United States Office of Air Quality EPA-450/2-78-036
Environmental Protection Planning and Standards OAQPS No. 1.2-111
Agency Research Triangle Park NC 27711 June 1978
&ERA Guidelines Series
Control of Volatile
Organic Compound
Leaks from
Petroleum Refinery
Equipment
-------
EPA-450/2-78-036
OAQPS No. 1.2-111
Control of Volatile Organic
Compound Leaks from Petroleum
Refinery Equipment
Emission Standards and Engineering Division
Strategies and Air Standards Division
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air, Noise, and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
June 1978
-------
OAQPS GUIDELINE SERIES
The guideline series of reports is being issued by the Office of Air Quality Planning and Standards (OAQPS) to
provide information to state and local air pollution control agencies; for example, to provide guidance on the
acquisition and processing of air quality data and on the planning and analysis requisite for the maintenance of
air quality. Reports published in this series will be available - as supplies perm it-from the Library Services Office
(MD35). U.S. Environmental Protection Agency, Research Triangle Park, North Carolina 27 71 1, or, for a nominal
fee, from the National Technical Information Service, 5285 Port Royal Road, Springfield, Virginia 22161
Publication No. EPA-450/2-78-036
(OAQPS No. 1 2-111)
-------
TABLE OF CONTENTS
Page
Chapter 1.0 Introduction and Summary .1-1
1.1 Need to Regulate Equipment Leaks from Petroleum
Refineries . 1-2
1.2 Monitoring and Maintaining Petroleua Refinery
Equipment 1-2
Chapter 2.0 Sources and Types of Refinery Equipment Leaks . . 2-1
2.1 Sources of VOC Emissions from Equipment Leaks . . 2-1
2.2 Magnitude of VOC Emissions from Equipment Leaks . 2-2
2.3 References 2-4
Chapter 3.0 Control of Refinery Equipment Leaks . . . 3-1
3.1 Monitoring 3-1
3.2 Maintenance 3-3
3.3 References 3-8
Chapter 4.0 Cost Analysts 4-1
4.1 Introduction 4-1
4.2 Control of VOC Leaks from Refineries .... 4-4
4.3 Cost Effectiveness ... . 4-11
4.4 References 4-13
Chapter 5.0 Effects of Applying the Technology ..... 5-1
5.1 Impact of a Monitoring and Maintenance Program
on VOC Emissions 5-1
5.2 Other Environmental Impacts ....... 5-2
5.3 References 5-2
111
-------
Page
Chapter 6.0 Enforcement Aspects 6-1
6.1 Affected Facility ...... 6-1
6.2 Format of Regulation 6-1
6.3 Compliance and Monitoring ........ 6-2
Appendix A. Emission Source Test Data . . . . . . . A-l
Appendix B. Detection of VOC Leaks From Petroleum
Refinery Equipment B-l
Appendix C. Monitoring and Maintenance Manpower Requirements . C-l
iv
-------
LIST OF TABLES
Page
Table 2-1 Distribution of Equipment Leak VOC Emissions for
a Model Refinery 2-3
Table 3-1 Smmry of EPA and Industry Equipment Leak
Source Test Data 3-4
Table 3-2 Suemary of Equipment Leak VOC Concentration Versus
Leak Rate Linear Regression Analysis 3-5
Table 4-1 Technical Parameters Used in Developing Control Costs . 4-3
Table 4-2 Cost Parameters Used 1n Computing Control Costs . . 4-5
Table 4-3 Control Cost Estimates of Monitoring and Maintenance
Program for Model Existing Petroleum Refinery
Equipment Leaks 4-8
Table 4-4 Cost Estimates of Typical Seal 011 Reservoir
Degassing Vent Control System . 4-10
Table A-1 Sunary of Results of Four EPA Tests A-4
Table A-2 Summary of Refinery A Testing A-5
Table A-3 Summary of Refinery B Testing . . . A-6
Table A-4 Summary of Refinery C Testing . A-7
Table A-5 Summary of Refinery D Testing A-8
Table B-1 Monitoring Instrument Performance Criteria .... B-2
Table C-l Annual Monitoring Manpower Requirements for Model
15,900 Cubic Meter Per Day Refinery C-3
Table C-2 Annual Maintenance Manpower Requirements for Model
15,900 Cubic Meter Per Day Refinery ...... C-4
v
-------
LIST OF FIGURES
Page
Figure 3-1 VOC Concentration Versus Leak Rate for Refinery
Valves, . . 3-6
Figure 3-2 VOC Concentration Versus Leak Rate for Refinery
Punps ............... 3-7
Figure 6-1 Example Monitoring Survey Log Sheet ..... 6-7
Figure 6-2 Exaaple Refinery Leak Report 6-8
Figure B-l Zero and Calibration Drift Detemlnatlon . . B-7
Figure B-2 Calibration Error Determination B-8
Figure B-3 Response T1«e Detemlnatlon B-9
vl
-------
ABBREVIATIONS AND CONVERSION FACTORS
EPA policy 1s to express all measurenents In agency documents In
Metric Milts. Listed below are abbreviations and conversion factoir for
British equivalents of Metric units.
Abbreviations
kg - kllograM
3
¦ - cubic aeter
¦ ton - aetric ton
Mg - Megagrai
kg/lO3*3 - kllograMS per thousand
cubic Meters
m /day - cubic Meters per day
cm - centlMeters
Conversion Factor
kg X 2.2 « pound (lb)
lb X 0.45 » kg
m3 X 6.29 - barrel {bbl)
bbl X 0.16 « m3
m ton X 1.1 * short ton
short ton X 0.91 ¦ m ton
*g
m ton
kg/103m3 X 0.35
lb/03bbl X 2.86
lb/10 bbl
kg/103M3
or/day X 6.29 » bbl/day
bbl/day X 0.16
m3/day
cm X 0.39
inches
Frequently used Measurewents 1n this docuwent
15,900 M3/day % 100,000 bbl/day
$100.60/m3 % $16.00/bb1
5 cm -w 2 Inches
61 n 200 feet
v11
-------
1.0 INTRODUCTION AND SUMMARY
This document addresses the control of volatile organic compounds
(VOC) frcm equipment leaks in petroleum refineries. Equipment considered
includes pump seals, compressor seals, seal oil degassing vents, pipeline
valves, flanges and other connections, pressure relief devices, process
drains, and open ended pipes. VOC emitted from equipment leaks are
primarily Cj through Cg hydrocarbons which are photochemically reactive
(precursors to oxidants).
Methodology described 1n this document represents the presumptive
norm or rea^nably available control technology (RACT) that can be
applied to existing petroleum refineries. RAci is defined as the lowest
emission limit that a particular source Is capable of meeting by the
application of control technology that Is reasonably available considering
technological and economic feasibility. It may require technology that
has been applied to similar, but not necessarily.identical, source categories.
It Is not intended that extensive research and development be conducted
before a given control technology can be applied to the source. This does
not, however, preclude requiring a short-term evaluation program to permit
the application of a given technology to a particular source. The latter
effort 1s an appropriate technology-forcing aspect of RACT.
1-1
-------
1.1 NEED TO REGULATE EQUIPMENT LEAKS FROM PETROLEUM REFINERIES
Control techniques guidelines are being prepared for source categories
that exit significant quantities of air pollutants 1n areas of the country
where National A»b1ent Air Quality Standards (NAAQS) are not being attained.
Equipment leaks In petroleum refineries are a significant source of VOC and
tend to be concentrated in areas where the oxidant NAAQS are likely to be
violated.
Nationwide VOC enlsslons from equipment leaks 1n petroleum refineries
are presently estimated to be 170,000 metric tons per year, or about one
percent of the total VOC emissions from stationary sources. The emission
factors upon which these estimates are based are presently being updated.
The total emission estimate 1s expected to Increase when the new factors
become available.
1.2 MONITORING AND MAINTAINING PETROLEUM REFINERY EQUIPMENT
The approach used In this document for controlling VOC leaks from
petroleum refinery equipment 1s dictated by the nature of the emissions.
There are many potential leak sources—over 100,000 1n a very large
ref1nery~and leak rates range over six orders of magnitude. Leaks from
most of the sources are Insignificant; a small percentage of the sources
account for a majority of the total mass emissions. This situation makes
1t difficult to quantify the emissions, and highlights the importance of
a monitoring plan to effectively locate leaks so that maintenance can be
performed.
Recent test data show that when a VOC concentration of over 10,000
parts per million (ppm) 1s found In proximity to a potential leak source,
1-2
-------
the source 1s leaking from one to ten kilograms per day depending on the
type of source. If the leak were not located or repaired for a year, annual
enlsslons from this single source would be from 0.4 to 3.7 metric tons of VOC.
