v>EPA
United States      Enforcement and
Environmental Protection  Compliance Assurance
Agency	(2224A)	
                                 EPA/305/B-98/011
                                 December 1998
Inspection Manual:
Federal Equipment Leak
Regulations for the
Chemical Manufacturing
Industry
Volume I: Inspection
Manual
                   EPA Office of Compliance
                   Chemical, Commercial
                   Services, and Municipal
                   Division

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ABSTRACT
The purpose of this manual is to enhance an inspector's ability to conduct more
complete and effective inspections at facilities in the chemical industry that are subject
to Federal equipment leak regulations. Equipment leak standards are designed to reduce
or eliminate emissions of volatile organic compounds (VOCs), volatile hazardous air
pollutants (VHAPs), and organic HAPs from the miles of piping and numerous
components found in chemical manufacturing processes.

This document is divided into three volumes. The  first volume is a manual for
inspectors;  the second and third volumes describe  regulations that apply to the chemical
manufacturing and the petroleum refining industries, respectively.

Volume I has five chapters dedicated to helping an inspector:
   •   Chapter 1 states the goals, background, approaches to rule enforcement, and
       organization of the document.
   •   Chapter 2 addresses applicability determinations: ensuring the correct rules are
       being complied with at a  facility, determining whether all appropriate
       components have been identified, and ensuring the components are properly
       classified by service.
   »   Chapter 3 discusses reporting and recordkeeping requirements for NSPS,
       NESHAP, HON, and RCRA (recordkeeping only), and strategies for reviewing
       reports  and records.
   •   Chapter 4 covers on-site inspections: walk-throughs and inspections with the
       inspector monitoring for leaks. It addresses pre-inspection activities, timing and
       scope, interviews, leak monitoring evaluations, inspections of the process area
       and records, and post-inspection reviews and reports.
   •   Chapter 5 discusses recommended inspection techniques and procedures.

Volume n tackles the equipment leak regulations applicable to the chemical
manufacturing  industry.
   •      The first three appendices of Volume II summarize the regulations of 40
          CFR Part 60 Subpart  W, Part 61 Subparts J and V, Part 63 Subparts H and
          I, Part 264 Subpart BB, and Part 265 Subpart BB; detail the differences
          among the regulations; and give  the requirements grouped by component.
   •      Appendix D describes the regulated equipment.
   •      Appendix E contains the "Method 21" approach to leak detection.
   *      Appendix F lists chemical manufacturing processes that are subject to HON.
   •      Appendix G lists organic HAPs that are subject to HON.
   *      Appendix H lists manufacturing processes and associated organic HAP
          emissions that are subject to HON.

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Volume in contains the equipment leak regulations applicable to the petroleum refining
industry.
   •  The three appendices of Volume HI summarize the regulations of 40 CFR Part
      60 Subparts DDD, GGG, KKK, and QQQ, and Part 63 Subpart CC; detail the
      differences among the regulations; and give the requirements grouped by
      component.

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CONTENTS
VOLUME I: INSPECTION MANUAL
                                                                   Page
Chapter 1   Statement of Goals, Background, Approaches
            to Rule Enforcement, and Organization of
            Document	  1- 1
      1.1   Scope of Manual and Statement of Purpose	  1-1
      1.2   Background 	  1-2
      1.3   Approaches to Rule Enforcement	1-12
      1.4   Organization of Document	1-13

Chapter 2   Applicability	  2-1
      2.1   Which Regulation?	  2-1
      2.2   Which Components?	  2-6
      2.3   Which Service?	  2-7

Chapter 3   Compliance/Inspection Through Reports and
            Recordkeeping	  3- 1
      3.1   Reports	  3- 1
      3.2   Recordkeeping	  3- 9
      3.3   Strategies for Reviewing Reports and Procedures  .	 3-16

Chapter 4   Compliance/Assessment Through On-Site
            Inspections	  4- 1
     '4.1   Walk-Through Inspections	  4- 1
      4.2   Direct Monitoring of Components	4-14

Chapter 5   Recommended Inspection Techniques and
            Procedures	  5-1

      5.1   Inspection Program Development	  5-1
      5.2   Working with Regulated Facilities	  5-3

Bibliography	  6-1

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CONTENTS (continued)
VOLUME II: CHEMICAL MANUFACTURING INDUSTRY REGULATIONS

Appendix A Equipment Leak Regulations: Side-by-Side Comparisons
Appendix B Equipment Leak Regulations: Summary of Differences
Appendix C Equipment Leak Regulations: Summary by Component
Appendix D Regulated Equipment
Appendix E Method 21 (40 CFR 60, Appendix A)
Appendix F Chemical Manufacturing Processes Subject to HON Standards (40
           CFR 63, Subpart H)
Appendix G Organic HAPs Subject to HON Standards (Subpart H)
Appendix H Manufacturing Processes and Organic HAPs Subject to HON
           Standards (Subpart I)
VOLUME HI: PETROLEUM REFINING INDUSTRY REGULATIONS

Appendix A Equipment Leak Regulations: Side-by-Side Comparisons
Appendix B Equipment Leak Regulations: Summary of Differences
Appendix C Equipment Leak Regulations: Summary by Component

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                                CHAPTER 1

    STATEMENT OF GOALS, BACKGROUND, APPROACHES TO RULE
          ENFORCEMENT, AND ORGANIZATION OF DOCUMENT
1.1   SCOPE OF MANUAL AND STATEMENT OF PURPOSE

      The purpose of this manual is to provide guidance to enhance an inspector's
ability to conduct more complete and effective inspections at facilities in the chemical
industry subject to Federal equipment leak regulations. Inspections are typically
conducted not only to determine whether a facility is in compliance with a regulation,
but also to evaluate the effectiveness of a facility's implementation of a program.

      Equipment leak inspections involve two separate, but equally important
activities:  evaluation of equipment leak program records and reports and on-site
inspections. To effectively conduct these activities, an inspector must be able to:

       •      Determine which Federal equipment leak regulations are applicable to a
             chemical industry facility.

       •      Understand the overall approach of using both equipment standards and
             leak detection and repair standards to achieve reductions in emissions
             from equipment leaks.

       •      Determine if a source is complying with all the requirements of
             component identification, component marking, equipment design,
             monitoring, repair, recordkeeping, and reporting.

       •      Understand the use of alternate standards.

       •      Understand the volatile organic compounds (VOC) analyzer performance
             specifications required by U.S. EPA Method 21.

       •      Understand the basic operating principles of flame ionization analyzers,
             photoionization analyzers, and catalytic combustion analyzers.
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       •     Evaluate source personnel's calibration procedures and records.

       »     Evaluate field monitoring procedures used by source personnel to detect
             leaks from regulated components.

       This manual addresses seven Federal equipment leak regulations that affect the
chemical industry.  These regulations, found in the Code of Federal Regulations (CFR),
are:

       •     40 CFR Part 60, Subpart W - SOCMI Equipment Leaks New Source
             Performance Standard (NSPS)
       •     40 CFR Part 61, Subpart J— Benzene Equipment Leaks National
             Emission Standard for Hazardous Air Pollutants (NESHAP)
       •     40 CFR Part 61, Subpart V - NESHAP Equipment Leaks
       •     40 CFR Part 63, Subpart H — Organic Hazardous Air Pollutants (RAP)
             Equipment Leak NESHAP
       •     40 CFR Part 63, Subpart I - Organic HAP Equipment Leak NESHAP
             for Certain Processes
       •     40 CFR Part 264, Subpart BB — Air Emission Standards for Equipment
             Leaks for TSDFs
       •     40 CFR Part 265, Subpart BB — Air Emission Standards for Equipment
             Leaks for Interim Program TSDFs

       Due to the similarity among many of the equipment leak regulations, the
guidance in this manual may be of assistance to inspectors responsible for conducting
inspections at facilities complying with State or local equipment regulations and at other
types of facilities (e.g., petroleum refineries) subject to other Federal equipment leak
regulations.  The focus of this manual, however, is the seven Federal regulations
identified above, which affect facilities in the chemical industry. These regulations are
presented in Volume n, Appendices A, B, and C. Regulations that affect the petroleum
refinery industry are presented in Volume HI.
1.2    BACKGROUND

1.2.1  Introduction; What are equipment leaks and why are they of concern?

       Chemical manufacturing processes include miles of piping and numerous
components which convey petrochemical feedstocks, water, steam, and intermediate
and final products. Emissions from equipment leaks occur in the form of gases or
liquids that escape to the atmosphere through many types of connection points (e.g.,
flanges, threaded fittings, etc.) or through the moving parts of valves, pumps,
compressors, pressure relief devices, and certain types of process equipment.

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       Equipment leaks are primarily defined within the above regulations on the basis
of a detection instrument which reads the airborne concentration of volatile organic
carbons at a potential leak point on a parts per million (ppm) basis. If the leak exceeds
the  threshold definition of the applicable regulation, repair of the leaking equipment is
required. How the instrument is used (leak monitoring procedure) and performance
criteria for the instrument are defined in Method 21 of 40 CFR Part 60, Appendix A
(see Volume n, Appendix E). Equipment leaks also may be defined on the basis of
visual observation of certain types of equipment.  Each regulation includes leak
definitions for specific types of equipment (see Volume n, Appendix C).

       Equipment leak standards are designed to reduce or eliminate emissions of
VOCs, volatile hazardous air pollutants (VHAPs), and organic HAPs.  VOCs, along
with nitrogen oxides (NO*) and ultraviolet radiation, contribute to ozone production.
Ozone is one of the criteria pollutants for which a national ambient air quality standard
(NAAQS) is designated under Section 109 of the Clean Air Act, and nonattainment of
the  ozone NAAQS is a serious problem in the United States. VHAPs and organic
HAPs (collectively referred to as HAPs in this document) are controlled because such
air pollutants can pose a health risk for humans, in the form of direct worker exposure
or as a contribution to air pollution affecting a broader population.

       Equipment leak emissions of VOCs and HAPs from the source categories •
discussed above constitute a significant source of air pollutants.  For example,
equipment leak emissions are estimated to be responsible for over 50 percent of the
total VOC emissions from refineries or about 10,000 tons per year in California based
on the 1990 emissions inventory of the California Air Resources Board.  Significant
emissions from equipment leaks are also reported by the chemical manufacturing
industries to the Toxic Chemical Release Inventory, as required by Section 313 of the
Emergency Planning and Community Right-to-Know Act.  For example, all
manufacturers of chemicals and allied products (Standard Industrial Classification (SIC)
Code 2800) reported in 1993 that fugitive emissions accounted for approximately
250,000 tons of air emissions. Fugitive emissions from equipment leaks are a
significant subset of total fugitive emissions.

       Federal equipment leak standards implemented during the 1980's were estimated
to reduce VOC and HAP emissions between 55 and 68 percent from facilities affected
by the standards.  For example, the EPA estimated the VOC emissions from facilities
affected by the synthetic organic chemical manufacturing industry (SOCMI) standards
would be reduced from approximately 91,500 tons per year (tpy) to 40,700 tpy--a 56
percent reduction. The emission reduction estimate for benzene sources at chemical
manufacturing facilities is 68 percent. The Hazardous Organic NESHAP (HON)
standards, as well as some State and local standards, are intended to achieve even
greater reductions of VOC and HAP fugitive emissions.
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1.2.2  Components

       A general set of equipment is covered by all of the equipment leak standards
affecting chemical facilities.  This includes pumps, compressors, pressure relief
devices, open-ended valves or lines, valves, sampling connections, flanges and other
connectors.  In addition, all of the standards  include any devices or systems (i.e.,
alarms, or dual mechanical seals) required to satisfy performance or equipment
standards. The equipment leak standards also identify requirements for closed-vent
systems and control devices that may be used to comply with the regulations.

       Additional equipment is covered only by specific standards.  For example,
product accumulator vessels are addressed only by the HON and benzene NESHAP,
and agitators are addressed only by the HON. The HON also addresses instrumentation
systems.

       Leak Detection and Repair (LDAR) programs  (see Section 1.2.3.1) affect valves
and pumps and other components. Appendix C in Volume n provides a component-by-
component summary of the equipment leak regulations.  Specific regulated components
are discussed in greater detail in Volume n, Appendix D.

       1.2.2.1   Pomps

       Pumps are used extensively in chemical manufacturing facilities for moving
fluids. The most widely used pump is the centrifugal pump.  Other types of pumps that
also may be used are the positive-displacement, reciprocating and rotary action, and
special canned-motor and diaphragm pumps.

       Chemicals transferred by pumps can leak at the point of contact between the
moving shaft and stationary  casing. To isolate the pump's interior from the
atmosphere,  all pumps, except the seal-less type (canned-motor and diaphragm), require
a seal at the point where the shaft penetrates the housing.  The most commonly used
seals in these pumps are packed and mechanical.  However, no seal system is perfect,
and many pumps are equipped with a closed-vent system.

       1.2.2.2   Compressors

       Centrifugal, reciprocating, and rotary compressors are used in chemical
manufacturing facilities. The centrifugal compressor uses a rotating element or series
of elements containing curved blades to increase the pressure of a gas by centrifugal
force.  Reciprocating and rotary compressors increase pressure by confining the gas in
a cavity and progressively decreasing the volume of the  cavity.  Reciprocating
compressors usually use a piston and cylinder arrangement, while rotary compressors
use rotating elements such as lobed impellers or sliding vanes.

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       As with pumps, seals are required to prevent leakage from compressors. Rotary
shaft seals for compressors may be labyrinth, restrictive carbon rings, mechanical
contact, or liquid film. All of these seals are leak restriction devices, but none of them
completely eliminate leakage. To respond to leakage, many compressors are equipped
with ports in the seal area that evacuate collected gases to a control device.

       1.2.2.3    Pressure Relief Devices

       Engineering codes require the use of pressure-relieving devices or systems in
applications where the process pressure may exceed the maximum allowable working
pressure of the  vessel. The pressure relief valve is the most common type of pressure-
relieving device used. Typically, relief valves are spring-loaded and designed to open
when the system pressure exceeds a set pressure, allowing the release of vapors or
liquids until the system pressure is reduced to its normal operating level.  When the
normal pressure is re-attained, the valve reseats and a seal is again formed.  The seal is
a disc on a seat, and a leak through this seal is a potential source of fugitive VOC and
HAP emissions. The potential causes of leakage from relief valves are "simmering or
popping" (a condition that occurs when the system pressure comes close to the set
pressure of the  valve); improper reseating of the valve after a relieving operation; and
corrosion or degradation of the valve seat.

       Rupture discs also may be used to relieve pressure in process units.  These discs
are made of a material that ruptures when a set pressure is exceeded, thus allowing the
system to depressurize.  The advantage of a ruptured disc is that the disc seals tightly
and does not allow any emissions to escape from the system during normal operations.
When the disc ruptures, however, the system will depressurize until atmospheric
conditions are obtained, unless the disc is used with a pressure relief valve.

       1.2.2.4    Sampling Connections

       Process  unit operations are checked periodically by routine analysis of
feedstocks and products.  To obtain representative samples for these analyses, sampling
lines first must  be purged. If the flushing liquid is not controlled, it could be drained
onto the ground or into a process drain where it would evaporate and release emissions
to the atmosphere.  Closed-loop sampling systems control the purged process fluid by
returning it directly to the process line, collecting and recycling the fluid, or
transporting the fluid to a control device.

       1.2.2.5    Open-ended Lines or Open Valves

       Some valves are installed in a system so that they function with the downstream
line open to the atmosphere.  Open-ended lines, which are used mainly in intermittent
service for sampling and venting, include purge, drain, and sampling lines.  Some

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open-ended lines are needed to preserve product purity.  Normally, these are installed
between multi-use product lines to prevent products from collecting in cross-tie lines
during valve seat leakage. A faulty valve seat or incompletely closed valve would
result in leakage through the valve, releasing emissions to the atmosphere.

       1.2.2.6   Process Valves

       One of the most common pieces of equipment affected by these standards is the
process valve.  Commonly used types are control, globe, gate, plug, ball, relief,  and
check valves.  All except the relief valve (see Section 1.2.2.3) and check valve are
activated through a valve stem, which may have either a rotational or linear motion,
depending on the design.  The valve stem requires a seal to isolate the process fluid
inside the valve from the atmosphere. The possibility of a leak through this  seal  makes
it a potential source of fugitive emissions. Since a check valve has no stem or
subsequent packing gland, it is not considered a potential source of fugitive emissions
and is not subject to the standards.

       The stem can be sealed to prevent leakage by using a packing gland or O-ring
seals.  Valves  that require the stem to move in and out with or without rotation must
use a packing  gland. Conventional packing glands are suited for a wide variety of
packing material. The most common are various types of braided asbestos that contain
lubricants. Other packing materials include graphite, graphite-impregnated fibers, and
tetrafluorethylene polymer.  The packing material used depends on the valve application
and configuration.  These conventional packing glands can be used over a range of
operating temperatures, but at high pressures, these glands must be quite tight to obtain
a good seal.

       Elastomeric O-rings also are used for sealing process valves.  These O-rings
provide good sealing, but are not suitable if sliding motion occurs through the packing
gland.  These  seals are used rarely in high pressure service, and operating temperatures
are limited by  the seal material.

       Bellows seals are more effective for preventing process fluid leaks than the
conventional packing gland or any other gland-seal arrangement. This type of seal
incorporates a formed metal bellows that makes a barrier between the disc and body
bonnet joint.  The bellows is the weak point of this type of system, and service life can
be quite variable. Consequently, this type of seal normally is backed up with a
conventional packing gland and often is fitted with a leak detector in case of failure.

       A diaphragm may  be used to isolate the working parts of the valve and the
environment from the process liquid.  The diaphragm also may be used to control the
flow of the process fluid.  In this design, a compressor component pushes the
diaphragm toward the valve bottom, throttling the flow.  The diaphragm and

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compressor are connected in a manner so that separating them is impossible under
normal working conditions. When the diaphragm reaches the valve bottom, it seats
firmly against the bottom, forming a leak-proof seal.  This configuration is
recommended for fluids containing solid particles and for medium-pressure service.
Depending on the diaphragm material, Ms type of valve can be used at temperatures up
to 205°C and in severe acid solutions.  If the seal fails, however, a valve using a
diaphragm seal can become a source of fugitive emissions.

       1.2.2.7   Flanges and Other Connectors

       Flanges are bolted, gasket-sealed junctions used wherever pipes or other
equipment such as vessels, pumps, valves, and heat exchangers may require isolation or
removal.  Connectors are all other nonwelded fittings that serve a similar purpose to
flanges, which also allow bends in pipes (elbows), joining two pipes (couplings), or
joining three or four pipes (tees or crosses).  Connectors typically are threaded.

       Flanges may become fugitive emissions sources when leakage occurs because of
improperly chosen gaskets or poorly assembled flanges. The primary cause of flange
leakage is thermal stress, which causes deformation of the seal between the flange
faces.  Threaded connectors may leak if the threads become damaged or corroded or if
tightened without sufficient lubrication or torque.

       1.2.2.S   Product Accumulator Vessels. Bottoms Receivers.,  and Separator
              Vessels

       Product accumulator vessels include overhead and bottoms receiver vessels used
with fractionation columns and product separator vessels used in series  with reactor
vessels to separate reaction products. Accumulator vessels can be vented directly to the
atmosphere or indirectly through a blowdown drum or vacuum system.  When an
accumulator vessel contains benzene and other HAPs and vents to the atmosphere,
emissions will occur.

       1.2.2.9   Agitators

       Agitators are used to stir or blend chemicals. Like pumps and compressors,
agitators may leak organic chemicals at the point where the shaft penetrates the casing.
Consequently, seals are required to minimize fugitive emissions. Four  seal
arrangements commonly are used with agitators:  compression packing  (packed seal),
mechanical seals, hydraulic seals, and lip seals. Packed seals for agitators are very
similar in design and application to packed seals for pumps.

       Although mechanical seals are more costly than the other three types of seals,
they offer a greatly reduced leakage rate to offset their higher cost.  Furthermore, the

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maintenance frequency of mechanical seals is one-half to one-fourth that of packed
seals.  At pressures greater than 1,140 kPa (150 psig), the leakage rate and maintenance
frequency are so superior that the use of packed seals on agitators is rare.  As with
packed seals, the mechanical seals for agitators are similar in design and application to
the mechanical seals for pumps.

       1.2.2.10  Instrumentation Systems

       Instrumentation systems consist of smaller pipes and tubing that carry samples
of process fluids to be analyzed to determine process operating conditions or to systems
for measurement of process conditions.

       1.2.2.11  Cloged-Vent Systems and Control Devices

       A closed-vent system can be used to collect and dispose of gaseous emissions
from seal oil degassing vents, pump and compressor seal leakage, relief valve leakage,
and relief valve discharges because of over-pressure operation.  A closed-vent system
consists of piping connectors, flame arresters, and, if necessary, flow-inducing devices.
Closed-vent systems are designed and operated so that all emissions are transported to a
control device without leakage to the atmosphere.

       Several types of control devices can be used to dispose of VOC and HAP
emissions captured in the closed-vent system.  Incineration, carbon adsorption, and
condensation are three control methods that typically are applied.

1.2.3  Leak Minimization Standards

       Equipment leak standards are designed to control  emission leaks from regulated
equipment through the application of work practices, equipment standards, and
operational practices.  The work practice most commonly applied to control equipment
leaks is the LDAR program. Equipment practices  include the use of specific types of
components, equipment design standards or specifications, and operational standards
for certain types of equipment.  Equipment practices are evaluated using performance
standards that provide a basis for monitoring or substantiating the effectiveness of such
control practices.

       1.2.3.1    Leak Detection and Repair

       LDAR programs consist of two phases: (1) monitoring potential fugitive
emission sources within a process unit to detect leaks, and (2) repair or replacement of
the leaking component.
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       The level of emission reduction achieved by a LDAR program is affected by
several factors. The three main factors are monitoring interval, leak definition, and
repair interval:

       »      Monitoring interval—The monitoring interval is the frequency at which
              individual component monitoring is conducted.  For example, valves are
              generally required to be monitored once a month using a leak detection
              instrument, but the monitoring interval may be extended to once every
              quarter for each valve that has not leaked for two successive months.
              The LDAR programs also specify weekly  visual inspections of pumps
              and compressors for indications of liquids dripping from the seals.

       •      Leak definition—The leak definition is the  VOC (or HAP) concentration
              observed during monitoring with a leak detection instrument that exceeds
              the threshold standard for the  applicable regulation.  Leaks may also be
              defined on the basis of visual inspections.  In other cases, monitoring is
              required if certain indications  of leaks are  observed.

       *      Repair interval—The repair interval is defined as the length of time
              allowed between detection of a leak and repair of the leak. When a leak
              is detected, the affected component is required to be repaired as soon as
              practicable, but not later than  15 calendar  days after the leak is detected,
              unless the conditions described under "Delay of Repair" (later in this
              section) are met.

       For each component, the first attempt at repair is  to be made no later than five
calendar days after each leak is detected.  First attempts at repair include, but are not
limited to, the following best practices, where practicable and appropriate:

              *  Tightening of bonnet bolts

              *  Replacement of bonnet bolts

              *  Tightening of packing gland nuts

              •  Injection of lubricant into lubricated packing

       Other factors that can improve  the efficiency of an LDAR program that are not
addressed by the standards include training programs  for equipment monitoring
personnel and tracking systems that address the cost efficiency of alternative equipment
(e.g., competing brands of valves hi a specific application).
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       1.2.3.2    Equipment. Design. Operational, and Performance Standards

       Equipment standards refer to the use of specific types of components.  Design
standards include requirements for dual mechanical seals, closed purge and vent
systems, caps, blind flanges, second valves, and control equipment specifications
associated with flares and enclosed combustion devices.

       Certain equipment operations, e.g., the proper sequence for closing double
blocks and bleed valves or the requirement to maintain a pilot flame in flares, are
regulated through implementing operational standards.

       Performance standards refer to no detectable emissions and percent reduction
efficiency for control devices. Annual monitoring is used for components subject to the
"no detectable emissions" requirement, which requires emissions of less  than 500 ppmv
above background levels. No detectable emissions components include pumps,
compressors, valves (specifically designated for no detectable emissions), pressure
relief devices in gas/vapor service, and closed-vent systems for both NSPSs and
NESHAPs.

1.2.4  Eederal Equipment Leak Regulations

       Federal equipment leak regulations affecting chemical manufacturing facilities
consist of standards promulgated under the NSPS, NESHAP, and the Resource
Conservation and Recovery Act (RCRA). NSPSs are implemented under Section 111
of the Clean Air Act and apply to newly constructed stationary sources—those sources
constructed after the date that an NSPS is proposed in the Federal Register. NSPSs
become effective upon promulgation.  In addition, existing stationary sources (sources
existing prior to the NSPS proposal date) can become subject to an NSPS if they are
modified or reconstructed after the NSPS proposal date.  A degree of national
uniformity to air pollution standards is established through NSPSs.  Such uniformity
tends to preclude situations in which certain States could attract new industries as a
result of relaxed standards, relative to other States.

       NESHAPs, which are implemented under Section 112 of the Clean Air Act,
apply to both new and existing stationary sources. NESHAPs are intended to control
hazardous pollutants such as carcinogens or other serious disease-causing agents.
Formerly, they were developed and implemented for individual pollutants, but this
proved to be an extremely cumbersome and slow-moving process. By 1990, NESHAPs
had been established for only eight pollutants.  Of these, equipment leak regulations
were applied only to benzene and vinyl chloride.  The Clean Air Act Amendments of
1990 (CAAA) have changed the approach for controlling hazardous  air pollutants. In
the CAAA, 189 chemicals are identified as air toxics that will be controlled on a source
category basis. A subset of the listed chemicals will be regulated under the HON.

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      As a class, organic air emissions at hazardous waste treatment, storage, and
disposal facilities (TSDFs) are regulated under Subtitle C of RCRA.  Final standards
are established in the rale to limit leaks from equipment (e.g., pumps and valves) that
contains or contacts hazardous waste streams with 10 percent or more total organics.
The final standards incorporate, or closely follow, many of the provisions of the
equipment leak NSPS and the benzene NESHAP.  These standards are promulgated
under authority of Section 3004 of the Hazardous and Solid Waste Amendments to
RCRA and are incorporated into Parts 264 and 265 (Subpart BB), Air Emission
Standards for Owners and Operators of Hazardous Waste Treatment, Storage, and
Disposal Facilities (U.S. EPA, 1990b).

      1.2.4.1   Federally Regulated Source Categories - NSPS

      The NSPS equipment leak standards for the SOCMI are in Subpart W of 40
CFR Part 60, and sections (§) of this standard are found in §60.480 through §60.489.
The proposal and applicability date for Subpart W is January 5, 1981. The rale was
promulgated on October 18, 1983.

      1.2.4.2   Sources Subject to NESHAP Regulations

      NESHAPs have been established for equipment leaks of two designated VHAPs-
-benzene and vinyl chloride. Only the benzene NESHAP is applicable to chemical
manufacturing facilities.

      The NESHAPs are found in 40 CFR Part 61.  Part 61 contains the national
emission standards for hazardous air pollutants, including the folio whig subparts:

      «     Subpart J specifies the national emission standard for equipment leaks of
             benzene and basically incorporates Subpart V as its standards.  Subpart J
             is found in §61.110 through §61.112.  Subpart J was promulgated on
             June 6, 1984.

      •     Subpart V contains the national emission standard for VHAP equipment
             leaks. This subpart contains generic provisions and standards that are
             incorporated by reference in 40 CFR 61, Subpart J. Subpart V is  found
             in §61.240 through §61.247.  Subpart V was promulgated on June 6,
             1984.
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       1.2.4.3    Hazardous Organic National Emission Standard (HON)

       The HON for equipment leaks at organic chemical plants is found at 40 CFR
Part 63, Subpart H, in §63.160 through §63.182. These standards apply to equipment
in organic hazardous  air pollutant service for 300 or more hours per year. The
chemical manufacturing processes and organic HAPs subject to the rule are published
in Tables 1 and 2 of Subpart F to 40 CFR Part 63 (see Volume H, Appendices F
andG).

       Subpart H standards also apply to some additional processes that produce certain
butadienes, chlorine,  or styrene-based products.  These processes are addressed in
Subpart I of 40 CFR  63 (see Volume H, Appendix H) at §63.190 through §63.193.
The HON was promulgated on April 22,  1994.

       A number of the manufacturing  processes listed under the HON also contain
equipment subject to  NSPS or NESHAP equipment leak standards.  Wherever such
overlapping rules apply, the HON takes precedence.

       1.2.4.4    Hazardous Waste Facility Emission Standards

       Organic air emissions at hazardous waste TSDFs are found at Parts 264 and 265
(Subpart BB), Air Emission Standards for Owners and Operators of Hazardous Waste
Treatment, Storage, and Disposal Facilities and Air Emissions Standards for Owners
and Operators of Interim Status Hazardous Waste Treatment, Storage and Disposal
Facilities, respectively. The regulations may be found at §264.1050 through §264.1065
and §265.1050 through §265.1064.  The rules were both promulgated on June 21,
1990.
1.3    APPROACHES TO RULE ENFORCEMENT

       Reports, recordkeeping requirements, and inspections form the basis of
assessing compliance with the Federal equipment leak standards.  Inspections require
the evaluation of records and reports as well as the performance of on-site inspections,
including leak detection. Both activities are necessary to me accomplishment of
effective regulatory oversight.

1.3.1  Review of Reports and Recordkeeping

       The review of records and reports can encompass two separate functions:  (1)
determination that the records and reports are in compliance with the applicable
standards, and (2) use of records and reports in the performance of on-site inspections.
One of the goals of this manual is to assist inspectors in evaluating the often

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complicated and voluminous records that are an essential part of the equipment leak
programs.  The records and reports required by the Federal equipment leak standards
are essential elements for the demonstration of compliance by the regulated facility.  It
should be noted that these regulations are complicated and are not uniform from one
category to another.  It is imperative therefore, that the inspector be thoroughly
knowledgeable of the source specific regulations before conducting an inspection.  This
will aid the inspector in recognizing what types of information are important for the
compliance determination as well as providing a means of preparation for site visits and
inspections.

1.3.2  On-Site Inspections

       On-site inspections can encompass the direct monitoring  of regulated equipment
and measurement of equipment leaks as well as observational techniques addressing
plant procedures, equipment usage, and evaluation of monitoring and testing performed
by the plant.  One goal of this manual is to provide guidance in  the development and
implementation of direct monitoring inspections.  Another goal is to enable the
inspector, through observational techniques, to determine if plant personnel are in full
compliance with EPA Method 21 field monitoring techniques and if they are adequately
identifying regulated and/or leaking equipment.  Inspectors must, therefore, be
thoroughly familiar with VOC detector operating principles, calibration procedures,
operating problems, and leak screening techniques in order to perform both types of
inspections.
1.4    ORGANIZATION OF DOCUMENT

       Chapter 2 - Applicability

       The focus of this chapter is to address applicability determinations needed to
ensure the correct rule(s) is (are) being complied with, all appropriate components are
included in the program, and all such components are correctly identified as to which
service they are in.

       Chapter 3 - Compliance/Inspection Through Reports and Recordkeeping

       This chapter addresses the review of reports and recordkeeping for compliance
with the Federal equipment leak regulations.
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       Chapter 4 - Compliance/Inspection Through Walk-Through Monitoring

       This chapter addresses the compliance and inspection issues that can be
addressed by conducting an actual walk-through of the facility including on-site review
of records and the use of a monitor during the walk-through.

       Chapter 5 - Recommended Inspection Techniques and Procedures

       This chapter provides a summary of the pros and cons of both enforcement
strategies.  Actual programs should seek a balance between the two. The best
procedure will vary based on resources available to the inspector and the air quality
priorities of the regions.
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                                 CHAPTER 2

                               APPLICABILITY
       This chapter addresses three critical applicability determinations. The first
determination is to ensure the correct rales are being complied with at any given
facility. Second, once the correct rale is determined for each process area within a
facility, determine whether all appropriate components have been identified. The third
critical determination is to ensure that these components are properly classified as to
what type of service they are in.

       These three determinations are discussed in the following sections of this
chapter.  For each determination, a discussion of each regulation is presented,  followed
by a discussion of procedures that can be used in making these critical determinations.
2.1    WHICH REGULATION?

2.1.1  Specific Regulations

       At many chemical manufacturing facilities, more than one Federal equipment
leak rule may be applicable to different pieces of equipment or process areas within the
facility. However, each rule has a precedence ranking relative to the other rales such
that only one rule should be applicable to any specific piece of equipment or process
area.

       The HON standard  (40 CFR 63, Subpart H and I) is the best place to begin for
the determination of rule precedence.  The rale takes precedence over any equipment
also subject to NSPS or NESHAP standards, including some equipment previously
subject to benzene regulations. If a process is not subject to 40 CFR 63, it should be
reviewed for benzene applicability  (40 CFR 61, Subparts J and V).  The NESHAPs
take precedence over any applicable NSPS [§61.110(d) or §61.240(c)].

       Several terms important to determination of rale applicability can be confusing
because they have different meanings under some of the rales  (e.g., affected facility) or
can be used in different contexts (in service).  Those terms important to the following
discussions are reviewed here to help clarify how the standards are applied.

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       Affected Facility.  An affected facility is an emission source or group of
emission sources to which a standard applies. Part 60, Subpart W defines affected
facility as the "group of all equipment within a process unit."  All of the other rules
addressed by this manual  define each individual piece of equipment (e.g., pump,
compressor) as the affected facility.

       Process Unit. All of the standards (except RCRA Subpart BB) contain the
following generic definition:  "a process unit can operate independently if supplied with
sufficient storage facilities for the product."  Each standard also contains specific
qualifiers (see Table 2.1). The RCRA definition of a hazardous waste management unit
refers to the area hi which a nazardous waste is  stored or in which constituent wastes
are mixed.

                       Table 2.1. Process Unit Definitions-Specific Qualifiers
 Standard	Specific Process Unit Definition	
 40 CFR Part 60                 Components assembled to produce, as intermediate or final products, one or
                             more of the chemicals listed in §60.489 of Subpart W.
 40 CFR Part 61                 Equipment assembled to produce VHAP or its derivatives as intermediates or
                             final products, or equipment assembled to use a VHAP in the production of a
                             product.
 40 CFR Part 63                 Equipment assembled and connected by pipes or ducts to process raw materials
                             and to manufacture an intended product.
 40 CFR Part 265                A contiguous area of land on or in which hazardous waste is placed, or the
                             largest area in which there is significant likelihood of mixing hazardous waste
                             constituents in the same area. Example; A tank and its associated piping and
	underlying containment system.	

       The EPA clarifies  the definition of process unit for the SOCMI standards, as
follows:  The definition was drafted by EPA to provide a practical way to determine
which equipment is included in an affected facility. There are no specific physical
boundaries or size criteria.  The definition instead depends upon several operational
factors, including chemical produced and the configuration of the processing
equipment.  Such configurations may be different for different producers of the same
chemical; therefore, the definition may be fairly site specific.  In practice, however, the
definition wiE implement  the selection of a process unit basis as the "source" covered
by the standards.

       Service. Service refers to two district concepts.  "In ... service" addresses the
specific conditions by which rale applicability is determined.  These terms (in organic
HAP service, in volatile organic compound  (VOC) service, etc.) are discussed in this
section.  "Type of service" refers to the physical condition of the process material:
gas/vapor, light liquid, or heavy liquid. Type of service is discussed  in a later section
of this chapter.

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       2.1.1.1    40 CFR Part 63

       Within the chemical industry, the HON applies to major sources which
manufacture as a primary product one or more of a designated list of chemicals and
which make or use as a reactant or manufacture as a product, co-product, or byproduct
any of a designated list of organic HAPs, The applicable chemicals and HAPs are
published as Table 1  and Table 2 of 40 CFR 63, Subpart F.

       In addition to the chemical manufacturing processes referred to above, the HON
also applies to a number of processes that produce certain butadiene-,  chlorine-, or
styrene-based products.  These processes are identified in 40 CFR 63, Subpart I, and
are required to comply with the provisions of Subpart H,

       For those facilities subject to the HON, the standards apply to equipment in
organic hazardous air pollutant service for 300 or more hours per year.  "In organic
HAP  service" means that the equipment contains or contacts a fluid that is five percent
or greater by weight  of total organic HAP. Within the rule, specific standards apply to
equipment in different types of service: gas/vapor, light liquid, and heavy liquid.

       The HON also stipulates that each piece of equipment within a process unit that
can reasonably be expected to contain equipment in organic HAP service is presumed to
be in  organic HAP service unless an owner or operator demonstrates that the piece of
equipment is not in organic HAP service. For a piece of equipment to be considered
not in organic HAP service, it must be determined that the percent organic HAP
content can be reasonably expected not to exceed five percent by weight on an annual
average basis.  For purposes of detennining the percent organic HAP content of the
process fluid that is contained in or contacts equipment, Method 18 of 40 CFR Part 60,
Appendix A is to be used.

       The HON is applicable to both new and existing facilities, regardless of their
date of construction.  For the purpose of establishing compliance deadlines, those
processes subject to Subpart H are divided into five distinct groups. The compliance
dates  (as of April 10, 1995) for the process groups at existing sources are as follows:


               Group I:               October 24, 1994
               Group H:              January 23, 1995
               Group ffl:              April 24, 1995
               Group IV:              July  24, 1995
               Group V:              October 23, 1995
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The group designation for each process unit is indicated in Table 1 of Subpart F.
However, the owner/operator of a plant has the option to comply at an earlier date than
required by the schedule.

       New sources that commence construction or reconstruction after December 31,
1992, should be in compliance with Subpart H upon initial startup or April 22, 1994,
whichever is later.

       Existing sources identified in Subpart I were required to comply with the
standard no later than October 24, 1994. New sources are required to comply upon
initial start-up.

       Finally, any equipment that is in vacuum service and equipment that is in
organic HAP service less than 300 hours per year are excluded from the requirements
of the HON standard.  No other specific exemptions are identified in the rule.
Equipment in VHAP service less than 300 hours per year as well as exempt equipment
in vacuum service must be identified in plant records.

       2.1.1.2    40 CFR Part 61

       The benzene equipment leak standards apply to components that are intended to
operate in benzene service. This is defined as "a piece of equipment which either
contains or contacts a fluid Qiquid or gas) that is at least 10 percent benzene by
weight." Generic provisions and standards for equipment in VHAP service are'at 40
CFR 61 Subpart V, and the benzene standards are at 40 CFR 61 Subpart J.

       As with the HON, the benzene equipment leak standards apply to both new and
existing sources,  and no applicability date separates new from existing sources. Each
piece of equipment within a process unit that can conceivably contain equipment in
VHAP service is presumed to be VHAP service unless an owner or operator
demonstrates that the piece of equipment is not in VHAP service.  A piece of
equipment is considered to be not in VHAP service if the percent VHAP content can be
reasonably expected never to exceed 10 percent by weight. Such determinations can be
made through the use of engineering judgement or by following procedures that
conform to ASTM Method D-2267.

       These standards do not apply to sources located in coke by-product plants.  Any
equipment in benzene service located at a plant site designed to produce or use less than
1,000 mg of benzene per year is exempt from the benzene NESHAP. This cutoff is
intended to  exempt most research and development facilities and other small-scale
operations.  Also exempt is any process unit that has no equipment in benzene service
and any equipment that is in vacuum service. All exempt equipment and equipment not
in VHAP service must be identified in plant records.

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       2.1.1.3   40 CFR Part 60

       SOCMI is a broad source category that covers plants that produce many types of
organic chemicals.  Examples of organic chemicals produced in the SOCMI segment
include acetone, methyl methacrylate, toluene, and glycine.  The complete list of
organic chemicals covered by SOCMI equipment leak standards is found in §60.489 of
40 CFR Part 60. 40 CFR 60 Subpart W applies to the industries that produce as
intermediates, byproducts, or final products, one or more of the chemicals listed in
§60.489 of the standard.  The standards apply to any affected facility that commenced
construction or modification after January 5, 1981.

       Subpart W applies to any piece of equipment which contains or contacts a
process fluid that is at least 10 percent VOC by weight.

       Any affected facility that has the design capacity to produce less than 1,000
megagrams (Mg) (1,100 tons) per year is exempt from the SOCMI rules. An affected
facility that produces heavy liquid chemicals only from heavy liquid feed or raw
materials is also exempt.  Exemptions also apply to: any affected facility that produces
beverage alcohol, any affected facility that has no equipment in VOC service, and all
equipment in vacuum service.

       2.1.1.4   40 CFR Part 264 and 265

       40 CFR Part 264,  Subpart BB applies to  owners and operators of facilities that
treat, store, or dispose of hazardous wastes  (TSDFs). Part 265, Subpart BB applies to
owners and operators of interim status TSDFs.  These  subparts apply to equipment that
contains or contacts  hazardous wastes with organic concentrations of at least 10 per cent
by weight that are managed in:  (1) units that are subject to the permitting requirements
of 40 CFR Part 270, or (2) hazardous waste recycling units that are located on
hazardous waste management facilities otherwise subject to the permitting requirements
of Part 270,  A facility may be  an operational chemical manufacturer, but any organic
waste streams it generates may  render it subject  to 264/265 BB (i.e., it does not need to
be a commercial treatment, storage, or disposal facility).

       Any equipment that is in vacuum service is excluded from the requirements of
this standard. However, equipment in vacuum service must be identified in plant
records.  These regulations do not affect conditionally-exempt or small-quantity
generators, and they do not affect satellite accumulation areas.

2.1.2  Procedures to Determine if Appropriate Rule is Being Applied

       Determination of rule applicability is ultimately the responsibility of the
regulated facility. Normally, any questions regarding applicability are reviewed and

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resolved through the State permitting process. Thus, an inspector can determine which
rules are being applied to a facility by consulting that facility's air permits. However,
permits are not always correct, and total reliance on the permit is not recommended.  A
thorough knowledge and understanding of the various process areas within a facility,
and the relationship of such processes to potentially applicable rules, will contribute to
an inspector's effectiveness.

       At any given facility, there will be an ongoing activity of equipment replacement
or retirement and additions or modifications to the various processes. Good process
knowledge will help the inspector to keep track of such changes, understand how the
current rule applies to new equipment, and identify any oversights by the facility in the
identification of such equipment. Additionally, the inspector may identify situations
such as changes to process constituents or formula, or major modifications, which
necessitate a review of rule applicability. With experience, the inspector may be able
to identify entire processes or facilities which an owner/operator has failed to recognize
as potentially subject to a rule.
2.2    WHICH COMPONENTS?

2.2.1  Specific Components

       Each of the Federal equipment leak regulations specifies a list of components
covered by each regulation.  Specific components common to all of the regulations
include:  valves, connectors, pumps, compressors, pressure relief devices, sampling
connection systems, open-ended valves or lines, and closed vent systems and control
devices.  The benzene NESHAP also applies to product accumulator vessels, whereas
the HON also applies to agitators, surge control vessels, bottoms receivers, and
instrumentation systems.

2.2.2  Quiflance tqi Determine if Eqm|tment Jas Been Identified Properly

       Production facilities subject to one or more of the equipment leak standards are
typically large plants with a very large number of components.  In order to comply with
the various standards,  an owner or operator needs to be able to locate and identify those
components subject to the standards and to reference any relevant information
applicable to each individual component.  Some types of information are required by
some of the rules; other information is simply useful or prudent from the
owner/operator's perspective. An inspector should develop a detailed understanding of
a facility's component identification system,  as well as information about the
components themselves.
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       The most basic element of any component identification system is the
assignment of a unique identification (ID) number to each component.  The ID number
is used to comply with various recordkeeping and reporting requirements. For
example, the ID number of each component that is found to be leaking is recorded in a
log. In addition, a list of the ID numbers of all equipment subject to the standards are
to be recorded in a log.  Lists of identification numbers are also required for equipment
in vacuum service, and other equipment in any special status identified by the
regulations.

       Following establishment of an ID system, being able to establish the exact
location of each component is the next basic element.  Most ID systems are designed to
facilitate location by incorporating the individual process unit (or other geographically
convenient criteria) into the number system. For the NSPS equipment leak standards,
components are only subject to the standards if they are located in an affected facility.
Therefore, it is important to identify the location of each component with regard to the
process unit it is in and whether that process unit is an affected facility.

       Another item of concern to the inspector is the relationship between the plant's
inventory of equipment subject to the standards and the equipment which is actually in
service.  When individual pieces of equipment or subsections of a process area are
taken out of service, such equipment should be routinely retired  or identified as out-of-
service on the inventory. Likewise, new or replacement equipment should be added to
the inventory. If an inspector can identify equipment that has not been properly added
or deleted from the inventory, then the facility may not be in full compliance with the
applicable rule.
2.3    WHICH SERVICE?

2.3.1  Service Definition

       The specific standards applied to equipment subject to these rules depends on
the type of service the equipment is in. Most rules identify three types of conditions:
gas/vapor service, light liquid service, and heavy liquid service. Part 61 does not
define "light" or "heavy" liquid, just "liquid service." Definitions of the three types of
service are the same, although several rules provide for alternative means of
measurement or demonstration.

       "In gas/vapor service" means that the piece of equipment contains or contacts
process fluid that is in the gaseous state at operating conditions. All of the standards
use this definition except the HON, which refers to "equipment in organic hazardous air
pollutant service (which) contains a gas or vapor at operating conditions."
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       Equipment Is "in light liquid service" if all of the following conditions are met:

       •      The vapor pressure of one or more components is > 0.3 kPa (0,04 psi) at
              20°C.

       •      The total concentration of the pure components, with a vapor pressure
              >0,3 kPa (0.04 psi) at 20°C, is s20 percent by weight.

       *      The fluid  is a liquid at operating conditions.

       40 CFR Part 61,  Subpart V defines "in liquid service" rather than differentiating
between "in light liquid service" and "in heavy liquid service." In liquid service means
that a piece of equipment is not in gas/vapor service. The HON also uses this
definition of "in liquid service."

       A summary of components and type of service designations covered by the
Federal equipment leak regulations is presented in Table 2.2.

2.3.2  Guidance toJMermtne if Correct Seryjce is Identified

       As is the case with rule applicability, determination of type of service is the
responsibility  of the regulated facility.  The regulations require that documentation of
type of service determination be maintained by the facility. If an inspector questions a
facility's classification, a review of the records which address how the type of service
classification was made would be the first step.

       An inspector may also be able to review process and material balance data to
determine if type of service classifications are appropriate. As a final course of action,
an inspection may collect a sample of the process material in question and apply the
analysis specified by the applicable rule.
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                  TABLE 2.2
SUMMARY OF EQUIPMENT LEAK COMPONENTS COVERED
COMPONENT
Valves, gas/vapor
service
Valves, light liquid
service
Valves, heavy
liquid service
Pumps, light liquid
service
Pumps, heavy
liquid service
Pressure relief
devices, gas/vapor
service
Pressure relief
devices, light
liquid service
Pressure relief
devices, heavy
liquid service
Compressors
Sampling
connection systems
Open-ended valves
or lines
Flanges and other
connectors (all
services)
Connectors in
gas/vapor service
Connectors in light
liquid service
Connectors in
heavy liquid
service
Closed-vent
systems and
devices
Agitators in
gas/vapor service
40 CFR Part 60,
Subpart VV
60.482-7
.60.482-7
60.482-8
60.482-2
60.482-8
60.482-4
60.482-8
60.482-8
60.482-3
60.482-5
60.482-6
60.482-8
NA
NA
NA
60.482-10
NA
40 CFR Part 61,
Subparts J and V
in VHAP service
61.242-7
in VHAP service
61.242-2
61.242-4
in liquid service
61.242-8
61.242-3
61.242-5
61.242-6
6L242-8
NA
NA
NA
61.242-11
NA
40 CFR Part 63,
Subparts H and I
63.168
63.168
63.169
63.163
63.169
63.165
in liquid service
63.169
63.164
63.166
63.167
NA
63.174
63.174
63.169
63.172
63.173
40 CFR Part 264, Subpart BB
40 CFR Pan 265, Subpart BB
264.1057
265.1057
264.1057
265.1057
264.1058
265.1058
264.1052
265.1052
264.1058
265.1058
264.1054
265.1054
264.1058
265.1058
264.1058
265.1058
264.1058
265.1053
264.1055
265.1055
264.1056
265.1056
264.1058
265.1058
NA
NA
NA
264.1060
265.1060
NA
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                                    TABLE 2.2
                 SUMMARY OF EQUIPMENT LEAK COMPONENTS COVERED
COMPONENT
Agitators in light
liquid service
Agitators in heavy
liquid service
Instrumentation
systems
Product
accumulator
vessels
Surge control
vessels
Bottoms receivers
40 CFR Part 60,
SubpartW
NA
NA
NA
NA
NA
NA
40 CFR Part 61,
Subparts J and V
NA •
NA
NA
61.242-9
NA
NA
40 CFR Part 63,
Subparts H and I
63,173
63.169
63.169
NA
63.170
63.170
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB
NA
NA
NA
NA
NA
NA
NA - not applicable
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                                 CHAPTERS

                  COMPLIANCE/INSPECTION THROUGH
                     REPORTS AND RECORDKEEPING
      It is extremely important that an inspector be thoroughly familiar with the
reporting and recordkeeping requirements of the regulations. With the exception of
RCRA, all of the equipment leak standards addressed by this manual stipulate that
compliance with the applicable standards will be determined by review of required
records, by review of performance test results, and by inspections. The NSPS and
HON also reference reports as a basis for compliance demonstration. Parts 264 and
265 both specify reeordkeeping requirements, and Part 264 requires reports if leak
repairs are not completed on schedule or if control devices deviate from their
operational standards for more than 24 hours.  Review of reports and records is also a
critical component in the conduct of effective on-site inspections.

      This chapter first addresses the content of required reports for the NSPS,
NESHAP and HON and discusses their review for the purposes of compliance
determination.  Recordkeeping requirements of the NSPS, NESHAP, HON, and RCRA
regulations  are then addressed, with a concluding discussion of recordkeeping
compliance reviews. The chapter concludes with additional discussion of strategies an
inspector can use to supplement the review of records  and reports. Chapter 4 addresses
the role of records and reports as a resource for on-site inspections.

3.1   REPORTS

3.1.1 40 CFR Part 60. Subpart W

      Facilities subject to Subpart W are required to submit reports both under the
general provisions, which are applicable to all NSPSs unless the specific subpart says
otherwise, and under Subpart W.  The following paragraphs identify the various
reports required and the information each is to contain. Failure to submit the required
reports on time and with the required information may be grounds for non-compliance.

      The NSPS General Provisions (40 CFR Part 60, Subpart A, §60.7) mandate that
any owner or operator subject to a NSPS must provide written notification of the date
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of construction or reconstruction within 30 days after work begins. In addition to the
construction or reconstruction notification, the general provisions require the following:

       •      A notification of the anticipated date of initial startup of an affected
              facility postmarked between 30 and 60 days before the startup date.

       »      A notification of the actual date of initial startup of an effective facility
              within 15 days after startup.

       •      A notification of any physical or operational change to an existing
              facility that may increase the emission rate of any pollutant to which a
              standard applies, unless that change is specifically exempted.  This
              notice shall be postmarked 60 days, or as soon as practicable, before the
              change.

       3.1.1.1   Initial Reports

       Under Subpart W facilities are required to submit semiannual reports beginning
six months after the initial startup date and every six months thereafter. The initial
report must include an identification of the process unit, the number of valves in
gas/vapor service or light liquid service, the number of pumps in light  liquid service,
and the number of compressors.  Valves, pumps, and compressors that are designated
as having no detectable emissions should not be included hi the totals listed in the initial
report.

       3.1.1.2   Semiannual Reports

       Semiannual reports are required beginning six months after the  initial report and
each six months thereafter. These reports contain information on the results of LDAR
programs.  The information required in these reports begins with the process unit
identification,  which should correspond with the identification in the initial report.  The
semiannual report must document, on a monthly basis, the total number of detected
leaks and the number of this total that were not repaired in the required 15-day period.
In each Distance where a repair is delayed, the report is to explain the delay. If the
reason for the  delay is that it could not be repaired until a process unit  shutdown, then
the report is to indicate why a process unit shutdown was technically infeasible  during
the reporting period.  The report shall then show the dates during the reporting  period
when process unit shutdowns occurred. In addition, any revisions to items reported in
the initial report are to be  described and discussed.  The format of reports is not
specified in the regulations, and a number of variations are acceptable.
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       3.1.1.3    Other Reporting Requirements

       Other reporting requirements contained in the NSPS regulations include two
alternative standards for valves: the allowable percentage of valves leaking, and the
skip-period LDAR program. If an owner or operator elects to comply with either of
these alternative standards, a notification must be provided 90 days before
implementing the provisions.

       40 CFR Part 60 also requires the owner or operator to submit a written report of
the results of any performance test to EPA. Performance tests are required for no
detectable emissions equipment and valves complying with an alternative standard.
They also may be required for closed-vent systems, control devices, and equivalent
means  of emission limitation.  Information must be made available to EPA as necessary
to determine the operating conditions during the performance tests. In addition,
Subpart W requires that the owner or operator notify the Administrator of the schedule
for the initial performance tests at least 30 days before conducting them.

3.1.2  40 CFR Part 61

       40 CFR Part 61, Subparts J and V require submission of an initial statement and
semiannual reports.

       3.1.2.1    Initial Reports

       The initial report must contain two portions:  a written assertion stating that the
company will implement the standards and the testing, reeordkeeping, and reporting
requirements contained in the applicable NESHAP; and information on the equipment
subject to the regulation, including equipment identification (ID) numbers, process unit
IDs for each source, and a description of the type of equipment (e.g., a pump or a
pipeline valve). Also, the percent by weight of VHAPs in the fluid being handled by
the equipment and the state of the fluid (i.e., gas/vapor or liquid) must be included.
Finally, the initial report must contain a description of the chosen method of
compliance and a schedule for subsequent semiannual reports. The source must abide
by this schedule unless it is amended in subsequent semiannual reports.

       All facilities in existence on the effective date of any NESHAP were required to
submit an initial report. Therefore, all existing facilities subject to the above-
referenced standards should have already submitted an initial report.  All new plants are
required to submit an initial report with the application for approval of construction, as
required by the general provisions of Part 61 (NESHAP).
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       3.1.2.2    Semiannual Reports

       Six months after the initial report, and every six months thereafter, the facility
must submit a semiannual report. These semiannual reports are for NESHAP
compliance and are similar to the required NSPS semiannual reports.  They must
provide process unit IDs for regulated equipment and, on a monthly basis for each
process unit, the number of valves, compressors, and pumps that were detected leaking.
Of those valves, compressors, and pumps that were detected leaking, the number that
were not repaired within 15 days is to be reported, along with an explanation of why a
repair was delayed. If the reason for the delay was that a process unit shutdown is
needed before repair, then an explanation must be given why a process unit shutdown
was infeasible.

       The report also must include the dates of all process unit shutdowns during the
six-month reporting period and a discussion of any revisions to the initial report or
subsequent revisions to the initial report. The regulations do not specify the format of
the reports; they only specify minimum content requirements. Each facility develops
and uses its own format.

       These standards allow the designation of equipment subject to a no detectable
emissions  limit rather than an LDAR standard, an alternative standard based on the
allowable percentage of valves leaking,  and an alternative skip-period LDAR program.
All three of these as well as closed-vent systems and control devices require
performance tests.  If a performance test was conducted within the six-month reporting
period, then the results of the test also must be included in the semiannual report.

       3.1.2.3    Other Reporting Requirements

       An owner or operator of a facility electing to comply with either of the
alternative standards for valves (i.e., the allowable percentage of valves leaking or the
skip-period LDAR program), must provide notification 90 days before implementation
of either of these programs.

       Certain circumstances described in the regulations do not require an application
for approval of construction/modification.   These circumstances are:  (1) a new source
complies with the standards, (2) a new source is not part of the construction of a
process unit, or (3) all information required in the initial report is contained in the next
semiannual report.

3.1.3  40 CFR Part 63. Subparts H and I

       Existing facilities subject to the HON standards are required to submit an initial
notification that describes the source and the chemical manufacturing processes subject

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to the standards. New sources (if the start-up date is 90 days or more after the
promulgation date) are required to submit an application for approval of construction or
reconstruction in lieu of the initial notification.  All sources are required to submit a
Notification of Compliance Status within 90 days of the applicable compliance date.
This notification describes how the source will maintain compliance with the standard.
Finally, periodic reports are to be submitted semiannually beginning six months after
the Notification of Compliance Status. Reports can be submitted on electronic media
where acceptable to the regulating agency and the owner/operator of the source.

       3.1.3.1   Initial Notification

       The initial notification required of existing sources is due within 120 days of the
date of promulgation of the applicable standard (April 22, 1994, for Subparts H and I).
It is to include the name and address of the owner or operator, the address (physical
location) of the affected source, identification of the chemical manufecturing processes
subject to the subpart, and a statement of whether the source can achieve compliance by
the applicable compliance date. The application for approval of construction or
reconstruction submitted by new sources is to contain the same information as required
for the initial notification.

       3.1.3.2   Notification of Compliance Status

       The Notification of Compliance Status is due within 90 days of the applicable
compliance date (Subpart H has five dates, see Chapter 1) for existing sources.  New
sources, which are required to comply with Phase II of the HON upon initial startup,
would include the equivalent compliance status information in their application.  The
Notification of Compliance Status requires the following information for each process
unit subject to the standards:

       •     Process unit identification

       •     Number of each equipment type (e.g., valves, pumps) excluding
             equipment in vacuum service

       •     Method of compliance with the standard (e.g.,  "monthly LDAR" or
             "equipped with dual mechanical seals")

       •     A planned schedule for each phase of the requirements applicable to
             pumps in light liquid service and valves  in gas/vapor or light liquid
             service.

       If a source elects to use pressure testing  of batch product process equipment to
demonstrate compliance, the notification report is to include the batch products or

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product codes subject to this option and the planned schedule for pressure testing of the
equipment when it is configured for such production. The notification shall identify
each enclosed-vented process unit and describe the negative pressure system and control
device used.

      3.1.3.3    Periodic Report

      The periodic reports are to be submitted semiannually and are to convey the
following information for each process unit for each monitoring period during the six-
month period reported:

       •     The number (by type) of valves, pumps, compressors, agitators,
             connectors, and screwed connectors that were detected leaking and the
             number for which leaks were not repaired as required in the standard.

       *     The total number (by type) of valves, pumps, connectors, and screwed
             connectors monitored and the percent of the total found leaking.

       »     The number of unrepaired valves and the number of unrepaired
             connectors that are determined non-reparable.

       •     The facts that explain any delay of repairs and, where appropriate, why a
             process unit shutdown was technically infeasible.

       «     The results of all monitoring of pressure relief devices, closed-vent
             systems, and any compressors designated to operate at less than 500
             ppm.

       *     If applicable, implementation of a monthly monitoring program for
             valves, a quality improvement program for valves or pumps, or a change
             in connector monitoring alternatives.

      If the source has elected to use pressure testing to demonstrate compliance for
batch process equipment, the report shall also include;

       *     Batch product process equipment train identification.

       »     The number of pressure tests conducted and the number of tests where
             the equipment train failed the test.

       •     The facts that explain any delay of repairs.
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       •      The results of all monitoring to determine compliance with standards for
              closed-vent systems and control devices.

3.1.4  40 CFR Parts 264 and 265. Subpart BB

       TSDF facilities to which Part 264 applies are not required to submit an initial
report and are required to submit a semiannual report only under certain conditions.
These conditions refer to failure to repair leaking equipment on schedule or failure to
correct a control device which exceeds or operates outside of design specifications.  If a
report is required,  it shall identify the facility and provide the dates of hazardous waste
management unit shutdowns that occurred during the preceding semiannual reporting
period.  For each month during the semiannual reporting period, the TSDF is required
to report:  (1) the ID number of each valve, pump, or compressor for which a leak was
not repaired or required, and 2) the date, duration and cause of any control device
exceedance, and any corrective measures taken.

       40 CFR Part 265, Subpart BB contains no reporting requirements.

3.1.5  Reviewing  Reports

       Although reports are the primary mechanism by which a facility documents
compliance with the equipment leak rules, they are of limited value to the inspector as a
means of identifying specific violations or of substantiating noncompliance.  From a
regulatory point of view, review of reports can only substantiate noncompliance on the
basis of:

       »      Failure to submit a report

       •      Late submittals

       •      Missing or incomplete report content

       •      Self-reported violations

       For purposes of determining compliance, the primary focus of an inspector's
review of reports should be on the issue of report completeness. Other issues
(accuracy, equipment classification, monitoring performance, etc.) require some further
interaction with the review of records and/or on-site inspections.

       During the  first year or two of developing an equipment leak program at a
regulated facility, it is possible that a facility may overlook or be unaware of some
reporting requirements.  Equipment subject to partial exemptions or non-routine
reporting schedules may be  the most likely to be overlooked. However, once a facility

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has submitted a report that the Agency accepts as complete, the facility is unlikely to
regress from this established standard.  Subsequent violations of reporting requirements
are most likely to be associated with changes in the process, e.g., failure to add/delete
equipment as a result of maintenance or process modifications.

       A report  may contain "self-reported" violations such as failure to attempt
equipment repair within schedule or during process shutdown.  An inspector should, of
course, review each report carefully and note  such "self-reported" violations for follow-
up. In many cases, these events prove to be recordkeeping or reporting errors rather
than true violations.  For example, transcription errors may occur between records and
reports (e.g., a valve is monitored as leaking at 1,500 ppm but is transcribed to a report
at 15,000 ppm),  or a maintenance crew may forget to submit repair invoices.  By
routinely following up on such questions, an inspector will help the facility to recognize
inadequacies in its equipment leak compliance program and such reporting errors
should decline.

       Many facilities employ sophisticated monitoring systems and databases to
minimize both the  labor hours and opportunities for clerical errors associated with large
scale monitoring systems. Monitoring equipment can be equipped with a data logger
containing the sequential ID numbers for all equipment within a process area. At each
monitoring point, the data logger automatically records the highest instrument reading
obtained at that point.  This data can then be downloaded to a database that contains;
(1) all the relevant information for each piece  of equipment, and (2) a report generator
which automatically prepares the appropriate report for each process area.

       Sophisticated systems can also generate erroneous reports, as a result of lack of
foresight in their preparation or due to a lack of human attention to the system.  As  an
example, some data logging systems employ a default value of zero or carry forward
the reading from the previous monitoring. As a result, these systems may report a
numerical reading  for a piece of equipment, even if that equipment was not monitored.
Conversely, these systems may not be able to  record readings from new equipment until
the equipment data has been entered into the database.

       Ultimately, the best strategy for effective review of reports by an inspector is
developed familiarity.  This includes familiarity with the recordkeeping and reporting
requirements of  the rules, and familiarity with how the regulated facility is performing
its monitoring, data management, leak repair,  and reporting programs. By developing
such detailed knowledge about a specific facility, an inspector will be better prepared to
interpret and understand that facility's reports. This developed familiarity requires an
ongoing balance of effort which includes on-site inspection and review of records.
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3.2    RECORDKEEPING

3.2.1  Part 60 Subpart W and Part 61 Subpart V & J

       All of the equipment leak regulations require the maintenance of extensive,
detailed records that can be readily accessed at the plant site.  Specific records that are
required include:

       •      A list of ID numbers for all equipment subject to the requirements
             (except for welded fittings or connectors under some rules).

       »      A list of equipment ID numbers for equipment designated for "no
             detectable emissions" or complying with the less than 500 ppm above
             background standard.  The no detectable emissions designation must be
             signed by the owner or operator and requires an annual compliance test
             and a record of the date of the compliance test, the background level
             measured, and the maximum instrument reading measured at the
             equipment.

       •      A list of equipment ID numbers for pressure relief devices required to
             comply with the standards for pressure relief devices in gas/vapor
             service.

       »      A list of ID numbers for equipment in vacuum service.

       If a closed-vent system and a control device are used to control fugitive
emissions, the records for this equipment must include:

       •      Detailed schematics, design specifications, and piping and
             instrumentation diagrams,

       •      Dates and descriptions of any changes in the design specifications.

       »      A description of the parameters) monitored to ensure that a control
             device is operated and maintained in conformance  with the design, and
             an explanation of why that parameter was selected for monitoring.

       •      Periods when the closed-vent systems and control devices are not
             operated as designed, including periods when a flare pilot light does not
             have a flame.

       •      Dates of start-ups and shutdowns of the closed-vent systems and control
             devices.

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       A dual mechanical seal system that includes a barrier fluid system is an
alternative for reducing emissions from pumps and compressors.  If a dual mechanical
seal system with a barrier fluid system is used, the following information must be
recorded:  (1) the design criteria that indicates failure of the seal system, the barrier
fluid system,  or both; (2) an explanation of the choice of this design criteria; and (3)
documentation of any changes to the criteria and the reasons for the changes.

       The records also must contain a list of ID numbers for valves that are designated
as "unsafe to monitor," an explanation for this designation, and the plan for monitoring
each valve. The same records are required for valves designated as "difficult to
monitor."  For valves complying with the skip-period provisions, a schedule of
monitoring and a record of the percent of valves found leaking during each monitoring
period must be kept on file.

       Certain criteria allow a facility to be exempted from the requirements (see
Chapter 2). If a facility claims an exemption, then it must maintain a log that contains
information, data, and analyses to support its exemption declaration.  For example, 40
CFR 63 Subparts V & J stipulate that the following information shall be recorded:  (1)
an analysis demonstrating the design capacity of the process unit, and (2) an analysis
demonstrating that equipment is not in VHAP service.

       For each compliance monitoring test conducted, a record of results must be
retained. This includes the monthly leak monitoring for pumps and valves, as well as
the annual no detectable emissions monitoring for pumps, compressors,'valves, and
closed-vent systems.  Any monitoring for alternative standards also must be
documented.

       Other non-periodic circumstances require compliance monitoring. A pressure
relief device must be monitored within five calendar days after a pressure release to
confirm that no emissions are detectable. If a pump or valve in heavy liquid service,
flange, or other connector is suspected of leaking, this equipment must be monitored
within five days. If a leak is detected and repair is attempted, the component must be
monitored to determine  if the repair attempt was successful. Records must be kept of
the findings of all such monitoring tests. If a leak is detected, the equipment must be
identified as a leaking component by attaching an ID tag to the leaking equipment.  The
tag must be weatherproof and readily visible. A tag may be removed after the
equipment has been repaired and retested successfully.  The tag may be removed from a
valve, however, only after it has been repaired and monitored for two successive
months with no detected leak.

       When leaks are detected, records on each leak must be kept and maintained for
two years.  For each detected leak, the equipment ED number, the instrument and
operator ID numbers, and the date the leak was detected must be recorded.  The date of

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each repair attempt and an explanation of each method applied should be recorded.  If
the leak is corrected, then the date of successful repair should be entered in the log.  If
the repair is unsuccessful, the operator should record that the maximum instrument
reading of the monitoring after the respective repair was above the applicable leak
limit.

       If a leak is not repaired within 15 calendar days of being detected, "repair
delayed" should be entered in the log, and the reason for the delay should be discussed.
If the reason for the delay is that the repair could not be attempted until a process
shutdown, then the person who made the decision to delay repair must sign the log.  If
process unit shutdowns occurred while the leak remained unrepaired, the dates of these
shutdowns also must be recorded. Finally, the expected date of successful repair of the
leak should be entered for these delinquent leaks.

3.2.2  Recordkeeping for the HON

       The HON incorporates virtually all of the recordkeeping requirements of the
NSPS and NESHAP standards, with significant additions and extensions.  For example,
all equipment ID numbers are required to identify the process area in which the
equipment is located.  Additional equipment addressed by the HON includes agitators,
product accumulator vessels, and bottoms receivers equipped with closed-vent and
control systems, pressure release devices equipped with upstream rupture disks,
instrumentation systems, batch process equipment, enclosed-unit processes, and
equipment in HAP service less man 300 hours per year.  Substantial new recordkeeping
requirements are associated with equipment in a quality improvement program (QDP).

       Connectors need not be identified individually, but the number of connectors in
each process area are to be recorded.  Screwed connectors are  to be individually
identified. Additionally,  each connector which has been disturbed since the last
monitoring is to be identified and the date and result of follow-up monitoring recorded.

       The HON records require a monitoring schedule by process area for valves and
connectors.  Both valves and connectors that are designated as  difficult  to monitor,
unsafe to monitor, or unsafe to repair are to be identified in the records. The records
must also ID valves and connectors which have been removed  from service and claimed
for emission reduction credits.

       Tagging of individual components within each process area is  not required by
the HON, so long as other identification requirements are met. Tagging and reporting
requirements for leaking equipment are the same as the NESHAP regulations. For
equipment which cannot be repaired within the applicable deadline, the  HON allows
written procedures for determining that such equipment qualifies for delay  of repair
status to be included hi the records.

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       Visual inspections required by the HON are to be recorded. These are to
include documentation that the inspection was conducted, the date of the inspection, and
detailed records for leaking equipment identified in these inspections.

       When a facility elects to periodically pressure test a batch process, each
regulated product and the time hi service for each product are to be recorded.  Pressure
test records are to include the date of each test and any visual observation of leaks.
When equipment fails a pressure test, records are to be kept of each leak repair attempt,
the date of each repair, the repair methods employed, and the reasons for any delay of
repair.

       Enclosed-vent process units and the HAPs they handle are required to be
identified in the records.  Enclosed-vent process units are enclosed in such a manner
that all emissions from equipment leaks are vented through a closed vent system to a
control device.  The records are to include a schematic of the process unit, enclosure,
and closed vent system and a description of the system used to create the negative
pressure in the enclosure.

       A QIP generally consists of information gathering, detennining superior
technologies, and replacing existing equipment with the superior technologies until the
required base performance levels are achieved.  The recordkeeping requirements
basically stipulate dates and documentation of QIP activities.  The Demonstration of
Further Progress QIP for valves requires additional recordkeeping for monitoring and
repair activities.  The Technology Review and Improvement QIP for valves  or pumps
extends recordkeeping requirements to include: equipment construction and use data,
process stream data, inspection of leaking valves removed from service or of pumps
that leak frequently, and analysis of equipment performance based on these records.

3.2.3  RCRA Recordkeeping Requirements

       The RCRA equipment leak standards stipulate that records be maintained hi the
facility operating record or in a log maintained in the facility operating record.  The
following information is to be maintained for each piece of equipment to which Subpart
BB applies:

       •     Equipment ID number and hazardous waste management unit
             identification.

       •     Approximate location within the facility.

       •     Type of equipment (e.g. pump or pipeline valve).
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       •     Percent-by-weight total organics in the hazardous waste stream at the
             equipment.

       »     Physical state of hazardous waste at the equipment (e.g., gas/vapor or
             liquid).

       *     Method of compliance with the standard.

       »     A list of ID numbers for all subject equipment.

       »     A list of ID numbers for equipment designated for "no detectible
             emissions," with signature of the owner or operator.

       •     A list of ID numbers for pressure relief devices subject to the standard.

       »     For each compliance test required by the standards, the date, the
             background level, and the maximum instrument reading measured at the
             equipment.

       For each leak detected in the compliance tests, the following information is to be
recorded in a log and maintained for three years:

       •     The instrument, operator, and equipment ID numbers.

       •     The date evidence of a potential leak was found.

       «     The date the leak was detected and the dates of each repair attempt.

       »     Repair methods applied in each attempted repair.

       *     "Above 10,000" if the instrument reading following a repair attempt
             exceeds 10,000 ppm.

       •     "Repair delayed" and the reason if a leak is not repaired within 15 days
             of discovery.

       •     Delay of repair documentation for applicable valves.

       *     Owner or operator signature when repairs cannot be effected without a
             unit shutdown.

       •     The expected date of repair for leaks not repaired within 15 days.
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       •     The date of successful repair.

       The records are to include design documentation and monitoring, operating, and
inspection information for each closed vent system and control device. In addition, a
performance test plan and documentation of performance test results are required when
test data is used to demonstrate control device performance. Control devices not
otherwise identified in the regulations are also required to record monitoring and
inspection information indicating proper operation and maintenance of the control
device.

       A list of valves designated as unsafe to monitor and a list of valves designated as
difficult to monitor are to be maintained.  Each list is to include an explanation of the
designation and a plan for monitoring each valve.  Recorded information for other
valves must include (1) a schedule of monitoring and (2) the percent of valves found
leaking during each monitoring period.

       The following information is to be maintained hi a log  for determination of
applicable exemptions: (1) analysis determining the design capacity of the hazardous
waste management unit, (2) a statement listing the hazardous waste influent/effluent to
each unit and an analysis determining whether these hazardous wastes are heavy
liquids, and (3) up-to-date analysis, supporting information, and data used to determine
applicability of the standards.

3.2.4  Reviewing Records

       When reviewing equipment leak records, it is important to keep in mind the
primary purpose of the records, which is verification of the information in the reports
and documentation of other elements of program performance such as performance of
monitoring, adherence to repair schedules, documentation of visual inspections, etc.
Review of records should be guided by the inspector's prior review of the reports and
should focus on using the records to (1) confirm the  accuracy and content of the reports
and (2) determine that recordkeeping requirements of the applicable standard are
complied with.

       Specifically, records should be investigated to confirm that all components are
indicated as being monitored as reported and to confirm the number of reported leaks.
Additionally, such information should be compared with the inventories of total
components by type of service as recorded in the initial report for each facility.  There
will normally be some fluctuation in the total number of components inspected during
each monitoring period due to a variety of factors such as leak/repair status and
equipment retired from or added to a process. A detailed review of the records may be
necessary to resolve all of the apparent anomalies in  process areas with a large number
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of components or where substantial modifications are underway. Failure to record and
report such changes may result in a violation of the standards.

       Records should also be reviewed to confirm the performance of repairs and
follow-up monitoring on all reported leaks.  For example, if a valve was reported
leaking, check if the records confirm the following: (1) a first attempt to repair within
five days, (2) completion of repair within 15 days, and (3) monthly monitoring for two
months before return to quarterly monitoring. If the valve was not repaired but was
scheduled for repair at the next shutdown, was this an appropriate classification (i.e. is
the explanation/documentation of the classification reasonable and signed by the proper
official)?  The complete list of components scheduled for repair at the next shutdown
should be reviewed to determine the appropriateness of this classification.

       As is  the case with reports, only a limited number of specific violations can be
identified and confirmed solely through a review of records.  Establishing such a
violation is primarily a process of identifying something which is missing. Facilities
are in direct noncompliance under the following situations:

       •      Failure to record leaks and dates of repairs,

       •      Failure to record the reason for delaying repair of leaks past an allotted
              tune frame,

       •      Failure to develop a schedule to observe visual emissions from flares,

       »      Failure to perform emission testing for control devices (except  in the
              case of flares), and

       •      Failure to record periods when the control device is  not operating.

       Finally, each facility will develop and implement its own form of
recordkeeping. The variety and inconsistency of recordkeeping formats from one
facility to another is a problem which an inspector has little opportunity to influence or
correct.  For example, the availability and utility of work orders to support
recordkeeping or to confirm/resolve errors and oversights will vary from facility to
facility.  To be effective, an inspector needs to develop a degree of familiarity with the
data collection and management system of each facility in his or her area of
responsibility.
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3.3    STRATEGIES FOR REVIEWING REPORTS AND RECORDS

       As has been previously discussed, the report and recordkeeping requirements of
the equipment leak regulation do. not provide enough information for an inspector to
make a complete determination of compliance.  The report and recordkeeping review
activities provide the basis for determining whether a facility is in compliance with the
report and recordkeeping requirements and provide the informational basis for more in
depth inspection activities. Strategies available to the inspector to improve the
effectiveness of both functions include (1) requesting additional information and 2)
coordinating the review process with on-site inspections to reinforce the determination
of compliance.

       An inspector can generally request that a facility provide any records specified
by the equipment leak regulations in the form of a supplementary report. A thorough
understanding of the records  required by the standards and the data management
systems of the individual facilities will enable an inspector to request additional
information in a format that is reasonable for the facility to comply with and useful to
the inspector's objectives.  Other information not specifically referenced in the
regulations may also be available to the inspector.  Process flow diagrams and/or
schematics of individual process areas can be particularly useful as a means of orienting
oneself prior to  a site visit, reviewing the appropriateness of various equipment
designations (e.g., type of service, dangerous to monitor), and for cross-referencing
data from various records sources.  Work repair orders and/or repair invoices are
another source of potentially  useful information, especially when it is necessary to
reconcile apparent gaps or oversights  in the records.

       Required reports and  supplementary irformation provided by the facility are
useful means of preparing for on-site inspections. In addition, information collected
on-site or requested during a site visit can be used for follow-up review and evaluation
of compliance status.  Collecting or requesting information for review after completion
of a site visit allows the inspector to make more efficient use of available time while on-
site.  Such information can be used to supplement and/or document inspection field
notes and observations.  Additionally, such information can be compared with the
initial review of semiannual reports to resolve any lingering questions.
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                                  CHAPTER 4

      COMPLIANCE/ASSESSMENT THROUGH ON-SITE INSPECTIONS
       On-site inspections are a critical component in evaluating compliance with the
leak detection rules and evaluating the effectiveness of facility LDAR monitoring
activities. Due to the complexity of the standards and the large numbers of emission
points at a typical facility, it is imperative that an inspection be conducted hi a
systematic fashion.  An inspector may choose to use a portable VOC analyzer to
conduct direct leak checks of regulated equipment, but it is also possible to conduct a
compliance inspection without the use of such equipment. The first portion of this
chapter addresses the conduct of a walk-through inspection without an analyzer; the
second portion addresses the conduct of inspections with the direct monitoring of
regulated equipment.

       Equipment leak inspections encompass a broad range of potential activities.  The
specific content and organization of inspections will vary according to the priorities or
objectives of the inspector and/or policies of the agency. For example, it may be
necessary to devote an entire inspection to on-site interviews and examination of
records addressing the appropriate classification of equipment. Short, follow-up
inspections may be combined with other on-site activities. This chapter uses a
simplified inspection format to illustrate the important elements of organizing and
conducting inspections.
4.1    WALK-THROUGH INSPECTIONS

       A complete equipment leak inspection program includes pre-inspection
activities,  on-site activities, and post-inspection review and reports.  The pre-inspection
activities help the inspector become familiar with the facility, contributes to the
selection of specific process areas or components to be inspected, and may determine
the actual  timing of the inspection. On-site activities include review of records,
interviews with plant personnel, inspection of regulated equipment, and observation of
monitoring procedures.  Post-inspection activities include additional review of records
and other  information, preparation of the inspection report, and establishing the
foundation for subsequent inspections.
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4.1.1         Pre-inspection Activities

       The purpose of pre-inspection activities is for the inspector to develop a general
understanding of the plant under investigation, the processes employed, and products
produced. Additionally, the inspector should be familiar with the applicable regulations
and understand what types of information are required to determine compliance prior to
the on-site inspection.  Good preparation helps to select those units suspected or
detected as being compliance problems, determine the appropriate timing of the
inspection, and improve an inspector's efficiency while on-site. Caution: While it is
meaningful to gain an impression of the overall situation through these pre-
inspection activities, it is equally important than an inspector not prejudge a
facility based only on the preliminary information.  Compliance determination
should be finalized only after the on-site inspection and follow-up activities are
completed.

       It is important that the inspector keep detailed records for each inspection. An
inspection notebook should be started during the pre-inspection time period so that all
information  is contained in a central location for the entire inspection. Since the
notebook may be used to form the premise of the inspector's report and as evidence in
legal proceedings,  it is critical that the inspector substantiate the facts with tangible
evidence such as pertinent observations, photographs, copies of documents,
descriptions of procedures, unusual conditions, problems and statements from facility
personnel.

       4.1.1.1   Report Reviews and Other Information Sources

       Sources subject to the various equipment leak standards  are required to submit a
preliminary  notification and/or initial report which provides general facility
information, process unit information, and the inventory of all subject equipment with
details of individual components. These initial documents should be  evaluated for
completeness, as discussed in the preceding chapter. If any aspect of the initial
documents are incomplete, the inspector should record this in the inspection notebook.

       Each of the regulations also require the submission of semiannual or periodic
reports.  The inspector should evaluate the most recent of these reports for
completeness and compliance with the requirements. Additionally, these reports should
be compared with  each other and with the initial reports to determine the consistency of
information. Any  inconsistencies or omissions of required information should be
recorded in the inspection notebook.

       Following the review and evaluation of these reports, the inspector should
review previous inspection reports and related documentation such as field notes, post-
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 inspection correspondence, and violation notices. These will identify previous
 deficiencies and related issues, may record the estimated schedule of additions or
 reconstructions the facility is planning to implement, and may record specific actions
 the facility has committed to with respect to improving its compliance with the
 equipment leak regulations.

       The omissions, inconsistencies, unclear information, or question areas identified
 by the above review should be noted in the inspection notebook. A complete and well
 organized list of questions should be developed from these notations so that plant
 personnel can be questioned or plant records checked during the inspection.
 Inconsistencies by themselves.are not uncommon and do not necessarily indicate
 violations. They may indicate poor implementation of recordkeeping and reporting
 which can be corrected at the facility without the issuance  of formal citations.

       In the case of new regulations (e.g., the HON in 1995/96) or new plant
 construction, the only source of information specific to the equipment leak programs
 may be the initial report. In such cases, the inspector should examine agency files to
 determine if other process areas at the facility have been previously regulated under
 other equipment leak rules. If so, these reports may provide some background about
 the facility's  familiarity and performance with respect to equipment leak regulations.
 Agency files  should also be examined to obtain other compliance information,
 correspondence, complaints, etc. regarding the facility.  Other types of permits and
 reports, such as  those for other air regulations, wastewater, hazardous waste, or toxic
 substance permits, should also be reviewed. A good example is TRI reports, submitted
pursuant to EPCRA requirements.  Information contained  in the initial equipment leak
 reports should be compared with these other sources of information to assess the
 consistency between the details reported.

       Other inspectors who are currently or formerly assigned to the facility in
 question should be interviewed for their experience and  insight. For example, RCRA
 and air inspectors should perform cross-media reviews of each other's inspection
reports.

       Finally, up-to-date schematics or flow charts of regulated process areas at the
facility should be obtained to facilitate understanding of the physical site layout. A
major problem that confronts the inspector is determining  if equipment exists in the
facility that is subject to the standard, but is not listed hi the in-plant records and
therefore is not being monitored and/or does not meet the equipment specifications.
This may be the most difficult part of an inspection.  One method of addressing this
problem  is to request a process unit material balance with a corresponding simplified
flow diagram. This information could then be reviewed hi detail to determine if there
appears to be equipment which should be listed and is not.  If such areas exist, then the
on-site inspection or follow-up inspection should address this issue.

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       4.1.1.2    Inspection Timing and Scope

       An additional consideration during pre-inspection preparations should be the
nature of the inspection itself.  Does the purpose of the inspection require an
unannounced visit or is some degree of notification acceptable?  While it is desirable to
maintain some degree of flexibility as to the specific plant areas and records you will
examine while on-site, it is also necessary to allow key plant personnel an opportunity
to rearrange their activities to accommodate the inspection.  The inspection involves the
review of many records and interviews with key company officials. Additionally, plant
personnel should be available to accompany the inspector during the facility walk-
through and to answer the inspector's questions.

       If you plan to examine leak monitoring activities of plant personnel or their
outside contractors, obtain their current monitoring schedule. You need to ensure that
routine monitoring activities will be conducted during your visit, and you may want to
select an inspection date which coincides with monitoring of specific process areas.

       Another aspect of inspection preparation involves making an assessment of what
can be accomplished within the time available to conduct the inspection.  To make the
best use of limited time and resources, it is often useful to structure the inspection on
the basis of what can be accomplished within one full day.

       For the inspection program discussed in this section, an initial interview with
plant officials and the site walk-through can be accomplished during the" morning, with
the afternoon devoted to review of records and a final interview addressing any
questions or observations resulting from the inspection. It may be necessary to review
some of the records prior to conducting the site  walk-through, especially if the records
are needed to identify specific equipment to be inspected.  In general, the site walk-
through should be completed before reviewing the records in detail to assure that
enough time is available for the walk-through.  If the record review cannot be
completed on-site, copies can generally be taken back to the office.

       It is useful to become familiar with the normal workday schedule at each plant
and to schedule your inspection accordingly. For example, the equipment leak
monitoring personnel may work an early shift (e.g., 6 am to  3 pm) so that maintenance
personnel can conduct same-day equipment repairs on a later shift.  At a small facility
which  employs a contract monitoring service, monitoring personnel may only be
available one or two days per week or during alternating weeks. It is generally difficult
to obtain useful observations or interviews if you schedule a process area walk-through
during the lunch break. More importantly, if you are flexible in the scheduling of
inspection activities, plant personnel may  be more relaxed and responsive to your
inquiries.
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       4.1.1.3   Health and Safety Planning

       A critical aspect of pre-inspeetion planning includes efforts to ensure that
personnel safety measures are in place.  Contaminants of concern identified during the
preliminary review of the facility should be reviewed for exposure impacts, via dermal
or inhalation pathways, to ensure appropriate personnel safety gear is donned for the
inspection. Further, if potential risks exist, the inspector should wear a modified level
C and be able to don a respirator  if monitoring equipment indicates levels in the
breathing zone exceed acceptable levels. Finally, when you schedule an inspection,
review with company officials what safety equipment is needed and what, if any, safety
equipment the company will provide.

4.1.2  Qn-SiteInspection

       When you arrive at the facility, notice if there are any strong odors or visible
emissions. If there is a visible emission or strong odor, make sure it is thoroughly
documented before entering the facility. Try to find out the cause of the visible
emissions or odor after you have  introduced yourself.

       4.1.2.1Initial Interview

       Once the inspector has identified himself or herself and has been granted entry
to the facility, the initial interview should be conducted.  The objective of the interview
is to inform the facility officials of the purpose of the inspection, the  authority tinder
wMch it will be conducted, the procedures to be followed, and your agenda for the day
of the inspection.

       Discussion of the agenda should include an explanation of how you plan to
perform the inspection and should address any adjustments to your schedule
necessitated by plant operating schedules and conditions. With regard to leak
monitoring activities,  it is probably best to observe calibration and monitoring
procedures as they are scheduled  for that day, rather than to observe  a possibly
rehearsed demonstration of these  activities. Final specification  of the records you wish
to inspect should be made at this time, along with agreement as to when they will be
available and where you can review them.

       An important component of the inspection involves the evaluation of how well
company officials understand the  applicable regulations and how effectively they are
acting to achieve compliance.  The inspector should have key plant officials explain  the
compliance program of the facility: including a general discussion of
problems/solutions, plant quality  assurance procedures, and compliance program goals
of the plant.  With regard to the inspection agenda for the day,  the inspector should
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verify that the sources are subject to the standard and should ask for a description of the
process areas, principal products, and location of major emission points.

       Before proceeding into the process areas, the inspector should review plant
safety procedures and confirm that all appropriate safety equipment is available.
Finally, plant officials should be advised of their right to request confidential treatment
of trade secret information.  Company officials may review the inspection notes at the
end of the inspection and mark trade information confidential.

       4.1.2.2   LeakMonitoringActivities

       A key element of the facility inspection involves evaluation of the leak
monitoring program.  This activity may include: interviewing monitoring personnel,
observing the calibration of leak detection equipment, and observing facility personnel
perform leak detection monitoring and spot checking of equipment sources for leaks.

       Some facilities conduct monitoring with their own personnel, while others
employ an outside contractor to perform the leak monitoring.  If in-house personnel
conduct the monitoring, an inspector may want to  review the training and resources
provided to the employees. If an outside contractor is employed, the inspector should
determine if the facility employs any oversight or quality assurance procedures to
evaluate the performance of the contractor.  Other pertinent items include:  how
monitoring personnel report leaks, how repairs are scheduled, and how follow-up
monitoring is scheduled for repaired equipment.

       The competency of the personnel who conduct the monitoring may be evaluated
both through observation and direct interviewing.  The inspector should discuss the
plant procedures and schedules for monitoring, the recording of monitoring results,
general information regarding the analyzers in use, requirements of Method 21, and any
other areas the inspector determines to be of importance. These could include training
received, task supervision, and ancillary duties performed by the leak monitoring
personnel.

       The leak detection equipment used to document facility compliance must be
calibrated on a routine basis. The inspector should observe calibration procedures
performed by the facility or contractor personnel who normally perform the routine
monitoring.  The calibration precision tests, response time, and response factor tests
reveal whether the instruments are operating properly for the specific applications.  The
inspector should witness the calibration procedures and should note any deviations from
the Method 21  procedures.

       A number of other factors can be important such as:  probe cleanliness, probe
leakages, gas flow rates, improper warmup period, incorrect zero, or meter adjustment.

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If the meter readout cannot be adjusted to the proper value, a malfunction of the
analyzer is indicated and corrective actions are necessary before using the analyzer.
The inspector should verify that the correct calibration gases are used and that the gases
are within the proper range. The inspector should record the instrument response time,
response factors, and calibration precision tests.

       After the calibration procedure is complete, the inspector should observe the
plant personnel's or private contractor's technique hi performing actual leak detection
measurements.  The plant personnel should be able to correctly monitor fugitive
emissions from all the equipment types at the plant site. Additionally, the plant
personnel should be able to correctly determine background concentrations. Any
deviations from Method 21 procedures should be noted.  Techniques for correctly
monitoring certain equipment items are described in the foEowing paragraphs.  See
Appendix E in Volume n for a more detailed discussion of monitoring techniques.

       Fugitive leaks from valves occur primarily  from the valve stem packing gland.
The normal procedure is to circumscribe the valve stem with the probe held at the stem-
packing interface.  Maintaining such a close proximity to the stem is necessary in order
to obtain accurate measurement because of the relatively poor capture effectiveness of
the probe design. The presence of strong cross-draft wind further reduces the probe
capture capability. For these reasons the proper placement of the probe is critical. It
should be noted, however, that this monitoring requirement dictates that the inspector
position himself or herself in the immediate vicinity of the leak because most probes  are
relatively short in length.  Caution: If the inspector detects unsafe conditions, he  or
she should stop observation and inform plant personnel. All involved parties
should follow their organization's safety procedures.

       Certain monitoring procedures can be employed to minimize the risk of such
exposure. Whenever feasible, equipment to be monitored should be. approached from
downwind.  Concentrations of equipment hi a sheltered area should be approached
relatively slowly from a more open area.  In both cases, use your sense of smell and
visual observation of the instrument background reading as an early means of detecting
elevated concentrations.

       Fugitive emissions from pumps occur from the pump shaft seal used to isolate
the process fluid from the atmosphere. Monitoring must be performed within one
centimeter of the seal and the rotating shaft. Caution: A rigid probe tip should not
be used near the rotating shaft because it could break if the monitoring personnel
were not able to hold the probe absolutely steady during the measurement. A
flexible tip is usually added to the end of the rigid probe when sampling pumps. If the
housing configuration prevents a complete traverse of the shaft periphery, sample all
accessible portions. Additional points on the pump or compressor housing where leaks
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could occur include flanges and other connections, and these should be sampled.  Also,
look for liquid leaks from the stuffing boxes of pumps.

       Care must be exercised  when monitoring sources, such as valves and pumps,
that handle heavy liquid streams at high temperatures. Relatively nonvolatile organic
compounds can condense hi the probe and detector. Both the instrument response to
the emissions and the instrument return to zero may be slowed due to the condensation
of these compounds.

       Fugitive leaks from flanges or other connectors typically occur at the flange or
connector sealing interface. For all connections, the probe should be positioned at the
outer edge of the flange-gasket interface, and monitoring should be conducted over the
entire circumference of the flange.

       In most cases, the configuration of pressure relief devices prevents sampling at
the sealing interface.  However, for those pressure relief devices equipped with an
enclosed discharge pipe, extension, or horn, the sample probe inlet should be placed at
the approximate center of the exhaust area relative to the atmosphere.  Also, sample at
any "weep hole" at the bottom  of such devices.

       Certain fugitive leak sources are subject to a "no  detectable emission"
regulation, i.e., the difference between the background organic vapor concentration and
the concentration measured at the source  should not be greater than 500 ppmv.  The
background concentration is determined by placing the probe one to two meters upwind
of the source.  If other equipment interferes with the background measurement, the
upwind monitoring location can be as close as  25 centimeters.

       Leak monitoring personnel should record the highest instrument reading
obtained at each piece of equipment. For fugitive VOC  sources that have a highly
variable leak rate, the maximum sustained concentration or maximum repeated
concentration observed should be recorded.

       During observation of the leak monitoring, the inspector should note how well
the monitoring personnel keep track of their monitoring  equipment. While monitoring
is underway, the probe tip should be routinely  checked and cleaned out as necessary.
Instrument background readings and return to zero rates  should be monitored
periodically.  Also, note whether monitoring personnel are equipped with and using
appropriate tags to mark leaking equipment.

       Finally, note the number of equipment components and the number of leaks
detected by the monitoring personnel.  These can be used to calculate rough estimates
of leak monitoring rates (i.e., valves per hour or total components per hour) and
component leak rates (e.g., eight leaking  valves out of 150 tested equals six  percent

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leak rate).  These rates can be compared to leak monitoring rates and component leak
rates calculated from the records for the same or similar process areas.  A large and
consistently repeated difference between reported rates and observed rates may indicate
that monitoring personnel are changing their procedures in some consistent fashion
while being observed by the inspector.

       In addition to observing the performance of routine monitoring, the inspector
may wish to have the monitoring personnel spot-check a representative sample of
equipment for leaks. This should be done by observing personnel perform leak
detection monitoring on each type of equipment subject to the standard. The spot-
checks should include:

       *     recently leaking  devices;

       *     "no detectable emission" devices;

       *     exempt devices (verify compliance).

       Finally,  if a facility is using closed vent systems and control devices, ensure
compliance with minimum temperature, residence time, efficiency and no detectable
emissions requirements. If flares are being used, inspect for no visible emissions as
determined by Reference Method 22.

       4.1.2.3    Process Area Inspection

       In addition to observing the leak monitoring program, an inspector should
devote some time to observation of the process  area itself and interviewing process
personnel regarding their roles in the equipment leak program.  By doing so, an
inspector can determine compliance with observable requirements such as equipment
tagging and gain a better understanding of the program implementation.

       The degree to which process area personnel will be aware of and involved in the
equipment leak  program will vary from facility to facility. At a rninimum, there should
be a designated  individual (process area chief or shift foreman) responsible for (1)
documentation of visual inspections, (2) maintenance of on-site logs, and (3)
coordination between leak monitoring and equipment maintenance. Other areas in
which process personnel may be involved include  (1) performance of first attempt at
repair, (2) oversight or quality  review of leak monitoring personnel, and (3) on-site
responsibility for equipment markers and removable equipment (e.g., end caps or
plugs).

       Perhaps  one of the most important areas to discuss with process personnel is the
issue of coordination between leak monitoring and equipment maintenance personnel.

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Lack of communication between these groups is a significant source of errors and
compliance problems.  How well the facility understands these problems and the types
of procedures undertaken to correct or prevent such oversights can reveal a lot about
the development and effectiveness of a facility's equipment leak program.

       Observation of the process area should include verification of component
tagging, observation of end caps or plugs on open ended lines, inspection of sampling
connection systems and equipment in vacuum service, and evaluation of the operation
of various control devices.

       Errors and oversights with respect to component tagging requirements are a
common problem which can be directly observed by the inspector.  All equipment that
is scheduled for repair  or to be monitored following repair must be clearly labeled. An
inspector can use records and reports to develop a list of components that should be
tagged and can then directly inspect those components to confirm the tags are being
applied and maintained. For equipment that will not be repaired until the next process
turnaround, the inspector can review the process equipment where the component is
located to confirm that  such repairs cannot be accomplished without a process
shutdown.

       Open-ended lines are frequently out of compliance (e.g., no plug or end cap)
and can be directly cited as a violation as a result of on-site inspections.  Plant
personnel may lose or misplace end caps or plugs when such lines are opened, then
simply forget about them. An area-wide maintenance activity may  result hi numerous
lines with missing caps.

       Sampling connection systems should be examined to confirm that the vent
properly returns process fluids to the process. Similarly, equipment in vacuum service
should be examined to  confirm that equipment to create such a vacuum is in place,
operating, and venting  to a control device.

       Each dual mechanical seal with barrier fluid system is required to be equipped
with a sensor that monitors the chosen criteria to detect a system failure.  This sensor
must be checked daily or be equipped with an audible alarm.  The inspector should
verify that the sensor has an alarm which is working properly or that the sensors are
being monitored daily.

       If a control  device is being used to control equipment leak emissions, the
inspector needs to observe several items.  The first is the identification of the control
device and the manner  in which the owner or operator is monitoring its operation.
Following are several questions that should be answered during the inspection:

       »     Why type of control device is used?

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       •      What is the claimed control device efficiency?

       »      Is the efficiency measured (tested) or calculated?  Obtain a copy of any
              of these test results or calculations.

       »      For incineration devices, what is the combustion temperature (from the
              field or control room)?

       »      For each type of control device in use, what are the critical parameters
              that demonstrate compliance (e.g., adsorber pressure drop/regeneration
              cycle time, scrubbing fluid flow rate/pressure drop, final temperature
              leaving condenser)?

       *      For flares, during normal operation what is the net heating value and exit
              velocity of the flare gas? Is the velocity and net heating value of the
              flare gas measured (tested) or calculated? Obtain copies of these test
              results and/or calculations.  Check the flame indicating device (probably
              a thermocouple readout) in the field or control room for proper
              operation. Observe the flare for  visible emissions.

       The inspector should evaluate the parameters chosen and the rationale for this
selection to determine if these parameters are appropriate to monitor proper operation
for the type of control device. This evaluation may need to be done off-site if the
inspector is not readily familiar with a particular type of control device.

       4.1.2.4   Inspection of Records

       Recordkeeping requirements and strategies for the review of records have been
addressed in Chapter 3.  The primary objective  of the record inspections is to minimize
fugitive emissions through requiring adherence to the recordkeeping requirements of
the regulation. Records that are required to be kept by the facility (and not reported)
should be reviewed by the inspector during the on-site inspection.  The inspector should
determine what information needs to be obtained to document compliance.  In
particular, the inspector should identify missing information, incomplete data or reports
and inconsistencies in the available background  material, and specifically seek to extract
this information from on-site facility reports for the purpose of making a compliance
determination. Likewise, if noncompliance is suspected, the inspector should
concentrate efforts on obtaining necessary documentation for verifications.

       The first step in the records review should be to determine if the records  are
complete according to the regulations.  After determining the completeness of the
records, a check for consistency and validity should follow. An inspector should take
along a few of the most recent semiannual reports so that comparisons can be drawn

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between the information contained in these reports and the information in the on-site
records, especially if during the pre-inspection review the inspector identifies any
inconsistencies.  Alternatively, the inspector may copy the appropriate records and
perform this comparison off-site.  If any equipment is complying by an option of the
regulations that requires annual testing, then it is advisable to bring semiannual reports
which contain test results to check for consistency with the complete test reports.  The
records for leaking pumps, compressors, and valves should be compared with the
numbers in the last several semiannual reports.  Any inconsistencies between the
reports and records should be noted.

       The inspector should then review the monitoring data to ascertain if the control
device is being operated according to its design.  The records must also contain design
specifications, instrumentation diagrams, etc. so that this comparison can be drawn.
The records are to contain a log of periods when the closed-vent systems and control
devices are not operated in accordance with the design specifications.  The duration and
frequency of noncompliance episodes should be noted. The inspector should compare
his findings regarding such periods (based on a review of the monitoring data) with the
instances recorded in the log. Any inconsistencies should be noted in the inspection
notebook.

       The test data  pertaining to  no detectable emissions equipment or valves
complying with percentage of valves leaking provision that was reported should be
compared with the test information contained in the records.  Again, any
inconsistencies should be noted.  A test for a process unit complying with the percent
leakage that indicates greater than two percent leakers is a violation.  Any instance
where such a test was conducted and not reported should be noted and evaluated as a
possible inconsistency or a violation.

4.1.3  Post-Inspection Review and Reports

       4.1.3.1   Post-Inspection Review

       The post-inspection process should begin by reviewing the applicability
determination to ensure that all questions about the facility as a whole and all individual
process units have been fully answered.  The equipment listings should also be
reviewed.

       There are two fundamental questions that an inspector should consider during
this post-inspection data sorting.

       •      Is the  recordkeeping system adequate  to track monitoring, leaks, and
              repairs?
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       *      Are the monitoring staff, equipment, and procedures adequate?

The answers to these questions and rationale for these answers should be contained in
the inspection report.  If the response to either of these is no, suggestions should be
made to proper plant personnel to address correction of the existing problems.

       4.1.3.2   Post-Inspection Reports

       Upon completion of the walk-through inspection, the  inspector should begin
preparing the inspection report while all the events of the inspection are still fresh in his
or her mind. The inspector should prepare the report before conducting another leak
detection inspection. When two or more inspections are done at one time, it becomes
difficult to mentally separate one from another. The facility  data contained in the initial
report, the semiannual reports, as well as results  of the facility record review and the
inspection, constitute the information available to the inspector to evaluate compliance
with the regulations. Additional information, elaboration or  clarification may come
from the inspector's field notebook. If the inspector feels that it is needed, letters may
be issued or phone calls made requesting additional information.  The instance may
occur where a return visit to the plant is necessary.  These follow-up type inspections
should be abbreviated in nature and focus on the  unanswered questions or problem
areas.

       The next phase of the post-inspection process is to write the inspection report.
The report organizes and correlates all evidence gathered during the inspection into a
concise and useable format.  The report serves to record the procedures used in
gathering data and gives factual observations and evaluations drawn in determining
facility compliance. The inspector's report will also serve as part of the evidence for
any enforcement proceeding or compliance-related follow-up activities.

       The inspection results should be organized in a comprehensive, objective and
accurate report.  The recommended report elements are listed below:

       •      Introduction
       »      Compliance Status for Regulated Equipment
       »      Evaluation of Observed Program
       •      Data
       *      Summary

4.1.4  Preparation for Subsequent Inspections

       After completing the report, the inspector should prepare for the next inspection
while the facility's processes are still fresh in his or her mind* This can be
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accomplished by preparing a list of items to be checked and information to be reviewed
or gathered during the next inspection.

       There are several suggestions to be considered for subsequent inspections at a
facility. The pre-inspection preparation should basically be the same for each
inspection. The inspector should review all the information contained in the facility's
file including the initial and semiannual reports.  The semiannual reports that have been
submitted since the last inspection should be reviewed most carefully. The past
inspection reports should also be reviewed. If any items were noted in these reports
which required action by the facility, then the semiannual reports should be examined
with these specific areas in mind.  There also are items to consider regarding the on-site
inspection. Due to the large number of records that are required, it may be impossible
to review  all records on each visit. If this is the case, it is a good idea to spot-check a
different portion of the records during each inspection.  It is also suggested that the
inspector check a different area of the plant by general walk-through and equipment
spot-checks in an effort to eventually cover the entire affected facility.
4.2    DIRECT MONITORING OF COMPONENTS

       The use of monitoring equipment by an inspector introduces an added level of
complexity to the inspection process and may produce unsatisfactory results if the direct
monitoring is not carefully planned. On the other hand, some detailed inspection data
suggest that actual leak rates are often much higher than what is reported by the
facilities, and some local agencies are convinced that a comprehensive direct
monitoring strategy is necessary for effective enforcement of the equipment leak rules.
However, the use of direct monitoring by inspectors does not necessarily guarantee an
effective regulatory program in and of itself.

       In recent years, the National Enforcement Inspection Center (NEIC) of U.S.
EPA has conducted a number of comprehensive sampling inspections of facilities
subject to 40 CFR 60, Subpart GGG, NSPS for petroleum refineries. These inspections
included some facilities at which direct monitoring had been included as part of the
local agency's inspection procedures.  A typical NEIC inspection involved two or three
inspectors conducting direct monitoring of eight or ten process areas. Plant personnel
or their contractors accompanied the inspectors and conducted their own monitoring,
employing the same methodology used by the EPA inspectors (Method 21).  In all
cases, the NEIC inspections measured leak rates at a majority of process areas that
were substantially higher than leak rates currently being reported by the facilities. A
typical inspection of ten process areas  would find seven or more process areas with leak
rates of three to five times the reported rates.  In all cases but one, leak rates found by
the plant personnel accompanying the inspection agreed with the findings of the
inspectors.

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       These inspections suggest that the primary problem is the monitoring
methodology employed by the facilities or their contractors.  Although ostensibly
following Method 21 procedures, the monitoring personnel appear to be performing
cursory examinations in an attempt to complete as many inspections as possible within
an allotted period of time, resulting in a chronic under-reporting of leak rates.

       These inspections also illustrate some of the difficulties associated with
evaluating compliance with the equipment leak rules. If a facility is conducting the
required monitoring, performing repairs on schedule, and complying with all of the
recordkeeping and reporting requirements, it can be extremely difficult to demonstrate
that the facility is not achieving the emission reductions expected from the reported
level of performance.  The inspector can only periodically observe performance of the
monitoring personnel and can at best only develop circumstantial evidence of
inconsistencies between routine and observed monitoring practices.

       The use of direct monitoring within the context of an agency inspection program
needs to address this issue of verifying that the monitoring and testing procedures
utilized by the plant are in full compliance with the Method 21 sampling methodology.
To accomplish this, an inspector could monitor a representative sample of equipment
within a  process area and compare the results with the history of leak checks for that
process area conducted by the plant. A large discrepancy between the inspector's
findings  and the plant's records would indicate that the monitoring procedures of the
plant need to be improved.

       Another means of evaluating the monitoring procedures of plant personnel is to
have them monitor all  of the components hi a specific area of a process unit, while the
inspector follows and monitors the identical equipment. Alternatively, the inspector
could accompany the plant personnel and monitor each piece  of equipment
concurrently, so that both operators obtain the same reading.  In the first case,
discrepancies in the results of the two evaluations would indicate a need for improved
monitoring technique,  while the second scenario allows the plant personnel to directly
perform  the monitoring method as practiced and approved by the Agency.

4.2.1  ]Process Area Inspection

       Evaluating the monitoring technique of plant personnel is useful on an
occasional basis, but conducting inspections of a representative sample of equipment
within a  process area is probably preferable as a long-term inspection practice. It
directly addresses the performance of regulated equipment at  a facility and can be more
consistently replicated  as an inspection procedure. Plant personnel would also have the
opportunity to accompany the inspector with their own monitoring equipment without
interfering with the inspection procedure.
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       Determining what constitutes a representative sample of equipment within a
process area is an issue of both numbers and accessibility. Equipment that is not
classified as difficult or unsafe to monitor, but which requires some exertion to reach
(e.g., climbing towers) should be systematically included in the inspector's sampling
pattern.  Equipment such as pumps and compressors, which are normally present in
small numbers within a process area, can all be sampled. Valves, normally present in
very large numbers within a process area, need to be systematically sampled. Other
equipment, including connectors, pressure relief devices, and equipment subject to no
detectable emission limits, can be spot-checked during the inspection.

       As a general rule of thumb, 200 to 300 valves can be inspected within a half day
of direct monitoring and are usually a sufficient number to constitute a representative
sample.  Very large process areas (i.e., more than 1,000 valves) may require a larger
sample.  A purely random sampling of valves is often infeasible and is usually not
necessary so long as other steps are taken to maintain representativeness. For example,
if a process area has four reactor columns which require climbing to access equipment,
select one or two columns and monitor all valves on those selected.

       Usually, one or two cohesive subsets of a large process area can be identified
and sampled as a representative sample of that area.  Often, the facility will have an
established "start-to-finish" route to be used by its own monitoring personnel or
subcontractors. Using a process flow diagram, it may be possible to divide the route
into three or four sections and then select any one section as the representative sample
for that area.  Any equipment type such as pumps, reactor columns, surge control
vessels, etc. that are concentrated in a specific area should be added to the inspection.
Depending on the number involved, all or a portion of these units (as well as valves and
other connectors associated with the units) can be sampled.

       To be most effective, direct monitoring needs to be repeated. An ideal practice
might be to test each process area at a regulated facility  once per year. The specific
process area to be tested on any given day would be unannounced.  If annual testing of
all process areas cannot be achieved, the selection of process areas  to be tested should
be guided by the inspector's on-site observations and evaluation of the facility's records
and reports. Additionally, certain process areas can be expected to leak more often
than others and should therefore be inspected more frequently.  These areas include
those processes containing more volatile materials and processes operating at elevated
temperatures or pressures.

4.2.2  Inspection Preparation

       Preparing for and conducting an inspection that includes direct monitoring of a
process area is very similar to the procedures for a walk-through inspection described
earlier in this section.  The principal difference is that performance of the monitoring

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by the inspector replaces the observation of monitoring by facility personnel.  Other
inspection activities, including preview of reports, on-site observations of regulated
equipment, interviews with plant personnel, and on-site inspection of records remain
virtually unchanged.  Direct monitoring activities may increase an inspector's risk of
exposure and the adequacy of safety planning steps should be reviewed.

       Several steps need to be added to the preparation stage to ensure a successful
inspection.  These include equipment maintenance, supplementary supplies, and
planning the monitoring approach.

       Prior to each inspection, the monitoring instruments and supporting equipment
should be inspected to confirm that everything is in good working order and will be
available on the dates needed.

       The next step in the pre-check procedure is to confirm that the sampling
instrument is properly calibrated.  This includes checking that the monthly calibration
precision test has been conducted and scheduling a daily calibration test for the
inspection date. If a calibration test is to be performed in the field, confirm that
disposable cylinders of certified gas mixtures in the appropriate concentrations will be
available.

       Finally, check the condition of the analyzer backpack.  All analyzers should be
outfitted so that the instrument can be carried on the  inspector's back.  Additionally, the
pack straps should be equipped with clips for the hand-held probe and the inspector's
clipboard.  This allows both hands to be free for climbing ladders. Use of a backpack
will greatly reduce fatigue, and the probe can also be clipped to a strap when the
inspector is writing in the clipboard.

       Selection of the specific process area or areas to be tested should be
accomplished during the inspection preparation. This may be done as a result of a
preliminary review of reports and records, notes from previous inspections, or an
annual schedule.  Process area schematics, leak monitoring and repair records, and
information about process materials (type of service, heated or pressurized processes,
volatility of process materials) can be used to make such determinations.  These
materials should be requested in advance from the facility.  When the inspection is
scheduled with the facility, the inspector should request that the most recent records for
four or five process areas (including the one to be directly monitored) be  available at
the beginning of the inspection.  This will allow the inspector to review the most up-to-
date information on the process area immediately before the inspection.
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4.2.3  Pn-Site Inspection Procedures

       During the pre-inspection meeting, identify the specific process area(s) you plan
to inspect and monitor and review the most recent records from those processes.  Also,
request to see a copy of the permit and check to see if the permit is current and valid.
Compare your agency's current equipment list with the source's equipment list.  Check
existing permit conditions and ask if any changes have been made to the operation
which are not reflected in the permit.

       Immediately prior to entering the process area, warm up your analyzer
instrument, check that all components are operating properly, and perform a span check
with the appropriate calibration gas.  Upon entering the process area, ask the
production personnel if there are any leaking components and when they were found
leaking and tagged. Compare any reported leakers with the most recent records for that
area.  While conducting the monitoring inspection, observe tags on leaking components
to ensure that they  are properly dated and that the allowed time period for repair has
not expired.

       While conducting the monitoring inspection, use your senses of sight, smell, and
hearing to survey an area for leaks and to help you zero in on leaking components.  As
you enter an area and proceed from component to component, note any suspect odors
and watch for any increases in background concentrations on your analyzer gauge.
Look for any distortion emanating from the equipment similar to the distortion seen
from infrared radiation near the ground or on a roof on a hot day. Also, look for such
distortions in the shadow of the equipment.  If background noises are not excessive,
you may also detect leaks by hearing them.  Investigate the source of any unexplained
hissing sounds. Caution; Your risk of an exposure that exceeds acceptable levels
can increase significantly as you zero in on leaking components.  Be certain that all
appropriate safety gear is donned  before proceeding with your investigation.

       Always look for liquid leaks from components in the form of drips or spray
mist.  Investigate any stains which may be the result of recent evaporation of such
leakage.  If process or sealing fluids are present at valve stems, pump shafts, or
connection points, look for bubbles  which may indicate a leak.

       When using the analyzer to check each piece of equipment for a leak, move the
probe slowly along the interface where a leak may be likely, holding the probe tip as
close to the interface as possible.  Look for blips  in the meter reading, which may
indicate that you recently passed over a leak. Remember that there is a response time
lag (usually less than five or ten seconds) between the time a VOC is sucked into the
probe and the time that a meter indication is observed. When a blip is observed, slowly
retrace your sampling route until you find the point at the interface where the leak is
highest.

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       The leak rate is measured by finding the highest concentration of the leak.  At
the interface where the leak is highest, vary the angle of the probe to maximize the
concentration. If possible, block any wind or draft from the area you are checking.
Read and record the maximum concentration that you can maintain for several seconds,
not just the peak of a spike.  If the leak is intermittent or pulsing, note the maximum
concentrations across several cycles and record the maximum of these readings. In the
case of gross leaks (e.g., 50,000 ppp or more), attempting to read the maximum
concentration following this procedure may lead to flame-out or saturation of the
analyzer. Addition of dilution air to the probe intake may be necessary to obtain an
accurate reading. Alternatively, the inspector may record the highest reading
obtainable without risking damage to the analyzer and note any supplementary
information (odors, etc.) associated with the leak.

       Within the portion of a process area selected for direct monitoring, certain
components are more likely to leak than others, and these components should be
carefully examined. Flow control valves, which are operated more frequently than
other valves,  are correspondingly more likely to leak.  There are often valves and
connectors located near pumps and compressors that are subjected to vibrations and
pressure surges. A pump that is not running is more likely to leak at the shaft seal than
one which is operating. Gauges and meters that have been repositioned by plant
personnel are more likely to leak as a result of such movement. Finally, any equipment
that has been worked on or recently installed is more likely to leak.  Visual cues (tool
marks, new looking or cleaner components) as well as the facility's monitoring and
repair records will help you identify such components.

       It may not be necessary to record every component you examine, especially if
you can use a process diagram to document the areas inspected. Ask the plant
personnel who accompany you during the inspection to keep a running tally of the
number and type of each component inspected. When a leak is detected, record the
leak rate and the ID for the leaking component. Plant personnel should tag each
leaking component. If plant personnel make an initial attempt to repair the component,
try to reinspect these components to confirm the results of the initial repair attempt. It
may be possible to do this after monitoring of the selected area is completed or at the
end of the day. If personnel initiate repair attempts while you are conducting the
monitoring inspection,  do not slow down your own inspection schedule by waiting to
monitor repairs. Come back after completing your monitoring schedule.

       Detailed inspection procedures for valves, pumps, compressors, pressure relief
devices,  connectors, and other equipment have been discussed earlier in this chapter.
While conducting the inspections, remember to look for grease or other materials mat
could plug the probe and continually check the probe tip for any obstructions. Also,
use caution when inspecting any moving equipment.  Do not touch the surface of any
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rotating or reciprocating shaft with the probe tip of your analyzer.  Use a short piece of
plastic or tygon tubing at the probe tip as an extra means of protection.

4.2.4  Post-Inspection Interview

       Include a discussion of the findings from your monitoring inspection in the post-
inspection interview with plant personnel.  Address any areas where the monitoring
results may result in a notice of violation, such as leaks from equipment designated for
no detectable emissions. If the monitoring results indicate a significant discrepancy
with leak rates reported by the facility, discuss this issue and elicit comments from the
plant personnel regarding specific actions to be taken to address the problem.
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                                 CHAPTERS

     RECOMMENDED INSPECTION TECHNIQUES AND PROCEDURES


5.1    INSPECTION PROGRAM DEVELOPMENT

       Chapter four briefly referred to the fact that the emphasis of equipment leak
inspections will vary in response to a variety of factors. One important factor is the
state of LDAR program development at a new facility or at a facility newly subject to a
new rale. Initial inspections at such facilities would focus on applicability, appropriate
classification of equipment, and documentation of exemptions.  Later inspections would
focus more heavily on inspection of monitoring practices, reeordkeeping, and repair
procedures, and addressing the correction of identified deficiencies.  Assuming the
LDAR program at the regulated facility matures and stabilizes, on-going inspections
may evolve into a more-or-less routine pattern of compliance oversight.

       However, even within the context of inspections at a facility with an established
LDAR program, the emphasis of individual inspections will vary.  There may be one or
two annual inspections that address the facility as a whole in addition to periodic
inspections that look more  closely at individual process areas. Intermittent events, such
as start-up following a process shutdown or the employment  of new monitoring
personnel at the facility, may become the primary emphasis of individual inspections.
Finally, the experience level of the inspector may be a factor in the selection of
inspection emphasis.

       Implementation of the HON equipment leak provisions provides a convenient
means of illustrating such an evolution of inspection emphasis.  As the rule was
implemented, many chemical facilities found themselves subject to equipment leak
regulations for the first time.  For those  facilities already subject to NSPS or NESHAP
regulations, the HON was likely to introduce an expansion of the number of regulated
process areas as well as more extensive recordkeeping requirements and more stringent
leak standards.  Such facilities may have found that current monitoring and
recordkeeping practices were inadequate, or even inappropriate, for the demands of the
regulations and the needs of the facility.  Those changes may have resulted in an
expanded level of inspection activity for the regulatory agency as well as a need to
adjust the inspection emphasis in step with development of the LDAR programs at the
regulated facilities.

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       At the outset of implementation of new LDAR requirements for a facility, the
first few inspections would focus primarily on applicability issues while developing
familiarity with the plant's initial approaches to monitoring, recordkeeping, and
equipment repair. Finding and reconciling any misclassification or oversight with
respect to regulatory applicability during the initial phase could avoid more serious
complications at a later stage. An inspector addressing this issue could consult with
personnel in the agency who have developed the facility's permits, study process flows
and material balances of the facility, and review the documentation and justification for
'those processes which have been classified as qualifying for various exemptions.  At
this time, the inspector should also look at equipment classified as  "difficult to monitor"
or "unsafe to monitor" to confirm that such equipment meets the applicable
requirements.

       Once the issue of applicability has been adequately resolved, the inspector can
begin to concentrate on direct observation of the facility's monitoring program and
conduct visual inspections of individual process areas.  While observing monitoring
activities, the inspector may devote one or two site visits to conducting side-by-side
monitoring with the facility's personnel.  This would afford an opportunity to identify
and address any problems with monitoring techniques at the facility. In the case of
process area site visits, the inspector can interview operating personnel so as  to gam
insight into how well they understand their role in developing compliance with the
equipment leak regulations.  The inspector should also address issues such as proper
tagging of leaking equipment, performance of repairs within the allotted time, follow-
up monitoring  of repaired equipment, visual inspections, and recordkeeping practices to
document these activities.  The inspector should also become familiar with closed-vent
control devices at the facility and the equipment served by such devices.

       After several rounds of monitoring have been completed and the first one or two
periodic reports submitted, the inspector can relate his or her developed familiarity with
the facility to the information in these records and reports.  The inspector will be able
to identify those process areas and equipment types that are exhibiting higher than
average leak rates and may even be able to identify specific pieces  of equipment as
"chronic leakers."

       The next phase of inspection activities, beginning perhaps midway through the
second year of regulations, would begin to incorporate direct monitoring of
representative portions of selected process areas. Once again, developed familiarity
with the facility will aid  the inspector in selection of appropriate areas to be monitored.
Direct monitoring inspections can become an important part of inspection procedures
over the next several years, along with periodic observational inspections or walk-
throughs of larger portions of the facility.
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       Maintaining consistent documentation in the form of inspection reports and
associated notes will help to develop a consistent background file on the facility.  This
can be especially important as experienced inspectors are replaced by new personnel.
Ideally, one or two inspectors should be continuously assigned to the same facility or
group of facilities and should be responsible for the full range of air related permits and
emission control programs at those facilities.  This will help to reinforce a fuller
understanding of the facilities and will also broaden the range of regulatory expertise
among the individual inspectors. Additionally, if possible, a new inspector should
accompany a more experienced individual on several inspections for training.  Finally,
whenever feasible, experienced inspectors should accompany each other on inspections
of their respective facilities. This will help to expand the inspector's perspective by
exposing them to equipment leak programs at other facilities and will also help to
reinforce consistent monitoring and inspection techniques among the inspection staff.

       A final, optional phase of inspection activities would be to conduct
comprehensive monitoring inspections of individual facilities.  This would involve two
or three inspectors visiting a facility for several days to conduct complete monitoring of
selected process areas and/or representative portions of larger process areas.  Such
inspections could be patterned after the in-depth inspections of the NEIC. Facility
personnel would accompany the inspectors and conduct side-by-side monitoring of
selected process areas. These comprehensive monitoring inspections could accomplish
three purposes:  (1) evaluate and compare the extent to which the facilities are
accomplishing the emission reduction objectives of the regulations, (2) evaluate the
effectiveness of the agency's inspection program, and (3) provide a basis for
documenting noncompliance in the form of under-reporting of leak rates at individual
facilities.  As a long-term program, comprehensive monitoring inspections could be
performed on all facilities or a subset of facilities within an agency's jurisdiction on a
cycle of once every four or five years.  Additionally, comprehensive inspections could
be performed at individual facilities whenever such action is necessary.
5.2    WORKING WITH REGULATED FACILITIES

       Over the long term, a successful inspection and regulatory enforcement program
for the equipment leak regulations is more likely to succeed if the inspector can develop
a cooperative working relationship with the regulated facilities.  Such a relationship will
make it easier for the  inspector to obtain information about the facility in the form of
reformatted or supplemental reports and other information not specifically identified by
the recordkeeping requirements.  The inspector may also find it easier to elicit verbal
information about planned changes or developments within the facility which can be
useful to the planning effort for future inspections. In exchange, the inspector may be
able to assist the regulated facility by providing information or assistance helpful to the
facility's development of a successful equipment leak program.  Such a relationship can

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therefore improve the probability that enforcement of the equipment leak regulations
will contribute to effective and long-term reductions of this class of emissions.

       The issue of component monitoring technique is a particularly important area in
which the inspector can potentially contribute assistance.  Facility personnel or
contractors responsible for monitoring may feel inclined to complete the monitoring of
as many components as possible  within a limited amount of time. This emphasis on
speed and efficiency may result in a decline in monitoring technique, with personnel
moving their analyzers too quickly over the equipment or not holding the probe tip
close enough to those points where leaks are likely to occur.  As previously discussed,
the inspector can review and critique the monitoring technique of plant personnel or
engage in side-by-side monitoring with the personnel.  This creates an opportunity for
the inspector to demonstrate correct monitoring techniques and can improve the
probability that reported leak rates  accurately reflect conditions at the facility.

       Collaboration in the area  of monitoring technique can be taken one step further
by making agency training available to monitoring personnel from the regulated
facilities.  Shared training further reinforces the objective of getting the facilities to
practice appropriate monitoring techniques and may also contribute to cost savings for
both the agency and the facilities with respect to training costs. For example, the South
Coast Air Quality Management District (SCAQMD) has found shared training to be a
successful approach.  The SCAQMD is planning to expand their program to include
certification of facility monitoring personnel.

       As an inspector develops  experience with equipment leak programs and learns
more about how other facilities are developing their programs, the inspector may be
able to offer additional assistance or advice in a number of areas. An inspector can
develop such experience from accompanying other inspectors to other facilities, and
through long-term observation of different approaches within facilities assigned to the
inspector. If one or two facilities within an agency's jurisdiction are achieving
exceptional success with their leak minimization programs, an inspector can inform
other facilities of such accomplishments and encourage information sharing between the
facilities.  An inspector may also be aware of additional potential resources, such as
trade associations, that may be a source of help to a facility.

       Some of the approaches used by successful facilities include in-plant oversight
of monitoring procedures, use of internal leak standards, innovative component tracking
systems, use of advanced repair systems and materials, and installation of new
equipment with improved leak minimization performance.

       In-plant oversight of monitoring involves the application of quality assurance
techniques to the equipment monitoring and leak reporting activities.  Some facilities
that employ subcontractors have  found it advantageous to obtain analyzer instruments

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and train one or two plant personnel to provide oversight and backup to the contract
monitoring service.  By developing an in-house monitoring capability, the facility is
better able to identify and correct any deficiencies in the contractor's performance. As
a backup resource, the in-house personnel are most valuable as a means of assuring
appropriate follow-up monitoring and reporting of repaired equipment.

       Although most contract monitoring services provide a database and
recordkeephig system as part of then: package, some facilities prefer to develop an
internal system. This allows for faster acquisition of reports, enables report formats to
be modified, addresses some issues of confidentiality, and creates the opportunity to
incorporate the monitoring and recordkeeping systems in the development of additional
program elements.

       Facilities that perform their own monitoring cite a number of factors which
reinforce their commitment to this approach.  Having plant-wide in-house monitoring
capabilities permits the establishment and maintenance of higher performance standards
and allows for greater flexibility in the utilization of monitoring resources. This
flexibility can be applied to leak testing equipment during process repair and
maintenance  activities, during startup after a process shutdown, and for spot-checking
suspect equipment without waiting for the routine monitoring schedule.

       Internal plant standards refer to a potentially broad range of activities designed
to ensure compliance by doing  more than the minimum requirements of the regulations.
Some plants will repair equipment before applicable leak rate definitions are exceeded
(e.g., conduct an initial repair procedure on any equipment leaking at 5,000 ppm or
more when the leak definition is 10,000 ppm) Other strategies include supplemental
monitoring as described previously, replacement of equipment which continues to leak
after two or more attempts at repair, and repair of equipment which could be classified
as non-repairable.  In a related approach, many facilities have incorporated
environmental compliance, waste minimization, pollution prevention, and similar goals
within the context  of total quality management programs or other production quality
initiatives.

       Component tracking addresses the utilization of repetitive monitoring data to
evaluate the long-term performance of equipment.  This can include the identification of
equipment  which leaks chronically or performance comparisons of alternative
components within a process area. The increased sophistication and flexibility of
internalized databases and recordkeeping systems lends support to the utilization of
component tracking strategies.

       Equipment leak regulations have been in effect at some facilities for a number of
years. Efforts to minimize equipment leaks have contributed to advances in repair
techniques  and materials and to development of new equipment with improved leak

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minimization performance. Improved repair techniques have greatly expanded the
number and types of equipment which can be repaired in place, without a process
shutdown.  Improved component materials such as specialty gaskets can improve the
performance and extend the life of existing equipment.  Finally, the design of new
processes or reconstruction of existing process areas can incorporate leak minimization
efforts by reducing the number of valves, flanges, and other connectors within the
process system.

       The leak standards and other specified control strategies within the HON are a
reflection of the achievable standards resulting from the improved equipment, repair
techniques, and information management strategies summarized above.  Additionally,
the QIP provisions of the HON are based on leak minimization programs that have
worked for other facilities in the past. Although not formally required until Phase ffl,
an inspector might suggest that facilities implement QIP plans or an in-house equivalent
early on as a means of improving their opportunities to meet compliance with the
standard.
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                            BIBLIOGRAPHY
1.   EPA/625/R-93/005. Control Techniques for Fugitive VOC Emissions from
     Chemical Process Facilities (March 1994).

2.   EPA-625/10-84-004.  Fugitive VOC Emissions in the Synthetic Organic
     Chemicals Manufacturing Industry.

3.   EPA-6QO/7-82-063. Evaluation of Potential VOC Screening Instruments
     (November).  NTIS PB83-139733.

4.   EPA-6QO/2-81-110, Response of Portable VOC Analyzers to Chemical Mixtures,
     Chemical Process Branch (June 1981).  NTIS PB81-234262.

5.   EPA-60Q/2-81-080. Evaluation of Maintenance for Fugitive VOC Emissions
     Control (May).  NTIS PBS 1-206005.

6.   EPA-600/2-91-051. Response Factors for VOC Analyzers at a Meter Reading of
     10,000 PPMV for Selected Organic Compounds. NTIS PB81-234817.

7.   EPA-600/2-81-022. Response Factors of VOC Analyzers Calibrated with
     Methane for Selected Organic Compounds (November). NTIS PB81-182339.

8.   EPA-600/2-81-003. Problem-Oriented Report: Frequency of Leak Occurrence
     for Fittings in Synthetic Organic Chemical Plan Process Units. NTIS PB81-
     141566.

9.   EPA-600/2-80-075d.  Assessment of Atmospheric Emissions from Petroleum
     Refining: Volume 4, Appendix C, D, E (July). NTIS PB81-103830.

10.   EPA-600/2-80-075c. Assessment of Atmospheric Emissions from Petroleum
     Refining: Volume 3, Appendix B (April).  NTIS PB80-225279.

11.   EPA/453/R-93/026. Protocol for Equipment Leak Emission Estimates (June
     1993).
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12.   EPA-450/4-92-012. Method 21 Evaluation for the HON (90-ME-07).

13.   EPA-450/3-92-001a-draft. VOC/VHAP Emissions from Marine Vessel Loading
     Operations, Technical Support Document for Proposed Standards (May 1992).

14.   EPA-45Q/3-90-019. Polymer Manufacturing Industry-Enabling Document
     (December)., NTIS PB91-161745.

15.   EPA-450/3-89-009. Hazardous Waste Treatment, Storage and Disposal Facilities:
     Background Information for Promulgated Organic Emission Standards from
     Process Vents and Equipment Leaks (June).  NTIS PB90-252503.

16.   EPA-450/3-88-010. Protocols for Generating Unit-Specific Emission Estimates
     for Equipment Leaks of VOC and VHAP, Emission Standards Division (October
     1998). NTIS PB89-138689.

17.   EPA-450/3-86-002, Emission Factors for Equipment Leaks of VOC and HAP
     (1986). NTIS PB86-171527.

18.   EPA-450/3-83-019a, Polymer Manufacturing Industry: Background Information
     for Proposed Standards (September).  NTIS  PB88-114996.

19.   EPA-450/3-83-007. Control of VOC Equipment Leaks from Natural
     Gas/Gasoline Process Plants, Guideline Series (December 1983). NTIS PB84-
     161520.

20.   EPA-450/3-83-006. Control of VOC Leaks from Synthetic Organic Chemical and
     Polymer Manufacturing Equipment, Guideline Series (March 1984).  NTIS PB84-
     189372.

21.   EPA-450/3-82-024a. Equipment Leaks of VOC in Natural Gas Production
     Industry: Background Information for Proposed Standards (December).  NTIS
     PB84-155126.

22.   EPA-450/2-82-105. Controlling VOC Emissions from Leaking Process
     Equipment, Student Guidebook for APTI Course SI:417 (August 1992).

23.   EPA-450/3-82-010. Fugitive Emission Sources of Organic Compounds:
     Additional Information on Emissions, Emission Reductions, and Costs (1982).
     NTIS PB82-217126.

24.   EPA-450/3-82-003. Vinyl Chloride:  First Review of National Emission
     Standards (March). NTIS PB84-114354.

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25.  EPA-450/3-81-015a. VOC Fugitive Emissions in Petroleum Refining Industry:
     Background Information for Proposed Standards, Emission Standards, and
     Engineering Division (November 1982). NTIS PB83-157743.

26.  EPA-450/3-*80-033a. VOC Fugitive Emissions in the Synthetic Organic
     Chemicals Manufacturing Industry:  Background Information for Proposed
     Standards (November). NTIS PB81-152167.

27.  EPA-450/3-80-033b. VOC Fugitive Emissions in the Synthetic Organic
     Chemicals Manufacturing Industry:  Background Information for Promulgated
     Standards (June). NTIS PB84-105311.

28.  EPA-450/3-80-032a. Benzene Fugitive Emissions:  Background Information for
     Proposed Standards (November).  NTIS PB82-151664.

29.  EPA-450/3-80-032b. Benzene Fugitive Emissions:  Background Information for
     Proposed Standards (June).  NTIS PB84-210-301.

30.  EPA-450/2-78-041. Measurement of VOCs, Guideline Series (September 1979).

31.  EPA450/2-78-036, Control of VOC Leaks from Petroleum Refinery Equipment,
     Guidelines Series (June 1978). NTIS PB82-6158.

32.  EPA-340/1-91-013. NSPS for VOC Emissions from Petroleum Wastewater
     Systems, Inspection Manual (September 1991).

33.  EPA-340/l-90-026a. Inspection Techniques for Fugitive VOC Emission Sources:
     Course Module S380, Student's Manual (September).

34.  EPA-340/l-9Q-026b. Inspection Techniques for Fugitive VOC Emission Sources:
     Course Module S380, Lecturer's Manual (1990).

35.  EPA-340/1-86-015. Portable Instruments User's Manual for Monitoring VOC
     Sources, Stationary Source Compliance Series  (June 1986). NTIS PB90-218611.

36.  EPA-340/1-80-008. Petroleum Refinery Enforcement Manual, Stationary Source
     Enforcement Series (March 1980).

37.  EPA-340/1-77-005. Inspection Manual for the Enforcement of NSPS:  Volatile
     Hydrocarbon Storage Tanks, Stationary Enforcement Series (April 1977).
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38.  Inspection Manual for Enforcement of NSPS; Equipment Leaks in SOCM,
     Petroleum Refineries, Onshore Natural Gas Processing Plants.  Class Notebook.
     Prepared for EPA by Radian (September 1990).

39.  EPA Preliminary Draft.  Control of VOCs from VOL Storage in Floating and
     Fixed Roof Tanks (January 1981).

40.  EMTIC BBS, File No. FNL-RPT.W51.  Survey of Portable Analyzers for the
     Measurement of Gaseous Fugitive Emissions.

41.  HON Leak Inspection Manual (Draft), U.S. EPA Region 5  (May 17, 1995).

42.  A Guide to the Inspection of Petroleum Refineries for Compliance with Air
     Pollution Regulations, Compliance Assistance Program, California Environmental
     Protection Agency, Air Resources Board, Compliance Division (July 1994).

43.  Fugitive Emissions of Volatile Organic Compounds, Volume 1 Operator's
     Handbook, South Coast Air Quality Management District, Diamond Bar, CA
     (March 1992).

44.  Fugitive Emissions of Volatile Organic Compounds, Volume 2 Operator's
     Handbook, South Coast Air Quality Management District, Diamond Bar, CA
     (March 1992).

45.  API Publication 2517. Evaporative Loss from External Floating Roof Tanks
     (February 1989).

46.  Examples of Emission Estimate Reports from SOCMI Leaks, Team, Inc. (1990).

47.  Fugitive Emission Experience Based on Numerous Emission Estimation Studies,
     Team, Inc. (1990).

48.  "Fugitive Emission Reg. Change." Pollution Engineering. December 1991.

49.  Hydrocarbon Emissions from Gasoline Storage and Distribution Systems,
     CONCAWE (December 1978).

50.  "Implementing Options for MACT Standards for Emissions  from Leaking
     Equipment," PNWIS-AWMA annual meeting (June 1991).

51.  "Leakless Valves: A Control Technology for Reducing Fugitive Emissions?,"
     PNWIS-AWMA annual meeting (June 1991).
                                     6-4

-------
52,  NWAPA Reg. Summary on VOC Control at Refineries.

53.  NWAPA Report to Board (1989); includes Reduction Summary.

54.  Nelson, W.E., "Compressor Seal Fundamentals." Hydrocarbon Processing.
     56(12):91-95, December 1977.

55.  Pikulik, A. "Manually Operated Valves." Chemical Engineering. 85(7): 121, pp.
     3-23, 3-24.  April 3, 1978.

56.  Ramsden, J.H.  "How to Choose and Install Mechanical Seals." Chemical
     Engineering. 85(22):97-102. October 9, 1978.

57.  Ramsey, W.D. and G.C. Zoller. "How the Design of Shafts, Seals and Impellers
     Affects Agitator Performance." Chemical Engineering. 83(18): 101-108.  August
     30, 1976.

58.  Templeton, H.C.  "Valve Installation, Operation and Maintenance."  Chemical
     Engineering. 78(23): 141-149.  October 11, 1971.
                                     6-5

-------
&EPA
            United States
            Environmental Protection
            Agency	
           Enforcement and
           Compliance Assurance
           (2224A)	
EPA/305/B-98/011
December 1998
Inspection Manual:
Federal Equipment Leak
Regulations for the
Chemical Manufacturing
Industry
Volume II: Chemical
Manufacturing Industry
Regulations
                      EPA Office of Compliance
                      Chemical, Commercial
                      Services, and Municipal
                      Division

-------

-------
ABSTRACT
The purpose of this manual is to enhance an inspector's ability to conduct more
complete and effective inspections at facilities in the chemical industry that are subject
to federal equipment leak regulations. Equipment leak standards are designed to reduce
or eliminate emissions of volatile organic compounds  (VOCs), volatile hazardous air
pollutants (VHAPs), and organic HAPs from the miles of piping and numerous
components found in chemical manufacturing processes.

This document is divided into three volumes. The first volume is a manual for
inspectors;  the second and third volumes describe regulations that apply to the chemical
manufacturing and the petroleum refining industries, respectively.

Volume I has five chapters dedicated to helping an inspector:
   •   Chapter 1 states the goals, background, approaches to rale enforcement, and
       organization of the document.
   •   Chapter 2 addresses applicability determinations: ensuring the correct rules are
       being complied with at a  facility, determining whether all appropriate
       components have been identified, and ensuring the components are properly
       classified by service.
   •   Chapter 3 discusses reporting and recordkeeping requirements for NSPS,
       NESHAP, HON, and RCRA (recordkeeping only), and strategies for reviewing
       reports and records.
   •   Chapter 4 covers on-site inspections: walk-throughs and inspections with the
       inspector monitoring for leaks. It addresses pre-inspection activities, timing and
       scope, interviews, leak monitoring evaluations, inspections of the process area
       and  records, and post-inspection  reviews and reports.
   »   Chapter 5 discusses recommended inspection techniques and procedures.

Volume II tackles the equipment leak regulations applicable to the chemical
manufacturing industry.
   «   The first three appendices of Volume n summarize the regulations of 40 CFR
       Part 60 Subpart W,  Part 61 Subparts J and V, Part 63 Subparts H and I, Part
       264  Subpart BB, and Part 265 Subpart BB; detail the differences among the
       regulations; and give the  requirements grouped by component.
   •   Appendix D describes the regulated equipment.
   •   Appendix E contains the  "Method 21" approach to leak detection.
   »   Appendix F lists chemical manufacturing processes that are subject to HON.
   •   Appendix G lists organic HAPs that are subject to HON.
   •   Appendix H lists manufacturing processes and associated organic HAP
       emissions that are subject to HON.

-------
Volume HI contains the equipment leak regulations applicable to the petroleum refining
industry.
   *  The three appendices of Volume DI summarize the regulations of 40 CFR Part
      60 Subparts DDD, GGG, KKK, and QQQ, and Part 63 Subpart CC; detail the
      differences among the regulations; and give the requirements grouped by
      component.

-------
CONTENTS
VOLUME II: CHEMICAL MANUFACTURING INDUSTRY REGULATIONS

                                                             Page
Appendix A Equipment Leak Regulations: Side-by-Side Comparisons .. . A-l

Appendix B Equipment Leak Regulations: Summary of Differences  .... B-l

Appendix C Equipment Leak Regulations: Summary by Component .... C-l

Appendix D Regulated Equipment	D-l

Appendix E Method 21 (40 CFR 60, Appendix A)	E-l

Appendix F Chemical Manufacturing Processes Subject to HON
           Standards (40 CFR 63, Subpart H)		F-l

Appendix G Organic HAPs Subject to HON Standards (Subpart H)	G-l

Appendix H Manufacturing Processes and Organic HAPs Subject to
           HON Standards (Subpart I)	H-l

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CONTENTS (continued)
VOLUME I: INSPECTION MANUAL
Chapter 1

Chapter 2
Chapter 3
Chapter 4
Chapter 5
Bibliography
Statement of Goals, Background, Approaches to Rule
Enforcement, and Organization of Document
Applicability
Compliance/Inspection Through Reports and Recordkeeping
Compliance/Assessment Through On-Site Inspections
Recommended Inspection Techniques and Procedures
VOLUME HI: PETROLEUM REFINING INDUSTRY REGULATIONS

Appendix A  Equipment Leak Regulations: Side-by-Side Comparisons
Appendix B  Equipment Leak Regulations: Summary of Differences
Appendix C  Equipment Leak Regulations: Summary by Component

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                                 APPENDIX A

       EQUIPMENT LEAK REGULATIONS: SIDE-BY-SIDE COMPARISONS

                                                                          page
GENERAL ASPECTS OF RULE
Applicability	,	   A-l
Exemptions 	   A-2
Definitions	   A-2
Equipment Identification	   A-5
Compliance Demonstrations  	   A-5
Method of Compliance Determination	 A-6
Requirements When More than One Standard Applies	A-6

SPECIFIC COMPONENT SUMMARIES
Valves, Gas/Vapor or Light Liquid Service		   A-7
Valves, Heavy Liquid Service	A-10
Alternative Standards for Valves	,	  A-ll
Pumps, Light Liquid Service	A-13
Pumps, Heavy Liquid Service 	A-15
Pressure Relief Devices, Gas/Vapor Service	  1	A-17
Pressure Relief Devices, Light Liquid or Heavy Liquid Service 	A-l8
Compressors   	A-19
Sampling Connections Systems	A-21
Open-Ended Valves or Lines	A-22
Flanges and Connectors (All Services)	A-23
Connectors, Gas/Vapor or Light Liquid Service	A-24
Connectors, Heavy Liquid Service	A-26
Agitators, Gas/Vapor Service or Light Liquid Service	A-27
Agitators, Heavy Liquid Service	A-30
Instrumentation Systems	A-31
Product Accumulator Vessels	A-32
Surge Control Vessels and Bottoms Receivers	A-33
Closed-Vent Systems and Control Devices	A-34

DELAY OF REPAIR	A-37

QUALITY IMPROVEMENT PROGRAMS	  ...  A-39

EQUIVALENCE  OF (or ALTERNATIVE) MEANS OF EMISSIONS LIMITATION
General	A-45
Batch Processes	A-46

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Enelosed-Vented Process Units	A-48




TEST METHODS AND PROCEDURES	A-49




RECORDKEEPING REQUIREMENTS	A-54




REPORTING REQUIREMENTS	A-67

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SUMMARY OF REGULATIONS
page A-l

General Aspects of Rule




APPLICABILITY




















REGULATION

40 CFR part 60,
Subpart VV


All equipment within a
process unit in the
synthetic organic
manufacturing industry that
commences construction,
reconstruction, or
modification after 1/5/81.

A list of SOCMI chemicals
produced as intermediates
or final products by
process units is provided to
determine applicability.









40 CFR part 61,
Subpart J


Equipment that is operated
in, benzene service.




















40 CFR part 61,
Subpart V


Equipment operated in
volatile HAP (VHAP)
service after the date for
which part 61 regulations
have been promulgated.

















40 CFR part 63,
Subpart H


Equipment in organic HAP
service operated at least
300 hours per year at
facilities for which part 63
regulations have been
adopted and that cross-
reference this subpart.

A list of organic HAP is
provided to determine
applicability.











40 CFR part 63,
Subpart I


Equipment in organic HAP
service (see Definitions)
operated at least 300 hours
per year in the following
types of processes: Styrene-
butadiene rubber production;
polybutadiene rubber
production; processes
producing five specific
agricultural chemicals;
processes producing six
specific types of
polymers/resins or other
chemicals; pharmaceutical
processes using carbon
tetrachloride or methylene
chloride; and five specified
polymers/resins."
Specific HAPs are
designated for determining
applicability,

40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
Equipment at facilities that
treat, store, or dispose of
hazardous wastes that
contains or contacts,
hazardous waste with
organic concentrations of at
least 10 percent by weight
that are managed in units
subject to the permitting
requirements of part 270 or
hazardous waste recycling
units located at such
facilities otherwise subject
to the permitting
requirements of part 270,







-------
SUMMARY OF REGULATIONS
page A-2

General Aspects of Rule




EXEMPTIONS


























DEFINITIONS
"In gas/vapor service"




"In heavy liquid
service"

REGULATION

40 CFR part fiO,
Subpart VV


Any affected facility with
design capacity to produce
less than l.OOOMgper
year.

Any affected facility that
produces heavy liquid
chemicals only from heavy
liquid feed or raw
materials.

Any affected facility that
produces beverage alcohol.

Any affected facility that
has no equipment in VOC
service. (Must maintain
certain records
demonstrating exemption
applies.)








The piece of equipment
contains process fluid that
is in gaseous state at
operating conditions.

The piece of equipment is
not in gas/vapor service or
in light liquid service.

40 CFR part 61.
Subprt I


Coke by-product plants.

Any equipment in benzene
service located at plant
designed to produce or use
less than 1, 000 Mg of
benzene per year.

Any process unit thai has
no equipment in benzene
service.

Exempt from part 60 if
subject to part 61.














40 CFR part 61,
SubpartV


None specified.



























A piece of equipment contains process fluid that is in the
gaseous state at operating conditions.



Not applicable.



40 CFR part 63,
SubpartH


Research and development
facilities.

Exempt from part 60 and
from part 6! if provisions
of Part 63 are effective.

Petroleum refining process
units.

Ethylene process units.

Equipment subject to
subpart which does not
emit HAPs.

CMPUs located at coke
by-product recovery
plants.

Solvent reclamation,
recovery, or recycling
operations at hazardous
waste TSDFs that require a
40 CFR part 270 permit
that are not part of a
SOCMI CMPU.

40 CFR part 63,
Subprt I


Facilities that do not have
the designated HAP(s) need
only document the basis for
this determination.

Research and development
facilities.

Exempt until no later than
April 22, 1997, If plant site
emits less than 10 tpy of any
individual HAP and less
than 25 tpy of any
combination of HAP.














A piece of equipment in organic hazardous air pollutant
(HAP) service contains a gas or vapor at operating
conditions.


A piece of equipment in organic HAP service is not in
gas/vapor service or in light liquid service.


40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpan BB
None specified.



























The piece of equipment
contains or contacts a
hazardous waste stream that
is in the gaseous state at
operating conditions.
The piece of equipment is
not in gas/vapor service or
iu light liquid service.

-------
SUMMARY OF REGULATIONS
page A-3

General Aspects of Rule




DEFINITIONS
(continued)
"In light liquid service"


















"In liquid service"

"In VOC service"




"In VHAP service"


REGULATION

40 CFR part 60,
Subpari VV




The piece of equipment
contains a liquid that meets
the following conditions:

1. The vapor pressure of
one or more of the
components is greater than
0.3kPaat20°C;

2. The total concentration
of pure components having
a vapor pressure greater
thanG.3kPaat20°Cis
equal to or greater than 20
percent by weight; and

3. The fluid is a liquid at
operating conditions.

Not applicable.

The piece of equipment
contains or contacts a
process fluid that is at least
10 percent VOC by
weight.
Not applicable.



40 CFR part 61 , .40 CFR part 61 ,
Subprt J Subpart V




Not applicable.


















A piece of equipment is not in gas/vapor service.

The piece of equipment contains or contacts a process
fluid that is at least 10 percent VOC by weight and the
piece of equipment is not in heavy liquid service (as
defined under 40 CFR part 60, subpart VV).
.•
A piece of equipment either contains or contacts a fluid
(liquid or gas) that is at least 10 percent by weight a
volatile hazardous air pollutant (VHAP),

40 CFR part 63, 40 CFR part 63,
Subpart H Subpart I




A piece of equipment in organic HAP service contains a
liquid that meets the following conditions:

1 , The vapor pressure of one or more of the organic
compounds is greater than 0.3 kPa at 20°C;

2. The total concentration of the pure organic compounds
having a vapor pressure greater than 0.3 kPa at 20*C is
equal to or greater than 20 percent by weight of the total
process stream; and

3. The fluid is a liquid at operating conditions.







A piece of equipment in organic HAP service is not in
gas/vapor service.
The piece of equipment contains or contacts a process fluid
that is at least 10 percent VOC by weight and the piece of
equipment is not in heavy liquid service (as defined under
40 CFR part 60, subpart VV).

Not applicable.



40 CFR part 264,
Subprt BB
40 CFR part 265,
Subpart BB _


The piece of equipment
contains or contacts, a waste
stream that meets the
following conditions;

1 . The vapor pressure of
one or more of the
components is greater than
0.3kPaat20°C;

2, The total concentration
of pure components having
a vapor pressure greater
than0.3kPaat20"Cis
equal to or greater than 20
percent by weight; and

3. The fluid is a liquid at
operating conditions.
Not applicable.

Not applicable.




Not applicable.



-------
SUMMARY OF REGULATIONS
pageA-4
General Aspects of Rule
DEFINITIONS
(continued)
"In organic hazardous
air pollutant or in
organic (HAP) service"
"In benzene service"
Equipment
Process Unit (hazardous
waste management unit
for 40 CFR parts 264
and 265)
REGULATION
40 CFR part 60,
Subpart VV
Not applicable.
Not applicable.
Each pump, compressor,
pressure relief device,
sampling connection
system, open-ended valve
or line, valve, and flange
or other connector in VOC
service and any devices or
systems required by this
subpart.
Components assembled to
produce, as intermediate or
final products, one or more
of the chemicals specified
in §60,489. A process unit
can operate independently
if supplied with sufficient
feed or raw materials and
sufficient storage facilities
for the product.
40CFRptrt61,
Subpart I
40 CFR part 61,
Subpart V
Not applicable.
A piece of equipment
contains or contacts a fluid
(liquid or gas) that is at
least 10% benzene by
weight.
Not applicable.
Bach pump, compressor, pressure relief device, sampling
connection system, open-ended valve or line, valve, flange
or other connector, product accumulator vessel in VHAP
service, and any devices or systems required by this
subpart.
Equipment assembled to produce a VHAP or its
derivatives as intermediate or final products, or equipment
assembled to use a VHAP in the production of a product.
A process unit can operate independently if supplied with
sufficient feed or raw materials and sufficient product
storage facilities.
40 CFR part 63,
SubpartH
A piece of equipment
either contains or contacts
a fluid (liquid or gas) that
is at least 5 percent by
weight total organic HAP.
40 CFR part 63,
Subpartl
A piece of equipment either
contains or contacts a fluid
(liquid or gas) that is at least
5 percent by weight of the
designated organic HAP
listed in §63.190(b) of this
subpart.
Not applicable.
Each pump, compressor, agitator, pressure relief device,
sampling connection system, open-ended valve or line,
valve, connector, surge control vessel, bottoms receiver,
and instrumentation system in organic HAP service, and
any devices or systems required by this subpart.
A chemical manufacturing process unit as defined in
subpart F of this part, a process unit subject to the
provisions of subpart I of this part, or a process unit subject
to another subpart in 40 CFR part 63 that references this
subpart,11
40 CFR part 264,
Subprt BB
40 CFR pan 263,
Subpart BB
Not applicable.
Not applicable.
Bach valve, pump,
compressor, pressure relief
device, sampling connection
system, open-ended valve or
line, or flange or any
devices or systems required
by this subpart.
A contiguous area of land
on or in which hazardous
waste is placed, or the
largest area in which there
is significant likelihood of
mixing hazardous waste
constituents in the same
area."

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SUMMARY OF REGULATIONS
page A-5

General Aspects of Rule




DEFINITIONS
(concluded)
Repaired










FirstAttempt at Repair





EQUIPMENT
IDENTIFICATION
(see also Recordkeeping
• Requirements)
COMPLIANCE
DEMONSTRATIONS










REGULATION

40 CFR part 60,
Subpart W




Equipment is adjusted, or
otherwise altered, in order
to eliminate a leak as
indicated by one of the
following: an instrument
reading of 10,000 ppm or
greater, indications of
liquids dripping, or
indication by sensor that a
seal or barrier fluid has
failed.
To take rapid action for the
purpose of stopping or
reducing leakage of
organic material to
atmosphere using best
practices.
Not specified.



Performance test required
for all equipment within
180 days of initial startup.










