### 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 Te chnical Support Document

I. Purpose The objective of this documen t is to provide cost info rmation 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 fug itive leaks from equipment and wastewater collection and treatment systems, are inherently difficult to quantify with methods currently available. In general, uncertainties in emi ssions estimates are related to the omission or mischaracterization of significant em ission 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 pr ocess sewers, wastewater systems, or other fugitive emissions

 Improper characterization of sources for emission m odels and emission factors

 Inherent uncertainty in emi ssions estimation methodologies

In 2010, the EPA undertook an extensive information collection effort focused on sending an information collecti on 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 emi ssions 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 re port their emissions

### 2 according to the protocol. In one such instance, approximately 20% of the major source refineries did not report any emissions from wast ewater collection and treatment systems. This notable gap was in spite of detailed guidance a nd model spreadsheet made available to assess
these emissions.
Recent emission studies show differences between facility em ission reporting, the modeling of that data, and the actual measured concentratio ns. A study in 2010, funded by an EPA grant to the City of Houston, evaluated di fferential 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 th e accuracy of emission factors and emission estimating methods. The DIAL study measured em issions from various process areas. The results pointed to significant differences between emission esti mate method results and actual emissions data collected, with measured resu lts most commonly far gr eater than estimated. Similar results were also found in 2008, when a DI AL test was conducted at the BP Texas City Refinery. Among the findings, emissions from ta nks 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 Texa s Air Quality Study-2000, where ambi ent 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 a nother 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 conc urred 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 an d Prevention City of Houston, Measurement and Analysis of Benzene and VOC Emissions in the Houston Ship Channel Ar ea and Selected Surrounding Majo r 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 DI AL Emission Test Data for BP Petroleum Refinery in Texas City, Texas. EPA 453/R-10-002. December 2010. 3 Improving Emission Inventories for Eff ective Air Quality Management Across No rth America. NARSTO 05-001. August 2005. 4 Office of Inspector General Report. Report No. 2006-P- 00017. EPA CAN Improve Emissi on Factors Development and Management. March 22,, 2006.

### 3 In 2009, the EPA conducted a year-long diffusi ve tube monitoring pilot project at the
fenceline of Flint Hills West Refi nery 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 implem entable by modestly trained personnel and provided useful information on overall concentr ation levels and source identification using simple upwind and downwind comparisons. Th is memorandum provides guidance and impact
estimates for fenceline di ffusive 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 benzen e are fugitive emissions from process equipment, wastewater treatment, storage ta nks, and loading operations, the releases generally occur near ground level. Thus, the highest fenceline benzene concentrations outside th e facility will likely occur near the property boundary near ground level. Consequently, ambient air monitoring at the property boundary (fenceline) will provide a di rect measure of the annual average benzene concentrations directly surrounding the refinery.
EPA reviewed the available l iterature and identified several different methods for measuring fugitive emissions around the fenceline of a petroleum refinery. These methods include: (1) passive diffusive tube monitoring ne tworks; (2) active monito ring 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 ha s been demonstrated in a European study
of refineries. The Internationa l 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-pumpe d 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 Emissi on Characterization from Non-Point Source s.” Final ORS Protocol, June 14, 2006. Available at: http://www.epa.gov/ttn/emc/prelim/otm10.pdf

. 6 “Indoor, ambient and workplace air – Sa mpling and analysis of volatile orga nic compounds by sorbent tube/thermal desorption/capillary gas chromatography – Part 2: Diffusi ve Sampling.” International St andard 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 rega rding the diffusive tube monitoring approach and Subsection E provides considerations for citi ng monitoring stations fo r fenceline monitoring (applicable to both passive diffusive tube and acti vely-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 provi ded 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 Deploym ent and VOC Sample Collection (Method 325A) and Sampler Preparation and Analysis (325B), whic h is applicable to an alysis of a number of volatile organic compounds, including benzene. The method provide s 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 diffusi on 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 tu bes 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 monito ring applications. As su ch, there are more data regarding the effective sampling rate for passive diffusive tube samplers at this frequency, reducing the uncertainty in the measured concentr ations. 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 fre quency increases the cost of the monitoring program. Additionally, the shorter time period asso ciated with more frequent sampling leads to