The monitoring plan recommended Includes annual, quarterly, and weekly
Inspections. In the monitoring Inspections the refinery operator will de-
termine the VOC concentration in proximity to each Individual potential
1
leak source with a portable VOC detection Instrument. If the VOC concen-
tration at the source exceeds 10,000 ppm, the leak should be repaired
within fifteen (15) days. The recommended monitoring Intervals are:
annual—pump seals, pipeline valves In liquid service, and process drains;
quarterly—compressor seals, pipeline valves 1n gas service, and pressure
relief valves In gas service; weekly—visual Inspection of pump seals;
and no individual monitoring—pipeline flanges and other connections, and
pressure relief valves In liquid service. Whenever a liquid leak from a
pump seal 1s observed during the visual Inspection and whenever a relief valve
vents to atmosphere, the operator must Immediately monitor the VOC concentration
of that component. If a leak 1s detected, the leak should be repaired within
fifteen datys. The manpower required to perform the Inspections Is approximately
1800 manhours per year for a 15,900 cubic meter per day refinery.
A portion of the components with concentrations In excess of
10,000 ppm will not be able to be repaired within fifteen (15) days. The
refinery operator should report quarterly leaks that cannot be repaired within
this time frame and should make arrangements for this equipment to be
repaired during the next scheduled turnaround or, If unable to bring a com-
ponent Into compliance, apply for a variance on an Individual basis.
1-3
-------
The approximate manpower required to perform maintenance on leaking
equipment is 3800 manhours per year for a 15,900 cubic meter per day
refinery.
1-4
-------
2.0 SOURCES AND TYPES OF REFINERY EQUIPMENT LEAKS
Petroleum refining represents a large potential source of volatile
organic compound (VOC) emissions by virtue of the large quantities of
petroleum liquids refined and the Intricacy of the refining processes.
The major sources of refinery VOC emissions that have been addressed 1n
guideline documents Include fixed roof storage tanks; vacuum producing
systems, wastewater separators, and process unit turnarounds; and gasoline
transfer operations. This chapter discusses equipment leaks, another
significant source of VOC emissions for which controls previously have
been adequately defined.
2.1 SOURCES OF VOC EMISSIONS FROM EQUIPMENT LEAKS
There are many types of equipment In petroleum refineries that can
develop leaks. Among these are pump seals, compressor seals, pipeline
valves, open-ended valves, flanges and other connections, pressure
relief devices and process drains. Most of these sources maintain their
sealing effect through proper mating of two sealing surfaces. These sealing
surfaces Include compressed packings, gaskets, finely machined surfaces
(as 1n mechanical seals), and seats (as 1n pressure relief devices). If
these seals are not properly designed,, constructed, installed, and maintained, they
can degrade to the point where their ability to seal is reduced. As this process
continues, the leaking equipment becomes a significant source of VOC emissions. In
addition to sealing failures, open-ended valves that are not completely
shut off (such as a sample tap or bleed valve) and process drains which
are not properly designed or operated can also emit VOC to atmosphere.
2-1
-------
2.2 MAGNITUDE OF VOC EMISSIONS FROM EQUIPMENT LEAKS
Many studies have been undertaken to determine the magnitude of VOC
emissions from equipment leaks. About twenty years ago, a Joint Project1
mas undertaken to quantify all emissions from refineries in the Los Angeles
air basin. The emission factors that resulted fro® this study are currently
used to estimate the VOC emissions from refineries. 2 Radian Corporation
has been contracted by EPA to update refinery emission factors to the present
3
state of the art. This study 1s Incomplete and thus their preliminary data
cannot be cited. Results should be available In late 1978 or early 1979.
Limited testing has been perforated by KVB, Incorporated;4 Industry;5
Meteorology Research, Incorporated; and EPA, but none of these tests have
yielded new emission factors.
Recent tests have shown that most ref1nery equipment have low leak
rates and that the small percentage of equipment with high leak rates accounts
for a large part of the total VOC emitted. Table 2-1 presents preliminary
Q
data from the Radian study that Illustrates this point. In every
case a small percentage of the sources emit about 90 percent
of tiie emissions. The test program undertaken by KVB, Incorporated, under
Q
contract with California Air Resources Board also found this to be the case.
This leads to the conclusion that the key to controlling VOC emissions from
equipment leaks 1s developing an effective monitoring and maintenance
program to locate this small percentage of the total equipment with high
leak rates so that repairs can be scheduled.
2-2
-------
TABLE 2-1. DISTRIBUTION OF EQUIPMENT LEAK VOC EMISSIONS FOR
A MODEL REFINERY*
COMPONENT
NUMBER OF
COMPONENTS
COMPONENTS
WITH 90% h
OF EMISSIONS0
PERCENT OF
TOTAL REFINERY
LEAK EMISSIONS
Pump Seals
250
23
5
Compressor Seals
14
2
2
Pipeline Valves
25,500
765
75
Process Drains
1.400
56
3
Pressure Relief
Valves
130
7
11
Flanges
64,000
640
4
a Based on actual sampling of equipment In six refineries by Radian
Corporation (Reference 3) and a model 15,900 cubic meter per day
refinery.
b Ninety percent of the total mass emissions are emitted by the listed
number of the components.
2-3
-------
2.3 REFERENCES
1. "Joint District, Federal and State Project for the Evaluation of
Refinery Emissions," Los Angeles County A1r Pollution Control District,
Nine Reports. 1957 - 1958.
2. "Compilation of Air Pollutant Emission Factors," Second Edition,
AP-42, U.S. Environmental Protection Agency, April, 1973.
3. "Assessment of Environmental Emissions from 011 Refining," Radian
Corporation, EPA Contract No. 68-02-2665, 1n progress, March, 1976 to
March, 1979.
4. Personal communlcation between Harold J. Taback, KVB, Incorporated,
and K.C. Hustvedt, U.S. EPA, memo to the flies dated March 10, 1978.
5. Letter with attachments from J.M. Johnson, Exxon Company, U.S.A.
to Robert T. Walsh, U.S. EPA, ESED, CPB, July 28, 1977.
6. Letter with attachments from B. F. Ballard, Phillips Petroleum
Company, to William Stewart, Texas A1r Control Board, September 8, 1977.
7. Personal communication between Paul Harrison, Meteorology
Research, Incorporated, and K.C. Hustvedt, U.S. EPA, memo to James F. Durham,
dated January 18, 1978.
8. "Assessment of Environmental Emissions from Oil Refining,"
op clt.
9. Taback, op clt.
2-4
-------
3.0 CONTROL OF REFINERY EQUIPMENT LEAKS
There ire two phases to controlling volatile organic compound (VOC)
emissions from equipment leaks; first, the laaks must be located (monitoring),
and then the leak must be repaired (maintenance). This chapter discusses
both phases. The manhour requirements of applying the monitoring and
maintenance program are presented In Appendix C, costs in Chapter 4, and
environmental effects 1n Chapter 5.
3.1 MONITORING
There are many types of monitoring that may be effective 1n reducing
emissions of VOC to atmosphere. These Include Individual source monitoring,
unit walkthrough monitoring, and multiple fixed-point monitoring. Only
Individual source monitoring has been evaluated sufficiently to determine
its effectiveness and will therefore be the only technique discussed below.
3.1.1 Individual Source Monitoring
Each type of equipment listed 1n Chapter 2 can be monitored for leaks
by sampling the ambient air 1n proximity to the potential leak point with
a portable VOC detection Instrument. Both the recommended Instrument and
monitoring techniques for each type of equipment are described 1n Appendix B.
Routine monitoring of every potential leak source 1n this manner will ensure
that all leaks in the refinery are located, thus allowing maintenance to be
)
scheduled as necessary.
In order to develop a monitoring plan for equipment leaks, one must
first define what constitutes an equipment leak. Tests were performed by
Radian Corporation 1n four refineries on equipment that had a VOC
3-1
-------
concentration of over 10,000 parts per million (ppm) at the seal Interface. 1
In the 166 tests Radian performed, the average leak rate was 5.6 kilograms
per day (kg/day) with leak rates ranging from 1.0 to 10.1 kg/day for the
different types of equipment. This Is a significant leak rate, averaging
over 2 metric tons per year per source. If this leaking equipment were
located and repaired, an appreciable reduction In VOC emissions would result.
Table 3-1 shows the Incidence of leaks for different types of refinery
equipment as found In EPA and Industry * source tests. Here again 1t 1s
shown that a small percentage of the sources leak. This table 1s used In
Appendix C to determine the manpower requirements for repairing leaking
equipment. In the EPA and Industry tests a leaking component Is defined as one
havinn a VOC concentration over 1000 parts oer million (ppm) at a distance of 5
centimeters (cm) from the potential leak source. In this document, however,
a leaking component has a VOC concentration of over 10,000 ppm at the potential
leak source (0 cm). It has been shown in the tests performed by Radian
4 5
Corporation and Meteorology Research that these two values are equivalent.
Table 3-2 summarizes log-log linear regression analyses that were performed
by Radian for equipment total leak rate versus VOC concentration at a given
distance from pump seals, compressor seals and valves. Figures 3-1 and 3-2
are the actual relations that the analyses predicts for valves and pumps,
respectively. There are fewer sources sampled at the 5 cm distance
because this analysis was not Initiated until after the sampling was underway.
