United States Office of Air Quality EPA-340/1-88-015
Environmental Protection Planning and Standards June 1986
Agency Washington, DC 20460
Stationary Source Compliance Series
&ER& Portable
Instruments
User's Manual
for Monitoring
VOC Sources
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EPA-340/1-86-015
Portable Instruments User's
Manual for Monitoring
VOC Sources
by
PEI Associates, Inc.
11499 Chester Road
Post Office Box 46100
Cincinnati, Ohio 45246-0100
and
Richards Engineering
Durham, North Carolina 27705
Contract No. 68-02-3963
Work Assignment No. 103
Prepared for
EPA Project Officer: John Busik
EPA Work Assignment Manager: Mary Cunningham
U.S. ENVIRONMENTAL PROTECTION AGENCY
Stationary Source Compliance Division
Office of Air Quality Planning and Standards
Washington, D.C. 20460 u Environi^ntal Protection Agency
•Region 5, LVvrary (5?L-16)
June 1986 r^0 R rjf;,rLor.i St-eet, Room 1670
IL 60604
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DISCLAIMER
This report was prepared by PEI Associates, Inc., Cincinnati, Ohio,
under Contract No. 68-02-3963, Work Assignment No. 103. It has been reviewed
by the Stationary Source Compliance Division of the Office of Air Quality
Planning and Standards, U.S. Environmental Protection Agency and approved
for publication. Approval does not signify that the contents necessarily
reflect the views and policies of the U.S. Environmental Protection Agency.
Mention of trade names or commercial products is not intended to constitute
endorsement or recommendation for use.
n
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CONTENTS
Tables '. . . v
Acknowledgment vi
1. Introduction 1
2. Regulatory Requirements 3
New Source Performance Standards 3
National Emission Standards for Hazardous Pollutants. . . 9
Instrument specifications 15
3. Portable Instrument Operating Principles 16
VOC detectors 16
Thermocouples 19
Static pressure gauges 20
4. Establishing an Agency Program for the Use of Portable
Instruments for Monitoring VOC and Air Toxics Sources. ... 21
Selection of the necessary types of instruments 21
Instrument spare parts and accessories 28
Laboratory and shop support facilities 29
Instrument maintenance program and records 31
Costs 32
Preparing bid specifications 39
5. Instrument Calibration and Evaluation 41
Instrument calibration requirements and procedures. ... 41
Routine laboratory evaluation of instrument performance . 49
Routine field-oriented evaluations of instrument condi-
tions and performance 51
6. Field Inspection Procedures and Inspection Safety 58
Principles, requirements, and limitations of agency
inspections 58
Screening tests for VOC leaks from process equipment. . . 61
Inspection of carbon-bed adsorbers 67
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CONTENTS (continued)
Inspection of thermal and catalytic incinerators 69
Inspection of vapor recovery systems 71
Surveying emissions from stacks, vents, and roof monitors. . . 72
References 75
Appendices
A. Reference Method 21 and NSPS and NESHAPS Regulations 80
B. Organic vapor analyzer response factors 119
C. lonization potentials of selected organic compounds 130
Glossary 134
IV
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TABLES
Number Page
1 NSPS VOC Fugitive (Leak) Emission Limits 4
2 NSPS VOC Monitoring Requirements for Sources Controlled by
Carbon-Bed Absorbers and Thermal or Catalytic Incineration . 6
3 NESHAP Monitoring Requirements for Fugitive Emissions 10
4 Most Common Portable VOC Detection Instruments 17
5 Ease-of-Use of Organic Vapor Analyzers 25
6 Definitions of Hazardous Locations in Accordance With the
National Electrical Code 26
7 Intrinsic Safety Ratings of Commercial Instruments, January
1986 27
8 Estimated Costs of HNU Model PI-101 Photoionization Analyzer . 34
9 Estimates Costs for Foxboro Model 108 FID Type Organic Vapor
Analyzer 35
10 Estimated Costs for Bacharach TLV Sniffer 36
11 Estimated Costs for Omega Portable Thermometer 37
12 General Equipment Costs 39
13 Recommended Calibration Gases for Routine Instrument Service . 43
14 Calibration Time Requirements When Using Commercially Prepared
Calibration Gases 44
15 Calibration Time Requirements When Calibration Gas Mixtures
are Blended 46
16 Time Required for Field Span Checks 48
17 Partial Listing of Recommended Onsite Spare Parts and Supplies
for Portable Instruments 55
18 Estimated Leakage Rates for Refinery Components 63
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ACKNOWLEDGMENT
This report was prepared for the U.S. Environmental Protection Agency by
PEI Associates, Inc., Cincinnati, Ohio, and Richards Engineering, Durham,
North Carolina. Mr. John Busik was the EPA Project Officer and Ms. Mary
Cunningham the Work Assignment Manager. Mr. John Zoller served as the Project
Director, and Mr. David Dunbar was the Project Manager. The principal authors
were Mr. G. Vinson Hellwig, Mr. David Dunbar, and Mr. John Richards, Richards
Engineering. Mr. Tom Ponder served as Senior Technical Advisor. The authors
wish to thank Ms. Mary Cunningham for her guidance and direction on this work
assignment.
VI
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SECTION 1
INTRODUCTION
The U.S. Environmental Protection Agency (EPA) has promulgated New Source
Performance Standards (NSPS) and National Emission Standards for Hazardous
Air Pollutants (NESHAP's) for several categories of sources that emit volatile
organic compounds (VOC's) and that require monitoring with portable detection
instruments. The EPA has also issued control techniques guidelines (CTG's) for
a number of source categories that emit VOC's. The source categories covered
by the NSPS, NESHAP's, and CTG's include petroleum refineries, synthetic or-
ganic chemical plants, coating operations, and natural gas processing plants.
Fugitive VOC emissions at these sources occur at valves, pumps, drains,
pressure relief devices, etc. If these points of fugitive emissions can be
identified, the leaks can be repaired and the emissions can be eliminated.
This manual presents information on the principles of operation of cur-
rently available portable monitors and the field inspection techniques for
the monitor's safe use in both screening and compliance determinations. This
manual is intended to be used by State or local agencies.
The level of the inspection performed is often determined by the com-
pliance history of the source and the regulatory requirements. If the in-
spection procedure involves the use of a sophisticated instrument to deter-
mine compliance with a regulation, it is classed as a Level 3 inspection,
which is the most thorough and time-consuming level. Level 3 inspections are
designed to provide a detailed engineering analysis of source compliance by
use of measured operating parameters or emissions data. The Level 3 inspec-
tion for determining fugitive VOC emissions requires the use of portable hand-
held instruments. These instruments include portable organic vapor monitors,
thermocouples, and static pressure gauges.
The EPA has published Reference Method 21 to provide a technical method
to test for leaks from these sources. Method 21 allows the user to select
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one of several instruments available on the market if they meet the specifi-
cations and performance requirements, discussed in Section 2. A summary of
the published specifications of many of the portable VOC monitors is presented
in this manual.
Because the inspector will be using a reference test method and the
aquired data may be used in an enforcement action against the facility,
special care should be taken in the use of portable instruments during a
Level 3 inspection. Calibration procedures must be strictly adhered to verify
the acquired data.
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SECTION 2
REGULATORY REQUIREMENTS
The use of portable VOC-detecting instruments is based primarily on re-
quirements regarding control of leaks as contained in the NSPS and NESHAP's
and in the CTG's published by EPA to provide guidance for State and local
agencies in the development of their own regulations.
2.1 NEW SOURCE PERFORMANCE STANDARDS
Two categories of VOC emissions must be monitored: 1) emissions from
sources controlled by carbon-bed absorbers, thermal incinerators, and vapor
recovery systems; and 2) fugitive emissions from process equipment. Appendix
A contains the NSPS requirements for the source categories in Table 1. The
monitoring is to be performed as described in 40 CFR 60, Appendix A, Reference
Method 21.
2.1.1 Determination of Volatile Organic Compound Leaks From Sources Con-
trolled by Carbon-Bed Absorbers, Condenser Units, and Thermal of
Catalytic Incinerators
Carbon-bed absorbers, condenser units, and thermal or catalytic inciner-
ators are used to control emissions from the surface coating of metal furni-
ture, automobiles and light-duty trucks, pressure-sensitive tape and labels,
large appliances, metal coils, and beverage cans, and flexible vinyl and
urethane coating and printing.
Carbon-bed absorption units, condenser units, and thermal or catalytic
incinerators normally require onsite monitoring with stationary instruments
rather than portable ones; however, some measurements can be made with portable
instruments to verify both the operation of the control equipment and the on-
site stationary monitoring results. Carbon-bed absorbers and condenser units
require the use of both VOC-detection equipment and temperature-monitoring
equipment. Thermal and catalytic incinerators also require the use of
temperature monitoring equipment.
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TABLE 1. NSPS VOC FUGITIVE (LEAK) EMISSION LIMITS
Source category
Equipment
Emission
limit
Monitoring
requirement
Subpart VV - Equipment
Leaks of VOC in the
Synthetic Organic
Chemicals Manufacturing
Industry
Subpart XX - Bulk
Gasoline Terminals
Subpart GGG - Equip-
ment Leaks of VOC in
Petroleum Refineries
Valves
Pumps
Compressors
Sampling connec-
tions
Open-ended lines
Pressure-relief
devices
Exception:
plants process-
ing only heavy
liquids or
solids and
facilities pro-
ducing beverage
alcohol
All the loading
racks at a bulk
gasoline ter-
minal that de-
liver gasoline
into any de-
livery tank truck
Valves
Pumps
Sampling connec-
tions
L0,000 ppm by volume
(ppmv)
10,000 ppmv or
visible leak from
seal in pumps in
liquid service
Zero
Zero
Zero
500 ppmv or less
above background
level
10,000 ppmv
10,000 ppmv
10,000 ppmv
or visible leak
Zero
Monthly
Monthly
No require-
ments
No require-
ments
No require-
ments
Periodic3
Monthly
Monthly
Monthly
No require-
ments
(continued)
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TABLE 1 (continued)
Source category
Equipment
Emission
limit
Monitoring
requirement
Subpart KKK - Equip-
ment Leaks of VOC from
Onshore Natural Gas
Processing Plants
Open-ended lines
Pressure relief
device
Valves
Pumps
Sampling connec-
tions
Open-ended lines
Pressure relief
devices
Zero
500 ppmv or less
above background
level
10,000 ppmv
10,000 ppmv
Zero
Zero
10,000 ppmv
No require-
ments
Periodic9
Monthly
Monthly
No require-
ments
No require-
ments
Periodic3
Except in the case of pressure releases where the source must be monitored
within 5 days of a pressure release.
In certain source categories, the NSPS regulations require adherence to
an emission limit or some other operating parameter. Compliance with this
requirement is monitored by onsite equipment. These standards apply to
various surface coating operations and flexible vinyl and urethane coating
and printing (Table 2).
Portable monitoring instruments can be used on the exit vent/stack side
of the carbon absorbers and condenser units to detect breakthrough of the
VOC's. A portable monitor used to perform this type of test must be sensi-
tive in the 50 to 500 ppmv range. Such an instrument can detect VOC emis-
sions that are over and above what would be expected from a controlled source.
Because these portable instruments are continuous or semi continuous, the
probe only has to be put in the gas stream for the length of time necessary
to exceed the response time specified in the instrument manual.
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TABLE 2. NSPS VOC MONITORING REQUIREMENTS FOR SOURCES CONTROLLED BY CARBON-BED ABSORBERS
AND THERMAL OR CATALYTIC INCINERATION
Source category
Equipment or
operations
Emission limit or
work practice
Monitoring requirements
Subpart EE - Surface
Coating of Metal
Furniture
Subpart MM - Automobile
and Light-Duty Truck
Surface Coating Opera-
tions
Subpart RR - Pressure-
Sensitive Tape and
Label Surface Coating
All metal furniture
surface coating
operations applying
organic coatings
Prime coating
Guide coating
Top coating
Exempt: plastic
components and all-
plastic bodies on
separate lines
Coating line input-
ing greater than
45 Mg (50 tons)
VOC per 12-month
period
0.90 kg/liter of coating
solids applied
0.16 kg/liter of applied
coating solids per each
prime coat operation
1.40 kg/liter of applied
coating solids per each
guide coat operation
1.47 kg/liter of applied
coating solids per each
top coat operation
(continued)
0.2 kg of VOC per kg of
coating solids applied
or
90% VOC emission reduc-
tion or an overall emis-
sion reduction equivalent
to the 0.20 kg per kg of
coating solids applied,
whichever is less stringent
Temperature measurement with
capture system and incineration
Permanent record of incinera-
tor temperature, if applicable
Same as above
Same as above
Same as above
Facilities with thermal in-
cinerators: temperature of
incinerator's exhaust gases
Facilities with catalytic in-
cinerators: gas temperature
upstream and downstream of the
catalyst bed
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TABLE 2 (continued)
Source category
Equipment or
operations
Emission limit or
work practice
Monitoring requirements
Subpart SS - In-
dustrial Surface Coat-
ing: Large Appliances
Subpart TT - Metal
Coil Surface Coating
Subpart WW - Beverage
Can Surface Coating
Industry
Coating line input-
ing less than 45 Mg
(50 tons) VOC per
12-month period
All large appliance
surface coating
line operations
Prime coating
operations, finish
coating operations,
and combined prime
and finish coating
operations when
finish coat is
applied wet on wet
over prime coat
and cured simul-
taneously
Two-piece beverage
can coating:
Exterior base
coating operation
Clear base coating
or overvarnish
coating
Not subject to limits but
subject to monitoring
requirements
0.90 kg/liter applied coat-
ing solids
0.28 kg/liter coating solids
with no emission control
0.14 kg/liter coating solids
with continuous emission
control
10% VOC's applied (90%
emission reduction)
Prorated value with
intermittent emission
control
Temperature measurement with
capture system and incinera-
tion
Continuous record of incinera-
tor temperature, if applicable
Same as above
Same as above
Same as above
0.29 kg VOC/liter of
coating solids (except
clear base coating)
0.46 kg VOC/liter of
coating solids
Temperature measurement for
incineration
Same as above
(continued)
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TABLE 2 (continued)
Source category
Equipment or
operations
Emission limit or
work practice
Monitoring requirements
Subpart FFF - Flexible
Vinyl and Urethane
Coating and Printing
Inside spray coat-
ing
Rotogravure print-
ing line
0.89 kg VOC/liter of
coating solids
Reduce gaseous VOC emis-
sions by 85%
Temperature measurement for
incineration
Continuous measurement and
recording of the temperature of
thermal incinerator exhaust
gases or of the gas tempera-
ture upstream and downstream
of a catalytic incinerator,
installation of a continuous
monitoring system for solvent
recovery
00
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Portable monitors also can be used to check the continuous monitor re-
quired at some sources. This measurement process is the same as that used for
testing breakthrough.
A thermocouple can be used to check the exit gas temperature from a
thermal or catalytic incinerator. A baseline stack temperature measurement
should be taken at the time the incinerator's permanent thermocouple is cali-
brated. This baseline temperature measurement gives a reference point for
future inspections.
2.1.2 Fugitive Emissions From Process Equipment
For the synthetic organic chemicals manufacturing industry, bulk gaso-
line terminals, petroleum refineries and on-shore natural gas processing
plants (Table 1), NSPS requires periodic leak inspections of the equipment to
determine if any fugitive VOC emissions are escaping. These leak inspections
are performed with portable VOC-detecting equipment according to Reference
Method 21. Equipment to be tested includes valves, pumps, seals, compressors,
sampling connections, open-ended lines, and pressure-relief devices.
A portable VOC-detection monitor may be used for leak inspections. The
probe must be inserted in the vicinity of a potential leak and must be moved
around the area where the leak may occur. The leak must be compared against
a background concentration, especially when the standards call for an emis-
sion limit of 0 or 500 ppmv. Field procedures for conducting leak inspection
monitoring are discussed in Section 6 of this manual.
2.2 NATIONAL EMISSION STANDARDS FOR HAZARDOUS POLLUTANTS
For certain categories of sources, NESHAP's place a not-to-be-exceeded
limit on fugitive emissions from processes, pumps, compressors, valves,
pressure-relief systems, etc. These standards apply to vinyl chloride,
ethylene dichloride, benezene, and volatile hazardous air pollutants (VHAP).
Emissions are monitored both by stationary onsite monitors and portable
instruments, depending on the regulatory requirements. Table 3 lists the
regulated facilities, emission standards (where monitoring is required), and
monitoring requirements for fugitive emissions from process sources. The
methods of detecting leaks and types of equipment to be inspected for leaks
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TABLE 3. NESHAP MONITORING REQUIREMENTS FOR FUGITIVE EMISSIONS
Source category
Equipment or
operations
Emission limit or
equipment standard
Monitoring requirements
Subpart F - Vinyl
Chloride
Ethylene dichloride
manufacture
Vinyl chloride
manufacture
Polyvinyl chloride
manufacture
Reactor; strip-
per; mixing,
weighing and
holding con-
tainers; monomer
recovery system
Reactor opening
loss
Reactor manual
vent
Sources follow
ing stripper
1) Ethylene dichloride
purification: 10 ppmv
2) Oxychlorination reactor:
0.2 g/kg (0.0002 Ib/lb)
of the 100% ethylene
dichloride product
10 ppmva
10 ppmvc
0.02 g vinyl chloride/kg
(0.00002 Ib vinyl chloride/
No emissions
For each calendar day:
1) Using stripping tech-
nology - 2000 ppmv for
polyvinyl chloride dis
persion resins (exclud-
ing latex), 400 ppmv
Source test
Continuous monitor
Source test
Continuous monitor
Source test
Continuous monitor
Source test
Continuous monitor
Source test
Continuous monitor
Source test
(continued)
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TABLE 3 (continued)
Source category
Equipment or
operations
Emission limit or
equipment standard
Monitoring requirements
Ethylene dichloride,
vinyl chloride and/
or polyvinyl
chloride manu-
facture
Relief valve dis-
charge
Loading and un-
loading 1 ines
SI ip gauges
Pump; compressor
and agitator seal
each for other polyvinyl
chloride resins (includ-
ing latex)
2) Other than stripping
technology - 2 g/kg
(0.002 Ib/lb) product for
dispersion polyvinyl
chloride resins (exclud-
ing latex)
0.4 g/kg (0.0004 Ib/lb
product for other poly-
vinyl chloride resins
(including latex)
No discharge
0.0038 m after each load-
ing, or 10 ppm when con-
tained by a control system
10 ppm from the required
control system
10 ppm from the required
control system with seals
Source test
No requirement
Source test
Continuous monitor
Source test
Continuous monitor
Source test
Continuous monitor
(continued)
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TABLE 3 (continued)
Source category
Equipment or
oj)eratjons
Emission limit or
equipment standard
Monitoring requirements
ro
Subpart J - Equipment
Leaks (Fugitive Emis-
sion Sources) of
Benzene
(continued)
Leakage from
relief valves
Manual venting
of gases
Opening of
equipment
Samples (at
least 10% by
weight vinyl
chloride)
Leak detection
and elimination
In-process waste-
water
Pumps
Compressors
Pressure-relief
devices
Sampling connec-
systems
Open-ended valves
or lines
Rupture disk must be
installed
10 ppmv from a required
control system
10 ppmv from a required
control system
Returned to system
Implementation of an
approved program
10 ppmv before discharge
No leakage (instrument
reading <10,000 ppmv)
Meet equipment specifica-
tions
No detectable emissions
No VHAP emissions
Meet equipment specifications
Meet equipment specifications
No requirement
Source test
Continuous monitor
Source test
Continuous monitor
No requirement
Approved testing program
Source test
Continuous monitor
Monthly leak detection and
repair program
No requirement
No requirement
No requirement
No requirement
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TABLE 3 (continued)
Source category
Equipment or
operations
Emission limit or
equipment standard
Monitoring requirements
Subpart V - Equipment
Leaks (Fugitive Emis-
sion Sources)
(continued)
Valves
Pressure-relief
devices in liquid
service and flanges
and other con-
nectors
Product accumulator
vessels or systems
designed to produce
or use >1,000 Mg/yr
benzene
Closed-vent systems
Control systems:
Vapor recovery
systems
Enclosed combustion
devices
Flares
Pumps, compressors,
pressure relief
devices, sampling
connection systems,
open-ended valves
or lines, valves,
flanges and other
No leakage (instrument read-
ing <10,000 ppmv)
No leakage (instrument read-
ing <10,000 ppmv)
Meet equipment specifications
No detectable emissions
Operate at 95% efficiency
Operate at 95% efficiency
No visible emissions
Same as Subpart J
Monthly leak detection and
repair program
No requirement
No requirement
No requirement
No requirement
No requirement
No requirement
Same as Subpart J
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TABLE 3 (continued)
Source category
Equipment or
operations
Emission limit or
equipment standard
Monitoring requirements
connectors, pro-
duct accumulator
vessels, and
control devices
Before opening any equipment for any reason, the quantity of vinyl chloride is to be reduced so that the
equipment contains no more than 2.0% by volume vinyl chloride or 0.0950 m3 (25 gal) of vinyl chloride,
whichever is larger, at standard temperature and pressure.
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are similar to those presented in Subsection 2.1.2. Table 3 also presents
the requirements for leak detection and the emission limits. It should be
noted that because vented discharges from NESHAP sources are controlled with
thermal or catalytic incineration devices, these sources are monitored with
temperature sensing devices. Appendix A contains the NESHAP1s that are
listed in Table 2.
2.3 INSTRUMENT SPECIFICATIONS
Limited portable VOC-detection instruments specifications are outlined in
Appendix A of 40 CFR 60. The reader is encouraged to review Reference Method
21 (Appendix A) to become familiar with the required instrument specifications.
It should be noted that no specifications concerning other types of instru-
ments such as thermocouples and static pressure gauges are currently available.
15
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SECTION 3
PORTABLE INSTRUMENT OPERATING PRINCIPLES
Various types of instruments are available for detecting organic vapors
during inspections. These monitors involve a variety of detectors that
operate on several different principles. Each detector has its own advantages,
disadvantages, and sensitivity.
Other types of portable equipment used during source inspections in-
clude temperature monitors, flow monitors, and pressure gauges. This equip-
ment is much smaller, less expensive, and easier to use than the portable VOC
detectors.
3.1 VOC DETECTORS
Several types of portable VOC detectors can be used either as screening
tools or to meet the requirements of EPA Method 21. These include:
o Flame ionization detector (FID)
o Photoionization (ultraviolet) detector (PID)
o Nondispersive infrared detector (NDIR)
o Catalytic combustion or hot wire detector.
The specifications of these instruments vary greatly with regard to
sensitivity, range, and responsiveness. Table 4 lists the most common moni-
tors currently in use and the associated detection principle, range, sensi-
tivity, and response time of each.
3.1.1 Flame Ionization Detector
In an FID, the sample is introduced into a hydrogen flame. A concentra-
tion of even 0.1 ppm of a hydrocarbon produces measurable ionization, which
is a function of the number of carbon ions present. A positively charged
collector surrounds the flame, and the ion current between the flame and the
collector is measured electronically. Pure hydrogen burning in air produces
16
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TABLE 4. MOST COMMON PORTABLE VOC DETECTION INSTRUMENTS'
Monitor
550, 551, 555
(AID, Inc.)
OVA 108, 128
Century
Systems, Inc.
(Foxboro)
PI-101
(HNu Systems,
Inc.)
TLV Sniffer
(Bacharach)
Ecolyzer 400
(Energetics
Science)
Mi ran 1A
(Foxboro)
Detection
principle
FID
FID .
PID
Catalytic
combustion
Catalytic
combustion
IR
Range, ppm
0-200,
0-2000,
0-10,000
0-10,
0-100,
0-1000
0-20,
0-200,
0-2000
0-500,
0-5000,
0-50,000
0-100%
LFL
ppm to %
Sensitivity
0.1 ppm at
0-200 ppm
0.2 ppm (Model 128)
0.5 ppm (Model 108)
1 ppm
2.0 ppm
1% LFLb
1 ppm
Response
time, s
5
2
2
5
15
1, 4, 10
and 40
Does not necessarily represent all portable monitors currently being sold.
Lower flammability limit.
very little ionization, so background effects are essentially masked by the
hydrogen flame. The calibrated output current is read on a panel meter or
chart recorder.
Organic compounds containing nitrogen, oxygen, or halogen atoms give a
reduced response when compared to compounds without these atoms. The FID
hydrocarbon analyzers are usually calibrated in terms of a gas such as methane
or hexane, and the output is read in parts per million of carbon measured as
methane or hexane.
Although nitrogen (Np), carbon monoxide (CO), carbon dioxide (COp), and
water vapor (H?0) do not produce significant interferences, condensed water
vapor can block the sample entry tube and cause erratic readings. Also, when
oxygen (Op) exceeds 4 percent, a significantly lower output reading can occur.
17
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The relative response of the FID to various organic compounds, including those
with attached oxygen, chlorine, and nitrogen atoms, varies from compound to
compound.
3.1.2 Photoionization Detectors
In the photoionization process, ultraviolet light ionizes a molecule as
follows: R + hv -> R + e", where R is the ionized species and hv represents
a photon with energy less than or equal to the ionization potential of the
molecule. Generally all species with an ionization potential less than the
ionization energy of the lamp are detected. Because the ionization poten-
tial of all major components of air (Ck, N2, CO, C02, and HLO) is greater
than the ionization energy of the lamps in general use, they are not detected.
The sensor consists of an argon-filled, ultraviolet (UV) light source
that emits photons. A chamber adjacent to the sensor contains a pair of
electrodes. When a positive potential is applied to one electrode, the field
that is created drives any ions formed by the absorption of UV light to the
collector electrode, where the current (proportional to the concentration) is
measured.
3.1.3 Nondispersive Infrared Detector
Nondispersive infrared (NDIR) spectrometry is a technique based on the
broadband absorption characteristics of certain gases. Infrared radiation is
typically directed through two separate absorption cells: a reference cell
and a sample cell. The sealed reference cell is filled with nonabsorbing gas,
such as nitrogen or argon. The sample cell is physically identical to the
reference cell and receives a continuous stream of the gas being analyzed.
When a particular hydrocarbon is present, the IR absorption is proportional
to the molecular concentration of that gas. The detector consists of a double
chamber separated by an impermeable diaphragm. Radiant energy passing through
the two absorption cells heats the two portions of the detector chamber dif-
ferentially. The pressure difference causes the diaphragm between the cells
in a capacitor to distend and vary. This variation in capacitance, which is
proportional to the concentration of the component of gas present, is mea-
sured electronically.
18
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The NDIR instruments are usually subject to Interference because other
gases (e.g., H20 and C02) absorb at the wavelength of the gas of interest.
Efforts to eliminate the interferences by use of reference cells or optical
filters are only partially successful. For hydrocarbon (HC) monitoring, the
detector is filled with one or several different hydrocarbons, which may be
different from the HC contained in the sample; this causes a disproportionate
response. Other sources of errors include gas leaks in the detector and
reference cells, inaccurate zero and span gases, nonlinear response, and
electronic drift.
3.1.4 Catalytic Combustion or Hot Wire Detector
The heat of combustion of a gas is sometimes used for quantitative
detection of that gas. Suffering the same limitation as thermal conductivity,
this method is nonspecific, and satisfactory results depend on sampling and
measurement conditions.
One type of thermal combustion cell uses a resistance bridge containing
arms that are heated filaments. The combustible gas is ignited in a gas cell
upon contact with a heated filament; the resulting heat release changes the
filament resistance, which is measured and related to the gas concentration.
Another combustion method uses catalytic heated filaments or oxidation
catalysts. Filament temperature change or resistance is measured and related
to gas concentrations.
3.2 THERMOCOUPLES
The temperature monitors most commonly used are direct-readout hand-held
thermocouples. The thermocouple is composed of two wires of dissimilar metals
that are joined at one end. When the joined end is heated, a voltage flow
can be observed (Seebeck effect). A voltmeter is attached to the thermocouple,
and the observed voltage is proportional to the measured temperature. A
portable thermocouple assembly consists of a shielded probe, a connecting
wire, and a voltmeter. The voltmeter may be a temperature conversion unit on
a multimeter or a dedicated direct readout temperature unit. The voltmeter
is battery-operated, small, and easily portable.
19
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3.3 STATIC PRESSURE GAUGES
Among the several different available static pressure gauges, the most
commonly used for this type of field work are the inclined manometer and the
diaphragm gauge. A pressure tap is necessary for use of a portable static
pressure gauge. The pressure tap basically consists of a small opening in
the wall of a duct, which can be fitted with a connection and a hose to make
pressure measurements. The tap should be far enough away from such distur-
bances as elbows and internal obstructions to make the effects of such distur-
4
bances negligible.
The appropriate side, positive or negative, of the manometer or pressure
gauge is connected by a rubber hose at the tap, and a pressure reading can be
taken. It is often advantageous to disconnect a permanent pressure gauge and
take a pressure reading at that point to compare it with the facility's in-
strumentation.
20
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SECTION 4
ESTABLISHING AN AGENCY PROGRAM FOR THE USE OF PORTABLE INSTRUMENTS
FOR MONITORING VOC AND AIR TOXICS SOURCES
The portable instruments used during VOC and air toxics source inspec-
tions require special care and attention to ensure that they provide re-
sults that are consistent with the agencies overall goal and objectives. A
well developed and organized program is necessary to ensure selection of the
proper instruments and adequate calibration procedures; the adoption of
written measurement and recordkeeping procedures; and the taking of sufficient
field notes during inspections. The purpose of this section is to help a
regulatory agency establish a complete program for the use of portable instru-
ments for VOC source inspections.
Factors to consider during the preparation of bid specifications include
the instrument performance requirements of the promulgated regulations and
the practical features that improve the instrument's reliability and make it
more convenient to use. Detailed information is necessary concerning the type
of laboratory and shop facilities that will be needed to support portable in-
spection instruments. These instruments should not be calibrated, maintained,
and stored in an office.
4.1 SELECTION OF THE NECESSARY TYPES OF INSTRUMENTS
Selection of the types of instruments needed for source evaluation is
based primarily on a review of the types of industrial facilities within the
agency's jurisdiction and an evaluation of the inspection requirements
inherent in the promulgated VOC regulations. Agencies should also determine
if it is possible to select instruments that can be used for future air toxic
control requirements as well as the already existing VOC regulations.
4.1.1 Organic Vapor Analyzers
Detector's Response--
One important criterion in the selection of organic vapor detectors is
the response of the instrument to the specific chemical or chemicals present
21
-------
in the gas stream. The abilities of the major classes of organic vapor
analyzers to detect different organic chemicals differ substantially. The
response factor, defined below, provides a convenient index of this property.
Response Factor = Actual Concentration/Instrument Observed Concentration
A response factor of 1.0 means that the instrument readout is identical
to the actual concentration of the chemical in the gas sample. As the
response factor increases, the instrument readout is proportionally less than
the actual concentration. If the regulatory limit is 10,000 ppmv (observed),
the use of an instrument with a response factor of 10 for the specific chemi-
cal(s) would allow an actual concentration of 100,000 ppmv. Conversely, the
use of an instrument with a response factor of 0.1 would indicate that the
regulatory limit of 10,000 ppmv had been exceeded when the actual concentra-
tion is only 1000 ppmv. It is desirable to select an instrument with response
factors as close as possible to 1.0 for the specific compounds of interest.
Unfortunately, instrument response factors can be complex functions of
numerous variables. The response factors depend on the chemical compound used
to calibrate the organic vapor detector and on the concentration of organic
vapor being analyzed. '6 Published response factors that specify the value
based on the instrument-determined concentration are preferred in the selec-
tion of an instrument because they are the most consistent with the regulatory
format.
Fugitive leaks often will involve mixtures of organic vapors. Work done
by Brown, Dubose, and Harris indicated that the response factor for a mixture
of two organic compounds falls between the individual response factors for
the compounds. This would suggest that the instrument offers no synergistic
phenomenon and that weighted average response factors could be used to approxi-
mate instrument response to a mixture.
Representatives of instrument manufacturing companies contacted as part
of this study generally believe that the response factors published by EPA
and by their companies are sufficiently accurate.19'21'39 Slight differences,
however, do exist between response factors determined by EPA and those reported
by instrument manufacturers. These differences could be due to differences
in the calibration procedures, the specific instrument model used in the work,
or the specific instrument itself. Many instrument manufacturers, however,
22
-------
believe that instrument-to-instrument variability in the response factors is
slight and that the values remain relatively stable over the life of the
19 21 39 40
instrument. ' ' ' Neither the EPA nor the instrument manufacturing
companies, however, have specifically studied instrument-to-instrument
variability or long-term response factor stability. One consulting firm has
recommended that users routinely redetermine the response factors rather than
24
relying on published values. There are some who believe that routine re-
determination of instrument-specific response factors by regulatory agencies
is unnecessary in most cases. The most recent response factor data published
by both EPA and the instrument manufacturers should be consulted before in-
struments are purchased. The response factor data compiled in Appendix B
should assist regulatory agencies in their evaluation of the general capa-
bilities of different styles of instruments. These data include a partial
listing of the response factors determined for the Foxboro OVA-108 and the
5 6
Bacharach TLV Sniffers. ' Limited response factor information concerning
photoionization analyzers and one infrared analyzer has been abstracted from
8 9
other sources. '
A review of the response factor data shown in Appendix B indicates that
a substantial difference exists among the four major categories of VOC in-
struments. The instruments capable of monitoring high concentrations of hydro-
carbon compounds, which make up many of the VOC emissions, are not as useful
for measuring some of the oxygenated and chlorinated organic compounds, which
represent many of the air toxic emissions. Thus, it may be impossible to re-
concile the needs of both the VOC and air toxics inspection programs by the
selection of a single type of instrument.
Because response factor data are currently very limited, agencies may
wish to use additional data in selecting organic vapor analyzers. In the
case of photoionization units, the ionization potentials of organic compounds
provide a qualitative index of the instrument's capability to detect the com-
pound. A summary of ionization potential data provided by an instrument manu-
facturer is provided in Appendix C. In reviewing these data, the agency
should note that an instrument often can detect compounds with ionization
potentials slightly above the rating of the lamp. For example, a compound
with an ionization potential of 10.5 eV could possibly be monitored with an
23
-------
instrument having a 10.0 eV lamp. Although the lamp's rating is based on
the wavelength of the most intense emission line, there are often less in-
tense emission lines at shorter wavelengths.
Range and Accuracy—
The ability of an instrument to measure 10,000 ppmv should be carefully
considered if the instrument will be used to determine compliance with EPA
Method 21 regulations. As indicated in Table 4, only a few of the currently
available units can operate at 10,000 ppmv or above. Other units can operate
at this concentration only by using dilution probes. Although dilution
probes can be used accurately, they can also be a large source of error.
Both changes in flow rate through the dilution probe and saturation of the
charcoal tubes used to remove organic vapors from the dilution air can lead
to large errors in the indicated organic vapor concentration. Dilution
probes also complicate calibration and field span checks. For these reasons,
they should be avoided whenever possible.
Generally, the instruments should have the desired accuracy at the con-
centration of interest. It should be noted that an accuracy of +5 percent
is required for Method 21 work.
Ease-of-Use--
Ease of use is an important instrument selection criterion because of
the conditions under which the field inspector must work. The instrument
must be as light as possible because the inspector must walk over relatively
large areas (in most facilities) to evaluate fugitive leaks from numerous
valves and other sources. In some cases, a moderate amount of climbing is also
necessary. After 4 to 6 hours, even a light instrument can seem uncomfortably
cumbersome.
Table 5 contains information concerning the portability of some of the
commercially available organic vapor instruments. As shown, the weights of
the units and the manner in which they are used differ substantially.
Generally, instruments equipped with shoulder straps are the most con-
venient to use for fugitive VOC leak surveys. The instrument readout on
the hand-held probe is very important, because the inspector immediately sees
when the probe has been placed in a very high VOC concentration. The hand-
held gauge also slightly reduces the time involved in leak surveys.
24
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TABLE 5. EASE-OF-USE OF ORGANIC VAPOR ANALYZERS
Instrument
manufacturer
Century (Foxboro)
108
Century (Foxboro)
128
Photovac 10S50
HNU PI-101
AID Model 585
AID Model 712
Barachach TLV
Ecolyzer 400
Miran 1A
Type
FID
FID
PID
PID
PID
FID
Cata-
lytic
Cata-
lytic
Infra-
red
Weight,
Ibs
13
13
26
9
8
14
5.5
8
12.5
Mode of use
Shoulder strap
Shoulder strap
Case with handle
Shoulder strap
Small case with
handle
Shoulder strap
Shoulder strap
Shoulder strap
Carrying handle
Other comments
Readout on probe
Readout on probe
Necessary to remove
cover to adjust range
Necessary to open case
at each measurement
site
Readout on probe
Necessary to set unit
down at each measure-
ment site
Intrinsic Safety—
All instruments used during field inspections of VOC source and air toxic
sources must be intrinsically safe if they are to be used in potentially
explosive atmospheres. Localized pockets of gas (and even particulates)
within the explosive range can result from fugitive leaks and malfunctioning
control devices. Intrinsic safety simply means that the instrument will not
provide a source of ignition for the explosive materials when the instrument
is used properly. Instrument designs are certified as intrinsically safe for
certain types of atmospheres by organizations such as the Factory Mutual Research
Corporation. Table 6 lists the types of atmospheres by safety classification.
The conditions can be further classified according to Groups A through G,
25
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TABLE 6. DEFINITIONS OF HAZARDOUS LOCATIONS IN ACCORDANCE WITH THE NATIONAL
ELECTRICAL CODE9
Classification
Description
Class I locations
Division 1
Division 2
Class II locations
Division 1
Division 2
Class III locations
Division 1
Division 2
Areas where volatile flammable liquids and flammable
gases are used and handled.
Class I areas where hazardous concentrations are
likely to occur in the course of normal operations.
Class I areas where hazardous concentrations are
probable only in the case of accidents or unusual
operating conditions.
Areas where combustible dust may be present.
Class II areas where combustible dust is likely to
be present in explosive or ignitable concentrations
in the course of normal operations.
Class II areas where hazardous concentrations of
combustible dust is probable only in the case of
accidents or unusual operating conditions.
Areas where easily ignited fibers and materials that
could result in combustible flyings are present.
Class III areas where easily ignited fibers and
materials are processed.
Class III areas where easily ignited fibers and
materials are stored or handled.
Sources: References 12 and 13.
which denote the type of flammable vapor or combustible dust that may be
present.
The large majority of the organic vapor analyzers are designed to be
instrinsically safe in Class 1 areas. Factory Mutual, however, has certified
only a few of the currently available commercial instruments to be intrinsically
safe. Table 7 lists the present status of commercial instruments.
It should be noted that the information presented in Table 7 could change
in the near future. At least one manufacturer has several applications pend-
14
ing concerning hazardous location approval.
26
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TABLE 7. INTRINSIC SAFETY RATINGS OF COMMERCIAL INSTRUMENTS, JANUARY 1986C
Instrument
manufacturer
Model
Atmosphere
Factory mutual
approved
Foxboro
Foxboro
Bacharach
AID, Inc.
AID, Inc.
HNU Systems, Inc.
OVA-108
OVA-128
TLVb
585
712
PI-101
Class I, Division 1
Class I, Division 1
Class I, Division 1 and 2
Class I, Division 2
Class I, Division 1
Class I, Division 2
Yes
Yes
Yes
No
No
No
Not a complete listing of commercial instruments.
bModel 0023-7356.
Other Considerations-
Several recent improvements have been made in probe design. As a result,
agencies should carefully evaluate the probes available with the organic vapor
analyzer models they are considering. By reviewing detailed drawings or
examining "loaner" probes, agencies can determine if the probe is susceptible
to leakage. Air infiltration through the probe has been a common problem in
the past. ' ' ' This problem has been especially severe on telescoping-
type extension probes.
Some older flame ionization analyzers have suffered hydrogen leaks due
to cold creep of the TEFLON washers used to seal part of the pressurized
hydrogen line. ' The hydrogen leak ignition problems reported in earlier
studies, however, may have been solved by redesigning the hydrogen line
19
fittings. Agencies should examine the hydrogen line design on any FID that
is being seriously considered for purchase to ensure that this will not be a
problem.
4.1.2 Thermocouples
It should be noted that currently none of the battery-powered thermo-
couples are designed as intrinsically safe for either Class I or Class II
atmospheres. Therefore, these instruments cannot be taken into or through
27
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areas where there is a possibility of encountering explosive mixtures of
organic vapor and/or dust. Conventional flashlights are also not intrinsically
safe, and they should be replaced by explosion-proof flashlights.
4.2 INSTRUMENT SPARE PARTS AND ACCESSORIES
Portable instruments for inspection of VOC sources and air toxic sources
are sophisticated units. Maintaining an available supply of certain accessory
spare parts and routine replacement parts will minimize unnecessary downtime
of these instruments and will help field inspectors to obtain high quality
data.
