United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park NC 27711
EPA-450/2-78-036
OAQPSNo. 1.2-111
June 1978
Air
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 Off ice
(MD35), U.S. Environmental Protection Agency, Research Triangle Park, North Carolina 2771 1, or, fora 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  NMd to Regulate Equipment Leaks from Petroleum
             Refineries	1-2
        1.2  Monitoring and Maintaining Petroleum 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  Afftcted Facility	     6-1
        6.2  Formt 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 Fran Petroleum
             Refinery Equipment  ....  	   B-l
Appendix C.  Monitoring and Maintenance Manpower Requirements  .   C-1
                               IV

-------
                              LIST OF TABLES
                                                                   Page
Table 2-1  Distribution of Equipment Leak VOC Emissions for
           a Model Refinery	2-3
Table 3-1  Suemary of EPA and Industry Equlpnent Leak
           Source Test Data	    3-4
Table 3-2  Summary 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  Summary 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-l  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

-------
                              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
            PIMBS	    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 Detemlnation  .   .   .   .  B-7
Figure B-2  Calibration Error Determination	B-8
Figure B-3  Response T1«e Determination  	   B-9
                                   vl

-------
                  ABBREVIATIONS AND CONVERSION FACTORS

      EM policy 1s to express all measurements In agency documents In
metric Milts.  Listed below are abbreviations and conversion factor" for
British equivalents of metric units.
Abbreviations
kg  -  kilogram
m   -  cubic meter

m ten  -  metric ton
Mg  -  megagram
kg/urV  -  kilograms per thousand
             cubic meters
m /day  -  cubic meters per day
cm  -   centimeters
Conversion Factor
kg X 2.2  •
Ib X 0.45 '
m3 X 6.29
bbl X 0.16
pound (Ib)
 barrel (bbl)
m ton X 1.1  * short ton
short ton X 0.91 » m ton
Mg  *  m ton
kg/103m3 X 0.35  -  1b/103bb1
1bro3bbl X 2.86  -  kg/103m3
m3/day X  6.29 -  bbl/day
bbl/day X 0.16
                                                            m3/day
on X 0.39  *  Inches
Frequently used measurements 1n this document
     15,900 m3/day -v  100,000 bbl/day
     $100.60/m3     *  $16.00/bb1
          5 cm     -w   2 Inches
          61  n       *   200 feet

-------
                       1.0  INTRODUCTION AND S(MMRY

      This document addresses the control of volatile organic compounds
(«®C) frail 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 C, through C~ hydrocarbons which are photochemlcally reactive
(precursors to oxldants).
       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 Hm1t 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 emit significant quantities of air pollutants 1n areas of the country
where National Ambient 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 oxldant NAAQS are likely to be
violated.
       Nationwide VOC missions 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 in a very large
refinery—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) Is 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
emissions 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
                                              i
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  is 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 days.  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

-------
,v
                  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 In mechanical  seals), and seats (as In 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 1s 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   MAGNITbOE OF VOC EMISSIONS FROH EQUIPMENT LEAKS
      Many studies have been undertaken to determine the magnitude of VOC
emissions from equipment leaks.  About twenty years ago, a Joint Project
was undertaken to quantify all emissions from refineries 1n the Los Angeles
air basin.  The emission factors that resulted from this study are currently
used to estimate the VOC emissions from refineries.    Radian Corporation
has been contracted by EPA to update refinery emission factors to the present
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 performed 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 refinery  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
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
                                                                            g
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 REFINERY8

COMPONENT
PIMP Seals
Compressor Seals
Pipeline Valves
Process Drains
Pressure Relief
NUMBER OF
COMPONENTS
250
14
25.500
1.400
130
COMPONENTS
WITH 90% h
OF EMISSIONS0
23
2
765
56
7
PERCENT OF
TOTAL REFINERY
LEAK EMISSIONS
5
2
75
3
11
   Valves

 Flanges
64,000
640
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 communication 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 are two phases to controlling volatile organic compound (VOC)
emissions fro* equipment leaks; first, the ls»aks 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 in Chapter  2 can be monitored  for  leaks
by sampling the ambient air in 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  in this manner will  ensure
that  all  leaks in the refinery are located, thus allowing maintenance  to be
                                                                    i
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.
  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 2 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
havlnn a VOC concentration over 1000 parts per 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
Corporation 4 and Meteorology Research 5 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  Vltual Inspection
     As a supplement to Individual source monitoring with a portable VOC
detection device, visual Inspections can bt performed to dtttct evidence
of liquid Itakagt fron pump seals.  Uhen visual evidence of liquid leakage
from a PIMP seal Is observed, the operator  should Immediately obtain a
portable VOC detection Instrument and monitor the component as outlined
In Appendix B.  If the component Is 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 Is  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 In a temporary Increase
1n emissions  to atmosphere.
                                    3-3

