SEPA
United States
Environmental Protection
Agency
IMPLEMENTATION DOCUMENT FOR THE
PESTICIDE ACTIVE INGREDIENT
PRODUCTION NESHAP -
(40 CFR 63, SUBPART MMM)
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EPA-305-B-05-001
March 2005
Implementation Document for the
Pesticide Active Ingredient Production
NESHAP
(40 CFR 63, Subpart MMM)
Prepared for:
Air Compliance Branch
Compliance Assessment and Media Programs Division (CAMPD)
Office of Compliance (OC)
Office of Enforcement and Compliance Assurance (OECA)
U.S. Environmental Protection Agency
Washington, DC 20460
and
Information Transfer and Program Integration Division (ITPID)
Program Implementation and Review Group (PIRG)
Office of Air Quality Planning and Standards (OAQPS)
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
Prepared by:
Research Triangle Institute
3040 Cornwall! s Road
Research Triangle Park, North Carolina 27709-2194
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What is the legal status of this guide?
The Office of Air Quality Planning and Standards (OAQPS) and the Office of Enforcement and
Compliance Assistance (OECA) of the U. S. Environmental Protection Agency (EPA) have reviewed this
document and approved it for publication.
When using this document, remember that it is not legally binding and does not replace the final rule -
"National Emission Standard for Hazardous Air Pollutants for Pesticide Active Ingredient Production"
(published in the Federal Register, 6/23/99, 64 FR 33550 and amended 6/3/02, 9/20/02, and 11/21/02)
or any State, local or tribal rules that may apply to your facility.
This document is not intended, nor can you rely on it, to create any rights enforceable by any party in
litigation with the United States. The EPA may change this document at any time without public notice.
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Thank You
The document was prepared by a joint partnership among the Environmental Protection Agency
(EPA, or we), State and local agencies for air pollution control, trade associations, and
organizations who produce pesticide active ingredients. The development team had the
following members:
Alfred Azevedo, WV Office of Air Quality
Lalit Banker, EPA, OAQPS, ESD
John A. Dege, DuPont Environmental Center for Excellence
Richard A. DiMenna, Rohm and Haas Company
Dianne J. Walker, EPA, PTAB, Region III
We thank these people for their participation. Their technical insights, experiences, and
suggestions were essential to this guide's development.
11
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Table of Contents
Page
What is the legal status of this guide? i
List of Figures vii
List of Tables vii
List of Acronyms ix
Chapter 1 - Introduction 1-1
Why should I use this implementation document? 1-1
What provisions does this document describe? 1-1
Is there anything I should know before using this document? 1-1
How do I get copies of this document? 1-2
We want your feedback 1-2
Survey on the Implementation Document for the Pesticide Active Ingredient Production
NESHAP 1-3
Chapter 2 - What this Pesticide Active Ingredient rule covers - An Overview 2-1
Why was this Pesticide Active Ingredient (PAI) rule written? 2-1
How do I know if I am subject to this rule? 2-1
What is an affected source? 2-2
When do I need to comply? 2-4
What pesticide active ingredients are subject to the rule? 2-7
How does "primary use" differ from "primary product"? 2-7
How do I determine the primary use of a product? 2-8
What is a pesticide active ingredient (PAI) process unit? 2-8
What is an integral intermediate? 2-9
How is "nondedicated" equipment regulated? 2-10
How do I know if a storage vessel is part of a PAI process unit? 2-11
What requirements apply during periods of startup, shutdown, and malfunction? 2-11
What provisions in this rule overlap provisions in other rules? 2-12
What is exempt from the rule? 2-13
Chapter 3 - Complying with requirements for process vents 3-1
What is a process vent? 3-1
What process vents does Subpart MMM apply to? 3-1
What process vents are exempt? 3-2
What compliance options do I have for my Group 1 process vents? 3-3
How do I show initial compliance with the process vent requirements? 3-8
What monitoring must I do for my process vents? 3-12
What parameters must I monitor? 3-12
How do I set monitoring parameter limits? 3-17
iii
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Table of Contents (cont'd)
Page
How do I monitor to comply with the alternative standard? 3-18
How may I average my monitoring parameter values? 3-18
What records must I keep for my process vents? 3-19
What reports must I submit for my process vents? 3-20
Checklists for Process Vent Inspections 3-21
Chapter 4 - Complying with requirements for storage vessels 4-1
What is a storage vessel? 4-1
What storage vessels are subject to subpart MMM? 4-1
What storage vessels are exempt? 4-1
What is a "Group 1" storage vessel? 4-2
How do I know if a storage vessel is part of a PAI process unit? 4-2
What compliance options do I have for my storage vessels? 4-3
How do I show initial compliance with the storage vessel requirements? 4-5
How do I comply when my control device needs repairs [options 5 (A, B, C, and E)]? .4-11
What monitoring must I do for my storage vessels? 4-11
What records must I keep for my storage vessels? 4-17
What reports must I submit for my storage vessels? 4-17
Checklists for Inspection of Storage Vessels 4-19
Chapter 5 - Complying with requirements for wastewater systems 5-1
What wastewater streams are subject to Subpart MMM? 5-1
What types of wastewater components are subject to Subpart MMM? 5-1
What wastewater streams are exempt? 5-2
How do I identify a Group 1 wastewater stream? 5-2
What are my compliance options for wastewater systems? 5-3
What are my emission suppression compliance options? 5-4
What are my compliance options for air pollution control devices? 5-9
What treatment compliance options do I have for my wastewater streams? 5-10
How do I show initial compliance with the emission suppression compliance
requirements? 5-13
How do I show initial compliance with the treatment compliance requirements? 5-13
How do I show initial compliance with the control device compliance requirements? . . 5-19
What monitoring must I do to comply with the emission suppression requirements for
waste management units? 5-22
What monitoring must I do for my wastewater treatment unit? 5-28
What monitoring must I do for my air pollution control device? 5-28
How do I inspect my closed-vent systems? 5-30
What are my compliance options for heat exchange systems? 5-30
What records must I keep for my wastewater systems? 5-33
What reports must I submit for my wastewater systems? 5-38
Checklists for Wastewater System Inspections 5-43
IV
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Table of Contents (cont'd)
Page
Chapter 6 - Complying with requirements for equipment leaks 6-1
What equipment leaks are regulated by Subpart MMM? 6-1
How do I identify equipment subject to the equipment leak provisions? 6-1
What equipment is exempt? 6-2
What compliance options do I have for my equipment leaks? 6-2
How do I implement a leak detection and repair (LDAR) program under Option 1? 6-3
What are the LDAR requirements for Pumps in Light Liquid Service and Agitators in
Gas/Vapor Service and Light Liquid Service (Option 1)? 6-7
What are the LDAR requirements for open-ended valves or lines (Option 1)? 6-10
What LDAR requirements apply to valves in gas/vapor or light liquid service
(Option 1)? 6-11
What LDAR requirements apply to compressors (Option 1)? 6-13
What LDAR requirements apply for pressure relief devices in gas/vapor service
(Option 1)? 6-14
What LDAR requirements apply for sampling connection systems (Option 1 ?) 6-15
What LDAR requirements apply for pumps, valves, connectors, and agitators in heavy
liquid service; instrumentation systems: and pressure relief devices in liquid service
(Option 1) ? 6-16
What LDAR requirements apply for connectors in gas/vapor or light liquid service
(Option 1)? 6-17
What are my compliance requirements for closed-vent systems and control devices
(Option 2)? 6-20
What are my compliance requirements for pressure testing (Option 3)? 6-22
What are my compliance requirements for alternative monitoring of batch processes
(Option 4)? 6-24
What is required for an alternative standard (Option 5)? 6-25
What are my leak repair requirements? 6-26
What if equipment is unsafe or difficult to monitor (Options 1, 2, and 4?) 6-28
What records must I keep for my equipment leaks? 6-29
What reports must I submit? 6-37
Checklists for Equipment Leak Inspections 6-40
Chapter 7 - Sample calculations 7-1
What calculations are required by Subpart MMM? 7-1
How do I calculate uncontrolled process vent emissions? 7-2
How do I determine if process vents are Group 1 or Group 2? 7-7
How do I calculate the flow-weighted average flowrate for "large" process vents? 7-8
How do I calculate controlled emissions out of a condenser? 7-9
How do I correct concentration measurements to account for supplemental gases? 7-11
How do I determine if I have a heat exchange system leak when complying with option
HE1? 7-13
Chapter 8 - Recordkeeping and reporting 8-1
What records must I keep? 8-1
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Table of Contents (cont'd)
Page
What do I have to report and when? 8-2
How can I change the date my reports are due? 8-2
Where do I send my reports? 8-2
Chapter 9 - Other requirements and information 9-1
Who administers this regulation? 9-1
Do I need a title V permit? 9-2
How do I change my permit to include this rule? 9-2
What portions of the General Provisions apply? 9-3
Chapter 10 - Getting additional help 10-1
Whom can I ask for help? 10-1
Can I get more information on the Web? 10-3
Is there a list of commonly asked questions? 10-4
Chapter 11 - Supplemental information for State and local agencies and Tribes 11-1
How many facilities may need to meet emission limits? 11-1
Who regulates facilities in Indian Country? 11-1
How much HAP emissions will the rule reduce? 11-1
VI
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List of Figures
Page
Figure 2-1. Compliance Timeline and Reporting Requirements for Existing
Affected Sources 2-5
Figure 2-2. Compliance Timeline and Reporting Requirements for New and
Reconstructed Sources 2-6
Figure 6-1. Flowchart of monitoring frequencies for connectors 6-19
List of Tables
TABLE 3-1. Compliance Options for Process Vents 3-4
TABLE 3-2. Monitoring Requirements for Air Pollution Control Devices 3-14
TABLE 4-1. Design and Operating Requirements for Storage Vessels Equipped with a
Floating Roof 4-7
TABLE 5-1. Performance Testing Requirements for Treatment Units 5-15
TABLE 5-2. Characteristics to Consider in Design Evaluations for Control Devices 5-19
TABLE 5-3. Inspection Requirements for Waste Management Units 5-23
TABLE 5-4. Monitoring Requirements for Control Devices 5-29
TABLE 5-5. Recordkeeping Requirements for Wastewater Systems 5-34
TABLE 5-6. Information on Wastewater Systems to Include in the Notification of
Compliance Status Report 5-38
TABLE 5-7. Information on Wastewater Systems and Heat Exchange Systems to Include in
Your Periodic Report 5-40
TABLE 6-1. General Requirements and Exceptions of the Equipment Leak Provisions ... 6-4
TABLE 6-2. Recordkeeping Requirements of the Equipment Leak Provisions 6-31
TABLE 7-1. Operational and Emissions Data for a PAI Process 7-1
TABLE 8-1. Summary of Recordkeeping Requirements 8-4
TABLE 8-2. Report Due Dates for Existing Affected Sources 8-10
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List of Tables (cont'd)
TABLE 8-3. Report Due Dates for New Affected Sources 8-11
TABLE 8-4. Reporting Requirements 8-12
TABLE 9-1. General Provisions Applicability to Subpart MMM 9-3
TABLE 10-1. EPA Regional Air Division Offices 10-2
Vlll
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List of Acronyms
ADI Applicability Determination Index
AMR Actual mass removal
APCD Air pollution control device
ATW Air Toxics Website
BACT Best available control technology
CAA Clean Air Act
CFR Code of Federal Regulations
CEMS Continuous emissions monitoring system
C12 Chlorine
CMS Continuous monitoring system
DOT Department of Transportation
EFR External floating roof
FIFRA Federal Insecticide, Fungicide, and Rodenticide Act
Fr Fraction removed
GPO Government Printing Office
HAP Hazardous air pollutant
HC1 Hydrochloric acid
HOPE High density polyethylene
HON Hazardous Organic NESHAP
IDS Individual drain system
IFR Internal floating roof
LAER Lowest achievable emissions rate
LDAR Leak detection and repair
MACT Maximum achievable control technology
NEPIS National Environmental Publications Internet Site
NESHAP National Emission Standards for Hazardous Air Pollutants
NOCSR Notification of compliance status report
NPDES National Pollution Discharge Elimination System
NSCEP National Service Center for Environmental Publications
NSPS New Source Performance Standards
OECA Office of Enforcement and Compliance Assurance
PAI Pesticide active ingredient
POD Point of determination
PS Performance specification
PTE Potential to emit
PUG Process unit group
QA/QC Quality assurance/quality control
RCRA Resource Conservation and Recovery Act
RMR Required mass removal
SBAP Small Business Assistance Program
SSMP Startup, shutdown, and malfunction plan
STAPPA/ State and Territorial Air Pollution Program Administrators and Local Air
ALAPCO Pollution Control Officials
TOC Total organic compounds
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List of Acronyms (cont'd)
TSDF Treatment, storage, and disposal facility
TTN Technology Transfer Network
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Chapter 1 - Introduction
Why should I use this implementation document?
This document can help facility owners and operators understand the National Emission Standards for
Hazardous Air Pollutants (NESHAP) for Pesticide Active Ingredient (PAI) Production (also known as
Subpart MMM) by helping you determine:
• if the rule applies to your facility and process
• what compliance options are available
• how to establish initial compliance
• how to monitor ongoing compliance
• what records to keep
• what information to report
• dates by which you must meet requirements
• how to perform required calculations
What provisions does this document describe?
This document describes the standards and compliance options for process vents, storage vessels,
wastewater systems, and equipment leaks except for the emissions averaging and pollution prevention
options.
Is there anything I should know before using this document?
When using this document, remember that it does not replace the final rule but summarizes the
requirements published in the final rule and its
amendments. You should keep up with any new
requirements by periodically checking the Federal Keep informed of rule changes, if any, by
Register and the Code of Federal Regulations (CFR). checking the Federal Register.
You can download Federal Register notices by going
to the Government Printing Office (GPO) website at
www.gpoaccess.gov/fr/index.html.
You can download a copy of the amended final rule as published in the Code of Federal Regulations at
the GPO website: www.gpoaccess.gov/cfr/retrieve.html.
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How do I get copies of this document?
You can get copies of this document in three ways:
• EPA's Office of Enforcement and Compliance Assurance website
(www.epa.gov/compliance/assistance/sectors/index.htmT). Look under Pesticide Active
Ingredients.
• National Service Center for Environmental Publications (www.epa.gov/ncepiham/index.htm).
Look under Online Publications, and then the National Environmental Publications Internet Site
(NEPIS) and EPA document number 305-B-05-001.
• EPA's Technology Transfer Network Air Toxics Website (www.epa.gov/ttn/atw). Look under
Rules and Implementation, national emission standards for hazardous air pollutants, pesticide
active ingredient, orwww.epa.gov/ttn/atw/pest/pestpg.html.
We want your feedback
To serve you better, we have included a survey on the usefulness of this document. If you would like to
participate, please fill out the survey on page 1-3 and return it to the address indicated. We will keep your
responses confidential if you desire, but use them to help us improve future documents.
Help us publish better documents by filling
out our survey
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Survey on the Implementation Document for the
Pesticide Active Ingredient Production NESHAP
Please help us gauge this document's usefulness by completing this short form. We will keep your responses confidential if you
desire, but use them to help improve future documents. Check this box if you would like us to keep your responses confidential
1. What type of business do you work for? (check one of the following)
Manufacturing nD Contractor nD Tribe nD Government (specify Federal, State, local)
Other
2. What are your job responsibilities? (check any that apply)
Facility Operator nD Maintenance nD Facility Manager nDEnvironmental Staff nD
Regulator nD Other:
3. How did you hear about this implementation document? (check any that apply)
Co-worker nD EPA TTN via dial up modem nD EPA TTN via the Web nD Other
Please check the box under the number that most closely shows your agreement with the following statements
1= Strongly Agree to 5 = Strongly Disagree
Statement
The document was timely.
The document provides a good overview of the rule.
The document provides the type of information my organization needs to comply.
The document helped us achieve compliance more quickly than if we had developed our
own.
We have incorporated parts of this document into our own policy documents.
The format of this document was well organized and easy to understand.
1
2
3
4
5
N/A
4. What did you like about this document or what helped you the most? (be as specific as you can)
5. What did you not like about this document or what helped you the least? (be as specific as you can)
6. What would you change about this document (e.g. formats; excluding information or including things that you did not
see in the document)?
7. Overall, did you find this document to be:
extremely useful nD very useful nD
8. Other comments:
somewhat useful nD not useful at all nD
Provide additional comment on the back of this form or on a separate sheet of paper.
Return survey to: ATTN: Pesticide Active Ingredient Implementation Contact, U.S. Environmental Protection Agency (EPA), Mail
Code 2223A, 1200 Pennsylvania Avenue, NW, Washington, DC 20460, or fax (202) 564-0050
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Chapter 2 - What this Pesticide Active Ingredient rule covers -
An Overview
Why was this Pesticide Active Ingredient (PAI) rule written?
The PAI rule was written to reduce hazardous air pollutant (HAP) emissions and achieve the
environmental benefits intended by the Clean Air Act (CAA) of 1990.
The rule applies to all organic HAP emissions from facilities subject to the rule. It also applies to
chlorine and hydrogen chloride emissions, and it applies to particulate matter emissions from
certain PAI product dryers and bag dumps. Our research indicates that the primary organic HAP
emissions from PAI production include the following:
• toluene
• methanol
• xylene
• methyl chloride
• methylene chloride
ethylene dichloride
carbon tetrachloride
• acetonitrile
How do I know if I am subject to this rule?
You are subject to this rule if your facility meets all of the following:
• is a major source of HAP emissions
manufactures at least one PAI
• is not exempt
Definition. Pesticide Active Ingredient means any material that is an active
ingredient within the meaning of FIFRA section 2(a); is used to produce an
insecticide, herbicide, or fungicide end use pesticide, consists of one or more organic
compounds; and that must be labeled in accordance with 40 CFR part 156.
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Note: PAIs are typically described by North American Industrial Classification System (NAICS) codes 325199
and 32532; these materials are identified by product classification codes 01, 21, 02, 04, 44, 07, 08, and 16 in
block 19 on EPA form 3540-16, the Pesticides Report for Pesticide-Producing Establishments.
You are not subject to this rule if you have a federally enforceable limit on your facility by the
compliance date of Subpart MMM that restricts your
emissions to <10 tons/yr of any single HAP and
<25 tons/yr of all combined HAPs (i.e, in such cases, Your facility is a major source if it can
your facility would not be classified as a maj or source potentially emit >10 tons/yr of a single
under §63.2 of the General Provisions). HAP or >25 tons/yr of all HAPs.
If your facility is major source, some PAI operations at your facility may still be exempt from the
rule. These exemptions are listed at the end of this chapter.
For a list of regulated HAPs, check our Air Toxics Website (ATW) at:
http://www.epa.gov/ttn/atw/188polls. txt
What is an affected source?
Under Subpart MMM, an affected source includes all of the following [§63.1360(a)]:
• the facility-wide collection of pesticide active ingredient manufacturing process units
(PAI process units) that process, use, or produce HAP
Definition. Process unit means the equipment assembled and connected by pipes or
ducts to process raw materials and to manufacture an intended product.
• waste management units, heat exchange systems, and cooling towers associated with the
PAI process units described above
An affected source includes all of the following types of emission points [§63.1360(a) and
definition of "PAI process unit" in §63.1361]:
process vents
See Chapters 3 through 6for details
Storage vessels about your compliance options for
these emission points.
wastewater systems
equipment leaks
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A new affected source includes either of the following [§63.1360(b)]:
• an affected source, as described above, for which construction or reconstruction started
after November 10, 1997, or
• any dedicated PAI process unit that meets both of the following criteria:
* construction commenced after November 10, 1997, or reconstruction commenced after
September 20, 2002
* has the potential to emit 10 tons/yr of any one HAP or 25 tons/yr of combined HAP
Definition. Dedicated PAI process unit means a PAI process unit constructed from equipment
that is fixed in place and designed and operated to produce only a single product or co-
products. The equipment is not designed to be reconfigured to create different process units,
and it is not operated with different raw materials so as to produce different products.
Examples of changes to a facility and the type of standards that would apply are as follows:
If you...
And...
Then...
add a dedicated PAI you have an existing affected source,
process unit at a major
source after November
10, 1997
and the potential to emit (PTE) for the
added process unit is less than 10 tons/yr
of individual HAP or 25 tons/yr of total
HAP at the time the dedicated PAI
process unit is added
your added process unit becomes part of the
existing affected source and is subject to
existing source standards
you have an existing affected source,
and the PTE for the added process unit
exceeds either HAP threshold (10 or 25
tons/yr), at the time the dedicated PAI
process unit is added
the added dedicated PAI process unit is a
new affected source and subject to the new
source standards (all other PAI process units
that were part of the existing affected source
remain subject to existing source standards).
you have no existing affected source at
the time the dedicated PAI process unit
is added
regardless of the PTE, your added dedicated
PAI process unit becomes a new affected
source that is subject to the new source
standards
add a PAI process unit
that runs in
nondedicated
equipment at a major
source
you have an existing affected source
your added PAI process unit becomes part of
the existing affected source and is subject to
existing source standards regardless of
whether you also have a dedicated PAI
process unit that is a new affected source
you have only a new affected source at
the time the nondedicated PAI process
unit is added
your added PAI process unit becomes part of
the new affected source and is subject to new
source standards
you do not have an affected source at the
time the nondedicated PAI process unit
is added, and you had no nondedicated
equipment on November 10, 1997
you have constructed an affected source and
the PAI process unit is subject to new source
standards
2-3
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If you...
And...
Then..
you do not have an affected source at the
time the nondedicated PAI process unit
is added, but construction of the
nondedicated equipment began before
November 10, 1997
your added PAI process unit becomes an
existing affected source and is subject to
existing source standards
add nondedicated
equipment to a major
source
you already have an existing affected
source with nondedicated equipment
that you use to make PAI's
all PAI process units at the affected source
remain subject to existing source standards
add equipment to a
dedicated PAI process
unit at a major source
you already have an existing affected
source
the dedicated PAI process unit remains part
of the existing affected source and subject to
the existing source standards
replace equipment in
PAI process units at
an existing affected
source
the amount of equipment replaced in a
dedicated PAI process unit meets the
definition of reconstruction
the dedicated PAI process unit becomes a
new affected source that is subject to new
source standards, and all other PAI process
units remain subject to existing source
standards
the amount of equipment replaced
throughout the entire affected source
meets the definition of reconstruction
the affected source becomes a new affected
source, and all PAI process units are subject
to new source standards
When do I need to comply?
If your facility is an existing affected source, you must comply by December 23, 2003. This date
is 4.5 years after the rule's effective date of June 23, 1999 [§63.1364(a)]. The effective date is the
date the final rule was published in the Federal Register. The compliance date in the final rule
was 6/23/02, but the compliance date was extended by 18 months in amendments published on
6/3/02. An extension of up to 1 additional year may be requested if time is needed to install
controls, and it must be submitted 120 days before compliance date.
If your affected source is new or reconstructed, except
for a new affected source that consists of a
reconstructed dedicated PAI process unit, you must
comply upon startup of your operations or on 6/23/99,
whichever is later. [§63.1364(b)] If your affected
source is a dedicated PAI process unit for which
reconstruction commenced after September 20, 2002
you must comply upon startup. See Figures 2-1 and 2-2 for detailed compliance timelines
Some additions to an existing source may be
subject to existing source standards and
others may be subject to new source
standards. See "What is an affected
source?" (page 2-2) for more information.
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Existing Affected Sources
Initial Startup before November 10, 1997 (Rule proposal date)
Pesticide Active Ingredient (PAI) Rule
Effective Date June 23, 1999
If you are submitting a(n) ...
\
Site-Specific Test \
Initial Notification
Report of
Relevancy Compliance Precompliance
Plan and \
Notification of Initial Notification
Planned of Compliance
Startup, \
Shutdown, \
(§63.1368(b)) & Extension Request Plan Compliance Date Performance Test Status (NOCS) Periodic Report Malfunction Report \
(§63.9
Then ...
Sub
(b)(2)) (§63.136
mit by Submit
4(a)(2)(i)) (§63.1 :
no later Subn
368(e)) (§63.13
nit by Must co
S4(a)(l)) (§63. 1C
mply by Submit
68(m)) (§63.1
SO days Subn
368(f)) (§63.1
nit by Submit b
368(g)) (§63.1
/ 7/77/05 Submit b
368(i)) \
/ 7/77/05 /
1 0/23/99 than 8/25/03 or 9/23/03 or 12/23/03 before 5/27/04 and every 6 and every 6 /
or within 120 120 days before 3 months before
Performance Test*
months thereafter. months /
days after source compliance date. compliance date.
thereafter.** /
becomes subject /
to
rule.
/
1 Results of performance tests must be included in the Notification of Compliance Status Report. Therefore, performance tests must be conducted prior to the
submittal date of the Notification of Compliance Status Report, or within 150 days after startup of an existing affected source if the source begins operation
after the effective date of the rule. (§63.7(a)(2)(iii))
* Reports are only required if a startup, shutdown, or malfunction occurred during the reporting period. (§63.1368(1))
Figure 2-1. Compliance Timeline and Reporting Requirements for Existing Affected Sources.
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New and Reconstructed Affected Sources
Initial Startup after November 10, 1997 (Rule proposal date)
Pesticide Active Ingredient (PAI) Rule
Effective Date June 23, 1999
If you are submitting a(n)...
Initial Notification
Report of Relevancy
(§63.1368(b)),
(§63.9(b)(2)), and
(§63.5(d)(1)
Precompliance
Plan
(§63.1368(e))
Compliance Date
(§63.1364(b))
Site-Specific Test
Plan and
Notification of
Planned
Performance Test
(§63.1368(m))
Initial Notification
of Compliance
Status (NOCS)
(§63.1368(f))
Periodic Report
(§63.1368(g))
Startup,
Shutdown,
Malfunction Report
(§63.1368(1))
Then.
to
Submit by
10/23/99 or within
120 days after
source becomes
subject to rule.
Submit with the
application for
approval of
construction or
reconstruction.
Comply on 6/23/99
or upon startup,
whichever is later.*
Submit 60 days
before
Performance
Tests**
Submit 150 days
after effective date
or initial startup.
Submit 240 days
after initial NOCS'
due date and
every 6 months
thereafter.
Submit 240 days
after initial NOCS'
due date and
every 6 months
thereafter.***
Compliance date for a reconstructed dedicated PAI process unit is 9/20/02 or startup, whichever is later.
Performance tests shall be conducted within 150 days after the effective date, or within 150 days after startup of a new source that has an initial startup after
the effective date of the rule. (§63.7(a)(2)(i) and (ii))
1 Reports are only required if a startup, shutdown, or malfunction occurred during the reporting period. (§63.1368(1))
Figure 2-2. Compliance Timeline and Reporting Requirements for New and Reconstructed Sources.
-------
What pesticide active ingredients are subject to the rule?
Subpart MMM applies to only a fraction of all materials that are registered as active ingredients
within the meaning of Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) section 2(a).
The materials subject to this rule depend on how they are used. You are subject to
Subpart MMM if your material:
• meets all of the conditions in the definition of PAI in §63.1361 of Subpart MMM (see
page 2-1 for the definition of PAI)
Procedures to determine primary use
is "primarily used" as a PAI are described below.
Your material is not subject to Subpart MMM if it meets any of the following criteria: [definition
of PAI in §63.1361]
• it is an inorganic compound
it is used to produce active ingredients that are not identified by product classification
codes 01, 21, 02, 04, 44, 07, 08, or 16 in block 19 on EPA form 3540-16, the Pesticide
Report for Pesticide-Producing Establishments (e.g., materials classified as disinfectants,
rodenticides, and water purifiers)
How does "primary use" differ from "primary product"?
The concepts of primary use and primary product serve the following purposes:
Primary use refers to the predominant end-use application of each material that may be
used for both PAI and non-PAI purposes. Your primary use will determine if the material
is a PAI that is subject to this rule.
• Primary product refers to the predominant product produced in a process unit group
(PUG), and is used to determine the applicable requirements for all PAI process units in
the group. Process unit groups are part of an alternative means of compliance for sources
with nondedicated equipment that is subject to multiple MACT rules (see "How is
nondedicated equipment regulated" later in this chapter for a discussion of the PUG
concept).
Definition. Process unit group means a group of process units that manufacture PAFs
and products other than PAFs by alternating raw materials or operating conditions, or
by reconfiguring process equipment. A process unit group is determined according to
the procedures specified in §63.1360(g).
2-7
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How do I determine the primary use of a product?
Your product is "primarily used" as a PAI if more than 50 percent of the projected annual
production of the product in the 3 years after June 23, 1999, or startup, whichever is later, will be
used as a PAI [from the definition of "PAI process unit" in §63.1361].
If the initial primary use of your product is for non-PAI purposes, you must re-evaluate the
primary use if there is reason to believe it has changed.
If the primary use changes from non-PAI to PAI, then the process unit producing that material
becomes a PAI process unit and is subject to
Subpart MMM, unless it is already subject to 40 n „ . ,., n,, , n,,
r / „ x Y. Recordkeepmg oj the PAI and non-PAI uses is
CFR part 63, Subpart F (HON). If your process required ifnon.PAI uses are the primary use.
unit is subject to Subpart F, you must follow the
Subpart F requirements, not those in
Subpart MMM.
What is a pesticide active ingredient (PAI) process unit?
A PAI process unit produces either of the following [§63.1361]:
• a PAI
an integral intermediate
Note: Integral intermediate is defined on page 2-9. You may designate as a PAI process unit any process unit
that produces an intermediate that is not an integral intermediate [§63.1360(g)]
Typically, each integral intermediate process and the associated PAI process are separate PAI process units.
However, if 100 percent of an integral intermediate is used in the production of a single PAI, you may consider
the entire system to be one PAI process unit [from the definition of process in §63.1361].
A PAI process unit is not linked to any specific piece of equipment. Rather, it applies to
whatever equipment is being used to produce a particular product. For example, if you have two
distinct process "lines," both producing the same product, they
constitute one PAI process unit. Alternatively, you may have See «how js nondedicated
"nondedicated" equipment that can be configured in different equipment regulated, "for more
ways to make different products as needed. In this case, each information.
time you make a particular PAI, you may use a different
reactor, centrifuge, or other equipment, but it is the same PAI
process unit. Similarly, if the same equipment is used to produce different PAIs at different
times, it constitutes a different PAI process while it is used to make each of the products. When
you use the equipment (in the same configuration or a different one) to produce a non-PAI, the
equipment does not constitute a PAI process unit.
2-8
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A PAI process unit can include any of the following [§63.1361]:
the PAI process (i.e., the processing equipment such as mixing vessels, reactors, and
distillation units)
associated storage vessels, as determined under §63.1360(f)
• connected piping and ducts
open equipment used to convey and store liquids, as defined under §63.1362(k)
• associated components such as:
*• pumps
*• compressors
*• agitators
*• pressure relief devices
*• sampling connection systems
*• open-ended valves or lines (process fluid on only one side)
*• valves with process fluid on both sides
> connectors
*• instrumentation systems
What is an integral intermediate?
An integral intermediate is an organic compound that meets all of the following criteria
[§63.1361]:
• it is further processed or modified in one or more additional steps to produce a PAI
• 50 percent or more of the annual production is used in on-site production of one or more
PAIs
• it is not stored before the next processing step (see next paragraph)
• it is not already subject to 40 CFR 63, Subpart F
2-9
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An intermediate is stored if it is discharged to a storage vessel, and it meets any of the following
conditions [§63.1361]:
• you shutdown the processing equipment that discharges the intermediate to the storage
vessel before you start up the processing equipment that withdraws the intermediate from
the storage vessel
• you store the intermediate in the vessel for at least 30 days before it is used to make a PAI
• the equipment that produces the intermediate is located in a separate building (or
processing area) than the equipment that uses the intermediate as a feedstock. The control
equipment cannot be shared by the two processing areas
How is "nondedicated" equipment regulated?
The discussion under "What is a PAI process unit," explained that a PAI process unit is defined
based on the product being produced, regardless of the equipment.
However, you may use the same equipment to produce different products (both PAIs and other
types of compounds) at different times, or there may be overlap of at least some of the equipment
used to make different products. For this document, this equipment is referred to as
"nondedicated" equipment, and in some cases Subpart MMM allows you to comply with a
different MACT rule when you use such equipment to produce a PAI.
Typically, you must comply with the requirements of Subpart MMM for each PAI process unit.
However, for PAI process units that are comprised of nondedicated equipment, you may
determine applicability
cased on tne lOllOWing ^£ purp0se 0-fthis alternative for nondedicated equipment is to minimize the
alternative procedure possibility for overlap between Subpart MMM and other MACT standards (e.g.,
[§63.1360(h)J: Pharmaceuticals, polymers and resins, etc.) for equipment used in multiple process
units. Examples of how to apply the PUG concept are illustrated for several case
studies in EPA 305-B-04-001.
® First, categorize the nondedicated equipment into one or more process unit groups
(see the definition of process unit group on page 2-7)
® Then, determine the primary product for each process unit group (see note below)
@ Finally, for each PAI process unit within a process unit group, you may elect to
comply with another applicable MACT rule as a means of demonstrating compliance
with Subpart MMM, under either of the following conditions:
if any product produced in the process unit
group is subject to the pharmaceutical Exceptions to the Subpart GGGprovision
MACT rule (Subpart GGG of 40 CFR are listed in $63-I360(h)(2).
part 63), you may elect to comply with
Subpart GGG [§63.1360(h)(2)]
2-10
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if the primary product of a process unit group is a material that is subject to another
MACT rule on June 23, 1999, or date of startup, whichever is later, you may elect to
comply with that other subpart [§63.1360(h)(3)].
Note: Your primary product is the type of product (e.g., pharmaceutical products, PAI's, etc.) you expect to
produce for the greatest operating time in the 5-year period following the compliance date or the initial startup
of the process unit group, whichever is later. Alternatively, if you expect the operating time to be the same for
two or more process units, your primary product is the product that you expect to produce the greatest amount of
on a mass basis [§63.1360(h)(l)(iv)].
This alternative does not address situations in which the primary product of a process unit group is PAI's, and
the other product(s) are not limited to pharmaceuticals. In these situations, you must consult the rule(s) that
apply to any other products to determine the requirements that apply when you use the equipment to produce
those products. For example, §63.2535(l)(3)(ii)(B) of the Miscellaneous Organic Chemical Manufacturing
NESHAP (Subpart FFFF) allows compliance with Subpart MMMfor miscellaneous organic chemical
manufacturing processes within the process unit group if the primary product of the process unit group is
determined to be pesticide active ingredients.
How do I know if a storage vessel is part of a PAI process unit?
In general, your storage vessel is considered part of the process unit that either supplies the
greatest input to the storage vessel or uses the greatest output from the storage vessel. If this
process unit is a PAI process unit, the storage vessel is subject to Subpart MMM [§63.1360(f)(2)].
Exceptions to this general rule are described in Chapter 4 for each of the following types of
storage vessels:
• storage vessels in tank farms
,,,,, , . , , / j / ,, These procedures are
storage vessels that have equal input to (and/or output *. „ ,, ,,
0 ^i f \ f essentially the same as those
from) two or more processes ,-„ t
storage vessels for which the use varies or changes
storage vessels that are subject to other MACT standards on the effective date of Subpart
MMM
What requirements apply during periods of startup, shutdown, and
malfunction?
You must comply with the emission limits in Subpart MMM at all times, except during periods of
startup, shutdown, and malfunction if all of the following apply [§63.1360(e)(l)]:
the startup, shutdown, or malfunction prevents you from complying with any emission
limit, design, or work practice standard that otherwise applies
2-11
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• you follow the procedures in your startup, shutdown, and malfunction plan as specified in
§63.1367(a)(3)
you implement, to the extent reasonably available, means to prevent or minimize
emissions (e.g., identify control devices, work practices, pollution prevention measures,
etc.) in your startup, shutdown, and malfunction plan [§63.1360(e)(4)J
you submit reports of periods of startup, shutdown, and malfunction as specified in
§63.1368(i)
You may not shut down equipment used to control emissions if the shutdown would cause
emission limits to be exceeded, except in either of the following circumstances [§63.1360(e)(3)J:
• the control equipment is malfunctioning
the control equipment would be damaged as a result of a malfunction in the PAI process
unit.
What provisions in this rule overlap provisions in other rules?
Your options in the event that, for a given PAI process unit, the applicability of Subpart MMM
overlaps with another regulation after the compliance date of Subpart MMM are as follows:
[§63.1360(i)]
If, for the following emission Subpart MMM overlaps with the
point... following rule...
Then..
All emission points
Other MACT rules in 40 CFR
part 63 (e.g., the HON,
Pharmaceuticals, etc.)b
• Choose, to the extent the subparts are
consistent, under which subpart you will
maintain your records and reports
• For 40 CFR 63, Subpart A (General
Provisions) check Table 1 of Subpart
MMM final rule to determine which
Subpart A requirements apply to your
emission point
• Develop a process unit group as
described in the section "How is
nondedicated equipment regulated" on
page 2-10
Equipment leaks
Subpart I in 40 CFR part 63
Comply with either the provisions of
Subpart MMM or the provisions of
Subpart H of 40 CFR part 63
Storage vessels
(Group 1 and 2)
Subpart Kb of 40 CFR part 60
[NSPS]
Comply only with the provisions of
Subpart MMM
2-12
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If, for the following emission Subpart MMM overlaps with the
point... following rule... Then...a
Process vents Subparts III, NNN, or RRR of Comply only with Subpart MMM if the
40 CFR part 60 [NSPS] process vent subject to the other subpart is
controlled to 98 percent.
Otherwise, comply with both Subpart
MMM and Subparts III, NNN and RRR as
applicable.
Process vents, equipment Subparts AA, BB, and CC of Comply either with the monitoring,
leaks, waste management 40 CFR parts 264 and 265 recordkeeping, and reporting requirements
units [RCRA] in Subpart MMM, or the other subparts.
However, you must report all excursions as
required in §63.1368(g) of Subpart MMM
Wastewater streams 40 CFR parts 260 through 272 Comply with whichever rule has the more
[RCRA] stringent control, testing, monitoring,
recordkeeping, and reporting requirements
a Identify which subpart you have chosen to comply with in your Notification of Compliance Status Report as
required under Subpart MMM. For wastewater streams, keep records of the information used to determine which
requirements were the most stringent and submit the information to the Administrator if requested to do so.
b An offsite reloading or cleaning facility that supports railcars or tank trucks that are used in your vapor balancing
alternative for storage tanks need comply only with the provisions of the subpart of 40 CFR part 63 that applies to
their facility.
What is exempt from the rule?
Section 63.1360(d) specifies that the rule does not apply to any of the following:
• research and development facilities
PAI process units that are subject to 40 CFR 63, Subpart F
• ethylene production
• coal tar distillation
stormwater from segregated sewers
• water from fire-fighting and deluge systems, including testing of such systems
spills
• water from safety showers
• noncontact steam boiler blowdown and condensate
laundry water
• vessels storing materials that contain no organic HAP or contain organic HAP as
impurities only
2-13
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• equipment (e.g., flanges, valves, pumps, etc.) intended to operate in organic HAP service
for less than 300 hours during the calendar year. (However, you must keep a list of such
equipment.)
In addition, under §63.1361, the following are not considered to be part of the PAI process unit:
• formulation of pesticide products (i.e., the mixing or blending of active ingredients with
each other or inert ingredients)
QA/QC laboratories
2-14
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Chapter 3 - Complying with requirements for process vents
What is a process vent?
A process vent is a point of emission from processing equipment to the atmosphere or a control
device [§63.1361]. The vent may be the release point for either of the following:
• an emission stream associated with an individual unit operation, or
emission streams from multiple unit operations that have been manifolded together into a
common header.
Examples of process vents include, but are not limited to, vents on the following:
condensers used for product recovery
• bottom receivers
• surge control vessels Vents °" storase vessels>
emission sources, and equipment leaks
' reactors are not process vents. See "What
process vents are exempt? " on page 3-2
• filters for the minimum HAP concentration that
an emission stream must have to be a
• centrifuges process vent.
• process tanks
• dryers
What process vents does Subpart MMM apply to?
Subpart MMM applies to all process vents that:
• are part of processes at an affected source
• emit organic HAP and/or chlorine (C12) and hydrochloric acid (HC1)
are not exempt
All process vents (new or existing) are called either "Group 1" process vents or "Group 2"
process vents.
Process vents are in Group 1 and are subject to controls if any of the following apply
[§63.1362(b)(2)(i),
3-1
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• the collective uncontrolled organic HAP emissions from all of the vents in the process are
greater than 0.15 Mg/yr; or
• the collective uncontrolled HC1/C12 emissions from all of the vents in the process are
greater than 6.8 Mg/yr.
Note: The uncontrolled HCI/C12 threshold includes HCl/Cl2from the process itself as
well as HCI/C12 created in combustion control devices that are used to control emissions
of halogenated organic compounds.
Process vents that do not meet the definition of Group 1 process vents are called Group 2
process vents. Group 2 process vents do not require controls, but you must calculate the
uncontrolled emissions for these processes and monitor either the number of batches per year
(for batch operations) or the operating hours per year (for continuous operations) to demonstrate
that annual emissions are below the limit for Group 2 processes.
Note: Particulate matter emissions from process vents also require control if the vents are
from product dryers that dry a PAI or integral intermediate that is also a HAP or a bag
dump that is used to add a solid HAP material to the process (excluding HAP present only as
impurities).
What process vents are exempt?
A vent is not a process vent if the undiluted
and uncontrolled emission Stream released The definition of process vent in §63.1361 describes ways
through the vent contains less than 50 ppmv to determine the HAP concentration.
HAP.
If your Group 1 process vents discharge to any of the following control devices, they are exempt
from the initial compliance demonstrations, monitoring provisions, and associated recordkeeping
and reporting requirements under Subpart MMM [§§63.1362(1), 63.1365(a)(4), and
63.1366(b)(l)(ix)(B)]. However, all other Subpart MMM provisions apply for these processes
(e.g., requirements to determine applicability and standards for storage tanks, wastewater, and
equipment leaks).
• A boiler or process heater burning hazardous waste for which you have:
*• been issued a final permit for the boiler or process heater under 40 CFR part 270 and
are complying with the requirements of Subpart H in 40 CFR part 266
*• certified compliance with the interim status requirements of Subpart H in 40 CFR part
266.
3-2
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• A hazardous waste incinerator for which you have:
*• been issued a final permit for the incinerator under 40 CFR part 270 and you are
complying with the requirements of Subpart O in 40 CFR part 264
*• certified compliance with the interim status requirements of Subpart O in 40 CFR
part 265.
• A boiler or process heater with a design heat input >44 MW
• A boiler or process heater for which the emission stream is introduced with the primary
fuel
What compliance options do I have for my Group 1 process vents?
Compliance options are categorized by organic HAP emissions and HC1/C12 emissions. The
options are similar for existing and new sources. The main difference is higher percent
reductions in organic HAP and HC1/C12 emissions are required for vents at a new source under
the following conditions:
98 percent reduction instead of 90 percent reduction for all organic HAP emissions, not
just those from "large" vents.
• 99 percent reduction instead of 94 percent reduction in HC1/C12 emissions if the
uncontrolled emissions are >191 Mg/yr.
Compliance options are explained in greater detail below. A summary is available in Table 3-1.
Organic HAP emissions for "large" vents - Existing Sources
Each process vent that meets both of the following conditions is subject to more stringent
organic HAP controls than other vents:
Procedures to calculate uncontrolled emissions
Uncontrolled organic HAP emissions are are specified in §63.1365(c)(2).
>22.68 Mg/yr
• "Low flow" emission stream [i.e., the flow-weighted average flow rate of the vent as
calculated using equation 1 in §63.1362(b)(2)(ii) is less than or equal to the flow rate
index calculated using equation 2 in §63.1362(b)(2)(ii)]
For ease of discussion in this document, we refer to vents that meet these conditions as "large"
vents, although subpart MMM does not use this or
any other term to describe these vents. For these See Chapter 7for example calculations used
large vents, you have the following five control to identify a large vent.
options for the organic HAP emissions:
3-3
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TABLE 3-1. Compliance Options for Process Vents
If you have And your process
a(n)... vents are... Then, for... Your compliance options are...a
Existing
source
Group 1 for
organic HAP
(>0.15Mg/yr/
process)
Group 1 for
HC1/C12
(>6.8 Mg/yr/
process)
each "large" vent
reduce organic HAP emissions by
>98 percent (Option 1)
reduce organic HAP emissions to
< 20 ppmv (Option 2)
use a flare that meets the
requirements of §63.1 l(b)
(Option 3)
use the alternative standard (Option
4)
continue reducing HAP emissions
by percentage achieved on or
before 11/10/97, if that amount is
> 90 percent (Option 5)
any individual vent or any
combination of vents, excluding large
vents
reduce organic HAP emissions to
<20 ppmv (Option 2)
use a flare that meets the
requirements of §63.1 l(b)
(Option 3)
use the alternative standard
(Option 4)
the collective emissions from all
vents, excluding large vents, not
controlled by Option 2, Option 3, or
Option 4
reduce HAP emissions by > 90 percent
(Option 6)
any individual vent or any
combination of vents
reduce emissions to <20 ppmv
(Option 7)
use the alternative standard
(Option 8)
the collective emissions from all vents
not controlled by Option 7 or
Option 8
reduce HC1/C12 emissions by
> 94 percent (Option 9)
New source
Group 1 for
organic HAP
(>0.15 Mg/yr/
process)
any individual vent or any
combination of vents
reduce organic HAP emissions to
<20 ppmv (Option 2)
use a flare that meets the
requirements of §63.1 l(b)
(Option 3)
use the alternative standard
(Option 4)
the collective emissions from all vents
not controlled by Option 2, Option 3,
or Option 4
reduce organic HAP emissions by
>98 percent (Option 1)
3-4
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TABLE 3-1. (cont'd)
If you have And your process
a(n)... vents are...
Then, for...
Your compliance options are...a
Group 1 for
HC1/C12
(>6.8 Mg/yr/
process and
< 191 Mg/yr/
process)
any individual vent or any
combination of vents
reduce emissions to <20 ppmv
(Option 7)
use the alternative standard
(Option 8)
the collective emissions from all vents
not controlled by Option 7 or
Option 8
reduce HC1/C12 emissions by
> 94 percent (Option 9)
Group 1 for
HC1/C12
(>191 Mg/yr/
process)
any individual vent or any
combination or vents
reduce emissions to <20 ppmv
(Option 7)
use the alternative standard
(Option 8)
the collective emissions from all vents
not controlled by Option 7 or
Option 8
reduce HC1/C12 emissions by > 99
percent (Option 10)
New or
existing
source
a source of
paniculate matter
emissions
the vent from each product dryer that
drys a PAI or integral intermediate
that is also a HAP
reduce paniculate matter emissions to
<0.01gr/dscf (Option 11)
the vent from each bag dump that is
used to introduce a HAP solid to the
process, excluding HAP present only
as impurities
reduce paniculate matter emissions to
<0.01gr/dscf (Option 11)
Group 2 for
organic HAP
and/or HC1/C1,
the process
no control required, but recordkeeping
is required to demonstrate compliance
with the 0.15 Mg/yr threshold for
organic HAP emissions and the
6.8 Mg/yr threshold for HC1/C12
emissions
a For each option, emissions must be routed from the process vent to the control device through a closed-vent
system.
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Option 1: 98% reduction [§63 1362(b)(2)(ii)]
Reduce total organic HAP emissions by at least 98 weight percent
Option 2: reduce outlet concentration [§631362(b)(2)(iv)(A)]
Reduce organic HAP emissions to an outlet concentration of <20 ppmv
OptionS: use a flare [§63.1362(b)(2)(iv)(B)]
Use a flare that meets the requirements of §63.1 l(b) (Subpart A General Provisions) to
control total organic HAP emissions
Option 4: use alternative standard [§63 1362(b)(6)]
Reduce total organic HAP emissions to an outlet concentration of <20 ppmv as total organic
compounds (TOC) if you use a combustion device, or to <50 ppmv as TOC if you use a
noncombustion device
Note: The outlet concentration when using a combustion device is the same as for Option 2,
but the alternative standard requires monitor ing with CEMS, whereas Option 2 requires an
initial performance test (or design evaluation) and monitoring of control device operating
parameters.
OptionS: current % reduction [§63 1362(b)(2)(ii)(B)]
Reduce uncontrolled total organic HAP emissions by at least 90 weight percent if the
emissions were already reduced by at least 90 weight percent by a control device installed on
or before November 10, 1997.
Organic HAP emissions for "all" process vents - Existing Sources
For all process vents within a process that do not fit the definition of a "large" vent, you have
four compliance options available. For any individual vent or any combination of vents you
may comply using Option 2, Option 3, or Option 4 as described above. For the collective
emissions from all vents not controlled by one of these three options, you must use:
Option 6: 90% reduction [§63 1362(b)(2)(ii)]
Reduce uncontrolled organic HAP emissions by at least 90 weight percent
HCI/CI2 emissions - Existing Sources
For uncontrolled HC1/C12 emissions, you have three compliance options available. You may
control any individual process vent or any combination of process vents using:
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Option?: reduce outlet concentration [§63 1362(b)(3)(ii)]
Reduce uncontrolled HC1/C12 emissions to an outlet concentration of <20 ppmv
OptionS: use alternative standard [§63 1362(b)(6)]
Reduce uncontrolled HC1/C12 emissions to an outlet concentration of <20 ppmv if you use a
combustion device to control halogenated organic HAP, or to <50 ppmv if you control
HC1/C12 from the process using a noncombustion device.
Note: The outlet concentration is the same as for Option 7 if you use a combustion device to
control halogenated organic compounds, but the alternative standard requires monitoring
with CEMS, whereas Option 7 requires an initial performance test (or design evaluation) and
monitoring of control device operating parameters.
You must control collective uncontrolled HC1/C12 emissions from all Group 1 process vents that
are not controlled by Option 7 or Option 8 using:
Option9: 94% reduction [§63 1362(b)(3)(ii)]
Reduce uncontrolled HC1/C12 emissions by at least 94 weight percent
Organic HAP emissions - New Sources
For the organic HAP emissions, you have four compliance options available. You may control
organic HAP emissions from any individual vent or any combination of vents within a process
using Option 2, Option 3, or Option 4 as described above. You must use Option 1 as
described above to control the collective emissions from all Group 1 process vents that are not
controlled using Option 2, Option 3, or Option 4.
HCI/CI2 emissions - New Sources
Your compliance options for your new uncontrolled HC1/C12 sources depends on the amount of
your uncontrolled emissions. The two categories are: (1) >6.8 Mg/yr but <191 Mg/yr and (2)
>191 Mg/yr. Regardless of the uncontrolled emissions, two of your options are to control any
individual process vent or any combination of process vents using Option 7 or Option 8 as
described above.
If the collective uncontrolled HC1/C12 emissions from all of the process vents within a process
are >6.8 Mg/yr and <191 Mg/yr, your third compliance option is to control the collective
uncontrolled HC1/C12 emissions from all Group 1 process vents that are not controlled by Option
7 or Option 8 using:
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Option 9: 94% reduction [§63 1362(b)(5)(ii)]
Reduce uncontrolled HC1/C12 emissions by at least 94 weight percent
If, however, your uncontrolled HC1/C12 emissions from the sum of all process vents within a
process are > 191 Mg/yr, your third compliance option is to control the collective uncontrolled
HC1/C12 emissions from all Group 1 process vents that are not controlled by Option 7 or Option
using:
Option 10: 99% reduction [§63 1362(b)(5)(iii)]
Reduce uncontrolled HCl/Cl2 emissions by at least 99 weight percent
What compliance options do I have for process vents that emit
participate matter?
You have one compliance option for particulate matter emissions at both existing and new
sources. The compliance option applies to two types of
processing equipment: (1) product dryers that dry a
product or integral intermediate that is also a HAP and (2) Particulate matter emissions from all
bag dumps that are used to add a solid material that is also a other vents are exempt.
HAP to the process, excluding solid materials that contain
HAP only as impurities. Your compliance option is:
Option 11: reduce outlet concentration [§63 1362(e)(l)and(2)]
Reduce uncontrolled particulate matter emissions to outlet concentrations of <0.01 gr/dscf
How do I show initial compliance with the process vent requirements?
How you show initial compliance depends on which options you choose and which types of
activities generate emissions from your processes.
Typically, to demonstrate initial compliance, you will need to calculate the uncontrolled
emissions from each activity in your process that generates emissions. The emissions for these
activities are also called "emission episodes." You will need the uncontrolled emissions to
determine whether the process has Group 1 or Group 2 process vents. You also may need
uncontrolled emissions to:
• determine conditions under which the performance test or design evaluation must be
performed
• determine whether a control device is "large" or "small"
• use in calculations of the percent reduction for a process
3-8
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Compliance with Group 2 emission limits
You demonstrate initial compliance with the Group 2 cutoffs for uncontrolled organic HAP and
HC1/C12 mass emission limits by projecting the annual uncontrolled emissions for the process.
You do this by performing all of the following: [§63.1365(c)(l)(i), (ii)]
calculating the uncontrolled emissions for each emission episode within the process
• summing the emissions for all emission episodes from batch operations and multiplying
by the estimated annual number of batches
• summing the emissions for all emission episodes from continuous operations in the
process and multiplying by the estimated operating time per year
Note: One approach would be to estimate emissions from continuous operations on an
hourly basis and then multiply by the number of operating hours per year.
Equations for calculating uncontrolled emissions from the following activities are included in
§63.1365(c)(2)(i)(B) of the rule:
filling
Most of the calculations require you to estimate the HAP
purging partial pressure. Section 63.1365(c)(2)(i)(A) describes
options for estimating partial pressure. Chapter 7
heating provides example calculations and references to other
. . . documents with additional examples.
depressunzation
• vacuum systems
• gas evolution
air drying
If your emissions are due to activities other than
listed above, you must conduct an engineering Information and procedures that may be
assessment to determine your emissions used in an engineering assessment are
[§63.1365(c)(2)(ii)]. described in §63.1365(c)(2)(ii).
You may also request approval from the Administrator
to determine emissions from any of the listed activities based on an engineering assessment.
Compliance with percent reduction options (Option 1, 5, 6, 9, or 10)
You demonstrate initial compliance with the percent reduction options by doing all of the
following:
• determine uncontrolled emissions for all emission episodes that are part of the analysis
• determine controlled emissions for these emission episodes
3-9
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sum the uncontrolled and controlled emissions and calculate the overall percent reduction
Note: If all process vent emissions from a process are controlled using a single control
device that achieves at least 98% reductions, and a performance test is conducted over an
entire batch cycle, then calculating the uncontrolled and controlled emissions for each
emission episode is not necessary. §63. 1365(b)(ll)(iii)(D)
If all process vents from a process are controlled using a single control device, then
calculating controlled emissions for each emission episode is not necessary.
You determine uncontrolled emissions as described above. The procedures to determine
controlled emissions vary depending on whether you use a condenser, a "large" control device,
or a "small" control device.
Definition: Large control device means a device that controls
process vents, and the combined inlet HAP emissions into the
control device from all sources are > 10 tons/yr.
Definition: Small control device means a device that controls
process vents, and the combined HAP emissions into the
control device from all sources are <10 tons/yr.
For condensers, you calculate controlled emissions for each emission episode by doing both of
the following: [§63.1365(c)(3)(iii)]
determine the outlet gas temperature that, when used in the appropriate equation in
§63.1365(c)(3)(iii), yields controlled emissions at the required percent reduction from
uncontrolled levels
measure the outlet gas temperature from the condenser and show that it is less than or
equal to the temperature used in the calculation
For control devices other than a condenser, you calculate controlled emissions based on the
following steps:
• determine whether you have a large control device or a small control device based on the
total annual inlet uncontrolled HAP emissions
for a large control device, calculate the control If a small control device becomes a large
efficiency using a performance test control device, you must then recalculate
TS63 1365(c)(3)(ii)l the control efficiencies using the results of
' \ J\ J\ }i a performance test.
for a small control device, calculate the control
efficiency using either a performance test or a design evaluation [§63.1365(c)(3)(i)]
calculate controlled emissions using the uncontrolled emissions and the calculated
control efficiency
3-10
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Note: Both design evaluations and performance tests must be conducted under the most
challenging conditions for the device. The rule defines the most challenging conditions as
either absolute or hypothetical peak-case conditions. The procedures for determining the
absolute or hypothetical peak-case conditions are described in §63.1365(b)(ii).
The parameters to consider in design evaluations for different types of control devices are
described in §63.1365(a)(l).
Compliance with outlet concentration options (Option 2 or 7)
You demonstrate compliance with the 20 ppmv outlet concentration limit for organic HAP by
measuring either total organic HAP or TOC [§63.1365(a)(6)].
You determine initial compliance with the 20 ppmv outlet concentration limits by testing using
an applicable EPA method (e.g., Ml8 for total organic HAP, M25A for TOC, or M26 for HC1)
under the most challenging conditions for the device [§63.1365(c)(l)(v)].
If you combine supplemental gases with the emission stream, you must correct the measured
concentrations as follows:
To 3 percent oxygen, if you use a combustion control device [§63.1365(a)(7)(i)].
• By the ratio of the total flow to the flow without supplemental gases, if you use a
noncombustion control device [§63.1365(a)(7)(ii)]
Definition: Supplemental gases means any nonaffected gaseous streams (streams that are not from
process vents, storage vessels, equipment or waste management units) that contain less than 20
ppmv TOC and less than 20 ppmv total HC1 and chlorine, as determined through process
knowledge, and are combined with an affected vent stream. Air required to operate combustion
device burner(s) is not considered a supplemental gas.
Compliance using a flare (Option 3)
When you use a flare as your control device, demonstrate initial compliance by doing all of the
following:
• determine visible emissions using Method 22 of 40 CFR part 60, Appendix A, as
described in §63.1 l(b)(4) of the General Provisions (i.e., the flare must produce no
visible emissions, except for a period not to exceed 5 minutes in a 2-hour observation
period).
determine under absolute or hypothetical peak-case conditions, the net heating value of
gas being combusted and its exit velocity as specified in §63.1 l(b)(6) through (8) of the
General Provisions [§63.1365(a)(3), (c)(l)(vii)]
3-11
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Compliance with the alternative standard (Option 4 or 8)
You demonstrate initial compliance with the alternative standard by having the monitoring
equipment installed and operational on the compliance date (see "How do I monitor to comply
with the alternative standard" later in this chapter).
In addition, if you intend to calibrate the monitor using the predominant HAP, you will have to
use Method 18 to determine the predominant HAP [§63.1365(a)(5), (c)(l)(vi)].
Compliance with particulate matter concentration limits (Option 11)
For bag dumps and product dryers, you demonstrate initial compliance with the outlet
concentration limit of 0.01 gr/dscf by conducting a performance test using Method 5 of appendix
A of 40 CFR part 60. [§63.1365(b)(7)]
What monitoring must I do for my process vents?
To demonstrate ongoing compliance with the option you selected, you must monitor one or more
parameters, and you must inspect closed-vent systems for leaks. Typically, your monitoring
requirements consist of all of the following:
Identifying the parameter(s) to monitor
• Setting site-specific limits for the parameter(s)
• Averaging the measured values for comparison with the limits
Each of these steps is discussed in more detail below.
