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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
for
Meeting
Percent
Leaker
Requirements
for
HON
Sources
1.0
INTRODUCTION
This
memorandum
describes
the
estimation
of
costs
and
emission
reductions
associated
with
applying
more
stringent
equipment
leak
requirements
than
in
the
hazardous
organic
NESHAP
(
HON)
to
the
synthetic
organic
chemical
manufacturing
industry
(
SOCMI).
Currently
the
HON
allows
2
percent
of
valves
at
a
process
unit
to
be
leaking.
The
control
options
evaluated
for
this
analysis
were
requiring
the
total
percentage
of
leaking
valves
at
HON
chemical
manufacturing
process
units
to
be
less
than
or
equal
to
0.5
percent,
1
percent,
and
0.25
percent.

Table
1­
1
summarizes
the
results
of
this
analysis
for
105
HON
facilities
where
costs
and
emissions
reductions
were
calculated.

Section
2.0
discusses
the
data
sources
used
for
this
analysis.
Section
3.0
presents
the
methodology
and
results
of
the
analysis.
Section
4.0
lists
references.
Appendix
A
summarizes
the
costs
and
emission
reductions
of
meeting
0.5
percent
leaking
valves
requirement.
Appendix
B
summarizes
the
costs
and
emission
reductions
of
meeting
1
percent
leaking
valves
requirement.

Appendix
C
summarizes
the
costs
and
emission
reductions
of
meeting
0.25
percent
leaking
valves
requirement.
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Table
1­
1.
Summary
of
Costs
and
Emission
Reductions
for
Percent
Leak
Levls
for
105
HON
Facilities
Percent
Leakers
Total
Annual
Costs
($/
yr)
Total
HAP
Emission
reductions
(
kg/
yr)

0.25
4,314,255
497,784
0.50
4,221,604
360,995
1.0
4,090,506
167,447
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.
A
previous
analysis
documented
the
calculation
of
the
average
ratio
of
emissions
from
valves
to
total
facility
emissions
based
on
the
ACC
data
and
other
data
sources.
1
Emission
factors
and
equations
used
to
calculate
the
percentage
of
leaking
components
were
obtained
from
the
equipment
leaks
protocol.
2
Costs
associated
with
monitoring
and
repairing
valves
were
obtained
from
previous
EPA
equipment
leak
studies.
3
3.0
METHODOLOGY
AND
RESULTS
This
analysis
was
conducted
in
a
three
step
process.
First,
the
number
of
valves
at
each
HON
process
unit
and
facility
were
calculated.
The
valve
count
was
then
used
to
calculate
the
emission
reductions
associated
with
meeting
a
specific
percent
leaker
level.
The
valve
count
was
also
used
to
develop
cost
estimates
of
meeting
the
percent
leaker
levels.

Determination
of
the
Number
of
Valves
at
Each
Facility
The
first
step
in
this
analysis
was
to
determine
the
number
of
valves
at
each
facility.
The
valve
count
was
calculated
from
the
total
emissions
of
HAPs
of
interest
from
each
facility.
HAPs
of
interest
are
those
with
URE
values.
Consequently,
total
HAP
emissions
from
process
units
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containing
at
least
one
URE
HAP
were
calculated.
The
total
facility
HAP
emissions
were
calculated
by
summing
emissions
from
the
process
units.
Using
the
ratio
of
emissions
from
valves
to
total
facility
emissions
previously
calculated
(
0.619),
the
total
HAP
emissions
from
valves
was
determined.
1
The
number
of
valves
was
then
calculated
using
the
following
equation:

#
valves
=
EHAP
/
(
h
*
EF)

where:
EHAP
=
the
total
HAP
emissions
in
kg/
yr
h
=
hours
of
operation
per
year
EF
=
emission
factor
for
valves
in
kg/
component/
hour
For
this
analysis,
the
hours
of
operation
per
year
were
assumed
to
be
8,400.
The
emission
factor
for
valves
is
0.0006
kg/
hour/
component.
2
Determination
of
Emission
Reductions
from
Meeting
Percent
Leaker
Levels
Emission
reductions
associated
with
meeting
a
percent
leaking
valve
requirement
were
calculated
by
subtracting
the
emissions
associated
with
the
target
level
(
e.
g.,
1,
0.5,
or
0.25
percent)
from
the
emissions
associated
with
the
baseline
level
(
i.
e.,
2
percent
or
less).
The
baseline
emissions
were
provided
by
the
ACC.
The
percent
leakers
associated
with
the
baseline
emissions
were
calculated
using
the
following
equation
from
the
equipment
leaks
protocol:

%
leakers
=
100
*
[(
Epl/(#
valves
*
h)
 
1.7
x
10­
5]
/
0.044
where:
Epl
=
the
total
emissions
associated
with
the
percentage
leakers
in
kg/
year.

