energ-Jti=li 

Matthew Todd 

Rogulotory and Sctentlfic Affairs 

1220 L Street, NW 

Washington, DC 

20005-4070 USA 

Telephone: 202-682-8319 

Fax: 202-682-8031 

Email: ToddM@aoi.om 

www.aoi.om 

Coker Vent Potential Release Limit 

Preliminary Emission. Cost and Cost Effectiveness Estimates 

Ms. Brenda Shine 

US EPA 

Office of Air Quality Planning and Standards 

Sector Policies and Programs Division (E 143-01) 

Research Triangle Park, NC 27711 

shine.brenda@epa.gov 

Dear Brenda, 

In November, the American Petroleum Institute (API) indicated that we were gathering 

investment cost information relative to the impact of a potential delayed coker vent 

atmospheric release criterion. While not complete, we have gathered a significant 

amount of information and are providing a summary herein. Using this information, we 

have also calculated preliminary cost effectiveness values for the potential release 

criteria. Our analyses are summarized below. 

I. Cost Effectiveness 

Table 1 shows the cost effectiveness using the mid-point investment cost estimates. 

Following EPA practice, investment costs were annualized at 7% interest and a 20 year 

life (CRF = 0.094393). Following the SCAQMD precedent, annual operating costs were 

taken as 7% of investment cost (4% operating cost and 3% utilities). A .recovered fuel 

gas credit was taken as 150% of the amount of methane predicted to be recovered by 

the model. This accounts for other recovered gases besides methane. Recovered 

gases are valued at a natural gas value of $0.094/lb. 
API Delayed Coker Investment Cost Information Page 2 

Table 1: Calculated Cost Effectiveness 

$/Ton 

5 psig Regulatory Limit 

VOC (as propane} 76,000 

Total HAPs 378,000 

2 psig Regulatory Limit 

VOC las orooane} 126,000 

Total HAPs 629,000 

2 v 5 Increment 

VOC (as propane) 202,000 

Total HAPs 1,011 000 

II. Cost Information 

In November 2013, API surveyed the nation's delayed coking units (DCUs) to determine 

each unit's best estimate of the investments they would need to make to meet not-toexceed and average release limits of 5 psig and 2 psig.1 To date, cost estimates 

(typically ranges) have been obtained for 40 DCUs and estimates for additional DCUs 

are expected. Five of the 40 estimates were historical (i.e., previous investments made 

to achieve a not-to-exceed 2 psig capability} and one was mostly historical investment, 

but also includes an estimate of future investment that will be needed to meet a not-toexceed limit of 5 or 2 psig, because both criteria are still sometimes exceeded. These 

six values ranged from $1M to $12M. The cost magnitudes and distribution for these 40 

DCUs was used to estimate the costs that would be incurred by the 80 operating DCUs 

if a Sector Rule criterion is imposed. 

Based on the EPA Refining Industry Information Collection Request (ICR) results, 

updated based on industry information, we estimate that there are 80 DCUs with a total 

of 254 coke drums currently operating in the U.S. The number of drums was rounded to 

260 coke drums for the emission, cost, and cost effectiveness estimates presented in 

the tables. Please note that this is a change from the 75 DCU and 240 drum estimates 

we provided to you when we met. Based on existing state, permit, and consent decree 

requirements, we estimate that 15 DCUs are already subject to a do-not-exceed 2 psig 

federally enforceable requirement, though compliance may not be required until as late 

as 2017, and thus no investment or emission impact from those units has been ascribed 

to the Sector Rule in our calculations. 

1 This survey included input from members of American Fuel and Petrochemical Manufacturers (AFPM) 
API Delayed Coker Investment Cost Information Page3 

Table 2 summarizes the national investment cost ranges, based on the data collected 

for the do-not-exceed limits. Estimates were also requested for meeting an average 5 

psig or 2 psig release pressure. There was generally consensus that investment costs 

would be reduced for an average versus a not-to-exceed value, but only a few DCUs 

provided specific cost estimates. Essentially, it appears that where a DCU already 

operates close to a do-not exceed limit, an investment of $1-3M might be totally avoided 

if the limit were expressed as an average. 