4.2.1 Battery Packs
All of the organic vapor analyzers require a rechargable battery pack
to operate the sample pump and the electrical components. Failure of these
battery packs is a common problems with these instruments.11'15'16 A re-
placement battery pack should be taken along on all field inspections in case
an unexpected failure should occur. A spare is also useful when field work
is being conducted during cold conditions, as such conditions reduce the
19
useful operating time.
A spare recharger is also necessary for the lead-acid gel battery packs
used in some types of flame ionization analyzers, as these batteries must be
recharged on an almost continuous basis to prevent loss of the charge. If a
deep discharge occurs, the battery pack cannot be recharged by the unit sup-
19
plied with the instrument. Thus, two rechargers are needed, one for the
original instrument battery pack and one for the backup battery pack.
Spare rechargers are also recommended for the nickel-cadmium (Ni-Cd)
battery packs commonly used in the photoionization instruments. Recent improve-
ments in battery rechargers have significantly reduced the possibility of
20
battery overcharge. Only these newer style units should be used if the
instrument has the Ni-Cd batteries.
A nonrechargable 9-volt battery similar to those used in radios, is
normally used in a thermocouple. As a result, a spare is recommended.
28
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4.2.2 Detectors
The photoionization analyzers and the catalytic combustion analyzers have
detectors that must be replaced after extended use. The inspectors should
17 21
take replacement detectors with them on field trips in case they are needed. '
For photoionization units, the key component is the ionization lamp
within the detector. Inspectors should take at least one spare lamp on all
field work in the event that one of the following may occur: the lamp is
damaged by the deposition of nonvolatile components on the lamp window, the
window is scratched during cleaning, the lamp is damaged by physical shock,
or the lamp simply wears out.
The detectors of catalytic combustion analyzers are composed of a coated
hot wire that is part of a Wheatstone bridge. Exposure to high concentra-
tions of organic vapor can cause excessive volatilization of the catalyst
21
from the wire surface. The sensor also can be damaged by the deposition of
nonvolatile, noncombustible material. For these reasons, at least two re-
placement sensors should be taken on field inspections.
4.2.3 Particulate Filters
All organic vapor analyzers are subject to damage by the deposition of
nonvolatile materials in the instrument probes and/or the instrument detectors.
Most commercially available units include some form of particulate filters
within the probes to collect this material. Several replacement filters should
be taken along with the instruments because the filters are easily blinded.
Most experienced instrument operators consider it prudent to use a glass
wool "Prefilter" in addition to the instrument filters to reduce further the
chances of particulate deposition inside the instruments. ' A small
section of plastic tubing with some glass wool is recommended for all organic
vapor analyzers. Care must be taken, however, to ensure that the filter does
not add excessive sample flow resistance.
4.3 LABORATORY AND SHOP SUPPORT FACILITIES
Because of their level of sophistication, organic vapor analyzers require
laboratory and instrument shop support facilities. Regulatory agency in-
spectors should not attempt to store and calibrate the instruments in their
29
-------
offices, as this practice can lead to significant safety problems and com-
plicate the routine maintenance of the instruments.
4.3.1 Storage of Compressed Gases
One of the primary purposes of the laboratory facility is to provide a
safe location for storage of the gas cylinders used to calibrate the organic
vapor analyzers. These facilities are able to secure the cylinders firmly so
they cannot be knocked over accidently. Accidents involving even small gas
cylinders in offices could have very serious consequences. Furthermore
laboratories can and should store the cylinders in areas that are properly
ventilated with exhaust hoods. Conversely, leaks of compressed gas in offices
can lead to localized high concentrations of gases such as hexane, benzene,
butadiene, and vinyl chloride, or even to localized pockets of explosive gas
mixtures. For these reasons, it is very important to store and use the cali-
bration cylinders, zero gas cylinders, and hydrogen cylinders (for flame
ionization analyzers) in properly designed laboratory facilities.
Another important consideration is that the exhaust from organic vapor
analyzers during calibration can be toxic. In the case of the photoionization
analyzers, most of the inlet calibration gas is exhausted because the instru-
ments are nondestructive. In the case of flame ionization detectors, however,
low concentrations of phosgene and hydrogen chloride can be emitted when
22
chlorinated hydrocarbons are used for calibration. Thus, the instrument
should be placed in a location where the exhaust is captured by an approved
hood and ventilation system.
4.3.2 Gas Flow Evaluation
Many of the organic vapor analyzers, especially the flame ionization
detectors, are sensitive to the sample gas flow rate. Routine confirmation
of proper flow rate is important, especially for those instruments that do not
include a flow sensor. Flow rates are normally measured by use of a rotameter
designed for flow rates between 0.5 and 5.0 liters per minute. The rotameter
should be calibrated against a soap bubble flow meter.
4.3.3 Electrical Diagnostic Equipment
The extent to which malfunctioning organic vapor analyzers can be ser-
viced by agency personnel is limited because the intrinsic safety of the
30
-------
instrument can be voided inadvertently. Nevertheless, qualified agency in-
strument technicians should be equipped to check such basic operating param-
eters as the lamp voltages of photoionization units and the battery output
voltages on all portable instruments.
4.3.4 Thermocouple Calibration Equipment
The thermocopule readout device and thermocouple probes should be cali-
brated at least twice a year. For convenience, the calibrations should be
performed in-house with a conventional tube furnace. The field instrument
and probes are compared against National Bureau of Standards (NBS) traceable
thermocouple probes.
4.3.5 Static Pressure Calibration Equipment
All diaphragm-type static pressure gauges must be calibrated on at least
a weekly basis. A relatively large U-tube manometer should be permanently
mounted in the agency laboratory for calibration of 0 to 10 inch W.C. and the
23
0 to 60 inch W.C. gauges. An inclined manometer is needed for calibration
of the 0 to 2 inch W.C. gauges.
4.3.6 Storage Space
Adequate space should be provided to store the instruments, the necessary
spare parts, and the routine calibration/maintenance records. The availa-
bility of convenient storage space removes the temptation to store the instru-
ments in the trunk of a car, where they could be damaged by excessive vibra-
tion and shock or by excessive heat. A checklist should be posted near the
stored units listing the spare parts that should be taken to jobsites to
ensure adequate instrument performance during the inspection.
Adequate working area should be provided for the inspectors to calibrate
and check-out the instruments before leaving for the field. The working area
must be large enough to accommodate a 20 to 30 liter TEDLAR bag, the instru-
ment, the gas cylinders, and any gas-blending equipment that may be necessary.
4.4 INSTRUMENT MAINTENANCE PROGRAM AND RECORDS
In most regulatory agencies, numerous individuals will use the portable
organic vapor analyzers, thermometers, and static pressure gauges, and it is
31
-------
unrealistic to expect all of them to be fully knowledgeable concerning instru-
ment calibration and repair. It is also unrealistic to ask each of them to
make independent determinations of organic vapor analyzer response factors or
other performance data obtained on an infrequent basis. Therefore, one or
two people should be assigned the responsibility for the overall maintenance
of the instruments. Persons skilled in instrument calibration and/or repair
are ideal for this assignment. They can make whatever nonroutine tests and
measurements are necessary to ensure that the monitors continue to perform
adequately. They can also instruct other agency personnel concerning the
proper way to replace filters, detectors, and battery packs, to operate the
unit; and to perform field span checks.
Only those persons assigned responsibility for the instruments should
make any routine repairs other than the replacement of detectors, photoioni-
zation lamps, battery packs and particulate filters, which can be replaced by
the inspector and the replacements noted in a log or report provided to the
person who has been assigned responsibility for the unit. This reduces the
chance of the intrinsic safety of an instrument being inadvertently bypassed
by an unqualified individual. The instruments should be returned to the
manufacturers for any nonroutine repairs.
Records should be maintained on each instrument including all routine
calibrations, any response factor determinations, and all repair notes.
Problems reported by field personnel should be briefly summarized in a chrono-
logical record. The file should contain at least one copy of each operating
manual and a list of all part numbers (if not included in the manual).
4.5 COSTS
4.5.1 Instruments and Accessories
Cost data for various organic vapor analyzers and other instruments have
been compiled to illustrate the capital and operating costs. These data are
presented simply to help regulatory agencies prepare realistic budgets. They
should not be used for comparison of different instruments, as each instrument
has different applications and capabilities.
The cost data are based on verbal quotes and published price lists pre-
pared by instrument manufacturers. The data were obtained in December 1985
32
-------
and were confirmed in January 1986. Cost data presented in earlier re-
?4. 7^\ ?fi
ports ' are generally out-of-date. All of the price information presented
in this section should be confirmed because price increases are expected in
the near future.
Also included are the costs of various accessories believed to be helpful
in ensuring high-quality field data and acceptable instrument availability.
Organic vapor analyzers require numerous accessories and spare parts and the
cost of these should be included in the original budgets.
The yearly operating cost estimates presented herein are based on the
use of the instrument for 50 days a year, 6 hours a day. It has been assumed
that laboratory calibration will be performed before any field work begins
and that field span checks will be performed at least twice a day. Costs
of calibration gases for the field span checks are based on the disposable-
type cylinders offered by several different suppliers.
The cost of the HNU PI-101, the Foxboro OVA 108, and the Bacharach TLV
Sniffers are presented in Tables 8, 9, and 10, respectively. The specified
costs apply to the intrinsically safe model, which is the only type that
regulatory agencies should use. The tables represent the kind of informa-
tion that should be compiled regardless of which type of instrument or model
is being considered.
The relatively large fraction of the basic analyzer cost represented by
the accessories reflects the high cost of spare battery packs and rechargers
needed because of the vulnerability of intrinsically safe battery packs when
not cared for properly. When a battery pack fails, getting a replacement
could take anywhere from 1 week to several months; therefore, having spare
battery packs and chargers is a necessary expense.
Another major component that drives the accessory costs up is the
detector cells. The detector in each of the instruments has one or more
sensitive components. Exposure to high temperature, moisture, particulates,
or very high organic vapor concentrations can cause premature failure.
Regulatory agencies that use these instruments for a variety of purposes
ranging from leak surveys to roof monitor emission surveys are likely to
damage the detectors occasionally regardless of how carefully the inspectors
conduct the field work.
33
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TABLE 8. ESTIMATED COSTS OF HNU MODEL PI-101 PHOTOIONIZATION ANALYZER
Equipment and supplies
Cost. $°
Analyzer, Model 81-IS-101-100 (intrinsically
safe), with corrosion-resistant detector
chamber
• b
Accessories
Spare 10.2 eV lamp
Span gas cylinder regulator
Instrument carrying case
Spare battery pack
Spare recharger
Spare probe extension
Spare fan
5245
300
99
250
200
360
30
240
Subtotal 1479
Expendable supplies
Calibration gas cylinder (3 cylinders
per year minimum)
Particulate filters
Cleaning compound ($24 per unit,
1 unit required)
Replacement lamp
Yearly factory service
Cost/year, $
150
20
25
300
Subtotal
300'
795
aAll cost data provided by HNU Systems, Inc.27'28
Necessary accessories and supplies specified by Richards Engineering.
C0oes not include $40 shipping charges.
34
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TABLE 9. ESTIMATED COSTS FOR FOXBORO MODEL 108 FID TYPE ORGANIC
VAPOR ANALYZER3
Equipment and supplies
Cost, $
Analyzer, with GC option
Accessories
Spare battery pack
Spare recharger
Spare probe
Recorder (intrinsically safe)
Ignitors
Pump valves (package of 10)
Pump diaphragm
Mixer/burner assemblies
Washers, TEFLON (package of 12)
Washers, brass (package of 12)
Calibration kit regulator and case
5200
460
427
40
460
32
15
20
200
18
15
90
Subtotal 1777
Service and supplies
Yearly factory service
Chart paper ($60/6 rolls, 6 rolls/year)
Flame arresters (package of 10)
Calibration gas for field span checks
(4 at $63)
Factor determinations (2 cylinders at $82 each)
Hydrogen gas (< 0.5 ppm HC)
Cost/year, $
110'
60
9
252
164
60
Subtotal
736
a 29
Instrument related cost.data provided by Foxboro. Calibration gas and
hydrogen gas cost data. JU"ji""
Necessary accessories and supplies specified by Richards Engineering.
s+
Does not include $40 shipping charges.
35
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TABLE 10. ESTIMATED COSTS FOR BACHARACH TLV SNIFFER
Equipment and supplies
Cost, $
Analyzer, Model 53-7-TLV
Accessories
In-line filter and water trap assembly
Battery charger
Spare battery pack
Spare detector cell
Calibration kit (regulator, case and 2
cylinders)
Subtotal
1580
62
56
392
115
212
837
Service and supplies
Factory servicing
Calibration gas for field span checks
(4 at $63)
Calibration gases for office calibrations
and response factor checks (2 cylinders
at $73)
Replacement detector
Cost/year, $
100C
252
146
115
Subtotal 613
a 33
Instrument related cost data provided by Bacharach, Inc. Calibration
gas data.30'31'32
Necessary accessories and supplies specified by Richards Engineering.
C0oes not include $40 shipping charges.
36
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TABLE 11. ESTIMATED COSTS FOR OMEGA PORTABLE THERMOMETER1
Equipment and supplies
Cost, $
Analyzer, Model 871
• b
Accessories
Beaded probes, 6 feet (2 probes)
Carrying case
Subtotal
225.00
51.20
10.00
61.20
Service and supplies
Replacement batteries (5 at $3 each)
Calibration (semiannual at $50 each)
Cost/year, $
15.00
100.00
Subtotal
115.00
3 34
Cost data provided by Omega Engineering, Inc.
Necessary accessories and supplies specified by Richards Engineering.
The yearly operating cost of each instrument includes a fee for factory
service. This is considered a desirable precaution because the instruments
are used for compliance determination and because only limited repair/adjust-
ment of intrinsically safe instruments should be attempted by agency personnel.
One of the main yearly operating costs is for calibration gases (certified
to plus or minus 2%) shipped in disposable cylinders. Assuming each field
span check requires 1 to 2 minutes and the instrument draws 2 liters per
minute, the average disposable cylinder will be adequate for only 10 to 20
measurements (assuming 40 liters of compressed gas). At a rate of approxi-
30 31 32
mately $70 per replacement cylinder ' ' each span check would cost be-
tween $3.50 and $7.00. Although that is not a high price to ensure high-
quality data, some agencies may wish to investigate less expensive alternatives,
One alternative is a gas-transfer system. With this approach, calibration
gas would be supplied by the same large cylinder used for the laboratory
37
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calibrations and be transported by means of a standard sampling cylinder.
The total cost of the components of the sample cylinder system would be $300
to $500. ' This includes a 1-liter, high-pressure, stainless steel sam-
pling cylinder with needle valves, a 10-liter TEDLAR bag, a carrying case,
and a regulator. The uncertainty in the cost estimate is due to the lack of
available cost data concerning regulators to transfer gas from a large cylinder
to a sample cylinder. With the sample cylinder approach, the cost of the
calibration gas itself is essentially negligible because sufficient gas would
be available from the main laboratory cylinder, which should be purchased
once a year. Whereas the initial cost is moderately high, the yearly cost
is quite low because the cost of disposable cylinders is eliminated. Another
advantage is that the sampling cylinder would only have to be pressurized to
approximately 325 psig to provide adequate gas for two span checks per day.
This is lower than the 1000 psig used in some types of disposable cylinders.
Additional work is necessary to determine if the transfer approach is a safe
and economical alternative to the use of disposable cylinders.
The costs of the thermocouple thermometer, shown in Table 11, include
the cost of semiannual recalibration against NBS-traceable thermocouples.
Although this is a relatively simple procedure, it is assumed that regulatory
agencies will not be equipped to perform this calibration. Therefore, the
cost for outside calibration has been listed.
The cost of static pressure gauges ranges from $25 to $50 apiece, de-
pending on the range of the unit and the manufacturer. Although no
accessories or supplies are generally necessary to maintain these instruments,
some attrition of the units can be expected if they are treated especially
roughly.
4.5.2 General Equipment
Certain basic equipment is necessary to support the instruments used for
inspections of VOC and air toxics sources. The cost for this equipment is
presented in Table 12. All of the equipment is used and stored in an instru-
ment laboratory or an instrument shop. The general laboratory equipment is
used primarily for calibration of the organic vapor analyzers and for the
routine determination of instrument-specific response factors.
38
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TABLE 12. GENERAL EQUIPMENT COSTS
Item
20-liter TEDLAR bags
Bag evacuation pump
Cylinder gas regulators
Rotameters, stainless steel
with needle valve and
baseplate
Soap bubble flow meter
Cylinder brackets
TOTAL
Quantity
2
1
2
2
1
2
Cost/unit,
$
22
250
198
123
80
27
Total cost,
$
44
250
396
246
80
54
1070
Reference
35
35
30
36
30
4.6 PREPARING BID SPECIFICATIONS
Each type of organic vapor analyzer and thermometer is produced by
several different manufacturers. Many of the instrument models offered by the
manufacturers come with different options that are tailored to certain appli-
cations. Because of the diversity of commercially available instruments, the
bid specifications must be prepared carefully.
An instrument that is to be used for VOC leak surveys must meet the EPA
Reference Method 21 specifications summarized earlier in Section 3 and
presented in Appendix A. An important performance criterion specified is
that the readability of the meter scale must be to plus or minus 5 percent of
the leak definition concentration, which is 10,000 ppmv in certain industries.
To reach this concentration, some instruments must include a dilution assembly.
Another important criterion is that the instrument be intrinsically safe for
Class I, Division 1 and 2 environments. If a recorder is specified, it also
should be intrinsically safe (some are not).
The specific organic chemicals that will be monitored should be identified
before bids are solicited. Instruments have considerably different capabili-
ties, and only those with reasonable response factors for the specific chemi-
cals of interest should be used.
39
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The list of accessories and spare parts should be used along with infor-
mation supplied by the manufacturers on spare parts to determine those that
are necessary. Including these items on the bid list will facilitate a more
complete evaluation of the total cost of the different instruments.
40
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SECTION 5
INSTRUMENT CALIBRATION AND EVALUATION
Instruments used to determine compliance of industrial facilities must be
accurately calibrated on a routine basis. The calibration precision tests,
response time, and response factor tests also should be performed to confirm
that the instruments are operating properly for the specific application(s).
This section presents various calibration and instrument evaluation options
available to regulatory agencies that are establishing an instrument program
for VOC and air toxics sources.
5.1 INSTRUMENT CALIBRATION REQUIREMENTS AND PROCEDURES
5.1.1 VOC Analyzers
Calibration Procedures--
Calibration requirements for VOC instrumentation are specified in EPA
Method 21 and in the specific NSPS applicable to sources of fugitive VOC emis-
sions. The requirements pertaining to calibration are briefly summarized
here, and the complete Method 21 regulations are presented in Appendix A.
o The instruments should be calibrated daily.
o The gas concentration used for calibration should be close to the
leak definition concentration.
o The calibrant gas should be either methane or hexane.
o A calibration precision test should be conducted every month.
- o If gas blending is used to prepare gas standards, it should
provide a known concentration with an accuracy of +_ 2 percent.
The daily calibration requirement specified in Method 21 and in the vari-
ous NSPS gives individual instrument operators some flexibility. The calibra-
tion could consist of a multipoint calibration in the lab, or it could be a
•37
single-point "span check."
41
-------
Neither Method 21 nor the applicable NSPS specifies where the calibration
takes place. Obviously it would be simpler to conduct the calibration test in
the agency laboratory rather than after arrival at the plant being inspected;
however, the calibration could conceivably shift sufficiently to affect the
accuracy of the leak detection measurements. The degree of possible shift has
not been documented for the various commercially available instruments.
Although a survey of several major instrument manufacturers indicated that most
iQ 01 op on
believe that the units are "calibration stable," ''' no distinct study
has been conducted to demonstrate confidence in the calibration after the
instrument has been subjected to vibration during transit. Because of the
suspected potential for calibration shifts in all of the organic vapor analyzer
types, one should consider conducting at least a single-point span check after
the instrument arrives onsite. This concern is shared by several consul-
tants, ' an EPA engineer involved in the development of Method 21 and by
19 "38 40
a number of instrument manufacturers' representatives. Chehaske has
recommended that a span test be run at a midpoint of the day and at the con-
clusion of the field work.
Although the span checks discussed above would in most cases qualify as
the daily calibrations required by the NSPS; a separate calibration test for
organic vapor analyzers should be conducted whenever possible. Calibrations
performed in the regulatory agency laboratory as compared to calibrations that
are conducted in the field are conducted under more controlled conditions
because uniform day-to-day calibration gas temperatures and calibration gas
flow rates can be maintained in the laboratory. Furthermore, the initial
calibration test provides an excellent opportunity to confirm that the entire
instrument system is working properly before it is taken into the field. The
laboratory calibration data should be carefully recorded in the instrument
calibration/maintenance notebook discussed in Section 4, and this calibration
should be considered as the official calibration required by the regulations.
The laboratory calibration is best performed by the personnel assigned
primary responsibility for the maintenance and testing of all the agency
organic vapor analyzers. This ensures the use of proper and consistent pro-
cedures. If instrument problems are identified, the instrument can either be
repaired or the field inspector can be issued another unit that is operating
properly.
42
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Laboratory Calibrations--
As specified in the EPA-promulgated NSPS, the instruments used in accord-
ance with Method 21 must be calibrated by using either methane or hexane at
concentrations that are close to the leak-detection limits. In most cases,
the leak-detection limit is 10,000 ppmv, however, for certain sources, it is
500 ppmv above the background levels.
Methane-in-air is generally the preferred calibrant gas for the high
41
concentration range. A hexane-in-air concentration of 10,000 ppmv should
not be prepared because it is too close to the lower explosive limit. Also,
some hexane can condense on the calibration bag surfaces at this high concen-
tration. If hexane-in-air calibrations are necessary, the chosen concentra-
tion should be a compromise between the need for adequate calibration of leak-
detection levels and the practical safety and reproducibility problems inherent
in the use of hexane. The EPA has taken the position that the choice of cali-
brant gas does not affect the ability of instruments to detect fugitive leaks.
Some VOC instruments, such as photoionization and infrared instruments,
do not respond to methane (Section 3). With these units, a different cali-
bration gas should be used. If the inspection is concerned primarily with
one specific organic compound (e.g., hexane), that compound can be used for
calibration. In other cases, a calibration gas that adequately represents the
expected mixture of organic compounds that could be leaking from the source
should be used. The calibration gases recommended by the instrument manufac-
turers are shown in Table 13 as a general guide to inspectors.
TABLE 13. RECOMMENDED CALIBRATION GASES FOR ROUTINE INSTRUMENT SERVICE
41
Type of
instrument
FID
FID
PID
Catalytic
combustion
Manufacturer
Foxboro
HNU Systems, Inc.
AID Inc.
Bacharach
Calibration
gas
Methane
Benzene
Benzene
Hexane
Reference
19
20
38
43
43
-------
The calibration procedures for each instrument model are specified in the
instruction manuals. Material presented in this section is intended to
emphasize the importance of certain calibration procedures discussed in these
various instruction manuals.
Regardless of the type of VOC instrument, the flow rate of the gas during
calibration should be approximately equal to the flow rate during normal use
of the instrument, as flow rate influences the measured concentration.
Proper flow rate is very important for the FID instruments.
The two main calibration techniques that can be used are 1) commercially
prepared calibration gas mixtures or 2) blended calibration gas mixtures. The
commercially prepared calibration mixtures are more convenient, but they are
slightly more expensive than the calibration mixtures blended onsite. When
commercially prepared mixtures are used, a large cylinder containing a certi-
fied concentration of calibration gas (balance of gas mixture is air) is used
to fill a TEDLAR bag. The instrument simply withdraws a gas sample from the
bag at a rate of 0.5 to 3.0 liters a minute, depending on the normal sampling
rate. The estimated time required for the calibration is shown in Table 14.
TABLE 14. CALIBRATION TIME REQUIREMENTS WHEN
USING COMMERCIALLY PREPARED CALIBRATION GASES
Activity
Time required,
minutes
Set up instrument
Instrument warmup and calibration assembly setup
Flush sample bags
Fill bags with calibration gas and with zero air
Reset instrument
Record results in notebook or on logsheet
Total
2
10
5
2
5
_2
26
Obtaining the desired calibration gas mixture in commercially prepared
cylinders is sometimes impractical. In such cases, the mixture can be pre-
pared by blending the calibration compound with hydrocarbon-free air in a
large TEDLAR or TEFLON bag. This is a much more time-consuming procedure.
44
-------
g
For example, the specific steps in the procedures used by Menzies and Fasano
are as follows:
1. Flush and evacuate bag three times with hydrocarbon-free air.
2. Fill bag with hydrocarbon-free air.
3. Inject a known volume of test compound into the bag.
4. Permit at least 1 hour of equilibration to ensure adequate evapora-
tion (if sample is liquid) and mixing.
5. Draw gas sample from the bag.
Menzies and Fasano prepared the hydrocarbon-free air by passing compressed air
through silica gel (for air drying), charcoal, and a high efficiency filter.
As long as the charcoal bed is not saturated with water and/or organic vapor,
it should adequately remove organic vapor. Charcoal beds do not remove
methane, however. Menzies and Fasano metered the hydrocarbon-free air into
the bag by using a rotameter. Presumably, they used precision rotameters or
other accurate gas flow monitors to achieve a known concentration within the
required accuracy of +_ 2 percent. They injected the calibration compound (a
liquid in their work) into the bag with a microliter syringe.
Calibration time requirements can be high. Menzies and Fasano recommended
an equilibration time of 1 hour to inject the liquid into the gas. Even when
a calibration gas is introduced into a bag, the equilibration time should be
between 15 and 30 minutes. Additional time is required to flush the bags
several times with VOC-free air. Time requirements for a bag sample calibra-
tion are summarized in Table 15.
Because of the lengthy calibration time required by this approach, it
would be especially helpful to have an instrument specialist conduct the pro-
cedure. This person could calibrate several instruments simultaneously, as
much of the time is spent in 1) waiting for the instrument to warmup, 2) wait-
ing for the bag evacuation pump to empty the TEDLAR bag, and 3) waiting for
the gas sample to equilibrate in the bag.
When charcoal beds are used to provide the VOC-free air, a routine check
should be made to determine breakthrough of organic compounds. This is done
by passing a low-hydrocarbon-concentration gas stream (approximately 10 to 50
ppmv) through the bed for a period of 5 to 10 minutes. If the bed has not
45
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TABLE 15. CALIBRATION TIME REQUIREMENTS WHEN CALIBRATION
GAS MIXTURES ARE BLENDED
Activity
Time required,
minutes
Setup instrument
Instrument warmup and calibration assembly setup
Empty and flush bags
Inject calibration compound and equilibrate
Set calibration and zero
Record results in notebook or on logsheet
Total
2
15
10
30 to 60
5
2
75 to 105
become saturated, the outlet hydrocarbon concentration should be low. Obvious-
ly, methane should not be used as the hydrocarbon because charcoal is ineffec-
tive in adsorbing methane.
Field Span Check Procedures--
The following are some of the various ways to calibrate the portable
instrument onsite:
o Use large pressurized gas cylinders transported to inspection sites.
o Use certified gas cylinders provided by the source being inspected.
o Use disposable gas cylinders with the appropriate gas composition
and concentration.
o Use a gas sampling cylinder with a gas blending system.
Transporting large pressurized gas cylinders is generally impracticable
because most agencies do not have the vehicles necessary for this purpose.
It is not safe to transport unsecured, pressurized gas cylinders in personal
or State-owned cars. Furthermore, there are specific Department of Transpor-
tation (DOT) regulatons governing the shipping of compressed gases.
Using the source's gas cylinders is certainly the least expensive approach
for a regulatory agency; however, the appropriate gas cylinders are not always
available. Also, the use of the source's cylinders prevents the agency from
46
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making a completely independent assessment of the VOC fugitive leaks and from
evaluating the adequacy of the plant's leak-detection program.
Using disposable cylinders of certified calibration gas mixtures is rela-
tively simple because no onsite blending is necessary and the cylinders are
easily transported. The calibration gas mixture may be fed to the instrument
directly by using a preset regulator that provides constant gas flow and pres-
sure; or the gas can be fed into a TEDLAR or TEFLON bag, from which it is
drawn into the portable instrument.
A third approach involves the use of a stainless steel gas sample cylinder
with a small TEDLAR sample bag. A small quantity of calibration gas is drawn
from a large cylinder of certified gas mixture (at the agency's main labora-
tory) into the small transportable gas sample cylinder. The calibration gas
is kept at a relatively low pressure to minimize safety problems during trans-
port of the material to the jobsite. The compressed gas is transferred to the
TEDLAR bag through a regulator and needle valve. At a pressure of 325 psig,
a 1 liter sample cylinder should provide enough span check gas for two field
checks. Zero air can be supplied by drawing ambient air through a small char-
coal filter. This approach is very inexpensive because the agency is using
small quantities of the certified calibration gas mixture from the main cylin-
der at the laboratory and they are not purchasing any disposable cylinders.
Some additional development work on this simple approach is necessary to
ensure that a regulator is available to transfer the gas from the main cylin-
der to the sample cylinder at pressures reaching several hundred psig. Most
regulators have a delivery pressure limit of 100 psig.30'31 It is also neces-
sary to confirm that the compressed gas can be transferred safely. It should
be noted, however, that this is the same approach used to fill the hydrogen
fuel cylinders on the flame ionization analyzers. Therefore, an approach of
this type should be feasible.
Relatively little time is required for the span checks when portable
cylinders of certified gas mixtures or transfer gas sample cylinders are used.
The time required for various activities is indicated in Table 16. It should
be noted that the instrument warmup must be done anyway, therefore this time
should not be "charged" against the span check. The overall time commitment
to the field span checks is not excessive when one considers the clear indica-
tion of organic vapor analyzer performance that these checks provide.
47
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TABLE 16. TIME REQUIRED FOR FIELD SPAN CHECKS
Activity
Time required,
minutes
Initial span check
Assemble and leak-check instrument
Warmup instrument and assembly of span check
equipment
Monitor span check gas
Record results in field notes
Subtotal
Midday span check
Return to location of span check assembly
Fill bag/start span check system
Monitor span check gas
Record results in field notes
Subtotal
Final span check
Fill bag/start span check
Monitor span check gas
Record results in field notes
Empty bag and pack span check equipment
Subtotal
10
2
__2
18
15
4
2
_2
23
4
2
2
_4
12
The field span check should be performed as far away as possible from
potential sources of fugitive VOC. It should also be performed in areas
where there are no large AC motors or other equipment that generate strong
electrical fields, as such equipment can have an adverse effect on certain
19
types of instruments (e.g., photoionization analyzers). The charcoal filter
used in the "clean air" supply should be routinely regenerated to avoid the
possibility of saturation. The charcoal filter should be checked occasionally
for saturation by supplying a moderate, known concentration of VOC and then
checking the measured exit concentration after several minutes.
Data concerning the span checks should be recorded in the inspector's
field notes. This will demonstrate that the specific unit operated properly
during the period in which compliance information was obtained at the
48
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inspection site. If gauges are provided with the instrument, the field in-
spector also should occasionally note the instrument sample gas flow rate.
5.1.2 Thermocouples
Thermocouples may be tested in several ways. The simplest method for
testing is checking a thermocouple in an ice bath and in boiling distilled
water. There are electronic "ice point" reference circuits commercially
available to check thermocouple operation. There also is an isothermal zone
box test equipment to test the thermocouple in a different range. There are
o
several suggestions for thermocouple operation. These include:
1. Use the largest wire possible that will not shunt heat away from
the measurement area
2. Avoid mechanical stress and vibration that could strain the wires
3. Avoid steep temperature gradients
4. Use the thermocouple wire well within its temperature rating
5. Use the proper sheathing materials in hostile environments.
5.2 ROUTINE LABORATORY EVALUATION OF INSTRUMENT PERFORMANCE
Routine laboratory evaluation of instrument performance must be con-
ducted. This evaluation includes determination of response factors, deter-
mination of response time, determination of instrument sample flow rates, and
calibration precision tests.
5.2.1 Determination of Response Factors
When published response factors for the organic compounds being monitored
are much greater than 1 (approaching 10) or much smaller than 1 (approaching
0.1), however, it would be prudent to measure the response factor for these
specific compounds. A response factor of 10 is the maximum allowed by Method
21, which means that the meter response was 10,000 ppmv when the actual con-
centration was 100,000 ppmv. Although Method 21 does not specify a lower
limit to the response factor, a response factor value of 0.1 means the observed
concentration is 10,000 ppmv when the actual concentration is only 1,000 ppmv.
The general procedure for measuring the response factor is presented in Method
21 (Appendix A).
49
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5.2.2 Determination of Response Time
The response time of the organic vapor analyzer is an important operating
variable. A decrease in instrument response time due either to leakage down-
stream of the pump or to increased flow resistance through instrument probes
and filters can slow down the field work.
For compliance with Method 21 specifications, the response time should
be checked before initially using the instruments in the field and whenever
the sample flow system has been changed. Agency personnel should conduct this
test more frequently, however, to confirm that no leakage of sample air has
occurred downstream of the pump. The use of soap solution is the only alterna-
18
tive to identify sample gas leakage after the instrument pump, and it is
difficult to apply and observe soap solution in the cramped areas around the
instrument pumps. Instructions for conducting response factor tests are
included in Section 4.4.3 of Method 21.
5.2.3 Determination of Instrument Sample Flow Rate
For organic vapor analyzers, especially those without flow monitors, the
sample flow rate should be measured on a routine schedule. A calibrated rota-
meter or other flow sensor should be used to determine the flow rate when the
typical particulate filters, prefilters, and other flow restrictions are in
place. If an instrument rotameter is used, its adequacy should be checked.
The fact that instrument response is relatively insensitive to sample
flow rate (i.e., photoionization analyzers) does not eliminate concern over
proper flow rate. The tip of the sensor probe operates much like a small
hood, and reductions in sample flow rate reduce the effectiveness of pollutant
capture. Furthermore, if the probe is not oriented correctly, the "high"
pressure organic vapor plume acts like a strong cross-draft across the probe
inlet. For these reasons, maximum capture effectiveness is essential, and
reduced sample flow rates should be of concern regardless of the type of
organic vapor analyzer used.
5.2.4 Calibration Precision Tests
Calibration precision tests must be made before the analyzer is placed in
operation and at 3-month intervals thereafter. The general procedures are
discussed in Section 4.4.2 of Method 21. As with the other instrument
50
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evaluation procedures, this test is best performed by instrument specialists
who are assigned responsibility for routine calibration and maintenance of
all the agency's portable instruments (discussed in Section 4.4 of this
manual).
5.3 ROUTINE FIELD-ORIENTED EVALUATIONS OF INSTRUMENT CONDITIONS AND PERFORMANCE
Several instrument performance checks should be made before the inspector
leaves for the jobsite and during the routine screening of possible fugitive
VOC sources. The field-check procedures are in addition to, not a replacement
for, the calibration procedures discussed earlier. The daily calibration, the
field span checks, and the routine field performance checks are necessary to
confirm that the instrument is operating properly. Preferably, the initial
instrument checks should be made by the regulatory agency's instrument specia-
list assigned responsibility for the monitors. Brief notes concerning each
day's initial instrument checks should be included in the main instrument
evaluation/maintenance notebook kept in the instrument laboratory. The inspec-
tors make the field checks by using the instruments at the jobsite and docu-
mentation of these field checks should be part of the inspectors' field notes.
5.3.1 Initial Instrument Checks
It is very important that a few simple instrument checks be made before
the inspector leaves for the jobsite. The appropriate field checks for each
instrument can be found in the instruction manual supplied by the instrument
manufacturer. The following common factors, however, should be checked re-
gardless of the type of instrument:
o Leak checks including integrity of sample line and adequacy of
pump operation
o Probe condition
o Battery pack status
o Detector condition
o Spare parts and supplies.
All of these checks can be made in a period of 5 to 15 minutes. Repairs
to the detectors, batteries, and probes usually can be accomplished quickly if
51
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a set of spare parts is kept on hand. Some of the checks that should be made
before field work is begun are discussed in the following subsections.
Leak Checks--
To leak check the probes on units with flow meters, the probe outlet
should be plugged for 1 to 2 seconds while the sample pump is running. If
the sample flow rate drops to zero, there are no significant leaks in the en-
tire sampling line. If any detectable sample flow rate is noted, further
leak checks will be necessary to prevent dilution of the VOC sample gas during
screening tests. The leak checks involve a step-by-step disassembly of the
probe/sample line starting at the probe inlet and working back toward the
instrument. At each step, the probe/sample line is briefly plugged to deter-
mine if inleakage is still occurring at an upstream location. Once the site
of leakage has been determined, the probe/sample line is repaired and reassem-
bled. To confirm that the probe/sample line is now free of air infiltration,
the probe is again briefly plugged at the inlet to demonstrate that the sample
flow rate drops to zero.
When leaks are detected, there is sometimes a tendency to overtighten
the fittings, especially those between the instrument body and the end of the
sample line. With some types of fittings (e.g., Swagelok fittings) over
tightening can damage the fitting and even lead to persistent leaks.38
Units that do not have flow monitors should be leak-tested by installing
a rotameter on the sample line as close as possible to the inlet to the instru-
ment body. The leak-testing procedure described above can then be followed.
Also, the sound of the pump should be noted, as this provides one qualitative
means of identifying pluggage. It should be noted, however, that pump noise
is useless for identification of probe leakage because the pump continues to
receive air due to the infiltration.
One report states that the catalytic combustion units should not be leak-
24
tested by plugging the probe. Short-term loss of sample flow would reportedly
lead to high detector temperatures. One manufacturer, however, reports that
the detector used on their instrument is the same as the detector used on a
diffusion-controlled sampler and that the short-term loss of sample flow would
21
not be a significant problem.
52
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When more than one probe can be attached to the instrument body, each
probe should be tested. Only those that can be sealed properly should be
packed for field use.
Probe Condition—
The probes for some instruments can contain a number of independent com-
ponents, especially those that dilute the sample before analysis. The physi-
cal condition of the probe should be visually-checked before use". These checks
include, but are not limited to:
o Presence of any organic deposits on the inside of the probe
o Presence of clean particulate filter in the probe
o Condition of orifice(s) used to control dilution air flow into
the sample probe
o Condition of sealing "0" ring or other sealing assembly used to
prevent inadvertent dilution of sample flow.
Any deposits found should be removed, or a different probe should be used.
Cleaning instructions can be found in the manufacturers' operating manuals.
Generally, the probes are cleaned with acetone and then carefully purged of
19
any acetone vapor before assembly.
Battery Pack Status Checks-
Checking the battery pack is particularly important because it can be a
source of frequent problems. The battery pack condition is normally checked
by simply switching the instrument to the "Battery Check" position and observ-
ing the dial setting. If the battery appears at all weak, a new battery pack
should be installed. Most batteries fail because they have not been recharged
sufficiently.
The Ni-Cd batteries, used in many photoionization, catalytic, and
infrared instruments, must be charged for 8 to 12 hours for each 8 hours of
operation. These batteries are very vulnerable to overcharging. Recent
improvements in the Ni-Cd battery chargers, however, have substantially
38
reduced the chance of overcharging. Despite a common misconception, the
lead acid-gel batteries commonly used in FID instruments are not subject to
overcharging, and they should be left on the battery pack recharger whenever
1 Q
the instrument is not in use.
53
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During cold weather, weak batteries will operate for only a short period.
In fact, if the unit is to be operated in cold conditions for most of the
inspection day, it would be helpful to bring a second battery pack along so
19
the battery pack can be replaced at midday.
Detector Condition--
Each of the instruments includes a key component within the VOC detector.
Rather than an initial calibration (recommended earlier in Section 5.1), some
inspectors check the detector status by briefly monitoring automobile exhaust.
This is not generally advisable because condensable organic compounds and par-
ticulate matter can deposit in the probe, partially plug the filters, and even
damage the detector. If a qualitative response test is desired, an organic
vapor source, such as a cigarette lighter (do not take into plants to be
inspected), certain marking implements, liquid paper thinner, or a small sample
bag should be used. A complete calibration is preferred over these qualitative
response checks.
The flame ionization instruments are checked by depressing the ignitor
button for several seconds. If the unit will not ignite after repeated attempts,
there may be problems with the batteries, ignitor, or hydrogen supply. Most
of these problems cannot be solved immediately; therefore, other instruments
will have to be used until the repairs are completed. Hydrogen leak problems
in
are much less prevalent with newer instruments. Failure of the catalytic
units to respond to organic vapor is often due to failure of the main detector
cell, an easily replaced component.
Spare Parts and Supplies—
Most of the instruments used on VOC inspections are sophisticated instru-
ments rather than simple "off-the-shelf" items. Each requires some spare parts
and supplies to ensure that the inspection is not terminated prematurely. Table
17 provides a partial listing of the recommended spare parts for each general
type of instrument. All of the parts listed should be carried to the jobsite.
Other spare parts (discussed in Section 4) should be left at the instrument
laboratory/shop. Further information is available in the manufacturers' operat-
ing manuals and from the manufacturers' representatives.
