0154­
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HON
storage
vessel
memo.
doc
1
MEMORANDUM
TO:
Randy
McDonald,
U.
S.
Environmental
Protection
Agency,
OAQPS
FROM:
Roy
Oommen,
Eastern
Research
Group
(
ERG),
Morrisville
DATE:
June
9,
2006
SUBJECT:
Storage
Vessel
Emission
Reduction
and
Control
Cost
Estimates
1.0
INTRODUCTION
The
purpose
of
this
memorandum
is
to
present
the
analyses
used
to
estimate
the
hazardous
air
pollutant
(
HAP)
emissions,
emission
reductions,
and
costs
associated
with
controlling
uncontrolled
storage
vessels
at
hazardous
organic
NESHAP
(
HON)
sources.
These
uncontrolled
storage
vessels
are
classified
in
the
HON
regulation
as
Group
2
storage
vessels.
Section
2
presents
the
data
used
to
estimate
baseline
emissions
from
uncontrolled
storage
vessels.
Section
3
presents
the
methodologies
used
to
estimate
emission
reductions
and
control
costs.

2.0
BASELINE
DATA
Baseline
storage
vessel
data
on
existing
HON
facilities
were
collected
by
the
American
Chemistry
Council
(
ACC)
through
a
voluntary
survey
and
provided
to
EPA.
The
ACC
data
contained
site­
specific
information
for
the
base
year
1999
for
104
of
the
238
existing
HON
facilities.
Information
from
all
the
facilities
was
then
combined
into
one
database.
The
data
fields
in
the
database
are
presented
in
Table
2­
1.

The
ACC
survey
requested
that
storage
vessel
information
be
identified
as
either
controlled
or
uncontrolled.
However,
many
respondents
did
not
provide
this
information.
Such
storage
vessels
were
grouped
into
a
third
category,
unspecified
storage
vessels.
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storage
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Table
2­
1.
Data
Fields
in
Storage
Vessels
Database
Source
ID
HON
Facility
ID
Chemical
Manufacturing
Process
Unit
ID
(
CMPU_
ID)

Latitude
Longitude
Emission
Type
HAP
Name
CAS
Number
Emission
Rate
(
kg/
yr)

Stack
Height
3.0
EMISSION
REDUCTION
AND
CONTROL
COST
ESTIMATES
For
this
analysis,
both
uncontrolled
storage
vessels
and
unspecified
storage
vessels
were
categorized
as
Group
2.
This
assumption
regarding
the
unspecified
vessels
provides
the
most
conservative
estimate
of
costs.
Additionally,
this
analysis
was
conducted
only
for
storage
vessels
that
contained
at
least
one
HAP
with
a
high
lifetime
cancer
risk,
as
well
as
other
specific
pollutants
of
interest.
Collectively,
these
HAP
are
referred
as
HAPs
listed
in
Table
38
of
the
proposed
rule.

Each
storage
vessel
was
identified
based
on
the
process
unit
associated
with
it,
as
well
as
by
unique
longitude
and
latitude,
stack
height,
and
pollutants
emitted.
For
this
analysis
all
Group
2
tanks
were
assumed
to
be
fixed
roof
and
each
storage
vessel
was
assumed
to
store
only
1
HAP.

3.1
Emission
Reductions
Emission
reductions
were
calculated
assuming
that
each
Group
2
storage
vessel
would
be
controlled
by
converting
the
fixed
roof
tank
to
an
internal
floating
roof
tank.
This
was
one
of
the
control
methods
used
in
the
HON
and
achieves
95
percent
reduction
in
emissions.
The
annual
0154­
04­
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HON
storage
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3
emission
reductions
from
converting
each
Group
2
storage
vessel
was
calculated
using
the
following
equations:

ER
=
(
0.95)((
EHAP)(
H)(
1/
1000)

where:

°
ER
is
the
emission
reduction
of
the
HAP
in
the
storage
vessel
(
Megagrams
per
year),
°
EHAP
is
the
storage
vessel
HAP
emission
rate
(
kilograms
per
hour),
and
°
H
is
the
hours
of
operation
per
year.