40 CFR part 61 , 40 CFR part 61,
Subpart J Subpart V




Equipment is adjusted, or otherwise altered, to eliminate a
leak.









To take rapid action for the purpose of stopping or
reducing leakage of organic material to atmosphere using
best practices.



Marked in manner such that it can be readily distinguished
from other pieces of equipment.


Performance test required for all equipment within 180
days of initial startup.

For existing sources, shall be in compliance within 90
days after the effective date of the applicable-standard.





For new sources, shall be in compliance upon effective
date of the applicable standard.

40 CFR part 63, 40 CFR part 63,
Subpart H Subpart I




Equipment is adjusted, or otherwise altered, to eliminate a
leak as defined in the applicable sections of this subpart and
unless otherwise specified in the applicable provisions of
this subpart, is monitored to verify that emissions are below
the applicable leak definition.






To take action for the purpose of stopping or reducing
leakage of organic material to atmosphere followed by
monitoring to verify that the leak is repaired unless the
owner or operator determines by other means that the leak
is not repaired.

Marked in manner such that it can be readily distinguished
from equipment not subject to this subpart (does not require
physical lagging except for leaking equipment).

Performance test required within 180 days of initial startup.


For existing sources, shall be in compliance no later than
(he following dates:
Group I: October 24, 1994
Group II: January 23, 1 993
Group III: April 24, 1995
Group IV: July 24, 1995
Group V: October 23, 1995
For new sources, shall be in compliance upon initial
startup, or the effective date of the applicable standard.

40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB _


Equipment is adjusted, or
otherwise altered, to.
eliminate a leak.








To take rapid action for the
purpose of stopping or
reducing leakage of organic
material to atmosphere
using best practices.

Marked in manner such that
it can be readily
distinguished from other
pieces of equipment.
Not specified.












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                                                                            SUMMARY OF REGULATIONS
page A-6
General Aspects of Rule
METHOD OF
COMPLIANCE
DETERMINATION
REQUIREMENTS
WHEN MORE THAN
ONE STANDARD
APPLIES
REGULATION
40CFRpart60,
Subpart VV
Review of records and
reports, review of
performance test results,
and inspections.
Not specified.
40CPRpart6l,
Subpart J
40 CPR part 61,
Subpart V
Review of records, review of performance test results,
and inspections.
A source subject to this
subpart that is also subject
to 40 CFR part 60 only
will be required to comply
with the provisions of this
subpart.
A source subject to this
subpart that is also subject
to 40 CFR part 60 only
will be required to comply
with the provisions of this
subpart.
40 CPR part 63,
Subpart H
40 CFR part 63,
Subpart I
Review of records and reports, review of performance test
results, and inspections.
Equipment subject to this subpart that are also subject to 40
CFR part SO or 40 CFR part 61 will be required to comply
only with the provisions of this subpart.
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
Not specified.
Any facility subject to this
subpart and 40 CFR part
60, subpart VV or 40 CFR
part 61 , subpart V, may
elect to comply with this
subpart or the provisions in
part 60 or 61 to the extent
that the documentation
under the regulation at part
60 or part 61 duplicates the
documentation required
under this subpart.
" Processes producing styrene-butadiene rubber (butadiene and styrene emissions only).  Processes producing polybutadiene rubber (butadiene emissions only). Processes producing the following agricultural chemicals
(butadiene, carbon tetrachloride, methylene chloride, and ethylene dichloride emissions only): Captafol (R); Captan (R); Chlorothalonil; Dacthal; and Tordon (R) acid. Processes producing the following polymers/resins
and other chemicals (carbon tetrachloride, methylene chloride, tetrachloroethylene, chloroform, and ethylene dichloride emissions only):  Hypalon (R); Oxybisphenoxarsine/l,3-diisocyanate [OBPA (R)]; polycarbonates;
polysulfide rubber; chlorinated paraffins; and symmetrical tetrachloropyridine.  Pharmaceutical production processes using carbon tetrachloride or methylene chloride (carbon tetrachloride and methylene chloride emissions
only).  Processes producing the following polymers/resins and other chemicals (butadiene emissions only):  tetrahydrophthalic anhydride (THPA); methlymethacrylate-butadiene slyrene resins (MBS); butadiene-furfural cotrimer;
methlymethacrylate-acrylonitrile-butadiene-sryrene (MABS) resins; and ethylidene norbornene.


* "Chemical manufacturing process unit" means the equipment assembled and connected by pipes or ducts to process raw materials and to manufacture an intended product, A CMPU consists of more than one unit operation.
For the purposes of this subpart, chemical manufacturing process unit includes air oxidation reactors and their associated product separators and recovery devices; reactors and their associated product separators and recovery
devices; distillation units and their associated distillate receivers and recovery devices; associated unit operations (as defined in this section) and associated recovery devices; and any feed, intermediate, and product storage
vessels, product transfer racks, and connected ducts and piping. A chemical manufacturing process unit includes pumps, compressors, agitators, pressure relief devices, sampling connection systems, open-ended valves or
lines, valves, connectors, instrumentation systems, and control devices or systems. A chemical process manufacturing unit is identified by its primary product.
c Examples of hazardous waste management units include a surface impoundment, a waste pile, a land treatment area, a landfill cell, an incinerator, a tank and its associated piping and underlying containment system and
a container storage area.  A container alone does not constitute a unit; the unit includes containers and the land or pad upon which they are placed.

-------
                                                                     SUMMARY OF REGULATIONS
                                                                                                                                                             page A-7
  Specific
 Component
 Summaries
                                                                                         REGULATION
            40 CFR part 60,
              Subpart VV
  40 CFR part 61,
     Subpart J
40 CFR part 61,
   Subpart V
40 CFR part 63,
   Subpart H
40 CFR part 63,
   Subpart I
40 CFR part 264,
   Subpart BB
40 CFR part 265,
   Subpart BB
VALVES, GAS/VAPOR OR LIGHT LIQUID SERVICE
   Standards
Monitor monthly.

After two consecutive months of no leaks, a
valve may be monitored quarterly.

If leak, detected, monitor valve monthly until
leak is not detected for two consecutive
months.
Monitor monthly,

After two consecutive months of no leaks, a
valve may be monitored quarterly.

If leak detected, monitor valve monthly until
leak is not detected for two consecutive
months.
                  In Phases I and II, monitor each valve
                  quarterly.

                  In Phase III, monitoring frequency based on
                  percent valves found leaking:
                                                                                                  Percent Leaking

                                                                                                      > 2
                                                                                                      <2
                                                                                                      < 1

                                                                                                      0.5
                                     Monitoring Frequency

                                     Monthly or implement a
                                     quality implementation
                                     plan (QIP)
                                     Quarterly
                                     Quarterly or once every
                                     2 quarters
                                     Quarterly or once every
                                     4 quarters
                                                                                                 (If >J.% leaking valves at a plant site with
                                                                                                 less than 250 valves in organic HAP service:
                                                                                                 monitor quarterly.)

                                                                                                 Existing Sources

                                                                                                 Phase I: begins on compliance date,

                                                                                                 Phase II:  begins no later than one year after
                                                                                                 the compliance date.

                                                                                                 Phase III;  begins no later than 2 1A years
                                                                                                 after the compliance date.
                                        Monitor monthly.

                                        After two consecutive months of no leaks, a
                                        valve may be monitored quarterly.

                                        If leak detected, monitor valve monthly until
                                        leak is not detected for two consecutive
                                        months.

-------
                                                                       SUMMARY OF REGULATIONS
                                                                                                                                                                  page A-8
   Specific
 Component
 Summaries
                                                                                             REGULATION
             40 CFR part 60,
               Subpart VV
   40CFRpart<51,
      Subpart J
40 CFR part 61,
   Subpart V
40 CFR part 63,
   Subpart H
40 CFR part 63,
   Subpart I
40 CFR part 264,
   Subptrt BB
40 CFR part 265,
   Subpart BB
VALVES. GAS/VAPOR OR LIGHT LIQUID SERVICE (conllnued)
   Standards
  (concluded)
                                                                                      New Sources   -

                                                                                      Phase I: this phase is not applicable.

                                                                                      Phase II:  begins upon facility startup,

                                                                                      Phase HI: begins no  later than one year after
                                                                                      initial startup.
        Leak
   Definition
10,000 ppm
 10,000 ppm
                   Phase I:   10,000 ppm
                   Phase II:    500 ppm
                   Phase III;    500 ppm
                                          10,000 ppm
      Repair
Repair as soon as practicable, no later than
15 calendar days after detection.

First attempt within 5 calendar days of
detection.
 Repair as soon as practicable, no later than
 15 calendar days after detection.

 First attempt within 5 calendar days of
 detection.
                   Repair as soon as practicable, no later than
                   15 calendar days after detection.

                   First attempt within 5 calendar days of
                   detection.

                   When repaired, monitor at least once within
                   first 3 months after repair.
                                          Repair as soon as practicable, no later than
                                          15 calendar days after detection.

                                          First attempt within 5 calendar days of
                                          detection.
First Attempt
    at Repair
    Practices
Best practices include, but are not limited to;
   -  tightening of bonnet bolts
   -  replacement of bonnet bolts
   -  tightening of packing gland nuts
   -  injection of lubricant into lubricated
      packing
 Best practices include, but are not limited
 to;
    - tightening of bonnet bolts
    - replacement of bonnet bolts
    - tightening of packing gland nuts
    - injection of lubricant into lubricated
	packing	'
                   Best practices include, but are not limited to;
                      -  tightening of bonnet bolts
                      -  replacement of bonnet bolts
                      -  tightening of poking gland nuts
                      -  injection of lubricant into lubricated
                         packing
                                          Best practices include, but are not limited to;
                                             - tightening of bonnet bolts
                                             - replacement of bonnet bolts
                                             - tightening of packing gland nuts
                                             - injection of lubricant into lubricated
                                               packing

-------
                                                                       SUMMARY OF REGULATIONS
                                                                                                                                                                 page A-9
  Specific
 Component
 Summaries
                                                                                            REGULATION
             40 CFR part GO,
               Subpart VV
  40 CFR part 61,
     Subpart J
40 CFR pan 61,
   Subpart V
40 CFR part 63,
   Subpart H
40 CFR part 63,
   Subpart I
40 CFR part 264,
   Subpart BB
40 CFR part 265,
   Subpart BB
VALVES, GAS/VAPOR OR LIGHT LIQUID SERVICE (concluded)
  Exemptions
Equipment in vacuum service.

"No detectable emissions" valves:  less than
500 ppm above background.

"Unsafe to monitor" valves: written plan to
monitor as frequently as practicable during
safe to monitor times.

"Difficult to monitor" valves:  written plan to
monitor at least once per year.  No more than
3.0 percent of valves in affected facility can
be designated as difficult to monitor.
Equipment in vacuum service.

"No detectable emissions" valves: less than
500 ppm above background.

"Unsafe to monitor" valves:  written plan to
monitor as frequently as practicable during
safe to monitor times.

"Difficult to monitor" valves:  written plan
to monitor at least once per year,
                   Equipment in vacuum service.

                   Equipment operated fewer than 300 hours per
                   year.

                   "Unsafe to monitor" valves:  written plan to
                   monitor as frequently as practicable during
                   safe to monitor times,

                   "Difficult to monitor" valves: written plan to
                   monitor at least once per year.  No more than
                   3.0 percent of valves in new  facility can be
                   designated as difficult to monitor,

                   Equipment located at plant sites with fewer
                   than 250 valves is exempt from monthly
                   monitoring; instead monitor once per quarter
                   or comply with percent leak requirements for
                   < 1% or 0.5%, as applicable.
                                          Equipment in vacuum service,

                                          "No detectable emissions" valves: less than
                                          500 ppm above background.

                                          "Unsafe to monitor" valves: written plan to
                                          monitor as frequently as practicable during
                                          safe to monitor times.

                                          "Difficult to monitor" valves:  written plan to
                                          monitor at least once per year.

                                          No external activating mechanism in contact
                                          with hazardous waste stream; is tested for
                                          compliance initially, annually, and as
                                          requested by the Regional Administrator

                                          Valves designated as difficult to monitor at
                                          hazardous waste management units in
                                          operation prior to June 21, 1990, and
                                          owner/operator follows written plan that
                                          requires monitoring of valves at least once
                                          per calendar year.

-------
SUMMARY OF REGULATIONS
page A-10
Specific
Component
Summaries
REGULATION
40 CFR part 60,
SubpartVV
40 CFR part 61, 40CFRpart61,
Subpart J Subpart V
40CFRpart63, 40CFRpart63,
Subpart H Subpart I
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
VALVBS, HEAVY LIQUID SERVICE
Standards
Leak
Definition
Repair
First Attempt
at Repair
Practices
Exemptions
Monitoring of potential leaks within 5
calendar days of detection if evidence of
potential leak is found by visual, auditory,
olfactory, or other detection method.
10,000 ppm
Repair as soon as practicable, no later than
15 calendar days after detection,
First attempt within 5 calendar days of
detection.
Best practices include, but are not limited to:
- tightening of bonnet bolts
- replacement of bonnet bolts
- tightening of packing gland nuts
- injection of lubricant into lubricated
packing
Equipment in vacuum service.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Monitoring of potential leaks within 5
calendar days of detection if evidence of
potential leak is found by visual, audible,
olfactory, or other detection method.
Monitoring: 500 ppm
Repair as soon as practicable, no later than
15 calendar after detection.
First attempt within 5 calendar days of
detection.
For equipment that are not monitored
(Method 21), repair shall mean that visual,
olfactory or other indications of a leak have
been eliminated; no bubbles are observed at
potential leak sites during lead check with
soap solution; or system will hold a test
pressure.
Best practices include, but are not limited to:
- tightening of bonnet bolts
- replacement of bonnet bolts
- tightening of packing gland nuts
- injection of lubricant into lubricated
poking
Equipment in vacuum service.
Equipment operated fewer than 300 hours per
year.
Monitoring of potential leaks within 5
calendar days of detection if evidence of
potential leak is found by visual, audible,*
olfactory, or other detection method.
10,000 ppm
Repair as soon as practicable, no later than
15 calendar days after detection.
First attempt within 5 calendar days of
detection.
Best practices include, but are not limited to:
- tightening of bonnet bolts
- replacement of bonnet bolts
- tightening of packing gland nuts
- injection of lubricant into lubricated
packing
Equipment in vacuum service.

-------
SUMMARY OF REGULATIONS
page A-ll

Specific
Component
Summaries


REGULATION

40 CFR part 60,
Subpart VV


40 CFR part 61 , 40 CFR part 61 ,
Subpart J Subpart V


40 CFR part 63, 40 CFR part 63,
Subpart H Subpart I


40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
ALTERNATIVE STANDARDS FOR VALVES
Allowable Percentage of Valves Leaking
Standard
















Leak
Definition
Repair



First Attempt
at Repair
Practices




Allowable percentage of leaking valves is
equal to or less than 2.0 percent.
Notify Administrator of election to comply
with alternative standard.

Conduct performance test initially, annually,
and at other times as requested by the
Administrator.

Performance tests shall:
* Monitor all valves in gas/vapor and in light
liquid service within one week.

« Calculate percent leaking.



10,000 ppm

Repair as soon as practicable, no later than
15 calendar days after detection.
First attempt within 5 calendar days of
detection.
Best practices include, but are not limited to:
- tightening of bonnet bolts
- replacement of bonnet bolts
- tightening of packing gland nuts
- injection of lubricant into lubricated
packing

Notify Administrator of election to comply
with alternative standard.
Conduct performance test initially, annually.
and at other times as requested by the
Administrator.

Performance tests shall:

• Monitor all valves in gas/vapor and in
light liquid service within one week.
• Calculate percent leaking.

• Equal to or less than 2.0 percent leaking.

Notify Administrator in writing when owner
or operator elects to no longer comply with
alternative standard.
10,000 ppm

Repair as soon as practicable, no later than
15 calendar days after detection.
First attempt within 5 calendar days of
detection.
Best practices include, but are not limited
to:
- tightening of bonnet bolts
- replacement of bonnet bolts
- tightening of packing gland nuts
- injection of lubricant into lubricated
packing
Not applicable.
















Not applicable.

Not applicable.



Not applicable.






Notify Regional Administrator of election to
comply with alternative standard.
Conduct performance test initially, annually,
and at other times as requested by the
Regional Administrator.

Performance tests shall:

* Monitor all valves in gas/vapor and in light
liquid service within one week.
• Calculate percent leaking.

* Equal to or less than 2.0 percent leaking.

Notify Regional Administrator when owner
or operator elects to no longer comply with
alternative standard.
10,000 ppm

Repair as soon as practicable, no later than
15 calendar days after detection.
First attempt within 5 calendar days of
detection.
Best practices include, but are not limited to:
- tightening of bonnet bolts
- replacement of bonnet bolts
- tightening of packing gland nuts
- injection of lubricant into lubricated
packing


-------
                                                                       SUMMARY OF REGULATIONS
                                                                                                                                                               page A-12
  Specific
 Component
 Summaries
                                                                                            REGULATION
             40 CFR pit 60,
               Subpart VV
  40 CFR part 61,
     Subpart J
40 CFR part 61,
   Subpart V
40 CFR part 63,
   Subpart H
40 CFR pan 63,
   Subpart I
40 CFR part 264,
   Subpart BB
40 CFR part 265,
   Subpart BB
Skip Period Leak Detection and Repair
    Standard
Notify Administrator of election to comply
with alternative standard.

Comply initially with monthly LDAR, then
either:

  1. After 2 consecutive quarters with equal
     to or less than 2 percent leakers,
     monitor semiannually; or

  2, After 5 consecutive quarters with equal
     to or less than 2 percent leakers,
     monitor annually,

Revert to monthly monitoring if percent
leakers exceed 2 percent,

Keep record  of percent leakers during each
leak detection.
Notify Administrator of election to comply
with alternative standard.

Comply initially with monthly LDAR, then
either:

  1. After 2 consecutive quarters with
     equal to or less than 2 percent leakers,
     monitor semiannually.

  2, After 5 consecutive quarters with
     equal to or less than 2 percent leakers,
     monitor annually,

Revert to monthly monitoring if percent
leakers exceed 2 percent.
                   Not applicable.
                                         Notify Regional Administrator of election to
                                         comply with alternative standard.

                                         Conduct performance test initially, annually,
                                         and at other times as requested by the
                                         Regional Administrator.

                                         Comply initially with monthly LDAR, then
                                         either:

                                           1,  After 2 consecutive quarters with equal
                                               to or less than 2 percent leakers,
                                               monitor semiannually.

                                           2.  After 5 consecutive quarters with equal
                                               to or less than 2 percent leakers,
                                               monitor annually,

                                         Revert to monthly monitoring if percent
                                         leakers exceed 2 percent,

                                         Notify Regional Administrator when owner
                                         or operator elects to no longer comply with
                                         alternative standard.

-------
                                                                     SUMMARY OF REGULATIONS
                                                                                                                                                           page A-13
  Specific
 Component
 Summaries
                                                                                         REGULATION
            40 CFR part 60,
              Subpart VV
  40 CFR part 61,
     Subpart J
40 CFR part 61,
   Subpart V
40 CFR part 63,
   Subpart H
40 CFR part 63,
   Subpart I
40 CFR part 264,
   Subpart BB
40 CFR part 265,
   Subpart BB
PUMPS, LIGHT LIQUID SERVICE
   Standards
Pumps:  Monitor monthly and conduct
weekly visual inspections.
Pumps: Monitor monthly and conduct
weekly visual inspections.  If located at
unmanned plant site, visual inspections
required at least monthly.
                  Pumps: Monitor monthly and conduct
                  weekly visual inspections.  If located at
                  unmanned plant site, visual inspections
                  required at least monthly,

                  Phase III:  If the greater of either 10 percent
                  of pumps in a process unit (or source-wide)
                  or 3 pumps in a process unit (or source-wide)
                  leak, then implement technology review and
                  improvement QIP.  (This does not apply to
                  process unit if more than 90% of the pumps
                  in the unit are either dual mechanical seal or
                  designed with no externally activated shaft
                  penetrating the housing.)

                  Existing Sources

                  Phase I: begins on compliance date.

                  Phase II:   begins no later than one year after
                  the compliance date.

                  Phase III:  begins no later than 2 V4 years
                  after the compliance date.

                  New Sources

                  Phase I: this phase is not applicable.

                  Phase II;   begins upon facility startup.

                  Phase III:  begins no later than one year after
                  initial startup.
                                        Pumps: Monitor monthly and conduct
                                        weekly visual inspections.

-------
                                                                     SUMMARY OF REGULATIONS
                                                                                                                                                            page A-14
  Specific
 Component
 Summaries
                                                                                          REGULATION
             40 CFR pan 60,
               Subpart VV
  40 CFR part 61,
     Subpart J
40 CFR part 61,
   Subpart V
40 CFR part 63,
   Subpart H
40 CFR part 63,
   Subpart I
40 CFR part 264,
   Subpart BB
40 CFR part 265,
   SubpM BB
PUMPS, LIGHT LIQUID SERVICE (continued)
       Leak
   Definition
10,000 ppm

Indications of liquids dripping from pump
seal
10,000 ppm

Indications of liquids dripping from pmp
seat

"Dual Mechanical Seal" Pumps: Indications
of liquid dripping from pump seal where
monitoring for VHAP indicates the presence
of VHAP (less background reading) and for
monitoring total VOCs measures greater
tan 10,000 ppm
                  Phase I:   10,000 ppm

                  Phase II:  5,000 ppm

                  Phase III: 5,000 ppm (polymerizing
                            monomers)
                            2,000 ppm (food/medical
                            services)
                            1,000 ppm (all other pumps)

                  Indications of liquids dripping from pump
                  seal.
                                         10,000 ppm

                                         Indkations of liquids dripping from pump
                                         seal
      Repair
Repair as soon as practicable, no later than
15 calendar days after detection.

First attempt within 5 calendar days of
detection.
Repair as soon as practicable, no later than
15 calendar days after detection.

First attempt within 5 calendar days of
detection.
                   Repair as soon as practicable, no later than
                   15 calendar days after detection.

                   First attempt within 5 calendar days of
                   detection.

                   Phase III pumps with leak definition of 1,000
                   ppm: repair only required for pumps leaking
                   at 2,000 ppm or more
                                         Repair as soon as practicable, no later than
                                         15 calendar days after detection.

                                         First attempt within 5 calendar days of
                                         detection.
First Attempt
    at Repair
    Practices
None specified.
None specified.
                   Best practices include, but are not limited to:
                      -  tightening of packing gland nuts
                      -  ensuring that the seal flush is operating
                        at design pressure and temperature
                                         None specified.

-------
                                                                     SUMMARY OF REGULATIONS
                                                                                                                                                             page A-15
  Specific
 Component
 Summaries
                                                                                          REGULATION
            40 CFR part 60,
               Subpart VV
  40 CFR part 61,
     Subpart J
40 CFR part 61,
   Subpart V
40 CFR part 63,
   Subpart H
40 CFR part 63,
   Subpart I
40 CFR part 264,
   Subpart BB
40 CFR part 265,
   Subpart BB
PUMPS, LIGHT LIQUID SERVICE (concluded)
  Exemptions
Equipment in vacuum service.

Any pump equipped with a compliant closed-
vent system and control device.
               "Dual Mechanical Seal" pumps: specific
               operating and design requirements.

               "No Detectable Emissions" pumps:  less than
               500 ppm above background and specified
               design requirements.
Equipment in vacuum service.

Any pump equipped with a compliant
closed-vent system and control device.
                                          "Dual Mechanical Seal" pumps:  specific
                                          operating and design requirements.

                                          "No Detectable Emissions" pumps:  less
                                          than 500 ppm above background and
                                          specified design requirements.

                                          Any pump located at an unmanned site is
                                          exempt from weekly visual inspections and
                                          daily sensor checks, provided each pump is
                                          inspected as often as practicable and at least
                                          monthly.
                   Equipment in vacuum service,

                   Any pump equipped with a compliant closed-
                   vent system that transports leakage back to
                   the process, fuel gas system, or to a
                   compliant control device.

                   "Dual Mechanical Seal" pumps: specific
                   operating and design requirements.

                   "No Detectable Emissions" pumps:  less than
                   500 ppm above background and specified
                   design requirements.

                   No external shaft penetrating the pump
                   housing: weekly visual inspection.

                   Equipment operated fewer than 300 hours per
                   year.

                   Process units with more than 90% of pumps
                   with dual mechanical seal or closed-vent
                   system are exempt from monthly calculations
                   of percent leaking pumps.

                   If at unmanned site, visually  inspect as often
                   as practicable and at least monthly.

                   Unsafe to monitor pumps are exempt if
                   monitoring personnel would be exposed to an
                   immediate danger and owner/operator has 8
                   plan that requires monitoring as often as
                   practical during safe to monitor times, but not
                   more frequently than the periodic monitoring
                   schedule otherwise applicable.
                                         Equipment in vacuum service.

                                         Any pump equipped with a compliant closed-
                                         vent system and control device.
                                                                                    "Dual Mechanical Seal" pumps: specific
                                                                                    operating and design requirements.

                                                                                    "No Detectable Emissions" pumps: less than
                                                                                    500 ppm above background and specified
                                                                                    design requirements.

-------
SUMMARY OF REGULATIONS
page A-16
Specific
ComponenJ
Summaries
REGULATION
40 CFR part 60,
Subpart VV
40CFRpart61, 40 CPU part 61,
Subpart J Subpart V
40CFRpart63, 40 CFR part 
-------
                                                                        SUMMARY OF REGULATIONS
                                                                                                                                                                  page A-17
   Specific
 Component
 Summaries
                                                                                             REGULATION
             40 CFR part 60,
               Subpart W
  40 CPR part 61,
     Subparl J
40 CFR part 61,
   Subpart V
40 CFR part 63,
   Subpart H
40 CFR part 63,
   Subpart I
40 CPR part 264,
   Subpart BB
40 CFR part 265,
   Subpart BB
PRESSURE RELIEF DEVICES, GAS/VAPOR SERVICE
   Standards
No detectable emissions, except during
pressure releases (less than 500 ppm above
background).

After each release, return to no detectable
emissions within 5 calendar days as indicated
by monitoring of the pressure relief device.
No detectable emissions (less than 500 ppm
above background).

After each release, return to no detectable
emissions within 5 calendar days as
indicated by monitoring of the pressure
relief device.
                   No Rupture Disk

                   No detectable emissions (less than 500 ppm
                   above background)

                   After each release, return to no detectable
                   emissions within 5 calendar days as indicated
                   by monitoring of the pressure relied device.

                   With Rupture Disk

                   After each release, replace rupture disk
                   within 5 calendar days.
                                          No detectable emissions (less than 500 ppm
                                          above background),

                                          After each release, return to no detectable
                                          emissions within 5 calendar days as indicated
                                          by monitoring of the pressure relief device.
       Leak
   Definition
"No detectable emissions" - less than 500
ppm above background.
"No detectable emissions" - less than 500
ppm above background.
                   "No detectable emissions" - less than 500
                   ppm above background.
                                           "No detectable emissions" - less than 500
                                           ppm above background.
      Repair
Return to condition of "no detectable
emissions" as soon as practicable but no later
than 5 calendar days after pressure release.
Return to condition of "no detectable
emissions" as soon as practicable but no
later than 5 calendar days after pressure
release.
                   Not applicable.
                                          Return to condition of "no detectable
                                          emissions" as soon as practicable but no later
                                          than 5 calendar days after pressure release.
  Exemptions
Pressure relief devices equipped with closed-
vent system and control device.
               Equipment in vacuum service.
Pressure relief devices equipped with
compliant closed-vent system and control
device.

Equipment in vacuum service.
                   Pressure relief devices routed to a process or
                   fuel gas system or equipped with compliant
                   closed-vent system and control device.

                   Equipment in vacuum service.

                   Equipment operated fewer than 300 hours per
                   year,

                   Any pressure relief device equipped with a
                   rupture disk meeting die requirements of the
                   rule.
                                          Pressure relief devices equipped with
                                          compliant closed-vent system and control
                                          device.

                                          Equipment in vacuum service.

-------
SUMMARY OF REGULATIONS
page A-18
Specific
Component
Summaries
REGULATION
40 CFR part fiO,
Subpari VV
40CFRpart61, 40CFRpart61,
Subpart J Subpart V
40CFRprt63, 40 CFR part 63,
Subpart H Subpart I
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
PRESSURE RELIEF DEVICES, LIGHT LIQUID OR HEAVY LIQUID SERVICE
Standards
Leak
Definition
Repair
First Attempt
at Repair
Practices
Exemptions
Monitoring of potential leaks within 5
calendar days of detection if evidence of
potential leak is found by visual, auditory,
olfactory, or other detection method.
10,000 ppm
Repair as soon as practicable, no later than
15 calendar days after detection.
First attempt within 5 calendar days of
detection.
Best practices include, but are not limited to:
- tightening of bonnet bolts
- replacement of bonnet bolts
• tightening of packing gland nuts
- injection of lubricant into lubricated
packing
Equipment in vacuum service.
Monitoring of potential leaks within 5
calendar days of detection if evidence of
potential leak is found by visual, auditory,
olfactory, or other detection method.
10,000 ppm
Repair as soon as practicable, no later than
15 calendar days after detection,
First attempt within 5 calendar days of
detection.
Best practices include, but are not limited
to:
- tightening of bonnet bolts
- replacement of bonnet bolts
- tightening of packing gland nuts
- injection of lubricant into lubricated
packing
Equipment in vacuum service.
Monitoring of potential leaks within 5
calendar days of detection if evidence of
potential leak is found by visual, auditory,
olfactory, or other detection method.
Monitoring: 500 ppm
Repair as soon as practicable, no later than
15 calendar after detection.
First attempt within 5 calendar days of
detection.
For equipment that are not monitored
(Method 21), repair shall mean that visual,
olfactory or other indications of a leak have
been eliminated; no bubbles are observed at
potential leak sites during lead check with
soap solution; or system will hold a test
pressure.
Best practices include, but are not limited to:
- tightening of bonnet bolts
- replacement of bonnet bolts
- tightening of packing gland nuts
- injection of lubricant into lubricated
packing
Equipment in vacuum service.
Equipment operated fewer than 300 hours per
year.
Monitoring of potential leaks within 5
calendar days of detection if evidence of
potential leak is found by visual, auditory,
olfactory, or other detection method.
10,000 ppm
Repair as soon as practicable, no later than
15 calendar days after detection.
First attempt within 5 calendar days of
detection.

Equipment in vacuum service.

-------
                                                                          SUMMARY OF REGULATIONS
                                                                                                                                                                       page A-19
   Specific
 Component
 Summaries
                                                                                                REGULATION
              40 CFR part 60,
                Subpart VV
  40 CFR part 61,
     Subpart J
40 CFR part 61,
   Subpart V
40 CFR part 63,
   Subpart H
40 CFR part 63,
   Subpart I
40 CFR part 264,
   Subpart BB
40 CFR part 265,
   Subpart BB
COMPRESSORS
    Standards
 Equip with compliant seal system that
 includes a barrier fluid system and  that
 prevents leakage to atmosphere.

 Seal system shall meet certain design and
 operation requirements.

 Install sensor to detect failure of seal system,
 barrier fluid  system, or both.

 Check sensor daily or equip with audible
 alarm.
                Establish criteria that indicates failure of seal
                system, barrier fluid system, or both,
Equip with seal system that includes a
barrier fluid system and that prevents
leakage to atmosphere.

Seal system shall meet certain design and
operation requirements.

Install sensor to detect failure of seal
system, barrier fluid system, or both.

Visually check sensor daily or equip with
audible alarm (unless located at unmanned
plant site),

Establish criteria that indicates failure of
seal system, barrier fluid system, or both.
                    Equip with seal system that includes a barrier
                    fluid system and that prevents leakage to
                    atmosphere.

                    Seal system shall meet certain design and
                    operation requirements.

                    Install sensor to detect failure of seal system,
                    barrier fluid system, or both.

                    Check sensor daily or equip with audible
                    alarm that is checked monthly (unless located
                    at unmanned plant site, then check daily).

                    Establish criteria that indicates failure of seal
                    system, barrier fluid system, or both.
                                           Equip with seal system that includes a barrier
                                           fluid system and that prevents leakage to
                                           atmosphere.

                                           Seal system shall meet certain design and
                                           operation requirements.

                                           Install sensor to detect failure of seal system,
                                           barrier fluid system, or both.

                                           Check sensor daily or equip with audible
                                           alarm that is checked monthly; if at
                                           unmanned plant site, check daily.

                                           Establish criteria  that indicates failure of seal
                                           system, barrier fluid system, or both.
        Leak
   Definition
 Sensor indicates failure of seal system,
• barrier fluid system, or both based on
 established criteria.
Sensor indicates failure of seal system,
barrier fluid system, or both based on
established criteria.
                    Sensor indicates failure of seal system,
                    barrier fluid system, or both based on
                    established criteria.
                                           Sensor indicates failure of seal system,
                                           barrier fluid system, or both based on
                                           established criteria.
      Repair
 Repair as soon as practicable, no later than
 15 calendar days after detection.

 First attempt within 5 calendar days of
 detection.
Repair as soon as practicable, no later than
15 calendar days after detection.

First attempt within 5 calendar days of
detection.
                    Repair as soon as practicable, no later than
                    15 calendar days after detection.

                    First attempt within 5 calendar days of
                    detection.
                                           Repair as soon as practicable, no later than
                                           15 calendar days after detection.

                                           First attempt within 5 calendar days of
                                           detection.

-------
                                                                   SUMMARY OF REGULATIONS
                                                                                                                                                       page A-20
  Specific
 Component
 Summaries
                                                                                       REGULATION
            40 CFR part 60,
              Subpart VV
  40 CFR part 61,
    SubprtJ
40 CFR part 61,
   Subpart V
40 CFR part 63,
   Subpart H
40 CFR part 63.
   SubptrtI
40 CFR part 264,
   Subpart BB
40 CFR part 265,
   Subpart BB
COMPRESSORS (concluded)
  Exemptions
Equipment in vacuum service.

Compressors equipped with compliant closed-
vent system and control device.
              Compressors designed to operate with an
              instrument reading less than 500 ppm above
              background.

              Reciprocating compressors that meet certain
              criteria.
Equipment in vacuum service.

Compressors equipped with compliant
closed-vent system and control device.
                                         Compressors designed to operate with an
                                         instrument reading less than 500 ppm above
                                         background.
                  Equipment in vacuum service,

                  Any compressors equipped with compliant
                  closed-vent system that returns to process,
                  fuel gas system, or transports leakage back to
                  the process or to a compliant control device.

                  Compressors designed to operate with an
                  instrument reading less than 500 ppm above
                  background.

                  Compressors operated fewer than 300 hours
                  per year in organic HAP service.
                                       Equipment in vacuum service,

                                       Compressors equipped with compliant
                                       closed-vent system and control device.
                                                                                Compressors designed to operate with an
                                                                                instrument reading less than 500 ppm above
                                                                                background.

-------
SUMMARY OF REGULATIONS
page A-21
Specific
Component
Summaries
REGULATION
40 CFR part 60,
Subpart VV
40 CFR part 61, 40 CFR part 61 ,
Subpart J Subpart V
40 CFR part 63, 40 CFR part 63,
Subpart H Subpart I
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
SAMPLING CONNECTION SYSTEMS
Standards
Leak
Definition
Repair
Exemptions
Equipped with closed-purge, closed-loop, or
closed-vent system that returns the purged
process fluid to the process line, collects and
recycles the purged process fluid to a
process, or is designed and operated to
capture and transport all the purged process
fluid to a compliant control device.
Not applicable.
Not applicable.
Equipment in vacuum service,
In-situ sampling systems and sampling
systems without purges.
Equipped with closed-purge system or
closed-vent system that either returns the
fluid to the process line or collects and
recycles the purged fluid with zero VHAP
emissions to the atmosphere, or captures
and transports all purged fluids to a
compliant control device.
Not applicable.
Not applicable.
Equipment in vacuum service.
In-situ sampling systems.
Equipped with closed-purge system, closed-
loop, or closed-vent system that either returns
the fluid to the process, recycles the purged
fluid, send it to a compliant control device, or
collect, store, and transport it to an
appropriate facility.
Gases displaced during filling of samples are
not required to be collected or captured.
Not applicable.
Not applicable.
Equipment in vacuum service.
In-situ sampling systems and sampling
systems without purges.
Equipment operated fewer than 300 hours per
year.
Equipped with closed-purge system or
closed-vent system that either returns the
fluid to the process line or collects and •
recycles the purged fluid with zero VHAP
emissions to the atmosphere, or captures and
transports all the purged hazardous waste
stream to a compliant control device.
Not applicable.
Not applicable.
Equipment in vacuum service.
In-situ sampling systems.
Sampling systems without purges.

-------
SUMMARY OF REGULATIONS
page A-22
Specific
Component
Summaries
REGULATION
40 CFR part 60.
Subpart VV
40 CFR ptrt 61 , 40 CFR part 61 ,
Subpart J Subpart V
40 CFR part 63, 40 CFR part 63,
Subpart H Subpart 1
40 CFR part 264,
Subpart BE
40 CFR part 265,
Subpart BB
OPEN-ENDED VALVES OR LINES
Standards
Leak
Definition
Repair
Exemptions
Equip with cap, blind flange, plug, or second
valve to seal open end at all time except
when operations require flow through open
end.
Second Valve
Close valve on process fluid end before
closing second valve
Double Block and Bleed System
Bleed valve or line may remain open during
operations that require venting the line
between the block valves, but comply with
basic standard at all other times.
•Not applicable.
Not applicable.
Equipment in vacuum service.
Equip with cap, blind flange, plug, or
second valve to seal open end at all time
except when operations require flow through
open end,
Second Valve
Close valve on process fluid end prior to
closing second valve
Double Block and Bleed System
May remain open during operations that
require venting the line between the block
valves, but comply with basic standard at all
other times.
Not applicable.
Not applicable.
Equipment in vacuum service.
Equip with cap, blind flange, plug, or second
valve to seal open end at all time except when
operations require flow through open end or
during maintenance and repair.
Second Valve
Close valve on process fluid end prior to
closing second valve
Double Block and Bleed System
May remain open during operations that
require venting the line between the block
valves, but comply with basic standard at all
other times.
Not applicable.
Not applicable.
Equipment In vacuum service.
Open-ended valves and tines in an emergency
shutdown system that are designed to open
automatically in (he event of a process upset.
Equipment operated fewer than 300 hours per
year.
Equipment containing materials which would
automatically polymerize or cause a safety
hazard if capped or equipped with a double
block and bleed system.
Equip with cap, blind flange, plug, or second
valve to seal open end at all time except
when operations require flow through open
end.
Second Valy?
Close valve on hazardous waste stream end
prior to closing second valve
Double Block and Bleed Svstem
May remain open during operations that
require venting the line between the block
valves, but comply with basic standard at all
other times.
Not applicable.
Not applicable.
Equipment in vacuum service.

-------
SUMMARY OF REGULATIONS
page A-23
Specific
Component
Summaries
REGULATION
40 CFR part 60,
Subpart VV
40 CFR part 61 , 40 CFR part 61 ,
Subpart J Subpart V
40 CFR part 63, 40 CFR part 63,
Subpart H Subpart I
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
FLANGES AND OTHER CONNECTORS (ALL SERVICES)
Standards
Leak
Definition
Repair
First Attempt
at Repair
Practices
Exemptions
Monitor within 5 days if evidence of a
potential leak is found by visual, auditory,
olfactory, or other detection methods.
10,000
Repair as soon as practicable, no later than
IS calendar days after detection.
First attempt within 5 calendar days of
detection.
Best practices include, but are not limited to:
- tightening of bonnet bolts
- replacement of bonnet bolts
- tightening of packing gland nuts
- injection of lubricant into lubricated
packing
Equipment in vacuum service.
Monitor within 5 days if evidence of a
potential leak is found by visual, auditory,
olfactory, or other detection methods.
10,000
Repair as soon as practicable, no later than
15 calendar days after detection.
First attempt within 5 calendar days of
detection.
Best practices include, but are not limited
to:
- tightening of bonnet bolts
- replacement of bonnet bolts
- tightening of packing gland nuts
- injection of lubricant into lubricated
packing
Equipment in vacuum service.
(see Connectors, gas/vapor or light liquid
service)
(see Connectors, gas/vapor or light liquid
service)
(see Connectors, gas/vapor or light liquid
service)
(see Connectors, gas/vapor or light liquid
service)
(see Connectors, gas/vapor or light liquid
service)
Monitor within 5 days if evidence of a
potential leak is found by visual, auditory,
olfactory, or other detection methods. •
10,000
Repair as soon as practicable, no later than
15 calendar days after detection.
First attempt within 5 calendar days of
detection.

Equipment in vacuum service.

-------
                                                                    SUMMARY OF REGULATIONS
                                                                                                                                                          page A-24
  Specific
 Component
 Summaries
                                                                                         REGULATION
            40CFRprt60,
              Subpart VV
  40 CfR part 61,
     Subpart J
40GFRpart6l,
   Subpart V
40 CFR pan 63,
   Subpart H
40 CFR part 63,
   SubpirtI
40 CFR part 264,
   Subpart BB
40 CFR part 265,
   Subpart BB
CONNECTORS.  GAS/VAPOR OR LIGHT LIQUID SERVICE
   Standards
(see "Flanges and other connectors, all
services)
(see "Flanges and other connectors, all
services)
                  Initial Survey: Monitor ail connectors within
                  a 12 month period

                  Subsequent monitoring frequency based on
                  percent leaking connectors:

                  • annual if 2 0.5%
                  • once every 2 years if < 0.5%
                  • once every 4 years if <0.5% during 2
                    year monitoring
                  • once every 2 years if 0,5 to < 1 % during 4
                    year monitoring
                  • annual if > 1 % during 4 year monitoring

                  To comply with monitoring frequency of once
                  every two years, monitor at least 40% of the
                  connectors in the first year and the remainder
                  in the second year.

                  To comply with monitoring frequency of once
                  every four years, monitor at least 20% each
                  year until all have been monitored within 4
                  years.

                  Connectors that have been opened or
                  reconnected or have had the seal broken:
                  Monitor for leaks within 3 months after being
                  returned to organic HAP service or calculate
                  percent leakers by setting nonreparable
                  components to zero for all monitoring
                  periods.  May switch between these
                  alternatives at end of monitoring period.

                  A switch in alternatives requires initial
                  monitoring no later than 12 months after
                  reporting the switch.
                                        (see "Flanges and other connectors, all
                                        services)

-------
                                                                     SUMMARY OF REGULATIONS
                                                                                                                                                             page A45
  Specific
 Component
 Summaries
                                                                                          REGULATION
            40 CFR part 60,
              Subpart VV
  40 CFR part 61,
     Subpart J
40 CFR part 61,
   Subpart V
40 CFR part 63,
   Subpart H
40 CFR part 63,
   Subpart I
40 CFR part 264,
   Subpart BB
40 CFR part 265,
   Subpart BB
CONNECTORS,  GAS/VAPOR OR LIGHT LIQUID SERVICE (concluded)
       Leak
   Definition
(see "Flanges and other connectors, all
services)
(see "Flanges and other connectors, all
services)
                  500 ppm (except for inaccessible, ceramic, or
                  ceramic-lined connectors)
                                         (see "Flanges and other connectors, ail
                                         services)
      Repair
(see "Flanges and other connectors, all
services)
(see "Flanges and other connectors, all
services)
                  Repair as soon as practicable, but no later
                  than 15 calendar days after detection.

                  First attempt to repair within 5 calendar days
                  of detection,

                  When repaired, monitor at least once within
                  first 3 months of repir.
                                         (see "Flanges and other connectors, all
                                         services)
  Exemptions
(see "Flanges and other connectors, all
services)
(see "Flanges and other connectors, all
services)
                  Equipment in vacuum service.

                  Equipment operated fewer than 300 hours per
                  year.

                  "Unsafe to monitor" connectors: Written
                  plan to monitor as frequently as practicable
                  during safe to monitor periods, but no more
                  frequently than the periodic schedule
                  otherwise applicable,

                  "Unsafe to repair" connectors: Repair by end
                  of the next scheduled process unit shutdown.

                  "Inaccessible" or "ceramic" or "ceramic-
                  lined" connectors: Repir any observed leak.
                                         (see "Flanges and other connectors, all
                                         services)

-------
SUMMARY OF REGULATIONS
page A-26
Specific
Component
Summaries
REGULATION
40 CFR part 60,
Subpart W
40 CFR part 6! , 40 CFR part 61 ,
Subpart J Subpart V
40 CFR part 63, 40 CFR prt 63,
Subpart H Subpart I
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
CONNECTORS, HEAVY LIQUID SERVICE
Standards
Leak
Definition
Repair
Exemptions
(see "Flanges and other connectors, al!
services)
(see "Flanges and other connectors, all
services)
(see "Flanges and other connectors, all
services)
(see "Flanges and other connectors, all
services)
(see "Flanges and other connectors, all
services)
(see "Flanges and other connectors, all
services)
(see "Flanges and other connectors, all
services)
(see "Flanges and other connectors, all
services)
Monitoring of potential leaks within 5
calendar days of detection if evidence of
potential leak is found by visual, audible,
olfactory, and other detection methods.
Monitoring: 500 ppm
Repair as soon as practicable, no later than
15 calendar after detection.
For connectors in heavy liquid service that
are not monitored (Method 21), repair shall
mean that visual, audible, olfactory, or other
indications of a leak have been eliminated; no
bubbles are observed at potential leak sites
during leak check with soap solution; or
system will hold a test pressure.
Equipment in vacuum service.
Equipment operated fewer than 300 hours per
year.
(see "Flanges and other connectors, all
services)
(see "Flanges and other connectors, all
services)
(see "Flanges and other connectors, all
services)
(see "Flanges and other connectors, all
services)

-------
SUMMARY OF REGULATIONS
page A-27
Specific
Component
Summaries
REGULATION
40 CFR part 60,
Subpart VV
40 CFR part 61 , 40 CFR part 61 ,
Subpart J Subpart V
40 CFR part 63, 40 CFR part 63,
Subpart H Subpart I
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
AGITATORS, GAS/VAPOR SERVICE OR LIGHT LIQUID SERVICE
Standards







Not applicable.







Not applicable.







"Non Dual Mechanical Seal" Agitators
Monthly monitoring and weekly visual check
for indications of dripping liquid. If at
unmanned site, visually inspect as often as
practicable and at least monthly.
"Dual Mechanical Seal" Agitators
Daily sensor check and weekly visual
inspections for indications of dripping liquid.
Dual mechanical seal requirements:
» Barrier fluid pressure at all times greater
than agitator stuffing box pressure, or
• Barrier fluid degassing reservoir routed to
a process or fuel gas system or connected
by a compliant closed-vent system to a
control device, or
• Closed-loop system that purges the barrier
fluid into a process stream.
Owner/operator determines criteria applicable
to file presence and frequency of drips and to
the sensor that indicates failure of the seal
system, the barrier fluid system, or both.
Not applicable.







AGITATORS, GAS/VAPOR SERVICE OR LIGHT LIQUID SERVICE (concluded)

-------
SUMMARY OF REGULATIONS
page A-28
Specific
Component
Summaries
Leak
Definition



Repairs

REGULATION
4QCFRpwt60,
Subpart VV
Not applicable.



Not applicable.

40 CFR part 61, 40CFRprt61,
Subpart J Subpart V
Not applicable,



Not applicable.

40 CM pit 63, 40 CHI part 63,
Subpart H Subpart I
"Non Dual Mechanical Seal" Agitators:
Monthly monitoring: 10,000 ppm
Weekly Visual: presence of indications of
dripping liquids
"Dual Mechanical Seal" Apitators:
Weekly Visual: if indications of dripping
liquids, monitor and if raiding is 10,000 ppm
based or higher, a leak is detected.
Drip Criteria: A leak is detected if the drip
criteria established are exceeded.
Sensor: A leak is detected if the sensor
indicates failure of the seal system, the
barrier fluid system, or both.
Repair as soon as practicable, no later than
15 days after detection.
First attempt to repair within 5 calendar days
of detection.
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
Not applicable.



Not applicable.


-------
                                                                    SUMMARY OF REGULATIONS
                                                                                                                                                            page A-29
 Specific
Component
Summaries
                                                                                         REGULATION
            40 CFR part 60,
              Subpart VV
  40CFRpart61,
     Subpart J
40 CPR part 61,
   Subpart V
40 CFR part 63,
   Subpart H
40 CPR part 63,
   Subpart I
40 CFR part 264,
   Subpart BB
40 CFR part 265,
   Subpart BB
 Exemptions
Not applicable.
Not applicable.
                  Designed with no externally actuated shaft
                  penetrating the agitator housing,

                  Equipment in vacuum service.

                  Agitators operated fewer than 300 hours per
                  year in organic HAP service.

                  Any agitator equipped with a compliant
                  closed-vent system and control device.

                  "Difficult to monitor" agitators: less than 3%
                  or agitators may be so marked.

                  "Unsafe to monitor" agitators: written plan to
                  monitor as frequently as practicable during
                  safe to monitor periods, but no more
                  frequently than the periodic  schedule
                  otherwise applicable,

                  Agitators obstructed by equipment piping that
                  prevents access by a monitor probe,

                  Agitators located at unmanned plant sites are
                  exempt from weekly visual inspection and
                  daily sensor check if visually inspected as
                  often as possible and at least monthly.
                                         Not applicable.

-------
SUMMARY OF REGULATIONS
page A-30
Specific
Component
Summaries
REGULATION
40 CFR part 60,
Subpart VV
40 CFR part 61, 40 CFR part 61,
Subpart J Subpart V
40 CFR part 63, 40 CFR part 63,
Subpart H Subpart I
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
AGITATORS, HEAVY LIQUID SERVICE
Standards
Leak
Definition
Repair
Exemptions
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable,
Not applicable.
Monitoring of potential leaks within 5
calendar days of detection if evidence of
potential leak is found by visual, audible,
olfactory, or other detection method.
Monitoring: 10,000 ppm
Repair as soon as practicable, no later than
15 calendar after detection
For agitators in heavy liquid service that are
not monitored (Method 21), repair shall mean
that visual, audible, olfactory, or other
indications of a leak have been eliminated; no
bubbles are observed at potential leak sites
during leak check with soap solution; or
system will hold a test pressure.
Equipment in vacuum service.
Equipment operated fewer than 300 hours per
year.
Not applicable.
Not applicable.
Not applicable.
Not applicable.

-------
SUMMARY OF REGULATIONS
page A-31
Specific
Component
Summaries
REGULATION
40 CFR part 60,
Subpart VV
40 CFR part 61, 40CERpart61,
Subpart J Subpart V
40 CFR part 63, 40 CFR part 63,
Subpart H Subpart I
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
INSTRUMENTATION SYSTEMS
Standards
Leak
Definition
Repair
Exemptions
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Monitoring of potential leaks within 5
calendar days of detection if evidence of
potential leak is found by visual, audible,
olfactory, or other detection method.
Monitoring: 500 ppm
Repair as soon as practicable, no later than
15 calendar after detection.
For instrumentation systems that are not
monitored (Method 21), repair shall mean
that visual, audible, olfactory, or other
indications of a leak have been eliminated; no
bubbles are observed at potential leak sites
during leak check with soap solution; or
system will hold a test pressure.
Equipment in vacuum service.
Equipment operated fewer than 300 hours per
year.
Not applicable.
Not applicable.
Not applicable.
Not applicable.

-------
SUMMARY OF REGULATIONS
page A-32
Specific
Component
Summaries
REGULATION
40 CFR part 60,
SubpattW
40 CFR part 61,
SubpaitJ
40 CFR part 61,
Subpart V
40 CFR part 63,
SubpartH
40 CFR part 63,
Subprt I
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
PRODUCT ACCUMULATOR VESSELS
Standards
Leak
Definition
Repair
Exemptions
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Compliant closed-vent system and control
device.
Not applicable.
Not applicable.
Equipment in vacuum service.
(sec Surge Control Vessels and Bottoms
Receivers)
(see Surge Control Vessels and Bottoms
Receivers)
(see Surge Control Vessels and Bottoms
Receivers)
(see Surge Control Vessels and Bottoms
Receivers)
Not applicable.
Not applicable.
Not applicable.
Not applicable.

-------
SUMMARY OF REGULATIONS
page A-33
Specific
Component
Summaries
REGULATION
40 CFR part 60,
. Subpart VV
40 CFR part 61 , 40 CFR part 61 ,
Subpart J Subpart V
40 CFR part 63, 40 CFR part 63,
Subpart H Subpart I
40 CFR part 264,
Subpart BB
40 CFR part 265,
' Subpart BB
SURGE CONTROL VESSELS AND BOTTOMS RECEIVERS
Standards
Leak
Definition
Repair
Exemptions
Not applicable.
Not applicable.
Not applicable.
Not applicable.
(see Product Accumulator Vessels)
(see Product Accumulator Vessels)
(see Product Accumulator Vessels)
(see Product Accumulator Vessels)
Use of closed-vent system that routes the
organic vapors either back to process or to
compliant control device,
Comply with the requirements for fixed roofs
with internal or external floating roofs.
Not applicable.
Not applicable.
Surge control vessels routed back to process.
Equipment in vacuum service,
Equipment operated fewer than 300 hours per
year.
Surge control vessels that do not meet certain
capacity and vapor pressure criteria; see
Tables 2 and 3 of Subpart H.
Not applicable.
Not applicable.
Not applicable.
Not applicable,
^- . „

-------
                                                                      SUMMARY OF REGULATIONS
                                                                                                                                                              page A-34
  Specific
 Component
 Summaries
                                                                                           REGULATION
             40 CFR part 60,
               Subprt VV
  40 CFR part 61,
     SubpartJ
40 CFR part 61,
   Subpart V
40 CFR part 63,
   Subpart H
40 CFR part 63,
   Subpart I
40 CFR part 264,
   Subpart BB
40 CFR part 265,
   Subprt BB
CLOSED VENT SYSTEMS AND CONTROL DEVICES
   Standards
Control devices and closed-vent systems to be
operated at all times that emissions may be
vented to them.
               Control Devices

               Vapor recovery systems:  95 percent or
               greater recovery
               Combustion devices: 95 percent or greater
               reduction or minimum residence time of 0.75
              •seconds and minimum temperature of 816°C,
               Flares: Comply with §60.18
               Closed-Vent Systems (CVS)

               Hard pipe construction:  Initial inspection
               (Method 21) and then annual visual
               inspections.

               Ductwork construction:  Initial and annual
               inspections using Method 21.

               Does not apply if CVS is in vacuum service.
Control devices and closed-vent systems to
be operated at all times that emissions may
be vented to them.
                                           Control Devices

                                           Vapor recovery systems: 95 percent or
                                           greater recovery
                                           Combustion devices;  95 percent or greater
                                           reduction or minimum residence time of
                                           0,50 seconds and minimum temperature of
                                           76Q°C.
                                           Flares: Comply with §60.18
                                           Closed-Vent Systems rCVS)

                                           No detectable emissions (less than 500 ppm
                                           above background) and no visual
                                           indications.
                   Control devices and closed-vent systems to be
                   operated at all times that emissions may be
                   vented to them.

                   Control devices subject to 40 CFR 63 subpart
                   H and 40 CFR 264 subpart BB or 40 CFR
                   265 subpart BB may comply with the
                   monitoring, recordkeeping and reporting
                   requirements of subpart H or of parts 264
                   and/or 265.

                   Recovery or Recapture Devices:

                   Vapor recovery systems: 95 percent or
                   greater recovery or an exit concentration of
                   20 ppmv, whichever is less stringent.

                   Combustion devices;  95 percent or greater
                   reduction or 20 ppmv on any basis,  corrected
                   to 3% Oj, whichever  is less stringent; or
                   minimum residence time of 0.50 seconds and
                   minimum temperature of 760°C,

                   Flares: Comply with §63.1 l(b).
                                          Closed-Vent Systems (CVS)

                                          Hard pipe construction:  Initial inspection
                                          (Method 21) and then annual visual
                                          inspections,

                                          Ductwork construction:  Initial and annual
                                          inspections using Method 21.

                                          Does not apply if CVS is in vacuum service.
                                         Control devices and closed-vent systems to
                                         be operated at all times that emissions may
                                         be vented to them.

                                         Control Devices

                                         Vapor recovery systems:  95 percent or
                                         greater recovery unless total organic
                                         emission limits of 1.4 kg/hr (12.8 Mg/yr) for
                                         ail affected processes can be attained at an
                                         efficiency of less than 95 percent.

                                         For carbon adsorbers, carbon replacement
                                         intervals specified.

                                         Combustion devices: 95 percent or greater
                                         reduction; 20 ppmv total organic compound
                                         concentration; or minimum residence time of
                                         0.50 seconds and minimum temperature of
                                         760-C.

                                         Boilers and process heaters: Introduce vent
                                         stream into flame combustion zone.

                                         Flares: Flame present at all times, no  visible
                                         emissions (except for periods not to exceed a
                                         total of 5 minutes during any 2 consecutive
                                         hours), basic requirements for heat content
                                         and exit velocities.

                                         Closed-Vent Systems (CVS)

                                         No detectable emissions (less than 500 ppm
                                         above background).

-------
SUMMARY OF REGULATIONS
page A-35

Specific
Component
^intitti3t"ip<;
wUUIillal ica


REGULATION

40 CFR part 60,
Subpart VV


40 CPR part 61 , 40 CFR part 61 ,
Subpart J - Subpart V


40 CFR part 63, 40 CFR part 63,
Subpart H Subpart I


40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
CLOSED VENT SYSTEMS AND CONTROL DEVICES (continued)
Monitoring
















Leak
Definition

Repair



Control Devices: Monitor to ensure operated
and maintained in conforraance with their
designs.



Closed-Vent Systems: If contains by-pass
lines, (1) vent stream flow meters or (2) car-
seal or lock-and-key type of configuration
with monthly visual inspection required.
Inspect initially, annually, and at other times
as requested by the Administrator,

Hard pipe construction: Method 21 for initial
inspection, annual visual inspections.
Duct Work construction: Method 21 for
initial and annual inspections.
> 500 ppm or above background

Visual inspection
Repair as soon as practicable, but no later
than 15 calendar days after detection.
First attempt to repair within 5 calendar days
of detection.
Control Devices: Monitor to ensure
operated and maintained in conformance
with their designs.



Closed-Vent Systems: Initially, annually,
and at other times as requested by the
Administrator.








500 ppm

Visual inspection
Repair as soon as practicable, but no later
than 15 calendar days after detection.
First attempt to repair within 5 calendar
days of detection.
Control Devices: Monitor to ensure operated
and maintained in conformance with their
designs.



Closed-Vent Systems: If contains by-pass
lines: install, set or adjust and maintain vent
stream flow indicator installed at entrance to
any bypass line or (l)vent stream flow meters
or (2) car-seal or lock-and-key type of
configuration with monthly visual inspection
required.




500 ppm

Visual inspection
Repair as soon as practicable, but no later
than 15 calendar days after detection.
First attempt to repair within 5 calendar days
of detection.
Control Devices: Monitor to ensure operated
and maintained in conforraance with their
designs. Specific requirements identified for
vent stream flow monitors and other
monitors for specific types of control
devices.
Closed- Vent Systems: Initially, annually,
and at other times as requested by the
Administrator.








CVS: detectable emissions (sSQO above
background)

Repair as soon as practicable, but no later
than 15 calendar days after detection.
First attempt to repair within 5 calendar days
of detection.

-------
                                                                 SUMMARY OF REGULATIONS
                                                                                                                                                   page A-36
  Specific
 Component
 Summaries
                                                                                     REGULATION
            40 CFR part 60,
              Subpart VV
  40 CFR part 61,
    SubpartJ
40CFRpirt61,
   Subpart V
40 CFR part 63,
   Subpart H
40 CFR part 63,
   Subpart I
40CFRprt264,
  Subpart BB
40 CFR part 265,
  Subpart BB
CLOSED VENT SYSTEMS AND CONTROL DEVICES (concluded)
  Exemptions
Equipment in vacuum service.

"Unsafe to inspect" parts;  inspect as
frequently as practicable during safe to
inspect times,

"Difficult to inspect" parts: inspect at least
once every 5 years.
Equipment in vacuum service.
                  Equipment in vacuum service.

                  "Unsafe to inspect" parts; Inspect as
                  frequently as practicable but not more than
                  once per year.

                  "Difficult to inspect" parts; inspect at least
                  once every 5 years.

                  Equipment in organic HAP service fewer
                  than 300 hours per year.

                  Equipment needed for safety purposes are not
                  subject to these monitoring requirements.
                                      Equipment in vacuum service.

                                      Equipment that contains or contacts a
                                      hazardous waste of at least 10% by weight
                                      for fewer than 300 hours per year.

                                      "Unsafe to monitor" parts; monitor as
                                      frequently as possible during safe to monitor
                                      times.

-------
                                                                        SUMMARY OF REGULATIONS
                                                                                                                                                                page  A-37
Delay of Repair
                                                                                               REGULATION
                              40 CFR part 60,
                                Subpart VV
                                             40 CFR part 61,
                                                Subpart J
                       40CPRpart61,
                          Subpart V
  40 CFR part 63,
     Subpart H
40 CPR part 63,
   Subpart I
40 CFR part 264,
   Subpart BB
40 CFR part 265,
   Subpart BB
       General
Allowed if repair is technically infeasible
without a process unit shutdown.
                  Repair to occur before end of next process
                  unit shutdown.
                  Allowed for equipment isolated from the
                  process and that does not remain in VOC
                  service.
Allowed if repair is technically infeasible
without a process unit shutdown.
                                           Repair to occur before end of next process
                                           unit shutdown.
                                           Allowed for equipment isolated from the
                                           process and that does not remain in VHAP
Allowed if repair is technically infeasible
without a process unit shutdown,
                                           Repair to occur before end of next process
                                           unit shutdown.
                                           Allowed for equipment isolated from the
                                           process and that does not remain in organic
                                           HAP service.
                    Allowed if repair is technically infeasible
                    without a hazardous waste management unit
                    shutdown.

                    Repair to occur before end of next
                    hazardous waste management unit
                    shutdown.

                    Allowed for equipment isolated from the
                    unit and that does not continue to contain or
                    contact hazardous waste with organic
                    concentrations of at least 10 percent by
                    weight.
        Valves
     (including
 connectors and
 agitators for 40
   CFR part 63
          only)
Allowed if:

Emissions of purged material resulting from
immediate repair greater than the fugitive
emissions likely to result from the delay in
the repair and purged material is collected
and destroyed or recovered in compliant
control device when procedures are
effected.

Delay beyond a process unit shutdown
allowed if valve assemblies have been
depleted and valve assembly supplies had
been sufficiently stocked before supplies
were depleted.

Not allowed beyond next process unit
shutdown, unless next process unit
shutdown occurs sooner than 6 months after
first process unit shutdown.
Allowed if:

Emissions of purged material resulting from
immediate repair greater than the fugitive
emissions likely to result from the delay in
the repir and purged material is collected
and destroyed or recovered in compliant
control device when procedures are
effected.

Delay beyond a process unit shutdown
allowed if valve assemblies have been
depleted,  valve assembly supplies had been
sufficiently stocked before supplies were
depleted.

Not allowed unless next process unit
shutdown occurs sooner than 6 months after
first process unit shutdown.
Allowed if:

Emissions of purged material resulting from
immediate repair greater than the fugitive
emissions likely to result from the delay in
the repair and purged material is collected
and destroyed or recovered in compliant
control device when procedures are effected.

Delay beyond a process unit shutdown
allowed if valve assemblies have been
depleted, valve assembly supplies had been
sufficiently stocked before supplies were
depleted.
                                                                                                       Not allowed beyond the second process unit
                                                                                                       shutdown unless the third process unit
                                                                                                       shutdown occurs sooner than 6 months after
                                                                                                       first process unit shutdown.
                    Allowed if:

                    Emissions of purged material resulting from
                    immediate repair greater than the fugitive
                    emissions likely to result from the delay in
                    the repir and prged material is collected
                    and destroyed or recovered in compliant
                    control device when procedures are
                    effected.

                    Delay beyond a hazardous waste
                    management unit shutdown allowed if valve
                    assemblies have been depleted, valve
                    assembly supplies had been sufficiently
                    stocked before supplies were depleted.

                    Not allowed unless next unit shutdown
                    occurs sooner than 6 months after first unit
                    shutdown.

-------
                                                                     SUMMARY OF REGULATIONS
                                                                                                                                                          page A-38
Delay of Repair
                                                                                           REGULATION
                             40 CFR part 60,
                               Subpart VV
                                           40CFRptrt6l,
                                              Subpatt J
                      40 CFR part 61,
                         Subpart V
  40 CFR part 63,
     Subpart H
40 CFR part 63,
   Subpart I
40 CFR part 264,
   Subpart BB
40 CFR part 265,
   Subpari BB
        Pumps
Allowed if:

Repair requires use of DMS seal system
that includes barrier fluid and
Allowed if;

Repair requires use of DMS seal system that
includes barrier fluid and
                 Repair completed as soon as practicable,
                 but not later than 6 months after leak was
                 detected.
                                         Repair completed as soon as practicable, but
                                         not later than 6 months after leak was
                                         detected.
Allowed if;

Repair requires replacing existing seal design
with a new system that provides better
performance under provisions of a QIP or
using a DMS, a pump designed with no
externally actuated shaft, or a compliant
closed-vent system and control device.

Repair completed as soon as practicable, but
not later than 6 months after leak was
detected.
                   Allowed if;

                   Repair requires use of DMS seal system that
                   includes barrier fluid and
                                                                                   Repair completed as soon as practicable, but
                                                                                   not later than 6 months after leak was
                                                                                   detected.
   Closed-Vent
   Systems and
Control Devices
Allowed if emissions resulting from delay
of repair would be greater than fugitive
emissions from delay of repair.  Repair
required by end of next process unit
shutdown.
Not applicable.
Allowed if emissions resulting from delay of
repair would be greater than fugitive
emissions from delay of repair.  Repair
required by end of next process unit
shutdown.
                   Allowed if emissions resulting from delay of
                   repair would be greater than fugitive
                   emissions from delay of repair. Repair
                   required by end of next process unit
                   shutdown.

-------
                                                                   SUMMARY OF REGULATIONS
                                                                                                                                                         page A-39
  Quality
Improvement
 Programs
                                                                                          REGULATION
          40 CFR part 60,
             Subpart VV
 40 CFR part 61,
    SubpartI
40 CFR part 61,
   Subpart V
40 CFR part 63,
   Subpart H
40 CFR part 63,
   Subpart I
40 CFR part 264,
   Subpart BB
40 CFR part 265,
   Subpart BB
  Applicability
Not applicable.
Not applicable.
                  Valves

                  Optional in phase III to ownersXoperators with  10% or 3 pumps leaking.

                  Once < 10% or <3 pumps (6 month rolling average)
                  leaking is achieved, comply  with .§63,163.

                  If leak  rate again exceeds the greater of either > 10% or 3
                  pumps  leaking, can use QIP again.
                                             Not applicable.

-------
                                                                    SUMMARY OF REGULATIONS
                                                                                                                                                           page A-40
                                                                                            REGULATION
   Quality
Improvement
 Programs
           40 CFR part 60,
             Subpart VV
 40 CFR part 61,
   Subpart J
40 CFR part 61,
   SubpariV
40 CFR part 63,
   Subpart H
40 CFR part 63,
   Subpart I
40 CFR pit 264,
   Subpart BB
40 CFR part 265,
   Subpart BB
      Valves,
Demonstration
    of Further
     Progress
Not applicable.
Not applicable.
                   Comply with valve standard except monitor quarterly.

                   Collect data and maintain records as follows:

                   *  maximum instrument reading observed in each
                     monitoring observation before repair, response factor
                     for each stream, instrument model number, and date of
                     observation

                   • classification of valve "gas or light liquid service"

                    * repair method used and instrument readings after repair
                     (monitoring required at least once within the first 3
                     months after the repair is eompIeted)(!D tag on a
                     leaking valve may be removed after the valve
                     successfully passes this monitoring period)

                   Continue to collect data on the valves for as long as the
                   process unit is in QIP

                   Demonstrate progress in reducing the percent leaking
                   valves each quarter by at least:

                   • 10 percent (meaning that each quarter there is at least a
                     10 percent reduction in the percent leaking valves from
                     the preceding monitoring period) [calculation to be
                     made by formula specified in §63.17S(d)(4)(i)], or

                   • alternative quarterly percent reduction [calculated
                     according to the equation in §63.175(d)(4)(iii)(A)] and
                     to less than 2 percent within 2 years.
                                                                                              The provisions for failure to meet the 10 percent reduction
                                                                                              for 2 consecutive rolling averages are:

                                                                                              *  a choice of monthly monitoring, or

                                                                                              *  implementation of a QIP for technology review as
                                                                                                 specified in §63,175(e).

-------
                                                                     SUMMARY OF REGULATIONS
                                                                                                                                                             page A-41
  Quality
Improvement
 Programs
                                                                                             REGULATION
           40 CFR part 60,
             Subpart VV
 40 CFR part 61,
    Subpart J
40 CFR part 61,
   Subpart V
40 CFR part 63,
   Subpart H
40 CFR part 63,
   Subpart I
40 CFR part 264,
   Subpart BB
40 CFR part 265,
   Subpart BB
      Valves,
   Technology
   Review and
 Improvement
Not applicable.
Not applicable.
                   Data collection for the valves as long as in QIP:

                   • Valve type and manufacturer, valve design, materials of
                     construction, packing material, and year installed.

                   « Service characteristics of the stream (e.g., operating
                     pressure, temperature, line diameter, corrosivity),

                   • Whether in gas/vapor or light liquid service.

                   * If a leak is detected, the maximum instrument reading
                     observed before a repair, response factor for stream if
                     adjusted, instrument model number, and date of
                     observation.

                   » If a leak is repaired, repair methods used and the
                     instrument readings after  the repair.

                   Inspect all valves removed due to leaks to determine cause
                   of failure  and recommend design and other changes to
                   reduce leak potential.

                   Analyze data "to determine the services, operating and
                   maintenance procedures, and valve designs or technologies
                   that have  poorer than average emission performance and
                   those that have better than average emission performance.
                   The first analysis shall be completed no later than 18
                   months after the start of Phase III, shall use a minimum of
                   6 months  of data, shall be done yearly for as long as the
                   process unit is in the QIP program.

                   Superior valve performance  is defined as:
                   * technology for valves having a leak frequency of <1%
                     for specific applications in process unit.
                   * technology has low emission performance and is
                     capable of achieving <2% leaking valves in process
                     unit.
                                              Not applicable.

-------
                                                                    SUMMARY OF REGULATIONS
                                                                                                                                                          page A-42
   Quality
Improvement
  Programs
                                                                                            REGULATION
           4QCFRprt60,
             Subpstt VV
 40CFRprt61,
    SubpartJ
40 CFR part 61,
   Subpart V
40 CFR part 63,
   SubprtH
40 CFR part 63,
   Subprtl
40 CFR part 264,
   SubpartBB
40 CFR part 265,
   SubparlBB
      Valves,
   Technology
   Review and
  Improvement
   (concluded)
Not applicable.
Not applicable.
                   Trial evaluation program is required for plants that have
                   not demonstrated superior performing valve designs and
                   technologies:

                    1.  The number of valves in the trial program shall be the
                   lesser of 1 percent or 20 valves for programs involving
                   single process units and the lesser of 1 percent or SO
                   valves for programs involving groups of process units.

                    2.  The program shall specify and include design
                   documentation of:
                   »  superior performing valve designs or technologies
                   •  stages of evaluating  these valve designs or technologies
                   *  frequency of monitoring or inspection
                   «  range of operating conditions component will be
                     evaluated under
                   •  conclusions regarding the emission performance and
                     appropriate operating conditions and services

                   The performance trials shall be conducted for a 6-month
                   period beginning no later than 18 months after the
                   beginning of the QIP.

                   Conclusions will be drawn no later than 24 months after
                   the beginning of the QIP.

                   Any plant site with fewer than 400 valves and owned by a
                   company with fewer than 100 total employees is exempt
                   from the trial evaluations of valves. These exempted
                   plants shall begin the program at the start of the fourth
                   year of Phase HI.

                   If superior emission performance technology  can not be
                   identified, replacement valve shall be one with lowest
                   emission performance technologies identified for the
                   specific application.
                                              Not applicable.

-------
                                                                    SUMMARY OF REGULATIONS
                                                                                                                                                          page A-43
                                                                                           REGULATION
  Quality
Improvement
 Programs
           40 CFR part 60,
             Subpart VV
 40 CFR part 61,
    Subpart J
40 CFR part 61,
   Subpart V
40 CFR part 63,
   Subpart H
40 CFR part 63,
   Subpart I
40 CFR part 264,
   Subpart BB
40 CFR part 265,
   Subpart BB
      Pumps,
   Technology
   Review and
 Improvement
Not applicable.
Not applicable.
                  Data collection:

                  *  Pumps:  type and manufacturer, seal type and
                     manufacturer, pump design, materials of construction,
                     barrier fluid or packing material, and year installed,

                  «  Service characteristics of the stream, discharge
                     pressure, temperature, flow rate, corrosivity, and
                     annual operating hours.

                  *  Maximum instrument readings observed before repair,
                     response factor for the stream, instrument number, and
                     date of observation.

                  »  If a leak is detected, repair methods used and the
                     instrument readings after the repair.

                  Inspect all pumps or pump seals that exhibit frequent seal
                  failure and  were removed due to leaks. Inspection shall
                  determine probable cause and recommendation for design
                  changes or  changes in specifications to reduce leak
                  potential.

                  Analyze data to determine the services, operating and
                  maintenance procedures, and pumps and pump seal designs
                  or technologies that have poorer than average emission
                  performance and those that have better than average
                  emission performance. The first analysis shall be
                  completed no later than 18 months after the start of the
                  program, shall  use a minimum of 6 months of data, shall
                  be done yearly for as long as the process unit is in the QIP
                  program.
                                              Not applicable.

-------
                                                                    SUMMARY OF REGULATIONS
                                                                                                                                                          page A-44
  Quality
Improvement
 Programs
                                                                                            REGULATION
           40 CFR part 60,
             Subpart VV
40CFRpart61,
    Subpart J
40 CFR part 61,
   Subpart V
40 CFR part 63,
   Subpart H
40 CPR part 63,
   SubptrtI
40 CHI part 264,
   Subpart BB
40 CFR part 265,
   Subpart BB
      Pumps,
   Technology
   Review and
 Improvement
   (concluded)
Not applicable.
Not applicable.
                   Superior pump performance is defined as:
                   «  pumps or pump seals that will result in <  10% leaking
                     pumps in the process unit,
                   *  includes material or design changes to the existing
                     pump, pump seal, seal support system, installation of
                     multiple mechanical seals or equivalent, or pump
                     replacement.

                   Trial evaluation program is required for plants that have
                   not demonstrated superior technologies:

                    I.  The number of pump seal technologies or pumps in
                   the trial program shall be the lesser of 1 percent or 2
                   pumps for programs involving single process units and the
                   lesser of 1 percent or 5 pumps for plant sites or groups of
                   process units. The minimum number of pumps or pump
                   seal technologies in the program shall be 1; and

                    1,  The program shall specify and include design
                   documentation of the following:
                   *  superior performing pump seal designs or technologies
                   *  stages of evaluating these pump designs or pump seal
                     technologies
                   «  frequency of monitoring or inspection
                   »  range of operating conditions component will be
                     evaluated under
                   •  conclusions regarding the emission performance and
                     appropriate operating conditions and services

                   The performance trials shall be conducted for a 6-month
                   period beginning no later than 18  months after the
                   beginning of the QIP.

                   Conclusions will be drawn no later than 24 months after
                   the beginning of the QIP.

                   Beginning at the start of the third year of the QIP for
                   plants with 400 or more valves or 100 or more employees
                   and at the start of the fourth year for others, the
                   owner/operator shall replace the pumps and pump seals
                   that are not superior technology.  Pumps or pump seals
                   shall be replaced at the rate of 20 % per year and shall
                                *ar>!a/»(*rf until all arf» «!trwrirtr ftwhnn!nffv
                                              Not applicable.

-------
                                                                       SUMMARY OF REGULATIONS
                                                                                                                                                            page A-45
 Equivalence of (or
Alternative) Means
   of Emission
   Limitation;
     General
                                                                           REGULATION
            40 CFR part 60,
              SubpartVV
  40 CFR part 61,
     SubpartJ
40 CFR part 61,
   Subpart V
40 CFR part 63,
   Subpart H
40 CFR part 63,
   Subpart I
40 CFR prt 264,
   Subpart BB
40 CFR part 265,
   Subpart BB
Equipment,
Design, and
Operational
Requirements
Owner/operator collect and verify test data
to demonstrate equivalence,

Administrator compares test data.

Administrator may condition approval.
Owner/operator collect and verify test data
for alternative means of emission limitation.
                                                              Administrator may condition approval.
                   Owner/operator collect and verify test data
                   for alternative means of emission limitation,

                   Administrator compares test data,

                   Administrator may condition approval.
                                        Not applicable.
Work Practices
Owner/operator collect and verify test data
to demonstrate equivalence.

Owner/operator demonstrates emission
reduction achieved by required work
practice.

Owner/operator demonstrates emission
reduction achieved by equivalent means of
emission limitation.

Owner/operator commits to alternative
work practices.
                     Administrator compares demonstrated
                     emission reductions.

                     Administrator may condition approval.
Owner/operator collect and verify test data
for alternative means of emission limitation.

Owner/operator demonstrates emission
reduction achieved by required work
practice (for minimum of 12 months),

Owner/operator demonstrates emission
reduction achieved by alternative means of
emission limitation.

Owner/operator commits in writing to work
practices that provide  for emission
reductions equal to or greater than emission
reductions achieved by required work
practices.

Administrator compares demonstrated
emission reductions,

Administrator may condition approval.
                   Owner/operator collect and verify test data
                   for alternative means of emission limitation.

                   Owner/operator demonstrates emission
                   reduction achieved by required work
                   practice (for minimum of 12 months).

                   Owner/operator demonstrates emission
                   reduction achieved by alternative means of
                   emission limitation.

                   Owner/operator commits to alternative
                   work practices.
                                                                                    Administrator compares demonstrated
                                                                                    emission reductions.

                                                                                    Administrator may condition approval.
                                        Not applicable.
Unique Approach
Owner/operator may offer unique approach
to demonstrate equivalency.
Owner/operator may offer unique approach
to demonstrate equivalency.
                   Owner/operator may offer unique approach
                   to demonstrate equivalency.
                                        Not applicable.
Manufacturers of
Equipment
May apply for determination of equivalency
for equipment, design, and operational
requirements.
May apply for determination of equivalency
for equipment, design, and operational
requirements.
                   May apply for determination of equivalency
                   for equipment, design, and operational
                   requirements.
                                        Not applicable.

-------
                                                                     SUMMARY OF REGULATIONS
                                                                                                                                                       page A46
Alternative Means
   of Emission
   Limitations:
 Batch Processes
                                                                           REGULATION
  40 CFR part 60,
    subpart VV
  40 CFR put 61,
     subpart J
  4QCFfiprt6I,
     subpart V
         40 CFR putt 63,
            subpart H
40 CFR part 63,
   subpart I
40 CFR part 264,
   Subpart BB
40 CFR part 265,
   subpart BB
Monitoring Option
Not applicable.
Not applicable.
Not applicable.
The batch processes provision is an alternative to complying with §§63.163 through
63.171 and §§63.173 through 63.176. Under the monitoring option for batch
processes, the standards are similar to those for continuous processes with the
monitoring frequency prorated to time in use of organic HAP.

Each time equipment is reconfigured for the production of a new product, the
reconfigured equipment is to be monitored for leaks within 30 days of start-up.  This
initial monitoring of the reconfigured equipment oan not be used in determining
percent leaking equipment in the process unit.

Connectors are to be monitored in accordance with §63.174.

Equipment other than connectors  are to be monitored based on the frequencies shown
below, which can be adjusted to accommodate process operations:

       BATCH PROCESS EQUIPMENT MONITORING FREQUENCIES
                          (other than connectors)                	
                                                                                     Batch Process Time
                                                                                     in Use (% of year)
                                                                                        0 to < 25%
                                                                                       25 to < 50%
                                                                                       50 to < 75%
                                                                                        75 to 100%
                                                                                                   Equivalent Continuous Process
                                                                                                       Monitoring Frequency
                                                                                                            Monthly
                                                                                         quarterly
                                                                                         quarterly
                                                                                        bimonthly
                                                                                         monthly
                                                                                                            Quarterly
                                                                                      annually
                                                                                    semianmially
                                                                                  three times a year
                                                                                      quarterly
                                                                                                        SemiannuaUy
                                                                                     annually
                                                                                     annually
                                                                                   semiannually
                                                                                   semiannuaily
                                                                                     If a leak is detected, It must be repaired as soon as practicable, but no later than 15
                                                                                     calendars after detection.  Delay of repair is allowed if equipment supplies have been
                                                                                     depleted and supplies had been sufficiently stocked before their depletion and the
                                                                                     repair is made no later than 10 calendar days after delivery of the replacement
                                                                                     equipment.
                             Not applicable.

-------
                                                                       SUMMARY OF REGULATIONS
                                                                                                                                                             page A47
Alternative Means
   of Emission
   Limitations:
 Batch Processes
                                                                             REGULATION
  40 CFR part 60,
     subpart VV
  40 CFR part 61,
      subpart J
  40 CFR part 61,
     subpart V
          40 CFR part 63,
             subpart H
40 CFR part 63,
   subpart I
40 CFR part 264,
   Subpart BB
40 CFR part 265,
   subpart BB
    Pressure Test
          Option
Not applicable.
Not applicable.
Not applicable.
Monitor for teaks when the equipment is in organic HAP service, in use with an
acceptable surrogate volatile organic compound which is not an organic HAP, or is in
use with any other detectable gas or vapor.

Each time equipment is reconfigured for production of a different product or
intermediate, the batch process train is to be pressure-tested for leaks before organic
HAP is first fed into the equipment.

Pressure test new or disturbed equipment when a batch process train is reconfigured.

Pressure testing not required for routine seal breaks, such as changing hoses and
filters.

Batch process equipment test using either:
»  procedures specified for pressure or vacuum loss [see §63,180(0] or
*  procedures specified for using a liquid [see §63,180(g)]

Each batch process that operates in  organic HAP service during a calendar year must
be pressure tested at least once during that same calendar year.

For pressure or vacuum tests, a leak is detected if the rate of pressure change in
excess of 6.9 kilopascals (1 psig) in 1 hour; or if there is visible, audible, or olfactory
evidence of fluid loss.

For pressure tests using a liquid, a leak is detected if there are indications of dripping
liquid or other evidence of fluid loss from process units.

When leaks are detected, repairs must be made and a retest conducted before startup
of the process.

If the process unit fails this retest or the second of 2 consecutive pressure tests, the
equipment must be repaired as soon as practicable but not later than 30 calendar days
aftef the second pressure test.
                              Not applicable.

-------
                                                                SUMMARY OF REGULATIONS
                                                                                                                                  page A-48
Alternative Means
   of Emission
   Limitations:
 Enctosed-Vented
  Process Units
                                                         REGULATION
40 CFR part 60,
  Subpart VV
40 CFR part 61,
   Subpart J
40 CFR part 61,
  Subpart V
40CPRpart63,
  Subpart H
40 CFR part 63,
   Subpart I
40 CFR pit 264,
   Subpart BB
40 CFR pare 265,
   Subpart BB
                  Not applicable.
                           Not applicable.
                                    Process units enclosed such tat all
                                    emissions from equipment teaks are venied
                                    through a closed-vent system to a control
                                    device are exempt from the requirements of
                                    §§63.163 through 63,171 and §§63.173 and
                                    63,174.

                                    Enclosure is to be maintained under
                                    negative pressure at all times the process
                                    unit is in operation,
                                                       Not applicable.

-------
                                                                       SUMMARY OF REGULATIONS
                                                                                                                                                          page A-49
 Test Methods and
    Procedures
                                                                                                REGULATION
            40 CPR part 60,
              Subpart VV
  40CFRprt61,
     Subpart I
40CFRpart61,
   Subpart V
40 CFR part 63,
   Subpart H
40 CFR part 63,
   SubpartI
40 CFR part 264,
   Subpart BB
40 CFR part 265,
   Subpart BB
Monitoring Method
and Technique
Method 21 of 40 CFR part 60, Appendix A

Test each piece of equipment unless
demonstration is made that equipment is not
in VOC service
Method 21 of 40 CFR part 60, Appendix A

Instrument to meet performance criteria of
Method 21

Traverse probe around all potential leak
interfaces as close as possible as described
in Method 21
                   Method 21 of 40 CFR part 60, Appendix A

                   Instrument to meet performance criteria of
                   Method 21 except:

                   «  response factor criteria is for the average
                     composition of the process fluid, not each
                     individual VOC in stream

                   »  for process streams that contain inerts that
                     are not organic HAPs or VOC, average
                     stream response factor is calculated on an
                     inert-free basis

                   If no instrument available that meet all Method
                   21 criteria, then instrument readings may be
                   adjusted as specified.

                   Monitor all equipment while it is "in service"
                                         Method 21 of 40 CFR part 60, Appendix A

                                         Instrument to meet performance criteria of
                                         Method 21

                                         Traverse probe around all potential leak
                                         interfaces as close as possible as described
                                         in Method 21
Calibration
Before use each day of use

Procedures specified in Method 2!

Calibration gases used:

»  zero air (less than 10 ppm hydrocarbon
   in air)

»  mixture of methane or n-hexane and air
   at about, but less than, 10,000 ppm
   methane or n-hexane
Before use each day of use

Procedures specified in Method 21

Calibration gases used:

»  zero air (less than 10 ppm hydrocarbon
   in air)

•  mixture of methane or n-hexane and air
   at about, but less than, 10,000 ppm
   methane or n-hexane
                   Before use each day of use

                   Procedures specified in Method 21

                   Calibration gases used:

                   *  zero air (less than 10 ppm of hydrocarbon
                     in air)

                   *  Phase I: mixture of methane in air at
                     concentration of about, but less than,
                     10,000 ppm

                   •  Phase II: mixture of methane  in air at
                     concentration of about, but less than:
                     10,000 ppm for agitators
                      5,000 ppm for pumps
                       500 ppm for all other equipment
                                         Before use each day of use

                                         Procedures specified in Method 21

                                         Calibration gases used:

                                         *  zero air (less than 10 ppm hydrocarbon
                                           in air)

                                         •  mixture of methane or n-hexane and air
                                           at about, but less than, 10,000 ppm
                                           methane or n-hexane

-------
                                                                     SUMMARY OF REGULATIONS
                                                                                                                                                       page A-SO
 Test Methods and
    Procedures
                                                                                              REGULATION
            40 CFR part 60,
              Subpart VV
  40 CFE part 61,
     Subpart J
40 CFR part 61,
   Subpart V
4QCFRptrt63,
   SubpartH
40 CFE part 63,
   Subprtl
40CFRprt264,
   Subpart BB
40CFRprt26S,
   Subpart BB
Calibration
(concluded)
                                                                                 •  Phase HI; mixture of methane in air at
                                                                                    concentration of about, but less than:
                                                                                     10,000 ppm for agitators
                                                                                     2,000 ppm for pumps in food/ medical
                                                                                     service
                                                                                     5,000 ppm for pumps in polymerizing
                                                                                     monomer service
                                                                                     1,000 ppm for all other pumps
                                                                                     500 ppm for all other equipment

                                                                                 Phases II and III exception:  under certain
                                                                                 conditions may calibrate up to 2,000 ppm
                                                                                 higher than the leak definition
"No detectable
emissions"
monitoring
Background level determined by Method 21

Traverse probe as close to the potential
leak interface as possible as described in
Method 21

Calculate arithmetic difference between the
msximum concentration indicated by the
instrument and the background level
compared to 500 ppm to determine
compliance
Background level determined by Method 21

Traverse probe as close to the potential leak
interface as possible as described in Method
21

Calculate arithmetic difference between the
maximum concentration indicated by the
instrument and the background level
compared to 500 ppm to determine
compliance
                  Background level determined by Method 21

                  Traverse probe as close to the potential leak
                  interface as possible as described in Method
                  21

                  Calculate arithmetic difference between the
                  maximum concentration indicated by the
                  instrument and the background level compared
                  to 500 ppm to determine compliance
                                        Background level determined by Method 21

                                        Traverse probe as close to the potential leak
                                        interface as possible as described in Method
                                        21

                                        Calculate arithmetic difference between the
                                        maximum concentration indicated by the
                                        instrument and the background level
                                        compared to 500 ppm to determine
                                        compliance

-------
SUMMARY OF REGULATIONS
page A-51
Test Methods and
Procedures
Not "in service"
demonstration





Samples
Vapor pressures
REGULATION
40 CFR part 60,
Subpart VV
Equipment must be demonstrated not to be
in VOC service (i.e., VOC content never
greater than 10% by weight).
For demonstration:
Use procedures that conform to ASTM E-
260, E-168, E-169 to determine percent
VOC in process fluid that is contained or
contacts a piece of equipment.
Engineering judgement may be used to
estimate the VOC content if piece of
equipment had not been shown previously
to be in VOC service.
Administrator will require use of ASTM
Method D-2267b in event of disagreement
to determine VOC content.
Compounds determined by EPA to have
negligible photochemical reactivity can be
excluded in determining VOC content of a
process fluid.
Representative of process fluid that is
contained in or contacts the equipment or
the gas being combusted in flare.
Standard reference texts or
ASTM D-2879
40 CFR part 61 , 40 CFR part 61 ,
Subpart J Subpart V
Equipment is presumed to be in VHAP
service unless demonstrated that the VHAP
content can never reasonably expected to
exceed 10 percent by weight.
For demonstration:
Use procedures that conform to ASTM
Method D-2267.
Engineering judgment may be used to
determine percent VHAP clearly does not
exceed 10 percent.
Administrator will require use of ASTM
Method D-2267 in event of disagreement to
determine VOC content.
If owner or operator determines that a piece
of equipment is in VHAP service,
determination can only be revised by
following demonstration procedures.
Representative of process fluid that is
contained in or contacts the equipment or
the gas being combusted in flare."
Not specified.
40 CFR part 63, 40 CFR part 63,
Subpart H Subpart I
Equipment is presumed to be in organic HAP
service unless demonstrated that the organic
HAP content can never reasonably expected to
exceed 5 percent by weight.
For demonstration:
Use Method 18 of 40 CFR part 60, appendix
A to determine percent organic HAP.
Engineering judgment may be used to
determine percent organic HAP does not
exceed 5 percent.
Owner/operator may instead determine
organic HAP content does not exceed 5
percent by weight.

Representative of process fluid that is
contained in or contacts the equipment.

40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
Test each component to determine whether
it contains or contacts a hazardous waste
with organic concentration of 10 percent by
weight or greater.
For demonstration:
Use ASTM Methods D 2267-88, E 169-87,
E 168-88, E260-85, or Method 9060 or
8240ofSW-846,
Engineering judgment may be used to
estimate organic concentration.
Regional Administrator will require the use
of ASTM Methods D 2267-88, E 169-87, E
168-88, E260-85, or Method 9060 or 8240
of SW-846 in the event of disagreement to
determine VOC content.
If owner or operator determines that a piece
of equipment contains or contacts a
hazardous waste with an organic
concentration of at least 10% be weight, the
determination can only be revised by
following the demonstration procedures, .
Representative of the highest total organic
content hazardous waste that is contained in
or contacts the equipment.
Standard reference texts or
ASTM D-2879-86

-------
                                                                     SUMMARY OF REGULATIONS
                                                                                                                                                      page A-52
 Test Methods and
    Procedures
                                                                                              REGULATION
            40 CFR part 60,
              Subpart VV
  40 CFR pit 61,
     Subpart J
40 CFR part 61,
   SubpartV
40 CFR part 63,
   Subpart H
40 CFR part 63.
   Subpart I
40 CFR part 264,
   Subpart BB
40 CFR part 265,
   Subpart BB
Flare Compliance
Visible emissions:  Method 22

Presence of flame; thermocouple or
equivalent
                    Exit velocity:  Method 2, 2A, 2C, or 2D

                    Component concentration; Method 18 and
                    ASTM D 2504-67

                    Net Heat of Combustion:  Published values
                    or ASTM D 2382-76, if published values
                    not available or cannot be calculated
Visible emissions: Method 22

Presence of flame:  thermocouple or
equivalent
                                        Exit velocity:  Method 2,2A, 2C, or 2D

                                        Concentration: Method 18 or ASTM
                                        D2509-67.

                                        Net Heat of Combustion:  published value
                                        or ASTM D2382-76, if pblished values not
                                        available or cannot be calculated
                  Visible emissions:  Method 22

                  Presence of flame:  thermocouple or
                  equivalent
                                        Exit velocity:  Method 2,2A, 2C, or 2D

                                        Concentration: Method 18
                                        Net Heat of Combustion:  published value or
                                        ASTM D2382-76, if published values not
                                        available or cannot be calculated
                                        Visible emissions: Method 22

                                        Presence of flame:  heat sensing monitoring
                                        device with a continuous recorder that
                                        indicates the continuous ignition of the pilot
                                        flame

                                        Exit velocity: Method 2, 2A, 2C, or 2D

                                        Concentration: Method 18
                                                             Net Heat of Combustion:  published value
                                                             or ASTM D2382-76, if published values not
                                                             available or cannot be calculated
Batch Processes -
Pressure Test with
Gas or Vacuum
Not applicable.
Not applicable.
                  Pressurize to operating pressure or place under
                  vacuum

                  Turn offence test pressure or vacuum is
                  obtained

                  Test for at least 15 minutes

                  Calculate change in pressure

                  Use pressure measurement device with
                  accuracy  of+.2.5 millimeters of mercury

                  Alternative equivalent procedures are allowed
                  provided  alternative is capable of detecting a
                  pressure loss or rise.
                                        Not applicable.

-------
                                                                 SUMMARY OF REGULATIONS
                                                                                                                                                page A-53
Test Methods and
   Procedures
                                                                                         REGULATION
           40 CFR part 60,
             Subpatt VV
  40CFRpart61,
     Subpart J
40CFRpart61,
  Subpart ¥
40 CFR part 63,
   Subpart H
40 CFR part 63,
   Subpart I
40 CFR part 264,
   Subpart BB
40 CFR part 265,
   Subpart BB
 Batch Processes -
Pressure Test with
          Liquid
Not applicable.
Not applicable.
                 Fill with test liquid until normal operating
                 pressure is obtained.

                 Test for at least 60 minutes, unless test fails
                 before then.

                 Inspect each seal for indications of fluid loss.
                 If indications are found, a leak is detected,

                 Alternative equivalent procedures are allowed
                 provided alternative is capable of detecting
                 fluid loss.
                                      Not applicable.

-------
                                                                       SUMMARY OF REGULATIONS
                                                                                                                                                          page A-54
  Record keeping
   Requirements
                                                                                         REGULATION
           40CFRpart60,
             Subpart VV
 40 CFR part 61,
    Subpart J
40 CFR part 61,
   Subpirl V
40 CFR part 63,
   Subpart H
40 CPR part 63,
   Subpartl
40 CFR part 264,
   Subprt BB
40 CFR part 265,
   Subprt BB
Consolidated
Rceordteeping
An owner or operator of more than one
affected facility subject to this subpart
may use one recordkeeping system if the
system identifies each record by facility.
An owner or operator of more than one
process unit subject to this subpart may
use one recordkeeping system if the
system identifies each record by process
unit.
                  An owner or operator of more than one
                  process unit subject to this subpart may
                  use one recordkeeping system if die
                  system identifies each record by process
                  unit and the program being implemented
                  for each type of equipment.
                                      An owner or operator of more than one
                                      hazardous waste management unit
                                      subject to this subpart may use one
                                      recordkeeping system if the system
                                      identifies each record by hazardous
                                      waste management unit.
When leak detected
Tagging Requirements

•  a weather-proof and readily visible
   identification, marked with the
   equipment ID number, attached to the
   leaking equipment
                       ID may be removed after it lias been
                       repaired, except for valves
                       for valves, ID may be removed after
                       2 months of monitoring with no leaks
                       detected
                     Log Requirements

                     «  instrument and operator ID numbers
                       and equipment ID number
                     «  date leak detected

                     (Continued on next page)
Tagging Requirements

•  a weather-proof and readily visible
   identification, marked with the
   equipment ID number, attached to the
   leaking equipment
                                         ID may be removed after it has been
                                         repaired, except for valves
                                         for valves, ID may be removed after
                                         2 months of monitoring with no leaks
                                         detected
                                       Log Requirements

                                       « instrument and operator ID numbers
                                         and equipment ID number
                                       * date leak detected

                                       (Continued on next page)
                  Tagging Requirements

                  *  a weather-proof and readily visible
                     identification, marked with the
                     equipment ID number, attached to the
                     leaking equipment
                                         ID may be removed after it has been
                                         repaired, except for valves and
                                         connectors

                                         for valves and connectors, ID may be
                                         removed after it has been monitored
                                         as specified and no leak has been
                                         detected during the follow-up
                                         monitoring
                                       Log Requirements

                                       *  instrument and equipment ID number,
                                          and operator name, initials, and ID
                                          number
                                       « date leak detected

                                       (Continued on next page)
                                      Tagging Requirements

                                      •  a weather-proof and readily visible
                                         identification, marked with the
                                         equipment ID number, date evidence
                                         of potential leak found (heavy liquid
                                         service only), and date leak detected,
                                         attached to the leaking equipment

                                      •  ID may be removed after it has been
                                         repaired, except for valves
                                                            for valves, ID may be removed after
                                                            2 months of monitoring with no leaks
                                                            detected
                                                          Lop Requirements

                                                          •  instrument and operator ID numbers
                                                            and equipment ID number

                                                          •  date evidence of potential leak found
                                                            (only for equipment in heavy liquid
                                                            service, pressure relief devices in
                                                            light liquid service, and flanges and
                                                            other connectors)

                                                          *  date leak detected

                                                          (Continued on next page)

-------
                                                                         SUMMARY OF REGULATIONS
                                                                                                                                                            page A-55
  Recordkeeping
   Requirements
                                                                                            REGULATION
        40 CFR part 60,
          Subpart VV
40 CFR part 61,
   Subpart J
40 CFR part 61,
   Subpart V
40 CFR part 63,
   Subpart H
40 CFR part 63,
   Subpart I
40 CFR part 264,
   Subpart BB
40 CFR part 265,
   Subpart BB
When leak detected
(concluded)
dates of each attempt to repair leak

repair methods applied in each
attempt to repair

"above 10,000" if maximum
instrument reading after each repair
attempt is J>. 10,000 ppm

"repair delayed" and reason for delay
if leak is  not repaired within 15
calendar days after detection

signature of owner/operator whose
decision it was that repair could not
be effected without a process
shutdown
                        expected date of successful repair if
                        leak is not repaired within the 15
                        days
                     « dates of process unit shutdown that
                       occurred while the equipment is
                       unrepaired

                     * date of successful repair of the leak

                     Retain for 2 years in readily accessible
                     location.
  dates of each attempt to repair leak

  repair methods applied in each
  attempt to repair

  "above  10,000" if maximum
  instrument reading after each repair
  attempt is J>, 10,000 ppm

  "repair delayed" and reason for delay
  if leak is not repaired within 15
  calendar days after detection

  signature of owner/operator whose
  decision it was thai repair could not
  be effected without a process
  shutdown
                                        expected date of successful repair if
                                        teak is not repaired within the 15 days
                                     •  dates of process unit shutdown that
                                        occurred while the equipment is
                                        unrepaired

                                     «  date of successful repair of the leak

                                     Retain for 2 years in readily accessible
                                     location.
                      dates of first attempt to repair leak
                   «  maximum instrument reading after
                      successful repair or determined to be
                      nonreparable

                   •  "repair delayed" and reason for delay
                      if leak is not repaired within 15
                      calendar days after detection

                   «  documentation of sufficient supply of
                      spare parts on-site before depletion
                      and reason for depletion if repair
                      delayed because stocked parts were
                      depleted

                   *  ID of connectors open or otherwise
                      had the seal broken since last
                      monitoring period, and dates and
                      results of follow-up monitoring

                   «  dates and results of monitoring

                   •  dates of process unit shutdown that
                      occurred while the equipment is
                      unrepaired

                   •  date of successful repair of the leak

                   Retain for 2 years in a manner that can
                   be readily accessed at the plant site.
                                          dates of each attempt to repair leak

                                          repair methods applied in each
                                          attempt to repair

                                          "above 10,000" if maximum
                                          instrument reading after each repair
                                          attempt is >, 10,000 ppm

                                          "repair delayed" and reason for
                                          delay if leak is not repaired within 15
                                          calendar days after detection

                                          signature of owner/operator whose *
                                          decision it was that repair could not
                                          be effected without a unit shutdown
                                                                                  expected date of successful repair if*"
                                                                                  leak is not repaired within the 15
                                                                                  days

                                                                                  documentation supporting delay of
                                                                                  repair of a valve
                                                                               •  date of successful repair of the leak

                                                                               Log to be kept in the facility operating
                                                                               record for 3 years.

-------
                                                                         SUMMARY OF REGULATIONS
                                                                                                                                                              page A-56
  Recordteping
   Requirements
                                                                                            REGULATION
           40 CFR pan 60,
             Subpari VV
 40 CFR part 61,
    SubpartJ
40 CFR part 61,
   SubpartV
40 CFR part 63,
   SubpartH
40 CFR part 63,
   Subpari I
40 CFR part 264,
   Subpari BB
40 CFR part 265,
   Subprt BB
Closed vent
systems and control
devices
*  detailed schematics, design
   specifications, and piping and
   instrumentation diagrams

•  dates and descriptions of any changes
   in design specifications

•  description of parameters) to be
   monitored to ensure proper operation
   and maintenance

•  explanation of selection of
   parameter(s)

«  periods when not opented according
   to design

•  dates of startups and shutdowns of
   control devices and closed-vent
   systems

When no leak detected;
   -  record that instrument of visual
     inspection was conducted
   -  date of inspection
   -  statement that no leaks were
     detected

For unsafe and difficult to inspect parts
of closed-vent system;
   -  identification
   -  explanation
   -  plan for inspecting equipment

Keep these  records in a readily
accessible location.
•  detailed schematics, design
   specifications, and piping and
   instrumentation diagrams

•  dates and descriptions of any changes
   in design specifications

•  description of parameter® to be
   monitored to ensure proper operation
   and maintenance

•  explanation of selection of
   parameters)

*  periods when not operated according
   to design, including when flare pilot
   light is out

«  dates of startups and shutdowns of
   control devices and closed-vent
   systems

Keep these  records in a readily
accessible location.
                   Design Specifications and Performance
                   Demonstration:

                   *  detailed schematics, design
                      specifications, and piping and
                      instrumentation diagrams

                   •  dates and descriptions of any changes
                      in design specifications

                   «  description of parameter® to be
                      monitored to ensure proper operation
                      and maintenance

                   »  flare design and compliance
                      demonstration results

                   *  explanation of selection of
                      parameter(s)

                   The design specification and
                   performance demonstration records are
                   to be kept for the life of the equipment.
                                       Description and date of each
                                       modification made to the closed-vent
                                       system or control device design.

                                       Identification of operating parameter,
                                       description of monitoring device, and
                                       diagram of monitoring sensor
                                       location(s) for the following types of
                                       monitoring devices:  vent stream flow,
                                       temperature, heat sensing, organic
                                       concentration, regeneration cycles for
                                       carbon beds, and good combustion
                                       practices.

                                       Monitoring, operating, and inspection
                                       information required by paragraphs
                                       §§63.1033 (f) through (j).

                                       Date, time, and duration of each period
                                       that occurs while the control device  is
                                       operating when any monitored
                                       parameter exceeds the value established
                                       in the control device design analysis.

                                       Explanation for each period for which
                                       monitored parameter exceeded the
                                       established value.

                                       For carbon adsorption systems, date
                                       when existing carbon in the control
                                       device is replaced with fresh carbon or,
                                       if monitoring the organic concentration
                                       to determine breakthrough, date and
                                       time of carbon breakthrough and date
                                       when existing carbon is replaced with
                                       fresh carbon.

-------
                                                                        SUMMARY OF REGULATIONS
                                                                                                                                                            page A-57
  Recordkeeping
   Requirements
                                                                                           REGULATION
           40 CFR part 60,
             Subpart VV
 40 CFR part 61,
    Subpart J
40 CFR part 61,
   Subpart V
40 CFR part 63,
   Subpart H
40 CFR part 63,
   Subpart I
40 CFR part 264,
   Subpart BB
40 CFR part 265,
   Subpart BB
Closed vent
systems and control
devices (concluded)
                                                                               Records of Operation:
                                                                               «  records of operation of closed-vent
                                                                                 systems and control devices
                                                                               *  dates and duration when closed-vent
                                                                                 systems, and control devices not
                                                                                 operated according to design
                                                                               •  dates and duration when monitoring
                                                                                 systems/devices are nonoperative
                                                                               »  dates of startups and shutdowns
                                                                               •  records of closed-vent inspections
                                                                                                   The records of operation are to be kept
                                                                                                   for 2 years.
                                                                               Part 264:
                                                                               •  For "other" control devices, the
                                                                                  Regional Administrator will specify
                                                                                  the appropriate recoidkeeping
                                                                                  requirements,

                                                                               Part 265:
                                                                               •  For "other" control devices,
                                                                                  monitoring and inspection
                                                                                  information indicating proper
                                                                                  operation and maintenance.

                                                                               Keep these records up-to-date in the
                                                                               facility operating record. Operating
                                                                               information is to be kept for 3 years.
Visual inspections
Not applicable.
Not applicable.
                   Documentation that inspection was
                   conducted

                   Dates of inspection

                   These records are to be kept for 2 years.
                                       Not applicable.
All equipment...
List of ID numbers of subject equipment
                     List of ID numbers of equipment
                     designated for no detectable emissions
                     and signed by owner/operator

                     List of ID numbers for pressure relief
                     devices in gas/vapor service

                     For each compliance test for
                     components designated for no detectable
                     emissions:
                     •  dates conducted
                     •  background level measured
                     •  maximum instrument reading

                     List of ID numbers of equipment in
List of ID numbers of subject equipment
(except welded fittings)

List of ID numbers of equipment
designated for no detectable emissions
and signed by owner/operator

List of ID numbers for pressure relief
devices in gas/vapor service

For each compliance test for components
designated for no detectable emissions:
• dates conducted
* background level measured
• maximum instrument reading

List of ID numbers of equipment in
vacuum service
                   List of ID numbers of subject equipment
                   (except certain connectors)

                   Location of equipment on site plan, log
                   entries, etc.

                   Connectors do not need to be
                   individually identified if all connectors in
                   a designated area or length of pipe are
                   identified as a group and the number of
                   connectors is identified

                   Schedule by process unit for monitoring
                   connectors and valves

                   Identification of equipment in HAP
                   service by tagging, identified on a plant
                   site plan, in log entries, or other
                   methods
                                       List of ID numbers of subject
                                       equipment (except welded fittings)

                                       List of ID numbers of equipment
                                       designated for no detectable emissions
                                       and signed by owner/operator

                                       List of ID numbers for pressure relief
                                       devices in gas/vapor service

                                       For each compliance test for
                                       components designated for no detectable
                                       emissions:
                                       *  dates conducted
                                       •  background level measured
                                       •  maximum instrument reading

                                       List of ID numbers of equipment in
                                       vacuum service

-------
                                                                      SUMMARY OF REGULATIONS
                                                                                                                                                         page A-58
  RecortBceepng
   Requirements
                                                                                         REGULATION
           40CFRprt60,
             SubpartVV
 40CPRprl61,
    SubpartJ
40CFRpart61,
   Subpirt V
40CFRpart63,
   SubpartH
40CFRptrt63,
   SubpartI
40 CM part 264,
   SubpartBB
40 CFR part 265,
   Subpart BB
All equipment ...
(continued)
Maintain records in a readily accessible
location.
Maintain records for 2 years in a readily
accessible location.
                  List of ID numbers for equipment
                  equipped with a closed-vent system and
                  control device.

                  For each compliance test for components
                  designated for no detectable emissions:
                  •  dates conducted and results
                  «  background level measured
                  •  maximum instrument reading.

                  List of ID numbers of compressors and
                  pressure relief devices complying with
                  an instrument reading of less than 500
                  ppm above background standard.

                  ID of surge control vessels or bottoms
                  receivers equipped with  a closed-vent
                  system or control device,

                  ID of pressure relief devices equipped
                  with rupture disks,

                  ID of instrumentation systems (individual
                  components need not be  identified).

                  ID of screwed connectors complying
                  with §63.174(c)(2). Identification can be
                  fcy grouping or area.

                  ID of connectors opened since last
                  monitoring period.

                  List of valves and connectors removed
                  from or added to the process if net
                  credits for the removal or the valves or
                  connectors are expected  to be used.

                  Documentation of the integrity of die
                  weld for removed connectors.
                                      For open-ended valves or lines, list of
                                      ID numbers of subject valves and lines,

                                      ID numbers for equipment that contains
                                      or contacts hazardous waste with an
                                      organic concentration of at least 10%
                                      by weight for a period of fewer than
                                      300 hours per year.

                                      Equipment identification number and
                                      hazardous waste management unit
                                      identification.

                                      Information to be kept for pumps
                                      equipped with a dual mechanical seal:
                                      » design criteria for indicating failure
                                      » explanation for selected criteria
                                      * any changes to the criteria and the
                                        reason for change.

                                      Approximate facility location on facility
                                      plot.

                                      T^pe of equipment.

                                      Percent-by-weight of total organics in
                                      hazardous waste at the equipment.

                                      Hazardous waste state at the equipment.

                                      Method of compliance.

                                      Retain in a log that is kept in the facility
                                      operating record.

-------
SUMMARY OF REGULATIONS
page A-59
Recordkeeping
Requirements
All equipment ...
(concluded)
Unsafe to Monitor
Equipment
Difficult to Monitor
Equipment
Unsafe to Repair
Connectors
Valves complying
with alternative
standard for skip-
periods
Barrier fluid and
seal systems
REGULATION
40 CFR part 60,
Subpart VV

List of ID numbers
Planned schedule for monitoring
List of ID numbers
Explanation for designation
Planned schedule for monitoring
Not applicable.
Schedule of monitoring
Percent valves leaking during each
monitoring period
Design criteria for indicating failure
Explanation for selected criteria
Any changes to selected criteria and
reasons for change
40 CFR part 61 , 40 CFR part 61 ,
Subpart J Subpart V

List of ID numbers
Planned schedule for monitoring
List of ID numbers
Explanation for designation
Planned schedule for monitoring
Not applicable.
Schedule of monitoring
Percent valves leaking during each
monitoring period
Design criteria for indicating failure
Explanation for selected criteria
Any changes to selected criteria and
reasons for change
40 CFR part 63, 40 CFR part 63,
Subpart H Subpart I
Design criteria, explanation, and
changes to criteria of any pumps
equipped with a dual mechanical seal.
Copies of periodic reports (if database
not capable of generating such).
Maintain records in a manner that is
readily accessible at the plant site.
List of ID numbers
Planned schedule for monitoring
List of ID numbers
Explanation for designation
Planned schedule for monitoring
List of ID numbers
Explanation for designation
Not applicable.
Design criteria for indicating failure
Explanation for selected criteria
Any changes to selected criteria and
reasons for change
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB

List of ID numbers
Planned schedule for monitoring
List of ID numbers
Explanation for designation
Planned schedule for monitoring
Not applicable.
Schedule of monitoring
Percent valves leaking during each
monitoring period
Design criteria for indicating failure
Explanation for selected criteria
Any changes to selected criteria and
reasons for change

-------
                                                                      SUMMARY OF REGULATIONS
                                                                                                                                                         page A-60
  Recordkeeping
   Requirements
                                                                                         REGULATION
           40 CFR part 60,
             SubpartVV
 40 CFR part 61,
    SubpartJ
40 CFR part 61,
   SubpartV
40 CFR part 63,
   SubpartH
40 CFR part 63,
   Subpart I
40CFRpart2fi4,
   Subpart BB
40CPRpan265,
   Subpart BB
Exemptions
Determinations
Analysis demonstrating facility design
capacity

Statement listing feed or raw materials
and products from facility and analysis
demonstrating whether these chemicals
are heavy liquids or beverage alcohols

Analysis demonstrating that equipment is
not in VOC service
Analysis demonstrating facility design
capacity

Analysis demonstrating that equipment is
not in VHAP service
                  Information and data used to
                  demonstrate that equipment is not in
                  organic HAP service, is in HAP service
                  fewer than 300 hours per year,  or is in
                  heavy liquid service
                                      Analysis determining the design
                                      capacity of ihe unit

                                      Statement listing the hazardous waste
                                      influent to and effluent from each
                                      subject unit and an analysis determining
                                      whether these wastes are heavy liquids

                                      Up-to-date analysis and supporting
                                      information to determine whether or
                                      equipment is  subject to this subpart,  A
                                      new determination is required when the
                                      owner/operator takes any action that
                                      could result in an increase in the  total
                                      organic content of the waste contained
                                      in or contacted by closed vent systems
                                      and control devices previously
                                      determined not subject to this rule
Not "In service"
Information and data used to
demonstrate that a piece of equipment is
not in VOC service
Information and data used to
demonstrate that a piece of equipment is
not in VHAP service
                  Information, data, and analysis used to
                  demonstrate that a piece of equipment or
                  process unit is in heavy liquid service
                                      Not specified.
Batch Processes
Not applicable.
Not applicable.
                  Monitoring of Batch Processes

                  List of equipment added since last
                  monitoring period

                  Record inspection performed if no leaks
                  found

                  Documentation of any switch from batch
                  process monitoring to pressure testing or
                  vice versa

                  Identify equipment on a plant site plan,
                  in log entries, or by other appropriate
                  methods
                                      Not applicable.

-------
                                                                     SUMMARY OF REGULATIONS
                                                                                                                                             page A-61
  Recbrdkeeping
   Requirements
                                                                                        REGULATION
40 CFR part 60,
  SubpartVV
40 CFR part 61,
   Subpart J
40 CFR part 61,
   Subpart V
40 CFR part 63,
   Subpart H
40 CFR part 63,
   Subpart I
40 CFR part 264,
   Subpart BB
40 CFR part 265,
   Subpart BB
Batch Processes
(concluded)
                                                                  Pressure Test of Batch Processes

                                                                  ID of each product, or product code,
                                                                  produced during calendar year

                                                                  Records demonstrating the proportion of
                                                                  the time during the calendar year the
                                                                  equipment is in use in a batch process
                                                                  that is subject to the provisions of this
                                                                  subpart

                                                                  Date and results of monitoring for
                                                                  equipment added to the batch process
                                                                  unit since the last monitoring period

                                                                  Physical tagging not required; may be
                                                                  identified on plant site plan, in log
                                                                  entries, other appropriate methods

                                                                  Dates of each pressure test, the test
                                                                  pressure, and the pressure drop observed
                                                                  during the  pressure test

                                                                  Records of any visible, audible, or
                                                                  olfactory evidence  of fluid loss

                                                                  Failure of two consecutive pressure
                                                                  tests.  Record the following and keep for
                                                                  two years:

                                                                  •  date of each pressure test

                                                                  •  date of each leak repair attempt

                                                                  «  repair methods applied

                                                                  •  reason for delay of repair

                                                                  •  expected and actual delivery date of
                                                                     replacement equipment

                                                                  *  date of successful repair

-------
SUMMARY OF REGULATIONS
page A-62
Record keeping
Requirements
No detectable
emissions
REGULATION
40CFRparl60.
Subpart W
Background level
Maximum instrument reading
40 CFR part 61,
Subpart J
40 CFR part 61,
SubptrtV
Background level
Maximum instrument reading
40 CFR pan 63,
Subpart H
40 CFR part 63,
Subpart I
Nor applicable.
40 CPR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
Background level
Maximum instrument reading

-------
                                                                      SUMMARY OF REGULATIONS
                                                                                                                                                         page
  Recordkeeping
   Requirements
                                                                                         REGULATION
          40 CFR part 60,
            Subpart VV
 40 CFR part 61,
    Subpart I
40 CFR part 61,
   Subpart V
40 CFR part 63,
   Subpart H
40 CFR part 63,
   Subpart I
40 CFR part 264,
   Subpart BB
40 CFR part 265,
   Subpart BB
QIP
Not applicable.
Not applicable.
                  If leak not repaired within 15 calendar
                  days of discovery, reason for leak repair
                  delay and expected date of successful
                  repair

                  Records of all analyses required under
                  ff63.175(e) and §63,176(d), including:

                  *  list identifying areas associated with
                     poorer than average performance and
                     the associated service characteristics
                     of the stream, the operating
                     conditions, and maintenance practices

                  «  reasons for rejecting specific
                     candidate superior emission
                     performing valve or pump technology
                     from performance trials

                  «  list of candidate superior emission
                     performing valve or pump
                     technologies and documentation of
                     performance trial program items

                  *  beginning date and duration of
                     performance trials of each candidate
                     superior emission performing
                     technology

                  Records documenting the quality
                  assurance program

                  Records indicating all valves or pumps
                  replaced or modified are in compliance
                  with the quality assurance requirements

                  Records documenting compliance with
                  the 20 percent or greater annual
                  replacement rate for pumps

                  Information and data showing company
                  has less than 100 employees
                                      Not applicable.

-------
SUMMARY OF REGULATIONS
page A-64
Reeordkeeplng
Requirements
QIP - Reasonable
further progress






REGULATION
40 CFR part 60,
Subpart VV
Not applicable.






40 CFR part 61, 40 CFR part 61,
Subpart J Subpart V
Not applicable.






40 CFR part 63, 40 CFR part 63,
Subpart H Subpart I
For each valve in each process unit
subject to the Q[P:
• maximum instrument reading
observed in each monitoring
observation before repair, response
factor for the stream (if appropriate),
instrument model number, and date of
the observation
• whether the valve is in gas or light
liquid service
* if a leak is detected, the repair
methods used and the instrument
readings after repir
If data analyzed as part of a larger
analysis program; describe any
maintenance or QIP intended to improve
emission performance
Percent leaking valves and rolling
average percent reduction observed each
quarter
Beginning and end dates while meeting
the requirements of the QIP
40 CFR part 264,
Subpart BB
40 CFR part 265,
Subpart BB
Not applicable.







-------
                                                                     SUMMARY OF REGULATIONS
                                                                                                                                                       page
  Reeordkeeping
   Requirements
                                                                                        REGULATION
          40 CFR part 60,
            Subpart VV
 40 CFR part 61,
   Subpart J
40 CFR part 61,
   Subpart V
 40 CFR part 63,
.    Subpart H
40 CFR part 63,
   Subpart I
40 CFR part 264,
   Subpart BB
40 CFR part 265,
   Subpart BB
QIP - Technology
review and
improvement
Not applicable.
Not applicable.
                                                                            Type and manufacturer, design,
                                                                            materials of construction, packing
                                                                            material, and year installed

                                                                            Service characteristics of the stream
                                                                            (e.g., operating pressure, temperature,
                                                                            line diameter, corrosivity)

                                                                            Whether in gas/vapor or light liquid
                                                                            service

                                                                            If a leak is detected, the maximum
                                                                            instrument reading observed before a
                                                                            repair, response factor for stream if
                                                                            adjusted, instrument model number, and
                                                                            date of observation

                                                                            Repair methods used and the instrument
                                                                            readings after the repair

                                                                            Description of any maintenance or
                                                                            qualify assurance program used in the
                                                                            process unit that are intended to improve
                                                                            performance

                                                                            Percent leaking valves observed each
                                                                            quarter

                                                                            Documentation of al! inspections and
                                                                            recommendations for design or
                                                                            specification changes to reduce leak
                                                                            frequency

                                                                            Beginning and end dates while meeting
                                                                            requirements of the QIP
                                                         Not applicable.

-------
SUMMARY OF REGULATIONS
page A-66
Record keeping
Requirement
QIP - Technology
review and
improvement
(concluded)









Enclosed Vent
Process



REGULATION
40 CFR part 60,
Subptrt W











Not applicable.



40 CFR part 61, 40 CHI part 61,
SubpartJ SubpartV











Not applicable.



40 CFR partffl, 40 CFR part 63,
Sulprt H Subpt rt I
te,
Type and manufacturer, sea! type and
manufacturer, pump design, materials of
construction, barrier fluid or packing
material, and year installed
Service characteristics of the stream,
discharge pressure, temperature, flow
rate, corrosivity, and annual operating
hours
Maximum instrument readings observed
before repair, response factor for the
stream, instrument number, and date of
observation
If a leak is detected, repair methods used
and the instrument readings after the
repair
Rolling average percent leaking pumps
Documentation of all inspections and
recommendations for design or
specification changes to reduce leak
frequency
Beginning and end dates while meeting
requirements of the QIP
ID of process units and organic HAPs
handled
Schematic of process unit, enclosure,
and closed-vent system
Description of system used to create
negative pressure
40 CFR part 264,
Subpart BB
40 CFR part 265.
SubpnrtBB











Not appiicable.




-------
                                                                       SUMMARY OF REGULATIONS
                                                                                                                                                            page A-67
    Reporting
   Requirements
                                                                                          REGULATION
           40 CFR part 60,
             Subpart VV
 40 CFR part 61,
    Subpart 1
40 CFR part 61,
   Subpart V
40 CFR part 63,
   Subpart H
40 CFR part 63,
   Subpart I
40 CFR part 264,
   Subpart BB
40 CFR part 265,
   SubpirtBB
Initial Report
Process unit identification

Number of valves in gas/vapor and light
liquid service, excluding those
designated for no detectable emissions

Number of pumps in light liquid service,
excluding those designated for no
detectable emissions or equipped with a
compliant closed-vent system or control
device

Number of compressors, excluding
those designated for no detectable
emissions or equipped with a compliant
closed-vent system and control device
For each source:

•  equipment identification number

*  process unit identification

•  type of equipment

•  percent weight VHAP

*  process fluid state

•  method  of compliance

Reporting schedule for submittal of ,
subsequent semiannual reports

An owner or operator is also required to
submit a statement notifying the
Administrator that the requirements of
this subpart are being implemented. For
existing sources and new sources with an
initial startup date preceding the effective
date, this notification is to be submitted
within 90 days of the effective date. For
new source with an initial startup date
after the compliance date, this
notification is to be submitted with the
application for approval of construction.
                   Initial Notification

                   «  name and address of owner/operator

                   •  address of facility (physical location)

                   •  identification of subject processes

                   •  compliance statement

                   •  statement of whether a source can
                     achieve compliance by the applicable
                     compliance date

                   Notification of Compliance Status (for
                   each subject process unit)

                   A. For each subject unit:

                   •  process unit identification

                   •  number of each equipment type
                     (except those in vacuum service)

                   «  method of compliance

                   •  planned schedule for each phase (for
                     light liquid  pumps and gas/vapor
                     valves)

                   B. Batch processes:

                   •  batch products or product codes

                   •  planned schedule for testing

                   C, Enclosed-vented process units:

                   *  process unit identification

                   •  description of negative pressure
                     system and control device
                                       Not specified.

-------
                                                                        SUMMARY OF REGULATIONS
                                                                                                                                                            page A-68
    Reporting
   Requirements
                                                                                           REGULATION
           40CFRpart60,
             Subpart VV
 40CFRp»rt6l,
    Subpart J
40CFRprt61,
   Subptrt V
40CFRpart63,
   Subpart H
4QCFRpart63,
   SubpartI
40CFRprt264,
   Subjwrt BB
40 CPR part 265,
   Subpart BB
Subsequent
Semiannual/
Periodic Reports
Process unit identification

The following information by month in
the reporting period:

•  number of valves, pumps, and
   compressors for which leaks were
   detected

•  number of valves, pumps, and
   compressors for which leaks were not
   repaired as required

»  the facts that explain each delay of
   repair, and where appropriate, why a
   process unit shutdown was technically
   infeasible

Dates of process unit shutdowns that
occurred within the semiannual
reporting period

Revisions to items reported in the initial
semiannual report if changes have
occurred since the initial  semiannual
report or subsequent revisions to the
initial semiannual report

Report of all performance tests in
accordance with §60.8
Process unit identification

The following information by month in
the reporting period:

• number of valves, pumps, and
  compressors for which letks were
  detected

• number of valves, pumps, and
  compressors for which leaks were not
  repaired as required

* the facts that explain each delay of
  repair, and where appropriate, why a
  process unit shutdown was technically
  infeasible

Dates of process unit shutdowns that
occurred within the semiannual reporting
period

Revisions to items reported in the initial
semiannual report if changes have
occurred since the initial semiannual
report or subsequent revisions to the
initial semiannual report
                   Submit the following information semi-
                   annually starting 6 months after the
                   Notification of Compliance:

                   • the number of valves, pumps,
                     compressors, agitators, connectors,
                     and screwed connectors for which
                     leaks were detected

                   * the percent leakers for valves, pumps,
                     connectors, and screwed connectors

                   • the total number of valves, pumps,
                     connectors, and screwed connectors
                     monitored

                   * the number of valves, pumps,
                     compressors, agitators, connectors,
                     and screwed connectors for which
                     leaks were not repaired

                   * identification of (he number of valves
                     and connectors determined to be
                     nonreparable

                   * explanation of why repairs delayed and
                     why process unit shutdown was
                     infeasible

                   • notification of change in connector
                     monitoring alternatives (if applicable)

                   Revisions to items reported in the
                   notification of compliance status if
                   method of compliance has changed since
                   the last report

                   Information listed under Notification of
                   Compliance Status for process units with
                   later compliance dates

                   For "no detectable emissions"
                   components: all monitoring to show
                                       NOTE:  The following is applicable to
                                       40 CFR part 264, subpart BB only.

                                       The EPA identification number, name,
                                       and address of the facility.

                                       The following information by month in
                                       the reporting period:

                                       » equipment identification number of
                                         each valve, pump, and compressor
                                         for which leaks were not repaired as
                                         required

                                       « dates of hazardous waste management
                                         unit shutdowns that occurred within
                                         the Semiannual reporting period

                                       • dates when the required control
                                         device exceeded or operated  outside
                                         design specifications and was not
                                         corrected within 24 hours, the
                                         duration and cause of each
                                         exceedance, and any corrective
                                         measures taken.

                                       If during the semiannual reporting
                                       period, pumps, valves, and connectors
                                       are repaired as required  and the control
                                       device does not exceed or operate
                                       outside of design specifications for
                                       more than 24 hours, a report to the
                                       Regional Administrator is not required.

-------
                                                                      SUMMARY OF REGULATIONS
                                                                                                                                                        page A-69
    Reporting
   Requirements
                                                                                        REGULATION
          40CFRpart60,
            Subpart VV
 40 CFR part 61,
    Subpart J
40 CFR part 61,
   Subpart V
40 CFR part 63,
   Subpart H
40 CFR part 63,
   Subpart I
40 CFR part 264,
   Subpart BB
40 CFR part 265,
   Subpart BB
Batch Processes -
Pressure Testing
Not applicable.
Not applicable.
                  Batch product process equipment train
                  identification.

                  Number of pressure tests conducted.

                  Number of felled pressure tests.

                  Explanation of delay of repairs.

                  All monitoring results.
                                      Not applicable.
Other
Notification 90 days prior to election to
comply with either alternative standard
for valves in gas/vapor service.

Report of all performance test in
accordance with §60.8, except 30 day
notification required only for initial
performance test.
Notification 90 days prior to complying
with either alternative standard for
valves in gas/vapor service.-

Report of all performance test and
monitoring to determine compliance with
no detectable emissions and with
§63.243-1 and -2 conducted within the
semiannual reporting period.
                  Not applicable.
                                      Not applicable.

-------

-------
                                APPENDIX B

       EQUIPMENT LEAK REGULATIONS: SUMMARY OF DIFFERENCES

                                                                         Bigg
GENERAL ASPECTS OF RULE
Applicability	,	B-l
Exemptions	 .  B-l
Definitions	B-2
Equipment	  B-2
Process Unit	B-3
Repaired	B-3
Equipment Identification	B-3

SPECIFIC COMPONENT SUMMARIES
Valves, Gas/Vapor or Light Liquid Service 	B-4
Valves, Heavy Liquid Service	B-5
Alternative Standards for Valves	B-6
Pumps, Light Liquid Service	B-7
Pumps, Heavy Liquid Service	B-9
Pressure Relief Devices, Gas/Vapor Service	.'	B-10
Pressure Relief Devices, Light Liquid or Heavy Liquid Service	  B-10
Compressors  	  B-ll
Sampling Connection Systems .... 1		 .  B-12
Open-Ended Valves or Lines	  B-12
Flanges and Other Connectors (All Services)	  B-13
Connectors, Gas/Vapor or Light Liquid Service	  B-13
Connectors, Heavy Liquid Service	  B-13
Agitators, Gas/Vapor Service or Light Liquid Service	  B-13
Agitators, Heavy Liquid Service	  B-13
Instrumentation Systems	  B-14
Product Accumulator Vessels	,	  B-14
Surge Control Vessels and Bottoms Receivers	  B-14
Closed-Vent Systems and Control Devices	  B-15

DELAY OF REPAIR	  B-17

QUALITY IMPROVEMENT PROGRAMS	  B-18

EQUIVALENCE OF (OR ALTERNATIVE) MEANS OF
EMISSIONS LIMITATION	  B-19

-------
ALTERNATIVE MEANS OF EMISSION LIMITATION:
BATCH PROCESSES	  B-19

ALTERNATIVE MEANS OF EMISSION LIMITATION:
ENCLOSED-VENTED PROCESS UNITS	  B-19

TEST METHODS AND PROCEDURES	 .  B-20

RECORDKEEPWG REQUIREMENTS	,	  B-23

REPORTING REQUIREMENTS	  B-27

-------
SUMMARY OF REGULATION
page B-i

General Aspects of
Rule



APPLICABILITY




















EXEMPTIONS
















REGULATION

40 CFR Part 60,
Subpart VV


All equipment within a
process unit in the
synthetic organic
manufacturing industry that
commences construction,
reconstruction, or
modification after 1/5/81,
A list of SOCMI chemicals
produced as intermediates
or final products by
process units is provided to
determine applicability.









Any affected facility with
design capacity to produce
less than l.OOOMgper
year.


Any affected facility that
has no equipment in VOC
service.

Any affected facility that
produces heavy liquid
chemicals only from heavy
liquid feed or raw
materials.
Any affected facility that
produces beverage alcohol.

40 CFR Part 61,
Subpart J


Equipment that is operated
in beraene service.



















Any equipment in benzene
service located at plant
designed to produce or use
less than 1,000 Mg of
benzene per year.

Any process unit that has
no equipment in benzene
service.

Coke by-product plants.

Exempt from part 60 if
subject to part 61,




40 CFR Part 61,
Subpart V


Equipment operated in
volatile HAP (VHAP)
service after the date for
which part 61 regulations
have been promulgated.
















None specified.

















40 CFR Part 63,
Subpart H


Equipment in organic HAP
service operated at least 300
hours per year at facilities
for which part 63
regulations have been
adopted and that cross-
reference this subpart.

A list of organic HAP is
provided to determine
applicability.










Research and development
facilities.

Exempt from part 60 and
from part 61 if subject to
part 63.












40 CFR Part 63,
Subpart I


Equipment in organic HAP
service (see Definitions)
operated at least 300 hours
per year in the following
types of processes: Styrene-
butadiene rubber production;
polybutadiene rubber
production; processes
producing five specific
agricultural chemicals;
processes producing six
specific types of
polymers/resins or other
chemicals; pharmaceutical
processes using carbon
tetrachloride or methylene
chloride; and five specified
polymers/resins.3
Specific HAPs are
designated for determining
applicability.
Research and development
facilities.

Facilities that do not have
the designated HAP(s) need
only document the basis for
this determination.

Exempt until no later than
April 22, 1997, if plant site
emits less than 10 tpy of any
individual HAP and less
than 25 tpy of any
combination of HAP,




40 CFR Part 264,
Subpart BB
40 CFR Part 265,
Subpart BB
Equipment at facilities that
treat, store, or dispose of
hazardous wastes that
contains or contacts
hazardous waste with
organic concentrations of at
least 10 percent by weight
that are managed in units
subject to the permitting
requirements of part 270 or
hazardous waste recycling
units located at such
facilities otherwise subject
to the permitting
requirements of part 270.






None specified.

















-------
SUMMARY OF REGULATION
page B-2
General Aspects of
Rule
DEFINITIONS
"In gas/vapor
service"
"In heavy liquid
service"
"In light liquid
service"
"In liquid service"
"In VOC service"
"In VHAP service"
"In organic
hazardous air
pollutant or in
organic (HAP)
service"
"In benzene service"
EQUIPMENT

40 CFR Part CO,
SubpartVV
The piece" of equipment
contains process fluid that
is in gaseous state at
operating conditions.


Not applicable.
The piece of equipment
contains or contacts a
process fluid that is at least
10 percent VOC by
weight.
Not applicable.
Not applicable.
Not applicable.

40 CFR Part 61.
SubpartJ
REGULATION
40 CFR Part 61.
Subpart V
A piece of equipment contains process fluid that is in the
gaseous state at operating conditions.
Not applicable.
Not applicable.
A piece of equipment is not in gas/vapor service.
The piece of equipment contains or contacts a process fluid
that is at least 10 percent VOC by weight and the piece of
equipment is not in heavy liquid service (as defined under
40 CFR Part 60, subpart VV).
A piece of equipment either contains or contacts a fluid
(liquid or gas) that is at least 10 percent by weight a volatile
hazardous air pollutant (VHAP).
Not applicable.
A piece of equipment
contains or contacts a fluid
(liquid or gas) that is at
least 10% benzene by
weight.

Not applicable.
ADDS*, product accumulator vessels
40 CFR Part 63,
Subpart H

40 CFR Part 63.
Subpart I
A piece of equipment in organic hazardous air pollutant
(HAP) service contains a gas or vapor at operating
conditions.
40 CFR Part 264,
Subprt BB
40 CFR Part 265,
Subpart BB
The piece of equipment
contains or contacts a
hazardous waste stream that
is in the gaseous siate at
operating conditions,


A piece of equipment in organic HAP service is not in
gas/vapor service.
The piece of equipment contains or contacts a process fluid
that is at least 10 percent VOC by weight and the piece of
equipment is not in heavy liquid service (as defined under 40
CFR Part 60, subpart VV).
Not applicable.
A piece of equipment either
contains or contacts a fluid
(liquid or gas) that is at least
5 percent by weight total
organic HAP.
Not applicable.

A piece of equipment either
contains or contacts a fluid
(liquid or gas) that is at least
5 percent by weight of the
designated organic HAP
listed in §63,19Q(b) of this
subpart.

ADDS: agitators, surge control vessels, bottoms receivers,
and instrumentation systems.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.


-------
                                                                 SUMMARY OF REGULATION
page B-3
General Aspects of
Rule
PROCESS UNIT
REPAIRED
EQUIPMENT
IDENTIFICATION
REGULATION
40CFRPart60,
. Subpart VV
Components assembled to
produce, as intermediate or
final products, one or more
of the chemicals specified
in §60,489. A process unit
• can operate independently
if supplied with sufficient
feed or raw materials and
sufficient storage facilities
for the product.
Equipment is adjusted, or
otherwise altered, in order
to eliminate a leak as
indicated by one of the
following: an instrument
reading of 10,000 ppm or
greater, indications of
liquids dripping, or
indication by sensor that a
seal or barrier fluid has
failed.
None specified.
40CFRPart61,
Subpart J
40CFRPart61,
Subpart V
Equipment assembled to produce a VHAP or its derivatives
as intermediate or final products, or equipment assembled
to use a VHAP in the production of a product. A process
unit can operate independently if supplied with sufficient
feed or raw materials and sufficient product storage
facilities.
Equipment is adjusted, or otherwise altered, to eliminate a
leak.
Mark subject equipment in such a manner as to readily
distinguish from after pieces of equipment.
40 CFR Part 63,
Subpart H
40 CFR Part 63,
Subpart I
A chemical manufacturing process unit as defined in subpart
F of this part, a process unit subject to the provisions of
subpart I of this part, or a process unit subject to another
subpart in 40 CFR Part 63 that references this subpart.
Equipment is adjusted, or otherwise altered, to eliminate a
leak as defined in the applicable sections of this subpart.
Same as 40 CFR Part 61, but adds: Identification does not
require physical tagging.
40 CFR Part 264,
Subpart BB
40 CFR Part 26S,
Subpart BB
A contiguous area of land
on or in which hazardous
waste is placed, or the
largest area in which there
is significant likelihood of
mixing hazardous waste
constituents in the same
c
area.
Equipment is adjusted, or
otherwise altered, to
eliminate a -leak. -
Mark subject equipment in
such a manner as to readily
distinguish from other
pieces of equipment.
  Processes producing styrene-butadiene robber (butadiene and styrene emissions only).  Processes producing polybutadiene rubber (butadiene emissions only).  Processes producing the following agricultural chemicals
(butadiene, carbon tetrachtoride, methylene chloride, and ethylene dichloride emissions only): Captafol (R); Captan (R); Chlorothalonil; Dacthal; and Tordon (R) acid.  Processes producing the following polymers/resins
and other chemicals (carbon tetrachloride, methylene chloride, tetrachloroethylene, chloroform, and ethylene dichloride emissions only):  Hypalon (R); Oxybisphenoxarsine/l,3-diisocyanate [OBPA (R)]; polycarbonates;
polysulfide rubber; chlorinated paraffins; and symmetrical tetraehloropyridine. Pharmaceutical production processes using carbon tetrachloride or methylene chloride (carbon tetrachloride and methylene chloride emissions
only). Processes producing the following polymers/resins and other chemicals (butadiene emissions only): tetrahydrophthalie anhydride (THPA); methlymethacryfate-butadiene styrene resins (MBS); butadiene-furtural cotrimer;
meftlymethacrylate-acrylonirrile-butadiene-slyrene (MABS) resins; and ethylidene norbornene,

   "Chemical manufacturing process unit" means the equipment assembled and connected by pipes or ducts to process raw materials and to manufacture an intended product.  For the purposes of this subpart, chemical
manufacturing process unit includes air oxidation reactors and their associated product separators and recovery devices; reactors and their associated product separators and recovery devices; distillation units and their associated
distillate receivers and recovery devices; associated unit operations (as defined in this section); and any feed, intermediate, and product storage vessels, product transfer racks, and connected ducts and piping,  A chemical
manufacturing process unit includes pumps, compressors, agitators, pressure relief devices, sampling connection systems, open-ended valves or lines, valves, connectors, instrumentation systems, and control devices or systems.
A chemical process manufacturing unit is identified by its primary product.
c Examples of hazardous waste management units include a surface impoundment, a waste pile, a land treatment area, a landfill cell, an incinerator, a tank and its associated piping and underlying containment system and
a container storage area. A container alone does not constitute a unit; the unit includes containers and the land or pad upon which they are placed.

-------
SUMMARY OF REGULATION
pageB-4
Specific
Component
Summaries
REGULATION
40 CPR Part (50,
SubpartVY
VALVES, GAS/VAPOR OR LIGHT LIQUID SERVICE
Standards
Standards;
Basic
Monitoring
Interval
Standards:
Plants with
less than 250
valves in
organic HAP
service
No
Detectable
Emissions
Unsafe-to-
Monitor:
Interval
Diffieult-to-
Monitor:
Definition
DifFieult-to-
Monitor:
Limit on
Number

Monthly that can go to quarterly.
Not applicable.
40 CFR Part 61 , 40 CFR Part 61 ,
SubpartJ SubpattV
40 CFR Part 63, 40 CPR Part 63,
Subpart H Subpirt I
40 CFR Part 264,
Subpart BB
40 CFR Part 265,
Subpart BB

Designates valves "in liquid service" not in
either "light liquid" or "heavy liquid"
servke.
Monthly that can go to quarterly.
Not applicable.



No more than 3.0 percent of valves in
affected facility can be designated as difficult-
to-monitor.
None specified.
•
Quarterly in Phases I and II.
In Phase HI, varies depending on percent
leaking.
In Phase III, can monitor quarterly (rather
than monthly) or comply with paragraphs
(d)(3)or(d){4).
Not applicable.
ADDS: but not more frequently than the
periodic monitoring schedule otherwise
applicable.
ADDS: or it is not accessible at anytime in
a safe manner
No more dian 3.0 percent of valves in
affected facility can be designated as
difficult-to-monitor.
Monthly that can go to quarterly.
Not applicable.



None specified.

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SUMMARY OF REGULATION DIFFERENCES
page B-5
Specific
Component
Summaries
REGULATION
40 CFR Part 60,
Subpart VV
40 CFR Part 61 , 40 CFR Part 61 ,
Subpart I Subpart V
VALVES, GAS/VAPOR OR LIGHT LIQUID SERVICE (concluded)
Leak
Definition
Repairs
Exemptions
10,000 ppm
10,000 ppm


40 CFR Part 63, 40 CFR Part 63,
Subpart H Subpart I

Phase I: 10,000 ppm
Phase II: 500 ppm
Phase III: 500 ppm
ADDS; When repaired, monitor at least
once within first 3 months after repair.
Equipment operated less than 300 hours per
year.
40 CFR Part 264,
Subpart BB
40 CFR Part 265,
Subpart BB

10,000 ppm



VALVES, HEAVY LIQUID SERVICE
Standards
Leak
Definition
Repair

10,000 ppm
Not applicable.
10,000 ppm


Monitoring: 500 ppm
For valves in heavy liquid service that are
not monitored (Method 21), repair shall
mean that visual, audible, olfactory, or
other indications of a leak have been
eliminated; no bubbles are observed at
potential leak sites during leak check with
soap solution; or system will hold a test
pressure.
10,000 ppm


-------
SUMMARY OF REGULATION DIFFERENCES
page B-6
Specific
Component
Summaries

40 CFR Part 60,
Subpart VV
40 CFR Part 6J,
SubpartJ
ALTERNATIVE STANDARDS FOR VALVES
REGULATION
40 CFR Part 61,
Subparl V
40 CFR Part ffl,
Subparl K


40 CFR Part 63,
Subpart I
40CFRPirt264,
Subpart BB
40 CFR Part 265,
Subpart BB

Allowable Percentage of Valves Leaking
Standard
Notification
Applies to "affected facilities"
Not required.
Applies to "process units"
Notification required if compliance with
allowable percent is discontinued
Not applicable.
Not required.
Applies to "hazardous waste management •
units"
Notification required if compliance with
allowable percent is discontinued
Skip Period Leak Detection and Repair
Standard
Calculation

Calculate percent leaking by dividing sum of
valves found leaking during current
monitoring and valves for which repair has
been delayed by the total number of subject
valves.
Not specified.
Not applicable.


Not specified.

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SUMMARY OF REGULATION DIFFERENCES
page B-7
Specific
Component
Summaries

REGULATION
40 CFR Part 60,
Subpart VV

40 CPR Part 61 , 40 CFR Part 61 ,
Subpart J Subpart V

PUMPS, LIGHT LIQUID SERVICE
Standards




DMS:
Barrier Fluid
Purges into
Process
DMS:
Barrier Fluid
System
DMS:
Indications of
Liquids
Dripping
DMS: Sensor
and Audible
Alarm





zero VOC emissions


in heavy liquid service and not in VOC
service -
Indications means a leak is detected.
ADDS: If located at unmanned plant site,
visual inspections required at least monthly.




zero VHAP emissions


not in VHAP service and not in VOC
service
Indications require monitoring with
instrument. A leak is detected if: (1) the
presence of VHAP is detected, or (2) an
instrument reading is 10,000 ppm or greater
(total VOC) is measured.

40 CFR Part 63, 40 CFR Part 63,
Subpart H Subpart I

40 CFR Part 264,
Subpart BB
40 CFR Part 265,
Subpart BB

ADDS: If located at unmanned plant site,
visual inspections required at least monthly.
ADDS:
Phasfi III:
If the greater of either 10 percent of pumps
in a process unit (or source-wide) or 3
pumps in a process unit (or source-wide)
leak, then implement technology review and
improvement QIP. (This does not apply to
process unit if more than 90% of the pumps
in the unit are either dual mechanical seal or
designed with no externally activated shaft
penetrating the housing.)
no similar statement


not in light liquid service
Indications require monitoring with
instrument. A leak is detected if instrument
reading is 1,000 ppm or greater.
Daily observation or equipped with alarm
waived if located at an unmanned plant site.





no delectable emissions


must not be a hazardous waste with organic
concentrations 10 percent or greater by
weight
Indications means a leak is detected.
Check alarm monthly to ensure it is
functioning properly.

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                                                        SUMMARY OF REGULATION DIFFERENCES
                                                                                                                                                     pageB-8
  Specific
 Component
 Summaries
                                                                                     REGULATION
            40 CFR Part 60.
              SubpartVV
  40 CFR Part 61,
     Subpart I
40 CFR Part 61,
   SubpartV
40 CFR Part 63.
   Subpart H
40 CFR Pan 63,
   Subpart I
40 CFR Part 264,
   Subpart BB
40 CFR Part 265,
   Subpart BB
PUMPS. LIGHT LIQUID SERVICE (concluded)
         No
   Detectable
   Emissions
                                                                               Not provided. Instead provides baste
                                                                               exemption for pumps designed with no
                                                                               externally actuated shaft penetrating the
                                                                               pump housing (a specification under the
                                                                               other standards for pumps designated for no
                                                                               detectable emissions).	
       Leak
   Definition
10,000 ppm
10,000 ppm
                  Phase 1:   10,000 ppm

                  Phase II:   5,000 ppm

                  Phase III:  5,000 ppm (polymerizing
                           monomers)
                           2,000 ppm (food/medical
                           services)
                     	1,000 ppm (all other pumps)
                                     10,000 ppm
      Repair
                                                                               For pumps in Phase III subject to the leak
                                                                               definition of 1,000 ppm, repair is not
                                                                               required unless instrument reading of 2,000
                                                                               ppm or greater is detected.	
First Attempt
    at Repair
None specified.
None specified.
                  Best practices include, but are not limited
                  to:
                          tightening of packing gland nuts
                          ensuring mat the seal flush is
                          operating at design pressure and
                 	temperature	
                                     None specified.
  Exemptions
                                                                               ADDS: Use compliant closed-vent system
                                                                               that transports leakage back to the process
                                                                               or to a compliant control device,

                                                                               Equipment operated less than 300 hours per
                                                                               year.	

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SUMMARY OF REGULATION DIFFERENCES
page B-9
Specific
Component
Summaries
REGULATION
40 CFR Part 60,
Subpart VV
40 CFR Part 61,
Subpart J
PUMPS, HEAVY LIQUID SERVICE
Standards
Leak
Definition
Repair
Exemptions

10,000 ppm
40 CFR Part 61,
Subpart V
40 CFR Part 63,
Subpart H

Not applicable.



40 CFR Part 63,
Subpart I
40 CFR Part 264,
Subpart BB
40 CFR Part 265,
Subpart BB


Monitoring; 2,000 ppm
For pumps in heavy liquid service that are
not monitored (Method 21), repair shall
mean that visual, audible, olfactory, or
other indications of a leak have been
eliminated; no bubbles are observed at
potential leak sites during leak check with
soap solution; or system will hold a test
pressure.
Equipment operated less than 300 hours per
year.
10,000 ppm



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SUMMARY OF REGULATION DIFFERENCES
page B-10
Specific
Component
Summaries
REGULATION
40 CFR Pan 60,
SubpariVV
PRESSURE RELIEF DEVICES, GAS/VAPOR SERVICE
Standards
Repair
Exemptions
40 CFR Part 61 , 40 CFR Part 61 ,
SubprtJ SubprtV
40 CFR Part 63, 40 CFR Part 63,
Subput H Sufapart I
40 CFR Part 264.
Subpart BB
40 CER Part 265,
Subpart BB




ADDS;
With Rupture Disk
After each release, replace rupture disk
within 5 calendar days.
Not applicable.
Equipment operated less than 300 hours per
year.
•



PRESSURE RELIEF DEVICES, LIGHT LIQUID OR HEAVY LIQUID SERVICE
Standards
Leak
Definition
Repair
Exemptions

10,000 ppm

10,000 ppm


Monitoring: 500 ppm
For pressure relief devices in liquid service
that are not monitored (Method 21), repair
shall mem that visual, audible, olfactory, or
other indications of a leak have been
eliminated; no bubbles are observed at
potential leak sites during leak check with
soap solution; or system will hold a test
pressure.
Equipment operated less than 300 hours per
year.
10,000 ppm



-------
SUMMARY OF REGULATION
page B-il
Specific
Component
Summaries
REGULATION
40 CFR Part 60,
Subpart VV
40 CFR Part 61,
Subpart J
COMPRESSORS
Standards
Standards:
Barrier Fluid
Purges into
Process
Standards;
Barrier Fluid
Systems
Standards:
Sensor and
Audible
Alarm
Exemptions
40 CFR Part 61,
Subpart V
40 CFR Part 63, 40 CFR Part 63,
Subpart H Subpart I
40 CFR Part 264,
Subpart BB
40 CFR Part 265,
Subpart BB


zero VOC emissions
in heavy liquid service and not in VOC
service
zero VHAP emissions
not in VHAP service and not in VOC
service

Reciprocating compressors that meet certain
criteria.

no similar statement
not in light liquid service
Daily observation or equipped with alarm
waived if located at an unmanned plant site.
Equipment operated less than 300 hours per
year.
no detectable emissions '
must not be a hazardous waste with organic
concentrations 10 percent or greater by
weight
Check alarm monthly to ensure it is
functioning properly.


-------
SUMMARY OF REGULATION DIFFERENCES
page B42
Specific
Component
Summaries
REGULATION
40 CFR Part 60,
Subpart VV
40 CFR Part 61 , 40 CFR Part 61 ,
Subpsirt J Subpart V
SAMPLING CONNECTION SYSTEMS
Standards;
Introduction
Standards:
Return of
fluid to
process or
recycle
Exemptions

ADDS; Closed-loop system
with zero VOC emissions to the atmosphere
ADDS: Sampling systems without purges.
with mm VHAP emissions to the
atmosphere

40 CFR Part 63, 40 CFR Part 63,
Subpart H Subpart I
40 CFR tot 264,
Subpart BB
40 CFR Part 265,
Subpart BB

ADDS:
The system shall collect or capture the
sample purge for return to the process,
Gases displaced during filling of ihe sample
container are not required to be collected or
captured.
ADDS: Closed-loop system
No mention of emissions to the atmosphere.
ADDS: Sampling systems without purges,
Equipment operated less than 300 hours per
year.

With no detectable emissions to the
atmosphere


OPEN-ENDED VALVES OR LINES
Standards
Exemptions


ADDS: flow allowed during maintenance
or repair.
ADDS: Open-ended valves and lines in an
emergency shutdown system that are
designed to open automatically in the event
of a process upset,
Equipment operated less than 300 hours per
year.



-------
SUMMARY OF REGULATION
page B-13
Specific
Component
Summaries
REGULATION
40 CFR Part 60,
Subpart VV
40 CFR Part 61 , 40 CFR Part 61 ,
Subpart J Subpart V
40 CFR Part 63, 40 CFR Part 63,
Subpart H Subpart I
40 CFR Part 264,
Subpart BB
40 CFR Part 265,
Subpart BB
FLANGES AND OTHER CONNECTORS (ALL SERVICES)
Standards

Not applicable. The subpart has standards
for connector in gas/vapor or light liquid
service and for connectors in heavy liquid
service.
•

CONNECTORS, OAS/VAPOR OR LIGHT LIQUID SERVICE
Standards
Not applicable [See Flanges and other
connectors (all services)].
Not applicable [See Flanges and other
connectors (all services)].
See Regulatory Summary table for
description of regulations for these
components.
Not applicable [See Flanges and other
connectors (all services)].

