Monitoring Options 

One of the primary constituents of concern from petroleum refinery emission sources is 

benzene. Since the primary releases of benzene are fugitive emissions from process equipment, 

wastewater treatment, storage tanks, and loading operations, the releases generally occur near 

ground level. Thus, the highest fenceline benzene concentrations outside the facility will likely 

occur near the property boundary near ground level. Consequently, ambient air monitoring at the 

property boundary (fenceline) will provide a direct measure of the annual average benzene 

concentrations directly surrounding the refinery. 

EPA reviewed the available literature and identified several different methods for 

measuring fugitive emissions around the fenceline of a petroleum refinery. These methods 

include: (1) passive diffusive tube monitoring networks; (2) active monitoring station networks; 

(3) open path monitoring systems, such as those described in EPA’s Other Test Method 10 

(OTM-10).5 Diffusive tube monitoring for benzene has been demonstrated in a European study 

of refineries. The International Organization for Standardization (ISO) has finalized a standard 

method for diffusive sampling (ISO/FDIS 16017-2).6 Diffusive tube monitoring requires less 

equipment and allows samples to be collected over longer time periods (due to the lower 

sampling rates) than conventional, actively-pumped monitoring stations, which lowers costs, but 

it does not provide the time resolution of emissions like active or open path monitoring systems. 

 

5 “Optical Remote Sensing for Emission Characterization from Non-Point Sources.” Final ORS Protocol, June 14, 2006. 

Available at: http://www.epa.gov/ttn/emc/prelim/otm10.pdf. 

6 “Indoor, ambient and workplace air – Sampling and analysis of volatile organic compounds by sorbent tube/thermal 

desorption/capillary gas chromatography – Part 2: Diffusive Sampling.” International Standard ISO/FDIS 16017-2. 2003. 
4 

Diffusive tube monitoring can be performed with minimal operator training, whereas open path 

monitoring systems employs complex equipment and specially trained personnel to operate. 

Subsections B through D provides more detail regarding the diffusive tube monitoring approach 

and Subsection E provides considerations for citing monitoring stations for fenceline monitoring 

(applicable to both passive diffusive tube and actively-pumped monitoring stations). This detail 

is needed to project the costs of the monitoring systems, and the costs estimates for the three 

monitoring options are provided in Subsection F. 

B. Sorbent Selection 

Diffusive tube sampling can be used to assess the ambient concentration of a wide variety 

of organic compounds. The primary focus of the ambient air monitoring approach is on benzene 

due to its prominence in overall refinery emissions, particularly from fugitive sources. To this 

end, the EPA has developed draft Method 325A and 325B, Volatile Organic Compounds from 

Fugitive and Area Sources: Sampler Deployment and VOC Sample Collection (Method 325A) 

and Sampler Preparation and Analysis (325B), which is applicable to analysis of a number of 

volatile organic compounds, including benzene. The method provides a quality assurance 

evaluation procedure for the use of a number of sorbents and tube dimensions, but also provides 

for use of specific sorbent tubes (4.9 square mm with an internal diffusion cavity gap of 1.5 cm) 

and sorbent (packed with 40/60 or 60/80 mesh Carbopack X) without further evaluation, since 

the diffusive uptake rates on these specific tubes have been shown to perform within the data 

quality objectives outlined in the draft method. 

C. Diffusive Tube Monitoring Frequency 

Method 325A requires that the sampling tubes be changed every two weeks at 

approximately the same time of day from each of the monitoring sites. This monitoring 

frequency was selected for several reasons. A two-week sampling frequency is the frequency 

that has been used in most diffusive tube monitoring applications. As such, there are more data 

regarding the effective sampling rate for passive diffusive tube samplers at this frequency, 

reducing the uncertainty in the measured concentrations. Monitoring more frequently, such as 

changing and analyzing each tube weekly, can be used to achieve greater time resolution of 

samples. However, a weekly monitoring frequency increases the cost of the monitoring 

program. Additionally, the shorter time period associated with more frequent sampling leads to 
5 

smaller sample volumes, which increase the likelihood of having detection limited results if the 

ambient concentrations are low. Sampling less frequently, for example monthly or every four 

weeks, is not recommended unless the ambient concentrations are known to be low. The 

effective sampling rate of the diffusive tube monitor begins to decrease with longer sampling 

times and there is variability in this decrease depending on the ambient concentration. This leads 

to increased uncertainty regarding the measured ambient concentration for monthly monitoring. 

Additionally, saturation of the sorbent tube is more likely to occur during long sampling periods, 

which would create a low bias in the results if the ambient concentrations are high. As ambient 

concentrations at the fenceline of a refinery are expected to be moderate and variable (changing 

with process operations and wind direction), a four-week sampling time is not appropriate. A 

two-week sampling frequency provides the best combination of low cost and high measurement 

accuracy, and is therefore recommended for most diffusive tube sampling applications. 

D. Diffusive Tube Monitor Description 

 Diffusive tube monitors are tubes packed with sorbent material. Glass wool or similar 

material is used to keep the sorbent in-place. The tubes are transported with brass end-caps, 

which are used to seal the tubes. During sampling, one of the brass end caps is replaced with a 

diffusion cap, which allows ambient air to diffuse into the tube at relatively steady rates. 

 Method 325A describes placement requirements for the diffusive tube samplers. The 

diffusive tube samples should be placed at a height of 5 to 6 feet (typical adult exposure height). 

