Attachments: 

Attachment 1: 

Results of RBLC Database Queries 

Attachment 2: 

BACT Analysis for control of TDI emissions from slabstock foam production line at a facility in 

Ft. Wayne, IN 

Attachment 3: 

Detailed RTO/RCO Cost Analyses 

Attachment 4: 

Memorandum regarding Equipment Leaks in the Chemical and Petroleum Industries 

Attachment 5: 

BAAQMD Equipment Leak Memo 
Attachment 1: 

Results of RBLC Database Queries 
Attachment 1a. Summary of RBLC Query for NAICS 326150 

RBLCID Corporate or 

Company Name Last Updated Process Name 

*IN-0127 Foamex Innovations, 

Inc. 

6/26/2012 Thermal Reticulation 

Unit 

MI-0313 Woodbridge 

Corporation 

11/18/2002 Mold Release 

Application 

NC-0071 Nomaco, Inc. 3/12/2004 Polyethylene Foam 

Extrusion & 

Converting Lines 

NC-0109 Nomaco, Incorporated 1/11/2006 Extruders 

NC-0110 Nomaco, Incorporated 1/11/2006 Extruders 

OK-0108 Nomaco, Inc. 1/10/2005 Foam Extrusion (5) 

OK-0108 Nomaco, Inc. 1/10/2005 Printing 

OK-0108 Nomaco, Inc. 1/10/2005 Combustion Units 

(Engine/Heaters) 

OK-0122 Nomaco, Inc. 4/20/2009 Polyethylene Foam 

Extrusion 
Attachment 1b. Summary of RBLC Query for SIC 3086 

RBLCID Corporate or Company 

Name Last Update Process Name Notes 

AZ-0019 Western Insulfoam 12/18/2001 Foam Panel 

Manufacturing 

CA-0724 Pactuco 8/29/2006 Polystyrene 

Extrusion 

Process 

CA-0742 Styrotek, Inc. 12/18/2001 Expandable 

Polystyrene 

Molding 

Operation 

CA-0785 Carpenter Co. 12/18/2001 Non-woven 

Polyester Foam 

Line 

CA-0785 Carpenter Co. 12/18/2001 Adhesive 

Application 

Process 

CA-0909 Dart Container Corporation 

of California 

10/11/2005 Polystyrene 

Foam Extrusion 

CA-0987 Pactuco 8/25/2003 Polystyrene 

Extrusion 

Process 

CT-0105 Tuscarora Inc. 12/18/2001 Molding, 

Expandable 

Polystyrene 

IL-0081 Owens Corning 9/17/2003 Polystyrene 

Foam Board 

Extrusion Lines 

*IN-0127 Foamex Innovations Inc. 6/26/2012 Thermal 

Reticulation Unit 

KY-0080 Dart Container of KY 4/23/2004 Polystyrene 

Container 

Manufacturing 

KY-0080 Dart Container of KY 4/23/2004 Foam Extrusion 

Lines (18) 

KY-0080 Dart Container of KY 4/23/2004 Printers, UV Ink 

& amp; Off Line 

KY-0080 Dart Container of KY 4/23/2004 Warehouse 

Storage 

KY-0080 Dart Container of KY 4/23/2004 Polystyrene 

Extruders & 

Thermoformers 

MI-0196 Falcon Manufacturing of 

Michigan, Inc. 

10/9/2002 Expander Polystyrene 
Attachment 1b. Summary of RBLC Query for SIC 3086 

RBLCID Corporate or Company 

Name Last Update Process Name Notes 

MI-0196 Falcon Manufacturing of 

Michigan, Inc. 

10/9/2002 Mold Polystyrene 

MI-0207 Tuscarora Plastics, Inc. 10/9/2002 Storage, PreExpansion & 

Pre-Puff, 

Molding, Storage 

MI-0210 Tuscarora Plastics, Inc. 10/9/2002 Storage, PreExpansion, & 

Pre-Puff, 

Molding 

MI-0249 Tuscarora Inc. 1/3/2003 Manufacturing, 

Expandable 

Plastic Beads 

MI-0273 Fagerdala – Paclite 

Incorporated 

12/28/2001 Expandable 

Polystyrene 

Molding 

MI-0273 Fagerdala – Paclite 

Incorporated 

12/28/2001 Expandable 

Polypropylene 

Molding 

MI-0278 Voltek Div of Sekisui 

America Corp. 

12/20/2001 Foam 

Production, 

Polyolefin, 

Ovens, 11 Each 

MI-0313 Woodbridge Corporation 11/18/2002 Mold Release 

Application 

VOC 

MI-0322 Fagerdala Pac-Lite 

Incorporated 

12/7/2004 Extrusion, 

Polyethylene

MI-0322 Fagerdala Pac-Lite 

Incorporated 

12/7/2004 Extrusion, 

Polypropylene 

MI-0322 Fagerdala Pac-Lite 

Incorporated 

12/7/2004 Expandable 

Polypropylene 

Bead Production 

MI-0384 Dart Container Corporation 

of Michigan 

8/21/2007 EUCUP: 

Production of 

Foam Containers 

MS-0085 Dart Container Corporation 

LLC 

4/17/2007 Natural Gas 

Fired Boiler 

MS-0085 Dart Container Corporation 

LLC 

4/17/2007 Cup 

Manufacturing 

Process 
Attachment 1b. Summary of RBLC Query for SIC 3086 

RBLCID Corporate or Company 

Name Last Update Process Name Notes 

NC-0071 Nomaco Inc. 3/12/2004 Polyethylene 

Foam Extrusion 

& Converting 

Lines 

NC-0109 Nomaco Incorporated 1/11/2006 Extruders 

NC-0110 Nomaco Incorporated 1/11/2006 Extruders 

NV-0027 Universal Urethane, Inc. 5/6/2005 MFG of 

Polyurethane 

Products 

OH-0234 Knauf USA Polystyrene Inc. 10/9/2002 Polystyrene 

Foam Production 

Process 

OK-0108 Nomaco Inc. 1/10/2005 Foam Extrusion 

(5) 

OK-0108 Nomaco Inc. 1/10/2005 Printing 

OK-0108 Nomaco Inc. 1/10/2005 Combustion 

Units 

(Engine/Heaters) 

OK-0122 Nomaco Inc. 4/20/2009 Polyethylene 

Foam Extrusion 

PA-0164 Dart Container Corporation 9/4/2003 Polystyrene 

Extrusion 

PA-0164 Dart Container Corporation 9/4/2003 Thermoforming, 

Roll Storage 

PA-0210 Dart Container Corp of PA 8/4/2008 Polystyrene 

Extrusion 

PA-0210 Dart Container Corp of PA 8/4/2008 Boiler, (2) 

PA-0210 Dart Container Corp of PA 8/4/2008 EPS Container 

Manufacturer 

PA-0222 Dart Corp. of America 4/12/2005 Expandable Cup 

Manufacturing 

VA-0187 Amoco Foam Products 

Company 

5/23/2002 Expandable 

Polystyrene 

Products 

Manufacturing 

Plant 
Attachment 2: 

BACT Analysis for control of TDI emissions 

from slabstock foam production line 

at a facility in Ft. Wayne, IN 
Indiana Department of Environmental Management

Office of Air Quality

APPENDIX A

BACT ANALYSIS REPORT

Source Description and Location

Source Name: Foamex Innovations Operating 

Company

Source Location: 3005 Commercial Road, Fort Wayne, 

Indiana 46809

County: Allen

SIC Code: 3086

Operation Permit Renewal No.: T003-27321-00225

Operation Permit Renewal Issuance Date: July 23, 2009

PSD/Significant Source Modification No.: 003-29260-00225

Significant Permit Modification No.: 003-29273-00225

Permit Reviewer: Stephanie Wilkerson

Background Information

The Office of Air Quality (OAQ) has performed a best available control technology (BACT) review

relating to the operation of a stationary flexible polyurethane foam production and processing 

plant, located at 3005 Commercial Road, in Fort Wayne, Indiana. This source is owned and 

operated by Foamex Innovations Operating Company, and is referred to as FXI in this document.

FXI submitted an application on May 13, 2010, to construct and operate one (1) new 

polyurethane foam production line, identified as PL-01c, and one (1) polyurethane foam coating 

line, identified as CL-01. The modification has potential VOC emissions greater than forty (40) 

tons per year and is located at a major source for PSD. Therefore, the operation of the one (1) 

new polyurethane foam production line and one (1) new polyurethane foam coating line is subject 

to the requirements of 326 IAC 2-2-3 (PSD BACT) and 326 IAC 8-1-6 (VOC BACT).

IDEM, OAQ conducts BACT analyses in accordance with the “Top-Down” Best Available Control 

Technology Guidance Document outlined in the 1990 draft U.S. EPA New Source Review 

Workshop Manual, which outlines the steps for conducting a top-down BACT analysis. Those 

steps are listed below.

(a) Identify all potentially available control options;

(b) Eliminate technically infeasible control options;

(c) Rank remaining control technologies;

(d) Evaluate the most effective controls and document the results; and

(e) Select BACT.

Also in accordance with the “Top-Down” Best Available Control Technology Guidance Document

outlined in the 1990 draft U.S. EPA New Source Review Workshop Manual, BACT analyses take 

into account the energy, environmental, and economic impacts on the source. Emission 

reductions may be determined through the application of available control techniques, process 
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design, and/or operational limitations. Such reductions are necessary to demonstrate that the 

emissions remaining after application of BACT will not cause or contribute to air pollution thereby 

protecting public health and the environment.

VOC BACT Analysis

Step One: Identify All Control Technologies

The following control technologies were evaluated in regards to controlling VOC emissions from 

the polyurethane foam production and coating lines:

(a) Condensation System

Condensation systems use a refrigerant to cool the exhaust stream from a 

process, causing a phase change from gas to liquid for the volatile constituents. 

The liquid is collected, and the concentration of the volatile constituent that was 

removed in the condensation step is reduced from the exhaust gas. This 

technology is particularly applicable when concentration of VOCs in the gas 

stream is greater than one percent (1%).

(b) Carbon Adsorption

In carbon adsorption systems, exhaust gases are passed through a bed of 

activated carbon granules and the organic compounds are absorbed onto the 

surface of the carbon granules. When the carbon is saturated, the captured 

organics are desorbed, usually using steam. Carbon adsorption can consist of 

two (2) beds used in tandem, to allow for one (1) bed to be working while the 

second bed is being desorbed and prepared for the next cycle.

Carbon adsorption can typically achieve VOC control efficiencies of 

approximately 95% on a continuous basis.

(c) PolyadTM

The Polyad

System TM System is offered by a microwave technology vendor that 

combines resin-fluidized bed adsorption with microwave dynamic bed desorption 

that claims VOC control primarily for stripping VOCs from soil vapor extraction 

units, air stripping at remediation sites, and solvent recovery.

(d) Flares

Flares are a VOC-combustion control process in which VOCs are piped to a 

remote, usually elevated location, and burned in an open flame in the open air. 

Flares use a specially designed burner tip, auxiliary fuel, and air to promote 

mixing from proper VOC destruction. Completeness of combustion in a flare is 

governed by flame temperature, residence time in the combustion zone, turbulent 

mixing of the gas stream components to complete the oxidation reaction, and 

available oxygen for free radical formation. Combustion is complete if all VOC 

emissions are converted to carbon dioxide (CO2) and water. Incomplete 

combustion results in some of the VOCs being unaltered or converted to other 

organic compounds such as aldehydes or acids.

(e) Biofiltration

In biofiltration, off-gases containing biodegradable organic compounds are 

vented, under controlled temperature and humidity, through a biologically active 

material. The process uses a biofilm containing a population of microorganisms 

immobilized on a porous substrate such as peat, soil, sand, wood, compost, or 

numerous synthetic media. As an air stream passes through the biofilter, the 
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contaminants in the air stream partition from the gaseous phase to the liquid 

phase of the biofilm. Once contaminants pass into the liquid phase, they become 

bioavailable for the complex oxidative process by the microorganisms inhabiting 

the biofilm.

The bioscrubber is an enhancement of the biofilter where a packed tower is 

flooded with a liquid-phase contaminant stream and the discharge effluent is 

retained in a sump for added time to improve the contact time between the 

contaminants and the microbes.

(f) Membrane Separation Technologies

Membrane separation technology involves the preferential transport of organic 

vapors through a non-porous gas separation membrane via a diffusion process. 

The feed stream is compressed to approximately 150 psig and sent to a 

condenser where the liquid solvent is recovered. The condenser bleed is sent to 

the membrane module where it is concentrated and returned to the compressor 

for further recovery in the condenser.

(g) Ultraviolet (UV) Oxidation

Also called photolytic destruction, UV oxidation of vapor-phase contaminants is 

accomplished by passing the off-gases in close proximity to a powerful UV light 

source. The photo-oxidation is usually supplemented with a gaseous chemical 

oxidant, such as ozone, or a solid catalyst like titanium dioxide. This technology 

has been proposed for off-gas treatment from soil-vapor extraction and other 

groundwater remediation units by the U.S. Department of Energy.

(h) Non-Thermal Plasma (NTP) Technology

NTP technology consists of an electrically neutral form of gas containing 

substantial concentrations of electrons, ion, and other highly reactive free 

radicals with may be generated in the gas stream by application of electrical 

energy. In theory, the sequential chemical reactions result in the destruction of 

the air contaminants. The U.S. Navy sought to be one of the first to install and 

use NTP technology for controlling paint booth VOC emissions.

(i) Catalytic Incineration

In catalytic incineration, solvent-laden air is preheated and the organic 

constituents are ignited and combusted to create CO2 and water. In the 

presence of a catalyst, this reaction is able to take place at lower temperatures 

than those required for thermal oxidation. Temperatures between 350 and 500 

degrees Celsius (662 - 932°F) are common. Lower reaction temperatures 

reduce or eliminate the need for supplemental fuel, and will also decrease the 

formation of NOX from the combustion process. The catalysts most often used 

are metal oxides or precious metals that are supported on ceramic or metallic 

substrates. 

Catalytic incinerators can typically achieve control efficiencies of approximately 

95% on a continuous basis.

(j) Thermal Oxidation

In thermal oxidation, solvent-laden air is preheated and the organic constituents 

are ignited and combusted to create CO2 and water. Dilute gas streams require 

auxiliary fuel, generally natural gas, to sustain combustion. Various incinerator 

designs are used, but must provide high turbulence to mix the fuel and solventladen air. The design must also provide enough residence time to ensure 

essentially complete combustion of the off-gases.
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Control efficiencies of 95% are possible with thermal oxidation.

To be considered technically feasible, a control technology must either be successfully 

demonstrated on a unit or, if not demonstrated, then be "available and applicable". A technology 

is considered "available" if it can be obtained by the applicant through commercial channels. An 

available technology is considered "applicable" if it can reasonably be installed and operated on 

the unit in question.

Step Two: Evaluate Technical Feasibility

The feasibility of each of the potentially applicable control options identified is reviewed below.

(a) Condensation System

Condensation is not considered a technically-feasible control option to reduce the 

VOC emissions from the polyurethane foam production line. The exhaust stream 

from the polyurethane foam production and coating lines is very dilute, precluding 

any effective applicability of the system. Also, various organic compounds may 

be present in the exhaust stream that would affect the operational efficiency of a 

condensation system.

(b) Carbon Adsorption

Carbon adsorption is considered a technically-feasible option to control VOC 

emissions from the polyurethane foam production and coating lines. However, 

no existing applications currently exist within the foam production industry.

Carbon adsorption can typically achieve VOC control efficiencies of 

approximately 95% on a continuous basis.

(c) PolyadTM

The Polyad

System TM System has several limitations. Among those are an impaired 

efficiency due to a dilute inlet stream concentration; potential interference from 

moisture and certain constituents in the exhaust stream; and re-entrainment of 

VOCs during microwave desorption. Therefore, the PolyadTM

adsorption/microwave desorption technology is not considered technicallyfeasible to reduce VOC emissions from the polyurethane foam production and 

coating lines.

(d) Flares

Flares are not a technically-feasible control options for VOC emissions from the 

polyurethane foam production and coating lines. The large volume of air flow 

and the small VOC loading in the exhaust stream exclude the flare as an 

appropriate control device. Additionally, flares are primarily safety devices that 

deal with flows of short duration, such as an upset condition or accidental release 

from a process, rather than a control device used to treat a continuous emissions 

stream.

(e) Biofiltration

Biofiltration systems are typically used for odor control in clearly speciated air 

streams. These control devices typically have large footprints and operate in 

narrow bands of temperature and pressure requiring expensive gas conditioning. 

The source does not have the space required to support a biofiltration system, 

and the constituents of the exhaust from the polyurethane foam production and 

coating lines may foul the system, requiring expensive replacement of the 
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microorganisms and/or the biofilm. Therefore, biofiltration is not considered a 

technically-feasible control option.

(f) Membrane Separation Technologies

Membrane separation technologies are not a technically-feasible option. These 

technologies for removal of VOCs from a gas stream are in use for product 

recovery, and also for certain environmental remediation applications. However, 

membrane systems are sensitive to mixture concentrations and conditions, and 

would not effectively accommodate fluctuations in VOC concentrations in the gas 

stream, making them impractical for pollution control in many industrial 

applications.

(g) Ultraviolet (UV) Oxidation

UV light frequency must be selected for maximum VOC removal based on inlet 

stream constituents. The effectiveness of the control method is greatly 

diminished for a matrix of volatile constituents with variable photolytic destruction 

isotherms. Additionally, the interaction between chemical constituents, 

preferential destruction, and potential fouling of the titanium dioxide catalyst from 

inlet stream moisture limit the effectiveness of UV oxidation. Therefore, this is 

not considered a technically-feasible control option for this operation.

(h) Non-Thermal Plasma (NTP) Technology

NTP Technology is not available commercially and has not yet been proven as 

effective. Therefore, based on availability, this is not a technically-feasible 

control option.

(i) Catalytic Incineration

Catalytic incineration is a technically-feasible option. The economic, energy, and 

environmental impacts associated with this technology are further discussed in 

this analysis.

(j) Thermal Oxidation

Thermal oxidation is considered a technically-feasible control option for this 

operation. The economic, energy, and environmental impacts associated with 

this technology are further discussed in this analysis.

The following table summarizes other BACT determinations at similar sources or on similar 

processes:

Company/

Location

Year

Issued

Process 

Description

BACT Emission 

Limits/Requirements Reference

Nomaco, Inc./

Canadian 

County, OK

2008 Polyurethane 

foam extrusion

No controls required; 0.7 lb VOC/lb 

resin blowing agent limit and overall 

limit of 1,621.8 tpy blowing agent 

usage

RBLC ID: OK-0122

DaimlerChrysler 

Corporation/

Toledo, OH

2007 Injected foam 

sound deadener

No controls required; LAER 

requirements: 6.80 lb VOC/hr; 8.30 tpy; 

and 0.14 lb/gal of foam lb/gal of 

unreacted foam.

RBLC ID: OH-0309

Dart Container 

Corp./ Ingham 

County, MI

2007 Expandable 

polystyrene 

process; preexpansion 

system

Pentane emissions controlled by three 

(3) steam boilers. Emission limits of 

75.33 lb VOC/hr and 219.95 tpy.

RBLC ID: MI-0384

Nomaco, Inc./

Oklahoma City, 

OK

1999 Flash tube dryer Emissions from dryer to be controlled 

by RTO with 95% CE; 12.6 lb/hr and 

55.2 tpy VOC limit.

RBLC ID: NC-0081
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Company/

Location

Year

Issued

Process 

Description

BACT Emission 

Limits/Requirements Reference

Nomaco, Inc./ 

Wake Co., NC

2003 Polyethylene 

foam extrusion 

and converting 

lines

No controls required; blowing agent 

usage limits of 0.6lb VOC/ft3

RBLC ID:NC-0071

foam and 

1,250 tpy.

General Motors, 

Lansing Craft 

Centre/ 

Lansing, MI

2002 Rigid foam 

injection

No controls required; VOC emissions 

limited to 4.45 tons per twelve (12) 

month average, and 57.4 lb/day

RBLC ID: MI-0351

Owens Corning/ 

Winnebago 

Co., IL

2001 Polystyrene 

foam board 

manufacturing

No controls required; HCFC emissions 

limited to 39.5 lb/hr in staging and 

warehousing, and 187.2 lb/hr "other"

RBLC ID: IL-0081

General Motors 

Delta Township 

Assembly/ 

Eaton Co., MI

2001 Structural foam 

injection

No controls required; VOC emissions 

limited to 230 lb/day and 28.4 tpy.

RBLC ID: MI-0326

Whirlpool Corp./

Vanderburgh 

Co,. IN

2001 Foam line Material substitution required as BACT, 

with 2,948,400 lbs per twelve (12) 

consecutive month period usage of 

new HCFC.

RBLC ID: IN-0107

Voltek Division 

of Sekisui 

America Corp./ 

Branch Co., MI

2000 Polyolefin foam 

production/ 

ovens

Catalytic oxidizer on each oven 

required with overall control efficiency 

of 96%; VOC emissions limits of 0.12 

lb/hr and 0.53 tpy

RBLC ID: MI-0278

Carpenter Co./ 

Elkhart, IN 2009

Foam pouring 

line

No controls required; VOC emissions 

limit of 38.6 tons per twelve (12) 

consecutive month period; required 

continued development of catalysts to 

reduce emissions where feasible; work 

practice standards

Indiana SPM039-

17958-00086

Four (4) foam 

turnstile 

operations

No controls required; Two (2) units 

have HVLP use requirements and VOC 

emissions limit of less than 65 tpy

Createc 

Corporation/ 

Portland, IN

2009 Polystyrene 

foam 

manufacturing

No controls required; Total VOC usage 

limit of less than 291.25 tpy; Pentane 

may not exceed 7% content by weight

Indiana Title V 

Renewal T075-28002-

00024

Cryovac Rigid 

Packaging, 

Sealed Air 

Corporation/ 

Indianapolis, IN

1997 Polystyrene 

extruded foam 

manufacturing

VOC emissions from the reclaim 

extruders must be controlled by an 

incinerator with minimum overall 

destruction efficiency of 90%; Resin 

usage limit of 28,546 tpy and blowing 

agent usage limit of 1,316 tpy.

Indiana Title V 

Construction Permit 

097-5348-00093

Foamex 

Innovations, 

Inc./ Auburn, IN

2005 Flexible 

polyurethane 

foam VPF line

VOC emissions controlled by a carbon 

adsorber with minimum overall control 

efficiency of 51%; VOC emissions from 

carbon adsorber not to exceed 38.5 

lb/hr; VPF line production limited to 

less than 1.2 billion board feet per year

Indiana SSM033-

20970-00047

Genpak, LLC/ 

Scottsburg, IN

2007 Expandable 

polystyrene 

(EPS) food tray 

production line

VOC emissions controlled by either 

boiler or RTO with minimum 

destruction efficiency of 95%; capture 

system for repelletizer to maintain 

minimum capture efficiency of 85%; 

blowing agent input limit of 906.66 tpy

Indiana SSM143-

25032-00016

2000 Expandable

polystyrene 

(EPS) cup

production line

VOC emissions controlled by boiler 

with minimum destruction efficiency of 

95%; capture system for PreExpansion Room to maintain minimum 

capture efficiency of 95%; blowing 

agent input limit of 182 tpy

Indiana SSM143-

11382-00016
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Company/

Location

Year

Issued

Process 

Description

BACT Emission 

Limits/Requirements Reference

Johns Manville/ 

Bremen, IN

2001 Rigid 

polyisocyanurate 

foam panel 

manufacturing 

process

VOC emissions controlled by RTO with 

an overall minimum control efficiency of 

90%, except during November through 

March of each year; Throughput shall 

not exceed 678,356,560 board feet per 

year 

Indiana SPR099-

14499-00042

Syndicate 

Sales, Inc./ 

Kokomo, IN

2008 Foam 

production, 

forming and 

packaging 

operation

VOC emissions controlled by RTO with 

an overall minimum destruction 

efficiency of 95%, except during 

November through March of each year; 

Total blowing agent VOC usage limited 

to less than 149.21 tpy, equivalent to 

96.90 tpy VOC emissions based on 

59% uncontrolled emissions from 

warehouse and 41% controlled 

emissions through RTO

Indiana FESOP 

Renewal 067-26473-

00053

Tegrant 

Diversified 

Brands, Inc./ 

Michigan City, 

IN

1996 Expandable 

polystyrene 

molding process

No controls required; Use of material 

with lowest-available pentane content 

required plus ongoing research and 

movement to materials with lower

pentane/VOC content

Indiana VOC BACT in 

CP091-4823-00079

1999 Pre-expanders No controls required; Maximum 

average VOC (pentane) content of 

materials is 5.5%; Ongoing research 

for lowest VOC-containing materials 

and alternates required

Indiana VOC BACT in 

T091-7666-00079

2001 Four (4) molding 

presses

No controls required; VOC usage 

limited to 155.22 tpy; Molding 

compound shall not exceed 5.5% VOC 

(pentane) content; Ongoing research 

for lowest VOC-containing materials 

and alternates required

Indiana VOC BACT in 

SSM091-14438-

00079

A review of previous BACT determinations and requirements from the RBLC and other permits 

issued to similar sources resulted in the following discussion:

(a) Several sources in the table above manufacture types of foam that are vastly 

different to that produced at the FXI facility that is the subject of this analysis. 

These sources were used in comparison only for VOC limits; the manufacturing 

processes and resulting emissions stream is significantly different from that of 

FXI.

(1) The emissions stream from processes making polystyrene, polyolefin, 

polyisocyanurate, and polyethylene foam have a different VOC 

composition from the polyurethane process proposed at FXI. 

Additionally, the VOC limits imposed upon the other units listed above 

are significantly higher than those limits proposed as BACT by FXI. 

Therefore, the BACT requirements for those facilities, including those requiring 

the use of add-on controls, do not represent BACT for the FXI facility in Fort 

Wayne, Indiana.

(b) With the exception of the Foamex Innovations, Inc. facility in Auburn, Indiana, the 

other sources manufacturing foams of polyurethane or similar compounds do not 

have add-on controls required. BACT was most often established as a VOC 

emission limit in tons per year and/or VOC content and usage limitations.
Foamex Innovations Operating Company Page 8 of 13

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(1) Based on information from the source, the only similarity between the 

FXI Auburn facility and the FXI Fort Wayne facility is that they both 

produce polyurethane foam. The FXI Auburn facility utilizes a Variable 

Pressure Foaming machine that is an enclosed chamber with one (1) 

emission point that is able to be pressurized. This process uses less air 

flow and has very high capture efficiency due to its design.

The proposed foam pour line at the FXI Fort Wayne facility is an 

atmospheric pour line system. This system is not fully enclosed and 

operates at atmospheric conditions, requiring much greater airflows than 

the Auburn facility (approximately 63,000 acfm for FXI Fort Wayne 

versus 2,000 acfm for FXI Auburn).

Additionally, the products manufactured at the FXI Auburn facility are of 

one (1) type. The FXI Fort Wayne facility manufactures foam for a 

variety of uses, and will, therefore, use more and different catalysts that 

would potentially foul a similar control device to what is required for the 

Auburn foam line.

The remaining technically feasible control options for controlling VOC emissions from the

proposed polyurethane foam production and coating lines are ranked below by control efficiency:

Step Three: Rank Feasible Technologies

Control Technology Control Efficiency (%)

Regenerative Thermal Oxidation 95

Catalytic Incineration 95

Carbon Adsorption 95

Further evaluation including economic, energy and environmental impacts are required for 

controlling VOC emissions from the proposed polyurethane foam production and coating lines. 

Annualized costs were determined in accordance with the EPA guidance (EPA’s Office of Air 

Quality Planning and Standards Control Cost Manual), with other relevant information provided by 

the respective equipment vendors, inputs from plant personnel, and engineering judgment. 

Step Four: Evaluate Top Control Alternatives

For all evaluations below, direct costs listed do not include any additional costs to increase the 

flow rate to accommodate the exhaust flow rate from the proposed coating line or to install the 

duct work from the coating line to the control device.
Foamex Innovations Operating Company Page 9 of 13

Fort Wayne, Indiana TSD Appendix A

Permit Reviewer: Stephanie Wilkerson BACT Analysis for PSD/SSM 003-29260-00025

Economic feasibility was evaluated as demonstrated below:

Economic Impact Analysis:

RTO

DIRECT COST (Pollution Control Equipment) Unit Cost TOTAL ($)

Direct Purchased Equipment

Equipment Total (A) A = $949,000

Instruments 0.01 A $95,000

Access Way Addition (Engineering Estimate) $25,000

Sales Taxes 0.07 A $73,000

Freight 0.05 A $52,000

Total Equipment Costs (B) B = $1,194,000

Direct Installation Cost

Foundation and Support 0.08 B $96,000

Handling and Erection 0.14 B $167,000

Electrical 0.04 B $48,000

Piping 0.02 B $24,000

Insulation 0.02 B $24,000

Site Prep (Engineering Estimate) $30,000

Total Direct Installation Costs $390,000

TOTAL Direct Investment (TDI) = 

(Total Equipment Cost + Total Direct Installation Cost) TDI = $1,583,000

Indirect Installation Costs

Engineering 0.10 B $119,000

Contractor Fees 0.10 B $119,000

Construction and Field Expenses 0.05 B $60,000

Start-up & Performance 0.03 B $36,000

Contingencies 0.03 B $36,000

Total Indirect Installation Costs (TIC) TIC = $370,000

TOTAL CAPITAL INVESTMENT (TCI) = (TDC +TIC) TCI = $1,953,000

ANNUAL OPERATION & MAINTENANCE

Direct Operating Costs (DA)

Operating Labor + Supervisory Labor $8,000

Maintenance Labor + Materials $15,000

Natural Gas (5.00 $/1000 ft3) $1,382,000

Electricity ($0.052/kWh) $106,000

Total Direct Operating Costs (DA) DA = $1,511,000

Indirect Operating Costs (IC)

Overhead $14,000
Foamex Innovations Operating Company Page 10 of 13

Fort Wayne, Indiana TSD Appendix A

Permit Reviewer: Stephanie Wilkerson BACT Analysis for PSD/SSM 003-29260-00025

Taxes, Insurance, Administrative Costs $78,000

Capital Recovery Factor (system)

(Assumes 7% interest over 10 years) $277,000

Total Indirect Operating Costs (IA) IA = $369,000 

Total operating Costs (DA + IA) TOC = $1,880,000

Tons VOC Removed @ 95% = 93.1 tpy

Cost per Ton VOC Removed = $20,193

Catalytic Incineration System

DIRECT COST (Pollution Control Equipment) Unit Cost TOTAL ($)

Direct Purchased Equipment

Equipment Total (A) A = $1,231,200

Instruments 0.01 A $123,000

Access Way Addition (Engineering Estimate) $25,000

Sales Taxes 0.07 A $95,000

Freight 0.05 A $68,000

Total Equipment Costs (B) B = $1,542,000

Direct Installation Cost

Foundation and Support 0.08 B $123,000

Handling and Erection 0.14 B $216,000

Electrical 0.04 B $62,000

Piping 0.02 B $31,000

Insulation 0.02 B $31,000

Site Prep (Engineering Estimate) $30,000

Total Direct Installation Costs $493,000

TOTAL Direct Investment (TDI) = 

(Total Equipment Cost + Total Direct Installation Cost) TDI = $2,035,000

Indirect Installation Costs

Engineering 0.10 B $154,000

Contractor Fees 0.10 B $154,000

Construction and Field Expenses 0.05 B $77,000

Start-up & Performance Test 0.03 B $46,000

Contingencies 0.03 B $46,000

Total Indirect Installation Costs (TIC) TIC = $477,000

TOTAL CAPITAL INVESTMENT (TCI) = (TDC +TIC) TCI = $2,512,000

ANNUAL OPERATION & MAINTENANCE

Direct Operating Costs (DA)

Operating Labor & Supervisory Labor $8,000
Foamex Innovations Operating Company Page 11 of 13

Fort Wayne, Indiana TSD Appendix A

Permit Reviewer: Stephanie Wilkerson BACT Analysis for PSD/SSM 003-29260-00025

Maintenance Labor & Materials $15,000

Natural Gas (5.00 $/1000 ft3) $331,000

Electricity ($0.052/kWh) $126,000

Catalyst Replacement ($650/ft3 metal oxide) - (0.001 ft3/acfm) $40,950

Total Direct Operating Costs (DA) DA = $521,000

Indirect Operating Costs (IC)

Overhead (60% of maintenance labor & materials) $14,000

Taxes, Insurance, Administrative Costs $100,000

Capital Recovery Factor (system)

(Assumes 7% interest over 10 years) $356,000

Total Indirect Operating Costs (IA) IA = $470000 

Total operating Costs (DA + IA) TOC = $991,000

Tons VOC Removed @ 95% = 93.1 tpy

Cost per Ton VOC Removed = $10,644

Carbon Adsorption System

DIRECT COST (Pollution Control Equipment) Unit Cost TOTAL ($)

Direct Purchased Equipment

Equipment Total (A) A = $2,600,000

Instruments 0.01 A $260,000

Access Way Addition (Engineering Estimate) $25,000

Sales Taxes 0.07 A $182,000

Freight 0.05 A $130,000

Total Equipment Costs (B) B = $3,172,000

Direct Installation Cost

Foundation and Support 0.08 B $254,000

Handling and Erection 0.14 B $444,000

Electrical 0.04 B $127,000

Piping 0.02 B $63,000

Insulation 0.02 B $63,000

Site Prep (Engineering Estimate) $30,000

Total Direct Installation Costs $981,000

TOTAL Direct Investment (TDI) = 

(Total Equipment Cost + Total Direct Installation Cost) TDI = $4,153,000

Indirect Installation Costs

Engineering 0.10 B $317,000

Contractor Fees 0.10 B $317,000

Construction and Field Expenses 0.05 B $159,000
Foamex Innovations Operating Company Page 12 of 13

Fort Wayne, Indiana TSD Appendix A

Permit Reviewer: Stephanie Wilkerson BACT Analysis for PSD/SSM 003-29260-00025

Start-up & Performance Test 0.03 B $95,000

Contingencies 0.03 B $95,000

Total Indirect Installation Costs (TIC) TIC = $983,000

TOTAL CAPITAL INVESTMENT (TCI) TCI = $5,136,000

ANNUAL OPERATION & MAINTENANCE

Direct Operating Costs (DA)

Operating Labor & Supervisory Labor $5,000

Maintenance Labor & Materials $9,000

Replacement Parts, Carbon Replacement Labor, and Carbon 

Cost (5-year life) $35,900

Steam and Cooling Water $132,300

Distillation System $34,200

Electricity ($0.05/kWh) $41,300

Total Direct Operating Costs (DA) DA = $257,700

Indirect Operating Costs (IC)

Overhead $8,000

Taxes, Insurance, Administrative Costs $205,000

Capital Recovery Factor (system)

(Assumes 7% compound interest rate and system useful life of 

10 years) = 0.1424 $728,800

Total Indirect Operating Costs (IA) IA = $941,800

Total operating Costs (DA + IA) TOC = $1,199,500

Tons VOC Removed @ 95% = 93.1 tpy

Cost per Ton VOC Removed = $12,884

(a) Based on the information presented above, it would be economically infeasible to 

control the emissions from the proposed polyurethane foam production and 

coating lines with a thermal oxidizer at a cost of $20,193 per ton of VOC 

removed.

(b) Based on the information presented above, it would be economically infeasible to 

control the emissions from the proposed polyurethane foam production and 

coating lines with a catalytic incineration system at a cost of $10,644 per ton of 

VOC removed.

(c) Based on the information presented above, it would be economically infeasible to 

control the emissions from the proposed polyurethane foam production and 

coating lines with a carbon adsorption system at a cost of $12,884 per ton of 

VOC removed.

The proposed BACT from FXI is to limit VOC emissions from the one (1) proposed 

polyurethane foam production line to less than 80.8 tons per twelve (12) consecutive 

month period; maintain the equipment in good working order; and to utilize best 

management work practices to minimize VOC emissions.
Foamex Innovations Operating Company Page 13 of 13

Fort Wayne, Indiana TSD Appendix A

Permit Reviewer: Stephanie Wilkerson BACT Analysis for PSD/SSM 003-29260-00025

The proposed BACT from FXI for the one (1) proposed polyurethane foam coating line is 

to limit VOC emissions to less than 17.2 tons per twelve (12) consecutive month period.

Pursuant to 326 IAC 2-2-3 (PSD BACT), and 326 IAC 8-1-6 (VOC BACT), the Best Available 

Control Technology (BACT) for the one (1) proposed polyurethane foam production line, identified 

as PL-01c, and the one (1) proposed polyurethane foam coating line, identified as CL-01,for VOC

shall be as follows:

Step Five: Select BACT

(a) The input of VOC to the one (1) polyurethane foam production line shall not exceed 80.8 

tons per twelve (12) consecutive month period, with compliance determined at the end of 

each month.

(b) The Permittee shall utilize the following best management practices to minimize VOC 

emissions from the one (1) polyurethane foam production line:

(1) Use of the lowest VOC-content foam production materials where technically 

feasible;

(2) Track the quantity of amine catalyst used on a monthly basis;

(3) Store and handle the amine catalyst to minimize fugitive losses; and

(4) Continue to explore options for the production of foam using non-VOC content 

materials.