What parameters must I monitor?
The specific parameters that you must monitor, and the required frequency of monitoring, will
depend on the type of control device that you use and if the total inlet HAP emissions going into
your control device is <0.91 Mg/yr or >0.91 Mg/yr.
If the total inlet HAP emissions to your control device are <0.91 Mg/yr, you are required to
conduct a periodic verification that the device is operating properly.
To provide the verification you must demonstrate on a daily, or more frequent, basis that the
control device is working as designed.
One example of an acceptable periodic Jou describe the verification procedure you intend
verification demonstration is to conduct a daily to use in your Precompliance Plan.
3-12
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measurement of the same parameter(s) that must be monitored for larger control devices, as
described below [§63.1366(b)(l)(i)].
Note: The periodic verification does not apply for the alternative standard (Option 4 or 8);
you must always continuously monitor the outlet concentration^) using a CEMS.
If the total inlet HAP emissions to your control device are >0.91 Mg/yr, you must monitor either
the outlet emission concentration or various operating parameters as described in
§63.1366(b)(l)(ii) through (xi). These monitoring requirements are summarized in Table 3-2.
Note: Each monitoring device must be calibrated annually, and the required accuracy of
each device is specified in §63.1366(b)(l) of the rule.
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TABLE 3-2. Monitoring Requirements for Air Pollution Control Devices
If you are
complying with
the following
compliance
options...
And the total inlet
HAP emissions to
your control
device are...
And you are using
the following
control device...
Then you must monitor this
parameter. . .a At this frequency. . .
According to these
sections of the rule...
Options 1, 2, 5-7,
9, 10, and 11
<0.91 Mg/yr any control device parameter(s) specified in your
approved precompliance plan that
demonstrate the control device is
operating as designed
at least once per day
§63.1366(b)(l)(i)
Options 1,2,5-7,
9,10, and 11
(e.g., any %
reduction or outlet
concentration
option, except the
alternative
standard", Option
4 or 8)
>0.91 Mg/yr
Scrubber
Condenser
Regenerative
carbon adsorber
liquid flow rate into scrubber or
pressure drop across the scrubber
every 15 minutes
§63.1366(b)(l)(ii)
also monitor the pH if the scrubber once per day
uses a caustic solution to remove
acid gases
§63.1366(b)(l)(ii)
condenser outlet gas temperature
regeneration frequency (time
since the end of the last
regeneration), and
temperature to which the bed
is heated during regeneration,
and
temperature to which the bed
is cooled, and
regeneration stream flow, and
check for bed poisoning
following manufacturer's
specifications
every 15 minutes
• each regeneration cycle
• each regeneration cycle
within 15 minutes of
completing the cooling
phase of each
regeneration cycle
each regeneration cycle
once per year
§63.1366(b)(l)(iii)
§63.1366(b)(l)(iv)
-------
TABLE 3-2. (cont'd)
If you are
complying with
the following
compliance
options...
And the total inlet
HAP emissions to
your control
device are...
And you are using
the following
control device...
Then you must monitor this
parameter...a
At this frequency...
According to these
sections of the rule..
Nonregenerative
carbon adsorber
operating time since last
replacement, or
n/a
• monitor TOC concentration in • daily, or at an interval no §63.1366(b)(l)(v)(A)
exhaust vent stream for greater than 20 percent of
breakthrough the time needed to
consume the total
working capacity of the
carbon under peak-case
conditions
Thermal temperature of gases exiting the every 15 minutes §63.1366(b)(l)(vii)
incinerator combustion chamber
Catalytic temperature difference across the every 15 minutes §63.1366(b)(l)(viii)
incinerator catalyst bed
Process heater temperature of gases exiting the every 15 minutes §63.1366(b)(l)(ix)(A)
and boiler (except combustion chamber
those covered by
Option 4)
Fabric filter use a bag leak detection system continuously §63.1366(b)(l)(xi)
that provides an output of relative
paniculate matter emissions
any other device identify applicable parameters and part of the request for §63.1366(b)(4)
request approval to use approval
Options >0.91Mg/yr Flare presence of pilot flame every 15 minutes §63.1366(b)(l)(vi)
(e.g., using a
flare)
-------
TABLE 3-2. (cont'd)
If you are
complying with
the following
compliance
options...
Option 4 or 8
(e.g., alternative
standard)
And the total inlet
HAP emissions to
your control
device are...
All
And you are using
the following
control device...
Any control
device
Then you must monitor this
parameter. . .a At this frequency. . .
outlet TOC concentration and/or every 15 minutes
outlet HC1/C12 concentration using
CEMS meeting PS 8 or 9 of
Appendix B of Part 60
According to these
sections of the rule...
§63.1366(b)(5)
a Note that for all control devices, a closed vent system that contains a bypass line that could divert a vent stream away from the control device must be
monitored for flow in the bypass line every 15 minutes, or the bypass line valve must be secured in the closed position with a car seal or lock and key type
configuration, and the seal or closure mechanism must be visually inspected once per month [§63.1366(b)(l)(xiii) and 63.1362(j)].
" As an alternative to the specified operating parameters for control devices used to comply with any of the percent reduction or outlet concentration options
for organic HAP emissions and HC1/C12 emissions you may use a continuous emissions monitoring system (CEMS) meeting the requirements of
Performance Specifications (PS) 8 or 9 of Appendix B of Part 60 to monitor TOC and/or HC1/C12 every 15 minutes [§63.1366(b)(l)(x)].
-------
How do I set monitoring parameter limits?
You establish the limit against which your monitored values for a control device operating
parameter is compared during the initial compliance
demonstration [§63.1366(b)(3)(i) and (ii)]. This limit
will be associated with the most challenging conditions The monitoring parameter limits and your
for the control device, and is used to demonstrate rationale for these limits are subject to
ongoing compliance review and approval by the Administrator.
If you demonstrate initial compliance by conducting a
performance test, you establish minimum or maximum monitoring limits based on the average of
the average values from each of the three test runs [§63.1366(b)(3)(ii)(A)].
In addition to setting monitoring limits for the most challenging conditions, you also may set
additional monitoring limits for less challenging conditions.
For example, if you use a scrubber to control several process vents within a batch process, you
must set at least one scrubber liquid flow rate limit, and this limit must be associated with the
most challenging operating conditions under
which the initial compliance determination is
j . j A «-•.•• ,1 •, j ii You must record in a daily schedule or log the
conducted. Maintaining the monitored scrubber •<<,-,<, *;••*; ^
° points at which the parameter limit changes, and
flow above this limit at all times demonstrates at ieast one reading must be taken after each
that the required percent reduction is being met. change, even if the duration associated with that
However, if the HAP emitted from one vent is limit is less than 15 minutes.
more soluble than the HAP emitted from other
vents (i.e., it is a period that does not constitute
the most challenging conditions for the control device), you may decide to set a lower flow rate
limit for the time that vent is being controlled. But you must demonstrate that the required level
would still achieve the required control level.
To establish monitoring levels for the less challenging conditions, you may supplement the
performance test results with an engineering
assessment and/or manufacturers „, n ,. n, ,, , .,,,,.
. . „ . I he Precompliance Plan must be submitted far
recommendations. Your rationale for the approval at least 6 months before the Compliance
specific level(s) must be provided in your date. See Chapter 8.
Precompliance Plan.
Note: Limits are not applicable for flares (option 3) because the monitored parameter, the
presence or absence of a pilot flame, can not vary over a range.
Monitoring limits for the alternative standard and for product dryers and bag dumps are
defined in the standards themselves, and you may not set multiple limits when complying with
these standards.
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How do I monitor to comply with the alternative standard?
If you choose to comply with the alternative standard, your monitoring requirements include all
of the following: [§63.1366(b)(5)]
use CEMS to monitor outlet TOC and total HC1/C12 concentrations at least once every 15
minutes
• typically, adjust the measured concentrations to account for supplemental gases that are
added to the emission stream. For combustion devices, you may monitor residence time
and firebox temperature as an alternative to adjusting the concentration
use a TOC monitor that meets the requirements of Performance Specification 8 or 9 of
appendix B of 40 CFR part 60
• install, calibrate, maintain, and operate the monitors in accordance with §63.8 of subpart
A of 40 CFR part 63
Note: You do not have to monitor the total HCI/C12 concentration if you know that the process
(or control device) does not generate HCI/C12.
Procedures for adjusting the outlet concentration to account for supplemental gases are
specified in §63.1365(a)(7), and alternatives to correcting for supplemental gases are
specified in §63.1366(b)(5)(ii)(A) and(B).
How may I average my monitoring parameter values?
Typically, monitored parameter values must be averaged over either a day or a block. A daily
average is any continuous 24-hour period of your choice - it does not have to be from midnight
to midnight.
A block average is only for vents from batch operations, and it is limited to the period of time
that is, at a maximum, equal to the time from the beginning to the end of a series of consecutive
batch operations [§63.1366(b)(2)(i) and (ii)].
Monitoring values taken during periods of no flow or when venting streams that are not subject
to the rule should not be considered in either the daily or block averages. To identify periods of
no flow you must use a flow indicator at the inlet (or outlet) of the control device
[§63.1366(b)(2)(iii)].
Note: Averaging is not applicable for carbon adsorbers (except under option 4, the
alternative standard), for flares (option 3), and for fabric filters (option 11).
You must use daily averaging when complying with the alternative standard (option 4 or 8).
3-18
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How do I inspect my closed-vent systems?
You must inspect closed-vent systems for leaks initially (by the compliance date) and annually.
If your closed-vent system is constructed of
ductwork, you must perform sensory inspections „ ,., .. , , .,
J r j t- Calibration procedures and other requirements
(i.e., use Sight, sound, and smell to find for Method 21 inspections are specified in
indications of leaks) and perform inspections §63.1366(h)(3)(iii) through (vi). A leak is defined
using Method 21 of appendix A in 40 CFR part as a reading more than 500 ppm above
60. If your closed-vent system is constructed of background levels.
hard-piping, only sensory inspections are
required. [§63.1366(h)(2)(i) and (ii)]
If necessary, you may designate parts of the closed-vent system as unsafe-to-inspect or difficult-
to-inspect. These parts of the closed-vent
system do not have to be inspected on the „ ,... ,, , , , ,. , , ,
. . . . -111 Conditions that make parts oj a closed-vent system
schedule described above. However, you must unsafe-to-inspect or difficult-to-inspect are
inspect the unsafe-to-inspect equipment when it specified in §63.1366(h)(6) and (7).
is safe to do so (but not more frequently than
annually), and you must inspect the difficult-to-
inspect equipment at least once every 5 years. You must also have a written plan that states
when you will perform these inspections.
Any leaks that you detect while conducting an inspection must be repaired within 15 calendar
days from the date that you detected the leak,
and you must make a first attempt at repair „ , , . ...,, . . , . . ,,
. i f i • i You may delay repair if the repair is technically
within 5 calendar days after the leak is detected. infeasMe without a shutdown or if the emissions
After making a repair, you must reinspect the from immediate repair are likely to be greater
equipment using Method 21 to verify that the than the emissions from the unrepaired
repair was successful or to determine that the equipment.
equipment is nonrepairable. [§§63.1366(h)(4)
and63.1367(f)(4)(iii)]
Note: You do not have to inspect a closed-vent system that operates under negative pressure.
What records must I keep for my process vents?
For all compliance options, you must keep records of each measurement of a continuously
monitored operating parameter or CEMS reading that demonstrates continuous compliance.
[§63.1367(b)(l)] See Table 3-2 for a listing of the monitoring requirements. Recordkeeping
requirements that relate to demonstrating compliance with the process vent standards are
presented in Chapter 8.
3-19
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What reports must I submit for my process vents?
Reporting requirements are presented in Chapter 8.
3-20
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Checklists for Process Vent Inspections
Facility Name:
Facility Location:
Facility TRI ID #:
Inspector:
Date:
The table below explains which inspection checklists you should use for determining compliance
with the process vent requirements.
And the total inlet HAP And the process vent emission Then use the
If you emissions to the control streams are conveyed by a closed- following
follow... device are... vent system to ... checklists3:
any option, > 0.91 Mg/yr
except 3, 4,
and 8
a scrubber
a condenser
a regenerative carbon adsorber
a nonregenerative carbon adsorber
a thermal incinerator
a catalytic incinerator
a boiler or process heater with a
o
3
4
5
6
7
8
9
Starting on
page ...
3-28
3-30
3-32
3-34
3-35
3-37
3-39
design heat input of < 44
megawatts and for which the
emission stream is not introduced
with the primary fuel
3
4 or 8
any option,
except 4 and
8
> 0.91 Mg/yr
all
< 0.91 Mg/yr
a fabric filter
a flare
any control device
any control device
10
11
12
13
3-41
3-43
3-45
3-47
a Checklists 1 and 2 apply for all options.
3-21
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Checklist 1: Applicability (All Options)3
Facility Name:
Facility Location:
Facility TRI ID #:
Inspector:
Date:
Note: Answer questions 1 through 3 for organic HAP and HC1/C12 emissions, and answer question 4 for product
dryers and bag dumps. §63.1362(b)(2)(i), (3)(i), (4)(i), (5)(i), (e) and (1), §63.1365(a)(4), §63.1366(b)(l)(ix)(B)
Comments
1. Is the total organic HAP and HC1/C12 content of your emission D Yes D No
stream <20 ppmv?
Note: If you answer "yes" to this question for all emission
streams from process vents in a process, do not continue; your
process is not subject to control requirements for organic HAP
or HCI/C12. If you answer "no "for any emission streams from
process vents within a process, proceed to question 2.
1. Are the total uncontrolled organic HAP emissions from all D Yes D No
process vents in the process < 0. 15 Mg/yr, and are the total
uncontrolled HC1/C12 emissions from all process vents in the
process < 6.8 Mg/yr?
Note: If you answer "yes" to this question, do not continue;
your process is not subject to control requirements for process
vents. If you answer "no ", proceed to question 3.
3 . Does your process vent discharge to any of the following
control devices:
a boiler or process heater burning hazardous waste for
which you have:
* been issued a final permit under 40 CFR part 270 and D Yes D No
are complying with requirements of 40 CFR part 266,
subpart H; or
* certified compliance with the interim status D Yes D No
requirements of 40 CFR part 266, subpart H?
a hazardous waste incinerator for which you have:
* have been issued a final permit under 40 CFR part 270 D Yes D No
and are complying with the requirements of 40 CFR
part 264, subpart O; or
* have certified compliance with the interim status D Yes D No
requirements of 40 CFR part 265, subpart O?
a boiler or process heater with a design heat input D Yes D No
>44 megawatts?
a boiler or process heater for which the emission stream is D Yes D No
introduced with the primary fuel?
3-22
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Checklist 1: (cont'd)
Applicability (All Options)
Comments
Note: If you answer "yes " to using any of the control devices
listed in this question, do not continue; you are exempt from
the monitoring and associated recordkeeping and reporting
requirements. If you answered "no " to all of the questions,
your control device is subject to monitoring and
recordkeeping; proceed to checklist 2 for closed-vent systems
and to the appropriate checklist for your control device.
4. Does the emission stream contain paniculate matter from either D Yes D No
a bag dump that is used to add a HAP raw material or a product
dryer that drys a HAP product or integral intermediate?
Note: If you answer "no " to this question, your product dryer
or bag dump is not subject to control. If you answer "yes" to
this question, your product dryer or bag dump is subject to
control; proceed to checklist 10.
a The compliance options are described in the section "What compliance options do I have for my Group 1 process
vents?" and Table 3-1.
3-23
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Checklist 2: Requirements for closed-vent systems (All Options)3
Facility Name:
Facility Location:
Facility TRI ID #:
Inspector:
Date:
Note: A "yes" response to a question in this checklist means compliance with that requirement, and a "no"
response means noncompliance with the requirement. If the requirement is not applicable, indicate "N/A" in the
comments column.
A. Monitoring Requirements Comments
Note: Questions 2 through 4 do not apply for a closed-vent system that operates under negative pressure.
1 . If your closed-vent system has bypass lines that could divert a vent
stream away from the control device and to the atmosphere, have
you done one of the following:
used a flow indicator that takes a reading at least once every 15 D Yes D No
minutes at the entrance of the bypass line? §63.1362(j)(l)
performed a monthly visual inspection that the bypass line D Yes D No
valve is secured in the closed position with a car-seal or a
lock-and-key type configuration? §63.1362(j)(2)
Note: Low leg drains, high point bleeds, analyzer vents, open-ended
valves or lines, rupture disks, and pressure relief valves needed for
safety purposes are not subject to the monitoring requirements for
bypass lines. §63.1362(1)
1. If your closed-vent system is constructed of ductwork, do you D Yes D No
conduct annual inspections for leaks using Method 21 in appendix
A of 40 CFR part 60 and annual sensory inspections (based on
sight, sound, and smell) for indications of leaks?
§63.1366(h)(2)(ii)(B) and (C)
Note: When using Method 21, a leak is detected if the maximum
reading is at least 500 ppm greater than the background level.
Section 63.1366(h)(3)(ii) describes detection instrument
performance criteria such as response factors, calibration
procedures, and how to account for background levels.
3 . If your closed-vent system is constructed of hard-piping, do you D Yes D No
conduct annual sensory inspections for indications of leaks?
4. After repairing a leak, do you use Method 21 to confirm that the D Yes D No
leak is successfully repaired or that it is nonrepairable?
§63.1367(f)(4)(iii)
3-24
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Checklist!: (cont'd)
Requirements for closed-vent systems (All Options)
B. Recordkeeping and Reporting Requirements Comments
Note: Questions 3 through 8 do not apply for a closed-vent system that operates under negative pressure.
§§63.1366(h)(9) and (10)
1. If you use a flow indicator to monitor your closed-vent system
bypass line, do you have all of the following records:
§63.1367(f)(3)(i)
• hourly flow indicator readings? D Yes D No
times and durations of periods when the flow indicator is not D Yes D No
operating?
times and durations of periods when the vent stream is diverted D Yes D No
from the control device?
2. If you use a seal mechanism to prevent diversion of emission streams
through a bypass line, do you have all of the following
records: §63.1367 (f)(3)(ii)
• records that the monthly visual inspections of the seal or closure D Yes D No
mechanism have been done?
• records of all periods when the seal mechanism is broken, the D Yes D No
bypass line valve position has changed, or the key for a lock-and-
key type lock has been checked out?
3.
records of any car-seal that has broken?
Do your records identify all parts of the closed-vent system that you
designated as unsafe-to-inspect or difficult-to-inspect, and do the
records explain why you assigned the designation?: §63. 1367(f)(l)
and (2)
DYes
DYes
DNo
DNo
4. Do you have a written plan for inspecting the unsafe-to-inspect parts of D Yes D No
the closed-vent system as frequently as practicable (but not more than
once per year)? §§63.1366(h)(6)(ii) and 63.1367$(1)
5. Do you have a written plan for inspecting the difficult-to-inspect parts D Yes D No
of the closed-vent system at least once every 5 years?
§§63.1366(h)(7)(ii) and63.1367(^(2)
6. Do your records indicate that the closed-vent system is inspected for
leaks as follows: §§63.1366(h)(2)(i)(B), (ii)(B), and (ii)(C)
an annual sensory inspection (i.e., visual, audible, or olfactory) for D Yes D No
indications of leaks if the closed-vent system is constructed of
hard-piping?
3-25
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Checklist!: (cont'd)
Requirements for closed-vent systems (All Options)
B. Recordkeeping and Reporting Requirements Comments
both an annual sensory inspection and an instalment inspection D Yes D No
using Method 21 in appendix A of 40 CFR part 60 if the closed-
vent system is constructed of ductwork?
Note: When using Method 21, a leak is detected if the maximum
reading is at least 500 ppm greater than the background level.
Section 63.1366(h)(3)(ii) describes detection instrument performance
criteria such as response factors, calibration procedures, and how to
account for background levels.
7. For each inspection (sensory or Method 21) during which no leaks
were detected, do you have records of the following: §63.1367(f)(5)
and (6)
date of the inspection? D Yes D No
statement that no leaks were detected? D Yes D No
8. For each inspection (sensory or Method 21) during which a leak is
detected, do you have the following records: §63.1367(j)(4)
identification of the leaking equipment? D Yes D No
instrument identification number and operator name or initials (if D Yes D No
the leak was detected using Method 21), or a record that the leak
was detected by sensory observation?
the date the leak was detected? D Yes D No
the date of the first attempt to repair the leak? D Yes D No
Note: the first attempt to repair the leak must be no later than 5
calendar days after the leak is detected. §63.1366(h)(4)(i)
maximum instrument reading measured by Method 21 after the D Yes D No
leak is repaired or determined to be nonrepairable?
all of the following if the leak is not repaired within 15 days after
the leak was discovered:
* reason for the delay in repair? D Yes D No
* name, initials, or other form of identification of the person who D Yes D No
decided repairs cannot be made without a shutdown?
*• expected date of successful repair? D Yes D No
Note: delay of repair until the next shutdown is allowed if the
repair is technically infeasible without a shutdown, or if the
emissions from immediate repair would be greater than the
fugitive emissions likely from delay.
3-26
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Checklist!: (cont'd)
Requirements for closed-vent systems (All Options)
B. Recordkeeping and Reporting Requirements Comments
dates of shutdowns that occur while the equipment is unrepaired? D Yes D No
date of successful repair of the leak? D Yes D No
9. Are records retained for at least 5 years? §63.1367(a)(l) D Yes D No
10. Did you submit all of the following in your Periodic Report:
§63.1368(g)(2)(iii) and (xi)
records of all periods when the vent stream is diverted from the D Yes D No
control device?
records of all periods when the seal mechanism is broken, the D Yes D No
bypass valve position has changed, or the key to unlock the
bypass line valve was checked out?
records of inspections during which a leak is detected? D Yes D No
a The compliance options are described in the section "What compliance options do I have for my Group 1 process
vents?" and in Table 3-1.
3-27
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Checklist 3: Requirements for scrubbers (All options except 3, 4, 8, and ll)a
Facility Name:
Facility Location:
Facility TRI ID #:
Inspector:
Date:
Note: A "yes" response to a question in this checklist means compliance with that requirment, and a "no"
response means noncompliance with the requirement. If the requirement is not applicable, indicate "N/A" in the
comments column.
A. Monitoring Requirements §63.1366(b)(l)(ii) and (2)
Comments
1. Do you monitor scrubber liquid flow rate or pressure drop at least
once every 15 minutes during the period in which the scrubber is
controlling HAP from an emission stream?
DYes
DNo
2. Is the monitoring device used to determine the pressure drop certified D Yes D No
by the manufacturer to be accurate to within a gauge pressure of ± 10
percent of the maximum pressure drop measured?
3. Is the monitoring device used for measurement of scrubber liquid
flow rate certified by the manufacturer to be accurate to within ±10
percent of the design scrubber liquid flow rate?
DYes
DNo
4. Is the monitoring device calibrated annually?
DYes
5. Do you monitor the pH of the effluent scrubber liquid at least once a D Yes
day if the scrubber uses a caustic solution to remove acid emissions?
6. Do you average the continuous readings over the operating day or
operating block?
DYes
DNo
DNo
DNo
DNo
7. If flow to the scrubber can be intermittent, did you install a flow
indicator at the inlet or outlet of the scrubber and do you use it to
identify periods of no flow?
DYes
B. Recordkeeping and Reporting Requirements
Comments
1.
Did you submit all of the following in your Notification of
Compliance Status Report:
results of the initial performance test or design evaluation?
§63.1368(f)(2)
DYes
documentation to establish a minimum scrubber liquid flow rate D Yes
or pressure drop as a site-specific operating parameter?
§63.1368(f)(3)
DNo
DNo
2. Do you keep daily (or more frequent) records of the pH of the
scrubber effluent if you use a caustic solution? §63.1367(b)(l)
DYes
DNo
DNo
3. Do you keep continuous records of the scrubber inlet flow rate or
pressure drop? §63.1367(b)(l)
DYes
3-28
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Checklists: (cont'd)
Requirements for scrubbers (All options except 3, 4, 8, and 11)
B. Recordkeeping and Reporting Requirements Comments
4. Do you submit all of the following in your Periodic Reports if
exceedances or excursions are > 1 percent of the total operating time
during the reporting period:
§63.1368(g)(2)
all monitoring data for all operating days or blocks when the D Yes D No
average scrubber inlet flow rate or pressure drop is lower than
the minimum established in your NOCSR or operating permit?
all monitoring data for all operating days or blocks when the D Yes D No
average pH value of the scrubber effluent is lower than the
minimum established in your NOCSR or operating permit?
identification of all operating days when insufficient monitoring D Yes D No
data are collected?
operating logs and operating scenarios for all operating days or D Yes D No
blocks when the scrubber inlet flow rate, inlet pressure drop, or
effluent pH is lower than the minimum established in your
NOCSR or operating permit?
records of the information for CMS required by §63.10(c)(5) D Yes D No
through (13) in subpart A to 40 CFR part 63 (General
Provisions)
5. Do you maintain records for 5 years? §63.1367(a)(l) D Yes D No
a The compliance options are described in the section "What compliance options do I have for my Group 1 process
vents?" and in Table 3-1.
3-29
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Checklist 4: Requirements for condensers (All options except 3, 4, 8, and ll)a
Facility Name:
Facility Location:
Facility TRI ID #:
Inspector:
Date:
Note: A "yes" response to a question in this checklist means compliance with that requirement, and a "no"
response means noncompliance with the requirement. If the requirement is not applicable, indicate "N/A" in the
comments column.
A Monitoring Requirements §63.1366(b)(l)(iii) and (2)
Comments
1. Do you measure the condenser outlet gas temperature at least once
every 15 minutes during the period in which the condenser is
controlling HAP from an emission stream?
DYes
DNo
2. Is the temperature monitoring device accurate to within ± 2 percent
of the temperature measured in degrees Celsius or ± 2.5°C,
whichever is greater?
DYes
DNo
3. Is the temperature monitoring device calibrated annually?
DYes
DYes
DNo
DNo
4. Do you average the temperature readings over the operating day or
operating block?
5. If flow to the condenser can be intermittent, did you install a flow
indicator at the inlet or outlet of the condenser and do you use it to
identify periods of no flow?
B. Recordkeeping and Reporting Requirements
DYes
DNo
Comments
1. Did you submit all of the following in your Notification of
Compliance Status Report:
results of the calculations to demonstrate initial compliance?
§63.1368(f)(2)
documentation to establish the maximum condenser outlet gas
temperature as a site-specific operating parameter?
§63.1368(f) (3)
DYes
DYes
DNo
DNo
2. Do you keep continuous records of the condenser outlet temperature?
§63.1367(b)(l)
DYes
DNo
Do you submit all of the following in your Periodic Reports if
exceedances or excursions are > 1 percent of the total operating time
during the reporting period: §63.1368(g)(2)(ii)
all monitoring data for all operating days or blocks when the
condenser average outlet temperatures that are higher than the
maximum established in your NOCSR or operating permit?
identification of all operating days when insufficient monitoring
data are collected?
DYes
DYes
DNo
DNo
3-30
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Checklist 4: (cont'd)
Requirements for condensers (All options except 3, 4, 8, and 11)
B. Recordkeeping and Reporting Requirements Comments
operating logs and operating scenarios for all operating days or D Yes D No
blocks when the condenser average outlet temperature is higher
than the maximum established in you NOCSR or operating
permit?
records of the information for CMS required by §63.10(c)(5) D Yes D No
through (13) in subpart A to 40 CFR part 63 (General
Provisions)
4. Do you maintain records for 5 years? §63.1367(a)(l) D Yes D No
a The compliance options are described in the section "What compliance options do I have for my Group 1 process
vents?" and in Table 3-1.
3-31
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Checklist 5: Requirements for regenerative carbon adsorbers (All options except 3, 4, 8, and
Facility Name:
Facility Location:
Facility TRI ID #:
Inspector:
Date:
Note: A "yes" response to a question in this checklist means compliance with the requirement, and a "no"
response means noncompliance with the requirement. If the requirement is not applicable, indicate "N/A" in the
comments column.
A. Monitoring Requirements §63.1366(b)(l)(iv) and (2)
Comments
1. For each regenerative cycle, do you monitor all of the following:
operating time since last regeneration?
temperature to which the bed is heated during regeneration?
temperature to which the bed is cooled, measured within 15
minutes of completing the cooling phase?
regeneration stream flow?
DYes
DYes
DYes
DYes
DYes
DNo
DNo
DNo
DNo
DNo
2. Is the temperature monitoring device accurate to within ± 2 percent
of the temperature measured in degrees Celsius or ± 2.5°C,
whichever is greater?
3. Is the regeneration stream flow monitoring device capable of
recording the total regeneration stream flow to within ±10 percent of
the established value (i.e., accurate to within ± 10 percent of the
reading)?
DYes
DNo
4.
5.
B.
1.
Are the temperature and flow monitoring devices calibrated
annually?
Do you conduct an annual check for bed poisoning in accordance
with manufacturer's specifications?
Recordkeeping and Reporting Requirements
Did you submit all of the following in your Notification of
D Yes D No
D Yes D No
Comments
Compliance Status Report:
results of the initial performance test or design evaluation?
§63.1368(f)(2)
documentation to establish the regeneration stream flow, the
minimum carbon bed regeneration temperature, and the
maximum cooling phase temperature as site-specific operating
parameters? §63.1368(f)(3)
DYes
DYes
DNo
DNo
2. Do you keep records of the total regeneration stream mass or
volumetric flow for each carbon bed regeneration cycle?
§63.1367 (b)(l)
D Yes D No
3-32
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Checklists: (cont'd)
Requirements for regenerative carbon adsorbers (All options except 3, 4, 8, and 11)
B. Recordkeeping and Reporting Requirements Comments
3. Do you keep records of the temperature to which the carbon bed is D Yes D No
heated during each carbon bed regeneration? §63. 1367(b)(l)
4. Do you keep records of the temperature to which the carbon bed is D Yes D No
cooled after each carbon bed regeneration? §63. 1367(b)(l)
5. Do you keep records of the operating time between regeneration? D Yes D No
6. Do you identify all of the following in your Periodic Reports if
exceedances or excursions are > 1 percent of the total operating time
during the reporting period: §63. 1368(g)(2)
all regeneration cycles when the total regeneration stream mass D Yes D No
or volumetric flow is lower than the minimum flow
established during your initial compliance demonstration?
all regeneration cycles during which the temperature to which D Yes D No
the carbon bed is heated during regeneration is lower than the
minimum temperature established during your initial compliance
demonstration?
all regeneration cycles during which the temperature to which D Yes D No
the carbon bed is cooled after regeneration is higher than the
maximum temperature established during your initial compliance
demonstration?
• all instances when the operating time between regeneration D Yes D No
exceeds the time interval established during your initial
compliance demonstration?
A .• i f .• A DYes DNo
operating scenarios and operating logs for operating days or
blocks when any of the parameters described above are outside
the limit established during your initial compliance
demonstration?
7. Do you maintain records for 5 years? §63. 1367(a)(l) D Yes D No
a The compliance options are described in the section "What compliance options do I have for my Group 1 process
vents?" and in Table 3-1.
3-33
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Checklist 6: Requirements for nonregenerative carbon adsorbers (All options except 3, 4, 8, and
Facility Name:
Facility Location:
Facility TRI ID #:
Inspector:
Date:
Note: A "yes" response to a question in this checklist means compliance with that requirement, and a "no"
response means noncompliance with the requirement. If the requirement is not applicable, indicate "N/A" in the
comments column.
A. Monitoring Requirements §63.1366(b)(l)(v) and (2)
Comments
1. Do you replace the carbon bed in the nonregenerative carbon
adsorption system with fresh carbon on a regular schedule based on
either of the following:
monitor the outlet TOC concentration that indicates
breakthrough?
time interval established in your NOCS?
DYes
DYes
DNo
DNo
2. If you monitor the TOC concentration, do you take readings daily or
at an interval no greater than 20 percent of the time required to
consume the total carbon working capacity under peak-case
conditions?
B. Recordkeeping and Reporting Requirements
DYes
DNo
Comments
1. Did you submit the results of the initial design evaluation in your
Notification of Compliance Status Report? 63.1368(0 (2)
DYes
DNo
2. Do you identify in your Periodic Reports all instances when the D Yes D No
carbon bed is not replaced within the required time interval based on
either the outlet TOC concentration or the time period established in
your NOCSR or operating permit? §63.1368(g)(2)
3. If you monitor the outlet TOC concentration, do you maintain
records of readings? §63.1367(b)(l)
DYes
DNo
4. Do you maintain records for 5 years? §63.1367(a)(l)
DYes
DNo
a The compliance options are described in the section "What compliance options do I have for my Group 1 process
vents?" and in Table 3-1.
3-34
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Checklist 7: Requirements for thermal incinerators (All options except options 3, 4, 8, and ll)a
Facility Name:
Facility Location:
Facility TRI ID #:
Inspector:
Date:
Note: A "yes" response to a question in this checklist means compliance with that requirement, and a "no"
response means noncompliance with the requirement. If the requirement is not applicable, indicate "N/A" in the
comments column.
A. Monitoring Requirements §63.1366(b)(l)(vii) and (2)
Comments
1. Do you measure the outlet gas temperature at least once every 15
minutes during the period in which the thermal incinerator is
controlling HAP from an emission stream?
D Yes D No
2. Is the temperature monitoring device accurate to within
± 0.75 percent of the temperature measured in degrees Celsius
or ± 2.5°C, whichever is greater?
D Yes D No
3. Is the temperature monitoring device calibrated annually?
DYes
DYes
DNo
DNo
4. Do you average the temperature readings over the operating day or
operating block?
5. If flow to the thermal incinerator can be intermittent, did you install
a flow indicator at the inlet or outlet of the thermal incinerator and
do you use it to identify periods of no flow?
B. Recordkeeping and Reporting Requirements
D Yes D No
Comments
1. Did you submit all of the following in your Notification of
Compliance Status Report:
2.
results of the initial performance test or design evaluation?
§63.1368(f)(2)
documentation to establish the minimum outlet gas temperature
as a site-specific operating parameter? §63. 1368(f)(3)
Do you keep continuous records of the outlet temperature?
§63.1367(b)(l)
DYes
DYes
DYes
DNo
DNo
DNo
3-35
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Checklist?: (cont'd)
Requirements for thermal incinerators (All options except options 3, 4, 8, and 11)
B. Recordkeeping and Reporting Requirements Comments
3. Do you submit all of the following in your Periodic Reports if
exceedances or excursions are > 1 percent of the total operating time
during the reporting period: §63.1368(g)(2)
all monitoring data for all operating days or blocks when the D Yes D No
average outlet temperature is lower than the minimum
temperature specified in your NOCSR or operating permit?
identification of all operating days when insufficient monitoring D Yes D No
data are collected?
operating logs and operating scenarios for all operating days or D Yes D No
blocks when the average operating temperature is lower than
the minimum temperature specified in your NOCSR or
operating permit?
records of the information for CMS required by §63.10(c)(5) D Yes D No
through (13) in appendix A of 40 CFR part 63 (General
Provisions)?
4. Do you maintain records for 5 years? §63.1367(a)(l) D Yes D No
a The compliance options are described in the section "What compliance options do I have for my Group 1 process
vents?" and in Table 3-1.
3-36
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Checklist 8: Requirements for catalytic incinerators (All options except 3, 4, 8, and ll)a
Facility Name:
Facility Location:
Facility TRI ID #:
Inspector:
Date:
Note: A "yes" response to a question in this checklist means compliance with that requirement, and a "no"
response means noncompliance with the requirement. If the requirement is not applicable, indicate "N/A" in the
comments column.
A. Monitoring Requirements §63.1366(b)(l)(viii) and (2)
Comments
1. Do you measure the temperature of the gas stream immediately before
and after the catalyst bed at least once every 15 minutes during the
period in which the catalytic incinerator is controlling HAP form an
emission stream?
D Yes D No
2. Do you calculate the temperature difference across the catalyst bed at
least once every 15 minutes during the period in which the catalytic
incinerator is controlling HAP form an emission stream?
D Yes D No
3. Is the temperature monitoring device accurate to within ± 0.75 percent
of the temperature measured in degrees Celsius or ± 2.5°C, whichever
is greater?
D Yes D No
4. Is the temperature monitoring device calibrated annually?
DYes
DYes
DNo
DNo
5. Do you average the temperature readings over the operating day or
operating block?
6. If flow to the catalytic incinerator can be intermittent, did you install a
flow indicator at the inlet or outlet of the catalytic incinerator and do
you use it to identify periods of no flow?
B. Recordkeeping and Reporting Requirements
D Yes D No
Comments
1. Did you submit all of the following in your Notification of
Compliance Status Report:
results of the initial performance test or design evaluation?
§63.1368(0(2)
documentation to establish the minimum temperature of the gas
stream immediately before the catalyst bed and the minimum
temperature difference across the catalyst bed as site-specific
operating parameters? §63.1368(f) (3)
DYes
DYes
DNo
DNo
2. Do you keep continuous records of the temperature of the gas stream
upstream of the catalyst bed and the temperature difference across the
catalyst bed? §63.1367(b)(l)
D Yes D No
3-37
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Checklists: (cont'd)
Requirements for catalytic incinerators (All options except 3, 4, 8, and 11)
B. Recordkeeping and Reporting Requirements Comments
3. Do you submit all of the following in your Periodic Reports if
exceedances or excursions are > 1 percent of the total operating time
during the reporting period: §63.1368(g)(2)
all monitoring data for all operating days or blocks when the D Yes D No
average upstream temperature is lower than the minimum
temperature specified in your NOCSR or operating permit, or the
average temperature difference across the catalyst bed is lower
than the minimum temperature difference specified in your
NOCSR or operating permit?
• identification of all operating days when insufficient monitoring D Yes D No
data are collected?
operating scenarios and operating logs for all operating days or D Yes D No
blocks when the temperatures do not meet the limits specified in
your NOCSR or operating permit?
the information required by §63.10(c)(5) through (13) in appendix D Yes D No
A of 40 CFR part 63 (General Provisions)
3. Do you maintain records for 5 years? §63.1367(a)(l) D Yes D No
a The compliance options are described in the section "What compliance options do I have for my Group 1 process
vents?" and in Table 3-1.
3-38
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Checklist 9: Requirements for a boiler or process heater (All options, except 3, 4, 8, and ll)a
Facility Name:
Facility Location:
Facility TRI ID #:
Inspector:
Date:
Note: A "yes" response to a question in this checklist means compliance with that requirement, and a "no"
response means noncompliance with the requirement. If the requirement is not applicable, indicate "N/A" in the
comments column.
A. Monitoring Requirements §63.1366(b)(l)(ix) and (2)
Comments
1. Do you monitor the temperature of the gases exiting the combustion
chamber at least every 15 minutes during the period in which the
boiler or process heater is controlling HAP from an emission stream?
D Yes D No
2. Is the temperature monitoring device accurate to within ± 0.75 percent D Yes D No
of the temperature measured in degrees Celsius
or ± 2.5°C, whichever is greater?
3. Is the temperature monitoring device calibrated annually?
D Yes D No
D Yes D No
4. Do you average the temperature readings over the operating day or
operating block?
5. If flow to the boiler or process heater can be intermittent, did you
install a flow indicator at the inlet or outlet of the boiler or process
heater and do you use it to identify periods of no flow?
B. Recordkeeping and Reporting Requirements
D Yes D No
Comments
1. Did you submit all of the following in your Notification of
Compliance Status Report:
results of the initial performance test or design evaluation?
§63.1368(f)(2)
• documentation to establish the minimum combustion zone
temperature? §63.1368(f)(3)
D Yes D No
D Yes D No
D Yes D No
2. Do you have continuous records of the combustion zone temperature?
§63.1367(b)(l)
3-39
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Checklist 9: (cont'd)
Requirements for a boiler or process heater (All options, except 3, 4, 8, and 11)
B. Recordkeeping and Reporting Requirements Comments
3. Do you submit all of the following in your Periodic Reports if
exceedances or excursions are > 1 percent of the total operating time
during the reporting period: §63.1368(g)(2)
all monitoring data for all operating days or blocks when the D Yes D No
average combustion zone temperature is lower than the minimum
temperature specified in your NOCSR or operating permit?
identification of all operating days when insufficient monitoring D Yes D No
data are collected?
operating scenarios and operating logs for all operating days or D Yes D No
blocks when the average combustion zone temperature is lower
than the minimum specified in your NOCSR or operating permit?
records of the information for CMS required by §63.10(c)(5) D Yes D No
through (13) in appendix A of 40 CFR part 63 (General
Provisions)
4. Do you maintain records for 5 years? §63.1367(a)(l) D Yes D No
a The compliance options are described in the section "What compliance options do I have for my Group 1 process
vents?" and in Table 3-1.
3-40
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Checklist 10: Requirements for fabric filters (Option ll)a
Facility Name:
Facility Location:
Facility TRI ID #:
Inspector:
Date:
Note: A "yes" response to a question in this checklist means compliance with that requirement, and a "no"
response means noncompliance with the requirement. If the requirement is not applicable, indicate "N/A" in the
comments column.
A. Monitoring Requirements §63.1366(b)(l)(xi)
Comments
1. Do you have a bag leak detection system that provides output of
relative paniculate matter emissions?
DYes
DYes
DNo
DNo
2. Does the bag leak detector have an alarm system that sounds when it
detects an increase in paniculate matter emissions over the level
established during initial calibration?
3. Is the bag leak detector installed in either of the following locations:
In each fabric filter compartment or cell of a positive pressure D Yes D No
fabric filter?
downstream of a negative pressure or induced air filter? D Yes D No
4. Do you calibrate the bag leak detection system as follows:
Have you established the relative baseline output level (by D Yes D No
adjusting the range and averaging penod of the device)?
Have you established the alarm set points and alarm delay time? D Yes D No
Do you adjust the sensitivity or range, averaging period, alarm set D Yes D No
points, or alarm delay time only as descnbed in your operation
and maintenance plan?
If you ever increase the sensitivity by more than 100 percent or D Yes D No
decrease the sensitivity for more than 50 percent, do you also
conduct a complete baghouse inspection to demonstrate that it is
in good operating condition?
Have you performed other calibration procedures based on D Yes D No
available guidance from EPA or on the manufacturer's written
specifications and instructions?
5. If the alarm on a bag leak detection system is triggered, do you begin
to identify the cause of the alarm and take corrective action as
specified in your corrective action plan within one hour of the alarm?
B. Recordkeeping and Reporting Requirements
D Yes D No
Comments
1. For each time the bag leak detection alarm is activated, do you have the
following records: §63.1367(b)(5)
date and time?
D Yes D No
3-41
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Checklist 10: (cont'd)
Requirements for fabric filters (Option 11)
B.
2.
3.
Recordkeeping and Reporting Requirements
brief explanation of the cause of the alarm?
brief description of corrective action taken?
Do you maintain records for 5 years? §63. 1367(a)(l)
Do you have an operation and maintenance plan that describes proper
operation and maintenance procedures (such as how to adjust the
sensitivity or range, averaging period, alarm set point, and alarm delay
time)? §§63. 1366(b)(l)(xi)(F)and 63. 1367(e)(6)
DYes
DYes
DYes
DYes
Comments
DNo
DNo
DNo
DNo
4. Do you have a corrective action plan that describes corrective actions to D Yes D No
be taken, and the timing of those actions, when the paniculate matter
concentration exceeds the setpoint and activates the alarm?
§§63-1366(b)(l)(xi)(G) and 63.1 367 (e
5. Do you submit bag leak detection records in your Periodic Reports if D Yes D No
exceedances are > 1 percent of the total operating time during the
reporting period: §63. 1368(g)(2)
6. Do you submit updates to your corrective action in your periodic D Yes D No
reports? §63. 1368(g) (2) (viii) _
a Option 1 1 is described in the section "What compliance options do I have for process vents that emit paniculate
matter?" and in Table 3-1.
3-42
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Checklist 11: Requirements for flares (Option 3)a
Facility Name:
Facility Location:
Facility TRI ID #:
Inspector:
Date:
Note: A "yes" response to a question in this checklist means compliance with that requirement, and a "no"
response means noncompliance with the requirement. If the requirement is not applicable, indicate "N/A" in the
comments column.
1. Monitoring Requirements §63.1366(b)(l)(vi) and (2)
Comments
1. Do you monitor for the presence of the flare pilot flame at least once
every 15 minutes?
D Yes D No
2. Is the monitoring device calibrated annually?
B. Recordkeeping and Reporting Requirements
D Yes D No
Comments
1. Did you submit all of the following in your Notification of
Compliance Status Report:
results of the initial visible emissions test? §63.1368(f)(2)
the net heating value of gas being combusted and its exit velocity?
§63.1368(f) (3)
D Yes D No
D Yes D No
2. Do you maintain records of the continuously monitored data?
§63.1367 (b)(l)
D Yes D No
Do you identify all of the following in your Periodic Reports if
exceedances or excursions are > 1 percent of the total operating time
during the reporting period: §63.1368(g)(2)
all periods when the flare pilot flame was absent?
• all periods when the monitor was not working?
D Yes D No
D Yes D No
4. Do you maintain records for 5 years? §63.1367(a)(l)
D Yes D No
a Option 3 is described in the section "What compliance options do I have for my Group 1 process vents?" and in
Table 3-1.
3-43
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Checklist 12: Requirements for alternative standard (Option 4 and 8)a
Facility Name:
Facility Location:
Facility TRI ID #:
Inspector:
Date:
Note: A "yes" response to a question in this checklist means compliance with that requirement, and a "no"
response means noncompliance with the requirement. If the requirement is not applicable, indicate "N/A" in the
comments column.
A. Monitoring Requirements
Comments
1. Have you installed a CEMS to monitor the outlet TOC concentration D Yes D No
and/or outlet HC1 and chlorine concentration at least once every 15
minutes during the period in which the control device is controlling
HAP from an emission stream? §63.1366(b)(5)(i)
2. Does your TOC monitor meet the requirements of Performance D Yes D No
Specification 8 or 9 of appendix B of part 60? §63-1366fi)(5)fi)
3. Is your TOC monitor installed, calibrated, and maintained in D Yes D No
accordance with §63.8 (the General Provisions in subpart A to 40 CFR
part 63)? §63.1365 (b)(5)Q
4. If you introduce supplemental gases to the emission stream before a
noncombustion device, do you perform both of the following:
§§63.1365(a)(7) and63.1366(b)(5)(ii)
adjust the monitored outlet TOC and/or HC1/C12 concentrations to D Yes D No
account for the supplemental gases?
evaluate the volumetric flow rate of all gas streams each time a D Yes D No
new operating scenario is implemented?
5. If you introduce supplemental gases to the emission stream before a D Yes D No
combustion device, do you perform either of the following:
§§63.1365(a) (7) and 63.1366(b)(5)(ii)
adjust the monitored outlet TOC and/or HC1/C12 concentrations to
3 percent oxygen, or
monitor residence time and firebox temperature?
6. Is the CEMS data reduced to operating day averages? §63.1366(b)(2) D Yes D No
and (8)^
7. If flow to the control device can be intermittent, did you install a flow D Yes D No
indicator at the inlet or outlet of the control device, and do you use it
to identify periods of no flow? §63.1366(b)(2)(iii)
B. Recordkeeping and Reporting Requirements Comments
1. Do you have a written quality control program with protocols for D Yes D No
various operations including calibration procedures for the monitor?
§63.8(d)
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Checklist 12: (cont'd)
Requirements for alternative standard (Option 4 and 8)
B. Recordkeeping and Reporting Requirements Comments
2. Have you recorded all maintenance and calibration checks performed D Yes D No
ontheCEMS? §63.1367(b)(3)_
3. Do you have all of the following records: §63.1367(a)(4) and
63.10(c)(l) through (14)
all required CEMS measurements (including monitoring data D Yes D No
recorded during unavoidable CEMS breakdowns and
out-of-control periods)?
• the date and time of each period when the CEMS is inoperative D Yes D No
except for zero (low-level) and high-level checks?
the date and time of each period when the CEMS is out of control D Yes D No
(e.g., calibration drift exceeds specification, CEMS fails cylinder
gas audit)?
the date, start time, and end time of each period of excess emissions D Yes D No
and parameter monitoring exceedances, including those occurring
during startups, shutdowns, and malfunctions?
• the nature and cause of any malfunction of your monitor (if D Yes D No
known), and corrective actions taken?
the nature of any repairs or adjustments to a CEMS that was D Yes D No
inoperative or out of control?
the total process operating time during the reporting period? D Yes D No
all procedures, including calibrations, that are part of your D Yes D No
quality control program?
4. Do you have records indicating that you notified the Administrator at D Yes D No
least 60 days before conducting a performance evaluation of your
CEMS? §63.1368(d) and 63.8(e)(2)
5. Do you submit all of the following in your Periodic Reports if
exceedances or excursions are > 1 percent of the total operating time
during the reporting period: §63.1368(g)(2)
all monitoring data for all operating days or operating blocks when D Yes D No
the average TOC or HC1/C12 concentrations exceed 20 ppmv for
combustion devices or 50 ppmv for noncombustion devices?
identification of all operating days when insufficient monitoring D Yes D No
data are collected?
operating logs and operating scenarios for operating days when the D Yes D No
TOC and/or HC1/C12 concentration exceeded the 20 ppmv or 50
ppmv limit?
the records listed in "3 "required by §63.10(c)(5) through (13) D Yes D No
3-45
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Checklist 12: (cont'd)
Requirements for alternative standard (Option 4 and 8)
B. Recordkeeping and Reporting Requirements Comments
6. If you correct concentrations for supplemental gases from a D Yes D No
noncombustion device, do you reevaluate the flow rates of supplemental
gases and affected gas streams after each operating scenario change,
and include the revised flows and the procedures used to estimate them
in your periodic reports?
7. Do you maintain records for 5 years? §63.1367(a)(l) D Yes D No
a Options 4 and 8 are described in the section "What compliance options do I have my my Group 1 process vents?':
and in Table 3-1.
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Checklist 13: Requirements for any control devices that control vent streams containing total
HAP emissions less than 0.91 Mg/yr (All options except 4 and 8)a
Facility Name:
Facility Location:
Facility TRI ID #:
Inspector:
Date:
Note: A "yes" response to a question in this checklist means compliance with that requirement, and "no"
response means noncompliance with the requirement. If the requirement is not applicable, indicate "N/A" in the
comments column. If your approved monitoring procedures are the same as those specified in the rule for a larger
control device, also fill out the appropriate checklist from among checklists 3 through 11.
A. Monitoring Requirements §63.1366(b)(l)(i) and (2)
1. If the verification procedure includes monitoring a parameter more
than one time per day, do you average the daily readings?
D Yes D No
Comments
1. Do you periodically verify that the control device is operating properly D Yes D No
by following the procedures specified in your approved Precompliance
Plan?
3. Do you calibrate any monitoring instruments according to procedures
in your approved Precompliance Plan?
D Yes D No
4. If flow to the control device can be intermittent, did you install a flow D Yes
indicator at the inlet or outlet of the control device and do you use it to
identify periods of no flow?
B. Recordkeeping and Reporting Requirements
DNo
Comments
1. Did you submit a description of your daily or per batch verification
procedures in your Precompliance Plan? §63.1368(e)
D Yes D No
2. Do you submit all of the following in your Periodic Reports if the
exceedances or excursions are > 1 percent of the total operating time
during the reporting period:
§63.1368(g)(2)
all monitoring data for all operating days or blocks when the data
show the control device is not operating as designed?
identification of all operating days or blocks when insufficient
monitoring data are collected?
D Yes D No
D Yes D No
3. Do you maintain records for 5 years? §63.1367(a)(l)
D Yes D No
a The compliance options are described in the section "What compliance options do I have for my Group 1 process
vents?" and in Table 3-1.
3-47
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Chapter 4 - Complying with requirements for storage vessels
What is a storage vessel?
A storage vessel is a tank or other vessel that is used to store organic liquids that contain one or
more HAP [§63.1361]
What storage vessels are subject to subpart MMM?
Storage vessels that meet all of the following criteria are subject to Subpart MMM:
• meet the definition of a "Group 1" storage vessel [§63.1361]
are determined to be part of a PAI process unit [§63.1360(f)]
• are not exempt under the definition of storage vessel [§63.1361]
What storage vessels are exempt?
Any storage vessels meeting either of the following conditions are not subject to Subpart MMM:
• Group 2 storage vessels
• Vessels that are not part of a PAI process unit
Note: A Group 2 storage vessel is any vessel that does not meet the definition of a Group 1 storage vessel.
In addition, your tank or other vessel is not considered to be a storage vessel (Group 1 or 2) if
any of the following apply [§63.1361]:
• it is permanently attached to a motor vehicle, such as a truck, railcar, barge, or ship
• it is designed to operate with a pressure in excess of 204.9 kilopascals and without
emissions to the atmosphere
• material stored in the vessel contains no organic HAP or contains organic HAP only as
impurities
Definition: Impurity means a substance that is produced coincidentally with the
product(s), or is present in a raw material. An impurity does not serve a useful purpose in
the production or use of the product(s) and is not isolated.
4-1
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• it is a wastewater storage tank
• it is a non-wastewater waste tank
• it is a process tank
What is a "Group 1" storage vessel?
If your storage vessel meets any of the following criteria, it is considered a "Group 1" storage
vessel: [§63.1361]
Your storage vessel is at...
And has a capacity of..
And stores material with a maximum true
vapor pressure of...
an existing source
a new source
>75m3
>40m3
> 75m3
> 3.45 kPa
> 16.5 kPa
> 3.45 kPa
Note: If you do not wish to determine the maximum true vapor pressure of the material in a storage vessel,
then you must designate it as a Group 1 storage vessel [§63.1362(c)(l)J.
How do I know if a storage vessel is part of a PAI process unit?
Your storage vessel is not part of a PAI process unit (and is not part of the affected source) if it
is (was) subject to another MACT standard on June 23, 1999 [§63.1360(f)(l)].
Your storage vessel is part of a PAI process unit if either of the following apply:
• the input to the vessel from the PAI process unit is greater than or equal to the input from
any other PAI or non-PAI process unit
• the output from the vessel to the PAI process unit is greater than or equal to the output to
any other PAI or non-PAI process unit
Note: If the greatest input to (or output from) a shared storage vessel is the same for two or more process units,
including at least one PAI process unit, you may assign the storage vessel to any one of the PAI process units.
[§63.1360(f)(2)]
If the process unit(s) the storage vessel is used with varies from year to year, then you determine
the greatest input or output on either of the following: [§63.1360(f)(4)]
• what you actually used the vessel for during the year preceding June 23, 1999 (for
existing sources) or
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• what you expect to use the vessel for in the 5 years after startup (for new storage vessels
or existing vessels that were not in operation for the year preceding June 23, 1999).
For storage vessels in tank farms, you use the same procedures described above to determine if
the storage vessel is part of a PAI process unit, except your analysis is limited to the process
units for which there is no storage vessel in-between the storage vessel in the tank farm and the
associated processes (i.e., an "intervening" storage vessel). [§63.1360(f)(3)]
As an alternative, even if an intervening storage vessel is present, you may assign the
storage vessel in the tank farm to whichever PAI process send the most material to, or
receives the most material from, the storage tank in the tank farm. [§63.1360(f)(3)(ii)(C)]
You must reevaluate if your storage vessel is part of a PAI process unit after any of the
following occur: [§63.1360(f)(5)]
• the storage vessel begins receiving material from (or sending material to) another process
unit
• the storage vessel ceases to receive material from (or send material to) a PAI process unit
• there is a significant change in the use of the storage vessel
What compliance options do I have for my storage vessels?
For any storage vessel covered under Subpart MMM, you have five compliance options:
Note: Compliance options for storage vessels are the same for new and existing sources.
Option 1: Use a fixed roof tank with an internal floating roof (IFR)
[§63.1362(c)(2)(i)]
Equip the storage vessel with a fixed roof and internal floating roof
Option 2: Install an external floating roof (EFR) [§63 1362(c)(2)(ii)]
Equip the storage vessel with an external floating roof
Option 3: Convert your external floating roof to an internal floating roof
[§63.1362(c)(2)(iii)]
Equip the storage vessel with an external floating roof converted to an internal floating roof
(i.e., install a fixed roof above an external floating roof)
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Option 4: Vapor balance to a tank truck or railcar [§63 1362(c)(6)]:
Use a vapor balancing system that is designed and operated to route organic HAP vapors
displaced from loading of the storage vessel to the railcar or tank truck from which the
storage vessel is filled. No pressure relief device on the storage vessel, or on the railcar or
tank truck, may open during loading or as a result of daily temperature changes.
Note that railcars and tank trucks that deliver HAP to your storage tank must be reloaded and cleaned at a
facility that either vents emissions from the railcar or tank truck to a control device or vapor balances to the
storage tank that contains the liquid that is transferred to the railcar or tank truck.
Option 5: Use a control device that meets any of the following conditions
[§63.1362(c)(2)(iv)]:
(A) Percent reduction [§63.1362(c)(2)(iv)(A)]
Equip the storage vessel with a closed vent system and a control device that reduces
organic HAP emissions by >95 percent (by weight)
(B) Reduce outlet concentration to ^20 ppmv [§63 1362(c)(2)(iv)(B)]
Equip the storage vessel with a closed vent system and a control device that reduces
organic HAP emissions to outlet concentrations of <20 ppmv
(C) A flare [§63.1362(c)(2)(iv)(C)]
Equip the storage vessel with a flare that meets the requirements of §63.1 l(b) (see the
Subpart A General Provisions)
(D) Use one of the following as a control device:
• A boiler or process heater with a design heat input
of 44 megawatts or greater
• A boiler or process heater into which the emission
stream is introduced with the primary fuel
• An incinerator, boiler, or process heater that is
permitted under RCRA
These control devices are exempt
from initial compliance
demonstrations and monitoring
requirements.
[§63.1362(1) and
§63.1365(a)(4)(i)(ii)}
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(E) Use the alternative standard [§63 1362(c)(4)]
Use the alternative standard under §63.1362(c)(4), and route emissions from storage
vessels to a control device or series of control devices that achieve all of the following
outlet concentrations:
<20 ppmv TOC (as calibrated on methane or the predominant HAP)
• <20 ppmv total HC1 and C12
Note: The outlet concentration limits are the same for options SB and 5E, but the alternative standard
requires monitoring with CEMS, whereas Option 5B requires an initial performance test (or design
evaluation) and monitoring of control device operating parameters.
For option 5, you are exempt from specification requirements during periods of planned routine maintenance
of the control device that do not exceed 240 hr/yr [§63.1362(c)(5)].
How do I show initial compliance with the storage vessel
requirements?
Subpart MMM contains different initial compliance requirements based on the compliance
options you choose.