The diffusive tubes can be attached by brackets to a support structure. The tubes should be 

oriented vertically downward to avoid ingress of particulates. The tubes should also be protected 

from the weather using some type of protective hood. The primary purpose of this weather hood 

is to prevent precipitation or snow from blocking the sampling surface (openings in the diffusion 

end-cap). It also helps to prevent solar heating of the tube (higher temperatures reduce the 

sorption capacity of the sorbent). A simple weather protector consists of an inverted cone/funnel 

that fits tightly around the diffusive tube with the open (sampling) end of the tube barely visible 

from the cone opening as seen in Figure 1. 
6 

Figure 1. Sampling Monitor with Weather Protector 

E. Monitor Placement 

The number and placement of the monitors will be dependent on the size and shape of the 

facility. It may also depend on the proximity of potential emission sources to the property 

boundaries, the proximity of receptors along the property boundary, and the prevailing wind 

direction. Method 325A provides guidance on the placement of monitors. In developing 

Method 325A, aerial photographs were studied and a variety of different placement protocols 

were evaluated (e.g., placement of monitors at 15, 20, and 30 degree angles). Generally, the 

placement of the monitors is prescribed at different angles based on the size of the area (or 

subarea). At the facility, these horizontal and vertical angles can be measured using an 

instrument such as a theodolite. 

1. Facilities with a Regular (Circular, Triangular, Rectangular, or Square) Shape 

Facilities that have a common shape and whose area can reasonably encompass a circle 

should apply the below steps for proper monitor placement: 

(1.) Determine the center point of the facility. 

(2.) If the facility has crude refining capacity of less than 125,000 barrels per day (less than 

750 acres) the facility would fall into the small size category and would measure from 

the center point angles of 30 degrees for a total of twelve 30 degree measurements. 
7 

(3.) If the facility has crude refining capacity greater than or equal to 125,000 and less than 

225,000 barrels per day (greater than or equal to 750 acres but less than 1,500 acres) 

would fall into the medium size category and would measure from the center point 

angles of 20 degrees for a total of eighteen 20 degree measurements. 

(4.) If the facility has crude refining capacity greater than or equal to 225,000 barrels per 

day (greater than or equal to 1,500 acres) would fall into the large size category and 

would measure from the center point angles of 15 degrees for a total of twenty-four 15 

degree measurements. 

(5.) Place monitors secured by a 6-foot pole at each point where the measured angle 

intersects the property boundary. Please note that a facility may have more than 12, 

18, or 24 monitors if the measured angle intersects more than one point along the 

property boundary. In this case, a monitor needs to be placed at each point of 

intersection. 

(6.) In the case that a source is within 50 meters of the property boundary and the source 

location is between two monitors, measure the distance (x) between the two monitors 

and place another monitor halfway between (x/2) the two monitors. 

 Figure 2 shows the monitor placement around the property boundary of a facility whose 

area is between 750 and 1,500 acres. As prescribed above, the facility measured from the 

property center angles of 20 degrees, which required 18 monitor placements. Monitor 

placements are represented with black dots along the property boundary. Per Method 325A (step 

6 above), the facility also added three additional monitors (gray shaded) to provide sufficient 

coverage of all area sources. 
8 

Figure 2. Refinery with a Regular Shape 

2. Facilities with an Irregular Shape 

In the case that the facility has an irregular shape such as an arc, half circle, or the facility 

can be broken down into different shapes (i.e., two connecting rectangles), the facility should 

then be broken up into subareas. The subareas should be such that a circle can be reasonably 

encompassed by the subarea. Facilities should apply the below steps for proper monitor 

placement: 

(1.) Determine the center point of each subarea. 

(2.) If your subarea falls into the small category, measure from the center point angles of 

30 degrees for a total of twelve 30 degree measurements. 

(3.) If the subarea is in the medium category, measure from the center point angles of 20 

degrees for a total of eighteen 20 degree measurements. 

(4.) If the subarea is in the large category, measure from the center point angles of 15 

degrees for a total of twenty-four 15 degree measurements. 

(5.) Place monitors secured by a 6-foot pole at each point where the measured angle 

intersects the outer property boundary. If the measured angle intersects the inner 

boundary of an adjacent subarea, do not place a monitor in this case. However, if the 
9 

measured angle intersects more than one point along the subarea’s outer boundary, a 

monitor needs to be placed at each point of intersection. 

(6.) In the case that a source is within 50 meters of the subarea’s property boundary and 

the source location is between two monitors, measure the distance (x) between the two 

monitors and place another monitor halfway between (x/2) the two monitors. 

Figures 3 and 4 demonstrate how to apply the above techniques. Figure 3 shows an 

example of where the facility’s area is comprised of two distinct shapes. As a result, the area is 

divided into two subareas. The first subarea whose area is between 750 and 1,500 acres requires 

measuring 20 degree angles to determine monitor placement. Since the second subarea has an 

area of less than 750 acres, monitor placement is based on the measurement of angles of 

30 degrees. Figure 4 shows a facility whose area is arc shaped. In order to provide sufficient 

monitoring coverage, this facility was divided into three subareas. Each subarea is less than 

750 acres. Therefore, monitor placement for each subarea is based on making 30 degree 

measurements. 

Figure 3. Refinery Divided into Two Subareas 
10 

Figure 4. Refinery Divided into Three Subareas 

F. Fenceline Monitoring Costs 

1. Approach for Developing Monitoring Costs for Passive Diffusive Tube Monitoring 

Costs for the monitoring program vary depending on the number of sample points and 

whether or not the refinery chooses to conduct in-house analysis of samples rather than outsource 

the analysis of samples. The analysis of the diffusive tube samples is relatively straight-forward 

and automated systems are available so that the analyses can be performed with minimal manhours. Therefore, many refiners may opt to conduct analysis in-house. 