CONNECTORS, HEAVY LIQUID SERVICE
Standards
Not applicable [See Flanges and other
connectors (all services)].
Not applicable.
See Regulatory Summary table for
description of regulations for these
components.
Not applicable [See Flanges and other
connectors (all services)].

AGITATORS, GAS/VAPOR SERVICE OR LIGHT LIQUID SERVICE
Standards
Not applicable.
Not applicable.
AGITATORS, HEAVY LIQUID SERVICE
Standards
Not applicable.
Not applicable.
See Regulatory Summary table for
description of regulations for these
components.
Not applicable.

See Regulatory Summary table for
description of regulations for these
components.
Not applicable.

-------
SUMMARY OF REGULATION
page B-14
Specific
Component
Summaries
REGULATION
40CFRP«t60,
Subpart VV
40CFRPtrl61,
Subpart J
INSTRUMENTATION SYSTEMS
Standards
Not applicable.
4QCFRPsrl6i,
Subpart V
40 CFR Part 63. 40 CFR Part 63,
Subpart H Subpart I
40 CFR Part 264,
Subpart BB
40 CFR Part 265,
Subpart BB

Not applicable.
See Regulatory Summary table for
description of regulations for these
components.
Not applicable.

PRODUCT ACCUMULATOR VESSELS
Standards
Not applicable.
See Regulatory Summary table for
description of regulations for these
components.
Not applicable (see Surge Control Vessels
and Bottoms Receivers)
Not applicable.

SURGE CONTROL VESSELS AND BOTTOMS RECEIVERS
Standards
Not applicable.
Not applicable (see Product Accumulator
Vessels)
See Regulatory Summary table for
description of regulations for these
components.
Not applicable.

-------
SUMMARY OF REGULATION
page B-15
Specific
Component
Summaries
REGULATION
40 CFR Part 60,
Subpart VV
40 CFR Part 61. 40 CFR Part 61,
Subpart J SubptrtV
CLOSED VENT SYSTEMS AND CONTROL DEVICES
Standards:
Vapor
Recovery
Devices
Standards:
Combustion
Devices
Standards:
Flares
Standards:
Ciosed-Vent
Systems
Monitoring:
Control
Devices
Monitoring:
Closed-Vent
Systems
Inspections:
Closed-Vent
Systems
40 CFR Part 63, 40 CFR Part 63,
Subpart H Subpart I
40 CFR Part 264,
Subpart BB
40 CFR Part 265,
Subpart BB


minimum residence time of 0.75 seconds and
minimum temperature of 816°C
Comply with §60. 18
Initial and annual inspection requirements,
which vary based on whether hard piping or
ductwork is used.
minimum residence time of 0.50 seconds
and minimum temperature of 760°C
Comply with §60. 18
No detectable emissions and no visual
indications.
minimum residence time of 0.50 seconds
and minimum temperature of 760°C
Comply with §63,11 (b)
Initial and annual inspection requirements,
which vary based on whether hard piping or
ductwork is used.

Install flow monitors or monthly visual
inspections where bypass, lines could divert
flow
If contains by-pass lines, (1) vent stream flow
meters or (2) car-seal or lock-and-key type of
configuration with monthly visual inspection
required.
"Unsafe-to-monitor" parts: inspect as
frequently as practicable, but no more
frequently than annually,
"Diffieult-to-monitor" parts; inspect at least
once every 5 years.
Initially, annually, and at other times
specified by EPA
None specified.
Install flow monitors or monthly visual
inspections where bypass lines could divert
flow
If contains by-pass lines, (1) vent stream
flow meters or (2) car-seal or loek-and-key
type of configuration with monthly visual
inspection required.
"Unsafe-to-monitor" parts: inspect as
frequently as practicable, but no more
frequently than annually.
"Difficult-to-monitor" parts: inspect at least
once every 5 years.
Vapor recovery systems: 95 percent or
greater recovery unless toial organic
emission limits of §265.1032(a)(i) for all '
affected processes can be attained at an
efficiency of less than 95 percent.
For carbon adsorbers, carbon replacement
intervals specified.
minimum residence time of 0,50 seconds
and minimum temperature of 760"C or to 20
ppmv
Basic requirements for visible emissions,
heat content, and exit velocities.
No detectable emissions.
Specific requirements identified for vent
stream flow monitors and other monitors for
specific types of control devices.
Initially, annually, and at other times
specified by EPA
None specified.

-------
SUMMARY OF REGULATION DIFFERENCES
page B-16
Specific
Component
Summaries

40 CFR Part 60,
Subpart VV
40 CFR Part 61,
Subpart J
CLOSED VENT SYSTEMS AND CONTROL DEVICES (concluded)
Leak
Definition
Repair
Exemptions
500 ppm.
ADDS: Delay of repair allowed under
certain circumstances. Repair required no
later than by end of next process unit
shutdown.
REGULATION
40 CFR Part 61,
Subpart V

Not applicable.


40 CFR Part 63,
Subpart H


40 CFR Part 63,
Subpart I
40 CFR Part 264,
Subpart BB
40 CFR Part 265,
Subpart BB

500 ppm
ADDS: Delay of repair allowed under
certain circumstances. Repair required no
later than by end of next process unit
shutdown.
Equipment operated less than 300 hours per
year.
Equipment needed for safety purposes are
not subject to these monitoring
requirements.
Not applicable,
CVS: detectable emissions >.500 above '
background



-------
                                                          SUMMARY OF REGULATION DIFFERENCES
                                                                                                                                                        page B-17
Delay of Repair
                                                                                          REGULATION
                            40 CFR Part 60,
                              Subpart VV
                                          40 CFR Part 61,
                                             Subpart J
                      40 CFR Part 61,
                         Subpart V
  40 CFR Part 63,
     Subpart H
40 CFR Part 63,
   Subpart I
40 CFR Part 264,
   Subpart BB
40 CFR Part 265,
   Subpart BB
      General:
       Isolated
    Equipment
Does not remain in VOC service.
Does not remain in VHAP service.
Does not remain in organic HAP service.
                   Does not continue to contain or contact
                   hazardous waste with organic concentrations
                   of at least 10 percent by weight.	
        Valves
Not allowed unless next process unit
shutdown occurs sooner than 6 months after
1st process unit shutdown.
Not allowed unless next process unit
shutdown occurs sooner than 6 months after
1st process unit shutdown.
Not allowed beyond the second process unit
shutdown unless the third process unit
shutdown occurs sooner than 6 months after
1st process unit shutdown.	
                   Not allowed unless next unit shutdown occur
                   sooner than 6 months after 1st unit
                   shutdown.
 Connectors and
      Agitators
Not applicable.
Not applicable.
Allowed if:

emissions from purged material resulting
from immediate repair less than from the
delay

purged material is later collected and
destroyed or recovered in compliant control
device

Delay beyond next process unit shutdown
allowed if otherwise sufficient supply of
valves have been depleted.
                   Not applicable.
        Pumps
                                                                                 Additional allowances;

                                                                                 If repair requires replacing existing seal
                                                                                 design with a new system that provides better
                                                                                 performance or compliant closed-vent system
                                                                                 and control device.

-------
SUMMARY OF REGULATION DIFFERENCES
page B-18
Quality
Improvement
Programs
Applicability
REGULATION
40 CFR Part 60,
Subprt VV
Not applicable.
40 CFR Part 61,
SubpartJ
40 CFR Part 61,
SubpartV
Not applicable.
40 CFR Part 63,
Subprt H
40 CFR Part 63,
Subparll
See Regulatory Summary taWe for description of Quslily
Improvement Programs.
40 CFR Part 264,
Subpart BB
40 CFR Part 265,
Subpart BB
Not applicable.

-------
SUMMARY OF REGULATION
page B-19
Equivalence of (or
Alternative) Means
of Emission
Limitation
Equipment, Design,
and Operational
Requirements
Work Practices:
Demonstration of
Emission Reduction
for Required Work
Practice
Unique Approach
Manufacturers of
Equipment
REGULATION
40 CFR Part 60,
Subpart VV

No length of demonstration period
indicated.
40 CFR Part 61,
Subpart J
40 CFR Part 61,
Subpart V
No requirement for Administrator to
compare test data.
Required for minimum of 12 months.
40 CFR Part 63,
Subpart H

40 CFR Part 63,
Subpart I

Required for minimum of 12 months.


40 CFR Part 264,
Subpart BB
40 CFR Part 265,
Subpart BB
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Alternative Means
of Emission
Limitation:
Batch Processes

REGULATION
40 CFR Part 60,
subpart VV
Not applicable.
40 CFR Part 61,
subpart J
40 CFR Part 61,
subpart V
Not applicable.
40 CFR Part 63,
subpart H
40 CFR Part 63,
subpart I
See Regulatory Summary table for description of standards for batch processes.
40 CFR Part 265,
subpart BB
Not applicable.
Alternative Means
of Emission
Limitation:
Enclosed-Vented
Process Units

REGULATION
40 CFR Part 60,
Subpart VV
Not applicable.
40 CFR Part 61,
Subpart J
40 CFR Part 61,
Subpart V
Not applicable.
40 CFR Part 63,
Subpart H
40 CFR Part 63,
Subpart I
See Regulatory Summary table for
description of standards for enclosed-
vented process units.
40 CFR Part 264,
Subpart BB
40 CFR Part 265,
Subpart BB
Not applicable.

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                                                         SUMMARY OF REGULATION DIFFERENCES
                                                                                                                                                    page B-20
Test Methods and
   Procedures
                                                                                           REGULATION
           40CFRPart60,
             Subpart VV
  40 CFR Ptrt 61,
     Subpart J
<«) CFR Part 61,
   Subpart V
40 CFR Part 63,
   Subpart H
40 CFR Part 63.
   Subpart I
40 CFR Part 264,
   Subpart BB
40 CFR Part 265,
   Subpart BB
      Monitoring
         Method,
   Technique, and
       Instrument
ADDS: Test each piece of equipment
unless demonstration is made that
equipment is not in VOC service.
ADDS: Instrument to meet performance
criteria of Method 21

Traverse probe around all potential leak
interfaces as close as possible as described
in Method 21
                  ADDS: Instrument lo meet performance
                  criteria of Method 21 except:

                   response factor criteria is for the average
                  composition of the process fluid, not each
                  individual VOC in stream

                   for process streams that contain inerts that
                  are not organic HAPs or VOC, average
                  stream response factor is calculated on an
                  inert-free basts

                  If no instrument available that meet all
                  Method 21 criteria, then instrument
                  readings may be adjusted as specified

                  Monitor all equipment while it is "in
                  service"
                                      ADDS: Instrument to meet performance
                                      criteria of Method 21

                                      Traverse probe around all potential leak
                                      interfaces as close as passible as described
                                      in Method 21
       Calibration
                                                                                gases:  limits to methane

                                                                                 Phase II;  mixture of methane in air at
                                                                                concentration of about, but less than:

                                                                                  10,000 ppm for agitators
                                                                                   5,000 ppm for pumps
                                                                                    500 ppm all  other equipment

                                                                                 Phase III: mixture of methane in air at
                                                                                concentration of about, but less than:

                                                                                  10,000 ppm for agitators
                                                                                   2,000 ppm for pumps in food/ medical
                                                                                service
                                                                                   5,000 ppm for pumps in polymerizing
                                                                                monomer service
                                                                                   1,000 ppm for all other pumps
                                                                                    500 ppm for all other equipment

                                                                                Phase II and ni Exception:  under certain
                                                                                conditions may calibrate up to 2,000 ppm
                                                                                higher than the leak definition	

-------
                                                           SUMMARY OF REGULATION
                                                                                                                                                         page B-21
Test Methods and
   Procedures
                                                                                             REGULATION
            40 CFR Part 60,
              Subpart VV
  40 CFR Part 61,
     Subpart J
40 CFR Part 61,
   Subpart V
40 CFR Part 63,
   Subpart H
40 CFR Part 63,
   Subpart I
40 CFR Part 264,
   Subpart BB
40 CFR Part 265,
   Subpart BB
  Not "in service"
    determination
For demonstration;

Use procedures that conform to ASTM E-
260, E-168, B-169 to determine percent
VOC in process fluid that is contained or
contacts a piece of equipment.

Engineering judgement may be used to
estimate the VOC content if piece of
equipment had not been shown previously
to be in VOC service,

Administrator will require use of ASTM
Method D-2267b in even! of disagreement
to determine VOC content,

Compounds determined by EPA to have
negligible photochemical reactivity can be
excluded in determining VOC  content of a
process fluid.	
For demonstration:

Use procedures that conform to ASTM
Method D-2267,
                                                            Engineering judgment may be used to
                                                            determine percent VHAP clearly does not
                                                            exceed 10 percent.
                                                            Administrator will require use of ASTM
                                                            Method D-2267b in event of disagreement
                                                            to determine VOC content.
                  For demonstration:

                  Use Method 18 of 40 CFR Part 60,
                  appendix A to determine percent organic
                  HAP.
                                         Engineering judgment may be used to
                                         determine percent organic HAP does not
                                         exceed 5 percent,

                                         Owner/operator may instead determine
                                         organic HAP content does not exceed 5
                                         percent by weight.
                                       For demonstration:

                                       Use ASTM Methods D 2267-88, E 169-87,
                                       E 168-88, E260-85, or Method 9060 or
                                       8240ofSW-846.
                                                            Engineering judgment may be used to
                                                            estimate organic concentration.
                                                            Regional Administrator will require the use
                                                            of ASTM Methods D 2267-88, E 169-87, E
                                                            168-88, E260-85, or Method 9060 or 8240
                                                            of SW-846 in the event of disagreement to
                                                            determine VOC content.
  Revisions of "In
         service"
    determination
None specified.
Determination of in VHAP service can be
revised only by following specified
procedures.
                  Determination of in organic HAP service
                  can be revised by either following specified
                  procedures or documenting a change in
                  process or raw materials no longer causes
                  equipment to be in organic HAP service.
                                       If owner or operator determines that a piece
                                       of equipment contains or contacts a
                                       hazardous waste with an organic
                                       concentration of at least 10% be weight, the
                                       determination can only be revised by
                                       following the demonstration procedures.
         Samples
Representative of process fluid that is
contained in or contacts the equipment or
the gas being combusted in flare.	
Representative of process fluid mat is
contained in or contacts the equipment or
the gas being combusted in flare.
                  Representative of process fluid that is
                  contained in or contacts the equipment.
                                       Representative of the highest total organic
                                       content hazardous waste that is contained in
                                       or contacts the equipment.	
  Vapor pressures
Standard reference texts
  or
ASTM D-2879
Not specified.
                  Not specified.
                                       Standard reference texts
                                          or
                                       ASTM D-2879-86
 Flare Compliance
Presence of flame: thermocouple or
equivalent.

Component concentration;  Method 18 and
ASTM D-2504-67
Presence of flame; thermocouple or
equivalent

Concentration:  Method 18 or ASTM
D2509-67.
                  Presence of flame;  thermocouple or
                  equivalent.

                  Concentration: Method 18
                                       Presence of flame:  heat sensing monitoring
                                       device with a continuous recorder that
                                       indicates the continuous ignition of the pilot
                                       flame.

                                       Concentration: Method 18

-------
SUMMARY OF REGULATION DIFFERENCES
page B-22
Test Methods am!
Procedures
Batch Processes -
Pressure Test with
Gas or Vacuum
Batch Processes -
Pressure Test with
Liquid
REGULATION
40CFRPart60,
SubjartW
Not applicable.
Not applicable.
40 CFR Part 61,
Subpart J
40 CFR Part 61,
SubptrtV
Not applicable.
Not applicable.
40CFRPart63,
SubpartH
40 CFR Part 63,
Subpart I
Sec Regulation Summary able for specific
requirements.
See Regulation Summary table for specific
requirements.
40 CFR Part 264,
Subpart BB
40 CFR Part 265,
Subpart BB
Not applicable.
Not applicable.

-------
                                                           SUMMARY OF REGULATION
                                                                                                                                            page B-23
  Recordkeeping
   Requirements
                                                                                            REGULATION
40 CFR Part 60,
  Subpart VV
40 CFR Part 61,
   Subpart J
40 CFR Part 61,
   Subpart V
40 CFR Part 63,
   Subpart H
40 CFR Part 63,
   Subpart I
40 CFR Part 264,
   Subpart BB
40 CFR Part 265,
   Subpart BB
When leak detected
                    DOES NOT HAVE:

                     dates of process unit shutdown that
                    occurred while the equipment is
                    unrepaired
                                                               id removal after repair except for valves and
                                                               connectors and no leak detected during foilowup
                                                               for valves and connectors, id may be removed
                                                               after 2 months of no leaks detected and no leak has
                                                               been detected during the followup monitoring

                                                               ADDS:

                                                                operator name and initials

                                                                maximum instrument reading after successful
                                                               repair or determined to be nonrepairable

                                                                for connectors: id of connectors disturbed since
                                                               last monitoring period, and dates and results of
                                                               follow-up monitoring

                                                                copies of periodic reports (if database not capable
                                                               of generating such)
                                                                                             DOES NOT HAVE:

                                                                                              repair methods applied in each attempt to repair

                                                                                              "above  10,000" if maximum instrument reading
                                                                                             after each repair attempt is J>. 10,000 ppm

                                                                                              signature of owner/operator whose decision it
                                                                                             was that repair could not be effected without a
                                                                                             process shutdown
                                                                                   for a weather-proof and readily visible
                                                                                   identification, adds:

                                                                                   date evidence of potential leak found and date
                                                                                   leak detected
                                                                                   ADDS:

                                                                                    date evidence of potential leak found

                                                                                    documentation supporting delay of repair of
                                                                                   a valve


                                                                                   DOES NOT HAVE:

                                                                                    dates of process unit shutdown that occurred
                                                                                   while the equipment is unrepaired

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SUMMARY OF REGULATION
page B-24

Recordkeeping
Requirements



Closed vent
systems and control
devices











Visual inspections



40 CFR Part 60.
Subpart W



40 CFR Part 61,
Subpart J
















Not applicable.

REGULATION

40 CFR Part 61,
Subpart V
















Not applicable.

40 CFR Part 63,
Subpart H


ADDS:



40 CFR Part 63,
Subpart I




flare design and compliance demonstration results
records of operation of closed-vent systems and
control devices



dates and duration when closed-vent systems, and
control devices not operated according to design


dates and duration when monitoring
systems/devices are nonoperative


records of closed-vent inspections


documentation that inspection was conducted
dates of inspection


40 CFR Part 264,
Subpart BB
40 CFR Pan 265,
Subpart BB
ADDS:

explanation of each period of exeeedanees
For carbon adsorbers:

date when fresh carbon added

monitoring of carbon breakthrough (certain
carbon adsorbers)


For other, non-specified control devices,
monitoring and inspection information
indicating proper operation and maintenance
Not applicable.


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                                                          SUMMARY OF REGULATION DIFFERENCES
                                                                                                                                                     page B-25
  Recordkeeping
   Requirements
                                                                                           REGULATION
         40 CFR Part 60,
            Subpart VV
40 CFR Part 61,
   Subpart J
40 CFR Part 61,
   Subpart V
40 CFR Part 63,
   Subpart H
40 CFR Part 63,
   Subpart I
40 CFR Part 264,
   Subpart BB
40 CFR Part 265,
   Subpart BB
AH equipment...
 list of id numbers of subject
equipment
 list of id numbers of subject
equipment (except welded fittings)
                   list of id numbers of subject equipment (except
                  certain connectors).

                  ADDS:

                   schedule for monitoring connectors

                   list of id numbers for equipment equipped with
                  closed-vent system and control device

                   list of id numbers of compressors and pressure
                  relief devices complying with less than 500 ppm
                  above background standard

                   list of id numbers of pressure relief devices with
                  rupture disks

                   id of instrumentation systems

                   id of screwed connectors complying with
                  §63.174(c)(2)

                   list of valves and connectors removed if net
                  credits for their removal are expected to be used

                  DOES NOT HAVE:

                   list of id numbers of equipment designated for no
                  detectable emissions and signed by owner/operator

                   list of id numbers for pressure relief devices in
                  gas/vapor service

                   for each compliance test for components
                  designated for no detectable emissions

                    date conducted
                    background level measured
                    maximum instrument reading

                   list of id numbers of equipment in vacuum
                  service
                                          list of id numbers of subject equipment
                                         (except welded fittings)

                                         ADDS:

                                          equipment identification number and
                                         hazardous waste management unit
                                         identification

                                          approximate facility location

                                          type of equipment

                                          percent-by-weight of total organies in
                                         hazardous waste at the equipment

                                          hazardous waste state at the equipment

                                          method of compliance

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SUMMARY OF REGULATION
page B-26
Recwxl keeping
Requirement
Unsafe or Difficult
to Monitor Valves
Unsafe-to- Monitor
or Repair,
Inaccessible or
Glass-Lined
Connectors
Valves complying
with alternative
standard for skip-
periods
Exemption
Determinations
Not "In service"
Batch Processes
QIP
Enclosed Vent
Process
REGULATION
40 CFR Part 60.
Subprt VV
40 CFR Part 61, 40 CFR Part 61,
Subpart J Subpart V
40CFRPart63, 40 CFR Part 63,
Subprt H Subprt I
40 CFR Part 264,
Subprt BB
40 CFR Part 265,
Subpart BB

Not applicable.
Not applicable.

analysis demonstrating facility design
capacity
statement listing feed or raw
materials and products from facility
and analysis demonstrating whether
these chemicals are heavy liquids or
beverage alcohol
analysis demonstrating that equipment
is not in VOC service
information and data used to
demonstrate that a piece of equipment
is not in VOC service
Not applicable
Not applicable.
Not applicable.
analysis demonstrating facility design
capacity
analysis demonstrating that equipment
is not in VHAP service
information and data used to
demonstrate that a piece of equipment
is not in VHAP service
Not applicable
Not applicable.
Not applicable.
list of id numbers
explanation for designation
plan or schedule for monitoring
Not applicable.
identification of equipment in organic HAP
service less than 300 hours per year
information, data, and analysis used to
demonstrate that a piece of equipment or process
unit is in heavy liquid service
See Regulation Summary table for specific
requirements.
See Regulation Summary table for specific
requirements.
See Regulation Summary table for specific
requirements.
Not applicable.

an analysis determining the design capacity
of the unit
statement listing the hazardous waste
influent to and effluent from each subject unit
and an analysis determining whether these
wastes are heavy liquids
an up-to-date analysis and supporting
information to determine whether or
equipment is subject to this subpart
Not specified.
Not applicable
Not applicable.
Not applicable.

-------
                                                         SUMMARY OF REGULATION DIFFERENCES
                                                                                                                                                         page B-27
  Reporting
Requirements
                                                                                      REGULATION
          40 CFR Part 60,
            Subpart VV
 40 CFR Part 61,
    Subpart J
40 CFR Part 61,
   Subpart V
40 CFR Part 63,
   Subpart H
40 CFR Part 63,
   Subpart I
40 CFR Part 264,
   Subpart BB
40 CFR Part 265,
   Subprt BB
   Initial Report
process unit identification

number of valves, pumps, and
compressors, excluding those designated
for no detectable emissions
For each source:

 equipment identification number

 process unit identification

 type of equipment

 percent weight VHAP

 process fluid state

 method of compliance

Reporting schedule for submittal of
subsequent semiannual reports

An owner or operator is also required to
submit a statement notifying the
Administrator that the requirements of
this subpart are being implemented. For
existing sources and new sources with an
initial startup date preceding the effective
date, this notification is to be submitted
within 90 days of the effective date. For
new source with an initial startup date
after the compliance date, this
notification is to be submitted with the
application for approval of construction.
                  Initial Notification

                    name and address of owner/operator
                    address of facility (physical location)

                    identification of subject processes
                    compliance statement

                    statement of whether a source can
                  achieve compliance by the applicable
                  compliance date

                  Notification of Compliance Status (for
                  each subject process unit)

                  A.  For each subject unit:

                    process unit identification

                    number of each equipment type (except
                  those in vacuum service)

                    method  of compliance

                    planned schedule for each phase

                  B.  Batch processes:

                    batch products or product codes

                    planned schedule for testing

                  C.  Enclosed-vented Process Units

                    process unit identification

                    description of negative pressure system
                  and control device
                                      Not specified.

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                                                         SUMMARY OF REGULATION DIFFERENCES
                                                                                                                                                         page B-28
                                                                                      REGULATION
  Reporting
Requirements
          40 CFR Part 60,
             Subpart VV
 40 CFR Part 61,
    SubpartJ
40CFRPut61,
   Subpart V
40 CM Part 63,
   SubpriH
4QCFRPart63,
   Subpart I
40 CFR Part 264,
   Subpart BB
40 CFR Part 265,
   Subpart BB
     Subsequent
   SemiAnnual/
  Period Reports
 process unit identification

The following information by month in
the reporting period:

 number of valves, pumps, and
compressors for which leaks were
detected
                   number of valves, pumps, and
                  compressors for which leaks were not
                  repaired as required
                   the facts that explain each delay of
                  repair, and where appropriate, why a
                  process unit shutdown was technically
                  infeasible
 process unit identification

The following information by month in
the reporting period:

 number of valves, pumps, and
compressors for which leaks were
detected
                                        number of valves, pumps, and
                                       compressors for which leaks were not
                                       repaired as required
                                        the facts that explain each delay of
                                       repair, and where appropriate, why a
                                       process unit shutdown was technically
                                       infeasible
                   not required

                   not required by month
                    the number of valves, pumps,
                  compressors, agitators, connectors, and
                  screwed connectors for which leaks were
                  detected

                    the number of valves, pumps,
                  compressors, agitators, connectors, and
                  screwed connectors for which leaks were
                  not repaired

                    explanation of why repairs delayed and
                  why process unit shutdown was
                  infeasible

                  ADDS:

                    the percent leakers for valves, pumps,
                  connectors, and screwed connectors

                    the total number of valves, pumps,
                  connectors, and screwed connectors
                  monitored

                    identification of the number of valves
                  and connectors determined to be
                  nonrepairable

                    notification of change in connector
                  monitoring alternatives (if applicable)

                  For "no detectable emissions"
                  components:  all monitoring to show
                  compliance

                    initiation of monthly monitoring under
                  phase IH or QIP (if applicable)	
                                      Not specified for part 265.

                                      For part 264:

                                       The EPA identification number, name,
                                      and address of the facility.

                                      The following information by month in
                                      the reporting period:

                                       equipment identification  number of
                                      each vaive,  pump, and compressor for
                                      which leaks were not repaired as
                                      required

                                       dates of hazardous waste management
                                      unit shutdowns that occurred within the
                                      semiannual  reporting period

                                       dates when the required  control device
                                      exceeded or operated outside design
                                      specifications and was not corrected
                                      within 24 hours, the duration and cause
                                      of each exceedance, and any corrective
                                      measures taken.

                                      If during the semiannual reporting
                                      period, pumps, valves, and connectors
                                      are repaired as  required and the control
                                      device does not exceed or operate
                                      outside of design specifications for
                                      more than 24 hours, a report to the
                                      Regional Administrator is not required.

-------
SUMMARY OF REGULATION
page B49
Reporting
Requirements
Subsequent
SemiAnnual/
Period Reports
(concluded)
Batch Processes -
Pressure Testing
Compliance with
Alternative
Standards for
Valves
REGULATION
40 CFR Part 60,
Subpart VV
Dates of process unit shutdowns that
occurred within the semiannual
reporting period
Revisions to items reported in the initial
semiannual report if changes have
occurred since the initial semiannual
report or subsequent revisions to the
initial semiannual report
Report of all performance test in
accordance with §60.8,

Not applicable.
90 day prior notice required.
40 CFR Part 61 , 40 CFR Part 61 ,
Subpart J Subpart V
Dates of process unit shutdowns that
occurred within the semiannual reporting
period
Revisions to items reported in the initial
semiannual report if changes have
occurred since the initial semiannual
report or subsequent revisions to the
initial semiannual report
Report .of. all performance test and
monitoring to determine compliance with
no detectable emissions and with
§63.243-1 and -2.
Not applicable.
90 day prior notice required.
40 CFR Part 63, 40 CFR Part 63,
Subpart H Subpart I
not required
not required
not required
See Regulation Summary table for
specific requirements.
Not applicable.
40 CFR Part 264,
Subpart BB
40 CFR Part 265,
Subpart BB
not required
not required
not required
Not applicable.
Not applicable.

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                                  APPENDIX C

        EQUIPMENT LEAK REGULATIONS: SUMMARY BY COMPONENT

                                                                            Bigs
40 CFR PART 60, SUBPART W
Closed-Vent Systems and Control Devices . .	C-l
Compressors	C-3
Dual Mechanical Seal System	C-6
No Detectable Emissions .	C-8
Open-Ended Valves or Lines	  C-10
Pressure Relief Devices in Gas/Vapor Service	C-ll
Pumps and Valves in Heavy Liquid Service, Pressure Relief Devices in Light
Liquid or Heavy Liquid Service, and Flanges and Other Connectors 	  C-13
Pumps in Light Liquid Service	,	  C-15
Sampling Connection Systems	  C-18
Valves in Gas/Vapor and Light Liquid Service  	C-20

40 CFR PART 61, SUBPARTS J AND V
Closed-Vent Systems and Control Devices	C-23
Compressors	!	  C-25
Dual Mechanical Seal System . . .	C-28
No Detectable Emissions	C-31
Open-Ended Valves or Lines	  C-33
Pressure Relief Devices in Gas/Vapor Service	C-35
Pressure Relief Devices in Liquid Services, Flanges and Other Connectors	C-37
Product Accumulator Vessels	  C-39
Pumps in VHAP Service	C-41
Sampling Connection Systems  .	C-44
Valves in VHAP Service	  C-46

40 CFR PART 63, SUBPARTS H AND I
Agitators in Gas/Vapor Service or Light Liquid Service	  C-49
Alternative Means of Emission Limitations: Enelosed-Vented Process Units	C-53
Alternative Means of Emission Limitations: Batch Processes	  C-54
Closed-Vent Systems and Control Devices	C-58
Compressors	  C-62
Connectors in Gas/Vapor and Light Liquid Service  	  C-65
Dual Mechanical Seal System	  C-70
Open-Ended Valves or Lines		  C-73
Pressure Relief Devices in Gas/Vapor Service	-....•	C-75

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Pumps in Light Liquid Service	C-78
Pumps, Valves, Connectors, and Agitators in Heavy Liquid Service;
Instrumentation. Systems; and Pressure Relief Devices in Liquid Service	C-82
Quality Improvement Program for Pumps in Light Liquid Service .	C-86
Quality Improvement Program for Valves	 C-89
Sampling Connection Systems	,	C-93
Surge Control Vessels and Bottoms Receivers	 C-95
Valves in Gas/Vapor and Light Liquid Service	 C-97

40 CFR PART 264 AND PART 265, SUBPARTS BB
Closed-Vent Systems and Control Devices	  C-101
Compressors	  C-105
Dual Mechanical Seal  System	  C-108
No Detectable Emissions	  C-lll
Open-Ended Valves or Lines	  C-113
Pressure Relief Devices in Gas/Vapor Service	  C-115
Pumps and Valves in Heavy Liquid Service, Pressure  Relief Devices in Light
Liquid or Heavy Liquid Service, and Flanges and Other Connectors	  C-117
Pumps in Light Liquid Service	  C-120
Sampling Connection Systems	  C-123
Valves in Gas/Vapor and Light Liquid Service  	  C-125

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CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                  APPLICABLE REGULATIONS
            40 CFR Part 61,
            Subparts J and V
40 CFR Part 63,
Sabparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB
ITEM
Basic Standard
Leak Definition

Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
REQUIREMENTS
Control devices and closed-vent systems to be operated at all times that emissions may be vented to
them
Control Devices:
» vapor recovery systems: 95 percent or greater recovery
• combustion devices: 95 percent or greater reduction or minimum residence time of 0.75 seconds
at a minimum temperature of 816 °C
« flares: comply with §60,18
• monitor to ensure operated and maintained in conformance with design
Monitoring:
• closed-vent systems: inspect initially, annually, and at other times as requested by the
Administrator
> 500 ppm above background or visual inspections

Equivalent means of emission limitation
Vapor collection or closed-vent systems operated under a vacuum
Unsafe or difficult to inspect portions of closed-vent systems require alternate inspection plan
Hard pipe construction: Method 21 for initial inspection, annual visual inspections
Duct work construction: Method 21 for initial and annual inspections
First attempt to repair within 5 calendar days of detection
Repair as soon as practicable; no later than 15 days after detection
Allowed if technically infeasible without process unit shutdown or if owner/operator determines that
emissions from immediate repair would be greater than emissions from delay of repair. Repair is
required before end of next process unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in VOC service
          CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                                    page C-l

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                    CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                                          APPLICABLE REGULATIONS
                                  40 CFR Part 61,
                                  Sabparts J and V
                                          40 CFR Part 63,
                                          Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265. Subpart BB
      HEM
                                     REQUIREMENTS
Recordkeeping
Requirements
 When no leak detected:
  «  record that instrument or visual inspection was conducted
  »  date of inspection
  *  statement that no leaks were detected

Information to be kept for all closed-vent systems and control devices:
  »  detailed schematics, design specifications, and piping and instrumentation diagrams
  •  dates and descriptions of any changes in design specifications
  •  description of parameters) to be monitored to ensure proper operation and maintenance
  •  explanation of selected parameter(s)
  •  periods when not operated according to design
  *  dates of startups and shutdown of closed-vent system and control device
  »  list of ID numbers of subject closed-vent systems and control devices
  »  list of ID numbers for closed-vent systems and control devices in vacuum service

Information to be kept in a log for determining exemptions:
  •  analysis demonstrating design capacity of affected facility
  •  demonstration that the feed or raw materials and products from the affected facility are heavy
    liquids or beverage alcohols
  »  analysis demonstrating that equipment is not in VOC service

Information to be kept for unsafe to Inspect parts of closed-vent system (40 CER 60.482-10Q)):
  •  identification
  «  explanation for designation
  •  plan for inspecting equipment

Information to be kept for difficult to inspect parts of closed-vent system (40 CER 60.482-10(k)):
  •  identification
  »  explanation for designation
  »  plan for inspecting equipment
Reporting
Requirements
Initial report:
 •  process unit identification

Subsequent semiannual reports:
 «  process unit identification
 •  dates of process unit shutdowns that occurred within the semiannual repotting period
 «  revisions to items reported in the initial report if changes have occurred since the initial report or
    subsequent revisions to the initial report
 «  report of all performance tests in accordance with §60.8
                               CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                                                                                    page C-2

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  COMPRESSORS
APPLICABLE REGULATIONS
40 CFR Part 61f
Subparts J and V

40 CFR Part 63,
Subparts H and I

40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB

ITEM
Basic Standard
Leak Definition

Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
REQUIREMENTS
Equipped with compliant seal system that includes a barrier fluid system that prevents leakage of
VOC to atmosphere
For each seal system:
• operate with the barrier fluid at a pressure that is greater than the stuffing box pressure, or
• equip with a barrier fluid system that is connected by a closed vent system to a compliant control
device, or
» equip with a system that purges the barrier fluid into a process stream with zero VOC emissions
to the atmosphere
The barrier fluid system shall be in heavy liquid service or shall not be in VOC service
Install sensor to detect failure of seal system, barrier fluid system, or both
Check sensor daily or equip with audible alarm
Establish criteria that indicates failure of seal system, barrier fluid system, or both
Sensor indicates failure of seal system, barrier fluid system, or both, based on established criteria.

Equivalent means of emission limitation
Equipment in vacuum service
Reciprocating compressors that meet certain criteria
Compressors designated for no detectable emissions, which operate less than 500 ppm above
background (see No Detectable Emissions)
Compressors equipped with a compliant closed-vent system and control device (see Closed-vent
Systems and Control Devices)
Sensor alarm or visual check
First attempt within 5 calendar days of detection
Repair as soon as practicable; no later than 15 calendar days after detection
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in VOC service
     COMPRESSORS
page C-3

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                                             COMPRESSORS
                                          APPLICABLE REGULATIONS
                                  4QCFRPart61,
                                  Subparts J and V
                                           40CFRPart63,
                                           Subparts H and I
40 CFR Part 264, Subpart IB
40 CFR Part 265, SubpartBB
      ITEM
                                     REQUIREMENTS
Recordkeeping
Requirements
When leak detected:
  » a weather-proof and readily visible identification, marked with the equipment ID number,
    attached to the leaking equipment
  » ID may be removed after it has been repaired

Information to be kept in log for 2 years after leak detected:
  • instrument and operator ID numbers and equipment ID number
  • date leak detected
  « dates of each attempt to repair leak
  » repair methods applied in each attempt to repair
  « "above 10,000" if maximum instrument reading after each repair attempt is ,>. 10,000 ppm
  « "repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection
  » signature of owner/operator whose decision it was that repair could not be effected without a
    process shutdown
  • expected date of successful repair if leak is not repaired within the 15 days
  « dates of process unit shutdown that occurred while the equipment is unrepaired
  • date of successful repair of the leak

Information to be kept for all compressors:
  • list of ID numbers of subject compressors
  * list of ID numbers of compressors designated for no detectable emissions and signed by
    owner/operator
  • for each compliance test for compressors designated for no detectable emissions:
    * »  date conducted
    • •  background level measured
    • •  maximum instrument reading
  » list of ID numbers for compressors in vacuum service

Information to be kept for barrier fluid and seal systems:
  » design criteria for indicating failure
  • explanation for selected criteria
  • any changes to selected criteria and reasons for  change

Information to be kept in a log for determining exemptions:
  • analysis demonstrating design capacity of affected facility
  » demonstrations that the feed or raw materials and products from the affected facility are heavy
    liquids or beverage alcohols
  » analysis demonstrating that equipment is not in VOC service

Information to be kept if equipped with a closed-vent system and control device:
  * periods when closed-vent system and control device are not operated according to design
  « dates of startup and shutdown of the closed-vent system and control device
                                                COMPRESSORS
                                                                                     page C-4

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                                             COMPRESSORS
                                          APPLICABLE REGULATIONS
      40 CFR Part 60,
        SubpartW
               40 CFR Pan 61,
               Subparts J and V
40 CFR Part 63,
SnbpartsH and I
40 CFR Part 264, Subpart BB
40 CFR Part 265. Subpart BB
     ITEM
                                     REQUIREMENTS
Reporting
Requirements
Initial report;
  •  process unit identification
  «  number of compressors, excluding those designated for no detectable emissions or equipped with
    a compliant closed-vent system and control device

Subsequent semiannual reports:
  •  process unit identification
  •  the following information for each month in the reporting period:
    • •  number of compressors for which leaks were detected
    « «  number of compressors for which leaks were not repaired within 15 days after detection
    » •  the facts that explain each delay of repair, and where appropriate, why a process unit
        shutdown was technically infeasible
  •  dates of process unit shutdowns that occurred within the semiannual reporting period
  •  revisions to items reported in the initial report if changes have occurred since the initial report or
    subsequent revisions to the initial report
  »  report of all performance tests in accordance with §60.8.
                                                COMPRESSORS
                                                                                                        page C-5

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DUAL MECHANICAL SEAL SYSTEM
          APPLICABLE REGULATIONS
   40CFRPart61,
   Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpait BB
40 CFR Part 265. Subpart BB
ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
REQUIREMENTS
For each dual mechanical seal system:
« operate the barrier fluid at a pressure that is at all times greater than the pump stuffing box
pressure, or
• connect the barrier fluid degassing reservoir by a closed-vent system to a control device, or
• equip with a system that purges the barrier fluid into a process stream with zero VOC emissions
to the atmosphere
For all dual mechanical seal systems:
• the barrier fluid system shall be in heavy liquid service or not in VOC service
« equip each barrier fluid system with a sensor that detects failure of seal system, barrier fluid
system, or both
• • check each sensor daily or equip with audible alarm
» determine criteria for sensor and for dripping liquids that indicates failure of the seal system, the
barrier fluid system, or both
» perform weekly visual inspections for indications of liquids dripping from the pump seals
Applies as an exemption to: Pumps in Light Liquid Service
Indications of liquids dripping from the pump seal or sensor detection
N/A
N/A
Visual, sensor
First attempt within 5 calendar days of detection
Repair as soon as practicable; no later than 15 days after detection
If repair requires use of a dual mechanical seal system that includes a barrier fluid system and repair
is completed as soon as practicable but no later than 6 months after leak detected
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in VOC service
      DUAL MECHANICAL SEAL SYSTEM
                                   page C-6

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                              DUAL MECHANICAL SEAL SYSTEM
                                          APPLICABLE REGULATIONS
                                  40 CFR Part 61,
                                  Snbpatts J and V
                                           40 CFR Part 63,
                                           Subpaits H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Sabpart BB
     ITEM
                                     REQUIREMENTS
Recordkeeping
Requirements
When leak detected:
 «  a weather-proof and readily visible identification, marked with the equipment ID number,
    attached to the leaking equipment
 »  ID may be removed after it has been repaired

Information to be kept in log for 2 years after leak detected:
 »  instrument and operator ID numbers and equipment ID number
 •  date leak detected
 •  dates of each attempt to repair leak
 «  repair methods applied in each attempt to repair
 •  "above 10,000" if maximum instrument reading after each repair attempt is _>. 10,000 ppm
 •  "repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection
 »  signature of owner/operator whose decision it was that repair could not be effected without a
    process shutdown
 »  expected date of successful repair if leak is not repaired within the 15 days
 «  dates of process unit shutdown that occurred while the equipment is unrepaired
 •  date of successful repair of the leak

Information to be kept for all dual mechanical seal systems:
 •  list of ID numbers of equipment with dual mechanical seal systems
 «  list of JDD numbers of equipment in vacuum service

Information to be kept for barrier fluid and seal systems:
 «  design criteria for indicating failure
 «  explanation for selected criteria
 •  any changes to selected criteria and reasons for change

Information to be kept in a log for determining exemptions:
 •  analysis demonstrating design capacity of affected facility
 »  demonstration that the feed or raw materials and products from the affected facility are heavy
    liquids or beverage alcohols
 •  analysis demonstrating that equipment is not hi VOC service
Reporting
Requirements
Initial report:
 »  process unit identification

Subsequent semiannual reports:
 «  process unit identification
 *  the following information for each month in the reporting period:
    • • number of pumps for which leaks were detected
    » • number of pumps for which leaks were not repaired as required
    » • the facts that explain each delay of repair, and where appropriate, why a process unit
        shutdown was technically infeasible
 »  dates of process unit shutdowns that occurred within the semiannual reporting period
 •  revisions to items reported in the initial report if changes have occurred since the initial report or
    subsequent revisions to the initial report
 »  report of all performance tests in accordance with §60.8
                                       DUAL MECHANICAL SEAL SYSTEM
                                                                                      page C-7

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 NO DETECTABLE EMISSIONS
       APPLICABLE REGULATIONS
40 CFR Part 61,
Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB
ITEM
Basic Standard



Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
REQUIREMENTS
Has an instrument reading of less than 500 ppm above background
specified in 60.485(c)
as measured by the methods
Test for compliance initially upon designation, annually, and at other times as requested by the
Administrator
Applies as basic standard for:
• pressure relief devices in gas/vapor service

Applies as an alternate standard to:
• pumps in light liquid service (must have no externally actuated shaft penetrating the pump
housing)
» valves in gas/vapor service or in light liquid service (must have no external actuating mechanism
in contact with the process fluid)
<500 ppm above background
N/A
N/A
Method 21
N/A
N/A
      NO DETECTABLE EMISSIONS
                                  page C-8

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                                   NO DETECTABLE EMISSIONS
                                          APPLICABLE REGULATIONS
                                  40 CFR Part 61,
                                  Subparts J and V
                                           40 CFR Part 63,
                                           Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB
     ITEM
                                     REQUIREMENTS
Recordkeeping
Requirements
When leak detected:
  «  a weather-proof and readily visible identification, marked with the equipment ID number,
    attached to the leaking equipment
  •  ID may be removed after leak has been repaired

Information to be kept in log for 2 years after leak detected:
  •  instrument and operator ID numbers and equipment ID number
  •  date leak detected
  •  dates of each attempt to repair leak
  •  repair methods applied in each attempt to repair
  «  "above 10,000" if maximum instrument reading after each repair attempt is 210,000 ppm
  •  "repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection
  «  signature of owner/operator whose decision it was that repair could not be effected without a
    process shutdown
  •  expected  date of successful repair if leak is not repaired within the 15 days
  •  dates of process unit shutdown that occurred while the equipment is unrepaired
  «  date of successful repair of the leak

Information to be kept:
  •  list of ID numbers of equipment designated for no detectable emissions and signed by
    owner/operator
  *  for each compliance test for no detectable emissions:
    • •  date conducted
    • •  background level measured
    • •  maximum instrument reading
  »  list of ID numbers for equipment in vacuum service
  •  list of ID numbers for pressure relief devices in gas/vapor service
Reporting
Requirements
Semiannual reports:
  » dates of process unit shutdowns that occurred within the semi-annual reporting period
  • revisions to items reported in the initial report if changes have occurred since the initial report or
    subsequent revisions to the initial report
  « report of all performance tests in accordance with §60.8
                                          NO DETECTABLE EMISSIONS
                                                                                     page C-9

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OPEN-ENDED VALVES OR LINES
       APPLICABLE REGULATIONS
 40CFRPart61,
 Subparts I and V
40eFRPart63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB
ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
Recordkeeping
Requirements
Reporting
Requirements
REQUIREMENTS
Use cap, blind flange, plug, or second valve to seal open end at all times except when operations
require flow through open end
Second valve: close valve on process fluid end before closing second valve
Double block and bleed system: bleed valve or line may remain open during operations that require
venting the line between the block valves, but comply with basic standard at all other times
N/A
Equivalent means of emission limitation
Equipment in vacuum service
N/A
N/A
N/A
Information to be kept for all open-ended valves or lines:
« list of ID number of subject open-ended valves or lines
« list of ID numbers of equipment in vacuum service
Information to be kept in a log for determining exemptions:
• analysis demonstrating design capacity of affected facility
« demonstration that the feed or raw materials and products from the affected
liquids or beverage alcohols
• analysis demonstrating that equipment is not in VOC service
facility are heavy
Initial report:
• process unit identification
Subsequent semiannual reports:
• process unit ID
• revisions to items reported in the initial report if changes have occurred since the initial report or
subsequent revisions to the initial report
      OPEN-ENDED VALVES OR LINES
                                 page C-10

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PRESSURE RELIEF DEVICES IN GAS/VAPOR SERVICE
                   APPLICABLE REGULATIONS
             40CFRPait61,
             Subparts J and V
40 CPR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB
ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
REQUIREMENTS
No detectable emissions (less than 500 ppm above background), except during pressure
After each release return to no detectable emissions within 5 calendar days as indicated
of the pressure relief device
releases
by monitoring
No detectable emissions (<500 ppm above background)
N/A
Equipment in vacuum service
Pressure relief devices equipped with a compliant closed-vent system and control device (see Closed-
vent Systems and Control Devices)
Method 21
Return to condition of "no detectable emissions" as soon as practicable but no later than
days after pressure release
5 calendar
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in VOC service
          PRESSURE RELIEF DEVICES IN .GAS/VAPOR SERVICE
                                  pageC-11

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                  PRESSURE RELIEF DEVICES IN GAS/VAPOR SERVICE
                                         APPLICABLE REGULATIONS
      40 CFR Part 60,
        SubpartW
              40CFRPait61,
              Subparts I and V
40 CFR Part 63,
Subparts H and I
40 CFR Pan 264, Subpart BB
40 CFR Part 265, Subpart BB
     ITEM
                                    REQUIREMENTS
Recordkeeping
Requirements
Infonnation to be kept for all pressure relief devices:
  •  list of ID numbers of pressure relief devices required to comply
  «  list of ID numbers for no detectable emissions
  »  for each compliance test for pressure relief devices designated for no detectable emissions:
    » •  dates conducted
    • *  background level measured
    • •  maximum instrument reading
  •  list of ID numbers for pressure relief devices in vacuum service

Information to be kept in a log for determining exemptions:
  •  analysis demonstrating design capacity of affected facility
  »  demonstration that the feed or raw materials and products from the affected facility are heavy
    liquids or beverage alcohols
  •  analysis demonstrating that equipment is not in VOC service

Information to be kept if equipped with a closed-vent system and control device:
  •  periods when closed-vent system and control device were not operated according to design
  »  dates of startup and shutdown of the closed-vent system and control device
Reporting
Requirements
Initial report:
 »  process unit ID for pressure relief devices

Subsequent semiannual reports:
 »  process unit identification
 •  the facts that explain each delay of repair, and where appropriate, why a process unit shutdown
    was technically infeasible
 »  dates of process unit shutdowns that occurred within the semiannual reporting period
 •  revisions to items reported in the initial report if changes have occurred since the initial report or
    subsequent revisions to the initial report
 «  report of all performance tests in accordance with §60,8.
                              PRESSURE RELIEF DEVICES IN GAS/VAPOR SERVICE
                                                                                  page C-12

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            PUMPS AND VALVES IN HEAVY LIQUID SERVICE, PRESSURE
                RELIEF DEVICES IN LIGHT LIQUID OR HEAVY LIQUID  '
                 SERVICE, AND FLANGES AND OTHER CONNECTORS
                                       APPLICABLE REGULATIONS
     4QCFRPart60,
          partW
             40CFRPart61,
             Siibparts J and V
40CFRPart63,
Subparts H and I
40 CPR Part 254, Subpart BB
40 CFR Part 265, Subpart BB
     ITEM
                                  REQUIREMENTS
Basic Standard
Monitoring of potential leaks within 5 calendar days of detection if evidence of potential leak is found
by visual, auditory, olfactory, or other detection method
Leak Definition
10,000 ppm
Alternative
Standards
Equivalent means of emission limitation
Exemptions
Equipment in vacuum service
Monitoring
Method
Method 21
Repair
Requirements
First attempt within 5 calendar days of detection

Repair as soon as practicable; no later than 15 days after detection
Delay of Repair
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown

Allowed for equipment that is isolated from the process and that does not remain in VOC service.

For valves:
 »  allowed if emissions of purged material resulting from immediate repair would exceed fugitive
    emissions from delay of repair, and purged material is collected and destroyed or recovered in
    compliant control device when repair occurs
 •  delay beyond a process unit shutdown allowed if valve assemblies have been depleted and valve
    assembly supplies had been sufficiently stocked before supplies were depleted
 »  not allowed beyond next process unit shutdown unless next process unit shutdown occurs sooner
    than 6 months after first process unit shutdown.

For pumps:
 •  allowed if repair requires use of dual mechanical seal system that includes barrier fluid and
    repair is completed as soon as practicable but not later than 6 months after leak was detected.
             PUMPS AND VALVES IN HEAVY LIQUID SERVICE, PRESSURE RELIEF DEVICES IN LIGHT
                 LIQUID OR HEAVY LIQUID SERVICE, AND FLANGES AND OTHER CONNECTORS          page C-13

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            PUMPS AND VALVES IN HEAVY LIQUID SERVICE, PRESSURE
                RELIEF DEVICES IN LIGHT LIQUID OR HEAVY LIQUID
                  SERVICE, AND FLANGES AND OTHER CONNECTORS
                                       APPLICABLE REGULATIONS
                                40CERPart61,
                                Subparts J and V
                                       40 CFR Part 63,
                                       Snbparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB
     ITEM
                                  REQUIREMENTS
Recordkeeping
Requirements
When leak detected:
 »  a weather-proof and readily visible identification, marked with the equipment ID number,
    attached to the leaking equipment
 «  ID may be removed after it has been repaired

Information to be kept in log for 2 years after leak detected:
 »  instrument and operator ED numbers and equipment ID number
 •  date leak detected
 *  dates of each attempt to repair leak
 •  repair methods applied in each attempt to repair
 »  "above 10,000" if maximum instrument reading after each repair attempt is > 10,000 ppm
 •  "repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection
 »  signature of owner/operator whose decision it was that repair could not be affected without a
    process shutdown
 •  expected  date of successful repair if leak is not repaired within 15 days
 *  dates of process unit shutdown that occurred while the equipment is unrepaired
 •  date of successful repair of the leak

Information to be kept for all equipment in these categories:
 «  list of ID numbers of subject equipment in these categories
 »  list of ID numbers for  equipment in vacuum service

Information to be kept in a log for determining exemptions:
 «  analysis demonstrating design capacity of affected facility
 «  demonstration that the feed or raw materials and products from the affected facility are heavy
    liquids or beverage alcohols
 «  analysis demonstrating that equipment is not in VOC service
Reporting
Requirements
Initial report:
 «  process unit identification

Subsequent semiannual reports:
 •  process unit identification
 »  by month in the reporting period, the facts that explain each delay of repair, and where
    appropriate, why a process unit shutdown was technically infeasible
 «  dates of process unit shutdowns that occurred within the semiannual reporting period
 »  revisions to items reported in the initial report if changes have occurred since the initial report or
    subsequent revisions to the initial report
 «  report of all performance tests in accordance with §60.8
             PUMPS AND VALVES IN HEAVY LIQUID SERVICE, PRESSURE RELIEF DEVICES IN LIGHT
                 LIQUID OR HEAVY LIQUID SERVICE, AND FLANGES AND OTHER CONNECTORS
                                                                              page C-14

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PUMPS IN LIGHT LIQUID SERVICE
        APPLICABLE REGULATIONS
40CERPart60, 40CERPart61, 40CERPart63,
Subpart W Subparts J and V Subparts H and I
MH
ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
•

40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB


REQUIREMENTS
Monthly leak detection and repair
Weekly visual observation for leaks
10,000 ppm
Indications of liquids dripping from pump seal

Equivalent means of emission limitation

Pumps in vacuum service
Dual mechanical seal pumps (see Dual Mechanical Seals)
Any pump designated for no detectable emissions (see No Detectable Emissions)
Any pump equipped with a compliant closed-vent system and control device (see Closed-vent Systems
and Control Devices)
Method 21; no more than 1 cm from rotating shaft
First attempt within 5 calendar days of detection
Repair as soon as practicable; no later than 15 days after detection
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown.
Allowed for equipment that is isolated from the process and that does not remain in VOC service
Allowed if repair requires use of a dual mechanical seal system that includes a barrier fluid system
and repair is completed as soon as practicable but not later than 6 months after leak was detected
      PUMPS IN LIGHT LIQUID SERVICE
page C-15

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                               PUMPS IN LIGHT LIQUID SERVICE
                                          APPLICABLE REGULATIONS
                                  40CFRPart61,
                                  Subparts J and V
                                           40 CFR Part 63,
                                           Subparts H and I
40 CFR Pan 264, Subpart BB
40 CFR Part 265, Subpart BB
     HEM
                                     REQUIREMENTS
Recordkeeping
Requirements
When leak detected:
  « a weather-proof and readily visible identification, marked with the equipment ID number,
    attached to the leaking equipment
  • ID may be removed after it has been repaired

Information to be kept in log for 2 years after leak detected:
  • instrument and operator ID numbers and equipment ED number
  * date leak detected
  * dates of each attempt to repair leak
  • repair methods applied in each attempt to repair
  • "above 10,000" if maximum instrument reading after each repair attempt is >_ 10,000 ppm
  • "repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection
  « signature of owner/operator whose decision it was that repair could not be effected without a
    process shutdown
  » expected date of successful repair if leak is not repaired within the 15 days
  • dates of process unit shutdown that occurred while the equipment is unrepaired
  » date of successful repair of the leak

Information to be kept for all pumps:
  • list of ED numbers of subject pumps
  » list of ED numbers of pumps designated for no detectable emissions and signed by
    owner/operator
  » for each compliance test for pumps designated for no detectable emissions:
    • •  date conducted
    • •  background level measured
    • •  maximum instrument reading
  » identification of pumps in vacuum service

Information to be kept for barrier fluid and seal systems:
  * design criteria for indicating failure
  « explanation of selected criteria
  • any changes to selected criteria and reasons for change

Information to be kept if pump is equipped with a closed-vent system and control device:
  • periods when closed-vent system and control device is not operating according to design
  • dates of startup and shutdown of closed-vent system and control device

Information to be kept in a log for determining exemptions:
  • analysis demonstrating design capacity of affected facility
  • demonstration that the feed or raw materials and products from the affected facility are heavy
    liquids or beverage alcohols
  « analysis demonstrating that equipment is not in VOC service
                                       PUMPS IN LIGHT LIQUID SERVICE
                                                                                    page C-16

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                               PUMPS IN LIGHT LIQUID SERVICE
                                         APPLICABLE REGULATIONS
                                 40 CFR Pan 61,
                                 Subparts J and V
                                          40 CFR Pan 63,
                                          Subparts H and I
40 CFR Part 264, Subpan BB
40 CFR Part 265, Subpan BB
     ITEM
                                    REQUIREMENTS
Reporting
Requirements
Initial report:
 •  process unit identification
 «  number of pumps, excluding those designated for no detectable emissions or equipped with a
    closed-vent system or control device

Subsequent semiannual reports:
 »  process unit identification
 •  the following information for each month in the reporting period:
    • •  number of pumps for which leaks were detected
    • •  number of pumps for which leaks were not repaired within 15 days after detection
    • •  the facts that explain each delay of repair, and where appropriate, why a process unit  •
        shutdown was technically infeasible
 »  dates of process unit shutdowns that occurred within the semiannual reporting period
 •  revisions to items reported in the initial report if changes have occurred since the initial report or
    subsequent revisions to the initial report
 «  report of all performance test in accordance with §60.8
                                      PUMPS IN LIGHT LIQUID SERVICE
                                                                                  page C-17

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SAMPLING CONNECTION SYSTEMS
        APPLICABLE REGULATIONS
40CFRPart60, 40CFRPart61, 40CFRPart63,
1 Subpart W Subparts J and V Subparts H and I
^•H
ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
Recordkeeping
Requirements
•

40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB


REQUIREMENTS
Equipped with closed-purged, closed-loop, or closed-vent system that returns the fluid to the process
line, recycles the purged fluid to a process, or sends it to a compliant control device
N/A

Equivalent means of emission limitation

Equipment in vacuum service
In-situ sampling systems
Sampling systems without purges
N/A
N/A
N/A
Information to be kept for all sampling connections:
« list of ID numbers of subject sampling connection systems
« list of ID numbers of sampling connections systems in vacuum service
Information to be kept if equipped with closed-vent system and control device:
» periods when closed-vent system and control device is not operated according to design
• dates of startup and shutdown of closed-vent system and control device
Information to be kept in a log for determining exemptions:
* analysis demonstrating design capacity of affected facility
« demonstration that the feed or raw materials and products from the affected facility are heavy
liquids or beverage alcohols
* analysis demonstrating that equipment is not in VOC service
     SAMPLING CONNECTION SYSTEMS
page C-1S

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                             SAMPLING CONNECTION SYSTEMS
                                       APPLICABLE REGULATIONS
     40 CFR Part 60,
       SubpartW
              40CFR Panels
              Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Pan 264, Subpart BB
40 CFR Pan 265, Subpart BB
     ITEM
                                  REQUIREMENTS
Reporting
Requirements
Initial report:
 «  process unit identification

Subsequent semiannual reports:
 «  process unit ID
 •  revisions to items reported in the initial report if changes have occurred since the initial report or
    subsequent revisions to the initial report
                                    SAMPLING CONNECTION SYSTEMS
                                                                              page C-19

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         VALVES IN GAS/VAPOR AND LIGHT LIQUID SERVICE
                            APPLICABLE REGULATIONS
40 CFR Part 60,
  SubpartW
40CFRPart61,
Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB
ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
REQUIREMENTS
Monitor monthly
If valve does not leak for 2 months, may be monitored quarterly
If valve leaks, monitor monthly until no leak is detected for 2 consecutive months
10,000 ppm


Equivalent means of emission limitation
Allowable percentage of valves leaking: may elect to comply with s2% leaking valves
• notify Administrator before implementing
• conduct performance tests initially, annually, and as requested by Administrator
• • monitor within one week using Method 21
« • leak definition is 10,000 ppm
• • leak percentage cannot be greater than 2.0%
Skip period leak detection and repair:
» notify Administrator before implementing
« comply initially with basic standard
• if s2% leaking after 2 consecutive quarterly leak detection periods, may begin to skip 1 of the
quarterly monitoring periods
• after 5 consecutive periods with s2.0% leaking, may begin to skip 3 of the quarterly periods
» if >2.0% leaking, comply with basic standard, but can again elect to use alternate standard
Valves in vacuum service
Valves designated for no detectable emissions (less than 500 ppm above background - see
Detectable Emissions)
Valves designated unsafe to monitor or difficult to monitor
No
Method 21
First attempt within 5 calendar days of detection
Repair as soon as practicable; no later than 15 days after detection
                  VALVES IN GAS/VAPOR AND LIGHT LIQUID SERVICE
                                                      page C-20

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                  VALVES IN GAS/VAPOR AND LIGHT LIQUID SERVICE
                                          APPLICABLE REGULATIONS
                                  40CFRPart61,
                                  Subparts J and V
                                          40 CFR Part 63,
                                          Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB
     ITEM
                                    REQUIREMENTS
Delay of Repair
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown

Allowed for equipment that is isolated from the process and that does not remain in VOC service

Allowed if emissions of purged material from immediate repair would exceed fugitive emissions from
delay of repair, and purged materials are collected and destroyed or recovered in a compliant control
device when repair occurs

Allowed beyond process unit shutdown if otherwise sufficient supply of valve assembly replacements
are exhausted and supplies had been sufficiently stocked before depletion

Not allowed beyond next process unit shutdown unless next shutdown occurs sooner than 6 months
after first process unit shutdown
Recordkeeping
Requirements
When leak detected:
  •  a weather-proof and readily visible identification, marked with the equipment ID number,
    attached to the leaking equipment
  •  ID may be removed after it has been repaired and monitored for 2 months with no leaks detected
    during those 2 months

Information to be kept in log for 2 years after leak detected:
  •  instrument and operator ID numbers and equipment ID number
  •  date leak detected
  «  dates of each attempt to repair leak
  »  repair methods applied in each attempt to repair
  •  "above 10,000" if maximum instrument reading after each repair attempt is >  10,000 ppm
  •  "repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection
  •  signature of owner/operator whose decision it was that repair could not be effected without a
    process shutdown
  •  expected date of successful repair if leak is not repaired within the 15 days
  •  dates of process unit shutdown that occurred while the equipment is unrepaired
  »  date of successful repair of the leak

Information to be kept for all valves:
  *  list of ID numbers of subject valves
  •  list of ID numbers of valves designated for no detectable emissions and signed by owner/operator
  •  for each compliance test for valves designated for no detectable emissions:
    • •  date conducted
    • «  background level measured
    • •  maximum instrument reading
  •  list of ID numbers for valves in vacuum service

                                  (Continued on next page)
                              VALVES IN GAS/VAPOR AND LIGHT LIQUID SERVICE
                                                                                   page C-21

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                  VALVES IN GAS/VAPOR AND LIGHT LIQUID SERVICE
                                         APPLICABLE REGULATIONS
      40CFRPtrt60,
        Submit W
              40CFRPart61,
              Snbparts J and V
40CFRPait63,
SubpartsH and!
40 CFR Part 264, Subpart BB
40 CPR Part 265, Subpart BE
     ITEM
                                    REQUIREMENTS
Reeordkeeping
Requirements,
continued
Information to be kept for unsafe or difficult to monitor valves:
  •  list of ID numbers
  »  explanation for designation
  «  planned schedule for monitoring

Information to be kept for valves complying with alternative standard - skip period leak detection and
repair:
  »  schedule of monitoring
  »  percent of valves found leaking during each monitoring period

Information and data to be kept in a log for determining exemptions:
  »  analysis demonstrating design capacity of affected facility
  •  demonstration that the feed or raw materials and products from the affected facility are heavy
    liquids or beverage alcohols
  «  analysis demonstrating that equipment is not in VOC service
Reporting
Requirements
Initial report:
  •  process unit identification
  •  number of valves, excluding those designated for no detectable emissions

Subsequent semiannual reports:
  «  process unit identification
  •  the following information for each month in the reporting period:
    » •  number of valves for which leaks were detected
    • •  number of valves for which leaks were not repaired within 15 days after detection
    • •  the facts that explain each delay of repair, and where appropriate, why a process unit
        shutdown was technically infeasible
  •  dates of process unit shutdowns that occurred within the semiannual reporting period
  »  revisions to items reported in the initial report if changes have occurred since the initial report or
    subsequent revisions to the initial report
  •  report of all performance tests in accordance with §60.8

If complying with alternative standard, notify Administrator 90 days before implementation
                             VALVES IN GAS/VAPOR AND LIGHT LIQUID SERVICE
                                                                                   page C-22

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            CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                             APPLICABLE REGULATIONS
40 CFR Part 60,
  Subpart VV
40 CFR Part 61,
Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB
ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
REQUIREMENTS
Control devices and closed-vent systems to be operated at all times that emissions may be vented to
them
Control Devices:
« vapor recovery systems: 95 percent or greater recovery
» enclosed combustion devices: 95 percent or greater reduction or minimum residence time of
0.50 seconds and minimum temperature of 760 °C
• flares: comply with §60.18
» monitor to ensure operated and maintained in conformance with their design
Closed- Vent Systems:
• no detectable emissions (less than 500 ppm above background) and no visual indications
• monitor initially, annually, and at other times as requested by the Administrator
Closed-vent system: no detectable emissions (<500 ppm above background) and visual inspection

Alternative means of emission limitation

Equipment in vacuum service
Method 21
As soon as practicable, but no later than 15 calendar days after detection
First attempt to repair within 5 calendar days of detection
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in VHAP service
                     CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                                                        page C-23

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                    CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                                          APPLICABLE REGULATIONS
      40CFRPart60,
        Subpart W
              40CFRPart61,
              Subparts J and V
40CPRPart63,
Subparts H and I
40 CPR Part 264, Subpart BB
40 CFR Part 265, Subpart BB
      ITEM
                                    REQUIREMENTS
Recordkeeping
Requirements
Information to be kept for all closed-vent systems and control devices:
  •  detailed schematics, design specifications, and piping and instrumentation diagrams
  •  dates and descriptions of any changes in design specifications
  •  description of parameter^) to be monitored to ensure proper operation and maintenance
  •  explanation of selected parameter(s)
  •  periods when not operated according to design, including periods when a flare pilot light does
    not have a flame
  •  dates of startups and shutdown of the closed-vent system and control device
  »  list of ID numbers of subject closed-vent systems and control devices
  •  list of ID numbers of closed-vent systems and control devices designated for no detectable
    emissions and signed by owner/operator
  »  list of ID numbers for closed-vent systems and control devices in vacuum service
  «  information and data used to demonstrate equipment is not in VHAP service

Information to be kept for use in determining exemptions:
  *  analysis demonstrating design capacity of the process unit
  •  analysis demonstrating that equipment is not in VHAP service
Reporting
Requirements
Initial report:
 «  process unit identification
 »  equipment identification number
 •  type of equipment
 »  percent weight VHAP
 «  process fluid state
 •  method of compliance
 «  reporting schedule for submittal of subsequent semiannual reports
 «  statement notifying Administrator that subpart requirements are being implemented

Subsequent semiannual reports:
 »  process unit identification
 •  dates of process unit shutdowns that occurred within the semiannual reporting period
 •  revisions to items reported in the initial report if changes have occurred since the initial report or
    subsequent revisions to the initial report
 •  report of all performance tests to determine compliance with no detectable emissions
 «  by month in the reporting period, the facts that explain any delay of repairs and, where
    appropriate, why a process unit shutdown was technically infeasible
                               CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                                                                                  page C-24

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                                   COMPRESSORS
                                 APPLICABLE REGULATIONS
40 CFR Part 60,
  Subpart W
40 CFR Part 61,
Subparts J and V
40 CFR Part 63,
Subparls H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB
ITEM
Basic Standard
Leak Definition

Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
REQUIREMENTS
Equip with compliant seal system that includes a barrier fluid system that prevents leakage to
atmosphere
• operate the barrier fluid at a pressure that is at all times greater than the pump stuffing box
pressure, or
» connect the barrier fluid degassing reservoir by a closed-vent system to a control device, or
• equip with a system that purges the barrier fluid into a process stream with zero VHAP
emissions to the atmosphere
The barrier fluid system is not in VHAP service and, if covered under 40 CFR 60, is not in VOC
service
Install sensor that will detect failure of seal system, barrier fluid system, or both
» check each sensor daily or equip with audible alarm, unless at unmanned plant site
Establish criteria that indicates failure of seal system, barrier fluid system, or both
Sensor indicates failure of seal system, barrier fluid system, or both, based on established criteria.

Alternative means of emission limitation
Equipment in vacuum service
Compressors designated for no detectable emissions, which operate less than 500 ppm above
background (see No Detectable Emissions)
Compressors equipped with a compliant closed-vent system and control device (see Closed-vent
Systems and Control Devices)
Sensor alarm or visual check
First attempt within 5 calendar days of detection
Repair as soon as practicable; no later than 15 calendar days after detection
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in VHAP service
                                      COMPRESSORS
                                                               page C-25

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                                            COMPRESSORS
                                          APPLICABLE REGULATIONS
      40 CFR Part 60,
     	Subpart W
              40 CFB. Part 61,
              Suboarts J and V
40 CFR Part 63,
Snbparts Hand I
40 CFR Part 264, Subpart BB
40 CFR Fart 26S, Subpart BB
     ITEM
                                     REQUIREMENTS
Recordkeeping
Requirements
When leak detected:
  •  a weather-proof and readily visible identification, marked with the equipment ID number,
    attached to the leaking equipment
  «  ID may be removed after it has been repaired

Information to be kept in log for 2 years after leak detected:
  »  instrument and operator ID numbers and equipment ID number
  •  date leak detected
  •  dates of each attempt to repair leak
  «  repair methods applied in each attempt to repair
  »  "above 10,000" if maximum instrument reading after each repair attempt is J>. 10,000 ppm
  «  "repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection
  •  signature of owner/operator whose decision it was that repair could not be effected without a
    process shutdown
  •  expected date of successful repair if leak is not repaired within the 15 days
  »  dates of process unit shutdown that occurred while the equipment is unrepaired
  »  date of successful repair of the leak

Information to be kept for all compressors:'
  •  list of ID numbers of subject compressors
  «  list of ID numbers of compressors designated for no detectable emissions and signed by
    owner/operator
  «  for each compliance test for compressors designated for no detectable emissions:
    * »  date conducted
    • •  background level measured
    « »  maximum instrument reading
  •  list of ID numbers for compressors in vacuum service
  «  information and data used to demonstrate equipment is not in VHAP  service

Information to be kept for barrier fluid and seal systems:
  «  design criteria for indicating failure
  •  explanation for selected criteria
  «  any changes to criteria and reasons for change

Information to be kept for compressors equipped with a closed-vent system and control device:
  •  periods when the closed-vent system and control device is not operated as designed, including
    periods when a flare piiot light does not have a flame
  •  dates of start-up and shutdown of the closed-vent system and control device

Information to be kept for use in determining exemptions:
  •  analysis demonstrating design capacity of the process unit
  «  analysis demonstrating that equipment is not in VHAP service
                                                COMPRESSORS
                                                                                    page C-26

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                                            COMPRESSORS
                                          APPLICABLE REGULATIONS
      40 CFR Part 60,
        Subpart W
              40CFRPart61,
              Sabpatts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB
     ITEM
                                     REQUIREMENTS
Reporting
Requirements
Initial report:
  »  equipment identification number
  •  process unit number
  *  type of equipment
  •  percent weight VHAP
  •  process fluid state
  *  method of compliance
  •  reporting schedule for submittal of subsequent semiannual reports
  *  statement notifying Administrator that subpart requirements are being implemented

Subsequent semiannual reports:
  •  process unit identification
  •  the following information by month in the reporting period:
    * •  number of compressors for which leaks were detected
    • •  number of compressors for which leaks were not repaired within 15 days after detection
    « •  the facts that explain each delay of repair, and where appropriate, why a process unit
        shutdown was technically infeasible
  •  dates of process unit shutdowns that occurred within the semiannual reporting period
  «  revisions to items reported in the initial report if changes have occurred since the initial report or
    subsequent revisions to the initial report
  *  report of all performance tests and monitoring to determine compliance with rto detectable
    emissions
                                                COMPRESSORS
                                                                                                       page C-27

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                    DUAL MECHANICAL SEAL SYSTEM
                              APPLICABLE REGULATIONS
40 CFR Part 60,
  SnhpanW
40 CFR Part 61,
Subpaits J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB
ITEM
Basic Standard






Leak Definition



Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
REQUIREMENTS
For each dual mechanical seal system:
» operate the barrier fluid at a pressure that is at all times greater than the pump stuffing box
pressure, or
* connect the barrier fluid degassing reservoir by a closed-vent system to a control device, or
« equip with a system that purges the barrier fluid into a process stream with zero VHAP
emissions to the atmosphere

The barrier fluid system is not in VHAP service and, if covered under 40 CFR 60, is not in VOC
service
Equip each barrier fluid system with a sensor that will detect failure of seal system, barrier fluid
system, or both
» check each sensor daily or equip with audible alarm
• if at unmanned site, visually inspect as often as practicable and at least monthly
Determine criterion for sensor that indicates failure of the seal system, the barrier fluid system,
both
Determine criteria for presence and frequency of drips that indicate failure
Perform weekly visual inspections for indications of liquids dripping from the pump seal
• if indications of liquid, monitor with Method 21 to determine presence of VOC and VHAP
barrier fluid
Applies as an alternative standard to: Pumps in Light Liquid Service
Sensor
Presence of VHAP above background
10,000 ppm total VOC
Criteria
or

in





N/A
N/A
Visual, sensor, Method 21
First attempt within 5 calendar days of detection
Repair as soon as practicable; no later than 15 days after detection
                          DUAL MECHANICAL SEAL SYSTEM
                                                        page C-28

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                               DUAL MECHANICAL SEAL SYSTEM
                                           APPLICABLE REGULATIONS
      40 CFR Part 60,
        SubpartW
               40 CFR Part 61,
               Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpatt BE
      ITEM
                                     REQUIREMENTS
Delay of Repair
If repair requires use of a dual mechanical seal system that includes a barrier fluid system and repair
is completed as soon as practicable but no later than 6 months after leak detected

Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown

Allowed for equipment that is isolated from the process and that does not remain in VOC service
Recordkeeping
Requirements
When leak is detected:
  »  a weather-proof and readily visible identification, marked with the equipment ID number,
    attached to the leaking equipment
  •  ID may be removed after leak has been repaired

Information to be kept in log for 2 years after leak detected:
  •  instrument and operator ED numbers and equipment ID number
  •  date leak detected
  »  dates of each attempt to repair leak
  »  repair methods applied in each attempt to repair
  •  "above 10,000" if maximum instrument reading after each repair attempt is >. 10,000 ppm
  «  "repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection
  «  signature of owner/operator whose decision it was that repair could not be effected without a
    process shutdown
  •  expected date of successful repair if leak is not repaired within the 15 days
  •  dates of process unit shutdown that occurred while the equipment is unrepaired
  •  date of successful repair of the leak

Information to be kept for all dual mechanical seal systems:
  »  list of ID numbers of dual mechanical seal systems
  •  list of ID numbers designated for no detectable emissions and signed  by owner/operator
  »  for each compliance test for dual mechanical seal systems designated for no detectable emissions:
    • •  date conducted
    • •  background level  measured
    • *  maximum instrument reading
  «  list of ID numbers for  dual mechanical seal systems in vacuum service
  •  information and data used to demonstrate equipment is not in VHAP  service

Information to be kept for barrier fluid and seal systems:
  •  design criteria for indicating feilure
  •  explanation for selected criteria
  «  any changes to criteria and reasons for change

Information to be kept for use in determining exemptions:
  •  analysis demonstrating design capacity of the process unit
  •  analysis demonstrating that equipment is not in VHAP service
                                       DUAL MECHANICAL SEAL SYSTEM
                                                                                    page C-29

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                             DUAL MECHANICAL SEAL SYSTEM
                                        APPLICABLE REGULATIONS
      40 CFR Part 60,
        Sabpatt W
              40 CFR Part 61.
              Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CPR Part 265, Subpart BB
     HEM
                                   REQUIREMENTS
Reporting
Requirements
Initial report:
 *  process unit identification

Subsequent semiannual reports:
 »  process unit identification
 •  by month in the reporting period, the facts that explain each delay of repair, and where
    appropriate, why a process unit shutdown was technically infeasible
 •  dates of process unit shutdowns that occurred within the semiannual reporting period
 »  revisions to items reported in the initial report if changes have occurred since the initial report or
    subsequent revisions to the initial report
                                    DUAL MECHANICAL SEAL SYSTEM
                                                                                page C-30

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                         NO DETECTABLE EMISSIONS
                               APPLICABLE REGULATIONS
40 CFR Part 60,
  Subpart W
40 CFR Part 61,
Subparts J and V
40 CER Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265. Subpart BB
ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
REQUIREMENTS
Has an instrument reading of less than 500 ppm above background as measured by the methods
specified in 61.245(c)
Test compliance initially upon designation, annually, and as requested by the Administrator
Applies as basic standard for:
» closed vent systems
• pressure relief devices in gas/vapor service
Applies as an alternate standard to:
• pumps (must have no externally actuated shaft penetrating the pump housing)
• valves (must have no external actuating mechanism in contact with the process fluid)
• compressors
No detectable emissions (<500 ppm above background)
N/A
N/A
Method 21
N/A
N/A
                              NO DETECTABLE EMISSIONS
                                                                                   page C-31

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                         NO DETECTABLE EMISSIONS
                               APPLICABLE REGULATIONS
40CFRPait60,
  Subpart W
40CFRPart61,
Snbparts J and V
40CFRPart63,
Snbparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB
ITEM
Recordkeeping
Requirements


























Reporting
Requirements





REQUIREMENTS
When leak is detected:
« a weather-proof and readily visible identification, marked with the equipment ED number,
attached to the leaking equipment
• ID may be removed after leak has been repaired
Information to be kept in log for 2 years after leak detected:
« instrument and operator ID numbers and equipment ID number
• date leak detected
• dates of each attempt to repair leak
• repair methods applied in each attempt to repair
• "above 10,000" if maximum instrument reading after each repair attempt is J>. 10,000 ppm










« "repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection
• signature of owner/operator whose decision it was that repair could not be effected without
process shutdown
• expected date of successful repair if leak is not repaired within the 15 days
» dates of process unit shutdown that occurred while the equipment is unrepaired
« date of successful repair of the leak
Information to be kept for all:
• list of ID numbers of equipment designated for no detectable emissions and signed by
owner/operator
• for each compliance test for no detectable emissions:
• • date conducted
• • background level measured
• • maximum instrument reading
» list of IDs of equipment in vacuum service
• information and data used to demonstrate equipment is not in VHAP service
Information to be kept for use in determining exemptions:
• analysis demonstrating design capacity of the process unit
* analysis demonstrating that equipment is not in VHAP service
Semiannual reports:
« process unit ID
» dates of process unit shutdowns that occurred within the semi-annual reporting period
a



















« revisions to items reported in the initial report if changes have occurred since the initial report or
subsequent revisions to the initial report
• report of all performance tests and monitoring to determine compliance with no detectable
emissions



                              NO DETECTABLE EMISSIONS
                                                          page C-32

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                        OPEN-ENDED VALVES OR LINES
                                 APPLICABLE REGULATIONS
40 CFR Part 60,
  Subpart W
40CFRPart61,
Subparts J and V
40 CFR Part 63,
Subparts Hand I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB
ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
Recordkeeping
Requirements
REQUIREMENTS
Use cap, blind flange, plug, or second valve to seal open end at all times except when operations
require flow through open end
Second valve: close valve on process fluid end before closing second valve
Double block and bleed system: bleed valve or line may remain open during venting operations that
require venting the line between the block valves but comply with basic standard at all other times
N/A

Alternative means of emission limitation

Equipment in vacuum service
N/A
N/A
N/A
Information to be kept for all open-ended valves or lines:
• list of ID number of subject open-ended valves or lines
• information and data used to demonstrate equipment is not in VHAP service
Information to be kept for use in determining exemptions:
» analysis demonstrating design capacity of the process unit
* analysis demonstrating that equipment is not in VHAP service
                               OPEN-ENDED VALVES OR LINES
                                                              page C-33

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                               OPEN-ENDED VALVES OR LINES
                                       APPLICABLE REGULATIONS
     40CFRPart60,
       Subpart W
             40CERPart61,
             Siibparts J and V
40 CER Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CPR Part 265, Subpart BB
     HEM
                                  REQUIREMENTS
Reporting
Requirements
Initial report:
 •  equipment identification number
 «  process unit number
 «  type of equipment
 »  percent weight VHAP
 •  process fluid state
 »  method of compliance
 •  reporting schedule for submittal of subsequent semiannual reports
 »  statement notifying Administrator that subpart requirements are being implemented

Subsequent semiannual reports:
 *  process unit ED
 *  revisions to items reported in the initial report if changes have occurred since the initial report or
    subsequent revisions to the initial report
                                     OPEN-ENDED VALVES OR LINES
                                                                               page C-34

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           PRESSURE RELIEF DEVICES IN GAS/VAPOR SERVICE
                               APPLICABLE REGULATIONS
40CFRPart6Q,
  Subpart W
40CFRPart61,
Subparts J and V
40 CER Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CPR Part 265, Subpart BB
ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
REQUIREMENTS
No detectable emissions (less than 500 ppm above background)
After each release, return to no detectable emissions within 5 calendar days as indicated by
monitoring of the pressure relief device
No detectable emissions (<500 ppm above background)
N/A
Equipment in vacuum service
Any pressure relief device equipped with a compliant closed-vent system and
Closed-vent Systems and Control Devices)
control device (see
Method 21
Return to condition of "no detectable emissions" as soon as practicable but no
days after pressure release
later than 5 calendar
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in VHAP service
                     PRESSURE RELIEF DEVICES IN GAS/VAPOR SERVICE
                                                            page C-35

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                  PRESSURE RELIEF DEVICES IN GAS/VAPOR SERVICE
                                         APPLICABLE REGULATIONS
      40 CFR Part 60,
        SubpartW
              40 CFR Part 61,
              Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpan BB
     ITEM
                                    REQUIREMENTS
Recordkeeping
Requirements
Information to be kept for all pressure relief devices:
  •  list of ID numbers of subject pressure relief devices
  »  list of ED numbers of pressure relief devices for no detectable emissions and signed by
    owner/operator
  •  for each compliance test for pressure relief devices designated for no detectable emissions:
    • • date conducted
    • • background level measured
    • • maximum instrument reading
  •  list of ID numbers for pressure relief devices in vacuum service
  »  information and data used to demonstrate equipment is not in VHAP service

Information to be kept for pressure relief devices equipped with a closed-vent system and control
device:
  •  periods when the closed-vent system and control device is not operated as designed, including
    periods when a flare pilot light does not have a flame
  »  dates of start-up and shutdown of the closed-vent system and control device

Information to be kept for use in determining exemptions:
  «  analysis demonstrating design capacity of the process unit
  •  analysis demonstrating that equipment is not in VHAP service
Reporting
Requirements
Initial report:
  «  equipment identification number
  «  process unit number
  •  type of equipment
  «  percent weight VHAP
  •  process fluid state
  •  method of compliance
  «  reporting schedule for submittal of subsequent semiannual reports
  •  statement notifying Administrator that subpart requirements are being implemented

Subsequent semiannual reports:
  •  process unit identification
  •  the facts that explain each delay of repair, and where appropriate, why a process unit shutdown
    was technically infeasible
  •  dates of process unit shutdowns that occurred within the semiannual reporting period
  •  revisions to items reported in the initial report if changes have occurred since the initial report or
    subsequent revisions to the initial report
  »  report of all performance tests and monitoring to determine compliance with no detectable
    emissions
                              PRESSURE RELIEF DEVICES IN GAS/VAPOR SERVICE
                                                                                  page C-36

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                    PRESSURE RELIEF DEVICES IN LIQUID SERVICES,
                            FLANGES AND OTHER CONNECTORS
                                        APPLICABLE REGULATIONS
      40 CFR Part 60,
        SubpartVV
              40 CFR Part 61,
              Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB
     ITEM
                                    REQUIREMENTS
Basic Standard
 Monitoring of potential leaks within 5 calendar days of detection if evidence of potential leak is found
 by visual, auditory, olfactory, or other detection method
Leak Definition
 10,000 ppm
Alternative
Standards
 Alternative means of emission limitation
Exemptions
 Equipment in vacuum service
Monitoring
Method
 Method 21
Repair
Requirements
 First attempt within 5 calendar days of detection

 Repair as soon as practicable; no later than 15 days after detection
Delay of Repair
 Allowed if technically infeasible without process unit shutdown; required before end of next process
 unit shutdown

 Allowed for equipment that is isolated from the process and that does not remain in VHAP service.
Recordkeeping
Requirements
 When leak detected:
  « a weather-proof and readily visible identification, marked with the equipment ID number,
    attached to the leaking equipment
  * ID may be removed after it has been repaired

 Information to be kept in log for 2 years after leak detected:
  * instrument and operator ID numbers and equipment ID number
  » date leak detected
  • dates of each attempt to repair leak
  « repair methods applied in each attempt to repair
  « "above 10,000" if maximum instrument reading after each repair attempt is >, 10,000 ppm
  • "repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection
  « signature of owner/operator whose decision it was that repair could not be effected without a
    process shutdown
  • expected  date of successful repair if leak is not repaired within the 15 days
  « dates of process unit shutdown that occurred while the equipment is unrepaired
  » date of successful repair of the leak

	(Continued on next page)	
                              PRESSURE RELIEF DEVICES IN LIQUID SERVICES,
                                    FLANGES AND OTHER CONNECTORS
                                                                                 page C-37

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                   PRESSURE RELIEF DEVICES IN LIQUID SERVICES,
                         .  FLANGES AND OTHER CONNECTORS
                                        APPLICABLE REGULATIONS
      40 CfR Part 60,
       SabpanW
              40 CFR Part 61,
              Subpaits J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CPR Part 265, Subpart BB
     ITEM
                                   REQUIREMENTS
Recordkeeping
Requirements
(continued)
Information to be kept for all pressure relief devices, flanges and other connectors:
 •  list of ID numbers of subject pressure relief devices, flanges and other connectors
 •  list of ID numbers for equipment in vacuum service
 »  information and data used to demonstrate equipment is not in VHAP service

Information to be kept for use in determining exemptions:
 •  analysis demonstrating design capacity of the process unit
 »  analysis demonstrating that equipment is not in VHAP service
Repotting
Requirements
Initial report:
 •  equipment identification number
 »  process unit number
 •  type of equipment
 •  percent weight VHAP
 «  process fluid state
 «  method of compliance
 »  reporting schedule for submittal of subsequent semiannual reports
 »  statement notifying Administrator that subpart requirements are being implemented

Subsequent semiannual reports:
 »  process unit identification
 •  the facts that explain each delay of repair, and where appropriate, why a process unit shutdown
    was technically infeasible
 *  dates of process unit shutdowns that occurred within the semiannual reporting period
 •  revisions to items reported in the initial report if changes have occurred since the initial report or
    subsequent revisions to the initial report
                              PRESSURE RELIEF DEVICES IN LIQUID SERVICES,
                                   FLANGES AND OTHER CONNECTORS
                                                                              page C-38

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                      PRODUCT ACCUMULATOR VESSELS
                                 APPLICABLE REGULATIONS
40 CFR Part 60,
  Subpart VV
40 CFR Part 61,
Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Pan 265, Subpart BB
ITEM
Basic Standard
Leak Definition

Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
Recordkeeping
Requirements
REQUIREMENTS
Equip with a compliant closed-vent system and control device
N/A

Alternative means of emission limitation
Equipment in vacuum service
N/A
N/A
N/A
Information to be kept for all product accumulator vessels:
» list of ID numbers of subject product accumulator vessels
« list of HDD numbers for product accumulator vessels in vacuum service
» information and data used to demonstrate equipment is not in VHAP service
» periods when the closed-vent system and control device are not operated as designed, including
periods when a flare pilot light does not have a flame
« dates of startups and shutdowns of the closed-vent system and control device
Information to be kept for use in determining exemptions:
• analysis demonstrating design capacity of the process unit
« analysis demonstrating that equipment is not in VHAP service
                             PRODUCT ACCUMULATOR VESSELS
                                                              pageC-39

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                            PRODUCT ACCUMULATOR VESSELS
                                        APPLICABLE REGULATIONS
      40 CFR Part 60,
       SubpartW
              40 CFR Part 61,
              Subparts I and V
40CFRPait<53,
Snbparts H and I
40 CFR Pan 264, Subpart BB
40 CFR Part 265. Subpart BB
     ITEM
                                   REQUIREMENTS
Reporting
Requirements
Initial report:
 «  process unit identification
 •  equipment identification number
 *  type of equipment
 •  percent weight VHAP
 •  process fluid state
 •  method of compliance
 •  reporting schedule for submittal of subsequent semiannual reports
 »  statement notifying Administrator that subpart requirements are being implemented

Subsequent semiannual reports:
 »  process unit identification
 •  dates of process unit shutdowns that occurred within the semiannual reporting period
 •  revisions to items reported in the initial report if changes have occurred since the initial report or
    subsequent revisions to the initial report
                                    PRODUCT ACCUMULATOR VESSELS
                                                                               pageC-40

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                                     PUMPS IN VHAP SERVICE
                                         APPLICABLE REGULATIONS
      40 CFR Part 60,
        Subpart W
              40 CFR Part 61,
              Subpaits J and V
40 CFR Part 63,
Subpatts H and I
40 CFR Pan 264, Subpart BB
40 CFR Part 265. Snbpait BB
     ITEM
                                     REQUIREMENTS
Basic Standard
Monthly monitoring

Weekly visual observation for dripping liquids
Leak Definition
10,000 ppm

Indications of liquids dripping from pump seal
Alternative
Standards
Alternative means of emission limitation
Exemptions
Pumps designated for no detectable emissions (see No Detectable Emissions)

Pumps equipped with a compliant closed-vent system and control device (see Closed-vent Systems
and Control Devices)

Pumps equipped with a dual mechanical seal (see Dual Mechanical Seals)

Pumps in vacuum service

Any pump located at unmanned site is exempt from weekly visual inspections and daily sensor checks
provided each pump is visually inspected as often as practicable and at least monthly
Monitoring
Method
Method 21; no more than 1 cm from rotating shaft
Repair
Requirements
First attempt within 5 calendar days of detection

Repair as soon as practicable; no later than 15 days after detection
Delay of Repair
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown

Allowed for equipment that is isolated from the process and that does not remain in VHAP service

Allowed if repair requires use of a dual mechanical seal system that includes a barrier fluid system
and repair is completed as soon as practicable but not later than 6 months after leak was detected
                                           PUMPS IN VHAP SERVICE
                                                                                                       page C-41

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                                     PUMPS IN VHAP SERVICE
                                          APPLICABLE REGULATIONS
      40CFRPart60,
        Subpart W
               40CFRPait61,
               Snbparts J and V
40CFRPart63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB
     ITEM
                                     REQUIREMENTS
Recordkeepmg
Requirements
When leak detected:
  *  a weather-proof and readily visible identification, marked with the equipment ID number,
    attached to the leaking equipment
  «  ID may be removed after it has been repaired

Information to be kept in log for 2 years after leak detected:
  »  instrument and operator ID numbers and equipment ID number
  •  date leak detected
  »  dates of each attempt to repair leak
  «  repair methods applied in each attempt to repair
  «  "above 10,000" if maximum instrument reading after each repair attempt is >. 10,000 ppm
  »  "repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection
  *  signature of owner/operator whose decision it was that repair could not be effected without a
    process shutdown
  »  expected  date of successful repair if leak is not repaired within the 15 days
  «  dates of process unit shutdown that occurred while the equipment is unrepaired
  •  date of successful repair of the leak

Information to be kept for all pumps:
  •  list  of ID numbers of subject pumps
  »  list  of ID numbers of pumps designated for no detectable emissions and signed by
    owner/operator
  •  for  each compliance test for pumps designated for no detectable emissions:
    • •  date conducted
    • •  background level measured
    • •  maximum instrument reading
  »  list  of pumps in vacuum service
  •  information and data used to demonstrate equipment is not in VHAP service

Information to be kept for  barrier fluid and seal systems:
  •  design criteria for indicating failure
  •  explanation for selected criteria
  »  any changes to criteria and reasons for change

Information to be kept for  pumps equipped with a closed-vent system and control device:
  »  periods when the closed-vent system and control device is not operated as designed, including
    periods when a flare pilot light does not have a flame
  •  dates of start-up and shutdown of the closed-vent system and control device

Information to be kept for  use in determining exemptions:
  »  analysis demonstrating design capacity of the process unit
  «  analysis demonstrating that equipment is not  in VHAP service
                                          PUMPS IN VHAP SERVICE
                                                                                   page C-42

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                                     PUMPS IN VHAP SERVICE
                                         APPLICABLE REGULATIONS
      40CFRPart60,
        Subpart W
              40 CFR Pait61,
              Subtarts J and V
40 CER Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB
     ITEM
                                    REQUIREMENTS
Reporting
Requirements
Initial report:
  •  equipment identification number
  •  process unit number
  »  type of equipment
  •  percent weight VHAP
  •  process fluid state
  •  method of compliance
  •  reporting schedule for submittal of subsequent semiannual reports
  •  statement notifying Administrator that subpart requirements are being implemented

Subsequent semiannual reports:
  »  process unit identification
  »  the following information by month in the reporting period:
    • • number of pumps for which  leaks were detected
    • » number of pumps for which  leaks were not repaired within 15 days after detection
    • • the facts that explain each delay of repair, and where appropriate, why a process unit
        shutdown was technically infeasible
  »  dates of process unit shutdowns that occurred within the semiannual reporting period
  •  revisions to items reported in the initial report if changes have occurred since the initial report or
    subsequent revisions to the initial report
  »  report of all performance tests and monitoring to determine compliance with no detectable
    emissions.
                                          PUMPS IN VHAP SERVICE
                                                                                                     page C-43

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                     SAMPLING CONNECTION SYSTEMS
                              APPLICABLE REGULATIONS
40CFRPait60,
  SnbparcW
40CPRPart61,
Subpam I and V
40 CFR Part 63,
Snbpans H and I
40 CFR Part 264, Subpart BE
40 CFR Pan 265. Subpart BB
ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
Recordkeeping
Requkements
REQUIREMENTS
Equip with closed-purge system or closed-vent system that returns the fluid to the process line with
zero VHAP emissions to the atmosphere, recycles the purged fluid with zero VHAP emissions to the
atmosphere, or sends it to a compliant control device
N/A
Alternative means of emission limitation
Equipment in vacuum service
In-situ sampling systems
N/A
N/A
N/A
Information to be kept for all sampling connections:
» list of ID numbers of subject sampling connection systems
• periods when the closed- vent system and control device are not operated as designed,
periods when a flare pilot light does not have a flame
» dates of startups and shutdowns of the closed-vent system and control device
• list of ID numbers of equipment in vacuum service
* information and data used to demonstrate equipment is not in VHAP service
Information to be kept for use in determining exemptions:
• analysis demonstrating design capacity of the process unit
« analysis demonstrating that equipment is not in VHAP service
including
                           SAMPLING CONNECTION SYSTEMS
                                                          page C-44

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                             SAMPLING CONNECTION SYSTEMS
                                        APPLICABLE REGULATIONS
      40 CFR Part 60,
        SubpartW
              40 CFR Part 61,
              Subpans J and V
40 CFB. Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpait BB
     ITEM
                                   REQUIREMENTS
Reporting
Requirements
Initial report:
 •  process unit identification
 «  equipment identification number
 •  type of equipment
 •  percent weight VHAP
 •  process fluid state
 •  method of compliance
 •  reporting schedule for submittal of subsequent semiannual reports
 •  statement notifying Administrator that stibpart requirements are being implemented

Subsequent semiannual reports:
 •  process unit ID
 »  revisions to items reported in the initial report if changes have occurred since the initial report or
    subsequent revisions to the initial report
                                     SAMPLING CONNECTION SYSTEMS
                                                                                page C-45

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                          VALVES IN VHAP SERVICE
                               APPLICABLE REGULATIONS
40CFRPart60,
  Subpart W
40CFRPart61,
Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB
ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
REQUIREMENTS
Monthly monitoring
If valve does not leak for 2 months, may be monitored quarterly
If leak detected, monitor monthly until no leak is detected for 2 consecutive months
10,000 ppm


Alternative means of emission limitation
Allowable percentage of valves leaking: may elect to comply with s2% leaking valves
• notify Administrator before implementing
» conduct performance tests initially, annually, and as requested by Administrator
• • monitor within one week using Method 21
• • leak definition is 10,000 ppm
• • leak percentage cannot be greater than 2.0%
• notify Administrator if no longer complying with alternate standard
Skip period leak detection and repair:
» notify Administrator before implementing
• comply initially with basic standard
* if s2% leaking after 2 consecutive quarterly leak detection periods, may begin to skip 1 of the
quarterly monitoring periods
• after 5 consecutive periods with s2.Q% leaking, may begin to skip 3 of the quarterly periods
* if >2.0% leaking, comply with basic standard, but can again elect to use alternate standard
Valves in vacuum service
Valves designated for no detectable emissions (less than 500 ppm above background) (see
Detectable Emissions)
Valves designated unsafe to monitor or difficult to monitor
No
Method 21
First attempt within 5 calendar days of detection
Repair as soon as practicable; no later than 15 days after detection
                               VALVES IN VHAP SERVICE
                                                           page C-46

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                                    VALVES IN VHAP SERVICE
                                          APPLICABLE REGULATIONS
      40 CFR Part 60,
        SubpartW
               40 CFR Part 61,
               Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Snbpart BB
40 CFR Part 265, Subpart BB
     ITEM
                                     REQUIREMENTS
Delay of Repair
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown

Allowed for equipment that is isolated from the process and that does not remain in VHAP service

Allowed if emissions of purged material from immediate repair would exceed fugitive emissions from
delay of repair, and purged materials are collected and destroyed or recovered in a control device
when repair occurs

Allowed beyond process unit shutdown if otherwise sufficient supply of valve assembly replacements
are exhausted

Not allowed beyond next process unit shutdown unless next process unit shutdown occurs sooner than
6 months after first process unit shutdown
Recordkeeping
Requirements
When leak detected:
 •  a weather-proof and readily visible identification, marked with the equipment ID number,
    attached to the leaking equipment
 »  ID may be removed after it has been repaired and monitored for 2 months with no leaks

Information to be kept in log for 2 years after leak detected:
 *  instrument and operator ED numbers and equipment ID number
 «  date leak detected
 »  dates of each attempt to repair leak
 •  repair methods applied in each attempt to repair
 •  "above 10,000" if maximum instrument reading after each repair attempt is >  10,000 ppm
 •  "repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection
 •  signature of owner/operator whose decision it was that repair could not be effected without a
    process shutdown
 »  expected date of successful repair if leak is not repaired within the 15 days
 •  dates of process unit shutdown that occurred while the equipment  is unrepaired
 •  date of successful repair of the leak

Information to be kept for all valves:
 »  list of ID numbers of subject valves
 »  list of ID numbers of valves designated for no detectable emissions and signed by owner/operator
 »  for each compliance test for valves designated for no detectable emissions:
    * •  date conducted
    • •  background level  measured
    * •  maximum instrument reading
 «  list of ED numbers for  valves in vacuum service
 •  information and data used to demonstrate equipment is not in VHAP service

Information to be kept for unsafe or difficult to monitor valves:
 •  list of ID numbers
 «  explanation for designation
 «  planned schedule for monitoring
                                   (Continued on next page)
                                          VALVES IN VHAP SERVICE
                                                                                    page C-47

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                                    VALVES IN VHAP SERVICE
                                          APPLICABLE REGULATIONS
      40 CFR Part 60,
        SuhpartW
              40 CFR Part 61,
              Subparos J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpan BB
     HEM
                                    REQUIREMENTS
Rccordkeeping
Requirements,
continued
Information to be kept for valves complying with alternate standard - skip period leak detection and
repair:
  »  schedule of monitoring
  «  percent of valves found leaking during each monitoring period

Information to be kept for use in determining exemptions:
  *  analysis demonstrating design capacity of the process unit
  •  analysis demonstrating that equipment is not in VHAP service
Repotting
Requirements
Initial report:
  «  valve ID number
  •  process unit identification
  •  type of equipment
  •  percent weight VHAP
  »  process fluid state
  »  method of compliance
  •  reporting schedule for submittal of subsequent semiannual reports
  »  statement notifying Administrator that subpart requirements are being implemented

Subsequent semiannual reports:
  »  process unit identification
  »  the following information by month in the reporting period:
    • • number of valves for which leaks were detected
    • • number of valves for which leaks were not repaired within 15 days after detection
    • * the facts that explain each delay of repair, and where appropriate, why a process unit
        shutdown was technically infeasible
  »  dates of process unit shutdowns that occurred within the semiannual reporting period
  »  revisions to items reported in the initial report if changes have occurred since the initial report or
    subsequent revisions to the initial report
  «  report of all performance tests in accordance with no detectable emissions
                                          VALVES m VHAP SERVICE
                                                                                   page C-48

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          AGITATORS IN GAS/VAPOR SERVICE OR LIGHT LIQUID SERVICE
                                          APPLICABLE REGULATIONS
40CFRPart60,
Subpart W

40 CFR Part 61,
Subparts J and V

                                                              40 CFR Part 63,
                                                              Subparts H and I
                                                                  40 CFR Part 264, Subpart BB
                                                                  40 CFR Part 265, Subpart BB
     ITEM
                                     REQUIREMENTS
Basic Standard
"Non-dual mechanical seal" agitators:
 «  monthly monitoring and weekly visual check for indications of dripping liquid
 »  if at unmanned site, visually inspect as often as practicable and at least monthly
Leak Definition
Monitoring:  10,000 ppm

Visual:  indications of liquids dripping from agitator
Alternative
Standards
Enclosed-vented process units: may enclose process units and operate under negative pressure while
venting all leaks from equipment through a closed-vent system to a control device meeting the
requirements of this rule.

Batch processes: may pressure test or monitor equipment for leaks
Exemptions
Dual mechanical seal agitators (see Dual Mechanical Seal Systems)

Agitators designed with no externally actuated shaft penetrating the agitator housing

Agitators equipped with closed-vent system and control device (see Closed-vent Systems and Control
Devices)

Agitators located at unmanned plant site are exempt from weekly visual inspection and daily sensor
check if visually inspected as often as practical and at least monthly

Difficult to monitor agitators exempt if:
  •  agitator cannot be monitored without elevating personnel more than 2 meters above a support
    surface or if it is not accessible at any time in a safe  manner,
  »  process unit where agitator is located is an existing source or  <3% of total number of agitators
    in a new source are designated difficult to monitor, and
  •  written plan requires monitoring at least once per calendar year

Unsafe to monitor agitators are exempt if:
  •  monitoring personnel would be exposed to an immediate danger, and
  •  written plan requires monitoring as frequently as practical during safe to monitor times, but not
    more frequently than monitoring schedule

Agitators obstructed by equipment or piping that prevents access by a monitor probe

Equipment in vacuum service

Equipment operated fewer than 300 hours per year in organic HAP service
Monitoring
Method
Method 21; no more than 1 cm from rotating shaft
  •  response factor criteria (excluding inerts) for average composition of process fluid
  •  monitor all equipment while it is "in service"
                         AGITATORS IN GAS/VAPOR SERVICE OR LIGHT LIQUID SERVICE
                                                                                    page C-49

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         AGITATORS IN GAS/VAPOR SERVICE OR LIGHT LIQUID SERVICE
                                      APPLICABLE REGULATIONS
     •WCPRPartfiO,
       Subpart W
             40 CFR Part 61,
             Subpaits J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CPR Pan 265, Subpart BB
     ITEM
                                 REQUIREMENTS
Repair
Requirements
First attempt within 5 calendar days of detection

Repair as soon as practicable; no later than 15 days after detection
Delay of Repair
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown

Allowed for equipment that is isolated from the process and that does not remain in organic HAP
service

Allowed if emissions of purged material from immediate repair would exceed fugitive emissions from
delay of repair, and purged materials are collected and destroyed or recovered in a control device
when repair occurs
                      AGITATORS IN GAS/VAPOR SERVICE OR LIGHT LIQUID SERVICE
                                                                           page C-50

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          AGITATORS IN GAS/VAPOR SERVICE OR LIGHT LIQUID SERVICE
                                          APPLICABLE REGULATIONS
      40 CFR Part 60,
        Subpart W
              40 CFR Part 61,
              Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Snbpart BB
40 CFR Part 265, Subpart BB
     ITEM
                                     REQUIREMENTS
Recordkeeping
Requirements
When leak detected:
 •  a weather-proof and readily visible identification, marked with the equipment ED number,
    attached to the leaking equipment
 »  ID may be removed after it has been repaired

Information to be kept in log for 2 years after leak detected:
 «  instrument and equipment ID number and operator name, initials, or ID number
 •  date leak detected
 •  date of first attempt to repair leak
 «  maximum instrument reading after successful repair or determination the equipment is
    nonrepairable
 »  "repair delayed" and reason for delay if leak not repaired within  15 calendar days after detection.
    The owner or operator may develop and cite a written procedure that identifies conditions
    justifying a delay of repair
 »  documentation of sufficient supply of spare parts on-site before depletion and reason for
    depletion if repair delayed because stocked parts were depleted
 •  copies of periodic reports (if database not capable of generating)
 •  dates of process unit shutdown that occurred while the equipment is unrepaired
 •  date of successful repair of the leak

Information to be kept for  all agitators:
 •  list of ED numbers of subject equipment
 •  location of equipment  on site plan, log  entries, etc.
 *  list of ID numbers of equipment equipped with closed-vent system and control device
 «  documentation and dates of visual  inspections

Information to be kept for  agitators with dual mechanical seal system:
 •  design criteria for indicating failure
 •  explanation for selected criteria
 •  any changes to criteria and reasons for changes

Information to be kept for  unsafe to monitor agitators:
 *  identification of equipment designated as unsafe to monitor
 •  plan for monitoring

Information to be kept for  difficult to monitor agitators:
 »  list of ID numbers for equipment designated as difficult to monitor
 •  explanation of designation
 »  planned schedule for monitoring

Information and data used  to demonstrate that equipment is not in organic HAP service, is in HAP
service fewer than 300 hours/year, or is in  heavy liquid service
                         AGITATORS IN GAS/VAPOR SERVICE OR LIGHT LIQUID SERVICE
                                                                                   page C-51

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          AGITATORS IN GAS/VAPOR SERVICE OR LIGHT LIQUID SERVICE
                                        APPLICABLE REGULATIONS
      40 CFR Part 60,
        Subpart W
              40 CFR Part 61,
              Subpans J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Snbpart BB
     ITEM
                                   REQUIREMENTS
Reporting
Requirements
Initial notification:
  •  name and address of owner/operator
  •  address of facility
  •  identification of subject processes
  •  compliance statement
  «  statement if a source can achieve compliance by applicable date

Notification of compliance status:
  •  process unit identification
  •  number of agitators (excluding those in vacuum service)
  •  method of compliance

Subsequent semiannual reports:
  •  the following information for each monitoring period during the 6-month reporting period:
    • *  number of agitators for which leaks were detected
    • •  number of agitators for which leaks were not repaired as required
    • •  the facts that explain each delay of repair, and where appropriate, why a process unit
        shutdown was technically infeasible
  •  revisions to items reported in the notification of compliance status if method of compliance has
    changed since the last report
  •  information listed under notification of compliance status for process units witn later compliance
    dates
                        AGITATORS IN GAS/VAPOR SERVICE OR LIGHT LIQUID SERVICE
                                                                               page C-52

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                   ALTERNATIVE MEANS OF EMISSION LIMITATION:
                            ENCLOSED-VENTED PROCESS UNITS
                                       APPLICABLE REGULATIONS
      40 CFR Part 60,
       Subpatt W
              40 CFR Part 61,
              Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265. Subpart BB
     ITEM
                                  REQUIREMENTS
Basic Standard
Process units enclosed in such a manner that all emissions from equipment leaks are vented through a
closed-vent system to a control device. The enclosures shall be maintained under negative pressure at
all times the process unit is in operation
Recordkeeping
Requirements
Owner/operators shall maintain the following records:
 •  ID numbers of the process units and the organic HAPs they handle
 «  a schematic of the process unit, enclosure, and closed vent system
 «  a description of the system used to create a negative pressure in the enclosure to ensure that all
    emissions are routed to the control device
Reporting
Requirements
Information for each process unit:
 «  process unit identification
 »  description of the system used to create a negative pressure in the enclosure and the control
    device used
                              ALTERNATIVE MEANS OF EMISSION LIMITATION:
                                    ENCLOSED-VENTED PROCESS UNITS
                                                                              page C-53

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           ALTERNATIVE MEANS OF EMISSION LIMITATION:
                           BATCH PROCESSES
                            APPLICABLE PECULATIONS
lOCFRParteO,
 SubpartW
40CFRPart61,
Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpan BB
40 CFR Part 265, Subpart BB
ITEM
Basic Standard
(Alternative)
Monitoring
Options
REQUIREMENTS
1) Batch pressure test or
2) Meet standards for continuous processes with changes to monitoring
1) Batch pressure testing:
• test batch process equipment using either:
• • procedures specified for pressure or vacuum loss [see §63.180(f)] or
• « with a liquid using procedures specified in §63. 180(g)
• each time equipment is reconfigured for production of a different product or intermediate, the
batch product-process equipment train shall be pressure tested for leaks before organic HAP is
first fed to the equipment and the equipment is placed in organic HAP service
« when the batch product-process train is reconfigured to produce a different product, pressure
testing is required only for the new or disturbed equipment
« each batch process that operates in organic HAP service during a calendar year must be pressure
tested at least once during that calendar year
• pressure testing is not required for routine seal breaks, such as changing hoses or filters, which
are not part of the reconfiguration to product a different product or intermediate
» for pressure tests using a gas or a vacuum, a leak is found if the rate of pressure change exceeds
1 psig in 1 hour or if there is visible, audible, or olfactory evidence of fluid loss
• for pressure tests using a liquid, a leak is defined as dripping liquid or other evidence of fluid
loss from process units
2) Continuous process monitoring method:
« monitor for leaks when the equipment is in organic HAP service, in use with an acceptable
surrogate volatile organic compound which is not an organic HAP, or in use with any other
detectable gas or vapor
• each time the equipment is reconfigured for the production of a new product, the reconfigured
equipment shall be monitored for leaks within 30 days of start-up of the process; this initial
monitoring of reconfigured equipment shall not be included in determining percent leaking
equipment in the process unit.
• connectors are to be monitored in accordance with §63. 174
» monitor equipment other dian connectors at the frequencies specified in the following schedule:
EQUIPMENT MONITORING FREQUENCIES (odier than connectors)
i
1 Time in Use (% of year) Equivalent Continuous Process Monitoring Frequency
i Monthly Quarterly Semiannually
I Oto <25 quarterly annually annually
• 25 to < 50 quarterly semiannually annually
i
• 50 to <75 bimonthly three times/year semiannually
75 to 100 monthly . quarterly semiannually

                   ALTERNATIVE MEANS OF EMISSION LIMITATION:
                              BATCH PROCESSES
                                                    page C-54

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ALTERNATIVE MEANS OF EMISSION LIMITATION:
               BATCH PROCESSES

               APPLICABLE REGULATIONS
40CFRPart6Q, 40CFRPart61,
Subpart W Subparts J and V


ITEM
Repair
Requirements
Delay of Repair
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB


REQUIREMENTS
Batch:
• when leaks are detected, repairs must be made and a retest conducted before startup of the
process
« If the process unit fails this retest or the second of 2 consecutive pressure tests, the equipment
must be repaired as soon as practicable but not later than 30 calendar days after second pressure
test
Continuous:
• If a leak is detected, it shall be repaired as soon as practicable but not later than 15 calendar days
after it is detected
Allowed if the replacement equipment is not available, providing the following conditions are met:
* equipment supplies have been depleted and supplies had been sufficiently stocked before the
supplies were depleted
» the repair is made no later than 10 calendar days after delivery of the replacement equipment
        ALTERNATIVE MEANS OF EMISSION LIMITATION:
                  BATCH PROCESSES
page C-55

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                    ALTERNATIVE MEANS OF EMISSION LIMITATION:
                                        BATCH PROCESSES
                                         APPLICABLE REGULATIONS
40 CFR Part 60,
Subpart W

40 CFR Part 61,
Subpatts J and V

                                                             40 CFR Part 63,
                                                             Subpaits H and I
                                                                40 CFR Part 264, Subpart BB
                                                                40 CFR. Part 265, Subpart BB
     ITEM
                                    REQUIREMENTS
Recordkeeping
For each component, all other elements of the rule (leak definition, records, reports, etc.) apply the
same as for continuous processes

Identity equipment on a plant site plan, in log entries, or by other appropriate methods

List of equipment added since last monitoring period

Documentation of any switch from batch process monitoring to pressure testing or vice versa

Record that inspection was performed if no leaks are found

Records of any visible, audible, or olfactory evidence of fluid loss

Batch pressure testing:
  •  batch products or product codes for equipment subject to this monitoring option
  «  identification of each product or product code produced during the calendar year; it is not
    necessary to identify individual items of equipment in a batch product process equipment train
  «  records demonstrating the proportion of the time during the calendar year the equipment is in use
    in  a batch process; examples of suitable documentation are records of time in use for individual
    pieces of equipment or average time in use for the process unit
  •  the dates of each pressure test, the test pressure, and the pressure drop observed during the test

When a batch product process equipment train does not pass two consecutive pressure tests, the
following information shall be recorded in a log and kept for 2 years:
  •  the date of each pressure test and the date of each leak repair attempt
  «  repair methods applied in each attempt to repair the leak
  •  the reason for the delay of repair
  »  the expected date for delivery of the replacement equipment and the actual date of delivery of the
    replacement equipment
  •  the date of successful repair

Continuous process monitoring:
  •  records demonstrating the proportion of the time during the calendar year the equipment is in use
    in a batch process; examples of suitable documentation are records of time in use for individual
    pieces of equipment or average time in use for the process unit; these records are not required if
    the owner or operator does not adjust monitoring frequency by the time in use
  •  date and results of monitoring for equipment added to the batch process unit since the last
    monitoring period.
                               ALTERNATIVE MEANS OF EMISSION LIMITATION:
                                             BATCH PROCESSES
                                                                                  page C-56

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                  ALTERNATIVE MEANS OF EMISSION LIMITATION:
                                      BATCH PROCESSES
                                       APPLICABLE REGULATIONS
     40CFRPart60,
       SubpartW
             40 CFR Part 61,
             Subparts J and V
40 CFR Part 63,
Snbparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB
     ITEM
                                  REQUIREMENTS
Reporting
Notification of compliance status:
 »  batch products or product codes designated for pressure testing sad
 •  a planned schedule for pressure testing when equipment is configured for production of products
    subject to provisions of subpart.

Periodic reports:
 *  batch product process equipment train identification
 •  the number of pressure tests conducted
 •  the number of pressure tests where the equipment train failed the pressure test
 »  the facts that explain any delay of repairs
 *  the results of all monitoring to determine compliance of closed-vent systems
                             ALTERNATIVE MEANS OF EMISSION LIMITATION:
                                          BATCH PROCESSES
                                                                             page C-57

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           CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                            APPLICABLE REGULATIONS
40CFRP»rt60,
  SabpartW
40CFRPart61,
Subparts J and V
40 CFR Part 63,
Subpaits H and I
40 CFR Part 264, Subpart BB
40 CPR Part 265, Subpart BB
ITEM
Basic Standard
Leak Definition
Alternative
Standard
REQUIREMENTS
Control devices and closed-vent systems: operate whenever HAP emissions may be vented to them
Control devices subject to 40 CFR 63 subpart H and 40 CFR 264 subpart BB or 40 CFR 265 subpart
BB may comply with the monitoring, recordkeeping and reporting requirements of subpart H or of
parts 264 and/or 265.
Recovery or Recapture Devices:
Vapor recovery systems: 95 percent or greater recovery or an exit concentration of 20 ppmv,
whichever is less stringent
Enclosed combustion devices: 95% or more reduction, or 20 ppmv on any basis, corrected to
3% O2, whichever is less stringent, or minimum residence time/temp: 0.50 sec. & 760° C
Flares: Comply with §63.1 l(b)
Closed-Vent Systems:
Initial and annual inspection requirements:
• hard pipe construction: initial inspection per Method 21, annual visual inspections for
visual, olfactory or audible leaks
• duct work construction: initial and annual inspections per Method 21
No detectable emissions (< 500 ppm above background)
Visual inspections
Alternative means of emission limitation
                    CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                                                      page C-58

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                    CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                                          APPLICABLE REGULATIONS
      40CFRPart60,
        SubpartW
              40CFRPa«61,
              Subparts J and V
40CFRPart63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB
     ITEM
                                    REQUIREMENTS
Exemptions
Equipment in vacuum service

Equipment in organic HAP service fewer than 300 hours per year

Equipment such as low leg drains, high point bleeds, analyzer vents, open-ended valves or lines, and
pressure relief valves needed for safety purposes exempt from monitoring requirements

"Unsafe to inspect" parts are exempt from §63.180(b) inspections if:
  «  inspecting personnel would be exposed to an imminent or potential danger, and
  »  the owner or operator has a, written plan requiring inspection during safe to inspect times as
    frequently as practicable but not more than once per year

"Difficult to inspect" parts are exempt from §63.180(b) inspections if:
  •  the equipment cannot be inspected without elevating the inspecting personnel more than 2 meters
    above a support surface, and
  •  the owner or operator has a written plan requiring inspection of the equipment at least once every
    5 years
Monitoring
Method
Monitor control devices to ensure operated & maintained in conformance with design specifications

By-pass lines:
  •  install, set or adjust and maintain vent stream flow indicator installed at entrance to any bypass
    line or
  »  secure valve in non-diverting position with car-seal or lock-and-key type locks with monthly
    visual inspection

Method 21:
  •  response factor criteria (excluding inerts) for average composition of process fluid
  «  monitor all equipment while it is "in service"
Repair
Requirements
First attempt within 5 calendar days of detection

Repair as soon as practicable; no later than 15 days after detection
Delay of Repair
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown

Allowed if emissions of purged material from immediate repair would exceed fugitive emissions from
delay of repair; required before end of next process unit shutdown

Allowed for equipment that is isolated from the process and that does not remain in organic HAP
service.
                                CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                                                                                   page C-59

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                    CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                                         APPLICABLE REGULATIONS
40CFRPart60,
SabpartW

40 CFR Part fil,
Subparts J and V

                                                             40 CFR Part 63,
                                                             Subparts H and I
                                                                 40 CFR Part 264, Subpart BB
                                                                 40 CFR Part 265. SubpartBB
     ITEM
                                    REQUIREMENTS
Recordkeeping
Requirements
When leak detected:
  «  a weather-proof and readily visible identification, marked with the equipment ID number,
    attached to the leaking equipment
  «  ID may be removed after equipment has been repaired

Information to be kept in log for 2 years after leak detected:
  »  instrument and equipment ID number and operator name, initials, and ID number
  •  date leak detected
  «  date of first attempt to repair leak
  •  maximum instrument reading after successful repair or if determined to be nonrepairable
  •  "repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection.
    The owner or operator may develop and cite a written procedure that identifies conditions
    justifying a delay of repair
  «  documentation of sufficient supply of spare parts on-site before depletion and reason for
    depletion if repair delayed because stocked parts were depleted
  «  copies of periodic reports (if database not capable of generating)
  *  dates of process unit shutdown that occurred while the equipment is unrepaired
  »  date of successful repair of the leak

Information to be kept for all closed-vent systems and control devices:
  «  list of ID numbers of subject equipment
  •  location of equipment on  site plan, log entries, etc.
  «  list of ID numbers for components equipped with closed-vent system and control device
  •  ID of surge control vessels and bottoms receivers equipped with closed-vent system and control
    device
  *  documentation of visual inspections
  •  design specifications (retain for life of equipment)
    • •  design specifications and performance demonstrations to include detailed schematics and
        piping and instrumentation diagrams
    • •  dates and descriptions of any changes in the design specifications
    » •  flare design and results of compliance demonstration
    • •  description and explanation of control device monitoring parameters
  »  records of operation (retain for 2 years)
    • •  dates and durations when closed-vent system and control device is not operated as designed
        (includes lack of flame in flare pilot light) and when monitoring systems/devices are
        nonoperative
    * •  dates and durations of start-ups and shutdowns of control devices
  «  records of inspections (retain for 2 years)
    • •  if no leaks detected:  record date and fact of inspection and statement no leaks detected
    « •  if leaks detected:  information specified previously

Information and data used to demonstrate that a closed-vent system and control device is not in
organic HAP service or is in HAP service fewer than 300 hours/year
                               CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                                                                                   page C-60

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                   CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                                        APPLICABLE REGULATIONS
      40CFRPaxt60,
       SubpartW
              40 CFR Part 61;
              Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Sabpart BB
     ITEM
                                   REQUIREMENTS
Reporting
Requirements
Initial notification:
 *  name and address of owner/operator
 •  address of facility
 »  identification of subject processes
 •  compliance statement
 *  statement if a source can achieve compliance by applicable date

Notification of compliance status:
 »  process unit identification
 »  number of closed-vent system and control device, excluding those in vacuum service
 •  method of compliance

Subsequent semiannual reports:
 •  the facts that  explain any delay of repairs
 *  the results of all monitoring of closed-vent systems or of control devices
 »  revisions to items reported in the initial compliance notice if method of compliance has changed
    since the last  report
 «  if applicable,  the compliance option selected for closed-vent systems and control devices
                              CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                                                                                page C-61

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                                   COMPRESSORS
                                APPLICABLE REGULATIONS
40 CFR Part 60,
  Subptrt W
40 CFR Part 61,
Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subparr BB
40 CPE Part 265, Subpart BB
ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
REQUIREMENTS
Equip with compliant seal system that includes a barrier fluid system that prevents leakage to
atmosphere
For each compressor seal system:
• operate the barrier fluid at a pressure that is at all times greater than the pump stuffing box
pressure, or
• equip with a barrier fluid degassing reservoir that is routed to a process or fuel gas system or
connected by a closed-vent system to a control device, or
« equip with a closed-loop system that purges the barrier fluid into a process stream
The barrier fluid system is not in light liquid service
Install sensor to detect failure of seal system, barrier fluid system, or both
Check sensor daily or equip with audible alarm, unless at an unmanned plant site
Establish criteria that indicates failure of seal system or barrier fluid system or both
Sensor indicates failure of seal or barrier fluid system or both based on established criteria
Alternative means of emission limitation
Enclosed-vented process units: may enclose process units and operate under negative pressure while
venting all leaks from equipment through a closed-vent system to a control device meeting the
requirements of the rule
Batch processes: may pressure test or monitor equipment for leaks
Compressors designated to operate with instrument reading of less than 500 ppm above background
(see No Detectable Emissions)
Compressors equipped with closed-vent system; returns to a process, fuel gas system or compliant
control device (see Closed-vent Systems and Control Devices)
Compressors in vacuum service
Compressors operated fewer than 300 hours per year in organic HAP services
Daily observation of sensors or use of sensor alarm system
First attempt within 5 calendar days of detection
Repair as soon as practicable; no later than 15 calendar days after detection
                                      COMPRESSORS
                                                             page C-62

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                                             COMPRESSORS
                                           APPLICABLE REGULATIONS
      40 CFR Part 60,
        SabpartW
               40CFRPart61,
               Subparts J and V
40 CFR Part 63,
Subpaits H and I
40 CFR Part 264, Subpart BE
40 CFR Part 265, Subpart BB
      ITEM
                                     REQUIREMENTS
Delay of Repair
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown

Allowed for equipment that is isolated from the process and that does not remain in organic HAP
service
Recordkeeping
Requirements
When leak detected:
  *  a weather-proof and readily visible identification, marked with the equipment ID number,
    attached to the leaking equipment
  *  ID may be removed after it has been repaired

Information to be kept in log for 2 years after leak detected:
  »  instrument and equipment ID number and operator name, initials, or ID number
  •  date leak detected
  •  date of first attempt to repair leak
  •  maximum instrument reading after successful repair or determination to be nonrepairable
  »  "repak delayed"  and reason for delay if leak not repaired within 15 calendar days after detection.
    The owner or operator may develop and cite a written procedure that identifies conditions
    justifying a delay of repair
  «  documentation of sufficient supply of spare parts on-site before depletion and "reason for
    depletion if repair delayed because stocked parts were depleted
  •  dates of process unit shutdowns that occurred while the equipment is unrepaired
  »  date of successful repair of the leak

Information to be kept for all compressors:
  •  list of ID numbers of subject  compressors
  •  location of compressor on site plan, log entries, etc.
  »  list of ID numbers of compressors equipped with closed-vent system and control device
  «  list of ID numbers of compressors designated to operate at less than 500 ppm above background
  «  documentation and dates of visual inspections
  »  for each  compliance test for compressors designated to operate at less than 500 ppm above
    background:
    • •  date conducted and results of test
    « •  background level measured
    • •  maximum instrument reading
  »  copies of periodic reports (if database not capable of generating)

Information to be kept for barrier fluid and  seal systems:
  »  design criteria for indicating failure
  •  explanation for selected criteria
  «  any changes to criteria and reasons for change

Information and data  used to demonstrate that a compressor is not in organic HAP service or is in
HAP service  fewer than 300 hours/year
                                                 COMPRESSORS
                                                                                     page C-63

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                                            COMPRESSORS
                                          APPLICABLE REGULATIONS
      40GFRP«t60,
        Subpart W
              40 CFR Part 61,
              Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB
     ITEM
                                    REQUIREMENTS
Reporting
Requirements
Initial notification:
  •  name and address of owner/operator
  »  address of facility
  »  identification of subject processes
  •  compliance statement
  «  statement if a source can achieve compliance by applicable date

Notification of compliance status:
  •  process unit identification
  »  number of compressors (excluding those in vacuum service)
  *  method of compliance

Subsequent semiannual reports:
  *  the following information for each monitoring period during the 6-month period:
    » •  number of compressors for which leaks were detected
    » •  number of compressors for which leaks were not repaired as required
    • •  the facts that explain each delay of repair, and  where appropriate, why a process unit
        shutdown was technically infeasible
  »  results of monitoring for compressors designated to operate at less than 500 ppm
  •  revisions to items reported in the notification of compliance status if method of compliance has
    changed since the last report
  «  information listed under Notification of Compliance for process units with later compliance dates
                                               COMPRESSORS
                                                                                   page C-64

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              CONNECTORS IN GAS/VAPOR AND LIGHT LIQUID SERVICE
                                         APPLICABLE REGULATIONS
40 CER Part 60,
SubpartW

40 CFR Part 61 s
Snbparts J and V

                                                             40CFRPart63,
                                                             Subparts H and I
                                                                 40 CFR Part 264, Subpart BB
                                                                 40 CFR Part 265, Subpart BB
     ITEM
                                    REQUIREMENTS
Basic Standard
Initial survey:
  «  Monitor all connectors within first 12 months after initial start-up (new sources)
  *  Monitor all connectors no later than 12 months after compliance date (existing)

Subsequent monitoring frequency based on percent leaking:
  »  Annual: if aO.5% during last annual or biennial period
  »  Once every 2 years: if <0.5%  during last monitoring period (monitor at least 40% of connectors
    in first year and remainder in second year)
  *  Once every 4 years: if <0.5%  during 2 year monitoring period (monitor at least 20% per year
    until all are monitored within 4 years)
  »  Once every 2 years:  0.5 to <1% during 4 year monitoring period (monitor at least 40% of
    connectors first year and remainder in second year)
  •  Annual: if > 1 % during  4 year monitoring period

For any connector that has been opened or otherwise has had its seal broken, monitor when
reconnected or within first 3  months of being returned to HAP service.

If leak is detected and it cannot be repaired, then the connector should be counted as nonrepairable
for purposes of determining monitoring frequency. If the owner or operator chooses not to monitor
connectors that have been opened or otherwise had the seal broken, then he cannot count
nonrepairable connectors for the purposes of determining monitoring frequency. The owner or
operator will instead set the nonrepairable component of the  monitoring frequency equation to zero
for all monitoring periods.

A switch in alternatives requires initial monitoring no later than 12 months after reporting the switch.
Leak Definition
500 ppm (except for inaccessible, ceramic, or ceramic-lined connectors)
Alternative
Standards
Alternative means of emission limitation

Alternative requirements allowed for screwed connectors less than 2 inches in nominal inside
diameter; may comply with 63.169 and monitor within first 3 months of return to organic HAP
service after being opened or having seal otherwise broken

Alternative requirements for connectors that have had the seal broken or otherwise been opened (see
Basic Standard above)
                           CONNECTORS IN GAS/VAPOR AND LIGHT LIQUID SERVICE
                                                                                   page C-65

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              CONNECTORS IN GAS/VAPOR AND LIGHT LIQUID SERVICE
                                         APPLICABLE REGULATIONS
      40CERPart60,
        Sabpart W
              40 CFR Part 61,
              Subpans J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, SubpartBB
     ITEM
                                    REQUIREMENTS
Exemptions
Connectors in vacuum service

Connectors in organic HAP service fewer than 300 hours per year

"Unsafe-to-monitor" connectors:  monitor as frequently as practicable during safe to monitor periods,
but no more frequently than the periodic schedule otherwise applicable

"Unsafe-to-repair" connectors: repair by end of the next scheduled process unit shutdown

"Inaccessible" or "ceramic" or "ceramic-lined" connectors: repair any leak observed by visual,
audible, olfactory or other means
Monitoring
Method
Method 21
  •  response factor criteria (excluding inerts) for average composition of process fluid
  «  monitor all equipment while it is "in service"
Repair
Requirements
First attempt within 5 calendar days of detection

Repair as soon as practicable; no later than 15 days after detection

When repaired, monitor at least once within first 3 months of repair
Delay of Repair
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown

Allowed if emissions of purged materials from immediate repair would exceed fugitive emissions
from delay of repair, and purged materials are collected and destroyed or recovered in a control
device when repair occurs

Allowed for equipment that is isolated from the process and that does not remain in organic HAP
service
Calculation of
Percent Leaking
For the first monitoring period:
 *  percent leaking connectors = [number of connectors measured at 500 ppm or greater / (total
    number of measured connectors in the process unit + optional credit for removed connectors)] *
    100

For subsequent monitoring periods:
 «  percent leaking connectors =[ (number of connectors measured at 500 ppm or greater - number
    of allowable nonrepairable connectors) / (total number of monitored connectors in the process
    unit + optional credit for removed connectors)] * 100
                           CONNECTORS IN GAS/VAPOR AND LIGHT LIQUID SERVICE
                                                                                 pageC-66

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              CONNECTORS IN GAS/VAPOR AND LIGHT LIQUID SERVICE
                                          APPLICABLE REGULATIONS
      40 CFR Pan 60,
        SubpartW
               40 CFR Part 61,
               Subpans J and V
40 CFR Part 63,
Subpaits H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB
     ITEM
                                     REQUIREMENTS
Optional Credit
for Removed
Connectors
Credit may be given for eliminating connectors if the following requirements are met:
 •  connector was welded after the date of proposal of the specific subpart that references this
    subpart
 *  integrity of the weld is demonstrated by monitoring it according to the procedures in 63.180(b)
    or by testing using X-ray, acoustic monitoring, hydrotesting, or other applicable method
 *  welds created after the date of proposal but before the date of promulgation of a specific subpart
    that references this subpart are monitored or tested by 3 months after the compliance date
    specified in the applicable subpart, and
 *  welds created after promulgation of the subpart that references this subpart are monitored or
    tested within 3 months after being welded

If an inadequate weld is found or the connector is not welded completely around the circumference,
the connector is not considered a welded connector and is therefore not exempt.

In percent leaking connectors equations, optional credit for removed connectors is calculated:
0.67 * net (total removed - total added) number of connectors in organic HAP service that are
removed from the process unit after compliance date for existing units and after initial start-up for
new units. If credits are not taken, the credit = 0
                            CONNECTORS IN GAS/VAPOR AND LIGHT LIQUID SERVICE
                                                                                   page C-67

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              CONNECTORS IN GAS/VAPOR AND LIGHT LIQUID SERVICE
                                         APPLICABLE REGULATIONS
40CFRPait60,
Subpart W

40CERPart61,
Subpatts J and V

                                                             40 CFR Part 63,
                                                             Sufcparts H and I
                                                                 40 CFR Part 264, Subpart BB
                                                                 40 CFR Part 265, Subpart BB
     ITEM
                                    REQUIREMENTS
Recordfceeping
Requirements
When leak detected:
  • a weather-proof and readily visible identification, marked with the equipment ID number,
    attached to the leaking equipment
  • ID may be removed after it has been repaired and monitored when reconnected or within first 3
    months of repair and no leak is detected

Information to be kept in log for 2 years after leak detected:
  • instrument and equipment ED number and operator name, initials, or ID number
  • date leak detected
  • date of first attempt to repair leak
  » maximum instrument reading after successful repair or determination as nonrepairable
  » "repair delayed* and reason for delay if leak not repaired within 15 calendar days after detection.
    The owner or operator may develop and cite a written procedure that identifies conditions
    justifying a delay of repair
  • documentation of sufficient supply of spare pans on-site before depletion and reason for
    depletion if repair delayed because stocked parts were depleted
  « dates of process unit shutdowns that occurred while the equipment is unrepaired
  • date of successful repair of the leak
  • dates and results of monitoring

Information to be kept for all connectors:
  « identification of connectors, by area or grouping, with total number of connectors within each
    group
  * ID of screwed connectors, by area or grouping, with total number of screwed connectors with
    each group
  • location of areas or groups on site plan, log  entries, etc.
  • schedule by process unit for monitoring connectors
  » list of connectors removed and added if net credits for their removal are expected to be used
  * list of ID numbers for connectors in vacuum service
  » documentation of the integrity of the weld for removed connectors
  • copies of periodic reports (if database not capable of generating)
  « ID of connectors open or  otherwise had the seal broken since the last monitoring period, and
    dates and results of follow-up monitoring

Information to be kept for unsafe to monitor connectors:
  • identification of equipment designated as unsafe to monitor
  • plan for monitoring

Information to be kept for unsafe to repair connectors:
  » list of ID numbers
  » explanation for designation

Information to be kept for inaccessible, ceramic, and ceramic-lined connectors:
  • exempt from recordkeeping requirements

Information and data used to demonstrate that connectors are not in organic HAP service, are in HAP
service fewer than 300 hours/year, or are in heavy liquid service
                           CONNECTORS IN GAS/VAPOR AND LIGHT LIQUID SERVICE
                                                                                   page C-68

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              CONNECTORS IN GAS/VAPOR AND LIGHT LIQUID SERVICE
                                          APPLICABLE REGULATIONS
      40CFRPart60,
        Subpart W
              40 CFR Part 61S
              Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB
      ITEM
                                    REQUIREMENTS
Reporting
Requirements
Initial notification:
  «  name and address of owner/operator
  •  address of facility
  •  identification of subject processes
  «  compliance statement
  «  statement if a source can achieve compliance by applicable date

Notification of compliance status:
  «  process unit identification
  *  number of connectors,  excluding those in vacuum service
  «  method of compliance

Subsequent semiannual reports:
  «  number of connectors and  screwed connectors for which leaks were detected
  •  total number of connectors and screwed connectors monitored
  •  the percent  leakers for  connectors and screwed connectors
  *  number of connectors and  screwed connectors for which leaks were not repaired within 15 days
    after detection
  •  identification of the number of connectors determined to be nonrepairable
  •  the facts that explain each  delay of repair, and where appropriate, why a process unit shutdown
    was technically infeasible
  •  notification of change to connector monitoring alternatives (if applicable)
  •  revisions to items reported in the initial report if method of compliance has changed since the last
    report
  •  initiation of monthly monitoring under Phase in or QEP (if applicable)
  •  information listed under notification of compliance status for process units with later compliance
    dates

Inaccessible, ceramic, and ceramic-lined connectors exempt from reporting requirements
                            CONNECTORS IN GAS/VAPOR AND LIGHT LIQUID SERVICE
                                                                                   page C-69

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                   DUAL MECHANICAL SEAL SYSTEM
                             APPLICABLE REGULATIONS
40 CFR Pan 60,
  Subpart W
40 CFR Part 61,
Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB
ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
REQUIREMENTS
For each dual mechanical seal system:
• operate the barrier fluid at a pressure that is at all times greater than the pump stuffing box
pressure, or
• equip with a barrier fluid degassing reservoir that is routed to a process or fuel gas system or
connected by a closed-vent system to a control device, or
• equip with a closed-loop system that purges the barrier fluid into a process stream
For all dual mechanical seal systems:
« the barrier fluid system is not in light liquid service
• barrier fluid system is equipped with a sensor to detect failure of seal system, barrier fluid
system, or both
• • check each sensor daily or equip with audible alarm unless located at unmanned site
» • determine criterion that indicates failure of the seal system, the barrier fluid system, or both
• perform weekly visual inspections for indications of liquid dripping from the pump seals;
monitor if indications observed to determine if there is a leak of HAP in the barrier fluid
Applies as an alternative standard for:
• Pumps in Light Liquid Service
» Agitators in Gas/Vapor Service and in Light Liquid Service
Indications of liquids dripping from the pump seal and instrument reading of 1000 ppm HAP; failure
of sensor criteria
N/A
Any affected equipment equipped with a closed-vent system transporting fluid to process fuel gas
system or control device
Unsafe-to-monkor pumps are exempt if:
» monitoring personnel would be exposed to an immediate danger
* owner/operator has a written plan that requires monitoring as often as practical during safe to
monitor times
If at unmanned plant site, visually inspect as often as practical and at least monthly
Visual, sensor
First attempt within 5 calendar days of detection
Repair as soon as practicable; no later than 15 days after leak is detected
                          DUAL MECHANICAL SEAL SYSTEM
                                                       page C-70

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                              DUAL MECHANICAL SEAL SYSTEM
                                          APPLICABLE REGULATIONS
40CFRPart60,
Subpart W

40 CFR Part 61,
Subparts J and V

                                                               40 CFR Part 63,
                                                               Subparts H and I
                                                                   40 CFR Part 264, Subpart BB
                                                                   40 CFR Part 265, Subpart BB
     ITEM
                                     REQUIREMENTS
Delay of Repair
Allowed if repair requires replacing the existing seal design with a new system that meets improved
performance criterion

Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown

Allowed for equipment that is isolated from the process and that does not remain in organic HAP
service
Recordkeeping
Requirements
When leak detected:
  •  a weather-proof and readily visible identification, marked with the equipment ID number,
    attached to the leaking equipment
  «  ID may be removed after leak has been repaired

Information to be kept in log for 2 years after leak detected:
  »  instrument and equipment ID number, and operator name, initials, or ID number
  »  date leak detected
  •  date of first attempt to repair leak
  •  maximum instrument reading after successful repair or determined to be nonrepairable
  •  "repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection.
    The owner or operator may develop and cite a written procedure that identifies conditions
    justifying a delay of repair
  •  documentation of sufficient supply of spare parts on-site before depletion and reason for
    depletion if repair delayed because stocked parts were depleted
  »  expected date of successful repair if leak is not repaired within the 15 days
  •  date of successful repair of the leak

Information to be kept for all dual mechanical seal systems:
  »  list of ID numbers of dual mechanical seal systems
  •  location of equipment on site plan, log entries,  etc.
  •  documentation and dates of visual inspections
  »  copies of periodic reports (if database not capable of generating)

Information to be kept for barrier fluid and seal systems:
  •  design criteria for indicating failure
  •  explanation for selected criteria
  »  any changes to criteria and reasons for change

Identification, by list or location,  of equipment in organic  HAP service fewer than 300 hours per year
                                       DUAL MECHANICAL SEAL SYSTEM
                                                                                     page C-71

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                              DUAL MECHANICAL SEAL SYSTEM
                                         APPLICABLE REGULATIONS
      40CFRPart60,
       Subpart Vy
              40CFRPait61,
              Subpans J and V
40 CFR Part 63,
Sutaparts H and!
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB
     ITEM
                                    REQUIREMENTS
Reporting
Requirements
Initial notification:
 «  name and address of owner/operator
 •  address of facility
 •  identification of subject processes
 «  compliance statement
 •  statement if a source can achieve compliance by applicable date

Notification of compliance status:
 »  process unit identification
 •  number of pumps (excluding those in vacuum service)
 «  method of compliance

Subsequent semiannual reports:
 «  the following information for each monitoring period in the reporting period:
    • •  number of pumps for which leaks were detected
    • *  percent of pumps leaking
    • •  total number of pumps monitored
    • •  number of pumps for which leaks were not repaired as required
    « •  the facts that explain each delay of repair, and where appropriate, why a process unit
        shutdown was technically  infeasible
 «  revisions to items reported in the initial notification of compliance if method of compliance has
    changed since the last report
 «  information listed under Notification of Compliance for process units with later compliance dates
                                     DUAL MECHANICAL SEAL SYSTEM
                                                                                                   page C-72

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                       OPEN-ENDED VALVES OR LINES
                               APPLICABLE REGULATIONS
40CFRPart6Q,
  Subpart W
40CFRPart61,
Subparts J and V
40CFRPart63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CPRPart 265, Subpart BB
ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
Recordkeeping
Requirements
REQUIREMENTS
Use cap, blind flange, plug, or second valve to seal open end at all times except when operations
require flow through open end or during maintenance and repair
Second valve: close valve on process fluid end prior to closing second valve
Double block and bleed system: bleed line valve may remain open during venting operations that
require venting the line between the block valves but comply with basic standard at all other times
N/A

Alternative means of emission limitation

Emergency shutdown system
Equipment containing materials which would automatically polymerize or cause a safety hazard if
capped or equipped with a double block and bleed system
Equipment in vacuum service
Equipment operated fewer than 300 hours per year
N/A
N/A
N/A
Information to be kept for all open-ended valves or lines:
» list of ID number of subject equipment
• location on site plan, log entries, etc.
Copies of periodic reports (if database not capable of generating)
Information and data used to demonstrate that equipment is not in organic HAP service or is
service fewer than 300 hours/year
in HAP
                             OPEN-ENDED VALVES OR LINES
                                                           page C-73

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                               OPEN-ENDED VALVES OR ONES
                                        APPLICABLE REGULATIONS
      40 CFR Part 60,
        SubpartW
              40CFRPart61,
              Subparts J and V
40CFRPart63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB
     ITEM
                                   REQUIREMENTS
Reporting
Requirements
Initial notification:
 •  name and address of owner/operator
 «  address of facility
 •  identification of subject processes
 •  compliance statement
 «  statement if a source can achieve compliance by applicable date

Notification of compliance status:
 •  process unit identification
 »  number of open-ended valves or lines (excluding those in vacuum service)
 •  method of compliance

Subsequent semiannual reports:
 •  dates of process unit shutdowns that occurred within the semiannual reporting period
 «  revisions to items reported hi the initial report if changes in the method of compliance have
    changed since the last report
 •  information listed in notification of compliance status for process units with later compliance
    dates
                                      OPEN-ENDED VALVES OR LINES
                                                                                page C-74

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PRESSURE RELIEF DEVICES IN GAS/VAPOR SERVICE
                    APPLICABLE REGULATIONS
40 CFR Part 60,
Subpart VV

40 CFR Part 61,
Subparts J and V

                                    40 CFR Part 63,
                                    Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB
ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
REQUIREMENTS
Without rupture disk:
« operate at less than 500 ppm above background except during pressure releases
• within 5 calendar days after each release, return to operating standard and monitor the pressure
relief device (PRD) to confirm
• within 5 calendar days after the pressure release and being returned to HAP service, monitor to
confirm 500 ppm above background standard
With rupture disk:
» after each release, replace rupture disk within 5 calendar days
< 500 ppm above background
Alternative means of emission limitation
Pressure relief device routed to a process or fuel gas system or equipped with compliant closed-vent
system and control device (see Closed-vent Systems and Control Devices)
Pressure relief device in vacuum service
Pressure relief device in organic HAP service fewer than 300 hours per year
Any pressure relief device equipped with a rupture disk meeting the requirements of the rule
Method 21
• Response factor criteria (excluding inerts) for average composition of process fluid
• Monitor all equipment while it is "in service"
See basic standard
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in organic HAP
service
          PRESSURE RELIEF DEVICES IN GAS/VAPOR SERVICE
               page C-75

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                  PRESSURE RELIEF DEVICES IN GAS/VAPOR SERVICE
                                          APPLICABLE REGULATIONS
      40CFRPart60,
        SubpartW
              40 CFR Part 61,
              Sabparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CPR Fait 265, Subpart BB
     ITEM
                                     REQUIREMENTS
Reeordkeeping
Requirements
When leak detected:
  •  a weather-proof and readily visible identification, marked with the equipment ID number,
    attached to the leaking equipment
  *  ID may be removed after leak has been repaired

Information to be kept in log for 2 years after leak detected:
    instrument and equipment ID number, and operator name, initials, or ID number
    date leak detected
    dates of first attempt to repair leak
    maximum instrument reading after successful repair or determined to be nonrepairable
    "repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection.
    The owner or operator may develop and cite a written procedure that identities conditions
    justifying a delay of repair
  •  documentation of sufficient supply of spare parts on-site before depletion and reason for
    depletion if repair delayed because stocked parts were depleted
  »  copies of periodic reports (if database not capable of generating such)
  »  expected  date of successful repair if leak is not repaired within the 15 days
  •  dates of process unit shutdown that occurred while the equipment is unrepaired
  »  date of successful repair of the leak

Information to be kept for all pressure relief devices:
  «  list of ID numbers of pressure relief devices
  »  list of ID numbers of pressure relief devices equipped with rupture disks
  »  list of ID numbers of pressure relief devices complying with an instrument reading of less than
    500 ppm  above background standard
  •  location of pressure relief devices on site plan,  log entries, etc.
  »  list of ID numbers for pressure relief devices equipped with closed-vent system and control
    device
  »  documentation and dates of visual  inspections
  •  for monitoring following a pressure release for each PRD:
    • •  dates and results of monitoring
    • •  background level measured
    • »  maximum instrument reading

Information and data used to demonstrate that a pressure relief device is not in organic HAP service
or is in HAP service fewer than 300 hours/year
                              PRESSURE RELIEF DEVICES IN GAS/VAPOR SERVICE
                                                                                  page C-76

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                  PRESSURE RELIEF DEVICES IN GAS/VAPOR SERVICE
                                          APPLICABLE REGULATIONS
      40 CFR Part 60,
        SubpartW
              40 CFR Part 61,
              Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB
     ITEM
                                    REQUIREMENTS
Reporting
Requirements
Initial notification:
  »  name and address of owner/operator
  »  address of facility
  •  identification of subject processes
  •  compliance statement
  »  statement if a source can achieve compliance by applicable date

Notification of Compliance Status:
  •  process unit identification
  »  number of pressure relief devices, excluding those in vacuum service
  »  method of compliance

Subsequent semiannual reports:
  •  by monitoring period in the reporting period, explanation of why repairs delayed and why a
    process unit shutdown was infeasible
  •  for "no detectable emissions" components, results of all monitoring to show compliance with the
    operating standard of less than 500 ppm
  «  revisions to items reported in the initial report if changes have occurred since the initial report or
    subsequent revisions to the initial report
  •  information listed in Notice of Compliance Status for process units with later compliance dates
                              PRESSURE RELIEF DEVICES IN OAS/VAPOR SERVICE
                                                                                  page C-77

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                               PUMPS IN LIGHT LIQUID SERVICE
                                         APPLICABLE REGULATIONS
      40CFRPait60,
        Subpan W
              40 CFR Part 61,
              Subparts J and V
40 CFR. Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265. Subpart BB
     HEM
                                    REQUIREMENTS
Basic Standard
Monthly leak detection and repair

Weekly visual observation for leaks

For existing sources:
  »  Phase I begins on compliance date
  •  Phase n begins no later than 1 year after compliance date
  •  Phase in begins no later than 2 Vz years after compliance date

For new sources:
  *  Phase II begins after initial start-up
  «  Phase ffl begins no later than 1 year after initial start-up

Choose no later than first monitoring period whether to calculate percent leaking pumps on a process
unit basis or source-wide basis

Phase HI: if the greater of 10% or 3 pumps in a process unit leaks (6 month average), Quality
Improvement Program (QIP) required
Leak Definition
Phase I:      10,000 ppm
Phase H:     5,000 ppm
Phase HI:     5,000 ppm for pumps handling polymerizing monomers
             2,000 ppm for pumps in food/medical service
             1,000 ppm for all other pumps

Indications of liquids dripping from pump seal
Alternative
Standards
Alternative means of emission limitation

Enclosed-vented process units: may enclose process units and operate under negative pressure while
venting all leaks from equipment through a closed vent system to a control device meeting the
requirements of this rule

Batch processes: may pressure test or monitor equipment for leaks

"No detectable emissions" pumps (see No Detectable Emissions)
                                      PUMPS IN LIGHT LIQUID SERVICE
                                                                                  page C-78

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                               PUMPS IN LIGHT LIQUID SERVICE
                                         APPLICABLE REGULATIONS
      40 CFR Part 60,
        Subpart W
              40 CFR Part 61 (
              Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart IB
40 CFR Part 265, Subpart BB
     ITEM
                                    REQUIREMENTS
Exemptions
Dual mechanical seal pumps (see Dual Mechanical Seal System)

Pumps designed with no externally actuated shaft penetrating pump housing

Pump equipped with closed-vent system and control device (see Closed-vent Systems and Control
Devices)

Pumps in vacuum service

Pumps operated fewer than 300 hours per year in organic HAP service

Process units with more than 90% of pumps with dual mechanical seal or closed-vent system are
exempt from monthly calculations of percent leaking pumps

If at unmanned site, visually inspect as often as practicable and at least monthly

Unsafe to monitor pumps are exempt if:
  •  monitoring personnel would be exposed to an immediate danger
  •  owner/operator has a written plan that requires monitoring as often as practical during safe to
    monitor times, but not more frequently than the periodic monitoring schedule otherwise
    applicable
Monitoring
Method
Method 21; no more than 1 cm from rotating shaft
  »  response factor criteria (excluding inerts) for average composition of process fluid
  »  monitor all equipment while it is "in service"
Repair
Requirements
First attempt within 5 calendar days of detection

Repair as soon as practicable; no later than 15 days after detection

Phase in pumps with leak definition of 1,000 ppm: repair only required for pumps leaking at  2,000
ppm or more
Delay of Repair
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown.