Options 1, 2 or 3: Compliance using internal or external floating roofs
You demonstrate initial compliance when you use a floating roof by determining if you are in
compliance with all of the following:
• floating roof design features
• operating requirements
• inspection and measurement requirements (measurements are only for option 2)
Initial compliance and monitoring requirements for storage vessels equipped with a floating roof
are specified in §63.119 and §63.120 of Subpart G of the HON as referenced from §63.1365(d)
and §63.1366. However, Subpart MMM designates different definitions and compliance dates as
follows: [§63.1365(d)(3)]
• the definition in §63.1361 applies when the term "storage vessel" is used in §§63.119 and
63.120.
• November 10, 1997 applies instead of December 31, 1992.
• June 23, 1999 applies instead of April 22, 1994.
• the compliance date specified in §63.1364 of Subpart MMM applies instead of the
compliance date in §63.100 of Subpart F.
4-5
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the "maximum true vapor pressure of the total organic HAP in the stored liquid" is based
on the Group 1 characteristics defined in §63.1361 rather than the criteria specified in
Tables 5 and 6 of Subpart G.
See Table 4-1 (page 4-7) for your floating roof design and operating requirements. You may be
subject to one or more of the requirements listed depending on the compliance options you
choose. Initial inspections and measurements are discussed in the section "What monitoring
must I do?" later in this chapter.
Option 4: Vapor balancing
If you use the vapor balancing option to comply with Subpart MMM, you demonstrate initial
compliance by installing a pressure relief device on the storage vessel that is set to no less than
2.5psig. [§63.1362(c)(6)(v)]
Note that offsite cleaning and reloading facilities must provide you with written certification that they will meet all
of the requirements of Subpart MMM. [§63.1362(c)(6)(vii)(A)]
Option 5: Compliance using a control device
(A) Percent reduction
If you use the percent reduction option to comply with Subpart MMM, you must demonstrate
initial compliance by determining the efficiency of the control device based on either of the
following:
• performance test data [§63.1365(d)(l)(i)] Sections 63 1365(b)(1) through (11) specijy
• design evaluation [§63.1365(d)(l)(ii)] test methods and procedures.
Performance test procedures
If you send emissions from both a storage vessel and process vents to the same control device,
you may demonstrate initial compliance for the storage vessel using the results of the test you
conducted to show compliance with the process vent standards, provided that the test showed a
percent reduction >95 percent [§63.1365(d)(l)(i)(C)]. See "How do I show initial compliance
with the process vent requirements?" beginning on page 3-8 for more information.
If you elect to conduct a test specifically for the emissions from the storage vessel, the test must
be conducted at the reasonably expected maximum filling rate [§63.1365(d)(l)(i)(A)].
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If you are
complying with... Then your...
TABLE 4-1. Design and Operating Requirements for Storage Vessels Equipped with a Floating Roof3
Must... And also must...
Option 1,2, or 3 floating roof be floating on the liquid surface except under
the following conditions when being
(Please note that supported by the leg supports is allowed:
you have more • during initial fill
requirements for • after the vessel has been completely
these options emptied and degassed
further in this • before refilling
table)
automatic bleeder vents have gaskets be closed at all times except when the roof is
being floated off or landed on the leg supports
rim space vents have gaskets be set to open only in the folio wing conditions:
• when the roof is being floated off the roof
leg supports
• when the pressure beneath the rim seal
^j exceeds manufacturer's specifications
openings in non-contact IFRs or EFRs project below the liquid surface
(except for automatic bleeder vents
and rim space vents)
access hatches and gauge floats have a gasketed cover be closed at all times except for access
Option 1 openings in the IFR (except for leg have a cover or lid with a gasket be closed at all times except for access
sleeves, automatic bleeder vents, rim
space vents, column wells, ladder
wells, sample wells, and stub drains)
sample wells have a slit fabric cover over at least
90 percent of the opening
ladder wells have a gasketed sliding cover
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TABLE 4-1. (cont'd)
If you are
complying with.
Then your...
Must...
And also must...
penetrations in the IFR for fixed roof
columns
have either of the following:
• a flexible fabric sleeve seal
• a gasketed sliding cover
Option 2
closure device between the vessel
wall and roof edge
be any one of the following:
• a liquid-mounted or metallic shoe
primary seal with no secondary seal"
• a vapor-mounted primary seal and a
secondary seal"
• a liquid-mounted or metallic shoe
primary seal and a secondary seal
completely cover the space between the EFR
and the vessel wall
f' Option 1 or 3
oo
closure device between the vessel
wall and the roof edge
be any one of the following:
• a vapor-mounted seal"
• a liquid-mounted seal
• a metallic shoe seal
• a double seal
completely cover the space between the IFR
and the vessel wall
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TABLE 4-1. (cont'd)
If you are
comply ing with...
Then your...
Must...
And also must...
Option 2 or 3 openings in the roof except for the
following:
• automatic bleeder vents
• rim space vents
• roof drains
• leg sleeves
be equipped with a gasketed cover or lid
both of the following:
• keep the cover or lid closed except for
access
• cover on each access hatch and each gauge
float well must be bolted or fastened to be
air tight when closed
roof drains that empty into the stored
liquid
have a slotted membrane fabric cover over at
least 90 percent of the drain opening area
guide pole wells
unslotted guide poles
slotted guide poles
have either of the following:
• a gasketed sliding cover
• a flexible fabric sleeve seal
have a gasketed cap on the end of the pole
be kept closed except when gauging the liquid
level or taking liquid samples
have a gasketed float or other device to close
off the liquid surface from the atmosphere
IFR = internal floating roof EFR = external floating roof
a Rule references for the information in Table 4-1 are: §63.119(b) for option 1, §63.119(c) for option 2, and §63.119(d)foroption3.
" This type of sealing mechanism is allowed only until the first time the storage vessel is emptied and degassed or June 23, 2009, whichever is earlier.
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Design evaluation procedures
If you choose to demonstrate initial compliance by conducting a design evaluation, you must
document how you demonstrate that your control device achieves the required control efficiency
when the storage vessel is filled at the reasonably expected maximum filling rate. The
parameters to consider in design evaluations for different types of control devices are described
in§63.1365(a)(l).
(B) Outlet concentration
If you are complying with Subpart MMM using the Sections 63.1365(b)(l) through (11) specify
outlet concentration option, you demonstrate initial test methods ^procedures.
compliance by conducting a performance test to show
the outlet TOC or total organic HAP concentration is
<20 ppmv [§63.1365(a)(6) and (d)(2)].
(C) Flare
When a flare is the control device, you demonstrate initial compliance by doing all of the
following:
• determining visible emissions using EPA Method 22 of 40 CFR part 60, Appendix A, for
a 2-hour observation period [§63.1365(a)(3) and (d)(4)]. Flares must produce no visible
emissions, except for a period of 5 minutes during any 2 consecutive hours [§63.1 l(b)(4)
of subpart A]
determining under absolute or hypothetical peak-case conditions, the net heating value of
gas being combusted and its exit velocity as specified in §63.1 l(b)(6) through (8) of the
General Provisions [§63.1365(a)(3) and (d)(4)]
(E) The alternative standard
When using the alternative standard in §63.1362(c)(4), your outlet TOC concentration must be
<20 ppmv, and the outlet HC1 and C12 concentration must be <20 ppmv.
You demonstrate initial compliance with these values by having the monitoring equipment
operational on the compliance date (see the discussion of monitoring requirements for option 5C
in the section "What monitoring must I do for my storage vessels?" later in this chapter, [page
4-16]). In addition, if you intend to calibrate the monitor using the predominant HAP, you will
have to use EPA Method 18 to determine the predominant HAP [§63.1365(a)(5) and (d)(6)].
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How do I comply when my control device needs repairs [options 5 (A,
B, C, and E)]?
Your storage vessel is exempt from Subpart MMM during periods of routine maintenance on the
storage vessel control device, provided that the routine maintenance does not exceed 240 hr/yr
(unless you get an extension) [§§63.1362(c)(5) and 63.1365(d)(7)].
You demonstrate initial compliance with the provisions by including anticipated periods of
planned routine maintenance for the first reporting period in the Notification of Compliance
Status report as discussed in "What do I have to report and when?" in Chapter 8 (page 8-1).
What monitoring must I do for my storage vessels?
Your monitoring requirements depend on the compliance option you select. A summary of the
monitoring requirements for each compliance option follows:
If you are complying
using...
Then your monitoring requirements
include ...
You must monitor at this frequency..
Option 1,2 or 3
various inspections and measurements
typically annually and every time the
storage vessel is emptied and
degassed
Option 5 (A or B)
monitor one or more control device
operating parameters such as temperature
and flow rate
every 15 minutes
Option 5 (C)
Option 5 (E)
monitor presence of pilot flame
every 15 minutes
every 15 minutes
monitor outlet TOC and, if appropriate,
HC1/C12 concentrations
Additional details for each option are provided below.
Options 1 or 3: Monitoring for internal floating roofs (IFRs)
If you comply with option 1 or 3, your monitoring requirements are as follows [§63.120(a) as
cross-referenced from §63.1365(d)(3)]:
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IfyourlFR
has a ...
Double-seal
system
(Option A)
Double-seal
system
(Option B)
Then visually
inspect the ...
IFR, the primary
and secondary seal,
gaskets, slotted
membranes, and
sleeve seals, if any
(i.e., an "internal
inspection")
secondary seal
through manholes
and roof hatches
on the fixed roof
(i.e., an "external"
inspection)
For the following
failures ...
• defects in the IFR
• holes, tears, or other
openings in the seal
or seal fabric
• gaskets that no
longer close off the
liquid surface to the
atmosphere
• slotted membranes
with more than
10 percent open area
• IFRs that are not
resting on the
surface of the liquid
or the leg supports
• liquid on the IFR
• detached seal
At this frequency...
each time the vessel
is emptied and
degassed,
and at least once
every 5 years after
the compliance date
at least once every 12
months after either
the initial fill date or
the compliance date,
whichever is later
According to these
sections of the rule...
§63.120(a)(3)(i)and
(a)(7)
§63.120(a)(3)(ii)and
(a)(4)
IFR, the primary
and secondary seal,
gaskets, slotted
membranes, and
sleeve seals, if any
(i.e., an "internal"
inspection)
holes or tears in the
seal fabric
visible gaps between
the seal and the wall
of the storage vessel
defects in the IFR
holes, tears, or other
openings in the seal
or seal fabric
gaskets that no
longer close off the
liquid surface to the
atmosphere
slotted membranes
with more than
10 percent open area
each time the vessel
is emptied and
degassed, and at least
once every 10 years
after the compliance
date
§63.120(a)(3)(iii)and
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IfyourlFR
has a...
Then visually
inspect the ...
For the following
failures...
At this frequency...
According to these
sections of the rule..
Single-seal
system
IFR and the seal
through manholes
and roof hatches
on the fixed roof
(i.e., an "external"
inspection)
IFR, the seal,
gaskets, slotted
membranes, and
sleeve seals, if any
(i.e., an "internal"
inspection)
IFRs that are not
resting on the
surface of the liquid
or the leg supports
liquid on the IFR
detached seal
holes or tears in the
seal fabric
visible gaps between
the seal and the wall
of the storage vessel
defects in the IFR
holes, tears, or other
openings in the seal
or seal fabric
gaskets that no
longer close off the
liquid surface to the
atmosphere
slotted membranes
with more than
10 percent open area
at least once every 12
months after initial
fill, or at least once
every 12 months
after compliance date
§63.120(a)(2)(i)and
each time the storage
vessel is emptied and
degassed, and at least
once every 10 years
after the compliance
date
§63.120(a)(2)(ii)and
Note: Subpart MMM designates some different definitions and compliance dates than are used in §63.120 of
subpart G. These differences are noted in "How do I show initial compliance with the storage vessel
requirements " earlier in this chapter.
Defects and other failures found during annual inspections must be repaired within 45 days after performing the
inspection (unless you get an extension) [§63.120(a)(4)J. Defects and other failures found in the inspection after
emptying and degassing the storage vessel must be repaired before refilling the storage vessel with organic HAP
[§63.120(a)(7)].
Option 2: Monitoring for external floating roofs (EFRs)
If you comply with option 2, your monitoring requirements are as follows [§63.120(b) as cross-
referenced from §63.1365(d)(3)]:
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For EFRs with the
following features..
Monitor the following..
At this frequency
According to this section
of the rule...
All EFRs
visually inspect the roof,
seals, and fittings
each time the vessel is
emptied and degassed
§63.120(b)(10)
EFR with primary and
secondary seals
measure" gap between vessel during the hydrostatic §63.120(b)(l)(i)
wall and primary seal
testing of the vessel or
by the compliance date,
whichever occurs last,
and at least every 5
years thereafter
inspect integrity of primary
seal and if using a metallic
shoe seal, measure the
distance the metallic shoe
extends above the liquid
surface
during the hydrostatic
testing of the vessel or
by the compliance date,
whichever occurs last,
and at least every 5
years thereafter
§63.120(b)(5)
measure" gap between vessel
wall and secondary seal
annually
inspect integrity of secondary
seal and inspect for proper fit
annually
annually
§63.120(b)(6)
§63.120(b)(l)(ii)
EFR with liquid-
mounted or metallic
shoe primary seal and
no secondary sealc
measure" gap between vessel
wall and primary seal
inspect integrity of primary annually
seal
§63.120(b)(5)(ii)
if a metallic shoe seal is
used, measure vertical
distance that one end of the
metallic shoe extends above
the liquid surface
annually
§63.120(b)(5)(i)
a All measurements and inspections that must be performed annually must also be performed before the
compliance date.
" Make seal gap measurements according to the method described in §63.120(b)(2) through (b)(4) of subpart G.
c When secondary seal is added, both the primary and secondary seals must be measured within 90 days and at
the frequency specified for EFRs with primary and secondary seals [§63.120(b)(l)(iv)]. A secondary seal must
be added when the vessel is emptied and degassed, or by June 23, 2009 at the latest. [§63.119(c)(l)(iv)]
Note: Subpart MMM designates some different definitions and compliance dates than those used in §63.120 of
subpart G. These differences are noted in "How do I show initial compliance with the storage vessel
requirements " earlier in this chapter.
If you think performing seal gap measurements and inspection of a vessel may be unsafe, then you may get an
extension to perform the measurements and inspection or empty and remove the storage vessel from service
[§63.120(b)(7)].
4-14
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Subpart MMM also requires that you repair defects and other failures identified during
inspections if you are using option 2. The types of conditions that you must repair and the time
allowed for the repairs are as follows:
When you are performing ...
And you find that...
Then, repair the condition...
visual inspection of the roof,
seals, and fittings after
emptying and degassing the
storage vessel
the external floating roof has defects
the primary or secondary seal has holes,
tears, or other openings in the seal or
seal fabric
gaskets no longer close off the liquid
surface from the atmosphere
the slotted membrane has more than
10 percent open area
before refilling the storage
vessel with organic HAP
[§63.120(b)(10)(i)]
seal gap measurement and
visual inspection for all
primary seals
the total area of gaps between the vessel
wall and primary seal exceeds
212 cmVmeter of vessel diameter
there are gaps between the vessel wall
and primary seal wider than 3.81 cm
there are holes in the mechanical shoe
(if used), seal fabric, or seal envelope
within 45 days from the
measurement or inspection
(unless you get an extension)
[§63.120(b)(8)]
additional measurement for
metallic shoe primary seals
the metallic shoe seal does not have one
end in the stored liquid and the other end
extending at least 61 cm above the stored
liquid surface
within 45 days from the
measurement or inspection
(unless you get an extension)
[§63.120(b)(8)]
seal gap measurement and
visual inspection for all
secondary seals
the total area of gaps between the vessel
wall and secondary seal exceeds
21.2 cmVmeter of vessel diameter
there are gaps between the vessel wall
and secondary seal wider than 1.27 cm
the secondary seal does not completely
cover the space between the roof edge
and the space between the vessel wall
there are holes, tears, or other openings
in the secondary seal or seal fabric
within 45 days from the
measurement or inspection
(unless you get an extension)
[§63.120(b)(8)]
Option 4: Vapor Balancing
If you comply with option 4, you must monitor quarterly (using Method 21) the pressure relief
valve on the storage vessel. If you obtain a reading of 500 ppmv or greater, you have a leak.
You must repair leaks within 5 days after the leak is detected. [§63.1362(c)(6)(iv)]
4-15
-------
Option 5: Control Devices
(A&B) Monitoring for percent reduction or outlet concentration
The monitoring requirements for your storage vessel percent reduction and outlet concentration
options are the same as the monitoring requirements for the process vent percent reduction and
outlet concentration options and vary depending on the control device that you use. Table 3-2 in
Chapter 3 summarizes the monitoring requirements for the percent reduction and outlet
concentration options for various control devices [§63.1366(b)(l)].
(C) Monitoring for flares
If you control storage vessel emissions with a flare, you must monitor the presence of the flame.
Monitoring must be conducted at least once every 15 minutes. You must calibrate the
monitoring device used to detect the presence of the pilot flame annually [§63.1366(b)(l)(vi)].
(E) Monitoring for the alternative standard
If you choose to comply with the alternative standard, your monitoring requirements include all
of the following:
monitor the outlet TOC and HC1/C12 concentration at least once every 15 minutes
Note: You do not have to monitor the total HCl and C12 concentrations if you know that the emission stream
does not contain HCI/C12 emissions [§63.1366(b)(5)J.
adjust the monitored concentrations per §63.1365(a)(7) to account for supplemental
gases, if any
Note: As an alternative to adjusting monitored concentrations to account for supplemental gases when
using a combustion device, you may monitor residence time and firebox temperature.
use a TOC monitor that meets the requirements of Performance Specification 8 or 9 of
appendix B of 40 CFR part 60
install, calibrate, maintain, and operate the monitors in accordance with §63.8 of the
General Provisions
(D) Monitoring for boilers or process heaters
You are not required to do any monitoring if you route storage vessel emissions through a
process heater or boiler that meets the criteria for compliance option 5 (D) (see page 4-4).
Note: If your process heater or boiler has a design heat input of<44 MW, or the vent streams are not
introduced with the primary fuel, you must comply with option 5A, 5B, or 5E.
4-16
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What records must I keep for my storage vessels?
Recordkeeping requirements are presented in Chapter 8.
What reports must I submit for my storage vessels?
General reporting requirements are presented in Chapter 8. Requirements specific to storage
vessels are shown in this section.
Depending on the compliance option you choose, the following notifications may be required:
If you are
complying with...
And you do the following ...
You must notify the
Administrator...
According to this section
of subpart G...
Option 1, 2 or 3
Option 2
refill your storage vessels after
visual inspection of the roof, seals,
and fittings each time the vessel is
emptied and degassed
perform seal gap measurements
30 daysa before
refilling your vessel
30 days before
performing the
measurements
§§63.120(a)(5)and
(b)(10)(ii)
§63.120(b)(9)
a If the inspection prior to refilling is unplanned, the notification may be made at least 7 days before refilling.
For Options 1, 2, and 3 you must report the following in your periodic reports:
If you are
complying with...
Then for...
Include the following information .
According to this
section of the rule .
Option 1 or 3
annual "external"
inspections during
which you detect any
failures of the control
equipment
"internal" inspections
during which you
detect any failures
date of inspection
identification of storage vessel
description of failure
date of and description of repair
date storage vessel was emptied, if
applicable
§63.122(d)(l)
date of inspection
identification of storage vessel
description of the failure
date of and description of repair
§63.122(d)(2)
4-17
-------
If you are
complying with.
Then for...
Include the following information .
According to this
section of the rule .
Option 2
seal gaps that exceed
allowed limits and/or
any defects or other
seal failures that you
detect during
inspections conducted
concurrently with the
seal gap measurement
date of seal gap measurement
raw data obtained in the
measurement
calculation of total seal gap area
description of any failures
date of and description of repair (or
date storage vessel was emptied)
§63.122(e)(l)
visual inspections of
empty and degassed
storage vessels during
which you detect any
defects or failures
date of inspection
identification of storage vessel
description of the failure
date of and description of repair
§63.122(e)(3)
For Option 4, you have no reporting requirements. However, the offsite reloading and cleaning
facility must provide both you and EPA a written certification that they will comply with the
requirements of Subpart MMM. If they comply by venting emissions from the railcar or tank
truck to a control device, then they must comply with all of the applicable reporting requirements
in §63.1368 of Subpart MMM. If they vapor balance, no reporting is required.
For Options 5 (A, B, C and E), you must also report the following:
When submitting your... Include information on the ...
According to the following
section of the rule...
Notification of Compliance
Status report
anticipated periods of planned routine
maintenance
§63.1368(f)(7)
Periodic reports
actual periods of planned routine maintenance
during the reporting period
and
anticipated periods of planned routine
maintenance for the next reporting period
§63.1368(g)(2)(v)
4-18
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Checklists for Inspection of Storage Vessels
Facility Name:
Facility Location:
Facility TRI ID #:
Inspector:
Date:
There are seven checklists for storage vessels. The table below explains which inspection
checklists you should use for storage vessels.
If you follow ...
Option 1
Option 2
Option 3
Option 4
Option 5(A or B)
For a storage vessel with...
a fixed roof and an internal floating roof
an external floating roof
an external floating roof converted to an
internal floating roof
vapor balancing
a closed-vent system and control device
that reduces emissions > 95% by weight
or reduces outlet concentrations <20
ppmv
Then use the
following
checklists3 ...
2
3
4
5
6
(also use checklists
2 through 9, as
applicable, in
Chapter 3)
Starting on
page ...
4-21
4-25
4-32
4-37
4-39
Option 5(C)
a flare
(and checklists 2
and 10 in Chapter 3)
4-39
Option 5(E) emissions routed to a control device to
meet the alternative standard
4-40
a Checklist 1 applies for all options.
4-19
-------
Checklist 1: Applicability (All Options)
Facility Name:
Facility Location:
Facility TRI ID #:
Inspector:
Date:
Note: Use this checklist to determine if your tanks or vessels are storage vessels, if your storage vessels are part
of the affected source, and if storage vessels are subject to control requirements.
Comments
1. Does your tank or vessel meet the definition of a storage D Yes D No
vessel? §63.1361
Note: If you answer "yes" to this question, proceed to
question 2. If you answer "no, " do not continue; your vessel
is not a storage vessel.
1. Is your storage vessel part of a PAI process unit? §63.1360(f) D Yes D No
Note: If you answer "yes" to this question, proceed to
question 3. If you answer "no, " do not continue; your
storage vessel is not part of the affected source.
3. Is your storage vessel a Group 1 storage vessel based on any
one of the following: §63.1362(c) (1)
you designated the storage vessel as Group 1? D Yes D No
the storage vessel has a capacity > 75 m3 and stores D Yes D No
material with a maximum true vapor pressure > 3.45 kPa?
the storage vessel is at a new affected source, has a D Yes D No
capacity >40 m3, and stores material with a maximum
true vapor pressure > 16.5 kPa?
Note: If you answer "yes" to any of the items in this question,
your storage tank is subject to control requirements; proceed
to the applicable checklist for the compliance option you
choose. If you answer "no " to all of the items in this
question, do not proceed; you are exempt from control
requirements.
4-20
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Checklist 2: Requirements for a storage vessel with an internal floating roof (Option 1)
Facility Name:
Facility Location:
Facility TRI ID #:
Inspector:
Date:
Note: A "yes" response to a question in this checklist means compliance with that requirement, and a "no"
response means noncompliance with the requirement. If the requirement is not applicable, indicate "N/A" in the
comments column.
A. Monitoring and Inspection Requirements §§63.119(b) and 63.120(a) as cross-
referenced from §63.1365(d)(3) Comments
Note: The monitoring requirements include visual inspections. Questions 3-5 apply for all visual inspections.
Questions 6-15 apply only for visual inspections performed each time the vessel is emptied and
degassed (i.e., "internal" visual inspections).
1. If the storage vessel is equipped with a single-seal system, do
both of the following apply: §63.120(a)(2)
• Do you perform an "external" visual inspection of the IFR D Yes D No
and seal at least once every 12 months?
• Do you perform an "internal" visual inspection of the IFR, D Yes D No
the seal, gaskets, slotted membranes, and sleeve seals (if
any) each time the storage vessel is emptied and degassed,
and at least once every 10 years?
2. If the storage vessel is equipped with a double-seal system, do D Yes D No
either of the following apply: §63.120(a) (3)
• Do you perform an "internal" visual inspection of the IFR,
the primary seal, the secondary seal, gaskets, slotted
membranes, and sleeve seals (if any) each time the storage
vessel is emptied and degassed, and at least once every
5 years, or
• Do you perform an "external" visual inspection of the IFR
and the secondary seal at least once every 12 months, and
do you perform an "internal" visual inspection of the IFR,
the primary seal, the secondary seal, gaskets, slotted
membranes, and sleeve seals (if any) each time the vessel is
emptied and degassed, and at least once every 10 years?
3. Does the floating roof float on the liquid surface? D Yes D No
§§63.119(b)(l) and (2) and63.120(a)(4)
Note: The roof is not required to be floating on the liquid
surface during initial filling, after the vessel has been
completely emptied and degassed, and when completely
emptied before being refilled. When the roof is resting on the
leg supports, the process of filling, emptying, or refilling must
be continuous and completed as soon as possible.
4-21
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Checklist!: (cont'd)
Requirements for a storage vessel with an internal floating roof (Option 1)
A. Monitoring and Inspection Requirements §§63.119(b) and 63.120(a) as cross-
referenced from §63.1365(d)(3) Comments
4. Is the IFR in good condition (i.e., free of defects such as D Yes D No
corrosion or pools of standing liquid)? §63.120(a)(4) and (7)
5. Inspect the seal(s). §63.120(a)(4) and (7)
• Is the seal attached to the IFR? D Yes D No
• Is the seal or seal fabric free of holes, tears, or other D Yes D No
openings?
• Does the seal make continuous contact with the wall of the D Yes D No
storage vessel (i.e., no visible gaps between the seal and
wall)?
6. Is the IFR equipped with a liquid-mounted seal, metallic shoe D Yes D No
seal, or a double seala? §63.119(b)(3)^
7. Inspect deck openings
• If the IFR is non-contact, do the openings in the IFR project D Yes D No
below the stored liquid surface (except automatic bleeder
and rim space vents)b? §63.119(b)(5)(i)
• Is each opening in the IFR equipped with a gasketed cover D Yes D No
(except leg sleeves, automatic bleeder vents, rim space
vents, column wells, ladder wells, sample wells, and stub
drains)b? §63.119(b)(5)(ii)
• Is each cover on an IFR opening closed (unless open for D Yes D No
access)? §63.119(b)(6)
• Are covers on each access hatch and automatic gauge float D Yes D No
fastened air-tight when closed? §63.119(b) (6)
• Do gaskets on IFR opening covers close off the liquid D Yes D No
surface from the atmosphere? §63.120(a)(7)
8. Inspect automatic bleeder vents
• Are the automatic bleeder vents closed (unless the roof is D Yes D No
being floated off or landed on the roof leg supports)?
§63.119(b)(4)
• Are the automatic bleeder vents gasketed?" D Yes D No
§63.119(b)(5)(iv)
• Do the gaskets close off the liquid surface from the D Yes D No
atmosphere? §63.120(a)(7)
4-22
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Checklist!: (cont'd)
Requirements for a storage vessel with an internal floating roof (Option 1)
A. Monitoring and Inspection Requirements §§63.119(b) and 63.120(a) as cross-
referenced from §63.1365(d)(3)
Comments
9. Inspect rim space vents
• Are the rim space vents closed (except when either the roof D Yes D No
is being floated off the roof leg supports, or the pressure
beneath the rim seal exceeds the manufacturer's
recommended setting)? §63.119(a)(6)
• Are the rim space vents gasketed? §63.119(b)(5)(v) D Yes D No
• Do the gaskets close off the liquid surface from the D Yes D No
atmosphere? §63.120(a)(Q
10. Does each sample well have a slit fabric cover over at least D Yes D No
90 percent of the opening?b §63.119(b)(5)(iii) and
§^3JJO(a)(7)_
11. Does each ladder well have a gasketed sliding cover?" D Yes D No
§63-119(b)(5)(vO
12. Does each column well supporting the fixed roof have either a D Yes D No
flexible fabric sleeve seal or gasketed sliding cover?"
§63-119(b)(5)(vii)^
13. Do ladder and column well gaskets close off the liquid surface D Yes D No
to the atmosphere? §63.120(a) (7)
14. If flexible fabric sleeve seals are used for column wells, are the D Yes D No
fabric sleeves free of defects such as holes, tears, or gaps?
§63.J_20(a)(7)_
15. If repairs were needed, did you complete them before refilling D Yes D No
the storage vessel? §63.120(a)(7)
B. Recordkeeping and Reporting Requirements §§ 63.122 and 63.123 as cross
referenced by §§ 63.1367(b)(ll) and 63.1368(g)(2)(xii) Comments
Note: There are reporting and recordkeeping requirements for visual inspections.
1. Did you record the occurrence of each visual inspection? D Yes D No
§63.123(c)
1. Do you maintain all records for 5 years? §63.1367(a) (1) D Yes D No
3. If you detect a failure during an inspection, do you submit all
of the following information in your periodic report:
§63.122(d)(l)(ii)and(2)(ii)
• date of the inspection? D Yes D No
• identification of all storage vessels with failures? D Yes D No
4-23
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Checklist!: (cont'd)
Requirements for a storage vessel with an internal floating roof (Option 1)
B. Recordkeeping and Reporting Requirements §§ 63.122 and 63.123 as cross
referenced by §§63.1367(b)(ll) and 63.1368(g)(2)(xii) Comments
• description of the failures? D Yes D No
• either the date and nature of repairs made or the date the D Yes D No
vessel was emptied (if the vessel was not already empty)?
4. If your periodic report in "3" shows that you made a repair
more than 45 days after the failure was found, does your next
periodic report include documentation of the use of up to two
30-day extensions and the following information:
§§63.120(a)(4) and63.122(d)(l)(iii)
• identification of the storage vessel? D Yes D No
• description of the failure? D Yes D No
• documentation that alternate storage capacity was D Yes D No
unavailable?
• schedule of actions taken to make repairs or empty the D Yes D No
vessel as soon as possible?
• date the storage vessel was emptied and nature of and date D Yes D No
repair was made?
5. If you refilled a storage vessel after it was emptied and D Yes D No
degassed, did you submit a report notifying the Administrator
at least 30 days before the vessel was refilled (7 days if the
inspection was unplanned and could not be foreseen 30 days
before refilling)? §63.120(a)(5) and (6)
a If the internal floating roof is equipped, as of November 10, 1997, with a single vapor-mounted seal, then the
requirement for a liquid-mounted seal, metallic shoe seal, or dual-seal does not apply until the earlier of the
following dates: (1) the next time the storage vessel is emptied and degassed, or (2) June 23, 2009.
" If the IFR did not meet these specifications as of November 10, 1997, the requirement to meet these specifications
does not apply until the earlier of the following dates: (1) the next time the storage vessel is emptied and degassed,
or (2) no later than June 23, 2009.
4-24
-------
Checklist 3: Requirements for a storage vessel with an external floating roof (Option 2)
Facility Name:
Facility Location:
Facility TRI ID #:
Inspector:
Date:
Note: A "yes" response to a question in this checklist means compliance with that requirement, and a "no"
response means noncompliance with the requirement. If the requirement is not applicable, indicate
"N/A" in the comments column.
A. Monitoring and Inspection Requirements §§63.119(c) and 63.120(b) as cross-
referenced from §63.1365(d)(3) Comments
Note: The monitoring requirements include visual inspections and seal gap measurements. For a dual-seal
system, the secondary seal inspection and gap measurement (questions 3 and 5 through 7) occurs
annually. Primary seal inspections and gap measurements (questions 4 through 7), and "comprehensive"
inspections (questions 8 through 16) occur at least every 5 years and every time the storage vessel is
empty and degassed. For a single-seal system (i.e., an option until 2009 at the latest), the primary seal
inspection and gap measurement occurs annually, question 3 does not apply, and a "comprehensive"
inspection is required when the storage vessel is empty and degassed.
1. Does the EFR float on the surface of the stored liquid? D Yes D No
§63.119(c)(3) and (4)
Note: The roof is not required to be floating on the liquid
surface during initial filling, after the vessel has been
completely emptied and degassed, and when completely
emptied before being refilled. When the roof is resting on the
leg supports, the process of filling, emptying, and refilling must
be continuous and completed as soon as possible.
1. Is the EFR in good condition (i.e., free of defects such as D Yes D No
corrosion and pools of standing liquid)? §63.120(b)(10)(i)
3. Inspect the secondary seal and perform seal gap measurements.
• Is the seal continuously attached along the edge of the D Yes D No
EFR? §63.120(b)(6)(i)
• Is the seal and seal fabric free of holes, tears, or other D Yes D No
openings? §63.120(b)(6)(ii)
• Are any gaps between the seal and the wall of the storage
vessel less than both of the following: §63.120(b)(4)
*• The total area of the gaps is less than 21.2 cm2 per meter D Yes D No
of vessel diameter?
* The maximum gap width between the vessel wall and D Yes D No
the seal does not exceed 1.27 cm?
4-25
-------
Checklists: (cont'd)
Requirements for a storage vessel with an external floating roof (Option 2)
A. Monitoring and Inspection Requirements §§63.119(c) and 63. 120(b) as cross-
referenced from §63.1365(d)(3) Comments
• Do you measure the seal gap between the vessel wall and D Yes D No
the secondary seal at least once per year?
Note: If, as of November 11, 1997, your EFR has a liquid-
mounted or metallic shoe primary seal with no secondary seal,
you are not required to install a secondary seal until either the
next time the storage vessel is emptied and degassed or June
23, 2009, whichever is earlier.
4. Inspect the primary seal and perform seal gap measurements.
• Is the primary seal either a metallic shoe or liquid-mounted D Yes D No
seal? §63.119(c)(l)(ii)
Note: If your EFR is equipped with a vapor-mounted
primary seal and a secondary seal as of November 11,
1997, then you are not required to install a metallic shoe or
liquid-mounted primary seal until the next time the storage
vessel is emptied and degassed or June 23, 2009, whichever
is earlier.
• Does the primary seal form a continuous closure that
completely covers the space between the vessel wall and
EFR such that: §63. 120(b) (3)
*• The total area of the gaps is less than 212 cm2 per meter D Yes D No
of vessel diameter?
* The maximum gap width between the vessel wall and D Yes D No
the seal does not exceed 3.81 cm?
• Is the seal fabric, seal envelope, or shoe (if a metallic shoe D Yes D No
seal is used) free of holes, tears, or other openings?
§63.120(b)(5)(ii)
• If the primary seal is a metallic shoe seal:
* Does the lower end of the metallic shoe extend into the D Yes D No
stored liquid? §63.120(b)(5)(i)
*• Does the upper end of the metallic shoe seal extend a D Yes D No
minimum vertical distance of 61 cm above the liquid
surface? §63.120(b)(5)(i)
*• Is there a flexible coated fabric that spans the space D Yes D No
between the metal shoe and the vessel wall?
• If the primary seal is a liquid-mounted seal, is the seal in D Yes D No
contact with the liquid between the storage vessel wall and
EFR? definition of liquid-mounted seal in §63. Ill
4-26
-------
Checklists: (cont'd)
Requirements for a storage vessel with an external floating roof (Option 2)
A. Monitoring and Inspection Requirements §§63.119(c) and 63.120(b) as cross-
referenced from §63.1365(d)(3) Comments
• Do you measure the seal gap between the vessel wall and D Yes D No
the primary seal at least every 5 years? §63.120(b)(l)(i)
Note: If your EFR does not have a secondary seal,
§63.120(b)(l)(ii) specifies the seal gap measurements for
the primary seal must be once per year.
5. When you measure the seal gaps, if any, do all of the following
apply:
• Is the EFR floating (i.e., not resting on the roof leg D Yes D No
supports)? §63.120(b)(2)(i)
• Do you measure around the entire circumference of the D Yes D No
vessel in each place where a 0.32 centimeter (1/s inch)
diameter uniform probe passes freely between the wall and
the seal? §63.120(b)(2)(ii)
• Do you determine the total surface area of each gap using D Yes D No
probes of various widths to measure the gap accurately?
§63.120(b)(2)m(iii)m
6. If you determine that it is unsafe to perform the seal gap D Yes D No
measurements, do either of the following apply: §63.120(b)(7)
• Do you measure the gaps no later than 30 days after the
determination?
or
• Do you remove the vessel from service within 45 days after
the determination?
Note: You may use up to 2 extensions of the 45-day limit
provided you explain why it was unsafe to perform the seal gap
measurement or inspection, document that alternate storage
capacity is unavailable, and specify a schedule to ensure that
the vessel is emptied as soon as practical
7. Do you either repair the seals or empty the storage vessel no D Yes D No
later than 45 days after the seal gap measurements or
concurrent inspection indicate a failure? §63.120(b)(8)
8. Do you visually inspect the EFR, the primary seal, the D Yes D No
secondary seal, and fittings each time the vessel is emptied and
degassed? §63.120(b)(10)
4-27
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Checklists: (cont'd)
Requirements for a storage vessel with an external floating roof (Option 2)
A. Monitoring and Inspection Requirements §§63.119(c) and 63.120(b) as cross-
referenced from §63.1365(d)(3) Comments
9. Inspect deck openings.
• If the EFR is non-contact, do the openings in the EFR D Yes D No
project below the stored liquid surface (except automatic
bleeder and rim space vents)? §63.119(c)(2)(i)
Note: If these openings did not provide projections below
the liquid surface as of November 11, 1997, you are not
required to comply with this requirement until the next time
the storage vessel is emptied and degassed or June 23,
2009, whichever is earlier.
• Is each opening in the EFR equipped with a gasketed cover D Yes D No
that forms a vapor-tight seal (except automatic bleeder
vents, rim space vents, roof drains, and leg sleeves)?
§63.119(c)(2)(ii)
• Is each gasketed cover on any EFR opening closed (unless D Yes D No
open for access)?
• Are covers on each access hatch and gauge float well D Yes D No
fastened air-tight when closed? §63.119(c) (2) (in)
• Do gaskets on EFR opening covers close off the liquid D Yes D No
surface from the atmosphere? §63.120(b)(l0)(i)
10. Inspect automatic bleeder vents.
• Are the automatic bleeder vents closed (unless the roof is D Yes D No
being floated off or landed on the roof leg supports)?
• Are the automatic bleeder vents gasketed? D Yes D No
§63.119(c)(2)(v)
• Do the gaskets close off the liquid surface from the D Yes D No
atmosphere? §_63-12°(b)(10)(0
11. Inspect rim space vents.
• Are the rim space vents closed (except when the roof is D Yes D No
being floated off the roof leg supports, or the pressure
beneath the rim seal exceeds the manufacturer's
recommended setting)? §63.119(c) (2) (iv)
• Are the rim space vents gasketed? §63.119(c)(2)(v) D Yes D No
• Do the gaskets close off the liquid surface from the D Yes D No
atmosphere? §63.120(b)(10)(i)
4-28
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Checklists: (cont'd)
Requirements for a storage vessel with an external floating roof (Option 2)
A. Monitoring and Inspection Requirements §§63.119(c) and 63.120(b) as cross-
referenced from §63.1365(d)(3)
Comments
12. Is each roof drain covered with a slotted membrane fabric that
covers at least 90 percent of the opening area?
§63.119(c)(2)(vi)
DYes
DNo
13. Is each slotted or unslotted guide pole well equipped with
either a gasketed sliding cover or a flexible fabric sleeve seal
that closes off the liquid surface from the atmosphere?
§63.119(c)(2)(vii) and (ix)
DYes
DNo
14. Does each unslotted guide pole have on its end a closed
gasketed cap that closes off the liquid surface from the
atmosphere (except when gauging the liquid level or taking
liquid samples)? §63.119(c)(2)(viii)
DYes
DNo
15. Does each slotted guide pole have a gasketed float inside the
guide pole or other control device that closes off the liquid
surface from the atmosphere? §63.119(c)(2)(x)
DYes
DNo
16. Does each gauge hatch and sample well have a closed gasketed
cover that closes off the liquid surface from the atmosphere
(except when open for access)? §63.119(c)(2)(xi)
DYes
DNo
B. Recordkeeping and Reporting Requirements §§ 63.122 and 63.123 as
referenced by §§ 63.1367(b) (11) and 63.1368(g) (2) (xii)
cross-
Comments
1. Do your records indicate that you made seal gap measurements D Yes
and performed a concurrent visual inspection annually for the
secondary seal and every 5 years for the primary seal?
§63.120(b)(l)(i) and (Hi)
DNo
2.
3.
4.
5.
For all seal gap measurements, did you record all of the
following: §63.123(d)
• the date of the seal gap measurement?
• the raw data obtained?
• calculations performed?
Did you record the occurrence of each "comprehensive" visual
inspection?
Do you maintain records for 5 years? §63. 1367(a)(l)
Did you notify the Administrator at least 30 days before each
seal gap measurement? §63.120(b)(9)
DYes
DYes
DYes
DYes
DYes
DYes
DNo
DNo
DNo
DNo
DNo
DNo
4-29
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Checklists: (cont'd)
Requirements for a storage vessel with an external floating roof (Option 2)
B. Recordkeeping and Reporting Requirements §§ 63.122 and 63.123 as cross-
referenced by §§ 63.1367(b)(ll) and 63.1368(g)(2)(xii) Comments
6. If you detected a failure in the seals during the seal gap
measurement or concurrent visual inspection, did you include
the following in your periodic report: §63.122(e) (1)
• the date of the inspection or measurement? D Yes D No
• the raw data obtained during the seal gap measurement? D Yes D No
• calculations of the total gap area? D Yes D No
• a description of any failure? D Yes D No
• the date and nature of the repair or the date the vessel was D Yes D No
emptied?
7. If your periodic report in "6" shows that you made a repair
more than 45 days after the failure was found, does your next
periodic report include documentation of the use of up to two
30-day extensions and the following information:
§63.120(b)(8) and§63.122(e)(2)
• identification of the storage vessel? D Yes D No
• description of the failure? D Yes D No
• documentation that alternate storage capacity was D Yes D No
unavailable?
• schedule of actions taken to make repairs or empty the D Yes D No
vessel as soon as possible?
• date the storage vessel was emptied and nature of and date D Yes D No
repair was made?
8. If you detected a failure during a "comprehensive" visual
inspection, did you submit the following information about the
inspection in your periodic report: §63.122(e)(3)(ii)
• date of the inspection? D Yes D No
• identification of all storage vessels with failures? D Yes D No
• description of the failures? D Yes D No
• date and nature of repair? D Yes D No
9. Before refilling an empty and degassed storage vessel, did you D Yes D No
submit a report to notify the Administrator at least 30 days
before the vessel was refilled (7 days if the inspection was
unplanned and could not be foreseen 30 days before refilling)?
§63.120(b)(10)(ii) and (in)
4-30
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Checklists: (cont'd)
Requirements for a storage vessel with an external floating roof (Option 2)
B. Recordkeeping and Reporting Requirements §§ 63.122 and 63.123 as cross-
referenced by §§ 63.1367(b)(ll) and 63.1368(g)(2)(xii) Comments
10. If you did not empty and remove a storage vessel from service
within 45 days after determining that it was unsafe to perform
the seal gap measurement and concurrent inspection of the
seals, does your next periodic report include the following
documentation for up to two 30-day extensions:
§§63.120(b)(7)(ii) and 63.122(e)(2)
• identification of the storage vessel? D Yes D No
• explanation of why it is unsafe to perform the seal gap D Yes D No
measurements?
• documentation that alternate storage capacity was D Yes D No
unavailable?
• a schedule of actions taken to make repairs or empty the D Yes D No
vessel as soon as practical?
• date the storage vessel was emptied and nature of and date D Yes D No
repair was made?
4-31
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Checklist 4: Requirements for a storage vessel with an external floating roof converted to an
internal floating roof (Option 3)
Facility Name:
Facility Location:
Facility TRI ID #:
Inspector:
Date:
Note: A "yes" response to a question in this checklist means compliance with that requirement, and a "no"
response means noncompliance with the requirement. If the requirement is not applicable, indicate
"N/A" in the comments column.
A. Monitoring and Inspection Requirements §§63.119(b) and (c) and 63.120(a) as
cross-referenced from §63.1365(d)(3) Comments
Note: The monitoring requirements include visual inspections and measurements.
Questions 3-5 apply to all inspections. Questions 6-15 apply only for visual inspections performed each
time the vessel is emptied and degassed (i.e., "internal" visual inspections).
1. If the storage vessel is equipped with a single-seal system, do
both of the following apply: §63.120(a)(2)
• Do you perform an "external" visual inspection of the D Yes D No
floating deck and seal at least once every 12 months?
• Do you perform an "internal" visual inspection of the D Yes D No
floating deck, the seal, gaskets, slotted membranes, and
sleeve seals (if any) each time the storage vessel is emptied
and degassed, and at least once every 10 years?
2. If the storage vessel is equipped with a double-seal system, do D Yes D No
either of the following apply: §63.120(a) (3)
• Do you perform an "internal'Visual inspection of the
floating deck, the primary seal, the secondary seal, gaskets,
slotted membranes, and sleeve seals (if any) each time the
storage vessel is emptied and degassed, and at least once
every 5 years, or
• Do you perform an "external" visual inspection of the
floating deck and the secondary seal at least once every 12
months, and do you perform an "internal" visual inspection
of the floating deck, the primary seal, the secondary seal,
gaskets, slotted membranes, and sleeve seals (if any) each
time the vessel is emptied and degassed, and at least once
every 10 years?
4-32
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Checklist 4: (cont'd)
Requirements for a storage vessel with an external floating roof converted to an internal floating
roof (Option 3)
A. Monitoring and Inspection Requirements §§63.119(b) and (c) and 63.120(a) as
cross-referenced from §63.1365(d)(3) Comments
3. Does the floating deck float on the liquid surface? D Yes D No
§§63.119(b)(l) and (2) and 63.120(a)(4)
Note: The roof is not required to be floating on the liquid
surface during initial filling, after the vessel has been
completely emptied and degassed, and when completely
emptied before being refilled. When the floating roof is resting
on the leg supports, the process of filling, emptying, and
refilling must be continuous and completed as soon as
possible.
4. Is the floating deck in good condition (i.e., free of defects such D Yes D No
as corrosion or pools of standing liquid)? §63.120(a) (4) and
(7)_
5. Inspect the seal(s). §63.120(a)(4) and (7)
• Is the seal attached to the floating deck? D Yes D No
• Is the seal or seal fabric free of holes, tears, or other D Yes D No
openings?
• Does the seal make continuous contact with the wall of the D Yes D No
storage vessel (i.e., no visible gaps between the seal and
wall)?
6. Is the floating deck equipped with a liquid-mounted seal, D Yes D No
metallic shoe seal, or a double seal? §63.119(b)(3)
Note: If the IFR is equipped, as of November 11, 1997, with a
single vapor-mounted seal, then you are not required to
comply with this provision until the next time the storage vessel
is emptied and degassed or June 23, 2009, whichever is
earlier.
7. Inspect deck openings.
• If the floating deck is non-contact, do the openings in the D Yes D No
floating deck project below the stored liquid surface (except
automatic bleeder and rim space vents)? §63.119(c) (2) (i)
Note: If these openings did not provide projections below
the liquid surface as of November 11, 1997, you are not
required to comply with this provision until the next time
the storage vessel is emptied and degassed or June 23,
2009, whichever is earlier.
4-33
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Checklist 4: (cont'd)
Requirements for a storage vessel with an external floating roof converted to an internal floating
roof (Option 3)
A. Monitoring and Inspection Requirements §§63. 119(b) and (c) and 63. 120(a) as
cross-referenced from §63.1365(d)(3) Comments
• Is each opening in the floating deck equipped with a D Yes D No
gasketed cover that forms a vapor-tight seal (except
automatic bleeder vents, rim space vents, roof drains, and
leg sleeves)? §63.119(c)(2)(ii)
• Is each gasketed cover on any deck opening closed (unless D Yes D No
open for access)? §63.119(c)(2)(ii)
• Are covers on each access hatch and gauge float well D Yes D No
fastened air-tight when closed? §63.119(c)(2)(ii)
• Do gaskets on deck opening covers close off the liquid D Yes D No
surface from the atmosphere? §63. 120(a)(7)
8 . Inspect automatic bleeder vents .
• Are the automatic bleeder vents closed (unless the roof is D Yes D No
being floated off or landed on the roof leg supports)?
• Are the automatic bleeder vents gasketed? D Yes D No
§63.119(c)(2)(v)
• Do the gaskets close off the liquid surface from the D Yes D No
atmosphere? §63.120(a)(7)
9. Inspect rim space vents.
• Are the rim space vents closed (except when either the roof D Yes D No
is being floated off the roof leg supports, or the pressure
beneath the rim seal exceeds the manufacturer's
recommended setting)? §63.119(c)(2)(iv)
• Are the rim space vents gasketed? §63.119(c)(2)(v) D Yes D No
• Do the gaskets close off the liquid surface from the D Yes D No
atmosphere? §63.120(a)(7)
10. Is each roof drain covered with a slotted membrane fabric that D Yes D No
covers at least 90 percent of the opening area?
11. Is each slotted or unslotted guide pole well equipped with D Yes D No
either a gasketed sliding cover or a flexible fabric sleeve seal
that closes off the liquid surface from the atmosphere?
§63.119(c)(2)(vii) and (ix)
4-34
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Checklist 4: (cont'd)
Requirements for a storage vessel with an external floating roof converted to an internal floating
roof (Option 3)
A. Monitoring and Inspection Requirements §§63.119(b) and (c) and 63.120(a) as
cross-referenced from §63.1365(d)(3)
Comments
12. Does each unslotted guide pole have on its end a closed
gasketed cap that closes off the liquid surface from the
atmosphere (except when gauging the liquid level or taking
liquid samples)? §63.119(c)(2)(viii)
DYes
DNo
13. Does each slotted guide pole have a gasketed float inside the
guide pole or other control device that closes off the liquid
surface from the atmosphere? §63.119(c) (2) (x)
DYes
DNo
14. Does each gauge hatch and sample well have a closed gasketed
cover that closes off the liquid surface from the atmosphere
(except when open for access)? §63.119(c)(2)(xi)
DYes
DNo
15. Did you complete any repairs of failures detected during
inspections before refilling the storage vessel? §63.120(a)(7)
DYes
DNo
B. Recordkeeping and Reporting Requirements §§ 63.122 and 63.123 as cross
referenced by §§ 63.1367(b) (11) and 63.1368(g) (2) (xii)
3. If you detected a failure during an inspection, did you submit
the following information in your periodic report:
§63.122(d)(l)(ii) and (2)(ii)
4. If your periodic report in "3" shows that you made a repair
more than 45 days after the failure was found, does your next
periodic report include documentation of the use of up to two
30-day extensions and the following information:
§§63.120(a)(4) and63.122(d)(l)(iii)
• identification of the storage vessel?
• description of the failure?
• documentation that alternate storage capacity was
unavailable?
DYes
DYes
DYes
DNo
DNo
DNo
Comments
Note: There are reporting and recordkeeping requirements for visual inspections.
1 . Did you record the occurrence of each visual inspection?
§63.123(e)
1. Do you maintain all records for 5 years? §63. 1367(a)(l)
D Yes D No
D Yes D No
• date of the inspection?
• identification of all storage vessels with failures?
• description of the failures?
• either the date and nature of repairs made or the date the
vessel was emptied (if the vessel was not already empty)?
DYes
DYes
DYes
DYes
DNo
DNo
DNo
DNo
4-35
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Checklist 4: (cont'd)
Requirements for a storage vessel with an external floating roof converted to an internal floating
roof (Option 3)
B. Recordkeeping and Reporting Requirements §§ 63.122 and 63.123 as cross
referenced by §§63.1367(b)(ll) and 63.1368(g)(2)(xii) Comments
• schedule of actions taken to make repairs or empty the D Yes D No
vessel as soon as possible?
• date the storage vessel was emptied and nature of and date D Yes D No
repair was made?
5. If you refilled a storage vessel after it was emptied and D Yes D No
degassed, did you submit a report notifying the Administrator
at least 30 days before the vessel was refilled (7 days if the
inspection was unplanned and could not be foreseen 30 days
before refilling)? §63.120(a)(5) and (6)
4-36
-------
Checklist 5: Requirements for a storage vessels using vapor balancing (Option 4)
Facility Name:
Facility Location:
Facility TRI ID #:
Inspector:
Date:
response means noncompliance \
"N/A" in the comments column.
Note: A "yes" response to a question in this checklist means compliance with that requirement, and a "no
p mpanc nrmrmnniianr^ with the requirement. If the requirement is not applicable, indicate
i.
A. Monitoring Requirements
Comments
1. When a storage vessel is filled from a tank truck or railcar, is a
vapor collection system connected between them?
§63.1362(c)(6)(iii)
DYes
DNo
2. Is the pressure relief device on the storage vessel set to >2.5
psig? §63.1362(c)(6)(v)
DYes
DYes
DNo
DNo
3. Is the pressure relief device monitored quarterly for leaks using
Method 21 of 40 CFR, part 60, appendix A?
§63.1362(c)(6)(v)(A)
B. Recordkeeping and Reporting Requirements
Comments
1. Do you have records that the tank trucks and/or railcars from
which the storage vessel is filled meet U.S. DOT pressure
requirements in 49 CFR part 180 or 173.31, respectively?
§63.1367 (b) (8)
DYes
DNo
2. For each pressure relief device leak, do you have records of all
of the following: §§63.1367(b) (8)
• the instrument identification number?
• the equipment identification number?
• operator name, initials, or identification number?
• date leak was detected?
• date of first repair attempt?
• date of successful repair?
• maximum instrument reading measured by Method 21 after
the leak is repaired?
DYes
DYes
DYes
DYes
DYes
DYes
DYes
DNo
DNo
DNo
DNo
DNo
DNo
DNo
3. Do you have written certification from facilities that reload
and/or clean tank trucks and railcars that they will either reduce
the HAP content of displaced vapor by > 90 percent (and meet
compliance requirements in Subpart MMM) or vapor balance
to the tank from which the tank truck or rail car is loaded?
§63.1362(c)(6)(vii)(A)
DYes
DNo
4. Do you maintain records for 5 years? §63.1367(a)(l)
DYes
DNo
4-37
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Checklist 6: Requirements for a storage vessel meeting the requirements for a closed-vent
system and add-on control device (Options 5A, SB, and 5C)
Facility Name:
Facility Location:
Facility TRI ID #:
Inspector:
Date:
Note: A "yes" response to a question in this checklist means compliance with that requirement, and a "no"
response means noncompliance with the requirement. If the requirement is not applicable, indicate
"N/A" in the comments column.
A. Monitoring Requirements
Comments
1. Was the control device operational at all times except during
periods of planned routine maintenance? §63.1362(c)(5)
B. Recordkeeping and Reporting Requirements
DYes
DNo
Comments
1. Do you keep records of periods of planned routine
maintenance? §63.1367(b) (6) (viii)
DYes
DYes
DYes
DYes
DNo
DNo
DNo
DNo
2. Do you submit both of the following in your periodic reports?
§63.1368(g)(2)(v)
• records of actual periods of planned routine maintenance
during the reporting period?
• anticipated periods of planned routine maintenance for the
next reporting period?
3. Do both of the following apply each time periods of planned
routine maintenance exceed 240 hr/yr: §63.1362(c)(5)
• you submit an application to the Administrator requesting D Yes D No
approval of an extension to no more than 360 hr/yr that
contained both of the following:
* an explanation of why the extension is needed? D Yes D No
*• a statement affirming that no material will be added to D Yes D No
the storage vessel between the time the 240 hr limit is
exceeded and the date the control device is returned to
service?
• you submit the application at least 60 days before the 240 D Yes D No
hr/yr limit is exceeded?
4-38
-------
Checklist 7: Requirements for a storage vessel meeting the alternative standard (Option 5E)
Facility Name:
Facility Location:
Facility TRI ID #:
Inspector:
Date:
Note: A "yes" response to a question in this checklist means compliance with that requirement, and a "no"
response means noncompliance with the requirement. Only question 7 in section A and questions 8
through 10 in section B of this checklist apply if you have already used checklists 2 and 12 in chapter 3
for process vents that are controlled with the same control device. If the requirement is not applicable,
indicate "N/A" in the comments column.
A. Monitoring Requirements Comments
1. Did you install a CEMS to monitor and record the outlet TOC D Yes D No
concentration at least once every 15 minutes? §63.1366(b)(5)
2. If you are using a combustion control device that generates D Yes D No
HC1, did you install a CMS to monitor and record the outlet
HC1 concentration at least once every 15 minutes?
3. If you introduce supplemental gases to the emission stream
before a noncombustion device, do you perform both of the
following: §§63.1365(a)(7) and63.1366(b)(5)(ii)
• adjust the monitored outlet TOC and/or HC1/C12 D Yes D No
concentrations to account for the supplemental gases?
• evaluate the volumetric flow rate of all gas streams each D Yes D No
time a new operating scenario is implemented?
4. If you introduce supplemental gases to the emission stream
before a combustion device, do you perform either of the
following: §§63.1365(a)(7) and63.1366(b)(5)(ii)
• adjust the monitored outlet TOC and/or HC1/C12 D Yes D No
concentrations to 3 percent oxygen?
• monitor residence time and firebox temperature? D Yes D No
5. Is the CEMS data reduced to operating day averages? D Yes D No
§63.1366(b)(2)and(8)
6. If flow to the control device can be intermittent, did you install D Yes D No
a flow indicator at the inlet or outlet of the control device, and
do you use it to identify periods of no flow?
§63.1366(b)(2)(iii)
1. Was the control device operational at all times except during D Yes D No
periods of planned routine maintenance? §63.1362(c)(5)
4-39
-------
Checklist?: (cont'd)
Requirements for a storage vessel meeting the alternative standard (Option 5E)
B. Recordkeeping and Reporting Requirements Comments
1. Do you have a written quality control program with protocols D Yes D No
for various operations, including calibration procedures for the
monitor? §63.8(d)
1. Have your recorded all maintenance and calibration checks D Yes D No
performed on the CEMS? §63.1367 (b) (3)
3. Do you have records of: §§63.1367(a)(4) and63.10(c)(l)-(14)
• All required CEMS measurements (including monitoring D Yes D No
data recorded during unavoidable CEMS breakdowns and
out-of-control periods)?
• The date and time of each period when the CEMS is D Yes D No
inoperative except for zero (low-level) and high-level
checks?
• The date and time of each period when the CEMS is out of D Yes D No
control (e.g., calibration drift exceeds specification, CEMS
fails cylinder gas audit)?
• The date and start and end time of each period of excess D Yes D No
emissions and parameter monitoring exceedances occurring
during startups, shutdowns, malfunctions, and at other
times?
• The nature and cause of any malfunction of your monitor (if D Yes D No
known), and corrective actions taken?
• The total process operating time during the reporting D Yes D No
period?
• All procedures, including calibrations, that are part of your D Yes D No
quality control program?