Average annual costs were estimated for a ten year period (as the useful life of the 

analytical equipment is expected to be 10 years according to the analytical equipment 

manufacturer representatives). The initial costs include the cost of purchasing and installing the 

monitoring stations, collecting the samples, and performing the analyses for the first year. The 

initial costs include the cost of purchasing a GC (with FID detector), a thermal desorption unit 

with an autosampler, and the diffusive tubes and caps. Analytical equipment cost estimates were 

developed from vendor quotes. These quotes included both the cost of the analytical equipment 
11 

and materials (diffusive tubes, end-caps, etc.) as well as man-hour estimates for performing the 

analyses. Recurring costs include the cost (man-hours) for collecting the samples, and the cost 

of analyzing the samples (and any materials consumed). 

Costs were developed for three different sizes of facilities: 

1) Small model plants with fenceline monitors at angles of 30 degree = 12 fenceline 

monitoring locations. 

2) Medium model plants with fenceline monitors at angles of 20 degree = 18 fenceline 

monitoring locations 

3) Large model plants with fenceline monitors at angles of 15 degree = 24 fenceline 

monitoring locations 

For each model plant, cost estimates were developed assuming that the facility purchased 

the necessary analytical equipment and performed the analyses in-house and separate cost 

estimates were developed assuming that the facility outsourced all sample analyses. Some 

facilities may have an existing GC and may only need to purchase the automated desorption tube 

sampler system, but all facilities were assumed to purchase both in order to perform the in-house 

analysis in order to project reasonable worst-case capital cost estimates. 

Table 1 presents a summary of capital and annualized costs per model refinery for inhouse and outsourced analysis. Attachments 1 through 6 of this memorandum present the 

detailed cost estimates for the in-house and outsourced analyses for each model plant. 

Table 1. Model Plant Costs (in 2009$) for Fenceline Monitoring 

Model Plant 

Capital Costs, $ Annualized Costs, $/yr 

In-house 

Analysis 

Outsourced 

Analysis 

In-house 

Analysis 

Outsourced 

Analysis 

Small 85,440 21,370 36,300 64,200 

Medium 86,650 22,580 41,000 86,900 

Large 88,270 23,960 45,900 109,700 

2. Approach for Developing Monitoring Costs for Active Monitoring Stations 

For comparative purposes, the costs for employing active monitoring stations were also 

assessed. The location and number of monitoring stations were assumed to be the same as for 
12 

the passive monitoring system. Most of the capital costs for the active monitoring system are 

identical to that for the passive monitoring system, except that each site would require a 

sampling pump (estimated to cost $2,000 each) and a more substantial sampling system weather 

protector/shelter (estimated to cost $1,000 each). A power supply would be needed to run each 

sampling pump. It was assumed power was available for each monitoring location. If power 

supply was not available, either a battery operated pump could be used or electrical power would 

need to be installed for each site, which could significantly raise the capital costs of each 

monitoring station. 

 The primary difference in the annual operating costs for the active system is the more 

frequent sample collection. Typically, active sampling systems are used to collect a daily 

sample. To minimize the number of samples collected, it is common for active sampling 

systems to collect one sample every other of every third day, but to compare with the continual 

sampling of the passive system, it was assumed samples were collected from each monitoring 

location on a daily basis. Thus, while the capital costs for the active monitoring station are 

expected to be on the low side, the annual operating costs may be considered to be reasonable 

worst-case estimates. Table 2 presents a summary of capital and annualized costs per model 

refinery for in-house analysis. Based on the cost-estimates for the passive monitoring stations 

and the more frequent sampling of the active monitoring system, only in-house analysis was 

considered for the active monitoring system. Attachments 7 through 9 of this memorandum 

present the detailed cost estimates for the active monitoring system for each model plant. 

Table 2. Model Plant Costs (in 2009$) for Fenceline Monitoring 

Model Plant 

Number of 

Monitoring Site per 

Model Plant 

Capital Costs per 

Model Plant, $ 

Annualized Costs 

per Model Plant, 

$/yr 

Small 12 132,000 194,000 

Medium 18 152,900 256,600 

Large 24 174,000 319,300 
13 

3. Approach for Developing Monitoring Costs for Open Path Monitoring Networks 

Open path monitoring systems, such as those described in EPA’s Other Test Method 10 

(OTM-10)7 provide another alternative to a passive monitoring network. The most common 

open path systems that may be used for continual fenceline monitoring are ultraviolet differential 

optical absorption spectroscopy (UV-DOAS) and Fourier transform infrared spectroscopy 

(FTIR). Equipment costs for a single UV-DOAS or FTIR system were estimated to be about 

$100,000,8 so a complete fenceline monitoring system (four systems plus shelters) was estimated 

to cost approximately $500,000. Depending on the availability of available electric power, site 

preparation and installation costs could significantly increase the total capital costs for an open 

path monitoring system. For the purpose of this analysis, a cost estimate of $250,000 per year 

was used to estimate the annual operating costs of the system. These costs were applied to all 

refineries, regardless of size. Depending on the configuration of the plant, it may be possible to 

use only 3 monitoring systems; however, it is more likely that the facility would have an 

irregular shape or a very long fenceline (too long for accurate measurement with one open path 

system) such that more than four open path instruments would be needed for full coverage of the 

facility’s fenceline. Thus, the open path monitoring system costs developed for this analysis are 

expected to provide a minimum cost estimate for open path monitoring system of a refineries 

complete fenceline. As with the other monitoring systems, the capital costs were annualized 

assuming a 10-year life and a 7 percent interest rate. Thus, the annualized cost for each facility 

was estimated to be $321,200 per year ($250,000 + 0.1424×$500,000). 

4. Summary and Comparison of Monitoring Costs 

Table 3 presents the nationwide cost estimate of applying the different monitoring 

options to all 142 major source refineries. To generate the estimate, we assumed that refineries 

with crude refining capacity of less than 125,000 barrels per day would fall into the small size 

(less than 750 acres), refineries with crude refining capacity greater than or equal to 125,000 

barrels per day and less than 225,000 barrels per day would fall into the medium size facility 

range (greater than or equal to 750 and less than 1,500 acres), and refineries with crude 

 

7 “Optical Remote Sensing for Emission Characterization from Non-Point Sources.” Final ORS Protocol, June 14, 2006. 