Table 2: Nationwide DCU Investment Estimate 

5 psig Limit 2 psig Limit 

Low Mid High Low Mid 

Number of DCUs 65 65 

Number requiring no Investment 47 15 

Number requiring Investment 18 50 

Number requiring Investment of <$5M 7 28 

Number requiring Investments between 

$5M and $10M 8 13 

Number requiring Investments of> $10M 3 10 

Average Investment for DCU's Requiring 

Investment (M$) 6.3 8.4 10.6 6.8 8.2 

Total Nationwide Cost (M$) 112 151 189 345 413 

Ill. Emission Estimates 

Since the methodology that EPA will use to estimate DCU emissions for the Refinery 

Sector rulemaking is not yet public, the emission estimates generated by the model 

used by the South Coast Air Quality Management District (SCAQMD) for their recent 

Rule 1114 development has been used as the basis for the cost effectiveness 

calculations presented here2

• There are significant issues with this model that we 

believe result in a large overstatement of the emissions from these vents and we will 

comment on those items in our comments on the Sector Rule proposal, if they are 

appropriate to the emissions model EPA uses. 

2 Final Staff Report, Proposed Rule 1114 - Petroleum Refinery Coking Operations, May 2013, available at 

http://www.aqmd.gov/hb/atlachments/2011-2015/2013May/2013-May3-Q30.pdf, Attachment F. 

High 

9.6 

482 
API Delayed Coker Investment Cost Information Page4 

Based on the information collected from the industry and the information provided in the 

non-confidential ICR database, we used the following (Table 3) distribution of average 

release pressures to calculate the base case emission levels. We believe this 

distribution conservatively represents the typical average release pressures currently 

occurring or to which DCUs are already committed to achieving due to state, permit or 

consent decree requirements, if that is lower than current release pressures. 

Table 3: Estimated Base Case Atmospheric Release Pressure Distribution 

for Currently Operating Coke Drums 

o/o of 260 

Base Case Release Pressure Drums 

1 psig average release pressure 18:75 

2 psig average release pressure 16.25 

3 psig average release pressure 12.50 

5 psig average release pressure 31.25 

13 psig average release pressure3 21.25 

Table 4 summarizes the emissions estimates used as the basis for the cost 

effectiveness calculations presented in Section I above. The base case estimate 

assumes the Table 3 release pressure distribution; the do-not-exceed 5 psig limit 

estimate assumes the DCUs that average 5 psig or higher in the base case achieve an 

average release pressure of 3 psig after the Sector Rule compliance date; and the donot-exceed 2 psig limit estimate assumes all DCUs have an average of 1 psig release 

pressure after the Sector Rule compliance date. These are the average release 

pressures our surveys have indicated are typical for coke drums subject to these donot-exceed limits. 

3 13 psig is the top of the typical release pressure range Identified in the API surveys, though many DCU's average 

less than 13 psig. This value is used for conservatism in estimating the base case emissions. 
API Delayed Coker Investment Cost Information PageS 

Table 4: Coke Vent National Emission Estimates using SCAQMD model. 

Base 5psig 2psig 

Case Limit Limit 

VOC (as propane), Tons/year 689 366 154 

Total HAPs, Tons/year4 138 73 31 

Again, we appreciate the dialogue that we continue to have with you on this and other 

refinery sector issues. Please contact me if you would like to discuss any of this 

information further. 

Cc: Ms. Penny Lassiter 

US EPA 

Sincerely, 

Is/ 

Matthew Todd 

Office of Air Quality Planning and Standards 

Sector Policies and Programs Division (E143-01) 

Research Triangle Park, NC 27711 

Lassiter.Penny@epamail.epa.gov 

4 The SCAQMD model assumes 20% of VOC is HAP.