Allowed for equipment that is isolated from the process .and that does not remain in organic HAP
service

Allowed if repair requires use of:
  •  a new system determined to provide better performance under provisions of a QIP, or
  »  a dual mechanical seal that includes a barrier fluid system, or
  «  a pump designed with no externally actuated shaft, or
  «  a closed-vent system and control device
and repair is completed as soon as practicable but not later than 6 months after leak detected
                                       PUMPS IN LIGHT LIQUID SERVICE
                                                                                    page C-79

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                               PUMPS IN LIGHT LIQUID SERVICE
                                          APPLICABLE REGULATIONS
40 CFR Pan 60,
SubpartW

40CFRPart61,
Subparts I and V

                                                              40 CFR Part 63,
                                                              Subpans H and I
                                                                 40 CFR Part 264, Subpart BB
                                                                 40 CPR Part 265, Subpart BB
     ITEM
                                     REQUIREMENTS
Recordkeeping
Requirements
When leak detected:
  «  a weather-proof and readily visible identification, marked with the equipment ID number,
    attached to the leaking equipment
  •  ID may be removed after it has been repaired

Information to be kept in log for 2 years after leak detected:
  •  instrument and equipment ID number and operator name, initials, or ID number
  •  date leak detected
  •  date of first attempt to repair leak
  •  maximum instrument reading (M21) after successful repair or determination the pump is
    nonrepairable
  •  "repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection.
    The owner or operator may develop and cite a written procedure that identifies conditions
    justifying a delay of repair
  •  documentation of sufficient supply of spare parts on-site before depletion and reason for
    depletion if repair delayed because stocked parts were depleted
  •  dates of process unit shutdown that occurred while the equipment is unrepaired
  •  date of successful repair of the leak

Information to be kept for all pumps:
  •  list of ID numbers of subject pumps
  »  location of pump on site plan, log entries, etc.
  »  list of ID numbers of pumps equipped with closed-vent system and control device
  *  documentation and dates of visual inspections
  •  copies of periodic reports (if database not capable of generating)

Information to be kept for unsafe to monitor pumps:
  «  identification of equipment designated as unsafe to monitor
  »  plan for monitoring

Information to be kept for difficult to monitor pumps:
  «  list of ID numbers
  »  explanation for designation
  •  planned schedule for monitoring

Information to be kept for pumps equipped with dual mechanical seal:
  •  design criteria for indicating failure
  «  explanation for selected criteria
  *  any changes  to the criteria, and reason for change

Information and data used to demonstrate that a pump is not in organic HAP service, is in HAP
service fewer than 300 hours/year, or is in heavy liquid service
                                       PUMPS IN LIGHT LIQUID SERVICE
                                                                                   page C-80

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                               PUMPS IN LIGHT LIQUID SERVICE
                                          APPLICABLE REGULATIONS
      40 CFR Part 60,
        SubpartW
              40 CFR Part 61,
              Snbparts J and V
40 CFR Pan 63,
Snbparts H and I
40 CFR Part 264, Subpart BB
40 CPR Pan 265, Subpan BB
     ITEM
                                    REQUIREMENTS
Reporting
Requirements
Initial notification:
 •  name and address of owner/operator
 •  address of facility
 •  identification of subject processes
 *  compliance statement
 »  statement if a source can achieve compliance by applicable date

Notification of compliance status:
 •  process unit identification
 •  number of pumps (excluding those in vacuum service)
 •  method of compliance
 •  planned schedule for each phase of requirements

Subsequent semiannual reports:
 •  the following information for each monitoring period in the reporting period:
    « • number of pumps for which leaks were detected
    « • percent of pumps leaking
    • • total number of pumps monitored
    • • number of pumps for which leaks were not repaired as required
    • • the facts that explain each delay of repair, and where appropriate, why a process unit
        shutdown was technically infeasible
 •  revisions to items reported in the initial notification of compliance status if method of compliance
    has changed since the tost report
 •  initiation of monthly monitoring under phase III or QIP (if applicable)
 »  information listed under notification of compliance status for process units with later compliance
    dates
                                       PUMPS IN LIGHT LIQUID SERVICE
                                                                                   page C-81

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                   PUMPS, VALVES, CONNECTORS, AND AGITATORS
             IN HEAVY LIQUID SERVICE; INSTRUMENTATION SYSTEMS;
                 AND PRESSURE RELIEF DEVICES IN LIQUID SERVICE
                                       APPLICABLE REGULATIONS
      40 CFR Part 60,
       Subpart W
             40 CFR Part 61,
             Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB
     ITEM
                                  REQUIREMENTS
Basic Standard
Monitoring of potential leaks within 5 calendar days of detection if evidence of potential leak is found
by visual, audible, olfactory, or other detection method, unless repaired as discussed under "Repair
Requirements" below
Leak Definition
Monitoring:
 »  agitators - 10,000 ppm
 »  pumps - 2,000 ppm
 »  valves, connectors, pressure relief devices, instrumentation systems - 500 ppm
 *  pumps in food/medical service - 2,000 ppm
 »  pumps handling polymerizing monomers - 5,000 ppm

Other:
 »  evidence of potential leak by visual, audible, olfactory or other detection requirement
Alternative
Standards
Alternative means of emission limitation

Enclosed vented process units: may enclose process units and operate under negative pressure while
venting all leaks from equipment through a closed vent system to a control device meeting the
requirements of this rule.

Batch processes: may pressure test or monitor equipment for leaks
Exemptions
Equipment in vacuum service

Equipment operated fewer than 300 hours per year in organic HAP service
Monitoring
Method
Method 21; no more than 1 cm from rotating shaft
 «  response factor criteria (excluding inerts) for average composition of process fluid
 •  monitor all equipment while it is "in service"
Repair
Requirements
First attempt within 5 calendar days of detection

Repair as soon as practicable; no later than 15 days after detection

For equipment that are not monitored (Method 21), repair shall mean that visual, olfactory or other
indications of a leak have been eliminated; no bubbles are observed at potential leak sites during lead
check with soap solution; or system will hold a test pressure
                 PUMPS, VALVES, CONNECTORS, AND AGITATORS IN HEAVY LIQUID SERVICE;
              INSTRUMENTATION SYSTEMS; AND PRESSURE RELIEF DEVICES IN LIQUID SERVICE         page C-82

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                   PUMPS, VALVES, CONNECTORS, AND AGITATORS
             IN HEAVY LIQUID SERVICE; INSTRUMENTATION SYSTEMS;
                 AND PRESSURE RELIEF DEVICES IN LIQUID SERVICE
                                       APPLICABLE REGULATIONS
     40 CFR Part 60,
       Subpart W
              4QCFRPart61,
              Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB
     ITEM
                                  REQUIREMENTS
Delay of Repair
 Allowed if technically infeasible without process unit shutdown; required before end of next process
 unit shutdown

 Allowed for equipment that is isolated from the process and that does not remain in organic HAP
 service

 Valves, connectors and agitators:
  • Allowed if emissions of purged material resulting from immediate repair would exceed fugitive
    emissions from delay of repair and purged material is collected and destroyed or recovered in
    compliant control device when repair is done

 Valves:
  • Delay beyond a process unit shutdown allowed if sufficiently stocked supplies of valve
    assemblies have been depleted

  » Delay not allowed beyond the second process unit shutdown unless the third process unit
    shutdown occurs sooner than 6 months after first process unit shutdown

 Pumps:
  • Allowed if repair requires replacing existing seal design with a new system that provides better
    performance, dual mechanical seal system, meets requirements of §63.163(f), or compliant
    closed-vent system and control device, and repair is completed as soon as practicable but not
    later than 6 months after leak detected
Recordkeeping
Requirements
 When leak detected:
 . • a weather-proof and readily visible identification, marked with the equipment ID number,
    attached to the leaking equipment
  « ID may be removed after it has been repaired, except valves
  « ED may be removed from valve after it has been monitored at least once within first 3 months of
    repair and no leak is detected
  • ID may be removed from connector after it has been repaired and monitored when reconnected
    or within 3 months of repair and no leak is detected

	(Continued on next page)	
                 PUMPS, VALVES, CONNECTORS, AND AGITATORS IN HEAVY LIQUID SERVICE;
               mSTRUMENTATION SYSTEMS; AND PRESSURE RELIEF DEVICES IN LIQUID SERVICE        page C-83

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                  PUMPS, VALVES, CONNECTORS, AND AGITATORS
            IN HEAVY LIQUID SERVICE; INSTRUMENTATION SYSTEMS;
                AND                         DEVICES IN LIQUID SERVICE
                                      APPLICABLE REGULATIONS
     40 CFR Part 60,
       Subpart W
             40CFRPait61,
             Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CER Part 264, Subpart BB
40 CFR Part 265, Subpart BB
     ITEM
                                  REQUIREMENTS
Recordkeeping
Requirements
(continued)
Information to be kept in log for 2 years after leak detected:
 «  instrument and equipment ID number and operator name, initials, and ID number
 »  date leak detected
 »  dates of each attempt to repair leak
 •  maximum instrument reading after successful repair or determination the equipment is
    nonrepairable
 »  "repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection.
    The owner or operator may develop and cite a written procedure that identifies conditions
    justifying a delay of repair
 •  documentation of sufficient supply of spare parts on-site before depletion and reason for
    depletion if repair delayed because stocked parts were depleted
 »  dates of process unit shutdown that occurred while the equipment is unrepaired
 •  date of successful repair of the leak

Information to be kept for all equipment:
 «  list of ID numbers of subject equipment (except instrumentation systems)
 •  location of equipment on site plan, log entries,  etc.
 •  documentation and dates of visual inspections
 »  ID of instrumentation systems; individual components need not be identified
 »  Information, data, and analysis used to demonstrate that a piece of equipment or process unit is
    in heavy liquid service
 •  copies  of periodic reports (if database not capable of generating)

Additional information to be kept for connectors:
 •  identification of connectors, by area or grouping, with total number of connectors within each
    group
 «  ID of connectors opened or otherwise had the seal broken since the last monitoring period, and
    dates and results of follow-up  monitoring
                PUMPS, VALVES, CONNECTORS, AND AGITATORS IN HEAVY LIQUID SERVICE;
              INSTRUMENTATION SYSTEMS; AND PRESSURE RELIEF DEVICES IN LIQUID SERVICE        page C-84

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                  PUMPS, VALVES, CONNECTORS, AND AGITATORS
            IN HEAVY LIQUID SERVICE; INSTRUMENTATION SYSTEMS;
                AND PRESSURE RELIEF DEVICES IN LIQUID SERVICE
                                     APPLICABLE REGULATIONS
     40 CFS. Part 60,
       Snbpart W
             40CFRPart61,
             Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpatt BB
     ITEM
                                 REQUIREMENTS
Reporting
Requirements
Initial notification:
 •  name and address of owner/operator
 »  address of facility
 «  identification of subject processes
 »  compliance statement
 »  statement if a source can achieve compliance by applicable date

Notification of compliance status:
 •  process unit identification
 •  number of each type of equipment (excluding those in vacuum service)
 *  method of compliance

Subsequent semiannual reports:
 •  for each monitoring period, the facts that explain each delay of repair, and where appropriate,
    why a process unit shutdown was technically infeasible
 *  revisions to items reported in the initial Notification of Compliance Status if method of
    compliance has changed since the last report
 «  information listed in the Notification of Compliance Status for process units with later
    compliance dates
                PUMPS, VALVES, CONNECTORS, AND AGITATORS IN HEAVY LIQUID SERVICE;
              INSTRUMENTATION SYSTEMS; AND PRESSURE RELIEF DEVICES IN LIQUID SERVICE        page C-85

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  QUALITY IMPROVEMENT PROGRAM FOR PUMPS IN LIGHT LIQUID SERVICE
                                        APPLICABLE REGULATIONS
      40CFRPitrt60,
       SubpartW
              40 CFR Part 61,
              Subpaits J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB
     ITEM
                                   REQUIREMENTS
Applicability
A technology review of improvement QIP's are required in Phase ffl if the greater of either 10% of
pumps in a process unit (or plant site) or 3 pumps in a process unit (or plant site) leak

Once  < 10% or <  3 pumps leaking is achieved (6 month rolling average), comply with basic
standard

If leak rate again exceeds the greater of either > 10% or 3 pumps leaking, can use QIP again
Basic Standard
Comply with basic standard for pumps not in QIP

Collect the following data:

Pumps:
  »  type and manufacturer
  «  seal type and manufacturer
  •  pump design
  •  materials of construction
  «  year installed
  •  barrier fluid or packing material

Service characteristics of the stream:
  •  discharge pressure, temperature, flow rate, corrosivity, annual operating hours

Maximum instrument readings before repair, response factor for stream, instrument number, and
date of observation

If leak is detected, repair methods used and the instrument readings after the repair

Inspect all pumps and pump seals that exhibit frequent failure and were removed from the process
unit due to leaks; determine probable cause of leaks and recommend changes to reduce leak potential

Continue to collect data as long as part of QIP
Data Analysis
Analyze data to determine the services, operating and maintenance procedures, and pumps and pump
seal designs or technologies that have poorer and those that have better than average performance;
the first analysis shall be completed no later than 18 months after the start of the program, shall use a
minimum of 6 months of data, and shall be done yearly for as long as the process unit is in the QIP
program.  The analysis shall determine if specific trouble areas can be identified.
                   QUALITY IMPROVEMENT PROGRAM FOR PUMPS IN LIGHT LIQUID SERVICE
                                                                                page C-86

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  QUALITY IMPROVEMENT PROGRAM FOR PUMPS IN LIGHT LIQUID SERVICE
                                          APPLICABLE REGULATIONS
      40CFRPait«>,
        Subpart W
              40 CFR Part 61,
              Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Snbpart BB
40 CFR Part 265, Subpart BB
     ITEM
                                    REQUIREMENTS
Performance Trial
Evaluation
Required for plants that have not demonstrated superior technologies:
  »  the number of pump seal technologies or pumps in the trial program shall be the lesser of 1 % or
    2 pumps for programs involving single process units and the lesser of 1 % or 5 pumps for plant
    sites or groups of process units; the minimum number of pumps or pump seal technologies in the
    program shall be 1
  »  the program shall specify and include design documentation, the evaluation stages, frequency of
    monitoring, the range of operating conditions, and conclusions

The performance trials shall be conducted for a 6-month period beginning no later than 18 months
after the beginning of the QIP

Conclusions will be drawn no later than 24 months after the beginning of the QJP

Any plant site with fewer than 400 valves and owned by a company with fewer than 100 employees
exempt from trial evaluations. Instead begin pump seal or pump replacement program at the start of
the fourth year of QIP.                               	    	      	      	
Performance Test
Evaluation
Termination
Continue to conduct trials as long as no superior performing design or technology has been identified
or until there are no technically feasible alternatives as demonstrated through an engineering
evaluation. Otherwise the facility may stop conducting performance tests after all alternative superior
emission performance technologies have been evaluated and a superior performing design or
technology has been demonstrated
Quality Assurance
Program
Establishes minimum design standards for each category of pumps or pump seal technology

Requires that all equipment orders specify the design standard for the pump or pump seal

Provides for an audit procedure for quality control of purchased equipment

Details off-line pump maintenance and repair procedures

Shall be established no later than start of third year of QIP for sites with a400 valves or 2100
employees; by start of fourth year for others
Equipment
Replacement
Beginning at the start of the third year of the QIP for plants with 400 or more valves or 100 or more
employees and at the start of the fourth year for others, the owner/operator shall replace the pumps
and pump seals that are not superior emission performance technology with pumps or pump seals of
superior technology that comply with QA standards for the pump category.

Pumps or pump seals shall be replaced at the rate of 20% per year based on the total number of
pumps in light liquid service (minimum of one) and shall continue to be replaced until all are
superior technology
                    QUALITY IMPROVEMENT PROGRAM FOR PUMPS IN LIGHT LIQUID SERVICE
                                                                                  page C-87

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QUALITY IMPROVEMENT PROGRAM FOR PUMPS IN LIGHT LIQUID SERVICE
                               APPLICABLE REGULATIONS
   40CFRPart60,
    Subpart W
40CFRPart6l,
Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CPR Part 265, Subpart BB
ITEM
Superior Emission
Performance
Technology
Recordkeeping
Requirements
Reporting
Requirements
REQUIREMENTS
Category or design of pumps or pump seals that will result in < 10% leaking pumps in the process
unit of plant site
Includes material or design changes to the existing pump, pomp seal, seal support system, installation
of multiple mechanical seals or equivalent, or pump replacement
» pump type, manufacturer, seal type and manufacturer, design, materials of construction (if
applicable), barrier fluid or packing material, and year installed
« service characteristics of the stream, discharge pressure, temperature, flow rate, eorrosivify, and
annual operating hours
• maximum instrument readings before repair, response factor, instrument number, and date of
observation
• if leak detected, the repair method used and the instrument reading after repair
• if data analyzed as part of a larger analysis program; describe any maintenance or QIP intended
to improve emission performance
* rolling average percent leaking pumps
• documentation of all inspections and recommendations for design or specification changes to
reduce leak frequency
• beginning and end dates while meeting requirements of the QIP
» reason for any leak repair delay and expected date of successful repair
• records of all analyses required under §63.176(d), including:
• • list identifying areas associated with poorer than average performance and associated
service characteristics of the stream, operating conditions, and maintenance procedures
• » reasons for rejecting specific candidate superior emission performing pump technology from
performance trials
• • list of candidate superior emission performing pump technologies and documentation of
performance trial program items required under 63.176(d)(6)(iii)
• • beginning date and duration of performance trials for each candidate superior emission
performing technology
• records documenting the quality assurance program, as specified in 63.176(d)(7)
• records indicating all pumps replaced or modified are in compliance with the quality assurance
program
« records documenting compliance with 20% or greater annual replacement rate for pumps
* information and data showing company has fewer than 100 employees
Semiannual reports:
« initiation of monthly monitoring under Phase HI or QIP (if applicable)
             QUALITY IMPROVEMENT PROGRAM FOR PUMPS IN LIGHT LIQUID SERVICE
                                                      page C-88

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                    QUALITY IMPROVEMENT PROGRAM FOR VALVES
                                          APPLICABLE REGULATIONS
      40 CFR Part 60,
        SubpartW
              40 CFR Part 61,
              Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpait BB
      ITEM
                                    REQUIREMENTS
Applicability
Optional in Phase ffl to owners/operations with <; 2% leakers

Decision required within first year of Phase HI

If rolling average of percent leakers is < 2% for 2 consecutive quarters:  I) comply with QIP, 2)
comply with valve standard, or 3) comply with both QIP and valve standard

If continuing QIP, exempt from performance trial requirements or further progress as long as process
unit has <2% leaking valves

If not continuing QIP (i.e., complying with valve standard) cannot use QIP again if leak rate goes
above 2%; monthly monitoring is required

If complying with both QIP and valve standard, owner/operator may use the following monitoring
frequencies:
  »  if < 2% leaking, then monitor once per quarter
  •  if < 1 % leaking, then monitor once every 2 quarters
  «  if <0,5% leaking, then once every 4 quarters
Demonstration of
Further Progress
Comply with valve standard except monitor quarterly

Collect data and maintain records as follows:
  •  maximum instrument reading observed in each monitoring, response factor, model number, and
    date of observation
  •  classification of valve "gas or light liquid service"
  •  repair method used and instrument readings after repair (monitoring required at least once within
    the first 3 months after the repair is completed)(ID tag on a leaking valve may be removed after
    the valve successfully passes this monitoring period)

Continue to collect data for as long as the process unit is in QIP

Demonstrate progress in reducing the percent leaking valves each quarter by at least:
  »  10 percent (meaning that each quarter there is at least a  10 percent reduction in the percent
    leaking valves from the preceding monitoring period) or
  »  determine required quarterly percent reduction and to less than 2% within 2 years

The provisions for failure to meet the 10% reduction for 2 consecutive rolling averages are:
  »  a choice of monthly monitoring, or
  «  implementation of a QIP for technology review as specified in §63.175(e)
                                QUALITY IMPROVEMENT PROGRAM FOR VALVES
                                                                                    page C-89

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                    QUALITY IMPROVEMENT PROGRAM FOR VALVES
                                         APPLICABLE REGULATIONS
      40 CFR Part 60,
        SubptrtW
              40 CFR Part 61,
              Snbparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB
      ITEM
                                    REQUIREMENTS
Data Collection
(Technology
Review and
Improvement)
Data collection for as long as in QDP:
  »  valve type and manufacturer, valve design, materials of construction, year installed, and packing
    material
  »  service characteristics of the stream (e.g., operating pressure, temperature, line diameter,
    corrosivity)
  •  gas/vapor or light liquid service
  •  repair methods used and the instrument readings after the repair
  •  maximum instrument reading before repair, response factor, model number, and date of
    observation
  »  description of use of any maintenance or quality assurance programs intended to improve
    emissions

Inspect all valves removed due to leaks to determine cause of failure and recommend design and
other changes to reduce leak potential
Data Analysis
(Technology
Review and
Improvement)
Analyze data to determine the services, operating and maintenance procedures, and valve designs or
technologies that have poorer and those that have better than average performance to determine
specific trouble areas; the first analysis shall be completed no later than 18 months after the start of
the program, shall use a minimum of 6 months of data, shall be done yearly for as long as the
process unit is in the QIP program
Definition of
Superior
Performing Valve
Technology
Technology for valves having a leak frequency of <2% for specific applications in process unit

Candidate demonstrates or reports having low emission performance and capable of achieving <2%
leaking valves in process unit
Performance Test
Trial Evaluation
(Technology
Review and
Improvement)
Required for plants that have not demonstrated superior technologies:
  »  the number of valves in the trial program shall be the lesser of 1 % or 20 valves for programs
    involving single process units and the lesser of 1 % or 50 valves for programs involving groups
    of process units
  »  the program shall specify and include design documentation, the evaluation stages, frequency of
    monitoring, the range of operating conditions, and conclusions regarding performance and
    operating conditions and services

Any plant site with fewer than 400 valves and owned by a company with fewer than 100 employees
exempt from trial evaluations. Instead begin program at the start of the fourth year of Phase in

The performance trials shall be conducted for a 6-month period beginning no later than 18 months
after the beginning of the QIP

Conclusions will be drawn no later than 24 months after the beginning of the QIP

Performance test trials will continue as long as no superior design or technology is identified
                               QUALITY IMPROVEMENT PROGRAM FOR VALVES
                                                                                   page C-90

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                    QUALITY IMPROVEMENT PROGRAM FOR VALVES
                                          APPLICABLE REGULATIONS
      40 CFR Part 60,
        Subpart W
               40 CFR Part 61,
               Snbparts J and V
40 CFR Part 63,
Snbparts H and I
40 CFR Pan 264, Subpart BB
40 CFR Part 265, Subpart BB
      ITEM
                                     REQUIREMENTS
Quality Assurance
Plan
Program shall be established no later than the start of the third year of Phase HI for plant sites with
2:400 valves or a 100 employees, and no later than the start of the fourth year of Phase IEE for plants
with <  400 valves and < 100 employees

Program shall be reviewed and updated (as appropriate) each year as long as the process unit has
22% leaking valves

Program shall:
•   Establish minimum design standards for each category of valves
*   Require that all equipment orders specify the design standard
•   Include a written'procedure for bench testing
*   Require that all valves repaired on-line be monitored for 2 successive months after repair
•   Provide for an audit procedure for quality control of purchased equipment
•   Detail off-line valve maintenance and repair procedures
Equipment
Replacement
(Technology
Review and
Improvement)
Beginning at the start of the third year of Phase ffl for plants with 400 or more valves or 100 or more
employees and at the start of the fourth year of Phase HI for others, each replacement valve shall
meet quality assurance and superior emission performance technology standards

If superior emission performance technology cannot be identified, replacement valve shall be one
with lowest emission performance technologies identified for the specific application
Recordkeeping
Requirements
QIP:
    reason for any leak repair delay and expected date of successful repair
    records of all analyses required under §63.175(e)
    records documenting the quality assurance program
    records indicating all valves replaced or modified are in compliance with the quality assurance
    requirements
    information and data showing company has fewer than 100 employees
Recordkeeping for
QIP-
Demonstration of
Reasonable
Further Progress
QIP - reasonable further progress:
  •  owner or operator shall collect the following data and maintain records for each valve in each
    process unit subject to the QEP
    • •  maximum instrument reading before repair, response factor, instrument model number, and
        date of observation
    • •  whether valve is in gas or light liquid service
    • •  if leak detected, the repair methods used and instrument reading after repair
  «  percent leaking valves and rolling average percent reduction observed each quarter
  •  beginning and end dates while meeting the requirements of the QIP
                                QUALITY IMPROVEMENT PROGRAM FOR VALVES
                                                                                    page C-91

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           QUALITY IMPROVEMENT PROGRAM FOR VALVES
                            APPLICABLE REGULATIONS
40 CFR Part 60,
 SnbpartW
40 CFR Pan 61,
Subpans J and V
40 CFR Part 63,
Subpans Hand I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpait BB
ITEM
Recordkeeping for
QIP - Technology
Review and
Improvement
Reporting
Requirements
REQUIREMENTS
QIP - technology review and improvement:
« valve type, manufacturer, design, materials of construction, packing material, and year installed
• service characteristics of the stream (e.g. operating pressure, temperature, line diameter,
corrosivity)
» whether valve is in gas/vapor or light liquid service
« if leak detected, maximum instrument reading before repair, response factor, model number, and
date of observation
* if leak detected, the repair method used and the instrument reading after repair
* if data analyzed as part of a larger analysis program; describe any maintenance or QIP intended
to improve emission performance
» percent leaking valves observed each quarter
« documentation of all inspections and recommendations for design or specification changes to
reduce leak frequency
« beginning and end dates while meeting requirements of the QIP of technology review and
improvement
Subsequent semiannual reports:
» initiation of monthly monitoring under Phase HI or QIP (if applicable)
                    QUALITY IMPROVEMENT PROGRAM FOR VALVES
                                                    page C-92

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                     SAMPLING CONNECTION SYSTEMS
                               APPLICABLE REGULATIONS
40 CFR Part 60,
  Subpart W
40 CFR Part 61,
Subpaits J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB
ITEM
Basic Standard
Leak Definition

Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
Recordkeeping
Requirements
REQUIREMENTS
Equipped with closed-purge system or closed-vent system that returns the fluid to the process line;
recycles the purged fluid; sends it to a compliant control device; or collects, stores and transports it
to an appropriate facility
Gases displaced during filling of samples are not required to be collected or captured
N/A

Alternative means of emission limitation
Sampling systems in vacuum service
In-situ sampling systems and sampling systems without purges
Sampling systems in organic HAP service fewer than 300 hours per year
N/A
N/A
N/A
Information to be kept for all sampling connections
• list of ID numbers of subject sampling connection systems
• location of sampling system on site plan, log entries, etc.
Information and data used to demonstrate that equipment is not in organic HAP service or is in HAP
service fewer than 300 hours/year.
                            SAMPLING CONNECTION SYSTEMS
                                                            page C-93

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                              SAMPLING CONNECTION SYSTEMS
                                         APPLICABLE REGULATIONS
      40 CER Part 60,
        SubpartW
              40CFRPart61,
              SubpaitsJandy
40 CFR Part 63,
Subparts H and I
40 CFR Pan 264, Subpart BB
40 CFS Part 265, Snbpatt BB
     HEM
                                    REQUIREMENTS
Reporting
Requirements
Initial notification:
 «  name and address of owner/operator
 •  address of facility
 »  identification of subject processes
 •  compliance statement
 «  statement if a source can achieve compliance by applicable date

Notification of Compliance Status:
 •  process unit identification
 •  number of sampling connection systems, excluding those in vacuum service
 «  method of compliance

Subsequent semiannual reports:
 »  for each monitoring period during the 6 month period, the facts that explain any delay of repairs
    and, where appropriate, why a process unit shutdown was infeasible
 •  revisions to items reported in the initial notification of compliance status if the method of
    compliance has changed since the last report
 «  information listed under Notice of Compliance Status for process units with later compliance
    dates
                                     SAMPLING CONNECTION SYSTEMS
                                                                                 page C-94

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SURGE CONTROL VESSELS AND BOTTOM RECEIVERS
                   APPLICABLE REGULATIONS
40 CFR Part 60,
Subpait W

40 CFR Part 61,
Subparts J and V

                                   40 CFR Pan 63,
                                   Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB
ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
Recordkeeping
Requirements
REQUIREMENTS
Use of closed-vent system that routes the organic vapors either back to process or to compliant
control device
Comply with the requirements under §63.119(b) for fixed roofs with internal floating roofs or under
§63.119(c) for external floating roofs
N/A


Alternative means of emission limitation
Equipment in vacuum service
Equipment in organic HAP service fewer than 300 hours per year
Surge control vessels routed back to process
Surge control vessels that do not meet certain capacity and vapor pressure criteria^ see Tables 2 and 3
of Subpart H
N/A
N/A
N/A
Information to be kept for all equipment:
• list of ID numbers of subject equipment
• location of equipment on site plan, log entries, etc.
» ID of surge control vessels or bottoms receivers equipped with a closed vent system or control
device
Information and data used to demonstrate that equipment is not in organic HAP service or is in HAP
service fewer than 300 hours/year
          SURGE CONTROL VESSELS AND BOTTOM RECEIVERS
              page C-95

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                 SURGE CONTROL VESSELS AND BOTTOM RECEIVERS
                                       APPLICABLE REGULATIONS
      40 CFR Part 60,
        SubpartW
             40 CFR Part 61,
             Subparts J and V
40 CFR Part 63,
Snbparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB
     ITEM
                                  REQUIREMENTS
Reporting
Requirements
Initial notification:
 •  name and address of owner/operator
 «  address of facility
 •  identification of subject processes
 •  compliance statement
 »  statement if a source can achieve compliance by applicable date

Notification of Compliance Status:
 •  process unit identification
 »  number of each type of equipment, excluding those in vacuum service
 •  method of compliance

Subsequent semiannual reports:
 •  revisions to items reported in the Notification of Compliance Status if the method of compliance
    has changed since the last report
 *  Information listed in the Notice of Compliance Status for process units with later compliance
    dates
                            SURGE CONTROL VESSELS AND BOTTOM RECEIVERS
                                                                            page C-96

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VALVES IN GAS VAPOR AND LIGHT LIQUID SERVICE
                  APPLICABLE BEGULATIONS
40CFRPart60, 40CFRPart61, 40 CFR Part 63,
Subpart W Subparts J and V Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB
^^••B

ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
REQUIREMENTS
Phase I & II: Monitor each valve quarterly
Phase HI: Monitoring frequency based on percent valves found leaking:
Percent Leaking Monitoring Frequency
2% (or more) Monthly or QIP
<2% Quarterly
< 1 % Quarterly or once every 2 quarters
<0.5% Quarterly or once every 4 quarters
For existing sources:
• Phase I begins on compliance date
• Phase II begins no later than 1 year after compliance date
* Phase ffl begins no later than 2 1A years after compliance date
For new sources:
• Phase n begins after initial start-up
* Phase ffl begins no later than 1 year after initial start-up
Phase I: 10,000 ppm
Phase II: 500 ppm
Phase HE: 500 ppm

Alternative means of emission limitation
QIP for valves (Phase Iff)

Valves in vacuum service
Valves in organic HAP service fewer than 300 hours per year
Valves designated unsafe to monitor or difficult to monitor (at new facilities, maximum 3% of valves
may be designated as difficult to monitor)
Equipment located at plant sites with fewer than 250 valves is exempt from monthly monitoring;
instead monitor once per quarter or comply with percent leak requirements for < 1% or 0.5%, as
applicable
Method 21
» response factor criteria (excluding inerts) for average composition
* monitor all equipment while it is "in service"
of process fluid
         VALVES IN GAS/VAPOR AND LIGHT LIQUID SERVICE
page C-97

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                 VALVES IN GAS VAPOR AND LIGHT LIQUID SERVICE
                                       APPLICABLE REGULATIONS
     40CFRPatt60,
       SubpartW
             40CFRPart61»
             Subparts J and V
40 CFR Part 63,
Sutoaits H and I
40 CFR Part 264, Subpart BB
40 CFR Pan 265, Subpan BB
     ITEM
                                  REQUIREMENTS
Repair
Requirements
First attempt within 5 calendar days of detection

Repair as soon as practicable; no later than 15 days after detection

When repaired, monitor at least once within first 3 months of repair
Delay of Repair
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown

Allowed for equipment that is isolated from the process and that does not remain in organic HAP
service

Allowed if emissions of purged material from immediate repair would exceed fugitive emissions from
delay of repair, and purged materials are collected and destroyed or recovered in a control device
when repair occurs

Allowed beyond process unit shutdown if valve assembly replacement supplies are exhausted and had
been sufficiently stocked before supplies were depleted

Not allowed beyond second process unit shutdown unless third shutdown occurs sooner than 6 months
after first shutdown
                            VALVES IN GAS/VAPOR AND LIGHT LIQUID SERVICE
                                                                               page C-98

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                  VALVES IN GAS VAPOR AND LIGHT LIQUID SERVICE
                                          APPLICABLE REGULATIONS
      40 CFR Part 60,
        SubpartW
              40 CFR Part 61,
              Subparts J and ¥
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB
     ITEM
                                     REQUIREMENTS
Recordkeeping
Requirements
When leak detected:
 •  a weather-proof and readily visible identification, marked with the equipment ID number,
    attached to the leaking equipment
 •  ID may be removed after it has been repaired and monitored at least once within first 3 months
    of repair and no leak is detected

Information to be kept in log for 2 years after leak detected:
 •  instrument and equipment ID number and operator name, initials, or ID number
 «  date leak detected
 •  date of first attempt to repair leak
 »  maximum instrument reading after successful repair or if determined to be nonrepairable
 *  "repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection.
    The owner or operator may develop and  cite a written procedure that identifies conditions
    justifying a delay of repair
 •  documentation of sufficient supply of spare parts on-site before depletion and reason for
    depletion if repair delayed because stocked parts were depleted
 •  dates of process unit shutdown that occurred while the equipment is unrepaired
 »  date of successful repair of the leak
 *  copies of periodic reports (if database not capable of generating)

Information to be kept for all valves:
 •  list of ID numbers of subject valves
 •  location of valve on-site plan, log entries, etc.
 *  schedule by process unit for monitoring valves
 •  list of valves removed and added to a process unit after the compliance date if net credits for
    their removal are expected to be used

Information to be kept for difficult  to monitor valves:
 *  list of ID numbers
 «  explanation for designation
 »  planned  schedule  for monitoring

Information to be kept for unsafe to monitor valves:
 «  identification of equipment designated as unsafe to  monitor
 *  plan for monitoring

Information and data used to demonstrate that a valve is not in organic HAP service, is in HAP
service fewer than 300 hours/year,  or is in heavy liquid service
                              VALVES IN GAS/VAPOR AND LIGHT LIQUID SERVICE
                                                                                    page C-99

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                  VALVES IN GAS VAPOR AND LIGHT LIQUID SERVICE
                                         APPLICABLE REGULATIONS
      40 CFR Part 60,
        Subpart W
              40 CFR Part 61,
              Subparts J and V
40 Cm Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB
     ITEM
                                    REQUIREMENTS
Reporting
Requirements
Initial notification:
 •  name and address of owner/operator
 »  address of facility
 »  identification of subject processes
 •  compliance statement
 •  statement if a source can achieve compliance by applicable date

Notification of Compliance Status:
 »  process unit identification
 •  number of valves, excluding those in vacuum service
 •  method of compliance
 «  planned schedule for each phase

Subsequent semiannual reports:
 »  the following information for each monitoring period in the reporting period:
        number of valves for which leaks were detected
        total number of valves monitored
        the percent leakers for valves
        number of valves for which leaks were not repaired within 15 days after detection
        identification of the number of valves determined to be nonrepairable
        explanation of why repairs delayed and why a process unit shutdown was infeasible
    revisions to items reported in the initial compliance notice if the method of compliance has
    changed since the last report
    initiation of monthly monitoring under Phase 1H or QBP (if applicable)
    information listed in the Notice of Compliance Status for process units with later compliance
    dates
                             VALVES IN GAS/VAPOR AND LIGHT LIQUID SERVICE
                                                                                page C-100

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            CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                              APPLICABLE REGULATIONS
40 CFR Part 60,
  Subpart W
40 CFR Part 61,
Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CER Part 264, Subpart BB
40 CER Part 265, Subpart BB
ITEM
Basic Standard


































Leak Definition
Alternative
Standards
REQUIREMENTS
Control devices and closed-vent systems to be operated at all times that emissions may be vented to
them
Each piece of equipment shall be marked in such a manner to distinguish it readily from other pieces
of equipment
Applies to equipment containing or contacting hazardous waste with minimum organic concentrations
of 10% by weight
Control Devices:
» vapor recovery systems: 95 percent by weight or greater recovery unless total organic emission
limits of §265.1032(a)0) for all affected processes can be attained at an efficiency of less than 95
percent
• carbon adsorbers: carbon replacement intervals specified
• enclosed combustion devices (e.g., vapor incinerator, boiler, or process heater): 95 percent or
greater reduction, 20 ppmv total organic compound concentration, or minimum residence time of
0.50 seconds at a minimum temperature of 760 °C; boilers and process heaters: introduce vent
stream into flame combustion zone
• flares: basic requirements for visible emissions, heat content, exit velocities, and flare design;
flame present at all times
Closed- Vent Systems:
• designed to operate with no detectable emissions, indicated by instrument reading of less than
500 ppmv above background and by visual inspections; or
« designed to operate at a pressure below atmospheric pressure
Monitoring:
• Control devices:
» • monitor to ensure operated and maintained in conformance with their designs
* • specific requirements identified for vent stream flow monitors and other monitors for
specific types of control devices
• Closed-vent systems:
» • initial leak detection monitoring to demonstrate that closed-vent system operates with no
detectable emissions (<500 ppmv above background)
• » initial inspection to be performed on or before the system is subject to regulation
• • closed-vent system joints, seams or other connections that are permanently or semi-
permanently sealed shall be visually inspected at least once per year
« • components shall be monitored after repair or replacement or after connection is unsealed
• » closed-vent system components or connections (except those designated unsafe to monitor)
shall be monitored annually and at other times as requested by the Regional Administrator
No detectable emissions ( <500 ppm above background)
N/A

                      CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                                                          page C-101

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                    CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                                          APPLICABLE REGULATIONS
      40CFRPsrt60,
        Subpart W
              40 CFR Part 61,
              Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB
      ITEM
                                    REQUIREMENTS
Exemptions
Equipment which contains or contacts a hazardous waste of at least 10% by weight for a period of
fewer than 300 hours per year

Any components of a closed-vent system designated as unsafe to monitor are exempt from annual
monitoring if:
  »  monitoring personnel would be exposed to an immediate danger, and
  •  the owner or operator adheres to a written plan that requires monitoring as frequently as
    practicable during safe to monitor times
Monitoring
Method
Method 21 (closed-vent systems)

Specified monitoring procedures for control devices
Repair
Requirements
First attempt to repair within 5 calendar days of detection

Repair as soon as practicable; no later than 15 days after detection
Delay of Repair
Allowed if technically infeasible without process unit shutdown or if emissions from immediate repair
would be greater than fugitive emissions from delay of repair; required before end of next process
unit shutdown

Allowed for equipment that is isolated from the process and that does not remain in contact with
organic hazardous waste at least 10% by weight
Recordkeeping
Requirements
Information to be kept for each closed vent system and control device: (information to be maintained
in facility's operating record)
  •  equipment ID and hazardous waste management unit ID
  »  approximate location within facility on facility plot plan
  »  type of equipment
  *  percent by weight total organics in hazardous waste stream
  •  hazardous waste state at the closed-vent system and  control device
  •  method of compliance with the standard
  «  implementation schedule for installation and operation of closed-vent system and control device if
    unable to install and comply by the effective date of the rule
  •  performance test plan if using test data to demonstrate the organic removal efficiency or total
    organic compound concentration achieved by the closed-vent system and control device
    including:
    • •  description of how the test will be conducted when the hazardous waste management unit is
        operating at the highest load or capacity level reasonably expected to occur, including
        estimated or design flow rate and organic content of each vent stream and definition of
        acceptable operating ranges of key process and  control parameters during the test program

                                 (Continued on next page)
                               CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                                                                                 page C-I02

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                     CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                                          APPLICABLE REGULATIONS
      40 CFR Part 60,
        Subpart W
              40CERPart61,
              Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CKR Part 265, Subpart BB
     ITEM
                                     REQUIREMENTS
Recordkeeping
Requirements
(continued)
    • •  a detailed engineering description of the closed-vent system and control device including:
        • • •  manufacturers name and model number
        • « •  type of control device
        • » *  dimensions of control device
        • • •  capacity
        • « •  construction materials
    • •  a detailed description of sampling ami monitoring procedures, including location in the
        system, equipment used,  sampling and monitoring frequency and planned analytical
        procedures
 »  documentation of compliance with standard including detailed design documentation or
    performance test results specified in 264.1035(b)(4) and 265.1035(b)(4)
 •  design documentation and operating, monitoring, and inspection information for each closed vent
    system and control device as specified in 264.1035(c) and 265.1035(c); maintain for 3 years
 •  for control devices other than thermal vapor incinerators, catalytic vapor incinerators, flares,
    boilers,  process heaters, condensers, or carbon adsorption systems, monitoring and inspection
    information indicating proper operation and maintenance
 •  list of ID numbers for the closed vent systems and control devices
 »  list of ID numbers for equipment in  vacuum service
 •  identification, by list or location, of equipment that contains or contacts hazardous waste with an
    organic  concentration of at least 10% by weight for a period of less than 300 hours/year

Information to be kept for the purpose of determining exemptions;
 •  analysis determining the design capacity of the hazardous waste management unit
 *  statement listing the hazardous waste influent to and effluent from each hazardous waste
    management unit and an analysis determining whether these are heavy liquids
 •  up-to-date analysis and supporting information and data used to determine if equipment is subject
    to the requirements of the rule including supporting documentation required by 264.1063(d)(3)
    and 265.1063(d)(3). A new determination is required when the owner/operator takes any action
    that could result in an increase in the total organic content of the waste contained in or contacted
    by equipment previously determined not be subject

Information to be kept for unsafe to monitor closed-vent system and control device:
 »  identification of equipment designated as unsafe to monitor
 »  explanation stating why the closed-vent  system is unsafe to monitor
 •  plan for monitoring

In addition:
 •  Part 264 - for "other" control  devices - monitoring and inspection criteria indicating proper
    operation and maintenance of the control device will be determined by the Regional
    Administrator
                                CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                                                                                   page C-103

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                   CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                                       APPLICABLE REGULATIONS
     40CFRPait60,
       SubpaitW
             40GERPart61,
             Subparts J and V
40CFRPart63,
Subparts H and I
40 CER Part 264, Subpart BB
40 CFRPart 265, Subpart BB
     ITEM
                                  REQUIREMENTS
Reporting
Requirements
Semiannual report requirements:
 •  Part 265:
    • • None

 •  Part 264:*
    • • the EPA ID number, name and address of the facility
    • * dates of hazardous waste management unit shutdowns that occurred within the semiannual
       reporting period
    • • for each month during the semiannual reporting period, if any control device exceeded or
       operated outside design specifications and was not corrected within 24 hours, report the
       duration and cause of each exceedance, and any corrective measures taken

* If, during the semiannual reporting period, leaks from valves, pumps, and compressors are repaired
as required, and no control device exceeds or operates outside of design specifications for more than
24 hours, a report is not required.
                             CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                                                                             page C-I04

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                                  COMPRESSORS
40 CFR Part 60,
  Subpart W
                                APPLICABLE REGULATIONS
40 CFR Part 61,
Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Snbpart BB
ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
REQUIREMENTS
Equip with compliant seal system that includes a barrier fluid system that prevents leakage to
atmosphere
For each barrier fluid system:
• operate the barrier fluid at a pressure that is at all times greater than the pump stuffing box
pressure, or
• connect the barrier fluid degassing reservoir by a closed-vent system to a compliant control
device, or
• equip with a system that purges the barrier fluid into a hazardous waste stream with no detectable
emissions to the atmosphere Qess than 500 ppm above background)
The barrier fluid system must not be a hazardous waste with organic concentrations 10% or greater
by weight
Install sensor to detect failure of seal system, barrier fluid system, or both
Check sensor daily or equip with audible alarm that is checked monthly; if at unmanned plant site,
check sensor daily
Establish criteria that indicates failure of seal system, barrier fluid system, or both
Sensor indicates failure of seal system, barrier fluid system, or both based on established criteria
N/A
Equipment designated for no detectable emissions (less than 500 ppm above background) (see No
Detectable Emissions)
Equipment in vacuum service
Equipment equipped with closed vent system and control device capable of capturing and transporting
leakage from the seal to a compliant control device (see Closed-vent Systems and Control Devices)
Observation of sensor
Method 21 for no detectable emissions
First attempt within 5 calendar days of detection
Repair as soon as practicable; no later than 15 calendar days after detection
                                     COMPRESSORS
                                                             page C-105

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                                             COMPRESSORS
                                           APPLICABLE REGULATIONS
      40 CFR Part 60,
        Subpart W
               40 CFR Part 61,
               Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Pan 264, Subpart BB
40 CFR Part 265, Subpart BB
     ITEM
                                     REQUIREMENTS
Delay of Repair
Allowed if technically infeasible without hazardous waste management unit shutdown; required
before end of next waste management unit shutdown

Allowed for equipment that is isolated from the process and that does not remain in contact with
organic hazardous waste at least 10% by weight
Recordkeeping
Requirements
When leak detected:
  • a weather-proof and readily visible identification, marked with the equipment ID number and
    date leak was detected, attached to the leaking equipment
  • ID may be removed after it has been repaired

Information to be kept in log for 3 years after leak detected:
  « instrument and operator ID numbers and equipment ID number
  * date leak detected
  « dates of each attempt to repair leak
  • repair methods applied in each attempt to repair
  • "above  10,000" if maximum instrument reading after each repair attempt is a 10,000 ppm
  « "repair  delayed"  and reason for delay if leak not repaired within 15 calendar days after detection
  • signature of owner/operator whose decision it  was that repair could not be effected without a
    process shutdown
  « expected date of successful repair if leak is not repaired within the 15 days
  » date of successful repair of the leak

Information  to be kept for all compressors:
  « compressor ID number and hazardous waste management unit identification
  » approximate facility location
  » type of equipment
  • percent-by-weight of total organics in hazardous waste at the compressor
  » hazardous waste  state at the compressor
  * method  of compliance
  • list of ID numbers of subject compressors
  • list of ID numbers of compressors designated for no detectable emissions and signed by
    owner/operator
  • for each compliance test for compressors designated for no detectable emissions:
    * •  date conducted
    » •  background  level measured
    • •  maximum instrument reading
  » list of ID numbers for compressors in vacuum service
  » identification, by list or location, of equipment that contains or contacts hazardous waste with an
    organic  concentration of at least 10% by weight for a period of fewer than 300 hours per year

Information  to be kept for barrier fluid and seal systems:
  • design criteria for indicating failure
  « explanation for selected criteria
  • any changes to criteria and reasons for change

                                  (Continued on next page)
                                                COMPRESSORS
                                                                                   page C-106

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                                             COMPRESSORS
                                          APPLICABLE REGULATIONS
      40CFRPart60,
        Subpart W
              40CFRPart61,
              Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB
      ITEM
                                     REQUIREMENTS
Recordkeeping
Requirements,
continued
Information to be kept for the purpose of determining exemptions:
  •  analysis determining the design capacity of the hazardous waste management unit
  «  statement listing the hazardous waste influent to and effluent from each hazardous waste
    management unit and an analysis determining whether these are heavy liquids
  *  up-to-date analysis and supporting information and data used to determine if equipment is subject
    to the requirements of the rule including supporting documentation required by 264.1063(d)(3)
    and 265.1063(d)(3). A new determination is required when the owner/operator takes any action
    that could result in an increase in the total organic content of the waste contained in or contacted
    by equipment previously determined not be subject	
Reporting
Requirements
Semiannual report requirements:
  •  Part265:
    •»  None

  •  Part 264:*
    « •  the EPA ID number, name and address of the facility
    • •  for each month during the semiannual reporting period:
        * * *  the ID number for each compressor for which a leak was not repaired as required
        • • »  if control device for any compressor exceeded or operated outside of design
              specification and was not corrected within 24 hours, report the duration and cause of
              each exceedance, and any correction measures taken.
    • «  dates of hazardous waste management unit shutdowns that occurred within the semiannual
        reporting period

* If, during the semiannual reporting period, leaks from valves, pumps, and compressors are repaired
as required, and no control device exceeds or operates outside of design specifications for more than
24 hours, a report is not required
                                                COMPRESSORS
                                                                                   page C-107

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                     DUAL MECHANICAL SEAL SYSTEM
                              APPLICABLE REGULATIONS
40 CFR Part 60,
  SubpanW
40 CFR Part 61,
Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB
ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
REQUIREMENTS
For each dual mechanical seal system that includes a barrier fluid system:
• operate the barrier fluid at a pressure that is at all times greater than the pump stuffing box
pressure, or
* connect the barrier fluid degassing reservoir by a closed-vent system to a compliant control
device, or
• equip with a system that purges the barrier fluid into a hazardous waste stream with no detectable
emissions to the atmosphere (less than 500 ppm above background)
The barrier fluid system must not be a hazardous waste with organic concentrations 10% or greater
by weight '
Equip each barrier fluid system with a sensor that detects failure of the seal system, barrier fluid
system, or both
• check each sensor daily or equip with audible alarm; check audible alarm monthly to ensure it is
working
Visually inspect weekly for indications of liquids dripping from the pump seals
Establish criteria, based on design and operating experience, that indicates failure of the seal system,
barrier fluid, or both
Applies as an alternative to pumps in light liquid service
Indications of liquids dripping from the pump seal or sensor detection, based on failure criteria
N/A
Designated for no detectable emissions (less than 500 ppm above background) and if no externally
actuated shaft penetrates pump housing and pump is tested for compliance initially, annually, and at
other times requested by Administrator (see No Detectable Emissions)
Equipped with closed-vent system capable of capturing and transporting leakage from the seal(s) to a
compliant control device (see Closed-vent Systems and Control Devices)
Visual, sensor, criteria
First attempt within 5 calendar days of detection
Repair as soon as practicable; no later than 15 days after detection
                           DUAL MECHANICAL SEAL SYSTEM
                                                          page C-10S

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                              DUAL MECHANICAL SEAL SYSTEM
                                          APPLICABLE REGULATIONS
      40CFRPart60,
        Subpart W
              40 CER Part 61,
              Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB
     ITEM
                                     REQUIREMENTS
Delay of Repair
If repair requires use of a dual mechanical seal that includes a barrier fluid system and repair is
completed as soon as practicable but no later than 6 months after leak detected

Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown

Allowed for equipment that is isolated from the process and that does not remain in VOC service
Recordkeeping
Requirements
When leak detected:
  »  a weather-proof and readily visible identification, marked with the equipment ID number and
    date leak was detected, attached to the leaking equipment
  •  ID may be removed after it has been repaired

Information to be kept in inspection log for 3 years after leak detected:
  •  instrument ID; operator name, initials, or ID number; and equipment ID number
  «  date leak detected
  »  dates of each attempt to repair leak
  »  repair methods applied in each attempt to repair
  •  "above 10,000" if maximum instrument reading after each repair attempt is _>. 10,000 ppm
  «  "repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection
  »  signature of owner/operator whose decision it was that repair could not be effected without a
    hazardous waste management shutdown
  «  expected date of successful repair if leak is not repaired within the 15 days
  «  date of successful repair of the leak

Information to be kept for all dual mechanical seal systems:
  »  list of ID numbers of dual mechanical  seal systems
  •  list of ID numbers designated for no detectable emissions and signed by owner/operator
  «  for each compliance test for components designated for no detectable emissions:
    «•  dates conducted
    • •  background level measured
    • •  maximum instrument reading
  »  list of ID numbers of mechanical seal systems in vacuum service
  •  equipment ID number and hazardous waste management unit ID
  «  approximate facility location on facility plot
  «  type of equipment
  •  percent-by-weight of total organics in hazardous waste at the equipment
  »  hazardous waste state at the equipment
  »  method of compliance
  •  identification, by list or location, of equipment that contains or contacts hazardous waste with an
    organic concentration of at least 10% by weight for a period of fewer than 300 hours per year

Information to be kept for barrier fluid and seal systems:
  «  design criteria for radicating failure
  »  explanation for selected criteria
  •  any changes to criteria and reasons for change

                                   (Continued on next page)
                                      DUAL MECHANICAL SEAL SYSTEM
                                                                                    page C-109

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                              DUAL MECHANICAL SEAL SYSTEM
                                          APPLICABLE REGULATIONS
      40CFRPart60,
        Subpart W
              40CFRPart61,
              Subparts J and V
40eFRPart63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CPR Part 265, Subpart BB
     ITEM
                                     REQUIREMENTS
Recordkeeping
Requirements,
continued
Information to be kept for the purpose of determining exemptions:
  •  analysis determining the design capacity of the hazardous waste management unit
  »  statement listing the hazardous waste influent to and effluent from each hazardous waste
    management unit and an analysis determining whether these are heavy liquids
  •  up-to-date analysis and supporting information and data used to determine if equipment is subject
    to the requirements of the rule including supporting documentation required by 264.1063(d)(3)
    and 265.1063(d)(3).  A new determination is required when the owner/operator takes any action
    that could result in an increase in the total organic content of the waste contained in or contacted
    by equipment previously determined not to be subject
Reporting
Requirements
Semiannual report requirements:
  «  Part 265:
    • •  None

  •  Part 264:*
    • •  the EPA ID number, name, and address of the facility
    • •  by month in the reporting period, dates of hazardous waste management unit shutdowns that
        occurred
    • •  ID number for any pump not repaired on time

* If, during the semiannual reporting period, leaks from valves, pumps and compressors are repaired
as required and the control device does not exceed or operate outside of the design specifications for
more than 24 hours, no report to the Regional Administrator is required.
                                      DUAL MECHANICAL SEAL SYSTEM
                                                                                 page C-110

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                         NO DETECTABLE EMISSIONS
                               APPLICABLE REGULATIONS
40 CFR Part 60,
  Subpart W
40 CFR Pan 61,
Sabparts 1 and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB
ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
Recordkeeping
Requirements
REQUIREMENTS
Has an instrument reading of less than 500 ppm above background as measured by the methods
specified in 264.1063(c) and 265.1063(c)
Test for compliance initially upon designation, annually, and as requested by the Regional
Administrator
Applies as an exemption to:
• pumps (must have no externally actuated shaft penetrating the pump housing)
» valves in gas/vapor service or in light liquid service(must have no external actuating mechanism
in contact with the hazardous waste stream)
* compressors
Applies as basic standard for:
• closed-vent systems
« pressure relief devices in gas/vapor service
< 500 ppm above background
N/A >
N/A
Method 21
N/A
N/A
Information to be kept:
* list of ID numbers of equipment designated for no detectable emission and signed by
owner/operator
• for each compliance test for no detectable emissions:
* • date conducted
• « background level measured
• • maximum instrument reading
                               NO DETECTABLE EMISSIONS
                                                                                  pageC-111

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                              NO DETECTABLE EMISSIONS
                                    APPLICABLE REGULATIONS
     40 CFR Part 60,
       Subpart W
            40CFRPart61,
            Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB
     HEM
                               REQUIREMENTS
Reporting
Requirements
Semiannual report requirements:
 » Part 265:
   •«  None

 « Part 264:
   • •  None specific to no detectable emissions
                                   NO DETECTABLE EMISSIONS
                                                                       page C-112

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                       OPEN-ENDED VALVES OR LINES
                               APPLICABLE REGULATIONS
40CFRPart60,
  Subpart W
40CFRPait61,
Sabparts J and V
40CFRPart63,
Subparts H and I
40 CPR Part 264, Subpait BB
40 CFR Part 265, Su&part BB
ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
REQUIREMENTS
Use cap, blind flange, plug, or second valve to seal open end at all times except when operations
require flow through open end
Second valve: close valve on process fluid end prior to closing second valve
Double block and bleed system: bleed lines may remain open during operations that require venting
the line between the block valves but comply with basic standard at all other times
N/A
N/A
Equipment in vacuum service
N/A
N/A
N/A
                             OPEN-ENDED VALVES OR LINES
                                                           pageC-113

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                                OPEN-ENDED VALVES OR LINES
                                         APPLICABLE REOULATIONS
      40 CFR Part 60,
        Subpart W
              40 CFR Part 61,
              Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265. Subpart BB
     ITEM
                                    REQUIREMENTS
Recordkeeping
Requirements
Information to be kept for all open-ended valves or lines:
  »  equipment ID number and hazardous waste management unit identification
  •  approximate facility location
  •  type of equipment
  •  percent-by-weight of total organics in hazardous waste at the valve
  »  hazardous waste state at the valve
  •  method of compliance
  *  list of ID numbers of subject valves and lines
  »  list of ID numbers of equipment in vacuum service
  »  identification either by list or location of equipment that contains or contacts hazardous waste
    with an organic concentration of at least 10% by weight for a period of fewer than 300 hours per
    year

Information to be kept for the purpose of determining exemptions:
  •  analysis determining the design capacity of the hazardous waste management unit
  •  statement listing the hazardous waste influent to and effluent from each hazardous waste
    management unit and an analysis determining whether these are heavy liquids
  »  up-to-date analysis and supporting information and data used to determine if equipment is subject
    to the requirements of the rule including supporting documentation required by 264.1063(d)(3)
    and 265.1063(d)(3).  A new determination is required when the owner/operator takes any action
    that could result in an increase in the total organic content of the waste contained in or contacted
    by equipment previously determined not to be subject
Reporting
Requirements
Semiannual report requirements:
 «  Part 265:
    • •  None

 «  Part 264:
    • «  None specific to open-ended valves or lines
                                       OPEN-ENDED VALVES OR LINES
                                                                                 page C-114

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           PRESSURE RELIEF DEVICES IN GAS/VAPOR SERVICE
                               APPLICABLE REGULATIONS
40 CFR Part 60,
  SubpartW
40 CFR Part 61,
Snbparts J and V
40 CFR Pan 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB
ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
REQUIREMENTS
No detectable emissions (less than 500 ppm above background)
After each release return to no detectable emissions within 5 calendar days as indicated by monitoring
of the pressure relief device
No detectable emissions (< 500 ppm above background)
N/A
Pressure relief devices in vacuum service
Pressure relief device equipped with compliant closed-vent system and control device
Method 21
See basic standard
Allowed if technically infeasible without process unit shutdown; required before end of next
management unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in contact with
organic hazardous waste by 10% weight
                     PRESSURE RELIEF DEVICES IN GAS/VAPOR SERVICE
                                                          pageC-115

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                   PRESSURE RELIEF DEVICES IN GAS/VAPOR SERVICE
                                          APPLICABLE REGULATIONS
      40CFRI>ait60,
        Subpart W
              40CFRPart61,
              Subparts J and V
40CFRPart63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB
     ITEM
                                    REQUIREMENTS
Recordkeeping
Requirements
Information to be kept for all pressure relief devices:
  • pressure relief device ID number and hazardous waste management unit identification
  « approximate facility location
  * type of equipment
  • percent-by-weight of total organics in hazardous waste at the pressure relief device
  • hazardous waste state at the pressure relief device
  « method of compliance
  * list of ID numbers of subject pressure relief devices
  • list of ID numbers for pressure relief devices in gas/vapor service required to comply with "no
    detectable emissions"
  • for each compliance test for pressure relief devices designated for no detectable emissions:
    «» dais conducted
    * » background level measured
    • • maximum instrument reading
  * list of ID numbers for pressure relief devices in vacuum service
  » identification, either by list or location, of equipment that contains or contacts hazardous waste
    with an organic concentration of at least 10% by weight for a period of fewer than 300 hours per
    year

The following information shall be recorded in a log that is kept in the facility operating record for
use in determining exemptions:
  * analysis determining the design capacity of the hazardous waste management unit
  • statement listing the hazardous waste influent to and effluent from each hazardous waste
    management unit and an analysis determining whether these hazardous wastes are heavy liquids
  • up-to-date analysis and the supporting information and data used to determine whether or not
    equipment is subject to the requirements of the rule including supporting documentation required
    by 264,1063(d)(3) and 265.1063(d)(3),  A new  determination is required when the
    owner/operator takes any action that could result in an increase in the total organic content of the
    waste contained in or contacted by equipment previously determined not to be subject
    requirements
Reporting
Requirements
Semiannual report requirements:
  »  Part 265:
    • •  None

  »  Part 264:*
    • •  the EPA ID number, name and address of the facility
    • •  for each month during the semiannual reporting period:
        » » •  if control device for any pressure release device exceeded or operated outside of
              design specification and was not corrected within 24 hours, report the duration and
              cause of each exceedanee, and any correction measures taken,
        » » •  dates of hazardous waste management unit shutdowns that occurred within the
              semiannual reporting period

* If, during the semiannual reporting period, leaks from valves,  pumps, and compressors are repaired
as required, and no control device exceeds or operates outside of design specifications for more than
24 hours, a report is not required.
                              PRESSURE RELIEF DEVICES IN GAS/VAPOR SERVICE
                                                                                  pageC-116

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            PUMPS AND VALVES IN HEAVY LIQUID SERVICE, PRESSURE
                RELIEF DEVICES IN LIGHT LIQUID OR HEAVY LIQUID
                 SERVICE, AND FLANGES AND OTHER CONNECTORS
                                       APPLICABLE REGULATIONS
     40 CFR Part 60,
       Subpart W
             40 CFR Part 61,
             Subpaits J and V
40 CFR Pan 63,
Subparts H and I
40 CFR Part 264, Snbpart BB
40 CFR Part 265, Subpart BB
     ITEM
                                  REQUIREMENTS
Basic Standard
Monitoring of potential leaks within 5 calendar days of detection if evidence of potential leak is found
by visual, audible, olfactory, or other detection method
Leak Definition
10,000 ppm
Alternative
Standards
N/A
Exemptions
Equipment in vacuum service
Monitoring
Method
Method 21
Repair
Requirements
First attempt within 5 calendar days of detection

Repair as soon as practicable; no later than 15 days after detection
Delay of Repair
Allowed if technically infeasible without hazardous waste management unit shutdown; required
before end of next hazardous waste management unit shutdown

Allowed for equipment that is isolated from the process and that does not remain in contact with
organic hazardous waste of at least 10% by weight

Valves:
 «  Allowed if emissions of purged material from immediate repair would exceed fugitive emissions
    from delay of repair, and purged materials are collected and destroyed or recovered in a
    compliant control device when repair occurs
 •  Allowed beyond process unit shutdown if valve assembly replacement is necessary and otherwise
    sufficient supply of valve assembly replacements is exhausted
 •  Not allowed beyond next shutdown unless next unit shutdown occurs sooner than 6 months after
    first unit shutdown

Pumps:
 «  Repair requires use of dual mechanical seal system that includes barrier fluid and repair
    completed as soon as practicable but no later than 6 months after leak detected
             PUMPS AND VALVES IN HEAVY LIQUID SERVICE, PRESSURE RELIEF DEVICES M LIGHT
                 LIQUID OR HEAVY LIQUID SERVICE, AND FLANGES AND OTHER CONNECTORS          page C-l 17

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            PUMPS AND VALVES IN HEAVY LIQUID SERVICE, PRESSURE
                RELIEF. DEVICES IN LIGHT LIQUID OR HEAVY LIQUID
                  SERVICE, AND FLANGES AND OTHER CONNECTORS
                                       APPLICABLE REGULATIONS
40 CFR Part 60,
Subpart W

40 CFR Part 61,
Subparts J and V

40 CFR Part 63,
Subparts H and I

                                                                               40 CFR Part 264, Subpart BB
                                                                               40 CFR Part 265, Subpart BB
     ITEM
                                  REQUIREMENTS
Recordkeeping
Requirements
When leak detected:
 «  a weather-proof and readily visible identification, marked with the equipment ID number, date
    evidence of a potential leak found, and date leak detected, attached to the leaking equipment

Information to be kept in log for 3 years after leak detected:
 •  instrument and operator ID numbers and equipment ID number
 »  date evidence of potential leak found
 *  date leak detected
 »  dates of each attempt to repair leak
 »  repair methods applied in each attempt to repair
 •  "above 10,000" if maximum instrument reading after each repair attempt is a 10,000 ppm
 «  "repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection
 «  signature of owner/operator whose decision it was that repair could not be effected without a
    process shutdown
 *  documentation  supporting delay of repair of a valve
 »  expected date of successful repair if leak is not repaired within 15 days
 •  date of successful repair of the leak

Information to be kept for all equipment:
 •  equipment ID number and hazardous waste management unit identification
 »  approximate  facility location
 »  type of equipment
 •  percent-by-weight of total organics in hazardous waste at the equipment
 «  hazardous waste state at the equipment
 «  method of compliance
 •  list of ED numbers of subject equipment
 «  list of ID numbers for equipment in vacuum service
 *  identification, either by list or location, of equipment that contains or contacts hazardous waste
    with an organic content of at least 10% by weight for a period of less than 300 hours per year

Information to be kept for the purpose of determining exemptions:
 •  analysis determining the design capacity of the hazardous waste management unit
 »  statement listing the hazardous waste influent to and effluent from each hazardous waste
    management  unit and an analysis determining whether these  are heavy liquids
 •  up to date analysis and supporting information and data used to determine if equipment is subject
    to the requirements of the rule including supporting documentation required by 264.1063(d)(3)
    and 265.1063(d)(3). A new determination is required when  the owner/operator takes any action
    that could result in an increase in the total organic content of the waste contained in or contacted
    by equipment previously determined not to be subject
             PUMPS AND VALVES IN HEAVY LIQUID SERVICE, PRESSURE RELIEF DEVICES IN LIGHT
                 LIQUID OR HEAVY LIQUID SERVICE, AND FLANGES AND OTHER CONNECTORS          page C-l 18

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          PUMPS AND VALVES IN HEAVY LIQUID SERVICE, PRESSURE
              RELIEF DEVICES IN LIGHT LIQUID OR HEAVY LIQUID
               SERVICE, AND FLANGES AND OTHER CONNECTORS
                                  APPLICABLE REGULATIONS
     40 CFR Part 60,
      Subpart W
            40 CFR Part 61,
            Snbparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265. Subpart BB
    ITEM
                              REQUIREMENTS
Reporting
Requirements
Semiannual report requirements:
 •  Part 265:
    • •  None

 •  Part 264:*
    • «  the EPA ID number, name, and address of the facility
    • •  dates of hazardous waste management unit shutdowns that occurred within the semiannual
       period

* If, during the semiannual reporting period, leaks from valves, pumps, and compressors are repaired
as required, and no control device exceeds or operates outside of design specifications for more than
24 hours, a report is not required.
            PUMPS AND VALVES IN HEAVY LIQUID SERVICE, PRESSURE RELIEF DEVICES IN LIGHT
               LIQUID OR HEAVY LIQUID SERVICE, AND FLANGES AND OTHER CONNECTORS         page C-i 19

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PUMPS IN LIGHT LIQUID SERVICE
        APPLICABLE REGULATIONS
40CFRPart60,
SubpartW


ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
4QCFRPsrt61, 40CFRPart63,
Subparts J and V Subparts H and I


I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB
REQUIREMENTS
Non-dual mechanical seal pumps: Monitor monthly and conduct weekly visual inspections for
indications of liquids dripping from pump seal
10,000 ppm
Indications of liquids dripping from pump seal
No externally actuated shaft penetrating pump housing
Operate with no detectable emissions
Test for compliance upon designation, annually, and when requested by Regional Administrator
Pumps in vacuum service
Any pump equipped with a compliant closed-vent system and control device
Any pump equipped with a dual mechanical seal: specific operating and design requirements (see
Dual Mechanical Seal System)
Any pumps designated for no detectable emissions (less than 500 ppm above background) (see No
Detectable Emissions)
Method
21

First attempt within 5 calendar days of detection
Repair as soon as practicable; no later than 15 days after detection
Allowed if technically infeasible without hazardous work management unit shutdown; required before
end of next hazardous waste management unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in contact with
organic hazardous waste at least 10% by weight
Allowed if repair requires use of a dual mechanical seal system that includes a barrier fluid system
and repair is completed as soon as practicable, but not later than 6 months after leak detected
      PUMPS IN LIGHT LIQUID SERVICE
page C-120

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                               PUMPS IN LIGHT LIQUID SERVICE
                                          APPLICABLE REGULATIONS
      40 CFR Part 60,
        Snbpait W
              40CFRPart61,
              Subparts J and V
40 CFR Part 63,
Snbparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265. Subpart BB
     ITEM
                                     REQUIREMENTS
Recordkeeping
Requirements
When leak detected:
 «  a weather-proof and readily visible identification, marked with the equipment ID number and
    date leak detected, attached to the leaking equipment
 •  ID may be removed after it has been repaired

Information to be kept in log for 3 years after leak detected:
 »  instrument ID, operator ID, and equipment ID numbers
 •  date leak detected
 •  dates of each attempt to repair leak
 •  repair methods applied in each attempt to repair
 «  "above 10,000" if maximum instrument reading after each repair attempt is >, 10,000 ppm
 •  "repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection
 •  signature of owner/operator whose decision it was that repair could not be effected without a
    process shutdown
 •  expected date of successful repair if leak is not repaired within the 15 days
 *  date of successful repair of the leak

Information to be kept for all pumps:
 »  pump ID number and hazardous waste management unit identification
 •  approximate facility location
 •  type of equipment
 •  percent-by-weight of total organics in hazardous waste at the pump
 «  hazardous waste state at the pump
 »  method of compliance
 «  list of ID numbers of subject pumps
 «  list of ID numbers of pumps designated for no detectable emissions and signed by
    owner/operator
 •  for each compliance test for pumps designated for no delectable emissions:
    • •  date conducted
    • •  background level measured
    « •  maximum instrument reading
 »  list of ID numbers for pumps in vacuum  service
 *  identification, either by list or location, of equipment that contains or contacts hazardous waste
    with an organic concentration of at least  10% by weight for a period of fewer than 300 hours per
    year

Information to be kept for pumps equipped with dual mechanical seal:
 »  design criteria for indicating failure
 »  explanation for selected criteria
 •  any changes to the criteria, and reason for change
                                       PUMPS IN LIGHT LIQUID SERVICE
                                                                                  page C-121

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                               PUMPS IN LIGHT LIQUID SERVICE
                                          APPLICABLE REGULATIONS
      40 CFR Part 60,
        SubpartW
              40 CFR Part 61,
              Subpans J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart SB
40 CFR Part 265, Subpart BB
     ITEM
                                    REQUIREMENTS
Recordkeeping
Requirements,
continued
The following information shall be recorded in a log that is kept in the facility operating record for
use in determining exemptions:
  • an analysis determining the design capacity of the hazardous waste management unit
  » a statement listing the hazardous waste influent to and effluent from each hazardous waste
    management unit and an analysis determining whether these hazardous wastes are heavy liquids
  « an up-to-date analysis and the supporting information and data used to determine whether or not
    equipment is subject to the requirements of the rule including supporting documentation required
    by 264.1063(d)(3) and 265.1063(d)(3). A new determination is required when the
    owner/operator takes any action that could result in an increase in the total organic content of the
    waste contained in or contacted by equipment previously determined not to be subject.
Reporting
Requirements
Semiannual report requirements:
  «  Part 265:
    *   None

  •  Part 264:*
    » •  the EPA ID number, name and address of the facility
    • •  for each month during the semiannual reporting period:
        • • • the ID number for each pump for which a leak was not repaired as required
        *** if control device for any pump exceeded or operated outside of design specification
             and was not corrected within 24 hours, report the date, duration and cause of each
             exceedance, and any correction measures taken.
        « » » dates of hazardous waste management unit shutdowns that occurred within the
             semiannual reporting period

* If, during the semiannual reporting period, leaks from valves, pumps, and compressors are repaired
as required, and no control device exceeds or operates outside of design specifications for more than
24 hours, a report is not required.
                                      PUMPS IN LIGHT LIQUID SERVICE
                                                                                  page C-122

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                     SAMPLING CONNECTION SYSTEMS
                               APPLICABLE REGULATIONS
40CFRPart60,
  Subpart VV
40CFRPart61,
Subparts J and V
40 CFR Part 63,
Sabparts H and I
40 CFR Pan 264, Subpart BB
40 CFR Part 265, Subpart BB
ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
REQUIREMENTS
Equipped with closed-purge closed vent loop system or closed-vent system that returns the fluid to the
process, recycles the purged fluid to a compliant waste management unit, or sends it to a compliant
control device
N/A
N/A
Equipment in vacuum service
In-situ sampling systems
Sampling systems without purges
N/A
N/A
N/A
                            SAMPLING CONNECTION SYSTEMS
                                                           page C-123

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                              SAMPLING CONNECTION SYSTEMS
                                          APPLICABLE REGULATIONS
4QCFRPart60,
Subpart W

40CFRPart61,
Subparts J and V

40CFRPart63,
Subparts H and I

                                                                                     40 CER Part 264, Subpart BB
                                                                                     40 CFR Part 265, Subpart BB
     ITEM
                                     REQUIREMENTS
Recordkeeping
Requirements
Information to be kept for all sampling connections:
  * sampling connection system ID number and hazardous waste management unit identification
  « approximate facility location
  * type of equipment
  • percent-by-weight of total organics in hazardous waste at the sampling connection system
  » hazardous wastes state at the sampling connection system
  « method of compliance
  • list of ID numbers of sampling connection systems subject to the rule
  « list of ED number of equipment in vacuum service
  « identification, either by list or location, of equipment that contains or contacts hazardous waste
    with an organic concentration of at least 10% by weight for a period of fewer than 300 hours per
    year

Information to be kept for the purpose of determining exemptions:
  « analysis determining the design capacity of the hazardous waste management unit
  * statement listing the hazardous waste influent to and effluent from each hazardous waste
    management unit and an analysis determining whether these are heavy liquids
  • up-to-date analysis and supporting information and data used to determine if equipment is subject
    to the requirements of the rule including supporting documentation required by 264.1063(d)(3)
    and 26S.1063(d)(3). A new determination is required when the owner/operator takes any action
    that could result in an increase in the total organic content of the waste contained in or contacted
    by equipment and control devices previously determined not to be subject
Reporting
Requirements
Semiannual report requirements:
  •  Part 265:
    • •  None

  •  Part 264:*
    • •  the EPA ED number, name and address of the facility
    • •  for each month during the semiannual reporting period:
        • • •  if control device for any sampling connection system operated outside of design
              specification and was not corrected within 24 hours, report the duration and cause of
              each exceedance, and any correction measures taken
        • • •  dates of hazardous waste management unit shutdowns that occurred within the
              semiannual reporting period

* If, during the semiannual reporting period, leaks from valves, pumps, and compressors are repaired
as required, and no control device exceeds or operates outside of design specifications for more than
24 hours, a report is not required.
                                      SAMPLING CONNECTION SYSTEMS
                                                                                  page C-124

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           VALVES IN GAS/VAPOR AND LIGHT LIQUID SERVICE
                                APPLICABLE REGULATIONS
40CFRPart60,
  Subpart VV
40CFRPart61,
Sttbparts J and V
40CFRPart63,
Subparts H and I
40 CFR Part 264, Subptrt BB
40 CPRPart 265, Subpart BB
ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
REQUIREMENTS
Monthly monitoring
If valve does not leak for 2 consecutive months, may be monitored quarterly
If valve leaks, monitor monthly until no leak is detected for 2 consecutive months
10,000 ppm
Allowable percentage of valves leaking or skip period leak detection and repair
Valves in vacuum service
Valves designated for no detectable emissions (less than 500 ppm above background) (see No
Detectable Emissions)
No external activating mechanism in contact with hazardous waste stream; is tested for compliance
annually, initially, and as requested by the Regional Administrator
Valves designated unsafe to monitor: owner/operator follows with plan to monitor as frequently as
practicable during safe to monitor times
Valves designated as difficult to monitor at hazardous waste management units in operation prior to
June 21, 1990, and owner/operator follows written plan that requires monitoring of valves at least
once per calendar year
Method 21
First attempt within 5 calendar days of detection
Repair as soon as practicable; no later than 15 days after detection
                      VALVES IN GAS/VAPOR AND LIGHT LIQUID SERVICE
                                                            page C-125

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                  VALVES IN GAS/VAPOR AND LIGHT LIQUID SERVICE
                                         APPLICABLE REGULATIONS
      40 CFR Part 60,
        SubpanW
              40 CFR Part 61,
              Subparts J and V
40 CFR Part 63,
Subparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265, Subpart BB
     ITEM
                                    REQUIREMENTS
Delay of Repair
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown

Allowed for equipment that is isolated from the process and that does not remain in contact with
organic hazardous waste at least 10% by weight

Allowed if emissions of purged material from immediate repair would exceed fugitive emissions from
delay of repair, and purged materials are collected and destroyed or recovered in a compliant control
device  when repair occurs

Allowed beyond process unit shutdown if valve assembly replacement is necessary and otherwise
sufficient supply of valve assembly replacements is exhausted

Not allowed beyond next unit shutdown unless next unit shutdown occurs sooner than 6 months after
first unit shutdown
Reeordkeeping
Requirements
"When leak detected:
  •  a weather-proof and readily visible identification, marked with the equipment ED number and
    date leak detected, attached to the leaking equipment
  «  ID may be removed after it has been repaired and monitored for 2 successive months with no
    leaks detected during those two months

Information to be kept in log for 3 years after leak detected:
  •  instrument and operator ID numbers and equipment ID number
  «  date leak detected
  *  dates of each attempt to repair leak
  •  repair methods applied in each attempt to repair
  •  "above 10,000" if maximum instrument reading after each repair attempt is J>. 10,000 ppm
  •  "repair delayed* and reason for delay if leak not repaired within 15 calendar days after detection
  •  signature of owner/operator whose decision it was that repair could not be effected without a
    process shutdown
  »  documentation supporting delay of repair
  •  expected date of successful repair if leak is not repaired within the 15 days
  »  date of successful repair of the leak

Information to be kept for all valves:
  «  valve ID number  and hazardous waste management unit identification
  »  approximate facility location
  •  type of equipment
  *  percent-by-weight of total organics in hazardous waste at the valve
  •  hazardous waste state at the valve
  »  method of compliance
  •  list of ID numbers of subject valves
  *  list of ID numbers of valves designated for no detectable emissions and signed by owner/operator
  *  for each compliance test for valves designated for no detectable emissions:
    • •  date conducted
    • •  background level measured
    • •  maximum instrument reading
  	(Continued on next page)	
                              VALVES IN GAS/VAPOR AND LIGHT LIQUID SERVICE
                                                                                  page C-126

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                  VALVES IN GAS/VAPOR AND LIGHT LIQUID SERVICE
                                          APPLICABLE REGULATIONS
      40 CFR Part 60,
        SubpartW
              40 CFR Part 61,
              Subparts J and V
40 CFR Pan 63,
Sttbparts H and I
40 CFR Part 264, Subpart BB
40 CFR Part 265. Snbpart BB
     ITEM
                                    REQUIREMENTS
Recordkeeping
Requirements,
continued
  •  list of ID numbers for valves in vacuum service
  »  identification, either by list or location, of equipment that contains or contacts hazardous waste
    with an organic concentration of at least 10% by weight for a period of fewer than 300 hours per
    year

Information to be kept for unsafe or difficult to monitor valves:
  «  list of ED numbers
  •  explanation for designation
  «  planned schedule for monitoring

Information to be kept for valves complying with the skip leak detection and repair alternative
standards:
  •  schedule of monitoring
  *  percent of valves found leaking during each monitoring period

Information to be kept for the purposes of determining exemptions:
  •  analysis determining the design capacity of the hazardous waste management unit
  «  statement listing the hazardous waste influent to and effluent from each hazardous waste
    management unit and an analysis determining whether these are heavy liquids
  •  up-to-date analysis and supporting information and data used to determine if equipment is subject
    to the requirements of the rule including supporting documentation required by 264.1063(d)(3)
    and 265.1063(d)(3). A new determination is required when the owner/operator takes any action
    that could result in an increase in the total organic content of the waste contained in or contacted
    by equipment previously determined not to be subject
Reporting
Requirements
Semiannual report requirements:
  »   Part 265:                                                                   i
    • •  None

  •   Part 264:*
    • •  the EPA ID number, name and address of the facility
    • •  for each month during the semiannual reporting period:
        « • •  the ID number for each valve for which a leak was not repaired as required
        « • •  dates of hazardous waste management unit shutdowns that occurred within the
              semiannual reporting period

* If, during the semiannual reporting period, leaks from valves, pumps, and compressors are repaired
as required, and no control device exceeds or operates outside of design specifications for more than
24 hours, a report is not required.
                              VALVES IN GAS/VAPOR AND LIGHT LIQUID SERVICE
                                                                                   page C-127

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VALVES IN GAS/VAPOR AND LIGHT LIQUID SERVICE                 page C-128

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                                APPENDIX D

                          REGULATED EQUIPMENT1
  'Source: Handbook:  Control Techniques for Fugitive VOC Emissions from Chemical Process
Facilities, Chapter 3, EPA/625/R-93/005, Office of Research and Development, Cincinnati, OH,
45268, March 1994.

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                                        Chapters
                                Regulated Equipment
Equipment leak standards are designed to control
emissions of VOCs and VHAPs from regulated
equipment through the application of work practices
and equipment  practices. The work practice most
commonly applied to control equipment leaks is the
LDAR  program, which is discussed  in detail in
Section 2.2.4.2. Subsequent chapters address the
monitoring,    recordkeeping,    and    reporting
requirements of implementing  a LDAR program
under NSPS or NESHAP standards. In this chapter,
regulated equipment is reviewed to illustrate how
monitoring programs are applied to specific pieces
of equipment.

Equipment  practices  include the use of specific
types of components, equipment design standards
or specifications, and  operational  standards for
certain types of equipment Equipment practices are
evaluated using  performance standards that provide
a  basis  for monitoring  or  substantiating  the
effectiveness of such control practices. Equipment
practices, briefly summarized in Section 2.2.4.3, are
addressed in greater detail in this chapter.

A general set of equipment is covered  by all of the
equipment  leak standards. Some  equipment is
covered only by specific standards. For example,
product accumulator vessels are covered only by
the equipment leak standards for benzene. Also, the
vinyl chloride fugitive emission standards  cover
additional sources (loading and unloading lines,
agitators,  slip gauges, opening of equipment, and in-
process wastewater). Except for agitators, however,
the emissions from these sources generally are not
considered "equipment leaks." The equipment leak
standards also identify requirements for closed-vent
systems and control devices that may be used to
comply with the regulations.

3.1    Pumps
Pumps are  used extensively  in the SOCMI and
petroleum refinery industries, as well as in natural
gas processing plants,  for moving organic fluids.
The most widely used pump is the centrifugal pump.
Other types of pumps that also may be used are the
positive-displacement,   reciprocating  and  rotary
action, and special canned-motor and diaphragm
pumps (U.S. EPA, 1990).

Chemicals transferred by pumps can leak at the
point  of contact between the moving shaft and
stationary casing. To isolate the pump's interior from
the atmosphere, all pumps, except the seal-less
type (canned-motor and diaphragm), require a seal
at the point where the shaft penetrates the housing.
The most commonly used seals in these pumps are
packed and mechanical (U.S. EPA, 1980a).
       Pump stuffing box
                                     gland
Figure 3-1. Diagram of simple packed seal (U.S. EPA, 1980b).

3.1.1  Packed Seals
Packed seals can be used on both reciprocating  and
rotary action pumps. A packed seal consists of a
cavity ("stuffing box") in the pump casing filled with
special packing material that is compressed with a
packing gland to form a seal around the shaft.  A
simple packed seal is illustrated in Figure 3-1. To
prevent  buildup of frictional heat,  lubrication  is
required. A sufficient amount of liquid (either the
liquid" being pumped  or another liquid  that  is
injected)  must be allowed  to  flow between  the
packing and the shaft to provide the necessary
lubrication. If this packing and/or the shaft seal face
degrade after a period of usage, organic compounds
can leak to the atmosphere.
REGULATED EQUIPMENT
                                      page D-1

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3.1.2   Single Mechanical Seals
Mechanical seals, limited in  application to pumps
with rotating shafts, can be  single or dual. Basic
designs of mechanical seals vary, but all have a
lapped seal face between a stationary element and
a rotating seal ring (Ramsden, 1978). In a single
mechanical seal application,  the rotating-seal ring
and stationary element faces are lapped to a very
high degree of flatness to maintain contact over their
shared surface area (Figure 3-2). The faces are held
together by a combination of pressure supplied by a
spring and the pump  pressure transmitted through
the liquid that is being pumped. An  elastomer seals
the rotating face to the shaft.  The stationary face is
sealed to the stuffing box with another elastomer or
gasket. As with packed seals,  the faces  must be
lubricated: however,  because  of  the mechanical
seafs construction, much less lubrication is needed.
Again, if the seal  becomes imperfect because of
wear, the organic  compounds being  pumped can
teak between  the seal faces and can be emitted to
the atmosphere.
                  lwM gasket
     Pump stuffing
     box"
                                      Gland ring
                                      Insert packing

                                       Stationary
                                         ft'HMH
                                         'Posstefe
Figure 3-2.  Diagram of basic single mechanical seal (U.S.
           EPA, 1980b).
3.1.3   Dual Mechanical Seals
Dual mechanical seals (Figure 3-3) can be arranged
back to back, in tandem, or face to face. In the back-
to-back arrangement, the too seals form a closed
cavity. A barrier fluid, such as water or seal oil, is
circulated through the  cavity. Because  the barrier
fluid surrounds the dual seal  and lubricates both
sets of seal faces, the heat transfer and seal  life
characteristics of this dual seal are much  better than
those of the single seal. In order for the seal to
function, the barrier fluid "must be at a pressure
greater than the operating pressure of the stuffing
box. As a result, some barrier fluid will leak across
the seal faces. Liquid leaking across the inboard
face will enter the stuffing box and  mix with the
process liquid.  Barrier fluid  going  across  the
outboard face will exit to the atmosphere. Therefore,
the barrier fluid must be compatible with the process
liquid and with the environment (Ramsden, 1978, p.
99).
                 SwlitqukJ
                 out (top)
Swliquia
in (bottom),
                                          Gland
Possfetotaak
into ww ling
fluid
                                                    Fluid and
                 I/
                 Primary
                 seal
     Seconclay
     seat
              Back-to-Back Arrangement

                       Seal liquid
                       Out   in
                       (Up)  (bottom)
                                                                                            Gland
                                                                                            plate
                            \/
      Primary seal       Secondary seal

               Tandem Arrangement

Figure 3-3.  Typical arrangements of dual mechanical
          pump seals (U.S. EPA, 1984).
REGULATED EQUIPMENT
                                        page D-2

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In a tandem dual mechanical seal arrangement, the
seals face the same direction, and the secondary
seal provides a backup for the primary seal. A seal
flush is used In the stuffing box to remove the heat
generated by friction. As with the back-to-back seal
arrangement, the cavity between the two tandem
seals is filled with a barrier fluid. The barrier fluid,
however,  is at a pressure  lower than  that in the
stuffing box. Therefore, any leakage will be from the
stuffing box into the seal cavity containing the barrier
fluid. Since this liquid is routed to a closed reservoir,
process liquid that leaks into the seal cavity also will
be transferred to the reservoir. At the reservoir, the
process liquid could vaporize and be emitted to the
atmosphere. To ensure that VOCs or VHAPs do not
leak from the reservoir, the reservoir can be vented
to a control device.

Another arrangement of dual seals is face to face. In
this configuration, two rotating faces are mated with
a common stationary barrier. Barrier fluid may be
provided at higher or lower pressures than in the
stuffing box. As in the tandem arrangement,  if the
barrier fluid is at a lower pressure than in the stuffing
box, the barrier fluid  reservoir may require venting to
a control device.

3.1.4   Seal-less Pumps
The seal-less pump includes canned-motor and
diaphragm pumps. In canned-motor pumps (Figure
3-4), the cavity housing, the  motor rotor, and the
pump  casing are interconnected. As a result, the
motor bearings run in the process  liquid  and all shaft
         Discharge
                      . Coolant ejrcuiatngwCe
                    ] /  SMortinar
 Suction
seals are eliminated. Because the process liquid is
the bearing  lubricant, abrasive solids cannot be
tolerated. Canned-motor pumps are used widely for
handling organic  solvents, organic heat transfer
liquids,  light oils, and many toxic or hazardous
liquids. Canned-motor pumps also are used when
leakage is an economic problem (Perry and Chilton,
1978, p. 6-8).

Diaphragm pumps (Figure 3-5) perform similarly to
piston and  plunger  pumps. The driving member,
however, is a flexible diaphragm fabricated of metal,
rubber,  or plastic. The primary  advantage of this
arrangement is that no packing and shaft seals are
exposed to the process liquid, which is an important
asset when handling hazardous or toxic liquids.
Diaphragm
          Impeller
Figure 3-4.  Diagram of seal-less canned-motor pump (U.S.
          EPA, 1990, P. 2-11).
Figure 3-5.  Diagram of diaphragm pump (U.S. EPA, 1990,
          p. 2-13),

3.2    Compressors
In the industries affected by  these standards,
centrifugal, reciprocating, and rotary compressors
are used.  The  centrifugal  compressor uses  a
rotating element or  series of elements containing
curved blades to increase the pressure of a gas by
centrifugal   force.   Reciprocating   and   rotary
compressors increase pressure by confining the gas
REGULATED EQUIPMENT
                                       page D-3

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     Pen tray b««ao»d
 Internal
 gat pretture

     Atmosphere

                    Labyrinth Seal
                                                             Port may be
                                                             added for
                                                             sealing
                                                           Internal
                                                           gas
                                                           pressure
                                                                         Restrictive Ring Seal
    Internal
    gac pressure
Clean oil in

   Pressure
   breakdown
   sleeve
          Stanonaryseat

                  Carbon ring
                                                                                   Clean oil in
                                     Atmosphere
                  Contaminated
                  oil out
                               Corfta'itffnated
                               oil out
Oil out
                Single Mechanical Seal
                                     Liquid Film Seal
              Figure 3-6. Typical designs of mechanical compressor seals (Ramsden, 1978, p.99).
REGULATED EQUIPMENT
                                                               page D-4

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in a cavity and progressively decreasing the volume
of the cavity. Reciprocating compressors usually use
a piston  and cylinder arrangement,  while  rotary
compressors use rotating elements such as lobed
impellers or sliding vanes.

As  with  pumps, seals  are  required  to prevent
leakage from compressors.  Rotary shaft seals for
compressors may be labyrinth,  restrictive carbon
rings, mechanical contact, or liquid film. Figure 3-6
is an illustration of typical designs of these four
types of seals. All of these seals are leak restriction
devices,  but none  of them  completely eliminates
leakage. To respond to leakage, many compressors
are equipped  with  ports in  the  seal area that
evacuate collected gases.

3.2.1  Labyrinth
The labyrinth seal is composed of a series of close
tolerance, interlocking "teeth" that restrict the flow of
gas  along  the  shaft. Many variations in  "tooth*
design and materials of construction are available.
Although  labyrinth seals as a group have the largest
leak potential of the different types, properly applied
variations in tooth configuration and  shape can
reduce leakage by up to 40 percent over a straight-
pass-type labyrinth (Nelson,  1977).

3,2.2  Carbon Rings
Restrictive  carbon  ring  seals consist of multiple
stationary carbon rings with close shaft clearances.
These seals may be operated dry with a sealing fluid
or with a buffer gas. Restrictive ring seals can
achieve lower leak rates than can the labyrinth type.

3.2.3  Mechanical
Mechanical contact seals are a common type of seal
for rotary compressor shafts and are similar to the
mechanical seals described  for pumps. In this type
of seal, the clearance  between  the  rotating and
stationary elements is reduced to zero, and oil or
another suitable lubricant is supplied  to the seal
faces. Mechanical seals can achieve the lowest leak
rates of the types discussed here, but they are not
suitable for all processing.

3.2.4  Packed
Packed seals are used for reciprocating compressor
shafts. As with pumps,  the packing in me stuffing
box  is compressed with a  gland  to form a seal.
Packing used on reciprocating compressor shafts is
 often of the "chevron" or netted V type. To ensure
 operating safety, the area between the compressor
 seals and the compressor motor (distance piece)
 normally is enclosed and vented outside of the
 compressor building. If hydrogen sulfide is present
 in the  gas,  then the vented  vapors  are flared
 normally.

 Reciprocating  compressors  can use  a metallic
 packing plate and nonmetallic partially compressible
 material (i.e., Graffbil, Teflon) or oil wiper rings to
 seal shaft  leakage  to  the  distance piece.
 Nevertheless, some leakage into the distance piece
 may occur.

 3.2.5  Liquid Film Seals
 In addition to having seal types like those used for
 pumps, centrifugal compressors can be equipped
 with a liquid-film seal. The seal is a film oil that flows
 between the rotating shaft and the stationary gland.
 The oil  that leaves the  compressor  from  the
 pressurized  system side  is  under the  system
 internal gas pressure and is contaminated with the
 gas. When this contaminated oil is returned to the
 open oil reservoir, process gas and entrained VOCs
 and VHAPs can be released to the atmosphere.

 3.3   Pressure Relief Devices
 Engineering  codes require the use of pressure-
 relieving devices or systems in applications where
                                         Disc
Figure 3-?.
Diagram of a spring-loaded relief valve (U.S.
EPA, 1990, p.2-16).
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the process pressure may exceed the maximum
allowable working  pressure  of the vessel.  The
pressure relief valve is the most common type of
pressure-relieving  device  used. Typically,  relief
valves  are  spring-loaded  (see Figure 3-7)  and
designed to  open when  the  system pressure
exceeds a set pressure, allowing the release  of
vapors  or liquids until the  system  pressure  is
reduced to its normal operating level. When tfie
normal  pressure is re-attained, the valve reseats,
and a seal is again formed. The seal is a disc on a
seat,  and a leak through this  seal is a potential
source of VOC and VHAP fugitive  emissions.  The
potential causes of leakage from relief valves are
"simmering or popping" (a condition  that occurs
when the system pressure comes close to the set
pressure of the valve); improper reseating of the
valve after a relieving operation; and corrosion  or
degradation  of the valve seat  (U.S. EPA, 1980a, p.
3-3).

Rupture discs also may be used to relieve pressure
fn process units (see Figure 3-8). These discs are
made of a material  that  ruptures when  a set
pressure Is exceeded, thus allowing the system to
depressurize.  The advantage of a rupture disc is
that the disc seals tightly and does not allow any
 To
 Atmospheric
 vent
    „_    Seat
   ft PrrauranM
  J.2H2-,	—EH
   i Hutmnaae  tff
Figure 3-8.
                 Rupture disc
                            Prom system
          Typical design of a pressure  relief  valve
          mounted on a rupture disc device (Ramsden,
          1978, p.99)
                                                 VOC or VHAP to escape from the system during
                                                 normal  operations.  When   the  disc  ruptures,
                                                 however,   the system will  depressurize  until
                                                 atmospheric  conditions are obtained, unless the
                                                 disc is used with a pressure relief valve.

                                                 3.4    Sampling Connections
                                                 Process unit operations are checked periodically by
                                                 routine  analysis of  feedstocks and products.  To
                                                 obtain representative samples for these analyses,
                                                 sampling lines first must be purged.  If the flushing
                                                 liquid is not controlled, it could be drained onto the
                                                 ground  or into a process  drain where it would
                                                 evaporate  and release VOCs or VHAPs to the
                                                 atmosphere. Closed-loop sampling systems control
                                                 the purged process fluid by returning it directly to
                                                 the process line, collecting and recycling the fluid, or
                                                 transporting tiie fluid to a control device. These
                                                 sampling system controls typically allow zero VOC
                                                 or VHAP emissions to the atmosphere. Two closed-
                                                 loop sampling systems are illustrated in Figure 3-9.
                                                              Process line
                                                                     O
Process line
       a-
                                                                                        Sample
                                                                                        container
                                                 Figure 3-9.
                                                              Sample
                                                              container
                                                            Diagram of two closed-loop sampling systems
                                                            (Ramsden, 1978, p. 99).
                                                 3.5    Open-ended Lines or Open Valves
                                                 Some valves are installed in a system so that they
                                                 function with the downstream line open  to the
                                                 atmosphere.  Open-ended  lines, which are used
                                                 mainly  in intermittent service for  sampling and
                                                 venting, include purge, drain,  and sampling lines.
                                                 Some open-ended lines are needed to preserve
                                                 product  purity.  Normally,  these  are  installed
                                                 between multi-use product lines to prevent products
                                                 from collecting in cross-tie lines during valve seat
                                                 leakage. A faulty valve seat or incompletely closed
                                                 valve would result in  leakage  through the valve,
                                                 releasing fugitive VOC or VHAP emissions to the
                                                 atmosphere.
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Operational requirements specify that open-ended
valves or lines be equipped with a cap, blind flange,
plug, or second valve. The purpose of the cap, blind
flange, plug, or second valve is to seal the open end
at all times,  except during  operations requiring
process fluid flow through the open-ended  valve or
line.

If a second valve is used, the open-ended line or
valve is to be operated so that the valve on  the
process fluid end is closed before the second valve
is  closed. If a double  block-and-bleed  system is
being used, the bleed valve or line may remain open
during operations that require  venting the line
between the block  valves. At all other times,  the
open end of the bleed valve or line  must be sealed
(again, except during operations requiring  process
fluid flow through the open-ended line or valve).

3.6    Process Valves
One of the most common pieces of equipment
affected by these standards  is the process valve.
Commonly used types are control, globe, gate, plug,
ball, relief, and check valves (see Figures 3-10 and
3-11). All  except the relief valve (see Section 3.3)
and check valve are activated  through a valve stem,
which may have either a rotational or linear motion,
depending on the design. The valve stem  requires
a seat to  isolate the process fluid inside the valve
from  the  atmosphere. The  possibility  of a  leak
through this  seal makes  it a potential  source of
fugitive emissions. Since a check valve has  no stem
or subsequent packing  gland, it is not considered a
potential source of fugitive emissions.

The stem can be sealed to prevent leakage  by using
a packing gland or O-ring seals. Valves that require
the stem to move in and out with  or without rotation
must use a packing gland. Conventional  packing
glands  are suited for  a wide variety of  packing
material. The most common  are various types of
braided asbestos that contain  lubricants. Other
packing   materials   include   graphite,  graphite-
impregnated fibers, and tetrafluorethylene polymer.
The packing material used depends on the valve
application and configuration. These conventional
packing  glands can be used  over a range  of
operating temperatures, but at high pressures, these
glands must be quite  tight to obtain a good seal
(Templeton, 1971).
               Handwheel
Packing
nut
  Body
         Disc
                  Seat
Figure 3-10. Diagram of a globe valve
          with a packed seal (U.S.
          EPA, 1980b).
                            Powntal
                            leak areas
                                                                   Ball
                                                      Figure 3-11.  Diagram of a ball valve (U.S. EPA, 1990,
                                                                 p. 2-21).
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                                Stem
                                       Bellows
Figure 3-12. Diagram of a sealed bellows valve (U.S. EPA,
          1990, p. 2-23).
                                                  Diaphragm
                                                 Figure 3-14.
               Diagram of a bonnet diaphragm seal (U.S.
               EPA, 1990, p. 2-24).
    Figure 3-13. Diagram of a weir diaphragm seal
              (U.S. EPA, 1990, p. 2-24).
Elastomeric  O-rings  also  are used  for  sealing
process  valves.  These  O-rings  provide  good
sealing, but are not suitable if sliding motion occurs
through the packing gland. These  seals are used
rarely  in  high pressure service,  and  operating
temperatures are limited by the seal material.

Bellows seals  are  more effective for preventing
process fluid leaks than is the conventional packing
gland or any other gland-seal arrangement This
type of seal incorporates a formed metal  bellows
that makes a barrier between the disc and body
bonnet joint (see Figure 3-12). The bellows is the
weak point of this type of system, and service life
can be quite variable. Consequently,  this type of
seal normally is  backed up with  a conventional
packing gland and often is fitted with a leak detector
in case of failure.

A diaphragm may be used to isolate  the working
parts of the valve and the environment from the
process liquid. Illustrated in Figures 3-13 and 3-14
are two types of diaphragm seals. The diaphragm
also may be used to control the flow of the process
fluid. In  this design, a  compressor  component
pushes the diaphragm toward the valve  bottom,
throttling the flow. The diaphragm and  compressor
are connected in a manner so that separating them
is impossible  under  normal working   conditions.
When the diaphragm reaches the valve bottom, it
seats firmly against the bottom, forming  a leak-proof
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seal. This configuration is recommended for fluids
containing solid particles and for medium-pressure
service. Depending on the diaphragm material, this
type of valve can be used at temperatures up to
2Q5°C and in severe acid solutions. If the seal fails,
however,  a valve using a diaphragm seal can
become a source of fugitive, emissions  (Pikulik,
1978, pp. 3-23 and 3-24).

3.7     Flanges and Other Connectors
Flanges are bolted, gasket-sealed junctions  used
wherever pipes or other equipment such as vessels,
pumps, valves, and heat exchangers  may require
isolation or removal. Connectors  are all  other
nonwelded fittings that serve a similar purpose to
flanges, which also allow bends  in pipes (elbows),
joining  two pipes (couplings), or joining  three or tour
pipes (tees or crosses). Connectors  typically are
threaded.

Flanges may become fugitive emissions  sources
when leakage occurs because of improperly chosen
gaskets or poorly assembled flanges.  The primary
cause  of flange leakage is thermal stress, which
causes deformation of the seal between the flange
faces. Threaded connectors may  leak if the threads
become damaged or corroded or if tightened without
sufficient lubrication or torque. LDAR programs are
the principal control technique for flanges and other
connectors.

3.8     Product Accumulator Vessels
The  background  information document  for the
proposed  benzene standards (U.S. EPA. 1980b)
states  that product accumulator vessels include
overhead  and  bottoms receiver vessels used with
fractionation columns and product separator vessels
used  in series with  reactor vessels  to separate
reaction products. Accumulator vessels  can be
vented  directly to the atmosphere  or indirectly
through a blowdown drum or vacuum system. When
an accumulator vessel contains benzene and vents
to the atmosphere, benzene emissions can occur.
This equipment is covered only by the benzene
equipment leak standards.

The  benzene  standards  require  each  product
accumulator vessel to be equipped with a closed-
vent system capable of capturing and  transporting
any leakage from the vessel to a control device.
Acceptable control devices include vapor recovery
systems, enclosed combustion devices, or flares.
These control systems are described in Section
3.10.

3.9    Agitators
Agitators are used to stir or blend chemicals. Like
pumps  and  compressors,  agitators  may leak
organic chemicals at the point where the shaft
penetrates  the casing. Consequently, seats are
required to minimize fugitive emissions. Four seal
arrangements commonly  are used with agitators:
compression  packing  (packed seal), mechanical
seals, hydraulic seals, and lip seals. Packed seals
for  agitators  are very  similar  in  design and
application to packed seals for pumps (Ramsey and
Zoller, 1976).

Although mechanical seals are more costly than the
other three types of  seals, they  offer a .greatly
reduced leakage  rate to  offset their higher cost.
Furthermore,   the  maintenance  frequency  of
mechanical seals is one-half to one-fourth that of
packed seals. At pressures greater than 1,140 kPa
(150  psig),  the leakage  rate  and  maintenance
frequency are so  superior that the use of packed
seals on agitators is rare. As with packed seals, the
mechanical seals for agitators are similar in design
and application to the mechanical seals for pumps.

The hydraulic seal, which  is the simplest and least
used  agitator shaft  seal,  has an  annular cup
attached to the process vessel that contains a liquid
that is in contact with an inverted cup attached to
the rotating agitator shaft. The primary advantage of
this seal is that it is a noncontact seal.  Use of this
seal,  however, is  limited to low temperatures and
pressures and very small  pressure fluctuations. In
addition, organic chemicals may contaminate the
      liquid  and   then   be released  into  the
atmosphere as fugitive emissions.

A lip seal can be used on a top-entering agitator as
a dust or vapor seal. The sealing element is  a
spring-loaded  elastomer.  Lip seals are relatively
inexpensive and easy to install. Once the seal has
been  installed,  the  agitator  shaft  rotates  in
continuous contact with the lip seal. Pressure limits
of the seal are 2  to 3 psig because it operates
without lubrication, and operating temperatures are
limited by  the  characteristics  of the  elastomer.
Fugitive. emissions can be released through this
seal  when the seal  wears excessively  or  the
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operating pressure surpasses the pressure limits of
the seal,

3.10   Closed-Vent Systems and Control
Devices
A closed-vent system can be used to collect and
dispose of gaseous VOC emissions from seal oil
degassing  vents,  pump -and compressor  seal
leakage, relief  valve leakage,  and  relief valve
discharges because of over-pressure operation. A
closed-vent system consists of piping connectors,
flame arresters,  and, if  necessary, flow-inducing
devices. Closed-vent systems are  designed  and
operated so that all VOC emissions are transported
to  a control  device without  leakage to  the
atmosphere.

Several types of control devices can be used to
dispose of VOC and VHAP emissions captured in
the  closed-vent  system.  Incineration,  carbon
adsorption, and  condensation are three control
methods  that  typically   are applied.  Control
efficiencies of the three methods are dependent on
specific operating characteristics and the types of
emissions being generated.  Typically,  enclosed
combustion devices (boilers, process heaters, and
thermal and catalytic incinerators)  can achieve
better than 95 percent destruction efficiencies. The
key parameters affecting destruction efficiency are
residence time and temperature. Carbon adsorption
systems can achieve 95 to  99 percent control
efficiency through  proper design  and operation,
white condensation systems can achieve capture
efficiencies of 90 percent or more.

Flares commonly found at plants subject to these
standards include steam-assisted, air-assisted, non-
assisted, ground, and dual-flare systems. Certain
flares have demonstrated  destruction efficiencies
equal to those  of  enclosed combustion devices
provided certain design specifications (heat content
and exit velocity) are met (U.S. EPA, 1985).

3.11   References
When an NTIS number is cited in a reference, that
document is available from:

   National Technical Information Service
   5285 Port Royal Road
   Springfield, VA 22161
   703-487-4650
Nelson, W.E. 1977. Compressor seal fundamentals.
   Hydrocarbon    Processing    56(12):91-95.
   December.

Perry,  R.H.  and C.H.  Chitton.  1978.  Chemical
   Engineer's Handbook, 5th Edition. McGraw-Hill
   Book Company,  New York, NY. pp. 6-8.

Pikulik,  A.  1978.  Manually  operated  valves.
   Chemical Engineering 85(7):121. April 3. pp. 3-
   23, 3-24.

Ramsden, J.H.  1978. How to choose and install
   mechanical  seals.   Chemical  Engineering
   85(22):97-102. October 9.

Ramsey, W.D.  and G.C. Zoller. 1976. How the
   design of shafts, seals and impellers affects
   agitator performance.  Chemical Engineering
   83(18): 101-108. August 30.

Templeton, H.C. 1971. Valve installation, operation
   and   maintenance.   Chemical  Engineering
   78(23):141-149.  October 11.

U.S. EPA. 1990. U.S.  Environmental Protection
   Agency. Inspection techniques for fugitive VOC
   emission   sources:  Course   module  5380.
   Student's    manual.    EPA-340/1-90-026a.
   Washington,  DC. September.

U.S. EPA. 1985. U.S.  Environmental Protection
   Agency.   Polymer   manufacturing  industry:
   Background information for proposed standards.
   EPA-450/3-83-019a.    NTIS   PB88-114996.
   Research Triangle Park, NC. September.

U.S. EPA. 1984. U.S.  Environmental Protection
   Agency Fugitive VOC emissions in the synthetic
   organic chemicals manufacturing industry.  EPA-
   625/10-84-004.  Research Triangle Park, NC,
   and Cincinnati, OH. December.

U.S. EPA. 1980a. U.S.  Environmental Protection
   Agency. VOC fugitive emissions  in synthetic
   organic  chemicals  manufacturing   industry:
   Background information for proposed standards.
   EPA-450/3-80-033a.    NTIS   PB81-152167.
   Research Triangle Park, NC. November.
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U.S. EPA. 1980b. U.S. Environmental Protection
   Agency.    Benzene    fugitive    emissions:
   Background information for proposed standards.
   EPA-450/3-80-032a.    NTIS    PBS 1-151664.
   Research Triangle Park, NC. November.
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         APPENDIX E




METHOD 21 {40 CFR 60, APPENDIX A)

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        EMISSION MEASUREMENT TECHNICAL INFORMATION CENTER
                            NSPS TEST METHOD
                             (EMTICM-21, 2/9/93)

        Method 21 - Determination of Volatile Organic Compound Leaks

1.  APPLICABILITY AND PRINCIPLE

1,1  Applicability. This method applies to the determination of volatile organic compound
(VOC) leaks from  process equipment.   These sources include, but are not limited to,
valves, flanges and other connections, pumps and compressors, pressure relief devices,
process drains, open-ended valves, pump and compressor seal system degassing vents,
accumulator vessel vents, agitator seals, and access door seals,

1.2  Principle. A portable instrument is used to detect VOC leaks from individual sources.
The instrument detector type is not specified, but it must meet the specifications and
performance criteria contained in Section 3. A leak definition concentration based on a
reference compound is specified in each applicable regulation. This procedure is intended
to locate and classify leaks only, and is not to  be used  as a direct measure of mass
emission rate from individual sources.

2.  DEFINITIONS

2.1   Leak Definition Concentration. The local VOC concentration at the surface of a
leak source that indicates that a VOC emission (leak) is present,  The leak definition is an
instrument meter reading based on a reference compound.

2.2 Reference Compound. The VOC species selected as an instrument calibration basis
for specification  of the leak definition concentration. (For example, if a leak definition
concentration is 10,000 ppm as methane, then any source emission that results in a local
concentration that yields a meter reading of 10,000 on an instrument meter calibrated with
methane would be classified as a leak. In this example, the leak definition is  10,000 ppm,
and the reference compound is methane.)

2.3  Calibration Gas. The VOC compound used to adjust the instrument meter reading
to a known value.  The calibration gas is usually the reference compound at a known
concentration approximately equal to the leak definition concentration.

2.4  No Detectable Emission.  The total VOC concentration at the surface of a  leak
source that indicates that a VOC emission (leak)  is not present. Since background VOC
concentrations may exist, and to account for instrument drift and imperfect reproducibility,
a difference between the source surface concentration and the local ambient concentration
is determined.  A difference based on the meter readings of less than a concentration

METHOD 21 (40 CFR 60, APPENDIX A)                                               page E-1

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corresponding to the minimum readability specification indicates that a VOC emission
(leak) is not present (For example, if the leak definition in a regulation is 10,000 ppm, then
the allowable increase is surface concentration versus local ambient concentration would
be 500 ppm based on the instrument meter readings.)

2.5 Response Factor. The ratio of the known concentration of a VOC compound to the
observed meter reading when measured using an instrument calibrated with the reference
compound specified in the applicable regulation.

2.6  Calibration Precision. The degree of agreement between measurements of the
same known value, expressed as the relative percentage of the average difference
between the meter readings and the known concentration to the known concentration.

2.7 Response Time. The time interval from a step change in VOC concentration at the
input of the sampling system to the time at which 90 percent of the corresponding final
value is reached as displayed on the instrument readout meter.

3. APPARATUS

3.1  Monitoring Instrument.

3.1.1  Specifications

a.  The VOC instrument detector shall respond to the compounds being processed.
Detector types which may meet this requirement include, but are not limited to, catalytic
oxidation, flame ionization, infrared absorption, and photoionization.

b.   The instrument shall be  capable  of measuring the leak definition concentration
specified in the regulation.

c.  The scale of the instrument meter shall be readable to + or - 5 percent of the specified
leak definition concentration.

d.  The instrument shall be equipped with a pump so that a continuous sample is provided
to the detector. The nominal sample flow rate shall be 0.1 to 3.0 liters per minute.

e.  The instrument shall be intrinsically safe for operation in explosive atmospheres as
defined by the applicable U.S.A. standards (e.g., National Electrical Code by the National
Fire Prevention Association).

f.  The instrument shall be equipped with a probe or probe extension for sampling not to
exceed  1/4 in. in outside diameter, with a single end opening for admission of sample.
METHOD 21 (40 CFR 60, APPENDIX A)                                                page E-2

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3.1.2  Performance Criteria.

a. The instrument response factors for the individual compounds to be measured must
be less than 10.

b.  The instrument response time must be equal to or less than 30 seconds.  The
response time must be determined for the instrument configuration to be used during
testing.

c. The calibration precision must be equal to or less than 10 percent of the calibration gas
value.

d. The evaluation procedure for each parameter is given in Section 4.4.

3.1.3  Performance Evaluation Requirements.

a. A response factor must be determined for each compound that is to be measured,
either by testing or from reference sources. The response factor tests are required before
placing the analyzer into service, but do not have to be repeated at subsequent intervals.

b.  The calibration precision test must be completed prior to placing the analyzer into
service, and at subsequent 3-month intervals or at the next use whichever is later.

c.  The response time test is required before placing the instrument into service. If a
modification to the sample pumping system or flow configuration is made that would
change the response time, a new test is required before further use.

3.2 Calibration Gases.

   The monitoring instrument is calibrated in terms of parts per million by volume (ppm)
of the reference compound specified in the applicable regulation. The calibration gases
required for monitoring and instrument performance evaluation are a zero gas (air, less
than 10 ppm VOC) and a calibration gas in air mixture approximately equal to the leak
definition specified in the regulation.  If cylinder calibration gas mixtures are used, they
must be analyzed and certified by the manufacturerto be within + or - 2 percent accuracy,
and a shelf life must be specified. Cylinder standards  must be either reanalyzed  or
replaced at the end  of the specified shelf life.  Alternatively, calibration gases may be
prepared by the user according to any accepted gaseous preparation procedure that will
yield a mixture accurate to within + or - 2 percent. Prepared standards must be replaced
each day of use unless it can be demonstrated that degradation does not occur during
storage.
   Calibrations may be performed using a compound other than the reference compound
if a conversion factor is determined for that alternative compound so that the resulting

METHOD 21 (40 CFR 60, APPENDIX A)                                                 page E-3

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meter readings during source surveys can be converted to reference compound results.

4.  PROCEDURES

4.1 Pretest Preparations. Perform the instrument evaluation procedure given in Section
4.4 if the evaluation requirement of Section 3.1.3 have not been met

4.2 Calibration Procedures. Assemble and start up the VOC analyzer according to the
manufacturer's  instructions.  After the  appropriate warmup period and zero internal
calibration procedure, introduce the calibration gas into the instrument sample probe.
Adjust the instrument meter readout to correspond to the calibration gas value. (Note: If
the meter readout cannot be adjusted to the proper value, a malfunction of the analyzer
is Indicated and corrective actions are necessary before use.)

4.3 Individual Source Surveys.

4.3.1  Type I - Leak Definition Based on Concentration.  Place the probe inlet at the
surface of the component interface where leakage could occur.  Move the probe along the
interface periphery while observing the instrument readout. If an increased meter reading
is observed, slowly sample the interface where leakage is indicated until the maximum
meter reading is obtained. Leave the probe inlet at this maximum reading location for
approximately two times the instrument response time. If the maximum observed meter
reading is greaterthan the leak definition in the applicable regulation, record and report the
results as specified in the regulation reporting requirements. Examples of the application
of this general technique to specific equipment types are:

a. Valves - Leaks usually occur at the seal between the stem and the housing. Place the
probe at the  interface  where the  stem exits  the  packing  and sample the stem
circumference and the flange periphery.  Survey valves of multipart assemblies where a
leak could occur.

b.  Flanges and Other Connections - Place the probe at the outer edge of the flange-
gasket interface and sample the circumference of the flange.

c. Pump or Compressor Seals - If applicable, determine the type of shaft seal. Perform
a survey of the local area ambient VOC concentration and determine if detectable
emissions exist as described above.

d.  Pressure Relief Devices - For those devices equipped with an enclosed extension, or
horn,  place the probe inlet at approximately the center of the exhaust area to  the
atmosphere.

e.  Process Drains - For open drains, place the probe inlet as near as possible to the

METHOD 21 (40 CFR 60, APPENDIX A)                                                page E-4

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center of the area open to the atmosphere. For covered drains, locate probe at the surface
of the cover and traverse the periphery.

f.  Open-ended Lines or Valves - Place the probe inlet at approximately the center of the
opening of the atmosphere.

g.  Seal System Degassing Vents, Accumulator Vessel Vents, Pressure Relief Devices -
If applicable, observe whether the applicable ducting or piping exists.  Also, determine if
any sources exist in the ducting or piping where emissions could occur before the control
device.  If the required ducting  or piping exists and there are no sources where the
emissions could be vented to the atmosphere before the control device, then it is
presumed that no detectable emissions are present. If there are sources in the ducting or
piping where emissions could be vented or sources where leaks could occur, the sampling
surveys described in this section shall be used to determine if detectable emissions exist.

h.  Access door seals - Place the probe inlet at the surface of the door seal interface and
traverse the periphery.

4.3.2  Type II - "No Detectable Emission".  Determine the ambient concentration around
the source by moving the probe randomly upwind and downwind around one to two meters
from the source.  In case of interferences, this determination may be made closer to the
source down to no closer than 25 centimeters. Then move the probe to the surface of the
source and measure as in 4.3.1.  The difference  in these concentrations determines
whether there are no detectable emissions.  When the regulation also requires that no
detectable emissions exist, visual observations and sampling surveys are required.
Examples of this technique are: (a) Pump or Compressor Seals -  Survey the local area
ambient VOC  concentration and determine if detectable emissions exist, (b) Seal System
Degassing Vents, Accumulator Vessel Vents, Pressure Relief Devices - Determine if any
VOC sources exist upstream of the device.  If such ducting exists and emissions cannot
be vented to the atmosphere upstream of the control device, then  it is presumed that no
detectable emissions are present, if venting is possible sample to determine if detectable
emissions are present.

4.3.3  Alternative Screening Procedure.

4.3.3.1 A screening procedure based on the formation of bubbles in a soap solution that
is sprayed on a potential leak source  may be used for those sources that do not have
continuously moving parts, that do not have surface temperatures greater than the boiling
point or less than the freezing point of  the soap solution, that do not have open areas to
the atmosphere that the soap solution cannot bridge, or that do not exhibit evidence of
liquid  leakage. Sources that have these conditions present must be surveyed using the
instrument technique of Section 4.3.1 or 4.3.2.
METHOD 21 (40 CFR 60, APPENDIX A)                                                 page E-5

-------
4.3.3.2 Spray a soap solution over all potential leak sources. The soap solution may be
a commercially available leak detection solution or may be prepared using concentrated
detergent and water.

A pressure sprayer or squeeze bottle may be used to dispense the solution. Observe the
potential leak sites to determine if any bubbles are formed. If no bubbles are observed,
the source is presumed to have no detectable emissions or leaks as applicable.  If any
bubbles are observed, the instrument techniques of Section 4.3.1 or 4.3.2 shall be used
to determine if a leak exists, or if the source has detectable emissions, as applicable.

4.4 Instrument Evaluation Procedures. At the beginning of the instrument performance
evaluation test, assemble and start up the instrument according to the manufacturer's
instructions for recommended warmup period and preliminary adjustments.

4.4.1  Response Factor.

4.4.1.1   Calibrate the instrument with  the reference compound  as specified in the
applicable regulation.  For each organic species that is to be measured during individual
source surveys, obtain or prepare  a known standard in air at a concentration of
approximately 80 percent of the applicable leak definition unless limited by volatility or
explosivity. In these cases, prepare a standard at 90 percent of the standard saturation
concentration, or 70 percent of the lower explosive limit, respectively.  Introduce this
mixture to the analyzer and record the observed meter reading.  Introduce zero air until a
stable reading is obtained. Make a total  of three measurements by alternating between
the known mixture and zero air. Calculate the response factor for each repetition and the
average response factor.

4.4.1.2  Alternatively, if response factors  have  been published for the compounds of
interest for the instrument or detector type, the response factor determination is not
required, and existing results may be referenced.  Examples of published response factors
for flame ionization and catalytic oxidation detectors are included in the Bibliography.

4.4.2  Calibration Precision. Make a total of three measurements by alternately using
zero gas and the specified calibration gas. Record the meter readings.  Calculate the
average algebraic difference between the  meter readings and the known value.  Divide this
average difference by the known  calibration value and  multiply by 100 to express the
resulting  calibration precision as a percentage.

4.4.3  Response Time. Introduce zero gas into the instrument sample probe.  When the
meter reading has stabilized, switch quickly to the specified calibration gas. Measure the
time from switching to when 90 percent of the final stable reading is attained. Perform this
test sequence three times and record the results. Calculate the average response time.
METHOD 21 (40 CFR 60, APPENDIX A)                                                 page E-6

-------
5. BIBLIOGRAPHY

1.   Dubose, D.A., and G.E. Harris.  Response Factors of VOC Analyzers at a Meter
Reading of 10,000 ppmv for Selected Organic Compounds. U.S. Environmental Protection
Agency, Research Triangle Park, NC. Publication No. EPA 600/2-81051. September 1981.

2.  Brown, G.E., et al. Response Factors of VOC Analyzers Calibrated with Methane for
Selected Organic Compounds. U.S. Environmental Protection Agency, Research Triangle
Park, NC.  Publication No. EPA 600/2-81-022. May 1981.

3.   DuBose, D.A. et al. Response of Portable VOC Analyzers to Chemical Mixtures.
U.S. Environmental Protection Agency, Research Triangle Park, NC. Publication No. EPA
600/2-81-110. September 1981.
METHOD 21 (40 CFR 60, APPENDIX A)                                              page E-7

-------
                 THIS PAGE INTENTIONALLY LEFT BLANK
METHOD 21 (40 CFR 60, APPENDIX A)                                           page E-8

-------
           APPENDIX F

CHEMICAL MANUFACTURING PROCESSES
    SUBJECT TO HON STANDARDS
       (40 CFR 63, SUBPART H)

-------

-------
  TABLE 1 TO SUBPART F - SYNTHETIC ORGANIC CHEMICAL MANUFACTURING INDUSTRY
                                  CHEMICALS
Chemical Name3
Acenaphthene
Acetal
Acetaldehyde
Aeetaldol
Acetamide
Acetanilide
Acetic acid
Acetic anhydride
Acetoacetanllide
Acetone
Acetone cyanohydrin
Acetonitrile
Acetophenone
Acrolein
Acrylamide
Acrylic acid
Acrylonitrile
Adiponitrile
Alizarin
Alkyl anthraqutnones
Allyl alcohol
Allyl chloride
Allyl cyanide
Aminophenol sulfbnic acid
Aminophenol (p-)
Aniline
Aniline hydroehloride
Anisidine (o-)
Anthracene
Anthraquinone
CAS Number"
83329
105577
75070
107891

103844
64197
108247
102012
67641
75865
75058
98862
107028
79061
79107
107131
111693
72480
008
107186
107051
109751
0010
123308
62533
142041
90040
120127
84651
Group
V
V
II
II
II
II
II
II
HI
I
V
I
I
IV
I
IV
I
I
V
V
I
IV
IV
V
I
I
111
II
V
III
CHEMICAL MANUFACTURING PROCESSES SUBJECT TO HON STANDARDS
page F-1

-------
Chemical Name9
Azobenzene
Benzaldehyde
Benzene
Benzenedisulfonic acid
Benzenesulfonic acid
Benzil
BenzIIic acid
Benzole acid
Benzoin
Benzonitrile
Benzophenone
Benzotrichloride
Benzoyl chtoride
Benzyl acetate
Benzyl alcohol
Benzyl benzoate
Benzyl chloride
Benzyl dichloride
Biphenyl
BisphenoLA
Bis(ChloromethyI)Ether
Bromobenzene
Bromofbrrn
Bromonaphthatene
Butadiene (1,3-)
Butanediol(1,4-)
Butyl acrylate (n-)
Butyleneglycol(1,3-)
Butyrolactone
Caprolactam
Carbaryl
Carbazole
CAS Number5
103333
100527
71432
98486
98113
134816
76937
65850
119539
100470
119619
98077
98884
140114
100516
120514
100447
98873
92524
80057
542881
108861
75252
27497514
106990
110634
141322
107880
96480
105602
• 63252
86748
Group
I
111
I
I
I
III
III
III
III
III
I
III
II!
Ill
III
III
III
III
I
III
I
I
V
IV
II
I
V
II
I
II
V
V
CHEMICAL MANUFACTURING PROCESSES SUBJECT TO RON STANDARDS
page F-2

-------
Chemical Name3
Carbon disulfide
Carbon tetrabromide
Carbon tetrachloride
Carbon tetrafluoride
Chloral
Chloroacetic acid
Chloroacetophenone (2-)
Chloroaniiine (p-)
Chlorobenzene
2-Chloro-1 ,3-butadiene (Chforoprene)
Chtorodifluoroethane
Chlorodifluoromethane
Chloroform
Chloronaphthalene
Chloronitrobenzene (m-)
Chloronitrobenzene (o-)
Chloronitrobenzene (p-)
Chlorophenol (m-)
Chlorophenol (o-)
Chlorophenol (p-)
Chlorotoluene (m-)
Chlorotoluene (o-)
Chlorotoluene (p-)
Chlorotrifluoromethane
Chrysene
Cresol and cresylic acid (m-)
Cresol and cresylic acid (o-)
Cresol and cresylic acid (p-)
Cresote and cresylic acids (mixed)
Cumene
Cumene hydroperoxide
Cyanoacetic acid
CAS Number*
75150
558134
56235
75730
75876
79118
532274
106478
108907
126998
25497294
75456
67663
25586430
121733
88733
100005
108430
95578
106489
108418
95498
106434
75729
218019
108394
95487
106445
1319773
98828
80159
372098
Group
IV
II
I
II
II
II
I
II
I
II
V
I
I
IV
I
I
I
II
II
II
111
111
III
II
V
111
III
111
111
1
1
11
CHEMICAL MANUFACTURING PROCESSES SUBJECT TO HON STANDARDS
page F-3

-------
Chemical Name'
Cyciohexane
Cycfohexanol
Cyclohexanone
Cycfohexylamine
Cyctooctadienes
Decahydronaphthalene
Diacetoxy-2-Butene (1,4-)
Diaminophenol hydrochloride
Dibromomethane
Dlchloroaniline (mixed isomers)
Dichtorobenzene (p-)
Dlchlorobenzene (m-)
Dichtorobenzene (o-)
Dichlorobenzidlne (3,3'-)
Dlchlorodifluoromethane
Dfchtoroethane (1,2-) (Ethylene dichloride) (EDC)
Dichloroethyl ether (bis(2-chloroethyl)ether)
Dichloroethylene (1 ,2-)
Dichlorophenol (2,4-)
Dichloropropene (1,3-)
Dichlorotetrafluoroethane
Dichloro-1-butene (3,4-)
DichIoro-2-butene (1,4-)
Diethanoiamine (212'-lminodiethanol)
Diethyl sulfate
Diethylamine
Diethylaniline (2,6-)
Diethylene glycol
Diethylene glycol dibutyl ether
Diethylene glycol diethyl ether
Diethylene glycol dimethyl ether
Diethylene glycol monobutyl ether acetate
CAS Number"
110827
108930
108941
108918
29965977
91178
0012
137097
74953
27134276
106467
541731
95501
91941
75718
107062
111444
540590
120832
542756
1320372
760236
764410
111422
64675
109897
579668
111466
112732
112367
111966
124174
Group
I
I
I
111
II
IV
V
V
V
I
I
I
I
I
I
I
I
II
III
II
V
II
V
I
II
IV
V
I
I
I
I
I
CHEMICAL MANUFACTURING PROCESSES SUBJECT TO HON STANDARDS
page F-4

-------
Chemical Name3
Diethylene glycol monobutyl ether
Diethylene glycol monoethyl ether acetate
Diethylene glycol monoethyl ether
Diethylene glycol monohexyl ether
Diethylene glycol monomethyl ether acetate
Diethylene glycol monomethyl ether
Dihydroxybenzoic acid (Resorcylic acid)
Dimethylbenzidine (3,3'-)
Dimethyl ether
Dimethylformamide (N,N-)
Dimethylhydrazine (1,1-)
Dimethyl sulfate
Dimethyl terephthalate
Dimethylamine
DImethylaminoethanol (2-)
Dimethylaniline (N,N')
Dinitrobenzenes (NOS) c
Dinitrophenol (2,4-)
Dinitrotoluene (2,4-)
Dioxane (1 ,4-) (1 ,4-Diethyleneoxide)
Dioxolane (1,3-)
Diphenyl methane
Diphenyl oxide
Diphenyl thiourea
Diphenylamine
Dipropylene glycol
Di-o-tolyguanidine
Dodecanedioic acid
Dodecyl benzene (branched)
Dodecyl phenol (branched)
Dodecylaniline
Dodecylbenzene (n-)
CAS Number"
112345
112152
111900
112594
629389
111773
27138574
119937
115106
68122
57147
77781
120616
124403
108010
121697
25154545
51285
121142
123911
646060
101815
101848
102089
122394
110985
97392
693232
123013
121158585
28675174
121013
Group
I
I
I
V
V
1
V
II
IV
1!
11
I
11
IV
1
ill
1
111
III
1
1
1
1
111
III
1
111
1
V
V
V
1
CHEMICAL MANUFACTURING PROCESSES SUBJECT TO HON STANDARDS
page F-5

-------
Chemical Name*
Dodecylphenol
Epiehlorohydrin (1-chIoro-2,3-epoxy propane)
Ethanolamine
Ethyl acrylate
Ethylbenzene
Ethyl chloride (Chforoethane)
Ethyl chloroacetate
Ethylamine
Ethylaniline (N-)
Ethylaniline (o-)
Ethylcellulose
Ethylcyanoacetate
Ethyiene carbonate
Ethylene dibromlde (Dibromoethane)
Ethyiene glycol
Ethyiene glycol dlacetate
Ethyiene glycol dibutyl ether
Ethyiene glycol diethyl ether (1,2-diethoxyethane)
Ethyiene glycol dimethyl ether
Ethyiene glycol monoacetate
Ethyiene glycol monobutyl ether acetate
Ethyiene glycol monobutyl ether
Ethyiene glycol monoethyl ether acetate
Ethyiene glycol monoethyl ether
Ethyiene glycol monohexyl ether
Ethyiene glycol monomethyl ether acetate
Ethyiene glycol monomethyl ether
Ethyiene glycot monooctyl ether
Ethyiene glycol monophenyl ether
Ethyiene glycol monopropyl ether
Ethyiene oxide
Ethylenediamlne
CAS Number"
27193868
106898
141435
140885
100414
75003
105395
75047
103695
578541
9004573
105566
96491
106934
107211
111557
112481
629141
110714
542596
112072
111762
' 111159
110805
112254
110496
109864
002
122996
2807309
75218
107153
Group
III
I
I
II
I
IV
II
V
III
HI
V
V
I
i
I
!
V
I
I
V
I
!
I
I
V
I
I
V
I
I
I
II
CHEMICAL MANUFACTURING PROCESSES SUBJECT TO HON STANDARDS
page F-6

-------
Chemical Name3
Ethyienediamine tetraacetic acid
Ethylenimine (Aziridine)
Ethylhexyl acrylate (2-isomer)
Fluoranthene
Formaldehyde
Formamide
Formic acid
Fumaric acid
Glutaraldehyde
Glyceraldehyde
Glycerol
Glycine
Glyoxal
Hexachlorobenzene
Hexachlorobutadiene
Hexachloroethane
Hexadiene(1,4-)
Hexamethylenetetramine
Hexane
Hexanetriol (1,2,6-)
Hydroquinone
Hydroxyadipaldehyde
Isobutyl acrylate
Isobutylene
Isophorone
Isophorone nifrile
Isophthalic acid
Isopropyiphenol
Linear alkylbenzene
Maleic anhydride
Maieic hydrazide
CAS Number"
60004
151564
103117
206440
50000
75127
64186
110178
111308
367475
56815
56406
107222
118741
87683
67721
592450
100970
110543
106694
123319
141311
106638
115117
78591
0017
121915
25168063
_d
108316
123331
Group
V
II
II
V
I
II
II
I
IV
V
II
II
II
II
II
I!
II
I
V
IV
I
V
V
V
IV
V
III
III
I
I
I
CHEMICAL MANUFACTURING PROCESSES SUBJECT TO HON STANDARDS
page F-7

-------
Chemical Name2
Malic acid
Metanilic acid
Methacrylic acid
Methanol
Methionine
Methyl acetate
Methyl acryiate
Methyl bromide (Bromomethane)
Methyl chloride (Chtoromethane)
Methyl ethyl ketone (2-butanone)
Methyl formate
Methyl hydrazine
Methyl Isobutyl carbinol
Methyl isobutyl ketone (Hexone)
Methyl isocyanate
Methyl mereaptan
Methyl methacrylate
Methyl phenyl carbinol
Methyl tert-butyl ether
Methylamine
Methylaniline (N-)
Methylcyclohexane
Methylcyciohexanol
Methylcyclohexanone
Methylene chloride (Dichtoromethane)
Methylene dianiline (4,4'-isomer)
Methylene dipheny! diisocyanate (4,4'-) (MD1)
Methylionones (a-)
Methylpentynoi
Methylstyrene (a-)
Naphthalene
Naphthalene sulfonic acid (a-)
CAS Number"
6915157
121471
79414
67561
63683
79209
96333
74839
74873
78933
107313
60344
108112
108101
624839
74931
80626
98851
1634044
74895
100618
108872
25639423
1331222
75092
101779
101688
79696
77758
98839
91203
85472
Group
I
I
V
IV
i
IV
V
IV
IV
V
II
IV
IV
IV
IV
IV
IV
II
V
IV
HI
HI
V
HI
I
I
III
V
V
I
IV
IV
CHEMICAL MANUFACTURING PROCESSES SUBJECT TO HON STANDARDS
page F-8

-------
Chemical Name3
Naphthalene sulfonic acid (b-)
Naphthol (a-)
Naphthol (b-)
Naphtholsulfonic acid (1-)
Naphthylamine sulfonic acid (1 ,4-)
Naphthyiamine sulfonic acid (2,1-)
Naphthylamine (1-)
Naphthylamine (2-)
Nitroaniline (m-)
Nitroaniline (o-)
Nitroanisole (o-)
Nitroanisole (p-)
Nitrobenzene
Nitre-naphthalene (1-)
Nitre-phenol (p-)
Nitrophenol (o-)
Nitropropane (2-)
Nitrotoluene (all isomers)
Nitrotoluene (o-)
Nitrotoluene (m-)
Nitrotoluene (p-)
Nifroxylene
Nonylbenzene (branched)
Nonylphenol
Octene-1
Octylphenol
Paraformaldehyde
Paraldehyde
Pentachlorophenol
Pentaerythritol
Peracetic acid
Perchloromethyl mercaptan
CAS Number"
120183
90153
135193
567180
84866
81163
134327
91598
99092
88744
91236
100174
98953
86577
100027
88755
79469
1321126
88722
99081
99990
25168041
1081772
25154523
111660
27193288
30525894
123637
87865
115775
79210
594423
Group
IV
IV
IV
V
V
V
V
V
II
I
111
111
I
IV
III
111
II
III
III
111
111
V
V
V
I
III
I
II
111
• I
II
IV
CHEMICAL MANUFACTURING PROCESSES SUBJECT TO HON STANDARDS
page F-9

-------
Chemical Name3
Phenanthrene
Phenetidine (p-)
Phenol
Phenolphthalein
Phenolsulfonic acids (all isomers)
Phenyt anthranilic acid (all isomers)
Phenylenediamine (p-)
Phloroglucinol
Phosgene
Phthalto acid
Phthalic anhydride
Phthalimlde
Phthalonitrile
Ptoollne (b-)
Piperazine
Propiolactone (beta-)
Propionaldehyde
Propionic acid
Propylene carbonate
Propylene dichloride (1 ,2-dichloropropane)
Propylene glycol
Propylene giycol monomethyl ether
Propytene oxide
Pyrene
Pyridine
p-tert-Butyi toluene
Quinone
Resorcinol
Salicylic acid
Sodium methoxide
CAS Number"
85018
156434
108952
77098
1333397
91407
106503
108736
75445
88993
85449
85416
91156
108996
110850
57578
123386
79094
108327
78875
57556
107982
75569
129000
110861
98511
106514
108463
69727
124414
Group
V
111
ill
111
111
III
I
III
IV
HI
HI
HI
HI
II
I
I
IV
I
V
IV
I
I
I
V
II
III
111
I
HI
IV
CHEMICAL MANUFACTURING PROCESSES SUBJECT TO HON STANDARDS
page F-10

-------
Chemical Name3
Sodium phenate
Stilbene
Styrene
Succinie acid
Succinonitrile
Sulfanilic acid
Sulfolane
Tartaric acid
Terephthalic acid
Tetrabromophthalic anhydride
Tetrachlorobenzene (1,2,4,5-) •
Tetraehloroethane (1,1,2,2-)
Tetrachloroethylene (Perchloroethylene)
Tefrachlorophthalic anhydride
Tetraethyl lead
Tetraethylene glycol
Tetraethylenepentamine
Tetrahydrofuran
Tetrahydronapthalene
Tetrahydrophthalic anhydride
Tetramethyienediamine
Tetramethylethylenediamine
Tetramethyllead
Toluene
Toluene 2,4 diamine
Toluene 2,4 diisocyanate
Toluene diisocyanates (mixture)
Toluene sulfonic acids
Toluenesulfonyl chloride
Toluidine (o-)
Trichloroaniline (2,4,6-)
Trichlorobenzene (1,2,3-)
CAS Number"
139026
588590
100425
110156
110612
121573
126330
526830
100210
632791
95943
79345
127184
117088
78002
112607
112572
109999
119642
85438
110601
110189
75741
108883
95807
584849
26471625
104154
98599
95534
• 634935
87616
Group
III
111
I
I
I
III
II
I
II
III
I
II
!
III
IV
I
V
I
IV
li
II
V
V
I
II
II
II
III
III
II
111
V
CHEMICAL MANUFACTURING PROCESSES SUBJECT TO HON STANDARDS
page F-11

-------
Chemical Name*
Trichlorobenzene (1,2,4-)
Trichloroethane (1,1,1-)
Trichloroethane (1,1,2-) (Vinyl trichloride)
Trichloroethylene
Trichlorofluoromethane
Trichtorophenol (2,4,5-)
(1,1,2-) Trichloro (1,2,2-) trifluoroethane
Triethanolamine
Trielhylamlne
Trielhylene glycol
Triethylene glycol dimethyl ether
Trielhylene glycol monoethyl ether
Triethylene glycol monomethyl ether
Trimethylamine
Trimethylcyclohexanol
Trimethylcyctohexanone
Trimethylcyclohexylamine
Trimethylolpropane
Trimethylpentane (2,2,4-)
Trlpropylene glycol
Vinyl acetate
Vinyl chloride (Chtoroethylene)
Vinyl toluene
Vinylcyclohexene (4-)
Vinylidene chloride (1 ,1-dichtoroethylene)
VinyI(N-)-pyrrolidone(2-)
Xanthates
Xylene sulfonic acid
Xylenes (NOS)C
Xylene (m-)
Xylene (o-)
Xylene (p-)
CAS Number"
120821
71556
79005
79016
75694
95954
76131
102716
121448
112276
112492
112505
112356
75503
933482
2408379
34216347
77996
540841
24800440
108054
75014
25013154
100403
75354
88120
140896
25321419
1330207
108383
95476
106423
Group
I
II
II
I
I
I
I
I
IV
I
I
V
I
IV
IV
IV
V
I
V
V
II
I
III
II
II
V
V
III
I
I
I
I
CHEMICAL MANUFACTURING PROCESSES SUBJECT TO HON STANDARDS
page F-12

-------
Chemical Name3
Xylenols (Mixed)
Xylidene
CAS Number"
1300716
1300738
Group
V
ill
alsomer means all structural arrangements for the same
 number of atoms of each element and does not mean salts,
 esters, or derivatives.
      Number = Chemical Abstract Service number.

CNOS = not otherwise specified.

dNo CAS number assigned.
CHEMICAL MANUFACTURING PROCESSES SUBJECT TO HON STANDARDS
page F-13

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CHEMICAL MANUFACTURING PROCESSES SUBJECT TO HON STANDARDS                        page F-14

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                 APPENDIX G




ORGANIC HAP SUBJECT TO HON STANDARDS (SUBPART H)

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-------
      TABLE 2 TO SUBPART F - ORGANIC HAZARDOUS AIR POLLUTANTS
   Chemical Name8*
CAS Number0
   Acenaphthene
   Acetaldehyde
   Acetamide
   Acetonitrile
   Acetophenone
   Acrolein
   Acrytamide
   Acrylic acid
   Acrylonitrile
   Alizarin
   Aliyl chloride
   Aniline
   Anisidine (o-)
   Anthracene
   Anthraquinone
   Benzene
   Benzotrichioride
   Benzyl chloride
   Biphenyl
   Bis(chloromethyl)ether
   Bromoform
   Bromonaphthalene
   Butadiene (1,3-)

   Carbon disuifide
   Carbon tetrachloride
   Chloroacetic acid
   Chloroacetophenone (2~)
   ' Chlorobenzene
          83329
          75070
          60355
          75058
          98862
         107028
          79061
          79107
         107131
          72480
         107051
          62533
          90040
         120127
          84651
          71432
          98077
         100447
          92524
         542881
          75252
      27497514
         106990

          75150
          56235
          79118
         532274
         108907
ORGANIC HAP SUBJECT TO HON STANDARDS
            page G-1

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    Chemical Name*"
CAS Number0
    2-Chloro-,1,3-butadiene (Chloroprene)
    Chloroform
    Chloronaphthalene
    Chrysene
    Cresols and cresylic acids (mixed)
    Cresol and cresylic acid (o-)
    Cresol and cresylic acid (m-)
    Cresoi and cresylic acid (p-)
    Cumene
    Dichlorobenzene (p-)
    Dtehtorobenzidine (3,3'-)
    Dichtoroethane (1,2-) (Ethylene dichioride) (EDC)

    DJchloroethylether(Bis(2-chIoroethyl)ether)
    Dichloropropene (1,3-)
    Diethanolamine(2,2'-Iminodiethanol)
    Dimethylaniline (N.N-)
    Diethyl sulfate
    Dimethylbenzidine (3,3'-)
    Dimethylformamide  (N,N-)
    DImethylhydrazine (1,1-)
    Dimethylphthalate
    Dimethylsulfate
    Dioitrophenol (2,4-)
    Dinitrotoluene (2,4-)
    Dioxane (1,4-) (1,4-Diethyleneoxide)
    1,2-DFphenyIhydrazine
    Epichiorohydrin (1 -ChIoro-2,3-epoxypropane)
    Ethyl acrylate
    Ethylbenzene
    Ethyl chloride (Chloroethane)
         126998
          67663
       25586430
         218019
        1319773
          95487
         108394
         106445
          98828
         106467
          91941

         107062
         111444
         542756
         111422
         121697
          64675
         119937
          68122
          58147
         131113
          77781
          51285
         121142
         123911
         122667
         106898
         140885
         100414
          75003
ORGANIC HAP SUBJECT TO HON STANDARDS
             page G-2

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   Chemical Name3*
CAS Number*
   Ethylene dibromide (Dibromoethane)
   Ethylene glycol
   Ethylene oxide
   Ethylidene dichloride (1,1-Dichloroethane)
   Fluoranthene
   Formaldehyde
   Glycol ethersd
   Hexachlorobenzene
   Hexachlorobutadiene
   Hexachloroethane
   Hexane
   Hydroquinone
   Isophorone
   Maleic anhydride
   Methanol
   Methylbromide (Bromomethane)
   Methylchloride (Chloromethane)
   Methyl ethyl ketone (2-Butanone)
   Methyl hydrazine
   Methyl isobutyl ketone (Hexone)
   Methyl isocyanate
   Methyl methacrylate
   Methyl tert-butyl ether
   Methylene chloride (Dichloromethane)
   Methylene diphenyl diisocyanate (4,4'-) (MDI)
   Methylenedianiline (4,4'-)
   Naphthalene
   Naphthalene sulfbnic acid (a)
   Naphthalene sulfonic acid (P)
   Naphthol (a)
   Naphthol (P)
         106934
         107211
          75218
          75343
         206440
          50000

         118741
          87683
          67721
        .110543
         123319
          78591
         108316
          67561
          74839
          74873
          78933
          60344
         108101
         624839
          80626
        1634044
          75092
         101688
         101779
          91203
          85472
         120183
          90153
         135193
ORGANIC HAP SUBJECT TO HON STANDARDS
             page G-3

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    Chemical Name*-"
CAS Number0
    Naphtholsulfonfc acid (1-)
    Naphthylamine sulfonic acid (1,4-)
    Naphthylamine sulfonic acid (2,1-)
    Naphthylamine (1-)
    Naphthylamine (2-)
    Nitronaphthalene (1-)
    Nitrobenzene
    Nitrophenol (p-)
    Nitropropane (2-)
    Phenanthrene
    Phenol
    Phenylenediamine (p-)
    Phosgene
    Phthalic anhydride
    Propiolactone (beta-)
    Propionaldehyde
    Propylene dichtoride (1,2-Dichloropropane)
    Propylene oxide
    Pyrene
    Quinone
    Styrene
    Tetrachloroethane (1,1,2,2-)
    Tetrachloroethylene(Perchloroethylene)
    Tetrahydronaphthalene
    Toluene
    Toluene diamine (2,4-)
    Toluene diisocyanate (2,4-)
    Toluidine (o-)
    Trichloroben2ene (1,2,4-)
    Trichloroethane (1,1,1-) (Methyl chloroform)
    Trichloroethane (1,1,2-) (Vinyl trichloride)
         567180
          84866
          81163
         134327
          91598
          86577
          98953
         100027
          79469
          85018
         108952
         106503
          75445
          85449
          57578
         123386
          78875
          75569
         129000
         106514
         100425
          79345
         127184
         119642
         108883
          95807
         584849
          95534
         120821
          71556
          79005
ORGANIC HAP SUBJECT TO HON STANDARDS
             page G-4

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    Chemical Name3*
CAS Number0
   Trichloroethylene
   Trichlorophenol (2,4,5-)
   Triethylamine
   Trimethylpentane (2,2,4-)
   Vinyl acetate
   Vinyl chloride (Chloroethylene)
   Vinylidene chloride (1,1-Dich!oroethylene)
   Xylenes (NOS)
   Xylene (m-)
   Xylene (o-)
   Xylene (p-)	
           7i016
           95954
          121448
          540841
          108054
           75014
           75354
        1330207
          108383
           95476
          106423
a For all Listings above containing the word "Compounds," the following applies:  Unless otherwise
specified, these listings are defined as including any unique chemical substance that contains the named
chemical (i.e., antimony, arsenic) as part of that chemical's infrastructure.

blsomer means all structural arrangements for the same number of atoms of each element and does not
mean salts, esters, or derivatives.
CCAS Number = Chemical Abstract Service number.
^Includes mono- and di- ethers of ethylene glycol, diethylene glycol, and triethylene glycol
R-(OCH2CH2)n-OR'
where
n = 1,2, or 3;
R = alkyl or aryl groups; and
R'= R, H, or groups which, when removed, yield glycol ethers with the structure: R-(OCH
Polymers are excluded from the glycol category.
ORGANIC HAP SUBJECT TO HON STANDARDS
             page G-5

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                 THIS PAGE INTENTIONALLY LEFT BLANK
ORGANIC HAP SUBJECT TO HON STANDARDS                                      page G-6

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              APPENDIX H

MANUFACTURING PROCESSES AND ORGANIC HAP
  SUBJECT TO HON STANDARDS (SUBPART I)

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     MANUFACTURING PROCESSES AND ORGANIC HAP SUBJECT TO HON
                              STANDARDS (SUBPART I)
 ProductionProcess(es)
Regulated Emissions
 Styrene-butadiene rubber production
Butadiene and styrene
 Polybutadiene rubber production
Butadiene
 The processes producing the agricultural
 chemicals:
        Captafol™

        Captan™

        Chlorothalonil

        Dacthal

        Tordon™ acid
 Processes producing the polymers/resins or other
 chemical products:
        Hypalon™

        Oxybisphenoxarsine/

         1,3-diisocyanate (OBPA™)

        Polycarbonates

        Polysulfide rubber

        Chlorinated paraffins

        Symmetrical tetrachloropyridine
Butadiene, carbon tetrachloride,
methylene chloride, and ethylene
dichloride
Carbon tetrachloride, methylene
chloride, tetrachloroethylene,
chloroform, and ethylene
dichloride
 Pharmaceutical production processes using carbon
 tetrachloride or methylene chloride
Carbon tetrachloride and
methylene chloride
MANUFACTURING PROCESSES AND ORGANIC HAP SUBJECT TO HON STANDARDS (SUBPART I)
                              page H-1

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 Production ProcessfesV                              Regulated EmissicMs
 Processes producing the polymers/resins or other          Butadiene
 chemicaf products:
        Methylmethacrylate-butadiene-
         styrene resins (MBS)
        Butadiene-furfural cotrimer
        Methylmethacrylate-acryloriitrile-
         butadiene-styrene (MABS) resins
        Ethylidene norbornene
MANUFACTURING PROCESSES AND ORGANIC HAP SUBJECT TO HON STANDARDS (SUBPART I)            page H-2

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EPA
          United States
          Environmental Protection
          Agency	
           Enforcement and
           Compliance Assurance
           (2224A)  	
EPA/305/B-98/011
December 1998
Inspection Manual:
Federal Equipment Leak
Regulations for the
Chemical Manufacturing
Industry
Volume III: Petroleum
Refining Industry
Regulations
                    EPA Office of Compliance
                    Chemical, Commercial
                    Services, and Municipal
                    Division

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ABSTRACT
The purpose of this manual is to enhance an inspector's ability to conduct more
complete and effective inspections at facilities in the chemical industry that are subject
to Federal equipment leak regulations. Equipment leak standards are designed to reduce
or eliminate emissions of volatile organic compounds (VOCs), volatile hazardous air
pollutants (VHAPs), and organic HAPs from the miles of piping and numerous
components found in chemical manufacturing processes.

This document is divided into three volumes. The first volume is  a manual for
inspectors; the second and third volumes describe regulations that apply to the  chemical
manufacturing and the petroleum refining industries, respectively.

Volume I has five chapters dedicated to helping an inspector:
   «   Chapter 1 states the goals, background, approaches to rale enforcement, and
       organization of the document.
   •   Chapter 2 addresses applicability determinations: ensuring the correct rales are
       being complied with at a facility, determining whether all appropriate
       components have been identified, and ensuring the components are properly
       classified by service.
   «   Chapter 3 discusses reporting and recordkeeping requirements for NSPS,
       NESHAP, HON, and RCRA (recordkeeping only), and strategies for reviewing
       reports and records.
   •   Chapter 4 covers on-site inspections: walk-throughs and inspections with the
       inspector monitoring for leaks. It addresses pre-inspection activities, timing and
       scope, interviews, leak monitoring evaluations, inspections of the process area
       and records, and post-inspection reviews and reports.
   •   Chapter 5 discusses recommended inspection techniques and procedures.

Volume BE tackles the equipment leak regulations applicable to the chemical
manufacturing industry.
   •   The first three appendices of Volume II summarize the regulations of 40 CFR
       Part 60 Subpart W, Part 61 Subparts J and V, Part 63 Subparts H and I, Part
       264 Subpart BB, and Part 265 Subpart BB; detail the differences among the
       regulations; and give the requirements grouped by component.
   •   Appendix D describes the regulated equipment.
   «   Appendix E contains the "Method 21" approach to leak detection.
   »   Appendix F lists chemical manufacturing processes that are subject to HON.
   •   Appendix G lists organic HAPs that are  subject to HON.
   «   Appendix H lists manufacturing processes and associated organic HAP
       emissions that are subject to HON.

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Volume III contains the equipment leak regulations applicable to the petroleum refining
industry.
   •  The three appendices of Volume in summarize the regulations of 40 CFR Part
      60 Subparts DDD, GGG, KKK, and QQQ, and Part 63 Subpart CC; detail the
      differences among the regulations; and give the requirements grouped by
      component.

