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

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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

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 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

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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

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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

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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

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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

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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

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     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

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     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

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                                                                            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

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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.  '

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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

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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
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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

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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

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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
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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
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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.
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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.

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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

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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

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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

-------
§ 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.

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  -"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-^ ^ 
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  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

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   "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

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   (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

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NESHAPS REGULATIONS
        104

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 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

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    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

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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

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 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
 («>(!),  
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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

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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). 
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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
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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
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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.
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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

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              APPENDIX B



ORGANIC VAPOR ANALYZER RESPONSE FACTORS
                  119

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      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

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 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

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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

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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

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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

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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

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 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

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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

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                                  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

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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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