54
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TABLE 17. PARTIAL LISTING OF RECOMMENDED ONSITE SPARE PARTS
AND SUPPLIES FOR PORTABLE INSTRUMENTS
Instrument
Spare parts and supplies
Flame ionization detectors
Photononization detectors
Nondispersive infrared detectors
Catalytic combustion units
Thermocouples
Battery pack
Particulate filters
Glass wool
TYGON tubing (1 foot)
Window cleaning kit
Spare lamp
Particulate filters
Glass wool
Dilution probe
TYGON tubing (1 foot)
Rotameter
Battery pack
Battery pack
Particulate filter
Rotameter
Glass wool
TYGON tubing (1 foot)
Detector
Battery pack
Particulate filter
Rotameter
TYGON tubing (1 foot)
Battery
Probe
5.3.2 Routine Performance Checks During Field Work
Several routine performance checks should be conducted during field work.
These checks take very little time and demonstrate that the unit is continuing
to perform in a proper manner. They also should be discussed briefly in the
field notes.
Instrument Zero--
The instrument zero should be rechecked whenever it has been exposed to
very high organic vapor concentrations and whenever organic liquids may have
been inadvertently sucked into the probe. 8>Z4»44 The instrument zero should
be checked at least twice a day, even when these problems do not occur or are
55
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not suspected. It can be checked by sampling background air at a location up-
wind of any possible VOC sources or by supplying some charcoal-filtered air to
the analyzer. If the zero has drifted significantly, the probe particulate
filter and the prefilter (if one is used) should be replaced. Also, the probe
should either be cleaned or replaced. The instrument then should be recali-
brated before the field work continues.
Instrument Response—
The instrument response should also be checked routinely during field
testing because all of the instrument types are vulnerable to operating prob-
lems that can result in reduced sensitivity or complete loss of response. In
the case of FID's, exposure to very high VOC concentrations (above 70,000
19
ppmv) can lead to flame out of the unit. It is sometimes difficult to hear
the audible flame-out alarm over plant noise unless earphones (supplied with
some models) are used. If the inspector fails to hear the flame-out alarm,
he or she could miss a number of fugitive leaks.
The catalytic combustion units are also vulnerable to problems when ex-
posed to very high concentrations. The detector can reach temperatures high
21
enough to cause some loss of the catalyst coating. If done repeatedly, this
21
can also shorten the life of the detector. Exposure to lead-containing
21
gasoline can lead to some poisoning of the detector catalyst. For these
reasons, the response should be checked whenever the unit is "pegged." The
remaining gas in the TEDLAR bag used for span checks provides a convenient
source of organic vapor to confirm instrument response.
Response problems of the photoionization and nondispersive infrared
detectors result primarily from deposition of condensed organic compounds on
the optical surface. The window should be cleaned at least once a day and
whenever material might have been deposited as a result of exposure to high con-
39 40 45
centrations or entrained liquids. ' ' Unfortunately, contamination on the
optical window is not always visible. Therefore, inspectors should simply
assume the window is dirty and take the necessary time to use the cleaning
solution. Instrument manufacturers recommend a solvent similar to methanol
(instrument manufacturers should be contacted for specific recommendations)
for routine cleaning. ' The cleaning compound is mildly abrasive and is
intended only for stubborn deposits that cannot be removed by more gentle
27
cleaners.
56
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Battery Condition--
In the case of some FID's, weak batteries will not have enough power to
operate the ignitor, even though a proper reading was obtained during the bat-
19
tery check. This can be a problem after the FID has been operated for several
hours and after a number of flame-outs have occurred. Therefore, the instrument
operator should check the battery condition several times during the day.
Probe/Sampling Line Leakage--
The probe and sampling line integrity should be checked several times a
day by simply plugging the probe inlet. The flow rate indicated by the instru-
ment meter (if one is present) and the sound of the instrument should be
noted. Any potential leaks should be corrected before work is continued.
57
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SECTION 6
FIELD INSPECTION PROCEDURES AND INSPECTION SAFETY
This section presents field measurement procedures for regulatory agency
inspectors. The first subsection presents several basic reasons why the
measurement procedures used by agency inspectors are inherently different from
those that may be used by source personnel or their consultants. It also pre-
sents some important basic principles concerning the inspection of VOC and air
toxic sources. The remaining subsections concern major types of sources for
which portable inspection instruments have proven useful. Safety considera-
tions have been integrated with the information concerning field inspection
procedures and underlined to emphasize their importance as an essential part of
all activities involving the portable instruments.
6.1 PRINCIPLES, REQUIREMENTS, AND LIMITATIONS OF AGENCY INSPECTIONS
One of the basic premises of the inspection techniques presented in this
section is that the agency inspector does not have sufficient time to survey
all potential sources of fugitive emissions independently or to monitor the
performance of all air pollution control devices completely. Furthermore, each
inspection involves a review of the permits, a review of operating records, and
interviews with appropriate plant supervisory personnel. Because the use of
portable instruments, the subject of this manual, composes only one part of
the overall inspection, it is unrealistic to assume that agency inspectors can
spend the majority of the inspection day using the portable instruments.
Rather, inspectors must be able to select those few measurement activities that
are most useful in the characterization of the overall conditions at the facil-
ity. In the case of fugitive VOC and air toxic leaks, the inspector must
determine the monitoring accordingly.
Field inspection surveys conducted by plant personnel and consultants
often involve a team of at least two individuals—one to operate the
instrument and one to record the data and tag the appropriate sources.
58
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Regulatory agencies usually send only one inspector. As a result, the inspec-
tion proceeds more slowly, as the inspector normally must set the instrument
down to record the results. This problem cannot be solved by the use of con-
tinuous recorders because most of them are not intrinsically safe and should
not be used.
The data obtained by regulatory agency inspectors must be of the highest
quality reasonably possible because these data are used to determine the com-
pliance status of the facility. Time should be allocated for the field span
checks, response checks, and zero gas checks discussed in the earlier sections.
It is preferable to have a limited set of data of unquestionably high quality
than a large set of potentially inaccurate data.
6.1.1 Inspection Principles
Use of the baseline technique is the best approach to inspection of air
pollution control devices such as carbon-bed adsorbers, incinerators, and vapor
recovery. The baseline technique is based on the comparison of current inspec-
tion data against unit-specific performance data obtained in the past. Shifts
in several operating parameters are used as an indication of problems. The
portable instruments are used only when there are insufficient onsite equip-
ment performance monitors or when reasonable questions arise concerning the
adequacy of the onsite gauges. The basic principles of the baseline technique
are as follows:
o Only unit-specific data are used to evaluate performance.
o Portable instruments are used when onsite gauges are either
unavailable or unreliable.
o Problems are identified by evaluating changes in a number of operat-
ing parameters and conditions.
o The information is compiled in a methodical manner.
o The inspection procedure is modified or limited to the extent
necessary to ensure safety of the inspector, plant personnel, and
the source's equipment.
The baseline technique is not directly applicable to the fugitive VOC and
air toxics leak sources, as no directly observable valve or pump operating
parameters govern the rate of fugitive emissions. These sources either leak or
59
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they don't. For the fugitive leak sources, the baseline concept should be
applied to the plant's leak-detection and repair program rather than to the indi-
vidual leaking components. The adequacy of the leak-detection procedures is
determined by spot-checking potential leaking sources and by rechecking those
components that have been tagged previously. Changes over time in the leak-
detection and repair program that could have an adverse impact on total emissions
should be .evaluated. In other words, the adequacy of a plant's leak-detection
and repair program is evaluated by using leak data obtained during the current
inspection and data obtained during previous inspections. This is a more
accurate approach than simply evaluating what activities are conducted at what
frequency in a given plant's program. The type of programs necessary at one
plant and those at supposedly similar facilities can differ significantly.
6.1.2 General Safety Procedures
All agency personnel should have an occupational health medical examination
before conducting any field inspections. This examination demonstrates that the
inspector is physically capable of the stress associated with carrying the port-
able instruments, climbing ladders/stairs, and wearing the required respirators
and other personnel protection equipment. Annual medical examinations should
be required.
All regulatory agencies should adopt and adhere to written safety procedures
governing all routine activities of field personnel. Specific safety proce-
dures concerning the use of portable instruments and the types of industries
the inspector will visit should be included in these procedures.
Because agency coworkers are rarely present, the inspector should insist
that someone from the plant accompany him or her at all times to ensure that
the inspector does not inadvertently enter unsafe areas, to assist the in-
spector in the event of accidental gas releases within the facility, to get
help if the inspector is injured, and to provide general assistance and advice
regarding safety. ' Inspectors should not work alone in the facility for
any reason.
Prior to leaving for the jobsite, the inspector should obtain all necessary
safety equipment. All the safety equipment, especially respirators, should be
checked to confirm that they are in good working condition. The proper safety
shoes should be worn for the conditions that exist at the facility being
60
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inspected. Because safety shoe requirements differ, the plant should be con-
sulted to determine the proper type of shoe before the inspector departs for the
jobsite.
Before entering the processing areas of the facilities, the inspector
should discuss the instrument intrinsic safety with the appropriate plant repre-
sentatives. Portable instruments that are not intrinsically safe should not
be taken into Class I, Division 1 and Division 2 areas.
During the field survey, the inspector should use an organic vapor analyzer
to help determine if conditions are safe. This is especially true when a tank
with a floating roof is only partially full. These situations must be approached
with great caution as they are similar to entering a confined area. Half-face
cartridge-type respirators for organic vapor are limited to maximum concentra-
tions of 50 ppmv. This concentration can be easily exceeded in the immediate
vicinity of fugitive leaks. The inspector should use the organic vapor analyzer
to determine if poorly ventilated areas have organic vapor concentrations in
the breathing zone that are above the concentration limits of the respirator.
Inspectors rarely have the opportunity to acclimate to heat stress. Heat
exhaustion and stroke can result from the physical exertion of carrying the
instruments and from exposure to hot process equipment. Inspectors should plan
to take regularly scheduled breaks and drink fluids to reduce the risk of heat
exhaustion and heat stroke. These breaks are good times to check the zero
drift or to perform the field span checks of the portable instruments.
6.2 SCREENING TESTS FOR VOC LEAKS FROM PROCESS EQUIPMENT
The primary purpose of the VOC leak-screening tests is to determine if the
plant's leak-detection and maintenance program is adequate. The inspection con-
sists of a review of the leak records and a field survey with an organic vapor
analyzer.
6.2.1 Selecting an Inspection Strategy
Because the time available for the field survey is often limited, the most
probable "leakers" should be targeted for evaluation. The inspector should con-
sider the following factors to determine potential problem sources.
o Specific components identified as leakers in the past
o Type of service (e.g., gas, light liquid, heavy liquid)
61
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o Type of component (e.g., valves, pumps, flanges, compressors, open-
ended lines, relief valves)
o Pressure of line
o Temperature of line
o Specific design of component (e.g., type of pump seal, type of valve,
type of valve packing)
o Age of equipment/component
o Volatility of specific organic compound(s) being handled
o Presence of dripping liquids.
Because the field inspector does not have the luxury of spending hours to
determine the optimum field survey strategy, it is recommended that field moni-
toring primarily emphasize the following: 1) those components/process areas
with a demonstrated history of high leak rates, 2) valves in gas and light
liquid service, 3) pumps in light liquid service, and 4) compressors. Data
obtained during a number of EPA-sponsored studies and private studies have
clearly indicated that these sources have the highest frequency of VOC leaks
25 48 49 5(
in refineries and synthetic organic chemical manufacturing industry plants. ' ' '
For example, data compiled by Wetherold et al. and shown in Table 18 indicate
that valves and pumps in heavy liquid service leak much less frequently than
those in gas service and in light liquid service (light liquid means a boil-
ing point below that of kerosene; heavy liquid means a boiling point equal to
or above that of kerosene). Investigators have generally concluded that most
chemical plant and refinery components in heavy liquid service have a low
probability of leaking.
The data presented in Table 18 clearly indicates that flanges are a
relatively minor source of emissions. Although this is consistent with other
studies of petroleum refineries, the flange leakage in some synthetic organic
chemical manufacturing industry facilities may be higher, based on observa-
49
tions by Harvey and Nelson. Nevertheless, flanges are not good targets for
the field survey because they are numerous and their overall leak rate is less
than those of other components.
Conversely, most refineries and synthetic organic chemical manufacturing
industry plants have very few pumps and compressors, but the leak frequencies
62
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TABLE 18. ESTIMATED LEAKAGE RATES FOR REFINERY COMPONENTS'
Source type
Estimated percentage
that are leaking
Valves
Gas/vapor streams
Light liquid/two-phase streams
Heavy liquid streams
Flanges
Pump seals
Light liquid streams
Heavy liquid streams
Compressor seals
Hydrocarbon service
Hydrogen service
Drains
Relief valves
29.3
36.5
6.7
3.1
63.8
22.8
70.3
81.2
19.2
39.2
Information abstracted from Table 1-1 in Reference 25.
appear to be high. Several of these should be included on the field survey.
Any pump that has liquid dripping from the seal certainly should be moni-
52 53
tored ' although this is not an entirely reliable indicator of excessive
fugitive emissions.
Because of their large number in a typical refinery or synthetic organic
chemical manufacturing industry plants, valves are considered dominant sources
25 48 49
of fugitive VOC emissions, ' ' and a number of these should certainly be
included on any field survey. Unfortunately, the EPA-sponsored studies indi-
cate that a relatively small fraction of the valves are responsible for most
of the emissions from this fugitive source. For example, Wetherold and Provost
found that 3.6 percent of the valves were causing more than 90 percent of the
25
fugitive emissions attributed to valves. To the extent possible, the in-
spector should target the field survey toward the offending valves. The
identification of the problem is complicated by the fact that a typical re-
finery could have more than 10,000 to 20,000 valves.
AQ
'
63
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Soap solution can be used to help in the selection of the valves to moni-
tor. The time required to spray the soap on the valve stem, however,
is just slightly less than that required to monitor the emissions with an organic
vapor analyzer. Soap screening techniques are more appropriate when the actual
emissions are to be quantified by source bagging, which is a time-intensive
approach. Source bagging is commonly practiced as part of special fugitive
leak studies, but it is not a routine inspection tool.
During the field survey, inspectors should listen for any audible leaks,
as this may help to locate "leakers" that were not suspected. Sometimes odors
also can be of benefit in adjusting the field survey portion of the inspection.
The effectiveness of both of these techniques is limited, however.
Another technique of limited usefulness is the "walk through" survey, in
which a portable organic vapor analyzer is used to identify areas of high con-
centrations relative to background concentrations. Supposedly, these areas
would be in the immediate area of fugitive leaks. Unfortunately, this technique
does not appear to be a reliable indicator of fugitive leak locations. Weber
and Mims found that the results could not be reproduced even when the technique
was repeated almost immediately.
With regard to line pressure and temperature, Wetherold et al. found no
significant relationship between these parameters and leak frequency in refin-
eries, however, Langley et al. found that line pressure did correlate with
leak frequency in selected synthetic organic chemical manufacturing industry
57
facilities. Inspectors should consider line pressure only as a secondary
variable when attempting to evaluate the most important components and/or
process areas.
6.2.2 Measurement Procedures
Fugitive leaks from valves in closed systems occur primarily from the
valve stem packing gland. This packing material is intended to seal the pro-
cess gas and/or liquids from the atmosphere. As the packing lubricant is lost
or the packing material wears, some volatilization of organic vapors is possible.
For these types of valves, the emissions are monitored at the point where
the valve steam leaves the packing gland. The normal procedure is to circum-
scribe this location with the probe within 1 centimeter of the valve stem.
This close location is necessary because of the relatively poor capture
64
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effectiveness inherent in the probe designs used on commercially available
instruments. The capture effectiveness decreases very rapidly with distance
from the probe. The presence of a strong cross-draft due to ambient wind
further reduces the probe capture capability. For these reasons, the probe
must be placed very close to the valve packing gland. It should be noted,
however, that this brings the inspector into the immediate vicinity of the
leak because of the short length of most probes. While monitoring the leak,
the inspector could exceed the safe operating range of the respirator and even
saturate the respirator cartridge. To minimize inhalation hazards, the in-
spector should terminate any screening tests when the concentration of organic
vapor in the breathing zone exceeds the maximum safe concentration of his or
her specific respirator.
Some EPA-sponsored work has indicated that fugitive emissions from sources
such as valves could be reliably monitored at 5 centimeters from the valve stem
rather than the 1-centimeter distance discussed above. A leak definition of
1000 ppmv at 5 centimeters appears equivalent to the conventional leak defini-
tion of 10,000 ppmv at 1 centimeter. The 5-centimeter distance is an attractive
alternative because this lessens the chance that liquids on the surface of the
valve will be carried into the instrument. For Method 21 inspections, however,
leak definition of 10,000 ppmv at 1 centimeter should be used to ensure con-
sistency with the regulation.
Valves used on the ends of drains or sample lines have two sources of
leakage, the valve stem and the valve seat. Most sources use a double valve
arrangement or incorporate a blind flange to protect against emission losses
through the valve seat of the main shutoff valve. To confirm the adequacy of
the drain or sampling line seal, the probe is usually placed at the center of
the discharge pipe.
Fugitive emissions from pumps occur from the pump shaft seal used to
isolate the process fluid from the atmosphere. The most commoly used seals
are single mechanical seals, double mechanical seals, and packed seals. Moni-
toring is done within 1 centimeter of the seal and the rotating shaft. A rigid
probe tip should not be used near the rotating shaft. The probe tip could
break if the inspector were not able to hold the probe absolutely steady during
the measurement. A flexible tip is usually added to the end of the rigid
I c CO
probe when sampling pumps. '
65
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Most pump shafts have shaft guards that protect against entrapment in the
rapidly rotating shaft. With some instruments, it is difficult to reach
through the guard to the location of the shaft and shaft seal. The guard should
not be removed under any circumstances, and those pumps without guards should
be approached very carefully. If there is any question concerning the safety of
the measurement, it should not be performed. Pump monitoring safety should be
discussed with plant personnel before the field survey portion of the inspection
is initiated.
Several organic vapor analyzer problems can be caused by sampling gases
having too high a concentration. At hydrocarbon concentrations above 70,000 ppmv,
19
flame-out of flame ionization detectors can occur. High concentrations of
hydrocarbons can lead to very high detector temperatures and the loss of catalyst
in catalytic units. Condensation of a portion of these high concentration vapors
on photoionization unit lamp windows can reduce the sensitivity of the instrument.
The condensation of material in the probe and sampling lines can be a problem
for all types of instruments. For these reasons, the inspector should monitor
the hydrocarbon concentration while slowly approaching the valve stem, pump
shaft seal, or other source. If the instrument gauge indicates high concentra-
tions, the specific leak site on the valve stem or pump seal should be approached
very carefully. In some cases, the concentration will exceed the leak definition
even before the probe is placed close to the leak site. Obviously, in these
cases, there is no need to move the probe closer and risk affecting the perform-
ance of the organic vapor analyzer. Furthermore, there is nothing to be gained
by maintaining the probe at the leak site for two times the response time (a
general rule) if the instrument already indicates a concentration above the
leak. To the maximum extent possible, field inspectors should protect the
organic vapor analyzers against high organic vapor concentrations.
The organic vapor analyzer probe should never be placed in direct contact
with liquids during the monitoring of fugitive emissions. A portion of the
liquid could be pulled into the probe and damage the instrument detector. If
there is contact with liquid, it may be necessary to clean and/or repair the
instrument.
The inspector also must exercise care when monitoring sources, such as
valves and pumps, that handle heavy liquid streams at high temperatures. Rela-
tively nonvolatile organic compounds can condense in the probe and the
66
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detector. Both the instrument response to the emissions and the instrument
return to zero may be slowed because of the condensation of these compounds.
For fugitive VOC sources that have a highly variable leak rate, the maximum
sustained concentration or maximum repeated concentration observed should gen-
erally be recorded.
Certain fugitive leak sources are subject to a "no detectable leak" regula-
tion, i.e., the difference between the background organic vapor concentration
and the concentration downstream of the source should not be greater than 500
ppmv. The background concentration is determined by placing the probe 1 to 2
meters upwind of the source. If other equipment interferes with the background
measurement, the upwind monitoring location can be as close as 25 centimeters.
No heroic attempts should be made to reach valves and other fugitive
sources in inaccessible locations. A relatively high percentage of the valves
EC CO
are often in difficult-to-reach locations. '
6.3 INSPECTION OF CARBON-BED ADSORBERS
Carbon-bed adsorbers are used to recover valuable solvents used in the
manufacturing process. Most larger systems are regenerative units with two or
more carbon-bed vessels. The beds are isolated one by one for regeneration
while the others remain on-line. Steam is the most common means of bed regen-
eration. Selection of the regeneration cycle is based on the need to maximize
solvent recovery while minimizing steam consumption. The organic compounds
desorbed from the bed during regeneration are condensed, along with the steam,
in a condenser. The water and the solvents are then separated in a decanter.
Unless the field inspector has a prior background in carbon-bed design and
operation, it will be difficult to identify carbon-bed system problems by using
only the control device gauges.
Portable inspection instrumentation is very useful for this type of air
pollution control device because it provides a direct means of determining
whether the removal efficiency has decreased since the baseline period. The
effluent gas during the adsorption period from each separate bed should be be-
tween 50 and 500 ppmv, if the carbon bed is being operated properly and the
adsorbent remains in good condition. If the bed is being operated too long
between regeneration cycles or the adsorbent is no longer able to handle the
67
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solvent loading, the effluent gas concentration increases dramatically. Emis-
sions can also increase if the bed has become partially saturated with hard-to-
remove compounds.
To determine if the carbon beds have a "breakthrough" condition, the
inspector places the portable organic vapor analyzer near the exhaust of each
individual bed.60'61 The emissions should be monitored several times during
the adsorption cycle of each bed. Because the instrument usually is not cali-
brated for the specific solvents being handled, the value does not correspond
directly with the actual concentration. Nevertheless, a comparison of the cur-
rent value against effluent concentrations that were measured when the control
system was working properly provides an indication of operating problems. A
very high reading during the inspection is also a clear indication of bed
problems.
Before being used in field work, the organic vapor analyzer should be
calibrated for a moderately low concentration. A calibration to 10,000 ppmv
methane is not appropriate when the emissions being measured are expected to
be in the range of 50 to 500 ppmv.
Portable instruments generally can be used safely on the exhaust streams
because the maximum organic vapor concentration is rarely above 25 to 50 per-
cent of the lower explosive limit (LEL). Nevertheless, field inspectors should
use only intrinsically safe instruments as other areas around the carbon bed
or the facility could have potentially explosive vapors during unusual operating
conditions.
No heroic efforts should be made to monitor carbon-bed exhaust vents that
are in difficult to reach locations. These exhausts are often too high to
reach with standard probes. Inspectors also must be careful to avoid the
downdraft emissions from the vents. Even when the carbon-bed is operating
properly, the organic vapor concentrations exceeds the maximum allowable con-
centration of cartridge-type respirators. When the bed is not operating
properly, concentrations in the stack can be very high. Plume downdraft is
quite common because the gas stream is not very hot, the exit velocities are
low, and the vents are usually only 5 to 15 feet above the ground.
Carbon-bed performance problems identified by the organic vapor instruments
can be confirmed by using a solvent material balance. Because it is relatively
time-consuming, however, this exercise is generally performed only when the bed
68
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emissions are abnormally high or when safety considerations preclude the use of
measurements.
Static pressure gauges have a limited application in the inspection and
evaluation of carbon-bed adsorbers. The gauge can be used to measure the
static pressure drop across the bed if static pressure measurement taps are
available above and below the bed. These data are useful in determining if
the bed has collapsed (often caused by corrosion) of if the total gas flow
rate to the carbon-bed has increased substantially.
6.4 INSPECTION OF THERMAL AND CATALYTIC INCINERATORS
Theoretically, thermometers should be very valuable for routine inspec-
tions of thermal and catalytic incinerators. On all types of incinerators,
the operating temperature is one of the main variables determining the effec-
tiveness of pollutant destruction. The independent measurement of the in-
cinerator operating temperature during the inspection would be very useful in
confirming proper operation. Unfortunately, however, the incinerators rarely
have ports in which a thermocouple could be inserted to determine the temper-
ature, partially because it is very difficult to obtain accurate measurements
with portable thermometers. If the probe is placed within the direct line-
of-sight of the burner flame, the radiant energy received by the probe can
indicate higher-than-actual gas temperatures. Conversely, thermocouple probes
partially or completely shielded by refractory baffles can indicate much
lower-than-actual gas temperatures. Most facilities rely on permanently mounted
temperature indicators installed with the incinerator rather than attempting
to measure the incinerator temperature. Chances that an onsite gauge will be
significantly in error are slight because failure of the onsite temperature
monitor usually causes the"incinerator to trip off-line. For these reasons,
regulatory agency inspectors generally use the onsite gauge to confirm the
proper operation of incinerators.
If an independent temperature measurement is needed, the inspector can
monitor the incinerator stack temperature. A drop in this value compared with
baseline data indicates a decrease in the incinerator operating temperature.
Whereas actual incinerator conditions could not be reliably inferred from the
stack temperature data alone, large decreases in the stack temperature could
69
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demonstrate the need for a stack test. Most thermal and catalytic incinerator
stacks, however, do not have appropriate ports for portable thermocouples, and
many of those that do are in inaccessible locations. Inspectors must be
extremely careful when making measurements on incinerator stacks. Potential
problems include (but are not limited to) severe burns, heat stress, falls,
and inhalation hazards. It should also be noted that battery-powered thermom-
eters are generally not intrinsically safe; therefore, these instruments
cannot be used in areas where potentially explosive gas mixtures or dust
clouds could exist.
Although specific procedures have not yet been developed, organic vapor
analyzers could conceivably be used as part of an incinerator inspection. A
portion of the incinerator stack gas could be withdrawn and cooled to a gas
temperature compatible with the organic vapor analyzer. Presumably, this
would require that the instrument probe be replaced with a sampling train in-
cluding a high-temperature probe, a condenser, a moisture trap, and a particu-
late filter arranged in series. The measured organic vapor concentration
would provide a direct indication of the effectiveness of the incinerator.
Actually, a procedure of this type would be difficult to implement at the
present time for the following reasons:
o The sampling train includes several bulky items that are time-
consuming to setup and cumbersome to transport.
o A traverse of the stack would be necessary to determine the
presence of any stratification of partially combusted organic vapors.
o Condensation of nonvolatile organic compounds could plug the par-
ti cul ate filter or damage the instrument detectors.
o Failure to cool the stack gas adequately would result in damage to
the instrument.
o There is no assurance that the instrument will detect a sufficient
fraction of the partially combusted organic compounds.
For these reasons, field inspectors do not currently use this technique.
All of the sampling train problems probably could be worked out, however, the
uncertainty of instrument response due to unknown organic compound species may
preclude use of this technique. At the present time, it is recommended that
regulatory agency inspectors not attempt to use organic vapor analyzers for
the evaluation of incinerator effluent.
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6.5 INSPECTION OF VAPOR RECOVERY SYSTEMS
Three major types of vapor recovery systems are commonly used at gasoline
terminals: 1) carbon-bed adsorbers with followup gasoline absorption, 2) re-
frigeration, and 3) thermal oxidation. Portable instruments can be used to a
limited extent to inspect these air pollution control systems.
Vapor recovery systems using carbon adsorbers are inspected in a manner
similar to that described earlier for carbon-bed adsorbers in Subsection 6.3.
If the exhaust vent for each bed (normally there are two beds) is accessible,
the organic vapor analyzer probe can be used to confirm that the exhaust con-
centration during the adsorbtion cycle is less than 500 ppmv. Failure of the
desorption process or saturation of the bed both lead to "breakthough" and
very high VOC concentrations during the adsorbtion cycle. In fact, the emis-
sions from the carbon bed during severe malfunction can be within the explosive
range.
The potentially high vapor concentrations necessitate that the probe
initially be placed well downwind of the exhaust vent in an area where dilu-
tion of the effluent has already occurred. If the observed concentration is
high (> 200 to 300 ppmv), the bed obviously is not operating properly and no
further measurements are necessary. If the downwind concentration is very
low, the probe can be advanced slowly toward the exhaust vent itself. If the
observed concentration exceeds several thousand ppmv at any time, the measure-
ments should be discontinued. This cautious approach is required because of
the remote possibility that a significant static charge can accumulate on the
instrument probe or the inspector's clothing as he or she walks around the
unit. A spark in a cloud of gasoline vapors within the explosive range would
have serious consequences. Therefore, the probe is never allowed to enter
the exhaust plume at an area where explosive concentrations could conceivably
exist.
Many carbon-bed vapor recovery systems do not have platforms above the
beds to permit access to the exhaust vents, which are usually 10 to 15 feet
above the ground. When this is the case, inspectors should not attempt to
climb up to the vapor recovery systems to reach the exhaust vents.
Portable instruments have very little application in the inspection of
the refrigeration and incinerator vapor recovery systems. In the case of the
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refrigeration units, the normal exhaust concentrations are 30,000 to 50,000
ppmv, which are above the normal operating range of most instruments. Further-
more, the gasoline vapor concentration can be in the explosive range. Also
access to the exhaust vents, normally 10 to 15 feet high, is generally very
poor. The thermal incinerators rarely have measurement ports to permit the
use of portable thermometers, and the inherent measurement accuracy problems
are the same as those for large thermal and catalytic systems.
6.6 SURVEYING EMISSIONS FROM STACKS, VENTS, AND ROOF MONITORS
Regulatory agency personnel have expressed an interest in evaluating the
organic vapor emissions from stacks, vents, and roof monitors as part of
special inspections. Some of the principal objectives of these surveys are
summarized below:
o To evaluate possible sources of community odors.
o To evaluate emissions from bypass stacks and vents believed to be
sealed.
o To evaluate adequacy of pollutant capture in specific process areas
and buildings.
o To identify sources of organic compounds not currently included on
the plant emission inventory or covered by operating permits.
These activities are obviously different from those of a conventional
source inspection. Unfortunately, most regulatory agencies currently do not
have the necessary equipment to perform such evaluations. Presumably, the
organic vapor analyzers purchased for inspection of VOC and air toxic sources
could be used for these additional activities.
Stacks, vents, and roof monitors are difficult sources to measure with
portable organic vapor analyzers. All of the commonly used instruments are
easily damaged if particulate is carried into the instrument detector. Con-
densable organic vapors, condensable acid vapors, and moisture could severely
damage the instrument detectors, the instrument pumps, and the entire
sample-handling system. Thus, the instruments should include a moisture trap
and a particulate filter, at the very minimum. An additional glass wool plug
at the probe inlet would provide additional protection. Both the glass wool
72
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and the instrument particulate filter should be changed if there is an indica-
tion that the sample flow rate has decreased during the survey.
High organic vapor concentrations can lead to flame-out of the FID's and
damage to all types of instrument detectors. When high concentrations are
expected, the instrument should include a dilution probe. As an alternative,
the sample could be taken in a TEDLAR or TEFLON bag and diluted with hydro-
carbon-free air before the instrument is used. If high VOC concentrations are
accidently found, the probe should not be left in the high concentration stream
for a long time.
In sources of this type, the specific chemical compounds in the gas
stream are rarely known. Lack of knowledge concerning the appropriate re-
sponse factors makes it difficult to interpret the organic vapor analyzer
meter readings. The instrument simply provides a qualitative indication of
the presence or absence of high concentrations of organic vapors. In some
compounds, the response may be so poor that small sources of emissions will
not be reliably identified. To improve the reliability of detection, field
inspectors could use two different types of analyzers. Combinations such as
an FID and a PID, a catalytic unit and a PID, or an FID and an infrared unit
would cover a much broader group of organic compounds. This also increases
the time and difficulty of the survey, however.
Before conducting any surveys of stacks, vents, and roof monitors, regu-
latory agency personnel should carefully evaluate the potential safety hazards
and the potential variability of emissions. It may be difficult to obtain
good data even if the instruments are responding properly.
Many fugitive emissions passing up through the stacks, vents, and roof
monitors are intermittent in nature. Some degree of luck is necessary to have
the instrument at the right spot at the right time. The probability of detec-
tion is improved if the inspector is familiar with the plant operating cycles.
Even with a good working knowledge of the plant operations, however, the
inspector can miss the short-term emission events. Another major problem
is the size of some of the vents and roof monitors. The probes used with the
portable instruments are relatively short and would not be appropriate for
traversing large open sources. Although the use of longer probes is possible,
the additional flow resistance could have a detrimental effect on the
73
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instrument's sample gas flow rate. This is important because some instruments,
notably the FID, are especially sensitive to flow rate variation.
Several potentially serious safety problems must be considered before
surveys of stacks, vents, and roof monitors are attempted:
o Falls through weak roofs
o Sudden exposure to potentially toxic compounds through inhalation
if a pollutant downdraft exists
o Heat stress around hot sources
o Climbing hazards because of the cumbersomeness of the portable
instruments and accessories.
The most important of the safety problems is the possibility of falls through
weak roofs. Structural problems in portions of roofs are very common and it
is often difficult to spot the weak areas. Agency inspectors must exercise
extreme caution when walking across or working on roofs. Unfortunately, walk-
ing across the roofs is the only way to read most of the vents and roof moni-
tors. The second major problem is the sudden exposure to high concentrations
of potentially toxic organic compounds. Exposure can occur before the in-
spector can put on the respirator and the organic vapor concentrations can
greatly exceed the allowable limits of the respirator. The problem is further
compounded by the fact that some of the organic compounds are skin- and eye-
absorbable, thus limiting the help provided by a respirator.
Based on the potential instrument damage, the uncertainties of instrument
response, the variability of pollutant emissions, and the possible safety
hazards, extreme care should be exercised in conducting these type of surveys.
Obviously, if unsafe conditions exist with respect to these type of surveys
they should not be conducted.
74
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REFERENCES
1. U.S. Environmental Protection Agency. Summary of Available Portable VOC
Detection Instruments. EPA-340/1-80-010, 1980.
2. U.S. Environmental Protection Agency. Evaluation of Potential VOC Screen-
ing Instruments. EPA-600/7-82-063, 1982.
3. Temperature Measurement Handbook and Enclyclopedia, 1985. Omega Engineer-
ing, Inc. Standford, Connecticutt.
4. Jorgensen, R., Ed. Fan Engineering. Buffalo Forge Co., Buffalo, New
York, Eighth Edition, 1983.
5. Brown, G. E., et al. Project Summary Response Factors of VOC Analyzers
Calibrated With Methane for Selected Organic Chemicals. U.S. Environ-
mental Protection Agency, Industrial Environmental Research Laboratory,
Research Triangle Park, North Carolina. EPA-600/S2-81-002, May 1981.
6. Dubose, D. A., and G. E. Harris. Project Summary. Response Factors of
VOC Analyzers at a Meter Reading of 10,000 ppmv for Selected Organic
Compounds. U.S. Environmental Protection Agency, Industrial Environ-
mental Research Laboratory, Research Triangle Park, North Carolina.
EPA-600/S2-81-051, September 1981.
7. Dubose, D. A., G. E. Brown, and G. E. Harris. Response of Portable VOC
Instruments to Chemical Mixtures. EPA-600/2-81-110, June 1981.
8. Menzies, K. T., and R. E. Fasano. Evaluation of Potential VOC Screening
Instruments. EPA-600/7-82-063, November 1982.
9. Analytical Instrument Development, Inc. PID - Different lonization
Sources and a Comprehensive List of lonization Potentials, Bulletin
AN-145, undated.
10. Analytical Instrument Development, Inc. Design and Characteristics of a
Photoionization-Based Portable Organic Vapor Meter, Description and
Applications of the AID 580. April 1981.
11. Ressl, R. A., and T. C. Ponder, Jr. Field Experience With Four Portable
VOC Monitors. Prepared by PEI Associates, Inc., for U.S. Environmental
Protection Agency, Research Triangle Park, North Carolina, under Con-
tract No. 68-02-3767. December 1984.
75
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12. Brooks, J. C. Excerpts of Some of the Articles and Sections of the
National Electrical Code, NFPA No. 70, 1971, Adopted by OSHA Standards
(Section 1910.309). North Carolina Department of Labor Reprint Number
SAH-5, June 1973.
13. Michaels, E. C. Defining the Limits of Hazardous (Classified) Locations
for Compliance With National Electrical Code. Plant Engineering, pages
153-155.
14. Photovac, Inc. Photovac's TIP, An Innovative Photoionization Detector
for Air Analysis. 1985.
15. Personal communication from R. Taggert and J. Prionti, Delaware Depart-
ment of Natural Resources, to J. Richards, Richards Engineering,
November 25, 1985.
16. Personal communication from 0. Chehaske, Pacific Environmental Services,
Inc., to J. Richards, Richards Engineering, November 25, 1985.
17. Personal communication from J. Maxwell, Entropy Environmentalists, Inc.,
to J. Richards, Richards Engineering, December 4, 1985.
18. Flanagan, G. Selecting a Volatile Organic Chemical Detector. Chemical
Engineering Progress, 37-44, September 1984.
19. Personal communication from N. Davis, Foxboro Corp., to J. Richards,
Richards Engineering, November 26, 1985.
20. HNU Systems, Inc. Instruction Manual for Model PI-101 Photoionization
Analyzer. 1975.
21. Personal communication from 0. Singleton, Bacharach, Inc., to J. Richards,
Richards Engineering, December 5, 1985.
22. Becker, J. H., et al. Instrument Calibration With Toxic and Hazardous
Materials. Industrial Hygiene News, July 1983.
23. Richards, J., and R. Segal 1. Advanced Inspection Techniques Workshop,
Student Manual. Report submitted to U.S. Environmental Protection
Agency under Contract No. 68-02-3960. May 1984.
24. Riggin, R. M. Draft - Guidance Document on the Use of Portable Volatile
Organic Compounds (VOC's) Analyzers for Leak Detection. Prepared under
EPA Contract No. 68-02-3487. No Date Specified.
25. Wetherold, R., and L. Provost. Emission Factors and Frequency of Leak
Occurrence for Fittings in Refinery Process Units. EPA-600/2-79-044,
February 1979.
26. PEDCo Environmental, Inc. Summary of Available Portable VOC Detection
Instruments. Prepared for U.S. Environmental Protection Agency, Division
of Stationary Source Enforcement, under EPA Contract No. 68-01-4147.
March 1980.
76
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27. Personal communication from R. Sevalo, HNU Systems, Inc., to J. Richards,
Richards Engineering, January 10, 1986.
28. HNU Systems Inc. Model PI-101 Photoionization Analyzer, Price List.
September 20, 1985.
29. Personal communication from N. Davis, Foxboro Corp., to J. Richards,
Richards Engineering, January 10, 1986.
30. Scott Environmental Technology, Inc. Scott Specialty Gases. 1985.
31. AIRCO, Inc. Special Gases and Equipment. November 1984.
32. Specialty Gases Division, Liquid Air Corporation. Alphagaz Nonreturnable
Cylinders, Price List. Effective February 1, 1985.
33. Personal communication from A. Smith, Bacharach, Inc., to J. Richards,
Richards Engineering, January 10, 1986.
34. Omega Engineering, Inc. 1983 Complete Temperature Measurement Handbook.
1983.
35. Personal communication from R. Stroup, Nutech Corp., to J. Richards,
Richards Engineering, January 10, 1986.
36. Cole-Parmer Instrument Company. 1985-86 Cole-Parmer Catalog. 1985-1986.
37. Personal communication from G. McAllister, U.S. Environmental Protection
Agency, to J. Richards, Richards Engineering, December 6, 1985.
38. Personal communication from J. Washle, Analytical Instrument Development,
Inc., to J. Richards, Richards Engineering, December 4, 1985.
39. Personal communication from R. Sevalo, HNU Systems, Inc., to J. Richards,
Richards Engineering, December 5, 1985.
40. Personal communication from N. Barker, Photovac, Inc., to J. Richards,
Richards Engineering, December 4, 1985.
41. U.S. Environmental Protection Agency. Standards of Performance for New
Stationary Source; Synthetic Organic Chemical Manufacturing Industry;
Equipment Leaks of VOC, Reference Methods 18, and 22; Final Rule.
Federal Register, Volume 48, Number 202, page 48334. October 18, 1983.
42. U.S. Environmental Protection Agency. Control of Volatile Organic Com-
pound Leaks From Gasoline Tank Trucks and Vapor Collection Systems.
EPA-450/2-78-051, December 1978.
43. United Technologies, Bacharach. Instruction Manual, TLV Sniffer,
Instruction 23-9613, Revision 1. September 1982.
77
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44. PEDCo Environmental, Inc. VOC Sampling and Analysis Workshop, Volume II.
Papers and Lecture Notes. EPA-340/l-84-001b, September 1983.
45. Personal communication from J. Washall, Analytical Instrument Develop-
ment, Inc., to J. Richards, Richards Engineering, December 5, 1985.
46. Richards, J., and R. Segall. Air Pollution Source Inspection Safety
Procedures, Student Manual. EPA-340/185-002a, September 1985.
47. Gordon, R. J., et al. Inspection Manual for Control of Volatile Organic
Emissions From Gasoline Marketing Operations. EPA-340/1-80-012,
January 1980.