4. Do you have records indicating that you notified the D Yes D No
Administrator at least 60 days before conducting a performance
evaluation of your CEMS? §§63.1368(d) and 63.8(e)(2)
5. Did you include in your periodic report a description of the D Yes D No
routine maintenance planned for the control device for the next
reporting period and actually performed in the last reporting
period? §§63.1367(b)(6)(viii) and63.1368(g)(2)(v)
4-40
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Checklist?: (cont'd)
Requirements for a storage vessel meeting the alternative standard (Option 5E)
B. Recordkeeping and Reporting Requirements Comments
6. Do you submit all of the following in your periodic reports if
exceedances or excursions are > 1 percent of the total operating
time during the reporting period: §63.1368(g)(2)
• all monitoring data for all operating days or operating D Yes D No
blocks when the average TOC or HC1/C12 concentration
exceeds 20 ppmv for combustion control devices or 50
ppmv for noncombustion control devices?
• identification of all operating days when insufficient D Yes D No
monitoring data are collected?
7. Do you maintain records for 5 years? §63.1367(a)(l) D Yes D No
8. Do you keep records of periods (i.e., date and time) of planned D Yes D No
routine maintenance? §63.1367(b)(6)(viii)
9. Do you submit both of the following in your periodic reports:
§63.1368(g)(2)(v)
• records of actual periods of planned routine maintenance for D Yes D No
the reporting period?
• anticipated periods of planned routine maintenance for the D Yes D No
next reporting period?
10. Do all of the following apply each time periods of planned
routine maintenance exceed 240 hr/yr: §§63.1362(c)(5)
• you submit an application to the Administrator requesting
approval of an extension to no more than 360 hr/yr that
contained both of the following:
* an explanation of why the extension is needed? D Yes D No
*• a statement affirming that no material will be added to D Yes D No
the storage vessel between the time the 240 hr limit is
exceeded and the date the storage vessel is returned to
service?
• you submit the application at least 60 days before the 240 D Yes D No
hr/yr limit is exceeded?
4-41
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Chapter 5 - Complying with requirements for wastewater systems
What wastewater streams are subject to Subpart MMM?
Subpart MMM applies to "Group 1" wastewater streams that are discarded from a PAI process
unit that is at an affected source. A "Group 1" wastewater stream is any wastewater stream that
meets either of the following conditions: [§63.1361]
• Is generated from a PAI process, or a scrubber used to control emissions from a PAI
process, and contains either:
*• an annual average concentration of Table 9 compounds of at least 5 ppmw and has an
average flow rate of 0.02 L/min or greater; or
Note: Table 9 compounds are compounds listed on Table 9 ofsubpart G of the HON.
*• a total concentration of Table 9 compounds of at least 10,000 ppmw at any flow rate.
• Is generated from a PAI process unit as a result of maintenance activities and contains at
least 5.3 Mg of Table 9 HAP per individual discharge event.
Residuals removed from a Group 1 wastewater stream are also subject to Subpart MMM.
Definition. Residual means any liquid or solid material containing Table 9
compounds that is removed from a wastewater stream by a waste management
unit or treatment process that does not destroy organics.
What types of wastewater components are subject to Subpart MMM?
Subpart MMM applies to all of the following components of wastewater systems; these
components are called waste management units:
• wastewater tanks
., . , Definition. Waste management unit means the
• surface impoundments equipment, structure(s), and/or device(s) used to convey,
• containers store, treat, or dispose of wastewater streams or residuals.
• individual drain systems
• oil-water separators
Note: treatment processes are a subset of waste management units that remove or destroy the organics in a
wastewater.
5-1
-------
Subpart MMM also applies to heat exchange systems (see the section "What are my compliance
options for heat exchange systems?" beginning on page 5-30 for additional information).
Definition. Heat exchange system means any cooling tower system or once-through cooling
water system (e.g., river or pond water). A heat exchange system can include more than one
heat exchanger and can include an entire recirculating or once-through cooling system.
What wastewater streams are exempt?
Any wastewater stream that meets any of the following conditions is not subject to Subpart
MMM: [§§63.132(a)(3) and 63.1360(d)(4)]
Group 2 wastewater streams
Note: A Group 2 wastewater stream is any wastewater stream that does not meet the definition of a
Group 1 wastewater stream
• wastewater streams that are not part of a PAI process unit
• laundry water
• stormwater from segregated sewers
• water from fire-fighting and deluge systems, including testing of such systems
• spills
• water from safety showers
• noncontact steam boiler blowdown and condensate
How do I identify a Group 1 wastewater stream?
You identify Group 1 wastewater streams in either of the following ways: [§63.144(a)(l) and
(2)]
• designate the streams as Group 1
, . If you designate the stream as Group 1, you do not have
• determine the wastewater stream to do any measurements or caicuiations.
flow rate and annual average
concentration of Table 9 HAP
To determine the annual average flowrate and annual average concentration, both values must be
representative of actual or anticipated operation of the PAI process unit over a designated 12-
month period.
The annual average concentration is the total mass of Table 9 compounds
present in the wastewater stream during the designated 12-month period
divided by the total mass of the wastewater stream in the same 12-month
period.
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You may base the concentration on any of the following: [§63.144(b)]
• process knowledge
• bench scale or pilot scale test data
The POD means the point at which a wastewater
• test data from sampling at the point of stream exists the PAI process unit. [§63.1361]
determination (POD) or at a location
downstream of the POD
Note: You may determine the concentration either at the POD or downstream from the POD. If you
determine the concentration downstream of the POD, you must also make adjustments to account for
changes (e.g., dilution) caused by combining the Group 1 stream with other streams.
You may base the flowrate on any of the following: [§63.144(c)]
knowledge of the wastewater stream
and/or process If you determine or estimate the total volume of
wastewater, divide by 525,000 minutes to determine
historical records the annual average flowrate.
• measurement of the flowrate
Note: You may determine the flowrate either at the POD or downstream from the POD. If you determine the
flowrate downstream of the POD, you must also make adjustments like those described above for concentration.
What are my compliance options for wastewater systems?
You must meet all of the following for Group 1 wastewater streams:
• emission suppression compliance options
• air pollution control device compliance options for vented emissions from covered and
enclosed waste management units
• treatment compliance options
You must meet any of the following for residuals: [§63.138(k)]
• recycle it to a process
• sell it for the purposes of recycling
• return it to the treatment unit
• treat it to reduce the Table 9 HAP by >99 percent
• treat in a RCRA unit
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What are my emission suppression compliance options?
Emission suppression options are techniques for minimizing HAP emissions before the
wastewater reaches a treatment unit. You have several emission suppression compliance options
for each type of waste management unit. These options are the same for both existing and new
sources.
Note: The only exemption from the emission suppression requirements is for waste management units that are
also biological treatment units and meet specified requirements for HAP degradation. See the discussion of
treatment options T3G and T3H in the sections "What treatment compliance options do I have? " beginning on
page 5-10 and "How do I show initial compliance with the treatment compliance requirements?" beginning on
page 5-13. [§63.138(a)(3)]
Wastewater tanks
If your wastewater tank receives, manages, or treats a Group 1 wastewater stream or residual,
you have three compliance options if your wastewater tank meets any of the following:
[§63.133(a)]
Definition. Wastewater tank means a stationary waste management unit that is designed to
contain an accumulation of wastewater and residuals and is constructed primarily of nonearthen
materials which provide structural support. Wastewater tanks used for flow equalization are
included in this definition.
• tank size > 151 m3 storing wastewater with maximum true vapor pressure >5.2 kPa
• tank size >75 m3 and <151 m3 storing wastewater with maximum true vapor pressure
>13.1kPa
• tanks of any size storing any Group 1 wastewater stream or residual if the tank is used for
any of the following:
*• heating wastewater
*• treating by means of an exothermic reaction
*• sparging
Your three compliance options for these wastewater tanks are:
Option WT1: Use a fixed roof and control device [§63 133(a)(2)(i)]
Use a fixed roof and a closed-vent system that routes HAP vapors to control device.
Option WT2: Use a fixed roof and an internal floating roof [§63133(a)(2)(ii)]
5-4
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Option WT3: Use an external floating roof [§63.133(a)(2)(iii)]
For all other wastewater tanks that receive, manage, or treat a Group 1 wastewater stream, you
have four compliance options available. You may comply using option WT1, WT2, or WT3 as
described above, or you may comply using:
Option WT4: Use a fixed roof [§63.133(a)(l)]
Use a fixed roof tank, which may be vented to the atmosphere.
Surface impoundments
If your surface impoundment receives, manages, or treats a Group 1 wastewater stream or
residual, you have two compliance options:
Definition. Surface impoundment means a waste management unit which is a natural topographic
depression, manmade excavation, or diked area formed primarily of earthen materials (although it
may be lined with manmade materials), which is designed to hold an accumulation of liquid wastes
or waste containing free liquids. A surface impoundment is used for the purpose of treatment,
storing, or disposing of wastewater or residuals, and is not an injection well. Examples of surface
impoundments are equalization, settling, and aeration pits, ponds, and lagoons.
Option S1: Use a cover and control device [§63 134(b)(l)]
Install a vented cover (e.g., an air supported structure or rigid cover) and a closed vent
system that routes HAP vapors to an air pollution control device. Keep access hatches,
sampling ports, and other openings in the cover closed at all times except when it is
necessary to use the opening for sampling, removal, or for equipment inspection,
maintenance, or repair. For more information about control device requirements, see "What
are my compliance options for air pollution control devices?" later in this chapter (page 5-9).
Option S2: Use a floating flexible membrane cover [§63 134(b)(2)]
Use a floating flexible cover that meets all of the following design and operational criteria:
• it is designed to float on the liquid surface and form a continuous barrier over the entire
surface of the liquid
• is constructed from either:
*• high density polyethylene (HDPE) that is at least 2.5 millimeters thick
*• a material or a composite of different materials that have both organic permeability
properties that are equivalent to those of HDPE and chemical and physical properties
such that it will last for its intended service life
5-5
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• it has no visible cracks, holes, gaps, or other open spaces between cover section seams or
between the edge of the cover and its foundation mountings
each opening in the cover has a closure device (e.g., an access hatch) that is free of
visible cracks and other open spaces between the edge of the opening in the cover and the
closure device; §63.134(b)(2)(vi) specifies factors to consider in selecting suitable
materials for closure devices
closure devices are secured in the closed position except when allowed to be open as
specified in §63.134(b)(2)(vii)
drains for emergency removal of stormwater are allowed in the cover; these drains must
have either of the following:
*• a slotted membrane fabric cover that covers at least 90 percent of the area of the
opening
*• a flexible fabric sleeve seal
Containers
If your container receives, manages, or treats a Group 1 wastewater stream or residual, you must
operate and maintain a cover on the container. Other compliance requirements vary depending
on the size of the container and whether you treat wastewater in the container.
Definition. Container means any portable waste management unit that has a capacity greater than or
equal to 0.1 cubic meters in which a material is stored, transported, treated, or otherwise handled.
Examples of containers are drums, barrels, tank trucks, barges, dumpsters, tank cars, dump trucks,
and ships.
Your compliance options for containers are summarized in the following table:
Capacity of the container, m3
> 0.42
< 0.42 (but >0.1)
If you treat wastewater in the container,
must it remain open during treatment?
No
Yes
No
Yes
Compliance options
Cl
Cl and C3
Cl or C2
C3 and either Cl or C2
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Option C1: Use a cover and inspect for leaks [§63 135(b)(l), (b)(2)(ii), and (b)(3)]
Operate and maintain a cover, keep the cover and all openings closed except when in use,
and inspect for leaks. In addition, when you pump a Group 1 wastewater stream into a
container that has a capacity of at least 0.42 m3, you must use a submerged fill pipe that
meets design criteria specified in §63.135(c)(l). See "What monitoring must I do to
comply with the emission suppression requirements for waste management units?" later
in this chapter (page 5-22) for more information about the inspection requirements.
Option C2: Use a cover on containers that meet Department of Transportation
(DOT) specifications [§63.135(b)(2)(i) and (b)(3)]
Use a container that meets DOT specifications and testing requirements under 40 CFR
part 178. Keep the cover and all openings closed except when in use.
Option C3: Use an enclosure [§63.135(d)]
If you treat a Group 1 wastewater stream or residual in a container that must remain open
during treatment, then you must place the container inside an enclosure that has a closed
vent system to transport organic vapors to a control device. You also must comply with
either option Cl or C2. See "What are my compliance options for air pollution control
devices?" later in this chapter (page 5-9) for more information about the requirements for
control devices.
Individual drain systems
If your individual drain system (IDS) receives or manages a Group 1 wastewater stream, then
you have two compliance options.
Definition. Individual drain system means the system used to convey wastewater streams or
residuals to a waste management unit or to discharge or disposal. The term includes: hard piping; all
process drains and junction boxes; and associated sewer lines, other junction boxes, manholes,
sumps, and lift stations conveying wastewater streams or residuals.
Your compliance options for individual drain systems are as follows:
Option D1: Cover each opening [§63 136(b)]
Use covers on each opening in the drain system that are designed and operated as follows:
• if the cover is vented, route vapors to a process or through a closed vent system to a
control device
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keep covers and openings in the covers closed at all times except when necessary to use
the openings
See "What are my compliance options for air pollution control devices?" beginning on page 5-9 for
more information about the requirements for control devices.
Option D2: Use specified techniques for various parts of the drain system
[§63.136(e)]
Use emission suppression techniques as described in the following table:
for the
following part
ofanIDSa...
an individual
drain
you must suppress
emissions by...
using either a:
water seal
tightly fitting cap or
plug
and if...
you use a water seal, you must design the
wastewater discharge pipe to the drain or the
shield around the drain as specified in
§63.136(e)(l)(ii)
according to
this section of
the rule...
§63.136(e)(l)
a junction box
using a tightly fitting
solid cover
your cover is vented, you must route the vapors
to a process or transport the vapors through a
closed vent system to a control device (note that
if the junction box is filled and emptied by gravity
flow or it operates with only slight variations in
liquid level, then venting to the atmosphere is
allowed if the system is designed as specified in
§63.136(e)(2)(ii))
§63.136(e)(2)
sewer lines keeping covered or
enclosed without visible
gaps or other openings
to the atmosphere
N/A
§63.136(e)(3)
a A segregated stormwater sewer system, which is a drain and collection system that you designed and operate for
the sole purpose of collecting rainfall runoff, is exempt from the requirements for individual drain systems under
subpart MMM.
Oil-water separators
A waste management unit that separates and removes oils, scum, and solids from the wastewater
by gravity. Most of the separation occurs as the wastewater stream passes through a quiescent
zone in the unit where oils and scum with specific gravities less than water float to the top of the
aqueous phase, while heavier solids sink to the bottom. Some of the organic compounds
contained in the wastewater will partition to the oil phase and then can be removed with the
skimmed oil, leaving the separated water.
If your oil-water separator receives, manages, or treats a Group 1 wastewater stream or residual,
then you have three compliance options:
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Option O1: Use a fixed roof and control device §63 137(a)(l)
Use a fixed roof and transport organic vapors through a closed-vent system to a control
device. See "What are my compliance options for air pollution control devices?" below
on this page for more information about the requirements for control devices.
Option O2: Use a floating roof §63 137(a)(2)
Use a floating roof that meets the requirements specified in 40 CFR part 60, subpart
QQQ §§60.693-2(a)(l)(i), (a)(l)(ii), (a)(2), (a)(3), and (a)(4).
Note: For those parts of an oil-water separator where you cannot use a floating roof (e.g., over the weir
mechanism), you must comply with option Ol.
Option O3: Use an equivalent means of reduction §63 137(a)(3)
You may submit an application requesting approval of an alternative means of reduction
that is equivalent to the reduction that would be achieved by Option Ol or Option O2.
Note: You application must include either actual emission test data or an engineering evaluation
[§63.137(a)(3)(i) and (ii)]
What are my compliance options for air pollution control devices?
If you comply with an emission suppression compliance option for waste management units,
including waste management units that are treatment units, that includes vented covers or
enclosures, you have five compliance options for the vented emission streams:
Option A1: Percent reduction [§63.139(c)(l)(i), (2), (4), and (5)]
Reduce vented organic HAP emissions by >95 percent.
Option A2: Outlet concentration limit [§§63 139(c)(l)(ii), (2), (4), and (5), and
63.1362(d)(13)]
Reduce vented organic HAP emissions to <20 ppmv as TOC. If you combine the emission
streams with supplemental gases before a vapor recovery system, you must adjust the
measured HAP concentration to account for the dilution caused by the supplemental gases.
If you combine the emission stream with supplemental gases prior to a combustion device,
you must calculate the concentration at 3 percent oxygen.
Note: This option is not allowed for emissions from surface impoundments and containers if you use a
noncombustion device.
5-9
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Option A3: Specified enclosed combustion device [§63 139(b)(l)(iii)]
Use an enclosed combustion device that provides a minimum residence time of 0.5 seconds
at a minimum temperature of 760°C.
Option A4: Use a flare [§63 139(b)(3)]
Use a flare that meets the requirements of §63.1 l(b) (subpart A General Provisions) to
control organic HAP emissions.
Option A5: Specified exempted devices [§63 139(d)(4)]
Use any of the following devices that are exempt from initial compliance, monitoring,
recordkeeping, and reporting requirements under Subpart MMM:
• A boiler or process heater burning hazardous waste for which you have:
*• been issued a final permit for the boiler or process heater under 40 CFR part 270 and
are complying with the requirements of Subpart H in 40 CFR part 266
*• certified compliance with the interim status requirements of Subpart H in 40 CFR part
266
• A hazardous waste incinerator for which you have:
*• been issued a final permit for the incinerator under 40 CFR part 270 and you are
complying with the requirements of Subpart O in 40 CFR part 264
*• certified compliance with the interim status requirements of Subpart O in 40 CFR part
265
• A boiler or process heater with a design heat input >44 MW
• A boiler or process heater for which the emission stream is introduced with the primary
fuel
What treatment compliance options do I have for my wastewater
streams?
Treatment units are techniques that remove or destroy the organics in a wastewater stream.
Subpart MMM includes several compliance options and specifies how treatment units may be
used to achieve compliance with one or more of the compliance options. The compliance
options may be used individually or in combination to achieve the required emission control.
For all existing sources and most new sources, you have four treatment compliance options for
wastewater streams:
5-10
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Option T1: Reduce outlet concentration to less than 50 ppmw [§63 138(b)(l)]
Use a treatment unit that discharges HAP at less than 50 ppmw.
Note: You cannot use biological treatment units or dilution with this option.
Option T2: Use a design steam stripper [§63 138(d)]
Use a steam stripper that meets the following specific design and operating requirements:
• minimum active column height of 5 meters
• countercurrent flow configuration with a minimum of 10
actual trays
You are exempt from initial
• minimum steam flow rate of 0.04 kg/liter of wastewater compliance demonstration
feed to the column requirements for option T2.
• minimum wastewater feed temperature of 95°C, or
minimum column temperature of 95°C
• maximum liquid loading of 67,100 liters/hr/m2
• operate at atmospheric pressure
Option T3: Mass reduction [§63 138(e), (f), and (g)]
You have the following eight mass reduction options that vary in their required reductions
depending on the type of treatment unit you use, the types of wastewater streams that you
treat, and the specific compliance level:
For
option...
T3A
T3B
T3C
T3D
T3E
T3F
T3G
T3H
You may use the following type of
treatment unit...
noncombustion, nonbiological
noncombustion, nonbiological
combustion
combustion
noncombustion (including closed
biological)
closed biological
open or closed biological
open or closed biological
You must reduce the HAP
in the following streams...
Group 1
Group 1
Group 1
Group 1
Group 1
Group 1 and Group 2
Group 1
Group 1 and Group 2
By this amount...
99%
weighted average Fr value
99%
weighted average Fr value
required mass removal
95% required mass removal
required mass removal
95% required mass removal
5-11
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If you comply with option T3A or T3C, your treatment unit must reduce the mass of total Table
9 HAP that it receives by at least 99 percent. Generally, this would be a good option to use if the
treatment unit is used only for Group 1 streams that contain HAP with fraction removal (Fr)
values of 0.99. Note that these options are not allowed for biological treatment units.
If you comply with option T3B or T3D, your
treatment unit must achieve an overall Table 9 HAP The Fr values are specified in Table 9 of
mass reduction that is equal to or greater than the subPart G- These values are equivalent to the
• i x i r-^T- 1 r- xi TTATI- xi mass percentage reduction that would be
weighted average of the Fr values for the HAP in the achjed usm|the design steam stripper
wastewater stream. For example, if your Group 1
wastewater stream has one HAP with an Fr value of
0.99 and an equal amount of a second HAP with an Fr value of 0.95, then your treatment unit
must achieve an overall reduction of at least 97 percent (see "How do I show initial compliance
with the treatment compliance options" beginning on page 5-13 for more information). You
might want to choose one of these options if you treat only Group 1 streams, the HAP in your
wastewater stream have different Fr values, and you cannot achieve an overall 99 percent
reduction. These options also are not allowed for biological treatment units.
To comply with option T3E, you must
determine the required mass removal The required mass removal is the hourly mass of Table
(RMR) for each of your Group 1 streams. 9 HAP that must be removed or destroyed in the
,r . . . •. . .1 1 treatment unit. It is determined using weighted average
Your treatment unit must then have an Fr vames for ^ Tablg g HAp in tteBwast5water stefm
actual mass removal (AMR) rate that meets (see "How do I show initial compliance with the
or exceeds the sum of the RMR's for treatment compliance options" for more information).
wastewater streams that will be combined
for treatment. This option may be
advantageous if you treat both Group 1 and Group 2 streams because the Table 9 HAP in your
Group 2 streams can contribute to the total mass reduction. This means that the percentage
reduction achieved by the treatment unit can be lower than for the percentage reduction options.
Also note that this option is available for biological treatment units only if they are closed units.
Option T3F is similar to option T3E, except that required mass removal is specified as 95%, it is
only allowed for closed biological treatment units, and the required mass removal must be
applied to both the Group 2 and Group 1 streams that are combined for treatment in the
biological unit. Options T3G and T3H are similar to options T3E and T3F, except that the
compliance procedures are designed specifically for open biological treatment units.
Option T4: Use a RCRA unit [§63 138(h)]
Treat the wastewater in a permitted
Resource Conservation and Recovery Act YOU are exempt from initial compliance
(RCRA) hazardous waste incinerator, a requirements, monitoring, and associated
RCRA permitted process heater or boiler, recordkeeping and reporting requirements under
or discharge to a properly permitted Subpart MMM if you comply with option T4.
underground injection well.
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For new sources, you have the same four options described above, except you must comply with
either option T3A, T3B, or T4 if the total mass flow rate of HAP in wastewater from the affected
source is 2,100 Mg/yr or more.
Instead of treating the wastewater yourself, you may transfer it to someone else for treatment.
Whoever agrees to treat the wastewater must comply with the requirements in subpart MMM.
You must also meet all of the following if you decide to transfer the wastewater to someone else
for treatment:
• comply with the emission suppression and control device options prior to transfer
• include a notice with the shipment of each Group 1 wastewater stream or residual (or
each time there is a change in the required treatment) stating that the stream contains
HAP that are to be controlled as specified in subpart MMM
• obtain written certification from the treatment facility stating that they will comply with
subpart MMM
Note: If the wastewater stream contains <50 ppmw of partially soluble HAP, the offsite facility does not
have to comply with the emission suppression requirements (i.e., covers on waste management units prior
to the activated sludge unit) if the treatment is performed in a biological treatment unit, and you
demonstrate that <5 percent of the soluble HAP is emitted prior to the activated sludge unit. See Tables 2
and 3 to subpart MMM for listings of partially soluble HAP and soluble HAP, respectively.
[§63.1362(d)(14)]
How do I show initial compliance with the emission suppression
compliance requirements?
You must conduct an initial inspection of waste management units and closed-vent systems that
transport emissions to control devices. These inspections are identical to inspections that must
be performed periodically to demonstrate ongoing compliance. To avoid repetition, inspection
requirements are summarized in "What monitoring must I do to comply with the emission
suppression requirements for waste management units?" (page 5-22).
How do I show initial compliance with the treatment compliance
requirements?
You must conduct either a design evaluation or a performance test to demonstrate initial
compliance with treatment compliance Option Tl and all versions of Option T3.
General Requirements for Performance Tests
To demonstrate compliance using a performance test, you must meet all of the following:
[§63.145(a)]
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• demonstrate compliance under "representative" conditions for the process(es)
demonstrate compliance when the treatment unit is operating at representative inlet
flowrate and concentration
collect and analyze wastewater samples using the test methods and procedures specified
in §§63.144(b)(5)(i) through (iii) and 63.1365(b)(8)
• take concentration and flow measurements at the same time
a test consists of at least 3 test runs, each for a 1-hour period; take samples at
approximately equally-spaced time intervals over each 1-hour period
For a performance test of a biological treatment process (Options T3E, T3F, T3G, and T3H),
you may consider the inlet to the equalization tank to be the inlet to the treatment process if you
meet all of the following:
• wastewater is conveyed by hard-piping from either the previous treatment process or the
POD to the equalization tank
• wastewater is conveyed by hard-piping from the equalization tank to the biological
treatment process (i.e., there are no waste management units between the equalization
tank and the biological process unit)
• the equalization tank has a fixed roof with a closed vent system transports emissions to
an air pollution control device
Specific Performance Test Requirements for Treatment Compliance Options
Specific requirements for performance tests that you use to demonstrate initial compliance with
option Tl or any variation of option T3 are specified in §63.145 and summarized in Table 5-1.
For the mass reduction compliance options, the procedures described in Table 5-1 are for either a
single treatment unit or a series of treatment units that are connected by hard-piping (i.e., when
you determine flow rate and concentrations for the treatment unit, the inlet is prior to the first
treatment unit in the series, and the outlet is the exit from the last treatment unit in the series).
If you use a series of treatment processes that are not connected by hard-piping, then you must
apply the procedures in the table to each individual treatment unit in the series and sum the
resulting reductions from each unit to determine if you are in compliance.
Note: You do not have to sum the mass reductions from all of the units if each unit is designed to remove
different HAP. For example, suppose wastewater streams that contain both toluene and methanol are sent to a
series of treatment units where the first unit removes a mass of toluene that exceeds the Fr value for toluene,
and the second unit removes a mass of methanol that exceeds the Fr value for methanol. In this case, you can
do calculations around just the first unit to demonstrate compliance for toluene, and around just the second
device for methanol.
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TABLE 5-1. Performance Testing Requirements for Treatment Units
For option...
For each test run, determine the...
And calculate the...
You have
demonstrated
compliance if...
According to
this section of
the rule...
Tl
(noncombustion
and
nonbiological
treatment units)
concentration of Table 9 HAP at the
outlet of the treatment unit
average concentration of Table 9 HAP at the outlet of
the treatment unit over all of the test runs
the sum of the Table 9
HAP averaged over
the 3 runs is <50
ppmw
§63.145(b)
T3A
(noncombustion
and
nonbiological
treatment units)
Table 9 HAP concentrations at inlet
and exit of the treatment unit
wastewater flowrate entering and
exiting the treatment unita
average mass flow rate of Table 9 HAP entering
and exiting the treatment unit over all of the test
runs (use equations WW1 and WW2)
percent removal
the calculated percent
removal is > 99
percent
§63.145(c)
T3B
(noncombustion
and
nonbiological
treatment units)
Table 9 HAP concentrations at inlet
and exit of the treatment unit
wastewater flowrate entering and
exiting the treatment unita
average mass flow rate of Table 9 HAP entering
and exiting the treatment unit over all of the test
runs (use equations WW1 and WW2)
percent removal in the treatment unit
flow-weighted average of the Fr values for the
Table 9 HAP entering the treatment unit (use
equation WW8)
the calculated percent §63.145(c)
removal is greater than
or equal to the flow-
weighted average of
the Fr values
T3C • Table 9 HAP concentration in
(combustion wastewater entering the combustion
treatment units) unit
• wastewater flowrate entering the
combustion unit
• Table 9 HAP concentration in the
vented gas stream exiting the
combustion unit
• volumetric flowrate of the vented gas
stream exiting the combustion unit
average mass flow rate of Table 9 HAP entering
the combustion treatment unit over all of the test
runs (use equation WW4)
average mass flow rate of Table 9 HAP exiting the
combustion treatment unit in the vented gas stream
(use equation WW6)
destruction efficiency of the combustion treatment
unit for Table 9 HAP
the calculated
destruction efficiency
is > 99 percent
§63.145(d)
-------
TABLE 5-1. (cont'd)
For option...
For each test run, determine the... And calculate the...
You have
demonstrated
compliance if...
According to
this section of
the rule...
T3D • Table 9 HAP concentration in
(combustion wastewater entering the combustion
treatment units) unit
• Table 9 HAP concentration in the
vented gas stream exiting the
combustion unit
• volumetric flowrate entering the
combustion treatment unit
• volumetric flowrate of the vented gas
stream exiting the combustion unit
average mass flow rate of Table 9 HAP entering
the combustion treatment unit over all of the test
runs (use equation WW4)
average mass flow rate of Table 9 HAP exiting the
combustion treatment unit in the vented gas stream
over all of the test runs (use equation WW6)
flow-weighted average of the Fr values for the
Table 9 HAP entering the combustion treatment
unit (use equation WW8)
destruction efficiency of the combustion treatment
unit for Table 9 HAP
the calculated
destruction efficiency
is greater than or equal
to the flow-weighted
average of theFr
values
§63.145(d)
T3E
(noncombustion
and closed
biological
treatment units)
Table 9 HAP concentration in each
Group 1 wastewater stream at its
PODb
Table 9 HAP concentration at the inlet
and outlet of the treatment unit
flowrate of each Group 1 wastewater
stream at its PODb
flowrate of wastewater at inlet and
outlet of the treatment unita
RMR for each Group 1 wastewater stream over all the AMR for the §63.145(e)
of the test runs (use equation WW9, which requires treatment unit is
the HAP Fr values)
sum of the RMR values for all of the Group 1
wastewater streams
average mass flowrate of Table 9 HAP entering
and exiting the treatment unit over all of the test
runs (use equations WW1 and WW2)
difference between the average mass flowrates of
Table 9 HAP entering and exiting the treatment
unit (this is the actual mass removal [AMR])
greater than or equal
to the sum of the
RMR's for the Group
1 wastewater streams
that are treated in the
treatment unit
-------
TABLE 5-1. (cont'd)
For option...
For each test run, determine the... And calculate the...
You have
demonstrated
compliance if...
According to
this section of
the rule...
T3F (closed • Table 9 HAP concentration in each
biological Group 1 and Group 2 wastewater
treatment units) stream at its POD"
• flowrate of each Group 1 and Group 2
wastewater stream at its POD"
• Table 9 HAP concentration at the inlet
and outlet of the treatment unit
• flowrate of wastewater at inlet and
outlet of the treatment unita
RMR for each Group 1 and Group 2 wastewater
stream (use equation WW9a; note that the RMR is
95 percent of the mass of HAP in each wastewater
stream)
sum of the RMR values for all of the Group 1 and
Group 2 wastewater streams
average mass flowrate of Table 9 HAP entering
and exiting the treatment unit over all of the test
runs (use equations WW1 and WW2)
difference between the average mass flowrates of
Table 9 HAP entering and exiting the treatment
unit (this is the AMR)
the AMR for the
closed biological
treatment unit is
greater than the sum
of the RMR's for all
of the Group 1 and
Group 2 wastewater
streams that are
treated in the closed
biological treatment
unit
§63.145(e)
T3G (open or
closed biological
treatment units)0
Table 9 HAP concentration in each
Group 1 wastewater stream at its
PODb
flowrate of each Group 1 wastewater
stream at its PODb
Table 9 HAP concentration at the inlet
and outlet of the treatment unit
flowrate of wastewater at inlet and
outlet of the treatment unita
RMR for each Group 1 wastewater stream over all
of the test runs (use equation WW11, which
requires the HAP Fr values)
sum of the RMR values for all of the Group 1
wastewater streams
fraction of Table 9 HAP biodegraded in the
treatment unit (determined using procedures in
§63.145(h) and appendix C to 40 CFR part 63)
average HAP mass flow rate entering the
biological treatment unit over all of the test runs
(use equation WW1)
AMR for the biological treatment unit (multiply
the average mass flow rate entering the treatment
unit by the average fraction biodegraded)"
the AMR for the
biological treatment
unit is greater than or
equal to the sum of the
RMR's for Group 1
wastewater streams
treated in the
biological treatment
unit
§63.145(f)
-------
TABLE 5-1. (cont'd)
For option...
For each test run, determine the... And calculate the...
You have
demonstrated
compliance if...
According to
this section of
the rule...
T3H (open or
closed biological
treatment units)0
Table 9 HAP concentration in each
Group 1 and Group 2 wastewater
stream (that are combined for
treatment in the treatment unit) at its
PODb
flowrate of each Group 1 and Group 2
wastewater stream at its POD"
Table 9 HAP concentration at the inlet
and outlet of the treatment unit
flowrate of wastewater at inlet and
outlet of the treatment unita
oo
RMR for each Group 1 and Group 2 wastewater
stream (use equation WW9a; note that the RMR is
95 percent of the mass of HAP in each wastewater
stream)
sum of the RMR values for all of the Group 1 and
Group 2 wastewater streams
average HAP mass flowrate entering the treatment
unit over all of the test runs (use equation WW1)
fraction of the Table 9 HAP biodegraded in the
treatment unit (determined using procedures in
§63.145(h) and appendix C to 40 CFR part 63)
AMR for the treatment unit (multiply the average
mass flow rate entering the treatment unit by the
fraction biodegraded)"
the AMR for the open
or closed biological
treatment unit is
greater than or equal
to the sum of the
RMR's for all of the
Group 1 and Group 2
wastewater streams
that are treated in the
open or closed
biological treatment
unit
§63.145(g)
a Only one measurement is needed if the outlet flow is not greater than the inlet flow.
" The determination may be made downstream of the POD if you adjust the measured concentration to account for combination of streams or treatment.
c You do not need to conduct a performance test if the biological treatment unit meets the definition of an "enhanced biological treatment unit" (see §63.111 for
the definition), and at least 99 percent of the Table 9 HAP by weight are included on list 1 in Table 36 to subpart G.
" Note that a different calculation is required if the biological treatment unit is part of a series of treatment units and the treatment units are connected by hard-
piping; see equation WW13 in §63.145(f)(5) for more information.
-------
Design evaluations for Treatment Units [§63 138(j)(l)]
If you elect to demonstrate initial compliance with a treatment compliance option by conducting
a design evaluation, you must provide documentation that addresses the operating characteristics
of the treatment process. The design evaluation also must be based on operation at a
representative wastewater stream flow rate and a Table 9 HAP concentration under which it
would be most difficult to demonstrate compliance.
If you comply with Option T3E, T3F, T3G, or T3H using a closed biological treatment unit,
you must use a mass balance to determine the AMR in the biological treatment unit as follows:
• step 1: determine mass flow rate of Table 9 HAP entering the biological unit
• step 2: determine mass flow rate of Table 9 HAP exiting the biological unit in the
discharged wastewater
• step 3: determine the mass flow rate of Table 9 HAP exiting the biological treatment unit
in the vented gas stream
• step 4: the AMR is calculated by subtracting the values in steps 2 and 3 from the value in
step 1
How do I show initial compliance with the control device compliance
requirements?
Subpart MMM requires you to conduct either a design evaluation or a performance test for each
control device you use to comply with Option Al, A2, A3, or A4.
Design evaluation [§63 139(d)(2)]
The specific parameters that you must consider in a design evaluation vary depending on the
type of control device that you use. The requirements are summarized in Table 5-2.
TABLE 5-2. Characteristics to Consider in Design Evaluations for Control Devices
If you
comply
with ...a
option Al
orA2
And you are using
the following
control device ...
thermal vapor
incinerator
catalytic vapor
incinerator
Then you must consider these
characteristics...
• vent stream composition
• constituent concentration
• flow rate
• vent stream composition
• constituent composition
• flow rate
And establish the following...
• design minimum temperature in
combustion zone
• design average temperature in
combustion zone
• combustion zone residence time
• design minimum temperature across
the catalyst bed
• design average temperature across
the catalyst bed
• design minimum outlet temperature
• design average outlet temperature
5-19
-------
TABLE 5-2. (cont'd)
If you
comply
with ...a
And you are using
the following
control device ...
Then you must consider these
characteristics...
And establish the following...
boiler or process
heater
condenser
regenerative
carbon adsorber
non-regenerative
carbon adsorber
vent stream composition
constituent concentration
flowrate
vent stream composition
constituent concentration
flowrate
relative humidity
temperature
vent stream composition
constituent concentration
flow rate
relative humidity
temperature
vent stream composition
constituent concentration
mass or volumetric flowrate
relative humidity
temperature
design minimum flame zone
temperature
design average flame zone
temperature
design minimum combustion zone
residence time
design average combustion zone
residence time
description of method and location
where the vent stream is introduced
to the flame zone
design outlet organic compound
concentration levels
design average temperature of the
condenser exhaust vent stream
design average temperatures of the
coolant fluid at the condenser inlet
and outlet
design exhaust vent stream organic
compound concentration level
adsorption cycle time
number and capacity of carbon beds
type and working capacity of
activated carbon used
design total regeneration stream mass
or volumetric flow rate
design carbon bed temperature after
regeneration
design carbon bed regeneration time
design service life of the carbon
design exhaust vent stream organic
compound concentration level
capacity of carbon bed
type and working capacity of
activated carbon
design carbon replacement interval
scrubber
vent stream composition
constituent concentration
liquid-to-vapor ratio
scrubbing liquid flow rate and
concentration
temperature
reaction kinetics of the
constituents with the scrubbing
liquid
design exhaust vent stream organic
compound concentration level
type and total number of theoretical
and actual trays for a tray column
type and total surface area of
packing, by section, for a packed
column
5-20
-------
TABLE 5-2. (cont'd)
If you And you are using
comply the following Then you must consider these
with...a control device... characteristics...
And establish the following..
Option A3 enclosed
combustion
device
none specified
none specified
option A4 flare
constituent concentration
constituent heat of combustion
flow rate
cross-sectional area of the
flare tip
vent gas heating value
vent gas exit velocity
conduct Method 22 visible emissions
test
a Each option is described in the section "What are my compliance options for air pollution control devices?"
beginning on page 5-9.
Performance test [§§63.1362(d)(12) and (13), 63.139(d)(l), and 63.145(a), (i), and (j)]
Your performance testing requirements are summarized in the following table:
If you
comply
with
a then you must...
you have
demonstrated initial
compliance if...
according to this
section of the
rule...
option Al • conduct the performance test under representative
process unit operating conditions and when control
device is operating at a representative inlet flow rate
and concentration (Note: If the control device
operates over several sets of representative
conditions, test under one set, and supplement test
results with modeling and/or engineering
assessment to demonstrate performance over the
range)
• use specified test methods and procedures to select
sampling site, determine flow rate, and measure
organic HAP or TOC concentration
• calculate mass rate of TOC or total organic HAP
entering and existing the control device (use
equations WW16 and WW17)
• calculate the mass percent reduction
the calculated mass
reduction is > 95
percent
§§63.145(a)and
(i), and
63.1362(d)(12)
option A2 • conduct performance test under conditions, and
using test methods and procedures, as specified
above for option Al
• correct measured outlet TOC or total organic HAP
concentration to account for supplemental gases
option A4 • determine visible emissions using Method 22 for 2-
hour period
• determine vent stream heating value and exit
velocity
the corrected
concentration is <20
ppmv
§§63.1362(d)(13)
and63.145(a)and
(i)
you meet the criteria
specified in
§63.11(b)
§§63.11(b)and
63.145(j)
a Each option is described in the section "What are my compliance options for air pollution control devices?"
beginning on page 5-9.
5-21
-------
What monitoring must I do to comply with the emission suppression
requirements for waste management units?
Your monitoring requirements consist of a variety of inspections and repairs. The specific
requirements depend on the compliance option you select. Details for each emission suppression
compliance option are specified in Table 5-3.
Note: If your emission suppression compliance option includes a closed vent system and control device, see
"What monitoring must I do for my air pollution control device? " and "How do I inspect my closed-vent
systems?" on pages 5-28 through 5-30 for additional information.
Note: If necessary, you may designate parts of covers, fixed roofs, and enclosures as unsafe-to-inspect or
difficult-to-inspect. Your requirements for these designated parts of emission suppression devices are the same
as for sections of closed-vent systems that you designate as unsafe-to-inspect or difficult-to-inspect (see "How do
I inspect my closed-vent systems? " on page 5-30 for additional information. [§63.1366(h)(6) and (7)]
5-22
-------
TABLE 5-3. Inspection Requirements for Waste Management Units
u\
to
If you have a(n) And you comply
with option. . . a Then you must . . .
wastewater WT1 inspect fixed roof and all openings for leaks (note that
tank these inspections are not required if your fixed roof is
maintained under negative pressure)
WT2 inspect floating roof in accordance with §63 . 120(a)(2)
and (a)(3), and check for control equipment failures such
as a rim seal that is detached from the floating roof or
gaps between the seal and the wall of the wastewater
tank as listed in §63.133(g)(l)(i) through (viii)
WT3 measure floating roof seal gaps in accordance with
§63.120(b)(3)(i) through (4), and inspect the seals for
compliance with design criteria specified in
§63.120(b)(5) and (6) (i.e., inspect for control equipment
failures such as a rim seal that is detached from the
floating roof or gaps between the seal and the wall of the
wastewater tank as listed in §63. 133(g)(l)(i) through
(viii))
Note: §63.133(e) specifies procedures to follow if
you determine that it is unsafe to perform the seal gap
measurement or inspections
WT1, WT2, or inspect wastewater tank for control equipment failures
WT3 such as a cracked cover or door
WT1, WT2, inspect wastewater tank for improper work practices
WT3, or WT4 (e.g., leaving an access door open when not in use)
At this
frequency... Using...
initially Method 21
semiannually sensory
observations
varies visual
depending on observations
number of
seals and the
option
selected
initially and visual
once every 5 observations
years for the
primary seal;
both initially
and annually
for the
secondary
seal
initially and visual
semiannually observations
initially and visual
semiannually observations
According to this
section of the rule...
§63.133(b)(l),(b)(4),
§63.1366(h), and
Table 1 1 to subpart G
§63.133(b)(l),(b)(4),
§63.1366(h), and
Table 1 1 to subpart G
§63.133(c),(g)(l),and
(g)(2); §63.143(a);
and Table 1 1 to
subpart G
§63.133(d),(g)(l),
and(g)(3);
§63. 143(a); and Table
1 1 to subpart G
§63.133(g)(l)(ix),
(g)(3), §63.43(a), and
Table 1 1 to subpart G
§63.133(f),
§63. 143(a), and Table
1 1 to subpart G
-------
TABLE 5-3. (cont'd)
If you have a(n) And you comply
with option...a Then you must.
At this
frequency.
Using...
According to this
section of the rule..
WT1, WT2, repair defects (e.g., improper work practices or control each time a N/A §§63.133(h) and
WT3, or WT4 equipment failures) within 45 calendar days of detection, defect is 63.140
unless a delay of repair or an extension is allowed detected
surface SI inspect the cover and all openings for leaks (note that initially Method 21 §63.134(b)(3), (4),
impoundment these inspections are not required if your cover is and (5), §63.1366(h),
maintained under negative pressure) and Table 11 to
subpart G
semiannually sensory §63.134(b)(3), (4),
observations and (5), §63.1366(h),
and Table 11 to
subpart G
Y1 SlorS2 visually inspect the surface impoundment for both of the initially and visual §63.134(c),
jf following defects: semiannually observations §63.143(a), and Table
• improper work practices (e.g., leaving an access hatch 11 to subpart G
or other closure device open when not in use)
• control equipment failures (e.g., cracks or gaps in the
cover or closure devices)
repair defects within 45 calendar days of detection, eachtimea N/A §§63.134(d) and
unless a delay of repair is allowed defect is 63.140
detected
container Cl inspect cover and all openings for leaks initially Method 21 §63.135(b)(l) and
§63.1366(h), and
Table 11 to subpart G
semiannually sensory §63.135(b)(l) and
observations (b)(2)(ii),
§63.1366(h), and
Table 11 to subpart G
-------
TABLE 5-3. (cont'd)
fj\
to
If you have a(n) And you comply
with option. . . a Then you must . . .
C3 inspect the enclosure and all openings for leaks (note
that inspections are not required if you maintain the
enclosure under negative pressure)
Cl or C2 inspect the container for both of the following types of
defects:
• control equipment failures (e.g., a cover that is broken
or has a crack or gap)
• improper work practices (e.g., leaving an access hatch
open when not in use)
repair defects due to control equipment failures and
improper work practices within 15 calendar days after
detection, unless a delay of repair is allowed
individual drain D 1 inspect the cover and all openings for leaks (note that
system you are not required to conduct these inspections if your
cover is maintained under negative pressure)
inspect the individual drain system for both of the
following types of defects:
• control equipment failures (e.g., a cover that is broken
or cracked)
• improper work practices (e.g., leaving an access hatch
open when not in use)
At this
frequency...
initially
semiannually
initially and
semiannually
each time a
defect is
detected
initially
semiannually
initially and
semiannually
Using...
Method 21
sensory
observations
visual
observations
N/A
Method 21
sensory
observations
visual
observations
According to this
section of the rule...
§63.135(d)(l)and(4),
§63.1366(h), and
Table 1 1 to subpart G
§63.135(d)(l),(d)(4),
and Table 1 1 to
subpart G
§63.135(e),
§63. 143(a), and Table
1 1 to subpart G
§§63.135(f)and
63.140
§63.136(b)(l)(i)and
(b)(4), §63.1366(h),
and Table 1 1 to
subpart G
§63.136(b)(l)(i),
§63.1366(h), and
Table 1 1 to subpart G
§63.136(c),
§63. 143(a), and Table
1 1 to subpart G
-------
TABLE 5-3. (cont'd)
If you have a(n) And you comply
with option. . . a Then you must .
At this
frequency...
Using..
According to this
section of the rule..
D2 verify that sufficient water is present to maintain each initially and visual §63.136(e)(l)(i),
water seal semiannually observation, §63.143(a), and Table
flow monitoring 11 to subpart G
device, or
continuous drip
into the drain
inspect tightly fitting caps and plugs on drains for defects initially and visual §63.136(f)(l),
such as gaps, cracks, or holes semiannually observations §63.143(a), and Table
11 to subpart G
inspect covers on junction boxes for defects such as initially and visual §63.136(f)(2),
gaps, cracks, or holes semiannually observations §63.143(a), and Table
11 to subpart G
u\
o^ inspect unburied portion of sewer line for defects such as initially and visual §63.136(f)(3),
cracks and gaps semiannually observations §63.143(a), and Table
11 to subpart G
DlorD2 repair defects within 15 calendar days after detection eachtimea N/A §§63.136(d), (g), and
unless a delay of repair is allowed defect is 63.140
detected
oil-water Ol inspect fixed roof an all openings for leaks (note that the initially Method 21 §63.137(b)(l) and
separator inspection is not required if the fixed roof is maintained (b)(4), §63.1366(h),
under negative pressure) and Table 11 to
subpart G
semiannually sensory §63.137(b)(l) and
observations (b)(4), §63.1366(h),
and Table 11 to
subpart G
-------
TABLE 5-3. (cont'd)
fj\
to
If you have a(n) And you comply
with option. . . a Then you must . . .
O2 inspect the oil-water separator for control equipment
failures such as a rim seal that is detached from the
floating roof or gaps between the seal and the oil-water
separator wall as listed in §63. 137(e)(l)(i) through (vi)
Ol or O2 inspect the oil-water separator for improper work
practices (e.g., leaving an access door open when not in
use)
inspect the oil-water separator for control equipment
failures such as a cracked cover or door
repair improper work practices and control equipment
failures within 45 calendar days of detection unless a
delay of repair is allowed
At this
frequency...
initially and
every five
years for the
primary seal,
and initially
and annually
for the
secondary
seal
initially and
semiannually
initially and
semiannually
each time a
defect is
detected
Using...
procedures
specified in
§60.696(d)(l)
to inspect seals
and measure
seal gaps
visual
observations
visual
observations
N/A
According to this
section of the rule...
§63.137(c),(e)(l)(i)
through (vi), and
(e)(2), §63.143(a), and
Table 1 1 to subpart
§63.137(d), 63.143(a),
and Table 1 1 to
subpart G
§63.137(e)(l)(vii),
(e)(3), §63.143(a), and
Table 1 1 to subpart G
§§63.137(f)and
63.140
a The emission suppression compliance options are described on pages 5-4 through 5-9.
-------
What monitoring must I do for my wastewater treatment unit?
To demonstrate ongoing compliance with the compliance options for treatment units, you must
monitor operating parameters for the treatment unit. Subpart MMM specifies the parameters to
monitor only for steam strippers. For all other treatment units, you must determine both the
parameters that demonstrate proper operation of the treatment and the frequency at which they
should be monitored. You must then submit a request for approval to monitor according to that
plan. The following table summarizes the requirements:
And you
comply with
If you use a ... option. . . a
Biological T3E, T3F,
treatment unit T3G, or
T3H
Steam stripper Tl, T2,
T3A, T3B,
orT3E
Any other Tl, T3A,
treatment T3B, T3C,
unitb T3D, or
T3E
Then you must ...
Request approval to monitor
appropriate parameters that
demonstrate proper operation of
the biological treatment unit
monitor each of the following:
• steam flow rate
• wastewater feed mass flow
rate
• either wastewater feed
temperature or column
operating temperature
Use your precompliance report
(or the procedures in §63.8(f)) to
request approval to monitor
appropriate parameters that
demonstrate proper operation of
your treatment process
At this
frequency...
As specified by
the permitting
authority
continuously
As specified by
the Administrator
According to this
section of the rule...
§63.1366(b)(l)(vii),
§63. 143(c) and Table
12 to subpart G
§63.1366(b)(l)(xii),
§63.143(b), and
Table 12 to subpart G
§63.1366(b)(l)(xii),
§63.143(d), and
Table 12 to subpart G
a The treatment compliance options are described on pages 5-9 through 5-13.
" You may also use this procedure to request approval to monitor parameters for a steam stripper that differ from
those specified in this table.
What monitoring must I do for my air pollution control device?
To demonstrate ongoing compliance with compliance options Al, A2, A3, and A4 for air
pollution control devices, you must monitor one or more operating parameters as specified in
Table 5-4.
5-28
-------
TABLE 5-4. Monitoring Requirements for Control Devices
If you use a ...
Thermal
incinerator
Boiler or
process heater
<44 MW (and
vent stream is
not mixed
with the
primary fuel)
Catalytic
incinerator
Condenser
Carbon
adsorber
(regenerative)
Carbon
adsorber (non-
regenerative)
And you
comply with
option. . . Then you must . . .
Al, A2, or Monitor firebox temperature
A3
Al, A2, or Monitor combustion temperature
A3
Al or A2 Do either of the following:
• Monitor temperature upstream
of the catalyst bed
• Install temperature monitors
upstream and downstream of
the catalyst bed, and monitor
the temperature difference
across the catalyst bed
Al or A2 Monitor condenser exit (product
side) temperature
Al or A2 Monitor each of the following:
• Total regeneration stream mass
or volumetric flow during
regeneration
• Temperature of carbon bed after
regeneration
• Temperature of carbon bed
within 15 minutes of
completing a cooling cycle
Al or A2 Monitor organic compound
concentration at adsorber outlet, or
Replace the carbon at a regular
predetermined interval that is less
than the time interval
corresponding to the maximum
design flow rate and organic
concentration in the gas stream
At this
frequency a' ...
Continuously
Continuously
Continuously
Continuously
Each regeneration
cycle
Daily, or at intervals
no greater than 20%
of the design carbon
replacement interval,
whichever is greater
At calculated
intervals
According to
this section of
the rule...
§63.143(e)(l)
and Table 13 to
subpart G
§63.143(e)(l)
and Table 13 to
subpart G
§63.143(e)(l)
and Table 13 to
subpart G
§63.143(e)(l)
and Table 13 to
subpart G
§63.143(e)(l)
and Table 13 to
subpart G
§63.143(e)(l)
and Table 13 to
subpart G
§63.143(e)(l)
and Table 13 to
subpart G
5-29
-------
TABLE 5-4. (cont'd)
If you use a ...
Flare
And you
comply with
option...
A4
Then you must ...
monitor for presence of flame at
the pilot light
At this
frequency a' ...
continuously (with
hourly records)
According to
this section of
the rule...
§63.143(e)(l)
and Table 13 to
subpart G
a As an alternative to any of the parameter monitoring requirements specified in this table, you may instead
continuously monitor the organic concentration at the outlet of the control device. [§63.143(e)(2)]
" You may request approval to monitor parameters other than those specified in this table. [§63.143(e)(3)]
How do I inspect my closed-vent systems?
Your inspection requirements for closed-vent systems that are used to transport organic vapors
from a waste management unit to a control device are the same as for closed-vent systems used
to transport vapors from a process vent to a control device. Therefore, see "How do I inspect my
closed-vent systems?" on page 3-19 in chapter 3 for more information. [§63.1366(h)(6) and (7)]
What are my compliance options for heat exchange systems?
If you have heat exchange systems (as defined on page 5-2), you have two compliance options.
These options require you to monitor for leaks and repair leaks that you detect, unless you are
exempt. The requirements are the same for both existing and new affected sources:
Exemptions [§63.104(a)(l) through (6)]
You are exempt from the heat exchange system compliance options if your system meets any of
the following six conditions:
• The minimum pressure on the cooling water side of the heat exchange system is at least 35
kPa greater than the maximum pressure on the process side
• There is an intervening cooling fluid, containing less than 5 percent by weight of HAP
listed in Table 4 to subpart F of part 63, between the process and the cooling water (and the
intervening fluid is not sent through a cooling tower or discharged).
• You have a once-through heat exchange system that is subject to a National Pollution
Discharge Elimination System (NPDES) permit with an allowable discharge limit of that is
either:
*• 1 ppm or less above influent concentration, or
*• 10 percent or less above the influent concentration.
5-30
-------
• You have a once-through heat exchange system that is subject to an NPDES permit that
includes all of the following:
*• requires monitoring of a parameter(s) or condition(s) to detect a leak of process fluids
into cooling water,
*• specifies or includes the normal range of the parameter or condition,
*• requires monitoring for the parameter selected as leak indicators no less frequently than
monthly for the first 6 months and quarterly thereafter, and
*• requires you to report and correct leaks to the cooling water when the parameter or
condition is outside the normal range.
• You have a recirculating heat exchange system that is used to cool process fluids that
contain less than 5 percent by weight of total HAP listed in Table 4 to Subpart F of part 63.
• You have a once-through heat exchange system that is used to cool process fluids that
contain less than 5 percent by weight of total HAP listed in Table 9 to Subpart G of part 63.
Option HE1: Monitor HAP or other representative substances [§63.104(b)]
Implement a monitoring program for one or more HAP or other representative substances (e.g.,
total HAP, total VOC, one or more speciated HAP, or other compounds) whose presence in
cooling water indicates a leak. Your monitoring program must be conducted as follows:
• You must monitor monthly for the first 6 months and quarterly thereafter.
• Monitoring of speciated HAP or total HAP refers to the following HAP:
*• HAP listed in Table 4 to Subpart F of part 63, if you have a recirculating heat exchange
system, or
*• HAP listed in Table 9 to Subpart G of part 63, if you have a once-through heat exchange
system.
• Use any EPA-approved method listed in 40
CFR part 136 as long as the method is sensitive YOU may use alternative methods upon
to concentrations as low as 10 ppm and you approval by the Administrator.
use the same method for both the entrance and
exit samples.
You must collect at least three sets of samples. The samples may be collected at the
entrance and exit of each heat exchange system or at locations where the cooling water
enters and exits each heat exchanger or combination of heat exchangers. Entrance and exit
locations are established as follows:
5-31
-------
If you take samples
at the...
Then the entrance is the
point at which...
And the exit is the point at
which...
According to this
section of the rule..
entrance and exit of a
recirculating system
the cooling water leaves
the cooling tower prior to
being returned to the
process equipment
the cooling water is
introduced to the cooling
tower after being used to
cool the process fluid
§63.104(b)(4)(i)
entrance and exit of a
once-through heat
exchange system
the cooling water enters
the plant or the PAI
process unit(s)
the cooling water exits the
plant or PAI process unit(s)
§63.104(b)(4)(ii)
entrance and exit of
each heat exchanger
or any combination
of heat exchangers
the cooling water enters
the individual heat
exchanger or group of heat
exchangers
the cooling water exits the
heat exchanger or group of
heat exchangers
§63.104(b)(4)(iii)
Calculate the mean entrance concentration and the mean exit concentration. Adjust the
concentration to correct for any makeup water or evaporative losses, if applicable.
You have detected a leak if both of the following are true:
the exit mean concentration is greater than the entrance
mean concentration based on the results of a one-sided
statistical procedure at the 0.05 level of significance, and
the difference between the means is at least 1 ppmw or
10 percent of the entrance value, whichever is greater
See chapter 7 for a sample
calculation.
Option HE2: Monitor using a surrogate indicator of leaks [§63104(c)]
Monitor one or more surrogate indicators (e.g., ion-specific electrode monitoring, pH, or
conductivity) or one or more process or other
conditions that indicate a leak. Under this
option, you must prepare and implement a
monitoring plan that describes the
procedures that you will use to detect process
fluid leaks into the cooling water. Include the
following in your plan:
You must maintain your current monitoring plan
onsite. If you ever revise your plan, you must also
maintain the most recent superceded plan for at least
5 years from the date of its creation (maintain onsite
for at least 6 months).
Description of the parameter(s) or condition(s) to be monitored.
Explanation of how the selected parameter(s) or condition(s) will reliably indicate a leak.
The parameter level(s) or condition(s) that constitute a leak, including supporting data and
calculations.
Note: Monitoring must be sufficiently sensitive to determine the range of parameter levels or conditions when
the system is not leaking.
5-32
-------
• How frequently you will monitor.
Note: Frequency must be at least monthly during the first 6 months and at least quarterly thereafter.
• The records you will maintain.
You have a leak when the monitored parameter(s) or condition(s) exceed the threshold specified
in your monitoring plan.
Note: If you identify a leak using a method that is not described in your plan, and the method(s) in your plan
could not detect the leak, you must revise your plan and document the basis for the changes. The revision must
be completed within 180 after you discover the leak.
Leak repair [§63.104(d) and (e)]
After you detect a leak, you must:
• Repair the leak as soon as practical (but no later than 45 calendar days after you determine
that you have a leak, unless a delay of repair is allowed), and
• Within 7 calendar days after repairing the leak or startup (whichever is later), confirm that
the heat exchange system has been repaired.
A delay of repair is allowed if:
• Equipment is isolated from the process, or
Reporting requirements for a delay of repair are
• Repair is technically infeasible without a described in Table 5-7 (page 5-40).
shutdown and any one of the following
conditions also apply:
*• a planned shutdown is scheduled within the next two months after you determine a delay
of repair is necessary,
*• a shutdown for repair would cause greater emissions than the potential emissions from
delaying repair, or
Note: You must calculate emissions according to procedures described in §63.104(e)(2)(i)(A) and (B).
*• necessary parts or personnel were not available (for up to a maximum of 120 calendar
days).