(c) The input of VOC to the one (1) polyurethane foam coating line shall not exceed 17.2 

tons per twelve (12) consecutive month period, with compliance determined at the end of 

each month.
Attachment 3: 

Detailed RTO/RCO Cost Analyses 
Attachment 3a. Storage Tank Emission and Control Cost Details 

Control 

Scenario 

HAP 

Emissions 

(Tons/yr) 

Capital 

Control 

Costs ($) 

Annual 

Control 

Cost 

($/yr) 

HAP 

Emission 

Reduction 

(Tons/yr) 

Cost 

Effectiveness 

($/Ton) 

Incremental 

Cost 

Effectiveness 

($/Ton) 

Uncontrolled1,2 0.0867 NA NA NA NA NA 

Vapor 

Balancing1,2

0.00434 $6,150 $1,133 0.0824 $13,759 NA 

Regenerative 

Thermal 

Oxidation3

0.00173 $895,281 $325,603 0.084966 $3,832,154 $124,747,995

Recuperative 

Thermal 

Oxidation3

0.00173 $537,915 $702,280 0.084966 $8,265,426 $269,568,200

1

 Uncontrolled and vapor balancing costs were obtained using the methodology from the 6/17/1996 memorandum: 

"Estimated Regulatory Alternative Impacts for Flexible Polyurethane Foam Production", available as part of 

“Hazardous Air Pollutant Emissions From The Production Of Flexible Polyurethane Foam: Supplementary 

Information Document For Proposed Standards” Emission Standards Division, U.S. EPA, September 1996. The costs 

and emissions are based on the Model Plant 3 cost estimate, which consists of 1 TDI storage tank at a Slabstock Foam 

Production facility. Costs were escalated to 2010 dollars using the Chemical Engineering Magazine Plant Cost index, 

http://www.che.com/pci/. 2

 Emissions estimated based on tank emissions data from Slabstock Foam facilities reporting tanks emissions and sizes 

in the 2011 survey of FPUF facilities performed under Section 114 of the CAA. 3

 Regenerative and recuperative thermal oxidizer costs based on 15,000 scfm flow rate from the storage tank. 

 
Attachment 3b. Vapor Balance Costs for Foam Storage Vessels 

Capital Cost for Vapor Balance1 $6,150

Number of MeCl2 Uncontrolled Tanks 0MeCl2 Emissions (Ton/yr) 0Number of TDI Uncontrolled Tanks 1TDI Emissions (Ton/yr) 0.087Capital Costs $6,150 Annual O&M (3%) $184Capital Charges (14.24%) $876Taxes, Ins. (4%) $246Recovery Credit $173Total Annual Costs $1,133 Emission Reduction 0.0824MeCl2 0.0000TDI 0.0824Cost Effectiveness ($/Ton HAP) $13,759 Chemical Prices for Recovery Credits 

Methylene Chloride 0.485 $/lb 970 $/Ton 2008 value, still close to 0.

listed in 1996 NESHAP ca

TDI 1.05 $/lb 2100 $/Ton 2006 value, still close to 1 

listed in 1996 NESHAP ca

Source: http://www.icis.com/chemicals/channel-info-chemicals-a-z/ 1 p. 7-28 of Gasoline Distribution Proposal BID (EPA-453/R-94-002a), Taking difference in cost of balancing incoming and 

loads ($31,208) and cost of balancing outgoing loads ($23,227) and dividing by two (since this cost is for a bulk plant with ttanks) and then adjusting using Chemical Engineering Plant Cost Index from 1990 (357.6) to 2010 (550.8). 
Attachment 3c. Total Annual Cost Spreadsheet Program Recuperative Thermal 

Oxidizers (RCO) 

Baton Rouge Ethylene Propylene Rubber Front End

Cost Base Date: CEPCI 1999 390.6

Cost Escalation: CEPCI 2010 550.8

 

Input Parameters 

Gas Flowrate (scfm) 15,002

Reference Temperature (oF) 77

Inlet Gas Temperature (oF) 75

Inlet Gas Density (lb/scf) 0.073901176

Primary Heat Recovery (fraction) 0.7

Waste Gas Heat Content (BTU/scf) 0.313

Waste Gas Heat Content (BTU/lb) 4.24

Gas Heat Capacity (BTU/lb-oF) 0.255

Combustion Temperature (oF) 2000

Heat Loss (fraction) 0.01

Exit Temperature (oF) 652.5

Fuel Heat of Combustion (BTU/lb) 21502

Fuel Density (lb/ft3) 0.0408 

Design Parameters 

Auxiliary Fuel Requirement (lb/min) 7.681576526

 (scfm) 188.2739345

Total Gas Flowrate (scfm) 15190.16447

Total Capital Investment ($) 

(Cost Correlations Range: 500 to 50,000 

scfm, 70% Heat Recovery) 

Total Capital Investment – Base $381,462

Total Capital Investment – Escalated $537,915

Annual Cost Inputs 

Operating Factor (hr/yr) 8760

Operating Labor Rate ($/hr) 23.38 2009 Technical labor rate 

Maintenance Labor Rate ($/hr) 25.718 Operator labor rate*1.1 

Operating Labor Factor (hr/sh) 0.5

Maintenance Labor Factor (hr/sh) 0.5

Electricity Price ($/kwh) 0.0685

Natural Gas Price ($/mscf) 5.23

Annual Interest Rate (fraction) 0.07

Control System Life (years) 15

Capital Recovery Factor 0.109794625

Taxes, Insurance, Admin. Factor 0.04

Pressure Drop (in. w.c.) 20
Attachment 3c. Total Annual Cost Spreadsheet Program Recuperative Thermal 

Oxidizers (RCO) 

Annual Costs 

Item Cost ($/yr)

Operating Labor $12,800.55

Supervisory Labor $1,920.08

Maintenance Labor $14,080.61

Maintenance Materials $14,080.61

Natural Gas $517,543.96

Electricity $35,548.54

Overhead $25,729.11

Taxes, Insurance, Administrative $21,516.58

Capital Recovery $59,060.13

Total Annual Cost $702,280
Attachment 3d. Total Annual Cost Spreadsheet Program Regenerative Thermal Oxidizers 

(RTO)

TDI Storage Tank

Cost Base Date: CEPCI 1999 390.6

Cost Escalation: CEPCI 2010 550.8

 

Input Parameters 

Gas Flowrate (scfm) 15,002

Reference Temperature (oF) 77

Inlet Gas Temperature (oF) 75

Inlet Gas Density (lb/scf) 0.073901176

Primary Heat Recovery (fraction) 0.7

Waste Gas Heat Content (BTU/scf) 0.313

Waste Gas Heat Content (BTU/lb) 4.24

Gas Heat Capacity (BTU/lb-oF) 0.255

Combustion Temperature (oF) 2000

Heat Loss (fraction) 0.01

Exit Temperature (oF) 652.5

Fuel Heat of Combustion (BTU/lb) 21502

Fuel Density (lb/ft3) 0.0408 

Design Parameters 

Auxiliary Fuel Requirement (lb/min) 1.301689294

 (scfm) 31.90414935

Total Gas Flowrate (scfm) 15033.79468

Total Capital Investment ($) 

(Cost correlations range: 10,000 to 100,000 scfm) 

Total Capital Investment – Base $634,889

Total Capital Investment – Escalated $895,281

Annual Cost Inputs 

Operating Factor (hr/yr) 8760

Operating Labor Rate ($/hr) 23.38 2009 Technical labor rate 

Maintenance Labor Rate ($/hr) 25.718 Operator labor rate*1.1 

Operating Labor Factor (hr/sh) 0.5

Maintenance Labor Factor (hr/sh) 0.5

Electricity Price ($/kwh) 0.0685

Natural Gas Price ($/mscf) 5.23

Annual Interest Rate (fraction) 0.07

Control System Life (years) 15

Capital Recovery Factor 0.109794625

Taxes, Insurance, Admin. Factor 0.04

Pressure Drop (in. w.c.) 20
Attachment 3d. Total Annual Cost Spreadsheet Program Regenerative Thermal Oxidizers 

(RTO)

Annual Costs 

Item Cost ($/yr)

Operating Labor $12,800.55

Supervisory Labor $1,920.08

Maintenance Labor $14,080.61

Maintenance Materials $14,080.61

Natural Gas $87,700.93

Electricity $35,182.60

Overhead $25,729.11

Taxes, Insurance, Administrative $35,811.25

Capital Recovery $98,297.07

Total Annual Cost $325,603
Attachment 4: 

Memorandum regarding Equipment Leaks in the 

Chemical and Petroleum Industries 
FROM: Cindy Hancy, RTI International 

TO: Jodi Howard, EPA/OAQPS 

FOR: EPA Docket No. EPA-HQ-OAR-2010-0869 

DATE: December 21, 2011 

SUBJECT: Analysis of Emissions Reduction Techniques for Equipment Leaks 

1. Purpose

This memorandum documents a general review and analysis of emissions reduction techniques 

for equipment leaks. It reviews control alternatives and estimates the costs and environmental 

impacts for the alternatives identified. 

2. Legislative Background

The Clean Air Act (CAA) requires the U.S. Environmental Protection Agency (EPA) to review 

promulgated standards periodically to ensure new source performance standards (NSPS) and 

national emissions standards for hazardous air pollutants (NESHAP) reflect advances in 

emissions reduction technology. Specifically, Section 112(d)(6) of the Clean Air Act (CAA) 

states that “[t]he Administrator shall review, and revise as necessary (taking into account 

developments in practices, processes, and control technologies), emission standards promulgated 

under this section no less often than every 8 years.” Similarly, Section 111(b)(1)(B) requires 

EPA to review NSPS for a given source category every 8 years, and, if appropriate, revise such 

standards. To facilitate these required reviews, EPA is evaluating key emission sources that exist 

across several source categories to provide a consistent framework for regulating emissions from 

these sources. This memorandum provides information that may be considered in the course of 

conducting a technology review for equipment leak emissions from a specific source category in 

the future. 

3. Introduction

Equipment leak standards are designed to reduce or eliminate emissions of volatile organic 

compounds (VOCs), volatile hazardous air pollutants (VHAPs), and organic hazardous air 

pollutants (HAPs) from piping and equipment found in various manufacturing processes. Many 

federal regulations have been written to minimize air emissions from equipment leaks. Currently, 

most equipment leaks are defined within regulations primarily on the basis of a detection 

instrument that reads the airborne concentration of volatile organic carbons at a potential leak 

point on a parts per million (ppm) basis or on the basis of visual observation of certain types of 

equipment. Generally, if the leak exceeds the threshold, or leak definition, of the applicable 
Technical Memorandum – Analysis of Emissions Reduction Techniques for Equipment Leaks 

December 21, 2011 

2 

regulation, repair of the leaking equipment is required. This memorandum considers methods to 

reduce emissions from equipment leaks and analyzes the impacts associated with these methods 

(EPA, 1998). 

4. Description of Emission Releases

Emissions from equipment leaks occur in the form of gases or liquids that escape to the 

atmosphere through many types of connection points (e.g., flanges, threaded fittings) or through 

the moving parts of valves, pumps, compressors, pressure relief devices, and certain types of 

process equipment (EPA, 1998). 

Pumps 

Pumps are used extensively in chemical manufacturing facilities for moving fluids. The most 

widely used pump is the centrifugal pump. Other types of pumps include positive-displacement, 

reciprocating and rotary action, and special canned-motor and diaphragm pumps. Chemicals 

transferred by pumps can leak at the point of contact between the moving shaft and stationary 

casing. To isolate the pump’s interior from the atmosphere, all pumps, except the sealless type 

(canned-motor and diaphragm), require a seal at the point where the shaft penetrates the housing. 

The most commonly used seals in these pumps are packed and mechanical. However, no seal 

system is perfect, and many pumps are equipped with a closed-vent system. 

Compressors 

Centrifugal, reciprocating, and rotary compressors are used in chemical manufacturing facilities. 

The centrifugal compressor uses a rotating element or series of elements containing curved 

blades to increase the pressure of a gas by centrifugal force. Reciprocating and rotary 

compressors increase pressure by confining the gas in a cavity and progressively decreasing the 

volume of the cavity. Reciprocating compressors usually use a piston and cylinder arrangement, 

while rotary compressors use rotating elements such as lobed impellers or sliding vanes. 

As with pumps, seals are required to prevent leakage from compressors. Rotary shaft seals for 

compressors may be labyrinth, restrictive carbon rings, mechanical contact, or liquid film. All of 

these seals are leak restriction devices, but none of them completely eliminate leakage. To 

respond to leakage, many compressors are equipped with ports in the seal area that evacuate 

collected gases to a control device. 

Pressure Relief Devices 

Engineering codes require the use of pressure-relieving devices or systems in applications where 

the process pressure may exceed the maximum allowable working pressure of the vessel. The 

pressure relief valve is the most common type of pressure-relieving device used. Typically, relief 

valves are spring-loaded and designed to open when the system pressure exceeds a set pressure, 

allowing the release of vapors or liquids until the system pressure is reduced to its normal 

operating level. When the normal pressure is re-attained, the valve reseats and a seal is again 

formed. The seal is a disc on a seat, and a leak through this seal is a potential source of fugitive 

VOC and HAP emissions. The potential causes of leakage from relief valves are improper 
Technical Memorandum – Analysis of Emissions Reduction Techniques for Equipment Leaks 

December 21, 2011 

3 

reseating of the valve after a relieving operation (which occurs when the system pressure comes 

close to the set pressure of the valve); and corrosion or degradation of the valve seat. Some 

pressure relief devices can be vented to a closed vent system for emissions control. 

Rupture discs also may be used to relieve pressure in process units. These discs are made of a 

material that ruptures when a set pressure is exceeded, thus allowing the system to depressurize. 

The advantage of a ruptured disc is that the disc seals tightly and does not allow any emissions to 

escape from the system during normal operations. When the disc ruptures, however, the system 

will depressurize until atmospheric conditions are obtained (and then remain open to the 

atmosphere until the disk is replaced), unless the disc is used with a pressure relief valve. 

Sampling Connections 

Process unit operations are checked periodically by routine analysis of feedstocks and products. 

To obtain representative samples for these analyses, sampling lines first must be purged. If the 

flushed fluid is a liquid, it could be drained onto the ground or into a process drain where it 

would evaporate and release emissions to the atmosphere. Gas streams could be purged directly 

to the atmosphere. Closed-loop sampling systems control the purged process fluid by returning it 

directly to the process line, collecting and recycling the fluid, or transporting the fluid to a 

control device. 

Open-ended Lines 

Some valves are installed in a system to function with downstream lines open to the atmosphere. 

Open-ended lines, which are used mainly in intermittent service for sampling and venting, 

include purge, drain, and sampling lines. Some open-ended lines are needed to preserve product 

purity. Normally, these are installed between multi-use product lines to prevent products from 

collecting in cross-tie lines during valveseat leakage. A faulty valve seat or incompletely closed 

valve would result in leakage through the valve, releasing emissions to the atmosphere. As 

described in section 5, a cap, plug, blind flange, or secondary valve is used at the end of the 

open-ended line to prevent those emissions from reaching the atmosphere. 

Process Valves 

One of the most common types of equipment included in an equipment leak detection and repair 

program is the process valve. Commonly used types are control, globe, gate, plug, ball, relief, 

and check valves. All except the relief valve and check valve are activated through a valve stem, 

which may have either a rotational or linear motion, depending on the design. The valve stem 

requires a seal to isolate the process fluid inside the valve from the atmosphere. The possibility 

of a leak through this seal makes it a potential source of fugitive emissions. A check valve 

typically is not a potential source of fugitive emissions because it has no stem or packing gland; 

however, some check valves have a hinge that penetrates the valve housing, which is a potential 

source of fugitive emissions. 

The stem can be sealed to prevent leakage by using a packing gland or O-ring seals. Valves that 

require the stem to move in and out with or without rotation must use a packing gland. 

Conventional packing glands are suited for a wide variety of packing material. Packing materials 
Technical Memorandum – Analysis of Emissions Reduction Techniques for Equipment Leaks 

December 21, 2011 

4 

include graphite, graphite-impregnated fibers, and tetrafluorethylene polymer. The packing 

material used depends on the valve application and configuration. These conventional packing 

glands can be used over a range of operating temperatures, but at high pressures, these glands 

must be tight to obtain a good seal. 

Elastomeric O-rings also are used for sealing process valves. These O-rings provide good 

sealing, but are not suitable if sliding motion occurs through the packing gland. These seals are 

used rarely in high pressure service, and operating temperatures are limited by the seal material. 

Bellows seals are generally thought to be more effective for preventing process fluid leaks than 

the conventional packing gland or other gland-seal arrangement. This type of seal incorporates 

formed metal bellows that makes a barrier between the disc and body bonnet joint. The bellows 

are the weak point of this type of system, and service life can be quite variable. Consequently, 

this type of seal normally is backed up with a conventional packing gland and often is fitted with 

a leak detector in case of failure. 

A diaphragm may be used to isolate the working parts of the valve and the environment from the 

process liquid. The diaphragm also may be used to control the flow of the process fluid. In this 

design, a compressor pushes the diaphragm toward the valve bottom, throttling the flow. The 

diaphragm and compressor are connected in a manner so that separating them is impossible 

under normal working conditions. When the diaphragm reaches the valve bottom, it seats firmly 

against the bottom, forming a leak-proof seal. This configuration is recommended for fluids 

containing solid particles and for medium-pressure service. Depending on the diaphragm 

material, this type of valve can be used at temperatures up to 205°C and in severe acid solutions. 

If the seal fails, however, a valve using a diaphragm seal can become a source of leaks. 

Flanges and Other Connectors 

Flanges are bolted, gasket-sealed junctions used wherever pipes or other components or 

equipment (such as vessels, pumps, valves, and heat exchangers) may require isolation or 

removal. Connectors are all other nonwelded fittings that serve a similar purpose to flanges, 

which also allow bends in pipes (elbows), joining two pipes (couplings), or joining three or four 

pipes (tees or crosses). Connectors typically are threaded. 

Flanges may become fugitive emissions sources when leakage occurs because of improperly 

chosen gaskets or poorly assembled flanges. The primary cause of flange leakage is thermal 

stress, which causes deformation of the seal between the flange faces. Threaded connectors may 

leak if the threads become damaged or corroded or if tightened without sufficient lubrication or 

torque (EPA Office of Compliance Chemical, Commercial Services, and Municipal Division, 

1998). 

Agitators 

Agitators are used to stir or blend chemicals. Like pumps and compressors, agitators may leak 

organic chemicals at the point where the shaft penetrates the casing. Consequently, seals are 

required to minimize fugitive emissions. Four seal arrangements commonly are used with 
Technical Memorandum – Analysis of Emissions Reduction Techniques for Equipment Leaks 

December 21, 2011 

5 

agitators: compression packing (packed seal), mechanical seals, hydraulic seals, and lip seals. 

Packed seals for agitators are very similar in design and application to packed seals for pumps. 

Although mechanical seals are more costly than the other three types of seals, they offer a greatly 

reduced leakage rate to offset their higher cost. Furthermore, the maintenance frequency of 

mechanical seals is one-half to one-fourth that of packed seals. At pressures greater than 1,140 

kPa (150 psig), the leakage rate and maintenance frequency are so superior that the use of packed 

seals on agitators is rare. As with packed seals, the mechanical seals for agitators are similar in 

design and application to the mechanical seals for pumps. 

Instrumentation Systems 

Instrumentation systems consist of smaller pipes and tubing that carry samples of process fluids 

to be analyzed to determine process operating conditions or to systems for measurement of 

process operating conditions (e.g., composition, pressure, flow, etc.). Valves and connectors are 

the predominant type of equipment used in instrumentation systems; however, other types of 

equipment may also be included in these systems. These components are generally the source of 

leaks from instrumentation systems as well as fluid that is vented or discharged from the 

analyzer or bypass lines. 

Closed-Vent Systems 

A closed-vent system can be used to collect and convey gaseous emissions from seal oil 

degassing vents, pump and compressor seal leakage, relief valve leakage, and relief valve 

discharges because of over-pressure operation. A process or portion of a process also can be 

enclosed, and the enclosure can be vented through a closed vent system. A closed-vent system 

consists of piping; equipment such as connectors, open-ended lines, and valves; flame arrestors, 

and, if necessary, flow-inducing devices. Closed-vent systems are designed and operated to 

convey emissions to a control device. However, just like in process lines, equipment in a closed 

vent system is a potential source of emissions due to leaks. 

5. Identification of Control Options for Equipment Leaks

There are two primary techniques for reducing equipment leak emissions: (1) modifying or 

replacing existing equipment, and (2) implementing a leak detection and repair (LDAR) 

program. Modifying or replacing existing equipment is referred to as an “equipment 

modification.” Controlling emissions by equipment modification is achieved by either installing 

additional equipment that eliminates or reduces emissions, or replacing existing equipment with 

sealless types. An LDAR program is a structured program to detect and repair equipment that is 

identified as leaking (U.S. EPA Office of Air Quaility Planning and Standards, 1995). 

Equipment Modification Control Alternatives 

For each equipment type there are one or more equipment modifications that can be implemented 

for emissions control. This section reviews the modification alternatives for different equipment 

leak types. 
Technical Memorandum – Analysis of Emissions Reduction Techniques for Equipment Leaks 

December 21, 2011 

6 

Pumps 

Equipment modifications for pumps include routing leaking vapors through a closed-vent system 

to control or replacing the existing pump with a new pump that is designed with dual mechanical 

seals or is a sealless type. 

A pump with dual mechanical seals contains two seals between which a barrier fluid is 

circulated. Depending on the design of the dual mechanical seals, the barrier fluid can be 

maintained at a pressure that is higher than the pumped fluid or at a pressure that is lower than 

the pumped fluid. If the barrier fluid is maintained at a higher pressure than the pumped fluid, the 

pumped fluid will not leak to the atmosphere. The control efficiency of dual mechanical seals 

with a barrier fluid at a higher pressure than the pumped fluid is essentially 100 percent, 

assuming both the inner and outer seal do not fail simultaneously. If the barrier fluid is 

maintained at a lower pressure than the pumped fluid, a leak in the inner seal would result in the 

pumped fluid entering the barrier fluid. To prevent emissions of the pumped fluid to the 

atmosphere, a barrier fluid reservoir system should be used. At the reservoir, the pumped fluid 

can vaporize (i.e., de-gas) and then be collected by a closed-vent system. 

The actual emissions reduction achievable through use of dual mechanical seals depends on the 

frequency of seal failure. Failure of both the inner and outer seals could result in relatively large 

releases of the process fluid. Pressure monitoring of the barrier fluid may be used to detect 

failure of the seals, allowing for a quick response to a failure. 

Sealless pumps, when operating properly, will not leak because the process fluid cannot escape 

to the atmosphere. Sealless pumps are used primarily in processes where the pumped fluid is 

hazardous, highly toxic, or very expensive, and where every effort must be made to prevent all 

possible leakage of the fluid. Under proper operating conditions, the control efficiency of 

sealless pumps is essentially 100 percent; however, if a catastrophic failure of a sealless pump 

occurs, there is a potential for a large quantity of emissions. 

Compressors 

Emissions from compressors may be reduced by collecting and controlling the emissions from 

the seal or by improving seal performance. Shaft seals for compressors are of several different 

types--all of which restrict but do not eliminate leakage. In some cases, compressors can be 

equipped with ports in the seal area to evacuate collected gases using a closed-vent system. 

Additionally, for some compressor seal types, emissions can be controlled by using a barrier 

fluid in a similar manner as described for pumps. 

Pressure Relief Valves 

Equipment leaks from pressure relief valves (PRVs) occur as a result of improper reseating of 

the valve after a release, or if the process is operating too close to the set pressure of the PRV 

and the PRV does not maintain its seal. Emissions occurring from PRVs as a result of an 

overpressure discharge are not considered to be equipment leak emissions. There are two 

primary alternatives for controlling equipment leaks from pressure relief devices: use of a 

rupture disk (RD) in conjunction with the PRV, or use of a closed-vent system. The control 
Technical Memorandum – Analysis of Emissions Reduction Techniques for Equipment Leaks 

December 21, 2011 

7 

efficiency of the RD/PRV combination is assumed to be 100 percent when operated and 

maintained properly. 

A closed-vent system can be used to transport equipment leaks from a PRV to a control device. 

However, the equipment leak control efficiency for a closed-vent system installed on a PRV may 

not be as high as the control efficiency that can be achieved by installing a closed-vent system on 

other equipment types. This is due to the difficulty of designing an efficient control device that 

can handle both high and low flow emissions since emissions from pressure relief devices can be 

either high during an overpressure incident or low when associated with equipment leaks. 

Valves 

Emissions from process valves can be eliminated if the valve stem can be isolated from the 

process fluid. Two types of sealless valves are available: diaphragm valves and sealed bellows 

valves. The control efficiency of both diaphragm and sealed bellows valves is virtually 100 

percent. However, a failure of these types of valves has the potential to cause temporary 

emissions much larger than those from other types of valves. 

Connectors 

In cases where connectors are not required for safety, maintenance, process modification, or 

periodic equipment removal, emissions can be eliminated by welding the connectors together. 

Open-Ended Lines 

Emissions from open-ended lines can be controlled by properly installing a cap, plug, or second 

valve to the open end. If a second valve is installed, the upstream valve should always be closed 

first after use of the valves to prevent the trapping of fluids between the valves. Capping an 

open-ended line has the potential to achieve nearly 100 percent control. However, monitoring 

has shown that capped open-ended lines often leak due to improper installation. 

Sampling Connections 

Emissions from sampling connections occur as a result of purging the sampling line to obtain a 

representative sample of the process fluid. Emissions from sampling connections can be reduced 

by using a closed-loop sampling system or by collecting the purged process fluid and transferring 

it to a control device, back to the process, or for liquids, to a hazardous waste or other type of 

treatment unit. The closed-loop sampling system is designed to return the purged fluid to the 

process at a point of lower pressure. A throttle valve or other device is used to induce the 

pressure drop across the sample loop. The efficiency of a closed-loop system is assumed to be 

100 percent. Alternatively, in some cases, sampling connections can be designed to collect 

samples without purging the line. If such a sampling connection is installed and no emissions to 

the atmosphere occur when a sample is collected, then the control efficiency can be assumed to 

be 100 percent (U.S. EPA Office of Air Quaility Planning and Standards, 1995). 

Instrumentation Systems 

Emissions from the connectors, valves, and other equipment in instrumentation systems can be 

controlled using the same techniques described above for such equipment in process lines. 
Technical Memorandum – Analysis of Emissions Reduction Techniques for Equipment Leaks 

December 21, 2011 

8 

Emissions of material that is purged from the system can be controlled using the same types of 

techniques as described above for sampling connections. 

Agitators 

Agitators are used to stir or blend chemicals. Like pumps and compressors, agitators may leak 

organic chemicals at the point where the shaft penetrates the casing. Consequently, seals are 

required to minimize fugitive emissions. Four seal arrangements commonly are used with 

agitators: compression packing (packed seal), mechanical seals, hydraulic seals, and lip seals. 

Packed seals for agitators are very similar in design and application to packed seals for pumps. 

Leak Detection and Repair Program 

An LDAR program is designed to identify pieces of equipment that are emitting sufficient 

amounts of material to warrant reduction of the emissions through repair. Leak detection 

methods can include sensory inspections (i.e., indications of leaks based on sight, sound, or 

smell) or monitoring with portable organic vapor analyzers in accordance with Method 21. 

Typically, Method 21 has been used to monitor equipment in gas/vapor service and equipment in 

contact with relatively volatile liquids. Sensory inspections are generally used for equipment in 

contact with less volatile liquids (i.e., “heavy” liquid service). These programs are best applied to 

equipment types that can be repaired on-line, resulting in immediate emissions reduction, and/or 

to equipment types for which equipment modifications are not feasible. An LDAR program is 

best suited to valves and pumps, and can also be implemented for agitators and connectors. 

For other equipment types, an LDAR program is not as applicable. Compressors are repaired in a 

manner similar to pumps; however, because compressors ordinarily do not have a spare for 

bypass, a process unit shutdown may be required for repair. Compressors are typically controlled 

by seal systems that include a barrier fluid system. Historically, open-ended lines have been 

controlled solely by equipment modifications (because the modification is expected to achieve 

100 percent emissions reduction). Emissions from sampling connections can only be reduced by 

changing the method of collecting the sample (since, by definition, equipment leak emissions are 

the material purged from the line), and cannot be reduced by an LDAR program. Safety 

considerations may preclude the use of an LDAR program on pressure relief valves. 

Many studies have been performed to estimate the control effectiveness of a given LDAR 

program for light liquid pumps, gas valves, light liquid valves, and connectors. The control 

effectiveness is based on the relationship between the percentage of equipment pieces that are 

leaking and the corresponding average leak emission rate for all of the equipment. The main 

factors in determining the control effectiveness are: (1) how a “leak” is defined, (2) the leak 

frequency before the LDAR program is implemented, and (3) the final leak frequency after the 

LDAR program is implemented. The leak definition (or action level) for a piece of equipment is 

the screening value at which a “leak” is indicated if the instrument reading is equal to or greater 

than that value. The leak frequency is the fraction of equipment with screening values equal to or 

greater than the leak definition (EPA, 1995). 
Technical Memorandum – Analysis of Emissions Reduction Techniques for Equipment Leaks 

December 21, 2011 

9 

New Control Technologies 

No entirely new developments in methods for controlling equipment leak emissions were found. 

However, variations and advancements in existing technologies and practices that are not 

currently required in existing EPA rules have been identified and are listed as follows. 

• Optical gas imaging – Optical gas imaging devices offer the ability to monitor equipment 

from a distance and identify leaks (of a sufficient mass) from equipment within the line 

of sight of the optical imager (Environ International Corporation, 2003). 

• “Low leak” packings – Packing combinations for valves and gaskets for flanges that 

significantly reduce emissions are in place in some facilities, particularly refineries. 

Facilities and packing manufacturers have created emission testing protocols for packings 

in order to study and test their effectiveness. One of these studies, performed by two 

packing manufacturers, revealed that “[s]everal aspects of valve design; including 

tolerances, surface finish, stem straightness and the overall alignment of the stem, stem 

nut and stuffing box were found to be contributing factors to either the failure and/or 

success of a particular stem packing to meet the emission requirements.” These studies 

have lead to advancements such as packing consisting of braided carbon filament end 

rings that encapsulate an Inconel wire mesh with three molded flexible graphite center 

rings (Cornelsen, 2006). 

Some packing manufacturers have begun marketing packings as “low-leak” packing and 

providing performance guarantees. Companies have also developed in-house testing 

programs to ensure that packings are suitable for site-specific applications and to evaluate 

the performance of different materials (Reeves, 2011). 

• Monitoring of new equipment – Some local governments require monitoring on types 

equipment that have not been monitored in the past. In some cases, this is based on data 

collected since LDAR programs where first designed and implemented. For example, 

inspection agencies have conducted monitoring of open ended valves and lines (OELs) at 

numerous facilities and found OELs that are leaking due to improper installation of the 

plugs and other control equipment (Wilwerding 2007, Loukeris 2006). Monitoring on 

atmospheric PRVs for releases and leaks is also required by some local governments 

(Douglas, 2005). 

The South Coast Air Management Quality District (SCAQMD) requires continuous 

monitoring of a percentage of atmospheric PRDs at refineries by installing a monitoring 

device capable of recording the duration of each release and quantifying emissions. 

Wireless technology allows continuous monitoring of PRDs and makes it easy for 

operators to identify releases and leaks. There are several monitoring devices that can be 

used, including acoustic sensors and pressure/differential pressure sensors. These sensor 

units communicate with a base radio that interfaces with the existing control system 

(Ellis, 2007). 
Technical Memorandum – Analysis of Emissions Reduction Techniques for Equipment Leaks 

December 21, 2011 

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6. Summary of Control Options Analyzed 

For the purposes of this memorandum, the baseline control option is a combination of leak 

detection and repair (LDAR) program elements, equipment design standards, and performance 

standards which were based on a review of the requirements and applicability of existing 

regulations, including federal, state, and local rules. The baseline leak detection and repair 

program is equivalent to the requirements in the National Emission Standards for Equipment 

Leaks--Control Level 1 (40 CFR part 63, subpart TT) and Standards of Performance for 

Equipment Leaks of VOC in the Synthetic Organic Compound Manufacturing Industry for 

which Construction, Reconstruction, or Modification Commenced After January 5, 1981 but 

Before November 7, 2006 (40 CFR part 60, subpart VV) and represents the least stringent set of 

requirements that apply to facilities that are currently subject to equipment leaks standards. Thus, 

it is also considered to be the least stringent alternative for a process unit or facility that is 

currently not subject to standards. Table 1 summarizes the requirements of the baseline for all 

equipment. 

Table 1. Baseline Requirements for all Equipment Types 

Equipment Baseline Requirements 

Pumps in light liquid service (Pumps LL) Monthly Method 21 monitoring 

Leak definition of 10,000 ppm 

Pumps in heavy liquid service (Pumps HL) Sensory Monitoring 

Valves in gas and vapor service and Valves in light 

liquid service (Valves G/LL) 

Monthly Method 21 monitoring (or less frequent 

depending on leaks found) 

Leak definition of 10,000 ppm 

Valves in heavy liquid service (Pumps HL) Sensory Monitoring 

Connectors in gas and vapor service and 

Connectors in light liquid service (Connectors G/LL) 

Sensory Monitoring 

Connectors in heavy liquid service (Connectors HL) Sensory Monitoring 

Agitators in gas and vapor service and Agitators in 

light liquid service (Agitators G/LL) 

Monthly Method 21 monitoring 

Leak definition of 10,000 ppm 

Agitators in heavy liquid service (Agitators HL) Sensory Monitoring 

Compressors Barrier fluid options 

Open Ended Lines Cap or comparable 

Sampling Connection Systems (all types of service) All must be closed purge, closed loop, or have a 

closed vent system (CVS) 

Pressure relief devices in gas and vapor service 

(PRV Gas) 

No detectable emissions (or rupture disk CVS/air 

pollution control device (APCD)) 

Pressure relief devices in liquid service (PRV 

Liquid) 

Sensory Monitoring 

Instrumentation Systems For large valves: Comply with applicable 

requirements above 

For all other equipment: Sensory monitoring 
Technical Memorandum – Analysis of Emissions Reduction Techniques for Equipment Leaks 

December 21, 2011 

11 

In addition, this memorandum also analyzes several alternative means of compliance. From the 

baseline, independent alternatives for each component type were developed and are summarized 

in Table 2. This approach provides the ability to analyze the incremental costs and cost 

effectiveness of each alternative individually, while still distributing costs of certain activities 

(such as the use of a monitoring instrument or a database) that apply to, or can be used for, more 

than one type of equipment. Furthermore, many of these alternatives match current regulatory 

requirements for facilities subject to certain existing rules; these alternatives thus can also serve 

as the baseline in analyses of nationwide impacts of regulatory alternatives for source-category 

specific rules that reference the Uniform Standards. 

Table 2. Summary of Equipment Leak Requirement Options 

Alternative Options Additional Requirements 

Valve Option 1 Lowers leak definition of Valves G/LL to 500 ppm 

Valve Option 2 Lowers leak definition of Valves G/LL to 100 ppm 

Pumps Option 1 Lowers leak definition of Pumps LL to 2,000 ppm1

Pumps Option 2 Lowers leak definition of Pumps LL to 500 ppm 

Connectors Option 1 Adds instrument monitoring for Connectors G/LL at 500 ppm 

1

 Note that the regulatory leak definition for pumps is 2,000 ppm; however, data collected at a leak definition of 1,000 

ppm were often used in this analysis to represent pumps with a leak definition of 2,000 ppm. 

Additional Requirements for Open Ended Lines and Pressure Relief Devices 

In addition to the requirements in Table 2, this memorandum also analyses the incremental cost 

of conducting annual instrument monitoring to demonstrate that the open-ended valve or line 

operates with an instrument reading of less than 500 ppm above background (i.e., that the cap, 

blind flange, plug, or second valve seals the open-ended valve or line at all times). It was 

assumed that the annual monitoring would not provide any additional emissions reductions since 

the baseline requires OELs to be capped, but would result in additional monitoring and repair 

costs. The costs of annual monitoring, including repair of any leaks found, are included in 

Section 8. 

The impacts associated with wireless monitoring for PRDs were also analyzed in this 

memorandum. It was assumed that no additional emissions reductions would occur from this 

requirement, but it would result in additional capital costs. Wireless monitoring costs are 

included in Section 8. 

7. Impact Analysis

Model Facilities 

To calculate cost estimates and emissions reductions for potential equipment leak requirements, 

model plants were developed to represent equipment counts found at different types of chemical 

and refining facilities. Six models were created, three to represent chemical manufacturing 

process units and three to represent petroleum refineries. These models allowed for the 
Technical Memorandum – Analysis of Emissions Reduction Techniques for Equipment Leaks 

December 21, 2011 

12 

consideration of the costs and emissions reduction impacts for processes of various sizes in 

multiple industries. The six models are summarized in Table 3. 

Table 3. Model Plants 

 

 Type of Equipment 

Number of Pieces of Equipment 

Model 1 Model 2 Model 3 Model 4 Model 5 Model 6 

Simple 

Chemical

Medium 

Chemical

Complex 

Chemical

Topping 

Refinery 

Small 

Refinery 

Large 

Refinery 

Pump Seals 

 * Light-liquid service 15 40 56 8 69 176 

 * Heavy-liquid service 0 5 36 8 61 246 

Valves 

 * Gas/vapor service 77 414 1,379 75 1,178 3,263 

 * Light-liquid service 380 1,179 1,980 251 2,428 5,857 

 * Heavy-liquid service 0 71 1,272 216 1,719 3,163 

Connectors 

 * Flanges - gas/vapor 164 2,333 7,641 

 * Flanges - G/LL 731 2,662 7,410 555 4,644 13,379 

 * Flanges - HL 454 4,186 7,725 

Agitators 

* Light-liquid service 0 3 0 0 0 0 

* Heavy-liquid service 0 3 0 0 0 0 

Compressor Vent 0 2 8 2 19 31 

Open-ended Valves 33 141 424 39 238 902 

Sampling Connections 8 35 106 10 70 159 

Pressure Relief Devices 2 45 76 9 79 119 

 

Total Equipment Counts 1,246 4,600 12,747 1,791 17,024 42,661 

Models 1-3 represent a range of chemical manufacturing process units and are based on the 

models used in the Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC 

in the SOCMI (Parrish, 2007). These equipment counts encompassed a large range of individual 

process units at chemical manufacturing facilities. However, a facility with numerous process 

units could have many times more pieces of equipment than Model 3. Focus was placed on small 

facilities since that size range is where the impacts are most likely to be more burdensome. When 

impacts for Model 3 are reasonable, we can be certain that they will also be reasonable for larger 

facilities. 