### 5 smaller sample volumes, which increase the likel ihood of having detection limited results if the ambient concentrations are low. Sampling less frequently, for example m onthly 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 decr ease with longer sampling times and there is variability in this decrease depending on the am bient concentration. This leads to increased uncertainty regarding the measured ambient concentration for monthly monitoring. Additionally, saturati on 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 ar e expected to be moderate and variable (changing with process operations and wind direction), a f our-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 w ith 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 sampli ng, 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 att ached by brackets to a support stru cture. 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 protectiv e hood. The primary purpose of this weather hood is to prevent precipitation or snow from blocki ng the sampling surface (openings in the diffusion end-cap). It also helps to prevent solar heat ing of the tube (higher temperatures reduce the sorption capacity of the sorbent). A simple weather protector cons ists of an inverted cone/funnel that fits tightly around the diffusive tube with th e 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 provide s guidance on the placement of monitors. In developing Method 325A, aerial photographs were studied a nd 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 diffe rent angles based on the size of the area (or subarea). At the facility, these horizontal a nd 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 w hose 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 gr eater than or equal to 125,000 and less than 225,000 barrels per day (greater than or equa l 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 la rge size category and would measure from the center point angles of 15 degrees for a to tal 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 boundar y. Please note that a facili ty 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 monito r needs to be placed at each point of
intersection. (6.) In the case that a source is within 50 mete rs of the property boundary and the source
location is between two mon itors, 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 th e property boundary of a facility whose area is between 750 and 1,500 acres. As prescrib ed above, the facility measured from the property center angles of 20 degrees, which required 18 monitor placements. Monitor placements are represented with black dots alon g the property boundary. Per Method 325A (step 6 above), the facility also added three additiona l 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 s hould apply the below steps for proper monitor placement: (1.) Determine the center point of each subarea. (2.) If your subarea falls into th e small category, measure from the center point angles of 30 degrees for a total of twel ve 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 la rge category, measure from the center point angles of 15 degrees for a total of twenty-f our 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 measur ed 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 subar ea’s outer boundary, a monitor needs to be placed at each point of intersection. (6.) In the case that a source is within 50 me ters 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 half way 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 facili ty 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 fo r 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 Cost s for Passive Diffusive Tube Monitoring Costs for the monitoring program vary depe nding 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 an alysis of the diffusive tube samp les is relatively straight-forward and automated systems are available so that th e 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 a nd installing the monitoring stations, collecting the samples, and pe rforming the analyses for the first year. The
initial costs include the cost of purchasing a GC (with FID det ector), a thermal desorption unit with an autosampler, and the diffusive tubes and caps. Analytical equipment cost estimates were developed from vendor quotes. Thes e 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 monito rs at angles of 30 degree = 12 fenceline monitoring locations. 2) Medium model plants with fe nceline monitors at angles of 20 degree = 18 fenceline monitoring locations 3) Large model plants with fenceline monito rs at angles of 15 degree = 24 fenceline monitoring locations

For each model plant, cost estimates were de veloped assuming that the facility purchased the necessary analytical equipment and perfor med the analyses in-house and separate cost estimates were developed assuming that the fa cility outsourced all sample analyses. Some facilities may have an existing GC and may only need to purchas e 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 reasonabl e 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 a nd outsourced analyses for each model plant.

Table 1. Model Plant Costs (in 2009$) for Fence line 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 empl oying 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 cap ital 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 availa ble 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 coul d significantly raise the capital costs of each monitoring station. The primary difference in the annual operati ng 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 sample s collected, it is common for active sampling systems to collect one sample every other of ev ery third day, but to comp are 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 cap ital costs for the active monitoring station are expected to be on the low side, the annual opera ting costs may be considered to be reasonable worst-case estimates. Table 2 presents a su mmary of capital and annua lized costs per model refinery for in-house analysis. Based on the cost -estimates for the pass ive 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 ac tive monitoring system for each model plant.