Available at: http://www.epa.gov/ttn/emc/prelim/otm10.pdf. 

8 Secrest, C. and D. Hoyt. “Air Monitoring Tools and Techniques: Practical Application for Savvy Air Investigators.” Presented 

at the EPA Regiion 6 National Multimedia Inspectionn/Enforcement Workshop. Dallas, TX. May 15-17, 2012. Available at: 

http://www.epa.gov/region6/6en/x/workshops/2012-may/presentations/hoyt-secrest.pdf. 
14 

throughput of greater than or equal to 225,000 barrels per day would fall into the large facility 

size (greater than or equal to 1,500 acres). The model plant costs presented in Table 1 suggest 

that conducting analyses in-house is the most cost-effective option for all model plant sizes. 

Therefore, the nationwide costs were projected assuming on all facilities would elect to purchase 

the equipment necessary to perform the analysis in-house. 

Table 3. Nationwide Costs (in 2009$) for Fenceline Monitoring at Petroleum Refineries 

Refinery Area 

Size 

Number of 

Refineries 

Number of 

Monitoring 

Sites 

Capital Cost 

($) 

Annualized Cost 

($/yr) 

Passive Diffusive Tube Monitoring Station Network 

Small 

(< 750 acres) 84 12 7,177,000 3,049,000 

Medium (≥ 750 

and < 1,500 acres) 27 18 2,340,000 1,107,000 

Large 

(≥1,500 acres) 31 24 2,736,000 1,423,000 

Total 142 2,238 12,250,000 5,580,000

Active Monitoring Station Network 

Small 

(< 750 acres) 84 12 11,090,000 16,300,000 

Medium (≥ 750 

and < 1,500 acres) 27 18 4,130,000 6,930,000 

Large 

(≥1,500 acres) 31 24 5,390,000 9,900,000 

Total 142 2,238 20,600,000 33,100,000

Open Path Monitoring Network

Total 142 568 71,000,000 45,600,000 

As seen by the costs presented in Table 3, passive diffusive tube monitoring is 

significantly less expensive, both in terms of capital and operating costs, than active or open path 

monitoring systems. 
A-1 

Attachment 1: Passive Monitoring In-House Cost Analysis - Small Model Plant 

Total Number of Monitoring Stations 12

Cost Item 

Technical 

Hours 

Management 

Hours 

Clerical 

Hours Quantity Cost 

Capital Costs   

Purchased Equipment Cost:   

 Meteorological Station   

 System Mounting Arma 1 516

 Data Loggera 1 3,022

 Pressure Sensor and Enclosurea 1 742

 Temperature Sensor and Enclosurea 1 465

 Radiation Shielda 1 146

 Ultrasonic Anemometer Wind Speed/Directiona 1 2,590

 Towera 1 2,500

 Thermal Desorption System with AutoSamplerb 1 40,284

 Gas Chromatography with FIDb 1 22,680

 Diffusion Tubes with end caps ($683 per pack of 10)b 3 2,213

 Analytical Cap - AutoSampler ($220 per pack of 20)b 2 475

 Diffusion Caps ($129 per pack of 10)b 3 418

 Weather Protectors ($150 per pack of 10) 2 324

 Steel Polesc 12 648

Installation Costd 40 2 4  ‐  3,824

Ancillary Cost (Planning/Selecting)d 40 2 4  ‐  3,824

Shipping    770

Total Capital Investment (TCI)    85,440 

                 

Annualized Costs               

Equip maintenance, insurance, etc (10% of TCI)    8,534

Sampling Collection Costd,e 78 3.9 7.8  ‐  7,457

Sampling Analysis Costd,f 67.6 3.38 6.76  ‐  6,463

Recordkeeping Costd 13 0.65 1.3  ‐  1,243

Reporting Costd 4 0.2 0.4  ‐  382

Annualized Operating Cost             24,089 

    

Total Annualized Costsg             36,300 

a) Costs were obtained from R.M. Young Company www.youngusa.com/products 

b) Costs were obtained from Perkin-Elmer. Total cost includes 8% sales tax. Thermal Desorption System with AutoSampler can 

sample up to 50 tubes. Analytical cap is recommended for use with AutoSampler. 

c) Cost is based on $30 per 6-foot pole + $20 cover/ancillary equipment. Total cost includes 8% sales tax. 

d) Managerial hours = 0.05 × Technical hours. Clerical hours = 0.1 × Technical hours. Costs per labor hour based on May 2009 

labor rates from Bureau of Labor and Statistics, (BLS), for NAICS 324100 available at: http://stats.bls.gov/oes/oes_dl.htm. 

Estimated benefits and overhead costs as 110 percent of labor costs. Loaded labor rates used were: $85/hr for technical; $130/hr 

for managerial; and $41/hr for clerical. 

e) Technical hours based on 0.25 hours to collect and replace each sampling tube (26 times/yr). 

f) Technical hours based on sampling analysis of 0.05 hour per tube and 2 hours to calibrate equipment (26 times/yr). 

g) Total Annualized Costs = Annualized Operating Costs + Total Capital Investment * Capital Recovery Factor. Capital Recovery 

Factor based on 10 year life at 7 percent interest = 0.1424 

 
A-2 

Attachment 2: Passive Monitoring In-House Cost Analysis - Medium Model Plant 

Total Number of Monitoring Stations 18

Cost Item 

Technical 

Hours 

Management 

Hours 

Clerical 

Hours Quantity Cost 

Capital Costs   

Purchased Equipment Cost:   