48. Hanzevack, K. M. Fugitive Hydrocarbon Emissions - Measurement and Data
Analysis Methods. In: Proceedings of Symposium/Workshop on Petroleum
Refinering Emissions. EPA-600/2-78-199, September 1978.
49. Harvey, C. M., and A. C. Nelson, Jr. VOC Fugitive Emission Data - High
Density Polyethylene Process Unit. EPA-600/2-81-109, June 1981.
50. Morgester, J. J., et al. Control of Emissions From Leaking Valves and
Flanges at Oil Refineries. California Air Resources Board Publication.
November 15, 1978.
51. Wetherold, R. G., L. P. Provost, and C. D. Smith. Assessment of
Atmospheric Emissions From Petroleum Refining: Volume 3, Appendix B.
EPA-600/2-80-075c, April 1980.
52. Hustvedt, K. C., et al. Control of Volatile Organic Compound Leaks From
Petroleum Refinery Equipment. EPA-450/2-78-036, June 1978.
53. U.S. Environmental Protection Agency. Benzene Fugitive Emissions -
Background Information for Proposed Standards. EPA-450/3-80-032a,
November 1980.
54. Williamson, A. M. Valves - A Possible Source of Fugitive Emissions in
Hydrocarbon Processes. In: Proceedings of Symposium/Workshop on
Petroleum Refining Emissions. EPA-600/2-78-199, September 1978.
55. U.S. Environmental Protection Agency. Control of Volatile Organic
Compound Leaks From Synthetic Organic Chemical and Polymer Manufacturing
Equipment, Guideline Series. EPA-450/3-83-006, March 1984.
56. Weber, R., and K. Mims. Project Summary. Evaluation of the Walkthrough
Survey Method for Detection of Volatile Organic Compound Leaks. EPA-
600/S2-81-073, July 1981.
57. Langley, G. J., et al. Analysis of SOCMI VOC Fugitive Emissions Data.
EPA-600/2-81-111, June 1981.
78
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58. Langley, G. J., and R. G. Wetherold. Project Summary. Evaluation of
Maintenance for Fugitive VOC Emissions Control. EPA-600/S2-81-080,
July 1981.
59. Labadie, G. P. Fugitive Hydrocarbon Emission Control at Chevron U.S.A.'s
El Segundo Refinery. Presented at the Americal Petroleum Institute
Operating Practice Committee, Subcommittee on Facilities and Maintenance,
San Francisco, California, May 14, 1979.
60. Michaelis, T. B. Techniques to Detect Failure on Carbon Adsorption
Systems. EPA-340/1-80-011, April 1980.
61. Personal communication from T. Michaelis, Michaelis and Associates, Inc.,
and J. Richards, Richards Engineering, December 9, 1985.
79
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APPENDIX A
REFERENCE METHOD 21 AND NSPS
AND NESHAPS REGULATIONS
80
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REFERENCE METHOD 21
81
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Method 21. Determination of Volatile Organic
Compounds Leaks "6
1. Applicability and Principle.
J.J Applicability. This method applies to
the determination of volatile organic
compound (VOC) leaks from process
equipment. These sources include, but are not
limited to. valves, flanges and other
connections, pumps and compressors.
pressure relief devices, process drains, open-
ended valves, pump and compressor seal
system degassing vents, accumulator vessel
vents, agitator seals, and access door seels.
1.2 Principle. A portable instrument is
used to detect VOC leaks from individual
sources. The instrument detector type is not
specified, but it must meet the specifications
and performance criteria contained in Section
3. A leak definition concentration based on a
reference compound is specified in each
applicable regulation. This procedure is
intended to locate and classify leaks only.
and is not to be used as a direct measure of
mass emission rates from individual sources.
2. Definitions.
2.1 Leah Definition Concentration. The
local VOC concentralion at the surface of a
leak source that indicates that a VOC
emission (leak) is present. The leak definition
!9 an instrument meter reading based on a
reference compound
2.2 Reference Compound. The VOC
species selected as an instrument calibration
basis for specification of the leak definition
concentration. (For example: If a leak
definition concentration is 10.000 ppmv as
methane, then any source emission that
results in a local concentration that yields a
meter reading of 10.000 on an instrument
calibrated with methane would be classified
as a leak. In this example, the leak definition
is 10.000 ppmv. and the reference compound
is methane.)
2.3 Calibration Gas. The VOC compound
used to adjust the instrument meter reading
to a known value. The calibration gas is
usually the reference compound at a
concentration approximately equal to the
leak definition concentration.
2.4 No Detectable Emission. The local
VOC concentration at the surface of a leak
source that indicates that a VOC emission
(leak) is not present. Since background VOC
concentrations may exist, and to account for
instrument drift and imperfect
reproducibility. a difference between the
source surface concentration and the local
ambient concentration is determined. A
difference based on meter readings of less
than a concentration corresponding to the
minimum readability specification indicates
that a VOC emission (leak) is not present.
(For example, if the leak definition in a
regulation is 10.000 ppmv. then the allowable
increase in surface concentration versus local
ambient concentration would be 500 ppmv
based on the instrument meter readings.)
2.5 Response Factor. The ratio of the
known concentration of a VOC compound to
the observed meter reading when measured
using an instrument calibrated with the
reference compound specified in the
application regulation.
2.6 Calibration Precision. The degree of
agreement between measurements of the
same known value, expressed as the relative
percentage of the average difference between
the meter readings and the known
concentration to the known concentration.
2.7 Response Time. The time interval
from a step change in VOC concentration at
the input of the sampling system to the time
at which 90 percent of the corresponding final
value is reached as displayed on the
instrument readout meter.
3. Apparatus.
3.1 Monitoring Instrument.
3.J.I Specifications.
a. The VOC instrument detector shall
respond to the compounds being processed
Detector types which may meet this
requirement include, but are not limited to.
catalytic oxidation, flame iomzation. infrared
absorption, and pholoiomzation.
b. The instrument shall be capable of
measuring the leak definition concentration
specified in the regulation.
c. The scale of the instrument meter shall
be readable to±5 percent of the specified leak
definition concentration.
d. The instrument shall be equipped with a
pump so that a continuous sample is provided
to the detector. The nominal sample flow rate
shall be V4 to 3 liters per minute.
e. The instrument shall be intrinsically safe
for operation in explosive atmospheres as
defined by the applicable U.S.A. standards
(e.g.. National Electrical Code by the National
Fire Prevention Association). 2 3
3.1.2 Performance Criteria.
a. The instrument response factors for the
individal compounds to be measured must be
less than 10.
b. The instrument response time must be
equal to or less than 30 seconds. The
response time must be determined for the
instrument configuration to be used during
testing.
c. The calibration precision must be equal
to or less than 10 percent of the calibration
gas value.
d. The evaluation procedure for each
parameter is given in Section 4.4.
3.1.3 Performance Evaluation
Requirements.
a. A response factor must be determined
for each compound that is to be measured.
either by testing or from reference sources
The response factor tests are required before
placing the analyzer into service, but do noi
have to be repeated as subsequent intervals
b. The calibration precision test must be
completed prior to placing the analyzer into
service, and at subsequent 3-month intervals
or at the next use whichever is later.
c. The response time test is required prior
to placing the instrument into service. If a
modification to the sample pumping system
or flow configuration is made that would
change the response time, a new test is
required pnor to further use.
3.2 Calibration Cases. The monitoring
instrument is calibrated in terms of parts per
million by volume (ppmv) of the reference
compound specified in the applicable
regulation. The calibration gases required for
monitoring and instrument performance
evaluation are • zero gas (air. less than 10
pprev VOC) and a calibration gas in air
mixture approximately equal to the leak
definition specified in the regulation. If
cylinder calibration gas mixture are used, they
must be analyzed and certified by the
manufacturer to be within ±2 oercent
accuracy, and a shelf life must be specified.
Cylinder standards must be either reanalyzed
or replaced at the end of the specified shelf
life. Alternately, calibration gases may be
prepared by the user according to any
accepted gaseous standards preparation
procedure that will yield a mixture accurate
to within ±2 percent. Prepared standards
must be replaced each day of use unless it
can be demonstrated that degradation does
not occur during storage.
Calibrations may be performed using a
compound other than the reference
compound if a conversion factor is
determined for that alternative compound so
that the resulting meter readings during
source surveys can be converted to reference
compound results. 213
4. Procedures.
4.1 Pretest Preparations. Perform the
instrument evaluation procedures given in
Section 4.4 if the evaluation requirements of
Section 3.1.3 have not been met.
4.2 Calibration Procedures. Assemble and
start up the VOC analyzer according to the
manufacturer's instructions. After the
appropriate warmup period and zero internal
calibration procedure, introduce the
calibration gas into the instrument sample
probe. Adjust the instrument meter readout to
correspond to the calibration gas value.
Note —If the meter readout cannot be
adjusted to the proper value, a malfunction of
the analyzer is indicated and corrective
actions are necessary before use.
4.3 Individual Source Surveys.
4.3.1 Type I—Leak Definition Based on
Concentration. Place the probe inlet at the
surface of the component interface where
leakage could occur. Move the probe along
the interface periphery while observing the
instrument readout. If an increased meter
reading is observed, slowly sample the
interface where leakage is indicated until the
maximum meter reading is obtained Leave
the probe inlet at this maximum reading
location for approximately two times the
instrument response time. If the maximum
observed meter reading is greater than the
leak definition in the applicable regulation.
record and report the results at ipecified in
the regulation reporting requirements.
Examples of the application of this general
technique to specific equipment types are:
a. Valves—The most common source of
leaks from valves is at the seal between the
stem and housing. Place the probe at the
interface where the stem exists the packing
gland and sample the stem circumference.
Also, place the probe at the interface of the
packing gland take-up flange seat and sample
the periphery. In addition, survey valve
housings of multipart assembly at the surface
of all interfaces where a leak could occur. 213
b. Flanges and Other Connections—For
welded flanges, place the probe at the outer
edge of the flange-gasket interface and
sample the circumference of the flange.
Sample other types of nonpermanent joints
(such as threaded connections) with a similar
traverse.
c. Pumps and Compressors—Conduct a
circumferential traverse at the outer surface
of the pump or compressor shaft and seal
Interface. If the source is a rotating shaft.
position the probe inlet within 1 cm of the
32
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•haft-teal interface for the survey. If the
homing configuration prevent* a complete
travene of the shaft periphery, sample all
accessible portions. Sample all other joints
on the pump or compressor bousing where
leakage could occur.
d. Pressure Relief Device*—The
configuration of most pressure relief devices
prevents sampling at the sealing seal
interface. For those device* equipped with an
enclosed extension, or horn, place the probe
inlet at approximately the center of the
exhaust area to the atmosphere.
e. Process Drain*—For open drains, place
the probe inlet at approximately the center of
the area open to the atmosphere. For covered
drain*, place the probe at the surface of the
cover interface and conduct a penpheral
traverse.
f. Open-Ended Lines or Valves—Place the
probe inlet at approximately the center of the
opening to the atmosphere.
g. Seal System Degassing Vents and
Accumulator Vents—Place the probe inlet at
approximately the center of the opening to
the atmosphere.
h. Access Door Seals—Place the probe inlet
at the surface of the door seal interface and
conduct a penpheral travetse.
4.3-2 Type II—"No Detectable Emission ".
Determine the local ambient concentration
around the source by moving the probe inlet
randomly upwind and downwind at a
distance of one to two meters from the
source. If an interference exists with this
determination due to a nearby emission or
leak, the local ambient concentration may be
determined at distances closer to the source.
but in no case shall the distance be less than
25 centimeters. Then move the probe inlet to
the surface of the source and determine the
concentration described in 4.3.1. The
difference between these concentrations
determines whether there are no detectable
emissions. Record and report the results as
specified by the regulation.
For those cases where the regulation
requires a specific device installation, or that
specified vents be ducted or piped to a
control device, the existence of these
conditions shall be visually confirmed. When
the regulation also requires that no
detectable emissions exist, visual
observations and sampling surveys are
required. Examples of this technique are:
(a) Pump or Compressor Seals—If
applicable, determine the type of shaft seal.
Preform a survey of the local area ambient
VOC concentration and determine if
detectable emissions exist as described
above.
(b) Seal System Degassing Vents,
Accumulator Vessel Vents, Pressure Relief
Devices—If applicable, observe whether or
not the applicable ducting or piping exists.
Also, determine if any sources exist in the
ducting or piping where emission* could
occur prior to the control device. If the
required ducting or piping exist* and there
are no sources where the emissions could be
vented to the atmosphere prior to the control
device, then it is presumed that no detectable
•mission* are present. If there are sources in
the ducting or piping where emissions could
be vented or sources where leaks could
occur, the sampling surveys described in this
paragraph shall be u*«d to determine if
detectable emissions exuL
4JJ Alternative Screen ing Procedure. A
screening procedure bated on the formation
of bubble* in a soap solution that is sprayed
on a potential leak source may be used for
thoee source* that do not have continuously
moving parts, that do not have surface
temperature* greater than the boiling point or
less than the freezing point of the soap
solution, that do not have open areas to the
atmosphere that the soap solution cannot
bridge, or that do not exhibit evidence of
liquid leakage. Sources thai have these
conditions present must be surveyed using
the instrument techniques of'4.3.1 or 4.3.2.
Spray a soap solution over all potential
leak sources. The soap solution may be a
commercially available leak detection
solution or may be prepared using
concentrated detergent and water. A pressure
sprayer or a squeeze bottle may be used to
dispense the solution. Observe the potential
leak sites to determine if any bubbles are
formed. If no bubbles are observed, the
source is presumed to have no detectable
emissions or leaks as applicable If aru
bubbles are observed, the instrument
techniques of 4 3 1 or 4.3.2 shall be used to
determine if a leak exists, or if the source hds
detectable emissions, as applicable. 213
4.4 Jnstrument Evaluation Procedures. At
the beginning of the instrument performance
evaluation test, assemble and start up the
instrument according to the manufacturer's
instructions for recommended warmup period
and preliminary adjustments.
4.4,1 Response Factor. Calibrate the
instrument with the reference compound as
specified in the applicable regulation. For
each organic species that is to be measured
dunng individual source surveys, obtain or
prepare a known standard in air at a
concentration of approximately 80 percent of
the applicable leak definition unless limited
by volatility or explosivity. In these cases.
prepare a standard at 90 percent of the
saturation concentration, or 70 percent of the
lower explosive limit, respectively. Introduce
this mixture to the analyzer and record the
observed meter reading. Introduce zero air
until a stable reading is obtained. Make a
total of three measurements by alternating
between the known mixture and zero air
Calculate the response factor for each
repetition and the average response factor.
Alternatively, if response factors have been
published for the compounds of interest for
the instrument or detector type, the response
factor determination i* not required, and
existing results may be referenced. Examples
of published response factors for flame
ionization and catalytic oxidation detectors
are included in Section 5.
4.4.2 Calibration Precision. Make a total of
three measurements by alternately using zero
gas and the specified calibration gaa. Record
the meter readings. Calculate the average
algebraic difference between the meter
readings and the known value. Divide this
average difference by the known calibration
value and mutiply by 100 to express the
resulting calibration precision a* a
percentage.
4.4.3 Retponte Time. Introduce zero gas
into the instrument sample probe When the
meter reading ha* stabilized switch quickly
to the specified calibration gas. Measure the
time from switching to when 90 percent of the
final liable reading ia attained. Perform this
teal aequence three tine* and record the
mult*. Calculate the average response time.
* Bibliography.
i.1 DuBoM. ZM.. and C.E. Hams.
ReapotiM Factor* of VOC Analyzers at a
Meter Reading of 10.000 ppmv for Selected
Organic Compound*. UA Environmental
Protection Agency. Research Triangle Park.
N.C. Publication No. EPA 800/2-81-051.
September 1981.
SJ Brown. C.E.. tt al. Response Factor* of
VOC Analyser* Calibrated with Methane for
Selected Organic Compound*. US.
Environmental Protection Agency. Research
Triangle Park. N.C. Publication No. EPA 600/
2-81-422. May 1081.
5J DuBote. D.A.. et at. Response of
Portable VOC Analyzers to Chemical
Mixture*. U.S. Environmental Protection
Agency. Research Triangle Park. N.C.
Publication No. EPA flOO/2-«1-nO. September
1981.
03
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NSPS REGULATIONS
84
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Subpart W—Standard* of
Part ormanc* for Equipment Laaks of
VOC in tha Synthatlc Organic ,0
Cnamicate Uanufaeturtng Industry
|W.4*0 AppMcabmty and designation of
affactedfacfttty.
(a)(l) The provisions of this lubpart
apply to affected facilities in the
synthetic organic chemicals
manufacturing industry.
(2) The group of all equipment
(defined in § 60.461) within a process
unit is an affected facility.
(b) Any affected facility under
paragraph (a) of this section that
commences construction or modification
after January 5,1981. sh.all be subject to
the requirements of this subpart.
(c) Addition or replacement of
equipment for the purpose of process
improvement which is accomplished
without a capital expenditure shall not
by itself be considered a modification
under this subpart
(d)(l) If an owner or operator applies
for one or more of the exemptions in this
paragraph, then the owner or operator
shall maintain records as required in
i 60.486(i).227
(2) Ajiy affected facility that has the
design capacity to produce less than
1.000 Mg/yr is exempt from ( 60.482.
(3) If an affected facility produces
heavy liquid chemicals only from heavy
liquid feed or raw materials, then it is
exempt from § 60.482.
(4) Any affected facility that produces
beverage alcohol is exempt from
160.482.
(5) Any affected facility that has no
equipment in VOC service is exempt
from S 60.482.
§60.4»1 Definition*.
As used in this subpart. all terms not
defined herein shall have the meaning
given them in the Act or in Subpart A of
Part 60. and the following terms shall
have the specific meanings given them.
"Capital expenditure" means, in
addition to the definition in 40 CFR 60.2.
an expenditure for a physical or
operational change to an existing facility
that:
(a) Exceeds P. the product of the
facility's replacement cost. R, and an
adjusted annual asset guideline repair
allowance, A. as reflected by the
following equation: P » R X A. where
(1) The adjusted annual asset
guideline repair allowance. A. is the
product of the percent of the
replacement cost. Y. and the applicable
basic annual asset guideline repair
allowance, B. as reflected by the
following equation: A = Y x (B -r 100).
(2) The percent Y is determined from
the following equation: Y-«U9— 4JE75
log X when X ia MB soiaM IBM year of
oonstrwottoo: aasT "°
(3) The applicable basic annual asset
guideline repair allowance. E is selected
from the following table consistent with
the applicable subpart: 227
FC* OETERMMMNG APWJCABCE FOA B
w
000..
GOG
KKK-
VMMOIS
124
12.S
70
4J
"Closed vent system" means a system
that is not open to the atmosphere and
that is composed of piping, connections.
and, if necessary, flow inducing devices
that transport gas or vapor from a piece
or pieces of equipment to a control
device.
"Connector" means flanged, screwed.
welded, or other joined fittings used to
connect two pipe lines or a pipe line and
a piece of process equipment.
"Control device" means an enclosed
combustion device, vapor recovery
system, or flare.
"Distance piece" means an open or
enclosed casing through which the
piston rod travels, separating the
compressor cylinder from the crankcase.
"Double block and bleed system"
means two block valves connected in
series with a bleed valve or line thai can
vent the line between the two block
valves. 227
"Equipment" means each pump.
compressor, pressure relief device.
sampling connection system, open-
ended valve or line, valve, and flange or
other connector in VOC service and any
devices or systems required by this
subpart.
"First attempt at repair" means to
take rapid action for the purpose of
stopping or reducing leakage of organic
material to atmosphere using best
practices.
"In gas/vapor service" means that the
piece of equipment contains process
fluid that is in the gaseous state at
operating conditions.
"In heavy liquid service" means that
the piece of equipment is not in gas/
vapor service or in light liquid service.
"In light liquid service" means that the
piece of equipment contains a liquid that
meets the conditions specified in
I 60.485(e).
"Liquids dripping" means any visible
leakage from the seal including
spraying, misting, clouding, and ice
formation.
"Open-ended valve or line" means
any valve, except safety relief valves,
having one side of the valve seat in
contact with process fluid and one side
open to the atmosphere, either directly
or through open piping.
"Pressure release" means the
emission of materials resulting from
system pressure being greater than set
pressure of the pressure relief device.
"Process improvement" means routine
changes made for safety and
occupational health requirements, for
energy savings, for better utility, for
ease of maintenance and operation, for
correction of design deficiencies, for
bottleneck removal, for changing
product requirements, or for
environmental control.
"Process unit" means components
assembled to produce, as intermediate
or final products, one or more of the
chemicals listed in § 60.489 of this part.
A process unit can operate
independently if supplied with sufficient
feed or raw materials and sufficient
storage facilities for the product.
"Process unit shutdown" means a
work practice or operational procedure
that stops production from a process
unit or part of a process unit. An
unscheduled work practice or
operational procedure that stops
production from a process unit or part of
a process unit for less than 24 hours is
not a process unit shutdown. The use of
spare equipment and technically
feasible bypassing of equipment without
stopping production are not process unit
shutdowns.
"Quarter" means a 3-month period:
the first quarter concludes on the last
day of the last full month during the 180
days following initial startup.
"Replacement cost" means the capital
needed to purchase all the depreciable
components in a facility. 227
"Repaired" means that equipment is
adjusted, or otherwise altered, in order
to eliminate a leak as indicated by one
of the following: an instrument reading
or 10.000 ppm or greater, indication of
liquids dripping, or indication by a
sensor that a seal or barrier fluid system
has failed.
"Sensor means a device that measures
a physical quantity or the change in a
physical quantity such as temperature.
pressure, flow rate, pH. or liquid level.
"In-situ sampling systems" means
nonextracrive samplers or in-line
samplers.
"Synthetic organic chemicals
manufacturing industry" means the
industry that produces, as intermediates
or final products, one or more of the
chemicals listed in § 60.489.
"In vacuum service" means that
equipment is operating at an internal
85
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pressure which it at least 5 kilopascals
(kPa) below ambient pressure.
"Volatile organic compounds" or VOC
meant, for the purposes of this subpart.
any reactive organic compounds as
defined in 160.2 Definitions.
"In VOC Service" means that the
piece of equipment contains or contacts
a process fluid that is at least 10 percent
VOC by weight. (The provisions of
I 60.485(d) specify how to determine
that a piece of equipment is not in VOC
service.)
IM.482-1 Standards: General.
(a) Each owner or operator subject to
the provisions of this subpart shall
demonstrate compliance with the
requirements of i 60.482-1 to { 60.482-10
for all equipment within 180 days of
initial startup.
(b) Compliance with § 60.482-1 to
i 60.482-10 will be determined by
review of records and reports, review of
performance test results, and inspection
using the methods and procedures
specified in I 60.485.
(c)(l) An owner or operator may
request a determination of equivalence
of a means of emission limitation to the
requirements of § 60.482-2. -3, -5. -6. -7.
-8. and -10 as provided in 160.484.
(2) If the Administrator makes a
determination that a means of emission
limitation is at least equivalent to the
requirements of i 60.482-2. -3, -5. -«, -7,
-6, or -10, an owner or opera-tor shall
comply with the requirements of that
determination.
(d) Equipment that is in vacuum
service is excluded from the
requirements of i 60.482-2 to § 60.482-10
if it is identified as required in
|60.488(e)l5).2"
160.482-2 StandardaOPumee In light NquM
(a)(l) Each pump in light liquid service
shall be monitored monthly to detect
leaks by the methods specified in
f 60.485(b), except as provided in
160.482-1 (c) and paragraphs (d). (e),
and (f) of this section.
(2) Each pump in light liquid service
shall be checked by visual inspection
each calendar week for indications of
liquids dripping from the pump seal.
(b)(l) If an instrument reading of
10,000 ppm or greater is measured, a
leak is detected.
{2) If there are indications of liquids
dripping from the pump seal, a leak is
detected.
(c)(l) When a leak is detected, it shall
be repaired as soon as practicable, but
not later than 15 calendar days after it is
detected, except as provided in S 60.482-
9.
(2) A first attempt at repair shall be
made no later than 5 calendar days after
each leak is detected.
(d) Each pamp equipped with a dual
mechanical seal system that includes a
barrier fluid system is exempt from the
requirements of paragraph (a), provided
the following requirements are met:
(1) Each dual mechanical seal system
is:
(i) Operated with the barrier fluid at a
pressure that is at all times greater than
the pump stuffing box pressure; or
(ii) Equipment with a barrier fluid
degassing reservoir that is connected by
a closed vent system to a control device
that complies with the requirements of
§ 60.482-10; or
(iii) Equipped with a system that
purges the barrier fluid into a process
stream with zero VOC emissions to the
atmosphere.
(2) The barrier fluid system is in
heavy liquid service or is not in VOC
service.
(3) Each barrier fluid system is
•»uipped with a sensor that will detect
lure of the seal system, the barrier
tiuid system, or both.
(4) Each pump is checked by visual
inspection., each calendar week, for
indications of liquids dripping from the
pump seals.
(5)(i) Each sensor as described in
paragraph (d){3) is checked daily or is
equipped with an audible alarm, and
(ii) The owner or operator determines.
based on design considerations and
operating experience, a criterion that
indicates failure of the seal system, the
barrier fluid system, or both.
(6)(i) If there are indications of liquids
dripping from the pump seal or the
sensor indicates failure of the seal
system, the barrier fluid system, or both
based on the criterion determined in
paragraph (d)(5)(ii). a leak is detected.
(ii) When a leak is detected, it shall be
repaired ac soon as practicable, but not
later than 15 calendar days after it is
detected, except as provided in | 80.482-
9.
(iii) A firmt attempt at repair shall be
made no later than 5 calendar days after
each leak is detected.
(e) Any pump that is designated, as
described in i 60.486(e) (1) and (2). for
no detectable emission, as indicated by
an instrument reading of less than 500
ppm above background, is exempt from
the requirements of paragraphs (a), (c).
and (d) if the pump:
(1) Has oo externally actuated shaft
penetrating the pump housing.
(2) Is demonstrated to be operating
with no detectable emissions as
indicated by an instrument reading of
less than 500 ppm above background as
measured by the methods specified in
I 60.485(c). and
(3) Is tested for compliance with
paragraph (e)(2J initially upon
designation, annually, and at other times
requested by the Administrator.
(f) If any pump-is equipped with a
closed vent system capable of capturing
and tnnapotting any leakage from the
aeal or seals to a control device that
complies with the requirements of
I 60.482-10. it is exempt from the
paragraphs
S 90.493-3 Compreaaors.
(a) Each compressor shall be equipped
with a seal system that include* a
barrier fluid system and that prevents
leakage of VOC to the atmosphere.
except aa provided in 1 80.4a2-l(c) and
paragraph (h) and (i) of this section.
(b) Each compressor seal system as
required in paragraph (a) shall be:
(1) Operated with the barrier fluid at a
pressure thct is greater than the
compressor stuffing box pressure; or
(2) Equipped with a barrier fluid
system that is connected by a closed
vent system to a control device that
complies with the requirements of
I 60.482-10; or
(3) Equipped with a system that
purges the barrier fluid into a process
stream with zero VOC emissions to the
atmosphere.
(c) The barrier fluid system shall be in
heavy liquid service or shall not be in
VOC service.
(d) Each barrier fluid system as
described in paragraph (a) shall be
equipped with a sensor that will detect
failure of the seal system, barrier fluid
system, or both.
(e)(l ) Each sensor as required in
paragraph (d) shall be checked daily or
shall be equipped with an audible alarm.
(2) The owner or operator shall
determine, based on design
considerations and operating
experience, a criterion that indicates
failure of the seal system, the barrier
fluid system, or both.
(f) If the sensor indicates failure of the
seal system, the barrier system, or both
based on the criterion determined under
paragraph (e)(2). a leak is detected.
(g)(l) When a leak is detected it shall
be repaired as soon as practicable, but
not later than 15 calendar days after it is
detected, except as provided in I 60.482-
9.
(2) A first attempt at repair shall be
made no later than 5 calendar days after
each leak is detected.
(h) A compressor is exempt from the
requirements of paragraphs (a) and (b).
if it is equipped with a closed vent
system capable of capturing and
transporting any leakage from the seal
86
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to a control device that complies with
the requirements of i 60.482-10. except
as provided in J 00.482-3(1).
(i) Any compressor that is designated,
as described in f 80.486(e) (1) and (2).
for no detectable emissions, as indicated
by an instrument reading of less than
500 ppm above background, is exempt
from the requirements of paragraphs
(a)-(h) if the compressor
' (1) Is demonstrated to be operating
with no detectable emissions, as
indicated by an instrument reading of
less than 500 ppm above background, as
measured by the methods specified in
{ 60.485(c); and
(2) Is tested for compliance with
paragraph (i)(l) initially upon
designation, annually, and at other times
requested by the Administrator.
(j) Any existing reciprocating
compressor in a process unit which
becomes an affected facility under
provisions of S 60.14 or 60.15 is exempt
.from § 60.482 (a), (b). (c), (d). (e). and (h).
provided the owner or operator
demonstrates that recasting the distance
piece or replacing the compressor are
the only options available to bring the
compressor into compliance with the
provisions of § 60.4823 (a), (b). (c). (d).
(e). and (h).
IM-4U-S
S80.4ta-4 Sti
devices in gas/
dardKPr
(a) Except during pressure releases.
each pressure relief device in gas/vapor
service shall be operated with no
detectable emissions, as indicated by an
instrument reading of less than 500 ppm
above background, as determined by the
methods specified in i 60.485(c).
0>M1) After each pressure release, the
pressure relief device shall be returned
to a condition of no detectable
emissions, as indicated by an instrument
reading of less than 500 ppm above
background, as soon as practicable, but
no later than 5 calendar days after the
pressure release, except as provided in
S 60.482-4.
(2) No later than 5 calendar days after
the pressure release, the pressure relief
device shall be monitored to confirm the
conditions of no detectable emissions.
as indicated by an instrument reading of
less than 500 ppm above background, by
the methods specified in { 60.485(c).
(c) Any pressure relief device that is
equipped with a closed vent system
capable of capturing and transporting
leakage through the pressure relief
device to a control device as described
in { 60.482-10 is exempted from the
requirements of paragraphs (a) and (b).
(a) Each sampling connection system
shall be equipped with a closed purge
system or closed vent system, except as
provided in | 60.482-1 (c).
(b) Each closed purge system or
closed vent system as required in
paragraph (a) shall:
(1) Return the purged process fluid
directly to the process line with zero
VOC emissions to the atmosphere: or
(2) Collect and recycle the purged
process fluid with zero VOC emissions
to the atmosphere: or
(3) Be designed and operated to
capture and transport all the purged
process fluid to a control device that
complies with the requirements of
i 60.482-10.
(c) In-situ sampling systems are
exempt from paragraphs (a) and (b).
1 60.412-8. Standards: Opan anded valves
(a)(l) Each open-ended valve or line
shall be equipped with a cap. blind
flange, plug, or a second valve, except
as provided in i 80.482-l(c).
(2) The cap, blind flange, plug, or
second valve shall seal the open end at
all times except during operations
requiring process fluid flow through the
open-ended valve or line.
(b) Each open-ended valve or line
equipped with a second valve shall be
operated in a manner such that the
valve on the process fluid end is closed
before the second valve is closed.
(c) When a double biock-and-bleed
system is being used, the bleed valve 01
line may remain open during operations
that require venting the line between thf
block valves but shall comply with
paragraph (a) at all other times.227
§60.4*2-7 Standards: VatoM In gas/vapor
eacvtee hi light HquM service.
(a) Each valve shall be monitored
monthly to detect leaks by the methods
specified in 160.485(b) and shall comply
with paragraphs (bHe),* except as
provided in paragraphs {f). (g). and (h).
i 60.483-1, 2, and § 60.482-l(c).
(b) If an instrument reading of 10.000
ppm or greater is measured, a leak is
detected.
(c)(l) Any valve for which a leak is
not detected for 2 successive months
may be monitored the first month of
every quarter, beginning with the next
quarter, until a leak is detected.
(2) If a leak is detected, the valve shall
be monitored monthly until a leak is not
detected for 2 successive months.227
(d)(l) When a leak is detected, it shall
be repaired as soon as practicable, but
no later than 15 calendar days after the
leak is detected, except as provided in
I 60.482-9.
(2) A first attempt at repair shall be
made no later than 5 calendar days after
each leak is detected.
(e) First attempts at repair include, but
are not limited to, the following best
practices when practicable:
(1) Tightening of bonnet bolts:
(2) Replacement of bonnet bolts:
(3) Tightening of packing gland nuts:
(4) Injection of lubricant into
lubricated packing.
(f) Any valve that is designated, as
described in i 60.486(e)(2), for no
detectable emissions, as indicated by an
instrument reading of less than 500 ppm
above background, is exempt from the
requirements of paragraph (a) if the
valve:
(1) Has no external actuating
mechanism in contact with the process
fluid,
(2) Is operated with emissions less
than 500 ppm above background as
determined by the method specified in
I d0.485(c). and
(3) la tested for compliance with
paragraph (f)(2) initially upon
designation, annually, and at other times
requested by the Administrator.
(g) Any valve that is designated, aa
described in 160.486(f)(l). as an unsafe-
to-monitor valve is exempt from the
requirements of paragraph (a) if:
(1) The owner or operator of the valve
demonstrates that the valve is unsafe to
monitor because monitoring personnel
would be exposed to an immediate
danger as a consequence of complying
with paragraph (a), and
(2) The owner or operator of the valve
adheres to a written plan that requires
monitoring of the valve aa frequently as
practicable during safe-to-monitor times.
(h) Any valve that is designated, as
described in f 60.486(0(2), as a difficult-
to-monitor valve is exempt from the
requirements of paragraph (a) if:
(1) The owner or operator of the valve
demonstrates that the valve cannot be
monitored without elevating the
monitoring personnel more than 2
meters above a support surface.
(2) The process unit within which the
valve is located either becomes an
affected facility through { 60.14 or
§ 60.15 or the owner or operator
designates less than 3.0 percent of the
total number of valves as difficult-(o-
monitor. and227
(3) The owner or operator of the valve
follows a written plan that requires
monitoring of the valve at least once per
calendar year.
87
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|M.4«2-4 Standard* Pump* and verve*
In heavy squid service, pressure relief
device* In Hght ftquid or heavy Rquid
aervtee, and flange* and other connector*.
(a) Pumps and valves in heavy liquid
service, pressure relief devices in light
liquid or heavy liquid service, and
flanges and other connectors shall be
monitored within 5 days by the method
specified in f 80.485(b) if evidence of a
potential leak is found by visual.
audible, olfactory, or any other
detection method.
(b) If an instrument reading of 10.000
ppm or greater is measured, a leak is
detected.
(c)(l) When a leak is detected, it shall
be repaired as soon as practicable, but
not later than 15 calendar days after it is
detected, except as provided in
i 00.482-9.
(2) The first attempt at repair shall he
made no later than 5 calendar days after
each leak is detected.
(d) First attempts at repair include.
but are not limited to. the best practices
described under 180.482-7(e).
|M.4t3-t Standard*: Delay of repair.
(a) Delay of repair of equipment for
which leaks have been detected will be
allowed if the repair is technically
infeasible without a process unit
shutdown. Repair of this equipment .
shall occur before the end of the next
process unit shutdown.
(b) Delay of repair of equipment will
be allowed for equipment which is
isolated from the process and which
does not remain in VOC service.
(c) Delay of repair for valves will be
allowed if:
(1) The owner or operator
demonstrates that emissions of purged
material resulting from immediate repair
are greater than the fugitive emission*
likely to result from delay of repair, and
(2) When repair procedures are
effected, the purged material is collected
and destroyed or recovered in a control
device complying with { 60.482-10.
(d) Delay of repair for pumps will be
allowed if:
(1] Repair requires the use of a dual .
mechanical seal system that includes a
barrier fluid system, and
(2) Repair is completed as soon as
practicable, but not later than 8 months
after the leak was detected.
(e) Delay of repair beyond a process
unit shutdown will be allowed for a
valve, if valve assembly replacement is
necessary during the process unit
shutdown, valve assembly supplies have
been depleted, and valve assembly
supplies had been sufficiently stocked
before the supplies were depleted. Delay
of repair beyond tne next process uim
shutdown will not be allowed unless the
next process unit shutdown occurs
sooner than 6 months after the first
process unit shutdown.
M&aa-lo Standard*: Oe**d »»rrt
eyetarn* and 4*wilu* devlc***
(a) Owners or operators of closed vent
systems and control devices used to
comply with provisions of this subpart
shall comply with the provisions of this
section.
(b) Vapor recovery systems (for
example, condensers and adsorbers)
shall be designed and operated to
recover the VOC emissions vented to
them with an efficiency of 95 percent or
greater.
(c) Enclosed combustion devices shall
be designed and operated to reduce the
VOC emissions vented to them with an
efficiency of 95 percent or greater, or to
provide a minimum residence time of
0.75 seconds at a minimum temperature
of818*C
(d)(l) Flares shall be designed for and
operated with no visible omissions as
determined by the methods specified in
§ 80.485(g). except for periods not to
exceed a total of 5 mimues during any 2
consecutive hours.
(2) Flares shall be operated with a
flame present at all times, as determined
by the methods specified in i 60.485(g).
(3) Flares shall be used only with the
net heating value of the gas being
combusted being 11.2 Ml/son (300 Btu/
scf) or greater if the flare is steam-
assisted or air-assisted: or with the net
heating value of the gas being
combusted being 7.45 M)/scm or greater
if the flare is nonassisted. The net
heating value of the gaa being
combusted shall be determined by the
methods specified in f 80.485(g).
(4) Steam-acsisted and nonasmated
flares shall be designed for and
operated with an exit velocity, as
determined by the methods specified in
§ 80.485(g)(4). less than 18 m/sec (80 ft/
sec).
(5) Flares used to comply with this
subpart shall be steam-assisted, air-
assisted, or nonassisted.
(8) Air-assisted flares shall be
designed and operated with an exit
velocity less than the velocity. V-... as
determined by the methods specified in
t 80.485(g)(5).
(e) Owners or operators of control
devices used to comply with the
provisions of this subpart shall monitor
these control devices to ensure that they
are operated and maintained in
conformance with their designs.
(f)(l) Closed vent systems shall be
designed end operated with no
detectable emissions, as indicated by an
instrument reading of less than 500 ppm
kbove background and visual
inspections, as determined by the
methods specified in i 60.485(c).
(2) Closed vent systems shall be
monitored to determine compliance with
this section initially in accordance with
180.8. annually and at other times
requested by the Administrator.
(g) Closed vent systems and control
devices used to comply with provisions
of this subpart shall be operated at all
times when emissions may be vented to
them.
f«0.4S3-1 AD
i tor
rcentagi
leaking.
(a) An owner or operator may elect to
comply with an allowable percentage of
valves leaking of equal to or lessJhan
2.0 percent
(b) The following requirements shall
be met if an owner or operator wishes to
comply with an allowable percentage of
valves leaking:
(1) An owner or operator must notify
the Administrator that the owner or
operator has elected to comply with the
allowable percentage of valves leaking
before implementing this alternative
standard, as specified in i 80.487(b).
(2) A performance test as specified in
paragraph (c) of this section shall be
conducted initially upon designation.
annually, and at other times requested
by the Administrator.
(3) If a valve leak is detected it shall
be repaired in accordance with 180.482-
7(d) and (e).
(c) Performance tests shall be
conducted in the following manner.
(1) All valves in gas/vapor and light
liquid service within the affected facility
shall be monitored within 1 week by the
methods specified in | 80.485(b).
(2) If an instrument reading of 10.000
ppm or greater is measured, a leak is
detected.
(3) The leak percentage shall be
determined by dividing the number of
valves for which leaks are detected by
the number of valves in gas/vapor and
light liquid service within the affected
facility.
(d) Owners and operators who elect
to comply with this alternative standard
shall not have an affected facility with a
leak percentage greater than 2.0 percent
160.4*3-2 Alternative standarde for
vafvee ship period leak detection and
(a)(l) An owner or operator may elect
to comply with one of the alternative
work practices specified in paragraphs
(b) (2) and (3) of this section.
(2) An owner or operator must notify
the Administrator before implementing
88
-------
one of the alternative work practices. ••
•pecifled in i 60.487(b).
(b)(l) An owner or operator shall
comply initially with the requirements
for valve* in gas/vapor service and
valves in light liquid service, as
described in I 50.482-7.
(2) After 2 consecutive quarterly leak
detection periods with the percent of
valves leaking equal to or less than 2A
an owner-or operator may begin to skip
1 of the quarterly leak detection periods
for the valves in gas/vapor and light
liquid service.
(3) After 5 consecutive quarterly leak
detection periods with the percent of
valves leaking equal to or less than 2.0,
an owner or operator may begin to skip
3 of the quarterly leak detection periods
for the valves in gas/vapor and light
liquid service.
(4) If the percent of valves leaking is
greater than 2.0, the owner or operator
shall comply with the requirements as
described in 1 60.482-7 but can again
elect to use this section.
(5) The percent of valves leaking shall
be determined by dividing the sum of '
valves found leaking during current
monitoring and valves for which repair
has been delayed by the total number of
valves subject to the requirements of
1 80.483-2.