This analysis shows that a VOC concentration of 1000 ppm at 5 cm and 10,000 ppm
at 0 cm represent equivalent emission rates so the leak rate incidence data
shown In Table 3-1 1s valid for both leak definitions.
3-2
-------
3.1.2 VI«uil Inspection
As a supplement to Individual source monitoring with a portable VOC
detection device, visual Inspections can b« performed to datact evidence
of liquid leakage from pump seals. Mhan visual avldanca of liquid leakage
from a pump seal Is observed, the operator should 1 mediately obtain a
portable VOC detection Instrument and monitor the component as outlined
in Appendix B. If the component 1s found to be leaking, i.e., a VOC
concentration over 10,000 ppm, maintenance should be scheduled. All liquid
leaks will not necessarily result in a reading greater than 10,000 ppm.
3.2 MAINTENANCE
Uhen leaks ere located by either monitoring method described In
Section 3.1, the leaking component must then be repaired or replaced.
Many components can be serviced on-line and this 1s generally regarded
as routine maintenance to keep operating equipment functioning properly.
Equipment failure, as indicated by a leak which servicing does not
eliminate, requires isolation of the faulty equipment for either
repair or replacement. This will normally result 1n a temporary increase
1n emissions to atmosphere.
r
3-3
-------
TABLE 3-1. SUMMARY OF EPA* ANO INDUSTRY* EQUIPMENT LEAK
SOURCE TEST DATA
Number of
Percent0
Emission Source
Sources Tested
Leaking
Pump Seals 521 12
Compressor Seals 29 7
Pipeline Valves 1350 6
Drains 369 6
Pressure Relief Devices 15d 7e
a Four EPA source tests described in Appendix A.
b One Industry test (Reference 1).
c Concentration over 1000 ppm at 5 centimeters (equivalent 10,000 ppro
at the source).
d Not a representative sample.
e In the Joint Project (Reference 3) a leak was defined as a concentration
over the lower explosive limit inside the horn and in that study 20
percent of the sources leaked. This value is used in the analysis in
Appendix C.
3-4
-------
TABLE 3-2. SUMMARY OF EQUIPMENT LEAK VOC CONCENTRATION VERSUS
LEAK RATE LINEAR REGRESSION ANALYSIS a
Emission Source
Concentration ^
(ppm)
Predicted
Emissions
(kg/day)
Number of
Sources
Sampled
Correlation
Coefficient
Pump Seals
10,000 § 0 cm
1.11
51
0.591
1,000 9 5 cm
1.14
31
0.691
Compressor Seals
10,000 9 0 cm
1,000 9 5 cm d
0.70
19
0.551
Valves
10,000 9 0 cm
0.19
191
0.635
1,000 9 S cm
0.21
73
0.620
a Based on data from four refinery tests by Radian Corporation (Reference 4)
b The Maximum concentration found at the listed distance from the potential
leak source
c The emission rate predicted by the linear regression equation for a leak at
the given concentration* The average emission rate for all leaks greater
than the given concentration would be approximately one order of magnitude
higher.
d A valid sample of VOC concentrations at 5 cm from compressor seals was not
available.
3-5
-------
0.1
u
a>
i.
2L
u
o>
o
s
&
m
«>
5
o
0.01
0.001
10,000
Haxlmum VOC Concentration (parts per million)
FIGURE 3-1. VOC CONCENTRATION VERSUS LEAK RATE FOR REFINERY VALVES
-------
4.0 COST ANALYSIS
4.1 INTRODUCTION
4.1.1 Purpose
The purpose of this chapter is to present estimated costs for control of
volatile organic compound (VOC) emissions from equipment leaks at existing
petroleum refineries.
4.1.2 Scone
Estimates of capital and annualized costs are resented for controlling
emissions from equipment leaks at existing petroleum refineries. The major
sources of VOC emissions that are considered in this chapter Include process
drains; pipeline valves, flanges* connections and fittings; pump and compres-
sor seals; pressure relief devices; and sampling connections. The recommended
control technique to substantially reduce equipment leaks Is a monitoring and
maintenance program. Control costs are developed for a model existing medium
3
size refinery with a throughput of 15,900 m/day. These costs are based on
the use of two (2) monitoring instruments and the leak detection and mainte-
nance procedures specified in Chapter 6. Costs are also presented for a
typical seal oil reservoir degassing vent control system, which may be re-
quired to bring this source of VOC emissions into compliance. Since emission
reductions are not presently quantifiable, recovered product credits and
cost-effectiveness measures have not been determined. However, a simple
procedure is presented that may be used to determine recovery credits and
cost-effectiveness when new refinery emission factors become available.
4.1.3 Use of Model Refinery
Petroleum refineries vary considerably as to size, configuration and
age of facilities, product mix, and degree of control. Because of the vari-
ation among plants, this cost analysis is based on a model medium size
4-1
-------
refinery that has a throughput of 15,900 m3/day. Tabic 4-1 presents the
technical parameters that pertain to the model refinery. The parameters
were selected as being representative of existing medium sized refineries
based on Information from an American Petroleum Institute publication J
petroleum refineries and equipment vendors. Although model plant costs
may differ, sometimes appreciably, with actual costs Incurred, they are
the most useful means of determining.and comparing emission control costs.
4.1.4 Bases for Capital and Annualized Cost Estimates
Capital cost estimates represent the investment required to purchase
and calibrate monitoring instruments for leak detection surveys and the
Installed costs of a seal oil reservoir degassing vent control system.
Annualized control cost estimates include annualized capital charges and
annual materials, maintenance and calibration cost of monitoring instru-
ments, annual monitoring labor cost, annual leak repair and maintenance
labor cost, annual administrative and support cost of the monitoring and
maintenance program, and annual operating and maintenance cost of a de-
gassing vent control system. Cost estimates were obtained from petroleum
refineries, equipment vendors, a major refinery contractor, a national
survey of current salary rates, and an oil Industry journal. All costs
reflect fourth quarter 1977 dollars. Costs for research and development,
production losses during downtime, and other highly variable costs are not
Included In the estimates.
The annualized capital charges are sub-divided Into capital recovery
costs (depreciation and Interest costs) and costs for property taxes and
Insurance. Depreciation and Interest costs nave been computed using a
capital recovery factor based on a 6 year replacement life of the monitoring
4-2
-------
Table 4-1. TECHNICAL PARAMETERS USED IN
DEVELOPING CONTROL COSTS8
I. Refinery Throughput:
15.900 m3/d*y
II. Operating Factor:b
365 d*ys per year
III. Monitoring and Maintenance Program:
A. Recommended Emission Monitoring Procedures per Section 6.3 and
Appendix B.
B. Recommended Monitoring Instruments per Appendix B.
C. Number of Monitoring Instruments:c 2
d £
D. Estimated Monitoring Manhours per year: * 1800
E. Estimated Maintenance and Repair
Manhours per year:d,f 3800
IV. Seal Oil Reservoir Degassing Vent Control Svstem:b
Piping: 61.0 m length, 5.1 cm d1a., carbon steel.
Valves: 3 plug type, 5.1 cm dla., cast steel.
Flame Arrestor: One metal gauze type, 5.1 cm d1a.
V. Average Density of Recovered Product:9
671 Kg/m3
aExcept as noted, parameter values are taken from Chapters 2 and 3.
bEPA estimate.
Reference 2; one monitoring Instrument needed for the refinery, and one
Instrument needed for the tank farm and as a back-up Instrument.
dPer Reference 3 and EPA estimate as discussed In Appendix C.
eBased on two person teams (except for the visual pump seal Inspection)
performing the leak detection surveys.
^Includes Initial leak repair and on-going maintenance.
Reference 4, product that would have leaked but does not escape because
the leaks are repaired; saved product assumed to be equivalent to gasoline.
4-3
-------
Instruments and a 10 year Ufa of tha degassing vant control system and an
Intarast rata of 10X par annum. Costs for property taxas and Insurance
are computed at 4% of the capital costs. All annualized costs are for
one year periods connenclng with the first quarter of 1978.
4.2 CONTROL OF VOC LEAKS FROM REFINERIES
4.2.1 Model Cost Parameters
The major sources of VOC leaks from petroleum refinery equipment Include
process drains; pipeline valves, flanges and other pipe connections; pump
and compressor seals; pressure relief devices; and sampling connections.
The recommended control techniques to reduce VOC emissions from equipment
leaks are a monitoring (leak detection) and maintenance (leak repair) program,
and, when necessary, a seal oil reservoir degassing vent control system. Cost
parameters used 1r» computing emission control costs are shown 1n Table 4-2.
These parameters pertain to the medium size model refinery ami are based on
3 5 fi 7 fi 9
actual cost/price data from petroleum refineries, equipment ven-
dors, IO^^S.16 a survey of current salary rates, an oil industry jour-
la 14
nal, a major refinery contractor, and EPA estimates.