-------
      TABLE 3-1.  SUMMARY OF EPA* AND INDUSTRY6 EQUIPMENT  LEAK

                         SOURCE TEST DATA
Emission Source
Punp Seals
Compressor Seals
Pipeline Valves
Drains
Pressure Relief Devices
Number of
Sources Tested
521
29
1350
369
15d
Percent0
Leaking
12
7
6
6
7e
a  Four EPA source tests described 1n Appendix A.

b  One Industry test (Reference 1).

c  Concentration over 1000 ppm at 5 centimeters (equivalent 10,000 ppra
   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 hom 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
PiMp Seals

Compressor Seals
Valves

Concentration
(ppm)
10,000 9 0 cm
1,000 95 cm
10,000 9 0 cm
1,000 9 5 cm d
10,000 9 0 cm
1,00095cm
a Based on data from four refinery tests
b The Maximum
concentration found at the
Predicted
Emissions
(kg/day)
1.11
1.14
0.70
0.19
0.21
by Radian
c Number of
Sources
Sampled
51
31
19
191
73
Correlation
Coefficient
0.591
0.691
0.551
0.635
0.620
Corporation (Reference 4)
listed distance from the potential
leak source

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.

A valid sample of VOC concentrations at 5 cm from compressor seals was not
available.
                                     3-5

-------
                                                                                                                UJ

                                                                                                                i

                                                                                                                i
8
o
1^
+*


!
o
o


8
                                                                                                                2

                                                                                                                *
                                                                                                                to
                                                                                                                oe
                                                                                                                UJ
                                                                                                                u
                                                                                                                o
                                                                                                                o
                                                                                                                c*>

                                                                                                                I

                                                                                                                to
                                                                                               8
                                              (Xtp Ji9d
                                                            3-6

-------
                          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
petroleu» refineries.
4.1.2  Scope
     Estimates of capital and annual1zed costs are e/esented 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
size refinery with a throughput of 15,900 or/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 1s 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.  Table 4-1 presents the
technical parameters that pertain to the model refinery.  The parameters
wtre selected as being representative of existing medium sized refineries
based on Information from an American Petroleum Institute publication,
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.
Annual1zed control cost estimates Include annual1zed 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 annual1zed capital charges are sub-divided Into capital recovery
costs (depreciation and Interest costs) and costs for property taxes and
Insurance.  Depreciation and Interest costs uava 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/day
 II.  Operating Factor;b
      365 days 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.  Estimated Monitoring Manhours per year:d*e   1800
      E.  Estimated Maintenance and Repair
          Manhours per year:dff                        3800
 IV.  Seal Oil Reservoir Degassing Vent Control System:
      Piping:  61.0 m length, 5.1 cm d1a., carbon steel.
      Valves:  3 plug type, 5.1 cm dia., 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.
   Per 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 the degassing vtnt control system and an
Inttrtst rate of 10X per annum.  Costs for property taxts and Insurance
are computed at 4% of the capital costs.  All annual1zed costs are for
one year periods commencing 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 in table 4-2.
These parameters pertain to the medium size model refinery and are based on
                                                  7 5 fi 7 Q Q
actual cost/price data from petroleum refineries, *»»»»»'»«»» equipment ven-
dors,  '°»''»'5»'° a survey of current salary rates,    an oil Industry jour-
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 lonlzation detection principle and are certified safe
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 Equlpmnt Cost:              $8,800
      Annual Materials, Maintenance, and
       Calibration Cost:0                    $2,500
      Equipment Replacement L1fe:c           6 years
      Battery Pack Replacement Life:         1 year
 II.  Aimuallzed Capital Charges Factors;0
      Annual Interest Rate:                  10X
      Property Taxes and Insurance Charge:   4X of Capital Cost
HI.  Monitoring (Leak Detection) Labor Costs:
      Annual Monitoring Manhours:d           1800
      Weighted Average Labor Rate:6          $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
               c '
  V.  Annual Administrative and Support Cost of Monitoring and Maintenance
      Programs
      40* of the sum of III. and IV. costs.
 VI.  Seal Oil Reservoir Degassing Vent Control System:
      Carbon Steel Piping:h
         Installed Capital Cost:             $2400
         Annual Operating and Maintenance Cost:c
           5X of Installed Capital Cost
         Life:    10 years
                                     4-5

-------
                           Table 4-2  (continued)


       Plug Type Valves:

          Specification:                    UCB 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 Gauze Flame Arrester;1*

          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:
               15X of Installed Capital Cost

          Life:  10 years

 VII.   Recovered Product Value:*

       $100.60/m3
 ^References 2, 10 and 11; costs based on the use of two (2)  Century Systems
  Corp.  Model OVA-108 Portable Organic Vapor Analyzers.