What records must I keep for my wastewater systems?
Your recordkeeping requirements for wastewater systems and heat exchange systems are
presented in Table 5-5 (pages 5-34 through 5-37) and in Chapter 8.
5-33
-------
TABLE 5-5. Recordkeeping Requirements for Wastewater Systems and Heat Exchange Systems
Categories of
records are...
Then for each...
You must keep records of...
According to this
section of the rule..
identification Group 2 wastewater stream all of the following: §63.147(b)(8)
records (that is not complying with • process unit identification and description of process unit
treatment option T3F or • stream identification code
T3H) • concentration of Table 9 HAP in ppmw, including documentation of the
methodology used to determine the concentration
• flow rate in liters/min
wastewater stream that you how process knowledge was used to determine the annual average §63.147(f)
determine to be Group 2 concentration and/or annual average flow rate
based on process knowledge
of the annual average flow
rate and/or HAP
concentration
wastewater stream the notice sent to the treatment operator stating that the wastewater stream or §63.147(a)
Y1 transferred offsite for residual contains organic HAP that must be managed and treated in accordance
-&. treatment with subpart MMM
emission wastewater tank • the occurrence of each required inspection (e.g., for leaks, improper work §63.147(b)(l)
suppression records practices, and/or control equipment failures, depending on the emission
suppression compliance option)
• all of the following for each seal gap measurement (Option WT2 or WT3): §63.147(b)(3)
*• date of the measurement
*• raw data
*• calculations of width and area of each gap and total gap area
• all of the following associated with each decision to use an extension when §63.147(b)(6)
you determine it is unsafe to perform seal gap measurements or you delay
repair:
• description of the failure
*• documentation that alternate storage capacity is unavailable
*• a schedule of actions to complete repair or empty the vessel as soon as
possible
-------
TABLE 5-5. (cont'd)
Categories of
records are...
Then for each...
You must keep records of...
According to this
section of the rule..
surface impoundment the occurrence of each required inspection for improper work practices and §63.147(b)(l)
control equipment failures
container the occurrence of each required inspection for improper work practices and §63.147(b)(l)
control equipment failures
individual drain system the occurrence of each required inspection for improper work practices and §63.147(b)(l)
control equipment failures
oil-water separator • the occurrence of each required inspection for improper work practices and §63.147(b)(l)
control equipment failures
• all of the following for each seal gap measurement: §63.147(b)(3)
*• date of measurement
^ *• raw data
w *• calculations of gap width and total gap area
waste management unit all of the following for each delay of repair due to unavailability of parts: §63.147(b)(7)
• description of the failure
• reason additional time was necessary
• date when repair was completed
closed-vent system, cover, inspections for leaks, and results of monitoring/inspection of bypass lines, as §63.1367(f)
fixed roof, or enclosure described in "What records must I keep?" in Chapter 8
Control device thermal incinerator, • continuously monitored parameter data (see Table 5-4) §§63.147(b)(5),
records catalytic incinerator, • daily averages of continuously monitored parameter data 63.147(d), and
condenser, or boiler or 63.1367(b)(l)
process heater <44 MW
flare the times and duration of all periods when there is no pilot flame §63.147(d)(l)
-------
TABLE 5-5. (cont'd)
Categories of
records are...
Then for each...
You must keep records of...
According to this
section of the rule..
regenerative carbon all of the following for each regeneration cycle: §63.147(d)(2)
adsorber • total regeneration stream mass flow
• temperature carbon bed at end of regeneration
• temperature to which the carbon bed is cooled within 15 minutes of
completing the cooling cycle
nonregenerative carbon • all of the folio wing if you use anorganic monitoring device: §63.147(d)(3)
adsorber »• how the monitoring frequency was determined
*• when the organic concentration was measured
*• when the carbon was replaced
• all of the following if you replace the carbon at a predetermined interval
*• how the carbon replacement interval was determined
*• when the carbon was replaced
^ boiler and process heater any change in the location at which the vent stream is introduced into the flame §63.147(c)
01 zone
control device that you • the continuously monitored organic concentration data §§63.147(b)(5) and
monitor using an organic • the daily average of the organic concentration 63.1367(b)(l)
monitor rather than
operating parameter
monitors
Treatment unit treatment unit other than a • information and actions as approved by the Administrator § §63.147(b)(4) and
records steam stripper • each measurement of any operating parameter data 63.1367(b)(l)
steam stripper all of the following continuously recorded parameter data: § §63.147(b)(5) and
• steam flow rate 63.1367(b)(l)
• wastewater feed mass flow rate
• wastewater feed temperature or column temperature
-------
TABLE 5-5. (cont'd)
Categories of
records are...
Then for each...
You must keep records of...
According to this
section of the rule..
Heat exchange
system records
heat exchange system
monitoring data that indicate each leak
date when each leak was detected
information regarding leaks detected by procedures not in your monitoring
plan, if you comply with option HE2
basis for any determinations that monitoring results are due to a condition
other than a leak
dates of efforts to repair leaks
method or procedure used to confirm repair of a leak
date repair was confirmed
§§63.104(f)(l)and
63.1362(f)
-------
What reports must I submit for my wastewater systems?
Chapter 8 describes the notifications and reports that you may need to submit, and the dates
when they must be submitted. Most of the information about wastewater systems that you will
need to submit must be included in the following reports:
• notification of compliance status report
• periodic reports
Notification of compliance status report
You must include information related to wastewater systems in your notification of compliance
status report as described in Table 5-6.
TABLE 5-6. Information on Wastewater Systems to Include in the Notification of
Compliance Status Reporta
For each...
Include all of the following information in your notification of
compliance status report...
According to this
section of the rule.
Group 2 wastewater all of the identification records listed in Table 5-5
stream
§63.146(b)(l)
wastewater stream
that contains Table 9
HAP
process unit identification
description of process unit
wastewater stream identification
Group status (Group 1 or Group 2)
statement that you designated the stream as Group 1 or both
of the following:
* wastewater stream flowrate
* concentration of Table 9 HAP
treatment compliance option used
type of treatment unit(s)
waste management unit identification
intended control device for vented streams
§63.146(b)(2)and
Table 15 to subpart G
treatment unit that
receives, manages, or
treats a Group 1
wastewater stream or
residual
treatment unit identification
description of the treatment unit
identification of all wastewater streams treated by the
treatment unit
parameters to be monitored to demonstrate ongoing
compliance
§63.146(b)(4)and
Table 17 to subpart G
waste management
unit that receives or
manages a Group 1
wastewater stream or
residual
identification of the waste management unit
description of the was management unit
identification of each wastewater stream received or
managed by the waste management unit (Group 1 and
Group 2)
§63.146(b)(5)and
Table 18 to subpart G
5-38
-------
TABLE 5-6. (cont'd)
For each...
Include all of the following information in your notification of
compliance status report...
According to this
section of the rule...
residual removed
from a Group 1
wastewater stream
identification of the residual
description of the residual
identification of the wastewater stream from which the
residual is removed
treatment unit from which the residual originates
fate of the residual (i.e., sold, returned to process, returned
to waste management unit or treatment unit, or > 99 percent
destruction of the Table 9 HAP using nonbiological unit)
all of the following if you reduce the Table 9 HAP by > 99
percent:
* identification of device used
* description of device used
* efficiency of device, including information to substantiate
the stated efficiency
§63.146(b)(6)and
Table 19 to subpart G
flare used to comply
with an emission
suppression
compliance option
flare design
results of initial compliance determination (visible emissions
readings, heat content determinations, flow rate
measurements, and exit velocity determination)
times and durations of all periods during the initial
compliance determination when the pilot flame was absent
or the monitor was not operating
§63.146(b)(7)(i)
non-flare control
device used to
comply with an
emission suppression
compliance option
the operating range for each parameter to be monitored
either of the following from the initial compliance
determination:
* the design evaluation, including supporting
documentation
* the results of the performance test (operating ranges for
process and control parameters, value of parameters being
monitored, and applicable supporting calculations)
§63.146(b)(7)(ii)
biological treatment
unit
the operating range for parameters to be monitored as
approved by the Administrator
results of the initial measurements of the parameters
approved by the Administrator and any applicable
supporting calculations
§63.146(b)(8)(i)
steam stripper that
is not a design steam
stripper
the operating range for the parameters to be monitored as listed §63.146(b)(2)(i)
in Table 5-5
5-39
-------
TABLE 5-6. (cont'd)
Include all of the following information in your notification of According to this
For each... compliance status report... section of the rule.
nonbiological, non-
steam stripper
treatment unit, and
any steam stripper
for which you
request approval to
monitor parameters
other than those
specified in
Table 5-5
the operating range of parameters to be monitored
§63.146(b)(80(ii)
waste management
unit or treatment
unit used to comply
with a treatment
compliance option
either of the following used to demonstrate ongoing
compliance:
• design evaluation, including supporting documentation
• results of the performance test, including all of the
following:
* operating ranges of parameters
* value of each parameter being monitored
* applicable supporting calculations
§63.146(b)(9)
1 The reporting requirements in this table for treatment units do not apply to design steam strippers or RCRA units.
Periodic report
You must include the information about wastewater systems and heat exchange systems in your
periodic reports as described in Table 5-7.
TABLE 5-7. Information on Wastewater Systems and Heat Exchange Systems to Include
in Your Periodic Report
If you have...
For which you...
According to this
Then include the following information in your section of the
periodic reports... rule...
a waste
management unit
that receives,
manages, or treats
a Group 1
wastewater stream
or residual
identified a
control equipment
failure during an
inspection
date of the inspection §63.146(c)
identification of the waste management with
the failure
description of the failure
description of the nature of the repair
date of repair
5-40
-------
Table 5-7. (cont'd)
If you have...
For which you...
Then include the following information in your
periodic reports...
According to this
section of the
rule...
a wastewater tank used a 30-day
complying with
option WT3
extension to
continue using the
tank more than 45
days after
determining it is
unsafe to inspect
or perform seal
gap
measurements
explanation of why it was unsafe to perform §63.146(g)
the inspection or seal gap measurement
statement that alternate storage capacity was
unavailable
a schedule of actions to ensure the tank is
emptied as soon as possible
a wastewater tank
that failed an
inspection for
improper work
practices or control
equipment failures
use a 30-day
extension to
continue using the
tank beyond 45
days after
detecting the
defect
description of the failure
statement that alternate storage capacity was
not available
a schedule of actions to ensure the control
equipment will be repaired or the vessel will
be emptied as soon as possible
§63.146(g)
a closed-vent
system with a
bypass line
a thermal
incinerator,
catalytic
incinerator, boiler
or process heater,
or condensera
a flarea
comply with any
emission
suppression
option
monitor operating
parameters to
comply with
option Al, A2, or
A3b
comply with
option A4b
either of the following:
• times and durations of all periods when the
vent stream is diverted through the bypass or
the flow monitor is not working
• results of monthly inspections that show the
bypass line valve has moved to the diverting
position or the seal has been changed
• daily average of continuously monitored
parameter that is outside its preestablished
range0
• list all days when insufficient monitoring
data were collected
• duration of each period when monitoring
data were not collected for an excursion, as
defined in §63. 1366(b)(7)
duration of all periods when all pilot flames are
absent
§63.1368(g)(2)(iii)
§63.146(e)(l),
Table 20 to subpart
G, and
§63.1368(g)(2)(ii)
§63.146(e)(l)and
Table 20 to subpart
G
a regenerative
carbon adsorbera
monitor operating
parameters to
comply with
option Al or A2"
identify all regeneration cycles when a
monitored parameter is outside its
preestablished range0
list all operating days when insufficient
monitoring data are collected
duration of each period when monitoring
data are not collected for an excursion, as
defined in §63.1366(b)(7)
§63.146(e)(l)and
Table 20 to subpart
G
5-41
-------
Table 5-7. (cont'd)
If you have...
any control
devicea
a biological
treatment unit
a steam stripper
a treatment unit
other than a
biological unit or
steam stripper
a control device or
treatment unit
a heat exchange
system
For which you...
use an organic
monitoring device
comply with
option T3E, T3F,
T3G, orT3Hd
comply with
option Tl, T2,
T3A, T3B, or
T3Ed
comply with
option Tl, T3A,
T3B, T3C, T3D,
or T3Ed
you request
approval of
monitoring
procedures not
specified in
subpart MMM
(any treatment
option)
have invoked the
delay of repair
provisions in
§63.104(e)
Then include the following information in your
periodic reports...
monitoring results for each operating day
during which the daily average concentration
was outside the preestablished range0
results of measurements that indicate the
biological treatment unit was outside of the
preestablished range0
the monitoring results for each operating day
when the daily average value of any monitored
parameter is outside the preestablished range0
the monitoring results for each operating day
during which the daily average value of any
monitored parameter approved by the
Administrator is outside the approved range
information as specified by the Administrator
• indication that a leak is present,
• date the leak was detected,
• identify whether the leak has been repaired,
• reason(s) for the delay of repair (note that if
According to this
section of the
rule...
§63.146(e)(2)
§63.146(d)(l)
§63.146(d)(2)
§63.146(d)(3)
§63.146(f)
§§63.104(f)(2)and
63.1368(1)
the reason for the delay is that you estimated
that the shutdown for repair would cause
more emissions than from delaying repair,
you must include the emission estimation
calculations)
if the leak remains unrepaired, identify the
expected date of repair, and
if you repaired the leak, identify the date the
leak was successfully repaired.
a You must include the specified information in your periodic report only if the conditions specified in
S63.1368(g)(2)(ii) are met.
" Each compliance option is described in the section "What are my compliance options for air pollution control
devices?" beginning on page 5-9.
c You determine the preestablished range as part of your initial compliance demonstration and document the values
in your notification of compliance status report or operating permit.
d Each treatment option is described in the section "What treatment compliance options do I have for my wastewater
streams?" beginning on page 5-10.
5-42
-------
Checklists for Wastewater System Inspections
Facility Name:
Facility Location:
Facility TRI ID #:
Inspector:
Date:
The table below explains which inspection checklists you should use for waste management
units and emission suppression equipment that manage, store, or treat Group 1 wastewater
streams.
If you use a ... That is controlled using ...
Then use these checklists ...
Starting on
page ...
wastewater
tanka
a fixed roof with a closed-vent
system routed to a control device
(Option WT1)
checklists 1 and 6 in this chapter and
see next table for checklists specific
to the control device
5-45 and 5-56
an external floating roof (Option
WT3)
checklist lin this chapter and section
A of checklist 3 in Chapter 4
a fixed roof with an internal floating
roof (Option WT2)
checklist 1 in this chapter and section
A of checklist 2 in Chapter 4
an external floating roof converted to
an internal floating roof (Option
WT2)
checklist 1 in this chapter and section
A of checklist 4 in Chapter 4
5-45 and 4-25
5-45 and 4-21
5-45 and 4-22
a fixed roof (Option WT4)
checklist 1 in this chapter
5-45
5-46 and 5-56
surface
impoundmenta
a cover with a closed-vent system
routed to a control device (Option
SI)
checklists 2 and 6 in this chapter and
see next table for other checklists
a floating flexible membrane cover
(Option S2)
checklists 2 and 6 in this chapter
5-46 and 5-56
contained
a cover (Option Cl or C2)
checklists 3 and 6 in this chapter
a cover and enclosure with a closed-
vent system to route emissions to a
control device (Option C3)
checklists 3 and 6 in this chapter and
see next table for checklists specific
to the control device
5-48 and 5-56
5-48 and 5-56
individual a cover and, if vented, routed to a
drain system process or through a closed-vent
system to a control device (Option
Dl)
checklists 4 and 6 in this chapter and
see next table for checklists specific
to the control device
5-50 and 5-56
water seal controls or a tightly fitting
cap or plug for drains, tightly fitting
solid covers for junction boxes (or
covers vented to a control device) or
closed sewer lines (Option D2)
checklist 4 in this chapter (and
checklist 6 for any vented covers)
5-50 and 5-56
5-43
-------
If you use a ... That is controlled using ...
Then use these checklists ...
Starting on
page ...
oil-water
separator
a fixed roof and closed-vent system
routed to a control device (Option
01)
checklists 5 and 6 in this chapter and 5-53 and 5-56
see next table for checklists specific
to the control device
a floating roof (Option O2)
checklist 5 in this chapter
5-53
a You are exempt from the emission suppression requirements if the waste management unit is also a biological
treatment unit that meets the biodegradation requirements of treatment option T3 G or T3H. [§63.13 8(a)(3)]
The table below explains which checklists you should use for control devices:
The wastewater system emission streams are conveyed by a Then use the following
closed-vent system to the following control device ... checklists from Chapter 3:
Starting on pages.
a scrubber 2 and 3 3-24 and 3-28
a condenser 2 and 4 3-24 and 3-30
a regenerative carbon adsorber 2 and 5 3-24 and 3-3 2
a nonregenerative carbon adsorber 2 and 6 3-24 and 3-3 4
a thermal incinerator 2 and 7 3-24 and 3-3 5
a catalytic incinerator 2 and 8 3-24 and 3-37
a boiler or process heater with a design heat input of 2 and 9 3-24 and 3-39
<44 megawatts or for which the emission stream is not
introduced with the primary fuel
a flare 2 and 11 3-24 and 3-43
The table below identifies the checklists you should use for treatment units:
Then use these checklists
For the following treatment units... in this chapter: Starting on page.
Steam stripper (including design steam stripper) 7 5-58
Biological treatment unit 8 5-60
Other types of treatment units 8 5-60
Use checklist 9 (page 5-61) for heat exchange systems.
5-44
-------
Checklist 1: Requirements for all wastewater tanks (emission suppression compliance options
WT1, WT2, WT3, and WT4)a
Facility Name:
Facility Location:
Facility TRI ID #:
Inspector:
Date:
Note: A "yes" response to a question in this checklist means compliance with that requirement, and a "no"
response means noncompliance with the requirement. If the requirement is not applicable, indicate "N/A" in the
comments column.
A. Monitoring and Inspection Requirements
Comments
1. Are all openings (e.g., access hatches, sampling ports, and gauge D Yes
wells) closed (e.g., covered by a lid) except when in use (e.g., it is in
use during wastewater sampling or removal or for equipment
maintenance, inspection, or repair) (Option WT1, WT2, WT3, or
WT4)? §63.133(f)
B. Recordkeeping and Reporting Requirements
DNo
Comments
1. Do you keep all records for at least 5 years? §63,1367(a)
DYes
DYes
DNo
DNo
2. Do you record the occurrence of each semiannual visual inspection
of wastewater tanks for improper work practices (Option WT1,
WT2, WT3, or WT4)? §63.147(b)(l)
3. Do you record the occurrence of each semiannual visual inspection
of wastewater tanks for control equipment failures (Option WT1,
WT2, orWT3)? §63.147(b)(l)
DYes
DNo
4. If your wastewater tank is equipped with a fixed roof and emissions
are vented through a closed-vent system to a control device (Option
WT1), do you record the occurrence of each semiannual visual
inspection for leaks? §63.147(b)(1)
DYes
DNo
5. If your wastewater tank is equipped with an IFR or EFR (Option
WT2, or WT3), do you record the occurrence of each periodic
inspection of the seals? §63.147(b)(1)
DYes
DNo
6. For each inspection of the wastewater tank during which a control
equipment failure was identified, including detached seals for an IFR
or EFR, do you record and report the following in your next Periodic
Report (Option WT1, WT2, or WT3): §63.146(c)
• Date of the inspection
• Identification of the wastewater tank having the failure?
• Description of the failure?
• Description of the nature of the repair?
• Date the repair was made?
DYes
DYes
DYes
DYes
DYes
DNo
DNo
DNo
DNo
DNo
a The emission suppression compliance options for wastewater tanks are described in the section "What are my
emission suppression compliance options?" beginning on page 5-4.
5-45
-------
Checklist 2: Requirements for all surface impoundments (emission suppression compliance
options SI and S2)a
Facility Name:
Facility Location:
Facility TRI ID #:
Inspector:
Date:
Note: A "yes" response to a question in this checklist means compliance with that requirement, and a "no"
response means noncompliance with the requirement. If the requirement is not applicable, indicate "N/A" in the
comments column.
A. Monitoring and Inspection Requirements Comments
Note: Answer questions in item " 1" if you comply with the requirements
to cover surface impoundments in §63.134(b)(l). Answer questions in
item "2" if you comply with the requirements for a floating flexible
membrane cover in §63.134(b)(2).
1. If you use a cover on a surface impoundment (Option S1), are all of
the following requirements met: §63.134(b)(l), (c)(l), and (c)(2)
• Are all access hatches and other openings closed except when in D Yes D No
use (e.g., it is in use during wastewater sampling or removal or
for equipment maintenance, inspection, or repair)?
• Is all control equipment functioning properly (e.g., seals, joints, D Yes D No
lids, covers, and doors are not cracked, gapped, or broken)?
• Is the cover used at all times when a Group 1 wastewater or D Yes D No
residual is in the surface impoundment, except during removal of
treatment residuals or closure of the surface impoundment?
2. If you use a floating flexible membrane cover on a surface
impoundment (Option S2), are all of the following requirements met:
§63.134(b)(2)
• is the cover floating on the liquid surface over the entire area of D Yes D No
the liquid surface?
• is the floating flexible membrane cover made out of either of the D Yes D No
following:
* high density polyethylene with a thickness of at least 2.5
millimeters, or
* a material that has an equivalent organic permeability and
integrity for the intended service life of the floating cover?
• is the floating flexible membrane cover free of visible cracks, D Yes D No
holes, gaps, or other open spaces between cover section seams or
between the cover and its foundation mountings?
• does each opening in the cover have a closure device that when D Yes D No
closed leaves no visible cracks, holes, gaps, or other open spaces?
• is each closure device closed except as allowed in D Yes D No
§63.134(b)(2)(vii)?
5-46
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Checklist!: (cont'd)
Requirements for all surface impoundments
A. Monitoring and Inspection Requirements
Comments
• are closure devices made of suitable materials to minimize
exposure of organic HAP to the atmosphere, considering factors
specified in §63.134(b)(2)(vi)?
• if the floating membrane cover has emergency drains for storm
water removal, are they equipped with either of the following:
* a slotted membrane fabric cover that covers at least 90
percent of the area of the opening, or
* a flexible fabric seal?
B. Recordkeeping and Reporting Requirements (Option SI or S2)
DYes
DYes
DNo
DNo
3. Do you record the occurrence of each semiannual visual inspection
of surface impoundments for control equipment failures?
§63.147(b)(l)
DYes
DNo
Comments
1.
2.
Do you keep all records at least 5 years? §63. 1367 (a)
Do you record the occurrence of each semiannual visual inspection
of surface impoundments for improper work practices?
§63.147(b)(l)
DYes
DYes
DNo
DNo
4. For each inspection of the surface impoundment during which a
control equipment failure was identified, do you record and report
the following in your next Periodic Report: §63.146(c)
• Date of the inspection
• Identification of the surface impoundment having the failure?
• Description of the failure?
• Description of the nature of the repair?
• Date the repair was made?
DYes
DYes
DYes
DYes
DYes
DNo
DNo
DNo
DNo
DNo
a The emission suppression compliance options for surface impoundments are described in the section "What are my
emission suppression compliance options?" beginning on page 5-4.
5-47
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Checklist 3: Requirements for all containers (emission suppression compliance options Cl, C2,
and C3)a
Facility Name:
Facility Location:
Facility TRI ID #:
Inspector:
Date:
Note: A "yes" response to a question in this checklist means compliance with that requirement, and a "no"
response means noncompliance with the requirement. If the requirement is not applicable, indicate "N/A" in the
comments column.
A. Monitoring and Inspection Requirements Comments
1. For containers with capacity greater than or equal to 0.1 but less
than or equal to 0.42 cubic meters, do you meet all of the following
requirements (Option Cl or C2): §63.135(b)(2) and (3)
• do the containers have covers? D Yes D No
• are the covers and all openings closed (e.g., covered by a lid) D Yes D No
except when in use (e.g., an opening is in use during filling,
removal, inspection, sampling, or pressure relief events related to
safety)?
• is all control equipment functioning properly (e.g., covers and D Yes D No
doors are not cracked, gapped, or broken)?
• either of the following: D Yes D No
* do the containers meet the DOT specifications and testing
requirements (Option C2)?
*• do you inspect the covers for leaks as specified in
§63.1366(h) (Option Cl)?
2. For containers with capacity greater than 0.42 cubic meters, do you
meet all of the following requirements (Option Cl): §63.135(b)(l),
(b)(3), and(c)
• do the containers have covers? D Yes D No
• do you fill the containers using a submerged fill pipe that does D Yes D No
not extend more than 6 inches or within two fill pipe diameters of
the bottom of the containers?
• are the covers and all openings closed (e.g., covered by a lid) D Yes D No
when not in use (e.g., an opening is in use if it is used for the
submerged fill pipe, wastewater removal, inspection, sampling, or
pressure relief events related to safety)?
• is all control equipment functioning properly (e.g., covers and D Yes D No
doors are not cracked, gapped, or broken)?
5-48
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Checklist 3: (cont'd)
Requirements for all containers
A. Monitoring and Inspection Requirements
Comments
3. For containers that have a capacity greater than or equal to 0.1 cubic D Yes
meters, are used to treat a Group 1 wastewater stream or residual,
and it is necessary that the containers be open during treatment, are
the containers located within an enclosure that has a closed-vent
system to transport emissions to a control device (Option C3)?
§63.13 5(d)
B. Recordkeeping and Reporting Requirements (Option Cl, C2, or C3)
DNo
3. Do you record the occurrence of each semiannual visual inspection
of containers for control equipment failures? §63.147(b) (1)
DYes
DNo
Comments
1.
2.
Do you keep all records for at least 5 years? §63. 1367(a)(l)
Do you record the occurrence of each semiannual visual inspection
of containers for improper work practices? §63. 147(b)(l)
DYes
DYes
DNo
DNo
4. For each inspection during which a control equipment failure was
identified, do you record and report the following in your next
Periodic report: §63.146(c)
• Date of the inspection
• Identification of the container having the failure?
• Description of the failure?
• Description of the nature of the repair?
• Date the repair was made?
DYes
DYes
DYes
DYes
DYes
DNo
DNo
DNo
DNo
DNo
5. Do you have a record of the capacity of each container maintained at D Yes D No
your facility? §63.1368(0(1)
a The emission suppression compliance options for containers are described in the section "What are my emission
suppression compliance options?" beginning on page 5-4.
5-49
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Checklist 4: Requirements for all individual drain systems (emission suppression compliance
options Dl and D2)a
Facility Name:
Facility Location:
Facility TRI ID #:
Inspector:
Date:
Note: A "yes" response to a question in this checklist means compliance with that requirement, and a "no"
response means noncompliance with the requirement. If the requirement is not applicable, indicate "N/A" in the
comments column.
A. Monitoring and Inspection Requirements Comments
Note: Answer only the questions in item " 1" if you comply with the
requirements to cover each opening in an individual drain system in
§63.136(b) through (d). Answer only questions in items "2" through "4"
if you comply with the alternative requirements for drains, junction boxes,
and sewers in §63.136(e) through (g).
1. If you cover each opening in your individual drain system (with or
without a closed-vent system to route emissions to a control device
or to a process), do you meet all of the following requirements
(Option Dl):
• is the individual drain system designed and operated to segregate D Yes D No
the vapors within the system from other drain systems and the
atmosphere? §63.136(b)(5)
• are the cover and all openings (e.g., access hatches, sampling D Yes D No
ports, and gauge wells) kept closed except when in use (e.g., an
opening is in use during sampling, removal, or equipment
maintenance, inspection, or repair)? §63.136(b)(l) and (c)(l)
• are the cover and all openings maintained in good D Yes D No
condition? §63.136(b)(5)
1. If you do not comply with the cover requirements described in item
"1", do you meet all of the following requirements for drains
(Option D2):
• is each drain equipped with either water seal controls (e.g., p- D Yes D No
trap, s-trap) or a tightly-fitting cap or plug? §63.136(e)(l)
• for each drain equipped with a water seal, is water always present D Yes D No
in the water seal? §63.136(e)(l)(i)
5-50
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Checklist 4: (cont'd)
Requirements for all individual drain systems
A. Monitoring and Inspection Requirements Comments
• if a water seal is used on a drain receiving a Group 1 process D Yes D No
wastewater stream, do you meet either of the following
requirements: §63.136(e)(l)(ii)
*• does the drain pipe discharging the wastewater extend below
the liquid surface in the water seal, or
* is a flexible shield (or other enclosure which restricts wind
motion) installed that encloses the space between the pipe
discharging the wastewater and the drain receiving the
wastewater?
3. If you do not comply with the cover requirements described in item
"1", do you meet all of the following for junction boxes (Option D2):
• are junction boxes equipped with tightly fitting solid covers D Yes D No
(vented or unvented) that are free of gaps, cracks, or holes?
§63.136(e)(2)
• if the covers are vented, do you meet either of the following: D Yes D No
*• is the vent pipe connected to a closed-vent system that
transports emissions to a process or control device, or
§63.136(e)(2)(i)
*• do you meet all of the following: §63.136(e)(2)(ii)
* is the vent pipe at least 90 centimeters in length?
* is the diameter of the vent pipe less than 10.2
centimeters?
* is a water seal installed at the entrance or exit of the
junction box?
Note: the design requirements in §63.136(e)(2)(ii) are
allowed as an alternative to venting to a process or control
device only if the junction box is filled and emptied by
gravity flow or it is operated with no more than slight
fluctuations in the liquid level.
4. If you do not comply with the cover requirements described in item
" 1", do you meet both of the following for your sewers (Option D2):
§63.136(e)(3)
• are your sewer lines covered or enclosed? D Yes D No
• are the covers and enclosures free of gaps, cracks, or other D Yes D No
openings to the atmosphere?
5-51
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Checklist 4: (cont'd)
Requirements for all individual drain systems
B. Recordkeeping and Reporting Requirements Comments
Note: Answer questions in items "1" through "4" if you comply with the
requirements to cover each opening in an individual drain system in
§63.136(b) through (d). Answer questions in items "1" and "5" if you
comply with the alternative requirements for drains, junction boxes, and
sewer lines in §63.136(e) through (g).
1. Do you keep all records for at least 5 years (Option D1 or D2)? D Yes D No
§63.1367 (a)
1. Do you record the occurrence of each semiannual visual inspection D Yes D No
of the individual drain systems for improper work practices (Option
Dl)? §§63.136(c)_and63.147(b)(l)_
3. Do you record the occurrence of each semiannual visual inspection D Yes D No
of the individual drain systems for control equipment failures
(OptionDl)? §§63.136(c) and63.147(b)(l)
4. For each inspection during which a control equipment failure was
identified, do you record and report the following in your next
periodic report (Option Dl): §§63.136(c) and63.146(c)
*• date of the inspection
• identification of the individual drain system having the failure?
* description of the failure?
* description of the nature of the repair?
* date the repair was made?
DYes
DYes
DYes
DYes
DYes
DNo
DNo
DNo
DNo
DNo
5. If you comply with the separate requirements for drains, junction
boxes, and sewer lines, do you keep all of the following records
(Option D2):
• documentation of the occurrence of each semiannual inspection D Yes D No
of drains to ensure that caps or plugs are in place and properly
installed? §§63.136(f)(l) and63.147(b)(l)
• documentation of the occurrence of each semiannual verification D Yes D No
of water supply to the drain? §§63.136(e)(l)(ii) and 63.146(c)
• documentation of the occurrence of each semiannual inspection D Yes D No
of junction boxes to ensure that there are no gaps, cracks, or other
holes in the cover? §§63.136(J)(2) and63.147(b)(l)
• documentation of the occurrence of each semiannual inspection D Yes D No
of the unburied portion of each sewer line to ensure that there are
no cracks or gaps that could result in air emissions?
§§63.136(f)(3) and63.147(b)(l)
a The emission suppression compliance options for individual drain systems are described in the section "What are
my emission suppression compliance options?" beginning on page 5-4.
5-52
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Checklist 5: Requirements for all oil-water separators (emission suppression compliance options
Ol and O2)a
Facility Name:
Facility Location:
Facility TRI ID #:
Inspector:
Date:
Note: A "yes" response to a question in this checklist means compliance with that requirement, and a "no"
response means noncompliance with the requirement. If the requirement is not applicable, indicate "N/A" in the
comments column.
A. Monitoring and Inspection Requirements Comments
Note: Answer questions in items "1" through "8" if you comply with the
requirements for Option O2 to use a floating roof in §63.137(a)(2).
Answer questions in items "8" and "9" if you comply with the
requirements for Option Ol to use a fixed roof and closed-vent system in
§63.137(a)(l).
1. Is the floating roof is resting on the liquid surface of the stored D Yes D No
material, except during abnormal conditions (i.e., low flow rate)?
§§63.137(e)(l)(i) and 60.693-2(a)(3)
1. Is the floating roof is in good condition (i.e., free of defects such as D Yes D No
corrosion and pools of standing liquid)? §63.137(e)(l)(ii)
3. Is a secondary seal installed above the primary seal? D Yes D No
4. Does the secondary seal meet all of the following requirements:
• is the seal and seal fabric free of holes, tears, an other openings? D Yes D No
§63.137(e)(l)(iv)
• is the seal continuously attached along the edge of the floating D Yes D No
deck? §63.137(e)(l)(iii)
• does the seal completely cover the space between the edge of the
floating roof and the oil-water separator wall, except as allowed
by both of the following: §§63.137(e)(l)(vi) and
60.693-2(a)(l)(ii)
*• the total gap area between the separator wall and the D Yes D No
secondary seal does not exceed 6.7 square centimeters per
meter of the separator wall perimeter?
* the maximum gap width between the separator wall and the D Yes D No
seal does not exceed 1.3 centimeters at any point?
5. Does the primary seal meet all of the following requirements:
• is the primary seal a liquid-mounted seal or a mechanical shoe D Yes D No
seal? §60.693-2(a)(l)(i)
• is the seal fabric, seal envelope, or shoe (if a metallic shoe is D Yes D No
used) free of holes, tears, and other openings? §63.137(e)(l)(iv)
5-53
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Checklist 5: (cont'd)
Requirements for oil-water separators
A. Monitoring and Inspection Requirements
Comments
if the primary seal is a liquid-mounted seal (e.g., foam or liquid- D Yes D No
filled seal), is the seal in contact with the liquid between the wall
of the oil-water separator and the floating roof?
§60.693-2(a)(i)(A)
is the seal continuously attached along the edge of the floating D Yes D No
deck? §63.137(e)(l)(iii)
does the primary seal form a continuous closure that completely
covers the annular space between the wall of the oil-water
separator and the edge of the floating roof, except as allowed by
both of the following: §§63.137(e)(l)(v) and 60.693-2(a)(l)(i)(B)
and (C)
*• is the total area of gaps between the wall of the oil-water D Yes D No
separator and the primary seal are less than 67 square
centimeters per meter of the separator wall perimeter?
*• the maximum gap width between the wall of the oil-water D Yes D No
separator and the seal is less than 3.8 centimeters at all
points?
6. If the floating roof is equipped with one or more emergency roof
drains for removal of stormwater, is each emergency roof drain fitted
with either of the following: §60.693-2(a) (4)
• a slotted membrane fabric cover that covers at least 90 percent of
the drain opening area, or
• a flexible fabric sleeve seal?
DYes
DNo
7. Are all openings in the floating roof equipped with a gasketed cover,
seal, or lid, which is kept closed at all times, except during
inspections and maintenance? §60.693-2(a)(2)
DYes
DNo
Are gaskets, joints, lids, covers, and doors in good condition (i.e., not D Yes
cracked, gapped, or broken)? §63.137(e)(l)(vii)
9. Are all openings kept closed except when in use (e.g., an opening is
in use during sampling, removal of material, inspection,
maintenance, or repair)? §63.137(b)(l)(ii) and (d)
B. Recordkeeping and Reporting Requirements
DYes
DNo
DNo
Comments
1. Do you keep all records for at least 5 years (Option Ol or O2)?
§63.1367 (a)
DYes
DNo
2. If you use a floating roof (Option 2), do records indicate all of the
following:
• that seal gap measurements are performed annually for the
secondary seal? §§63.137(c)(2) and63.147(b)(l)
• that seal gap measurements are performed every 5 years for the
primary seal? §§63.137(e)(l) and 63.147(b)(l)
DYes
DYes
DNo
5-54
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Checklist 5: (cont'd)
Requirements for oil-water separators
B. Recordkeeping and Reporting Requirements Comments
• that all of the following information is recorded for each seal gap D No
measurement: §63.147(b)(3) D Yes
* date of measurement? D Yes
* raw data obtained? D Yes
* calculations performed?
DNo
DNo
3. Do you record the occurrence of each semiannual visual inspection D Yes D No
of oil-water separators for improper work practices (Option Ol or
O2)? §§63.137(d)and63.147(b)(l)
4. Do you record the occurrence of each semiannual visual inspection D Yes D No
of oil-water separators for control equipment failures (Option Ol or
O2)? §§63.137(e)and63.147(b)(l)
5. For each inspection during which a control equipment failure was
identified, do you record and report all of the following in your next
periodic report (Option Ol or O2): §§63.137 (e) and 63.146(c)
• date of the inspection
• identification of the oil-water separator having the failure?
• description of the failure?
• description of the nature of the repair?
• date the repair was made?
DYes
DYes
DYes
DYes
DYes
DNo
DNo
DNo
DNo
DNo
6. When your seal gap measurements indicate a failure, do you include
all of the following in your next periodic report (Option O2):
• date of measurement? D Yes D No
• raw data obtained? D Yes D No
• calculations performed? D Yes D No
a The emission suppression compliance options for oil-water separators are described in the section "What are my
emission suppression compliance options?" beginning on page 5-4.
5-55
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Checklist 6: Requirements for covers, fixed roofs, and enclosures that are used in emission
suppression compliance options
Facility Name:
Facility Location:
Facility TRI ID #:
Inspector:
Date:
Note: A "yes" response to a question in this checklist means compliance with that requirement, and a "no"
response means noncompliance with the requirement. If the requirement is not applicable, indicate "N/A" in the
comments column.
A. Monitoring and Inspection Requirements
Comments
Note: Inspections for leaks are not required if you maintain your cover,
fixed roof, or enclosure (and the closed-vent system that is connected to it)
under negative pressure.
1. Do you conduct semiannual sensory-based inspections of each cover, D Yes D No
fixed roof, and enclosure for leaks? §63.1366(h)(2)(iii)(B)
1. After repairing a leak, do you use Method 21 to confirm that the leak D Yes D No
is successfully repaired or that it is nonrepairable?
§63.1367(f)(4)(iii)
B. Recordkeeping and Reporting Requirements Comments
1. Do you keep all records for at least 5 years? §63.1367(a) D Yes D No
2. Do your records identify all parts of the covers, fixed roofs, and D Yes D No
enclosures that you designated as unsafe to inspect or difficult to
inspect, and do the records explain why you assigned the
designation? §63.1367^(1) and (2)
3. Do you have a written plan for inspecting the unsafe-to-inspect parts D Yes D No
of the covers, fixed roofs, and enclosures as frequently as
practicable? §§63.1366(h)(6)(ii) and63.1367(j)(l)
Note: The inspections do not need to be more frequent than once per
year.
4. Do you have a written plan for inspecting the difficult-to-inspect D Yes D No
parts of covers, fixed roofs, and enclosures at least once every 5
years? §§63.1366(h)(7) (ii) and 63.1367'$ (2)
5. For each inspection during which no leaks are detected, do you
records all of the following: §63.1367(f) (6)
• date of the inspection? D Yes D No
• a statement that no leaks were detected? D Yes D No
6. For each inspection during which a leak is detected, do you have the
following records: §63.1367(f) (4)
• identification of the leaking equipment? D Yes D No
5-56
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Checklist 6: (cont'd)
Requirements for covers, fixed roofs, and enclosures
B. Recordkeeping and Reporting Requirements Comments
• the date the leak was detected? D Yes D No
• the date of the first attempt to repair the leak? D Yes D No
Note: The first attempt to repair the leak must be no later than 5
calendar days after the leak is detected. §63.1366(h)(4)(i)
• maximum instrument reading measured by Method 21 after the D Yes D No
leak is repaired or determined to be nonrepairable?
• all of the following if the leak is not repaired within 15 calendar
days after the leak was discovered:
*• reason for the delay? D Yes D No
* name, initials, or other form of identification of the person D Yes D No
who decided repairs cannot be made without a shutdown?
* expected date of successful repair? D Yes D No
Note: Delay of repair until the next shutdown is allowed if the
repair is technically infeasible without a shutdown, or if the
emissions from immediate repair would be greater than the
fugitive emissions likely from delay.
• dates of shutdowns that occur while the equipment is unrepaired? D Yes D No
• date of successful repair of the leak? D Yes D No
7. Did you submit the records in "6" of all inspections during which a D Yes D No
leak is detected in your next periodic report? §63.1368(g)(2)(iii) and
(xi)
5-57
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Checklist 7: Requirements for steam strippers (treatment compliance options Tl, T2, T3A, T3B,
and T3E)a
Facility Name:
Facility Location:
Facility TRI ID #:
Inspector:
Date:
Note: A "yes" response to a question in this checklist means compliance with that requirement, and a "no"
response means noncompliance with the requirement. If the requirement is not applicable, indicate "N/A" in the
comments column.
A. Monitoring and Inspection Requirements
does the countercurrent flow configuration have at least 10 actual
trays?
is the steam flow rate at least 0.04 kilograms of steam per liter of D Yes
wastewater feed?
is the temperature of the wastewater feed to the steam stripper (or D Yes
the column temperature) at least 95°C?
is the wastewater liquid loading no greater than 67,100 liters per D Yes
hour per square meter?
DNo
DNo
DNo
DNo
DNo
• does it operate at nominal atmospheric pressure? D Yes D No
B. Recordkeeping and Reporting Requirements (Options Tl, T2, T3A, T3B, or T3E)
3. Do you keep records of the daily averages of each of the parameters
in "2"? §63.147'(d)
DYes
DNo
Comments
1. If you have a design steam stripper (Option T2), does it meet all of
the following requirements: §63.138(d)
• is the minimum active column height at least 5 meters? D Yes
DYes
Comments
1.
2.
Do you keep all records for at least 5 years? §63. 1367 (a)
Do you keep records of the continuous monitoring data for all of the
following parameters : §63. 1 4 7(b) (5)
• steam flow rate?
• wastewater feed mass flow rate?
• either wastewater feed temperature or column temperature?
Note: You do not have to monitor these parameters if you request
and receive approval to monitor alternative parameters.
DYes
DYes
DYes
DYes
DNo
DNo
DNo
DNo
5-58
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Checklist 7: (cont'd)
Requirements for steam strippers
B. Recordkeeping and Reporting Requirements (Options Tl, T2, T3A, T3B, or T3E) Comments
4. For each inspection during which a control equipment failure was
identified, do you record and report the following in the Periodic
report: §63.146(c)
• date of the inspection
• identification of the treatment unit?
• description of the failure?
• description of the nature of the repair?
• date the repair was made?
DYes
DYes
DYes
DYes
DYes
DNo
DNo
DNo
DNo
DNo
5. Do you submit all of the following in your Periodic Reports if
exceedances or excursions are > 1 percent of the total operating time
during the reporting period: §63.1368(g) (2)
• all monitoring data (including daily averages) for all operating D Yes D No
days or blocks when the average of a monitored parameter is
outside the range specified in your NOCSR or operating permit?
• identification of all operating days or blocks when insufficient D Yes D No
monitoring data are collected?
• operating logs and operating scenarios? D Yes D No
a The treatment compliance options for steam strippers are described in the section "What treatment compliance
options do I have for my wastewater streams?" beginning on page 5-10.
5-59
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Checklist 8: Requirements for treatment units other than steam strippers (treatment compliance
options Tl and all versions of T3)a
Facility Name:
Facility Location:
Facility TRI ID #:
Inspector:
Date:
Note: A "yes" response to a question in this checklist means compliance with that requirement, and a "no"
response means noncompliance with the requirement. If the requirement is not applicable, indicate "N/A" in the
comments column. All questions apply to option Tl and all versions of option T3, unless noted.
A. Monitoring and Inspection Requirements
Comments
1. Are monitoring devices present to conduct monitoring that was
approved by the Administrator or permitting authority? §63.143(c)
and (d)
B. Recordkeeping and Reporting Requirements
DYes
DNo
4. If you use a biological treatment unit and you comply with Option
T3G or T3H), do you have records of the Fblo determination?
DYes
DNo
Comments
1.
2.
3.
Do you keep all records for at least 5 years? §63. 1367 (a)
Do you have records of monitoring approved by the Administrator or
permitting authority? §63. 147(b) (4)
If any of the parameters are monitored continuously, do you keep
records of the daily averages? §63.147(d)
DYes
DYes
DYes
DNo
DNo
DNo
Do you submit all of the following in your Periodic Reports if
exceedances or excursions are > 1 percent of the total operating time
during the reporting period: §63.1368(g) (2)
• all monitoring data (including daily averages) for all operating
days or blocks when the average of a monitored parameter is
outside the range specified in your NOCSR or operating permit?
DYes
DNo
• identification of all operating days or blocks when insufficient
monitoring data are collected?
• operating logs and operating scenarios?
DYes
DYes
DNo
DNo
a The treatment compliance options for all treatment units are described in the section "What treatment compliance
options do I have for my wastewater streams?" beginning on page 5-10.
5-60
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Checklist 9: Requirements for heat exchange systems (compliance options HE1 and HE2)a
Facility Name:
Facility Location:
Facility TRI ID #:
Inspector:
Date:
Note: Use section A of this checklist to determine if your heat exchange system is subject to control
requirements. If it is, then a "yes" response to a question in section B of this checklist means compliance with
that requirement, and a "no" response means noncompliance with the requirement. If the requirement is not
applicable, indicate "N/A" in the comments column.
A. Applicability Comments
1. Does your heat exchange system meet any of the following
conditions? §63.104(a)
• Is the minimum pressure on the cooling water side of the heat D Yes D No
exchange system at least 35 kPa greater than the maximum
pressure on the process side?
• Do you use an intervening fluid between the process and the D Yes D No
cooling water where the intervening fluid meets both of the
following:
*• contains less than 5 percent by weight of HAP listed in
Table 4 to subpart F of 40 CFR part 63, and
*• is not sent through a cooling tower or discharged?
• Do you have a once-through heat exchange system that is subject D Yes D No
to an NPDES permit with an allowable discharge limit that is
either 1 ppm or less above the influent concentration or 10
percent or less above the influent concentration?
• Do you have a once-through heat exchange system that is subject D Yes D No
to an NPDES permit that includes all of the following:
* requires monitoring of a parameter(s) or conditions) to
detect a leak of process fluids into cooling water, and
*• specifies or includes the normal range of the parameter(s) or
condition(s), and
*• requires monitoring for the parameter(s) no less frequently
than monthly for the first 6 months and quarterly thereafter,
and
* requires you to report and correct leaks to the cooling water
when the parameter or condition is outside the normal ,-, Y ,-, N
range?
• Do you have a recirculating heat exchange system that is used to
cool process fluids that contain less than 5 percent by weight of
total HAP listed in Table 4 to subpart F of part 63?
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Checklist 9: (cont'd)
Requirements for heat exchange systems
A. Applicability
Comments
• Do you have a once-through heat exchange system that is used to
cool process fluids that contain less than 5 percent by weight of
total HAP listed in Table 9 to subpart G of part 63?
Note: If you answer "yes" to any of the questions in this section,
do not continue; your heat exchange system is exempt from
control requirements. If you answer "no " to all of the questions
in this section, proceed to the questions in section B.
B. Recordkeeping and Reporting Requirements
DYes
DNo
Comments
1.
2.
Do you keep all records for at least 5 years? §63.1367(a)
DYes
DNo
If you comply with option HE2, do you have a monitoring plan that
includes all of the following: §63.104(c) (1)
• description of the parameter(s) or condition(s) to be monitored? D Yes D No
• explanation of how the selected parameters) or condition(s) will D Yes D No
reliably indicate a leak?
• the parameter level(s) or conditions) that constitute a leak, D Yes D No
including supporting data and calculations?
• your monitoring frequency? D Yes D No
• the records that you will maintain? D Yes D No
3. When you detect a leak, do you have all of the following records:
§63.104(J)(1)
• identification of the leak? D Yes D No
• date when the leak was detected? D Yes D No
• date(s) of efforts to repair the leak? D Yes D No
• the method or procedure used to confirm repair of the leak? D Yes D No
• date the repair was confirmed? D Yes D No
Note: confirmation of repair is not applicable while delay of
repair provisions are in effect.
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Checklist 9: (cont'd)
Requirements for heat exchange systems
B. Recordkeeping and Reporting Requirements Comments
4. If you have delayed repair of a leak, do you have documentation for D Yes D No
either of the following, along with a schedule for completing the
repair as soon as practical: §63. 1 04(e) (2)
• the basis of a determination that a shutdown for repair would
cause greater emissions than the emissions likely to result from
delaying repair, or
• evidence that the necessary parts or personnel were not available
to make the repair?
Note: Documentation is not necessary if you isolate the
equipment from the process, or if you have a planned shutdown
scheduled within the next 2 months after you determine that a
delay of repair is necessary. §63. 1 04(e) introductory text and
5 . Do you submit all of the following in your Periodic Reports if you
delay repair of a leaking heat exchange system: §63. 1 04(f}(2)
• Identification of the leak? D Yes D No
• date the leak was detected? D Yes D No
• whether or not the leak has been repaired? D Yes D No
• reason(s) for any delay of repair? D Yes D No
• documentation of emissions estimates, if repair is delayed for D Yes D No
either of the reasons listed in question B. 4?
• either the expected date of repair (if the leak has not yet been D Yes D No
repaired) or the date the leak was successfully repaired?
a The compliance options for heat exchange systems are described in the section "What are my compliance options
for heat exchange systems?" beginning on page 5-30.
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Chapter 6 - Complying with requirements for equipment leaks
What equipment leaks are regulated by Subpart MMM?
Subpart MMM regulates equipment leaks from equipment in "organic HAP service." The
equipment leak provisions apply to all of the following types of equipment [§63.1363(a)(l)]:
• pumps
• compressors Definition: "In organic HAP service" means that the
equipment component either contains or contacts a
• agitators fluid that is at least 5 percent organic HAP by weight.
• pressure relief devices
• sampling connection systems
open-ended valves or lines
• valves
• connectors
• instrumentation systems
If you have equipment subject to both Subpart MMM and other air regulations under 40 CFR
parts 60 or 61, you are only required to comply with Subpart MMM [§63.1362(a)(2)J.
Equipment leak provisions apply at all times except when the lines of a non-operating PAI
process unit are drained and depressurized [§63.1360(e)(2)].
How do I identify equipment subject to the equipment leak
provisions?
You must identify each piece of equipment that is subject to the equipment leak provisions so it
can be distinguished from equipment not subject to the provisions. You do not have to
physically tag the equipment unless you wish to do so. Instead, you can mark the equipment on
a plant site plan, in log entries, or by designating process boundaries with waterproof
identification. [§63.1363(a)(7)]
Note: If you make changes to the process or equipment subject to the leak detection requirements, you must
update the equipment identification, if needed, within 15 calendar days of the end of each monitoring period for
that component.
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Leaks are detected by sight, sound, odor, or monitoring. When a leak is detected, you must
attach a visible, weatherproof identification to the leaking equipment. The identification may be
removed under either of the following circumstances: [§63.1363(a)(10)]
• after the leak has been repaired if the equipment is not a valve in light liquid or gas/vapor
service
• when no leak is detected by follow-up monitoring on a valve in light liquid or gas/vapor
service
Follow-up monitoring for valves is described in
§63.1363(e)(7)(iii)ofsubpartMMM.
What equipment is exempt?
All of the following are exempt from the equipment leak provisions [§63.1363(a)(5) through
(9)]:
• lines and equipment that do not contain process fluids
• utilities and other nonprocess lines that do not combine their materials with process fluids
they serve
• bench-scale processes
equipment in vacuum service
• equipment in organic HAP service less than 300 hours per year
What compliance options do I have for my equipment leaks?
For equipment in organic HAP service, you have the following five compliance options:
Option 1: Use a leak detection/repair program [§63 1363(b), (c), (d), and (e); and
sections of Subpart H referenced from §63.1363(b)]
Implement a leak detection and repair (LDAR) program.
Option 2: Use enclosed equipment and transport emissions through a closed-
vent system to a control device [§63.1363(b)(3)(ii), §63.172, and §63.179]
Capture equipment leak emissions and transport them through a closed-vent system to a
control device. This option applies to an entire process unit that is enclosed, and emissions
are transported through a closed-vent system to a control device. It also applies to pumps,
6-2
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agitators, compressors, pressure relief devices, and sampling connection systems that are
equipped with a closed-vent system to transport leaking liquid, emissions, or samples to a
control device (or a process).
OptionS: Use pressure testing [§63.1363(b)(3)(iv), §63.178(b)]
Pressure test the process to demonstrate compliance for equipment for which periodic
monitoring would be required under option 1. Also comply with the option 1 requirements
for compressors, pressure relief devices in gas/vapor service, open-ended valves and lines,
and sampling connection systems.
Option 4: Alternative monitoring for batch processes [§63 1363(b)(3)(iv),
§63.178(c)]
Implement an LDAR program as in option 1, except the monitoring frequency may be
reduced for some batch components that operate less than 75 percent of the time.
Option 5: Alternative means of emission limitation [§63 1363(b)(2), §63 177]
Apply for permission to use an alternative equipment, design, or operational requirement or
work practice standard.
The requirements and exceptions for all of the options as applied to different types of equipment
are summarized in Table 6-1 (page 6-4). Additional details are also provided later in this
chapter.
How do I implement a leak detection and repair (LDAR) program under
Option 1?
Your requirements under an LDAR program depend on what type of equipment you are using.
The LDAR program is broken down into the following eleven categories:
• pumps in light liquid service
Definition. In light liquid service means that a piece of equipment in organic HAP service contains a
liquid that meets all of the following conditions:
(1) The vapor pressure of one or more of the organic compounds is greater than 0.3 kPaat 20°C;
(2) The total concentration of the pure organic compounds constituents 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.
(Note: Vapor pressures may be determined by the methods described in 40 CFR 60.485(e)(l).)
6-3
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TABLE 6-1. General Requirements and Exceptions of the Equipment Leak Provisions
For the following equipment...
Your equipment leak requirements are... Except for.. .a
According to this
section of the rule.
Pumps in light liquid service and
agitators in gas/vapor service and in
light liquid service
(Option 1)
quarterly monitoring for leaks (or
monthly if calculated percent leaking
pumps exceeds specified level)
weekly visual inspections
repair of leaks
unsafe to monitor or inaccessible equipment
pumps/agitators with dual mechanical seal
system with barrier fluid
pumps/agitators with no externally actuated
shaft
pumps/agitators with closed-vent systems
and control devices
pumps/agitators at unmanned sites
§63.1363(c)
Open-ended valves or lines
(Option 1)
seal valves or lines with a cap, blind
flange, plug, or a second valve
valves/lines designed to open automatically
in emergency
valves/lines containing materials which
would autocatalytically polymerize
valves/lines that would be hazardous if
capped or equipped with a double block and
bleed system
§63.1363(d)
Valves in gas/vapor service and light
liquid service
(Option 1)
initial monitoring for leaks
repeat monitoring based on calculation
of percent leaking valves
repair of leaks
unsafe and difficult to monitor valves §63.1363(e)
inaccessible valves
Compressors
(Option 1)
equip compressors with a seal system
that includes barrier fluid system
repair of leaks
compressors with closed-vent systems and
control devices
compressors with leak detection instrument
reading of <500 ppm
§63.164
Pressure relief devices in gas/vapor
service
(Option 1)
leak detection instrument reading of <500
ppm (except during pressure releases)
pressure relief devices with closed-vent
systems and control devices
pressure relief devices with upstream rupture
disks
§63.165
Sampling connection systems
(Option 1)
a closed-purge, closed-loop, or closed-vent
system
in-situ sampling systems and sampling systems §63.166
without purge
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TABLE 6-1. (cont'd)
For the following equipment...
Your equipment leak requirements are... Except for.. .a
According to this
section of the rule.
Pumps, valves, connectors, and
agitators in heavy liquid service;
instrumentation systems; and
pressure relief devices in liquid
service
(Option 1)
monitor equipment when sensory
detection methods provide evidence of
potential leaks
repair of leaks
potential leaks that are repaired before
monitoring
§63.169
Connectors in gas/vapor service and
in light liquid service
(Option 1)
initial monitoring for leaks
repeat monitoring based on calculation
of percent leaking connectors
repair of leaks
connectors that have been opened or have a
broken seal
screwed connectors with a small inside
diameter
ceramic or ceramic-lined connectors
unsafe and difficult to monitor connectors
inaccessible connectors
credits for removed connectors
§63.174 with
changes described in
§63.1363(b)(3)(iii)
Enclosed equipment with closed-
vent systems and
control devices
(Option 2)
percent reduction, outlet concentration,
or equipment operating requirements
monitoring for use of bypass lines
inspections
repair of leaks
control devices subject to monitoring,
reporting, and recordkeeping requirements in
40 CFR part 264, subpart BB, or in 40 CFR
part 265, subpart BB
§63.172 with
changes described in
§63.1363(b)(3)(ii)
Pressure testing
(Option 3)
pressure test each time equipment is
reconfigured
pressure test at least annually if
equipment is not reconfigured
repair leaks and retest
pressure testing is not required for routine seal §63.178(b) and (d)
breaks that are unrelated to reconfiguration of with changes
the equipment described in
§63.1363(b)(3)(iv)
Monitoring for batch processes
(Option 4)
apply equipment standards and monitor
as required by option 1
monitor after reconfiguration
repair leaks
monitoring frequency may be reduced for
valves and agitators that are not operated full
time
§63.178(c)and(d)
a Note that equipment exempted from the general requirements often still must meet specified design criteria, must be monitored less frequently, or must meet
other requirements. Details are presented later in this chapter.
-------
agitators in gas/vapor service and light liquid service
Definition. In gas/vapor service means that a piece of
equipment in organic HAP service contains a gas or
vapor at operating conditions.
open-ended valves or lines
valves in gas/vapor or light liquid service
compressors
pressure relief devices in gas/vapor service
sampling collection systems
pump, valves, connectors and agitators in heavy liquid service
Definition. In heavy liquid service means that the piece
of equipment in organic HAP service is not in gas/vapor
or light liquid service.
• instrumentation systems
• pressure relief devices in liquid service
connectors in gas/vapor service and in light liquid service
Note: Equipment in gas/vapor and light liquid service are subject to different requirements than equipment in
heavy liquid service.
