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1
MEMORANDUM
TO:
Randy
McDonald,
U.
S.
Environmental
Protection
Agency,
OAQPS
FROM:
Roy
Oommen,
Eastern
Research
Group
(
ERG),
Morrisville
DATE:
June
1,
2006
SUBJECT:
Cost
and
Emission
Reductions
of
Leakless
Valves
for
HON
Facilities
1.0
INTRODUCTION
This
memorandum
describes
the
estimation
of
costs
and
emission
reductions
associated
with
replacing
existing
valves
with
leakless
valves
at
facilities
subject
to
the
Hazardous
Organic
NESHAP
(
HON).
Data
sources
used
in
the
analysis
are
presented
in
section
2.0.
The
methodology
and
results
are
discussed
in
section
3.0.

2.0
DATA
SOURCES
Responses
to
a
voluntary
risk
assessment
information
request
made
by
the
American
Chemistry
Council
(
ACC)
provided
total
facility
pollutant
specific
emission
estimates
for
105
HON
facilities.
The
105
serve
as
the
basis
for
EPA
=

s
risk
assessment
of
the
HON.
The
ACC
data
did
not
include
component
counts.

Notification
of
Compliance
Status
(
NOCS)
reports
from
97
facilities
subject
to
the
HON
were
reviewed
for
more
specific
component
information.
Of
the
NOCS
reports
reviewed,
only
29
contained
information
about
the
number
of
valves
and
other
equipment
in
use.
However,
the
NOCS
reports
did
not
specify
the
service
(
gas,
light
liquid,
heavy
liquid)
of
the
components.
The
NOCS
reports
also
did
not
provide
emissions
information.

Emission
factors
and
reduction
efficiencies
associated
with
leakless
equipment
and
equipment
meeting
the
HON
standards
were
obtained
from
the
equipment
leaks
protocol.
1
Costs
associated
with
leakless
valves
were
documented
in
a
previous
memorandum.
2
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2
3.0
METHODOLOGY
AND
RESULTS
The
calculation
of
the
costs
and
emission
reductions
associated
with
using
leakless
equipment
for
the
105
HON
facilities
were
based
on
identifying
the
number
of
valves
in
each
facility
that
needed
to
be
replaced.
Estimating
the
number
of
valves
at
the
105
HON
sites
required
relating
the
component
count
information
in
the
NOCS
reports
to
the
emissions
data
provided
by
the
ACC.
The
methodology
used
is
described
in
the
following
sections.

Calculation
of
the
Valve
to
Total
Component
Count
Ratio
Only
29
facilities
had
information
in
their
NOCS
reports
on
the
number
of
valves
and
other
components.
The
information
in
these
NOCS
reports
was
used
to
calculate
the
ratio
of
valve
volatile
organic
compound
(
VOC)
emissions
to
total
equipment
VOC
emissions.
First,
the
uncontrolled
VOC
emissions
from
each
component
was
calculated
by
multiplying
the
average
uncontrolled
VOC
emission
factor
from
the
protocol
with
the
number
of
components,
and
assuming
8,400
hours
per
year
of
operation.
Because
the
NOCS
reports
did
not
specify
the
service
of
the
equipment,
it
was
assumed
that
the
components
reported
were
all
subject
to
the
HON
leak
detection
and
repair
program,
i.
e.,
they
were
all
light
liquid
and
gas/
vapor
service.

Additionally,
the
average
of
the
emission
factors
for
gas
and
light
liquid
components
was
used
to
calculate
uncontrolled
emissions.

The
baseline
VOC
emissions,
i.
e.,
emissions
assuming
HON
equipment
leaks
level
of
control,
were
calculated
for
each
component
using
the
HON
control
efficiencies
in
the
protocol.

The
average
control
efficiency
for
gas
and
light
liquid
components
was
used
in
the
calculations.

Table
3­
1
presents
the
calculation
of
valve
emissions
from
the
29
facilities
with
NOCS
reports
that
were
used.