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CONTENTS
VOLUME IE: PETROLEUM REFINING INDUSTRY REGULATIONS

                                                            Page
Appendix A  Equipment Leak Regulations: Side-by-Side Comparisons	A-l

Appendix B  Equipment Leak Regulations: Summary of Differences ...... B-l

Appendix C  Equipment Leak Regulations: Summary by Component	C-l

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CONTENTS (continued)
VOLUME I:  INSPECTION MANUAL
Chapter 1

Chapter 2
Chapter 3
Chapter 4
Chapter 5
Bibliography
Statement of Goals, Background, Approaches to Rule Enforcement,
and Organization of Document
Applicability
Compliance/Inspection Through Reports and Recordkeeping
Compliance/Assessment Through On-Site Inspections
Recommended Inspection Techniques and Procedures
VOLUME II:      CHEMICAL MANUFACTURING INDUSTRY
                 REGULATIONS

Appendix A Equipment Leak Regulations: Side-by-Side Comparisons
Appendix B Equipment Leak Regulations: Summary of Differences
Appendix C Equipment Leak Regulations: Summary by Component
Appendix D Regulated Equipment
Appendix E Method 21 (40 CFR 60, Appendix A)
Appendix F Chemical Manufacturing Processes Subject to HON Standards
           (40 CFR 63, Subpart H)
Appendix G Organic HAPs Subject to HON Standards (Subpart H)
Appendix H Manufacturing Processes and Organic HAPs Subject to HON
           Standards (Subpart I)

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                                     APPENDIX A

            EQUIPMENT LEAK REGULATIONS: SIDE-BY-SIDE COMPARISONS
      40 CFR Part 60, Subparts DDD, GGG, KKK, QQQ
      40 CFR Part 63, Subpart CC
                                                                            page
      GENERAL ASPECTS OF RULE
      Applicability	A-l
      Exemptions 	A-l
      Definitions	A-l
      Equipment Identification	A-3
     . Compliance Demonstrations	A-4
      Method of Compliance Determination	A-4
      Requirements When More Than One Standard Applies	A-4

      SPECIFIC COMPONENT SUMMARIES
      Valves, Gas/Vapor or Light Liquid Service	A-5
'      Valves, Heavy Liquid Service  	A-8
      Alternative Standards for Valves	A-9
      Pumps, Light Liquid Service	A-ll
      Pumps, Heavy Liquid Service  	,	A-14
      Pressure Relief Devices, Gas/Vapor Service	A-15
      Pressure Relief Devices, Light Liquid or Heavy Liquid Service  	A-17
      Compressors	A-18
      Sampling Connection Systems	A-20
      Open-Ended Valves or Lines	A-21
      Flanges and Other Connectors (All Services)	A-22
      Connectors, Gas/Vapor or Light Liquid Service	A-23
      Instrumentation Systems	A-25
      Closed-Vent Systems and Control Devices	A-26

      DELAY OF REPAIR	A-28

      EQUIVALENCE OF (OR ALTERNATIVE) MEANS OF EMISSIONS LIMITATION:
      GENERAL		A-29

      EQUIVALENCE OF (OR ALTERNATIVE) MEANS OF EMISSIONS LIMITATION:
      ENCLOSED-VENTED PROCESS UNITS	A-30
I

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QUALITY IMPROVEMENT PROGRAMS	A-31

TEST METHODS AND PROCEDURES		A-37

RECORDREEPMG REQUIREMENTS	 A-42

REPORTING REQUIREMENTS	A-52
40 CFR Part 61, Subparts F, L, FF
40 CFR Part 264, Subpart CC
40 CFR Part 265, Subpart CC
                                                                        page
GENERAL ASPECTS OF RULE
Applicability	A-54
Exemptions	A-54
Definitions	A-55
Equipment Identification	 A-57
Compliance Demonstrations	A-57
Method of Compliance Determination	A-57
Requirements When More Than One Standard Applies	A-57

SPECIFIC COMPONENT SUMMARIES
Process Unit/Plant Area	A-58
Valves, Gas/Vapor or Light Liquid Service	 A-59
Alternative Standards for Valves	A-61
Pumps, Light Liquid Service	A-64
Pressure Relief Devices, Gas/Vapor Service	A-67
Pressure Relief Devices, Light Liquid or Heavy Liquid Service	A-68
Compressors	A-69
Sampling Connection Systems  	A-72
Open-Ended Valves or Lines	A-73
Flanges and Other Connectors (All Services)	A-74
Agitators, Gas/Vapor or Light Liquid Service	A-75
Product Accumulator Vessels	A-76
Closed-Vent Systems and Control Devices	A-77
Process Vessels, Storage Tanks, and Tar-Intercepting Sumps	A-80
Light-Oil Sumps	A-82
Tanks		A-84
Surface Impoundments	A-85
Containers	A-86
Covers	A-88
Exhausters	A-90

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DELAY OF REPAIR .		A-92

EQUIVALENCE OF (OR ALTERNATIVE) MEANS OF EMISSIONS LIMITATION:
GENERAL	'	A-94

TEST METHODS AND PROCEDURES	A-95

RECORDKEEPING REQUIREMENTS	A-98

REPORTING REQUIREMENTS	A-106

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SUMMARY OF REGULATIONS
page A-l

General Aspects of Rule



APPLICABILITY


















EXEMPTIONS













DEFINITIONS
"In gas/vapor service"

REGULATION

40CFRPart60,
Subpart DDD

Each group of fugitive
emission equipment within
a process unit in the
polymer manufacturing
industry that commences
construction,
reconstruction, or
modification after
September 30, 1987.

The facilities covered are
polypropylene,
polyethylene, and
polystyrene.





This subpart does not apply
to VOC emissions from
equipment leaks from
poly(ethytene
terephthalate)
manufacturing processes

Any affected facility with
design capacity to produce
less than l,QOOMgper
year.
;



40CFRPart60,
Subpart GOG

Each compressor and the
group of all equipment
within a process unit in a
petroleum refinery that
commences construction,
reconstruction, or
modification after January
4, 1983.











None specified.














40 CFR Part 60,
Subpart KKK

Each compressor and the
group of ail equipment
within a process unit in an
onshore natural gas
processing plant that
commences construction,
reconstruction, or
modification after January
20, 1 984.










Any compressor station, .
dehydration unit,
sweetening unit,
underground storage tank,
field gas gathering system
or liquified natural gas unit
that is not located at the
onshore processing plant
site.






The piece of equipment contains process fluid that is in gaseous state at operating
conditions.

40 CFR Part 60,
Subpart QQQ

Individual drain systems,
individual oil-water
separators, and aggregate
facilities located within a
petroleum refinery
wastewater system that
commences construction,
reconstruction, or
modification after May 4,
1987.

"Aggregate facility" is an
individual drain system
together with ancillary
downstream sewer lines
and oil-water separators,
down to and including the
secondary oil-water
separator.
None specified.














Not applicable.


40 CFR Part 63,
Subpart CC
(existing)

40 CFR Part 63,
Subpart CC
(existing or new)
This subpart applies to all equipment leaks from petroleum
refining process units that are located at a major source and
that emit or have equipment containing or contacting one or
more of the HAP listed in Table 1 of this subpart.


This subpart does not apply to equipment intended to operate
in organic HAP service for less than 300 hours during the
calendar year.























Research and development facilities.


Equipment that does not contain any of the HAP listed in
Table 1 of this subpart.



Units processing natural gas liquids.


Units used specifically for recycling discarded oil.

Shale oil extraction units.

Ethylene processes.




Process units and emission points subject to subparts F, G, H,
and I of 40 CFR Part 63.



A piece of equipment in organic hazardous air pollutant
(HAP) service contains a gas or vapor at operating conditions,

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SUMMARY OF REGULATIONS
page A-2
General Aspects of Rule
"In heavy liquid
service"
"In light liquid service"
"In VOC service"
"In organic hazardous
air pollutant or in
organic (HAP) service"
"In wet gas service"
"Gas tight"
REGULATION
40 CFR Part 60,
Subpart ODD
40 CFR Part 60,
Subpart GGG
The piece of equipment is not in gas/vapor service or in
light liquid service.
40 CFR Part 60,
Subpart KKK
The piece of equipment is
not in gas/vapor service or
in light liquid service or
the weight percent
evaporated is 10 percent or
lessatl50°C.
The piece of equipment contains a liquid that meets the following conditions:
1 . The vapor pressure of one or more of the components is greater than 0.3 kPa at 20°C;
2. The total concentration of pure components having a vapor pressure greater than 0.3
kPa at 20°C is equal to or greater than 20 percent by weight; and
3. The fluid is a liquid at operating conditions.
4. The percent evaporated is greater than 10 percent at 150°C.
The piece of equipment contains or contacts a process fluid that is at least 10 percent VOC
by weight.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
A piece of equipment
contains or contacts the
field gas before the
extraction step in the
process.
Not applicable.
40 CFR Part 60,
Subpart QQQ
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Operated with no
detectable emissions.
40 CFR Part 63,
Subpart CC
(existing)
40 CFR Part 63,
Subpart CC
(existing or new)
A piece of equipment is not in gas/vapor service or in light
liquid service.
A piece of equipment contains a liquid that meets the
following conditions:
1. The vapor pressure of one or more of the organic
compounds is greater than 0.3 kPa at 20°C;
2. The total concentration of the pure organic compounds
having a vapor pressure greater than 0.3 kPa at 20°C is equal
to or greater than 20 percent by weight of the total process
stream;
3. The fluid is a liquid at operating conditions; and
4. The percent evaporated is greater than 10 percent at
150"C.
Not applicable.
A piece of equipment either contains or contacts a fluid
(liquid or gas) that is at least 5 percent by weight total organic
HAP.
Not applicable.
Not applicable.

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SUMMARY OF REGULATIONS
page A-3
General Aspects of Rule
REGULATION
40 CFR Part 60,
Subpart ODD
40 CFR Part 60,
Subpart GGQ,
40 CFR Part 60,
Subpart KICK
40 CFR Part 60,
Subpart QQQ
40 CFR Part 63,
Subpart CC
(existing)
DEFINITIONS (concluded)
"No detectable organic
emissions"
Equipment
("Equipment Leaks" for
40CFRPart63,subpart
CC)
Process Unit
Repaired
First Attempt at Repair
EQUIPMENT
IDENTIFICATION (see
also Recordkeeping
Requirements)
Not applicable.
Each pump, compressor,
pressure relief device,
sampling connection
system, open-ended valve
or line, valve, and flange or
other connector in VOC
service and any devices or
systems required by
Subpart VV.
Equipment assembled to
perform any of the physical
and chemical operations in
the production of
polypropylene,
polyethylene, polystyrene,
(general purpose, crystal,
or expandable), or
polyethylene
terephthalate) or one of
their copolymers, A
process unit can operate
independently if supplied
with sufficient feed or raw
materials and sufficient
storage facilities for the
product.
Not applicable.
Each valve, pump, pressure
relief device, sampling
connection system, open-
ended valve or line, and
flange or other connector
in VOC service. For the
purposes of recordkeeping
and reporting, compressors
are considered equipment.
Components assembled to
produce intermediate or
final products from
petroleum, unfinished
petroleum derivatives or
other intermediates; a
process unit can operate
independently if supplied
with sufficient feed or raw
materials and sufficient
storage facilities for the
product.
Not applicable.
Each pump, pressure relief
device, open-ended valve
or line, valve, compressor
and flange or other
connector that is in VOC
service or in wet gas
service and any device or
system required by this
subpart.
Equipment assembled for
the extraction of natural
gas liquids from field gas,
the fractionation of the
liquids into natural gas
products, or other
operations associated with
the processing of natural
gas products. A process
unit can operate
independently if supplied
with sufficient feed or raw
materials and sufficient
storage facilities for the
product.
Equipment is adjusted, or otherwise altered, in order to eliminate a leak as indicated by
one of the following: an instrument reading of 10,000 ppm or greater, indications of
liquids dripping, or indication by sensor that a seal or barrier fluid has failed.
To take rapid action for the purpose of stopping or reducing leakage of organic material to
atmosphere using best practices.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not specified.
40 CFR Part 63,
Subpart CC
(existing or new)

Not applicable.
HAP emissions form a pump, compressor, pressure relief
device, sampling connection system, open-ended valve or
line, valve, or instrumentation system in organic HAP service.
Vents from wastewater system drains, tank mixers, and
sample valves on storage tanks are not equipment leaks.
Equipment assembled and connected by pipes or ducts to
process raw and/or intermediate materials and to manufacture
an intended product. A process unit includes any associated
storage vessels. For the purposes of this subpart, a process
unit includes, but is not limited to, chemical manufacturing
process units and petroleum refining process units.
Equipment is adjusted, or otherwise altered, to eliminate a
leak as defined in the applicable sections of this subpart.
To take action for the purpose of stopping or reducing
leakage of organic material to atmosphere using best
practices.
Marked in manner such that it can be readily distinguished
from equipment not subject to this subpart (does not require
physical tagging except for leaking equipment).

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SUMMARY OF REGULATIONS
page A-4
General Aspects of Rule
COMPLIANCE
DEMONSTRATIONS
METHOD OF
COMPLIANCE
DETERMINATION
REQUIREMENTS
WHEN MORE THAN
ONE STANDARD
APPLIES
REGULATION
40CPRPart60.
Subpart ODD
40 CFR Part 60,
Subpart GOG
40 CFR Part 60,
Subpart KKK
40 CFR Part 60,
Subpart QQQ
Required for all equipment within 1 80 days ofinilial startup.
Review of records and reports, review of performance test results, and inspections.
Not specified.
Facilities subject to subpart
VVorsubpartKKKof40
CFR Part 60 are excluded
from this subpart.
Facilities covered by
subpart VV or subpart
GGG of 40 CFR Part 60
are excluded from this
subpart.
Not specified.
40 CFR Part 63,
Subpart CC
(existing)
40 CFR Part 63,
Subpart CC
(existing or new)
Existing Sources: in compliance by August 18, 1998
Existing Sources electing to comply with subpart H, 40 CFR
Part 63: Phase I - August 18, 1998; Phase II - August 18,
1999; Phase III -June 1 8, 2001
New Sources that commence construction or reconstruction
after July 14, 1994: in compliance upon initial startup or
August 18, 1998, whichever is later.
Review of records and reports, review of performance test
results, and inspections.
Equipment subject to this subpart that are also subject to 40
CFR Part 60 or 40 CFR Part 61 will be required to comply
only with the provisions of this subpart.

-------
                                                                     SUMMARY OF REGULATIONS
                                                                                                                                                              page A-5
   Specific
  Component
  Summaries
                                                                                             REGULATION
  40 CFR Part 60,
    Subpart DDD
40 CFR Part 60,
 Subpart OGO
40CFRPart60,
 Subpart KKK
40CFRPart60,
 Subpart QQQ
40 CFR Part 63,
  Subpart CC
   (existing)
40 CFR Part 63,
  Subpart CC
(existing or new)
VALVES, GAS/VAPOR OR LIGHT LIQUID SERVICE
     Standards
Monitor monthly.

After two consecutive months of no leaks, a valve may be monitored
quarterly.

If leak detected, monitor valve monthly until leak is not detected for two
consecutive months,

"No detectable emissions" valves:  less than 500 ppm above background,
                "Unsafe-to-monitor" valves:  written plan to monitor as frequently as
                practicable during safe-to-monitor times.

                "Difficult-to-monitor" valves: written plan to monitor at least once per year.
                No more than 3.0 percent of valves in affected facility can be designated as
                difTicuIt-to-monitor.
                                             Not applicable.
                                             Monitor monthly,

                                             After two consecutive months of
                                             no leaks, a valve may be
                                             monitored quarterly. Provisions
                                             made to allow use of qualified
                                             previously generated monitoring
                                             data to use less frequent
                                             monitoring.

                                             If leak detected, monitor valve
                                             monthly until leak is not detected
                                             for two consecutive months.

                                             "No detectable emissions" valves:
                                             less than 500 ppm above
                                             background.

                                             "Unsafe-to-monitor" valves:
                                             written plan to  monitor as
                                             frequently as practicable during
                                             safe-to-monitor times.

                                             "Difflcult-to-monitor" valves:
                                             written plan to  monitor at least
                                             once per year.  No more than 3
                                             percent of valves in affected
                                             facility can be designated as
                                             diffi cult-to-monitor.
                                                     In Phases I and II, monitor each valve quarterly.

                                                     In Phase III, monitoring frequency based on
                                                     percent valves found leaking and whether
                                                     connectors are being monitored according to
                                                     §63,649 [with CM = connector monitoring; w/o
                                                     CM = no connector monitoring]:

                                                      Percent Leaking    Monitoring
                                                     with CM  w/o. CM  Frequency
                                                                                                                                > 4    < 5         Monthly or Implement a
                                                                                                                                                 quality implementation
                                                                                                                                                 plan (QIP)
                                                                                                                                < 4    < 5         Quarterly
                                                                                                                                < 3    < 4         Quarterly or once every 2
                                                                                                                                                 quarters
                                                                                                                                < 2    < 3         Quarterly or once every 4
                                                                                                                                                 quarters

                                                                                                                              (If >2% leaking valves at a plant site with less "
                                                                                                                              than 250 valves in organic HAP service:
                                                                                                                              monitor quarterly.)

                                                                                                                              "Unsafe-to-monitor" valves: written plan to
                                                                                                                              monitor as frequently as practicable during safe-
                                                                                                                              to-monitor times.

                                                                                                                              "Difficult-to-monitor" valves: written plan to
                                                                                                                              monitor at least once per year.  No more than 3.0
                                                                                                                              percent of valves in new facility can be
                                                                                                                              designated as difficult-to-monitor.	

-------
SUMMARY OF REGULATIONS
page A-6
Specific
Component
Summaries
REGULATION
40CFRPart6Q, 40CFRPart6Q, 40CFRPart60.
SubpwtDDD SubparlOGO SubpsrtKKK
40CFRPart60,
SubpartQQQ
40CFRPart63.
SubpartCC
(existing)
40CPRPart63,
Subpart CC
(existing or new)
VALVES, GAS/VAPOR OR LIGHT LIQUID SERVICE (continued)
Standards
(concluded)
Leak
Definition
Repair
First Attempt
at Repair

1 0,000 ppm
Repair as soon as practicable, no later than 15 calendar days after detection.
First attempt within 5 calendar days of detection.
Best practices include, but are not limited to:
tightening of bonnet bolts
replacement of bonnet bolts
tightening of packing gland nuts
injection of lubricant into lubricated packing

Not applicable.
Nol applicable.
Not applicable.

10,000
Repair as soon as practicable, no
later than 15 calendar days after
detection.
First attempt within 5 calendar
days of detection.
Calculation of percent leaking may be done on
process unit or source-wide basis. Calculation
procedures remains the same until a permit
change is made. Decision on how to caleulate
required within the first monitoring period after
August 18, 1998,
Phase HI: Any valve designated as having no
detectable emissions may comply with §60.482-
7(f) instead.
Phase I: 1 0,000 ppm
Phase 11: 1, 000 ppm
Phase III: 1,000 ppm
Repair as soon as practicable, no later than 15
calendar days after detection.
First attempt within 5 calendar days of detection,
When repaired, monitor at least once within first
3 months after repair.
Best practices include, but are not limited to:
- tightening of bonnet bolts
- replacement of bonnet bolts
- tightening of packing gland nuts
- injection of lubricant into lubricated packing

-------
                                                                 SUMMARY OF REGULATIONS
                                                                                                                                                    page A-7
   Specific
 Component
 Summaries
                                                                                       REGULATION
  40 CFR Part 60,
   Subpart ODD
   40 CFR Part 60,
    Subpart GOO
    40 CFR Part 60,
     Subpart KKK
   40 CFR Part 60,
    Subpart QQQ
       40 CFR Part 63,
         Subpart CC
          (existing)
40 CFR Part 63,
  Subpart CC
(existing or new)
VALVES, GAS/VAPOR AND LIGHT LIQUID SERVICE (concluded)
   Exemptions
Equipment in vacuum
Equipment in vacuum
                                   Valves in gas/vapor or
                                   light liquid service
                                   within a process unit
                                   located on the Alaskan
                                   North slope.
Equipment in vacuum
service.

Valves in gas/vapor or
light liquid service within
a process unit located on
the Alaskan North slope
are exempt from the
routine monitoring
requirements of §60,482-
7(a).

Valves in gas/vapor or
light liquid service
located at a
nonfractionating plant
that does not have a
design capacity to
process 283,000 standard
cubic meters per day or
more of field gas are
exempt from the routine
monitoring requirements
of§60.482-7(a).	
Not applicable.
Equipment in vacuum service.

Equipment operated less than 300 hours per year.

-------
SUMMARY OF REGULATIONS
page A-8
Specific
Component
Summaries
REGULATION
40 CFR Part 60, 40 CFR Part 60, 40 CFR Part 60,
SubpartDDD SubpartOOO SubpwtKKK.
40 CFR Part 60,
Subpart QQQ
40 CFR Part 63, 40 CPR Part 63,
Subpart CC Subpart CC
(existing) (existing or new)
VALVES, HEAVY LIQUID SERVICE
Standards
Leak
Definition
Repair
First Attempt
at Repair
Exemptions
Monitoring of potential leaks within 5 calendar days of detection if evidence
of potential leak is found by visual, audible, olfactory, or other detection
method,
1 0,000 ppm
Repair as soon as practicable, no later than IS calendar days after detection.
First attempt within 5 calendar days of detection.
Best practices include, but are not limited to:
tightening of bonnet bolts
replacement of bonnet bolts
tightening of packing gland nuts
injection of lubricant into lubricated packing
Equipment in vacuum service.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Monitoring of potential leaks within 5 calendar days of detection if evidence of
potential leak is found by visual, audible, olfactory, or other detection method.
10,000 ppm
Repair as soon as practicable, no later than 1 5 calendar after detection. First attempt
within 5 calendar days of detection,
For valves in heavy liquid service that are not monitored (Method 21), repair shall
mean that visual, audible, olfactory, or other indications of a leak have been eliminated;
no bubbles are observed at potential leak sites during leak check with soap solution; or
system will hold a tesl pressure.
Best practices include, but are not limited to:
tightening of bonnet bolts
replacement of bonnet bolts
lightening of packing gland nuts
injection of lubricant into lubricated packing
Equipment in vacuum service.
Equipment operated less than 300 hours per year.

-------
SUMMARY OF REGULATIONS
page A-9

Specific
Component
Summaries

REGULATION

40GFRPart60» 40CFRPart60, 40CFRPart60,
Subpart ODD Subpart QGG Subpart KKK

40CFRPart60,
Subpart QQQ

40CFRPart63,
Subpart CC
(existing)
40 CFR Part 63,
Subpart CC
(existing or new)
ALTERNATIVE STANDARDS FOR VALVES
Allowable Percentage of Valves Leaking
Standard






















Leak
Definition
Repair




Notify Administrator of election to comply with alternative standard.

Conduct performance test initially, annually, and at other times as requested
by the Administrator.

Performance tests shall:

- Monitor all valves in gas/vapor and in light liquid service within one
week.

- Calculate percent leaking.

- Equal to or less than 2,0 percent leaking.










1 0,000 ppm

Repair as soon as practicable, no later than 1 5 calendar days after detection.

First attempt within 5 calendar days of detection.


Not applicable.






















Not applicable.

Not applicable.




Notify Administrator of election
to comply with alternative
standard.

Conduct performance test
initially, annually, and at other
times as requested by the
Administrator,

Performance tests shall:

• Monitor ail valves in gas/vapor
and in light liquid service within
one week.
• Calculate percent leaking.
• Equal to or less than 2.0
percent leaking.
Calculation of percent leaking
may be done on a process unit or
source-wide basis. Once decided,
all subsequent calculations made
on same basis unless permit
change.
10,000 ppm

Repair as soon as practicable, no
later than 1 5 calendar days after
detection.
First attempt within 5 calendar
days of detection.
Not applicable.






















Not applicable.

Not applicable.





-------
SUMMARY OF REGULATIONS
A-10

Specific
Component
Summaries

Pirsl Attempt
at Repair







REGULATION

40CPRPart60, 40CFRPart60, 40CPRPan60,
Subpart ODD Subpart OGO Subpart KKK

Best practices include, but are not limited to:

tightening of bonnet bolts
replacement of bonnet bolls
tightening of packing gland nuts
injection of lubricant into lubricated packing



40CFRPtrt60.
Subpart QQQ

Not applicable.








40CFRPart63,
Subpart CC
(existing)
Best practices include, but are not
limited to:

• lightening of bonnet bolts
- replacement of bonnet bolts
- tightening of packing gland
nuts
• injection of lubricant into
lubricated packing
40CFRPatt63,
Subpart CC
(exisling or new)
Nol applicable.








Skip Period Leak Detection and Repair
Standard




















Notify Administrator of election lo comply with alternative standard.

Conduct performance test initially, annually, and at other times as requested
by the Administrator.

Comply initially with monthly LDAR, then:

1 . After 2 consecutive quarters with equal to or less than 2 percent
leakers, monitor semiannually; or

2, After 5 consecutive quarters with equal lo or less than 2 percent
leakers, monitor annually.

Revert to monthly monitoring if percent leakers exceed 2 percent.







Not applicable.




















Notify Administrator of election
to comply with alternative
standard.

Conduct performance test
initially, annually, and at other
limes as requested by the
Administrator.

Comply initially with monthly
LDAR, then either:

1, After 2 consecutive quarters
with equal to or less than 2
percent leakers, monitor
semiannually.
2, After 5 consecutive quarters
with equal to or less than 2
percent leakers, monitor annually.
Revert to monthly moniloring if
percent leakers exceed 2 percent.
Nol applicable.





















-------
                                                                    SUMMARY OF REGULATIONS
                                                                                                                                                         page A41
   Specific
 Component
 Summaries
                                                                                           REGULATION
  40 CFR Part 60,
   Subpart ODD
40 CFR Part 60,
 Subpart OGQ
40 CFR Part 60,
 Subpart KICK
40 CFR Part 60,
 Subpart QQQ
40 CFR Part 63,
  Subpart CC
   (existing)
40 CFR Part 63,
  Subpart CC
(existing or new)
PUMPS, LIGHT LIQUID SERVICE
    Standards
Pumps; Monitor monthly and conduct weekly visual inspections.
               "Dual Mechanical Seal" Pumps: specific operating and design requirements,

               "No Detectable Emissions" Pumps:  less than 500 ppm above background and
               specified design requirements.
                                            Not applicable.
                                            Pumps: Monitor monthly and
                                            conduct weekly visual
                                            inspections,

                                            "Dual Mechanical Seal" Pumps:
                                            specific operating and design
                                            requirements.

                                            "No Detectable Emissions"
                                            Pumps: less than 500 ppm above
                                            background and specified design
                                            requirements.
                                                    Pumps; Monitor monthly and conduct weekly
                                                    visual inspections. If located at unmanned plant
                                                    site, visual inspections required at least monthly,

                                                    "Dual Mechanical Seal" Pumps:  specific
                                                    operating and design requirements.

                                                    "No Detectable Emissions" Pumps: less than
                                                    500 ppm above background and specified design
                                                    requirements.

                                                    Phase III: If less than 10 percent of the light
                                                    liquid pumps or less than 3 light liquid pumps
                                                    are leaking, monitor monthly. If less than 3
                                                    percent of the light liquid pumps or less than I
                                                    light liquid pump are leaking, monitor quarterly.
                                                    If the greater of either 10 percent of pumps in a
                                                    process unit (or source-wide) or 3 pumps in a
                                                    process unit (or source-wide) leak, then
                                                    implement technology review and improvement
                                                    QIP. (This does not apply to process unit if more
                                                    than 90% of the pumps in the unit are either dual
                                                    mechanical seal or designed with no externally
                                                    activated shaft penetrating the housing.)

                                                    Phase I; this phase is not applicable.

                                                    Phase II: begins upon facility startup.

                                                    Phase III: begins no later than one year after
                                                    initial startup.                             	

-------
SUMMARY OF REGULATIONS
page A-12
Specific
Component
Summaries
REGULATION
40CFRPart60,
Subpnrt ODD
•JQCFRPartfiO,
Subpart GGG
PUMPS, LIGHT LIQUID SERVICE (continued)
Leak
Definition
Repair
First Attempt
at Repair
1 0,000 ppm
Indications or liquids
dripping from pump
seal except that
indications of liquid
dripping from bleed
ports in existing
pumps are not
considered to be a
leak.
40CFRPart60,
Subpart KKK
4QCFRPart60,
Subpart QQQ
40CFRPart63,
SubptrtCC
(existing)
40CPRP»rt63,
SrtpsrteC
(existing or new)

10,000 ppm
Indications of liquids dripping from pump seal.
Repair as soon as practicable, no later than 15 calendar days after detection.
First attempt within 5 calendar days of detection.
None specified.
Not applicable.
Not applicable.
Not applicable.
10,000 ppirt
Indications of liquids dripping
from pump seal.
Phase 1; 10,000 ppin
Phase 11; 5,000 ppm
Phase III: 2,000 ppm
Indications of liquids dripping from pump seal.
Repair as soon as practicable, no later than 1 5 calendar days after detection.
First attempt within 5 calendar days of detection.
None specified.
Best practices include, but are not limited to:
tightening of packing gland nuts
ensuring that the seal flush is operating at
design pressure and temperature

-------
SUMMARY OF REGULATIONS
page A-13

Specific
Component
Summaries

REGULATION

40 CFR Part 60,
Subpart ODD

40 CFR Part 60,
Subpart 000

40 CPR Part 60,
Subpart KKK

40 CFR Part 60,
Subpart QQQ

40 CFR Part 63, 40 CFR Part 63,
Subpart CC Subpart CC
(existing) (existing or new)
PUMPS, LIGHT LIQUID SERVICE (concluded)
Exemptions




















Equipment in vacuum
service.

Any pump equipped
with a compliant
closed-vent system
and control device.














Equipment in vacuum
service.

Any pump equipped
with a compliant
closed-vent system and
control device.
Pumps in light liquid
service within a
process unit located on
the Alaskan North
slope.









Equipment in vacuum
service.

Any pump equipped with
a compliant closed-vent
system and control
device.
Pumps in light liquid
service within a process
unit located on the
Alaskan North slope and
those located at a non-
fractionating plant that
does not have the design
capacity to process
283,000 standard cubic
meters per day or more of
field gas are exempt from
the routine monitoring
requirements of §60,482-
2(aMl).
Not applicable.




















Equipment in vacuum service.

Any pump equipped with a compliant closed-vent system that transports leakage back
to the process or to a compliant control device.

Equipment operated less than 300 hours per year.





'-










-------
SUMMARY OF REGULATIONS
page A-14
Speeifle
Component
Summaries
REGULATION
40CPRPan60, 40CFRPart60, 40CFRPart60.
Subpart ODD Subpart 000 Subptirt KKK
40CFRPart60,
Subpan QQQ
40CFRPart63. 40 CFR Pan 63,
Subpnrt CC Subpart CC
(existing) (existing or new)
PUMPS, HEAVY LIQUID SERVICE
Standards
Leak
Definilion
Repair
First Attempt
at Repair
Exemptions
Monitoring of putcniia! leaks williiti 5 calendar days of detection if evidence
of potential leak is found by visual, audible, olfactory, or other detection
method.
1 0,000 ppm
Repair as soon as practicable, no later than 1 5 calendar days after detection.
First attempt within 5 calendar days of detection.
Best practices include, but are not limited to:
tightening of bonnet bolts
replacement of bonnet bolts
tightening of packing gland nuts
injection of lubricant into lubricated packing
Equipment in vacuum service.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Monitoring of potential leaks within 5 calendar days of detection if evidence of
potential leak is found by visual, audible, olfactory, or other detection method.
10,000 ppm
Repair as soon as practicable, no later than IS calendar alter detection. First attempt
within 5 calendar days of detection.
For pumps in heavy liquid service that are not monitored (Method 21), repair shall
mean that visual, audible, olfactory, or other indications of a leak have been eliminated;
no bubbles arc observed at potential leak sites during leak check with soap solution; or
system will hold a test pressure.
Best practices include, but arc not limited to:
tightening of bonnet bolts
replacement of bonnet bolts
tightening of packing gland nuts
injection of lubricant into lubricated packing
Equipment in vacuum service.
Equipment operated less than 300 hours per year.
Reciprocating pumps in heavy liquid service.

-------
SUMMARY OF REGULATIONS
page A-15

Specific
Component
Summaries

REGULATION

40CFRPart60, 40CFRPart60,
Subpart ODD Subpart GGG

40 CFR Part 60,
Subpart KKK

40 CFR Part 60,
Subpart QQQ

40 CFR Part 63,
Subpart CC
(existing)
40 CFR Part 63,
Subpart CC
(existing or new)
PRESSURE RELIEF DEVICES, GAS/VAPOR SERVICE
Standards






















Leak
Definition




No detectable emissions (less than 500 ppm
above background).

After each release, return to no detectable
emissions within 5 calendar days as indicated by
monitoring of the pressure relief device.

















"No detectable emissions" - less than 500 ppm
above background.




Option 1 : Monitor
quarterly and after each.
release monitor within 5
days. At
nonfractionating plants
where monitoring is done
by non-plant personnel,
monitoring after each
release must be done
when non-plant
personnel are next on-site
but within 30 days.

Option 2; No detectable
emissions (less than 500
ppm above background).
After each release, return
to no detectable
emissions within 5
calendar days as
indicrted by monitoring
of the pressure relief
device.
Option 1: 1 0,000 ppmv

Option 2; "No detectable
emissions" - less than
500 ppm above
background.
Not applicable.






















Not applicable.





No detectable emissions (less than
500 ppm above background).

After each release, return to no
detectable emissions within 5
calendar days as indicated by
monitoring of the pressure relief
device.















No Rupture Disk

No detectable emissions (less than 500 ppm
above background)

After each release, return to no detectable
emissions within 5 calendar days as indicated by
monitoring of the pressure relied device.

With Rupture Disk

After each release, replace rupture disk within 5
calendar days.










"No detectable emissions" - less than 500 ppm above background.






-------
                                                                   SUMMARY OF REGULATIONS
                                                                                                                                                      page A-16
   Specific
 Component
 Summaries
                                                                                         REGULATION
  40CFRPart60,
   Subpart ODD
40CPRPart60,
 Subpart GOG
40CFRPart6Q,
 Subpart KKK
40CFRPart6Q,
 Subpart QQQ
40CFRPart63,
  Subpart CC
   (existing)
40CFRPart63,
  Subpart CC
(existing or new)
PRESSURE RELIEF DEVICES. GAS/VAPOR SERVICE (concluded)
       Repair
Return to condition of "no detectable emissions'*
as soon as practicable but no later than S
calendar days after pressure release,
                   Option 1: First attempt
                   to repair within 5 days,
                   Completed repair within
                   15 days.

                   Option 2: Return to
                   condition of "no
                   deteeiable emissions" BS
                   soon as practicable but
                   no later than 5 calendar
                   days after pressure
                   release.
                    Not applicable.
                    Return to condition of "no
                    detectable emissions" as soon as
                    practicable but no later than S
                    calendar days after pressure
                    release.
                        Not applicable.
   Exemptions
Pressure relief devices equipped with closed-
vent system and control device.
               Equipment in vacuum service.
                   Pressure relief devices
                   equipped with closed-
                   vent system and control
                   device.

                   Equipment in vacuum
                   service,

                   PRDs in gas/vapor
                   service within a process
                   unit located on the
                   Alaskan North slope and
                   those located at a non-
                   fractionating plant that
                   does not have the design
                   capacity to process
                   283,000 standard cubic
                   meters per day or more of
                   field gas are exempt from
                   the routine monitoring
                   requirements of
                   §6Q.632(b)(l).	
                    Not applicable.
                   Pressure relief devices equipped with compliant closed-vent system and control device.

                   Equipment in vacuum.service.

                   Equipment operated less than 300 hours per year.

-------
SUMMARY OF REGULATIONS
page A-17
Specific
Component
Summaries
REGULATION
40CFRPart60, 40CFRPart60, 40CFRPart60,
SubpartDDD SubpartGGG SubpartKKK
40CFRPart60,
Subpart QQQ
40CFRPart63,
Subpart CC
(existing)
40CFRPart63,
Subpart CC
(existing or new)
PRESSURE RELIEF DEVICES, LIGHT LIQUID OR HEAVY LIQUID SERVICE
Standards
Leak
Definition
Repair
Exemptions
Monitoring of potential leaks within 5 calendar days of detection if evidence
of potential leak is found by visual, audible, olfactory, or other detection
method.
1 0,000 ppm
Repair as soon as practicable, no later than 15 calendar days after detection.
First attempt within S calendar days of detection.
Equipment in vacuum service.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Monitoring of potential leaks within 5 calendar days of detection if evidence of
potential leak is found by visual, audible, olfactory, or other detection method.
10,000 ppm
Repair as soon as practicable, no
later than 1 5 calendar after
detection.
First attempt within 5 calendar
days of detection.
Monitoring: 500 ppm
Repair as soon as practicable, no later than 15
calendar after detection.
First attempt within 5 calendar days of detection,
For pressure relief devices in liquid service that •
are not monitored (Method 21), repair shall mean
that visual, audible, olfactory, or other
indications of a leak have been eliminated; no
bubbles are observed at potential leak sites
during leak check with soap solution; or system
will hold a test pressure.
Equipment in vacuum service.
Equipment operated less than 300 hours per year.

-------
SUMMARY OF REGULATIONS
page A-18
Specine
Component
Summaries
REGULATION
40CPRPart6Q, 40CFRPartfi0, 40CFRPart60,
SubpartDDD SubpartOOQ SubpanKKK
40CFRPart60,
Subpart QQQ
40CFRPart63, 40 CFR Part 63,
Subpart CC Subpart CC
(existing) (existing or new)
COMPRESSORS
Standards
Leak
Definition
Repair
Equip with seal system that Includes a barrier fluid system and that prevents
leakage to atmosphere.
Seal system shall meet certain design and operation requirements.
Install sensor to detect failure of seal system, barrier fluid system, or both.
Check sensor daily or equip with audible alarm.
Establish criteria that indicates failure of seal system, barrier fluid system, or
both.
Sensor indicates failure of seal system, barrier fluid system, or both based on
established criteria.
Repair ts soon as practicable, no later than 1 5 calendar days after detection.
First attempt within 5 calendar days of detection.
Not applicable.
Not applicable.
Not applicable.
Equip with seal system that includes a barrier fluid system and that prevents leakage to
atmosphere.
Seal system shall meet certain design and operation requirements.
Install sensor to detect failure of seal system, barrier fluid system, or both.
Cheek sensor daily or equip with audible alarm [Subpart H does not require for
compressors located at unmanned plant site].
Establish criteria that Indicates failure of seal system, barrier fluid system, or both.
Sensor indicates failure of seal system, barrier fluid system, or both based on
established criteria.
Repair as soon as practicable, no later than 1 5 calendar days after detection.
First attempt within 5 calendar days of detection.

-------
SUMMARY OF REGULATIONS
page A-19

Specific
Component
Summaries

REGULATION

40CFRPart60,
Subpart ODD

40CFRPart60,
Subpart GOG

40CFRPart60,
Subpart KKK

40CFRPart60,
Subpart QQQ

40CFRPart63, 40CFRPart63,
Subpart CC Subpart CC
(existing) (existing or new)
COMPRESSORS (concluded)
Exemptions




















Equipment in vacuum
service.

Compressors
equipped with
compliant closed-
vent system and
control device.

Compressors
designed to operate
with an instrument
reading less than 500
ppm above
background.

Reciprocating
compressors that
meet certain criteria.


Equipment in vacuum
service.

Compressors equipped
with compliant closed-
vent system and
control device.

Compressors designed
to operate with an
instrument reading less
than 500 ppm above
background.

Reciprocating
compressors that meet
certain criteria.

Reciprocating
compressors that are in
hydrogen service.
Equipment in vacuum
service.

Compressors equipped
with compliant closed-
vent system and control
device.

Compressors designed to
operate with an
instrument reading less
than 500 ppm above
background.

Reciprocating
compressors that meet
certain criteria.

Reciprocating ,
compressors that are in
wet gas service,
Not applicable.




















Equipment in vacuum service.

Compressors equipped with compliant closed-vent system and control device.

Compressors designed to operate with an instrument reading less than 500 ppm above
background.

Equipment operated less than 300 hours per year.

Reciprocating compressors are exempt from the seal requirements if recasting the
distance piece or compressor replacement is required.

Compressors in hydrogen service.
,








-------
SUMMARY OF REGULATIONS
page A-20
Specific
Component
Summaries
REGULATION
40CFRPart6Q, 40CFRPart60,
Subpart ODD Subpart 000
40CFRPart60,
Subpsrt KKK
40CFRPort60,
Subpart QQQ
40 CFR Part 63,
Subpart CC
(existing)
40 CFR Part 63.
Subpart CC
(existing or new)
SAMPLING CONNECTION SYSTEMS
Standards
Leak
Definition
Repair
Exemptions
Equipped with closed-purge, closed-loop, or
closed-vent system that returns (he purged
process fluid to the process line, collects and
recycles the purged process fluid to a process, or
is designed and operated to capture and transport
all the purged process fluid to a compliant
control device.
Not applicable.
Not applicable.
Equipment in vacuum service.
In-situ sampling systems and sampling systems
without purges.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Nol applicable.
Not applicable.
Not applicable.
Not applicable.
Equipped with closed-purge,
closed-loop, or closed-vent system
that returns the purged process
fluid to the process line or collects
and recycles the purged process
fluid to a process or is designed
and operated lo capture and
transport all the purged process
fluid to a compliant control
device.
Not applicable.
Not applicable.
Equipped with closed-purge system, closed-loop,
or closed-vent system that either returns the fluid
to the proeess, recycles the purged fluid, or sends
it to a compliant control device.
Oases displaced during filling of samples are not
required to be collected or captured.
Not applicable.
Not applicable.
Equipment in vacuum service.
In-silu sampling systems and sampling systems without purges.
Equipment operated less than 300 hours per year.

-------
SUMMARY OF REGULATIONS
page A-21
Specific
Component
Summaries
REGULATION
40CFRPart60,
Subpart ODD
OPEN-ENDED VALVES OR LINES
Standards
Leak
Definition
Repair
Exemptions
40CFRPart60,
Subpart 000

40 CFR Part 60,
Subpart KKK
40 CFR Part 60,
Subpart QQQ
40 CFR Part 63,
Subpart CC
(existing)
40 CFR Part 63,
Subpart CC
(existing or new)

Equip with cap, blind flange, plug, or second valve to seal open end at all time
except when operations require flow through open end,
Second Valve
Close valve on process fluid end prior to closing second valve
Double Block and Bleed System
May remain open during operations that require venting the line between the
block valves, but comply with basic standard at all other times.
Not applicable.
Not applicable.
Equipment in vacuum service.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Equip with cap, blind flange, plug, or second valve to seal open end at all time except
when operations require flow through open end.
Second Valve
Close valve on process fluid end prior to closing second valve
Double Block and Bleed System
May remain open during operations that require venting the line between the block
valves, but comply with basic standard at all other times.
Not applicable.
Not applicable.
Equipment in vacuum service.
Equipment operated less than 300
hours per year.
Equipment in vacuum service.
Open-ended valves and lines in an emergency
shutdown system that are designed to open
automatically in the event of a process upset.
Equipment operated less than 300 hours per year.

-------
SUMMARY OF REGULATIONS
pge A-22
Specific
Component
Summaries
REGULATION
40 CFR Part 60,
Subpart ODD
40 CFR Part 60,
Subpart GOO
40 CFR Part 60,
Subpart KKK
40 CFR Part 60,
Subpart QQQ
40 CFR Part 63,
Subpart CC
(existing)
40 CFR Part 63,
Subpart CC
(existing or new)
FLANGES AND OTHER CONNECTORS (ALL SERVICES)
Standards
Leak
Definition
Repair
Exemptions
Monitor within 5 days if evidence of a potential leak is found by visual,
auditory, olfactory, or other detection methods.
10,000 ppm
Repair as soon as practicable, no later than 1 5 calendar days after detection.
First attempt within 5 calendar days of detection.
Equipment in vacuum service.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Monitor within 5 days if evidence
of a potential leak is found by
visual, auditory, olfactory, or
other detection methods.
Monitor within 5 days If evidence of a potential
leak is found by visual, auditory, olfactory, or
other detection methods.
Alternatively, connectors in gas/vapor and light
liquid service may comply with an alternative
program (see Connectors, gas/vapor or light
liquid service).
10,000 ppm
Repair as soon as practicable, no later than IS calendar days after detection.
First attempt within 5 calendar days of detection.
Equipment in vacuum service.
Equipment operated less than 300 hours per year.

-------
                                                                   SUMMARY OF REGULATIONS
                                                                                                                                                      page A-23
   Specific
 Component
 Summaries
                                                                                         REGULATION
  40CFRPart60,
   Subpart ODD
   40 CFR Part 60,
    Subpart GOG
    40 CFR Part 60,
     Subpart KKK
   40 CFR Part 60,
    Subpart QQQ
        40 CFR Part 63,
         Subpart CC
          (existing)
40 CFR Part 63,
  Subpart CC
(existing or new)
CONNECTORS, GAS/VAPOR OR LIGHT LIQUID SERVICE
    Standards
Not applicable.
Not applicable.
Not applicable.
Not applicable.
NOTE: The following applies only to units opting to comply with §63.649.

Option 1:  Random 200 Connector Alternative

 Initial monitoring of 200 randomly selected connectors within first 12 months

 Monitor each repaired leak within 3 months

 Subsequent monitoring required based on percent leaking connectors:

         Percent Leaking     Frequency
                                                                                                                    >2.0
                                                                                                                    <2
                                                                                                                    <1
                                                                                                                    2 inches in diameter, monitor if in gas/vapor service and inspect if
                                                                                                         in light liquid service within 12 months after compliance date.  Excludes inaccessible
                                                                                                         and unsafe-to-monitor connectors.

                                                                                                          Monitor/inspect each repaired leak within 3 months

                                                                                                          Subsequent monitoring required based on percent leaking connectors:

                                                                                                                  Percent Leaking     Frequency
                                                                                                                    >2.0
                                                                                                                    <2
                                                                                                                     annual
                                                                                                                     every 2 years
                                                                                                                     every 4 years

-------
SUMMARY OF REGULATIONS
page A-24
Specific
Component
Summaries
REGULATION
4QCFRPirt60,
Subpart ODD
40CFRPart6Q»
Subpart QGQ
40CFRPart60,
Subpart KKK
40CFRPart60,
Subpart QQQ
40CPRP»rt63, 4QCFRPart63,
Subpwt CC Subpart CC
(existing) (existing or new)
CONNECTORS, GAS/VAPOR OR LIGHT LIQUID SERVICE (concluded)
Standards
(concluded)
Leak
Definition
Repair
Exemptions

Not applicable.
Not applicable.
Not applicable.

Not applicable.
Not applicable.
Not applicable.

Not applicable.
Not applicable.
Not applicable.

Not applicable.
Not applicable.
Not applicable.
Option 2 concluded:
Equation to calculate percent leaking provided.
Cannot combine gas/vapor and light liquid to calculate percent leaking.
Identify by area or length of pipe; physical tagging and individual component
identification is not required.
Option 1: I.OOOppm
Option 2: gas/vapor service - 1,000 ppm
light liquid service - 3 drips per minute
Repair as soon as practicable, but no later than IS calendar days after detection.
First attempt to repair within 5 calendar days of detection.
Delay of repair allowed under certain circumstances
Equipment in vacuum service.
Equipment operated less than 300 hours per year.

-------
SUMMARY OF REGULATIONS
page A-25
Specific
Component
Summaries
REGULATION
40CFRPart60,
Subpart DDD
40CFRPart60,
Subpart QQG
40CFRPart60,
Subpart KKK
40 CFR Part 60,
Subpart QQQ
40 CFR Part 63, 40 CFR Part 63,
Subpart CC Subpart CC
(existing) (existing or new)
INSTRUMENTATION SYSTEMS
Standards
Leak
Definition
Repair
Exemptions
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Monitoring of potential leaks within 5 calendar days of detection if evidence of
potential leak is found by visual, audible, olfactory, or other detection method,
1 0,000 ppm
Repair as soon as practicable, no later than 15 calendar after detection.
For instrumentation systems that are not monitored (Method 2 1 ), repair shall mean thai
visual, audible, olfactory, or other indications of a leak have been eliminated; no
bubbles are observed at potential leak sites during leak check with soap solution; or
system will hold a test pressure.
Equipment in vacuum service.
Equipment operated less than 300 hours per year.

-------
SUMMARY OF REGULATIONS
page A-26

Specific
Component
Summaries

REGULATION

40eFRPart6Q, 40CFRPwt«), 40CFRP«t60,
SubpartDDD SubpirtGGG Subpart KKK

40CFRPwl60,
SubpwlQQQ

CLOSED VENT SYSTEMS AND CONTROL DEVICES
Standards

























Control devices and closed-vent systems to be operated at all time that
emissions may be vented to them,

Control Devices

Vapor recovery systems: 95 percent or greater recovery

Combustion devices: 95 percent or greater reduction or minimum residence
time of 0.75 seconds and minimum temperature of 816°C,

Flares: Comply with §60. 1 8


Closed-Vent Systems (CVS)

Hard pipe construction: Initial inspection (Method 21) and then annual visual
inspections.
Ductwork construction: Initial and annual inspections using Method 21.

Does not apply if CVS is in vacuum service.






Control devices and
closed-vent systems to
be operated at all time
that emissions may be
vented to them.

Control Devices

Vapor recovery
systems: 95 percent or
greater recovery
Combustion devices:
95 percent or greater
reduction or minimum
residence time of 0.75
seconds and minimum
temperature of 8 16"C.
Flares: Comply with
§60.18

Closed- Vent Systems
(CVS)
No detectable emissions
(less than 500 ppm
above background).
semiannually thereafter.
40CFRPan63, 40GFRPart«,
Subpart CC Subpwt CC
(existing) (existing or new)

Control devices and closed-vent systems to be operated al ali time thai emissions may
be vented to them.

Control Devices

Vapor recovery systems: 95 percent or greater recovery

Combustion devices: 95 percent or greater reduction or minimum residence time of, for
existing sources complying with subpart VV, 0.75 seconds and minimum temperature
of 8 1 5°C or for new sources and existing sources complying with subpart H, 0.50
seconds and minimum temperature of 760°C.
Flares: Comply with §63.11 (b).

Closed-Vent Systems (CVS)

Hard pipe construction: Initial inspection (Method 21) and then annual visual
inspections.
Ductwork construction: Initial and annual inspections using Method 21,

Does not apply if CVS is in vacuum service.







-------
SUMMARY OF REGULATIONS
page A-27
Specific
Component
Summaries
REGULATION
40 CFR Part 60,
Subpart ODD
40 CFR Part 60,
Subpart OQO
40 CFR Part 60,
Subpart KKK
40 CFR Part 60,
Subpart QQQ
40 CFR Part 63,
Subpart CC
(existing)
40 CFR Part 63,
Subpart CC
(existing or new)
CLOSED VENT SYSTEMS AND CONTROL DEVICES (concluded)
Monitoring
Leak
Definition
Repair
Exemptions
Control Devices: Monitor to ensure operated and maintained in conformance
witii their designs,
Closed-Vent Systems: If contains by-pass lines, (I) vent stream flow meters
or (2) car-seal or lock-and-key type of configuration with monthly visual
inspection required.
"Unsafe-to-monitor" parts: inspect as frequently as practicable, but no more
frequently than annually,
"DifTicult-to-monitor" parts: inspect at least once every 5 years.
500 ppm
Repair as soon as practicable, but no later than 15 calendar days after
detection,
First attempt to repair within 5 calendar days of detection.
Delay of repair allowed under certain circumstances. Repair required no later
than by end of next process unit shutdown.
Equipment in vacuum service.
Control Devices:
Monitor to ensure
operated and
maintained in
conformance with their
designs.
500 ppm
Repairs soon as
practicable, but no later
than 30 calendar days
after detection.
Delay of repair allowed
under certain
circumstances. Repair
required no later than
by end of next refinery
or process unit
shutdown.
Not applicable.
Control Devices: Monitor to ensure operated and maintained in conformance with their
designs.
Closed- Vent Systems: If contains by-pass lines, (1) vent stream flow meters or-(2) car-
seal or lock-and-key type of configuration with monthly visual inspection required.
"Unsafe-to-monitor" parts: inspect as frequently as practicable, but no more frequently
than annually.
"Difficult-to-monitor" parts: inspect at least once every 5 years.
500 ppm
Repair as soon as practicable, but no later than 15 calendar days after detection.
First attempt to repair within 5 calendar days of detection.
Delay of repair allowed under certain circumstances. Repair required no later than by
end of next process unit shutdown.
Equipment in vacuum service.
Equipment operated less than 300
hours per year.
Equipment in vacuum service.
Equipment operated less than 300 hours per year.
Equipment needed for safety purposes are not
subject to these monitoring requirements.

-------
                                                                      SUMMARY OF REGULATIONS
                                                                                                                                                           page A-28
Delay of Repair
                                                                                             REGULATION
                  40CFRPart60,
                   Subpart ODD
                    40CPRPart60,
                     Subpart GOG
40CFRPart60.
 Subpart KKK
40CFRPart6Q,
 SubpartQQQ
40CPRPart63,
  Subpart CC
   (existing)
40CPRParl63,
  SubpnttCC
(existing or new)
       Genera!
Allowed if repair is technically infeasible without a process unit
shutdown.

Repair to occur before end of next process unit shutdown,

Allowed for equipment isolated from the process and that docs not
remain in VOC service.
                     (see "Closed-vent
                     Systems and Control
                     Devices")
                     Allowed if repair is technically infcasible without a process unit shutdown.

                     Repair to occur before end of next process unit shutdown.

                     Allowed for equipment isolated from the process and that does not remain in organic HAP
                     service.
        Valves
Allowed if:

emissions of purged material resulting from immediate repair greater
than the fugitive emissions likely to result from the delay in the repair
and

purged material is collected and destroyed or recovered in compliant
control device when procedures are effected.

Delay beyond a process unit shutdown allowed if valve assemblies
have been depleted, valve assembly supplies had been sufficiently
stocked before supplies were depleted.
                 Not allowed unless next process unit shutdown occurs sooner than 6
                 months after 1st process unit shutdown.
                     (see "Closed-vent
                     Systems and Control
                     Devices")
                     Allowed if:

                     emissions of purged material resulting
                     from Immediate repair greater than the
                     fugitive emissions likely to result from
                     the delay in the repair and

                     purged material is collected and
                     destroyed or recovered in compliant
                     control device when procedures are
                     effected.

                     Delay beyond a process unit shutdown
                     allowed if valve assemblies have been
                     depleted, valve assembly supplies had
                     been sufficiently stocked before supplies
                     were depleted.

                     Not allowed unless next process unit
                     shutdown occurs sooner than 6  months
                     after 1st process unit shutdown.	
                            Allowed If:

                            emissions of purged material resulting from
                            immediate repair greater than the fugitive
                            emissions likely to result from the delay in the
                            repair and

                            purged material is collected and destroyed or
                            recovered in compliant control device when
                            procedures are effected.

                            Delay beyond a process unit shutdown
                            allowed if valve assemblies have been
                            depleted, valve assembly supplies had been
                            sufficiently stocked before supplies were
                            depleted.

                            Not allowed beyond the second process unit
                            shutdown unless the third process unit
                            shutdown occurs sooner than 6 months after
                            1st process unit shutdown.
        Pumps
Allowed if:

Repair requires use of DMS seal system that includes barrier fluid and

Repair completed as soon as practicable, but not later than 6 months
after leak detected.
                     (see "Closed-vent
                     Systems and Control
                     Devices")
                     Allowed if:

                     Repair requires use of DMS seai system
                     that includes barrier fluid and

                     Repair completed as soon as practicable,
                     but not later than 6 months after leak
                     detected.
                            Allowed if:

                            Repair requires replacing existing seai design
                            with a new system that provides better
                            performance, DMS, meets requirements of
                            !j63,163(f), or compliant closed-vent system
                            and control device.

                            Repair completed as soon as practicable, but
                            not later than 6 months after leak detected.

-------
SUMMARY OF REGULATIONS
page A.-29
Equivalence of (or
Alternative) Means
of Emission
Limitation:
General
Equipment, Design,
and Operational
Requirements
Work Practices
Unique Approach
Manufacturers of
Equipment
REGULATION
40CFRPart60, 40CFRPart60,
Subpart DDD Subpart GOG
Owner/operator collect and verify test
data to demonstrate equivalence,
Administrator compares test data.
Administrator may condition approval.
Owner/operator collect and verify test
data to demonstrate equivalence
Owner/operator demonstrates emission
reduction achieved by required work
practice
Owner/operator demonstrates emission
reduction achieved by equivalent means
of emission limitation
Owner/operator commits to alternative
work practices
Administrator compares demonstrated
emission reductions
Administrator may condition approval
Owner/operator may offer unique
approach to demonstrate equivalency
40 CFR Part 60,
Subpart KKK
Applicant collect and verify test
data, covering 12 months, to
demonstrate equivalence or better.
Administrator makes finding.
Administrator may condition
approval.
Applicant commits to alternative
means.
Applicant collect and verify test
data, covering 1 2 months, to
demonstrate equivalence or better.
Administrator makes finding.
Administrator may Condition
approval.
Applicant commits to alternative
means.
Not specified.
40 CFR Part 60,
Subpart QQQ
Any person collect and verify test
data to demonstrate equivalence.
Administrator makes finding.
Administrator may condition
approval.
Any person collect and verify test
data to demonstrate equivalence.
Administrator makes finding.
Administrator may condition
approval.
Not specified.
40 CFR Part 63, Subpart CC
(existing)
40 CFR Part 63,
Subpart CC
(existing or new)
Owner/operator collect and verify test data for alternative means
of emission limitation.
Administrator compares test data.
Administrator may condition approval.
Owner/operator collect and
verify test data to
demonstrate equivalence.
Owner/operator demonstrates
emission reduction achieved
by required work practice.
Owner/operator demonstrates
emission reduction achieved
by equivalent means of
emission limitation.
Owner/operator commits to
alternative work practices.
Administrator compares
demonstrated emission
reductions.
Administrator may condition
approval.
Owner/operator collect and
verify test data for alternative
means of emission limitation.
Owner/operator demonstrates
emission reduction achieved
by required work practice (for
minimum of 12 months).
Owner/operator demonstrates
emission reduction achieved
by alternative means of
emission limitation.
Owner/operator commits to
alternative work practices.
Administrator compares
demonstrated emission
reductions.
Administrator may condition
approval.
Owner/operator may offer unique approach to demonstrate
equivalency.
May apply for determination of equivalency for equipment, design, and operational requirements.

-------
SUMMARY OF REGULATIONS
pige A-30
Alternative Means
ofEmission
Limitations:
Unclosed-Vented
Process Units













REGULATION


40 CFR Part 60,
Subjwrt D00

Not applicable.












40 CFR Part 60,
SubpartGOG

Not applicable.












40 CPR Part 60,
Subpart KKK

Not applicable.












40 CFR Part 60,
Subpart QQQ

Not applicable.












40 CFR Part 63, Subpart CC
(existing)

Not applicable.












40 CFR Part 63,
Subpart CC
(existing or new)
Process units enclosed such
that all emissions from
equipment leaks are vented
through a closed-vent system
to a control device are exempt
from the requirements of
S§63. 163 through 63. 17 land
§§63.173 and 63.174,
Enclosure is to be maintained
under negative pressure at all
limes tiie process unit is in
operation.

-------
                                                                SUMMARY OF REGULATIONS
                                                                                                                                                 page A-31
  Quality
Improvement
  Programs
                                                                                        REGULATION
 40 CFR Part 60,
  Subpart ODD
 40 CFR Part 60,
  Subpart GOG
  40 CFR Part 60,
   Subpart KICK.
  40 CFR Part 60,
   Subpart QQQ
 40 CFR Part 63,
   Subpart CC
   (existing)
                        40 CFR Part 63,
                          Subpart CC
                        (existing or new)
   Applicability
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Valves

Optional in phase III to owners\operators with >4% leakers if not also
complying with §63.649 or with >S% leakers if also complying with
§63.649,

Decision required within first year of phase III,

If rolling average of percent leakers is <4% (<5%) for 2 consecutive
quarters: (I) comply with QIP, (2) comply with §63.168, or (3) comply
with both QIP and §63.168.

If comply with §63,168 only, can not use QIP again if leak rate goes above
4 (5) percent; monthly monitoring is required.

Pumps

Required in phase  HI if 6 month rolling average is the greater of either
>IO% or 3 pumps leaking.

Once<10%or<3 pumps leaking is achieved, comply with §63.163.

If leak rate again exceeds the greater of either >10% or 3 pumps leaking,
can use QIP again.	

-------
                                                                    SUMMARY OF REGULATIONS
                                                                                                                                                        page A-32
                                                                                             REGULATION
   Quality
 Improvement
  Programs
 40 CFR Pert 60,
   Subpart ODD
 40 CFR Part 60,
  Subpart GGG
  40 CFR Part 60,
   Subpirt KKK
  40 CFR Part 60,
   Subpart QQ
-------
                                                                  SUMMARY OF REGULATIONS
                                                                                                                                                       page A-33
  Quality
Improvement
  Programs
                                                                                            REGULATION
 40 CFR Part 60,
  Subpart DDD
 40 CFR Part 60,
  Subpart OGG
  40 CFR Part 60,
   Subpart KKK
  40 CFR Part 60,
   Subpart QQQ
 40 CFR Part 63,
   Subpart CC
    (existing)
                         40 CFR Part 63,
                           Subpart CC
                         (existing or new)
        Valves,
    Technology
    Review and
   Improvement
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Data collection for the valves as long as in QIP:

          Valve type and manufacturer, valve design, materials of
          construction, packing material, and year installed.

          Service characteristics of the stream (e.g., operating pressure,
          temperature, line diameter, corrosivity).

          Gas/vapor or light liquid service.

          if a leak is detected, the maximum instrument reading observed
          before a repair, response factor for stream if adjusted,
          instrument model number, and date of observation.

          Repair methods used and the instrument readings after the
          repair.

Inspect all valves removed due to leaks to determine cause of failure and
recommend design and other changes to reduce leak potential.

Analyze data to determine the services, operating and maintenance
procedures, and valve designs or technologies that have poorer than
average emission performance and those that have better than average
emission performance. The first analysis shall be completed no later than
18 months after the start of Phase III, shall use a minimum of 6 months of
data, shall be done yearly for as long as the process unit is in the QIP
program.

-------
                                                                 SUMMARY OF REGULATIONS
                                                                                                                                                   page A-34
  Quality
Improvement
  Programs
                                                                                         REGULATION
 40CFRPart60,
  Subprt ODD
 40CFRPart6Q,
  Subpart 000
  40CFRPart6Q,
   Subpsrt KKK
  40CFRPart60,
   Subpart QQQ
 40CFRPart63,
   Subpsrt CC
    (existing)
                        40CFRPart63,
                          Subpart CC
                        (existing or new)
       Valves,
    Technology
    Review and
   improvement
    (concluded)
Not applicable.
Mot applicable.
Not applicable.
Not applicable.
Not applicable.
Trial evaluation program is required for plants that have not demonstrated
superior performing valve designs and technologies:

 1. The number of valves In the trial program shall be the lesser of 1
percent or 20 valves for programs involving single process units and the
lesser of 1 percent or 50 valves for programs involving groups of process
units.

 2. The program shall specify and include design documentation of!

         superior performing valve designs or technologies
         the stages of evaluating these valve designs or technologies
         the frequency of monitoring or inspection
         range of operating conditions component will be evaluated
         under
         conclusions regarding the emission performance and
         appropriate operating conditions and services

The performance trials shall be conducted for a 6-month period beginning
no later than 18 months after the beginning of the Q!P.

Conclusions will be drawn no later than 24 months after the beginning of
theQIP.

Any plant site with fewer than 400 valves and owned by a company with
fewer than 100 total employees is exempt from the trial evaluations of
valves. These exempted plants shall begin the program at the start of the
fourth year of Phase Hi.

If superior emission performance technology can not be identified,
replacement valve shall be one with lowest emission performance

-------
                                                                  SUMMARY OF REGULATIONS
                                                                                                                                                       page A-35
  Quality
improvement
  Programs
                                                                                           REGULATION
 40 CFR Part 60,
   Subpart DDD
 40 CFR Part 60,
  Subpart OQG
  40 CFR Part 60,
   Subpart KKK.
  40 CFR Part 60,
   Subpart QQQ
 40 CFR Part 63,
   Subpart CC
    (existing)
                         40 CFR Part 63,
                           Subpart CC
                         (existing or new)
        Pumps,
    Technology
    Review and
   Improvement
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Data collection;

         Pumps: type and manufacturer, seal type and manufacturer,
         pump design, materials of construction, barrier fluid or packing
         material, and year installed.

         Service characteristics of the stream: discharge pressure,
         temperature, flow rate, corrosivity, annual operating hours.

         Maximum instrument readings observed before repair, response
         factor for the stream, instrument number, and date of
         observation.

         If a leak is detected, repair methods used and the instrument
         readings after the repair.

Inspect all pumps or pump seals that exhibit frequent seal failure and were
removed due to leaks.  Inspection shall determine probable cause and
recommendation for design changes or changes in specifications to reduce
leak potential.

Analyze data to determine the services, operating and maintenance
procedures, and pumps and pump seal designs or technologies that have
poorer than average emission performance and those that have better than
average emission performance.  The first analysis shall be completed no
later than 18 months after the start of the program, shall use a minimum of
6 months  of data, shall be done yearly for as long as the process unit  is in
the QIP program.

-------
                                                                SUMMARY OF REGULATIONS
                                                                                                                                                        A-36
  Quality
Improvement
  Programs
                                                                                         REGULATION
 40CFRPart60,
   Subpart ODD
 4QCFRPart60,
  Subpart GOG
  40CPRPart60,
   Subpart KKK
  40CFRPartfiO,
   Subpart QQQ
 40CFRPM163,
   Subpan CC
    (existing)
                          40CFRPart63,
                           SubprtCe
                          (existing or new)
        Pumps,
    Technology
    Review and
   Improvement
    (concluded)
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
  Trial evaluation program is required Tor plants that have not demonstrated
  superior technologies:

   1.  The number of pump seal technologies or pumps in the trial program
  shall be the lesser of I percent or 2 pumps for programs involving single
  process units and the lesser of i percent or 5 pumps for plant sites or
  groups of process units. The minimum number of pumps or pump seal
  technologies in the program shall be I; and

   2.  The program shall specify and include design documentation of:

           superior performing pump seal designs or technologies
           the stages of evaluating these pump designs or pump seal
           technologies
           the frequency of monitoring or inspection
           range of operating conditions component will be evaluated
           under
           conclusions regarding the emission performance and
           appropriate operating conditions and services

  The performance trials shall be conducted for a 6-month period beginning
  no later than 18 months after the beginning of the QIP.

  Conclusions will be drawn no later than 24 months after the beginning of
  the QIP.

  Beginning at the start of the third year of the QIP for plants with 400 or
  more valves or 100 or more employees and at the start of the fourth year
  for others, the owner/operator shall replace the pumps and pump seals that
  are not superior technology.  Pumps or pump seals shall be replaced at the
  rate of 20 percent per year and shall continue to be replaced until all are
j  superior technology^	

-------
                                                                    SUMMARY OF REGULATIONS
                                                                                                                                                     page A-37
 Test Methods and
    Procedures
                                                                                          REGULATION
 40 CFR Part 60,
  Subpart ODD
40 CFR Part 60,
 Subpart OGG
40 CFR Part 60,
 Subpart KKK
40 CFR Part 60,
 Subpart QQQ
40 CFR Part 63,
  Subpart CC
   (existing)
40 CFR Part 63,
  Subpart CC
(existing or new)
Monitoring Method
and Technique
Method 2! of 40 CFR Part 60, Appendix A

Test each piece of equipment unless demonstration is made that
equipment is not in VOC service
                                       Method 2 i of 40 CFR
                                       Part 60, Appendix A
                                           Method 21 of 40 CFR Part 60,
                                           Appendix A

                                           Test each piece of equipment
                                           unless demonstration is made that
                                           equipment is not in organic HAP
                                           service.
                                                    Method 21 of 40 CFR Part 60, Appendix A

                                                    Instrument to meet performance criteria of
                                                    Method 21 except:

                                                     response factor criteria is for the average
                                                    composition of the process fluid, not each
                                                    individual VOC in stream

                                                     for process streams that contain inerts that
                                                    are not organic HAP or VOC, average slream
                                                    response factor is calculated on an inert-free
                                                    basis

                                                    If no instrument available thai meet all
                                                    Method 21 criteria, then Instrument readings
                                                    may be adjusted as specified.

                                                    Monitor all equipment while it is "in service"
Calibration
before use each day of use

procedures specified in Method 21

calibration gases used;

 zero air (less than 10 ppm hydrocarbon in air)

 mixture of methane or n-hexane and air at about, but less than, 10,000 ppm methane or n-hexane
                                                                                               before use each day of use

                                                                                               procedures specified in Method 21

                                                                                               calibration gases used:

                                                                                                zero air (less than 10 ppm of hydrocarbon in
                                                                                               air)

                                                                                                Phase 1:  mixture of methane in air at
                                                                                               concentration of about, but less than,  10,000
                                                                                               ppm

                                                                                                Phase II: mixture of methane in air at
                                                                                               concentration of about, but less than:

                                                                                                 10,000 ppm for agitators
                                                                                                 5,000 ppm for pumps
                                                                                                  500 ppm all other equipment

-------
SUMMARY OF REGULATIONS
page A-38
Test Methods and
Procedures
Calibration
(concluded)






"No detectable
emissions"
monitoring

REGULATION
40CPRPart6Q,
SubpsrtDDD







40CFRPart6D,
SubporiGGG







4QCFRPartfiO,
SubpwtKKK







4QCFRPart60,
SubpwtQQQ







40CFRPart63,
SubpartCC
(existing)







40CFRPart63,
Subpsrt CC
(existing or new)
Phase HI: mixture oCmethane in air at
concentration of about, but less than:
10,000 ppm for agitators
2,000 ppm for pumps in food/ medical .
service
5,000 ppm for pumps in polymerizing
monomer service
1,000 ppm for all other pumps
500 ppm for all other equipment
Phases II and HI Exception: under certain
conditions may calibrate up to 2,000 ppm
higher than the leak definition
Background level determined by Method 21
Traverse probe as close to the potential leak interface as possible as described in Method 21
Calculate arithmetic difference between the maximum concentration indicated by the instrument and the background level compared to SOD ppm to determine compliance

-------
SUMMARY OF REGULATIONS
page A-3?

Test Methods and
Procedures


Not "in service"
demonstration





















"In wet gas service"







REGULATION

40CFRPart60,
Subpart ODD


40CFRPart60, .
Subpart GOG

Equipment must be demonstrated not to be
in VOC service (i.e.
, VOC content never
greater than 1 0% by weight).

For demonstration:




Use procedures that conform to ASTM E-
260, E-168, E-169 to determine percent
VOC in process fluid that is contained or
contacts a piece of equipment.


Engineering judgement may be used to
estimate the VOC content if piece of
equipment had not been shown previously
to be in VOC service.


Administrator will require use of ASTM
Method D-2267b in event of disagreement
to determine VOC content.
Compounds determined by EPA to have
negligible photochemical reactivity can be
excluded in determining VOC content of a
process fluid.
Not applicable.








Not applicable.








40CFRPart60,
Subpart KKK

Equipment musi be
demonstrated that
the percent VOC
content can be
reasonable expected
never to exceed
10.0 percent by
weight.

For demonstration:

Use procedures that
conform to ASTM
Methods El 69,
E168,orE-260
(incorporated by
reference).






Equipment to be in
wet gas service, it
must be determined
that it contains or
contacts the field
gas before the
extraction step in
the process.

40 CFR Part 60,
Subpart QQQ

Not applicable.






















Not applicable.








40 CFR Part 63, 40 CFR Part 63,
Subpart CC Subpart CC
(existing) (existing or new)
Equipment is presumed to be in organic HAP service unless demonstrated that the
organic HAP content can never reasonably expected to exceed 5 percent by weight.

For demonstration:

Use Method 1 8 of 40 CFR Part 60, appendix A to determine percent organic HAP.

Engineering judgment may be used to determine percent organic HAP does not
exceed 5 percent.

Owner/operator may instead determine organic HAP content does not exceed 5
percent by weight.











Not applicable. Not applicable.








-------
SUMMARY OF REGULATIONS
page A-40

Test Methods mid
Procedures


Not "in hydrogen
service"

























Samples

Vapor pressures


REGULATION

40CFRPart60,
Subptri ODD

Not applicable.



























4QCFRPtrt60,
Subpart GGG

Equipment must be
demonstrated to be
not in hydrogen
service; that is, the
percent hydrogen
content can be
reasonably expected
always to exceed 50
percent by volume.
For demonstration;
Use procedures thai
conform to the
general method
described in ASTM
E-260, E-168,orE-
169.
Engineering
judgement may be
used instead provided
it demonstrates that
the content clearly
exceeds 50 percent by
volume.
In case of
disagreement, the
ASTM procedure
results will prevail.

40CFRPart60,
Subpwt KICK

Not applicable.


























Representative of process fluid that is contained in or contacts the
equipment or the gas being combusted in flare.
Standard reference texts
or
ASTM D-2879

40CFRPart60,
Subpart QQQ

Not applicable.


























Not applicable.

Not applicable.



40CFRPart63,
Subpart CC
(existing)
Not applicable.



























40CFRPan63.
Subpart CC
(existing or new)
Not applicable.


























Representative of process fluid that is contained in or contacts the equipment.

Not specified.


Not specified.



-------
SUMMARY OF REGULATIONS
page A-41
Test Methods and
Procedures
Flare Compliance
REGULATION
40CFRPart60, 40CFRPart60, 40CFRPart60, 40CFRPart60, 40CFRPart63, 40CFRPart63,
SubpartDDD SubpartGGG SubpartKKK SubpartQQQ SubpartCC SubpartCC
(existing) (existing or new)
Visible emissions: Method 22
Presence of flame: thermocouple or equivalent
Exit velocity: Method 2, 2A, 2C, or 2D
Component concentration: Method 18 and ASTM D 2504-67
Net Heat of Combustion: Published values or ASTM D 2382-76, if published values not available or cannot be calculated

-------
                                                                    SUMMARY OF REGULATIONS
                                                                                                                                                 page A-42
    Recorcikeeping
    Requirements
                                                                                               REGULATION
  40CFRPart60,
   Subpwt ODD
40CPRPart60,
 Subpwt 000
4DCFRPtri60>
 Subprt KKK
40CFRPart6&,
 SubpartQQQ
40CFRPort63,
  SubpaitCC
   (existing)
40CFRPart63,
  SubpwtCC
(existing or new)
Consolidated
Rceordkccping
An owner or operator of more than one affected facility subject
to this subport may use one rceordkeeping system ifthe system
identifies each record by facility.
                                    Not specified.
                                               An owner or operator of more than
                                               one process unit subject to this
                                               subpart may use one recordkeeping
                                               system ifthe system identifies each
                                               record by process unit,
                                                       An owneror operator of more than one
                                                       process unit subject to this subpart may use
                                                       one recordkeeping system ifthe system
                                                       identifies each record by process unit and
                                                       the program being implemented for each
                                                       type of equipment
When leak detected.
Tagging Requirements:

 a weather-proof and readily visible identification, marked with
the equipment id number, attached to the leaking equipment

 id may be removed after it has been repaired, except for valves

 for valves, id may be removed after 2 months of monitoring
with no leaks detected

Log Requirements:

 instrument and operator id number and equipment id number

 date leak detected

 dates of each attempt to repair leak

 repair methods applied in each attempt to repair

 "above 10,000" if maximum instrument reading after each
repair attempt is > 10,000 ppm

 "repair delayed" and reason for delay if leak is not repaired
within 15 calendar days after detection
                                    Tagging Requirements:

                                    None required,


                                    Log Requirements:

                                      location

                                      date

                                      corrective action taken

                                    If delay:

                                      expected date of successful
                                    repair

                                      reason for delay

                                      owner/operator signature

                                      date of successful repair of
                                    leak

                                   I   Retain for 2 years	
                                               Tagging Requirements:

                                                a weather-proof and readily
                                               visible identification, marked with
                                               the equipment id number, attached
                                               to the leaking equipment

                                                id may be removed after it has
                                               been repaired, except for valves

                                                for valves, id may be removed
                                               after 2 months of monitoring with
                                               no leaks delected
                                                                                                             Log Requirements:

                                                                                                              instrument and operator id
                                                                                                             number and equipment id number
                                                        Tagging Requirements:

                                                         a weather-proof and readily visible
                                                        identification, marked with the equipment id
                                                        number, attached to the leaking equipment

                                                         id may be removed after it has been
                                                        repaired, except for valves and connectors

                                                         for valves and connectors, id may be
                                                        removed after it has been monitored as
                                                        specified and no leak has been detected
                                                        during the follow-up monitoring

                                                        Log Requirements:

                                                         instrument and equipment id number, and
                                                        operator name, initials, and id number

-------
                                                                      SUMMARY OF REGULATIONS
                                                                                                                                                       page A-43
    Recordkceping
    Requirements
                                                                                                  REGULATION
  40CFRPart60,
   Subpart ODD
40 CFR Part 60,
 Subpart GOG
40 CFR Part 60,
 Subpart KKK
40 CFR Part 60,
 Subpart QQQ
40 CFR Part 63,
  Subpart CC
   (existing)
40 CFR Part 63,
  Subpart CC
(existing or new)
When leak detected,
(concluded)
 signature of owner/operator whose decision it was that repair
could not be effected without a process shutdown

 expected date of successful repair if leak is not repaired with the
15 days

 dates of process unit shutdown that occurred while the
equipment is unrepaired

 date of successful repair of the leak

Retain for 2 years in readily accessible location.
                                                                     date leak detected

                                                                     dates of each attempt to repair
                                                                    leak

                                                                     repair methods applied in each
                                                                    attempt to repair

                                                                     "above 10,000" if maximum
                                                                    instrument reading after each repair
                                                                    attempt is > 10,000 ppm

                                                                     "repair delayed" and reason for
                                                                    delay if leak is not repaired within
                                                                    15 calendar days after detection

                                                                     signature of owner/operator
                                                                    whose decision it was that repair
                                                                    could not be effected without a
                                                                    process shutdown

                                                                     expected date of successful repair
                                                                    if leak is not repaired with the  15
                                                                    days

                                                                     dates of process  unit shutdown
                                                                    that occurred while the equipment
                                                                    is unrepaired

                                                                     date of successful repair of the
                                                                    leak

                                                                    Retain for 5 years; most recent 2
                                                                    years on-site or accessible from
                                                                    central location via computer; other
                                                                    3 years may be off-site.	
                                                                                    date leak detected

                                                                                    dates of first attempt to repair leak
                                                                                                                                                     maximum instrument reading after
                                                                                                                                                   successful repair or determined to be
                                                                                                                                                   nonreparable
                                                                                                                                                     "repair delayed" and reason for delay if
                                                                                                                                                    leak is-not repaired within 15 calendar days
                                                                                                                                                    after detection

                                                                                                                                                     for connectors:  id of connectors disturbed
                                                                                                                                                    since last monitoring period, and dates and
                                                                                                                                                    results of follow-up monitoring

                                                                                                                                                     copies of periodic reports (if database not
                                                                                                                                                    capable of generating such)
                                                                                                                                                     dates of process unit shutdown that
                                                                                                                                                   occurred while the equipment is unrepaired

                                                                                                                                                     date of successful repair of the leak
                                                                                                                                                   Retain for 5 years; most recent 2 years on-
                                                                                                                                                   site or accessible from central location via
                                                                                                                                                   computer; other 3 years may be off-site.

-------
                                                                       SUMMARY OF REGULATIONS
                                                                                                                                                       page A-44
    Recordkecping
    Rcquiremcnls
                                                                                                   REGULATION
  40CFRPart60,
   Subpart ODD
40CFRPart60,
 Subpart GOG
40CFRPart60,
 Subpart KKK
40CFRPart60,
 Subpart QQQ
40CFRPart63,
  Subpart CC
   (existing)
40 CFR Part 63.
  Subpart CC
(existing or new)
Closed vent systems
and control devices
 detailed schematics, design specifications, and piping and
instrumentation diagrams

 dates and descriptions of any changes in design specifications

 description of parameters) to be monitored to ensure proper
operation and maintenance

 explanation of selection of parameter(s)

 periods when not operated according to design

 dates of startups and shutdowns of control devices and closed-
vent systems

Keep these records in a readily accessible location.
                                      For life of facility:

                                       detailed schematics, design
                                      specifications, and piping and
                                      instrumentation diagrams

                                       dates and descriptions of any
                                      changes in design
                                      specifications

                                       description of parameters) to
                                      be monitored to ensure proper
                                      operation and maintenance

                                       documentation that control
                                      device will achieve required
                                      control efficiency during
                                      maximum loading conditions

                                       explanation of selection of
                                      parameters)

                                      For 2 years:

                                       periods when not operated
                                      according to design

                                       dates of startups and
                                      shutdowns of control devices
                                      and closed-vent systems

                                      Incinerators:  temperatures and
                                      exceedances

                                      Carbon adsorbers: outlet VOC
                                      concentrations and
                                      exceedances
                                                 detailed schematics, design
                                                 specifications, and piping and
                                                 instrumentation diagrams

                                                  dates and descriptions of any
                                                 changes in design specifications

                                                  description of parameters) to be
                                                 monitored to ensure proper
                                                 operation and maintenance

                                                  explanation of selection of
                                                 parameter(s)

                                                  periods when not operated
                                                 according to design

                                                  dates of startups and shutdowns of
                                                 control devices and closed-vent
                                                 systems

                                                 Keep these records in a readily
                                                 accessible location.
                                                          Design Specifications and Performance
                                                          Demonstration:

                                                           - detailed schematics, design
                                                          specifications, and piping and
                                                          instrumentation diagrams

                                                           - dates and descriptions of any changes in
                                                          design specifications

                                                           - description of parameter(s) to be
                                                          monitored to ensure proper operation and
                                                          maintenance

                                                           - flare design and compliance
                                                          demonstration results

                                                           - explanation of selection of parameter(s)

                                                          The design specification and performance
                                                          demonstration records are to be kept for the
                                                          life of the equipment.

                                                          Records of Operation:

                                                           - records of operation of closed-vent
                                                          systems and control devices

                                                           - dates and duration when closed-vent
                                                          systems, and control devices not operated
                                                          according to design

                                                           - dates and duration when monitoring
                                                          systems/devices are nonoperative

                                                           - dates of startups and shutdowns

                                                           - records of closed-vent inspections

                                                          Retain for 5 years; most recent 2 years on-
                                                          site or accessible from central location via
                                                          computer; other 3 years may be off-site.

-------
                                                                      SUMMARY OF REGULATIONS
                                                                                                                                                      page
    Recordkeeping
    Requirements
                                                                                                 REGULATION
  40CFRPart60,
   Subpart ODD
 40CFRPart60,
  Subpart GOG
 40CFRPart60,
   Subpart KKK
      40CFRPart60,
       Subpart QQQ
        40CFRPart63,
          Subpart CC
           (existing)
            40 CFR Part 63,
              Subpart CC
            (existing or new)
Closed vent systems
and control devices
(concluded)
                                                           For no detectable emissions:

                                                            dates of each measurement
                                                            background level
                                                            maximum instrument reading
Visual Inspections
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
 documentation that inspection was
conducted

 dates of inspection

Retain for 5 years; most recent 2 years on-
site or accessible from central location via
computer; other 3 years may be off-site.
All equipment...
 list of id numbers of subject equipment

 list of id numbers of equipment designated for no detectable
emissions and signed by owner/operator

 list of id numbers for pressure relief devices in gas/vapor
service

 for each compliance test for components designated for no
detectable emissions:

  dates conducted
  background level measured
  maximum instrument reading

 list of id numbers of equipment in vacuum service

Maintain records in a readily accessible location.
                                      Not applicable,
                                                  list of id numbers of subject
                                                 equipment

                                                  list of id numbers of equipment
                                                 designated for no detectable
                                                 emissions and signed by
                                                 owner/operator

                                                  list of id numbers for pressure
                                                 relief devices in gas/vapor service

                                                  for each compliance test for
                                                 components designated for no
                                                 detectable emissions:

                                                   dates conducted
                                                   background level measured
                                                   maximum instrument reading

                                                  list of id numbers of equipment in
                                                 vacuum service
                                                                 list of id numbers of subject equipment
                                                                (except certain connectors)

                                                                 connectors do not.need to be individually
                                                                identified if all connectors in a designated
                                                                area or length of pipe are identified as a
                                                                group and the number of connectors is
                                                                identified

                                                                 schedule by process unit for monitoring
                                                                connectors and valves

                                                                 identification of equipment in HAP service
                                                                by tagging, identified on a plant site plan, in
                                                                log entries,  or other methods

                                                                 list of id numbers for equipment equipped
                                                                with a closed-vent system and control device

-------
SUMMARY OF REGULATIONS
page A-46
Reeordkeeping
Requirements
All equipment ...
(concluded)








Unsafe- or Diffieult-to-
Monitor Valves
REGULATION
40CFRPart6Q, 40CPRPart60, 40CPRPart60,
Subpart ODD Subpart OOO Subpart KKK










40CPRPart60,
Subpart QQQ









Not applicable.
40CFRPart63,
Subpart CC
(existing)
Retain for 5 years; most recent 2
years on-silc or accessible from
central location via computer; other
3 years may be off-site.








40CFRPart63,
Subpart CC
(existing or new)
list of id numbers of compressors and
pressure relief devices complying with an
instrument reading of less than 500 ppm
above background standard
id of surge control vessels or bottoms
receivers equipped with a closed-vent
system or control device
id of pressure relief devices equipped with
rupture disks
id of instrumentation systems (individual
components need not be identified)
id of screwed connectors complying with
§63.174(c)(2). identification can be by
grouping or area.
list of valves and connectors removed from
or added to the process if net credits for the
removal or the valves or connectors are
expected to be used
documentation of the integrity of the weld
for removed connectors
if complying with §63.649, documentation
that all monitoring and inspections have
been conducted as required and document
repair of leaks as applicable.
Retain for 5 years; most recent 2 years on-
site or accessible from central location via
computer; other 3 years may be off-site.
list of id numbers
explanation for designation
planned schedule for monitoring

-------
SUMMARY OF REGULATIONS
page A-47
Rccordkeeping
Requirements
Unsafc-to- Monitor or
Repair, Inaccessible or
Glass-Lined
Connectors
Valves complying with
alternative standard for
skip-periods
Barrier fluid and seal
systems
Exemptions
Determinations
Nol "In service"
"In wet gas service"
REGULATION
40 CFR Part 60,
Subpart ODD
Not applicable.
40 CFR Part 60,
Subpart GGG
Not applicable.
40 CFR Part 60,
Subpart KKK
Not applicable.
schedule of monitoring
percent valves leaking during each monitoring period
design criteria for indicating failure
explanation for selected criteria
any changes to selected criteria and reasons for change
analysis demonstrating facility design
capacity
analysis demonstrating that equipment is
not in VOC service
analysis
demonstrating
facility design
capacity
analysis
demonstrating that
equipment is not
in VOC service
analysis
demonstration that
a reciprocating
compressor is in
wet gas service
information and data used to demonstrate that a piece of
equipment is not in VOC service
Not applicable.
Not applicable.
information and
data used to
demonstrate that a
reciprocating
compressor is in
wet gas service
40 CFR Part 60,
Subpart QQQ
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
40 CFR Part 63,
Subpart CC
(existing)
Not applicable.
schedule of monitoring
percent valves leaking during
each monitoring period
40 CFR Part 63,
Subpart CC
(existing or new)
list of id numbers
explanation for designation
planned schedule for monitoring
Not applicable,
design criteria for indicating failure
explanation for selected criteria
any changes to selected criteria and reasons for change
analysis demonstrating facility
design capacity
analysis demonstrating that
equipment is not in VHAP service
identification of equipment in
organic HAP service less than 300
hours per year
information and data used to
demonstrate that a piece of
equipment is not in organic HAP
service
Not applicable.
identification of equipment in organic HAP
service less than 300 hours per year
demonstration that compressor is not In
hydrogen service
information, data, and analysis used to
demonstrate that a piece of equipment or
process unit is in heavy liquid service
Not applicable.

-------
SUMMARY OF REGULATIONS
page A-48
Recordkecping
Requirements
QIP








REGULATION
40 CFR Pan 60,
Subpart ODD
Not applicable.








40 CFR Part 60,
Subpsrt QQG
Not applicable.








40 CFR Part 60,
Subptrt KKK
Not applicable.








40 CFR Part 60,
Subptrt QQQ
Not applicable.








40 CFR Part 63,
SubpirtCC
(existing)
Not applicable.








40 CFR Part 63,
Subpart CC
(existing or new)
If leak not repaired within IS calendar days
of discovery, rcison for leak repair 
-------
SUMMARY OF REGULATIONS
page A-49
Rccordkeeping
Requirements
QIP - Reasonable
further progress





REGULATION
40 CFR Part 60,
Subpart ODD
Not applicable.





40 CFR Part 60,
Subpart OGQ
Not applicable.





40 CFR Part 60,
Subpart KKK
Not applicable.





40 CFR Part 60,
Subpart QQQ
Not applicable.





40 CFR Part 63,
Subpart CC
(existing)
Not applicable.





40 CFR Part 63,
Subpart CC
(existing or new)
for each vaive in each process unit subject
to the QIP:
maximum instrument reading
observed in each monitoring
observation before repair^ the
response factor for the stream (if
appropriate), the instrument
model number, and the date of
the observation
whether the valve is in gas or
light liquid service
if a leak is detected, the repair
methods used and the instrument
readings after repair
percent leaking valves and rolling average
percent reduction each quarter
beginning and end dates while meeting the
requirements of the QIP

-------
SUMMARY OF REGULATIONS
A-50
Reeonteplng
Requirements
QIP- Technology
review and
improvement









REGUI^ATION
40CFRPart60,
Subparl ODD
Not applicable.










40CFRPart60,
SubpartGOG
Not applicable.










40CFRPart60,
Subpwt KICK
Not applicable.










40CFRPart60,
Subpart QQQ
Not applicable.










40CFRPart63,
Subpart CC
(existing)
Not applicable.










40 CFR Part 63,
Subpart CC
(existing or new)
For valves:
valve type and manufacturer, valve design,
materials of construction, packing material,
and year installed
service characteristics of the stream (e.g.,
operating pressure, temperature, line
diameter, corrosivity)
gas/vapor or light liquid service
If a leak is detected, the maximum
instrument reading observed before a repair,
response factor for stream if adjusted,
instrument model number, and date of
observation
repair methods used and the instrument
readings after the repair
a description of any maintenance or quality
assurance program used In the process unit
that are intended to improve performance
percent leaking valves
documentation of all inspections and
recommendations for design or specification
changes to reduce leak frequency
beginning and end date while meeting
requirements of the QIP

-------
SUMMARY OF REGULATIONS
page A-51
Recordkeeping
Requirements
QIP - Technology
review and
improvement
(concluded)






No detectable
emissions
Enclosed Vented
Process Units


REGULATION
40CFRPart60,
Subpart ODD
Not applicable.






40CFRPart60,
Subpart 000
Not applicable.






40 CFR Part 60,
Subpart K.KK
Not applicable.






40 CFR Part 60,
Subpart QQQ
Not applicable.






40 CFR Part 63,
Subpart CC
(existing)
Not applicable.






background level
maximum instrument reading
Not applicable.


Not applicable.


40 CFR Part 63,
Subpart CC
(existing or new)
For pumps:
type and manufacturer, seal type and
manufacturer, pump design, materials of
construction, barrier fluid or packing
material, and year installed
service characteristics of the stream:
discharge pressure, temperature, flow rate,
corrosivity, annual operating hours
maximum instrument readings observed
before repair, response factor for the stream,
instrument number, and date of observation
if a leak is detected, repair methods used
and the instrument readings after the repair
rolling average percent leaking pumps
documentation of all inspections and
recommendations for design or specification
changes to reduce leak frequency
beginning and end date while meeting
requirements of the QIP
Not applicable.
id of process units and organic HAP
handled
schematic of process unit, enclosure, and
closed-vent system
description of system used to create
negative pressure

-------
                                                                  SUMMARY OF REGULATIONS
                                                                                                                                                      page A-52
  Reporting
Requirements
                                                                                           REGULATION
 40 CFR Part 60,
  Subpart ODD
40 CFR Part 60,
 SubparlGGG
40 CFR Part 60,
 SubpartKKK
40 CFR Part 60,
 SubpsrtQQQ
40 CFR Part 63,
  Subpart CC
   (existing)
40 CFR Part 63,
  Subpart CC
(existing or new)
   Initial Report
process unit identification

number of valves, pumps, and compressors, excluding those
designated for no detectable emissions
                                   Certification that initial
                                   inspection of eiosed-veni system
                                   and control device has been
                                   performed.
                                                 process unit identification

                                                 number of valves, pumps,
                                                 and compressors, excluding
                                                 those designated for no
                                                 detectable emissions
                                                     InitialAllocation

                                                      name and address of owner/operator

                                                      address of facility (physical location)

                                                      identification of subject processes

                                                      compliance statement

                                                      statement of whether a source can achieve
                                                     compliance by the applicable compliance date

                                                     Notification of Compliance Status (for each, subject
                                                     process unit)

                                                     A. For each subject unit:

                                                      process unit identification

                                                      number of each equipment type (except those in
                                                     vacuum service)

                                                      method of compliance

                                                      planned schedule for each phase

                                                      whether percent valves leaking will be calculated on
                                                     a process unit or source-wide basis

                                                      if performance test required, complete test report

                                                     B. Enclosed-vented Process Units

                                                      process unit identification

                                                      description of negative pressure system and control
                                                     device

-------
                                                                    SUMMARY OF REGULATIONS
                                                                                                                                                           page A-53
                                                                                              REGULATION
  Reporting
Requirements
 40CFRPart60,
  Subpart ODD
40 CFR Part 60,
 Subpart 000
40 CFR Part 60,
 Subpart KXK
40 CFR Part 60,
 Subpart QQQ
40 CFR Part 63,
  Subpart CC
   (existing)
40 CFR Part 63,
  Subpart CC
(existing or new)
    Subsequent
    semiannual/
Periodic Reports
 process unit identification

The following information by month in the reporting period:
                   number of valves, pumps, and compressors for which leaks
                  were detected
                   number of valves, pumps, and compressors for which leaks
                  were not repaired as required
                   the facts that explain each delay of repair, and where
                  appropriate, why a process unit shutdown was technically
                  infeasible
                  Dates of process unit shutdowns that occurred within the
                  semiannual reporting period
                  Revisions to items reported in the initial semiannual report if
                  changes have occurred since the initial semiannual report or
                  subsequent revisions to the initial semiannual report
                                    Semi-annual certification that all
                                    required inspections have been
                                    carried out.

                                    Initial and semi-annual reports
                                    that summarize all inspections
                                    that identity problems that could
                                    result in VOC emissions,
                                    including information about
                                    repairs and corrective action
                                    taken.

                                    Semi-annual reports of each
                                    period of exeeedance for
                                    incinerators and carbon adsorbers.
                                                    process unit identification

                                                   The following information by
                                                   month in the reporting
                                                   period:

                                                    number of valves, pumps,
                                                   and compressors for which
                                                   leaks were detected

                                                    number of valves, pumps,
                                                   and compressors for which
                                                   leaks were not repaired as
                                                   required

                                                    the facts that explain each
                                                   delay of repair, and where
                                                   appropriate, why a process
                                                   unit shutdown was
                                                   technically infeasible

                                                   Dates of process unit
                                                   shutdowns that occurred
                                                   within the semiannual
                                                   reporting  period

                                                   Revisions to items reported
                                                   in the initial semiannual
                                                   report if changes have
                                                   occurred since the initial
                                                   semiannual report or
                                                   subsequent revisions to the
                                                   initial semiannual report
                                                      Submit the following information semi-annually
                                                      starting 6 months after the Notification of
                                                      Compliance:

                                                       the number of valves, pumps, compressors,
                                                      connectors, and screwed connectors forwhich.leaks
                                                      were detected

                                                       the percent leakers for valves, pumps, connectors,
                                                      and screwed connectors

                                                       the total number of valves, pumps, connectors, and
                                                      screwed connectors monitored

                                                       the number of valves, pumps, compressors,
                                                      connectors, and screwed connectors for which leaks
                                                      were not repaired

                                                       identification of the number of valves and connectors
                                                      determined to be nonreparable

                                                       explanation of why repairs delayed and why process
                                                      unit shutdown was infeasible

                                                       notification of change in connector monitoring
                                                      alternatives (if applicable)

                                                      For "no detectable emissions" components: all
                                                      monitoring to show compliance

                                                       initiation of monthly monitoring under phase III or
                                                      QIP (ifapplicable)  '
         Other    Notification 90 days prior to election to comply with either
                  alternative standard for valves in gas/vapor service.
                  Report of all performance test in accordance with §60,8.
                                                         If flare used, initial performance
                                                         test within 60 days of initial
                                                         startup.
                                                                     Notification 90 days prior to
                                                                     complying with either
                                                                     alternative standard for
                                                                     valves in gas/vapor service.

                                                                     Report of all performance
                                                                     tests in accordance with
                                                                     §60.8.
                                                                                None specified.

-------
                                                                       SUMMARY OF REGULATIONS
                                                                                                                                                       page A-54
General Aspects of lule
                                                                                                   REGULATION
                                40CFRPart61,
                                   SubpartF
                                            40CFRPirt6l,
                                               SubjartL
                                                 40 CFR Pan 61,
                                                   Subpart FF
                                      40 CFR Part 2«,
                                         Subpart CC
                                    40 CFR Part 265,
                                      Subpart CC
APPLICABILITY
Flams which produce:
- ethylene dichlorkle by reaction
of oxygen and hydrogen chloride
wiih ethylene
- vinyl chloride by any process
- one or more polymers
containing any fraction of
polymerized vinyl chloride.
At furnace and foundry coke by-product
recovery plants:
- tar decanters
- tar storage tanks
- tar-intereepting sumps
- flushing-liquor circulation lanks
- light-oil sumps
- light-oil condensers
- light-oil decanters
- wash-oil decanters
- wash-oil circulation tanks
- naphthalene processing
- final coolers
- final-cooler cooling towers
- equipment intended to operate in benzene
service

Also applies to benzene storage tanks, BTX
storage tanks, light-oil  storage tanks, and
excess ammonia-liquor storage tanks at
furnace coke by-product recovery plants.
Owners/operators of chemical
manufacturing plants, coke by-
product recovery plants, and
petroleum refineries and the
owners/operators of hazardous
waste treatment, storage, and
disposal facilities that treat, store,
or dispose of hazardous waste
generated by these facilities.
Facilities that treat, store, or dispose of hazardous waste in
tanks, surface impoundments, or containers subject to either 40
CFR Part 264, Subpart I (Use and Management of Containers),
J (Tank Systems), or K (Surface Impoundments).

Containers:  >0.1 cubic meters capacity
EXEMPTIONS
Equipment used in research and
development if the reactor used
to polymerize the vinyl chloride
processed in the equipment has a
capacity sO,19 m! (50 gal).
None specified.
The following waste is exempted:

- waste in the form of gases or
vapors that is emitted from
process fluids

- waste that is contained in a
segregated stormwater sewer
system
A waste management unit that holds hazardous waste placed in
the unit before June 5,  1995, and in which no hazardous waste is
added to the unit on or after June 5, 1995.

A container that has a design capacity <. 0.1 in3.

A tank or surface impoundment in which an owner/operator has
stopped adding hazardous waste and begun implementing or
completed closure pursuant to an approved closure plan.

A waste management unit used solely for on-site treatment or
storage of hazardous waste  that is generated as the result of
implementing remedial activities required under certain
corrective action RCRA, CERCLA, and other similar
authorities.

A waste management unit that is used solely for the management
of radioactive mixed waste  in accordance with all applicable
regulations under the authority of the Atomic Energy Act and  the
Nuclear Waste Policy Act.	

-------
SUMMARY OF REGULATIONS
page A-55
General Aspects of Rule
DEFINITIONS
"In gas/vapor service"
"In heavy liquid
service"
"In light liquid service"
"In liquid service"
"In VOC service"
"In VHAP service"
"In organic hazardous
air pollutant or in
organic (HAP) service"
"In benzene service"
REGULATION
40CFRPart61,
Subpart F
None specified.
None specified.
None specified.
None specified.
The piece of equipment contains
or contacts a process fluid that is
at least 10 percent VOC by
weight and the piece of
equipment is not in heavy liquid
service (as defined under 40 CFR
Part 60, subpart VV).
Not applicable.
None specified.
None specified.
40 CFR Part 61,
Subpart L
A piece of equipment contains process fluid
that is in the gaseous state at operating
conditions.
Not applicable.
Not applicable.
A piece of equipment is not in gas/vapor
service.
The piece of equipment contains or contacts
a process fluid that is at least 10 percent
VOC by weight and the piece of equipment
is not in heavy liquid service (as defined
under 40 CFR Part 60, subpart VV).
A piece of equipment either contains or
contacts a fluid (liquid or gas) that is at
ieast 10 percent by weight a volatile
hazardous air pollutant (VHAP).
Not applicable.
A piece of equipment, other than an
exhauster, contains or contacts a fluid
(liquid or gas) that is at least 10% benzene
by weight.
Any exhauster that contains or contacts a
fluid (liquid or gas) that is at least 1 %
benzene by weight.
40 CFR Part 61,
Subpart FF
None specified.
None specified.
None specified.
None specified.
None specified.
None specified.
None specified.
None specified.
40 CFR Part 264,
Subpart CC
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
40 CFR Part 265,
Subpart CC
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.

-------
SUMMARY OF REGULATIONS
page A-56
General Aspects of Rule
DEFINITIONS
(concluded)
"In vinyl chloride
service"
"No delectable organic
emissions"
Equipment
Exhauster
Process Unit
Repaired
First Attempt at Repair
REGULATION
40CPRPart6I,
Subpari F
A piece of equipment either
contains or contacts a liquid that
is at least 10 percent by weight
vinyl chloride or a gas that is at
least 10 percent by volume vinyl
cliloride.
Not applicable.
None specified.
None specified.
None specified.
None specified.
None specified,
40 CFR Part 61,
SubprtL
Not applicable.
Not applicable,
Each pump, valve, exhauster, pressure
relief device, sampling connection system,
open-ended valve or line, and flange or
other connector in benzene service.
Fan located between the inlet gas flange
and outlet gas flange of the coke oven gas
line that provides motive power for coke
oven gases.
Equipment assembled to produce a VHAP
or its derivatives as intermediate or final
products, or equipment assembled to use a
VHAP in the production of a product. A
process unit can operate independently if
supplied with sufficient feed or raw
materials and sufficient product storage
rnn:t:fU«
Equipment is adjusted, or otherwise
altered, to eliminate a leak.
To take rapid action for the purpose of
stopping or reducing leakage of organic
material to the atmosphere using best
practices.
40 CFR Part 61,
Subpart FF
Not applicable.
Not applicable.
None specified.
None specified.
Equipment assembled and
connected by pipes or ducts to
produce intermediate or final
products, A process unit can be
operated independently if
supplied with sufficient fuel or
raw material and sufficient
None specified.
None specified.
40 CFR Part 264,
Subpart CC
Not applicable.
40 CFR Part 265.
Subparl CC
Not applicable.
No escape of organics from a device or system to the
atmosphere as determined by: (!) an instrument reading less
than 500 ppmv above the background level of each joint, fitting,
and seal and (2) by no visible openings or defects in the device
or system such as rips, tears, or gaps.
Not applicable.
Not applicable.
Not applicable.
None specified.
None specified.
Not applicable.
Not applicable.
Not applicable.
None specified.
None specified.

-------
SUMMARY OF REGULATIONS
page A-57
General Aspects of Rule
EQUIPMENT
IDENTIFICATION (see
also Recordkeeping
Requirements)
COMPLIANCE
DEMONSTRATIONS
METHOD OF
COMPLIANCE
DETERMINATION
REQUIREMENTS
WHEN MORE THAN
ONE STANDARD
APPLIES
REGULATION
40CFRPart61,
Subpart F
If complying with subpart V:
Marked in manner such that it
can be readily distinguished from
other pieces of equipment.
Not required for process units
with less than 1% leaking valves.
40 CFR Part 6i,
Subpart L
Marked in manner such that it can be
readily distinguished from other pieces of
equipment in benzene service.
40 CFR Part 61,
Subpart FF
None specified.
For existing sources, shall be in compliance within 90 days after the effective date of the applicable standard.
For new sources, shall be in compliance upon effective date of the applicable standard.
Review of records, review of performance test results, and inspections.
A source subject to this subpart
that is also subject to 40 CFR
Part 60 only will be required to
comply with the provisions of
this subpart.
None specified.
None specified.
None specified.
40 CFR Part 264,
Subpart CC
None specified.
None specified.
None specified.
None specified.
40 CFR Part 265,
Subpart CC
None specified.
None specified.
None specified.
None specified.

-------
SUMMARY OF REGULATIONS
page A-58
Specific
Component
Summaries
REGULATION
40 CFR Part 61,
Subpart F
40 CFR Part 61,
Subpart L
40CFRPartfil,
Subpart FP
40 CFR Part 264,
Subpart CC
40 CFR Part 265,
Subpart CC
PROCESS UNIT/PLANT AREA
Standards


Leak
Definition



Repair
Exemptions
Vinyl chloride (VC)
monitoring system capble of
detecting major leaks and
identification of the general
area of the plant where the
leak is located.
System to be operated
according to plan developed
by plant owner or operator.
Location and number of points
to be monitored and the
frequency of the monitoring
based on the number of pieces
of equipment in VC service
and the size and physical
layout of the plant.
Determined by plant owner or
operator.
Acceptable definition when
compared to background
concentrations of vinyl
chloride in the areas of the
plant to be monitored for
teaks.
Definition of a leak may vary
from area to area.
Is to change over time as
background concentrations are
reduced.
None specified. Plan is to
include action to be taken
when a leak is detected.
None specified.
Not applicable.


Not applicable.



Not applicable.
Not applicable.
Not applicable.


Not applicable.



Not applicable.
Not applicable.
Not applicable.


Not applicable.



Not applicable.
Not applicable.
Not applicable.


Not applicable.



Not applicable.
Not applicable.

-------
SUMMARY OF REGULATIONS
page A-59
Specific
Component
Summaries
REGULATION
40CFRPart6l,
Subpart F
40 CFR Part 61,
Subpart L
40 CFR Part 61,
Subpart FF
40 CFR Part 264,
Subpart CC
40 CFR Part 265,
Subpart CC
VALVES, GAS/VAPOR OR LIGHT LIQUID SERVICE
Standards













Leak
Definition

If complying with subpart V,
40 CFR Part 61:
Monitor monthly.
After two consecutive months
of no leaks, a valve may be
monitored quarterly.
If leak detected, monitor valve
monthly until leak is not
detected for two consecutive
months.
Not required for process units
with less than 2% leaking
valves.
"No detectable emissions"
valves: less than 500 ppm
above background.
"Unsafe-to-monitor" valves:
written plan to monitor as
frequently as practicable
during safe-to-monitor times.
"Diffieult-to-monitor" valves:
written plan to monitor at least
once per year.
If complying with subpart V,
40 CFR Part 61;
10,000 ppm

Monitor monthly.
After two consecutive months of no
leaks, a valve may be monitored
quarterly.
If leak detected, monitor valve
monthly until leak is not detected for
two consecutive months.


"No detectable emissions" valves:
less than 500 ppm above
background.
"Unsafe-to-monitor" valves: written
plan to monitor as frequently as,, -
practicable during safe-to-monitor
times.
"Difficult-to-monitor" valves:
written plan to monitor at least once
per year.

10,000 ppm
Not applicable.













Not applicable.

Not applicable.













Not applicable.

Not applicable.













Not applicable.


-------
SUMMARY OF REGULATIONS
page A-60
Specific
Component
Summaries
REGULATION
40CFRPart6i,
Subpari F
40 CFR Part 61,
Subpart L
40 CFR Part 61,
SubjMrt FF
40 CFR Part 264,
Subpart CC
40 CFR Part 265,
Subpart CC
VALVES, GAS/VAPOR OR LIGHT LIQUID SERVICE (concluded)
Repair


First Attempt
at Repair


Exemptions
If complying with subpart V,
40 CFR Part 61;
Repair as soon as practicable,
no later than 15 calendar days
after detection.
First attempt within 5 calendar
days of detection.
If complying with subpart V,
40 CFR Part 61;
Best practices include, but are
not limited to;
- tightening of bonnet bolts
- replacement of bonnet bolts
- tightening of packing gland
nuts
- injection of lubricant into
lubricated packing
If complying with subpart V,
40CFRPart61:
Equipment in vacuum service.

Repair as soon as practicable, no
later than 15 calendar days after
detection.
First attempt within 5 calendar days
of detection.

Best practices include, but are not
limited to:
- tightening of bonnet bolts
- replacement of bonnet bolts
- tightening of packing gland nuts
- injection of lubricant into
lubricated packing
Equipment in vacuum service.
Not applicable,


Not applicable.


Not applicable.
Not applicable.


Not applicable.


Not applicable.
Not applicable,


Not applicable.


Not applicable

-------
SUMMARY OF REGULATIONS
page A-61
Specific
Component
Summaries
REGULATION
40 CFR Part 61,
Subpart F
40 CFR Part 61,
Subpart L
40 CFR Part 61,
Subpart FF
40 CFR Part 264,
Subpart CC
40 CFR Part 265,
Subpart CC
i
ALTERNATIVE STANDARDS FOR VALVES
Allowable Percentage of Valves Leaking
Standard







Leak
Definition

Repair


If complying with subpart V,
40 CFR Part 61:
Notify Administrator of
election to comply with
alternative standard.
Conduct performance test
initially, annually, and at other
times as requested by the
Administrator.
Performance tests shall:
- Monitor all valves in
gas/vapor and in light liquid
service within one week.
- Calculate percent leaking.
- Equal to or less than 2.0
percent leaking.

If complying with subpart V,
40 CFR Part 61:
10,000 ppm
If complying with subpart V,
40 CFR Part 61:
Repair as soon as practicable,
no later than 15 calendar days
after detection.
First attempt within 5 calendar

Notify Administrator of election to
comply with alternative standard.
Conduct performance test initially,
annually, and at other times as
requested by the Administrator,
Performance tests shall:
- Monitor all valves in gas/vapor
and in light liquid service within one
week.
- Calculate percent leaking.
- Equal to or less than 2.0 percent
leaking,
Notify Administrator in writing
when owner or operator elects to no
longer comply with alternative
standard.

10,000 ppm

Repair as soon as practicable, no
later than IS calendar days after
detection.
First attempt within 5 calendar days
r\? H**frw»mn
Not applicable.







Not applicable.

Not applicable.


Not applicable.







Not applicable.

Not applicable.


Not applicable.







Not applicable.

Not applicable.



-------
SUMMARY OF REGULATIONS
page A-62
Specific
Contponert
Summaries
REGULATION
40 CH? Part 61,
Subpart P
4QCFRPart«,
Subpart L
40 CFR Part 61,
Subprt FF
40 CFR Part 264.
Subpart CC
40 CFR Part 265,
Subpuri CC
Allowable Percentage of Valves Leaking (concluded)
First Attempt
at Repair
If complying with subparl V,
40 CFR Part 61:
Best practices include, but are
not limited to:
- tightening of bonnet bolts
- replacement of bonnet
bolts
- tightening of packing gland
nuts
- injection of lubricant Into
lubricated packing
Best practices include, but are not
limited to;
- tightening of bonnet bolts
- replacement of bonnet bolts
- tightening of packing gland nuts
- injection of lubricant into
lubricated packing
Not applicable.
Not applicable.
Not applicable.

-------
                                                                      SUMMARY OF REGULATIONS
                                                                                                                                                             page A-63
   Specific
 Component
 Summaries
                                                                                            REGULATION
      40CFRPart6i,
         Subpart F
40CFRPart61,
   Subpart L
40CFRPart61,
  Subpart FF
40 CFR Part 264,
   Subpart CC
40 CFR Part 265,
   Subpart CC
Skip Period Leak Detection and Repair
     Standard
If complying with subpart V,
40 CFR Part 61:

Notify Administrator of
election to comply with
alternative standard.
               Conduct performance test
               initially, annually, and at other
               times as requested by the
               Administrator.

               Comply initially with monthly
               LDAR, then:

                1. After 2 consecutive
               quarters with equal to or less
               than 2 percent leakers,
               monitor semiannually; or

                2. After 5 consecutive
               quarters with equal to or less
               than 2 percent leakers,
               monitor annually.

               Revert to monthly monitoring
               if percent leakers exceed 2
               percent.	
                                             Notify Administrator of election to
                                             comply with alternative standard.
                              Conduct performance test initially,
                              annually, and at other times as
                              requested by the Administrator.
                              Comply initially with monthly
                              LDAR, then either;

                               1,  After 2 consecutive quarters
                              with equal to or less than 2 percent
                              leakers, monitor semiannually.
                               2.  After 5 consecutive quarters
                             with equal to or less than 2 percent
                             leakers, monitor annually.
                              Revert to monthly monitoring if
                              percent leakers exceed 2 percent.
                          Not applicable.
                          Not applicable.
                          Not applicable.

-------
                                                                    SUMMARY OF REGULATIONS
                                                                                                                                                   page A-64
   Specific
 Component
 Summaries
                                                                                          REGULATION
40 CFR Part 61,
   SubpartF
40 CFR Part 61,
   Subpart L
40 CFR Part 61,
  Subpart FF
40 CFR Part 264,
   Subpart CC
40 CFR Part 265.
   Subprt CC
PUMPS, LIGHT LIQUID SERVICE
    Standards   Rotating Pumas
               Minimize VC emissions by
               installing sealless pumps,
               pumps with double mechanical
               seals or equivalent. If double
               mechanical seals are used,
               minimize VC emissions by
               maintaining the pressure
               between the two seals so that
               any leak that occurs is into the
               pump; by ducting any vinyl
               chloride between the two seals
               through a control system from
               which the VC concentration in
               the exhaust gases does not
               exceed 10 ppm; or equivalent.

               Reciprocating Pumps

               Minimize VC emissions by
               installing double outboard
               seals, or equivalent. If double
               outboard seals are used,
               minimize VC emissions by
               maintaining the pressure
               between the two seals so that
               any leak that occurs is into the
               pump; by ducting any vinyl
               chloride between the two seals
               through a control system from
               which the VC concentration in
               the exhaust gases does not
               exceed 10 ppm; or equivalent.
                       Pumps; Monitor monthly and
                       conduct weekly visual inspections,
                       If located at unmanned plant site,
                       visual inspections required at least
                       monthly.

                       "Dual Mechanical Seal" Pumps;
                       specific operating and design
                       requirements.

                       "No Detectable Emissions" Pumps:
                       less than 500 ppm above
                       background and specified design
                       requirements.
                         Not applicable.
                         Not applicable.
                          Not applicable.

-------
                                                                    SUMMARY OF REGULATIONS
                                                                                                                                                         page
   Specific
 Component
 Summaries
                                                                                         REGULATION
      40 Cm Part 61,
         Subpart F
40 CFR Part 61,
   Subpart L
40 CFR Part 61,
  Subpart FF
40 CFR Part 264,
   Subpart CC
40 CFR Part 265,
   Subpart CC
PUMPS, LIGHT LIQUID SERVICE (continued)
    Standards
   (concluded)
Alternatively, comply with
subpart V, part CFR Part 61:

Pumps:  Monitor monthly and
conduct weekly visual
inspections.  . If located at
unmanned plant site, visual
inspections required at least
monthly,

"Dual Mechanical Seal™
Pumps:  specific operating and
design requirements.

"No Detectable Emissions"
Pumps:  less than 500 ppm
above background and
specified design requirements.
        Leak
    Definition
If complying with subpart V,
40 CFR Part 61:

10,000 ppm

Indications of liquids dripping
from pump seal

"Dual Mechanical Seal"
Pumps: Indications of liquid
dripping from pump seal
where monitoring for VHAP
indicates the presence of
VHAP (less background
reading) and for monitoring
total VOC measures greater
than 10,000 ppm	
                         Not applicable.
                         Not applicable.
                          Not applicable.
                                            10,000 ppm

                                            Indications of liquids dripping from
                                            pump seal

                                            "Dual Mechanical Seal" Pumps:
                                            Indications of liquid dripping from
                                            pump seal where monitoring for
                                            VHAP indicates the presence of
                                            VHAP (less background reading)
                                            and for monitoring total VOC
                                            measures greater than  10,000 ppm

-------
SUMMARY OF REGULATIONS
page A-66
Specific
Component
Summaries
REGULATION
4QCFRPart6l,
Subpart F
40CFRParl6I,
Subpart L
40CPRPart6l,
Subpart FF
40 CFR Part 264,
Subparl CC
40 CFR Part 265.
Subprt CC
PUMPS, LIGHT LIQUID SERVICE (concluded)
Repair
First Attempt
at Repair
Exemptions
If complying with subpart V,
40CFRPart6I:
Repair as soon as practicable,
no later than IS calendar days
after detection,
First attempt within 5 calendar
days of detection,
None specified.
None specified.
Repair as soon as practicable, no
later than IS calendar days after
detection.
First attempt within 5 calendar days
of detection.
None specified.
Equipment in vacuum service.
Any pump equipped with a
compliant closed-vent system and
control device.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.

-------
SUMMARY OF REGULATIONS
page A-67
Specific
Component
Summaries
REGULATION
40CFRPart61,
Subpart F
40CFRPart61,
Subpart L
40CFRPart61,
- Subpart FF
40 CFR Part 264,
Subpart CC
40 CFR Part 265,
Subpart CC
PRESSURE RELIEF DEVICES, GAS/VAPOR SERVICE
Standards
Leak
Definition
Repair
Exemptions
Discharges: No discharge to
the atmosphere.
Leaks: No detectable
emissions (less than 500 ppm
above background).
After each release, return to
no detectable emissions within
5 calendar days as indicated
by monitoring of the pressure
relief device.
Leaks: "No detectable
emissions" - less than 500
ppm above background.
Leaks: Return to condition of
"no detectable emissions" as
soon as practicable but no
later than 5 calendar days after
pressure release.
Emergency relief discharges
or relief valve discharges
ducted to control device
continually operating while the
emissions from the release are
present at the device,
"Emergency relief discharge"
means a discharge that could
not have been avoided by
taking measures to prevent the
discharge,
No detectable emissions (less than
500 ppm above background).
After each release, return to no
detectable emissions within 5
calendar days as indicated by
monitoring of the pressure relief
device.
"No detectable emissions" - less
than 500 ppm above background.
Return to condition of "no
detectable emissions" as soon as
practicable but no later than 5
calendar days after pressure release.
Pressure relief devices equipped
with compliant closed-vent system
and control device.
Equipment in vacuum service.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable,
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.

-------
SUMMARY OF REGULATIONS
page A-68
Specific
Component
Summaries
REGULATION
40 CFR Pan 61.
Subpan F
40 CFR Part 6!,
Subpart L
40 CFR Part 61,
Subpart FF
40CFRPirt264,
Subpart CC
40 CFR Part 265,
Subpart CC
PRESSURE RELIEF DEVICES, LIGHT LIQUID OR HEAVY LIQUID SERVICE
Standards
Leak
Definition
Repair
Exemptions
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Monitoring of potential leaks within
5 calendar days of detection If
evidence of potential leak is found
by visual, audible, olfactory, or
other detection method.
10,000 ppm
Repair as soon as practicable, no
later than 15 calendar days after
detection,
First attempt within 5 calendar days
of detection.
Equipment in vacuum service.
Not applicable.
Not applicable,
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.

-------
                                                                    SUMMARY OF REGULATIONS
                                                                                                                                                          page A-69
   Specific
 Component
 Summaries
                                                                                          REGULATION
      40CFRPart6i,
         Subpart F
        40CPRPart61,
           Subpart L
        40CFRPart61,
          Subpart FF
        40 CFR Part 264,
          Subpart CC  '
         40 CFR Part 265,
            Subpart CC
COMPRESSORS
    Standards
Rotating Compressors

Minimize VC emissions by
installing compressors with
double mechanical seals or
equivalent.  If double
mechanical seals are used,
minimize vinyl chloride
emissions by maintaining the
pressure between the two seals
so that any leak that occurs is
into the compressor; by
ducting any vinyl chloride
between the two seals through
a control system from which
the VC concentration in the
exhaust gases does not exceed
10 ppm; or equivalent,

Reciprocating Pumps

Minimize VC emissions by
installing double outboard
seals, or equivalent. If double
outboard seals are used,
minimize VC emissions by
maintaining the  pressure
between the two seals so that
any leak that occurs is Into the
compressor; by  ducting any
vinyl chloride between the two
seals through a control system
from which the  VC
concentration in the exhaust
gases does not exceed 10 ppm;
or equivalent.	
Not applicable.
Not applicable.
Not applicable.
Not applicable.

-------
SUMMARY OF REGULATIONS
page A-7Q

Specific
Component
Summaries
REGULATION

40 CFR Part 61,
Subpart F
40 CFR Part 61,
Subpart L
40 CFR Part 61.
Subpart FF
40 CFR Part 264.
Subpart CC
40 CFR Part 265,
Subpart CC
COMPRESSORS (continued)
Standards
(concluded)

















Leak
Definition




Alternatively, comply with
subpart V, 40 CFR Part 61:
Equip with seal system that
includes a barrier fluid system
and that prevents leakage to
atmosphere.
Seal system shall meet certain
design and operation
requirements.
Install sensor to detect failure
of seal system, barrier fluid
system, or both.
Check sensor daily or equip
with audible alarm (unless
located at unmanned plant
site).
Establish criteria that indicates
failure of seal system, barrier
fluid system, or both.
If complying with subpart V,
40 CFR Part 61:
Sensor indicates failure of seal
system, barrier fluid system,
or both based on established
criteria.



















Not applicable.
























Not applicable.
























Not applicable.
























Not applicable.






-------
SUMMARY OF REGULATIONS
page A-71
Specific
Component
Summaries
REGULATION
40 CFR Part 61,
Subpart F
40CFRPart61,
Subpart L
40CFRPart61,
Subpart FF
40 CFR Part 264,
Subpart CC
40 CFR Part 265,
Subpart CC
COMPRESSORS (concluded)
Repair
Exemptions
If complying with subpart V,
40CFRPart61:
Repair as soon as practicable,
no later than 15 calendar days
after detection.
First attempt within 5 calendar
days of detection.
None specified.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.

-------
SUMMARY OF REGULATIONS
page A-72

Specific
Component
Summaries
REGULATION

4QCFRPirt6i,
SubprtF
40 CFR Part 61,
Subpart L
40 CFR Part 61,
Subpart FF
40 CFR Part 264,
Subprt CC
40 CFR Part 265,
Subprt CC
SAMPLING CONNECTION SYSTEMS
Standards




















Leak
Definition
Repair
Exemptions




Unused portions of samples
containing at least 10 percent
by weight VC are to be
returned to the process or
destroyed in a compliant
control device. Sampling
techniques are to be such that
samples containers in VC
service are purged into a
closed process system.
Alternatively, comply with
subpart V, 40 GFR Part 61:
Equipped with closed-purge
system or closed-vent system
that either returns the fluid to
the process line or collects and
recycles the purged fluid with
zero VHAP emissions to the
atmosphere, or captures and
transports all purged fluids to
a compliant control device,
Not applicable.

Not applicable.
If complying with subpart V,
40CFRPart61:

Equipment in vacuum service.
In-situ sampling systems.
Equipped with closed-purge system
or closed-vent system that either
returns the fluid to the process line
or collects and recycles the purged
fluid with zero VHAP emissions to
the atmosphere, or captures and
transports all prged fluids to a
compliant control device.













Not applicable.

Not applicable.
Equipment in vacuum service.

In-situ sampling systems.


Not applicable.




















Not applicable.

Not applicable.
Not applicable.




Not applicable.




















Not applicable.

Not applicable.
Not applicable.




Not applicable.




















Not applicable.

Not applicable.
Not applicable.





-------
SUMMARY OF REGULATIONS
page A-73

Specific
Component
Summaries
REGULATION

40 CFR Part 61,
Subpart F
40 CFR Part 61 ,
Subpart L
40 CFR Part 61,
Subpart FF
40 CFR Part 264,
Subpart CC
40 CFR Part 265,
Subpart CC
OPEN-ENDED VALVES OR LINES
Standards





















Leak
Definition
Repair
Exemptions










Comply with subpart V, 40
CFR Part 61:

Equip with cap, blind flange,
plug, or second valve to seal
open end at all time except
when operations require flow
through open end.

Second Valve

Close valve on process fluid
end prior to closing second
valve

Double Block and Bleed
System
May remain open during
operations that require venting
the line between the block
valves, but comply with basic
standard at all other times.
Not applicable.

Not applicable.
OELs located on multiple
service process lines that
operate in VC service less
than 10 percent of the time,
provided they are addressed in
the process unit/plant area
monitoring system.
Exemption may be extended to
OELS demonstrated to require
significant retrofit cost to
comply with subpart V.
Equip with cap, blind flange, plug,
or second valve to seal open end at
all time except when operations
require flow through open end.

Second Valve

Close valve on process fluid end
prior to closing second valve

Double Block and Bleed System

May remain open during operations
that require venting the line between
the block valves, but comply with
basic standard at all other times.






Not applicable.

Not applicable.
Equipment in vacuum service.










Not applicable.





















Not applicable.

Not applicable.
Not applicable.










Not applicable.





















Not applicable.

Not applicable.
Not applicable.










Not applicable.





















Not applicable.

Not applicable.
Not applicable.











-------
SUMMARY OF REGULATIONS
page A-74
Specific
Component
Summaries
REGULATION
40 CFR Part 61,
Subparl F
40 CFR Part 6i,
Subpart L
40CFRPart61,
Subpart FF
40 CFR Part 264,
Subptrt CC
40 CFR Part 265,
Subprt CC
FLANGES AND OTHER CONNBCT01S (ALL SERVICES)
Standards
Leak
Definition
Repair
Exemptions
Comply with subpart V, 40
CFR Part 61:
Monitor within 5 days if
evidence of a potential leak is
found by visual, auditory,
olfactory, or other detection
methods.
10,000
Repair as soon as practicable,
no later than 15 calendar days
after detection.
First attempt within 5 calendar
days of detection.
Equipment in vacuum service.
Not required for process units
with less than 2% leaking
valves.
Monitor within 5 days if evidence of
a potential leak Is found by visual,
auditory, olfactory, or other
detection methods.
10,000
Repair as soon as practicable, no
later than 15 calendar days after
detection.
First attempt within 5 calendar days
of detection.
Equipment in vacuum service.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.

-------
SUMMARY OF REGULATIONS
page A-'P


Component
Summaries
REGULATION

40CFRPart6I,
Subpart F
40CFRPart61,
Subpart L
40CFRPart6i,
Subpart FF
40 CFR Part 264,
Subpart CC
40 CFR Part 265,
Subpart CC
AGITATORS, GAS/VAPOR SERVICE OR LIGHT LIQUID SERVICE
Standards















Leak
Definition
Repairs
Exemptions
Minimize VC emissions by
installing agitators with double
mechanical seals, or
equivalent, If double
mechanical seals are used,
minimize VC emissions by
maintaining the pressure
between the two seals so that
any leak that occurs is into the
agitated vessel; by ducting any
vinyl chloride between the two
seals through a control system
from which the VC
concentration in the exhaust
gases does not exceed 10 ppm;
or equivalent.
None specified.

None specified,
None specified.
Not applicable.















Not applicable.

Not applicable,
Not applicable,
Not applicable.















Not applicable.

Not applicable.
Not applicable.
Not applicable.















Not applicable.

Not applicable.
Not applicable.
Not applicable.















Not applicable.

Not applicable.
Not applicable.

-------
SUMMARY OF REGULATIONS
page A-76
Specific
Component
Summaries
REGULATION
40 CFR Pan 61,
Subpart F
4QCFRPart6l,
Subpart L
40CFRP»rt«,
Subpart FF
40 CFR Part 264,
Subpart CC
40 CFR Part 265,
Subpart CC
PRODUCT ACCUMULATOR VESSELS
Standards
Leak
Definition
Repair
Exemptions
Compliant closed-vent system
and control device.
Not applicable.
Not applicable.
Equipment in vacuum service.
Not required for process units
with less than 2% leaking
valves.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.

-------
                                                                       SUMMARY OF REGULATIONS
                                                                                                                                                               page A-77
   Specific
 Component
 Summaries
                                                                                             REGULATION
      40 CFR Part 61,
         Subparl F
         40CFRPart61,
            Subpart L
         40CFRPart6i,
           Subpart PF
        40 CFR Part 264,
           Subpart CC
40 CFR Part 265,
   Subpart CC
CLOSED VENT SYSTEMS AND CONTROL DEVICES
    Standards
Continually operating while
emissions from the release are
present,

Control Devices

Other than flares: limit VC
emissions to less than 10 ppm
(average over 3-hour period)

Flares: Comply with §60.18.
Control devices and closed-vent
systems to be operated at all time
that emissions may be vented to
them.

Control Devices

Vapor recovery systems: 95
percent or greater recovery

Combustion devices: 95 percent or
greater reduction or minimum
residence time of 0,50 seconds and
minimum temperature of 760°C,

Flares: Comply with §60.18

Closed-Vent Systems iCVS)

No detectable emissions (less than
500 ppm above background) and no
visual indications.
Control devices and closed-vent
systems to be operated at all times
when waste is placed in the waste
management unit, except when
maintenance or repair cannot be
completed without a shutdown of the
control device.

Closed-Vent System (CVS)

No detectable emissions  (less than
500 ppmv above background).

All gauging and sampling devices
are to be gas-tight except when in
operation.

Control Devices

Enclosed  combustion device:
 reduce organic emissions  by
>_95% by weight

 achieve  a total organic  compound
concentration of 20 ppmv on a dry
basts corrected to 3% O2

 minimum residence time of 0.5 sec
at minimum temperature of 760°C

Boiler/Process Heater:

 introduce vent stream into flame
zone
Operating at all times when gases, vapors, or fumes are vented from the waste
management unit through the CVS to the control device.

Control Devices

Designed and operated to reduce total organic content of the inlet vapor stream
vented to the control device by at least 95% by weight.

For carbon adsorbers, carbon replacement intervals specified [see §264.1033(g)
and (h)].

Enclosed combustion devices: 95 percent or greater reduction; 20 ppmv total
organic compound concentration; or minimum residence time of 0,50 seconds
and minimum temperature of 760°C,

Boilers and process heaters: Introduce vent stream into flame combustion zone.

Flares: Flame present at all times, no visible emissions (except for periods not
to exceed a total of 5 minutes during any 2 consecutive hours), basic
requirements for heat content and exit velocities.

An applicable control device other than a thermal vapor incinerator, flare,
boiler, process heater, condenser, or carbon adsorption system: develop
documentation including sufficient information to describe the  control device
operation and identify process parameter(s) that indicate proper operation and
maintenance of the control device.

Closed-Vent System (CVS)

Designed for and operated with no detectable emissions.

Route gases, vapors, and fumes emitted from the hazardous waste to a control
device.

If the system contains one or more bypass devices that could be used to divert
gases, vapors, or fumes  from entering the control device, §264.1087(b)(3)
requirements apply.	

-------
                                                                  SUMMARY OF REGULATIONS
                                                                                                                                              page A-78
   Specific
 Component
 Summaries
                                                                                       REGULATION
40 CFR Part 61,
   Subpsm P
40 CFR Pan 61.
   SubpartL
40 CFR Part 61,
  Subpirt FF
40 CFR Part 264,
   SubpartCe
40 CFR Part 265,
   SubpirtCC
CLOSED VBNT SYSTEMS AND CONTROL DEVICES (continued)
    Standards
  (concluded)
                                                       Vapor recovery system:

                                                        >.95% (by weight) recovery or
                                                       control efficiency of the organic
                                                       emissions
                                                                             >.9B% (by weight) recovery or
                                                                           control efficiency of the benzene
                                                                           emissions

                                                                           Flares: Comply with §60,18

                                                                           Other Control Devices:

                                                                            J>.95% (by weight) recovery or
                                                                           control efficiency of the organic
                                                                           emissions
                                                                            J>.98% (by weight) recovery or
                                                                           control efficiency of the benzene
                                                                            develop test data and design
                                                                           information to document efficiency

                                                                            identify critical operating
                                                                           parameters, range of values of these
                                                                           parameters that ensure emission
                                                                           control efficiency and how these
                                                                           will be monitored

                                                                           CVS and CDs:

                                                                            visually inspect initially and
                                                                           quarterly thereafter

                                                                            include ductwork, piping, and
                                                                           connections for evidence of visible
                                                                           defects (e.g., holes, loose
                                                                           connections)

-------
SUMMARY OF REGULATIONS
page A-79

Specific
Component
Summaries
REGULATION

40CPRPart61,
Subpart F
40CFRPart61,
Subpart L
40CPRPart61,
Subpart FF
40 CFR Part 264, 40 CFR Part 265,
Subpart CC Subpart CC
CLOSED VENT SYSTEMS AND CONTROL DEVICES (concluded)
Monitoring














Leak
Definition

Repair

Exemptions
Not applicable,














Not applicable.


Not applicable.

Not applicable.
Control Devices; Monitor to ensure
operated and maintained in
conformanee with their designs.

Closed- Vent Systems: Initially,
annually, and at other times as
requested by the Administrator.








Not applicable.


Control Devices: Continuous
monitoring of operations

Closed-Vent Systems: Monitor
initially and at least once per year
thereafter.

If contains by-pass lines, (1) vent
stream flow indicators or (2) car-
seal or lock-and-key type of
configuration with monthly visual
inspection required.
Visually inspect flow monitoring
device at least once per operating
day.
Monitoring: 500 ppm

Visual: visible defects
Closed-Vent Systems (CVS): Initially, annually, and at other times as
requested by the Administrator,

If contains by-pass lines, (1) vent stream flow meters or (2) car-seal or lock-and-
key type of configuration with monthly visual inspection required.










CVS: detectable emissions >.500 above background


Repair as soon as practicable, but no later than 1 5 calendar days after detection.
First attempt to repair within 5 calendar days of detection.
Equipment In vacuum service.
None specified.
Not applicable. Not applicable.

-------
                                                                   SUMMARY OF REGULATIONS
                                                                                                                                                       page A-80
   Specific
 Component
 Summaries
                                                                                        REGULATION
      4QCFRPart61,
         Subpan F
        4QGFRPart6l.
           Subpan L
        40CFRPan6t,
          Subpart FF
       40 CFR Part 264,
          Subpart CC
         40 CFR Part 265.
            SubpanCC
PROCESS VESSELS, STORAGE TANKS, AND TAR-INTERCEPTING SUMPS
    Standards
Not applicable.
Option 1; Duet to a control device
designed and operated tor no
detectable emissions as indicated by
an instrument reading of less than
SOO ppmv above background and
visual inspections.

Monitor the connections and seals
on each control system to determine
if it is operating with no delectable
emissions.

Visually inspect each source,
including sealing materials, and the
ductwork of the control system for
evidence of visible defects (e.g.,
tears, gaps).

Conduct monitoring and visually
inspection semi-annually and at any
other time after the control system is
rcprcssurized.

Option 2: Install, operate, and
maintain a pressure relief device,
vacuum relief device, access hatch,
and sampling port. Equip each
hatch and sampling port with gasket
and cover, seal, or lid that is closed
at all times except when in use.

Use of sludge conveyors requires
operation of %vater leg seal on tar
decanter roof to ensure enclosure of
the major portion of the liquid
surface not necessary of its
operation.	
Not applicable.
Not applicable.
Not applicable.

-------
SUMMARY OF REGULATIONS
page A-81
Specific
Component
Summaries
REGULATION
40CFRPart61,
Subpart F
40CFRPart61,
Subpart L
40CFRPart61,
Subpart FF
40 CFR Part 264,
Subpart CC
40 CFR Part 265,
Subpart CC
PROCESS VESSELS, STORAGE TANKS, AND TAR-INTERCEPTING SUMPS (concluded)
Leak
Definition
Repair
Exemptions
Not applicable.
Not applicable.
Not applicable.
Monitoring: 500 ppmv above
background level.
Visual: Visible defects are
observed.
Repair as soon as practicable, but no
later than 1 5 calendar days after
detection.
First attempt to repair within 5
calendar days of detection.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.

-------
                                                                     SUMMARY OF REGULATIONS
                                                                                                                                                           page A-82
  Specific
 Component
 Summaries
                                                                                           REGULATION
      40 CFR Part 61,
         SubpnriP
        40 CFR Part 61,
           Subpart L
        40 CFR Part 61,
           Subpart PF
        40 CFR Part 264.
           Subpar! CC
         40 CFR Part 265.
            Subpart CC
LIGHT-OIL SUMPS
    Standards
Not applicable.
Option!: Enclose and seat the
liquid surface in llic sump to form a
closed system to contain lite
emissions.

Option 2: Install, operate, and
maintain a vent on the light-oil sump
cover. Equip each vent pipe with a
water leg seal, a pressure relief
device, or vacuum relief device.

Option 3: Install, operate, and
maintain an access hatch on each
light-oil sump cover. Equip each
hatch with a gasket and a cover,
seal, or lid that is kept closed except
when in use.

Covers may be removed for
maintenance but must be replaced
with seal at completion of
maintenance.

If control equipment is used to
comply;

 monitor the connections and seals
on each control system to determine
if it is operating with no detectable
emissions.

 visually inspect each source,
including sealing materials, for
evidence of visible defects (e.g.,
tears, gaps),

 conduct this monitoring and
inspection semtannually and at any
other time the cover is  removed.
Not applicable.
Not applicable.
Not applicable.

-------
SUMMARY OF REGULATIONS
page A-83
Specific
Component
Summaries
REGULATION
40CFRPart61,
Subpart F
40CFRPart61,
Subpart L
40 CFR Part 61,
Subpart FF
40 CFR Part 264,
Subpart CC
40 CFR Part 265,
Subpart CC
LIGHT-OIL SUMPS (concluded)
Leak
Definition
Repair
Exemptions
Not applicable.
Not applicable.
Not applicable.
Monitoring: 500 ppmv above
background level.
Visual: Visible defects are
observed.
Repair as soon as practicable, but no
later than 15 calendar days after
detection.
First attempt to repair within 5
calendar days of detection.
Not applicable.
• Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.

-------
SUMMARY OF REGULATIONS
page A-84

Specific
Component
Summaries
TANKS
Standards





















Leak
Definition

Repair


Exemptions








40CFRPart61,
Subpwt F

Not applicable.





















Not applicable.


Not applicable.


Not applicable.








40CFRPart<51,
Subpart L

Not applicable.





















Not applicable.


Not applicable.


Not applicable.






REGULATION

40CFRPart6I.
Subpirt FF

Option 1: Compliant fixed roof (sec
Covers) and compliant closed-vent
system and control device.
Option 2: Compliant fixed roof
provided certain conditions arc met
including but not limited to the
following maximum organic vapor
pressure and size requirements:

Capacity Vapor pressure
(cubic meters) fkilopaseals)

not specified 5,2
>75to<151 27.6
<75 76.6

Each fixed roof, seal, access door,
and other opening: initial and
quarterly inspections for cracks and
gaps and that access doors and other
openings are closed and properly
gasketed.
Broken seal or gasket.

Detectable emissions measured.
As soon as practicable, but not later
than 45 calendar days after
irientificfltion.
Tanks with fixed roof and internal
floating roo'f meeting
§60.112b(a)(l).
External floating roots that comply
with 860. 112b(a)(2).
Alternative means of emission
limitation. (§60.1 14b)


40 CFR Part 264. 40 CFR Part 265.
Subpart CC Subpart CC

Pressure tanks; no detectable organic emissions

Non-pressure tanks:
Option 1: Compliant cover and compliant closed-vent system and control
device.

Option 2; Compliant cover provided certain conditions arc met including but
not limited to the following maximum organic vapor pressure and size
requirements:

Capacity Vapor pressure
(cubic meters) fkilopascalsl

>IS1 5.2
>75to<151 27.6
<75 76.6

Option 3: Equipped with fixed roof and internal floating roof that meets
§265.1091 or (§60.1 12b).

Option 4: Equipped with external floating roof that meets §265. 1 091
(or§60.112b).
(see Covers)


(see Covers)


A tank that meets all of the requirements identified in §265.1083©
[§264. 1082(c)] including but not limited to an average VO concentration of the
hazardous waste at the point of waste origination is <100 ppmw.
Tanks used for biological treatment of hazardous waste in accordance with
§265. 1 083O [§264. 1 082(c)(2)(iv)].



-------
SUMMARY OF REGULATIONS
page A-85
Specific
Component
Summaries
REGULATION
40 CFR Part 61,
Subpart F
40CFRPart61,
Subpart L
40 CFR Part 61,
Subpart FF
40 CFR Part 264, 40 CFR Part 265,
Subpart CC Subpart CC
SURFACE IMPOUNDMENTS
Standards
Leak
Definition
Repair
Exemptions
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Compliant covers (see Covers) that
are vented to compliant closed-vent
system and control device.
Inspect initially and quarterly
thereafter for cracks or gaps.
Broken seal or gasket.
As soon as practicable, but not later
than IS calendar days after
identification.
None specified.
Option 1 ; Compliant covers that are vented to compliant closed-vent system
and control device.
Option 2: Floating membrane cover that meets certain requirements including
designed to operate with no detectable organic emissions.
(see Covers)
(see Covers)
A surface impoundment that meets all of the requirements identified in
§265.10830 [P64,l082(c)] including but not limited to an average VO
concentration of the hazardous waste at the point of waste origination is <100
ppmw.
Surface impoundments used for biological treatment of hazardous waste In
accordance with §265.1083(c)(2)(iv) [§264.1082(c)(2)(iv)].

-------
SUMMARY OF REGULATIONS
page A-86

Specific
Component
Summaries
REGULATION

40 era Pan 61,
SubpartF
40 CFR Part 61.
Subpart L
40 CFR Part 61,
Subpart FF
40 CFR Part 264, 40 CFR Part 265,
Subpart CC Subpart CC
CONTAINERS
Standards




























Leak
Definition
Repair


Not applicable.




























Not applicable.

Not applicable.


Nol applicable.




























Not applicable.

Not applicable.


Compliant cover (see Covers)
designed for no detectable
emissions.
Monitor initially and annually
there after.

Maintain cover in closed, sealed
position.
Treatment Containers:

Locate in compliant enclosure
vented to compliant closed vent
system and control device.

Compliant Enclosure: designed
and operated with sufficient airflow
to capture organic vapors emitted
from container and vent them to
compliant closed vent system and
control device.

Transfer into Containers:

use of conveyance system that uses
a lube (or other means) to add waste
to the container and cover to remain
in place and all container openinp
to be in closed, sealed position
except tor opening.
Broken seal, or gasket.

As soon as practicable, but not later
than 15 calendar days after
identification.
Non-lreaiment Conlainers:

Option I: Compliant eovsr (sec Covers).
Monitor first time hazardous waste placed in container.

If cannot repair immediately, remove hazardous waste from
containers. Do not use container until leak is repaired and container
retested.
Option 2: If capacity is <0,46 cubic meters, compliant cover and complies with
49 CFR Part 178 regulations for packaging hazardous waste for transport.

Option 3: If attached to or part of truck, trailer, or railcar, demonstrate that
within preceding 12 months to be organic vapor light (sustains a pressure
change of <750 pascals within 5 minutes after pressurization).

Treatment Containers:

Located in compliant enclosure vented to compliant closed vent system and
control device.

Compliant Enclosure: designed and operated with sufficient airflow to capture
organic vapors emitted from container and vent them to compliant closed vent
system and control device.

Transfer into Conlainers (>0,46 cubic meters capacity:

use of conveyance system thai uses a tube (or other means) to add waste to the
container and cover to remain in place and all container openings to be in
CiOSGvi, scsiCu position except ior opening.
(see Covers)

(see Covers)



-------
SUMMARY OF REGULATIONS
page A-8?
Specific
Component
Summaries
REGULATION
40CFRPart61,
Subpart P
40CFRPart61,
Subpart L
40CFRPart61,
Subpart FF
40 CF1 Part 264,
Subpart CC
CONTAINERS (concluded)
Exemptions


Not applicable.


Not applicable.


Containers with fixed roof and
internal floating roof meeting
§60.112b(a)(l).
External floating roofs that comply
with §60.1 12b(a)(2).
Alternative means of emission
limitation, (§60.1 14b)
40 CFR Part 265,
Subpart CC

A container that meets all of the requirements identified in §265.10830
(§264.1082(c)] including but not limited to an average VO concentration of the
hazardous waste at the point of waste origination is < 1 00 ppmw.
Containers used for biological treatment of hazardous waste in accordance with
§265. 1 083(c)(2)(iv) [§264. 1 082(c)(2)(iv)].



-------
SUMMARY OF REGULATIONS
page A-88
Specific
Component
Summaries
REGULATION
40 CFR Part 61,
Subpart F
40 CFR Part 61,
Subpart L
40CFRPart6I,
Subpari FF
40 CFR Pan 264. 40 CFR Part 265,
Subpart CC Subpart CC
COVERS
Standards
Leak
Definition
Monitoring
Repair
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Initial and subsequent annual
monitoring Tor no detectable organic
emissions from cover and all
openings.
Maintain each opening in closed,
sealed position at all times except
when necessary to use opening.
Detectable emissions.
Broken seal or gasket.
Instrument: Method 21 of 40 CFR
Part 60, subpart A
Visual inspection: view entire cover
surface and each cover opening in
closed, sealed position for evidence
of defect that may affect ability to
continue to operate with no
detectable organic emissions.
As soon as practicable, but not later
than 15 (45 for tanks) calendar days
after identification.
Initial and semiannual visual inspection and monitoring for no detectable
organic emissions from cover and cover openings when all cover openings arc
secured in closed, scaled position.
"Unsafc-to-inspect" covers: written plan to inspect and monitor cover as -
frequently as practicable during times when a worker can safely access the
cover.
"Difficult-to-inspecl" covers: written plan and schedule to inspect and monitor
at least once per calendar year.
Seals around rotating shaft: 10,000 ppmv
All other seals and cover connections: detectable emissions (i.e., concentrations
greater than 500 ppmv plus background level).
Visual: a visible hole, gap, tear, or split in cover surface or cover opening.
Instrument: Method 21 of 40 CFR Part 60, subpart A
Visual inspection: view entire cover surface and each cover opening in closed,
sealed position for evidence of defect that may affect ability to continue to
operate with no detectable organic emissions.
First attempt to repair: within 5 calendar days of detection.
Completed repair: within 15 calendar days of detection.
Delay of repair allowed under certain circumstances.

-------
                                                                    SUMMARY OF REGULATIONS
                                                                                                                                                        page
   Specific
 Component
 Summaries
                                                                                         REGULATION
      40CFRPart61,
         Subpart F
        40CFRPart61,
           Subpart L
        40CFRPart61,
          Subpart FF
        40 CFR Part 264,
          Subpart CC
40 CFR Part 265,
   Subpart CC
COVERS (concluded)
  Exemptions
Not applicable.
Not applicable.
None specified.
Tank with internal floating roof or external floating roof that is inspected and
monitored in accordance with §265.1091 (§264.1091).

Tank is buried partially or entirely underground — only inspect or monitor
portion that is above ground and can be opened to the atmosphere .

Containers that meet all requirements specified in either §265,1087(b)(l)(ii) or
(iii)[§264.1086(b)(l)(ii) or (iii)J

Semiannual inspection/monitoring exemptions;

 cover remained closed and sealed since last visual inspection and monitoring

 designated as unsafe to inspect and monitor

 designated as difficult to inspect and monitor if installed and placed in service
before December 6, 1994	

-------
SUMMARY OF REGULATIONS
page A-90
Specific
Component
Summaries
REGULATION
40CFRPart61,
Subpart F
40 CFR Part 61,
Subpart L
40 CFR Part 61,
Subpart FF
40 CFR Part 264,
Subptrt CC
40 CFR Part 265,
Subpart CC
EXHAUSTERS
Standards





Leak
Definition
Repair

Not applicable.





Not applicable.
Not applicable.

Option 1:
Monitor quarterly to detect leaks
Option 2:
Equip with seal system that includes
a barrier fluid system and that
prevents leakage to atmosphere.
Seal system shall meet certain
design and operation requirements.
Install sensor to delect Mure of seal
system, barrier fluid system, or both.
Check sensor daily or equip with
audible alarm (unless located at
unmanned plant site).
Establish criteria that indicates
failure of seal system, barrier fluid
system, or both.
Option 1: 10,000 ppm
Option 2: Sensor indicates failure of
seal system, barrier fluid system, or
both based on established criteria.
Repair as soon as practicable, no
later than 1 5 calendar days after
detected.
A first attempt at repair shall be
made no later than 5 calendar days
after each leak is detected.
Not applicable.





Not applicable.
Not applicable.

Not applicable.





Not applicable.
Not applicable.

Not applicable.





Not applicable.
Not applicable.


-------
SUMMARY OF REGULATIONS
page A-91
Specific
Component
Summaries
REGULATION
40CFRPart61,
Subpart F
40CFRPart61,
Subpart L
40CFRPart6I,
Subpart FP
40 CFR Part 264,
Subpart CC
40 CFR Part 265,
Subpart CC
EXHAUSTERS (concluded)
Exemptions


Not applicable.


Equipment in vacuum service.
Exhausters equipped with compliant
closed-vent system and control
device.
Exhausters designed to operate with
an instrument reading less than 500
ppm above background.
Not applicable.


Not applicable.


Not applicable.



-------
                                                                   SUMMARY OF REGULATIONS
                                                                                                                                                      page A-92
Deity of Repir
                                                                                               REGULATION
                           40CFRParl6I,
                              Subpart F
                                      40CFRPart61,
                                         Subpart L
         40CFRPart61,
           Subparl FF
      40 CFR Part 264,
        Subparl CC
         40 CFR Part 265,
            Subpart CC
           General
If complying with subpart V,
40 CFR Part 61:

Allowed if repair is technically
infeasiblc without a process
unit shutdown.

Repair to occur before end of
next process unit shutdown,

Allowed for equipment
isolated from die process and
that does not remain in VHAP
service.
                                                   Allowed if repir is technically
                                                   infeasible without a process unit
                                                   shutdown.

                                                   Repair to occur before end of next
                                                   process unit shutdown,

                                                   Allowed for equipment isolated
                                                   from the process and that docs not
                                                   remain in VHAP service.
Allowed if the repir is technically
impossible without a complete or
partial facility or unit shutdown.

Repair of such equipment shall
occur before the end of the next
facility or unit shutdown.
For tanks and surface impoundment covers:

Allowed beyond 15 days if repair requires first emptying contents ami
temporary removal of tank or surface impoundment from service results
in unscheduled production stoppage of (he source generating the
hazardous waste being managed,

Repair to occur at next time source generating the hazardous waste being
managed stops operation for any reason.
            Valves
If complying with subpart V,
40CFRPa«61:

Allowed if:

emissions of purged material
resulting from immediate
repair greater than the fugitive
emissions likely to result from
the delay in the repair and

purged material is collected
and destroyed or recovered in
compliant control device when
procedures are effected.

Delay beyond a process unit
shutdown allowed if valve
assemblies have been
depleted, valve assembly
supplies had been sufficiently
stocked before supplies were
depleted.

Not allowed unless next
process unit shutdown occurs
sooner than 6 months after 1st
process unit shutdown.	
Not applicable.
Not applicable.
                                                   Allowed if;

                                                   emissions of purged material
                                                   resulting from immediate repair
                                                   greater than the fugitive emissions
                                                   likely to  result from the delay in
                                                   the repir and

                                                   purged material is collected and
                                                   destroyed or recovered in
                                                   compliant control device when
                                                   procedures are effected.

                                                   Delay beyond a process unit
                                                   shutdown allowed if valve
                                                   assemblies have been depleted,
                                                   valve assembly supplies had been
                                                   sufficiently stocked before supplies
                                                   were depleted.
                                                   Not allowed unless next process
                                                   unit shutdown occurs sooner man
                                                   6 months after 1st process unit
                                                   shutdown.
Not applicable.