Table 2. Model Plant Costs (in 2009$) for Fence line 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 Co sts for Open Path Monitoring Networks Open path monitoring systems, such as t hose described in EPA’s Other Test Method 10 (OTM-10) 7 

### provide another alternative to a pass ive monitoring network. The most common open path systems that may be used for continua l fenceline monitoring are ultraviolet differential optical absorption spectroscopy (UV-DOAS) and Fourier transform in frared 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 availa bility 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 ope rating costs of the system. These costs were applied to all refineries, regardless of size. Depending on the configuration of the plan t, it may be possible to use only 3 monitoring systems; however, it is mo re likely that the fa cility would have an irregular shape or a very long fenceline (too l ong for accurate measurement with one open path system) such that more than four open path inst ruments would be needed for full coverage of the facility’s fenceline. Thus, the ope n path monitoring system costs developed for this analysis are expected to provide a minimum cost estimate fo r 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 perc ent interest rate. Thus, the a nnualized 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 estim ate of applying the different monitoring options to all 142 major source refineries. To gene rate the estimate, we assumed that refineries with crude refining capacity of less than 125,000 barrels per day would fa ll 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 in to the medium size facility range (greater than or equal to 750 and less than 1,500 acres), and re fineries with crude

7 “Optical Remote Sensing for Emissi on Characterization from Non-Point Source s.” 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: Prac tical Application for Savvy Ai r Investigators.” Presented at the EPA Regiion 6 National Multimedia Inspectionn/Enforcem ent 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 e qual to 225,000 barrels per day would fall into the la rge facility size (greater than or equal to 1,500 acres). The model plant costs presen ted in Table 1 suggest that conducting analyses in-hous e is the most cost-effective op tion 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 Fen celine 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-H ouse 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 Arm a 1 516 Data Logger a 1 3,022
Pressure Sensor and Enclosure a 1 742 Temperature Sensor and Enclosure a 1 465
Radiation Shield a 1 146 Ultrasonic Anemometer Wind Speed/Direction a 1 2,590

Tower a 1 2,500 Thermal Desorption System with AutoSampler b 1 40,284 Gas Chromatography with FID b 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 Poles c 12 648 Installation Cost d 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 Cost d,e 78 3.9 7.8 ‐ 7,457 Sampling Analysis Cost d, f 67.6 3.38 6.76 ‐ 6,463 Recordkeeping Cost d 13 0.65 1.3 ‐ 1,243 Reporting Cost d 4 0.2 0.4 ‐ 382 Annualized Operating Cost 24,089

Total Annualized Costs g 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 Statis tics, (BLS), for NAICS 324100 available at: http://stats.bls.gov/oes/oes_dl.htm

. Estimated benefits and overhead costs as 110 percent of labor cost s. 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 Operat ing Costs + Total Capital Investment * C apital Recovery Factor. Capital Recovery Factor based on 10 year life at 7 percent interest = 0.1424

### A-2 Attachment 2: Passive Monitoring In-Hou se 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 Arm a 1 516 Data Logger a 1 3,022
Pressure Sensor and Enclosure a 1 742 Temperature Sensor and Enclosure a 1 465
Radiation Shield a 1 146 Ultrasonic Anemometer Wind Speed/Direction a 1 2,590

Tower a 1 2,500 Thermal Desorption System with AutoSampler b 1 40,284 Gas Chromatography with FID b 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 Poles c 18 972 Installation Cost d 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 Cost d,e 117 5.85 11.7 ‐ 11,185 Sampling Analysis Cost d, f 75.4 3.77 7.54 ‐ 7,208 Recordkeeping Cost d 13 0.65 1.3 ‐ 1,243 Reporting Cost d 4 0.2 0.4 ‐ 382 Annualized Operating Cost 28,684

Total Annualized Costs g 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 Statis tics, (BLS), for NAICS 324100 available at: http://stats.bls.gov/oes/oes_dl.htm

. Estimated benefits and overhead costs as 110 percent of labor cost s. 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 Operat ing Costs + Total Capital Investment * C apital Recovery Factor. Capital Recovery Factor based on 10 year life at 7 percent interest = 0.1424

### A-3 Attachment 3: Passive Monitoring In-H ouse 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 Arm a 1 516 Data Logger a 1 3,022
Pressure Sensor and Enclosure a 1 742 Temperature Sensor and Enclosure a 1 465
Radiation Shield a 1 146 Ultrasonic Anemometer Wind Speed/Direction a 1 2,590