  Based  on the following usages per monitoring Instrument per year:  one (1)
  battery pack, and two (2) filter packs.

 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), consisting of an Instrument Technician and  a Junior Chemical
  Engineer; Includes wages and salary plus an additional 40X  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.
L
 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

-------
   Table 4-3.  CONTROL COST ESTIMATES OF MONITORIN8 AND MAINTENANCE
               PR06RAM FOR MODEL EXISTING PETROLEUM REFINERY EQUIPMENT
               LEAKS
    Throughput                                          15,900 ra3/day


Control Technique                                      Monitoring and
  •                                  	Maintenance Program


Instrument Capital Cost ($000)*                             8.8

Annual1zed Instrument Capital Charges ($000)                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)f            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 OVA-108 Portable Organic Vapor Analyzers.
 Capital recovery costs (using capital recovery factor with 10X annual Interest
 rate and 6 year Instrument life) plus 4X of capital cost for property taxes
 and Insurance.
CEPA estimate.
 Estimated 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.
Estimated 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.
9Total AnnualIzed Costs are the sum of AnnualIzed Instrument Capital Charges; Annual
 Instrument Materials, Maintenance and Calibration Costs; Annual Monitoring Labor
 Costs; Annual Maintenance Labor Costs; and Annual Administrative and Support Costs.
^Credits for recovered (saved) product are not Included 1n these costs.
                                     4-8

-------
Englnttr are 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 annual1zed cost of $115,000, not Including
recovery credits from reduced emissions.  Recovery credits would, of course,
reduce the total annual1zed 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 VOC 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 1n Tables 4-1 and 4-2, respectively.
     From Table 4-4, 1t 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 VOC.
Recovered fuel credits would, of course, reduce the total annualIzed cost of
control.  Alternately, the VOC 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


Annual1zed 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, 15, and 16.
bCap1tal recovery costs (using capital recovery factor with 10X tnnual
 Interest rate and 10 year replacement .lite) plus 4* of capital cost
 for property taxes and Insurance.
References  15 and 16 and EPA estimates.
dTotal Annualized Costs are the sum of Annualized Capital Charges and
 Annual Operating and Maintenance Costs.
6Cred1ts for fuel value of recovered VOC are not Included In these costs,
                                    4-10

-------
4.3  COST-EFFECTIVENESS
     Since mission 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.
                     v
     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 1s 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) (1150/Ng) = $75,000/yr.
Step 2!
Total Annual1zed Cost * $115,000 - (Annual Product Recovery Credits) =
$115,000 - $75,000 « $40.000
Step 3;
tat mcttaM. - (^fciagVaato.1 • W* • "O/H,
*(S100.60

                                    4-11

-------
     Tht cost-effectiveness of each seal oil reservoir degassing vent control
system Mill vary with the particular situation, so quantitative C-E values
cannot be presented 1n this guideline.  But, whether or not such a control
systM 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.   Nemo 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, Okla.  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.
     Nemo 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 W. 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'
 *
                                                 4-14

-------
            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.   This estimate Is based on existing AP-42 emission
factors for leak sources o* 174 kilograms per thousand cubic meters of
                   2
refinery throughput  and 1977 Industry throughput of 2.69 million cubic
meters per day.   As discussed In Chapter 2.0, the AP-42 emission factors
are based on 20 year old data.  Emission factors for petroleum refinery
equipment leaks are presently being updated, and preliminary date show
                                                             4
the total leak emission rate 1s greater than AP-42 Indicates.   In order
to avoid confusion that occurs when new emission factors are published
based on old or limited date, 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 emission 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 Air Quality and Emission Trends Report 1975."
Environmental Protection Agency, OAQPS, MDAD-MRB, Research Triangle
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.
                                 5-2

-------
                         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 1t 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, aromatlcs, 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 In the manner described In Appendix B.  L«aks
                                  6-1