-------
SUMMARY OF REGULATIONS
page A-Stf
Delay of Repair
Pumps



REGULATION
40 CFR Part 61,
Subpart P
If complying with subpart V,
40CFRPart61:
Allowed if:
Repair requires use of DMS
seal system that includes
barrier fluid and
Repair completed as soon as
practicable, but not later than
6 months after leak detected.
40CPRPart61,
Subpart L

Allowed if:
Repair requires use of DMS seal
system that includes barrier fluid
and
Repair completed as soon as
practicable, but not later than 6
months after leak detected.
40CFRPart61,
Subpart FF
Not applicable.



40 CFR Part 264,
Subpart CC
Not applicable.



40 CFR Part 265,
Subpart CC
Not applicable.




-------
SUMMARY OF REGULATIONS
page A-94
Equivalence of (or
Alternative) Nleans of
Emission Limitation:
General
Equipment, Design, and
Operational
Requirements








Work Practices






















Unique Approach
Manufacturers of
Equipment
BiGULATON

4QCFRPart6I,
SubprtF
Upon written application from an
owner or operator, the
Administrator may approve use
of equipment or procedures that
have been demonstrated to his
satisfaction to be equivalent in
terms of reducing VC emissions
to the atmosphere to those
prescribed for compliance with a
specific paragraph of this
subpart,
Upon written application from an
owner or operator, the
Administrator may approve use
of equipment or procedures that
have been demonstrated to his
satisfaction to be equivalent in
terms of reducing VC emissions
to the atmosphere to those
prescribed for compliance with a
specific paragraph of this
subpart.












None specified.
None specified.

40CFRPart61,
Subpart L
The Administrator shall comptre
test data for alternative means of
emission limitation to a benzene
control efficiency of 98% or 95%
for a tar decanters.






Owner/operator collect and verify
test data for alternative means of
emission limitation.

Owner/operator demonstrates
emission reduction achieved by
required work practice (for
minimum of 12 months).

Owner/operator demonstrates
emission reduction achieved by
alternative means of emission
limitation,
Owner/operator commits in
writing to work practices that
provide for emission reductions
equal to or greater than emission
reductions achieved by required
work practices.
Administrator compares
demonstrated emission reductions.
Administrator may condition
approval.
Not applicable.
Not applicable.

40CFRPjm61,
Subpart FF
Any person can collect, verify,
and submit information showing
alternative means achieves
equivalent emission reductions.

Administrator makes findings.

Administrator may condition
approval.


Not applicable.






















Not applicable.
Not applicable.

40 CFR Part 264,
Subpart CC
Not applicable.










Not applicable.






















Not applicable.
Not applicable.

40 CFR Part 265,
Subpart CC
Not applicable.










Not applicable.






















Not applicable.
Not applicable.


-------
                                                                      SUMMARY OF REGULATIONS
                                                                                                                                                     page A-95
   Test Methods and
      Procedures
                                                                                                REGULATION
      40 CFR Part 61,
        Subpart F
       40CFRPart61,
          Subpart L
40 CFR Part 61,
  Subpart FP
40 CFR Part 264,
   Subpart CC
40 CFR Part 265,
   Subpart CC
Monitoring Method and
Technique
Process Unit/Plant Area:

Device that obtains
representative samples from
one or more applicable
emission points on a
continuous sequential basis,

Samples analyzed with gas
chromatography or, if all
hydrocarbons measures are
VC, with infrared
speetrography, flame ion
detection, or alternative
method,

Daily  span check required
using  VC concentration of 10
ppm or equivalent to
emission limit, as
appropriate.	
Method 21 of 40 CFR Part 60, Appendix A

Instrument to meet performance criteria of Method 21
                         Method 21 of 40 CFR Part 60, Appendix A
Calibration
Gas mixtures:

 conform as specified in
sections 5,2.1 and 5,2.2 of
Test Method 106 and in
accordance with section 7.1
of Test Method 106
Before use on each day of its use, the instrument shall be calibrated by procedures specified in Method 21

Calibration gases used:

 zero air (less than 10 ppm hydrocarbon in air)

 mixture of methane or n-hexane and air at about, but less than, 10,000 ppm methane or n-hexane
"No detectable
emissions" monitoring
Background level determined by Method 21

Traverse probe as close to the potential leak interface as possible as described in Method 21

Calculate arithmetic difference between the maximum concentration indicated by the instrument and the background level compared to 500 ppm to determine compliance

-------
                                                                   SUMMARY OF REGULATIONS
                                                                                                                                               page A-96
   T«i Methods and
      Procedures
                                                                                             REGULATION
     40CFRPart61,
        SubpartF
      40 CFR Part 61,
         Subpart L
40 CFR Part 61,
  Subpart FF
40 CFR Part 264,
   Subpart CC
40 CFR Part 265.
   Subpart CC
Noi "in service*
demonstration
If complying with subpart V,
40 CFR Part 61:

Equipment is presumed to be
in VHAP service unless
demonstrated that the VHAP
content can never reasonably
expected to exceed 10
percent by  weight.
                       For demonstration:

                       Use procedures that conform
                       to ASTM Method D-2267.

                       Engineering judgment may
                       be used to determine percent
                       VHAP clearly does not
                       exceed 10 percent.

                       Administrator will require
                       use of ASTM Method D-
                       2267b in event of
                       disagreement to determine
                       VOC content.

                       If owner or operator
                       determines that a piece of
                       equipment is in VHAP
                       service, determination can
                       only be revised by following
                       demonstration procedures.
Equipment is presumed to be in
benzene service unless
demonstrated that the benzene
content can never reasonably
expected to exceed 10 percent
by weight.

Exhausters are presumed to be
in benzene service unless
demonstrated that the benzene
content can never reasonably
expected to exceed 1 percent by
weight.

For demonstration:

Use procedures that conform to
ASTM Method D-2267.

Engineering judgment may be
used to determine percent
VHAP clearly does not exceed
10 percent.

Administrator will require use
of ASTM Method D-226?b in
event of disagreement to
determine VOC content.
                           If owner or operator determines
                           that a piece of equipment is in
                           VHAP service, determination
                           can only be revised by
                           following demonstration
                           procedures.	
                              Not applicable.
                        Not applicable.
                       Not applicable.

-------
SUMMARY OF REGULATIONS
page A-9?
Test Methods and
Procedures
Samples
Vapor pressures
VO concentration of
hazardous waste
Flare Compliance
REGULATION
40CFRPart61,
Subpart F
If complying with subpart V,
40CFRPart6I:
Representative of process
fluid that is contained in or
contacts the equipment or the
gas being combusted in flare,
None specified,
Not applicable.
40CFRPart61,
Subpart L
Representative of process fluid
that is contained in or contacts
the equipment or the gas being
combusted in flare.
None specified.
Not applicable.
40CFRPart61,
Subpart FF
Not applicable.
Not applicable,
Not applicable.
40 CFR Part 264, 40 CFR Part 265,
Subpart CC Subpart CC
Collect at point of waste origination at least 4 discrete samples
Collect within 1-hour period
Collect in accordance with "Test Methods for Evaluating Solid Waste,
Chemical/Physical Methods," EPA SW-846, 3rd, edition, Sept. 1986.
Not applicable. Not applicable.
Method 25D, 40 CFR Part 60, appendix A
Visible emissions: Method 22
Presence of flame: thermocouple or equivalent
Exit velocity; Method 2, 2A, 2C, or 2D
Concentration: Method 18 or ASTM D2509-67,
Net Heat of Combustion; published value or ASTM 02382-76, if published values not available or cannot be calculated.

-------
                                                                    SUMMARY OF REGULATIONS
                                                                                                                                                 page A-98
    Rccordkccpmg
     Requirements
                                                                                               REGULATION
        40CFRPari6i,
           Subpari F*
40CFRPari6l,
   SubpartL
40CFRPsirt61,
  Subptrt FP
40GFR Part 264,
   Subparc CC
40 CFR Part 265,
   Subparl CC
Consolidated
Reeordkeeping
Subrart P: None specified,

SubranV.40CPRPart61:

An owner or operator of more than
one process unit subject to this
subpart may use one recordkeeping
system if the system identifies each
record by process unit.	
                         Not applicable.
                         None specified.
                      None specified.
                                                          An owner or operator of more than
                                                          one process unit subject to this
                                                          subpart may use one recordkeeping
                                                          system if the system identifies each
                                                          record by process unit.	
When teak detected.
                        Process Unit/Plant Area;

                         concentration of VC measures,
                        analyzed, and recorded by the VC
                        detector

                         location of each measurement

                         date and approximate time of each
                        measurement

                        Method 21:

                         leaks detected

                         action taken to repair

                         location of leak

                         cause of leak

                         date and time leak defected

                         action taken to eliminate the leak

                        Retain records for at least 3 years
                                  (see next page)
                         Record of each test of deteelable
                         emissions:

                          date test performed

                          background level measured

                          maximum concentration

                          waste management unit

                          control equipment

                          leak interface location where
                         detectable emissions were measured

                          description of problem and the
                         corrective action taken

                          date the corrective action
                         completed
                         Date of attempt to repair

                         Repair method applied

                         Date of successful repair

                         Retain for 3 years

-------
                                                                      SUMMARY OF REGULATIONS
                                                                                                                                                      page A-99
    Recordkeeping
     Requirements
                                                                                                 REGULATION
         40CFRPart61,
           Subpart F
40 CFR Part 61,
   Subpart L
40 CFR Part 61,
  Subpart FF
40 CFR Part 264,
   Subpart CC
40 CFR Part 265,
   Subpart CC
When leak detected
(continued)
Subpart V. 40 CPR Part 61:

Tagging Requirements:

 a weather-proof and readily visible
identification, marked with the
equipment id number, attached to
the leaking equipment

 id may be  removed after it has
been repaired, except for valves

 for valves, id may be removed
after 2 months of monitoring with
no leaks detected

Log Requirements:

 instrument and operator id number
and equipment id number

 date leak detected

 dates of each attempt to repair leak

 repair methods applied in each
attempt to repair

 "above 10,000" if maximum
instrument reading after eaeh repair
attempt is .>, 10,000 ppm

 "repair delayed" and reason for
delay if leak is not repaired within
15 calendar days after detection

 signature of owner/operator whose
decision it was that repair could not
be effected without a process
shutdown
                                                           Tagging Requirements:

                                                            a weather-proof and readily visible
                                                           identification, marked with the
                                                           equipment id number, attached to
                                                           the leaking equipment

                                                            id may be removed after it has
                                                           been repaired, except for valves

                                                            for valves, id may be removed
                                                           after 2 months of monitoring with
                                                           no leaks detected

                                                           Log Requirements:

                                                            instrument and operator id number
                                                           and equipment id number

                                                            date leak detected

                                                            dates of each attempt to repair leak

                                                            repair methods applied in each
                                                           attempt to repair

                                                            "above 10,000" if maximum
                                                           instrument reading after each repair
                                                           attempt is j£. 10,000 ppm

                                                            "repair delayed" and  reason for
                                                           delay if leak is not repaired within
                                                           15 calendar days after detection

                                                            signature of owner/operator whose
                                                           decision it was that repair could not
                                                           be effected without a process
                                                           shutdown

-------
                                                                         SUMMARY OF REGULATIONS
                                                                                                                                                         page A-100
     Recordkeeplng
     Retirements
                                                                                                     REGULATION
         40CFRPart6I,
            Subpart F*
         40CPRPart6I,
            Subpart L
40 CFR Part 61,
  Subpart FP
40 CFR Part 264,
   Subpan CC
40 CFR Part 265.
   SubprtCC
When leak detected,
(concluded)
 expected date of successful repair
if leak is not repaired with the 15
days

 date of successful repair of the
leak

Retain for 2 years in readily
 accessible location.
 expected date of successful repair
if leak is not repaired with the 15
days

 date of successful repair of the
leak

Retain for 2 years in readily
accessible location.
Closed vent systems and
control devices
Subpait-P:  None specified,

Subpart V. 40 CFR Part 61:

 detailed schematics, design
specifications, and piping and
instrumentation diagrams

 dates and descriptions of any
changes in design specifications

 description of parameters) to be
monitored to ensure proper
operation and maintenance

 explanation of selection of
parameter(s)

 periods when not operated
according to design

 dates of startups and shutdowns of
control devices and closed-vent
systems

Keep these records in a readily
accessible location.           	
                                                             For control devices:

                                                              detailed schematics, design
                                                             specifications, and piping and
                                                             instrumentation diagrams

                                                               dates and descriptions of any
                                                             changes in design specifications

                                                               description of parameters) to be
                                                             monitored to ensure proper
                                                             operation and maintenance

                                                               explanation of selection of
                                                             parameter(s)

                                                               periods when not operated
                                                             according to design

                                                               dates of startups and shutdowns of
                                                             control devices and closed-vent
                                                             systems

                                                             Keep these records in a readily
                                                             accessible location.
                                    Certification that the closed-vent
                                    system or control device is designed
                                    to operate at the documented
                                    performance level or highest load or
                                    capacity expected to occur

                                    For control devices:

                                     engineering calculations used to
                                    determine performance and a design
                                    analysis  that includes detailed
                                    schematics, design specifications,
                                    and piping and instrumentation
                                    diagrams

                                     performance tests,  including
                                    description  of test procedures,
                                    control device, sampling and
                                    monitoring  procedures, and all test
                                    results
                           Signed certification of compliance of control device under
                           maximum operating conditions

                           Design analysis or performance test plan and test results

                           Description and date of each modification made to the closed-
                           vent system or control device design,

                           Identification of operating parameter, description of monitoring
                           device, and diagram of monitoring sensor locadon(s) for the
                           following types of monitoring devices:  vent stream flow,
                           temperature, heat sensing, organic concentration, regeneration
                           cycles for carbon beds, and  good combustion practices,

                           Records of all Method 27 tests

                           Records of all visual inspections

                           Records of all monitoring for detectable organic emissions

                           Records of management of carbon removed from carbon
                           adsorption system

                           For compliance with §265.1083(c)(2)(vi) or (v)
                           [§264.1082(c)(2)(vi) or(v)]:

                             id number of incinerator, boiler, or industrial furnace	

-------
SUMMARY OF REGULATIONS
page A-101
Recordkeeping
Requirements
Closed vent systems and
control devices
(continued)









REGULATION
40CFRPart61,
Subpart r










40 CFR Part 61,
Subpart L










40 CFR Part 61,
Subpart FF
dates of startup and shutdown
description of parameters) to be
monitored to ensure proper
operation and maintenance
description of operating periods
when device is not in operation
For all thermal vapor and catalytic
vapor incinerators and for boilers
with <44 MW capacity;
temperature of the gas stream
exceedances
For all boilers and process heater:
each occurrence when there is a
change in the location at which the
vent stream is introduced into the
flame zone
temperature of the gas stream
For boilers and process heaters with
J>.44 MW capacity;
parameter(s) that indicates good
combustion operating practices are
being used
40 CFR Part 264,
Subpart CC










40 CFR Part 265,
Subpart CC











-------
SUMMARY OF REGULATIONS
page A-102
Recordkeeptng
Requirements
Closed vent systems and
control devices
(concluded)









Visual inspections



REGULATION
40CFRParl61,
Subpart F3











Not applicable.



40 CFR Part 61,
Subpari L











Not applicable.



40 CPR Panet,
Subpart FF
Flares;
continuous records or flare pilot
flame monitoring
all periods when pilot flame is
absent
Condensers:
organic or benzene concentration
or
temperature
exceedances
Carbon adsorbers:
organic or benzene concentrations
exceedances
Maintain a record for each visual
inspection dial identifies a problem
that could result in benzene
emissions. Include date of
inspection, waste management unit
and control equipment location
inspected, description of problem,
corrective action taken, and date
corrective action was completed.
40 CFR Part 264,
Subpart CC











40 CFR Part 265,
Subpart CC











Alt visual inspections of covers




-------
SUMMARY OF REGULATIONS
page A-103
Recordkeeping
Requirements
All equipment ...








Unsafe- or Diffieult-to-
Monitor Valves (covers
for 264 and 265)


REGULATION
40CFRPart61,
Subpart Fa
Subpart P: None specified.
Subpart V. 40 CFR Part 61:
list of id numbers of subject
equipment (except welded fittings)
list of id numbers of equipment
designated for no detectable
emissions and signed by
owner/operator
list of id numbers for pressure
relief devices in gas/vapor service
for each compliance test for
components designated for no
detectable emissions:
dates conducted
background level measured
maximum instrument reading
list of id numbers of equipment in
vacuum service
Maintain records for 2 years in a
readily accessible location.
Subpart P: None specified.
Subpart V. 40 CFR Part 61:
list of id numbers
explanation for designation
planned schedule for monitoring
40 CFR Part 61,
Subpart L


list of id numbers of subject
equipment (except welded fittings)
list of id numbers of equipment
designated for no detectable
emissions and signed by
owner/operator
list of id numbers for pressure
relief devices in gas/vapor service
for each compliance test for
components designated for no
detectable emissions:
dates conducted
background level measured
maximum instrument reading
list of id numbers of equipment in
vacuum service
Maintain records for 2 years in a
readily accessible location. For
foundry coke by-product recovery
plant, the annual coke production
(of furnace and foundry coke) shall
be recorded and maintained for 2
years following determination.
list of id numbers
explanation for designation
planned xhedule for monitoring
40 CFR Part 61,
Subpart FF





for each compliance test for
components designated for no
detectable emissions:
dates conducted
background level measured
maximum instrument reading


Not applicable.


40 CFR Part 264,
Subpart CC
Not applicable.








40 CFR Part 265,
Subpart CC
Not applicable.




"^



list of id numbers
explanation for designation
planned schedule for monitoring

-------
SUMMARY OF REGULATIONS
page A-104
Reeordkeeptnf
Requirements
Valves complying willi
alternative standard for
skip-periods
Barrier fluid and seal
systems
Exemptions
Determinations
Not "In service"
REGULATION
40 CFR Part 61,
Subpart F*
Submrt P: None specified.
SubparlV,40CFRP»rt6l:
schedule of monitoring
percent valves leaking during each
monitoring period
Subpart Pi None specified,
Subpart ¥.40 CPR Part 61 :
design criteria for indicating
failure
explanation for selected criteria
any changes to selected criteria
and reasons for change
Subpart F: None specified.
Subpart V. 40 CFR Part 61:
analysis demonstrating facility
design capacity
analysis demonstrating that
equipment is not in VHAP service
SubpartE: None specified.
Subpart V. 40 CFR Part 61 :
information and data used to
demonstrate that a piece of
equipment is not in VHAP service
40 CFR Part 61,
Subpart L
schedule of monitoring
percent valves leaking during each
monitoring period
design criteria for indicating
failure
explanation for selected criteria
any changes to selected criteria
and reasons for change
analysis demonstrating facility
design capacity
analysis demonstrating that
equipment is not in VHAP service
information and data used to
demonstrate that a piece of
equipment is not in VHAP service
40 CPR Part 61,
Subparl FF
Not applicable.
Not applicable.
Not applicable.
Not applicable.
40 CFR Part 264,
Subpart CC
Not applicable.
Not applicable.
Not applicable.
Not applicable.
40 CFR Part 265,
Subpart CC
Not applicable.
Not applicable.
Not applicable.
Not applicable.

-------
                                                    SUMMARY OF REGULATIONS
page A-105
Recordkeeping
Requirements
Tanks



Tanks, surface
impoundments,
containers

Alternative
Recordkeeping
REGULATION
40CFRPart61,
.Subpart F8
Not applicable.



Not applicable.

Not applicable,
40CFRPart61,
Subpart L
Not applicable.



Not applicable. ,

Not applicable.
40CFRPart61,
Subpart FF
Not applicable.



Not applicable.

Not applicable.
40 CFR Part 264, 40 CFR Part 265,
Subpart CC Subpart CC
§265.1085(c) or §264. 1084(c):
date and time each waste sample is collected
results of each determination for maximum organic vapor
pressure
tank dimensions and design capacity
No air emission controls:
information used for each waste determination
date, time, and location of each waste sample if results are
used
Owners/operators also subject to 40 CFR Part 60, subpart VV
or 40 CFR Part 61, subpart V may elect to demonstrate
compliance using the documentation required under said subpart
VV or subpart V to the extent that such documentation
duplicated the documentation required under 40 CFR Part 265
[264], subpart CC.
Subpart V, 40 CFR Part 61, recordkeeping requirements are not required for process units with less than 2% leaking valves. Other recordkeeping requirements required under subpart F are still applicable.

-------
                                                                     SUMMARY OF REGULATIONS
                                                                                                                  page A-106
Reporting Requirements
                                                                                                REGULATION
                              40CPRPart61,
                                 Subptrt F*
       40CFRPart61,
          Subpart L
40 CFR Part 61.
  Subpart FF
          40 CFR Part 264.
             Subpart CC
40 CFR Part 265.
   Subpart CC
          Initial Report
                        Equipment and procedural
                        specifications ire being met.

                        Statement that contains the
                        following:

                         list of equipment installed  for
                        compliance

                         description of the physical and
                        functional characteristics of
                        each piece of equipment

                         description of the methods
                        that have been incorporated into
                        the standard operating
                        procedures for measuring or
                        calculating the emissions for
                        which emission limits have
                        been prescribed

                         statement that each piece of
                        equipment is installed and that
                        each piece of equipment and
                        each procedure is being used

                        Subpart V, 40 CFR Part 61:

                        For each source:
                         equipment id number

                         process unit id

                         type of equipment
For each source to benzene
service:

 equipment id number

 process unit id

 type of equipment
                               For subject facilities;

                                 regulatory status of each waste
                               stream

                                 total annual benzene quantity

                                 each benzene waste stream
                               and whether it will be
                               controlled for benzene

                                 for each benzene waste stream
                               not being controlled for benzene

                                 — whether water content is
                                 — type of waste stream
                                 — annual waste quantity
                                 — range of benzene
                               concentration
                                 - average benzene
                               concentration
                                 — annual benzene quantity
None specified.
                                                              None specified.

-------
                                                                     SUMMARY OF REGULATIONS
                                                                                                                                                  page A-107
Reporting Requirements
                                                                                                REGULATION
                              40CFRPart61,
                                 Subpart F
                                      40CFRPart61,
                                        Subpart L
                                      40 CFR Part 61,
                                        Subpart FF
40 CFR Part 264,
   Subpart CC
40 CFR Part 265,
   Subpart CC
          Initial Report
           (concluded)
 percent weight VHAP

 process fluid state

 method of compliance

Reporting schedule for
submittal of subsequent
semiannual reports

An owner or operator is also
required to submit a statement
notifying the Administrator that
the requirements of this subpart
are being implemented. For
existing sources and new
sources with  an initial startup
date preceding the effective
date, this notification is to be
submitted within 90 days of the
effective date. For new source
with an initial startup date after
the compliance date, this
notification is to be submitted
with the application for
approval of construction.	
 percent weight VHAP

 process fluid state

 method of compliance

Reporting schedule for submittal
of subsequent semiannual reports

Submit statement that the
requirements of this subpart and
40 CFR Part 61, subpart V have
been implemented. For existing
sources and new sources with an
initial startup date preceding the
effective date,  submit within 90
days of the effective date.  For
new source with an initial startup
date after the compliance date,
submit with the application for
approval of construction.

-------
                                                                      SUMMARY OF REGULATIONS
                                                                                                                                                   page A-108
Reporting Requirements
                                                                                                  REGULATION
                               40CFRPart61,
                                 Subpart F3
                                      40CFRPart61,
                                         SubpartL
                                       4QCFRParlfil,
                                         SubpartFF
                                         40 CFR Part 264,
                                            Subpart CC
                                             40 CFR Part 265,
                                                Subpart CC
           Subsequent
   Semiannual/Periodic
              Reports
Subpart P:

Due March IS, June 15,
September 15, and December
15;

 VC content of emissions for
each 3-hour period during
which the average emissions
are in excess of the limits
specified for any control system
to  which fugitive emissions are
required to be ducted

 the number of 3-hour periods
determined during the reporting
period

 if no excess emissions, a
statement to that effect

Subpart V. 40 CPR Part 61:

 process unit identification

The following information by
month in the reporting period:

 number of valves, pumps, and
compressors for which leaks
were detected

 number of valves  nuiBns  and
compressors for which leaks
were not repaired as required

 the facts that explain each
delay of repair, and where
appropriate, why a process unit
shutdown was technically
infeasible         	
For sources subject to §61.132
and §61.133:

 brief description of any visible
defect in the source or ductwork

 number of leaks

 number of leaks repaired

 brief description of any system
abnormalities
                                                       For equipment in benzene
                                                       service:

                                                        process unit identification

                                                       The following by month in the
                                                       reporting period:

                                                        number of valves, pumps, and
                                                       compressors for which leaks
                                                       were detected

                                                        number of valves_ numns- and
                                                       compressors for which leaks
                                                       were not repaired as required

                                                        the facts that explain each delay
                                                       of repair, and where appropriate,
                                                       why a process unit shutdown was
                                                       technically infeasible
Facilities with > 10 Mg/yr
benzene waste:

Annual reports Including but not
limited to:

 update of information
contained in initial report

 all inspections during which
detectable emissions are
measured or a problem (e.g.,
broken seal, gap) that could
result in benzene emissions is
identified

 information on repair and
corrective action taken

Quarterly:

 all inspections required have
been carried out

 for control devices:  periods
of exceedances
Exempted tanks, surface impoundments..
and containers:

 each occurrence when hazardous waste
is placed in unit in noncompliance with
§264,1082(c)(I)or{2)

Tanks complying with §264.1084M:

 each occurrence of noncompliance

 submit within 15 calendar days of time
when become aware of noncompliance

Control Device

 semiannual report when noncompliance
has occurred

 each period of 24 hour or longer when
operating in noncompliance

 for flares; when operated with visible
emissions

Ail reports to include;

 EPA id number

 facility name and address

 description of event and cause (not for
control devices)

 explanation why control device not
returned to compliance within 24 hours
(control devices only)

 dates of the noncompliance
None specified.

-------
                                                                     SUMMARY OF REGULATIONS
                                                                                                                                                  page A-109
Reporting Requirements
                                                                                                 REGULATION
                              40CFRPart61,
                                 Subpart Fa
                                      40 CFR Part 61,
                                        Subpart L
                                       40CFRPart6i,
                                         Subpart FF
          40 CFR Part 264,
             Subpart CC
40 CFR Part 265,
   Subpart CC
           Subsequent
   Semiannual/Periodic
              Reports
           (concluded)
Dates of process unit shutdowns
that occurred within the
semiannual reporting period

Revisions to items reported in
the initial semiannual report if
changes have occurred since
the initial semiannual report or
subsequent revisions to the
initial semiannual report
Dates of process unit shutdowns
that occurred within the
semiannual reporting period

Revisions to items reported in the
initial semiannual report if
changes have occurred since the
initial semiannual report or
subsequent revisions to the initial
semiannual report.

For each exhauster for each
quarter in the semi-annual
period:

 number for which leaks were
detected

 number for which leaks were
repaired as required

 performance test results

Signed statement stating whether
all the provisions of this subpart
have been fulfilled
 actions taken to correct noncompliance
and prevent reoccurrence

 signed and dated by authorized
representative

-------
                                                                      SUMMARY OF REGULATIONS
                                                                                                                                                   pageA-110
Reporting Requirements
                                                                                                  REGULATION
                               40CPRPari61,
                                 SubpartF11
                                      4QCFRPart61.
                                         SubparlL
       40CFRPa«6l,
         Subpart FF
          40CFRParl264,
             Subpart CC
       40 CFR Pan 265,
         Subpan CC
                Other
Subpart F;

Within 10 days of any
discharge, submit report
containing information on the
source, nature and cause of the
discharge, the date and lime of
the discharge, the approximate
total VC loss during the
discharge, the method used for
determining the loss, the action
taken to prevent the discharge,
and measures adopted to
prevent future discharges,

Subpart V. 40 CFR Part 61;

Notification 90 days prior to
complying with either
alternative standard for valves
in gas/vapor service,

Report of all performance test
and monitoring to determine
compliance with no detectable
emissions and with §63.243-1
and -2 conducted within the
semiannual reporting period.
                                                       Notification 90 days prior to
                                                       complying with either alternative
                                                       standard for valves in gas/vapor
                                                       service (§63,243-1 and -2).

                                                       Report of all performance test
                                                       and monitoring to determine
                                                       compliance with no detectable
                                                       emissions and with conducted
                                                       within the semiannual reporting
                                                       period.	
If total annual benzene waste is
< 1 Mg/yr: updates whenever
changes occur that may increase
benzene waste to more than 1
Mg/yr

If total annual benzene waste is
1 to 10 Mg/yr, updates
whenever changes occur that
may increase benzene waste to
more than  10 Mg/yr

If total annual benzene waste is
> 10 Mg/yr, certification that
necessary equipment has been
installed and initial performance
tests have been carried out.
Not applicable.
Not applicable.
         Subpart V, 40 CFR Part 61, reporting requirements are not required for process units with less than 2% leaking valves. Other reporting requirements required under subpart F are still applicable.

-------
                               APPENDIX B

       EQUIPMENT LEAK REGULATIONS: SUMMARY OF DIFFERENCES
40 CFR Part 60, Subparts ODD, GGG, KKK, QQQ
40 CFR Part 63, Subpart CC

GENERAL ASPECTS OF RULE
Applicability	B-l
Exemptions  	B-l
Definitions	,		B-l
Equipment Identification	B-3
Compliance Demonstrations  	B-3
Method of Compliance Determination	,	B-3
Requirements When More Than One Standard Applies	 B-4

SPECIFIC COMPONENT SUMMARIES
Valves, Gas/Vapor or Light Liquid Service	B-5
Valves, Heavy Liquid Service	B-8
Alternative Standards for Valves	,	".	B-8
Pumps, Light Liquid Service	,	 B-10
Pumps, Heavy Liquid Service .	 B-12
Pressure Relief Devices, Gas/Vapor Service	 B-13
Pressure Relief Devices, Light Liquid or Heavy Liquid Service  	,	 B-14
Compressors  	 B-15
Sampling Connection Systems	*	 B-15
Open-Ended Valves or Lines		 B-16
Flanges and Other Connectors (All Services)	B-16
Connectors, Gas/Vapor or Light Liquid Service	B-17
Instrumentation Systems	B-19
Closed-Vent Systems and Control Devices	B-20

DELAY OF REPAIR	,	 B-22

EQUIVALENCE OF (OR ALTERNATIVE) MEANS OF
EMISSIONS LIMITATION: GENERAL	B-23

EQUIVALENCE OF (OR ALTERNATIVE) MEANS OF
EMISSIONS LIMITATION: ENCLOSED-VENTED PROCESS UNITS	B-24

-------
QUALITY IMPROVEMENT PROGRAMS	 B-25

TEST METHODS AND PROCEDURES	 B-31

RECORDKEEPING REQUIREMENTS	 B-35

REPORTING REQUIREMENTS	 B-45
40 CFR Part 61, Subparts F, L, FF
40 CFR Part 264 and Part 265, Subparts CC


GENERAL ASPECTS OF RULE
Applicability	 B^I7
Exemptions 	 B-47
Definitions	 B-4$
Equipment Identification	 B-50
Compliance Demonstrations  	 B-50
Method of Compliance Determination	 B-50
Requirements When More Than One Standard Applies	B-50

SPECIFIC COMPONENT SUMMARIES
Process Unit/Plant Area	 B-51
Valves, Gas/Vapor or Light Liquid Service  	 B-52
Alternative Standards for Valves	 B-52
Pumps, Light Liquid Service	 B-53
Pressure Relief Devices, Gas/Vapor Service	 B-54
Pressure Relief Devices, Light Liquid or Heavy Liquid Service	 B-55
Compressors  	B-56
Sampling Connection Systems	 B-58
Open-Ended Valves or Lines	 B-59
Flanges and Other Connectors (All Services)	 B-59
Agitators, Gas/Vapor Service or Light Liquid Service	 B-60
Product Accumulator Vessels	 B-60
Closed-Vent Systems and Control Devices	 B-61
Process Vessels, Storage Tanks, and Tar-Intercepting Sumps	 B-64
Light-Oil Sumps	 . B-66
Tanks	 B-68
Surface Impoundments	 B-69
Containers	 B-70
Covers	 B-72
Exhausters	 B-73

-------
DELAY OF REPAIR	 B-75

EQUIVALENCE OF (OR ALTERNATIVE) MEANS OF
EMISSIONS LIMITATION: GENERAL .	 B-76

TEST METHODS AND PROCEDURES	 B-77

RECORDKEEPMG REQUIREMENTS	B-79

REPORTING REQUIREMENTS	 B-84

-------

-------
SUMMARY OF REGULATION DIFFERENCES
page

General Aspects of Rule



APPLICABILITY


















EXEMPTIONS













DEFINITIONS
"Fn gas/vapor service"

REGULATION

40CFRPart60,
Subpart ODD

Each group of fugitive
emission equipment within
a process unit in the
polymer manufacturing
industry that commences
construction,
reconstruction, or
modification after
September 30, 1987.

The facilities covered are
polypropylene,
polyethylene, and
polystyrene.





This subpart does not apply
to VOC emissions from
equipment leaks from
polyethylene
terephthalate)
manufacturing processes

Any affected facility with
design capacity to produce
less than 1,000 Mg per
year.




40 CFR Part 60,
Subpart GGQ

Each compressor and the
group of all equipment
within a process unit in a
petroleum refinery that
commences construction,
reconstruction, or
modification after January
4, 1983.











None specified.














40 CFR Part 60,
Subpart KKK

Each compressor and the
group of all equipment
within a process unit in an
onshore natural gas
processing plant that
commences construction,
reconstruction, or
modification after January
20, 1984.










Any compressor station,
dehydration unit,
sweetening unit,
underground storage tank,
field gas gathering system
or liquified natural gas unit
that is not located at the
onshore processing plant
site.






The piece of equipment contains process fluid that is in gaseous state at operating
conditions.

40 CFR Part 60,
Subpart QQQ

Individual drain systems,
individual oil-water
separators, and aggregate
facilities located within a
petroleum refinery
wastewater system that
commences construction,
reconstruction, or
modification after May 4,
1987,

"Aggregate facility" is an
individual drain system
together with ancillary
downstream sewer lines
and oil-water separators,
down to and including the
secondary oil-water
separator.
None specified.














Not applicable.


40 CFR Part 63, 40 CFR Part 63,
Subpart CC Subpart CC
(existing) (existing or new)
This subpart applies to all equipment leaks from petroleum
refining process units that are located at a major source and
that emit or have equipment containing or contacting one or
more of the HAP listed in Table 1 of this subpart.

This subpart does not apply to equipment intended to operate
in organic HAP service for less than 300 hours during the
calendar year.











Research and development facilities,

Equipment that does not contain any of the HAP listed in
Table 1 of this subpart.

Units processing natural gas liquids.

Units used specifically for recycling discarded oil.

Shale oil extraction units.

Ethylene processes.
Process units and emission points subject to subparts F, G, H,
and 1 of 40 CFR Part 63.

A piece of equipment in organic hazardous air pollutant
(HAP) service contains a gas or vapor at operating conditions.

-------
SUMMARY OF REGULATION
page B-2
General Aspects of Rule
REGULATION
40 CFR Part 60,
Subpart ODD
40 CFR Part 60,
Subpart QGG
40 CFR Part 60,
Subpart KKK
40 CFR Part 60,
Subpart QQQ
40 CFR Part 63,
Subpart CC
(existing)
DEFINITIONS (continued)
"In heavy liquid
service"
"In light liquid service"
"In VOC service"
"In organic hazardous
air pollutant or In
organic (HAP) service"
"In wet gas service"
"Gas tight"
Equipment
("Equipment Leaks" for
40 CFR Part 63, subpart
CC)
The piece of equipment is not in gas/vapor service or in
light liquid service.
The piece of equipment is
not in gas/vapor service or
in light liquid service or
the weight percent
evaporated is 10 percent or
less at ISO'C,

The piece of equipment contains or contacts a process fluid that is at least 10 percent VOC
by weight.
Not applicable.
Not applicable.
Not applicable.
Each pump, compressor,
pressure relief device,
sampling connection
system, open-ended valve
or line, valve, and flange or
other connector in VOC
service and any devices or
systems required by
Subpart VV.
Not applicable.
Not applicable.
Not applicable.
Each valve, pump, pressure
relief device, sampling
connection system, open-
ended valve or line, and
flange or other connector
in VOC service. For the
purposes of reeordkeeping
and reporting, compressors
are considered equipment.
Not applicable.
A piece of equipment
contains or contacts the
field gas before the
extraction step in the
process.
Not applicable.
Each pump, pressure relief
device, open-ended valve
or line, valve, compressor
and flange or other
connector that is in VOC
service or in wet gas
service and any device or
system required by this
subpart.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Operated with no
detectable emissions.
Not applicable.

40 CFR Part 63,
Snbpart CC
(existing or new)

A piece of equipment is not in gas/vapor service or in light
liquid service.

Not applicable.
A piece of equipment either contains or contacts a fluid
(liquid or gas) that is at least 5 percent by weight total organic
HAP.
Not applicable.
Not applicable.
HAP emissions form a pump, compressor, pressure relief
device, sampling connection system, open-ended valve or
line, valve, or instrumentation system in organic HAP service.
Vents from wastewater system drains, tank mixers, and
sample valves on storage tanks are not equipment leaks.

-------
SUMMARY OF REGULATION
page B-3
General Aspects of Rule
REGULATION
40CFRPart60,
Subpart ODD
40 CFR Part 60,
Subpart GGG
40 CFR Part 60,
Subpart KKK
40 CFR Part 60,
Subpart QQQ
40 CFR Part 63,
Subpart CC
(existing)
DEFINITIONS (concluded)
Process Unit
Repaired
First Attempt at Repair
EQUIPMENT
IDENTIFICATION (see
also Recordkeeping
Requirements)
COMPLIANCE
DEMONSTRATIONS
METHOD OF
COMPLIANCE
DETERMINATION
Equipment assembled to
perform any of the physical
' and chemical operations in
the production of
polypropylene,
polyethylene, polystyrene,
(general purpose, crystal,
or expandable), or
polyethylene
terephthalate) or one of
their copolymers. A
process unit can operate
independently if supplied
with sufficient feed or raw
materials and sufficient
storage facilities for the
product.
Components assembled to
produce intermediate or
final products from
petroleum, unfinished
petroleum derivatives or
other intermediates; a
process unit can operate
independently if supplied
with sufficient feed or raw
materials and sufficient
storage facilities for the
product.
Equipment assembled for
the extraction of natural
gas liquids from field gas,
the fractionation of the
liquids into natural gas
products, or other
operations associated with
the processing of natural
gas products. A process
unit can operate
independently if supplied
with sufficient feed or raw
materials and sufficient
storage facilities for the
product.
Equipment is adjusted, or otherwise altered, in order to eliminate a leak as indicated by
one of the following: an instrument reading of 10,000 ppm or greater, indications of
liquids dripping, or indication by sensor that a seal or barrier fluid has failed.

Not applicable.
Not applicable.
Not applicable.
None specified.
Required for all equipment within 180 days of initial startup.

40 CFR Part 63,
Subpart CC
(existing or new)

Equipment assembled and connected by pipes or ducts to
process raw and/or intermediate materials and to manufacture
an intended product. A process unit includes any associated
storage vessels. For the purposes of this subpart, a process
unit includes, but is not limited to, chemical manufacturing
process units and petroleum refining process units.
Equipment is adjusted, or otherwise altered, to eliminate a .
leak as defined in the applicable sections of this subpart.

Marked in manner such that it can be readily distinguished
from equipment not subject to this subpart (does not require
physical tagging except for leaking equipment).
Existing Sources: in compliance by August 18, 1998
Existing Sources electing to comply with subpart H, 40 CFR
Part 63: Phase I -August 18, 1998; Phase II -August 18,
1 999; Phase III -June 18,2001
New Sources that commence construction or reconstruction
after July 14, 1994: in compliance upon initial startup or
August 18, 1998, whichever is later.


-------
SUMMARY OF REGULATION
page B-4
General Aspects of Rule
REQUIREMENTS
WHEN MORE THAN
ONE STANDARD
APPLIES
REGULATION
40 CFR Part 60,
Subpart ODD
None specified.
40CFRPart60,
SubpwtOOG
Facilities subject to subpart
VV or subpart KKK, of 40
CPR Part 60 arc excluded
from lliis subpart.
40 CFR Part 60,
Subpart KKK
Facilities covered by
subpart VV or subpart
GGG of 40 CFR Part 60
nre excluded from this
subpart.
40 CFR Pan 60,
Subpart QQQ
None specified.
40 CFR Part 63,
Subpart CC
(existing)
40 CFR Part 63,
Subpart CC
(existing or new)
Equipment subject to this subpart thai nre also subject to 40
CFR Part 60 or 40 CFR Part 6 1 will be required to comply
only with the provisions of this subpart.

-------
                                                           SUMMARY OF REGULATION DIFFERENCES
                                                                                                                                                             page B-5
   Specific
  Component
  Summaries
                                                                                             REGULATION
  40 CFR Part 60,
    Subpart ODD
40 CFR Part 60,
 Subpart OGQ
40 CFR Part 60,
 Subpart KKK
40 CFR Part 60,
 Subpart QQQ
40 CFR Part 63,
  Subpart CC
   (existing)
40 CFR Part 63,
  Subpart CC
(existing or new)
VALVES, GAS/VAPOR OR LIGHT LIQUID SERVICE
     Standards
Monitor monthly.

After two consecutive months of no leaks, a valve may be monitored
quarterly,

If leak detected, monitor valve monthly until leak is not detected for two
consecutive montlis.

"No detectable emissions" valves:  less than 500 ppm above background.
                "Unsafe-to-monitor" valves:  written plan to monitor as frequently as
                practicable during safe-to-monitor times.

                "Difficult-to-monitor" valves: written plan to monitor at least once per year.
                No more than 3.0 percent of valves in affected facility can be designated as
                difficult-to-monitor.
                                            Not applicable.
                                            Monitor monthly.

                                            After two consecutive months of
                                            no leaks, a valve may be
                                            monitored quarterly.  Provisions
                                            made to allow use of qualified
                                            previously generated monitoring
                                            data to use less frequent
                                            monitoring.

                                            If leak detected, monitor valve
                                            monthly until leak is  not detected
                                            for two consecutive months.

                                            "No detectable emissions" valves:
                                            less than 500 ppm above
                                            background,

                                            "Unsafe-to-monitor" valves:
                                            written plan to monitor  as
                                            frequently as practicable during
                                            safe-to-monitor times.

                                            "Difficult-to-monitor" valves:
                                            •written plan to monitor  at least
                                            once per year. No more than 3
                                            percent of valves in affected
                                            facility can be designated as
                                            difficult-to-monitor.
                                                     In Phases I and II, monitor each valve quarterly.

                                                     In Phase HI, monitoring frequency based on
                                                     percent valves found leaking and whether
                                                     connectors are being monitored according to
                                                     §63.649 [with CM = connector monitoring; w/o
                                                     CM = no connector monitoring]:

                                                      Percent Leaking    Monitoring
                                                     with CM  w/o CM  Frequency

                                                      > 4   < 5        Monthly or implement a
                                                                       quality implementation
                                                                       plan (QIP)
                                                      <4   <5        Quarterly
                                                      < 3   < 4    •    Quarterly or once every 2
                                                                       quarters
                                                      < 2   < 3        Quarterly or once every 4
                                                                       quarters

                                                     (If >2% leaking valves at a plant site with less
                                                     than 250 valves in organic HAP service:
                                                     monitor quarterly.)

                                                     "Unsafe-to-monitor" valves:  written plan to
                                                     monitor as frequently as practicable during safe-
                                                     to-monitor times.

                                                     "Difficult-to-monitor" valves: written plan to
                                                     monitor at least once per year.  No more than 3.0
                                                     percent of valves in new facility can be
                                                     designated as difficult-to-monitor.	

-------
SUMMARY OF REGULATION DIFFERENCES
page B-6
Specific
Component
Summaries
REGULATION
40 CFR Part 60, 40 CFR Part 60, 40 CFR Part 60,
Subpart DDD Subpart GOO Subpart KKK.
40 CFR Part 60,
SubptrtQQQ
40 CFR Part 63,
Subpart CC
(existing)
40 CFR Part 63,
Subpart CC
(existing or new)
VALVES, GAS/VAPOR OR LIGHT LIQUID SERVICE (continued)
Standards
(concluded)
Leak
Definition
Repair
First Attempt
at Repair

1 0,000 ppm



Not applicable.
Not applicable.
Not applicable.

10,000

Calculation of percent leaking may be done on
process unit or source-wide basis. Calculation
procedures remains the same until a permit
change is made. Decision on how to calculate
required within the first monitoring period after
August 18, 1998.
Phase HI: Any valve designated as having no
detectable emissions may comply with §60.482-
7(0 instead.
Phase I: 1 0,000 ppm
Phase 11; 1,000 ppm
Phase HI: 1, 000 ppm
ADDS:
When repaired, monitor at least once within first
3 months after repair.


-------
SUMMARY OF REGULATION DIFFERENCES
page B-7

Specific
Component
Summaries

REGULATION

40CFRPart60,
Subpart ODD

40CFRPart60,
Subpart GOG

40CFRPart60,
Subpart KKK

40CFRPart60,
Subpart QQQ

40 CFR Part 63, 40 CPR Part 63,
Subpart CC Subpart CC
(existing) (existing or new)
VALVES, GAS/VAPOR AND LIGHT LIQUID SERVICE (concluded)
Exemptions









































ADDS;
Valves in gas/vapor or
light liquid service
within a process unit
located on the Alaskan
North slope.















ADDS:
Valves in gas/vapor or
light liquid service within
a process unit located on
the Alaskan North slope
are exempt from the
routine monitoring
requirements of §60.482-
7(<0.
Valves in gas/vapor or.
light liquid service
located at a
nonftactionating plant
that does not have a
design capacity to
process 283,000 standard
cubic meters per day or
more of field gas are
exempt from the routine
monitoring requirements
of§6Q,482-7(a).
Not applicable.




















ADDS:
Equipment operated less than 300 hours per year.




















-------
SUMMARY OF REGULATION
pageB-8
Specific
Component
Summaries
REGULATION
40 CFR Part 60, 40 CFR Part 60, 40 CFR Part 60,
Subpart ODD SubpartOOO SubpartKKK
VALVES, HEAVY LIQUID SERVICE
Standards
Leak
Definition
Repair
First Attempt
at Repair
Exemptions





40 CFR Part 60,
Subpart QQQ

Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
40 CFR Part 63,
Subpart CC
(existing)

40 CFR Part 63,
Subpart CC
(existing or new)



ADDS:
For valves in heavy liquid service that are not monitored (Method 21), repair shall
mean that visual, audible, olfactory, or other indications of a leak have been eliminated;
no bubbles are observed at potential leak sites during leak check with soap solution; or
system will hold a test pressure.

ADDS:
Equipment operated less than 300 hours per year.
ALTERNATIVE STANDARDS FOR VALVES
Allowable Percentage of Valves Leaking
Standard
Leak
Definition
Repair
First Attempt
at Repair




Not applicable.
Not applicable.
Not applicable.
Not applicable.
ADDS:
Calculation of percent leaking
may be done on a process unit or
source-wide basis. Once decided,
all subsequent calculations made
on same basis unless permit
~u««~~
vimtigv.



Not applicable.
Not applicable.
Not applicable.
Not applicable.

-------
SUMMARY OF REGULATION DIFFERENCES
page
Specific
Component
Summaries
\
REGULATION
40 CFR Part 60,
Subpart ODD
40 CFR Part 60,
Subpart OOO
40 CFR Part 60,
Subpart KKK
40 CFR Part 60,
Subpart QQQ
40 CFR Part 63,
Subpart CC
(existing)
40 CFR Part 63,
Subpart CC
(existing or new)
Skip Period Leak Detection and Repair
Standard

Not applicable,

Not applicable.

-------
SUMMARY OF REGULATION
page B40

Specific
Component
Summaries



40CFRPart60,
Subpnrt ODD

40CPRPart60,
Subpart GGO

PUMPS, LIGHT LIQUID SERVICE
Standards

















Leak
Definition








Repair
REGULATION

40CFRPart6Q,
Subjwrt KKK

40CFRPart60,
Subpart QQQ

4X)CFRPart63,
Subpart CC
(existing)
40CPRPart63,
SubpirtCC
(existing or new)


1 0,000 ppm

ADDS;
... except tiwt
indications of liquid
dripping from bleed
ports in existing
pumps are not
considered to be a
leak.
10,000 ppm

Not applicable.

















Not applicable.









Not applicable.


















10,000 ppm









ADDS;
Phase III: If less than 10 percent of the light
liquid pumps or less than 3 light liquid pumps
are leaking, monitor monthly. If less than 3
percent of the light liquid pumps or less than 1
light liquid pump are leaking, monitor quarterly.
If the greater of either 10 percent of pumps in a
process unit (or source-wide) or 3 pumps in a
process unit (or source-wide) leak, then
implement technology review and Improvement
QIP, (This does not apply to process unit if more
than 90% of the pumps in the unit are either dual
mechanical seal or designed with no externally
activated shaft penetrating the housing.)
Phase I: this phase is not applicable.
Phase II: begins upon facility startup.
Phase III: begins no later than one year after
initial startup.
Phase I: 10,000 ppm

Phase H: 5,000 ppm
Phase HI: 2,000 ppm








-------
                                                       SUMMARY OF REGULATION DIFFERENCES
                                                                                                                                                  page B-H
   Specific
 Component
 Summaries
                                                                                      REGULATION
  40 CFR Part 60,
   Subpart ODD
40 CFR Part 60,
 Subpart GGG
40 CFR Part 60,
 Subpart KKK.
40 CFR Part 60,
 Subpart QQQ
40 CFR Part 63,
  Subpart CC
   (existing)
40 CFR Part 63,
  Subpart CC
(existing or new)
PUMPS, LIGHT LIQUID SERVICE (concluded)
  First Attempt
     at Repair
None specified.
                                          Not applicable.
                                         None specified.
                                                 Best practices include, but are not limited to;

                                                  tightening of packing gland nuts

                                                  ensuring that the seal flush is operating at
                                                 design pressure and temperature	
   Exemptions
                    ADDS:

                    Pumps in light liquid
                    service within a
                    process unit located on
                    the Alaskan North
                    slope.
                  ADDS:

                  Pumps in light liquid
                  service within a process
                  unit located on the
                  Alaskan North slope and
                  those located at a non-
                  fractionating plant that
                  does not have the design
                  capacity to process
                  283,000 standard cubic
                  meters per day or more of
                  field gas are exempt from
                  the routine monitoring
                  requirements of §60.482-
                   Not applicable.
                   ADDS:

                   Equipment operated less than 300 hours per year.

-------
SUMMARY OF REGULATION DIFFERENCES
page B-12
Specific
Component
Summaries
REGULATION
40CFRPart60, 40CFRPart60, 40CFRPart60,
SubpartDDD SubptrtGGG Subpart KKK
40CFRP«t60.
Subp« QQQ
40CFRPart63,
Subpart CC
(existing)
PUMPS, HEAVY LIQUID SERVICE
Standards
Leak
Definition
Repair
First Attempt
at Repair
Exemptions





Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
40CFRPart63,
Subpart CC
(existing or new)



ADDS:
For pumps in heavy liquid service that are not monitored (Method 2!), repair shall
mean that visual, audible, olfactory, or other indications of a ieak have been eliminated;
no bubbles are observed at potential leak sites during leak check with soap solution; or
system will hold a test pressure.

ADDS:
Equipment operated less than 300 hours per year.
Reciprocating pumps in heavy liquid service.

-------
SUMMARY OF REGULATION DIFFERENCES
page B-1'3

Specific
Component
Summaries

REGULATION

40 GFR Part 60, 40CFRPart60,
Subpart ODD Subpart GOG

40CFRPart60,
Subpart KK.K

40CFRPart60,
Subpart QQQ

40 CFR Part 63,
Subpart CC
(existing)
40 CFR Part 63,
Subpart CC
(existing or new)
PRESSURE RELIEF DEVICES, GAS/VAPOR SERVICE
Standards












Leak
Definition

Repair

























ADDS Option;
Option I; Monitor
quarterly and after each
release monitor within 5
days. At
nonfractionating plants
where monitoring is done
by non-plant personnel,
monitoring after each
release must be done
when non-plant
personnel are next on-site
but within 30 days.
ADDS:

Option 1; I0,000ppmv
ADDS:
Option 1: First attempt
to repair within 5 days.
Completed repair within
1 5 days.
Not applicable.












Not applicable.


Not applicable.

















ADDS:
.vyith.Ruptme.Pisk.

After each release, replace rupture disk within 5
calendar days.
















Not applicable.





-------
SUMMARY OF REGULATION
page B44
Specific
Component
Summaries

40CFRP«rt60,
Subpwt ODD
REGULATION
40CFRPat60,
Subpart 000
40CFRPart60,
Subpart KKK
40CFRPartfiO,
SubpwtQQQ
40CFRPsrt63,
Subpart CC
(existing)
40eFRPart63,
Subpart CC
(existing or new)
PRESSURE RELIEF DEVICES, GAS/VAPOR SERVICE (concluded)
Exemptions

ADDS:
PRDs in gas/vapor
service within a process
unit located on the
Alaskan North slope and
those located at a non-
fractionating plant that
docs not have the design
capacity to process
283,000 standard cubic
meters per day or more of
field gas are exempt from
the routine monitoring
requirements of
§60.632(b)(l).
Not applicable.
ADDS:
Equipment operated less than 300 hours per year.
PRESSURE RELIEF DEVICES, LIGHT LIQUID OR HEAVY LIQUID SERVICE
Standards
Leak
Definition
Repair
Exemptions

10,000 ppm


Not applicable, .
Not applicable.
Not applicable.
Not applicable.

1 0,000 ppm

Monitoring: 500 ppm
ADDS:
For pressure relief devices in liquid service that
are not monitored (Method 21), repair shall mean
that visual, audible, olfactory, or other
indications of a leak have been eliminated; no
bubbles are observed at potential leak sites
during leak check with soap solution; or system
will hold a test pressure.
ADDS:
Equipment operated less than 300 hours per year.

-------
SUMMARY OF REGULATION DIFFERENCES
page B-15
Specific
Component
Summaries
REGULATION
40 CFR Part 60,
Subpart DDD
COMPRESSORS
Standards
Leak
Definition
Repair
Exemptions
40 CFR Part 60,
Subpart GGO
40 CFR Part 60,
Subpart KKK
40 CFR Part 60,
Subpart QQQ
40 CFR Part 63,
Subpart CC
(existing)
40 CFR Part 63,
Subpart CC
(existing or new)





SAMPLING CONNECTION SYSTEMS
Standards
Leak
Definition
Repair
Exemptions
ADDS:
Reciprocating
compressors that are in
hydrogen service.
ADDS:
Reciprocating
compressors that are in
wet gas service.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
ADDS:
Subpart H does not require compressors located at unmanned plant sites to be comply
with daily sensor check or be equipped with audible alarm. '


ADDS:
Equipment operated less than 300 hours per year.
Compressors in hydrogen service.

Equipped with closed-purge, closed-loop, or
closed-vent system that returns the purged
process fluid to the process line, collects and
recycles the purged process fluid to a process, or
is designed and operated to capture and transport
all the purged process fluid to a compliant
control device.
Not applicable.
Not applicable.

Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not -applicable.
Not applicable.
Equipped with closed-purge,
closed-loop, or closed-vent system
that returns the purged process
fluid to the process line or collects
and recycles the purged process
fluid to a process or is designed
and operated to capture and
transport all the purged process
fluid to a compliant control
device.
Not applicable.
Not applicable.
Equipped with closed-purge system, closed-loop,
or closed-vent system that either returns the fluid
to the process, recycles the purged fluid, or sends
it to a compliant control device.
Gases displaced during filling of samples are not
required to be collected or captured.
Not applicable.
Not applicable.
ADDS:
Equipment operated less than 300 hours per year.

-------
SUMMARY OF REGULATION
page B-16
Specific
Component
Summaries
REGULATION
40CFRPart60,
Subpart ODD
OPEN-ENDED VALVES OR LINES
Standards
Leak
Definition
Repair
Exemptions
40CFRPart60,
Subpart GOO

40CFRPart60,
Subpart KKK
40CFRPart«>,
Subpart QQQ
40CPRPart63»
Subpart CC
(existing)
40CFRP«t63,
Subpart CC
(existing or new)


Not applicable.
Not applicable.

Not applicable.
Not applicable.
Not applicable.
Not applicable.

Not applicable.
Not applicable.
ADDS;
Equipment operated less than 300
hours per year.
ADDS;
Open-ended valves and lines in an emergency
shutdown system that are designed to open
automatically in the event of a process upsei.
Equipment operated less than 300 hours per year.
FLANGES AND OTHER CONNECTORS (ALL SERVICES)
Standards
Leak
Definition
Repair
Exemptions




Not applicable.
Not applicable.
Not applicable.
Not applicable.

ADDS:
Alternatively, connectors in gas/vapor and light
liquid service may comply with an alternative
program (see Connectors, gas/vapor or light
liquid service).


ADDS:
Equipment operated less than 300 hours per year.

-------
                                                        SUMMARY OF REGULATION DIFFERENCES
                                                                                                                                                    page B-17
   Specific
  Component
  Summaries
                                                                                        REGULATION
  40 CFR Part 60,
   Subpart DDD
   40 CFR Part 60,
    Subpart 000
    40 CFR Part 60,
     Subpart KKK
   40 CFR Part 60,
    Subpart QQQ
       40 CFR Part 63,
         Subpart CC
          (existing)
40 CFR Part 63,
  Subpart CC
(existing or new)
CONNECTORS, GAS/VAPOR OR LIGHT LIQUID SERVICE
    Standards
Not applicable.
Not applicable.
Not applicable.
Not applicable.
NOTE: The following applies only to units opting to comply with §63.649.

Option 1: Random 200 Connector Alternative

 Initial monitoring of 200 randomly selected connectors within first 12 months

 Monitor each repaired leak within 3 months

 Subsequent monitoring required based on percent leaking connectors:

         Percent Leaking     Frequency
                                                                                                                  >2.Q
                                                                                                                  <2
                                                                                                                  <1
                                                                                                                  <0.5
                                                                                                                   semiannual
                                                                                                                   annual
                                                                                                                   every 2 years
                                                                                                                   every 4 years
                                                                                                        Identify by area or length of pipe; physical tagging and individual component
                                                                                                       identification is not required.

                                                                                                       Option 2:  Connector Inspection Alternative   .

                                                                                                        For all connectors >2 inches in diameter, monitor if in gas/vapor service and inspect if
                                                                                                       in light liquid service within 12 months after compliance date. Excludes inaccessible
                                                                                                       and unsafe-to-monitor connectors.

                                                                                                        Monitor/inspect each repaired leak within 3 months

                                                                                                        Subsequent monitoring required based on percent leaking connectors:

                                                                                                                Percent Leaking    Frequency
                                                                                                                  >2.0
                                                                                                                  <2
                                                                                                                   annual
                                                                                                                   every 2 years
                                                                                                                   every 4 years

-------
SUMMARY OF REGULATION
page B-18
Specific
Component
Summaries
REGULATION
40CFRPart<50,
Subpart ODD
40CFRPart60,
SubpartOOO
40CFRPart60,
Subpart KKK
40CFRPart60,
Subpart QQQ
40CFRPart63, 40CFRPart63,
Subpart CC Subpart CC
(existing) (existing or new)
CONNECTORS, GAS/VAPOR OR LIGHT LIQUID SERVICE (concluded)
Standards
(concluded)
Leak
Definition
Repair
Exemptions

Not applicable.
Not applicable.
Not applicable.

Not applicable.
Not applicable.
Not applicable.

Not applicable.
Not applicable.
Not applicable.

Not applicable.
Not applicable.
Not applicable.
Option 2 concluded:
Equation to calculate percent leaking provided.
Cannot combine gas/vapor and light liquid to calculate percent leaking.
Identify by area or length of pipe; physical tagging and individual component
identification is not required.
Option I: l.OOOppm
Option 2: gas/vapor service - 1,000 ppm
light liquid service - 3 drips per minute
Repair as soon as practicable, but no later than 15 calendar days after detection.
First attempt to repair within 5 calendar days of detection.
Delay of repair allowed under certain circumstances
Equipment in vacuum service,
Equipment operated less than 300 hours per year.

-------
SUMMARY OF REGULATION DIFFERENCES
page B-19
Specific
Component
Summaries
REGULATION
40CFRPart60,
Subpart ODD
40 CFR Part 60,
Subpart GGG
40 CFR Part 60,
Subpart KKK
40 CFR Part 60,
Subpart QQQ
40 CFR Part 63, 40 CFR Part 63,
Subpart CC Subpart CC
(existing) (existing or new)
INSTRUMENTATION SYSTEMS
Standards
Leak
Definition
Repair
Exemptions
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable,
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Monitoring of potential leaks within 5 calendar days of detection if evidence of
potential leak is found by visual, audible, olfactory, or other detection method.
1 0,000 ppm
Repair as soon as practicable, no later than 15 calendar after detection.
For instrumentation systems that are not monitored (Method 21), repair shall mean thai
visual, audible, olfactory, or other indications of a leak have been eliminated; no
bubbles are observed at potential leak sites during leak check with soap solution; or
system will hold a test pressure.
Equipment in vacuum service.
Equipment operated less than 300 hours per year.

-------
SUMMARY OF REGULATION
page B-20
Specific
Component
Summaries
REGULATION
40CFRPart60, 40CPRPart«, 40CPRPart60,
SubpartDDD SubpsrtOOO SubptrtKKK
CLOSED VENT SYSTEMS AND CONTROL DEVICES
Standards



Monitoring
Leak
Definition
Repair




Closed-Vent Systems (CVS)
Hard pipe construction: Initial inspection (Method 21) and ihen annual visual
inspections.
Ductwork construction: Initial and annual inspections using Method 21.
Does not apply if CVS is in vacuum service.


Repair as soon as practicable, but no later than 1 5 calendar days after
detection.


40CFRPM60,
SubpartQQQ
40CFRPart63, 40 CFR Part 63,
SubpartCC SubpaitCC
(existing) (existing or new)



Closed-Vent Systems
(CVS)
No detectable emissions
(less than 500 ppm
above background).
Monitor initially and
semiannually (hereafter.
No monitoring
requirements for closed-
vent systems, "unsafe-
to-monitor" parts, and
"diffieult-to-monitor"
parts.

Repairs soon as
practicable, but no later
than 30 calendar days
after detection.
DELETES:
First attempt to repair
within 5 calendar days
of detection.
Control Devices
Variation when complying wllh subpart H:
Combustion devices; 95 percent or greater reduction or minimum residence time of
0.50 seconds and minimum temperature of 760°C.
Closed-Vent Systems (CVS)
Hard pipe construction: Initial inspection (Method 21) and then annual visual
inspections.
Ductwork construction: Initial and annual inspections using Method 21.
Does not apply if CVS is in vacuum service.


Repair as soon as practicable, but no later than 1 5 calendar days after detection.



-------
SUMMARY OF REGULATION DIFFERENCES
page B-21
Specific
Component
Summaries
REGULATION
40CPRPart60,
Subpart ODD
40CFRPart60,
Subpart OGQ
40CFRPart60,
Subpart KKK
40 CFR Part 60,
Subpart QQQ
40 CFR Part 63,
Subpart CC
(existing)
40 CFR Part 63,
Subpart CC
(existing or new)
CLOSED VENT SYSTEMS AND CONTROL DEVICES (concluded)
Exemptions

Not applicable.
ADDS:
Equipment operated less than 300
hours per year.
ADDS:
Equipment operated less than 300 hours per year.
Equipment needed for safety purposes are not
subject to these monitoring requirements.

-------
SUMMARY OF REGULATION
page B-22
Del«yorRcpalr
General
Valves
Pumps
REGULATION
40 CFR Part 60,
SubpartDDO
40 CFR Part 60,
Subpart GGG
40 CFR Part 60,
Subpart KKK
Allowed Tor equipment isolated from (lie process and (hat does not
remain in VOC service.
Not allowed unless next process unit shutdown occurs sooner than 6
months after 1st process unit shutdown.
Repair requires use of DMS seal system that includes barrier fluid
40 CFR Part 60,
Subpart QQQ
(see "Closed-vent
Systems and Control
Devices")
(see "Closed-vent
Systems and Control
Devices")
(see "Closed-vent
Systems and Control
Devices")
40 CFR Part 63,
Subpart CC
(existing)
40CFRPart63,
Subpart CC
(existing or new)
Allowed lor equipment isolated from the process and thai does not remain in organic HAP
service.
Not allowed unless next process unit
shutdown occurs sooner than 6 months
after 1st process unit shutdown.
Repair requires use of DMS seal system
that includes barrier fluid
Not allowed beyond the second process unit
shutdown unless the third process unit
shutdown occurs sooner than 6 months after
1st process unit shutdown.
Repair requires replacing existing seal design
with a new system that provides better
performance, DMS, meets requirements of
§63.163(1), or compliant closed-vent system
and control device.

-------
SUMMARY OF REGULATION DIFFERENCES
page B-23
Equivalence of (or
Alternative) Means
of Emission
Limitation:
General
Equipment, Design,
and Operational
Requirements
Work Practices
Unique Approach
Manufacturers of
Equipment
REGULATION
40CFRPart60, 40CFRPart60,
SubpartDDD SubpartGOG
Owner/operator collect and verily test
data to demonstrate equivalence.
Administrator compares test data.
Owner/operator collect and verify test
data to demonstrate equivalence
Owner/operator demonstrates emission
reduction achieved by required work
practice
Owner/operator demonstrates emission
reduction achieved by equivalent means
of emission limitation
Owner/operator commits to alternative
work practices
Administrator compares demonstrated
emission reductions

40 CFR Part 60,
Subpart KK.K
Applicant collect and verify test
data, covering 12 months, to
demonstrate equivalence or better,
Administrator makes finding.
Applicant commits to alternative
means.
Applicant collect and verify test
data, covering 12 months, to
demonstrate equivalence or better.
Administrator makes Finding,
Applicant commits to alternative
means.
None specified.
40 CFR Part 60,
Subpart QQQ
Any person collect and verily test
data to demonstrate equivalence.
Administrator makes finding.
Any person collect and verify test
data to demonstrate equivalence.
Administrator makes finding.
None specified.
40 CFR Part 63, Subpart CC
(existing)
40 CFR Part 63,
Subpart CC
(existing or new)
Owner/operator collect and verify test data for alternative means
of emission limitation.
Administrator compares test data.
Owner/operator collect and
verity test data to
demonstrate equivalence.
Owner/operator demonstrates
emission reduction, achieved
by required work practice.
Owner/operator demonstrates
emission reduction achieved
by equivalent means of
emission limitation,
Owner/operator commits to
alternative work practices.
Administrator compares
demonstrated emission
reductions.
Owner/operator collect and
verify test data for alternative
means of emission limitation.
Owner/operator demonstrates
emission reduction achieved
by required work practice (for
minimum of 12 months).
Owner/operator demonstrates
emission reduction achieved
by alternative means of
emission limitation.
Owner/operator commits to
alternative work practices.
Administrator compares
demonstrated emission
reductions.



-------
SUMMARY OF REGULATION DIFFERENCES
page B-24
Alternative Means
of Emission
1, imitations:
Gncteed-Venled
Process Unils













REGULATION


40 CFR Part 60,
SubptrtDDD

Not applicable.












40CFRPartdO,
Subpart GOO

Not applicable.












40 CFR Part 60,
Subpwt KKK

Not applicable.












40CFRPart60,
SubpanQQQ

Not applicable.












40 CFR Part 63, Subpart CC
(existing)

Not applicable.












40 CFR Part 63,
Subpart CC
(existing or new)
Process units enclosed such
that all emissions from
equipment leaks are vented
through a closed-vent system
to a control device arc exempt
from the requirements of
§§63.163 through 63.171 nnd
§§63. 173 and 63, 174.
Enclosure is to be maintained
under negative pressure at all
times the process unit is in
operation.

-------
                                                     SUMMARY OF REGULATION DIFFERENCES
                                                                                                                                               page B-25
  Quality
Improvement
 Programs
                                                                                      REGULATION
 40CFRPart60,
  Subpart ODD
 40CFRPart60,
  Subpart GOG
  40CFRPart60,
   Subpart KKK
  40 CFR Part 60,
   Subpart QQQ
 40 CFR Part 63,
   Subpart CC
   (existing)
                       40 CFR Part 63,
                         Subpart CC
                       (existing or new)
   Applicability
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Valves

Optional In phase III to ownersloperators with >4% leakers if not also
complying with §63.649 or with >S% leakers if also complying with
§63.649.

Decision required within first year of phase III.

If roiling average of percent leakers is <4% (10% or 3 pumps leaking.

Once <10% or <3 pumps leaking is achieved, comply with §63.163.

If leak rate again exceeds the greater of either >IO% or 3 pumps leaking,
can use QIP again.	

-------
                                                        SUMMARY OF REGULATION DIFFERENCES
                                                                                                                                                          B-26
                                                                                          REGULATION
   Quality
 improvement
  Programs
 40CFRPart«0,
  Subpart ODD
 4QCPRPart60,
  SubpsrtGGQ
  40CFRPart60,
   Subptrt KKK
  40CFRPart6Q,
   Subpart QQQ
 40CFRPart63,
   Subpart CC
    (existing)
                        4aCFRPart63,
                          Subpart CC
                        (existing or ne%v)
        Valves,
Demonstration of
 Further Progress
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Collect data and maintain records as follows:

 • maximum instrument reading observed in each monitoring observation
before repair, the response factor for each stream, the instrument model
number, and the date of observation

 • 'classification of valve "gas or light liquid service"

 • repair method used and instrument readings after repair (monitoring
required at least once within the first 3 months after the repair is
completed)(ID tag on a leaking valve may be removed after the valve
successfully passes this monitoring period)

Continue to collect data on the valves for as long as the process unit is in
QIP

Demonstrate progress in reducing the percent leaking valves each quarter
by at least:

 • 10 percent (meaning that each quarter there is at least a 10 percent
reduction in the percent leaking valves from the preceding monitoring
period) [calculation to be made by formula specified in §63.I75(d)(4)(i)],
or

 • alternative quarterly percent reduction [calculated according to the
equation in §63. l.7S(d)(4)(iii)(A)] and to less than 4 (5) percent within 2
years,
                                                                                                                  The provisions for failure to meet the 10 percent reduction for 2
                                                                                                                  consecutive rolling averages are:

                                                                                                                   • a choice of monthly monitoring, or

                                                                                                                   • implementation of a QIP for technology review as specified in
                                                                                                                  §63.175(e).

-------
                                                       SUMMARY OF REGULATION DIFFERENCES
                                                                                                                                                     page B-2?
  Quality
Improvement
  Programs
                                                                                          REGULATION
 40CFRPart60,
   Subpart ODD
 40 CFR Part 60,
  Subpart GGG
  40 CFR Part 60,
   Subpart KKK
  40 CFR Part 60,
   Subpart QQQ
 40 CFR Part 63,
   Subpart CC
   (existing)
                        40 CFR Part 63,
                           Subpart CC
                        (existing or new)
       Valves,
    Technology
    Review and
   Improvement
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Data collection for the valves as long as in QIP:

         Valve type and manufacturer, valve design, materials of
         construction, packing material, and year installed.

         Service characteristics of the stream (e.g., operating pressure,
         temperature, line diameter, corrosivity).

         Gas/vapor or light liquid service.

         if a leak is detected, the maximum instrument reading observed
         before a repair, response factor for stream if adjusted,
         instrument model number, and date of observation.

         Repair methods used and the instrument readings after the
         repair,

Inspect all valves removed due to leaks to determine cause of failure and
recommend design and other changes to reduce leak potential.

Analyze data to determine the services, operating and maintenance
procedures, and valve designs or technologies that have poorer than
average emission performance and those that have better than average
emission performance. The first analysis shall be completed no later than
18 months after the start of Phase III,  shall use a minimum of 6 months of
data, shall be done yearly for as long as the process unit is in  the Q!P
program.

-------
                                                      SUMMARY OF REGULATION DIFFERENCES
                                                                                                                                                  page B-28
  Quality
Improvement
  Programs
                                                                                        REGULATION
 40CFRPart60,
   Subpact ODD
 40CFRPart«J,
  Subpart OGG
  40CFRPart60,
   Subpart KKK
  40CFRPart60,
   Subpart QQQ
 40CFRPart63,
   Subpart CC
    (existing)
                        40€PRP8rt63,
                          Subpart CC
                        (existing or new)
       Valves,
    Technology
    Review and
   Improvement
    (concluded)
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Trial evaluation program is required for plants that have not demonstrated
superior performing valve designs and technologies;

 I,  The number of valves In the trial program shall be the lesser of 1
percent or 20 valves for programs involving single process units and the
lesser of 1 percent or 50 valves for programs involving groups of process
units.

 2,  The program shall specify and Include design documentation of:

         superior performing valve designs or technologies
         the stages of evaluating these valve designs or technologies
         the frequency of monitoring or inspection
         range of operating conditions component will be evaluated
         under
         conclusions regarding the emission performance and
         appropriate operating conditions and services

The performance trials shall be conducted for a 6-month period beginning
no later than 18 months after the beginning of the QIP.

Conclusions will be drawn no later than 24 months after the beginning of
the QIP.

Any plant site with fewer than 400 valves and owned by a company with
fewer than 100 total employees is exempt from the trial evaluations of
valves. These exempted plants shall begin the program at the start of the
fourth year of Phase 111.

If superior emission performance technology can not be identified,
replacement valve shall be one with lowest emission performance
technologies identified tor the specific application.	

-------
                                                       SUMMARY OF REGULATION DIFFERENCES
                                                                                                                                                     page B-29
  Quality
Improvement
  Programs
                                                                                          REGULATION
 40 CFR Part 60,
   SubpartDDD
 40 CFR Part 60,
  Siibpart 000
  40 CFR Part 60,
   Subpart KKK
  40 CFR Part 60,
   Subpart QQQ
 40 CFR Part 63,
   Subpart CC
   (existing)
                        40 CFR Part 63,
                          Subpart CC
                        (existing or new)
       Pumps,
    Technology
    Review and
   Improvement
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Data collection:

         Pumps; type and manufacturer, seal type and manufacturer,
         pump design, materiais of construction, barrier fluid or packing
         material, and year installed,

         Service characteristics of the slream; discharge pressure,
         temperature, flow rate, corrosivity, annual operating hours.

         Maximum instrument readings observed before repair, response
         factor for the stream, instrument number, and date of
         observation.

         If a leak is detected, repair methods used and the instrument
         readings after the repair.

Inspect all pumps or pump seals that exhibit frequent seal failure and were
removed due to leaks.  Inspection shall determine probable cause and
recommendation for design changes or changes in specifications to reduce
leak potential.

Analyze data to determine the services, operating and maintenance
procedures, and pumps and pump seal designs or technologies that have
poorer than average emission performance and those that have better than
average emission performance. The first analysis shall be completed no
later than 18 months after the start of the program, shall use a minimum of
6 months of data, shall  be done yearly for as long as the process unit is in
the QIP program,

-------
                                                       SUMMARY OF REGULATION DIFFERENCES
                                                                                                                                                   page B-30
  Quality
Improvement
  Programs
                                                                                         REGULATION
 40 CFR Part 60,
  SubpartDUU
 40 CFR Part 60,
  Subpart GOG
  40 CFR Part 60,
   Subpart KKK
  40 CFR Part 60,
   Subpart QQQ
 40 CFR Part 63,
   Subpart CC
   (existing)
                        40 CFR Part 63,
                          Subpart CC
                        (existing or new)
        Pumps,
    Technology
    Review and
   Improvement
    (concluded)
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Trial evaluation program is required for plants that have not demonstrated
superior technologies:

 1.  The number of pump seal technologies or pumps in the trial program
shall be the lesser of 1 percent or 2 pumps for programs involving single
process units and the lesser of I  percent or 5 pumps for plant sites or
groups of process units. The minimum number of pumps or pump seal
technologies in the program shall be 1; and

 2.  The program shall specify and include design documentation of:

         superior performing pump seal designs or technologies
         the stages of evaluating these pump designs or pump seal
         technologies
         the frequency of monitoring or inspection
         range of operating conditions component will be evaluated
         under
         conclusions regarding the emission performance and
         appropriate operating conditions and services

The performance trials shall be conducted for a 6-month period beginning
no later than 18 months after the beginning of the QIP.

Conclusions will be drawn no later than 24 months after the beginning of
the QIP.

Beginning at the start of the third year of the QIP for plants with 400 or
more valves or 100 or more employees and at the start of the fourth year
for others, the owner/operator shall  replace the pumps and pump seals that
are not superior technology. Pumps or pump seals shall be replaced at the
rate of 20 percent per year and shall continue to be replaced until all are
superior technology.	

-------
                                                         SUMMARY  OF REGULATION DIFFERENCES
                                                                                                                                                   page B-31
 Test Methods and
    Procedures
                                                                                        REGULATION
 40 CFR Part 60,
  Subpart ODD
40 CFR Part 60,
 Subpart QOG
40 CFR Part 60,
 Subpart KKK
40 CFR Part 60,
 Subpart QQQ
40 CFR Part 63,
  Subpart CC
   (existing)
40 CFR Part 63,
  Subpart CC
(existing or new)
Monitoring Method
and Technique
Test each piece of equipment unless demonstration is made that
equipment is not in VOC service
                                                              Test each piece of equipment
                                                              unless demonstration is made that
                                                              equipment is not in organic HAP
                                                              service,
                                                                         Instrument to meet performance criteria of
                                                                         Method 21 except:

                                                                          response factor criteria is for the average
                                                                         composition of the process fluid, not each
                                                                         individual VOC in stream

                                                                          for process streams that contain inerts that
                                                                         are not organic HAP or VOC, average stream
                                                                         response factor is calculated on an inert-free
                                                                         basis

                                                                         If no instrument available that meet all
                                                                         Method 21 criteria, then instrument readings
                                                                         may be adjusted as specified.

                                                                         Monitor all equipment while it is "in service"
Calibration
calibration gases used:

 mixture of methane or n-hexane and air at about, but less than, 10,000 ppm methane or n-hexane
                                                                                             calibration gases used:

                                                                                              Phase I:  mixture of methane in air at
                                                                                             concentration of about, but less than, 10,000
                                                                                             ppm

                                                                                              Phase II: mixture of methane in air at
                                                                                             concentration of about, but less than:

                                                                                               10,000 ppm for agitators
                                                                                               5,000 ppm for pumps
                                                                                                 500 ppm all other equipment

-------
SUMMARY OF REGULATION DIFFERENCES
page B-32
Test Methods »icl
Procedures







"No detectable
emissions"
monitoring
REGULATION
40CFRPirt60,
Subpsrt ODD







4QCPRP«t60,
Subpart 000







40CFRPart60,
Subpart KKK.







40CFRPart«,
Subpsrt QQQ







«CFRPart«.
Subpart CC
(existing)







40CFRP»t63,
Subpart CC
(existing or new)
Phase HI; mixture of methane in air at
concentration or about, but less limn:
10,000 ppm Tor agitators
2,000 ppm for pumps in food/ medical .
service
5,000 ppm for pumps in polymerizing
monomer service
1,000 ppm for all other pumps
500 ppm for all other equipment
Phases II and III Exception: under certain
conditions may calibrate up to 2,000 ppm
higher than the leak definition


-------
                                                         SUMMARY OF REGULATION DIFFERENCES
                                                                                                                                                   page B-33
 Test Methods and
    Procedures
                                                                                         REGULATION
 40 CFR Part 60,
  Subpart ODD
   40 CFR Part 60,
    Subpart GOG
  40 CFR Part 60,
   Subpart KICK.
    40 CFR Part 60,
     Subpart QQQ
       40 CFR Part 63,
         Subpart CC
          (existing)
            40 CFR Part 63,
              Subpart CC
            (existing or new)
Not "in service"
demonstration
Equipment must be demonstrated not to be
in VOC service (i.e., VOC content never
greater than 10% by weight).
                   For demonstration:

                   Use procedures that conform to ASTM E-
                   260, E-168, E-I69 to determine percent
                   VOC in process fluid that is contained or
                   contacts a piece of equipment.

                   Engineering judgement may be used to
                   estimate the VOC content if piece of
                   equipment had not been shown previously
                   to be in VOC service.

                   Administrator will require use of ASTM
                   Method D-2267b in event of disagreement
                   to determine VOC content,

                   Compounds determined by EPA to have
                   negligible photochemical reactivity can be
                   excluded in determining VOC content of a
                   process fluid.                 	
                      Equipment must be
                      demonstrated that
                      the percent VOC
                      content can be
                      reasonable expected
                      never to exceed
                      10.0 percent by
                      weight.

                      For demonstration:

                      Use procedures that
                      conform to ASTM
                      Methods El69,
                      E168,orE-260
                      (incorporated by
                      reference).
                    Not applicable.
                        Equipment is presumed to be in organic HAP service unless demonstrated that the
                        organic HAP content can never reasonably expected to exceed 5 percent by weight.
                                                                                    For demonstration:

                                                                                    Use Method 18 of 40 CFR Part 60, appendix A to determine percent organic HAP,

                                                                                    Engineering judgment may be used to determine percent organic HAP does not
                                                                                    exceed 5 percent.

                                                                                    Owner/operator may instead determine organic HAP content does not exceed 5
                                                                                    percent by weight.
"In wet gas service"
Not applicable.
Not applicable.
Equipment to be in
wet gas service, it
must be determined
that it contains or
contacts the .field
gas before the
extraction step in
the process.	
Not applicable.
Not applicable.
Not applicable.

-------
SUMMARY OP REGULATION
page B-34
Test Methods and
Procedures
Not "in hydrogen
service"




Samples
Vapor pressures


Flare Compliance
REGULATION
40CFRPart60,
Subpart ODD
Not applicable.




40CFRPart60,
SubpnrtGGG
Equipment must be
demonstrated to be
not in hydrogen
service; that is, ihe
percent hydrogen
content can be
reasonably expected
always to exceed 50
percent by volume.
For demonstration:
Use procedures Ihat
conform to the
general method
described in ASTM
E-260,E-168,orE-
169.
Engineering
judgement may be
used instead provided
it demonstrates that
the content clearly
exceeds 50 percent by
volume.
In case of
disagreement, the
ASTM procedure
results will prevail.
4QCFRPart60,
Subpart KKK
Not applicable.




Representative of process fluid that is contained in or contacts the
equipment or the gas being combusted in flare.
Standard reference texts
or
ASTM D-2879
40CFRPart60,
Subpsrt QQQ
Not applicable.




Not applicable.
Not applicable.


40CPRP8rt63,
Subpart CC
(exiiting)
Not applicable.




40CFRPart63,
Subpart CC
(existing or new)
Not applicable.




Representative of process fluid that is contained in or contacts the equipment.
None specified.


None specified.




-------
                                                          SUMMARY OF REGULATION DIFFERENCES
                                                                                                                                                 page B-35
    Reeordkeeping
    Requirements
                                                                                              REGULATION
  40CFRPart60,
   Subpart ODD
40 CFR Part 60,
 Subpart 000
40 CFR Part 60,
 Subpart KKK
40 CFR Part 60,
 Subpart QQQ
40 CFR Part 63,
  Subpart CC
   (existing)
40 CFR Part 63,
  Subpart CC
(existing or new)
Consolidated
Recordkeeping
An owner or operator of more than one affected facility subject
to this subpart may use one recordkeeping system if the system
identifies each record by facility.
                                    None specified.
                                              An owner or operator of more than
                                              one process unit subject to this
                                              subpart may use one recordkeeping
                                              system if the system identifies each
                                              record by process unit.
                                                        An owner or operator of more than one
                                                        process unit subject to this subpart may use
                                                        one recordkeeping system if the system
                                                        identifies each record by process unit and
                                                        the program being implemented for each
                                                        type of equipment.
When leak detected.
Tagging Requirements;
                        for valves, id may be removed after 2 months of monitoring
                       with no leaks detected
                       Log Requirements:
                        dates of each attempt to repair leak
                        repair methods applied in each attempt to repair
                        "above 10,000" if maximum instrument reading after each
                       repair attempt is > 10,000 ppm
                                    Tagging Requirements:

                                    None required.
                                                         Log Requirements:

                                                          location


                                                          date

                                                          corrective action taken
                                              Tagging Requirements:
                                                                                       for valves, id may be removed
                                                                                      after 2 months of monitoring with
                                                                                      no leaks detected
                                                                 Log Requirements:
                                                                  dates of each attempt to repair
                                                                 leak

                                                                  repair methods applied in each
                                                                 attempt to repair

                                                                  "above  10,000" if maximum
                                                                 instrument reading after each repair
                                                                 attempt is > 10,000 ppm
                                                        Tagging Requirements:

                                                        ALSO applies to connector

                                                         for valves and connectors, id may be
                                                        removed after it has been monitored as
                                                        specified and no leak has been detected
                                                        during the follow-up monitoring

                                                        Log Requirements:

                                                        ADDS: operator name and initials

                                                         dates of first attempt to repair leak
                                                                                                                        maximum instrument reading after
                                                                                                                       successful repair or determined to be
                                                                                                                       nonrepairable
                                                                                If delay:

                                                                                 reason tor delay

-------
                                                      SUMMARY OF REGULATION DIFFERENCES
                                                                                                                                       page B-36
   Recordteepini
    Requirements
                                                                                         REGULATION
40CFRP«t«»,
 SubjWl DOD
40CFRPart60,
 Subpart GGO
40 Cm Part 60,
 Subptrl KKK
40 CPR Part 60,
 SubpartQQQ
40CFRPwt63,
  Subpart CC
   (existing)
4QCFRP»rt63,
  SubptrtCC
(existing or new)
When leak detected,
(concluded)
                      Retain for 2 years in readily accessible location.
                                                     Retain for 2 years
                                                             Retain for 5 years; most recent 2
                                                             years on-site or accessible from
                                                             central location via computer; other
                                                             3 years may be off-site.
                                                                            for connectors: id of connectors disturbed
                                                                          since last monitoring period, and dates and
                                                                          results of follow-up monitoring

                                                                            copies of periodic reports (if database not
                                                                          capable of generating such)

                                                                          Retain for 5 years; most recent 2 years on-
                                                                          site or accessible from central location via
                                                                          computer; other 3 years may be off-site,

                                                                          DELETES:

                                                                            signature of owner/operator whose decision
                                                                          it was that repair could not be effected
                                                                          without a process shutdown

-------
                                                           SUMMARY OF REGULATION DIFFERENCES
                                                                                                                                                     page B-37
    Recordkeeping
    Requirements
                                                                                                REGULATION
  40 CFR Part 60,
   Subpart ODD
 40 CFR Part 60,
  Subpart GOG
 40 CFR Part 60,
  Subpart KKfC
      40 CFR Part 60,
       Subpart QQQ
        40 CFR Part 63,
          Subpart CC
           (existing)
            40 CFR Part 63,
               Subpart CC
            (existing or new)
Closed vent systems
and control devices
 periods when not operated according to design

 dates of startups and shutdowns of control devices and closed-
vent systems

Keep these records in a readily accessible location.
                                      For life of facility:

                                       documentation that control
                                      device will achieve required
                                      control efficiency during
                                      maximum loading conditions

                                      For 2 years:

                                       periods when not operated
                                      according to design

                                       dates of startups and
                                      shutdowns of control devices
                                      and closed-vent systems

                                      Incinerators: temperatures and
                                      exceedances

                                      Carbon adsorbers: outlet VOC
                                      concentrations and
                                      exceedances

                                      For no detectable emissions:

                                       dates of each  measurement
                                       background level
                                       maximum instrument reading
                                                  periods when not operated
                                                 according to design

                                                  dates of startups and shutdowns of
                                                 control devices and closed-vent
                                                 systems

                                                 Keep these records in a readily
                                                 accessible location.
                                                               Design Specifications and Performance
                                                               Demonstration:

                                                                - flare design and compliance
                                                               demonstration results

                                                               The design specification and performance
                                                               demonstration records are to be kept for the
                                                               life of the equipment.

                                                               Records of Operation:

                                                                - records of operation of closed-vent
                                                               systems and control devices

                                                                - dates and duration when closed-vent
                                                               systems, and control devices not operated
                                                               according to design

                                                                - dates and duration when monitoring
                                                               systems/devices are nonoperative

                                                                - dates of startups and shutdowns

                                                                - records of closed-vent inspections

                                                               Retain for 5 years; most recent 2 years on-
                                                               site or accessible from central location via
                                                               computer; other 3 years may be off-site.
Visual Inspections
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
 documentation that inspection was
conducted

 dates of inspection

Retain for 5 years; most recent 2 years on-
site or accessible from central location via
computer; other 3 years may be off-site.

-------
                                                          SUMMARY OF REGULATION DIFFERENCES
                                                                                                                                                        B-38
    Rccordkccplng
    Requirement
                                                                                               REGULATION
  40CPRPart60,
   Subpart ODD
4QCFRPart60,
 Subpart GOO
40CFRPart60,
 Subpart KKK
40CFRPartW,
 Subpart QQQ
40GFRPwt63,
  SubpirtCC
   (existing)
4QCPRPart63,
  SubpirtCC
(existing or new)
All equipment ...
 list ofid numbers of subject equipment

 list ofid numbers of equipment designated for no detectable
emissions and signed by owner/operator

 list ofid numbers for pressure relief devices in gas/vapor
service

 for each compliance test for components designated for no
detectable emissions:

  dates conducted
  background level measured
  maximum instrument reading

 list ofid numbers of equipment in vacuum service

Maintain records in a readily accessible location.
                                    Not applicable.
                                                list ofid numbers of subject
                                               equipment

                                                list ofid numbers of equipment
                                               designated for no detectable
                                               emissions and signed by
                                               owner/operator

                                                lislofld numbers for pressure
                                               relief devices in gas/vapor service

                                                for each compliance test for
                                               components designated for no
                                               detectable emissions:

                                                 dates conducted
                                                 background level measured
                                                 maximum instrument reading

                                                list of id numbers of equipment in
                                               vacuum service

                                               Retain for 5 years; most recent 2
                                               years on-site or accessible from
                                               central location via computer; other
                                               3 years may be off-site.
                                                         list ofid numbers of subject equipment
                                                        (except certain connectors)

                                                         connectors do not need to be individually
                                                        identified if all connectors in a designated
                                                        area or length of pipe are identified as a
                                                        group and the number of connectors is
                                                        Identified

                                                         schedule by process unit for monitoring
                                                        connectors and valves

                                                         identification of equipment in HAP service
                                                        by tagging, identified on a plant site plan, in
                                                        log entries, or other methods

                                                         list of id numbers for equipment equipped
                                                        with a closed-vent system and control device

                                                         list ofid numbers of compressors and
                                                        pressure relief devices complying with an
                                                        instrument reading of less than 500 ppm
                                                        above background standard

                                                         id of surge control vessels or bottoms
                                                        receivers equipped with a closed-vent
                                                        system or control device

                                                         id of pressure relief devices equipped with
                                                        rupture disks

                                                         id of instrumentation systems (individual
                                                        components need not be identified)

                                                         id of screwed connectors complying with
                                                        §63,l?4(c)(2). Identification can be by
                                                        grouping or area.	

-------
SUMMARY OF REGULATION DIFFERENCES
page B-39
Recordkeeping
Requirements
All equipment ...
(concluded)
Unsafe- or Diffleult-to-
Monitor Valves
Unsafe-to- Monitor or
Repair, Inaccessible or
Glass-Lined
Connectors
Valves complying \vith
alternative standard for
skip-periods
Barrier fluid and seal
systems
REGULATION
40 CFR Part 60,
Subpart ODD
40 CFR Part 60,
Subpart GOG
40 CFR Part 60,
Subpart KKK


Not applicable.
Not applicable,
Not applicable.


40 CFR Part 60,
Subpart QQQ

Not applicable.
Not applicable.
Not applicable.
Not applicable.
40 CFR Part 63,
Subpart CC
(existing)

40 CFR Part 63,
Subpart CC
(existing or new)
list of valves and connectors removed from
or added to the process if net credits for the
removal or the valves or connectors are
expected to be used
documentation of the integrity of the weld
for removed connectors
if complying with §63.649, documentation
that all monitoring and inspections have
been conducted as required and document
repair of leaks as applicable.
Retain for 5 years; most recent 2 years on-
site or accessible from central location via
computer; other 3 years may be ofF-stte,

Not applicable.

list of id numbers
explanation for designation
planned schedule for monitoring
Not applicable.


-------
SUMMARY OF REGULATION DIFFERENCES
page B-40
Reeordkeeprng
Requirements
Exemptions
Determinations
Not "In service"
"In wet gas service"
REGULATION
40CFRPart60,
Subparl ODD
40epRP«60,
SubpartOOG
analysis dcmonslraiing facility design
capacity
analysis demonstrating thit equipment is
not in VOC service
40CPRParl60,
Subpsrt KKK
analysis
demonstrating
facility design
capacity
analysis
demonstrating that
equipment is not
in VOC service
analysis
demonstration that
a reciprocating
compressor is in
wet gas service
information and data used to demonstrate that a piece of
equipment is not in VOC service
Not applicable.
Not applicable.
information and
data used to
demonstrate that a
reciprocating
compressor is in
wet gas service
40CFRPart60,
SubpartQQQ
Not applicable.
Not applicable.
Not applicable,
40CFRPtrt63,
Subpart CC
(existing)
analysis demonstrating facility
design capacity
analysis demonstrating that
equipment is not in VHAP service
identification of equipment in
organic HAP service less than 300
hours per year
information and data used to
demonstrate that a piece of
equipment is not in organic HAP
service
Not applicable.
40CFRPwt63,
SubjJKlCC
(existing or new)
identification of equipment in organic HAP
service less than 300 hours per year
demonstration that compressor is not in
hydrogen service
information, data, and analysis used to
demonstrate that a piece of equipment or
process unit is in heavy liquid service
Not applicable.

-------
SUMMARY OF REGULATION DIFFERENCES
page B-41
Recordkeeping
Requirements
QIP








REGULATION
40 CFR Part 60,
Subpart DDD
Not applicable.








40 CFR Part 60,
. Subpart 000
Not applicable.








40 CFR Part 60,
Subpart KKK
Not applicable.








40 CFR Part 60,
Subpart QQQ
Not applicable.








40 CFR Part 63,
Subpart CC
(existing)
Not applicable.








40 CFR Part 63,
Subpart CC
(existing or new)
If leak not repaired within 15 calendar days
of discovery, reason for leak repair delay
and expected date of successful repair
Records of all analyses required under
§§63.175(e)and§63.I76(d):
areas associated with poorer than average
performance and the associated service
characteristics of the stream, the operating
conditions, and maintenance practices
the reasons for rejecting specific candidate
superior emission performing valve or pump
technology from performance trials «
the list of candidate superior emission
performing valve or pump technologies and
documentation of performance trial program
items
the beginning date and duration of
performance trials of each candidate
superior emission performing technology
Records documenting the quality assurance
program
Records indicating all valves or pumps
replaced or modified are in compliance with
the quality assurance requirements
Records documenting compliance with the
20 percent or greater annual replacement
rate for pumps
Information and data showing company has
less than 100 employees

-------
SUMMARY OF REGULATION DIFFERENCES
page B-42
Rccwdkeeping
Requirements
QIP - Reasonable
further progress





REGULATION
40 CFR Part 60,
Subptrt ODD
Not applicable.





40 CFR Part 60,
SubptrtGOO
Not applicable.





40 CFR Part 60,
Subpart KKK
Not applicable.





40 CPU Part 60,
Subpirt QQQ
Not applicable.





40 CFR Part 63,
Subpart CC
(existing)
Not applicable.





40 CFR Part 63,
Subpart CC
(existing or new)
for each valve in each process unit subject
to the QIP:
maximum instrument resding
observed in each monitoring
observation before repair,, the
response factor for the stream (if
appropriate), the instrument
model number, and the date of
the observation
whether the valve is in gas or
light liquid service
if a leak is delected, Ihe repair
methods used and the Instrument
readings after repair
percent leaking valves and rolling average
percent reduction each quarter
beginning and end dates while meeting the
requirements of the QIP

-------
SUMMARY OF REGULATION DIFFERENCES
page B-43
Recordkeepmg
• Requirements
QIP - Technology
review and
improvement










REGULATION
40 CFR Part 60,
Subpart ODD
Not applicable.











40 CFR Part 60,
Subpart 000
Not applicable.











40 CFR Part 60,
Subpart KKK
Not applicable.











40 CFR Part 60,
Subpart QQQ
Not applicable.











40 CFR Part 63,
Subpart CC
(existing)
Not applicable.











40 CFR Part 63,
Subpart CC
(existing or new)
For valves:
valve type and manufacturer, valve design,
materials of construction, packing material,
and year installed
service characteristics of the stream (e.g.,
operating pressure, temperature, line
diameter, corrosivity)
gas/vapor or light liquid service
if a leak is detected, the maximum
instrument reading observed before a repair,
response factor for stream if adjusted,
instrument model number, and date of
observation
repair methods used and the instrument
readings after the repair
a description of any maintenance or quality
assurance program used in the process unit
that are intended to improve performance
percent leaking valves
documentation of all inspections and
recommendations for design or specification
changes to reduce leak frequency
beginning and end date while meeting
requirements of the QIP

-------
SUMMARY OF REGULATION
pageB-44

Rccordkccping
Requirements


QIP- Technology
review and
improvcntcni
(concluded)
















No detectable
emissions

Enclosed Vented
Process Units




REOUI.AT10N

40CFRPart60,
Subptrt ODD

Not applicable.




















40CFRPart60,
Subpsit GOG

Not applicable.




















40CPRPart60,
Subpart KKK

Not applicable.




















40CFRPart60,
Subpart QQQ

Not applicable.




















40CFRPirt63,
Subpart CC
(existing)
Not applicable.



















background level

maximum instrument reading
Not annlicahle.





Not applicable.






4QCFRPart63»
Subpart CC
(existing or new)
For pumps:

type and manufacturer, seal type and
manufacturer, pump design, materials of
construction, barrier fluid or packing
material, and year installed
service characteristics of the stream:
discharge pressure, temperature, flow rate,
corrosivity, annual operating hours
maximum instrument readings observed
before repair, response factor for the stream,
instrument number, and date of observation
if a leak is detected, repair methods used
and the instrument readings after the repair
rolling average percent leaking pumps
documentation of all inspections and
recommendations for design or specification
changes to reduce leak frequency
beginning and end date while meeting
requirements of the QIP
Not applicable.


id of process units and organic HAP
handled
schematic of process unit, enclosure, and
closed-vent system
description of system used to create
negative pressure

-------
                                                       SUMMARY OF REGULATION DIFFERENCES
                                                                                                                                                    page B-45
 Reporting
Requirements
                                                                                          REGULATION
 40 CFR Part 60,
  Subpart ODD
40 CFR Part 60,
 Subpart GOG
40 CFR Part 60,
 Subpart KKK
40 CFR Part 60,
 Subpart QQQ
40 CFR Part 63,
  Subpart CC
   (existing)
40 CFR Part 63,
  Subpart CC
(existing or new)
   Initial Report
process unit identification

number of valves, pumps, and compressors, excluding those
designated for no detectable emissions
                                   Certification that initial
                                   inspection of closed-vent system
                                   and control device has been
                                   performed.
                                                 process unit identification

                                                 number of valves, pumps,
                                                 and compressors, excluding
                                                 those designated for no
                                                 detectable emissions
                                                    Initial Notification

                                                     name and address of owner/operator

                                                     address of facility (physical location)

                                                     identification of subject processes

                                                     eomplianee statement

                                                     statement of whether a source can achieve
                                                    compliance by the applicable compliance date

                                                    Notification of Compliance Status (for each subject
                                                    process unit)

                                                    A. For each subject unit:

                                                     process unit identification

                                                     number of each equipment type (except those in
                                                    vacuum service)

                                                     method of compliance

                                                     planned schedule for each phase

                                                     whether percent valves leaking will be calculated on
                                                    a process unit or source-wide basis

                                                     if performance test required, complete test report

                                                    B. Enclosed-vented Process Units

                                                     process unit identification

                                                     description of negative pressure system and control
                                                    device

-------
                                                         SUMMARY OF REGULATION
                                                                                                                                                          page B-46
                                                                                             REGULATION
  Reporting
Requirements
 40CFRPart60,
  Subpan ODD
4QCFRPart60,
 Subpwt GOO
40CFRPart60,
 SubpartKKK
40CFRPart<50,
 SubpartQQQ
40CFRPart(53,
  SubparlCC
   (existing)
40CFRPart63,
  Subptrt CC
(existing or new)
    Subsequent
   ScmiAnnual/
Periodic Reports
 process unit identification

Tlie following information by month in the reporting period:
                   number of valves, pumps, and compressors for which leaks
                  were detected
                   number of valves, pumps, and compressors for which leaks
                  were not repaired as required
                   the facts dial explain each delay of repair, and where
                  appropriate, why a process unit shutdown was technically
                  infeasible
                  Dates of process unit shutdowns that occurred within the
                  semiannual reporting period
                  Revisions to items reported in the initial semiannual report if
                  changes have occurred since the initial semiannual report or
                  subsequent revisions to the initial semiannual report
                                    Semi-annual certification that all
                                    required inspections have been
                                    carried out

                                    Initial and semi-annual reports
                                    that summarize all inspections
                                    that identify problems that could
                                    result in VOC emissions,
                                    including information about
                                    repairs and corrective action
                                    taken,

                                    Semi-annua! reports of each
                                    period ofexeeedanee for
                                    incinerators and carbon adsorbers.
                                                   process unit identification

                                                  The following information by
                                                  month in the reporting
                                                  period:

                                                   number of valves, pumps,
                                                  and compressors for which
                                                  leaks were detected

                                                   number of valves, pumps,
                                                  and compressors for which
                                                  leaks were not repaired as
                                                  required

                                                   the facts that explain each
                                                  delay of repair, and where
                                                  appropriate, why a process
                                                  unit shutdown was
                                                  technically infeasible

                                                  Dates of process unit
                                                  shutdowns that occurred
                                                  within the semiannual
                                                  reporting period

                                                  Revisions to items reported
                                                  in the initial semiannual
                                                  report if changes have
                                                  occurred since the initial
                                                  semiannual report or
                                                  subsequent revisions to the
                                                  initial semiannual report
                                                      Submit the following information semi-annually
                                                      starting 6 months atler the Notification of
                                                      Compliance:

                                                       the number of valves, pumps, compressors,
                                                      connectors, and screwed connectors for which leaks
                                                      were detected

                                                       the percent leakers for valves, pumps, connectors,
                                                      and screwed connectors

                                                       the total number of valves, pumps, connectors, and
                                                      screwed connectors monitored

                                                       the number of valves, pumps, compressors,
                                                      connectors, and screwed connectors for which leaks
                                                      were not repaired

                                                       identification of the number of valves and connectors
                                                      determined to be nonrepayable

                                                       explanation of why repairs delayed and why process
                                                      unit shutdown was infeasible

                                                       notification of change in connector monitoring
                                                      alternatives (if applicable)

                                                      For "no detectable emissions" components: all
                                                      monitoring to show compliance

                                                       initiation of monthly monitoring under phase HI or
                                                      QIP (if applicable)
         Other    Notification 90 days prior to election to comply with either
                  alternative standard for valves in gas/vapor service.
                  Report of all performance test in accordance with §60.8,
                                                         If flare used, initial performance
                                                         test within 60 days of initial
                                                         startup.
                                                                     Notification 90 days prior to
                                                                     complying with either
                                                                     alternative standard for
                                                                     valves in gas/vapor service.

                                                                     Report of all performance
                                                                     tests in accordance with
                                                                     §60.8.
                                                                               None specified.

-------
                                                             SUMMARY OF REGULATION DIFFERENCES
                                                                                                                                                        page B-4/
General Aspects of Rule
                                                                                                   REGULATION
                                40CFRPart61,
                                   Subpart F
                                             40 CFR Part 61,
                                               Subpart L
                                                 40CFRPart61,
                                                   Subpart FF
                                       40 CFR Part 264,
                                         Subpart CC
                                    40 CFR Part 265,
                                       Subpart CC
APPLICABILITY
Plants which produce:
- ethylene dichloride by reaction
of oxygen and hydrogen chloride
with ethylene
- vinyl chloride by any process
- one or more polymers
containing any fraction of
polymerized vinyl chloride.
At furnace and foundry coke by-product
recovery plants:
- tar decanters
- tar storage tanks
- tar-intercepting sumps
- flushing-liquor circulation tanks
- light-oil sumps
- light-oil condensers
- light-oil decanters
- wash-oil decanters
- wash-oil circulation tanks
- naphthalene processing
- final coolers
- final-cooler cooling towers
- equipment intended to operate in benzene
service

Also applies to benzene storage tanks, BTX
storage tanks, light-oil storage tanks, and
excess ammonia-liquor storage tanks at
furnace coke by-product recovery plants.
Owners/operators of chemical
manufacturing plants, coke by-
product recovery plants, and
petroleum refineries and the
owners/operators of hazardous
waste treatment, storage, and
disposal facilities that treat, store,
or dispose of hazardous waste
generated by these facilities.
Facilities that treat, store, or dispose of hazardous waste in
tanks, surface impoundments, or containers subject to either 40
CFR Part 264, Subpart I (Use and Management of Containers),
J (Tank Systems), or K (Surface Impoundments).

Containers:  > 0,1 cubic meters capacity
EXEMPTIONS
Equipment used in research and
development if the reactor used
to polymerize the vinyl chloride
processed in the equipment has a
capacity <0.19 mj (50 gal).
None specified.
The following waste is exempted:

- waste in the form of gases or
vapors that is emitted from
process fluids

- waste that is contained in a
segregated stormwater sewer
system
A waste management unit that holds hazardous waste placed in
the unit before June 5,  1995, and in which no hazardous waste is
added to the unit on or after June 5, 1995.

A container that has a design capacity <. 0.1 m5,

A tank or surface impoundment in which an owner/operator has
stopped adding hazardous waste and begun implementing or
completed closure pursuant to an approved closure plan.

A waste management unit used solely for on-site treatment or
storage of hazardous waste  that is generated as the result of
implementing remedial activities required under certain
corrective action RCRA, CERCLA, and other similar
authorities.

A waste management unit that is used solely for the management
of radioactive mixed waste  in accordance with all applicable
regulations under the authority of the Atomic Energy Act and Hie
Nuclear Waste Policy Act.	

-------
SUMMARY OF REGULATION
pageB-48
General Aspects of Rute
DEFINITIONS
"In gas/vapor service"
"In heavy liquid
service"
"In light liquid service"
"In liquid service"
"In VOC service"
"In VHAP service"
"In organic hazardous
air pollutant or in
organic (HAP) service"
"In benzene service"
REGULATION
40 CFR Part 61,
Subpart F
None specified.
None specified.
None specified.
None specified.
The piece of equipment contains
or contacts a process fluid that is
at least 10 percent VOC by
weight and the piece of
equipment is not in heavy liquid
service (as defined under 40 CFR
Part 60, subpart VV),
Not applicable.
None specified.
None specified.
40 CFR Part 61,
Subpart L
A piece of equipment contains process fluid
that is in the gaseous state at operating
conditions.
Not applicable.
Not applicable.
A piece of equipment is not in gas/vapor
service.
The piece of equipment contains or contacts
a process fluid that is at least 10 percent
VOC by weight and the piece of equipment
is not in heavy liquid service (as defined
under 40 CFR Part 60, subpart VV).
A piece of equipment either contains or
contacts a fluid (liquid or gas) that is at
least 10 percent by weight a volatile
hazardous air pollutant (VHAP).
Not applicable.
A piece of equipment, other than an
wXhsuster contains ~r contacts a fluid
(liquid or gas) that is at least 10% benzene
by weight.
Any exhauster that contains or contacts a
fluid (liquid or gas) that is at least 1 %
benzene by weight.
40 CFR Part 61,
Subpart FF
None specified.
None specified.
None specified.
None specified.
None specified.
None specified.
None specified.
None specified.
40 CFR Part 264.
Subpart CC
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
40 CFR Part 265,
Subpart CC
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.

-------
SUMMARY OF REGULATION DIFFERENCES
page B-49
General Aspects of Rule
DEFINITIONS
(concluded)
"In vinyl chloride
service"
"No detectable organic
emissions"
Equipment
Exhauster
Process Unit
Repaired
First Attempt at Repair
REGULATION
40CFRPart61,
Subpart F
A piece of equipment either
contains or contacts a liquid that
is at least 10 percent by weight
vinyl chloride or a gas that is at
least 10 percent by volume vinyl
chloride.
Not applicable.
None specified.
None specified.
None specified.
None specified.
None specified.
40GFRPart61,
Subpart L
Not applicable.
Not applicable.
Each pump, valve, exhauster, pressure
relief device, sampling connection system,
open-ended valve or line, and flange or
other connector in benzene service.
Fan located between the inlet gas flange
and outlet gas flange of the coke oven gas
line that provides motive power for coke
oven gases.
Equipment assembled to produce a VHAP
or its derivatives as intermediate or final
products, or equipment assembled to use a
VHAP in the production of a product. A
process unit can operate independently if
supplied with sufficient feed or raw
materials and sufficient product storage
facilities.
Equipment is adjusted, or otherwise .
altered, to eliminate a leak.
To take rapid action for the purpose of
stopping or reducing leakage of organic
material to the atmosphere using best
practices.
40CFRPart61,
Subpart FF
Not applicable.
Not applicable.
None specified.
None specified.
Equipment assembled and
connected by pipes or ducts to
produce intermediate or final
products. A process unit can be
operated independently if
supplied with sufficient fuel or
raw material and sufficient
product storage facilities.
None specified.
None specified.
40 CFR Part 264,
Subpart CC
Not applicable.
40 CFR Part 265,
Subpart CC
Not applicable.
No escape of organics from a device or system to the
atmosphere as determined by; (1) an instrument reading less
than 500 ppmv above the background level of each joint, fitting,
and seal and (2) by no visible openings or defects in the device
or system such as rips, tears, or gaps.
Not applicable,
Not applicable.
Not applicable.
None specified.
None specified.
Not applicable. *
Not applicable.
Not applicable.
None specified.
None specified.

-------
SUMMARY OF REGULATION
page B-50
General Aspects of Rule
EQUIPMENT
IDENTIFICATION (see
also Recordkceping
Requirements)
COMPLIANCE
DEMONSTRATIONS
METHOD OF
COMPLIANCE
DETERMINATION
REQUIREMENTS
WHEN MORE THAN
ONE STANDARD
APPLIES
REGULATION
40 CFR Part 61,
Subpart F
If complying with subpart V:
Marked in manner such that it
can be readily distinguished from
other pieces of equipment.
Not required for process units
with less than 2% leaking valves.
40 CFR Part 61,
Subpart L
Marked in manner such that it can be
readily distinguished from oilier pieces of
equipment in benzene service.
40 CFR Part 61,
Subpart FF
None specified.
For existing sources, shall be in compliance within 90 days after the effective date of the applicable standard,
For new sources, shall be in compliance upon effective date of the applicable standard.
Review of records, review of performance test results, and inspections.
A source subject to this subpart
that is also subject to 40 CFR
Part 60 only will be required to
comply with the provisions of
this subpart.
None specified.
None specified.
None specified.
40 CFR Pan 264,
Subpart CC
None specified.
None specified.
None specified.
None specified.
40CFRParl2fiS,
Subpart CC
None specified.
None specified.
None specified.
None specified.

-------
SUMMARY OF REGULATION
page B-51
Specific
Component
Summaries
REGULATION
40CFRPart61,
Subpart F
40CFRPart61,
Subpart L
40CFRPart61,
Subpart FF
40 CFR Part 264,
Subpart CC
40 CFR Part 265,
Subpart CC
PROCESS UNIT/PLANT AREA
Standards


Leak
Definition



Repair
Exemptions
Vinyl chloride (VC)
monitoring system capable of
detecting major leaks and
identification of the general
area of the plant where the
leak is located.
System to be operated
according to plan developed
by plant owner or operator.
Location and number of points
to be monitored and the
frequency of die monitoring
based on the number of pieces
of equipment in VC service
and the size and physical
layout of the plant,
Determined by plant owner or
operator.
Acceptable definition when
compared to background
concentrations of vinyl
chloride in the areas of the
plant to be monitored for
leaks.
Definition of a leak may vary
from area to area.
Is to change over time as
background concentrations are
reduced.
None specified, Plan is to
include action to be taken
when a leak is detected.
None specified.
Not applicable.


Not applicable.



Not applicable.
Not applicable.
Not applicable.


Not applicable.



Not applicable.
Not applicable.
Not applicable.


Not applicable.



Not applicable.
Not applicable.
Not applicable.

•f
Not applicable, •'



Not applicable.
Not applicable.

-------
SUMMARY OF REGULATION DIFFERENCES
page B-52
Specific
Component
Summaries
REGULATION
*
40 CFR Part 61,
Subpart F
40 CFR Part 61,
Subpart L
40 CFR Part 61,
Subpart FF
40 CFR Part 264,
Subpart CC
40 CFR Part 265,
Subpart CC
VALVES, GAS/VAPOR OR LIGHT LIQUID SERVICE
Standards
Leak
Definition
Repair
First Attempt
at Repair
Exemptions
If complying with subpart V,
40 CFR Part 61:
ADDS: Monthly monitoring
not required for process units
with less than 2% leaking
valves.









Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
ALTERNATIVE STANDARDS FOR VALVES
Allowable Percentage of Valves Leaking
Standard
Leak
Definition
Repair
First Attempt
at Repair




ADDS:
Notify Administrator in writing
when owner or operator elects to no
longer comply with alternative
standard.



Not applicable.
Not applicable.
Not applicable.
Not applicable,
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Skip Period Leak Detection and Repair
Standard


Not applicable.
Not applicable.
Not applicable.

-------
                                                         SUMMARY OF REGULATION DIFFERENCES
                                                                                                                                                      page B-53
   Specific
 Component
 Summaries
                                                                                        REGULATION
      40CFRPart61,
         Subpart F
40CFRPart61,
   Subpart L
40CFRPart61,
  Subpart FF
40 CFR Part 264,
   Subpart CC
40 CFR Part 265,
   Subpart CC
PUMPS, LIGHT LIQUID SERVICE
    Standards
ADDS:

Rotating Pumps

Minimize VC emissions by
installing sealless pumps,
pumps with double mechanical
seals or equivalent.  If double
mechanical seals are used,
minimize VC.emissions by
maintaining the pressure
between the two seals so that
any leak that occurs is into the
pump; by ducting any vinyl
chloride between the two seals
through a control system from
which the VC concentration  in
the exhaust gases does not
exceed 10 ppm; or equivalent.

Reciprocating Pumps

Minimize VC emissions by
installing double outboard
seals, or equivalent. If double
outboard seals are used,
minimize VC emissions by
maintaining the pressure
between the two seals so that
any leak that occurs is into the
pump; by ducting any vinyl
chloride between the two seals
through a control system from
which the VC concentration  in
the exhaust gases does not
exceed 10 ppm; or equivalent.
                         Not applicable.
                         Not applicable.
                         Not applicable.

-------
SUMMARY OF REGULATION
page B-54
Specific
Component
Summaries
REGULATION
40CFRPart6l,
Subpart F
40 CFR Part 61,
Subpart L
40 CFR Part 61,
Subpart FF
40 CFR Part 264,
Subpart CC
40 CFR Part 265,
Subpart CC
PUMPS, LIGHT LIQUID SERVICE (concluded)
Leak
Definition
Repair
First Attempt
at Repair
Exemptions


None specified.
None specified.


None specified.
Equipment in vacuum service.
Any pump equipped with a
compliant closed-vent system and
control device.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
PRESSURE RELIEF DEVICES, GAS/VAPOR SERVICE
Standards
Leak
Definition
Repair
Exemptions
ADDS:
Discharges: No discharge to
the atmosphere.



Emergency relief discharges
or relief valve discharges
ducted to control device
continually operating while the
emissions from the release are
present at the device.
"Emergency relief discharge"
means a discharge that could
not have been avoided by
taking measures to prevent the
discharge.
Pressure relief devices equipped
with compliant closed-vent system
and control device,
Equipment in vacuum service.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.

-------
SUMMARY OF REGULATION DIFFERENCES
page B-55
Specific
Component
Summaries
REGULATION
40CFRPart61,
Subpart F
40CFRPart61,
Subpart L
40CFRPart61,
Subpart FF
40 CFR Part 264,
Subpart CC
40 CFR Part 265,
Subpart CC
PRESSURE RELIEF DEVICES, LIGHT LIQUID OR HEAVY LIQUID SERVICE
Standards
Leak
Definition
Repair
Exemptions
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Monitoring of potential leaks within
5 calendar days of detection if
evidence of potential leak is found ,
by visual, audible, olfactory, or
other detection method.
10,000 ppm
Repair as soon as practicable, no
later than 15 calendar days after
detection.
First attempt within 5 calendar days
of detection.
Equipment in vacuum service.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.

-------
                                                          SUMMARY OF REGULATION
                                                                                                                                                         page B-56
   Specific
 Component
 Summaries
                                                                                           REGULATION
      40 CFR Part 61,
         SubjMrt F
        40 CFR Part 61,
           Subpart L
        40 CFR Pan 61,
          Subpart FF
        40 CFR Part 264.
          Subpart CC
          40 CFR Part 265,
            Subpart CC
COMPRESSORS
    Standards
Rotating Coropreaora

Minimize YC emissions by
installing compressors with
double mechanical seals or
equivalent. If double
mechanical seals are used,
minimize vinyl chloride
emissions by maintaining the
pressure between the two seals
so that any leak that occurs is
into the compressor; by
ducting any vinyl chloride
between the two seals through
a control system from which
the VC concentration in the
exhaust gases does not exceed
10 ppni; or equivalent,

Reciprocating .Pumps

Minimize VC emissions by
installing double outboard
seals, or equivalent. If double
outboard seals ate used,
minimize VC emissions by
maintaining the  pressure
between the two seals so that
any leak that occurs is into the
compressor: by  ducting any
vinyl chloride between the two
seals through a control system
from which the  VC
concentration in the exhaust
gases does  not exceed 10 ppm;
or equivalent.
Not applicable.
Not applicable.
Not applicable.
Not applicable.

-------
SUMMARY OF REGULATION DIFFERENCES
page B-57

Specific
Component
Summaries
REGULATION

40CFRPart61,
Subpart P
40 CFR Part 61,
Subpart L
40 CFR Part 61,
Subpart FF
40 CFR Part 264,
Subpart CC
40 CFR Part 265,
Subpart CC
COMPRESSORS (continued)
Standards
(concluded)

















Leak
Definition




Alternatively, comply with
subpart V, 40 CFR Part 61:
Equip with seal system that
includes a barrier fluid system
and that prevents leakage to
atmosphere.
Seal system shall meet certain
design and operation
requirements,
Install sensor to detect failure
of seal system, barrier fluid
system, or both.
Check sensor daily or equip
with audible alarm (unless
located at unmanned plant
site).
Establish criteria that indicates
failure of seal system, barrier
fluid system, or both.
If complying with subpart V,
40 CFR Part 61:
Sensor indicates failure of seal
system, barrier fluid system,
or both based on established
criteria.



















Not applicable.
























Not applicable.
























Not applicable.
























Not applicable.






-------
SUMMARY OF REGULATION
page B-58
Specific
Component
Summaries
REGULATION
40CFRPart61,
Subpart F
40 CFR Part 61,
Subpart L
40 CFR Part 61.
SubpanFF
40 CFR Part 264.
SubpartCC
40 CFR Part 265,
Subpart CC
COMPRESSORS (concluded)
Repir
Exemptions
If complying with subpart V,
40 CFR Part 61:
Repair as soon as practicable,
no later than IS calendar days
after detection,
First attempt within 5 calendar
days of detection.
None specified.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
SAMPLING CONNECTION SYSTEMS
Standards
Leak
Definition
Repair
Exemptions
ADDS;
Unused portions of samples
containing at least 10 percent
by weight VC are to be
returned to the process or
destroyed in a compliant
control device, Sampling
techniques are to be such that
samples containers in VC
service are purged into a
closed process system.
Not applicable.
Not applicable.


Not applicable.
Not applicable.

Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.

-------
SUMMARY OF REGULATION DIFFERENCES
page B-59
Specific
Component
Summaries
REGULATION
40CFRPart61,
Subpart F
40CFRPart61,
Subpart L
40CFRPart61,
Subpart FF
40 CFR Part 264,
Subpart CC
40 CFR Part 265,
Subpart CC
OPEN-ENDED VALVES OR LINES
Standards
Leak
Definition
Repair
Exemptions

Not applicable.
Not applicable.
OELs located on multiple
service process lines that
operate in VC service less
than 10 percent of the time,
provided they are addressed in
the process unit/plant area
monitoring system.
Exemption may be extended to
OELS demonstrated to require
significant retrofit cost to
comply with subpart V.

Not applicable.
Not applicable.
Equipment in vacuum service.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable,
Not applicable.
Not applicable.
Not applicable.
FLANGES AND OTHER CONNECTORS (ALL SERVICES)
Standards
Leak
Definition
Repair
Exemptions



ADDS;
Not required for process units
with less than 2% leaking
valves.




Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable,
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.

-------
SUMMARY OF REGULATION
page B-60
Specific
Component
Summaries
REGULATION
40 CFR Part 61,
Subpart F
40 CFR Par! 61,
Subpart L
40 CFR Part 61,
Subpart FF
40 CFR Part 264,
Subpart CC
40 CFR Pan 265.
Subjwrt CC
AGITATORS, GAS/VAPOR SERVICE OR LIGHT LIQUID SERVICE
Standards
Leak
Definition
Repairs
Exemptions
Minimize VC emissions by
installing agitators with double
mechanical seals, or
equivalent. If double
mechanical seals are used,
minimize VC emissions by
maintaining the pressure
between the two seals so that
any teak that occurs Is into the
agitated vessel; by ducting any
vinyl chloride between the two
seals through a control system
from which the VC
concentration in the exhaust
gases does not exceed 10 ppm;
or equivalent.
None specified.
None specified.
None specified.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
PRODUCT ACCUMULATOR VESSELS
Standards
Leak
Definition
Repair
Exemptions
Compliant closed-vent system
and control device.
Not applicable.
Not applicable.
Equipment in vacuum service.
Not required for process units
with less than 2% leaking
valves.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.

-------
                                                            SUMMARY OF REGULATION DIFFERENCES
                                                                                                                                                              page B-61
   Specific
 Component
 Summaries
                                                                                             REGULATION
      40CFRPart61,
         Subpart F
         40CFRPart61,
            Subpart L
         40CFRPart61,
           Subpart FF
        40 CFR Part 264,
           Subpart CC
40 CFR Part 265,
   Subpart CC
CLOSED VENT SYSTEMS AND CONTROL DEVICES
    Standards
Continually operating while
emissions from the release are
present.

Control Devices

Other than flares: limit VC
emissions to less than 10 ppm
(average over 3-hour period)

Flares:  Comply with §60,18.
Control devices and closed-vent
systems to be operated at all time
that emissions may be vented to
them,

Control Devices

Vapor recovery systems:  95
percent or greater recovery

Combustion devices: 95 percent or
greater reduction or minimum
residence time of 0.50 seconds and
minimum temperature of 760°C,

Flares: Comply with §60.18

Closed-Vent Systems (CVS)

No detectable emissions (less than
500. ppm above background) and no
visual indications.
Control devices and closed-vent
systems to be operated at all times
when waste is placed in the waste
management unit, except when
maintenance or repair cannot be
completed without a shutdown of the
control device.

Closed-Vent System (CVS)

No detectable emissions  (less than
500 ppmv above background).

All gauging and sampling devices
are to be gas-tight except when in
operation.

Control Devices

Enclosed  combustion device;
 reduce organic emissions by
>.95% by weight

 achieve  a total organic compound
concentration of 20 ppmv on a dry
basis corrected to 3% Oa

 minimum residence time of 0.5 sec
at minimum temperature of760°C

Boiler/Process Heater:

 introduce-vent stream into flame
zone
Operating at all times when gases, vapors, or fumes are vented from the waste
management unit through (he CVS to the control device.

Control Devices

Designed and operated to reduce total organic content of the inlet vapor stream
vented to the control device by at least 95%  by weight.

For carbon adsorbers, carbon replacement intervals specified [see §264.1033(g)
and (h)J.

Enclosed combustion devices: 95 percent or greater reduction; 20 ppmv total
organic compound concentration; or minimum residence  time of 0.50 seconds and
minimum temperature of 760°C,

Boilers and process heaters;  Introduce vent stream into flame combustion zone.

Flares: Flame present at all times, no visible emissions (except for periods not to
exceed a total of 5 minutes during any 2 consecutive hours), basic requirements
for heat content  and exit velocities.

An applicable control device other than a thermal vapor incinerator, flare, boiler,
process heater, condenser, or carbon adsorption system:  develop documentation
including sufficient information to describe the control device operation and
identify process  parameter(s) that indicate proper operation and maintenance of
the control device.

Closed-Vent System (CVS)

Designed for and operated with no detectable emissions.

Route gases, vapors, and fumes emitted from the hazardous waste to a control
device.

If the system contains one or more bypass devices that could be used to divert
gases, vapors, or ftimes from entering the control device, §264,1087(b)(3)
requirements apply.	

-------
                                                       SUMMARY OF REGULATION
                                                                                                                                            pagel-62
   Specific
 Component
 Summaries
                                                                                      REGULATION
4QCPRPart<5J,
   Subpart F
4QCFRPart61,
   Subpart L
4QCFRPirt611
  SubprtFF
4QCFRPart2«,
   Subpart CC
40 CFR Part 265,
   Subpari CC
CLOSED VENT SYSTEMS AND CONTROL DEVICES (continued)
    Standards
   (continued)
                                                      Vapor recovery system:

                                                       J>.95% (by weight) recovery or
                                                      control efficiency of the organic
                                                      emissions
                                                                           J>.98?5 (by weight) recovery or
                                                                          control efficiency of the benzene
                                                                          Piares;  Comply with §60,18

                                                                          Other Control Devices:
                                                                                 (by weight) recovery or
                                                                          control efficiency of the organic
                                                                          emissions
                                                                           2.98% (by weight) recovery or
                                                                          control efficiency of the benzene
                                                                          emissions

                                                                           develop test data and design
                                                                          information to document efficiency

                                                                           identify critical operating
                                                                          parameters, range of values of these
                                                                          parameters that ensure emission
                                                                          control ef&ienty aiiu iiuw ihese
                                                                          will be monitored

-------
SUMMARY OF REGULATION DIFFERENCES
page B-63
Specific
Component
Summaries
REGULATION
40 CFR Part 61,
Subpart F
40 CFR Part 61,
Subpart L
40 CFR Part 61,
Subpart FF
40 CFR Part 264, 40 CFR Part 265,
Subpart CC Subpart CC
CLOSED VENT SYSTEMS AND CONTROL DEVICES (concluded) _
Standards
(concluded)

Monitoring



Leak
Definition
Repair

Exemptions


Not applicable.



Not applicable.
Not applicable.

Not applicable.


Control Devices: Monitor to ensure
operated and maintained in
conformanee with their designs.
Closed-Vent Systems: Initially,
annually, and at other times as
requested by the Administrator.


Not applicable.
CVS and CDs:
visually inspect initially and
quarterly thereafter
include ductwork, piping, and
connections for evidence of visible
defects (e.g., holes, loose
connections)
Control Devices: Continuous
monitoring of operations
Closed-Vent Systems: Monitor
initially and at least once per year
thereafter.
If contains by-pass lines, (1) vent
stream flow indicators or (2) car-
seal or lock-and-key type of
configuration with monthly visual
inspection required.
Visually inspect flow monitoring
device at least once per operating
day.
Monitoring: 500 ppm
Visual: visible defects



Closed-Vent Systems (CVS): Initially, annually, and at other times as requested
by the Administrator.
If contains by-pass lines, (1) vent stream flow meters or (2) car-seal or iock-and-
key type of configuration with monthly visual inspection required.

CVS: detectable emissions ,>.500 above background
Repair as soon as practicable, but no later than 1 5 calendar days after detection.
First attempt to repair within 5 calendar days of detection.
Equipment in vacuum service.
None specified.
Not applicable. Not applicable.

-------
                                                          SUMMARY OF REGULATION
                                                                                                                                                        page B-64
   S'pecifrc
 Component
 Summaries
                                                                                          REGULATION
      40 CFR Part 61,
         Subpart F
        40CPRPart61.
           Subpart L
        40 CFR Part 61,
          Subparl FF
        40 CFR Part 264,
          SubpariCC
          40 CFR Pan 265,
            SubfwrtCC
PROCESS VESSELS, STORAGE TANKS, AND TAR-INTERCEPTING SUMPS
    Standards
Not applicable.
Option 1; Duct to a control device
designed and operated for no
detectable emissions as indicated by
an instrument reading of less than
500 ppmv above background and
visual inspections,

Monitor the connections and seals
on each control system to determine
if it is operating with no delectable
emissions,

Visually inspect each source,
including sealing materials, and the
ductwork of the control system for
evidence of visible defects (e,g.,
tears, gaps).

Conduct monitoring and visually
inspection semi-annuaily and at any
other time after the control system is
repressurized.

Option 2; install, operate, and
maintain a pressure relief device,
vacuum relief device, access hatch,
and sampling port. Equip each
hatch and sampling port with gasket
and cover, seal, or lid that is closed
at all times except when in use.

Use of sludge conveyors requires
operation of water leg seal  on tar
decanter roof to ensure enclosure of
the major portion of the liquid
surface not necessary of its
operation.
Not applicable.
Not applicable.
Not applicable.

-------
SUMMARY OF REGULATION DIFFERENCES
page B-65
Specific
Component
Summaries
REGULATION
40 CFR Part 61,
Subpart F
40CFRPart61,
Subpart L
40CFRPart61,
Subpart FF
40 CFR Part 264,
Subpart CC
40 CFR Part 265,
Subpart CC
PROCESS VESSELS, STORAGE TANKS, AND TAR-INTERCEPTING SUMPS (concluded)
Leak
Definition
Repair
Exemptions
Not applicable.
Not applicable.
Not applicable.
Monitoring: 500 ppmv above
background level,
Visual: Visible defects are
observed.
Repair as soon as practicable, but no
later than !5 calendar days after
detection.
First attempt to repair within 5
calendar days of detection.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.

-------
                                                          SUMMARY OF REGULATION
                                                                                                                                                         pge B-66
   Specific
 Component
 Summaries
                                                                                           REGULATION
      40CFRPart6l,
         SubprtF
        4QCFRPart61,
           SubpanL
        40 CFR Part 61,
           SubpartFF
        40 CPR Part 264.
          Subpart CC
          40 CPR Part 265,
             Subpart CC
LIGHT-OIL SUMPS
    Standards
Not applicable.
Option 1: Enclose and seal the
liquid surface in the sump to form a
closed system to contain the
emissions.

Option 2: Install, operate, and
maintain a vent on the light-oil sump
cover. Equip each vent pipe with a
water leg seal, a pressure relief
device, or vacuum relief device,

Option 3: Install, operate, and
maintain an access hatch on each
light-oil sump cover. Equip each
hatch with a gasket and a cover,
seal, or lid that is kept closed except
when in use.

Covets may be removed for
maintenance but must be replaced
with seal at completion of
maintenance.

If control equipment is used to
comply:

 monitor the connections and seals
on each control system to determine
if it is operating with no  detectable
emissions.

 visually inspect each source,
including sealing materials, for
evidence of visible defects (e.g.,
tears, gaps).

 conduct this monitoring and
inspection semiannually and at any
other time the cover is removed.
Not applicable.
Not applicable.
Not applicable.

-------
SUMMARY OF REGULATION DIFFERENCES
page B-67
Specific
Component
Summaries
REGULATION
40CFRPart61,
Subpart F
40CFRPart61,
Subpart L
40CFRPart61,
Subpart FF
40 CFR Part 264,
Subpart CC
40 CFR Part 265,
Subpart CC
LIGHT-OIL SUMPS (concluded)
Leak
Definition
Repair
Exemptions
Not applicable.
Not applicable.
Not applicable.
Monitoring: 500 ppmv above
background level.
Visual: Visible defects are
observed.
Repair as soon as practicable, but no
later than 15 calendar days after
detection.
First attempt to repair within 5
calendar days of detection.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.

-------
SUMMARY OF REGULATION DIFFERENCES
page B-68
Specific
Component
Summaries
REGULATION
40 CFR Part 61,
Subp«rtF
40CFRPart61,
SubpartL
40 CFR Part 61,
Subpart FF
40 CFR Part 264. 40 CFR Part 265,
Subptrt CC Subpari CC
TANKS
Standards



Leak
Definition
Repair
Exemptions


Not applicable.



Not applicable.
Not applicable.
Not applicable.


Not applicable.



Not applicable.
Not applicable.
Not applicable.


Oplion 1: Compliant fixed roof (see
Covets) and compliant closed-venl
system and control device.
Oplion 2: Compliant fixed roof
provided certain conditions arc met
including but not limited to the
following maximum organic vapor
pressure and size requirements:
Capacity Vapor pressure
(cubic meters') (kilopascals)
not specified 5,2
>75to<151 27.6
<75 76.6
Each fixed roof, seal, access door,
and other opening: inkial and
quarterly inspections for cracks and
gaps and that access doors and other
openings are closed and properly
gasketed.
Broken seal or gasket.
Detectable emissions measured.
As soon as practicable, but not later
than 45 calendar days after
identification.
Tanks with fixed roof and internal
floating roof meeting
§60.112b(a)(l).
External floating roofs that comply
with§60.112b(a)(2).
Alternative means of emission
limitation, (§60. 1Mb)
Pressure tanks; no detectable organic emissions
Non-pressure tanks:
Option I: Compliant cover and compliant closed-vent system and control
device,
Oplion 2: Compliant cover provided certain conditions are met including but not
limited to the following maximum organic vapor pressure and size requirements:
Capacity Vapor pressure
(cubic meters'! (kUopascals)
>151 5.2
>75to
-------
SUMMARY OF REGULATION
page B-69
Specific
Component
Summaries
REGULATION
40 CFR Part 61,
Subpart F
40 CFR Part 61,
Subpart L
40CFRPart61,
Subpart FF
40 CFR Part 264, 40 CFR Part 265,
Subpart CC Subpart CC
SURFACE IMPOUNDMENTS
Standards
Leak
Definition
Repair
Exemptions
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Compliant covers (see Covers) that
are vented to compliant closed-vent
system and control device.
Inspect initially and quarterly
thereafter for cracks or gaps.
Broken seal or gasket.
As soon as practicable, but not later
than 15 calendar days after
identification.
None specified.
Option 1 : Compliant covers that are vented to compliant closed-vent system and
control device.
Option 2: Floating membrane cover that meets certain requirements including
designed to operate with no detectable organic emissions.
(see Covers)
(see Covers)
A surface impoundment that meets all of the requirements identified in
§26S,lQ83(c) [§264.1082(c)] including but not limited to an average VO
concentration of the hazardous waste at the point of waste origination is <100
ppmw.
Surface impoundments used for biological treatment of hazardous waste in
accordance with §265.1083(e)(2)(iv) [§264.1082(c)(2)(lv)].

-------
SUMMARY OF REGULATION
page B-70
Specific
Component
Summaries
REGULATION
40CFRP«rt61,
Subpart F
M CFR Part 61,
Subpart L
40 CFR Part 61,
Subptt FF
0,46 cubic meters capacity:
use of conveyance system that uses a tube (or other means) to add waste to the
container and cover to remain in place and all container openinp to be in closed,
sealed position except for opening.
(see Covers)
(see Covers)

-------
SUMMARY OF REGULATION DIFFERENCES
page B-71
Specific
Component
Summaries
REGULATION
40CFRPart61,
Subpart F
40CFRPart61,
Subpart L
40CFRPart61,
Subpart FF
40 CFR Part 264,
Subpart CC
CONTAINERS (concluded)
Exemptions


Not applicable.


Not applicable.


Containers with fixed roof and
internal floating roof meeting
§60.U2b(a)(I).
External floating roofs that comply
with §60.1 12b(a)(2).
Alternative means of emission
limitation. (§60. 114b)
40 CFR Part 265,
Subpart CC

A container that meets all of the requirements identified in §265.1083(e)
[§264.1082{c)] including but not limited to an average VO concentration of the
hazardous waste at the point of waste origination is <100 ppmw.
Containers used for biological treatment of hazardous waste in accordance with
§265. i 083(c)(2)(iv) [§264. 1082(c)(2)(iv)].



-------
                                                             SUMMARY OF REGULATION
                                                                                                                                                                 page B-72
   Specific
 Component
 Summaries
                                                                                               REGULATION
      40CFRParl6I,
         SubpartF
         40CFRPart61,
            SubpartL
         40CFRPart61,
           SubpartFF
        40 CFR Part 264.
           Snbpart CC
40 CFR Part 265,
   Subpart CC
COVERS
    Standards
Nol applicable.
Not applicable.
Initial and subsequent annual
monitoring for no detectable organic
emissions from cover and all
openings.

Maintain each opening in closed,
sealed position at all times except
when necessary to use opening.
Initial and semiannual visual inspection and monitoring for no detectable organic
emissions from cover and cover openings when all cover openings are secured in
closed, sealed position.

"Unsafe-to-inspect" covers: written plan to inspect and monitor cover as •
frequently as practicable during times when a worker can safely access the cover.

"Difficult-to-inspect" covers: written plan and schedule to inspect and monitor at
least once per calendar year.
         Leak
    Definition
Not applicable.
Not applicable.
Detectable emissions,
                                                                                  Broken seal or gasket.
Seals around rotating shaft: 10,000 ppmv

All other seals and cover connections: detectable emissions (i.e., concentrations
greater than 500 ppmv plus background level).

Visual: a visible hole, gap, tear, or split in cover surface or cover opening.
   Monitoring
Not applicable.
Not applicable.
       Repair
Not applicable.
Not applicable.
As soon as practicable, but not later
than 15 (45 for tanks) calendar days
after identification.
First attempt to repair:  within 5 calendar days of detection.

Completed repair: within 15 calendar days of detection.

Delay of repair allowed under certain circumstances.
   Exemptions
Not applicable.
Not applicable.
None specified.
Tank with internal floating roof or external floating roof that is inspected and
monitored in accordance with §265.1091 (§264.1091).

Tank is buried partially or entirely underground -- only inspect or monitor portion
that is above ground and can be opened to the atmosphere.

Containers that meet all requirements specified in either §265.1087(b)(l)(ii) or
(iii) [§264.1086(b)(l)(ii) or (Hi)]

Semiannual inspection/monitoring exemptions:

 cover remained closed and sealed since last visual inspection and monitoring

 designated as unsafe to inspect and monitor

 designated as difficult to inspect and monitor if installed and placed in service
before December 6,1994      	

-------
SUMMARY OF REGULATION DIFFERENCES
page B-73
Specific
Component
Summaries
REGULATION
40 CFR Part 61,
Subpart F
40CFRPart61,
Subpart L
40CFR-Part61,
Subpart FF
40 CFR Part 264,
Subpart CC
40 CFR Part 265,
Subpart CC
EXHAUSTERS
Standards





Leak
Definition
Repair

Not applicable.





Not applicable.
Not applicable.

Option 1:
Monitor quarterly to detect leaks
Option 2:
Equip with seal system that includes
a barrier fluid system and that
prevents leakage to atmosphere.
Seal system shall meet certain
design and operation requirements.
Install sensor to detect failure of seal
system, barrier fluid system, or both.
Check sensor daily or equip with
audible alarm (unless located at
unmanned plant site).
Establish criteria that indicates
failure of seal system, barrier fluid
system, or both.
Option 1; 1 0,000 ppm
Option 2: Sensor indicates failure of
seal system, barrier fluid system, or
both based on established criteria,
Repair as soon as practicable, no
later than 15 calendar days after
detected.
A first attempt at repair shall be
made no later than 5 calendar days
after each leak is detected.
Not applicable.





Not applicable.
Not applicable.

Not applicable.





Not applicable.
Not applicable.

Not applicable.





Not applicable.
Not applicable.


-------
SUMMARY OF REGULATION DIFFERENCES
page B-74
Specific
Component
Summaries
REGULATION
40 CFR Pan 61,
Subparl F
40 CFR Pan 61,
Swbparl L
40 CFR Part 61,
SubpartPF
40 CFR Part 264,
Subpart CC
40CFRPirt26S,
Subpart CC
EXHAUSTERS (concluded)
Exemptions


Not applicable.


Equipment in vacuum service.
Exhausters equipped with compliant
closed-vent system and control
device.
Exhausters designed to operate with
an instrument reading less than 500
ppm above background.
Not applicable.


Not applicable.


Not applicable.



-------
SUMMARY OF REGULATION DIFFERENCES
page B-75

Delay of Sepair


General












Vaives
Pumps
REGULATION

40CFRPart61,
Subpart F
If complying with subpart V,
40CFRPart61:

Allowed if repair is technically
infeasible without a process
unit shutdown.

Repair to occur before end of
next process unit shutdown.
Allowed for equipment
isolated from the process and
that does not remain in VHAP
service.

40CFRPart61,
Subpart L



Allowed if repair is technically
infeasible without a process unit
shutdown.

Repair to occur before end of next
process unit shutdown.
Allowed for equipment isolated
from the process and that does not
remain in VHAP service.




40CFRPart61,
Subpart FF
Allowed if the repair is technically
impossible without a complete or
partial facility or unit shutdown.

Repair of such equipment shall
occur before the end of the next
facility or unit shutdown.






Not applicable.
Not applicable.

40 CFR Part 264,
Subpart CC

40 CFR Part 265,
Subpart CC
For tanks and surface impoundment covers:


Allowed beyond 15 days if repair requires first emptying contents and
temporary removal of tank or surface impoundment from service results
in unscheduled production stoppage of the source generating the
hazardous waste being managed



Repair to occur at next time source generating the hazardous waste being
managed stops operation for any




Not applicable.
Not applicable.
reason.




Not applicable.
Not applicable.

-------
SUMMARY OF REGULATION
pageB-76
Equivalence of (or
Alternative) Menus of
Emission Limitation:
General
Equipment, Design, and
Operational
Requirements








Work Practices






















Unique Approach
Manufacturers of
Equipment
REGULATION

40CPRPart61.
Subpart F
Upon written application from an
owner or operator, the
Administrator may approve use
of equipment or procedures that
have been demonstrated to his
satisfaction to be equivalent in
terms of reducing VC emissions
to the atmosphere to those
prescribed for compliance with a
specific paragraph of this
subpart.
Upon written application from an
owner or operator, the
Administrator may approve use
of equipment or procedures that
have been demonstrated to his
satisfaction to be equivalent in
terms of reducing VC emissions
to the atmosphere to those
prescribed for compliance with a
specific paragraph of this
subpart.












None specified.
None specified.

40CFRParl61,
Subpart L
The Administrator shall compre
test data for alternative means of
emission limitation to a benzene
control efficiency of 98% or 95%
for a tar decanters.






Owner/operator collect and verify
test data for alternative means of
emission limitation.

Owner/operator demonstrates
emission reduction achieved by
required work practice (for
minimum of 12 months).

Owner/operator demonstrates
emission reduction achieved by
alternative means of emission
limitation.
Owner/operator commits in
writing to work practices that
provide for emission reductions
equal to or greater than emission
reductions achieved by required
work practices.
Administrator compares
demonstrated emission reductions.
Administrator may condition
approval.
Not applicable.
Not applicable.

40CFRPart61,
Subpart FF
Any person can collect, verify.
and submit information showing
alternative means achieves
equivalent emission reductions.

Administrator makes findings.

Administrator may condition
approval.


Not applicable.






















Not applicable.
Not applicable.

40 CFR Part 264,
Subpart CC
Not applicable.










Not applicable.






















Not applicable.
Not applicable.

4QCFRPtrt26S,
Subpart CC
Not applicable.










Not applicable.






















Not applicable.
Not applicable.


-------
SUMMARY OF REGULATION DIFFERENCES
page B-77

Test Methods and
Procedures

Monitoring Method and
Technique

















Calibration





"No detectable
emissions" monitoring
REGULATION

40CFRPart61,
Subpart F
Process Unit/Plant Area;

Device that obtains
representative samples from
one or more applicable
emission points on a
continuous sequential basis.
Samples analyzed with gas
chromatography or, if all
hydrocarbons measures are
VC, with infrared
spectrography, flame ion
detection, or alternative
method.
Daily span check required
using VC concentration of 10
ppm or equivalent to
emission limit, as
appropriate.
Gas mixtures:
conform as specified in
sections 5.2.1 and 5.2,2 of
Test Method 106 and in
accordance with section 7.1
of Test Method 106

40CFRPart61,
Subpart L

40 CFR Part 61,
Subpart FF
Method 21 of 40 CFR Part 60, Appendix A


Instrument to meet performance criteria of Method 21
















Before use on each day of its use,
Calibration gases used:


















40 CFR Part 264, 40 CFR Part 265,
Subpart CC Subpart CC
Method 21 of 40 CFR Part 60, Appendix A


















the instrument shall be calibrated by procedures specified in Method 21


zero air (less than 10 ppm hydrocarbon in air)


mixture of methane or n-hexane and air at about, but less than, 10,000 ppm methane or n-hexane


-------
SUMMARY OF REGULATION
page B-78
Test Methods and
Procedures
Not "in service"
demonstration
Samples
Vapor pressures
VO concentration of
hazardous waste
Flare Compliance
REGULATION
40 CFR Part 61,
Subpart F
If comply ing with subpart V,
40 CFR Part 61:
Equipment is presumed to be
in VHAP service unless
demonstrated that the VHAP
content can never reasonably
expected to exceed 10
percent by weight.
If complying with subpart V,
40 CFR Part 61:
Representative of process
fluid that is contained in or
contacts the equipment or the
gas being combusted in flare.
None specified.
Not applicable.
40 CFR Part 61,
Subpart L
Equipment is presumed to be in
benzene service unless
demonstrated that the benzene
content can never reasonably
expected to exceed 10 percent
by weight.
Exhausters are presumed to be
in benzene service unless
demonstrated that the benzene
content can never reasonably
expected to exceed 1 percent by
weight.
Representative of process fluid
that is contained in or contacts
the equipment or the gas being
combusted in flare.
None specified.
Not applicable.
40 CFR Part 61,
Subpart FF
Not applicable.
Not applicable.
Not applicable.
Not applicable,
40CFRPtrl264.
Subpart CC
Not applicable.
40 CFR Part 265,
Subpart CC
Not applicable.
Collect at point of waste origination at least 4 discrete samples
Collect within 1-hour period
Collect in accordance with "Test Methods for Evaluating Solid Waste,
Chemical/Physical Methods," EPA SW-846, 3rd, edition, Sept. 1986,
Not applicable.
Not applicable.
Method 25D, 40 CFR Part 60, appendix A


-------
SUMMARY OF REGULATION DIFFERENCES
page B-79

Recordkeeping
Requirements

Consolidated
Rccordkeeping
When leak detected ...






















REGULATION

40 CFR Part 61,
Subpart Fa
Subpart F: None specified.

Subpart .P;

Process Unit/Plant Area:

concentration of VC measures,
analyzed, and recorded by the VC
detector

location of each measurement

date and approximate time of each
measurement
Method 21:

leaks detected

action taken to repair
location of leak

cause of leak
date and time leak detected
action taken to eliminate the leak
Retain records for at least 3 years

40CFRPart61,
Subpart L


(see next page)























40 CFR Part 61,
Subpart FF
Not applicable.

Record of each test of detectable
emissions;

date test performed

background level measured

maximum concentration

waste management unit

control equipment
leak interface location where
detectable emissions were measured

description of problem and the
corrective action taken
date the corrective action
completed





40 CFR Part 264, 40 CFR Part 265 ,
Subpart CC Subpart CC
None specified. None specified.

Date of attempt to repair

Repair method applied

Date of successful repair

Retain for 3 years

















-------
                                                             SUMMARY OF REGULATION DIFFERENCES
                                                                                                                                                        page B-80
    Reeordkeeping
     Requirements
                                                                                                   REGULATION
         40CFRPart61,
           Subpart F"
40CPRPart6l,
   Suhparl L
40CFRPart6i,
  Subpart FF
40 CFR Part 264,
   Subpart CC
40CFRPart2fi5,
   Subpart CC
Closed ?cni systems and
control devices
SubparlP:  None specified.

Subpart V...40 CPR.Part.6V;

 detailed schematics, design
specifications, and piping and
instrumentation diagrams

 dates and descriptions of any
changes in design specifications

 description of parameters) to be
monitored to ensure proper
operation and maintenance

 explanation of selection of
parameter(s)

 periods when not operated
according to design

 dates of startups and shutdowns of
control devices and closed-vent
systems

Keep these records in a readily
accessible location.
                                                            For control devices:

                                                             detailed schematics, design
                                                            specifications, and piping and
                                                            instrumentation diagrams

                                                             dates and descriptions of any
                                                            changes in design specifications

                                                             description of parameters) to be
                                                            monitored to ensure proper
                                                            operation and maintenance

                                                             explanation of selection of
                                                            parameters)

                                                             periods when not operated
                                                            according  to design

                                                             dates of startups and shutdowns of
                                                            control devices and closed-vent
                                                            systems

                                                            Keep these records in a readily
                                                            accessible location.
                          Certification that the closed-vent
                          system or control device is designed
                          to operate at the documented
                          performance level or highest load or
                          capacity expected to occur

                          For control devices:

                           engineering calculations used to
                          determine performance and a design
                          analysis that includes detailed
                          schematics, design specifications,
                          and piping and instrumentation
                          diagrams

                            performance tests, including
                          description of test procedures,
                          control device, sampling and
                          monitoring procedures, and all test
                          results

                            dates of startup and shutdown

                            description of parameter(s) to be
                          monitored to ensure proper
                          operation and maintenance

                            description of operating periods
                          when device is not in operation

                          For all thermal vapor and catalytic
                          vapor incinerators and for boilers
                          un£h <44 MW capacity!

                            temperature of the gas stream

                            exceedances
                           Signed certification of compliance of control device under
                           maximum operating conditions

                           Design analysis or performance test plan and test results

                           Description and date of each modification made to the closed-
                           vent system or control device design.

                           Identification of operating parameter, description of monitoring
                           device, and diagram of monitoring sensor Iocation(s) for the
                           following types of monitoring devices;  vent stream flow,
                           temperature,  heat sensing, organic concentration, regeneration
                           cycles for carbon beds, and good combustion practices,

                           Records of all Method 27 tests

                           Records of all visual inspections

                           Records of all monitoring for delectable oi^anic emissions

                           Records of management of carbon removed from carbon
                           adsorption  system

                           For compliance with §265.i083(c)(2)(vi) or (v)
                           t§264.1082(c)(2)(vi)or(v)]:

                            id number of incinerator, boiler, or industrial furnace

-------
                                                       SUMMARY OF REGULATION DIFFERENCES
                                                                                                                                  page B-81
    Recordkeeping
    Requirements
                                                                                          REGULATION
40 CFR Part 61,
   Subpart Fa
40CFRParf 61,
   Subpart L
40CFRPart61,
  Subparf FF
40 CFR Part 264,
   Subpart CC
40 CFR Part 265,
   Subpart CC
Closed vent systems and
control devices
(concluded)
                                                        For all boilers and process heater:

                                                         each occurrence when there is a
                                                        change in the location at which the
                                                        vent stream is introduced into the
                                                        flame zone

                                                         temperature of the gas stream

                                                        For boilers and process heaters with
                                                        _>44 MW capacity:

                                                         parameters) that indicates good
                                                        combustion operating practices are
                                                        being used

                                                        Flares:

                                                         continuous records of flare pilot
                                                        flame monitoring

                                                         all periods when pilot flame is
                                                        absent

                                                        Condensers:

                                                         organic or benzene concentration
                                                        or

                                                         temperature

                                                         exceedances

                                                        Carbon adsorbers:

                                                         organic or benzene concentrations

                                                         exceedances

-------
                                                            SUMMARY OF REGULATION
                                                                                                                                                     page B-82
    Rccordfcceping
     Requirements
                                                                                                 REGULATION
         40CFRPatt6l,
           Subpart F*
        4QCFRPwt61,
           SubpartL
         40CPRPart61,
           SubpjrtFF
    40 CFR Part 264.
       Subpart CC
40 CFR Part2S5,
   Subpart CC
Visual inspections
Not applicable.
Not applicable.
Maintain a record for each visual
inspection that identifies a problem
that could result in benzene
emissions.  Include date of
inspection, waste management unit
and control equipment location
inspected, description of problem,
corrective action taken, and date
corrective action was completed.
All visual inspections of covers
AH equipment...
SubpartP: None specified.