Models 4-6 represent different size refineries, from a simple topping refinery to a complex 

refinery. The equipment counts presented for small and large refineries in Locating and 

Estimating Air Emissions from Sources of Benzene (EPA, 1998) were used to estimate the 

number of pieces of equipment in each type of refinery process unit. Model 4, the topping 
Technical Memorandum – Analysis of Emissions Reduction Techniques for Equipment Leaks 

December 21, 2011 

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refinery, was assumed to consist of one crude distillation unit. Except for PRV, the equipment 

counts for that model are equal to the counts for a crude distillation unit at a small refinery in 

Locating and Estimating Air Emissions from Sources of Benzene (EPA, 1998). The PRV counts 

were estimated based on a summary of data collected through EPA’s Petroleum Refinery 

Information Collection Request (ICR) (EPA, 2011). 

Models 5 and 6 were developed using information from the U.S. Energy Information 

Administration (EIA) on the number of refineries in the U.S., their capacities, and the types of 

processes at each (U.S. DOE, 2011). The EIA report includes production capacity of facilities in 

barrels per day (bbl/d) and the downstream charge capacity of each plant divided into process 

type (vacuum distillation, delayed coking, fluid coking, visbreaking, and other processes). Since 

Locating and Estimating Air Emissions from Sources of Benzene defines the “large model 

refinery” as a refinery with a crude charge capacity greater than 50,000 barrels per stream day, 

refineries were classified as “large” or “small” based on the capacity in the EIA report. The 

number of each type of process at an average “small” refinery and an average “large” refinery 

was estimated based on the data in the EIA report. For example, the EIA report included 40 

“small” refineries, 24 of which reported vacuum distillation capacity. Therefore, it was assumed 

for purposes of developing a small refinery model that an average small refinery has 0.6 vacuum 

distillation units. Finally, the number of each type of process was multiplied by the appropriate 

equipment counts in Locating and Estimating Air Emissions from Sources of Benzene, and the 

results were summed for each type of equipment except for PRV. The PRV counts were 

estimated based on a summary of data from the Petroleum Refinery ICR. References for model 

facilities are included in attachment 1. 

The goal was to develop models as representative of the potential affected sources as possible so 

that the model plants can be used in the future to develop source category-specific nationwide 

impact estimates in an efficient manner. There are process units and facilities larger than the 

largest model; however, these models are intended to cover a range of sizes representing a 

majority of the potential affected facilities. In addition, the options considered for the Uniform 

Standards that are affected by economies of scale will have a greater impact on smaller processes 

than larger processes. These models can be adjusted as needed based on data for a specific 

source category or industry to represent that source category or industry more accurately. 

Leak Frequencies 

Leak frequency refers to the estimated percentage of equipment that will be found leaking at a 

given leak definition. Leak frequencies were used to calculate both cost and emission estimates 

and are included in Table 4 and 5. Leak frequencies were estimated using several sources 

including the Protocol for Equipment Leak Emissions Estimates and industry data. Attachment 2 

includes the basis for the leak frequencies in Tables 4 and 5. Detailed information on how leak 

frequencies were used in cost and emission estimates is included in the following sections. 
Technical Memorandum – Analysis of Emissions Reduction Techniques for Equipment Leaks 

December 21, 2011 

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Table 4. Summary of Equipment Leak Frequency % for Model 1-3

Equipment Leak Frequencies % (Initial/Subsequent) 

Pump Seals 

LL Valves GV Valves LL 

Agitators 

LL 

Connectors 

G/V and LL OELs 

Baseline 2.42 / 0.23 0.33 / 0.33 0.33 / 0.33 2.42 / 0.23 NA NA 

Valves 

Option 1 NA 7.24 / 0.51 4.84 / 0.51 NA NA NA 

Valves 

Option 2 NA 12.24 / 0.61 8.07 / 0.61 NA NA NA 

Pumps 

Option 1 13.48 / 0.26 NA NA NA NA NA 

Pumps 

Option 2 18.43 / 0.33 NA NA NA NA NA 

Connectors 

Option 1 NA NA NA NA 0.36 / 0.36 NA 

OELs Annual 

Monitoring NA NA NA NA NA 0.90 / 0.45 

Table 5. Summary of Equipment Leak Frequency % for Model 4-61

Equipment Leak Frequencies % (Initial/Subsequent) 

Pump 

Seals LL Valves GV Valves LL 

Agitators 

LL 

Connectors 

G/V 

Connectors 

LL OELs 

Baseline 0.88 / 0.88 1.18 / 1.18 1.38 / 1.38 0.88 / 0.88 NA NA NA 

Valves 

Option 1 NA 5.95 / 1.91 6.30 / 1.97 NA NA NA NA 

Valves 

Option 2 NA 14.73 / 1.28 

15.14 / 

1.17 NA NA NA NA 

Pumps 

Option 1 3.31 / 0.98 NA NA NA NA NA NA 

Pumps 

Option 2 4.57 / 1.26 NA NA NA NA NA NA 

Connectors 

Option 1 NA NA NA NA 1.70 / 0.81 1.70 / 0.81 NA 

OELs 

Annual 

Monitoring 

NA NA NA NA NA NA 2.30 / 

1.15 

1

 U.S. EPA National Enforcement Investigations Center (NEIC) data on leak frequencies for valves at refineries 

suggest the actual percentage leaking may be higher. In order to account for this, it was estimated that the actual 

percentage leaking is 1.7 times higher than typically measured leak frequencies. This factor represents the 10th 

percentile of the data set (i.e., 90 percent of the NEIC leak frequencies were at least 1.7 times higher than the leak 

frequencies reported by the refineries) and was used determining leak frequencies (Parrish et al., 2007). 
Technical Memorandum – Analysis of Emissions Reduction Techniques for Equipment Leaks 

December 21, 2011 

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Emission Reductions 

In order to calculate the emissions reductions that result from the baseline requirements, we first 

had to estimate uncontrolled emissions. Once the emissions reductions of the baseline were 

found, the incremental emissions reductions of each control alternative were also calculated. The 

incremental emissions reductions of each option is incremental with respect to the previous 

option for a given equipment type. For example, the emissions reduction for pumps Option 1 is 

based on the additional emissions reductions of Option 1 with respect to the baseline pump 

emissions; similarly, the emissions reduction of pumps Option 2 is based on the additional 

emission reduction of Option 2 with respect to Option 1. The following sections describe how 

these emissions were calculated. 

The first step in calculating emissions was to establish emission factors for each equipment type. 

Emission factors are the estimated leak rates of an equipment type at a given leak definition and 

are normally given in kg/hr/piece of equipment. Tables 6 and 7 summarize the leak emission 

factors used for Models 1-3 and 4-6, respectively. Attachment 3 includes detailed information on 

the basis for these emission factors.
Technical Memorandum – Analysis of Emissions Reduction Techniques for Equipment Leaks 

December 21, 2011 

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Table 6. Emission Factors for Chemical Manufacturing Plant Models 

Emission Factors for Chemical Manufacturing Plant Models 1-3 (kg/hr/piece of equipment)1

Uncontrolled Baseline Valve Option 1 Valve Option 2 Pumps Option 1 Pump

Option 

Pump Seals LL 1.23E-02 2.51E-03 NA NA 6.95E-04 5.31E-Valves G/V 5.22E-04 3.52E-04 2.03E-04 1.82E-04 NA NA Valves LL 5.86E-04 3.90E-04 2.32E-04 2.05E-04 NA NA Connectors – Flanges G/V 3.07E-04 3.07E-04 NA NA NA NA Connectors – Flanges G/LL 3.07E-04 3.07E-04 NA NA NA NA Agitators LL 1.23E-02 2.51E-03 NA NA NA NA Compressor Vent 2.28E-01 2.28E-02 NA NA NA NA Open-ended Valves 1.70E-03 3.33E-05 NA NA NA NA Sampling Connections 1.50E-02 NA NA NA NA NA PRV – Disks 1.04E-01 NA NA NA NA NA 

1 Equipment in HL service was not included in this analysis because we are unable to quantify the reductions that are achieved using se
Technical Memorandum – Analysis of Emissions Reduction Techniques for Equipment Leaks 

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Table 7. Emission Factors for Refinery Models 

Emission Factors for Refinery Plant Models 4-6 (kg/hr/piece of equipment)1

Uncontrolled Baseline Valve Option 1 Valve Option 2 Pumps Option 1 Pum

Optio

Pump Seals LL 1.05E-03 7.11E-04 NA NA 3.26E-04 3.22EValves G/V 3.71E-04 2.24E-04 8.85E-05 2.10E-05 NA NA Valves LL 3.75E-04 2.23E-04 8.88E-05 2.02E-05 NA NA Connectors – Flanges G/V 1.04E-04 1.04E-04 NA NA NA NA Connectors – Flanges G/LL 8.46E-05 8.46E-05 NA NA NA NA Agitators LL 1.05E-03 NA NA NA NA NA Compressor Vent 6.36E-01 3.18E-02 NA NA NA NA Open-ended Valves 2.30E-03 7.34E-05 NA NA NA NA Sampling Connections 1.50E-02 NA NA NA NA NA PRV – Disks 1.60E-01 NA NA NA NA NA 1 Equipment in HL service was not included in this analysis because we are unable to quantify the reductions that are achieved using se
Technical Memorandum – Analysis of Emissions Reduction Techniques for Equipment Leaks 

December 21, 2011 

18 

Uncontrolled emissions were calculated by multiplying the emission factors in Tables 6 and 7, 

the equipment counts of each model, and the operating hours (which were assumed to be 8,760 

hours/yr). Uncontrolled emissions for each model are summarized in Table 8. Attachment 4 

provides detailed calculations. 

Table 8. Uncontrolled Emissions for Each Model 

Model 

Total Uncontrolled 

Emissions (lb/yr) 

Total Uncontrolled 

Emissions (tpy) 

Model 1 20,400 10.2 

Model 2 157,000 78.7 

Model 3 326,000 163 

Model 4 61,000 30.4 

Model 5 548,000 274 

Model 6 941,000 471 

Once uncontrolled baseline emissions were established, emission estimates were calculated for 

the baseline. The leak definitions under the baseline are 10,000 ppm for pumps LL, valves G/LL, 

and agitators in G/LL. Therefore, the leak emission factors for the baseline (summarized in Table 

6 and 7) for these equipment types are based on a leak definition of 10,000 ppm. These leak 

emission factors were multiplied by the equipment counts for each model and 8,760 hours to get 

annual emissions. As stated in Section 5, the efficiency of the control methodologies for 

sampling connections and PRVs in gas service is expected to be 100 percent; therefore, 

implementing the requirements of the baseline for these types of equipment results in essentially 

zero emissions for those equipment types. Emission reductions from sensory requirements were 

assumed to be zero because we are unable to quantify emissions reductions associated with 

sensory requirements. Baseline compressor vent emissions estimates are based on emission 

factors used in the HON analysis (Whitt, 1991), assuming the seal system barrier fluid would be 

routed to a reservoir where the fluid could degas and the vapors routed to a control device. For 

OELs, we used the emissions factors documented in previous analyses (Parrish and Randall, 

2007; Parrish et al., 2007) at the leak frequencies described earlier in this section. Table 9 

summarizes baseline emissions for all model plants. 
Technical Memorandum – Analysis of Emissions Reduction Techniques for Equipment Leaks 

December 21, 2011 

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Table 9. Baseline Emissions Summary 

Option 1 Emissions (lb/yr) 

Equipment Type Model 1 Model 2 Model 3 Model 4 Model 5 Model 6 

Pump Seals 

Light-liquid service 728 1,940 2,717 110 948 2,418 

Valves 

Gas/vapor service 523 2,814 9,374 324 5,092 14,106 

Light-liquid service 2,863 8,884 14,920 1,082 10,471 25,259 

Connectors 

Flanges - gas/vapor 0 0 0 330 4,693 15,371 

Flanges - G/LL 4,334 15,782 43,932 906 7,584 21,849 

Agitators 

Light-liquid service 0 146 0 -- -- -- 

Compressor Vent 0 881 3,523 1,228 11,669 19,038 

Open-ended Valves 21 91 273 55 337 1,278 

TOTAL (lb/yr) 8,470 31,538 74,737 4,036 40,795 99,319 

TOTAL (tpy) 4.23 15.27 37.37 2.02 20.40 49.66 

The emission reductions for the baseline were calculated by subtracting total baseline emissions 

from total uncontrolled emissions. The alternative options for each equipment type provide 

additional reductions by increasing the baseline requirements of that equipment type. Table 10 

summarizes emissions reductions of the baseline, as well as the additional reductions of each 

subsequent option. Detailed calculations are included in Attachment 4. 
Technical Memorandum – Analysis of Emissions Reduction Techniques for Equipment Leaks 

December 21, 2011 

20 

Table 10. Emissions Summary 

Emissions Reductions Summary (tpy) 

Model 1 Model 2 Model 3 Model 4 Model 5 Model 6 

Uncontrolled Emissions 10.2 78.7 163 30.4 274 471 

Baseline Emissions 4.23 15.3 37.4 2.02 20.4 49.7 

Baseline Emissions 

Reductions 5.96 63.5 126 28.4 254 421 

Additional Incremental Reductions: 

Valves Option 1 (wrt to 

Baseline valve 

emissions) 

0.69 2.40 5.02 0.42 4.69 11.87 

Valves Option 2 (wrt to 

Valves Option 1) 0.12 0.43 0.92 0.24 2.55 6.65 

Pumps Option 1 (wrt to 

Baseline pump 

emissions) 

0.26 0.70 0.98 0.03 0.26 0.65 

Pumps Option 2 (wrt to 

Pumps Option 1) 0.02 0.06 0.09 0.0003 0.003 0.007 

Connectors Option 1 

(wrt to Baseline 

connector emissions) 

1.02 3.7 10.4 0.41 4.0 12.1 

8. Control Costs 

The cost analysis uses a methodology that was originally presented in Impacts from the Control 

of VHAP Emissions from Equipment Leaks in Non-SOCMI Process Units for HON (Whitt, 

1991). The methodology has been tailored specifically for this analysis. Several constant values 

used in this analysis were developed for previous analyses and are detailed in this section. 

Cost calculations can fall into three categories: 

1. Monitoring and Equipment Costs 

2. Leak Repair Costs 

3. Planning and training Costs 

The first step was to estimate the costs of implementing the baseline. Once this was completed, 

the incremental cost of each alternative was calculated. This section will analyze each cost 

estimates and summarize the costs for each option. 

Labor Hour Rates 

Wage rate estimates used to calculate costs were based on data from the U.S. Department of 

Labor, Bureau of Labor Statistics for general manufacturing sectors (Sectors 31, 32, and 33) 

(BLS, 2010). Overhead factors and fringe benefits were added to labor rates when necessary. 

Table 11 summarizes the wage rates and overhead factors used to estimate costs for each option. 
Technical Memorandum – Analysis of Emissions Reduction Techniques for Equipment Leaks 

December 21, 2011 

21 

Table 11. Summary of 2009 Hourly Labor Rates 

Activity $/hr Basis for Estimate 

General manufacturing - 

Installation, maintenance, repair 

occupations 

22.08 

Mean hourly wage for Installation, Maintenance, and Repair 

Occupations 

(Standard Occupational Classification (SOC) Code 49-0000) 

(BLS, 2010) 

Plant and system operators 22.72 Mean hourly wage for Plant and System Operators, All Other 

(SOC Code: 51-8099) (BLS, 2010) 

Environmental engineering 39.53 Mean hourly wage for Environmental Engineers 

(SOC Code: 17-2081) (BLS, 2010) 

General and operations 

managers 

57.80 Mean hourly wage for Engineering Managers 

(SOC Code: 11-9041) (BLS, 2010) 

General office and admin support 17.31 

Mean hourly wage for Office and Administrative Support 

Occupations 

(SOC Code: 43-0000) (BLS, 2010) 

Planning and training labor 

charge1 92.72 

Weighted average for technical (39.53), management (57.80), 

and clerical labor (17.31). The weighted average assumes 

5 hours of management time and 10 hours of clerical effort per 

100 hours of technical labor. Includes overhead factor for 

planning and training. 

Leak Repair Labor Charge2 66.24 

The general manufacturing sector - Installation, Maintenance, 

and Repair Occupations labor rate with the overhead factor 

applied was used for all repairs 

1

 A planning and training overhead factor of 2.1 was used based on Technology Review for Heat Exchange Systems 

(Coburn, 2011). 

2

 A maintenance and repair overhead factor of 3 was used based on a 200 percent overhead factor (which -correlates 

to a factor of 3) based on the overhead factor used for performance testing contractors in the CEMS Cost Model 

(EPA, 2002). 

Monitoring and Equipment Modification Costs 

Initial monitoring costs are considered capital costs and are higher than annual monitoring costs 

in order to account for implementation. They are incurred once at the start of the program and 

were calculated by multiplying the equipment counts in a given model by an estimated initial 

monitoring fee. Table 12 summarizes the monitoring fees for each equipment type and the basis 

for each. 
Technical Memorandum – Analysis of Emissions Reduction Techniques for Equipment Leaks 

December 21, 2011 

22 

 Table 12. Initial monitoring Fees 

Monitoring Fee ($/ 

equipment piece) Basis 

Pumps LL 23.80 Includes field identification of subject equipment; creating and 

issuing drawings; creating data forms and tags; tagging of the 

pumps and valves; and populating the software. The value also 

assumes that contractors are performing this work. (Updated from 

Eastman Chemical Co, 1999.) 

Valves G/LL 

Agitators LL 

OELs 

Pumps HL 1.10 Based on an estimate of 3 minutes to monitor each piece of 

equipment at a “general manufacturing sector - installation, 

maintenance, and repair occupations” wage rate. (Update from 

Eastman Chemical Co, 1999.) 

Valves HL 

Agitators HL 

Connectors 

Annual monitoring costs vary by the number of times the equipment type has to be monitored 

per year. Table 13 summarizes the annual monitoring fees by equipment type. The annual 

monitoring costs are calculated by multiplying the equipment counts by the monitoring fee and 

the monitoring frequency. 

Table 13. Annual monitoring/maintenance Fees 

Subsequent Monitoring 

Fee ($/equipment piece) Basis 

Pumps LL 1.50 Based on information provided by a monitoring and 

repair contractor (Parrish, 2006) Valves G/LL 

Agitators LL 

OELs 

Connectors GV/LL 2.50 

Equipment modification costs are considered to be capital costs and were calculated for the 

baseline requirements to equip open-ended valves with caps or other comparable seals, install 

rupture discs on pressure relief devices in gas service, to equip compressor vents with a seal 

system, and to retrofit sample connection systems to be closed purge, closed loop, or have a 

closed vent system. Table 14 summarizes the initial cost for these requirements and the basis for 

each cost estimate. 
Technical Memorandum – Analysis of Emissions Reduction Techniques for Equipment Leaks 

December 21, 2011 

23 

Table 14. Equipment Modification Costs for PRVs, OEVs, Sampling Connections, and 

Compressor vents 

Equipment/ 

Device Type 

Initial 

Cost 

($2010) Unit Basis Reference 

Pressure Relief 

Devices 

* Disks 

122.11 $/ equipment Cost of one rupture disk. Escalated vendor quote 

(Hausle & Whitt, 1992) 

* Disk holders, 

valves, etc. 6,374.29 $/ equipment 

Equipment cost of 1 gate 

valve, tee, elbow, rupture 

disk holder, pressure 

gauge, bleed valve, steel 

body/trim and labor costs 

(36 labor hours). 

Escalated labor and 

equipment cost (Hausle & 

Whitt, 1992) 

Open-ended 

Valves 140.92 $/ equipment 

Cost for one 2.5 cm gate 

valve for open ended 

lines and 1.4 labor hours 

Escalated from costs provided 

in Hausle & Whitt, 1992 

Sampling 

Connections 687.86 $/ equipment 

Equipment cost for 6 

meter pipe, 3 ball valves 

and 2.4 labor hours. 

Escalated from costs provided 

in Hausle & Whitt, 1992 

Compressor 

Vent Seal 10,526.21 $/ equipment 

Equipment cost of 122 

meter pipe, 3 steel 

valves, 1 flame arrestor, 

and 78 labor hours. 

Escalated from costs provided 

in Hausle & Whitt, 1992 

Monitoring instrumentation is also necessary for Method 21 monitoring, as well as a data 

collection system to store monitoring records. Instrumentation and data collection systems are 

capital costs that were estimated at $10,800 and $14,500, respectively, per facility. The estimated 

instrumentation costs are roughly equal to the cost to purchase a standard TVA1000B flame 

ionization detector (FID)-only monitor with probe from Thermo Fisher Scientific (2011). The 

data collection system cost was based on Revised MACT Floor, Regulatory Alternatives, and 

Nationwide Impacts for Equipment Leaks at Chemical Manufacturing Facilities (Shine et al., 

2003). 

Initial costs for PRD wireless monitoring device capable of identifying and recording the time 

and duration of each pressure release and calculating the quantity of regulated material released 

were also analyzed in addition to the baseline PRD requirements. There are several types of 

wireless monitoring systems and costs vary depending on the number of PRDs at a facility. 

Based on cost studies from a SCAQMD staff report, the estimated cost of wireless monitoring 

was assumed to be 7,500 dollars per PRD (the midpoint of the range provided by Ellis (2007), 

which includes device parts, installation, maintenance, and data retrieval system. Annual 

operating costs were not included in this analysis because they are assumed to be minimal. 

Because the cost of electronic monitoring is not linear and facilities requiring a large number of 

monitors will benefit from economies of scale, the sixth-tenths rule was applied to calculate 

initial costs which are provided below (Ellis, 2007). 
Technical Memorandum – Analysis of Emissions Reduction Techniques for Equipment Leaks 

December 21, 2011 

24 

Leak Frequency and Repair Costs 

The control options summarized in Tables 1 and 2 require Method 21 monitoring and repair of 

leaks for certain equipment types. Repair costs are a function of the leak frequency of a given 

equipment type. An initial leak frequency represents the equipment found to be leaking the first 

time the monitoring is conducted using a particular leak definition. The cost to repair these initial 

leaks is considered as initial LDAR costs (along with initial monitoring fees). The subsequent 

leak frequency represents the equipment found to be leaking after a few monitoring cycles have 

been completed and the program reaches “steady state” the cost to repair subsequent leaks are 

considered annual repair costs. Generally, the subsequent leak frequency is estimated to be less 

than the initial leak frequency, but in some cases they are assumed to be the same. For example, 

the initial leak frequencies for the baseline are the estimated percentages of uncontrolled 

equipment leaking above the 10,000 ppm leak definition, and the subsequent leak frequencies are 

the estimated percentage of “leakers” once the initial leaks are repaired and the requirements are 

in place. If initial or subsequent leak frequencies increase for a control alternative, the initial 

LDAR costs or the annual repair costs can increase because there are more leaks to repair; these 

additional repair costs are considered incremental costs for each alternative option. Leak 

frequencies were estimated using several sources including the Protocol for Equipment Leak 

Emissions Estimates and industry data. As previously stated, attachment 2 includes the basis for 

the leak frequencies in Tables 4 and 5. 

The cost to repair initial and subsequent leaks is also based on whether the repair can be 

performed online and the number of hours required to repair the leak. The general manufacturing 

sector - Installation, Maintenance, and Repair Occupations labor rate with the overhead factor 

applied ($66.24/hr) was used for all repairs. Table 15 includes the assumptions used to estimate 

the cost of repairing leaks and attachment 5 provides detailed cost calculations. 

Table 15. Summary of Leak Repair Assumptions 

Equipment Type 

Percent Repaired 

Online 

Hours Required 

to repair online 

Leak 

Percent Repaired 

Offline 

Hours Required 

to repair Offline 

Leak 

Pumps LL 100% 16.00 0 NA 

Agitators 100% 16.00 0 NA 

Valves LL/G 75% 0.17 25% 4.00 

Connectors1 75% 0.17 25% 2.00 

OELs2 75% 0.17 25% 4.00 

1

 Not applicable to Option 1-3 since connectors are not required to perform Method 21 monitoring and leak repair. 

2

 Only applicable to annual monitoring requirement (not used in baseline calculations of OELs). 

As part of the initial (LDAR) repair cost for pumps we assumed that the seals would need to be 

replaced. The cost to purchase replacement pump seals was estimated to be $282.71/leaking 

pump (updated from Hausle, 1992); therefore, initial LDAR cost for pumps also includes the cost 

of replacement pumps seals multiplied by the number of initial leaks (in addition to the initial 

monitoring and repair costs). The annual cost of pump replacements is included as an annual 
Technical Memorandum – Analysis of Emissions Reduction Techniques for Equipment Leaks 

December 21, 2011 

25 

maintenance cost. Leak repair costs also include additional monitoring of the repaired leaks in 

order to verify the equipment was completely fixed. These costs are considered annual costs and 

were calculated using the subsequent monitoring fee for the equipment type and the subsequent 

number of equipment leaking. 

Baseline cost estimates for OELs only include the costs related to installing caps and annual 

maintenance and do not include any OEL repair costs. OEL repair costs were only used when 

calculating incremental cost of annual monitoring on OELs (see Table 17). 

Maintenance and Miscellaneous Costs 

For pumps and agitators, annual maintenance costs were included and are based on the annual 

number of leaks multiplied by the updated cost of a replacement seal, $282.71 (Hausle, 1992). 

Annual maintenance costs were also included for PRVs, OELs, sampling connections, and 

compressor vents as a percentage of initial monitoring fees. For PRV disk holders, OELs, 

sampling connections, and compressor vents, annual maintenance costs were based on 5 percent 

of initial monitoring costs and 2 percent of initial monitoring costs for PRV disks. 

Annual miscellaneous costs were also included in this analysis for pumps, PRDs, OELs, 

sampling connections, and compressor vents. For pumps and agitators, the miscellaneous costs 

are based on 80 percent of the annual maintenance costs. For PRDs, OELs, sampling connections 

and compressor vents, the annual miscellaneous charges are estimated using 4 percent of initial 

monitoring costs (Hausle, 1992). 

Administrative, Reporting, Planning, and Training Labor Costs 

Planning and training costs are initial costs associated with the implementation of an LDAR 

program. These costs include initial review of requirements and training of facility personnel. 

We estimated initial planning and training costs based on an estimate of 320 labor hours and a 

labor rate of $92.72/hr. The value of 320 hours per process unit is based on an estimate of initial 

administration, planning, and training to implement a SOCMI-based LDAR program (Meardon, 

1998). Planning and training costs were included in baseline estimates, and it was assumed that 

no additional planning and training costs would be incurred with any of the alternative options 

for pumps and valves (i.e., incremental costs of planning and training was assumed to be 0 for all 

alternative options). For connectors, it was assumed that an additional 20 hours would be 

required for activities such as adding connectors to the LDAR database for instrument 

monitoring. 

Annual reporting and administrative costs were estimated using 250 hours at a labor rate of 

$92.72/hr to account for preparation of annual reports and recordkeeping. The 250 hour estimate 

was based on the ratio of the amount of hours required for LDAR programs with and without 

connectors which is estimated at 8 people at 32 hours each in Equipment Leak Analysis for 

Amino and Phenolic Resins NESHAP (Meardon, 1998). Development of the labor rate is 

discussed in Table 11. Annual reporting costs were included in baseline estimates and it was 

assumed that no additional annual reporting costs would be incurred with any of the alternative 

options for pumps and valves (i.e., incremental costs of planning and training was assumed to be 

$0 for all alternative options). For connectors, it was assumed that an additional 50 hours would 
Technical Memorandum – Analysis of Emissions Reduction Techniques for Equipment Leaks 

December 21, 2011 

26 

be required for preparation of annual reports and recordkeeping once the LDAR program 

included instrument monitoring for connectors. 

Annualized Initial Costs 

Initial capital costs and labor expenditures were annualized using capital recovery factors. The 

following equation was used to calculate capital recovery factors (EPA, 2002): 

 CRF = [i * (1+i)n)] / [(1+i)n – 1], 

Where, i is the interest rate and n is the life span in years. 

For pump seals and rupture disks, the capital recovery factor is 0.244, assuming a life span of 5 

years. For all other equipment types, the capital recovery factors is 0.142 based on a life span of 

10 years. We also annualized initial repair labor and planning and training costs over 10 years. 

For both factors, an interest rate of 7 percent was used. The impacts analysis also includes a 

recovery credit for the material that is not lost as emissions from equipment leaks. As in the 

Technology Review for Heat Exchange Systems (Coburn, 2011), these credits are $500/ton VOC. 

Incremental Costs 

Once the total initial and annual costs for the implementation of baseline requirements was 

determined, the incremental annual cost of each alternative option was estimated. Similar to 

incremental emissions reductions, incremental costs are the additional costs of the option with 

respect to the preceding option. The incremental costs were based on the additional repair costs 

(initial and subsequent) of the lower leak definition of a given alternative option and any 

additional costs that are calculated as a function of leaks (maintenance costs, annual 

miscellaneous charges, and monitoring costs to verify off line repairs). It was assumed that there 

are no incremental costs associated with monitoring fees, administrative costs, and planning and 

training (except as described for connectors) since these are constant and should not increase 

with a lower leak frequency. Detailed incremental cost calculations are included in attachment 5. 

Cost Summary 

Cost estimates are summarized in Table 16 and Table 17. Detailed cost calculations are included 

in attachment 5 
Technical Memorandum – Analysis of Emissions Reduction Techniques for Equipment Leaks 

December 21, 2011 

27 

Table 16. Baseline Detail Cost Summary 

Baseline 

Model 

Capital Cost 

($) 

Annualized Costs 

Without Recovery 

Credits ($/yr) 

VOC Recovery 

Credit ($/yr) 

Total Annualized 

Cost ($/yr) 

Model 1 90,763 41,009 (2,980) 38,029 

Model 2 455,982 129,599 (31,731) 97,867 

Model 3 859,162 226,203 (62,822) 163,381 

Model 4 156,783 57,067 (14,180) 42,887 

Model 5 956,067 263,308 (126,809) 136,499 

Model 6 1,658,781 461,483 (210,466) 251,017 

Table 17. Summary of Incremental Annualized Cost Estimates for all Control Alternatives 

(Including Recovery Credits) 

Baseline 

Valve 

Option 1 

Valve 

Option 2 

Pumps 

Option 1 

Pumps 

Option 2 

Connectors 

Option 1 

Model Total Cost ($/yr) Incremental Cost ($/yr) 

Model 1 38,029 15 901 312 354 7,360 

Model 2 97,867 97 3,223 831 944 13,861 

Model 3 163,381 358 7,076 1,163 1,322 29,846 

Model 4 42,887 268 2,815 189 437 7,714 

Model 5 136,499 3,033 27,993 1,628 3,772 32,188 

Model 6 251,017 7,725 79,562 4,152 9,622 87,089 

The cost for the additional requirements for PRDs and OELs are summarized in Table 18. 

Incremental costs for each of these options are with respect to the baseline. 

Table 18. Additional Costs of Wireless Monitoring for PRDs and Annual OEL Monitoring 

(Incremental to Baseline) 

Type of 

Facility 

Facility Initial Cost 

PRD Wireless 

Electronic 

Monitoring ($)1

Annualized 

Incremental PRD 

Wireless Electronic 

Monitoring ($/yr) 

Capital Cost of 

Annual OEL 

Monitoring ($) 

Annualized 

Incremental Cost 

of Annual OEL 

Monitoring ($/yr) 

Model 1 11,368 1,619 808 176 

Model 2 73,619 10,482 3,453 750 

Model 3 100,821 14,355 10,383 2,256 

Model 4 28,029 3,991 997 234 

Model 5 103,190 14,692 6,082 1,429 

Model 6 131,944 18,786 23,049 5,415 

1

 Costs calculated using six-tenths rule. 
Technical Memorandum – Analysis of Emissions Reduction Techniques for Equipment Leaks 

December 21, 2011 

28 

9. Cost Effectiveness

The cost effectiveness of baseline is calculated by dividing the total annual costs (including 

recovery credits) by the total emissions reduction of the baseline. Similarly, incremental cost 

effectiveness was calculated by dividing the incremental cost of each option (including recovery 

credits) by the incremental emissions reductions. Tables 19-22 summarize the cost effectiveness 

of each control alternative analyzed in this memorandum. 

Additional requirements for wireless monitoring for PRDs and annual monitoring of OELs were 

not included in the cost effectiveness summary since no emissions reductions from these 

activities is expected. 

Table 19. Baseline Cost Effectiveness Summary 

Model 

Emission 

Reductions 

(tpy) 

Total Annual 

Cost ($/yr) 

Cost 

Effectiveness 

($/ton VOC) 

Model 1 5.96 38,029 6,380 

Model 2 63.46 97,867 1,542 

Model 3 125.64 163,381 1,300 

Model 4 28.36 42,887 1,512 

Model 5 253.62 136,499 538 

Model 6 420.93 251,017 596 

Table 20. Valve Options Cost Effectiveness Summary 

Valves Option 1 Valves Option 2 

Model 

Incremental 

Annualized 

Cost ($) 

Incremental 

Emissions 

Reduction 

(tpy) 

Overall Cost 

Effectiveness 

($/ton) 

Incremental 

Annualized 

Cost ($) 

Incremental 

Emissions 

Reduction 

(tpy) 

Overall Cost 

Effectiveness 

($/ton) 

Model 1 15 0.69 22 901 0.12 7,323 

Model 2 97 2.40 40 3,223 0.43 7,506 

Model 3 358 5.02 71 7,076 0.92 7,701 

Model 4 268 0.42 633 2,815 0.24 11,588 

Model 5 3,033 4.69 646 27,993 2.55 10,994 

Model 6 7,725 11.87 651 79,562 6.65 11,966 
Technical Memorandum – Analysis of Emissions Reduction Techniques for Equipment Leaks 

December 21, 2011 

29 

Table 21. Pump Options Cost Effectiveness Summary 

Pumps Option 1 Pumps Option 2 

Model 

Incremental 

Annualized 

Cost ($) 

Incremental 

Emissions 

Reduction 

(tpy) 

Overall Cost 

Effectiveness 

($/ton) 

Incremental 

Annualized 

Cost ($) 

Incremental 

Emissions 

Reduction 

(tpy) 

Overall Cost 

Effectiveness 

($/ton) 

Model 1 312 0.26 1,184 354 0.024 14,977 

Model 2 831 0.70 1,184 944 0.063 14,977 

Model 3 1,163 0.98 1,184 1,322 0.088 14,977 

Model 4 189 0.030 6,339 437 0.00031 1,429,098 

Model 5 1,628 0.26 6,339 3,772 0.0026 1,429,098 

Model 6 4,152 0.65 6,339 9,622 0.0067 1,429,098 

Table 22. Connector Option 1 Cost Effectiveness Summary (Incremental to Baseline) 

Connectors Option 1 (Incremental to Baseline) 

Model 

Incremental 

Annualized 

Cost ($) 

Incremental 

Emissions 

Reduction (tpy)

Overall Cost 

Effectiveness 

($/ton) 

Model 1 7,360 1.02 7,192 

Model 2 13,861 3.73 3,719 

Model 3 29,846 10.37 2,877 

Model 4 7,714 0.41 18,957 

Model 5 32,188 4.00 8,038 

Model 6 87,089 12.11 7,191 

9. References

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Facilities Subject to the Group IV Polymers and Resins NESHAP. Docket A-92-45, 

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Valve World, February 2006, pp 49-52. 
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Douglas, Victor. (2005). BAAQMD Staff Report: Proposed Amendments to Regulation 8, Rule 

28: Episodic Release from Pressure Relief Devices at Petroleum Refineries and Chemical 

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1998. Docket No. A-92-19, Document No. II-B-11. 

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Technical Memorandum – Analysis of Emissions Reduction Techniques for Equipment Leaks 

December 21, 2011 

31 

Shine, Brenda, Melissa Icenhour, and David Randall. (2003) Memorandum: Revised MACT 

Floor, Regulatory Alternatives, and Nationwide Impacts for Equipment Leaks at Chemical 

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http://www.fishersci.com/ecomm/servlet/fsproductdetail_10652_6471343_29104_-1_0. 

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33.htm. 

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from Sources of Benzene. Office of Air Quality Planning and Standards. EPA-454/R-98-011. 

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Refinery Information Collection Request (ICR) for Calendar Year 2010. March 31, 2011. 

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Whitt, Daryl J. (1991). Impacts From the Control of VHAP Emissions from Equipment Leaks in 

non-SOCMI Process Units for the HON. Radian Corporation. Docket No. A-90-20, 

Document No. II-B-7. 