4.2.2 Control Costs of Monitoring and Maintenance Program
Table 4-3 presents the estimated costs of controlling VOC leaks from
equipment of the model medium size petroleum refinery. The costs are based
on the use of two (2) portable organic vapor analyzers that are suitably
equipped and calibrated for monitoring VOC emission leaks. These devices
operate on the flame Ionization detection principle and are certified safe
11
for use In hazardous locations by Factory Mutual Research Corporation.
Except for the visual pump seal Inspections, the estimated monitoring labor
costs are calculated assuming two (2) person survey teams. For the purpose
of determining costs, an Instrument Technician and a Junior Chemical
4-4
-------
Table 4-2. COST PARAMETERS USED IN COMPUTING CONTROL COSTS
I* Monitoring Instruments:*
Purchased EquipMnt Cost: $8,800
Annual Materials* Maintenance, and
Calibration Cost:° 12,500
EquipMnt Replacement L1fe:c 6 years
Battery Pack Replacement Life: 1 year
II. Annualized Capital Charges Factors:0
Annual Interest Rate: 10X
Property Taxes and Insurance Charge: 4X of Capital Cost
III. Monitoring (Leak Oetectlon) Labor Costs:
Annual Monitoring Manhours:^ 1800
Weighted Average Labor Rate:e $14.00/hour
IV. leak Repair and Maintenance Labor Costs:
Annual Leak Repair and Maintenance
Manhours:d 3800
Average Labor Rate:f $14.00/hour
< '
V. Annual Administrative and Support Cost of Monitoring and Maintenance
Program:9
40X of the sum of III. and IV. costs.
VI. Seal Oil Reservoir Degassing Vent Control System:
Carbon Steel P1o1no:h
Installed Capital Cost: S2400
Annual Operating and Maintenance Cost:c
5X of Installed Capital Cost
Life: 10 years
4-5
-------
Table 4-2 (continued)
Plug Tw Valves:1
Specification: MCB ASTM A216-60
Purchase Price: $140 each
Installation Cost:c 10 hr each 9 $14.00/hr.
Annual Operating and Maintenance Cost:
15% of Installed Capital Cost
Life: 10 years
Metal Same Flame Arrestor:^
Specification: Model 4950; ductile Iron with
4.8 mm stainless steel grid
Purchase Price: $260
Installation Cost: 10 hr 9 $14.00/hr
Annual Operating and Maintenance Cost:1
15% of Installed Capital Cost
Life: 10 years
k
VII. Recovered Product Value:
$100.60/m3
References 2, 10 and 11; costs based on the use of two (2) Century Systems
Corp. Model 0VA-108 Portable Organic Vapor Analyzers.
bBased on the following usages per monitoring instrument per year: one (1)
battery pack, and two (2) filter packc.
CEPA estimate.
Reference 3 and EPA estimate as discussed in Appendix C.
References 3, 5, 6, 7, 8, 9 and 12; weighted average labor rate of two (2) person
survey team(s)t consisting of an Instrument Technician and a Junior Chemical
Engineer; Includes wages and salary plus an additional 40% for labor related
costs to refineries. An Instrument Technician and a Junior Chemical Engineer
are assumed for cost purposes; the number and types of personnel actually assigned
the monitoring functions will be determined by the respective refineries.
^References 3, 5, 6, 7, 8 and 9; average labor rate of refinery maintenance
personnel; includes wages plus an additional 40 percent for labor related
costs to refineries.
)
4-6
-------
Table 4-2 (continued)
Reference 3 and EPA estimate; Includes costs of data reduction and
analysis and report preparation.
^Reference 14.
^Reference 15.
^Reference 16.
k
Average gasoline value based on price data from Reference 13 and the
Hall Street Journal, October 20, 21, and 24, 1977 and February 15, 16,
and 17, 1978.
4-7
-------
Tabic 4-3. CONTROL COST ESTIMATES OF MONITORING AND MAINTENANCE
PROGRAM FOR MODEL EXISTING PETROLEUM REFINERY EQUIPMENT
LEAKS
Throughput
15,900 m3/day
Control Technique
Monitoring and
Maintenance Program
Instrument Capital Cost ($000)a
8.8
Annualized Instrument Capital Charges ($000)b
2.4
Annual Instrument Materials, Maintenance, and
Calibration Costs ($000)*»c
2.5
Annual Monitoring Labor Costs ($000)d
25.2
Annual Maintenance Labor Costs ($000)e
53.2
Annual Administrative and Support Costs ($000)^
31.7
Total Annualized Costs ($000)9,h
115.0
References 2, 10 and 11; costs based on the use of two (2) Century Systems Corp.
Model 0VA-108 Portable Organic Vapor Analyzers.
''Capital recovery costs (using capital recovery factor with 10% annual Interest
rate and 6 year Instrument life) plus 4% of capital cost for property taxes
and Insurance.
CEPA estimate.
dEst1mated monitoring man-hours per Reference 3 and EPA estimate; weighted
average labor rate of two person survey team(s) consisting of an Instrument
Technician and a Junior Chemical Engineer per References 3, 5, 6, 7, 8, 9 and 12.
eEst1mated leak repair and maintenance man-hours per Reference 3 and EPA estimate;
average maintenance labor rate per References 3, 5,6, 7, 8, and 9.
^Reference 3.
gTotal Annualized Costs are the sum of Annualized Instrument Capital Charges; Annual
Instrument Materials, Maintenance and Calibration Costs; Annual Monitoring Labor
Costs; AtwuaT Maintenance Labor Costs; and Annual Administrative and Support Costs.
^Credits for recovered (saved) product are not included in these costs.
4-8
-------
Engineer ire assumed to perform the recommended monitoring. The number and
types of personnel actually assigned the monitoring functions will be deter-
mined by the respective refineries. The estimated maintenance labor costs
include both Initial and on-going leak repair and maintenance.
From Table 4-3, It should be noted that the recommended monitoring and
maintenance program for the model medium size refinery has an estimated
capital cost of $8,800 and a total annualized cost of $115,000, not including
recovery credits from reduced emissions. Recovery credits would, of course,
reduce the total annualized cost of control. Since these estimates are
expected costs of typical medium sized refineries, the control costs of actual
refineries may vary from the estimates, depending upon refinery size, con-
figuration, age, condition, and degree of control.
4.2.3 Control Costs of Seal Oil Reservoir Degassing Vent System
Another potential source of V0C emissions are seal oil reservoir de-
gassing vents (refer to Section 6.3.2). In order to bring such a source
into compliance with the concentration limits, a refinery may be required to
install one or more control systems. Table 4-4 presents the estimated costs
of a typical seal oil reservoir degassing vent control system. The technical
parameters and cost parameters of the typical degassing vent control system
are shown in Tables 4-1 and 4-2, respectively.
From Table 4-4, it can be seen that the typical degassing vent control
system has an estimated installed capital cost of $3,700 and a total annualized
cost of $1,200. These costs are based on the emissions being piped to an ex-
isting heater fire box with no credit allowed for the fuel value of the V0C.
Recovered fuel credits would, of course, reduce the total annualized cost of
control. Alternately, the V0C emissions may be piped to an existing flare
system at slightly lower expected control costs; however, there will be no
recovery of the fuel value.
4-9
-------
Table 4-4. COST ESTIMATES OF TYPICAL SEAL OIL RESERVOIR
DE6ASSIN6 VENT CONTROL SYSTEM
Installed Capital Cost ($000)®
3.7
Annualized Capital Charges ($000)b
0.8
Annual Operating and Maintenance Costs ($000)c
0.4
Total Annualized Costs ($000)d,e
1.2
References 14, IS, and 16.
bCap1tal recovery costs (using capital recovery factor with 1QX oinual
Interest rate and 10 year replacement .Ufa) plus 4< of capital znst
for property taxes and insurance.
References 15 and 16 and EPA estimates.
dTotal Annualized Costs are the sun of Annualized Capital Charges and
Annual Operating and Maintenance Costs.
eCredits for fuel value of recovered VOC are not included in these costs.
4-10
-------
4.3 COST-EFFECTIVENESS
Since emission reduction factors are not presently quantifiable, recovered
product credits (savings) cannot be calculated and cost effectiveness measures,
such as $ per Mg, have not been determined. However, assuming that the re-
covered (saved) product value 1s $150/Mg*, It would require an emission reduc-
tion of about 767 Mg per year for the total value of recovered product to be
equal to the total annualized cost of the monitoring and maintenance program.
In this special case, the cost effectiveness would be $0.0 per Mg of reduced
emissions. Thus, an emission reduction greater than 767 Mg/year will result
In a net credit (savings) while an emission reduction less than 767 Mg/year
will be a net cost.
A simple three-step procedure 1s presented below that may be used to
determine recovered product credits and cost effectiveness ratios of the
monitoring and maintenance program when new refinery emission factors become
available. This procedure Is Illustrated for a hypothetical emission reduc-
tion of 500 Mg/year for the model refinery.