-------
detected by either the refinery operator or the air pollution control agency
             \         "  .       •       •
would be subject to these guidelines.  Recommended monitoring requirements for
the refinery operators are presented In 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 VOC, 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 in 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
                                i  ,    -                          '
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 in 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
remaining 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  Rtportlng Requirements
     After etch quarterly monitoring has been performed (and the annual),
the refinery operator should sutalt 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 Figure 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 in 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 it 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 in 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 if these methods are shown to be equivalent  to
those presented here.   An example  would be substituting walkthrough
                                    6-4

-------
monitoring (as described 1n 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 1n 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 1n 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 1s when a dual
sealing system 1s 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 1s degassed to atmosphere.  If such a system Is used, instead
                                 5.5

-------
of monitoring the VOC concentration of the double seal, the refinery
operator should monitor the seal oil reservoir degassing vent to
determine If 1t 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 limit.
                                 6.6

-------
                                                                                         r
                  O

                 ;£
                                                                                         I

UJ


i
(XI
 O
 »•*

jt
I to
                                                                                           .

                                                                                         1

                                                                                         dl
vo
O
•—«


O
UJ

O
                                  6-7

-------
  §
  3
    ;g
-i  ec
                                                                        s
                                                                        CM
                                                                        VO
                                                                        3
                           6-8

-------
                 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.I   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 superfract1onat1on
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-water separation caused elevated  hydrocarbon
 concentrations In the process drains.   In a few units there was a  large
 hydrocarbon cloud downwind from DUMPS  that had Mechanical seal  failures.
 This nade It Impossible to survey the DUMPS 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 0; the aromatlcs recovery unit and
                                  A-2

-------
                      «• »«M H T*te A-l
4 ? "*
      ', * *
      5.
                                                                    4

-------
              TABLE A -  1
SUMMARY OF RESULTS OF FOUR EPA TESTS

Emission Source
Puap Seals
Compressor Seals
Block Valves
Control Valves
Open-Ended Valves °
Drains
Pressure Relief Devices
Number of
Sources Tested
482
15
940
287
43*
367
15 a
Percent
Leaking
13
7
6
7
12
6
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
     Seals                                       327                           16

Compressor Seals                                  12                            0

Block Valves                                     601                            3

Control Valves                                   198                            8

Open-Ended Valvesb                               36                            °

Drains                                           279                            5

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   Including bleed valves  and sample connections
                                           A-7

-------
                TABLE A -  5        SUMMARY OF REFINERY  D  TESTING

Emission Source
PUMP Seals
Compressor Seals
Block Valves
Control Valves
Open-Ended Valves c
Drains
Pressure Relief Devices
Number of
Sources Tested
43
1
142
61
3b
24
_
Percent *
Leaking
16
0
13
3
67
15
_
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.I  INTRODUCTION
     This test method describes the procedures used to detect volatile organic
compound (VOC) leaks from petroleum refinery equipment.  A portable test
Instrument 1s 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.I.  The definitions and evaluation procedures for each parameter
are given in Section B.4.
                                   B-l

-------
        Table B.I.  Monitoring Instrument Performance Criteria
            Parameter                       Specification
1.  Zero drift (2-hour)             - 5 ppnv
2.  Calibration drift (2-hour)      - 5X of the calibration gas value
3.  Calibration error               - 5% of the calibration gas value
4.  Response time                   - 5 seconds
     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 in 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
                                     B-2

-------
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
         ."  .         .  .•      '       ('        '               -  -
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 relief devices - 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 centrold 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 centrold 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  centrold of the uncapped cpening 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 concentre-
                                          . •*
tlon at the time 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 Instrument 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 In Figure B.I).  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 test 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 staple 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:         ,
       x.j = 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 in 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

-------







t

>
B.



g

IO
%
O
VI
(9
O
1
IS
O










• •
0
•— 1
*e
1
•M
l/>
•5
















































g
I
Is
55
*
If
-1
3.
s
X
1
5
le
ii
o
*
_j

_
+* C
ll
°«
5°

^J
iz
rao



01
e|
as
ac



i
JZ
1

01
^2
O






1
1
*
X








**l

. '
O
H

8
tx
1
"i ^
I M ^H
'5
1C
«>2
H H- «
oC Sc
51 =5
•
e o>
O *J
•^» •»- 3
• • • • ^» ^J gM
p-  0 «—








§
'e
i
01
s
If.
I-
O
O
4*
«
^
u
•o
g
*

oa
JJ
3
Ol

*""