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Investigations Center. Transmitted via email to Karen Rackley. June 14, 2007. Docket Item 

No. EPA-HQ-OAR-2006-0699-0072. 
Attachment 1

Based on data in Refinery Capacity 2010 (U.S. DOE, 2011) and the analysis of amendments to 40 CFR part 60, subp

Number of process units in average small refinery: Number of process units in average large re

0.9 Crude Distillation 1 Crude Distillation0.1 Alkylation (sulfuric acid) 0.4 Alkylation (sulfuric ac0.1 Alkylation (HF) 0.4 Alkylation (HF)0.5 Catalytic Reforming 1.1 Catalytic Reforming0.1 Hydrocracking 0.5 Hydrocracking1.5 Hydrotreating/Hydrorefining 3.7 Hydrotreating/Hydrore0.3 Catalytic Cracking 0.9 Catalytic Cracking

0.03 Thermal Cracking (visbreaking) 0.02 Thermal Cracking (vis

0.1 Thermal Cracking (coking) 0.6 Thermal Cracking (co0.2 Hydrogen Plant 0.4 Hydrogen Plant0.7 Asphalt Plant 0.4 Asphalt Plant

1 Product Blending 1 Product Blending

0.7 Sulfur Plant 1.3 Sulfur Plant0.6 Vacuum Distillation 0.9 Vacuum Distillation

2 Full-Range Distillation 3 Full-Range Distillation

0.3 Isomerization 0.6 Isomerization0.2 Polymerization 0.2 Polymerization

0.05 MEK Dewaxing 0.05 MEK Dewaxing

0.2 Other Lube Oil Processes 0.1 Other Lube Oil Proces

0.08 Aromatics 0.2 Aromatics
Chemical Manufacturing Leak Frequencies (Used to calculate Repair Costs)

Type of Equipment

Initial Leak 

Frequency 

(%)

Basis

Subsequent 

Leak 

Frequency 

(%)

Ba

Pump Seals * Light-liquid service 2.42

Calculated using table 1 of Revised MACT floor, Regulatory Alternatives, and Nationwide Impacts for Equipment Leaks at Chemical Manufacturing Facilities MON Memorandum 5/5/2003 and TABLE 5-4. EQUATIONS RELATING AVERAGE LEAK RATE TO FRACTION LEAKING AT SOCMI UNITS of the Protocol for Equipment Leak Emission Estimates. Calculation of this value shown in this attachment. 0.23

Memorandum: Final Impacts AOptions for Equipment Leaks oAttachment E

Valves

 * Gas/vapor service 0.33

Set equal to the Subsequent Leak Frequency (Calculated a leak frequency of 0.22 using procedure similar to pumps above; however, this value was not used because it is less than the Subsequent Leak Frequency) 0.33

Memorandum: Final Impacts AOptions for Equipment Leaks oAttachment E

 * Light-liquid service 0.33

Set equal to the Subsequent Leak Frequency (Calculated a leak frequency of 0.22 using procedure similar to pumps above; however, this value was not used because it is less than the Subsequent Leak Frequency) 0.33

Memorandum: Final Impacts AOptions for Equipment Leaks oAttachment E

Connectors * Flanges - gas/vapor N/A N/A * Flanges - light liquid N/A N/AAgitators * Light-liquid service 2.42 Same as pump seals 0.23 Same as pump sealsOEL N/A N/A

Baseline
Chemical Manufacturing Leak Frequencies (Used to calculate Repair Costs)

Type of Equipment

Initial Leak 

Frequency 

(%)

Basis

Subsequent 

Leak 

Frequency 

(%)

Ba

Valves

 * Gas/vapor service 7.24

Sum of Initial Leak Frequency at 10,000 ppm (Baseline; see above) and Initial Leak Frequency at 500 ppm (Memorandum: Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC in the SOCMI, Attachment E) 0.51

Memorandum: Final Impacts AOptions for Equipment Leaks oAttachment E

 * Light-liquid service 4.84

Sum of Initial Leak Frequency at 10,000 ppm (Baseline; see above) and Initial Leak Frequency at 500 ppm (Memorandum: Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC in the SOCMI, Attachment E) 0.51

Memorandum: Final Impacts AOptions for Equipment Leaks oAttachment E

Type of Equipment

Initial Leak 

Frequency 

(%)

Basis

Subsequent 

Leak 

Frequency 

(%)

Ba

Pump Seals * Light-liquid service 13.48

Sum of Initial Leak Frequency at 10,000 ppm (Baseline; see above) and Initial Leak Frequency at 1,000 ppm (Memorandum: Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC in the SOCMI, Attachment E) 0.26

Memorandum: Final Impacts AOptions for Equipment Leaks oAttachment E

Type of Equipment

Initial Leak 

Frequency 

(%)

Basis

Subsequent 

Leak 

Frequency 

(%)

Ba

Connectors * Flanges - gas/vapor 0.36

Memorandum: Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC in the SOCMI, Attachment E 0.36

Memorandum: Final Impacts AOptions for Equipment Leaks oAttachment E

 * Flanges - light liquid 0.36

Memorandum: Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC in the SOCMI, Attachment E 0.36

Memorandum: Final Impacts AOptions for Equipment Leaks oAttachment E

Option 1 for Pumps 

Option 1 for Connectors 

Option 1 for Valves
Chemical Manufacturing Leak Frequencies (Used to calculate Repair Costs)

Type of Equipment

Initial Leak 

Frequency 

(%)

Basis

Subsequent 

Leak 

Frequency 

(%)

Ba

Valves

 * Gas/vapor service 12.24

Sum of Initial Leak Frequency at 10,000 ppm (Baseline; see above), Initial Leak Frequency at 500 ppm (Memorandum: Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC in the SOCMI, Attachment E), and Initial Leak Frequency at 100 ppm of 5.00% (Calculation of this value shown in this attachment) 0.61

= Subsequent Leak Frequency 100 ppm (Semiannual monitorFrequency for Average Refine(Semiannual monitoring) x SubChemical Manufacturing Valvemonitoring)

 * Light-liquid service 8.07

Sum of Initial Leak Frequency at 10,000 ppm (Baseline; see above), Initial Leak Frequency at 500 ppm (Memorandum: Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC in the SOCMI, Attachment E), and Initial Leak Frequency at 100 ppm of 3.22% (Calculation of this value shown in this attachment) 0.61

= Subsequent Leak Frequency 100 ppm (Semiannual monitorFrequency for Average Refine(Semiannual monitoring) x SubChemical Manufacturing Valvemonitoring)

Type of Equipment

Initial Leak 

Frequency 

(%)

Basis

Subsequent 

Leak 

Frequency 

(%)

Ba

Pump Seals * Light-liquid service 18.43

Sum of Initial Leak Frequency at 10,000 ppm (Baseline; see above), Initial Leak Frequency at 1,000 ppm (Memorandum: Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC in the SOCMI, Attachment E), and Initial Leak Frequency at 500 ppm of 4.95% (Calculation of this value shown in this attachment) 0.33

= Subsequent Leak Frequency Pumps, 1,000 ppm (Monthly mFrequency for Refinery Pumpsmonitoring) / Subsequent Leak Pumps, 1,000 ppm (Quarterly 

Option 2 for Pumps

Option 2 for Valves
Chemical Manufacturing Leak Frequencies (Used to calculate Repair Costs)

Type of Equipment

Initial Leak 

Frequency 

(%)

Basis

Subsequent 

Leak 

Frequency 

(%)

Ba

OEL 0.90

Memorandum: Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC in the SOCMI, Attachment K 0.45

Assume that since an instrume

greater means that the OEL is owners/operators will be more caps and plugs are replaced pcollect samples. This increaselead to a reduction in leaks.

OEL Monitoring
Refinery Leak Frequencies (Used to calculate Repair Costs)

Type of Equipment

Initial Leak 

Frequency 

(%)

Basis

Subsequent 

Leak 

Frequency 

(%)

Bas

Pump Seals * Light-liquid service 0.88 Set equal to the Subsequent Leak Frequency 0.88

Memorandum: Final Impacts AnOptions for Equipment Leaks of Refineries, Attachment D

Valves

 * Gas/vapor service 1.18 Set equal to the Subsequent Leak Frequency 1.18

Memorandum: Final Impacts AnOptions for Equipment Leaks of Refineries, Attachment D

 * Light-liquid service 1.38 Set equal to the Subsequent Leak Frequency 1.38

Memorandum: Final Impacts AnOptions for Equipment Leaks of Refineries, Attachment D

Connectors * Flanges - gas/vapor N/A N/A * Flanges - light liquid N/A N/AAgitators * Light-liquid service 0.88 Same as pump seals 0.88 Same as pump sealsOEL N/A N/A

Type of Equipment

Initial Leak 

Frequency 

(%)

Basis

Subsequent 

Leak 

Frequency 

(%)

Bas

Valves

 * Gas/vapor service 5.95

Sum of Initial Leak Frequency at 10,000 ppm (see above) and Initial Leak Frequency at 500 ppm (Memorandum: Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC in Petroleum Refineries, Attachment E) 1.91

Memorandum: Final Impacts AnOptions for Equipment Leaks of Refineries, Attachment D

 * Light-liquid service 6.30

Sum of Initial Leak Frequency at 10,000 ppm (see above) and Initial Leak Frequency at 500 ppm (Memorandum: Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC in Petroleum Refineries, Attachment E) 1.97

Memorandum: Final Impacts AnOptions for Equipment Leaks of Refineries, Attachment D

Baseline

Option 1 for Valves
Refinery Leak Frequencies (Used to calculate Repair Costs)

Type of Equipment

Initial Leak 

Frequency 

(%)

Basis

Subsequent 

Leak 

Frequency 

(%)

Bas

Pump Seals * Light-liquid service 3.31

Sum of Initial Leak Frequency at 10,000 ppm (see above) and Initial Leak Frequency at 1,000 ppm (Memorandum: Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC in Petroleum Refineries, Attachment E) 0.98

Memorandum: Final Impacts AnOptions for Equipment Leaks of Refineries, Attachment D

Type of Equipment

Initial Leak 

Frequency 

(%)

Basis

Subsequent 

Leak 

Frequency 

(%)

Bas

Connectors * Flanges - gas/vapor 1.70

Protocol for Equipment Leak Emission Estimates, USEPA, November 1995 (EPA-453/R-95-017), Table G-2 0.81

Average Percent Leaking G and (API Data, Quarterly Monitoring Impacts Analysis for Regulatory Leaks of VOC in Petroleum Refquarters/year x 0.9 (10% repeat 

 * Flanges - light liquid 1.70

Protocol for Equipment Leak Emission Estimates, USEPA, November 1995 (EPA-453/R-95-017), Table G-2 0.81

Average Percent Leaking G and (API Data, Quarterly Monitoring Impacts Analysis for Regulatory Leaks of VOC in Petroleum Refquarters/year x 0.9 (10% repeat 

Option 1 for Pumps 

Option 1 for Connectors 
Refinery Leak Frequencies (Used to calculate Repair Costs)

Type of Equipment

Initial Leak 

Frequency 

(%)

Basis

Subsequent 

Leak 

Frequency 

(%)

Bas

Valves

 * Gas/vapor service 14.73

Sum of Initial Leak Frequency at 10,000 ppm (Baseline; see above), Initial Leak Frequency at 500 ppm (Memorandum: Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC in Petroleum Refineries, Attachment E), and Initial Leak Frequency at 100 ppm of 8.78% (Calculation of this value shown in this attachment) 1.28

Estimated subsequent leak freqvalves at 500 ppm to be 2.45% leak frequencies at other leak dFinal Impacts Analysis for ReguLeaks of VOC in Petroleum RefSince this value is greater than would be required.Subsequent Leak Frequency, 1Monitoring) = Subsequent Leak (Quarterly Monitoring) / Subseqppm (Semiannual Monitoring) x Frequency, 100 ppm (Semiannu

 * Light-liquid service 15.14

Sum of Initial Leak Frequency at 10,000 ppm (Baseline; see above), Initial Leak Frequency at 500 ppm (Memorandum: Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC in Petroleum Refineries, Attachment E), and Initial Leak Frequency at 100 ppm of 8.83% (Calculation of this value shown in this attachment) 1.17

Estimated subsequent leak freqvalves at 500 ppm to be 2.24% leak frequencies at other leak dFinal Impacts Analysis for ReguLeaks of VOC in Petroleum RefSince this value is greater than would be required.Subsequent Leak Frequency, 1Monitoring) = Subsequent Leak (Quarterly Monitoring) / Subseqppm (Semiannual Monitoring) x Frequency, 100 ppm (Semiannu

Option 2 for Valves
Refinery Leak Frequencies (Used to calculate Repair Costs)

Type of Equipment

Initial Leak 

Frequency 

(%)

Basis

Subsequent 

Leak 

Frequency 

(%)

Bas

Pump Seals * Light-liquid service 4.57

Sum of Initial Leak Frequency at 10,000 ppm (Baseline; see above), Initial Leak Frequency at 1,000 ppm (Memorandum: Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC in Petroleum Refineries, Attachment E), and Initial Leak Frequency at 500 ppm of 1.26% (Calculation of this value shown in this attachment) 1.26

= Subsequent Leak Frequency, Monitoring) / Subsequent Leak (Quarterly Monitoring) x Averag500 ppm (API Data, Quarterly M

Type of Equipment

Initial Leak 

Frequency 

(%)

Basis

Subsequent 

Leak 

Frequency 

(%)

Bas

OEL 2.30

Memorandum: Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC in Petroleum Refineries, Attachment K 1.15

Assume that since an instrumen

greater means that the OEL is oowners/operators will be more dcaps and plugs are replaced procollect samples. This increased lead to a reduction in leaks.

OEL Monitoring

Option 2 for Pumps
Table 1: Resulting Emission Rates and Program Efficiencies for CMA data. 

Component

LeakDefinition

(ppmv)

No.Monitored No. Leaking

Initial LeakRate (%)

Pumps 500 121 0

0

1000 683 13 1.92000 82 0

0 G Valves 500 20766 104 

5000 374 39 10.43 5000 161 0 

10000 662 13 1.96 10000 7062 41 

Valves 500 62299 312 0.5 LL Valves 500 41533 208 

5000 483 0

0 5000 322 0 

10000 21185 123 0.58 10000 14123 82 

Source: Memo: Revised MACT floor, Regulatory Alternatives, and Nationwide Impacts for Equipment Leaks at CFacilities MON. From Brenda Shine, Melissa Icenhour, and David Randall 5/5/2003

Initial Leak Freq ‐ 10,000 ppm 
Uncontrolled

Emissions NEIC Factor 1.71

ALR @ 500 ppm (kg/hr/source)

Leak fraction @ 10,000 ppm

Leak fraction @ 10,000 ppm (%)

Average Uncontrolled Leak Rate

Average 

Uncontrolled Emission Factor (kg/hr/source)

Gas Valves 0.000394 0.00339 0.339 0.501974818 5.22E-04

Light Liquid Va 0.000430 0.00292 0.292 0.467353214 5.86E-04Valves (using L 0.000429764 2.92E-03 2.92E-01 0.46735321 0.000585944

ALR @ 1,000 ppm (kg/hr/source)

Leak fraction @ 10,000 ppm

Leak fraction @ 10,000 ppm (%)

ALR @ 5,000 ppm

Leak fraction @ 10,000 ppm

Leak fraction @ 10,000 ppm (%)

Average Uncontrolled Leak Rate

Average Uncontrolled Emission Fac(kg/hr/source)

Pumps 0.004042028 0.00892512 0.89251157 0.03715172 0.146882176 14.68822 4.332354 0.0122976

Rate for costs

ALR @ 500 ppm (kg/hr/source)

Leak fraction @ 10,000 ppm

Leak fraction @ 10,000 ppm (%)

Average Uncontrolled Leak Rate

Valves 0.000262 1.03E-03 1.03E-01 0.22303044

ALR @ 1,000 ppm (kg/hr/source)

Leak fraction @ 10,000 ppm

Leak fraction @ 10,000 ppm (%)

ALR @ 5,000 

ppm (kg/hr/source)

Leak fraction @ 10,000 ppm

Leak fraction @ 10,000 ppm

Average 

Uncontrolled Leak Rate

Pumps 0.00255 0.00266393 0.26639344 0.02226 0.084833333 8.483333 2.420517

Based on 5-46 of Equipment Leaks Protocol Equations and Revised MACT Floor, reg alternative, and nationwidleaks... memo. May 5 2003

Initial Leak Freq ‐ 10,000 ppm 
Chemical Manufacturing Models - Gas Valves - From 500 to 100

EPA's SOCMI data

Protocol no 

control % 

leakersa

leak 

concentration

Percent 

leakers when 

monitored

assumed typical 

screening value in the 

range to the next 

thresholda

10 26 10 39.7

100 17.5 100 1.05 Option 232

500 13.6 500 0.87 Baseline 665

1000 12 1000 1330

2000 10.5 2000 2990

5000 8.7 5000 6650

10000 7.5 10000 23200

50000 5.5 50000 66500

100000 4.5 100000 397000 39700

1000000

Distribution

leak 

concentration

Percent 

leakers when 

monitored

500 0.72

1000 0.632000 0.525000 0.45

50000 0.33

100000 0.27

Leak Freq calcs 100 500

Baseline 0.51Option 8, Initial 5.0Option 8, Subsequent 0.61

aFrom figure B-3-3 in the Protocol document

Emissions New Calcs 
Chemical Manufacturing Models - Gas Valves

Use correlation equation to estimate emissions for uncontrolled scenario1 - No control 2 - Baseline before control 3 - Baseline c

GV default zero 6.60E-07 Average above

Instantaneous 500

Leak 

Definition

Range of 

concentrations

Percent of 

values in 

rangea

Average 

screening value 

in range

Emission rate, 

kg/hr (per 100 

valves)

Percent of 

values in 

rangea

Emission rate, 

kg/hr (per 100 

valves)

Percent of 

values in 

rangea

E

k

<10 74.0 0.00004884 84.9 0.00005604 85.3 

10 10 to 100 8.5 39.7 0.000395 9.8 0.000454 9.8 

100 100 to 500 3.9 232 0.000847 4.5 0.000972 4.5 

500 500 to 1000 1.6 665 0.000872 0.10 0.000056 0.05 

1000 1000 to 2000 1.5 1330 0.001496 0.10 0.000095 0.05 2000 2000 to 5000 1.8 2990 0.003642 0.11 0.000232 0.06 5000 5000 to 10000 1.2 6650 0.004879 0.08 0.000311 0.04 

10000 10000 to 50000 2.0 23200 0.024207 Pegged value 0.13 0.001543 0.06 50000 50000 to 100000 1.0 66500 0.030350 0.11 0.06 0.001935 0.03 

100000 >100000 4.5 310000 0.523616 0.495 0.29 0.033375 0.14 

Emission rate 

per valve

Emission rate 

per valve

E

0.00590 0.00562 0.00039 

Emission rate estimated using (500 ppm) (10,000 ppm) (

 ALR equation 0.0060 0.00050 

Leak Frequency Calculations Baseline Option

<10 74.0 <10 85.2 89.1

10 10 to 100 8.5 10 to 100 9.8 10.2

100 100 to 500 3.9 0.61 100 to 500 4.5 0.14

500 500 to 1000 1.6 0.51 500 to 1000 0.06 0.06

1000 1000 to 2000 1.5 1000 to 2000 0.06 0.05

2000 2000 to 5000 1.8 2000 to 5000 0.07 0.06

5000 5000 to 10000 1.2 5000 to 10000 0.04 0.04

10000 10000 to 50000 2.0 10000 to 50000 0.07 0.07

50000 50000 to 100000 1.0 50000 to 100000 0.04 0.03

100000 >100000 4.5 >100000 0.17 0.16

Emissions New Calcs 
Chemical Manufacturing Models - Gas Valves

Use correlation equation to estimate controlled emissions (for HON program)

4 - Option 8 prior to control 5 - Option 1 controlled

GV default zero 6.60E-07 Average above, assume half repairs are 

100

Leak 

Definition

Range of 

concentrations

Percent of 

values in 

range

Average 

screening value 

in range

Emission rate, kg/hr 

(per 100 valves) when 

monitored

Emission 

rate after 

repair, kg/hr

Percent of 

values in 

rangea

Emission rate, 

kg/hr (per 100 

valves)

<10 88.8 0.0000586 0.000066 89.3 0.0000589

10 10 to 100 10.2 39.7 0.000474 10.3 0.000477

100 100 to 500 0.23 232 0.000051 0.16 0.000034

500 500 to 1000 0.10 665 0.000052 0.05 0.000026

1000 1000 to 2000 0.09 1330 0.000090 0.04 0.0000452000 2000 to 5000 0.11 2990 0.000218 0.05 0.0001095000 5000 to 10000 0.07 6650 0.000292 0.04 0.000146

10000 10000 to 50000 0.12 23200 0.001448 0.06 0.00072450000 50000 to 100000 0.06 66500 0.001816 0.03 0.000908

100000 >100000 0.27 310000 0.031327 0.13 0.015663

Emission rate per 

valve

Emission rate 

per valve

0.000358 0.00000066 0.000182

Average emission rate

 during monitoring period 0.000179

Emissions New Calcs 
Chemical Manufacturing Models - Light Liquid Valves - from 500 to 100

EPA's SOCMI data

Protocol no 

control % 

leakersa

leak 

concentration

Percent 

leakers when 

monitored

assumed typical 

screening value in the 

range to the next 

thresholda

10 18 10 39.7

100 11 100 1.05 Option 232

500 8.5 500 0.87 Baseline 665

1000 7 1000 1330

2000 5.8 2000 29905000 5.1 5000 6650

10000 4.5 10000 23200

50000 2.9 50000 66500

100000 2.2 100000 397000 39700

1000000

Distribution

leak 

concentration

Percent 

leakers when 

monitored

500 0.81

1000 0.672000 0.555000 0.49

10000 0.4350000 0.28

100000 0.21

Leak Freq calcs 500 10000

Baseline 0.27Option, Initial 3.2Option, Subsequent 0.61

aFrom figure B-3-4 in the Protocol document

Emissions New Calcs 
Chemical Manufacturing Models - Light Liquid Valves

Use correlation equation to estimate emissions for uncontrolled scenario1 - No control 2 - Baseline before control 3 - Baseline c

LLV default zero 4.90E-07 Average above

Instantaneous 500

Leak 

Definition

Range of 

concentrations

Percent of 

values in 

rangea

Average 

screening value 

in range

Emission rate, 

kg/hr (per 100 

valves)

Percent of 

values in 

rangea

Emission rate, 

kg/hr (per 100 

valves)

Percent of 

values in 

rangea

E

k

<10 82.0 0.0000402 88.8 0.0000435 89.2 

10 10 to 100 7.0 39.7 0.000844 7.6 0.000914 7.6 

100 100 to 500 2.5 232 0.001231 2.7 0.001333 2.7 

500 500 to 1000 1.5 665 0.001709 0.2 0.000174 0.1 

1000 1000 to 2000 1.2 1330 0.002375 0.1 0.000242 0.1 2000 2000 to 5000 0.7 2990 0.002643 0.1 0.000270 0.0 5000 5000 to 10000 0.6 6650 0.004283 0.1 0.000437 0.0 

10000 10000 to 50000 1.6 23200 0.030922 Pegged value 0.2 0.003154 0.1 50000 50000 to 100000 0.7 66500 0.031314 0.15 0.1 0.003194 0.0 

100000 >100000 2.2 310000 0.335657 0.33 0.2 0.034232 0.1 

Emission rate 

per valve

Emission rate 

per valve

E

Emission rate per valve 0.00411 0.00405 0.00044 

Emission rate estimated using (500 ppm) (10,000 ppm) (

 ALR equation 0.00402 0.00058 

Leak Frequency Calculations Baseline Option

<10 82.0 <10 89.2 91.6

10 10 to 100 7.0 10 to 100 7.6 7.8

100 100 to 500 2.5 0.61 100 to 500 2.7 0.14

500 500 to 1000 1.5 0.51 500 to 1000 0.1 0.08

1000 1000 to 2000 1.2 1000 to 2000 0.1 0.07

2000 2000 to 5000 0.7 2000 to 5000 0.0 0.04

5000 5000 to 10000 0.6 5000 to 10000 0.0 0.03

10000 10000 to 50000 1.6 10000 to 50000 0.1 0.0950000 50000 to 100000 0.7 50000 to 100000 0.0 0.04

100000 >100000 2.2 >100000 0.1 0.12

Emissions New Calcs 
Chemical Manufacturing Models - Light Liquid Valves

Use correlation equation to estimate controlled emissions (for HON program)

4 - Option 1 prior to control 5 - Option 1 controlled

LLV default zero 4.90E-07 Average above, assume half repairs are 

100

Leak 

Definition

Range of 

concentrations

Percent of 

values in 

range

Average 

screening value 

in range

Emission rate, kg/hr 

(per 100 valves) when 

monitored

Emission 

rate after 

repair, kg/hr

Percent of 

values in 

rangea

Emission rate, 

kg/hr (per 100 

valves)

<10 91.2 0.0000447 0.000049 91.7 0.0000449

10 10 to 100 7.8 39.7 0.000938 7.8 0.000943

100 100 to 500 0.24 232 0.000117 0.16 0.000078

500 500 to 1000 0.14 665 0.000163 0.07 0.000081

1000 1000 to 2000 0.11 1330 0.000226 0.06 0.000113

2000 2000 to 5000 0.07 2990 0.000252 0.03 0.0001265000 5000 to 10000 0.06 6650 0.000408 0.03 0.000204

10000 10000 to 50000 0.15 23200 0.002943 0.08 0.00147250000 50000 to 100000 0.07 66500 0.002981 0.03 0.001490

100000 >100000 0.21 310000 0.031948 0.10 0.015974

Emission rate per 

valve

Emission rate 

per valve

Emission rate per valve 0.000400 0.00000049 0.000205

Average emission rate 

 during monitoring period 0.000200 

vs.

Emissions New Calcs 
Chemical Manufacturing Models - Pumps - from 1000 to 500

EPA's SOCMI data

Protocol no 

control % 

leakersa

leak 

concentration

Percent 

leakers when 

monitored

assumed typical 

screening value in the 

range to the next 

thresholda

10 44 500 0.56 Option 665

100 30 1000 0.44 Baseline 1330

500 21 2000 2990

1000 17.1 5000 6650

2000 13.2 10000 23200

5000 9.8 50000 66500

10000 7 100000 397000 39700

50000 3.5 1000000

100000 2

Distribution

leak 

concentration

Percent 

leakers when 

monitored

500 99.59

1000 99.702000 99.795000 99.86

10000 99.9650000 100.00

100000 100.05

Leak Freq calcs 500 1000

Baseline 0.26Option, Initial (NSPS) 4.9Option, Subsequent 0.33

aFrom figure B-3-2 in the Protocol document

Emissions New Calcs 
Chemical Manufacturing Models - Pumps

Use correlation equation to estimate emissions for uncontrolled scenario1 - No control 2 - Baseline before control 3 - Baseline c

P default zero 7.50E-06 Average above

Instantaneous 1000

Leak 

Definition

Range of 

concentrations

Percent of 

values in 

rangea

Average 

screening value 

in range

Emission rate, 

kg/hr (per 100 

pumps)

Percent of 

values in 

rangea

Emission rate, 

kg/hr (per 100 

pumps)

Percent of 

values in 

rangea

E

k

<10 56.0 0.00042 67.3 0.000504408 67.4 0

10 10 to 100 14.0 39.7 0.005524 16.8 0.006635 16.9 

100 100 to 500 9.0 232 0.015211 10.8 0.018268 10.8 500 500 to 1000 3.9 665 0.015697 4.7 0.018852 4.7 

1000 1000 to 2000 3.9 1330 0.027789 0.1 0.000714 0.1 2000 2000 to 5000 3.4 2990 0.047226 0.1 0.001214 0.0 5000 5000 to 10000 2.8 6650 0.075148 0.1 0.001931 0.0 

10000 10000 to 50000 3.5 23200 0.263017 Pegged value 0.1 0.006758 0.0 50000 50000 to 100000 1.5 66500 0.268442 0.62 0.0 0.006898 0.0 

100000 >100000 2.0 310000 1.272523 1.2400 0.1 0.032698 0.0 

Emission rate 

per pump

Emission rate 

per pump

E

Emission rate per valve 0.01991 0.01958 0.00094 

Emission rate estimated using (1,000 ppm) (10,000 ppm) (

 ALR equation 0.0000 0.00233 

Leak Frequency Calculations Baseline Option

<10 56.0 <10 67.4 70.7

10 10 to 100 14.0 10 to 100 16.8 17.7

100 100 to 500 9.0 100 to 500 10.8 11.4500 500 to 1000 3.9 0.33 500 to 1000 4.7 0.06

1000 1000 to 2000 3.9 0.26 1000 to 2000 0.1 0.06

2000 2000 to 5000 3.4 2000 to 5000 0.1 0.055000 5000 to 10000 2.8 5000 to 10000 0.0 0.04

10000 10000 to 50000 3.5 10000 to 50000 0.1 0.0550000 50000 to 100000 1.5 50000 to 100000 0.0 0.02

100000 >100000 2.0 >100000 0.0 0.03

Emissions New Calcs 
Chemical Manufacturing Models - Pumps

Use correlation equation to estimate controlled emissions (for HON program)

4 - Option 9 prior to control 5 - Option 9 controlled

P default zero 7.50E-06 Average above, assume half repairs are 

500

Leak 

Definition

Range of 

concentrations

Percent of 

values in 

range

Average 

screening value 

in range

Emission rate, kg/hr 

(per 100 pumps) when 

monitored

Emission 

rate after 

repair, kg/hr

Percent of 

values in 

rangea

Emission rate, 

kg/hr (per 100 

pumps)

<10 70.5 0.000528656 0.00075 70.7 0.000530239

10 10 to 100 17.6 39.7 0.006954 17.7 0.006974

100 100 to 500 11.3 232 0.019146 11.4 0.019204

500 500 to 1000 0.10 665 0.000420 0.07 0.000280

1000 1000 to 2000 0.10 1330 0.000744 0.05 0.0003722000 2000 to 5000 0.09 2990 0.001265 0.05 0.0006325000 5000 to 10000 0.07 6650 0.002013 0.04 0.001006

10000 10000 to 50000 0.09 23200 0.007044 0.05 0.00352250000 50000 to 100000 0.04 66500 0.007189 0.02 0.003595

100000 >100000 0.05 310000 0.034080 0.03 0.017040

Emission rate per 

pump

Emission rate 

per pump

Emission rate per valve 0.000794 0.0000075 0.00053

Average emission rate

 during monitoring period 0.000401

vs.

Emission rate estimated using 

 ALR equation 0.0005771

(HON avg leak rate, kg/hr)

Emissions New Calcs 
Refinery Leak Frequencies

PUMPS

New = Monthly 500, baseline = Monthly 1,000

1

leak range 0 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (500 ppm), % 2.16 <-- (this value for monthly monitoring)percent in range 88.057 9.784 0.472 1.079 0.433 0.061 0.113 100.000representative value default 165 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/pump) 0.000024 1.13E-03 2.65E-03 7.89E-03 2.31E-02 4.40E-02 1.31E-01 0.0005

2 Controlled estimate using average leak rate as one-half of reported leak frequency, converted to monthly monitoring

leak range 0 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (500 ppm), % 2.16 <-- (this value for monthly monitoring)percent in range 88.958 9.884 0.315 0.540 0.217 0.030 0.057 100.000representative value default 165 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/pump) 0.000024 1.13E-03 2.65E-03 7.89E-03 2.31E-02 4.40E-02 1.31E-01 0.0003

3

Then determine the percent leaking at other leak definitions by assuming the same distribution of leaking pumps as reported by API.leak range 0 500 1,000 10,000 50,000 100,000 1,000,000

leak frequency (1,000 ppm), % 1.69 2.16 (at 1,000 ppm)percent in range 88.057 9.784 0.472 1.079 0.433 0.061 0.113 100.000representative value default 165 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/pump) 0.000024 1.13E-03 2.65E-03 7.89E-03 2.31E-02 4.40E-02 1.31E-01 0.0005

4

Then determine the percent leaking at other leak definitions by assuming the same distribution of leaking pumps as reported by API.leak range 0 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (1,000 ppm), % 1.69percent in range 88.816 9.868 0.472 0.540 0.217 0.030 0.057 100.000representative value default 165 665 3,970 23,200 66,500 397,000

average for values above 1,000 zeroemissions (kg/hr/pump) 0.000024 1.13E-03 2.65E-03 7.89E-03 2.31E-02 4.40E-02 1.31E-01 0.0003

5 Baseline and Initial Leak Freq. Calc.

leak range 0 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (1,000 ppm), % 0.98 1.26 (at 500 ppm)percent in range 88.866 9.874 0.276 0.630 0.253 0.036 0.066Controlled, w/ leak frequency as summarized in API report equal to leak frac. (i.e., estimate emission rate when monitored, not avg. over monitoring period) conBaseline estimate - Apply industry-based baseline-to-controlled percent leakers ratio for valves to controlled leak frequency for pumps above 1,000 ppm (adjustBaseline estimate - Average above 1,000 ppm
Refinery Leak Frequencies

GAS VALVES

New = Quarterly, 100, Baseline = Semiannual, 500 (VVa to Opt7)

1 Controlled, with leak frequency as summarized in API report equal to leak fraction (i.e., estimate emission rate when monitored, not average over monitoring pe

leak range 0 100 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (100 ppm), % 2.19percent in range 88.031 9.781 1.753 0.052 0.275 0.061 0.012 0.035 representative value default 33 232 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/valve) 0.0000078 3.11E-05 1.33E-04 2.92E-04 1.11E-03 4.14E-03 9.07E-03 3.44E-02 

2 Controlled estimate using average leak rate as one-half of reported leak frequency

leak range 0 100 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (100 ppm), % 2.19percent in range 88.752 9.861 1.169 0.026 0.138 0.031 0.006 0.018 10representative value default 33 232 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/valve) 0.0000078 3.11E-05 1.33E-04 2.92E-04 1.11E-03 4.14E-03 9.07E-03 3.44E-02 

3 Baseline estimate

leak range 0 100 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (500 ppm), % 3.28 10.050 (at 100 ppm)percent in range 87.049 2.902 6.770 0.391 2.072 0.460 0.089 0.266 10representative value default 33 232 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/valve) 0.0000078 3.11E-05 1.33E-04 2.92E-04 1.11E-03 4.14E-03 9.07E-03 3.44E-02 

4 Baseline estimate - average above 10,000 ppm

leak range 0 100 500 1,000 10,000 50,000 100,000 1,000,000

leak frequency (500 ppm), % 3.28 10.050 (at 100 ppm)percent in range 88.524 2.951 6.885 0.196 1.036 0.230 0.044 0.133 10representative value default 33 232 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/valve) 0.0000078 3.11E-05 1.33E-04 2.92E-04 1.11E-03 4.14E-03 9.07E-03 3.44E-02 

5 Baseline and Initial Leak Freq. Calc.

leak range 0 100 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (500 ppm), % 1.91 8.779 (at 100 ppm)percent in range 88.278 2.943 6.866 0.228 1.209 0.269 0.052 0.155
Refinery Leak Frequencies

LIGHT LIQUID VALVES

New = Quarterly, 100, Baseline = Semiannual, 500 (VVa to Opt7)

1 Controlled, with leak frequency as summarized in API report equal to leak fraction (i.e., estimate emission rate when monitored, not average over monitoring pe

leak range 0 100 500 1,000 10,000 50,000 100,000 1,000,000

leak frequency (100 ppm), % 2.01percent in range 88.192 9.799 1.599 0.070 0.226 0.074 0.010 0.031 10representative value default 33 232 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/valve) 0.0000078 3.11E-05 1.33E-04 2.92E-04 1.11E-03 4.14E-03 9.07E-03 3.44E-02 

2 Controlled estimate using average leak rate as one-half of reported leak frequency

leak range 0 100 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (100 ppm), % 2.01percent in range 88.856 9.873 1.066 0.035 0.113 0.037 0.005 0.016 10representative value default 33 232 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/valve) 0.0000078 3.11E-05 1.33E-04 2.92E-04 1.11E-03 4.14E-03 9.07E-03 3.44E-02 

3 Baseline estimate

leak range 0 100 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (500 ppm), % 3.38 3.376 (at 500 ppm)percent in range 86.961 2.899 6.764 0.573 1.857 0.609 0.079 0.259 10representative value default 33 232 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/valve) 0.0000078 3.11E-05 1.33E-04 2.92E-04 1.11E-03 4.14E-03 9.07E-03 3.44E-02 

4 Baseline estimate - average above 10,000 ppm

leak range 0 100 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (500 ppm), % 3.38 3.376 (at 500 ppm)percent in range 88.481 2.949 6.882 0.287 0.928 0.305 0.039 0.129 10representative value default 33 232 665 3,970 23,200 66,500 397,000

zero

emissions (kg/hr/valve) 0.0000078 3.11E-05 1.33E-04 2.92E-04 1.11E-03 4.14E-03 9.07E-03 3.44E-02 

5 Baseline and Initial Leak Freq. Calc.

leak range 0 100 500 1,000 10,000 50,000 100,000 1,000,000leak frequency (500 ppm), % 1.97 8.832 (at 100 ppm)percent in range 88.227 2.941 6.862 0.334 1.083 0.355 0.046 0.151
Attachment 3 - Emission Factors

SOCMI

Uncontrolled Emission Rates

(kg/hr/piece of 

equipment)

Pump Seals LL 1.23E-02

Valves G/V 5.22E-04

Valves LL 5.86E-04

Agitators LL 1.23E-02

Connectors – Flanges G/V 3.07E-04

Connectors – Flanges G/LL 3.07E-04

Compressor Vent 2.28E-01

Open-ended Valves 1.70E-03

Sampling Connections 1.50E-02

PRV – Disks 1.04E-01

Baseline Emission Rates

(kg/hr/piece of 

equipment)

Pump Seals LL 2.51E-03

Valves G/V 3.52E-04

Valves LL 3.90E-04

Agitators LL 2.51E-03

Connectors – Flanges G/V 3.07E-04

Connectors – Flanges G/LL 3.07E-04

Compressor Vent 2.28E-02

Open-ended Valves 3.33E-05

Valves Option 1

(kg/hr/piece of 

equipment)

Valves G/V 2.03E-04

Valves LL 2.32E-04

V l O ti 2

Calculated using initial leak rates of pumps and valves from facility data used in calculating MACT floors for the MON 

(Table A1) and the equations in Table 5-4 from the Protocol for Equipment Leak Estimates. See sample calculation for 

Model 1 pumps in light liquid service.

See Uncontrolled basis. 

Based on Table 2-1 of Equipment Leaks Protocol. 10 percent of uncontrolled compressor seal value

Based on Memorandum: Analysis of Additional Data on Leaks from Open-Ended Lines

Basis

Based on EPA SOCMI data for Pumps at 10,000 ppm

Based on EPA SOCMI data for Gas Valves at 500 ppm

Based on EPA SOCMI data for LL Valves at 500 ppm

Based on on SOCMI average emission factors in Table 2-1 of the Protocol for Equipment Leak Emission Estimates

Based on Equipment Leak Protocol Table 5-4 and MON leak rate data for connectors at 500 ppm. NEIC Factor applied. 