 Meteorological Station   

 System Mounting Arma 1 516

 Data Loggera 1 3,022

 Pressure Sensor and Enclosurea 1 742

 Temperature Sensor and Enclosurea 1 465

 Radiation Shielda 1 146

 Ultrasonic Anemometer Wind Speed/Directiona 1 2,590

 Towera 1 2,500

 Thermal Desorption System with AutoSamplerb 1 40,284

 Gas Chromatography with FIDb 1 22,680

 Diffusion Tubes with end caps ($683 per pack of 10)b 4 2,951

 Analytical Cap - AutoSampler ($220 per pack of 20)b 2 475

 Diffusion Caps ($129 per pack of 10)b 4 557

 Weather Protectors ($150 per pack of 10) 2 324

 Steel Polesc 18 972

Installation Costd 40 2 4  ‐  3,824

Ancillary Cost (Planning/Selecting)d 40 2 4  ‐  3,824

Shipping    782

Total Capital Investment (TCI)    86,650 

                 

Annualized Costs               

Equip maintenance, insurance, etc (10% of TCI)    8,665

Sampling Collection Costd,e 117 5.85 11.7  ‐  11,185

Sampling Analysis Costd,f 75.4 3.77 7.54  ‐  7,208

Recordkeeping Costd 13 0.65 1.3  ‐  1,243

Reporting Costd 4 0.2 0.4  ‐  382

Annualized Operating Cost             28,684 

    

Total Annualized Costsg             41,000 

a) Costs were obtained from R.M. Young Company www.youngusa.com/products

b) Costs were obtained from Perkin-Elmer. Total cost includes 8% sales tax. Thermal Desorption System with AutoSampler can 

sample up to 50 tubes. Analytical cap is recommended for use with AutoSampler. 

c) Cost is based on $30 per 6-foot pole + $20 cover/ancillary equipment. Total cost includes 8% sales tax. 

d) Managerial hours = 0.05 × Technical hours. Clerical hours = 0.1 × Technical hours. Costs per labor hour based on May 2009 

labor rates from Bureau of Labor and Statistics, (BLS), for NAICS 324100 available at: http://stats.bls.gov/oes/oes_dl.htm. 

Estimated benefits and overhead costs as 110 percent of labor costs. Loaded labor rates used were: $85/hr for technical; $130/hr 

for managerial; and $41/hr for clerical. 

e) Technical hours based on 0.25 hours to collect and replace each sampling tube (26 times/yr). 

f) Technical hours based on sampling analysis of 0.05 hour per tube and 2 hours to calibrate equipment (26 times/yr). 

g) Total Annualized Costs = Annualized Operating Costs + Total Capital Investment * Capital Recovery Factor. Capital Recovery 

Factor based on 10 year life at 7 percent interest = 0.1424 

 
A-3 

Attachment 3: Passive Monitoring In-House Cost Analysis - Large Model Plant 

Total Number of Monitoring Stations 24

Cost Item 

Technical 

Hours 

Management 

Hours 

Clerical 

Hours Quantity Cost 

Capital Costs   

Purchased Equipment Cost:   

 Meteorological Station   

 System Mounting Arma 1 516

 Data Loggera 1 3,022

 Pressure Sensor and Enclosurea 1 742

 Temperature Sensor and Enclosurea 1 465

 Radiation Shielda 1 146

 Ultrasonic Anemometer Wind Speed/Directiona 1 2,590

 Towera 1 2,500

 Thermal Desorption System with AutoSamplerb 1 40,284

 Gas Chromatography with FIDb 1 22,680

 Diffusion Tubes with end caps ($683 per pack of 10)b 5 3,688

 Analytical Cap - AutoSampler ($220 per pack of 20)b 3 713

 Diffusion Caps ($129 per pack of 10)b 5 697

 Weather Protectors ($150 per pack of 10) 3 486

 Steel Polesc 24 1,296

Installation Costd 40 2 4  ‐  3,824

Ancillary Cost (Planning/Selecting)d 40 2 4  ‐  3,824

Shipping    798

Total Capital Investment (TCI)    88,270 

                 

Annualized Costs               

Equip maintenance, insurance, etc (10% of TCI)    8,827

Sampling Collection Costd,e 156 7.8 15.6  ‐  14,914

Sampling Analysis Costd,f 83.2 4.16 8.32  ‐  7,954

Recordkeeping Costd 13 0.65 1.3  ‐  1,243

Reporting Costd 4 0.2 0.4  ‐  382

Annualized Operating Cost             33,320 

    

Total Annualized Costsg             45,900 

a) Costs were obtained from R.M. Young Company www.youngusa.com/products

b) Costs were obtained from Perkin-Elmer. Total cost includes 8% sales tax. Thermal Desorption System with AutoSampler can 

sample up to 50 tubes. Analytical cap is recommended for use with AutoSampler. 

c) Cost is based on $30 per 6-foot pole + $20 cover/ancillary equipment. Total cost includes 8% sales tax. 

d) Managerial hours = 0.05 × Technical hours. Clerical hours = 0.1 × Technical hours. Costs per labor hour based on May 2009 

labor rates from Bureau of Labor and Statistics, (BLS), for NAICS 324100 available at: http://stats.bls.gov/oes/oes_dl.htm. 