Table
3­
2
presents
the
total
HON
controlled
equipment
leak
emissions,
and
the
emissions
of
the
components
that
contribute
most
to
the
total:
valves,
pumps,
and
connectors.
The
table
also
presents
the
ratio
of
controlled
component
emissions
to
total
controlled
emissions.
An
average
ratio
for
each
component
was
calculated
using
only
the
information
from
facilities
providing
component
counts
for
all
three
component
types.
The
average
ratio
relating
VOC
emissions
from
valves
to
total
VOC
emissions
was
calculated
to
be
0.619.
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3
Calculation
of
Total
HAP
Emissions
From
Valves
The
ACC
data
provided
annual
emissions
of
each
hazardous
air
pollutant
(
HAP)
for
each
emission
source
(
e.
g.,
equipment
leaks,
process
vents,
etc.)
from
each
of
the
105
HON
facilities.

Total
HAP
emissions
for
equipment
leaks
from
each
facility
were
calculated
by
summing
the
emissions
of
each
HAP.

The
total
HAP
emissions
attributed
to
valves
was
calculated
by
multiplying
the
total
HAP
emissions
from
equipment
leaks
by
the
average
VOC
valve
to
total
emissions
ratio
(
0.619).
This
assumes
that
the
rate
of
release
of
HAPs
is
equal
to
the
rate
of
release
of
VOC
from
leaking
valves.

Calculation
of
the
Number
of
Valves
at
HON
Facilities
The
number
of
valves
at
each
of
the
105
facilities
were
calculated
by
dividing
the
total
HAP
emissions
attributed
to
valves
by
the
VOC
emission
factor
associated
with
the
HON
level
of
control
for
valves,
0.00006
kg/
component/
year,
and
assuming
8,400
hours
per
year
of
operation.

The
VOC
emission
factor
associated
with
the
HON
level
of
control
for
valves
was
calculated
by
multiplying
the
average
of
the
uncontrolled
emission
factors
for
gas
and
light
liquid
valves
(
0.005)

by
the
emissions
that
would
remain
after
the
HON
emission
reductions
of
88
percent
was
applied
(
100­
88
=
12
percent).

For
this
analysis
it
was
assumed
that
the
HAP
to
VOC
ratio
is
1,
i.
e,
VOC
emissions
are
equal
to
HAP
emissions.
This
assumption
may
overestimate
the
number
of
valves,
but
will
also
provide
the
most
conservative
estimate
of
costs.
Table
3­
3
summarizes
the
calculation
of
valves
for
each
facility
from
the
industry
survey.

Calculation
of
Cost
The
equipment
capital
cost
of
leakless
valves
was
calculated
using
cost
information
presented
in
another
memorandum.
2
No
information
was
available
on
the
installation
costs
associated
with
replacing
existing
valves
with
leakless
valves.
The
Office
of
Air
Quality
Planning
and
Standards
(
OAQPS)
Control
Cost
Manual
(
OCCM)
provides
information
on
the
installation
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4
costs
of
air
pollution
control
devices,
such
as
scrubbers,
and
ductwork.
3
For
this
analysis,
the
installation
cost
was
assumed
to
be
similar
to
equipment
in
the
OCCM.
An
average
installation
factor
from
the
OCCM
of
30
percent
of
capital
cost
was
used.
There
is
insufficient
information
to
assess
whether
this
factor
underestimates
installation
costs.

The
annualized
cost
of
leakless
valves
was
also
calculated
using
cost
information
from
a
previous
memorandum.
2
The
annualized
cost
of
installation
was
calculated
assuming
a
7
percent
interest
rate
over
the
life
of
the
leakless
component.
No
other
annual
costs
are
anticipated
from
leakless
equipment.
Table
3­
4
presents
the
capital
and
annual
cost
estimates
from
converting
valves
to
leakless
valves.
The
total
capital
cost
for
the
industry
is
estimated
to
be
3.6
billion
dollars.
The
total
annual
cost
is
estimated
to
be
337
million
dollars.

4.0
REFERENCES
1.
U.
S.
Environmental
Protection
Agency.
1995
Protocol
for
Equipment
Leak
Emission
Estimates.
Emission
Standards
Division.
November
1995.
EPA­
453/
R­
95­
017.

2.
Oommen,
Roy,
ERG.
Memorandum
to
Mark
Morris,
U.
S.
Environmental
Protection
Agency.
HON
Equipment
Leaks
Analyses.
November,
2002.

3.
U.
S.
Environmental
Protection
Agency.
Office
of
Air
Quality
Planning
and
Standards.
OAQPS
Control
Cost
Manual,
Fifth
Edition,
Research
Triangle
Park.
EPA
453/
B­
96­
001.