(8) An owner or operator must keep a
record of the percent of valves found
leaking during each leak detection
period.
ftO.484 Equivalence of
(a) Each owner or operator subject to
the provisions of this subpart may apply
to the Administrator for determination
of equivalence for any means of
emission limitation that achieve* a
reduction in emissions of VOC at least
equivalent to the reduction in emissions
of VOC achieved by the controls
required in this subpart
(b) Determination of equivalence to
the equipment design, and operational
requirements of this snbpart will be
evaluated by the following guidelines:
(1) Each owner or operator applying
for an equivalence determination shall
be responsible for collecting and
verifying test data to demonstrate
equivalence of means of emission
limitation.
(2) The Administrator will compare
test data for the means of emission
limitation to test data for the equipment
design, and operational requirements.
(3) The Administrator may condition
the approval of equivalence on
requirements that may be necessary to
assure operation and maintenance to
achieve the same emission reduction as
the equipment design, and operational
requirements.
(c) Determination of equivalence to
the required work practices in this
subpart will be evaluated by the
following guidelines:
(1) Each owner or operator applying
for a determination of equivalence shall
be responsible for collecting and
verifying test date to demonstrate
equivalence of an equivalent means of
emission limitation.
(2) For each affected facility for which
a determination of equivalence Is
requested, the emission reduction
achieved by the reqmred work practice
shall be demonstrated.
(3] For each affected faculty, far
which a determination of equivalence is
requested, me emission reduction
achieved by the equivalent means of
emission limitation shall be
demonstrated.
(4) Each owner or operator applying
for a determination of equivalence shall
commit in writing to work practices)
that provide for emission redactions
equal to or greater than the eamsion
reductions achieved by the required
work practice.
(3) The Administrator will compere
the demonstrated emission redaction for
the equivalent means of emission
limitation to the demonstrated mission
reduction for the required work
practices and wifl consider the
commitment in paragraph (c)(4).
(6) The Administrator may condition
the approval of equivalence on
requirements that may be necessary to
assure operation and maintenance to
achieve the same emission redaction as
the required work practice.
(d) An owner or operator may offer a
unique approach to demonstrate the
equivalence of any equivalent means of
emission limitation.
(e)(l) After a request for
determination of equivalence is
received, the Administrator will publish
a notice in die Federal Register and
provide the opportunity for public
hearing if the Administrator judges that
the request may be approved.
(2) After notice and opportunity for
public hearing, the Administrator will
determine the equivalence of a means of
emission limitation and will publish the
determination in the Federal Register.
(3) Any equivalent means of emission
limitation* approved under this section
shall constitute a required work
practice, equipment, design, or
operational standard within the meaning
of Section lll(h)(l) of the Clean Air Act
(f)(l) Manufacturers of equipment
used to control equipment leaks of VOC
may apply to the Administrator for
determination of equivalence for any
equivalent means of emission limitation
that achieves a reduction in emissions of
VOC achieved by the equipment design,
and operational requirement! of this
subpart.
(2) The Administrator will make an
equivalence determination according to
the provisions of paragraphs (b). [c). (d).
and (e).
160.485 Teat methoda and procedures.
(a) Each owner or operator subject to
the provisions of this subpart shall
comply with the test method and
procedure requirements provided in this
section.
(b) Monitoring, as required in
({ 80.462.80.463. and 80.484, shall
comply with the following requirements:
(1) Monitoring shaU comply with
Reference Method 21.
t2) The detection instrument shall
meet the performance criteria of
Reference Method 2L
(3) The instrument shall be calibrated
before use on each day of its use by the
methods specified to Method XL
(4) Calibration gases snail be
(i) Zero air (less than 10 ppm of
hydrocarbon in air): and
(ii) A mixture of methane or n-hexane
and air at e concentration of
approximately, but less than. 10,000 ppm
methane or n-hexane.
(5) The instrument probe shall be
traversed around all potential leak
interfaces as close to the interface as
possible as described in Reference
Method 21.
(c) When equipment is tested for
compliance with no detectable
emissions as required in 5 80.482 -2(e). -
3(i), -4. -Tffl. and -10(e). the test shall
comply with the following requirement*;
(1) The requirements of paragraphs
(b)(lH4) sheH apply.
(2) The background level shall be
determined, as set forth in Reference
Method 21.
(3) The instrument probe shall be
traversed around all potential leak
interfaces as dose to the interface as
possible as described in Reference
Method 21.
(4) The arithmetic difference between
the maximum concentration Indicated
by the instrument and the background
level is compared with 500 ppm for
determining compliance.
(d)(l) Each piece of equipment within
a process unit is presumed to be in VOC
service unless an owner or operator
demonstrates that the piece of
equipment is not in VOC service. For a
piece of equipment to be considered not
in VOC service, it must be determined
that the percent VOC content can be
reasonably expected never to exceed 10
percent by weight For purposes of
8
-------
determining the perctnt VOC content to
the proceu fluid that is contained in or
contact* equipment, procedurea that
conform to the general methods
described in ASTM &4BO. B-166. E-1BO
(incorporated by reference aa apaeified
in 180.17) ahall be uaed.
(2) If an owner or operator decides to
exclude non-reactive organic
compound* from the total quantity of
organic oampooada in determining the
percent VOC content of the process
fluid, the exclusion will be allowed if:
(i) Thoae eabatances excluded are
those considered aa having negligible
photochemical reactivity by die
Administrator and
(ii) The owner or operator
demonstrates that the percent organic
content, excluding non-reactive oiganic
compounds, can be reasonably expected
never to exceed 10 percent by weight
(3)(i) An owner or operator may use
engineering judgment rather than the
procedures in paragraphs (d) (1) and (2)
of this section to demonstrate that the
percent VOC content does not exceed 10
percent by weight provided that the
engineering judgment demonstrates that
the VOC content clearly does not .
exceed 10 percent by weight. When an
owner or operator and the
Administrator do not agree on whether
a piece of equipment is not in VOC
service, however, the procedures in
paragraphs (d) (1) and (2) shall be used
to resolve the disagreement
(if) If an owner or operator determines
that a piece of equipment is in VOC
service, the determination can be
revised only after following the
procedures ia paragraphs (d) (1) and (2J.
(a) Equipment ia in light liquid service
if the fbUowmf conditions apply:
(1) The vapor pressure of one or more
of the components is greater than 0.3
kPa at 20* C. Vapor pressures may be
obtained from standard reference texts
or may be determined by ASTM 0-2879
(incorporated by reference as specified
in i 60.17).
(2) The total concentration of the pure
components having a vapor pressure
greater than CL3 kPa at 20* C is equal to
or greater than 20 percent by weight
and
(3) The fluid ia a liquid at operating
conditions.
(f) Samples used in conjunction with
paragraphs (d), (e). and (g) shall be
representative of the process fluid that
is contained in or contacts the
equipment or the gas being combusted
in the flare.
(g)(l) Reference Method 22 shall be
used to determine the compliance of
flares with the visible emission
provisions of this subpart
(2) The presence of a flare pilot flame
ahall be monitored using a thermocouple
or any other equivalent device to detect
the presence of a flame.
(3) The net heating valoe of the ges
being combusted in a flare ahall be
calculated using the following equation:
Where:
HI * Net heating value of the sample. M)/
tern: where the net enthalpy per mole of
offga* ic bated on combustion st 25'C
•nd 760 mm Ha. but the standard
temperature for determining the volume
corresponding to one mole is 20*.
K - Conttant
1.740 x to1
rA
where
•unurd I
npcrttm
""1
arc
C,» Concentration of sample component i in
ppm. ai measured by Reference Method
18 snd ASTM D2S04-67 (reapproved
1977) (incorporated by reference as
specified in 160.17).
H, - Net heat of combustion of sample
component i. kcal/g mole. The heats of
combustion may be determined using
ASTM 02382-76 (incorporated by
reference ss specified in 160.17) if
published values are not available or
cannot be calculated.
(4) The actual exit velocity of a flare
shall be determined by dividing the
volumetric flowrate (in units of standard
temperature and pressure), as
determined by Reference Method 2.2A.
2C. or 2D as appropriate: by the
unobstructed (free) cross sectional area
of the dare tip.
(5) The maximum permitted velocity.
Vm... for air-assisted flares shall be
determined by the following equation:
Vra = 8.706 + 0.7084(HT)
V... = Maximum permitted velocity. m/«ec.
8 706 = Constant.
0.7084 = Constant.
HT = The net heating value •• determined in
paragraph (g)|4).
(Sn 114 or the Clean Air Act as amended (42
U.SC. 7414||
S 60.484 Recordkeeping, requirements.
(a )(1) Each owner or operator subject
to the provisions of this subpart shall
compl> with the recordkeeping
requirements of this section.
(2) An owner or operator of more than
one affected facility subject to the
provisions of this subpart may comply
with the recordkeeping requirements for
these facilities in one recordkeeping
system if the system identifies each
record by each facility.
(b) When each leak is detected as
apecified in i 80.482-2. -3. -7. -8, and
100.483-2. the following requirements
apply:
(1) A weatherproof and readily visible
identification, marked with the
equipment identification number, shall
be attached to the leaking equipment
(2) The identification on a valve may
be removed after it has been monitored
for 2 successive months as specified in
160.482-7(c) and no leak has been
detected during those 2 months.
(3) The identification on equipment
except on a valve, may be removed after
it haa been repaired.
(c) When each leak ia detected as
specified in 161X482-1 -3. -7, -8. and
i 80.483-2, the following information
ahall be recorded in a log and shall be
kept for 2 years in a readily accessible
location:
(1) The instrument and operator
identification numbers and the
equipment identification number.
(2) The date the leak was detected
and the datea of each attempt to repair
the leak.
(3) Repair methods applied in each
attempt to repair the leak.
(4) "Above 10.000" if the maximum
instrument reading measured by the
methods specified in § 60.485(a) after
each repair attempt ia equal to or greater
than 10.000 ppm.
(5) "Repair delayed" and the reason
for the delay if a leak is not repaired
within 15 calendar days after discovery
of the leak.
(8) The signature of the owner or
operator (or designate) whoae decision
it was that repair could not be effected
without a process shutdown.
(7) The expected date of successful
repair of the leak if a leak ia not
repaired within IS days.
(8) Dates of process unit shutdown
that occur while the equipment is
unrepaired.
(9) The date of successful repair of the
leak.
(d) The following information
pertaining to the design requirements for
closed vent systems and control devices
described in i 60.482-10 shall be
recorded and kept in a readily
accessible location:
(1) Detailed schematics, design
specifications, and piping and
instrumentation diagrams.
(2) The dates and descriptions of any
changes in the design specifications.
(3) A description of the parameter or
parameters monitored, as required in
i 60 482-10(e). to ensure that control
devices are operated and maintained in
90
-------
conformance with their design and an
explanation of why that parameter (or
parameters) was selected for the
monitoring.
(4) Periods when the closed vent
systems and control devices required in
i 60.482-2. -3. -4, and -5 are not operated
as designed, including periods when a
flare pilot light does not have a flame.
(5) Dates of startups and shutdowns of
the closed" vent systems and control
devices required in } 60.482-2, -3. -4. and
•5.
, (e) The following information
pertaining to all equipment subject to
the requirements in i 60.482-1 to -10
shall be recorded in a log that is kept in
a readily accessible location:
(1) A list of identification numbers for
equipment subject to the requirements
of this subpart.
(2)(i) A list of identification numbers
for equipment that are designated for no
detectable emissions under the
provisions of i 60.482-2(e). -3(i) and
•7(f).
(ii) The designation of equipment as
subject to the requirements of § 60.482-
2(e). -3(i). or -7(f] shall be signed by the
owner or operator.
(3) A list of equipment identification
numbers for pressure relief devices
required to comply with $ 60.482-4.
(4)(i) The dates of each compliance
test as required in i 60.482-2(6), -3(i). -4.
and -7(f).
(ii) The background level measured
during each compliance test.
(iii) The maximum instrument reading
measured at the equipment during each
compliance test.
(5) A list of identification numbers for
equipment in vacum service.
(f) The following information
pertaining to all valves subject to the
requirements of $ 60.482-7 (g) and (h)
shall be recorded in a log that is kept in
a readily accessible location:
(1) A list of identification numbers for
valves that are designated as unsafe-to-
monitor, an explanation for each valve
stating why the valve is unsafe-to-
monitor, and the plan for monitoring
each valve.
(2) A list of identification numbers for
valves that are designated as difficult-
to-monitor, an explanation for each
valve stating why the valve is difficult-
to-monitor, and the schedule for
monitoring each value.
(g) The following information shall be
recorded for valves complying with
S 60.483-2:
(1) A schedule of monitoring
(2) The percent of valves found
leaking during each monitoring period.
(h) The following information shall be
recorded in a log that is kept in a readily
accessible location:
(1] Design criterion required in
i 80.482-2(d)(5) and | 60.482-3(e)(2} and
explanation of the design criterion; and
(2) Any changes to this criterion and
the reasons for the changes.
(i) The following information shall be
recorded hi a log that it kept in a readily
accessible location for use in
determining exemption* a* provided in
i 60.480(d):
(1) An analysis demonstrating the
design capacity of the affected facility.
(2) A statement luting the feed or row
materials and products from the affected
facilities find an analysis demonstrating
whether these cheoiicab are heavy
liquids or beverage alcohol and
(3) An analysis demonstrating that
equipment is not in VOC service.
. (j) Information and data used to
demonstrate that a piece of equipment is
not in VOC service shall be recorded in
a log that is kept In a readily accessible
location.
(k) The provisions of § S 80.7 (b) and
(d) do not apply to affected facilities
subject to this subpart
(Sec. 114 of the dean Air Ad as eoMnded (42
U.S.C. 7414))
(Approved by 0* Office of kianafcawat mod
Budget undar UM oontrai auariMr 2080-0012)
JftO.487 naportmu flsnulrsnients.
(a) Each owner or operator subject to
the provisions of this subpart shall
submit semiannual reports to the
Administrator beginning six months
after the initial start up date.
(b) The initial semiannual report to
the Administrator shall include the
following information:
(1) Process unit identification.
(2) Number of valves subject to the
requirements of f 80.462-7, excluding
those valves designated for no
detectable emissions under the
provisions of § 00.482-7(0-
(3) Number of pumps tnhyict to die
requirements of $ 60.402-2,
those pumps designated for no
detectable emissions under the
provisions of i 80.4BZ-2(e) and those
pumps complying with ( 60.482-2(0-
(4) Number of compressors subject to
the requirements of { 60.482-3.
excluding those compressors desi^uted
for no detectable emissions under the
provisions of f £0.482^30) and those
compressors complying with 1 00.462-
3(h).
(c) All semiannual reports to the
Administrator shall include the
following information. f""man'T^ from
the information in 1 60.486:
(1) Process unit identification.
(2) For each month during the
semiannual reporting period.
(i) Number of valves for which leaks
were detected as described in
1 90.482(7}(b) or | 60,483-2,
(ii) Number of varies for which leaks
were not reported as repaired in
1 60.483-ndKU777
(iii) Number of pups for wmeh leaks
were detected as described mil 00.482-
(iv) Number of pumps for which leaks
erer not repaired as required in
Ii 80.482-2lcXD and (dMSflii).
(v) Number of compressors for which
leaks were detected as described in
160.482-4(0.
(vi) Number of compressors for which
leaks were aot repaired as required u
1 80.482-JkKU and227
(vii) The acts that explain each delay
of repair and, where appropriate, why a
process orn't shutdown was technically
infeasible.
(3) Dates of process mdt shutdowns
which occurred within the semianmal
reporting period.
(4) Revisions to Items reported
according to paragraph (b) if changes
have occurred since the initial report or
subsequent revisions to the initial
lepoiL
(d) Aa owner or opertor alerting to
comply with the provisions of ii 6O483-
1 and -2 shall notify the Administrator
of the alternative standard selected 90
days before implementiag either of the
provisions,
(e) An owner or operator shall report
the results of all performance tests in
accordance with i 00.8 of the General
Provisions. The provisions of 1 6O8(dl
do not apply to affected facilities subject
to the provisions of this sobpart except
that an owner or operator most notify
the Administrator of the schedule for the
initial performance tests at least 90 days
before the initial performance tests.
(f) The requirements of paragraphs {a)
through (c) of this subsection remain in
force until and unless EPA. ta delegating
enforcement authority to a State under
Section lll(c) of the Act approves
reporting requirements or an alternative
means of compliance surveillance
adopted by such State, hi mat event
affected sources within the State wfB be
relieved of the obligation to comply with
the requirements of paragraphs (a)
through (c) of this subsection, provided
that they comply with the requirements
established by the State.
(S«c. 114 of the Clean Air Act u amended {42
U.S.C. 7414U
Approved by the Oolot of ManagesiaM and
Budget under tbm control Mimbcr 2000-0912)
91
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§ 60.4M Reconstruction.
For the purposes of this subpart.
(a) The cost of the following
frequently replaced components of the
facility shall not be considered in
calculating either the "fixed capital cost
of the new components" or the "fixed
capital costs thai would be required to
construct a comparable new facility"
under § 60.15: pump seals, nuts and
bolts, rupture disks, and packings.
(b) Under { 60.15, the "fixed capital
cost of new components" includes the
fixed capita] cost of all depreciable
components (except components
specified in § 60.468 (a)) which are or
will be replaced pursuant to all
continuous programs of component
replacement which are commenced
within any 2-year period following the
applicability date for the appropriate
subpart. (See the "Applicability and
designation of affected facility" section
of the appropriate subpart.) For
purposes of this paragraph.
"conunenced" means that an owner or
operator has undertaken a continuous
program of component replacement or
that an owner or operator has entered
into a contractual obligation to
undertake and complete, within a
reasonable time, a continuous program
of component replacement.
rio* produced by
CAS Mo
MI-04-1
I60.4M Us* of ctwmteato pro
affected facHttie*.
(a) The following chemicals are
produced, as intermediates or final
products, by process units covered
under this subpart The applicability
date for process units producing one or
more of these chemicals i» January 5.
1961.
SfHI-U-4-
WO-M-7..
•S-31-0-
M-M-
100-41-*-
100-M-*.
1SO-t1-4 —
100-44-7 —
m-n-a—
•a-«2-4
•O-OS-7
10-W-1
I74»7-«1-4_
10S-M-0—
123-M-
TS-1-
CASMo <
MtfOOM.
5M-1V4
M-Z3-S
•004-35-7
79-11-*
106-W-*
96-SI-3
110-W-7*
13Z2-0»-1.
Bifffl phonoL
1319-77-3
4170-30-0
37t4-«6-0
w-u-a
eo-is-»
372-0»4
106-77-4
10S-77-0
110-8Z-7.
106-83-0.
1OB-W-1
1
tO«-*1-t
111.7S-4
111-30-1
92
-------
25322-01-4
1321-12-*..
27215-9S-4
251S4-S2-3
271IV2*-*
26471-42-5
1333-07-4
104-15-4'
«•-$•-•...
2W1S.12-4
106-
70-3. 120-62
of Ownwau Sam* •omwm or mom* rat m i
1» turxurot do not KM* CAS nunfem Mugrw
Th> sttnd*ro> apply to aM ot Vi* cnamcatt Mki
CAS run«Mn «•*• bMn aagrMt V not
•No CAS numdwui h*v« Own i
Proposed/effective
46 FR 1136. 1/5/81
Promulgated
48 FR 48328. 10/18/83 (206)
Revised
48 FR 22598, 5/30/84 (227)
49 FR 26738. 6/29/34 (230)
M-70-2
1S6-43-4
106-AS-2
B •onwrs. or nunurM coni4»n«i ttM
•CAS numtMr* tor torn* ot Vw
93
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Subpart XX— Standards of
Psrformanca for Bulk Oaaoflna
Tarmlnato"3
fW.500 AppfcaMMyanddMigMtlonof
(•) The affected facility to which the
provision* of thii lubpart apply is the
total of all the loading racks at a bulk
gasoline terminal which deliver liquid
product into gasoline tank trucks.
(b) Each-facility under paragraph (a)
of this section, the construction or
modification of which is commenced
after December 17, 1980. is subject to the
provisions of this subpart.
(c) For purposes of this subpart, any
replacement of components of an
existing facility, described in paragraph
I 80.500(a). commenced before August
18. 1963 in order to comply with any
emission standard adopted by a State or
political subdivision thereof will not be
considered a reconstruction under the
provisions of 40 CFR 60.15.
[Note: Tht intent of these standards is to
•••<•!<«• the emuwoos of VOC through the
application of best demonstrated
technologies (BUT). The numerical emission
limits in thii standard are expressed in terms
of total organic compounds. This emission
limit reflects the performance of BUT.)
ftO.SM Oeflnmone.
Hie terms used in this subpart an
defined in the Clean Air Act in 1 60.2 of
this part or in this section as follows:
"Bulk gasoline terminal" means any
gasoline facility which receives gasoline
by pipeline, ship or barge, and has a
gasoline throughput greater than 75.700
liters per day. Gasoline throughput shall
be the nym1""1" calculated design
throughput as may be limited by
compliance with an enforceable
condition under Federal. State or local
law and discoverable by the
Administrator and any other person.
"Continuous vapor processing
system" means a vapor processing
system that treats total organic
compounds vapors collected from
gasoline tank trucks on a demand basis
without intermediate accumulation in a
vapor holder.
"Existing vapor processing system"
means a vapor processing system
[capable of achieving emissions to the
atmosphere no greater than 80
milligrams of total organic compounds
per liter of gasoline loaded], the
construction or refurbishment of which
was commenced before December 17.
1980. and which was not constructed or
refurbished after that date.
"Gasoline" means any petroleum
distillate or petroleum distillate/alcohol
blend having a Reid vapor pressure of
27.6 kilopascals or greater which is used
as a fuel for internal combustion
engines.
"Gasoline tank truck" means a
delivery tank truck used at bulk gasoline
terminals which is loading gasoline or
which has loaded gasoline on the
immediately previous load.
"Intermittent vapor processing
system" means a vapor processing
system that employs an intermediate
vapor holder to accumulate total organic
compounds vapors collected from
gasoline tank trucks, and treats the
accumulated vapors only during
automatically controlled cycles.
"Loading rack" means the loading
arms, pumps, meters, shutoff valves,
relief valves, and other piping and
valves necessary to fill delivery tank
trucks.
"Refurbishment" means, with
reference to a vapor processing system,
replacement of components of, or
addition of components to, the system
within any 2-year period such that the
fixed capital cost of the new
components required for such
component replacement or addition
exceeds 50 percent of the cost of a
comparable entirely new system.
Total organic compounds" means
those compounds measured according to
the procedures in I 60.503.
"Vapor collection system" means any
equipment used for containing total
organic compounds vapors displaced
during the loading of gasoline tank
trucks.
"Vapor processing system" means all
equipment used for recovering or
oxidizing total organic compounds
vapors displaced from the affected
facility.
"Vapor-tight gasoline tank truck"
means a gasoline tank truck which has
demonstrated within the 12 preceding
months that its product delivery tank
will sustain a pressure change of not
more than 750 pascals (75 mm of water)
within 5 minutes after it is pressurized
to 4.500 pascals (450 mm of water). This
capability is to be demonstrated using
the pressure test procedure specified in
Reference Method 27.
f 80.502 Standard for VototU* Organic
Compound (VOC) emieetone front bu4k
gaaoUne tenmnala.
On and after the date on which
I 6tX8(a) requires a performance test to
be completed, the owner or operator of
each bulk gasoline terminal containing
an affected facility shall comply with
the requirements of this section.2
(a) Each affected facility shall be
equipped with a vapor collection system
designed to collect the total organic
compounds vapors displaced from tank
trucks during product loading.
(b) The emissions to the atmosphere
from the vapor collection system due to
the loading of liquid product into
gasoline tank trucks are not to exceed 35
milligrams of total organic compounds
per liter of gasoline loaded, except as
noted in paragraph (c) of this section
(c) For each affected facility equipped
with an existing vapor processing
system, the emissions to the atmosphere
from the vapor collection system due to
the loading of liquid product into
gasoline tank trucks are not to exceed 80
milligrams of total organic compounds
per b'ter of gasoline loaded.
(d) Each vapor collection system shall
be designed to prevent any total organic
compounds vapors collected at one
loading rack from passing to another
loading rack.
(e) Loadings of liquid product into
gasoline tank trucks shall be limited to
vapor-tight gasoline tank trucks using
the following procedures:
(1) The owner or operator shall obtain
the vapor tightness documentation
described in | 80.505(b) for each
gasoline tank truck which is to be
loaded at the affected facility.
(2) The owner or operator shall
require the tank identification number to
be recorded as each gasoline tank truck
is loaded at the affected facility.
(3) The owner or operator shall cross-
check each tank identification number
obtained in (e)(2) of this section with the
file of tank vapor tightness
documentation within 2 weeks after the
corresponding tank is loaded.
(4) The terminal owner or operator
shall notify the owner or operator of
each nonvapor-tight gasoline tank truck
loaded at the affected facility within 3
weeks after the loading has occurred.
(5) The terminal owner or operator
shall take steps assuring that the
nonvapor-tight gasoline tank truck will
not be reloaded at the affected facility
until vapor tightness documentation for
that tank is obtained.
(6) Alternate procedures to those
described in (e)(l) through (5) of this
section for limiting gasoline tank truck
loadings may be used upon application
to. and approval by, the Administrator.
(0 The owner or operator shall act to
assure that loadings of gasoline tank
trucks at the affected facility are made
only into tanks equipped with vapor
collection equipment that is compatible
with the terminal's vapor collection
system.
(g) The owner or operator shall act to
assure that the terminal's and the tank
truck's vapor collection systems are
connected during each loading of a
gasoline tank truck at the affected
facility. Examples of actions to
94
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accomplish this include training drivers
in the hookup procedures and posting
\ isible reminder signs at the affected
loading racks.
(h) The vapor collection and liquid
loading equipment shall be designed and
operated to prevent gauge pressure in
the delivery tank from exceeding 4.500
pascals (450 nun of water) during
product loading. This level is not to be
exceeded when measured by the
procedures'specified in f 60.503(b).
(i) No pressure-vacuum vent in the
bulk gasoline terminal's vapor collection
system shall begin to open at a system
pressure less than 4.500 pascals (450 mm
of water).
(j) Each calendar month, the vapor
collection system, the vapor processing
system, and each loading rack handling
gasoline shall be inspected during the
loading of gasoline tank trucks for total
organic compounds liquid or vapor
leaks. For purposes of this paragraph.
detection methods incorporating sight.
sound, or smell are acceptable. Each
detection of a leak shall be recorded and
the source of the leak repaired within 15
calendar days after it is detected.
(Approved by the Office of Management and
Budgerunder control number 2060-0006)
160 JOS T«»t methods and procedure*.
(a) Section 60.8(0 does not apply to
the performance test procedures
required by this subpart.
(b) For the purpose of determining
compliance with $ 60.502(h). the
following procedures shall be used:
(1) Calibrate and install a pressure
measurement device (liquid manometer,
magnehelic gauge, or equivalent
instrument), capable of measuring up to
500 mm of water gauge pressure with
±2.5 mm of water precision.
(2) Connect the pressure measurement
device to a pressure tap in the terminal's
vapor collection system, located as close
as possible to the connection with the
gasoline tank truck.
(3) During the performance test.
record the pressure every 5 minutes
while a gasoline tank truck is being
loaded, and record the highest
instantaneous pressure that occurs
during each loading. Every loading
position must be tested at least once
during the performance teat.213
(c) For thi> purpose of determining
compliance with the mass emission
limitations of $ 60.502(b) and (c). the
following reference methods shall be
used:
(1) For the determination of volume at
the exhaust vent:
(i) Method 2B for combustion vapor
processing systems.
(it) Method 2A for all other vapor
processing systems.
(2) For the determination of total
organic compounds concentration at the
exhaust vent. Method 25A or 25B. The
calibration gas shall be either propane
or butane.
(d) Immediately prior to a
performance test required for
determination of cr.-npliance with
i 80.502(b). (c). and (h). all potential
sources of vapor leakage in the
terminal's vapor collection system
equipment shall be monitored for leaks
using Method 21. The monitoring shall
be conducted only while a gasoline tank
truck is being loaded. A reading of
10.000 ppmv or greater as methane shall
be considered a leak. All leaks shall be
repaired prior to conducting the
performance test.
(e) The test procedure for determining
compliance with { 60.502(b) and (c) is as
follows:
(1) All testing equipment shall be
prepared and installed as specified in
the appropriate test methods.
(2) The time period for a performance
test shall be not less than 6 hours.
during which at least 300.000 liters of
gasoline are loaded. If the throughput
criterion is not met during the initial 6
hours, the test may be either continued
until the throughput criterion is met, or
resumed the next day with another
complete 6 hours of testing. As much as
possible, testing should be conducted
during the 9-hour period in which the
highest throughput normally occurs.
(3) For intermittent vapor processing
systems:
(i) The vapor holder level shall be
recorded at the start of the performance
test. The end of the performance test
shall coincide with a time when the
vapor holder is at its original level.
(ii) At least two startups and
shutdowns of the vapor processor shall
occur during the performance test If this
does not occur under automatically
controlled operation, the system shall be
manually controlled.
(4) The volume of gasoline dispensed
during the performance test period at all
loading racks whose vapor emissions
are controlled by the processing system
being tested shall be determinpd This
volume may be determined from
terminal records or from gasoline
dispensing meters at each loading rack.
(5) An emission testing interval shall
consist of each 5-mmute period during
the performance test. For each interval
(i) The reading from each
measurement instrument shall be
recorded, and
(11) The volume exhausted and the
average total organic compounds
concentration in the exhaust vent shall
be determined, as specified in the
appropriate test method. The average
total organic compounds concentration
shall correspond to the volume
measurement by taking into account the
sampling system. response time.
(6) The mass emitted during each
testing interval shall be calculdted as
fojlows:
where
M«, = m«s* of total organic compounds
emitted during testing interval :. ng
V,.= volume of air-vapor mixture exhausted
m*. at standard conditions.
C,= total organic compound* concentration
(at measured] at the exhaust vent, pprv.v
K = density of calibration ga*. mg/m1 at
standard condition!
-VJ3X10* for propane
- 1.41 x 10*. for butane 2 1 3
• -standard condition*. 20'C and 760 mm Hg
(7) The total organic compounds mass
emissions shall be calculated as follows:
a
X K,
where: 2 1 3
E— mas* of total organic compounds emitted
per volume of gasoline loaded, mg/ liter.
MM s mass of total organic compounds
emitted during testing interval i. mg.
L> total volume of gasoline loaded, liters.
n= number of testing intervals.
(f) The owner or operator may adjust
the emission results to exclude the
methane and ethane content in the
exhaust vent by any method approved
by the Administrator
(See. 114 of the Clean Air Act as amended (42
U S.C. 7414)|
(Approved by the Office of Management and
Budget under control number 2060-0006 )
{60.504 ( Reserved L
J 60.505 Reporting and recordkeeping
(a) The tank truck vapor tightness
documentation required under
160.502(e)(1) shall be kept on file at the
terminal in a permanent form available
for inspection.
(b) The documentation file for each
gasoline tank truck shall be updated at
least once per year to reflect current test
results as determined by Method 27
This documentation shall include, as a
minimum, the following information.
• (1) Test Title: Gasoline Delivery Tank
Pressure Test— EPA Reference Method
95
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(2) Tank Owner and Address.
(3) Tank Identification Number.
(4) Testing Location.
(5) Date of Test.
(6) Tester Name and Signature.
(7) Witnessing Inspector, if any:
Name. Signature, and Affiliation.
(8) Test Results: Actual Pressure
Change in 5 minutes, mm of water
(average for 2 runs).
(c) A record of each monthly leak
inspection-required under i 60.502(j)
sh-.ll be kept on file at the terminal for
at least 2 years. Inspection records shall
include, as a minimum, the following
information:
(I) Date of Inspection.
(2) Findings (may indicate no leaks
discovered: or location, nature, and
seventy of each leak).
(3) Leak determination method.
(4) Corrective Action (date each leak
repaired: reasons for any repair interval
in excess of 15 days).
(5) Inspector Name and Signature.
(dj The terminal owner or operator
shall keep documentation of all
notifications required under
t 60.502(e)(4) on file at the terminal for
at least 2 years.
(e) [Reserved].
(f) The owner or operator of an
affected facility shall keep records of ail
replacements or additions of
components performed on an existing
vapor processing system for at least 3
years.
[Sec. 114 of the Clean Air Act as amended (42
U.S.C. 7414))
(Approved by the Office of Management and
Budget under control number 2060-OOOfi )
{•0.50* ItoCQfwtruetlon.
For purposes of this subpart:
(a) The cost of the following
frequently replaced components of the
affected facility shall not be considered
in calculating either the "fixed capital
cost of the new components" or the
"fixed capital costs that would be
required to construct a comparable
entirely new facility" under $ 60.15.
pump seals, loading arm gaskets and
swivels, coupler gaskets, overfill sensor
couplers and cables, flexible vapor
hcses. and grounding cables and
connectors.
(b) Under { 60.15. the "fixed capital
cost of the new components" includes
the fixed capital cost of all depreciable
components [except components
specified in { 60.506(a)| which are or
will be replaced pursuant to all
continuous programs of component
replacement which are commenced
within any 2-year period following
December 17.1980. For purposes of this
paragraph, "commenced" means that an
owner or operator has undertaken a
continuous program of component
replacement or that an owner or
operator has entered into a contractual
obligation to undertake and complete.
within a reasonable time, a continuous
program of component replacement.
(Sec. 114 of the Clean Air Act a* amended (42
U.S.C. 7414))
Proposed/effective
45 FR 83126, 12/17/80
Promulgated
48 FR 37578, 8/18/83 (195)
Revised
48 FR 56S80, 12/22/83 (213)
96
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Subpart GGG—Standard* of
Eafformanca for Equipment Laaks of
VOC to Petroleum Refineries "7
IW.S90 AppllcaMttty and designation of
affected fae»ty.
(a)(l) The provisions of this subpart
apply to affected facilities in petroleum
refineries.
(2) A compressor is an affected
facility.
(3) The group of all the equipment
(defined in i 60.591) within a process
unit is an affected facility.
(b) Any affected facility under
paragraph (a) of this section that
commences construction or modification
after January 4.1983. is subject to the
requirements of this subpart.
(c) Addition or replacement of
equipment (defined in § 60.591) for the
purpose of process improvement which
is accomplished without a capital
expenditure shall not by itself be
considered a modification under this
subpart.
(d) Facilities subject to Subpart W or
Subpart KKK of 40 CFR Part 60 are
excluded from this subpart.
feojai Deflnittone.
As used in this subpart. all terms not
defined herein shall have the meaning
gfven them in the Act. in Subpart A of
Part 60. or in Subpart W of Part 60. and
the following terms shall have the
specific meanings given them.
"Alaskan North Slope" means the
approximately 60.000 square mile area
extending from the Brooks Range to the
Arctic Ocean.
"Equipment" means each valve, pump.
pressure relief device, sampling
connection system, open-ended valve or
line, and flange or other connector in
VOC service. For the purposes of
recordkeeping and reporting only.
compressors are considered equipment.
"In Hydrogen Service" means that a
compressor contains a process fluid that
meets the conditions specified in
160.593(b).
"In Light Liquid Sen-ice" means that
the piece of equipment contains a liquid
that meets the conditions specified in
f 60.593(c).
"Petroleum Refinery" means any
facility engaged in producing gasoline.
kerosene, distillate fuel oils, residual
fuel oils, lubricants, or other products
through the distillation of petroleum, or
through the redistillation, cracking, or
reforming of unfinished petroleum
derivatives.
"Petroleum" means the crude oil
removed from the earth and the oils
derived from tar sands, shale, and coal.
"Process Unit" means components
assembled to produce intermediate or
final products from petroleum.
unfinished petroleum derivatives, or
other intermediates: a process unit can
operate independently if supplied with
sufficient feed or raw materials and
sufficient storage facilities for the
proJurt
f«0.5»? Standards.
(a) Each owner or operator subject to
the provisions of this subpart shall
comply with the requirements of
5 60.482-1 to i 60.482-10 as soon as
practicable, but no later than 180 days
after initial startup.
(b) An owner or operator may elect to
comply with the requirements of
J 60.4S.V1 and § 60.483-2.
(c) An owner or operator may apply to
the Administrator for a determination of
equivalency for any means of emission
limitation that achieves a reduction in
emissions of VOC at least equivalent to
the reduction in emissions of VOC
achieved by the controls required in this
subpart. In doing so. the owner or
operator shall comply with requirements
of i 60.484.
(d) Each owner or operator subject to
the provisions of this subpart shall
comply with the provisions of { 60.485
except as provided in { 60.593.
(e) Each owner or operator subject, to
the provisions of this subpart shall
comply with the provisions of { 60.486
and § 60.487.
(Sec 114 of Clean Air Ac: a* amended (42
U.SC.74K!)
f 60.593 Eiceptiona.
(a) Each owner or operator subject to
the provisions of this subpart may
comply with the following exceptions to
the provisi-jns of Subpart VV.
(b)(l) Compressors in hydrogen
service are exempt from the
requirements of f 60.592 if an owner or
operator demonstrates that a
compressor is in hydrogen service.
(2) Each compressor is presumed not
be be in hydrogen service unless an
owner or operator demonstrates that the
piece of equipment is in hydrogen
service. For a piece of equipment to be
considered in hydrogen service, it must
be determined that the percent hydrogen
content can be reasonably expected
always to exceed 50 percent by volume.
For purposes of determining the percent
hydrogen content in the process fluid
that is contained in or contacts a
compressor, procedures that conform to
the general method described in ASTM
E-260. E-168, or E-169 (incorporated by
reference as specified in J60.17) shall be
used.
(3)(i) An owner or operator may use
engineering judgment rather than
procedures in paragraph (b)(2) of this
section to demonstrate that the percent
content exceeds 50 percent by volume.
provided the engineering judgment
demonstrates that the content clearly
exceeds 50 percent by volume. When an
owner or operator and the
Administrator do not agree on whether
a piece of equipment is in hydrogen
service, however, the procedures in
paragraph (b)(2) shall be used to resolve
the disagreement.
(ii) If an owner or operator determines
that a piece of equipment is in hydrogen
service, the determination can be
revised only after following the
procedures in paragraph (b)(2).
(c) Any existing reciprocating
compressor that becomes an affected
facility under provisions of 5 60.14 or
| 60.15 is exempt from i 60.482 (a), (b).
(c). (d). (e). and (h) provided the owner
or operator demonstrates that recasting
the distance piece or replacing the
compressor are the only options
available to bring the compressor into
compliance with the provisions of
160.482 (a), (b). (c). (d). (e). and (h).
(d) An owner or operator may use the
following provision in addition to
160.485(e): Equipment is in light liquid
service if the percent evaporated is
greater than 10 percent at 150'C as
determined by ASTM Method D-86
(incorporated by reference as specified
in i 60.18).
(e) Pumps in light liquid service and
valves in gas/vapor and light liquid
service within a process unit that is
located in the Alaskan North Slope are
exempt from the requirements of
i 60.482-2 and § 60.482-7.
Proposed/effect ^ve
48 FR 279, 1/4/83
Promulgated
49 FR 22598, 5/30/84 (227)
97
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PART60-CAMENOED]
40 CFR Part 60 is amended as follows:
1. By Adding a new Subpart GGG as
follows:
Subpart GGG— Standard* of Performance
for Equipment Leaks of VOC In Petroleum*
Sac. '
60.590 Applicability and designation of
affected facility.
60.591 Definitions.
60.592 Standards.
60.593 Exceptions.
eo.594-eo.599 [Reserved}
Subpart GGG—Standards of '1
Performance for Equipment Leaks of
VOCln Petroleum Refineries _,* , - .,'-.
J 6&590 AppttcabWty and designation of .
affected faculty. : - , ^- --*~ <»
(a)tlj The proviisioas of this subpart'
apply to affected facilities in petroleum
refineries.' ' ' ~_: ; * " .,.."'.'^'."„
(2) A compressor1 is an affected * "..
facility. v" • I " , ."j;
"(3) The group of all the equipment
{defined-in § 60.591} within a process . _-
unit is an affected facility. .V ..
• (b) Any affected facility under
paragraph (aj of this section that
• commences construction or modification
. 'after January 4,1983, is subject to the
requirements of this subparL - . . •
. ~- (e) Addition or replacement of ;
equipment (defined in § 60.591] for the
purpose of process improvement which
is accomplished without a capital
expenditure shall not by itself be
considered a modification under this ^
snbpart - , '
(d) Facilities subject to Subpart W or
Subpart KKK of 40 CFR Part 60 are
excluded from this subpart. , ,
• > . .
J6OJ91 Oeflntttona.
As used, in this subpart all terms not
defined herein shall have the meaning
given them in the Act in Subpart A of
Part 60, or in Subpart W of Part 60, and
. the following terms shall have the
specific meanings given them.
"Alaskan North Slope" means the
approximately 69.000 square mile area
extending from the Brooks Range to the
Arctic Ocean.