Subpart V. 40 CPR Part 61:

 list of id numbers of subject
equipment (except welded fittings)

 list of id numbers of equipment
designated for no detectable
emissions and signed by
owner/operator

 for each compliance test for
components designated for no
detectable emissions:

   dates conducted
   background level measured
   maximum instrument reading

 list of id numbers for  pressure
relief devices in gas/vapor service

 list of id numbers of equipment in
vacuum service

Maintain records for 2 years in a
readily accessible location.
                                                            list of id numbers of subject
                                                           equipment (except welded fittings)

                                                            list of id numbers of equipment
                                                           designated for no detectable
                                                           emissions and signed by
                                                           owner/operator

                                                            for each compliance test for
                                                           components designated for no
                                                           detectable emissions:

                                                              dates conducted
                                                              background level measured
                                                              maximum instrument reading

                                                            list of id numbers for pressure
                                                           relief devices in gas/vapor service

                                                            list of id numbers of equipment in
                                                           vacuum service

                                                           Maintain records for 2 years in a
                                                           readily accessible location. For
                                                           foundry coke by-product recovery
                                                           plant,  the annual coke production
                                                           (of furnace and foundry coke) shall
                                                           be recorded and maintained for 2
                                                           years following determination.
                                                                     Not applicable.
                                    for each compliance test for
                                  components designated for no
                                  detectable emissions:

                                     dates conducted
                                     background level measured
                                     maximum instrument reading
                                                              Not applicable.

-------
                                         SUMMARY OF REGULATION DIFFERENCES
page B-83
Recordkeeping
Requirements
Unsafe- or Difficult-to-
Monitor Valves (covers
for 264 and 265)
Valves complying with
alternative standard for
skip-periods
Barrier fluid and seal
systems
Exemptions
Determinations
Not "In service"
Tanks
Tanks, surface
impoundments,
containers
Alternative
Recordkeeping
REGULATION
40 CFR Part 61,
Subpart Fa
Subpart P: None specified.
Subpart g: None specified.
Subpart JP: None specified.
Subpart E: None specified.
Subpart F; None specified.
Not applicable.
Not applicable.
Not applicable,
40CFRPart61,
Subpart L





Not applicable.
Not applicable.
Not applicable.
40CFRPart6I,
Subpart FF
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable,
Not applicable.
Not applicable.
Not applicable.
40 CFR Part 264,
Subpart CC
40 CFR Part 265,
Subpart CC

Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
Not applicable.
§265.1085eor §264. 1084(c):
date and time each waste sample is collected
results of each determination for maximum organic vapor
pressure
tank dimensions and design capacity
No air emission controls:
information used for each waste determination
date, time, and location of each waste sample if results are
used
Owners/operators also subject to 40 CFR Part 60, subpart VV
or 40 CFR Part 61, subpart V may elect to demonstrate
compliance using the documentation required under said subpart
VV or subpart V to the extent that such documentation
duplicated the documentation required under 40 CFR Part 265
[264], subpart CC.
Subpart V, 40 CFR Part 61, recordkeeping requirements are not required for process units with less than 2% leaking valves. Other recordkeeping requirements required under subpart F are still applicable.

-------
                                                          SUMMARY OF REGULATION
                                                                                                                                                 pageB-84
Reporting Requirements
                                                                                               REGULATION
                              40 CFR Part 61,
                                 SubpartF*
                                     40 CPR Pan 61.
                                        SubptttL
      40 CFR Part 61,
         Subpart FF
          40 CFR Part 2«,
            SubpartCC
      40 CFR Part 265,
         SubprtCC
          Initial Report
Subparl F:

Equipment and procedural
specifications are being met.

Statement that contains the
following:

 list of equipment installed for
compliance

 description of the physical and
functional characteristics of
each piece of equipment

 description of the methods that
have been incorporated into the
standard operating procedures
for measuring or calculating the
emissions for which emission
limits have been  prescribed

 statement that each piece of
equipment is installed and that
each piece of equipment and
each procedure is being used

Subpart V. 40 CPR Part 61;

For each source:

 equipment id number

 process unit id

 type of equipment
                                                      For each source in benzene
                                                      service:

                                                       equipment id number

                                                       process unit id

                                                       type of equipment	
For subject facilities:

 regulatory status of each waste
stream

 total annual benzene quantity

 each benzene waste stream
and whether it will be
controlled for benzene

 for each benzene waste stream
not being controlled for benzene

 - whether water content is
                                                                                      —  type of waste stream
                                                                                      -  annual waste quantity
                                                                                      —  range of benzene
                                                                                     concentration
                                                                                      —  average benzene
                                                                                     concentration
                                                                                      —  annual benzene quantity
None specified.
None specified.

-------
                                                            SUMMARY OF REGULATION DIFFERENCES
                                                                                                                                                       page B-83
Reporting Requirements
                                                                                                  REGULATION
                               40CFRPart61,
                                  Subpart Fa
                                       40CFRPart61,
                                          Subpart L
                                        40CFRPart61,
                                          Subpart FF
                                          40 CFR Part 264,
                                            Subpart CC
                                              40 CFR Part 265,
                                                 Subpart CC
          Initial Report
           (concluded)
 percent weight VHAP

 process fluid state

 method of compliance

Reporting schedule for
submittal of subsequent
semiannual reports

An owner or operator is also
required to submit a statement
notifying the Administrator that
the requirements of this subpart
are being implemented.  For
existing sources and new
sources with an initial startup
date preceding the effective
date, this notification is to be
submitted within 90 days of the
effective date.  For new source
with an initial startup date after
the compliance date, this
notification is to be submitted
with the application for
approval of construction.	
  percent weight VHAP

  process fluid state

  method of compliance

 Reporting schedule for submittal
 of subsequent semiannual reports

 Submit statement that the
 requirements of this subpart and
 40 CFR Part 61, subpart V have
 been implemented. For existing
 sources and new sources with an
 initial startup date preceding the
 effective date,  submit within 90
 days of the effective date.  For
 new source with an initial startup
 date after the compliance date,
 submit with the application for
 approval of construction.
           Subsequent
   SemiAnnual/Periodie
              Reports
SubpartF:

Due March 15, June 15,
September 15, and December
15:

 VC content of emissions for
each 3-hour period during
which the average emissions are
in excess of the limits specified
for any control system to which
fugitive emissions are required
to be ducted
For sources subject to §61.132
and §61.133:

  brief description of any visible
defect in the source or ductwork

•  number of leaks

  number of leaks repaired

  brief description of any system
abnormalities
Facilities with > 10 Mg/yr
benzene waste:

Annual reports including but not
limited to;

 update of information
contained in initial report

 all inspections during which
detectable emissions are
measured or a problem (e.g.,
broken seal, gap) that could
result in benzene emissions is
identified
Exempted tanks, surface impoundments.
and containers:

 each occurrence when hazardous waste
is placed in unit in noncompliance with
§264,1082(c)(l)or(2)

Tanks complying with 8264.1084(c1:

 each occurrence of noncompliance

 submit within 15 calendar days of time
when become aware of noncompliance
None specified.

-------
                                                            SUMMARY OF REGULATION DIFFERENCES
                                                                                                                                                     page B-86
Repotting Requirements
                                                                                                  REGULATION
                               40CFRParl61,
                                 Subpart F8
                                      40CPRPart6I,
                                         Subpart L
       4QCPRPart6i,
         Subpart FF
          40 CFR Part 264,
             Subpart CC
40 CFR Part 265,
   Subjwirt CC
           Subsequent
   SemiAnnual/Periodic
              Reports
           (continued)
 the number of 3-hour periods
determined during the reporting
period

 if no excess emissions, a
statement to that effect

Subpart.V. JO CFR Part 61:

 process unit identification

The following information by
month in the reporting period;

 number of valves, pumps, and
compressors for which leaks
were delected

 number of valves, pumps, and
compressors for which leaks
were not repaired as required

 the facts that explain each
delay of repair, and where
appropriate, why a process unit
shutdown was technically
infeasible

Dates of process unit shutdowns
that occurred within the
semiannual reporting period

Revisions to items reported in
the initial semiannual report if
changes have occurred since the
initial semiannual report or
subsequent revisions to the
initial semiannual report
                                                       For equipment in benzene
                                                       service:

                                                        process unit identification

                                                       The following by month in the
                                                       reporting period;

                                                        number of valves, pumps, and
                                                       compressors for which leaks
                                                       were detected

                                                        number of valves, pumps, and
                                                       compressors for which leaks
                                                       were not repaired as required

                                                        the facts that explain each delay
                                                       of repair, and where appropriate,
                                                       why a process unit shutdown was
                                                       technically infeasible
                                                       Dates of process unit shutdowns
                                                       that occurred within the
                                                       semiannual reporting period

                                                       Revisions to items reported in the
                                                       initial semiannual report if
                                                       changes have occurred since the
                                                       initial semiannual report or
                                                       subsequent revisions to the initial
                                                       semiannual report.
 information on repair and
corrective action taken

Quarterly:

 all inspections required have
been carried out

 for control devices; periods
of exceedances
Contral Device

 semiannual report when noncompliance
has occurred

 each period of 24 hour or longer when
operating in noncompliance

 for flares; when operated with visible
emissions

 All reports to include:

 EPA id number

 facility name and address

 description of event and cause (not for
control devices)

 explanation why control device not
returned to compliance within 24 hours
(control devices only)

 dates of the noncompliance

 actions taken to correct noncompliance
and prevent reoccurrence

 signed and dated by authorized
representative

-------
                                                            SUMMARY OF REGULATION  DIFFERENCES
                                                                                                                       page B-87
Reporting Requirements
                                                                                                  REGULATION
                               40CFRPart61,
                                 Subpart F8
        40 CFR Part 61,
          Subpart L
40 CFR Part 61,
  Subpart FF
40 CFR Part 264,
   Subpart CC
40 CFR Part 265,
   Subpart CC
           Subsequent
    SemiAnnual/Period
              Reports
           (concluded)
For each exhauster for each
quarter in the semi-annual
period:

  number for which leaks were
detected

  number for which leaks were
repaired as required

  performance test results

Signed statement stating whether
all the provisions of this subpart
have been fulfilled
                Other
                        Within 10 days of any
                        discharge, submit report
                        containing information on the
                        source, nature and cause of the
                        discharge, the date and time of
                        the discharge, the approximate
                        total VC loss during the
                        discharge, the method used for
                        determining the loss, the action
                        taken to prevent the discharge,
                        and measures adopted to
                        prevent future discharges.

                        Subpart V. 40 CFR Part 61:

                        Notification 90 days prior to
                        complying with either
                        alternative standard for valves
                        in gas/vapor service.

                        Report of all performance test
                        and monitoring to determine
                        compliance with no detectable
                        emissions and with §63.243-1
                        and -2 conducted within the
                        semiannual reporting period.
                                If total annual benzene waste is
                                < 1 Mg/yr: updates whenever
                                changes occur that may increase
                                benzene waste to more than 1
                                Mg/yr

                                If total annual benzene waste is
                                1 to 10 Mg/yr, updates
                                whenever changes occur that
                                may increase benzene waste to
                                more than 10 Mg/yr

                                If total annual benzene waste is
                                > 10 Mg/yr, certification that
                                necessary equipment has been
                                installed and initial performance
                                tests have been carried out.
                        Not applicable.
                             Not applicable.
Notification 90 days prior to
complying with either alternative
standard for valves in gas/vapor
service (§63.243-1 and -2).

Report of all performance test
and monitoring to determine
compliance with no detectable
emissions and with conducted
within the semiannual reporting
period.	
                                                                    for nrocess units with less than 2% leaking valves. Other reporting requirements required under subpart F are still applicable.

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                                  APPENDIX C

        EQUIPMENT LEAK REGULATIONS; SUMMARY BY COMPONENT

                                                                            page
40 CFR PART 60, SUBPART DDD
Closed-Vent Systems and Control Devices	,	C-l
Compressors	C-3
Dual Mechanical Seal System	C-5
No Detectable Emissions	C-7
Open-Ended Valves or Lines		C-8
Pressure Relief Devices in Gas/Vapor Service	C-9
Pumps and Valves in Heavy Liquid Service, Pressure Relief Devices in Light
 Liquid or Heavy Liquid Service, and Flanges and Other Connectors	C-10
Pumps in Light Liquid Service	C-12
Sampling Connection Systems	C-14
Valves in Gas/Vapor and Light Liquid Service  	C-15

40 CFR PART 60, SUBPART GGG
Closed-Vent Systems and Control Devices  .	  C-17
Compressors	 ,	.'......  C-19
Dual Mechanical Seal System	, , .  C-21
No Detectable Emissions	C-23
Open-Ended Valves or Lines	C-24
Pressure Relief Devices in Gas/Vapor Service	C-25
Pumps and Valves in Heavy Liquid Service, Pressure Relief Devices in Light
 Liquid or Heavy Liquid Service, and Flanges and Other Connectors 	  C-26
Pumps in Light Liquid Service	 .  C-28
Sampling Connection Systems	C-30
Valves in Gas/Vapor and Light Liquid Service 	C-31

40 CFR PART 60, SUBPART KKK
Closed-Vent Systems and Control Devices  .	C-33
Compressors	C-35
Dual Mechanical Seal System	C-37
No Detectable Emissions	C-39
Open-Ended Valves or Lines	C-40
Pressure Relief Devices hi Gas/Vapor Service	  C-41
Pumps and Valves in Heavy Liquid Service, Pressure Relief Devices in Light
 Liquid or Heavy Liquid Service, and Flanges and Other Connectors	  C-43
Pumps in Light Liquid Service	  C-45
Valves in Gas/Vapor and Light Liquid Service	 .  C-47

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40 CFR PART 60, SUBPART QQQ
Closed-Vent Systems and Control Devices	C-49

40 CFR PART 63, SUBPART CC (existing sources)
Closed-Vent Systems and Control Devices	 C-52
Compressors	C-55
Dual Mechanical Seal System	C-57
No Detectable Emissions	C-59
Open-Ended Valves or Lines	C-60
Pressure Relief Devices in Gas/Vapor Service	C-61
Pumps and Valves in Heavy Liquid Service, Pressure Relief Devices in Light
 Liquid or Heavy Liquid Service, and Flanges and Other Connectors  	C-63
Pumps in Light Liquid Service	  ,	C-65
Sampling Connection Systems  	C-67
Valves in Gas/Vapor  and Light Liquid Service	C-68

40 CFR PART 63, SUBPART CC (existing or new sources)
All Connectors and Instrumentation Systems; Pumps, Valves, and Agitators
 in Heavy Liquid Service; and Pressure Relief Devices in Liquid Service	C-70
Alternative Means of Emission Limitations:  Enclosed-Vented Process Units	C-73
Closed-Vent Systems and Control Devices	C-74
Compressors	 C-77
Connectors	C-80
Dual Mechanical Seal System	'	C-83
Open-Ended Valves or Lines	C-85
Pressure Relief Devices in Gas/Vapor Service	C-87
Pumps in Light Liquid Service	C-89
Quality Improvement Program for Pumps in Light Liquid Service	C-92
Quality Improvement Program for Valves	C-94
Sampling Connection Systems	C-97
Valves in Gas/Vapor  and Light Liquid Service	 C-99

40 CFR PART 264 AND PART 265, SUBPARTS CC
Closed-Vent Systems and Control Devices	  C-102
Containers  .	  C-104
Covers		  C-106
Surface Impoundments	  C-109
Tanks	  C-lll

40 CFR PART 61 SUBPART F
Agitators	  C-113
Closed-Vent Systems and Control Devices	  C-115
Compressors  	  C-117
Dual Mechanical Seal System	  C-119
Flanges and Other Connectors	  C-121

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No Detectable Emissions	  C-123
Open-Ended Valves or Lines	  C-124
Pressure Relief Devices in Vinyl Chloride Service	  C-125
Process Units/Plant Areas	  C-128
Product Accumulator Vessels	  C-130
Pumps in Vinyl Chloride Service	  C-131
Sampling Connection Systems	  C-133
Valves in Vinyl Chloride Service	  C-135

40 CFR PART 61, SUBPART L
Closed-Vent Systems and Control Devices	  C-137
Dual Mechanical Seal System	  C-139
Exhausters .	  C-141
Light-Oil Sumps	  C-143
No Detectable Emissions	  C-145
Open-Ended Valves or Lines	  C-146
Pressure Relief Devices in Gas/Vapor Service	  C-147
Pressure Relief Devices in Liquid Services, Flanges and Other Connectors	  C-149
Process Vessels, Storage Tanks, and Tar-Intercepting Sumps	,	  C-151
Pumps in VHAP Service	  C-153
Sampling Connection Systems	  C-155
Valves in VHAP Service	  C-156

40 CFR PART 61, SUBPART FF
Closed-Vent Systems and Control Devices .	  C-158
Containers	  C-161
Covers	  C-164
Surface Impoundments	  C-166
Tanks	  C-168

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              CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                              APPLICABLE REGULATIONS
40 CFR Part 60
 Subpait DDD
40 CFR Part 60,
Subpart GGG

40 CFR Part 60,
Subpart KKK .

40 CFR Part 60,
Subpart QQQ

40 CFR Part 63,
Subpart CC
(existing)

40 CFR Part 63,
Subpart CC
(existing or new)

ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
REQUIREMENTS
Control Devices:
• vapor recovery systems: 95 percent or greater recovery
• combustion devices: 95 percent or greater reduction or minimum residence time of 0.75 seconds
and minimum temperature of 816°C
• flares: comply with §60.18
Closed- Vent Systems:
• no detectable emissions (less than 500 ppm above background)
• control devices and closed-vent systems to be operated at all times that emissions may be vented
to them
Monitoring:
• control devices: monitor to ensure operated and maintained in conformance with their designs
« closed-vent systems: initially, annually, and at other times as requested by the Administrator
Closed-vent system: 500 ppm or visible indications
N/A
Vapor collection or closed-vent systems operated under a vacuum
Unsafe or difficult to monitor portions of closed-vent systems require alternate inspection
plan
Hard piping construction: Method 21 for initial inspection, annual visual inspections
Duct work construction: Method 21 for initial and annual inspections
First attempt to repair within 5 calendar days of detection
Repair as soon as practicable; no later than 15 days after detection
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown
Allowed for equipment that is isolated from tiie process and that does not remain in VOC service
                       CLOSED-VENT SYSTEMS AND CONTROL DEVICES
page C-l

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                    CLOSED-VENT SYSTEMS AND CONTROL DEVICES

                                         APPLICABLE REGULATIONS
  40CFRPan60
  Subpart DDD
FR Part 60,
part GOG

40 CFR Part 60,
Subpart KKK

40 CFR Part 60,
Subpart QQQ

40 CFR Part 62,
Subpart CC
(existing)

40 CFR Pan 63,
Subpart CC
(existing or new)

     ITEM
                                    REQUIREMENTS
Recordkeeping
Requirements
When leak detected:
  «  a weather-proof and readily visible identification, marked with the equipment ID number,
    attached to the leaking equipment
  •  ID may be removed after it has been repaired

Information to be kept in log for 2 years after leak detected:
  •  instrument and operator ID number and equipment ID number
  •  date leak detected
  •  dates of each attempt to repair leak
  «  repair methods applied in each attempt to repair
  »  "above 10,000" if maximum instrument reading after each repair attempt is >_ 10,000 ppm
  •  "repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection
  •  signature of owner/operator whose decision it was that repair could not be effected without a
    process shutdown
  »  expected date of successful repair if leak is not repaired with the 15 days
  •  dates of process unit shutdown that occurred while the equipment is unrepaired
  »  date of successful repair of the leak

When no leak detected:  records that instrument or visual inspection was conducted, date of
inspection, and.statement that no leaks were detected

Information to be kept for  all closed-vent systems and control devices:
  •  detailed schematics, design specifications, and piping and instrumentation diagrams
  •  dates and descriptions of any changes in design specifications
  «  description of parameters) to be monitored to ensure proper operation and maintenance
  *  explanation of selected parameter(s)
  •  periods of non-operation according to design
  •  dates of startups and shutdown
  •  list of ID numbers of subject closed-vent systems and control devices
  »  list of ID numbers of closed-vent systems and control devices designated for no detectable
    emissions and signed by owner/operator
  •  for each compliance test for closed-vent systems and control devices designated for no detectable
    emissions
    «•  date conducted
    • •  background level measured
    • •  maximum instrument reading
  •  list of ID numbers for closed-vent systems and control devices  in vacuum service
Reporting
Requirements
Initial semiannual report:
  •  process unit identification

Subsequent semiannual reports:
  •  process unit identification
  •  dates of process unit shutdowns that occurred within the semiannual reporting period
  «  revisions to items reported in the initial semiannual report if changes have occurred since the
    initial semiannual report or subsequent revisions to the initial semiannual report
  •  report of all performance tests  in accordance with §60.8
                               CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                                                                                    page C-2

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                                   COMPRESSORS
                                 APPLICABLE REGULATIONS
40 CFR Part 60
 Subpart DD0
40 CFR Part 60,
Subpart GGG

40 CFR Part 60,
Subpart KKK

40 CFR Part 60,
Subpart QQQ

40 CFR Part 63,
Subpart CC
(existing)

40 CFR Part 63,
Subpart CC
(existing or new)

ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
Recordkeeping
Requirements
REQUIREMENTS
Equipped with compliant seal system that prevents leakage to atmosphere
Install sensor to detect failure of seal system
Check sensor daily or equip with audible alarm
Establish criteria basic standard that indicates failure of seal system or barrier fluid system or both
Sensor indicates failure of sea! or barrier fluid system or both based on established
criteria.
Equivalent means of emission limitation
No detectable emissions, operate less than 500 ppm above background
Closed-vent system and control device
Equipment in vacuum service
Reciprocating compressors that meet certain criteria
Sensor alarm or visual check
First attempt within 5 calendar days of detection
Repair as soon as practicable; no later than 15 calendar days after detection
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in VOC service
When leak detected:
• a weather-proof and readily visible identification, marked with the equipment
attached to the leaking equipment
• ID may be removed after it has been repaired
(Continued on next page)
ID number,
                                      COMPRESSORS
                                                                                   page C-3

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                                             COMPRESSORS

                                          APPLICABLE REGULATIONS
  40CFRPiirt60
   Sotpait DDD
40 CFR Part 60,
  Subpart GGG
40 CFR Part 60,
 Subpart KKK
40 CFR Part 60,
 Subpart QQQ
40 CFR Part 63,
  Subpart CC
   (existing)
40 CFR Part 63,
  Subpart CC
(existing or new)
      ITEM
                                     REQUIREMENTS
Recordkeeping
Requirements
(continued)
Information to be kept in log for 2 years after leak detected:
  •  instrument and operator ID number and equipment ID number
  •  date leak detected
  •  dates of each attempt to repair leak
  •  repair methods applied in each attempt to repair
  »  "above 10,000" if maximum instrument reading after each repair attempt: is _>. 10,000 ppm
 , •  "repair delayed" and reason for delay is leak not repaired within 15 calendar days after detection
  •  signature of owner/operator whose decision it was that repair could not be effected without a
    process shutdown
  •  expected  date of successful repair if leak is not repaired with the 15 days
  •  dates of process unit shutdown that occurred while the equipment is unrepaired
  •  date of successful repair of the leak

Information to be kept for all compressors:
  •  list of ID numbers of subject compressors
  •  list of ID numbers of compressors designated for no detectable emissions and signed by
    owner/operator
  •  for each compliance test for compressors designated for no detectable emissions
    • • date conducted
    • • background level measured
    • • maximum instrument reading
  •      list of ID numbers for compressors in vacuum service
Reporting
Requirements
Initial semiannual report:
 •  process unit identification
 •  number of compressors, excluding those designated for no detectable emissions

Subsequent semiannual reports:
 •  The following information by month in the reporting period:
    • •  process unit identification
    • •  number of compressors for which leaks were detected
    • •  number of compressors for which leaks were not repaired within 15 days after detection
    • •  the facts that explain each delay of repair, and where appropriate, why a process unit
        shutdown was technically infeasible
 •  Dates of process unit shutdowns that occurred within the semiannual reporting period
 »  Revisions to items reported in the initial semiannual report if changes have occurred since the
    initial semiannual report or subsequent revisions to the initial semiannual report
 •  Report of all performance tests in accordance with §60.8.
                                                COMPRESSORS
                                                                                     page C-4

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                         DUAL MECHANICAL SEAL SYSTEM
                                   APPLICABLE REGULATIONS
40 CFR Part 60
 Subpart DDD
40 CFR Part 60,
 Subpart GOG
40 CFR Part 60,
 Subpart KKK
40 CFR Part 60,
 Subpart QQQ
40 CFR Part 63,
  Subpart CC
  (existing)
40 CFR Part 63,
  Subpart CC
(existing or new)
ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
REQUIREMENTS
For each dual mechanical seal system:
• operate the barrier fluid at a pressure that is at all times greater than the pump stuffing box
pressure, or
» connect the barrier fluid degassing reservoir by a closed-vent system to a control device, or
• equip with a system that purges the barrier fluid into a process stream with zero VHAP
emissions to the atmosphere
For all dual mechanical seal systems:
• the barrier fluid system shall be in heavy liquid service or not in VOC service
« equip each barrier fluid system with a sensor
• • check each sensor daily or equip with audible alarm
• • determine criterion that indicates failure of the seal system, the barrier fluid system, or both
» perform weekly visual inspections for indications of liquids dripping from the pump seals
Indications of liquids dripping from the pump seal; sensor
Applies as an alternative standard to: Pumps in Light Liquid Service
N/A
Visual, sensor
First attempt within 5 calendar days of detection
Repair as soon as practicable; no later than 15 days after detection
If repair requires use of a DMS that includes a barrier fluid system and repair is completed as soon as
practicable but no later than 6 months after leak detected
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in VOC service
                                DUAL MECHANICAL SEAL SYSTEM
                                                                          page C-5

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                              DUAL MECHANICAL SEAL SYSTEM

                                          APPLICABLE REGULATIONS
  40 CFR Part 60
  Subpatt DDD
40 CFR Pan 60,
 Subpart GGG
40 CFR Pan 60,
 Subpart KKK
40 CFR Pan 60,
 Subpan QQQ
40 CFR Pan 63,
  Subpan CC
   (existing)
40 CFR Pan 63,
  Subpan CC
(existing or new)
     ITEM
                                    REQUIREMENTS
Recordkeeping
Requirements
Information to be kept in log for 2 years after leak detected:
 «  instrument and operator ID number and equipment ID number
 «  date leak detected
 »  dates of each attempt to repair leak
 »  repair methods applied in each attempt to repair
 «  "above 10,000" if maximum instrument reading after each repair attempt is .>_ 10,000 ppm
 «  "repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection
 •  signature of owner/operator whose decision it was that repair could not be effected without a
    process shutdown
 •  expected date of successful repair if leak is not repaired within the 15 days
 «  dates of process unit shutdown that occurred while the equipment is unrepaired
 «  date of successful repair of the leak

Information to be kept for all dual mechanical seal systems:
 •  list of ID numbers of pumps with dual mechanical seal  systems
 •  list of DD numbers designated for no detectable emissions and signed by owner/operator
Reporting
Requirements
Initial semiannual report:
 •  process unit identification

Subsequent semiannual reports:
 •  the following information by month in the reporting period:
    • •  process unit identification
    • •  the facts that explain each delay of repair, and where appropriate, why a process unit
        shutdown was technically infeasible
 •  dates of process unit shutdowns that occurred within the semiannual reporting period
 «  revisions to items reported in the initial semiannual report if changes have occurred since the
    initial semiannual report or subsequent revisions to the initial semiannual report
 •  report of all performance tests in accordance with §60.8
                                      DUAL MECHANICAL SEAL SYSTEM
                                                                                    page C-6

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                         NO DETECTABLE EMISSIONS
                              APPLICABLE REGULATIONS
40 CFR Part 60
 Subpart ODD
40 CFR Part 60,
Subpart GOG

40 CFR Part 60,
Subpart KKK

40 CFR Part 60,
Subpart QQQ

40 CFR Part 63,
Subpart CC
(existing)

40 CFR Part 63,
Subpart CC
(existing or new)

ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
Recordkeeping
Requirements
Reporting
Requirements
REQUIREMENTS
An instrument reading of less than 500 ppm above background as measured by the methods specified
in §60.485
Demonstrate compliance initially upon designation and test annually
500 ppm
Applies as an alternate standard to:
• pumps in light liquid service (must have no externally actuated shaft penetrating the pump
housing)
• valves in gas/vapor service or in light liquid service (must have no external actuating mechanism
in contact with the process fluid)
Applies as regulated standard for:
• closed vent systems
• pressure relief devices in gas/vapor service
N/A
Method 21
N/A
N/A
Information to be kept:
* list of ID numbers of equipment designated for no detectable emission and signed by
owner/operator
» for each compliance test for no detectable emission
• • date conducted
* • background level measured
» « maximum instrument reading
Subsequent semiannual reports:
« dates of process unit shutdowns that occurred within the semi-annual reporting period
• revisions to items reported in the initial semiannual report if changes have occurred since the
initial semiannual report or subsequent revisions to the initial semiannual report
• report of all performance tests in accordance with §60.8
                              NO DETECTABLE EMISSIONS
                                                                              page C-7

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                      OPEN-ENDED VALVES OR LINES
                             APPLICABLE REGULATIONS
40CFRP*rt60
 Subput DDD
40 CFR Part 60,
Subpart GGQ

40 CFR Part 60,
Subpart KKK

40 CFR Part 60,
Subpart QQQ

40 CFR Part 63,
Subpart CC
(existing)

40 CFR Part 63,
Subpart CC
(existing or new)

ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
Recordkeeping
Requirements
Reporting
Requirements
REQUIREMENTS
Use cap, blind flange, plug, or second valve to seal open end at all times except when operations
require flow through open end
Second valve - close valve on process fluid end prior to closing second valve
Double block and bleed system may remain open during operations but comply with basic standard at
all other times
N/A
N/A
Equipment in vacuum service
N/A
N/A
N/A
Information to be kept for all open-ended valves or lines
» list of ID number of subject open-ended valves or lines
Initial semiannual report:
« process unit identification
Subsequent semiannual reports:
• process unit ID
* revisions to items reported in the initial semiannual report if changes have occurred since the
initial semiannual report or subsequent revisions to the initial semiannual report
                           OPEN-ENDED VALVES OR LINES
page C-8

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PRESSURE RELIEF DEVICES IN GAS/VAPOR SERVICE
                  APPLICABLE REGULATIONS
40CFRPart60
Subpart ODD
ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
Recordkeeping
Requirements
Reporting
Requirements
40CFRPait60, 4QCFRPart60, 40CFRPart60, 40CFRPart63,
Subpart GGG Subpart KKK Subpart QQQ Subpart CC
(existing)


40 CFR Part 63,
Subpart CC
(existing or new)


REQUIREMENTS
No detectable emissions (less than 500 ppm above background)
After each release return to no detectable emissions within 5 calendar days as indicated by monitoring
of the pressure relief device
500 ppm
Equivalent means of emission limitation
Pressure relief device equipment with compliant closed-vent system and control device
Equipment in vacuum service
Method 21
N/A
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in VOC service
Information to be kept for all pressure relief devices:
» list of ID numbers of pressure relief devices required to comply
• « for each compliance test for pressure relief devices designated for no detectable emissions
* • dates conducted
« « background level measured
* • maximum instrument reading
• list of ED numbers for pressure relief devices in vacuum service
Initial semiannual report:
• process unit ID for pressure relief devices
Subsequent semiannual reports:
• process unit identification
• the facts that explain each delay of repair, and where appropriate, why a process unit shutdown
was technically infeasible
« dates of process unit shutdowns that occurred within the semiannual reporting period
• revisions to items reported in the initial semiannual report if changes have occurred since the
initial semiannual report or subsequent revisions to the initial semiannual report
» report of all performance tests in accordance with §60.8.
         PRESSURE RELIEF DEVICES IN GAS/VAPOR SERVICE
page C-9

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            PUMPS AND VALVES IN HEAVY LIQUID SERVICE, PRESSURE
                RELIEF DEVICES IN LIGHT LIQUID OR HEAVY LIQUID
                 SERVICE, AND FLANGES AND OTHER CONNECTORS
                                      APPLICABLE REGULATIONS
 40 CFR Part 60
  Subput ODD
 40 CFR Part 60,
  Snbpart GOG
40 CFR Pan 60,
 Subpart KKK
40 CFR Part 60,
 Subpart QQQ
40 CFR Part 63,
  Subpart CC
   (existing)
40 CFR Part 63,
  Subpart CC
(existing or new)
     ITEM
                                  REQUIREMENTS
Basic Standard
Monitoring of potential leaks within 5 calendar days of detection if evidence of potential leak is found
by visual, audible, olfactory, or other detection method
Leak Definition
 10,000 ppm
Alternative
Standards
Equivalent means of emission limitation
Exemptions
Equipment in vacuum service
Monitoring
Method
Method 21
Repair
Requirements
 First attempt within 5 calendar days of detection

 Repair as soon as practicable; no later than 15 days after detection
Delay of Repair
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown

Allowed for equipment that is isolated from the process and that does not remain in VOC service.
Recordkeeping
Requirements
 When leak detected:
  » a weather-proof and readily visible identification, marked with the equipment ID number,
    attached to the leaking equipment
  • ID may be removed after it has been repaired

 Information to be kept in log for 2 years after leak detected:
  • instrument and operator ID number and equipment ID number
  * date leak detected
  • dates of each attempt to repair leak
  « repair methods applied in each attempt to repair
  • "above 10,000" if maximum instrument reading after each repair attempt is ,>. 10,000 ppm
  • "repair delayed" and reason for delay  if leak not repaired within 15 calendar days after detection
  « signature of owner/operator whose decision it was that repair could not be affected without a
    process shutdown
  • expected date of successful repair if leak is not repaired within 15 days
  « dates of process unit shutdown that occurred while the equipment is unrepaired
  « date of successful repair of the leak

	(Continued on next page)	
             PUMPS AND VALVES IN HEAVY LIQUID SERVICE, PRESSURE RELIEF DEVICES IN LIGHT
                 LIQUID OR HEAVY LIQUID SERVICE, AND FLANGES AND OTHER CONNECTORS
                                                                              page C-10

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           PUMPS AND VALVES IN HEAVY LIQUID SERVICE, PRESSURE
                RELIEF DEVICES IN LIGHT LIQUID OR HEAVY LIQUID
                SERVICE, AND FLANGES AND OTHER CONNECTORS
                                     APPLICABLE REGULATIONS
 40 CFR Pait 60
  Snbpait DDD
40 CFR Part 60,
 Subpart OGO
40 CFR Part 60,
 Subpan KKK
40 CFR Part 60,
 Subpart QQQ
40 CFR Part 63,
  Subpart CC
   (existing)
40 CFR Pan 63,
  Subpart CC
(existing or new)
     ITEM
                                 REQUIREMENTS
Reeordkeeping
Requirements
(continued)
Information to be kept for ill equipment in these categories:
 *  list of ID numbers of subject equipment in these categories
 •  list of ID numbers for equipment in vacuum service
Reporting
Requirements
Initial semiannual report:
 • process unit identification

Subsequent semiannual reports:
 « process unit identification
 « the following information by month in the reporting period
   • • number of pumps and valves for which leaks were detected
   * • number of pumps and valves for which leaks were not repaired within 15 calendar days
   • • the facts that explain each delay of repair, and where appropriate, why a process unit
       shutdown  was technically infeasible
 « dates of process unit shutdowns that occurred within the semiannual reporting period
 » revisions to items reported in the initial semiannual report if changes have occurred since the
   initial semiannual report or subsequent revisions to the initial semiannual report
 * report of all performance tests in accordance with §60.8
             PUMPS AND VALVES IN HEAVY LIQUID SERVICE, PRESSURE RELIEF DEVICES IN LIGHT
                LIQUID OR HEAVY LIQUID SERVICE, AND FLANGES AND OTHER CONNECTORS          page C-l 1

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PUMPS IN LIGHT LIQUID SERVICE




        APPLICABLE REGULATIONS
40CFRP«t60
Subpart ODD
^mm
HEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
Recordkecping
Requirements
40CFRPait60, 40CFRPart60, 40CFRPart60, 40CFR
Subpart OGG SubpattKKK Subpart QQQ Subpa
(exis


Part 63, 40CFRPart63,
it CC Subpart CC
ting) (existing or new)


REQUIREMENTS
Monthly leak detection and repair
Weekly visual observation for leaks
10,000 ppm
Indications of liquids dripping from pump seal
Equivalent means of emission limitation
Dual mechanical seal pumps (see Dual Mechanical Seals)
No detectable emissions (see No Detectable Emissions)
Closed-vent system and control device (see Closed-vent Systems and Control Devices)
Pumps in vacuum service
Liquids dripping from bleed ports in existing pumps
Method 21; no more the 1 cm from rotating shaft
First attempt within 5 calendar days of detection
Repair as soon as practicable; no later than 15 days after detection
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown.
Allowed for equipment that is isolated from the process and that does not remain in VOC service
Allowed if repair requires use of a DMS that includes a barrier fluid system and repair is completed
as soon as practicable but not later than 6 months after leak detected
When leak detected:
» a weather-proof and readily visible identification, marked with the equipment ID number,
attached to the leaking equipment
* ID may be removed after it has been repaired
(Continued on next page)
      PUMPS IN LIGHT LIQUID SERVICE
page C-12

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                               PUMPS IN LIGHT LIQUID SERVICE
                                          APPLICABLE REGULATIONS
 4QCFRPart60
  Subpart DDD
40eERPart60,
Subpart GOG

40 CFR Part 60,
Subpart KKK

40CERPart60,
Subpart QQQ

40 CFR Part 63,
Subpart CC
(existing)

40 CJFR Part 63,
Subpart CC
(existing or new)

     ITEM
                                     REQUIREMENTS
Recordkeeping
Requirements
(continued)
Information to be kept in log for 2 years after leak detected:
 •  instrument and operator ID number and equipment ID number
 •  date leak detected
 •  dates of each attempt to repair leak
 •  repair methods applied in each attempt to repair
 •  "above 10,000" if maximum instrument reading after each repair attempt is > 10,000 ppm
 •  "repair delayed" and reason for delay is leak not repaired within 15 calendar days after detection
 »  signature of owner/operator whose decision it was that repair could not be effected without a
    process shutdown
 »  expected date of successful repair if leak is not repaired with the 15 days
 •  dates of process unit shutdown that occurred while the equipment is unrepaired
 •  date of successful repair of the leak

Information to be kept for all pumps:
 •  list of ID numbers of subject pumps
 •  list of ID numbers of pumps designated for no detectable emissions and signed by
    owner/operator
 •  for each compliance test for pumps designated for no detectable emissions
    « • date conducted
    • • background  level measured
    • • maximum instrument reading

Information and data used to demonstrate that a pump is not in VOC service
Reporting
Requirements
Initial semiannual report:
  •  process unit identification
  •  number of pumps, excluding those designated for no detectable emissions

Subsequent semiannual reports:
  •  The following information by month in the reporting period:
    • •  process unit identification
    » »  number of pumps for which leaks were detected
    • •  number of pumps for which leaks were not repaired within 15 days after detection
    » •  the facts that explain each delay of repair, and where appropriate, why a process unit
        shutdown was technically infeasible
  •  Dates of process unit shutdowns that occurred within the semiannual reporting period
  •  Revisions to items reported in the initial semiannual report if changes have occurred since the
    initial semiannual report or subsequent revisions to the initial semiannual report
  •  Report of all performance tests in accordance with  §60.8.
                                       PUMPS IN LIGHT LIQUID SERVICE
                                                                                    page C-13

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                     SAMPLING CONNECTION SYSTEMS
                              APPLICABLE REGULATIONS
40 CFR Pan 60
 Subpart DDD
FR Part 60,
span GGG

40 CFR Part 60,
SubpartKKK

40 CFR Part 60,
Subpart QQQ

40 CFR Part 63,
Subpart CC
(existing)

40 CFR Part 63,
Subpart CC
(existing or new)

ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
Reeordkeeping
Requirements
Reporting
Requirements
REQUIREMENTS
Equipped with closed-purged, closed-loop, or closed-vent system that: returns the fluid to the
process, or recycles the purged fluid to a process, or sends it to a complaint control device
N/A
N/A
Equipment in vacuum service; in-situ sampling systems; and sampling systems without purges.
N/A
N/A
N/A
Information to be kept for all sampling connections
« list of ID numbers of subject sampling connection systems
Initial semiannual report:
» process unit identification
Subsequent semiannual reports:
» process unit ED
• revisions to items reported in the initial semiannual report if changes have occurred since the
initial semiannual report or subsequent revisions to the initial semiannual report
                            SAMPLING CONNECTION SYSTEMS
page C-14

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VALVES IN GAS/VAPOR AND LIGHT LIQUID SERVICE
                 APPLICABLE REGULATIONS
40 CFR Part 60
Subpart DDD
ITEM
Basic Standard


Leak Definition
Alternative
Standards



Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair



40 CFR Part 60, 40 CFR Part 60,
Subpart GGG Subpart KKK


40 CFR Part 60, 40 CFR
Subpart QQQ Subpa
(exis


Part 63, 40 CFR Part 63,
it CC Subpart CC
ting) (existing or new)


REQUIREMENTS
Monthly leak detection and repair


If valve does not leak for 2 months, may be monitored quarterly
If valve leaks, monitor monthly until no leak is detected for 2 consecutive months
10,000 ppm

Equivalent means of emission limitati
No detectable emissions
m



Valves designated unsafe to monitor or difficult to monitor
Allowable percentage of valves leaking
Valves in vacuum service
Method 21
First attempt within 5 calendar days of detection
Repair as soon as practicable; no later than 15 days after detection
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in VOC service
Allowed if emissions of purged material from immediate repair would exceed fugitive emissions from
delay of repair, and purged materials are collected and destroyed or recovered ia a control device
when repair occurs
Allowed beyond process unit shutdown if otherwise sufficient supply of valve assembly replacements
are exhausted
         VALVES IN GAS/VAPOR AND LIGHT LIQUID SERVICE
page C-15

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                  VALVES IN GAS/VAPOR AND LIGHT LIQUID SERVICE
                                          APPLICABLE REGULATIONS
  40 CFR Pan 60
  Subpan ODD
40 CFR Part 60,
 Subpart GOG
40 CFR Part 60,
 Subpart KKK
40 CFR Part 60,
 Subpart QQQ
40 CFR Part 63,
  Subpart CC
   (existing)
40 CFR Part 63,
  Subpart CC
(existing or new)
      ITEM
                                    REQUIREMENTS
Recordkeeping
Requirements
When leak detected:
  «  a weather-proof and readily visible identification, marked with the equipment ID number,
    attached to the leaking equipment
  »  ID may be removed after it has been repaired and monitored for 2 months with no leaks

Information to be kept in log for 2 years after leak detected:
  *  instrument and operator ID number and equipment ID number
  •  date leak detected
  •  dates of each attempt to repair leak
  •  repair methods applied in each attempt to repair
  •  "above 10,000" if maximum instrument reading after each repair attempt is _>_ 10,000 ppm
  *  "repair delayed" and reason for delay is leak not repaired within 15 calendar days after detection
  «  signature of owner/operator whose decision it was that repair could not be effected without a
    process shutdown
  •  expected date of successful repair if leak is not repaired with the 15 days
  «  dates of process unit shutdown that occurred while the equipment is unrepaired
  •  date of successful repair of the leak

Information to be kept for  all valves:
  «  list of ID numbers of subject valves
  •  list of ID numbers of valves designated for no detectable emissions and signed'by owner/operator
  »  for each compliance test for valves designated for no detectable emissions
    • •  date conducted
    • •  background level measured
    • •  maximum instrument reading
  «  list of ID numbers for valves in vacuum service

Information and data used  to demonstrate that a valve is not in VOC service
Reporting
Requirements
Initial semiannual report:
  •  process unit identification
  «  number of valves, excluding those designated for no detectable emissions

Subsequent semiannual reports:
  «  process unit identification

  «  the following information by month in the reporting period:
    • •  number of valves for which leaks were detected
    • •  number of valves for which leaks were not repaired within 15 days after detection
    * •  the facts that explain each delay of repair, and where appropriate, why a process unit
        shutdown  was technically infeasible
  *  dates of process unit shutdowns that occurred within the semiannual reporting period
  •  revisions to items reported in the initial semiannual report if changes have occurred since the
    initial semiannual report or subsequent revisions to the initial semiannual report
  *  report of all performance tests in accordance with alternative standards
                              VALVES IN GAS/VAPOR AND LIGHT LIQUID SERVICE
                                                                                   page C-16

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               CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                                APPLICABLE REGULATIONS
40 CFR Part 60
 Subpart DDD
40 CFR Part 60,
 Subpart GGG
0 CFR Pan 60,
Subpart KKK

40 CFR Part 60,
Subpart QQQ

40 CFR Pan 63,
Subpart CC
(existing)

40 CFR Part 63,
Subpart CC
(existing or new)

ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
REQUIREMENTS
Control Devices:
• vapor recovery systems: 95 percent or greater recovery
• combustion devices: 95 percent or greater reduction or minimum residence time of 0.75 seconds
and minimum temperature of 816°C
» flares: comply with §60.18
Closed- Vent Systems:
• no detectable emissions (less than 500 ppm above background)
* control devices and closed-vent systems to be operated at all times that emissions may be vented
to them
Monitoring:
• control devices: monitor to ensure operated and maintained in conformance with their designs
» closed-vent systems: initially, annually, and at other times as requested by the Administrator
Closed-vent system: 500 ppm or visible indications
N/A
Vapor collection or closed-vent systems operated under a vacuum
Unsafe or difficult to monitor portions of closed-vent systems require alternate inspection plan
Hard piping construction: Method 21 for initial inspection, annual visual inspections
Duct work construction: Method 21 for initial and annual inspections
First attempt to repair within 5 calendar days of detection
Repair as soon as practicable; no later than 15 days after detection
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in VOC service
                        CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                                                                   page C-17

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                     CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                                          APPLICABLE REGULATIONS
  40 CFR Part 60
   Subpart DDD
40 CFR Part 60,
  Subpart GOG
40 CFR Pan 60,
 Subpart KKK
40 CFR Part 60,
 Subpart QQQ
40 CFR Part 63,
  Subpart CC
   (existing)
40 CFR Part 63,
  Subpart CC
(existing or new)
      ITEM
                                     REQUIREMENTS
Recordkeeping
Requirements
When leak detected:
  *  a weather-proof and readily visible identification, marked with the equipment ID number,
    attached to the leaking equipment
  •  ID may be removed after it has been repaired

Information to be kept in log for 2 years after leak detected:
  »  instrument and operator ID number and equipment ID number
  •  date leak detected
  «  dates of each attempt to repair  leak
  »  repair methods applied in each attempt to repair
  •  "above 10,000" if maximum instrument reading after each repair attempt is >_ 10,000 ppm
  *  "repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection
  *  signature of owner/operator whose decision it was that repair could not be effected without a
    process shutdown
  •  expected  date of successful repair if leak is not repaired with the 15 days
  •  dates of process unit shutdown that occurred while the equipment is unrepaired
  «  date of successful repair of the leak

When no leak detected:  records that instrument or visual inspection was conducted, date of
inspection, and statement that no leaks were detected

Information to be kept for all closed-vent systems and control devices:
  •  detailed schematics, design specifications, and piping and instrumentation diagrams
  •  dates and descriptions of any changes in design specifications
  »  description of parameter(s) to be monitored to ensure proper operation and maintenance
  »  explanation of selected parameter(s)
  •  periods of non-operation according to design
  •  dates of startups and shutdown
  •  list of ID numbers of subject closed-vent systems and control devices
  »  list of ID numbers of closed-vent systems and control devices designated for no detectable
    emissions and signed by owner/operator
  *  for each compliance test for closed-vent systems and control devices designated for no detectable
    emissions
    • •  date conducted
    • •  background level measured
    • •  maximum instrument reading
  »  list of DD numbers for closed-vent systems and control devices in vacuum service
Reporting
Requirements
Initial semiannual report:
 •  process unit identification

Subsequent semiannual reports:
 «  process unit identification
 »  dates of process unit shutdowns that occurred within the semiannual reporting period
 •  revisions to items reported in the initial semiannual report if changes have occurred since the
    initial semiannual report or subsequent revisions to the initial semiannual report
 •  report of all performance tests in accordance with §60.8
                                CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                                                                                   page C-18

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                                    COMPRESSORS
                                  APPLICABLE REGULATIONS
40 CFR Part 60
 Subpart DDD
40 CFR Part 60,
 Subpart GGG
0 CFR Part 60,
Subpart KKK

40 CFR Part 60,
Subpart QQQ

40 CFR Part 63,
Subpart CC
(existing)

40 CFR Part 63,
Subpart CC
(existing or new)

ITEM
Basic Standard
Leak Definition

Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
Recordkeeping
Requirements
REQUIREMENTS
Equipped with compliant seal system that prevents leakage to atmosphere
Install sensor to detect failure of seal system
Check sensor daily or equip with audible alarm
Establish criteria basic standard that indicates failure of seal system or barrier fluid system or both
Sensor indicates failure of seal or barrier fluid system or both based on established criteria.

Equivalent means of emission limitation
No detectable emissions, operate less than 500 ppm above background
Closed-vent system and control device
Equipment in vacuum service
Reciprocating compressors that meet certain criteria
Compressors in hydrogen service
Sensor alarm or visual check
First attempt within 5 calendar days of detection
Repair as soon as practicable; no later than 15 calendar days after detection
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in VOC service
When leak detected:
• a weather-proof and readily visible identification, marked with the equipment ID number,
attached to the leaking equipment
• ID may be removed after it has been repaired
(Continued on next page)
                                       COMPRESSORS
                                                                      page C-19

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                                             COMPRESSORS
                                          APPLICABLE REGULATIONS
  -WCFRPaneO
  Subpart DDD
40 CFR Part 60,
 Subpart GGG
SO CFR Part 60,
SubpaitKKK

40 CFR Part 60,
Subpart QQQ

40 CFR Part 63,
Subpart CC
(existing)

40 CFR Part 63,
Subpart CC
(existing or new)

     ITEM
                                     REQUIREMENTS
Recordkeeping      Information to be kept in log for 2 years after leak detected:
Requirements         • instrument and operator ID number and equipment ID number
(continued)           • date leak detected
                     » dates of each attempt to repair leak
                     • repair methods applied in each attempt to repair
                     « "above 10,000" if maximum instrument reading after each repair attempt is >_ 10,000 ppm
                     • "repair delayed" and reason for delay is leak not repaired within 15 calendar days after detection
                     • signature of owner/operator whose decision it was that repair could not be effected without a
                       process shutdown
                     » expected date of successful repair if leak is not repaired with the 15 days
                     • dates of process unit shutdown that occurred while the equipment is unrepaired
                     * date of successful repair of the leak

                   Information to be kept for all compressors:
                     * list of ID numbers of subject compressors
                     • list of ID numbers of compressors designated for no detectable emissions and signed by
                       owner/operator
                     « for each compliance test for compressors designated for no detectable emissions
                       * «  date conducted
                       » •  background level measured
                       » •  maximum instrument reading
                     • list of ID numbers for compressors in vacuum service
Reporting          Initial semiannual report:
Requirements         • process unit identification
                     » number of compressors, excluding those designated for no detectable emissions

                   Subsequent semiannual reports:
                     « The following information by month in the reporting period:
                       » • process unit identification
                       • • number of compressors for which leaks were detected
                       • • number of compressors for which leaks were not repaired within 15 days after detection
                       * • the facts that explain each delay of repair, and where appropriate, why a process unit
                           shutdown was technically infeasible
                     » Dates of process unit shutdowns that occurred within the semiannual reporting period
                     * Revisions to items reported in the initial  semiannual report if changes have occurred since the
                       initial semiannual report or subsequent revisions to the initial semiannual report
                     « Report of all performance tests in accordance with §60,8.
                                                COMPRESSORS
                                                                                    page C-20

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                         DUAL MECHANICAL SEAL SYSTEM
                                  APPLICABLE REGULATIONS
40 CFR Part 60
 Subpart DDD
40 CFR Part 60,
 Subpart GGG
40CERPart60,
 Subpart KKK
40 CER Part 60,
 Subpart QQQ
40 CFR Part 63,
  Subpart CC
  (existing)
40 CFR Part 63,
  Subpart CC
(existing or new)
ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
REQUIREMENTS
For each dual mechanical seal system:
» operate the barrier fluid at a pressure that is at all times greater than the pump stuffing box
pressure, or
• connect the barrier fluid degassing reservoir by a closed-vent system to a control device, or
• equip with a system that purges the barrier fluid into a process stream with zero VHAP
emissions to the atmosphere
For all dual mechanical seal systems:
« the barrier fluid system shall be in heavy liquid service or not in VOC service
• equip each barrier fluid system with a sensor
• • check each sensor daily or equip with audible alarm
• • determine criterion that indicates failure of the seal system, the barrier fluid system, or both
» perform weekly visual inspections for indications of liquids dripping from the pump seals
Indications of liquids dripping from the pump seal; sensor
Applies as an alternative standard to: Pumps in Light Liquid Service
N/A
Visual, sensor
First attempt within 5 calendar days of detection
Repair as soon as practicable; no later than 15 days after detection
If repair requires use of a DMS that includes a barrier fluid system and repair is completed as soon as
practicable but no later than 6 months after leak detected
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in VOC service
                                DUAL MECHANICAL SEAL SYSTEM
                                                                        page C-21

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                              DUAL MECHANICAL SEAL SYSTEM
                                          APPLICABLE REGULATIONS
  40 CFR Part 60
   Subpart DDD
40 CFR Pan 60,
 Subpart GGG
40 CFR Part 60,
 Subpart KKK
40 CFR Part 60,
 Subpart QQQ
40 CFR Part 63,
  Subpart CC
   (existing)
40 CFR Part 63,
  Subpart CC
(existing or new)
      ITEM
                                     REQUIREMENTS
Recordkeeping
Requirements
Information to be kept in log for 2 years after leak detected:
  «  instrument and operator ID number and equipment ID number
  «  date leak detected
  «  dates of each attempt to repair leak
  »  repair methods applied in each attempt to repair
  •  "above 10,000" if maximum instrument reading after each repair attempt is „>, 10,000 ppm
  »  "repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection
  •  signature of owner/operator whose decision it was that repair could not be effected without a
    process shutdown
  »  expected date of successful repair if leak is not repaired within the 15 days
  »  dates of process unit shutdown that occurred while the equipment is unrepaired
  »  date of successful repair of the leak

Information to be kept for all dual mechanical seal systems:
  •  list of DD numbers of pumps with dual mechanical seal systems
  •  list of ID numbers designated for no detectable emissions and signed by owner/operator
Reporting
Requirements
Initial semiannual report:
  •  process unit identification

Subsequent semiannual reports:
  •  the following information by month in the reporting period:
    • • process unit identification
    • • the facts that explain each delay of repair, and where appropriate, why a process unit
        shutdown was technically infeasible
  •  dates of process unit shutdowns that occurred within the semiannual repjrting period
  »  revisions to items reported in the initial semiannual report if changes have occurred since the
    initial semiannual report or subsequent revisions to the initial semiannual report
  •  report of all performance tests in accordance with §60.8
                                      DUAL MECHANICAL SEAL SYSTEM
                                                                                   page C-22

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                            NO DETECTABLE EMISSIONS
                                   APPLICABLE REGULATIONS
40 CFR Part 60
 Subpart DDD
40 CFR Part 60,
 Subpart GOG
40 CFR Part 60,
 Subpart KKK
40 CFR Part 60,
 Subpart QQQ
40 CFR Part 63,
  Subpart CC
  (existing)
40 CFR Part 63,
  Subpart CC
(existing or new)
ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
Recordkeeping
Requirements
Reporting
Requirements
REQUIREMENTS
An instrument reading of less than 500 ppm above background as measured by the methods
in §60.485(c)
Demonstrate compliance initially upon designation and test annually
specified
500 ppm
Applies as an alternate standard to:
• pumps in light liquid service (must have no externally actuated shaft penetrating the pump
housing)
• valves in gas/vapor service or in light liquid service (must have no external actuating mechanism
in contact with the process fluid)
Applies as regulated standard for:
» closed vent systems
• pressure relief devices in gas/vapor service
N/A
Method 21
N/A
N/A
Information to be kept:
* list of ID numbers of equipment designated for no detectable emission and signed by
owner/operator
» for each compliance test for no detectable emission
• • date conducted
• • background level measured
• • maximum instrument reading
Subsequent semiannual reports:
• dates of process unit shutdowns that occurred within the semi-annual reporting period
• revisions to items reported in the initial semiannual report if changes have occurred since the
initial semiannual report or subsequent revisions to the initial semiannual report
« report of all performance tests in accordance with §60,8
                                  NO DETECTABLE EMISSIONS
                                                                       page C-23

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                          OPEN-ENDED VALVES OR LINES
                                 APPLICABLE REGULATIONS
40 CFR Part 60
 Subpart ODD
40 CFR Part 60,
 Subpart GGG
40 CFR Part 60,
 Subpart KKK
40 CFR Part 60,
 Subpart QQQ
40 CFR Part 63,
  Subpart CC
  (existing)
40 CFR Part 63,
  Subpart CC
(existing or new)
ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
Recordkeeping
Requirements
Reporting
Requirements
REQUIREMENTS
Use cap, blind flange, plug, or second valve to seal open end at all times except when operations
require flow through open end
Second valve - close valve on process fluid end prior to closing second valve
Double block and bleed system may remain open during operations but comply with basic standard at
all other times
N/A
N/A
Equipment in vacuum service
N/A
N/A
N/A
Information to be kept for all open-ended valves or lines
» list of ID number of subject open-ended valves or lines
Initial semiannual report:
« process unit identification
Subsequent semiannual reports:
» process unit ID
* revisions to items reported in the initial semiannual report if changes have occurred since the
initial semiannual report or subsequent revisions to the initial semiannual report
                                OPEN-ENDED VALVES OR LINES
                                                                     page C-24

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                  PRESSURE RELIEF DEVICES IN GAS/VAPOR SERVICE
                                          APPLICABLE REGULATIONS
 40CFRPart60
  Subpart ODD
40 CFR Pan 60,
 Subpart GGG
40 CFR Part 60,
 Subpart KKK
40 CFR Part 60,
 Subpart QQQ
40 CFR Part 63,
  Subpart CC
   (existing)
40 CFR Part 63,
  Subpart CC
(existing or new)
     ITEM
                                     REQUIREMENTS
Basic Standard
No detectable emissions (less than 500 ppm above background)

After each release return to no detectable emissions within 5 calendar days as indicated by monitoring
of the pressure relief device
Leak Definition
500 ppm
Alternative
Standards
Equivalent means of emission limitation

Pressure relief device equipment with compliant closed-vent system and control device
Exemptions
Equipment in vacuum service
Monitoring
Method
Method 21
Repair
Requirements
N/A
Delay of Repair
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown

Allowed for equipment that is isolated from the process and that does not remain in VOC service
Recordkeeping
Requirements
Information to be kept for all pressure relief devices:
  « list of ID numbers of pressure relief devices required to comply
  • for each compliance test for pressure relief devices designated for no detectable emissions
    « • dates conducted
    * • background level measured
    • * maximum instrument reading
  • list of ID numbers for pressure relief devices in vacuum service
Reporting
Requirements
Initial semiannual report:
  * process unit ED for pressure relief devices

Subsequent semiannual reports:
  » process unit identification
  • the facts that explain each delay of repair, and where appropriate, why a process unit shutdown
    was technically infeasible
  » dates of process unit shutdowns that occurred within the semiannual reporting period
  • revisions to items reported in the initial semiannual report if changes have occurred since the
    initial semiannual report or subsequent revisions to the initial semiannual report
  » report of all performance tests in accordance with §60.8.
                               PRESSURE RELIEF DEVICES IN GAS/VAPOR SERVICE
                                                                                    page C-25

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            PUMPS AND VALVES IN HEAVY LIQUID SERVICE, PRESSURE
                RELIEF DEVICES IN LIGHT LIQUID OR HEAVY LIQUID
                 SERVICE, AND FLANGES AND OTHER CONNECTORS
                                       APPLICABLE REGULATIONS
 40 CFR Part 60
  Sttbput DDD
40CFRPait60,
 Subpart GGG
!0 CFR Part 60,
SubpartKKK

40 CFR Part 60,
Subpart QQQ

40 CFR Part 63,
Subpart CC
(existing)

40 CFR Part 63,
Subpait CC
(existing or new)

     ITEM
                                  REQUIREMENTS
Basic Standard
Monitoring of potential leaks within 5 calendar days of detection if evidence of potential leak is found
by visual, audible, olfactory, or other detection method
Leak Definition
10,000 ppm
Alternative
Standards
Equivalent means of emission limitation
Exemptions
Equipment in vacuum service
Monitoring
Method
Method 21
Repair
Requirements
First attempt within 5 calendar days of detection

Repair as soon as practicable; no later than 15 days after detection
Delay of Repair
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown

Allowed for equipment that is isolated from the process and that does not remain in VOC service.
Reeordkeeping
Requirements
When leak detected:
 »  a weather-proof and readily visible identification, marked with the equipment ID number,
    attached to the leaking equipment
 «  ID may be removed after it has been repaired

Information to be kept in log for 2 years after leak detected:
 •  instrument and  operator ED number and equipment DD number
 »  date leak detected
 *  dates of each attempt to repair leak
 •  repair methods  applied in each attempt to repair
 •  "above 10,000" if maximum instrument reading after each repair attempt is J> 10,000 ppm
 «  "repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection
 *  signature of owner/operator whose decision it was that repair could not be affected without a
    process shutdown
 •  expected  date of successful repair if leak is not repaired within 15 days
 «  dates of process unit shutdown that occurred while the equipment  is unrepaired
 «  date of successful repair of the leak
             PUMPS AND VALVES IN HEAVY LIQUID SERVICE, PRESSURE RELIEF DEVICES IN tlGHT
                 LIQUID OR HEAVY LIQUID SERVICE, AND FLANGES AND OTHER CONNECTORS
                                                                             page C-26

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           PUMPS AND VALVES IN HEAVY LIQUID SERVICE, PRESSURE
               RELIEF DEVICES IN LIGHT LIQUID OR HEAVY LIQUID
                SERVICE, AND FLANGES AND OTHER CONNECTORS
                                     APPLICABLE REGULATIONS
 40 CFR Part 60
  Subpart DDD
40 CFR Part 60,
 Subpart OGG
40 CFR Part 60,
 Subpart KKK
40 CFR Part 60,
 Subpart QQQ
40 CFR Part 63,
  Subpart CC
  (existing)
40 CFR Part 63,
  Subpart CC
(existing or new)
     ITEM
                                REQUIREMENTS
Reeordkeeping
Requirements
(concluded)
Information to be kept for all equipment in these categories:
 • list of ID numbers of subject equipment in these categories
 « list of ID numbers for equipment in vacuum service
Reporting
Requirements
Initial semiannual report:
 • process unit identification

Subsequent semiannual reports:
 • process unit identification
 * the following information by month in the reporting period
   • • number of pumps and valves for which leaks were detected
   « * number of pumps and valves for which leaks were not repaired within 15 calendar days
   • • the facts that explain each delay of repair, and where appropriate, why a process unit
       shutdown  was technically infeasible
 • dates of process unit shutdowns that occurred within the semiannual reporting period
 » revisions to items reported in the initial semiannual report if changes have occurred since the
   initial semiannual report or subsequent revisions to the initial semiannual report
 • report of all performance tests in accordance with §60.8
             PUMPS AND VALVES IN HEAVY LIQUID SERVICE, PRESSURE RELIEF DEVICES IN LIGHT
                LIQUID OR HEAVY LIQUID SERVICE, AND FLANGES AND OTHER CONNECTORS          page C-27

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                               PUMPS IN LIGHT LIQUID SERVICE
                                         APPLICABLE REGULATIONS
  40 CFR Part 60
   Subpan ODD
 40 CFR Part 60,
  Subpart GGG
10 CFR Part 60,
Subpart KKK

40 CFR Part 60,
Subpart QQQ

40 CFR Part 63,
Subpart CC
(existing)

40 CFR Part 63,
Subpart CC
(existing or new)

     ITEM
                                     REQUIREMENTS
Basic Standard
 Monthly leak detection and repair

 Weekly visual observation for leaks
Leak Definition
 10,000 ppm

 Indications of liquids dripping from pump seal
Alternative
Standards
 Equivalent means of emission limitation

 Dual mechanical seal pumps (see Dual Mechanical Seals)

 No detectable emissions (see No Detectable Emissions)

 Closed-vent system and control device (see Closed-vent Systems and Control Devices)
Exemptions
 Pumps in vacuum service

 Pumps in process units located in the Alaskan North Slope
Monitoring
Method
 Method 21; no more the 1 cm from rotating shaft
Repair
Requirements
 First attempt within 5 calendar days of detection

 Repair as soon as practicable; no later than 15 days after detection
Delay of Repair
 Allowed if technically infeasible without process unit shutdown; required before end of next process
 unit shutdown.

 Allowed for equipment that is isolated from the process and that does not remain in VOC service

 Allowed if repair requires use of a DMS that includes a'barrier fluid system and repair is completed
 as soon as practicable but not later than 6 months after leak detected
Reeordkeeping
Requirements
 When leak detected:
  «  a weather-proof arid readily visible identification, marked with the equipment ID number,
     attached to the leaking equipment
  »  ID may be removed after it has been repaired

	   (Continued on next page)	
                                       PUMPS IN LIGHT LIQUID SERVICE
                                                                                   page C-28

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                               PUMPS IN LIGHT LIQUID SERVICE
                                          APPLICABLE REGULATIONS
  40 CFR Part 60
   Subpart DDD
40 CFR Part 60,
 Subpart GGG
) CFR Part 60,
Subpart KKK

40 CFR Part 60,
Subpart QQQ

40 CFR Part 63,
Subpart CC
(existing)

40 CFR Part 63,
Subpart CC
(existing or new)

      ITEM
                                    REQUIREMENTS
Recordkeeping
Requirements
(continued)
Information to be kept in log for 2 years after leak detected:
 »  instrument and operator ID number and equipment ID number
 «  date leak detected
 •  dates of each attempt to repair leak
 •  repair methods applied in each attempt to repair
 •  "above 10,000" if maximum instrument reading after each repair attempt is >, 10,000 ppm
 «  "repair delayed" and reason for delay is leak not repaired within 15 calendar days after detection
 •  signature of owner/operator whose decision it was that repair could not be effected without a
    process shutdown
 •  expected date of successful repair if leak is not repaired with the 15 days
 «  dates of process unit shutdown that occurred while the equipment is unrepaired
 •  date of successful repair of the leak

Information to be kept for  all pumps:
 «  list of ID numbers of subject pumps
 •  list of ID numbers of pumps designated for no detectable emissions and signed by
    owner/operator
 «  for each compliance test for pumps designated for no detectable emissions
    • *  date conducted
    • •  background level measured
    * •  maximum instrument reading

Information and data used  to demonstrate that a pump is not in VOC service
Reporting
Requirements
Initial semiannual report:
 *  process unit identification
 •  number of pumps, excluding those designated for no detectable emissions

Subsequent semiannual reports:
 »  The following information by month in the reporting period:
    • •  process unit identification
    » •  number of pumps for which leaks were detected
    • «  number of pumps for which leaks were not repaired within 15 days after detection
    * •  the facts that explain each delay of repair, and where appropriate, why a process unit
        shutdown was technically infeasible
 *  Dates of process unit shutdowns that occurred within the semiannual reporting period
 •  Revisions to items reported in the initial semiannual report if changes have occurred since the
    initial semiannual report or subsequent revisions to the initial semiannual report
 •  Report of all performance tests in accordance with §60.8.
                                       PUMPS IN LIGHT LIQUID SERVICE
                                                                                   page C-29

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                     SAMPLING CONNECTION SYSTEMS
                              APPLICABLE REGULATIONS
40 CFR Part 60
 Subpart DDD
40CFRPart60,
 Subpart GOG
40 CFR Part 60,
Subpart KKK

40 CER Part 60,
Subpart QQQ

40 CFR Pan 63,
Subpart CC
(existing)

40 CFR Part 63,
Subpart CC
(existing or new)

ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
Recordkeeping
Requirements
Reporting
Requirements
REQUIREMENTS
Equipped with closed-purged, closed-loop, or closed-vent system
process, or recycles the purged fluid to a process, or sends it to a
that: returns the fluid to the
complaint control device
N/A
N/A
Equipment in vacuum service; in-situ sampling systems; and sampling systems without purges.
N/A
N/A
N/A
Information to be kept for all sampling connections
• list of ID numbers of subject sampling connection systems
Initial semiannual report:
» process unit identification
Subsequent semiannual reports:
• process unit ID
• revisions to items reported in the initial semiannual report if changes have occurred since the
initial semiannual report or subsequent revisions to the initial semiannual report
                           SAMPLING CONNECTION SYSTEMS
                                                              page C-30

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VALVES IN GAS/VAPOR AND LIGHT LIQUID SERVICE
                 APPLICABLE REGULATIONS
40 CFR Part 60
Subpart DDD
40CFRPart60, 40CFRPart60, 40CFRPait60, 40CFR
Subpart GGG Subpart KKK Subpart QQQ Subpa
(exis
^^m

ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
Part 63, 40 CFR Part 63,
it CC Subpart CC
ting) (existing or new)


REQUIREMENTS
Monthly leak detection and repair
If valve does not leak for 2 months, may be monitored quarterly
If valve leaks, monitor monthly until no leak is detected for 2 consecutive months
10,000 ppm

Equivalent means of emission limitation
No detectable emissions
Valves designated unsafe to monitor or difficult to monitor
Allowable percentage of valves leaking

Valves in vacuum service
Valves in process units located in the Alaskan North Slope
Method 21
First attempt within 5 calendar days of detection
Repair as soon as practicable; no later than 15 days after detection
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in VOC service
Allowed if emissions of purged material from immediate repair would exceed fugitive emissions from
delay of repair, and purged materials are collected and destroyed or recovered in a control device
when repair occurs
Allowed beyond process unit shutdown if otherwise sufficient supply of valve assembly replacements
are exhausted
         VALVES IN GAS/VAPOR AND LIGHT LIQUID SERVICE
page C-31

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                  VALVES IN GAS/VAPOR AND LIGHT LIQUID SERVICE
                                          APPLICABLE REGULATIONS
  40OFRPart60
  Subpart DDD
40 CFR Part 60,
 Subpart GGG
10 CFR Part 60,
SubpattKKK

40 CFR Part 60,
Subpart QQQ

40 CFR Part 63,
Subpart CC
(existing)

40 CFR Pan 63,
Subpart CC
(existing or new)

     ITEM
                                    REQUIREMENTS
Recordkeeping
Requirements
When leak detected:
  «  a weather-proof and readily visible identification, marked with the equipment ID number,
    attached to the leaking equipment
  «  ED may be removed after it has been repaired and monitored for 2 months with no leaks

Information to be kept in log for 2 years after leak detected:
  «  instrument and operator ID number and equipment ID number
  •  date leak detected
  «  dates of each attempt to repair leak
  •  repair methods applied in each attempt to repair
  »  "above 10,000" if maximum instrument reading after each repair attempt is J>_ 10,000 ppm
  •  "repair delayed" and reason for delay is leak not repaired within 15 calendar days after detection
  •  signature of owner/operator whose decision it was that repair could not be effected without a
    process shutdown
  •  expected date of successful repair if leak is not repaired with the 15 days
  »  dates of process unit shutdown that occurred while the equipment is unrepaired
  •  date of successful repair of the leak

Information to be kept for all valves:
  •  list of ID numbers of subject valves
  »  list of ID numbers of valves designated for no detectable emissions and sdgned'by owner/operator
  *  for each compliance test for valves designated for no detectable emissions
    • •  date conducted
    * •  background level measured
    * *  maximum instrument reading
  *  list of ID numbers for valves in vacuum service

Information and data used to demonstrate that a valve is not in VOC service
Reporting
Requirements
Initial semiannual report:
  »  process unit identification
  »  number of valves, excluding those designated for no detectable emissions

Subsequent semiannual reports:
  •  process unit identification
  *  the following information by month in the reporting period:
    • • number of valves for which leaks were detected
    « • number of valves for which leaks were not repaired within 15 days after detection
    • * the facts that explain each delay of repair, and where appropriate, why a process unit
        shutdown was technically infeasible
  »  dates of process unit shutdowns that occurred within the semiannual reporting period
  •  revisions to items reported in the initial semiannual report if changes have occurred since the
    initial semiannual report or subsequent revisions to the initial semiannual  report
  «  report of all performance tests in accordance with alternative standards
                              VALVES IN GAS/VAPOR AND LIGHT LIQUID SERVICE
                                                                                   page C-32

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                 CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                                    APPLICABLE REGULATIONS
40 CFR Part 60
 Subpart ODD
40 CFR Part 60,
 Subpart GGG
40 CFR Part 60,
 Subpart KKK
40 CFR Part 60,
 Subpart QQQ
40 CFR Part 63,
  Subpart CC
   (existing)
40 CFR Part 63,
  Subpart CC
(existing or new)
ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
REQUIREMENTS
Control Devices:
• vapor recovery systems: 95 percent or greater recovery
• combustion devices: 95 percent or greater reduction or minimum residence time of 0.75 seconds
and minimum temperature of 816°C
• flares: comply with §60.18
Closed- Vent Systems:
• no detectable emissions (less than 500 ppm above background)
• control devices and closed-vent systems to be operated at all times that emissions may be vented
to them
Monitoring:
• control devices: monitor to ensure operated and maintained in conformance with their designs
• closed-vent systems: initially, annually, and at other times as requested by the Administrator
Closed-vent system: 500 ppm or visible indications
N/A
Vapor collection or closed-vent systems operated under a vacuum
Unsafe or difficult to monitor portions of closed-vent systems require alternate inspection plan
Hard piping construction: Method 21 for initial inspection, annual visual inspections
Duct work construction: Method 21 for initial and annual inspections
First attempt to repair within 5 calendar days of detection
Repair as soon as practicable; no later than 15 days after detection
Allowed if technically infeasible without process unit shutdown; required before
unit shutdown
Allowed for equipment that is isolated from the process and that does not remain
end of next process
in VOC service
                           CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                                                                                           page C-33

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                    CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                                         APPLICABLE REGULATIONS
40 CFR Part 60
Subpart DDD

40 CFR Part <
Subpart G&

                                     40 CFR Pan 60,
                                      Subpan KKK
CFR Pan 60,
ibpart QQQ

40 CFR Part 63,
Subpan CC
(existing)

40 CFR Part 63,
Subpart CC
(existing or new)

     ITEM
                                    REQUIREMENTS
Recordkeeping
Requirements
When leak detected:
 «  a weather-proof and readily visible identification, marked with the equipment ID number,
    attached to the leaking equipment
 «  ID may be removed after it has been repaired

Information to be kept in log for 2 years after leak detected:
 «  instrument and operator ID number and equipment ED number
 •  date leak detected
 •  dates of each attempt to repair leak
 «  repair methods applied in each attempt to repair
 •  "above 10,000" if maximum instrument reading after each repair attempt is .>. 10,000 pprn
 «  "repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection
 •  signature of owner/operator whose decision it was that repair could not be effected without a
    process shutdown
 •  expected date of successful repair if leak is not repaired with the 15 days
 »  dates of process unit shutdown that occurred while the equipment is unrepaired
 •  date of successful repair of the leak

When no leak detected:  records that instrument or visual inspection was conducted, date of
inspection, and statement that no leaks were detected

Information to be kept for all closed-vent systems and control devices:
 «  detailed schematics, design specifications, and piping and instrumentation diagrams
 •  dates and descriptions of any changes in design specifications
 •  description of parameter(s) to be monitored to ensure proper operation and maintenance
 •  explanation of selected parameters)
 •  periods of non-operation according to design
 •  dates of startups and shutdown
 •  list of ID numbers of subject closed-vent systems and control devices
 •  list of ID numbers of closed-vent systems and control devices designated for no detectable
    emissions and signed by owner/operator
 •  for each compliance test for closed-vent systems and control devices designated for no detectable
    emissions
    • •  date conducted
    • •  background level measured
    » •  maximum instrument  reading
 •  list of ID numbers for closed-vent systems  and control devices in vacuum service
Reporting
Requirements
Initial semiannual report:
  •  process unit identification

Subsequent semiannual reports:
  •  process unit identification
  «  dates of process unit shutdowns that occurred within the semiannual reporting period
  •  revisions to items reported in the initial semiannual report if changes have occurred since the
    initial semiannual report or subsequent revisions to the initial semiannual report
  «  report of all performance tests in accordance with §60.8
                               CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                                                                                   page C-34

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      COMPRESSORS
40 CFR Part 60
Subpart D0D

40 CFR Part 60,
Subpart GOG

    APPLICABLE REGULATIONS
40 CFR Part 60,
 Subpart KKK
PR Part 60,
>part QQQ

40 CFR Part 63,
Subpart CC
(existing)

40 CFR Part 63,
Subpart CC
(existing or new)

ITEM
Basic Standard
Leak Definition

Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
REQUIREMENTS
Equipped with compliant seal system that prevents leakage to atmosphere
Install sensor to detect failure of seal system
Check sensor daily or equip with audible alarm
Establish criteria basic standard that indicates failure of seal system or barrier fluid system or both
Sensor indicates failure of seal or barrier fluid system or both based on established criteria.

Equivalent means of emission limitation
No detectable emissions, operate less than 500 ppm above background
Closed-vent system and control device
Equipment in vacuum service
Reciprocating compressors that meet certain criteria
Reciprocating compressors in wet gas service
Sensor alarm or visual check
First attempt within 5 calendar days of detection
Repair as soon as practicable; no later than 15 calendar days after detection
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in VOC service
         COMPRESSORS
                                                      page C-35

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                                             COMPRESSORS
40 CFR Pan 60
Subpart DDD

40 CFR PartS
Subpart GGC

                                          APPLICABLE REGULATIONS
                                      40 CFR Part 60,
                                       Subpart KKK
CFR Part 60,
bpartQQQ

40 CFR Part 63,
Subpart CC
(existing)

40 CFR Part 63,
Subpart CC
(existing or new)

      ITEM
                                     REQUIREMENTS
Recordteeping
Requirements
When leak detected:
  •  a weather-proof and readily visible identification, marked with the equipment ID number,
    attached to the leaking equipment
  »  ID may be removed after it has been repaired

Information to be kept in log for 2 years after leak detected:
  •  instrument and operator ID number and equipment ID number
  •  date leak detected
  »  dates of each attempt to repair leak
  •  repair methods applied in each attempt to repair
  •  "above 10,000" if maximum instrument reading after each repair attempt is .>. 10,000 ppm
  »  "repair delayed" and reason for delay is leak not repaired within 15 calendar days after detection
  »  signature of owner/operator whose decision it was that repair could not be effected without a
    process shutdown
  »  expected date of successful repair if leak is not repaired with the 15 days
  »  dates of process unit shutdown that occurred while the equipment is unrepaired
  •  date of successful repair of the leak

Information to be kept for all compressors:
  •  list of ID numbers of subject compressors
  *  list of ID numbers of compressors designated for no detectable emissions and signed by
    owner/operator
  •  for each compliance test for compressors designated for no detectable emissions
    • •  date conducted
    » •  background level  measured
    • •  maximum instrument reading
  »      list of ID numbers for compressors in vacuum service

Information and data used to demonstrate that a reciprocating compressor is in wet gas service
Reporting
Requirements
Initial semiannual report:
  »  process unit identification
  «  number of compressors, excluding those designated for no detectable emissions

Subsequent semiannual reports:
  «  The following information by month in the reporting period:
    • •  process unit identification
    * *  number of compressors for which leaks were detected
    * •  number of compressors for which leaks were not repaired within 15 days after detection
    « •  the facts that explain each delay of repair, and where appropriate, why a process unit
        shutdown was technically infeasible

  •  Dates of process unit shutdowns that occurred within the semiannual reporting period
  «  Revisions to items reported in the initial semiannual report if changes have occurred since the
    initial semiannual  report or subsequent revisions to the initial semiannual report
  »  Report of all performance tests in accordance with §60.8.
                                                COMPRESSORS
                                                                                    page C-36

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DUAL MECHANICAL SEAL SYSTEM
         APPLICABLE REGULATIONS
40 CFR Part 60
Subpart DDD

40 CFR Part 60,
Subpart GGG

      40 CFR Part 60,
      Subpart KKK
40 CFR Pan 60,
Subpart QQQ

40 CFR Part 63,
Subpart CC
(existing)

40 CFR Part 63,
Subpart CC
{existing or new)

ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
REQUIREMENTS
For each dual mechanical seal system:
« operate the barrier fluid at a pressure that is at all times greater than the pump stuffing box
pressure, or
• connect the barrier fluid degassing reservoir by a closed-vent system to a control device, or
« equip with a system that purges the barrier fluid into a process stream with zero VHAP
emissions to the atmosphere
For all dual mechanical seal systems:
« the barrier fluid system shall be in heavy liquid service or not in VOC service
» equip each barrier fluid system with a sensor
• • check each sensor daily or equip with audible alarm
• • determine criterion that indicates failure of the seal system, the barrier fluid system, or both
* perform weekly visual inspections for indications of liquids dripping from the pump seals
Indications of liquids dripping from the pump seal; sensor
Applies as an alternative standard to: Pumps in Light Liquid Service
N/A
Visual, sensor
First attempt within 5 calendar days of detection
Repair as soon as practicable; no later than 15 days after detection
If repair requires use of a DMS that includes a barrier fluid system and repair is completed as soon as
practicable but no later than 6 months after leak detected
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in VOC service
      DUAL MECHANICAL SEAL SYSTEM
                                                         page C-37

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                              DUAL MECHANICAL SEAL SYSTEM
                                         APPLICABLE REGULATIONS
  40CFRPan60
  Subpatt DDD
40 CFR Pan 60,
 Subpart GGG
40 CFR Part 60,
 SubpartKKK
40 CFR Pan 60,
 Subpart QQQ
40 CFR Part 63,
  Subpart CC
   (existing)
40 CFR Part 63,
  Subpart CC
(existing or new)
     ITEM
                                    REQUIREMENTS
Recordkeeping
Requirements
Information to be kept in log for 2 years after leak detected:
 •  instrument and operator ID number and equipment ID number
 •  date leak detected
 •  dates of each attempt to repair leak
 •  repair methods applied in each attempt to repair
 •  "above 10,000" if maximum instrument reading after each repair attempt is _>. 10,000 ppm
 •  "repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection
 •  signature of owner/operator whose decision it was that repair could not be effected without a
    process shutdown
 •  expected date of successful repair if leak is not repaired within the 15 days
 •  dates of process unit shutdown that occurred while the equipment is unrepaired
 »  date of successful repair of the leak

Information to be kept for all dual mechanical seal systems:
 •  list of ED numbers of pumps  with dual mechanical seal systems
 •  list of ED numbers designated for no detectable emissions and signed by owner/operator
Reporting
Requirements
Initial semiannual report:
 •  process unit identification

Subsequent semiannual reports:
 »  the following information by month in the reporting period:
    • •  process unit identification
    » •  the facts that explain each delay of repair, and where appropriate, why a process unit
        shutdown was technically infeasible
 •  dates of process unit shutdowns that occurred within the semiannual reporting period
 *  revisions to items reported in the initial semiannual report if changes have occurred since the
    initial semiannual report or subsequent revisions to the initial semiannual report
 •  report of all performance tests in accordance with §60,8
                                      DUAL MECHANICAL SEAL SYSTEM
                                                                                   page C-38

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NON DETECTABLE EMISSIONS
      APPLICABLE REGULATIONS
40 CFR Part 60
Subpart DDD

40 CFR Part 60
Siibpart GGG

   40 CFR Part 60,
    Subpart KKK
FR Part 60,
>part QQQ

40 CFR Pan 63,
Subpart CC
(existing)

40 CFR Part 63,
Subpart CC
(existing or new)

ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
Recordkeeping
Requirements
Reporting
Requirements
REQUIREMENTS
An instrument reading of less than 500 ppm above background as measured by
in §60.485
Demonstrate compliance initially upon designation and test annually
the methods specified
500 ppm
Applies as an alternate standard to:
« pumps in light liquid service (must have no externally actuated shaft penetrating the pump
housing)
• valves in gas/vapor service or in light liquid service (must have no external actuating mechanism
in contact with the process fluid)
Applies as regulated standard for:
» closed vent systems
« pressure relief devices in gas/vapor service
N/A
Method 21
N/A
N/A
Information to be kept:
« list of ID numbers of equipment designated for no detectable emission and
owner/operator
* for each compliance test for no detectable emission
• • date conducted
» • background level measured
• * maximum instrument reading
signed by
Subsequent semiannual reports:
« dates of process unit shutdowns that occurred within the semi-annual reporting period
• revisions to items reported in the initial semiannual report if changes have occurred since the
initial semiannual report or subsequent revisions to the initial semiannual report
« report of all performance tests in accordance with §60.8
      NO DETECTABLE EMISSIONS
page C-39

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OPEN-ENDED VALVES OR LINES
       APPLICABLE REGULATIONS
40 CFR Part 60
Subpan ODD

40 CFR Part 60,
Subpan GGG

    40 CFR Pan 60,
    Subpan KKK
TR Part 60,
bpart QQQ

40 CFR Part 63,
Subpart CC
(existing)

40 CFR Part 63,
Subpan CC
(existing or new)

ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
Recordkeeping
Requirements
Reporting
Requirements
REQUIREMENTS
Use cap, blind flange, plug, or second valve to seal open end at all times except when operations
require flow through open end
Second valve - close valve on process fluid end prior to closing second valve
Double block and bleed system may remain open during operations but comply with basic standard at
all other times
N/A
N/A
Equipment in vacuum service
N/A
N/A
N/A
Information to be kept for all open-ended valves or lines
» list of ID number of subject open-ended valves or lines
Initial semiannual report:
» process unit identification
Subsequent semiannual reports:
• process unit ID
« revisions to items reported in the initial semiannual report if changes have occurred since the
initial semiannual report or subsequent revisions to the initial semiannual report
     OPEN-ENDED VALVES OR LINES
page C-40

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              PRESSURE RELIEF DEVICES IN GAS/VAPOR SERVICE
                                • APPLICABLE REGULATIONS
40 CFR Part 60
 Subpart DDD
40 CFR Part 60,
 Subpart GOG
40 CFR Part 60,
 Subpart KKK
40 CFR Part 60,
 Subpart QQQ
40 CFR Part 63,
  Subpart CC
  (existing)
40 CFR Part 63,
  Subpart CC
(existing or new)
ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
REQUIREMENTS
Monitor quarterly and within 5 days after each pressure release
For nonfractionating plants monitored by non-plant personnel; after each pressure release
next time monitoring personnel are onsite or within 30 days
monitor
10,000 ppm

Equivalent means of emission limitation
Pressure relief device equipment with compliant closed-vent system and control device
No detectable emissions
Equipment in vacuum service
Equipment in process units in the Alaskan North Slope
Equipment in nonfractionating plants with less than 10 million scfd of field gas processing

capacity
Method 21
First attempt within 5 calendar days of detection
Repair as soon as practicable; no later than 15 days after detection
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in VOC service
                       PRESSURE RELIEF DEVICES IN GAS/VAPOR SERVICE
                                                                    page C-41

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                  PRESSURE RELIEF DEVICES IN GAS/VAPOR SERVICE
                                         APPLICABLE PECULATIONS
40CFRPan60
Subpart DDD

40 CFR Part 60,
Subpart OGG

                                     40 CFR Part 60,
                                      Subpart KKK
:FR Part 60,
bpart QQQ

40 CFR Part 63,
Subpart CC
(existing)

40 CFR Part 63,
Subpart CC
(existing or new)

      ITEM
                                    REQUIREMENTS
Rccordkeeping
Requirements
When leak detected:
 •  a weather-proof and readily visible identification, marked with the equipment ID number,
    attached to the leaking equipment
 •  ID may be removed after it has been repaired and monitored for 2 months with no leaks

Information to be kept in log for 2 years after leak detected:
 «  instrument and operator ID number and equipment ID number
 •  date leak detected
 *  dates of each attempt to repair leak
 •  repair methods applied in each attempt to repair
 •  "above 10,000" if maximum instrument reading after each repair attempt is .>_ 10,000 ppm
 »  "repair delayed" and reason for delay is leak not repaired within 15 calendar days after detection
 »  signature of owner/operator whose decision it was that repair could not be effected without a
    process shutdown
 •  expected date of successful repair if leak is not repaired with the 15 days
 •  dates of process unit shutdown that occurred while the equipment is unrepaired
 •  date of successful repair of the leak

Information to be kept for all pressure relief devices:
 •  list of ID numbers of pressure relief devices required to comply
 »  list of ID numbers of PRD designated for no detectable emissions and signed by owner/operator
 •  for each compliance test for pressure relief devices designated for no detectable emissions
    • •  dates conducted
    »•  background level measured
    • •  maximum instrument reading
 •  list of ID numbers for pressure relief devices in vacuum service
Reporting
Requirements
Initial semiannual report:
 •  process unit ID for pressure relief devices

Subsequent semiannual reports:
 *  process unit identification
 •  the facts that explain each delay of repair, and where appropriate, why a process unit shutdown
    was technically infeasible
 »  dates of process unit shutdowns that occurred within the semiannual reporting period
 •  revisions to items reported in the initial semiannual report if changes have occurred since the
    initial semiannual report or subsequent revisions to the initial semiannual report
 •  report of all performance tests in accordance with §60.8.
                              PRESSURE RELIEF DEVICES IN GAS/VAPOR SERVICE
                                                                                  page C-42

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        PUMPS AND VALVES IN HEAVY LIQUID SERVICE, PRESSURE
            RELIEF DEVICES IN LIGHT LIQUID OR HEAVY LIQUID
             SERVICE, AND FLANGES AND OTHER CONNECTORS
                               APPLICABLE REGULATIONS
40 CFR Part 60
 Subpart DDD
40 CFR Part 60,
 Subpart GOG
40 CFR Part 60,
 Subpart KKK
40 CFR Part 60,
 Subpart QQQ
40 CFR Part 63,
 Subpart CC
  (existing)
40 CFR Part 63,
  Subpart CC
(existing or new)
ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
REQUIREMENTS
Monitoring of potential leaks within 5 calendar days of detection if evidence of potential leak is found
by visual, audible, olfactory, or other detection method
10,000 ppm
Equivalent means of emission limitation
Equipment in vacuum service
Method 21
First attempt within 5 calendar days of detection
Repair as soon as practicable; no later than 15 days after detection
Allowed if technically unfeasible without process unit shutdown; required
unit shutdown
Allowed for equipment that is isolated from the process and that does not
before end of next process
remain in VOC service.
          PUMPS AND VALVES IN HEAVY LIQUID SERVICE, PRESSURE RELIEF DEVICES IN LIGHT
             LIQUID OR HEAVY LIQUID SERVICE, AND FLANGES AND OTHER CONNECTORS         page C-43

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            PUMPS AND VALVES IN HEAVY LIQUID SERVICE, PRESSURE
                RELIEF DEVICES IN LIGHT LIQUID OR HEAVY LIQUID
                 SERVICE, AND FLANGES AND OTHER CONNECTORS
                                       APPLICABLE REGULATIONS
 40 CFR Part 60
  SubpartDDD
40 CFR Part 60,
 Subpart GGG
40 CFR Part 60,
 Subpart KKK
40 CFR Part 60,
 Subpart QQQ
40 CFR Part 63,
  Subpart CC
   (existing)
40 CFR Part 63,
  Subpart CC
(existing or new)
     ITEM
                                  REQUIREMENTS
Recordkeeping
Requirements
When leak detected:
 »  a weather-proof and readily visible identification, marked with the equipment ID number,
    attached to the leaking equipment
 «  ID may be removed after it has been repaired

Information to be kept in log for 2 years after leak detected:
 «  instrument and operator ID number and equipment ID number
 »  date leak detected
 •  dates of each attempt to repair leak
 »  repair methods-applied in each attempt to repair
 •  "above 10,000" if maximum instrument reading after each repair attempt is _>, 10,000 ppm
 *  "repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection
 »  signature of owner/operator whose decision it was that repair could not be affected without a
    process shutdown
 »  expected date of successful repair if leak is not repaired within 15 days
 »  dates of process unit shutdown that occurred while the equipment  is unrepaired
 »  date of successful repair of the leak

Information to be kept for all equipment in these categories:
 »  list of ID numbers of subject equipment in these categories
 •  list of ID numbers for equipment in vacuum service
Reporting
Requirements
Initial semiannual report:
 »  process unit identification

Subsequent semiannual reports:
 •  process unit identification

 *  the following information by month in the reporting period
    * •  number of pumps and valves for which leaks were detected
    • •  number of pumps and valves for which leaks were not repaired within 15 calendar days
    • •  the facts that explain each delay of repair, and where appropriate, why a process unit
        shutdown was technically infeasible
 •  dates of process unit shutdowns that occurred within the semiannual reporting period
 »  revisions to items reported in the initial semiannual report if changes have occurred since the
    initial semiannual report or subsequent revisions to the initial semiannual report
 »  report of all performance tests in accordance with §60.8
             PUMPS AND VALVES IN HEAVY LIQUID SERVICE, PRESSURE RELIEF DEVICES IN LIGHT
                 LIQUID OR HEAVY LIQUID SERVICE, AND FLANGES AND OTHER CONNECTORS
                                                                             page C-44

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                               PUMPS IN LIGHT LIQUID SERVICE
                                         APPLICABLE REGULATIONS
40 CFR Part 60
Subpart DDD

40 CFR Part 60,
Subpart GGG

                                     40 CFR Part 60,
                                      Subpart KKK
40 CFR Part 60,
Subpart QQQ

40 CFR Part 63,
Subpart CC
(existing)

40 CFR Part 63,
Subpart CC
(existing or new)

     ITEM
                                    REQUIREMENTS
Basic Standard
Monthly leak detection and repair

Weekly visual observation for leaks
Leak Definition
10,000 ppm

Indications of liquids dripping from pump seal
Alternative
Standards
Equivalent means of emission limitation

Dual mechanical seal pumps (see Dual Mechanical Seals)

No detectable emissions (see No Detectable Emissions)

Closed-vent system and control device (see Closed-vent Systems and Control Devices)
Exemptions
Pumps in vacuum service

Pumps in process units located in the Alaskan North Slope

Pumps in nonfractionating plants with less than 11 million scfd of field gas processing capacity
Monitoring
Method
Method 21; no more the 1 cm from rotating shaft
Repair
Requirements
First attempt within 5 calendar days of detection

Repair as soon as practicable; no later than 15 days after detection
Delay of Repair
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown.

Allowed for equipment that is isolated from the process and that does not remain in YOC service

Allowed if repair requires use of a DMS that includes a barrier fluid system and repair is completed
as soon as practicable but not later than 6 months after leak detected
                                       PUMPS IN LIGHT LIQUID SERVICE
                                                                                   page C-45

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                               PUMPS IN LIGHT LIQUID SERVICE
                                          APPLICABLE REGULATIONS
  40CFRPatl60
   Subpart DDD
40 CFR Part 60,
 Subpart GOG
40CFRFart60,
 Subpart KKK
40 CFR Part 60,
 Subpart QQQ
40 CFR Part 63,
  Subpart CC
   (existing)
40 CFR Part 63,
  Subpart CC
(existing or new)
     HEM
                                     REQUIREMENTS
Recordfceeping
Requirements
When leak detected:
 •  a weather-proof and readily visible identification, marked with the equipment ID number,
    attached to the leaking equipment
 »  ID may be removed after it has been repaired

Information to be kept in log for 2 years after leak detected:
 •  instrument and operator ID number and equipment ID number
 »  date leak detected
 »  dates of each attempt to repair leak
 »  repair methods applied in each attempt to repair
 •  "above 10,000" if maximum instrument reading after each repair attempt is _>. 10,000 ppm
 «  "repair delayed" and reason for delay is leak not repaired within 15 calendar days after detection
 «  signature of owner/operator whose decision it was that repair could not 'be effected without a
    process shutdown
 «  expected date of successful repair if leak is not repaired with the 15 days
 »  dates of process unit shutdown that occurred while the equipment is unrepaired
 »  date of successful repair of the leak

Information to be kept for all pumps:
 •  list of ED numbers of subject pumps
 »  list of JD numbers of pumps designated for no detectable emissions and signed by
    owner/operator
 •  for each compliance test for pumps designated for no detectable emissions
    • •  date conducted
    « *  background level measured
    • •  maximum instrument reading

Information and data used  to demonstrate that a pump is not in VOC service
Reporting
Requirements
Initial semiannual report:
 •  process unit identification
 «  number of pumps, excluding those designated for no detectable emissions

Subsequent semiannual reports:
 «  The following information by month in the reporting period:
    » •  process unit identification
    • •  number of pumps for which leaks were detected
    » •  number of pumps for which leaks were not repaired within 15 days after detection
    »•  the facts that explain each delay of repair, and where appropriate, why a process unit
        shutdown was technically infeasible
 »  Dates of process unit shutdowns that occurred within the semiannual reporting period
 «  Revisions to items reported in the initial semiannual report if changes have occurred since the
    initial semiannual report or subsequent revisions to the initial semiannual report
 *  Report of all performance tests in accordance with §60.8.
                                       PUMPS IN LIGHT LIQUID SERVICE
                                                                                   page C-46

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                  VALVES IN GAS/VAPOR AND LIGHT LIQUID SERVICE
                                         APPLICABLE REGULATIONS
40 CFR Part 60
Subpart ODD

40 CFR Part 60,
Subpart GOG

                                     40 CFR Part 60,
                                      Subpart KKK
FR Part 60,
opart QQQ

40 CFR Part 63,
Subpart CC
(existing)

40 CFR Part 63,
Subpart CC
(existing or new)

     ITEM
                                    REQUIREMENTS
Basic Standard
Monthly leak detection and repair

If valve does not leak for 2 months, may be monitored quarterly

If valve leaks, monitor monthly until no leak is detected for 2 consecutive months
Leak Definition
10,000 ppm
Alternative
Standards
Equivalent means of emission limitation

No detectable emissions

Valves designated unsafe to monitor or difficult to monitor

Allowable percentage of valves leaking
Exemptions
Valves in vacuum service

Valves in process units in the Alaskan North Slope

Valves in nonfractionating plants with less than 10 million scfd of field gas processing capacity
Monitoring
Method
Method 21
Repair
Requirements
First attempt within 5 calendar days of detection

Repair as soon as practicable; no later than 15 days after detection
Delay of Repair
Allowed if technically infeasible without process-unit shutdown; required before end of next process
unit shutdown

Allowed for equipment that is isolated from the process and that does not remain in VOC service

Allowed if emissions of purged material from immediate repair would exceed fugitive emissions from
delay of repair, and purged materials are collected and destroyed or recovered in a control device
when repair occurs

Allowed beyond process unit shutdown if otherwise sufficient supply of valve assembly replacements
are exhausted
                              VALVES IN GAS/VAPOR AND LIGHT LIQUID SERVICE
                                                                                   page C-47

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                  VALVES IN GAS/VAPOR AND LIGHT LIQUID SERVICE
                                         APPLICABLE REGULATIONS
40 CFR Part 60
Subpart DDD

40 CFR Part 60,
Subpan GGG

                                     40 CFR Part 60,
                                      Subpart KKK
DPR Part 60,
bpart QQQ

40 CFR Part 63,
Subpan CC
(existing)

40 CFR Part 63,
Subpart CC
(existing or new)

     ITEM
                                    REQUIREMENTS
Recordkeeping
Requirements
When leak detected:
 »  a weather-proof and readily visible identification, marked with the equipment ID number,
    attached to the leaking equipment
 «  ID may be removed after it has been repaired and monitored for 2 months with no leaks

Information to be kept in log for 2 years after leak detected:
 *  instrument and  operator ID number and equipment ID number
 »  date leak detected
 •  dates of each attempt to repair leak
 «  repair methods  applied in each attempt to repair
 •  "above 10,000" if maximum instrument reading after each repair attempt is J>. 10,000 ppm
 «  "repair delayed" and reason for delay is leak not repaired within 15 calendar days after detection
 »  signature of owner/operator whose decision it was that repair could not be effected without a
    process shutdown
 »  expected date of successful repair if leak is not repaired with the 15 days
 »  dates of process unit shutdown that occurred while the equipment is unrepaired
 •  date of successful repair of the leak

Information to be kept for all valves:
 •  list of ID numbers of subject valves
 »  list of ID numbers of valves designated for no detectable emissions and signed'by owner/operator
 •  for each compliance test for valves designated for no detectable emissions
    • •  date conducted
    • •  background level measured
    • »  maximum  instrument reading
 •  list of ID numbers for valves in vacuum service

Information and data used to demonstrate that a valve is not in VOC service
Reporting
Requirements
Initial semiannual report:
 •  process unit identification
 »  number of valves, excluding those designated for no detectable emissions

Subsequent semiannual reports:
 »  process unit identification
 •  the following information by month in the reporting period:
    • •  number of valves for which leaks were detected
    • •  number of valves for which leaks were not repaired within 15 days after detection
    • •  the facts that explain each delay of repair, and where appropriate, why a process unit
        shutdown was technically infeasible
 »  dates of process unit shutdowns that occurred within the semiannual reporting period
 »  revisions to items reported in the initial semiannual report if changes have occurred since the
    initial semiannual report or subsequent revisions to the initial semiannual report
 »  report of all performance tests in accordance with alternative standards
                              VALVES IN GAS/VAPOR AND LIGHT LIQUID SERVICE
                                                                                  page C-48

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                CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                                   APPLICABLE REGULATIONS
40 CWS. Part 60
 Subpart DDD
40 CFR Part 60,
 Subpart GGO
40 CFR Part 60,
 Subpart KKK
40 CER Part 60,
 Subpart QQQ
40 CFR Part 63,
  Subpart CC
  (existing)
40 CFR Part 63,
  Subpart CC
(existing or new)
ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
REQUIREMENTS
Control Devices:
• vapor recovery systems: 95 percent or greater recovery
• combustion devices: 95 percent or greater reduction or minimum residence time of 0.75 seconds
and minimum temperature of 816°C
• flares: comply with §60.18
» flow indicator required to ensure vapors are routed to control device
Closed- Vent Systems:
• no detectable emissions (less than 500 ppm above background)
« control devices and closed-vent systems to be operated at all times that emissions may be vented
to them
* shall be purged to direct vapor to control device
Monitoring:
* control devices: monitor to ensure operated and maintained in conformance with their designs
* closed-vent systems: initially, semi-annually, and at other times as requested by the
Administrator
• all gauging and sampling devices to be gas tight
Closed-vent system: 500 ppm

Equivalent means of emission limitation

N/A
Method 21
Flares: Conduct initial performance test and monitor to comply with §60.18(0(2)
First attempt to repair as soon as practicable; no later than 30 days after detection
Allowed if technically infeasible without process unit shutdown; required before end of next refinery
or process unit shutdown
                          CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                                                                         page C-49

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                    CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                                         APPLICABLE REGULATIONS
40 CFR Pan 60
Subpart DDD

40CFRPan60,
Subpart GGG

40 CFR Part 60,
Subpart KKK

                                                       40 CFR Part 60,
                                                         Subpart QQQ
40 CFR Pan 63,
Subpart CC
(existing)

40 CFR Part 63,
Subpart CC
(existing or new)

     ITEM
                                    REQUIREMENTS
Reeordkeeping
Requirements
Information to be kept in log for 2 years after leak detected:
 •  location of leak
 «  date leak detected
 *  corrective action taken
 •  expected date of successful repair if leak is not repaired with the 30 days
 «  reason for delay if leak not repaired within 30 calendar days after detection
 «  signature of owner/operator whose decision it was that repair could not be effected without a
    process shutdown
 •  date of successful repair of the leak

Information to be kept for all closed-vent systems and control devices:
 •  detailed schematics, design specifications, and piping and instrumentation diagrams
 •  dates and descriptions of any changes in design specifications
 •  description of parameter(s) to be monitored to ensure proper operation and maintenance
 •  documentation that control device will achieve required control efficiency during maximum
    loading conditions
 *  explanation of selected parameters)
 «  periods of non-operation according to design
 •  dates of startups and shutdown
 •  for each no detectable emission measurement (retain for 2 years)
    « •  date conducted
    « •  background level measured
    » •  maximum instrument reading

Information for thermal incinerators (retain for 2 years)
 •  continuous records of gas stream temperature  in the combustion zone
 «  records of all 3-hour periods during which combustion zone temperatures are more than 28°C
    (30°F) below the design temperature

Information for catalytic incinerators (retain for 2 years)
 •  continuous records of gas stream temperatures, upstream and downstream of the catalytic bed
 •  records of all 3-hour periods during which temperatures before the bed are more than 28°C
    (50°F) below the design temperature
 »  records of all 3-hour periods during which the average temperature differences across the
    catalytic bed are less than 80 percent of the design temperature differences

Information for carbon absorbers (retain for 2 years)
 •  continuous records of VOC concentration at the  outlet
 «  records of all 3-hour periods when VOC concentrations are more than 20 percent greater than
    design levels
                               CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                                                                                   page C-50

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                    CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                                         APPLICABLE REGULATIONS
 40 CFR Part 60
  Subpart DDD
40 CFR Part 60,
 Subpart GOG
40 CFR Part 60,
 Subpart KKK
40 CFR Part 60,
 Subpart QQQ
40 CFR Part 63,
  Subpart CC
   (existing)
40 CFR Part 63,
  Subpart CC
(existing or new)
     ITEM
                                    REQUIREMENTS
Reporting           Initial certification within 60 days of startup that required equipment is in place and has been
Requirements       inspected or tested as required

                   Semi-annual certification that all required inspections have been carried out

                   If a flare is used, initial performance test results within 60 days of startup.

                   Initial and semi-annual reports that summarize all inspections that identify problems that could result
                   in VOC emissions; including information about repairs and corrective action taken.

                   Semi-annual reports of
                    • each 3-hour period of thermal incinerator operation during which combustion zone temperatures
                      are more than 28°C (50°F) below design temperature
                    » each 3-hour period of catalytic incinerator operation during which temperatures before the bed
                      were more than 28°C (50°F) below design and all 3-hour periods during which temperatures
                      across the bed are less than 80 percent of design
                    » each 3-hour period of carbon absorber operation during which VOC concentrations are more
                      than 20 percent greater than design
                               CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                                                                                  page C-51

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CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                APPLICABLE REGULATIONS
40 CFR Part 60
SubpartDDD

40 CFR Part 60,
Subpart GGG

40 CFR Part 60,
Subpart KKK

40 CFR Part
Subpart QC;

                                         40 CFR Part 63,
                                          Subpart CC
                                           (existing)
40 CFR Part 63,
  Subpart CC
(existing or new)
ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
REQUIREMENTS
Control Devices:
• vapor recovery systems: 95 percent or greater recovery
« combustion devices: 95 percent or greater reduction or minimum residence time of 0,75 seconds
and minimum temperature of 816°C
» flares: comply with §60.18
Closed- Vent Systems:
« no detectable emissions (less than 500 ppm above background)
« control devices and closed-vent systems to be operated at all times that emissions may be vented
to them
Monitoring:
» control devices: monitor to ensure operated and maintained in conformance with their designs
» closed-vent systems: initially, annually, and at other times as requested by the Administrator
Closed-vent system: 500 ppm or visible indications
40 CFR 63, Subpart H
Vapor collection or closed-vent systems operated under a vacuum
Unsafe or difficult to monitor portions of closed-vent systems require alternate inspection plan
Hard piping construction: Method 21 for initial inspection, annual visual inspections
Duct work construction: Method 21 for initial and annual inspections
First attempt to repair within 5 calendar days of detection
Repair as soon as practicable; no later than 15 days after detection
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in VOC service
        CLOSED-VENT SYSTEMS AND CONTROL DEVICES
      page C-52

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                    CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                                         APPLICABLE REGULATIONS
40 CFR Part 60
Subpart ODD

40 CFR Part 60,
Subpait GOG

40 CFR Part 60,
Subpart KKK

40 CFR Part (
Sobpart QQ(

                                                                          40 CFR Part 63,
                                                                            Subpart CC
                                                                             (existing)
                                                                          40 CFR Part 63,
                                                                            Subpart CC
                                                                          (existing or new)
     ITEM
                                    REQUIREMENTS
Recordkeeping
Requirements
When leak detected:
 «  a weather-proof and readily visible identification, marked with the equipment ID number,
    attached to the leaking equipment
 *  ID may be removed after it has been repaired

Information to be kept in log for 5 years after leak detected:
 •  instrument and operator ID number and equipment ID number
 •  date leak detected
 •  dates of each attempt to repair leak
 •  repair methods applied in each attempt to repair
 •  "above 10,000" if maximum instrument reading after each repair attempt is >_ 10,000 ppm
 •  "repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection
 •  signature of owner/operator whose decision it was that repair could not be effected without a
    process shutdown
 •  expected date of successful repair if leak is not repaired with the 15 days
 »  dates of process unit shutdown that occurred while the equipment is unrepaired
 •  date of successful repair of the leak

When no leak detected:  records that instrument or visual inspection was conducted, date of
inspection, and statement that no leaks were detected

Information to be kept for all closed-vent systems and control devices:
 •  detailed schematics, design specifications, and piping and instrumentation diagrams
 •  dates and descriptions of any changes in design specifications
 •  description of parameters) to be monitored to ensure proper operation and maintenance
 »  explanation of selected parameters)
 •  periods of non-operation according to design
 •  dates of startups and shutdown
 »  list of ID numbers of subject closed-vent systems and control devices
 •  list of ID numbers of closed-vent systems and control devices designated for no detectable
    emissions and signed by owner/operator
 •  for each compliance test for closed-vent systems and control devices designated for no detectable
    emissions
    • •  date conducted
    • •  background level measured
    « •  maximum instrument reading
 «  list of ID numbers for closed-vent systems and control devices in vacuum service

Information and data used to demonstrate that equipment is not in organic HAP service or is in HAP
service fewer than 300 hours/year
                                CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                                                                                   page C-53

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                   CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                                      APPLICABLE REGULATIONS
 40 CFR Pan 60
  Subpart DDD
40CFRPart60,
 Subpart GOG
40CFRPart60,
 Subpart KKK
40CFRPart60,
 Subpart QQQ
40 CFR Part 63
  Subpart CC
   (existing)
40 CFR Part 63,
  Subpart CC
(existing or new)
     HEM
                                  REQUIREMENTS
Reporting
Requirements
Initial semiannual report:
 •  process unit identification

Subsequent semiannual reports:
 •  process unit identification
 »  dates of process unit shutdowns that occurred within the semiannual repsrting period
 «  revisions to items reported in the initial semiannual report if changes have occurred since the
    initial semiannual report or subsequent revisions to the initial semiannual report
 «  report of all performance tests in accordance with §60.8
                             CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                                                                             page C-54

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  COMPRESSORS
APPLICABLE REGULATIONS
40 CFR Part 60
Subpart DDD

40 CFR Part 60,
Subpart GGG

40 CFR Part 60,
Subpart KKK

40 CFR Part
Subpart QQ

                             40 CFR Part 63,
                               Subpart CC
                               (existing)
40 CFR Part 63,
  Subpart CC
(existing or new)
ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
REQUIREMENTS
Equipped with compliant seal system that prevents leakage to atmosphere
Install sensor to detect failure of seal system
Check sensor daily or equip with audible alarm
Establish criteria basic standard that indicates failure of seal system or barrier fluid system
or both
Sensor indicates failure of seal or barrier fluid system or both based on established criteria.

Equivalent means of emission limitation
No detectable emissions, operate less than 500 ppm above background
Closed-vent system and control device
40 CFR 63, Subpart H

Equipment in vacuum service
Reciprocating compressors that meet certain criteria
Compressors in hydrogen service
Reciprocating compressors exempt from seal requirements if recasting the distance pieces or
compressor replacement is required
Sensor alarm or visual check
First attempt within 5 calendar days of detection
Repair as soon as practicable; no later than 15 calendar days after detection
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in VOC service
      COMPRESSORS
       page C-55

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                                             COMPRESSORS
                                           APPLICABLE REGULATIONS
40 CFR Part 60
Subptrt ODD

40 CFR Part 60,
Subpan GGG

40 CFR Part 60,
Subpart KKK

40 CFR Part (
Subpart QQ(

                                                                            40 CFR Part 63,
                                                                              Subpart CC
                                                                               (existing)
                                                                            40 CFR Part 63,
                                                                              Subpart CC
                                                                            (existing or new)
      ITEM
                                     REQUIREMENTS
Recordkeeping
Requirements
When leak detected:
  •  a weather-proof and readily visible identification, marked with the equipment ID number,
    attached to the leaking equipment
  •  ID may be removed after it has been repaired

Information to be kept in log for 5 years after leak detected:
  •  instrument and operator ID number and equipment ID number
  •  date leak detected
  •  dates of each attempt to repair leak
  •  repair methods applied in each attempt to repair
  •  "above 10,000" if maximum instrument reading after each repair attempi: is J>. 10,000 ppm
  •  "repair delayed" and reason for delay is leak not repaired within 15 calendar days after detection
  •  signature of owner/operator whose decision it was that repair could not tie effected without a
    process shutdown
  •  expected  date of successful repair if leak is not repaired with the 15 days
  •  dates of process unit shutdown that occurred while the equipment is unrepaired
  •  date of successful repair of the leak

Information to be kept for all compressors:
  •  list of ID numbers of subject compressors
  •  list of ID numbers of compressors designated for no detectable emissions; and signed by
    owner/operator
  •  for each compliance test for compressors designated for no detectable emissions:
    • •  date conducted
    • •  background level measured
    • •  maximum instrument reading
  •  list of ID numbers for compressors in vacuum service
  •  information and data demonstrating hydrogen service
Reporting
Requirements
Initial semiannual report:
 •  process unit identification
 •  number of compressors, excluding those designated for no detectable emissions

Subsequent semiannual reports:
 •  The following information by month in the reporting period:
    • •  process unit identification
    • •  number of compressors for which leaks were detected
    • •  number of compressors for which leaks were not repaired within 15 days after detection
    • •  the facts that explain each delay of repair, and where appropriate, why a process unit
        shutdown was technically infeasible
 •  Information and data used to demonstrate that a compressor is not in HAP service, is in HAP
    service fewer than 300 hours/year, or is in hydrogen service.
 •  Dates of process unit shutdowns that occurred within the semiannual reporting period
 •  Revisions to items reported in the initial semiannual report if changes  have occurred since the
    initial semiannual report or subsequent revisions to the initial semiannual report
 •  Report of all performance tests in accordance with §60.8.
                                                 COMPRESSORS
                                                                                    page C-56

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DUAL MECHANICAL SEAL SYSTEM
           APPLICABLE REGULATIONS
40 CFR Part 60
Subpart ODD

40 CFR Part 60,
Subpart GOG

40 CFR Part 60,
Subpart KKK

40 CFR Part 6
Subpart QQ<

                                        40 CFR Part 63,
                                          Subpart CC
                                           (existing)
40 CFR Part 63,
  Subpart CC
(existing or new)
ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
REQUIREMENTS
For each dual mechanical seal system:
• operate the barrier fluid at a pressure that is at all times greater than the pump stuffing box
pressure, or
• connect the barrier fluid degassing reservoir by a closed-vent system to a control device, or
• equip with a system that purges the barrier fluid into a process stream with zero VHAP
emissions to the atmosphere
For all dual mechanical seal systems:
• the barrier fluid system shall be in heavy liquid service or not in VOC service
* equip each barrier fluid system with a sensor
• • check each sensor daily or equip with audible alarm
• • determine criterion that indicates failure of the seal system, the barrier fluid system, or both
» perform weekly visual inspections for indications of liquids dripping from the pump seals
Indications of liquids dripping from the pump seal; sensor
Applies as an alternative standard to: Pumps in Light Liquid Service
N/A
Visual, sensor
First attempt within 5 calendar days of detection
Repair as soon as practicable; no later than 15 days after detection
If repair requires use of a DMS that includes a barrier fluid system and repair is completed as soon as
practicable but no later than 6 months after leak detected
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in VOC service
       DUAL MECHANICAL SEAL SYSTEM
        page C-57

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                              DUAL MECHANICAL SEAL SYSTEM
                                         APPLICABLE REGULATIONS
  40 CFR Pan 60
  Subpart DDD
40 CFR Part 60,
 Subpart GGG
40 CFR Part 60,
 Subpart KKK
40 CFR Pan 60,
 Subpart QQQ
40 CFR Pan 63,
  Subpart CC
   (existing)
40 CFR Part 63,
  Subpart CC
(existing or new)
     mat
                                    REQUIREMENTS
Recordkeeping
Requirements
Information to be kept in log for 5 years after leak detected:
 •  instrument and operator ID number and equipment ID number
 «  date leak detected
 •  dates of each attempt to repair leak
 «  repair methods applied in each attempt to repair
 »  "above 10,000" if maximum instrument reading after each repair attempl is „>, 10,000 ppm
 •  "repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection
 •  signature of owner/operator whose decision it was that repair could not be effected without a
    process shutdown
 »  expected date of successful repair if leak is not repaired within the 15 days
 »  dates of process unit shutdown that occurred while the equipment  is unrepaired
 »  date of successful repair of the leak

Information to be kept for all dual mechanical seal systems:
 •  list of ID numbers of pumps with dual mechanical seal systems
 *  list of ID numbers designated for no detectable emissions and signed by owner/operator
Reporting
Requirements
Initial semiannual report:
 •  process unit identification

Subsequent semiannual reports:
 »  the following information by month in the reporting period:
    • «  process unit identification
    • •  the facts that explain each delay of repair, and where appropriate, why a process unit
        shutdown was technically infeasible
 •  dates of process unit shutdowns that occurred within the semiannual reporting period
 •  revisions to items reported in the initial semiannual report if changes have occurred since the
    initial semiannual report or subsequent revisions to the initial semiannual report
 »  report of all performance tests in accordance with §60.8
                                      DUAL MECHANICAL SEAL SYSTEM
                                                                                                     page C-58

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NO DETECTABLE EMISSIONS
      APPLICABLE REGULATIONS
40 CFR Part 60
Subpart ODD

40 CFR Part 60,
Subpart GGG

40 CFR Part 60,
Subpart KKK

40 CFR Part
Subpart QQ

                                 40 CFR Part 63,
                                   Subpart CC
                                   (existing)
40 CFR Part 63,
  Subpart CC
(existing or new)
ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
Recordkeeping
Requirements
Reporting
Requirements
REQUIREMENTS
An instrument reading of less than 500 ppm above background as measured by the methods specified
in §60.485(c)
Demonstrate compliance initially upon designation and test annually
500 ppm
Applies as an alternate standard to:
• pumps in light liquid service (must have no externally actuated shaft penetrating the pump
housing)
• valves in gas/vapor service or in light liquid service (must have no external actuating mechanism
in contact with the process fluid)
Applies as regulated standard for:
• closed vent systems
» pressure relief devices in gas/vapor service
N/A
Method 21
N/A
N/A
Information to be kept:
« list of ED numbers of equipment designated for no detectable emission and signed by
owner/operator
• for each compliance test for no detectable emission
* • date conducted
* • background level measured
» • maximum instrument reading
Subsequent semiannual reports:
* dates of process unit shutdowns that occurred within the semi-annual reporting period
• revisions to items reported in the initial semiannual report if changes have occurred since the
initial semiannual report or subsequent revisions to the initial semiannual report
» report of all performance tests in accordance with §60.8
      NO DETECTABLE EMISSIONS
       page C-59

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                          OPEN-ENDED VALVES OR LINES
                                  APPLICABLE REGULATIONS
40CERP«t60
 Subpart ODD
40 CFR Part 60,
 Subpart GOG
40 CFR Part 60,
 Subpart KKK
40 CFR Part 60,
 Subpart QQQ
40 CFR Part 63,
  Subpart CC
  (existing)
40 CFR Part 63,
  Subpart CC
(existing or new)
ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
Reeordkeeping
Requirements
Reporting
Requirements
REQUIREMENTS
Use cap, blind flange, plug, or second valve to seal open end at all times except when operations
require flow through open end
Second valve - close valve on process fluid end prior to closing second valves
Double block and bleed system may remain open during operations but comply with basic standard at
all other times
N/A
40 CFR 63, Subpart H
Equipment in vacuum service
N/A
N/A
N/A
Information to be kept for all open-ended valves or lines
* list of ID number of subject open-ended valves or lines
Information and data used to demonstrate that equipment is not in organic HAP service or is in HAP
service fewer than 300 hours per year
Initial semiannual report;
» process unit identification
Subsequent semiannual reports:
• process unit ID
» revisions to items reported in the initial semiannual report if changes have occurred since the
initial semiannual report or subsequent revisions to the initial semiannual report
                                OPEN-ENDED VALVES OR LINES
                                                                      page C-60

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PRESSURE RELIEF DEVICES IN GAS/VAPOR SERVICE
                 APPLICABLE REGULATIONS
40CFRPart60
Subpart ODD

40CFRPart60, 40CFRPart60, 40 CFR Part 60, 40 CFR
SnbpattGGG Subpart KKK Subpart QQQ Subpa
(exis
Part 63, 40 CFR Part 63,
it CC Subpart CC
ting) {existing or new)
•^

ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
Recordkeeping
Requirements
REQUIREMENTS
No detectable emissions (less than 500 ppm above background)
After each release return to no detectable emissions within 5 calendar days as indicated by monitoring
of the pressure relief device
500 ppm


Equivalent means of emission limitation
Pressure relief device equipment with compliant closed-vent system and control device
40 CFR 63, Subpart H
Equipment in vacuum service
Method 21
N/A
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in VOC service
Information to be kept for all pressure relief devices:
• list of ID numbers of pressure relief devices required to comply
• for each compliance test for pressure relief devices designated for
« • dates conducted
» • background level measured
* • maximum instrument reading
« list of ID numbers for pressure relief devices in vacuum service
Information and data used to demonstrate that a pressure relief device
or is in HAP service fewer than 300 hours per year
no detectable emissions
is not in organic HAP service
         PRESSURE RELIEF DEVICES IN GAS/VAPOR SERVICE
page C-61

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                  PRESSURE RELIEF DEVICES IN GAS/VAPOR SERVICE
                                        APPLICABLE REGULATIONS
 40 CFR Part 60
  Subpart DDD
40 CFR Part 60,
 Subpart GGG
40 CFR Part 60,
 Subpart KKK
40 CFR Part 60,
 Subpart QQQ
40 CFR Pan 63,
  Subpart CC
   (existing)
40 CFR Part 63,
  Subpart CC
(existing or new)
     ITEM
                                  REQUIREMENTS
Reporting
Requirements
Initial semiannual report:
 *  process unit ID for pressure relief devices

Subsequent semiannual reports:
 »  process unit identification
 *  the facts that explain each delay of repair, and where appropriate, why a process unit shutdown
    was technically infeasible
 *  dates of process unit shutdowns that occurred within the semiannual reporting period
 »  revisions to items reported in the initial semiannual report if changes have occurred since the
    initial semiannual report or subsequent revisions to the initial semiannual report
 •  report of all performance tests in accordance with §60.8.
                             PRESSURE RELIEF DEVICES IN GAS/VAPOR SERVICE
                                                                              page C-62

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            PUMPS AND VALVES IN HEAVY LIQUID SERVICE, PRESSURE
                RELIEF DEVICES IN LIGHT LIQUID OR HEAVY LIQUID
                 SERVICE, AND FLANGES AND OTHER CONNECTORS
                                       APPLICABLE REGULATIONS
40 CFR Part €0
Subpart DDD

40 CFR Part 60,
Subpart GGG

40 CFR Part 60,
Subpart KKK

40 CFR Part (
Subpart QQ

                                                                      40 CFR Part 63,
                                                                       Subpart CC
                                                                        (existing)
                                                                      40 CFR Part 63,
                                                                        Subpart CC
                                                                      (existing or new)
     ITEM
                                  REQUIREMENTS
Basic Standard
Monitoring of potential leaks within 5 calendar days of detection if evidence of potential leak is found
by visual, audible, olfactory, or other detection method
Leak Definition
 10,000 ppm
Alternative
Standards
Equivalent means of emission limitation

40 CFR 63, Subpart H
Exemptions
Equipment in vacuum service
Monitoring
Method
Method 21
Repair
Requirements
 First attempt within 5 calendar days of detection

 Repair as soon as practicable; no later than 15 days after detection
Delay of Repair
 Allowed if technically infeasible without process unit shutdown; required before end of next process
 unit shutdown

 Allowed for equipment that is isolated from the process and that does not remain in VOC service.
Recordkeeping
Requirements
 When leak detected:
  • a weather-proof and readily visible identification, marked with the equipment ED number,
    attached to the leaking equipment
  • ID may be removed after it has been repaired

 Information to be kept in log for 5 years after leak detected:
  • instrument and operator ID number and equipment ID number
  * date leak detected
  • dates of each attempt to repair leak
  • repair methods applied in each attempt to repair
  • "above 10,000" if maximum instrument reading after each repair attempt is >_ 10,000 ppm
  • "repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection
  • signature of owner/operator whose decision it was that repair could not be affected without a
    process shutdown
  » expected date of successful repair if leak is not repaired within 15 days
  • dates of process unit shutdown that occurred while the equipment is unrepaired
  • date of successful repair of the leak

	(Continued on next page)	
             PUMPS AND VALVES IN HEAVY LIQUID SERVICE, PRESSURE RELIEF DEVICES IN LIGHT
                 LIQUID OR HEAVY LIQUID SERVICE, AND FLANGES AND OTHER CONNECTORS
                                                                              page C-63

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           PUMPS AND VALVES IN HEAVY LIQUID SERVICE, PRESSURE
                RELIEF DEVICES IN LIGHT LIQUID OR HEAVY LIQUID
                 SERVICE, AND FLANGES AND OTHER CONNECTORS
                                      APPLICABLE REGULATIONS
 40 CFR Part 60
  SubpwtDDD
40 CFR Part 60,
 Subpart GOG
40 CFR Pan 60,
 Subpart KKK
40 CFR Part 60,
 Subpart QQQ
40 CFR Part 63,
  Subpart CC
   (existing)
40 CFR Part 63,
  Subpart CC
(existing or new)
     ITEM
                                 REQUIREMENTS
Recordkeeping
Requirements
(continued)
Information to be kept for all equipment in these categories:
 •  list of ID numbers of subject equipment in these categories
 «  list of ID numbers for equipment in vacuum service

Information and data used to demonstrate that equipment is not in organic HAP service, or is in HAP
service fewer than 300 hours/year
Reporting
Requirements
Initial semiannual report:
 *  process unit identification
 •  declare selection of process unit or sourcewide basis for calculating percent leaking equipment

Subsequent semiannual reports:
 •  process unit identification
 •  the following information by month in the reporting period
    • • number of pumps and valves for which leaks were detected
    • • number of pumps and valves for which leaks were not repaired within 15 calendar days
    • • the facts that explain each delay of repair, and where appropriate, why a process unit
       shutdown was technically infeasible
 «  dates of process unit shutdowns that occurred within the semiannual reporting period
 «  revisions to items reported in the initial semiannual report if changes have occurred since the
    initial semiannual report or subsequent revisions to the initial semiannual report
 •  report of all performance tests in accordance with §60.8
            PUMPS AND VALVES IN HEAVY LIQUID SERVICE, PRESSURE RELIEF DEVICES IN LIGHT
                LIQUID OR HEAVY LIQUID SERVICE, AND FLANGES AND OTHER CONNECTORS
                                                                           page C-64

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                               PUMPS IN LIGHT LIQUID SERVICE

                                         APPLICABLE REGULATIONS
40 CFR Part 60
Subpart DDD

40 CFR Part 60,
Subpart GGG

40 CFR Part 60,
Subpart KKK

40 CFR Part <
Subpart QQ<

                                                                          40 CFR Part 63,
                                                                            Subpart CC
                                                                             (existing)
                                                                          40 CFR Part 63,
                                                                            Subpart CC
                                                                          (existing or new)
     ITEM
                                    REQUIREMENTS
Basic Standard
Monthly leak detection and repair

Weekly visual observation for leaks
Leak Definition
10,000 ppm

Indications of liquids dripping from pump seal
Alternative
Standards
Equivalent means of. emission limitation

Dual mechanical seal pumps (see Dual Mechanical Seals)

No detectable emissions (see No Detectable Emissions)

Closed-vent system and control device (see Closed-vent Systems and Control Devices)

40 CFR 63, Subpart H
Exemptions
Pumps in vacuum service

Reciprocating pumps exempt from §60.482 if recasting of distance piece or pump replacement is
required
Monitoring
Method
Method 21; no more the 1 cm from rotating shaft
Repair
Requirements
First attempt within 5 calendar days of detection

Repair as soon as practicable; no later than 15 days after detection
Delay of Repair
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown.

Allowed for equipment that is isolated from the process and that does not remain in VOC service

Allowed if repair requires use of a DMS that includes a barrier fluid system and repair is completed
as soon as practicable but not later than 6 months after leak detected
                                      PUMPS IN LIGHT LIQUID SERVICE
                                                                                  page C-65

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                                PUMPS IN LIGHT LIQUID SERVICE

                                          APPLICABLE REGULATIONS
4Q€F!FsnSG
SubjSrt DDD

40 CM Pan 60,
Subpart GGG

* CHI, Part 60,
Subpatt KKK

40 CFR Part
Subpart QQ

                                                                           40 CFR Pan 63,
                                                                             Subpart CC
                                                                              (existing)
                                                                           40 CPR Part 63t
                                                                             Subpart CC
                                                                           (existing or new)
      ITEM
                                     REQUIREMENTS
Recordkceping
Requirements
When leak detected:
  *  a weather-proof and readily visible identification, marked with the equipment ID number,
    attached to the leaking equipment
  «  ID may be removed after it has been repaired

Information to be kept in log for 5 years after leak detected:
  »  instrument and operator ID number and equipment ID number
  •  date leak detected
  •  dates of each attempt to repair leak
  »  repair methods applied in each attempt to repair
  •  "above 10,000" if maximum instrument reading after each repair attempt is .>. 10,000 ppm
  »  "repair delayed" and reason for delay is leak not repaired within 15 calendar days after detection
  »  signature of owner/operator whose decision it was that repair could not be effected without a
    process shutdown
  «  expected  date of successful repair if leak is not repaired with the 15 days
  »  dates of process unit shutdown that occurred while the equipment is unrepaired
  •  date of successful repair of the leak

Information to be kept for all pumps:
  •  list of ID numbers of subject pumps
  «  list of ID numbers of pumps designated for no detectable emissions and signed by
    owner/operator
  •  for each compliance test for pumps designated for no detectable emissions
    »•  date conducted
    • •  background level measured
    • •  maximum instrument reading

Information and data used to demonstrate that a pump is not in HAP service, is in HAP service fewer
than 300 hours/year, or is in heavy liquid service
Reporting
Requirements
Initial semiannual report:
  •  process unit identification
  »  number of pumps,,excluding those designated for no detectable emissions
  •  declare selection of process unit or source-wide basis for calculating percent leaking equipment

Subsequent semiannual reports:
  •  The following information by month in the reporting period:
    * •  process unit identification
    » •  number of pumps for which leaks were detected
    • •  number of pumps for which leaks were not repaired within 15 days after detection
    »•  the facts that  explain each delay of repair, and where appropriate, why a process unit
        shutdown was technically infeasible
  »  Dates of process unit shutdowns that occurred within the semiannual reporting period
  •  Revisions to items reported in the initial semiannual report if changes have occurred since the
    initial semiannual  report or subsequent revisions to the initial semiannual report
  •  Report of all performance tests in accordance with §60.8.
                                       PUMPS IN LIGHT LIQUID SERVICE
                                                                                    page C-66

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                         SAMPLING CONNECTION SYSTEMS
                                   APPLICABLE REGULATIONS
40 CFR Part 60
 Subpart DDD
40 CFR Part 60,
 Subpart GGO
40 CFR Part 60,
 Subpart KKK
40 CFR Part 60,
 Subpart QQQ
40 CFR Pan 63,
  Subpait CC
   (existing)
40 CFR Part 63,
  Subpart CC
(existing or new)
ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
Recordkeeping
Requirements
Reporting
Requirements
REQUIREMENTS
Equipped with closed-purged, closed-loop, or closed-vent system that: returns the fluid to the
process, or recycles the purged fluid to a process, or sends it to a complaint control device
N/A
40 CFR 63, Subpart H
Equipment in vacuum service; in-situ sampling systems; and sampling systems without purges.
N/A
N/A
N/A
Information to be kept for all sampling connections
» list of ID numbers of subject sampling connection systems
Information and data used to demonstrate that equipment is not in organic HAP service, or is
service fewer than 300 hours/year.
in HAP
Initial semiannual report:
« process unit identification
Subsequent semiannual reports:
• process unit ID
• revisions to items reported in the initial semiannual report if changes have occurred since the
initial semiannual report or subsequent revisions to the initial semiannual report
                                 SAMPLING CONNECTION SYSTEMS
                                                                         page C-67

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             VALVES IN GAS/VAPOR AND LIGHT LIQUID SERVICE
                                APPLICABLE REGULATIONS
40 CFR Part 60
 Subpart DDD
40 CFR Pan 60,
 Subpart GOO
40 CFR Pan 60,
 Subpait KKK
40 CFR Pan 60,
 Subpait QQQ
40 CFR Part 63,
  Subpart CC
  (existing)
40 CFR Part 63,
  Subpart CC
(existing or new)
ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
REQUIREMENTS
Monthly leak detection and repair
If valve does not leak for 2 months, may be monitored quarterly
If valve leaks, monitor monthly until no leak is detected for 2 consecutive months
May use qualified monitoring data generated prior to August 15, 1995 to qualify for quarterly
monitoring
10,000 ppm

Equivalent means of emission limitation
No detectable emissions
Valves designated unsafe to monitor or difficult to monitor
Allowable percentage of valves leaking
40 CFR Part 63, Subpart H

Valves in vacuum service
Method 21
First attempt within 5 calendar days of detection
Repair as soon as practicable; no later than 15 days after detection
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in VOC service
Allowed if emissions of purged material from immediate repair would exceed fugitive emissions from
delay of repair, and purged materials are collected and destroyed or recovered in a control device
when repair occurs
Allowed beyond process unit shutdown if otherwise sufficient supply of valve assembly replacements
are exhausted
                       VALVES IN GAS/VAPOR AND LIGHT LIQUID SERVICE
                                                                  page C-68

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                  VALVES IN GAS/VAPOR AND LIGHT LIQUID SERVICE
                                          APPLICABLE REGULATIONS
40 CFR Part 60
Subpart ODD

40 CFR Part 60,
Subpart GOG

40 CFR Part 60,
Subpart KKK

40 CFR Part €
Subpart QQC

                                                                            40 CFR Part 63,
                                                                             Subpart CC
                                                                              (existing)
                                                                            40 CFR Part 63,
                                                                              Subpart CC
                                                                            (existing or new)
     ITEM
                                     REQUIREMENTS
Recordkeeping
Requirements
When leak detected:
  »  a weather-proof and readily visible identification, marked with the equipment ID number,
    attached to the leaking equipment
  «  ID may be removed after it has been repaired and monitored for 2 months with no leaks

Information to be kept in log for 5 years after leak detected:
  •  instrument and operator ID number and equipment ID number
  •  date leak detected
  •  dates of each attempt to repair leak
  «  repair methods applied in each attempt to repair
  •  "above 10,000" if maximum instrument reading after each repair attempt is _>. 10,000 ppm
  *  "repair delayed" and reason for delay is leak not repaired within 15 calendar days after detection
  •  signature of owner/operator whose decision it was that repair could not be effected without a
    process shutdown
  •  expected date of successful repair if leak is not  repaired with the 15 days
  »  dates of process unit shutdown that occurred while the equipment is unrepaired
  »  date of successful repair of the leak

Information to be kept for all valves:
  •  list of ID numbers of subject valves
  »  list of ID numbers of valves designated for no detectable emissions and signed by owner/operator
  •  for each compliance test for valves designated for no detectable emissions
    » •  date conducted
    « •  background level measured
    • •  maximum instrument reading
  •  list of ID numbers for valves  in vacuum service

Information and data used to demonstrate that a valve is not in organic HAP service,  is in HAP
service fewer than 300 hours/year, or is in heavy liquid service.
Reporting
Requirements
Initial semiannual report:
  • process unit identification
  • number of valves, excluding those designated for no detectable emissions
  » declare selection of process unit or sourcewide basis for calculating percent leaking equipment

Subsequent semiannual reports:
  • process unit identification
  » the following information by month in the reporting period:
    » •  number of valves for which leaks were detected
    * •  number of valves for which leaks were not repaired within 15 days after detection
    « »  the facts that explain each delay of repair, and where appropriate, why a process unit
         shutdown was technically infeasible
  * dates of process unit shutdowns that occurred within the semiannual reporting period
  • revisions to items reported in the initial semiannual report if changes have occurred since the
    initial semiannual report or subsequent revisions to the initial semiannual report
  » report of all performance tests in accordance with alternative standards
                               VALVES IN GAS/VAPOR AND LIGHT LIQUID SERVICE
                                                                                     page C-69

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               ALL CONNECTORS AND INSTRUMENTATION SYSTEMS;
                   PUMPS AND VALVES IN HEAVY LIQUID SERVICE;
                 AND PRESSURE RELIEF DEVICES IN LIQUID SERVICE
                                       APPLICABLE REGULATIONS
  40 CFR Pan 60
  Subpwrt DDD
40 CFR Part 60,
 Subpan GGG
40 CFR Part 60,
 Subpart KKK
40 CFR Part 60,
 Subpart QQQ
40 CFR Part 63,
  Subpan CC
   (existing)
40 CFR Part 63,
  Subpart CC
(existing or new)
     ITEM
                                  REQUIREMENTS
Basic Standard
Monitoring of potential leaks within 5 calendar days of detection if evidence of potential leak is found
by visual, audible, olfactory, or other detection method, unless repaired as discussed under "Other"
below
Leak Definition
Monitoring
  •  pumps - 2,000 ppm
  «  valves, connectors,  instrumentation systems - 1000 ppm
  «  pressure relief - 500 ppm

Other
  *  evidence of potential leak
Alternative
Standards
Equivalent means of emission limitation

Enclosed vented process units

Connectors in gas/vapor or light liquid service may comply with §63.649 instead
Exemptions
Equipment in vacuum service

Equipment operated fewer than 300 hours per year in organic HAP service

Reciprocating pumps in heavy liquid service
Monitoring
Method
Method 21, 40 CFR Part 60, Appendix A
 •  no more than 1 cm from rotating shaft
 •  response factor criteria (excluding inerts) for average composition of process fluid
 *  monitor all equipment while it is "in service"
Repair
Requirements
First attempt within 5 calendar days of detection

Repair as soon as practicable; no later than 15 days after detection
Delay of Repair
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown

Allowed for equipment that is isolated from the process and that does not remain in organic HAP
service
            ALL CONNECTORS AND INSTRUMENTATION SYSTEMS; PUMPS, VALVES, AND AGITATORS
                IN HEAVY LIQUID SERVICE; AND PRESSURE RELIEF DEVICES IN LIQUID SERVICE         page C-70

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               ALL CONNECTORS AND INSTRUMENTATION SYSTEMS;
                   PUMPS AND VALVES IN HEAVY LIQUID SERVICE;
                 AND PRESSURE RELIEF DEVICES IN LIQUID SERVICE
                                       APPLICABLE REGULATIONS
 40 CER Part 60
  Subpart ODD
 4QCFRPart60,
  Subpart GOO
40 CfS. Part 60,
 Subpart KKK
40 CER Part 60,
 Subpart QQQ
40 CFR Part 63,
  Subpart CC
   (existing)
40 CFR Part 63,
  Subpart CC
(existing or new)
     ITEM
                                   REQUIREMENTS
Recordkeeping
Requirements
When leak detected:
  » a weather-proof and readily visible identification, marked with the equipment ID number,
    attached to the leaking equipment
  « ID may be removed after it has been repaired, except valves
  • ID may be removed from valve after it has been monitored at least once within first 3 months of
    repair

Information to be kept in log for 5 years after leak detected:
  * instrument and equipment ID number and operator name, initials, and ID number
  • date leak detected
  • dates of each attempt to repair leak
  • maximum instrument reading after successful repair or determination the equipment is non-
    reparable
  • "repair delayed"  and reason for delay if leak not repaired within 15 calendar days after detection
  • dates of process unit shutdown that occurred while the equipment is unrepaired
  • date of successful repair of the leak

Information to be kept for all equipment
  • list of ID numbers of subject equipment
  • location of equipment on site plan, log entries, etc.
  • identify records by process unit and program, implemented
  » documentation and dates of visual inspections

Information and data  used to demonstrate that equipment is not in organic HAP service, is in HAP
service fewer than 300 hours/year, or is in heavy liquid service.
Reporting
Requirements
 Initial notification:
  • name and address of owner/operator
  * address of facility (physical location)
  • identification of subject processes
  * compliance statement
  • statement of whether a source can achieve compliance by the applicable compliance date

 Notification of compliance status:
  • process unit identification
  * number of each type of equipment (excluding those in vacuum service)
  » method of compliance (final choice to monitor valves due after Phase III compliance date)

	(Continued on next page)	
            ALL CONNECTORS AND INSTRUMENTATION SYSTEMS; PUMPS, VALVES, AND AGITATORS
                IN HEAVY LIQUID SERVICE; AND PRESSURE RELIEF DEVICES IN LIQUID SERVICE          page C-71

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              ALL CONNECTORS AND INSTRUMENTATION SYSTEMS;
                  PUMPS AND VALVES IN HEAVY LIQUID SERVICE;
                AND               RELIEF DEVICES IN LIQUID SERVICE
                                     APPLICABLE REGULATIONS
 40CFRl>«t60
  Subpart DDD
40CFRPart60,
 Subpart GGG
40 CFR Part 60,
 Subpart KKK
40 CFR Part 60,
 Subpart QQQ
40 CFR Part 63
  Subpart CC
  (existing)
40 CFR Part 63,
  Subpart CC
(existing or new)
     ITEM
                                REQUIREMENTS
Reporting
Requirements
(continual)
Subsequent semiannual reports:
 • process unit identification
 • the following information by month in the reporting period
   • • number of each type of equipment for which leaks were detected
   * • percent of pumps, valves, and connectors leaking
   • • total number of each type of equipment monitored
   • • number of each type of equipment for which leaks were not repaired within 15 days after
       detection
   • • the facts that explain each delay of repair, and where appropriate, -why a process unit
       shutdown was technically infeasible
 • dates of process unit shutdowns that occurred within the semiannual reporting period
 « revisions to items reported in the initial semiannual report if changes have occurred since the
   initial semiannual report or subsequent revisions to the initial semiannual report
           ALL CONNECTORS AND INSTRUMENTATION SYSTEMS; PUMPS, VALVES, AND AGITATORS
               IN HEAVY LIQUID SERVICE; AND PRESSURE RELIEF DEVICES IN LIQUID SERVICE          page C-72

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                  ALTERNATIVE MEANS OF EMISSION LIMITATIONS:
                            ENCLOSED-VENTED PROCESS UNITS
                                       APPLICABLE REGULATIONS
 40 CFR Part 60
  Subpart ODD
40 CFR Part 60,
 Subpart GGG
40 CFR Part 60,
 Subpart KKK
40 CFR Part 60,
 Subpart QQQ
40 CFR Part 63,
  Subpart CC
   (existing)
40 CFR Part 63,
  Subpart CC
(existing or new)
     ITEM
                                   REQUIREMENTS
Basic Standard
Process units enclosed in such a manner that all emissions from equipment leaks are vented through a
closed-vent system to a control device. The enclosures shall be maintained under negative pressure at
all times the process unit is in operation
Recordkeeping
Requirements
Owner/operators shall maintain the following records:
 •  ID numbers of the process units and the organic HAP's they handle
 •  a schematic of the process unit, enclosure, and closed vent system
 «  a description of the system used to create a negative pressure in the enclosure to ensure that all
    emissions are routed to the control device
Reporting
Requirements
Initial notification:
 *  name and address of owner/operator
 •  address of facility (physical location)
 •  identification of subject processes
 «  compliance statement
 »  statement of whether a source can achieve compliance by the applicable compliance date

Notification of compliance status:
 »  process unit identification
 »  description of the system used to create a negative pressure in the enclosure and the control
    device used
                             ALTERNATIVE MEANS OF EMISSION LIMITATIONS:
                                    ENCLOSED-VENTED PROCESS UNITS
                                                                               page C-73

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CLOSED-VENT SYSTEMS AND CONTROL DEVICES
              APPLICABLE REGULATIONS
40CFRP»rt6Q
Stibpan ODD

40CFRPart60, 40CFRPart6Q, 40CFRPart60, 40CFRPart63,
SubpartGGG SubpartKKK SubpartQQQ SubpartCC
(existing)


HEM
Basic Standard
Leak Definition
Applicability
Exemptions
Monitoring
Method
40 CFR Part 63,
Subpart CC
(existing or new)
•••
REQUIREMENTS
Control Devices
Vapor recovery systems: 95 percent or greater recovery
Combustion devices: 95% or more reduction, or minimum residence time and temperature of
0.50 seconds & 760° C
Flares: Comply with §63.1 l(b)
Closed-Vent Systems
Initial and annual inspection requirements:
• hard piping construction: initial inspection per Method 21, annual visual inspections
• duct work construction: initial and annual inspections per Method 21
Control devices and closed-vent systems (CD/CVS): operate whenever emissions may be vented to
them
Monitoring
Monitor control devices to ensure operated & maintained in conformance with design specifications
If contain by-pass lines, monitor closed-vent systems with (1) vent stream flow meters or
(2) secure with car-seal or lock-and-key type locks with monthly visual inspection
"Unsafe-to-monitor" parts: inspect as frequently as practicable, but no more than annually
"Difficult-to-monitor" parts: inspect at least once every 5 years
500 ppm
Visual inspections
Applicable as alternative standard for: pumps in light liquid service, compressors, pressure relief
devices in gas/vapor service, sampling connection systems, surge control vessels, bottoms receivers,
and agitators in gas/vapor and light liquid service
Equipment in vacuum service
Equipment in organic HAP service fewer than 300 hours per year
Equipment needed for safety purposes exempt from monitoring requirement!?
Method 21
• Response factor criteria (excluding inerts) for average composition of p rocess fluid
• Monitor all equipment while it is "in service"
        CLOSED-VENT SYSTEMS AND CONTROL DEVICES
page C-74

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                    CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                                         APPLICABLE REGULATIONS
40 CFR Part 60
Subpart ODD

40 CFR Part 60,
Subpart GOG

40 CFR Part 60,
Subpart KKK

40 CFR Part 60,
Subpart QQQ

40 CFR Part 63,
Subpart CC
(existing)

                                                                                              40 CFR Part 63,
                                                                                                Subpart CC
                                                                                              (existing or new)
     ITEM
                                    REQUIREMENTS
Repair
Requirements
First attempt within 5 calendar days of detection

Repair as soon as practicable; no later than 15 days after detection
Delay of Repair
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown

Allowed if emissions of purged material from immediate repair would exceed fugitive emissions from
delay of repair
Recordkeeping
Requirements
When leak detected:
 •  a weather-proof and readily visible identification, marked with the equipment ID number,
    attached to the leaking equipment
 •  ID may be removed after equipment it has been repaired

Information to be kept in log for 5 years after leak detected:
 «  instrument and equipment ID number and operator name, initials, and ID number
 •  date leak detected
 «  date of first attempt to repair leak
 •  maximum instrument reading after successful repair or if determined to be non-reparable
 •  "repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection
 «  dates of process unit shutdown that occurred while the equipment is unrepaired
 •  date of successful repair of the leak

Information to be kept for all closed-vent systems and control devices:
 *  list of ID numbers of subject equipment
 •  location of equipment on site plan, log entries, etc,
 •  list of ID numbers for components equipped with CVS/CD
 «  ID of surge control vessels and bottoms receivers equipped with CVS/CD
 •  documentation of visual inspections
 «  Design specifications (retain for life of equipment)
    • •  design specifications and performance demonstrations to include detailed schematics and
        piping and instrumentation diagrams
    * •  dates and descriptions of any  changes in the design specifications
    * •  flare design  and results of compliance demonstration
    « •  description and explanation of control device monitoring parameters
 •  Records of operation (retain for 5  years)
    « •  dates and durations when CVS/CD are not operated as designed (includes lack of flame in
        flare pilot light
    • •  dates and durations of start-ups and shutdowns of control devices
 *  Records of inspections (retain for 5 years)
    • •  if no leaks detected: record date and fact of inspection and statement no leaks detected
    « •  if leaks detected: information specified previously

Information and data used to demonstrate that a CVS/CD is not in organic HAP service or is in HAP
service fewer than 300 hours/year
                                CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                                                                                    page C-75

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                   CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                                        APPLICABLE REGULATIONS
  40 CFR Pan 60
  Subpart DDD
40 CFR Part 60,
 Subpart GGG
40 CFR Part 60,
 Subpart KKK
40 CFR Part 60,
 Subpart QQQ
40 CFR Part 63,
  Subpart CC
  (existing)
40 CFR Part 63,
  Subpart CC
(existing or new)
     HEM
                                  REQUIREMENTS
Reporting
Requirements
Initial notification:
 »  name and address of owner/operator
 »  address of facility (physical location)
 •  identification of subject processes
 •  compliance statement
 •  statement of whether a source can achieve compliance by the applicable compliance date

 Notification of compliance status:
 •  process unit identification
 «  number of CVS/CD, excluding those in vacuum service
 »  method of compliance

Subsequent semiannual reports:
 •  process unit identification
 »  the facts that explain any delay of repairs
 »  the results of all monitoring of closed-vent systems or of control devices
 •  dates of process unit shutdowns that occurred within the semiannual reporting period
 »  revisions to items reported in the initial semiannual report if changes have occurred since the
    initial semiannual report or subsequent revisions to the initial semiannual report
                              CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                                                                               page C-76

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  COMPRESSORS
APPLICABLE REGULATIONS
40 CFR Part 60
Subpart ODD

40eFRPart60, 40CFRPart60, 4QCFRPart6G, 40CFRPart63,
Subpart GGG Subpart KKK Subpart QQQ Subpart CC
(existing)


ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
40 CFR Part 63,
Subpart CC
(existing or new)
REQUIREMENTS
Equip with compliant seal system that prevents leakage to atmosphere
Install sensor to detect failure of seal system
Check sensor daily or equip with audible alarm that is checked monthly; if at unmanned plant site,
check daily
Establish criteria that indicates failure of seal system or barrier fluid system or both
Sensor indicates failure of seal or barrier fluid system or both based on established criteria

Equivalent means of emission limitation
Compressors designated to operate at less than 500 ppm
Closed-vent system; return to process or to control device (CVS)
Enclosed-vented process units

Compressors in vacuum service
Compressors in hydrogen service
Compressors operated fewer than 300 hours per year in organic HAP services
Reciprocating compressors exempt from seal requirements if recasting distance pieces or compressor
replacement is required
Daily observation of sensors or use of sensor alarm system
First attempt within 5 calendar days of detection
Repair as soon as practicable; no later than 15 calendar days after detection
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in organic HAP
service
     COMPRESSORS
                                              page C-77

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                                            COMPRESSORS
                                          APPLICABLE REGULATIONS
40 CFR Part 60
Subpart DDD

40 CFR Part 60,
Subpait GOG

40 CFR Part 60,
Subpart KKK

40 CFR Part 60,
Subpart QQQ

40 CFR Part 63,
Subpart CC
(existing)

                                                                                              40 CFR Part 63,
                                                                                                Subpart CC
                                                                                              (existing or new)
     ITEM
                                     REQUIREMENTS
Recordkeeping
Requirements
 When leak detected:
  «  a weather-proof and readily visible identification, marked with the equipment ID number,
     attached to the leaking equipment
  *  ID may be removed after it has been repaired

 Information to be kept in log for 5 years after leak detected:
  *  instrument and equipment ID number and operator name, initials, aad ED number
  •  date leak detected
  •  date of first attempt to repair leak
  •  maximum instrument reading after successful repair or determination to be non-reparable
  •  "repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection
  •  dates of process unit shutdowns that occurred while the equipment is unrepaired
  *  date of successful repair of the leak

 Information to be kept for all compressors:
  «  list of ID numbers of subject compressors
  •  location of compressor on site plan, log entries, etc.
  •  list of ID numbers of compressors equipped with CVS
  •  list of ID numbers of compressors designated to operate at less than 500 ppm
  •  identify records by process unit and program implemented for each pump
  «  documentation and dates of visual inspections
  •  for each compliance test for compressors designated to operate at less than 500 ppm
     • «  date conducted
     » •  background level measured
     « •  maximum instrument reading

 Information and data used to demonstrate that a compressor is not in organic HAP service, is in
 HAP service fewer than 300 hours/year, or is in hydrogen service
Reporting
Requirements
 Notification of compliance status:
  •  process unit identification
  «  number of compressors (excluding those in vacuum service)
  •  method of compliance

 Initial notification:
  •  name and address of owner/operator
  »  address of facility (physical location)
  •  identification of subject processes
  «  compliance statement
  »  statement of whether a source can achieve compliance by the applicable compliance date

	             (Continued on next page)	
                                                COMPRESSORS
                                                                                    page C-78

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                                            COMPRESSORS
                                         APPLICABLE REGULATIONS
 40 CFR Part 60
  Subpart DDD
40 CFR Part 60,
 Subpart GOO
40 CFR Part 60,
 Subpart KKK
40 CFR Part 60,
 Subpart QQQ
40 CFR Part 63,
  Subpart CC
   (existing)
40 CFR Part 63,
  Subpart CC
(existing or new)
     ITEM
                                    REQUIREMENTS
Reporting
Requirements
(continued)
Subsequent semiannual reports:
  •  process unit identification
  •  the following information for each monitoring period in the reporting period:
    * • number of compressors for which leaks were detected
    • » number of compressors for which leaks were not repaired within 15 days after detection
    • • the facts that explain each delay of repair, and where appropriate, why a process unit
        shutdown was technically infeasible
  •  results of monitoring for compressors designated to operate at less than 500 ppm
  *  dates of process unit shutdowns that occurred within the semiannual reporting period
  «  revisions to items reported in the initial compliance notice if changes have occurred since the
    initial semiannual report or subsequent revisions to the initial semiannual report
                                               COMPRESSORS
                                                                                                      page C-79

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                                       CONNECTORS
                                    APPLICABLE REGULATIONS
40 CFR Pan 60
 Subpart ODD
40 CFR Part 60,
 Subpart GGG
40 CFR Part 60,
 Subpart KKK
40 CFR Pan 60,
 Subpart QQQ
40 CFR Part 63,
  Subpart CC
   (existing)
40 CFR Part 63,
  Subpart CC
(existing or new)
ITEM
Basic Standard

























Leak Definition


Alternative
Standards
REQUIREMENTS
NOTE: The following applies only to units opting to comply with §63.649.
Option 1: Random 200 Connector Alternative
• Initial monitoring of 200 randomly selected connectors within first 12 months
• Monitor each repaired leak within 3 months
« Subsequent monitoring required based on percent leaking connectors:
Percent Leaking Frequency
_>_ 2.0 semiannual
< 2 annual
< 1 every 2 years
< 0.5 every 4 years
« Identify by area or length of pipe; physical tagging and individual component identification is not
required.
Option 2: Connector Inspection Alternative
• For all connectors >2 inches in diameter, monitor if in gas/vapor service and inspect if in light
liquid service within 12 months after compliance date. Excludes inaccessible and unsafe-to-
monitor connectors.
« Monitor/inspect each repaired leak within 3 months
* Subsequent monitoring required based on percent leaking connectors:
Percent Leaking Frequency
.>. 2.0 annual
< 2 every 2 years
< 1 every 4 years
Equation to calculate percent leaking provided.
Cannot combine gas/vapor and light liquid to calculate percent leaking.
Identify by area or length of pipe; physical tagging and individual component identification is not
required.
Option 1: l.OOOppm
Option 2: gas/vapor service - 1,000 ppm
light liquid service - 3 drips per minute
Comply with §63.174 of Subpart H, 40 CFR Part 63.