Tower a 1 2,500 Thermal Desorption System with AutoSampler b 1 40,284 Gas Chromatography with FID b 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 Poles c 24 1,296 Installation Cost d 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 Cost d,e 156 7.8 15.6 ‐ 14,914 Sampling Analysis Cost d, f 83.2 4.16 8.32 ‐ 7,954 Recordkeeping Cost d 13 0.65 1.3 ‐ 1,243 Reporting Cost d 4 0.2 0.4 ‐ 382 Annualized Operating Cost 33,320

Total Annualized Costs g 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 Statis tics, (BLS), for NAICS 324100 available at: http://stats.bls.gov/oes/oes_dl.htm

. Estimated benefits and overhead costs as 110 percent of labor cost s. 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 Operat ing Costs + Total Capital Investment * C apital Recovery Factor. Capital Recovery Factor based on 10 year life at 7 percent interest = 0.1424

### A-4 Attachment 4: Passive Monitoring Outs ource 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 Arm a 1 516 Data Logger a 1 3,022
Pressure Sensor and Enclosure a 1 742 Temperature Sensor and Enclosure a 1 465
Radiation Shield a 1 146 Ultrasonic Anemometer Wind Speed/Direction a 1 2,590

Tower a 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 Poles c 12 648 Installation Cost d 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 Cost d,e 78 3.9 7.8 ‐ 7,457 Sampling Analysis Cost f 416 49,920 Recordkeeping Cost d 13 0.65 1.3 ‐ 1,243 Reporting Cost d 4 0.2 0.4 ‐ 382 Annualized Operating Cost 61,139

Total Annualized Costs g 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 Statis tics, (BLS), for NAICS 324100 available at: http://stats.bls.gov/oes/oes_dl.htm

. Estimated benefits and overhead costs as 110 percent of labor cost s. 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 Operat ing Costs + Total Capital Investment * C apital Recovery Factor. Capital Recovery Factor based on 10 year life at 7 percent interest = 0.1424

### A-5 Attachment 5: Passive Monitoring Outs ource 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 Arm a 1 516 Data Logger a 1 3,022
Pressure Sensor and Enclosure a 1 742 Temperature Sensor and Enclosure a 1 465
Radiation Shield a 1 146 Ultrasonic Anemometer Wind Speed/Direction a 1 2,590

Tower a 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 Poles c 18 972 Installation Cost d 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 Cost d,e 117 5.85 11.7 ‐ 11,185 Sampling Analysis Cost f 572 68,640 Recordkeeping Cost d 13 0.65 1.3 ‐ 1,243 Reporting Cost d 4 0.2 0.4 ‐ 382 Annualized Operating Cost 83,708

Total Annualized Costs g 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 Statis tics, (BLS), for NAICS 324100 available at: http://stats.bls.gov/oes/oes_dl.htm

. Estimated benefits and overhead costs as 110 percent of labor cost s. 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 Operat ing Costs + Total Capital Investment * C apital Recovery Factor. Capital Recovery Factor based on 10 year life at 7 percent interest = 0.1424

### A-6 Attachment 6: Passive Monitoring Outs ource 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 Arm a 1 516 Data Logger a 1 3,022
Pressure Sensor and Enclosure a 1 742 Temperature Sensor and Enclosure a 1 465
Radiation Shield a 1 146 Ultrasonic Anemometer Wind Speed/Direction a 1 2,590

Tower a 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 Poles c 24 1,296 Installation Cost d 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 Cost d,e 156 7.8 15.6 ‐ 14,914 Sampling Analysis Cost f 728 87,360 Recordkeeping Cost d 13 0.65 1.3 ‐ 1,243 Reporting Cost d 4 0.2 0.4 ‐ 382 Annualized Operating Cost 106,295

Total Annualized Costs g 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 Statis tics, (BLS), for NAICS 324100 available at: http://stats.bls.gov/oes/oes_dl.htm