"Equipment" means each valve, pump,
pressure relief device, sampling
connection system, open-ended valve or
line, and flange or other connector in
VOC service. For the purposes of
recordkeeping and reporting only,
compressors are considered equipment.
"In Hydrogen Service" means that a
compressor contains a process fluid that
meets the conditions specified in
§ 60.593(b). s
"In Light Liquid Service" means that
. the piece of equipment contains a liquid
that meets, the conditions specified in
9 60.593(c).
"Petroleum Refinery" means any
facility engaged in producing gasoline,
kerosene, distillate .fuel oils, residual
fuel oils, lubricants, or other products
through the distillation of petroleum, or
through the redistillation, cracking, or
reforming of unfinished petroleum
derivatives.
-------
-"Petroleum" means the crude oil
removed from the earth and the oils -
derived from tar sands, shale, and coal.
"Process Unit" means components
assembled to produce intermediate or
final products from petroleum,
unfinished petroleum derivatives, or
other intermediates; a process unit can
operate independently if supplied with
sufficient feed or raw materials and
sufficient storage facilities for the
product.
§60.592 Standards.
(a) Each owner or operator subject to '
the provisions of this subpart shall
comply with the requirements of
§ 60.482-1 to § 60.482-10 asioon as
practicable, but no later than 180 days
after initial startup.
(b) An owner or operator may elect to
comply with the requirements of
S 60.483-1 and § 60.483-2.
(c) An" owner or operator may apply to
the Administrator for a determination of
equivalency for any means of emission
limitation that achieves a reduction in
emissions of VOC at least equivalent to
the reduction in emissions of VOC
. achieved by the controls required in this
subpart. In doing so, the owner or
operator shall comply with requirements
of j 60.484; - ._
(d) Each owner or operator subject to
the provisions of this subpart shall — .
comply with the provisions of 5 60.485
except as provided in S .60.593.
(e)'Each owner or operator subject to
the provisions of this subpart shall
comply with the provisions of S 60.486
and 560.487. --_.,-
(Sec. 114 of Clean Air Act as amended (42 -
US.P.7414)) - ' " .
560.583 Exception^.'-' ^ V'. -
(a) Each owner or operator subject to
the provisions of this subpart may •-.-—- ,
comply with the following exceptions to
the provisions of Subpart W. - ••
(b)(l) Compressors in hydrogen
service are exempt from the
requirements of § 60.592 if an owner, or
operator demonstrates that a '
compressor is in hydrogen service. - .
(2) Each compressor is presumed not
be be in hydrogen service unless an .<
owner or operator demonstrates that the
piece of equipment is in hydrogen
service. For a piece of equipment to be :;-
considered in hydrogen service, it must"
be determined that the percent hydrogen •
content can be reasonably expected-;. •'
always to exceed 50 percent by volume. '
For purposes of determining the percent- •
hydrogen content in the process fluid *
that is contained in or contacts a .•' : . -'
compressor, procedures that conform to
the general method described in ASTM
E-280, Er-168, or E-169 (incorporated by
- reference as specified in 560.17) shall be
used.
(3)(i) An owner or operator may use
engineering judgment rather than
procedures in paragraph (b)(2) of this
section to demonstrate that the percent
.content exceeds 50 percent by volume,
provided the engineering judgment -
demonstrates that the content clearly
exceeds 50 percent by volume. When an
owner or operator and the - / '
Administrator do not agree on whether
a piece of equipment is in hydrogen
service, however, .the procedures in
paragraph (b)(2) shall be used to resolve
the disagreement..'
(ii}If an owner or operator determines
that a piece of equipment is in hydrogen
service, the determination can be
revised only after following the
proceduresin paragraph (b)(2). '-".'"• .
(c) Any existing reciprocating "' --' • *.
compressor that becomes an Effected
facility under provisions of 5 60.14 or .
S 60.15 is exempt front 5 60.482 (a], (b),
(c), (d), (e), and fh) provided the owner
or operator demonstrates that recasting
: the distance piece or replacing the
- compressor are the only options. ;' - '
available td~bring the compressor into
compliance with the 'provisions of
. 5 «0.482 (a). (b),-(c), (d), (e), and (h).
(d) An owner or operator may use the
following provision in-addition to " -
5 60.485(e): Equipment is in light liquid
service if the percent evaporated is * •'.-:
greater than 10 percent at 150'C as \\
determined by ASTM Method D-88 -% "
(incorporated by reference as specified
in 5 60.18)., -•/. ^ ••- ^ '• .? >£/"-;•- <
- (e) Pumps in light liquid service and>, -
valves in gas/vapor and light liquid"* -../*-•
'service within a process unit that is • •>- •'-
- located in the Alaskan North Slope are'' • -
exempt from the requirements af»*':. - ^ - '
5-60.482-2 and 5 60.482-7.•*•:.~ J~ :.:- -^ '
2. By adding in .alphabeticarbjrder the ~
new terms "capital expenditure,"!^ ...,_
"double block and bleed-system," and -
"replacement cost" in 5 60.481 of
Subpart'Vy as follows.*, v /-.", T -
$60481 Deflntttona.:. -.~~>~: >;.' ^-'
"Capital 'expenditure", means, in - "x
addition to the definition in 40 CFR 80^,'
an expenditure for a physical or ~'.' -- ^
operational change to an-exiafihg facility
.that- .'• ~ •-•• • -?~ .—-,- • --
(a) Exceeds P^ the product of the
facility's replacement cost. R, and an ~-
adjusted annual asset* guideline repaji^-
"allowance, A, as reflected'by the-^y?t
following equation: P^=~R 3<~A,- Wh'ere«<
(1) The adjusted annual-asset -.->v-~ >~
guideUne-repair allowance;-A, is4he •
product of the percent of the*- i* • >»~
replacement cost Y, and the applicable "
basic annual asset guideHne repau"- • .-
allowance, B, as reflected by the
following equation: A = Y X (B -f-100);
(2) The percent Y is determined from
the following equation: Y = 1.0 — 0.575'
log X, where X is the year of
construction; and
(3) The applicable basic annual asset
guideline repair allowance, B, is selected
from-the following table consistent with
the applicable subpart:
TABLE FOR DETERMINING APPLICABLE FOR B
Subpvt ^pfiufcto to tedflly
uu : - • •••
mn
twa
mat
vnucota
tobviiMd
ncquMkm
^*
1U
. 123
7.0
4J
"Double block and bleed system" ~
means two block valves connected in
series with a bleed valve or line that can
vent the line between the two block
valves...*.'-•.•_, -: - ' • - O -
x*. .,
'"Replacement cost" means the capital
needed to purchase all the depreciable
components in« facility."- -
(Sections ill, 114. and 3O1(») of the Qean Air"
Act as amended (42 U.S.C. 7411,7414; ~
^^^:p^--v::r' -••':'*'••: I.
I 3. By adding.paragraph (c) to § 60.482-1
6 asfoDows: --r i.._». *.: *-.-.- .„
\ «0^8»* StandanteOpm-mded valves ,
or ttnee. - .".-.:.'.-• ." "
.
(c) When a double block-and-ble«d
«ystem k being-used, the bleed valve or -
line may remain open during operations .
that require venting the line between .the
block valves but shall .comply with y;.: .-
-paragraph ta)^at all other- times.. *-; -*.",.
(SectioM ill. 114. arid301(a) of the dean Air,
Act M amended (42 LLS.C741X. 7414,
- 4. By revising paragraph (d)(lj of:." -
5 60.480 as fbllowsT --. , ^_. -.'. i.
§60.48a AppOcabilttyanddeclgrwtloriof .
affected facility...."».--_ ;- -->
(d)(l) If an owner or operator applies -
for one or more of the exemptions in this
paragraph, then the owner oroperator
(Section* 111, 1M. andSQlfa) of the dean Air •."
; Act as amended (42 UAC..7411,74J4,,,.:_, ;
• • ;--•-* -».- . • .
5. By revising-paragraph -fd)
-------
Reconstruction.
• (40) ASTM D86-78. DistiUation of.
stroleum Products. IBR approved for
service is excluded from the; - O.'..^-* "^^"teequehtfy replaced components pFthe" "^-, (Sections lll.*ll4.'and 30l(a) of the Ctean Air
'requirements of { 60482-2 to § 60.482^10; - facility shall not be considered ia -~"' ~*'*-''~ -Act as amended (42JJ.&C7411.7414.
'uMt iff testified as required In J^^^ TeoifeJ]} ^ - ,r^ :r_r>-\A. -
16O488(e)C5J.> ^4fi^fe.$i§^'^^^^rftfienew components^ or. AeVfixed^^.^--/^-^-
(Sections ltx.13.4i arid 301(aj<>tm« Clea»AfrrT&P.N^wst* that would be required to- *• -" *!"**"*
. 'Act as amended £42 U.&C74li,74M*
.constructa wmparablenew. fe
"-
" a"By revising paragra
and tot BgMHquki service.
disks, ind packings, :7^-^ '
Witair.*
^costof new components'* includes, the ,,.
^. fixed capital cost of all depreciable -; j; J
^'components (except components-';
^Jjpedfied in §60.488 (a)) which are or" "
;:~wjQ be replaced pursuant la aQ -''+'.,-.
_ (2)'If a leak is detected, the valve shall continuous programs of component :\ "Ji-
be monitored monthly until a Teak is not"/ replacement which are commenced ^
detected for 2 succjMssive^nonths. .',;-." J^; within, any 2-year,period following the.. .
^,ip^:"^^vapplicability date for the appropriate
^.'^^^^'-{/Xw-J-anatftnov^ fG^n ttia> **A,T^r«H*»«WtltHr '" ••"fotfimtatftttV means that anowneroc
a continuous
" Appendix A (Araendecll ' . ' , ]-,•:
-10. By redesignating theTiefitting "5^' •
^ Apparatus" as""5.rApparanis" in' _
.^Method 18 of Appendix A as follows:
•*-'..*" * '-*''' * r - * --'*•'»"
5.1 Apparatus .- .-....• -•- • .-
* '•' * /*.*..•'*-,"
. (Sections 111,114, and 301(a) of the Clean Air
Act as amended (42 U.&C. 7411,7414,
_7601(afll .;. _ . - . -_. .f
- -11. By revising'the first equation in.
Section 6V2.1.1 in Method 18 of Appendix
- A as follows: .
v FP,T,_" -
?* 18~?
•••- (Sections. 111. 114. and 301(a) of the Clean Air
^ Act as amende^ (42 tt&C 7411.7414.
-
total number olvalvea as difficult-to-^ ^
-------
PARTaO-iAMENDEIXJ
1. The ajQthBritjr-dtation far-Part 60 -
"
" ,' Authority: 42 Ua.cf 7«1. 7vn(»T "- ; '
2: By a'ddlng a new :T5ubparl KJOCas
~ '
' Subpart KICK— Standante of Performance -
: tor Equipment Leaks of SOCTrom .Onshore
MetwaLQae Processing PJjnt> . • '..•' •
80.630
8OB31 Ttefihidon*. ~ ' .-. ; _r.j;-' ;, •
OOLflU" !3t*ndard*. " ' . ""'" r-';. ,y
" 80^33 Exception*, -. . - •-* — •> '
60^34- Alternative means of amiui«a
limitation.- ". •'. -
dO SOS
SubpvKfCKK— StMKtantesf PwtoaiMiicv
$60.630 AppflcabJOty.j
I faculty. . ,
id,deeigratlofi of
- la affected Sociihie»-iQ onvkora
natural g^T'p*y^° **'"g plj»«rf«:
- ^2} A) for>the
purpoae'of juocesa impcovemaot that is
accomjifished- without a.capitaJ
expandllure shaD not'iy itaelTbe
considered, a nmdOlcaiion under ihls
.subpart
(d) Facilities covered by.Snbpart W
or Subpart HGC.of .40 CFR Part-80 are
excluded.from . this .suapart
(e) Acompieksorjtation..dehydration
oimtaweelening anitlmdeigiound
storage lank, field gaa gatheringflystem.
or Knnefied pahiml.gaa unites, covered
.^y this 3ufapaitiifitaa-JooatBd.at.an ,
* If
:.: rtheamttiinnrtioaatediatthe plant site.
?;' tpt&oni the provisions of
_
defined:nerein.3halllhave the meaning
given ftemin the-Act^n Subpaet A ef
Pȣt 80; orin-Subpart W of Part 60; and
the ifdtowinglerms shall have the
spec3Jc awanmgs given them.
, "Alaskan North Slope^ means the
approxbnately J9.000 square-nwle area
extending from the Brooks Range -to the
ftrutlc Ocean.' - ,
eadh pump, "
pressure relief device, open-tended valve
or Bae. •whre.rompresaoc. and flange or
other untueulor^hat is in VOC.service
or in -wet gas liquids into natural
gas products.
"Onshore" .means all facilities except
those that are located in the territorial
seas or on'the outer continental shelf.
"Process unir means equipment
assembled forsthe extraction .of-natural
gas .liquids Aom field •gas. the
fracUonationtoflhe.liquids.into natural
gas;pcoducts, or .other operations
associated with .the processing of
natural gas products. A process-unit can
operate independently if supplied with
sufficient feed or jaw materials and
sufficient storage facilities for .the
products.
"Reciprocating-compressor" means a
piece of. equipment that increases the
pressure of a process gas by positive
displacement, employing linear
movement of the driveshaft;
101
-------
"In wet gas service" means that a
piece of equipment contains or contacts
the field gas before the extraction step
in the process.
§60.632 Standards.
(a) Each owner or operator subject to
the provisions of this subpart shall.
comply with the requirements of
§ 60.482-1 (a), (b), and (d) and § 60.482-2
through § 60.482-10. except as provided
in § 60.633. as soon as practicable, but
no later than 180 days after initial
startup.
(b) An owner or operator may elect to
comply with the requirements of
§ 60.483-1 and § 60.483-2.
(c) An owner or operator may apply to
the Administrator for permission to use
an alternative means of emission
limitation that achieves a reduction jn
emissions of VOC at least equivalent to ,
that achieved by the controls required in
this subpart In doing so, the owner or
operator shall comply with requirements
of S 60.634 of this subpart
(d) Each owner or operator subject to
the provisions of this subpart shall
comply with the provisions of § 60.485
• except as provided in § 60.633(f) of this
subpart
(e) Each owner or operator subject to
the provisions of this subpart shall •
comply with the provisions of 5 60.488v"
and § 60.487 except as provided in
§ 60.633, § 60.635. and § 80.636 of this
subpart • ' . -.--.-
(f) An owner of operator shall use the'
following provision instead of
§ 80.485(d)(l): Each piece of equipment
is presumed to be in VOC service or in
wet gas service unless an owner, or
operator demonstrates that the piece of
equipment is not in VOC service or in -
wet gas service. For a piece of
equipment to be considered not in VOC
service, it must be determined that the'
percent VOC content can be reasonably
expected never to exceed 10.0 percent
by weight. For a-piece of equipment to
be considered in wet gas service, it must
be determined that it contains or
contacts the field gas before the
extraction step in the process. For •
purposes of determining the percent
VOC content of the process fluid that is
contained in or contacts a piece of
equipment procedures that conform to
the methods described in ASTM 1
Methods E169, E168, or £280
(incorporated by reference as specified' '
in 5 60.17) shall be used. - : . - .
§60.633 Exceptions.
(a) Each owner or operator subject to
the provisions of this subject may
comply with the following exceptions to
the provisions of Subpart W. v
(b) (1) Each pressure relief device in
gas/vapor service may be monitored
quarterly and within 5 days after each
pressure release to detect leaks by the
methods specified in § 60.485(b) except
as provided in § 60.632(c), paragraph- -
(b)(4) of this section, and § 60.482-4(a)-
(c) of Subpart W.
(2) If an instrument reading of 10,000
ppm or greater is measured, a leak is
detected.
(3) (i) When a leak is detected, it shall
be repaired as soon as practicable, but
no later than 15 calendar days after it is
detected, except as provided in § 60.482-
9.
(ii) A first attempt at repair shall be
made no later than 5 calendar days after
*each leak is detected.
(4) (i) Any pressure relief device that
is located in a nonfractionating plant
that is monitored only by nonplapt
personnel may be monitored after a
pressure release4he next time the
monitoring personnel are on site, in^pffd
of within 5 days as specified in ..
paragraph (b)(l) of this section and
§ 8p.482-(b)(l) of Subpart W.
(ii) No pressure relief .device
described in paragraph (b){4)(i) of this .
section shall be allowed to operate for
more .than 30 days after a pressure,.
release without monitoring,';. v • "
(c) Sampling connection systems are
exempt from the .requirements-of '
§60*482-5.. :- ..;,.•-.:
•(d) Pumps in light liquid servicev.
valves in gas/vapor and light liquid
service, and pressure relief devices in
gas/vapor service that are located at a
nonlractionating plant that does not •
have the design capacity to process
283,000 standard cubic meters per day
(sand) (10 million standard cubicieet .
per day (scfd)] or more of field gas are
exempt from the routine monitoring ~ ~
requirements of § 60.482-2(a)(l), :;
§ 60.482-7(a), and § 60.833(b)(l).
(e) Pumps in light liquid service, *
valves in gas/vapor and light liquid
service, and pressure relief devices in
gas/vapor .service within a process unit.
that is located in the Alaskan North
Slope are exempt from the routine-
monitoring requirements of § 60.482- v
2(a)(l). § 80.482-7(a). and § 60.633(b)(l).
(f) Reciprocating compressors in wet
gas service are exempt from thev
compressor control requirements of -
§60.482-3. ' '..
(g) In addition to the requirements for
flares at § 60.482-10(d)(4), the following-
are allowed: . - -_•". ,•>--• /•' -•
.• (1) Steam-assisted and nonassisted
flares designed for and operated with an
exit velocity, as determined by the
methods specified in § 60.485(g)(4), .
equal to or greater than 18.3 m/sec (60
ft/sec) but less than 122m/sec (400 ft/
sec) if the net heating value of the gas
being combusted is greater than 37.3
MJ/scm (1000 Btu/scf).
(2) Steam-assisted and nonassisted
flares designed for and operated with an
exit velocity, as determined by the
methods specified in § 60.485(g)(4), less
than 122 m/sec (400 ft/sec) and less
than the velocity, vmax, as determined
by the following equation:
- (H, + -2&8)/31.7
vmax - Maximum permitted velocity, m/sec.-
ZS.S » Constant.
31.7 - Constant.
HT » The net heating value as determined in
1 80.485 (g)(3).
(h) An owner or operator may use the'
following provisions instead of
§60.485(e):
(1) Equipment is In heavy liquid .
service if the weight percent evaporated '
is 10 percent or less at 150 *C as
determined by .ASTM Method D86
(incorporated by reference as specified
in §60.17). - .. . '.•*•- " -
'. (2) Equipment is in light liquid service
if die weight percent evaporated is
greater than 10 percent at 150 *C as
determined by ASTM Method~D86
(incorporated by reference as specified
in §40.17). . -
§60534 Alternative means of •mlraton -,
Mmtts«o»,- .. _,.. .... . . , '• -
(») If, jn the Administrator's judgment
an alternative nnnnft of emission
"limitation will achieve a reduction in ...
VOC emissions at least equivalent to
the reduction in VOC emissions
achieved under any design, equipment
work practice or operational standard, ' i
: the Administrator will publish, in the
Federal Register a notice permitting the
use of that alternative meansior the
purpose
standard The notice may condition - •'
permission on requirement* related to '
.the operation and maintenance of the
alternative means.
(b) Any notice under paragraph (a) of
this section shall be published only after
^notice and an opportunity for a public
hearing.
(c) The Administrator will consider -
applications under this section from
either owners oroperators of affected
facilities, or manufacturers of control
equipment -~ - , .
(d) The Administrator will treat .
applications under this section ..' - -
; according to the' following-criteria.-' • -
except hi cases where he concludes that
other criteria are appropriate: •' '"v
(1) The applicant must collect verify
and submit test data, covering a period
of at least-12 months, necessary to
support the finding in paragraph (a) of
this section. ,
102
-------
(2) If the applicant is an owner or
. operator of an affected facility. He must'
commit in writing to operate and - , _ '
maintain the. alternative means so as to
achieve a reduction in VOC emissions at
least equivalent to the redaction, in VQC
emissions achieved uhder'the design. _ ,
equipment, ^ork practice or operational
§60.635 ReeordkMptoig rcqurefflcnts.' J
" (a) Each- owner or~bperafor subject to*^'
the provisions of this subpart shall ''_' ~
comply with the requirements of . * :
paragraphs (b) ancT(c) of- this section in*
addition to the requirements of § 60.486.
(b) The following recordkeeping ."•>.- •"'.
requirements shall apply to pressure .
relief devices subject to the • .".*,'• "
requirements of 9 60.833(b-)(l) of this ,.
subpart. ,'^.. f. .i'"-" -..-..'^^:'j>V *:-'-£
(1) VVhen each leak is. detected as
. specified ut & 60.633(b)(2). a J". ~i": -
weatherproof and readily visible V" -"•",
identification, marked with the *' . .-"
equipment identification number, shall/
be attached to-the leaking equipment. .
The identification on the pressure relief'
device maybe removed after it has been
repaired. . .•>.-".. "\:'~^r-^
(2] When each leak is detected as '_' '
specified in 5 60.633(b)(2), the following
information shall be recorded'in- a log*
and shall be kept for 2" years in a readily
accessible location: -. .'"•
(i) The .instrument and operator -
identification numbers and the
equipment identification number.. .
(u'JL The date the leak was detected .
and the dates of each attempt to repair
the leak. . - '. - . -
(iii) Repair methods applied in each
attempt to repair the leak.
- (iv) "Above 10.000 ppm" if the
maximum instrument reading measured
by the methods specified in § 60.635(a)
after each repair attempt is 10,000 ppm
jor greater/" • -'."-"-• ••-•">-f ;•-•'•-'••"
',. (v) ."Repair delayed" and the reason •
for the delay-if a leak is not repaired .
within 15 calendar days after discovery
of the leak ' --. - -^.-...' ^
(vi) The signature of the owner or ' -
. operator (or designate) whose decision
:Jtwas that repair could not be effected
•without a process shutdown. : ": •'"/;
-V (yii) The. expected date of successful'.
repair of the leaifif a-leak is not ~'i~-~ •
. repaired within 15days, ,.- ::\;.
- (viii) Dates of process unit shutdowns
that occur while the equipment is .
unrepaired. „ '. • .-. ;. £.;.,,'-"•/.-
\ (!x) The date of successful repair of -
".theleak. - .: - --•*_- ^-;_: '
(x) A list of identification numbers for
; equipment that are designated for no
- detectable emissions under the
provisions of 9 60.482-4(a)C The T~ 'f >
designation^ equipment subject to the
" provisions of 9 60.482-4(aj"3hallbe~ :^- ^ _
; signed by the owner .or operator.' '"'~,
(c) AD owner or operator shall comply ^
with the following requirement in „.. *
addition-to the requirement of ; o
9 60.4860): Information and data used to '
..demonstrate that a reciprocating '
.compressor is in wet gas service to
apply for the exemption in 9 60.633(f)
shall be recorded in a log that is kept in
a readily accessible location. '.
. (Approved by the Office of Management and
Budgetunder control nvunber 2060-0120} —
9.60.830 Reporting requirements.'
(a) Each owner or operator subject to ~
the provisions of this subpart shall
comply with the requirements of
paragraphs (b) and (c) of this section in
addition to the requirements of 9 60.487.
(b) An owner or operator shall include
the following information in the initial
semiannual report in addition to the
information required in 9 60.487(b)(l)-
- (4): number of pressure relief devices
subject to the requirements of
9 60.633(b) except for those pressure
relief devices designated for no
'-detectable emissions under the
provisions of j_60.482-4(a) and those
. pressure relief devices complying with
(c) An owner or operator shall include
die' following information in all
semiannual reports in addition to the ~
- information required in § 60.487(c)(2)(i>-
•
(1) Number of pressure relief devices
"-•:. for which leaks were detected as
required in 160.833(b)(2) and :
•«^. (2) Number of pressure relief devices
for which leaks were not repaired as
' required in 9 60.633(b)(3).
• {Approved by the Office of Management and
Budget under control number 2060-0120)
.. 3. By revising paragraphs (a) (34), (35),
~ (36), and (40) of 9 60.17 of Subpart A—
",General Provisions to read as follows: .
•j 60.17 Incorporation by reference;
(a) ' ' *
,-- (34) ASTM E169-63 (Reapproved
.'-1977], General Techniques of Ultraviolet
Quantitative Analysis. IBR approved for
! 60.48$(d), S 60.593(b), and 5 60.632(f).
(35) ASTM E168-87 (Reapproved
1877), General Techniques of Infrared-
Quantitative Analysis. IBR approved for
S 60.485(d), § 60.593(b), and 9 60.632(f).
-(36) ASTM E280-73. General Gas
Chromatography Procedures, EBR
approved for § 60.485(d), § 60.593(b).
and § 6O.832(f).
(40) ASTM D86-78, Distillation of
Petroleum Products. IBR approved for
9 60.593(d) and 9 60.633(h).
. [FR Doc. 85-15099 Filed 8-21-85: 8:45 am)
•UNO COM iseo 10 M
103
-------
NESHAPS REGULATIONS
104
-------
Subpart F—National Emiuion Standard
tar Vinyl CntorfctoU
161.60 Applicability.
(a) This subpart applies to plants
which produce:
(1) Ethylene dichloride by reaction of
oxygen and hydrogen chloride with
ethylene.
(2) Vinyl chloride by any proceas,
and/or
(3) One or more polymers containing
aay fraction of polymerized vinyl chlo-
ride.
(b). This subpart does not apply to
equipment used in research and develop-
ment if the reactor used to polymerize
the vinyl chloride processed in the equip-
ment has a capacity of no more than
0.19 m* (50 gal).
(c) Sections of this subpart other than
H 61.61; 61.64 (a), (b), (c).and (d);
•1.67; 61.68; 61.69: 61.70; and 61.71 do
not apply to equipment used in research
and development if the reactor used to
polymerize the vinyl chloride processed
in the equipment has a capacity of
greater than 0.19 m3 (50 gal) and no
i than 4.07 m' (1100 gal) .»
f 61.61 Definition*.
Terms used in this subpart are denned
in the Act, in Subpart A of this part, or
In this section as follows:
(a) "Ethylene dichloride plant" in-
cludes any plant which produces ethyl-
ene dichloride by reaction of oxygen and
hydrogen chloride with ethylene.
(b) "Vinyl chloride plant" includes
any plant which produces vinyl chloride
by any process.
(c) "Polyvinyl chloride plant" includes
any plant where vinyl chloride alone or
m combination with other materials la
polymerized.
(d) "Slip gauge" means a gauge which
has a probe that moves through the gas/
liquid interface in a storage or transfer
vessel and indicates the level of vinyl
chloride in the vessel by the physical
state of the material the gauge dis-
charges.
(e) "Type of resin" means the broad
classification of resin referring to the
basic manufacturing process for produc-
ing that resin, including, but not limited
to, the suspension, dispersion, latex, bulk,
and solution processes.
(f) "Grade of resin" means the sub-
division of resin classification which de-
scribes it as a unique resin, i.e., tbe moat
exact description of a resin with no fur-
ther subdivision.
(g) "Dispersion resin" means a. resin
manufactured in such away as to form
fluid dispersions when dispersed in a
plasticizer or plasticizer/diluent mix*
tures.
(h) "Latex resin" means a resin which
is produced by a polymerization process
which initiates from free radical catalyst
sites and is sold undrled.
(1) "Bulk resin' •means a resin which
is produced by a polymerization process
in which no water is used.
(j) "Inprocess wastewater" means any
water which, during manufacturing or
processing, comes Into direct contact
with vinyl chloride or polyvinyl chloride
or results from the production or use of
any raw material, intermediate product.
finished product, by-product, or waste
product containing vinyl chloride or
polyvinyl chloride but which has not
been discharged to a wastewater treat-
ment process or discharged untreated M
wastewater.
(k) "Wastewater treatment process"
includes any process which modifies
characteristics such as BOD. COD. TBS,
and pH, usually for the purpose of meet-
ing effluent guidelines and standards; It
does not include any process the purpose
of which is to remove vinyl chloride from
water to meet requirements of this
subpart.
(1) "In vinyl chloride service" means
that a piece of equipment contains or
contacts either a liquid that is at least
10 percent by weight vinyl chloride or a
gas that Is at least 10 percent by volume
vinyl chloride.
(m) "Standard operating procedure"
means a formal written procedure offi-
cially adopted by the plant owner or
operator and available on a routine baals
to those persons responsible for carrying
out the procedure.
(n) "Run" means the net period of
time during which an emission sample is
collected.
(o) "Ethylene dichloride purification"
includes any part of the process of ethyl-
ene dichloride production which follows
ethylene dichloride formation and In
which finished ethylene dichloride la
produced.
(p) "Vinyl chloride purification" In-
cludes any part of the process of vinyl
chloride production which follows vinyl
chloride formation and in which finished
vinyl chloride is produced.
(q) "Reactor" includes any vessel in
which vinyl chloride is partially or totally
polymerized into polyvinyl chloride.
(r) "Reactor opening loss" means the
emissions of vinyl chloride occurring
when a reactor is vented to the atmos-
phere for any purpose other than an
emergency relief discharge av .
(s) "Stripper" inehtdes aar mawl in
which residual vinyl chloride ta removed
from polyvinyl chloride resin, except
bulk resin, in the slurry form by the we
of heat and/or vacuum. In the case of
bulk resin, stripper includes any vessel
which is used to remove residual vinyl
chloride from polyvinyl chloride resin
immediately following the polymeriza-
tion step in the plant process flow.
(t) "Standard temperature" means a
temperature of 20* C (69' P).M
(u) "Standard pressure" means a
pressure of 760 nun of Rg (29.92 in. of
105
§ 61.62 Emiuion standard for ethylene
dichloride plant*. 3*
(a) Ethylene dichloride purification:
The concentration of vinyl chloride in
*M exhaust gases discharged to the at-
mosphere from any equipment used in
•ttrylene dichloride purification is not
to exceed 10 ppm, except as provided in
I «1.65(a). This requirement does not
apply to equipment that has been opened.
is out of operation, and met the require-
ment in 161.85(b) <6) (i) before being
•pened.
Oxyehlorination reactor: Except
M provided in 561.65 Vinyl chloride formation and puri-
fication: The concentration of vinyl
ahJortde in all exhaust gases discharged
to the atmosphere from any equipment
used in vinyl chloride formation and/or
purification is not to exceed 10 ppm. ex-
cept as provided in i 61.65(a). This re-
quirement does not apply to equipment
that has been opened, is out of operation.
and met the requirement in 9 61.65(b>
(6) (l) before being opened.
§ 61.64 EmiMHHi •taarfarcl for polyvinyl
chloride plant*.
An owner or operator of a polyvinyl
chloride plant shall comply with the re-
wirementa of this section and f 61.65.
(a) Xemctor. The following require-
onta apply to reactors:
(1) The concentration of vinyl chlo-
itte in all exhaust gases discharged to
to* atmosphere from each reactor is not
to exceed 10 ppm. except as provided in
paragraph (2> of this section and
161.65 (a).
(2) The reactor opening loss from each
reactor is not to exceed 0.02 g vinyl
cbJonde/kg (0.00002 Ib vinyl chloride/
lb> of polyvinyl chloride product, with
the product determined on a dry solids
basis. This requirement applies to any
vessel which is used as a reactor or as
both a reactor and a stripper. In the
bulk process, the product means the
gross product of prepolymerization and
postpolymerization.
(3) Manual vent valve discharge: Ex-
cept for an emergency manual vent valve
discharge, there is to be no discharge to
tbe atmosphere from any normal vent
valve on a polyvinyl chloride reactor in
•vtayl chloride service. An emergency
manual vent valve discharge means a
barge *» the ataaoaphere which could
have been avoided by taking meas-
i to prevent the discharge. Within 10
-------
i of «ay discharge to the atmosphere
from any manual vent valve, the owner
or operator of the source from which the
discharge occurs shall submit to the Ad-
ministrator a report in writing contain-
ing information on the source, nature
and cause of the discharge, the date and
Ifcne of the discharge, the approximate
total vinyl chloride loss during the dis-
charge. the method used for determining
the vinyl chloride loss, the action that
was taken to prevent the discharge, and
measures adopted to prevent future dis-
charges.
Stripper. The concentration of
vinyl chloride in all exhaust gases dis-
charged to the atmosphere from each
stripper is not to exceed 10 ppm, except
M provided in |01.65 (a). This require-
ment does not apply to equipment that
has been opened, is out of operation, and
•et the requirement in i 61.65(b) (6) (1)
before being opened.
(c) Mixing, weighing, and holding
containers. The concentration of vinyl
chloride in all exhaust gases discharged
to the atmosphere from each mixing.
weighing, or holding container in vinyl
enloride service which precedes the
stripper (or the reactor if the plant has
s» stripper) in the plant process flow is
ae« to exceed 10 ppm. except as provided
in } 61.65^phffrf . the
technology other than stripping or in
quantity of vinyl chloride in all parts of
each loading or unloading line that are
to be opened to the atmosphere is to be
reduced so that the parts combined con-
tain no greater than 0.0038 m' (0.13 ff)
of vinyl chloride, at standard tempera-
ture and pressure; and
(11) Any vinyl chloride removed from
a loading or unlns fling line in accord-
ance with paragraph (b)(l)(i) of this
section is to be ducted through a control
system from which the concentration of
vinyl chloride in the exhaust gases does
not exceed 10 ppm. or equivalent as pro-
vided in 5 61.66.
( 2 > Slip gauges . During loading or on-
loading operations, the vinyl chloride
emissions from each slip gauge in vinyl
chloride service are to be minimised by
ducting any vinyl chloride discharged
from toe sHp gauge through a control
system from which the eeaoentratkm of
vinyl chloride in the exhaust gases does
not exceed 10 ppm, or equivalent as pro-
vided in i 61.66.
(3) Leakage from pump, compressor,
and agitator seals:
(1) Rotating pumps. Vinyl chloride
emissions from seals on all rotating
pumps in vinyl chloride service are to be
minimized by installing sealless pumps.
pumps with double mechanical seals, or
equivalent as provided in § 61.66. If
double mechanical seals are used, vinyl
tntorlde emissions from the seals are to
be minimized by maintaining the pres-
sure between the two seals so that any
•leak that occurs is into the pump; by
ducting any vinyl chloride between the
two seals through a control system from
which the concentration of vinyl chlo-
ride in the exhaust gases does not ex-
ceed 10 ppm; or equivalent as provided
te | 61.66.
(11) Reciprocating -pumps. Vinyl chlo-
ride emissions from seals on all recipro-
cating pumps in vinyl chloride service
ere to be minimized by installing double
outboard seals, or equivalent as provided
in { 61.66. If double outboard seals are
used, vinyl chloride emissions from the
seals are to be minimized by maintaining
the pressure between the two seals so
that any leak that occurs is into the
pump; by ducting any vinyl chloride be-
tween the two seals through a control
system from which the concentration of
Ttayl chloride In the exhaust gases does
not exceed 10 ppm: or equivalent as
provided in {61.66.
(ill) Rotating compressor. Vinyl
chloride emissions from seals on all ro-
tating compressors in vinyl chloride
service are to be minimized by installing
compressors with double mechanical
iseli. or equivalent as provided in § 61.66.
tt double mechanical seals are used, vinyl
emlortde emissions from the seals are to
be minimized by maintaining the pres-
ses between the two seals so that any
leak that occurs is into the compressor;
by ducting any vinyl chloride between
the two seals through a control system
from which the concentration of vinyl
chloride in the exhaust gases does not
exceed 10 ppm; or equivalent as provided
in I 61.66.
(iv) Reciprocating compressors. Vinyl
chloride emissions from seals on all re-
ciprocating compressors in vinyl chloride
service are to he snsnisaiBsd by tosfealUn?
double outboard seals, or equivalent as
pcwtted in I 61.6C. If double outboard
seals are used, vinyl chloride emissions
from the seals are to be minimized by
maintaining the pressure between the
two seals so that any leak that occurs is
into the compressor; by ducting any
vinyl chloride between the two seals
through a control system from which the
concentration of vinyl chloride in the
exhaust gases does not exceed 10 ppm;
or. equivalent as provided in 5 61.66.
(v) Agitator. Vinyl chloride emissions
from leelt on all agitators in vinyl chlo-
ride service are to be minimized by in-
106
-------
stalling agitators with double mechani-
cal seals, or equivalent as provided in
I 61.66. It double mechanical seals are
need, vinyl chloride emissions from the
seals are to be minimized by maintaining
the pressure between the two seals so
that any leak that occurs is into the agi-
tated vessel; by ducting any vinyl chlo-
ride between the two seals through a
control system from which the concen-
tration of vinyl chloride in the exhaust
gases does not exceed 10 ppm; or equiva-
lent as provided in } 61.86.
(4) Leakage from relief valves. Vinyl
chloride emissions due to leakage from
each relief valve on equipment in vinyl
chloride service are to be minimized by
Installing a rupture disk between the
equipment and the relief valve, by con-
necting the relief valve discharge to a
process line or recovery system, or equiv-
alent as provided in ! 61.66.
(5) Manual venting of gases. Except
as provided in 5 61.64(a) (3), all gases
which are manually vented from equip-
ment in vinyl chloride service are to be
ducted through a control system from
which the concentration of vinyl chloride
in the exhaust gases does not exceed 10
ppm; or equivalent as provided in $ 81.66.
(6) Opening of equipment. Vinyl
chloride emissions from opening of
equipment (including loading or unload-
ing lines that are not opened to the at-
mosphere after each loading or unload-
ing operation) are to be minimized as
follows:
(i) Before opening any equipment for
any reason, the quantity of vinyl chlo-
ride is to be reduced so that the equip-
ment contains no more than 2.0 percent
by volume vinyl chloride or 0.0950 m* (25
gal) of vinyl chloride, whichever is
larger, at standard temperature and
pressure; and
(ii) Any vinyl chloride removed from
the equipment in accordance with pen-
graph (b) (6) (i) of this section is to be
ducted through a control system from
which the concentration of vinyl chlo-
ride in the exhaust gases does not exceed
10 ppm, or equivalent as provided in
J 61.66.
(7) Samples. Unused portions of sam-
ples containing at least 10 percent by
weight vinyl chloride are to be returned
to the process, and sampling techniques
are to be such that sample containers in
vinyl chloride service are purged into a
closed process system.
(8) Leak detection and elimination.
Vinyl chloride emissions due to leaks
from equipment in vinyl chloride service
are to be minimized by instituting and
implementing a formal leak detection
and elimination program. The owner or
operator shall submit a description of
the program to the Administrator for
approval. The program is to be sub-
mitted within 45 days of the effective
date of these regulations, unless a waiver
of compliance is granted under 8 61.11.
If a waiver of compliance is granted, the
program is to be submitted on a date
scheduled by the Administrator. Ap-
proval of a program will be granted by
the Administrator provided he finds:
(i) It includes a reliable end accurate
vinyl chloride monitoring system for de-
tection of major leaks and identification
of the general area of the plant where a
leak is located. A vinyl chloride monitor-
tag system means a device which obtains
air samples from one or more points on
a continuous sequential basis and ana-
lyzes the samples with gas chromatog-
raphy or. If the owner or operator as-
sumes that all hydrocarbons measured
are vinyl chloride, with infrared spectro-
photometry, flame ion detection, or an
equivalent or alternative method.
(ii) It Includes a reliable and accurate
portable hydrocarbon detector to be used
routinely to find small leaks and to pin-
point the major leaks indicated by the
vinyl chloride monitoring system. A
portable hydrocarbon detector means a
device which measures hydrocarbons
with a sensitivity of at least 10 ppm
and is of such design and size that it can
be used to measure emissions from local-
ised points.
(ill) It provides for an acceptable cali-
bration and maintenance schedule for
the vinyl chloride monitoring system and
portable hydrocarbon detector. Tor the
vinyl chloride monitoring system, a dally
span check is to be conducted with a
concentration of vinyl chloride equal to
the concentration defined as a leak ac-
cording to paragraph (b) (8) (vl) of this
section. The calibration is to be done
with either:
(A) A calibration gas mixture pre-
pared from the gases specified in sections
5.2.1 and 5.2.2 of Test Method 106 and
in accordance with section 7.1 of Test
Method 106, or '•
(B) A calibration gas cylinder stand-
ard containing the appropriate concen-
tration of vinyl chloride. The gas com-
position of the calibration gas cylinder
standard is to have been certified by the
manufacturer. The manufacturer must
have recommended a maximum shelf life
for each cylinder so that the concentra-
tion does not change greater than ±5
percent from the certified value. The date
of gas cylinder preparation, certified
vinyl chloride concentration and recom-
mended maximum shelf life must have
been affixed to the cylinder before ship-
ment from the manufacturer to Ifce
buyer. If a gas chromatograph is used as
the vinyl chloride monitoring system,
these gas mixtures may be directly used
to prepare a chromatograph callbratfan
curve as described in section 7.3 of Test
Method 106. The requirements in sec-
tion 5.2.3.1 and 5.2.3.2 of Test Method
104 for certification of cylinder stand-
ards and for establishment and verifica-
tion of calibration standards are to be
foDowed.3*
(iv) The location and number of points
to be monitored and the frequency of
monitoring orovided for in the program
are acceotable when they are compared
with the number of pieces of equipment
in vinyl chloride service and the size and
physical layout of the plant.