B-7

-------
Instilment ID
      Low
 Calibration  Gas Mixture Data
	 ppin            High
_ppm
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
                           Mean Difference
                    Calibration Gas Concentration
                                 x 100
 Calibration Gas Concentration -Instrument Reading
2JAbsolute Value
                                                             law
                                                     High
           Figure B.2.  Calibration Error Determination
                                 R-8

-------
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
                       v
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 in B.3.2 to determine If
a leak Is present.  For those cases where an Increased VOC concentration 1s
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.I   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,  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
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
during ongoing gas service component monitoring.  Manpower requirements
                                  C-1

-------
for maintenance of each sourct were approximated by a refining company
and the State of California A1r Resources Board.6  As shown 1n Table C-2,
the total annual direct labor requirement for repairing leaks 1s 3,800
manhours.
     It should be noted that this estimate 1s for the maximum 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 leaks
will be detected during subsequent Inspections.  This should result In
much lower maintenance manpower requirements for following years.
                                   C-2

-------
IA
 I
O
      hit
      •"• 5**" Q
       • g-gJE
       i
        ill
      .f
              IIs
                                       V
                 i—  CM
                    in
                 moo
                               P-  F- P- CO
C     c



44  3  +i
M  «l  M
c  i-  e
              +»  44  4>
4J  «4  4J 4J
VI  VI  VI M
C  C  C C

                 Ml
                 J
                            to ot
                            CM r-
                             0» •«-     M  01   en
                             > >  oi  e i-   c
                            p- I.  «J  t- f—   10

                       u    5 «S  ">  £ oe   C
      O          t-  Q
      M     01 -O  «     01 01 01
      VIM   C -P-  «/l  Irt  i- O C
      OTr-  -p- 3     M  3-p- f
                       VI > P-
                               3  3
                                                       VI

                                                       M
                                               M
                                               f  §
                                               I?
                                               s  5
                                               I  ji


                                               II
                                               *  2
                                                  2
                                      : 2
                                      e |
                                      * f
                                      & I
                                      vo «
                                    M en o
                                    j§ CM *»
                                 ! i
                                 *3 «*
                                 I  »
                                 2i
                      *»  o» 4*    e
                      «  « S    P-
                         M
                         1 > f*>
                        "r»     1
                        *» at vo
                         tfl O
                         « t-
           1 t

           ii
                                                             C  M
                                                             o  o>
•o    >  O  o>  or
K ~* I.  f  U  «
« rs, o>  4*  f  Z.
- o. *  i  js
•" ^ 8  *  *
« i a  c  t.
I
4J
•i
s
                                                          * I  V  Ifc -
                                                          c- >  *•  s** »•
                                                          •»- V  r->  »•»• «
                                                             fe  a»
                           a  e  s
                     •p X» VI  *J  •«
                      « <9 M  1-  5  _
                      M in 01  e     U
                     a a £  l  s  a
                   I
                                                          o -o  a> <*-
                                    C-3

-------
         TABLE C-2.  ANNUAL MAINTENANCE MANPOWER REQUIREMENTS  FOR MODEL
                     15,900 CUBIC METER PER DAY REFINERY

Source

PIMP Seals
Compressor
Seals
Pipeline
Valves
Process
Drains
Pressure
Relief
Valves
Pipeline
Flanges
Number of9
Sources

250
14

25,500

1,400

130


64,000

Estimated Number b
of Leaks Detected
Per Year

30
2

1640

84

34


.

Average Repair a
Time
(hours)

80
40

0.6e

4

Of


_
T(l
>d Total Annual
Manpower
Requirement
(hours)
2400
80

984

336

0


.
iTAI Win
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 rechecklng 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 manhours, and the remaining 90 percent tightened
     or greased on-Hne at a cost of 0.17 manhours (Reference 6)

f    These leaks repaired by routine maintenance at no Incremental Increase 1n
     manpower requirements (Reference 1)
                                      C-4

-------
C.2   REFERENCES
     1.  Letter with attachments from J.M. 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 Nil11am Stewart, Texas Air Control Board, September 8, 1977.
     4.  Johnson, J.M. Op C1t.
     5.  Ibid.
     6.  "Emissions From Leaking Valves, Flanges, Pump and Compressor
Seals, and Other Equipment at Oil 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

-------
                                                                          SJS
                                                                           ?§*

                                                                           ll
ano-


spls
Wl >J Q. W
01    ""
                                                                                    mc
                                                                                    3 3
                                                                                   ff

                                                                                  ™ ~ (fl


-------