For most equipment, you implement an LDAR program by monitoring in accordance with one
or both of the following procedures:
• by using Method 21 as specified in §63.1363(b)(3)(v) and §63.180 of the HON
• by visual or other sensory means of detection
The frequency of Method 21 monitoring for pumps in light liquid service, valves in gas vapor
service or light liquid service, and connectors in gas/vapor service or light liquid service
depends on how many leaked in the preceding
monitoring period(s). You have the option of
how to group processes for use in calculating Definition. A group of processes means all of the
., . r- x, . ., . , , equipment associated with processes in a building,
the percentage of these components that leak. pressing area, or facility-wide. Agroupof
You have even more grouping possibilities processes may consist of a single process.
for valves because you may establish groups
using subsets of the valves within groups of
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processes, as long as less than 2 percent of the valves in the overall group of processes from
which the subsets were created are leaking (see requirements for subgrouping in "What LDAR
requirements apply to valves in gas/vapor or light liquid service (Option 1)?" for more
information).
For other equipment, your LDAR program consists of work practice procedures or equipment
design requirements.
Additional details of LDAR programs for each of the eleven categories of equipment are
provided later in this chapter.
What are the LDAR requirements for Pumps in Light Liquid Service
and Agitators in Gas/Vapor Service and Light Liquid Service
(Option 1)?
Requirements for pumps and agitators under Option 1 include all of the following [§63.1363(c)]:
• monitor equipment for leaks using Method 21
• perform visual inspections
• repair leaks
In addition, pumps and agitators with specific design or operational features are exempt from
some of these requirements. The requirements and exemptions are detailed below.
Monitoring for leaks
You must monitor for leaks at least once each quarter using the monitoring method described in
§63.180(b) of subpart H [§63.1363(c)(2)(i)]. This method requires you to use a leak detection
instrument. Your equipment is considered leaking if you get any of the following instrument
readings: [§63.1363(c)(2)(ii)]
• > 10,000 ppm for agitators
> 2,000 ppm for pumps
You must calculate the percentage of pumps that leak using the procedure outlined in
§63.1363(c)(4). Prior to the first monitoring period
you must decide what groups of processes to You do nothave to calcuMe the percentage
develop (see page 6-6 for the definition of "group of Of agitators that are leaking.
processes"). You then calculate the percent leakers
in each group of processes for each monitoring
period.
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You must monitor all of the pumps in the group of processes monthly if (based on a 1-year
rolling average) either of the following apply:
• 10 percent or more of the pumps in
the group of processes leak TA , . , ,
You may return to quarterly monitoring after the 1-
• three or more pumps in the group of year rollinS average value drops below 10percent (or
processes leak (if the group of less than 3 pumps leak).
processes has less than 30 pumps)
All pumps in organic HAP service must be included in the calculation of percent leaking pumps,
except for the following:
• pumps designed with no externally actuated shaft penetrating the pump housing
[§63.1363(c)(6)]
all pumps in a group of processes if more than 90 percent of the pumps in the group of
processes are either of the following: [§63.1363(c)(9)J
*• equipped with a dual mechanical seal system that includes a barrier fluid system
*• designed with no externally actuated shaft penetrating the pump/agitator housing
• pumps that you designate as difficult to monitor
• pumps that are in compliance with option 2
Note: Pumps that are excluded from the percent leaking calculation also never have to be monitored more
frequently than quarterly.
Visual inspections
Each pump and agitator must be checked weekly by visual inspection for signs of liquids
dripping from the pump or agitator seal. If you notice signs of liquids dripping from the seal,
you must do either of the following: [§63.1363(c)(2)(iii)]
• stop the liquid from dripping
• monitor the pump or agitator using a leak detection instrument (follow the procedure
specified in §63.180(b) to determine if you have a leak; you have a leak if the instrument
reading is > 10,000 ppm for agitators or >2,000 ppm for pumps)
Repair of leaks
You must repair leaks as soon as possible after they are detected, unless a delay of repair is
allowed. See "What are my leak repair requirements?" for more information.
6-8
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Exceptions
There are several exemptions to the requirements for implementing an LDAR program for
Pumps in Light Liquid Service and Agitators in Gas/Vapor Service and Light Liquid Service.
Exemptions include all of the following:
Pumps that are difficult to monitor and agitators that are unsafe or difficult to monitor -
• Equipment that is unsafe or difficult to monitor is subject to special monitoring
requirements instead of the quarterly or monthly monitoring described above, and pumps
that are difficult to monitor also are excluded from the calculation of the percent leaking
pumps. See "What if equipment is unsafe or difficult to monitor?" (page 6-28) for more
information.
Pumps or agitators with special design features -
Pumps or agitators equipped with a dual mechanical seal system that includes a barrier
fluid system are exempt from the quarterly or monthly monitoring provisions in
§63.1363(c)(2) provided that all of the following are performed: [§63.1363(c)(5)]
*• your dual mechanical seals meet one of the following criteria:
»«• are operated with a barrier fluid pressure that is always greater than the
pump/agitator stuffing box pressure
»«• are equipped with a barrier fluid degassing reservoir connected by a closed-vent
system to a control device
»*» are equipped with a closed-loop system that purges the barrier fluid into a process
stream
* the barrier fluid is not in light liquid service
*• each barrier fluid system has a sensor that will detect failure of the seal system, the
barrier fluid system, or both. The sensor must be observed daily or have an alarm
(unless the pump is at an unmanned plant site).
*• each pump/agitator must be visually inspected each week to see if liquids are dripping
from the pump/agitator seal. If liquids are dripping, you must either stop the drips or
monitor the seal with a leak detection instrument to determine if there is a leak of
organic HAP in the barrier fluid. You have a leak if the instrument reads
> 10,000 ppm for agitators or >2,000 ppm for pumps, and you must repair the leak as
described in "What are my leak repair requirements?" (page 6-26).
*• you have determined the criteria that you will use to indicate failure of the seal
system, the barrier fluid system, or both. If a leak is detected based on your criteria
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then you must repair the leak as described in "What are my leak repair requirements?"
(page 6-26).
Note: Pumps with dual mechanical seals also must be included in the percent leaking calculation
Any pump or agitator designed with no externally actuated shaft penetrating the
pump/agitator housing is exempt from all of the monitoring, visual inspection, repair, and
calculation of percent leaking pumps provisions. [§63.1363(c)(6)]
Pumps and agitators with a closed-vent system that captures and transports leaking
material from the seals to a process or control device are complying with option 2 and are
exempt from the monitoring, visual inspection, repair, and calculation of percent leaking
pumps provisions under option 1. [§63.1363(c)(7)]
Pumps and agitators at unmanned plant sites are exempt from weekly visual inspections
and daily sensor observations (for pumps/agitators with dual mechanical seal and barrier
fluid systems). However, each pump/agitator must be visually inspected at least monthly
or more frequently if possible. [§63.1363(c)(8)]
What are the LDAR requirements for open-ended valves or lines
(Option 1)?
You comply with the LDAR requirements for open-ended valves or lines under Option 1 by
sealing the open end using any of the following devices: [§63.1363(d)(l)(i)]
• a cap
a blind flange
• a plug
• a second valve
The mechanism you use to seal the open end must meet both of the following:
[§63.1363(d)(l)(ii)]
• it must be in use at all times except:
*• during operations requiring process fluid flow through the valve or line
*• during maintenance
*• during repair
• it must be in place within 1 hour after any of the excepted periods listed above
Note: If you use a second valve, you must close the valve on the process fluid end before closing the second
valve. [§63.1363(d)(2)]
If you use a double block and bleed system, you may leave the bleed valve or line open during operations that
require venting the line between the block valves. [§63.1363'(d) (3)]
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Exemptions
You do not have to comply with the requirements to seal the open-ended valve or line if any of
the following situations apply to the open-ended valve or line: [§63.1363(d)(4) through (6)]
• it contains material which would autocatalytically polymerize
• it contains material which could cause a safety hazard if capped or equipped with a double
block and bleed system
• it is designed to open automatically as part of an emergency shutdown system in the event
of a process upset
What LDAR requirements apply to valves in gas/vapor or light liquid
service (Option 1)?
For valves in gas/vapor or light liquid service you must implement an LDAR program by doing
all of the following steps:
Step 1: Identify your valves:
• identify all valves in PAI process units [§63.1363(a)(7)J
Step 2: Identify valves subject to special monitoring requirements:
• identify each valve that meets one of the following conditions: [§63.1363(f)]
*• is unsafe to monitor
For more information, see "What if equipment
- is difficult to monitor is unsafe or difflcult to monitor? "
Step 3: Perform initial monitoring:
• monitor all valves (except those identified in Step 2) using a leak detection instrument
within 1 year after the compliance date (e.g., by 12/23/04). Use Method 21 as specified in
§63.180(b) of subpartH. [§63.1363(e)(2) and (e)(3)(i)]
Step 4: Repair all leaks
• if you find a leaky valve, you must repair it as soon as possible, unless a delay of repair is
allowed. See "What are my leak repair requirements?" (page 6-26) for more information.
Note: You have a leak if the instrument reading is 500 ppm or greater [§63.1363(e)(3)(ii)].
• re-monitor the valve within 3 months of repair, but you do not need to include these
monitoring results in the calculation of percent leakers described in Step 5
[§63.1363(e)(7)(iii)and(e)(6)(ii)]
Note: Days when a valve is not in organic HAP service are not included in the 3-month period.
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Step 5: Calculate your percentage of leaking valves
calculate the percentage of leaking valves in a group of valves, excluding nonrepairables
[§63.1363(e)(6)(ii)]. You may define groups
that are most appropriate for your site-specific The results ofthese caiculations are used to
circumstances. Your choices for groups determine the frequency of subsequent
consist of any combination of the following: monitoring, as described in Step 6.
[§63.1363(b) and (e)(6)(i)]
*• create a group of all the valves from a single process
*• create a group of all the valves from multiple processes
*• create multiple subgroups of all the valves from multiple processes (see page 6-13 for
instructions on how to create a subgroup)
Note: To create or revise groups of processes after the implementation date, you must revise your permit
[§63.1363(e)(6)(i)].
To calculate the percentage of leaking valves in a group or subgroup, you may exclude
nonrepairable valves (up to 1 percent of the total number of valves in the group or subgroup),
except you must include the nonrepairable valve as a leaking valve in the calculation of percent
leakers for the first monitoring period after you identify it as leaking. [§63.1363(e)(6)(iv)]
Step 6: Continuous monitoring for leaks
• After your initial round of monitoring, you must monitor for leaks as follows:
If the total number of
valves you have for all
groups is...
And the percentage of
leaking valves in the group
or subgroup is...a
Then you must
monitor at least once
every..."
According to
§63.1363(e)(6)(iii)andthis
section of the rule...
>250 > 2 percent
<2 percent
<1 percent
<0.5 percent
<0.25 percent
<250 no determination required
<1 percent
<0.5 percent
<0.25 percent
month
3 months
6 months
12 months
2 years
3 months
6 months
12 months
2 years
§63.1363(e)(4)(i)
§63.1363(e)(4)(ii)
§63.1363(e)(4)(iii)
§63.1363(e)(4)(iv)
§63.1363(e)(4)(v)
§63.1363(e)(9)
§63.1363(e)(4)(iii),
(e)(4)(iv), (e)(4)(v), and
(e)(9)
Percentages are averaged from the data collected during the previous two monitoring periods if the group or
subgroup was monitored every year or every 2 years, and percentages are averaged from the previous three
monitoring periods if the group or subgroup was monitored every 1 month, 3 months, or 6 months.
[§63.1363(e)(6)(iii)]
All valves that you find to be leaking must be repaired and remonitored within 3 months as specified in step 4.
[§63.1363(e)(7)]
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Your requirements for subgrouping valves include all of the following:
• you may subgroup valves within a group of processes if less than 2 percent of the valves
in the group leaked in the last monitoring period [§63.1363(e)(5)(i)]
• you must check for compliance with the 2 percent cutoff for the group every 6 months
[§63.1363(e)((5)(iii)]
anytime you find more than 2 percent in the group to be leaking, you must revert to
monitoring the group as a whole (i.e., monitor all of the valves in the group monthly)
[§63.1363(e)(5)(iii)]
• when you create subgroups, you must include in the most frequently monitored subgroup
all valves that meet either of the following conditions [§63.1363(e)(5)(ii)(A)]:
*• those with less than 1 year of monitoring data
* those that have not been monitored in the last 12 months
• you may move any valve from a less frequently monitored subgroup to a more frequently
monitored subgroup if you take all of the following actions before and after the move
[§63.1363(e)(5)(ii)(B)]:
*• before the move: monitor the valve during the most recent monitoring period for the
less frequently monitored subgroup
*• after the move: include the first monitoring results in your next calculation of the
percentage leaking valves for the less frequently monitored subgroup
• you may move a valve from a more frequently monitored subgroup to a less frequently
monitored subgroup if the valve has not
leaked for the period of the less
. Nonrepayable valves may not be moved to a less
frequently monitored subgroup frequently monitored subgroup.
[§63.1363(e)(5)(ii)(Q]
Note: Additional recordkeeping andreporting is required for valves in subgroups [§63.1363(e)(5)(iv) and
(v)]. See Table 6-2 in the section "What records must I keep for my equipment leaks? " (page 6-31) and the
section "What reports must I submit" (page 6-37) for more information.
What LDAR requirements apply to compressors (Option 1)?
To comply with the LDAR requirements for compressors (option 1), you must do all of the
following:
• equip your compressors with a seal system that includes a barrier fluid system and meets
any one of the following [§63.164(a) and (b)]:
*• it is operated with the barrier fluid pressure greater than the compressor stuffing box
pressure
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*• it is equipped with a barrier fluid system degassing reservoir that is routed to a process
or connected by a closed-vent system to a control device
*• it is equipped with a closed-loop system that purges the barrier fluid directly into a
process stream
Note: the barrier fluid must not be in light liquid service.
equip the barrier fluid system with a sensor that will detect a system failure [§63.164(d)]
• determine a criterion for the sensor that indicates the failure [§63.164(e)(2)]
• observe the sensor daily or equip it with an alarm (this requirement does not apply if the
compressor is located at an unmanned plant site)[§63.164(e)(l)]
Note: you have a leak if the sensor detects a failure [§63.164(f)J
• repair leaks as soon as possible, unless a delay of repair is allowed. See "What are my
leak repair requirements?" (page 6-26) for more information.
Exceptions
The LDAR requirements do not apply to compressors in organic HAP service if you do any of
the following:
• comply with option 2 by equipping the compressor with a closed-vent system to capture
and transport leaks back to a process or to a control device [§63.164(h)]
• designate that the compressor operates with an instrument reading of less than 500 ppm
above background based on monitoring using Method 21 at all of the following times
[§63.164(i)]:
> when you make the designation
*• annually
*• any other time requested by the Administrator
What LDAR requirements apply for pressure relief devices in
gas/vapor service (Option 1)?
To comply with the LDAR requirements for pressure relief devices in gas/vapor service (option
1), you check your devices for leaks after each pressure release as follows: [§63.165(b)]
• return the pressure relief device to normal operating condition as soon as possible, but not
more than 5 days after the pressure release, unless a delay is allowed. See "What are my
leak repair requirements?" (page 6-26) for more information.
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• monitor the pressure relief device within 5 days after the pressure release (and the
pressure relief device has been returned to organic HAP service) using a leak detection
instrument
• the instrument reading must be less than 500 ppm above background
Note: To measure leaks, use Method 21 and the procedures specified in §63.180(c) ofsubpart H. You may
either adjust the instrument reading to account for background levels, or you may directly compare the reading
to the 500 ppm limit.
Exceptions
You are exempt from the LDAR requirements for pressure relief devices in gas/vapor service if
either of the following apply:
• you comply with Option 2 by capturing emissions from releases and transporting them
through a closed-vent system to a process or control device. [§63.165(c)]
• if your pressure relief device is equipped with a rupture disk upstream of the pressure
relief device, and you replace the rupture disk as soon as possible (but no more than 5
days) after a pressure release. [§63.165(d)]
What LDAR requirements apply for sampling connection systems
(Option 1)?
To comply with the LDAR requirements for sampling connection systems (option 1), you must
meet certain design requirements. Each of
your sampling connection systems must v „ , ,
, 11 1 j i You do not have to collect or capture gases displaced
have a closed-purge, closed-loop, or during filling of the sample containers. [§63.166(a)J.
closed-vent system that does one of the
following: [§63.166(b)]:
• returns purged process fluid directly to the process line
collects and recycles purged process fluid to a process
• captures and transports purged process fluid to a control device
collects, stores, and transports purged process fluid to a waste management unit, TSDF, or
permitted waste management facility
Note: Your waste management unit must meet the control requirements specified in subpart Gfor Group 1
wastewater (see Chapter 5 for details) if the purged process fluid contains any of the HAP listed in Table 9 to
subpart G.
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Exceptions
The following sampling systems are exempt from the LDAR requirements for sampling
connection systems: [§63.166(c)]
• in-situ sampling systems
• sampling systems without purges
What LDAR requirements apply for pumps, valves, connectors, and
agitators in heavy liquid service; instrumentation systems: and
pressure relief devices in liquid service (Option 1)?
To comply with the LDAR requirements for pumps, valves, connectors, and agitators in heavy
liquid service; instrumentation systems; and pressure relief devices in liquid service under
Option 1 you must do all of the following [§§63.1363(b)(2) and 63.169]:
• monitor equipment for leaks
• repair leaks
Both types of requirements are detailed below.
Monitoring for leaks
If you see, hear, notice an odor, or otherwise detect a potential leak, then you must do either of
the following:
consider the equipment to be leaking
• monitor for leaks within 5 days of noticing the potential leak using a leak detection
instrument. Follow Method 21 and the procedures described in §63.180(b).
The following table summarizes instrument readings that are considered to be a leak:
A leak is detected for ... If the instrument reading is ...
agitators 10,000 ppm
pumps handling polymerizing monomers 5,000 ppm
pumps in food or medical service 2,000 ppm
valves 500 ppm
connectors 500 ppm
instrumentation systems 500 ppm
pressure relief devices 500 ppm
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Repair of leaks
You must repair leaks as soon as possible after they are detected, unless a delay of repair is
allowed. See "What are my leak repair requirements?" (page 6-26) for additional details.
Repair of potential leaks means any of the following: [§63.169(c)(3)]
• you can no longer see, hear, smell, or otherwise detect the potential leak
• you see no bubbles at potential leak sites during a leak check with soap solution
• the system will hold a test pressure
What LDAR requirements apply for connectors in gas/vapor or light
liquid service (Option 1)?
To comply with the LDAR requirements for connectors (option 1), you must do all of the
following:
Step 1: Identify your connectors
Identify all connectors in PAI process units [§63.1363(a)(7)]
Step 2: Identify connectors subject to special monitoring requirements
Identify each connector that meets one of the following conditions [§63.1363(f)]:
• unsafe to monitor
For more information, see "What if equipment is unsafe
• difficult to monitor or difficult to monitor?" (page 6-28)
• inaccessible
• ceramic or ceramic-lined
Step 3: Perform initial monitoring
Monitor all connectors (except those designated in Step 2 ) [§63.174(b)(l) and (2)]:
• by December 23, 2004 for existing sources
• within 12 months after initial startup or by December 23, 2004, whichever is later, for
new sources
Step 4: Repair the leak
Repair leaks as soon as possible, unless a delay of repair is allowed [§63.174(d)]. See
"What are my leak repair requirements?" (page 6-26) for more information.
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Step 5: Calculate your percentage of leaky connectors
Calculate the percentage of leaking connectors in a group of processes using the
procedures specified in §63.174(i). See page 6-6 for a definition of "group of processes".
Step 6: Continuous monitoring for leaks
After the first year of monitoring, determine your required monitoring frequency for each
group of processes using the flowchart in figure 6-1. [§63.1363(b)(3)(iii)(C) through (G)]
Step 7: Repair leaks
Repair leaks as soon as possible as specified in step 4.
Exceptions to the above LDAR requirements for connectors apply for the following connectors:
connectors that have been opened
• screwed connectors
eliminated connectors
Monitoring connectors that have been opened
You have two options for monitoring of connectors that have been opened or have a broken
seal[§63.174(c)(l)]:
• Monitor the connector for leaks when it is reconnected or within the first 3 months after it
is returned to organic HAP service. If a leak is detected, it must be repaired (unless it is
determined to be nonrepairable).
• Choose not to monitor the connector. If you choose not to monitor the connector, then you
cannot count nonrepairables in your calculation of the percentage that are leaking.
Note: You may switch between the two monitoring alternatives for connectors that have been opened or
have a broken seal, provided the switch is at the end of the current monitoring period, and that it is reported
in your periodic report. You must complete initial monitoring in the new alternative no later than 12 months
after you report the switch.
Monitoring for screwed connectors
For screwed connectors with an inside diameter of 2 inches or less installed before November
10, 1997, you may do all of the following as an alternative to the procedure described above for
connectors that have been opened: [§63.174(c)(2)]
• Comply with the requirements for connectors in heavy liquid service in §63.169 of the
subpart H (i.e., if you detect evidence of a leak by sight, sound, odor, or other means, then
either repair the connector or monitor to determine if repair is needed).
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/ Use this flowchart for each \
I group of processes J
Monitor all connectors in the group of processes
within one year after the compliance date.
Did >.0.5% of
your connectors leak
in the monitoring
period?
Did >. 0.25% of
your connectors leak
in the monitoring
period?
Yes—^
Monitor all connectors in the group of processes once during the next year. Return
to (A) at the end of the year to determine the subsequent monitoring frequency.
Yes-
Your new required monitoring frequency is at least once in 4 years. You must
monitor 40% of the connectors in the group of processes in the first 2 years.
Your new required monitoring
frequency is at least once in 8
years. You must monitor 50%
of the connectors in the group
of processes in the first 4 years.
Did ^ 1 % of
your connectors leak
in the first 4-year
period?
Did >.0.5% of
your connectors leak
in the first 4-year
period?
Did >_ 0.35% of
your connectors leak
in the first 4-year
period?
Did >. 1 % of
your connectors leak
in the full 4-year
period?
Did >. 0.5% of
your connectors leak
in the full 4-year
period?
You must revert to annual
monitoring for all connectors in the
group of processes. Return to
(A) at the end of the year to
determine the subsequent
monitoring frequency.
Your new required monitoring
frequency is once every 2 years. At
the end of the 2-year period, return
to (A) to determine the subsequent
^^ monitoring frequency.
You must revert to monitoring every
2 years for all connectors in the
iroup of processes. Return to
"A) at the end of the 2-year period
to determine the subsequent
monitoring frequency.
You must revert to monitoring once
every 4 years for
all connectors in the group of
processes. Go to (B) for the
procedures.
Monitor the remaining 50% ofconnectors in the second 4 years of
the 8-year period. Return to (A) at the end of the 8-year period to
determine the subsequent monitoring frequency.
Figure 6-1. Flowchart of monitoring frequencies for connectors.
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Monitor for leaks within the first 3 months after the screwed connector is returned to organic
HAP service after having been opened or having the seal broken. Leaks must be repaired as
described in "What are my leak repair requirements?"
Monitoring for connectors you eliminate
If you eliminate a connector subject to repeat monitoring, you may take credit for elimination
of the connector if all of the following requirements are met [§63.174(j)]:
• The connector was welded after November 10, 1997
The integrity of the weld is demonstrated by Method 21 monitoring, X-ray testing,
acoustic monitoring, hydrotesting, or other method
• Welds created after November 10, 1997 but before June 23, 1999 are monitored or tested
by 3 months after the compliance date
• Welds created after June 23, 1999 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 exempt from the monitoring requirements
What are my compliance requirements for closed-vent systems and
control devices (Option 2)?
Requirements for closed vent systems and control devices under Option 2 include all of the
following [§§63.1363(b)(3)(ii), 63.172, and 63.179]:
• operating requirements of closed-vent systems and control devices
• inspections of closed-vent systems
• repair of leaks in closed-vent systems
• monitoring of control devices
• monitoring of bypass lines
In addition, there are exemptions to these requirements for specific types of equipment. Each of
these requirements and related exemptions are detailed below.
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Operating requirements
Closed-vent systems and control devices must be operating whenever organic HAP emissions
are being vented [§63.172(m)]. The table below summarizes the standards for control devices
(these requirements are not applicable if you transport emissions from equipment to a process):
If you operate a(n)...
Recovery or recapture
device
(e.g., condenser,
absorber, etc.)
Enclosed combustion
device
Flare
Then meet...
> 95 percent
reduction
> 95 percent
reduction
the requirements of
§63.11(b)
Or meet... Or meet...
20 ppmva
20 ppmv (dry basis, 3 minimum residence time of 0.5
percent O2) sec. at 1400°F (760°C)
a The 20 ppmv standard is not applicable if you are using option 2 for an enclosed process unit.
Inspections for closed-vent systems
You must conduct both initial and annual inspections of closed-vent systems. [§63.172(f) and
(g)]
If your closed-vent system is made of hard-piping, you must perform an initial inspection using a
leak detection instrument, and you must
perform annual sensory inspections to check for
indications of leaks based on sight, sound, or §63.180(b) of subpartH specifies how you must
0 conduct inspections using a leak detection
instrument. You have a leak if the instrument
reading is >500 ppm above background.
If your closed-vent system is made of duct
work, you must use a leak detection instrument
in both your initial and annual inspections [§63.172(f) and (g)].
Note: You do not have to inspect parts of a closed-vent system that are unsafe to monitor or difficult to monitor.
See "What if equipment is unsafe or difficult to monitor? "for more information. [§63. 1363(b)(3)(ii)(A)]
You also do not have to monitor your closed-vent system if you operate and maintain it at negative pressure.
However, you must install at least one pressure measurement device that can be read from a readily accessible
location to verify that negative pressure is maintained in the closed-vent system when the control device is
operating. [§63.1363(b)(3)(ii)(B)]
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Repair leaks
All leaks in your closed-vent system that you detect by sensory inspections or by using a leak
detection instrument must be repaired as soon as possible, unless a delay of repair is allowed.
See "What are my leak repair requirements?" (page 6-26) for more information.
Monitoring control devices
You must monitor your control device to ensure that it is operated and maintained as designed.
You must select the parameter or parameters to monitor and keep a record that explains why
each parameter was selected for monitoring. See "Records for closed-vent systems (Option 2)"
in "What records must I keep for my equipment leaks?" (page 6-29) for more information.
[§§63.172(e) and 63.1363(g)(7)(i)(D)]
Note: This requirement does not apply if you transport emissions to a process instead of a control device.
If your control device is subject to monitoring, recordkeeping, and reporting requirements in 40 CFR part 264,
subpart BB, or in 40 CFR part 265, subpart BB, then you may choose whether to comply with the monitoring,
recordkeeping, and reporting requirements of this rule or the requirements in 40 CFR parts 264 or 265. You
must identify which option you choose in your periodic report [§63.172(n)].
Monitoring bypass lines
If your closed-vent system has bypass lines that could divert a vent stream away from the control
device and to the atmosphere, you must do one of the following [§63.172(j)J:
• Use a flow indicator at the entrance of the bypass line. The flow indicator must take a
reading at least once every 15 minutes and you must keep records of the readings. See
"records for closed-vent systems (Option 2)" in "What records must I keep for my
equipment leaks?" for more information
• Secure the bypass line valve in the non-diverting position with a car-seal or a
lock-and-key type configuration. You must visually inspect the seal or closure
mechanism monthly to ensure the valve is maintained in the non-diverting position
Note: You do not have to comply with the bypass monitoring requirements for low leg drains, high point bleeds,
analyzer vents, open-ended valves or lines, and pressure reliefvalves that are needed for safety purposes.
[§63.172(j)(3)]
What are my compliance requirements for pressure testing
(Option 3)?
If you comply with the requirements for pressure testing, you are exempt from the option 1
monitoring provisions for all of the following: [§§63.1363(b)(3)(iv) and 63.178(b)]
• pumps in light liquid service
• valves in gas/vapor service and in light liquid service
6-22
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• pumps, valves, connectors, and agitators in heavy liquid service; instrumentation
systems; and pressure relief devices in liquid service
agitators in gas/vapor service and in light liquid service
connectors in gas/vapor service and light liquid service
You must comply with the Option 1 requirements for all of the following:
• sampling connection systems
open-ended valves or lines
• compressors
• pressure relief devices in gas/vapor service
You must also comply with the Option 2 requirements if closed-vent systems are used to
capture and transport leaking or purged material to a process or control device from any of the
following equipment:
• pumps
agitators
• compressors
• pressure relief devices
• sampling connection systems
For exempt process equipment, you must pressure test the equipment train for leaks each time
the equipment is reconfigured for
production of a different product. Pressure
testing is not required for routine seal
breaks, such as changing hoses or filters,
that are unrelated to reconfiguration. You
must pressure test at least once per year.
[§63.178(b)(l>]
If you pressure test, process equipment must be tested
using either of the procedures specified in:
• §63.180(j) for pressure or vacuum loss
•H§63.180(g) for a test using a liquid
6-23
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You have a leak if: [§63.178(b)(3)]
For pressure or vacuum tests... For pressure tests using a liquid...
The pressure changes at a rate greater than there are indications of liquids dripping
6.9 kilopascals (1 psig) in 1 hour or
or if there is other evidence of fluid loss.
if there is visible, audible, or olfactory
evidence of fluid loss
If you detect a leak, you must repair it and retest the equipment before start-up of the process.
See "What are my leak repair requirements?" (page 6-26) for more information.
What are my compliance requirements for alternative monitoring of
batch processes (Option 4)?
If you elect to comply with the alternative monitoring for batch equipment, you must do all of
the following:
comply with all of the compliance requirements for option 1 except:
*• less frequent monitoring may be possible for both of the following: [§63.178(c)(l)]
»*» valves in gas/vapor or light liquid service
»«• agitators in gas/vapor or light liquid service
Note: Pumps must be monitored quarterly or monthly as specified in option 1, and connectors must be
monitored annually or on a less frequent schedule as specified in option 1. [§§63.1363(b)(3)(iv)(B)
and63.178(c)(3)(ii)]
*• different reasons for delay of repair are allowed. See "What are my leak repair
requirements?" (page 6-26) for more information
• monitor for equipment leaks within 30 days after process startup when you have
reconfigured the equipment for the production of a new product. [§63.178(c)(3)(i)]
Note: These monitoring results after a process startup can not be used in determining percent leaking
equipment.
• perform monitoring that requires use of a leak detection instrument when the batch
equipment is in use with any of the following [§63.178(c)(2)]:
• organic HAP
an acceptable surrogate volatile organic §63.l80(b) of subpart Hspecifies how to
.... -TTA^. monitor jor equipment leaks using a leak
compound which IS not an organic HAP detection instrument.
any other detectable gas or vapor
6-24
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You may monitor batch valves and agitators at the following reduced frequencies
If the equipment is operated ...
0 to <25 percent of the year
25 to <50 percent of the year
50 to <75 percent of the year
75 to 100 percent of the year
And the monitoring frequency required for a continuous process is...
monthly quarterly semiannually
Then you must monitor your batch process. . .
quarterly annually annually
quarterly semiannually annually
bimonthly three times semiannually
monthly quarterly semiannually
The monitoring frequencies specified in the table above can be adjusted to accommodate your
process operations. You may monitor anytime during the monitoring period (e.g., month,
quarter, year), provided the monitoring is conducted within a reasonable time after monitoring
was last completed. For example, if the equipment is not operating during the scheduled
monitoring period, the monitoring can be done during the next period when the process is
operating. [§63.178(c)(3)(iv)]
What is required for an alternative standard (Option 5)?
You (and manufacturers of equipment used to control equipment leaks) may apply for
permission to use alternative means of emission limitation (e.g., alternative standard) to comply
with the equipment leak standards in subpart MMM. An "Alternative emission limit" is a way
of reducing emissions other than the equipment, design, or operational requirements or work
practice standards in Subpart MMM's equipment leak provisions. Some general conditions must
be met when you apply for alternative means of emission limitation, including all of the
following: [§63.177(b), (c), and (e)]:
• you are responsible for collecting and verifying emission performance test data for an
alternative limit
Note: You may offer a unique approach to demonstrate the effectiveness of your alternative [§63.177 (d)]
• the Administrator will compare test data or the demonstrated emission reduction for the
alternative means of emission limitation to test data or emission reduction for the
required PAI equipment leak standards
• if the PAI standard is a work practice, you must commit in writing to work practices that
provide the same or better emission reductions than required by Subpart MMM and you
must demonstrate the that you are meeting the emission reduction standard for at least a
1-year period.
6-25
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the Administrator may condition the permission on requirements that may be necessary
to ensure operation and maintenance to achieve the same or greater emission reduction as
the Subpart MMM equipment leak standards
What are my leak repair requirements?
Your leak repair and delay of repair requirements under Options 1, 2, 3, and 4 are detailed
below:
Option 1
Rule references for Option 1 leak repair provisions are:
§63.1363(c)(3) for pumps in light liquid service and agitators in gas/vapor or light
liquid service
§63.1363(e)(7) for valves in gas/vapor or light liquid service
§63.164(g) for compressors
§63.165(b)(l) for pressure relief devices in gas/vapor service
§63.169(c) and (d) for pumps, valves, connectors, and agitators in heavy liquid service;
instrumentation systems; and pressure relief devices in liquid service
§63.174(d) and (h) (2) and (3) for connectors in gas/vapor of light liquid service
You must repair leaking equipment as soon as possible after leaks are detected. A first attempt
to repair the leak must be made within 5 days after the leak is detected. Activities listed in
Subpart MMM as first attempts to repair leaks from pumps and valves are summarized as
follows:
For the following equipment...
First attempts to repair leaks include...
According to...
pumps/agitators in light liquid
service or heavy liquid service
tightening of packing gland nuts
ensuring the seal flush is operating at design
pressure and temperature
§§63.1363(c)(3)
and63.169(d)
valves in gas/vapor service, light
liquid service, or heavy liquid
service
tightening of bonnet bolts
replacement of bonnet bolts
tightening of packing gland nuts
injection of lubricant into lubricated packing
§§63.1363(e)(8)
and63.169(d)
Leaks must be fully repaired within 15 days after detection. However, you may delay repair of
leaking equipment under any of the following circumstances [§63.171].
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• If the repair is technically infeasible without a process unit shutdown. You may delay
repair until the end of the next process unit shutdown [§63.171(a)].
• If equipment is isolated from the process and does not remain in organic HAP service
[§63.171(b)]
• If emissions of material purged from valves, connectors, or agitators during immediate
repair would be greater than the fugitive emissions likely to result from delay of repair.
When the repair is performed the purged material must be collected and destroyed or
recovered in a control device [§63.171(c)].
• If pump repair requires replacing the existing seal with a new system that will better meet
the requirements of Option 1 or that meets Option 2. The repair must be completed as
soon as possible but not more than 6 months from the time when the leak was detected
[§63.171(d)].
• If valve assembly replacement is necessary during a process unit shutdown, but valve
assembly supplies are not on hand. You may not delay repairs beyond the next process
unit shutdown, unless a third shutdown will occur within 6 months from the first process
unit shutdown [§63.171(e)].
Option 2
Leaks in your closed-vent system must be repaired as soon as possible after leaks are detected.
A first attempt to repair the leak must be made within 5 days after the leak is detected. Leaks
must be fully repaired within 15 days after detection. However, you may delay repair of leaks in
closed-vent systems only if either of the following applies: [§63.172(h) and (i)]
• the repair is technically infeasible without a process unit shutdown
• if you determine that emissions resulting from immediate repair would be greater than the
fugitive emissions likely to result from delaying the repair
A delayed repair must be completed by the end of the next process unit shutdown. [§63.172(i)]
Option 3
If you detect a leak during pressure testing, you must repair the leak and retest the equipment
before start-up of the process. If the equipment fails the retest or the second of two consecutive
pressure tests, it must be repaired as soon as possible, but no later than 30 days after the second
pressure test. [§63.178(b)(4)]
Delaying repair of leaking equipment is allowed under option 3 if the replacement equipment
is not available and both of the following conditions are met: [§63.178(d)]
• equipment supplies (which were sufficiently stocked) have been depleted
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• the repair is made no later than 10 days after delivery of the replacement equipment
Option 4
If you detect a leak when monitoring a batch process under option 4, you must repair the leak as
soon as possible. Generally, repairs must be made no later than 15 days after you detected the
leak. However, delaying repair of leaking equipment is allowed under the same conditions as for
options. [§63.178(c)(4)and(d)]
What if equipment is unsafe or difficult to monitor? (Options 1, 2,
and 4)
If you designate the following equipment as unsafe to monitor, difficult to monitor, or
inaccessible, the equipment is exempt from the general equipment leak requirements listed in
Table 6-1 in "What compliance options do I have for my equipment leaks?" (page 6-4):
[§63.1363(f)]
• pumps in light liquid service and agitators in gas/vapor service and in light liquid
service
• valves in gas/vapor service and in light liquid service
closed-vent systems
• connectors in gas/vapor service and in light liquid service
Equipment that is unsafe to monitor
You may designate valves, connectors, agitators, and any part of a closed-vent system as unsafe
to monitor if you determine that monitoring personnel would be exposed to an immediate danger
if you comply with the equipment leak monitoring requirements. If you designate equipment as
unsafe to monitor, then you must have a written plan that requires monitoring of the equipment
as frequently as possible during safe-to-monitor times. You do not have to monitor more
frequently than the periodic monitoring schedule that would apply of the equipment were not
unsafe to monitor. [§63.1363(f)(2)]
Equipment that is difficult to monitor
You may designate valves, agitators, pumps, or any part of a closed-vent system as difficult to
monitor if you determine that either of the following are true: [§63.1363(f)(3)(i)]
• the equipment can not be monitored without elevating the monitoring personnel more
than 2 meters above a support surface
• the equipment is not accessible at anytime in a safe manner
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If you designate equipment as difficult to monitor, then you must follow a written plan that
requires monitoring of the equipment at least once per calendar year. At a new source, you may
designate no more than 3 percent of each type of equipment as difficult to monitor. No limits
apply to the percentage of equipment that can be designated as difficult to monitor at an existing
source, as long as it meets the applicable criteria. [§63.1363(f)(3)(ii) and (iii)]
Inaccessible connectors and ceramic or ceramic-lined connectors
You may designate a connector as inaccessible if it is any of the following: [§63.1363(f)(4)(i)]
• buried
• insulated in a manner that prevents access to the equipment by a monitor probe
obstructed by equipment or piping that prevents access to the equipment by a monitor
probe
• unable to be reached from a wheeled scissor-lift or hydraulic-type scaffold which would
allow access to equipment up to 7.6 meters above the ground
• not able to be accessed at any time in a safe manner to perform monitoring. Examples of
unsafe access are:
*• access requiring a wheeled scissor-lift on unstable or uneven terrain
*• access requiring a motorized man-lift basket in areas where an ignition potential
exists
*• access near hazards such as electrical lines
*• access that would risk damage to equipment
Ceramic or ceramic-lined connectors may be treated as inaccessible connectors [§63.1363(f)(l)].
At an existing source, you may designate any connector as inaccessible if it meets the applicable
criteria. At a new source, you may designate no more than 3 percent of connectors as
inaccessible. [§63.1363(f)(4)(ii)]
Inaccessible connectors observed by sight, sound, odor, or other means to be leaking must be
repaired as soon as possible. See "What are my leak repair requirements?" (page 6-26) for more
information. [§63.1363(f)(4)(iii)]
What records must I keep for my equipment leaks?
You must keep the following types of records depending on the type of equipment you use and
the compliance option you choose: [§63.1363(g)J
• general records (identification of equipment, records of exemptions, etc.)
• records of visual inspections
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• monitoring records
• records of pressure tests
• records of compressor and pressure relief valve compliance tests
• records for closed-vent systems
• records for components in heavy liquid service
• records of exempt components
• records pertaining to the division of valves in gas/vapor service and light liquid service
into process subgroups
Specific records in all of these categories are identified in Table 6-2 (page 6-31).
You only need one recordkeeping system, even you have more than one group of processes
subject to the equipment leak requirements. Keep records at the plant site in hard copy or
electronic form. All records must be kept for at least 5 years. At a minimum, the most recent 2
years of records must be retained onsite. The remaining 3 years of records may be retained
offsite. You may keep the records on microfilm, a computer, computer disks, magnetic tape
disks, or on microfiche. [§§63.1363(g)(l), 63.1367(a)(l), and 63.10(b)(l) of subpart A].
6-30
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TABLE 6-2. Recordkeeping Requirements of the Equipment Leak Provisions
Categories of records
under each option are..
Then for the following
equipment...
You must keep records of...
According to this
section of the rule.
General equipment
identification records
(All options)
equipment in organic HAP
service less than 300 hr/yr
identification of equipment
information, data, and analysis used to make the determination
§63.1363(g)(9)
all equipment in organic HAP
service for 300 hr/yr or more
(except instrumentation systems)
list of equipment identification numbers (note that the total
number of connectors in an area may be listed as a group rather
than individually)
updates to the list after equipment changes (make updates within
15 days after then end of monitoring periods for equipment that is
monitored periodically)
§63.1363(g)(2)(i)(A)
equipment in heavy liquid
service
list of identification numbers as specified above
information, data, and analysis used to determine that the
equipment is in heavy liquid service
§63.1363(g)(8)
^ Equipment-specific
identification records
(Options 1 and 4)
instrumentation systems
list of identification numbers for each instrumentation system (note
that you do not need to identify each component in an
instrumentation system)
§63.1363(g)(2)(iv)
compressors
list of identification numbers for compressors that you designate as
operating with a leak detection instrument reading of less than 500
ppm above background
§63.1363(g)(2)(ii)(B)
pressure relief devices in
gas/vapor service
list of identification numbers for pressure relief devices that will
be operated with a leak detection instrument reading of less than
500 ppm above background
list of identification numbers for pressure relief devices that have
rupture disks
§63.1363(g)(2)(iii)
valves, connectors, and agitators
that you designate as unsafe to
monitor; and valves, agitators,
and pumps that you designate as
difficult to monitor
list of identification numbers for the equipment that you designate
in each of these categories
a copy of your written plan that specifies the frequency for
monitoring this equipment
§63.1363(g)(2)(vi)
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TABLE 6-2. (cont'd)
Categories of records
under each option are..
Then for the following
equipment...
You must keep records of...
According to this
section of the rule...
valves that you assign to • identification of which valves are assigned initially to each §63.1363(e)(5)(iv)(A)
subgroups subgroup and (C)
• identification of valves that are reassigned and when they were
reassigned
Design criteria records dual mechanical seal systems for • identify design criteria that indicate failure of the seal system §63.1363(g)(2)(v)
(Options 1 and 4) pumps, agitators, and and/or barrier fluid system
compressors • an explanation of the design criteria
• any changes to the design criteria
• the reasons for any changes to the design criteria
Monitoring records connectors and valves in your schedules for monitoring these types of equipment with a leak §63.1363(g)(2)(i)(B)
(Options 1 and 4) gas/vapor and light liquid detection instrument
service
^ connectors that you remove • listof the connectors removed from or added to the process §63.1363(g)(2)(vii)
from a process so that you can • documentation of the integrity of the weld for all removed
receive credit in the percent connectors
leaking calculation
all equipment when leaks are • the instrument and the equipment identification number §63.1363(g)(4)(i)
detected using a leak detection • the operator name, initials, or identification number through (iv)
instrument • date the leak was detected
• date of the first attempt to repair the leak
• date of successful leak repair
• maximum instrument reading measured by the leak detection
instrument after the leak is successfully repaired or determined to
be non-repairable
all equipment when leak repair • reason for the delay §63.1363(g)(4)(v) and
is delayed beyond 15 days after • dates of process shutdowns during the time the equipment is (vi)
the date the leak was detected unrepaired
-------
TABLE 6-2. (cont'd)
Categories of records
under each option are..
Then for the following
equipment...
You must keep records of..
According to this
section of the rule...
opened connectors for which
you comply with the monitoring
specified in §63.174(c)(l)(i)
identification of the connectors that were disturbed since the last
monitoring period
date of follow-up monitoring
monitoring results (i.e., leak detection instrument reading)
§63.1363(g)(4)(vii)
compressors that you designate
as operating with leak detection
instrument readings less than
500 ppm above background, and
pressure relief devices in
gas/vapor service that are
returned to operating with
instrument readings less than
500 ppm above background after
pressure releases
dates of tests to verify compliance
measured background level during tests
maximum leak detection instrument reading during tests
§63.1363(g)(6)
Visual inspection
records
(Options 1 and 4)
pumps in light liquid service and occurrence and date of inspecti<
agitators in gas/vapor and light
liquid service
ion
§63.1363(g)(3)
-------
TABLE 6-2. (cont'd)
Categories of records
under each option are..
Then for the following
equipment...
You must keep records of...
According to this
section of the rule.
Closed vent system and
control device recordsa
(Option 2)
all closed vent systems and
control devices
schematics, design specifications of the control device, and piping
and instrumentation diagrams
dates and descriptions of any changes in the design specifications
for a flare: the design (i.e., steam assisted, air assisted, or
nonassisted), and the results of the compliance demonstration
required by §63.11(b)
a description of the parameter or parameters monitored to ensure
that control devices are operated and maintained as designed, and
an explanation of why each parameter was selected for the
monitoring
dates and durations when monitoring results show control device
is not operating as designed
dates and durations when the control device monitor is not
working
dates and durations of startups and shutdowns of control devices
inspections for closed vent systems that do not operate under
negative pressure:
»• if no leaks were detected, record the date of the inspection
and state that no leaks were detected
*• if leaks were detected, by either sensory observations or
using a leak detection instrument, record the same
information described above for leaks detected using a leak
detection instrument under option 1
results of bypass line monitoring when using a flow indicator:
*• hourly flow indicator records
*• times and durations of periods when the flow indicator was
not operating
*• times and durations of periods when flow was diverted from
the control device
§§63.1363(g)(7)(i),
(ii), (iii), and
63.1720(1)
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TABLE 6-2. (cont'd)
Categories of records
under each option are..
Then for the following
equipment...
You must keep records of...
According to this
section of the rule...
each enclosed process
identification of the process
identification of the HAP handled by the enclosed process
schematic of the process, enclosure, and the closed vent system
description of the system used to create a negative pressure in the
enclosure
§63.1363(g)(10)
pumps, agitators, compressors,
and pressure relief devices
equipped with closed vent
systems
identification numbers for all such equipment
§63.1363(g)(2)(ii)(A)
parts of a closed vent system
that you designate as unsafe to
monitor or difficult to monitor
a list of the designated parts of the closed vent system
a written plan for monitoring these parts of the closed vent system
§63.1363(g)(2)(vi)
Pressure test records
(Option 3)
each process equipment train
that is pressure tested
identification of each product, or product code, produced during
the calendar year
dates of each pressure test
the test pressure, and the pressure drop observed during each
pressure test
any evidence of fluid loss detected by sight, sound, or odor
§63.1363(g)(5)(i)
through (v)
each process equipment train
that does not pass two
consecutive pressure tests (i.e., it
is not successfully repaired after
a leak is detected in the first test)
date of each pressure test
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
the actual date of delivery of the replacement equipment
the date of successful repair
§63.1363(g)(5)(vi)
-------
TABLE 6-2. (cont'd)
Categories of records
under each option are..
Then for the following
equipment...
You must keep records of..
According to this
section of the rule.
Adjusted monitoring
frequency records for
batch processes
(Option 4)
each batch process complying
with option 4
identification of equipment added to the process since the last
monitoring period
date of monitoring for equipment added in reconfiguration as
specified in §63.178(c)(3)(i)
instrument reading if a leak is detected during monitoring of
added equipment, or statement indicating that monitoring was
performed if no leak is detected
the portion of time during the year that the equipment for which
the monitoring frequency is adjusted is in use in the PAI process
(e.g.,records of the time in use for individual pieces of equipment
or average time in use for the process unit)
§63.1363(g)(4)(viii)
and(g)(5)(ii)
1 If you convey emissions to a process instead of to a control device, you are subject only to the requirements for closed vent systems.
Oi
Oi
-------
What reports must I submit?
Chapter 8 describes the notifications and reports that you may need to submit, and the dates
when they must be submitted. The information that you will need to submit about equipment
leaks is described below. Most of the information that you will need to submit must be included
in the following reports:
• notification of compliance status report
periodic reports
If you decide to subgroup valves, you must also notify the Administrator at least 30 days before
the beginning of the next monitoring period. In the notification, you must identify the processes
that will be subgrouped and the valves that will be assigned to each subgroup.
[§63.1363(e)(5)(v)]
Notification of compliance status report
You must include the following information specific to equipment leaks in your notification of
compliance status report:
For each...
You must include the following information...
According to this section of
the rule...
group of processes
(all options)
identification of the group of processes
approximate number of each type of equipment (e.g.,
pumps, valves, etc.) in organic HAP service, excluding
those in vacuum service
specific method of compliance
§63.1363(h)(2)(i)
process in
compliance with
option 3
identification of products or product codes for PAI's
made in the pressure-tested equipment
planned schedule for pressure testing when the
equipment is configured for production of PAI's
§63.1363(h)(2)(ii)
enclosed process
complying with
option 2
identification of each enclosed process
a description of the system used to create a negative
pressure in the enclosure
a description of the control device used to control
emissions
§63.1363(h)(2)(iii)
Periodic report
You must include the following information about equipment leaks in your periodic reports:
6-37
-------
If you comply Include the following information in your periodic
with... Then for... reports...
According to the
following sections of
the rule...
Option 1 or 4
valves in • total number that leaked
gas/vapor or • total number monitored
light liquid • percent that leaked
service • total number not repaired
• number that are nonrepayable
• all valve reassignments among subgroups
• results of semiannual percent-leakers
calculation for groups of processes that have
subgroups
• a statement indicating the start of monthly
monitoring, if applicable
pumps in light • total number that leaked
liquid service • total number monitored
• percent that leaked
• total number not repaired
• a statement that a monthly monitoring program
was started, if applicable
agitators in
gas/vapor or
light liquid
service
connectors in
gas/vapor or
light liquid
service
§63.1363(e)(5)(vi),
(h)(3)(ii)(A),
(h)(3)(ii)(B), and
§63.1363(h)(3)(ii)(C),
(D), and (K)
total number that leaked
total number monitored
total number not repaired
§63.1363(h)(3)(ii)(C)
and(D)
compressors • total number that leaked §63.1363(h)(3)(ii)(E),
• total number not repaired (F), and (J)
• results of all monitoring to demonstrate that
compressors operate with instrument readings
<500 ppm above background
total number that leaked
total number monitored
percent that leaked
number that were not repaired
number that are nonrepairable
statement identifying a change in method of
connector monitoring for opened connectors, if
applicable
§63.1363(h)(3)(ii)(G),
(H), and (L)
pressure relief
device in
gas/vapor
results of all monitoring after a pressure release
§63.1363(h)(3)(ii)(J)
service
Option 2
all types of
equipment
closed vent
systems
• reasons for any delay of repair
• explanation of why a process shutdown was
technically infeasible
results of all annual inspections
§63.1363(h)(3)(ii)(I)
§63.1363(h)(3)(ii)(J)
6-38
-------
If you comply
with... Then for...
Include the following information in your periodic
reports...
According to the
following sections of
the rule...
Option 3
All options
the process
all types of
equipment
closed-vent
systems
all equipment
• identification of process equipment train
• number of pressure tests conducted
• number of pressure tests where either the retest
or two consecutive tests failed
reasons for any delay of repairs
results of all annual inspections
any change to information that you submitted in
your notification of compliance status report
§63.1363(h)(3)(iii)(A),
(B),and(C)
§63.1363(h)(3)(iii)(D)
§63.1363(h)(3)(iii)(E)
§63.1363(h)(3)(iv)
6-39
-------
Checklists for Equipment Leak Inspections
Facility Name:
Facility Location:
Facility TRI ID #:
Inspector:
Date:
Note: This table explains which inspection checklists you should use for determining
compliance with the equipment leak requirements.
Option For the following equipment..
Then use these
checklists:
Starting on pages .
1
Pumps in light liquid service and agitators in
gas/vapor service and in light liquid service
land 2
Connectors in gas/vapor service and in light liquid
service
land 9
6-4 land 6-43
Open-ended valves or lines
Valves in gas/vapor service and light liquid
service
Compressors
Pressure relief devices in gas/vapor service
Sampling connection systems
Pumps, valves, connectors, and agitators in heavy
liquid service; instrumentation systems; and
pressure relief devices in liquid service
Iand3
land 4
Iand5
1 and 6
land?
landS
6-4 land 6-48
6-4 land 6-49
6-4 land 6-53
6-4 land 6-57
6-4 land 6-59
6-4 land 6-60
6-4 land 6-63
2 Closed-vent systems and control devices
3 Equipment in process that is pressure tested
4 Equipment in process that complies with
alternative monitoring for batch processes
1 and 10
land 11
land 12 (and all of 2
through 9 that are
applicable)
6-4 land 6-68
6-4 land 6-73
6-4 land 6-75
6-40
-------
Checklist 1: Applicability and Identification of Equipment
Facility Name:
Facility Location:
Facility TRI ID #:
Inspector:
Date:
Note: A "yes" response to question A. 1 in this checklist means the equipment is not subject to the equipment
leak requirements in subpart MMM; all other equipment in PAI processes is subject to subpart MMM. A "yes"
response to a question in section B of this checklist means compliance with that requirement, and a "no" response
means noncompliance with the requirement.
A. Applicability
Comments
1. Do you have equipment that is used as follows:
§63.1363(a)(l), (5), (6), and (8)
• in vacuum service? D Yes D No
• in bench-scale processes? D Yes D No
• that do not contain process fluids (e.g., utilities and heating D Yes D No
and cooling systems that do not combine their materials
with process materials)?
• not in organic HAP service? D Yes D No
B. Review Records and Inspection Comments
1. Do your records identify each piece of equipment covered by
the equipment leak provisions (i.e., that are in organic HAP
service as part of a PAI process) using any combination of the
following methods: §63.1363(a)(7)
• physically tagging the equipment
• marking the equipment on a plant site plan
• marking the equipment in log entries
• designating process boundaries with waterproof
identification
• another appropriate method for identifying equipment
Note: connectors do not need to be individually identified if all
of the connectors in an area are identified as a group and the
number of connectors is identified.
You do not need to identify individual components in
instrumentation systems.
Other checklists list specific components that must be
separately identified because they meet a specific design or
operating characteristic.
DYes
DYes
DYes
DYes
DYes
DNo
DNo
DNo
DNo
DNo
6-41
-------
Checklist 1: (cont'd)
Applicability and Identification of Equipment
B. Review Records and Inspection Comments
2. Do you have records identifying all equipment in organic HAP D Yes D No
service for <300 hr/yr? §63.1363(g)(9)
Note: this equipment is not subject to any other requirements
under subpartMMM.
6-42
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Checklist 2: Requirements for pumps in light liquid service and agitators in gas/vapor and in
light liquid service (Option 1)
Facility Name:
Facility Location:
Facility TRI ID #:
Inspector:
Date:
Note: A "yes" response to a question in this checklist means compliance with that requirement, and a "no"
response means noncompliance with the requirement. If the requirement is not applicable, indicate "N/A" in the
comments column.
A. Monitoring, Inspection, and Design Requirements Comments
1. Did you monitor for leaks from each pump and agitator using D Yes D No
the method in §63.180(b)? §63.1363(c)(2)(i)
Note: pumps and agitators without an externally actuated
shaft penetrating the pump or agitator housing are exempt
from the monitoring requirement.
1. Have you performed weekly visual inspections of each pump D Yes D No
and agitator (including those equipped with dual mechanical
seals) for indications of liquids dripping from the pump or
agitator seal? §63.1363(c)(2)(iii)
Note: weekly inspections are not required for unmanned sites,
but the pumps and agitators must be inspected at least monthly.
Pumps and agitators without an externally actuated shaft
penetrating the pump or agitator housing are exempt from the
inspection requirement.
3. Did you calculate the percent of leaking pumps using the
procedure outlined in §63.1363(c)(4):
• determine all groups of processes before the end of the first D Yes D No
monitoring period?
• calculate 1-year rolling average of percent leakers (or only D Yes D No
the number leaking if there are <30 pumps in a group of
processes)?
• determine the total number of pumps in a group of D Yes D No
processes as the sum of all pumps in organic HAP service?
Note: leaking pumps in a continuous process in the first
quarter after startup do not have to be included in the percent
leaking calculation for that monitoring period.
You do not have to calculate percent leakers for pumps in a
group of processes if>90% of the pumps in the group have no
externally actuated shaft penetrating the pump housing and/or
dual mechanical seals with a barrier fluid system.
6-43
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Checklist 2: (cont'd)
Requirements for pumps in light liquid service and agitators in gas/vapor and in light liquid service
A. Monitoring, Inspection, and Design Requirements Comments
4. Did you monitor each pump monthly if (based on a 1-year D Yes D No
rolling average) the greater of either: §63.1363(c)(4)(ii)
• 10 percent of the pumps in a group of processes leak, or
• three pumps in a group of processes leak
Note: you may return to quarterly monitoring after a 1-year
rolling average no longer meets either of these conditions.
5. For pumps and agitators that you have designated as unsafe to D Yes D No
monitor or difficult to monitor, do you monitor at the frequency
specified in your written plan? §63.1363(f)
6. Does each pump and agitator equipped with a dual mechanical
seal have all of the following: §63.1363(c)(5)
• a barrier fluid system that meets one of the following: D Yes D No
*• a barrier fluid pressure that is always greater than the
pump/agitator stuffing box pressure, or
*• a barrier fluid degassing reservoir connected by a
closed-vent system to a control device, or
a closed-loop system that purges the barrier fluid into a
process stream
• a barrier fluid that is not in organic HAP service? D Yes D No
• a sensor that will detect failure of the seal system, the D Yes D No
barrier fluid system, or both?
7. For each pump and agitator with dual mechanical seals, do you D Yes D No
check the sensor daily, or does it have an alarm?
§63.1363(c)(5)(v)
8. When you observe liquids dripping from a pump or agitator D Yes D No
seal during a weekly visual inspection, did you do either of the
following: §63.1363(c)(2)(iii) and (c)(5)(iv)
stop the liquids from dripping, or
• monitor for leaks using a leak detection instrument?
9. When you detected a leak based on the results of monitoring
with a leak detection instrument, did you do both of the
following: §63.1363(a) (10)
• attach a visible, weatherproof identification to the leaking D Yes D No
pump or agitator?
• leave the identification on the pump or agitator until after D Yes D No
the leak was repaired?
6-44
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Checklist 2: (cont'd)
Requirements for pumps in light liquid service and agitators in gas/vapor and in light liquid service
B. Leak Repair Requirements Comments
1 . When you detected a leak, did you do both of the following:
§63.1363(c)(3)
• make your first attempt to repair the leak within 5 days D Yes D No
after detecting it?
• either fully repair the leak within 1 5 days after detecting it, D Yes D No
or delay repair for any of the reasons in question 2?
Note: first attempts to repair leaking pumps include tightening
of packing gland nuts and ensuring the seal flush is operating
at design pressure and temperature.
2. If you delayed repair, was it for one of the following reasons: D Yes D No
§§63.1363(b)(3)(i), (c)(3)(i), and63.171
the repair was technically infeasible without a process unit
shutdown, or
you determined that repair personnel would be exposed to
an immediate danger if attempting to repair without a
process unit shutdown, or
the equipment was isolated from the process and did not
remain in organic HAP service, or
emissions purged from the equipment during immediate
repair would be greater than emissions resulting from
delaying the repair and using a control device to reduce the
emissions, or
pump repair requires replacement of the existing seal with a
new system that will better meet the PAI rule requirements?