(v) It contains an acceptable plan of
action to be taken when a leak is de-
tected.
(vl) It contains a definition of leak
which is acceptable when compared with
the background concentrations of vinyl
chloride in the areas of the plant to be
monitored by the vinyl chloride monitor-
ing system. Measurements of background
concentrations of vinyl chloride in the
areas of the plant to be monitored by the
vinyl chloride monitoring system are to
be included with the description of the
program. The definition of leak for a
given plant may vary among the differ-
ent areas within the plant and is also to
change over time as background con-
centrations in the plant are reduced.
(9) Inprocess wastewater. Vinyl chlo-
ride emissions to the atmosphere from
Inprocess wastewater are to be reduced
a* follows:
(i) The concentration of vinyl chlo*
fide in each Inprocess wastewater stream
containing greater than 10 ppm vinyl
chloride measured immediately as it
leaves a piece of equipment and before
being mixed with any other inprocess
wastewater stream is to be reduced to no
more than 10 ppm by weight before being
mixed with any other inprocess wastewa-
ter stream which contains less than 10
ppm vinyl chloride; before being exposed
to the atmoshere; before being dis-
charged to a wastewater treatment proc-
CM; or before being discharged untreated
as a wastewater. This paragraph does
apply to water which is used to displace
vinyl chloride from equipment before it
is opened to the atmosphere in accord-
ance with J81.64(a)(2> or paragraph
(b) <6> of this section, but does not apply
to water which is used to wash out equip-
ment after the equipment has already
been opened to the atmosphere in ac-
cordance with J61.64(a)(2) or para-
graph (b) (6) of this section.30
(ii) Any vinyl chloride removed from
the inprocess wastewater in accordance
with paragraph (b) (9) (1) of this section
is to be ducted through a control system
from which the concentration of vinyl
chloride in the exhaust gases does not
exceed 10 ppm, or equivalent as provided
m i 61.66.
(c) The requirements in paragraphs
and (b) (8) of this section are to be In-
corporated into a standard operating
procedure, and made available upon re-
quest for inspection by the Administra-
tor. The standard operating procedure is
to Include provisions for measuring the
vinyl chloride in equipment 3:4.75 m1
(1.250 gal) in volume for which an emis-
sion limit is prescribed in 5 61.65(b) (6)
(i) prior to opening the equipment and
using Test Method 106, a portable hydro-
carbon detector, or an equivalent or al-
ternative method. The method of meas-
urement is to meet the requirements in
I 81.67(g) (5) (i) (A) or (g) ((5) (i) (B).
114 of UM
Air Act ••
107
-------
I 61.66 Equivalent equipment ami pro-
cedure*.
Upon written application from an own-
er or operator, the Administrator may
approve use of equipment or procedures
which have been demonstrated to his
satisfaction to be equivalent in terms of
reducing vinyl chloride emissions to the
atmosphere to those prescribed for com-
pliance with a specific paragraph of this
•ubpart. For an- existing source, any re-
quest for using an equivalent method as
the initial measure of control is to be
submitted to the Administrator within
M days of the effective date. For a new
aource, any request for using an equiva-
lent method is to be submitted to the
Administrator with the application for
approval of construction or modification
required by I 61.07.
f 61.67 EmiMioa test*.
(a) Unless a waiver of emission testing
is obtained under i 61.13, the owner or
operator of a source to which this sub-
part applies shall test emissions from
the source,
(1) Within 90 days of the effective date
in the case of an existing source or a
new source which has an initial startup
date preceding the effective date, or
(2) Within 90 days of startup in the
case of a new source, initial startup of
which occurs after the effective date.
(b) The owner or operator shall pro-
vide the Administrator at least 30 days
prior notice of an emission test to afford
the Administrator the opportunity to
have an observer present during the test.
(c) Any emission test is to be con-
ducted while the equipment being tested
!• operating at the maximum production
rate at which the equipment will be op-
erated and under other relevant condi-
tions as may be specified by the Adminis-
trator based on representative perform-
ance of the source.
(d) [Reserved]31
When at all possible, each sample
is to be analyzed within 24 hours, but in
no case in excess of 72 hours of sample
collection. Vinyl chloride emissions are
to be determined within 30 days after the
emission test. The owner or operator
•hall report the determinations to the
Administrator by a registered letter dis-
patched before the close of the next busi-
ness day following the determination.3*
(f) The owner or operator shall retain
at the plant and make available, upon
request, for inspection by the Adminis-
trator, for a minimum of 2 years records
of emission test results and other data
needed to determine emissions.
(f) Unless otherwise specified, the
owner or operator shall use test Test
Methods in Appendix B to this part for
each test as required by paragraphs
(«>(!),
-------
is to be made is to be specified by the
Administrator for each individual plant
at the time of the determination baaed
on the plant's operation. For a reactor
that is also used as a stripper, the deter-
mination may be made immediately fol-
lowing the stripping operation.
(1) Bxcept as provided m paragraph
(g)(5)(il) of this section, the reactor
opening loss is to be determined using
the following equation:
W (2.60) (10-*) (Cb)
C — V9
when:
C- kg vinyl chloride emissions/kg product.
W- Capacity of the reactor In m'.
2.90—Density of vinyl chloride at one atmosphere and
20*Cinkg/m>.
Vf*" Conversion (actor (or ppm.
Cb-ppm by volume vinyl chloride as determined by
Test Method 108 or a portable hydrocarbon
detector which measures hydrocarbons
with a sensitivity of at least 10 ppm.
K- Number of batches since the reactor was last
opened to the atmosphere.
Z-Avertfe kf of polyvinyl chloride produced par
batch in the number of batches since the reactor
was last opened to the atmosphere.
(A) If Method 106 is used to deter-
mine the concentration of vinyl chloride
(Cb), the sample is to be withdrawn at
a constant rate with a probe of sufficient
length to reach the vessel bottom from
the manhole. Samples are to be taken
for 5 minutes within 6 inches of the ves-
sel bottom, 5 minutes near the vessel
center, and 5 minutes near the vessel top.
(B) If a portable hydrocarbon detec-
tor is used to determine the concentra-
tion of vinyl chloride (Cb), a probe of
sufficient length to reach the vessel bot-
tom from the manhole is to be used to
make the measurements. One measure-
ment wul be made within 6 inches of the
vessel bottom, one near the vessel center
and one near the vessel top. Measure-
ments are to be made at each location
until the reading is stabilized. All hydro-
carbons measured are to be assumed to
be vinyl chloride.
(C) The production rate of polyvinyl
chloride (Z) is to be determined by a
method submitted to and approved by the
Administrator.
(11) A calculation based on the number
of evacuations, the vacuum involved, and
Use volume of gas in the reactor is hereby
approved by the Administrator as an al-
ternative method for determining reac-
tor opening loss for postpolymerization
reactors in the manufacture of bulk
reams.
(•toe. 114 of tbo Cbta Air Aet M imencliii
(42 UA.C. T414». *MT
nitoring.
f 61.68 Emiaaion
(a) A vinyl chloride monitoring sys-
tem is to be used to monitor on a con-
tinuous basis the emissions from the
sources for which emission limits are pre-
scribed in i 61.62(5>. (b)<«)
(U),and(b)(9)(ii).30
(b) The vinyl chloride monitoring sys-
tem (s) used to meet the requirement in
paragraph (a) of this section is to be a
device which obtains air sampels from
one or more points on a continuous
sequential basis and analyzes the samples
with gas chromotography or, if the owner
or operator assumes that all hydrocar-
bons measured are vinyl chloride, with
infrared spectrophotometry, flame ion
detection, or an equivalent or alterna-
tive method. The vinyl chloride monitor-
ing system used to meet the requirement*
in 5 61.8S(b) (8) (1) may be used to meet
the requirements of this section.
(c) A daily span check is to be con-
ducted for each vinyl chloride monitor-
ing system used. For all of the emission
sources listed in paragraph (a) of this
section, except the one for which an emis-
sion limit is prescribed in f 81.62(b>, toe
daily span check is to be concducted with
a concentration of vinyl chloride equal
to 10 ppm. For the emission source for
which an emission limit is prescribed in
I 61.62(b), the daily span check is to be
conducted with a concentration of vinyl
chloride which is determined to be
equivalent to the emission limit for that
source based on the emission test re-
quired by } 61.67. The calibration is to
be done with either:
(1) A calibration gas mixture pre-
pared from the gases specified in sections
5.2.1 and 5.2.2 of Test Method 106 and
in accordance with section 7.1 of Test
Method 106. or31
(2) A calibration gas cylinder stand-
ard containing the appropriate concen-
tration of vinyl chloride. The gas com-
position of the calibration gas cylinder
standard is to have been certified by the
manufacturer. The manufacturer most
have recommended a maximum shelf
life for each cylinder so that the concen-
tration does not change greater than
±5 percent from the certified value. The
date of gas cylinder preparation, certified
vinyl chloride concentration and recom-
mended maximum shelf life must have
been affixed to the cylinder before ship-
ment from the manufacturer to the
buyer. If a gas chromatograph is used as
the vinyl chloride monitoring system,
these gas mixtures may be directly used
to prepare a ^hTrTntfttm*^ i*^'<*rJa^rTi
curve as described in section 7.3 of Te*t
Method 1M. The requirements in sec-
tions 5.2.3.1 and 5.2.3.2 of Test Method
106 for certification of cylinder stand-
ards and for establishment and verifica-
tion of calibration standards are to be
followed.3*
(•tee. 114 ef Use Cfeaa Air Aet M SB»*BSM
(4* UAC. 1414». d)(i) and <2) and (c) (3) of this
section, unless an equivalent or an alter-
native method has been approved by the
Administrator. If the Administrator
finds reasonable grounds to dispute the
results obtained by an equivalent or al-
ternative method, he may require the use
109
-------
of a reference method. If the results of
the reference and equivalent or alterna-
tive methods do not agree, the results
obtained by the reference method pre-
vail, and the Administrator may notify
the owner or operator that approval of
the method previously considered to be
equivalent or alternative is withdrawn.
(1) The owner or operator shall in-
clude in the report a record of any emis-
sions which averaged over any hour
period (commencing on the hour) are
In excess of the emission limits pre-
scribed in §§ 61.62(a) or (b), { 61.63(a),
or §61.64(a)(l), (b), (c), or (d), or for
any control system to which reactor
emissions are required to be ducted in
I «1.64(a) (2) or to which fugitive emis-
sions are required to be ducted In § 61.65
(b) (1) (11), (b) (2), (b) (5), (b) (6) (11). or
(b) (9) (11). The emissions are to be meas-
ured in accordance with 5 61.68.
(2) In polyvinyl chloride plants for
which a stripping operation is used to
attain the emission level prescribed in
f ll.64(e), the owner or operator shall
include in the report a record of the
vinyl chloride content in the polyvinyl
chloride resin. Test Method 107 is to be
used to determine vinyl chloride content
as follows:
(1) If batch stripping is used, one rep-
resentative sample of polyvinyl chloride
mm to to be taken frem each ketch of
•eh grade of ream immediately follow-
ing the completion of the stripping op-
eration, and identified by resin type and
grade and the date and time the batch
Is completed. The corresponding quan-
tity of material processed in each strip-
per batch is to be recorded and identi-
fied by resin type and grade and the
date and time the batch is completed?"
(11) If continuous stripping is used.
one representative sample of polyvinyl
chloride resin is to be taken for each
grade of resin processed or at intervals
of 8 hours for each grade of resin which
is being processed, whichever is more fre-
quent. The sample is to be taken as the
resin flows out of the stripper and iden-
tified by resin type and grade and the
date and time the sample was taken.
The corresponding quantity of material
processed by each stripper over the time
period represented by the sample during
tbe.eifht hour period, is to be recorded
and identified by resin type and grade
and the date and time it represents.
(ill) The quantity of material proc-
essed by the stripper is to be determined
on a dry solids basis and by a method
submitted to and approved by the Ad-
ministrator.
(iv) At the prior request of the Ad-
ministrator, the owner or operator shall
provide duplicates of the samples re-
quired in paragraphs (c) (2) and (c)
(2) (ii) of this section.
(v) The report to the Administrator
by the owner or operator is to include
the vinyl chloride content found in each
sample required by paragraphs (c)(2)
(1) and (c) <2> (ii) of this section, aver-
aged separately for each type of resin,
over each calendar day and weighted
according to the quantity of each grade
of resin processed by the stripper4-bour average, concentration of type.
T < resin in ppm (dry weight baals).
9=Total production of type T i resin over
the 34-hour period, in leg.
T i=Type of resin; 1=1,3 . . . m where m
la total number of resin types produced
during the 24-hour period.
(vi) The owner or operator shall re-
tain at the source and make available
for inspection by the Administrator lor
a minimum of 2 yean records of all data
needed to furnish the information re-
quired by paragraph (c)(2)(v) of this
section: The records are to contain the
following information:
(A) The vinyl chloride content found
hi all the samples required in paragraphs
(c) (2) (i) and (c) (2) (ii) of this section.
Identified by the resin type and grade
and the time and date of the sample, and
(B) The corresponding quantity of.
polyvinyl chloride resin processed by the
stripper(s). identified by the resin type
and grade and the time and date it
represents.
(3) The owner or operator shall In-
clude in the report a record of the emis-
sions from each reactor opening for
which an emission limit is prescribed In
I 61.64(a) (2). Emissions are to be deter-
mined in accordance with § 61.67(g) (5).
except that emission; for each reactor
are to be determined. For a reactor that is
also used as a stripper, the determination
may be made immediately following the
stripping operation.
(Set 114 of tbs OMB Air Act ss
(44 UJB.C T414)). 4MT
A reoord of the leaks detected dur-
ing.roatlQ«,monitoring with the portable
hydrocarbon detector and the action
taken to repair the leaks, as required
by | 61.«S(b) (8), including a brief state-
ment explaining the location and cause
of each leak detected with the portable
hydrocarbon detector, the date and time
of the teak, and any action taken to
eliminate that leakl"
(3) A record of emissions measured
to • renrrisin.il with i 61.68.3*
(4) A daily operating record for each
polyvinyl chloride reactor, including
areesuiu and temperatures.3*
OK. 114 ef tbe CUan Air Act i
<4S OMLC 74141).
-------
Subpart J—National EmiMion
Standard for Equipment Leaka
(Fugitive Emisaion Sources) of
Benzene97
{•1.110 Af*>«caMttyand0tti«n«
lot
(a) The provisions of this subpart
apply to each of the following sources
that are intended to operate in benzene
service- pumps, compressors, pressure
relief devices, sampling connections.
systems, open-ended valves or lines,
valves, flanges and other connectors.
product accumulator vessels, and
control devices or systems required by
this subpart.
(b) The provisions of this subpart do
not apply to sources located in coke by-
product plants.
(c)(l) If an owner or operator applies
for one of the exemptions in this
paragraph, then the owner or operator
shall maintain records as required in
f 61.246(0.
(2) Any equipment in benzene service
that is located at a plant site designed to
produce or use less than 1.000
megagrams of benzene per year is
exempt from the requirements of
i 61.112.
(3) Any process unit (defined in
§ 61.241) that has no equipment in
benzene service is exempt from the
requirements of | 81.112.
(d) While the provisions of this
subpart are effective, a source to which
this subpart applies that is also subject
to the provisions of 40 CFR Part 60 onlv
will be required to comply with the
provisions of this subpart.
M1.111
As used in this subpart. all terms not
defined herein shall have the meaning
given them in the Act in Subpart A of
Part 61. or in Subpart V of Part 61. and
the following terms shall have the
specific meanings given them:
"In benzene service" means that a
piece of equipment either contains or
contacts a fluid (Liquid or gas) that is at
least 10 percent benzene by weight as
determined according to the provisions
of 161.245(d). The provisions of
i 61.245(d) also specify how to
determine that a piece of equipment is
not in benzene service.
"Semiannual" means a 6-month
period: the first semiannual period
concludes on the last day of the last
month during the 180 days following
initial startup for new sources; and the
first semiannual period concludes on the
last day of the last full month during the
180 days after June 8,1984 for existing
sources.
M1.112
(a) Each owner or operator subject to
the provisions of this subpart shall
comply with the requirements of
Subpart V of this part
. (b) An owner or operator may elect to
comply with the requirements of
i 61.243-1 and i 61.243-2.
(c) An owner or operator may apply to
the Administrator for a determination of
an alternative means of emission
limitation that achieves a reduction in
emissions of benzene at least equivalent
to the reduction in emissions of benzene
achieved by the controls required in this
subpart In doing so, the owner or
operator shall comply with requirements
of i 61.244.
101.119-41.11*
38 FR 8826, 4/6/73 (1)
•s Mended
49 FR 23498, 6/6/84 (97)
111
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Subpart V—National Emission
Standard for Equipment Leaks
(Fugitive Emission Sources)"
MU40 AppHcaMHty and designation of
(a) The provisions of this subpart
•pply to each of the following sources
that ere intended to operate in volatile
hazardous air pollutant (VHAP) sen-ice:
pumps, compressors, pressure relief
devices, sampling connection systems,
open-ended valves or lines, valves.
flanges and other connectors, product
accumulator vessels, and control
devices or systems required by this
subpart.
(b) The provisions of this subpart
apply to the sources listed in paragraph
(a) after the date of promulgation of a
specific subpart in Part 81.
(c) While the provisions of this
subpart are effective, a source to which
this subpart applies that is also subject
to the provisions of 40 CFR Part 60 onh
will be required to comply with the
provisions of this subpart.
fat.141 OeflnWona.
As used in this subpart all terms not
defined herein shall have the meaning
given them in the Act in Subpart A of
Part 81. or in specific subparts of Pan 61;
and the following terms shall have
specific meaning given them:
"Closed-vent system" means a system
that is not open to atmosphere and that
is composed of piping, connections, and.
if necessary, flow-inducing devices that
transport gas or vapor from a piece or
pieces of equipment to a control device
"Connector" means, flanged, screwed.
welded, or other joined fittings used to
connect two pipe lines or a pipe line and
a piece of equipment.
"Control device" means an enclosed
combustion device, vapor recovery
system, or flare.
"Double block and bleed system"
means two block valves connected in
series with a bleed valve or line that can
vent the line between the two block
valves.
"Equipment" means each pump.
compressor, pressure relief device.
sampling connection system, open-
ended valve or line, valve, flange or
other connector, product accumulator
vessel in VHAP service, and any com™)
devices or systems required by this
subpart.
"First attempt at repair" means to
take rapid action for the purpose of
stopping or reducing leakage of orgdnit
material to atmosphere using best
practices.
"In gas/vapor service" means that a
piece of equipment contains process
fluid that is in the gaseous state at
operating conditions.
"In liquid service" means that a piei.e
of equipment is not in gas/vapor sen-ire
"In-situ sampling systems" means
nonextractivp samplers or in-line
samplers.
"In vacuum service" means thai
equipment is operating at an internal
pressure which is at least 5 kilopascats.
(kPa) below ambient pressure.
"In VHAP service" means that a pi<><>
of equipment either contains or conUri>-
a fluid (liquid areas) that is at least 10
percent by weight a volatile hazardous
air pollutant (VHAP) es determined
according to the provisions of
S 61 -245(d). The provisions of 19L24S{d]
also specify how to determine that a
piece of equipment is not in VHAP
service.
"In VOC service" means, for the
purposes of this subpart that (a) the
piece of equipment contains or contacts
a process fluid that is at least 10 percent
VOC by weight (see 40 CFR 80.2 for the
definition of volatile organic compound
or VOC and 40 CFR 80.485(4) to
determine whether a pi«ce of equipment
is not in VOC service) and (b) the piece
of equipment is not in liquid service as
defined in 40 CFR 60.481 ."2
"Open-ended valve or line" means
any valve, except pressure relief valves.
having one side of the valve seat in
contact with process fluid and one side
open to atmosphere, either directly or
through open piping.
"Pressure release" means the
emission of materials resulting from the
system pressure being greater than the
set pressure of the pressure relief
device.
"Process unit" means equipment
assembled to produce a VHAP or its
derivatives as intermediates or final
products, or equipment assembled to use
a VHAP in the production of a product
A process unit can operate
independently if supplied with sufficient
feed or raw materials and sufficient
product storage facilities.
"Process unit shutdown" means a
work practice or operational procedure
that stops production from a process
unit or part of a process unit. An
unscheduled work practice or
operational procedure that stops
production from a process unit or part of
a process unit for less than 24 hours is
not a process unit shutdown. The use of
spare equipment and technically
feasible bypassing of equipment without
stopping production are not process unit
shutdowns.
"Product accumulator vessel" means
any distillate receiver, bottoms receiver.
surge control vessel or product
separator in VHAP sen-ice that is
vented to atmosphere either directly or
through a vacuum-producing system. A
product accumulator vessel is in VHAP
service if the liquid or the vapor in the
vessel is at least 10 percent by weight
VHAP.
"Repaired" means that equipment is
adjusted, or otherwise altered, to
eliminate a leak as indicated by one of
the following: an instrument reading of
10.000 ppm or greater, indication of
liquids dripping, or indication by a
seasei Ifcat • eeei er barter fluid system
hasfafled
"Semiannual" means a 8-month
periffdb the flat samiaaoual period
nondndes on the last day of the last
mootb during the 180 days following
initial startup for new sources: and the
first semiannual period concludes on the
last day of the last full month during the
180 days after the effective date of a
specific subpart that references mis
subpart for existing sources ,m
"Sensor" means a device that
measures a physical quantity or the
change in a physical quantity, such as
temperature, pressure, flow rate, pH. or
liquid level
-Volatile Hazardous Air Pollutant" or
"VHAP" means a substance regulated
under this subpart for which a standard
for equipment leaks of the substance has
been proposed and promulgated.
Benzene is • VHAP.
161.242-1
(a) Each owner or operator subject to
the provisions of this subpart shall
demonstrate compliance with the
requirements of 161.242-1 to i 61.242-11
for each new end existing source as
required in 40 CFR 61.05, except as
provided in 161.243 and 161.244.
(b) Compliance with this subpart will
be detemined by review of records.
review of performance test results, and
inspection using the methods and
procedures specified in i 61.245.
(c)(l) An owner or operator may
request a determination of alternative
means of emission limitation to the
requiieuieiits of |f 61.242-2.61.242-3.
61.242-5. 61.242-6.
61.242-7.61.242-8, 81.242-9 and
81.242-11 as provided in 181.244.''2
(2) If the Administrator makes a
determination that a means of emission
limitation is at least a permissible
alternative to U» requirements of
II81.242-2,61.242-5, «1.242-5. 61.242-6.
61442-7. 61.24^-8, 61.242-9 or 61.242-11.
112
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an owner or operator shall comply with
the requirements of that determination.
(d) Each piece of equipment to which
this subpart applies shall be marked in
such a manner that it can be
distinguished readily from other pieces
of equipment.
(e) Equipment that is in vacuum
service is excluded from the
requirements of } 61.242-2. to } 61.242-
11 if it is identified as required in
|«1.246(eH5).
§•1.242-2 Standard*: Pump*.
(a)(l) Each pump shall be monitored
monthly to detect leaks by the methods
specified in i 61.245(b). except as
provided in i 6U42-l(c) and
paragraphs (d). (e). and (f) of this
section.
(2) Baca •«•* shell be checked by
visual inspection each calendar week
for indications of liquids dripping from
the pump seal.
(bKl) if •» instrument reading of
10.000 ppro or greater is measured, a
leak is detected.
(2) If there are indications of liquids
dripping from the pump seal, a leak is
(c)(l) When a leak is detected, it shall
be repaired as soon as practicable, but
not later than 15 calendar days after it is
detected except as provided in i 81.242-
10.
(2) A first attempt at repair shall be
made no later than S calendar days after
each leak is detected.
(d) Each pump equipped with a dual
mechanical teal system that includes a
barrier fluid system ia exempt from the
requirements of pargraph (a), provided
the following requirements are met:
(1) Each dual mechanical seal system
iK
(i) Operated with the barrier fluid at a
pressure that is at all times greater than
the pump stuffing box pressure: or
(ii) Equipped with a barrier fluid
degassing reservior that is connected by
a closed-vent system to a control device
that complies with the requirements of
i 81.242-11; or
fiii) Equipped with a system that
purges the barrier fluid into a process
stream with zero VHAP emissions to
atmosphere.
(2) The barrier fluid is not in VHAP
•en-ice and. if the pump is covered by
standards under 40 CFR Part 60. is not in
VOC sen-ice.
(3) Each barrier fluid system is
equipped with a sensor that will detect
failure of the seal system, the barrier
fluid system, or bom.
(4) Each pump is checked by visual
inspection each calendar week for
indications of liquids dripping from the
pump seal.
(5}(i) Each sensor as described in
paragraph (d)(3) of this section is
checked daily or is equipped with a
audible alarm, and
(ii) The owner or operator determines.
based on design considerations and
operating experience, a criterion that
indicates failure of the seal system, the
barrier fluid system, or both.
(8)(i) If there are indications of liquids
dripping from the pump seal or the
sensor indicates failure of the seal
system, the barrier fluid system, or both
biased on the criterion determined in
paragraph (d)(5)(U). a leak is detected.
(ii) When a leak ia detected, it shall be
repaired as soon as practicable, bat not
later than 15 calendar days after it is
detected, anoapt a* pcnriUad IB | •L142-
10.
(iii) A first attempt at repair shall be
made no later than 5 calendar days after
each leak is detected.
(e) Any pump that ia designated, aa
described in f 61-Z4Q(e)(2). for no
detectable emissions, as indicated by an
instrument reading of less than 500 ppm
above background, is exempt from the
requirements of paragraphs (a), (c). and
(d) if the pomp:
(1) Has no externally actuated shaft
penetrating the pump housing,
(2) Is demonstrated to be operating
with no detectable emissions, as
indicated by an instrument reading of
less than 500 ppm above background, as
measured by the method specified in
S 61.245(c), and
(3) Is tested for compliance with
paragraph (e)(2) initially upon
designation, annually, and at other times
requested by the Administrator.
(f) If any pump ia equipped with a
closed-vent system capable of capturing
and transporting any leakage from the
seal or seals to a control device that
complies with the requirements of
S 61.242-11. it ia exempt from the
requirements of paragraphs (a)-{e)-
(g) Any pump that is located within
the boundary of an unmanned plant site
is exempt from the weekly visual
inspection requirement of paragraphs
(a)(2) and (d)(4) of this section, and the
daily requirements of paragraph (d)(5)(i]
of this section, provided that each pump
is visually inspected as often as
practicable and at least monthly.
i 11.142-9
(a) Each compressor shall be equipped
with a seal system that includes a
barrier fluid system and that prevents
leakage of process fluid to atmosphere,
except as provided in S 61.242-l(c) and
paragraphs (h) and (i) of this section.
(b) Each compressor seal system as
required in paragraph (a) shall be:
(1) Operated with the barrier fluid at a
pressure that is greater than the
compressor stuffing box pressure: or
(2) Equipped with a barrier fluid
system that ia connected by a closed-
vent system to a control device that
complies with the requirements of
S 61.242-11: or
(3) Equipped with a system that
purges the barrier fluid into a process
stream with zero VHAP emissions to
atmosphere.
(c) The barrier fluid shall not be in
VHAP service and. if the compressor is
covered by standards under 40 CFR Part
60, shall not be in VOC service.
(d) Each barrier fluid system as
described in paragraphs (aHc) of this
section shall be equipped with a sensor
that will detect failure of the seal
system, barrier fluid system, or both.
(e)(l) Each sensor as required in
paragraph (d) of this section shall be
checked daily or shall be equipped with
an audible alarm unless the compressor
ia located within the boundary of an
unmanned plant site.112
(2) The owner or operator shall
determine, based on design
considerations and operating
experience, a criterion that indicates
failure of the seal system, the barrier
fluid system, or bom.
(f) If the sensor indicates failure of the
aeal system, the barrier fluid system, or
both based on the criterion determined
under paragraph (e)(2) of this section, a
leak is detected.
(g)(l) When a leak ia detected it shall
be repaired aa aoon aa practicable, but
not later than 15 calendar days after it is
detected except as provided in i 61.242-
10.
(2) A first attempt at repair shall be
made no later than 5 calendar days after
eack leak ia detected
(h) A compressor is exempt from the
requirements of paragraphs (a) and (b) if
it is equipped with a closed-vent system
capable of capturing and transporting
any leakage from the seal to a control
device that complies with the
requirements of \ 61.242-11. except as
provided in paragraph (i).
(i) Any Compressor that is designated.
aa described in f 81 J48(eK2). for no
detectable emission as indicated by an
instrument reading of less than 500 ppm
above background is exempt from the
113
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requirement* of paragraphs (aHh) if the
compressor
(1) Is demonstrated to be operating
with no detectable emissions, as
indicated by an instrument reading of
less than 500 ppm above background, as
measured by the method specified in
f 61.245(c): and
(2) Is tested for compliance with
paragraph (i](l) initially upon
designation, annually, and at other times
requested by the Administrator.
f 91.242-4 Standarde: "vwau
i gas/vapor service.
(a) Except during pressure releases,
each pressure relief device in gas/vapor
service shall be operated with no
detectable emissions, as indicated by an
instrument reading of less than 500 ppm
above background, as measured by the
method specified in 161.245(c).
(b](l) After each pressure release, the
pressure relief device shall be returned
to a condition of no detectable
emissions, as indicated by an instrument
reading of less than 900 ppm above
background, as soon as practicable, but
no later than 5 calendar day* after each
pressure release, except as
provided in 161.242-10."?
(2) No later than 8 calendar days after
the pressure release, the pressure relief
device shall be monitored to confirm the
condition of no detectable emissions, as
indicated by an instrument reading of
less than 500 ppm above background, as
measured by the method specified in
I 81.24S(c).
(c) Any pressure relief device that is
equipped with a closed-vent system
capable of capturing and transporting
leakage from the pressure relief device
to a control device as described in
{ 61.242-11 is exempt from the
requirements of paragraphs (a) and (b).
{•1.242-I
(a) Each sampling connection system
shall be equipped with a closed-purge
system or closed vent system, except as
provided in 16l.242-l(c).
(b) Each closed-purge system or
closed-vent system as required in
paragraph (a) shall:
(1) Return the purged process fluid
directly to the process line with zero
VHAP emissions to atmosphere; or
(2) Collect and recycle the purged
process fluid with zero VHAP emissions
to atmosphere; or
(3) Be designed and operated to
capture and transport all the purged
process fluid to a control device that
complies with the requirements of
i 61.242-11.
(c) In-iitu sampling systems are
exempt from the requirements of
paragraphs (a) and (b).
161.242-4 Standards: Open-ended valves
orenea.
(a)(l) Each open-ended valve or line
shall be equipped with a cap, blind
flange, plug, or a second valve, except
as provided in | 61.242-l(c).
(2)The cap. blind flange, plug, or
second valve shall seal the open end at
all times except during operations
requiring process fluid flow through the
open-ended valve or line.
(b) Each open-ended valve or line
equipped with a second valve shall be
operated in a manner such that the
valve on the process fluid end is closed
before the second valve is dosed.
(c) When a double block and bleed
system is being used, the bleed valve or
line may remain open during operations
that require venting the line between the
block valves but shall comply with
paragraph (a) at all other times.
| (1.242-7 Standards: Vatvee.
(a) Each valve shall be monitored
monthly to detect leaks by the method
specified in i 61-245{b) and shall comply
with paragraphs (bHe). except as
provided in paragraphs (f). (g)> and (h) of
this section. |§ 61.249-1 or 61.243-2. and
i 61.242-l(c).
(b) If an instrument reading of 10.000
ppm or greater is measured, a leak is
detected.
(c)(l) Any valve for which a leak is
not detected for 2 successive months
may be monitored the first month of
every quarter, beginning with the next
quarter, until a leak is detected.
(2) If a leak is detected, the valve shall
be monitored monthly until a leak is not
detected for 2 successive months.
(d)(l) When a leak is detected. H shall
be repaired as soon as practicable, but
no later than IS calendar days after the
leak is detected, except as provided in
I61.242-10.
(2) A first attempt at repair shall be
made no later than 5 calendar days after
each leak is detected.
(e) First attempts at repair include, but
are not limited to. the following bent
practices where practicable:
(1) Tightening of bonnet bolts:
(2) Replacement of bonnet bolts:
(3) Tightening of packing gland nuts:
and
(4) Injection of lubricant into
lubricated packing.
(f) Any valve that is designated, as
described in 161.246(eH2). for no
detectable emissions, as indicated by an
instrument reading of less than 500 ppm
above background, is exempt from the
requirements of paragraph (a) if the
valve:
(1) Has no external actuating
mechanism in contact with the process
fluid:
(2) Is operated with emissions less
than 500 ppm above background, as
measured by the method specified in
9 61.24S(c): and
(3) Is tested for compliance with
paragraph (0(2) initially upon
designation, annually, and at other times
requested by the Administrator.
(g) Any valve that is designated as
described in i 61.246(0(1). as an unsafe-
to-monitor valve is exempt from the
requirements of paragraph (a) if:
(1) The owner or operator of the valve
demonstrates that the valve is unsafe to
monitor because monitoring personnel
would be exposed to an immediate
danger as a consequence of complying
with paragraph (a): and
(2) The owner or operator of the valve
has a written plan that requires
monitoring of the valve as frequent as
practicable during safe-to-monitor times.
(h) Any valve that is designated, as
described in i 61.246(0(2). as a difficult-
to-monitor valve is exempt from the
requirements of paragraph (a) if:
(1) The owner or operator of the valve
demonstrates that the valve cannot be
monitored without elevating the
monitoring personnel more than 2
meters above a support surface:
(2) The process unit within which the
valve is located is an existing process
unit: and
(3) The owner or operator of the valve
follows a written plan that requires
monitoring of the valve at least once per
cwlendar year.
t«tJ4t-a
(a) Pressure relief devices in liquid
service and flanges and other
connectors shell be monitored within 5
days by the method specified in
I 61.245(0) if evidence of a potential
leak is (bund by visual, audible.
etfactory. or eeqr other detection
method, except as provided in
|61J42-l(c). 112
(b) If an instrument reeding of 10.000
ppm or greater is measured, a leak is
detected.
(c)(l) When a leak is detected, it shall
be repaired as soon as practicable, but
not later than 15 calendar days after it is
detected, except as provided in I 61.242-
10.
(2) The first attempt at repair shall be
made no later than 5 calendar days after
114
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each leak i» detected.
(d) Fint attempts at repair include.
but are not limited to. the best practices
described under « 61.242-7(e).
161.242-* Standards: Product
Each product accumulator vessel shall
be equipped with a closed-vent system
capable of capturing and transporting
any leakage from the vessel to a control
device as described in 8 61.242-11.
except as provided in i 61.242-l(c). "2
{•1.249-10 ttsndardK May of repa*.
(a) Delay of repair of equipment for
which leaks have been detected will be
allowed if the repair is technically
infeasible without a process unit
shutdown. Repair of this equipment
shall occur before the end of the next
process unit shutdown.
(b) Delay of repair of equipment for
which leaks have been detected will be
allowed for equipment that is isolated
from the process and that does not
remain in VHAP service.
(c) Delay of repair for valves will be
allowed if:
. (1) The owner or operator
demonstrates that emissions of purged
material resulting from immediate repair
are greater than the fugitive emissions
likely to result from delay of repair, and
(2) When repair procedures are
effected, the purged material is collected
and destroyed or recovered in a control
device complying with i 61.242-11.
(d) Delay of repair for pumps will be
allowed if:
(1) Repair requires the use of a dual
mechanical seal system that includes a
barrier fluid system, and
(2) Repair is completed as soon as
practicable, but not later than 6 months
after the leak was detected.
(e) Delay of repair beyond a process
unit shutdown will be allowed for a
valve if valve assembly replacement is
aaoaasary ihsriag the process unit
shutdown, wive assembly supplies have
been depleted, and valve assembly
supplies had been sufficiently stocked
before the supplies were depleted. Delay
of repair beyond the next process unit
shutdown will not be allowed unless the
next process unit shutdown occurs
sooner than a months after the first
process unit shutdown.
161.242-11 ttandardai Closed vent
(a) Owners or operators of closed-
vent systems and control devices used
to comply with provunona of this
subpart shall comply with the provisions
of this section, except as
provided in | 61.242-l(c). m
(b) Vapor recovery systems (for
example, condenser* and adsorbers)
shall be designed and operated to
recover the organic vapors vented to
them with an efficiency of 85 percent or
greater.
(c) Enclosed combustion devices shall
be designed and operated to reduce the
VHAP emissions vented to themVith an
efficiency of 95 percent or greater or to
provide a minimum residence time of
0.50 seconds at a minimum temperature
ofTWC.
(d)(l) Flares shall be designed for an
operated with no visible emissions as
determined by the methods specified in
16l.245(e). except for periods not to
exceed a total of 5 minutes during any 2
consecutive hour*.''J
(2) Flares shall be operated with a
flame present at all times, as determined
by the methods specified in 181.24S.(e).
(3) Flares shall be used only with the
net heating value of the gas being
combusted being 11.2 MJ/scm (300 Btu/
scf) or greater if the flare is steam-
assisted or air-assisted: or with the net
heating value of the gas being
combusted being 7.45 MJ/scm or greater
if the flare is nonassisted. The net
hearing value of the gas being
combusted shall be determined by the
method specified in I 61.24S(e).
(4) Steam-assisted and nonassisted
flares shall be designed for and
operated with an exit velocity, as
determined by the method specified in
I 61.245(e)(4). less than 18 m/sec (60 ft/
sec).
(5) Air-assisted flares shall be
designed and operated with an exit
velocity less than the velocity. "max. as
determined by the method specified in
§ 61.245(eM5).
(6) Flares used comply with this
subpart shall be steam-assisted, air-
assisted, or nonassisted.
(e) Owners or operators of control
devices that are need to comply with the
provisions of mis supbart shall monitor
these control device* to •new* thai they
are operated and maintained in
confortnence with ufcsur ctesian.
(f)(l) Closed-vent systems shall be
designed for and operated with no
detectable emissions, as indicated by an
instrument reading of less than 500 ppm
above background and by visual
inspections, as determined by the
methods specified as 161.245(c).
(2) Closed-event systems shall be
monitored to determine compliance with
this section initially in accordance with
I 61.05. annually, and at other times
requested by the administrator.
(3) Leaks, as indicated by an
instrument reading greater than 500 ppm
and visual inspections, shall be repaired
as soon as practicable, but not later than
15 calendar days after the leak is
detected.
(4) A first attempt at repair shall be
made no later than 5 calendar days after
the leak is detected.
(g) Closed-vent systems and control
devices use to comply with provisions of
this subpart shall be operated at all
times when emissions may be vented to
them.
161.243-1 Alternative star
i for
valves to VHAP service allowable
percentage of valves leaMno.
(a) An owner or operator may elect to
have all valves within a process unit to
comply with an allowable percentage of
valves leaking of equal to or less than
24) percent
(b) The following requirements shall
be met if an owner or operator decides
to comply with an allowable percentage
of valves leaking:
(1) An owner or operator must notify
the Administrator that the owner or
operator has elected to have all valves
within a process unit to comply with the
allowable percentage of valves leaking
before implementing this alternative
standard, as specified in i 61.247(d).
(2) A performance test as specified in
paragraph (c) of this section shall be
conducted initially upon designation.
annually, and at other times requested
by the Administrator.
(3) If a valve leak is detected, it shall
be repaired in accordance with { 81.242-
7(d) and (e).
(c) Performance tests shall be
conducted in the following manner
(1) All valves in VHAP service within
the process unit shall be monitored
within 1 week by the methods specified
in | 61.245(0).
(2) If an instrument reading of 10,000
ppm or greater is measured, a leak is
detected.
(3) The leak percentage shall be
determined by dividing the number of
valves in VHAP service for which leaks
are detected by the number of valves in
VHAP service within the process unit.
(d) Owner or operators who elect to
have all valve* comply with this
alternative standard shall not have a
process unit with a leak percentage
greater than 24) percent.
(e) If an owner or operator decides no
longer to comply with | 61.243-1. the
owner or operator must notify the
Administrator in writing that the work
practice standard described in f 81.242-
7(aHe) will be followed.
115
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f 11.243-2 AMemattve standards tor
vetoes In VHAP sendee skip period teak
detection and repair.
(a)(l) An owner or operator may elect
for aU valves within a process unit to
comply with one of the alternative work
ractices specified in paragraphs (b)(2)
• nd (3) of this section.
(2) An owner or operator must notify
the Administrator before implementing
ne of the alternative work practices, as
specified in { 61.247(d).
(b)(l) An owner or operator shall
amply initially with the requirements
for valves, as described in { 61.242-7.