3.2
Cost
Capital
and
annual
cost
estimates
were
calculated
using
information
in
previous
EPA
studies.
1,2
Based
on
the
studies
the
elements
of
total
capital
investment
that
were
calculated
are
capital
cost
of
the
conversion
to
internal
floating
roof,
degassing
and
cleaning
costs,
and
waste
disposal
costs:

TCI
=
Cconversion
+
Cwaste
+
Cdegas/
clean
where:

°
TCI
is
the
total
capital
investment
in
$,
°
Cconversion
is
the
cost
of
converting
fixed
roof
tanks
to
internal
floating
roof
tanks
in
$,
°
Cwaste
is
the
cost
of
waste
disposal
in
$,
and
°
Cdegas/
clean
is
the
cost
of
degassing
and
cleaning
the
fixed
roof
tank
in
$.

The
cost
of
converting
the
tank
was
calculated
using
the
following
equation2:

Cconversion
=
[
9.46
(
D)
2
+
40,103]
(
CE2003/
CE1991)

where:

°
D
is
the
diameter
of
the
tank
in
feet,
°
CE2003
is
the
chemical
engineering
cost
index
for
2003
(
402),
and
°
CE1991
is
the
chemical
engineering
cost
index
for
1991,
the
base
year
of
the
cost
algorithm
(
361.3).

The
diameter
of
the
tank
was
not
provided
in
the
survey
responses.
This
value
was
obtained
from
a
previous
EPA
document
that
related
tank
diameter
and
volume
to
various
tank
heights.
1
Each
tank
height
from
the
survey
responses
was
matched
to
the
closest
tank
height
in
the
EPA
study.
0154­
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storage
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doc
4
A
previous
EPA
document
provided
a
relationship
between
the
waste
disposal,
and
degassing
and
cleaning
costs
to
volume
of
the
tank.
1,2
These
costs
are
calculated
using
the
following
equations:

Cwaste
=
0.075
*
V
Cdegas/
clean
=
0.1
*
V
Total
annual
costs
were
calculated
from
capital
recovery
costs
and
indirect
costs
(
taxes,

insurance,
and
administrative
costs),
direct
costs
(
maintenance
and
inspection
costs),
and
recovery
credits.
2
TAC
=
Capital
Recovery
Costs
+
Indirect
Costs
+
Direct
Costs
 
Recovery
credits
The
capital
recovery
costs
are
equal
to
the
capital
costs
multiplied
by
the
capital
recovery
factor
(
CRF).
The
capital
recovery
factor
(
0.14)
was
calculated
using
the
following
equation:

CRF
=
(
i(
1+
i)
n)/((
1+
i)
n­
1)

where:

°
i
=
the
interest
rate
(
7
percent
was
used
for
this
analysis),
and
°
n
=
repayment
period
(
years).

For
this
analysis,
the
interest
rate
chosen
was
7
percent
and
the
repayment
period
was
10
years,
as
used
in
the
HON
for
storage
tanks.
Total
capital
recovery
costs
were
calculated
using:

Capital
Recovery
Costs
=
CRF
*(
Cconversion
+
Cwaste
+
Cdegas/
clean)

Indirect
costs
were
calculated
as
4
percent
of
capital
costs
and
direct
costs
were
calculated
as
6
percent
of
capital
costs.
2
By
reducing
the
emissions
from
storage
vessels,
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.
1
0154­
04­
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HON
storage
vessel
memo.
doc
5
A
summary
of
costs
and
emission
reductions
for
all
Group
2
tanks
is
presented
in
Table
3­

1.
A
detailed
summary
of
cost
information
for
uncontrolled
tanks
is
found
in
Attachment
A­
1
and
a
detailed
summary
of
cost
information
for
unspecified
tanks
is
found
in
Attachment
A­
2.

4.0
REFERENCES
1.
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.

2.
Alternative
Control
Techniques
Document:
Volatile
Organic
Liquid
Storage
in
Floating
and
Fixed
Roof
Tanks.
Emission
Standards
Division,
U.
S.
Environmental
Protection
Agency,
Office
of
Air
and
Radiation,
Office
of
Air
Quality
Planning
and
Standards,
Research
Triangle
Park,
NC,
January
1994.