Emissions
associated
with
the
target
percent
leaking
level
were
calculated
by
rearranging
the
previous
equation:

Epl
=
[(
0.044)(%
leakers/
100)
+
1.7
x
10­
5]
*
#
valves
*
h
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Determination
of
Costs
from
Meeting
Percent
Leaker
Levels
Costs
associated
with
changing
from
the
baseline
percent
leaking
level
to
the
target
level
include
repair,
monitoring,
rescreening,
and
data
management.
Repair
and
rescreening
costs
are
calculated
from
the
number
of
components
required
to
be
repaired.
This
value
is
estimated
by
the
following
equations:

Vrepair
=
(%
leakersbaseline
­
%
leakerstarget)(#
valves)(
MF)/
100
Where:
Vrepair
=
the
number
of
valves
repaired
MF
=
monitoring
frequency
for
valves
For
this
analysis,
costs
were
calculated
assuming
that
valves
would
be
monitored
twice
a
quarter
or
8
times
per
year
in
order
to
meet
lower
leak
rates.

Repair
costs
are
calculated
using
the
following
equation:

Crepair
=
(
CF
repair)(
trepair)(
Vrepair)

Where:
Crepair
=
cost
of
repair
in
$
per
year.

CFrepair
=
cost
factor
for
repair
in
$
per
hours
needed
for
repair
Trepair
=
time
required
for
repairing
valve
in
hours
Rescreening
costs
are
calculated
from
the
following
equation:

Crescreening
=
(
CFrescreening)(
Vrepair)

Where:
Crescreening
=
Costs
for
rescreening
valves
in
$
per
year
CFrescreening
=
Cost
factor
for
rescreening
in
$
per
valve
Monitoring
costs
and
data
management
costs
are
calculated
from
the
following
equations:
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Cmonitoring
=
(
CFmonitoring)(
monitoring
frequency)(#
valves)

Cdata_
manage
=
(
CFdata_
manage)(
monitoring
frequency)(#
valves)

Where:
Cmonitoring
=
cost
of
monitoring
valves
in
$
per
year
CFmonitoring
=
cost
factor
for
monitoring
valves
in
$
per
valve
Cdata_
manage
=
cost
of
data
management
activities
in
$
per
year
CFdata_
manage
=
cost
factor
for
data
management
activities
in
$
per
valve
Table
3­
1
presents
the
cost
factors
and
input
values
used
in
this
analysis.
The
cost
factors
were
obtained
from
previous
EPA
studies
and
modified
using
engineering
judgement.
Additionally,
by
reducing
the
emissions
from
leaking
components,
product
waste
is
reduced
and
can
be
claimed
as
recovery
credit.
The
HON
background
information
document
contains
a
recovery
credit
factor
of
$
1,370/
ton
of
product
saved.
4
Table
3­
1.
Cost
Inputs
for
Percent
Leaking
Valves
Analysis
Parameter
Input
Value
CFrepair
$
25
per
hour
Trepair
4
hours
CFrescreening
$
1
per
valve
CFmonitoring
$
1.50
per
valve
CFdata_
manage
$
0.50
per
valve
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4.0
REFERENCES
1.
Oommen,
Roy,
ERG.
Memorandum
to
Randy
McDonald,
U.
S.
Environmental
Protection
Agency.
Cost
and
Emission
Reductions
of
Leakless
Valves
for
HON
Facilities.

2.
U.
S.
Environmental
Protection
Agency.
1995
Protocol
for
Equipment
Leak
Emission
Estimates.
Emission
Standards
Division.
November
1995.
EPA­
453/
R­
95­
017.

3.
U.
S.
Environmental
Protection
Agency.
Internal
Instruction
Manual
for
ESD
Regulation
Development.
Leaking
Equipment 
Pumps,
Valves,
Connectors,
Compressors,
Safety
Relief
Valves.
July
1992.

4.
Hazardous
Air
Pollutant
Emissions
From
Process
Units
in
the
Synthetic
Organic
Chemical
Manufacturing
Industry­
Background
Information
for
Proposed
Standards,
Volume
1CModel
Emission
Sources,
Emission
Standards
Division,
U.
S.
Environmental
Protection
Agency,
Office
of
Air
and
Radiation,
Office
of
Air
Quality
Planning
and
Standards,
Research
Triangle
Park,
NC,
November
1992