((0.047*0.360*1.71/100)+1.7E-5)*Equipment Count*8760

Where 1.71 is the NEIC factor, 0.360 is the leak frequency of connectors at 500 ppm from MON data, and 0.047 and 

1.7E-5 are Table 5-4 values. 

Basis

Basis

Based on EPA SOCMI data for Pumps at 10,000 ppm

Based on EPA SOCMI data for Gas Valves at 10,000 ppm

Based on EPA SOCMI data for LL Valves at 10,000 ppm

Attachment 3 ‐ Page 1

Valves Option 2

(kg/hr/piece of 

equipment)

Valves G/V 1.82E-04

Valves LL 2.05E-04

Pumps Option 1

(kg/hr/piece of 

equipment)

Pump Seals LL 6.95E-04

Pumps Option 2

(kg/hr/piece of 

equipment)

Pump Seals LL 5.31E-04

Connectors Option 1

(kg/hr/piece of 

equipment)

Connectors – Flanges G/LL 1.62E-04 Based on EPA SOCMI data for Connectors at 500 ppm

Basis

Based on EPA SOCMI data for Gas Valves at 100 ppm

Based on EPA SOCMI data for LL Valves at 100 ppm

Basis

Based on EPA SOCMI data for Pumps at 500 ppm

Basis

Based on EPA SOCMI data for Pumps at 1,000 ppm

Basis

Attachment 3 ‐ Page 1
Refinery Models

Uncontrolled Emission Rates

(kg/hr/piece of 

equipment)

Pump Seals LL 1.05E‐03

Valves G/V 3.71E‐04

Valves LL 3.75E‐04

Agitators LL 1.05E‐03

Connectors – Flanges G/V 1.04E‐04

Connectors – Flanges G/LL 8.46E‐05

Compressor Vent 6.36E‐01

Open-ended Valves 2.30E‐03

Sampling Connections 1.50E‐02

PRV – Disks 1.60E‐01

Baseline Emission Rates

(kg/hr/piece of 

equipment)

Pump Seals LL 7.11E‐04

Valves G/V 2.24E‐04

Valves LL 2.23E‐04

Connectors – Flanges G/V 1.04E‐04

Connectors – Flanges G/LL 8.46E‐05

Compressor Vent 3.18E‐02

Open-ended Valves 7.34E‐05

Valves Option 1

(kg/hr/piece of 

equipment)

Valves G/V 8.85E-05

Valves LL 8.88E-05

Valves Option 2

(kg/hr/piece of 

equipment)

Valves G/V 2.10E-05

Valves LL 2.02E-05

Pumps Option 1

(k /h / i f

Basis

Memorandum: Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC in Petroleum Refineries

Basis

Based on on Refinery average emission factors in Table 2-2 of the Protocol for Equipment Leak Emission Estimates

Memorandum: Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC in Petroleum Refineries

Based on on Refinery average emission factors in Protocol for Equipment Leak Emission Estimates

Memorandum: Final Impacts Analysis for Regulatory Options for Equipment Leaks of VOC in Petroleum Refineries

Basis

Based on on Refinery average emission factors in Protocol for Equipment Leak Emission Estimates

Basis

Based on on Refinery average emission factors in Protocol for Equipment Leak Emission Estimates

Attachment 3 ‐ Page 2

(kg/hr/piece of 

equipment)

Pump Seals LL 3.26E‐04

Pumps Option 2

(kg/hr/piece of 

equipment)

Pump Seals LL 3.22E‐04

Connectors Option 1

(kg/hr/piece of 

equipment)

Connectors – Flanges G/V 3.95E-05

Connectors – Flanges G/LL 2.77E-05

Basis

Based on on Refinery average emission factors in Protocol for Equipment Leak Emission Estimates

Based on on Refinery average emission factors in Protocol for Equipment Leak Emission Estimates

Basis

Based on on Refinery average emission factors in Protocol for Equipment Leak Emission Estimates

Basis

Attachment 3 ‐ Page 2
Table A1. Resulting Emission Rates and Program Efficiencies for CMA Data

Leak Definition 

(ppmv) No. Monitored No. Leaking

Initial

Leak 

Rate (%)

Pumps 500 121 0 0

1000 683 13 1.9

2000 82 0 0

5000 374 39 10.43

10000 662 13 1.96

Valves 500 62299 312 0.5

5000 483 0 0

10000 21185 123 0.58

Sample calculation for Model 1 pumps in light liquid service is as follows:

Reference: Revised MACT Floor, Regulatory Alternatives, and Nationwide Impacts for Equipment Leaks at Chemical Manufacturing Facilities 

MON memorandum

Step 1: Calculate the LKFRAC % @ 10,000 ppm using 1,000 leak definition

ALR @ 1,000 ppm (kg/hr/source) = Equation 1

(0.11 × LKFRAC @1,000 ppm) + 4.6E-04 Table 5-4 Equipment Leak Protocol 

LKFRAC @ 1,000 ppm = Equation 2

(NEIC Factor x 1.9 % Initial Leak Rate of Pumps LL @ 1,000ppm)/100 

Substitute the leak frequency back into Equation 1. 

ALR @ 1,000 ppm (kg/hr/source) = 

0.11 × (NEIC Factor x 1.9 % Initial Leak Rate of Pumps LL @ 1,000ppm)/100 × 4.6E-04

ALR @ 10,000 ppm (kg/hr/source) = Equation 3

(0.24 × LKFRAC @ 10,000 ppm) + 1.9E-03 Table 5-4 Equipment Leak Protocol 

Rearrange Equation 3 and substitute ALR@ 10,000 ppm with ALR at 1,000 ppm 

LKFRAC % @ 10,000 ppm = 

[(ALR @ 1 000 ppm (kg/hr/source) - 1 9E-03)/0 24] × 100

Attachment 3 ‐ Page 3

LKFRAC % @ 10,000 ppm = 

[(ALR @ 1,000 ppm (kg/hr/source) - 1.9E-03)/0.24] × 100 

Substitute Equation 3 into Equation 4 

LKFRAC % @ 10,000 ppm = Equation 4

[(0.11 × (((NEIC Factor x 1.9 % Initial Leak Rate of Pumps LL @ 1,000ppm)/100 × 4.6E-04) - 1.9E-03)/0.24] × 100

Step 2: Calculate the LKFRAC % @ 10,000 ppm using 5,000 leak definition

Attachment 3 ‐ Page 3
Attachment 4

Uncontrolled

Type of Equipment

Pump Seals

kg/yr lb/yr kg/yr lb/yr kg/yr lb/yr kg/yr lb/yr kg/yr 

 * Light-liquid service 15 1,616 3,562 40 4,309 9,500 56 6,033 13,300 8 74 162 69 635  * Heavy-liquid service 0 -- -- 5 -- -- 36 -- -- 8 -- -- 61 -- Valves * Gas/vapor service 77 352 776 414 1,891 4,170 1,379 6,300 13,890 75 244 538 1,178 3,833  * Light-liquid service 380 1,950 4,300 1,179 6,052 13,342 1,980 10,163 22,406 251 824 1,816 2,428 7,970  * Heavy-liquid service 0 -- -- 71 -- -- 1,272 -- -- 216 -- -- 1,719 -- Connectors * Flanges - gas/vapor 0 0 0 0 0 0 0 0 0 164 150 330 2,333 2,129  * Flanges - G/LL 731 1,966 4,334 2,662 7,159 15,782 7,410 19,927 43,932 555 411 906 4,644 3,440  * Flanges - HL 0 0 0 0 0 0 0 0 0 454 0 4,186 Agitators * Light-liquid service 0 0 0 3 323 712 0 0 0 0 0 0 0 0  * Heavy-liquid service 0 -- -- 3 -- -- 0 -- -- 00000Compressor Vent 0002 3,995 8,806 8 15,978 35,226 2 11,143 24,565 19 105,856 Open-ended Valves 33 491 1,083 141 2,100 4,629 424 6,314 13,920 39 786 1,732 238 4,795 Sampling Connections 8 1,051 2,317 35 4,599 10,139 106 13,928 30,707 10 1,314 2,897 70 9,198 Pressure Relief Devices * Disks 2 1,822 4,017 45 40,997 90,382 76 69,239 152,646 9 12,614 27,810 79 110,726  * Disk holders, valves,etc. 2 -- -- 45 -- -- 76 -- -- 9 0 79 

TOTAL (lb/yr) 20,390 157,464 326,027 60,758 

TOTAL (tpy) 10.19499 78.73175 163.0133 30.37886 

Count

Emissions

Count

Emiss

Count

Emissions

Count

Emissions

Count

Emissions

Model 1 Model 2 Model 3 Model 4 Model 5 
Baseline

Type of Equipment

Pump Seals

kg/yr lb/yr kg/yr lb/yr kg/yr lb/yr kg/yr lb/yr kg/yr 

 * Light-liquid service 15 330 728 40 880 1,940 56 1,232 2,717 8 50 110 69 430  * Heavy-liquid service 0 -- -- 5 -- -- 36 -- -- 8 -- -- 61 -- Valves * Gas/vapor service 77 237 523 414 1,277 2,814 1,379 4,252 9,374 75 147 324 1,178 2,310  * Light-liquid service 380 1,299 2,863 1,179 4,030 8,884 1,980 6,767 14,920 251 491 1,082 2,428 4,750  * Heavy-liquid service 0 -- -- 71 -- -- 1,272 -- -- 216 -- -- 1,719 -- Connectors * Flanges - gas/vapor 0 0 0 0 0 0 0 0 0 164 150 330 2,333 2,129 

 * Flanges - G/LL 731 1,966 4,334 2,662 7,159 15,782 7,410 19,927 43,932 555 411 906 4,644 3,440  * Flanges - HL 0 0 0 0 0 0 0 0 0 454 0 4,186 Agitators * Light-liquid service 0 0 0 3 66 146 0 0 0 0 -- -- 0 --  * Heavy-liquid service 0 -- -- 3 -- -- 0 -- -- 0 -- -- 0 -- Compressor Vent 0 0 0 2 399 881 8 1,598 3,523 2 557 1,228 19 5,293 

Open-ended Valves 33 10 21 141 41 91 424 124 273 39 25 55 238 153 Sampling Connections 8 0 0 35 0 0 106 0 0 10 0 0 70 0 Pressure Relief Devices * Disks 2 0 0 45 0 0 76 0 0 9 0 0 79 0  * Disk holders, valves,etc. 2 -- -- 45 -- -- 76 -- -- 9 0 79 TOTAL (lb/yr) 8,470 30,538 74,737 4,036 TOTAL (tpy) 4.234773 15.26886 37.36873 2.018204 TOTAL REDUCTION (lb/yr) 11,920 126,926 251,289 56,721 TOTAL REDUCTION (tpy) 5.960215 63.46289 125.6445 28.36066 

Count

Emissions

Count

Emiss

Count

Emissions

Count

Emissions

Count

Emissions

Model 1 Model 2 Model 3 Model 4 Model 5 
Valves Option 1

Type of Equipment

kg/yr lb/yr kg/yr lb/yr kg/yr lb/yr kg/yr lb/yr kg/yr 

Valves * Gas/vapor service 77 136.67 301 414 734.83 1,620 1,379 2,447.67 5,396 75 58 128 1,178 913  * Light-liquid service 380 770.69 1,699 1,179 2,391.17 5,272 1,980 4,015.70 8,853 251 195 431 2,428 1,889  * Heavy-liquid service 0 -- -- 71 -- -- 1,272 -- -- 216 -- -- 1,719 -- Other emissions (Opt 2) 2,306 5,083 8,545 18,839 22,881 50,444 1,193 2,630 11,445 TOTAL (lb/yr) 7,083 25,731 64,693 3,188 TOTAL (tpy) 3.541575 12.86557 32.34645 1.594243 TOTAL REDUCTION (lb/yr) 1,386 4,807 10,045 848 TOTAL REDUCTION (tpy) 0.6932 2.4033 5.0223 0.4240 Pumps Option 1

Type of Equipment

Pump Seals

kg/yr lb/yr kg/yr lb/yr kg/yr lb/yr kg/yr lb/yr kg/yr 

 * Light-liquid service 15 91.27 201 40 243.40 537 56 340.76 751 8 23 50 69 197  * Heavy-liquid service 0 -- -- 5 -- -- 36 -- -- 8 -- -- 61 -- Other emissions (Opt 2) 1,975 4,355 7,665 16,899 21,649 47,727 1,143 2,520 11,015 Other emissions (Opt 3) 907 2,000 3,126 6,892 6,463 14,249 253 559 2,802 TOTAL (lb/yr) 6,557 24,327 62,728 3,129 TOTAL (tpy) 3.278368 12.16368 31.36381 1.564474 TOTAL REDUCTION (lb/yr) 526 1,404 1,965 60 TOTAL REDUCTION (tpy) 0.263207 0.701884 0.982638 0.029768 Connectors Option 1

Type of Equipment

kg/yr lb/yr kg/yr lb/yr kg/yr lb/yr kg/yr lb/yr kg/yr 

Connectors * Flanges - gas/vapor 0 -- -- 0 -- -- 0 -- -- 164 56.8 125 2,333 808.1  * Flanges - G/LL 731 1,037.3 2,287 2,662 3,777.6 8,328 7,410 10,515.4 23,182 555 135 297 4,644 1,128  * Flanges - HL 0 -- -- 0 -- -- 0 -- -- 454 -- -- 4,186 -- Other emissions (Opt 2) 10 21 507 1,117 1,721 3,795 582 1,284 5,446 Other emissions (Opt 3, 4) 999 2,202 3,369 7,428 6,804 15,001 276 609 2,999 TOTAL (lb/yr) 4,510 16,873 41,978 2,315 TOTAL (tpy) 2.25489 8.436596 20.98901 1.157537 TOTAL REDUCTION (lb/yr) 2,047 7,454 20,750 814 TOTAL REDUCTION (tpy) 1.023479 3.727086 10.3748 0.406938 

Count

Emissions Reduction

Count

Emissions R

Count

Emissions Reduction

Count

Emissions Reduction

Count

Emissions Reduction

Model 1 Model 2 Model 3 Model 4 Model 5 

Count

Emissions Reduction

Count

Emissions R

Count

Emissions Reduction

Count

Emissions Reduction

Count

Emissions Reduction

Model 1 Model 2 Model 3 Model 4 Model 5 

Count

Emissions

Count

Emiss

Count

Emissions

Count

Emissions

Count

Emissions

Model 1 Model 2 Model 3 Model 4 Model 5 
Valves Option 2

Type of Equipment

kg/yr lb/yr kg/yr lb/yr kg/yr lb/yr kg/yr lb/yr kg/yr 

Valves * Gas/vapor service 77 122.61 270 414 659.22 1,453 1,379 2,195.81 4,841 75 13.81 30 1,178 216.98  * Light-liquid service 380 682.76 1,505 1,179 2,118.35 4,670 1,980 3,557.53 7,843 251 44.31 98 2,428 428.63  * Heavy-liquid service 0 -- -- 71 -- -- 1,272 -- -- 216 -- -- 1,719 -- Other emissions (Opt 2) 0 0 465 1,026 1,598 3,523 557 1,228 5,293 Other emissions (Opt 4, 5, 6) 1,129 2,488 4,021 8,865 10,856 23,934 214 473 2,133 TOTAL (lb/yr) 4,264 16,014 40,140 1,829 TOTAL (tpy) 2.131855 8.007205 20.07009 0.914589 TOTAL REDUCTION (lb/yr) 246 859 1,838 486 TOTAL REDUCTION (tpy) 0.123035 0.429391 0.918926 0.242948 

8865.17

Pumps Option 2

Type of Equipment

Pump Seals

kg/yr lb/yr kg/yr lb/yr kg/yr lb/yr kg/yr lb/yr kg/yr 

 * Light-liquid service 15 69.82 154 40 186.20 410 56 260.67 575 8 22.56 50 69 194.60  * Heavy-liquid service 0 -- -- 5 -- -- 36 -- -- 8 -- -- 61 -- Other emissions (Opt 2) 0 0 465 1,026 1,598 3,523 557 1,228 5,293 Other emissions (Opt 5, 6) 1,037 2,287 3,778 8,328 10,515 23,182 192 422 1,936 Other emissions (Opt 8) 805 1,776 2,778 6,123 5,753 12,684 58 128 646 TOTAL (lb/yr) 4,216 15,888 39,964 1,829 TOTAL (tpy) 2.108209 7.944149 19.98181 0.914283 TOTAL REDUCTION (lb/yr) 47 126 177 0.61 TOTAL REDUCTION (tpy) 0.023646 0.063056 0.088278 0.000306 

Count

Emissions Reduction

Count

Emissions R

Count

Emissions Reduction

Count

Emissions Reduction

Count

Emissions Reduction

Model 1 Model 2 Model 3 Model 4 Model 5 

Count

Emissions Reduction

Count

Emissions R

Count

Emissions Reduction

Count

Emissions Reduction

Count

Emissions Reduction

Model 1 Model 2 Model 3 Model 4 Model 5 
Attachment 5: Cost Effectiveness and Cost Calculations

Uncontrolled 

Emissions (tpy) Capital Costs ($)

Annualized 

Costs Without 

Recovery 

Credits ($/yr)

VOC Recovery 

Credit ($/yr)

Total Annualized 

Cost ($/yr)

Emissions 

Reduction (tpy)

Model 1 10.19 90,763 41,009 (2,980) 38,029 5.96

Model 2 78.73 455,982 129,599 (31,731) 97,867 63.46

Model 3 163.01 859,162 226,203 (62,822) 163,381 125.64

Model 4 30.38 156,783 57,067 (14,180) 42,887 28.36

Model 5 274.02 956,067 263,308 (126,809) 136,499 253.62

Model 6 470.59 1,658,781 461,483 (210,466) 251,017 420.93

VALVES

Capital Costs 

($)

Annualized 

Costs Without 

Recovery 

Credits ($/yr)

VOC Recovery 

Credit ($/yr)

Incremental 

Annualized Cost 

($/yr)

Incremental 

Emissions 

Reduction (tpy)

Overall Cost 

Effectiveness 

($/ton)

Incremental 

Capital Costs ($)

Incremental 

Annualized Cost 

($/yr)

VOC Recovery 

Credit ($/yr)

Incrementa

Annualized C

($/yr)

Model 1 1,707 362 (347) 15 0.69 22 3,768 963 (62) 9

Model 2 6,216 1,299 (1,202) 97 2.40 40 13,716 3,438 (215) 3,2

Model 3 14,030 2,869 (2,511) 358 5.02 71 30,944 7,536 (459) 7,0

Model 4 1,211 480 (212) 268 0.42 633 5,299 2,937 (121) 2,8Model 5 13,356 5,379 (2,346) 3,033 4.69 646 58,507 29,266 (1,273) 27,9

Model 6 33,743 13,660 (5,935) 7,725 11.87 651 147,886 82,886 (3,324) 79,5PUMPS

Capital Costs 

($)

Annualized 

Costs Without 

Recovery 

Credits ($/yr)

VOC Recovery 

Credit ($/yr)

Incremental 

Annualized Cost 

($/yr)

Incremental 

Emissions 

Reduction (tpy)

Overall Cost 

Effectiveness 

($/ton)

Incremental 

Capital Costs ($)

Incremental 

Annualized Cost 

($/yr)

VOC Recovery 

Credit ($/yr)

Incrementa

Annualized C

($/yr)

Model 1 2,231 443 (132) 312 0.26 1,184 998 366 (12) 3

Model 2 5,948 1,182 (351) 831 0.70 1,184 2,661 976 (32) 9

Model 3 8,328 1,654 (491) 1,163 0.98 1,184 3,725 1,366 (44) 1,3

Model 4 262 204 (15) 189 0.03 6,339 135 437 (0) 4

Model 5 2,259 1,756 (128) 1,628 0.26 6,339 1,168 3,773 (1) 3,7

Model 6 5,763 4,479 (327) 4,152 0.65 6,339 2,980 9,625 (3) 9,6

OEL Monitoring (Increme

CONNECTORS

Capital Costs 

($)

Annualized 

Costs Without 

Recovery 

Credits ($/yr)

VOC Recovery 

Credit ($/yr)

Incremental 

Annualized Cost 

($/yr)

Incremental 

Emissions 

Reduction (tpy)

Overall Cost 

Effectiveness 

($/ton)

Incrementa

Capital Cost 

Model 1 19,368 7,872 (512) 7,360 1.02 7,192 Model 1 8Model 2 65,633 15,725 (1,864) 13,861 3.73 3,719 Model 2 3,4Model 3 179,391 35,034 (5,187) 29,846 10.37 2,877 Model 3 10,3

Model 4 19,494 7,918 (203) 7,714 0.41 18,957 Model 4 9Model 5 173,029 34,190 (2,002) 32,188 4.00 8,038 Model 5 6,0

Model 6 517,562 93,145 (6,055) 87,089 12.11 7,191 Model 6 23,0

Baseline

Valves Option 1 (Incremental to Baseline) Valves Option 2 (Incremental to O

Pumps Option 1 (Incremental to Baseline) Pumps Option 2 (Incremental to O

Connectors Option 1 (Incremental to Baseline)
Baseline Cost Estimates

Type of Component Number of Components

Initial 

Monitoring 

Fee or Unit 

Cost ($/comp)

Initial LDAR 

Costs ($) 

(Capital)

Initial 

LDAR 

Admin. 

Costs

Frequency of 

Monitoring 

(times/yr)

Subsequent 

Monitoring 

Fee ($/comp) 

or Charge 

(%)

Annual 

Monitoring 

Costs ($/yr)

Annual 

Maintenance 

Costs ($/yr)

Initial Leak 

Frequency 

(%)

Initial 

Numbe

of Leak

Model 1 Pump Seals

 * Light-liquid service 15 23.80 742.42 12 1.50 580.13 116.32 2.42 0.36 

 * Heavy-liquid service 0 1.10 0.00

Valves * Gas/vapor service 77 23.80 1852.51 2 1.50 231.00 0.33 0.26 

 * Light-liquid service 380 23.80 9142.25 2 1.50 1140.00 0.33 1.27 

 * Heavy-liquid service 0 1.10 0.00

Connectors * Flanges - gas/vapor 0 1.10 0.00

 * Flanges - light liquid 731 1.10 807.02 * Flanges -heavy liquid 0 1.10 0.00

Agitators * Light-liquid service 0 23.80 0.00 12 1.50 0.00 0.00 2.42 0.00  * Heavy-liquid service 0 1.10 0.00

Pressure Relief Devices * Disks 2 122.11 244.21 0 2.00 0.00 4.88

 * Disk holders, valves,etc. 2 6,374.29 12748.58 5.00 637.43

OEL 33 140.92 4650.43 5.00 232.52

Sampling Connections 8 687.86 5502.86 5.00 275.14Compressor Vent 0 10526.21 0.00 5.00 0.00

Replacement Pump Seals 15 282.71 102.65

Monitoring Instrument 1 10,800 10,800

Data Collection System 1 14,500 14,500

hr/activity $/hr

Administrative and Reports 250 92.72Planning and Training 320 92.72 29670.40

TOTALS 61092.92 29670.40 1951.13 1266.30

Capital Costs ($) 90,763

Annualized Capital ($/yr) 12,924

Annual Expenses ($/yr) 28,085

Annual Fixed Costs ($/yr) 37,123 41,009

Annual Variable Costs ($/yr) 3,886

Baseline 
Baseline Cost Estimates

Type of Component

Model 1 Pump Seals

 * Light-liquid service * Heavy-liquid serviceValves * Gas/vapor service * Light-liquid service * Heavy-liquid serviceConnectors * Flanges - gas/vapor * Flanges - light liquid * Flanges -heavy liquidAgitators * Light-liquid service * Heavy-liquid servicePressure Relief Devices * Disks * Disk holders, valves,etc.OELSampling ConnectionsCompressor VentReplacement Pump Seals

Monitoring InstrumentData Collection SystemAdministrative and ReportsPlanning and TrainingTOTALS

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak 

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

Offline Leak 

Repair Cost 

($/yr)

Monitoring 

to Verify 

Repair ($)

Annual 

Admin. 

Cost 

($/yr)

Annual 

Misc. 

Charges 

($/yr)

16.00 66.24 436.08 0 80.00 66.24 0.00 0.62 93.06

0.17 66.24 4.27 25 4.00 66.24 34.08 0.770.17 66.24 21.06 25 4.00 66.24 168.17 3.81

16.00 66.24 0.00 0 80.00 66.24 0.00 0.00 0.00

9.77

509.94186.02220.11

0.00

23180.00

461.41 202.25 5.20 23180.00 1018.90

Baseline 
Option 1 Cost Estimates

Type of Component Number of Components

Initial 

Monitoring 

Fee or Unit 

Cost ($/comp)

Initial LDAR 

Costs ($) 

(Capital)

Initial 

LDAR 

Admin. 

Costs

Frequency of 

Monitoring 

(times/yr)

Subsequent 

Monitoring 

Fee ($/comp) 

or Charge 

(%)

Annual 

Monitoring 

Costs ($/yr)

Annual 

Maintenance 

Costs ($/yr)

Initial Leak 

Frequency 

(%)

Initial 

Numbe

of Leak

Model 2 Pump Seals

 * Light-liquid service 40 23.80 1979.78 12 1.50 1547.01 310.20 2.42 0.97 

 * Heavy-liquid service 5 1.10 5.52

Valves * Gas/vapor service 414 23.80 9960.24 2 1.50 1242.00 0.33 1.38 

 * Light-liquid service 1,179 23.80 28365.03 2 1.50 3537.00 0.33 3.94 

 * Heavy-liquid service 71 1.10 78.38Connectors * Flanges - gas/vapor 0 1.10 0.00

 * Flanges - light liquid 2,662 1.10 2938.85 * Flanges -heavy liquid 0 1.10 0.00

Agitators * Light-liquid service 3 23.80 71.41 12 1.50 140.11 0.00 2.42 0.07 

 * Heavy-liquid service 3 1.10 3.31

Pressure Relief Devices * Disks 45 122.11 5494.78 0 2.00 0.00 109.90 * Disk holders, valves,etc. 45 6,374.29 286842.95 5.00 14342.15

OEL 141 140.92 19870.03 5.00 993.50Sampling Connections 35 687.86 24075.01 5.00 1203.75

Compressor Vent 2 10526.21 21052.42 5.00 1052.62

Replacement Pump Seals 40 282.71 273.72

Monitoring Instrument 1 10,800 10,800

Data Collection System 1 14,500 14,500

hr/activity $/hr

Administrative and Reports 250 92.72Planning and Training 320 92.72 29670.40

TOTALS 426311.44 29670.40 6466.12 18012.11

Capital Costs ($) 455,982

Annualized Capital ($/yr) 65,338

Annual Expenses ($/yr) 64,261

Annual Fixed Costs ($/yr) 103,059 129,599

Annual Variable Costs ($/yr) 26,539

Baseline 
Option 1 Cost Estimates

Type of Component

Model 2 Pump Seals

 * Light-liquid service * Heavy-liquid serviceValves * Gas/vapor service * Light-liquid service * Heavy-liquid serviceConnectors * Flanges - gas/vapor * Flanges - light liquid * Flanges -heavy liquidAgitators * Light-liquid service * Heavy-liquid servicePressure Relief Devices * Disks * Disk holders, valves,etc.OELSampling ConnectionsCompressor VentReplacement Pump Seals

Monitoring InstrumentData Collection SystemAdministrative and ReportsPlanning and TrainingTOTALS

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak 

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

Offline Leak 

Repair Cost 

($/yr)

Monitoring 

to Verify 

Repair ($)

Annual 

Admin. 

Cost 

($/yr)

Annual 

Misc. 

Charges 

($/yr)

16.00 66.24 1162.87 0 80.00 66.24 0.00 1.65 248.16

0.17 66.24 22.95 25 4.00 66.24 183.22 4.150.17 66.24 65.35 25 4.00 66.24 521.78 11.82

16.00 66.24 87.22 0 80.00 66.24 0.00 0.12 0.00

219.79

11473.72

794.80963.00842.10

23180.00

1338.39 705.00 17.73 23180.00 14541.57

Baseline 
Option 1 Cost Estimates

Type of Component Number of Components

Initial 

Monitoring 

Fee or Unit 

Cost ($/comp)

Initial LDAR 

Costs ($) 

(Capital)

Initial 

LDAR 

Admin. 

Costs

Frequency of 

Monitoring 

(times/yr)

Subsequent 

Monitoring 

Fee ($/comp) 

or Charge 

(%)

Annual 

Monitoring 

Costs ($/yr)

Annual 

Maintenance 

Costs ($/yr)

Initial Leak 

Frequency 

(%)

Initial 

Numbe

of Leak

Model 3 Pump Seals

 * Light-liquid service 56 23.80 2771.69 12 1.50 2165.81 434.27 2.42 1.36 

 * Heavy-liquid service 36 1.10 39.74Valves * Gas/vapor service 1,379 23.80 33176.74 2 1.50 4137.00 0.33 4.61 

 * Light-liquid service 1,980 23.80 47635.92 2 1.50 5940.00 0.33 6.61 

 * Heavy-liquid service 1,272 1.10 1404.29Connectors * Flanges - gas/vapor 0 1.10 0.00

 * Flanges - light liquid 7,410 1.10 8180.64 * Flanges -heavy liquid 0 1.10 0.00

Agitators * Light-liquid service 0 23.80 0.00 12 1.50 0.00 0.00 2.42 0.00  * Heavy-liquid service 0 1.10 0.00

Pressure Relief Devices * Disks 76 122.11 9280.07 0 2.00 0.00 185.60 * Disk holders, valves,etc. 76 6,374.29 484445.88 5.00 24222.29

OEL 424 140.92 59751.02 5.00 2987.55Sampling Connections 106 687.86 72912.88 5.00 3645.64Compressor Vent 8 10526.21 84209.70 5.00 4210.48

Replacement Pump Seals 56 282.71 383.21

Monitoring Instrument 1 10,800 10,800

Data Collection System 1 14,500 14,500

hr/activity $/hr

Administrative and Reports 250 92.72Planning and Training 320 92.72 29670.40

TOTALS 829491.78 29670.40 12242.81 35685.85

Capital Costs ($) 859,162

Annualized Capital ($/yr) 122,987

Annual Expenses ($/yr) 103,217

Annual Fixed Costs ($/yr) 174,938 226,203

Annual Variable Costs ($/yr) 51,265

Baseline 
Option 1 Cost Estimates

Type of Component

Model 3 Pump Seals

 * Light-liquid service * Heavy-liquid serviceValves * Gas/vapor service * Light-liquid service * Heavy-liquid serviceConnectors * Flanges - gas/vapor * Flanges - light liquid * Flanges -heavy liquidAgitators * Light-liquid service * Heavy-liquid servicePressure Relief Devices * Disks * Disk holders, valves,etc.OELSampling ConnectionsCompressor VentReplacement Pump Seals

Monitoring InstrumentData Collection SystemAdministrative and ReportsPlanning and TrainingTOTALS

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak 

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

Offline Leak 

Repair Cost 

($/yr)

Monitoring 

to Verify 

Repair ($)

Annual 

Admin. 

Cost 

($/yr)

Annual 

Misc. 

Charges 

($/yr)

16.00 66.24 1628.02 0 80.00 66.24 0.00 2.30 347.42

0.17 66.24 76.44 25 4.00 66.24 610.29 13.820.17 66.24 109.75 25 4.00 66.24 876.27 19.84

16.00 66.24 0.00 0 80.00 66.24 0.00 0.00 0.00

371.20

19377.84

2390.042916.523368.39

23180.00

1814.21 1486.57 35.97 23180.00 28771.40

Baseline 
Option 1 Cost Estimates

Type of Component Number of Components

Initial 

Monitoring 

Fee or Unit 

Cost ($/comp)

Initial LDAR 

Costs ($) 

(Capital)

Initial 

LDAR 

Admin. 

Costs

Frequency of 

Monitoring 

(times/yr)

Subsequent 

Monitoring 

Fee ($/comp) 

or Charge 

(%)

Annual 

Monitoring 

Costs ($/yr)

Annual 

Maintenance 

Costs ($/yr)

Initial Leak 

Frequency 

(%)

Initial 

Numbe

of Leak

Model 4 Pump Seals

 * Light-liquid service 8 23.80 264.94 12 1.50 309.40 238.15 0.88 0.07 

 * Heavy-liquid service 8 1.10 8.83

Valves * Gas/vapor service 75 23.80 1852.89 2 1.50 225.00 1.18 0.89 

 * Light-liquid service 251 23.80 6238.36 2 1.50 753.00 1.38 3.46 

 * Heavy-liquid service 216 1.10 238.46Connectors * Flanges - gas/vapor 164 1.10 181.06 * Flanges - light liquid 555 1.10 612.72 * Flanges -heavy liquid 454 1.10 501.22Agitators * Light-liquid service 0 23.80 0.00 12 1.50 0.00 0.00 0.88 0.00  * Heavy-liquid service 0 1.10 0.00

Pressure Relief Devices * Disks 9 122.11 1098.96 0 2.00 0.00 21.98 * Disk holders, valves,etc. 9 6,374.29 57368.59 5.00 2868.43

OEL 39 140.92 5495.97 5.00 274.80

Sampling Connections 10 687.86 6878.57 5.00 343.93

Compressor Vent 2 10526.21 21052.42 5.00 1052.62

Replacement Pump Seals 8 282.71 19.85

Monitoring Instrument 1 10,800 10,800Data Collection System 1 14,500 14,500

hr/activity $/hr

Administrative and Reports 250 92.72 0.00

Planning and Training 320 92.72 29670.40

TOTALS 127112.84 29670.40 1287.40 4799.91

Capital Costs ($) 156,783

Annualized Capital ($/yr) 22,377

Annual Expenses ($/yr) 34,690

Annual Fixed Costs ($/yr) 49,424 57,067

Annual Variable Costs ($/yr) 7,643

Baseline 
Option 1 Cost Estimates

Type of Component

Model 4 Pump Seals

 * Light-liquid service * Heavy-liquid serviceValves * Gas/vapor service * Light-liquid service * Heavy-liquid serviceConnectors * Flanges - gas/vapor * Flanges - light liquid * Flanges -heavy liquidAgitators * Light-liquid service * Heavy-liquid servicePressure Relief Devices * Disks * Disk holders, valves,etc.OELSampling ConnectionsCompressor VentReplacement Pump Seals

Monitoring InstrumentData Collection SystemAdministrative and ReportsPlanning and TrainingTOTALS

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak 

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

Offline Leak 

Repair Cost 

($/yr)

Monitoring 

to Verify 

Repair ($)

Annual 

Admin. 

Cost 

($/yr)

Annual 

Misc. 

Charges 

($/yr)

16.00 66.24 892.78 0 80.00 66.24 0.00 1.26 190.52

0.17 66.24 14.74 25 4.00 66.24 117.69 2.670.17 66.24 57.49 25 4.00 66.24 458.97 10.39

16.00 66.24 0.00 0 80.00 66.24 0.00 0.00 0.00

43.96

2294.74

219.84275.14842.10

23180.00

965.01 576.66 14.32 23180.00 3866.30

Baseline 
Option 1 Cost Estimates

Type of Component Number of Components

Initial 

Monitoring 

Fee or Unit 

Cost ($/comp)

Initial LDAR 

Costs ($) 

(Capital)

Initial 

LDAR 

Admin. 

Costs

Frequency of 

Monitoring 

(times/yr)

Subsequent 

Monitoring 

Fee ($/comp) 

or Charge 

(%)

Annual 

Monitoring 

Costs ($/yr)

Annual 

Maintenance 

Costs ($/yr)

Initial Leak 

Frequency 

(%)

Initial 

Numbe

of Leak

Model 5 Pump Seals

 * Light-liquid service 69 23.80 2285.11 12 1.50 2668.59 2054.04 0.88 0.61 

 * Heavy-liquid service 61 1.10 67.34Valves * Gas/vapor service 1,178 23.80 29102.67 2 1.50 3534.00 1.18 13.95 

 * Light-liquid service 2,428 23.80 60345.61 2 1.50 7284.00 1.38 33.51 

 * Heavy-liquid service 1,719 1.10 1897.78Connectors * Flanges - gas/vapor 2,333 1.10 2575.63 * Flanges - light liquid 4,644 1.10 5126.98 * Flanges -heavy liquid 4,186 1.10 4621.34Agitators * Light-liquid service 0 23.80 0.00 12 1.50 0.00 0.00 0.88 0.00  * Heavy-liquid service 0 1.10 0.00

Pressure Relief Devices * Disks 79 122.11 9646.39 0 2.00 0.00 192.93 * Disk holders, valves,etc. 79 6,374.29 503568.74 5.00 25178.44

OEL 238 140.92 33539.49 5.00 1676.97Sampling Connections 70 687.86 48150.02 5.00 2407.50

Compressor Vent 19 10526.21 199998.03 5.00 9999.90

Replacement Pump Seals 69 282.71 171.17

Monitoring Instrument 1 10,800 10,800

Data Collection System 1 14,500 14,500

hr/activity $/hr

Administrative and Reports 250 92.72 0.00

Planning and Training 320 92.72 29670.40

TOTALS 926396.30 29670.40 13486.59 41509.78

Capital Costs ($) 956,067

Annualized Capital ($/yr) 136,763

Annual Expenses ($/yr) 126,545

Annual Fixed Costs ($/yr) 193,382 263,308

Annual Variable Costs ($/yr) 69,926

Baseline 
Option 1 Cost Estimates

Type of Component

Model 5 Pump Seals

 * Light-liquid service * Heavy-liquid serviceValves * Gas/vapor service * Light-liquid service * Heavy-liquid serviceConnectors * Flanges - gas/vapor * Flanges - light liquid * Flanges -heavy liquidAgitators * Light-liquid service * Heavy-liquid servicePressure Relief Devices * Disks * Disk holders, valves,etc.OELSampling ConnectionsCompressor VentReplacement Pump Seals

Monitoring InstrumentData Collection SystemAdministrative and ReportsPlanning and TrainingTOTALS

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak 

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

Offline Leak 

Repair Cost 

($/yr)

Monitoring 

to Verify 

Repair ($)

Annual 

Admin. 