                                          CONNECTORS
                                                                          page C-80

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  CONNECTORS
APPLICABLE REGULATIONS
40 CFR Pan 60
Subpart DDD

40 CFR Part 60, 40 CFR Part 60, 40 CFR Pan 60, 40 CFR Part 63, 40 CFR Part 63,
Subpart GGG Subpart KKK Subpart QQQ Subpart CC Subpart CC
(existing) (existing or new)
HBHMl

ITEM
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
Recordkeeping
Requirements
Reporting
Requirements
REQUIREMENTS
Equipment in vacuum service.
Equipment operated fewer than 300 hours per year.
Inaccessible connectors (as defined in §63.174).
Unsafe-to-monitor connectors (as defined in §63.174).
Method 21, 40 CFR Part 60, Appendix A
Repair as soon as practicable, but no later than 15 calendar days after detection.
First attempt to repair within 5 calendar days of detection.
Allowed if repair is technically infeasible by normal repair techniques without a process unit
shutdown.
Repair to occur before end of next process unit shutdown.
Allowed for equipment isolated from the process and that does not remain in organic HAP service,
Also allowed if emissions from purged material resulting from immediate repair would be greater
than from delay of repair and, when repair is effected, the purged material is collected and destroyed
or recovered in a control device.
Document that all connector monitoring and inspections have occurred.
Document repair of leaking connectors as applicable.
Initial notification:
» name and address of owner/operator
• address of facility (physical location)
• identification of subject processes
« compliance statement
• statement of whether a source can achieve compliance by the applicable compliance date
Notification of compliance status:
» process unit identification
• number of connectors, excluding those in vacuum service
• method of compliance
(Continued on next page)
     CONNECTORS
page C-81

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                                            CONNECTORS
                                         APPLICABLE REGULATIONS
  40 CFR Part 60
  Subpart DDD
40 CFR Part 60,
 Subpart GGG
40 CFR Part 60,
 Subpait KKK
40 CFR Part 60,
 Subpart QQQ
40 CFR Part 63,
  Subpart CC
   (existing)
40 CFR Part 63,
  Subpart CC
(existing or new)
     ITEM
                                    REQUIREMENTS
Reporting
Requirements
(continued)
Subsequent semiannual reports:
 «  process unit identification
 •  the following information for each monitoring period in the reporting period:
    » •  number of connectors for which leaks were detected
    * •  total number of connectors monitored
    » •  the percent leakers for connectors
    • •  number of connectors for which leaks were not repaired within 15 days after detection
    • •  identification of the number of connectors determined to be non-reparable
    « •  explanation of why repairs delayed and why a process unit shutdown was infeasible
 •  dates of process unit shutdowns that occurred within the semiannual reporting period
 •  revisions to items reported in the initial semiannual report if changes have occurred since the
    initial semiannual report or subsequent revisions to the initial semiannual report
                                                CONNECTORS
                                                                                   page C-82

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DUAL MECHANICAL SEAL SYSTEM
         APPLICABLE REGULATIONS
40CFRPart60
Subpart ODD

40 CFR Part 60,
Subpart GGG

40 CFR Part 60,
Subpart KKK

40 CFR Part 60,
Subpart QQQ

40 CFR Part 63,
Subpait CC
(existing)

                                                 40 CFR Part 63,
                                                  Subpart CC
                                                 (existing or new)
ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
REQUIREMENTS
For each dual mechanical seal system:
• operate the barrier fluid at a pressure that is at all times greater than the pump stuffing box
pressure, or
• equip with a barrier fluid degassing reservoir that is connected by a closed-vent system to a
control device, or
• equip with a closed-loop system that purges the barrier fluid into a process stream
For all dual mechanical seal systems:
• the barrier fluid system is not in light liquid service
• barrier fluid system is equipped with a sensor
• • check each sensor daily or equip with audible alarm
« • determine criterion that indicates failure of the seal system, the barrier fluid system, or both
• perform weekly visual inspections for indications of liquid dripping from the pump seals,
monitor if indications observed
Indications of liquids dripping from the pump seal; sensor criteria; instrument reading of 1000 ppm
Applies as an alternative standard to: Pumps in Light Liquid Service and Agitators in Gas/Vapor
Service and in Light Liquid Service
NA
Visual, sensor
First attempt within 5 calendar days of detection
Repair as soon as practicable; no later than 15 days after leak is detected
Allowed if repair requires replacing the existing seal design with a new system that meets improved
performance criterion
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in organic HAP
service
      DUAL MECHANICAL SEAL SYSTEM
page C-83

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                              DUAL MECHANICAL SEAL SYSTEM
                                          APPLICABLE REGULATIONS
40 CFR Part 60
Subpart ODD

40 CFR Part 60,
Subpart GGG

40 CFR Part 60,
Subpart HOC

40 CFR Part 60,
Subpart QQQ

40 CFR Part 63,
Subpart CC
(existing)

                                                                                              40 CFR Part 63,
                                                                                                Subpart CC
                                                                                              (existing or new)
      ITEM
                                     REQUIREMENTS
Reeordkeeping
Requirements
Information to be kept in log for 5 years after leak detected:
  «  instrument and equipment ID number, and operator name, initials, and ID number
  »  date leak detected
  *  dates of each attempt to repair leak
  •  maximum instrument reading after successful repair or determined to be non-reparable
  •  "repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection
  •  copies of periodic reports (if database not capable of generating such)
  •  expected date of successful repair if leak is not repaired within the 15 days
  »  dates of process unit shutdown that occurred while the equipment is unrepaired
  *  date of successful repair of the leak

Information to be kept for all dual mechanical seal systems:
  •  list of ID numbers of dual mechanical seal systems
  •  ID of instrumentation systems
Reporting
Requirements
Initial notification:
  •  name and address of owner/operator
  •  address of facility (physical location)
  •  identification of subject processes
  •  compliance statement
  »  statement of whether a source can achieve compliance by the applicable compliance date

Notification of compliance status:
  •  process unit identification
  *  number of pumps (excluding those in vacuum service)
  *  method of compliance
  •  planned schedule for each phase of requirements

Subsequent semiannual reports:
  »  process unit identification
  •  the following information for each monitoring period in the reporting period:
    • • number of pumps for which leaks were detected
    • * percent of pumps leaking
    • • total number of pumps monitored
    * * number of pumps for which leaks were not repaired within 15 days after detection
    • • the facts that explain each delay of repair, and where appropriate, why a process unit
        shutdown was technically  infeasible
  •  dates of process unit shutdowns that occurred within the semiannual reporting period
  *  revisions to items reported in the initial compliance notice if changes have occurred since the
    initial semiannual report or subsequent revisions to the initial semiannual report
                                      DUAL MECHANICAL SEAL SYSTEM
                                                                                   page C-84

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OPEN-ENDED VALVES OR LINES
        APPLICABLE REGULATIONS
40 CFR Pan 60
Subpart DDD

40 CFR Pan 60,
Subpait GOG

40 CFR Part 60,
Subpart KKK

40 CFR Part 60,
Subpait QQQ

40 CFR Part 63,
Subpart CC
(existing)

                                                   40 CFR Part 63,
                                                    Subpart CC
                                                   (existing or new)
ITEM
Basic Standard
Leak Definition

Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
Recordkeeping
Requirements
Reporting
Requirements
REQUIREMENTS ,
Use cap, blind flange, plug, or second valve to seal open end at all times except when operations
require flow through open end
Second valve - close valve on process fluid end prior to closing second valve
Double block and bleed system may remain open during operations but comply with basic standard at
all other times
N/A

Equivalent means of emission limitation
Emergency shutdown system
N/A
N/A
N/A
Information to be kept for all open-ended valves or lines
• list of ID number of subject equipment
• location on site plan, log entries, etc.
Information and data used to demonstrate that equipment is not in organic HAP service or is in HAP
service fewer than 300 hours/year
Initial notification:
» name and address of owner/operator
• address of facility (physical location)
• identification of subject processes
« compliance statement
• statement of whether a source can achieve compliance by the applicable compliance date
(Continued on next page)
      OPEN-ENDED VALVES OR LINES
page C-85

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                               OPEN-ENDED VALVES OR LINES
                                        APPLICABLE REGULATIONS
 40CFRPatt60
  Subpart DDD
40 CFR Part 60,
 Subpart GOG
40 CFR Part 60,
 Subpart KKK
4QCFRPart60,
 Subpart QQQ
40 CFR Pan 63,
  Subpart CC
   (existing)
40 CFR Pan 63,
  Subpart CC
(existing or new)
     ITEM
                                   REQUIREMENTS
Reporting
Requirements
(continued)
 Notification of compliance status:
 «  process unit identification
 »  number of open-ended valves or lines (excluding those in vacuum service)
 *  method of compliance

Subsequent semiannual reports:
 »  process unit identification
 •  the following information for each monitoring period in the reporting period:
    « •  the facts that explain each deky of repair, and where appropriate, why a process unit
        shutdown was technically infeasible
 •  dates of process unit shutdowns that occurred within the semiannual reporting period
 «  revisions to items reported in the initial semiannual report if changes have occurred since the
    initial semiannual report or subsequent revisions to the initial semiannual! report
                                      OPEN-ENDED VALVES OR LINES
                                                                                page C-86

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PRESSURE RELIEF DEVICES IN GAS/VAPOR SERVICE
                 APPLICABLE REGULATIONS
40CFRPart60
Subpart DDD

40CFRPart60, 40CFRPart60, 40CERPart60, 40CFRPart63,
Subpart GGG Subpart KKK Subpart QQQ Subpart CC
(existing)


ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
Recordkeeping
Requirements
40 CFR Part 63,
Subpart CC
(existing or new)
•••!
REQUIREMENTS
Without rupture disk:
Operate at less than 500 ppm above background
Within 5 calendar days after each release, return to operating standard and monitor the pressure relief
device (PRO) to confirm
With rupture disk:
After each release, replace rupture disk within 5 calendar days
500 ppm
Equivalent means of emission limitation
Pressure relief device equipped with compliant closed-vent system and control device
Pressure relief device in vacuum service
Pressure relief device in organic HAP service fewer than 300 hours per year
Method 21
• Response factor criteria (excluding inerts) for average composition of process fluid
« Monitor all equipment while it is "in service"
See basic standard
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in organic HAP
service
Information to be kept for all pressure relief devices:
• list of ID numbers of pressure relief devices, and a list of ID numbers for pressure relief devices
equipped with rupture disks
• location of pressure relief devices on site plan, log entries, etc.
« list of ID numbers for pressure relief devices in vacuum service
• list of ID numbers for pressure relief devices equipped with closed-vent system and control
device
Information and data used to demonstrate that a pressure relief device is not in organic HAP service
or is in HAP service fewer than 300 hours/year
         PRESSURE RELIEF DEVICES IN GAS/VAPOR SERVICE
page C-87

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                                            DEVICES IN GAS/VAPOR SERVICE
                                         APPLICABLE REGULATIONS
  4QOFRPart60
   Subpart DDD
40 CFR Part 60,
 Subpatt GGO
40 CFR Part 60,
 Subpatt KKK
40 CFR Part 60,
 Subpatt QQQ
40 CFR Part 63,
  Subpait CC
   (existing)
40 CFR Part 63,
  Subpart CC
(existing or new)
     ITEM
                                    REQUIREMENTS
Reporting
Requirements
Initial notification:
 •  name and address of owner/operator
 •  address of facility (physical location)
 *  identification of subject processes
 •  compliance statement
 «  statement of whether a source can achieve compliance by the applicable compliance date

 Notification of compliance status:
 •  process unit identification
 »  number of pressure relief devices, excluding those in vacuum service
 »  method of compliance

Subsequent semiannual reports:
 •  process unit identification
 •  the following information by monitoring period in the reporting period
    » •  explanation of why repairs delayed and why a process unit shutdown was infeasible
 »  results of all monitoring to show compliance with the operating standard of less than 500 ppm
 *  dates of process unit shutdowns that occurred within the semiannual reporting period
 *  revisions to items reported in the initial semiannual report if changes have occurred since the
    initial semiannual report or subsequent revisions to the initial semiannual report
                              PRESSURE RELIEF DEVICES IN GAS/VAPOR SERVICE
                                                                                  page C-8

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                              PUMPS IN LIGHT LIQUID SERVICE
                                         APPLICABLE REGULATIONS
40 CFR Part 60
Subpart ODD

40 CFR Part 60,
Subpart OGO

40 CFR Part 60,
Subpart KKK

40 CFR Part 60,
Subpart QQQ

40 CFR Part 63,
Subpart CC
(existing)

                                                                                            40 CFR Part 63,
                                                                                              Subpart CC
                                                                                            (existing or new)
     ITEM
                                    REQUIREMENTS
Basic Standard
Monthly leak detection and repair

Weekly visual observation for leaks

At startup of new sources, comply with 63.163(a)(l)(ii)

Phase HI:
 *  If the greater of 10% or 3 pumps in process area leaks (6 month average), Quality Improvement
    Program (QIP) required
 »  If less than 10% or 3 pumps, monitor monthly
 •  If less than 3% or 1 pump, monitor quarterly
Leak Definition
Phase I:   10,000 ppm
Phase H:   5,000 ppm
Phase ffl:   2,000 ppm

Indications of liquids dripping from pump seal
Alternative
Standards
Equivalent means of emission limitation

Dual mechanical seal pumps (DMS)

Pumps designed with no externally actuated shaft

Closed-vent system and control device (CVS)

Enclosed-vented process units
Exemptions
Pumps in vacuum service

Pumps operated fewer than 300 hours per year in organic HAP service

Process units with more than 90% of pumps with DMS or CVS; exempt from monthly calculations of
percent leaking pumps

Any pump located at unmanned site exempt from weekly visual inspection provided each is inspected
as often as practicable and at least monthly

Reciprocating pumps exempt from §63.163 if recasting distance piece or pump replacement is
required
Monitoring
Method
Method 21; no more the 1 cm from rotating shaft
  •  response factor criteria (excluding inerts) for average composition of process fluid
  •  monitor all equipment while it is "in service"
                                      PUMPS IN LIOHT LIQUID SERVICE
                                                                                  page C-89

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                               PUMPS IN LIGHT LIQUID SERVICE

                                          APPLICABLE REGULATIONS
40 CFR Part 60
Subpart DDD

40 CFR Part 60,
Subpart GOG

40 CFR Pan 60,
Subpart KKK

40 CFR Part 60,
Subpart QQQ

40 CFR Part 63,
Subpart CC
(existing)

                                                                                              40 CFR Part 63,
                                                                                               Subpart CC
                                                                                              (existing or new)
      ITEM
                                    REQUIREMENTS
Repair
Requirements
First attempt within 5 calendar days of detection

Repair as soon as practicable; no later than 15 days after detection
Delay of Repair
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown.

Allowed for equipment that is isolated from the process and that does not remain in organic HAP
service

Allowed if repair requires use of:  (1) a new system determined under provisions of a QIP, or (2) a
DMS that  includes a barrier fluid system, or (3) a pump designed with no externally actuated shaft,
or (4) a closed-vent system and control device, and repair is completed as soon as practicable but not
later than 6 months after leak detected
Reeordkeeping
Requirements
When leafc detected:
  »  a weather-proof and readily visible identification, marked with the equipment ID number,
    attached to the leaking equipment
  »  ID may be removed after it has been repaired

Information to be kept in log for 5 years after leak detected:
  •  instrument and equipment ID number and operator name, initials, and ID1 number
  «  date leak detected
  «  date of first attempt to repair leak
  «  maximum instrument reading (M21) after successful repair or determination the pump is non-
    reparable
  «  "repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection
  »  dates of process unit shutdown that occurred while the equipment is unrepaired
  •  date of successful repair of the leak

Information to be kept for  all pumps:
  *  list of ID numbers of subject pumps
  «  location of pump  on site plan, log entries, etc.
  «  list of ID numbers of pumps equipped with CVS
  »  identify records by process unit and program implemented for each pump
  «  documentation and dates of visual inspections

Information and data used  to demonstrate that a pump is not in organic HAP service, is in HAP
service fewer than 300 hours/year, or is in heavy liquid service
                                       PUMPS IN LIGHT LIQUID SERVICE
                                                                                   page C-90

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                               PUMPS IN LIGHT LIQUID SERVICE

                                         APPLICABLE REGULATIONS
 40 CFR Part 60
  Subpart DDD
40 CFR Part 60,
 Subpart GOG
40 CFR Part 60,
 Subpart KKK
40 CFR Part 60,
 Subpart QQQ
40 CFR Part 63,
  Subpart CC
   (existing)
40 CFR Part 63,
  Subpart CC
(existing or new)
     ITEM
                                    REQUIREMENTS
Reporting
Requirements
Initial notification:
 *  name and address of owner/operator
 •  address of facility (physical location)
 •  identification of subject processes
 •  compliance statement
 •  statement of whether a source can achieve compliance by the applicable compliance date

 Notification of compliance status:
 •  process unit identification
 •  number of pumps (excluding those in vacuum service)
 •  method of compliance
 •  planned schedule for each phase of requirements

Subsequent semiannual reports:
 •  process unit identification
 •  the following information for each monitoring period in the reporting period:
    • »  number of pumps for which leaks were detected
    • •  percent of pumps leaking
    » «  total number of pumps monitored
    • •  number of pumps for which leaks were not repaired within 15 days after detection
    • «  the facts that explain each delay of repair, and where appropriate,.why a process unit
         shutdown was technically infeasible
 •  dates of process unit shutdowns that occurred within the semiannual reporting period
 •  revisions to items reported in the initial compliance notice if changes have occurred since the
    initial semiannual report or subsequent revisions to the initial semiannual report
                                       PUMPS IH LIGHT LIQUID SERVICE
                                                                                   page C-91

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  QUALITY IMPROVEMENT PROGRAM FOR PUMPS IN LIGHT LIQUID SERVICE
                                        APPLICABLE REGULATIONS
  40 CFR Pan 60
  SubpanDDD
40 CFR Pan 60,
 Subpait OGO
40 CFR Pan 60,
 Subpait KKK
40 CFR Part 60,
 Subpart QQQ
40 CFR Part 63,
  Subpan CC
   (existing)
40 CFR Part 63,
  Subpait CC
(existing or new)
      ITEM
                                   REQUIREMENTS
Applicability
A technology review of improvement QIP's are required in Phase III if the greater of either 10% of
pumps in a process unit (or source-wide) or 3 pumps in a process unit (or source-wide) leak

Once  < 10% or <  3 pumps leaking is achieved, comply with basic standard

If leak rate again exceeds the greater of either >  10% or 3 pumps leaking, can use QIP again
Data Collection
Pumps:
  •  type and manufacturer
  «  seal type and manufacturer
  •  pump design
  »  materials of construction
  •  year installed
  «  barrier fluid or packing material

Service characteristics of the stream:
  •  discharge pressure, temperature, flow rate, corrosivity, annual operating hours

Maximum instrument readings

Repair methods used and the instrument readings after the repair

Inspect all pumps and pump seals that exhibit frequent failure and recommend changes to reduce leak
potential
Data Analysis
Analyze data to determine the services, operating and maintenance procedures, and pumps and pump
seal designs or technologies that have poorer and those that have better than average performance;
the first analysis shall be completed no later than 18 months after the start of the program, shall use a
minimum of 6 months of data, shall be done yearly for as long as the process unit is in the QIP
program
Trial Evaluation
Required for plants that have not demonstrated superior technologies:
  •  the number of pump seal technologies or pumps in the trial program shall be the lesser of 1 % or
    2 pumps for programs involving single process units and the lesser of 1 % or 5 pumps for plant
    sites or groups of process units; the minimum number of pumps or pump seal technologies in the
    program shall be 1
  •  the program shall specify and include design documentation, the evaluation stages, frequency of
    monitoring, the range of operating conditions, and conclusions

The performance trials shall be conducted for a 6-month period beginning no later than 18 months
after the beginning of the QIP

Conclusions will be drawn no later than 24 months after the beginning of the QIP
                   QUALITY IMPROVEMENT PROGRAM FOR PUMPS IN LIGHT LIQUID SERVICE
                                                                                 page C-92

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  QUALITY IMPROVEMENT PROGRAM FOR PUMPS IN LIGHT LIQUID SERVICE
                                         APPLICABLE REGULATIONS
40 CFR Part 60
Subpart ODD

40 CFR Part 60,
Subpart GOG

40 CFR Part 60,
Subpart KKK

40 CFR Part 60,
Subpart QQQ

40 CFR Part 63,
Subpart CC
.(existing)

                                                                                             40 CFR Part 63,
                                                                                               Subpart CC
                                                                                             (existing or new)
     ITEM
                                    REQUIREMENTS
Equipment
Replacement
Beginning at the start of the third year of the QIP for plants with 400 or more valves or 100 or more
employees and at the start of the fourth year for others, the owner/operator shall replace the pumps
and pump seals that are not superior technology; pumps or pump seals shall be replaced at the rate of
20% per year and shall continue to be replaced until all are superior technology
Recordkeeping
Requirements for
All
QIP:
    reason for any leak repair delay and expected date of successful repair
    records of all analyses
    records documenting the quality assurance program
    records indicating all valves or pumps replaced or modified are in compliance with the 20% or
    greater annual replacement rats for pumps
    information and data showing company has less than 100 employees
Recordkeeping for
QIP - Technology
Review and
Improvement
Pumps:
  •  pump type; manufacturer; seal type and manufacturer; design; materials of construction (if
    applicable); year installed
  «  service characteristics of the stream         •              '
  •  maximum instrument readings
  •  if leak detected, the repair method used and the instrument reading after repair
  «  if data analyzed as part of a larger analysis program; describe any maintenance or QIP intended
    to improve emission performance

Rolling average percent leaking pumps

Documentation of all inspections and recommendations for design or specification changes to reduce
leak frequency

Beginning and end date while meeting requirements of the QIP
Reporting
Requirements
Subsequent semiannual reports:
  «  initiation of monthly monitoring under Phase ffl or QIP (if applicable)
                    QUALITY IMPROVEMENT PROGRAM FOR PUMPS IN LIGHT LIQUID SERVICE
                                                                                  page C-93

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                    QUALITY IMPROVEMENT PROGRAM FOR VALVES
                                         APPLICABLE REGULATIONS
  40 CFR Part 60
  Subpart ODD
40CFRPart60,
 Subpatt OC5G
40 CFR Part 60,
 Subpart KKK
40 CFR Part 60,
 Subpart QQQ
40 CFR Part 63,
  Subpart CC
   (existing)
40 CFR Part 63,
  Subpart CC
(existing or new)
      ITEM
                                    REQUIREMENTS
Applicability        Optional in Phase IH to owners/operations with a4% leakers without Section 63.649 connector
                   monitoring or aS% leakers with Section 63.649 connector monitoring

                   Decision required within first year of Phase HI

                   If rolling average of percent leakers is <4% (or 5%) for 2 consecutive quarters:  1) comply with
                   QIP, 2) monitor each valve quarterly or 3) comply with both QIP and monitor quarterly

                   If monitoring each valve quarterly cannot use QIP again if leak rate goes above 4% (or 5%); monthly
                   monitoring is required
Demonstration of
Further Progress
Collect data and maintain records as follows:
  »  maximum instrument reading observed in each monitoring
  •  classification of valve "gas or light liquid service"
  •  repair method used and instrument readings after repair (monitoring required at least once within
    the first 3 months after the repair is completed)(ID tag on a leaking valve may be removed after
    the valve successfully passes this monitoring period

Continue to collect data for as long  as the process unit is in  QIP

Demonstrate progress in reducing the percent leaking valves each quarter by at least:
  •  10 percent (meaning that each quarter there is at least a 10 percent reduction in the percent
    leaking valves from the preceding monitoring period)
  •  alternative quarterly percent reduction and to less than 4% (or 5%) within 2 years

The provisions for failure to  meet the 10% reduction for 2 consecutive rolling averages are:
  •  a choice of monthly monitoring, or
  •  implementation of a QBP for technology review
Technology         Data collection for as long as in QIP:
Review and           » valve type and manufacturer, valve design, materials of construction, year installed, and packing
Improvement           material
                     » service characteristics of the stream (e.g., operating pressure, temperature, line diameter,
                       eorrosivity)
                     • gas/vapor or light liquid service
                     * repair methods used and the instrument readings after the repair

                   Inspect all valves removed due to leaks to determine cause of failure and recommend design and
                   other changes to reduce leak potential

                   Analyze data to determine the services, operating and maintenance procedures, and valve designs or
                   technologies that have poorer and those that have better than average performance; the first analysis
                   shall be completed no later than 18 months after the start of the program, shall use a minimum of 6
                   months of data, shall be done yearly for as long as the process unit is in the QIP program
                               QUALITY IMPROVEMENT PROGRAM FOR VALVES
                                                                                  page C-94

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                    QUALITY IMPROVEMENT PROGRAM FOR VALVES
                                          APPLICABLE REGULATIONS
40CFRPart60
Subpart DDD

40 CER Part 60,
Subpart GGG

40 CFR Part 60,
Subpart KKK

40 CFR Part 60,
Subpart QQQ

40 CFR Part 63,
Subpart CC
(existing)

                                                                                               40 CFR Part 63,
                                                                                                 Subpart CC
                                                                                               (existing or new)
      ITEM
                                                         REQUIREMENTS
Data Collection
                   Data collection for as long as in QIP:
                     *  valve type and manufacturer, valve design, materials of construction, year installed, and packing
                        material
                     •  service characteristics of the stream (e.g., operating pressure, temperature, line diameter,
                        corrosivity)
                     «  gas/vapor or light liquid service
                     •  repair methods used and the instrument readings after the repair

                   Inspect all valves removed due to leaks to determine cause of failure and recommend design and
                   other changes to reduce leak potential
Data Analysis
                   Analyze data to determine the services, operating and maintenance procedures, and valve designs or
                   technologies that have poorer and those that have better than average performance; the first analysis
                   shall be completed no later than 18 months after the start of the program, shall use a minimum of 6
                   months of data, shall be done yearly for as long as the process unit is in the QBP program
Trial Evaluation
                    Required for plants that have not demonstrated superior technologies:
                     •  the number of valves in the trial program shall be the lesser of 1 % or 20 valves for programs
                        involving single process units and the lesser of 1% or 50 valves for programs involving groups
                        of process units
                     •  the program shall specify and include design documentation, the evaluation stages, frequency of
                        monitoring, the range of operating conditions, and conclusions

                    The performance trials shall be conducted for a 6-month period beginning no later than 18 months
                    after the beginning of the QIP

                    Conclusions will be drawn no later than 24 months after the beginning of the QIP
Equipment
Replacement
                    Beginning at the start of the third year of Phase III for plants with 400 or more valves or 100 or more
                    employees and at the start of the fourth year of Phase HI for others, each replacement valve shall
                    meet quality assurance and superior emission performance technology standards

                    If superior emission performance technology cannot be identified, replacement valve shall be one
                    with lowest emission performance technologies identified for the specific application
Recordkeeping
Requirements
                    Semiannual Reports
                     •  reason for any leak repair delay and expected date of successful repair
                     •  records of all analyses
                     •  records documenting the quality assurance program
                     *  records indicating all valves or pumps replaced or modified are in compliance with the quality
                        assurance requirements
                                QUALITY IMPROVEMENT PROGRAM FOR VALVES
                                                                                                        page C-95

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QUALITY IMPROVEMENT PROGRAM FOR VALVES
              APPLICABLE REGULATIONS
40CFRPart60
Subpart DDD

40CFRPan60, 40CFRPart60, 40CFRPart60, 40CFRPart63,
Subpart GGG Subpan KKK Subpart QQQ Subpart CC
(existing)


ITEM
Recordkeeping for
Demonstration of
Further Progress
Recordkeeping for
QIP - Technology
Review and
Improvement
Reporting
Requirements
40 CFR Part 63,
Subpart CC
(existing or new)
REQUIREMENTS
QIP reasonable further progress:
• owner or operator shall collect the following data and maintain records for each valve in each
process unit subject to the QIP:
• • maximum instrument reading
• • valve is in gas or light liquid service
• • if leak detected, the repair methods used and instrument reading after repair
• percent leaking valves and rolling average percent reduction each year
• beginning and end dates while meeting the requirements of the QIP
Valves:
valve type; manufacturer; design; materials of construction; year installed
service characteristics of the stream
valve is in gas or light liquid service
maximum instrument readings
if leak detected, the repair method used and the instrument reading after repair
if data analyzed as part of a larger analysis program; describe any maintenance or QIP intended
to improve emission performance
Percent leaking valves
Rolling average percent leaking pumps
Documentation of all inspections and recommendations for design or specification changes to reduce
leak frequency
Beginning and end date while meeting requirements of the QIP
Subsequent semiannual reports:
« initiation of monthly monitoring under Phase III or QIP (if applicable)
       QUALITY IMPROVEMENT PROGRAM FOR VALVES
page C-96

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SAMPLING CONNECTION SYSTEMS
         APPLICABLE REGULATIONS
40 CFR Part 60
Subpart DDD

40 CFR Part 60,
Subpart GGO

40 CFR Part 60,
Subpart KKK

40 CFR Part 60,
Subpart QQQ

40 CFR Part 63,
Subpart CC
(existing)

                                                   40 CFR Part 63,
                                                    Subpart CC
                                                   (existing or new)
ITEM
Basic Standard
Leak Definition

Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
Recordkeeping
Requirements
REQUIREMENTS
Equipped with closed-purge system or closed-vent system that either returns the fluid to the process,
recycles the purged fluid, or sends it to a compliant control device
Gases displaced during filling of samples are not required to be collected or captured
N/A

Equivalent means of emission limitation
Sampling systems in vacuum service
In-situ sampling systems and sampling systems without purges
Sampling systems in organic HAP service fewer than 300 hours per year
N/A
N/A
N/A
Information to be kept for all sampling connections
• list of ID numbers of subject sampling connection systems
* location of sampling system on site plan, log entries, etc.
• list of ID numbers for sampling systems in vacuum service
Information and data used to demonstrate that equipment is not in organic HAP service or is in HAP
service fewer than 300 hours/year.
      SAMPLING CONNECTION SYSTEMS
                                                          page C-97

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                              SAMPLING CONNECTION SYSTEMS
                                         APPLICABLE REGULATIONS
 40CFRPirt60
  Subpart DDD
40 CFR Part 60,
 Snbpart GOG
40CFRPart60,
 SubpanKKK
40 CFR Part 60,
 Subpart QQQ
40 CFR Part 63,
  Subpart CC
   (existing)
40 CFR Part 63,
  Subpart CC
(existing or new)
     ITEM
                                    REQUIREMENTS
Reporting
Requirements
Initial notification:
 »  name and address of owner/operator
 •  address of facility (physical location)
 »  identification of subject processes
 •  compliance statement
 •  statement of whether a source can achieve compliance by the applicable compliance date

Notification of compliance status:
 »  process unit identification
 •  number of sampling connection systems, excluding those in vacuum service
 «  method of compliance

Subsequent semiannual reports:
 *  process unit identification
 •  the following information for each monitoring period during the 6 month period
    * • the facts that explain any delay of repairs and, where appropriate, why a process unit
        shutdown was infeasible
 «  dates of process unit shutdowns that occurred within the semiannual reporting period
 •  revisions to items reported in the initial semiannual report if changes have occurred since the
    initial semiannual report or subsequent revisions to the initial semiannual report
                                      SAMPLING CONNECTION SYSTEMS
                                                                                   page C-98

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VALVES IN GAS/VAPOR AND LIGHT LIQUID SERVICE
                 APPLICABLE REGULATIONS
40CFRPart60
Subpart DDD


ITEM
Basic Standard
Leak Definition

Alternative
Standards
Exemptions
Monitoring
Method
40CFRPait60, 40CFRPart60, 40CFRPart60, 40CFRPart63, 40CFRPart63,
Subpart GOG Subpart KJKK Subpart QQQ Subpart CC Subpart CC
(existing) (existing or new)
H^^HH

REQUIREMENTS
Phase I & II: Monitor each valve quarterly
Phase III: Monitoring frequency based on percent valves found leaking:
Percent Leaking1 Monitoring Frequency
a b
4% (or more) 5% (or more) Monthly or Q1P
<4% <5% Quarterly
<3% <4% Quarterly or once every 2 quarters
<2% < 3 % Quarterly or once every 4 quarters
a: connectors not monitored under §63.649
b: connectors monitored per §63.649
(If 2% or more of valves leak at plant with < 250 valves in organic HAP service: monitor monthly)
'Percent leaking valves is calculated as a rolling average of two consecutive monitoring periods.
Non-reparable valves are only counted once in calculation of percent leaking. Non-reparable valves
exceeding 3 percent of total valves in HAP service shall be included in calculation of percent leaking
valves
2At startup of new sources, comply with §63.168(a)(l)(ii)
Phase I: 10,000 ppm
Phase D: 1,000 ppm
Phase HI: 1,000 ppm

Equivalent means of emission limitation
QIP for valves
Valves designated unsafe to monitor or difficult to monitor (at new facilities, maximum 3% of valves
may be designated as difficult to monitor)
At Phase HI, valves designated as no detectable emissions may follow rules @ 40 CFR 60.482-7(f).
Such valves are exempt from Subpart H monitoring provisions.
Valves in vacuum service
Valves in organic HAP service fewer than 300 hours per year
Method 21
« response factor criteria (excluding inerts) for average composition of process fluid
» monitor all equipment while it is "in service"
         VALVES IN GAS/VAPOR AND LIGHT LIQUID SERVICE
page C-99

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                  VALVES IN GAS/VAPOR AND LIGHT LIQUID SERVICE
                                         APPLICABLE REGULATIONS
  40 CFR Pan 60
  Subpart ODD
40 CFR Part 60,
 Subpart GGG
40 CFR Part 60,
 Subpart KKK
40 CFR Part 60,
 Subpart QQQ
40 CFR Part 63,
  Subpart CC
   (existing)
40 CFR Part 63,
  Subpart CC
(existing or new)
     ITEM
                                    REQUIREMENTS
Repair
Requirements
First attempt within 5 calendar days of detection

Repair as soon as practicable; no later than 15 days after detection

When repaired, monitor at least once within first 3 months of repair
Delay of Repair
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in organic HAP
service

Allowed if emissions of purged material from immediate repair would exceed fugitive emissions from
delay of repair, and purged materials are collected and destroyed or recovered in a control device
when repair occurs

Allowed beyond process unit shutdown if valve assembly replacement supplies are exhausted
Recordkeeping
Requirements
When leak detected:
 *  a weather-proof and readily visible identification, marked with the equipment ED number,
    attached to the leaking equipment
 »  ID may be removed after it has been repaired and monitored at least once within first 3 months
    of repair

Information to be kept in log for 5 years after leak detected:
 •  instrument and equipment ID number and operator name, initials, and ED number
 •  date leak detected
 •  date of first attempt to repair leak
 •  maximum instrument reading after successful repair or if determined to be non-reparable
 •  "repair delayed" and reason for delay if leak not repaired within  15 calendar days after detection
 •  dates of process unit shutdown that occurred while the equipment is unrepaired
 «  date of successful repair of the leak

Information to be kept for all valves:
 •  list of ID numbers of subject valves
 «  location of valve on-site plan, log entries, etc.
 •  schedule by process unit for monitoring valves
 •  list of valves removed if net credits for their removal are expected to be used
 •  list of ID numbers for valves in vacuum service

Information and data used to demonstrate that a valve is not in organic HAP service, is in HAP
service fewer than 300 hours/year, or is in heavy liquid service
                              VALVES IN GAS/VAPOR AND LIGHT LIQUID SERVICE
                                                                                 page C-100

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                  VALVES IN GAS/VAPOR AND LIGHT LIQUID SERVICE
                                          APPLICABLE REGULATIONS
  40 CFR Pan 60
  Subpart DDD
40 CFR Part 60,
 Subpart GGO
40 CFR Part 60,
 Subpart KKK
40 CFR Part 60,
 Subpart QQQ
40 CER Part 63,
  Subpart CC
   (existing)
40 CFR Part 63,
  Subpart CC
(existing or new)
     ITEM
                                    REQUIREMENTS
Reporting
Requirements
Initial notification:
 »  name and address of owner/operator
 •  address of facility (physical location)
 *  identification of subject processes
 »  compliance statement
 »  statement of whether a source can achieve compliance by the applicable compliance date

 Notification of compliance status:
 •  process unit identification
 •  number of valves, excluding those in vacuum service
 »  method of compliance (decision to calculate percent leaking valves on process unit or sourcewide
    basis not due until first required monitoring period after Phase I compliance data)
 •  planned schedule for each phase
 •  whether percent valves leaking will be calculated on a process unit basis or source-wide basis

Subsequent semiannual reports:
 «  process unit identification
 »  the following information for each monitoring period in the reporting period:
    • •  number of valves for which leaks were detected
    • •  total number of valves monitored
    * •  the percent leakers for valves
    • •  number of valves for which leaks were not repaired within 15 days after detection
    • *  identification of the number of valves determined to be non-reparable
    • •  explanation of why repairs delayed and why a process unit shutdown was infeasible
 •  dates of process unit shutdowns that occurred within the semiannual reporting period
 •  revisions to items reported in the initial semiannual report if changes have occurred since the
    initial semiannual report or subsequent revisions to the initial  semiannual report
 •  initiation of monthly monitoring under Phase III or QEP (if applicable)
                              VALVES IN GAS/VAPOR AND LIGHT LIQUID SERVICE
                                                                                   page C-101

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             CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                            APPLICABLE REGULATIONS
40 CFR Part 264,
  SubpaitCC
40 CFR Part 265,
  Swbpart CC
40 CFR Part 61,
Subpart F

40 CFR Part 61
Subpart L

40 CFR Part 61,
Subpart FF

ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
REQUIREMENTS
Operating at all times when gases, vapors, or fumes are vented from the waste management unit
through the CVS to the control device.
Control Devices
• Designed and operated to reduce total organic content of the inlet vapor stream vented to the
control device by at least 95% by weight.
« For carbon adsorbers, carbon replacement intervals specified [see §264.1033(g) and (h)].
« Enclosed combustion devices: 95 percent or greater reduction; 20 ppmv total organic compound
concentration; or minimum residence time of 0.50 seconds and minimum temperature of 760°C.
« Boilers and process heaters: Introduce vent stream into flame combustion zone.
« Flares: Flame present at all times, no visible emissions (except for periods not to exceed a total
of 5 minutes during any 2 consecutive hours), basic requirements for hesit content and exit
velocities.
An applicable control device other than a thermal vapor incinerator, flare, boiler, process heater,
condenser, or carbon adsorption system: develop documentation including sufficient information to
describe the control device operation and identify process pararneter(s) that indicate proper operation
and maintenance of the control device.
Closed- Vent Systems (CVS)
• Designed for and operated with no detectable emissions.
• Route gases, vapors, and fumes emitted from the hazardous waste to a control device.
• If the system contains one or more bypass devices that could be used to divert gases, vapors, or
fumes from entering the control device, §264.1087(b)(3) requirements apply.
CVS: detectable emissions J>500 ppm above background
N/A
N/A
Closed Vent Systems:
« Monitor initially and at least once per year thereafter
• If system contains by-pass lines, either use vent stream flow meters or a car-seal or lock-and-key
type of configuration and visually inspect monthly
Control Devices:
» Continuous monitoring of operations
First attempt to repair within 5 calendar days of detection
Repair as soon as practicable; no later than 15 days after detection
                     CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                                                       page C-102

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                    CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                                        APPLICABLE REGULATIONS
   40 CFR Part 264,
     Subpart CC
      40 CFR Part 265,
        Subpart CC
40 CFR Part 61,
  Subpart F
40 CFR Part 61
  Subpart L
40 CFR Part 61,
  Subpart FF
     ITEM
                                    REQUIREMENTS
Delay of Repair
N/A
Recordkeeping
Requirements
When leak detected:
 •  date of attempt to repair
 »  repair method applied
 »  date of successful repair
 »  retain for 3 years

All visual inspections of covers

For each time waste sample is collected:
 •  date and time sample is collected
 *  results of each determination for maximum organic vapor pressure
 *  tank dimensions and capacity

If no air emission controls are used:
 »  information for each waste determination
 «  date, time, and location of each waste sample if results are used

Alternative recordkeeping:
 «  Owners/operators also subject to 40 CFR Part 60, Subpart VV or 40 CFR Part 61, Subpart V
    may elect to demonstrate compliance using the documentation required under said Subpart VV or
    Subpart V to the extent that such documentation duplicated the documentation required under 40
    CFR Part 265 [264], Subpart CC.
Reporting
Requirements
NOTE:  The following is applicable to 40 CFR Part 264, Subpart CC only.

Exempted tanks, surface impoundments, and containers:
  « each occurrence when hazardous waste is placed in unit in noncompliance with §264.1082(c)(l)
    or (2)

Tanks complying with §264.1084(c):
  «  each occurrence of noncompliance
  •  submit within 15 calendar days of time when become aware of noncompliance

Control device:
  »  semiannual report when noncompliance has occurred
  •  each period of 24 hour or longer when operating in noncompliance
  •  for flares;  when operated with visible emissions

All reports to include:
  •  EPA ED number
  «  facility name and address
  •  description of event  and cause (not for control devices)
  »  explanation why control device not returned to compliance within 24 hours (control devices only)
  •  dates of the noncompliance
  «  actions taken to correct noncompliance and prevent reoccurrence
  «  signed and dated by  authorized representative
                               CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                                                                                 page C-103

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                                    CONTAINERS
                                 APPLICABLE REGULATIONS
40 CFR Part 264,
  SubptrtCC
40 CFR Part 265,
  Subpart CC
40 CFR Part 61,
Subpart F

40 CFR Part 61
Subpait L

40 CFR Part 61,
Subpart FF

ITEM
Basic Standard








Leak Definition
Alternative
Standards
Exemptions

Monitoring
Method
Repair
Requirements
REQUIREMENTS
Non-treatment Containers:
Option I:
» Compliant cover (see Covers).
« Monitor first time hazardous waste placed in container.
• If cannot repair immediately, remove hazardous waste from containers. Do not use container
until leak is repaired and container retested.
Option 2
» If capacity is _<0.46 cubic meters, compliant cover and complies with 49 CFR Part 178
regulations for packaging hazardous waste for transport.
Option 3
« If attached to or part of truck, trailer, or railcar, demonstrate that within preceding 12 months to
be organic vapor tight (sustains a pressure change of <15Q pascals within 5 minutes after
pressurization).
Treatment Containers:
• Located in compliant enclosure vented to compliant closed vent system and control device.
Compliant Enclosure:
• Designed and operated with sufficient airflow to capture organic vapors! emitted from container
and vent them to compliant closed vent system and control device.
Transfer into Containers (>0.46 cubic meters capacity:
« Use of conveyance system that uses a tube (or other means) to add waste to the container and
cover to remain in place and all container openings to be in closed, sealed position except for
opening.
See Covers
N/A

A container that meets all of the requirements identified in §265.1083(c) [§264.1082(c)] including but
not limited to an average VO concentration of the hazardous waste at the point of waste origination is
< 100 ppmw.
Containers used for biological treatment of hazardous waste in accordance with §26~5.1083(c)(2)(iv)
[§264.1082(c)(2)(iv)].
See Covers
N/A
                                       CONTAINERS
                                                                page C-104

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                                                 COVERS
   40 CFR Part 264,
     Subpait CC
                                         APPLICABLE REGULATIONS
      40 CFR Part 265,
        Subpait CC
40 CFR Part 61,
Subpart F

40 CFR Part 61,
Subpart L

40 CFR Part 61,
Subpart FF

      ITEM
Delay of Repair
                                    REQUIREMENTS
See Covers
Recordkeeping
Requirements
When leak detected:
 »  date of attempt to repair
 •  repair method applied
 *  date of successful repair
 *  retain for 3 years

All visual inspections of covers

If no air emission controls are used:
 •  information for each waste determination
 •  date, time, and location of each waste sample if results are used

Alternative recordkeeping:
 •  Owners/operators also subject to 40 CFR Part 60, Subpart W or 40 CFR Part 61, Subpait V
    may elect to demonstrate compliance using the documentation required under said Subpart VV or
    Subpart V to the extent that such documentation duplicated the documentation required under 40
    CFR Part 265 [264], Subpart CC.
Reporting
Requirements
NOTE:  The following is applicable to 40 CFR Part 264, Subpart CC only.

Exempted tanks, surface impoundments, and containers:
  • each occurrence when hazardous waste is placed in unit in noncompliance with §264»1082(c)(l)
    or (2)

Control Device
  »  semiannual  report when noncompliance has occurred
  »  each period of 24 hour or longer when operating in noncompliance
  •  for flares; when operated with visible emissions

All reports to include:
  •  EPA ID number
  *  facility name and address
  •  description of event and cause (not for control devices)
  *  explanation why control device not returned to compliance within 24 hours (control devices only)
  •  dates of the noncompliance
  «  actions taken to correct noncompliance and prevent reoccurrence
  •  signed and dated by authorized representative
                                                   COVERS
                                                                                                      page C-105

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                                                  COVERS
   40 CFR Fait 264,
     Subpan CC
      40 CFR Part 265,
         Subpait CC
                                          APPLICABLE REGULATIONS
40CFRPart61,
   Subpait F
40 CFR Part 61,
   Subpait L
40 CFR Part 61,
  Subpart FF
      ITEM
                                     REQUIREMENTS
Basic Standard
Initial and semiannual visual inspection and monitoring for no detectable organic emissions from
cover and cover openings when all cover openings are secured in closed, sealed position.

"Unsafe-to-inspeet" covers: written plan to inspect and monitor cover as frequently as practicable
during times when a worker can safely access the cover.

"Difficult-to-inspect" covers:  written plan and schedule to inspect and monitor at least once per
calendar year.
Leak Definition
Seals around rotating shaft: 10,000 ppmv

All other seals and cover connections:  detectable emissions (i.e., concentrations greater than 500
ppmv plus background level).

Visual:  a visible hole, gap, tear, or split in cover surface or cover opening.
Alternative
Standards
N/A
Exemptions
Tank with internal floating roof or external floating roof that is inspected and monitored in
accordance with §265.1091 (§264.1091).

Tank is buried partially or entirely underground — only inspect or monitor portion that is above
ground and can be opened to the atmosphere .

Containers that meet all requirements specified in either §265.1Q87(b)(l)(ii) or (iii)
[§264.1086(b)(l)(ii) or (iii)]

Semiannual inspection/monitoring exemptions:
  •  cover remained closed and sealed since last visual inspection and monitoring
  •  designated as unsafe to inspect and monitor
  •  designated as difficult to inspect and monitor if installed and placed in service before December
    6, 1994
Monitoring
Method
Instrument: Method 21, 40 CFR Part 60, Appendix A

Visual: View entire cover surface and each cover opening in a closed, seal position for evidence of
defect that may affect ability to continue to operate with no detectable organic emissions.
Repair
Requirements
First attempt to repair:  within 5 calendar days of detection.

Completed repair:  within 15 calendar days of detection.
                                                    COVERS
                                                                                                         page C-106

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                                                 COVERS
  40 CFR Part 264,
     Subpart CC
                                         APPLICABLE REGULATIONS
      40 CFR Part 265,
        Subpart CC
40 CFR Part 6l>
Subpart F

40 CFR Part 61,
Subpart L

40 CFR Part 61,
Subpart FF

     ITEM
                                     REQUIREMENTS
Delay of Repair
For tanks and surface impoundment covers:

Allowed beyond 15 days if repair requires first emptying contents and temporary removal of tank or
surface impoundment from service results in unscheduled production stoppage of the source
generating the hazardous waste being managed.

Repair to occur at next time source generating the hazardous waste being managed stops operation for
any reason.
Recordkeeping
Requirements
When leak detected:
 •  date of attempt to repair
 •  repair method applied
 »  date of successful repair
 •  retain for 3 years

All visual inspections of covers

For each time waste sample is collected:
 •  date and time sample is collected
 »  results of each determination for maximum organic vapor pressure
 *  tank dimensions and capacity

If no air emission controls are used:
 »  information for each waste determination
 »  date, time, and location of each waste sample if results are used

Alternative recordkeeping:
 •  Owners/operators also subject to 40 CFR Part 60, Subpart W or 40 CFR Part 61, Subpart V
    may elect to  demonstrate compliance using the documentation required under said Subpart VV or
    Subpart V to the extent that such documentation duplicated the documentation required under 40
    CFR Part 265 [264], Subpart CC.

Unsafe- or DifficuIt-to-Monitor Covers:
 •  list of identification numbers
 »  explanation for designation
 »  planned schedule for monitoring
                                                   COVERS
                                                                                                      page C-107

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                                                COVERS
  40 CFR Part 264,
     SubpanCC
      40 CFR Part 265,
        Subpart CC
                                        APPLICABLE REGULATIONS
40 CFR Part 61,
  Subpart F
40 CFR Part 61,
  Subpart L
40 CFR Pan 61,
  Subpart FF
     ITEM
                                    REQUIREMENTS
Reporting
Requirements
NOTE:  The following is applicable to 40 CFR Part 264, Subpart CC only.

Exempted tanks, surface impoundments, and containers:
  • each occurrence when hazardous waste is placed in unit in noncompliance with §264.1082(c)(l)
    or (2)

Tanks complying with §264.1084(c):
  •   each occurrence of noncompliance
  »  submit within 15 calendar days of time when become aware of noncompliance

Control Device
  *  semiannual report when noncompliance has occurred
  •  each period of 24 hour or longer when operating in noncompliance
  •  for flares;  when operated with visible emissions

All reports to include:
  »  EPA ID number
  •  facility name and address
  »  description of event and cause (not for control devices)
  •  explanation why control device not returned to compliance within 24 hours (control devices only)
  »  dates of the noncompliance
  •  actions taken to correct noncompliance and prevent reoccurrence
  »  signed and dated by authorized representative
                                                  COVERS
                                                                                                    page C-108

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                                    SURFACE IMPOUNDMENTS
                                          APPLICABLE REGULATIONS
   40 CFR Part 264,
     Subpart CC
      40 CFR Pan 265,
        Subpart CC
40 CFR Part 61,
Subpart F

40 CFR Part 61
Subpart L

40 CFR Pan 61,
Subpart FF

     ITEM
                                     REQUIREMENTS
Basic Standard
Option 1:  Compliant covers (see Covers) that are vented to compliant closed-vent system and control
device.

Option 2: Floating membrane cover that meets certain requirements including designed to operate
with no detectable organic emissions
Leak Definition
See Covers
Alternative
Standards
N/A
Exemptions
A surface impoundment that meets all of the requirements identified in §265.1083(c) [§264.1082(c)]
including but not limited to an average VO concentration of the hazardous waste at the point of waste
origination is < 100 ppmw.

Surface impoundments used for biological treatment of hazardous waste in accordance with
§265.1083(c)(2)(iv) [§264.1082(c)(2)(iv)J.
Monitoring
Method
See Covers
Repair
Requirements
See Covers
Delay of Repair
Allowed beyond 15 days if repair requires first emptying contents and temporary removal of tank or
surface impoundment from service results in unscheduled production stoppage of the source
generating the hazardous waste being managed.

Repair to occur at next time  source generating the hazardous waste being managed stops operation for
any reason.
Recordkeeping
Requirements
When leak detected:
  •  date of attempt to repair
  «  repair method applied
  «  date of successful repair
  «  retain for 3 years

AH visual inspections of covers

If no air emission controls are used:
  »  information for each waste determination
  •  date, time,  and location of each waste sample if results are used

                      	(Continued on next page)
                                          SURFACE IMPOUNDMENTS
                                                                                                       page C-109

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                                   SURFACE IMPOUNDMENTS
                                        APPLICABLE REGULATIONS
   40 CFR Part 264,
     SubpwtCC
      40 CFR Part 265,
        Subpart CC
40 CFR Part 6!,
  Subpart F
40 CFR Part 61
  Subpart L
40 CFR Part 61,
  Subpart FF
     ITEM
                                   REQUIREMENTS
Recordkeeping
Requirements
(continued)
Alternative reeordkeeping:
 •  Owners/operators also subject to 40 CFR Part 60, Subpart VV or 40 CFR Part 61, Subpart V
    may elect to demonstrate compliance using the documentation required under said Subpart VV or
    Subpart V to the extent that such documentation duplicated the documentation required under 40
    CFR Part 265 [264], Subpart CC.
Reporting
Requirements
NOTE:  The following is applicable to 40 CFR Part 264, Subpart CC only.

Exempted tanks, surface impoundments, and containers:
  » each occurrence when hazardous waste is placed in unit in noncompliance with §264.1082(c)(l)
    or (2)

Control Device
 •  semiannual report when noncompliance has occurred
 »  each period of 24 hour or longer when operating in noncompliance
 •  for flares;  when operated with visible emissions

All reports to include:
 »  EPA ID number
 •  facility name and address
 •  description of event and cause (not for control devices)
 •  explanation why  control device not returned to compliance within 24 hours (control devices only)
 *  dates of the noncompliance
 «  actions taken to correct noncompliance and prevent reoccurrence
 •  signed and dated by authorized representative
                                         SURFACE IMPOUNDMENTS
                                                                               pageC-110

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                                        TANKS
                                 APPLICABLE REGULATIONS
40 CFR Part 264,
  Subpart CC
40 CFR Part 61,
Subpart F

40 CFR Part 61,
Subpart L

40 CFR Part 61,
Subpart FF

ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
REQUIREMENTS
Pressure tanks: no detectable emissions
Non-pressure tanks:
Option 1: Compliant cover (see Covers) and compliant closed-vent system and control device
Option 2: Compliant cover provided certain conditions are met including but not limited to the
following maximum organic vapor pressure and size requirements:
Capacity Vapor Pressure
(cubic meters) fKilopascals)
>. 151 ' 5.2
*75 to < 151 27.6
<75 76.6
Conduct initial and quarterly inspections of each fixed roof, seal, access door, and other opening for
cracks and gaps and to ensure access doors and other openings are closed and properly gasketed.
See Covers
Equipped with fixed roof and internal floating roof meeting §60.112b(a)(l).
External floating roofs that comply with §6Q.112b(a)(2).
A tank that meets all of the requirements identified in §265.1083(c) [§264.1082(c>] including but not
limited to an average VO concentration of the hazardous waste at the point of waste origination is
< 100 ppmw.
Tanks used for biological treatment of hazardous waste in accordance with §265.1083(c)
[§264.1082(c)(2)(iv)].
See Covers
See Covers
Allowed beyond 15 days if repair requires first emptying contents and temporary removal of tank or
surface impoundment from service results in unscheduled production stoppage of the source
generating the hazardous waste being managed.
Repair to occur at next time source generating the hazardous waste being managed stops operation for
any reason.
                                          TANKS
                                                                                    page C-lll

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                                                 TANKS
                                         APPLICABLE REGULATIONS
   40 CFR Fart 264,
     Subpart CC
      40 CFR Part 265,
         Subpart CC
40 CFR Part 61,
Subpart F

40 CFR Part 61,
Subpart L

40 CFR Part 61,
Subpart FF

     ITEM
                                    REQUIREMENTS
Recordkeeping
Requirements
When leak detected:
 »  date of attempt to repair
 *  repair method applied
 *  date of successful repair
 «  retain for 3 years

All visual inspections of covers

For each time waste sample is collected:
 •  date and time sample is collected
 •  results of each determination for maximum organic vapor pressure
 •  tank dimensions and capacity

If no air emission controls are used:
 •  information for each waste determination
 «  date, time, and location of each waste sample if results are used

Alternative recordkeeping:
 •  Owners/operators also subject to 40 CFR Part 60, Subpart VV or 40 CFR Part 61, Subpart V
    may elect to demonstrate compliance using the documentation required under said Subpart VV or
    Subpart V to the extent that such documentation duplicated the documentation required under 40
    CFR Part 265 [264], Subpart CC.
Reporting
Requirements
NOTE: The following is applicable to 40 CFR Part 264, Subpart CC only.

Exempted tanks, surface impoundments, and containers:
  * each occurrence when hazardous waste is placed in unit in noncompliance with §264.1082(c)(l)
    or (2)

Tanks complying with §264.1084(c):
 «   each occurrence of noncompliance
 •  submit within 15 calendar days of time when become aware of noncompliance

Control device:
 •  semiannual report when noncompliance has occurred
 »  each period of 24 hour or longer when operating in noncompliance
 «  for flares; when operated with visible emissions

All reports to include:
 »  EPA ID number
 •  facility name and address
 «  description of event and cause (not for control devices)
 »  explanation why control device not returned to compliance within 24 hours (control devices only)
 •  dates of the noncompliance
 »  actions taken to correct noncompliance and prevent reoccurrence
 »  signed and dated by authorized representative
                                                   TANKS
                                                                                                     pageC-112

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                                               AGITATORS
                                          APPLICABLE REGULATIONS
40 CFR Part 264,
Subpart CC

40 CFR Part 265,
Subpart CC

                                                                       40 CFR Part 61,
                                                                          Subpart L
                                                                           40 CFR Part 61,
                                                                            Subpart FP
     ITEM
                                      REQUIREMENTS
Basic Standard
 Minimize VC emissions by installing agitators with double mechanical seals, or equivalent.  If double
 mechanical seals are used, minimize VC emissions by maintaining the pressure between the two seals
 so that any leak that occurs is into the agitated vessel; by ducting any vinyl chloride between the two
 seals through a control system from which the VC concentration in the exhaust gases does not exceed
 10 ppm; or equivalent.
Leak Definition
 None specified
Alternative
Standards
 Equivalent means of emission limitation
Exemptions
 None specified
Monitoring
Method
 N/A
Repair
Requirements
 N/A
Delay of Repair
 N/A
Recordkeeping
Requirements
 None specified
Reporting
Requirements
 Initial report:
  •  Equipment and procedural specifications are being met.
  •  Statement that contains the following:
     • •  list of equipment installed for compliance
     • •  description of the physical and functional characteristics of each piece of equipment
     • •  description of the methods that have been incorporated into the standard operating
         procedures for measuring or calculating the emissions for which emission limits have been
         prescribed
     * •  statement that each piece of equipment is installed and that each piece of equipment and
         each procedure is being used

 Quarterly reports: due March 15, June 15, September 15, and December 15:
  •  VC content of emissions for each 3-hour period during which the average emissions are in excess
     of the limits specified for any control system to which fugitive emissions are required to be
     ducted
  •  the number of 3-hour periods determined during the reporting period
  •  if no excess emissions, a statement to that effect

	(Continued on next page)	  	
                                                  AGITATORS
                                                                                                        page C-113

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                                              AGITATORS
                                        APPLICABLE REGULATIONS
  40 CFR Part 264,
     Subpan CC
      40 CFR Part 265,
        Subpart CC
40 CFR Part 61,
  Subpart F
40 CPR Part 61,
  Subpart L
40 CPR Part 61,
  Snbpart FF
     ITEM
                                    REQUIREMENTS
Reporting
Requirements
(continued)
Other reports (within 10 days of any discharge):
 *  information on the source
 »  nature and cause of the discharge
 *  the date and time of the discharge
 »  the approximate total vinyl chloride loss during the discharge
 •  the method used  for determining the loss
 »  the action taken to prevent the discharge
 •  measures adopted to prevent future discharges.
                                                AGITATORS
                                                                                                   pageC-114

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                    CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                                         APPLICABLE REGULATIONS
  40 CFR Part 264,
     Subpart CC
      40 CFR Part 265,
         SabpartCC
40 CFR Part 61,
   Subpart F
40 CFR Part 61,
  Subpart L
40 CFR Part 61,
  Subpart FF
     ITEM
                                    REQUIREMENTS
Basic Standard
Continually operating while emissions from the release are present.

Control Devices:
  • Other than flares: limit VC emissions to less than 10 ppm (average over 3-hour period)
  • Flares: Comply with §60.18.
Leak Definition
N/A
Alternative
Standards
N/A
Exemptions
N/A
Monitoring
Method
N/A
Repair
Requirements
N/A
Delay of Repair
N/A
Recordkeeping
Requirements
None specified under Subpart F for closed-vent systems and control devices when complying with
Subpart F; see 40 CFR Part 61, Subpart V if complying with that subpart.
Reporting
Requirements
 Initial report
  • Equipment and procedural specifications are being met.
  • Statement that contains the following:
    « »  list of equipment installed for compliance
    * •  description of the physical and functional characteristics of each piece of equipment
    • «  description of the methods that have been incorporated into the standard operating
         procedures for measuring or calculating the emissions for which emission limits have been
         prescribed
    » *  statement that each piece of equipment is installed and that each piece of equipment and
         each procedure is being used

 Quarterly reports: due March 15, June 15, September 15, and December 15:
  » VC content of emissions for each 3-hour period during which the average emissions are in excess
    of the limits specified for any control system to which fugitive emissions are required to be
    ducted
  * the number of 3-hour periods determined during the reporting period
  • if no excess emissions, a statement to that effect

	(Continued on next page)	
                               CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                                                                                 pageC-115

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                  CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                                     APPLICABLE REGULATIONS
  40 CFR Part 264,
     Subparc CC
     40 CFR Part 265,
       Subpart CC
40 CFR Part 61,
  Subpart F
40 CFR Part 61,
  Subpart L
40 CFR Part 61,
  Subpart FF
     ITEM
                                REQUIREMENTS
Reporting
Requirements
(continued)
Other reports (within 10 days of any discharge):
 « information on the source
 « nature and cause of the discharge
 • the date and time of the discharge
 • the approximate total vinyl chloride loss during the discharge
 « the method used for determining the loss
 « the action taken to prevent the discharge
 » measures adopted to prevent future discharges.
                            CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                                                                         page C-l 16

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   COMPRESSORS
APPLICABLE REGULATIONS
40 CFR Part 264,
Subpart CC

40 CFR Part 265,
Subpart CC .

      40 CFR Pan 61,
         Snbpart F
40CERPart61,
  Subpart L
40 CFR Part 61,
  Subpart FF
ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
Recordkeeping
Requirements
REQUIREMENTS
Rotating Compressors:

Minimize VC emissions by installing compressors with double mechanical seals or equivalent. If
double mechanical seals are used, minimize vinyl chloride emissions by maintaining the pressure
between the two seals so that any leak that occurs is into the compressor; by ducting any vinyl
chloride between the two seals through a control system from which the VC concentration in the
exhaust gases does not exceed 10 ppm; or equivalent.
Reciprocating Compressors:
Minimize VC emissions by installing double outboard seals, or equivalent. If double outboard seals
are used, minimize VC emissions by maintaining the pressure between the two seals so that any leak
that occurs is into the compressor; by ducting any vinyl chloride between the two seals through a
control system from which the VC concentration in the exhaust gases does not exceed 10 ppm; or
equivalent.
N/A; see 40 CFR Part 61, Subpart V if complying with that subpart.
Comply with Subpart V, 40 CFR Part 61
Equivalent means of emission limitation
None specified
N/A; see 40 CFR Part 61, Subpart V if complying with that subpart.
N/A; see 40 CFR Part 61, Subpart V if complying with that subpart.
N/A; see 40 CFR Part 61, Subpart V if complying with that subpart.
None specified under Subpart F for compressors complying with Subpart F; see 40 CFR Part 61,
Subpart V if complying with that subpart.
      COMPRESSORS
                                                     page C-117

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                                             COMPRESSORS
                                          APPLICABLE REGULATIONS
  40 CFR Pan 264,
     Subpart CC
      40 CFR Part 265,
     	Subpart CC
40 CFR Part 61,
   Subpart L
40 CFR Part 61,
  Subpart FF
     ITEM
                                     REQUIREMENTS
Reporting
Requirements
Equipment and procedural specifications are being met.

Statement that contains the following:
  •  list of equipment installed for compliance
  »  description of the physical and functional characteristics of each piece of equipment
  •   description of the methods that have been incorporated into the standard operating procedures
    for measuring or calculating the emissions for which emission limits have been prescribed
  »   statement that each piece of equipment is installed and that each piece of equipment and each
    procedure is being used

Quarterly reports; due March 15, June 15, September 15, and December 15:
  •  VC content of emissions for each 3-hour period during which the average emissions are in excess
    of the limits specified for any control system to which fugitive emissions are required to be
    ducted
  •  the number of 3-hour periods determined during the reporting period
  •  if no excess emissions, a statement to that effect

Other reports (within 10 days of any discharge):
  »  information on the source
  »  nature and cause of the discharge
  •  the date and time of the discharge
  *  the approximate total vinyl chloride loss during the discharge
  »  the method used for determining the loss
  •  the action taken to prevent the discharge
  «  measures adopted to prevent future discharges

See 40 CFR Part 61, Subpart V if complying with  that subpart.
                                                COMPRESSORS
                                                                                   pageC-118

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DUAL MECHANICAL SEAL SYSTEM
         APPLICABLE REGULATIONS
40 CFR Part 264,
Subpart CC

40 CFR Part 265,
Subpart CC

              40 CFR Part 61,
                Subpart F
40 CFR Part 61,
Subpart L

40 CFR Part 61,
Subpart FF

ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
REQUIREMENTS
For each dual mechanical seal system;
• operate the barrier fluid at a pressure that is at all times greater than the pump stuffing box
pressure, or
• connect the barrier fluid degassing reservoir by a closed-vent system to a control device, or
• equip with a system that purges the barrier fluid into a process stream with zero VHAP
emissions to the atmosphere
For all dual mechanical seal systems:
• the barrier fluid system shall be in heavy liquid service or not in VOC service
• equip each barrier fluid system with a sensor
• « check each sensor daily or equip with audible alarm
• • determine criterion that indicates failure of the seal system, the barrier fluid system, or both
» perform weekly visual inspections for indications of liquids dripping from the pump seals
Indications of liquids dripping from the pump seal; sensor
Applies as an alternative standard to: Pumps in Light Liquid Service
N/A
Visual, sensor
First attempt within 5 calendar days of detection
Repair as soon as practicable; no later than 15 days after detection
If repair requires use of a DMS that includes a barrier fluid system and repair is completed as soon as
practicable but no later than 6 months after leak detected
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in VOC service
      DUAL MECHANICAL SEAL SYSTEM
pageC-119

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                              DUAL MECHANICAL SEAL SYSTEM
                                         APPLICABLE REGULATIONS
   40 CFR Part 264,
     Subpart CC
      40 CFR Pan 265,
        Subpart CC
40 CFR Pan 61,
   Subpart L
40 CFR Part 61,
  Snbpart FF
     ITEM
                                    REQUIREMENTS
Reconlkeeping
Requirements
Information to be kept in log for 2 years after leak detected:
 «  instrument and operator ID number and equipment ID number
 •  date leak detected
 *  dates of each attempt to repair leak
 *  repair methods applied in each attempt to repair
 •  "above 10,000" if maximum instrument reading after each repair attempt is >_ 10,000 ppm
 »  "repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection
 •  signature of owner/operator whose decision it was that repair could not be effected without a
    process shutdown
 •  expected date of successful repair if leak is not repaired within the 15 days
 •  dates of process unit shutdown that occurred while the equipment is unrepaired
 •  date of successful repair of the leak

Information to be kept for all dual mechanical seal systems:
 •  list of ID numbers of dual mechanical seal systems
 *  list of ID numbers designated for no detectable emissions and signed by owner/operator
Reporting
Requirements
Initial semiannual report:
 «  process unit identification

Subsequent semiannual reports:
 »  the following information by month in the reporting period:
    • • process unit identification
    • • the facts that explain each delay of repair, and where appropriate, why a process unit
        shutdown was technically infeasible

 «  dates of process unit shutdowns that occurred within the semiannual reporting period

 •  revisions to items reported in the initial semiannual report if changes have occurred since the
    initial semiannual report or subsequent revisions to the initial semiannual report
                                      DUAL MECHANICAL SEAL SYSTEM
                                                                                                     page C-120

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                             FLANGES AND OTHER CONNECTORS

                                         APPLICABLE REGULATIONS
40 CFR Part 264,
' Subpart CC

40 CFR Part 265,
Subpart CC

                                                                      40 CFR Part 61,
                                                                         Subpart L	
                                                                         40 CFR Part 61,
                                                                           Subpart FF
     ITEM
                                     REQUIREMENTS
Basic Standard
Monitoring of potential leaks within 5 calendar days of detection if evidence of potential leak is found
by visual, audible, olfactory, or other detection method
Leak Definition
10,000 ppm
Alternative
Standards
Equivalent means of emission limitation
Exemptions
Equipment in vacuum service
Monitoring
Method
Method 21
Repair
Requirements
First attempt within 5 calendar days of detection

Repair as soon as practicable; no later than 15 days after detection
Delay of Repair
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown

Allowed for equipment that is isolated from the process and that does not remain in VHAP service.
Recordkeeping
Requirements
When leak detected:
  •  a weather-proof and readily visible identification, marked with the equipment ID number,
    attached to the leaking equipment
  *  ID may be removed after it has been repaired

Information to be kept in log for 2 years after leak detected:
  •  instrument and operator ED number and equipment ID number
  •  date leak detected
  •  dates of each attempt to repair leak
  •  repair methods applied in each attempt to repair
  •  "above 10,000" if maximum instrument reading after each repair attempt is >, 10,000 ppm
  «  "repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection
  •  signature of owner/operator whose decision it was that repair could not be effected without a
    process shutdown
  •  expected date of successful repair if leak is not repaired within the 15 days
  •  dates of process unit shutdown that occurred while the equipment is unrepaired
  «  date of successful repair of the leak

Information to be kept for all pressure relief devices, flanges and other connectors:
  *  list of ID numbers of subject pressure relief devices, flanges and other connectors
  «  list of ID numbers for  equipment in vacuum service

Information and data used to demonstrate that a pressure relief device is not in VHAP service
                                      FLANGES AND OTHER CONNECTORS
                                                                                   page C-121

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                           FLANGES AND OTHER CONNECTORS

                                       APPLICABLE REGULATIONS
  40 CFR Part 264,
     Subpart CC
      40 CFR Part 265
        Subpan CC
40 CFR Part 61,
  Subpan L
40 CFR Part 61,
  Subpart FF
     ITEM
                                   REQUIREMENTS
Reporting
Requirements
Initial semiannual report:
 *  equipment identification number
 »  process unit number
 «  type of equipment
 »  percent weight VHAP
 *  process fluid state
 «  method of compliance

Subsequent semiannual reports:
 •  process unit identification
 «  the facts that explain each delay of repair, and where appropriate, why a process unit shutdown
    was technically infeasible
 •  dates of process unit shutdowns that occurred within the semiannual reporting period
 •  revisions to items reported in the initial semiannual report if changes have occurred since the
    initial semiannual report or subsequent revisions to the initial semiannual report
                                   FLANGES AND OTHER CONNECTORS
                                                                              page C-122

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                           NO DETECTABLE EMISSIONS
                                APPLICABLE REGULATIONS
40 CFR Part 264,
  Subpart CC
40 CFR Part 265,
  Subpart CC
40 CFR Part 61,
  Subpart F
40 CFR Part 61,
  Sabpart L
40 CFR Part 61,
  Subpart FF
ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
Recordkeeping
Requirements
Reporting
Requirements
REQUIREMENTS
An instrument reading of less than 500 ppm above background as measured by the methods specified
in 60.485(c)
Demonstrate compliance initially upon designation and test annually
500 ppm
Applies as an alternate standard to:
* pumps (must have no externally actuated shaft penetrating the pump housing)
• valves (must have no external actuating mechanism in contact with the process fluid)
« compressors
Applies as regulated standard for:
» closed vent systems
• pressure relief devices in gas/vapor service
N/A
Method 21
N/A
N/A
Information to be kept:
• list of ID numbers of equipment designated for no detectable emission and signed by
owner/operator
• for each compliance test for no detectable emission
* * date conducted
• * background level measured
* • maximum instrument reading
Subsequent semiannual reports:
• dates of process unit shutdowns that occurred within the semi-annual reporting period
» revisions to items reported in the initial semiannual report if changes have occurred since the
initial semiannual report or subsequent revisions to the initial semiannual report
» report of all performance tests
                                NO DETECTABLE EMISSIONS
                                                                page C-123

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OPEN-ENDED VALVES OR LINES
      APPLICABLE REGULATIONS
40CFRPait264, 40 CFR Part 265, 40CFRPart61, 40CFRPan61,
Subpan CC SubpartCC | Subpart F | Subpart L
HHI^II

ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
Recordkeeping
Requirements
Reporting
Requirements
40 CFR Part 61,
Subpart FF


REQUIREMENTS
Use cap, blind flange, plug, or second valve to seal open end at all times except when operations
require flow through open end
Second valve - close valve on process fluid end prior to closing second valve
Double block and bleed system may remain open during operations but comply with basic standard at
all other times
N/A
N/A
Equipment in vacuum service
OELs located on multiple service process lines that operate in VC service less than 10 percent of the
time, provided they are addressed in the process unit/plant area monitoring (system.
Exemption may be extended to OELS demonstrated to require significant retrofit cost to comply with
Subpart V,
N/A
N/A
N/A
Information to be kept for all open-ended valves or lines
• list of ID number of subject open-ended valves or lines
Initial semiannual report:
• equipment identification number
» process unit number
• type of equipment
» percent weight VHAP
• process fluid state
• method of compliance
Subsequent semiannual reports:
« process unit ID
« revisions to items reported in the initial semiannual report if changes have occurred since the
initial semiannual report or subsequent revisions to the initial semiannual report
     OPEN-ENDED VALVES OR LINES
page C-124

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              PRESSURE RELIEF DEVICES IN VINYL CHLORIDE SERVICE
                                        APPLICABLE REGULATIONS
40 CFR Part 264,
Subpart CC

40 CFR Part 265,
Sobpart CC

40 CFR Part 61,
Subpart L

40 CFR Part 61,
Subpart FF

     ITEM
                                   REQUIREMENTS
Basic Standard
Under Subpart F, 40 CFR Part 61:
  •  Discharges: No discharge to the atmosphere.
  •  Leaks:  No detectable emissions (less than 500 ppm above background).
  •  After each release, return to no detectable emissions within 5 calendar days as indicated by
    monitoring of the pressure relief device.

Under Subpart V, 40 CFR Part 61:
  »  No detectable emissions (less than 500 ppm above background)
  •  After each release return to no detectable emissions within 5 calendar days as indicated by
    monitoring of the pressure relief device
Leak Definition
Under Subpart F, 40 CFR Part 61:
  •  Leaks:  "No detectable emissions" - less than 500 ppm above background.

Under Subpart V, 40 CFR Part 61:
  •  500 ppm
Alternative
Standards
Equivalent means of emission limitation
Exemptions
Under Subpart F, 40 CFR Part 61:
  •  Emergency relief discharges or relief valve discharges ducted to control device continually
    operating while the emissions from the release are present at the device.
  •  "Emergency relief discharge" means a discharge that could not have been avoided by taking
    measures to prevent the discharge.

Under Subpart V, 40 CFR Part 61:
  «  Equipment in vacuum service
  *  Pressure relief device equipment with compliant closed-vent system and control device
Monitoring
Method
Method 21
Repair
Requirements
Under Subpart F, 40 CFR Part 61:
  »  Leaks:  Return to condition of "no detectable emissions"
    5 calendar days after pressure release.

Under Subpart V, 40 CFR Part 61:
  -N/A
as soon as practicable but no later than
                           PRESSURE RELIEF DEVICES IN VINYL CHLORIDE SERVICE
                                                                               page C-125

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              PRESSURE RELIEF DEVICES IN VINYL CHLORIDE SERVICE
                                        APPLICABLE REGULATIONS
  40 CFR Part 264,
     SubpartCC
      40 CFR Part 265,
        Subpaft CC
40 CFR Part 61,
  Subpaft L
40 CFR Part 61,
  Subpart FF
     HEM
                                    REQUIREMENTS
Deliy of Repair
Under Subpart F, 40 CFR Part 61:
 •  N/A

Under Subpart V, 40 CFR Part 61:
 «  Allowed if technically infeasible without process unit shutdown; required before end of next
    process unit shutdown
 •  Allowed for equipment that is isolated from the process and that does not remain in VHAP
    service
Recordkeeping
Requirements
Under Subpart F, 40 CFR Part 61:
 •  None specified.

Under Subpart V, 40 CFR Part 61:
 *  Information to be kept for all pressure relief devices:
    • •  list of ID numbers of subject pressure relief devices
    • •  list of ID numbers of pressure relief devices for no detectable emissions and signed by
        owner/operator
    • *  for each compliance test for pressure relief devices designated for no detectable emissions:
        • • »  date conducted
        « * •  background level measured
        • • •  maximum instrument reading
    • •  list of ED numbers for pressure relief devices in vacuum service

 •  Information and data used to demonstrate that a pressure relief device is not in VHAP service
Reporting
Requirements
Under Subpart F, 40 CFR Part 61: Initial report
 *  Equipment and procedural specifications are being met.
 *  Statement that contains the following:
    • •  list of equipment installed for compliance
    • •  description of the physical and functional characteristics of each piece of equipment
    • •  description of the methods that have been incorporated into the staisdard operating
        procedures for measuring or calculating the emissions for which emission limits have been
        prescribed
    • •  statement that each piece of equipment is installed and that each piece of equipment and
        each procedure is being used
Quarterly reports: due March 15, June 15, September 15, and December 15:
 •  VC content of emissions for each 3-hour period during which the average emissions are in excess
    of the limits specified for any control system to which fugitive emissions are required to be
    ducted
 »  the number of 3-hour periods determined during the reporting period
 *  if no excess emissions, a statement to that effect

                                 (Continued on next page)
                           PRESSURE RELIEF DEVICES IN VINYL CHLORIDE SERVICE
                                                                                page C-126

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              PRESSURE RELIEF DEVICES IN VINYL CHLORIDE SERVICE
                                        APPLICABLE REGULATIONS
  40 CFR Part 264,
     Subpart CC
      40 CFR Part 265,
        SubpartCC
40 CFR Part 61,
  Subpart L
40 CFR Part 61,
  Subpart FF
     ITEM
                                   REQUIREMENTS
Reporting
Requirements
(continued)
Other reports (within 10 days of any discharge):
 •  information on the source
 •  nature and cause of the discharge
 •  the date and time of the discharge
 •  the approximate total vinyl chloride loss during the discharge
 »  the method used for determining the loss
 •  the action taken to prevent the discharge
 •  measures adopted to prevent future discharges.

Under Subpart V, 40 CFR Part 61:
 *  Initial semiannual report:
    • •  equipment identification number
    • *  process unit number
    • •  type of equipment
    • *  percent weight VH AP
    « •  process fluid state
    • •  method of compliance

 •  Subsequent semiannual reports:
    * •  process unit identification
    * •  the facts that explain each delay of repair, and where appropriate, why a process unit
        shutdown was technically infeasible
    • •  dates of process unit shutdowns that occurred within the semiannual reporting period
    » •  revisions to items reported in the initial semiannual report if changes have occurred since
        the initial semiannual
    • •  report or subsequent revisions to the initial semiannual report
    * •  report of all performance tests and monitoring to determine compliance with no detectable
        emissions
                           PRESSURE RELIEF DEVICES IN VINYL CHLORIDE SERVICE
                                                                                page C-127

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                         PROCESS UNIT/PLANT AREAS
                               APPLICABLE REGULATIONS
40 CFR Part 264,
  SubpanCC
40 CFR Part 265,
  SubpaitCC
40 CFR Part 61,
  Subpart L
40 CFR Part 61,
  Subpart FF
ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
Recordkeeping
Requirements
REQUIREMENTS
Vinyl chloride (VC) monitoring system capable of detecting major leaks and identification of the
general area of the plant where the leak is located.
System to be operated according to plan developed by plant owner or operator.
Location and number of points to be monitored and the frequency of the monitoring based on the
number of pieces of equipment in VC service and the size and physical layout of the plant.
Determined by plant owner or operator.
Acceptable definition when compared to background concentrations of vinyl chloride in the areas of
the plant to be monitored for leaks.
Definition of a leak may vary from area to area.
IS to change over time as background concentrations are reduced.
N/A
None specified
None specified
Not specified. Plan is to include action to be taken when a leak is detected.
N/A
None specified.
                               FROCKS UNITS/PLANT AREAS
                                                              page C-128

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                                  PROCESS UNIT/PLANT AREAS
                                         APPLICABLE REGULATIONS
  40 CFR Part 264,
     Subpart CC
      40 CFR Part 265,
         Subpart CC
40 CFR Part 61,
  Subpart L
40 CFR Part 61,
  Subpart FF
     ITEM
                                     REQUIREMENTS
Reporting
Requirements
Initial report
  «  Equipment and procedural specifications are being met,
  *  Statement that contains the following:
    • •  list of equipment installed for compliance
    » •  description of the physical and functional characteristics of each piece of equipment
    • •  description of the methods that have been incorporated into the standard operating
        procedures for measuring or calculating the emissions for which emission limits have been
        prescribed
    • •  statement that each piece of equipment is installed and that each piece of equipment and
        each procedure is being used

Quarterly reports: due March 15, June 15, September 15, and December 15:
  •  VC content of emissions for each 3-hour period during which the average emissions are in excess
    of the limits specified for any control system to  which fugitive emissions are required to be
    ducted
  «  the number of 3-hour periods determined during the reporting period
  •  if no excess emissions, a statement to that effect

Other reports (within 10 days of any discharge):
  •  information on the source
  •  nature and cause of the discharge
  »  the date and time of the discharge
  •  the approximate total vinyl chloride loss during  the discharge
  •  the method used for determining the loss
  *  the action taken to prevent the discharge
  «  measures adopted to prevent future discharges.
                                         PROCESS UNITS/PLANT AREAS
                                                                                   page C-129

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                             PRODUCT ACCUMULATOR VESSELS
                                        APPLICABLE REGULATIONS
40 CFR Part 264,
Subpart CC

40 CER Part 265,
Subpart CC

40 CFR Part 61,
Subpart L

40 CFR Part 61,
Subpart FF

     ITEM
                                   REQUIREMENTS
Basic Standard
Compliant closed-vent system and control device
Leak Definition
N/A
Alternative
Standards
N/A
Exemptions
Equipment in vacuum service
Monitoring
Method
Method 21
Repair
Requirements
N/A
Delay of Repair
Allowed if repair is technically infeasible without process unit shutdown; required before end of next
process unit shutdown

Allowed for equipment that is isolated from the process and that does not remain in organic VHAP
service
Recordkeeping
Requirements
Information to be kept for all product accumulator vessels:
 «  list of ID numbers of subject product accumulator vessels
 •  list of ID numbers for product accumulator vessels in vacuum service
Reporting
Requirements
Initial semiannual report:
 •  process unit identification
 «  equipment identification number
 «  type of equipment
 •  percent weight VHAP
 •  process fluid state
 »  method of compliance

Subsequent semiannual reports:
 •  process unit identification

 »  dates of process unit shutdowns that occurred within the semiannual reporting period

 *  revisions to items reported in the initial semiannual report if changes have occurred since the
    initial semiannual report or subsequent revisions to the initial semiannual report
                                    PRODUCT ACCUMULATOR VESSELS
                                                                               page C-130

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PUMPS IN VINYL CHLORIDE SERVICE
          APPLICABLE REGULATIONS
40 CFR Part 264,
Subpart CC

40 CFR Part 265,
Subpart CC

                40 CFR Part 61,
                  Subpart F
40 CFR Part 61,
  SnbpartL
40 CFR Part 61,
  Subpart FF
ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
Recordkeeping
Requirements
Reporting
Requirements
REQUIREMENTS
Rotating Pumps
Minimize VC emissions by installing sealless pumps, pumps with double mechanical seals or
equivalent. If double mechanical seals are used, minimize VC emissions by maintaining the pressure
between the two seals so that any leak that occurs is into the pump; by ducting any vinyl chloride
between the two seals through a control system from which the VC concentration in the exhaust gases
does not exceed 10 ppm; or equivalent.
Reciprocating Pumps
Minimize VC emissions by installing double outboard seals, or equivalent. If double outboard seals
are used, minimize VC emissions by maintaining the pressure between the two seals so that any leak
that occurs is into the pump; by ducting any vinyl chloride between the two seals through a control
system from which the VC concentration in the exhaust gases does not exceed 10 ppm; or equivalent.
N/A; see 40 CFR Part 61, Subpart V if complying with that subpart.
Equivalent means of emission limitation
Comply with Subpart V, 40 CFR Part 61
None specified
N/A; see 40 CFR Part 61, Subpart V if complying with that subpart.
N/A; see 40 CFR Part 61, Subpart V if complying with that subpart.
N/A; see 40 CFR Part 61 , Subpart V if complying with that subpart.
None specified for under Subpart F for compressors complying with Subpart F; see 40 CFR Part 61,
Subpart V if complying with that subpart.
Equipment and procedural specifications are being met.
Statement that contains the following:
• list of equipment installed for compliance
• description of the physical and functional characteristics of each piece of equipment
• description of the methods that have been incorporated into the standard operating procedures
for measuring or calculating the emissions for which emission limits have been prescribed
• statement that each piece of equipment is installed and that each piece of equipment and each
procedure is being used
(Continued on next page) "
       PUMPS IN VINYL CHLORIDE SERVICE
                                                          page C-131

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                            PUMPS IN VINYL CHLORIDE SERVICE
                                        APPLICABLE REGULATIONS
  40CFRPlit264,
     SubpanCC
      40 CFR Part 265,
        SubpanCC
40 CFR Part 61,
  Subpart L
40 CPR Part 61,
  Subpart FF
     ITEM.
                                   REQUIREMENTS
Reporting
Requirements
(continual)
Quarterly reports: due March 15, June 15, September 15, and December 15:
 «  VC content of emissions for each 3-hour period during which the average emissions are in excess
    of the limits specified for any control system to which fugitive emissions are required to be
    ducted
 *  the number of 3-hour periods determined during the repotting period
 •  if no excess emissions, a statement to that effect

Other reports (within 10 days of any discharge):
 «  information on the source
 *  nature and cause of the discharge
 »  the date and time of the discharge
 *  the approximate total vinyl chloride loss during the discharge
 •  the method used for determining the loss
 «  the action taken to prevent the discharge
 •  measures adopted to prevent future discharges.

See 40 CFR Part 61, Subpart V if complying with that subpart.
                                    PUMPS IN VINYL CHLORIDE SERVICE
                                                                                page C-132

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                              SAMPLING CONNECTION SYSTEMS
                                         APPLICABLE REGULATIONS
40 CFR Pan 264,
Subpart CC

40 CFR Part 265,
Subpart CC

                                                40 CFR Part 61,
                                                  Subpart F
40 CFR Part 61,
Subpart L

40 CFR Part 61,
Subpart FF

     ITEM
                                    REQUIREMENTS
Basic Standard
Unused portions of samples containing at least 10 percent by weight VC are to be returned to the
process or destroyed in a compliant control device. Sampling techniques are to be such that samples
containers in VC service are purged into a closed process system.
Leak Definition
N/A
Alternative
Standards
Comply with Subpart V, 40 CFR Part 61
Exemptions
N/A
Monitoring
Method
N/A
Repair
Requirements
N/A
Delay of Repair
N/A
Recordkeeping
Requirements
None specified under Subpart F for sampling connection systems complying with Subpart F; see 40
CFR Part 61, Subpart V if complying with that subpart.
Reporting
Requirements
Equipment and procedural specifications are being met.

Statement that contains the following:
  »  list of equipment installed for compliance
  •  description of the physical and functional characteristics of each piece of equipment
  »   description of the methods that have been incorporated into the standard operating procedures
    for measuring or calculating the emissions for which emission limits have been prescribed
  *   statement that each piece of equipment is installed and that each piece of equipment and each
    procedure is being used

Quarterly reports: due March 15, June 15, September 15, and December 15:
  «  VC content of emissions for each 3-hour period during which the average emissions are in excess
    of the limits specified for any control system to which fugitive emissions are required to be
    ducted
  »  the number of 3-hour periods determined during the reporting period
  •  if no excess emissions, a statement to that effect

                                  (Continued on next page)
                                      SAMPLING CONNECTION SYSTEMS
                                                                                  page C-133

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                             SAMPLING CONNECTION SYSTEMS

                                       APPLICABLE REGULATIONS
  40 CFR Part 264,
     Subpart CC
      40 CFR Part 265.
        Subpart CC
40 CFR Part 61,
  Subpart F
40 CFR Part 61,
  Subpart L
40 CFR Part 61,
  SiibpartPP
     ITEM
                                  REQUIREMENTS
Reporting
Requirements
(continued)
Other reports (within 10 days of any discharge):
 »  information on the source
 *  nature and cause of the discharge
 »  the date and time of the discharge
 »  the approximate total vinyl chloride loss during the discharge
 •  the method used for determining the loss
 •  the action taken to prevent the discharge
 «  measures adopted to prevent future discharges.

See 40 CER Part 61, Subpart V if complying with that subpart.
                                    SAMPLING CONNECTION SYSTEMS
                                                                             page C-134

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VALVES IN VINYL CHLORIDE SERVICE
          APPLICABLE REGULATIONS
40 CFR Part 264, 40 CFR Part 265, 40 CFR Part 61, 40 CFR Part 61,
SubpartCC SubpartCC SubpartF 1 SubpartL
li^HHIH

ITEM
Basic Standard
Leak Definition
Alternarive
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
40 CFR Part 61,
Subpart FF


REQUIREMENTS
Monthly leak detection and repair
If valve does not leak for 2 months, may be monitored quarterly
If valve leaks, monitor monthly until no leak is detected for 2 consecutive months
10,000 ppm

Equivalent means of emission limitation
No detectable emissions
Valves designated unsafe to monitor or difficult to monitor
Allowable percentage of valves leaking or skip period leak detection and
repair
Valves in vacuum service
Method 21
First attempt within 5 calendar days of detection
Repair as soon as practicable; no later than 15 days after detection
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in VHAP service
Allowed if emissions of purged material from immediate repair would exceed fugitive emissions from
delay of repair, and purged materials are collected and destroyed or recovered in a control device
when repair occurs
Allowed beyond process unit shutdown if otherwise sufficient supply of valve assembly replacements
are exhausted
       VALVES IN VINYL CHLORIDE SERVICE
page C-135

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                            VALVES IN VINYL CHLORIDE SERVICE
                                         APPLICABLE REGULATIONS
   40 CFR Part 264,
     SubpartCC
      40 CFR Part 265,
         SubpartCC
40 CFR Part 61,
   Subpart L
40 CFR Part 61,
  Subpart FF
     ITEM
                                    REQUIREMENTS
Recordkeeping
Requirements
When leak detected:
  «  a weather-proof and readily visible identification, marked with the equipment ID number,
    attached to the leaking equipment
  •  ID may be removed after it has been repaired and monitored for 2 months with no leaks

Information to be kept in log for 2 years after leak detected:
  •  instrument and operator ID number and equipment ID number
  *  date leak detected
  •  dates of each attempt to repair leak
  »  repair methods applied in each attempt to repair
  «  "above 10,000" if maximum instrument reading after each repair attempt is j>_ 10,000 ppm
  •  "repair delayed" and reason for delay is leak not repaired within 15 calendar days after detection
  «  signature of owner/operator whose decision it was that repair could not be effected without a
    process shutdown
  •  expected date of successful repair if leak is not repaired with the 15 days
  «  dates of process unit shutdown that occurred while the equipment is unrepaired
  »  date of successful repair of the leak

Information to be kept for all valves:
  »  list of E> numbers of subject valves
  •  list of ID numbers of valves designated for no detectable emissions and signed by owner/operator
  «  for each compliance test for valves designated for no detectable emissions
    « •  date conducted
    • •  background level measured
    « •  maximum instrument reading
  »      List of ID numbers for valves in vacuum service

Information and data used to demonstrate that a valve is not in VHAP service
Reporting
Requirements
Initial semiannual report:
 •  valve ID number
 •  process unit identification
 «  type of equipment
 *  percent weight VHAP
 •  process fluid state
 »  method of compliance

Subsequent semiannual reports:
 *  process unit identification
 •  the following information by month in the reporting period:
    • •  number of valves for  which leaks were detected
    • •  number of valves for  which leaks were not repaired within 15 days after detection
    • •  the facts that explain each delay of repair, and where appropriate, why a process unit
        shutdown was technically infeasible
 *  dates of process unit shutdowns that occurred within the semiannual reporting period
 •  revisions to items reported in the initial semiannual report if changes have occurred since the
    initial semiannual report or subsequent revisions to the initial semiannual report
 «  report of all performance tests in accordance with alternative standards
                                    VALVES IN VINYL CHLORIDE SERVICE
                                                                                  page C-136

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CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                 APPLICABLE REGULATIONS
40 CFR Part 264,
Subpart CC

40 CER Part 265,
Subpart CC

40 CFR Part 61,
Subpart F

                                         40 CFR Part 61,
                                           Subpart L
40 CFR Part 61,
  Subpart FF
ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
REQUIREMENTS
Control Devices:
• vapor recovery systems: 95 percent or greater recovery
• enclosed combustion devices: 95 percent or greater reduction or minimum residence time of
0.50 seconds and minimum temperature of 760°C
• flares: comply with §60.18
Closed- Vent Systems:
• no detectable emissions (less than 500 ppm above background) and no visual indications
• control devices and closed-vent systems to be operated at all times that emissions may be vented
to them
Monitoring:
« control devices: monitor to ensure operated and maintained in conformance with their designs
• closed-vent systems: initially, annually, and at other times as requested by the Administrator
Closed-vent system: 500 ppm
N/A
N/A
Method 21
As soon as practicable, but no later than 15 calendar days after detection
First attempt to repair within 5 calendar days of detection
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in VHAP service
         CLOSED-VENT SYSTEMS AND CONTROL DEVICES
        page C-137

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                     CLOSED-VENT SYSTEMS AND CONTROL DEVICIiS
                                         APPLICABLE REGULATIONS
40 CFR Pan 264.
Subptrt CC

40 CFR Part 265,
Subpart CC

40 CFR Part 61,
Subpart F

                                                                      40 CFR Part 61,
                                                                         Subpart L
                                                                        40 CFR Part 61,
                                                                          Subpait FF
     ITEM
                                    REQUIREMENTS
Recordkeeping
Requirements
When leak detected:
  •  a weather-proof and readily visible identification marked with the equipment ID number;
    attached to the leaking equipment
  •  ID may be removed after it has been repaired

Information to be kept in log for 2 years after leak detected:
  •  instrument and operator ID number and equipment ID number
  •  date leak detected
  •  dates of each attempt to repair leak
  «  repair methods applied in each attempt to repair
  •  "above 10,000" if maximum instrument reading after each repair attempt is >. 10,000 ppm
  •  "repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection
  •  signature of owner/operator whose decision it was that repair could not be effected without a
    process shutdown
  •  expected  date of successful repair if leak is not repaired with the 15 days
  •  dates of process unit shutdown that occurred while the equipment is unrepaired
  •  date of successful repair of the leak

Information to be kept for all closed-vent systems and control devices:
  •  detailed schematics, design specifications, and piping and instrumentation diagrams
  »  dates and descriptions of any changes in design specifications
  «  description of parameter(s) to be monitored to ensure proper operation and maintenance
  «  explanation of selected parameter(s)
  *  periods of non-operation according to design
  •  dates of startups and shutdown
  •  list of ID numbers of subject closed-vent systems and control devices
  •  list of ID numbers of closed-vent systems and control devices designated for no detectable
    emissions and signed by owner/operator
  •  for each compliance test for closed-vent systems and control devices designated for no detectable
    emissions
    • •  date conducted
    • •  background level measured
    * •  maximum instrument reading
  •  list of ID numbers for closed-vent  systems and control devices in vacuum service
Reporting
Requirements
Initial semiannual report:
  •  process unit identification
  »  equipment identification number
  •  type of equipment
  •  percent weight VHAP
  »  process fluid state
  •  method of compliance

Subsequent semiannual reports:
  «  process unit identification
  «  dates of process unit shutdowns that occurred within the semiannual reporting period
  •  revisions to items reported in the initial semiannual report if changes have occurred since the
    initial semiannual report or subsequent revisions to the initial semiannual report
  •  report of all performance tests to determine compliance with no detectable emissions
                                CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                                                                                  page C-138

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DUAL MECHANICAL SEAL SYSTEM
         APPLICABLE REGULATIONS
40 CFR Part 264,
Subpart CC

40 CFR Part 265,
Subpart CC

40 CFR Part 6
Subpart F

                                 40 CFR Part 61,
                                   Subpart L
40 CFR Pan 61,
  Subpart FF
ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
REQUIREMENTS
For each dual mechanical seal system;
» operate the barrier fluid at a pressure that is at all times greater than the pump stuffing box
pressure, or
• connect the barrier fluid degassing reservoir by a closed-vent system to a control device, or
» equip with a system that purges the barrier fluid into a process stream with zero VHAP
emissions to the atmosphere
For all dual mechanical seal systems:
» the barrier fluid system shall be in heavy liquid service or not in VOC service
» equip each barrier fluid system with a sensor
» • check each sensor daily or equip with audible alarm
• • determine criterion that indicates failure of the seal system, the barrier fluid system, or both
» perform weekly visual inspections for indications of liquids dripping from the pump seals
Indications of liquids dripping from the pump seal; sensor
Applies as an alternative standard to: Pumps in Light Liquid Service
N/A
Visual, sensor
First attempt within 5 calendar days of detection
Repair as soon as practicable; no later than 15 days after detection
If repair requires use of a DMS that includes a barrier fluid system and repair is completed as soon as
practicable but no later than 6 months after leak detected
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in VOC service
       DUAL MECHANICAL SEAL SYSTEM
        page C-139

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                              DUAL MECHANICAL SEAL SYSTEM
                                         APPLICABLE REGULATIONS
   40 CFR Pan 264,
     Subpart CC
      40 CFR Part 265,
        Subpart CC
40 CFR Part 61,
   Subpart F
40 CFR Part 61,
   Subpart L
40 OFR Part 61,
  Subpart FF
     ITEM
                                    REQUIREMENTS
Recordkeeping
Requirements
Information to be kept in log for 2 years after leak detected:
  •  instrument and operator ID number and equipment ID number
  »  date leak detected
  »  dates of each attempt to repair leak
  •  repair methods applied in each attempt to repair
  •  "above 10,000" if maximum instrument reading after each repair attempt is > 10,000 ppm
  «  "repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection
  *  signature of owner/operator whose decision it was that repair could not be effected without a
    process shutdown
  *  expected date of successful repair if leak is not repaired within the 15 dzys
  •  dates of process unit shutdown that occurred while the equipment is unrepaired
  »  date of successful repair of the leak

Information to be kept for all dual mechanical seal systems:
  *  list of ID numbers of dual mechanical seal systems
  •  list of ID numbers designated for no detectable emissions and signed by owner/operator
Reporting
Requirements
Initial semiannual report:
 •  process unit identification

Subsequent semiannual reports:
 »  the following information by month in the reporting period:
    • •  process unit identification
    • •  the facts that explain each delay of repair, and where appropriate, why a process unit
        shutdown was technically infeasible
 »  dates of process unit shutdowns that occurred within the semiannual reporting period
 »  revisions to items reported in the initial semiannual report if changes have occurred since the
    initial semiannual report or subsequent revisions to the initial semiannual report
                                      DUAL MECHANICAL SEAL SYSTEM
                                                                                  page C-140

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                                              EXHAUSTERS
                                          APPLICABLE REGULATIONS
40 CFR Part 264,
Subpart CC

40 CFR Part 265,
Subpart CC

40 CFR Part e
Subpart F

                                                                       40 CFR Part 61,
                                                                         Subpart L
                                                                          40 CFR Part 61,
                                                                            Subpart FF
     ITEM
                                     REQUIREMENTS
Basic Standard
 Option 1:
  • Monitor quarterly

 Option 2:
  • Equipped with compliant seal system that prevents leakage to atmosphere
  • Install sensor to detect failure of seal system
  • Check sensor daily or equip with audible alarm
  • Establish criteria basic standard that indicates failure of seal system or barrier fluid system or
    both
Leak Definition
 Option 1: 10,000 ppm

 Option 2: Sensor indicates failure of seal or barrier fluid system or both based on established
 criteria.
Alternative
Standards
 Equivalent means of emission limitation

 No detectable emissions, operate less than 500 ppm above background

 Closed-vent system and control device
Exemptions
 Equipment in vacuum service
Monitoring
Method
 Option 1: Method 21

 Option 2: Sensor alarm or visual check
Repair
Requirements
 First attempt within 5 calendar days of detection

 Repair as soon as practicable; no later than 15 calendar days after detection
Delay of Repair
 Allowed if technically infeasible without process unit shutdown; required before end of next process
 unit shutdown

 Allowed for equipment that is isolated from the process and that does not remain in VHAP service
Recordkeeping
Requirements
 When leak detected:
  •  a weather-proof and readily visible identification, marked with the equipment ID number,
     attached to the leaking equipment
  •  ID may be removed after it has been repaired

	(Continued on next page)	
                                                 EXHAUSTERS
                                                                                                       page C-141

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                                             EXHAUSTERS
   40 CFR Pan 264,
     Subpart CC
      40 CFR Part 265,
         SubpartCC
                                         APPLICABLE REGULATIONS
40 CFR Part 61,
   Subpart F
40 CFR Part 61,
   Subpart L
40 CFR Part 61,
  Subpart FF
      ITEM
                                     REQUIREMENTS
Rccordkeeping
Requirements
(continued)
Information to be kept in log for 2 years after leak detected:
  *  instrument and operator ID number and equipment ID number
  »  date leak detected
  •  dates of each attempt to repair leak
  »  repair methods applied in each attempt to repair
  •  "above 10,000" if maximum instrument reading after each repair attempt is J>. 10,000 ppm
  »  "repair delayed* and reason for delay if leak not repaired within 15 calendar days after detection
  •  signature of owner/operator whose decision it was that repair could not be affected without a
    process shutdown
  •  expected date of successful repair if leak is not repaired within the 15 days
  •  dates of process unit shutdown that occurred while the equipment is unrepaired
  •  date of successful repair of the leak

Information to be kept for all compressors:
  «  list of ID numbers of subject compressors
  •  list of ID numbers of compressors designated for no detectable emissions and signed by
    owner/operator
  •  for each compliance test for compressors designated for no detectable emissions
    • • date conducted
    • • background level measured
    * • maximum instrument reading
  •  list of ID numbers for compressors in vacuum service
Reporting
Requirements
Initial semiannual report:
 •  equipment identification number
 •  process unit number
 •  type of equipment
 «  percent weight VHAP
 •  process fluid state
 «  method of compliance

Statement that the requirements of this subpart and 40 CFR Part 61, Subpart V have been
implemented
Subsequent semiannual reports:
 •  process unit identification
    • »  number of exhausters for which leaks were detected
    • •  number of exhausters for which leaks were repaired as required
 «  dates of process unit shutdowns that occurred within the semiannual reporting period
 •  revisions to items reported in the initial semiannual report if changes have occurred since the
    initial semiannual report or subsequent revisions to the initial semiannual report
 «  report of all performance tests and monitoring to determine compliance with no detectable
    emissions
                                                EXHAUSTERS
                                                                                   page C-142

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 LIGHT-OIL SUMPS
APPLICABLE REGULATIONS
40 CFR Part 264,
Subpart CC

40 CFR Part 265,
Subpart CC

40 CFR Part <
Subpart F

                        40 CFR Pan 61,
                          Stibpart L
40 CFR Part 61,
  Subpan FF
ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
REQUIREMENTS
Option 1:
• Enclose and seal the liquid surface in the sump to form a closed system to contain the emissions.
Option 2:
• Install, operate, and maintain a vent on the light-oil sump cover. Equip each vent pipe with a
water leg seal, a pressure relief device, or vacuum relief device.
Option 3:
• Install, operate, and maintain an access hatch on each light-oil sump cover. Equip each hatch
with a gasket and a cover, seal, or lid that is kept closed except when in use.
Covers may be removed for maintenance but must be replaced with seal at completion of
maintenance.
If control equipment is used to comply:
» monitor the connections and seals on each control system to "determine if it is operating with no
detectable emissions.
» visually inspect each source, including sealing materials, for evidence of visible defects (e.g.,
tears, gaps).
« conduct this monitoring and inspection semiannually and at any other time the cover is removed.
Monitoring: 500 ppmv above background level
Visual: visible defects are observed
N/A
N/A
Method 21, 40 CFR Part 60, Appendix A
As soon as practicable, but no later than 15 days after detection
First attempt to repair within 5 calendar days of detection
Allowed if repair is technically infeasible without process unit shutdown; required before end of next
process unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in organic VHAP "
service
     LIGHT-OIL SUMPS
        page C-143

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                                          LIGHT-OIL SUMPS
                                         APPLICABLE REGULATIONS
  40 CFR Part 264,
     SubpanCC
      40 CFR Part 265,
        Subpart CC
40 CFR Pan 61,
   Subpart F
40 CFR Part 61,
  Subpart L
40 CFR Part 61,
  Subpart FF
      ITEM
                                    REQUIREMENTS
Recordkeeping
Requirements
Record and maintain the following for two-years:
 •  date of the inspection and the name of the inspector
 •  brief description of each visible defect in the source or control equipment and the method and
    date of repair of the defect
 •  the presence of a leak including the date of attempted and actual repair and the method of repair
    of the leak
 •  brief description of any system abnormalities found during the annual maintenance inspection,
    the repair made, the date of attempted repair, and the date of actual repair
Reporting
Requirements
Statement that the requirements of this subpart and 40 CFR Part 61, Subpart V have been
implemented
 •  type of source
 •  for equipment in benzene service:
    • •  equipment identification number
    » «  process unit identification
    » •  percent by weight benzene in the fluid at the equipment
    • •  process fluid state in the equipment
 «  method of compliance

Subsequent semiannual reports:
 •  brief description of any visible defects in the source or ductwork
 •  the number of leaks detected
 •  brief description of any system abnormalities found during the annual maintenance inspection
    that occurred in the reporting period and the repairs made
 «  a signed statement stating whether all the provision of Subpart L have been fulfilled during the
    semiannual reporting period
 •  revisions to items reported in the initial statement
                                               LIGHT-OIL SUMPS
                                                                                  page C-144

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NO DETECTABLE EMISSIONS
     APPLICABLE REGULATIONS
40 CFR Part 264,
Subpart CC

40 CFR Part 265,
Subpart CC

40 CFR Pane
Subpart F

                            40 CFR Part 61.
                              Subpart L
40 CFR Part 61,
  Subpart FF
ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
Recordkeeping
Requirements
Reporting
Requirements
REQUIREMENTS
An instrument reading of less than 500 ppm above background as measured by the methods specified
in 60.485(c)
Demonstrate compliance initially upon designation and test annually
500 ppm
Applies as an alternate standard to:
« pumps (must have no externally actuated shaft penetrating the pump housing)
• valves (must have no external actuating mechanism in contact with the process fluid)
• compressors
Applies as regulated standard for:
« closed vent systems
• pressure relief devices in gas/vapor service
N/A
Method 21
N/A
N/A
Information to be kept:
« list of ID numbers of equipment designated for no detectable emission and signed by
owner/operator
» for each compliance test for no detectable emission:
• • date conducted
• • background level measured
• • maximum instrument reading
Subsequent semiannual reports:
• dates of process unit shutdowns that occurred within the semi-annual reporting period
• revisions to items reported in the initial semiannual report if changes have occurred since the
initial semiannual report or subsequent revisions to the initial semiannual report
» report of all performance tests
      NO DETECTABLE EMISSIONS
        page C-145

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                        OPEN-ENDED VALVES OR LINES
                               APPLICABLE REGULATIONS
40 CFR Part 264,
  Subpart CC
40 CFR Pan 265,
  SubpartCC
40 CFR Part 61,
  Subpart F
40 CFR Part 61,
  Subpart L
40 CFR Part 61,
  Subpart FF
ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
Recordkeeping
Requirements
Reporting
Requirements
REQUIREMENTS
Use cap, blind flange, plug, or second valve to seal open end at all times except when operations
require flow through open end
Second valve - close valve on process fluid end prior to closing second valve
Double block and bleed system may remain open during operations but comply with basic standard at
all other times
N/A
N/A
Equipment in vacuum service
N/A
N/A
N/A
Information to be kept for all open-ended valves or lines
• equipment ID number of subject open-ended valves or lines
Initial semiannual report:
equipment identification number
process unit number
type of equipment
percent weight VHAP
process fluid state
method of compliance
Subsequent semiannual reports:
• process unit ID
• revisions to items reported in the initial semiannual report if changes have occurred since the
initial semiannual report or subsequent revisions to the initial semiannual report
                              OPEN-ENDED VALVES OR LINES
                                                               page C-146

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                  PRESSURE RELIEF DEVICES IN GAS/VAPOR SERVICE
                                        APPLICABLE REGULATIONS
40 CFR Part 264,
Subpart CC

40 CFR Part 265,
Subpart CC

40 CFR Part
Snbpart F

                                                                    40 CFR Part 61,
                                                                       Subpart L
                                                                      40 CFR Part 61,
                                                                        Subpart FF
     ITEM
                                   REQUIREMENTS
Basic Standard
No detectable emissions (less than 500 ppm above background)

After each release return to no detectable emissions within 5 calendar days as indicated by monitoring
of the pressure relief device
Leak Definition
500 ppm
Alternative
Standards
Equivalent means of emission limitation
Exemptions
Equipment in vacuum service

Pressure relief device equipment with compliant closed-vent system and control device
Monitoring
Method
Method 21
Repair
Requirements
N/A
Delay of Repair
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown

Allowed for equipment that is isolated from the process and that does not remain in VHAP service
Recordkeeping
Requirements
Information to be kept for all pressure relief devices:
  •  list of ID numbers of subject pressure relief devices
  «  list of ID numbers of pressure relief devices for no detectable emissions and signed by
    owner/operator
  •  for each compliance test for pressure relief devices designated for no detectable emissions:
    ««  date conducted
    • •  background level measured
    • •  maximum instrument reading
  »  list of ID numbers for pressure relief devices in vacuum service

Information and data used to demonstrate that a pressure relief device is not in VHAP service
                              PRESSURE RELIEF DEVICES IN GAS/VAPOR SERVICE
                                                                                page C-147

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                 PRESSURE RELIEF DEVICES IN GAS/VAPOR SERVICE
                                       APPLICABLE REGULATIONS
  40 CFR Part 264,
     SubpanCC
      40 CFR Part 265,
        SubpartCC
40 CFR Part 61,
  Subpait F
40 CFR Pan 61,
  Subpart L
40 CFR Part 61,
  Subpart FF
     ITEM
                                  REQUIREMENTS
Reporting
Requirements
Initial semiannual report:
 •  equipment identification number
 «  process unit number
 *  type of equipment
 »  percent weight VHAP
 •  process fluid state
 •  method of compliance

Subsequent semiannual reports:
 •  process unit identification
 •  the facts that explain each delay of repair, and where appropriate, why a process unit shutdown
    was technically inffeasible
 »  dates of process unit shutdowns that occurred within the semiannual reporting period
 •  revisions to items reported in the initial semiannual report if changes have occurred since the
    initial semiannual report or subsequent revisions to the initial semiannual report
 *  report of all performance tests and monitoring to determine compliance with no detectable
    emissions
                             PRESSURE RELIEF DEVICES IN GAS/VAPOR SERVICE
                                                                             page C-148

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                    PRESSURE RELIEF DEVICES IN LIQUID SERVICES,
                            FLANGES AND OTHER CONNECTORS
                                       APPLICABLE REGULATIONS
40 CER Part 264,
Subpart CC-

40 CFR Part 265,
Subpart CC

40 CFR Part <
Subpart F

                                                                   40 CFR Part 61.
                                                                      Subpart L
                                                                      40 CFR Part 61,
                                                                        Subpart FF
     ITEM
                                   REQUIREMENTS
Basic Standard
Monitoring of potential leaks within 5 calendar days of detection if evidence of potential leak is found
by visual, audible, olfactory, or other detection method
Leak Definition
 10,000 ppm
Alternative
Standards
Equivalent means of emission limitation
Exemptions
Equipment in vacuum service
Monitoring
Method
Method 21
Repair
Requirements
First attempt within 5 calendar days of detection

Repair as soon as practicable; no later than 15 days after detection
Delay of Repair
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown

Allowed for equipment that is isolated from the process and that does not remain in VHAP service.
Recordkeeping
Requirements
 When leak detected:
  • a weather-proof and readily visible identification, marked with the equipment ID number,
    attached to the leaking equipment
  • ID may be removed after it has been repaired

 Information to be kept in log for 2 years after leak detected:
  » instrument and operator ED number and equipment ID number
  » date leak detected
  • dates of each attempt to repair leak
  • repair methods applied in each attempt to repair
  * "above 10,000* if maximum instrument reading after each repair attempt is _>, 10,000 ppm
  • "repair delayed" and reason for delay if leak not repaired within 15 calendar days after detection
  • signature of owner/operator whose decision it was that repair could not be effected without a
    process shutdown
  • expected  date of successful repair if leak is not repaired within the 15 days
  • dates of process unit shutdown that occurred while the equipment is unrepaired
  • date of successful repair of the leak

	(Continued on next page)	
                               PRESSURE RELIEF DEVICES IN LIQUID SERVICES,
                                    FLANGES AND OTHER CONNECTORS
                                                                               page C-149

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                   PRESSURE RELIEF DEVICES IN LIQUID SERVICES,
                         .  FLANGES AND OTHER CONNECTORS
                                      APPLICABLE REGULATIONS
  40 CFR Pan 264,
     Subpait CC
     40 CFR Part 265,
        Subpart CC
40 CFR Part 61,
  Subpart F
40 CFR Part 61,
  Subpart L
40 CFR Part 61,
  Subpart FF
     ITEM
                                 REQUIREMENTS
Reeordkeeping
Requirements
(continued)
Information to be kept for all pressure relief devices, flanges and other connectors:
 »  list of DO numbers of subject pressure relief devices, flanges and other connectors
 »  list of ID numbers for equipment in vacuum service

Information and data used to demonstrate that a pressure relief device is not in VHAP service
Reporting
Requirements
Initial semiannual report:
 •  equipment identification number
 •  process unit number
 •  type of equipment
 •  percent weight VHAP
 *  process fluid state
 »  method of compliance

Subsequent semiannual reports:
 •  process unit identification
 •  the facts that explain each delay of repair, and where appropriate, why a process unit shutdown
    was technically infeasible
 •  dates of process unit shutdowns that occurred within the semiannual reporting period
 •  revisions to items reported in the initial semiannual report if changes have occurred since the
    initial semiannual report or subsequent revisions to the initial semiannual  report
                             PRESSURE RELIEF DEVICES IN LIQUID SERVICES,
                                  FLANGES AND OTHER CONNECTORS
                                                                            page C-150

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  PROCESS VESSELS, STORAGE TANKS, AND TAR-INTERCEPTING SUMPS

                              APPLICABLE REGULATIONS
40 CFR Part 264,
  Subpart CC
40 CFR Part 265,
  Subpart CC
40 CFR Part 61,
  Subpart F
40 CFR Part 61,
  Subpart L
40 CFR Part 61,
 Subpart FF
ITEM
Basic Standard
Leak Definition
" Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
REQUIREMENTS
Option 1:
• Duct to a control device designed and operated for no detectable emissions as indicated by an
instrument reading of less than 500 ppmv above background and visual inspections.
* Monitor the connections and seals on each control system to determine if it is operating with no
detectable emissions.
• Visually inspect each source, including sealing materials, and the ductwork of the control system
for evidence of visible defects (e.g., tears, gaps).
• Conduct monitoring and visually inspection semi-annually and at any other time after the control
system is repressurized.
Option 2:
• Install, operate, and maintain a pressure relief device, vacuum relief device, access hatch, and
sampling port. Equip each hatch and sampling port with gasket and cover, seal, or lid that is
closed at all times except when in use.
« Use of sludge conveyors requires operation of water leg seal on tar decanter roof to ensure
enclosure of the major portion of the liquid surface not necessary of its operation.
Monitoring: 500 ppmv above background level
Visual: visible defects are observed
N/A
N/A
Method 21
As soon as practicable, but no later than 15 days after detection
First attempt to repair within 5 calendar days of detection
Allowed if repair is technically infeasible without process unit shutdown; required before end of next
process unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in VHAP service
               PROCESS VESSELS, STORAGE TANKS, AND TAR-INTERCEPTING SUMPS
                                                           page C-151

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     PROCESS VESSELS, STORAGE TANKS, AND TAR-INTERCEPTING SUMPS

                                        APPLICABLE REGULATIONS
  40 CFR Part 264,
     Subpart CC
      40 CFR Part 265,
        Subpart CC
40 CFR Part 61,
  Subpart F
40 CFR Part 61,
  Subpart L
40 CFR Part 61,
  Subpart FF
     ITEM
                                   REQUIREMENTS
Rccordkeeping
Requirements
Record and maintain the following for two-years:
 •  date of the inspection and the name of the inspector
 »  brief description of each visible defect in the source or control equipment and the method an date
    of repair of the defect
 »  the presence of a leak including the date of attempted and actual repair and the method of repair
    of the leak
 »  brief description of any system abnormalities found during the annual maintenance inspection,
    the repair made, the date of attempted repair, and the date of actual repair
Reporting
Requirements
Statement that the requirements of this subpart and 40 CFR Part 61, Subpart V have been
implemented
 »  type of source
 •  for equipment in benzene service
    • •  equipment identification number
    • •  process unit identification
    » •  percent by weight benzene in the fluid at the equipment
    • •  process fluid state in the equipment
 »  method of compliance

Subsequent semiannual reports:
 »  brief description of any visible defects in the source or ductwork
 «  the number of leaks detected
 *  brief description of any system abnormalities found during the annual maintenance inspection
    that occurred in the reporting period and the repairs made
 •  a signed statement stating whether all the provision of Subpart L have been fulfilled during the
    semiannual reporting period
 »  revisions to items reported in the initial statement
                     PROCESS VESSELS, STOEAGE TANKS, AND TAR-INTERCEPTING SUMPS
                                                                               page C-152

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                                     PUMPS IN VHAP SERVICE
                                         APPLICABLE REGULATIONS
40 CFR Part 264,
Subpart CC

40 CFR Part 265,
Subpan CC

40 CER Part (
Subpart F

                                                                      40 CFR Part 61,
                                                                        Subpart L
                                                                        40 CFR Pan 61,
                                                                          Subpart FF
     ITEM
                                    REQUIREMENTS
Basic Standard
Monthly leak detection and repair

Weekly visual observation for leaks
Leak Definition
10,000 ppm

Indications of liquids dripping from pump seal
Alternative
Standards
Equivalent means of emission limitation

No detectable emissions (see No Detectable Emissions)

Closed-vent system and control device (see Closed-vent Systems and Control Devices)
Exemptions
Dual mechanical seal pumps (see Dual Mechanical Seals)

Pumps in vacuum service

Any pump located at unmanned site exempt from weekly visual inspection provided each is inspected
as often as practicable and at least monthly
Monitoring
Method
Method 21; no more the 1 cm from rotating shaft
Repair
Requirements
First attempt within 5 calendar days of detection

Repair as soon as practicable; no later than 15 days after detection
Delay of Repair
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown

Allowed for equipment that is isolated from the process and that does not remain in VHAP service

Allowed if repair requires use of a DMS that includes a barrier fluid system and repair is completed
as soon as practicable but not later than 6 months after leak detected
                                           PUMPS IN VHAP SERVICE
                                                                                  page C-153

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                                     PUMPS IN VHAP SERVICE
                                         APPLICABLE REGULATIONS
   40 CFR Pan 264,
     SubpartCC
      40 CFR Part 265,
        Subpart CC
40 CFR Part 61,
   Subpart F
40 CFR Part 61,
   Subpart L
40 CFR Part 61,
  Subpart FF
     ITEM
                                    REQUIREMENTS
Recordkeeping
Requirements
When leak detected:
 «  a weather-proof and readily visible identification, marked with the equipment ID number,
    attached to the leaking equipment
 •  ID may be removed after it has been repaired

Information to be kept in log for 2 years after leak detected:
 »  instrument and operator ID number and equipment ID number
 •  date leak detected
 »  dates of each attempt to repair leak
 «  repair methods applied in each attempt to repair
 •  "above 10,000" if maximum instrument reading after each repair attempt is _>. 10,000 ppm
 »  "repair delayed" and reason for delay is leak not repaired within 15 calendar days after detection
 «  signature of owner/operator whose decision it was that repair could not be effected without a
    process shutdown
 •  expected date of successful repair if leak is not repaired with the 15 days
 •  dates of process unit shutdown that occurred while the equipment is unrepaired
 «  date of successful repair of the leak

Information to be kept for all pumps:
 •  list of ID numbers of subject pumps
 »  list of ID numbers of pumps designated for no detectable emissions and signed by
    owner/operator
 •  for each compliance test for pumps designated for no detectable emissions:
    • •  date conducted
    * »  background level measured
    • »  maximum instrument reading

Information and data used to demonstrate that a pump is not in VHAP service
Reporting
Requirements
Initial semiannual report:
 •  equipment identification number
 «  process unit number
 «  type of equipment
 •  percent weight VHAP
 •  process fluid state
 •  method of compliance

Subsequent semiannual reports:
 •  The following information by month in the reporting period:
    * •  process unit identification
    » •  number of pumps for which leaks were detected
    • •  number of pumps for which leaks were not repaired within 15 days after detection
    • •  the facts that explain each delay of repair, and where appropriate, why a process unit
        shutdown was technically infeasible
 «  dates of process unit shutdowns that occurred within the semiannual reporting period
 •  revisions to items reported in the initial semiannual report if changes have occurred since the
    initial semiannual report or subsequent revisions to the initial semiannual report
 «  report of all performance tests and monitoring to determine compliance with no detectable
    emissions
                                           PUMPS IN VHAP SERVICE
                                                                                  page C-154

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                        SAMPLING CONNECTION SYSTEMS
                                 APPLICABLE REGULATIONS
40 CFR Part 264,
  Subpart CC
40 CFR Part 265,
  Subpart CC
40 CFR Part 61,
  Subpart F
40 CFR Part 61,
  Subpart L
40 CFR Part 61,
  Subpart FF
ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
Recordkeeping
Requirements
Repotting
Requirements
REQUIREMENTS
Equipped with closed-purge system or closed-vent system that either returns the fluid to the process
or recycles the purged fluid at zero VHAP emissions to the atmosphere or sends it to a complaint
control device
N/A
N/A ,
Equipment in vacuum service; in-situ sampling systems
N/A
N/A
N/A
Information to be kept for all sampling connections
• list of ID numbers of subject sampling connection systems
Initial semiannual report:
* process unit identification
• equipment identification number
• type of equipment
» percent weight VHAP
* process fluid state
• method of compliance
Subsequent semiannual reports:
• process unit ID
• revisions to items reported in the initial semiannual report if changes have occurred
initial semiannual report or subsequent revisions to the initial semiannual report
since the
                               SAMPLING CONNECTION SYSTEMS
                                                                 page C-155

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VALVES IN VHAP SERVICE
    APPLICABLE REGULATIONS
40 CFR Part 264, 40 CFR Pan 265, 40CFRPart61, 40 CFR Fait 61,
SUbpart CC Subpart CC Subpart F Subpan L
40 CFR Part 61,
Subpart FF
m^mm

ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
REQUIREMENTS
Monthly leak detection and repair
If valve does not leak for 2 months, may be monitored quarterly
If valve leaks, monitor monthly until no leak is detected for 2 consecutive months
10,000 ppm


Equivalent means of emission limitation
No detectable emissions
Valves designated unsafe to monitor or difficult to monitor
Allowable percentage of valves leaking or skip period leak detection and repair
Valves in vacuum service
Method 21
First attempt within 5 calendar days of detection
Repair as soon as practicable; no later than 15 days after detection
Allowed if technically infeasible without process unit shutdown; required before end of next process
unit shutdown
Allowed for equipment that is isolated from the process and that does not remain in VHAP service
Allowed if emissions of purged material from immediate repair would exceed fugitive emissions from
delay of repair, and purged materials are collected and destroyed or recovered in a control device
when repair occurs
Allowed beyond process unit shutdown if otherwise sufficient supply of valve assembly replacements
are exhausted
    VALVES IN VHAP SERVICE
                                              page C-156

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                                    VALVES IN VHAP SERVICE
                                         APPLICABLE REGULATIONS
  40 CFR Part 264,
     Subpart CC
      40 CFR Part 265,
         Subpart CC
40 CFR Part 61,
   Subpart F
40 CFR Pan 61,
   Subpart L
40 CFR Part 61,
  Subpart FF
     ITEM
                                     REQUIREMENTS
Recordkeeping
Requirements
When leak detected:
  »  a weather-proof and readily visible identification, marked with the equipment ED number,
    attached to the leaking equipment
  *  ID may be removed after it has been repaired and monitored for 2 months with no leaks

Information to be kept in log for 2 years after leak detected:
  •  instrument and operator ED number and equipment ID number
  •  date leak detected
  •  dates of each attempt to repair leak
  •  repair methods applied in each attempt to repair
  *  "above 10,000" if maximum instrument reading after each repair attempt is .>, 10,000 ppm
  *  "repair delayed" and reason for delay is leak not repaired within 15 calendar days after detection
  *  signature of owner/operator whose decision it was that repair could not be effected without a
    process shutdown
  •  expected date of successful repair if leak is not repaired with the 15 days
  •  dates of process unit shutdown that occurred while the equipment is unrepaired
  •  date of successful repair of the leak

Information to be kept for all valves:
  •  list of ID numbers of subject valves
  •  list of ID numbers of valves designated for no detectable emissions and signed by owner/operator
  •  for each compliance test for valves designated for no detectable emissions:
    • •  date conducted
    • •  background level measured
    • •  maximum instrument reading
  •  list of ID numbers for valves  in vacuum service

Information and data used to demonstrate that a valve is not in VHAP service
Reporting
Requirements
Initial semiannual report:
  •  valve ID number
  •  process unit identification
  •  type of equipment
  •  percent weight VHAP
  •  process fluid state
  •  method of compliance

Subsequent semiannual reports:
  «  process unit identification
  •  the following information by month in the reporting period:
    • •  number of valves for which leaks were detected
    • •  number of valves for which leaks were not repaired within 15 days after detection
    • •  the facts that explain each delay of repair, and where appropriate, why a process unit
         shutdown was technically infeasible
  «  dates of process unit shutdowns that occurred within the semiannual reporting period
  •  revisions to items reported in the initial semiannual report if changes have occurred since the
    initial semiannual report or subsequent revisions to the initial semiannual report
  *  report of all performance tests in accordance with alternative standards
                                           VALVES IN VHAP SERVICE
                                                                                    page C-157

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             CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                              APPLICABLE REGULATIONS
40 CFR Part 264,
  Subpart CC
40 CFR Part 265,
  Subpart CC
40 CFR Part 61,
  Subpart F
40 CFR Part 61
  Subpart L
40 CFR Part 61,
 Subpart FF
ITEM
Basic Standard







•
Leak Definition

Alternative
Standards
Exemptions
REQUIREMENTS
Closed Vent Systems:
• to be operated at all times when waste is placed in the waste management unit except when
maintenance or repair cannot be completed without a shutdown of the control device
« no detectable emissions (less than 500 ppnw above background)
« all gauging and sampling devices are to be airtight except when in operation
« visual inspect initially and quarterly thereafter including ductwork, piping, and connections for
evidence of visible defects
Control devices:
« to be operated at all times when waste is placed in the waste management unit except when
maintenance or repair cannot be completed without a shutdown of the control device
» visual inspect initially and quarterly thereafter including ductwork, piping, and connections for
evidence of visible defects
* Enclosed combustion device:
» • 2:95 percent reduction by weight of organic emissions
» • total organic concentration s20 ppmv
• • minimum residence time of 0.5 seconds at a minimum temperature of 760°C
« Boiler/Process Heater:
• • introduce vent stream into flame zone
» Vapor recovery:
• • ^95 percent reduction by weight of organic emissions
• * i98 percent reduction by weight of benzene emissions
• Flares:
»• comply with §60.18
» Other Control Devices:
• • a 95 percent reduction by weight of organic emissions
» • s98 percent reduction by weight of benzene emissions
• • develop test data and design information to document efficiency
» • identify critical operating parameters, range of values of these parameters to ensure
emission control efficiency, and how these parameters will be monitored
Monitoring: 500 ppm
Visual: visual defects
N/A

N/A
                      CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                                                          page C-158

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                    CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                                         APPLICABLE REGULATIONS
40 CFR Part 264,
Subpart CC

40 CFR Pan 265,
Subpart CC

40 CFR Part 61,
Subpart F

40 CFR Part 61
Subpart L

                                                                                            40 CFR Part 61,
                                                                                              Subpart FF
     ITEM
                                    REQUIREMENTS
Monitoring
Method
Closed Vent Systems:
  »  Monitor initially and at least once per year thereafter
  •  If system contains by-pass lines, either use vent stream flow indicators or a car-seal or lock-and-
    key type of configuration and visually inspect monthly
  «  Visually inspect flow monitoring device at least once per operating day

Control Device
  «  Continuous monitoring of operations
Repair
Requirements
First attempt to repair within 5 calendar days of detection

Repair as soon as practicable; no later than 15 days after detection
Delay of Repair
Delay of repair allowed if the repair is technically impossible without a complete or partial facility or
unit shutdown.

Repair to occur before the end of the next facility or unit shutdown.
Recordkeeping
Requirements
When leak detected (for each test of detectable emissions):
  »  date test performed
  «  background level measures
  »  maximum concentration
  •  waste management unit
  •  control equipment
  *  leak interface location where detectable emissions measured
  »  description of problem and the corrective action taken
  •  date the corrective action completed

For each visual inspection that identifies a problem that could result in benzene emissions:
  •  date of inspection
  *  waste management unit inspection
  *  control equipment location inspected
  •  description of problem
  •  corrective action taken
  •  date corrective action completed

For each compliance test for components designated as no detectable emissions:
  »  date conducted
  •  background level measured
  •  maximum instrument reading
                                CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                                                                                  page C-159

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                    CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                                         APPLICABLE REGULATIONS
   40 CFR Part 264,
     Subpart CC
      40 CFR Part 265,
        Subpait CC
40 CFR Part 61,
  Subpait F
40 CFR Pan 61
  Subpart L
40 CFR Part 61,
  Subpart FF
     ITEM
                                    REQUIREMENTS
Reporting
Requtremems
Initial report:
  •  regulatory status of each waste stream
  *  total annual benzene quantity
  •  each benzene waste stream and whether it will be controlled for benzene
  •  for each benzene waste stream not being controlled for benzene
    • •  whether water content is greater than 10 percent
    • •  type  of waste stream
    » •  annual waste quantity
    • •  range of benzene concentration
    « •  average benzene concentration
    • •  annual benzene quantity

Subsequent reports (facilities with > lOMg/yrof benzene waste):
  •  annual reports including, but not limited to:
    * •  update of information contained in initial report
    » •  all inspections during which detectable emissions are measured or a problem that could
        result in benzene emissions is identified
    » »  information on repair and corrective action taken
  •  Quarterly:
    • *  all inspections required have been carried out
    « •  for control devices: periods of exceedances

For facilities with < 1 Mg/yr of benzene waste:
  •  updates whenever changes occur that may increase benzene waste to  > 1 Mg/yr

For facilities with 1 to 10 Mg/yr of benzene waste:
  •  updates whenever changes occur that may increase benzene waste to  > 10 Mg/yr

For facilities with > 10 Mg/yr of benzene waste:
  »  certification that necessary equipment has been installed and initial performance tests have been
    carried out
                               CLOSED-VENT SYSTEMS AND CONTROL DEVICES
                                                                                 page C-160

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   CONTAINERS
APPLICABLE REGULATIONS
40 CFR Part 264,
Subpart CC

40 CFR Part 265,
Subpart CC

40 CFR Part 61,
Subpart F

40 CFR Part 61
Subpart L

                                          40 CFR Part 61,
                                           Subpart FF
ITEM
Basic Standard
Leak Definition
Alternative
Standards
Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
REQUIREMENTS
Compliance cover (see Covers) designed for no detectable emissions
Initial and subsequent annual monitoring
Maintain cover in closed, sealed position
Treatment containers:
• locate in enclosure designed and operated with sufficient airflow to capture organic vapors
emitted from container and vent them to compliant closed vent system and control device
Transfer into containers:
• use of conveyance system that use a tube, or other means, to add waste to the container and
cover to remain in place
• all container openings to be in closed, sealed position except for opening
Broken seal or gasket
• Tanks with fixed roof and internal floating roof meeting §60. 1 12b(a)(l).
• External floating roofs that comply with §60.112b(a)(2).
• Alternative means of emission limitation (§60. 1 14(b).
N/A
Visual, sensor
Repair as soon as practicable; no later than 15 days after identification
Delay of repair allowed if the repair is technically impossible without a complete or partial facility or
unit shutdown.
Repair to occur before the end of the next facility or unit shutdown.
      CONTAINERS
                                                 page C-161

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                                              CONTAINERS
                                          APPLICABLE REGULATIONS
   40 CFR Pan 264,
     Subpart CC
      40 CFR Part 265,
        Subpart CC
40 CFR Part 61,
   Subpart F
40 CFR Part 61
   Subpart L
40 CFR Part 61,
  Subpart FF
     ITEM
                                     REQUIREMENTS
Recordkeeping
Requirements
When leak detected (for each test of detectable emissions):
  •  date test performed
  •  background level measures
  •  maximum concentration
  •  waste management unit
  »  control equipment
  •  leak interface location where detectable emissions measured
  •  description of problem and the corrective action taken
  «  date the corrective action completed

For each visual inspection that identifies a problem that could result in benzene emissions:
  *  date of inspection
  •  waste management unit inspection
  •  control equipment location inspected
  »  description of problem
  •  corrective action taken
  •  date corrective action completed

For each compliance test for components designated as no detectable emissions:
  •  date conducted
  »  background level measured
  •  maximum instrument reading
Reporting
Requirements
Initial report:
  •  regulatory status of each waste stream
  •  total annual benzene quantity
  •  each benzene waste stream and whether it will be controlled for benzene
  •  for each benzene waste stream not being controlled for benzene
    » *  whether water content is greater than 10 percent
    • •  type of waste stream
    • •  annual waste quantity                                       :
    * •  range of benzene concentration
    • •  average benzene concentration
    • *  annual benzene quantity

Subsequent reports (facilities with  > 10 Mg/yr of benzene waste):
  •  annual reports including, but not limited to:
    « »  update of information contained in initial report
    • *  all inspections during which detectable emissions are measured or a problem that could
         result in benzene emissions is identified
    • «  information on repair and corrective action taken

  •  Quarterly
    • •  all inspections required have been carried out
    • •  for control devices: periods of exceedances

                                   (Continued on next page)	    	
                                                  CONTAINERS
                                                                                    page C-162

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   CONTAINERS
APPLICABLE REGULATIONS
40 CFR Part 264, 40 CFR Part 265, 40CFRPart61, 40CFRPart61 40CFRPart61,
SubpartCC SubpartCC SubpartF SubpartL SubpartFF
HIjj^^HI

ITEM
Reporting
Requirements
(continued)
REQUIREMENTS
For facilities with < 1 Mg/yr of benzene waste:
• updates whenever changes occur that may increase benzene waste to > 1 Mg/yr
For facilities with 1 to 10 Mg/yr of benzene waste:
* updates whenever changes occur that may increase benzene waste to > 10 Mg/yr
For facilities with > 10 Mg/yr of benzene waste:
• certification that necessary equipment has been installed and initial performance tests have been
carried out
     CONTAINERS
page C-163

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                                                  COVERS
                                          APPLICABLE REGULATIONS
40 CFR Part 264,
SubpanCC

40 CFR Part 265,
Subpart CC

40 CFR Part 61,
Subpart F

40 CFR Part 61,
Subpart L

                                                                                             40 CFR Part 61,
                                                                                               Subpart FF
      ITEM
                                      REQUIREMENTS
Basic Standard
 Initial and subsequent annual monitoring for no detectable organic emissions from cover and all
 openings

 Maintain each opening in a closed, sealed position at all times except when necessary to use opening
Leak Definition
 Detectable emissions

 Broken seal or gasket
Alternative
Standards
 N/A
Exemptions
 N/A
Monitoring
Method
 Instrument: Method 21, 40 CFR Part 60, Appendix A

 Visual: View entire cover surface and each cover opening in a closed, seal position for evidence of
 defect that may affect ability to continue to operate with no detectable organic emissions.
Repair
Requirements
 Repair as soon as practicable; no later than 15 calendar days after identification (45 days for tanks)
Delay of Repair
 Delay of repair allowed if the repair is technically impossible without a complete or partial facility or
 unit shutdown.

 Repair to occur before the end of the next facility or unit shutdown.
Recordkeeping
Requirements
 When leak detected (for each test of detectable emissions):
  •  date test performed
  •  background level measures
  «  maximum concentration
  •  waste management unit
  «  control equipment
  •  leak interface location where detectable emissions measured
  »  description of problem and the corrective action taken
  •  date the corrective action completed

 For each visual inspection that identifies a problem that could result in benzene emissions:
  •  date of inspection
  «  waste management unit inspection
  *  control equipment location inspected
  •  description of problem
  *  corrective action taken
  •  date corrective action completed
	(Continued on next page)	
                                                    COVERS
                                                                                                       page C-164

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                                                  COVERS
                                          APPLICABLE REGULATIONS
40 CFR Part 264,
Subpart CC

40 CFR Part 265,
Subpart CC

40 CFR Part 61,
Subpart F

40 CFR Part 61,
Subpart L

                                                                                              40 CFR Part 61,
                                                                                                Subpart FF
      ITEM
                                                         REQUIREMENTS
Recordkeeping
Requirements
(continued)
                    For each compliance test for components designated as no detectable emissions:
                     «  date conducted
                     *  background level measured
                     *  maximum instrument reading
Reporting
Requirements
                    Initial report:
                     •  regulatory status of each waste stream
                     •  total annual benzene quantity
                     •  each benzene waste stream and whether it will be controlled for benzene
                     »  for each benzene waste stream not being controlled for benzene:
                        * •  whether water content is greater than 10 percent
                        • •  type of waste stream
                        • •  annual waste quantity
                        • •  range of benzene concentration
                        • •  average benzene concentration
                        • •  annual benzene quantity

                    Subsequent reports (facilities with > 10 Mg/yr of benzene waste):
                     •  annual reports including, but not limited to:
                        • •  update of information contained  in initial report
                        • •  all inspections during which detectable emissions are measured or a problem that could
                            result in benzene emissions is identified
                        • •  information on repair and corrective action taken

                     •  Quarterly:
                        • •  all inspections required have been carried out
                        • •  for control devices: periods of exceedances

                    For facilities with < 1 Mg/yr of benzene waste:
                     •  updates whenever changes occur that  may increase benzene waste to > 1 Mg/yr

                    For facilities with 1 to 10 Mg/yr of benzene waste:
                     •  updates whenever changes occur that  may increase benzene waste to > 10 Mg/yr

                    For facilities with > 10 Mg/yr of benzene waste:
                     *  certification that necessary equipment has been installed and initial performance tests have been
                        carried out
                                                    COVERS
                                                                                                        page C-16S

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                                    SURFACE IMPOUNDMENTS
                                          APPLICABLE REGULATIONS
40 CFR Part 264,
SubpanCC

40 CFR Part 265,
Subpart CC

40 CFR Part 61,
Subpart F

40 CFR Part 61
Subpart L

                                                                                            40 CFR Part 61,
                                                                                              Subpart FF
      ITEM
                                     REQUIREMENTS
Basic Standard
 Compliant covers (see Covers) that are vented to compliant closed-vent system and control device.

 Initial and quarterly inspections for cracks or gaps
Leak Definition
Broken seal or gasket.
Alternative
Standards
 N/A
Exemptions
 N/A
Monitoring
Method
 N/A
Repair
Requirements
 As soon as practicable, but not later than 15 calendar days after identification.
Delay of Repair
 Delay of repair allowed if the repair is technically impossible without a complete or partial facility or
 unit shutdown.

 Repair to occur before the end of the next facility or unit shutdown.
Recordfceeping
Requirements
 When leak detected (for each test of detectable emissions):
  • date test performed
  • background level measures
  * maximum concentration
  » waste management unit
  • control equipment
  • leak interface location where detectable emissions measured
  * description of problem and the corrective action taken
  « date the corrective action completed

 For each visual inspection that identifies a problem that could result in benzene emissions:
  « date of inspection
  • waste management unit inspection
  » control equipment location inspected
  • description of problem
  » corrective action taken
  • date corrective action completed

	(Continued on next page)	
                                          SURFACE IMPOUNDMENTS
                                                                                                     page C-166

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                                    SURFACE IMPOUNDMENTS
                                          APPLICABLE REGULATIONS
40 CFR Part 264,
Subpart CC

40 CFR Part 265,
Subpart CC

40 CFR Part 61,
Subpart F

40 CFR Part 61
Subpart L

                                                                                              40 CFR Part 61,
                                                                                                Subpart FF
     ITEM
                                     REQUIREMENTS
Recordkeeping
Requirements
(continued)
For each compliance test for components designated as no detectable emissions:
 »  date conducted
 »  background level measured
 »  maximum instrument reading
Reporting
Requirements
Initial report:
  •  regulatory status of each waste stream
  •  total annual benzene quantity
  •  each benzene waste stream and whether it will be controlled for benzene
  «  for each benzene waste stream not being controlled for benzene:..
    • •  whether water content is greater than 10 percent
    • •  type of waste stream
    • •  annual waste quantity
    * •  range of benzene concentration
    • •  average benzene concentration
    • •  annual benzene quantity

Subsequent reports (facilities with  > 10 Mg/yr of benzene waste):
  •  annual reports including, but not limited to:
    • •  update of information contained in initial report
    « •  all inspections during which detectable emissions are measured or a problem that could
         result in benzene emissions is identified
    • •  information on repair and corrective action taken
  •  Quarterly:
    • *  all inspections required have been carried out
    • •  for control devices: periods of exceedances

For facilities with < 1 Mg/yr of benzene waste:
  •  updates whenever changes occur that may increase benzene waste to >  1 Mg/yr

For facilities with 1 to 10 Mg/yr of benzene waste:
  •  updates whenever changes occur that may increase benzene waste to >  10 Mg/yr

For facilities with > 10 Mg/yr of benzene waste:
  *  certification that necessary equipment has been installed and initial performance tests have been
    carried out
                                           SURFACE IMPOUNDMENTS
                                                                                    page C-167

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       TANKS
APPLICABLE REGULATIONS
40 CFR Part 264,
SubpaitCC

40 CFR Part 265,
Subpart CC

40 CFR Part 61,
SnbpartF

40 CFR Part 61,
Subpart L

                                          40 CFR Part 61,
                                           Snbpart FP
UEM
Baste Standard
Leak Definition
Alternative
Standards

Exemptions
Monitoring
Method
Repair
Requirements
Delay of Repair
REQUIREMENTS
Option 1: Compliant fixed roof (see Covers) and compliant closed-vent system and control device
Option 2: Compliant fixed roof provided certain conditions are met including but not limited to
the following maximum organic vapor pressure and size requirements:
Capacity Vapor Pressure
(cubic meters^ (Kilopascals)
Not specified 5.2
;j75 to < 151 27.6
<75 76.6
Conduct initial and quarterly inspections of each fixed roof, seal, access door, and other opening for
cracks and gaps and to ensure access doors and other openings are closed and properly gasketed.
Broken seal or gasket.
Detectable emissions measured.
• Tanks with fixed roof and internal floating roof meeting §60.112b(a)(l).
• External floating roofs that comply with §60. 1 12b(a)(2).
• Alternative means of emission limitation (§60. 1 14(b).
N/A
Method 21, 40 CFR Part 60, Appendix A
Repair as soon as practicable; no later than 45 calendar days after detection
Delay of repair allowed if the repair is technically impossible without a complete or partial facility or
unit shutdown.
Repair to occur before the end of the next facility or unit shutdown.
        TANKS
                                                  page C-168

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                                                   TANKS

                                          APPLICABLE REGULATIONS
40 CFR Part 264,
Subpart CC

40 CFR Part 265,
Subpart CC

40 CFR Part 61,
Subpart F

40 CFR Part 61
Subpart L

      ITEM
                                      REQUIREMENTS
Recordkeeping
Requirements
 When leak detected (for each test of detectable emissions):
  *  date test performed
  «  background level measures
  «  maximum concentration
  «  waste management unit
  «  control equipment
  »  leak interface location where detectable emissions measured
  •  description of problem and the corrective action taken
  •  date the corrective action completed

 For each visual inspection that identifies a problem that could result in benzene emissions:
  •  date of inspection
  •  waste management unit inspection
  «  control equipment location inspected
  •  description of problem
  »  corrective action taken
  •  date corrective action completed

 For each compliance test for components designated as no detectable emissions:
  •  date conducted
  •  background level measured
  •  maximum instrument reading
Reporting
Requirements
 Initial report:
  *  regulatory status of each waste stream
  *  total annual benzene quantity
  •  each benzene waste stream and whether it will be controlled for benzene
  •  for each benzene waste stream not being controlled for benzene:
     * •  whether water content is greater than 10 percent
     • •  type of waste stream
     • •  annual waste quantity
     • •  range of benzene concentration
     • •  average benzene concentration
     • •  annual benzene quantity

 Subsequent reports (facilities with  > 10 Mg/yr of benzene waste):
  •  annual reports including, but not limited to:
     « •  update of information contained in initial report
     • •  all inspections during which detectable emissions are measured or a problem that could
         result in benzene emissions is identified
     • •  information on repair and corrective action taken
  •  Quarterly
     • •  all inspections required have been carried out
     • •  for control devices: periods of exceedances

 For facilities with < 1 Mg/yr of benzene waste:
  »  updates whenever changes occur that may increase benzene waste to >  1 Mg/yr

	(Continued to next page)	
                                                     TANKS
                                                                                                         page C-169

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                                                 TANKS
                                        APPLICABLE REGULATIONS
  40 CFR Pan 264,
     Subpart CC
      40 CFR Part 265,
        Sufapart CC
40 CFR Part 61,
   Subpart F
 40 CFR Fan 61,
	Subpart L
40 CFR Pan 61.
  Subpart FF
     ITEM
                                    REQUIREMENTS
Reporting
Requirements
(continued)
For facilities with 1 to 10 Mg/yr of benzene waste:
 •  updates whenever changes occur that may increase benzene waste to > 10 Mg/yr

For facilities with > 10 Mg/yr of benzene waste:
 *  certification that necessary equipment has been installed and initial performance tests have been
    carried out.
                                                  TANKS
                                                                                                    page C-170

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