Estimated benefits and overhead costs as 110 percent of labor costs. Loaded labor rates used were: $85/hr for technical; $130/hr 

for managerial; and $41/hr for clerical. 

e) Technical hours based on 0.25 hours to collect and replace each sampling tube (26 times/yr). 

f) Technical hours based on sampling analysis of 0.05 hour per tube and 2 hours to calibrate equipment (26 times/yr). 

g) Total Annualized Costs = Annualized Operating Costs + Total Capital Investment * Capital Recovery Factor. Capital Recovery 

Factor based on 10 year life at 7 percent interest = 0.1424 
A-4 

Attachment 4: Passive Monitoring Outsource Cost Analysis - Small Model Plant 

Total Number of Monitoring Stations 12

Cost Item 

Technical 

Hours 

Management 

Hours 

Clerical 

Hours Quantity Cost 

Capital Costs   

Purchased Equipment Cost:   

 Meteorological Station   

 System Mounting Arma 1 516

 Data Loggera 1 3,022

 Pressure Sensor and Enclosurea 1 742

 Temperature Sensor and Enclosurea 1 465

 Radiation Shielda 1 146

 Ultrasonic Anemometer Wind Speed/Directiona 1 2,590

 Towera 1 2,500

 Diffusion Tubes with end caps ($683 per pack of 10)b 3 2,213

 Diffusion Caps ($129 per pack of 10)b 3 418

 Weather Protectors ($150 per pack of 10) 2 324

 Steel Polesc 12 648

Installation Costd 40 2 4  ‐  3,824

Ancillary Cost (Planning/Selecting)d 40 2 4  ‐  3,824

Shipping    136

Total Capital Investment (TCI)    21,370 

                 

Annualized Costs               

Equip maintenance, insurance, etc (10% of TCI)    2,137

Sampling Collection Costd,e 78 3.9 7.8  ‐  7,457

Sampling Analysis Costf 416 49,920

Recordkeeping Costd 13 0.65 1.3  ‐  1,243

Reporting Costd 4 0.2 0.4  ‐  382

Annualized Operating Cost             61,139 

    

Total Annualized Costsg             64,200 

a) Costs were obtained from R.M. Young Company www.youngusa.com/products

b) Costs were obtained from Perkin-Elmer. Total cost includes 8% sales tax. 

c) Cost is based on $30 per 6-foot pole + $20 cover/ancillary equipment. Total cost includes 8% sales tax. 

d) Managerial hours = 0.05 × Technical hours. Clerical hours = 0.1 × Technical hours. Costs per labor hour based on May 2009 

labor rates from Bureau of Labor and Statistics, (BLS), for NAICS 324100 available at: http://stats.bls.gov/oes/oes_dl.htm. 

Estimated benefits and overhead costs as 110 percent of labor costs. Loaded labor rates used were: $85/hr for technical; $130/hr 

for managerial; and $41/hr for clerical. 

e) Technical hours based on 0.25 hours to collect and replace each sampling tube (26 times/yr). 

f) Number analyses = (Number of samples + 4 QA samples)×26 times/yr, with a cost of $120 per analysis. 

g) Total Annualized Costs = Annualized Operating Costs + Total Capital Investment * Capital Recovery Factor. Capital Recovery 

Factor based on 10 year life at 7 percent interest = 0.1424 

 
A-5 

Attachment 5: Passive Monitoring Outsource Cost Analysis - Medium Model Plant 

Total Number of Monitoring Stations 18

Cost Item 

Technical 

Hours 

Management 

Hours 

Clerical 

Hours Quantity Cost 

Capital Costs   

Purchased Equipment Cost:   

 Meteorological Station   

 System Mounting Arma 1 516

 Data Loggera 1 3,022

 Pressure Sensor and Enclosurea 1 742

 Temperature Sensor and Enclosurea 1 465

 Radiation Shielda 1 146

 Ultrasonic Anemometer Wind Speed/Directiona 1 2,590

 Towera 1 2,500

 Diffusion Tubes with end caps ($683 per pack of 10)b 4 2,951

 Diffusion Caps ($129 per pack of 10)b 4 557

 Weather Protectors ($150 per pack of 10) 2 324

 Steel Polesc 18 972

Installation Costd 40 2 4  ‐  3,824

Ancillary Cost (Planning/Selecting)d 40 2 4  ‐  3,824

Shipping    148

Total Capital Investment (TCI)    22,580 

                 

Annualized Costs               

Equip maintenance, insurance, etc (10% of TCI)    2,258

Sampling Collection Costd,e 117 5.85 11.7  ‐  11,185

Sampling Analysis Costf 572 68,640

Recordkeeping Costd 13 0.65 1.3  ‐  1,243

Reporting Costd 4 0.2 0.4  ‐  382

Annualized Operating Cost             83,708 

    

Total Annualized Costsg             86,900 

a) Costs were obtained from R.M. Young Company www.youngusa.com/products

b) Costs were obtained from Perkin-Elmer. Total cost includes 8% sales tax. 

c) Cost is based on $30 per 6-foot pole + $20 cover/ancillary equipment. Total cost includes 8% sales tax. 

d) Managerial hours = 0.05 × Technical hours. Clerical hours = 0.1 × Technical hours. Costs per labor hour based on May 2009 

labor rates from Bureau of Labor and Statistics, (BLS), for NAICS 324100 available at: http://stats.bls.gov/oes/oes_dl.htm. 

Estimated benefits and overhead costs as 110 percent of labor costs. Loaded labor rates used were: $85/hr for technical; $130/hr 

for managerial; and $41/hr for clerical. 

e) Technical hours based on 0.25 hours to collect and replace each sampling tube (26 times/yr). 

f) Number analyses = (Number of samples + 4 QA samples)×26 times/yr, with a cost of $120 per analysis. 

g) Total Annualized Costs = Annualized Operating Costs + Total Capital Investment * Capital Recovery Factor. Capital Recovery 

Factor based on 10 year life at 7 percent interest = 0.1424 

 
A-6 

Attachment 6: Passive Monitoring Outsource Cost Analysis - Large Model Plant 

Total Number of Monitoring Stations 24

Cost Item 

Technical 

Hours 

Management 

Hours 

Clerical 

Hours Quantity Cost 

Capital Costs   

Purchased Equipment Cost:   