. Estimated benefits and overhead costs as 110 percent of labor cost s. 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 Operat ing Costs + Total Capital Investment * C apital Recovery Factor. Capital Recovery Factor based on 10 year life at 7 percent interest = 0.1424

### A-7 Attachment 7: Active Monitoring In-H ouse 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 Arm a 1 516 Data Logger a 1 3,022
Pressure Sensor and Enclosure a 1 742 Temperature Sensor and Enclosure a 1 465
Radiation Shield a 1 146 Ultrasonic Anemometer Wind Speed/Direction a 1 2,590

Tower a 1 2,500 Thermal Desorption System with AutoSampler b 1 40,284 Gas Chromatography with FID b 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 Poles c 12 13,608 Installation Cost d 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 Cost d,e 1095 54.75 109.5 ‐ 104,682 Sampling Analysis Cost d, f 469.5 23.475 46.95 ‐ 44,884 Recordkeeping Cost d 90 4.5 9 ‐ 8,604 Reporting Cost d 40 2 4 ‐ 3,824 Annualized Operating Cost 175,200

Total Annualized Costs g 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 Statis tics, (BLS), for NAICS 324100 available at: http://stats.bls.gov/oes/oes_dl.htm

. Estimated benefits and overhead costs as 110 percent of labor cost s. 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 tu be and 2 hours to calibrate equipment (analyze 180 times/yr). g) Total Annualized Costs = Annualized Operat ing Costs + Total Capital Investment * C apital Recovery Factor. Capital Recovery Factor based on 10 year life at 7 percent interest = 0.1424

### A-8 Attachment 8: Active Monitoring In-Hou se 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 Arm a 1 516 Data Logger a 1 3,022
Pressure Sensor and Enclosure a 1 742 Temperature Sensor and Enclosure a 1 465
Radiation Shield a 1 146 Ultrasonic Anemometer Wind Speed/Direction a 1 2,590

Tower a 1 2,500 Thermal Desorption System with AutoSampler b 1 40,284 Gas Chromatography with FID b 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 Poles c 18 20,412 Installation Cost d 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 Cost d,e 1642.5 82.125 164.25 ‐ 157,023 Sampling Analysis Cost d, f 524.25 26.2125 52.425 ‐ 50,118 Recordkeeping Cost d 90 4.5 9 ‐ 8,604 Reporting Cost d 40 2 4 ‐ 3,824 Annualized Operating Cost 234,860

Total Annualized Costs g 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 Statis tics, (BLS), for NAICS 324100 available at: http://stats.bls.gov/oes/oes_dl.htm

. Estimated benefits and overhead costs as 110 percent of labor cost s. 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 tu be and 2 hours to calibrate equipment (analyze 180 times/yr). g) Total Annualized Costs = Annualized Operat ing Costs + Total Capital Investment * C apital Recovery Factor. Capital Recovery Factor based on 10 year life at 7 percent interest = 0.1424

### A-9 Attachment 9: Active Monitoring In-H ouse 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 Arm a 1 516 Data Logger a 1 3,022
Pressure Sensor and Enclosure a 1 742 Temperature Sensor and Enclosure a 1 465
Radiation Shield a 1 146 Ultrasonic Anemometer Wind Speed/Direction a 1 2,590

Tower a 1 2,500 Thermal Desorption System with AutoSampler b 1 40,284 Gas Chromatography with FID b 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 Poles c 24 27,216 Installation Cost d 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 Cost d,e 2190 109.5 219 ‐ 209,364 Sampling Analysis Cost d, f 579 28.95 57.9 ‐ 55,352 Recordkeeping Cost d 90 4.5 9 ‐ 8,604 Reporting Cost d 40 2 4 ‐ 3,824 Annualized Operating Cost 294,540

Total Annualized Costs g 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 Statis tics, (BLS), for NAICS 324100 available at: http://stats.bls.gov/oes/oes_dl.htm

. Estimated benefits and overhead costs as 110 percent of labor cost s. 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 tu be and 2 hours to calibrate equipment (analyze 180 times/yr). g) Total Annualized Costs = Annualized Operat ing Costs + Total Capital Investment * C apital Recovery Factor. Capital Recovery Factor based on 10 year life at 7 percent interest = 0.1424