Step 1:
Annual Product Recovery Credits ¦ (Annual Emission Reduction) x
(Recovered Product Value) = (500 Mg/yr) ($150/Mg) = $75,000/yr.
Step 2:
Total Annualized Cost * $115,000 - (Annual Product Recovery Credits) =
$115,000 - $75,000 * $40,000
Step 3:
C«t Effect,™™, -
4-11
-------
The cost-effectiveness of each seal oil reservoir degassing vent control
systw will vary with the particular situation, so quantitative C-E values
cannot be presented In this guideline. But, whether or not such a control
system Is used should be based on an analysis that takes Into account the
potential emission reduction and the cost and technical feasibility of
bringing the source Into compliance with the concentration limitation. /
4-12
-------
4.4 REFERENCES FOR CHAPTER 4.0
1. "Hydrocarbon Emissions from Refineries", American Petroleum
Institute Publication No. 928, July, 1973.
2. K. C. Hustvedt, U.S. EPA. Mono to R. A. Quaney, dated March 6, 1978.
3. J. N. Johnson, Exxon Co., U.S.A. Letter to R. T. Walsh, U.S. EPA, with
attached studies of monitoring and maintenance program manpower require-
ments, dated July 28, 1977.
4. AP-42, Supplement No. 7, pg. 4.3-7.
5. Personal communication with L. Sturrock, Phillips Petroleum Co.,
Bartlesvllle, Ok la. Nemo to be file by R.A. Quaney, U.S. EPA, dated
February 24, 1978.
6. Personal communication with F. Roan, Gulf 011 Co., Philadelphia, Penn.
Memo to file by R. A. Quaney, U.S. EPA, dated May 24, 1978.
7. Personal communication with P. Thomas, Ashland 011 Co., Kentucky.
Memo to file by R. A. Quaney, U.S. EPA, dated May 24, 1978.
8. E. D. Blum, Union Oil Co. of California, Los Angeles, Calif. Letter
to R. A. Quaney, U.S. EPA, dated June 8, 1978.
9. Personal communication with B. Beyaert, Chevron U.S.A., San Francisco,
Calif. Memo to file by R. A. Quaney, U.S. EPA, dated June 9, 1978.
10. Personal communication with W. C. Hood, Century Systems Corp.,
Arkansas City, Kansas. Memo to file by R. H. Schippers dated July 13,
1977. Personal communication with J. Dickey, Century Systems Corp.,
Arkansas City, Kansas. Memo to file by R. A. Quaney dated February 14, 1978.
11. Organic Vapor Analyzer Specifications (CS-07907217) and Price List
(PL-038-7751), Century Systems Corp., Arkansas City, Kansas, 1977.
12. Persona1 communication with R. Tew, Director of Career Planning and
Placement, North Carolina State University, Raleigh, N.C. Memo to
file by R. A. Quaney dated February 27, 1978.
13. "Refined-products prices". Oil and 6as Journal. October 17, 1977 and
March 6, 1978.
14. Personal communications with M. Shoemaker, Fluor Corporation, Irvine,
Calif. Memo to file by R. A. Quaney, U.S. EPA, dated October 4, 1977.
Memo to file by R. H. Schippers, U.S. EPA, dated July 18, 1977.
4-13
-------
i
'v <; Wi#, r-rM
/¦ 1 ^ ^ * . *
> ->4 -.- *
:y-;i
r»
i* Ai
-;.i
I.
ifife-.KiJ
- •* • /?"'w? i
4-14
LaiyiHifeililii^
-------
5.0 EFFECTS OF APPLYING THE TECHNOLOGY
The Impacts of the Monitoring and maintenance program on air
pollution, water pollution, solid waste and energy are discussed In
this chapter.
5.1 IMPACT OF A MONITORING AND MAINTENANCE PROGRAM ON VOC EMISSIONS
Estimated volatile organic compound (VOC) emissions from equipment
leaks 1n petroleum refineries are 170,000 metric tons per year. This
represents almost one percent of the total nationwide VOC emissions from
stationary sources.1 This estimate Is based on existing AP-42 emission
factors for leak sources of 174 kilograms per thousand cubic meters of
refinery throughput and 1977 Industry throughput of 2.69 million cubic
3
meters per day. As discussed In Chapter 2.0, the AP-42 emission faetors
are based on 20 year old data. Emission factors for petroleum refinery
equipment leaks are presently being updated, and preliminary date show
the total leak emission rate 1s greater than AP-42 Indicates.4 In order
to avoid confusion that occurs when new emission factors are published
based on old or limited data, no attempt has been made to quantify the
emission reduction associated with a monitoring and maintenance program.
Rather, we will rely on the results of studies presently underway to
define total emissions and Mission reductions at some future date.
5-1
-------
5.2 OTHER ENVIRONMENTAL IMPACTS
EPA has examined the Impacts of applying the control technology
to petroleum refineries and has determined that there are no significant
adverse effects on other air pollution, water pollution, or solid waste.
There will be a very small energy requirement for monitoring Instruments
and equipment repairs. This requirement will be more than offset by
energy savings realized through product recovery when leaks are located
and repaired.
5.3 REFERENCES
1. "National A1r Quality and Emission Trends Report 1975."
Environmental Protection Agency, OAQPS, MDAD-MRB, Research Triangle
i
Park, N.C., EPA-450/1-76-002, November, 1976.
2. "Revision of Evaporative Hydrocarbon Emission Factors,"
EPA Report No. 450/3-76-039, August, 1976.
3. Cantrell, A, Annual Refining Survey. The Oil and Gas Journal,
75(13): 97-123, March 28, 1977.
4. "Assessment of Environmental Emissions From Oil Refining,"
Radian Corporation, EPA Contract No. 68-02-2665, In progress, March, 1976
to March, 1979.
-------
6.0 ENFORCEMENT ASPECTS
The purpose of this chapter 1s to define facilities to which regulations
will apply, to select appropriate regulatory format and to recomnend compliance
and monitoring techniques.
6.1 AFFECTED FACILITY
In formulating regulations it Is suggested that the affected facility
be defined as each individual source within a petroleum refinery complex.
A petroleum refinery complex Is defined as any facility engaged In producing
gasoline, arotnatics, kerosene, distillate fuel oils, residual fuel oils,
lubricants, asphalt, or other products through distillation of petroleum or
through redistillation, cracking, rearrangement or reforming of unfinished
petroleum derivatives. The affected facilities are each Individual source that
could potentially leak volatile organic compounds (VOC) to atmosphere. These
sources Include, but are not limited to, pump seals, compressor seals, seal oil
degassing vents, pipeline valves, flanges and other connections, pressure relief
devices, process drains, and open ended pipes.
6.2 FORMAT OF REGULATION
Regulations limiting emissions from refinery equipment leaks should
state that when any affected facility (component) within the petroleum refinery
complex Is found to be leaking, the refinery operator should make every
reasonable effort to repair the leak within fifteen (15) days. A leaking
component Is defined as one which has a VOC concentration exceeding 10,000 parts
per million (ppm) when tested 1n the manner described 1n Appendix B. L«aks
6-1
-------
detected by either the refinery operator or the air pollution control agency
would be subject to these guidelines. Reconnended monitoring requirements for
the refinery operators are presented 1n Section 6.3. In addition to the
concentration limit, regulations should specify that any time a valve Is
located at the end of a pipe or line containing V0Ct the end of the line
should be sealed with a second valve, a blind flange, a plug or a cap.
This sealing device may be removed only when the line 1s 1n use, i.e. when
a sample 1s being taken. This recommendation does not apply to safety
pressure relief valves.
6.3 COMPLIANCE AND MONITORING
The following sections outline suggested procedures petroleum refinery
operators and air pollution control agencies should follow to
control VOC leakage from refinery equipment.
6.3.1 Monitoring Requirements
In order to ensure that all existing leaks are Identified and that new
leaks are located as soon as possible, the refinery operator should perform
component monitoring using the method described 1n Appendix B as follows:
1. Monitor with a portable VOC detection device one time per
year (annually): pump seals
pipeline valves In liquid service
process drains
2. Monitor with a portable VOC detection device four times per
year (quarterly): compressor seals
pipeline valves 1n gas service
pressure relief valves In gas service
6-2
-------
3. Monitor visually fifty-two (52) times per year (weekly):
pump seals
4. No Individual monitoring necessary:
pipeline flanges
pressure relief valves 1n liquid service
For the purposes of this document, gas service for pipeline valves
and pressure relief valves Is defined as the VOC being gaseous at
conditions that prevail 1n the component during normal operations.
These components should be marked or noted In some way so that their
location 1s readily obvious to both the refinery operator performing
the monitoring and the air pollution control officer. Whenever liquids
are observed dripping from a pump seal, the seal should be checked
immediately with a portable VOC detector to determine if a leak 1s
present, I.e., a concentration over 10,000 ppm. If so, the leak should
be repaired within 15 days. In addition, whenever a relief valve vents
to atmosphere, the operator again has fifteen (15) days to monitor and
repair any leak that occurs. Finally, pressure relief devices which are
tied in to either a flare header or vapor recovery should be exempted from
the monitoring requirements.