Cost 

($/yr)

Annual 

Misc. 

Charges 

($/yr)

16.00 66.24 7700.24 0 80.00 66.24 0.00 10.90 1643.23

0.17 66.24 231.52 25 4.00 66.24 1848.46 41.860.17 66.24 556.08 25 4.00 66.24 4439.77 100.54

16.00 66.24 0.00 0 80.00 66.24 0.00 0.00 0.00

385.86

20142.75

1341.581926.007999.92

23180.00

8487.84 6288.23 153.29 23180.00 33439.34

Baseline 
Option 1 Cost Estimates

Type of Component Number of Components

Initial 

Monitoring 

Fee or Unit 

Cost ($/comp)

Initial LDAR 

Costs ($) 

(Capital)

Initial 

LDAR 

Admin. 

Costs

Frequency of 

Monitoring 

(times/yr)

Subsequent 

Monitoring 

Fee ($/comp) 

or Charge 

(%)

Annual 

Monitoring 

Costs ($/yr)

Annual 

Maintenance 

Costs ($/yr)

Initial Leak 

Frequency 

(%)

Initial 

Numbe

of Leak

Model 6 Pump Seals

 * Light-liquid service 176 23.80 5828.68 12 1.50 6806.84 5239.29 0.88 1.54 

 * Heavy-liquid service 246 1.10 271.58Valves * Gas/vapor service 3,263 23.80 80612.91 2 1.50 9789.00 1.18 38.65 

 * Light-liquid service 5,857 23.80 145570.13 2 1.50 17571.00 1.38 80.84 

 * Heavy-liquid service 3,163 1.10 3491.95Connectors * Flanges - gas/vapor 7,641 1.10 8435.66 * Flanges - light liquid 13,379 1.10 14770.42

 * Flanges -heavy liquid 7,725 1.10 8528.40

Agitators * Light-liquid service 0 23.80 0.00 12 1.50 0.00 0.00 0.88 0.00 

 * Heavy-liquid service 0 1.10 0.00

Pressure Relief Devices * Disks 119 122.11 14530.64 0 2.00 0.00 290.61

 * Disk holders, valves,etc. 119 6,374.29 758540.26 5.00 37927.01OEL 902 140.92 127111.84 5.00 6355.59Sampling Connections 159 687.86 109369.32 5.00 5468.47Compressor Vent 31 10526.21 326312.58 5.00 16315.63

Replacement Pump Seals 176 282.71 436.61

Monitoring Instrument 1 10,800 10,800

Data Collection System 1 14,500 14,500

hr/activity $/hr

Administrative and Reports 250 92.72 0.00

Planning and Training 320 92.72 29670.40

TOTALS 1629110.97 29670.40 34166.84 71596.60

Capital Costs ($) 1,658,781

Annualized Capital ($/yr) 237,074

Annual Expenses ($/yr) 224,410

Annual Fixed Costs ($/yr) 317,880 461,483

Annual Variable Costs ($/yr) 143,604

Baseline 
Option 1 Cost Estimates

Type of Component

Model 6 Pump Seals

 * Light-liquid service * Heavy-liquid serviceValves * Gas/vapor service * Light-liquid service * Heavy-liquid serviceConnectors * Flanges - gas/vapor * Flanges - light liquid * Flanges -heavy liquidAgitators * Light-liquid service * Heavy-liquid servicePressure Relief Devices * Disks * Disk holders, valves,etc.OELSampling ConnectionsCompressor VentReplacement Pump Seals

Monitoring InstrumentData Collection SystemAdministrative and ReportsPlanning and TrainingTOTALS

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak 

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

Offline Leak 

Repair Cost 

($/yr)

Monitoring 

to Verify 

Repair ($)

Annual 

Admin. 

Cost 

($/yr)

Annual 

Misc. 

Charges 

($/yr)

16.00 66.24 19641.19 0 80.00 66.24 0.00 27.80 4191.43

0.17 66.24 641.30 25 4.00 66.24 5120.15 115.950.17 66.24 1341.42 25 4.00 66.24 10709.93 242.53

16.00 66.24 0.00 0 80.00 66.24 0.00 0.00 0.00

581.23

30341.61

5084.474374.77

13052.50

23180.00

21623.91 15830.08 386.27 23180.00 57626.02

Baseline 
Pump Option 1 Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) 

Model 1

Pump Seals * Light-liquid service 15 0.00 2146.74 12 1.50 580.13 130.46 13.48 

 * Heavy-liquid service 0 0.00 0.00

Replacement Pump Seals 15 282.71 571.84

hr/activity $/hr

Administrative and Reports 0 92.72

Planning and Training 0 92.72 0.00

TOTALS 2718.58 0.00 580.13 130.46

Capital Costs ($) 2,719

Annualized Capital ($/yr) 444

Annual Expenses ($/yr) 1,305

Baseline Monitoring

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) 

Model 1

Pump Seals * Light-liquid service 15 0.00 385.35 12 1.50 580.13 116.32 2.42 

 * Heavy-liquid service 0 0.00 0.00

Replacement Pump Seals 15 282.71 102.65

hr/activity $/hr

Administrative and Reports 0 92.72

Planning and Training 0 92.72 0.00

TOTALS 488.00 0.00 580.13 116.32

Monitoring Repair

Baseline Capital Costs ($) 488 488.00

Baseline Annualized Capital ($/yr) 80 79.77

Baseline Annual Expenses ($/yr) 1,226 580.75 552.40

INCREMENTAL COSTS OF PUMP OPTION 1

Incremental Capital Costs ($) 2,230.58

Annualized Capital ($/yr) 364.60

Incremental Annual Expenses ($/yr) 78.53

Pumps Option 1 
Pump Option 1 Cost Estimates

Type of Component

Model 1

Pump Seals * Light-liquid service * Heavy-liquid serviceReplacement Pump Seals

Administrative and ReportsPlanning and TrainingTOTALS

Baseline Monitoring

Type of Component

Model 1

Pump Seals * Light-liquid service * Heavy-liquid serviceReplacement Pump SealsAdministrative and ReportsPlanning and TrainingTOTALS

Percent 

Repaired 

OnLine

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak 

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

Offline Leak 

Repair Cost 

($/yr)

Monitoring 

to Verify 

Repair ($)

Annual 

Admin. 

Cost 

($/yr)

Annual 

Misc. 

Charges 

($/yr)

100 16.00 66.24 489.08 0 80.00 66.24 0.00 0.69 104.37

0.00

489.08 0.00 0.69 0.00 104.37

Percent 

Repaired 

OnLine

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak 

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

Offline Leak 

Repair Cost 

($/yr)

Monitoring 

to Verify 

Repair ($)

Annual 

Admin. 

Cost 

($/yr)

Annual 

Misc. 

Charges 

($/yr)

100 16.00 66.24 436.08 0 80.00 66.24 0.00 0.62 93.06

0.00

436.08 0.00 0.62 0.00 93.06

Pumps Option 1 
Pump Option 1 Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) 

Model 2

Pump Seals * Light-liquid service 40 0.00 5724.65 12 1.50 1547.01 347.90 13.48 

 * Heavy-liquid service 5 0.00 0.00

Replacement Pump Seals 40 282.71 1524.89

hr/activity $/hr

Administrative and Reports 0 92.72

Planning and Training 0 92.72 0.00

TOTALS 7249.55 0.00 1547.01 347.90

Capital Costs ($) 7,250

Annualized Capital ($/yr) 1,185

Annual Expenses ($/yr) 3,479

Baseline Monitoring

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) 

Model 2

Pump Seals * Light-liquid service 40 0.00 1027.60 12 1.50 1547.01 310.20 2.42 

 * Heavy-liquid service 5 0.00 0.00

Replacement Pump Seals 40 282.71 273.72

hr/activity $/hr

Administrative and Reports 0 92.72

Planning and Training 0 92.72 0.00

TOTALS 1301.32 0.00 1547.01 310.20

Monitoring Repair

Baseline Capital Costs ($) 1,301 1,301.32

Baseline Annualized Capital ($/yr) 213 212.71

Baseline Annual Expenses ($/yr) 3,270 1,548.65 1,473.07

INCREMENTAL COSTS OF PUMP OPTION 1

Incremental Capital Costs ($) 5,948.23

Annualized Capital ($/yr) 972.27

Incremental Annual Expenses ($/yr) 209.41

Pumps Option 1 
Pump Option 1 Cost Estimates

Type of Component

Model 2

Pump Seals * Light-liquid service * Heavy-liquid serviceReplacement Pump Seals

Administrative and ReportsPlanning and TrainingTOTALS

Baseline Monitoring

Type of Component

Model 2

Pump Seals * Light-liquid service * Heavy-liquid serviceReplacement Pump SealsAdministrative and ReportsPlanning and TrainingTOTALS

Percent 

Repaired 

OnLine

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak 

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

Offline Leak 

Repair Cost 

($/yr)

Monitoring 

to Verify 

Repair ($)

Annual 

Admin. 

Cost 

($/yr)

Annual 

Misc. 

Charges 

($/yr)

100 16.00 66.24 1304.22 0 80.00 66.24 0.00 1.85 278.32

0.00

1304.22 0.00 1.85 0.00 278.32

Percent 

Repaired 

OnLine

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak 

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

Offline Leak 

Repair Cost 

($/yr)

Monitoring 

to Verify 

Repair ($)

Annual 

Admin. 

Cost 

($/yr)

Annual 

Misc. 

Charges 

($/yr)

100 16.00 66.24 1162.87 0 80.00 66.24 0.00 1.65 248.16

0.00

1162.87 0.00 1.65 0.00 248.16

Pumps Option 1 
Pump Option 1 Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) 

Model 3

Pump Seals * Light-liquid service 56 0.00 8014.51 12 1.50 2165.81 487.06 13.48 

 * Heavy-liquid service 36 0.00 0.00

Replacement Pump Seals 56 282.71 2134.85

hr/activity $/hr

Administrative and Reports 0 92.72

Planning and Training 0 92.72 0.00

TOTALS 10149.37 0.00 2165.81 487.06

Capital Costs ($) 10,149

Annualized Capital ($/yr) 1,659

Annual Expenses ($/yr) 4,871

Baseline Monitoring

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) 

Model 3

Pump Seals * Light-liquid service 56 0.00 1438.64 12 1.50 2165.81 434.27 2.42 

 * Heavy-liquid service 36 0.00 0.00

Replacement Pump Seals 56 282.71 383.21

hr/activity $/hr

Administrative and Reports 0 92.72

Planning and Training 0 92.72 0.00

TOTALS 1821.85 0.00 2165.81 434.27

Monitoring Repair

Baseline Capital Costs ($) 1,822 1,821.85

Baseline Annualized Capital ($/yr) 298 297.79

Baseline Annual Expenses ($/yr) 4,578 2,168.12 2,062.30

INCREMENTAL COSTS OF PUMP OPTION 1

Incremental Capital Costs ($) 8,327.52

Annualized Capital ($/yr) 1,361.17

Incremental Annual Expenses ($/yr) 293.18

Pumps Option 1 
Pump Option 1 Cost Estimates

Type of Component

Model 3

Pump Seals * Light-liquid service * Heavy-liquid serviceReplacement Pump Seals

Administrative and ReportsPlanning and TrainingTOTALS

Baseline Monitoring

Type of Component

Model 3

Pump Seals * Light-liquid service * Heavy-liquid serviceReplacement Pump SealsAdministrative and ReportsPlanning and TrainingTOTALS

Percent 

Repaired 

OnLine

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak 

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

Offline Leak 

Repair Cost 

($/yr)

Monitoring 

to Verify 

Repair ($)

Annual 

Admin. 

Cost 

($/yr)

Annual 

Misc. 

Charges 

($/yr)

100 16.00 66.24 1825.91 0 80.00 66.24 0.00 2.58 389.65

0.00

1825.91 0.00 2.58 0.00 389.65

Percent 

Repaired 

OnLine

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak 

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

Offline Leak 

Repair Cost 

($/yr)

Monitoring 

to Verify 

Repair ($)

Annual 

Admin. 

Cost 

($/yr)

Annual 

Misc. 

Charges 

($/yr)

100 16.00 66.24 1628.02 0 80.00 66.24 0.00 2.30 347.42

0.00

1628.02 0.00 2.30 0.00 347.42

Pumps Option 1 
Pump Option 1 Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) 

Model 4

Pump Seals * Light-liquid service 8 0.00 281.35 12 1.50 309.40 267.10 3.31 

 * Heavy-liquid service 8 0.00 0.00

Replacement Pump Seals 8 282.71 74.94

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00TOTALS 356.29 0.00 309.40 267.10

Capital Costs ($) 356

Annualized Capital ($/yr) 58

Annual Expenses ($/yr) 1,793

Baseline Monitoring

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) 

Model 4

Pump Seals * Light-liquid service 8 0.00 74.50 12 1.50 309.40 238.15 0.88  * Heavy-liquid service 8 0.00 0.00Replacement Pump Seals 8 282.71 19.85

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00TOTALS 94.35 0.00 309.40 238.15

Monitoring Repair

Baseline Capital Costs ($) 94 94.35

Baseline Annualized Capital ($/yr) 15 15.42

Baseline Annual Expenses ($/yr) 1,632 310.67 1,130.93

INCREMENTAL COSTS OF PUMP OPTION 1

Incremental Capital Costs ($) 261.95

Annualized Capital ($/yr) 42.82

Incremental Annual Expenses ($/yr) 160.77

Pumps Option 1 
Pump Option 1 Cost Estimates

Type of Component

Model 4

Pump Seals * Light-liquid service * Heavy-liquid serviceReplacement Pump Seals

Administrative and ReportsPlanning and TrainingTOTALS

Baseline Monitoring

Type of Component

Model 4

Pump Seals * Light-liquid service * Heavy-liquid serviceReplacement Pump SealsAdministrative and ReportsPlanning and TrainingTOTALS

Percent 

Repaired 

OnLine

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak 

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

Offline Leak 

Repair Cost 

($/yr)

Monitoring 

to Verify 

Repair ($)

Annual 

Admin. 

Cost 

($/yr)

Annual 

Misc. 

Charges 

($/yr)

100 16.00 66.24 1001.30 0 80.00 66.24 0.00 1.42 213.68

0.00

1001.30 0.00 1.42 0.00 213.68

Percent 

Repaired 

OnLine

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak 

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

Offline Leak 

Repair Cost 

($/yr)

Monitoring 

to Verify 

Repair ($)

Annual 

Admin. 

Cost 

($/yr)

Annual 

Misc. 

Charges 

($/yr)

100 16.00 66.24 892.78 0 80.00 66.24 0.00 1.26 190.52

0.00

892.78 0.00 1.26 0.00 190.52

Pumps Option 1 
Pump Option 1 Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) 

Model 5

Pump Seals * Light-liquid service 69 0.00 2426.65 12 1.50 2668.59 2303.71 3.31 

 * Heavy-liquid service 61 0.00 0.00

Replacement Pump Seals 69 282.71 646.39

hr/activity $/hr

Administrative and Reports 0 92.72

Planning and Training 0 92.72 0.00

TOTALS 3073.04 0.00 2668.59 2303.71

Capital Costs ($) 3,073

Annualized Capital ($/yr) 502

Annual Expenses ($/yr) 15,464

Baseline Monitoring

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) 

Model 5

Pump Seals * Light-liquid service 69 0.00 642.59 12 1.50 2668.59 2054.04 0.88 

 * Heavy-liquid service 61 0.00 0.00

Replacement Pump Seals 69 282.71 171.17

hr/activity $/hr

Administrative and Reports 0 92.72

Planning and Training 0 92.72 0.00

TOTALS 813.76 0.00 2668.59 2054.04

Monitoring Repair

Baseline Capital Costs ($) 814 813.76

Baseline Annualized Capital ($/yr) 133 133.01

Baseline Annual Expenses ($/yr) 14,077 2,679.49 9,754.28

INCREMENTAL COSTS OF PUMP OPTION 1

Incremental Capital Costs ($) 2,259.28

Annualized Capital ($/yr) 369.29

Incremental Annual Expenses ($/yr) 1,386.68

Pumps Option 1 
Pump Option 1 Cost Estimates

Type of Component

Model 5

Pump Seals * Light-liquid service * Heavy-liquid serviceReplacement Pump Seals

Administrative and ReportsPlanning and TrainingTOTALS

Baseline Monitoring

Type of Component

Model 5

Pump Seals * Light-liquid service * Heavy-liquid serviceReplacement Pump SealsAdministrative and ReportsPlanning and TrainingTOTALS

Percent 

Repaired 

OnLine

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak 

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

Offline Leak 

Repair Cost 

($/yr)

Monitoring 

to Verify 

Repair ($)

Annual 

Admin. 

Cost 

($/yr)

Annual 

Misc. 

Charges 

($/yr)

100 16.00 66.24 8636.20 0 80.00 66.24 0.00 12.22 1842.97

0.00

8636.20 0.00 12.22 0.00 1842.97

Percent 

Repaired 

OnLine

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak 

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

Offline Leak 

Repair Cost 

($/yr)

Monitoring 

to Verify 

Repair ($)

Annual 

Admin. 

Cost 

($/yr)

Annual 

Misc. 

Charges 

($/yr)

100 16.00 66.24 7700.24 0 80.00 66.24 0.00 10.90 1643.23

0.00

7700.24 0.00 10.90 0.00 1643.23

Pumps Option 1 
Pump Option 1 Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) 

Model 6

Pump Seals * Light-liquid service 176 0.00 6189.71 12 1.50 6806.84 5876.12 3.31 

 * Heavy-liquid service 246 0.00 0.00

Replacement Pump Seals 176 282.71 1648.77

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00

TOTALS 7838.49 0.00 6806.84 5876.12

Capital Costs ($) 7,838

Annualized Capital ($/yr) 1,281

Annual Expenses ($/yr) 39,444

Baseline Monitoring

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) 

Model 6

Pump Seals * Light-liquid service 176 0.00 1639.08 12 1.50 6806.84 5239.29 0.88 

 * Heavy-liquid service 246 0.00 0.00

Replacement Pump Seals 176 282.71 436.61

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00

TOTALS 2075.69 0.00 6806.84 5239.29

Monitoring Repair

Baseline Capital Costs ($) 2,076 2,075.69

Baseline Annualized Capital ($/yr) 339 339.28

Baseline Annual Expenses ($/yr) 35,907 6,834.63 24,880.48

INCREMENTAL COSTS OF PUMP OPTION 1

Incremental Capital Costs ($) 5,762.80

Annualized Capital ($/yr) 941.96

Incremental Annual Expenses ($/yr) 3,537.05

Pumps Option 1 
Pump Option 1 Cost Estimates

Type of Component

Model 6

Pump Seals * Light-liquid service * Heavy-liquid serviceReplacement Pump Seals

Administrative and ReportsPlanning and TrainingTOTALS

Baseline Monitoring

Type of Component

Model 6

Pump Seals * Light-liquid service * Heavy-liquid serviceReplacement Pump SealsAdministrative and ReportsPlanning and TrainingTOTALS

Percent 

Repaired 

OnLine

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak 

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

Offline Leak 

Repair Cost 

($/yr)

Monitoring 

to Verify 

Repair ($)

Annual 

Admin. 

Cost 

($/yr)

Annual 

Misc. 

Charges 

($/yr)

100 16.00 66.24 22028.56 0 80.00 66.24 0.00 31.18 4700.90

0.00

22028.56 0.00 31.18 0.00 4700.90

Percent 

Repaired 

OnLine

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak 

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

Offline Leak 

Repair Cost 

($/yr)

Monitoring 

to Verify 

Repair ($)

Annual 

Admin. 

Cost 

($/yr)

Annual 

Misc. 

Charges 

($/yr)

100 16.00 66.24 19641.19 0 80.00 66.24 0.00 27.80 4191.43

0.00

19641.19 0.00 27.80 0.00 4191.43

Pumps Option 1 
Pump Option 2 Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) 

Model 1 Pump Seals

 * Light-liquid service 15 0.00 2934.59 12 1.50 580.13 166.99 18.43 

 * Heavy-liquid service 0 0.00 0.00

Replacement Pump Seals 15 282.71 781.70

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00TOTALS 3716.29 0.00 580.13 166.99

Capital Costs ($) 3,716

Annualized Capital ($/yr) 607

Annual Expenses ($/yr) 1,508

INCREMENTAL COSTS OF PUMP OPTION 2

Incremental Capital Costs ($) 998

Annualized Capital ($/yr) 163

Incremental Annual Expenses ($/yr) 203

Pumps Option 2 
Pump Option 2 Cost Estimates

Type of Component

Model 1 Pump Seals

 * Light-liquid service * Heavy-liquid serviceReplacement Pump Seals

Administrative and ReportsPlanning and TrainingTOTALS

Percent 

Repaired 

OnLine

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak 

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

Offline Leak 

Repair Cost 

($/yr)

Monitoring 

to Verify 

Repair ($)

Annual 

Admin. 

Cost 

($/yr)

Annual 

Misc. 

Charges 

($/yr)

100 16.00 66.24 626.02 0 80.00 66.24 0.00 0.89 133.59

0.00

626.02 0.00 0.89 0.00 133.59

Pumps Option 2 
Pumps Option 2 Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) 

Model 2 Pump Seals

 * Light-liquid service 40 0.00 7825.59 12 1.50 1547.01 445.31 18.43 

 * Heavy-liquid service 5 0.00 0.00

Replacement Pump Seals 40 282.71 2084.53

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00TOTALS 9910.11 0.00 1547.01 445.31

Capital Costs ($) 9,910

Annualized Capital ($/yr) 1,620

Annual Expenses ($/yr) 4,020

INCREMENTAL COSTS OF PUMP OPTION 2

Incremental Capital Costs ($) 2,661

Annualized Capital ($/yr) 435

Incremental Annual Expenses ($/yr) 541

Pumps Option 2 
Pumps Option 2 Cost Estimates

Type of Component

Model 2 Pump Seals

 * Light-liquid service * Heavy-liquid serviceReplacement Pump Seals

Administrative and ReportsPlanning and TrainingTOTALS

Percent 

Repaired 

OnLine

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak 

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

Offline Leak 

Repair Cost 

($/yr)

Monitoring 

to Verify 

Repair ($)

Annual 

Admin. 

Cost 

($/yr)

Annual 

Misc. 

Charges 

($/yr)

100 16.00 66.24 1669.38 0 80.00 66.24 0.00 2.36 356.25

0.00

1669.38 0.00 2.36 0.00 356.25

Pumps Option 2 
Pumps Option 2 Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) 

Model 3 Pump Seals

 * Light-liquid service 56 0.00 10955.82 12 1.50 2165.81 623.43 18.43 

 * Heavy-liquid service 36 0.00 0.00

Replacement Pump Seals 56 282.71 2918.34

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00TOTALS 13874.16 0.00 2165.81 623.43

Capital Costs ($) 13,874

Annualized Capital ($/yr) 2,268

Annual Expenses ($/yr) 5,628

INCREMENTAL COSTS OF PUMP OPTION 2

Incremental Capital Costs ($) 3,725

Annualized Capital ($/yr) 609

Incremental Annual Expenses ($/yr) 757

Pumps Option 2 
Pumps Option 2 Cost Estimates

Type of Component

Model 3 Pump Seals

 * Light-liquid service * Heavy-liquid serviceReplacement Pump Seals

Administrative and ReportsPlanning and TrainingTOTALS

Percent 

Repaired 

OnLine

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak 

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

Offline Leak 

Repair Cost 

($/yr)

Monitoring 

to Verify 

Repair ($)

Annual 

Admin. 

Cost 

($/yr)

Annual 

Misc. 

Charges 

($/yr)

100 16.00 66.24 2337.13 0 80.00 66.24 0.00 3.31 498.74

0.00

2337.13 0.00 3.31 0.00 498.74

Pumps Option 2 
Pumps Option 2 Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) 

Model 4 Pump Seals

 * Light-liquid service 8 0.00 388.31 12 1.50 309.40 341.88 4.57 

 * Heavy-liquid service 8 0.00 0.00

Replacement Pump Seals 8 282.71 103.43

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00TOTALS 491.74 0.00 309.40 341.88

Capital Costs ($) 492

Annualized Capital ($/yr) 80

Annual Expenses ($/yr) 2,208

INCREMENTAL COSTS OF PUMP OPTION 2

Incremental Capital Costs ($) 135

Annualized Capital ($/yr) 22

Incremental Annual Expenses ($/yr) 415

Pumps Option 2 
Pumps Option 2 Cost Estimates

Type of Component

Model 4 Pump Seals

 * Light-liquid service * Heavy-liquid serviceReplacement Pump Seals

Administrative and ReportsPlanning and TrainingTOTALS

Percent 

Repaired 

OnLine

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak 

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

Offline Leak 

Repair Cost 

($/yr)

Monitoring 

to Verify 

Repair ($)

Annual 

Admin. 

Cost 

($/yr)

Annual 

Misc. 

Charges 

($/yr)

100 16.00 66.24 1281.65 0 80.00 66.24 0.00 1.81 273.50

0.00

1281.65 0.00 1.81 0.00 273.50

Pumps Option 2 
Pumps Option 2 Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) 

Model 5 Pump Seals

 * Light-liquid service 69 0.00 3349.14 12 1.50 2668.59 2948.71 4.57 

 * Heavy-liquid service 61 0.00 0.00

Replacement Pump Seals 69 282.71 892.12

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00TOTALS 4241.26 0.00 2668.59 2948.71

Capital Costs ($) 4,241

Annualized Capital ($/yr) 693

Annual Expenses ($/yr) 19,046

INCREMENTAL COSTS OF PUMP OPTION 2

Incremental Capital Costs ($) 1,168

Annualized Capital ($/yr) 191

Incremental Annual Expenses ($/yr) 3,582

Pumps Option 2 
Pumps Option 2 Cost Estimates

Type of Component

Model 5 Pump Seals

 * Light-liquid service * Heavy-liquid serviceReplacement Pump Seals

Administrative and ReportsPlanning and TrainingTOTALS

Percent 

Repaired 

OnLine

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak 

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

Offline Leak 

Repair Cost 

($/yr)

Monitoring 

to Verify 

Repair ($)

Annual 

Admin. 

Cost 

($/yr)

Annual 

Misc. 

Charges 

($/yr)

100 16.00 66.24 11054.21 0 80.00 66.24 0.00 15.65 2358.97

0.00

11054.21 0.00 15.65 0.00 2358.97

Pumps Option 2 
Pumps Option 2 Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) 

Model 6 Pump Seals

 * Light-liquid service 176 0.00 8542.73 12 1.50 6806.84 7521.35 4.57 

 * Heavy-liquid service 246 0.00 0.00

Replacement Pump Seals 176 282.71 2275.55

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00TOTALS 10818.28 0.00 6806.84 7521.35

Capital Costs ($) 10,818

Annualized Capital ($/yr) 1,768

Annual Expenses ($/yr) 48,581

INCREMENTAL COSTS OF PUMP OPTION 2

Incremental Capital Costs ($) 2,980

Annualized Capital ($/yr) 487

Incremental Annual Expenses ($/yr) 9,138

Pumps Option 2 
Pumps Option 2 Cost Estimates

Type of Component

Model 6 Pump Seals

 * Light-liquid service * Heavy-liquid serviceReplacement Pump Seals

Administrative and ReportsPlanning and TrainingTOTALS

Percent 

Repaired 

OnLine

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak 

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

Offline Leak 

Repair Cost 

($/yr)

Monitoring 

to Verify 

Repair ($)

Annual 

Admin. 

Cost 

($/yr)

Annual 

Misc. 

Charges 

($/yr)

100 16.00 66.24 28196.24 0 80.00 66.24 0.00 39.91 6017.08

0.00

28196.24 0.00 39.91 0.00 6017.08

Pumps Option 2 
Valve Option 1 Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) 

Model 1

Valves * Gas/vapor service 77 0.00 423.93 2 1.50 231.00 7.24 

 * Light-liquid service 380 0.00 1399.22 2 1.50 1140.00 4.84 

 * Heavy-liquid service 0 0.00 0.00

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00TOTALS 1823.15 0.00 1371.00 0.00

Capital Costs ($) 1,823.15

Annualized Capital ($/yr) 259

Annual Expenses ($/yr) 1,723

Baseline Monitoring

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) 

Model 1

Valves * Gas/vapor service 77 0.00 19.56 2 1.50 231.00 0.33 

 * Light-liquid service 380 0.00 96.52 2 1.50 1140.00 0.33 

 * Heavy-liquid service 0 0.00 0.00

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00

TOTALS 116.08 0.00 1371.00 0.00

Monitoring Repair

Baseline Capital Costs ($) 116.08 116.08

Baseline Annualized Capital ($/yr) 16 16.48

Baseline Annual Expenses ($/yr) 1,603 1,375.58 227.58

INCREMENTAL COSTS OF VALVE OPTION 1

Incremental Capital Costs ($) 1,707.07

Annualized Capital ($/yr) 242.40

Incremental Annual Expenses ($/yr) 119.35

Valves Option 1 
Valve Option 1 Cost Estimates

Type of Component

Model 1

Valves * Gas/vapor service * Light-liquid service * Heavy-liquid serviceAdministrative and ReportsPlanning and TrainingTOTALS

Baseline Monitoring

Type of Component

Model 1

Valves * Gas/vapor service * Light-liquid service * Heavy-liquid serviceAdministrative and ReportsPlanning and TrainingTOTALS

Percent 

Repaired 

OnLine

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak 

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

Offline Leak 

Repair Cost 

($/yr)

Monitoring 

to Verify 

Repair ($)

Annual 

Admin. 

Cost 

($/yr)

Annual 

Misc. 

Charges 

($/yr)

75 0.17 66.24 6.46 25 4.00 66.24 51.60 1.1775 0.17 66.24 31.89 25 4.00 66.24 254.63 5.77

0.00

38.35 306.22 6.93 0.00 0.00

Percent 

Repaired 

OnLine

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak 

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

Offline Leak 

Repair Cost 

($/yr)

Monitoring 

to Verify 

Repair ($)

Annual 

Admin. 

Cost 

($/yr)

Annual 

Misc. 

Charges 

($/yr)

75 0.17 66.24 4.27 25 4.00 66.24 34.08 0.7775 0.17 66.24 21.06 25 4.00 66.24 168.17 3.81

0.00

25.33 202.25 4.58 0.00 0.00

Valves Option 1 
Valve Option 1 Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) 

Model 2

Valves * Gas/vapor service 414 0.00 2279.31 2 1.50 1242.00 7.24 

 * Light-liquid service 1,179 0.00 4341.26 2 1.50 3537.00 4.84  * Heavy-liquid service 71 0.00 0.00

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00TOTALS 6620.56 0.00 4779.00 0.00

Capital Costs ($) 6,620.56

Annualized Capital ($/yr) 940

Annual Expenses ($/yr) 6,004

Baseline Monitoring

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) 

Model 2

Valves * Gas/vapor service 414 0.00 105.16 2 1.50 1242.00 0.33 

 * Light-liquid service 1,179 0.00 299.48 2 1.50 3537.00 0.33 

 * Heavy-liquid service 71 0.00 0.00

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00

TOTALS 404.63 0.00 4779.00 0.00

Monitoring Repair

Baseline Capital Costs ($) 404.63 404.63

Baseline Annualized Capital ($/yr) 57 57.46

Baseline Annual Expenses ($/yr) 5,588 4,794.96 793.30

INCREMENTAL COSTS OF VALVE OPTION 1

Incremental Capital Costs ($) 6,215.93

Annualized Capital ($/yr) 882.66

Incremental Annual Expenses ($/yr) 416.02

Valves Option 1 
Valve Option 1 Cost Estimates

Type of Component

Model 2

Valves * Gas/vapor service * Light-liquid service * Heavy-liquid serviceAdministrative and ReportsPlanning and TrainingTOTALS

Baseline Monitoring

Type of Component

Model 2

Valves * Gas/vapor service * Light-liquid service * Heavy-liquid serviceAdministrative and ReportsPlanning and TrainingTOTALS

Percent 

Repaired 

OnLine

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak 

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

Offline Leak 

Repair Cost 

($/yr)

Monitoring 

to Verify 

Repair ($)

Annual 

Admin. 

Cost 

($/yr)

Annual 

Misc. 

Charges 

($/yr)

75 0.17 66.24 34.75 25 4.00 66.24 277.41 6.2875 0.17 66.24 98.95 25 4.00 66.24 790.01 17.89

0.00

133.69 1067.42 24.17 0.00 0.00

Percent 

Repaired 

OnLine

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak 

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

Offline Leak 

Repair Cost 

($/yr)

Monitoring 

to Verify 

Repair ($)

Annual 

Admin. 

Cost 

($/yr)

Annual 

Misc. 

Charges 

($/yr)

75 0.17 66.24 22.95 25 4.00 66.24 183.22 4.1575 0.17 66.24 65.35 25 4.00 66.24 521.78 11.82

0.00

88.30 705.00 15.96 0.00 0.00

Valves Option 1 
Valve Option 1 Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) 

Model 3

Valves * Gas/vapor service 1,379 0.00 7592.18 2 1.50 4137.00 7.24 

 * Light-liquid service 1,980 0.00 7290.66 2 1.50 5940.00 4.84  * Heavy-liquid service 1,272 0.00 0.00

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00TOTALS 14882.84 0.00 10077.00 0.00

Capital Costs ($) 14,882.84

Annualized Capital ($/yr) 2,113

Annual Expenses ($/yr) 12,661

Baseline Monitoring

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) 

Model 3

Valves * Gas/vapor service 1,379 0.00 350.28 2 1.50 4137.00 0.33 

 * Light-liquid service 1,980 0.00 502.94 2 1.50 5940.00 0.33 

 * Heavy-liquid service 1,272 0.00 0.00

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00

TOTALS 853.21 0.00 10077.00 0.00

Monitoring Repair

Baseline Capital Costs ($) 853.21 853.21

Baseline Annualized Capital ($/yr) 121 121.16

Baseline Annual Expenses ($/yr) 11,783 10,110.66 1,672.76

INCREMENTAL COSTS OF VALVE OPTION 1

Incremental Capital Costs ($) 14,029.63

Annualized Capital ($/yr) 1,992.21

Incremental Annual Expenses ($/yr) 877.22

Valves Option 1 
Valve Option 1 Cost Estimates

Type of Component

Model 3

Valves * Gas/vapor service * Light-liquid service * Heavy-liquid serviceAdministrative and ReportsPlanning and TrainingTOTALS

Baseline Monitoring

Type of Component

Model 3

Valves * Gas/vapor service * Light-liquid service * Heavy-liquid serviceAdministrative and ReportsPlanning and TrainingTOTALS

Percent 

Repaired 

OnLine

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak 

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

Offline Leak 

Repair Cost 

($/yr)

Monitoring 

to Verify 

Repair ($)

Annual 

Admin. 

Cost 

($/yr)

Annual 

Misc. 

Charges 

($/yr)

75 0.17 66.24 115.73 25 4.00 66.24 924.03 20.9275 0.17 66.24 166.17 25 4.00 66.24 1326.74 30.04

0.00

281.91 2250.77 50.97 0.00 0.00

Percent 

Repaired 

OnLine

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak 

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

Offline Leak 

Repair Cost 

($/yr)

Monitoring 

to Verify 

Repair ($)

Annual 

Admin. 

Cost 

($/yr)

Annual 

Misc. 

Charges 

($/yr)

75 0.17 66.24 76.44 25 4.00 66.24 610.29 13.8275 0.17 66.24 109.75 25 4.00 66.24 876.27 19.84

0.00

186.19 1486.57 33.66 0.00 0.00

Valves Option 1 
Valve Option 1 Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) 

Model 4

Valves * Gas/vapor service 75 0.00 339.09 2 1.50 225.00 5.95 

 * Light-liquid service 251 0.00 1203.19 2 1.50 753.00 6.30 

 * Heavy-liquid service 216 0.00 0.00

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00TOTALS 1542.28 0.00 978.00 0.00

Capital Costs ($) 1,542.28

Annualized Capital ($/yr) 219

Annual Expenses ($/yr) 1,948

Baseline Monitoring

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) 

Model 4

Valves * Gas/vapor service 75 0.00 67.55 2 1.50 225.00 1.18 

 * Light-liquid service 251 0.00 263.43 2 1.50 753.00 1.38  * Heavy-liquid service 216 0.00 0.00

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00

TOTALS 330.97 0.00 978.00 0.00

Monitoring Repair

Baseline Capital Costs ($) 330.97 330.97

Baseline Annualized Capital ($/yr) 47 47.00

Baseline Annual Expenses ($/yr) 1,640 991.06 648.88

INCREMENTAL COSTS OF VALVE OPTION 1

Incremental Capital Costs ($) 1,211.31

Annualized Capital ($/yr) 172.01

Incremental Annual Expenses ($/yr) 308.19

Valves Option 1 
Valve Option 1 Cost Estimates

Type of Component

Model 4

Valves * Gas/vapor service * Light-liquid service * Heavy-liquid serviceAdministrative and ReportsPlanning and TrainingTOTALS

Baseline Monitoring

Type of Component

Model 4

Valves * Gas/vapor service * Light-liquid service * Heavy-liquid serviceAdministrative and ReportsPlanning and TrainingTOTALS

Percent 

Repaired 

OnLine

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak 

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

Offline Leak 

Repair Cost 

($/yr)

Monitoring 

to Verify 

Repair ($)

Annual 

Admin. 

Cost 

($/yr)

Annual 

Misc. 

Charges 

($/yr)

75 0.17 66.24 23.81 25 4.00 66.24 190.10 4.3075 0.17 66.24 82.04 25 4.00 66.24 655.04 14.83

0.00

105.85 845.14 19.14 0.00 0.00

Percent 

Repaired 

OnLine

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak 

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

Offline Leak 

Repair Cost 

($/yr)

Monitoring 

to Verify 

Repair ($)

Annual 

Admin. 