§63.1363(c)(3)
3. If you determined that a repair was technically infeasible or D Yes D No
would expose repair personnel to an immediate danger without
a process unit shutdown, did you complete the repair by the
end of the next process unit shutdown? §63.1363(b)(3)(i)(A)
and (B) as cross referenced by §63. 1363(c)(3)(i)
4. If you determined that emissions purged from an agitator D Yes D No
during immediate leak repair would be greater than emissions
resulting from delaying the repair, did you use a control device
to reduce emissions generated during agitator leak repair (or
otherwise collect and destroy purged material)? §63. 1 71(c) as
cross referenced by §63. 1363(c)(3)(i)
5. If you determined that pump repair required replacement of the D Yes D No
existing seal with a new system to better meet the PAI rule
requirements, did you repair the leak less than 6 months from
the time when the leak was detected? §63.171(d) as cross
referenced by §63. 1363(c)(3)
6-45
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Checklist 2: (cont'd)
Requirements for pumps in light liquid service and agitators in gas/vapor and in light liquid service
C. Recordkeeping and Reporting Requirements Comments
1. Do your records include any updates to identification numbers D Yes D No
prepared as specified in checklist 1 for pumps and agitators
subject to the LDAR requirements (option 1)?
§63.1363(g)(2)(i)(A)
Note: updates must occur within 15 days after the conclusion
of the monitoring period during which the changes occurred.
1. Do your records include the following information for each
sensor that is used to detect failure of the seal system and/or
barrier fluid system for pumps and agitators that have a dual
mechanical seal system: §63.1363(g)(2)(v)
• design criteria that indicate failure of the seal system, the D Yes D No
barrier fluid system, or both
• your explanation of the design criteria D Yes D No
• any changes to the design criteria and the reasons for the D Yes D No
changes
3 . Do your records include a list of pumps and agitators D Yes D No
designated as unsafe to monitor or difficult to monitor, and do
you have a written plan for monitoring or inspecting this
equipment? §63.1363(g)(2)(vi)
4. Do your records include the occurrence and date of each D Yes D No
weekly visual inspection for leaks in pumps and agitators?
For each leak that you detected, have you recorded:
§63. 1 363 (g) (4)
• the instrument and the equipment identification number and D Yes D No
the operator name, initials, or identification number?
• date the leak was detected? D Yes D No
• date of the first attempt to repair the leak? D Yes D No
• date of successful leak repair? D Yes D No
• maximum instrument reading measured by Method 2 1 of D Yes D No
40 CFR part 60, appendix A, after leak is successfully
repaired or determined to be non-repairable?
• all of the following if repairs were delayed beyond 15 days
after leak detection:
* reason for the delay? rj yes D No
* dates of process shutdowns that occur while the rj yes D No
equipment is unrepaired?
6-46
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Checklist 2: (cont'd)
Requirements for pumps in light liquid service and agitators in gas/vapor and in light liquid service
C. Recordkeeping and Reporting Requirements Comments
6. Did you include the following in your periodic report for each
monitoring period during the 6-month reporting period?
§63.1363(h)(3)(ii)(C), (D), (I), and (K)
• the number of pumps and agitators for which leaks were D Yes D No
detected?
• the total number of pumps and agitators monitored? D Yes D No
• the percent leaking pumps? D Yes D No
• the number of pumps and agitators for which leaks were not D Yes D No
repaired?
• the facts that explain any delay of repairs and, where D Yes D No
appropriate, why a process shutdown was technically
infeasible?
• if applicable, a statement that a monthly monitoring
program was initiated because a 1-year rolling average
showed more than 10 percent of pumps in light liquid
service (or three pumps if three is greater than 10 percent)
were leaking?
7. When any of the information regarding pumps and agitators in D Yes D No
your notification of compliance status report changes, do you
include the revised information in your next periodic report?
8. Do you keep all records for at least 5 years? §63. 1367 (a) D Yes D No
6-47
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Checklist 3: Requirements for open-ended valves or lines (Option 1)
Facility Name:
Facility Location:
Facility TRI ID #:
Inspector:
Date:
Note: A "yes" response to a question in this checklist means compliance with that requirement, and a "no"
response means noncompliance with the requirement. If the requirement is not applicable, indicate "N/A" in the
comments column.
A. Operating Requirements
Comments
1 . Have you equipped open-ended valves or lines with a cap, D Yes D No
blind flange, plug, or a second valve? §63. 1363(d)(l)(i)
1. Does the open
i end remain sealed at all times except when D Yes D No
either: §63.1363(d(l)(ii)
• operations require flow of process fluid through the
open-ended valve or line, or
• maintenance or repair is being conducted?
3. Did you replace the seal within 1 hour after completion of the
activities in question 2? §63.1363(d)(l)(ii)
DYes
DNo
DNo
4. If you equipped open-ended valves or lines with a second
valve, have you ensured that the valve on the process fluid end
is closed before the second valve is closed? §63.1363(d)(2)
B. Recordkeeping and Reporting Requirements
DYes
Comments
1. If necessary, have you updated identification numbers prepared
as specified in checklist 1 for open-ended valves or lines
subject to the LDAR requirements (option 1) to reflect
equipment changes? §63.1363(g)(2)(i)(A)
Note: updates must occur within 15 days after the conclusion
of the monitoring period during which the changes occurred.
DYes
DNo
2. When any of the information regarding open-ended valves and
lines in your notification of compliance status report changes,
do you include the revised information in your next periodic
report? §63.1363(h)(3)(iv)
DYes
DNo
3. Do you keep all records for at least 5 years? §63.1367(a)
DYes
DNo
6-48
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Checklist 4: Requirements for valves in gas/vapor service and light liquid service (Option 1)
Facility Name:
Facility Location:
Facility TRI ID #:
Inspector:
Date:
Note: A "yes" response to a question in this checklist means compliance with that requirement, and a "no"
response means noncompliance with the requirement. If the requirement is not applicable, indicate "N/A" in the
comments column.
A. Monitoring Requirements Comments
1. Did you monitor for leaks from valves using the method in D Yes D No
§63.180(b) by no later than 1 year after the compliance date
(e.g., by December 23, 2004 for existing sources)?
§63.1363(e)(2)
2. Have you assigned valves to groups of processes or subgroups D Yes D No
according to the procedures outlined in §63.1363(e)(5) and (6)?
3. Have you determined the percent leakers for the group or D Yes D No
subgroup according to the procedures specified in
§63.1363(e)(5)and(6)?
4. Do you determine the length of your next monitoring period for D Yes D No
valves in your group or subgroup based on the percent leakers
calculated in question 3? §63.1363(e)(4)
5. If you subgroup valves, do you determine the overall D Yes D No
performance of valves in the group of processes from which the
subgroups were developed every 6 months? §63.1363(e)(5)(iii)
and (e)(6)(ii)
6. If you subgroup valves and the overall group of processes from D Yes D No
which the subgroups were developed has >2 percent leakers,
do you stop using the subgroups and monitor all of the valves
in the group of processes monthly? §63.1363'(e) (5) (in)
1. For valves that you have designated as unsafe to monitor or D Yes D No
difficult to monitor, do you monitor at the frequency specified
in your written plan? §63.1363(f)
8. When you detected a leak based on the results of monitoring
with a leak detection instrument, did you do both of the
following: §63.1363(a) (10)
• attach a visible, weatherproof identification to the leaking D Yes D No
valve?
• leave the identification on the valve until after it was D Yes D No
monitored as specified in §63.1363(e)(7)(iii) (i.e., within 3
months after successful repair)?
6-49
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Checklist 4: (cont'd)
Requirements for valves in gas/vapor service and light liquid service
B. Leak Repair Requirements Comments
1 . When you detected a leak, did you do both of the following:
§63.1363(e)(7)and(8)
• make your first attempt to repair the leak within 5 days D Yes D No
after detecting the leak?
• either fully repair the leak within 15 days after detecting it, D Yes D No
or delay repair for any of the reasons in question 2?
Note: first attempts to repair leaking valves include tightening
or replacement of bonnet bolts, tightening of packing gland
nuts, and injection of lubricant into lubricated packing.
1. If you delayed repair, was it for one of the following reasons: D Yes D No
§§63.1363(b)(3)(i), (e)(7)(i), and63.171
the repair was technically infeasible without a process unit
shutdown, or
you determined that repair personnel would be exposed to
an immediate danger if attempting to repair without a
process unit shutdown, or
the equipment was isolated from the process and did not
remain in organic HAP service, or
emissions purged from the equipment during immediate
repair would be greater than emissions resulting from
delaying the repair and using a control device to reduce the
emissions, or
valve assembly supplies are not on hand and valve
replacement is needed during a process unit shutdown?
3 . If you determined that a repair was technically infeasible or D Yes D No
would expose repair personnel to an immediate danger without
a process unit shutdown, did you complete the repair by the
end of the next process unit shutdown? §63. 1363(b)(3)(i)(A)
and (B) as cross referenced by §63. 1363(e)(7)(i)
4. If you determined that emissions purged from a valve during D Yes D No
immediate leak repair would be greater than emissions
resulting from delaying the repair, did you use a control device
to reduce emissions generated during leak repair? §63. 1 71 (c)
as cross referenced by §63. 1363(e)(7)(i)
5. If valve assembly supplies were not on hand during a process D Yes D No
unit shutdown when valve replacement was needed, did you
replace the valve assembly during the next process unit
shutdown (unless a third shutdown occurred within 6 months
from the first process unit shutdown)? §63. 1 71 (e) as cross
referenced by §63. 1363(e)(7)(i)
6-50
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Checklist 4: (cont'd)
Requirements for valves in gas/vapor service and light liquid service
B. Leak Repair Requirements
Comments
6. If you made repairs to valves, did you monitor the valves at
least once while the valves were in organic HAP service within
the first 3 months after the repairs were made (in addition to the
monitoring that verifies repair was successful)?
§63.1363(e)(7)(iii)
C. Recordkeeping and Reporting Requirements
DYes
DNo
Comments
1. Do your records include any updates to identification numbers
prepared as specified in checklist 1 for valves subject to the
equipment leak requirements? §63.1363(g)(2)(i)(A)
Note: updates must occur within 15 days after the conclusion
of the monitoring period during which the changes occurred.
DYes
DNo
2. Do your records include a valve monitoring schedule?
§63.1363(g)(2)(i)(B)
DYes
DNo
3. Do your records include all of the following information
pertaining to assignment of valves to process subgroups:
§63.1363(e)(5)(iv)
• which valves are assigned to each subgroup? D Yes D No
• monitoring results and calculations made for each subgroup D Yes D No
for each monitoring period?
• which valves have been reassigned and when they were D Yes D No
reassigned?
• results of the semiannual overall performance calculation D Yes D No
for the group of processes?
4. Did you notify the Administrator of the decision to subgroup D Yes D No
valves earlier than 30 days before the beginning of the
monitoring period? (The notification must identify the
participating processes and the valves assigned to each
subgroup.) §63.1363(e)(5)(v)
5. Do your records include a list of valves that you designated as D Yes D No
unsafe to monitor or difficult to monitor, and do you have a
written plan for monitoring or inspecting this equipment?
I63j_363(^(2)(vi)_
6. For each leak that you detected, have you recorded:
§63.1363 (g) (4)
• the instrument and the equipment identification number and D Yes D No
the operator name, initials, or identification number?
• date the leak was detected? D Yes D No
• date of the first attempt to repair the leak? D Yes D No
• date of successful leak repair? D Yes D No
6-51
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Checklist 4: (cont'd)
Requirements for valves in gas/vapor service and light liquid service
C. Recordkeeping and Reporting Requirements Comments
• maximum instalment reading measured by Method 21 of D Yes D No
40 CFR part 60, appendix A, after leak is successfully
repaired or determined to be non-repairable?
• all of the following if repairs were delayed beyond 15 days
after leak detection:
* reason for the delay? D Yes D No
*• dates of process shutdowns that occur while the D Yes D No
equipment is unrepaired?
7. Did you include all of the following in your periodic report for
each monitoring period during the 6-month reporting period?
§63.1363(h)(3)(ii)(A), (B), (I), and (K)
• the number of valves with leaks detected? D Yes D No
• the total number of valves monitored? D Yes D No
• the percent leakers? D Yes D No
• the number of valves with leaks that were not repaired and D Yes D No
the number of those valves that are non-repairable?
• the facts that explain any delay of repairs and, where D Yes D No
appropriate, why a process shutdown was technically
infeasible?
• if applicable, a statement that a monthly monitoring D Yes D No
program was initiated if 2 percent or more valves leak in a
group of processes that has subgroups?
8. Did you include the following information in your periodic
report: §63.1363(e)(5)(vi)
• valve reassignments that occurred during the reporting D Yes D No
period?
• results of the semiannual overall performance calculation? D Yes D No
9. When any of the information regarding valves in your D Yes D No
notification of compliance report changes, do you include the
revised information in you next periodic report?
§63.1363(h)(3)(iv)
10. Do you keep all records for at least 5 years? §63.1367(a) D Yes D No
6-52
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Checklist 5: Requirements for compressors (Option 1)
Facility Name:
Facility Location:
Facility TRI ID #:
Inspector:
Date:
Note: A "yes" response to a question in this checklist means compliance with that requirement, and a "no"
response means noncompliance with the requirement. If the requirement is not applicable, indicate "N/A" in the
comments column.
A. Design and Monitoring Requirements Comments
1 . Are your compressors equipped with a seal system that D Yes D No
includes a barrier fluid system to prevent leaks of process fluid
to the atmosphere? §63.164(a)
Note: this requirement does not apply to compressors that you
designate as operating with a leak detection instrument
reading of less than 500 ppm above background.
1. Does each compressor seal system meet any of the following: D Yes D No
§63.164(b)
• operated with the barrier fluid pressure greater than the
compressor stuffing box pressure, or
• equipped with a barrier fluid system degassing reservoir
that is routed to a process or fuel gas system or connected
by a closed-vent system to a control device, or
• equipped with a closed-loop system that purges the barrier
fluid directly into a process stream
3.
4.
Is each barrier fluid in heavy liquid service? §63.164(c)
Is the barrier fluid system equipped with a sensor that will
detect failure of the seal system, barrier fluid system, or both
the seal and barrier fluid system? §63.164(d)
DYes
DYes
DNo
DNo
5. Have you observed the barrier fluid system failure sensor daily D Yes D No
(unless the sensor has an alarm or the equipment is at an
unmanned plant site)? §63.164(e)
6. For each compressor that you designated to operate with an
instrument reading of less than 500 ppm above background,
have you monitored using a leak detection instrument to
demonstrate compliance with the 500 ppm limit at all of the
following times:. §63. 164ft)
• upon designation? D Yes D No
• annually? D Yes D No
• any other times requested by the Administrator? D Yes D No
6-53
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Checklists: (cont'd)
Requirements for compressors
A. Design and Monitoring Requirements
Comments
7. When your sensor detected a failure (i.e., a leak), did you do
both of the following: §63.1363(a)(10)
• attach a visible, weatherproof identification to the leaking
compressor?
• leave the identification on the compressor until after the
leak was repaired?
DYes
DYes
DNo
DNo
B.
1.
2.
Leak Repair Requirements
When a sensor detects a failure, did you do both of the
following: §63.164(g)
• make your first attempt to repair the leak within 5 days D Yes D No
after detecting it?
• either fully repair the leak within 15 days after detecting it, D Yes D No
or delay repair for any of the reasons in question 2?
If you delayed repair, was it for one of the following reasons: D Yes D No
Comments
§§63.1363(b)(3)(i)(A) and (B), 63.164(g)(l), and 63.171
• the repair is technically infeasible without a process unit
shutdown?
• you determined that repair personnel would be exposed to
an immediate danger if attempting to repair without a
process unit shutdown?
• the equipment was isolated from the process and does not
remain in organic HAP service?
3. If you determined that a repair was technically infeasible or
would expose repair personnel to an immediate danger without
a process unit shutdown, did you complete the repair by the
end of the next process unit shutdown? §63.1363(b)(3)(i)(A)
and (B) as cross referenced by §63.164(g)(l)
C. Recordkeeping and Reporting Requirements
DYes
DNo
Comments
1. If necessary, have you updated identification numbers prepared
as specified in checklist 1 for compressors subject to the LDAR
requirements (option 1) to reflect equipment changes?
§63.1363(g)(2)(i)(A)
DYes
DNo
2. Do your records include identification numbers for
compressors that you designated as operating with an
instrument reading of less than 500 ppm above background
§63.1363(g)(2)(ii)(B)
DYes
DNo
6-54
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Checklists: (cont'd)
Requirements for compressors
C. Recordkeeping and Reporting Requirements Comments
3. Do your records include all of the following information for
each sensor used to detect failure of the compressor system
and/or barrier fluid system: §63.1363(g)(2)(v)
• design criteria that indicates failure of the seal system D Yes D No
and/or the barrier fluid system?
•
•
your explanation of the design criteria?
any changes to the design criteria and the
changes
reasons for the
D
D
Yes
Yes
D
D
No
No
4. For each leak that you detected, did you record:
§63.1363 (g) (4)
• date the leak was detected? D Yes D No
• date of the first attempt to repair the leak? D Yes D No
• date of successful leak repair? D Yes D No
• maximum instrument reading measured by Method 21 of D Yes D No
40 CFR part 60, appendix A, after leak is successfully
repaired or determined to be non-repairable?
• whether the repair is delayed for more than 15 days after D Yes D No
leak discovery and the reason for the delay?
• all of the following if repairs were delayed beyond 15 days
after leak detection
* reason for the delay? D Yes D No
* dates of process shutdowns that occur while the D Yes D No
equipment is unrepaired?
5. Did you record all of the following for each test used to
demonstrate compliance with the 500 ppm limit for designated
compressors: §63.1363(g)(6)
• date of each test? D Yes D No
• measured background level? D Yes D No
• maximum instrument reading? D Yes D No
6-55
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Checklists: (cont'd)
Requirements for compressors
C. Recordkeeping and Reporting Requirements Comments
6. Do you include all of the following in your periodic report for
each monitoring period during the 6-month reporting period?
§63.1363(h)(3)(ii)(E), (F), and (J)
• the number of compressors for which leaks were detected? D Yes D No
• the number of compressors for which leaks were not D Yes D No
repaired?
• the facts that explain any delay of repairs and, where D Yes D No
appropriate, why a process shutdown was technically
infeasible?
• the results of all monitoring to show compliance with the D Yes D No
500 ppm limit for compressors designated to operate below
500 ppm?
7. When any of the information regarding compressors in your D Yes D No
notification of compliance status report changes, do you
include the revised information in you next periodic report?
§63.1363(h)(3)(iv)
8. Do you keep all records for at least 5 years? §63.1367(a) D Yes D No
6-56
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Checklist 6: Requirements for pressure relief devices in gas/vapor service (Option 1)
Facility Name: _
Facility Location: _
Facility TRI ID #: _
Inspector: _
Date: _
Note: A "yes" response to a question in this checklist means compliance with that requirement, and a "no"
response means noncompliance with the requirement. If the requirement is not applicable, indicate "N/A" in the
comments column.
A. Monitoring Requirements Comments
Note: You are exempt from the requirements for pressure relief devices in gas/vapor service if your pressure
relief device is routed to a process. § 63. 165 (c)
1. Do your pressure relief devices have either: §§63. 165 (a) and D Yes D No
63. 165 (d)
a leak detection instrument reading of less than 500 ppm
above background (except during pressure releases) when
monitored using the method in §63. 180(c), or
• a rupture disk upstream of the pressure relief device?
2. Following a pressure release, do you either: D Yes D No
• monitor your pressure relief device within 5 days after a
pressure release and return of the pressure relief device to
organic HAP service to ensure a reading of less than 500
ppm above background, or §63. 165 '(b)
• place a rupture disk upstream of your pressure relief device
within 5 days following the pressure release? §63. 165 '(d)
Note that if you install a rupture disk, you are exempt from
monitoring for 500 ppm.
B. Recordkeeping and Reporting Requirements Comments
1 . If necessary, have you updated identification numbers prepared D Yes D No
as specified in checklist 1 for pressure relief devices subject to
the LDAR requirements (option 1) to reflect equipment
changes?
1. Do your records include identification numbers for pressure D Yes D No
relief devices that are either of the following:
§63.1363(g)(2)(iii)
subject to the LDAR requirement to operate with an
instrument reading of <500 ppm, or
• equipped with rupture disks?
6-57
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Checklist 6: (cont'd)
Requirements for pressure relief devices in gas/vapor service
B. Recordkeeping and Reporting Requirements Comments
3. Did you record all of the following for each test used to
demonstrate compliance with the 500 ppm operating limit:
§63.1363 (g) (6)
• date of each test?
• measured background concentration?
• maximum instrument reading?
DYes
DYes
DYes
DNo
DNo
DNo
4. Have you included the results of monitoring with a leak D Yes D No
detection instrument after pressure releases in your next
periodic report? j63.1363(h)(3)(ii)(J)
5. When any of the information regarding pressure relief devices D Yes D No
in your notification of compliance status report changes, have
you included the revised information in your next periodic
report? §63.1363(h)(3)(iv)
6. Do you keep all records for at least 5 years? §63.1367(a) D Yes D No
6-58
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Checklist 7: Requirements for sampling connection systems (Option 1)
Facility Name:
Facility Location:
Facility TRI ID #:
Inspector:
Date:
Note: A "yes" response to a question in this checklist means compliance with that requirement, and a "no"
response means noncompliance with the requirement. If the requirement is not applicable, indicate "N/A" in the
comments column.
A. Design Requirements Comments
Note: In-situ sampling systems and sampling systems without purges are exempt from the requirements for
sampling connection systems. §63.166(c)
1. Do each of your sampling connection systems have a closed- D Yes D No
purge, closed-loop, or closed-vent system? §63.166(a)
1. Do the closed-purge, closed-loop, or closed-vent systems do D Yes D No
one of the following: §63.166(b)
• return the purged process fluid directly to the process line
from which it was removed, or
• collect and recycle purged process fluid to any process, or
• capture and transport purged process fluid to a control
device, or
• collect, store, and transport purged process fluid to a waste
management unit, TSDF, or permitted waste management
facility?
B. Recordkeeping and Reporting Requirements Comments
1. If necessary, have you updated any identification numbers D Yes D No
prepared as specified in checklist 1 for sampling connection
systems subject to the LDAR requirements (option 1) to reflect
equipment changes? §63-1363 (§)(}) ft) W_
1. When any of the information regarding sampling connection D Yes D No
systems in your notification of compliance status report
changed, did you include the revised information in your next
periodic report? §63.1363(h)(3)(iv)
3. Do you keep all records for at least 5 years? §63.1367(a) D Yes D No
6-59
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Checklist 8: Requirements for pumps, valves, connectors, and agitators in heavy liquid service;
instrumentation systems; and pressure relief devices in liquid service (Option 1)
Facility Name:
Facility Location:
Facility TRI ID #:
Inspector:
Date:
Note: A "yes" response to a question in this checklist means compliance with that requirement, and a "no"
response means noncompliance with the requirement. If the requirement is not applicable, indicate "N/A" in the
comments column.
A. Monitoring Requirement
Comments
1. After detecting a potential leak by sensory observations, do you
either: §63.169(a) and (c)(3)
• monitor for leaks using the method in § 63.180(b) within
5 days after the potential leak is detected, or
• repair the leak such that any of the following are true:
you can no longer see, hear, smell, or otherwise detect
the potential leak, or
you see no bubbles at potential leak sites during a leak
check with soap solution, or
the system will hold a test pressure?
DYes
DNo
2. When you detected a leak based on the results of monitoring
with a leak detection instrument, did you do both of the
following: §63.1363(a) (10)
• attach a visible, weatherproof identification to the leaking
equipment?
• leave the identification on the equipment until after the leak
was repaired?
B. Leak Repair Requirements
DYes
DYes
DNo
DNo
Comments
1. When you detected a leak, did you do both of the following:
§63.169(c)(l)and(2)
• make your first attempt to repair the leak within 5 days
after detecting it?
• either fully repair the leak within 15 days after detecting it,
or delay repair for any of the reasons in question 2?
Note: examples of first attempts to repair leaking valves
include tightening or replacement of bonnet bolts, tightening of
packing gland nuts, and injection of lubricant into lubricated
packing. Examples of first attempts to repair leaking pumps
include tightening of packing gland nuts and ensuring the seal
flush is operating at design pressure and temperature.
DYes
DYes
DNo
DNo
6-60
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Checklists: (cont'd)
Requirements for pumps, valves, connectors, and agitators in heavy liquid service; instrumentation
systems; and pressure relief devices in liquid service
B. Leak Repair Requirements Comments
2. If you delayed repair, was it for one of the following reasons: D Yes D No
§§63.1363(b)(3)(i), 63.171, and63.169(c)(l)
• the repair was technically infeasible without a process unit
shutdown, or
• you determined that repair personnel would be exposed to
an immediate danger if attempting to repair without a
process unit shutdown, or
• the equipment was isolated from the process and did not
remain in organic HAP service, or
• emissions purged from valves, connectors, or agitators
during immediate repair would be greater than emissions
resulting from delaying the repair and using a control
device to reduce the emissions, or
• pump repair required replacement of the existing seal with
a new system that will better meet the PAI rule
requirements, or
• valve assembly replacement was necessary during a process
unit shutdown, but valve assembly supplies were not on
hand even though they had been sufficiently stocked before
being depleted?
3 . If you determined that a repair was technically infeasible or D Yes D No
would expose repair personnel to an immediate danger
without a process unit shutdown, did you complete the repair
by the end of the next process unit shutdown?
§§63.1363(b)(3)(i) and 63.169(c)(l)
4. If you determined that emissions purged from valves, D Yes D No
connectors, or agitators during immediate leak repair would
be greater than emissions resulting from delaying the repair,
did you use a control device to reduce emissions generated
during leak repair? §63. 1 71 (c) as cross referenced by
5 . If you determined that pump repair required replacement of the D Yes D No
existing seal with a new system to better meet the PAI rule
requirements, did you repair the leak less than 6 months from
the time when the leak was detected? §63. 1 71 (d) as cross
referenced by §63. 169(c)(l)
6. If valve assembly supplies were not on hand during a process D Yes D No
unit shutdown when valve replacement was needed, did you
replace the valve assembly during the next process unit
shutdown (unless a third shutdown occurred within 6 months
from the first process unit shutdown)? §63. 1 71 (e) as cross
referenced by §63. 169(c)(l)
6-61
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Checklists: (cont'd)
Requirements for pumps, valves, connectors, and agitators in heavy liquid service; instrumentation
systems; and pressure relief devices in liquid service
C. Recordkeeping and Reporting Requirements Comments
2. If necessary, have you updated equipment identification D Yes D No
numbers prepared as specified in checklist 1 to reflect any
equipment changes? §63.1363(g)(2)(i)(A) and (iv)
3. For each leak that you detected, have you recorded:
§63.1363(g)(4)
• the instrument and the equipment identification number and D Yes D No
the operator name, initials, or identification number?
• date the leak was detected? D Yes D No
• date of the first attempt to repair the leak? D Yes D No
• date of successful leak repair? D Yes D No
• maximum instrument reading measured by Method 21 of D Yes D No
40 CFR part 60, appendix A, after leak is successfully
repaired or determined to be non-repairable?
• all of the following if repairs were delayed beyond 15 days
after leak detection:
* reason for the delay? D Yes D No
* dates of process shutdowns that occur while the D Yes D No
equipment is unrepaired?
4. When any of the information in your notification of compliance D Yes D No
status report regarding equipment in heavy liquid service,
instrumentation systems, or pressure relief devices in liquid
service changed, did you include the revised information in
your next periodic report? §63.1363(h)(3)(iv)
5. Do you keep all records for at least 5 years? §63.1367(a) D Yes D No
6-62
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Checklist 9: Requirements for connectors in gas/vapor service and in light liquid service (Option
_0
Facility Name:
Facility Location:
Facility TRI ID #:
Inspector:
Date:
Note: A "yes" response to a question in this checklist means compliance with that requirement, and a "no"
response means noncompliance with the requirement. If the requirement is not applicable, indicate "N/A" in the
comments column.
A. Monitoring and Inspection Requirements Comments
1. Did you monitor for leaks from each connector using the D Yes D No
method in §63.180(b)? §63.174(a)
1. Did you perform initial monitoring of all connectors either: D Yes D No
• within 12 months after the compliance date at existing
sources, or §63.174(b)(l)
• within 12 months after initial start-up at new sources
(except that it does not have to be completed earlier than
June 23, 2000)? §63.174(b)(Q
3. Have you determined your percent leaking connectors using the D Yes D No
methods in §63.174(i)?
4. If you elected to take credit for elimination of a connector in
your percent leaking calculation, were all of the following
requirements met: §63.174(j)
• The connector was welded after November 10, 1997? D Yes D No
• The integrity of the weld was demonstrated by Method 21 D Yes D No
monitoring, X-ray testing, acoustic monitoring,
hydrotesting, or other method?
• Welds created after November 10, 1997 but before June 23, D Yes D No
1999 were monitored or tested by 3 months after the
compliance date?
• Welds created after June 23, 1999 were monitored or tested D Yes D No
within 3 months after being welded?
Note: If the weld is inadequate, or the connector was not
welded completely around the circumference, you can not
eliminate the connector from the monitoring requirements.
6-63
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Checklist 9: (cont'd)
Requirements for connectors in gas/vapor service and in light liquid service
A. Monitoring and Inspection Requirements Comments
5. Have you performed repeat monitoring at the time intervals D Yes D No
below that apply to you: §63.1363(b) (3) (in)
• each year (or every 2 years) if your percent leaking
connectors is >0.5%, or
• every 4 years if your percent leaking connectors is >0.25 to
0.5%, or
• every 8 years if your percent leaking connectors is <0.25%?
Note: the periodic monitoring after the initial survey is not
required for certain screwed connectors (see question 8).
6. Have you monitored connectors that have been opened or D Yes D No
have a broken seal using one of the following two options:
§63.174(c)(l)(i)and(ii)
• Monitored the connector for leaks when it is reconnected or
within the first 3 months after it is returned to organic HAP
service. If a leak was detected, you repaired the leak
(unless it is determined to be nonrepairable), or
• Did not monitor the connector and did not count the
connector as nonrepairable?
7. If you switched between the two monitoring alternatives in
question 6, did you do both of the following: §63.174(c) (1) (Hi)
• Make the switch at the end of the current monitoring period D Yes D No
(and you reported the switch)?
Complete initial monitoring in the new alternative no later D Yes D No
than 12 months after you reported the switch?
8. If you elected not to monitor screwed connectors with an D Yes D No
inside diameter of 2 inches or less that were installed before
November 10, 1997, have you done one of the following:
§63.174(c)(2)
• complied with the requirements of §63.169 of subpart H
(i.e., the same requirements as for connectors in heavy
liquid service), or
• both of the following each time the connector is opened or
has the seal broken:
* monitored for leaks within the first 3 months after the
connector is returned to organic HAP service, and
* repaired leaks detected by the monitoring?
9. For connectors that you have designated as unsafe to monitor D Yes D No
or inaccessible, do you monitor at the frequency specified in
your written plan? §63.1363'(j)
6-64
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Checklist 9: (cont'd)
Requirements for connectors in gas/vapor service and in light liquid service
A. Monitoring and Inspection Requirements
Comments
10. When you detected a leak based on the results of monitoring
with a leak detection instrument, did you do both of the
following: §63.1363(a) (10)
• attach a visible, weatherproof identification to the leaking
connector?
• leave the identification on the connector until after it was
monitored and determined to be not leaking if you comply
with§63.174(c)(l)(i), or until the leak was repaired if you
comply with §63.174(c)(l)(ii)?
B. Leak Repair Requirements
DYes
DYes
DNo
DNo
Comments
1. When you detected a leak, did you do both of the following:
§63.174(d)
2.
• make your first attempt to repair the leak within 5 days
after detecting it?
• either fully repair the leak within 15 days after detecting it,
or delay repair for any of the reasons in question 2?
If you delayed repair, was it for one of the following reasons:
DYes
DYes
DYes
DNo
DNo
DNo
§§63.1363(b)(3)(i), 63.171, and63.174(d)
• the repair was technically infeasible without a process unit
shutdown, or
• you determined that repair personnel would be exposed to
an immediate danger if attempting to repair without a
process unit shutdown, or
• the equipment was isolated from the process and did not
remain in organic HAP service, or
• emissions purged from the connector during immediate
repair would be greater than emissions resulting from
delaying the repair and using a control device to reduce the
emissions?
3. If you determined that a repair was technically infeasible or
would expose repair personnel to an immediate danger without
a process unit shutdown, did you complete the repair by the
end of the next process unit shutdown? §63.1363(b)(3)(i)(A)
and (B) as cross referenced by §63.174(d)
DYes
DNo
If you determined that emissions purged from a connector
during immediate leak repair would be greater than emissions
resulting from delaying the repair, did you use a control device
to reduce emissions generated during leak repair? §63.171 (c)
as cross referenced by §63.174(d)
DYes
DNo
6-65
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Checklist 9: (cont'd)
Requirements for connectors in gas/vapor service and in light liquid service
C. Recordkeeping and Reporting Requirements Comments
1 . Do your records include updates to the list of identification D Yes D No
numbers prepared as specified in checklist 1 for connectors
subject to LDAR requirements (option 1)?
§63.
1. Do your records include a schedule for monitoring connectors? D Yes D No
3 . Do your records include a list of connectors that you D Yes D No
designated as unsafe to monitor or inaccessible, and do you
have a written plan for monitoring or inspecting these
connectors? l63-1363(g)(})
-------
Checklist 9: (cont'd)
Requirements for connectors in gas/vapor service and in light liquid service
C. Recordkeeping and Reporting Requirements Comments
6. Did you include the following in your periodic report for each
monitoring period during the 6-month reporting period:
§§63.1363(h)(3)(ii)(G), (H), (I), and (L)
• the number of connectors in gas/vapor or light liquid D Yes D No
service for which leaks were detected as described?
• the total number of connectors monitored? D Yes D No
• the percent leaking? D Yes D No
• the number of connectors in gas/vapor or light liquid D Yes D No
service for which leaks were not repaired, and the number
of those that are determined non-repairable?
• the facts that explain any delay of repairs and, where g yes D No
appropriate, why a process shutdown was technically
infeasible?
• if applicable, notification of a change in connector ^ Yes D No
monitoring alternatives for connectors that have been
opened or have broken seals?
7. When any information in your notification of compliance status D Yes D No
report regarding connectors changed, did you include the
revised information in your next periodic report?
8. Do you keep all records for at least 5 years? §63. 1367 (a) D Yes D No
6-67
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Checklist 10: Requirements for closed-vent systems and control devices (Option 2)
Facility Name:
Facility Location:
Facility TRI ID #:
Inspector:
Date:
Note: A "yes" response to a question in this checklist means compliance with that requirement, and a "no"
response means noncompliance with the requirement. If the requirement is not applicable, indicate "N/A" in the
comments column.
A. Operating Requirements
Comments
1 . Have you operated your closed-vent system and control device
at all times when organic HAP emissions are being vented?
§63.1 7 2(m)
D Yes
D No
1. If you operate a recovery or capture device (e.g., condenser,
absorber, etc.), have you met either > 95 percent reduction or
< 20 ppmv? §63.1 7 2(b)
Note: The 20 ppmv standard is not applicable if you have
enclosed the process unit.
D Yes
D No
3 . If you operate an enclosed combustion device, have you met
either >95 percent reduction, <20 ppmv (dry basis, 3 percent
oxygen), or a minimum residence time of 0.5 sec. at 1400°F
(760°C)? §63.172(c)
D Yes
D No
4. If you operate a flare, have you met the requirements of
§63. 11 (b)? §63. 17 2 (
D Yes
D No
D No
5 . If you have enclosed a process unit, do you maintain your
enclosure under negative pressure at all times? §63. 1 79
B. Monitoring and Inspection Requirements
D Yes
Comments
1. If your closed-vent system is made of hard-piping, did you
perform annual sensory inspections for indications of leaks
based on sight, sound, or odor? §63.172(f)(l)(ii)
Note: the inspection is not required if the closed-vent system
operates under negative pressure.
D Yes
D No
2. If your vapor collection system or closed-vent system is made
of duct work, did you conduct annual inspections using a leak
detection instrument according to the procedures in
§63.180(b)? §63.172(f)(2)(ii) and (g)
Note: the inspection is not required if the closed-vent system
operates under negative pressure.
D Yes
D No
6-68
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Checklist 10: (cont'd)
Requirements for closed-vent systems and control devices
B. Monitoring and Inspection Requirements
Comments
3. If your closed-vent system has bypass lines that could divert a
vent stream away from the control device and to the
atmosphere, have you done one of the following: §63.172(j)
• Used a flow indicator that takes a reading at least once
every 15 minutes at the entrance of the bypass line, or
Secured the bypass line valve in the non-diverting position
with a car-seal or a lock-and-key type configuration?
Note: Low leg drains, high point bleeds, analyzer vents,
open-ended valves or lines, and pressure relief valves needed
for safety purposes are not subject to the monitoring
requirements for bypass lines. §63.172(j)(3)
DYes
DNo
4. If you secured the bypass line valve in the non-diverting
position as specified in question 3, did you visually inspect the
seal or closure mechanism monthly to ensure the valve is
maintained in the non-diverting position? §63.172(j)(2)
DYes
DNo
5 If your closed-vent system is designed to operate below
atmospheric pressure, have you installed a pressure
measurement device in a readily accessible location?
§63.1363(b)(3)(ii)(B)
C. Leak Repair Requirements
DYes
DNo
Comments
1. When you detected a leak, did you do both of the following:
§63.172(h)
• make your first attempt to repair the leak within 5 days
after detecting it?
• either fully repair the leak within 15 days after detecting it,
or delay repair for any of the reasons in question 2?
DYes
DYes
DNo
DNo
DNo
2. If you delayed repair, was it for one of the following reasons:
§63.172(1)
• the repair was technically infeasible without a process unit
shutdown, or
• emissions resulting from immediate repair of the leak
would be greater than the fugitive emissions likely to result
from delay of repair?
DYes
3. If you determined that a repair was technically infeasible
without a process unit shutdown, did you complete the repair
by the end of the next process unit shutdown? §63.172 ft)
DYes
DNo
6-69
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Checklist 10: (cont'd)
Requirements for closed-vent systems and control devices
D. Recordkeeping and Reporting Requirements Comments
1. Do your records of identification numbers prepared as specified
in checklist 1 indicate each component in the following
categories of equipment that are equipped with a closed-vent
system and comply with option 2: §63.1363(g)(2)(ii)(A)
• pumps in light liquid service?
• agitators in gas/vapor and light liquid service?
• compressors?
• pressure relief devices in gas/vapor service?
DYes
DYes
DYes
DYes
DNo
DNo
DNo
DNo
2. If necessary, do your records include updates to the list of D Yes D No
identification numbers prepared as specified in checklist 1 to
reflect any equipment changes? §63.1363(g)(2)(i)(A)
3. Do your records identify parts of closed-vent systems that you D Yes D No
designated as unsafe to monitor or difficult to monitor, and do
you have a written plan for monitoring or inspecting this
equipment? §63 -
4. When your sensory inspections or monitoring using a leak
detection instrument identified a leak in a closed vent system,
have you recorded: §63. 1363(g)(4) and (7)(iii)(B)
• the instrument and the equipment identification number and D Yes D No
the operator name, initials, or identification number (if
applicable)?
• date the leak was detected? D Yes D No
• date of the first attempt to repair the leak? D Yes D No
• date of successful leak repair? D Yes D No
• maximum instrument reading measured by Method 2 1 of D Yes D No
40 CFR part 60, appendix A, after leak is successfully
repaired or determined to be non-repairable?
• all of the following if repair was delayed:
* reason for the delay? D Yes D No
* dates of process shutdowns that occur while the D Yes D No
equipment is unrepaired?
6-70
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Checklist 10: (cont'd)
Requirements for closed-vent systems and control devices
D. Recordkeeping and Reporting Requirements Comments
5. If you use a flow indicator to monitor your closed-vent system
bypass line, do you have all of the following records:
§63.172(j)
• hourly flow indicator readings? D Yes D No
• times and durations of periods when the flow indicator was D Yes D No
not operating?
• times and durations of periods when the vent stream was D Yes D No
diverted form the control device?
6. Do your records include all of the following design and
performance documentation for control devices:
§63.1363(g)(7)(i)
• detailed schematics, design specifications of the control D Yes D No
device, and piping and instrumentation diagrams?
• the dates and descriptions of any changes in the design D Yes D No
specifications?
• for flares: a description of the flare design (i.e., steam D Yes D No
assisted, air assisted, or nonassisted) and the results of the
compliance demonstration required by §63.11(b)?
• a description of the parameter or parameters monitored to D Yes D No
ensure that control devices are operated and maintained as
designed and an explanation of why each parameter was
selected for the monitoring?
7. If you enclose a process, do you keep records of all of the
following: §63.1363(g) (10)
• identification of the process and the organic HAP it
handles?
• a schematic of the process, enclosure, and closed-vent
system?
• a description of the system used to create a negative
pressure in the enclosure?
DYes
DYes
DYes
DNo
DNo
DNo
Do your records include all of the following operational
information for closed vent systems and control devices:
§63.1363(g)(7)(ii)
• dates and durations when the closed-vent systems and D Yes D No
control devices are not operated as designed, as indicated
by the monitored parameters (including periods when a
flare pilot light system does not have a flame)?
• dates and durations when the monitor is not operating? D Yes D No
• dates and durations of startups and shutdowns of control D Yes D No
devices?
6-71
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Checklist 10: (cont'd)
Requirements for closed-vent systems and control devices
D. Recordkeeping and Reporting Requirements Comments
9. If you detect no leaks during an visual inspection of a closed D Yes D No
vent system, do you keep a record that the inspection was
performed, the date of the inspection, and a statement that no
leaks were detected? §63.1363(g) (7) (in) (A)
10. Do your periodic reports include the following for each
monitoring period during the 6-month reporting period:
§63.1363(h)(3)(ii)
• the facts that explain any delay of repairs of a closed vent D Yes D No
system and, where appropriate, why a process shutdown
was technically infeasible?
• the results of all monitoring to show compliance with the D Yes D No
provisions for inspections of closed vent systems?
11. For any control device that is subject to RCRA requirements, D Yes D No
ave you identified in your periodic report whether you are
complying with the monitoring, recordkeeping, and reporting
requirements in either: §63.172(n)
• 40 CFR part 264, subpart BB, or in 40 CFR part 265,
subpart BB, or
• subpart MMM (the PAI rule)?
12. When any of the information in your notification of compliance D Yes D No
status report regarding equipment equipped with a closed vent
system, closed-vent systems, enclosures, or control devices
changed, did you include the revised information in your next
periodic report? §63.1363(h)(3)(iv)
13. Do you keep all records for at least 5 years? §63.1367(a) D Yes D No
6-72
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Checklist 11: Requirements for pressure testing (Option 3)
Facility Name:
Facility Location:
Facility TRI ID #:
Inspector:
Date:
Note: A "yes" response to a question in this checklist means compliance with that requirement, and a "no"
response means noncompliance with the requirement. If the requirement is not applicable, indicate "N/A" in the
comments column.
A. Monitoring and Inspection Requirements
Comments
1. Do you perform pressure testing each time the equipment is
reconfigured for production of a different product (using the
procedures in §63.180(f) for pressure or vacuum loss or
§63.180(g) for a test using liquid)? §63.178(b) (1)
Note: After equipment is reconfigured, only the new or
disturbed equipment must be pressure tested. Also, pressure
testing is not required for routine seal breaks.
D Yes D No
2. Regardless of how often equipment is reconfigured, do you
pressure test at least once per year? §63.178(b)(l)(iii)
B. Leak Repair Requirements
D Yes D No
Comments
1. If you detected a leak during pressure testing, did you do one of D Yes D No
the following: §63.178(b) (4)
• repair the leak and retest the equipment before process
start-up, or
• repair the leak within 30 days after the second pressure test
if the equipment failed the second test?
2. If you delayed repair of leaks for equipment in a process that
was pressure tested, did all the following circumstances apply :
§63.178(d)
• replacement equipment was not available? D Yes D No
• equipment supplies (which were sufficiently stocked) have D Yes D No
been depleted?
• the repair is made no later than 10 days after delivery of the D Yes D No
replacement equipment?
C. Recordkeeping and Reporting Requirements Comments
1. Do you have records of all of the following: §63.1363(g) (5)
• identification of each product, or product code, produced D Yes D No
during the calendar year?
• identification of equipment in the process on a plant site D Yes D No
plan, in log entries, or by other appropriate methods?
6-73
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Checklist 11: (cont'd)
Requirements for pressure testing
C. Recordkeeping and Reporting Requirements Comments
• the dates of each pressure test, the test pressure, and the D Yes D No
pressure drop observed during the test?
• records of any evidence of fluid loss detected by sight, D Yes D No
sound, or odor?
• all of the following information if a process equipment train
failed two consecutive pressure tests (this information must
be kept for 2 years):
* The dates of each pressure test and leak repair attempt? D Yes D No
*• Repair methods applied in each attempt to repair the D Yes D No
leak?
* The reason for the delay of repair? D Yes D No
* The expected date for delivery of the replacement D Yes D No
equipment?
* The actual date of delivery of the replacement D Yes D No
equipment?
* The date of successful repair? D Yes D No
2. Does your periodic report include all of the following
information: §63.1363 (h) (3) (Hi)
• product process equipment train identification?
• the number of pressure tests conducted?
• the number of pressure tests where the equipment train
failed either the retest or two consecutive pressure tests?
• explanation for any delay of repair?
• the results of all monitoring to determine compliance with
the standards for inspection of closed-vent systems?
DYes
DYes
DYes
DYes
DYes
DNo
DNo
DNo
DNo
DNo
3. When any of the information in your notification of compliance D Yes D No
status report regarding pressure testing changed, did you
include the revised information in your next periodic report?
§63.1363(h)(3)(iv)
4. Do you keep all records for at least 5 years (except as noted D Yes D No
above)? §63.1367(a)
6-74
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Checklist 12: Requirements for alternative monitoring of batch processes (Option 4)
Facility Name:
Facility Location:
Facility TRI ID #:
Inspector:
Date:
Note: A "yes" response to a question in this checklist means compliance with that requirement, and a "no"
response means noncompliance with the requirement. If the requirement is not applicable, indicate "N/A" in the
comments column. Also use checklists 2 through 9 for each type of equipment in the process, except where
questions in this checklist conflict (e.g., use this checklist for the delay of repair requirements, and there is no first
attempt at repair requirements under option 4).
A. Monitoring and Inspection Requirements
Comments
1. Did you monitor batch equipment for leaks when equipment is
in organic HAP use or use with an acceptable surrogate or
detectable gas or vapor in accordance with both of the
following intervals: §63.178(c)(3)
• within 30 days of process start-up each time the equipment
is reconfigured for production of a new product?
• at the frequencies specified in §63.178(c)(3)(iii)?
B. Leak Repair Requirements
DYes
DYes
DNo
DNo
Comments
1. When you detected a leak, did you repair the leak within no
more than 15 days after the leak was detected (unless you met
the delay of repair provisions)? §63.178(c) (4)
D Yes D No
2. If you delayed repair of leaks, did all the following
circumstances apply: §63.178(d)
• replacement equipment was not available?
• equipment supplies (which were sufficiently stocked) have
been depleted?
• the repair is made no later than 10 days after delivery of the
replacement equipment?
C. Recordkeeping and Reporting Requirements
DYes
DYes
DNo
DNo
D Yes D No
Comments
1. Do your records include a list of equipment added to batch
processes since the last monitoring period?
§63.1363(g)(2)(viii)
DYes
DNo
2. Do your records include the monitoring date and results for
equipment added to a batch process since the last monitoring
period? §63.1363(g)(4)(viii)
DYes
DNo
6-75
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Checklist 12: (cont'd)
Requirements for alternative monitoring of batch processes
C. Recordkeeping and Reporting Requirements Comments
3. Do your records demonstrate the proportion of time during the D Yes D No
calendar year that the equipment is in use for a process or
processes subject to subpart MMM? §63.1363(g)(5)(ii)
Note: 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 only required for equipment for which you
adjust the monitoring frequency.
4. When any of the information in your notification of compliance D Yes D No
status report regarding processes for which you comply with
option 4 changed, did you include the revised information in
your next periodic report? §63.1363(h)(3)(iv)
5. Do you keep all records for at least 5 years? §63.1367(a) D Yes D No
6-76
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Chapter 7 - Sample calculations
What calculations are required by Subpart MMM?
Subpart MMM requires a variety of calculations to demonstrate compliance. The specific
calculations that you must conduct depend on the design and operation of your affected source
and the compliance options you choose. For example, you may be required to calculate any of
the following five items:
• Uncontrolled emissions from
individual process vents Uncontrolled process vent emissions are used to determine if a
process has Group 1 or Group 2 process vents.
• Flow-weighted average
flowrate for "large" process
vents
• Controlled emissions at the outlet of condensers that are control devices
Supplemental gas correction for compliance with outlet concentration limits
• Difference between inlet and outlet concentrations of a substance in cooling water used
in heat exchange systems
Examples of these five calculations are provided in this chapter and in cited references. The
calculations of process vent emissions are based on the data for a fictional process provided in
Table 7-1. These data are not intended to represent any particular process and are not
necessarily even physically viable. The data were created only for the purpose of illustrating the
types of calculations that may be required by Subpart MMM.
TABLE 7-1. Operational and Emissions Data for a PAI Process
Type of
process vent
Reactor
Emission
event
charging
heatup
Duration of
emission event,
min/batch
15
180
HAP emissions,
Ibftatch
discharged per methanol methylene emissions,
batch chloride Ib/yr3
200 gal 0.034 21
displaced
0.1281bmoleaiib 0.097 58
7-1
-------
TABLE 7-1. (cont'd)
Type of
process vent
Extraction
Holding
tank for
aqueous
phase
Crystallizer
for organic
phase
Centrifuge
for organic
phase
Dryer
Emission
event
charge
material from
reactor
charge
extraction
solvent
charging
charging
charging
air drying
Duration of
emission event,
mm/batch
75
30
60
45
45
180
Amount of gas
discharged per
batch
1,200 gal
displaced
400 gal
displaced
850 gal
displaced
700 gal
displaced
700 gal
displaced
3,000 scfm
HAP emissions,
tt^atch
methanol methylene
chloride
0.19
0.063 9.9
0.25 0.19
0.2 9
0.2 9
20 180
l otal H AF
emissions,
Ib/yr3
114
5,978
264
5,520
5,520
120,000
a Annual emissions based on 600 batches per year.
" See example 7.4 for the calculation of this value.
How do I calculate uncontrolled process vent emissions?
Section 63.1365(c)(2) specifies equations to use to estimate uncontrolled emissions from 7 types
of emission events. Examples illustrating the use of each of these equations are presented in
"Methods for Estimating Air Emissions From Chemical Manufacturing Facilities." This
document, currently in draft form, is chapter 16 of volume II in the Emission Inventory
Improvement Program series, and it may be downloaded from EPA's CHIEF page at:
www.epa.gov/ttn/chief/eiip/techreport/index.htmffireview (Look under Volumes and Chapters
under review). Example calculations for displacement and heatup emission events for the
process described in Table 7-1 are also presented below. Examples 7.1 and 7.2 calculate vapor
displacement emissions from charging material to a vessel using Equation 9 to subpart MMM,
which is written as follows:
E =
V
7 = 1
7-2
-------
where:
E = mass of HAP emitted
V = volume of gas displaced from the vessel
R = ideal gas law constant
P; = partial pressure of the individual HAP
n = number of HAP compounds in the emission stream
MW; = molecular weight of individual HAP in the emission stream
Section 63.1365(c)(2)(i)(D) in Subpart MMM specifies two alternative procedures for estimating
emissions from heating the contents of a
vessel to temperatures less than the
boiling point. One approach uses the
procedures and equations described in
§63.1365(c)(2)(i)(D)(7) and (2) of
Subpart MMM. The second approach is
specified in §63.1365(c)(2)(i)(D)(4) and
uses equations 15 through 17 in
§63.1365(c)(2)(i)(D)(0 and equation 14
in §63.1365(c)(2)(i)(D)(7), which are written
Note that equations 14 through 17 in Subpart MMM are
written for situations where HAP are the only volatile
components in the vessel. If other compounds are also
volatile (e.g., water), then the partial pressure terms in the
equations must include those compounds as well as the HAP.
Example 7.3 in this chapter (see page 7-6) illustrates how to
use the second approach in such a situation.
as follows:
E =
HAP
x In
tl
- Y p
T L^ i,\
(F)(fr) 1 1
\ft
flAP, 2
HAP
HAP
,,) =
V
i=\
Pr - Z Pa
v i=\
(R)(T2)
V
i=l
i=l
where:
E = mass of HAP emitted
MWHAP = average molecular weight of HAP compounds
Navg = average gas space molar volume during the heating process
PT = total pressure in the vessel
7-3
-------
P;i = partial pressure of individual HAP compounds at Tt
Pi2 = partial pressure of individual HAP compounds at T2
nHAF,i = number of moles of total HAP in the vessel headspace at Tt
nHAF,2 = number of moles of total HAP in the vessel headspace at T2
V = volume of free space in the vessel
R = ideal gas law constant
Tj = initial temperature of the vessel contents, absolute
T2 = final temperature of the vessel contents, absolute
n = number of HAP compounds in the emission stream
Example 7.1: Displacement emissions (one liquid phase)
Table 7-1 indicates that 200 gallons of methanol are charged to the reactor. The following data
and assumptions were used in estimating the methanol emissions from this event:
• Assume 800 gal of water (370 Ibmole) and 200 gal of non-HAP organic compounds (20
Ibmole) are added before the 200 gal (40 Ibmole) of methanol. Therefore, the methanol
mole fraction is 0.095 when the charging is complete.
• Temperature of the reactor contents is 25°C.
• Assume vapor space is in equilibrium with the final liquid mixture for the entire time
methanol is being charged.
• Vapor pressure of methanol at 25°C is 125 mmHg.
• Estimate partial pressure of methanol using Raoult's law and the final composition of
material in the reactor as follows:
pmethanoi = (xmeaumol)(Methanol vapor pressure)
= (0.095)(125/H/w//g)
= 11.9 mmHg
• Estimate methanol emissions using Equation 9 in Subpart MMM as follows:
(200ga/)(/f3 / 7.48ga/)(l L9mmHg)(32lb I Ibmole)
E =
(999 ft3 • mmHg I Ibmole • K)(298K)
= 0.034 Ib I batch
7-4
-------
Example 7.2: Displacement emissions (two liquid phases)
Table 7-1 indicates that the reactor output and 400 gal of methylene chloride are charged to the
extractor. The following data and assumptions are used to estimate the methylene chloride and
methanol emissions while the methylene chloride is charged:
• Methylene chloride is charged after the material from the reactor has been charged.
• Assume contents of reactor are still at an elevated temperature of 37°C when the
methylene chloride is added.
• Vapor pressure of methylene chloride at 37°C is 677 mmHg.
• Vapor pressure of methanol at 37°C is 228 mmHg.
• Since methylene chloride forms a separate phase, estimate HAP partial pressures
assuming equilibrium between the vapor space and each phase separately
> for the methylene chloride phase, assume no material is extracted while methylene
chloride is being added so that partial pressure of methylene chloride is the same as the
pure component vapor pressure.
> for the water/methanol/other organic compounds phase, assume some of the
methanol was consumed in the reactor so that the methanol mole fraction is now about
0.05. Using Raoult's law, the partial pressure of methanol is estimated to be about
11.4 mmHg.
• Estimate methylene chloride emissions using Equation 9 in Subpart MMM as follows:
_ (400ga/)(/f3 / 7A8gal)(677mmHg)(85lb I Ibmole)
(999ft3 • mmHg I Ibmole • K)(310 K)
= 9.9 lb/batch
• Estimate methanol emissions using Equation 9 in subpart MMM as follows:
(400gal)(ft3 / 7.48gal)(l 1.4 mmHg)(32 lb I Ibmole)
E =
(999ft" • mmHg I Ibmole • K)(310 K)
= 0.063 lb I batch
7-5
-------
Example 7.3: Heatup emissions
Table 7-1 indicates that the reactor contents are heated after all
of the raw materials have been added, and heat is applied for 3
hours. The following additional data and assumptions are used
to estimate the methanol emissions during this event:
• The vessel contents are heated from 25°C to 37°C.
• The reactor headspace is 5,000 gallons.
• Vapor pressure, mole fraction, and partial pressure data:
Seepage 7-3 for equations 14
through 17 in SubpartMMM.
Initial conditions at T, (25°Q
Final conditions at X, (37°Q
Condensable
component
water
methanol
vapor
pressure,
mmHg
24
125
liquid
mole
fraction3
0.858
0.095
partial
pressure,
mmHgb
20.3
11.9
vapor
pressure,
mmHg
47
228
liquid
mole
fraction0
0.858
0.095
partial
pressure,
mmHg
40.3
21.7
a Assume the balance is other organic compounds that have negligible vapor pressure.
" Partial pressures calculated using Raoult's law.
c Assume the vessel contents reach 37°C before any significant reaction occurs so that the mole
fractions at the initial and final temperatures are equal (the temperature is then maintained at 37°C
until the reaction is complete).
Estimate Navg using equation 16 as follows:
_ (5,OOOga/)(/;3 / 7A8gal)(76QmmHg)
avg ~ (2)(999 ft3 • mmHg I Ibmole • K) *
= 1.673 Ibmole
Estimate (n^p i2-%Ap ,1) using equation 17 as follows:
/7.48 gar/)
+
298 K 3 1 0 K)
(5,OOOga/X./?3/7.48gap
(999 ft3 • mmHg I Ibmole •
= 0.0617 Ibmole
21.7 mmHg)
(203mmHg + 11.9 mmHg)
7-6
-------
Estimate MWHAP using equation 14 as follows:
(11.9 + 21.7)(32/6 / Ibmole) + (20.3 + 40.3)(18/6 / Ibmole)
MWHAP
(11.9+21.7)+(20.3+40.3)
= 23 lb/Ibmole
• Estimate emissions of all condensable compounds using equation 14 (without MWHAP)
as follows:
( ( 760mmHg - (20.3mmHg + 11.9 mmHg)) )
E = 1.613Ibmole x In ^—^ — - 0.0617Ibmole
( \ 760 mmHg - (40.3 mmHg + 21.7 mmHg)} j
= 0.00846 Ibmole condensable components I event
• If all of the condensable compounds were HAP, we could multiply the total Ibmoles
emitted by MWj^p to estimate the total mass of HAP emitted. For this example,
however, only one condensable component (methanol) is HAP. Therefore, we can use
the average of the initial and final partial pressures to determine the fraction of the
emissions that is methanol. The average water partial pressure is 30.3 mmHg, and the
average methanol partial pressure is 16.8 mmHg. Therefore, 64 percent of the total
Ibmoles emitted is water and 36 percent is methanol. The total mass of methanol
emitted is then estimated as follows:
E = (0.00846 totallbmole)(0.36)(32 lb I Ibmole}
- 0.097lb methanol emitted I batch
How do I determine if process vents are Group 1 or Group 2?