6.3.2 Recording Requirements
When a leak 1s located, a weatherproof and readily visible tag bearing
an I. D. number and the date the leak Is located should be affixed to the
leaking component. The presence of the leak should also be noted on a survey
log similar to the one shown In Figure 6-1. When the leak is repaired, the
remalnlnq portions of the survey log (Figure 6-1) should be completed and
the tag discarded. The operator should retain the survey log for two years
after the inspection Is completed.
6-3
-------
6.3.3 Reporting Requirements
After each quarterly «mi1 toring hat bam performed (and the annual),
the refinery operator should submit a report to the air pollution control
officer listing all leaks that were located but not repaired within the
fifteen (15) day limit. A sample report 1s shown in Flqure 6-2. In
addition to submitting the report, the refinery operator should submit
a signed statement attesting to the fact that all monitoring has been
performed as stipulated 1n their control plan.
6.3.4 Other Considerations
Presently, there 1s little information available on the amount of
monitoring necessary to ensure that leaks are kept to a reasonable
limit. Considering this shortcoming, regulations that are written
should allow for modifications in the monitoring schedule where 1t is
proven to be either inadequate or excessive. If, after over one year
of monitoring, I.e., at least two complete annual checks, the refinery
operator feels that modifications of the requirements are In order, he may
request In writing to the air pollution control officer that a revision
be made. The submittal should include data that have been developed to
justify any modifications in the monitoring schedule. On the other
hand, 1f the air pollution control officer finds an excessive number of
leaks during an Inspection, or 1f the refinery operator found an excessive
number of leaks 1n any given area during scheduled monitoring, the air
pollution control officer should Increase the frequency of Inspections for
that part of the facility.
The refinery operator should not be restrained from adopting alternative
monitoring methods 1f these methods are shown to be equivalent to
those presented here. An example would be substituting walkthrough
6-4
-------
monitoring (as described In Appendix B) for the quarterly Individual gas
service valve monitoring. In order to apply for such a modification, the
refinery operator should establish a VOC concentration "action level"
and document Its effectiveness at locating leaks. Other alternative
monitoring Methods such as using soap solution to detect leaks from
"cool" components may be used if the refinery operator can develop a
data base to prove equivalence with the recommended procedure, I.e. a
concentration limit of 10,000 ppm.
It is anticipated that in most cases,a leaking component will be able
to be brought into compliance with the 10,000 ppm concentration limit
(repaired) with a minimum of effort. There are sources, however, that may
need to be isolated from the process in order to be repaired. This procedure
may be difficult for some equipment, especially compressors that do not have
spares and.valves that cannot be isolated. For these and possibly other
sources, it may be necessary to have a partial or complete unit shutdown
to repair the leak. Since a unit shutdown m*y create more emissions than
the repair eliminates, these sources need not be repaired until the
necessary shutdown occurs, such as a scheduled unit turnaround.
In certain instances, more than simple or unit shutdown repairs will
be necessary to bring a leaking component into compliance. This can
be true for some pump or compressor seals or for drain systems. It may
be necessary to modify or replace the whole pump or compressor seal system
or to modify the underground drain pipes. One example of this is when a dual
sealing system is used for pumps or compressors. A seal oil Is flushed
between the two seals creating a potential for VOC emissions if the seal
oil reservoir is degassed to atmosphere. If such a system is used, instead
6-5
-------
of monitoring the VOC concentration of the double seal, the refinery
operator should monitor the seal oil reservoir degassing vent to
determine if It 1s over the 10,000 ppm concentration limit. This source
can be controlled by venting to a firebox or to the flare header.
Sources such as this, where the leak cannot be repaired by maintenance
V
or equipment changeout, should be addressed Individually by the
air pollution control agency, taking Into account both the potential
emission reduction and the cost and technical feasibility of bringing
such a source Into compliance with the concentration 11m1t.
6-6
-------
LEAK DETECTION AND REPAIR SURVEY LOG INSTRUMENT OPERATOR:
RECORDER:
UNIT
COMPONENT
STREAM
COMPOSITION
TAG
NUMBER
DATE
LEAK
LOCATED
DATE
MAINTENANCE
PERFORMED
COMPONI
AFTER
DATE
ENT RECHECK
MAINTENANCE
—rfiSTROHEin—
READING (ppn)
-
*
FIGURE 6-1. Example Monitoring Survey Log Sheet
-------
UNIT
COMPONENT
STREAM
COMPOSITION
DATE
LEAK
LOCATED
DATE
MAINTENANCE
ATTEMPTED
DATE LEAK
WILL BE
REPAIRED
REASON REPAIRS FAILED
OR POSTPONED
>
-
FIGURE 6-2.
Example Refinery Leak Report
-------
APPENDIX A - EMISSION SOURCE TEST DATA
The purpose of Appendix A 1s to summarize and discuss source tests
that were conducted by EPA to define the present leak status of petroleum
refineries 1n the United States. EPA performed source tests at two
Los Angeles, California* area refineries during February 1977; a Houston,
Texas, area refinery In October, 1977; and a New Orleans, Louisiana, area
refinery In November, 1977. Refineries A, C and 0 are Integrated
refineries that produce a wide variety of products. Refinery B 1s a
crude topping and asphalt producing refinery. The following sections give
a brief description of the units tested 1n the refineries and conditions
that existed during the tests. Overall results are summarized In Table A-l
and the Individual results are shown 1n Tables A-2 through A-5. The hydro-
carbon concentrations that are reported are the maximum concentrations that
were found at a distance of 5 centimeters from each Individual leak source.
All tests were performed with a Century Systems OVA-108 Instrument.
A.l REFINERY A
Refinery A 1s a medium sized Integrated refinery owned by a major oil
company. Units surveyed 1n Refinery A Included a cooling tower, a delayed
coker, three wastewater separators, the tank farm, a superfractlonatlon
unit, an atmospheric distillation unit, a vacuum distillation unit, a fluid
catalytic cracking (FCC) unit and the FCC gas plant. All units were operating
normally throughout the testing except for the desalter In the atmospheric
A-l
-------
distillation unit. Improper oil-inter separation caused elevated hydrocarbon
concentrations In the process drains. In a few units there was a large
hydrocarbon cloud downwind from pimps that had mechanical seal failures.
This made It Impossible to survey the pumps and associated equipment
in such an area. A summary of results of component testing at Refinery A 1s
shown 1n Table A-2.
A. 2 REFINERY B
Refinery B Is a small, Independently owned crude topping refinery. All
of the operating equipment In the refinery was surveyed, Including the equipment
associated with their atmospheric and vacuum distillation units. Most of the
pumps In the refinery have dual mechanical seals with a barrier fluid so
very few had detectable leaks. Results of Refinery B testing are shown In
Table A-3.
A. 3 REFINERY C
Refinery C Is a large, major Integrated petroleum refinery. Many units
In Refinery C were surveyed, Including two wastewater separators, a distillate
desulfurlzer, an aromatlcs recovery unit, a crude atmospheric and vacuum
distillation unit, a fluid catalytic cracking unit, a hydrocracker, two
reformers and the tank farm. All of the units were operating normally when
the surveys were performed. The test results are summarized in Table A-4.
A.4 REFINERY D
Refinery D Is a fairly large Integrated refinery. It Is a recently
built grassroots refinery and Is owned by one of the major oil companies.
Only two units were surveyed In Refinery D; the aromatlcs recovery unit and
A-2
-------
-------
TABLE A - 1
SUMMARY OF RESULTS OF FOUR EPA TESTS
Number of Percent b
Emission Source Sources Tested Leaking
Pimp Seals 482 13
OMpressor Seals 15 7
Block Valves 940 6
Control Valves 287 7
Open-Ended Valves c 43* 12
Drains 367 6
Pressure Relief Devices 15 a 0
a Not a representative sample of refinery units
b VOC concentration over 1000 ppm measured at 5 centimeters from
the source. (Equivalent to 10,000 ppm at the source - see Chapter 2.)
c Including bleed valves and sample connections
A-4
-------
TABLE A - 4 SUMMARY OF REFINERY C TESTING
Number of
Percent a
Emission Source
Sources Tested
Leaking
Pump Seals
327
16
Compressor Seals
12
0
Block Valves
601
3
Control Valves
198
8
Open-Ended Valvesb
36
0
Drains
279
5
Pressure Relief Devices
-
-
a VOC concentration over 1000 ppm measured at S centimeters from
the source. (Equivalent to 10,000 ppm at the source - see Chapter 2.)
b Including bleed valves and sample connections
A-7
-------
TABLE A - 5
SUMMARY OF REFINERY D TESTING
Number of
Percent a
Emission Source
Sources Tested
Leaking
Pump Seals
43
16
Compressor Seals
1
0
Block Valves
142
13
Control Valves
61
3
Open-Ended Valves c
3 b
67
Drains
24
15
Pressure Relief Devices
•
—
a VOC concentration over 1000 ppm measured at 5 centimeters from
the source. (Equivalent to 10,000 ppm at the source - see Chapter 2.)
b Not a representative sample
c Including bleed valves and sample connections.