Cost 

($/yr)

Annual 

Misc. 

Charges 

($/yr)

75 0.17 66.24 14.74 25 4.00 66.24 117.69 2.6775 0.17 66.24 57.49 25 4.00 66.24 458.97 10.39

0.00

72.23 576.66 13.06 0.00 0.00

Valves Option 1 
Valve Option 1 Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) 

Model 5

Valves * Gas/vapor service 1,178 0.00 5325.99 2 1.50 3534.00 5.95 

 * Light-liquid service 2,428 0.00 11638.80 2 1.50 7284.00 6.30 

 * Heavy-liquid service 1,719 0.00 0.00

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00TOTALS 16964.79 0.00 10818.00 0.00

Capital Costs ($) 16,964.79

Annualized Capital ($/yr) 2,409

Annual Expenses ($/yr) 21,519

Baseline Monitoring

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) 

Model 5

Valves * Gas/vapor service 1,178 0.00 1060.92 2 1.50 3534.00 1.18 

 * Light-liquid service 2,428 0.00 2548.19 2 1.50 7284.00 1.38  * Heavy-liquid service 1,719 0.00 0.00

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00

TOTALS 3609.11 0.00 10818.00 0.00

Monitoring Repair

Baseline Capital Costs ($) 3,609.11 3,609.11

Baseline Annualized Capital ($/yr) 512 512.49

Baseline Annual Expenses ($/yr) 18,036 10,960.40 7,075.83

INCREMENTAL COSTS OF VALVE OPTION 1

Incremental Capital Costs ($) 13,355.68

Annualized Capital ($/yr) 1,896.51

Incremental Annual Expenses ($/yr) 3,482.74

Valves Option 1 
Valve Option 1 Cost Estimates

Type of Component

Model 5

Valves * Gas/vapor service * Light-liquid service * Heavy-liquid serviceAdministrative and ReportsPlanning and TrainingTOTALS

Baseline Monitoring

Type of Component

Model 5

Valves * Gas/vapor service * Light-liquid service * Heavy-liquid serviceAdministrative and ReportsPlanning and TrainingTOTALS

Percent 

Repaired 

OnLine

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak 

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

Offline Leak 

Repair Cost 

($/yr)

Monitoring 

to Verify 

Repair ($)

Annual 

Admin. 

Cost 

($/yr)

Annual 

Misc. 

Charges 

($/yr)

75 0.17 66.24 373.97 25 4.00 66.24 2985.82 67.6175 0.17 66.24 793.64 25 4.00 66.24 6336.44 143.49

0.00

1167.61 9322.26 211.10 0.00 0.00

Percent 

Repaired 

OnLine

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak 

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

Offline Leak 

Repair Cost 

($/yr)

Monitoring 

to Verify 

Repair ($)

Annual 

Admin. 

Cost 

($/yr)

Annual 

Misc. 

Charges 

($/yr)

75 0.17 66.24 231.52 25 4.00 66.24 1848.46 41.8675 0.17 66.24 556.08 25 4.00 66.24 4439.77 100.54

0.00

787.60 6288.23 142.40 0.00 0.00

Valves Option 1 
Valve Option 1 Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) 

Model 6

Valves * Gas/vapor service 3,263 0.00 14752.72 2 1.50 9789.00 5.95 

 * Light-liquid service 5,857 0.00 28075.98 2 1.50 17571.00 6.30 

 * Heavy-liquid service 3,163 0.00 0.00

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00TOTALS 42828.70 0.00 27360.00 0.00

Capital Costs ($) 42,828.70

Annualized Capital ($/yr) 6,082

Annual Expenses ($/yr) 54,400

Baseline Monitoring

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) 

Model 5

Valves * Gas/vapor service 3,263 0.00 2938.69 2 1.50 9789.00 1.18 

 * Light-liquid service 5,857 0.00 6146.94 2 1.50 17571.00 1.38  * Heavy-liquid service 3,163 0.00 0.00

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00

TOTALS 9085.63 0.00 27360.00 0.00

Monitoring Repair

Baseline Capital Costs ($) 9,085.63 9,085.63

Baseline Annualized Capital ($/yr) 1,290 1,290.16

Baseline Annual Expenses ($/yr) 45,531 27,718.47 17,812.79

INCREMENTAL COSTS OF VALVE OPTION 1

Incremental Capital Costs ($) 33,743.07

Annualized Capital ($/yr) 4,791.52

Incremental Annual Expenses ($/yr) 8,868.30

Valves Option 1 
Valve Option 1 Cost Estimates

Type of Component

Model 6

Valves * Gas/vapor service * Light-liquid service * Heavy-liquid serviceAdministrative and ReportsPlanning and TrainingTOTALS

Baseline Monitoring

Type of Component

Model 5

Valves * Gas/vapor service * Light-liquid service * Heavy-liquid serviceAdministrative and ReportsPlanning and TrainingTOTALS

Percent 

Repaired 

OnLine

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak 

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

Offline Leak 

Repair Cost 

($/yr)

Monitoring 

to Verify 

Repair ($)

Annual 

Admin. 

Cost 

($/yr)

Annual 

Misc. 

Charges 

($/yr)

75 0.17 66.24 1035.89 25 4.00 66.24 8270.57 187.2975 0.17 66.24 1914.47 25 4.00 66.24 15285.22 346.13

0.00

2950.36 23555.79 533.42 0.00 0.00

Percent 

Repaired 

OnLine

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak 

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

Offline Leak 

Repair Cost 

($/yr)

Monitoring 

to Verify 

Repair ($)

Annual 

Admin. 

Cost 

($/yr)

Annual 

Misc. 

Charges 

($/yr)

75 0.17 66.24 641.30 25 4.00 66.24 5120.15 115.9575 0.17 66.24 1341.42 25 4.00 66.24 10709.93 242.53

0.00

1982.72 15830.08 358.47 0.00 0.00

Valves Option 1 
Valve Option 2 Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Total 'Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Lea

Frequenc

(%) 

Model 1 Valves

 * Gas/vapor service 77 0.00 1314.60 2 1.50 231.00 0.00 12.24 

 * Light-liquid service 380 0.00 4276.56 2 1.50 1140.00 0.00 8.07 

 * Heavy-liquid service 0 0.00 0.00

hr/activity $/hr

Administrative and Reports 0 92.72

Planning and Training 0 92.72 0.00

TOTALS 5591.16 0.00 1371.00 0.00

Capital Costs ($) 5,591

Annualized Capital ($/yr) 794

Annual Expenses ($/yr) 2,150

INCREMENTAL COSTS OF VALVE OPTION 2

Incremental Capital Costs ($) 3,768

Annualized Capital ($/yr) 535

Incremental Annual Expenses ($/yr) 427

Valves Option 2 
Valve Option 2 Cost Estimates

Type of Component

Model 1 Valves

 * Gas/vapor service * Light-liquid service * Heavy-liquid serviceAdministrative and ReportsPlanning and TrainingTOTALS

Percent 

Repaired 

OnLine

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak 

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

Offline Leak 

Repair Cost 

($/yr)

Monitoring 

to Verify 

Repair ($)

Annual 

Admin. 

Cost 

($/yr)

Annual 

Misc. 

Charges 

($/yr)

50 0.17 66.24 5.20 50 4.00 66.24 124.63 1.4150 0.17 66.24 25.68 50 4.00 66.24 615.07 6.96

0.00

30.88 739.70 8.38 0.00 0.00

Valves Option 2 
Valve Option 2 Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Total 'Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Lea

Frequenc

(%) 

Model 2 Valves

 * Gas/vapor service 414 0.00 7068.10 2 1.50 1242.00 0.00 12.24 

 * Light-liquid service 1,179 0.00 13268.59 2 1.50 3537.00 0.00 8.07 

 * Heavy-liquid service 71 0.00 0.00

hr/activity $/hr

Administrative and Reports 0 92.72

Planning and Training 0 92.72 0.00

TOTALS 20336.69 0.00 4779.00 0.00

Capital Costs ($) 20,337

Annualized Capital ($/yr) 2,888

Annual Expenses ($/yr) 7,494

INCREMENTAL COSTS OF VALVE OPTION 2

Incremental Capital Costs ($) 13,716

Annualized Capital ($/yr) 1,948

Incremental Annual Expenses ($/yr) 1,490

Valves Option 2 
Valve Option 2 Cost Estimates

Type of Component

Model 2 Valves

 * Gas/vapor service * Light-liquid service * Heavy-liquid serviceAdministrative and ReportsPlanning and TrainingTOTALS

Percent 

Repaired 

OnLine

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak 

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

Offline Leak 

Repair Cost 

($/yr)

Monitoring 

to Verify 

Repair ($)

Annual 

Admin. 

Cost 

($/yr)

Annual 

Misc. 

Charges 

($/yr)

50 0.17 66.24 27.98 50 4.00 66.24 670.10 7.5950 0.17 66.24 79.67 50 4.00 66.24 1908.33 21.61

0.00

107.65 2578.43 29.19 0.00 0.00

Valves Option 2 
Valve Option 2 Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Total 'Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Lea

Frequenc

(%) 

Model 3 Valves

 * Gas/vapor service 1,379 0.00 23543.27 2 1.50 4137.00 0.00 12.24 

 * Light-liquid service 1,980 0.00 22283.13 2 1.50 5940.00 0.00 8.07  * Heavy-liquid service 1,272 0.00 0.00

hr/activity $/hr

Administrative and Reports 0 92.72

Planning and Training 0 92.72 0.00

TOTALS 45826.40 0.00 10077.00 0.00

Capital Costs ($) 45,826

Annualized Capital ($/yr) 6,507

Annual Expenses ($/yr) 15,802

INCREMENTAL COSTS OF VALVE OPTION 2

Incremental Capital Costs ($) 30,944

Annualized Capital ($/yr) 4,394

Incremental Annual Expenses ($/yr) 3,142

Valves Option 2 
Valve Option 2 Cost Estimates

Type of Component

Model 3 Valves

 * Gas/vapor service * Light-liquid service * Heavy-liquid serviceAdministrative and ReportsPlanning and TrainingTOTALS

Percent 

Repaired 

OnLine

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak 

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

Offline Leak 

Repair Cost 

($/yr)

Monitoring 

to Verify 

Repair ($)

Annual 

Admin. 

Cost 

($/yr)

Annual 

Misc. 

Charges 

($/yr)

50 0.17 66.24 93.19 50 4.00 66.24 2232.05 25.2750 0.17 66.24 133.80 50 4.00 66.24 3204.83 36.29

0.00

226.99 5436.89 61.56 0.00 0.00

Valves Option 2 
Valve Option 2 Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Total 'Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Lea

Frequenc

(%) 

Model 4 Valves

 * Gas/vapor service 75 0.00 1540.77 4 1.50 450.00 0.00 14.73 

 * Light-liquid service 251 0.00 5300.33 4 1.50 1506.00 0.00 15.14 

 * Heavy-liquid service 216 0.00 0.00

hr/activity $/hr

Administrative and Reports 0 92.72

Planning and Training 0 92.72 0.00

TOTALS 6841.09 0.00 1956.00 0.00

Capital Costs ($) 6,841

Annualized Capital ($/yr) 971

Annual Expenses ($/yr) 4,132

INCREMENTAL COSTS OF VALVE OPTION 2

Incremental Capital Costs ($) 5,299

Annualized Capital ($/yr) 752

Incremental Annual Expenses ($/yr) 2,184

Valves Option 2 
Valve Option 2 Cost Estimates

Type of Component

Model 4 Valves

 * Gas/vapor service * Light-liquid service * Heavy-liquid serviceAdministrative and ReportsPlanning and TrainingTOTALS

Percent 

Repaired 

OnLine

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak 

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

Offline Leak 

Repair Cost 

($/yr)

Monitoring 

to Verify 

Repair ($)

Annual 

Admin. 

Cost 

($/yr)

Annual 

Misc. 

Charges 

($/yr)

50 0.17 66.24 21.18 50 4.00 66.24 507.42 5.7550 0.17 66.24 65.10 50 4.00 66.24 1559.35 17.66

0.00

86.29 2066.77 23.40 0.00 0.00

Valves Option 2 
Valve Option 2 Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Total 'Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Lea

Frequenc

(%) 

Model 5 Valves

 * Gas/vapor service 1,178 0.00 24200.33 4 1.50 7068.00 0.00 14.73 

 * Light-liquid service 2,428 0.00 51271.68 4 1.50 14568.00 0.00 15.14  * Heavy-liquid service 1,719 0.00 0.00

hr/activity $/hr

Administrative and Reports 0 92.72

Planning and Training 0 92.72 0.00

TOTALS 75472.01 0.00 21636.00 0.00

Capital Costs ($) 75,472

Annualized Capital ($/yr) 7,281

Annual Expenses ($/yr) 45,913

INCREMENTAL COSTS OF VALVE OPTION 2

Incremental Capital Costs ($) 58,507

Annualized Capital ($/yr) 4,872

Incremental Annual Expenses ($/yr) 24,394

Valves Option 2 
Valve Option 2 Cost Estimates

Type of Component

Model 5 Valves

 * Gas/vapor service * Light-liquid service * Heavy-liquid serviceAdministrative and ReportsPlanning and TrainingTOTALS

Percent 

Repaired 

OnLine

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak 

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

Offline Leak 

Repair Cost 

($/yr)

Monitoring 

to Verify 

Repair ($)

Annual 

Admin. 

Cost 

($/yr)

Annual 

Misc. 

Charges 

($/yr)

50 0.17 66.24 332.74 50 4.00 66.24 7969.83 90.2450 0.17 66.24 629.76 50 4.00 66.24 15084.11 170.79

0.00

962.50 23053.93 261.03 0.00 0.00

Valves Option 2 
Valve Option 2 Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Total 'Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Lea

Frequenc

(%) 

Model 6 Valves

 * Gas/vapor service 3,263 0.00 67033.69 4 1.50 19578.00 0.00 14.73 

 * Light-liquid service 5,857 0.00 123681.32 4 1.50 35142.00 0.00 15.14 

 * Heavy-liquid service 3,163 0.00 0.00

hr/activity $/hr

Administrative and Reports 0 92.72

Planning and Training 0 92.72 0.00

TOTALS 190715.01 0.00 54720.00 0.00

Capital Costs ($) 190,715

Annualized Capital ($/yr) 27,082

Annual Expenses ($/yr) 116,286

INCREMENTAL COSTS OF VALVE OPTION 2

Incremental Capital Costs ($) 147,886

Annualized Capital ($/yr) 21,000

Incremental Annual Expenses ($/yr) 61,886

Valves Option 2 
Valve Option 2 Cost Estimates

Type of Component

Model 6 Valves

 * Gas/vapor service * Light-liquid service * Heavy-liquid serviceAdministrative and ReportsPlanning and TrainingTOTALS

Percent 

Repaired 

OnLine

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak 

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

Offline Leak 

Repair Cost 

($/yr)

Monitoring 

to Verify 

Repair ($)

Annual 

Admin. 

Cost 

($/yr)

Annual 

Misc. 

Charges 

($/yr)

50 0.17 66.24 921.67 50 4.00 66.24 22076.02 249.9550 0.17 66.24 1519.16 50 4.00 66.24 36386.99 411.99

0.00

2440.83 58463.01 661.95 0.00 0.00

Valves Option 2 
Connectors Option 1 Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) 

o

Model 1

Connectors * Flanges - gas/vapor 0 23.80 0.00 0.25 2.50 0.00 0.36 

 * Flanges - light liquid 731 23.80 17514.06 0.25 2.50 456.88 0.36  * Flanges -heavy liquid 0 0.00 0.00

hr/activity $/hr

Administrative and Reports 50 92.72

Planning and Training 20 92.72 1854.40

TOTALS 17514.06 1854.40 456.88 0.00

INCREMENTAL COSTS OF CONNECTORS OPTION 1

Incremental Capital Costs ($) 19,368

Annualized Capital ($/yr) 2,750

Incremental Annual Expenses ($/yr) 5,122

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) 

o

Model 2

Connectors * Flanges - gas/vapor 0 23.80 0.00 0.25 2.50 0.00 0.36 

 * Flanges - light liquid 2,662 23.80 63778.96 0.25 2.50 1663.75 0.36 

 * Flanges -heavy liquid 0 0.00 0.00

hr/activity $/hr

Administrative and Reports 50 92.72

Planning and Training 20 92.72 1854.40

TOTALS 63778.96 1854.40 1663.75 0.00

INCREMENTAL COSTS OF CONNECTORS OPTION 1

Incremental Capital Costs ($) 65,633

Annualized Capital ($/yr) 9,320

Incremental Annual Expenses ($/yr) 6,405

Connectors Option 1 
Connectors Option 1 Cost Estimates

Type of Component

Model 1

Connectors * Flanges - gas/vapor * Flanges - light liquid * Flanges -heavy liquidAdministrative and ReportsPlanning and TrainingTOTALS

Type of Component

Model 2

Connectors * Flanges - gas/vapor * Flanges - light liquid * Flanges -heavy liquidAdministrative and ReportsPlanning and TrainingTOTALS

Percent 

Repaired 

OnLine

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak 

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

Offline Leak 

Repair Cost 

($/yr)

Monitoring 

to Verify 

Repair ($)

Annual 

Admin. 

Cost 

($/yr)

Annual 

Misc. 

Charges 

($/yr)

75 0.17 66.24 0.00 25 2.00 66.24 0.00 0.0075 0.17 66.24 5.46 25 2.00 66.24 21.79 1.64

4636.00

5.46 21.79 1.64 4636.00 0.00

Percent 

Repaired 

OnLine

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak 

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

Offline Leak 

Repair Cost 

($/yr)

Monitoring 

to Verify 

Repair ($)

Annual 

Admin. 

Cost 

($/yr)

Annual 

Misc. 

Charges 

($/yr)

75 0.17 66.24 0.00 25 2.00 66.24 0.00 0.0075 0.17 66.24 19.88 25 2.00 66.24 79.35 5.99

4636.00

19.88 79.35 5.99 4636.00 0.00

Connectors Option 1 
Connectors Option 1 Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) 

o

Model 3

Connectors * Flanges - gas/vapor 0 23.80 0.00 0.25 2.50 0.00 0.36 

 * Flanges - light liquid 7,410 23.80 177536.48 0.25 2.50 4631.25 0.36  * Flanges -heavy liquid 0 0.00 0.00

hr/activity $/hr

Administrative and Reports 50 92.72

Planning and Training 20 92.72 1854.40

TOTALS 177536.48 1854.40 4631.25 0.00

INCREMENTAL COSTS OF CONNECTORS OPTION 1

Incremental Capital Costs ($) 179,391

Annualized Capital ($/yr) 25,474

Incremental Annual Expenses ($/yr) 9,560

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) 

o

Model 4

Connectors * Flanges - gas/vapor 164 23.80 4023.60 0.25 2.50 102.50 1.70 

 * Flanges - light liquid 555 23.80 13616.44 0.25 2.50 346.88 1.70  * Flanges -heavy liquid 454 0.00 0.00

hr/activity $/hr

Administrative and Reports 50 92.72

Planning and Training 20 92.72 1854.40

TOTALS 17640.03 1854.40 449.38 0.00

INCREMENTAL COSTS OF CONNECTORS OPTION 1

Incremental Capital Costs ($) 19,494

Annualized Capital ($/yr) 2,768

Incremental Annual Expenses ($/yr) 5,150

Connectors Option 1 
Connectors Option 1 Cost Estimates

Type of Component

Model 3

Connectors * Flanges - gas/vapor * Flanges - light liquid * Flanges -heavy liquidAdministrative and ReportsPlanning and TrainingTOTALS

Type of Component

Model 4

Connectors * Flanges - gas/vapor * Flanges - light liquid * Flanges -heavy liquidAdministrative and ReportsPlanning and TrainingTOTALS

Percent 

Repaired 

OnLine

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak 

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

Offline Leak 

Repair Cost 

($/yr)

Monitoring 

to Verify 

Repair ($)

Annual 

Admin. 

Cost 

($/yr)

Annual 

Misc. 

Charges 

($/yr)

75 0.17 66.24 0.00 25 2.00 66.24 0.00 0.0075 0.17 66.24 55.33 25 2.00 66.24 220.88 16.67

4636.00

55.33 220.88 16.67 4636.00 0.00

Percent 

Repaired 

OnLine

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak 

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

Offline Leak 

Repair Cost 

($/yr)

Monitoring 

to Verify 

Repair ($)

Annual 

Admin. 

Cost 

($/yr)

Annual 

Misc. 

Charges 

($/yr)

75 0.17 66.24 2.77 25 2.00 66.24 11.05 0.8375 0.17 66.24 9.37 25 2.00 66.24 37.39 2.82

4636.00

12.13 48.44 3.66 4636.00 0.00

Connectors Option 1 
Connectors Option 1 Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) 

o

Model 5

Connectors * Flanges - gas/vapor 2,333 23.80 57238.10 0.25 2.50 1458.13 1.70 

 * Flanges - light liquid 4,644 23.80 113936.46 0.25 2.50 2902.50 1.70  * Flanges -heavy liquid 4,186 0.00 0.00

hr/activity $/hr

Administrative and Reports 50 92.72

Planning and Training 20 92.72 1854.40

TOTALS 171174.56 1854.40 4360.63 0.00

INCREMENTAL COSTS OF CONNECTORS OPTION 1

Incremental Capital Costs ($) 173,029

Annualized Capital ($/yr) 24,570

Incremental Annual Expenses ($/yr) 9,620

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Leak Frequency (%) 

o

Model 6

Connectors * Flanges - gas/vapor 7,641 23.80 187465.22 0.25 2.50 4775.63 1.70 

 * Flanges - light liquid 13,379 23.80 328242.00 0.25 2.50 8361.88 1.70  * Flanges -heavy liquid 7,725 0.00 0.00

hr/activity $/hr

Administrative and Reports 50 92.72

Planning and Training 20 92.72 1854.40

TOTALS 515707.22 1854.40 13137.50 0.00

INCREMENTAL COSTS OF CONNECTORS OPTION 1

Incremental Capital Costs ($) 517,562

Annualized Capital ($/yr) 73,494

Incremental Annual Expenses ($/yr) 19,651

Connectors Option 1 
Connectors Option 1 Cost Estimates

Type of Component

Model 5

Connectors * Flanges - gas/vapor * Flanges - light liquid * Flanges -heavy liquidAdministrative and ReportsPlanning and TrainingTOTALS

Type of Component

Model 6

Connectors * Flanges - gas/vapor * Flanges - light liquid * Flanges -heavy liquidAdministrative and ReportsPlanning and TrainingTOTALS

Percent 

Repaired 

OnLine

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak 

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

Offline Leak 

Repair Cost 

($/yr)

Monitoring 

to Verify 

Repair ($)

Annual 

Admin. 

Cost 

($/yr)

Annual 

Misc. 

Charges 

($/yr)

75 0.17 66.24 39.37 25 2.00 66.24 157.17 11.8675 0.17 66.24 78.37 25 2.00 66.24 312.85 23.61

4636.00

117.74 470.01 35.48 4636.00 0.00

Percent 

Repaired 

OnLine

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak 

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

Offline Leak 

Repair Cost 

($/yr)

Monitoring 

to Verify 

Repair ($)

Annual 

Admin. 

Cost 

($/yr)

Annual 

Misc. 

Charges 

($/yr)

75 0.17 66.24 128.94 25 2.00 66.24 514.74 38.8575 0.17 66.24 225.77 25 2.00 66.24 901.29 68.03

4636.00

354.72 1416.04 106.89 4636.00 0.00

Connectors Option 1 
OEL Monitoring Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Le

Frequen

(%) 

Model 1

OEL 140.92 0.00 5.00 0.00

Annual monitoring 33 23.80 808.13 1 1.50 49.50 0.90 

hr/activity $/hr

Administrative and Reports 0 92.72

Planning and Training 0 92.72 0.00

TOTALS 808.13 0.00 49.50 0.00

Incremental Capital Costs ($) 808.13

Annualized Capital ($/yr) 114.75

Incremental Annual Expenses ($/yr) 60.79

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Le

Frequen

(%) 

Model 2

OEL 140.92 0.00 5.00 0.00

Annual monitoring 141 23.80 3452.93 1 1.50 211.50 0.90 

hr/activity $/hr

Administrative and Reports 0 92.72Planning and Training 0 92.72 0.00

TOTALS 3452.93 0.00 211.50 0.00

Incremental Capital Costs ($) 3,453

Annualized Capital ($/yr) 490

Incremental Annual Expenses ($/yr) 260

OEL Monitoring 
OEL Monitoring Cost Estimates

Type of Component

Model 1

OEL

Annual monitoring

Administrative and ReportsPlanning and TrainingTOTALS

Type of Component

Model 2

OEL

Annual monitoring

Administrative and ReportsPlanning and TrainingTOTALS

Percent 

Repaired 

OnLine

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak 

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

Offline Leak 

Repair Cost 

($/yr)

Monitoring 

to Verify 

Repair ($)

Annual 

Admin. 

Cost 

($/yr)

Annual 

Misc. 

Charges 

($/yr)

0.00

75 0.17 66.24 1.23 25 4.00 66.24 9.84 0.22

0.00

1.23 9.84 0.22 0.00 0.00

Percent 

Repaired 

OnLine

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak 

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

Offline Leak 

Repair Cost 

($/yr)

Monitoring 

to Verify 

Repair ($)

Annual 

Admin. 

Cost 

($/yr)

Annual 

Misc. 

Charges 

($/yr)

0.00

75 0.17 66.24 5.26 25 4.00 66.24 42.03 0.95

0.00

5.26 42.03 0.95 0.00 0.00

OEL Monitoring 
OEL Monitoring Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Le

Frequen

(%) 

Model 3

OEL 140.92 0.00 5.00 0.00

Annual monitoring 424 23.80 10383.28 1 1.50 636.00 0.90 

hr/activity $/hr

Administrative and Reports 0 92.72

Planning and Training 0 92.72 0.00

TOTALS 10383.28 0.00 636.00 0.00

Incremental Capital Costs ($) 10,383

Annualized Capital ($/yr) 1,474

Incremental Annual Expenses ($/yr) 781

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Le

Frequen

(%) 

Model 4

OEL 140.92 0.00 5.00 0.00

Annual monitoring 39 23.80 996.58 1 1.50 58.50 2.30 

hr/activity $/hr

Administrative and Reports 0 92.72 0.00Planning and Training 0 92.72 0.00

TOTALS 996.58 0.00 58.50 0.00

Incremental Capital Costs ($) 997

Annualized Capital ($/yr) 142

Incremental Annual Expenses ($/yr) 93

OEL Monitoring 
OEL Monitoring Cost Estimates

Type of Component

Model 3

OEL

Annual monitoring

Administrative and ReportsPlanning and TrainingTOTALS

Type of Component

Model 4

OEL

Annual monitoring

Administrative and ReportsPlanning and TrainingTOTALS

Percent 

Repaired 

OnLine

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak 

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

Offline Leak 

Repair Cost 

($/yr)

Monitoring 

to Verify 

Repair ($)

Annual 

Admin. 

Cost 

($/yr)

Annual 

Misc. 

Charges 

($/yr)

0.00

75 0.17 66.24 15.83 25 4.00 66.24 126.39 2.86

0.00

15.83 126.39 2.86 0.00 0.00

Percent 

Repaired 

OnLine

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak 

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

Offline Leak 

Repair Cost 

($/yr)

Monitoring 

to Verify 

Repair ($)

Annual 

Admin. 

Cost 

($/yr)

Annual 

Misc. 

Charges 

($/yr)

0.00

75 0.17 66.24 3.72 25 4.00 66.24 29.71 0.67

0.00

3.72 29.71 0.67 0.00 0.00

OEL Monitoring 
OEL Monitoring Cost Estimates

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Le

Frequen

(%) 

Model 5

OEL 140.92 0.00 5.00 0.00

238 23.80 6081.70 1 1.50 357.00 2.30 

hr/activity $/hr

Administrative and Reports 0 92.72 0.00

Planning and Training 0 92.72 0.00

TOTALS 6081.70 0.00 357.00 0.00

Incremental Capital Costs ($) 6,082

Annualized Capital ($/yr) 864

Incremental Annual Expenses ($/yr) 565

Type of Component Number of Components Initial Monitoring Fee or Unit Cost ($/comp) Initial LDAR Costs ($) (Capital) Initial LDAR Admin. Costs Frequency of Monitoring (times/yr) Subsequent Monitoring Fee ($/comp) or Charge (%) Annual Monitoring Costs ($/yr) Annual Maintenance Costs ($/yr) Initial Le

Frequen

(%) 

Model 6

OEL 140.92 0.00 5.00 0.00

902 23.80 23049.15 1 1.50 1353.00 2.30 

hr/activity $/hr

Administrative and Reports 0 92.72 0.00Planning and Training 0 92.72 0.00

TOTALS 23049.15 0.00 1353.00 0.00

Incremental Capital Costs ($) 23,049

Annualized Capital ($/yr) 3,273

Incremental Annual Expenses ($/yr) 2,142

OEL Monitoring 
OEL Monitoring Cost Estimates

Type of Component

Model 5

OELAdministrative and ReportsPlanning and TrainingTOTALS

Type of Component

Model 6

OELAdministrative and ReportsPlanning and TrainingTOTALS

Percent 

Repaired 

OnLine

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak 

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

Offline Leak 

Repair Cost 

($/yr)

Monitoring 

to Verify 

Repair ($)

Annual 

Admin. 

Cost 

($/yr)

Annual 

Misc. 

Charges 

($/yr)

0.00

75 0.17 66.24 22.71 25 4.00 66.24 181.30 4.11

0.00

22.71 181.30 4.11 0.00 0.00

Percent 

Repaired 

OnLine

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

OnLine Leak 

Repair Cost 

($/yr)

Percent 

Requiring 

Further 

Repair

Repair 

Time 

(hours)

Labor 

Charge 

($/hr)

Annual 

Offline Leak 

Repair Cost 

($/yr)

Monitoring 

to Verify 

Repair ($)

Annual 

Admin. 

Cost 

($/yr)

Annual 

Misc. 

Charges 

($/yr)

0.00

75 0.17 66.24 86.06 25 4.00 66.24 687.11 15.56

0.00

86.06 687.11 15.56 0.00 0.00

OEL Monitoring 
Attachment 5: 

BAAQMD Equipment Leak Memo 
Bay Area Air Quality Management District 

939 Ellis Street 

San Francisco, CA 94109 

Proposed Amendments 

Regulation 8 Rule 18: Equipment Leaks 

Control Measure SS-16 

Draft Staff Report

December 2003 

Prepared by: 

Victor Douglas 

Compliance and Enforcement Division 

Air Quality Specialist II 

Reviewed by: 

Wayne Kino 

Compliance and Enforcement Division 

Supervising Air Quality Specialist 

Jim Karas, P.E. 

Compliance and Enforcement Division 

Engineering Manager 

Kelly Wee 

Compliance and Enforcement Division 

Director 
TABLE OF CONTENTS 

EXECUTIVE SUMMARY ........................................................................................................1 

BACKGROUND ........................................................................................................................2 

PROPOSED RULE AMENDMENTS........................................................................................7 

EMISSION INVENTORY AND EMISSION REDUCTIONS..................................................9 

OTHER AREAS FOR POTENTIAL EMISSION REDUCTIONS .........................................11 

ECONOMIC IMPACTS...........................................................................................................13 

OTHER IMPACTS...................................................................................................................16 

CONCLUSIONS.......................................................................................................................18 
1 

EXECUTIVE SUMMARY 

Regulation 8, Rule 18 requires refineries to develop and implement a Leak Detection and 

Repair (LDAR) program to control fugitive emissions from valves, pumps, compressors, 

pressure relief valves, flanges, connectors, piping, and other equipment components. The 

rule, which includes the most stringent leak standards in California, also applies to 

chemical plants, bulk plants and bulk terminals. 

The proposed amendments to Regulation 8, Rule 8 ensure that best available control 

technologies are used for valves. The proposed amendments would: 

• Reduce the number of valves allowed on a non-repairable list; 

• Limit the number of valves on the non-repairable list with leaks of 10,000 parts 

per million (ppm) or more and ensure that emissions from each of these valves is 

less than 15 pounds per day; and 

• Allow connections to be placed on a non-repairable list at a ratio of one 

connection per two valves. 

The proposed amendments are intended to implement Control Measure SS-16 from the 

Bay Area 2001 Ozone Attainment Plan. That measure called for amendments to 

Regulation 8, Rule 18 that would require that replacement valves meet Best Available 

Control Technology requirements or that they be ìleaklessî valves. 

To implement the control measure, staff conducted numerous site visits to the Bay Area 

refineries and reviewed specific valve technologies to determine short-term and longterm emission performance. Staff found that no single valve type offered superior 

performance for the wide range of valve sizes and operating conditions encountered in a 

refinery, and that specifying valves for the many different situations encountered would 

be a complex undertaking with no clear benefits beyond those that come from the current 

rule. 

Staff determined that the existing valve leak standard of 100 ppm provides the best 

means to ensure that refineries use the best technology available for valve replacements. 

The 100 ppm standard is the most stringent in California (the South Coast AQMD leak 

standard for valves is 500 ppm) and is set at a level just above typical background 

concentrations. The amendments therefore implement the control measure by limiting 

the number of valves allowed on the non-repairable list, thereby ensuring the broadest 

possible application of the 100 ppm standard. 

During the rule development process for the amendments, refineries requested flexibility 

for connections that are very difficult to repair. Currently, connections must be repaired 

at any cost irrespective of emissions. To address this concern without increasing 

emissions, the proposed amendments would allow connections leaking below 10,000 

ppm to be placed on the non-repairable list at a ratio of one connection per two valves. 

The total number of valves and connections allowed on the list would continue to be 

determined strictly by the total number of valves in use at the refinery as documented 

annually. 
2 

These amendments will reduce emissions of organic and other pollutants, including toxic 

compounds. Staff has identified an emission reduction of 0.2 ton per day of precursor 

organic compounds. The expected total cost for all five Bay Area refineries to implement 

the proposed amendments is $23,500 to $118,000 per year. The cost effectiveness is 

approximately $320 to $1600 per ton of precursor organic compound emissions reduced. 

An analysis of the socioeconomic impacts of the proposal was prepared by Applied 

Development Economics of Berkeley, California. The analysis concludes that the 

economic and employment impacts to the Bay Area from the proposal would not be 

significant. 

A California Environmental Quality Act (CEQA) analysis for the proposed amendments 

has been prepared by Environmental Audit, Inc. of Placentia, California, concluding that 

the proposed amendments would not have any significant adverse environmental impacts. 

A Negative Declaration has been prepared for the proposed amendments pursuant to 

Public Resources Code ß 21080(c) and CEQA Guidelines 15070 et seq. and is being 

circulated for public review. 

The proposed amendments were developed through a workgroup that included District 

and ARB staff and representatives from environmental groups, the affected refineries, 

and the Western States Petroleum Association. The workgroup met six times in various 

locations. In addition, the proposal was discussed at a public workshop on October 28, 

2003 in Crockett. 

BACKGROUND 

There are five petroleum refineries within the jurisdiction of the District with 

approximately 233,000 total valves. The population of connections is estimated to be 

five times greater. The rule also applies to chemical plants, bulk plants and bulk 

terminals that have more than 100 valves or more than 10 pumps and compressors. The 

proposed amendments are not expected to significantly impact these smaller facilities. 

Regulatory History 

Rule 8-18 was first adopted in 1980 and was amended in 1992, with minor changes in 

1998 and 2002. Rule amendments adopted in 1992 significantly lowered the allowable 

leak concentration limits to the lowest in the country and required more effective 

inspection and repair programs in order to reduce emissions and promote selfcompliance. The 1992 amendments have reduced emissions by an estimated 1.2 tons per 

day. 

Rule 8-18 was last amended in November 2002 to address minor deficiencies identified 

by US EPA in their limited approval/disapproval of the rule. The U.S. Environmental 

Protection Agency (US EPA) fully approved the current rule in June 2003. 

Rule Development Process 

During the process to develop this proposed amendment to Rule 8-18, staff has worked 

extensively with the affected industry, interested public, and other air pollution control 
3 

agencies, such as the California Air Resources Board (CARB), US EPA and other air 

pollution control districts. 

Site Visits

Staff conducted numerous site visits to the Bay Area refineries to accompany both 

facility and district inspectors during Rule 8-18 inspections and learn how refinery staff 

carry out their leak detection and repair programs. These tours and the time spent in 

communication with both the inspectors and the representatives of the refineries were 

invaluable to the development of a balanced understanding of operations and 

technologies associated with the implementation of Rule 8-18. 

Literature Review and Information Requests 

Staff reviewed various sources of information regarding fugitive emissions, including 

bellow sealed valves, hermetically-sealed valves, fugitive emission rules of other 

California air districts, and reports provided by the refineries regarding their nonrepairable lists and leak detection and repair programs. 

Workgroup Meetings

During this rule development process, six workgroup meetings were held in various 

locations in the District. These workgroup meetings provided a forum in which technical 

and regulatory issues concerning this rule could be discussed in a effort to ensure that all 

participants had ample opportunity to voice their concerns and present comments and 

related information. In attendance at these meetings were industry representatives, 

environmentalists, CARB staff members, and district staff. 

Workshops

Staff hosted one workshop on October 28, 2003 in Crockett, to discuss draft amendments 

to the rule in a public forum. In attendance at the meeting were industry representatives, 

members of the public, environmentalist, and CARB staff members. 