According to the definition of "Group 1 process vent" in §63.1361 of Subpart MMM, all of the
process vents in a process are Group 1 if the sum of the organic HAP emissions from all process
vents is at least 0.15 Mg/yr (330 Ib/yr) and/or the sum of the HC1 and C12 emissions is at least
6.8 Mg/yr (15,000 Ib/yr). For the example process described by the data in Table 7-1, the
emission streams from each unit operation are process vents because their HAP concentrations
are greater than 50 ppmv (see definition of process vent in §63.1361). All of these process vents
also are Group 1 process vents because the total annual emissions of organic HAP are well above
0.15 Mg/yr.
Note: Although the process itself generates no HCl or C12, if the methylene chloride
emissions are controlled using an incinerator, you would need to determine the amount of
HCl generated by burning the methylene chloride. If that amount (plus any from the
process itself) exceeds 6.8 Mg/yr, which it would for the dryer emissions in the example
7-7
-------
process, then you would have to meet the control requirements for HCl and C12 in §63.1362
of Subpart MMM.
How do I calculate the flow-weighted average flowrate for "large"
process vents?
At existing sources, process vents that meet certain criteria are subject to more stringent control
requirements than other process vents (see "What compliance options do I have for my Group 1
process vents?" on page 3-3). To determine which process vents are subject to the more
stringent control requirement, Subpart MMM requires you to calculate the flow-weighted
average flowrate of process vents using equation 1 in §63.1362(b)(2). If this value is less than or
equal to the flowrate calculated using equation 2 in §63.1362(b)(2), then you must reduce
organic HAP emissions from the process vent by 98 percent. In practice, the calculation is only
required for vents with uncontrolled organic HAP emissions that exceed 50,000 Ib/yr because the
flowrate calculated using equation 2 is only realistic (i.e., a positive value) for higher emission
rates. Equations 1 and 2 are written as follows:
FR = — Eq-1
a n
ID,
i=l
FR = 0.02 x (HL) - 1,000 Eq. 2
where:
FRa = flow-weighted average flowrate for the vent, scfm
D; = duration of each emission event, min
FR; = flowrate of each emission event, scfm
n = number of emission events
FR = calculated flowrate, scfm
HL = annual uncontrolled organic HAP emissions, Ib/yr, as defined in §63.1361
For the example process in Table 1, only the dryer vent has uncontrolled organic HAP emissions
that exceed 50,000 Ib/yr. Since there is only one emission event associated with this vent, the
flow-weighted average flowrate for the vent is simply the actual flowrate out of the dryer, or
3,000 scfm. The next step is to compare this value to the flowrate calculated using equation 2 as
follows:
FR = (0.02X//Z) - 1,000
= (0.02)(120,000 Ib/yr)- 1,000
= 1,400 scfm
7-8
-------
Since the actual flowrate (3,000 scfm) is greater than the value calculated using equation 2, the
dryer vent is not a "large" vent and is not subject to the 98 percent control requirement.
The equation 1 calculation would be more complicated if the process vent consists of numerous
types of emission events. For example, the reactor process vent in Table 7-1 consists of two
emission events. Similarly, if vents from multiple vessels are connected to a common manifold
for discharge from a single point, then the collective emission stream is the process vent. For
example, if the emissions from the extraction vessel and crystallizer in Table 7-1 are combined,
then the process vent consists of the combined stream. In both of these scenarios for the process
in Table 7-1 there would be no need to calculate the flow- weighted average flowrates because
we know the total uncontrolled emissions are less than 50,000 Ib/yr. However, the following
calculation for the reactor vent in Table 7-1 is presented to illustrate the procedure for using
equation 1:
15min+ ISOmin
= QAlscfin
Note: In this calculation, the 200 gallons displaced during charging is equal 26. 7 ft3', or
an average flowrate of 1. 78 scfm over the 15-minute charging period. Also, the 0.128
Ibmole of air displaced as the reactor contents are heated is equal to 50 standard cubic
feet. For saturated conditions at the final reactor temperature, the partial pressures of
water and methanol in the reactor are 40. 3 mmHg and 21. 7 mmHg, respectively. Thus, the
total amount of displaced gas is 54 standard cubic feet. Over the 180 minutes that the
reactor is heated, the average discharge rate is about 0.3 scfm.
How do I calculate controlled emissions out of a condenser?
Section 63.1365(c)(3)(iii) of Subpart MMM describes procedures and equations to calculate
controlled emissions at the outlet of a condenser. For example, use equations 29 and 12 in
Subpart MMM to calculate emissions from a condenser used to control emissions from a heatup
event. Equations 29 and 12 read as follows:
Eq.29
PT ~ I
j=l
7-9
-------
Eq. 12
-^ V -* i / V -*2 '
where:
E = mass of HAP emitted
Ar| = moles of noncondensable gas displaced
PT = pressure in the receiver
P; = partial pressure of the individual HAP at the receiver temperature
Pj = partial pressure of the individual condensable compounds at the receiver
temperature
n = number of HAP compounds in the emission stream
V = volume of free space in the vessel
R = ideal gas law constant
Pal = initial noncondensable gas pressure in the vessel
Pa2 = final noncondensable gas pressure in the vessel
Tj = initial temperature of vessel contents (absolute)
T2 = final temperature of vessel contents (absolute)
Example 7.4: Condenser-controlled reactor heatup emissions
Suppose emissions during heatup of the reactor in Table 7-1 are routed to a condenser that is
operated at 10°C. The following data and assumptions were used in estimating the controlled
methanol emissions for this emission event:
• The headspace volume of the reactor is 5,000 gal.
• Example 7.3 presents partial pressures at the initial and final reactor temperatures. Use
these values in equation 12 to calculate Ar| as follows:
(5,000£a/)(//3 /7.48gal)
AT? =
^
999ft3 • mmHg I Ibmole • K
760 - 20.3 - 1 \.9mmHg)\ ( 760 - 40.3 -
298K J 31QK
= 0.128 Ibmole air
The water and methanol vapor pressures at the condenser receiver temperature of 10°C
are 9 mmHg and 54 mmHg, respectively.
Assuming the methanol and water are the only components in the receiver and they are
present in the same ratio as in the reactor during heatup (i.e., 90 percent water and 10
percent methanol), then water and methanol partial pressures for the receiver are 8.2
mmHg and 5.4 mmHg, respectively.
7-10
-------
Calculate the methanol emissions using equation 29 as follows (note that since
methanol is the only HAP, P; and MWj^p simplify to the applicable values for
methanol):
5. .4
E = 0.128 x x 32
760 - (8.2 + 5.4)
= 0.03 Ib methanol I batch
How do I correct concentration measurements to account for
supplemental gases?
If you elect to comply with an outlet concentration limit for process vents or storage tanks, you
may have to adjust the measured concentration to account for dilution caused by combination of
the affected vent streams with other gas streams
(i.e., "supplemental gases") that are not subject ^OM comP^ with the alternative standard (°Ption
, „ 11- • c- • o A ^, 4 or 8 in chapter 3), then you have alternatives to
tOCOntrol. See the discussion for options 2, 4, 7, the supplemental gas correction. See "How do I
and 8 in the section "How do I show initial monitor to comply with the alternative standard? "
compliance with the process vent requirements?" on page 3-18 for more information..
beginning on page 3-8 for the definition of
"supplemental gases" and the compliance requirements. The specific correction methodology
depends on whether the control device is a combustion device or a noncombustion device.
For combustion devices, you must correct the measured concentration to 3 percent oxygen using
equation 7 in §63.1365(a)(7)(i) to Subpart MMM as follows:
r r ( 179 I
C = C \ Eq.7
m(20.9-%O2d:
where:
Cc = concentration of TOC, total organic HAP, or total HC1 and chlorine corrected to 3
percent oxygen, dry basis, ppmv
Cm = total; concentration of TOC, total organic HAP, or total HC1 and chlorine in the
vented gas stream, average of samples, dry basis, ppmv
%O2d = concentration of oxygen measured in vented gas stream, dry basis, percent by
volume
7-11
-------
For noncombustion devices, correct the measured concentration to account only for the specific
amount of supplemental gases add using equation 8 in §63.1365(a)(7)(ii) to Subpart MMM as
follows:
V + V
C =C I — I Eq. 8
n m I y r I l
^ a
where:
Ca = corrected outlet TOC, total organic HAP, or total HC1 and chlorine concentration,
dry basis, ppmv
Cm = actual TOC, total organic HAP, or total HC1 and chlorine concentration measured
at the control device outlet, dry basis, ppmv
Va = total volumetric flow rate of affected streams vented to the control device
Vs = total volumetric flow rate of supplemental gases
Example 7.5: Supplemental gas correction for combustion device
Suppose that some of the process vents in Table 7-1 are controlled using a thermal incinerator
and you plan to comply with the 20 ppmv outlet concentration limit (Option 2 in chapter 3). You
must conduct a performance test to demonstrate compliance with the concentration limit. The
test is conducted under the absolute peak-case condition, which is determined to be the
maximum 1-hr loading to the incinerator. Since your system design includes the introduction of
a small amount of supplemental air under these conditions, you also measure the oxygen content
of the outlet gas stream at the same time you measure the total organic HAP concentration (as
specified in §63.1365(a)(7)(i)(C) of Subpart MMM). If you found the average of the measured
organic HAP concentrations to be 8 ppmv, and the average O2 concentration was 17 percent,
would you be in compliance with the outlet concentration emission limit? Use equation 7 to
Subpart MMM as follows:
= 37 ppmv
Therefore, the process vent would not be in compliance with the 20 ppmv outlet concentration
limit.
Example 7.6: Supplemental gas correction for noncombustion device
Suppose the process vents in example 7.5 were routed to a noncombustion device. The average
measured outlet concentration from the performance test is 13 ppmv, the average process vent
flowrate is 2 scfm, and you measure the supplemental gases flow rate to be 0.4 scfm. Correct the
measured concentration using equation 8 to Subpart MMM as follows:
7-12
-------
2 J
= \5.6ppmv
This system would be in compliance with the 20 ppmv outlet concentration limit.
How do I determine if I have a heat exchange system leak when
complying with option HE1?
The section "What are my compliance options for heat exchange systems?" beginning on page
5-30 indicates that a leak is detected under option HE1 when the exit mean concentration is
determined to be greater than the entrance mean concentration using a one-sided statistical test at
the 0.05 level of significance, and the amount by which the exit is greater is at least 1 ppmw or at
least 10 percent of the entrance concentration, whichever is greater.
Example 7.7: Checking heat exchange system for leaks
Suppose you have collected the following HAP concentration data for your heat exchange
system (note that you must collect at least three sets of samples):
Entrance concentration, Exit concentration,
Sample number ppmw ppmw
1
2
3
Mean
18
23
28
23
24
26
28
26
Step 1: The first step is to check the arithmetic difference between the entrance and exit means.
In this example, the difference is 3 ppmw, which exceeds both of the criteria (1 ppmw and 10
percent of the entrance mean). Therefore, we must proceed to step 2 to determine if there is a
statistically significant difference between the means.
Step 2: The second step is to determine if there is a statistical difference between the means at
the 0.05 level of significance. In this example our null hypothesis is that the two means are
equal. Since our sample size is small, we have an equal number of entrance and exit samples,
and we are assuming the population is normally distributed, the statistical procedure to use is the
T statistic for differences between means:
7-13
-------
(X,-X7)-d
rri \ 1 2. / O 7
I | and
v = nl + n2 - 2 and
and
w(w-l)
where:
T = T statistic value
Xj = mean exit concentration of the sample
X2 = mean entrance concentration of the sample
d0 = difference between the means for the null hypothesis (zero in this case)
Sp = pooled sample standard deviation (square root of the pooled sample variance)
nt = number of exit samples
n2 = number of entrance samples
v = degrees of freedom
Sp2 = pooled sample variance
S;2 = sample variances (i=l for exit and i=2 for entrance)
X; = individual entrance and exit sample concentrations
The entrance sample variance is:
(3)(182 + 232 + 282) - (18+ 23+ 28)2
-------
The pooled sample variance is:
(3 - 1)(25) + (3 - 1)(4)
*>= 3+3-2
= 14.5
The pooled standard deviation is the square root of the pooled sample variance, or 3.80.
The T statistic is then:
(26-23)-0
(3.8)(l/3+l/3)0'5
= 0.965
In this example, we have 4 degrees of freedom. According to tabulated values of the T statistic,
for 4 degrees of freedom and a 0.05 level of significance, the critical region is T>2.132. Since
our calculated T is outside the critical region, we accept the null hypothesis and conclude that the
exit and entrance means are not statistically different.
Since the means are not statistically different, the heat exchange system in this example does not
have a leak under Subpart MMM.
7-15
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[This page intentionally left blank.]
-------
Chapters - Recordkeeping and reporting
What records must I keep?
You will need to keep several types of records to
document compliance with various requirements in the YOU must retain all records for at least 5
rule. Most of the records that you will need to keep are years. [§§63.lO(b)(l)and63.l367(a)(l)]
listed in Table 8-1 (page 8-4).
In addition to these records, you must also develop both of the following written plans and
maintain the plans onsite:
• a startup, shutdown, and malfunction plan
(S SMP) that describes procedures you will You must keep super ceded versions of the
follow during such events and describes SSMP as well as the current version.
actions you will take to correct [§§63-I367(a)(3) and 63.6(e)(3)(v)]
malfunctions [§63.1367(a)(3)]
• a plan for inspecting all parts of a closed-vent system, cover, fixed-roof, or enclosure
that you designate as either unsafe-to-inspect or difficult-to-inspect
[§§63.1366(h)(6)(ii) and (7)(ii) and 63.1367(f)(l) and (2)]
If you use a fabric filter to comply with particulate matter emission limits for a bag dump or
product dryer (see "What compliance options do I have for process vents that emit particulate
matter?" on page 3-6 for applicability), then you must also develop and maintain the following
plans:
• an operation and maintenance plan that describes
proper operation and maintenance procedures for
,, r-i-r-1, 11 i 11,, If you are required to develop these
the fabric filter and bag leak detector. ,,, ,, , ... *, .,,
° plans, they must be submitted with your
precompliance plan (see Table 8-4 on
• a corrective action plan that describes corrective page 8-12 for information to include in
actions to be taken (and the timing of those your precompliance plan.
actions) when the particulate matter ^63- 1368(e)(6)]
concentration exceeds the setpoint and activates
the bag leak detector alarm.
If you comply with option HE2 for a heat exchange system, you must develop and maintain a
monitoring plan (see page 5-32 for a description of the information to include in your monitoring
plan).
8-1
-------
What do I have to report and when?
You will need to complete several different notifications and reports based on the types of
emission points at your facility and the compliance options you choose. The term "reports" is
used in this section to include both notifications and reports. Tables 8-2 and 8-3 (pages 8-10 and
8-11) show what reports you must submit and when they are due. Table 8-4 (page 8-12) gives
you details about what should be included in these reports.
How can I change the date my reports are due?
Under the General Provisions, §63.10(a)(5), you may request a change in the date you submit
your reports. You and your EPA Regional Office or State, local, or Tribal agency for air
pollution control (from now on referred to as "State") must mutually agree to the change, and the
change can not affect the frequency that you report. For example, semiannual reports for an
existing source are required in January and July of each year, beginning in 2005. You may
request that these dates be changed to some other time frame, such as one that coincides with
your title V operating permit notifications. This does not change your reporting frequency since
you are still submitting your semiannual reports twice per year.
Changes to reporting dates can begin 1 year after the compliance date (that is, reports required
after 12/23/04 can be changed). Reports due before 12/23/04 can not be changed and must be
reported by the date shown in Table 8-2. Contact your State for more information.
Where do I send my reports?
The General Provisions §63.9(a) and §63.10(a) require you to submit reports to your State or
your EPA Regional Office or both (dual reporting). Whom you send your reports to depends on
whether your State has been granted the authority to implement the PAI Production NESHAP.
You will need to submit reports in one of the following ways:
• to your EPA Regional Office if your State has not been delegated the authority to
implement and enforce the PAI Production NESHAP
• to you State with a copy to your EPA Regional Office, if your State has been granted
delegation and we have not waived the dual reporting requirement
• to your State if it has been granted delegation and we have waived the dual reporting
requirement
Not all State agencies have been granted delegation. Also, as of this publication, our Region I,
III, VIII, and X offices have not waived the dual reporting requirement under §63.9 and §63.10.
8-2
-------
This means if your facility is in one of the following Regions, you will need to submit your
reports to your State, local, or Tribal agency and the EPA Regional Office:
• Region I (CT, ME, MA, NH, RI, VT)
• Region III (DE, MD, PA, VA, WV, District of Columbia)
• Region VIII (CO, MT, ND, SD, UT, WY)
• Region X (AK, ID, WA, OR)
You will find a list of our Regional Offices and their addresses in Chapter 10.
You should check with your EPA Regional Office or State for the latest information about
submitting reports.
8-3
-------
TABLE 8-1. Summary of Recordkeeping Requirements^"^
For each...
And for
To comply with... which...
You must keep records of all of the following...
According to this
section of the rule..
Facility that is not
subject to subpart MMM
The applicability determination
§§63.10(b)(3)and
63.1367(a)(2)
Facility that is subject to
subpart MMM
A schedule or log of operating scenarios updated daily or, at a
minimum, each time a different operating scenario is put into
operation
§63.1367(b)(7)
You develop
process unit
groups for
processes that
are subject to
overlapping
requirements
with other rules
oo Process at a subject The use as a
•**• facility that produces a PAI is not the
material that is a PAI primary use
and has other uses
Dedicated PAI process the applicability construction
unit determination commenced
required by after 1 1/10/97
§63.1360(b)(2) or
reconstruction
commenced
after 9/20/02
• a listing of the PAI and non-P AI process units used to
establish the process unit group, and any subsequent
additions to or deletions from the list
• the operating time for each process unit used in a
determination or redetermination of the primary product for
the process unit group
• each determination and redetermination of the primary
product for the process unit group
• total production
• fraction of the total production used as a PAI
(Note that these records must be kept semiannually or more
frequently.)
number of turnovers for each storage tank that is assigned to the
PAI process unit
§§63.1360(h)(l)(vi)
and63.1367(b)(9)
§63.1367(g)
§63.1367(b)(6)(vi)
Startup, shutdown, and
malfunction event
occurrence and duration of each malfunction of process
operations or of air pollution control equipment
occurrence and duration of each malfunction of continuous
monitoring systems
all information necessary to demonstrate that procedures
specified in the SSMP were followed, or a description of
actions taken that are not consistent with the SSMP
§63.1367(a)(3)(i)-
(iii)
-------
TABLE 8-1. (cont'd)
For each...
PAI process
And for
To comply with. . . which. . .
You must keep records of all of the following...
• results of initial calculation of uncontrolled and controlled
According to this
section of the rule...
§63.1367(b)(6)
organic HAP and HC1/C12 emissions from process vents (note
that these calculations are not required if the conditions in
§63.1365(b)(ll)(iii)(D)(l) or (2) are met)
the ongoing number of batches per year for a batch process
the ongoing number of operating hours for a continuous
process
the ongoing number of batches and operating hours for a
process with both batch operations and continuous operations
a description of absolute or hypothetical peak-case operating
conditions under which performance testing of an APCD for
batch process vents is conducted
PAI process with Group
2 process vents
The daily rolling annual calculation of uncontrolled organic
HAP emissions
§§63.1366(c)and
63.1367(b)(4)
-------
TABLE 8-1. (cont'd)
For each...
To comply with...
And for
which...
You must keep records of all of the following..
According to this
section of the rule..
Wastewater stream • HAP concentrations §63.1367(b)(6)
• flowrate
APCD used to comply All options for All maintenance performed on the APCD §63.1367(b)(10)
with an emission PV; options 5A,
standard 5B, 5C, or 5Efor
ST; and options You monitor an Each measurement of the APCD operating parameter §63.1367(b)(l)
' ' ' or operating (Note: see the section "What records must I keep for my
parameter process vents? " in Chapter 3 and Table 5-5 in Chapter 5 for
parameters that must be recorded for certain APCD)
Treatment unit used to All treatment See Table 5-5 in Chapter 5 §63.1367(b)(l)
comply with a options
wastewater emission
standard
Emission suppression All emission See Table 5-5 in Chapter 5 §§63.147 and
technique for wastewater suppression 63.1362(d)
streams options
-------
TABLE 8-1. (cont'd)
For each...
CEMS used to comply
with the alternative
standard for process
vents and/or storage
tanks
And for
To comply with. . . which. . .
Option 4 or
option 8 for PV;
option 5E for ST
You must keep records of all of the following...
• calibration checks
• maintenance of the CEMS
• all of the following information required by §63 . 10(c)(l)
through (14):
*• all required CEMS measurements, including data recorded
According to this
section of the rule...
§63.1367(a)(4)and
(b)(3)
oo
during periods of unavoidable CEMS breakdowns and out-
of-control periods
date and time of each period when the CEMS was
inoperative, except for zero (low-level) and high-level
checks
date and time of each period when the CEMS was out of
control (e.g., calibration drift exceeded specification or
CEMS failed cylinder gas audit)
date, start time, and end time of each period of excess
emissions and parameter monitoring exceedances,
including identification of those during periods of startup,
shutdown, and malfunction.
the nature and cause of any malfunction, if known, and any
corrective actions taken
the nature of any repairs or adjustments to a CEMS that
was inoperative or out of control
the total process operating time during the reporting period
all procedures, including calibrations, that are part of your
quality control program
Bag leak detector used
to monitor paniculate
HAP emissions from a
fabric filter
Option 11 for PV
date and time of each bag leak detection alarm
brief explanation of the cause of the alarm
description of corrective action taken
§63.1367(b)(5)
-------
TABLE 8-1. (cont'd)
For each...
To comply with...
And for
which...
You must keep records of all of the following..
According to this
section of the rule..
oo
oo
Inspection of a closed-
vent system, cover,
fixed-roof, or enclosure
All options for
PV; options 5A,
5B, 5C, or 5E for
ST; and options
Al, A2, A3, A4,
and all emission
suppression
options for WW
a leak was
detected
identification of the leaking equipment
instrument identification number and operator name (if the
leak was detected using Method 21), or an indication that the
leak was detected by sensory observations
date the leak was detected
date of the first attempt to repair the leak
maximum instrument reading measured using Method 21
after the leak is repaired or determined to be nonrepairable
all of the following if the leak is not repaired within 15 days
after the leak was discovered
*• reason for the delay in repair
*• name, initials, or other identification of the person who
decided repair cannot be made without a shutdown
*• expected date of successful repair
dates of shutdowns that occur while the equipment is
unrepaired
date of successful repair of the leak
§63.1367(f)(4)
no leak was • date of the inspection
discovered • statement that no leaks were detected
§63.1367(f)(5)and(6)
Closed-vent system,
fixed-roof, cover, or
enclosure with
equipment that you
designate as unsafe- or
difficult-to-inspect
All options for
PV; options 5A,
5B, 5C, or 5E for
ST; and options
Al, A2, A3, A4,
and all emission
suppression
options for WW
identification of all parts of the equipment that you designate
as unsafe- or difficult-to-inspect
explanation of why the equipment is unsafe- or difficult-to-
inspect
§63.1367(f)(l)and(2)
-------
TABLE 8-1. (cont'd)
For each...
Closed-vent system or
vapor collection system
that contains a bypass
line that could divert a
vent stream away from
anAPCD
LDAR program for
equipment leaks
To comply with...
All options for
PV; options 5A,
5B, 5C, or 5E for
ST; and options
Al, A2, A3, and
A4forWW
And for
which...
You use a flow
indicator in the
bypass line
You use a seal
mechanism to
prevent
diversion
You must keep records of all of the following...
• hourly flow indicator records
• times and durations of each period when the vent stream is
diverted
• times and durations of each period when the flow indicator
was not operating
• occurrence of the monthly inspection of the seal or closure
mechanism
• occurrence of each period when the seal mechanism is
broken, the bypass line valve position has changed, or the key
for a lock-and key type lock has been checked out
• each time a car-seal has been broken
The records as specified in Table 6-2
According to this
section of the rule...
§63.1367(f)(3)(i)
§63.1367(f)(3)(ii)
§§63.1363(g)and
63.1367(c)
oo a Note that all records must be retained for at least 5 years. [§63.1367(a)(l)]
^> " The section "What provisions are described in this document?" on page 1-1 indicates that this document does not describe the requirements of the emissions
averaging and pollution prevention compliance options. Therefore, the recordkeeping associated with those options is not included in this table.
c If you have a new affected source, §63.1367(a)(5) requires you to comply with the application for approval of construction or reconstruction provisions in §63.5
of the General Provisions. This requirement is not highlighted in this table because it, like all of the requirements in the General Provisions, is discussed in
Chapter 9 of this document.
-------
TABLE 8-2. Report Due Dates for Existing Affected Sources3
If you need to submit a(n)...
Then submit the report
before...
According to this
section of the rule...
Initial Notification Report 10/23/99 §63.1368(b)
(120 days after the effective date)
Application for Approval of As soon as practicable before reconstruction §§63.1368(c) and
Construction or Reconstruction if is to commence 63.5(d)
reconstructing after 6/23/02 (effective
date)
Precompliance Plan 6/23/03 §63.1368(e)
(6 months before the compliance date)
Compliance Extension Request 8/25/03 §§63.1368(n) and
(120 days before the compliance date) 63.1364(a)(2)
Notification of continuous monitoring At least 60 days before the performance §63.1368(d)
system performance evaluation evaluation, or with the notification of the
performance test
Notification of Performance Test and 60 days before the test §63.1368(m)
Test Plan
Notification of Compliance Status 5/21/04 §63.1368(f)
Report (150 days after the compliance date)
Initial Semi-annual Periodic Report 1/17/05 (include information from 5/21/04 - §63.1368(g) and (1)
11/20/04)
Note: Quarterly reporting is required (240 days after the Notification of
if you comply with the alternative Compliance Status Report)
standard and you have excess
emissions [§63.1368(g)(l)(ii)]
Subsequent Semi-annual Periodic January 17 and July 17 of every year §63.1368(g) and (1)
Reports (60 days after each 6-month reporting
period)
Startup, Shutdown, and Malfunction Semi-annually - can submit with the periodic §63.1368(i)
Reports reports
Equipment Leak Reports Semi-annually - submit with the periodic §63.1368(j)
reports
Notification of Process Change Semiannually - submit with the next periodic §63.1368(h)
report, except reports are due at least 60 days
before either of the following:
• any change in an activity described in the
precompliance report, or
• any change in status of a control device
from small to large
a Note that the first semiannual reporting period begins on the date the notification of compliance status report is
due.
8-10
-------
TABLE 8-3. Report Due Dates for New Affected Sources3
If you need to submit a(n)...
Then submit the report
before...
According to this
section of the rule-
Initial Notification Report 120 days after initial startup, or with the §63.1368(b)
application for approval of construction
or reconstruction
Application for Approval of Construction As soon as practicable before the §§63.1368(c) and
or Reconstruction construction or reconstruction is planned 63.5(d)
to commence
Precompliance plan At least 6 months before the compliance §63.1368(e)
date
Notification of continuous monitoring At least 60 days before the performance §63.1368(d)
system performance evaluation evaluation is scheduled to begin, or with
the notification of performance test
Notification of Performance Test and Test At least 60 days before the test §63.1368(m)
Plan
Notification of Compliance Status Report 150 days afterthe compliance date §63.1368(f)
Initial Semi-annual Periodic Report" 240 days after the notification of §63.1368(g) and (1)
compliance status report is due
Note: Quarterly reporting is required if
you comply with the alternative standard
and you have excess emissions
[§?3-1368(8)(VWl
Subsequent Semi-annual Periodic semiannually-60 days after the end of the §63.1368(g) and (1)
Reports" applicable semiannual reporting period
Startup, Shutdown, and Malfunction Semiannually-can be submitted with the §63.1368(i)
Reports periodic reports, except an immediate
report is required if you take an action
that is inconsistent with your SSMP
Equipment Leak Reports Semiannually-submit with the periodic §63.1368(j)
reports
Notification of Process Change Semiannually-submit with the next §63.1368(h)
periodic report, except reports are due at
least 60 days before scheduled
implementation of either of the following:
• any change in an activity described in
the precompliance report, or
• any change in status of a control device
from small to large
a Note that Subpart MMM also includes reporting requirements for the emissions averaging option that are not
described in this document. [§63.1368(k)J
" Note that the first semiannual reporting period begins on the date the notification of compliance status report is
due.
8-11
-------
TABLE 8-4. Reporting Requirements3
If you are submitting
a(n)...
Then submit by
And include the following information, as applicable.
According to these
sections of the rule.
Request for Compliance
Extension (existing
source)
oo
to
120 days before the
compliance date
Note that you may submit a
request after this date if a
need arose after this date
and the need arose due to
circumstances beyond your
reasonable control
If you installed BACT or
technology required to
meet LAER before June 23,
1999, then you may submit
the request not later than
October 21, 1999
Description of the controls to be installed to comply with Subpart
MMM
Compliance schedule, including dates by which each step towards
compliance will be achieved, including at a minimum:
• Date by which contracts for emission control systems or
process changes for emission control will be awarded, or the
date by which orders will be issued for the purchase of
component parts to accomplish emission control or process
changes,
• Date by which on-site construction, installation of emission
control equipment, or a process change will be initiated,
• Date by which on-site construction, installation of emission
control equipment, or a process change is to be completed, and
• Date by which final compliance is to be achieved
Description of interim emission control steps that will be taken
during the extension period, including milestones to assure proper
operation and maintenance of emission control and process
equipment
Statement indicating whether you are requesting an extension of
other applicable requirements (e.g., performance testing
requirements)
If you installed BACT or technology to meet LAER, include all
information needed to demonstrate to the Administrator's
satisfaction that these controls apply to the HAP that must be
controlled under Subpart MMM
§§63.1364(a)(2),
63.1368(n), and63.6(i)(6)
-------
TABLE 8-4. (cont'd)
If you are submitting
a(n)...
Then submit by...
And include the following information, as applicable...
According to these
sections of the rule..
oo
Initial Notification
Reportb
120 days after the effective Your name and address.
date or 120 days after rule ... , , . ,, .. , - - .,..
Address (physical location) of your facility.
§63.1368(b); §63.9(b)
applies to your facility
Identification of the relevant standard (i.e., 40 CFR part 63, Subpart
MMM and your compliance date.
Brief description of nature, size, design, and method of operation.
Identify each point of emission for each HAP.
Statement of whether you are a major or area source.
Application for
Approval of
Construction or
Reconstruction
Before construction or
reconstruction
Your name and address.
Notification of your intent to construct or reconstruct.
Address (physical location) of your facility.
§63.1368(c); §63.5(d)
Identify the standard you are subject to (i.e., 40 CFR part 63,
Subpart MMM).
Date that you expect to start construction or reconstruction.
Date that you expect to finish construction or reconstruction.
Anticipated date of initial startup.
Type and amount of HAP you are emitting or expect to emit.
For construction: description of proposed nature, size, design,
method of operation and emission controls and other information
under §63.5 (d) (2).
For reconstruction: brief description of the facility, parts to be
replaced and emission controls and other information under
§63.5(d)(3).
-------
TABLE 8-4. (cont'd)
If you are submitting
a(n)...
Then submit by...
And include the following information, as applicable...
According to these
sections of the rule.
Precompliance Plan
3 months before
compliance data
Requests for approval to use alternative monitoring parameters.
Description of your daily or per batch demonstrations to verify that
control devices with inlet HAP emissions <1 ton/yr are operating as
designed.
Data and rationale used to set monitoring parameter levels for
conditions other than the peak case.
Your pollution prevention demonstration summary.
Data and rationale for engineering assessments.
Your operation and maintenance plan and corrective action plan for
fabric filters that are monitored with bag leak detectors.
§63.1368(e)
oo
Notification of
performance test and
test plan
At least 60 days before the
test
Notification of your intent to conduct a performance test.
Your test plan, including all of the following:
• summary of the test program,
• the test schedule,
• data quality objectives (i.e., pretest expectations of precision,
accuracy, and completeness of data),
• internal quality assurance (QA) program, including at a
minimum, the activities planned by routine operators and
analysts to assess test data precision (e.g., sampling and
analysis of replicate samples), and
• external QA program, including at a minimum, application of
plans for a test method performance audit during the
performance test (i.e., analysis of blind audit samples provided
by the Administrator in order to provide a measure of test data
bias); the external QA program may also include systems
audits that include the opportunity for on-site evaluation by the
Administrator of instrument calibration, data validation,
sample logging, and documentation of quality control data and
field maintenance activities.
§§63.1368(m)and63.7(c)
-------
TABLE 8-4. (cont'd)
If you are submitting
a(n)... Then submit by ..
And include the following information, as applicable...
According to these
sections of the rule.
Your emission profile (required by §63.1365(b)(ll)(iii))
Notification of
Compliance Status
Report
150 days after the
compliance date
oo
Results of applicability determinations
Results of emission profiles, performance tests, engineering
analyses, design evaluations or other calculations used to
demonstrate compliance
Anticipated periods of planned routine maintenance for control
devices used to comply with Option 5A, B, C, or E for storage tanks
Information for processes subject to the equipment leak provisions
as described in "What reports must I submit" in Chapter 6.
Descriptions of monitor devices, monitoring frequencies, and the
values of monitored parameters (and all supporting data and
calculations) established during the initial compliance
determination.
Operating scenarios; i.e., all of the following for each PAI process
unit:
• identification of each process vent and wastewater POD,
• emission episodes and their durations for each process vent,
• level of control and control devices,
• calculations and engineering analyses required to demonstrate
compliance
• description of operating and/or testing conditions for any
control devices
Descriptions of absolute or hypothetical peak-case operating and/or
testing conditions for control devices
Identification of emission points subject to overlapping
requirements with other rules, and the authority under which you
will comply.
§63.1368(1)
-------
TABLE 8-4. (cont'd)
If you are submitting
a(n)...
Then submit by...
And include the following information, as applicable...
According to these
sections of the rule.
Identification of emission points that discharge to exempt RCRA
units.
Percentage of total production from a PAI process unit that is
anticipated to be produced for use as a PAI in the 3 years after either
June 23, 1999, or startup, whichever is later.
Records of the initial process units used to create each PUG.
Semi-annual Periodic
Reports
Semi-annually no later
than 60 days after the end
of the 6-month reporting
period
oo
Your company name and address.
Identification of each HAP that you monitor at your affected source.
Beginning and ending dates of the reporting period.
Brief description of the PAI process units.
Applicable emission and operating parameter limitations specified
in Subpart MMM.
Monitoring equipment manufacturers) and model numbers.
Date of the latest CMS audit.
Total operating time of your affected source during the reporting
period.
Summary of emissions data or operating parameter data (depending
on which you monitor) including all of the following:
• total duration of excess emissions during the reporting period,
• total duration of excess emissions expressed as a percent of the
total operating time during the reporting period,
• breakdown of the total duration of excess emissions during the
reporting period into those that are due to startup/shutdown,
control equipment problems, process problems, other known
causes, and other unknown causes.
§§63.1368(g)(2)and(l)
and63.10(e)(3)(vi)(A)
through (M)
-------
TABLE 8-4. (cont'd)
If you are submitting
a(n)...
Then submit by
And include the following information, as applicable...
According to these
sections of the rule.
oo
CMS performance summary including all of the following:
• total CMS downtime during the reporting period,
• total duration of CMS downtime expressed as a percent of the
total source operating time during the reporting period,
• breakdown of total CMS downtime during the reporting period
that is due to monitoring equipment malfunctions,
nonmonitoring equipment malfunctions, quality
assurance/quality control calibrations, other known causes, and
other unknown causes.
Description of any changes to any of the following since the last
reporting period:
• CMS
• processes
• controls
The percentage of the total production in the reporting period used
as a PAI if the primary use of the material is not as a PAI
All of the following if the length of time for exceedances,
excursions, and/or CEMS downtime exceeded limits specified in
§63.1368(g)(2)(ii):
• all monitoring data for the day(s) in question
• duration of excursion
• operating logs for days when parameter averages are outside
the levels stated in the notification of compliance status report
• the following information required by §63.10(c)(5) through
(13) if you use a CEMS:
»• date and time of each period when the CEMS was
inoperative, except for zero (low-level) and high-level
checks,
-------
TABLE 8-4. (cont'd)
If you are submitting
a(n)...
Then submit by
And include the following information, as applicable...
According to these
sections of the rule.
oo
oo
*• date and time of each period when the CEMS was out of
control (e.g., calibration drift exceeded specification or
CEMS failed cylinder gas audit,
»• date, start time, and end time of each period of excess
emissions and parameter monitoring exceedances, including
identification of those during periods of startup, shutdown,
and malfunction,
*• the nature and cause of any malfunction of the monitor, if
known, and any corrective actions taken,
»• the nature of any repairs or adjustments to a CEMS that was
inoperative or out of control, and
*• the total process operating time during the reporting period.
The information listed in Table 5-7 for wastewater systems and heat
exchange systems
If a bypass line is equipped with a flow indicator, records of all
periods when a vent stream is diverted to the bypass line instead of
anAPCD.
If you use a seal mechanism to prevent diversion of a vent stream
through a bypass line instead of an APCD, records of all periods
when the seal mechanism is broken, the bypass valve position has
changed, or the key to unlock the bypass line valve was checked
out.
Statements documenting all of the following as applicable:
• no excess emissions
• no exceedances of a parameter
• no excursions
• no CEMS were inoperative, out-of-control, repaired, or
adjusted.
-------
TABLE 8-4. (cont'd)
If you are submitting
a(n)...
Then submit by
And include the following information, as applicable...
According to these
sections of the rule.
oo
VO
Both of the following if you control emissions from storage tanks
using an APCD (Option 5A, 5B, 5C, or 5E):
• actual periods of planned routine maintenance of the APCD
during the subject reporting period, and
• anticipated periods of planned routine maintenance of the
APCD during the next reporting period.
Information specified in §63.122(d) through (f) for storage tanks
equipped with floating roofs, as applicable.
Records specified in Table 8-1 for each inspection of a closed-vent
system, cover, fixed-roof, or enclosure during which a leak was
detected.
Both of the following for each process unit group:
• records of any process units added to the process unit group,
and
• results of any redetermination of the primary product.
Updates to the corrective action plan for any bag leak detection
system required by §63.1366(b)(l)(xi).
Name, title, and signature of the responsible official who is
certifying the accuracy of the report.
Date of the report.
Startup, Shutdown, and
Malfunction Reports
Startup, shutdown, and malfunction records as described in
Table 8-1
Semi-annually-can submit
with the periodic reports,
except an immediate report
is required when actions
taken differ from
procedures described in the Each immediate report must also explain circumstances of the event
SSMP for which procedures in the SSMP were not followed and indicate
whether any excess emissions and/or parameter monitoring
exceedances are believed to have occurred
§63.1368(i) and
63.10(d)(5)
Name, title, and signature of person who is certifying the accuracy
of the report
-------
TABLE 8-4. (cont'd)
If you are submitting
a(n)...
Then submit by...
And include the following information, as applicable.
According to these
sections of the rule.
Equipment Leak
Reports
Semi-annually--submit
with the periodic reports
See "What reports must I submit" in Chapter 6.
§§63.1363(h)and
63.1368(j)
oo
to
o
Notification of Process
Change
With the periodic report,
except as noted
in Table 8-2
Any of the following information, as applicable:
• A brief description of the process change
• A description of any modifications to standard procedures or
quality assurance procedures
• Revisions to any of the information reported in the original
notification of compliance status report
• Information required by the notification of compliance status
report for changes involving the addition of processes or
equipment
§63.1368(h)
a Note that Subpart MMM also includes reporting requirements for the emissions averaging option that are not described in this document [§63.1368(k) and (o)].
" If you have a new affected source that is subject to the special requirements under §63.6(b)(3) or (4), you must notify the Administrator of your compliance
obligations under those sections by the due date of the initial notification report.
-------
Chapter 9 - Other requirements and information
Who administers this regulation?
Your State or local agency for air pollution control, or your EPA Regional Office, will regulate
you. If your facility is in Indian Country, and your eligible Tribe or your EPA Regional Office
will regulate you. You may be regulated by one or more agencies depending on whether they
have been granted delegation of this rule.
Definition. An eligible Tribe means "a Tribe that has been
determined by the EPA to meet criteria for being treated in the
same manner as a State, pursuant to the regulations
implementing section 301(d)(2) of the Act"
Not all States have been granted delegation, or, if they have been granted delegation, they may
not have been delegated all portions of the rule. Our EPA Regional Offices may also have
retained certain rights even after delegation (for example, you may continue to have dual
reporting requirements as explained in Chapter 8).
The EPA has not delegated authority to approve any of the following: [§63.1369(c)]
• alternatives to the applicability requirements in §63.1360, standards in §§63.1362 and
63.1363, and compliance dates in §63.1364
Note: Where these sections of Subpart MMM reference another subpart, the cited provisions will be
delegated according to the delegation provisions of the referenced subpart. This includes cited provisions
that are modified by provisions in Subpart MMM.
• major alternatives to any of the test methods required by Subpart MMM, in accordance
with §63.7(e)(2)(ii) and (f)
major alternatives to any of the monitoring MaJor altematives to test methods
monitoring, and recordkeepmg and
required by Subpart MMM, in accordance With m requirements are defined in
§63.8(f) §63.90.
• major alternatives to any of the recordkeeping
and reporting required by Subpart MMM, in accordance with §63.10(f)
You should check with your EPA Regional Office or State for the latest information.
9-1
-------
Do I need a title V permit?
You will need a title V permit if you are subject to the Pesticide Active Ingredient NESHAP
since, under title V, you must get a permit if your facility is a major source. The Pesticide
Active Ingredient NESHAP applies to major sources.
To determine if your facility is a major source, you will need to calculate your HAP emissions
from your entire facility, not just your PAI production operations. If you do not have federally
enforceable limits in a State permit, you must calculate your emissions by determining your
potential emissions. If you need help determining if your facility is a major source or what your
potential emissions are, see the definitions in the Operating Permits Rule §70.2, or visit our title
V policy and guidance page at www.epa.gov/ttn/oarpg/t5main.html.
How do I change my permit to include this rule?
If you have already been issued a final title V permit and you have three or more years left on
your permit, your permitting authority will reopen your permit within 18 months of the
publication date of the final rule or final amendments. If you have less than three years left on
your permit, update your permit during your renewal period. If your permit has not been issued
in final form, update your application or draft permit.
To summarize, your options are as follows:
If a new rule is effective1'2
and you have...
Then...
not been issued a final title V permit
less than three years left on your permit
three or more years left on your permit
update your permit application or draft permit
update your title V permit during renewal
your permitting authority will reopen your permit within 18
months after the publication date of the final rule or final
amendments
1 The rules' effective date is the date the final rule is published in the Federal Register (which is 6/23/99 for this
rule).
2 This also applies if existing rules are modified and final amendments are published in the Federal Register.
Title V permitting rules may change after the publication of this document. Keep abreast of any
changes by checking the Federal Register or visit our title V websites at
www.epa.gov/ttn/oarpg/t5main.html and www.epa.gov/oar/oaqps/permits/.
9-2
-------
What portions of the General Provisions apply?
The General Provisions were published in the Federal Register on March 16, 1994 (Volume 59,
page 12408) and apply to all NESHAP, including the Pesticide Active Ingredient NESHAP.
This means that when you became subject to this rule, you also became subject to the General
Provisions. Some sections in this rule override the General Provisions. Table 1 to Subpart
MMM and Table 9-1 in this chapter identify which sections of the General Provisions apply to
this rule and which do not.
TABLE 9-1. General Provisions Applicability to Subpart MMM
Reference to Subpart A
Applies to
subpart MMM
Comment
§63.1(a)(l) Yes Additional terms are defined in § 63.1361
§63;l(a)(2)-(3) Yes
§63.1 (a)(4) Yes Subpart MMM (this table) specifies
applicability of each paragraph in subpart A to
subpart MMM
§63.1(a)(5) N/A Reserved
§63.1(a)(6)-(7) Yes
§63.1(a)(8) No Discusses State programs
§63.1(a)(9) N/A Reserved
§63.1(a)(10)-(14) Yes
§63.1(b)(l) No §63.1360 specifies applicability
§63.1_(b)(2)-(3) Yes
§ 63.1(c)(l) Yes Subpart MMM (this table) specifies the
applicability of each paragraph in subpart A to
sources subject to subpart MMM
§ 63.1(c)(2) No Area sources are not subject to subpart MMM
§63.1(c)(3) N/A Reserved
§63;l(c)(4)-(5) Yes
§63.1(d) N/A Reserved
§63.1(e) Yes
§ 63.2 Yes Additional terms are defined in § 63.1361;
when overlap between subparts A and MMM
occurs, subpart MMM takes precedence.
§63.3 Yes Other units used in subpart MMM are defined
in that subpart
§63.4(a)(l)-(3) Yes
9-3
-------
TABLE 9-1. (cont'd)
Reference to Subpart A
Applies to
subpart MMM
Comment
§ 63.4(a)(4) N/A Reserved
§63.4(a)(5)-(c) Yes
§ 63.5(a) Yes Except replace the terms "source" and
"stationary source" in §63.5(a)(l) of subpart A
with "affected source"
§ 63.5(b)(l) Yes
§ 63.5(b)(2) N/A Reserved
§63;5(b)(3)-(5) Yes
§ 63.5(b)(6) No § 63.1360(g) specifies requirements for
determining applicability of added PAI
equipment
§ 63.5(c) N/A Reserved
§63.5(d)-(e) Yes
§63.5(f)(l) Yes Except replace "source" in § 63.5(f)(l) of
subpart A with "affected source"
163;5(f)(2)Yes
§ 63.6(a) Yes
§63.6(b)(l)-(2) No §63.1364 specifies compliance dates
§63.6_(b)(3)-(4) Yes
§ 63.6(b)(5) Yes
§ 63.6(b)(6) N/A Reserved
§ 63.6(b)(7) Yes
§ 63.6(c)(l) - (2) Yes Except replace "source" in
§ 63.6(c)(l)-(2) of subpart A with "affected
source"
§63.6(c)(3)-(4) N/A Reserved
§ 63.6(c)(5) Yes
§ 63.6(d) N/A Reserved
§ 63.6(e) Yes Except § 63.1360 specifies that the standards in
subpart MMM apply during startup and
shutdown for batch processes; therefore, these
activities would not be covered in the startup,
shutdown, and malfunction Plan
§ 63.6(f) Yes Except § 63.1360 specifies that the standards in
subpart MMM also apply during startup and
shutdown for batch processes
9-4
-------
TABLE 9-1. (cont'd)
Reference to Subpart A
Applies to
subpart MMM
Comment
§ 63.6(g) Yes An alternative standard has been proposed;
however, affected sources will have the
opportunity to demonstrate other alternatives to
the Administrator
§ 63.6(h) No Subpart MMM does not contain any opacity or
visible emissions standards
§ 63.6(i)(l) Yes
§63.6(i)(2) Yes Except replace "source" in
§ 63.6(i)(2)(i) and (ii) of subpart A with
"affected source."
§ 63.6(1X3)-(140 Yes
§63.6(i)(15) N/A Reserved
§ 63.6(i)(16) Yes
§ 63.6© Yes
§ 63.7(a)(l) Yes
§ 63.7(a)(2)(i) - (vi) Yes § 63.1368 specifies that test results must be
submitted in the Notification of Compliance
Status due 150 days after the compliance date
§63.7(a)(2)(vii)-(viii) N/A Reserved
§63;7(a)(2)(ix)-(c) Yes
§63.7(d) Yes Except replace "source" in
§ 63.7(d) of subpart A with "affected source"
§ 63.7(e)(l) Yes §63.1365 contains test methods specific to PAI
sources
§ 63.7(e)(2) Yes
§63.7(e)(3) Yes Except § 63.1365 specifies less than 3 runs for
certain tests
§ 63.7(e)(4) Yes
§ 63.7(f) Yes
§ 63.7(g)(l) Yes Except §63.1368(a) specifies that the results of
the performance test be submitted with the
Notification of Compliance Status report
§ 63.7(g)(2) N/A Reserved
§63;7(g)(3) Yes
§ 63.7(h) Yes
§63.8(a)(l)-(2) Yes
9-5
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TABLE 9-1. (cont'd)
Reference to Subpart A
Applies to
subpart MMM
Comment
§ 63.8(a)(3) N/A Reserved
§ 63.8(a)(4) Yes
§ 63.8(b)(l) Yes
§63.8(b)(2) No §63.1366 specifies CMS requirements
§ 63.8(b)(3) - (c)(3) Yes Except the submittal date of the immediate
startup, shutdown, and malfunction reports for
CMS events shall be 2 days as in
§63.6(e)(3)(iy)
§ 63.8(c)(4) No §63.1366 specifies monitoring frequencies
§63.8(c)(5)-(8) No
§63;8(d)-(f)(3) Yes
§63.8(f)(4) Yes Except § 63.1368(b) specifies that requests
may also be included in the Precompliance
report
§ 63.8(f)(5) Yes
§ 63.8(f)(6) No Subpart MMM does not require CEM's
§63.8(g) No § 63.1366 specifies data reduction procedures
§63.9(a)-(d) Yes
§ 63.9(e) No
§63.9(f) No Subpart MMM does not contain opacity and
visible emission standards
§63;9(g) No
§ 63.9(h)(l) Yes
§63.9(h)(2)(i) Yes Except § 63.1368(a)(l) specifies additional
information to include in the Notification of
Compliance Status report
§63.9(h)(2)(ii) No § 63.1368 specifies the Notification of
Compliance Status report is to be submitted
within 150 days after the compliance date
§ 63.9(h)(3) Yes
§ 63.9(h)(4) N/A Reserved
§63.9(h)(5)-(6) Yes
§ 63.9(i) Yes
§63.9(j) No §63.1368(h) specifies procedures for
notification of changes
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TABLE 9-1. (cont'd)
Reference to Subpart A
Applies to
subpart MMM
Comment
§63.10(a)-(b)(l) Yes
§ 63.10(b)(2) No §63.1367 specifies recordkeeping requirements
§63.10(b)(3) Yes
§63.10(c) Yes
§63.10(d)(l) Yes
§63.10(d)(2) Yes
§ 63.10(d)(3) No Subpart MMM does not include opacity and
visible emission standards
§63.10(d)(4) Yes
§ 63.10(d)(5) Yes Except that actions and reporting for batch
processes do not apply during startup and
shutdown
§63.10(e)(l)-(2)(i) Yes
§63.10(e)(2)(ii) No Subpart MMM does not include opacity
monitoring requirements
§63.10(e)(3) Yes
§ 63.10(e)(4) No Subpart MMM does not include opacity
monitoring requirements
§63.10(f) Yes
§63.11-§63.15 Yes
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Chapter 10 - Getting additional help
Whom can I ask for help?
You can go to a lot of places for help, including all of the following:
• your State, local or Tribal agency for air pollution control
• your State's Small Business Assistance Program (SBAP)
• local, regional, or National Trade Associations
• your EPA Regional Office
State and local contacts can change frequently. To get the most current contact information, go
to the STAPPA/ALAPCO website (www.4cleanair.org) and then the membership directory. The
directory will give you the latest contact points for major air programs (that is, emission
standards for toxic air pollutants, ozone, etc.) at the State and local level.
If you have questions about this rule, you should
contact your State, local or Tribal agency before
calling the EPA. Their rules may be more
stringent than Federal requirements.
Many States have a Small Business Assistance Program. If you are a small business and do
not know who your SBAP is, you can call EPA's Clean Air Technology Center Hotline at (919)
541-0800 or visit EPA's SBAP at www.epa.gov/ttn/sbap for help.
Contact numbers for EPA's Regional Air Division Offices may also change frequently. To
obtain the most up-to-date information, you may want to visit your Regional Office's website.
Table 10-1 lists each of our Regional Offices, the Air Toxics Division Phone and Address, and
the Regions Internet home page. Make all written inquiries to the attention of "NESHAP (insert
rule name) Contact."
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TABLE 10-1. EPA Regional Air Division Offices
EPA Regional Office - MACT Implementation Contact Division Information*
EPA Region
Region I
Region II
Region III
Region IV
Region V
Region VI
Region VH
Region VIII
Region IX
Region X
States
Covered
CT, ME, MA,
NH, RI & VT
NJ, NY, Puerto
Rico & Virgin
Islands
DE, MD, PA,
VA, WV & DC
AL, FL, GA, KY,
MS, NC, SC &
TN
IL, IN, MI, WI,
MN&OH
AR, LA, NM, OK
&TX
IA, KS, MO &
NE
CO, MT, ND,
SD, UT & WY
AZ, CA, HI, NV,
American Samoa,
&Guam
AK, ID, WA &
OR
Division Phone and
Address
Office of Ecosystem Protection (OEP)
1 Congress Street, Suite 1100
Boston, MA 02114-2023
Attention: NESHAP (MACT) Contact
Division of Enforcement and Compliance Assurance
290 Broadway
2 1st Floor
New York, NY 10007-1866
Air Protection Division, 3 API 1 1
1650 Arch Street
Philadelphia, PA 19103-2029
Air, Pesticides and Toxics Management Division
Atlanta Federal Center
61 Forsyth Street
Atlanta, GA 30303-3104
Air and Radiation Division
77 West Jackson Blvd.
Chicago, IL 60604-3507
Compliance Assurance & Enforcement
Division (6EN)
1445 Ross Avenue
Dallas, TX 75202-2733
Air, RCRA and Toxics Division
901 North 5th Street
Kansas City, KS 66101
Office of Enforcement, Compliance and
Environmental Justice (ECEJ)
999 18th Street
1 Denver Place, Suite 500
Denver, CO 80202-2405
Air Division
75 Hawthorne Street
San Francisco, CA 94105
Air and RCRA Compliance Unit
1200 Sixth Avenue
Seattle, WA 98101
Division Phone /
RO Home Page
(617)918-1510
www. epa.gov/regionl
(212)637-3735
www. epa.gov/region2
(215)814-2056
www. epa.gov/region3
(404) 562-9077
www. epa.gov/region4
(312)353-2212
www. epa.gov/region5
(214)665-72507
(214)665-7220
www.epa.gov/region6
(913)551-7020
www. epa.gov/region 7
(303) 312-70287
(303) 312-6294
www.epa.gov/region8
(415)744-1219
www. epa.gov/region9
(206)553-1505
www. epa.gov/regionl 0
* Information subject to change without notice. For the latest information, please visit the Regional Office Website.
10-2
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Can I get more information on the Web?
You can get a wealth of information on the World Wide Web (WWW). Some of the more
popular ways to get information on this rule include:
• EPA's Air Toxics Website (www.epa.gov/ttn/atw)
You can download copies of preambles, regulations, background information documents,
policy memos, and other guidance materials here. All rule pages can be found under the
Rules and Implementation page. Pesticide active ingredient can be found under
www.epa.gov/ttn/atw/pest/pestpg.html.
• EPA's Applicability Determination Index (ADI)
(http://www.epa.gov/compliance/assistance/applicability/index.html)
EPA responds to written inquiries about the broad range of NSPS and NESHAP
regulatory requirements as they pertain to a specific source. These inquiries may
question whether a regulation applies to a specific source, or may relate to the
construction, reconstruction, modification, testing, monitoring, recordkeeping or
reporting requirements contained in the regulation as it applies to a specific source.
• OECA Compliance Assistance Centers (http://www.epa.gov/epahome/business.htm)
You can find information on compliance with federal regulations at this site. There are
centers for printing, automotive services and repair, agriculture, metal finishing
industries, the chemical industry, printed wiring board manufacture, transportation, and
local governments.
• STAPPA/ALAPCO home page (http://www.4cleanair.org)
STAPPA/ALAPCO is the State and Territorial Air Pollution Program Administrators
(STAPPA) and Local Air pollution Control Officials (ALAPCO) organization.
STAPPA/ALAPCO has members representing each State and local agency for air
pollution control.
You can get air pollution information at this site, including a document entitled
"Communicating Air Quality: A Compendium of Resources. " It lists educational
materials on air pollution that State and local agencies have created.
National Service Center for Environmental Publications (NSCEP) home page at
(http://www.epa.gov/ncepihom) maintains hard and electronic copies of EPA documents.
Additional copies of this document may be obtained free of charge via this website or
ordered by phone at 1-800-490-9198.
• MACT Case Studies for Pharmaceuticals Production, PAI Production, and
Miscellaneous Organic Chemical Manufacturing (EPA 305-B-04-001). This document
may be downloaded from www.epa.gov or ordered from NSCEP.
• National Environmental Compliance Assistance Clearinghouse
(http://cfpub.epa.gov/clearinghouse/). This website provides quick access to compliance
assistance tools, contacts, and planned activities from U.S. EPA, its partners, and other
compliance assistance providers.
10-3
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Is there a list of commonly asked questions?
For a list of questions and answers about the final rule, you will find EPA's "National Emission
Standards for Hazardous Air Pollutants (NESHAP)for Pesticide Active Ingredient Production:
Summary of Public Comments and Responses, May, 1999 (EPA-453/R-98-011) useful. You can
download the document by going to our ATW Pesticide Active Ingredient page at
www. epa. gov/ttn/atw/pest/pestpg. html.
10-4
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Chapter 11 - Supplemental information for State and
local agencies and Tribes
How many facilities may need to meet emission limits?
According to information we collected in 1995, we estimated that approximately 78 pesticide
active ingredient production facilities might be affected by this rule.
EPA's "Enabling Document: Source Identification Procedures for
Sources Subject to Regulations Under Section 112(d) of the Clean Air
Act as Amended in 1990", September 20, 1996 (otherwise known as the
"Cookbook"), can help you identify the steps you can take to locate
more sources.
You can download the cookbook by going to
www.epa.gov/ttn/atw/eparules.html, scroll down until you see "MACT
Implementation Strategy." The cookbook is in Appendix G of this
document.
Who regulates facilities in Indian Country?
The Clean Air Act authorizes the Administrator to treat an Indian tribe in the same manner as a
state for the Clean Air Act if specifically enumerated criteria in 40 CFR 49.3 are met. The EPA
encourages tribes to develop the capacity to administer section 112(d) programs and to request
delegation. Where such programs approval does not exist, the EPA Regional Office is the
regulatory authority. State programs are not applicable in Indian country unless EPA
specifically delegated such authority to a particular state.
How much HAP emissions will the rule reduce?
We estimate that full implementation of the rule will reduce HAP emissions by about 2,760 tons
annually. This represents about a 65 percent reduction from baseline levels prior to
promulgation of the rule. About 47 percent of the reduction is from process vents, 37 percent is
from wastewater, and the remainder is from equipment leaks and storage tanks.
11-1
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