 Meteorological Station   

 System Mounting Arma 1 516

 Data Loggera 1 3,022

 Pressure Sensor and Enclosurea 1 742

 Temperature Sensor and Enclosurea 1 465

 Radiation Shielda 1 146

 Ultrasonic Anemometer Wind Speed/Directiona 1 2,590

 Towera 1 2,500

 Diffusion Tubes with end caps ($683 per pack of 10)b 5 3,688

 Diffusion Caps ($129 per pack of 10)b 5 697

 Weather Protectors ($150 per pack of 10) 3 486

 Steel Polesc 24 1,296

Installation Costd 40 2 4  ‐  3,824

Ancillary Cost (Planning/Selecting)d 40 2 4  ‐  3,824

Shipping    161

Total Capital Investment (TCI)    23,960 

                 

Annualized Costs               

Equip maintenance, insurance, etc (10% of TCI)    2,396

Sampling Collection Costd,e 156 7.8 15.6  ‐  14,914

Sampling Analysis Costf 728 87,360

Recordkeeping Costd 13 0.65 1.3  ‐  1,243

Reporting Costd 4 0.2 0.4  ‐  382

Annualized Operating Cost             106,295 

    

Total Annualized Costsg             109,700 

a) Costs were obtained from R.M. Young Company www.youngusa.com/products

b) Costs were obtained from Perkin-Elmer. Total cost includes 8% sales tax. 

c) Cost is based on $30 per 6-foot pole + $20 cover/ancillary equipment. Total cost includes 8% sales tax. 

d) Managerial hours = 0.05 × Technical hours. Clerical hours = 0.1 × Technical hours. Costs per labor hour based on May 2009 

labor rates from Bureau of Labor and Statistics, (BLS), for NAICS 324100 available at: http://stats.bls.gov/oes/oes_dl.htm. 

Estimated benefits and overhead costs as 110 percent of labor costs. Loaded labor rates used were: $85/hr for technical; $130/hr 

for managerial; and $41/hr for clerical. 

e) Technical hours based on 0.25 hours to collect and replace each sampling tube (26 times/yr). 

f) Number analyses = (Number of samples + 4 QA samples)×26 times/yr, with a cost of $120 per analysis. 

g) Total Annualized Costs = Annualized Operating Costs + Total Capital Investment * Capital Recovery Factor. Capital Recovery 

Factor based on 10 year life at 7 percent interest = 0.1424 

 
A-7 

Attachment 7: Active Monitoring In-House Cost Analysis - Small Model Plant 

Total Number of Monitoring Stations 12

Cost Item 

Technical 

Hours 

Management 

Hours 

Clerical 

Hours Quantity Cost 

Capital Costs   

Purchased Equipment Cost:   

 Meteorological Station   

 System Mounting Arma 1 516

 Data Loggera 1 3,022

 Pressure Sensor and Enclosurea 1 742

 Temperature Sensor and Enclosurea 1 465

 Radiation Shielda 1 146

 Ultrasonic Anemometer Wind Speed/Directiona 1 2,590

 Towera 1 2,500

 Thermal Desorption System with AutoSamplerb 1 40,284

 Gas Chromatography with FIDb 1 22,680

 Diffusion Tubes with end caps ($683 per pack of 10)b 3 2, 213

 Analytical Cap - AutoSampler ($220 per pack of 20)b 2 475

 Diffusion Caps ($129 per pack of 10)b 3 418

 Sampling pump ($2,000 each+tax) 12 25,920

 Shelter and Steel Polesc 12 13,608

Installation Costd 80 4 8  ‐  7,648

Ancillary Cost (Planning/Selecting)d 80 4 8  ‐  7,648

Shipping    1,156

Total Capital Investment (TCI)    132,030 

                 

Annualized Costs               

Equip maintenance, insurance, etc (10% of TCI)    13,203

Sampling Collection Costd,e 1095 54.75 109.5  ‐  104,682

Sampling Analysis Costd,f 469.5 23.475 46.95  ‐  44,884

Recordkeeping Costd 90 4.5 9  ‐  8,604

Reporting Costd 40 2 4  ‐  3,824

Annualized Operating Cost             175,200 

    

Total Annualized Costsg             194,000 

a) Costs were obtained from R.M. Young Company www.youngusa.com/products

b) Costs were obtained from Perkin-Elmer. Total cost includes 8% sales tax. Thermal Desorption System with AutoSampler can 

sample up to 50 tubes. Analytical cap is recommended for use with AutoSampler. 

c) Cost is based on $1,000 per shelter + $30 per 6-foot pole + $20 cover/ancillary equipment. Total cost includes 8% sales tax. 

d) Managerial hours = 0.05 × Technical hours. Clerical hours = 0.1 × Technical hours. Costs per labor hour based on May 2009 

labor rates from Bureau of Labor and Statistics, (BLS), for NAICS 324100 available at: http://stats.bls.gov/oes/oes_dl.htm. 

Estimated benefits and overhead costs as 110 percent of labor costs. Loaded labor rates used were: $85/hr for technical; $130/hr 

for managerial; and $41/hr for clerical. 

e) Technical hours based on 0.25 hours to collect and replace each sampling tube (365 times/yr). 

f) Technical hours based on sampling analysis of 0.025 hour per tube and 2 hours to calibrate equipment (analyze 180 times/yr).

g) Total Annualized Costs = Annualized Operating Costs + Total Capital Investment * Capital Recovery Factor. Capital Recovery 

Factor based on 10 year life at 7 percent interest = 0.1424 

 
A-8 

Attachment 8: Active Monitoring In-House Cost Analysis - Medium Model Plant 

Total Number of Monitoring Stations 18

Cost Item 

Technical 

Hours 

Management 

Hours 

Clerical 

Hours Quantity Cost 

Capital Costs   

Purchased Equipment Cost:   