(2) After 2 consecutive quarterly leak
detection periods with the percentage of
valves leaking equal to or less than 2.0,
an owner or operator may begin to skip
1 of the quarterly leak detection periods
for the valves in VHAP service.
(3) After 5 consecutive quarterly leak
netection periods with the percentage of
valves leaking equal to or less than 2.0,
an owner or operator may begin to skip
3 of the quartely leak detection periods
for the valves in VHAP service.
(4) If the percentage of valves leaking
is greater than 2.0, the owner or operator
shall comply with the requirements as
described in | 81.242-7 but may again
sleet to use this section.
j 41.244 Alternative means of emission
limitation.
(a) Permission to use an alternative
means of emission limitation under
Section 112(e)(3] of the Clean Air Act
shall be governed by the following
procedures:
(b) Where the standard is an
equipment design, or operational
requirement:
(1) Each owner or operator applying
for permission shall be responsible for
collecting and verifying test data for an
alternative means of emission limitation.
(2) The Administrator will compare
test data for the means of emission
limitation to test data for the equipment.
design, and operational requirements.
(3) The Administrator may condition
the permission on requirements that
may be necessary to assure operation
and maintenance to achieve the same
emission reduction as the equipment.
design, and operational requirements
(c) Where the standard is a work
practice:
(1) Each owner or operator applying
for permission shall be responsible for
collecting and verifying test data for an
alternative means of emission limitation.
(2) For each source for which
permission is requested, the emission
reduction achieved by the required work
practices shall be demonstrated for a
minimum period of 12 months>
(3) For each source for which
permission is requested, the emission
reduction achieved by the alternative
means of emission limitation shall be
demonstrated.
(4) Each owner or operator applying
for permission shall commit in writing
each source to work practices that
provide for emission reductions equal to
or greater than the emission reductions
achieved by the required work practices.
(5) The Administrator will compare
the demonstrated emission reduction for
the alternative means of emission
limitation to the demonstrated emission
reduction for the required work
practices and will consider the
commitment in paragraph (c)(4).
(6) The Administrator may condition
the permission on requirements that
may be necessary to assure operation
and maintenance to achieve the same
emission reduction as the required work
practices of this subpart.
(d) An owner or operator may offer a
unique approach to demonstrate the
alternative means of emission limitation.
(e)(l) Manufacturers of equipment
used to control equipment leaks of a
VHAP may apply to the Administrator
for permission for an alternative means
of emission limitation that achieves a
reduction in emissions of the VHAP
achieved by the equipment, design, and
operational requirements of this subpart.
(2) The Administrator will grant
permission according to the provisions
of paragraphs (b). (c). and (d).
581.245 Test methoda and procedures.
(a) Each owner or operator subject to
the provisions of this subpart shall
comply with the test methods and
procedures requirements provided in
this section.
(b] Monitoring, as required in S 61.242.
{ 61.243. and } 61.244. shall comply with
the following requirements:
(1) Monitoring shall comply with
Reference Method 21.
(2) The detection instrument shall
meet the performance criteria of
Reference Method 21.
(3) The instrument shall be calibrated
before use on each day of its use by the
procedures specified in Reference
Method 21.
(4) Calibration gpses shall be:
(i) Zero air (less thanlQppm of
hydrocarbon in air): and P2
(ii) A mixture of methane or n-hexane
and air at a concentration of
approximately, but less than. 10.000 ppm
methane or n-hexane.
(S) The instrument probe shall be
traversed around all potential leak
interfaces as close to the interface as
possible as described in Reference
Method 21.
(c) When equipment is tested for
compliance with no detectable
emissions, as required in § J 61.242-2(e).
61.242-3(i). 61.242-4. 61.242-7(f). and
61.242-11 (f). the test shall comply with
the following requirements:
(1) The requirements of paragraphs
|bXlH4) shall apply.
(2) The background level shall be
determined, as set forth in Reference
Method 21.
(3) The instrument probe shall be
traversed around all potential leak
interfaces as close to the interface as
possible as described in Reference
Method 21.
(4) The arithmetic difference between
the maximum concentration indicated
by the instrument and the background
level is compared with 800 ppm for
determining compliance1.12
(d)(l) Each piece of equipment within
a process unit that can conceivably
contain equipment in VHAP service is
presumed to be in VHAP service unless
an owner or operator demonstrates that
the piece of equipment is not in VHAP
service. For a piece of equipment to be
considered not in VHAP service, it must
be determined that the percent VHAP
content can be reasonably expected
never to exceed 10 percent by weight.
For purposes of determining the percent
VHAP content of the process fluid that
is contained in or contacts equipment
procedures that conform to the methods
described in ASTM Method D-2267
(incorporated by the reference as
specified in i 61.18) shall be used.
(2)(i) An owner or operator may use
engineering judgment rather than the
. procedures in paragraph (d)(l) of this
section to demonstrate that the percent
VHAP content does not exceed 10
percent by weight provided that the
engineering judgment demonstrates that
the VHAP content clearly does not
exceed 10 percent by weight. When an
owner or operator and the
Administrator do not agree on whether
a piece of equipment is not in VHAP
service, however, the procedures in
paragraph (d)(l) of this section shall be
used to resolve the disagreement.
(ii) If am owner or operator determines
that a piece of equipment is in VHAP
service, the determination can be
revised only after following the
procedures in paragraph (d)(l) of this
section.
(3) Samples used in determining the
percent VHAP content shall be
representative of the process fluid that
is contained in or contacts the
equipment or the gas being combusted
in the flare.
(e)(l) Reference Method 22 shall be
116
-------
used to determine compliance of flares
with the visible emission provisions of
this subpart.
(2) The presence of a flare pilot flame
shall be monitored using a thermocouple
or any other equivalent device to detect
the presence of a flame.
(3) The net heating value of the gas
being combusted in a flare shall be
calculated using the following equation:
Hr-K
X
i-l
Where.
HT=Net heating value of the sample. M]/
•cm; where the net enthalpy per mole of
offgas is based on combustion at 25" C
•nd 760 mm Hg, but the standard
temperature for determining the volume
corresponding to one mole is 20*C.
K-Constant 1.7«clO-~1l/ppm) (q mole/
son) (MI/kcal) where standard ''3
temperature for (g mole/son) is 20*C
C,» Concentration of sample component i in
ppm. as measured by Reference Method 18
of Appendix A of 40 FR Part 00 and ASTM
D2S04-67 (reapproved 1977) (incorporated
by reference as specified in i 61.18).
H,-Nel heal of combustion of sample
component i. kcal/g mole. The heats of
combustion may be determined using
ASTM 02382-78 (incorporated by reference
as specified in I 61.18) if published values
are not available or cannot be calculated
(4) The actual exit velocity of a flare
shall be determined by dividing the
volumetric flowrate (in units of standard
temperature and pressure), as
determined by Reference Method 2. 2A.
2C. or* 20. as appropriate, by the
unobstructed (free) cross section area of
the flare tip.
(5) The maximum permitted velocity.
V..,. for air-assisted flares shall be
determined by the following equation:
VMax - S.78+
-------
•Uting why the valve is difficult to
monitor, and the planned schedule for
monitoring each valve.
(g) The following information shall be
recorded for valves complying with
| 01.243-2:
(1) A schedule of monitoring.
(2) The percent of valves found
leaking during each monitoring period.
(h) The following information shall be
recorded in a log that is kept in a readily
accessible location:
(1) Design criterion required in
§ 61 J42-2(d)(5) and { 61.242-3(e)(2) and
an explanation of the design criterion:
and
(2) Any changes to this criterion and
the reasons for the changes.
(i) The following information shall be
recorded in a log that is kept in a readily
accessible location for use in
determining exemptions as provided in
the applicability section of this subpart
and other specific subparts:
(1) An analysis demonstrating the
design capacity of the process unit, and
(2} An analysis demonstrating that
equipment is not in VHAP service.
(j) Information and data used to
demonstrate that a piece of equipment is
not in VHAP service shall be recorded
in a log that is kept in a readily
accessible location.
(Sec. 114 of the Clean Air Act •• •mended
(42 U.S.G. 7414).)
(Approved by the Office of Management and
Budget under control number 2060-0068)
§ 61.247 Reporting requirements.
(a)(l) An owner or operator of any
piece of equipment to which this subpart
applies shall submit a statement in
writing notifying the Administrator that
the requirements of $8 61.242. 61.245.
61.246. and 61.247 are being
•implemented.
(2) In the case of an existing source or
a new source which has an initial
startup date preceding the effective
date, the statement is to be submitted
within 90 days of the effective date.
unless a waiver of compliance is granted
under { 61.11. along with the
information required under ( 61.10. If a
waiver of compliance is granted the
statement is to be submitted on a date
scheduled by the Administrator.
(3) In the case of new sources which
did not have an initial startup date
preceding the effective date, the
statement shall be submitted with the
application for approval of construction.
as described in | 61.07.
(4) The statement is to contain the
following information for each source
(i) Equipment identification number
and process unit identification.
(ii) Type of equipment (for example, a
pump or pipeline valve).
(iii) Percent by weight VHAP in the
fluid at the equipment.
(iv) Process fluid state at the
equipment (gas/vapor or liquid).
(vj Method of compliance with the
standard (for example, "monthly leak
detection and repair" or "equipped with
dual mechanical seals").
(b) A report shall be submitted to the
Administrator semiannually starting 6
months after the initial report required
in § 61.247(a). that includes the
following information:
(1) Process unit identification.
(2) For each month during the
semiannual reporting period,
(i) Number of valves for which leaks
were detected as described in i 61.242-
7(b) of { 61.243-2.
(ii) Number of valves for which leaks
were not repaired as required in
i 61.242-7(d).
(iii) Number of pumps for which leaks
were detected as described in 5 61.242-
2(b) and (d)(6).
(iv) Number of pumps for which leaks
were not repaired as required in
{ 61.242-2(c) and (d)(6).
(v) Number of compressors for which
leaks were detected as described in
i 61.242-3(0
(vi) Number of compressors for which
leaks were not repaired as required in
f 61.242-3(g).
(vii) The facts that explain any deld>
of repairs and. where appropriate. why
a process unit shutdown was technically
infeasible.
(3) Dates of process unit shutdowns
which occurred within the semiannual
reporting period.
(4) Revisions to items reported
according to paragraph (a) if changes
have occurred since the initial report or
subsequent revisions to the initial
report.
INote. Compliance with the
requirementa of I «1.10
semiannual reporting period.
(c) In the first report submitted as
required in i 61.247(a). the report shall
include a reporting schedule stating the
months that semiannual reports shall be
submitted. Subsequent reports shall be
submitted according to that schedule.
unless a revised schedule has been
•ubmitted in a previous semiannual
report.
(d) An owner or operator electing to
comply with the provisions of Si 61.243-
1 and 61.243-2 shall notify the
Administrator of the alternative
standard selected 90 days before
implementing either of the provisions
(e) An application for approval of
construction or modification. § 61.051 a J
and i 61.07, will not be required if—
(1) The new source complies with the
standard. | 61.242;
(2) The new source is not part of the
construction of a process-unit: and
(3) In the next semiannual report
required by I 81.247(b). the information
in $ 61.247(a)(1) is reported.
(Sec. 114 of Ike Clean Air Act a* amend*] |4j
U.S.C. 7414).) (Approved by the Office of
Management and Budget under control
number ICR-1153.)
38 FR 8826, 4/6/73 (I)
as amended
49 FR 23498. 6/6/84 (97)
113
-------
APPENDIX B
ORGANIC VAPOR ANALYZER RESPONSE FACTORS
119
-------
TABLE B-l. RESPONSE FACTORS FOR AID MODEL 580 AND MODEL 585
PHOTOIONIZATION TYPE ORGANIC VAPOR ANALYZERS3
(10.0-eV Lamp)
Compound
Acetone
Acetophenone
Acrolein
Ammonia
Aniline
Benzene
1,3 Butadiene
Carbon disulfide
Chlorobenzene
Cyclohexane
1,2-Dichloroethane
Di ethyl ami ne
Dimethyl sulfide
Ethyl benzene
Ethyl ene oxide
Ethyl ether
Hexane
Hydrogen sulfide
Isopropanol
Methyl ethyl ketone
Methyl isocyanate
Methyl mercaptan
Methyl methacrylate
Nitric oxide
Ortho chloro toluene
Ortho xylene
Pyridine
Styrene
Sec butyl bromide
Tetrachi oroethene
Tetrachi oroethyl ene
Tetrahydrofuran
Toluene
Tri chl oroethyl ene
lonization
potential ,
eV
9.58
N.D.
N.D.
10.15
7.70
9.25
9.07
10.0
9.07
9.98
N.D.
N.D.
8.69
8.75
10.57
9.53
. 10.18
10.45
10.16 .
9.53
10.57
9.4
N.D.
9.25
8.83
8.56
9.32
N.D.
9.98
9.32
N.D.
9.54
8.82
N.D.
Response
factor
1.7
4.2
25.0
24.5
0.6
0.7
1.0
2.3
0.5
2.1
50.0
2.0
1.3
1.7
33.8
1.5
11.3
7.3
19.8
1.6
12.5
1.3
4.2
44.9
0.5
0.8
0.6
3.3
1.7
1.6
1.9
3.7
0.5
1.3
Source: Reference 9.
120
-------
TABLE B-2. RESPONSE FACTORS FOR THE MI RAN MODEL 1A/80 INFRARED ANALYZER
Compound
Acetal
Acetyl-1-propanol, 3-
Benzoyl chloride
Carbon tetrachloride
Chi oro-acetal dehyde
Chloroform
Dichloro-1-propanol ,2,3-
Diisopropyl Benzene, 1,3-
Diketene
Wave-
length,
um
9.5
3.3
9.5
6.35
5.7
6.35
9.5
13.5
13.5
3.3
6.35
5.7
3.3
Actual
concentration,
ppmv
1,000
5,000
10,000
500
1,000
100
500
1,000
100
500
1,000
500
1,000
10,000
500
1,000
10,000
500
1,000
10,000
500
1,000
10,000
1,000
5,000
10,000
1,200
500
1,225
100
500
1,225
5,000
10,000
Instrument
concentration,
ppmv
6,690
23,400
27,200
247
813
39
217
406
4,870
5,080
5,420
115
232
390
4,840
5,680
6,760
76
228
1,880
709
2,300
21,800
6,680
22,200
34,200
64.9
134
507
311
343
380
354
1,240
Response
factor
0.149
0.214
0.368
2.02
1.23
2.55
2.30
2.46
0.02
0.10
0.19
4.35
4.31
25.6
0.103
0.176
1.48
6.58
4.39
5.32
0.705
0.435
0.459
0.150
0.225
0.292
18.5
3.75
2.42
0.331
1.47
3.22
14.1
8.06
(continued)
121
-------
TABLE B-2 (continued)
Compound
Dimethyl sul fide
Ethanol
Ethyl ene glycol dimethyl
ether
Ethyl ene glycol
monoethyl ether
acetate
Wave-
length,
ym
5.7
9.5
5.7
6.35
9.5
3.3
3.4
3.3
3.4
3.6
3.6
5.7
Actual
concentration,
ppmv
1,000
5,000
10,000
1,000
5,000
10,000
1,000
5,000
10,000
1,000
5,000
10,000
1,000
5,000
10,000
1,000
5,000
10,000
1,000
5,000
10,000
1,000
5,000
10,000
1,000
5,000
10,000
1,000
5,000
10,000
1,000
2,000
200
1,000
?. onn
Instrument
concentration,
ppmv
2,280
6,390
8,600
69.4
377
580
822
1,010
1,180
2,480
4,590
6,540
15.3
120
270
3,830
18,500
34,300
430
3,420
7,530
5,110
21,100
33,800
2,310
11,700
20,600
284
1,870
3,920
50.8
158
2,590
5,110
fi.qfin
Response
factor
0.439
0.782
1.16
14.4
13.4
17.2
1.22
4.95
8.47
0.403
1.09
1.53
65.4
41.7
37.0
0.261
0.270
0.292
2.33
1.46
1.33
0.196
0.237
0.296
0.433
0.427
0.485
3.52
2.67
2.55
19.7
12.7
0.0772
0.196
n ?«?
(continued)
122
-------
TABLE B-2 (continued)
Compound
Formaldehyde
Formic acid
Freon 12
Furfural
Glycidol
Hydroxyacetone
Wave-
length,
ym
8.8
9.5
3.3
3.4
5.7
8.8
9.5
6.35
8.8
13.5
3.3
3.6
5.7
6.35
9.5
5.7
Actual
concentration,
ppmv
1,000
2,000
200
1,000
2,000
500
1,000
1,000
500
5,000
10,000
5,000
10,000
500
5,000
10,000
1212.5
2,425
4,850
1212.5
2,425
4,850
100
500
1,200
100
100
100
100
1,000
100
Instrument
concentration,
ppmv
261
808
472
2,190
3,470
266
916
72.4
4,990
23,600
31,300
1,000
2,920
1,190
9,120
14,100
5,940
6,470
7,490
1,714
3,130
4,680
656
5,470
12,200
262
572
3,100
6,540
132
1,950
Response
factor
3.83
2.48
0.424
0.457
0.576
1.88
1.09
13.8
0.100
0.212
0.319
5.00
3.42
0.420
0.548
0.709
0.204
0.375
0.648
0.707
0.775
1.04
0.152
0.0914
0.0984
0.382
0.175
0.323
0.0153
0.758
0.0513
(continued)
123
-------
TABLE B-2 (continued)
Compound
Methyl styrene, -
Methyl ene chloride
Pentanethiol ,1-
Perchloromethyl-
mercaptan
Propylene chlorohydrin
Wave-
length,
ym
6.35
9.5
3.3
5.7
6.35
9.5
13.5
3.3
13.5
3.3
3.6
5.7
8.8
9.5
13.5
Actual
concentration,
ppmv
100
100
1,030
5,000
103
1,030
5,000
1,010
5,000
1,030
5,000
1,030
5,000
5,000
10,000
5,000
10,000
5,000
5,000
500
1,000
5,000
5,000
500
1,000
5,000
500
1,000
5,000
Instrument
concentration,
ppmv
6,870
24.6
976
2,830
330
1,230
1,570
4,490
6,960
73.6
178
167
948
1,740
3,740
5,300
10,500
612
64.0
1,730
3,410
7,660
426
36.7
132
303
3,800
8,510
38,600
Response
factor
0.0146
4.07
1.06
1.77
0.312
0.837
3.18
0.229
0.718
14.0
28.1
6.17
5.27
2.87
2.67
0.943
0.952
8.17
78.1
0.289
0.293
0.653
11.7
13.6
7.58
16.5
0.132
0.118
0.130
(continued)
124
-------
TABLE B-2 (continued)
Compound
Tetrachloroethane,
1,1,2,1-
Tri chl oroethane, 1,1,1-
Tri chl orotri f 1 uoro-
ethane, 1,1,2-
Wave-
length,
ym
3.3
8.8
13.8
3.3
3.4
8.8
9.5
13.5
Actual
concentration,
ppmv
5,000
10,000
10,000
1,000
5,000
10,000
1,000
5,000
10,000
5,000
10,000
1,000
5,000
10,000 ,
1,000
5,000
10,000
5,000
10,000
Instrument
concentration,
ppmv
582
1,010
404
20,000
73,000
101,000
266
2,910
5,920
38.8
421
5,840
16,100
18,500
977
3,690
6,280
1,100
2,270
Response
factor
8.59
9.90
24.8
0.0500
0.0685
0.0990
3.76
1.72
1.69
129.0
23.8
0.171
0.311
0.541
1.02
1.36
1.59
4.55
4.41
Abstracted from Reference 8.
125
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TABLE B-3. RESPONSE FACTORS FOR THE HNU SYSTEMS, INC., MODEL PI-101
PHOTOIONIZATION ANALYZER3
Compound
Acetal
Carbon disulfide
Carbon tetrachloride
Chloroform
Diketene
Perch! oromethyl mecaptan
Toluene
Tetrachi oroethane ,1,1,2,2-
Trichl oroethane, 1,1,
Trichi orotrifluoroethane 1,1,2-
Actual
concentration
1,000
5,000
10,000
1,000
10,000
500
1,000
10,000
1,000
5,000
10,000
1,000
5,000
10,000
5,000
1,000
1,000
5,000
10,000
1,000
5,000
10,000
5,000
10,000
Instrument
concentration
925
7,200
13,200
1,990
12,900
784
1,070
6,070
756
2,550
5,250
148
318
460
103
1,180
736
1,170
1,880
1,020
6,170
9,430
155
430
Response
factor
1.1
0.69
0.76
0.50
0.78
0.64
0.94
1.6
1.3
2.0
1.9
6.8
16.0
22.0
48.0
0.85
1.4
4.3
5.3
0.98
0.81
1.1
32.0
23.0
Abstracted from Reference 8.
126
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TABLE B-4. RESPONSE FACTORS FOR FOXBORO OVA-108 AND BACHARACH TLV SNIFFER AT
10,000 ppmv RESPONSE3
Compound
Acetic acid
Acetic ahydride
Acetone
Acetonitrile
Acetyl chloride
Acetylene
Acrylic acid
Acrylonitrile
Allene
Allyl alcohol
Amylene
Anisole
Benzene
Bromobenzene
Butadiene, 1,3-
Butane, N
Butanol , sec-
Butanol , tert
Butene, 1-
Butyl acetate
Butyl acrylate, N-
Butyl ether, N
Butyl ether, sec
Butylamine, N
Butylamine, sec
Butylamine, tert-
Butyral dehyde, N-
Butyronitrile
Carbon disulfide
Chi oroacetal dehyde
Chlorobenzene
Chloroethane
Chloroform
Chloropropene, 1-
Chloropropene, 3-
Chlorotoluene, M-
Chlorotoluene, 0-
Chlorotoluene, P-
Crotonal dehyde
Cumene
Cyclohexane
Cychohexanone
Cyclohexene
Cyclohexylamine
Diacetyl
Response factor
OVA-108&
1.64
1.39
0.80
0.95
2.04
0.39
4.59
0.97
0.64
0.96
0.44
0.92
0.29
0.40
0.57
1.44 I
0.76
0.53
0.56
0.66
0.70
2.60
0.35
0.69
0.70
0.63
1.29
0.52
B
9.10
0.38
5.38 I
9.28
0.67
0.80
0.48
0.48
0.56
1.25
1.87
0.47
1.50
0.49
0.57
1.54
Response factor
TLV snifferb
15.60
5.88
1.22
1.18
2.72
B
B
3.49 I
15.00
X
1.03
3.91
1.07
1.19
10.90
4.11
1.25
2.17
5.84
1.38
2.57 I
' 3.58 I
1.15
2.02
1.56
1.95
2.30
, 1.47 I
3.92
5.07
0.88
3.90 P
B
0.87
1.24
0.91
1.06
1.17 I
B
B
0.70
7.04
2.17
1.38
3.28
(continued)
127
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TABLE B-4 (continued)
Compound
Dichloro-l-propene,2,3-
Dichloroethane, 1,1-
Dichloroethane,l,2-
Dichloroethylene,cis,l ,2-
Dichloroethylene, trans,! ,1-
Dichloromethane
Dichloropropane,l,2-
Diisobutylene
Dimethoxy ethane, 1,2-
Dimethy 1 f ormami de , N ,N-
Dimethy 1 hydrazi ne , 1 , 1-
Dioxane
Epichlorohydrin
Ethane
Ethanol
Ethoxy ethanol , 2-
Ethyl acetate
Ethyl acrylate
Ethyl chloroacetate
Ethyl ether
Ethyl benzene
Ethyl ene
Ethyl ene oxide
Ethyl enediamine
Formic acid
Glycidol
Heptane
Hexane,N-
Hexene,!-
Hydroxyacetone
Isobutane
Isobutylene
Isoprene
Isopropanol
Isopropyl acetate
Isopropyl chloride
Isovaleraldehyde
Mesityl oxide
Methacrolein
Methanol
Methoxy-ethanol ,2-
Methyl acetate
Methyl acetylene
Methyl chloride
Methyl ethyl ketone
Methyl formate
Response factor
OVA-108b
0.75
0.78
0.95
1.27
1.11
2.81
1.03
0.35
1.22
4.19
1.03
1.48
1.69
0.65
1.78
1.55
0.86
0.77
1.99
0.97
0.73
0.71
2.46
1.73
14.20
6.88
0.41 I
0.41
0.49
6.90
0.41
3.13
0.59
0.91
0.71
0.68
0.64
1.09
1.20
4.39 P
2.25
1.74
0.61
1.44
0.64
3.11
Response factor
TLV snifferb
1.75
1.86
2.15
1.63
1.66
3.85
1.54
1.41
1.52
5.29
2.70
1.31
2.03
0.69 I
X
1.82
1.43
X
1.59
1.14
4.74 D
1.56
2.40
3.26
B
5.55
0.73
0.69
4.69 D
15.20
0.55
B
X
1.39
1.31
0.98
2.19 D
3.14
3.49 D
2.01
3.13
1.85
6.79
1.84
1.12
1.94
120
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TABLE B-4 (continued)
Compound
Methyl methacrylate
Methyl -2-pentanol, 4-
Methyl -2-pentone ,4-
Methyl-3-butyn-2-ol,2
Methyl cyclohexane
Methyl cyclohexene
Methyl styrene,a-
Nitroethane
Nitromethane
Nitropropane
Nonane-n
Octane
Pentane
Picoline,2-
Propane
Propionaldehyde
Proponic acid
Propyl alcohol
Propyl benzene, n-
Propylene
Propyl ene oxide
Pyridine
Styrene
Tetrachl oroethane ,1,1,1,2
Tetrachl oroethane ,1,1,2,2
Tetrachl oroethyl ene
Toluene
Tri chl oroethane, 1,1, 1-
Tri chl oroethane, 1,1, 2-
Trichloroethylene
Tri chl oropropane, 1,2, 3-
Tri ethyl ami ne
Vinyl chloride
Vinyl idene chloride
Xylene, p-
Xylene, m-
Xylene, 0-
Response factor
OVA-108b
0.99
1.66
0.56
0.59
0.48
0.44
13.90
1.40
3.52
1.05
1.54
1.03
0.52
0.43
0.55 I
1.14
1.30
0.93
0.51
0.77
0.83
0.47
4.22
4.83 D
7.89
2.97
0.39
0.80
1.25
0.'95
0.96
0.51
0.84
1.12
2.12
0.40
0.43
Response factor
TLV snifferb
2.42
2.00
1.63
X
0.84
2.79
B
3.45
7.60
2.02
11.10
2.11
0.83
1.18
0.60 P
1.71
5.08 D
1.74
B
1.74 I
1.15
1.16
B
6.91
25.40
B
2.68 D
2.40
3.69
3.93
1.99
1.48
1.06
2.41
7.87
5.87 D
1.40
Abstracted from Reference 6.
'l = Inverse estimation method
D = Possible outliers in data
N = Narrow range of data
X = No data available
B = 10,000 ppmv response unachievable
P = Suspect points eliminated.
129
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APPENDIX C
IONIZATION POTENTIALS OF SELECTED ORGANIC COMPOUNDS
130
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IONIZATION POTENTIAL DATA USEFUL FOR SELECTION OF PHOTOIONIZATION TYPE
ORGANIC VAPOR ANALYZERS3
Chemical
lonization
potential
Chemical
lonization
potential
Acetaldehyde 10.21
Acetamide 9.77
Acetic acid 10.37
Acetone 9.69
Acetonitrile 12.22
Acetophenone 9.27
Acetyl bromide 10.55
Acetyl chloride 11.02
Acetylene 11.41
Acrolein 10.10
Acrylonitrile 10.91
Allyl alcohol 9.67
Ammonia 10.15
Aniline 7.70
Anisole 8.22
Benzaldehyde 9.53
Benzene 9.25
Benzenethiol 8.33
Benzonitrile 9.71
Benzotrifluoride 9.68
Biphenyl 8.27
Bromine 10.55
1-bromobutane 10.13
2-bromobutane 9.98
l-bromo-2-chloroethane 10.63
Broraochlororaethane 10.77
l-bromo-4-fluorobenzene 8199
l-bromo-2-methylpropane 10.09
l-brorao-2-methylpropane 9.89
1-bromopentane 10.10
1-bromppropane 10.18
2-bromopropene 10.08
1-bromopropene 9.30
3-bromopropene 9.70
2-bromothiophene 8.63
m-bromotoluene 8.81
o-bromotoluene 8.79
p-bromotolyene 8.67
Butane 10.63
1,3-butadiene 9.07
2,3-butadione 9.23
1-butanethiol 9.14
1-butene 9.58
cis-2-butene 9.13
Trans-2-butene 9.13
3-butene nitrile 10.39
n-butyl acetate 10.01
sec-butyl acetate 9.91
n-butyl alcohol 10.04
n-butyl amine 8.71
s-butyl amine 8.70
t-butyl amine 8.64
n-butly benzene 8.69
s-butyl benzene 8.68
t-butyl bnnzene 8.68
n-butyl formate 10.50
1-butyne 10.18
n-butyraldehyde 9.86
n-butyric acid 10.16
n-butyronitrile 11.67
Carbon dioxide 13.79
Carbon monoxide 14.01
Chlorine 11.48
Chlorobenzene 9.07
1-chlorobutane 10.67
2-chlorobutane 10.65
l-chloro-2-fluorobenzene 9.16
l-cholor-3-fluorobenzene 9.21
l-chloro-2-methylpropane 10.66
2-chloro-2-methylpropane 10.61
1-chloropropane 10.82
2-chloropropane 10.78
3-chloropropene 10.04
2-chlorothiophene 8.68
m-chlorotoluene 8.83
o-chlorotoluene 8.83
p-chlorotoluene 8.70
Crotonaldehyde 9.73
Cyanogen 13.80
Cyclohexane 9.98
Cyclohexanone 9.14
Cyclohexene 8.95
Cyclo-octatetraene 7.99
Cyclopentane 10.53
Cyclopentanone 9.01
Cyclopropane 10.06
Dedaborane 11.00
Dibromochlororaethane 10.59
Dibromodifluororaethane 11.07
1,1 dibromoethane 10.19
131
-------
1,2 dibromoethene 9.45
Dibromomethane 10.49
1,3 dibromopropane 10.07
m-dichlorobenzene 9.12
o-dichlorobenzene 9.07
p-dichlorobenzene 8.94
1,2 dichloroethane 11.12
cis-dichloroethene 9.65
trans-dichloroethene 9.66
Diborane 12.10
Dichloromethane 11.35
1,2 dichloropropane 10.87
1,3 dichloropropane 10.85
2,3 dichloropropene 9.82
Dibutyl amine 7.69
Diethoxymethane 9.70
N,N-diethyl acetaraide 8.60
Diethyl amine 8.01
Diethyl ether 9.43
N,N-diethyl formamide 8.89
Diethyl ketone 9.32
Diethyl sulfide 8.43
Diethyl sulfite 9.68
Dihydropyran 8.34
1,1 dimethoxyethane 9.65
Diraethoxyraethane 10.00
Diiodomethane 9.34
Diisopropylamine 7.73
N,N-diraethyl acetamide 8.81
Dimethyl amine 8.2
2,2-dimethyl butane 10.06
2,3-dimethyl butane 10.02
3,3-dimethyl butanone 9.17
Dimethyl ether 10.00
N,N-dimethyl formamide 9.12
2,2-dimethyl propane 10.35
Dimethyl sulfide 8.69
Dipropyl amine 7.84
Dipropyl sulfide 8.30
Durene 8.03
Ethane 11.65
Ethanethiol 9.29
Ethene 10.52
Ethyl acetate 10.11
Ethyl alcohol 10.48
Ethyl amine 8.86
Ethyl benzene 8.76
Ethyl bromide 10.29
Ethyl chloride 10.98
Ethyl disulfide 8.27
Ethylene oxide 10.57
Ethyl formate 10.61
Ethyl iodide 9.33
Ethyl isothiocyanate 9.14
Ethyl methyl sulfide 8.55
Ethyl nitrate
Ethyl propionate
Ethyl thiocyanate
Ethynylbenzene
Fluorine
Fluorobenzene
o-fluorophenol
m-fluorotoluene
o-fluorotolune
p-fluorotoluene
Formaldehyde
Formic acid
Freon 11 (CFC13)
Freon 12 (CF2C12)
Freon 13 (CF3C1)
Freon 22 (CHC1F2)
Freon 113 (CF3CC13)
2-furaldehyde
Furan
Hexane
Heptane
2-Heptanone
1-hexene
Hydrogen
Hydrogen bromide
Hydrogen chloride
Hydrogen cyanide
Hydrogen fluorine
Hydrogen iodide
Hydrogen sulfide
Hydrogen telluride
Iodine
lodobenzene
1-iodobutane
2-iodobutane
l-iodo-2-methylpropane
l-iodo-2-methylpropane
1-iodopentane
1-iodopropane
2-iodopropane
o-iodotoluene
m-iodotoluene
p-iodotoluene
Isobutane
Isobutyl amine
Isobutyl acetate
Isobutyl formate
Isobutyraldehyde
Isobutyric acid
Isopentane
Isoprene
Isopropyl acetate
Isopropyl benzene
Isopropyl ether
Isovaleraldehyde
11.22
10.00
9.89
8.82
15.70
9.20
8.66
8.92
8.92
8.79
10.87
11.05
11.77
12.91
12.91
12.45
11.78
9.21
8.89
10.18
10.08
9.33
9.46
15.43
11.62
12.74
13.91
15.77
10.38
10.46
9.14
9.25
8.73
9.21
.09
,18
9.02
9.19
9.26
9.17
8.62
8.61
8.50
10.57
8.70
9.97
10.46
9.76
10.02
10.32
8.85
9.99
10.16
9.20
9.71
9.
9.
132
-------
2,3-lutidine 8.85
2,4-lutidine 8.85
2,6-lutidine 8.85
Mesitylene 8.40
Mesityl oxide 9.08
Methane 12.98
Methanelthiol 9.44
N-methyl acetamide 8.90
Methyl acetate 10.27
Methyl alcohol 10.85
Methyl amine 8.97
Methyl bromide 10.53
2-methyl-l-butane 9.12
3-methyl-l-butene 9.51
3-methyl-2-butene 8.67
Methyl butyl ketone 9.34
Methyl butyrate 10.07
Methyl chloride 11.28
Methylcyclohexane 9.85
4-methylcyclohexene 8.91
Methyl disulfude 8.46
Methyl ethyl ketone 9.53
Methyl formate 10.82
2-methyl furan 8.39
Methyl iodide 9.54
Methyl isobutyl ketone 9.30
Methyl isobutyrate 9.98
Methyl isopropyl ketone 9.32
Methyl isothiocyanate 9.25
1-methyl naphthalene 7.96
2-raethyl naphthalene 7.96
2-methylpentane 10.12
3-methylpentane 10.08
2-methyl propene 9.23
Methyl propionate 10.15
Methyl propyl ketone 9.39
Methyl thiocyanate 10.07
a-methyl styrene 8.35
Naphthalene 8.12
Nitric oxide 9.25
Nitrobenzene 9.92
Nitrogen 15.50
Nitrogen dioxide 9.78
Nitroethane 10.81
Nitromethane 11.00
1-nitropropane 10.88
2-nitropropane 10.71
Oxygen 12.08
Ozone 12.08
Pentaborane 10.40
Pentane 10.35
2,4 pentanedione 8.87
1-pentene 9.50
Phenetole 8.11
Phenol 8.50
Source: Reference 5.
Phenyl isocyanate
Phenyl isothiocyanate
Phosgene
2-picoline
3-picoline
4-picoline
Propane
1-propanethiol
Propiolactone
Propionic acid
Propionitrile
Propionaldehyde
Propyl acetate
Propyl alcohol
Propyl amine
Propyl bnezene
Propylene
Propylene oxide
Propyl ether
Propyl formate
Propylene
Pyridine
Pyrrole
Styrene
Thiolacetic acid
Thiophene
Tetrachloroethene
Tetrachloromethane
Tetrahydrofuran
Tetrahydropyran
Tolune
Tribromethene
Tribromofluoromethane
Tribromomethane
Trichloroethene
Trichloromethane
Triethylamine
Trimethyl amine
2,2,4-triraethyl pentane
Tripropyl amine
Valeraldehyde
Valeric acid
Vinyl acetate
Vinyl bromide
Vinyl chloride
Vinyl methyl ether
Water
m-xylene
o-xylene
p-xylene
8.77
8.52
11.77
9.02
9.02
9.04
11.07
9.20
9.70
10.24
11.84
9.98
10.04
10.20
8.72
8.72
9.73
10.22
9.27
10.54
10.36
9.32
8.20
8.47
10.00
8.86
9.32
11.47
9.54
9.26
8.82
9.27
10.67
10.51
9.45
11.42
50
7,
7,
52
9.
9.
9.86
7.23
9.82
10.12
,19
.80
10.00
8.93
12.59
8.56
8.56
8.45
133
-------
GLOSSARY
Accuracy: The difference between the measured value and the true values
which has been established by an accepted reference method procedure.
In most cases, a value is quoted by the manufacturer, and no description
is given to indicate how this value was obtained.
Action Level: A measured concentration value obtained with a portable VOC
monitor. It indicates the need for repair.
Calibration: The method for determining the instrument response to calibra-
tion gases (dynamic calibration) or artificial stimuli (static calibra-
tion).
Directed Maintenance: Refers to a maintenance procedure in which the hydro-
carbon detector is used during maintenance. The leak is monitored with
the instrument until the repair reduces the measured concentration below
the action level.
Fugitive Emissions of VOC: Generally refers to the diffuse release of
vaporized hydrocarbon or other organic compounds. Fugitive emissions
originate from equipment leaks and from large and/or diffuse sources.
Ground: 1. The electrical neutral line having the same potential as the
surrounding earth. 2. The negative side of dc power supply.
3. Reference point for an electrical system.
Interferences: Any substance or species causing a deviation of instrument
output from the value that would result from the presence of only the
pollutant of concern.
Leak: A measured VOC concentration of the action level or greater, deter-
mined at a specified distance from the fugitive emission source (usually
0 cm). The concentration value that defines a leak can vary, depending
on the regulation and the industry. A value of 10,000 parts per million
by volume (ppmv) is by far the most often used and was used in this
manual unless otherwise noted.
No Detectable Emission: A local VOC concentration at the surface of a source
that indicates that a VOC emission (leak) is not present. Because back-
ground VOC concentrations may exist and to account for instrument drift
and imperfect reproducibility, a difference between the source surface
concentration and the local ambient concentration is determined. A
difference based on a meter reading of less than 5 percent of the leak
definition concentration indicates that a VOC emission is not present.
134
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Precision: The degree of variation between repeated measurements of the same
concentration.
Principle of Operation: The technique used to detect and measure the pollu-
tant or parameter.
Process Stream: Process fluids such as reactants, intermediate products,
final products, and by-products, that are contained within pipes, pumps,
valves, etc., in a process unit. Steam, water, air, and other utility
lines are not considered to be process streams.
Process Unit: Equipment assembled to produce an organic chemical as an
intermediate or final product. A process unit can operate independently
if supplied with sufficient feed or raw materials and sufficient storage
facilities for the final product.
Range: The lower and upper detectable limits. (The lower limit is usually
reported as 0.0 ppm. This is somewhat misleading and should be reported
as the true lower detectable limit.)
Repair: Adjustment or alteration of leaking equipment that reduces the
screening value from greater than or equal to the action level (i.e.,
>_10,000 ppmv) to below the action level (i.e., <1C,000 ppmv).
Response Factor: A correction factor that quantifies the difference in meter
response that a portable VOC analyzer has for various hydrocarbons and
substituted organic chemicals.
Response Time: The time interval from a step change in the input concentra-
tion at the instrument inlet to a reading of 90 percent (unless other-
wise specified) of the ultimate recorded output. This measurement is
the same as the sum of lag time and rise time.
Screening: The act of measuring the hydrocarbon concentration of a source
with a portable hydrocarbon detector.
Screening Value: The hydrocarbon concentration (in ppmv) detected at a
source with a portable hydrocarbon detector while traversing with the
instrument probe around all the potential leak points of the source.
Source Type: Process unit equipment components that may emit fugitive emis-
sions. Common source types of fugitive emissions are valves, pump
seals, flanges, compressor seals, and sampling lines.
Thermocouple: The junction of two dissimilar metals which has a voltage
output proportional to the difference in temperature between the hot
junction and the lead wires (cold junction).
135
-------
Type of Service: The physical state (gas, liquid, or both) of the
material(s) contained in a specific pipeline or vessel. The terms
liquid and gas are defined at operating condition of the process.
Liquid process streams can be further subdivided into:
0 Light VOC liquid—any process stream with a vapor pressure of equal
to or greater than 0.3 kPa at 20°C (lighter than kerosene).
0 Heavy VOC liquid—any process stream with a vapor pressure less
than 0.3 kPe at 20°C. •
Volatile Organic Compound (VOC): Any organic compound that participates in
atmospheric photochemical reactions.
Warmup Time: The elapsed time necessary after startup for the instrument to
meet stated performance specifications when the instrument has been shut
down for at least 24 hours.
136
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