Current Rule Requirements 

Each of the five refineries within the District has a leak detection and repair (LDAR) 

program. These programs function to ensure that all components are inspected regularly 

and, if a leak is found, the equipment is repaired, replaced, or placed on a list to be 

repaired. Under the current rule, there are four options under which a facility may 

comply with the rule: 

Option 1 – Leak Concentration Standard: This option allows the facility to 

inspect affected equipment for leaks; 100 ppm for valves and connections, and 

500 ppm for pumps, compressors and pressure relief devices. All equipment with 

leaks discovered by the facility must be minimized within 24 hours and repaired 

within seven days. All leaks discovered by the District must be repaired within 

24 hours. All equipment not subject to an LDAR program discovered to be 

leaking by District staff is a violation of this rule. 
4 

A fraction of the equipment that cannot be repaired may be placed on a nonrepairable list for up to five years or the next scheduled turnaround for that plant, 

whichever date comes first. The maximum fraction of components on the 

facility-wide turnaround list cannot exceed 0.5 percent for valves and 1.0 percent 

for pumps, compressors and pressure relief devices. Currently, connections are 

not allowed to be placed on a turnaround list. 

Option 2 – Mass Emissions Standard: This option allows the facility to use the 

concentration standards as trigger levels and measure any non-repairable 

component for mass emissions. Using the above Option 1 leak concentration 

standards as trigger levels, any non-repairable component can be measured for 

mass emissions. If the mass emission rate is greater than 15 pounds per day, the 

component must be repaired. If the mass emission rate is less than 0.1 or 0.2 

pounds per day, no further action is required. The number of components leaking 

between 0.1 or 0.2 and 15 pounds per day cannot exceed a small percentage of the 

total number of components at the facility. 

Option 3 – Reduced Inspection Frequency: Using the above Option 1 leak 

concentration standards as trigger levels, facilities can increase the interval 

between inspections for components that do not leak. This option reduces the 

cost of inspection and maintenance plans. The inspection frequency for 

equipment, except pumps and compressors, may be changed from quarterly to 

annually provided the equipment has been operated leak free for five consecutive 

quarters and records are submitted and approved by the District. If a leak is 

discovered, the frequency reverts back to quarterly inspections for that 

component. 

Option 4 – District Approved Inspection and Maintenance Plan: The final 

option allows facilities to implement an alternate program to reduce emissions 

from leaks. This option requires a written plan approved by the District and EPA. 

To date, no Bay Area refinery has elected to use this option. 

Other Air District Rules 

Several other air pollution control districts in California have rules that address fugitive 

emissions from refineries and chemical plants. These districts include the South Coast 

Air Quality Management District (Rule 1173), the San Joaquin Valley Unified Air 

Pollution Control District (4451 & 4452), and Ventura County Air Pollution Control 

District (Rule 74.7). In addition to these districtsí rules, the federal New Source 

Performance Standards affect emissions from equipment leaks. The table in Appendix A 

provides a simplified comparison of the major provisions of these rules with the 

provisions of the Districtís current rule. 

Overview of Current Leak Detection and Repair (LDAR) Programs 

Each LDAR program functions to ensure that all components are: 

• Identified; 
5 

• Labeled (except connections); 

• Inventoried; 

• Inspected for leaks; and 

• If found leaking, tagged, repaired, replaced, or placed on a non-repairable list. 

Identification: Each piece of equipment is uniquely identified in association with the 

plant at which it is located, the type of equipment, and a unique identification number. 

Labels: In addition, this identity is also placed on a label that is attached to each 

component or group of components. Labels contain varying degrees of information, but 

most will at least include the identification number. 

Inventory: Each piece of equipment is inventoried in a database that contains 

information on the equipment such as type, location, installation date, dates of inspection, 

leak concentration, and repair history. 

Inspections: Each refinery employs an inspection team that consists of either in-house 

employees or contractors.1 The inspection team calibrates their VOC detector, which is 

typically either a flame or photo ionization detector, and proceeds with the inspection. A 

member of the inspection team carries a monitoring device that reads and records 

information from a barcode or identifier attached to the component being inspected. If a 

leak is detected, a team member or another facility employee will attempt to minimize the 

leak as required by the rule. If the leak cannot be minimized, a team member will 

identify the component with a waterproof, indelible tag, upon which information 

regarding the leak is recorded and the component is identified for repair or replacement. 

Once the inspection is completed, the recorded information is uploaded into an LDAR 

data base. 

Technology Review 

The District reviewed equipment that could represent Best Available Control Technology 

for valves. 

Bellows Seal Valves

Bellows seal valves normally operate in a leak free manner because the moving 

components of the valve are hermetically sealed from the ambient air. Bellows seal 

valves function by replacing the packing and sliding or rotating seals with bellows 

(accordion-like tubing). This replacement eliminates the opportunity for emissions from 

the sliding of rotating seals and packing. However, failure of the bellows can result in 

significant emissions. 

 

1

 Three of the five Bay Area refineries employ independent contractors to conduct leak detection 

and repair inspections, and the remaining refineries utilize in-house employees. All refineries 

have a separate group dedicated to the task of leak detection and repair. 
6 

The bellows are sealed in two different ways. In one approach, the bellows are welded to 

the valve stem at the top and the valve body at the bottom. The process fluid is contained 

inside the bellows. In the approach, the bellows are welded to the valve stem at the 

bottom and the body on the top. The process fluid is contained in the annular region 

between the valve bonnet and bellows. 

Bellows valves are available only in a relatively narrow size range and could be used as 

replacements in only a small subset of all refinery applications. 

Solenoid-Actuated Valves

Solenoid-actuated valves are a departure from the standard air- or motor-operated valve 

design typically used for process fluid storage and handling of hydrocarbons. These 

valves are solenoid-actuated. They do not use stem, packing, or bellows. Further, 

solenoid-actuated valves isolate all moving parts within the process pressure areas. 

Because the actuator of these valves is completely sealed from the atmosphere and is 

actuated via magnetism, the potential for emissions due to the failure of seals surrounding 

dynamically moving parts is eliminated. However, failure of the isolation, such as a 

crack in the valve body can result in significant emissions. And, as with bellows valves, 

solenoid-activated valves could only be used in a limited range of refinery applications. 

ìBACTî Standard of the Control Measure

After reviewing specific valve technologies to evaluate short-term and long-term 

emission performance, staff concluded that the petroleum refineries must use the best 

technology available for replacements to consistently achieve the stringent emission 

standards of the rule ñ the 100 ppm leak limit for valves and 0.5 percent of the total 

number of valve allowed on a non-repairable list. Consequently, the strict emission 

standard combined with the limit placed on the non-repairable list constitutes a ìbest 

available control technologyî standard. 

As long as the refineries consistently meet this standard, the regulation need not dictate 

which technologies should be used. Rather, refineries should be allowed to use their 

expertise to determine the technology best suited for the conditions of use that will ensure 

compliance with the requirements of the rule. This approach will allow the introduction 

of improved technology that may ìcross overî from other industrial application without 

requiring an exhaustive review process to maintain a BACT list. 
7 

PROPOSED RULE AMENDMENTS 

The proposed amendments: 

• Reduce the number of valves that are allowed on the non-repairable list; 

• Limit the number of valves leaking in excess of 10,000 ppm; 

• Require mass emission rate determinations for valves leaking in excess of 10,000 

ppm and control those with excess emissions; and 

• Allow connections with leaks that do not exceed 10,000 ppm to be placed on the 

non-repairable list at a ratio of one connection per two valves. 

The amendments are made possible by improvements in the ability of the refineries to 

locate and repair leaking components and improvements in valve technology, such as 

hermetically sealed valves and advancements in valve stem packing materials. These 

improvements, which are already being implemented in some areas, have led to emission 

reductions that have not yet been credited to this rule. By implementing the 

improvements across the board, additional emissions reductions will be achieved. 

Finally, the amendments will ensure that the components that are believed to be 

responsible for the greatest emissions are examined and if found to have excessive 

emissions, controlled. 

Reducing the Number of Components on the Non-Repairable List 

The non-repairable list was established to provide a mechanism to address essential 

components. Essential components are those pieces of equipment that cannot be repaired 

or replaced unless the process unit is shutdown and the component is isolated. This 

activity would likely create more emissions than the actual fugitive leaks. The rule 

allows a certain percentage of each type of equipment to be placed on the list. Table 1 

indicates the current allowable fractions of each component on the non-repairable list. 

Table 1 

Current Allowable Limits for Components Awaiting Repair or Replacement 

Equipment Fraction of Non-repairable 

Equipment Allowed 

Maximum Duration 

Valves 0.5% 5 years or next turnaround 

Pressure Relief Devices 1 % 5 years or next turnaround 

Pumps/Compressors 1 % 5 years or next turnaround 

Data collected from the refineries indicate that the current LDAR programs implemented 

at some refineries result in a much lower fraction of leaking equipment being placed on a 

non-repairable list than the fraction allowable by Rule 8-18. This suggests that it is 

possible to reduce the percentage of equipment allowed on the non-repairable list or 

address non-repairable equipment in a different manner. 
8 

Staff proposes to modify the allowable fractions according to the table below. 

Table 2 

Proposed Revisions to the Allowable Limits for Components Awaiting Repair or 

Replacement 

Equipment Number of Non-repairable 

Pieces of Equipment Allowed 

Maximum Duration 

Valves (including valves with 

major leaks) and connectors 

0.3% of total number of valves 5 years or next turnaround 

Valves with major leaks 0.025% of the total number of 

valves 

5 years or next turnaround 

Pressure Relief Devices 1.0% total number of PRVs 5 years or next turnaround 

Pumps/Compressors 1.0% total number of pumps and 

compressors 

5 years or next turnaround 

In this proposal, the fraction of valves (including valves with major leaks) allowed on the 

non-repairable list would be reduced from 0.5 percent to 0.3 percent. 

Concentration Limit for Non-repairable Components 

The proposal will also limit the number of valves leaking in excess of 10,000 ppm to 

0.025 percent of the total number of valves in operation at the facility; these valves would 

be included in the number that make up the 0.3 percent allowed for all valves. Before a 

valve with a major leak (one that leaks in excess of 10,000 ppm) can be placed on the 

non-repairable list, its mass emission rate must be determined and found to be below 15 

pounds per day. In addition, the mass emission rate must be determined at least once per 

year to ensure that the leak does not exceed the 15-pound limit. This provision is 

intended to prevent a component from leaking an indefinite amount of mass emissions for 

up to five years. 

The amendments will require refineries to take action on valves that are found leaking in 

excess of 10,000 ppm (50 to 100 times the allowable limits). If a component is found to 

leak in excess of 10,000 ppm, the operator must do one of the following: (1) minimize 

the leak below 10,000 ppm within 24 hours and repair the component within seven days, 

or (2) measure the mass emission rate of the leak and place the component on the nonrepairable list only if the mass emission rate is less than 15 pounds per day. If the valve 

leaks in excess of the allowable mass emission rate, then the operator must either repair 

or replace that component or capture and vent those emissions to a control device. 

Additionally, the refiner must notify the District of each mass emission rate 

determination at least 96 hour prior to the determination. This will allow the District to 

review the process of the emission rate determination and also allow concurrent testing of 

the leaking component for methodology evaluation. 

Connections on the Non-repairable List 

The refineries have long asserted that regulatory flexibility is needed for connections that 

pose difficulty in repair. To address this concern, staff proposes allowing connections 
9 

with leaks less than 10,000 ppm to be placed on the non-repairable list in a very limited 

fashion that would not result in a relaxation of the rule. To ensure that any emissions 

associated with a connection being placed on the non-repairable list are offset, the 

amendments would require that each connection placed on the list counts as two pieces of 

equipment. The number of components allowed on the list is strictly limited to the 

number of valves located at the refinery multiplied by the allowed fraction. For example, 

if a refinery has 50,000 valves and the fraction of valves allowed on the non-repairable 

list is 0.3 percent, then the number of valves allowed on the list could not exceed 150. 

Additionally, for each connection allowed on the list, two spaces of the 150 allotted for 

valves would no longer be available. 

EMISSION INVENTORY AND EMISSION 

REDUCTIONS 

Emission Inventory 

Emission inventory data collected over the past several years indicate that fugitive 

emissions have been constantly decreasing. Table 3 details these emissions and 

reductions. There was a significant emissions reduction between the 2001 inventory and 

the current modified 2002 inventory. This emission reduction is due mostly to the 

adoption of new correlations factors from the EPA that are published in the ARBís 

"California Implementation Guidelines for Estimating Mass Emissions of Fugitive 

Hydrocarbon Leaks at Petroleum Facilities.î However, notwithstanding the change in 

correlation factors, there has been a general downward trend to fugitive emissions over 

the last several years. This trend is largely due to improvement in the leak detection and 

repair programs over time. 
10 

TABLE 3 

Estimated Emissions Inventories for All Fugitives Components1

SIP 

(Modified 

1999 

Inventory)1

2000 

Inventory2

2001 

Inventory2

Current 

(Modified 

2002 

Inventory) 2,3,4

Refinery (organic emissions - pounds/day) 

Chevron 7 ,821 7,821 7,773 2,294 

Shell 352 352 351 381 

ConocoPhillips 1,543 1,543 1,473 1,474 

Valero Asphalt 35 35 35 22 

Valero 1,969 530 257 332 

Tesoro 1,690 1,690 1,688 128 

Total (tons/day) 6.71 5.99 5.79 2.32 

1. These are the estimated fugitive emissions from all components affected by Rule 8-18, including 

valves, pumps, compressors, pressure relief devices, and connections. 

2. The annual emission inventories are based on equipment counts provided to the District by each 

refinery. 

3. The values in this column reflect the use of modified correlation factors for each component 

category, as published in the ARBís "California Implementation Guidelines for Estimating Mass 

Emissions of Fugitive Hydrocarbon Leaks at Petroleum Facilities.î 

4. These values are currently under review and may not reflect the final emission inventory for 2002. 

Emission Reductions 

The emission reductions for the proposed amendments are presented in Table 4. These 

emission reductions are based on the assumption that all leaking components other than 

connections will be discovered at the five Bay Area refineries. 

TABLE 4 

Emission Reduction Estimates1. 

Rule 8-18 Emissions2

(lbs/day (TPD)) 

Amended Rule 8-18 

Emissions3 

(lbs/day (TPD)) 

Emission Reductions 

(lbs/day (TPD)) 

Valves 706 (0.35) 303 (0.15) 403 (0.20) 

1. Assumes a total of 233,000 valves at all five Bay Area refineries (see Table 5). 

2. Assumes that the total number of valves leaking is 0.50 percent of all valves. 

3. Assumes that the total number of valves leaking is 0.30 percent of all valves and that fraction 

leaking above 10,000 ppm is 0.0025 percent. 

Staff estimates that there are approximately 233,000 total valves at the five Bay Area 

refineries. Table 5 presents the inventory for valves, pump and compressors, pressure 

relief devices, and connections. 
11 

TABLE 5 

Estimated Inventories1

 of Various Components Subject to Rule 8-18 

at the Bay Area Refineries

Refinery Components 

Valves Pumps and 

Compressors 

Connections 

Chevron 71,000 800 355,000 

ConocoPhillips 27,000 250 134,000 

Shell 52,000 360 217,000 

Tesoro 33,000 1500 156,000 

Valero 50,000 300 250,000 

TOTALS 233,000 2110 1,112,000 

1. These values are based on quarterly reports and direct quotes from industry representatives. 

OTHER AREAS FOR POTENTIAL 

EMISSION REDUCTIONS 

During this rule development process, staff examined other strategies that have some 

potential for achieving emission reductions. These strategies are not included in this 

rulemaking because they require further study. Each potential strategy examined by staff 

is discussed briefly below. 

Maximum Leak Limit for All Components 

District staff examined whether a maximum leak standard should be established and 

whether it would reduce emissions. The BAAQMD rule and many other air district 

fugitive rules allows repair to be deferred for a small number of valves that exceed leak 

limits. These allowances are intended to avoid the potentially significant emissions that 

could come from shutting down a unit to make repairs. On the other hand, emissions 

from components with significant leaks awaiting repair could be potentially significant. 

There is limited data available to determine whether a focus on leaks with concentrations 

over an established maximum is warranted. For individual components, the available 

data suggests that the correlation between mass emissions and concentration is poor. It 

may be more appropriate to focus on a mass emission approach. The proposed 

amendments will require the facilities to measure mass emissions on leaking valves over 

10,000 ppm leak concentrations. This data will help determine if a mass emission or a 

maximum concentration is warranted. Additionally, an initial assessment of data 

reported by the Bay Area refineries indicate that less than one in 5000 valves leak in 

excess of 10,000 ppm, which is less than ten at any one refinery. Only a very small 

fraction of these components are expected to have mass emissions rates in excess of the 

preset limits. Emission reductions may therefore be quite limited and need further 

examination. 
12 

Violations for Leaks Detected During District Inspections 

The current rule allows refineries 24 hours to repair leaks found by District inspectors 

and seven days to repair leaks discovered by refinery. An alternative would be to treat as 

a violation the detection of leaks by District inspectors in a specified percentage of the 

components inspected. The South Coast fugitives rule uses such an approach. This 

might encourage more thorough inspections by refinery personnel. On the other hand, 

refiners expressed concerns that even with good LDAR programs, it is possible to find 

leaks, particularly if a District inspector chooses to inspect an area that is due for 

inspection but has not yet inspected under the refinery LDAR program. Refiners felt that 

this might be perceived as unfair and might not improve the refinery program. 

Accelerated Replacement of Equipment with Frequent Leaks/Repairs 

Some specific components appear to be more prone to leaks and to require more repair. 

The rule could require a component to be replaced if the number of leaks within a 

specified time period exceeds a threshold specified in the rule. The South Coast and 

Ventura rules use this approach. On the other hand, it may be true that more frequent 

repair is required for certain demanding types of service, and any replacement component 

will have the same failure rate. 

Replacement of Inaccessible Equipment with Superior Technologies 

Replacement of inaccessible equipment with superior technologies could reduce the 

potential for emissions. Regulation 8, rule 18 requires less frequent inspection for these 

components. This reduced inspection frequency results in a longer average time period 

before a leak is detected and repaired. It is unclear whether superior technologies can be 

readily identified. 

Control Emissions from Heat Exchangers 

Heat exchangers are potential sources of VOC emissions through leakage of VOCs into 

cooling liquid and subsequent emission at cooling towers. A first step would be to 

measure VOC emissions at cooling towers over an entire cycle to determine whether 

emissions are significant. To determine if a leak exists in a heat exchanger, the VOC 

concentrations of cooling water at the inlet and outlet to the heat exchanger could be 

compared. A higher VOC concentration at the outlet would indicate a leak. This work 

would have to be done to determine whether there is any potential for emission 

reductions. 

Quantification of Mass Emissions and Emission Caps 

If mass emissions for leaking components can be reliably determined, a cap could be 

placed on total emissions from equipment placed on the non-repairable equipment list. 

Leaking equipment could be added to the list, but only if the total fugitive emission cap is 

not exceeded. If adding a leaking component would cause the cap to be exceed, 

emissions from equipment already on the non-repairable list would have to be reduced. 
13 

This approach would provide an incentive to replace high-emitting equipment on the list 

as soon as possible and would provide a facility flexibility to make the most cost 

effective choices that results in the least emission consequence. On the other hand, a 

mass emission cap could be overly complex and difficult to administer. 

Increase Inspection Frequencies 

Increasing the frequency of inspections would reduce the time that a leaking component 

goes undetected, and could decrease emissions. To implement increased inspection 

frequencies, additional staffing would be required. Staff would have to further assess 

potential emission reduction benefits from increased inspection frequencies. 

Smart LDAR 

The U.S. EPA and API have jointly worked on a project called ìSmart LDARî through 

the U.S. EPAís Common Sense Initiative for the Petroleum Refining Sector. Research 

indicates that a small subset of all leaking components is responsible for most of the 

emissions. Rather than focus efforts on controlling minor leaks, the Smart LDAR project 

is examining the use of remote sensing methods that would allow quick identification and 

repair of leaks causing large emissions. It is unclear when those methods will become 

available for routine use in refinery LDAR programs. 

ECONOMIC IMPACTS 

Costs 

The costs associated with the proposed amendment are primarily the costs of determining 

the mass emission rates of valves leaking in excess of 10,000 ppm and the cost of 

controlling component with emissions above the 15-pound limit. There are two methods 

that were identified as reliable methods of determining mass emissions: high volume 

collection system (HCVS) and the US EPA vacuum method. These methods are 

described and compared in Appendix B. 

Table 6 compares the cost of each of these methods. The cost values in Table 5 have 

been inflated from 1995 values using inflation factor of 1.2 obtained from the US 

Department of Labor, Bureau of Statistics (www.bls.gov). 

TABLE 6 

Cost Estimates for Mass Emission Rate Determinations 

HCVS Vacuum Method 

Total time required for ONE sample1 4 hours Two days 

Labor Cost per sample ($450/day) $225 $900 

Lab Cost per sample $0 $400 

TOTAL COST per sample $225 $1300 

1. This represents the time needed to sample one valve and not a population of valves. This value is 

based on the assumption that valves leaking in access of 10,000 ppm would be found individually and, 

therefore addressed individually. Further, it is expected to take at least a half day to prepare the 
14 

instrumentation (calibration and flow rate determination) for the high volume sampler and two days to 

enclose the leaking component and prepare for sampling (calibration and flow rate determination). 

Based on current inspection data, it was estimated that a total of 60 valves may need mass 

measurements. Using the cost estimates from Table 6, the cost of sampling 60 valves 

annually was estimated between $13,500 and $78,000. The cost to capture, vent and 

control emissions from a valve with excess emissions can range from $5,000 to $20,0002 

each depending on the valve size, location (accessible or inaccessible, proximity to a vent 

for flare or fire box, spatial proximity to other components, etc.). It was estimated that 

2.5 percent of valves leaking in excess of 10,000 ppm will have emissions of 15 pounds 

per day or greater,3 or 2.5 percent. That is approximately two valves District-wide that 

could potentially be required to be controlled. This would result in a potential cost of 

$10,000 to $20,000 to reduce 5.5 tons of emissions or a cost effectiveness that range 

between $1,800 and $3,600 per ton reduced. The annual costs associated with these 

proposed amendments are presented in Table 7. 

TABLE 7 

Costs of the Proposal

Requirement Annual Costs 

Mass Emission Rate Determinations $13,500 -$78,600 

Control of Valves with Excessive Leaks $10,000 to $40,000 

TOTAL COSTS $23,500 to $118,000 

The emission reduction that will result from this proposal is estimated to be 

approximately 74 tons per year. This results in a potential cost effectiveness range of 

$320 to $1,600 per ton of precursor organic compounds District-wide. 

Incremental Costs 

Under Heath and Safety Code section 40920.6, the District is required to perform an 

incremental analysis when adopting a Best Available Retrofit Control Technology 

(BARCT) rule or feasible measure required by the California Clean Air Act. To perform 

this analysis, the District must (1) identify one or more control options achieving the 

emission reduction objectives for the proposed rule, (2) determine the cost effectiveness 

for each option, and (3) calculate the incremental cost effectiveness of each option. To 

determine incremental costs, the District must ìcalculate the difference in dollar cost 

divided by the difference in the emission reduction potentials between each progressively 

 

2

 This cost range is based on personal conversations between District staff and staff members of 

the California Air Resources Board and refinery personnel. 

3

 Emissions estimates provided by WSPA. 
15 

more stringent potential control option as compared to the next less expensive control 

option.î 

This regulatory development process was initiated to examine the feasibility of drafting 

amendments to Regulation 8, Rule 18 that would implement Control Measure SS-16 

from the Bay Area 2001 Ozone Attainment Plan. To implement Control Measure SS-16, 

staff evaluated requiring replacement valves that meet BACT requirements or that they 

be ìleaklessî valves. Staff has concluded the performance standard in the current rule 

combined with the limit placed on the non-repairable list constitutes the ìbest available 

control technologyî and that no additional provisions are necessary or appropriate to 

ensure that refineries meet that standard of the rule. 

In addition, during this rule development process, staff examined various alternatives to 

achieve the emissions reduction required under the 2001 Ozone plan. The first option 

considered was to require all valves placed on the non-repair list to be repaired or 

replaced with hermetically-sealed valves. This option would be extremely expensive. 

Bellow seal valves cost approximately $12,000, which is about $7000 more than a typical 

valve. Two tenths of a percent of the total number of valves (233,000), could be placed 

on the non-repairable list for up to five years (46,600 valves). It is expected that about 

half of these valves would need to be replaced with bellow seal valves or 23,300 valves. 

Because the valves can remain on the list up to five year, 20 percent of the valves would 

be cycled out each year (4660 valves). This type of an approach would result in an 

annual cost of $32 million. The second option considered is outlined in this proposal. A 

comparison of the alternative and this proposal is summarized in Table 8. 
16 

TABLE 8 

Incremental Cost Analysis 

Annual Emissions 

Reductions 

Annual Costs Cost Effectiveness 

Replace Valves with 

Hermetically-Sealed 

Valves 

Negligible1

 $32 million Indeterminate 

The Proposal 74 tons $23,500 to $118,000 $320 to $1,600 per ton 

1. Specific emission reductions cannot be credited to the replacement of valves 

with bellow seal valves because all valves must meet the 100 ppm standard and 

limits on the non-repairable list. 

Socioeconomic Impacts 

Section 40728.5 of the Health and Safety Code requires an air district to assess the 

socioeconomic impacts of the adoption, amendment, or repeal of a rule if the rule is one 

that ìwill significantly affect air quality or emissions limitations.î Applied Economic 

Development of Berkeley, California, has prepared the required cost analysis. (Appendix 

D) 

OTHER IMPACTS 

Environmental Impacts 

The Districtís environmental consultant, Environmental Audit, Inc., prepared an initial 

study for the proposed rule amendments to determine whether rule adoption would result 

in any significant environmental impacts. In general, the initial study concludes that the 

proposed amendments would result in environmental benefits by reducing the number 

and magnitude of leaks for which repairs can be deferred under existing rule provisions. 

The complete environmental document is attached as Appendix C. A Negative 

Declaration for the proposed amendments has been prepared and is being circulated for 

comment. The comment period is from December 22, 2003 to January 12, 2004. 

Regulatory Impacts 

California Health and Safety Code section 40727.2 requires the District to identify 

existing federal air pollution control requirements for the equipment or source type 

affected by the proposed rule or regulation. The District must then note any differences 

between these existing requirements and the requirements imposed by the proposal. 

Regulation 8, Rule 18: Equipment Leaks applies to fugitive emissions from valves, 

pumps, compressors, pressure relief devices, connection and any other component that 

may have fugitive leaks. The proposal does not expand the applicability or the current 

rule. 
17 

Numerous federal requirements apply to fugitive emissions at the facilities subject to 

Regulation 8, Rule 18. New sources are subject to New Source Performance Standards 

found in 40 CFR Part 60, Subpart VV (Equipment Leaks of VOC in the Synthetic 

Organic Chemicals Industry) and Subpart GGG (Equipment Leaks of VOC in Petroleum 

Refineries). Other sources are subject to National Emission Standards for Hazardous Air 

Pollutants (NESHAPS) found in 40 CFR Part 61, Subpart V (National Emission 

Standards for Equipment Leaks (Fugitive Emission Sources)), and to 40 CFR Part 63, 

Subpart CC (National Emission Standards for Petroleum Refineries). A comparison 

between BAAQMD and federal requirements follows: 

BAAQMD Reg. 8, Rule 18 40 CFR60 VV, GGG, 40 CFR63 CC 

Applicability

Components at petroleum refineries, chemical 

plants, bulk plants and bulk terminals. 

Affected equipment in petroleum refineries, 

synthetic organic chemicals manufacturing 

facilities, onshore natural gas processing 

plants. 

Requirements

LDAR program for components in light 

liquid/gas/vapor. Quarterly inspections. 

Inaccessible components inspected annually. 

Pumps and valves inspected monthly. Valves 

in light liquid/gas/vapor service inspected 

monthly. After two monthly inspections 

without leaks, they may be inspected quarterly 

until a leak is detected. 

Leak threshold at 100 ppm for valves, 

connectors, 500 ppm for pumps, compressors 

and PRDs in gas/vapor/light liquid service. 

Leak threshold at 10,000 ppm for pumps and 

valves in heavy liquid service. 

Leaks detected by operator minimized within 

24 hours and repaired within 7 days. 

A percent of non repairable components may 

delay repair until unit turnaround. Leaks 

detected by BAAQMD repaired within 24 

hours. 

Pumps, valves, PRDs and connectors in light 

liquid/gas/vapor service leak threshold at 

10,000 ppm. Compressors required to have a 

seal system with barrier fluid. PRDs in 

gas/vapor service leak threshold at 500 ppm. 

 Leaks > 10K ppm 15 days repair maximum, 

first attempt at repair within 5 days. 

Recordkeeping and Reporting

Submit quarterly reports of non repairable 

components and their leak rates. 

Submit semiannual reports containing the 

number of components, by type, that were 

repaired and for which repair was delayed, 
18 

BAAQMD Reg. 8, Rule 18 40 CFR60 VV, GGG, 40 CFR63 CC 

and the reason for delay. 

Test Methods

U.S. EPA Method 21 for leak screening, 

ASTM Method D86 for VOC content of 

liquids. 

U.S. EPA Method 21 for leak screening, 

ASTM E-260, E-168, E-169 for the VOC 

content, ASTM Method D-2879 for the vapor 

pressure. 

Exemptions

Components handling liquids with an initial 

boiling point greater than 3020

 F. 

Components that present a safety hazard 

Components operating under negative 

pressure or enclosed systems and PRDs 

vented to vapor recovery or disposal system. 

Components handling fluids with less than 

10% by weight VOC. 

Pressure vacuum valves on storage tanks. Components operating under negative 

pressure, pumps with a closed vent system, 

PRDs vented to a control device. 

PRDs installed for thermal protection of 

liquid lines provided they are vented to a 

drain or back in the line 

Administrative requirements for equipment 

handling organic liquids with an initial boiling 

point greater than 3020

 F. 

District Staff Impacts 

Implementation of the proposal will have a negligible impact on the resources of the 

District. Staff will need to review reports regarding mass emission rate determinations 

and, occasionally, conduct site visit to witness of those determinations. 

CONCLUSIONS 

The proposed amendments to Regulation 8, Rule 18, Equipment Leaks will meet the 

commitment made during the adoption of the 2001 Ozone Attainment Plan for Control 

Measure SS-16. The proposal is intended set stringent standard and performance 

requirements that when implemented, will represent the best current industry practices 

and abilities and allow the District to account for any associated emission reduction. 

Pursuant to the Health and Safety Code section 40727, new regulations must meet 

necessity, authority, clarity, consistency, non-duplicity and reference. The proposed 

regulation is: 

• Necessary to protect public health by reducing volatile organic compounds that 

contribute to ozone formation and to carry out the commitment in control measure 
19 

SS-16 in the Bay Area 2001 Ozone Attainment Plan; and to protect public health 

by reducing exposures to toxic air contaminants. 

• Authorized by California Health and Safety Code section 40702. 

• Clear, in that the new regulation specifically delineates the affected industry, 

compliance options and administrative requirements for industry subject to this 

rule. 

• Consistent with other District rules, and not in conflict with state or federal law. 

• Non-duplicative of other statutes, rules or regulations. 

• The proposed regulation properly references the applicable District rules and test 

methods and does not reference other existing law. 

The proposal has met all legal noticing requirements and has been discussed with all 

interested parties. District staff recommends adoption of Regulation 8, Rule 18, 

Equipment Leaks. 

Appendix A 

Comparison of the Basic Provisions of the Fugitive 

Emissions Rules of Four California Air Districts 

Comparison of the Basic Provisions of the Fugitive 

Emissions Rules of Four California Air Districts 

BAAQMD 

Rule 8-18 

South Coast 

AQMD 

Rule 1173 

SJVUAPCD 

Rules 4451 & 

4452 

Ventura Co. 

APCD 

Rule 74.7 

Minimum Leak 

Limits 

ßß8-18-211, 

301!305 

ß1173 (d)(1) ß4451.3.9.1.1; 

ß4451.3.9.2; 

ß4452.3.6.1 

ßß74-7 

L.18!L.20, 

L.22 & L.23, 

Liquid 3 drops/min 3 drops/min 3 drops/min minor >3 

drops/min 

major = stream 

or mist 

Valves 100 ppm HL > 500; LL > 

50k/10k* 

10,000 ppm 

Connections 100 ppm HL > 500; LL > 

50k/10k* 

10,000 ppm 

Pumps/ Compressors 500 ppm HL > 500/100*; LL > 

50k/10k* 

10,000 ppm 

 minor >1,000 

1,000 > major >

10k 

PRDs/PRVs 500 ppm LL > 50k/200* 10,000 ppm major > 200 

ppm 

 L = leak (in ppm or 

drops/min) 

HL = heavy liquid 

leak 

LL = light 

liquid/gas/vapor leak 

*Limits for leaks 

found above leak 

thresholds (see 

Turnaround Lists) 

 

INSPECTION 

FREQUENCIES 

ßß8-18-

401.1!401.3 

ßß1173 (f)(1)(B) & 

(C) 

ß4451.5.2 & 

ß4452.5.1 

ß74-7 D.1 & 

D.2 

Valves Quarterly Quarterly Quarterly Monthly 

!Quarterly 

Connections Annually Quarterly Annually Monthly 

!Annually 

Pumps/ Compressors Quarterly Quarterly Quarterly Monthly 

!Quarterly 

PRDs/PRVs Annually Quarterly Quarterly Quarterly 

(≤110 days) 

Inaccessibles Annually Annually Annual or 

shutdowns 

NONREPAIRABLE 

LIST 

ßß8-18-306.2 & 

306.3 

 Leak Thresholds: 

ß1173(d)(1)Table 1 

ß4451.5.2 & 

ß4452.5.1.4 

Duration < 5 yrs. No time limit (∞) Next shutdown none 

Valves 0.5% 1% 0.5% 2% none 

Connections 0% 0% 0.5% 2% none 
BAAQMD 

Rule 8-18 

South Coast 

AQMD 

Rule 1173 

SJVUAPCD 

Rules 4451 & 

4452 

Ventura Co. 

APCD 

Rule 74.7 

Pumps/ Compressors 1% 5% 1% 2% 

Shutdown or one 

year 

none 

PRDs/PRVs 1% 5% 1% 2% 

REPAIR 

SCHEDULES 

ßß8-18-

301!305 

ß1173 (g)(1) Table 2 ß4451.5.3.2 & 

ß4452.5.1.4 

ß74-7 E Table 1 

Valves 24 hr (District)/ 

7 days 

(operator) 

m: 1 yr 

M: 15 days reduce 

< 10 d/min / 10k 

or vent to flare or 

control or show 

control is 

infeasible 

m: 14 days, M: 

5 days, 

S: 1 days 

Connections 24 hr (District)/ 

7 days 

(operator) 

m: 1 yr 

M: 15 days reduce 

< 10 d/min / 10k 

or vent to flare or 

control or show 

control is 

infeasible 

m: 14 days, M: 

5 days, 

S: 1 days 

Pumps/ Compressors 24 hr (District)/ 

7 days 

(operator) 

500 < LL < 10k: 7 

days 

100 < HL< 500: 7 

days 

3 drops/min & 100 < 

HL < 500: 7 days 

10k < L < 25k: 2 

days/ext 3 days 

L > 25k: 1 day 

HL > 500: 1 day/ext 3 

days 

LL > 3 drops/min: I 

day 

15 day 

> 15 day: replace, 

vent to control or 

repair at shutdown 

m: 14 days, M: 

5 days, 

S: 1 days 

PRDs/PRVs 7 days 

(District)/ 

17 days 

(operator) 

200 < L ≤ 25k: 2 days m: 1 yr 

M: 15 days reduce 

< 10 d/min / 10k 

or vent to flare or 

control or show 

control is 

infeasible 

m: 14 days, M: 

5 days, 

S: 1 days 

 L = leak (in ppm or 

drops) 

HL = heavy liquid 

leak 

LL = light 

liquid/gas/vapor leak 

ext = extended repair 

period 

Leak: m< 10 

drops/min or 

10,000 ppm 

M > 9 drops/min 

or 10,000 ppm. 

Leaks: m≤

10,000, 

10,000 <M ≤

25,000 

S >25,000
Appendix B 

Emissions Estimates 

EMISSION ESTIMATES FOR VALVES 

Valves 

200,000 valves at a Leak Rate 0.5 percent 

Screening Value 

(ppm) 

Numbers of 

Valves 

Leak Rate 

(lb/day) 

 

0 198,575 82 

0<S<100 425 1 

100<S<10,000 850 16 

>10,000 150 507 

Total 606 

Valves 

200,000 valves at a Leak Rate 0.3% with only 0.025% of the valves above the 

10,000-ppm limit

Screening Value 

(ppm) 

Numbers of 

Valves 

Leak Rate 

(lb/day) 

 

0 199,145 82 

0<S<100 255 0 

100<S<10,000 550 10 

>10,000 50 168 

Total 260 

Emission Reduction: 

Emission Reductions 

@ 0.3 percent Leaking 

Emission Reductions 

@ 0.2 percent Leaking 

346 lbs/day 458 lbs/day 

0.21 TPD 0.23 TPD 
Approach and Assumptions 

Source of Emission Factors: 

Emission estimates were calculated using the ARBís "California Implementation 

Guidelines for Estimating Mass Emissions of Fugitive Hydrocarbon Leaks at Petroleum 

Facilities.î 

Number of Values at Refineries: 

The number of valves in currently in operation at all the five Bay Area refineries is 

estimated to 200,000 and is based on WSPA Evaluation of Regulation 8, Rules 8 and 25 

conducted by Radian (December 1996), which estimated 180,000 valves. 

Number of Value Leaking in Excess of 10,000 ppm: 

Based on data collected during inspection audits of refinery fugitive components 

(July 1999 BAAQMD Inspection Audit of Fugitive Components at Refineries and May 

1997 BAAQMD Inspection Audit of Fugitive Components at Refineries), staff estimated 

that 15 percent of the leaking valves leak above 10,000. 

Additional Assumptions for Emission Estimates: 

For valves with leak concentrations between 0 and 100 ppm, the average leak 

concentration is 30 ppm; and the percent of leaking valves between 0 and 100 ppm is 0.5 

times the number of valves leaking below 10,000 ppm. 
Appendix C 

CEQA Analysis 

Appendix D 

Socioeconomic Analysis