 Meteorological Station   

 System Mounting Arma 1 516

 Data Loggera 1 3,022

 Pressure Sensor and Enclosurea 1 742

 Temperature Sensor and Enclosurea 1 465

 Radiation Shielda 1 146

 Ultrasonic Anemometer Wind Speed/Directiona 1 2,590

 Towera 1 2,500

 Thermal Desorption System with AutoSamplerb 1 40,284

 Gas Chromatography with FIDb 1 22,680

 Diffusion Tubes with end caps ($683 per pack of 10)b 4 2,951

 Analytical Cap - AutoSampler ($220 per pack of 20)b 2 475

 Diffusion Caps ($129 per pack of 10)b 4 557

 Sampling pump ($2,000 each+tax) 18 38,680

 Shelter and Steel Polesc 18 20,412

Installation Costd 80 4 8  ‐  7,648

Ancillary Cost (Planning/Selecting)d 80 4 8  ‐  7,648

Shipping    1,362

Total Capital Investment (TCI)    152,880 

                 

Annualized Costs               

Equip maintenance, insurance, etc (10% of TCI)    15,288

Sampling Collection Costd,e 1642.5 82.125 164.25  ‐  157,023

Sampling Analysis Costd,f 524.25 26.2125 52.425  ‐  50,118

Recordkeeping Costd 90 4.5 9  ‐  8,604

Reporting Costd 40 2 4  ‐  3,824

Annualized Operating Cost             234,860 

    

Total Annualized Costsg             256,600 

a) Costs were obtained from R.M. Young Company www.youngusa.com/products

b) Costs were obtained from Perkin-Elmer. Total cost includes 8% sales tax. Thermal Desorption System with AutoSampler can 

sample up to 50 tubes. Analytical cap is recommended for use with AutoSampler. 

c) Cost is based on $1,000 per shelter + $30 per 6-foot pole + $20 cover/ancillary equipment. Total cost includes 8% sales tax. 

d) Managerial hours = 0.05 × Technical hours. Clerical hours = 0.1 × Technical hours. Costs per labor hour based on May 2009 

labor rates from Bureau of Labor and Statistics, (BLS), for NAICS 324100 available at: http://stats.bls.gov/oes/oes_dl.htm. 

Estimated benefits and overhead costs as 110 percent of labor costs. Loaded labor rates used were: $85/hr for technical; $130/hr 

for managerial; and $41/hr for clerical. 

e) Technical hours based on 0.25 hours to collect and replace each sampling tube (365 times/yr). 

f) Technical hours based on sampling analysis of 0.025 hour per tube and 2 hours to calibrate equipment (analyze 180 times/yr).

g) Total Annualized Costs = Annualized Operating Costs + Total Capital Investment * Capital Recovery Factor. Capital Recovery 

Factor based on 10 year life at 7 percent interest = 0.1424 

 
A-9 

Attachment 9: Active Monitoring In-House Cost Analysis - Large Model Plant 

Total Number of Monitoring Stations 24

Cost Item 

Technical 

Hours 

Management 

Hours 

Clerical 

Hours Quantity Cost 

Capital Costs   

Purchased Equipment Cost:   

 Meteorological Station   

 System Mounting Arma 1 516

 Data Loggera 1 3,022

 Pressure Sensor and Enclosurea 1 742

 Temperature Sensor and Enclosurea 1 465

 Radiation Shielda 1 146

 Ultrasonic Anemometer Wind Speed/Directiona 1 2,590

 Towera 1 2,500

 Thermal Desorption System with AutoSamplerb 1 40,284

 Gas Chromatography with FIDb 1 22,680

 Diffusion Tubes with end caps ($683 per pack of 10)b 5 3,688

 Analytical Cap - AutoSampler ($220 per pack of 20)b 3 713

 Diffusion Caps ($129 per pack of 10)b 5 697

 Sampling pump ($2,000 each+tax) 24 51,840

 Shelter and Steel Polesc 24 27,216

Installation Costd 80 4 8  ‐  7,648

Ancillary Cost (Planning/Selecting)d 80 4 8  ‐  7,648

Shipping    1,571

Total Capital Investment (TCI)    173,970 

                 

Annualized Costs               

Equip maintenance, insurance, etc (10% of TCI)    17,397

Sampling Collection Costd,e 2190 109.5 219  ‐  209,364

Sampling Analysis Costd,f 579 28.95 57.9  ‐  55,352

Recordkeeping Costd 90 4.5 9  ‐  8,604

Reporting Costd 40 2 4  ‐  3,824

Annualized Operating Cost             294,540 

    

Total Annualized Costsg             319,300 

a) Costs were obtained from R.M. Young Company www.youngusa.com/products

b) Costs were obtained from Perkin-Elmer. Total cost includes 8% sales tax. Thermal Desorption System with AutoSampler can 

sample up to 50 tubes. Analytical cap is recommended for use with AutoSampler. 

c) Cost is based on $1,000 per shelter + $30 per 6-foot pole + $20 cover/ancillary equipment. Total cost includes 8% sales tax. 

d) Managerial hours = 0.05 × Technical hours. Clerical hours = 0.1 × Technical hours. Costs per labor hour based on May 2009 

labor rates from Bureau of Labor and Statistics, (BLS), for NAICS 324100 available at: http://stats.bls.gov/oes/oes_dl.htm. 

Estimated benefits and overhead costs as 110 percent of labor costs. Loaded labor rates used were: $85/hr for technical; $130/hr 

for managerial; and $41/hr for clerical. 

e) Technical hours based on 0.25 hours to collect and replace each sampling tube (365 times/yr). 

f) Technical hours based on sampling analysis of 0.025 hour per tube and 2 hours to calibrate equipment (analyze 180 times/yr).

g) Total Annualized Costs = Annualized Operating Costs + Total Capital Investment * Capital Recovery Factor. Capital Recovery 

Factor based on 10 year life at 7 percent interest = 0.1424