A-8
-------
APPENDIX B
DETECTION OF VOC LEAKS FROM PETROLEUM REFINERY EQUIPMENT
B.l INTRODUCTION
This test method describes the procedures used to detect volatile organic
compound (VOC) leaks from petroleum refinery equipment. A portable test
instrument is used to survey individual equipment leak sources. The specifi-
cations and performance criteria for the test Instrument are included. Also
Included is a description of an alternative walkthrough procedure that may
be used if the refinery owner or operator demonstrates that the procedure is
effective for locating individual equipment leaks.
B.2 APPARATUS
B.2.1 Monitoring Instrument
The VOC detection instrument used in this procedure may be of any type
that is designed to respond to total hydrocarbons or combustible gases. The
instrument must Incorporate an appropriate range option so that source levels
(10,000 ppm) can be measured. The Instrument shall be equipped with a pump
so that a continuous sample is provided to the detector. The Instrument meter
readout shall be such that the scale can be read to > 5 percent at 10,000 ppmv.
The instrument must be capable of achieving the performance criteria given
in Table B.l. The definitions and evaluation procedures for each parameter
are given in Section B.4.
B-l
-------
Table B.l. Monitoring Instrument Performance Criteria
Parameter
1. Zero drift (2-hour)
2. Calibration drift (2-hour)
- 5 ppmv
- 5X of the calibration gas value
- S% of the calibration gas value
- 5 seconds
Specification
3. Calibration error
4. Response time
The Instrument must be subjected to the performance evaluation test prior
to being placed in service and every 6 months thereafter. The performance
evaluation test is also required after any modification or replacement of the
Instrument detector.
B.2.2 Calibration Gases
The VOC detection Instrument 1s calibrated so that the meter readout
1s In terms of parts per million by volume (ppmv) hexane. The calibration
gases required for monitoring and Instrument performance evaluation are a
zero gas (air, < 3 ppmv hexane) and a hexane 1n air mixture of about 10,000 ppmv.
If cylinder calibration gas mixtures are used, they must be analyzed and
certified by the manufacturer to be within - 2 percent accuracy. 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.
Alternative calibration gas species may be used in place of hexane 1f a
relative response factor for each Instrument Is determined so that calibra-
tions with the alternative species may be expressed as hexane equivalents on
the meter readout.
B. 3 PROCEDURES
B.3.1 Calibration
Assemble and start up the VOC analyzer and recorder according to the
manufacturer's instructions. After the appropriate warmup period and zero or
-------
Internal calibration procedure. Introduce the 10,000 ppmv hexane or hexane
equivalent calibration gas Into the Instrument sample probe. Adjust the
Instrument meter readout and chart recorder to correspond to the calibration
gas value.
B.3.2 Individual Source Surveys
Place the Instrument sample probe inlet at the surface of the component
Interface where leakage could occur. During sample collection, the probe
should be moved along the Interface surface with special emphasis placed on
positioning the probe Inlet at the local upwind and downwind side of the
component Interface. If a concentration reading 1n excess of 10,000 ppmv
Is observed, record the date, time, and equipment Identification. This general
technique Is applied to specific types of equipment leak sources as follows:
B.3.2.1 Valves - The most common source of leaks from block (glove, plug,
gate, ball, etc.) and control valves Is at the seal between the stem and
housing. The probe should be placed at the Interface where the stem exits
the seal and sampling should be conducted on all sides of the stem. For
valves where the housing Is a multipart assembly, or where leaks can occur
from points other than the stem seal, these sources should also be surveyed
with the probe Inlet moved along the surface of the Interface.
B.2.2.2 Flanges and other connections - For welded flanges, the probe should
be placed at the outer edge of the flange-gasket Interface and samples
collected around the circumference of the flange. For other types of non-
permanent joints such as threaded connections, a similar traverse 1s conducted
at the component Interface.
B.3.2.3 Pumps and compressors - A circumferential traverse 1s conducted at
the outer surface of the pump or compressor shaft and housing seal interface.
In cases where the Instrument probe cannot be placed In contact with a
B-3
-------
rotating shaft, the probe Inlet must be placed within one centimeter of the
: . : ¦ r - -
shaft-seal Interface. In those cases where the housing configuration of the
pump or compressor prevents the complete traversing of the seal periphery, all
accessible portions of the shaft seal should be probed. All other joints where
leakage could occur shall also be sampled with the probe Inlet placed at the
surface of the Interface. For pumps or compressors using sealing oil, the
vent from the seal oil reservoir shall be sampled by placing the probe inlet
at approximately the centrold of the vent area to atmosphere.
B.3.2.4 Pressure rel1ef dev1ces - The physical configuration of most pressure
relief devices prevents sampling at the sealing surface Interface. However,
most devices are equipped with an enclosed extension, or horn. For this type
device, the probe inlet is placed at approximately the centroid of the exhaust
area to atmosphere.
B.3.2.5 Process drains - For open process drains, the sample probe inlet
shall be placed at approximately the centroid of the area open to the atmos-
phere. For covered drains, the probe should be placed at the surface of the
cover interface and a circumferential traverse shall be conducted.
B.3.2.6 Open-ended valves - Leakage from open-ended valves such as sample
taps or drain lines shall be detected by placing the probe Inlet at approxi-
mately the centroid of the uncapped opening to atmosphere.
B.4 INSTRUMENT PERFORMANCE EVALUATION PROCEDURES
B.4.1 Definitions
Zero drift - The change in the Instrument meter readout over a stated
period of time of normal continuous operation when the VOC concentration at
the time of measurement is zero.
B-4
-------
Calibration Drift - The change In the Instrument meter readout over a
stated period of tine of normal continuous operation when the VOC concentra-
tlon at the tine of measurement Is the sane known upscale value.
Calibration Error - The difference between the VOC concentration Indi-
cated by the meter readout and the known concentration of a test gas mixture.
Response Time - The time Interval from a step change 1n VOC concentration
at the Input of the sampling system to the time at which 95 percent of the
corresponding final value 1s reached as displayed on the Instrunent readout
meter.
B.4.2 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.
B.4.2.1 Zero and calibration drift test - Calibrate the instrument per the
manufacturer's Instructions using zero gas and a calibration gas representing
about 10,000 ppmv. Record the time, zero, and calibration gas readings
(example data sheet shown 1n Figure B.l). After 2 hours of continuous opera-
tion, Introduce zero and calibration gases to the Instrument. Record the
zero and calibration gas meter readings. Repeat for three additional 2-hour
periods.
B.4.2.2 Calibration error test - Make a total of nine measurements by
alternately using zero gas and a calibration gas mixture corresponding to
about 10,000 ppmv. Record the meter readings (example data sheet shown in
Figure B.2).
B.4.2.3 Response time teit procedure - Introduce zero gas Into the instrument
sample probe. When the meter reading has stabilized, switch quickly to the
10,000 ppmv calibration gas. Measure the time from concentration switching
B-5
-------
to 95 percent of final stable reading. Perform this test sequence three (3)
tines and record the results (example data sheet given 1n Figure B.3).
B.4.2.4 The calibration error test and the response time test may be per-
formed during the zero and calibration drift test.
B.4.3 Calculations
All results are expressed as mean values, calculated by:
where:
xi = value of the measurements
£ = sum of the individual values
x * mean value
n * number of data points
The specific calculations for each performance parameter are Indicated on
the respective example data sheet given 1n Figures B.I, B.2, and B.3.
(NOTE: The example data sheets are constructed so that performance criteria
tests can be conducted on 10,000 ppmv levels and a low level (<100 ppmv)
gas. For the purposes of the Individual source surveys, use only the
portions identified as "high calibration.11)
B-6
-------
Instrument ID: Calibration Gas Data: Low ppmv High
Zero Zero Low Calibration Low Calibration High Calibration High Calibration
Date and Time Reading Drift Gas Reading Drift Gas Reading Drift
Start
1.
2.
3.
4. "
Mean (1) Zero
Value: Drift- ppmv
_ mean calibration drift
Calibration Drift ¦ c,n|,r,t
-------
Instrument ID
Low
Calibration Gas Mixture Data
ppm High
_ppn»
Run Calibration Gas
No. Concentration, ppm
Instrument Meter
Reading, ppm
Difference!1^
ppm
1.
2.
3.
4.
5.
6.
7.
8.
9.
Mean Difference
Calibration Error » calibration Gas Concentration * 100
iQM
High
^fcallbratlon Gas Concentration - Instrument Reading
^Absolute Value
Figure B.2. Calibration Error Determination
R-«
-------
InstruMnt ID
Calibration Gas Concentration ____________
95* Response Time:
1. Seconds
2. Seconds
3. Seconds
Mean Response Time Seconds
Figure B.3. Response Time Determination
B-9
-------
B.5 ALTERNATIVE UNIT AREA SURVEYS
B.5.1 Introduction
In this procedure, a process unit area Is surveyed with a portable VOC
detector to determine If there Is an Increased local ambient VOC concentration
in the equipment area. The unit area walkthrough should be planned so that
the unit perimeter and all ground level equipment 1s surveyed. The walkthrough
must Include ambient VOC measurements at a distance of about one meter upwind
and downwind of all pump rows and control valves. In order to simplify data
recording and subsequent data review, a planned walkthrough path with codes
for location Identification Is recommended.
B.5.2 Apparatus
B.5.2.1 Monitoring Instrument - The VOC detection instrument used must conform
to the specifications and performance specifications given in B.2.1 except
that a measurement range must be available for accurately measuring ambient
VOC levels (usually less than 100 ppmv). The minimum detectable VOC concen-
tration must be 2 ppmv hexane or less. Also, the instrument must be equipped
with a portable strip chart recorder so that a permanent record of the walk-
through survey can be retained.
B.5.2.2 Calibration gases - The specifications for the calibration gases
required are given 1n B.2.2, except that the calibration mixture must be
approximately the same concentration as the chosen action level that indicates
a leak in the area.
B.5.2.3 Procedures . Prior to the start of the walkthrough, record the date,
time, origination point, and approximate wind speed and direction In the unit
area. Begin the walkthrough and record location Identifications during the
course of the survey. Make two complete traverses along the walkthrough path
to complete the survey. If an elevated VOC concentration Is observed,
B-10
-------
specifically Identify the location on the chart record. After completion of
the walkthrough survey, record the time and local wind conditions.
B.5.2.4 Data evaluation - Compare the results obtained during each of the
two traverses through the unit area by observing the strip chart records.
Using the ambient VOC concentration upwind of the unit area as a basis, identify
the locations where elevated VOC concentrations were observed on both traverses
Use the prevailing local wind condition information to locate the possible
sources of VOC leakage and use the procedures given 1n B.3.2 to determine If
a leak is present. For those cases where an increased VOC concentration is
observed in a specific location on one traverse, but not on the other, repeat
the ambient measurements in that general location. If increased VOC levels
are again observed, use the procedures in B.3.2 to locate the leak source.
If a repetition of an increased VOC level cannot'be obtained, or if shifts in
the location of elevated VOC concentrations during traverse repetitions can-
not be explained by varying wind direction or speed, treat these as transient
conditions and exclude these areas from individual leak source surveys
required above.
B.5.2.5 Instrument performance evaluation procedures - The VOC instrument
evaluation procedures are the same as those given In B.4 for source level VOC
detection instruments except that the calibration test concentrations must be
in the range expected during ambient surveys. The example data sheets in
Figures B.I, B.2, and B.3 include provisions for evaluation of ambient
level VOC detectors. For those cases where a single detector Is used for
both source and ambient (walkthrough) surveys, the performance evaluations
can be performed at the same time.
B-ll
-------
APPENDIX C
C.l MONITORING AND MAINTENANCE MANPOWER REQUIREMENTS
Table C-1 shows estimated annual manpower requirements for
monitoring 1n the model 15,900 cubic meter per day refinery. These
estimates are based on data supplied by Industry,1 EPA estimates, and
the monitoring guidelines presented 1n Section 6-3. For the purposes
of these estimates only, it Is assumed that these surveys will generally
be performed by two people—one operating the VOC detection Instrument
2
and the other recording the results. The visual Inspections are assumed
to be performed by one person. It 1s shown that the total direct labor
requirement for performing monitoring Inspections In the model refinery
is 1800 manhours per year, of which almost 1000 manhours were spent on
the complete annual Inspection.. Actual complete component testing by a
contractor 1n a more complex but similarly sized refinery took 936 manhours
3
to perform.
When a leak Is detected during the required monitoring, the leaking
component must then be repaired to reduce VOC emissions to atmosphere.
Table C-2 was developed to estimate manpower requirements for maintenance
using the percent of sources that leak from Table 3-1 and the number of
4
sources from industry estimates. In this analysis it is assumed that an
additional ten percent of the Initial leaks will be found each quarter
(hiring ongoing gas service component monitoring. Manpower requirements
C-1
-------
for maintenance of each source were approximated by a refining company5
fi
and the State of California A1r Resources Board. As shown 1n Table C-2,
the total annual direct labor requirement for repairing leaks is 3,800
manhours.
It should be noted that this estimate 1s for the maxlmun maintenance
requirements and will probably be realized only during the first year that
the monitoring and maintenance program 1s 1n effect. Assuming that
refinery equipment was properly specified and Installed, leaks (especially
1n valves) are usually the result of Insufficient leak detection and
maintenance. Once these leaks are identified and repaired, fewer Teaks
will be detected during subsequent inspections. This should result In
much lower maintenance manpower requirements for following years.
C-2
-------
TABLE C-1. ANNUAL MONITORING MANPOWER REQUIREMENTS FOR MODEL 15,900 CUBIC METER PER DAY REFINERY
Number of. Type of Estimated Time Nwbir of Times Annual Total
SOURCE Sources Monitoring Required to . Monitored, Manpower .
to Monitor per Year" Requirement
(minutes) (hours)
Pump Seals
250
Instrument
5
1
42
Visual
0.5
52
108s
Compressor
Seals
U
Instrument
10
4
18
Pipeline Valves
25,500
19 ,500 b
Liquid Service
Instrument
1
1
650
Gas Service
6,000 b
Instrument
1
4
800
Process Drains
1,400
Instrument
1
1
46
Pressure Relief
Devices
130 c
Instrument
8
4 *
138
Pipeline Flanges
14,000
None
TOTAL
0
1800
a Based on Industry (Reference 1) and EPA estimates
b Based on Joint Study (Reference 7) estimate of 23.6 percent of refinery valves being In gas service
c Pressure relief devices In gas service venting to atmosphere
d Monitoring requirements from Section 6-3
e In addition, pressure relief devices will need to be monitored wherever they vent to atmosphere
f Except as noted, total manpower requirements for these estimates are assumed to be based on two person
' teams perforating the monitoring
g (hie person performs visual Inspections
-------
TABLE C-2. ANNUAL MAINTENANCE MANPOWER REQUIREMENTS FOR MODEL
15,900 CUBIC METER PER DAY REFINERY
Source
Number of9
Sources
Estimated Number
of Leaks Detected
Per Year
Average Repair '
Time
(hours)
Total Annual
Manpower
Regulrement
(hours)
Pump Seals
250
30
80
2400
Compressor
Sials
14
2
40
80
Pipeline
Valves
25,500
1640
0.6e
984
Process
Drains
1,400
84
4
336
Pressure
Relief
Valves
130
34
°f
0
Plpeilne
Flanges
64,000
TOTAL
3800
a Based on Industry (Reference 1) and EPA estimates
b Based on Table 3-1 and ten percent of Initial leak recurrence rate for
quarterly Inspections
c No monitoring performed
d This estimate Includes time for rechecking the component after maintenance
is performed
e Weighted average repair time with ten percent of leaks Isolated and repaired
(Reference 1) at a cost of 4 raanhours, and the remaining 90 percent tightened
or greased on-line at a cost of 0.17 manhours (Reference 6)
f These leaks repaired by routine maintenance at no Incremental Increase in
manpower requirements (Reference 1)
C-4
-------
C.2 REFERENCES
1. Letter with attachments from J.N. Johnson* Exxon Company, U.S.A.,
to Robert T. Walsh, U.S. EPA, July 28, 1977.
2. Personal communication between Lynn Sturrock, Phillips Petroleum
Company, and R.A. Quaney* U.S. EPA, memo to files, February 24, 1978.
3. Letter with attachments from B.F. Ballard, Phillips Petroleum
Company, to William Stewart, Texas A1r Control Board, September 8, 1977.
4. Johnson, J.N. Op C1t.
5. Ibid.
6. "Brisslons From Leaking Valves, Flanges, Pump and Compressor
Seals, and Other Equipment at 011 Refineries," State of California Air
Resources Board, Report No. LE-78-001, April 24, 1978.
7. "Hydrocarbon Losses From Valves and Flanges," Robert K. Palmer,
Joint District, Federal and State Project for the Evaluation of Refinery
Emissions. Report No. 2, March, 1957.
C-5
-------
United States
Environmental Protection
Agency
Office of Air. Noise, and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park NC 27711
Official Business
Penalty for Private Use
$300
Publication No EPA-450/2-78-036
Postage and
Fees Paid
Environmental
Protection
Agency
EPA 335
VT
If your address is incorrect, please change on the above label,
tear off. and return to the above address
If you do not desire to continue receiving this technical report
series, CHECK HERE C . tear off label, and return it to the
above address
------- |